NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: nht89-2.29OpenTYPE: Interpretation-NHTSA DATE: July 6, 1989 FROM: Bob Jones -- Triple J Motors Saipan, Inc. TO: Ben Blas -- Congressman TITLE: Re Ref: 704-11 ATTACHMT: Attached to letter dated 7-5-90 from Robert H. Jones to Director, Office of Vehicle Safety Compliance Enforcement, NHTSA; Also attached to letter dated 3-11-91 from Paul Jackson Rice to Robert H. Jones (A37; VSA Sec. 103(8)); Also attached to l etter dated 1-22-91 from Robert H. Jones to Clive Van Orden (OCC 5733); Also attached to letter dated 12-11-90 from Robert H. Jones to Clive Van Orden; Also attached to letter dated 10-11-90 from Robert H. Jones to Congressman Ben Blaz TEXT: I am enclosing copies of a number of letters which create more confussion than they eliminate. The problem is quite simple. Triple J Motors on Saipan is in compliance with FMVSS and FMCSR Safety and EPA Regulations with all vehicles which we sell. No other dealer is 100% in compliance. All have sold or are selling vehicles which do not meet the Department of Transportation Safety Requirements and/or EPA Regulations. I want one of two things; either the Federal Government, through its U.S. Attorneys Office, should enforce the laws or set them aside so we all can play on a level ground. I am afraid to violate the regulations and wind up in a law suit as a result of a n accident or some late late action from the Federal Government. Any assitance you can give would be greatly appreciated. We don't care which way it goes; just a clarification that the CNMI must comply and enforce the regulations or that the regulations don't apply, so that we can import the same non compliance type of vehicles as the competition. |
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ID: 1985-04.30OpenTYPE: INTERPRETATION-NHTSA DATE: 11/18/85 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Finbarr J. O'Neill TITLE: FMVSS INTERPRETATION TEXT:
November 18, 1985 Finbarr J. O'Neill General Counsel Hyundai Motor America P.O. Box 2669 Garden Grove, California 92642-2669 Dear Mr. O'Neill: September 18, 1985, to Mr. Vinson of this office, asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to application of the "DOT" symbol to lighting equipment. You first ask for confirmation of your interpretation that Standard No. 108 does not require the DOT symbol on original equipment lenses of lamps other than headlamps. That is correct; the general certification of the vehicle manufacturer that its product complies with all applicable Federal motor vehicle safety standards is inclusive of all original equipment and of all requirements of the specific standards such as the color requirements for lenses imposed by Standard No. 108. You have also asked for confirmation that under Standard No. 108 the marking of replacement lenses with the DOT symbol is optional. That is correct; the other permissible certification options for replacement lenses are those imposed by 15 U.S.C. 1403, certification in the form of a label or tag on the lens itself or the container in which it is shipped. Finally, you have asked whether the National Highway Traffic Safety Administration can comment on whether it intends to propose mandatory marking of lenses in the near future. We have received a petition for rulemaking to amend Standard No. 108 to require items of replacement lighting equipment to be marked with the DOT symbol. However, the agency has not announced a decision on the petition at this time. Sincerely, Original Signed By Erika Z. Jones Chief Counsel |
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ID: 1985-04.40OpenTYPE: INTERPRETATION-NHTSA DATE: 11/29/85 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Mr. M. Iwase TITLE: FMVSS INTERPRETATION TEXT:
November 29, 1985 Mr. M. Iwase Manager, Technical Administration Dept. Koito Manufacturing Co., Ltd. Shizuoka Works 500, Kitawaki Shimizu-shi, Shizuoka-ken Japan Dear Mr. Iwase: This is in reply to your letter of September 20, 1985, to the former Chief Counsel of this agency, Frank Berndt, asking for a clarification of requirements for motorcycles equipped with two headlamps. You have informed us that your two-headlamp design complies with the photometric requirements of Motor Vehicle Safety Standard No. 108 (i.e., the at focus and out of focus tests of SAE J584) when the photometric measurements are made with reference to the photometric reference to the photometric reference axis of the individual headlamp unit. However, if this measurement is made at the combined axis, the combined maximum value of the upper beam will exceed 75,000 candela. Photometric measurements are to be made with reference to the photometric reference axis of the individual headlamp unit. Under Standard No. 108, however, the maximum candlepower of each unit on the upper beam is not to exceed 75,000. The fact that the combined maximum value of your system exceeds 75,000 candlepower. However, if the motorcycle headlamp is one consisting of two bulbs in a single housing, then the measurement is made at the combined axis of the two bulbs and the combined candlepower of this two-bulb single headlamp cannot exceed 75,000 candlepower. I hope that this answers your question. Sincerely, Original Signed By Erika Z. Jones Chief Counsel |
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ID: 86-3.23OpenTYPE: INTERPRETATION-NHTSA DATE: 05/12/86 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Ms. Mary Fulton TITLE: FMVSS INTERPRETATION TEXT:
May 12, 1986 Ms. Mary Fulton Willas USA 8933 Quartz Avenue Northridge, California 91324 Dear Ms. Fulton: This is in reply to your letter of March 24, 1986, enclosing a brochure on your new product "TaleLights," and asking our "opinion of the product's legal standing." The brochure describes TaleLights as a "multi-message signboard" which is mounted "in the same rear window area where the new mandatory 'extra' brakelights are placed." TaleLights features automatically-activated messages such as "STOP," and manually activated ones such as "OOPS! SORRY." The Federal requirements for motor vehicle lighting (Federal Motor Vehicle Safety Standard No. 108) presently cover aftermarket lighting equipment only to the extent that it is intended to replace lighting equipment that is originally installed on a vehicle in compliance with Standard No. 108. We assume from your brochure that your product is intended for installation in vehicles not originally equipped with center high-mounted stop lamps, and under this assumption, your aftermarket product would not be covered by our requirements. It is, however, subject to the laws of each State in which it is to be sold and operated, and we suggest that you contact the motor vehicle administrators of States where you intend to market TaleLights. Your lamp is not an acceptable substitute for a center high-mounted stop lamp and it would be a violation of the National Traffic and Motor Vehicle Safety Act for a dealer, distributor, manufacturer, or motor vehicle repair business to remove a center high-mounted stop lamp and to replace it with TaleLights. Sincerely, Original Signed By Erika Z. Jones Chief Counsel |
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ID: GF0044754OpenMr. Russ Hunt Dear Mr. Hunt: This is in response to your e-mail of July 13, 2004, in which you seek clarification of certain regulations pertaining to retreaded tires. Specifically, you ask whether it is permissible to remove or obscure certain information originally located on the sidewall of a medium truck tire during the retreading process. By way of background, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements. The issues raised by your letter are addressed below. There is no FMVSS applicable to retreaded tires for vehicles other than passenger cars. However, 49 CFR 574.5 does require each tire sold in the United States, including retreaded medium truck tires, to be labeled with Tire Identification Number (TIN) in order to facilitate a recall in the event of a defect. The DOT symbol located on the sidewall of a medium truck tire may either remain or be removed from that tire prior to retreading (see 574.5, enclosed). With respect to other information located on the tire sidewall, including manufacturer name, ply rating, and maximum pressure, no regulation requires retreaded tires (for vehicles other than passenger cars) to show this information, and no regulation prohibits a retreader from removing this information. I hope you find this information helpful. If you have further questions, you may contact Mr. George Feygin of my staff at (202) 366-2992. Sincerely, Jacqueline Glassman Enclosure |
2004 |
ID: 21111.ztvOpenMr. Tadzio Suzuki Re: Motorcycle turn signal lamps Dear Mr. Suzuki: This is in reply to your letter of December 17, 1999, asking whether a turn signal lamp design is in accordance with Federal Motor Vehicle Safety Standard No. 108. The turn signal lamp system consists of two lamps and is intended for use on motorcycles. In Stanley's design, the turn signal lamp contains two filaments, one performing the turn function and the other functioning as a "parking lamp." The parking lamp meets the requirements of Standard No. 108. You later describe the parking lamp as "operating continuously." When the turn signal is activated, the parking lamp function is turned off in the turn signal lamp, while it continues to function in the other turn signal lamp. In your opinion,
We regard the Stanley turn signal lamp design as incorporating an auxiliary function not required by Standard No. 108 for motorcycles. Under S5.1.3, this is acceptable if it does not impair the effectiveness of the required lighting equipment. We do not believe that the "parking" system you describe would have an impairing effect, and conclude that it is permissible under Standard No. 108. Sincerely, |
2000 |
ID: 77-1.47OpenTYPE: INTERPRETATION-NHTSA DATE: 03/17/77 FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA TO: Lucas Industries North America, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your February 4, 1977, question whether Safety Standard No. 116, Motor Vehicle Brake Fluids, permits DOT 3 and DOT 4 brake fluids to be colored "fluorescent yellow." The answer to your question is yes. Paragraph S5.1.14 of Standard No. 116 specifies that DOT 3 and DOT 4 fluids manufactured on or after September 1, 1978, shall be "colorless to amber." The agency interprets this color range to include any "yellow," whether or not fluorescent. Although not required, we consider fluorescence to be an added safety factor since it would facilitate the detection of leaks in the braking system. Sincerely, ATTACH. Office of the Chief Counsel -- National Highway Traffic Safety Administration Dear Sir Federal Motor Vehicle Safety Standard No. 116 - Brake Fluids Girling Limited manufactures motor vehicle brakes in the United Kingdom and also markets brake fluid. Girling Limited, like ourselves, is a subsidiary of Lucas Industries Limited of England. Girling products enter this country as original equipment on imported vehicles and, also, we import and market their products. We wish to know whether "fluorescent yellow" is an acceptable color for DOT 3 and DOT 4 motor vehicle brake fluids. The definition of clear-to-amber does not make this apparent. Yours truly LUCAS INDUSTRIES NORTH AMERICA INC; A J Burgess -- Vice President (Technical) cc: F Redler, NHTSA |
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ID: 77-2.19OpenTYPE: INTERPRETATION-NHTSA DATE: 04/28/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Onics Holdings, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your March 29, 1977, letter asking whether several vehicles that you describe would be considered "vehicles other than passenger cars" for purposes of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. Vehicles other than passenger cars includes: multipurpose passenger vehicles, trucks, buses, motorcycles, and trailers, all of which are defined in the Code of Federal Regulations, Title 49, Part 571.3. Since the vehicles you describe appear to fall within the definition of multipurpose passenger vehicle or truck, they are considered "vehicles other than passenger cars." Accordingly, they must comply with the rim marking requirements of Standard No. 120. SINCERELY, ONICS HOLDINGS INC. March 29, 1977 NHTSA Office of the Chief Counsel I note that for wheel rim marking purposes you define a "vehicle other than passenger car" as a "multipurpose passenger vehicle (MPV), truck, bus, motorcycle, or trailer". Would you be kind enough to give me a ruling as to whether the following vehicles fall into this category: General Motors Pickups, Type C and K (100 Series) General Motors Blazers, Type C and K (100 Series) General Motors Suburban, Type C and K (100 Series) General Motors Vans, Type G (100 Series) Similar vehicles made by other manufacturers I would appreciate a reply at your earliest convenience as the matter is urgent. Stuart A. Mossman President |
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ID: 77-2.29OpenTYPE: INTERPRETATION-NHTSA DATE: 05/05/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: D. G. Moore - Dry Launch TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 7, 1977, asking for a clarification of S4.3.1.1.1 of Standard No. 108. Your initial question of December 27, 1976, was not clear to us hence the reason my answer of March 4, 1977, caused you some confusion. The diagram in your letter of April 7 clearly depicts the exemption provided by S4.3.1.1.1 for the specific reasons therein, that when a clearance lamp indicating overall width is not located on the rear of a vehicle it need not be visible at 45 degrees inboard. As the only required points of photometric measurement of a clearance lamp so located are to the rear and at 45 degrees outboard, the lamp need not be visible at any point in the 45 degree arc depicted in your letter. SINCERELY, DRY LAUNCH April 7, 1977 Frank Berndt Acting Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Admin. Refering to your letter of March 4, 1977, #N40-30 (ZTV) the last two paragraphs dealt with my question - if it were permissible to eliminate photometric requirements in the "shaded" area provided for in the November 1975 amendment (S4.3.1.1.1). I'm afraid your answer was not clear to me and I can't say if you said it was permissible or not. Would you please clarify. Dennis G. Moore Does this area have photometric requirements when applied to the O.E.M. level? (Graphics omitted) |
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ID: 77-2.35OpenTYPE: INTERPRETATION-NHTSA DATE: 05/17/77 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Caron Service Center TITLE: FMVSS INTERPRETATION TEXT: This responds to your April 1, 1977, letter asking where you can obtain vehicle certification forms and a permit to undertake modifications of trucks to lengthen and shorten their frames. The National Highway Traffic Safety Administration (NHTSA) promulgates regulations pertaining to vehicle safety. It is the responsibility of manufacturers to comply with the requirements of the agency. The NHTSA does not license manufacturers or alterers. Accordingly, you need not obtain a Federal permit to alter trucks in the manner you propose. Similarly, the NHTSA does not supply forms for vehicle certification. You may have these forms printed in the form provided by Part 567, Certification, of our regulations (copy enclosed). The type of manufacturing operation you describe would place upon you responsibility, as an alterer of the vehicle prior to first purchase for purposes other than resale, to ensure that the vehicle continues to comply with all applicable safety standards after your modifications. Under Part 567 of our regulations, you must attach a label to the vehicle that states that, as altered, the vehicle continues to conform to the standards. I am enclosing an information sheet detailing where to obtain motor vehicle safety standards and regulations. SINCERELY, VEHICLE CERTIFICATION COMPLETED VEHICLE MANUFACTURED BY: DATE OF COMPLETION: INCOMPLETE VEHICLE MANUFACTURED BY: DATE INC. VEHICLE MFG GROSS VEH. WEIGHT RATING GROSS AXLE WEIGHT RATING THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT IN VEHICLE ID NUMBER: TYPE VEHICLE CLASSIFICATION: ( ) TRUCK ( ) BUS ( ) MPV |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.