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
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ID: aiam3706OpenMr. C. J. Johnston, Manager, Product Reliability, The BF Goodrich Company, Tire Group, 500 South Main Street, Akron, OH 44318; Mr. C. J. Johnston Manager Product Reliability The BF Goodrich Company Tire Group 500 South Main Street Akron OH 44318; Dear Mr. Johnston: This is in response to your May 12, 1983 letter regarding the tir sidewall molding requirements of the Uniform Tire Quality Grading Standards. In that letter you indicated that, acting in reliance on statements by a NHTSA employee, your company modified certain new tire molds by deleting the numerical treadwear grade from the sidewall label, but leaving the word 'TREADWEAR' in place. NHTSA subsequently stated, in a letter to Toyo Tire Company, that if the sidewall molded label is modified, both the numerical grade and the word 'TREADWEAR' should be deleted. You also indicated that BF Goodrich is now in the process of modifying the molds again to delete the word 'TREADWEAR'.; In light of your good faith reliance on agency statements and you current efforts to conform to the policy stated in our letter to Toyo Tire Company, NHTSA will take no enforcement action regarding sidewall molding requirements for tires produced through the completion of the mold modification process.; For future reference, please be aware formal interpretations of lega requirements are issued only by this office and only in writing. To obtain an interpretation upon which reliance can be placed for purposes of making business decisions, you should direct a letter of inquiry to the Chief Counsel's Office.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0080OpenMr. R. A. Moynihan, Sales Manager - Truck Equipment, ATECO Equipment Company, Post Office Box 8741, Pittsburgh, PA 15221; Mr. R. A. Moynihan Sales Manager - Truck Equipment ATECO Equipment Company Post Office Box 8741 Pittsburgh PA 15221; Dear Mr. Moynihan: This is in further reply to your letter to Mr. Slagle dated March 8 1968, in which you ask for information as to your company's responsibility under the National Traffic and Motor Vehicle Safety Act and regulations issued pursuant to the Act.; As I understand the description of the modification your company make to trucks the only standard now in effect that is applicable is Standard No. 205, the glazing standard. Therefore, the glass that you install in place of the original glass in the truck cab would have to comply with this standard.; Your company might also be affected by the enclosed Advanced Notice o Proposed Rulemaking. Your particular attention is directed to Docket No. 2-12 which would, if finalized, make the standard concerning anchorage of seats (No. 207) applicable to trucks.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel |
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ID: aiam2547OpenMr. Dennis J. Mahr, Attorney at Law, 232 Davidson Building, Sioux City, IA 51101; Mr. Dennis J. Mahr Attorney at Law 232 Davidson Building Sioux City IA 51101; Dear Mr. Mahr: This responds to your February 23, 1977, letter asking whether For Motor Company's record keeping practices conform to the regulations of the National Highway Traffic Safety Administration (NHTSA).; Your letter refers to material allegedly destroyed by Ford pertainin to accident and recall information involving headlamp concealment devices in 1967 Mercury Cougars. The NHTSA is unable to ascertain from the information that you have submitted whether or not Ford's record keeping violates our requirements.; The NHTSA implemented on August 20, 1974, a regulation requirin manufacturers to retain for a period of 5 years records generated or acquired after August 15, 1969, concerning motor vehicle malfunctions that may be related to motor vehicle safety (49 CFR 576, *Record Retention*). Since the recall to which you refer occurred prior to this regulation, it is possible that the identified records were generated or acquired prior to the promulgation of the regulation, and therefore, the destruction of these records would not necessarily mean that Part 576 was violated.; The NHTSA has a public file concerning the headlamp concealment device referred to in your letter. This file containing 26 pages of information will be sent to you by our Technical Reference Branch under separate cover.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5282OpenMs. Lisa A. Norris P.O. Box 41 Mandeville, LA 70470; Ms. Lisa A. Norris P.O. Box 41 Mandeville LA 70470; Dear Ms. Norris: This is in reply to your letter of December 1, 1993 to Robert Hellmuth of this agency. You have written us questioning the disconnection of your original equipment center highmounted stop lamp when an aftermarket spoiler with lamp was installed on your Honda. American Honda has referred you to us, referencing an interpretation by our former Chief Counsel, Paul Jackson Rice. I enclose a copy of Mr. Rice's letter of August 31, 1990, to David Holscher which sets forth the agency's views on this subject. These views remain our position. The disconnecting of your lamp appears permitted under Federal Motor Vehicle Safety Standard No. 108 according to this interpretation. Because Federal authorities do not interpret the laws of the individual States, we are unable to comment on the Louisiana provisions that you paraphrase, except to note that 'tail lights', as you refer to them, are not 'stop lamps' under Standard No. 108. Taillamps are another item of lighting equipment and have no relevance to the wiring of the center highmounted stop lamp. Sincerely, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam5328OpenMr. Perry McGlothan Quality Assurance Test Specialist Century Products Company 9600 Valley View Road Macedonia, OH 44056; Mr. Perry McGlothan Quality Assurance Test Specialist Century Products Company 9600 Valley View Road Macedonia OH 44056; Dear Mr. McGlothan: This responds to your letter to me about the hea impact protection and protrusion limitation requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, Child Restraint Systems. We received under separate cover the three child seats you sent for illustration purposes, samples of Models 4560, 4590 and the STE 1000. You discuss in your letter a new method you would like to use to attach the head impact protection foam to the child restraint shell. The foam would be attached to the shell by means of two push-in pins, each 1/2 inch in length and with a 3/4 inch diameter head, as distinguished from the padding being glued to the shell as in the past. You stated that this change would better secure the foam padding to the shell and help your manufacturing process. You asked us whether the new method would meet the head impact protection requirement of S5.2.3 (for restraints recommended for children weighing less than 20 pounds) and the protrusion limitations of S5.2.4. As you know, the National Traffic and Motor Vehicle Safety Act establishes a self-certification system under which manufacturers are responsible for ensuring that their products comply with all applicable FMVSSs. We do not approve, endorse, or give assurances of compliance of any product. NHTSA may examine the manufacturer's certification in the course of any enforcement action. In response to manufacturers' requests for interpretations of the FMVSS's, we try, to the extent possible, to provide information that will help them make their determinations of compliance. However, these responses are based on information provided by the manufacturer, and is subject to the findings of actual compliance testing by the agency. Should the agency, in the future, examine production units of these models and detect an apparent noncompliance or defect, those results will control. You first inquire, 'Please advise as to compression deflection,' which we understand as asking whether S5.2.3.2 would permit you to secure the foam with the pins. S5.2.3.2 states that each system surface, except for protrusions that comply with S5.2.4, which is contactable by a dummy head must be covered with slow recovery, energy absorbing material with specified characteristics. As explained in the next paragraph, the pins we examined appear to satisfy S5.2.4. Further, the pins might not be contactable by the dummy head in Standard 213's dynamic test. However, whether they are contactable can only be determined in the standard's dynamic test. S5.2.4 requires that any portion of a rigid structural component within or underlying a contactable surface, or any portion of a child restraint system surface that is subject to S5.2.3 shall meet specified limits on height and radius of exposed edge. Based on our visual inspection, the pins we saw appear to be within those limits. Again, however, the Vehicle Safety Act places the responsibility for determining compliance in the first instance on you, the manufacturer of the child restraint. We still have the three seats that you sent us. We plan to dispose of them unless we hear from you. I hope this information is helpful to you. Should you have any further questions or need further information, please feel free to contact Walter Myers of this office at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2117OpenHonorable Jamie L. Whitten, House of Representatives, Washington, D.C. 20515; Honorable Jamie L. Whitten House of Representatives Washington D.C. 20515; Dear Mr. Whitten: This is in further reply to your letter of October 3, 1975, for Mr Charles Russel of WJLJ, regarding tire failures on ambulances in Tupelo, Mississippi.; Pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 the Department's National Highway Traffic Safety Administration (NHTSA) has issued Federal Motor Vehicle Safety Standard No.109, 49 CFR 571.109, which specifies performance and labeling requirements for new tires for use on passenger cars. Among the labeling requirements is that such tires must have their load ratings molded into or onto both sidewalls. Standard No. 119, 40 CFR 571.119, establishes similar requirements for new tires for use on trucks, buses, trailers, motorcycles, and multipurpose passenger vehicles (MPV's). The choice of standard applicable to a given tire depends on that tire's primary intended use. These standards apply to tires, and not to vehicles.; To ensure that new vehicles are equipped with proper tires, the NHTS has also issued Standard No. 110 for passenger cars and a proposed new Standard No. 120 that would apply to vehicles other than passenger cars. Briefly, Standard No. 110 requires each new passenger car to be equipped with tires which meet Standard No. 109 and which are of sufficient load carrying capacity, as evidenced by the load ratings found on the sidewalls. As proposed, Standard No. 120 would require MPV's (including ambulances) to be equipped with tires which meet either Standard No. 109 or No. 119, and which are of sufficient load carrying capacity. In the case of Standard 119 tires, sufficiency of load carrying capacity would be calculated directly from the tires' load ratings. In the case of Standard 109 (passenger car) tires mounted on an MPV, sufficiency would be determined by dividing the tire load ratings by a 110 percent correction factor before comparing these ratings with the vehicle's weight ratings. The use of passenger car tires on new ambulances would thus not be prohibited by the new standard, provided this load rating correction factor is applied. This provision would recognize an established practice which has not been found to present a safety hazard. Passenger car tires generally provide a softer, more comfortable ride than truck tires, because the latter operate at higher inflation pressures, and thus may even more desirable on ambulances, provided they are of adequate load carrying capacity. The NHTSA expects to issue Standard No. 120 in the near future.; For your convenience, I am enclosing copies of Standards Nos. 109, 110 119, and the proposed Standard No. 120.; Sincerely, William T. Coleman, Jr. |
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ID: aiam4610OpenAIR MAIL; AIR MAIL; "Mr. R. Yamauchi Seat Belt Engineering Department Nippon Seiko K.K. 12 Kirihara-cho Fujisawa, JAPAN Dear Mr. Yamauchi: This responds to your letter asking for an interpretation of Standard No. 209, Seat Belt Assemblies (49 CFR /571.209). I regret the delay in responding. Your questions concerned a seat belt assembly that is designed with a dual mode retractor. The retractor for this system generally functions as an emergency locking retractor (ELR). However, the retractor can be converted to an automatic locking retractor (ALR) to facilitate securing a child restraint at that seating position. The retractor converts from an ELR to an ALR when the webbing is completely extended. The retractor converts back to an ELR when most of the webbing has been retracted. You posed the following questions. 1. Is this retractor considered an ELR? If so, is it required to comply with the performance requirements for ELR's, or is it required to comply with the performance requirements for both ELR's and ALR's? Response: Your letter did not provide sufficient information to allow us to answer this question. However, in a July 3, 1984 letter to Mr. Donald Schwentker, we explained the criteria we use to determine whether a dual mode retractor such as you described is considered an ELR or an ALR for the purposes of our safety standards. To briefly restate the criteria, section S4.1(g) of Standard No. 209 specifies adjustment requirements for all seat belt assemblies. We examine the functioning of the retractor during normal operation by occupants within the weights and dimensions set forth in S4.1(g)(3) of Standard No. 209. If 100 percent extension of the webbing is likely to occur during normal operation of the belt assembly by those occupants (thereby converting the retractor into an ALR), the retractor would be considered an ALR. If during normal operation of the belt assembly by the specified occupants the retractor would function exclusively as an ELR, the retractor would be considered an ELR. Using these criteria, the length of the webbing used in the belt assembly will ultimately determine whether a dual mode retractor would be considered an ELR. If the webbing is long enough that a 95th percentile adult male would not extend the webbing 100 percent during normal operations (including fastening and unfastening the belt or leaning forward to adjust the radio or other controls on the instrument panel), the retractor would operate exclusively as an ELR and would be treated as such for the purposes of our safety standards. If, on the other hand, normal operations by a 95th percentile adult male would result in 100 percent extension of the webbing, the retractor would be considered an ALR for the purposes of our standards. Your letter did not provide any information about the length of the webbing to be used in the belt assembly, so we cannot offer any opinion about whether the retractor for the belt assembly would be considered an ELR or an ALR. 2. You noted that section S5.2(k) of Standard No. 209 requires that ELRs be subjected to 45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension. You stated if dual mode retractors were treated as ELRs, this requirement would present serious problems, since 100 percent webbing extension would convert the retractor to an ALR and the subsequent retraction to 50 percent extension would not convert the retractor back to an ELR. Hence, when the webbing returned to 50 percent extension after 100 percent extension, the retractor would be an ALR. In this mode, the retractor would lock the webbing at 50 percent extension and no further cycles would be possible. To avoid this problem, you asked if you could test the retractor by subjecting it to 45,000 additional cycles between 0 percent extension and 100 percent extension. You asserted that this testing should be permitted, because it is a more stringent test of the retractor. Response: This question may reflect a misunderstanding of the differing responsibilities imposed on a manufacturer that is certifying compliance with a safety standard and on the agency when it is testing for compliance with a safety standard. You, as a manufacturer, are not required to conduct testing before certifying that your belt assemblies comply with Standard No. 209. Instead, the National Traffic and Motor Vehicle Safety Act requires that you exercise 'due care' in making such certifications. It is up to the manufacturer in the first instance to determine what data, test results, computer simulations, engineering analyses, or other information it needs to enable it to certify that each of its products comply with all applicable safety standards. If a manufacturer chooses to conduct testing, the manufacturer is free to modify any or all parts of the test procedure specified in the standard, provided that the manufacturer can show that the results obtained using these modified test procedures are sufficient to satisfy the 'due care' standard. You have the responsibility in the first instance to decide whether the substitution of an alternative test is sufficient to establish due care in making certifications based on this modification of the standard. This determination involves assessing whether the results of the alternative test procedure are good predictors of the results of the test procedure specified in the standard. When the agency conducts its compliance testing, however, it is required to follow the compliance tests specified in the applicable standard. Thus, the agency would not substitute cycles between 0 and 100 percent extension for the cycles between 50 and 100 percent extension that are specified in Standard No. 209. If this retractor were treated as an ELR for purposes of Standard No. 209, applying the criteria set forth above in response to your first question, we would test the retractor solely as an ELR. To do this, we would disengage or disconnect the features that convert the retractor to an ALR at 100 percent webbing extension. The retractor would then be tested in accordance with the procedures set forth in S5.2(k) of Standard No. 209. I hope this information is helpful. Please let me know if you have any further questions or need additional information on this subject. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam1412OpenMr. W. G. Milby, Project Manager, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Project Manager Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of December 19, 1973, asking whethe Blue Bird may use the manufacturing date of incomplete vehicles it manufactures, to be completed at a later time, as the date by which conformity to applicable safety standards is to be determined. You indicate that Blue Bird manufactures both incomplete and complete vehicles.; The Certification and Vehicles Manufactured in Two or More Stage regulations (49 CFR Parts, (sic) 567, 568) allow only final-stage manufacturers to certify conformity to applicable standards as of the manufacture date of an 'incomplete vehicle.' A person who manufactures the entire vehicle, including the chassis, is not a final-stage manufacturer within the intent of the regulation, and such a vehicle must be certified as of the date of its completion.; Part 568 clearly intends that multistage vehicles will be manufacture by more than one party. As your letter points out, the documentation required by Part 568 is unnecessary when only one manufacturer is involved. Moreover, the justification in the regulations for allowing a final-stage manufacturer to utilize the manufacture date of the incomplete vehicle is based partially on the fact that he has no control over the configuration of the incomplete vehicle, and that the incomplete vehicle manufacturer has no control over when and how the vehicle is completed. This justification does not exist when a single party builds the entire vehicle.; To permit a manufacturer of a complete vehicle to choose a date othe than the completion date for purposes of conformity would present this agency with serious enforcement problems. Which standards would apply would depend on how 'separate' were a single company's manufacturing operations. Due to the endless possibilities that may arise in this regard, it is difficult to envision fair and objective critieria (sic) by which this decision could be made. Finally, providing the relief you request would allow a manufacturer to avoid compliance with a forthcoming standard by manufacturing large numbers of incomplete vehicles for completion by him at a later time.; You should note that the legal status of Parts 567 and 568 is unclear due to the recent Court decisions in the *Rex Chainbelt* case. You will encounter no problems, however, by continuing to follow the regulations until further agency action is taken.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4240OpenThe Honorable Ted Stevens, United States Senate, Washington, DC 20510; The Honorable Ted Stevens United States Senate Washington DC 20510; Dear Senator Stevens: Thank you for your letter on behalf of your constituent, Ms. Bridge Ernst, regarding our regulations for safety belts on school buses. Your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.; In her letter to you, Ms. Ernst enclosed materials issued by th National Coalition for Seat Belts on School Buses which explained why the Coalition believes safety belts should be required by Federal law on all school buses. You asked us to discuss the main counter-arguments against such a requirement, and asked also whether any Federal legislation has been introduced recently to increase the safety requirement on school buses. I am pleased to respond.; I would like to begin with some background information on our schoo bus regulations. The National Traffic and Motor Vehicle Safety Act of 1966 authorizes NHTSA to issue motor vehicle safety standards for new motor vehicles, including school buses. Pursuant to that authority, NHTSA issued a comprehensive set of motor vehicle safety standards to improve school bus safety. Our school bus safety standards apply to various aspects of vehicle performance, including school bus windows and windshields, emergency exits, fuel systems and passenger seating and crash protection.; The safety belt issue your constituent raises involves the safet standard we issued for school bus passenger crash protection, Federal Motor Vehicle Safety Standard No. 222. Standard No. 222 requires that large school buses provide passenger crash protection through a concept called 'compartmentalization.' Compartmentalization requires that the interior of the school bus be improved with protective seat backs, additional seat padding, and better seat spacing and performance. These interior features are intended to keep occupants in their seating area during an accident. They ensure that a system of crash protection is provided to passengers independent of their actions to use safety belts. Standard No. 222 requires safety belts for passengers in smaller school buses since belts are needed on those vehicles to provide adequate crash protection.; The information from the Coalition that Ms. Ernst enclosed in he letter to you states that safety belts are needed on all school buses to protect children and keep them within their seating compartment in the event of a collision or rollover. We believe that effective passenger crash protection and containment is already provided by compartmentalization and that it would be inappropriate to issue a Federal mandate for safety belts on all school buses. While the effects of compartmentalization are expected to be greater in crashes involving front or rear impacts, the standard also has potential in side impacts and rollovers by minimizing the 'hostility' of the crash environment and by limiting the range of movement of an occupant in those two types of crashes.; For your information, I have enclosed a DOT report, 'Seat Belts i School Buses' (June 1985), which provides a thorough discussion of the safety belt issues raised by your constituent. As explained in the report, school buses in this country have compiled an excellent safety record. In addition to meeting compartmentalization requirements, large school buses incorporate more safety by virtue of their greater mass, higher seating height and high visibility to other motorists. Thus, the need for safety belts to mitigate against injuries and fatalities is not the same as that for other vehicles, such as passenger cars. Because the safety record of large school buses is very good, we must conclude that a Federal requirement for the installation of safety belts is not justified at this time.; The Coalition's material enclosed by Ms. Ernst included a statemen indicating that NHTSA 'supports local district seat belt programs.' NHTSA permits the voluntary installation of safety belts for passengers on large school buses if the purchaser wishes to have belts installed. We believe that such a decision should be made by individual schools and school districts that have made a reasoned assessment of their particular pupil transportation needs. However, because there are many effective ways to improve pupil transportation safety, such as improving driver training and school bus maintenance programs, it would be inappropriate for us to endorse local district programs for safety belts on school buses. Therefore, for purposes of clarification, we neither support nor discourage school districts' decisions to install safety belts on their large school buses.; You asked about any Federal legislation that had been recentl introduced to increase the safety of school buses. The Administration has not proposed any legislation affecting school buses. However, two bills were introduced in the 99th Congress concerning school buses. H.R. 3129 contained a provision calling for a school bus safety study to determine the measures most effective in protecting the safety of school children. H.R. 749 proposed incentive grants to the States encouraging the adoption and enforcement of laws requiring the use of safety belts in school buses. Neither H.R. 3129 nor H.R. 749 was enacted.; In addition, NHTSA has issued a notice of proposed rulemaking to amen Standard No. 222 by setting performance requirements for safety belts voluntarily installed in large school buses. If adopted, this rule would require safety belts voluntarily installed on new large school buses to meet Federal safety belt standards for strength and proper installation.; We are evaluating the comments submitted on our proposal and a fina decision on the rulemaking action is expected in the near future.; I hope this information is helpful. Please contact my office if we ca be of further assistance.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3585OpenMr. Ron Gustafson, Furudals Buruks Kursinternat, 790 70 FURUDUAL Sweden; Mr. Ron Gustafson Furudals Buruks Kursinternat 790 70 FURUDUAL Sweden; Dear Mr. Gustafson: This responds to your letter of June 28, 1982, asking abou requirements applicable to child restraints sold in the United States as well as any necessary permits or licenses. You also asked about any U.S. testing organizations, procedures or standards for child restraints.; All child restraints sold in the U.S. must conform with the minimu performance requirements of Federal Motor Vehicle Safety Standard No. 213, *Child Restraint Systems*. The standard also sets out the test procedures that are used to measure the performance of child restraints. There are no other performance requirements or test procedures applicable to child restraints. I am enclosing a copy of the standard.; You are not required to obtain a permit or license from this agenc prior to selling a child restraint in the U.S., nor are you required to obtain approval from any U.S. testing organization. As a manufacturer of motor vehicle equipment, you are required by Part 566, *Manufacturer Identification*, of our regulation to submit certain identifying information to the agency. I have enclosed a copy of Part 566.; In addition, you would be required by the National Traffic and Moto Vehicle Safety Act (15 U.S.C. S1392 *et seq*.) to certify that your child restraint complies with all applicable Federal Motor Vehicle Safety Standards. Under the Act, you would also be responsible for conducting a notification and remedy campaign for any safety-related defect in your product. I am enclosing a copy of the Act, which defines your responsibilities as a manufacturer.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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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.