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: aiam4349OpenMr. Alberto Negro, Fiat Research & Development - USA Branch, Parklane Towers West, Suite 1210, Dearborn, MI 48216; Mr. Alberto Negro Fiat Research & Development - USA Branch Parklane Towers West Suite 1210 Dearborn MI 48216; Dear Mr. Negro: This is in response to Mr. Rossi's request for an interpretation of th Federal motor vehicle theft prevention standard (49 CFR Part 541), which he asked that I direct to you. That standard requires that certain parts of high-theft carlines, including the engine and transmission, be marked with the vehicle identification number, if the part is an original equipment part, or with the letter 'R' and the manufacturer's trademark, if the part is a replacement part. Mr. Rossi stated that it is occasionally necessary to remove the original equipment engine or transmission from one of these cars and install a replacement engine or transmission in the car. The original equipment engine and/or transmission is then sent to the factory to be repaired and reconditioned. Following such repair, the engine and/or transmission is then put into the replacement parts network.; Mr. Rossi stated his belief that the original equipment part shoul have the original equipment identification removed and a replacement marking put onto the part. He then asked whether Ferrari was required to remove the footprint left by the original equipment identification marking or if that should be left on the part. The answer is that Ferrari and all other reconditioners are *not* permitted to remove from any reconditioned part the original equipment identification marking inscribed or affixed to the part in compliance with Part 541. Further, reconditioners are not required to inscribe or affix any additional markings to parts they have reconditioned. Title II of the Motor Vehicle Theft Prevention Standard of 1984 (Pub. L. 98-547, the Theft Act) includes a provision that addresses this question. This section (18. U.S.C. 511) reads as follows:; S511. *Altering or removing motor vehicle identification numbers* >>>(a) Whoever knowingly removes, obliterates, tampers with, or alter an identification number for a motor vehicle, or motor vehicle part, shall be fined not more than $10,000 or imprisoned not more than five years, or both.; (b)(1) Subsection (a) of this section does not apply to a removal obliteration, tampering, or alteration by a person specified in paragraph (2) of this subsection (unless such person knows that the vehicle or part involved is stolen).; (2) The persons referred to in paragraph (1) of this subsection are - (A) a motor vehicle scrap processor or a motor vehicle demolisher who complies with applicable State law with respect to such vehicle or part, (B) a person who repairs such vehicle or part, if the removal, obliteration, tampering, or alteration is reasonably necessary for the repair, and (C) a person who restores or replaces an identification number for such vehicle or part in accordance with applicable State law.<<<; None of the exceptions set forth in 18 U.S.C. 511(b)(2) would permi Ferrari to routinely remove original equipment markings from reconditioned engines and transmissions. The first exception is not applicable, since Ferrari is clearly not a motor vehicle scrap processor or demolisher. The second exception would be applicable only in rare instances, since it is not usually necessary to remove the original equipment identification marking in order to recondition engines or transmissions. The third exception was explained as follows in the House Report on the Theft Act (H.R. Rep. No. 1087, 98th Cong., 2d Sess., at 24 (1984)): 'The exemption also applies to persons acting under the authority of the Secretary of Transportation or State law to restore or replace such markings.' For the policy reasons discussed below, we will not give reconditioners authority to routinely remove original equipment identification markings from engines and transmissions. Assuming Ferrari does not have authority under applicable State law to remove such markings, the third exception does not apply to Ferrari when it is reconditioning engines and transmissions.; If reconditioners of engines and transmissions were allowed t routinely remove the original equipment identification markings, the law enforcement purposes of the Theft Act would be seriously undermined. In response to some comments received on the proposed Part 541, a new S541.6(b) was added to the final rule. This section expressly prohibits covered major parts from being marked as both original equipment and replacement parts. The preamble to the final rule explained the reasons for prohibiting such 'dual markings' as follows:; >>>Dual markings would give thieves the opportunity to present stole original equipment parts as properly marked replacement parts. Once the original equipment identification (the VIN) had been obliterated from those stolen parts, a legitimate replacement part marking would remain. Assuming that the obliteration of the VIN were performed reasonably proficiently, repair shops and investigators would have little reason to suspect that this part was anything other than a properly identified replacement part. 50 FR 43178, October 24, 1985.<<<; These same law enforcement concerns would arise if Ferrari were t remove the VIN markings from its reconditioned engines and transmissions. If those parts were marked as both original equipment and replacement parts, the problems associated with dual markings would arise. If, on the other hand, Ferrari were to try to obliterate the footprint from the original equipment, law enforcement officials would have no means of distinguishing engines Ferrari had reconditioned from stolen engines on which thieves had obliterated the original equipment marking and added a counterfeit replacement marking. In either case, it would cause confusion and uncertainty for law enforcement officials if Ferrari and the large number of other reconditioners were legitimately and routinely to remove the original equipment identification from reconditioned parts and add a replacement part marking to those parts.; Indeed, such action by reconditioners would serve to defeat the purpos of the Theft Act, which was to 'decrease the ease with which stolen vehicles and their major parts can be fenced.' If reconditioners routinely removed the original equipment markings from the engines and transmissions they reconditioned, car thieves could also remove those original equipment markings with impunity. If the thieves were ever questioned by law enforcement officials about the obliterated original equipment marking, they could respond that the marking must have been obliterated during reconditioning. If obliterated original equipment markings on parts do not provide law enforcement officials with evidence of illegal activity, there would seem to be no reason to require the original equipment markings on the parts.; Further, a requirement that all persons reconditioning engines an transmissions obliterate the original equipment marking and add a replacement part marking would impose significant additional costs and burdens on those persons. This would be inconsistent with the Theft Act's stated purpose of minimizing regulation of the aftermarket motor vehicle industry.; All of these potential problems can be avoided if reconditioners simpl leave the original equipment marking on the parts after reconditioning. When those markings are left in place by reconditioners, thieves cannot claim that an engine or transmission that has a 'footprint' in the area where the original equipment identification is placed is just a reconditioned part. Instead, the 'footprint' would alert law enforcement officials to the likelihood that the original equipment marking had been unlawfully removed from the part. Further, no burdens are imposed on reconditioners if they must leave the original equipment markings in place and are not required to add any markings of their own. Therefore, we conclude that the Theft Act and Part 541 require that businesses that recondition any major parts required to be marked pursuant to Part 541 leave those markings in place on the reconditioned parts. Part 541 does not require reconditioners to add any further identification markings to these parts.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3176OpenMr. K. W. Schang, Director, Vehicle Safety Programs, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. K. W. Schang Director Vehicle Safety Programs American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Schang: This responds to your recent letter requesting an interpretation of th warning system requirements for seat belts in Federal Motor Vehicle Safety Standard No. 208. The buckles of driver lap belts in all AMC vehicles and most Jeep vehicles are equipped with switches that prevent the audible belt use warning system from operating when the driver turns the ignition on after having fastened his or her lap belt. You ask whether the standard allows removal of the switch and associated wiring. The effect of this step, which would result in a savings of about $1.50 per vehicle, would be that the warning would operate regardless of whether the driver has fastened his or her lap belt. You also ask that your letter be considered a petition for rulemaking if this removal is not permissible.; Paragraph S7.3 of the standard requires a seat belt warning system tha activates a 4 to 8-second warning light when the vehicle's ignition switch is moved to the 'on' or 'start' position (condition 'a'), and a 4 to 8-second audible signal when condition 'a' exists and the driver's lap belt is not fastened (condition 'b'). Under your proposal, the audible signal would be activated when both conditions exist. However, it would also be activated when condition 'a' alone exists.; The functioning of the audible signal when condition 'a' only exists i not permissible under the standard. The rulemaking notices which led to adoption of the current requirement stated that the agency's intent was that the audible signal operate if the driver's lap belt is not in use. The agency expressed that same intent in the standard by specifying the light to function when condition 'a' existed and the audible signal when both conditions 'a' and 'b' existed. To interpret the standard to permit the signal to operate when condition 'a' only existed would be to render purposeless the specification of condition 'b'.; Further, the agency denies your petition to amend FMVSS 208 to permi operation of the audible signal when condition 'a' only exists. A greater limitation was placed on the operation of the audible warning signal in consideration of the irritation factor associated with the signal but not with the light. To provide a reminder and incentive for safety belt use and to avoid subjecting the conscientious belt user to having to hear an audible reminder to do something that he or she has already done, the agency specified that the signal would not function if the driver's safety belt were fastened.; In light of studies concerning the value of a properly designed bel use warning system in improving the rate of belt use, the agency is contemplating including a proposal to amend the FMVSS 208 warning requirements when it issues its forthcoming notice of proposed rulemaking on seat belt comfort and convenience. We would welcome your views on the proposal following its announcement.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4719OpenMr. Mehid Rowghani Dallas European Parts Distributors 1505 Wallace Drive Carrollton, TX 75006; Mr. Mehid Rowghani Dallas European Parts Distributors 1505 Wallace Drive Carrollton TX 75006; Dear Mr. Rowghani: This is in reply to your letter of January 9, 1990 to Taylor Vinson of this Office. You have asked whether 'importation and sale of European doors (without reinforcement bars) is in accordance with the rules and regulations of the Department of Transportation.' Your question appears premised upon the fact that many European passenger cars achieve compliance with Federal Motor Vehicle Safety Standard No. 214 Side Door Strength by being equipped with doors incorporating reinforcement bars. However, this standard applies only to new vehicles, and does not extend to replacement parts for such vehicles. Thus, if damage to a vehicle is such that its original door must be replaced, and that door incorporated a reinforcing bar, there is no requirement that the replacement door restore the vehicle to a condition in which it continues to meet Standard No. 214. In short, the importation and sale of a replacement door that does not incorporate a reinforcing bar does not violate any of the statutes, standards, or other regulations administered by this agency. If the replacement door is intended for use on a passenger car line that is subject to the Federal Motor Vehicle Theft Prevention Standard that this agency administers, however, you should be aware that it must nevertheless be marked with the registered trademark of the manufacturer of the door, or unique identifier if there is no registered trademark, and the letter 'R'. I enclose a copy of the standard for your information, as this requirement is a relatively new one, and may not be clearly understood. This marking must be on the door before the door is imported into the United States. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure (Part 541); |
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ID: aiam3526OpenMr. William E. Lawler, Specifications Manager, Indiana Mills & Manufacturing, Inc., 120 West Main Street, Carmel, IN 46032; Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing Inc. 120 West Main Street Carmel IN 46032; Dear Mr. Lawler: This responds to your recent letter asking whether the requirements o paragraph S7.1.1.3 of Safety Standard No. 208, *Occupant Crash Protection*, apply to motor homes and school buses with a GVWR of 10,000 pounds or less. It is your assumption that only those vehicle applications which must have seat belt assemblies meeting S7.1 generally are required to have emergency locking retractors on lap belts.; Your interpretation is incorrect. It is true that belt assemblie installed pursuant to S4.2.1.2 are not required to comply with paragraph S7.1.1 of Standard No. 208, since that paragraph states that it is applicable to lap belts installed pursuant to S4.1.1 and S4.1.2. However, paragraph S7.1.1.3 is not so limited. It states that:; >>>A lap belt installed at any front outboard designated seatin position in a vehicle manufactured on or after September 1, 1982, shall meet the requirements of this section by means of an emergency-locking retractor that conforms to Standard No. 209.<<<; This means that S7.1.1.3 applies to all lap belts installed in an vehicle in compliance with the standard, including belts installed under S4.2.1.2. Therefore, both motor homes and school buses with a GVWR of 10,000 pounds or less would have to comply with the requirement.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5558OpenMr. R. F. Tolley Senior Development Engineer New Products Office Magneti Marelli UK Ltd. Lighting Division Walkmill Lane, Cannock Staffordshire WS11 3LP England; Mr. R. F. Tolley Senior Development Engineer New Products Office Magneti Marelli UK Ltd. Lighting Division Walkmill Lane Cannock Staffordshire WS11 3LP England; "Dear Mr. Tolley: This responds to your letter of April 28, 1995 asking for an interpretation of the torque deflection test specified in paragraph S7.8.5.1 of Motor Vehicle Safety Standard No. 108. The second sentence of this paragraph states that 'The downward force used to create the torque shall be applied parallel to the aiming reference plane, through the aiming pads, and displaced forward using a lever arm such that the force is applied on an axis that is perpendicular to the aiming reference plane and originates at the center of the aiming pad pattern.' You believe that the instructions for performing the test are not sufficiently precise and can be interpreted in different ways. Specifically, you are concerned that the standard fails to adequately define the center of rotation of force, which is necessary to determine the downward force applied to the headlamp. We agree with you, and are examining ways in which the standard might be amended to address the problem you have brought to our attention. Noting that you have presented four possible answers (as well as 'some other point'), our comment is that, until NHTSA clarifies the matter, a manufacturer should choose a center of rotation that appears the most appropriate for the design of mechanically aimable headlamp under consideration, in certifying that the headlamp meets all applicable Federal motor vehicle safety standards. I am sorry that we could not be more helpful at this point. If you have any questions you may refer them to Taylor Vinson of this office (202-366-5263). Sincerely John Womack Acting Chief Counsel"; |
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ID: aiam1848OpenMr. G. Meier, Technical Service Manager, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. G. Meier Technical Service Manager Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Meier: This is in reference to your safety defect notification and remed campaign (NHTSA No 75-0022) concerning a nut used to secure the front exhaust pipe bracket to the automatic transmission housing which may loosen.; The letter which you have sent to the owners of the subject vehicle does not entirely meet the requirements of section 153 of the 1974 amendment to the National Traffic and Motor Vehicle Safety Act of 1966. Specifically, your letter fails to inform recipients that they may notify the Secretary of Transportation if they are unable to have the defect remedied without charge, as required by section 153(a)(6). The address for this purpose may be given as: Administrator, National Highway Traffic Safety Administration, Washington, D. C. 20590. We also believe that your statement, 'although the possibility of a fire is remote,' is a disclaimer, and is prohibited by 49 CFR S577.6. Likewise use of the word 'may' in your second sentence implies that possibly a defect does not exist and is therefore also prohibited. Your letter also fails to contain an evaluation of the risk to motor vehicle safety as required by section 153(a)(2).; It is therefore necessary that you revise the owner notification lette and send a copy to each owner whose vehicle has not yet been corrected. A copy should also be sent to this office.; If you desire further information, please contact Messrs. W. Reinhar or James Murray of this office at (202) 426-2840. A copy of the 1974 amendment is enclosed.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam3875OpenMr. Verne L. Freeland, P.O. Box 693652, Miami, FL 33269; Mr. Verne L. Freeland P.O. Box 693652 Miami FL 33269; Dear Mr. Freeland: This responds to your letter to Mr. Radovich of the Rulemaking divisio of this agency, requesting an interpretation of the requirements of Standard No. 213, *Child restraint systems* (49 CFR S571.213). Specifically, you stated that you had developed a child restraint system which was built into the vehicle seat, and asked how to proceed to have this child restraint certified as complying with Standard No. 213. As currently written, Standard No. 213 does not accommodate your type of restraint.; A manufacturer of a child restraint system is required to certify tha each child restraint system manufactured by it complies with all of the requirements of Standard No. 213, and adding a statement to that effect to the label required by section S5.5 of the Standard. This certification need not be based on actual test results, NHTSA only requires that the certification be made with the exercise of due care on the part of the manufacturer. It is up to the individual manufacturer to determine what test results, engineering analysis, or other data would be sufficient to enable it to meet the due care requirement in certifying that its child restraints comply with the standard. Certainly, we would recommend that a manufacturer marketing a new child restraint design test that restraint in accordance with the test procedures specified in the standard.; As you will see from the enclosed copy of Standard No. 213, Sectio S5.3.1 of the standard requires each child restraint system to be capable of being restrained by a type 1 seat belt system. In addition, the test procedures in section S6 specify that the child restraint is to be tested by attaching it to a standard vehicle seat solely by the vehicle seat's lap belts. Your design, which incorporates the restraint into a vehicle seat, could not be attached to a standard vehicle seat by means of lap belts.; Standard No. 213 would have to be amended in order for you to be abl to certify that your child restraint satisfies all the requirements of that standard. 49 CFR Part 552, *Petitions for Rulemaking, Defect, and Noncompliance Orders* (copy enclosed) gives interested persons the right to petition this agency for amendments (sic) a safety standard, and sets forth the required contents of the petition, the address to which it should be sent, and the procedures which will be followed by the agency in evaluating the petition. If you wish, you may file such a petition. Should such a petition be granted, this agency would follow its normal rulemaking procedures to amend Standard No. 213.; If you have some further questions or need further information on thi subject, please contact Mr. Steve Kratzke of my staff at this address or by telephone (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2767OpenMr. Donald Reed, Trailer Manufacturers Association, 401 North Michigan Avenue, Chicago, Illinois 60611; Mr. Donald Reed Trailer Manufacturers Association 401 North Michigan Avenue Chicago Illinois 60611; Dear mr. Reed: This responds to your December 22, 1977, letter asking whether the tir information label required by Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, must contain the rim size of the rim that is mounted in the vehicle.; Paragraph S5.3.2. of the standard states that the label must contai 'the size designation and, if applicable, the type designation of rims (not necessarily those on the vehicle) appropriate for those tires.' This paragraph specifically permits a manufacturer to equip a vehicle with rim sizes that differ from those listed on its tire information label.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5108OpenMr. Stan Kaplan Shimazaki Corp. 10 Columbus Circle New York, NY 10019; Mr. Stan Kaplan Shimazaki Corp. 10 Columbus Circle New York NY 10019; "Dear Mr. Kaplan: This responds to your letter of December 10, 1992 with respect to the relationship of Federal motor vehicle regulations to the Red Alert device that you wish to import and sell in the United States. The device is located on the accelerator rod. When there is a sudden release of the accelerator, the stop lamps are activated before the driver's foot has touched the service brake pedal. You state also that installation of the device is quick and simple, requiring 10 to 15 minutes and no special tools. You have asked if Red Alert 'meets the standard set by your administration and the (sic) how we can get a waiver on this product or does it require one at all.' The descriptive literature that you enclosed notes (under 'Authorization Requirements for Installation') that 'there are many countries in which it is mandated by regulations that only the brake pedal activate the rear brake lights,' and that 'Red Alert, situated as it is on the accelerator rod, is illegal in these countries.' The United States is one of these countries. Under Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, the stop lamps may only be activated by the brake pedal. This means that a vehicle that is equipped with Red Alert no longer complies with Standard No. 108. Under the National Traffic and Motor Vehicle Safety Act, this means that the manufacturer of the vehicle, and any distributor, dealer, or motor vehicle repair business who installs Red Alert is liable for a civil penalty for creating the noncompliance. In addition, if the noncompliance is created by the manufacturer of the vehicle, the manufacturer is obliged to notify owners of the noncompliance, and then to remedy it. However, the Act does not restrict the owner of the vehicle from such modifications as (s)he may perform, even if the modifications result in a noncompliance, unless State laws so forbid. Thus, Federal law does not prohibit a vehicle owner from installing Red Alert but (s)he may not enlist the services of a distributor, dealer, or motor vehicle repair business to perform the installation. In no circumstance is importation and sale of the device itself a violation of Federal law. These matters and the agency's views on the device are set forth more fully in the enclosed agency letter of January 25, 1990, concerning the Advanced Brake Light Device (ABLD). Noting that both the ABLD and Red Alert originate in Israel, we surmise that Red Alert is a variant of the ABLD. Although the interpretation in this letter does allow installation of the Red Alert at the hands of the vehicle owner, our conclusion is based upon Federal law and should not be construed as an endorsement of the device. The same safety concerns that we expressed in January 1990 remain valid today. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam2337OpenMr. Gary R. Mercer, FAM Enterprises, P.O. Box 563, Shelby, MT 59474; Mr. Gary R. Mercer FAM Enterprises P.O. Box 563 Shelby MT 59474; Dear Mr. Mercer: This responds to your May 17, 1976, question whether special safet requirements exist for a vehicle that is modified to permit its operation by a handicapped person from a wheelchair that is secured at the driver's position.; Section 108(a)(1)(A) of the A) of the National Traffic and Moto Vehicle Safety Act (the Act) (15 U.S.C. S 1397(a)(1)(A)) specifies that; >>>S 1397 (a)(1) No person shall -- (A) manufacture for sale, sell, offer for sale, or introduce or delive for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment <<<; unless it is in conformity with all applicable standards. If you modifications are made to a new vehicle prior to its first purchase for purposes other than resale and involve more than the addition of readily attachable components or minor finishing operations, Part 567 of our regulations requires that the vehicle remain in compliance following these alterations and that any change of gross vehicle weight rating or type classification be noted (49 CFR 567.7).; Assuming that the vehicle you modify is a multipurpose passenge vehicle under NHTSA regulations (*e.g*., a van-type vehicle that does not qualify as a truck) (49 CFR 571.3), it appears from your description of intended modifications that compliance with the following Federal motor vehicle safety standards might be affected:>>>; Standard No. 101, *Control Location, Identification, and Display* Standard No. 102, *Transmission Shift Lever Sequence, Starte Interlock, and Transmission Braking Effect*; Standard No. 111, *Rearview Mirrors* Standard No. 124, *Accelerator Control Systems* Standard No. 206, *Door Locks and Door Retention Components* Standard No. 208, *Occupant Crash Protection* Standard No. 209, *Seat Belt Assemblies* Standard No. 210, *Seat Belt Assembly Anchorages*<<< I have enclosed an information sheet that explains how to obtain copie of our standards and regulations.; There are no additional Federal motor vehicle safety requirements tha apply to vehicles operated by a handicapped person sitting at the driver's position in a wheelchair. I have enclosed a Veterans Administration document detailing their specifications for vehicle modifications.; Exemptions from the motor vehicle safety standards are available onl to the manufacturers of motor vehicles in accordance with S 123 of the Act (15 U.S.C. 1410).; Sincerely, Frank Berndt, Acting Chief Counsel |
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.