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: aiam4179OpenMr. W. K. Sherman, Manager, Inventors Research Foundation, P.O. Box 02588, Portland, OR 97202; Mr. W. K. Sherman Manager Inventors Research Foundation P.O. Box 02588 Portland OR 97202; Dear Mr. Sherman: This is in reply to your letter of June 30, 1986, with reference to th possible interest of this agency in an illuminated license plate holder which is lit when the ignition is turn on.; The agency does not 'approve' or promote proprietary items of lightin equipment. It does require illumination of the rear license plate in the manner set forth in SAE J587 October 81 (incorporated by reference in Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*) but there is no requirement for illumination of the front plate, however, consideration is being given to proposing the installation of a daytime running light on the front of vehicles, as Canada has recently done. Should the agency issue a formal proposal your client may wish to submit comments to the docket with reference to its device. Your client may also wish to examine current Federal rear lighting requirements to determine whether a vehicle equipped with its device would meet Standard No. 108. If so, it may wish to market the device as original or aftermarket equipment.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1681OpenFrank Mayer, P. Eng.,Gates Rubber of Canada Ltd,300 Henry Street, P.O. Box 310,Brantford, Ontario N3T 5w1; Frank Mayer P. Eng. Gates Rubber of Canada Ltd 300 Henry Street P.O. Box 310 Brantford Ontario N3T 5w1; Dear Mr. Mayer:#Please forgive the delay in responding to your reques of September 29, 1974, for information on Federal Motor Vehicle Safety Standard No. 106-74, *Brake hoses*. A copy of the standard is enclosed, along with a copy of the most recent amendment. To keep abreast of future changes, please refer to the enclosure, 'Where to Obtain Motor Vehicle Safety Standards and Regulations.' #Please note that the definition of 'brake hose assembly' excludes assemblies containing used components. Thus an assembly consisting of used renewable or reuseable end fitting and new replacement hose, for example, is not subject to the banding pursuant to S5.2.2(a) through (d) as incorporated in S7.2, whether it is destined for newly-manufactured vehicles or for the replacement market. I hope this answers satisfactority (sic.) the questions asked by Mr. A.W. Oswald in his letter of September 25, 1974.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam0993OpenMr. Charles J. Simerlein, Engineering Liaison Manager, Rockleigh, NJ 07647; Mr. Charles J. Simerlein Engineering Liaison Manager Rockleigh NJ 07647; Dear Mr. Simerlein: This is in reply to your letter of November 29, 1972, concerning th method in which a load is to be 'secured in the luggage area' under the test procedures of Standard 208. I apologize for our delay.; The intent of S8.1.1(a) is to place the load in the luggage area i such a way that it stays there during the test. The standard does not specify the manner in which the load is secured. A manufacturer may secure it in any reasonable manner.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4483OpenMr. Mark Jansen Chevy Duty Pickup Parts 4600 N.W. 52nd St. Kansas City, Mo. 64151; Mr. Mark Jansen Chevy Duty Pickup Parts 4600 N.W. 52nd St. Kansas City Mo. 64151; Dear Mr. Jansen: This is in reply to your letter of September 17, 1988 to Taylor Vinson of this Office. You would like to have parking lamp and tail lamp lenses 'remanufactured' for use on l947-66 Chevrolet and GMC pickup trucks, and have requested our views. We assume that you wish to have lenses manufactured to replace original equipment lenses on the trucks produced in the years indicated. Essentially, your operation appears unaffected by the requirements of this Department. The Federal motor vehicle lighting standard applies only to lenses intended to replace original lenses on vehicles manufactured on and after January l, l972, and would not cover lenses for use on l947-66 trucks. However, if the lenses you intend to manufacture are interchangeable with those on vehicles manufactured on and after January l, l972, you may have an obligation to ensure that they meet Federal requirements. If this is the case, we would be pleased to advise you further. Notwithstanding the foregoing, all replacement lenses are equipment that is subject to Federal notification and remedy provisions if they incorporate a defect that relates to motor vehicle safety. In your case, this likelihood may be remote as the item concerned is a simple one, but attention should be paid to quality control. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam3346OpenMr. Hiromi Hamaya, Vice President, Engineering Department, Bridgestone Tire Company of America, Inc., 2160 West 190th Street, P. O. Box 2964, Torrance, California 90509; Mr. Hiromi Hamaya Vice President Engineering Department Bridgestone Tire Company of America Inc. 2160 West 190th Street P. O. Box 2964 Torrance California 90509; Dear Mr. Hamaya: This responds to your July 17, 1980 letter to this office in which yo posed six questions concerning Safety Standard 119 (49 CFR s571.119). The answers are set forth below following the number you assigned to each question in your letter.; (1) No, T&RA design information is not considered apart of the T&R yearbook for purposes of Standard 119, Design information refers to future tire sizes which will soon be produced, but which are not currently on the market. Since the specifications in the design information have not been formally approved by T&RA, as the yearbook entries have, the design information has not been subjected to the same type of examination by T&RA, and is not accepted by this agency.; (2) The Plunger Energy Table (Table II in Standard 119) Publishe November 13, 1973 is the most current table we have published.; (3)The ETRTO petition to which you refer has not been granted by thi agency. Shortly after receipt of the petition, we made a telephone contact with ETRTO requesting further information which would justify setting the plunger energy specifications at the requested levels. ETRTO was informed that the petition would not be considered until we had received this additional information, and no further information has been received. Similarly, you company has requested the inclusion of additional values for Table II i a letter dated August 9, 1979. Mr. Finkelstein, our Associate Administrator for Rulemaking, sent a letter to Mr. P. L. Lab of Bridgestone on September 12, 1979 requesting further information and justification for including these values. To date, no further information has been received.; (4) Since there is no plunger energy value specified for tubeless tire with a load range greater than 'J' in Table II, there are currently no requirements for plunger energy strength that these tires must meet. It is acceptable if you choose to test these tires at the strength level specified for load rang 'J' ties, but that level is significantly below what would be expected for higher load range tires.; (5) When you company submits matching information to this agenc pursuant to the requirements of S5.1(a) of Standard 119, it is perfectly acceptable to send duplicate copies of the information you have furnished to the dealers, and no separate letter is necessary.; (6) I am aware of only three requests for plunger energy tests fo tubeless tires with load ranges greater than 'J'. The first came from Michelin in 1973, when the Standard wa being development. NHTSA asked Michelin to provide information o the proposed values, and Michelin never raised the issue again. ETRTO submitted the petition your referred to in question 3, and never provided the further information requested. Bridgestone submitted a petition in August 1979 and never provided the further information requested. There have been no other requests for additional plunger energy values.; If you have any further questions concerning this matter please fee free to contact Mr. Steve Kratzke of my staff at (202)426- 2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5338OpenMr. John Rhein Fisher-Price, Inc. 636 Girard Ave. East Aurora, NY 14052; Mr. John Rhein Fisher-Price Inc. 636 Girard Ave. East Aurora NY 14052; "Dear Mr. Rhein: This responds to your letter about the consume registration card required by Safety Standard No. 213, 'Child Restraint Systems.' I apologize for the delay in responding. You ask about three features of a registration card you wish to produce, and enclosed a sample card setting forth a 'proposed format.' You first ask whether you may specify 'Please Print' on the card. The answer is yes. NHTSA interpreted Standard 213 as permitting this feature, in an October 20, 1993 letter to Mr. Richard Glover of the Evenflo Juvenile Furniture Company. You also ask whether you may use 'open box spaces' for the consumer's name and address, to encourage consumers to print the information clearer (one character per box space). The answer is yes. NHTSA interpreted Standard 213 as permitting 'blocked squares' for the consumer's name and address in a June 14, 1993 notice (copy enclosed) denying Evenflo's petition for reconsideration of the rule that established the registration card requirement. Finally, you ask whether you may enlarge the consumer name and address space of the card, to provide consumers more space to print the information and thus increase the likelihood the information will be legible. The answer, with reference to the sample card you provided, is yes. Under S5.8 of Standard 213, the registration form must conform in size, content and format to forms depicted in the standard (figures 9a and 9b). The figures specify a minimum size for the card. Moreover, in the enclosed June 1993 notice, NHTSA explained that '(f)ormat refers to the general appearance of the form and to aspects such as type size, size and placement of margins, size and placement of the spaces for the consumer's name and address, and overall organization of the printed material.' The sample card you provided meets the minimum size requirement specified in the standard, and the general appearance and overall organization of the card is the same as that depicted in the standard (figure 9a). While the consumer name and address space is slightly larger than depicted in the standard, we conclude that this slight deviation is consistent with the standard's format requirements. This conclusion is based on the fact that this slight change does not affect the general appearance or overall organization of the card, and because the change provides consumers more space to print the information, i.e., it will not detract from the utility of the card. Please contact Ms. Deirdre Fujita of my staff at (202) 366-2992 if you have any questions. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2107OpenMr. John B. White, Engineering Manager, Technical Information Dept., Michelin Tire Corporation, P. O. Box 3467, New Hyde Park P. O., NY 11040; Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation P. O. Box 3467 New Hyde Park P. O. NY 11040; Dear Mr. White: This is in response to your letter of October 17, 1975, concerning th importation into the United States of tires that will be mounted on trucks intended for export from the United States.; 49 CFR Part 571.7(d) and Section 108(b)(5) of the National Traffic an Motor Vehicle Safety Act of 1966 specify that no Federal Motor Vehicle Safety Standards (FMVSS) apply to; >>>a motor vehicle or item of motor vehicle equipment intended solel for export, and so labeled or tagged on the vehicle or item itself and on the outside of the container, if any, which is exported.<<<; Therefore, tires which Michelin manufactures for sale directly to truck manufacturer who will mount them on trucks which are intended solely for export need not comply with Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*. When imported and shipped to the truck manufacturer, the tires must bear a label or tag indicating intent to export. Such a label must also appear on the outside of the container, if any, in which the tires are shipped. Importation of such tires is permitted by 19 CFR 12.80(b)(1)(ii), provided they are so labeled. A label need not remain on the tires after they have been mounted on the trucks, provided that the trucks bear similar labels.; Because these tires are not subject to any FMVSS and are beyond th scope of any expected defect notification and remedy program, Michelin Tire Corporation is not subject to the requirements of 49 CFR Part 574, *Tire Identification and Recordkeeping*, with respect to them.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0090OpenGeneral Motors Corporation, General Motors Technical Center, Warren, MI 48090; General Motors Corporation General Motors Technical Center Warren MI 48090; >>>*GRANT OF APPROVAL*<<< In accordance with Paragraph S3. of Motor Vehicle Safety Standard No 209, as amended, effective March 1, 1967, an interrupted thread belt is an approved equivalent to the belts specified in paragraph (f) of section 9.3 of Department of Commerce, National Bureau of Standards, *Standards for Seat Belts for Use in Motor Vehicles* (15 CFR 9) (31 F.R. 11528), provided it meets all other requirements of 13 CFR 9.; Sincerely, William Haddon, Jr., M. D., Director |
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ID: aiam2557OpenMr. Louis Marick, Chairman, ASTM Subcommittee F9.10, 339 Merriweather Road, Grosse Pointe, Michigan 48236; Mr. Louis Marick Chairman ASTM Subcommittee F9.10 339 Merriweather Road Grosse Pointe Michigan 48236; Dear Mr. Marick: This responds to your March 2, 1977, letter asking whether the Nationa Highway traffic Safety Administration (NHTSA) still emphasizes or frequently conducts tubeless tire resistance to bead unseating tests as authorized by Standard No. 109, *New Pneumatic Tires*.; As you know, the bead unseating test procedure was adopted from th society of Automotive Engineers Practice J918. It is our understanding that the SAE continues to use this procedure for tire performance tests. The NHTSA is of the opinion that the bead unseating test procedure is a viable laboratory evaluation of the compatibility of a tire and rim combination. This has become especially important since 1975, when the table of approved alternative rims of Appendix A of Standard No. 110, *Tire and Rim Selection*, was deleted, and the tables of standards organizations were adopted. The bead unseating test provides an additional verification of the tire and rim combinations listed in the yearbooks of these organizations.; Standard No. 109 requires several tire performance test: physica dimensions, resistance to bead unseating, strength, endurance, and high speed performance. The NHTSA compliance testing is conducted on a random selection basis. In the case of tires, not every test is conducted on each brand of tire selected for compliance testing, Therefore, the bead unseating test is not always conducted during compliance testing. However, the agency does conduct bead unseating test whenever appropriate and will continue to do so.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5292OpenMr. Timothy McQuiston Vice-President Sales California Dream P.O. Box 11 Waukesha, WI 53187; Mr. Timothy McQuiston Vice-President Sales California Dream P.O. Box 11 Waukesha WI 53187; Dear Mr. McQuiston: This is in reply to your letter of September 29 1993, to Taylor Vinson of this Office. Your company provides an aftermarket spoiler which incorporates a center stop lamp 'that complies with SAE standards.' You have asked us for a statement that you could provide your dealers that 'would affirm that when the dealer installs a spoiler containing a high mount third brakelight meeting/exceeding SAE standards, they are, in fact providing an equivalent light source, thereby allowing them (dealers) to remain in compliance with federal regulations.' You have also enclosed a November 1992 report from ETL Testing Laboratories rendered to Leegold Enterprise Co., Ltd. covering the lamp that we assume to be the one you are offering in your spoiler. Under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.), in the fact situation you present, the dealer has the following obligations with respect to new and used vehicles. It is obliged to deliver a new vehicle to the buyer with a center highmounted stop lamp that is in full compliance with Federal Motor Vehicle Safety Standard No. 108, and if it does not, it may be in violation of section 108(a)(10(A) of the Act (15 U.S.C. 1397(a)(1)(A)). With respect to a vehicle in use, under section 108(a)(2)(A) of the Act, it may not knowingly render inoperative, in whole or in part, the original center highmounted stop lamp unless it provides a conforming equivalent (agency interpretation of 15 U.S.C. 1397(a)(2)(A)). Therefore, as a general principle, we affirm your understanding that a dealer may knowingly render an original equipment center highmounted stoplamp inoperative on a vehicle in use, or cause it on a new vehicle to become noncompliant with the requirements of Standard No. 108 if the dealer provides a substitute lamp that meets Standard No. 108's requirements. The test report you provided indicates that the Model LG 03-60B lamp that was tested meets requirements specified in Standard No. 108 and SAE Recommended Practice J186a, and that that particular lamp is an equivalent in performance to an original equipment light source. Having said that, however, we feel that further comments are in order. The first comment is to clarify a misunderstanding reflected in your letter. The lamp must comply with Standard No. 108, and not with SAE specifications as you have stated. Although Table III of Standard No. 108 does incorporate by reference SAE Recommended Practice J186a, 'Supplemental High Mounted Stop and Rear Turn Signal Lamps,' September 1977, certain provisions of J186a, such as photometrics, do not apply because they have been modified by the text of Standard No. 108 itself. We are pleased to note that the summary of the test report appears to recognize this distinction. Our second comment is that, in addition to the assurances that you as the spoiler manufacturer provide the dealer, both you and the dealer are afforded a degree of protection from violations of the Act if Leegold's lamp, in fact, fails to meet Standard No. 108. This is true whether the dealer installs the spoiler either as original equipment or as aftermarket equipment. With respect to original equipment (i.e., installed before delivery of the vehicle to its first purchaser), Leegold, as the manufacturer of the lamp, is required by section 114 of the Act (15 U.S.C. 1403) to certify to its dealers and distributors that the lamp complies with Standard No. 108 (which may be signified by the symbol 'DOT' on the lamp). If the lamp is later discovered to be noncompliant, those who have sold the lamp and any new vehicle on which it has been installed are in technical violation of the Act, but are protected by section 108(b)(1) of the Act from civil penalties, unless they have actual knowledge that the lamp does not meet Standard No. 108 (15 U.S.C. 1397(b)(1)). With respect to a nonconforming lamp installed after the vehicle's first sale, the original lamp may have been disconnected or partially blocked by the aftermarket lamp, resulting in either case in a 'rendering inoperative' of required equipment within the meaning of the prohibition. However, we would not view this as a 'knowingly' rendering inoperative because the dealer's intent is to install a conforming lamp, as indicated by the lamp's certification. One final comment, one directed more to Leegold than to your or your dealers. As a result of our experience over the years, we have come to realize the value of surveillance testing of production lamps to assure that the lamps continue to comply withFederal requirements. Periodic testing may be regarded as evidence of the manufacturer's exercise of due care in the event of noncompliances. If the November 1992 ETL test is of a prototype lamp, Leegold may wish to have new tests conducted on production lamps. Even if that test were of production lamps, sufficient time has elapsed, in our view, for Leegold to conduct a new test, to ensure that design tolerances have been maintained in production and that the lamp continues to conform to Standard No. 108. Sincerely, John Womack Acting 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.