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: aiam1370OpenMr. M. L. Higgins, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. M. L. Higgins Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Higgins: This is in reply to your letter of November 26, 1973, asking whethe motor vehicle new or used car dealers are prohibited from selling vehicles mounted on regrooved or recapped tires. You indicated in a phone conversation with Michael Peskoe of this office that your concern is with motor vehicles generally, and not passenger cars alone.; New passenger cars are required to be sold with tires meeting th requirements of Motor Vehicle Safety Standard No. 109 (49 CFR 571.110). New vehicles other than passenger cars are not presently required by NHTSA regulations to be sold with particular tires, but requirements in this regard have been proposed (36 F.R. 14273, August 3, 1971).; This agency has no requirements regarding the sale of used moto vehicles equipped with recapped or retreaded tires. However, buses subject to Bureau of Motor Carrier Safety regulations are prohibited from operating with recapped, retreaded, or regrooved tires on their front wheels (49 CFR S 393.75(d)).; Trucks and truck tractors subject to Motor Carrier Safety requirement may not be operated with regrooved tires on the front wheels which have a load carrying capacity equal to or greater than that of 8.25-20 8 ply-rating tires (49 CFR 393.75(e)). For more inforamtion regarding the applicability of these requirements you should contact, Regualtions Division Bureau of Motor carrier Safety, Federal Highway Administration, United States Department of Transportation, Washington, DC 20590.; The sale of regrooved tires is subject to regulations issued by thi agency (49 CFR Part 569). the recent opinion issued by the United States Court of Appeals (*NAMBO* v. *Brinegar*, D.C. Dir., Case No. 71-1268, July 26, 1973) appears to allow the sale of regrooved tires under these regulations in certain circumstances. We believe the opinion is unclear in this regard, and as a result we have determined to seek additional judicial review to further clarify the matter.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4488OpenKarl-Heinz Faber Vice President Product Compliance and Service Mercedes-Benz of North America, Inc. P.O. Box 350 Montvale, NJ 07645; Karl-Heinz Faber Vice President Product Compliance and Service Mercedes-Benz of North America Inc. P.O. Box 350 Montvale NJ 07645; "Dear Mr. Faber: Thank you for your letter concerning the requirement of Standard No. 210, Seat Belt Assembly Anchorages. In particular, you asked for an interpretation of the provisions of S4.3 of the standard. I regret the delay in answering your questions. S4.3 of Standard No. 210 provides, in part, that 'Anchorages for automatic and for dynamically tested seat belt assemblies that meet the frontal crash protection requirements of S5.1 of Standard No. 208 (49 CFR Part 571.208) are exempt from the location requirements of this section.' (Emphasis added.) You first asked the agency to confirm that anchorages to be used with automatic and dynamically tested safety belts that meet the requirements of S5.1 of Standard No. 208 are exempt from all of the anchorage location requirements of S4.3. You are correct that S4.3 of Standard No. 210 provides that such anchorages are exempt from all the location requirements. The amendment to exempt anchorages of dynamically tested seat belt assemblies from the anchorage location requirements of Standard No. 210 became effective on May 5, 1986, well in advance of the September 1, 1989 effective date for dynamic testing of manual belts. This effective date indicates that the agency did not intend to limit the exemption from the anchorage location requirements to manual safety belts that were required to be dynamically tested. Additionally, the exemption applies to dynamically tested seat belt assemblies that 'meet' the frontal crash protection requirements of Standard No. 208, rather than to vehicles 'subject to' the frontal crash protection requirements of that Standard. This language indicates that NHTSA intended to allow manufacturers to take advantage of the exemption from the anchorage location requirements for dynamically tested safety belts before the dynamic testing requirements were applicable to such belts. Accordingly, if a vehicle is equipped with a manual safety belt at either or both front outboard seating positions, and the anchorage or anchorages for those belts do not comply with the anchorage location requirements set forth in S4.3 of Standard No. 210, the manufacturer must certify that the belts attached at any such anchorage points comply with S5.1 of Standard No. 208. In your second question, you asked the following: We also understand that such dynamic testing may be combined with other compliance testing, and the vehicle or vehicles used may be equipped 'as delivered' for sale to a consumer. Accordingly, the vehicle structure with built-in energy management features, seats with designed-in anti-submarining construction, energy absorbing instrument panel, collapsible steering column, driver and/or passenger airbag(s), anti-lacerative windshield glass, emergency tensioning retractors, etc. may be installed and functional, where applicable, during the compliance crash test. During its compliance testing, NHTSA combines a test of the occupant crash protection capabilities of automatic or manual safety belts with testing done to determine compliance with other standards. The agency tests vehicles to the frontal barrier crash requirements of Standard Nos. 208, 212, 219, and 301 in a single barrier impact. In conducting these compliance tests, NHTSA tests vehicles in their 'as delivered' form with all items of standard equipment present in the vehicle. Thus, if a vehicle has devices, such as an air bag system or pre-tensioning devices for the belts, installed in the vehicle as items of standard equipment, NHTSA's compliance testing is conducted with those items in place and fully functioning. If our compliance testing shows that a vehicle tested with a manual safety belt at one or both front outboard seating positions complies with the occupant crash protection requirements of S5.1 of Standard No. 208, then the anchorages for the belt or belts would not be subject to the anchorage location requirements of S4.3 of Standard No. 210. If you have any further questions, please let me know. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam4522OpenMr. Kent B. Robinson 18230 Kingsdale Ave., Apt. D Redondo Beach, CA 90278; Mr. Kent B. Robinson 18230 Kingsdale Ave. Apt. D Redondo Beach CA 90278; Dear Mr. Robinson: This is in reply to your letters of December 3 l987, January 19, 1988, and April 4, l988 (to Taylor Vinson of this Office), asking whether a device of your invention complies with all applicable Federal regulations. You have also requested information on how to petition for adoption of this device as mandated equipment on new motor vehicles. We regret the delay in responding to your letter. You have requested confidentiality of this matter to the extent permissible. As Mr. Donaldson of this Office explained to you by phone on January 14, our practice is to make available for public perusal copies of all agency interpretations, but not necessarily the correspondence that occasioned the interpretation, and, upon request, to delete from the interpretation the name and address and other data that might identify the person requesting the interpretation. You have assented to the withholding of your name and address in your letter of January 19. In that letter you requested withholding the drawings you enclosed on December 3. We shall not attach them to the copy of this letter made publicly available (although they will be subject to review by agency personnel who review this letter before I have signed it, and may be subject to eventual disclosure under a Freedom of Information Act request). However, the device must be described to the extent necessary to allow a reader to understand just what the opinion covers. Your device is a horizontal bar of lamps mounted inside the rear window of a passenger car consisting of the center highmounted stop lamp in the center, flanked by back up lamps, which are themselves flanked by left and right turn signal lamps. Each of the five lamps would have a lens area approximately 6' wide and 1 1/2 inches high. The applicable Federal law and regulation is the National Traffic and Motor Vehicle Safety Act and Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. With respect to acceptability of your device as an item of original equipment, for purposes of this interpretation we assume that the device is intended to replace the standard center highmounted stoplamp, but only to supplement the backup and turn signal lamps. Your device appears permissible as an item of original equipment under Standard No. 108 provided that all requirements for the center highmounted stoplamp continue to be met. We call your specific attention to the fact that means must be provided to minimize reflections from the center lamp upon the rear window glazing that might be visible to the driver, either directly or indirectly in the rearview mirror. Supplementary original lighting equipment is permissible under Standard No. 108 as long as it does not impair the effectiveness of lighting equipment required by the standard. The certification by a manufacturer that its vehicle complies with Standard No. 108 would encompass a certification that there is no impairment by any supplemental lighting equipment. The vehicle manufacturer must also consider whether any device installed in a rear window affects compliance with the interior rearview mirror field of view requirements specified by Standard No. lll Rearview Mirrors, and if affirmative to provide a passenger side exterior mirror. The Vehicle Safety Act covers safety related defects as well as motor vehicle safety standards, requiring notification of purchasers and remedy of safety related defects when they occur. Spillage of light upon the rear glazing could be considered as a safety related defect, and, for this reason, means should be provided to minimize reflections upon the rear glazing from all lamps in the array, and not just the center lamp. The applicable Federal law for aftermarket equipment is also the Vehicle Safety Act. It prohibits modifications by manufacturers, distributors, dealers, and motor vehicle repair businesses to vehicles if those modifications render inoperative in whole or in part equipment installed in accordance with a safety standard. Center highmounted lamps have been required as original equipment on new cars manufactured on or after September l, l985. Because of the potential for interfering with the effectiveness of the center lamp, we would regard removal of an original equipment center lamp and substitution of your device including its center lamp as rendering the center lamp partially inoperative within the meaning of the prohibition. However, if the modification is such that it can be done by the vehicle owner, the Act does not prohibit an owner from it. Further, the Act would not prohibit in any way the installation of your device on passenger cars manufactured before September l, 1985. However, supplementary lighting devices sold in the aftermarket are regulated by each State in which the device would be sold and used. Although we are not conversant with those laws, you may consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203 for an opinion. You have also asked how this device could be mandated as original equipment on new passenger cars. Any interested person may petition the Administrator for an amendment of Standard No. 108. However, the Vehicle Safety Act requires the safety standards to be standards for motor vehicle performance, and, to the extent possible, the agency attempts to minimize standards expressed in terms of design. For the same reason, the agency does not normally propose adoption of proprietary designs. As one of the requirements of a petition for rulemaking is that it contain the name and address of the petitioner, it might not be possible to afford the same degree of confidentiality to a petition that it is to a request for an interpretation. Your letter of April 4 asks a slightly different question on the subject of what is allowed to be viewed by other motorists in or around the rear window, with specific reference to turn signals, backup lamps, and hazard warning signals. The relevant portions of Standard No. 108 are those relating to mounting height. The maximum mounting height of 83 inches allowed for turn signals (which commonly also serve as hazard warning signals) is unlikely to be exceeded by turn signals mounted in the rear window area. There is no maximum restriction on the mounting height of backup lamps but we do have performance criteria which must be met in order to ensure that they can satisfy their intended function of providing illumination behind the vehicle. Finally, you should realize that it is incorrect to refer to your device as a 'third tail light assembly.' A taillamp is a specific rear lamp required by Standard No. 108, and one which you have not incorporated into your assembly. I hope that this answers your questions. As you requested in a phone call to Taylor Vinson the other day, we are returning the originals of your correspondence. Sincerely, Erika Z. Jones Chief Counsel Enclosures; |
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ID: aiam1720OpenMr. J. Robert Horst, Corporate Attorney, Eaton Corporation, 100 Erieview Plaza, Cleveland, OH 44114; Mr. J. Robert Horst Corporate Attorney Eaton Corporation 100 Erieview Plaza Cleveland OH 44114; Dear Mr. Horst: This responds to your November 22, 1974, request for an interpretatio of language in Standard No. 121, *Air brake systems, that regulates electrical failure of the antilock systems which may be installed by vehicle manufacturers to meet the standard's performance requirements. You ask whether the S5.1.6 requirement for a continuous warning light 'in the event of total electrical failure' includes (1) any failure within the antilock system other than complete loss of all electrical power, or (2) any failure in the vehicle power source to the antilock components or from the antilock components to the signal lamp in the driver's compartment. You also ask whether the S5.5.1 requirement that 'electrical failure of any part of the antilock system shall not increase the actuation and release times of the service brakes' permits an increase in actuation time while the antilock logic circuity (sic) first recognizes a failure that occurs during brake actuation and then deactivates the antilock system.; In responding to a similar request for interpretation on the meaning o 'total electrical failure' we interpreted this phrase in a May 26, 1972, letter to Wagner Electric to mean any electrical failure within the antilock electrical system circuitry which would cause loss of antilock control of every wheel on the vehicle. This requires that the signal activate when complete loss of electrical power is sensed within the antilock system. We understand that many available systems also signal partial loss of electrical integrity, and we may give future consideration to a requirement that the signal activate in response to specific 'partial failures.'; With regard to failures in the battery or in the wiring from th battery to the antilock or from the antilock to the signal in the driver's compartment, we cannot state that a failure in these systems would not be non-compliance with S5.1.6. Our other standards (e.g., *Lamps, reflective devices, and associated equipment) assume and require the integrity of the wiring systems necessary to meet the requirement. Of course an isolated case of battery failure or a broken wire to the signal lamp would not in itself be considered a non-compliance. It would appear that a manufacturer of antilock systems is not in a position to certify that the signal generated by his product will reach the dashboard.; You pointed out that, with regard to S5.5.1's requirement tha 'electrical failure of any part of the antilock system shall not increase the actuation and release times of the service brakes,' the possibility exists of an antilock electrical failure occurring during a brake application which would necessitate a period for recognition of the failure and deactivation of the system. This recognition period would increase the actuation time. The NHTSA believes that this period of initial recognition is desirable to detect and eliminate incorrect indications of malfunction without interfering with the antilock function. Until the wording of this section is modified to reflect this exception, the NHTSA interprets S5.5.1 to permit an increase in actuation time while antilock logic circuitry first recognizes a failure occuring (sic) during brake actuation, and deactivates the antilock system.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0832OpenMr. Tatsuo Kato, Engineering Representative, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Tatsuo Kato Engineering Representative Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Kato: This is in reply to your letter of August 29, 1972, regarding sectio S5.3.5 of Motor Vehicle Safety Standard No. 215, Exterior Protection.; The propulsion system is not considered to be out of adjustment if th shift lever moves from 'neutral' to 'drive' during a test impact, so long as the movement does not impair the subsequent operation of the transmission or other parts of the propulsion system.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4871OpenEric G. Hoffman, Esq. Russell & Hoffman, Inc. 2000 NCNB Plaza 300 Convent Street San Antonio, Texas 78205-3793; Eric G. Hoffman Esq. Russell & Hoffman Inc. 2000 NCNB Plaza 300 Convent Street San Antonio Texas 78205-3793; "Dear Mr. Hoffman: This responds to your letter of March 26, 1991 addressed to Mr. Harry Thompson, asking about a private school's use of 'mini-vans which are designed to carry more than 10 passengers.' Your letter was referred to our office for reply. You stated that the school has become aware of the National Traffic and Motor Vehicle Safety Act (Safety Act) and is concerned whether the operation of the vans is in compliance with applicable regulations under the Act. You asked a number of questions related to that concern. I am pleased to have this opportunity to clarify the operation of Federal law as it applies to school buses. The National Highway Traffic Safety Administration (NHTSA) defines 'school bus' as a motor vehicle designed for carrying 11 or more persons, including a driver, and sold for transporting students to and from school or school-related events. Therefore, the vehicles refered to in your letter would be considered school buses under federal law. The National Highway Traffic Safety Administration (NHTSA) has issued Federal motor vehicle safety standards applicable to all new school buses. These standards impose obligations on the manufacturers and sellers of new motor vehicles, not upon the subsequent users of these vehicles. It is a violation of Federal law for any person to sell as a school bus any new vehicle that does not comply with all school bus safety standards. If your client believes that they have been sold noncomplying vehicles, and that the dealer knew of their intended use, the school should contact NHTSA's Office of Vehicle Safety Compliance, at the address given above, and inform them of the apparent violation of Federal law. Without violating any provision of Federal law, a school may use a vehicle to transport school children, even if the vehicle does not comply with Federal school bus regulations. This is so because the individual States have authority over the activities of a user of a school bus. Since the various questions you ask assume that the Safety Act regulates users of school buses, we are unable to provide specific answers to those questions. To determine whether the private school your firm represents may use noncomplying vans, you must look to state law. I must emphasize NHTSA's position that a vehicle meeting Federal school bus regulations is the safest way to transport students. I encourage the school your firm represents to give its most careful consideration to the possible consequences of transporting students in vehicles that do not comply with these regulations. I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0561OpenMiss Vicki Morin, Project Director, National Association of Auto Trim Shops, Auto Trim News, 129 Broadway, Lynbrook, NY, 11563; Miss Vicki Morin Project Director National Association of Auto Trim Shops Auto Trim News 129 Broadway Lynbrook NY 11563; Dear Miss Morin: This is in reply to your letter of December 15, 1971, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You ask whether the standard applies to new cars manufactured afte September 1, 19072, or to any car sold after that date as well. The standard applies to passenger cars, multipurpose passenger vehicles, trucks, and buses manufactured on or after September 1, 1972. Vehicles manufactured before September 1, 1972, which would not be required to comply with the standard, may still be sold after that date.; Your second question is whether the standard applies only to ne vehicles, or whether it also applies to the aftermarket. As the standard applies only to vehicles manufactured on or after its effective date, replacement or aftermarket materials are not subject to its requirements.; A copy of the standard, as well as a copy of a proposed amendment, ar enclosed in accordance with your request.; We are pleased to be of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5299OpenMr. David Shapiro RV Designer Collection Woodbridge, Inc. Glenview, IL 60025; Mr. David Shapiro RV Designer Collection Woodbridge Inc. Glenview IL 60025; "Dear Mr. Shapiro: This responds to your inquiry about th applicability of Standard No. 302, Flammability of Interior Materials to aftermarket products. You state that you are planning to market fabric window coverings such as drapes and fabric bedding such as bedspreads for use in recreational vehicles. In response to your request for confirmation that Standard No. 302 does not apply to aftermarket products, I am pleased to have this opportunity to explain our regulations to you. By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The agency periodically tests new vehicles and items of equipment for compliance with the standards. In response to your question, there are currently no Federal motor vehicle safety standards (FMVSS's) that directly apply to the products you wish to manufacture. Under the authority of the Safety Act, NHTSA has issued Standard No. 302, which specifies requirements for the flammability resistance of materials in the occupant compartment of new vehicles. However, Standard No. 302 would not apply to your products because that standard applies to new motor vehicles and not to aftermarket items of motor vehicle equipment. I note, however, that there are other Federal requirements that indirectly affect the manufacture and sale of your products. Under the Safety Act, your products are considered to be items of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements in 151-159 of the Safety Act concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your products contain a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. I note that even though Standard No. 302 would not apply to your product, the product's flammability characteristics could be relevant to whether it contained a safety related defect. Manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 108(a)(2)(A) of the Safety Act, which states: 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative ... any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard ....' This section would prohibit any manufacturer, distributor, dealer, or repair business from installing your product in used vehicles if the effect of such installation was to render inoperative the compliance of the vehicle with any safety standard, including Standard No. 302. The 'render inoperative' prohibition of 108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Thus, if your products were placed in vehicles by the vehicle owners, your products would not need to meet any FMVSSs. Nevertheless, in the interest of safety, we suggest you consider conforming your product to a flammability resistance standard equivalent to Standard No. 302. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam5333OpenLawrence A. Beyer, Esq. 674 Lake Road Webster, NY 14580; Lawrence A. Beyer Esq. 674 Lake Road Webster NY 14580; Dear Mr. Beyer: This is in reply to your FAX of February 14, 1994, t Taylor Vinson of this Office, relating to a policy of the Office of Vehicle Safety Compliance (OVSC) regarding importation of vehicles from Canada. Under this policy, and because of the close congruence of the Federal motor vehicle safety standards of both the U.S. and Canada, OVSC has, in essence, waived the requirement for bond and entry through the registered importer process if the Canadian vehicle is accompanied by a letter from the vehicle manufacturer stating that the vehicle was manufactured to comply with the U.S. standards, except for minor labelling variations. You state that this policy has been restricted to personally owned vehicles and does not allow 'importations of vehicles by corporations for their corporation's personal use.' Instead, these vehicles must be entered under bond and conformance verified or achieved by a registered importer. You state that you do not understand the distinction OVSC makes between individual personal use and corporate personal use. Under the Imported Vehicle Safety Compliance Act of 1988, as a general matter, a noncomplying vehicle may enter the United States permanently only if it is imported by a registered importer who brings it into compliance. However, an exception is made by 15 U.S.C. 1397(f)(1)(B) which allows importation by a person other than a registered importer if that person has a conformance contract with a registered importer and if the vehicle is imported 'for personal use, and not for purposes of resale, by any individual (other than an individual described in subsections (g) and (h)). . . .' The term 'individual' refers to a human being and not a corporate person. Therefore, the Act distinguishes both as to whether an importation is for personal use and whether the importer is an individual or a corporation. I hope that this answers your question. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0131OpenMr. Donald S. Mortensen, Baycraft, 225 E. Lockhart, Coos Bay, OR 97420; Mr. Donald S. Mortensen Baycraft 225 E. Lockhart Coos Bay OR 97420; Dear Mr. Mortensen: Your letter of December 2, 1968, to Mr. William L. Hall, concernin safety glazing in canopies, has been referred to me for reply.; FHWA Ruling 68-1 clarified the requirement that slide-in campers mus comply with Standard 205 since they are items of motor vehicle equipment for use in motor vehicles. A copy of FHWA Ruling 68-1 is enclosed.; The same rationale applies to your canopies. Forward facing window must be laminated safety glass meeting the requirements of Test No. 26 of ASA Standard Z26.1-1966, July 15, 1966. Other windows may be AS1, 2, 3, 4, 5, 6, 7, 10, 11, 2-26, or 3-26.; Sincerely, Clue D. Ferguson, Director, Office of Standards o Crash-Injury Reduction, Motor Vehicle Safety Performance Service; |
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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.