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: aiam3576OpenMr. Arnold P. Fuchs, 68 Roslyn Road, Grosse Pointe Shores, MI 48236; Mr. Arnold P. Fuchs 68 Roslyn Road Grosse Pointe Shores MI 48236; Dear Mr. Fuchs: This letter is to confirm your view, expressed in a telephone call wit Edward Glancy of this office, that the requirements of Standard No. 206, *Door Locks and Door Retention Components*, are not applicable to a replacement latch for a truck built in 1969.; The requirements of Standard No. 206 are applicable to passenger cars multipurpose passenger vehicles and trucks. See S2 of that Standard. However, its requirements are not applicable to replacement parts for installation in used vehicles of these types.; Further, the 'render inoperative' provisions of the National Traffi and Motor Vehicle Safety Act are not relevant to the installation of such a latch. Under section 108(a)(2)(A) of that Act, a business such as a garage must make sure that it does not knowingly render inoperative the compliance of a vehicle with any applicable safety standard. With respect to a 1969 truck and Standard No. 206, there is no compliance which could be rendered inoperative since the Standard was never applicable to that truck. That Standard applies only to trucks manufactured on or after January 1, 1972.; I would note that even in the absence of an applicable safety standard the defect provisions of the Act may be applicable. Sections 151 *et seq*. of the Act provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5194OpenDr. Thomas L Luckemeyer Dept. VER/LB SWF Auto Electric GmH; Dr. Thomas L Luckemeyer Dept. VER/LB SWF Auto Electric GmH; "FAX 07142/73 28 95 Dear Dr. L ckemeyer: As you have requested, we ar responding by FAX to your FAX letter of June 25, 1993, to Taylor Vinson of this Office. Our FAX letter to you of May 28, 1993, provided an interpretation of SAE J588 NOV84, incorporated by reference in Federal Motor Vehicle Safety Standard No. 108. You mention the l990 SAE Ground Vehicle Lighting Manual which refers to SAE J588 September l970, and ask which is the correct SAE reference. Standard No. 108 was amended with an effective date of December 1, 1990, to substitute 'SAE J588 NOV84' for 'SAE J588 September 1970' as the U.S. Federal requirement for turn signal lamps used as original equipment on passenger cars and other motor vehicles with an overall width of less than 80 inches overall width. Turn signal lamps may still be manufactured to the requirements of 'SAE J588 September 1970' if they are intended to replace original equipment turn signal lamps that were manufactured in accordance with 'SAE J588 September 1970.' We understand that your earlier letter asked for an interpretation of Standard No. 108 as it related to the design of lamps for future production, and trust that this answers your question. As you have requested, we are also FAXing a copy of Table III. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3128OpenMr. Kei Matsui, Toyo Kogyo Co. Ltd., P.O. Box 18, Hiroshima, 730-91 Japan; Mr. Kei Matsui Toyo Kogyo Co. Ltd. P.O. Box 18 Hiroshima 730-91 Japan; Mr. Matsui: This is in response to your letter of May 11, 1979, requesting th National Highway Traffic Safety Administration's (NHTSA) views on whether the inclusion of optional equipment on certain Mazda models would be sufficient to create a number of different series within that model.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification number) states that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree on commonality in construction, such as body, chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line', denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; Based in the facts presented, it is apparent that models equipped wit different optional equipment could each be designed a 'series' if Mazda desired. Nonetheless, the definition of a 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If the difference between the potential series are superficial and a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality, the agency will not require such a designation.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0499OpenMr. Robert W. Etter, G & D Communications Corporation, 12997 Merriman Road, Livonia, MI 48150; Mr. Robert W. Etter G & D Communications Corporation 12997 Merriman Road Livonia MI 48150; Dear Mr. Etter: This is in reply to your letter of October 22, 1971, and your phon call to Michael Peskoe of November 15, 1971, requesting a copy of the Consumer Information regulations and asking what penalties may be imposed on manufacturers if their vehicles cannot perform as well as the figures they provide pursuant to the regulation. You stated in the above conversation that you have obtained the volume entitled 'Performance Data for New 1971 Passenger Cars and Motorcycles' which contains a copy of the Consumer Information requirements. I have enclosed certain amendments to the Consumer Information regulations which will bring the regulations as they appear in this volume up to date.; With reference to your question regarding penalties for violations o the Consumer Information requirements, Sections 108 and 109 of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. SS 1397, 1398) authorize the imposition of civil penalties of up to $1,000 per violation, and up to $400,000 for any related series of violations, against manufacturers whose vehicles cannot perform at least as well as the data they supply indicates. In addition, injunctive proceedings may be utilized pursuant to section 110 of the Act (15 U.S.C. S 1399).; I trust this answers your question. We regret that it was overlooked i our first response to your letter.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0104OpenMr. Harry G. Seitz, Driver Education Coordinator, Cleveland Public Schools, 1380 East Sixth Street, Cleveland, Ohio 44114; Mr. Harry G. Seitz Driver Education Coordinator Cleveland Public Schools 1380 East Sixth Street Cleveland Ohio 44114; Dear Mr. Seitz: Your letter of July 3, 1968, addressed to Mr. George C. Nield, of th National Highway Safety Bureau has been forwarded to my office for reply.; The installation of dual controls on driver education cars is not *pe se* in violation of the Federal motor vehicle safety standards. However, the secondary equipment must meet the same safety standards established or the primary controls. The secondary steering column must fulfill the same requirements made for the primary column as set forth in Federal Motor Vehicle Safety Standards Nos. 203 and 204. The installation of an additional foot brake must not affect compliance with Standard No. 105. However, duplicate compliance with the control location and identification requirements of Standard No. 101 is not required since the 'driver' of such a vehicle remains the person seated behind the primary controls. For the same reason the 'driver' mirror requirements of Standard No. 111 apply only with respect to the person seated at the primary controls.; Changes may be made to original equipment when necessary fo installation of secondary controls but none of the standards requirements specified may be eliminated or adversely affected by the alteration.; You may make available copies of this letter to dealers and intereste parties.; Sincerely, Eugene B. Laskin, Acting Director, Office of Standard Preparation; |
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ID: aiam0436OpenMr. K. Shindo,Executive Director,Meiji Rubber & Chemical Company, Ltd.,Kojima Building,10-2, Nishishinjuku, 1Chome.Shinjuku-Ku,Tokyo, Japan; Mr. K. Shindo Executive Director Meiji Rubber & Chemical Company Ltd. Kojima Building 10-2 Nishishinjuku 1Chome.Shinjuku-Ku Tokyo Japan; Dear Mr. Shindo:#This is in reply to your letter of September 3 askin questions about compliance of hydraulic brake hose assemblies with Federal Motor Vehicle Safety Standard No. 106.#With respect to your first to questions, The National Highway Traffic Safety Administration does not require that you demonstrate compliance with Standard No. 106 prior to supplying Japanese car manufacturers with brake hose assemblies to be installed on cars intended for export to the united States. If the Japanese vehicle manufacturers request proof of compliance from you (apparently in the form of a certification from the Commonwealth of Pennsylvania based upon test reports from only one or two test laboratories) such a request os solely a business matter between you and the vehicle manufacturer.#Your third question points out that proposed Standard No. 106 (Docket No. 1-5, Notice 7) would eliminate the specification of brake material for hydraulic brake hoses and asks whether you may implement this 'revision' at the present time. Notice 7 is a proposal only, and the current requirements specifying braid material remain in effect until a formal amendment of Standard No. 106 occurs. The brake hose manufacturer's code number, the subject of your fourth question is also a proposal which may or may not be adopted in the final rule.#Sincerely,Lawrence R. Schneider,Acting Chief Counsel; |
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ID: aiam4054OpenMr. Robert R. Gregg, Metzeler Motorcycle Tire, Agent Gregg, Inc., 144 Railroad Avenue, Suite 215, Edmonds, WA 98020; Mr. Robert R. Gregg Metzeler Motorcycle Tire Agent Gregg Inc. 144 Railroad Avenue Suite 215 Edmonds WA 98020; Dear Mr. Gregg: This responds to your letter to Steve Kratzke of my staff, seeking a interpretation of Standard No. 119, *New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR Part 571.119). Specifically, you asked if a motorcycle tire could have its maximum load capacity labeled on the sidewall as follows:; >>>At 60 MPH Max load _____lbs. at _____ psi cold.<<< Such labeling would violate Standard No. 119, as explained below. Section S6.5 of Standard No. 119 requires that certain information b labeled on the sidewall of all tires to which the standard applies. Section S6.5(d) requires the maximum load rating and corresponding inflation pressure to appear on all motorcycle tires as follows:; >>>Max load _____lbs at _____psi cold.<<< No speed rating or restriction may be given in conjunction with th maximum load rating on the sidewall of the tire. That rating, as its name implies, is intended to alert consumers to the tire's *maximum* capabilities.; A manufacturer may label a speed restriction on its tires to aler consumers to the tire's maximum speed if that maximum is 55 miles per hour (mph) or less. Section S6.5(e) permits speed restrictions of 55 mph or less to be labeled on the sidewall of the tire as follows:; >>>Max Speed _____mph. << |
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ID: aiam1193OpenMr. Hank Thorp, Hank Thorp Inc., Post Office Box 201. Edison, New Jersey 08817; Mr. Hank Thorp Hank Thorp Inc. Post Office Box 201. Edison New Jersey 08817; Dear Mr. Thorp: This is in response to your letter of July 7, 1973, which asks if th Manufacturer Code proposal (38 FR 14968, June 7, 1973) as it applies to wheel nuts (1) requires all manufacturers, including vehicle manufacturers, to label their products, (2) permits labeling with self-adhesive stickers, and (3) has authorized the issuance of codes at this time. In addition, you requested a clarification of an interpretation of Standard 211, *Wheel nuts*.; The answer to your first question is yes. The labeling requirement apply to foreign and domestic manufacturers of passenger cars and multi-purpose passenger vehicles and to manufacturers of equipment for those vehicles. The term 'manufacturer' includes an importer of vehicles or regulated equipment.; The use of a self-adhesive sticker in satisfaction of the permanent an legible labeling requirement of the proposal is permissible , so long as the information printed thereon is indelible and the label is affixed in such a manner that it cannot be removed without destroying or defacing it.; No codes have been assigned at this time. Assignment will not occu until a decision is reached as to issuance of a final rule.; The small hexagonal nuts which you import and which you describe a serving the same purpose as the small hexagonal nuts which secure factory-mounted, steel wheels to an axle, are not wheel nuts under the standard. The reference to normal coverage by a hub cap or wheel disc is simply descriptive of their location.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2795OpenMr. Robert W. Shebar, 38 N. Main Street, Freeport, NY 11520; Mr. Robert W. Shebar 38 N. Main Street Freeport NY 11520; Dear Mr. Shebar: This responds to your letter to Joan Claybrook on March 23, 1978, whic urges an extension of the exemption presently granted to TVR Cars of America, Ltd., from compliance with Standard No. 215, *Exterior Protection*. As noted in our earlier letter to TVR, Standard No. 215 was issued under the authority of one statute, the National Traffic and Motor Vehicle Safety Act, while the upcoming Part 581 *Bumper Standard* is issued under authority of this statute and a second one, the Motor Vehicle Information and Cost Savings Act (the Cost Savings Act).; Our earlier letter pointed out that the Cost Savings Act does no contain exemption authority which is as broad as that contained in the National Traffic and Motor Vehicle Safety Act. In the case of Part 581, the Department of Transportaiton (sic) can only exempt a passenger motor vehicle 'manufactured for a special use if (the) standard would unreasonably interfere with the special use of such vehicle' (15 U.S.C. S1912(c)(1)(B)). The legislative history of this provision cites a 4- wheel-drive vehicle equipped with a snow plow attachment as an example of a special use that would be unreasonably interfered with by a bumper standard.; Upon careful consideration of the issues raised in your letter, we d not believe there is an available basis for extension of TVR'd (sic) present exemption beyond the September 1, 1978, effective date of Part 581. The particular financial and engineering circumstances of TVR do not bear upon the limited grounds for exemption contained in the Cost Savings Act.; Thank you for bringing this matter to our attention. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2046OpenMr. Frank Hardy, Owner, The Hardy Heater Company, 9609 Dixie Highway, Louisville, KY 40272; Mr. Frank Hardy Owner The Hardy Heater Company 9609 Dixie Highway Louisville KY 40272; Dear Mr. Hardy: This is in response to your letter of July 30, 1975, in which yo inquire as to any rules and regulations to which you may be subject with respect to your pre-heater defroster. Your letter was referred to this office by the Environmental Protection Agency.; We assume, from the material submitted with your letter, that you pre-heater is sold for installation in used cars and supplements the vehicle's existing defrosting system. If our assumption is incorrect, please advise us. If your pre-heater is installed in a motor vehicle prior to its first purchase or if it replaces an existing defrosting system, you will be subject to regulations in addition to those mentioned in this letter.; The National Traffic and Motor Vehicle Safety Act provides that manufacturer, dealer, distributor, or repair shop may not render inoperative any safety device or design in a motor vehicle after its first purchase by the owner. this means that the installation of the pre-heater must not take the vehicle out of compliance with an applicable Federal Motor Vehicle Safety Standard. The standard with which you will likely be most concerned is Standard No. 103, *Windshield Defrosting and Defogging Systems* (copy enclosed).; In addition, if the fuel used in your pre-heater has a boiling poin greater than 32 degrees Fahrenheit, you must ensure that the pre-heater fuel system complies with Standard No. 301, *Fuel System Integrity* (copy enclosed).; Thank you for your interest in motor vehicle safety. Yours truly, Richard B. Dyson, Assistant 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.