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: aiam3766OpenMr. Pekka Suuronen, Product Development Manager, Racemark International, Inc., P.O. Box 82, Burnt Hills, NY 12027; Mr. Pekka Suuronen Product Development Manager Racemark International Inc. P.O. Box 82 Burnt Hills NY 12027; Dear Mr. Suuronen: This is in reply to your letters of July 27, 1983, and October 6, 1983 asking whether a sealed headlamp with 'replaceable European H4 bulb' or 'Ford bulb (6 standard sizes)' are considered 'legal,' (like Cibie BOBI) 'provided it meets with all the applicable SAE standards.'; Cibie certifies that its 'BOBI' headlamp complies with all applicabl Federal motor vehicle safety standards, pursuant to Section 114 of the National Traffic and Motor Vehicle Safety Act. Thus far, the National Highway Traffic Safety Administration has not contested that certification.; We do not understand your reference to the Ford bulb in '6 standar sizes.' The only size of that bulb that may be used in the new replaceable bulb headlamp systems is the one specified in the recent amendment to Standard No. 108. However, Volkswagen has petitioned for rulemaking to allow the H4 bulb.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0849OpenMr. Gorou Utsunomiya, Chief, Liaison Engineer in U.S., 23777 Greenfield Road, Suite 402, Southfield, Michigan 48075; Mr. Gorou Utsunomiya Chief Liaison Engineer in U.S. 23777 Greenfield Road Suite 402 Southfield Michigan 48075; Dear Mr. Utsunomiya: This is in reply to your letter of August, 1972, enclosing sketches o motor vehicles and asking into which category under the motor vehicles safety standards they fall. The numbered paragraphs below correspond to those in your letter.; >>>1. Figures 1,2, and 3 illustrate trailers under the standards Trailers are presently subject only to Motor Vehicle Safety Standard No. 108, 'Lamps, reflective Devices, and Associated Equipment.' Trailers equipped with air brakes and manufactured after September 1, 1974, will be required to conform to Standard No. 121, 'Air Brake Systems.' It is unlikely that manu camping or recreational trailers will be subject to these requirements.; 2. Figure 4 illustrates two pickup trucks equipped with slide-i campers. Pickup trucks must conform to all standards applicable to trucks. The campers must conform, as you state, to Motor Vehicle Safety Standard No. 205, 'Glazing Materials.' Both pickup trucks and slide-in campers will be required to conform to a new Standard No. 126, 'Truck-Camper Loading,' when that standard becomes effective. A copy of the standard is enclosed.; 3. In referring to the illustrations of the pickup trucks equipped wit slide-in campers, you ask whether the requirements applicable to the trucks when combined with a camper are different from those applicable when the truck is not so equipped. The answer is no. The standards applicable to pickup trucks (those that are applicable to 'trucks') are the same whether or not the pickup is equipped with a camper.; 4. The requirements for pickup trucks and slide-in campers do no differ if both components are manufactured by the same company.; 5. Wagon campers and motor homes are considered to be multi-purpos passenger vehicles when constructed on truck chassis. The illustration you enclose appear to us to represent vehicles manufactured on truck chassis.<<<; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2874OpenMr. Neil McCormick, Colorado Department of Education, 201 E. Colfax, State Office Building, Denver, CO 80203; Mr. Neil McCormick Colorado Department of Education 201 E. Colfax State Office Building Denver CO 80203; Dear Mr. McCormick: This responds to your September 22, 1978, letter asking whether th Federal government has any school bus safety standards that would prevent the State of Colorado from regulating in two areas.; A State is not permitted to have any regulation concerning an area o safety regulated by the Federal government unless the State regulation is identical to the Federal standard or imposes a higher standard of care than the Federal regulation and applies only to vehicles purchased for use by the State. With respect to the body diagonal strength test proposed in your letter, the agency does not regulate that aspect of performance. Therefore, the State of Colorado is permitted to regulate this aspect as long as its regulation does not conflict with any Federal standard.; Your second proposal would define 'activity bus' in a manner that woul except it from State requirements for lighting and color but would continue to require it to be constructed in accordance with the Federal school bus safety standards. Highway Safety Program Standard No. 17 formerly granted activity buses the option of meeting all of the color and marking requirements for school buses or none of those requirements. That standard has been changed with respect to this option. All activity buses manufactured after April 1, 1978, must comply with all of the requirements applicable to school buses including the color and lighting requirements. Therefore, it is the opinion of the agency that your proposed definition of activity bus would conflict with Standard No. 17.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2527OpenMr. A. J. Burgess, Lucas Industries North America, Inc., Two Northfield Plaza, Troy, Michigan 48084; Mr. A. J. Burgess Lucas Industries North America Inc. Two Northfield Plaza Troy Michigan 48084; Dear Mr. Burgess: This responds to your February 4, 1977, question whether Safet Standard No. 116, *Motor Vehicle Brake Fluids*, permits DOT 3 and DOT 4 brake fluids to be colored 'fluorescent yellow.'; The answer to your question is yes. paragraph S5.1.14 of Standard No 116 specified that DOT 3 and DOT 4 fluids manufactured on or after September 1, 1978, shall be 'colorless to amber.' The agency interprets this color range to include any 'yellow,' whether or not fluorescent. Although not required, we consider fluorescence to be an added safety factor since it would facilitate the detection of leaks in the braking system.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5348OpenMr. David A. Scott President, RKS International L.L.C. 822 Wisconsin Avenue Racine, WI 53403; Mr. David A. Scott President RKS International L.L.C. 822 Wisconsin Avenue Racine WI 53403; Dear Mr. Scott: This responds to your letter of March 8, 1994, askin for information about this agency's regulations regarding importation and sale of motor vehicles and motor vehicle equipment. You intend to import 'fiberglass kit cars.' The cars may be imported 'either disassembled or partially assembled.' Your company 'will then be providing and/or installing American parts in the U.S. for the major mechanical portions like engines, transmissions, suspension systems, tires, etc.' It appears from your letter that you intend to import items of equipment, either individually or as part of a larger assembly, which, after entry into the United States, will have the drive train and related components installed that are necessary to complete its manufacture as a motor vehicle. For purposes of this interpretation, it is unimportant whether the equipment is imported as individual items, or assembled into a vehicle lacking a power train. Some items of motor vehicle equipment are subject to the Federal motor vehicle safety standards (FMVSS). In order to be imported into the United States, they must comply with all applicable FMVSS. Passenger car equipment that must comply includes brake hoses, brake fluid, lamps and reflectors, tires, glazing material, and seat belt assemblies. It is mandatory that all these items (except lamps and reflectors) bear a DOT symbol in order to be imported, the symbol is the manufacturer's certification of compliance with the FMVSS. It is optional for lamps and reflectors to be marked with the DOT symbol. If they are not marked, permissible options include a certification statement attached to the equipment item or on the container in which the item is shipped. When assembly of the vehicle is completed in the United States, its assembler must satisfy itself that it conforms to all applicable FMVSS and affix a label certifying that the vehicle complies. I have enclosed a copy of an information sheet for new manufacturers of motor vehicles and motor vehicle equipment. It identifies relevant Federal statutes and this agency's standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers. It also explains how to obtain this agency's safety standards and regulations. If you have further questions we shall be pleased to answer them. Sincerely, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam2177OpenMr. J. E. Paquette, Director, Burlington Management Service Co., Greensboro, NC 27420; Mr. J. E. Paquette Director Burlington Management Service Co. Greensboro NC 27420; Dear Mr. Paquette: This responds to Burlington Fleet Service's December 9, 1975, questio whether the combination of usable parts from several existing vehicles into one functioning vehicle constitutes the manufacture of a new vehicle subject to applicable motor vehicle safety standards such as Standard No. 121, *Air Brake Systems*.; The answer to your question is no. For an assembly operation t constitute manufacture, there must be a substantial proportion of new or fundamentally rebuilt parts. In this case, no new parts, other than minor materials such as hoses and gaskets, are involved in the assembly. The NHTSA therefore, does not consider the operation to constitute manufacturing subject to the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1381 et seq.); Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2462OpenMr. David E. Martin, Director, Automotive Safety Engineering, Environmental Activities Staff, General Motors Corporation, General Motors Technical Center, Warren, MI 48090; Mr. David E. Martin Director Automotive Safety Engineering Environmental Activities Staff General Motors Corporation General Motors Technical Center Warren MI 48090; Dear Mr. Martin: This is in response to your November 2, 1976, letter concerning th type of statement regarding Federal Motor Vehicle Safety Standard No. 301-75, *Fuel System Integrity*, that must be included in the incomplete vehicle document supplied by General Motors Corporation along with its Cadillac commercial chassis.; You have essentially repeated the argument of your August 24, 1976 letter to me, in which you disagreed with the interpretation of 49 CFR Part 568, *Vehicles Manufactured in Two or More Stages*, that appeared in my July 20, 1976, letter to you. My letter explained that Part 568 prohibits the use by General Motors of a 'type (iii)' statement with respect to Standard No. 301-75 in the 1977 Cadillac incomplete vehicle document.; Both of your letters emphasize the significant effects that the work o the final-stage manufacturer has on the capability of the completed vehicle to conform to Standard No. 301-75. The NHTSA is mindful of the significance of these effects, and has never suggested that the final-stage manufacturer's work would *not* substantially determine the vehicle's conformity with the standard. Both of your letters erroneously conclude, however, that because the work of the final-stage manufacturer '*will* substantially determine such conformity' (your emphasis), 'the design of such an incomplete vehicle many times *will not substantially determine* conformity...' (your emphasis). This conclusion ignores the interpretation in our letter that, with regard to the vehicles in question, conformity is '*substantially determined by both* the design of the incomplete vehicle and the manner of completion by the final stage manufacturer' (emphasis added). The NHTSA stands by this position.; As you have requested, the letters discussed above have been include in Docket No. EX76-3, Notice 2.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2198OpenMr. Hal H. Newell, Eaton Corporation, Government Relations Office, 815 Connecticut Avenue, N.W., Washington, DC 20006; Mr. Hal H. Newell Eaton Corporation Government Relations Office 815 Connecticut Avenue N.W. Washington DC 20006; Dear Mr. Newell: This responds to Eaton Corporation's January 21, 1976, question whether the Ninth Circuit Court of Appeals stay of Standard No. 121, *Air Brake Systems*, eliminated all requirements of the standard for the period of the stay, whether complying vehicles built prior to the stay may be modified so they do not comply, and whether non-complying vehicles built during the stay would have to be retrofitted upon reinstatement of the standard. Your other questions are no longer relevant in view of the recent reinstatement of the standard by the Supreme Court.; The NHTSA has interpreted the stay to have had the effect, nationwide of voiding the standard's force and effect as a whole during the period of January 16 through January 29, 1976.; Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safet Act prohibits the sale of a vehicle unless it is in conformity with applicable standards in effect on the date of its manufacture. Therefore, a vehicle manufactured in conformity with Standard No. 121 prior to January 16, 1976, would have to conform to the standard when sold. Non-complying vehicles built during the stay would not be required to be retrofitted under this provision, because the standard was not in effect on the date of manufacture.; Sincerely,, James B. Gregory, Administrator |
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ID: aiam2032OpenMr. Hidekimi Inoue, Bridgestone Tire Co., Ltd., 350 Fifth Avenue, New York 10001; Mr. Hidekimi Inoue Bridgestone Tire Co. Ltd. 350 Fifth Avenue New York 10001; Dear Mr. Inoue: #This responds to your letter of July 14, 1975 concerning the permissibility of placing arrow-shaped markings on the tire sidewalls to show the locations of the treadwear indicators. #Federal Motor Vehicle Safety Standard No. 109 specifies certain labeling requirements for passenger car tires. Standard No. 119 specifies similar labeling for tires designed for use on vehicles other than passenger cars. Although the arrows which you have described are not required by either of these standards, the National Highway Traffic Safety Administration has no objection to such markings provided that none of the required label information is omitted. #Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam3273OpenMr. Robert Fondiller, President, WOW! Corporation, 200 West 58th Street, New York, NY 10019; Mr. Robert Fondiller President WOW! Corporation 200 West 58th Street New York NY 10019; Dear Mr. Fondiller: This responds to your March 18, 1980, letter to this agency in whic you posed some questions about a 3-wheeled vehicle your company plans to produce. First, you wanted to know if a 3-wheeled vehicle would be classified as a car, a motorcycle, or some other vehicle. Second, you asked if the vehicle could be licensed for street and/or highway use. Third, you asked if replacing the single rear wheel with a double rear wheel would result in the vehicle being classified as a 3- wheel or 4-wheel vehicle, and what effect, if any, classification as a 4-wheel vehicle would have on the answers given to the first two questions.; This agency classifies all 3-wheeled motor vehicles as motorcycles pursuant to the definition of 'motorcycle' given in 49 CFR S 571.3. The pertinent part of that section reads:; >>>'Motorcycle' means a motor vehicle with motive power having a sea or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.<<<; We determine the number of wheels on a vehicle simply by counting thos wheels. Hence, if you were to replace the single rear wheel with a double rear wheel, the vehicle would then be a 4-wheeled vehicle and could not be classified as a motorcycle. Such a vehicle would be classified as a passenger car.; The classification of a vehicle is important since it affects th Federal motor vehicle safety standards with which the vehicle must comply If a vehicle is a motorcycle, it must comply with the following safety standards: 108, 111, 112, 115, 120, 122, 123, and 127. If, on the other hand, a vehicle is a passenger car, it must comply with the following standards: 101, 103, 104, 107, 108, 110, 111, 112, 113, 114, 115, 118, 124, 127, 201, 202, 203, 204, 206, 207, 208, 209, 210, 211, 212, 214, 216, 219, and 302. As you see, the requirements for passenger cars are more stringent than for motorcycles.; I have enclosed a pamphlet prepared by this agency which gives a brie summary of the requirements of each of the Federal motor vehicle safety standards. However, because of the volume of these standards, we do not provide copies directly. I have also enclosed an information sheet which explains how you can obtain copies of our standards and other regulations.; This agency does not license any vehicles for street or highway use. W specify performance requirements, and any motor vehicle must be certified by its manufacturer as being in compliance with all applicable safety standards as of the date of its manufacture. If the vehicle complies with these requirements, we specify no further steps which must be taken.; If you have any further questions concerning motor vehicle safety o need further information, please do not hesitate to contact me.; Sincerely, Frank Berndt, 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.