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: aiam0711OpenMr. Clifford C. Oliver, Vice President, GO Industries, 4805 Bruce Crescent, Newport Beach, CA 92660; Mr. Clifford C. Oliver Vice President GO Industries 4805 Bruce Crescent Newport Beach CA 92660; Dear Mr. Oliver: This is in reply to your letter of April 26, 1972, requesting a opinion as to whether 'Abcite,' a product of the Dupont Company, may be used in campers and 'mini-mobile homes.'; Whether a particular glazing material may be used in motor vehicles o campers depends upon whether the material meets the requirements of Motor Vehicle Safety Standard No. 205, 'Glazing Materials' (49 CFR 571.205), which incorporates, as you indicate, the American National Standards Institute Standard Z26.1-1966. That standard also specifies the locations in motor vehicles where specific materials may be used.; Standard No. 205 does not apply to trailers. While we are not familia with the phrase 'mini-mobile home,' we consider mobile homes to be trailers, and the standard does not apply to them. With respect to campers, Standard No. 205 allows the use of any material meeting the requirements of Z26 in any location except for forward-facing windows. Forward-facing camper windows may not be manufactured of item 6 and item 7 material (AS6, AS7), but may be manufactured of any of the other materials (AS1-AS5, AS8-AS11) that meets the requirements of Z26.; Whether Abcite conforms to the requirements for glazing allowed to b used in campers is a determination that should be made in the first instance by its manufacturer, Dupont. If the manufacturer determines that such use is within the requirements of Standard No. 205, he is required by section 114 of the National Traffic and Motor Vehicle Safety Act to certify that the material conforms to the requirements of the standard. He is also required by the marking requirements in Section 6 of Z26.1-1966 to indicate on the material its AS designation. Any material that is so certified can be used in the camper locations listed on the standard as appropriate for that designated type.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5575OpenMr. Yoshiaki Matsui Manager Automotive Equipment Legal & Homologation Section Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153 Japan; Mr. Yoshiaki Matsui Manager Automotive Equipment Legal & Homologation Section Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Matsui: This responds to your letter of June 23, 1995, askin questions about neon high mounted stop lamps. The National Highway Traffic Safety Administration answered these questions in the preamble to a notice of proposed rulemaking that was published on June 19, 1995. We assume that you had not received it by the 23rd, and enclose a copy for your information. You will see (center column, page 31940) that Federal Motor Vehicle Safety Standard (FMVSS) No. 108 allows neon tubes as light sources for the center highmounted lamp. Under our interpretation of paragraph S5.1.1.16, FMVSS No. 108 also allows testing of a neon lamp with or without its ballast, in accordance with the directions of that paragraph. If you have any questions, you may refer them to Taylor Vinson of this Office. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0196OpenMr. H. Kirstein, Volkswagen of America, Incorporated, Englewood Cliffs, New Jersey 07632; Mr. H. Kirstein Volkswagen of America Incorporated Englewood Cliffs New Jersey 07632; Dear Mr. Kirstein: This will acknowledge your letter of November 25, 1969, to the Nationa Highway Safety Bureau requesting the addition of the 4-J and 4 1/2-J rims for use with the 5.60x15 tire size designation and the 4 1/2-J rim use with the 6.00x15 tire size designation to Table I, Appendix A of Federal Motor Vehicle Safety Standard No. 110.; The addition of these rims to Standard No. 110 is not necessary, a these combinations are listed within the references cited in S.3 of Standard No. 109. The fact that you have changed the hump configuration on these rims requires no action on our part as we do not list variations from the basic Tire and Rim Association's contours. We consider only the rim width and flange contour designation at this time when listing rims in the standard.; Manufacturers who modify rims are, of course, responsible to see tha their product will perform satisfactorily to the requirements of Standard No. 109 and No. 110.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam1775OpenMr. H. W. Gerth, Assistant Vice President, Mercedes-Benz of North America, Inc., One Mercedes Drive, Montvale, NJ 07645; Mr. H. W. Gerth Assistant Vice President Mercedes-Benz of North America Inc. One Mercedes Drive Montvale NJ 07645; Dear Mr. Gerth: This is in reference to your defect notification campaign (NHTSA No 75-0005) involving the front wheel bearings on certain Mercedes-Benz trucks, model L1113.; Since the notification was issued after the effective date of Publi Law 93-492, the provisions of this law apply to this notification. A copy of this law is enclosed for your information.; Specifically, the defect notification does not comply with sectio 153(a)(5) in that no specific date is given. Because remedy without charge is contingent upon actual dates, we believe the inclusion of a specific date is required. You must also include information that is responsive to section 153(a)(6). As the procedures referred to in that section have not been published, it is sufficient if you advise owners that they may write the Administrator, National Highway Traffic Safety Administration, Washington, D. C. 20590, if they find Mercedes- Benz to have failed or to have been unable to perform the repair satisfactorily.; In addition, we note from your defect report that you are notifyin first purchasers. Public law 93-492 has modified the statutory recipients of defect notification letters, and requires that notification be sent to the person who is registered under State law as the owner of the vehicle (section 153(c)(1)). First purchasers may also have to be notified under these requirements if registered owners cannot be found (153(c)(2)). We suggest you review these statutory changes and renotify owners, providing them with all required information. A letter containing the information in the notification letter forwarded to us plus the additional information referred to above will be considered to meet these statutory criteria.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam1774OpenMr. H. W. Gerth, Assistant Vice President, Mercedes-Benz of North America, Inc., One Mercedes Drive, Montvale, NJ 07645; Mr. H. W. Gerth Assistant Vice President Mercedes-Benz of North America Inc. One Mercedes Drive Montvale NJ 07645; Dear Mr. Gerth: This is in reference to your defect notification campaign (NHTSA No 75-0005) involving the front wheel bearings on certain Mercedes-Benz trucks, model L1113.; Since the notification was issued after the effective date of Publi Law 93-492, the provisions of this law apply to this notification. A copy of this law is enclosed for your information.; Specifically, the defect notification does not comply with sectio 153(a)(5) in that no specific date is given. Because remedy without charge is contingent upon actual dates, we believe the inclusion of a specific date is required. You must also include information that is responsive to section 153(a)(6). As the procedures referred to in that section have not been published, it is sufficient if you advise owners that they may write the Administrator, National Highway Traffic Safety Administration, Washington, D. C. 20590, if they find Mercedes- Benz to have failed or to have been unable to perform the repair satisfactorily.; In addition, we note from your defect report that you are notifyin first purchasers. Public law 93-492 has modified the statutory recipients of defect notification letters, and requires that notification be sent to the person who is registered under State law as the owner of the vehicle (section 153(c)(1)). First purchasers may also have to be notified under these requirements if registered owners cannot be found (153(c)(2)). We suggest you review these statutory changes and renotify owners, providing them with all required information. A letter containing the information in the notification letter forwarded to us plus the additional information referred to above will be considered to meet these statutory criteria.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam5123OpenMr. Patrick R. Smorra Group Vice President Chrysler Corporation 38111 Van Dyke Avenue Sterling Heights, MI 48312; Mr. Patrick R. Smorra Group Vice President Chrysler Corporation 38111 Van Dyke Avenue Sterling Heights MI 48312; Dear Mr. Smorra: This responds to your letter of November 12 to th Administrator asking for a variance from the Federal motor vehicle safety standards for vehicles that Chrysler Corporation would like to sell to foreign nationals for their use on vacation in the United States. You have inquired whether additional information is required. The agency would be willing to consider Chrysler's request through the medium of a petition for temporary exemption from one or more specific Federal motor vehicle safety standards. The temporary exemption, two years in duration, permits a manufacturer to sell up to 2,500 exempted vehicles in any 12-month period during the term of the exemption, subject to such terms and conditions as the agency deems appropriate. These exemptions are renewable. Indeed, NHTSA has already provided exemptions to General Motors for the same purpose as Chrysler's, pursuant to 49 CFR 555.5 and 555.6(d). For your guidance, I enclose a copy of the Federal Register notice that granted GM's original petition in 1988. Because of the necessity to afford the public an opportunity to comment, a petitioner should anticipate an elapsed time of approximately four months between the agency's receipt of its petition and a determination on it. Should you have questions on the exemption process, Taylor Vinson of this office will be pleased to answer them (202-366-5263). You have also asked ' i f, upon expiration of the variance, the vehicle has not left the U.S. who is responsible for the delinquency?' This is an interesting question. The exemption is not provided directly to the purchaser. Instead, it is provided to a manufacturer to allow it to sell nonconforming vehicles to foreign nationals without violating the National Traffic and Motor Vehicle Safety Act, subject to the purchaser's agreement to export the vehicle when (s)he leaves this country. Should a manufacturer sell an exempted vehicle to a foreign national knowing, or in the exercise of due care having reason to know, that the purchaser did not intend to export it, the manufacturer would have violated the Safety Act's prohibition against sale of nonconforming vehicles, notwithstanding the fact that the vehicle had been exempted. Moreover, if the manufacturer did not take appropriate steps to assure that the purchaser honored his or her commitment to export the vehicle, the agency could find that continuation of the exemption was no longer in the public interest, and cancel it. However, if the manufacturer did not know or in the exercise of due care have any reason to know that its exempted vehicles would not be exported, it would appear to have incurred no liability under the Act. As for a foreign national purchaser who fails to export a vehicle in conformity with the terms of the condition imposed by the manufacturer under the exemption, it appears that the purchaser could be deemed to have violated the Safety Act's prohibition against introduction into interstate commerce of a nonconforming vehicle, notwithstanding the fact that the manufacturer had received an exemption for the manufacture and sale of the vehicle. Finally, depending on the safety standards from which the vehicle had been excused, the owner of the vehicle might find it difficult to register it in a State without bringing it into full compliance with the safety standards. You have also asked, ' I n the unlikely event that this vehicle has an accident in which it is deemed undriveable, who is responsible for its disposition.' The answer to this question would appear to turn on the ownership of the vehicle. Since Chrysler does not intend to lease the exempted vehicles, we assume that it will transfer all right, title, and interest in them to the foreign national purchasers, and we assume that those owners will be responsible for the disposition of wrecked vehicles deemed undriveable. Sincerely, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam3336OpenMr. Brian Gill, American Honda Motor Co., Inc., 100 W. Alondra Blvd., P.O. Box 50, Gardena, California 90247; Mr. Brian Gill American Honda Motor Co. Inc. 100 W. Alondra Blvd. P.O. Box 50 Gardena California 90247; Dear Mr. Gill: This will confirm your telephone conversation with Mr. Schwartz of m office concerning the conformance of the numbering on the VIN plate you submitted with Federal Motor Vehicle Safety Standard No. 115, *Vehicle Identification Number*.; The National Highway Traffic Safety Administration does not giv advance approval of a manufacturer's compliance with motor vehicle safety standards or regulation, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed the VIN plate you submitted. The numbering on the VIN plate apparently complies with the legibility requirements of S4.3 of Standard No. 115.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5314OpenHarry C. Gough, P.E. Automotive Engineering Professional Specialist State of Connecticut Department of Motor Vehicles 60 State Street Wethersfield, CT 06161; Harry C. Gough P.E. Automotive Engineering Professional Specialist State of Connecticut Department of Motor Vehicles 60 State Street Wethersfield CT 06161; "Dear Mr. Gough: This is in reply to your letter of December 2, 1993 with respect to the term 'alternately flashing' as it applies under Safety Standard No. 108 to school bus lamps. You ask for our opinion because a manufacturer of strobe lighting has supplied documentation indicating that the system complies with Standard No. 108. According to your letter, in this system, the lamp on one side of the school bus (front and rear) 'flashes on and off four times in a 255 millisecond period and then stays off for 745 milliseconds, then the lamp on the opposite side of the bus repeats the aforementioned pattern.' You inquire as to whether 'alternately flashing' refers to this pattern, 'or do the four distinct on/off cycles on each side of the school bus defeat the intent of the term alternating.' As you know, paragraph S5.1.4 of Standard No. 108 incorporates by reference SAE Standard J887, School Bus Red Signal Lamps, July 1964, which requires that school bus warning lamp systems 'flash alternately.' We believe that the light emanating from a strobe lamp that flashes four times in 0.255 second will be perceived as a single flash of varying intensity and not as four separate flashes, and that when this is followed by an identical pattern on the other side of the bus, the system is one that is alternately flashing within the meaning of Standard No. 108. Further, under this interpretation, the flash rate meets SAE J887's specification of 60-120 flashes a minute. Unlike other SAE materials incorporated by reference relating to signal lamps (e.g., J1133 School Bus Stop Arms in Standard No. 131 School Bus Pedestrian Safety Devices and J590b Automotive Turn Signal Flashers in Standard No. 108), J887 contains no 'percent current 'on' time' requirements. I hope that this answers your question. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam4741OpenMr. Michael F. Pickholz President, Panda Technik 35656 Ashford Sterling Heights, MI 48077; Mr. Michael F. Pickholz President Panda Technik 35656 Ashford Sterling Heights MI 48077; "Dear Mr. Pickholz: This is in reply to your letter of April l9, l990 enclosing a sample of a motor vehicle reflector, expressing your concern that 'no laws or regulations are violated in the use' of it. It is contemplated that the reflector will be distributed in the United States to enhance nighttime and adverse weather visibility of slow moving/stationery vehicles. The reflective efficiency is represented to be up to ten times that of conventional reflectors, such as those 'required by law' on motor vehicles. The photograph you enclosed shows the reflectors mounted on a large, wide truck or trailer. The reflector 'can be installed with simple hand tools', on either the front or rear of the vehicle. It is apparent from your letter that Panda intends the reflector to be an aftermarket device, and one that is capable of installation by the vehicle owner. There are no Federal motor vehicle safety standards that apply to the reflector as an aftermarket device, and there is no Federal prohibition applicable to installation of the reflector by a vehicle owner. There is a general prohibition of the National Traffic and Motor Vehicle Safety Act under which modifications may not be performed to vehicles in use, by manufacturers, distributors, dealers, and motor vehicle repair businesses, if they result in rendering inoperable, in whole or in part, any device or element of design installed in accordance with a Federal motor vehicle safety standard. Should the reflective efficiency and mounting location of your reflector result in a reduced ability of drivers of other vehicles to perceive the turn and stop signals of the vehicle on which the reflector is mounted, we would regard the turn and stop signals to have been rendered inoperable in part within the meaning of the prohibition. Thus, you should ensure that the device would not have this effect. Supplementary lighting devices are also subject to the laws of the States in which they are sold and used. We are unable to advise you on State laws and suggest that you write the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, for an opinion. We are returning your sample. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam4131OpenMr. Rich Demski, Engineering, Federal Motors Inc., P.O. Box 5000, Ocala, FL 32678; Mr. Rich Demski Engineering Federal Motors Inc. P.O. Box 5000 Ocala FL 32678; Dear Mr. Demski: This responds to your request for an interpretation of Federal Moto Vehicle Safety Standard (FMVSS) No 101, *Controls and Displays*. You asked about the identification requirements applicable to a coolant temperature telltale. According to your letter and an accompanying drawing, you are currently identifying the telltale with the identifying symbol for the coolant temperature telltale specified by Table 2 of FMVSS No. 101, and the words 'ENG WATER TEMP'. Noting that some of your vehicles have engines which are air-cooled rather than water-cooled, you asked if FMVSS No. 101 permits you to delete the word 'WATER' while otherwise continuing to identify the telltale as described above. As discussed below, the answer to your question is yes.; By way of background information, the National Highway Traffic Safet Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, the manufacturer has the responsibility to certify that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.; Section S5.2.3 of FMVSS No. 101 states in relevant part: >>>Except for informational readout displays, any display locate within the passenger compartment and listed in column 1 of Table 2 that has a symbol designated in column 4, shall be identified by that symbol. Such display may, in addition be identified by the word or abbreviation shown in column 3. . . . Informational readout displays may be identified by the symbol designated in column 4 of Table 2 or by the word or abbreviation shown in column 3. Additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. . . .<<<; The coolant temperature telltale is a display listed in Table 2 o FMVSS No. 101, and the symbol pictured in your letter is the identifying symbol for that telltale specified in column 4 of the table. Therefore, under section S5.2.3 of the standard, your use of that symbol to identify the coolant temperature telltale is sufficient identification regardless of what, if any, identifying words you provide for the purpose of clarity.; Sincerely, Erika Z. Jones, 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.