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: aiam0475OpenMr. John Lucas, Commercial Rubber Company, 1659 East 23rd Street, Los Angeles, CA 90011; Mr. John Lucas Commercial Rubber Company 1659 East 23rd Street Los Angeles CA 90011; Dear Mr. Lucas: This is in reply to your letter of October 14, 1971, in which you as whether matrices (or molds) must be relettered to a new identification code mark when the ownership of a company is transferred from father to son. The son may continue to use the existing number if he will write a letter to us stating that he is the new owner, the date on which he became the new owner, that he wishes to continue to use the same identification code mark, and that he assume all responsibility under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 *et*. *seq*.) for tires manufactured with the identification mark on or after the date he assumes ownership of the company. This letter should also refer to the name of the old company and should include any changes being made in company name, address and types of tires being retreaded.; With the above procedure the matrices would not have to be relettered We will change our records to conform to the information contained in the letter.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam0899OpenMr. M. Terasawa, Representative, Nippondenso Company, Ltd., 1099 Wall Street, West, Lyndhurst, NJ 07071; Mr. M. Terasawa Representative Nippondenso Company Ltd. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Terasawa: This is in reply to your letter of October 25, 1972, telling us tha you have tested turn signal flashers in accordance with Motor Vehicle Safety Standard No. 108a, which you believe is a more severe test than Standard No. 108, and asking our views as to whether you should retest in accordance with Standard No. 108.; The important question is not whether one standard establishes a mor severe test than another, but whether a flasher meets all performance requirements applicable to it on the date of its manufacture. The legal obligation of a manufacturer is to insure that it does. The requirements currently applicable to flashers are those of Standard No. 108.; It is true that Standard No. 108a has been 'repealed' and No. 10 'reinstated'. The reason for this action is a judicial decision that the NHTSA did not provide adequate public notice and opportunity to comment on the flasher requirements in Standard No. 108a. However, the NHTSA has proposed that the flasher performance requirements of Standard No. 108a be re- adopted, and is offering the public an opportunity to comment. I enclose a copy of the notice for your information.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3656OpenMr. A. Forbes Crawford, No. 10 - 905 Chilco Street, Vancouver, British Columbia, Canada V6G 2R3; Mr. A. Forbes Crawford No. 10 - 905 Chilco Street Vancouver British Columbia Canada V6G 2R3; Dear Mr. Crawford: This is in reply to your letter of January 10, 1983, to Secretary Lewi recommending that he make an 'administrative decision' that would exempt foreign manufacturers from compliance with National Highway Traffic Safety Administration (NHTSA) regulations for vehicles conforming to standards of their country of origin, and which are produced in quantities 'up to 50,000 per year with engines not exceeding 65 cu. in. or 1100cc (sic).'; The Department does not have the legal authority to issue a directiv of this nature. The National Traffic and Motor Vehicle Safety Act requires that all motor vehicles offered for sale in the United States meet all applicable Federal motor vehicle safety standards, unless temporarily exempted. No permanent exemption is authorized for any type of vehicle, and no discretionary power is provided for this purpose. Authority of a nature responsive to your request could be provided only by a Congressional amendment to the Act.; As a former principal of Jet Industries which was the beneficiary o one of the NHTSA temporary exemptions (No. 76-1) and an extension of it, you are aware that a mechanism exists by which you may participate in the American market in a manner that takes into account both your economic realities and our safety concerns.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2137OpenMr. Andrew W. Brainerd, Brainerd & Bridges, 1 North LaSalle Street, Chicago, Illinois 60602; Mr. Andrew W. Brainerd Brainerd & Bridges 1 North LaSalle Street Chicago Illinois 60602; Dear Mr. Brainerd: #This is in response to your October 30, 1975 letter requesting clarification of the status of the banding requirement of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #The National Highway Traffic Safety Administration (NHTSA) has granted petitions, filed by General Motors Corporation and Ford Motor Company, which requested deletion of the banding requirement. This deletion is the 'change now being developed in our rulemaking proceedings' to which you have referred. The complete elimination of the banding requirement is inconsistent with any substitute labeling requirement. The petition of your client, Kugelfischer Georg Schaefer & Co., was denied for this reason. #You should understand that our commencement of a rulemaking proceeding does not signify that the requested amendment will necessarily be issued. It does indicate, however, a determination that there is a reasonable possibility that the requested amendment will be issued. A final decision concerning the issuance of a proposal to amend the standard will be made on the basis of all available information developed in the course of the proceeding, in accordance with statutory criteria. If the NHTSA determines that such an amendment would not be appropriate, the amendment which you have requested will be considered as an alternative. We do expect to issue a proposal in the near future. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs; |
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ID: aiam3657OpenMr. A. Forbes Crawford, No. 10 - 905 Chilco Street, Vancouver, British Columbia, Canada V6G 2R3; Mr. A. Forbes Crawford No. 10 - 905 Chilco Street Vancouver British Columbia Canada V6G 2R3; Dear Mr. Crawford: This is in reply to your letter of January 10, 1983, to Secretary Lewi recommending that he make an 'administrative decision' that would exempt foreign manufacturers from compliance with National Highway Traffic Safety Administration (NHTSA) regulations for vehicles conforming to standards of their country of origin, and which are produced in quantities 'up to 50,000 per year with engines not exceeding 65 cu. in. or 1100cc (sic).'; The Department does not have the legal authority to issue a directiv of this nature. The National Traffic and Motor Vehicle Safety Act requires that all motor vehicles offered for sale in the United States meet all applicable Federal motor vehicle safety standards, unless temporarily exempted. No permanent exemption is authorized for any type of vehicle, and no discretionary power is provided for this purpose. Authority of a nature responsive to your request could be provided only by a Congressional amendment to the Act.; As a former principal of Jet Industries which was the beneficiary o one of the NHTSA temporary exemptions (No. 76-1) and an extension of it, you are aware that a mechanism exists by which you may participate in the American market in a manner that takes into account both your economic realities and our safety concerns.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4027OpenMr. Ezio Masina, Product Manager, Forjas Taurus, S.A., Av. do Forte, 511, 90 000 Porto Alegre - RS, Brazil; Mr. Ezio Masina Product Manager Forjas Taurus S.A. Av. do Forte 511 90 000 Porto Alegre - RS Brazil; Dear Mr. Masina: Thank you for your letter of September 3, 1985, to Mr. Franci Armstrong of this agency, concerning the 'DOT' label required on motorcycle helmets sold in the United States. Your letter was referred to my office for reply.; You explained that you have reviewed Federal Motor Vehicle Safet Standard No. 218, *Motorcycle Helmets*, and believe that your helmets comply with the requirements of this standard. You asked if you could place the 'DOT' label on your helmets sold outside of the United States.; The National Highway Traffic Safety Administration (NHTSA) has n jurisdiction over helmets sold outside the United States. Therefore, our regulations would not affect how you label your helmets. We, of course, urge you to use the label only on helmets which, in fact, do comply with our standard. In addition, the label should not indicate that NHTSA or the Department of Transportation has endorsed or approved your product. We also recommend that you check the labeling requirements of the countries in which you plan to sell your helmets.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2446OpenMr. Galileo Buzzi-Ferraris, Technical Manager, Pirelli Tire Corporation, 600 Third Avenue, New York, New York 10016; Mr. Galileo Buzzi-Ferraris Technical Manager Pirelli Tire Corporation 600 Third Avenue New York New York 10016; Dear Mr. Buzzi-Ferraris: This is in response to your November 1, 1976, letter to Mark Schwimme of my staff, concerning the marking 'V1' on passenger car tires.; The marking 'V1' is not required by any Federal statute, motor vehicl safety standard, or other regulation to appear on the sidewall of passenger car tires. Furthermore, Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 as amended, 15 U.S.C. 1392(d), provides in pertinent part:; >>>Whenever a Federal motor vehicle safety standard established unde this title is in effect, no State of political subdivision of a State shall have any authority either o establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.<<<; This provision, considered with Federal Motor Vehicle Safety Standar No. 109, prohibits any State from imposing any safety labeling requirements for passenger car tires other than those contained in that standard. Any differing safety labeling requirements, including the 'V1' that you have mentioned, are thus preempted and void.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2043OpenMr. James H. Whitaker, Associate Professor, The University of Connecticut, Storrs, CT 06268; Mr. James H. Whitaker Associate Professor The University of Connecticut Storrs CT 06268; Dear Mr. Whitaker: Please forgive the delay in responding to your letter of May 22, 1975 which inquired about the status of tire grading standards.; On May 20, 1975, the National Highway Traffic Safety Administratio issued the Uniform Tire Quality Grading Standards with a series of effective dates beginning January 1, 1976 (40 FR 23073, May 28, 1975). On July 3, 1975, the regulation was republished with minor changes (40 FR 28071). On August 14, 1975, a stay of the effective dates was granted by the United States Court of Appeals for the Sixth Circuit, pending review of the validity of the regulation in a suit brought by eight tire manufacturers.; For your convenience, I have enclosed copies of the Federal Registe notices referred to above.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2041OpenMr. James H. Whitaker, Associate Professor, The University of Connecticut, Storrs, CT 06268; Mr. James H. Whitaker Associate Professor The University of Connecticut Storrs CT 06268; Dear Mr. Whitaker: Please forgive the delay in responding to your letter of May 22, 1975 which inquired about the status of tire grading standards.; On May 20, 1975, the National Highway Traffic Safety Administratio issued the Uniform Tire Quality Grading Standards with a series of effective dates beginning January 1, 1976 (40 FR 23073, May 28, 1975). On July 3, 1975, the regulation was republished with minor changes (40 FR 28071). On August 14, 1975, a stay of the effective dates was granted by the United States Court of Appeals for the Sixth Circuit, pending review of the validity of the regulation in a suit brought by eight tire manufacturers.; For your convenience, I have enclosed copies of the Federal Registe notices referred to above.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1369OpenMr. Danny Lanzdorf,Oshkosh Truck Corporation,2307 Oregon St.,Oshkosh, Wisconsin 54901; Mr. Danny Lanzdorf Oshkosh Truck Corporation 2307 Oregon St. Oshkosh Wisconsin 54901; Dear Mr. Lanzdorf:#This is to confirm your conversation of December 12 1974, with Mark Schwimmer of this office, in which you requested information on the permissibility of spray painting brake hose end fittings in the trucks which you manufacture.#Because the construction of the brake hose assembly is completed before the spray painting would take place, the only requirement of Motor Vehicle Safety Standard No. 106-74 which might prohibit the painting would be a vehicle requirement. Standard No. 106-74 as applied to vehicles is not effective until September 1, 1975, therefore, you may spray paint end fittings until then. The next Federal Register notice concerning the standard will deal with the permissibility of painting end fittings after the September, 1975 effective date.#Yours truly,Richard B. Dyson,Acting 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.