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: aiam3268OpenMr. Arnold van Ruitenbeek, Vice President, Continental Product Corporation, 1200 Wall Street West, Lyndhurst, new Jersey 07071; Mr. Arnold van Ruitenbeek Vice President Continental Product Corporation 1200 Wall Street West Lyndhurst new Jersey 07071; Dear Mr. Ruitenbeek: This responds to your March 28, 1980, letter to this office in whic you inquired about permissible markings on motorcycle tires. Specifically, you asked whether you could insert language in addition to that specified in Standard No. 119 when labeling the load rating and inflation pressure on certain tire sizes. The answer to your question is no.; Standard No. 119 ( 49 CFR S 571.119) specifies certain requirement which all motorcycle tires offered for sale in this country must meet. One of these provisions is the labeling requirement set fourth in paragraph s6.5 of the standard. Subparagraph (d) of s6.5 requires the maximum load rating and corresponding inflation pressure to appear on the tire in the following words: 'Max load * *lbs at * *psi cold.' The language of the subsection is mandatory and does not permit any variation. Therefore, the insertion of the phrase 'in USA and Canada,' as you suggest, would mean the tire would not comply with the labeling requirement of Standard No. 119.; The reason for this strict wording requirement is to ensure that th information labeled on motorcycle tires conveys necessary information to the purchaser of the tire in a clear, straightforward manner that is uniform with all motorcycle tires. Adding language which suggests that the maximum load of a tire depends on the country in which the tire is being used could confuse the user of the tire. Further, it suggests that the printed maximum load is not rally the maximum. Either of the results frustrates the purpose of the labeling requirement in Standard No. 119.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2839OpenMr. G. Bertella, Chief, Lighting and Optic Laboratory, Fiat- SA-GVF, Sperimentazione-Comp. Gruppi, C. Agnelli 200, 10135 Torino, Italy; Mr. G. Bertella Chief Lighting and Optic Laboratory Fiat- SA-GVF Sperimentazione-Comp. Gruppi C. Agnelli 200 10135 Torino Italy; Dear Mr. Bertella: This responds to your letter of May 8, 1978, to Mr. Vinson of thi office concerning the version of SAE J567, *Bulb Sockets*, applicable as a subreferenced standard to Federal Motor Vehicle Safety Standard No. 108.; The SAE standards which are specified in Standard No. 108 are cited b a number and letter to indicate the applicable version. These directly referenced SAE standards often subreference other SAE standards by inclusion of such terms as 'reference is made to SAE J* *' or 'reference SAE J* *' in which case, unless otherwise specified in Standard No. 108, the subreferenced standard is the version contained in the 1970 SAE Handbook (see paragraph S5.1 of Standard No. 108).; The subreferenced SAE standard closest in subject matter to J567 i J573d, *Lamp Bulbs and Sealed Units*', December 1968. By NHTSA interpretation J573 is not exclusive, and other bulb designs including tubular type bulbs are permitted which are not included in SAE J573. There is no subreferenced notation to SAE J567 contained in SAE J573d. Further, although the agency issued an interpretation in 1968 indicating that SAE Standard J575d, *Tests for Motor Vehicle Lighting Devices and Components*, August 1967, referenced J567, that statement was incorrect and J575d contains no such reference. Therefore SAE J567 is not a subreferenced standard in Standard No. 108. When an SAE Standard is not referenced or subreferenced by a Federal Standard, compliance with it is voluntary, and you may therefore use (or not use) SAE J567 or any version thereof as you choose, as long as the assembled lamp complies with Standard No. 108.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1073OpenMr. Abner J. Mikva, D'ANCONA, PFLAUM, WYATT & RISKIND, 33 North LaSalle Street, Chicago, Illinois 60602; Mr. Abner J. Mikva D'ANCONA PFLAUM WYATT & RISKIND 33 North LaSalle Street Chicago Illinois 60602; Dear Mr. Mikva: This is in response to your letter of March 19, 1973, in which yo asked that the NHTSA reconsider its decision to disallow the addition of devices such as flags to the warning devices regulated by motor vehicle safety standard No. 125. Your argument was that 'the motion of the flag makes it far more visible as objective test previously submitted to the Department of Transportation have suggested.'; We do not disagree with your assertion that the visibility of th device could be increased by the addition of flags. It is obviously true, and could be said of a variety of devices that could be added to the triangle to increase its size, brightness, or movement. The basic decision involved in the issuance of this standard, however, is that uniformity, and the recognition advantages that are associated with visibility. Although the addition of flags or other devices could increase the visibility of the warning devices, they would decrease their uniformity and recognizability.; For these reasons, your request that the NHTSA reconsider it requirement that warning device consist only of the specified triangle and its supports is denied. I assure you that no 'considerations not of the record' have entered into this decision.; Sincerely, James E. Wilson, Acting Administrator |
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ID: aiam0061OpenMaurice Wexler, Esq., Heiskell, Donelson, Adams, Williams & Wall, Suite 2020 First National Bank Building, Memphis, TN 38103; Maurice Wexler Esq. Heiskell Donelson Adams Williams & Wall Suite 2020 First National Bank Building Memphis TN 38103; Dear Mr. Wexler: Mr. Bridwell has asked that I reply to your letter of April 9, 1968. Enclosed for your information is a copy of the chassis-cab ruling an regulation issued December 29, 1967. Under the terms of the ruling and regulation and the National Traffic and Motor Vehicle Safety Act of 1966, when a truck body manufacturer assembles the truck body to a chassis-cab he is responsible for certification only if the completed vehicle is delivered to a dealer or distributor. The body manufacturer assembling the body to the chassis-cab would, however, be responsible for the vehicle's compliance with the lighting standard if not previously met by the chassis-cab manufacturer. Moreover if the addition of the body affects the chassis-cabs previous compliance with standards the body manufacturer would be responsible for compliance.; With regard to bodies mounted on chassis-cabs manufactured prior t January 1, 1968 compliance and certification is not required. However, the body, if manufactured on or after January 1, 1968, would have to contain glazing that complies with Standard No. 205 because the body is manufactured for use on motor vehicles and as such must meet any applicable equipment standards.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel |
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ID: aiam3827OpenMr. Takeshi Tanuma, Chief Operating Office, Nissan Research & Development, Inc., P.O. Box 8650, Ann Arbor, MI 48104; Mr. Takeshi Tanuma Chief Operating Office Nissan Research & Development Inc. P.O. Box 8650 Ann Arbor MI 48104; Dear Mr. Tanuma: This responds to your April 4, 1984 letter regarding the use of tw certification labels on motor vehicles, with each label containing a portion of the information specified in 49 CFR Part 567 and the two labels together providing all the specified information.; While the certification regulations specify that 'a label' shall b used, the agency has permitted the use of a label in two parts in circumstances which will not lead to confusion and which will satisfy the basic intent of Part 567. In particular, the two portions of the label must be placed in close proximity to each other, to permit individuals to readily find all the specified information and to leave no doubt as to the significance of either portion of the label. Further, the two portions must be oriented in such a manner that the information specified in section 567.4(g) of the certification regulations appears in the required order. As a practical matter, these considerations require that the two portions be affixed to the same vehicle part. While we cannot specify a particular distance as a maximum permissible separation of the two portions of the label, the two portions must be located so as to leave the unmistakable impression that they provide related information.; You also raised the possibility of adding language to one portion o the label to indicate the existence of the other portion and to specify the location of the second portion. While such language is not required, it might be a desirable means of promoting compliance with the considerations discussed above.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3830OpenMr. Takeshi Tanuma, Chief Operating Office, Nissan Research & Development, Inc., P.O. Box 8650, Ann Arbor, MI 48104; Mr. Takeshi Tanuma Chief Operating Office Nissan Research & Development Inc. P.O. Box 8650 Ann Arbor MI 48104; Dear Mr. Tanuma: This responds to your April 4, 1984 letter regarding the use of tw certification labels on motor vehicles, with each label containing a portion of the information specified in 49 CFR Part 567 and the two labels together providing all the specified information.; While the certification regulations specify that 'a label' shall b used, the agency has permitted the use of a label in two parts in circumstances which will not lead to confusion and which will satisfy the basic intent of Part 567. In particular, the two portions of the label must be placed in close proximity to each other, to permit individuals to readily find all the specified information and to leave no doubt as to the significance of either portion of the label. Further, the two portions must be oriented in such a manner that the information specified in section 567.4(g) of the certification regulations appears in the required order. As a practical matter, these considerations require that the two portions be affixed to the same vehicle part. While we cannot specify a particular distance as a maximum permissible separation of the two portions of the label, the two portions must be located so as to leave the unmistakable impression that they provide related information.; You also raised the possibility of adding language to one portion o the label to indicate the existence of the other portion and to specify the location of the second portion. While such language is not required, it might be a desirable means of promoting compliance with the considerations discussed above.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1876OpenMr. Owen R. Hildreth, Owen's International Inc., 16725 Van Dam Road, South Holland, IL 60473; Mr. Owen R. Hildreth Owen's International Inc. 16725 Van Dam Road South Holland IL 60473; Dear Mr. Hildreth: This responds to your March 14, 1975, question whether a truck deale or his customer may modify the brake system on a vehicle which is manufactured in conformity with Standard No. 121, *Air brake systems*, after the first purchase of the vehicle in good faith for purposes other than resale.; The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391 e seq.) requires that a vehicle meet all applicable safety standards at the time of sale. Conformity is not required, however, after the first purchase of the vehicle in good faith for purposes other than resale. In answer to your second question, therefore, the vehicle becomes 'used' after its first purchase in good faith for purposes other than resale. 'Good faith' means that the purchaser could not purchase the vehicle before an agreed-on modification simply to avoid the effect of the standard. Your modifications can be undertaken only on a vehicle which has already been purchased in good faith.; As for modification that you or your customer might wish to undertake he may himself make whatever changes he cares to, subject to State or motor carrier regulations. The Act does, however, prohibit manufacturers, distributors, dealers, or motor vehicle repair businesses from knowingly rendering inoperative any device or element of design installed on a motor vehicle in compliance with an applicable safety standard (except during repairs). Thus you could not modify the 121 system to render it inoperative.; As long as you and customer do not violate these provisions, the futur sale of a modified vehicle would not be in violation of the Act.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam1619OpenMr. David J. Bate, Service Quality Manager, British Leyland Motors Inc., 600 Willow Tree Road, Leonia, NJ 07605; Mr. David J. Bate Service Quality Manager British Leyland Motors Inc. 600 Willow Tree Road Leonia NJ 07605; Dear Mr. Bate: We have reviewed your draft owner notification letter regarding th noncompliance of certain Jaguar 'E' Type 2+2 sedans which fail to conform to Motor Vehicle Safety Standard No. 207. We find that your letter fails to conform to 49 CFR Part 577, 'Defect Notification' in two respects. It does not conform to section 577.4(b)(1), which specifies the content of the second sentence of each notification. We do not consider the determination that a safety related defect exists in these vehicles to have been made by the NHTSA Administrator. Such a determination can only follow proceedings held pursuant to section 113(e) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1402(e)). No such proceeding has been held in this case. The correspondence you received is directed at what we consider to be a formalized settlement of the matter, and not a formal determination proceeding. The first two sentences of your second paragraph should therefore be changed to read:; >>>'British Leyland Motors Inc., has determined that a defect whic relates to motor vehicle safety exists in a range of 1968 to 1972 Jaguar 'E' Type 2+2's. The defect results from a noncompliance with Federal Motor Vehicle Safety Standard No. 207.'<<<; In addition, section 577.4(e)(1)(ii) requires the notification t contain the manufacturer's estimate of the day by which his dealers or other service facility will be supplied with corrective parts and instructions. Your letter mentions only that parts will be in the hands of distributors by a 'campaign launch date.' The information must include an estimated date by which corrective parts will be in the hands of dealers.; In other respects your letter conforms to Part 577. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0078OpenMr. H. Moeller, Research and Development Department, Robert Bosch Corporation, 40-11 - 24th Street, Long Island City, NY 11101; Mr. H. Moeller Research and Development Department Robert Bosch Corporation 40-11 - 24th Street Long Island City NY 11101; Dear Mr. Moeller: Thank you for your letter of May 24, 1968, to Mr. J. E. Leysath of thi Bureau, concerning the testing of automotive flasher devices.; Motor Vehicle Safety Standard 108 specifies that turn signal flasher and vehicular hazard warning signal flashers conform to SAE Standards J590b and J945, respectively. These SAE standards, in turn, require that the test circuitry and test instrumentation conform to SAE Standard J823a. As you noted, the distribution of the 0.10 0.01 ohm series resistance in the standard test circuit (Figure 1 of J823a) is not specified in SAE Standard J823a. Therefore, your recommended distribution, namely, 0.025 0.005 ohms resistance between the power supply (positive terminal) and flasher input terminal, and 0.075 0.005 ohms resistance between the flasher output terminal and the flasher bulbs, would be permitted by SAE Standard J823a.; Flasher units having a ground terminal that is connected with th negative terminal of the power supply may be tested in the standard test circuit of SAE Standard J823a, provided the ground circuitry does not change the required resistance of 0.10 0.01 ohm looking into terminals A-B with the removable shunts in place (see note for Figure 1, SAE J823a).; The above-stated test provisions in no way except the flasher unit from meeting all performance requirements specified in Standard No. 108, including those specified in basically referenced SAE Standards J590b, 'Automotive Turn Signal Flashers,' and J945, 'Vehicle Hazard Warning Signal Flasher.'; Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam3220OpenMr. Heinz W. Gerth, Mercedes-Benz of North America, Inc., One Mercedes Drive, P.O. Box 350, Montvale, NJ 07645; Mr. Heinz W. Gerth Mercedes-Benz of North America Inc. One Mercedes Drive P.O. Box 350 Montvale NJ 07645; Dear Mr. Gerth:#This responds to your letter forwarded to us by Mr Jerry Sonosky, requesting an interpretation of the term 'overall width' as used in Safety Standard No. 104, *Windshield Wiping and Washing Systems*. You ask questions: (1) whether overall width means the design width of a vehicle, or whether it means the maximum possible width allowed by design tolerances, and (2) whether overall width includes plastic, splash molding attached to the vehicle body with screws and nuts.#In answer to your first question, overall width means the maximum design width of the vehicle including tolerances.#Safety Standard No. 104 defines 'overall width' as the maximum overall body width dimension 'W116,' as defined in section E, Ground Vehicle Practice, SAE Aero-space-Automotive Drawing Standards, September 1963. The 'W116' standard specifies that overall width is measured across the body, excluding hardware and applied moldings, but including fenders when integral with the body. Therefore, the overall width of a vehicle would not include splash molding on the sides of the vehicle.#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.