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: aiam0281OpenMr. R. C. Lowry, Plant Manager, Honiron, P.O. Box 3140, Honolulu, HI 96802; Mr. R. C. Lowry Plant Manager Honiron P.O. Box 3140 Honolulu HI 96802; Dear Mr. Lowry: This is in reply to your letter of June 17, 1971, concerning the notic published April 14, 1971 (36 F.R. 7054) amending the Certification regulations (49 CFR Part 567) and establishing regulations governing 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568). You ask whether as a trailer manufacturer you need comply only with the requirements of S 567.4(g)(1) at present, and need not comply with S 567.4(g)(2) through 567.4(g)(7) until October 1, 1972. The answer to this question is no. The amendment to the regulations on which your question is based merely added the requirements of S 567.4(g)(1)(iii), 567.4(g)(3), and 567.4(g)(4) to existing requirements that have been in effect since September 1, 1969 (copy enclosed). Thus, the requirements of S 567.4(g)(1)(i) and (ii), and 567.4(g)(2), (g)(5), (g)(6) and (g)(7) (as they appear in the notice of April 14, 1971) have been in effect since September 1, 1969. Of the new provisions, S 567.4(g)(1)(iii) did become effective June 1, 1971. The effective date of the other new provisions has been corrected to January 1, 1972, by a notice published April 27, 1971 (36 F.R. 7855), a copy of which is also enclosed.; You are correct in interpreting 'gross vehicle weight rating' as i applies to trailers, to exclude the weight of the tractor or other towing vehicle. It includes, as you state, only the weight of the fully loaded trailer. You are also correct in interpreting 'gross axle weight rating' as it applies to trailers to apply to only the weight applied to the axle of the trailer. It does not include the weight applied to any part of the towing vehicle.; If you have further questions, please let us know. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam3015OpenMr. H. Miyazawa, Director, Automotive Lighting, Engineering Department, Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. H. Miyazawa Director Automotive Lighting Engineering Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Miyazawa: This is in reply to your letter of April 28, 1979, asking two question with respect to certification of lighting equipment by use of the DOT symbol, as permitted by S4.7.2 of Federal Motor Vehicle Safety Standard No. 108.; Your first question is whether disassembled parts such as lenses screws, or bulbs must also be certified as conforming to all applicable Federal motor vehicle safety standards. The answer is no, only the completed lamp assembly must be so certified.; You have also asked 'in the case of lamp lens incorporated with refle reflector do we have to label the DOT label on this reflex reflector certifying it meets FMVSS?' The answer is yes. Although the lamp lens is not a required equipment item and not certified since it is only part of a lamp, the reflex reflector incorporated in it must be certified since the reflector is an item required by Standard No. 108.; I hope this answers your questions. Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1254OpenMr. Robert G. Beaumont, President, Sebring Vanguard, Inc., P.O. Box 1479, Sebring Air Terminal, Sebring, FL 33870; Mr. Robert G. Beaumont President Sebring Vanguard Inc. P.O. Box 1479 Sebring Air Terminal Sebring FL 33870; Dear Mr. Beaumont: We have received your letter of September 7, 1973, to Mr. Vinson wit its enclosures and appreciate your providing them.; In your 'memo' on purchase orders you state that Sebring Vanguard 'ha decided that our vehicles are multi- purpose vehicles.' The Vanguard, however, is not for purposes of the safety standards a multipurpose passenger vehicle, defined as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' (In a recent notice, copy enclosed, we have proposed a change in this definiton (sic) that would make it more restrictive.); The Vanguard as we understand it is a 'passenger car', defined as vehicle designed for carrying 10 passengers or less, other than a multipurpose passenger vehicle, motorcycle, or trailer. Vehicle design, rather than actual usage, is the definitional determinant, and the fact that some purchasers of a Vanguard may use it off-road or as a replacement for MPV's does not change its category.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0224OpenMr. Folke Kohler, Scandex Sakerhetsglas Akteibolag, Box 218, S-261 22 Londskrona 1, Sweden; Mr. Folke Kohler Scandex Sakerhetsglas Akteibolag Box 218 S-261 22 Londskrona 1 Sweden; Dear Mr. Kohler: This is in reply to your letter of March 3, 1970 in which you applie to the National Highway Safety Bureau for registration of glazing materials your company intends exporting to the United States for use in motor vehicles.; It is important that you understand that the National Highway Safet Bureau does not approve or certify that glazing materials meet the requirements of the Federal Motor Vehicle safety Standard applicable thereto (No. 205, copy enclosed). Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C. 1403 (a copy of the Act is also enclosed) requires the manufacturer to certify that his product complies with all applicable U.S. standards. You may certify that your company's glazing materials meet the standard by following the requirements of Section 114 of the Act or by following the certification alternative provided for in S3.4 of Standard No. 205. If you choose to use the alternative method provided for in the Standard you must apply for an approved manufacturer's code mark.; Although the Bureau does not certify glazing material as complying, i does conduct a compliance program to determine if the manufacturer's product does, in fact, comply with the applicable standards. Persons selling non-complying items of motor vehicle equipment are subject to a civil penalty of up to $1,000 per violation (see Sections 108 and 109 of the Act).; In addition, your attention is directed to Section 110(e) of the Ac which requires persons exporting motor vehicles and motor vehicle equipment into the United States to designate an agent for service of process. See Subpart D-Service of Process: Agents, of the General Procedural Rules (copy enclosed).; Sincerely, Lawrence R. Schneider, Chief, Regulations Division |
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ID: aiam0223OpenMr. Folke Kohler, Scandex Sakerhetsglas Aktiebolag, Box 218, S-261 22 Landskrona 1, Sweden; Mr. Folke Kohler Scandex Sakerhetsglas Aktiebolag Box 218 S-261 22 Landskrona 1 Sweden; Dear Mr. Kohler: This is in reply to your letter of March 3, 1970 in which you applie to the National Highway Safety Bureau for registration of glazing materials your company intends exporting to the United States for use in motor vehicles.; It is important that you understand that the National Highway Safet Bureau does not approve or certify that glazing materials meet the requirements of the Federal Motor Vehicle Safety Standard applicable thereto (No. 205, copy enclosed). Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C. 1403 (a copy of the Act is also enclosed) requires the manufacturer to certify that his product complies with all applicable U.S. standards. You may certify that your company's glazing materials meet the standard by following the requirements of Section 114 of the Act or by following the certification alternative provided for in S3.4 of Standard No. 205. If you choose to use the alternative method provided for in the Standard you must apply for an approved manufacturer's code mark.; Although the Bureau does not certify glazing material as complying, i does conduct a compliance program to determine if the manufacturer's product does, in fact, comply with the applicable standards. Persons selling non-complying items of motor vehicle equipment are subject to a civil penalty of up to $1,000 per violation (see Sections 108 and 109 of the Act).; In addition, your attention is directed to Section 110(e) of the Ac which requires persons exporting motor vehicles and motor vehicle equipment into the United States to designate an agent for service of process. See Subpart D-Service of Process: Agents, of the General Procedural Rules (copy enclosed).; Sincerely, Lawrence R. Schneider, Chief, Regulations Division |
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ID: aiam1532OpenMr. James W. Long,Continental Hydraulic Hose Corp.,P.O. Box 104,Upper Sandusky, Ohio 43351; Mr. James W. Long Continental Hydraulic Hose Corp. P.O. Box 104 Upper Sandusky Ohio 43351; Dear Mr. Long:#This responds to your May 16, 1974, request for approva of Continental's banding technique to meet the requirements of Standard No. 106,*Brake hoses*, for labeling brake hose assemblies, and for use of the letter 'C' to identify Continental as an assembly manufacturer.#The NHTSA interprets a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot be easily be removed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. the NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of specific design. #The letter 'C' has already been recorded with the Office of Standards Enforcement as the manufacturer designation for Continental Gummi-Werke A.G. of Germany. Please submit another choice to: Office of Standards Enforcement, 'Brake Hose Identification', National Highway Traffic Safety Administration, 400 Seventh St. S.W., Washington D.C. 20590.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam1483OpenMr. Al Zajic, Project Engineer, American Trailers, Inc., 5702 E. Admiral Place, 15708 Admiral Station, Tulsa, OK 74115; Mr. Al Zajic Project Engineer American Trailers Inc. 5702 E. Admiral Place 15708 Admiral Station Tulsa OK 74115; Dear Mr. Zajic: This responds to your April 12, 1974, question whether a permanentl attached steerable axle on a trailer is required (1) to meet the S5.3.2 stopping distance requirement with no uncontrolled lockup of any wheel above 10 mi/h, and (2) to meet the parking brake requirements for trailer converter dollies or for all other vehicles.; The answer to your first question is yes. The steerable axle(s) of an trailer must meet the stopping distance requirements of S5.3.2 with no uncontrolled lockup of wheels above 10 mi/h.; In answer to your second question, the permanently attached steerabl axle you describe is not a separate vehicle which would qualify as a trailer converter dolly. Therefore the axle is simply part of a trailer which must meet the parking brake requirements of either S5.6.1 or S5.6.2. Neither of these options specifies that there be parking brakes on steerable axles, although in satisfaction of S5.6.2 (grade holding), the manufacturer could utilize parking brakes on the steerable axle.; Yours truly, Richard B. Dyson, Chief Counsel |
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ID: aiam2472OpenMr. Michael E. Bufkin, 1136 Gail Lane, Sleepy Hollow, IL 60118; Mr. Michael E. Bufkin 1136 Gail Lane Sleepy Hollow IL 60118; Dear Mr. Bufkin: This responds to your November 12, 1976, question whether a tire bran name owner is required by S 574.7(b) of Part 574, *Tire Identification and Recordkeeping*, to establish and maintain specified purchaser information on its tires if the distributor or dealer fails to provide that information as specified by S 574.8 of the regulation. You also ask whether a tire registration form with dimensions other than those specified in Figure 3 of the regulation may be provided to tire distributors and dealers.; Section 158(b) of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. S 1418(b)) mandates the tire manufacurer's (sic) (including brand name owner's) responsibility to establish and maintain the purchaser information, independent of the distributor's or dealer's cooperation:; >>>S 158(a)(1) * * * * * (b) Every manufacturer of motor vehicle or tires shall cause th establishment and maintenance of records of the name and address of the first purchaser of each motor vehicle and tire produced by such manufacturer * * *<<<; Thus, the brand name owner's responsibility is a statutory one independent of any interpretation of Part 574.; With regard to the size of the tire registration form, S 574.7(a permits the use of any size form unless a dealer requests forms that conform to the universal format set forth in Figure 3. The agency has interpreted the requirement for provision of the universal format to not apply in the case of a dealer that sells only one brand of tire.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam3818OpenMr. Jacob Sheeskin, Sheeskin, Hillman & Lazar, P.C., 6110 Executive Boulevard, P.O. Box 2186, Rockville, MD 20852; Mr. Jacob Sheeskin Sheeskin Hillman & Lazar P.C. 6110 Executive Boulevard P.O. Box 2186 Rockville MD 20852; RE: your file 3189/001:11 Dear Mr. Sheeskin: This responds to your letter of March 7, 1984, concerning discussion between your client and the Maryland State Police about the application of tinting or sun screening materials to vehicle glazing materials. This office has sent two letters of interpretation concerning the application of glazing materials to the Maryland State Police. I am enclosing a copy of the agency's letters of December 20, 1983 and April 3, 1984 and the Maryland States Police's original request for an interpretation.; As stated in our letter of April 3, 1984, the application of tintin materials to glazing does not, in and of itself, constitute a violation of the render inoperative provisions of section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. To violate section 108(a)(2)(A), manufacturers, distributors, dealers, and motor vehicle repair shops that install tinting materials must knowingly install materials which render inoperative the glazing material's compliance with Standard No. 205. Thus, for example, a motor vehicle repair shop would be in violation of section 108(a)(2)(A) if it knowingly installed on a passenger car's window a tinting material which would render inoperative the glazing's compliance with the abrasion resistance or luminous transmittance requirements of the standard.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1745OpenMr. Gerhard P. Reichel, Attorney, Volkswagen of America, Inc., Englewood Cliffs, New Jersey 07632; Mr. Gerhard P. Reichel Attorney Volkswagen of America Inc. Englewood Cliffs New Jersey 07632; Dear Mr. Reichel: This is in reply to your letter of December 4, 1974, to Michael Pesko of this office asking whether it is permissible under Standard No. 110 to refer to air conditioning and automatic transmission option in stating the 'vehicle capacity weight' on the placard required under S4.3 of the standard. The format you suggest would state a vehicle capacity weight, followed on a separate line by the statement: 'If air conditioning is installed, subtract 82 pounds.' you also ask whether basic vehicle body style may be similarly treated. Your request is based on your desire to standardize the placard required by Standard No. 110, to make the placarding requirements less expensive to meet.; We interpret Standard No. 110 to permit the use of a standardize placard that contains various vehicle capacity weights based on body style or the presence of various options. However, in such a case we believe that label should at least initially contain the lowest vehicle capacity weight for the vehicle, that is, a weight which presumes that the vehicle is equipped with those options having an effect on vehicle capacity weight. If the absence of these options increases the vehicle capacity weight, we believe this should be stated beneath the basic vehicle capacity weight, and by specifying the actual weight with the option omitted rather than asking the reader to perform a computation.; 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.