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: aiam4312OpenMr. Robert R. Shapro, Vice President, Transportation Specialist, Inc., 512 Cave Road, Nashville, TN 37210; Mr. Robert R. Shapro Vice President Transportation Specialist Inc. 512 Cave Road Nashville TN 37210; Dear Mr. Shapro: This list responds to your request for 'the fact sheet concernin certification as required' by 49 CFR Parts 567 and 568. You describe your company as a 'multistage manufacturer,' and ask how your company can become certified 'to manufacture or alter vehicles in accordance with the code of Federal regulation.' I regret the delay in responding to your request.; First, please be aware that the National Highway Traffic Safet Administration (NHTSA) has authority to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. The NHTSA does not approve vehicles or equipment, nor do we endorse any commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a certification process under which each manufacturer must certify that its product meets agency safety standards, or other applicable standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.; As you request, I enclose a copy of 49 CFR Part 567, *Certification* and Part 568, *Vehicles Manufactured in Two or More Stages*. Also, for your information, I enclose an information sheet that may be of interest to you if you are new to motor vehicle and motor vehicle equipment manufacture.; Please note that there is no requirement that a company be 'certified before it can manufacture or alter vehicles. 49 CFR Part 566 does require that if a company begins to manufacture motor vehicles subject to any of the Federal safety standards, it must submit information identifying itself and its products to NHTSA not later than 30 days after it begins manufacture.; I hope you find this information helpful. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4311OpenMr. Robert R. Shapro, Vice President, Transportation Specialist, Inc., 512 Cave Road, Nashville, TN 37210; Mr. Robert R. Shapro Vice President Transportation Specialist Inc. 512 Cave Road Nashville TN 37210; Dear Mr. Shapro: This list responds to your request for 'the fact sheet concernin certification as required' by 49 CFR Parts 567 and 568. You describe your company as a 'multistage manufacturer,' and ask how your company can become certified 'to manufacture or alter vehicles in accordance with the code of Federal regulation.' I regret the delay in responding to your request.; First, please be aware that the National Highway Traffic Safet Administration (NHTSA) has authority to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. The NHTSA does not approve vehicles or equipment, nor do we endorse any commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a certification process under which each manufacturer must certify that its product meets agency safety standards, or other applicable standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.; As you request, I enclose a copy of 49 CFR Part 567, *Certification* and Part 568, *Vehicles Manufactured in Two or More Stages*. Also, for your information, I enclose an information sheet that may be of interest to you if you are new to motor vehicle and motor vehicle equipment manufacture.; Please note that there is no requirement that a company be 'certified before it can manufacture or alter vehicles. 49 CFR Part 566 does require that if a company begins to manufacture motor vehicles subject to any of the Federal safety standards, it must submit information identifying itself and its products to NHTSA not later than 30 days after it begins manufacture.; I hope you find this information helpful. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam5134OpenMr. Richard Langlais Prelco Inc. 94 Boulevard Cartier Riviere-Du-Loup Quebec, Canada G5R-2M9; Mr. Richard Langlais Prelco Inc. 94 Boulevard Cartier Riviere-Du-Loup Quebec Canada G5R-2M9; "Dear Mr. Langlais: This responds to your December 7, 1992, inquir requesting information about the agency's requirements set forth in 49 CFR 551.45, Service of Process, Agents. In a November 26, 1991, letter to you, Ms. Kathleen DeMeter, NHTSA's Assistant Chief Counsel for General Law, sent you a letter explaining your responsibilities pursuant to 551.45. You now have some additional questions related to Ms. DeMeter's letter. I am pleased to have this opportunity to respond to your additional questions. As our earlier letter explained, 551.45 sets forth this agency's requirements as they relate to the service of process on non-American manufacturers and importers. One such requirement provides that you must send a declaration of acceptance duly signed by the agent appointed and that agent must be a permanent resident of the United States. The agent may be an individual, a firm, or a U.S. corporation. You asked who could be appointed as your agent and whether we would recommend some agents or firms which specialize in this kind of service. With respect to your first question, any individual, firm, or United States corporation may be an agent provided that it is a permanent resident of this country. With respect to your second question, this agency does not recommend or endorse entities which may serve as an agent. Nevertheless, the National Glass Association, a trade association whose members include automotive glass manufacturers, may be able to assist you. It is located at 8200 Greensboro Drive, Suite 302, McLean Va 22102, and its telephone number is (703) 442-4890. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1122OpenMr. William R. Rodger, Rockwell-Standard Division, Automotive Technical Center, 2445 West Maple Road, Troy, MI 48084; Mr. William R. Rodger Rockwell-Standard Division Automotive Technical Center 2445 West Maple Road Troy MI 48084; Dear Mr. Rodger: By letter of January 31, 1973, Rockwell- Standard requested th National Highway Traffic Safety Administration to postpone the effective date of Motor Vehicle Safety Standard No. 121, *Air Brake Systems*, for twenty-four months with respect to vehicles having front axles with GAWR's of more than 12,000 pounds, single rear axles with GAWR's of more than 23,000 pounds, or tandem rear axles with combined GAWR's of more than 50,000 pounds.; After considering the request, which asks relief from all provisions o the standard, the agency has concluded that an exception of such magnitude is not warranted and therefore denies the request. The agency makes no finding as to whether more limited relief may be appropriate, and does not consider the denial of the January 31 request to preclude the company from submitting petitions for relief from specific aspects of the standard.; Sincerely, James E. Wilson, Associate Administrator, Traffic Safet Programs; |
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ID: aiam0185OpenMr. Frank Stewart, Sales Representative, La France, Precision Casting Company, 1462 South Velacco Street, Los Angeles, CA 90023; Mr. Frank Stewart Sales Representative La France Precision Casting Company 1462 South Velacco Street Los Angeles CA 90023; Dear Mr. Stewart: This is in reply to your letter of February 11, 1969, to Mr. Lowell K Bredwell. Your letter was misplaced and did not reach me until now. I apologize for the delay.; You submitted a label, asking whether it would comply with th Certification Regulations for motor vehicles, with particular reference to campers, trailers and motor homes. The current Certification regulations for motor vehicles, published July 9, 1969 (34 F.R. 11360, copy enclosed), require that the vehicle label contain, in the order listed:; >>>1. name of manufacturer, 2. month and year during which manufacture of the vehicle is completed, 3. the following statement-- 'THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFET STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE,'; 4. vehicle identification number, 5. (for multipurpose passenger vehicles only, as defined in 49 CFR S 371.3) the words 'TYPE MULTIPURPOSE PASSENGER VEHICLE.'<<<; You should note that the above requirements only apply to complet vehicles, which include motor homes and trailers, and not to items of equipment, such as campers, which will be only part of a vehicle. No regulations have been issued as yet for the certification of equipment. Under the National Traffic and Motor Vehicle Safety Act, equipment that either is covered by a standard or, as in the case of most campers, contains other equipment such as glazing that is covered by a standard, must carry a label or tag certifying that the equipment conforms to applicable Federal motor vehicle safety standards.; The label that you submitted differs from the above requirements i several respects. If you or your customers have further questions concerning the certification requirements, we will be please to answer them.; Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor vehicle Safety Performance Service; |
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ID: aiam2941OpenMr. Ben Bagby, Illinois Department of Administrative Services, 716 Stratton Office Building, Springfield, IL 62706; Mr. Ben Bagby Illinois Department of Administrative Services 716 Stratton Office Building Springfield IL 62706; Dear Mr. Bagby: This is in response to your letter of November 28, 1978, requesting ou interpretation of the Federal odometer law. Your questions and answers are as follows:; 1. Is the State of Illinois required to furnish odometer disclosur statements to purchasers of used vehicles which are sold by the State at public auction? Yes. For purposes of the Federal odometer law, it is irrelevant where or how vehicles are sold. The State is the transferor of the vehicles and as such is required under 49 CFR Part 580 to provide every transferee with an odometer disclosure statement.; 2. If the Federal government donates to the State surplus vehicles, i the Federal government required to provide odometer information to the State? Is the State required to furnish odometer information to other governmental units and not-for-profit institutions to whom it sells these vehicles? The answer to both questions is yes. The Federal government has incorporated the odometer disclosure statement onto Standard Form 97, which is the form which officially transfers a vehicle and evidences its release from the custody of the Federal government. In some instances a separate form is used and is attached to Standard Form 97.; Part 580.3 of Title 49 defines 'transferor' as 'any person wh transfers his ownership in a motor vehicle by sale, gift, or any means other than by creation of a security interest.' Therefore, it is irrelevant that the vehicles were donated by the Federal government rather than sold. The State as the new owner must, likewise, provide the purchaser with a disclosure statement.; If you have any further questions, please do not hesitate to write. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1249OpenMr. John Holzer, 217-18 64th Avenue, Bayside, NY 11364; Mr. John Holzer 217-18 64th Avenue Bayside NY 11364; Dear Mr. Holzer: Thank you for your letter of September 7, 1973, requesting informatio concerning possible regulatory action involving plastic or glass gas filters.; Although we have no regulations concerning gasoline filters, the la under which our regulations are promulgated requires that where possible, our standards be based on performance rather than design requirements. This gives the automotive manufacturers maximum flexibility in conforming with the requirements and provides freedom to select whatever design he prefers in order to meet the requirements of the standard.; Our current fuel system requirements are contained in Federal Moto Vehicle Safety Standard No. 301, Fuel Tanks, Fuel Tank Filler Pipes and Fuel Tank Connections, which was effective January 1, 1968. A copy of this standard is enclosed for your information. We have recently issued an amendment to the standard and a proposed amendment which are intended to substantially upgrade fuel systems of motor vehicles between September 1, 1975 and September 1, 1977. Copies of these rulemaking actions are enclosed for your information (38 F.R. 22397 and 22417).; Motor vehicle manufacturers are free to choose the components an designs which they consider most appropriate to their performance requirements. It is quite possible that certain components cannot be used as original equipment because of periodic regulatory actions, for example, a manufacturer may consider a glass fuel filter hazardous when he is attempting the preservation of fuel system integrity incidental to a 20 mile-per-hour, fixed barrier collision.; We would suggest that contact be made with the automotive manufacturer and original equipment manufacturers for a more complete answer to your question.; If we can be of any further assistance, please do not hesitate t contact us.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam5333OpenLawrence A. Beyer, Esq. 674 Lake Road Webster, NY 14580; Lawrence A. Beyer Esq. 674 Lake Road Webster NY 14580; Dear Mr. Beyer: This is in reply to your FAX of February 14, 1994, t Taylor Vinson of this Office, relating to a policy of the Office of Vehicle Safety Compliance (OVSC) regarding importation of vehicles from Canada. Under this policy, and because of the close congruence of the Federal motor vehicle safety standards of both the U.S. and Canada, OVSC has, in essence, waived the requirement for bond and entry through the registered importer process if the Canadian vehicle is accompanied by a letter from the vehicle manufacturer stating that the vehicle was manufactured to comply with the U.S. standards, except for minor labelling variations. You state that this policy has been restricted to personally owned vehicles and does not allow 'importations of vehicles by corporations for their corporation's personal use.' Instead, these vehicles must be entered under bond and conformance verified or achieved by a registered importer. You state that you do not understand the distinction OVSC makes between individual personal use and corporate personal use. Under the Imported Vehicle Safety Compliance Act of 1988, as a general matter, a noncomplying vehicle may enter the United States permanently only if it is imported by a registered importer who brings it into compliance. However, an exception is made by 15 U.S.C. 1397(f)(1)(B) which allows importation by a person other than a registered importer if that person has a conformance contract with a registered importer and if the vehicle is imported 'for personal use, and not for purposes of resale, by any individual (other than an individual described in subsections (g) and (h)). . . .' The term 'individual' refers to a human being and not a corporate person. Therefore, the Act distinguishes both as to whether an importation is for personal use and whether the importer is an individual or a corporation. I hope that this answers your question. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam3896OpenMr. H. Moriyoshi, Executive Vice President and General Manager, Mazda (North America), Inc., 24402 Sinacola Court, Farmington Hills, MI 48016; Mr. H. Moriyoshi Executive Vice President and General Manager Mazda (North America) Inc. 24402 Sinacola Court Farmington Hills MI 48016; Dear Mr. Moriyoshi: This is in reply to your letter of November 21, 1984, asking for a interpretation of Motor Vehicle Safety Standard No. 108 as it would apply to a contemplated parking lamp system.; Usually passenger cars are designed with two parking lamps, one on eac side of the vehicle front. Mazda would have two such lamps on each vehicle side, each of the two lamps flanking the headlamp. You have asked whether, in determining the H-V axis, one takes the axis as the center of each lamp, or should one consider the pair a single device and place the H-V axis at the midpoint between them.; Standard No. 108 requires passenger cars to be equipped with a minimu of two parking lamps, located 'as far apart as practicable.' Therefore, the outermost parking lamp, (the one located between the turn signal lamp and the headlamp is the lamp that must meet the parking lamp requirements of Standard No. 108, and the H-V axis for purposes of compliance would be determined at the center of the lens of that lamp. Supplementary lighting equipment is permissible under Standard No. 108 and does not have to meet the Standard's requirements, but it must not impair the effectiveness of the lighting equipment required by the standard (paragraph S4.1.3). Because of the difference in candela between parking lamps and headlamps, information available to us does not indicate that your supplementary parking lamp would have this effect, and consequently, the design would be permitted.; I hope that this answers your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1361OpenMr. George R. Semark, Planning and Development Center, Sheller-Globe Corporation, Transportation Group, 1200 East Kibby Street, Lima, Ohio 45802; Mr. George R. Semark Planning and Development Center Sheller-Globe Corporation Transportation Group 1200 East Kibby Street Lima Ohio 45802; Dear Mr. Semark: This is in response to your letter of November 21, 1973. Federal Moto Vehicle Safety Standard No. 125 applies only to the manufacturers of warning devices, not manufacturers of vehicles who supply warning devices with their vehicles. Therefore, there are no requirements that you furnish an approved device with your vehicles. What the standard prohibits is the manufacture or sale (separately or on a vehicle) of a *warning device produced on or after January 1, 1974*, that does not conform to the standard.; Yours truly, Richard B. Dyson, Assistant 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.