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: aiam2367OpenMr. Thomas S. Pieratt, Executive Director, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Executive Director Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This responds to your July 28, 1976, request for confirmation that boat-carrying trailer which has a primary cargo-carrying surface less than 40 inches from the ground qualifies as a 'Heavy hauler trailer', and that such trailers are not required to meet the requirements of Standard No. 121, *Air Brake Systems*, until September 1, 1977.; 'Heavy hauler trailer' is defined in the standard as follows: >>>'Heavy hauler trailer' means a trailer with one or more of th following characteristics:; (1) Its brake lines are designed to adapt to separation or extension o the vehicle frame, or; (2) Its body consists only of a platform whose primary cargo-carryin surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent 'front-end structure' as that term is used in S 393.106 of this title.<<<; The boat-carrying trailer which you describe as having a bed height o 18 3/4 inches would qualify for exemption until September 1, 1977.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam1682OpenMr. A.J. Burgess,Vice President (Technical),Joseph Lucas North America Inc.,Two Northfield Plaza,Troy, Michigan 48084; Mr. A.J. Burgess Vice President (Technical) Joseph Lucas North America Inc. Two Northfield Plaza Troy Michigan 48084; Dear Mr. Burgess:#This is to confirm your telephone conversation o November 13, 1974, with Mark Schwimmer of this office, concerning your request of October 4 for an interpretation of Federal Motor Vehicle Safety Standard No. 106-74 and its relation to SAE Standard J1403.#You are correct in assuming that all inside diameters listed in Tabled V and VI of Standard No. 106-74 are permitted for both light-wall and heavy-wall vacuum brake hose.#Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 prohibits any State from establishing or continuing in effect a safety standard applicable to an item of motor vehicle equipment performance, where there is an applicable Federal standard covering the same aspect of performance, unless the standards are identical. The NHTSA has determined that FMVSS 106-74 and SAE Standard J1403 are applicable to the same aspect of performance, and that they are not identical. Therefore, the States are prohibited from disapproving the use of brake hose which meets the requirements of Standard no. 106-74 but does not meet SAE Standard J1403.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam0188OpenMr. Heinz C. Hoppe, Executive Vice President, Mercedes-Benz of North America, Inc., 158 Linwood Plaza, Fort Lee, NJ 07024; Mr. Heinz C. Hoppe Executive Vice President Mercedes-Benz of North America Inc. 158 Linwood Plaza Fort Lee NJ 07024; >>>Re: Consumer Information<<< Dear Mr. Hoppe: We have received your submittal of consumer information in response t the requirements of 49 CFR Part 375. That regulation requires that manufacturers submit their information to the Administrator 30 days in advance of the time it is made available to prospective purchasers. Since we have not required that this advance submittal be in the same form as that given to purchasers, the following comments are only advisory in nature. There is one respect, however, in which the information, if supplied in this form to prospective purchasers, would not satisfy the requirements of the regulations.; The Consumer Information section on Vehicle Stopping Distance, 49 CFR 375.101, specifies that the information presented shall contain 'the most adverse combination of maximum or lightly loaded vehicle weight and complete logs of braking in any one of the vehicle brake subsystems.' In your submittal, you have presented information for failures in each of the front and rear subsystems, instead of selecting the most adverse combination of weights and system failures. This is likely to confuse consumers attempting to compare vehicles of different manufacturers, and fails to satisfy the requirement that the information shall be submitted 'in essentially the form illustrated in Figure 1' of S 375.101.; We will be glad to answer any questions that you may have with respec to the requirements of these or other motor vehicle safety regulations and standards.; Sincerely, Robert Brenner, Acting Director |
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ID: aiam0186OpenMr. Heinz C. Hoppe, Executive Vice President, Mercedes-Benz of North America, Inc., 158 Linwood Plaza, Fort Lee, NJ 07024; Mr. Heinz C. Hoppe Executive Vice President Mercedes-Benz of North America Inc. 158 Linwood Plaza Fort Lee NJ 07024; >>>Re: Consumer Information<<< Dear Mr. Hoppe: We have received your submittal of consumer information in response t the requirements of 49 CFR Part 375. That regulation requires that manufacturers submit their information to the Administrator 30 days in advance of the time it is made available to prospective purchasers. Since we have not required that this advance submittal be in the same form as that given to purchasers, the following comments are only advisory in nature. There is one respect, however, in which the information, if supplied in this form to prospective purchasers, would not satisfy the requirements of the regulations.; The Consumer Information section on Vehicle Stopping Distance, 49 CFR 375.101, specifies that the information presented shall contain 'the most adverse combination of maximum or lightly loaded vehicle weight and complete logs of braking in any one of the vehicle brake subsystems.' In your submittal, you have presented information for failures in each of the front and rear subsystems, instead of selecting the most adverse combination of weights and system failures. This is likely to confuse consumers attempting to compare vehicles of different manufacturers, and fails to satisfy the requirement that the information shall be submitted 'in essentially the form illustrated in Figure 1' of S 375.101.; We will be glad to answer any questions that you may have with respec to the requirements of these or other motor vehicle safety regulations and standards.; Sincerely, Robert Brenner, Acting Director |
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ID: aiam2829OpenMr. Carey R. DeMoss, McMullen & Porter, 12700 Park Central Place, Suite 1603, Dallas, TX 75251; Mr. Carey R. DeMoss McMullen & Porter 12700 Park Central Place Suite 1603 Dallas TX 75251; Dear Mr. DeMoss: This is in response to your letter of June 6, 1978, requesting a interpretation of the Federal odometer disclosure requirements. The question you raised was whether the owner of a truck with a gross vehicle weight rating of 64,000 pounds is required under Federal regulations to issue an odometer disclosure statement to the purchaser of the truck. 49 CFR S 580.4, Disclosure of odometer information, requires each transferor of a motor vehicle to furnish to the transferee a written disclosure statement. 49 CFR S 580.5(a)(1), however, exempts a transferor of a vehicle having a gross vehicle weight rating of more than 16,000 pounds from having to fulfill the requirements of S 580.4.; The National Highway Traffic Safety Administration (NHTSA) i promulgating these regulations added this exemption section because buses and large trucks are routinely driven hundreds of thousands of miles, and their maintenance records, not their odometers, have traditionally been relied on by buyers as the principal guide to their condition. It is, therefore, the interpretation of the NHTSA that in the situation you describe in your letter, no disclosure statement was required to be issued under the Federal regulations.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam4727OpenMs Margaret Schmock Dept K2/ELE2 Robert Bosch GmbH Postfach 42 7410 Reutlingen W. Germany; Ms Margaret Schmock Dept K2/ELE2 Robert Bosch GmbH Postfach 42 7410 Reutlingen W. Germany; Dear Ms Schmock: This is in reply to your FAX of March 6, l990, wit respect to the relationship between Federal Motor Vehicle Safety Standard No. 108, and 'CAC Title 13, Article 9'. You have indicated that CAC requires a headlamp adjustment range in the horizontal of at least +/- 4 degrees, whereas Standard No. 108 requires a horizontal adjustment range of not less than 2.5 degrees. You have asked whether Bosch headlamps still must have an adjustment range of +/-4 degrees in the horizontal although Standard No. 108 has been changed. We understand that 'CAC' refers to 'California Administrative Code'. The effect of the preemption provisions of the National Traffic and Motor Vehicle Safety Act is to prohibit California from adopting and enforcing a minimum horizontal headlamp adjustment range greater or less than 2.5 degrees. Thus, a State requirement that a headlamp have a horizontal range of +/- 4 degrees is invalid because it differs from a corresponding Federal requirement. We are unable to answer your further questions with respect to the California code, and suggest that, for further information you write Department of Motor Vehicles, State of California, 2415 First Avenue, Sacramento, California 95818, ATTN: Mr. A. A. Pierce, Director (FAX 916-732-7854). Sincerely, Stephen P. Wood Acting Chief Counsel; |
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ID: aiam3660OpenMr. Gonzalie Rivers, Director, Vehicle Registration Section, Division of Motor Vehicles, 1100 New Bern Avenue, Raleigh, NC 27697; Mr. Gonzalie Rivers Director Vehicle Registration Section Division of Motor Vehicles 1100 New Bern Avenue Raleigh NC 27697; Dear Mr. Rivers: This is in response to your letter of January 24, 1983 requesting tha North Carolina be granted an exemption from the requirements of the Federal Odometer Disclosure law and its accompanying regulation. Your request is denied.; The proposed North Carolina title and transfer document does no conform with the regulation's requirements. If you wish to use the title in lieu of a separate Federal odometer statement, the transferee's (purchaser's) signature must appear on the title and transfer document. The Agency considers this signature to be essential because it is an acknowledgment that the purchaser was aware of the mileage. The purchaser, when he signs the document, is prevented from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. If this signature is added, the North Carolina title will satisfy the Federal odometer disclosure statement requirements.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2590OpenMr. Richard L. Kreutziger, Executive Vice President, Coach & Equipment Sales Corp., Post Office Box 36, Penn Yan, NY 14527; Mr. Richard L. Kreutziger Executive Vice President Coach & Equipment Sales Corp. Post Office Box 36 Penn Yan NY 14527; Dear Mr. Kreutziger: This responds to your May 6, 1977, letter asking what standards appl to vehicles designed to transport fewer than 10 passengers to or from school.; Vehicles that transport fewer than 10 passengers to or from school ar not considered buses according to the National Highway Traffic Safety Administration's (NHTSA) definition of 'bus' found in 49 CFR Part 571.3. Accordingly, these vehicles transporting fewer than 10 passengers would not need to comply standards (sic) applicable to either school buses or buses in general. The vehicles to which you refer would be required to comply with standards applicable to passenger cars or multipurpose passenger vehicles depending upon the type of vehicle being used to transport children. You should consult Part 571.3 (enclosed) of our regulations to determine the classification of the vehicle you intend to construct since the vehicle classification establishes the applicability of the standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5155OpenMr. Greg Hixson President Hixson and Netherton Distributing P.O. Box 28995 Dallas, TX 75228; Mr. Greg Hixson President Hixson and Netherton Distributing P.O. Box 28995 Dallas TX 75228; "Dear Mr. Hixson: This responds to your March 30, 1993, letter askin for information on any regulations concerning aftermarket airbags. I am enclosing two letters dated March 26, 1993, to Mr. Steven C. Friedman and Mr. Jay Lee that explain the operation of Federal law with respect to aftermarket airbags. I am also enclosing a copy of the information sheet referred to in both letters. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures "; |
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ID: aiam1317OpenGreg Beck, 1715 Swarr Run Rd., Lancaster, PA 17601; Greg Beck 1715 Swarr Run Rd. Lancaster PA 17601; Dear Mr. Beck: Your letter of October 18, 1973, asks what violations of the Federa odometer laws may have occurred in your purchase of a 1962 Tempest which was misrepresented as a 1964 model.; Misrepresentation of the model year, which appears to be your principa grievance, is not a violation of Federal law but could be a violation of local laws against fraudulent merchandising.; Bill Tillett's failure to give you a disclosure statement may be violation of the Federal odometer disclosure regulation, a copy of which is enclosed. After March 1, 1973, the regulation requires each seller to make a signed, written disclosure of a vehicle's recorded mileage to his purchaser. If he knows the odometer reading is inaccurate, he must also state that the actual mileage is unknown. This statement must be made before the vehicle is sold.; If your seller violated these regulations with fraudulent intent, civil remedy is available to you under S 409 of the Act for $1,500 or treble damages, whichever is greater. To obtain your remedy, S 409 provides that you may bring a private civil action in State or Federal court. You may wish to consult an attorney about the possibility of bringing an action in your case.; Sincerely, Lawrence R. Schneider, 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.