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Interpretation ID: GF009787

    Mr. Dale Kardos
    Dale Kardos & Associates, Inc.
    3906 Huntington Street, NW
    Washington, DC 20015


    Dear Mr. Kardos:

    This responds to your letter asking whether a "keyless-go" key-locking system being contemplated by your client would meet the requirements of S4.2 of Federal motor vehicle safety standard (FMVSS) No. 114, Theft protection.

    By way of background, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements.  The following represents our opinion based on the facts you provided in your letter.

    Your letter describes a "keyless-go" system that unlocks the door when an electronic key code is transmitted from the key to the vehicle.If the door is opened following transmission of the key code to the vehicle, the steering column is automatically unlocked.For engine activation, an operator must insert the key into the electronic ignition lock. As soon as the key is removed from the electronic ignition lock, the steering column locks, the immobilizer is activated, and the electronic key code is removed from the system.

    You ask if S4.2 of FMVSS No. 114 permits a system that unlocks the steering column when an electronic key code is transmitted from the key to the vehicle, and the driver opens the door.

    S4.2 of FMVSS No. 114 reads as follows:

    Each vehicle shall have a key-locking system which, whenever the key is removed, prevents:

    (a) The normal activation of the vehicle's engine or motor; and

    (b) Either steering or forward self-mobility of the vehicle or both.

    We note that the standard does not specify under what conditions a steering column may become unlocked.However, the system described in your letter appears to operate in the manner consistent with the requirements of S4.2 because removal of the key from the electronic ignition lock prevents activation of the engine and locks the steering.

    NHTSA has issued several letters of interpretation pertaining to keyless systems similar to the one described in your letter (see our 7/17/2002 and 8/15/2002 letters to unnamed parties).You may find these letters useful in ascertaining whether your system complies with other requirements in FMVSS No. 114.

    I hope you find this information helpful.If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    2 Enclosures
    ref:114
    d.2/22/05