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NHTSA's Interpretation Files Search
NHTSA's Chief Counsel interprets the statutes that the agency administers and the regulations that it promulgates. When members of the public ask the agency a question about motor vehicles or motor vehicle equipment that involves these statutes and regulations, the Chief Counsel responds with a letter of interpretation that looks at the particular facts presented in the question and explains how the law applies given those facts. These letters of interpretation, signed by the Chief Counsel, represent the opinion of the agency on the questions addressed at the time of signature and may be helpful in determining how the agency might answer a question that you have if that question is similar to a previously-considered question. Please remember, however, that interpretation letters represent the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. Do not assume that a prior interpretation will necessarily apply to your situation! There are a number of reasons why the interpretation letters in this database might not be applicable to your situation. For more information, see the item below, "How do I use letters of interpretation?"

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Results: 16473
[1] Mr. Christopher C. Mansfield
Dear Mr. Mansfield:   We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy.  Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures.  These letters do not accuse your company, or any other company, of violating the law.       We understand that when a flood-damaged vehicle is declared a ... Dec 20, 2012

[2] Mr.Garrett Paddor
Dear Mr. Paddor:   We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy.  Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures.  These letters do not accuse your company, or any other company, of violating the law.       We understand that when a flood-damaged vehicle is declared a ... Dec 20, 2012

[3] Mr. Dana Proulx
Dear Mr. Proulx:   We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy.  Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures.  These letters do not accuse your company, or any other company, of violating the law.        We understand that when a flood-damaged vehicle is declared ... Dec 20, 2012

[4] Mr. Steven A. Bennett
Dear Mr. Bennett:   We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy.  Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures.  These letters do not accuse your company, or any other company, of violating the law.       We understand that when a flood-damaged vehicle is declared a ... Dec 20, 2012

[5] Ms.Patricia R. Hatler
Dear Ms. Hatler:   We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy.  Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures.  These letters do not accuse your company, or any other company, of violating the law.       We understand that when a flood-damaged vehicle is declared a ... Dec 20, 2012

[6] Mr. Jeffrey W. Jackson
Dear Mr. Jackson:   We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy.  Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures.  These letters do not accuse your company, or any other company, of violating the law.       We understand that when a flood-damaged vehicle is declared a ... Dec 20, 2012

[7] Mr.Charles E. Jarrett
Dear Mr. Jarrett:   We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy.  Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures.  These letters do not accuse your company, or any other company, of violating the law.       We understand that when a flood-damaged vehicle is declared a ... Dec 20, 2012

[8] Ms.Susan L. Lees
Dear Ms. Lees:   We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy.  Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures.  These letters do not accuse your company, or any other company, of violating the law.       We understand that when a flood-damaged vehicle is declared a ... Dec 20, 2012

[9] ITA_Defective_Tire_Exportation_12-00245
Dear Ms. Wilson:               This letter responds to your January 19, 2012 letter on behalf of ITR USA, Inc. requesting an interpretation of certain provisions of the Transportation Recall Enhancement, Accountability, and Documentation Act, Pub. L. No. 106-414, 114 Stat. 1800 et. seq. (2000) (TREAD Act).  You ask for clarification regarding two requirements under the TREAD Act:  the requirement in Section 7 that directs tire manufacturers, which includes importers, conducting recalls to include in their remedy program plans addressing how to prevent replaced tires from being resold for installation on a motor vehicle and the prohibition in Section 8 ... Oct 3, 2012

[10] 11-007173_R_Kesler_(Std 111)_Rearview_Mirrors
Dear Mr. Kesler:   This responds to two letters the agency has received from you dated September 7, 2011 and May 10, 2012, concerning your product: the Lane Change Safe Alert Indicator.  In both of your letters, you describe your product in detail and various situations where you believe the product would be helpful to a driver conducting a lane change maneuver.  As you describe in those letters, your Lane Change Safe Alert Indicator product utilizes modified OEM convex mirrors that have the alert indicators permanently inscribed on the mirror for both driver and passenger sides.  Further, the mirror contains ... Sep 25, 2012

[11] 12-001952 Matheny capacity includes driver (Standard No. 217)
Dear Mr. Fowler:               This responds to your letter to the National Highway Traffic Safety Administration (NHTSA) asking about Federal Motor Vehicle Safety Standard (FMVSS) No. 217, ?Bus Emergency Exits and Window Retention and Release.?  We apologize for the delay in responding; we regret that we did not receive the January 19, 2012 letter you had sent.               You ask for clarification of the term ?seating capacity? as used in Table 1 and Table 2 of FMVSS No. 217, i.e., whether the driver is considered part of the ?seating capacity? of a bus for purposes of determining the ... Aug 14, 2012

[12] 12-003091 Giordano (Std. No 120)
Dear Mr. Giordano:   This letter responds to your request for clarification regarding the relationship between the certification label and the tire selection requirements for school buses with a gross vehicle weight rating (GVWR) of more than 10,000 pounds under Federal Motor Vehicle Safety Standard (FMVSS) No. 120, which relates to tire selection and rims.  We are pleased to provide the following clarification.   We begin by clarifying NHTSA?s regulatory authority.  NHTSA has the authority under 49 U.S.C. Chapter 301 to prescribe Federal motor vehicle safety standards (FMVSSs).  The FMVSSs are applicable to new motor vehicles and new motor vehicle ... Aug 10, 2012

[13] 11-000612 M.Edie (Part 523)
Dear Mr. Edie: This is a response to your letter on January 21, 2011, in which you requested an interpretation of 49 CFR 523.2 and 523.5(b)(2) as they would apply to the classification of a motor vehicle with components affixed to its undercarriage.  The specific components described in your letter are tire aero deflectors, which are attached in front of the tires in order to reduce aerodynamic drag and thereby improve fuel economy.  Your letter states that in order to perform as needed, some of the components may be between 20 and 15 centimeters from their lowest point to the ... Jul 30, 2012

[14] DNBA_B.Nicolle_Parts_573_and_579
Dear Mr. Nicolle,   Thank you for your email of June 1, 2012 requesting a written notification of the legal obligations of Daimler Buses North America (DBNA) in light of the planned changes at DBNA.   You state that DBNA has decided to cease manufacturing and outfitting buses in North America, and explain that this will affect Orion, Sprinter, and Setra buses and motorcoaches.  You also state that DBNA will maintain a presence to handle service, warranty, and replacement parts issues for Orion buses, and that Setra will be ?transferred? to MCI Corporation for sales marketing, service and warranty issues.  ... Jul 19, 2012

[15] 11-005927 K.Ro (Std. No. 135)
Dear Mr. Ro:   This letter responds to your request for interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 135, Light Vehicle Brake Systems, on behalf of Toyota Motor Corporation (Toyota).  You state that Toyota is currently developing an electric vehicle (EV) that falls within the applicability of FMVSS No. 135.  You would like confirmation of your interpretation that the phrase ?accelerate as rapidly as possible? found within the test procedure of the standard takes account of a thermal protection feature in an EV battery system.  The issue raised by your letter is addressed below.   Among the performance ... Jul 5, 2012

[16] 10-000710 A.Killian,Jr. (Standard No. 205)
Dear Mr. Killian:   This responds to your letter requesting an exemption for your invention, a laminated area ?embedded? into the front driver side and passenger side windows to reduce headlight glare from the outside rearview mirrors.   By way of background, NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (49 U.S.C. Chapter 301, ?Safety Act?) to issue Federal motor vehicle safety standards (FMVSSs) that set performance requirements for new motor vehicles and new items of motor vehicle equipment.  NHTSA does not provide approvals of motor vehicles or motor vehicle equipment.  Instead, manufacturers are required to ... Jun 22, 2012

[17] 10-001392 K.Harris (Stds. 108 and 218)
Dear Mr. Harris:   This responds to your February 12, 2010 letter asking whether producing motorcycle helmets with built-in rear lighting in colors other than red (e.g., green, blue) violates DOT policy.  The issues raised by your letter are addressed below.   By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act (49 U.S.C. Chapter 301, ?Safety Act?) to issue Federal motor vehicle safety standards (FMVSSs) that set performance requirements for new motor vehicles and new items of motor vehicle equipment.  NHTSA does not provide approvals of motor ... Jun 22, 2012

[18] 11-000700 J.Hoffrichter (Std No. 207)
Dear Mr. Hofrichter:   This responds to your January 11, 2011 letter concerning whether a new seating application for trucks meets the requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 207, which governs vehicle seating systems.  Specifically, you ask several questions about vertical movement of a seating system during testing and whether such movement would mean that the seat was not compliant with the requirements of S4.2.1 of FMVSS No. 207.  As explained below, we believe that the movement you describe may constitute a test failure under FMVSS No. 207.   By way of background, NHTSA is authorized by ... Jun 22, 2012

[19] K.Dziczek Part 583
Dear Ms. Dziczek,   This letter is in response to your April 10, 2012 email to Thomas Healy of this office.  In your email you ask several questions about the requirements of 49 C.F.R. Part 583, Automobile Parts Content Labeling.  The responses to your questions are provided below.   By way of background, pursuant to the American Automobile Labeling Act, Part 583 requires passenger motor vehicles to be labeled with five items of information related to the countries of origin of those vehicles.  The items of required information are:               On a carline basis:                           U.S./Canadian parts content ... May 31, 2012

[20] 09-008024ws Yuen.htm
Dear Mr. Yuen:   This responds to your letter, dated October 9, 2009, asking whether the motorcycle rear lamp system you describe is permissible under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, which governs lamps, reflective devices, and associated equipment on vehicles.  I sincerely apologize for the delay in this response.  As explained below, we believe that the system would be permissible under FMVSS No. 108.   By way of background, NHTSA is authorized by the Safety Act to issue FMVSSs that set performance requirements for new motor vehicles and new items of motor vehicle equipment.  NHTSA does not ... Jul 26, 2011

[21] Mac Yousry
Dear Mr. Nelson:   This letter responds to your letter asking whether a product commonly known in the logging industry as a ?slasher saw table? would be considered a ?motor vehicle? within the laws and regulations administered by the National Highway Traffic Safety Administration (NHTSA).  As explained below, our answer is no.   You explain that a slasher saw table is a large saw permanently mounted to a bundling carriage that has two wheels and is pulled behind another trailer or truck.  It is used for cutting logs to a uniform length for loading onto a logging truck.  Although a ... Jul 25, 2011

[22] 0-004142 -- Toyota CAFE credit transfer banking -- 5 Jul 11 final for signature.htm
Dear Mr. Stricker:   This responds to your letter dated June 10, 2010 concerning the definition of the term ?transfer,? as used in relation to Corporate Average Fuel Economy (CAFE) credits.  You asked several questions relating to the revision to the definition of ?transfer? in the April 2010 final rule establishing CAFE standards for model years 2012-2016.    By way of background, ?credits? are earned by automobile manufacturers for over-compliance with passenger car and light truck CAFE standards, and may be used by the manufacturer to make up shortfalls in different model years and different compliance categories, subject to certain ... Jul 6, 2011

[23] Mr. Richard Hardesty
Dear Mr. Hardesty:   This responds to your letter to the National Highway Traffic Safety Administration (NHTSA) expressing concern about the Sargent Volunteer Fire Department?s transporting ?minor children in cargo areas in vehicles? during what appears to be an annual Fire Prevention Week event.  You enclose copies of newspaper photographs of preschool and elementary school students riding on a firetruck.  The captions on the photographs indicate that the children were given rides on the vehicles as part of a Fire Prevention Week parade or other community outreach event.   You are concerned that the firetrucks are not equipped to provide ... May 26, 2010

[24] Ms
Dear Mr. Siegel:   This responds to your letter asking about the applicability of Federal Motor Vehicle Safety Standard (FMVSS) No. 302, ?Flammability of Interior Materials,? to a refrigerator mounted in a cabinet in the sleeper of a Class 8 truck (a truck with a gross vehicle weight rating (GVWR) greater than 14,969 kilograms (33,000 pounds)).  You ask whether the standard would have to be met by just the front of the refrigerator door, and not the other exterior surfaces of the refrigerator.  As explained below, our answer is yes.   Background   By way of background, the National Highway ... Feb 25, 2010

[25] Carl Wacker
Dear Mr. Wacker:   This responds to your letter requesting an interpretation clarifying specific issues with respect to Federal Motor Vehicle Safety Standard (FMVSS) No. 138, Tire Pressure Monitoring Systems.  Specifically, you asked whether a tire pressure monitoring system (TPMS) must warn drivers of low tire pressure in particular circumstances, such as up to the maximum speed of the vehicle, and under all road surfaces and road conditions (including ice, snow, rain, gravel, dirt, and so forth).  You also asked whether a TPMS must comply with FMVSS No. 138 if a vehicle dealer changes the tire and wheel combination prior ... Nov 13, 2009