USA: Federal Motor Vehicle Safety Standards; Modernization of FMVSS No. 102, 103 and 104 to Accommodate ADS-Equipped Vehicles

 

The National Highway Traffic Safety Administration (NHTSA) is proposing an amendment to Federal Motor Vehicle Safety Standard (FMVSS) No. 102, which governs transmission shift position sequence, starter interlock, and transmission braking effect. The change would exempt vehicles equipped with Automated Driving Systems (ADS)—and lacking manually operated driving controls—from the requirement to display the transmission shift position. Because this display is intended to assist a human driver, it is unnecessary in fully automated vehicles without manual controls. Removing this requirement would reduce regulatory burdens and associated costs without affecting vehicle safety. This proposal is part of NHTSA’s broader effort to update regulations in response to vehicle automation. 

The rulemaking specifically targets ADS-equipped vehicles that do not include manual driving controls. While such vehicles are not yet widely available for consumer purchase, significant investment is underway in their testing, development, and limited deployment by manufacturers and rideshare companies. Automated vehicle technology has the potential to improve road safety and expand mobility, though it is still evolving and many of its benefits are not yet fully realized. As a result, NHTSA is working to eliminate unnecessary regulatory barriers while maintaining safety standards. 

In this context, NHTSA proposes revising FMVSS No. 102 to remove the requirement for a transmission shift position display in vehicles without manual controls. This adjustment would ease compliance burdens without compromising safety. It is one of several rulemaking efforts addressing ADS-equipped vehicles, but this particular proposal is limited to the display requirement in FMVSS No. 102 and does not apply to vehicles that retain manually operated driving controls. 

Regarding Federal Motor Vehicle Safety Standards (FMVSS) No. 103, “Windshield defrosting and defogging systems,” and No. 104, “Windshield wiping and washing systems,” this rulemaking addresses vehicles equipped with Automated Driving Systems (ADS) that lack manually operated driving controls. Although such vehicles are not yet available for consumer purchase, there is substantial investment in their safe testing, development, validation, and limited deployment by manufacturers and rideshare operators. Automated vehicle technology has the potential to reduce crashes and fatalities while improving mobility, but as it continues to evolve, many of its anticipated benefits have yet to be fully realized. Accordingly, NHTSA is working to remove unnecessary barriers to innovation while maintaining motor vehicle safety. 

As part of this effort, NHTSA is proposing amendments to FMVSS No. 103 and No. 104 to exempt vehicles without manually operated driving controls from these requirements. Because these systems are designed to support human drivers, they may be unnecessary in fully automated vehicles, and removing the requirements would reduce regulatory burdens and costs without compromising safety. These proposed changes are part of a broader initiative to modernize NHTSA’s regulations in response to vehicle automation. 

Additionally, this notice proposes updating FMVSS Nos. 103 and 104 to align with current industry standards through revised incorporations by reference. These updates are separate from the proposed exemptions for ADS-equipped vehicles without manual controls. If finalized, the revised standards would apply to passenger cars, multipurpose passenger vehicles, trucks, and buses, while vehicles without manually operated driving controls would remain exempt. 

To find out more about FMVSS and vehicle regulations in USA, do not hesitate to contact the Institute for Global Automotive Regulatory Research directly.