SUPPLEMENTARY INFORMATION:

I. Overview: Ford determined that certain MY 2022-2025 Ford Transit do not fully comply with paragraph S5.2.1 of FMVSS No. 101, Controls and Displays (49 CFR 571.101).

Ford filed a noncompliance report dated July 25, 2025, pursuant to 49 CFR part 573, Defect and Noncompliance Responsibility and Reports. Ford petitioned NHTSA on August 13, 2025, for an exemption from the notification and remedy requirements of 49 U.S.C. Chapter 301 on the basis that this noncompliance is inconsequential as it relates to motor vehicle safety, pursuant to 49 U.S.C. 30118(d) and 30120(h) and 49 CFR part 556, Exemption for Inconsequential Defect or Noncompliance.

This notice of receipt of Ford's petition is published under 49 U.S.C. 30118 and 30120 and does not represent any agency decision or another exercise of judgment concerning the merits of the petition.

II. Vehicles Involved: Approximately 19,341 MY 2022—2025 Ford Transit motor vehicles, manufactured between June 4, 2021, and June 25, 2025, were reported by the manufacturer.

III. FMVSS Requirements: Paragraph S5.2.1. of FMVSS No. 101 includes the requirements relevant to this petition. Paragraph S5.2.1 specifies that any control, telltale or indicator that is listed in column 1 of table 1 or table 2 in FMVSS No. 101 must be indicated in the vehicle by the corresponding symbol, word, or abbreviation in columns 2 or 3 in the same tables.

IV. Noncompliance: Ford explains that the subject Ford Transit vehicles were incorrectly labeled on the engine “Push To Start” (PTS) button, which fails to comply with FMVSS No. 101. The Ford Transit vehicles with an internal combustion engine (ICE) manufactured in the Kansas City Assembly Plant between June of 2021 and July of 2025 have a PTS button that is labeled “Power Start Stop” rather than “Engine Start Stop” which is required by FMVSS No. 101.

V. Summary of Ford's Petition: The following views and arguments presented in this section, “V. Summary of Ford's Petition,” are the views and arguments provided by Ford. They have not been evaluated by the Agency and do not reflect the views of the Agency. Ford describes the subject noncompliance and contends that the noncompliance is inconsequential as it relates to motor vehicle safety.

Ford states that an internal investigation and review determined that the subject Ford Transit vehicles built in the Kansas City Assembly Plant between June 4, 2021, and June 25, 2025, failed to comply with the controls identification requirements in paragraph S5.2.1 of FMVSS No. 101. Ford states that it was discovered that the ICE Transit vehicles had been equipped with the PTS button intended for installation in the Battery Electric and Hybrid Electric variants of the Transit model vehicles. Ford maintains two design variations of the Push to Start Button, one intended for ICE vehicles, which is labeled as “Engine Start Stop” and one intended for Battery Electric Vehicles (BEVs) and Hybrid Electric Vehicles (HEVs), which is labeled as “Power Start Stop”. Ford claims that both versions of the PTS button perform the same function of turning the vehicle on and off, and are located near the steering column as required by FMVSS No. 101, and are familiar enough for drivers to understand the purpose of the control.

According to tables 1 and 2 of FMVSS No 101, the PTS button on the subject vehicles' labels must contain the words “Engine Start” and “Engine Stop” when the engine control is “separate from the key locking system.” Ford cites paragraph S2 of FMVSS No. 101 in saying that the purpose of FMVSS No. 101 is to “ensure the accessibility, visibility, and recognition of controls under daylight and nighttime conditions, in order to reduce the safety hazards caused by the diversion of the driver's attention from the driving task, and mistakes in selecting the controls.”

Ford provides four reasons why this noncompliance is inconsequential to motor vehicle safety:

1. The mislabeled PTS button still reliably functions as designed and is indicated in the owner's manual, and Ford has corrected the error that led to mislabeling the affected production vehicles. Ford states that the issue is solely a labeling matter and does not affect functionality, as the driver is still able to consistently start and stop the vehicle's engine and be alerted to the function of the button through the noise of the engine's operation. Additionally, Ford adds that they have addressed the labeling concern in production and that all Ford Transit vehicles built after June 25, 2025, will bear the compliant “Engine Start Stop” label on the PTS button.

2. The language and symbol used on the mislabeled PTS buttons are widely used and understood, and will therefore not cause confusion about the button's function to the driver of the vehicle. Ford states that the noncompliant “Power Start Stop” still clearly uses the language “Start Stop”, thus clearly indicating the purpose of the control. Ford indicates that the Owner's Manual also provides a visual depiction of the button (with the label “Engine Start Stop”) and its location, as well as a description of the function of the button. Ford states that a vehicle operator would see that the mislabeled PTS button is in the same location, has the same shape, and has the same illumination as the PTS button described in the Owner's Manual and would easily be able to infer the function of the button.

Additionally, Ford stated that the term “Power” which is included within the noncompliant PTS button is commonly associated with the primary on/off function across a vast array of electronic devices and vehicle systems. The words “Power Start Stop,” particularly when displayed on a primary vehicle control, are understood by drivers to signify the action of turning the vehicle's operational power on and off. Ford further explained the “O” in “Power” for the incorrect labels has been replaced with the commonly used ISO Power On/Off symbol, regulated under ISO 2575:2010(E). Ford believes the integration of the ISO Power On/Off symbol further reinforces the control's function. The term “Power” is internationally recognized for power controls, which should enhance driver comprehension. Ford then cites a 2003 interpretation ^[1] by NHTSA that allowed Toyota to use the term “Power” and the ISO Power Symbol to identify the PTS button on their Hybrid Electric Vehicles.

3. Ford states that it is not aware of any reports of crashes, injuries, fatalities, or even complaints about this issue. Ford recognizes that this does not negate the possibility of risk to operators and passengers, but believes that it is an indication that customers are not confused by the discrepancy in labeling.

4. Ford provides examples where NHTSA has granted similar petitions for inconsequential noncompliance in the past and cites examples: ( printed page 37227)

• NHTSA granted a petition by Mack Trucks Inc. for noncompliant control identification because the control met all other FMVSS No. 101 requirements and the control's “labeling and position would be enough to avoid inducing confusion in the driver.”.^[2]

• NHTSA granted a petition to Kawasaki Motors Corp. for motorcycles with an ignition off control that was noncompliant with the identification requirements specified in FMVSS No. 123,Motorcycle Controls and Displays.^[3] Ford states that NHTSA granted the petition because “the switch's clear design reduced the likelihood for confusion or error” and the engine kill switch safety feature reduced any safety risks that might be caused by non-standard compliant labeling.

Ford concludes by stating its belief that the subject noncompliance is inconsequential as it relates to motor vehicle safety and its petition to be exempted from providing notification of the noncompliance, as required by 49 U.S.C. 30118, and a remedy for the noncompliance, as required by 49 U.S.C. 30120, should be granted.

NHTSA notes that the statutory provisions (49 U.S.C. 30118(d) and 30120(h)) that permit manufacturers to file petitions for a determination of inconsequentiality allow NHTSA to exempt manufacturers only from the duties found in sections 30118 and 30120, respectively, to notify owners, purchasers, and dealers of a defect or noncompliance and to remedy the defect or noncompliance. Therefore, any decision on this petition only applies to the subject vehicles that Ford no longer controlled at the time it determined that the noncompliance existed. However, any decision on this petition does not relieve vehicle distributors and dealers of the prohibitions on the sale, offer for sale, or introduction or delivery for introduction into interstate commerce of the noncompliant vehicles under their control after Ford notified them that the subject noncompliance existed.

(Authority: 49 U.S.C. 30118, 30120; delegations of authority at 49 CFR 1.95 and 501.8)

91 FR 37225