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NHTSA Proposes New Pedestrian Head-Protection Standard for Cars, SUVs and Pickups

NHTSA’s proposed pedestrian head-protection standard would test vehicle hoods at conditions modeling 25 mph impacts. It remains a proposed rule, not a requirement in force.
Entry658 Date Time3 min MechanicCarCody Team

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NHTSA has proposed a federal vehicle standard intended to reduce the risk of serious or fatal head injuries when a pedestrian’s head hits a vehicle’s hood or nearby front-end area. It is not in force: the latest located federal agenda, for 2026, still lists the action as a proposed rule and says more technical work is needed before it can be finalized.

What the proposed pedestrian head-protection rule would require

NHTSA’s September 2024 notice of proposed rulemaking would create Federal Motor Vehicle Safety Standard No. 228, “Pedestrian head protection.” It is based on Global Technical Regulation No. 9, with U.S.-specific adjustments. The proposal would test how well a vehicle manages the impact energy when a pedestrian’s head strikes the hood or adjacent front-end area; it does not simply require a softer hood. NHTSA’s proposed rule describes the test and requirements.

Vehicles covered

The proposed standard would cover passenger cars, light trucks such as pickups, multipurpose passenger vehicles such as SUVs, crossovers and vans, and buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less.

How the proposed tests work

Testing would use two instrumented headforms launched at designated areas of the hood and adjacent front-end surface:

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Proposed HIC limits

The proposal sets different limits for different portions of the test area: HIC must be below 1,000 in specified areas and no greater than 1,700 in the remaining test areas. A vehicle’s hood must have enough space above hard structures beneath it to manage impact energy. NHTSA also discusses possible extensions to grille areas on some large vehicles; that is a design issue in the proposal, not a finalized requirement.

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Has the rule taken effect?

No final rule is identified in the latest located status. The 2026 Unified Agenda lists the action, RIN 2127-AK98, at “Proposed Rule Stage.” It scheduled “Analyzing Comments” for September 2026 and says NHTSA needs further analysis of technical issues involving the test procedure and devices before it can finalize a GTR-based pedestrian standard. A scheduled milestone is not confirmation that the work was completed or that no later action occurred. The 2026 Unified Agenda entry is the latest located procedural status.

NHTSA initially set November 18, 2024, as the deadline for comments on the proposal, then extended the comment period by 30 days after receiving a request. That comment-period extension did not make the proposal a final rule. The Federal Register notice records the extension.

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When would manufacturers have to comply?

The proposal’s compliance date would be the first September 1 that falls two years after publication of a final rule. Final-stage manufacturers and alterers would receive an additional year, and manufacturers could comply earlier if they chose. Because a final rule has not been identified in the latest located status, there is no supported calendar compliance date.

Why NHTSA says pedestrian head protection matters

In its September 2024 announcement, NHTSA reported that U.S. pedestrian deaths rose 57% between 2013 and 2022, from 4,779 to 7,522. It said 88% of pedestrian fatalities in 2022 occurred in single-vehicle crashes; among pedestrians struck by a vehicle’s front, fatalities were most common in multipurpose passenger vehicles (49%) and passenger cars (37%). NHTSA’s announcement provides those figures.

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NHTSA estimated that the proposed standard could prevent approximately 67.4 fatalities a year. That is an agency estimate, not a measured outcome. The detailed proposal also estimated per-vehicle costs of $2.86–$3.50 for passenger cars and $3.29–$4.08 for light trucks, with annual total costs of $48.94–$60.43 million depending on the discount rate. These are estimates in the proposal, not observed consumer prices or costs for every vehicle.

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How this proposal fits with other pedestrian-safety measures

The proposed standard addresses head injuries when a pedestrian’s head contacts the hood or nearby front end. It complements, rather than replaces, pedestrian automatic emergency braking: as NHTSA explains in its proposal, braking systems can prevent some impacts or reduce impact speed, while head-protection design is intended to address some impacts that still happen.

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