NHTSA Defect Petition: Emergency Egress Controls Are Not Readily Accessible and… (DP25-002)
Opened December 23, 2025 · Tesla, Inc.
NHTSA opened a defect petition review (DP25-002) on December 23, 2025 into emergency egress controls are not readily accessible and clearly identifiable in 2022 Tesla Model 3. The investigation is closed on July 22, 2026.
DP25-002 at a glance
| NHTSA action number | DP25-002 |
|---|---|
| Type | Defect Petition |
| Opened | December 23, 2025 |
| Status | Closed July 22, 2026 |
| Vehicles | 2022 Tesla Model 3 |
| Component | Structure > Body > Door > Handle > Interior |
| Manufacturer | Tesla, Inc. |
| Resulting recall | None listed |
What is NHTSA investigating in the Tesla Model 3?
From NHTSA’s investigation summary:
The Office of Defects Investigation (ODI) has completed its review of a defect petition received on November 24, 2025, requesting an investigation into the emergency mechanical door release in 2022 Model Year (MY) Tesla Model 3.
The petition alleges that the controls for the emergency mechanical door release are not accessible and clearly identifiable and thus fail to comply with Federal Motor Vehicle Safety Standard (FMVSS) 206.
A vehicle equipped with electric door handles without an accessible mechanical door release creates a risk to safety when the electric door handle becomes inoperative due to loss of power and occupants are unable to easily locate the mechanical door release to exit the vehicle in case of an emergency.
A concealed or hard to locate emergency door release could prevent an operator or occupant from exiting the vehicle in the event of an emergency, such as a crash or fire.
The potential risk for entrapment can result in a severe injury or death of the operator and other occupants of the vehicle.
As of March 13, 2026, out of the population of 179,031 subject vehicles, NHTSA has identified one (1) consumer complaint, in NHTSA's databases alleging that the mechanical door release is concealed and unlabeled, resulting in a risk of entrapment in the event of an emergency, as cited in the Petition.
The complaint is for the same Vehicle Identification Number (VIN) as the subject vehicle of the Petition.
The allegation describes a front impact collision, where the vehicle lost electrical power, and the electric door mechanism stopped working.
The 2022 MY Model 3 has a mechanical release for the front doors, located in front of the window switch on the door's interior and consists of a lever that can be pulled up to open the door.
The subject vehicle does not have a mechanical release for the back doors.
The owner's manual for the 2022 MY Tesla Model 3 includes a section labeled "In Case of Emergency" that details how to open doors from the interior when the vehicle has no electrical power.
The owner's manual refers to the mechanical release as a "manual door release." The owner's manual instructs the operator to "pull up the manual door release located in front of the window switches." The owner's manual includes an illustration showing the mechanical door release lever and its location on the door.
The illustration depicts an image of the door with the window switch and lever, including a blue arrow pointing to the location of the lever to demonstrate the upward movement required to operate the lever.
The lever shown in the illustration does not contain a label to identify it.
Although they vary in design and location, mechanical releases for the front doors are available on all Tesla models.
The location and operation of the mechanical release is described in the owner's manual for each Tesla model.
Further, the owner's manual cautions the operator that the mechanical door release should only be used when the subject vehicle has no power or if otherwise necessary.
If the subject vehicle has power, the button located at the top of the interior door handle should be used to open the doors.
The Petition also stated the lack of an accessible mechanical emergency door release is a violation of the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 206 (49 CFR § 571.206).
FMVSS 206 specifies performance requirements for vehicle door locks, latches, hinges, and attachment components to prevent passenger ejection during crashes.
It applies to passenger cars, trucks, and buses with a GVWR of 4,536 kg (10,000 lbs.) or less, focusing on maintaining latch engagement under inertial loads and structural integrity.
No requirements exist in the standard that address the Petitioner's concern regarding the labeling and location of an emergency mechanical door release in passenger cars.
On November 4, 2025, NHTSA's Office of Rulemaking received a petition to initiate the issuance of a new Federal Motor Vehicle Safety Standard (FMVSS) to mandate a robust and obvious door egress system in all motor vehicles.
The request has been granted, and the Agency will accordingly commence a rulemaking proceeding.
See 49 CFR § 552.9.
A decision as to the issuance of a rule will be made on the basis of all available information developed in the course of the rulemaking proceeding, in accordance with statutory criteria.
Id.
The Agency has thoroughly assessed the material submitted by the Petitioner, consumer complaint information in NHTSA's databases, and other relevant information already in possession of the Agency.
NHTSA does not believe that the issues presented by the Petitioner indicate the likelihood of a safety related defect that would warrant a defect investigation, and the issue is best addressed through the rulemaking process.
After full consideration of the available information and the commencement of the related rulemaking proceeding, the Petition is denied.
Further specifics can be found in the Federal Register Notice.
The ODI report cited above can be viewed at NHTSA.gov under ODI Number 11701894 and the Defect Petition can be viewed under ODI Number 11698174.
What is a defect petition review?
Defect Petition is a review of a petition, usually filed by an owner, asking NHTSA to open a defect investigation. NHTSA decides whether to grant or deny it.
Did this investigation lead to a recall?
NHTSA closed this investigation on July 22, 2026 without listing a recall. That can mean NHTSA did not find a safety defect it could prove, or that the manufacturer addressed the issue another way. A closed investigation does not mean owners have no lemon law claim if the problem keeps happening.
Which vehicles are part of this investigation?
| Model years | Make | Model |
|---|---|---|
| 2022 | Tesla | Model 3 |
What are Tesla Model 3 owners reporting to NHTSA?
NHTSA’s public database lists 765 owner complaints filed since 2020 for the vehicles in this investigation (all components). Complaints are unverified owner reports.
What should owners do?
- Check your VIN at nhtsa.gov/recalls for any open recall on your vehicle.
- If you have the problem NHTSA is investigating, take the vehicle to a dealer now and get a repair order, even if the dealer cannot find anything.
- Keep a log of every time the problem happens: date, mileage and what happened. Photos and videos help.
- File your own complaint at nhtsa.gov/report-a-safety-problem. Owner complaints are what start and expand investigations.
- If the problem keeps coming back, talk to a lemon law attorney.
Recalls on the same vehicles
- 2021-2023 Tesla Model 3 Headlight Recall (26V507)
- 2026 Tesla Model Y Knee Bolster Recall (26V445)
- 2021-2023 Tesla Model 3 Backup Camera Software Recall (26V283)
- 2025 Tesla Model 3 Fuses Recall (25V690)
- 2026 Tesla Model 3 Seat Fastener Recall (25V410)
- 2023 Tesla Model 3 Steering Power Steering Recall (25V092)
- 2024-2025 Tesla Model 3 Backup Camera Software Recall (25V002)
- 2024 Tesla Cybertruck Tire Pressure Monitor Recall (24V935)
- 2021-2024 Tesla Model 3 Electrical Software Recall (24V554)
- 2021-2024 Tesla Model S Warning Light and Devices Recall (24V376)
Can a recall or defect investigation make my car a lemon in California?
Not by itself. What matters is whether a covered defect keeps coming back or keeps your vehicle at the dealer, and a federal investigation or recall is strong evidence that the problem is real.
Under California’s Song-Beverly Consumer Warranty Act, a manufacturer that cannot fix a warranty defect that substantially impairs a vehicle’s use, value or safety within a reasonable number of attempts may have to repurchase or replace it (Civ. Code 1793.2(d)). Within the first 18 months or 18,000 miles, the law presumes a reasonable number of attempts after two repairs of a defect likely to cause death or serious injury, four repairs of the same defect, or more than 30 days out of service (Civ. Code 1793.22(b)).
An owner who prevails can recover reasonable attorney fees and costs from the manufacturer (Civ. Code 1794(d)). You pay nothing, win or lose. We are paid only if you win, and the manufacturer pays our fees, including in settlements. If a case is lost, our firm covers the costs.
In our cases, a recall repair visit counts as a repair attempt, and it's strongest when the owner complained about the problem before the recall came out. A recall shows the defect is real and that enough owners reported it for the manufacturer to issue a fix.
The biggest mistake I see is waiting too long. The mileage offset starts at your first repair visit for the problem, so the sooner you take it in, the better. If the problem comes and goes, take it in when it happens. You can't go back to that date later.
If you get a recall notice, call a lemon law attorney right away. You may have taken the car in for the same problem before and forgotten, or there may be other recalls related to it.
Jacob Shayesteh, Esq. (SBN 362320), Founder and Managing Attorney. Quotes lightly edited for clarity. Prior results do not guarantee a similar outcome.
Frequently asked questions
Does the recall fixing my car mean I have no case?
Not necessarily. Even if the recall repair fixed it, you may still have a case, and a car that's a year or more old can still qualify.
Do used cars qualify for California lemon law?
We take certified pre-owned, demo and dealer vehicles. Since the California Supreme Court's Rodriguez decision in 2024, ordinary used cars generally do not qualify.
How long does a recall lemon law case take?
Recall-related cases typically resolve in one to three months from your first call. Prior results do not guarantee a similar outcome.
What does a lemon law attorney cost?
You pay nothing, win or lose. We are paid only if you win, and the manufacturer pays our fees, including in settlements. If a case is lost, our firm covers the costs.
Sources
- NHTSA investigation, recall and complaint data, accessed October 7, 2026
- California Civil Code 1793.22
Jacob Shayesteh, Esq., Founder and Managing Attorney of America’s Lemon Lawyer (Wynn Law Group, APC). Licensed by the State Bar of California, No. 362320. His practice focuses on California lemon law under the Song-Beverly Consumer Warranty Act.
State Bar of California license record · Avvo · Martindale-Hubbell · Lawyers.com · LinkedIn · Our attorneys
Attorney advertising. America’s Lemon Lawyer is a trade name of Wynn Law Group, APC. Responsible attorney: Jacob Shayesteh, Esq. (SBN 362320). This page reports public NHTSA data and is general information, not legal advice. Not affiliated with NHTSA or any vehicle manufacturer. Prior results do not guarantee a similar outcome.