Zoox Needs One Regulatory Yes Before It Can Start Charging Riders
Five days before NHTSA's comment period closes on Zoox's exemption petition, the Amazon-owned robotaxi company is sitting on nearly two million miles of autonomous driving data, 350,000 free rides, a growing list of cities, and a Uber partnership designed to put its steering-wheel-free vehicles on a ride-hail network this summer. What it still does not have is permission to charge.
That is what the FMVSS exemption request is actually about.
On March 11, NHTSA published a request for public comment on Zoox's petition to be exempted from eight Federal Motor Vehicle Safety Standards. The standards in question were written for vehicles with human drivers. FMVSS 103 covers windshield defrosting and defogging. FMVSS 104 covers windshield wipers and washers. FMVSS 108 covers lamps and reflective devices. FMVSS 111 covers rear visibility. FMVSS 135 covers brake systems designed around human reaction time. FMVSS 201 covers interior impact protection for occupants. FMVSS 205 covers glazing materials. FMVSS 208 covers occupant crash protection in frontal collisions. None of these requirements make sense for a vehicle that has no steering wheel, no pedals, and no sun visors, because none of those things are for the passenger. They are for the driver. Zoox's robotaxi does not have one.
The company is asking for a two-year exemption covering up to 2,500 vehicles per year. If granted, it would be the first commercial-scale exemption of its kind for an American-built purpose-built autonomous vehicle.
The August precedent and the December trigger
Zoox is not asking NHTSA for the first time. In August 2025, NHTSA issued what it called the first-ever demonstration exemption for American-built automated vehicles, covering all Zoox purpose-built vehicles operating on public roads in the United States. That exemption cleared up a long-running regulatory debate about whether Zoox could legally operate without meeting standards written for human-driven cars. It did not, however, authorize commercial service. It was a research and demonstration clearance TechCrunch.
The petition for a commercial exemption was filed August 22, 2025 Hunton Andrews Kurth. But the pressure to file it came from an inspection.
Under the Biden administration, NHTSA investigated Zoox's self-certification of its purpose-built vehicles and, in December 2024, issued an inspection report documenting several noncompliances with applicable FMVSS. The inspection report is what prompted Zoox to formally petition for exemptions under the Trump administration. Secretary of Transportation Sean Duffy, speaking at the National AV Safety Forum on March 10, called Zoox's proposed deployment "a major milestone toward providing the American AV industry with a streamlined pathway to scale commercial deployment of novel AV fleets". The administration has made clear it wants to be the one that clears the path.
The GM precedent no one wants to repeat
Zoox is not the first company to try this. In 2018, GM petitioned NHTSA to deploy up to 2,500 vehicles without steering wheels or brake pedals. The petition was withdrawn in 2020. GM refiled in 2022. It was withdrawn again in October 2024. GM spent six years in regulatory conversation with itself. Zoox is pursuing the same statutory pathway with a different outcome in mind: a company that has been operating driverless on public roads for nearly two years, with real passenger data, is not the same as a company with a vehicle that has never been in commercial service.
What the exemptions actually mean
The eight standards fall into two categories. The first are equipment requirements that are simply inapplicable to a vehicle with no human operator: windshield wipers, defrosting systems, rearview mirrors, brake pedals, sun visors. Zoox's position is that these requirements are obsolete when no one is driving. The second are performance requirements, occupant crash protection and glazing, where Zoox argues it meets or exceeds the underlying safety goal using different methods. FMVSS 208, for example, requires seatbelts and airbags calibrated for a human in a crash. Zoox's carriage-style seating, with four passengers facing each other, does not fit the test procedure. Zoox says it achieves equivalent or better occupant protection through its architecture. That is the argument the comment period is meant to stress-test.
Comments close April 10. NHTSA will then publish its reasoning and decision. There is no fixed timeline for that decision after the comment period closes.
The commercial dependency
Zoox launched a free public robotaxi service in Las Vegas in September 2025. It has been expanding in Las Vegas, San Francisco, and, as of this month, Austin and Miami. It has a partnership with Uber to integrate Zoox vehicles into the Uber network in Las Vegas this summer and Los Angeles by mid-2027. None of that generates revenue unless Zoox can charge for rides. The exemption is the gate. Without it, Zoox is a very expensive free taxi service with an Amazon budget.
The broader framework shift
The Zoox petition is not happening in isolation. On March 16, six days after the Zoox comment period opened, NHTSA issued two notices of proposed rulemaking to amend FMVSS 102, 103, and 104 to formally accommodate automated driving systems. This is a separate process with a longer runway, not the same as granting Zoox's exemption. But it signals that the agency is moving toward a permanent framework for ADS-equipped vehicles rather than treating each exemption as an ad hoc decision. Zoox's petition is the test case. Whatever NHTSA decides will define the terms for every purpose-built robotaxi that comes after it.
The clock is April 10. Zoox has the miles, the riders, the cities, and the Uber deal. The exemption is the only thing between where it is and where it needs to be.
† Zoox has reported providing 350,000 free rides; this figure is sourced from company announcements and has not been independently verified by type0.
‡ Partnership timeline and implementation details sourced from Uber Investor Relations press release; not independently verified.
‡‡ Characterization of exemption as "first commercial-scale exemption of its kind" reflects NHTSA/Federal Register framing; type0 has not independently verified this as unprecedented.
