The recall is expected to affect 153,152 Audi A3 cars built between 2015 and 2020, including the Sedan, Etron and Cabriolet models, as well as certain S3 Sedans.
The system which detects whether the passenger seat is occupied might malfunction and switch off the air bag even if a person is sitting there, the filing said.
Tesla told the Second Circuit US Court of Appeals the Trump action was "unlawful" and "diminishes the value of performance-based incentives that electric vehicle manufacturers, such as Tesla, accrue under the standards".
Tesla, whose electric cars produce zero emissions, sells credits to other automakers to reduce their burden of complying with the regulations, and argues that the Trump rule change makes those credits less valuable.
In November, NHTSA rejected a petition filed by General Motors Co to avoid recalling 5.9 million US vehicles with Takata air bags. GM said the callback covered 7 million vehicles worldwide and would cost $1.2 billion.