Interpretation ID: aiam0704
Livingston's Tire Shop
North Main Street
Hubbard
Ohio 44425;
Dear Mr. Livingston: This is in reply to your letter of May 2, 1972, requesting a lette from NHTSA to the effect that tire manufacturers are free to sell you new repairable tires which you plan to repair and sell. We have assumed that the manufacturers of the tires do not believe that they conform to Motor Vehicle Safety Standard No. 109. 'New Pneumatic Tires,' and that they have not certified conformance to the standard, as this is apparently the reason for their reluctance to sell you these tires.; Paragraph S6. of Standard No. 109 provides, among other things, tha passenger car tires that are not certified, defined as 'reclassified tires,' must bear a label (specified in the standard) stating that they are not to be sold for use on passenger cars.; If you wish to purchase reclassified tires, repair them, and resel them for passenger car use, you must ensure that they conform to the performance requirements of Standard No. 109 (paragraphs S1. through S5.). and relabel and certify them in accordance with paragraph S4.3.; You should be aware that the NHTSA has proposed, in a notice date November 27, 1971 (36 F.R. 22688, copy enclosed) to prohibit the sale for any purpose of reclassified tires.; Yours truly, Richard B. Dyson, Assistant Chief Counsel