Interpretation ID: aiam2103
Mountain States Tire Dealers Association
1230 Pontiac Street
Denver
Colorado 80220;
Dear Mr. Riggs: Please forgive the delay in responding to your letter of May 1, 1975 which included a list of information items you believe are required to appear on retreaded tires pursuant to Federal Motor Vehicle Safety Standard No. 117, *Retreaded Pneumatic Tires*.; With the following qualifications, you list is correct: >>>1. The tire must be labeled with the symbol 'DOT' followed by th letter 'R', and other information required by 49 CFR Part 574.5, *Tire Identification and Recordkeeping*, as a certification that the tire complies with Standard No. 117. This requirement is distinct from and in addition to the requirement that the casing retain the 'DOT' symbol from its original manufacturer.; 2. The words 'bias/belted' are not required, because the actual numbe of plies in the sidewall and, if different, in the tread area, are now required to appear.; 3. Tube-type and tubeless tires must be labeled with the specific wor 'tube-type' and 'tubeless', respectively.; 4. The items listed in your third group may appear in a paper labe only if that label is not easily removable.<<<; For your convenience, I have enclosed a copy of Standard No. 117. Yours truly, Richard B. Dyson, Assistant Chief Counsel