Interpretation ID: aiam3268
Vice President
Continental Product Corporation
1200 Wall Street West
Lyndhurst
new Jersey 07071;
Dear Mr. Ruitenbeek: This responds to your March 28, 1980, letter to this office in whic you inquired about permissible markings on motorcycle tires. Specifically, you asked whether you could insert language in addition to that specified in Standard No. 119 when labeling the load rating and inflation pressure on certain tire sizes. The answer to your question is no.; Standard No. 119 ( 49 CFR S 571.119) specifies certain requirement which all motorcycle tires offered for sale in this country must meet. One of these provisions is the labeling requirement set fourth in paragraph s6.5 of the standard. Subparagraph (d) of s6.5 requires the maximum load rating and corresponding inflation pressure to appear on the tire in the following words: 'Max load * *lbs at * *psi cold.' The language of the subsection is mandatory and does not permit any variation. Therefore, the insertion of the phrase 'in USA and Canada,' as you suggest, would mean the tire would not comply with the labeling requirement of Standard No. 119.; The reason for this strict wording requirement is to ensure that th information labeled on motorcycle tires conveys necessary information to the purchaser of the tire in a clear, straightforward manner that is uniform with all motorcycle tires. Adding language which suggests that the maximum load of a tire depends on the country in which the tire is being used could confuse the user of the tire. Further, it suggests that the printed maximum load is not rally the maximum. Either of the results frustrates the purpose of the labeling requirement in Standard No. 119.; Sincerely, Frank Berndt, Chief Counsel