Interpretation ID: aiam2376
No. 13 Connell Dr.
Little Rock
AR 72205;
Dear Mr. Atkinson: This is in response to your June 18, 1976, letter concerning th application of Federal Motor Vehicle Safety Standard No. 117, *Retreaded Pneumatic Tires*, to passenger car tires that are retreaded from bead to bead.; I understand that in this process, the labeling information molded o the sidewalls of the tire to be retreaded is buffed off prior to the application of new rubber. You have requested our assurance that 'it is permissible to do bead to bead retreading, removing the present labeling and remolding all the pertinent information on the tire.'; The requirements for casings to be used in retreading are set out i S5.2.3 of Standard No. 117:; >>>Each retreaded tire shall be manufactured with a casing that bears permanently molded at the time of its original manufacture into or onto the tire sidewall, each of the following:; (a) The symbol DOT, (b) The size of the tire, and (c) The actual number of plies or ply rating.<<< This section requires the above information to be present on the casin at the beginning of the retreading process, to ensure both that the carcass was originally manufactured to comply with Standard No. 109, *New Pneumatic Tires--Passenger Cars*, and that the retreader has reliable information on which to base the labeling of the completed tire. The section does not, however, require that this originally molded information be retained on the completed tire.; Certification and labeling requirements for completed retreaded tire are set out in S6 of the standard. The DOT symbol required by S6.1, however, is not a 'remolding' of the original DOT symbol (certifying compliance with Standard No. 109) that may have been buffed off. It is a new certification by the retreading party that his product complies with Standard No. 117. Further, this new DOT symbol must be followed by the letter 'R', as indicated in 49 CFR S 574.5, *Tire Identification and Recordkeeping*. 'Remolding' of the original DOT symbol is neither required nor permitted. Finally, the information required by S6.3 to appear on the completed tire is permitted, but not required, to so appear through retention of the original labeling.; In conclusion, bead- to-bead retreading is not prohibited by Standar No. 117, provided that the casings satisfy S5.2.3 at the beginning of the retreading process, and all other requirements of the standard are met.; Yours truly, Frank A. Berndt, Acting Chief Counsel