Interpretation ID: aiam4129
Manager
Technical Services
Yokohama Tire Corporation
1530 Church Road
Montebello
CA 90640;
Dear Mr. Griffing: This responds to your letter to Mr. Glen Ludwig, of our Enforcemen division, seeing an interpretation of Standard No. 119, *New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars* (49 CFR S571.119). Specifically, you stated that your company would like to label the following information on medium truck tires, in addition to the information specifically required to appear on the tires by Standard No. 119:; >>>1. the load index specified by the International Standard Organization (ISO), and; 2. the speed rating specified by the European Tire and Rim Technica Organisation (ETRTO).<<<; You asked two questions concerning these markings. First, you aske whether Standard No. 119 allows tire manufacturers to place two different load plates on tires, one for Standard No. 119 and one with the ISO load index, even if the maximum load given in pounds is not exactly the kilogram value for the maximum load of the listed ISO load index. The answer to this question depends on whether the ISO load index information is presented in a manner that would obscure or confuse the meaning of the information required to appear on the sidewall of the tire by Standard No. 119, or otherwise defeat the purpose of the required information.; Paragraph S6.5 of Standard No. 119 requires that certain information b labeled on the sidewalls of each tire subject to this standard. The agency has frequently stated in past interpretations that the purpose of these labeling requirements is to provide the consumer, in a clear and straightforward manner, with technical information necessary for the safe use of tires. See, for example, the enclosed April 30, 1980 letter to Mr. Arnold van Ruitenbeek. Standard No. 119 permits tire manufacturers to label additional information on the sidewall of the tires, provided that the additional information does not obscure or confuse the meaning of the required information, or otherwise defeat its purpose.; It is not clear from your letter whether you are proposing to add jus the ISO load index to the required information on the sidewall of the tires, or that load index *and* a separate maximum load rating expressed in kilograms. If you are proposing the former course of action, Standard No. 119 does *not* prohibit tire manufacturers from adding the ISO load index to the information required by Standard No. 119 to appear on the sidewall of the tires, provided that the load index is shown in such a way that it is not confusing to consumers. This agency sent two letters to Michelin Tire Corporation on this subject, dated July 14, 1980 and August 28, 1980. I have enclosed copies of these letters for your information.; If, on the other hand, you are proposing the latter course of action NHTSA has said that the load and inflation pressure information can be expressed in both English units and metric units, provided that the metric units are *equivalent* to the English units. See the enclosed April 5, 1979 letter to Mr. Michael Petler. However, Standard No. 119 does *not* permit a tire manufacturer to list two different maximum load values on its tires. See the enclosed August 18, 1983 letter to Mr. Arnold van Ruitenbeek. Accordingly, if your company's tires were to list one value as the maximum load rating in pounds and a *different* value as the maximum load rating in kilograms, NHTSA would consider such labeling to be a violation of the requirement in S6.5(d) of the Standard.; Your second question was whether this Department put out any specia instructions for tire manufacturers regarding the placement on the tire of the ETRTO and ISO information. As explained above, Standard No. 119 prohibits the addition of information to tire sidewalls only if such information confuses or obscures the meaning of the required information. There are no further 'special instructions' concerning this requirement. In past agency interpretations, the agency has made clear that the ETRTO speed ratings and the ISO load indices may be included in a tire's *size designation* without violating this prohibition. See the enclosed June 25, 1981 letter to Mr. Keigo Ohgiya for the ETRTO speed ratings and the August 28, 1980 letter to Mr. John B. White for the ISO load indices.; This agency position leaves wide latitude for the tire manufacturers t incorporate such additional information onto the tire sidewalls. One of the reasons for allowing this wide latitude is this agency's hope that the tire manufacturers can collectively agree, through the standardization organizations, to a resolution of the potential problems associated with providing additional information. If the tire companies jointly agree on a method of presenting this information that is not confusing to consumers, no 'special instructions' or other actions by this agency would be needed.; Should you have any further questions or need more information on thi subject, please contact Steve Kratzke of my staff at this address or by telephone at (202) 426- 2992.; Sincerely, Erika Z. Jones, Chief Counsel