Interpretation ID: aiam0253
Vice President
Universal Tire Corporation
4622 Southlawn Lane
Rockville
Maryland 20850;
Dear Mr. Finkel: The Office of Trade Regulation Rules of the Federal Trade Commissio has forwarded your letter of July 30, 1970, concerning tires marked 'Radial' that have casing cord angles that vary as much as 15 degrees from 90 degrees.; Paragraph S3 of Motor Vehicle Safety Standard No. 109 -- New Pneumati Tires, Passenger Cars -- defines a radial ply tire as a 'pneumatic tire in which the ply cords which extend to the beads are laid at substantially 90 degrees to the centerline of the tread'.; The Bureau does not consider cords laid a 75 degrees to the centerlin of the trend as 'Radial' tires and tires marked as much(sic) would not be incompliance with the tire standard.; Persons importing tires that do not comply with the standard would b violating section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1397).; For your information enclosed is a copy of the Passenger Car Tir Standard and the National Traffic and Motor Vehicle Safety Act.; Sincerely, Lawrence R. Schneider, Acting Deputy Chief Counsel