Interpretation ID: 11295ADRN
Baker & Daniels
300 North Meridian Street
Suite 2700
Indianapolis, IN 46204-1782
Dear Mr. Grandy:
This responds to your letter seeking confirmation that OEM passenger car wheel manufacturers have no certification responsibilities.
In your letter, you explain that your client is "an automobile wheel manufacturer that exports wheels to certain automobile manufacturers in the United States to be used in the production of passenger cars." You state your belief that your client does not have to certify its wheels, since neither Standard No. 110, Tire selection and rims, nor 211, Wheel nuts, wheel discs, and hub caps, "appears to apply to automobile wheels and we find no other Safety Standards applicable to automobile wheels."
You are correct that Standard No. 110 does not apply to your client's product. A motor vehicle wheel is comprised of a wheel rim and wheel disc. While Standard No. 110 specifies two requirements for passenger car rims (section S4.4), it is a "vehicle" standard with which the completed vehicle must comply, rather than an "equipment" standard for wheel components. Thus, the vehicle manufacturer, and not your client, would be responsible for certifying compliance with this standard.
With regard to Standard No. 211, we wish to clarify an issue about the applicability of the standard. Standard No. 211, Wheel nuts, wheel discs, and hub caps, applies to passenger car equipment. S4, Requirements, of the standard states:
As installed on any physically compatible combination of axle and wheel rim, wheel nuts, wheel discs, and hub caps for use on passenger cars and multipurpose passenger vehicles shall not incorporate winged projections that extend beyond the plane that is tangent to the outboard edge of the wheel rim at all points around its circumference. ***
Standard No. 211 defines "winged projection" in S3.2, and shows an example of a "winged projection" in Figure 1.
Your letter does not provide enough information to enable us to determine with certainty whether your client's wheels comprise components subject to Standard No. 211. The term "wheel discs" used in S4 typically refers to a component that is a part of a wheel in the same manner as a center-mounted wheel nut or hub cap. Your client's wheels may or may not include such components.
Please note that NHTSA is considering rescinding Standard No. 211, based on our tentative conclusion that it is unnecessarily design-restrictive. (60 FR 31947, June 19, 1995.) The public comment period closed on August 3, 1995. NHTSA is reviewing the public comments and expects to make a final decision on the matter in the near future.
I hope this information is helpful. If you need any further information, please contact Dorothy Nakama of my staff at (202) 366-2992.
Sincerely,
Samuel J. Dubbin Chief Counsel
ref:110#211 d:1/30/96