Interpretation ID: nht76-1.32

DATE: 05/11/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: Intercraft Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your March 29, 1976, letter concerning regulations applicable to farm tractor tires whose importation is contemplated by one of your clients.

Farm tractors are not "motor vehicles" as that term is defined in the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et Seq.). Accordingly, tires designed exclusively for use on farm tractors are not "motor vehicle equipment." Therefore, the importation of such tires and tubes is not subject to Federal motor vehicle safety standards or other regulations issued by the National Highway Traffic Safety Administration. We are unaware of any other regulations of the Department of Transportation concerning such tires.

Yours truly,

ATTACH.

Intercraft Corporation

March 29, 1976

Frank Berndt -- Acting Chief Counsel, National Highway Traffic Safety Administration,

Dear Mr. Berndt:

A foreign tire manufacturer has indicated to us that he is interested in exporting certain agricultural tires and matching tubes to one of our clients in the United States. If a transaction can be concluded, these tires and tubes would be imported to the U.S. by our client and would be sold by him in this country.

Two sizes of farm tires and tubes would be involved: 15.5-38 (6 and 8 PR) and 18.4-38 (8 PR). We understand that both of these sizes of tires and tubes are made for the rear wheels of farm tractors for field use only and are considered "Off The Road" in the tire industry.

We would like to ask if there are any U.S. Department of Transportation regulations concerning motor vehicle safety standards, tire identification and recordkeeping, or manufacturer identification that apply to the importation to the United States of tires and tubes of those two size designations? Do any DOT regulations apply to any other facet of the importation of such tires and tubes to the U.S.?

Sincerely, Robert M. Brodkey -- President