Interpretation ID: 18109.wkm

Mr. Frank Johnson
Executive Vice-President
Nichirin Inc.
139 Copernicus Boulevard
Brantford, Ontario, Canada
N3P 1N4

Dear Mr. Johnson:

This responds to your letter of May 26, 1998 to Mr. Luis Figueroa of this agency's Office of Vehicle Safety Compliance, who referred the letter to this office for response.

You state in your letter that your parent company, Nichirin Company, Ltd. Japan asked you to inquire of this agency whether it is permissible to add optional information to the required labeling of brake hoses. Specifically, you state that your current marking is

DOT NCRN 3/98 1/8 HL

You state that your parent company provides hoses for coupling by another party (Company X). This party requests that Nichirin provide hoses labeled as follows:

DOT NCRN FOR CO. X 3/98 1/8 HL

Assuming from the reference to "HL" in your labeling that the hoses concerned are low expansion hydraulic brake hoses, your current labeling is correct under subsection S5.2.2 of Federal Motor Vehicle Safety Standard (Standard) No. 106, Brake hoses. The standard makes no provision for marking information in addition to the required information. However, this agency has interpreted Standard 106 to permit the labeling of brake hoses with optional information if the optional information does not confuse or obscure the meaning of the required information. Moreover, in order to avoid confusion with the required information, the optional information must appear on the opposite side of the hose. Thus, you are permitted to label your hoses with the optional information your customer requested so long as that optional information appears on the side of the hose opposite from the required labeling.

I hope this information is helpful to you. Should you have any further questions or need additional information, feel free to contact Walter Myers of my staff at this address or at (202) 366-2992, or fax at (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:106
d.7/6/98