Interpretation ID: 2656o
Manager, Truck Tire Engineering
Yokohama Tire Corporation
Corporate Office
60l S. Acacia
Fullerton, CA 9263l
Dear Mr. Kaizaki:
This responds to your letter requesting an interpretation of Standard No. ll9, New Pneumatic Tires for Vehicles Other Than Passenger Cars. You asked whether it is permissible to place two tire size designations, 385/65R22.5 in larger letters and l5R22.5 in small letters, on the same tire. The answer to your question is no.
By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.
The practice of labeling two tire sizes on one tire, as you requested in your letter, was once a fairly common practice and was referred to as "dual-size markings." Dual-size markings were a marketing effort by tire manufacturers to try to persuade consumers to change the size and/or type of tire on their vehicles, by representing that this particular tire size was an appropriate replacement for two different sizes of tires. However, the practice of using dual-size markings confused many consumers about the size of the tire on their vehicle. The only purpose of the Federally required markings on tires is to provide consumers, in a straightforward manner, with technical information necessary for the safe use and operation of the tire. The agency concluded that it was inappropriate to permit a marketing technique that was confusing many consumers to defeat the purpose of the required markings on tires. Accordingly, dual-size markings were expressly prohibited for passenger car tires subject to Standard No. 109; 36 FR 1195, January 26, 1971.
The marking requirements for tires subject to Standard No. 119 are set forth in section S6.5 of the standard. Section S6.5(c) requires that each tire be marked on both sidewalls with "the tire size designation as listed in the documents and publications designated in S5.1." Section S5.1 of Standard No. 119 requires each tire manufacturer to ensure that a listing of the rims that may be used with each tire the manufacturer produces is available to the public. This may be done either by the individual manufacturer furnishing a document to each of its dealers, to this agency, and to any person upon request, or the manufacturer may rely on the tire and rim matching information published by certain standardization organizations.
While Standard No. 119 does not expressly prohibit dual-size markings, section S6.5(c) uses the singular when it refers to the "tire size designation" to be labeled on the tire. Considering the past history associated with dual-size markings, this agency interprets section S6.5(c) of Standard No. 119 as prohibiting a manufacturer from marking a tire with two different size designations, even if a document or publication designated in S5.1 were to show two different size designations for the same tire size.
Sincerely,
Erika Z. Jones Chief Counsel ref:119 d:2/16/88