Interpretation ID: aiam0743
Director of Government Relations
Rubber Manufacturers Association
1346 Connecticut Avenue
N.W.
Washington
D.C. 20036;
Dear Mr. Hastings: #This is in reply to your letter of June 9, 1972 asking whether the National Traffic and Motor Vehicle Safety Act preempts the various States from enforcing the Vehicle Equipment Safety Commission's Regulation V-1 with respect to passenger car tires. #Section 103(d) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1392(d)) requires any State law applicable to the same aspect of motor vehicle performance as a Federal motor vehicle safety standard to be identical to the Federal standard. We believe this section, considered in light of Federal Motor Vehicle Safety Standard No. 109, invalidates any State law that requires passenger car tires (except tires procured by a State for its own use) to meet the VESC Regulation V-1, or to be labeled with the V-1 symbol. #Sincerely, Lawrence R. Schneider, Chief Counsel;