Interpretation ID: aiam1208
Aktiengesellschaft
Werk 2
A-2514 Traiskirchen
N.O.
Attention: Gorter;
Dear Mr. Gorter: This is in reply to your letter of July 11, 1973, inquiring whether i is permissible under paragraph S4.3 of Standard No. 109 (49 CFR S571.109, 'New Pneumatic Tires') to label tires as follows:; >>>1) TUBE-LESS TYPE instead of tubeless. 2) TUBE- TYPE for tube type.<<< While not stated in your letter it appears that you wish to facilitat the relabeling of the word 'tube type' on tires originally manufactured as tubeless. We understand many tire manufacturers redesignate tubeless tires as tube type when they contain some imperfection that may affect their tubeless air-retention capability, but which perform satisfactorily when tubes are installed.; Paragraph S4.3 of Standard No. 109 specifically requires the wor 'tubeless' or 'tube type' as appropriate. Neither the phrase 'TUBE-LESS TYPE' nor the phrase 'TUBE- TYPE' conform to this requirement. the labeling you suggest would therefore not conform to Standard No. 109. We would expect that any redesignation of tubeless tires as tube type would be accomplished by obliterating the tubeless label and labeling the tire 'tube type', in the form required by the standard.; I would like to point out that our decision to interpret thes requirements strictly results in part from our efforts to stop a practice, which is occurring in the United States, in which some tire dealers sell tires that have been relabeled as tube type while representing to customers that tubes are not needed because the tires were originally tubeless. We believe labeling tires as you suggest will have the unfortunate consequence of promoting this activity, as it will make it more obvious that the tires were originally manufactured as tubeless.; Yours truly, Richard B. Dyson, Assistant Chief Counsel