Interpretation ID: aiam1758
Jr.
Director of Communications
Dealer News
1343 L Street
N.W.
Washington
D.C. 20005;
Dear Mr. Friedlander: This is in reply to your letter of December 24, 1974, forwarding to u a copy of an article in the December 23-30, 1974, issue of the NTDRA *Dealer News*, which attempts to clarify an earlier article interpreting the labeling requirements of Motor Vehicle Safety Standard No. 117.; We believe your revised article is still somewhat unclear i interpreting the requirements, and we would like to clarify these requirements for you.; >>>*THE FOLLOWING REQUIREMENTS ARE PRESENTLY EFFECTIVE*<<< The casing, before retreading, must contain in a permanent fashion, th following: the symbol 'DOT', the size of the tire, and the actual number of plies or ply rating.; The completed retread must be labeled,either permanently or with a affixed label that is not easily removable, with the following: the tire's size designation, its maximum permissible inflation pressure, the actual number of plies, ply rating or both, the words 'tubeless' or 'tube type,' as appropriate, the word radial, if the tire is of radial construction, and if the tire is of bias-belted construction, the words 'bias belted' *or* the actual number of plies in the sidewall and the actual number of plies in the tread area.; The completed retreaded tire must be permanently labeled only with it maximum permissible load. Permanent labeling includes molding, branding, or other method that will produce a permanent label, and includes any original casing label that is retained through the retread process.; >>>*THE FOLLOWING REQUIREMENTS ARE EFFECTIVE MAY 12, 1975*<<< The casing before retreading must contain in a permanent fashion th following: the symbol 'DOT', the size of the tire, and the actual number of plies or ply rating. These requirements are the same as those presently in effect.; The completed retread must be labeled, either permanently or with a affixed label that is not easily removable, with the following: the tire's size designation, its maximum permissible inflation pressure, the words 'tubeless' or 'tube type' as appropriate, and the word 'radial' if the tire is of radial construction.; The completed retread must be permanently labeled only with th following: the tire's maximum permissible load, the actual number of plies in the tire sidewall, and the actual number of plies in the tire tread area, if different, and the generic name of each cord material used in the plies (both sidewall and tread area) of the tire.; The changes made by the amendment published November 12, 1974 (39 F 39882), which are effective May 12, 1975, are, in summary, that (1) the labeling of the actual number of plies in the sidewall, and tread area if different, must after May 12, 1975, be permanently labeled, and (2) the generic names of each cord material, which prior to May 12, 1975, is not required to be labeled at all, must after May 12, 1975, be permanently labeled.; We believe some further clarification of the requirements should b conveyed to your readers.; Yours truly, Richard B. Dyson, Acting Chief Counsel