Interpretation ID: aiam2446
Technical Manager
Pirelli Tire Corporation
600 Third Avenue
New York
New York 10016;
Dear Mr. Buzzi-Ferraris: This is in response to your November 1, 1976, letter to Mark Schwimme of my staff, concerning the marking 'V1' on passenger car tires.; The marking 'V1' is not required by any Federal statute, motor vehicl safety standard, or other regulation to appear on the sidewall of passenger car tires. Furthermore, Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 as amended, 15 U.S.C. 1392(d), provides in pertinent part:; >>>Whenever a Federal motor vehicle safety standard established unde this title is in effect, no State of political subdivision of a State shall have any authority either o establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.<<<; This provision, considered with Federal Motor Vehicle Safety Standar No. 109, prohibits any State from imposing any safety labeling requirements for passenger car tires other than those contained in that standard. Any differing safety labeling requirements, including the 'V1' that you have mentioned, are thus preempted and void.; Sincerely, Frank A. Berndt, Acting Chief Counsel