Interpretation ID: aiam2539
Supervisor
Product Safety
Safety and Legislation Department
U.S. Suzuki Motor Corporation
13767 Freeway Drive
Santa Fe Springs
California 90670;
Dear Mr. Link: This responds to your February 23, 1977, letter asking whether thre proposed labeled satisfy the requirements for label identification found on Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with the requirements of Standard No. 120. A review of the labels you supplied indicates that you have used a different format than illustrated in our notice of February 7, 1977 (42 Federal Register 7140). For example, the amended Standard No. 120 does not require the words 'with the tires listed below' or even the word 'with' before the tire size. The deletion of such superfluous words from the label requirements of Standard No. 120 resulted from comments by manufacturers, particularly motorcycle manufacturers, that unnecessary word needlessly increase the size of the label.; The example of label information shown in S5.3 of the standard i intended only as a guide to manufacturers. A manufacturer can vary the illustrated format somewhat as long as the requirements of S5.3 are satisfied. Since the additional words on your label do not obfuscate the certification statement, the labels appear to comply with the requirements of Standard No. 120 and Part 567.; Sincerely, Frank Berndt, Acting Chief Counsel