Interpretation ID: aiam3421
Executive Director
Japan Automobile Tire Manufacturers Association
Inc.
9th Floor
Toranom Building
No. 1-12
1-Chome Toranomon
Minato-Ku
Tokyo
Japan;
Dear Mr. Ohgiya: This responds to your recent request for an interpretation of th labeling requirements of Safety Standard No. 109 (49 CFR S571.109). Specifically, your association wants to know if Standard 109 permits tire manufacturers to include the letters 'H,' 'S,' or 'V,' as appropriate, in the tire size designation required to appear on the sidewall of passenger car tires by S4.3(a) of the Standard.; Such labeling is permitted by Standard 109. The speed rating symbol ('h,' 'S,' or 'V') established by the European Tyre and Rim Technical Organization, indicate that a tire is an acceptable high-speed tire. This permits, for example, a knowledgeable purchaser of tires for emergency vehicles to know that these tires are suitable for the higher operational speeds necessary for those vehicles. Use of these symbols in the size designation would not likely confuse the less sophisticated consumer, or otherwise defeat the purpose of the labeling information. Accordingly, use of these symbols is permitted under Standard 109.; If you have any further questions, or need further information on thi matter, please feel free to contact Steve Kratzke of my staff (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel