Interpretation ID: aiam3530
International Sales Manager
CENTRA Leichtmetall-Rader GmbH
Daimlerstrasse 6
D-6733 Hassloch/Pfalz
West Germany;
Dear Mr. McCalmon: This responds to your letter to Mr. Kratzke of my staff concerning th Federal requirements for vehicle wheels that are to be imported into the United States. You noted in your letter that the wheels would be for 'original equipment on passenger vehicles and non-passenger vehicles (recreation vehicles).' There are two Federal Motor Vehicle Safety Standards which apply to wheel rims. There are no standards applicable to the rest of the wheel assembly, however.; The two applicable standards are No. 110, *Tire selection and rims passenger cars*, and Standard No. 120, *Tire selection and rims for motor vehicles other than passenger cars*. I have enclosed copies of both standards, along with Standards Nos. 109 and No. 119, which are applicable to tires. For those passenger car rims you manufacture there are two requirements, specified in section S4.4 of Standard No. 110. FIrst, the rim must be constructed to the dimensions of one of the rims that is listed under the definition of a test rim in Standard No. 109. This means that the rim must comply with the dimensional specifications shown for that rim size in the current publications of specified standardization organizations, such as the Tire & Rim Association, the European Tyre and Rim Technical Organization, or the Deutsches Institut fur Normnug. Second, in the event of a rapid loss of inflation pressure with the vehicle travelling in a straight line at 60 miles per hour, the rim must retain the deflated tire until the vehicle can be stopped with a controlled braking application.; For those rims you manufacture for use on vehicles other than passenge cars, Standard No. 120 also specifies two requirements. The first requirement, set forth in section S5.1.1, is that the rims on a vehicle must correspond with the size tire on the vehicle i.e., be listed as suitable by the tire manufacturer, pursuant to either Standard No. 109 or No. 119. This would be done in the publications of the standardization organizations, as explainted (sic) above. This requirement is the responsibility of the vehicle manufacturer, since only it knows what size tires will actually be on the vehicle. The second requirement, set forth in section S5.2, is that the rim must be marked with certain specified information.; When a rim manufacturer determines that its rims comply with th requirements outlined above, it may certify the rims and sell them in the United States. In your letter, you inaccurately stated that there is no (sic) a specific DOT certification for rims. While there is no specific DOT certification number, as required by some other standards for items for equipment other than rims, a manufacturer must always certify that each item of motor vehicle equipment complies with all applicable Federal motor vehicle safety standards, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1403) (copy enclosed). That section specifies that the certification for items of motor vehicle safety equipment, including rims, may be in the form of a label or tag on the item, or on the outside of a container in which the item is delivered. All of your rims to be sold in this country must contain such a certification.; The United States does not use a certification process similar to th EEC, in which the manufacturer delivers the item to be certified to the governmental entity, and that entity tests the item to determine if it can be certified. Instead, in the United States, the individual manufactuer (sic) must certify that the product complies with all applicable standards. Further, this agency does not require that a certification be based on actual tests of the equipment, we only require that the certification be made with the exercise of due care on the part of the manufacturer. It is up to the individual manufacturer to determine in the first instance exactly what data or information it needs to allow it to certify that the equipment meets all applicable Federal standards. Obviously, with respect to the requirements for rims, a manufacturer is not expected to test if the rims have the necessary markings or if the rim size is listed in one of the publications of a standardization organization.; Should you have any further questions about these standards, feel fre to contact me. If you need further information about the actual process of importing the rims into the United States or the form for the certification, you can contact the U.S. Customs Service Duty Assessment Division at 1301 Constitution Avenue, N.W., Washington, DC 20229.; Sincerely, Frank Berndt, Chief Counsel