Interpretation ID: aiam3791
Standards Attache
The French Embassy
Suite 715
2000 L Street
N.W.
Washington
DC 20036;
Dear Mr. Chambord: This responds to your recent letter to Mr. Steve Kratzke of my staff asking for information on requirements applicable to tire rims for vans. The three points set forth in your letter are correct statements of the requirements, but I will reiterate them to be certain that you provide accurate information.; (1) Vans are considered 'motor vehicles other than passenger cars' fo the purposes of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars* (49 CFR S571.120), and Standard No. 120 sets forth requirements which must be met by all new rims for use on vans. No other standard contains requirements applicable to those rims.; (2) Section S5.2(c) of Standard No. 120 requires the rim manufacture to permanently label each of its van rims with the letters 'DOT' as a certification that the rim satisfies the requirements of Standard No. 120. The manufacturer is expected to exercise due care before making such a certification. No outside inspector, either governmental or privately employed, need be consulted by a manufacturer before certifying the compliance of its rims.; (3) Rims entering into the United States are not individuall inspected, provided that the package containing the rims or the van on which the rims are installed bears an appropriate certification label. The only inspections at the port of entry are checks to see that a certification label is attached to the package of rims or the van.; Should you need any further information on this subject, please do no hesitate to contact me.; Sincerely, Frank Berndt, Chief Counsel