Interpretation ID: aiam4113
President
Semperit Tire Company
156 Ludlow Avenue
Northvale
NJ 07647;
Dear Mr. Horbatt: This responds to your letter to Stephen Kratzke of my staff, in whic you stated your interpretation of the requirements of the Uniform Tire Quality Grading Standards (49 CFR S575.104, 'UTQGS'). You stated that your company is introducing a new all-season tire to the United States market, and that you would like to import the first six months' production without the UTQGS grades molded onto the sidewall of the tires, but with paper labels showing those grades. This course of action is expressly permitted by the UTQGS.; First, the UTQGS is applicable to all-season tires. Sectio 575.104(c)(1) specifies that the UTQGS does not apply to 'winter-type snow tires.' The National Highway Traffic Safety Administration has explained that winter-type snow tires refers only to tires with a deep tread rubber and tread design which are inadvisable for year-round use on passenger automobiles. Since all-season tires are not 'winter-type snow tires,' they are subject to the requirements of the UTQGS. *See* 44 FR 30139, at 30140, May 24, 1979.; The requirement that the grades assigned under the UTQGS be permanentl molded onto one sidewall of each passenger car tire is set forth in 49 CFR S575.104(d)(1)(i)(A). However, that section reads:'*Except for a tire of a new tire line, manufactured within the first six months of production of the tire line*, each tire shall be graded with the words, letters, symbols, and figures ... permanently molded into or onto the tire sidewall....' A tire line introduced for the first time into the United States is considered a new tire line for the purposes of this section. Therefore, our UTQGS regulation does *not* require you to mold the assigned grades onto a sidewall of those tires manufactured within the first six months of production. Such tires are subject to the requirement that a paper label, showing the UTQGS grades assigned to the tire, be affixed to its tread surface (49 CFR S575.104(d)(1)(i)(B)), and that the grades assigned to those tires appear in the information furnished to prospective purchasers of the tires (49 CFR S575.6(c)).; If you have any further questions or need more information on thi subject, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992.; Sincerely, Erika Z. Jones, Chief Counsel