Interpretation ID: Alani.1
Mr. Y. Alani
Deputy General Manager
Autoluxe Tires (Israel) Ltd.
25 Hamelacha Street, Park Afeq
Rosh Haayin 48091
Israel
Dear Mr. Alani:
This is in response to your letter and subsequent e-mail to Eric Stas in which you requested clarification as to the proper application of speed rating codes for replacement tires. Specifically, your letter asked whether it would be permissible to replace original equipment tires with an "H" speed rating with replacement tires with a "T" speed rating, whether it would be permissible to place "H"-rated tires on the front axle and "T"-rated tires on the rear axle of a vehicle, and whether a damaged "H"-rated tires would retain that designation after being repaired. For the reasons discussed below, the National Highway Traffic Safety Administration (NHTSA) cannot advise you as to the proper application of these codes.
Speed ratings are not required under our Federal motor vehicle safety standards (FMVSSs). It is our understanding that the tire speed rating system was established by the European Tyre and Rim Technical Organization (ETRTO), so you may wish to consult with that organization about the proper application of such codes (see http://www.etrto.org/pub_gb.html for contact information.)
We assume that you wrote to us because some tires sold in the U.S. are labeled with speed rating codes. By way of explanation, NHTSA is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment (e.g., tires) introduced into the U.S. market. NHTSA does not issue approvals of these products, but instead, a manufacturer of motor vehicles or motor vehicle equipment must self-certify that its products meet all applicable safety standards, prior to offering such products for sale in the United States. Under our FMVSSs related to tires, manufacturers are not required to label tires with speed ratings. However, tire manufacturers are permitted to label additional information on the sidewall of tires, including speed rating codes, provided that the additional information does not obscure or confuse the meaning of the required information, or otherwise defeat its purpose.
If you have further questions, you may contact Eric Stas of my staff at (202) 366-2992.
Sincerely,
Jacqueline Glassman
Chief Counsel
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