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Interpretation ID: GF000573

    Ms. Laurie T. Baulig
    General Counsel
    Rubber Manufacturers Association
    1400 K Street, N.W.
    Washington, DC 20005


    Dear Ms. Baulig:

    This is in response to your letter of January 14, 2005, in which you requested a clarification regarding a recent technical amendment to paragraph S6.5(e) of FMVSS No. 119.

    On January 4, 2005, we published a technical amendment which, in part, revised paragraph S6.5(e) of FMVSS No. 119 (see 70 FR 299). Specifically, the amendment changed the metric value of tire speed restriction threshold from 88 km/h (55 mph) to 90 km/h (55 mph). Prior to the amendment, S6.5(e) of FMVSS No. 119 required that each tire be marked with speed restriction information, if the maximum speed of the tire was 88 km/h (55 mph) or less. Now, S6.5(e) of FMVSS No. 119 requires that each tire be marked with speed restriction information, if the maximum speed of the tire is 90 km/h (55 mph) or less. In both instances, S6.5(e) requires that the actual speed restriction be shown as follows:

    "Max speed __km/h (__mph)".

    The amendment was intended to make FMVSS No. 119 more consistent with established tire industry protocol and labeling technology, and did not substantively change the standard.

    You ask whether amendment to S6.5(e) requires that each tire manufactured after February 3, 2005 (the effective date of the amendment) be marked with the revised maximum speed restriction of "Max speed 90 km/h (55 mph)," if previously marked "Max speed 88 km/h (55 mph)," Our answer is no.

    The January 4, 2005 amendment to S6.5(e) of FMVSS No. 119 revised only the threshold below which all tires must be marked with their actual speed restriction (emphasis added). That is, the tire manufacturer could continue marking tires with the speed restriction of "Max speed 88 km/h (55 mph)", if that is the correct speed restriction, or other lower values, when appropriate.

    I hope you find this information helpful. If you have further questions, you may contact Mr. George Feygin of my staff at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    cc    Motomu Shinohara
          Secretary General, JATMA
          No. 33 Mori Building
          3-8-21 Toranomon, Minato-ku,
          Tokyo, 105-0001 JAPAN

    ref:119
    d.3/16/05