Interpretation ID: GF002565

Tony Dosmann, President
Dec-O-Art, Inc.
3914 Lexington Park Drive
Elkhart, IN 46514-1194

Dear Mr. Dosmann:

This responds to your letter in which you requested an interpretation of certain requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 110, Tire Selection and Rims and 49 CFR Part 567, Certification. Both regulations require permanently affixed labels. You ask us to explain the meaning of "permanent".

In previous letters of interpretation, we have explained that specifying precisely how a label is to be affixed could be design restrictive. However, when the agency requires a permanently affixed label for a vehicle, the label must be affixed in a manner that would make it likely to stay attached and legible during the lifetime of the vehicle, under normal conditions. We have previously stated that a label affixed to the vehicle using adhesives would be considered adequate. Finally, in previous letters we cautioned that labels should not be attached in a manner where they can be easily detached. I have enclosed copies of several relevant letters.

I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:110
d.4/15/05