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Interpretation ID: GF007220-2

    Louis J. Carlin, Director
    Safety Regulations and Consumer Information
    General Motors North America
    Mail Code: 480 111 S56
    30200 Mound Road
    Warren, MI 48090-9010


    Dear Mr. Carlin:

    This concerns your letter dated October 11, 2004, in which you requested an interpretation of certain requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 110, Tire Selection and Rims. We have reconsidered our response dated January 3, 2005 with respect to permissible load identifications.

    In your October 11, 2004 letter, you asked whether S4.3 of FMVSS No. 110, as amended by the final rule responding to petitions for reconsideration (see 69 FR 31306, June 3, 2004) allows a light truck tire load identification of B, C, D, E, or F on the tire information placard. In our response, we stated that S4.3(i) of FMVSS No. 110 permits only a tire load identification XL or "reinforced". We noted, however, that we were considering petitions for reconsideration asking the agency to permit light truck load identifications of B, C, D, E, or F on tire information placards.

    We have reconsidered our previous interpretation. While the agency declined to allow load index numbers on the tire placards (see id. at 31311)

    , we decided to allow load identifications of XL and "reinforced". The preamble to the final rule did not elaborate on other load identifications (see id. at 31312).

As you note in your letter, load identifications of B, C, D, E, or F are used for light truck tires to identify load carrying capability in the same way XL is used for passenger car tires to identify extra load carrying capability. In permitting the use of XL for passenger car tires, we stated:

"the agency agrees with petitioners that when the vehicles are equipped with these tires, consumers should be made aware of this information so that they know to replace them with tires capable of holding a similar load. "

In making this change, it was not our intent to allow the load identification for passenger car tires, but prohibit it for light truck tires. Accordingly, while S4.3(i) currently specifies only that a tire load identification XL or "reinforced" may appear on the tire information placard (see id. at 31318), we interpret that section to permit use of the corresponding light truck tire load identifications of B, C, D, E, or F. We intend to make this clear in the regulatory text as part of our response to petitions for reconsideration of the June 3, 2004 final rule.

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
ref:110
d.2/18/05