Interpretation ID: LW007646

Mr. Robert Babcock
Manager, Corporate Affairs
Hyundai America Technical Center, Inc.
5075 Venture Drive
Ann Arbor, MI 48108

Dear Mr. Babcock:

This is in response to your letter of October 7, 2004, in which you requested "confirmation that Federal Motor Vehicle Safety Standard 110 presents no obstacle to the inclusion of a label identifier for the Tire and Loading Information label required in the standard. " Your letter appears to seek clarification of the June 3, 2004, final rule amending Federal Motor Vehicle Safety Standard (FMVSS) No. 110, Tire Selection and Rims for Motor Vehicles with a GVWR of 4,536 Kilograms (10,000 Pounds) or Less (69 FR 31306). Paragraph S4.3(h) of that standard allows a vehicle manufacturer to place an optional bar code or vehicle identification number (VIN) on the righthand edge of the vehicle placard and tire information label. Specifically, you asked whether it would be permissible under paragraph S4.3(h) to place an alphanumeric identifier other than the VIN "outside the box" of the label in order to ensure that the correct label is placed on a specific configuration during the assembly process.

The National Highway Traffic Safety Administration (NHTSA) is in the process of responding to petitions for reconsideration of the June 3, 2004, final rule, and we expect to issue our response shortly. We will address the issue raised in your letter in our response to the petitions for reconsideration.

Should you have any remaining or additional questions once the response to the petitions for reconsideration is published, please feel free to submit them to the agency. If you have further questions in the interim, you may contact Mr. George Feygin of my staff at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:110
d.11/16/04