Interpretation ID: nht73-1.14

DATE: 08/17/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Semperit - Aktiengelellschaft

TITLE: FMVSS INTERPRETATION

TEXT:

This is in reply to your letter of July 11, 1973, inquiring whether it is permissible under paragraph S4.3 of Standard No. 109 (49 CFR @ 571.109, "New Pneumatic Tires") to label tires as follows:

1) TUBE-LESS TYPE instead of tubeless

2) TUBE- TYPE for tube type

While not stated in your letter it appears that you wish to facilitate the relabeling of the word "tube type" on tires originally manufactured as tubeless. We understand many tire manufacturers redesignate tubeless tires as tube type when they contain some imperfection that may affect their tubless air-retention capability, but which perform satisfactorily when tubes are installed.

Paragraph S4.3 of Standard No. 109 specifically requires the word "tubeless" or "tube type" as appropriate. Neither the phrase "TUBE-LESS TYPE" nor the phrase "TUBE- TYPE" conform to this requirement. The labeling you suggest would therefore not conform to Standard No. 109. We would expect that any redesignation of tubeless tires as tube type would be accomplished by obliterating the tubeless label and labeling the tire "tube type", in the form required by the standard.

I would like to point out that our decision to interpret these requirements strictly results in part from our efforts to stop a practice, which is occurring in the United States, in which some tire dealers sell tires that have been relabeled as tube type while representing to customers that tubes are not needed because the tires were originally tubless. We believe labeling tires as you suggest will have the unfortunate consequence of promoting this activity, as it will make it more obvious that the tires were originally manufactured as tubeless.

Yours truly,

ATTACH.

SEMPERIT

AKTIENGESELLSCHAFT

The Director National Highway Traffic Safety Administration U.S.-Department of Transportation July 11,1973

Re: Labelling tubeless, tube type

Dear Sir,

Concerning the labelling of tyres we want to ask if it is allowed to use the word-groups

TUBE-LESS TYPE instead of tubeless

and TUBE- TYPE for tube type.

The distance between TUBE- and TYPE is about of 0,8 inches.

Sincerely,

DEPARTMENT OF TRANSPORTATION

U.S. COAST GUARD TELECOMMUNICATIONS CENTER

07/04/73

NATIONAL HIGHWAY TRAFFIC SAFETY ADMIN US DEPT OF TRANSPORTATION WASHINGTON DC ATTENTION LAWRENCE R SCHNEIDER CHIEF CONSUL WE REFER TO OUR LETTER DATED MA 9 1973 AND ASK YOU PLEASE TO GIVE US AN ANSWER THANKS IN ADVANCE STOP

ERIK SUNDELIN TRELLEBORGS GUMMIFABRIK TRELLEBORG

COASTGUARD WSH