Interpretation ID: nht74-2.39

DATE: 03/18/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Continental Gummu-Werke

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 29, 1974, raising certain questions about the effective date (September 1, 1974) of the Uniform Tire Quality Grading regulation. You pose two hypothetical questions, asking whether tires must be quality graded when they are to be placed on vehicles manufactured or imported after September 1, 1974. In the first situation, the tires are manufactured in July 1974, while the vehicle is manufactured in August 1974 and imported in October 1974. In the second, the tires are manufactured in August 1974; the vehicle is manufactured in September 1974 and imported in November 1974.

The Quality Grading regulation applies to tires rather than vehicles. Its effective date of September 1, 1974, means that all passenger-car tires manufactured on or after that date must be graded in accordance with the regulation. There is no requirement, however, that vehicle manufacturers must use tires manufactured after that date. In each hypothetical question you present, the tires are manufactured before September 1, 1974, and therefore are not required to be graded. The date of manufacture or importation of the vehicle is immaterial.

Yours truly,

ATTACH.

Our Ref.: 61011-Ga-gs

January 29, 1974

Subject: U.T.Q.G. - Docket 25 Notice 7

Gentlemen:

As you know, the tire industry is faced with considerable difficulties in adhering to the date set, i.e. September 1, 1974.

This applies in particular to tires we supply to European vehicle manufacturers whose passenger car production is partly shipped to the United States.

Tires for such vehicles which arrive for instance in the United States in September 1974, have to be manufactured by us already in June. Therefore, your interpretation of paragraph 575.4a, reading as under, is very important for us:

". . . . . . . each section set forth in Support B of this Part applies according to its terms to motorvehicles and tires manufactured after the eff. date indicated, . . . . .".

To clarify matters, please permit us to put up for discussion the following two possibilities: Case Production Date Date of Import No. Tires Car of the Cars into USA 1 July 1974 August 1974 October 1974 2 August 1974 September 1974 November 1974

We would be very much obliged if you would inform us as to whether the tires of the vehicles in the above two cases have also to be provided with the statutory U.T.Q.G. marking.

Looking forward to hearing from you, we remain

Yours very truly, Continental Gummi-Werke Aktiengesellschaft; NEBE; (Illegible Word)