Interpretation ID: nht75-2.6

DATE: 09/16/75

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

TO: Kleber Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 3, 1975, asking whether it is permissible to import into this country a tire designed exclusively for racing purposes.

Tires designed to be used exclusively on racing vehicles, i.e., vehicles other than "motor vehicles" within the meaning of the National Traffic and Motor Vehicle Safety Act, are not regulated by the Federal motor vehicle safety standards, and may be imported. The labeling that you propose to use appears to be appropriate to warn users of their intended purpose. Manufacturers of such equipment should take all reasonable steps to ensure that their products are not misused.

YOURS TRULY,

June 3, 1975

OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Attention : Marc Schwimmer

First, let me briefly describe KLEBER CORP. KLEBER CORP. is a wholly owned subsidiary of KLEBER-COLOMBES of Paris, France. We are the second largest tire manufacturer in France after MICHELIN. All our tires are of radial concept. Since the beginning of this year, we are developing a distribution network in the U.S.A. Naturally, our passenger tires conform with Federal Standard 109.

In Europe, KLEBER manufactures tires that are designed for small formula cars (i.e.: Formula Ford). These tires are to be used exclusively on racing vehicles and not on regular automobiles. They do not bear the D.O.T. engravings.

We would like to import these tires in the U.S.A. and find that our sole competitor would be a GOODYEAR tire called "G-19". The "G-19" has no D.O.T. markings but on both sidewalls the caption "FOR RACING PURPOSES ONLY - NOT FOR HIGHWAY USE" appears in 1/4 inch letters.

We would like to know if it is legal to import and sell our tires (similar to the G-19) in this country, if, like GOODYEAR, we indicate "FOR RACING PURPOSES ONLY - NOT FOR HIGHWAY USE" on both sidewalls. As additional warning, we plan to print the same text on all invoices and literature related to these type tires.

On this subject, I contacted Mr. Diehl of the D.O.T. who feels that there should be no problem but suggested we check with you.

I am at your entire disposal for any further information you may need and remain,

KLEBER CORP.

Guy A. Catherine

General Sales Manager