Interpretation ID: nht75-4.16

DATE: 11/10/75

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

TO: Mountain States Tires Dealers Association

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of May 1, 1975, which included a list of information items you believe are required to appear on retreaded tires pursuant to Federal Motor Vehicle Safety Standard No. 117, Retreaded Pneumatic Tires.

With the following qualifications, your list is correct:

1. The tire must be labeled with the symbol "DOT" followed by the letter "R", and other information required by 49 CFR Part 574.5, Tire Identification and Recordkeeping, as a certification that the tire complies with Standard No. 117. This requirement is distinct from and in addition to the requirement that the casing retain the "DOT" symbol from its original manufacture.

2. The words "bias/belted" are not required, because the actual number of plies in the sidewall and, if different, in the tread area, are now required to appear.

3. Tube-type and tubeless tires must be labeled with the specific words "tube-type" and "tubeless", respectively.

4. The items listed in your third group may appear on a paper label only if that label is not easily removable.

For your convenience, I have enclosed a copy of Standard No. 117.

YOURS TRULY,

MOUNTAIN STATES TIRE DEALERS ASSOCIATION

May 1, 1975

U.S. Department of Transportation National Highway Traffic Safety Administration

From various sources, it is our understanding that after May 12, 1975, the following requirements must be met in retreading passenger car tires:

To be processed the casing must have on it from the original manufacturer

The symbol "DOT"

The tire size

Number of plies or ply rating

The completed retread must be permanently marked in at least one location with letters of a minimum of .078 inches high with the following:

Maximum Load

Actual number of plies in sidewall and tread, if different

Name of cord in sidewall and in tread area if different

The completed retread must also have this information on it, either with a permanent label, paper label or retained on the casing:

Size

Tube or Tubeless

Mamimum Inflation

Bias belted or Radial

Please advise us as soon as possible if the above information is correct so that we may have current, proper and accurate information for our members.

Claud Riggs, Exec. Secy.