Interpretation ID: nht79-4.18

DATE: 07/05/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Subaru of America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 4, 1979, concerning Subaru's obligation to provide to prospective motor vehicle purchasers an explanation of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104(d)(1)(ii)). You ask whether Subaru must provide UTQG information to prospective purchasers prior to April 1, 1980, in view of the fact that all motor vehicles sold by your company are equipped with radial tires.

With respect to radial tires, the effective date for all requirements of the UTQG regulation, other than the molding requirement of paragraph (d)(1)(i)(A) and the first purchaser requirement of paragraph (d)(1)(iii), is April 1, 1980. Therefore, manufacturers, such as Subaru, which offer for sale only motor vehicles equipped with radial tires, need not provide UTQG information for examination by prospective purchasers prior to April 1, 1980.

Sincerely,

ATTACH.

June 4, 1979

Richard J. Hipolit -- National Highway Traffic Safety Administration

Dear Mr. Hipolit:

In our telephone conversation on Friday, June 1, you confirmed my interpretation of the requirement for the date of publication of "Tire Quality Grading Information" for our prospective purchasers is dependent upon the effective date of the regulation. As we only use radial tires, the grading regulation effective date for which is April 1, 1980, our obligation to issue information to prospective purchasers is also April 1, 1980.

If this is still your opinion will you please confirm this in writing?

Thank you.

Yours very truly,

SUBARU OF AMERICA, INC.;

D. J. Schrum -- Manager Product Compliance