Interpretation ID: nht87-3.16

TYPE: INTERPRETATION-NHTSA

DATE: OCTOBER 20, 1987

FROM: T. J. BROWN -- GENERAL MGR., PRODUCT SERVICES, MOHAWK TIRE COMPANY

TO: ERIKA Z. ZONES -- CHIEF COUNSEL, NHTSA

ATTACHMT: 11/23/88 letter from Erika Z. Jones to T.J. Brown (A33; Std. 109)

TEXT: The Mohawk Rubber Company is in the process of purchasing for resale, a group of metric size tires from a manufacturer in the Far East. It has come to our attention that the maximum load and maximum pressures molded on the sidewalls of the tires are ind icated in kilograms and kilopascals only without any indication of the maximum pounds and PSI pressure.

After reviewing MVSS #109, it is not clear as to whether or not these tires are in compliance with the standard and the purpose of this letter is to request your interpretation or ruling in this matter.

The actual stamping on the tires is indicated as follows: Size 165SR15 Load Range B Maximum Load 530kgs - Maximum Pressure 230KPA 185SR14 Load Range B Maximum Load 600kgs - Maximum Pressure 230KPA 175SR14 Load Range B Maximum Load 560kgs - Maximum Pressure 230KPA 165SR13 Load Range B Maxim um Load 475kgs - Maximum Pressure 230KPA 155SR13 Load Range B Maximum Load 420kgs - Maximum Pressure 220KPA

According to the European Tire and Rim Technical Organization, the loads and pressures are correctly designated on these tires, however, we do question if the omission of the load designation and pressure in pounds prohibits them being sold in the U.S .A.

We will appreciate your response to our request for a ruling in this matter.