Interpretation ID: aiam3735
Vice President
Continental Products Corporation
1200 Wall Street West
Lyndhurst
NJ 07071;
Dear Mr. van Ruitenbeek: This responds to your recent letter asking for an interpretatio concerning Safety Standard No. 119, *New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars*. Specifically, you asked whether your company could label two maximum load ratings on the sidewall of certain motorcycle tires it manufactures. One maximum load rating would be applicable at the tire's top-rated speed, while the other would be applicable at a speed of 60 miles per hour. Such labeling would violate Standard No. 119.; Section S6.5 of Standard No. 119 requires that certain information b labeled on the sidewall of all tires to which the standard applies. Section S6.5 requires the maximum load rating and corresponding inflation pressure to appear on all motorcycle tires, shown as follows:; >>>Max load _____ lbs at _____ psi cold.<<< The maximum rating on the tire's sidewall, as the name implies, i intended to alert the consumer to the tire's *maximum* capabilities. Allowing tire manufacturers to specify more than one maximum load, based on various vehicle speeds, would dilute the value of the maximum load information to the consumer, by introducing the possibility of confusion and uncertainty about the actual *maximum* load the tire could carry while in use on a particular trip. To avoid this, the agency has stated on each occasion when questions have arisen in this area that only one maximum load rating may appear on the sidewall of tires.; Please understand that the agency does not doubt that these tires ca carry higher loads at lower speeds. Further, it does not have any objection to your publicizing those loads in your advertising literature, which you enclosed with your letter. However, the purpose of the labeling requirements on the sidewall of tires is not to give the consumer information for all possible operating conditions of the tire. Indeed, there is not enough space on the sidewall of the tire to do this. The purpose of the labeling requirements is to provide the consumer, in a straightforward manner, with technical information necessary for the safe use of the tires. In the case of the maximum load information, this necessitates providing only one maximum load rating on the sidewall of the tires.; Sincerely, Frank Berndt, Chief Counsel