Interpretation ID: aiam2768
Dorsey Trailers
Inc.
Hickman Avenue
Elba
Alabama 36323;
Dear Mr. Devane: This responds to your telephone request of February 9, 1978, to Roge Tilton of my staff asking whether Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, requires that you mount on your vehicles only retreaded tires containing the DOT symbol.; The standard in paragraph S5.1.3 requires that after January 1, 1978 all used tires mounted on vehicles covered by the standard be manufactured in accordance with Standard No. 119 as evidenced by the symbol DOT on the sidewall. Therefore, you would not be permitted to mount used tires on your vehicles that do not contain the DOT symbol.; Retreaded tires are not used tires. Retreaded tires must comply wit all applicable Federal requirements pertaining to them. In the case of retreaded nonpassenger car tires, there are no applicable Federal standards. The DOT symbol is only marked on those tires to which a Federal standard applies. Therefore, retreaded nonpassenger car tires do not need to be marked with the DOT symbol and, in fact, should not be marked with that symbol. Retreaded nonpassenger car tires without DOT Symbols can be mounted on your vehicles in full compliance with Standard No. 120. If the tires in your possession have the DOT symbol on them, they can still be mounted on your vehicles. The tire retreader would be responsible for the misapplication of the DOT symbol to these tires.; Sincerely, Joseph J. Levin, Jr., Chief Counsel