Interpretation ID: aiam1410
Mercedes-Benz of No. America
One Mercedes Drive
Montvale
New Jersey 07645;
Dear Mr. Gerth: This is in reply to your letter of December 11, 1973, asking whethe each of the following tire labeling formats used by the Michelin Tire Corporation complies with Motor Vehicle Safety Standard NO. 109:; 1. '2 steel tread plies/ 2 rayon body plies', 2. 'max. load 1,310 lbs at 36 psi max press.' We find that the first label format fails to conform to the standard Paragraph S4.3(e) requires the tire to be labeled with, 'the actual number of plies in the sidewall, and the actual number of plies in the tread area, if different.' The labeling format used by Michelin creates the impression, contrary to the stated requirements, that the number of plies in the sidewall and the tread area is the same. *viz.* '2'. We consider the body plies, running from bead to bead and lying under the plies in the tread area, to be counted also as plies in the tread area. Thus, the number of plies in the tread area is '4', 2 steel and 2 rayon. Moreover, while we understand the words 'body plies' to be essentially synonymous with 'sidewall plies', we fell there is little justification for departing from the word of the standard, which uses the word 'sidewall' in referring to plies.; We find the second labeling format, that dealing with maximu permissible inflation pressure and maximum load rating, to conform to Standard No. 109. The words 'permissible,' 'inflation,' and 'rating' are not essential to conformity as long as the appropriate values, clearly identified, are provided.; For your information, I point out that NHTSA test laboratories ar without authority to interpret Federal motor vehicle safety standards or provide such interpretations to companies whose products they test. Only interpretations issued in the form of correspondence signed by authorized NHTSA personnel or by notice published in the *Federal Register* are considered by this agency to be binding.; Sincerely, Lawrence R. Schneider, Chief Counsel