Interpretation ID: 77-2.3

TYPE: INTERPRETATION-NHTSA

DATE: 03/29/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: U. S. Suzuki Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 23, 1977, letter asking whether three proposed labels satisfy the requirements for label identification found in Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

The National Highway Traffic Safety Administration (NHTSA) does not issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with the requirements of Standard No. 120. A review of the labels you supplied indicates that you have used a different format than illustrated in our notice of February 7, 1977 (42 Federal Register 7140). For example, the amended Standard No. 120 does not require the words "with the tires listed below" or even the word "with" before the tire size. The deletion of such superfluous words from the label requirements of Standard No. 120 resulted from comments by manufacturers, particularly motorcycle manufacturers, that unnecessary words needlessly increase the size of the label.

The example of label information shown in S5.3 of the standard is intended only as a guide to manufacturers. A manufacturer can vary the illustrated format somewhat as long as the requirements of S5.3 are satisfied. Since the additional words on your labels do not obfuscate the certification statement, the labels appear to comply with the requirements of Standard No. 120 and Part 567.

SINCERELY,

U.S. SUZUKI Motor Corporation

February 23, 1977

Office of Chief Counsel National Highway Traffic Safety Administration U. S. Department of Transportation

Having reviewed the notice published in a recent issue of the FEDERAL REGISTER covering FMVSS no. 120 we are submitting examples of our proposed certification labels for your inspection. For this purpose please see attachment. We believe that any of these three proposals meet the requirements of 49 CFR ss571.120 S5.3 (label information) as amended.

Since the notice cited above did not address motorcycle certification labels specifically (the notice gave an example for trucks) we felt it is important that we have some clarification on this subject. The effective date, September 1, 1977, is fast approaching. Your response will be greatly appreciated.

Jeffrey L. Link Supervisor, Product Safety Safety and Legislation Department

MFD BY: SUZUKI MOTOR CO., LTD MFD IN: (Illegible Word)/76 THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE. GVWR 847 LBS WITH THE TIRES LISTED BELOW GAWR/FRONT 315 LBS WITH 3.25H19-4PR TIRES, 19X1.85B RIM AT 18PSI COLD. GAWR/REAR 532 LBS WITH 4.00H18-4PR TIRES, V.I.N. (Illegible Word) 18X2.15B RIM AT 25PSI COLD. GT750-(Illegible Word) MOTORCYCLE MADE IN JAPAN

MFD BY: SUZUKI MOTOR CO., LTD

MFD IN: (Illegible Word)/76

GVWR 847 LBS WITH THE TIRES LISTED BELOW GAWR/FRONT 315 LBS WITH 3.25H19-4PR TIRES, 19X1.85B RIM AT 18 PSI COLD. GAWR/REAR 532 LBS. WITH 4.00H18-4PR TIRES, 18X2.15B RIM AT 25 PSI COLD. THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE. V.I.N. GT750 (Illegible Word) MOTORCYCLE MADE IN JAPAN

MFD BY: SUZUKI MOTOR CO., LTD MFD IN: (Illegible Word)/76 GVWR 847 LBS WITH THE TIRES LISTED BELOW GAWR/FRONT 315 LBS WITH 3.25H19-4PR TIRES, 19X1.85B RIM AT 18 PSI COLD. GAWR/REAR 532 LBS WITH 4.00H18-4PR TIRES, 18X2.15B RIM AT 25 PSI COLD. THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE. V.I.N. (Illegible Word) GT750 - (Illegible Word) MOTORCYCLE MADE IN JAPAN