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Interpretation ID: GF005903

    Mr. Mark Jagow
    Pacific Coast Retreaders
    333 Hegenberger Road, Suite 705
    Oakland, CA 94621-1463


    Dear Mr. Jagow:

    This is in response to your June 1, 2005, letter in which you ask about certain tire marking requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 119, New pneumatic tires for vehicles other than passenger cars. Specifically, you ask if you are required to mark the maximum single load rating on tires intended to be used exclusively in tandem. Our answer is yes.

    S6.5(d) of FMVSS No. 119 requires that the truck tires be marked on each sidewall with, among other things, the maximum load rating and corresponding inflation pressure for the particular tire. This information must be "shown as follows":

    (Mark on tires rated for single and dual load): Max load single __kg (__lb) at __kPa (__psi) cold. Max load dual __kg (__lb) at __kPa (__psi) cold.

    (Mark on tires rated only for single load): Max load __kg (__lb) at __kPa (__psi) cold.

    Different labeling requirements thus apply depending on whether tires are rated for "single and dual load" or "only for single load".We interpret this provision to require all tires to be rated and marked in one of these two manners; i.e., it is not permissible to mark tires as rated only for dual load. Thus, truck tires rated for dual load applications, including those produced solely for tandem use, must also be labeled with the maximum single load rating in addition to the dual load rating. This is because the tires intended for tandem use could nevertheless be purchased and installed in single application. We believe there is a safety benefit in informing vehicle operators who may use your tires in a way that you did not intend; i.e., in a single application, that the load ratings are different when the tires are not installed in tandem.

    I hope you find this information helpful. If you have further questions, you may contact Mr. George Feygin of my staff at (202) 366-2992.

    Sincerely,

    Stephen P. Wood
    Assistant Chief Counsel
    for Vehicle Safety Standards and Harmonization

    ref:119
    d.9/7/05