Interpretation ID: nht72-1.21

DATE: 12/15/72

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: The General Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 8, 1972, inquiring whether new casings, to which tread is later added, are considered to be "tires" under the National Traffic and Motor Vehicle Safety Act. The NHTSA has taken the position that such casings are not tires until after the tread has been added, and the casings are not required to be certified as conforming to applicable standards until that occurs. Consequently, such casings may be imported without prior certification.

You also ask how best to inform Customs of our position, to avoid possible importation problems. We suggest you write to Mr. P. K. McCarthy, Chief, Restrictive Merchandise Branch, U. S. Bureau of Customs, Room 704C, 1145 19th Street, N.W., Washington, D. C. 20226, advising him of our opinion, and ask him to acknowledge this interpretation. You might also take steps to ensure that this information is relayed to the local customs officials at those ports of entry where the casings will be imported. If you need further assistance in this matter, please let me know.