Interpretation ID: nht75-1.49

DATE: 08/25/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Pirelli Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of May 5, 1975, which inquired about the permissibility of iron-branding the letters "N.A." on the sidewall of certain passenger car tires to indicate that they are not adjustable under your warranty.

Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires -- Passenger Cars, specifies labeling and performance requirements for such tires. The NHTSA has no objection to the provision of additional labeling information such as the "N.A." which you have suggested. However, the tire must continue to be capable of meeting the standard's performance requirements at the completion of the hot-branding process.

Sincerely,

ATTACH.

May 5, 1975

Office of Chief Counsel -- N.H.T.S.A. Att: Mark Schwimmer, attorney

Sir:

In reference to the phone conversation Friday morning, I am sending you a written request for the following information:

We would like to know if there are some objections from your office to iron-brand N.A. (not adjustable) tires which may present possible vibrations, bleeding white sidewall, unbalance or which may not deliver the 40.000 mile guarantee even though they belong to a tire line which has the 40.000 mile guarantee.

The tires involved (which are approximately 5000 units) will be sold at a discount of about 50%.

Of course such tires have all the safety guarantee as the regular premium ones.

Your prompt attention to this matter will be greatly appreciated.

Sincerely, PIRELLI TIRE CORPORATION -- G. Buzzi-Ferraris, Technical Manager