Interpretation ID: nht75-1.50

DATE: 11/18/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Tong Shin Chemical Products Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your inquiry concerning the addition of the symbol "DOT" to tires imported into this country, and in confirmation of your telephone conversation with Mr. Schwartz of this office.

49 CFR Part 574, Tire Identification and Recordkeeping, requires tire manufacturers to permanently mold into or onto the sidewall of tires an identification number and the symbol DOT. The position of the identification number and DOT symbol is illustrated in Figures 1 and 2 of the Regulation. The symbol DOT, as stated in Motor Vehicle Safety Standard No. 109, New Pneumatic Tires, 49 CFR 571.109, constitutes a certification that the tire conforms to all applicable safety standards.

Neither Standard No. 109 nor Part 574 prohibit the branding of the symbol DOT onto the tire after manufacture, as long as the information becomes part of the actual sidewall material. By branding the symbol DOT onto the tire you are certifying that the tires meet all the requirements of the motor vehicle safety standards based on information which, in the exercise of due care, you know to be accurate.

If you have further questions concerning this matter, please do not hesitate to contact me.