Interpretation ID: nht79-1.50

DATE: 11/09/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toyo Kogyo U.S.A.

TITLE: FMVSS INTERPRETATION

TEXT: This letter is in response to your October 19, 1979, request for an interpretation of the requirements of Federal Motor Vehicle Safety Standard No. 110 and 49 CFR Part 575. Specifically, you inquired if it is permissible for Mazda to place information concerning the 185SR13 tire size on the tire placard, as required by section 4.3(d) of Standard No. 110, and in the consumer information booklet, as required by 49 CFR @ 575.102(c)(2), for vehicles which may have 185HR13 tires installed by dealers at a customer's request. This would be permissible.

A 185SR13 tire and a 185HR13 tire are the same size and have the same load-carrying capacity. The "S" and "H" only denote different high-speed capabilities for what are, otherwise, identical tires.

This agency requires the manufacturer to list recommended tire sizes on the tire placard and in the consumer information booklet for two reasons. First, the information is required to ensure that any replacement tires installed on the vehicle will be a proper size for the rims mounted on that vehicle. Second, the information helps to ensure that the tires installed on the vehicle will have sufficient load-carrying capacity to be used safely on that particular vehicle. Neither of these safety concerns would be frustrated by a manufacturer putting information on the placard and in the booklet about a tire with a lower speed rating. Therefore, your proposed plan would not violate any of our consumer information regulations.

Sincerely,

ATTACH.

October 19, 1979

Chief Counsel -- National Highway Traffic Safety Administration

Dear Sir,

RE: Request for Interpretation on MVSS 110 & Part 575

MVSS 110 Sec. 4.3 (d) requires the vehicle manufacturer's recommended tire size designation on the tire placard and also Sec. 575.102 (c)(2) requires recommended tire size designations in the consumer information booklet. One of our MAZDA models has 185SR13 as the standard tires. Currently, we are considering 185HR13 as a dealer option because some customers want a higher performance tire on their cars. We do not believe that we should put 185HR13 as the recommended tire on the tire placard, for it is a higher performance than 185SR13 and it is not installed at our factory. Please grant us your interpretation.

Your earliest response would be highly appreciated.

Sincerely yours,

M. Ogata -- Branch Manager, TOYO KOGYO U.S.A. OFFICE