Interpretation ID: nht80-3.39

DATE: 08/28/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Michelin Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. John B. White Engineering Manager Technical Information Department Michelin Tire Corporation One Marcus Avenue Lake Success, New York 11042

Dear Mr. White:

In your July 30, 1980, letter you requested more information concerning the interpretation of Standard 120 (49 CFR S 571.120) set forth in my July 14, 1980, letter to you Specifically, you noted this agency's previous interpretation that Standard 120 requires the tire load range to appear on the vehicle label as part of the tire size designation required by S5.3.1. You asked if it is permissible for a vehicle manufacturer to list the tire size as either (1) 275/80R22.5 (143) (G), or (2) 275/80R22.5 (G)(143).

Neither of your listed examples would be acceptable as shown. However, alternative (2) could be used if it is modified to explain what the 143 listing means. As I stated in my July 14 interpretation of Standard 120, the purpose of that standard's labeling requirements is to provide the consumer with permanent and useful information concerning tires which can safely be used on that vehicle. As a general rule, the information can be most clearly conveyed to the consumer by following the format shown in the truck example following S5.3 in Standard 120. Minor variations of that format are permitted, provided the variations do not change or obscure the meaning of the label.

Once the necessary information has been clearly expressed in the units of measurement most familiar to the American consumer, (e.g., load range G), there is nothing confusing or misleading about expressing the load carrying capabilities in a different system of measurement, if the manufacturer clearly indicates that such is the case. Neither of your examples gives the consumer any clue that the 143 is not a part of the G load range rating. The vast majority of these consumers would have no idea that the number refers only to the ISO load index for the tire. Your first example lists 143 ahead of the letter indicating the load range, which would even further confuse the matter.

To comply with the requirements of Standard 120, a vehicle lable must list the load range (in the form of a letter) immediately following the size designation for the tire. If the manufacturer chooses, it may then list the ISO load index rating for the tire if it is clearly indicated as a separate rating. For example, the tire size shown in your example would not be confusing if it were shown on the label as follows: 275/80R22.5 (G) or (143).

Sincerely,

Signed by

Frank Berndt Chief Counsel

30 July 1980

Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration Washington, D.C. 20590

Ref: NOA-30

Dear Sir:

This is in regard to your letter of July 14, 1980 which responds to our letter of June 10, 1980 wherein we requested an interpretation of appropriate tire marking required to appear on the vehicle certification label by 49CFR Part 567.

Your response is that listing the tire on the certification label as 275/80R22.5 143/140K would not be in compliance since the load range letter (in this case G) would not be indicated.

We are therefore considering have the tire size listed as follows:

275/80R22.5(143)(G) or 275/80R22.5(G)(143)

Please advise if these are acceptable. Your quick response would be appreciated.

Yours truly,

MICHELIN TIRE CORPORATION Technical Group

John B. White Engineering Manager Technical Information Dept.

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