Interpretation ID: nht81-2.39

DATE: 06/25/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Japan Automobile Tire Manufacturers Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent request for an interpretation of the labeling requirements of Safety Standard No. 109 (49 CFR @ 571.109). Specifically, your association wants to know if Standard 109 permits tire manufacturers to include the letters "H," "S," or "V," as appropriate, in the tire size designation required to appear on the sidewall of passenger car tires by S4.3(a) of the Standard.

Such labeling is permitted by Standard 109. The speed rating symbols ("H," "S," or "V") established by the European Tyre and Rim Technical Organization, indicate that a tire is an acceptable high-speed tire. This permits, for example, a knowledgeable purchaser of tires for emergency vehicles to know that these tires are suitable for the higher operational speeds necessary for those vehicles. Use of these symbols in the size designation would not likely confuse the less sophisticated consumer, or otherwise defeat the purpose of the labeling information. Accordingly, use of these symbols is permitted under Standard 109.

If you have any further questions, or need further information on this matter, please feel free to contact Steve Kratzke of my staff (202-426-2992).