Interpretation ID: nht95-1.36

TYPE: INTERPRETATION-NHTSA

DATE: January 25, 1995

FROM: Stuart Sacks -- TRADEPRO, INC.

TO: Philip R. Recht, Esq. -- Chief Legal Council, U.S. DEPARTMENT OF TRANSPORTATION, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/25/95 LETTER FROM JOHN WOMACK TO STUART SACKS (A43; STD. 119 PART 574)

TEXT: Dear Mr. Recht:

We are requesting a further interpretation of the Federal Motor Vehicle Standard 119, part 119 S-6.5.

We are considering the immediate possibility of importing tires from The Hangzhou General Rubber Factory, which holds the D.O.T. identification number 7D.

While Standard 109 for passenger tires (Section S-4.3) requires molded D.O.T. code numbers, Standard 119 clearly does not require this for non-passenger tires.

The tires that we are interested in importing from the above factory do not have molded code numbers and the cost of altering these existing molds is prohibitive.

Please respond at your earliest possible convenience so that we might proceed with this matter in full compliance with current regulations.