Interpretation ID: aiam3697
Esq.
Law Department
The Goodyear Tire & Rubber Company
Akron
OH 44316;
Dear Mr. Caine: This responds to your recent letter in which you asked for a interpretation concerning the status of tires which are manufactured by applying new tread to a new casing. Specifically, you ask whether such tires should be considered retreaded tires or new tires subject to the applicable Federal motor vehicle safety standard.; Any tires manufactured by applying new tread to new casings would b considered new tires rather than retreaded tires, and would be subject to the same requirements as any other new tires.; Standard No. 117, *Retreaded Pneumatic Tires* (49 CFR S 571.117) defines the term 'casing' as follows: 'Casing means a used tire to which additional tread may be attached for the purpose of retreading.' In the situation you described in your letter, the casing is not a used tire. It is simply a new tire which has never had any tread attached to it. That casing would not be considered a used tire until the casing and the new tread attached to it had been used on the highway and the remainder of the tread then buffed off the casing to allow the application of another new tread. Only then could the casing be considered a used tire. With the addition of the new tread, the used tire would become a retreaded one.; I would appreciate it if you would forward any factual information yo have about the proposed importing of new casings to this agency's Office of Vehicle Safety Compliance. This will help us ensure that all imported new casings with new treads attached to them are subjected to the new tire performance tests.; Sincerely, Frank Berndt, Chief Counsel