Interpretation ID: nht88-2.36

TYPE: INTERPRETATION-NHTSA

DATE: 05/31/88 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: GARRY GALLAGHER -- VICE PRESIDENT, METZELER MOTORCYCLE TIRE

TITLE: NONE

ATTACHMT: FEBRUARY 11, 1988 LETTER FROM GALLAGHER TO COOK IS ATTACHED

TEXT: I am writing in response to your letter of February 11, 1988 that requested "written confirmation and approval" to add the word "reinforced" to the sidewall of the Metzeler Motorcycle ME88 Marathon model motorcycle tire. As discussed below, it is our op inion that Federal Motor Vehicle Safety Standard 119 does not prohibit the addition of the word "reinforced."

It is important to note that the National Highway Traffic Safety Administration does not approve motor vehicles or motor vehicle equipment, nor do we endorse commercial products. Instead, the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S .C. 1381 et seq.) establishes a "self certification" process under which each manufacturer is required to certify that its products meet all applicable safety standards. The Act prohibits the manufacture or sale of a noncomplying product.

Standard No. 119; New pneumatic tires for vehicles other than passenger cars establishes performance and marking requirements for tires for use on multipurpose passenger vehicles, trucks, buses, trailers, and motorcycles. Paragraph S6.5 of Standard No. 1 19 requires that certain information be labeled on the sidewalls of each tire subject to this standard. The agency has frequently stated in past interpretations that the purpose of these labeling requirements is to provide the consumer, in a clear and s traightforward manner, with technical information necessary for the safe use of the tires. Standard No. 119 permits tire manufacturers to label additional information on the sidewall on the tires, provided that the additional information does not obscur e or confuse the meaning of the required information, or otherwise defeat its purpose. Assuming that the addition of the word "reinforced" is not made in such a way that it obscures or confuses the meaning of the required information, Standard No. 119 d oes not prohibit the addition of the word "reinforced" to the motorcycle tire sidewall.

I hope the information provided above will be useful to you and to Metzeler Motorcycle Tire. If there are any further questions or if you need more information, please do not hesitate to write to me.