Interpretation ID: 13951.wkm

Richard D. Teeple, Esq.
Vice President and General Counsel
Cooper Tire & Rubber Company
Findley, OH 45840

Dear Mr. Teeple:

Please pardon the delay in responding to your letter to me of January 17, 1997, in which you asked whether you would be permitted to add "CAN REPLACE LT235/75R15 (C)" to the size markings on the sidewalls of your 30x9.50R15LT size of Mickey Thompson Baja Radial MTX light truck tires. The answer is no, the addition would not comply with Standard No. 119.

We addressed the issue of dual size markings on tires in a letter to Mr. Earl Dahl, Vice President, Goodyear Tire & Rubber Company, dated January 7, 1988, in which we quoted extensively from an interpretive letter to Michelin dated July 9, 1987 (copies enclosed). In both letters we stated that although dual-size markings were once a common practice in the industry, it confused many consumers as to the size of the tires on their vehicles. We pointed out that the purpose of Federally-required markings was to provide consumers with straightforward information for the safe use and operation of their tires. Thus, we concluded that it was "inappropriate" to permit a marketing technique that was confusing to many consumers, thereby defeating the purpose of the required tire markings.

The agency continues to adhere to those interpretations, and still believes that dual size markings on tires are inappropriate. Accordingly, your proposed markings would not comply with Standard No. 119.

We hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992, or by FAX at (202) 366-3820.

Sincerely,
John Womack
Acting Chief Counsel
Enclosures
ref:119
d:5/29/97