Interpretation ID: 3238o

Mr. Garry Gallagher
Vice President
Metzeler Motorcycle Tire
4520 107th SW
Everett, WA 98204

Dear Mr. Gallagher:

This responds to your letter seeking an interpretation of Standard No. 119, New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR /571.119). More specifically, you asked whether the letter "B" must appear as part of the size designation of a motorcycle tire if that tire is of bias belted construction. The answer to your question is no.

As you noted in your letter, section S6.5 of Standard No. 119 sets forth the marking requirements for tires used on motor vehicles other than passenger cars, including tires for use on motorcycles. Subsection S6.5(c) states that each such tire shall be marked with "The tire size designation as listed in the documents and publications designated in S5.1." Section S5.1, in turn, specifies tire and rim matching information that must be provided to the public. Generally speaking, the size designation of a tire shows only the physical dimensions of that tire, not necessarily its construction. Thus, the common meaning of the term "size designation" does not necessarily include an indication of the tire's construction type. Further, no provision of Standard No. 119 requires a tire's size designation to indicate the tire's construction type. The only reference in section S6.5 of Standard No. 119 to a tire's construction type is in subsection S6.5(i), which requires the word "radial" to appear on the tire's sidewall if the tire is of radial construction. Therefore, in response to your question, Standard No. 119 does not require the letter "B" to be included in the size designation of bias belted motorcycle tires.

You noted that your company sometimes adds the letter "B" to the size designation of these tires as an internal code. NHTSA has long said that manufacturers are free to include additional information on the sidewall of their tires, provided that the additional information does not obscure or confuse the meaning of the required information, or otherwise defeat the purpose of the required information. In this case, the addition of the letter "B" to the size designation would not appear to confuse or obscure the meaning of the size designation. Hence, there would be no apparent violation of Standard No. 119 by including the letter "B" in the size designation of bias belted motorcycle tires.

If you have any further questions or need additional information on this subject, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Erika Z. Jones Chief Counsel

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