Interpretation ID: aiam2552
P.O. Box 124
Pompano Beach
Florida 33061;
Dear Mr. Schellhase: This responds to your February 17, 1977, letter inquiring whether yo may inlay whitewall ring on black tires. You state that in the process a groove is cut around the tire and a white compound is inserted into the groove.; Assuming that you are discussing applying this process to new passenge car tires, whether the process is permissible depends upon whether or not it adversely affects the tire's compliance with Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires*, which prescribes performance requirements for all passenger car tires sold in the United States. A copy of the standard is enclosed.; If after using the process the tire will not comply with Standard No 109, the use of the process is prohibited, and its use can result in the imposition of civil penalties of up to $1,000 per tire and of other sanctions as well (15 U.S.C. 1397(a) (1), 1398, 1399). In addition, it is the responsibility of the one who wishes to use the process to determine whether it will cause the tires to fail the standard.; Sincerely, Frank A. Berndt, Acting Chief Counsel