Interpretation ID: nht75-2.18

DATE: 09/22/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bridgestone Tire Company of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of May 22, 1975, concerning truck tires which do nt conform to Federal Motor Vehicle Safety Standard No. 119 and which are intended for export to Middle Eastern and African countries.

49 CFR Part 571.7(d) and Section 108(b)(5) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, specify that no Federal Motor Vehicle Safety Standards apply to

a motor vehicle or item of motor vehicle equipment intended solely for export, and so labeled or tagged on the vehicle or item itself and on the outside of the container, if any, which is exported.

Therefore, tires which you manufacture for sale directly to a truck manufacturer who will mount them on trucks which will be driven directly to the port of export need not comply with Standard No. 119. When shipped to the truck manufacturer, the tires must bear a label or tag indicating intent to export. Such a label must also appear on the outside of the container, if any, in which the tires are shipped. A label need not remain on the tires after they have been mounted on the trucks, provided that the trucks bear similar labels.

Sincerely,

ATTACH.

BRIDGESTONE TIRE COMPANY OF AMERICA. INC.

May 22, 1975 Ref. No.: YT-926

Office of the Chief Counsel -- National Hwy. Traffic Safety Admin.

Subject: FMVSS No. 119

Dear Sir:

We have an inquiry on the following size tires to be equipped on new trucks for exporting to the Middle Eastern and African countries by a truck manufacturer: 400-500 1100-20 14PR 150-200 1100-22 14PR 400-500 1100-24 14PR

Since the tire usage condition in these countries is completely different from that of the U.S.A., we have been supplying specially designed tires to them which do not comply with the FMVSS No. 119.

Therefore, we would like to supply the same type of tires now being supplied to the Middle Eastern and African countries to the truck manufacturer strictly for export.

In such a case, will you adopt an exception to FMVSS No. 119 on those tires?

The trucks will be driven without cargo to the ports of Newark or Baltimore after manufacture in Allentown, Pennsylvania.

I would greatly appreciate a reply regarding this matter, as soon as possible.

Very truly yours,

Y. Toyoda -- Manager, Engineering Dept.

CC: M. Otsubo - T. Sato; 734-Tokyo; S. Nakajima-File