Interpretation ID: nht80-2.28

DATE: 04/30/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Continental Products Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

In reply refer to: NOA-30

Mr. Arnold van Ruitenbeek Vice President Continental Products Corporation 1200 Wall Street West Lyndhurst, New Jersey 07071

Dear Mr. Ruitenbeek:

This responds to your March 28, 1980, letter to this office in which you inquired about permissible markings on motorcycle tires. Specifically, you asked whether you could insert language in addition to that specified in Standard No. 119 when labeling the load rating and inflation pressure on certain tire sizes. The answer to your question is no.

Standard No. 119 (49 CFR S 571.119) specifies certain requirements which all motorcycle tires offered for sale in this country must meet. One of these provisions is the labeling requirement set forth in paragraph S6.5 of the standard. Subparagraph (d) of S6.5 requires the maximum load rating and corresponding inflation pressure to appear on the tire in the following words: "Max load lbs at psi cold." The language of the subsection is mandatory and does not permit any variations. Therefore, the insertion of the phrase "in USA and Canada," as you suggest, would mean the tire would not comply with the labeling requirement of Standard No. 119.

The reason for this strict wording requirement is to ensure that the information labeled on motorcycle tires conveys necessary safety information to the purchaser of the tire in a clear, straightforward manner that is uniform with all motorcycle tires. Adding language which suggests that the maximum load of a tire depends on the country in which the tire is being used could confuse the user of the tire. Further, it suggests that the printed maximum load is not really the maximum. Either of these results frustrates the purpose of the labeling requirement in Standard No. 119.

Sincerely,

Frank Berndt Chief Counsel

Continental Products Corporation

March 28, 1980

Mr. Steve Kratzke U.S. DEPT. OF TRANSPORTATION Nat'l. Hwy. Traffic Safety, Rm 5219 Washington, D.C. 20590

Dear Mr. Kratzke:

On three of our motorcycle tire sizes we plan to have the following inscription on the sidewall:

450H(V)17: Max Load in USA and Canada 835 lbs at 42 PSI Cold

120/90H(V)18: Max Load in USA and Canada 805 lbs at 42 PSI Cold

MT90S16: Max Load in USA and Canada 960 lbs at 42 PSI Cold

The underlined part will all be on one line on the sidewall of the tire. Besides the above information, all the other required DOT information will, of course, appear on the tire.

What sets these apart from our other sizes is the notation that this load is in USA and Canada.

We would appreciate it if you could let us know latest 4/11/80 whether or not your department has any objections.

Very truly yours,

Arnold van Ruitenbeek Vice President

AVR/sms