Interpretation ID: nht88-1.100

TYPE: INTERPRETATION-NHTSA

DATE: 04/18/88

FROM: GARY M. CEAZAN -- RIKEN AMERICA, INC.

TO: U.S. DEPARTMENT OF TRANSPORTATION Attn: Tire Division

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO GARY M CEAZAN; REDBOOK A32, STANDARD 109, 119; LETTER DATED 02/16/88 FROM ERIKA Z JONES TO MIKE KAIZAKI; STANDARD 119; UNDATED LETTER FROM ERIKA Z JONES TO E.W. DAHL

TEXT: Dear Commissioner:

Riken-America, Inc. is the importer, and national distributor, of Riken Tires for the United States. Riken Tires are manufactured in Japan by Okamoto Industries, Inc., Tokyo, Japan (D.O.T. Code No. ED).

The purpose of this letter is to obtain from your office a ruling on the following question:

...If a tire carries both the E.T.R.T.O. and the I.S.O. size markings, would this tire be considered by U.S. -- D.O.T. as a dual sized tire; and, therefore, not allowed to be sold in the United States?

Specifically, Okamoto Industries, Inc. is currently producing a line of metric size radial tires for sales in both Europe and Japan and both the E.T.R.T.O. and the I.S.O. size markings appear on the tires, at different locations, for example, the size marking 165/80R13 (I.S.O.) appears mid-way on the sidwall, and the size marking, 165R13 (E.T.R.T.O.) appears above the bead (see attached sketch).

Please advise if these tires could be imported into the United States with the size markings mentioned above. You may write to me at Riken-America, Inc., P. O. Box 3698 Terminal Annex, Los Angeles, California 90051, or telephone me at 1 (800) 421-1838. Thank you for your consideration of and response to this inquiry.