NHTSA Grants Michelin Petition on Mislabeled Spare Tire Inflation Pressure Markings

The Noncompliance

Michelin North America, Inc. (MNA) determined that certain Michelin TEX T195/65R22 T-type spare tires do not fully comply with paragraph S4.3(b) of Federal Motor Vehicle Safety Standard (FMVSS) No. 109, New Pneumatic Tires for Vehicles Manufactured from 1949 to 1975, Bias Ply Tires, and T-Type Spare Tires (49 CFR 571.109). Approximately 532 of the affected tires, manufactured between September 26, 2023, and March 6, 2024, were sold into the U.S. market as original equipment manufacturer (OEM) spares.

The relevant rule requirement, paragraph S4.3(b) of FMVSS No. 109, specifies that each tire must have the maximum permissible inflation pressure permanently molded onto or into both sidewalls. For T-type spare tires with a maximum inflation pressure of 420 kPa (60 psi), an additional marking stating "Inflate to 420 kPa (60 psi)" is also required on both sidewalls in a prominent location with a large font size — meaning the subject tires are required to carry the maximum inflation pressure in four distinct locations in total.

The specific noncompliance is that the subject tires incorrectly state the maximum permissible inflation pressure in one location on each sidewall. The tire markings show an incorrect pressure of 350 kPa (51 psi), instead of the correct 420 kPa (60 psi), in one of the two required locations on each sidewall.

Discovery, Reporting, and Remedy

According to MNA's petition, the noncompliance was discovered when Indian authorities detected the marking error during a certification inspection and alerted Michelin Europe. European Original Equipment Quality then notified North American Original Equipment Quality that some Range Rovers equipped with the affected spare tires may have been shipped to the U.S. MNA reports that it blocked 506 affected tires at the Nyiregyhaza, Hungary manufacturing facility, and confirmed that 532 tires had entered the U.S. market. MNA further reports that production of the affected tires was suspended within 24 hours of detecting the noncompliance, and that molds with corrected markings were put into production on March 25, 2024.

MNA filed a noncompliance report on May 1, 2024, pursuant to 49 CFR part 573, and subsequently petitioned NHTSA on May 29, 2024, for an exemption from the notification and remedy requirements of 49 U.S.C. Chapter 301, on the basis that the noncompliance is inconsequential to motor vehicle safety, pursuant to 49 U.S.C. 30118(d) and 30120(h) and 49 CFR part 556. Notice of receipt of MNA's petition was published with a 30-day public comment period on December 13, 2024, in the Federal Register (89 FR 101093). No public comments were received.

MNA's Safety Arguments

In its petition, MNA contends that several factors reduce the likelihood that the incorrect pressure marking would result in a safety consequence. MNA explains that the incorrect maximum permissible inflation pressure marking is inconsistent with the correct sidewall marking — "Inflate to 420 kPa (60 psi)" — which is present and correctly marked in two locations on the tire pursuant to paragraph S4.3.5 of FMVSS No. 109. MNA also notes that tires are inflated to the correct pressure at the wheel mounting facility, removing the need for dealers to determine which pressure to follow, and that the vehicle placard specifies 420 kPa (60 psi). Additionally, the most prominent spare tire sidewall marking, required by paragraph S4.5 of FMVSS No. 109, specifies 420 kPa (60 psi), which end users would encounter during a recommended monthly pressure check.

MNA further reports that testing confirmed the subject tires fully comply with all applicable FMVSS tire safety performance standards, including endurance, high speed performance, bead unseating, and tire strength. FMVSS No. 109 performance testing was conducted and confirmed that the tires passed under the specified conditions for both of the maximum inflation pressures marked on the tires — 350 kPa (51 psi) and 420 kPa (60 psi).

Agency Decision

NHTSA granted MNA's petition, announcing that the noncompliance is inconsequential as it relates to motor vehicle safety. The docket for this matter — NHTSA-2024-0049 — is available through the Federal Docket Management System at regulations.gov.

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