Is it the Beginning of the End for the Regs No One Wanted?
Uniform Tire Quality Grading's 35th birthday passed without fanfare last September. Given its twisted history and questionable pedigree, it's not surprising that there were no parties.
From the outset, UTQG was literally and figuratively a bastard law. Born out of misunderstood language in a last-minute amendment to a bill, other than some consumer activists, no one really wanted it - not the government, not the tiremakers and not dealers. And no one had a clue how to make it work. Even the father of UTQG later said it was a bad idea.
Yet 35-plus years later, we still have UTQG. And consumers, dealers and even some tire companies remain confused how UTQG can and should be used so consumers can "make an educated purchase," as the regulation states.
The tire dealers we spoke with don't see any need for UTQG to reach its next birthday. Even though tire companies say UTQG has been rendered meaningless by vastly improved tire technology and mileage warranties, they are reluctant to talk about UTQG. Some of them - manufacturers and private branders alike - chose to not participate in this story, and those that did agreed to comment anonymously, lest they draw the ire of NHTSA.
Consumers Union, publisher of Consumer Reports, is somewhat ambivalent about UTQG. CU still insists that some type of performance (not "quality") grading system would benefit tire shoppers, but admits there are many flaws in the current UTQG system. "UTQG has provided some benefit as a comparative tool," said a CU official, "but it is not intuitive, making it difficult to understand and use correctly."
One tire company said UTQG has served its intended purpose, and has also failed. "In that its purpose is to give consumers a yardstick to compare the relative treadwear, traction and temperature grades for a given tire against those of another, UTQG has done its job. But it lacks a link to actual on-road performance."
Still another tire company questions the legitimacy of the grades. "There has been no uniform application of the regulation across different manufacturers' products. While tires will likely achieve their stated grades, they will be labeled according to the position of that product in a particular manufacturer's line."
In other words, UTQG is all about marketing.
Treadwear - a tire's expected service life - is probably a consumer's most critical concern. Yet it is the one aspect of UTQG that comes under the most fire. Tiremakers themselves are expected to conduct all UTQG testing and assign grades. And while there is well-established test criteria, there is little or no government monitoring.
These factors have led to a hodge-podge of contradictory results. For example: One tiremaker's 400 treadwear grade earns only a 40,000-mile warranty, while another's 400-level tire carries a 60,000-mile warranty.
These discrepancies (see chart) have left consumers, dealers and even the tire producers confused. But it has been these same mileage warranties that put a huge hole in the sidewall of UTQG.
"Mileage warranties provide a better indication of expected tread life than the UTQG treadwear grade," said one tire company. "And many tires now feature a speed symbol on the sidewall that indicates the maximum speed at which the tire can be operated. This information is easier for a customer to relate to than UTQG grades."
What is eerily ironic is that the UTQG system came about as part of the same legislation that created the tire safety standards the TREAD Act is poised to supplant. And early critics repeatedly said that there was no reason for a quality grading system if the government was already going to address tire safety.
Today, with new TREAD Act-induced safety and testing standards on the horizon, one must again ask the question: Do we need UTQG? Do we still need a confusing system to assign a "quality" grade based on treadwear, traction and temperature, or do we need to consider real-world performance measurements?
What Is UTQG Exactly?
UTQG grades, rather, are supposed to give consumers a way to compare models from the same manufacturer - the good to the better to the best.
According to NHTSA's Web site, UTQG's "treadwear grade is a comparative rating based on the wear rate of the tire when tested under controlled conditions on a specified government test course. For example: a tire graded 150 would wear one and a half times as well on the government course as a tire graded 100."
To its credit, NHTSA cautions that a tire's actual treadwear may vary based on the "actual conditions of their use."
Traction grades (AA, A, B and C) "represent the tire's ability to stop on wet pavement as measured under controlled conditions on specified government test surfaces of asphalt and concrete. A tire marked 'C' may have poor traction performance." Traction grading does not include cornering.
"The temperature grades (A, B and C) represent the tire's resistance to the generation of heat and its ability to dissipate heat when tested under controlled conditions on a specified indoor laboratory test wheel," says NHTSA. "The grade 'C' corresponds to a level of performance which all passenger car tires must meet under the FMVSS 109."Those Confusing & Contradictory Grades
Treadwear Grades Compared to Stated Warranties
NOTE: Numbers next to brand types indicate tires from same manufacturer or marketer. All information gathered from tire company literature. For the most part, according to Tire Review research, tire dealers feels the current UTQG system is seriously flawed: 54.7% say UTQG should allow for realistic comparisons between brands and lines, and another 14.7% feel UTQG should just go away altogether.
Is It Still Valid?
Dealers say 34.7% of their customers rarely, if ever, even ask about UTQG ratings, and 18% of customers don't understand or don't care about them at all. However, 21.5% of customers, say dealers, do use UTQG rating in their tire purchase decision, though 25.5% erroneously try to use the ratings to compare multiple brands and lines.
When the very first UTQG ratings were release by NHTSA in April 1979, Tire Review published the complete rundown of grades by brand and manufacturer. The list included bias and bias-ply tires only; radials weren't subjected to UTQG testing until 1980.
In looking at the grade list, it is obvious there was a lot of sandbagging going on, and that consumers were justified in being concerned about the performance of their tires. Of the 366 major and private brands lines listed, only 80, or 21.9%, had a treadwear rating at 100 or above; according to NHTSA a 100 was the "control" rating, basically the bogey against which all tires were judged.
The highest treadwear rating - 140 - was attained by three private brands: Formula Super Stock 50, M&H Racemaster 50, and Pos-A-Traction Torque Twister 50, all produced by Armstrong. Yet Armstrong's own branded lines didn't grade above 100.
Times have certainly changed, but not some of the "rules." By today's standards, a tire carrying a 100 rating wouldn't even be suited for a lawnmower. On average, today's radials rate around 400 for treadwear, with numerous all-season lines rating as high as 800.
But, just as in 1979, major brand lines tend to carry lower treadwear ratings than private brands - a point disputed by some of the tire companies we spoke with. Tire Review randomly compared major and private brand UTQG grades against the mileage warranties each company offered. In every case, where the mileage warranty was the same, the private brand tire had a higher UTQG rating.
"Some of the rating differences are probably due to different marketing philosophies," said one tire company. "The majors have to worry about lining up their products lines in a logical fashion, and the private branders don't have the brand names or advertising to promote their products.
"The fallacy of UTQG is the differences you see from one manufacturer when you have two 400-rated tires, one with a 60,000-mile warranty and another with a 40,000-mile warranty. Or when you have two manufacturers with 400-rated tires with vastly different mileage warranties. They're both right, but who is wrong?"
Everybody and nobody. But the consumer remains confused.
UTQG's Twisted History
Back in those pre-radial days, 20,000 miles of tread life was the exception, not the rule, and that meant many consumers faced buying at least one set of new tires each year. Weary consumers had to pick through hundreds of tire brands, multiple types and often-outlandish advertising that threw around words like "safety" and "premium".
In those days, so-called "100-level" or "first line" tires were considered to be the "better" in "good, better, best." But one brand's 100-level was another brand's 140, or 80, or who really knew what. Loud voter complaints about deceptive tire advertising and inconsistent products got Congress' attention.
The Federal Trade Commission got involved and handled the advertising complaints. The RMA voluntarily instituted minimum safety standards for tires, including carcass strength, high-speed performance and load endurance. Those two actions took a lot of the sting out of the anticipated Congressional action.
When S.B. 2669 (which became the Motor Vehicle Safety Act) came to the full Senate for a vote in early 1966, the 34-page bill didn't even suggest any kind of tire grading system. It merely "authorized" the DOT to develop vehicle safety standards (the tire portions of which eventually became FMVSS 109 and 110).
Wisconsin Senator Gaylord Nelson, who took up the tire grading cause two years earlier, tacked an amendment to S.B. 2669 that created UTQG. Nelson was bolstered by what proved to be a woeful underestimation in a Nader-backed tire grading study. The study said tire grading was "probably technically feasible," yet its author later admitted he had no idea tiremakers would have to test every single line they produced.
In a vivid example of how one word can make all the difference in the world, Nelson's amendment did not "authorize" the DOT to begin addressing the issue, it "required" a tire quality grading system be in place within two years. Senators voted in favor of the amended bill, thinking Nelson's addition called only for a two-year feasibility study and not a full-blown regulation.
The Motor Vehicle Safety Act of 1966 - and UTQG - became law on Sept. 9, 1966. In September 1971, three years after its deadline passed, NHTSA proposed rules to grade tires on four properties: high-speed performance, endurance, road hazard resistance and uniformity and balance.
Tiremaker and consumer group complaints that the proposed system was too technical bogged things down until July 1973 when a U.S. District Court gave the DOT five months to issue its final UTQG rules.
Between late 1966 and early 1973, the tire grading plan had only considered bias and bias-ply tires. The growing popularity of radials and NHTSA's inability to obtain control tires threw more wrenches into the works. The NHTSA administrator at the time was Joan Claybrook. She is now president of Public Citizen, and declined several requests for comment for this article.
Despite tens of millions of taxpayer and tiremaker dollars and multiple trips to federal court, by mid-1978 there was still no workable UTQG system in place. In 1978, a government funded study - The Uniform Tire Quality Grading System: A Case Study of the Government Regulatory Process - blasted the government's misguided and misdirected role in the by-then 11-year process. (See www.tirereview.com for Tire Review's condensed version of the 56-page report.)
"There is no evidence that this regulation is better for the consumer than no regulation at all," the report concluded.
The UTQG system finally went into effect in 1979 - nearly 13 years after it became law and 11 years passed its deadline - grading tires on treadwear, traction and temperature resistance.
But in 1983, NHTSA suspended treadwear grading, strangely claiming its then-current system might mislead consumers and place an undue financial burden on tiremakers. In April 1984, though, the U.S. Court of Appeals ruled NHTSA's action was "arbitrary and capricious." The treadwear grading system was reinstated, and lives on to this day.
All along, no one really knew how to make UTQG work, and many from all sides questioned whether the subjective concept of "quality" could be scientifically quantified. That lack of confidence, however, stopped no one from creating one of the most improbable regulations in history.
Does It Work Today?
"In our opinion, it is very doubtful that anyone would notice if UTQG ended," says one tire company. "It just is not utilized very extensively nor is the information of much value."
"Some consumers would miss it because it's a comparative measurement for treadwear and heat dissipation," said another tire firm. "We think dealers would also miss it."
But dealers disagree. "Most consumers wouldn't know if UTQG went away tomorrow," said Joe Flynn III of Flynn Tire Group in Mercer, Pa.
"Less than half a percent of our retail customers even ask about or know about UTQG," said Barry Steinberg, president of Direct Tire in Boston. "I think UTQG has worked in the past as a guide for consumers, but clear industry-wide usage has never happened."
Part of the problem lies with dealers - and other tire retailers - who are as confused as consumers.
"All tire retailers have a problem understanding what UTQG is and how it should be used," said one tire company. "Traction and temperature grades are pretty straightforward and easy for a consumer or retailer to understand. The confusion is on treadwear ratings, how they are determined and what they mean."
"Very few tire dealers or consumers understand it or can explain it properly," said Flynn. "Most people try to convert the treadwear grade to real world mileage and that cannot be done. Treadwear grades now range from a low of near 100 to over 700. How far can a 700-grade tire really go? The answer is about 80,000 miles, if you properly maintain it.
"But if a grade of 100 equals a projected mileage of 30,000 miles when running the test, then a grade of 700 projects to 210,000 miles. We all know that this tire will not go that far, but that's what the test says," Flynn notes. "How come one brand's 80,000-mile is graded 600+ and someone else's is 700+? That's hard to explain to a consumer,. or anyone else for that matter."
"I think if you call 10 dealers from around the country, including us, you'll find there is little knowledge of UTQG," Steinberg admits.
Thanks to three decades of marketing, vast improvements in tire technology and performance, and a lack of consumer tire awareness, many say that UTQG has been rendered totally irrelevant.
Can It Be Fixed?
"Treadwear, traction and temperature were never measures of tire 'quality,' and, in truth, quality can only be assessed by a tire's record in the field," says Consumers Union. "A tire performance grade could be achieved with independent testing, much like vehicle NCAP (New Car Assessment Program) crash ratings. Tires would be evaluated independent of manufacturers, and ratings could include measures of high-speed capability, endurance and traction. And 'traction' is a misnomer and should be termed 'wet braking.'
"Due to the difficulties and inability to grade treadwear consistently over time, treadwear warranties really serve consumers better as an indicator of tread life," Consumers Union says.
"Quality is a difficult term to define," one tire company says. "It can mean different things to different people - smooth ride, relatively low noise levels, good snow traction, crisp vehicle handling response, etc. Treadwear, traction, and temperature resistance are merely an arbitrary set of performance attributes that we are mandated to assign to tires under the guise of 'quality'.
"There are many different models and brands of tires, all of which could have a dozen or more performance attributes to characterize the 'quality' of the tire. Developing and maintaining a system to grade this just isn't necessary. To stay in business, tire companies have to continually develop new products that deliver value at a fair price. If they don't, market forces will remove them. We sometimes forget these business basics."
"We don't think the measure of quality of any product is really how the government says it should perform, but it is how the customer says it does perform," said another tire company.
"Could we come up with another system? I don't know if we can, and I seriously doubt we want this," said that company. "Be careful what you wish for because you might get it."
"I think most tires have equal quality," Flynn says. "Yes, the industry could get to a good grading system, but it's not the one we have now. Today's grades are minimums, they don't reflect true performance. The system should do a better, more accurate job of rating real world performance, especially treadwear."
"Any tire grading should stress temperature and traction, which are the only important issues," Steinberg says. "Mileage is something consumers rely on the retailer to take care of.
"If real independent testing were done on tires with regard temperature and traction and how these affected safety and performance, maybe the public would be less confused and more well-informed."
So What Now?
The grading system is hard enough to explain to the "expert" let alone the layman. Plus, test-result sandbagging (or "line positioning", as some call it) and gross inconsistencies between warranty levels and treadwear grades have made the value of UTQG even more perplexing.
Still we have UTQG. And you must face a fundamental question every day: Is a 400AB-rated tire with a 45,000-mile warranty at $49 better than a 320AB tire with a 60,000-mile warranty for $69?
So many untestable intangibles play a role in tire mileage, traction and temperature - road conditions, driving habits, weather, tire care - that experts have long wondered if UTQG was ever realistic. Tire technology certainly zoomed passed UTQG long, long ago. Are treadwear, traction and temperature resistance adequate measures of tire "quality" - or even performance? Could there be a grading system that would allow consumers to make realistic, fair and equitable comparisons between tire brands and models? Thirty-five years later, many still question whether UTQG works. If UTQG was somehow revoked today, Consumers Union says some buyers would indeed miss it. "Those who use UTQG normally understand it, but also do not rely on UTQG solely in making their tire purchase decisions."Back in 1964, Congress began addressing two tire-related issues: the safety of tires and the ability of purchasers to understand what they were getting. One of the problems with UTQG is that most people - including tire companies - don't understand it very well. Most assume, for instance, that consumers can compare one brand/model of tire with another. UTQG was never intended to allow consumers to cross-compare products from different manufacturers or marketers. It would be impossible to do so because testing isn't centralized or done independently; each manufacturer tests and grades its own tires (and any private brand lines it produces).