Interpretation ID: aiam0339
Marden Manufacturing Company
205 Denton Avenue
Auburndale
FL 33823;
Dear Mr. Denton: This is in reply to your letter of May 3, 1971, requesting a interpretation of the Tire Identification and Record Keeping Regulation. You indicated in your letter that you are a trailer manufacturer. As such, you are considered a motor vehicle manufacturer under both the regulation and section 102(3) and (5) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 *et seq*.) (copies enclosed).; As a manufacturer, you are required, by section 113(f) of the Act, t record the name and address of the first purchaser for purposes other than resale. Section 574.10 of the regulation requires that you maintain a record of the tires shipped on or in vehicles which you manufacture. In the event of a defect notification concerning either the vehicle or its tires, your responsibilities are enumerated in section 111 and 113 of the Act.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel