Interpretation ID: nht71-3.21

DATE: 06/24/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: 707 Tire Service Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 15, 1971, concerning the Tire Identification and Record Keeping Regulation (49 CFR Part 574).

As stated in the interpretation published in the Federal Register of May 28, 1971, under section 113(f) of the National Traffic and Motor Vehicle Safety Act, "it is the tire manufacturer who has ultimate responsibility for maintaining the records of first purchasers".

Under the Act and the Regulation, we have no authority to require a tire manufacturer to choose someone as his designee. I have asked Goodyear's counsel for their position with regard to the possible use of tire dealers customer's lists and was forwarded a letter dated June 8, 1971, from the Goodyear Tire and Rubber Company which sets forth the company's policy with regard to the prohibition in the regulation. I enclose the letter for your information.

ENCLOSURE