Interpretation ID: nht71-3.24

DATE: 07/02/71

FROM: E.T. DRIVER -- NHTSA; SIGNATURE BY JOHN CARSON

TO: Bandag Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 30, 1971, and to confirm opinions given by members of this office(Illegible Words) phone coversation with you.

Under the National Traffic and Motor Vehicle Safety Act and regulations issued pursuant to it the treadless casing you import is not considered to be a completed tire until the tread is applied. Therefore, the Bandag dealer applying the tread is considered to be the tire manufacturer and the Korean manufacturer of the casing does not have to put his own "DOT" number on the casing.

Since you expect many of your dealers will be using this process, in order not to unduly expand the new manufacturer's list, all your dealers are to use your assigned code number "DOT" for the grouping representing the manufacturer's assigned code and their own three symbol retreader's code in the third grouping which is normally considered the optional code:

Your dealers, as manufacturers of the tires are responsible for maintaining the records of the first purchaser of the tires they manufacturer.

I believe Docket No. 70-12, Notice No. 9 (36 P.R. 9869) answers your question concerning the location of tire identification numbers.

Mr. M. Groosman U.S. Factory Representative Automobiles Peugeot

This is in reply to your letter of June 22 requesting an interpretation of Paragraph S4.2 of Motor Vehicles Safety Standard No. 101.

You may mark your windshield wiper control, and lighting - windshield washing control in the manner indicated in your letter. We do not consider the washing control a wiping control requiring identification as such merely because the wiper is momentarily activated when the washer system is in operation.

Lawrence R. Schneider Acting Chief Counsel