Interpretation ID: nht71-3.43

DATE: 07/19/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: General Telephone Company of California

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 17, 1971, concerning General Telephone's obligations under the Tire Identification and Record Keeping Regulation (49 CFR 574).

You have asked if General Telephone is required to keep records under the regulation in connection with the sale of used vehicles, and if it is, whether a specific exemption is required.

If you are selling used vehicles to purchasers who are the ultimate users of these vehicles, and you are equipping those vehicles with new or newly retreaded tires, you are considered a tire dealer under section 574.9 of the regulation and you are required to maintain the records required by section 574.8 of the regulation.

If, however, you are selling used vehicles without equipping them with new or newly retreaded tires, to dealers rather than users, the regulation does not apply to General Telephones and no specific exemption is necessary.

Enclosed for your convenience is a copy of the regulation, if we can be of further assistance please feel free to write.

ENCLOSURE