Interpretation ID: nht94-5.12

TYPE: INTERPRETATION-NHTSA

DATE: December 19, 1994

FROM: Glyn Thomas -- Thomas Tire

TO: Walter Myers -- Department Of Transportation

TITLE: Re: 19 CFR 12.80

ATTACHMT: ATTACHED TO 2/27/95 LETTER FROM PHILIP R. RECHT TO GLYN THOMAS (REDBOOK (6); PART 591; STD 109; STD. 119) AND 6/13/81 LETTER FROM FRANK BERNDT TO ROY LITTLEFIELD (STD 119)

TEXT: I am writing to you after our telephone conversation of today's date. This is a very urgent matter and I am writing to ask for a waiver to be allowed to continue to import truck casings into the U.S.A. for the purpose of retreading.

Some Japanese casings do not have the D.O.T. marking on the side wall. To allow for this, tires with less than 2/32" and being imported solely for the purpose of retreading are allowed entry.

However, my point is that tires with less than 2/32" tread remaining are usually not of sufficiently good quality.

I maintain that a declaration signed by the importer and confirmed by the receiving retread shop, at the time of entry, stating that the casings are being imported solely for the purpose of retreading, could [Illegible Word] solve this problem.

If this is not done, then it would badly effect the total number of casings available for U.S. retread shops and definitely effect production.

Is it possible to mail or fax me immediately, a waiver to this effect. Thus allowing the continued smooth import of casings.