Richard E. Trachtenberg, Esq.
Post Office Box 11005
330 Vanderbilt Motor Parkway
Hauppauge, NY 11788-0903

Dear Mr. Trachtenberg:

This responds to your letter of March 27, 1996 addressed to Walter Myers of my staff. You provide what you think may be tire identification number (TIN) 5R5691439T and ask us to verify that the number is a TIN and if so, provide you the information that it represents. You also state that the tire may be a retreaded tire. Our answer is that this number does not appear to be a TIN.

Title 49, Code of Federal Regulations, Part 574.5 establishes the requirement for TINs and specifies the information to be contained therein as well as the format and sequence of such information. Part 574.5 requires that the TIN be composed of four groups of symbols, letters and/or numbers. The first grouping, composed of two or three symbols, represents the manufacturer's identification mark assigned by this agency in accordance with Part 574.6. The second and third groupings identify the tire size and significant characteristics of the tire respectively, both at the option of the manufacturer. The fourth grouping of three symbols shows the week and year of manufacture.

The series of numbers and letters in question, 5R5691439T, do not comply with the requirements of Part 574.5. The first two or three characters, A5R@ or A5R5, have not been assigned by this agency. New tires are assigned a two-character code which may be either two letters or a number and a letter, for example ABA@ or A1B.@ Retreaded tires are assigned a three-letter code, such as ACJX.@ The numbers "439" could represent the manufacturing date, for example the 43d week of 1989, but there is no provision in the regulation for a "T" at the end of the

TIN. Thus, these numbers and letters do not comply with the TIN requirements of Part 574.5, and this agency has no record of or information on this particular series of numbers and letters.

I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Ref:574 d:5/1/96