Mr. Barry Livett
Assistant Director
Corporate Finance Department
Bank of China International (UK) Limited
One Canada Square
London E14 5AA

Dear Mr. Livett:

Please excuse the delay in responding to your letter to Mr. Arthur H. Neill, Jr. formerly of this Department, requesting a list of Chinese tire companies that have been granted certification by the U.S. Department of Transportation. Please be advised that Mr. Neill has retired.

You state that you work for the merchant banking arm of the Bank of China and are preparing information on the Chinese tire industry. In connection with this, you request from us a list of Chinese tire companies and/or names of Chinese tire brands that have been granted any form of U.S. certification.

The law of this country establishes a self-certification system in which manufacturers of motor vehicles and motor vehicle equipment, which includes tires, themselves certify that their products meet all applicable Federal motor vehicle safety standards. Thus, this agency does not certify, approve, disapprove, endorse, or assure compliance of any motor vehicle or item of motor vehicle equipment prior to its being introduced for sale in the retail market. Rather, this agency enforces compliance with the standards after the fact; that is, we purchase vehicles and equipment that are available to consumers in the retail market and test them for compliance. If they are found to comply, nothing further is done. If they are found not to comply, the manufacturer is responsible for correcting the problem(s), by repair or otherwise, at no expense to the customers.

We do, however, issue identification codes to each plant of each manufacturer that produces tires for sale in the United States. The purpose of such codes is that in the event of a tire recall, the codes will enable this agency to readily identify the plant in which the affected tires were produced. Therefore, enclosed in accordance with your request is a list of tire companies in China to which we have issued tire codes as of January 22, 1998.

I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at 011-202-366-2992, or by fax at 011-202-366-3820.

John Womack
Acting Chief Counsel