Interpretation ID: nht71-2.25

DATE: 04/13/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Tire Retreading Institute

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of December 28, 1970, to Roger Comptom, requesting an interpretation whether the Tire Identification and Record Keeping Regulation (49 CFR 574) is applicable to retreaded tires sold to the General Services Administration (GSA); and, if the regulation is applicable, what will GSA be considered to be; a distributor, a dealer, or a first purchaser for purposes other than resale.

The regulation is applicable to both new and retread tires sold to GSA. We consider GSA to be a "purchaser" under the regulation, and the manufacturer or retreader is required to maintain records of the purchaser's name and address and the identification number of the tires sold to them. However, as you must realize, individual arrangements on a contractual basis between GSA and its suppliers are not precluded by the regulation.