Interpretation ID: nht71-2.50

DATE: 05/13/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Harden Manufacturing Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 3, 1971, requesting an interpretation of the Tire Identification and Record Keeping Regulation. You indicated in your letter that you are a trailer manufacturer. As such, you are considered a motor vehicle manufacturer under both the regulation and section 102(3) and (5) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.) (copies enclosed).

As a manufacturer, you are required, by section 113(f) of the Act, to record the name and address of the first purchaser for purposes other than resale. Section 574.10 of the regulation requires that you maintain a record of the tires shipped on or in vehicles which you manufacture. In the event of a defect notification concerning either the vehicle or its tires, your responsibilities are enumerated in section 111 and 113 of the Act.

Enclosures