Interpretation ID: nht71-2.32

DATE: 04/28/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Simek Manufacturing Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 7, 1971, concerning the applicability of the Tire identification and Record Keeping Regulations to boat trailers. As used in the regulation, "Motor Vehicle" includes boat trailers as well as other types of trailers. Thus, the regulation does apply to boat trailers.

If a trailer is shipped with the tires attached, section 574.10 requires the motor vehicle manufacturer to maintain the records of the name and address of the first purchaser for purposes other than resale because the tires will be "on or in" a vehicle shipped by him. If, however, the trailers are shipped in a "knocked down" configuration with the tires shipped seperately, the tires are not considered to be shipped "on or in" the vehicle within the meaning of Section 574.10, and therefore, the vehicle dealer is, by section 57 required to report the name and address of the purchaser to the tire manufacturer.

The manner of maintaining the records is not specified by the regulation and any method that satisfies the requirements of the regulation may be used.