Interpretation ID: nht71-3.11

DATE: 06/01/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: The General Tire & Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of May 17, 1971, concerning the applicability of the Tire Identification and Record keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill.

As you mentional in your letter, under the regulation, a vehicle dealer has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer.

The Tire Identification and Record Keeping Regulation and the Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations.