Interpretation ID: aiam1430
Continental Gummi-Werke
Aktiengeselischaft
Postfach 169
3 Hannover
Germany;
Gentlemen: This is in reply to your letter of January 29, 1974, raising certai questions about the effective date (September 1, 1974) of the Uniform Tire Quality Grading regulation. You pose two hypothetical questions, asking whether tires must be quality graded when they are to be placed on vehicles manufactured or imported after September 1, 1974. In the first situation, the tires are manufactured in July 1974, while the vehicle is manufactured in August 1974 and imported in October 1974. In the second, the tires are manufactured in August 1974, the vehicle is manufactured in September 1974 and imported in November 1974.; The Quality Grading regulation applies to tires rather than vehicles Its effective date of September 1, 1974, means that all passenger-car tires manufactured on or after that date must be graded in accordance with the regulation. There is no requirement, however, that vehicle manufacturers must use tires manufactured after that date. In each hypothetical question you present, the tires are manufactured before September 1, 1974, and therefore are not required to be graded. The date of manufacture or importation of the vehicle is immaterial.; Yours truly, Richard B. Dyson, Assistant Chief Counsel