Interpretation ID: aiam2382
Pillsbury
Madison & Sutro
225 Bush Street
P. O. Box 7880
San Francisco
CA 94120;
Dear Ms. Ciani: This responds to your May 11, 1976, question whether S 574.7 of Par 574 (*Tire Identification and Record Keeping*) (49 CFR Part 574), requires that the brand name owner of a single tire brand must supply to its dealers tire registration forms that conform to the dimensions specified for the 'universal form' described in Figure 3 of the regulation. You also request confirmation that a tire registration form 'which fits credit card imprinters and provides for the registration of only two tires' is similar in format to the form described in Figure 3.; Section 574.7 of the regulation specifies in part that '. . . form conforming in size and similar in format to Figure 3 shall be provided to those dealers who request them. . . .' As stated in the preamble accompanying the requirement, the purpose of the specification is to ease the problem of the multi-brand dealer who was 'faced with a multiplicity of different forms and procedures for tire registration' (39 FR 19482, June 3, 1974). The requirement that the 'universal form' conform in size as well as format was added in conjunction with a similar requirement for dealers, in response to petitions for reconsideration of the June amendment (39 FR 28658, November 1, 1974).; Review of the changes indicates clearly that the requirement fo conformity in size of the 'universal form' was directed only to the situation of multi- brand dealers. The NHTSA does not consider the manufacturer or brand name owner of one tire brand to be subject to this requirement in the case of a dealer who sells only one brand of tires. It is clear that any advantage in the storage of different forms from different tire manufacturers would not apply in the case of a one-brand dealer. Accordingly, the NHTSA interprets S 574.7 to not require conformity in the size of forms supplied by a tire manufacturer, brand name owner, or its designee, in the case of requests from dealers that sell only one brand of tire.; In answer to your second request, the NHTSA considers a tir registration form which provides for the registration of only two tires to be similar in format to the form described in Figure 3. Any variation from the size of the form described in Figure 3 would, of course, be subject to the limitation just discussed.; Sincerely, Frank A. Berndt, Acting Chief Counsel