Interpretation ID: nht71-3.17

DATE: 06/08/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: British Leyland Motors Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 20, 1970, requesting an interpretation of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574).

The proposals you described in your letter, paragraphs 1 and 2, will certainly meet the minimum requirements of the regulation and are perfectly acceptable. The regulation requires that a record be kept of the type of tire shipped on or in the vehicle. It does not require that the individual tire identification number be(Illegible Word) with the name and address of the purchaser.

If a vehicle dealer sells a vehicle equipped with tires which were not shipped on or in the vehicle, the vehicle dealer is considered a tire dealer under section 574.9(b) and as such, he is required to record the name and address of the first purchaser along with the tire identification number, and forward this information to the tire manufacturer. However, the tire manufacturer may designate someone else to maintain the required records by section 574.7. Therefore, it would be acceptable to have your vehicle dealers forward the required information to you instead of to the tire manufacturer, if the tire manufacturer designates you to maintain the records of tires installed on your vehicles.

If we can be of any further assistance, please feel free to write.