Interpretation ID: 12375.wkm
Technical Manager
Hankook Tire America Corporation
Three University Plaza, Suite 430
Hackensack, NJ 07601
Dear Mr. Jung:
This responds to your letter to Mr. Jim Gilkey of this agency in which you asked whether the agency was planning to issue a regulation adding a symbol to the end of the tire identification number to designate the year of manufacture. The answer is no.
As you correctly pointed out in your letter, the fourth grouping of numerals in the tire identification number (TIN) required by 49 Code of Federal Regulations 574.5 is a three-symbol code representing the week and year of manufacture. The first two numbers represent the week and the third the year. Thus, in the example you provided, the numbers "439" would represent the 43d week of 1989. As you further pointed out, however, that "9" could also mean 1979 or even 1969. For that reason, you stated that the Imported Tyre Manufacturers Association of the United Kingdom intends to add a fourth symbol to that grouping to identify tires produced in the decade 1990 to 1999. You asked whether this agency has any plans to do the same.
The National Highway Traffic Safety Administration (NHTSA) has recognized the possibility that a single number representing the year of manufacture could cause some confusion because there is nothing to identify the decade to which that number belongs. That has not proven to be a significant problem, however, it being generally assumed that the number refers to the most recent year ending in that number. Because NHTSA only regulates new tires and newly-retreaded passenger car tires, that will generally be a valid assumption since it is extremely unlikely that a tire manufactured or retreaded in 1969 or 1979 will remain unsold on the store shelf in 1996. Accordingly, NHTSA has no present plans to add a symbol to the fourth grouping of the TIN to specify the exact year of manufacture.
I hope this information is helpful to you. Should you have any further questions or need additional information, feel free to contact Walter Myers of my staff at this address or at (202) 366-2992.
Sincerely,
John Womack
Acting Chief Counsel
Ref: #574
d:9/13/96