Interpretation ID: aiam0378
Vice President
Bandag Incorporated
1056 Hershey Avenue
Muscatine
IA 52761;
Dear Mr. Vischer: This is in reply to your letter of May 10, 1971, and to confir opinions given by members of this office in subsequent phone conversations with you.; Under the National Traffic and Motor Vehicle Safety Act and regulation issued pursuant to it the treadless casing you import is not considered to be a completed tire until the tread is applied. Therefore, the Bandag dealer applying the tread is considered to be the tire manufacturer and the Korean manufacturer of the casing does not have to put his own 'DOT' number on the casing.; Since you expect many of your dealers will be using this process, i order not to unduly expend the new manufacturer's list, all your dealers are to use your assigned code number 'XX' for the grouping representing the manufacturer's assigned code and their own three symbol retreader's code in the third grouping which is normally considered the optional code:(sic); Your dealers, as manufacturers of the tires are responsible fo maintaining the records of the first purchaser of the tires they manufacturer (sic).; I believe Docket No. 70-12, Notice No. 9 (36 F.R. 9869) answers you question concerning the location of tire identification numbers.; Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;