Interpretation ID: aiam1623
Manager
Government & Industry
Tech. Relations
Dunlop Tire & Rubber Corporation
P. O. Box 1109
Buffalo
NY 14240;
Dear Mr. Boyd: This is in response to your letter of September 11, 1974, askin several questions relating to our tire identification regulation as it applies to Dunlop Tire and Rubber Corporation (England).; When tires are manufactured for a brand name owner, as they will be i your case, you are correct in saying the first grouping in the identification number must contain the manufacturer's identification (DD, in your case) and the third grouping must contain up to four letters designating the brand name owner. Pursuant to section 574.5(c) you must maintain a detailed record of the brand name owner code used.; Pursuant to section 574.7(c), the brand name owner must maintain th information required by section 574.7 of the regulation. Therefore, no agreement between Dunlop and Armstrong is necessary.; Yours truly, Richard B. Dyson, Acting Chief Counsel