Interpretation ID: aiam2579
Lansdale
Carr & Baum
Advertising
Marketing & Management
17622 Armstrong Avenue
Irvine
CA 92705;
Dear Mr. Ideker: This responds to your March 25, 1977, letter asking whether you proposed tire registration card to be used by your retail tire stores meets the requirements of 49 CFR Part 574, *Tire Identification and Recordkeeping*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approvals of compliance with agency standards or regulations. The agency will, however, give an informal opinion as to whether your registration card appears to satisfy the requirements of the regulation.; The proposed card that you submitted is similar to the exampl presented in Figure 3 of Part 574. Accordingly, it appears to comply with most of the requirements of that regulation. The actual seller of the tires, however, is not identified on the form. Since Part 574.7 requires that the tire seller be identifiable to the tire manufacturer, the form should disclose that information. Naming only the corporate office is insufficient, since that does not readily identify the store through which the tire was sold. The NHTSA suggests that the actual seller's name and address be provided on the card as shown on Figure 3.; It is our understanding that the tire seller will forward the cards t you who will then forward the information to the manufacturer. This process is acceptable to the NHTSA as long as the information is forwarded to the manufacturer within the time frame specified in Part 574.8.; Sincerely, Frank A. Berndt, Acting Chief Counsel