Interpretation ID: nht74-5.46

DATE: 08/22/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Universal Tire

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 6, 1974, asking what registration procedures apply to tires manufactured before May 22, 1971, but sold after that date.

We interpret Part 574 of the Code of Federal Regulations, which establishes the tire registration requirements, as applying only to tires manufactured after the effective date of the regulation, May 22, 1971. Therefore, tires manufactured before that date need not be registered.

YOURS TRULY,

Universal Tire

National Highway Traffic Safety Administration Department of Transportation

Attention: Dick Dyson, Acting Chief Counsel

August 6, 1974/Letter #3747

I have just finished conversing with Mr. Cassanova who was very helpful; however, he referred my question to your department for legal advice.

Universal Tire is contemplating purchasing a number of containers of tires of foreign manufacture which have the old type serial number used prior to May 22, 1971. I am advised by Mr. Cassanova that we can sell these tires in view of the fact they have the old type serial number. They also are marked "D.O.T." and, of course, meet all D.O.T. specifications. We would be happy to have a letter to this effect written by the manufacturer if you suggest we do so.

Would you please reply by mail as to whether these tires would require registration as applies to the current system.

Your quick response and time is appreciated.

Thanking you in advance, I remain

Bruce Ladson Assistant Division Manager