Interpretation ID: nht78-4.21

DATE: 08/08/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHTSA

TO: Euro-Tire, Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your June 1, 1978, letter asking whether it is acceptable for you as a tire distributor to use your own tire registration form as long as it complies with the requirements of Part 574, Tire Identification and Record-keeping.

Part 574.7 of the Code of Federal Regulations (CFR) provides that a dealer of tires may supply his own form on which to record information specified in paragraphs (a)(1), (a)(2) and (a)(3), as long as the form contains the required information, conforms in size and is similar in format to the "Universal Format" form set forth in Figure 3 of that part. The form designed by Euro-Tire appears to meet the requirements of Part 574. Accordingly, it is acceptable for use in fulfilling the tire recordkeeping requirements.

SINCERELY,

June 1, 1978

Office of Chief Counsel U.S. Dept. of Transportation N.H.T.S.A.

Gentlemen:

Euro-Tire, Inc. is a retailer of several brands of passenger car tires.

Because of the nature of our operation, the registration of D.O.T. tire identification numbers as required by law has become very time consuming and costly to us.

Since our operation is fully automated, it would be advantageous to us to record the required information for the various brands of tires we sell on one universal form rather than on the several different forms provided by our supplier-manufacturers or their agents.

Attached is a photocopy of the form we designed for this purpose. The sample typewritten information, namely, customer name and address, date of sale and brand name, will be computer printed.

We believe that our form meets all the informational and dimensional requirements of NHTSA's "universal format" and that it complies substantially with the layout of the "universal format".

We would appreciate your reviewing our form and advising us promptly as to whether or not is is an acceptable substitute for the several different forms provided by our suppliers for registration purposes.

EURO-TIRE, INC.

Martin P. Ronsen President

IMPORTANT: Federal law requires registration of all tires purchased for highway use.

SOLD TO

JOHN Q CUSTOMER 1234 MAIN ST APT 34 ANY CITY NJ 07000

SOLD BY

euro-tire

EURO-TIRE, Inc. 1275 Bloomfield Ave. Fairfield, NJ 07006

DATE OF SALE 6/01/78

TIRE BRAND SUPERSLICK QTY D.O.T.TIRE IDENTIFICATION CODE 3 A 7 G X K L M N 3 5 7 1 A 7 G X K L M N 3 9 7

June 29, 1978

Office of Chief Counsel U.S. Dept. of Transportation N.H.T.S.A.

Att.: Nancy Eager, Esquire

Gentlemen:

We are enclosing a copy of our letter dated June 1, 1978 together with a copy of the proposed format we designed for the registration of D.O.T. tire identification numbers.

Your prompt attention to this matter would be greatly appreciated.

EURO-TIRE, INC.

Martin P. Ronsen