Interpretation ID: aiam0359
Director of Engineering
Williamsen Body & Equipment Company
1925 Indiana Avenue
P.O. Box 1076
Salt Lake City
UT 84111;
Dear Mr. Smith: This is in reply to your letter of May 18, 1971, requesting a interpretation of the Tire Identification and Record Keeping Regulation (49 C.F.R. Part 574) as it applies to vehicles manufactured in two or more stages.; The final-stage manufacturer, as a vehicle manufacturer, under sectio 113(f) of the National Traffic and Motor Vehicle Safety Act, is required to keep a record of the name and address of the first purchaser for purposes other than resale, and to maintain a record of the tires shipped on or in the completed vehicle (49 C.F.R. 574.10). Although the final-stage manufacturer may designate someone to maintain the records required under section 574.10 of the Tire Identification and Record Keeping Regulation, the legal responsibility for maintaining the records remains with the final-stage manufacturer.; However, the incomplete vehicle manufacturer, or any intermediat manufacturer, may assume 'legal responsibility for all duties and liabilities imposed on manufacturers by (the Act) with respect to the vehicle as finally manufactured . . .' (49 C.F.R. 568.7). In such a case, the responsibilities for maintaining the records required by the Act and by the Tire Identification and Record Keeping Regulation will be assumed by the incomplete vehicle manufacturer, or any intermediate manufacturer, and the final-stage manufacturer will be relieved of all liability for maintaining the records.; Under the Tire Identification and Record Keeping Regulation, th manufacturer is not required to keep a record of tires manufactured before May 22, 1971, but sold after that date. However, where feasible, we recommend that the manufacturer maintain some system whereby he can identify the type of tire on vehicles he sells as well as the purchaser of the vehicle.; For your convenience, we have enclosed copies of the Act with it amendments, the Tire Identification and Record Keeping Regulation, and the Certification Regulation.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel