Interpretation ID: aiam3719
Tire Manager
J-B Purchasing Corporation
P.O. Box 692
Auburn
NY 13021;
Dear Mr. Jayne: This responds to your recent letter asking about the requirements of 4 CFR Part 574, *Tire Identification and Recordkeeping*. You noted that your company currently retreads tires for its own use, and that you soon plan to retread tires for sale to others. You asked if the tires you retread for your own use need to be identified with a tire identification number. The answer is no.; Section 574.5 of the Tire Identification and Recordkeeping regulatio provides, in part, that, 'Each tire retreader, *except tire retreaders who retread tires for their own use*, shall conspicuously label one sidewall of each tire he retreads by permanently molding or branding into or onto the sidewall, ...a tire identification number....' Your question concerns a situation in which a tire retreader retreads some tires for his own use and some tires for sale or lease to others. To answer your question, it is helpful to examine the purpose of the identification requirement.; The purpose of having the tire identification number labeled on th sidewall of retreaded tires is twofold. First, it enables this agency and the user of the retreaded tire to identify the retreader of the tire in the event of some safety problem with the tire. Second, it enables the tire retreader to accurately identify the retreaded tires it may have to recall. In the case of tires offered for sale or use outside your company, it is plain that both these purposes would be served by having the tire identification number on the sidewall. Therefore, Part 574 requires that each such tire have a tire identification number on one sidewall.; However, with respect to tires retreaded for the retreader's own use it is obvious who retreaded the tire, whether or not a tire identification number appears on the sidewall. Hence, the first purpose listed above would not be served by having the tire identification number on the sidewall of these tires. Further, the retreader can inspect all of the retreaded tires it uses to determine if any are subject to its recall, and assure adequate remedy for those which are within the recall, without publicizing the identification numbers of those tires. Thus, the second purpose set forth above also would not be furthered by having the tire identification number on the sidewall of these tires. Please note, however, that any tire not marked with a tire identification number can never legally be sold or otherwise offered for use outside of your company.; Should you have any further questions or need additional informatio about this topic, please contact Steve Kratzke of my staff at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel