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Interpretation ID: GF003903

    Mr. Daniel A. Bensman
    Faulkner, Garmhausen, Keister & Shenk
    Courtview Center - Suite 300
    100 South Main Avenue
    Sidney, OH 45365


    Dear Mr. Bensman:

    This responds to your May 4, 2005, e-mail asking the agency to clarify certain requirements set forth in 49 CFR Part 574, Tire Identification and Recordkeeping (Part 574). Specifically, you ask if 574.10 requires vehicle manufacturers to record the Tire Identification Number (TIN) for each tire they install on motor vehicles prior to first sale.

    Part 574, sets forth two separate tire identification and recordkeeping requirements designed to facilitate notification of tire or new vehicle purchasers of defective or nonconforming tires, and to enable tire or new vehicle purchasers to identify tires subject to a recall. The first requirement, 574.7, applies to tire manufacturers and requires them to maintain tire registration records that they receive from tire dealers and distributors. The second requirement, 574.10, applies to motor vehicle manufacturers and requires them to maintain registration records on tires that they install on motor vehicles prior to first sale.

    The registration record required by 574.10 must include the information identifying the tires, and the name and address of the first purchaser of each vehicle equipped with such tires. The information that identifies the tires need not include the TIN. As explained in the response to the petitions for reconsideration of the final rule adopting the tire recordkeeping requirements, the National Highway Traffic Safety Administration did not require vehicle manufacturers to record the TIN of every tire they install on motor vehicles prior to first sale because such a requirement would be extremely burdensome and costly (see 36 FR 1196 at 1197, January 26, 1971). We note, however, that some vehicle manufactures chose to use the TIN in order to identify the tires installed on their vehicles, while others use different methods that enable them to identify the size, brand, and batch or lot of tires installed on the particular group of vehicles.

    I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

    Sincerely,

    Stephen P. Wood
    Acting Chief Counsel

    Enclosure
    ref:574
    d.9/19/05