Interpretation ID: nht73-2.21

DATE: 04/07/73

FROM: AUTHOR UNAVAILABLE; David Schmeltzer; NHTSA

TO: Arthur H. Davis

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter which we received April 5, 1973, which asks if you, as a dealer of tires, may register all new and retreaded tires sold to first purchasers on a single form and send that form to a tire registry service.

Under the Tire Identification and Record Keeping regulation (49 CFR Part 574) dealers selling cars to first purchasers must record the sale and forward the required information to the manufacturer or his designee. Therefore, you can only record all the tire sales from various manufacturers and retreaders on a registry service form if that registry service is the designee of all of the manufacturers and retreaders whose tires you sell.

For your information we have enclosed a copy of the Tire Identification and Record Keeping regulation (Notice No. 5) and a copy of an interpretation of the regulation dealing with the question of manufacturers' designees (Notice No. 10).

Thank you for your interest in auto safety.

Sincerely,

Enclosures

Sir

RE: D.O.T Registration

I am in the wholesale tire business. It has come to my attention twice that a dealer may register all this not only mine but all this on one simple registration form. That being Axican Systems hire.

Can a dealers register all new turn' and all retracks on the form that Axican Systems he use, mail it to Axican and be legally within the bainclouir of the federally law.

Sincerely,

(Illegible Word) --

RFD 2 Box 174A.,(Illegible Word). Mc 04401