Interpretation ID: nht74-4.38

DATE: 01/11/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Tire Distributors Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of December 19, 1973, concerning a standardized form for tire registration. The National Highway Traffic Safety Administration is aware of the problem that some dealers face in having to complete a multiplicity of tire registeration forms. Therefore, we issued on March 8, 1973, a proposal for a universal registration form such as you have suggested. We have received comments on our proposal from interested parties, and are currently revising it for issuance as a final rule in the spring of this year.

As to your specific question, whether you may adopt your own "universal" form, there is nothing in our regulations which would preclude your doing so. While Section 574.7 requires manufacturers, brand name owners, and retreaders to provide a means by which the registration data may be recorded and Section 574.3 requires distributors and dealers to submit the required information to the manufacturers, there is no requirement that the dealers utilize the manufacturers' forms. I have enclosed a copy of our proposed rule concerning universal tire registration forms. You should be aware that the proposal is now going through revisions based on comments received and the final rule may differ in some respects.

ENC.