Interpretation ID: nht78-4.20

DATE: 05/01/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHTSA

TO: National Tire Dealers & Retreaders Association, Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 23, 1978, letter asking whether the National Highway Traffic Safety Administration's (NHTSA) interpretation concerning the registration of passenger car tires can be applied to the registration of truck tires. In that interpretation, the NHTSA stated that it was permissible for a tire dealer to allow the tire purchaser to fill out the tire registration form and hand it back to the dealer.

The NHTSA's interpretation is applicable to both truck and passenger car tires. A truck tire dealer may permit a purchaser to fill out the required information rather than completing the registration form himself. However, this all must occur at the point of sale of the tire. The registration forms for both passenger car tires and truck tires are not permitted to be taken home or shipped with the tires to be completed by the purchaser and subsequently returned or mailed to the dealer. This would impair the benefit of mandatory tire registration and make it a voluntary program. This is not the intent of the regulation, and the NHTSA would not consider such a registration program to be in compliance with the tire registration regulation.

SINCERELY,

NATIONAL TIRE DEALERS & RETREADERS ASSOCIATION, INC.

February 23, 1978

Roger Tilton National Highway Traffic Safety Administration

Dear Mr. Tilton:

As you know, NHTSA has issued a interpretation of the regulations regarding tire identification and record keeping, which permits the tire dealer to hand to the consumer of passenger tires a form which the consumer may fill out at the dealers place of business.

Since a similar type of problem now exists in the sale of truck tires the question has been raised on registration there also.

It it permissible for a tire dealer, selling to a trucker, to give the trucker a form to fill out and return to the individual dealer? In some cases truck tires are shipped directly from the manufacturer to the trucker and the dealer may not have even a direct contact on every shipment.

Letting the cards accompany the tires or providing the registration cards to the trucker might be helpful. We would appreciate some guidance on this so we may advise our membership.

Philip P. Friedlander, Jr. Executive Vice President