Interpretation ID: nht95-3.61

TYPE: INTERPRETATION-NHTSA

DATE: July 26, 1995

FROM: Arthur N. Arschin, Esq

TO: Wilart Banks -- Office of Vehicle Safety Compliance, U.S. DOT

TITLE: Vee Rubber Co., Ltd. and Vee Rubber International Co., Ltd.

ATTACHMT: ATTACHED TO 10/20/95 LETTER FROM JOHN WOMACK TO ARTHUR N. ARSCHIN (A43; REDBOOK 2; PART 574)

TEXT: Dear Mr. Banks:

I am writing as the attorney and agent for the captioned companies, which are tire manufacturers based in Thailand. Previously, in 1987 I had made an inquiry to your office to obtain DOT identification numbers for those two Thailand corporations for the purpose of importing new and retreaded tires into the United States.

By your agency letters of November 3, 1987 and August 24, 1988 (copies enclosed), the DOT assigned identification marks to my client as follows: YRV for Plant No. 1 and YRV for Plant No. 2. In addition Plant No. 1 was assigned the code 4A and Plant N o. 2 was assigned 5A for purposes of new tire manufacturing.

What I need from your agency is a written confirmation that such assigned codes are still valid and may be validly used by my client.

If you are not able to do that, I would need a letter stating that once such codes are assigned, they remain valid for an indefinite period unless abandoned by the manufacturer.

Please contact the undersigned if additional information is needed.

Your prompt and considered attention will be greatly appreciated.

Attachments

LETTER # 1: 8-24-88

Mr. Arthur N. Arschin 233 Broadway - Suite 730 New York, N.Y. 10279

Dear Mr. Arschin:

We have registered the Vee Rubber Co., LTD., Inc. of Bangkok area retreed manufacturer with you as their agent.

The identification marks assigned to this company are: FOR PLANT NO. 1 YRU FOR PLANT NO. 2 YRV

These marks identify the Vee Rubber Co. as the retread manufacturer of both plants.

If you should no longer represent them or if there is a change in the company location or ownership, please notify us immediately.

Note: The code YPV, previously assigned to you is error, is not to be used as it is retained by another retreader.

Sincerely,

Nelson Gordy Motor Vehicle Requirements Division Office of Market Incentives, NHTSA

LETTER # 2:

11/3/87

Mr. Arthur N. Arschin Attorney at Law 233 Broadway - Suite 730 New York, NY 10279

Dear Mr. Arschin:

This is in reply to your request for assignment of tire manufacturer identification codes for the Vee Rubber Co., Ltd. and Vee Rubber Int. Co., Ltd. plants located at Samutsakorn, Thailand.

We are assigning the code 4A to Plant No.-1 and code 5A to Plant No.-2. Our records show the address of these plants and your main office as follows:

Plant Plant No.-1: B7/5 Gp. 4 Sethakij Road, Ban Koh Muaug District, Samutsakorn Province - Thailand Plant No.-2: 22/3 MOO 2 Tambal Chaimongkol Ampher * Samutsakorn, ThailandMain Office Plant No.-1: Vee Rubber Co., Ltd. 142/37 Sol Suksavithaya Sathorn Nua Road, Bangrak Bangkok, Thailand 10500 Plant No.-2: Vee Rubber International Co., Ltd. 142/35 Sol Suksavithaya Sathorn Nua Road, Bangrak Bangkok, Thailand 10500 * Denotes Illegible Word

We are enclosing the following publications for your information:

Regulation Part 574

Federal Motor Vehicle Safety Standards Nos. 109 and 119

The use of the DOT symbol molded into or onto a tire constitutes a certification by the manufacturer and signifies that the tire meets applicable Federal safety requirements. While it is not required that tires be tested prior to using the DOT symbol, t he National Highway Traffic Safety Administration does maintain a compliance test program to enforce safety standards, and any tires that are found not to meet the Federal standards, are subject to civil penalties of up to $ 1000 per tire but not to exce ed $ 800,000 for any related series of violations.

Your tire manufacturer's identification code mark is required on all new pneumatic tires sold in the United States for highway use. This code mark and other tire identification labeling are specified in Regulation Part 574.

Sincerely

Stanley R. Scheiner, Chief Crash Avoidance Division Office of Vehicle Safety Standards

3 Enclosures