tire recordkeeping: understanding and implementing ... - natm

National Association of Trailer Manufacturers(785) 272-4433 www.natm.com

Tire Recordkeeping:Understanding and

Implementing49 CFR §574.10


Review the FederalRegulations

Tire recordkeeping is covered in 49 CFR Part574

• Our primary concern involves § 574.10• However, there are compliance implications

for us and especially for our dealers in 49CFR §§ 574.8 and 574.9


The Federal RegulationTITLE 49--TRANSPORTATION

CHAPTER V--NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION, DEPARTMENT OF TRANSPORTATION

PART 574 - TIRE IDENTIFICATION AND RECORDKEEPING -

Sec. 574.10 Requirements for motor vehicle manufacturers.

Each motor vehicle manufacturer, or his designee, shall maintain a record of the new tires on or in each vehicle shippedby him or a motor vehicle distributor or dealer, and shall maintain a record of the name and address of the first purchaser for purposes other than resale of each vehicle equipped with such tires. These records shall be maintained for a period of not less than 5 years from the date of sale of the vehicle to the first purchaser for purposes other than resale.


• 49 CFR §574.10 requires four key elements:

– Trailer manufacturer, or designee, must maintain “a record” of the new tires “on or in” all trailers it ships or the trailer dealer ships

– This “record” must provide identification of tire size, brand, and batch or lot (The “record” also may be the tire’s Tire Identification Number)

– Trailer manufacturer or designee also must maintain “a record” of the retail purchaser (name and address) of each trailer equipped with the tires “on or in” the trailer when shipped

– Trailer manufacturer (or designee) must keep (maintain) the records for at least five years

Review of the Regulation (con’t)


Review of the Regulation

• Does this apply to us? “Yes,” according to NHTSA’s official response to a past interpretation request:

– “49 CFR Part 574 has two separate recordkeeping requirements. Both sections have been in effect, largely unchanged, since 1971. The first, 49 CFR §574.7, applies to tire manufacturers and requires them to maintain tire registration records that they receive from tire dealers and distributors. The second section, 49 CFR §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. These two recordkeeping requirements are separate requirements. Thus, NATM's members are required to keep records of all new tires they place on their motor vehicles prior to first sale subject to the requirements of 49 CFR §574.10.”


• What happens when you ship trailers to adealer with no tires “on or in” those trailers?According to §574.9, the companionregulation to §574.10, your trailer dealerbecomes a “tire dealer” with its own set ofrecordkeeping obligations. 49 CFR§574.9(b) provides:

Each person selling a motor vehicle to first purchasers, for purposes other than resale, that is equipped with new tires that were not on the motor vehicle when shipped by the motor vehicle manufacturer is considered a tire dealer for purposes of this part and shall meet the [tire recordkeeping] requirements specified in §574.8.

Review of the Regulation (con’t)


Scenarios• For the Trailer Manufacturer:

– Direct trailer sale to consumer– Trailer shipped to dealer with wheels and

tires attached– Trailer shipped to dealer with wheels and

tires NOT attached, but designated forattachment to specific trailer

– Trailer shipped to dealer with wheels andtires NOT attached and not designatedfor attachment to specific trailer

– Tires shipped to dealer for dealer stock– Tires-only sold directly to consumer

• We’ll visit these again later


What information do we record?

• Tire information ( size, brand,and batch or lot) or TireIdentification Number (TIN)

• Name and Address of the end-user/customer (first retailpurchaser)– This “customer” is not the dealer


What is the Tire ID or “TIN”?

• A series of letters and numbers in prescribed groupings embossed on or molded into the tire as follows: – Starts with “DOT”– 1st Group – Manufacturer Identification– 2nd Group – Tire Size– 3rd Group – Type (optional)– 4th Group – 2 digit week & 2 digit year of

manufacture (i.e. 2607)


Where is the Tire ID?


Example on the Tire


How do we collect the information?

• Trailer manufacturer must get the information back from either the trailer dealer, the consumer, or the tire manufacturer, unless it sells directly to the consumer or ships the tires loose or separate from the trailer.

• Some possible means:– Trailer/vehicle warranty cards– Other mail back forms or cards– Dealer reports or interface systems– Third-party tire registration services

• May require making the trailer dealer your “designee” in order to complete the record keeping process and fulfill your obligations under §574.10– how to “designate” will be discussed later


Warranty Return Card

Tire info from VIN software


Warranty Return Card


Use an MCO return card


Third-Party Registry Services


How do we maintain the information?

• Hard copy file• VIN Software

• Designate third party to share portionof recordkeeping obligations.Candidates include:– Trailer dealer/distributor

– Tire manufacturer/supplier

– Third-party registry service• Maintain for at least five years


Software’s Tire Record


Software’s Customer Record


Keep the Record 5 Years


The “Designee” Alternative

• Establish a Designee– Dealer– Tire Manufacturer– Third-party Registration Service

• “Designee” status creates legal relationship – requires mutual consent – best if in writing– may be governed by state law– consult attorney


Sample Designee LetterI


Designee Letter

tire recordkeeping: understanding and implementing ... - natm

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