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Tire Recordkeeping Requirements for Dealers
Tire Recordkeeping Requirements for Dealers By Terry Jones, NATM Technical Director
Readers may have noticed articles on tire recordkeeping in the past but such a complicated, far reaching regulation with consequences for non-compliance warrants regular coverage. Further, past articles have focused almost entirely on manufacturer’s requirements and have only briefly discussed a dealer’s requirements. This article intends to provide a simple overview of requirements for dealers as supplement to more indepth content. Who Needs to Comply? Trailer dealers enter the tire supply chain in various ways that include, but are not limited to, the following situations: •
Selling a trailer equipped with tires that were attached at the time of delivery to the dealer.
•
Selling a trailer equipped with tires that were not attached at the time of delivery to the dealer.
•
Selling tires separately as replacement parts.
•
Servicing and installing tires.
Under these various scenarios, federal regulation contemplates trailer dealers as both tire distributors and tire dealers (see 49 CFR §574.8 and §574.9). While this distinction matters from a regulatory perspective, however a trailer dealer enters the supply chain and becomes involved in the sale of tires, the resulting obligations are the same and all trailer dealers must comply.
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September/October 2021
What Must a Dealer Do? A trailer dealer only has one obligation under the tire recordkeeping requirements: to facilitate notification to purchasers of defective or nonconforming tires. Dealers can fulfill their obligations in several ways. Each methodology described below provides a path for tire manufacturers to contact potentially impacted customers in the event of a tire recall. Provide Tire Manufacturer Tire Registration/Warranty Form/Card Tire manufacturers are required by law (49 CFR §574.7(a)(1)) to provide a blank tire registration/warranty form/card (TIN card) to their customers. This card is then theoretically to be passed through the supply chain to the end-user. If purchasing a trailer from an NATM Certified Member, the dealer should receive a registration/warranty form/card to use. If the TIN card does not make it from the trailer manufacturer to the dealer or if the trailer manufacturer does not provide the tire warranty cards, tire warranty cards can be obtained upon request from the tire manufacturer. Regardless of the method of obtaining the card, the dealer must complete the TIN (Tire Identification Number) information as well as the dealer/distributor name, contact information, and provide it to the customer receiving those tires. Dealers may choose to complete the remainder of the tire warranty card and submit on the customers behalf, but submittal must be transmitted to the tire manufacturer within 30 days at no charge to the customer. For more information, visit 49 CFR §574.8(a)(1)(i).
www.NATM.com
