RMA supports expanding electronic tire registration

March 23, 2007

The Rubber Manufacturers Association (RMA) not only supports proposed rulemaking designed to expand electronic tire registration as a means to improve tire registrations, but also has offered to help get it passed.

"Improving the ability to register tires is pro-safety and strongly supported by tire manufacturers," says Dan Zielinski, the RMA's vice president of communications.

On Wednesday, March 21, the National Highway Traffic Safety Administration (NHTSA) announced it will rule on possible changes to current tire registration regulations to permit an electronic alternative. Current law requires paper cards be made available for this purpose, and allows electronic filing to supplement the paper requirement.

Under 40 C.F.R. §574.7(a)(1), a tire manufacturer must provide a registration form (or card) to "every distributor and dealer of its tires which offers new tires for sale or lease to tire purchasers."

(Last year, the White House Office of Management and Budget (OMB) asked NHTSA to evaluate whether the agency could permit greater latitude for electronic tire registration. NHTSA issued a Federal Register notice in December asking for public comment on the OMB's request.)

In a letter to NHTSA dated Feb. 6, 2007, RMA CEO and President Don Shea wrote that according to data compiled by the RMA, no more than 10% of tire registration cards are currently returned to manufacturers , and "a significant number of these cards are inaccurate, incomplete or illegible."

"RMA strongly believes that this rate of return would substantially improve if the tire registration regulations permitted either the tire dealer or consumer to provide the information required under Part 574 to the manufacturer via the Internet or other electronic means."

The RMA believes the obligations of both tire dealers and tire manufacturers should remain the same.

"Under the current regulations, the only obligation of the dealer or distributor is to provide a registration form to the consumer that includes the tire identification number ("TIN") and the distributor's or dealer's name and address," wrote Shea. "It is not the dealer's obligation to register the tire on the consumer's behalf. The revised regulations should not create any new or additional obligations for tire dealers or distributors."

Tire manufacturers are required to:

* provide the prescribed forms to dealers and distributors, and

* record and maintain the information contained in the forms they receive for at least five years.

"We urge NHTSA to make these changes expeditiously, either by issuing an appropriate interpretation of the existing regulations or by opening a new rulemaking," summed up Shea.

For more information, see Vol. 72, No. 54 of the Federal Register, page 13344, dated Wednesday, March 21, 2007. Any comments to the proposal must refer to the docket notice number (DOT Docket No. NHTSA–06–26554) and be submitted to the Office of Information and Regulatory Affairs, Office of Management and Budget, Att'n: Desk Officer for NHTSA, 725 17th Street NW, Washington, DC 20503. Also identify the proposed collection of information by referencing its OMB clearance number.

Comments must be received on or before April 20, 2007. It is requested, but not required, that two copies of the comment be provided.