NHTSA Proposes to Remedy Two Issues by Publishing a Notice of Proposed Rulemaking for Tire Identification and Recordkeeping
The National Highway Traffic Safety Administration (NHTSA) has issued a Notice of Proposed Rulemaking (NPRM) to increase the manufacturer identifier portion of the tire identification number (TIN) from two to three symbols and to standardize the length of the TIN. The intent of this proposal is to increase the number of unique combinations of characters for identifying individual manufacturers of new tires and to eliminate confusion that could arise from variable length of TINs.
On July 24, 2014, the NHTSA published in the Federal Register (Vol. 79, Number 142, Docket No. NHTSA-2014-0084), an NPRM amending 49 CFR Part 574 Tire Identification and Recordkeeping. The NPRM expands the first portion of the TIN to require three symbols for the manufacturer identifier to remedy the situation of the NHTSA running out of unique two symbol codes to identify new tire plants. The entire supply of 900 plant codes has been depleted and in order to assign new plant codes, the NHTSA has found it necessary to reissue previously issued, but currently unused plant codes. At the current rate of new plant code issuance, the NHTSA will not run out of three symbol manufacturer codes for decades, if not longer. The NPRM also proposes to standardize the length of the TIN to thirteen symbols for new tires and seven symbols for retreaded tires. This will make it easier to identify TINs with missing symbols and may assist consumers with identifying whether their tires are subject to recall. Also, it may help prevent crash investigators from recording partial TINs rather than full TINs on their report.
In January 1971, the NHTSA established a requirement that a TIN must be labeled on one sidewall of each tire that is newly manufactured or retreaded for the purpose of facilitating notification of purchasers of defective or noncompliant tires. Furthermore, the information contained in the TIN may be used by consumers to obtain information about the tire such as the actual manufacturer of the tire (in the case of a tire sold under a different brand) and the date of manufacture. Part 574 also provides for the registration of tires, including the collection of the TIN and the contact information of purchasers of tires, to enable manufacturers to notify tire owners of recalls.
It is the NHTSA’s intent that, if adopted, the amendments proposed in this NPRM would be effective immediately for new manufacturers and existing manufacturers opening new plants. This NPRM would make the new standardized length TIN mandatory for manufacturers using a three symbol plant code. Manufacturers who have previously been assigned a two symbol plant code may continue to use the existing TIN grouping requirements (including the use of the optional codes) until they begin using a three symbol plant code. This plan will allow manufacturers to begin using both the three symbol plant code and the thirteen symbol TIN at the same time. This NPRM proposes to make the use of the three symbol plant code and standardized TIN length optional for existing manufacturers, with two symbol plant codes beginning immediately upon issuance of a Final Rule implementing this proposal. The NHTSA is proposing that mandatory compliance with the use of the three symbol plant code and thirteen symbol TIN would be required beginning not sooner than five years after publication of a Final Rule implementing this proposal. This will give manufacturers sufficient lead time before they are required to use a three symbol plant code and thirteen symbol TIN. For existing manufacturers with two symbol plant codes, immediately upon publication of a Final Rule the NHTSA is planning to issue new three symbol plant codes in place of each two-symbol plant code. For nearly all manufacturers, the NHTSA will assign a "1" symbol in front of each existing two symbol plant code.
Some areas where the NHTSA is specifically seeking comment are:
- Is it necessary to make technical amendments to any of the tire labeling regulations in light of the proposed changes?
- Should there be additional lead time for low volume tire lines? Relief for low volume manufacturers could consist of longer lead time or a process to petition the NHTSA for continued use of an existing plant code. The NHTSA will also consider additional suggestions for how relief could be granted if necessary.
- What is the appropriate production threshold for determining whether a tire line could potentially be subject to any relief from the five-year lead time?
Comments regarding this NPRM must be received by NHTSA by August 25, 2014