US DOT/NHTSA Tire Registration Requirements & Recall Management Process



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US DOT/NHTSA Tire Registration Requirements & Recall Management Process Department of Transportation (DOT) National Highway Traffic Safety Administration (NHTSA) Office of Vehicle Safety Compliance (OVSC) JACK CHERN, Ph. D. December 9, 2014 1

Overview Tire Registration Responsibilities of Tire Manufacturers Tire Registration Responsibilities of Tire Dealers and Distributors Recall Process Management 2

Tire Registration Responsibilities of Tire Manufacturers 3

Tire Manufacturer Means As defined in 49 CFR Part 574.7, tire manufacturer is (1)Each new tire manufacturer; and/or (2) Each new tire brand name owner. 4

Tire Manufacturers Responsibilities Each/Every tire manufacturer or its designee shall provide tire registration forms to every distributors and dealers of its tires which offers new tires for sale or lease to tire purchasers (49 CFR 574.7). Each tire manufacturer shall record and maintain, or have recorded and maintained for it by a designee, the tire registration information for at least 5 years. 5

Tire Manufacturers Responsibilities (Cntd.) In addition to the tire registration form, tire manufacturer may voluntarily provide alternative* ways for tire registration, Internet, Telephone, or Other electronic means. *Manufacturer still needs to provide registration form. 6

Tire Registration Form Tire registration form shall contain space for recording the following information as specified in 49 CFR Part 574.7(a)(4)(i) thru (iii), Name and address of the tire purchaser Tire Identification Number (TIN): area must be shaded and filled by seller Name and address of the tire seller or other means by which the tire manufacturer can identify the tire seller: area must be shaded and filled by seller 7

What is TIN (Tire Identification Number)? Current New Tire TIN Full TIN: PP SS MMMM DDDD (between 6 to 12 digits) Partial TIN: PP SS MMMM (between 2 to 8 digits) NPRM New Tire TIN Full TIN: PPP MMMMMM DDDD (fixed @ 13 digits) Partial TIN: PPP MMMMMM (fixed @ 9 digits) Information need to be identified for a tire recall Tire manufacturer, brand name and/or model Tire size Tire TIN (identify if within the scope of a recall?) 8

Tire Registration Responsibilities of Tire Dealers and Distributors 9

Tire Dealers and Distributors Independent Dealer/Distributor - A business that is not owned or controlled by a tire manufacturer or brand name owner. Distributor - A person primarily selling and distributing tires for resale Dealer - A person selling and distributing new tires primarily to purchasers that in good faith purchase the vehicles or equipment other than for resale 10

Tire Registration Requirements (of Independent Distributor and Dealer) Each independent distributor and dealer shall comply with one of the following 3 options: Option #1: At the time of sale or lease of the tire, provide each purchaser with a paper tire registration form containing the entire tire identification number (TIN) of the tire(s) sold or leased to the purchaser, and the distributor s or dealer s name and street address, email address, or Web site The purchaser needs to mail the form back to the tire manufacturer or its designee to complete the tire registration. (a voluntary requirement of the purchaser.) 11

Tire Registration Requirements (Cntd.) (of Independent Distributor and Dealer) Option #2: Record the following information on a tire registration form and return it to the tire manufacturer or its designee on behalf of the tire purchaser, at no charge to the purchaser and within 30 days of the date of the sale or lease: The purchaser s name and address The entire TIN(s) of the tire(s) sold or leased to the purchaser The distributor s or dealer s name and street address, email address, or Web site 12

Tire Registration Requirements (Cntd.) (of Independent distributor and dealer) Option #3: Electronically transmit the following information to the tire manufacturer or its designee by a secure means (e.g., https://) authorized by the tire manufacturer, at no charge to the tire purchaser and within 30 days of the date of sale or lease: The purchaser s name and address The entire TIN(s) of the tire(s) sold or leased to the purchaser The distributor s or dealer s name and street address, email address, or Web site 13

Tire Registration Requirements (Cntd.) (of Independent Distributor and Dealer) If choosing to comply with either Option #1 or #2, the tire registration form provided by the tire manufacturer shall be used. Paper forms must comply with the requirements specified in 49 CFR Part 574.7(a). Multiple tire sales or leases to the same purchaser may be recorded on a single form or in a single electronic transmission. If choosing to comply with Option #3, a statement indicating the effect of the tire(s) has been electronically registered shall be included on the invoice and provide the invoice to the tire purchaser. 14

Tire Registration Requirements (Cntd.) (of Dependent Distributor and Dealer) Each dependent distributor and dealer, selling new tires to tire purchaser: Shall submit, using paper registration forms or secure electronic means, the information specified in 49 CFR Part 574.7(a)(4)(i) thru (iii) to the manufacturer or its designee, not less often than every 30 days, of the tires sold. (a mandatory requirement) If a distributor or dealer selling fewer than 40 tires during a 30 day period may wait until a total of 40 tires are sold, but not less often than every 6 months, to submit the information specified in Part 574.7(a)(4)(i) thru (iii) to the tire manufacturer or its designee. 15

Tire Registration Requirements (Cntd.) (Each/Every Distributor and Dealer) Each/Every distributor and dealer selling new tires to other tire distributors or dealers shall supply to the distributor or dealer a means to record the information specified in 49 CFR Part 574.7(a)(4)(i) thru (iii), unless such means has been provided to that distributor or dealer by another person or by a manufacturer. Each/Every distributor and dealer shall immediately stop selling any group of tires when so directed by a notification issued pursuant to 49 U.S.C. 30188, Notification of defects and non-compliance. 16

Recall Process Management 17

Recall Process Management Once a non-compliance or defect is determined to exist, it must be reported to NHTSA within 5 working days. The mechanism for reporting the non-compliance or defect is the Part 573 filing. Sale of the recalled product must stop immediately. The manufacturer must notify purchasers in accordance with regulatory requirements (Part 577) & replace or repair at no cost to the consumer. The manufacturer must ensure dealers/distributors are made aware of safety recalls and their associated rights and responsibilities. Manufacturers are required to submit quarterly report as outlined in the regulations (Part 573). 18

Recall Process Management (Cntd.) The success of a tire recall relies upon the tire manufacturer s ability to locate the purchasers of the defective tires. Unlike other safety recalls, tire recalls have an expiration of 60 days (49 U.S.C. 30120). Some manufacturers extend beyond that time frame but that would be within their discretion. NHTSA may direct the manufacturer to send a followup notification if the prior notification(s) has not resulted in an adequate number of tires being returned for remedy or replacement. 19

Recall Process Management (Cntd.) NHTSA may recommend the tire manufacturers reach out to the affected owners by Putting up signs by the counters or on the walls of the dealerships; Taking out ads in magazines that cater to the affected crowd (such as RV, trucking or car enthusiast); Posting to the manufacturer s website, facebook account or to forums likely visited by the affected owner. 20

Average Completion Rate of Tires 2008-2013 Mature Recalls 5th Qtr. or Greater 60 50 40 30 20 10 0 2008 2009 2010 2011 2012 2013 # of Recalls 16 6 13 3 16 4 Rate (%) 33 55 45 40 29 52 21

NHTSA s Efforts to Increase Tire Registration & Recall Completion Rate New TireWise Website: NHTSA launched its TireWise (http://www.safercar.gov/tires/index.html) campaign that provides consumers and retailers with essential information about choosing and caring for tires, urging consumers to register purchased tires. Apps: NHTSA launched a new SaferCar app that will provide users free access to key safety information. New Mandatory Safety Recall Notice Label: All manufacturers must use a distinctive safety recall notice label on required mailings that notify owners of recalled vehicles or equipment. 22

NHTSA s Efforts to Increase Tire Registration & Recall Completion Rate (Cntd.) Recall Notification Alert: Consumers and tire dealers can subscribe online at www.safercar.gov to receive an email notification when a manufacturer intends to conduct a new tire recall. Outreach to Tire Industry: Conducted two presentations at International Tire and Exhibition Conference (ITEC 2014) to the tire dealers and tire manufacturers to make them aware of their responsibilities pertaining to tire registration. 23

Thank You Any Questions? Feel Free to Email or Call: JACK CHERN jack.chern@dot.gov (202) 366-0661 24