Electronic tire registration is fine as a supplement to current regulations, but it doesn't relieve tire dealers of the duty to provide registration postcards to customers, the National Highway Traffic Safety Administration (NHTSA) said.
The agency's interpretation of tire registration rules pleased the Rubber Manufacturers Association (RMA), which requested it. But that doesn't end the concerns of a private tire registration company that said it is ``absolutely critical'' tire dealers understand they must still provide the registration cards.
That company, Akron-based CIMS Inc., also suspects ulterior motives on the part of tire makers for wanting electronic registration.
``I don't think the RMA needed to request permission from NHTSA for this,'' CIMS President Paul Kruder told Tire Business. ``The only reason I can see they want to do this is for use of the data as sales information.''
Use of tire registration information for any purpose except a recall is forbidden by law, and Ann Wilson, RMA senior vice president-government affairs, said tire manufacturers have no intention of violating that law. ``All our member companies are familiar with the statute, and none of them would try to skirt it,'' she said.
Ms. Wilson wrote the agency March 28 asking it to allow electronic registration in addition to the long-standing postcard requirement.
Allowing electronic registration, she said, could only improve registration rates significantly. ``No more than 10 percent of tire registration cards are currently returned to manufacturers, and a significant number of these cards are inaccurate, incomplete or illegible.''
But CIMS argued against electronic registration. Dealers would still have to provide postcards, CIMS said, but would also have to provide written instructions on how to complete tire registration via the Internet.
The RMA's 10-percent figure for tire registration was outdated and based on NHTSA data from 1986, the registration firm said. CIMS estimated that 28.6 percent of tire registration forms are properly filled out and returned.
In a letter dated July 18, NHTSA Chief Counsel Jacqueline Glassman said the agency would allow electronic registration to supplement but not replace the postcards, which are required by law.
``We do not agree with CIMS that supplemental electronic registration would create confusion,'' Ms. Glassman said. ``Moreover, since electronic registration would be supplemental and voluntary, it would not result in additional burdens.''
Ms. Wilson said she was satisfied with Ms. Glassman's interpretation of registration law. ``The supplement may allow consumers in this electronic age to register their tires more easily,'' she said, adding that the RMA never intended electronic registration to replace the current statute. ``The bottom line for the industry is that we want to see as many tires registered as possible.''
CIMS, however, is concerned NHTSA's interpretation could cause confusion among tire dealers, said Jerry Munger, the company's marketing manager. ``It is absolutely critical that dealers understand this is supplemental, and that they must still provide customers with a proper tire registration form,'' he said. ``When they changed the regulations from mandatory to voluntary registration, tire dealers interpreted it as meaning they no longer had to supply the cards. Now they could just tell their customers they can register their tires on the Web.''
Kumho Tires USA, Falken Tire Corp., Yokohama Tire Corp. and Pirelli Tire North America Inc. all currently have links on their Web sites to electronic tire registration forms. Kumho has posted a paragraph titled, ``Why You Should Register Your Tires.''
``In the near future, government regulations will require consumers to register their tires with the manufacturer,'' the paragraph states. ``You should be aware that independent tire dealers and distributors are not required to register for you.'' In fact, the only legal requirement is for tire dealers to provide registration cards.
Mike Leverington, marketing manager for Kumho, acknowledged the error and said he would correct it. The point, however, is that Kumho is trying to encourage as many of its customers as possible to register their tires in the face of massive consumer and dealer indifference, he said.
``I don't believe tire dealers are doing a very good job of telling consumers about how important it is to register their tires,'' Mr. Leverington said. ``If I were a dealer, I'd staple the cards to the invoices. Whether the RMA or CIMS is right about the percentage of tires being registered, it's still a pretty pitiful figure.''