Tire registration can be an inconsequential function of the retail tire business-until there is a tire recall. Then concerned customers without registered tires bring their cars to the tire shop so the mechanic can raise the car on a lift and identify the tire serial number on the inside sidewall.
Such a procedure-especially if the tire isn't on the recall list-can cost the dealership time and money. Or worse, an unregistered and unwitting customer continues to drive with potentially defective tires.
According to federal regulations, tire retailers are responsible for providing tire registration cards to purchasers and, in turn, the customers can voluntarily mail in the completed registrations to the tire manufacturers so they can be easily contacted if their tires are recalled for defects or other safety issues.
But this simple process intended to quickly remove unsafe tires from the road is often thwarted at various points in the cycle. A manufacturer may fail to provide the registration cards to retailers, a retailer may forego handing out the card to the tire purchaser or the consumer may not bother mailing in the card.
It's an issue-and a law-that has nagged the tire industry for nearly a quarter century. And since there has been no apparent enforcement of the federal regulation, it's one of those laws that isn't always obeyed.
Returning the form
Cooper Tire & Rubber Co. estimated that only about 3 or 4 percent of its tires sold at retail are registered. ``It's disappointing,'' said a Cooper spokesperson.
Other tire manufacturers said they couldn't provide data on how many of their tires are registered. The Rubber Manufacturers Association (RMA) estimates only about 10 percent of consumers register their tires.
That concurs with the National Highway Traffic Safety Administration's (NHTSA) only evaluation of the regulation, done in 1986. At that time, NHTSA estimated that under the pre-1982 requirements-in which retailers had to complete the registration-18 percent of tires sold by independent tire dealers were registered, dropping to 11 percent under the new system.
Meanwhile, CIMS Inc., an Akron-based tire registration services firm, puts the number somewhat higher. It estimates that 28.6 percent of aftermarket passenger and light truck tires in the U.S. are registered properly.
The current regulations were the result of lobbying by the National Tire Dealers & Retreaders Association (NTDRA)-predecessor to the Tire Industry Association's (TIA)-to make tire registration voluntary-switching the responsibility to mail in registration forms to the consumer from the dealer. NTDRA launched the lobbying effort after NHTSA targeted a few tire dealers for non-compliance and fined them thousands of dollars, according to TIA Executive Vice President Roy Littlefield.
According to the Surface Transportation Reauthorization Act of 1982, dealers must fill out the required information-the dealership's name and address and the tire identification number-on a registration form provided by the tire manufacturer and then hand it to the customer. It's strictly voluntary for the buyer to add his or her name and address and a postage stamp to the postcard-sized form and mail it back to the tire maker. The law applies to all highway tires.
Failure to fill out and distribute the registration cards to tire purchasers can result in a $1,100 per tire penalty up to a maximum of $880,000. ``I've not heard of any dealer getting fined, but it's something we always worry about,'' Mr. Littlefield said.
He noted that most federal agencies have suffered budget cuts and thus may have put enforcement of regulations such as this on the backburner. ``But they can be very subjective on when and where they enforce it,'' he said.
A NHTSA spokesman confirmed that no one has been prosecuted under the current regulation and admitted that staff ``could be assigned to enforce the regulation, but they are currently busy with assignments that have higher safety significance.''
In Canada, Transport Canada is responsible for compliance.
TIA has tried to get the word out about the law to its members through association publications and at dealer meetings. ``Since we lobbied for the change, we try to step up to the plate about it,'' Mr. Littlefield said.
Mr. Littlefield said he believes there are two reasons for a low compliance rate among tire dealers: ignorance of the law, especially among dealership employees, such as salespeople; and inconvenience, particularly among small tire shops that must deal with mounting regulations and paperwork. ``I don't think (the regulation) is common knowledge,'' he said. ``I think dealers want to deal with as little paperwork as possible.''
``I guess the main reason (tire dealers don't provide registration cards) is that it is too hard,'' concurred Alison Heiser, former vice president of marketing for Michelin Americas Small Tires. ``The process requires the dealer to transcribe the DOT number from each individual tire that's out in their bay onto a card that is at their sales counter. And it's just too hard to do. That's just too much work.''
Goodyear's manager of global product standards and regulations, John Rumel, said he once asked a tire dealer for a tire registration card and was told not to worry about it-he was told, instead, ``If you ever have a problem, just bring the tires back.''
Mr. Rumel said he believes that may be as much a reason why many dealers don't hand out registration cards as anything else. ``If you have a tire problem, they want you to come back to them,'' he said.
Not all tire dealers are complying with the law, agreed Mr. Tire Inc.'s director of operations, Roy Wilkins. ``I'd say the majority of the major companies are doing it.''
He said the Baltimore-based tire dealership with 40 stores has been distributing registration cards for a long time, even before the law took effect. The dealership fills out the cards and hands it to the customer to mail in later. But occasionally, if the customer balks about postage or the inconvenience, the dealership will send in the cards for him or her.
On the other hand, Joe Unrein, co-manager of Becker Tire & Treading Inc. in Great Bend, Kan., said he was unaware of the regulation until two years ago during the wake of the major Firestone Wilderness AT/ATX tire recall. Since then, his store has been conscientious about handing out the registration cards to customers.
Like Mr. Tire, Becker Tire sometimes takes the extra steps and completes and mails in the registration if a customer cannot. But Mr. Unrein thinks generally, customers don't mail in the registration cards because it's an inconvenience. He said his staff has discussed whether to put stamps on the cards as an added incentive.
Another reason for the lack of consumer cooperation may be the misperception that once registered, the consumer's name will end up on a mass marketing list, said Linda ``Lyn'' Lovell, director of product performance for Goodyear. ``Customers need to understand that we are not permitted to use that information for marketing purposes, that it's just used if there's a need to go out and get some quantity of product back,'' Ms. Lovell said.
From the perspective of cost, tire makers would prefer to contact as many customers as possible through their registration lists rather than have to undergo the expense of a major media recall alert, she added.
Paul Kruder, founder of Akron-based CIMS, which sells and records registration cards and acts as a clearinghouse for several manufacturers, claims that among the top 100 tire dealerships, he has seen a significant increase in registration during the last couple of years. That group, he said, has an estimated 50-percent return rate with the potential of approaching 80 percent.
Much of that can be attributed to salesperson training and point-of-sale registration. Several large chains have adopted electronic registration at the sales counter or handle sending in the registration cards for the customers. For example, about two years ago Bridgestone/Firestone Retail and Commercial Operations implemented electronic registration in its 1,600 company-owned stores in the U.S., thus eliminating the need for distributing registration cards.
CIMS also tries to simplify the process for dealers by selling an ``all-brands'' generic registration card to replace the myriad of brand-specific cards.
In addition to encouraging more dealers to fulfill their responsibility, CIMS also is waging a consumer awareness campaign and recently sent out information packets to 140 media outlets around the country.
CIMS said registration benefits tire dealers because during a tire recall shops can waste valuable time putting customers' vehicles on a lift to check if a tire identification number is subject to the recall.
And, unlike the Firestone Wilderness AT/ATX recall that generated massive media coverage, most tire recalls involve less than 1 million tires and thus receive little or no media attention, said Jerry Munger of CIMS. So consumers usually are unaware of a recall unless they are registered and receive direct manufacturer notification.
``What baffles me is that we don't have 100-percent registration when we're in the computer age now anyway,'' said Clarence M. Ditlow III, executive director of the Center for Auto Safety. ``How many tire sales today are cash sales? If you do a credit card scan, you'll already have the buyer's name and address and you could add the tire ID number then and there. Or you could put a bar code on the tire with the ID number and simply scan the tire.''
Is there a way to improve the system? Mr. Wilkins of Mr. Tire Inc. said while there are ways to improve the process, the main thing is: ``The public needs to be made more aware of the purpose of registration.''
``I think technology could be our friend in this case,'' said Ms. Heiser. ``Michelin really would like to see a completely different level of compliance in terms of tire registration.... Electronic data transaction, RFID (radio frequency identification) on tires, online registration through the Internet-all these things could help us. But we're still working through some of the old legislation at NHTSA in order to make sure we can make use of technology.''
Michelin and several other tire manufacturers have or will soon implement online tire registration on their Web sites. NHTSA recently said electronic registration is an acceptable avenue, but it does not replace a dealer's obligation to distribute registration postcards. The statement was a response to a request from the RMA to allow online registration. CIMS had balked at the request.
The postcard format of the registration card ``is not a 21st-century kind of approach to registration,'' RMA President Donald Shea said. ``Our view was that, notwithstanding the protestations of some who may have a vested interest in confining registration to one mechanism, our approach is that the more mechanisms that can be used by motorists, the better off everyone will be.
``We don't have a self-interest in this, other than the self-interest of making sure that if there is a recall, required for whatever reason, we are more easily able to reach out to motorists.... The Internet certainly has a significant role to play in commerce; why wouldn't it have a significant role to play in tire registration?''
CIMS is staunchly opposed to Internet registration, which Mr. Kruder contends will confuse consumers and require extra paperwork for dealers. Since the Web sites ask consumers to enter the tire identification number, one number entered wrong can void the registration, he said. And Internet registration doesn't eliminate the registration cards. Rather, dealers would have to handle distribution of both the cards and notices explaining how to register online.
Reporter Miles Moore contributed to this report.