NHTSA revises tire plant ID numbers
By Miles Moore, Senior Washington Reporter
WASHINGTON (April 14, 2015) — The National Highway Traffic Safety Administration (NHTSA) has revised the format of the tire identification number (TIN) system used to identify tire factories and tire production dates to allow more plant codes to be issued.
NHTSA issued its final rule on April 13, making good on proposals issued last year to make fundamental changes to the TIN format. The notice, published in the Federal Register, goes into effect immediately.
To expand the number of available tire manufacturer plant codes in TINs, NHTSA has changed those codes to three symbols from two. Plant codes are necessary in TINs to identify where a tire was manufactured.
Also, NHTSA has standardized the length of TINs to 13 symbols for new tires and seven for retreads. This was done, the agency said, to eliminate confusion from the previous variable lengths of TINs.
The existing system provides tire plant code possibilities of roughly 980 number and letter combinations. NHTSA has issued 960 codes, but about 80 are for plants that are closed or no longer make tires, with another 30 or so for retread plants, factories that don't make tires or make only bicycle tires and/or tubes, according to Tire Business' annual analysis of the codes.
NHTSA proposed the changes to TINs on July 24, 2014, and 13 interested parties commented on the proposal, including the Rubber Manufacturers Association (RMA), the National Transportation Safety Board (NTSB), the Japanese Automobile Tyre Manufacturers Association (JATMA) and the safety advocacy group Safety Research & Strategies Inc. (SRS)
The final rule extends the lead-time for phasing in the new codes to 10 years from five, as suggested by the RMA and the Tire and Rubber Association of Canada (TRAC). NHTSA agreed with the RMA and TRAC that ease the impact of the final rule on existing plants.
Also, the final rule eliminates the requirement for a 50-millimeter blank space following the date code. The RMA, TRAC, JATMA and several other commenters objected to this provision because it would be confusing and expensive. Also, the RMA and TRAC said Canadian tire manufacturers needed this space for Canada's National Safety Mark.
“(The RMA and TRAC) argued that this proposed requirement represented a barrier to trade that was not justified by safety,” the agency said in the final rule.
NHTSA rejected the comments from SRS and the NTSB that the agency should require a non-coded date of manufacture for TINs.
“Given that we did not propose any changes to the date code portion of the TIN, nor did we discuss or request comment on any potential changes to the date code, such a change may be beyond the scope of this rulemaking,” the agency said.
“Even if it were in scope, however, we do not believe a change to the date code is necessary for consumers to determine when their tires were manufactured,” it said.
Dan Zielinski, RMA senior vice president of public affairs, said his association is happy with a number of aspects of the final rule.
“Overall, NHTSA responded very positively to our recommendations,” he said. “This final rule came out pretty close to what we requested.”
Petitions for reconsideration of the final rule are due May 28, NHTSA said. The notice may be found by clicking here.
The Tire Industry Association (TIA) said it supports the changes to the Tire Identification and Recordkeeping requirements introduced by NHTSA.
Increasing the length of the TIN for new tires was necessary because the agency has run out of two-symbol codes to identify new tire plants, TIA said, and standardizing the length at 13 symbols is beneficial because varying lengths make it confusing to distinguish between partial and full TIN on both sidewalls. By allowing existing plants to keep their two-symbol code and add the number “1” before it with a 10-year lead time for full compliance, the association said the burden on tire manufacturers should be minimal.
TIA said it also is pleased that regulations for the retread TIN are not affected by the new requirements. The association agrees with NHTSA's assessment that the retread process will not be modified so the result of the final rule will be negligible, it added.
The RMA said it commented to NHTSA after its membership voiced concerns over some aspects of the proposed rule.
“RMA appreciates NHTSA's effort to create an effective regulation to continue its obligation to provide plant codes to manufacturers while making common-sense accommodations to limit unnecessary costs,” Mr. Zielinski said.
The association had urged NHTSA to drop a proposed requirement for a 50-millimeter blank space after the TIN, pointing out that the additional space “would add significant cost to the rulemaking with no safety benefit while causing extensive remodeling to tire molds around the world.” The final rule eliminated the proposed 50-millimeter requirement. Additionally, RMA noted that it successfully argued to NHTSA that tire manufacturers be given 10 years to phase in the new rule's requirements because a majority of tire molds last as long as 10 years, and it said NHTSA agreed with the association.
“RMA agrees that NHTSA needs to change the TIN to a three-digit plant code,” Mr. Zielinski said. “RMA members had several concerns with the proposal that would have needlessly raised costs to tires produced in the U.S. and NHTSA agreed to make key changes.”
In response to other stakeholder requests to change the date stamp portion of the TIN, NHTSA said, “…we do not believe a change to the date code is necessary for consumers to determine when their tires were manufactured.”
NHTSA added that sufficient information to understand the date stamp is available online or by asking a tire dealer.”
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