• First, RMA continues to mislead the tire industry by using a figure of 10% to represent tire registration levels. By continuing to misuse this 25-year-old figure, RMA is doing an injustice to tire dealers who are doing a great job of registering tires and increasing tire registration levels.

CIMS works directly with over 12,000 tire dealers and knows definitely that tire registration levels are dramatically higher than the 10% that RMA consistently quotes. Even NHTSA has used a much more realistic figure of 30% tire registration level in 2003.

• Secondly, the article stated “RMA feels the return rate would improve substantially if consumers could use the Internet to register tires.” Consumers currently have the option of registering their tires via the Internet. In 2003, NHTSA interpreted the tire registration regulation to allow tire manufacturers and brand owners to give consumers the option of registering their tires online vs. mailing the tire registration form. Tire dealers are still required to give the tire registration form to the consumer at the time of purchase.

• Third, what difference will there be in the inaccuracy or incomplete registration information whether it be on a registration form or via a Web site? CIMS has been registering tires for over 35 years and receives data in many forms including handwritten, POS electronic and manually keyed information. The inaccuracy and incomplete percentages among these different forms of data are nearly identical; human error cannot be prevented.

This brings us to the question: “Who is concerned about the negative effect and additional liabilities that will be placed on the tire dealer?” Electronic tire registration without any specific guidelines in place will hurt tire registration rather than improve it. Companies will pop up overnight in an attempt to exploit tire dealers by offering what they believe to be a legal way for tire dealers to comply with the NHTSA tire registration regulation.

CIMS has already witnessed new companies charging tire dealers and consumers anywhere from $0.40 to $1.50 per tire to register their tires. Who knows if these companies will be in business in six months? What happens to the tire registration information consumers and dealers have submitted to them?

Finally, tire registration is a consumer safety issue. The only way a consumer can receive a direct and timely notification that their tires are involved in a safety related recall is by having their tires registered.

Tire registration should not be about creating new ways to charge tire dealers to comply and should not be an attempt to find new revenue sources by gouging the consumer. Successful tire registration depends solely on the tire dealer. If the tire registration process becomes too burdensome, costly or confusing, tire dealers will do nothing.

Paul Kruder
President
CIMS
Akron, OH