We are writing in response to your May 2015 editorial, “We Can Do Better: Return to Mandatory Registration ASAP.” While we agree with your premise that the current system for registering tires needs to be improved, TIA is opposed to any legislative action that would overturn voluntary registration.
First and foremost, there is a proposed amendment in the GROW AMERICA Act that must be considered before discussing any hypothetical solutions. No one can predict what NHTSA will do if they are given the unrestricted authority to initiate new rulemaking. By excluding the distributors/dealers owned or controlled by the manufacturers, the independent channel would be held to a much higher, and unfair, standard.
[Editor’s Note: The GROW AMERICA Act (Generating Renewal, Opportunity, and Work with Accelerated Mobility, Efficiency, and Rebuilding of Infrastructure and Communities throughout America Act) is a $400 billion, four-year surface transportation bill presented to the House of Representatives by the Obama Administration in May. The hallmark of the 361-page bill is significant investment in infrastructure rebuilding, and expansions of freight shipping by rail and improved regional and local public transportation. Buried in the massive bill is a 131-word passage regarding tire registration by independent sellers, a passage that is most obviously not well-considered and lacking in vital details. The entire text of the tire registration section sis at the end of this Letter to the Editor.]
TIA represents thousands of tire retailers who are aware that the current system is antiquated and needs to be updated with technology that makes it easier for both themselves and consumers. And contrary to your remarks that dealers are in favor of “undoing a bad law,” we find that none of them have indicated they would support a return to mandatory tire registration. Rather than turn to the government for a solution to the problem, the industry needs to come together and develop a system that works for both the manufacturers and the independent retailers.
We believe that returning to mandatory registration under the current proposal in Congress is an attempt by the tire manufacturers to place the burden for recalls on the backs of small businesses. The tire manufacturers have yet to release any technology to make the process easier or more effective for registering their products. Even more troubling is the fact that RMA is unwilling to work with TIA to develop a solution that does not involve additional legislation.
The current proposal before Congress is completely slanted in favor of the tire manufacturers. Therefore, TIA will continue walking the halls of Congress to ensure the industry does not return to an ineffective tire registration system.
TIA believes tire registration is vital for consumer safety. We are willing to work with the tire manufacturers to develop solutions within the framework of the voluntary legislation in effect today. TIA’s position is that creating new regulatory burdens on our independent tire dealer members is unnecessary.
We propose that every new tire includes a universal barcode or RFID tag that can be easily scanned to capture the tire identification number (TIN). This would allow retailers to scan the TIN and permanently link it to the vehicle identification number (VIN). As you know, the tires normally stay with the vehicle and not with the owner. This TIN-to-VIN method for registering tires would lessen the burden on retailers and close the gaps in the current system created by ownership or address changes.
The 2015 TIA Board of Directors
Entire Text of GROW AMERICA Act portion dealing with Tire
Sec. 4112. Tire Registration by Independent Sellers
Subsection (b) of section 30117 of title 49, United States Code, is amended by revising paragraph (3) to read as follows: “(3) The Secretary may initiate a rulemaking to consider requiring a distributor or dealer of tires that is not owned or controlled by a manufacturer of tires to maintain records of the name and address of tire purchasers and lessors and information identifying the tire that was purchased or leased, and any additional records the Secretary deems appropriate. Such rulemaking may also consider requiring a distributor or dealer of tires that is not owned or controlled by a manufacturer of tires to electronically transmit such records to the manufacturer of the tire by secure means at no cost to tire purchasers or lessors.”