Voluntary Tire Registration Practices at Tire Dealerships

To Put This in Your Hands

While scanning a recent TIA email about its government affairs, I was dumbstruck by one statement that smacked me hard:

“Currently, about 17% of tires sold are registered.”

One-seven-percent, as in 17 out of 100 tires sold are actually registered so that the owners can be quickly and easily notified should there be a safety-related need.

That figure, says TIA, does not include OE tires or those sold by mass merchants, chain stores and company-owned locations. Those tires are, apparently, registered 100 out of 100 times. Certainly at a clip exceeding 17%.

That 17% figure is said to be “a consensus” of what NHTSA, tire manufacturers and CIMS (the industry’s prime provider of tire registration materials and systems) “gen­- erally report” as representative of the independent tire dealer body.

To put this in volume context, out of the 227.5 million replacement consumer tires that the RMA counted in 2013, independent dealers sold an estimated 145.3 million of them. So that 17% translates into a mere 24.7 million tires being registered, enough for roughly 6.2 million cars and pickups.

TIA’s point in pointing out this nearly invisible systemic failing is rooted in the high pressure presently being exerted on NHTSA in the wake of its failings in connection to the GM recall debacle and new revelations about its failings in the Ford-Firestone fiasco 14 years ago and the more recent “investigative report” hack job by ABC-TV that did rightfully point out that most drivers don’t know about tire recalls because their tires were never registered.

Few government agencies have taken so many deep body blows, and you know at some point it will start hitting back.

Even as NHTSA is getting bullwhipped by Congress, the ABC-TV reports in May also attracted the attention of the National Transportation Safety Board, which is now very intrigued by NHTSA’s tire failings and those of the tire registration system.

In unveiling the NTSB’s new tire probe, administrator Don Karol, said: “We’ll be examining the tire recall process to identify the responsibilities of the regulator, the manufacturer, the tire sales facility, and the consumer to determine if safety improvements are warranted.”

TIA executive vice president Roy Littlefield says, “There is a lot of pressure on NHTSA to get the number of tires registered up. They are preparing letters to be sent to manufacturers, distributors and retailers. I sus­pect that most retailers are not even aware of the law.”

To put this in historical context, the Surface Transportation Act of 1982 made tire registration “voluntary,” coming after 11 years of a mandatory system that tire dealers and the then NTDRA (now TIA) loudly decried. The voluntary system still mandated that all on-highway tires be registered, but dealers only had to provide registration cards, fill in the DOT numbers, and complete the dealer identification portion.

Customers were left to voluntarily fill in their names and addresses, voluntarily lick a stamp, and voluntarily pop the card into the mailbox.

In the intervening 32-plus years, tire registration has been made easier for dealers through their POS software and CIMS’s own software and now smartphone app. Even with those vast technology changes, confused dealers still think the “voluntary” part refers to them, not the buyer. And consumers voluntarily treat tires like blenders and shavers and hair curlers for which they rarely bother to send in the warranty and product registration cards.

What has not changed in the three decades since voluntary registration was instated is the fact that tires aren’t being registered at any higher a rate. It’s only gotten worse.

A 1986 study by NHTSA showed that while only 18% of all on-highway tires were registered under the evil mandatory system (a truly amazing definition of “mandatory”), over the first four years of the dealer-friend­ly voluntary system, only 11% were registered.

As in 11 out of every 100 consumer tires sold by independent tire dealers.

NHTSA’s next shot at fixing the problem came in 2000 with the TREAD Act, which was the direct result of the multiple tire recalls and vehicle safety concerns surrounding the Ford-Firestone situation. That game-changing bill was crafted through dozens of Congressional hearings, months of constituent meetings, hours and hours of outside lobbying, votes by both the Senate and House and a well-publicized signing ceremony – with nary a word directed at solving the failings of the tire registration system.

To my knowledge, after 1986 NHTSA has never conducted another tire registration compliance study. Thus the now accepted 17% figure.

To my knowledge, no tire dealer has ever been fined for failing to pass along to a customer tire registration cards – a fine that can reach $10,000 per tire up to a maximum of $400,000 for each sale – under the present voluntary system.

To my knowledge, at 11% everyone was happy with such a ridiculously low result. The good news, I suppose, is that we’ve improved by six points.
It would, however, be an equally massive error to pin the blame entirely on tire dealers.

To put things into context, back in 1981 and even when the Ford-Firestone fiasco occurred in the 1999-2000 frame, there were still daily newspapers – sometimes two – in every city. When real news about the multi-million tire recalls came out, it was primarily through newspapers that drivers learned the real details about what was happening and if their particular tires were affected. Whether they had registered their rubber or not, all they needed to do was compare the news story to their sidewalls to find out if they were impacted.

Nearly 15 years later, the newspapers that remain in our media-shifted universe are slimmer and trimmer and carry very little news. Tire recall information appears in very few places; unless it is a significant action, Tire Review relegates recall notices to our website and e-newsletter. Unfortunately the best way to get the news out would be to interrupt “Dancing With the Stars” with a breaking news update.

ABC-TV proved it would much rather take blind potshots at retailers, never considering the buyer’s role in a failed process.

“We have to do our part to educate our members and other retailers,” says Littlefield. “I am concerned that short-term NHTSA will start fining retailers like they did in the early 1980s, and long-term may try to go back to a mandatory system.”

To put that into actionable context, we need to step up. Yes, it is a voluntary system, and we’ve already noted the mandatory role dealers have to play. If you follow the letter of the law, it becomes inherent on the customer to follow through and register their tires.

What happens, then, if you break the law?

To put this in smart-business context, we know most consumers won’t take the time to follow through. So why not go the next step and comp­lete the registration cycle – right there at the counter? Why not earn greater respect and notice from clients by helping them through a system they simply don’t understand? I know that a lot of dealers already provide this customer service; it’s a small gesture that can add so much to your business.

Doing this won’t insulate you from NHTSA’s anticipated tough-guy approach. As a nation we regulate to the lowest common denominator; never ahead of the problem, always in reaction, and always regardless of the majority. If 20 dealers take that extra step and push customers to “voluntary” registration and one guy doesn’t, everyone suffers the brunt of the resulting legislative intrusion.

We know how much tire dealers love it when “government” invades your space, tells you what to do, and passes so many regulations that it’s “impossible to do business.” Consider, though, how that one apple causes these things to come about.

We cannot afford to sit on our hands and wait for the fates to strike. The smart thing – the only thing – to do now is redouble our efforts in the field with customers, and for TIA and others to monitor progress so that we can move the needle, get a more accurate picture of the results, and have a strong statement to make on Capitol Hill when the storm comes.

No one wants to be the low-hanging fruit when a government agency badly needs a win.

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