For purposes of NATM’s Compliance Verification Program (CVP), members are required to follow both Department of Transportation regulations relating to tire recordkeeping, as well as the three-step process voted on by NATM’s Board of Directors in July of 2019. The Department of Transportation’s regulations relating to tire recordkeeping can be found in 49 CFR §574.8 through 574.10. The main way these recordkeeping requirements will impact members depends on whether or not members are shipping your trailers with tires attached to the trailer or not, but please note that in either situation members will have to maintain certain records. Additionally, a member’s tire distributor should be providing members with a TIN form/card that can be given to end consumers and mailed back to a member’s tire manufacturer with relevant TIN information for the tires on the trailer.
Selling or Shipping Trailers with Tires Attached
For members who are either selling trailers with tires attached directly to consumers or selling them to dealers with tires attached, members will be required to have a method in place to match trailer VIN information to the corresponding TINs of the tires that are attached to the trailer. The graphic above can assist with locating the TIN for tires members are using.
Once the TINs have been located, members will be required to record and store this data, either in digital or paper copy to ensure members have access to those records. The intent of these recordkeeping requirements is to ensure that trailer manufacturers can assist in locating tires in the event of a recall.
Shipping Trailers without Tires Attached
For members who are shipping trailers to dealers without tires attached, a system will still need to be in place to track the batches of VINs and TINs that are being sent to specific dealers, as a requirement of NATM’s Compliance Verification Program.
The relevant information relating to this requirement can be found in the NATM Guidelines section B-7 dealing with tires.
In July of 2019, the NATM Board of Directors approved the following three step process that NATM Members must comply with to be in full compliance with the NATM Compliance Verification Program’s tire recordkeeping requirements:
A method of matching VINs and TINs, which could include batches of VINs and TINs,
A method for keeping a record of those matches,
Proof that the trailer manufacturer is forwarding partially completed TIN forms to dealers.
In this scenario, members will be responsible for tracking TINs and VINs that are sent to specific dealers. Dealers will be responsible for attaching tires to trailers, so there is no CVP requirement that manufacturers under this option keep track of which specific tires ended up on a trailer.
TIN Forms from Tire Distributors
Under the Department of Transportation regulations, a member’s tire distributors should be providing them with a TIN form or card that can be mailed back to them for each trailer purchased. If your tire manufacturer is not providing the TIN form or card, the trailer manufacturer must request the form/card from so that it can fulfill its obligation in providing the cards as outlined below.
For members who are selling trailers directly to consumers, one of three methods must be used for completing TIN forms and providing them back to the member’s tire manufacturer:
At the time of sale, a pre-completed TIN form must be provided to the purchaser with the TINs for each tire attached to the trailer, the form must have the member’s name and street address for identification purposes of the tire manufacturer;
At the time of sale, the member can gather the purchaser’s name and address, the TINs for each tire attached to the trailer, and also the member’s name and street address for identification purposes of the tire manufacturer. After the TIN form is completed, the member will ship this back to the tire manufacturer under this option; or
The member may electronically transmit the following information on tire registration by any means authorized by the tire manufacturer, the information must include the purchaser’s name and address, the TINs for each tire attached to the trailer, and the member’s name and street address for identification purposes of the tire manufacturer.
For members who are shipping trailers without tires attached, you must meet the requirements listed above from the July 2019 NATM Board of Directors Meeting, which include:
Having a method in place for matching batches of TINs and VINs that are sent to dealers;
A system in place to keep track of those batches; and
Proof that the member is sending along partially completed TIN forms to their dealers.
For reference, this is an example of an incomplete TIN form below.
For more information about the NATM Compliance Verification Program, contact NATM Compliance Team at Compliance@natm.com or call (785) 272-4433.