Bridgestone Americas Tire Operations

I am contacting you on behalf of Bridgestone Americas Tire Operations, LLC with a request for clarification of certain uses of the term “replacement tires” as addressed in the Tire Fuel Efficiency Consumer Information Program; Proposed Rule (“Proposed Rule”). 1. In section III.B. of the Proposed Rule regarding replacement tires (see 74 FR 29553, enclosed with this email), NHTSA states “the definition needs to be in terms of the actual sale of the tire…” and, “tires that are manufactured for the OE tire market could be sold as replacement tires…” (emphasis added). In certain circumstances consumers have tires replaced at no cost to them. Examples include tires replaced under certain warranty terms and tires replaced in situations of goodwill extended by a manufacturer or retailer. It is unclear whether new tires provided to consumers (after the sale of the new vehicle) are considered “replacement tires” if there is no cost to the consumer. It is particularly unclear whether new tires manufactured for the original equipment market but provided at no cost to a consumer (after the sale of the new vehicle) are considered “replacement tires” in the Proposed Rule. How are tires defined according to the Proposed Rule if they are provided to consumers free of charge? 2. Additionally, certain tires may be supplied only for the original equipment market, not marketed to consumers for ordinary retail sale, and are only available to tire retailers/installers to replace the same original equipment tire specifications under terms of a consumer warranty or by contractual agreement between the vehicle manufacturer and the tire manufacturer. How are tires defined according to the Proposed Rule if such tires are original equipment in specification and are provided to consumers strictly to replace the same original equipment tires under circumstances as described above?