Becky MacDicken [mailto:[redacted]]
Sent: Monday, November 10, 2003 2:55 PM
Subject: RE: Tire Guides, 16 CFR Part 228 - Comments
After reviewing RMA's comments, TIA is opposed to using the
term “remanufactured” in any information about retreads.
In TIA’s opinion, “remanufactured” tires are a type
of retreaded tire and are therefore already covered by the guides. If
a new definition is required for consumers, TIA suggests that instead
of using “remanufactured” that the FTC say, “Any tire
that is manufactured in the retread process which includes “top
tread” (or shoulder to shoulder), “full tread” and “bead
to bead” retreads. TIA fears the term “remanufactured” causes
great confusion and therefore believes it should be avoided.
This is in line with the battle we (then the National
Tire Dealer and Retreaders Association - NTDRA) waged in
the early 90's about the term "New-Treads" or "Nu-Treads" causing
confusion to the public.
If you have any questions please feel free to contact me.
Director of Government Affairs
Tire Industry Association
1532 Pointer Ridge Place
Bowie, MD 20716