Each panel below is a working miniature of a site that could run at this address: navigation, hero, product screen and proof numbers, followed by a plain note on how that business would position the name. All twenty stay on screen at all times; a lane simply marks its own. The domain sits in the browser bar of every one of them, whole and unbroken, because the name is the thing being sold.
01
The Word That Is Not In The Part
Six words you would expect in the federal tire rules, and how often each appears
TireChangeMobile
574zero hitsactivity
Read the trigger
Premises. Place of
business. Establishment.
Zero, zero and zero
in the whole of the part.
The federal tire recordkeeping rules are the first place anyone looks for what a tire business owes. They are written around a person and an activity, start to finish. We searched the complete text of the part for every word that would import a building, and not one of them is there.
49 C.F.R. PART 574, COMPLETE CURRENT TEXT, eCFR SNAPSHOT OF OCTOBER 1, 2026 · SEARCHED OCTOBER 4, 2026PRIMARY SOURCE
Each independent distributor and each independent dealer selling or leasing new tires to tire purchasers ... shall comply with paragraph (a)(1)(i), (a)(1)(ii) or (a)(1)(iii) of this section574.8(a)(1), QUOTED TO ITS TRIGGER. THE TRIGGER IS A TRANSACTION. NOTHING IN IT IS A LOCATION.
premisesThe ordinary word for the place a trade is carried on.0
place of businessThe phrase a registration statute normally turns on.0
physical locationThe modern drafting equivalent.0
storefrontWhat the trade press calls the thing this one is not.0
retail outletThe term used elsewhere in the recall provisions for a seller.0
establishmentThe word a health or safety code would use.0
WHAT DOES CHANGE THE DUTYOne classification, and it is about ownership. The part defines independent as, with respect to a tire distributor or dealer, "one whose business is not owned or controlled by a tire manufacturer or brand name owner." Nothing in that test is about size, model or address. A single truck is independent for the same reason a regional chain is.
THE PART DOES NOT DEFINE DEALER OR DISTRIBUTOR AT ALL. IT INCORPORATES THE STATUTORY DEFINITIONS, WHICH ARE ALSO PERSON-AND-ACTIVITY. SEPARATELY, 574.9 USES THE TERM MOTOR VEHICLE DEALER AND DEFINES IT NOWHERE. NOTHING ON THIS PAGE IS LEGAL ADVICE.NOT ADVICE
574the part
6words searched
0appearances, all six
How they position itThe first question any operator in this trade asks is whether the rules written for tire shops reach a truck. A page that answers it by printing the search counts is the one that gets forwarded.
02
A Person Holding Itself Out To The Public
The statutory definition that decides whether a mobile operator is a repair business
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301223 elementsno place
Read the definition
Three elements, and
not one of them is
a building, a bay
or a state license.
The federal prohibition on disabling a safety device binds five categories of person, and defines one of them inside its own text, in a single sentence. That sentence is the cleanest answer in the whole chapter to the question this name asks, and it is not a close call.
49 U.S.C. 30122(a), UNITED STATES CODE 2024 EDITION · READ ON govinfo OCTOBER 4, 2026PRIMARY SOURCE
In this section, "motor vehicle repair business" means a person holding itself out to the public to repair for compensation a motor vehicle or motor vehicle equipment.30122(a), QUOTED COMPLETE. THE WHOLE DEFINITION IS ONE SENTENCE.
ELEMENT ONEA person. Not a firm with a yard, not a licensee, not a registrant. The chapter's own revision notes record that the drafters removed the words "in the business of" as surplus.A PERSON
ELEMENT TWOHolding itself out to the public. A listing, a phone number and a van with a name on it satisfy this on the face of the text.HOLDING OUT
ELEMENT THREEFor compensation. This is what separates a business from an owner working on a vehicle. An owner is not one of the five bound categories and meets neither of the two qualifiers.PAID
AND THE ELEMENT THAT IS NOT THEREThere is no fourth. No premises, no bay, no inspection, no state license, no minimum size. On the text, an operator with no fixed shop is squarely inside this definition, and anyone selling the opposite is selling a loophole that the statute does not contain.NO PREMISES
THIS IS THE FEDERAL STATUTE ONLY. STATE VEHICLE, REPAIR AND INSPECTION CODES ARE A SEPARATE QUESTION AND CARDS 19 AND 20 SAY WHAT WE DID AND DID NOT CHECK. NOTHING HERE IS LEGAL ADVICE.FEDERAL ONLY
30122the section
3elements in the definition
0of them a place
How they position itThis is the sentence a buyer in this category will want on the first screen. Printing it whole, with the three elements separated, is worth more than any amount of marketing copy.
03
Brakes Are The Only One
The single component in the motor carrier rules whose technician must be qualified
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396.25one componentthree parts
See the search
A steer tire on a
loaded truck tractor can
be fitted at the roadside
by anybody at all.
One section of the motor carrier safety regulations sets qualifications for the people who inspect, maintain, service and repair a component. Every operative term in it names the same component. We read three whole parts looking for a second section like it, and there is not one.
49 C.F.R. PARTS 392, 393 AND 396, COMPLETE TEXT, eCFR SNAPSHOT OF OCTOBER 1, 2026 · READ OCTOBER 4, 2026PRIMARY SOURCE
Qualifications of brake inspectors ... no motor carrier may require or permit any person to perform safety-sensitive brake maintenance, service or inspection unless that person is brake inspector qualified396.25, QUOTED TO ITS OPERATIVE TERMS. EVERY ONE OF THEM NAMES THE SAME COMPONENT.
396.19Inspector qualifications, for the annual periodic inspection. Component-neutral: it is about the inspection, not about any one part of the vehicle.NOT A COMPONENT
396.25Qualifications of brake inspectors. Component-specific, and the only one of its kind in the regulations.BRAKES
tiresPart 396 uses the word in list items and condition criteria only. Nothing anywhere says who may do the work.NO SECTION
steering, suspension, lightingSearched for the same reason, with the same result.NO SECTION
AND WHO CERTIFIES THE REPAIRThe carrier does. The roadside repair is certified by the motor carrier "or its agent", and no qualification standard attaches to the agent.
SCOPED EXACTLY: THIS IS THE FEDERAL MOTOR CARRIER SAFETY REGULATIONS. THE OCCUPATIONAL SAFETY RULE ON SERVICING RIM WHEELS, 29 C.F.R. 1910.177, WAS OUTSIDE THIS SEARCH AND WE DID NOT READ IT, SO THIS CARD IS NOT A CLAIM THAT NO FEDERAL RULE TOUCHES THE WORK.WHAT WE DID NOT READ
396.25the section
1component it covers
3parts read end to end
How they position itThe absence is the asset. An operator who knows exactly which component is regulated and which is not is the operator a fleet buyer trusts, and this is the page that shows the search.
04
You Cannot Break It. You Need Not Fix It.
Two scenarios in one agency letter, with opposite answers
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2011 letter2 scenarios0 defenses
Both answers
Fitting a plain valve
stem to a dead sensor
is lawful. Fitting four
live wheels without them is not.
The make-inoperative prohibition is about breaking something, not about restoring it, and the agency drew the line in a letter to a tire trade association. Two fact patterns, opposite answers, and two defenses that were put to the agency and rejected in the same document.
NHTSA INTERPRETATION 11-003978, STANDARD 138, DATED NOVEMBER 22, 2011 · READ OCTOBER 4, 2026PRIMARY SOURCE
[Replacing an already damaged or inoperative sensor with a standard valve stem does not violate the prohibition] since the element of the system was already inoperativeSCENARIO ONE, THE AGENCY'S REASONING. THE BRACKETED WORDS SUMMARIZE THE FACT PATTERN; THE UNDERLINED WORDS ARE THE LETTER'S OWN.
In this scenario, we assume that the vehicle has a functioning TPMS system at the time he or she purchases aftermarket tires and wheels. In that case, a service provider would violate the make inoperative prohibition of 49 USC 30122(b) by installing new tires and wheels that do not have a functioning TPMS system.SCENARIO TWO, QUOTED. THE SAME HANDS, THE SAME TOOLS, THE OPPOSITE ANSWER.
THE THREE CURES THE LETTER NAMESDecline the job; move compatible sensors across from the original wheels; or sell new ones and integrate them. Those are the agency's three, in the agency's order.THREE
DEFENSE ONE, RAISED AND REJECTEDCustomer consent. The letter addresses it and it is not a defense.NOT A DEFENSE
DEFENSE TWO, RAISED AND REJECTEDLeaving the warning lamp lit so the driver knows. Also not a defense, and disabling the lamp is a violation in its own right. A lamp that comes on after the vehicle leaves is, by itself, neither.NOT A DEFENSE
AND HOW THE PENALTY COUNTSThe penalty section provides that a separate violation occurs for each motor vehicle or item of motor vehicle equipment. A four-wheel job is not one unit.PER ITEM
AN INTERPRETATION LETTER IS THE AGENCY ANSWERING ONE REQUESTER ON ONE FACT PATTERN. IT IS NOT A REGULATION. THERE IS ALSO NO FEDERAL DUTY ON A SHOP TO RESTORE A SYSTEM THAT ARRIVED BROKEN, AND THE AGENCY SAYS SO WHILE STRONGLY ENCOURAGING IT.NOT A REGULATION
2011the November of the letter
2scenarios in it
0defenses accepted
How they position itThis is the single most expensive piece of knowledge in the trade and it is almost never stated correctly. A name that carries the correct version is doing sales work before anyone reads a word of copy.
05
The Letter Lists Four. The Statute Binds Five.
A live interpretation on the agency's own site, overtaken by a 2015 amendment
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4 vs 5Dec 2015still live
Count them
Congress added a fifth
category in December
2015. The letter on the
site still enumerates four.
The interpretation on card 04 lists the categories the prohibition binds. It was written in 2011 and it was complete then. A highway law enacted at the end of 2015 inserted another one, and the letter has not been reissued. It is not wrong for its date. It is no longer a complete statement of who is bound.
49 U.S.C. 30122(b) AGAINST NHTSA INTERPRETATION 11-003978 · BOTH READ OCTOBER 4, 2026TWO CURRENT SOURCES
manufacturerIn the statute. In the letter.BOTH
distributorIn the statute. In the letter.BOTH
dealerIn the statute. In the letter.BOTH
repair businessIn the statute. In the letter. This is the one card 02 defines.BOTH
rental companyInserted into the statute by Public Law 114-94, enacted December 4, 2015, effective 180 days later. Absent from the letter, which predates it by four years.STATUTE ONLY
Quote the statute, not the letter's list.THE LETTER REMAINS THE AGENCY'S LIVE INTERPRETATION ON THE DOCTRINE, AND CARD 04 USES IT FOR EXACTLY THAT. IT IS THE ENUMERATION THAT HAS BEEN OVERTAKEN, AND ONLY THE ENUMERATION.
THIS CARD DOES NOT SAY THE AGENCY ERRED OR THAT ANY DOCUMENT IS OUT OF COMPLIANCE. A CORRECT 2011 LETTER AND A 2015 AMENDMENT CAN BOTH BE CURRENT AND STILL DISAGREE ON A LIST, AND READING BOTH IS THE ONLY WAY TO SEE IT.NOT AN ACCUSATION
4categories in the letter
5categories in the statute
2015the December one was added
How they position itFinding the seam between two live official documents is the kind of thing a buyer cannot do in an afternoon. It is also the clearest possible demonstration that the page was built from sources rather than from summaries.
06
Initiate A Rulemaking, By No Particular Date
What a 2015 highway law actually told the agency to do about tire registration
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24333no dutyno date
Read the verbs
It changed no duty on
any dealer. It ordered
a process, and gave it
no date to finish by.
Everyone in this trade has heard that a highway law made electronic tire registration mandatory. Read the section. It imposes nothing on any dealer at all; it directs the Secretary to start something. And unlike a section a few pages later in the same law, it sets no deadline whatsoever.
PUBLIC LAW 114-94, SECTION 24333, 129 STAT. 1715-1716, ENACTED DECEMBER 4, 2015 · ENROLLED TEXT READ ON govinfo OCTOBER 4, 2026PRIMARY SOURCE
SEC. 24333. TIRE REGISTRATION BY INDEPENDENT SELLERS. ... the Secretary shall initiate a rulemaking to require ...QUOTED TO ITS OPERATIVE VERB. WHAT FOLLOWS "TO REQUIRE" DESCRIBES WHAT THE RULEMAKING SHALL REQUIRE, NOT WHAT THE SECTION ITSELF REQUIRES.
READ THE VERB CHAINThe section does not say a dealer shall do anything. It says the Secretary shall initiate. Until a rule issues, the duty on a dealer is whatever the existing regulation already said.A PROCESS
AND THE DEADLINE, WHICH IS THE PART NOBODY PRINTSThere is none. Compare section 24403 of the same law, which opens "Not later than 18 months after the date of enactment". This section has no date certain at all.NO DATE
A CITATION THAT CIRCULATES WRONGThe tire registration provision is 24333, not 24403. Section 24403 is "Retention of safety records by manufacturers" and is a different subject with a different target. The source credit printed on the amended statute confirms which one did the amending.CHECK THE NUMBER
CARD 07 IS WHAT THE FEDERAL REGISTER SHOWS HAS HAPPENED SINCE. NOTHING ON THIS PAGE IS LEGAL ADVICE AND NOTHING HERE TELLS ANY READER WHAT TO DO ABOUT A REGISTRATION.NOT ADVICE
24333the section
0duties it puts on a dealer
0deadlines it sets
How they position itHalf this trade believes a duty exists that does not. A domain whose front page quotes the verb is the one an association or a compliance product would want to own.
07
The Last Amendment Predates The Law
Searching the Federal Register for anything that changed the part since
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20152008nothing
The timeline
The most recent change
to the part is dated
eight months before the
law that ordered a change.
If the rulemaking on card 06 had happened, the Federal Register would carry it. We searched for any document amending or proposing to amend the part after the law was enacted. The section that would have to change still shows a single credit, and that credit is from 2008.
FEDERAL REGISTER SEARCH FOR DOCUMENTS AMENDING OR PROPOSING TO AMEND 49 C.F.R. PART 574 · RUN OCTOBER 4, 2026OUR SEARCH, DATED
2008The sole source credit printed on the registration section, at 73 FR 72368. It is still the only one there.IN FORCE
2015April 13. The last Federal Register document to touch the part at all. It concerns the identification number, which card 14 is about.LAST CHANGE
2015December 4. The law on card 06 is enacted, eight months after that last change, and orders a rulemaking on the registration section.THE ORDER
2026October 4. We search again. Nothing amending or proposing to amend the part has been published in the interval.NOTHING
CORROBORATED THREE WAYS, NOT ONEThe agency's own June 2026 paperwork notice describes consumer registration as elective and website registration as available only if a manufacturer provides the capability. The agency told the safety board in 2016 that it was "currently developing a response" to the law's topics. And its December 2024 report to Congress on rulemaking status carries no entry for this part.
THIS CARD DOES NOT SAY THE AGENCY HAS BROKEN ANY DUTY. THE SECTION ON CARD 06 SETS NO DEADLINE, WHICH IS EXACTLY WHY THE INTERVAL IS WORTH MEASURING RATHER THAN CHARACTERIZING.NOT AN ACCUSATION
2015the year of the law
2008the sole credit on the section
0later documents found
How they position itA dated search with a dated negative result is the most credible thing a page in this field can publish, and it is what distinguishes a source from a summary of one.
08
Nobody Has To Keep The Record
Where the two five-year retention clocks in the part actually point
TireChangeMobile
574.7(d)574.10574.8
The clocks
Both retention clocks
in the part run against
manufacturers. A dealer
records, transmits, and keeps nothing.
The most repeated compliance line in this trade is that a dealer must keep tire registration records for five years. Two provisions in the part set a five-year clock. Both of them are addressed to a manufacturer. The independent dealer is told to record and to transmit, and is never once told to retain.
49 C.F.R. 574.7(d), 574.8(a)(1) AND 574.10, eCFR SNAPSHOT OF OCTOBER 1, 2026 · READ OCTOBER 4, 2026PRIMARY SOURCE
574.7(d)A five-year retention clock. It is addressed to a tire manufacturer.MANUFACTURER
574.10A five-year retention clock. It is addressed to a motor vehicle manufacturer.MANUFACTURER
574.8(a)(1)The independent dealer's own section. Three options, one of which is simply handing the customer a paper form. It uses the words record and transmit, and it never uses the word retain.NO CLOCK
AND THIS IS NOT A GAP BY ACCIDENTThe statute contains a standing bar on requiring independent dealers to maintain records, subject to an exception that the 2015 law on card 06 created. The exception exists. The rule that would use it does not. That is the concrete consequence of the interval measured on card 07, and it is why the two cards belong together.
THIS DESCRIBES THE FEDERAL PART ONLY. A MANUFACTURER PROGRAM, A DISTRIBUTOR AGREEMENT OR A STATE RULE MAY SAY SOMETHING ELSE, AND NOTHING HERE TELLS ANY READER WHAT RECORDS TO KEEP.NOT ADVICE
2five-year clocks in the part
2that bind manufacturers
0retention duties on a dealer
How they position itCorrecting a belief the whole trade holds, from the text, in three rows, is the kind of thing that makes a buyer stop scrolling.
09
There Is No State Record For A Tire
Why a recalled tire is harder to find than a recalled car, in two consecutive paragraphs
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301192 routes1 register
Read both routes
A car is found through
state records. A tire is
found only if someone
wrote your name down.
One paragraph of the notification statute sends a vehicle recall notice to the registered owner, through state records. The very next paragraph sends a replacement equipment notice to the most recent purchaser known to the manufacturer. There is no register on the second route. There is only whatever paperwork went up the chain.
49 U.S.C. 30119(d)(1) AND 30119(d)(2), UNITED STATES CODE 2024 EDITION · READ ON govinfo OCTOBER 4, 2026PRIMARY SOURCE
... to each person registered under State law as the owner and whose name and address are reasonably ascertainable by the manufacturer through State records or other available sources30119(d)(1)(A). THE VEHICLE ROUTE. A PUBLIC REGISTER DOES THE WORK.
Notification required under section 30118 of this title about replacement equipment shall be sent in the manner prescribed by the Secretary, by regulation, to the most recent purchaser known to the manufacturer.30119(d)(2). THE TIRE ROUTE. THE WHOLE OF IT TURNS ON THE WORD KNOWN.
AND THE AGENCY'S OWN EXPLANATION OF WHAT FOLLOWSIts annual recall reports note that completion rates for tires, equipment and child seats "fall behind completion rates for vehicle recalls", and give as the most prominent reason that vehicles generally see high registration participation with State DMVs. The statute on this card is why.THE AGENCY SAYS SO
WHAT THIS CARD DOES NOT PRINTA tire recall completion percentage. The statute that requires an annual completion-rate list specifies every metric in terms of vehicles, and the agency's own 2025 list states that it does not include recalls related to tires, child seats, and equipment. A figure does appear in one table of the annual reports, and four separate attempts to read that table produced four mutually inconsistent results, so we print none of them.REFUSED
A 2018 INSPECTOR GENERAL REPORT FOUND THAT THE RECALL DIVISION DOES NOT VERIFY COMPLETION RATES ALTHOUGH IT HAS THE AUTHORITY TO. WE FOUND NO LATER REPORT REVISITING THAT FINDING, SO WE DO NOT SAY IT HAS BEEN FIXED AND WE DO NOT SAY IT PERSISTS.WHAT WE CANNOT SAY
30119the section
2notification routes
1that reaches a public register
How they position itRefusing to print the number everybody else prints, and showing the four readings that did not agree, is a stronger proof of care than any figure would have been.
10
Two Clocks That Run Only On Tires
Two limits in the remedy statute with no counterpart for anything else
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15 years5 years180 days
Read the cliff
Fifteen calendar years
for everything else.
Five for a tire. And
180 days to present it.
The free-remedy obligation has an age cliff, and the cliff for a tire is a third of the cliff for everything else. A second limit applies to tires alone: there is a fixed window to present the tire, and when a replacement is not available the window restarts rather than extends.
49 U.S.C. 30120(b) AND 30120(g)(1), UNITED STATES CODE 2024 EDITION · READ ON govinfo OCTOBER 4, 2026PRIMARY SOURCE
The requirement that a remedy be provided without charge does not apply if the motor vehicle or replacement equipment was bought by the first purchaser more than 15 calendar years, or the tire, including an original equipment tire, was bought by the first purchaser more than 5 calendar years, before notice is given ...30120(g)(1), QUOTED. ONE SENTENCE CARRIES BOTH CLIFFS, WHICH IS WHY THE CONTRAST IS THE STATUTE'S OWN AND NOT OURS.
FREE-REMEDY CLIFF · A VEHICLE OR OTHER REPLACEMENT EQUIPMENT15CALENDAR YEARS FROM FIRST PURCHASE. THE SAME AXIS, THE SAME QUANTITY AND THE SAME ZERO AS THE FIGURE BESIDE IT.
FREE-REMEDY CLIFF · A TIRE5CALENDAR YEARS FROM FIRST PURCHASE, INCLUDING A TIRE THAT CAME ON THE VEHICLE.
THE SECOND CLOCK, WHICH HAS NO VEHICLE EQUIVALENTA manufacturer must remedy a defective or noncomplying tire if it is presented not later than 180 days after the later of two events. If the manufacturer decides to replace it and no replacement is available in that window, a fresh 180-day period begins only on notification that one will be, and only tires presented in that period must be remedied.RESTARTS
BOTH CLOCKS GOVERN WHETHER A REMEDY IS FREE AND WHEN IT MUST BE GIVEN. NEITHER IS A SAFETY LIMIT, NEITHER IS AN EXPIRATION DATE, AND CARD 11 IS ABOUT WHY NO SUCH DATE EXISTS AT ALL.NOT AN AGE RULE
15calendar years, everything else
5calendar years, a tire
180days to present it
How they position itThe five-year figure is the one number in this whole area that is real, statutory and quotable, and it is routinely confused with the age folklore on cards 11 to 13.
11
The Age Rule Was Never Written
Four searches used to establish a negative, and what each one returned
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0 hits3 standardsno rule
Read the searches
There is no federal
tire age limit. Not a
standard, not a rule,
not a line anywhere.
That is a negative claim, so it is only worth as much as the way it was established. Here are the searches, named, with their counts, including the two that returned hits which turned out on reading to be about something else entirely.
FULL-TEXT SEARCH OF 49 C.F.R. (eCFR VERSIONER XML, OCTOBER 1, 2026 SNAPSHOT) AND OF EVERY NHTSA FEDERAL REGISTER DOCUMENT SINCE JULY 2003 · RUN OCTOBER 4, 2026OUR SEARCH, DATED
aged tireSearched across the whole of the title.0 HITS
tire ageSix hits, every one a false positive: crash dummy weight percentiles, and a school bus seating label.0 ON POINT
tire expirationEight hits, every one a false positive.0 ON POINT
oven agingSearched across every document the agency published from July 2003 forward. This is the term its own deferred test would carry.0 HITS
AND THREE STANDARDS READ END TO ENDThe three tire safety standards are condition-based from first line to last. So is the motor carrier tire section, which cards 16 to 18 are about. Not one of the four contains an age clause of any kind.
AND THE RULE PEOPLE ARE SURE THEY HAVE READ SOMEWHERE IS REAL, IN ANOTHER COUNTRYA 2020 amendment to the British construction and use regulations genuinely bars tires over ten years old from the steering axles of heavy goods vehicles, buses, coaches and minibuses. That is the law of the United Kingdom, it has no application in the United States, and it is the most likely origin of a ten-year rule that people are sure they have read somewhere.
WE DID NOT SURVEY EVERY STATE, SO THIS CARD IS A FEDERAL NEGATIVE AND NOT A FIFTY-STATE ONE. CARD 20 SAYS EXACTLY WHICH STATE SOURCES WE READ AND WHICH WE DID NOT.FEDERAL ONLY
0hits for the term aged tire
3standards read end to end
2003the July the search runs from
How they position itEveryone in this category has an opinion about tire age and almost nobody has checked. A name attached to the actual searches is the one a standards body or an insurer would take seriously.
12
In Approximately Two Years
The sentence the agency wrote in 2003 about what it would propose next
TireChangeMobile
2003about 2 years23 since
Read the promise
The agency said it
would propose an aging
test in about two years.
That was twenty-three years ago.
The one time the federal government came close, it declined and said why, then made a promise about what would come next. Read the promise exactly, because what was deferred is a laboratory test on manufacturers and not a calendar limit on anyone's tires. Those are different things, and nearly every summary blurs them into one.
68 FR 38116, FINAL RULE OF JUNE 26, 2003, DOCKET NHTSA-03-15400 · READ ON govinfo OCTOBER 4, 2026PRIMARY SOURCE
Aging - At this time, the agency is not adopting a test to address the deterioration of tire performance caused by aging. We proposed three alternatives for an aging effects test ... Because we had little data and analysis regarding any of these tests and understood the tire industry to be regularly conducting aging testing, we requested comments on which alternative should be adopted. The tire industry did not, however, disclose any of its testing data or provide any analysis in its comments on the NPRM.QUOTED. THE AGENCY GIVES ITS OWN REASON, WHICH IS WHY THIS CARD DOES NOT HAVE TO GUESS AT ONE.
The agency has decided to defer rulemaking on an aging test until further research is completed. The agency intends to develop and propose an oven-aging test for FMVSS No. 139 in approximately 2 years.QUOTED FROM THE SAME DOCUMENT. CARD 11 IS THE SEARCH FOR WHAT CAME OF IT.
THE DISTINCTION THAT GETS LOST, AND IT IS THE WHOLE CARDAn oven-aging test is a laboratory procedure: a tire is artificially aged and then run on a test wheel, and it is a duty on the people who build tires. A replacement interval is a calendar instruction to the person who owns them. The agency deferred the first. It has never proposed the second, and card 13 shows what it says instead.
A FREQUENTLY REPEATED CLAIM IS THAT THE 2000 HIGHWAY SAFETY ACT ORDERED THIS RESEARCH. WE READ THAT ACT IN FULL. ITS TIRE SECTION ORDERS AN ENDURANCE AND RESISTANCE UPGRADE AND ANOTHER SECTION ORDERS THE PRESSURE MONITORING RULE. NO SECTION OF IT MENTIONS TIRE AGING.A CLAIM WE CHECKED AND DROPPED
2003the June of the final rule
2years it said it would take
23years since
How they position itA promise with a date on it, measured against the calendar, is a better argument than any adjective. It is also the page a trade publication would link to rather than rewrite.
13
Six To Ten, And Who Actually Says It
The one sentence that can be printed, and the four words that make it true
TireChangeMobile
6 to 10attributionnot a rule
Read both sources
Drop four words from
the agency's sentence
and a true statement
becomes a false one.
A pair of numbers is quoted everywhere in this trade. The agency does print them. The association most often credited with them publishes no universal number at all, and says so in plain words. The difference between a correct and an incorrect use of the figures is entirely whether the attribution survives the quotation.
NHTSA CONSUMER TIRE SAFETY PAGE AND THE US TIRE MANUFACTURERS ASSOCIATION PUBLISHED POSITION · BOTH READ OCTOBER 4, 2026TWO SOURCES, BOTH QUOTED
Some vehicle and tire manufacturers recommend replacing tires that are six to 10 years old, regardless of treadwear.THE AGENCY'S OWN SENTENCE, QUOTED WHOLE. THE UNDERLINED WORDS ARE THE FOUR THAT ARE ALWAYS DROPPED. WITH THEM IT REPORTS WHAT MANUFACTURERS SAY. WITHOUT THEM IT INVENTS A FEDERAL RULE.
In most cases, no. Most people drive enough miles every year that their tires will need to be replaced before age becomes an issue.THE ASSOCIATION, ANSWERING WHETHER TIRES HAVE AN AGE AT WHICH THEY MUST BE REPLACED.
... a tire or vehicle manufacturer's recommendation is not a guarantee or indication of the minimum serviceable life for your tireTHE SAME ASSOCIATION, DISCLAIMING THE MANUFACTURER RECOMMENDATIONS IT DEFERS TO.
The sentence is quotable. The number on its own is not.THE ONLY SAFE FORM IS THE AGENCY'S, WITH ITS ATTRIBUTION INTACT. THIS CARD DOES NOT SAY WHEN ANY TIRE SHOULD BE REPLACED, AND NOTHING ON THIS PAGE IS ADVICE.
A CALIFORNIA BILL IN THE 2009 TO 2010 SESSION WOULD HAVE REQUIRED DEALERS TO DISCLOSE THE MANUFACTURE DATE AND TO REPEAT A SIX-YEAR RECOMMENDATION. IT DIED WITHOUT FURTHER ACTION IN NOVEMBER 2010 AND WAS NEVER CHAPTERED. EVEN THAT BILL WAS A DISCLOSURE DUTY, NOT AN AGE LIMIT.A BILL, NOT A LAW
6the lower figure
10the upper figure
0numbers the association publishes
How they position itShowing that the quotable version and the circulating version differ by four words is the kind of precision that sells a name to a compliance product rather than to a shop.
14
Both Formats Are On The Rack
A transition that closed eighteen months ago, and the text still printed in the code
TireChangeMobile
13 symbolsApril 20253 formats
Count them
The thirteen-symbol
identification number
became mandatory in
April 2025, not in 2015.
A 2015 rule fixed the length of the tire identification number, and gave the reason for it in one blunt sentence. The same rule let manufacturers keep the old shorter plant code for a decade. A technician holding a tire today is looking at one of at least three formats, and the paragraph describing the oldest is still printed in the current code.
80 FR 19553, FINAL RULE OF APRIL 13, 2015, DOCKET NHTSA-2014-0084, AND 49 C.F.R. 574.5 AS IT STANDS ON OCTOBER 1, 2026 · READ OCTOBER 4, 2026PRIMARY SOURCE
... the entire supply of 900 plant codes has been depletedTHE AGENCY'S STATED REASON FOR FIXING THE LENGTH. QUOTED FROM THE 2015 FINAL RULE.
before 2000A three-symbol date code. The rule of the day said only that the third symbol represents the year, and it does not disambiguate the decade. The honest reading of a three-digit code is therefore narrow: it was built before July 2000.STILL SEEN
2000 to 2025A four-symbol date code, and an overall number the 2015 rule itself describes as running anywhere between six and twelve symbols. There is no single pre-2015 length to quote.STILL SEEN
from April 2025A fixed 13 symbols: three for the plant, six for the manufacturer's own code, four for the date. The 2015 rule permitted two-symbol plant codes until April 13, 2025, so this became the only lawful format eighteen months ago.CURRENT
AND THE PARAGRAPH THAT READS LIKE A LIVE OPTIONThe section still carries a paragraph headed as the old content requirement. The transition it describes closed on April 13, 2025. Tires lawfully built under it are still in service and still on racks, which is exactly why the text is still there and exactly why it is easy to quote as current.
THIS CARD PRINTS NO PLANT-CODE OR MANUFACTURER-CODE LOOKUP, AND IT DOES NOT SAY WHAT ANY PARTICULAR CODE MEANS OR WHO BUILT ANY TIRE. THE LETTERS G, I, O, Q, S AND Z ARE NOT USED, AND WE PRINT THAT FROM THE RULE RATHER THAN GUESSING AT A REASON THE RULE DOES NOT GIVE.NO LOOKUP TABLE
13symbols, the current format
2025the April it became mandatory
3formats still in service
How they position itA page that gets a date transition right to the day is a page a tire distributor or a recall-management product will bookmark, and the name is what they remember.
15
One Sidewall, Three Standards
Three texts on where the number has to be, and three different answers
TireChangeMobile
3 texts3 answers1 sidewall
Read all three
The folklore says the
date code hides on the
inboard side. The standard
for most tires says the opposite.
One rule says the full number goes on one sidewall. A second says which sidewall, and allows the other side to carry a shortened version with the date stripped out. A third says it may be marked on only one sidewall and asks for nothing shortened at all. Which answer governs depends on which standard the tire was certified to.
49 C.F.R. 574.5(a)(1), FMVSS 139 S5.5.1(b) AND FMVSS 119 S6.5(b), eCFR SNAPSHOT OF OCTOBER 1, 2026 · READ OCTOBER 4, 2026THREE CURRENT SOURCES
574.5(a)(1)The recordkeeping rule. The full identification number is required on one sidewall, and the provision carries a note sending the reader to the safety standards for the rest of the answer.ONE SIDE
FMVSS 139Light-vehicle tires built on or after September 1, 2009. The full number goes on the intended outboard sidewall. The other side may carry a partial number with the date code taken out.OUTBOARD
FMVSS 119Truck, bus, trailer and motorcycle tires. The number may be marked on only one sidewall, and there is no partial-number requirement at all.EITHER
SO THE FOLKLORE IS BACKWARDS, AND THE CONSEQUENCE IS PRACTICALThe date code is never guaranteed to be on both sides, and on most light-vehicle tires built this century the full number is on the side facing out. The agency's own consumer guidance puts the working instruction plainly: look on both sides of the tire, because the number may not be on both.
THESE THREE TEXTS DO RECONCILE, THROUGH THE NOTE IN THE RECORDKEEPING RULE, AND THIS CARD DOES NOT SAY ANY OF THEM IS WRONG. IT SAYS THAT READING ONLY ONE OF THEM WILL GIVE A CONFIDENT ANSWER THAT IS NOT THE ANSWER.NOT A CONFLICT CLAIM
3texts on the point
3answers they give
1sidewall the full number is required on
How they position itThe sidewall question is the single most common thing a customer asks in this trade. Owning the address that answers it correctly, with all three texts, is a working asset rather than a slogan.
16
The Numbers In The Code Are Not The Numbers At The Scale
Four tread depths, and which two of them are in the Code of Federal Regulations
TireChangeMobile
4/322/321/32
Read all four
Four over thirty-two
and two over thirty-two
are in the code. Two and
one are what ends the trip.
The motor carrier rules set two tread depth minimums and a driver is written up at those. Being taken off the road happens at two lower numbers, and neither of those appears anywhere in the regulations. The agency's own violation file shows the split exactly, because it carries a separate code for each.
49 C.F.R. 393.75(b) AND (c), eCFR VERSIONER XML, OCTOBER 1, 2026 SNAPSHOT, AGAINST THE AGENCY VIOLATION-CODE TABLE · READ OCTOBER 4, 2026PRIMARY SOURCE
Any tire on the front wheels of a bus, truck, or truck tractor shall have a tread groove pattern depth of at least 4/32 of an inch when measured at any point on a major tread groove.393.75(b), QUOTED.
Except as provided in paragraph (b) of this section, tires shall have a tread groove pattern depth of at least 2/32 of an inch when measured in a major tread groove.393.75(c), QUOTED. NOTE THAT THE TWO PARAGRAPHS DO NOT EVEN USE THE SAME WORDING FOR THE MEASUREMENT.
STEER AXLE · WRITTEN UP AT4/32IN THE CODE, AT 393.75(b). THIRTY-SECONDS OF AN INCH, THE SAME UNIT AND THE SAME ZERO AS ALL THREE FIGURES BESIDE IT.
ALL OTHER AXLES · WRITTEN UP AT2/32IN THE CODE, AT 393.75(c).
STEER AXLE · TAKEN OUT OF SERVICE AT2/32NOT IN THE CODE. THIS NUMBER COMES FROM THE CRITERIA ON CARD 17.
ALL OTHER AXLES · TAKEN OUT OF SERVICE AT1/32NOT IN THE CODE EITHER, AND THE AGENCY'S OWN CODE FOR IT ADDS A CONDITION ABOUT THREE LOCATIONS OR TWO ADJACENT GROOVES THAT THE REGULATION DOES NOT CONTAIN.
AND THE PHRASE EVERYONE QUOTES AS REGULATIONThe words about measuring in two adjacent major grooves do not appear in 393.75 at all. The regulation's own definition says a major tread groove is the space between two adjacent ribs or lugs, which is almost certainly where the confusion starts. The measurement phrase belongs to the criteria, not to the code.
A SEPARATE FIGURE IN THE SAME CRITERIA SETS A LIMIT AT HALF THE MAXIMUM INFLATION PRESSURE. THAT NUMBER IS NOT IN 393.75 EITHER, WHOSE OWN INFLATION PROVISION IS PURELY RELATIVE. NOTHING ON THIS PAGE TELLS ANY DRIVER OR CARRIER WHAT TO DO.NOT ADVICE
4/32steer axle, in the code
2/32all other, in the code
1/32all other, out of service
How they position itGetting the four numbers right, and saying which two are law, is a distinction almost no page in this trade draws. It is the whole reason a fleet or a roadside network would want the address.
17
While Not Regulations
Who writes the criteria an inspector applies, and what it costs to read them
TireChangeMobile
not regulationssoldone level
The agency's words
The criteria that take
a truck off the road are
written by a nonprofit
and sold, not published.
The document an inspector applies at the roadside is not in the Code of Federal Regulations. The agency said so itself, in the Federal Register, in a subordinate clause that settles the question. The one place the criteria are incorporated by reference reaches a single inspection level for a single cargo type.
89 FR 67560, PUBLISHED AUGUST 21, 2024 · READ ON govinfo OCTOBER 4, 2026PRIMARY SOURCE
The OOSC, while not regulations, provide enforcement personnel nationwide, including FMCSA's State partners, with uniform enforcement tolerances for inspections.QUOTED WHOLE. THE AGENCY, ABOUT THE CRITERIA ITS OWN STATE PARTNERS APPLY.
WHERE THE ROADSIDE AUTHORITY ACTUALLY COMES FROMThe section that lets an inspector declare a vehicle out of service never names the organization, and sets a single phrase as its standard: that the vehicle, by reason of its mechanical condition or loading, would likely cause an accident or a breakdown.ONE PHRASE
THE ONE INCORPORATION BY REFERENCEIt is approved for exactly one section: a pre-trip inspection of vehicles carrying highway-route-controlled quantities of radioactive material. The general criteria are not incorporated. A full-text search of the whole Code for a definition of the term returns nothing.ONE LEVEL
THE CURRENT EDITIONEffective April 1, 2026, with 17 approved changes from the previous one. The organization's own page says the formats are available for purchase through its store, and the agency's page says the document may be purchased from it.FOR SALE
WE COULD NOT OBTAIN A PRICE: THE STORE IS A SCRIPTED PAGE THAT SERVES NO FIGURE TO A READER FETCHING IT, SO THIS CARD PRINTS NONE. BOTH OVERSTATEMENTS ARE REFUSED HERE. THE CRITERIA ARE NOT A FEDERAL REGULATION, AND THEY DO NOT LACK FEDERAL STANDING EITHER.NO PRICE PRINTED
2026the current edition
17approved changes in it
1inspection level it is incorporated for
How they position itA buyer in roadside services needs to know which document decides their customer's day. Showing that it is bought rather than published is the kind of fact that makes an address feel like a publication.
18
Nine Percent Of What Is Written. Twenty-Seven Of What Is Stopped.
Tire violations against every other vehicle violation, in one complete calendar year
TireChangeMobile
9.4427.2246 codes
Read both shares
Under a tenth of the
vehicle violations written.
More than a quarter of
the vehicles taken off the road.
The agency's violation file for the last complete calendar year carries forty-six distinct codes under the tire section. Added together they are a small share of what gets written and a large share of what ends a trip. Nothing else near the top of that table behaves this way.
MOTOR CARRIER MANAGEMENT INFORMATION SYSTEM, SNAPSHOT AS OF AUGUST 28, 2026, CALENDAR YEAR 2025 · QUERIED OCTOBER 4, 2026AGENCY DATA, DATED
TIRE VIOLATIONS AS A SHARE OF ALL VEHICLE VIOLATIONS WRITTEN9.44%319,422 OF 3,382,211. DENOMINATOR: EVERY VEHICLE VIOLATION RECORDED IN THE YEAR.
TIRE VIOLATIONS AS A SHARE OF ALL VEHICLE OUT-OF-SERVICE VIOLATIONS27.22%196,092 OF 720,430. A DIFFERENT DENOMINATOR: ONLY THOSE VIOLATIONS THAT TOOK THE VEHICLE OFF THE ROAD.
WHY THESE TWO FIGURES ARE PRINTED SIDE BY SIDE AND NOT DIVIDEDThey are shares of two different populations, so there is no axis they can share and no ratio between them that means anything. Each is given with its own numerator and its own denominator for exactly that reason. The comparison worth making is not arithmetic: it is that one component accounts for a far larger slice of the stoppages than of the paperwork.
the year3,172,189 roadside inspections, of which 645,165 recorded at least one out-of-service violation.20.34%
who performs themState personnel carried out 3,065,375 of them. Federal personnel carried out the rest.96.6%
the single largest tire code104,089 violations recorded under one code, of which 102,825 were out of service.98.8%
THE PRIOR YEAR RAN 9.71 PERCENT AND 27.10 PERCENT, SO THE PATTERN IS STABLE RATHER THAN A ONE-YEAR ARTIFACT. THE SNAPSHOT DATE MATTERS AND IS PRINTED ABOVE. THIS CARD NAMES NO CARRIER, NO BRAND AND NO RETREADER, AND NOTHING HERE SAYS ANY OF THEM IS SAFE OR UNSAFE.NAMES NOBODY
9.44%of vehicle violations
27.22%of vehicle shutdowns
46tire codes in the file
How they position itOne component, three times over-represented in shutdowns, is the entire commercial argument for this service existing. A name that opens on the agency's own number is doing the pitch for its owner.
19
Two States, Opposite Instincts About The Truck
Where the building comes back, and what each state wants to know about the vehicle
TireChangeMobile
per vehicleper loadopposite
Read both statutes
One state puts the plate
number inside the registered
business name. The other
forbids asking for it.
Nothing in the federal rules asks where the work happens. Two state regimes do, and they are not even the same kind of law. One is a repair registration that issues a separate number for every vehicle. The other is an environmental registration that attaches the moment the old tires are driven away.
16 C.C.R. 3351.7.3 AND OHIO REVISED CODE 3734.83, WITH THE CALIFORNIA BUREAU'S OWN PUBLISHED NEWSLETTER · ALL READ OCTOBER 4, 2026TWO STATES, QUOTED
It is unlawful for any person to engage in the business of mobile automotive repair unless that person has registered as an automotive repair dealer ... A person engaged in the business of mobile automotive repair shall hold a unique registration number for each motor vehicle used to perform mobile automotive repair.CALIFORNIA, 16 C.C.R. 3351.7.3(a) AND (b). THE BUREAU'S OWN NEWSLETTER ADDS THAT THE VEHICLE LICENSE PLATE NUMBER IS INCLUDED AS PART OF THE REGISTERED BUSINESS NAME.
... no person shall transport scrap tires anywhere in this state unless the business or governmental entity that employs the person first registers with and obtains a registration certificate ... A transporter registered under this division shall maintain a copy of the registration certificate in each motor vehicle used by the registrant to transport scrap tires.OHIO, REVISED CODE 3734.83(A). THE EXEMPTION IN THE SAME SECTION IS 10 OR FEWER TIRES PER LOAD.
THE OPPOSITE INSTINCT, IN THE SAME SECTION OF THE OHIO STATUTEThe application shall not include the license plate number or vehicle identification number of any vehicle used to transport scrap tires. One state builds the plate into the business name; the other forbids collecting it on the form.FORBIDDEN
AND THE DUTY THAT RUNS BACKWARD UP THE CHAINThe Ohio section also reaches whoever hands the tires over: no person who possesses scrap tires shall cause them to be transported by a person who is not registered. The obligation is not only on the truck.ON THE GENERATOR
AND THE POINT THAT IS EASY TO MISSThe second of these is not a repair license. It is an environmental registration, and it attaches because a vehicle drove away carrying tires, which is what this trade does by definition.NOT A TRADE LICENSE
THESE ARE TWO STATES WE READ, NOT A SURVEY. THIS PAGE PUBLISHES NO COUNT OF STATES THAT DO OR DO NOT REGULATE ANY OF THIS, BECAUSE WE CHECKED A HANDFUL AND A HANDFUL IS NOT A CENSUS. CARD 20 LISTS WHAT WE COULD NOT READ AT ALL.NOT A SURVEY
1registration number per vehicle
10tires per load, the other exemption
2different kinds of law
How they position itThis is the card that explains the word mobile. The federal layer is indifferent to the truck and the state layer makes the truck the regulated object, and no other page in this category draws that line.
20
What This Page Will Not Say
The claims we could not make from a source, published so the list can be checked
TireChangeMobile
RefusedCheckable14
Hold us to it
Fourteen things
we would not
put in print.
Every figure here names its source and its date. These are the statements that could not be made that way, or that a page selling a domain name has no business making at all. They are published together so a buyer can check them against every other card.
THE FULL LIST, PUBLISHED SO IT CAN BE CHECKED AGAINST EVERY OTHER CARDREFUSED
01Any advice, of any kind, to anybody. Not what to keep, not when to replace anything, not whether to register for anything. Every card that comes near a duty says so on its face.
02That any named or unnamed company, carrier, platform or operator complies or fails to comply with anything. No company and no carrier is named anywhere on this page.
03Any count of states that do or do not license repair businesses, charge a tire fee or regulate scrap tires. We read a handful of statutes and a handful is not a census. Card 19 is the two we quote.
04That federal law sets a tire age limit, at six years, at ten, or at anything. Card 11 is how that negative was established and card 12 is the one time it was nearly otherwise.
05The six-to-ten figure without its attribution. The agency's sentence reports what manufacturers recommend. Stripped of four words it becomes a federal rule that does not exist.
06Any tire recall completion percentage. The statutory list excludes tires by its own terms, and the one table that does carry a figure gave four inconsistent readings. Card 09 shows the refusal rather than hiding it.
07Any tire-related crash, injury or fatality count. The figures in circulation attach to proposals that were modified before adoption, and we found no current one we could stand behind.
08Any price for the out-of-service criteria. The store served no figure to a reader fetching the page, so card 17 says that instead of estimating.
09Any share of new vehicles sold without a spare. Six separate searches of the Federal Register returned nothing usable, the one agency survey that mentions spares measures something else entirely, and no government figure exists that we could verify.
10Any civil penalty figure without its year and the document that set it. The maximums are adjusted for inflation, and an amendment flag currently sitting on the penalty section turns out to reach only a fuel economy paragraph.
11That the out-of-service criteria are a federal regulation, or that they have no federal standing. Card 17 refuses both, in the agency's own words.
12That retreads are banned on steer axles, or that trucks must carry a spare. Neither is in the motor carrier rules; the one retread restriction we found is narrower than the claim.
13What the pressure monitoring warning threshold is, stated as a single number. The standard sets a relative figure or a fixed floor by tire type, whichever is higher, and quoting only the first is wrong on exactly the vehicles where it matters.
14Any market size, growth rate or search volume for this category, from any source. None appears anywhere on this page.
EVERY NUMBER ON THIS PAGE CARRIES ITS SOURCE AND ITS DATE, AND WHERE A FIGURE IS OUR OWN SEARCH RATHER THAN A PUBLISHED ONE, THE CARD THAT PRINTS IT SAYS SO.SOURCED OR ABSENT
14refused claims
0unsourced numbers
0sentences of advice
How they position itIn a trade sold on reassurance and folklore, publishing the refusals is the whole differentiator.