Can You Register An Incomplete Vehicle

Truck dealers, vehicle upfitters and alterers – Are yous a manufacturer?

Your federal safety certification responsibilities

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Federal motor vehicle safety regulations directly affect your business — even if yous are not an original equipment manufacturer (OEM) of vehicles.

If y'all are a dealer (a person selling and distributing new motor vehicles or motor vehicle equipment primarily to purchasers that in proficient organized religion buy the vehicles or equipment other than for resale), federal law prohibits you from selling, offering for sale, manufacturing for sale, importing or delivering a motor vehicle or motor vehicle equipment unless it complies with the Federal Motor Vehicle Condom Standards (FMVSS) in effect when information technology was built and is properly certified. Dealers have a responsibility and must exist certain the vehicles they deliver are in compliance with FMVSS and properly certified. Whatsoever work you have washed on a vehicle may affect its certification.

Safety standard certification for dealers and alterers
Repair facilities, dealers and upfitters must comply with diverse motor vehicle rubber regulations. While National Highway Traffic Safety Administration (NHTSA) prophylactic standards (and possible safety and defect recalls) are near commonly viewed as applicable to OEMs, all of those previous manufacture players (repair facilities, dealers and upfitters) are in numerous ways required to bide by the regulations at various stages of the vehicle's life bike.

Do you install — or have installed — lift kits, snowplows, flatbeds, trailer hitches, partitions or shelving?

Do you change wheels, tires or bumpers, mount winches, tint windows or whatsoever number of other alterations or modifications requested by customers?

Did whatsoever of your piece of work modify the position or view of the rearview photographic camera, or did the weight of the equipment you added alter overall vehicle payload chapters past 100 pounds or more?

Depending on what you're doing and when, you likely have pregnant federal condom certification responsibilities that could even include requiring you to carry a retrieve if something was done incorrectly or contrary to safe standards.

Both upfitters and an OEM's franchised dealer play vital roles in the safety certification of a motor vehicle. While dealers, in particular, are likely to be heavily involved in rubber recalls initiated by an OEM, upfitters and dealers are responsible for their own deportment and could end up conducting recalls and remedies based on those actions. It'south important to annotation, these responsibilities employ even if the vehicle already has been certified in the final stage. Any visitor that performs work on a vehicle afterward it has been certified by a final-stage manufacturer may have pregnant certification and safety responsibilities.

It's not just the vehicle OEM's responsibleness
When a vehicle arrives at a dealership or upfitter facility, it may be completed or incomplete. Completed vehicles are those that are already certified to the FMVSS, either by the OEM or another concluding-phase manufacturer. If not, it is an incomplete vehicle and must exist completed and certified earlier it can be delivered to the customer. Depending on vehicle status, the actions you take determine your responsibilities in the safety certification procedure.

If the vehicle is certified in the final stage, it is ready to be sold to a client. If y'all perform certain activities prior to the vehicle being sold and titled, you may have responsibilities as an alterer. Similar activities done later the vehicle has been sold and titled would qualify equally modifications, which entail somewhat different responsibilities.

If a vehicle arrives every bit an incomplete vehicle, you or someone else will need to complete and certify it in the final stage before it can be sold to an finish user. A vehicle normally arriving in an incomplete stage could be a chassis cab or cutaway chassis.

Following are two central rules to note.

• Dominion ane — All vehicles must be certified in the last stage.
• Dominion two — All manufacturing operations performed on a motor vehicle before the first retail auction for use (meaning licensed and titled in some U.Southward. state) must exist certified.

What am I?
Are you a dealer, upfitter, manufacturer, alterer or a modifier?

The reply could be all of the to a higher place. The role y'all presume is based on actions yous take and at what stage. For instance, if you install a flatbed on a new chassis cab, you would be a final-phase manufacturer with responsibleness for certifying (and labeling) the vehicle in the final stage.

Alterations, commonly performed by dealers, are actions taken after final-stage certification but before the vehicle has been registered and titled. Adding a snowplow to a new pickup or lift kit to an SUV, for case, would exist an amending.

An alterer is responsible for ensuring the vehicle, as contradistinct, remains in compliance with the safety standards. You are also required to affix an altered vehicle certification label; boosted labeling responsibilities are possible, depending on gross vehicle weight rating (GVWR).

In the aforementioned examples, even though you are a dealer, you too become the last-stage manufacturer or alterer. If you perform those functions, you demand to be registered with NHTSA for the stages of manufacturing you perform.

Identifying your business every bit a manufacturer
Whether completing new incomplete vehicles (every bit a final-phase manufacturer) or performing manufacturing operations on completed vehicles, prior to the first retail sale (as an alterer), y'all are a manufacturer and accept a responsibleness to identify your business concern under 49 CFR, Part 566.

Manufacturers have the authority to certify the vehicles they consummate or modify, and as y'all "proper noun it to claim it," your identification as a manufacturer provides you the authority to perform your certification duties.

Not just is it mandated by federal regulation, purchasers such as leasing companies and individual fleets occasionally require proof that the manufacturers of their vehicles fulfilled their requirements to submit the information in accordance with Function 566.

Sometimes referred to equally NHTSA registration, this is a 1-time registration unless a business moves or makes relevant changes or additions to its product offerings. You tin can submit your organization's identification data via the Manufacturer Portal at vpic.nhtsa.dot.gov/mfrportal.

Many vehicle dealers are unaware some of the activities they perform oftentimes qualify them as manufacturers under NHTSA'south regulations. Being a franchised OEM dealer does non fulfill this registration requirement.

Stages of manufacturing and certification
A commercial vehicle or truck may accept several certifications by multiple companies. Depending on the vehicle delivered to the dealer, information technology may be incomplete or complete, and thus have different labels.

The responsibilities for final-phase manufacturers or alterers to certify, including labeling, the vehicles they build is recognizable for vehicles completed from incomplete vehicles like chassis cabs and cutaways that are intentionally produced with the demand to have bodies and equipment added by a final-stage manufacturer. Like all motor vehicles, they must see applicable FMVSS and emissions regulations.

What is less obvious are the same responsibilities for modifications that take been performed on vehicles that are certified as completed vehicles, like pickups and SUVs completed by an OEM, or those completed by a final-stage manufacturer, that undergo altered stage manufacturing.

Concluding-stage certification
If the vehicle was sent from the OEM as an incomplete vehicle — stripped, cowl and cutaway chassis or chassis cab — it volition have an incomplete vehicle document or manual (IVD or IVM), which includes a listing of each applicable safety standard followed by a conformity argument. Information technology provides data and guidelines necessary for an analysis of each safety standard to assess what can or cannot be done to the incomplete vehicle in order to maintain OEM certification. An incomplete vehicle could likewise have an intermediate-stage certification (e.grand., a dealer might send a new chassis cab — incomplete vehicle — to a truck equipment distributor/upfitter to lengthen the wheelbase and install a pusher axle merely will send it elsewhere for later installation of a dump trunk). The upfitter lengthening the wheelbase and installing the axle would braze an intermediate-stage certification label, and the company installing the body would affix the last-phase characterization.

Altered-stage certification
Alteration refers to certain work done on a vehicle after existence certified in the final stage but before the start retail sale for utilize (see Rule 2 on page 3, meaning licensed and titled in some U.S. land). If you receive a complete motor vehicle that has its consummate vehicle certification from ane or more manufacturers and you perform a manufacturing role that alters the vehicle prior to its first sale other than resale, you must

1. Allow the original certification label to remain on the vehicle;
2. Define that the vehicle as altered conforms to the rubber standards affected by the alterations; and
3. Affix to the vehicle an altered vehicle certification characterization, and possibly a vehicle placard or load conveying capacity modification label.

Contradistinct certification regulations cover all manufacturing performed later on the vehicle has been certified in the final stage and earlier the offset purchase of the vehicle in good faith for purposes other than resale. It includes anything that affects a vehicle's compliance with a rubber standard or that invalidates the vehicle's stated weight ratings. However, not all altering operations are considered (by the regulations) equally manufacturing. Specifically, the addition, substitution or removal of readily attachable components (such as mirrors or tire and rim assemblies) or modest finishing operations (such equally painting) are not considered manufacturing. However, in certain cases, these activities will bear upon compliance to specific safety standards, such as substituting tires and/or rims non designated by the OEM every bit i of the suitable combinations for that specific vehicle, and crave additional certification and labeling by the alterer.

For example, a vehicle dealer has a new pickup truck sitting on the lot, and a customer is interested only needs a platform body. Yous figure the body swap is easy enough and complete it in the service department. You have now become an alterer (because you performed piece of work on a final-phase vehicle non yet sold). As an alterer, yous are required to ensure the vehicle continues to encounter all applicable rubber standards and must affix the proper alteration characterization to the truck.

Had yous installed the aforementioned platform body on a pickup chassis (it had been delivered by the manufacturing plant without a bed and was certified every bit an incomplete vehicle), you would become the final-stage manufacturer and take the total certification responsibleness of a motor vehicle manufacturer.

FMVSS compliance and tools
The ultimate goal of certification is to exist able to stand for the vehicles you manufacture comply with all applicable FMVSS and emissions requirements, based on vehicle type, GVWR and conformity date.

Equally a final-stage manufacturer, you'll have to decide which standards apply and how to ensure they're met in the terminal configurations of vehicles you build. The base chassis will already meet certain FMVSS, but you'll need to determine how to run across the remainder, while maintaining compliance with the others. As previously noted, incomplete vehicle manufacturers (chassis OEMs) are required to provide downstream manufacturers with an IVD. This is a very important tool, every bit it helps identify all FMVSS that apply and provides guidance for maintaining compliance to standards with which the chassis is already produced to comply, meeting those dependent on the vehicle being completed, and those which need to be fully determined by the final-stage manufacturer.

Weight is a cistron in the outcome of a number of different FMVSS tests. Every bit such, numerous standards have weight and center of gravity limitations, detailed in OEM IVDs, that must exist evaluated to make up one's mind compliance. Weight analyses are therefore an everyday part in the truck equipment industry, and NTEA provides a costless, online beam weight and center of gravity figurer to members (ntea.com/weightcalculator). Additionally, the

Association offers the Commercial Vehicle Certification Guide as another resource to proceeds understanding of the certification process, including different labels. Visit ntea.com/vehiclecertification to learn more.

Equally an alterer, you take effectively the same responsibility to ensure a compliant vehicle, but from a different starting point. Completed vehicles do not come up with an IVD, but these documents tin still provide relevant guidance to evaluate alterations fabricated to these vehicles, relative to the standards that tin can be affected. Other helpful resources include OEM body architect books and technical bulletins. These publications provide a multifariousness of detail and specifications for private chassis models.

Regardless of the stages of manufacturing in which y'all are engaged, there is no substitute for developing an agreement of the different FMVSS and how to ensure the vehicles you complete and/or alter comply.

Final-stage manufacturers accept the full complement of FMVSS to evaluate, but there are a number of standards that should exist reviewed for alterations such equally pickup box removal, snowplow installation, bike and tire changes, and other truck personalization. These include, just are not limited to

• FMVSS 105: Hydraulic and Electric Brakes
• FMVSS 108: Lamps, Reflective Devices and Associated Equipment
• FMVSS 110: Tire Choice and Rims and Motor Habitation/Recreation Vehicle Trailer Load Carrying Capacity Information for Motor Vehicles with a GVWR of 4,536 Kilograms (ten,000 pounds) or Less
• FMVSS 111: Rearview Mirrors and Rear Visibility Systems
• FMVSS 126: Electronic Stability Control Systems
• FMVSS 135: Calorie-free Vehicle Brake Systems
• FMVSS 201: Occupant Protection in Interior Impact
• FMVSS 204: Steering Control Rearward Displacement
• FMVSS 208: Occupant Crash Protection (in Frontal Impacts)
• FMVSS 212: Windshield Mounting
• F/CMVSS 214: Side Impact Protection
• FMVSS 216a: Roof Trounce Resistance
• FMVSS 219: Windshield Zone Intrusion (upgraded)
• FMVSS 226: Ejection Mitigation
• FMVSS 301: Fuel System Integrity

Maintaining compliance with these standards every bit an alterer requires numerous upfront considerations before performing manufacturing operations on new vehicles.

Labels
Below are typical label examples required as part of final- or altered-stage certification.

For vehicles with a GVWR of x,000 pounds or less that are completed from incomplete vehicles (e.g., chassis cabs, cutaways, stripped chassis or incomplete vans), the incomplete vehicle is not required to have a vehicle placard since the last-stage manufacturing process will modify some of the information required on the information technology. Therefore, it's the final-stage manufacturer'southward responsibility to provide all necessary information on a new placard and affix it to the completed vehicle in one of the locations allowed by FMVSS 110.

For vehicle alterations or other modifications to a completed vehicle that involve permanently installed equipment or any changes to the vehicle tires, the existing placard must be examined by the vehicle alterer/modifier to determine if whatever of the information has been invalidated by the alteration or other modifications. Note, at that place is a dissever version of this label specific to trailers with a GVWR of ten,000 pounds or less, which does not refer to seating chapters or occupant weights.

When altering or modifying a completed vehicle by only adding equipment to a previously certified vehicle (not changing tires or wheels) prior to its start retail sale, the manufacturer that previously completed the vehicle is required to braze a placard that includes capacity weight. If you are adding permanently fastened equipment in excess of ane.5% times the GVWR or 100 pounds — whichever is less — to the vehicle, the existing load carrying capacity of the vehicle placard must be updated to reflect the reduced capacity.

The most common option for correcting this value is the load carrying chapters modification label. The net increase in curb weight is communicated on this characterization, which is applied inside 25mm of the vehicle placard.

If the particular model has been tested under NCAP (New Car Assessment Program), an additional label volition exist needed to signal that as contradistinct, the Stars for Cars rating may no longer exist applicable (see Altered Supplemental NCAP "Stars for Cars" Window Cling at ntea.com/shopntea). If the specific model has not been tested, it would not accept a rating, and no supplemental labeling is required. A list of models rated under this program (and, therefore, requiring this characterization, if altered) is available at safercar.gov. You can search models assessed on this site, as well as a list of upcoming the agency plans to test. If the new vehicle is already on-site, bank check for a star rating on the Monroney Label (also known as the MSRP label or window sticker).

Modifiers versus alterers
The term modifier is often mixed in with certification terminology. A modifier is a person who works on a used vehicle (i.e., one that has been sold just is not intended for resale, licensed and titled). Modifications do not crave a certification label, but a modifier does have a safety responsibility. For example, an owner purchases a pickup truck certified every bit consummate past the vehicle manufacturer. After operating the vehicle for several months, the owner brings the vehicle to you to add a snowplow. Since the modifications were made after the first purchase of the vehicle for purposes other than resale, you have no obligation to provide farther certification. While NHTSA's certification regulations utilise only to new motor vehicles, at that place are stipulations that apply to used vehicles.

Federal law prohibits a manufacturer, distributor, dealer or motor vehicle repair concern from knowingly making inoperative any office of a motor vehicle or motor vehicle equipment that is in compliance with an applicable safety standard. Also, manufacturing operations/modifications performed on used vehicles still subject field the manufacturer/modifier to retrieve and remedy responsibilities. Therefore, any installation or work done on a used truck should be performed in the same style as though it were to be certified. In other words, don't exercise to a used vehicle what yous would not practise to a new one, just because y'all don't have to certify and label it.

Vehicle dealer responsibilities
A dealer is prohibited (as is anyone) from manufacturing for sale, selling, offering for sale, importing or delivering a motor vehicle or motor vehicle equipment unless it complies with the FMVSS in result when information technology was built and is covered by a certification. Nether this section, dealers must be sure the vehicles they evangelize are certified. Every bit such, it'south important to sympathise the nuts of certification and which certifications are required for a given vehicle.

Liability concerns
Every visitor in the manufacturing and distribution chain has liability concerns. Proper certification and documentation will help yous to exist prepared in the event you meet any legal concerns. If you are a body or equipment manufacturer, make certain your distributor/installer (which may be a dealer) is installing and using your equipment correctly. If not, at that place is more likely to be a failure that could result in a condom problem, call up and possible legal activeness. Truck equipment distributors, dealers, alterers and modifiers all benefit from close working relationships with manufacturers of bodies, equipment and chassis. If you receive and follow good installation instructions, you take a better chance of fugitive liability problems. Similarly, equally an OEM or body and equipment manufacturer, having practiced working relationships with the installers and sellers of your product volition assist ensure those products perform the mode you intend. Look at how installations are done and how the vehicle is certified. If the manufacturer or alterer has solid processes in place for certification, you can likely be more confident they will take the same intendance with the work they exercise for you lot.

Definitions
Alterer — Defined in 49 CFR 567.3 of NHTSA regulations equally "a person who alters by addition, substitution or removal of components (other than readily attachable components) a certified vehicle before the first purchase of the vehicle other than for resale." (Outset purchase means the vehicle has been licensed and titled in some U.Due south. land.) For instance, a dealer has a completed new vehicle and a customer asks for a lift kit installation or pickup box removal for a different trunk as office of their purchase. As this work is beingness done prior to the bodily first retail sale and registration, information technology'southward considered an alteration and falls within the vehicle certification regulations. Alterers are required to add an altered certification characterization to the vehicle.

Dealer — A person selling and distributing new motor vehicles or motor vehicle equipment primarily to purchasers who, in expert faith, buy the vehicles or equipment other than for resale.

Concluding-stage manufacturer — Anyone who completes and certifies a vehicle in the concluding stage (meaning information technology's gear up for sale and registration). This may exist a vehicle completed from an OEM chassis cab, such every bit a dump truck.

Incomplete vehicle manufacturer — OEMs produce both complete and incomplete vehicles. Incomplete vehicles include stripped, cowl and cutaway chassis or chassis cabs. These are certified in an incomplete phase and crave further work by a final-stage manufacturer in order to be certified in the final stage and ready for sale. Incidentally, an incomplete vehicle could go through multiple incomplete vehicle manufacturing stages. For case, the OEM chassis cab may be sent out for an additional axle (another incomplete vehicle certification phase, known as intermediate-phase manufacturing) and then on to an upfitter for concluding-stage certification work (adding a body, etc.).

Manufacturer — A person
a) Manufacturing or assembling motor vehicles or motor vehicle equipment; or

b) Importing motor vehicles or motor vehicle equipment for resale.

Modifier — Similar to an alterer, but the work is performed after the first retail sale and registration. You still have much the same legal responsibilities as an alterer simply are not required to certify the vehicle or add a new certification label.

Registered manufacturer — If you complete new incomplete vehicles (every bit a final-phase manufacturer) or perform manufacturing operations on completed vehicles, prior to the first retail sale (every bit an alterer), yous are a manufacturer as divers by NHTSA.

If you fall within NHTSA's definition of a manufacturer, you are required to identify your business as such with the agency.

Upfitter — This is a common term for an NTEA benefactor member. These companies routinely have incomplete vehicles and install the trunk and equipment necessary to complete them (terminal stage). Upfitters are required to certify the new vehicle, every bit completed, is in compliance with all applicable safety standards in place at the time of manufacture.

Upfitters may too serve equally an alterer, modifier or incomplete vehicle manufacturer, depending on what manufacturing activities they perform and in what stage of certification the particular vehicle is in.

Once the upfitter's piece of work is done, they identify the proper certification characterization on the vehicle, and it is prepare for the next phase — possibly sale.

Learn more than
NTEA offers admission to publications and reference materials on current regulations, safety standards, and other technical issues at ntea.com. To learn more about the tools, resources and solutions available to members, visit ntea.com/memberbenefits.

Source: https://www.ntea.com/NTEA/NTEA/Member_benefits/Truck-dealers-vehicle-upfitters-alterers-Are-you-a-manufacturer-nm2.aspx

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