By Bob Raybuck, NTEA Director of Technical Services
This article was published in the July 2017 edition of NTEA News
Following is the first in a series of three articles on vehicle certification basics in the U.S., Canada and Europe. The remaining two will appear in the September and October issues of NTEA News.
As the trend toward global chassis platforms continues, we thought it might be helpful to explain the similarities and differences in three major vehicle safety and emissions certification systems — the U.S., Canada and European Union (EU). While all of these certification requirements have the same goal (ensuring safe and compliant vehicles), they do it in somewhat different manners. These differences can be very important to final-stage manufacturers completing or altering a truck for use in any of those geographic regions.
In this first of three articles, we will look at the vehicle certification requirements in the U.S.
As we know, work trucks in the U.S. are most often customized vehicles built for a specific purpose — beginning as either an incomplete vehicle such as a chassis cab, cutaway or strip chassis, or as a pickup or full body van complete vehicle. A U.S. company building complete commercial vehicles (typically called an upfitter or final-stage manufacturer) has a legal duty and obligation to certify the vehicle to applicable Federal Motor Vehicle Safety Standards (FMVSS) and maintain emissions certification of the work trucks it manufactures. This responsibility and process is commonly known as multi-stage vehicle certification. A vehicle certification label is the form used by the upfitter to show the vehicle conforms to all FMVSS and emissions requirements.
Often, new upfitters do not understand they are considered manufacturers under National Highway Traffic Safety Administration (NHTSA) regulations. A chassis cab or cutaway — the foundation of many work trucks — is an incomplete vehicle. When an upfitter adds a truck body and other equipment to an incomplete chassis, the upfitter becomes the final-stage manufacturer for that vehicle.
Another common work truck base is a complete full body cargo van or pickup truck. When it is modified by adding equipment such as a partition and interior shelving system or a snowplow, or by removal of a pickup box and subsequent addition of a truck body before the first retail sale, it becomes an altered vehicle and requires certification. This is known as altered certification. An intermediate manufacturer is a company that performs a manufacturing operation on a vehicle completed in two or more stages. For example, a company first installs a crane on an incomplete chassis and then an additional company adds final equipment, such as a body, to complete the vehicle. Under NHTSA regulations, all three businesses are considered manufacturers for vehicle certification purposes.
The upfitter is considered the manufacturer and needs to certify the vehicle to applicable FMVSS and emissions requirements — but what does that mean? A common misconception is that the upfitter is certified to build the work truck. All manufacturers, including the original equipment manufacturer (OEM), of incomplete chassis are not certified by NHTSA or any other federal government agency to build vehicles (passenger cars, SUVs, commercial trucks, etc.). Rather, they are required to certify the completed vehicle meets all FMVSS and emissions regulations applicable to the specific gross vehicle weight rating (GVWR) and vehicle type being built.
The incomplete vehicle OEM is required to provide an incomplete vehicle document (IVD) addressing applicable FMVSS and giving guidance to the subsequent manufacturer on FMVSS and emissions requirements the incomplete vehicle-as-manufactured meets or specific conditions the upfitter must meet for conformance to specific FMVSS and emissions requirements. Additionally, the OEM will provide regulatory requirements guidance via its body builder books for complete vehicles, such as cargo vans and pickups, and for incomplete vehicles.
Depending on GVWR, some applicable FMVSS will have strict performance-based requirements which may include destructive testing, such as crash testing. OEM-provided limitations and guidance for a specific FMVSS enable the upfitter to complete the vehicle within bounds of reasonable care in the FMVSS certification regulations.
Note, FMVSS are minimum performance standards and do not indicate vehicle quality or offer an affirmative defense in a product liability lawsuit. However, failure to meet applicable requirements will result in the final manufacturer or alterer being subject to NHTSA’s recall and remedy regulatory provisions, and therefore, potentially subject to serious product liability concerns.
While a final-stage certification label does not guarantee a quality vehicle has been built, companies adhering to a strict vehicle certification compliance system are more likely to have a similarly stringent quality assurance program. Vehicle certification is more than putting a label on a work truck — it’s the commitment to meeting specific and consistent processes to ensure the vehicles manufactured were built to meet FMVSS requirements as well as maintain vehicle emissions compliance.
Next month, we will review Canada’s certification requirements. While Canada’s standards are aligned closely with those in the U.S., the certification process has some significant differences.
Additional vehicle certification information, resources and products are available at ntea.com/vehiclecertification. If you have any questions or need further assistance, call NTEA’s Technical Services Department at 800-441-6832 from 8 a.m.–5 p.m. EDT, Monday–Friday.