Published in July 2023 Fleet Affiliation.
Vehicle certification is on the radar of most fleet professionals, but it is often misconstrued as an event rather than a process. When the term “final-stage manufacturer certification” is heard, fleet professionals may believe the vehicle was completed in its final-stage and certified. “Vehicle certification” is a term that applies to all new vehicles being manufactured to ensure that the vehicles meet specific safety standards and regulations.
Mass-produced vehicles built and sold in a single stage are certified by the original equipment manufacturer; however, commercial vehicles produced in multiple stages must go through certification at each stage, and the final-stage manufacturer is responsible for the final certification.
What does this mean for your fleet?
Vehicle certification is complex, and it is important to understand who is considered the final stage manufacturer. In some instances, end-user fleets mistakenly believe they are not responsible for vehicle certification. In the United States, two rules must be satisfied:
- All motor vehicles must be certified in the final stage.
- All manufacturing operations performed before the first purchase (licensed and titled) must be certified; however, the first rule still applies.
While a fleet can purchase an incomplete vehicle, license and title it with the respective state, and install their own body or equipment, as the end user, they are considered the final-stage vehicle manufacturer responsible for certifying the vehicle. As a fleet, it is important to be aware of the certification responsibilities being accepted – and the liability and risk assumed – with becoming a final-stage manufacturer.
3 commons scenarios
While there are many scenarios regarding when and who is required to certify a vehicle, there are three common situations.
- The fleet purchased a new incomplete chassis cab, then titled and licensed it. At a later date, they purchased a flatbed and either installed it in-house or hired an upfitter to install it. In this case, although the vehicle went through a retail sale and was licensed, manufacturing operations before the first retail sale were not certified, and the vehicle must be certified.
- The fleet purchased a pickup truck from a dealer lot, licensed and titled the vehicle, then put it in service. Later, they decided to remove the pickup box and install a service body. The truck has been certified by the manufacturer, and the first retail sale has occurred. The vehicle does not have certification obligations. However, any time a vehicle undergoes equipment installation or modification after certification requirements have been met, there is a legal obligation to ensure the vehicle remains in compliance with the same safety standards in which it was originally produced and certified.
- This final scenario is more common for ship-thru situations where a fleet may order a pickup truck from a truck dealer (for whom the manufacturer has obtained final-stage certification) and the truck goes to an upfitter to have the pickup box removed and a service body installed. Since this did not go through the first retail sale, the upfitter must certify that the truck meets all relevant safety standards by its alteration.
Ultimately, end-user fleets need to understand the implications of vehicle certification and know where their obligations and liability lie. In certain cases as discussed, certification requirements may have ended; however, providing safe and regulatory-compliant vehicles is always a requirement, regardless of certification obligation.