Re-rating a vehicle to 10,000 pounds GVWR and below

Bob Raybuck
NTEA Director of Technical Services

This article was published in the August 2022 edition of NTEA News.

From an NTEA member
A dealer asked us to change the gross vehicle weight rating (GVWR) of a new truck we’re upfitting from 10,600 pounds GVWR to 10,000 pounds to help with driver qualification requirements for a vehicle they’re trying to sell. What considerations do we need to be aware of with such a request?  

GVWR change requests should be handled with great caution. Assuming re-rating is a simple numerical exercise on a vehicle certification label can unnecessarily expose your company to responsibilities and liabilities for which you may be unprepared.

Since certification labels are the most outwardly visible part of the certification process, as well as referenced by motor carrier enforcement officials, it’s understandable the recognition of the vehicle certification process is often limited to the values on the certification label itself, and not the OEM representations and responsibilities that go into them. A healthier approach is to address these requests on a case-by-case basis. GVWR and gross axle weight ratings (GAWRs) provided by the original vehicle manufacturer can be changed by a final-stage manufacturer or alterer. However, if ratings are changed, there must be testing, analysis or documentation to establish compliance with all applicable Federal/Canada Motor Vehicle Safety Standards (F/CMVSS) at the new rating.

In a Jan. 3, 1972 interpretation to NTEA (formerly known as Truck Equipment Body Distributors Association), National Highway Traffic Safety Administration (NHTSA) provided the following guidance: “The information supplied to the final-stage manufacturer by the incomplete vehicle manufacturer under Part 568 is to assist the final-stage manufacturer in completing the vehicle in conformity with the standards, and certifying in conformity with Part 567. There are no requirements, however, as to how the final stage manufacturer uses this information. If they wish to take on the responsibility of changing the ratings in either direction, or to disregard the conformity information, that is their right. Of course, they will be assuming legal responsibility for whatever changes they make, as indicated by the facts of the particular situation and the information contained in the incomplete vehicle document. Similarly, they have the right to make whatever physical changes they wish to the chassis, and as such assume the normal responsibilities of a manufacturer in doing so including the responsibilities for the FMVSS standards affected by the changes. The Part 568 document [incomplete vehicle document] offers the final-stage manufacturer protection to the extent that they choose to stay within its limits; but it is their choice.”

There is a misconception that lowering GVWR is an easy process. Since the chassis is already capable of more weight, it’s assumed this is actually a better rating scenario. While this may seem accurate from a chassis capability perspective, such changes require OEM consulting guidance. Lowering GVWR could place the vehicle in a range where more regulatory compliance requirements apply (for which the intermediate-, final- or altered-stage manufacturer would become completely responsible).

Changing an off-the-lot chassis with a GVWR above 10,000 pounds to a value of 10,000 pounds or less is an attempt to prevent motor carrier operational requirements that would otherwise apply to the vehicle. This can void incomplete vehicle document (IVD) guidance and pass-through certification, since numerous F/CMVSS and other regulations are applicable to vehicles with 10,000-pound or less GVWRs, but do not apply to vehicles with 10,001-pound or higher GVWRs. These include dynamic, destructive and crash testing, as the base vehicle in a GVWR-lowering scenario may not be capable of meeting additional requirements of the lower GVWR.

For vehicles with a 10,000-pound or less GVWR, the following will apply:

  • C/FMVSS 110: Tire Selection and Rims
  • C/FMVSS 111: Rear Visibility
  • C/FMVSS 126: Electronic Stability Control
  • C/FMVSS 138: Tire Pressure Monitoring
  • C/FMVSS 201: Occupant Protection in Interior Impact
  • C/FMVSS 208: Occupant Crash Protection
  • C/FMVSS 214 Side Impact Protection
  • C/FMVSS 216a: Roof Crush Resistance
  • F/CMVSS 226: Ejection Mitigation
  • C/FMVSS 301: Fuel System Integrity

The original VIN-specific vehicle will not have been certified to these standards, which typically will require extensive (and expensive) testing and engineering analysis to ensure the vehicle meets all safety standards at the lower GVWR making this a very difficult decision both in the regulatory and economic arena. Further, a lower GVWR could put the truck in a new emissions category for which the base vehicle is not equipped or capable of achieving — potentially resulting in more (and extremely expensive) testing and regulatory compliance issues for the manufacturers, selling dealers and end users. It is also important to note that multiple vehicles would be required to conduct these tests, and there is no guarantee they would pass.

The re-rating of any new vehicle is complicated and potentially affects multiple motor vehicle
safety standards. Re-rating a vehicle to 10,000-pound GVWR and below increases this complication exponentially. Before committing to re-rating a vehicle, final stage manufacturers or alterers should do their due diligence to fully understand their responsibilities. If the dealer
insists that the company (the final-stage manufacturer or alterer) can re-rate the vehicle, remind the dealer that they can register as a final-stage manufacturer or alterer and take responsibility for re-rating as well. Then see if they are willing to accept the liability and responsibility re-rating entails.

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