What are manufacturer identification requirements?

From an NTEA member
We upfit vehicles for a leasing company, and they told us we need to be registered as a manufacturer with the U.S. Department of Transportation, even though we’re not a chassis OEM. What are these registration requirements, and does this apply to our company for the vehicles we build for them that go to Canada?
Even though you aren’t producing the base vehicles you’re upfitting, National Highway Traffic Safety Administration (NHTSA) considers you a manufacturer if you take part in any new vehicle manufacturing stage(s), including final-stage manufacturing or vehicle altering.

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