Does DOT certify multi-stage vehicle manufacturers?

NTEA regularly receives inquiries from members regarding compliance with vehicle safety standards and certification labeling. A member recently asked how they can get DOT-certified as a manufacturer.To best answer this question, we’ll have to answer another: What is a manufacturer?Title 49 (Subtitle VI, Part A, Chapter 301) of the U.S. Code of Federal Regulations (CFR) defines a manufacturer as “a person- (A) manufacturing or assembling motor vehicles or motor vehicle equipment, or (B) importing motor vehicles or motor vehicle equipment for resale.”For our purposes, a manufacturer is specifically a person (or company) who manufactures an incomplete vehicle or performs a manufacturing operation on a new incomplete vehicle. The latter includes an intermediate-stage manufacturer or a final-stage manufacturer. An altered-stage manufacturer alters a completed vehicle previously certified in the final stage prior to the first purchase.When it comes to manufacturer certification, in the CFR, the National Highway Traffic Safety Administration (NHTSA) describes it not as certification or registration, but as identification. The statute’s title, Part 566 – Manufacturer Identification, describes this. To legally manufacture vehicles in the incomplete, intermediate, final, or altered stage, a person or company must submit identifying information to NHTSA as a manufacturer.The obligation is described in Part 566 of Title 49, stating: “This part applies to all manufacturers of motor vehicles, and to manufacturers of motor vehicle equipment, other than tires, to which a motor vehicle safety standard applies…”Note that the information submission is a one-time requirement, unless a company moves locations, makes changes or additions to its product line, or modifies other required information that was previously submitted. Identification resubmission to NHTSA is required within 30 days of the relocation or product/information change.What are the information and submission requisites?Both are described in detail in Title 49 CFR Part 566 of the federal code, which states:"566.5 Requirements.Each manufacturer of a motor vehicle (other than a replica motor vehicle), and each manufacturer of covered equipment, shall furnish the information specified in paragraphs (a) through (c) of this section to https://vpic.nhtsa.dot.gov/ or to: Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Avenue SE, Washington, DC 20590....(a) Full individual, partnership, or corporate name of the manufacturer.(b) Residence address of the manufacturer and State of incorporation if applicable.(c) Description of each type of motor vehicle or of covered equipment manufactured by the manufacturer, including, for motor vehicles, the approximate ranges of gross vehicle weight ratings for each type.Except as noted below, the description may be of general types, such as “passenger cars” or “brake fluid.”In the case of multipurpose passenger vehicles, trucks, and trailers, the description shall be specific enough also to indicate the types of use for which the vehicles are intended, such as “tank trailer,” “motor home,” or “cargo van.”In the case of motor vehicles produced in two or more stages, if the manufacturer is an incomplete vehicle manufacturer, the description shall so state and include a description indicating the stage of completion of the vehicle and, where known, the types of use for which the vehicle is intended.In the case of replica motor vehicles, the manufacturer shall include, in the description of each type of motor vehicle it manufactures, a designation that the vehicle is a replica motor vehicle.Example: “Incomplete vehicle manufacturer—Chassis-cab intended for completion as van-type truck.”If the manufacturer is an intermediate manufacturer, or a final stage manufacturer, the description shall so state and include a brief description of the work performed.Example: “Multipurpose passenger vehicles: Motor homes with GVWR from 8,000 to 12,000 pounds. Final-stage manufacturer—add body to bare chassis.”566.6 Submittal of information.…(E)ach person who begins to manufacture a type of motor vehicle or covered equipment for which he has not submitted the required information shall submit the information specified in paragraphs (a) through (c) of § 566.5 not later than 30 days after he begins manufacture. Each manufacturer who has submitted required information shall keep his entry current, accurate and complete by submitting revised information not later than 30 days after the relevant changes in his business occur."Since NHTSA does not provide an estimated minimum time for the submitted information to appear on its website, the company should retain a record of the manufacturer’s submission (and its receipt by NHTSA).To check the status of the ID request, follow the link received in the submission confirmation email from NHTSA. Your company’s status (or the information for any NHTSA-identified manufacturer) can also be checked at the website linked in Part 566.5, the Manufacturer’s Information Database, at vpic.nhtsa.dot.gov/mid/.For additional information or questions, contact the NHTSA Manufacturer Helpdesk at manufacturerinfo@dot.gov or 888-399-3277.Manufacturer identification in CanadaUnlike a separate information submission to NHTSA in the U.S., Transport Canada includes manufacturer identification in its National Safety Mark (NSM) application. The NSM is a trademark, and its usage is granted and authorized by the Canadian Minister of Transport. Companies engaged in the business of manufacturing vehicles or equipment of a prescribed class in Canada are prohibited from applying the NSM to their products unless, among other requirements, the vehicle or equipment conforms to the prescribed Canadian Motor Vehicle Safety Standards (CMVSS). Likewise, companies (or an agent thereof) selling vehicles or equipment of a prescribed class in Canada to which an NSM has been applied are prohibited from selling unless the vehicles or equipment conform to the prescribed CMVSS. Imported vehicles and equipment do not necessarily require the NSM be applied; however, the imported products must still conform to all applicable standards. CMVSS compliance must be documented and submitted specifically for each commercial vehicle type submitted for an NSM. This includes detailed descriptions and engineering analysis of how the completed vehicle will comply with the required CMVSS for each body type and OEM chassis built. Note that the NSM is currently limited to Canadian entities or foreign companies with an agent for service in Canada.If your current or future business includes operations in Canada, contact Transport Canada at 800-333-0371/613-998-8616 (within/outside Canada) or mvs-sa@tc.gc.ca to discuss NSM requirements and the application process.NTEA’s Commercial Vehicle Certification GuideManufacturer ID submission is addressed in NTEA’s Commercial Vehicle Certification Guide. This resource includes detailed information and examples of compliance, certification and labeling requirements for all stages of vehicle manufacturing. Also included are worksheets for F/CMVSS compliance, early warning reporting requirements and a U.S./Canada Federal Lighting Guide Chart. Details of the NSM for Transport Canada are included in the Canadian version. The guide is available for purchase at a discounted rate for NTEA members at ntea.com/certguide.For additional questions, contact NTEA’s Technical Services Department (info@ntea.com or 248-489-7090 from 8 a.m.–5 p.m. ET, Monday–Friday).

Does DOT certify multi-stage vehicle manufacturers?

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