Elements of vehicle certification

From an NTEA member We’re opening a new truck equipment distribution business. Does certification of the trucks we build mean just labeling the vehicles when we’re finished building? Also, we’re considering building vehicles for customers in Canada. Is this the same for vehicles we would export? This is a good question and offers an opportunity to dispel a few myths. While labeling is probably the most visible part of the certification process, there is a common misconception that it is the only part. When certifying a vehicle, the label you install on the completed vehicle is representing that it “….CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS….” Or, similarly, that it “CONFORMS TO ALL APPLICABLE STANDARDS PRESCRIBED UNDER THE CANADIAN MOTOR VEHICLE SAFETY REGULATIONS…” for any vehicle you build for the Canadian market. There are numerous Federal/Canada Motor Vehicle Safety Standards (F/CMVSS) a given vehicle must meet, depending on type and gross vehicle weight rating (GVWR) — especially for those with a GVWR of 10,000 pounds or less, which have additional standards that do not apply to heavier vehicle weight classifications. The essence of the certification process that leads to labeling is documentation and retention of required materials that provide evidence supporting the representation you’re required to make using labels. A related urban legend is that certification is what you do after building the vehicle. Given the representation labels make, your certification process must have an upfront focus to ensure you’re able to properly build a vehicle and comply with all applicable F/CMVSS. There isn’t a specific, step-by-step method manufacturers are required to adopt, so there is freedom in how you manage this process within your business as long as an overarching goal to ensure vehicle compliance is achieved. However, this leads to another common misconception — that a business isn’t a manufacturer if it’s just adding a body to a new chassis or installing equipment on a new vehicle. Under federal law, a manufacturer is a person involved in: “(A) manufacturing or assembling motor vehicles or motor vehicle equipment, or (B) importing motor vehicles or motor vehicle equipment for resale.” This is functionally equivalent for Canada and includes everyone involved in building a new motor vehicle — from the chassis manufacturer to any person or business altering a completed vehicle previously certified in the final stage, prior to first purchase. There are several stages of vehicle manufacturing (see section at end of article) that include different associated responsibilities for manufacturers taking part in them. A common U.S. requirement is all manufacturers must submit identifying information about their operations to National Highway Traffic Safety Administration (NHTSA) under 49 CFR Part 566 (see Tech Connections, January 2020). Declaring the stage(s) of manufacturing you perform in your operations is included in the information you submit. Transport Canada requires foreign manufacturers to provide documentation, following specific procedures and giving proof of certification capability. After embracing your role as a manufacturer and understanding the different F/CMVSS, you must determine which ones apply to the vehicles you build and how they are being met. This is central to the certification process. In addition to reading the safety standards themselves — contained in 49 CFR Part 571 for U.S., and Motor Vehicle Safety Regulations (MVSR) for Canada — there are other information sources to review and use in your process, including incomplete vehicle documents (IVDs), body builder books and bulletins from respective OEMs of the new vehicles that you complete and/or alter. When completing incomplete vehicles (e.g., chassis cabs and cutaway chassis) with the addition of bodies and equipment, most final-stage manufacturers will rely on statements in the IVDs as their basis for determining compliance with applicable F/CMVSS. Some F/CMVSS can be met using pass-through certification, which is accomplished by remaining within the chassis manufacturer’s instructions in the IVD. Note, the chassis you complete will already meet a number of F/CMVSS when received from the OEM, so part of your process as the final-stage manufacturer will be to preserve original compliance of those standards by staying within IVD guidance. Other standards can have additional conditions necessary for you, as the final-stage manufacturer, to perform in order to complete the requirements, such as weight analyses and vertical center of gravity calculations for brake systems, based on your specific vehicle upfits. Sometimes, pass-through certification for individual standards may not be available from the OEM but could be accessible from component/system suppliers, which can provide compliance representations for equipment-based standards such as for lighting devices, wheels or seating/restraint systems. However, when pass-through isn’t available, multistage manufacturers need to exercise reasonable care to confirm the vehicles they produce meet safety standards for which they take responsibility — which can involve performing additional analysis or testing. For documentation and recordkeeping, capture your methods of compliance used for the various standards. There may be opportunities to streamline documentation where your compliance methods for the same F/CMVSS are related for a series of chassis and upfits throughout a given model year. With this foundation, labeling requirements follow the stages of manufacturing and can be found in U.S. 49 CFR Parts 567 and 568 and Canada MVSR C.R.C, c. 1038. Additional labeling is required for vehicles with a GVWR of 10,000 pounds or less, providing consumers with tire and loading information. Stages of manufacturing/types of manufacturers Incomplete vehicle manufacturer — A person who manufactures an incomplete vehicle by assembling components, none of which, taken separately, constitute an incomplete vehicle. Intermediate manufacturer — A person, other than the incomplete vehicle manufacturer or the final-stage manufacturer, who performs manufacturing operations on a vehicle manufactured in two or more stages. Final-stage manufacturer — A person who performs such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle. Alterer — A person who alters by addition, substitution, or removal of components (other than readily attachable components) a certified vehicle before the first purchase of the vehicle other than for resale. (Note: An alteration includes any change that affects a vehicle’s compliance with a safety standard or invalidates the vehicle’s stated weight ratings.) Canada classifies alterers as final-stage manufacturers. NTEA offers certification resources, including Commercial Vehicle Certification Guide and TE201 Certification, to help multistage manufacturers in U.S. and Canada understand their responsibilities. Learn more at ntea.com/vehiclecertification.

Elements of vehicle certification

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