GVWR changes

From an NTEA member A customer asked us to change the gross vehicle weight rating (GVWR) of a new truck we’re completing from a chassis cab (adding a body and equipment). We received two identical chassis for the same customer, both with a front gross axle weight rating (GAWR) of 8,000 pounds and rear GAWR of 19,500 pounds. However, one has a 27,500-pound GVWR and the other a 25,950-pound GVWR, but we’re performing identical upfits. The customer requested both chassis have 25,950-pound GVWRs, but the proper option code was omitted during the build sequence on one of vehicles. The customer refused to take delivery of the chassis with the higher GVWR, so the truck dealer requested we re-rate the 27,500-pound GVWR chassis to 25,950-pound GVWR. The chassis OEM would not provide a new incomplete vehicle label reflecting the lower GVWR, but did give a letter to our company (the final-stage manufacturer) stating GVWR should be 25,950 pounds. Can we certify the vehicle using the lower GVWR? GVWR change requests should be handled with great caution — even in situations where they may seem easy to do. Assuming re-rating is a simple numerical exercise on a label can unnecessarily expose your company to responsibilities for which you may be unprepared. Since labels are the most outwardly visible part of the certification process, as well as referenced by motor carrier enforcement officials, it’s understandable customer recognition of the process is often limited to the values on the label itself, and not manufacturer representations and responsibilities that go into them. A healthier approach is to address customer requests on a case-by-case basis. GVWR and GAWRs provided by the incomplete 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 this case, the chassis OEM helped provide additional necessary documentation in a letter to establish the GVWR change. Staying within specific guidance provided by a prior-stage manufacturer for meeting applicable F/CMVSS in the completed vehicle is known as pass-through certification. Remaining within conditions described in the chassis manufacturer letter and incomplete vehicle document (IVD) can enable pass-through certification when changing GVWR. In many cases, IVD statements will preclude the ability to use pass-through certification when changing GVWR and/or GAWRs assigned by the OEM, so obtaining a letter from the OEM with clarifications for your specific chassis configuration can preserve your ability to continue reliance on IVD statements in final-stage vehicle certification and assignment of ratings. Pass-through certification is a necessary tool for the truck equipment industry, and staying within OEM-provided guidance can support its use. Without pass-through, responsibilities for meeting all applicable F/CMVSS remain the same, but determining how the vehicle and its systems would pass all F/CMVSS tests falls more heavily on the final-stage manufacturer for complete vehicle certification. 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.” This logic can be applied to requests for increased GVWR — but it’s important to note again that such GVWR changes, especially for values outside the chassis-OEM-offered range for the specific model, are also likely to invalidate IVD use as your basis for conformity and any additional guidance provided by the OEM. This means you could become solely responsible for all affected motor vehicle safety standards, emissions and other requirements, including warranty implications. In particular, brake system testing that would have been performed by the OEM, which is based on GVWR, would not likely support a higher GVWR — placing responsibility on the final-stage manufacturer. Similarly, considerations for lowering GVWR into a range where more requirements apply, such as from a GVWR above 10,000 pounds to one 10,000 pounds or less, can create the same situation where IVD-provided guidance and pass-through certification are voided. There are numerous F/CMVSS and other regulations that apply to vehicles with a 10,000-pound or less GVWR but not to those with a 10,001-pound or more GVWR — and the base vehicle being considered in a GVWR-lowering scenario such as this may simply not be capable of meeting the dynamic/destructive performance test requirements applicable to vehicles with a GVWR in this range. Keep in mind, this applies to new motor vehicles. Once a vehicle has been completed in the final stage and has been licensed and titled by an owner in a given U.S. state, or sold and delivered to a purchaser at the first retail level in a Canadian province or territory, the certification obligation ends, along with the ratings assignment. NTEA’s Commercial Vehicle Certification Guide offers the latest regulatory information in the U.S. and Canada. Content addresses safety certification and labeling requirements vital to conformance with NHTSA and Transport Canada regulations. Learn more at ntea.com/certguide.

GVWR changes

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