Intermediate-stage vehicle certification labels and required documentation

From an NTEA member We are a work truck upfitter and have been asked to modify the wheelbase on a new incomplete chassis, which will go to another company for installation of customer-specified body and equipment. What are our certification obligations?In this situation, your company is considered an intermediate-stage manufacturer, defined by National Highway Traffic Safety Administration (NHTSA) as “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.” An intermediate-stage manufacturer’s certification-related duties are unique and require special attention to potential impacts on chassis OEM compliance representations and the resulting effects on the final-stage manufacturer’s certification of the completed vehicle. As an intermediate-stage manufacturer, consider matching chassis modifications, added components, and their arrangement as closely as possible to the model configuration for a completed vehicle if it were manufactured by the chassis OEM.Wheelbase modifications may affect a variety of Federal/Canadian Motor Vehicle Safety Standards (F/CMVSS), which subsequently impact statements in the chassis OEM’s incomplete vehicle document (IVD). Accordingly, the intermediate-stage manufacturer is required to provide an IVD addendum containing the company’s name, mailing address, and all revisions that should be made to the IVD to reflect any vehicle changes. The addendum must contain a certification by the intermediate manufacturer that the statements within are accurate as of the date of manufacture by the intermediate manufacturer, and can be used and relied on by any subsequent intermediate-stage manufacturer(s) and the final-stage manufacturer as a basis for certification. In the addendum, the intermediate manufacturer should list standards affected and amending statements in a form similar to the statements required in an IVD.To begin this process, the intermediate-stage manufacturer should review the original chassis manufacturer’s IVD to identify potential affects on applicable F/CMVSS. In particular, wheelbase changes can affect the brake system. This doesn’t necessarily mean the vehicle would be out of compliance, but the intermediate-stage manufacturer must review statements of conformity for the brake system and any other applicable standards for compliance conditions specified by the chassis OEM. Brake system standards — hydraulic or air — are covered under F/CMVSS 105 and 121, respectively. Brake hoses, addressed in F/CMVSS 106, can also be affected, and any additions or modifications to these components will require evaluation. Center of gravity limitations may be different with the new wheelbase, and axle weights and vehicle brake proportioning are subject to change for vehicles with the same gross vehicle weight rating (GVWR). Modifications must be reviewed against IVD conformity statements contained for these standards and any others affected by wheelbase changes.Amended IVD statements can be challenging for many companies because they are specific to the individual incomplete vehicle, and a wheelbase modification can encompass multiple systems, such as anti-lock braking system (ABS) function, exhaust/emissions, lighting, fuel lines, and more.Type statementsThere are three types of conformity statements used in an IVD, which are also considered legal declarations in Canada.“Type 1—A statement that the vehicle when completed will conform to the standard if no alterations are made in identified components of the incomplete vehicle.”“Type 2—A statement of specific conditions of final manufacture under which the manufacturer specifies that the completed vehicle will conform to the standard.”“Type 3—A statement that conformity with the standard cannot be determined based upon the components supplied on the incomplete vehicle, and that the incomplete vehicle manufacturer makes no representation as to conformity with the standard.”An example of a Type 2 statement in an IVD for FMVSS 121 might be: “This vehicle when completed will conform to FMVSS No. 121, Air Brake Systems, if it does not exceed any of the gross axle weight ratings, if the center of gravity at GVWR is not higher than 70 inches above the ground, and if no alterations are made in any brake system component.” If the intermediate manufacturing operation affects any of these requirements as described in the IVD, the intermediate-stage manufacturer would be responsible for providing a corrected statement that can be used and relied upon by any subsequent intermediate-stage manufacturer(s) and the final-stage manufacturer as a basis for certification.The intermediate-stage manufacturer must affix an information label to the incomplete vehicle with intermediate manufacturer name, month and year in which they performed their last manufacturing operation, gross vehicle weight rating and gross axle weight ratings for each axle in both kilograms and pounds (if different than the incomplete vehicle document), and vehicle identification number. When applied to the chassis, the information label should not obscure labels applied by previous-stage manufacturers.As with all motor vehicle and motor vehicle equipment manufacturers, intermediate-stage manufacturers are required to submit identifying information to NHTSA. If you have not previously done so, you’ll need to identify your operations. If you have an existing manufacturer identification record with NHTSA, updated information can be added to include intermediate-stage manufacturing. The agency provides a public web portal (vpic.nhtsa.dot.gov) to submit this information, and lists submissions from all other manufacturers that have fulfilled this requirement.Visit ntea.com/technicalresources for details on NTEA’s technical and engineering offerings.

Intermediate-stage vehicle certification labels and required documentation

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