Manufacturer defect reporting requirements in the work truck industry

Many work truck upfitters understand that as motor vehicle assemblers, they are considered manufacturers by NHTSA under vehicle certification regulations (49 CFR Part 566). Additionally, they know they are responsible as final-stage manufacturers to certify the work trucks they alter or complete from incomplete vehicles to the required FMVSS. However, some do not fully understand their duties and obligations for maintaining records and documentation involved in their vehicle manufacturing operations.