Usage requirements for vehicle placards vs. load carrying capacity modification labels

From an NTEA member Can you explain the difference between the tire and loading information label and the small, yellow load modification label, including when each should be used? The usage requirements for both of these labels can be found in Federal Motor Vehicle Safety Standard (FMVSS) 110, which requires all new vehicles with a gross vehicle weight rating (GVWR) of 10,000 pounds or less to have a vehicle placard (also known as the tire and loading information label) affixed to the driver’s side B-pillar. The requirement for this label has been in effect since September 2005 and serves to provide operating safety information from the vehicle manufacturer to the end-user, as one would conclude, related to the tires and loading of the vehicle. The standard’s requirements for the placard color, format and location provides a consistent means to draw the attention of the vehicle operators, generating recognition of the important information they contain. As a final-stage manufacturer, completing an incomplete vehicle, such as a chassis cab or cutaway, with a GVWR of 10,000 pounds or less, a new placard (Figure 1) is required and must be completed with actual tire size, inflation pressures, number of seating positions, and remaining cargo and passenger capacity information included. If you are altering a completed vehicle with a GVWR of 10,000 pounds or less (which would already be required to have a placard installed by the manufacturer that completed the vehicle), the information on the existing placard may need to be corrected. For example, the placard would no longer match the configuration of the vehicle if you were removing or adding seats or changing tires before the first retail sale, in which case this information must be corrected by one of the following methods. Cover the existing placard completely using a new placard with the correct information. Overlay the affected areas on the existing vehicle placard without affecting placard design or color requirements while leaving the accurate information undisturbed and visible. In situations where you are altering a completed vehicle with a GVWR of 10,000 pounds or less, such as a pickup truck or cargo van, where the curb weight of the vehicle is increased and the alterations do not include any changes to the number/location of the designated seats or any changes to the tires before the first retail sale, there is another option that can be more desirable than replacing the placard information. Since this combined capacity on the placard reflects the difference between the GVWR (or potentially a lesser threshold determined by the prior manufacturer) and the curb weight of the completed vehicle, it helps prevent overloading by end-users. This capacity is reduced when the curb weight is increased by the addition of other permanently attached equipment. If the amount of added weight exceeds “the lesser of 1.5 percent of GVWR or 45.4 kg (100 pounds)”, then the combined weight of occupants and cargo value on the placard must be corrected. This is where the small, yellow load carrying capacity modification label comes in as an option to communicate the reduced capacity of the vehicle. While the first two options to correct the placard information could also be used, where applicable, this label helps upfitters adding equipment such as snowplows, toolboxes, ladder racks, partitions, and bins and racks to complete vehicles that would already have a vehicle placard, by only requiring communication of the amount of increased weight (i.e., reduction in capacity) due to the added equipment. For example, if altering a new pickup, only by installing a toolbox and ladder rack for a dealer, and the equipment with all attachment hardware weighs 145 pounds (66 kg, exceeding the 45.4 kg limit), you could complete the load carrying capacity modification label (Figure 1) and place it next to (within 1 inch) the existing vehicle placard. The equipment manufacturer should provide the weight(s) of their products you’re installing, but remember to account for fastener weights, etc. If estimating, it’s better to overstate than understate the load carrying reduction when complying with National Highway Traffic Safety Administration requirements, but you will want to ensure the capacity reduction still accommodates any minimum cargo requirement of your customer, over and above the minimum required weight accommodation for passengers in the remaining capacity. It’s important to recognize that the load carrying capacity modification label only works in conjunction with an existing placard, and only to serve as one of the options to communicate the reduction to the combined weight of occupants and cargo stated on the placard. So, an altered-stage manufacturer would not install both a placard and a load carrying capacity modification label. If you need to generate a new placard to go on an altered vehicle in order to correct the original one, the remaining load carrying capacity should simply be stated on the new placard, along with the other information being corrected. To recap, if you are a final-stage manufacturer of a vehicle with a GVWR of 10,000 pounds or less, you would install a placard, along with your final-stage certification label. If you are altering a vehicle with a GVWR of 10,000 pounds or less, and changing the number of seats and/or any tire specifications, you would replace/cover the existing placard with a new, correct one or overlay corrected info, along with your altered-stage label. Or, if altering a vehicle only by the addition of permanently attached equipment that exceeds either limit of 1.5% of the GVWR or 45.4 kg (100 pounds), you have the option to use the load carrying capacity modification label, along with your altered-stage label. And, if the alterations do not involve any changes affecting the placard information and do not exceed the capacity reduction limits, then the existing placard is still considered accurate and you would only need to install your alterer’s label. If you have additional questions, contact NTEA’s Technical Services Department (248-489-7090 or info@ntea.com).

Usage requirements for vehicle placards vs. load carrying capacity modification labels

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