What label do I use? Part 1: Altered-stage certification

This three-part series provides an overview of the most common vehicle certification scenarios and the required labels associated with each. The label an upfitter uses is based on the stage of manufacturing they are performing on a new vehicle. As a result, it’s important to understand the different manufacturing stages and the responsibilities, including labeling, that go with them.Certification is a process, not just the act of applying a label to a new vehicle. Under federal law, a “manufacturer or distributor of a motor vehicle or motor vehicle equipment shall certify to the distributor or dealer at delivery that the vehicle or equipment complies with applicable motor vehicle safety standards.” This tells us that certification is something manufacturers do, and it requires knowledge of the various Federal Motor Vehicle Safety Standards (FMVSSs) in order to represent compliance. It is also important to understand that 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.” More specifically, according to the Vehicle Safety Act and National Highway Traffic Safety Administration (NHTSA) regulations, a manufacturer is a person who performs a manufacturing operation on a new incomplete vehicle –– including the incomplete vehicle manufacturer, intermediate manufacturer, and final-stage manufacturer –– or any person who alters a completed vehicle previously certified in the final stage prior to the first purchase.There are four possible manufacturing stages a new vehicle can undergo from a certification perspective: incomplete, intermediate, final and altered. Each stage has its own responsibilities and associated labeling, but all aim to produce a vehicle that meets every applicable motor vehicle safety standard when finished. Not all vehicles go through every one of the four possible stages, but all vehicles must be represented as “complete,” meaning they have been manufactured to a point where they can be certified as meeting all the required safety standards. Prior to being licensed/titled, some completed vehicles go through additional manufacturing operations. This is called altered-stage manufacturing. The label associated with this stage of manufacturing requires the upfitter performing these operations to make the statement that “AS ALTERED IT CONFORMS TO ALL APPLICABLE U.S.A. FEDERAL MOTOR VEHICLE SAFETY, BUMPER AND THEFT PREVENTION STANDARDS AFFECTED BY THE ALTERATION,” along with the month and year in which conformity is represented (see Figure 1).Altered-stage manufacturing involves the upfitting of a previously certified vehicle. Some examples include upfitting performed on pickup trucks and cargo vans, since those vehicles are completed in a single stage by the OEM and leave the factory fully certified. With this definition in mind, altered-stage certification applies to upfitting such as box removal, snowplow installations and accessory installations on pickups, as well as the various passenger and equipment upfitting performed on cargo vans. Vehicles included in the typical gross vehicle weight rating (GVWR) ranges for pickups and cargo vans have more FMVSSs and other more complex requirements than heavier vehicles. Often, when more upfitting is performed — especially where occupant accommodations are being incorporated and/or modified — the more FMVSSs are affected, requiring compliance.Understanding FMVSS is necessary to ensure an altered vehicle remains compliant. During this process, seeking guidance from the previous manufacturer (in most cases, the OEM of the pickup, cargo van, etc.) is key. Typically, upfitters can find guidance using the respective OEM’s body builder websites. While there is no particular form of documenting compliance rationale, manufacturers have a duty to maintain compliance records, and if requested, must make them available to authorized government officials. A shortened version of the alterer’s label can be used when no modifications are made to the tires, wheels, GVWR, gross axle weight rating (GAWR) or vehicle type during alterations (see Figure 2). If none of these elements is changed by the alterer, it is not necessary to restate them on the label. However, if changed, the information is still required. It is important to note that alterations that change vehicle type and/or GVWR can cause additional FMVSSs to apply to the vehicle, requiring compliance to those, as well. Certification labels must be affixed to the driver’s side B-pillar or adjacent door face as the primary location. Because these areas in modern vehicles are becoming more efficiently designed and pre-populated with the certification labels from prior manufacturers, finding available space for the alterer’s label has become a challenge. Utilizing the shorter label when possible can be helpful during production.During certification, it’s important to understand that not all operations performed on completed vehicles prior to licensing/titling are considered manufacturing under regulations. In these scenarios, an alterer’s label is not required. For example, minor finishing operations such as painting or decals are not considered manufacturing operations and would not require certification, if those are the only operations being performed. As a best practice, assume that permanently installing equipment and/or performing any upfitting that may affect a motor vehicle safety standard on a previously certified (but not used) vehicle will require altered-stage certification and labeling. There are two other labels (see Figures 3 and 4) often associated with altered-stage certification as prescribed by FMVSS 110: Tire Selection and Rims and Motor Home/Recreation Vehicle Trailer Load Carrying Capacity Information for Motor Vehicles with a GVWR of 4,536 Kilograms (10,000 Pounds) or Less. These labels provide important and required information for the end user/operators of light vehicles. However, neither of these labels are considered “certification labels.”The July 2025 NTEA News Tech Connections article “Vehicle placard vs. load carrying capacity modification label” covers details on the use and application of these labels. Members can access the article through ntea.com. To recap, certification is more than applying labels to new vehicles. It is a requirement for vehicle manufacturers and involves knowledge of applicable FMVSSs and the documentation needed to support it. The essence of altered stage certification is ensuring that a vehicle continues to meet the same standards it met as represented by the previous manufacturer, and any additional requirements that would apply as a result of the alterations.Additional articles in this series will address forms of final stage certification, and the NTEA Commercial Vehicle Certification Guide provides a comprehensive overview and examples, including labeling, associated with these important regulatory requirements.For additional questions, contact NTEA’s Technical Services Department (info@ntea.com or 248-489-7090 from 8 a.m.–5 p.m. ET, Monday–Friday).

What label do I use? Part 1: Altered-stage certification

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