What label do I use? Part 2: Simplified final-stage certification label

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 involves understanding the various Federal Motor Vehicle Safety Standards (FMVSS) to represent compliance. A manufacturer is defined as 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 each 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. All incomplete vehicles must be certified in the final stage before use on public roads. There are three final-stage certification labels, each with different conformity statements. This article covers the pass-through final-stage certification label.This label’s conformity statement reads: “THIS VEHICLE HAS BEEN COMPLETED IN ACCORDANCE WITH THE PRIOR MANUFACTURERS’ IVD, WHERE APPLICABLE. THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS, [AND BUMPER AND THEFT PREVENTION STANDARDS, IF APPLICABLE] IN EFFECT IN (MONTH, YEAR).” This certification label is used by final-stage manufacturers that can meet all requirements outlined in the incomplete chassis manufacturer’s Incomplete Vehicle Document (IVD). The IVD details the applicable FMVSS conditions and parameters the chassis OEM must meet. Some examples include maximum horizontal and vertical centers of gravity for the applicable braking standard (FMVSS 105, 121 or 135), maximum unloaded vehicle weight for multiple FMVSS requirements, and all other requirements, including restrictions to specific modifications of systems and components. Understanding FMVSS is necessary to ensure the completed vehicle is compliant. During this process, seeking guidance from the chassis manufacturer or any subsequent intermediate manufacturers 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.Certification labels must primarily be affixed to the driver’s side B-pillar or adjacent door face. 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 final-stage certification label has become a challenge.If you cannot meet all IVD conditions specified by the chassis OEM, an alternative final-stage label with a different conformity statement is required. Part 3 of this series will cover the specialized final-stage certification label, which may be an option for this situation. Additionally, NTEA’s Commercial Vehicle Certification Guide (ntea.com/certguide) provides a comprehensive overview with 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 2: Simplified final-stage certification label

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