What label do I use? Part 3: Specialized final-stage certification label (hybrid pass-through 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 application of a label on 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.From a certification perspective, there are four possible manufacturing stages a new vehicle can undergo: 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 certification that involves the combination of OEM pass-through and independent conformity determinations made by the final-stage manufacturer.This label’s conformity statement reads: “THIS VEHICLE HAS BEEN COMPLETED IN ACCORDANCE WITH THE PRIOR MANUFACTURERS’ IVD, WHERE APPLICABLE, EXCEPT FOR [INSERT FMVSS(S)]. THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS, [AND BUMPER AND THEFT PREVENTION STANDARDS IF APPLICABLE] IN EFFECT IN (MONTH, YEAR)” (see Figure 1).Like other forms of final-stage certification, this method is based on the degree to which guidance provided in the chassis OEM’s incomplete vehicle document (IVD) can be used. Part 2 of this series explored a label used by final-stage manufacturers that can meet all requirements outlined in the IVD.In this situation, the conformity statement used for the label allows the final-stage manufacturer to specify certain safety standards for which compliance is determined through means outside the scope of the IVD, while compliance with the remaining applicable standards is represented by staying within the IVD’s guidance. Carefully read the conformity statement for this label, since it can be misinterpreted that the final-stage manufacturer is simply omitting compliance representation for certain standards: however, this is absolutely not the case. Compliance with all the FMVSS that apply to a given vehicle is not optional. Rather, this method assumes compliance is based on the use of OEM’s IVD, other than specific standards that are being met through some other means, such as testing or engineering analyses. These other specific standards are noted as part of the label’s conformity statement.An example that includes use of this label in the certification process could be for an incomplete vehicle, such as a chassis cab, with a gross vehicle weight rating (GVWR) of 10,000 pounds or less. FMVSS 111, the standard for rear visibility that includes mirror requirements, also includes requirements for rear camera systems on light-duty vehicles. Since the OEM would be unable to install the required camera system in a known location that would both comply with the standard and not interfere with the body and equipment being installed, the OEM would likely provide what is known as a “Type 3” conformity statement in their IVD. Regarding the rear camera requirements of the standard, this statement would appear similarly as “conformity with FMVSS 111 cannot be determined based upon the components supplied on the incomplete vehicle, and OEM Motors makes no representation to conformity with the standard.”Since the OEM in this scenario is not providing pass-through compliance, this portion of the standard is left to the final-stage manufacturer. Since there is no basis provided in the IVD for FMVSS 111, the pass-through form of certification (including the associated label) would not apply, and the final-stage manufacturer would need to meet the requirements through a different means. Fortunately, there are other methods available, and OEMs have typically provided additional equipment and information for rear vision system requirements, including technical bulletins for their rear camera systems. By understanding FMVSS 111 and how to meet the rear vision system requirements without conditions provided in the IVD, the final-stage manufacturer can document their methodology — meanwhile staying within the guidance of the IVD for the other standards — and complete the certification process using this label with “111” noted in the conformity statement, as depicted in Figure 1.To learn more about FMVSS requirements, it can be helpful to review various IVDs, as well as the standards themselves, which are available at ecfr.gov/current/title-49/subtitle-B/chapter-V/part-571/subpart-B?toc=1.During this process, seeking guidance from the chassis manufacturer and any subsequent intermediate manufacturers is key. Typically, upfitters can find guidance using the OEMs’ body builder websites. While there is no prescribed format for documenting compliance rationale, manufacturers have a duty to maintain compliance records, and if requested, must make them available to authorized government officials.Additionally, NTEA’s Commercial Vehicle Certification Guide (ntea.com/certguide) provides a comprehensive overview with resources 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 3: Specialized final-stage certification label (hybrid pass-through certification)

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