Where to place vehicle certification labels

From an NTEA member Do certification labels have to be placed on the door pillar of the vehicles we build? This is a common inquiry related to certification labels for multi-stage manufacturers of newly completed or altered trucks. Determining where to place vehicle certification labels may seem like it would be the simplest operation in the whole certification process, but it can have its own challenges with modern vehicles, due to available clear space in the traditional B-pillar location and the contours of these structures from improved manufacturing processes. Modern truck cab and door configurations have been optimized for weight and structure, which has drastically reduced the large, flat surfaces previously available for certification label placement. Location options for installing certification labels are contained in Code of Federal Regulations (CFR) Title 49, Part 567.4 (c). This includes a hierarchy of locations in case primary positions do not work. “Except for trailers and motorcycles, the label shall be affixed to either the hinge pillar, door-latch post, or the door edge that meets the door-latch post, next to the driver’s seating position, or if none of these locations is practicable, to the left side of the instrument panel. If that location is also not practicable, the label shall be affixed to the inward-facing surface of the door next to the driver’s seating position. If none of the preceding locations is practicable, notification of that fact, together with drawings or photographs showing a suggested alternate location in the same general area, shall be submitted for approval to the Administrator, National Highway Traffic Safety Administration, Washington, D.C. 20590. The location of the label shall be such that it is easily readable without moving any part of the vehicle except an outer door.” The last sentence helps reveal the performance intention of the label locations in that they should be readily visible by opening the driver’s door, which is why trailer label locations are contained in a separate paragraph. As similar questions arise for trailer certification, “[t]he label for trailers shall be affixed to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle.” This provides a comparable, readily visible spot to position trailer certification labels; although, there is just one broad location, rather than a hierarchy of options. However, due to the exterior position location, the label is typically created in the form of a plate — with the same required information — in order to withstand environmental exposure. Similarly for vehicles in Canada, 6(3) of the Motor Vehicle Safety Regulations states the label shall be installed on “a bus, multi-purpose passenger vehicle, three-wheeled vehicle, passenger car, truck or low-speed vehicle, (i) to the hinge pillar, door latch post or the door edge that meets the door latch post next to the driver’s seating position, (ii) to the left side of the instrument panel or the inward-facing surface of the door next to the driver’s seating position, where it is impracticable to apply the label in accordance with subparagraph (i), or (iii) to a conspicuous and readily accessible location, where it is impracticable to apply the label in accordance with subparagraph (i) or (ii).” For trailers, the label is located “to the forward half of the left side of the trailer so that it is easily readable from outside the trailer without moving any part of the trailer.” Based on these requirements, the B-pillar is still the most ideal location for label placement on most vehicles, but the hierarchy of options and the objective of being able to readily find and read the labels by only opening the driver’s door will help identify alternatives when necessary.

Where to place vehicle certification labels

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