NTEA regularly receives inquiries regarding multistage vehicle certification, such as:
- How does my company become certified to build work trucks?
- How do I become certified to complete commercial vehicles?
Unlike certified public accountant or certified master technician positions, in the work truck industry, the
vehicle is certified —
not the company or individual.
What you need to know
- An incomplete vehicle must be certified in the final stage to meet Federal/Canadian Motor Vehicle Safety Standards (F/CMVSS) (U.S. or Canadian, respectively) and certified to maintain emissions regulations (U.S. or Canadian, respectively).
- The company must be registered as a final-stage, intermediate-stage and/or altered-stage manufacturer with National Highway Traffic Safety Administration in the U.S. and with Transport Canada in Canada.
- Again, companies aren’t certified (not the chassis OEMs, final-stage manufacturers, etc.). The vehicle is certified to safety standards and emission requirements.
The following information and resources can help provide a better understanding of what’s needed to meet the federal requirements for vehicle certification, including labels associated with the certification process.
JUMP TO FAQs
FAQs
What is vehicle certification and who is responsible for certifying in the U.S.?
- Vehicle certification involves more than putting a label on a work truck — it’s a commitment to meeting specific and consistent processes to help assure the purchaser of safety, reliability and durability.
- A U.S. company building complete commercial vehicles (typically called an upfitter or final-stage manufacturer) has a legal duty and obligation to certify the vehicle to applicable Federal Motor Vehicle Safety Standards (FMVSS) and maintain emissions certification of the work trucks it manufactures. This responsibility and process is commonly known as multistage vehicle certification. A vehicle certification label is the form used by the upfitter to show the vehicle conforms to all FMVSS and emissions requirements.
- Often, new upfitters do not understand they are considered manufacturers under National Highway Traffic Safety Administration (NHTSA) regulations. A chassis cab or cutaway — the foundation of many work trucks — is an incomplete vehicle. When an upfitter adds a truck body and other equipment to an incomplete chassis, the upfitter becomes the final-stage manufacturer for that vehicle.
- While a final-stage certification label does not guarantee a quality vehicle has been built, companies adhering to a strict vehicle certification compliance system are more likely to have a similarly stringent quality assurance program.
Is the vehicle certification process different in Canada?
- The Canadian multistage vehicle certification process has more initial direct government oversight than the U.S. Transport Canada is the federal department that regulates motor vehicle safety standards, and subsequently, certification of multistage-produced vehicles. U.S. and Canada have made efforts to align or harmonize many of the motor vehicle safety standards applicable to cars and trucks as well as many emissions regulations, but the vehicle certification process is significantly different between the countries.
- In Canada, multistage vehicle manufacturers must apply to Transport Canada for a national safety mark (NSM) before beginning multistage vehicle manufacturing. Additionally, safety standard documentation required by Transport Canada must be specific for each commercial vehicle type submitted for an NSM. This includes detailed descriptions and engineering analysis of how the completed vehicle will comply with the required Canadian Motor Vehicle Safety Standard (CMVSS) for each body type and OEM chassis built.
- Some differences between U.S. and Canadian motor vehicle safety standards include the Canadian requirement for daytime running lights and additional noise suppression for electronic equipment like radios and other items. As such, chassis OEMs require vehicles intended for sale in Canada be ordered as Canadian vehicles to ensure all applicable motor vehicle safety standards are properly accounted for in the manufacturing process.
Do upfitters have to register as manufacturers with NHTSA?
- Even though you aren’t producing the base vehicles you’re upfitting, National Highway Traffic Safety Administration (NHTSA) considers you a manufacturer if you take part in any new vehicle manufacturing stage(s), including final-stage manufacturing or vehicle altering.
- Although most multi-stage manufacturers are aware of certification requirements under 49 Code of Federal Regulations (CFR) Part 567 (Certification) and Part 568 (Vehicles Produced in Two or More Stages), some may not know they’re required to identify their operations with NHTSA. Not only is manufacturer identification required by federal regulation, purchasers such as state or municipal governments, leasing companies and private fleets occasionally require proof the manufacturers of their vehicles fulfilled registration requirements in accordance with Part 566.
- Registration requirements under 49 CFR Part 566 (Manufacturer Identification) state all incomplete-, intermediate-, final- and altered-stage manufacturers of motor vehicles and equipment (other than tires) to which a motor vehicle safety standard applies, must submit identifying information and a description of the vehicles they produce. This is a one-time registration unless a business moves or makes relevant changes or additions to its product offerings.
- To determine if your company is already registered with NHTSA, visit vpic.nhtsa.dot.gov/mid. To submit new or updated details (no later than 30 days after a product introduction or change occurs), visit the Manufacturer Portal at vpic.nhtsa.dot.gov/mfrportal. For questions on manufacturer registration, VIN numbers and registered importers, call NHTSA’s help desk at 888-399-3277.
If we modify a used truck, such as replacing the body, do we need to re-certify and re-label the truck after the work is done?
- No new certification labeling is required for used vehicles that have already been certified and licensed and titled in a state (which was a legal requirement when a vehicle was originally built) or for changing a body (e.g., converting a van body to a dump body), which is considered a modification. The modifier is required, though, to make sure the used vehicle still meets Federal Motor Vehicle Safety Standard (FMVSS) requirements such as lighting, braking, etc.
- A vehicle goes through multi-stage certification to FMVSS when it is newly built from an incomplete chassis by the addition of a body and other equipment. Once it is certified as a completed vehicle and becomes licensed and titled in a state, that original certification is what NHTSA recognizes.
- For more information, visit ntea.com/missinglabels.
Where can I find information on U.S. vehicle certification labels?
- The Vehicle Safety Act requires each manufacturer of a motor vehicle or motor vehicle equipment to affix a certification label on the vehicle prior to delivery to the succeeding manufacturer, dealer or purchaser of the vehicle. The label must certify that the vehicle or item of motor vehicle equipment conforms to all applicable safety standards in effect on a specified date.
- Certification labeling requirements follow the stages of manufacturing — incomplete-, intermediate-, final- and altered-stage — and can be found in U.S. 49 CFR Parts 567 and 568 and Canada MVSR C.R.C, c. 1038. Additional labeling is required for vehicles with a GVWR of 10,000 pounds or less, providing consumers with tire and loading information.
- WorkTruckCert is an efficient solution for creating vehicle certification labels. This cloud-based program was designed to streamline the completion and printing of certification labels and Second Stage Manufacturer’s Statements of Origin. The system archives vehicle records and helps companies document conformance with NHTSA-required safety standards. There is no cost to use the WorkTruckCert program (product purchase fees apply).
MORE RESOURCES
Disclaimer: This webpage and any related resources are intended for informational purposes only, and should not be used as a substitute for independent engineering analysis or judgment. This webpage and any related resources are not, and are not intended to, constitute legal advice or confirm legal compliance. To determine compliance with laws and engineering standards, consult with your own legal counsel and engineering experts.