What you need to know about the certification
process:
Keys to vehicle certification:
- Proper certification is required by law.
- Proper certification helps assure the
purchaser of safety, reliability and durability.
Who has the Ultimate Responsibility for Certification?
- Final Stage manufacturers
- Vehicle alterers
- Intermediate-stage manufacturers
- Trailer manufacturers
When are Certification Labels Required?
The vehicle certification label is the last step in the certification
process.
Different Labels are required for different stages of certification:
- Incomplete Vehicle (completed by the chassis manufacturer)
- Intermediate Stage
- Final Stage
- Altered Stage
Critical Elements of the Certification
Process
Proper vehicle certification involves more than just
sticking labels on trucks!
You need to perform:
- Payload Analysis
- Weight Distribution; and
- Complete a Federal Motor Vehicle
Safety Standard Compliance Analysis.
Examples:
Incomplete Vehicle Examples:
A truck dealer sends a new chassis-cab (incomplete vehicle) to a truck equipment distributor
for installation of a platform body and a conversion hoist.
A new chassis-cab (incomplete vehicle) is purchased by a customer (end user) directly from
a truck dealer. The customer takes the truck chassis to a truck equipment distributor for
installation of a dump body.
The distributor (Truck Equipment Co) is a final-stage manufacturer and therefore required
to certify the vehicle in the final stage and affix a final-stage certification label in an approved
location. (Removing the incomplete vehicle sticker/label, apply a final-stage certification label.
Altered Vehicle Example:
A truck dealer sends a new one-ton pickup truck to a truck equipment distributor for removal
of the pickup box and installation of a service body.
The vehicle has now been altered, and thus is required to certified with an altered vehicle
certification label. The label must state that, as altered, the vehicle conforms to all applicable
Safety Standards affected by the alteration.
Penalties for Manufacture, Sale of Non-certified Motor Vehicles
By Louie Kleinstiver, Director of Technical Services
National Truck Equipment Association
Posted: 9/5/2002
QUESTION:
Our truck equipment business certifies new incomplete motor vehicles in the final
stage and alters completed vehicles for truck dealers prior to the first purchase.
We are registered with the National Highway Traffic Safety Administration
(NHTSA) as a manufacturer of motor vehicles in compliance with 49 CFRPart
566 - Manufacturer Identification. We also perform a Federal Motor Vehicle
Safety Standard compliance analysis and certify the vehicles we manufacture to
be in compliance with 49 CFRPart 567 - Certification, and Part 568 - Vehicles
Manufactured in Two or More Stages. We constantly encounter situations where
the truck dealers have truck bodies and equipment installed and vehicles altered
by companies that do not certify.
Is there a law against and a penalty for failure to certify? Is there a law against
and penalty for selling a motor vehicle not certified?
ANSWER:
The answer to both questions is YES! The law, Title 49 of the United States Code
(USC), Chapter 301 Motor Vehicle Safety, Section 30112 - Prohibitions on
Manufacturing, Selling, and Importing Noncomplying Motor Vehicles and
Equipment, states, "a person may not manufacture for sale, sell, offer for sale,
introduce or deliver for introduction in interstate commerce, or import into the
United States, any motor vehicle or motor vehicle equipment manufactured on or
after the date an applicable motor vehicle safety standard prescribed under this
chapter [49 USCSection 30101 et seq.] takes effect unless the vehicle or
equipment complies with the standard and is covered by a certification issued
under Section 30115 of this title."
Section 30115 - Certification of Compliance states, "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 prescribed under this chapter [49 USCSection 30101 et
seq.]. A person may not issue the certificate if, in exercising reasonable care, the
person has reason to know the certificate is false or misleading in a material
respect. Certification of a vehicle must be shown by a label or tag permanently
fixed to the vehicle," NHTSAregulations concerning motor vehicle certification
and labeling requirements can be found in 49 CFRPart 567 -Certification, and
Part 568 - Vehicles Manufactured in Two or More Stages.
The law (49 USCSection 30165 - Civil Penalty) states, "A person that violates
any of Section 30112, 30115, 30117 through 30122, 30123(d), 30125(c),
30127, or 30141 through 30147, or a regulation prescribed thereunder, is liable
to the United States government for a civil penalty of not more than $5,000 for
each violation. A separate violation occurs for each motor vehicle or item of
motor vehicle equipment and for each failure or refusal to allow or perform an
act required by any of those sections. The maximum penalty under this
subsection for a related series of violations is $15,000,000." The same penalties
are contained in NHTSAregulation 49 CFRPart 578 - Civil and Criminal Penalties.
Failing to certify and selling a vehicle that is not certified are both against the
law!
No Final Stage Manufacture in Wyoming equals
Colman Equipment Co
Colman Equipment Company of Casper, Wyoming equals Value Added!!
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