Entering the US Market: Vehicle Safety (FMVSS)

FMVSS are the US federal motor vehicle safety standards. Their fundamental difference from EU type approval is that the regime is based on SELF-CERTIFICATION: the manufacturer itself declares that its product complies with the standards; no prior approval is obtained.

The obligation lies with the manufacturer, and responsibility passes to the manufacturer with the declaration. Manufacturers outside the United States are obliged to appoint a representative established in the US before NHTSA.

• Test reports to the relevant FMVSS standards
• The declaration of conformity and the certification label
• Manufacturer identification details and the VIN structure (for vehicles)
• The NHTSA representative appointment
• Records of the registration and recall obligations

1. 01Scope DeterminationIt is determined which legislation and marking scope the product falls under in the target market. This step defines the entire process; getting it wrong wastes all subsequent work.
2. 02Determining Applicable StandardsThe standards accepted by the market and any national deviations are identified. The same IEC standard may apply with different deviations in different markets.
3. 03Establishing the Test PlanIt is assessed which part of existing test reports will be accepted; missing tests are planned. A CB Scheme report, if available, reduces retesting.
4. 04Local Party and RegistrationIf the market requires an established representative, importer or applicant, this party is designated and the necessary registrations are made.
5. 05Tests and Technical FileTests are conducted and the technical file is prepared. Some markets require testing to be performed within their own country.
6. 06Certification or DeclarationDepending on the market's regime, a manufacturer's declaration is drawn up or a certificate is obtained from the authorised body; a factory audit is carried out if required.
7. 07Marking and LabellingThe mark and label are applied according to the market's format and language rules. The language requirement is checked at customs in most markets.
8. 08Shipment and CustomsIf a pre-shipment document is required, it is obtained; the document set to be presented at customs is completed.

• The regime is based on self-certification; no prior approval is obtained but responsibility is heavy
• Where non-conformity is found, a recall obligation arises
• An E-Mark or EU type approval does not take the place of FMVSS
• Component manufacturers also make their own declarations

1. 01The US vehicle arrangement and UNECE type approvalThe most fundamental difference: here there is no type approval and the manufacturer makes its own declaration. Under the UNECE arrangement an authority approves the type and the approval is mutually recognised. A vehicle's UNECE approval is not valid in this market.
2. 02Safety standards and emissions requirementsSafety falls under the transport authority's competence and emissions under the environmental authority's; the two processes run separately and neither satisfies the other.
3. 03Vehicle certification and equipment certificationThere are separate standards for items such as tyres, headlamps, glazing and seats, and their manufacturers make their own declarations; the vehicle's declaration does not cover the component's declaration.
4. 04Declaration and the recall obligationThe declaration is the beginning of the process rather than its end: when the manufacturer identifies non-conformity it is obliged to notify and remedy it, and this obligation continues throughout the life of the vehicle.

There is no separate certification page for this mark; the scope and process are as described on this page. The roadmap specific to your product is provided in writing at the quote stage.

This section's content is being prepared. The roadmap specific to your product and target market at the quote stage in writing.