Meeting Trailer Manufacturing Checklist Requirements

As of Jan. 2012, NATM required all trailer manufacturing members to participate in, and pass, the NATM Compliance Verification Program (CVP) to retain membership. To complete the program a compliance consultant visits the manufacturing facility and uses a checklist to verify that the required procedures and processes are in place. The checklist is based on NATM’s Guidelines for Recommended Minimum Manufacturing Practices for Light- and Medium-Duty Trailers, which is provided to all members.


The consultation checklists completed for 2015 have been evaluated to identify the top five items that fail to pass inspection. The five items most frequently missed on the checklists are:

- Owner's Manual includes required tire information - NHTSA notification statement is provided to each owner (10 point type minimum) - Front Side Reflex Reflectors - may be combined with lamps (Lens Coding “A”) - Front Clearance Lamps (Lens Coding “P2”, “PC” or “P3”, “PC2”) - Correct information on the certification label These items are not recommendations but obligations to manufacture trailers and in turn enable companies to pass the program. Correcting these items is fairly simple.

Owner’s Manual includes required tire information The minimum requirement for certification on this item is: the manufacturer provides the NHTSA brochure “Tire Safety - Everything Rides on It” or the NATM Tire Safety document with each trailer with a GVWR of 10,000 lbs. or less.

The Consumer Information regulations 49 CFR 575.6 requires additional tire information be provided with all trailers required to display the Tire Placard. NATM has published this tire safety information at www.NATM.com in the “Members Only” section area under PDFs. This document includes information for calculating cargo capacity for trailers as well as for the tow vehicle. It also includes all the definitions of terms (Glossary) contained with FMVSS 110 and 139 and the complete relevant text from the NHTSA brochure, “Tire Safety - Everything Rides on It.” You may obtain copies of this brochure from the NHTSA website by going to: www.nhtsa.gov/Vehicle+Safety/Tires/Tire+Safety:+Everything+ Rides+On+It

NHTSA notification statement is provided to each owner The minimum requirement for certification on this item is: the manufacturer provides the notification statement with each trailer.

49 CFR Part 575.6 (a) (2) (i - ii) states: (i) At the time a motor vehicle manufactured on or after Sept. 1, 1990, is delivered to the first purchaser for purposes other than resale, the manufacturer shall provide to the purchaser, in writing in the English language and not less than 10 point type, the following statement in the owner’s manual, or, if there is no owner’s manual, on a one-page document:

If you believe that your vehicle has a defect that could cause a crash or could cause injury or death, you should immediately inform the National Highway Traffic Safety Administration (NHTSA) in addition to notifying ABC Manufacturing, Inc. If NHTSA receives similar complaints, it may open an investigation, and if it finds that a safety defect exists in a group of vehicles, it may order a recall and remedy campaign. However, NHTSA cannot become involved in individual problems between you, your dealer or ABC Manufacturing, Inc. To contact NHTSA, you may either call the Vehicle Safety Hotline toll-free at 1-888-327-4236 (TTY: 1-800-424-9153), go to www.safercar.gov; or write to: Administrator NHTSA 1200 New Jersey Avenue S.E Washington, DC 20590


You can also obtain other information about motor vehicle safety from www.safercar.gov. (ii) The manufacturer shall specify in the table of contents of the owner’s manual the location of the statement in 575.6(a)(2)(i). The heading in the table of contents shall state “Reporting Safety Defects.” 49 CFR Part 575.6 (a)(2)(i-ii).

Front side reflex reflectors are properly installed The minimum requirements for certification on this item are: the front side reflex reflectors installed have lens coding “A” (A2 for trailers 80” or more in width) and are mounted at the appropriate height. These may be combined withlamps. 49 CFR 571.108 The mounting height from the ground is between 15 and 60 inches. If reflector is combined with the front side marker lamp, it cannot be mounted at a 45-degree angle. Reflex reflectors may not be required if they are replaced in their required location with conspicuity treatment. Special Condition: (S5.1.1.15) A trailer that is less than 6 feet in overall length, including the trailer tongue, need not be equipped with front side marker lamps and front side reflex reflectors.

Front clearance lamps are properly installed on units 80” width or wider

The minimum requirement for certification is: the front clearance lamps installed have lens coding “PC”, “P3”, or “PC2” are mounted in the appropriate location. 49 CFR 571.108 Front clearance lamps show vehicle's width and must be mounted at the widest point - symmetrical on the front or near the front facing forward, such that the center of the lens is no further than six inches from the extreme width of the trailer, and as high as practicable. More information can be found by referring to the NATM Guidelines for Recommended Minimum Manufacturing Practices for Light- and Medium-Duty Trailers Section B-6 Lighting Reflectors/Conspicuity and the National Highway Traffic Safety Administration (NHTSA) lighting chart. The NHTSA lighting chart is available for purchase by contacting NATM headquarters. Correct information on the certification label 49 CFR Part 571.10 or 571.120 Each vehicle shall show the information specified in S5.3.1 and S5.3.2 (i.e. ST205/75D15C) and, in the case of a vehicle equipped with a non-pneumatic spare tire, the information specified in S5.3.3, in the English language, lettered in block capitals and numerals not less than 2.4 millimeters high and in the format set forth following this section.

S5.3.1 Tires. The size designation (not necessarily for the tires on the vehicle) and the recommended cold inflation pressure for those tires such that the sum of the load ratings of the tires on each axle (when the tires' load carrying capacity at the specified pressure is reduced by dividing by 1.10, in the case of a tire subject to FMVSS No.109 [i.e., “p-metric” tires]) is appropriate for the Gross Axle Weight Rating (GAWR) as calculated in accordance with S5.1.2.

Complete rim information is included on the certification label 49 CFR Part 571.10 or 571.120 Each vehicle shall show the information specified in Part 571.110 S4.3.3 or 571-120 S5.3.1 and S5.3.2 (i.e. T 16x6 or 15x5J) and, in the case of a vehicle equipped with a non-pneumatic spare tire, the information specified in S5.3.3, in the English language, lettered in block capitals and numerals not less than 2.4 millimeters high and in the format set forth following this section. S5.3.2. Rims: The size designation and, if applicable, the type designation of Rims (not necessarily those on the vehicle) appropriate for those tires:

Truck Example--Suitable Tire-Rim Choice

GVWR: 7,840 kilograms (17,280 pounds) GAWR: Front--2,850 kilograms (6,280 pounds) with 7.50-200(D) tires, 20 x 6.00 rims at 520 kPa (75 psi) cold single. GAWR: Rear—4,990 kilograms (11,000 pounds) with 7.50-20(D) tires, 20 x 6.00 rims, at 450 kPa (65 psi) cold dual. GAWR: 13,280 kilograms (29,279 pounds). GAWR: Front--4,826 kilograms (10,640 pounds) with 10.00-20(F) tires, 20 x 7.50 rims, at 620 kPa (90 psi) cold single. GAWR: Rear--8,454 kilograms (18,639 pounds) with 10.00-20(F) tires, 20 x 7.50 rims, at 550 kPa (80 psi) cold dual.


Correct axle information is included on the certification label 49 CFR Part 567.4 (g) (4) The label shall contain the following statements, in the English language, lettered in block capitals and numerals not less than three thirty-seconds of an inch high, in the order shown: “Gross Axle Weight Rating or "GAWR," followed by the appropriate value in pounds for each axle, identified in order from front to rear (e.g., front, first intermediate, second intermediate, rear). The ratings for any consecutive axles having identical gross axle weight ratings when equipped with tires having the same tire size designation may, at the option of the manufacturer, be stated as a single value, with label indicating to which axles the ratings apply.”

GVWR included on the certification label 49 CFR Part 567.4 (g) (3) The label shall contain the following statements, in the English language, lettered in block capitals and numerals not less than three thirty-seconds of an inch high, in the order shown: "Gross Vehicle Weight Rating" or "GVWR," followed by the appropriate value in pounds, which shall not be less than the sum of the unloaded vehicle weight plus rated cargo load. Date of manufacture is included on the certification label 49 CFR Part 567.4 (g) (2) The label shall contain the following statements, in the English language, lettered in block capitals and numerals not less than three thirty-seconds of an inch high, in the order shown: Month and year of manufacture: This shall be the time during which work was completed at the place of main assembly of the vehicle. It may be spelled out, as "June 1970", or expressed in numerals, as "6/70."

Compliance statement is included on the certification label 49 CFR Part 567.4 (g) (5) The statement: The label shall contain the following statements, in the English language, lettered in block capitals and numerals not less than three thirty-seconds of an inch high, in the order shown: "This vehicle conforms to all applicable Federal Motor Vehicle Safety Standards in effect on the date of manufacture shown above." The expression "US" or "USA" may be inserted before the word "Federal".

Proper vehicle type is included on the certification label 49 CFR Part 567.4 (g) (7) The statement: The label shall contain the following statements, in the English language, lettered in block capitals and numerals not less than three thirty-seconds of an inch high, in the order shown: The type classification of the vehicle as defined in Sec. 571.3 of this chapter (e.g., truck, MPV, bus, trailer).




Weights and pressures listed in both metric and English measurements on the certification label


49 CFR Part 571.10 S4.3.3 or 571.120 S5.3.2


All weights and pressures must be listed in metric first with English measurements second (English measurements are not required).


All items are listed in the correct order on the certification label


49 CFR Part 567.4 (g)


The label shall contain the following statements, in the English language, lettered in block capitals and numerals not less than three thirty-seconds of an inch high, in the order shown:


  1. Name of manufacturer

  2. Month and year of manufacture

  3. Gross Vehicle Weight Rating or “GVWR”

  4. Gross Axle Weight Rating or “GAWR”

  5. The Type of Tires

  6. The Type of Rims

  7. Inflation Pressure - KPA (PSI)

  8. The statement: “This vehicle conforms to all applicable Federal Motor Vehicle Safety Standards in effect on the date of manufacture shown above”

  9. Vehicle identification number

  10. The type of classification of the vehicle (e.g., truck, MPV, bus, trailer)


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