The Automotive Parts Remanufacturers Association (APRA) recently filed extensive comments supporting retention of the Federal Trade Commission’s Guides for the Rebuilt, Reconditioned and Other Used Automobile Parts. These Guides were adopted by the FTC prior to 1979 and have been periodically reviewed and updated since.
The Guides establish minimum restoration requirements which must be met before a used part can be labeled “rebuilt” or “remanufactured.” They also prescribe labeling requirements for the rebuilt/remanufactured parts so that they will not be confused with new parts.
APRA has been a long-time supporter of the Guides and has promoted them among its members and the remanufacturing industry in general. “The FTC Guides provide remanufacturers with an excellent description of the procedures necessary to process their cores into remanufactured parts and the proper methods to label, market and sell them,” says William Gager, APRA president.
“Without the Guides, those parts suppliers who merely clean or superficially repair used vehicle parts would be more likely to misrepresent the condition of their parts and to market them as comparable to remanufactured/rebuilt parts or even new parts.”
The Guides require full disclosure of whether a non-new motor vehicle part is “used,” “secondhand,” repaired,” “remanufactured,” “reconditioned,” “rebuilt” or “relined.” They also require that before a part can be labeled “remanufactured” or “rebuilt” it be “dismantled and reconstructed as necessary, all of its internal and external parts cleaned and made free from rust and corrosion; all impaired, defective or substantially worn parts restored to a sound condition or replaced with new, rebuilt or unimpaired used parts; all missing parts replaced with new, rebuilt or unimpaired used parts; and such rewinding, machining and other operations performed as are necessary to put the industry product in sound working condition.
Finally, the Guides require the remanufacturer/rebuilder to disclose on the part, packaging and in advertising and marketing materials that the part has been remanufactured/rebuilt and to some extent the identity of the remanufacturer/rebuilder.
The FTC has requested comments on whether the Guides should be retained, their current effect on consumers and small businesses and whether any changes to the Guides were necessary.
