Industry associations APRA, MEMA and MERA have weighed in on the newest “FTC Guides for 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 Automotive Parts Remanufacturers Association (APRA) strongly urged the FTC to retain the Guides, believing that compliance with the Guides is not difficult and normally not costly to the parts supplier or the consumer. “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 APRA President, William Gager. “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.”
APRA suggested that the Guides be modified to make it clear that they applied to imported parts as well as domestic parts; to have them apply to all farm, construction and industrial vehicles; to make the requirements for clear and conspicuous disclosure more precise; to add language requiring a parts supplier to distinguish those parts which are repaired and reconditioned (but not rebuilt or remanufactured) from those which are being sold in used “as-is” condition and to require that the original trademark be left on the rebuilt/remanufactured part.
For their part, the Motor & Equipment Manufacturers Association (MEMA) and its remanufacturing affiliate, the Motor & Equipment Remanufacturers Association (MERA), are urging the U.S. Federal Trade Commission (FTC) to more accurately classify remanufactured parts. In their comments, MEMA and MERA stated that classifying remanufactured parts in the same category as parts not produced using standardized industrial processes in a manufacturing environment (used parts) is both inaccurate and confusing to consumers.
“While the industry acknowledges remanufactured parts are not ‘new,’ the new commercial reality is that they should not be classified as ‘used’ parts,” said John Chalifoux, president and COO of MERA. “Doing so ignores the significant advancements this country’s remanufacturing industry has made with regard to consumer quality and in the area of international trade since the Guides were first adopted in 1979.”
In support of their position, MEMA and MERA referenced more recent documents from other U.S. federal agencies including bilateral free trade agreements that recognize “remanufactured goods” as a unique classification.