NHTSA Recommendations for Manufacturer Communications Index

Introduction

Manufacturer Communications Index Downloadable Template (.xlsx)

The law now requires manufacturers to submit to NHTSA copies of their communications to dealers, owners, or purchasers about a defect or noncompliance and requires that such communications "shall be accompanied by an index to each communication." 49 U.S.C. 30166(f).

The index must identify the make, model, and model year of the affected vehicles and include a concise summary of the subject matter of the communication. 49 U.S.C. 30166(f)(2). This requirement has been in effect since October 1, 2012. See MAP–21, Public Law 112–141, §3, 126 Stat. 405,413 (2012).

Purpose

This document gives examples of various communications and specific recommendations on completing the fields for the required index.

These recommendations are in addition to the guidance provided in NHTSA Enforcement Guidance Bulletin 2016-01; Guidance on Submission and Treatment of Manufacturer Communications to Dealers, Owners, or Purchasers about a Defect or Noncompliance, 81 Fed. Reg. 16,270-16,275 (Mar. 25, 2016).

Communications index fields

NHTSA's communications index template has seven fields. Each field should contain the appropriate descriptive information related to each submitted communication, as described below. All rows associated with a communication should be sequential.

  • No. (Sequential number, changes for each communication)
    • This field contains numerical digits and represents the sequential number of manufacturer communications being submitted. The No. field should always begin at 1 and continue sequentially, with the largest number equaling the total number of communications submitted with the index.
  • MFR Communication ID
    • The manufacturer communication identifier field, MFR Communication ID, captures a unique alphanumeric identifier used by manufacturers to code the various types of communications being circulated. For example, technical service bulletin numbers, customer satisfaction campaign numbers, newsletter issue numbers, etc., are types of manufacturer communication identifiers. If a manufacturer communication does not have a unique ID already assigned, use the following protocol: [3-characters: World Manufacturer Identifier (WMI) or other alphanumeric identifier] + "-" + [5-character random string] + "-" + [2-digit month of submittal]. For example, "XYZ-V8L9E-04".
      Unique ID Generator (Optional) If a unique ID is needed, enter your WMI or other identifier (3 characters only) in the box below and then select the "Generate Unique ID" button. Copy the generated ID where needed in the index file. If necessary, the ID can be edited after it has been copied to the index file. Additional IDs can be generated by reselecting the "Generate Unique ID" button.

  • MFR Communication Date
    • The manufacturer communication date field, MFR Communication Date, should contain the date of, or date represented on, the specific communication. The format for each date should be MM/DD/YYYY, e.g., 03/09/2016 or 12/25/2016.
  • Make
    • The Make field captures all motor vehicle makes related to a communication. If the communication does not relate to specific motor vehicle make(s), then input NA in this field. For example, communications such as Technical/Technician/Automotive/Manufacturer Newsletters are communications that should have NA for the Make field.
  • Model
    • The Model field captures all motor vehicle models related to a communication. If the communication does not relate to specific motor vehicle model(s), then input other identifying information for the affected motor vehicles or motor vehicle equipment in this field. For example, communications such as Technical/Technician/Automotive/Manufacturer Newsletters are communications that could have other identifying information for the Model field.
  • Model Year
    • The Model Year field captures the range of all motor vehicle model years related to a communication. Use a separate row for each Make/Model/Model Year combination. If the communication does not relate to specific motor vehicle year(s), then input NA in this field. For example, communications such as Technical/Technician/Automotive/Manufacturer Newsletters are communications that could have NA for the Model Year field.
  • Concise Summary
    • The Concise Summary field captures, in 2000 characters or less, a brief description of a communication's most pertinent information, any related vehicle component information, and the general purpose for the communication.

Submitting the communications and communications index

All communications, except recall communications, should be submitted with a communications index file as individual, uncompressed email attachments. If the index has 10 communications, then the email should have 11 attachments (i.e., 1 index + 10 communications). Compressed files, such as .zip, will not be accepted. The submission must be emailed to tsb@dot.gov . The total size of the email, including attachments, cannot be greater than 20 MB. If necessary, divide the submission into multiple emails to meet this size restriction, taking care to follow the index file name sequencing and content requirements given below.

The subject for the email should be:

Manufacturer Non-Recall Communications and Index File from <insert your company name here>

The body of the email should identify the submission and the attachments as follows:

  1. Manufacturer Name
  2. Index File Name and Size
  3. Communication File Name and Size (listed individually)

For example:

layout for email body listing attachments

Recall communications and indexes should be submitted through the Manufacturer Recalls Portal in an accepted file type.

The file name for the index file should use the following protocol: "MIC-" + [first 4 alphanumeric characters of the manufacturer's name] + "-" + [the submission date in MMDDYYYY format] + "-" + [a 3-digit sequential version number beginning with "001" with no gaps in the sequence] + ".xlsx". For example, "MIC-SAMP-01012017-001.xlsx".

The file name for each attached communication should be the MFR Communication ID without any special characters. The original MFR Communication ID should be listed in the index file. All communication files must be in PDF format. The sample communications shown below would have the following document file names: 14AC0021.pdf (for the 14-AC-002-1 communication) and WMIRZX7Q10.pdf (for the WMI-RZX7Q-10 communication). If the communication file naming convention results in multiple files with the same name, submit those files in different emails to avoid any confusion. Each email must have an index file as an attachment and that index file must list only those communication files that are attached to that email.

Examples of completed index entries

Below are examples of completed index entries.

sample for MFR Communications Index file