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NHTSA Recommendations for Manufacturer Communications Index

Introduction

The law 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).

Manufacturer Communications Portal (MCP)


https://mcp.nhtsa.gov/

NHTSA has released a new online portal to facilitate the submission of communications and index data. The MCP provides an easy-to-use, online application that allows manufacturers to submit their communications and the required index information to NHTSA. NHTSA recommends that manufacturers use the MCP to submit copies of their communications to dealers, rental companies, owners, or purchasers about a defect or noncompliance, rather than submitting them via e-mail.

Manufacturers using the MCP will no longer need to create and submit a separate index document. Instead, the MCP will use the information provided by each manufacturer about each communication—including the make, model, and model year of the affected vehicles and a concise summary of the subject matter of the communication—to automatically generate the required index.

NHTSA recommends manufacturers use the MCP. Here's a link to the MCP User Guide. For manufacturers that choose not to use the MCP, Please click on the link below to get information on how to submit via e-mail.

E-mail submission of Manufacturer Communications


Although NHTSA recommends that manufacturers use the MCP rather than submitting their communications via e-mail, the MCP does not replace the e-mail submission process at this time. The following guidance gives examples of various communications and specific recommendations on completing the fields for the Excel index for e-mail submission for manufacturers that choose not to use the MCP.

Manufacturer Communications Index Downloadable Template (.xlsx)

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, shall be populated with the exact file name for the document being submitted. Please use your company's existing document naming convention when one already exists. For example, if the document is a Technical Service Bulletin and your company's name for it is TSB2015-081, that name should be what appears in the field MFR Communication ID, as well as being as the name of the actual document as submitted. 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 e-mail attachments. If the index has 10 communications, then the e-mail should have 11 attachments (i.e., 1 index + 10 communications). Compressed files, such as .zip, will not be accepted. The submission must be e-mailed to tsb@dot.gov . The total size of the e-mail, including attachments, cannot be greater than 20 MB. If necessary, divide the submission into multiple e-mails to meet this size restriction, taking care to follow the index file name sequencing and content requirements given below.

The subject for the e-mail should be:

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

The body of the e-mail 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 e-mail 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 e-mails to avoid any confusion. Each e-mail must have an index file as an attachment and that index file must list only those communication files that are attached to that e-mail.

Examples of completed index entries

Below are examples of completed index entries.

sample for MFR Communications Index file