Submission Number: 560948-00003
Received: 5/21/2012 12:22:03 PM
Commenter: Richard Beirne
Organization: United Auto Supply Inc
Agency: Federal Trade Commission
Initiative: 16 CFR Part 20; Guides for the Rebuilt, Reconditioned and Other Used Automobile Parts Industry; Project No. P127702
Attachments: No Attachments
While I understand the need for regulation, it has been my experience that in MOST cases, commonly sold rebuilt/remanufactured/used aftermarket parts are clearly labeled and described correctly to the purchaser. There is more than one channel for the sale of aftermarket parts, but my experience is that installers, fleets, and retail consumers are made aware when they are buying a product that is not new. Products that are remanufactured have always been labeled as such when packaged by reputable sellers. It has also been my experience that the marketplace quickly punishes anyone selling sub-standard parts of any kind, new, rebuilt, remanufactured, or used. I think there is a need for careful regulation, but there exists a risk if those regulations are hard to comply with.
In the last few years, there has been a major change in the availability of new parts that were formerly available only as used. That includes things like carburetors, rotating electrical (starters and alternators), air conditioning compressors, brake parts, CV shafts, and complete engines. Many of these products are now produced off-shore as new. The rebuilt/remanufactured industry is generally a domestic business due to the issue of cores for rebuilding. Shipping cores to off-shore plants for remanufacturing and bringing them back is cost prohibitive.
It is my view that this problem is very well regulated by the marketplace. I am unaware of any major problems with mislabeled or misleading auto parts other than counterfeit parts which is another issue.