The Low Volume Motor Vehicle Manufacturers Act: What Is It?
- Explanation of the law itself and its origins
- Importance of the act for low-volume manufacturers
- How the legislation has progressed since 2015
The Low Volume Motor Vehicle Manufacturers Act, which was signed into law as part of the Fixing America’s Surface Transportation (FAST) Act on December 14, 2015, was a beacon of hope for car enthusiasts and niche manufacturers alike. The act was designed to allow low-volume motor vehicle manufacturers (LVMs) to bypass the stringent Federal Motor Vehicle Safety Standards (FMVSS) in order to build up to 325 replica vehicles annually. These LVMs include companies that produce fewer than 5,000 units per year, which excludes the large auto giants we all know and think of when we talk about automakers.
Imagine this: a replica Ferrari Dino cruising down the highway or the iconic Land Rover Defender roaring through the rugged countryside. That was the dream the act aimed to turn into reality. And it wasn’t just about selling the idea of nostalgia—these replica cars were to be built with modern emissions standards and safety technology internally, even though their exterior design resembled cars over 25 years old.
The potential impact was huge! But despite all the fanfare and hope, the road to creating a thriving market for legally compliant replica cars has remained arduous. So why haven’t we seen an explosion of these beautifully nostalgic vehicles on our roads? Is it because there’s no interest in building replica vehicles in the USA? Not quite—the answer lies in a mix of red tape, slow-moving regulations, and powertrain compliance headaches.
NHTSA Replica Car Compliance: The Long Wait
- SEMA’s involvement and eventual lawsuit against NHTSA
- Why NHTSA took so long to establish regulations
- The final rule established in 2022 and its impact
It all started optimistically enough. The National Highway Traffic Safety Administration (NHTSA) had exactly one year to establish and roll out regulations to support this law after it was passed in 2015. But instead of quick action, auto manufacturers and enthusiasts found themselves waiting not just one year, but much longer.
By 2019—with almost four years still gone by and no rules finalized—the Specialty Equipment Market Association (SEMA) decided to take legal action against the federal government, accusing NHTSA of stalling and disregarding the FAST Act regulations. In December 2019, after much back and forth, NHTSA finally showed signs of life by signing draft regulations, but the final rules didn’t come into play until March 2022. That’s right—seven long years of waiting for a green light!
All of that wasted time meant a lot of frustration in the industry. But now, under the official guidelines, LVMs must ensure their vehicles both aesthetically resemble older vehicles (at least 25 years old) and adhere to modern safety norms. The dimensions of these replicas are allowed to vary by no more than 10% from the original vehicle, but the heart of the matter lies elsewhere: in the engine.
Powertrains and EPA Regulations: A Major Roadblock
- How replica car manufacturers struggle with EPA compliance
- The need for current-model-year, EPA-certified powertrains
- The complications of warranties and emission control mandates
While the aesthetic elements of the car are relatively straightforward to replicate, it’s what’s under the hood that brings the storm of challenges. To comply with the Environmental Protection Agency (EPA) regulations, including those laid out by the EPA Certification & Compliance Division, any replica car must be built with a powertrain that’s certified to the current model year. That means manufacturers can’t just throw in an old engine or something from another era—they need to source a compliant engine and match all the emissions control systems, like catalytic converters and electronic control units.
Powertrain compliance presents a dual hurdle: Manufacturers are often left stranded trying to find suitable engines that are EPA complaint, and even once they secure an option, they face a mountain of paperwork to certify emissions—and the warranty responsibility cannot be overlooked. The powertrain supplier is required to back up the emission-related components with an eight-year or 80,000-mile warranty, a daunting financial liability for smaller companies. These requirements under EPA regulations are enough to scare off many manufacturers, who would rather prioritize bigger volume production than cater to the intricate needs of a limited-run replica vehicle.
California Air Resources Board (CARB) Regulations: A State-Level Snag
- Additional emissions hurdles from the California Air Resources Board (CARB)
- The replica car and its powertrain must receive individual Executive Orders (EOs)
- Sprawling warranty requirements specific to California
As if federal regulations weren’t enough, manufacturers building replica vehicles in the USA also need to take into consideration the California Air Resources Board (CARB), which is notorious for its stringent emissions regulations. Cars sold in California are subjected to some of the toughest environmental standards in the world. The state’s requirements are critical since the California market is too large to ignore.
Where CARB regulations complicate matters even more for low-volume replica vehicles is that both the car itself and its powertrain must receive an Executive Order (EO) from CARB verifying compliance. And like federal law, the powertrain must leave the assembly line with warranties stretching over years: a 3-year or 50,000-mile warranty on the entire powertrain and a 7-year or 70,000-mile warranty on “high-priced parts.” These daunting hurdles further deter small manufacturers who would otherwise be lining up to offer their products in the Golden State.
Building Replica Vehicles in the USA: The Challenges and Opportunities
- An untapped market awaiting solutions
- Will electric vehicles open new possibilities for replica manufacture?
- Potential future developments in powertrain options
While traditional gasoline-powered replicas face a steep climb, electric vehicles (EVs) present a workaround, as they provide emission-free driving. But even with EVs, there’s no escape from red tape. Obtaining an EO from CARB for EVs poses its own maze of technicalities.
Despite these formidable hurdles, the slow but steady bureacratic crawl over the past has finally given way to a replica warrior’s road. Southfield Classics in Flowery Branch, GA, has achieved LVM certification for its EV-powered chassis that resides beneath a Chevy 3100 pickup body. It features all new components and is, essentially, a new vehicle. With this certification, the door is open for other builders to purchase it and sell replica vehicles as new under the Act. The company is currently developing new chassis to accommodate more classic and hot rod body styles.
Conclusion
The road to replicating classic cars in the United States hasn’t been an easy one. The establishment of the Low Volume Motor Vehicle Manufacturers Act was supposed to signal the dawn of a new era. While delays in NHTSA replica car compliance, complexities surrounding the California Air Resources Board regulations, and the complications of finding modern, emissions-compliant powertrains attempted to ground the movement before it could take off, the use of electric powerplants, combined with quality craftsmanship and effort from Southfield Classics, has created a blueprint for the future of LVMs.
Are you passionate about vintage cars? Want to see a future where these tributes to automotive history hit the road? Follow the legal and automotive developments closely, and let your congressman know that you support the FAST Act and want to see more ‘modern’ classics on the road.
