What this checklist covers
When a manufacturer decides a vehicle or equipment has a safety-related defect or does not comply with a federal safety standard, NHTSA rules require a defect and noncompliance report, notification of owners and dealers, and a free remedy. Federal law also bars dealers from selling or leasing new vehicles with an open recall until the remedy is done.
The NHTSA Recall Compliance Checklist is a 15-point scorecard for defect identification, recall decision, owner notification, remedy process, completion tracking, dealer communication, and NHTSA reporting. Each criterion is scored from 1 to 5 on what the auditor sees on the day, and every gap goes into an action plan with an owner and a close date.
AutoSmart tip: NHTSA recall compliance is one of the few regulatory obligations where the timing of the decision is as important as the quality of the remedy. The 5-business-day reporting clock starts from the date the manufacturer decides a safety defect exists — not from when NHTSA opens an investigation, not from when the remedy is developed. Ensure internal investigation processes have a clear decision gate, so the 5-day clock is not missed because the organisation was still deliberating.
The checks
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Defect identification and recall decision
- Is a defect monitoring process in place — covering warranty claims, field reports, customer complaints, and technical investigations — allowing the organisation to identify a potential safety defect or noncompliance with minimum delay?
- Is the NHTSA definition of a safety recall understood — that it applies when a vehicle, equipment, car seat, or tire creates an unreasonable safety risk or fails to meet a minimum safety standard — and is this definition applied consistently in defect investigations?
- Is a recall decision documented formally — including the basis for the decision, the population of affected vehicles or equipment, and the planned remedy — with the decision record retained?
- Is the 5-business-day reporting requirement to NHTSA (under 49 CFR Part 573) met from the date the manufacturer decides a safety defect or noncompliance exists?
Owner notification and remedy process
- Is owner notification mailed within 60 days of the recall decision (as required by 49 USC 30119) using the notification letter template approved or reviewed in accordance with NHTSA's notification requirements?
- Is the remedy offered to owners consistent with 49 USC 30120 — repair at no cost to the owner, replacement with an identical or reasonably equivalent vehicle, or refund of the purchase price less reasonable depreciation?
- Is the remedy available through the dealer network before or within a reasonable period of owner notification — preventing a situation where owners receive recall letters but cannot get the remedy performed?
- Are second notices sent to owners who have not responded within the required timeframe, as required by NHTSA's owner notification regulation?
Completion tracking and dealer communication
- Is recall completion rate tracked by VIN — covering vehicles remedied at dealerships, vehicles not yet remedied, and vehicles that are unregistered or unlocatable — with reporting to NHTSA on the required schedule?
- Are dealers equipped with the remedy parts, repair instructions, and claim reimbursement process before owner notifications are mailed — preventing owners from arriving at dealers who cannot perform the remedy?
- Is a VIN lookup tool available to dealers and the public, allowing any person to check whether a specific vehicle has an open recall?
NHTSA reporting and governance
- Are quarterly recall reports submitted to NHTSA within the required deadlines, accurately reflecting current completion rates and the number of vehicles remaining unremedied?
- Is a recall file maintained for each campaign — covering the defect report, owner notification, remedy description, parts supply, dealer instructions, and quarterly reports — retrievable for NHTSA review?
- Is the Early Warning Reporting (EWR) system monitored — with reports submitted on the required schedule — allowing early identification of potential safety issues before a formal recall decision is required?
- Is a named person designated as the NHTSA recall compliance contact, with the authority and process to initiate a recall decision, manage the remedy, and interface with NHTSA on the organisation's behalf?
How to run it
How the scoring works
Before the visit, fill in the dealer or centre, the auditor, the date and the audit cycle. Then score each of the 15 checks from 1 to 5 on what you see on the day, not on what the site aims for, and add them up out of 75.
- 1Not in place
- 2Attempted
- 3Defined
- 4Managed
- 5Fully sustained
- Green60–75 · 80–100%Compliant. Keep the standard.
- Amber38–59 · 50–79%Improvement needed: a structured action plan within 30 days.
- Red0–37 · Below 50%Priority intervention, escalated to regional management.
Then close every gap
Each gap goes into the action plan tracker and moves through four stages until the auditor closes it.
- 1PendingOwner and close date set
- 2In progressWork under way, evidence gathered
- 3CompletedEvidence submitted for review
- 4ApprovedVerified and closed by the auditor
Questions about this checklist
Can a dealer sell a new vehicle with an open recall?
Not until the remedy is done: federal law prohibits dealers from selling or leasing new vehicles subject to an open recall. Check NHTSA’s guidance for the details and any exceptions.
What about used vehicles?
Federal law treats used vehicles differently, and state rules vary. Checking used stock and telling buyers about open recalls is good practice.
How do I check a VIN?
Through the manufacturer’s dealer systems or NHTSA’s public VIN lookup on nhtsa.gov/recalls.
