Understanding 49 CFR 595 “Make Inoperative”

Register with NHTSA

This registration is for ALL dealers who convert vehicles for the disabled, and we hope you have already completed this. If you have not, a template letter to NHTSA is located below. Please make sure to use your own letter head and place your company information in the proper places. Keep a copy for your records and send the original Certified Return Receipt mail. This will be your way of proving your registration with them. (NHTSA will not send you any type of response.)

Make-Inoperative Disclosure Form

Proper Record Keeping

NMEDA has developed a form to comply with the “Make Inoperative” ruling from NHTSA. Please follow the steps listed below.

  • Make copies of the form linked above.
  • Fill out the necessary information on your company.
  • Fill out your customer’s information.
  • Fill out your customer’s vehicle information.
  • Mark if the modifications are being done for a driver and/or passenger.
  • Check all modifications made to vehicle (don’t forget the load carrying capacity).
  • Make a copy of the completed form.
  • Give the original to your customer to be kept with the vehicle’s papers.
  • File your copy of the form in the customer’s file, to be kept for 7 years.
  • Affix your label as required by NHTSA, adjacent to the original certification label or alterer’s certification label, if applicable


An important part of CFR 49 Part 595 is the label requirements. Labels should include:

  • Modifier’s name.
  • Modifier’s physical address.
  • The statement “This vehicle has been modified in accordance with 49 CFR 595.6 and may no longer comply with all Federal Motor Vehicle Safety Standards in effect at the time of its original manufacture.”
  • Affix your label, as required by NHTSA, adjacent to the original certification label or the alterer’s certification label, if applicable.

You may purchase these labels with the following form:

Supply Order Form

Notice: You must affix the Make Inoperative label in addition to the QAP numbered label. (Reason – There is no place on the QAP label for the modifier’s name and address.)

A Final Note

FMVSS #301 “Fuel System Integrity” is not exempt. This means that any lowered floor modifications where the fuel tank or connections are made or relocated will have to be of a type that has been certified by the supplier as complying with FMVSS #301. The certification can be through some combination of testing and engineering analysis but it must be available to NHTSA upon request.

If you are curious about the specific details of any of the FMVSS or the “Exemption from the Make Inoperative Prohibition” final rule you can find information in the NMEDA Guidelines and view them for yourself. The NMEDA Guidelines Section 2 is an attempt to cut through all the extraneous discussion and put the ruling into plain language while maintaining the intent of the ruling. The rule itself and the standards referenced would take precedence. If you are not familiar with the FMVSS then you really need to look them over in the Guidelines.

Sample Letter to NHTSA

Download letter

Attn: Administrator
National Highway Traffic Safety Administration
1200 New Jersey Ave., SE
Washington, D.C. 20590

Dear Administrator:

Please be advised that we wish to register with your agency as a specialty vehicle modifier for people with disabilities.

Our corporate name is:

We are located at:

State of Incorporation:

We make modifications for people with disabilities to operate or ride as a passenger in the modified vehicle and we intend to avail our-self of the exemption provided in 49 CFR 595.7

Thank you for your time and should you have any questions, please do not hesitate to contact us at the above.


(your name)
(company name)
(your position/title)