My friend, we’ve spoken privately about this issue but since you posted about it here. I’ll state my point clearly here.
I’ve already spoken to multiple attorneys about this, and I’m going to rely on their legal advice rather than opinions on a forum. Here’s the exact legal guidance I received, with the relevant language from the statutes and FTC policies themselves:
• Magnuson–Moss Warranty Act (15 U.S.C. § 2301–2312) applies only to new consumer products.The key line is:
Quote:
|
“A written warranty means any written affirmation… made in connection with the sale of a new consumer product.”
|
Rebuilt parts are not “new consumer products,” so these restrictions do not apply.
• Federal Regulation 16 C.F.R. § 700.11 (rebuilt/refurbished goods) states:
Quote:
|
“A supplier is not required to provide a written warranty… and if a warranty is given, the warrantor may specify the conditions under which it is applicable.”
|
Meaning: a rebuilder is legally allowed to condition a warranty on a tamper-evident seal.
• FTC Businessperson’s Guide to Federal Warranty Law explicitly says:
Quote:
|
“If you sell a repaired or refurbished item, you may define the terms and conditions of your own warranty.”
|
This is exactly the situation here with our units.
• The FTC’s restrictions on “warranty void if removed” stickers apply only to OEM manufacturers of NEW goods who attempt to restrict independent repair. They do not apply to independent rebuilders offering a workmanship guarantee.
• And to be clear, every major remanufacturer, Cardone, Bosch, ACDelco, Garrett, Dorman, uses the exact same tamper-evident seals and ties their warranty to the integrity of that seal. So based directly on federal statutes, FTC guidance, and accepted industry standards, the attorneys I consulted were very clear: This practice is legal, appropriate, and standard for rebuilt components.
Let’s not stretch this any further than it needs to. The matter is settled on my end, and I’m proceeding according to actual legal counsel. And to be honest, I think 99% of customers here already understand this as well. We offer an unlimited-miles, transferable lifetime warranty for a reason. If any of our units ever fail due to workmanship, we replace it. That speaks for itself.
Abdul