Examples of Compliance with the Pre-Award and Post-Delivery Review Requirements

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This section provides examples of Buy America certification calculations, purchaser's requirements certification information, and sample FMVSS self-certification stickers.

Buy America Certification

Exhibit 4-1 presents a sample table to be prepared by a manufacturer for the Buy America certification process.

Component Manufacturer Origin Component
Cost
Bus
Cost
Subcomponent
1. Engine
Alternator
A Co. U.S.A. 3%

 

Starter
B Co. U.S.A 3

 

Fuel Injectors
D Co U.S.A. 6

 

Radiator
E Co. U.S.A. 4

 

Engine Block
C Co. U.S.A. 24

 

Cylinder Head
C Co. U.S.A. 20

 

Total (engine) C Co. U.S.A. 60% 12%
2. Transmission
Gear Box
C Co. U.S.A 26%

 

Clutch
F Co. U.S.A. 14

 

Housing
C Co. U.S.A. 28

 

Total (transmission) C Co. U.S.A 68% 5
3. Lift
Control Unit
G Co. U.S.A. 30%

 

Floor, Rails, & Barriers
H Co. U.S.A. 32

 

Total (lift) H Co. U.S.A. 62% 10
4. Passenger Seats I Co. U.S.A.

 

9
5. Interior & Exterior Body Panels J Co. U.S.A.

 

3
6. Air-Conditioning K Co. U.S.A.

 

5
7. Farebox L Co. U.S.A.

 

1
8. Doors M Co. U.S.A.

 

1
9. Windows N Co. U.S.A.

 

3
10. Front Axle O Co. U.S.A.

 

2
11. Rear Axle O Co. U.S.A.

 

4
12. Destination Sign P Co. U.S.A.

 

2
13. Electrical Harness Q Co.

 

 

3
Total (bus)

 

 

 

60%

Exhibit 4-1. Sample Manufacturer’s Buy America Calculation

If a component is manufactured in the United States with less than 60 percent domestic subcomponents, then only its domestic cost (i.e., the cost of its domestic subcomponents plus the cost of manufacturing the component) may be used in the domestic content calculation of the bus.

Domestic subcomponents exported for inclusion in a foreign-manufactured component may also be included in the Buy America calculation, if the domestic subcomponents received a tariff exemption for importation back into the United States. However, only the cost of the domestic subcomponents, which is the cost at the time of export, may be used in the domestic content calculation of the bus.

The presentation of the costs for both of the above cases is different from that shown in Exhibit 4-1. Exhibit 4-2 presents the Buy America presentation for the cost of a transmission with at least 60 percent domestic subcomponents as was shown in Exhibit 4-1.

Component Manufacturer Origin Component
Cost
Bus
Cost
Subcomponent
2. Transmission
Gear Box
C Co. U.S.A 26%

 

Clutch
F Co. U.S.A. 14

 

Housing
C Co. U.S.A. 28

 

Total (transmission)
C Co. U.S.A 68%

5%

Exhibit 4-2. Sample Content Calculation for a U.S.-Manufactured Component With at Least
60 Percent Domestic Subcomponents

The 5 percent "Total (transmission)" figure in Exhibit 4-2 indicates that the transmission cost equals 5 percent of the cost of all components used in the bus. In this case, the transmission cost includes direct labor costs, direct materials costs, freight-in costs, sales costs, general and administrative costs, and an allowance for profit attributable to manufacturing the transmission.

For example, if the total cost of all bus components is $100,000, then, according to Exhibit 4-2, the cost of the transmission is $5,000. Of that $5,000, if $4,000 were the total cost of all subcomponents, then $1,000 would be the cost of manufacturing. The cost of the gear box, clutch, and housing is $1,040, $560, and $1,120, respectively.

Exhibit 4-3 presents a Buy America calculation for a transmission manufactured in the United States with less than 60 percent domestic subcomponents.

Component Manufacturer Origin Component
Cost
Bus
Cost
Subcomponent
2. Transmission
Gear Box
C Co. U.S.A 26%

 

Clutch
F Co. U.S.A. 14

 

Total (transmission) C Co. U.S.A 40%

2.6%

Exhibit 4-3. Sample Content Calculation for a U.S.-Manufactured Component With Less Than
60 Percent Domestic Subcomponents

In Exhibit 4-3, the 2.6 percent "Total (transmission)" figure means that the cost of the domestic subcomponents (or 40 percent of the total transmission subcomponent cost) plus the cost of manufacturing the transmission equals 2.6 percent of the cost of all components used in the bus. In this case, the cost of the transmission includes direct labor costs, domestic direct materials costs (or the domestic subcomponent costs), freight-in costs, an allowance for profit, and the sales, general and administrative costs attributable to manufacturing the transmission.

Using the earlier example, the 40 percent implies that the domestic subcomponents cost $1,600. Since the $1,000 manufacturing cost is allowed, the total is $2,600, or 2.6 percent of $100,000.

Exhibit 4-4 provides an example of a transmission from a foreign source with domestic subcomponents that received tariff exemptions.

Component Manufacturer Origin Component
Cost
Bus
Cost
Subcomponent
2. Transmission
Gear Box
C Co. U.S.A 26%

 

Clutch
F Co. U.S.A. 14

 

Total (transmission) C Co. Foreign Country 40%

1.6%

Exhibit 4-4. Sample Content Calculation for a Foreign-Manufactured Component With Domestic Subcomponents

In Exhibit 4-4, the 1.6 percent "Total (transmission)" figure means that the cost of the domestic subcomponents (domestic direct materials cost) used in the transmission is 1.6 percent of the cost of all components used in the bus.

Continuing with the previous example, the 1.6 percent indicates that the domestic components contribute $1,600 toward the cost of the bus. Recall that the total cost of the subcomponents equals $4,000. Note, however, that the $1,000 manufacturing cost is not allowed for foreign components as is allowed in both previous examples.

A component’s manufacturing cost is never used when calculating the domestic content of that component; its domestic content is based on subcomponent cost only. However, the component’s manufacturing cost should be used in the domestic content calculation of the bus, if the component was manufactured in the United States. Notice in the examples that the $1,000 manufacturing cost never contributes toward the domestic content of the component, but it does contribute toward the domestic content of the bus in Exhibits 4-2 and 4-3.

Purchaser’s Requirements Certification

The recipient should keep the following information in the certification file to support the purchaser’s requirements certification review:

  • A comparison of solicitation and bid specifications
  • An analysis of manufacturing capability
  • Copies of the visual inspection sheets
  • Copies of the road test sheets
  • A copy of the resident inspector's report describing manufacturing activities (if required)
  • Records of quality control measurements.

Comparison of Solicitation and Bid Specifications

The recipient should keep on file copies of the solicitation specifications, the manufacturer’s specifications, and the recipient’s agreement to any deviations from the solicitation technical specifications as proposed by the manufacturer.

Analysis of Manufacturing Capability

The recipient should keep on file an analysis of a prospective manufacturer’s information used to verify that the manufacturer is capable of building the bus to the specifications. This analysis may include statements, letters, and other information from the manufacturer describing the product, manufacturing and final assembly operations, and quality assurance program.

Visual Inspection Sheets

The visual inspection sheets should include a line for each item in the specification that can be verified and signed off. Appendix D contains a sample visual inspection sheet.

Road Test Sheets

Road test sheets should include all information cited in the contract that fairly represents the handling and operation of the bus(es). It might include items such as top speed, gradeability, fuel economy, noise, accessibility, maintainability, handling, and operation of all accessories. Appendix D contains a sample road test sheet.

Manufacturing Activities

The resident inspector’s report must include a description of final assembly and manufacturing operations, including a description of machine and hand operations—such as welding, painting, and drilling.

Records of Quality Control Measurements

Typical records of quality control should include information of actual and specified dimensions, clearances, and machining and assembly tolerances. In addition, the operational characteristics of all accessories should be included with this information.

FMVSS Certification

Vehicle labels must be permanently affixed in such a manner that they cannot be removed without being destroyed or defaced. The color of the lettering shall be such that it stands out from the background of the label. The lettering shall be in block capitals not less than 3/32 of an inch high.

Buses subject to FMVSS must have a FMVSS sticker affixed to the bus. Exhibits 4-6 through 4-10 present samples of various FMVSS stickers.

MANUFACTURED BY (NAME).

NAME
DATE: (MONTH/YEAR) GVWR:(WEIGHT) LB
FRONT GAWR: (WEIGHT) LB
WITH (
SIZE) TIRES,
(
SIZE/TYPE) RIMS,
AT PSI COLD (
SINGLE/DUAL)
REAR GAWR:(WEIGHT) LB
WITH (
SIZE) TIRES,
(
SIZE/TYPE) RIMS,
AT PSI COLD (
SINGLE/DUAL)
THIS VEHICLE CONFORMS TO ALL APPLICABLE U.S. FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE.

VIN: (VEHICLE IDENTIFICATION NUMBER)

TYPE: (VEHICLE TYPE)

 

VEHICLE IDENTIFICATION NUMBERVEHICLE TYPE

Exhibit 4-6. Sample Completed Vehicle FMVSS Sticker

 

THIS VEHICLE WAS ALTERED BY (NAME) IN (MONTH/YEAR) AND AS ALTERED, IT CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS AFFECTED BY THE ALTERATION AND IN EFFECT IN (MONTH/YEAR)

GVWR:(WEIGHT) LB

WEIGHT
FRONT GAWR: (WEIGHT) LB
WITH (
SIZE) TIRES,
(
SIZE/TYPE) RIMS,
AT PSI COLD (
SINGLE/DUAL)
REAR GAWR:(WEIGHT) LB
WITH (
SIZE) TIRES,
(
SIZE/TYPE) RIMS,
AT PSI COLD (
SINGLE/DUAL)
TYPE: (VEHICLE TYPE)

Exhibit 4-7. Sample Altered Vehicle Manufacturer’s
FMVSS Sticker

 

THIS CHASSIS-CAB CONFORMS TO FEDERAL MOTOR VEHICLE SAFETY STANDARD NOS. (APPLICABLE FMVSS NUMBERS). THIS VEHICLE WILL CONFORM TO STANDARD NOS. (APPLICABLE FMVSS NUMBERS) IF IT IS COMPLETED IN ACCORDANCE WITH THE INSTRUCTIONS CONTAINED IN THE INCOMPLETE VEHICLE DOCUMENT FURNISHED PURSUANT TO 49 CFR PART 568. CONFORMITY TO THE OTHER SAFETY STANDARDS APPLICABLE TO THIS VEHICLE WHEN COMPLETED IS NOT SUBSTANTIALLY AFFECTED BY THE DESIGN OF THE CHASSIS-CAB.

CHASSIS-CAB MANUFACTURED BY (NAME). (MONTH/YEAR)

(NAME). (MONTH/YEAR)

Exhibit 4-8. Sample Incomplete Vehicle Manufacturer’s
FMVSS Sticker

 

WITH RESPECT TO STANDARD NOS. (APPLICABLE FMVSS NUMBERS), THE INSTRUCTIONS OF PRIOR MANUFACTURERS HAVE BEEN FOLLOWED SO THAT THE CHASSIS-CAB NOW CONFORMS TO THESE STANDARDS. THIS CHASSIS-CAB CONFORMS TO FEDERAL MOTOR VEHICLE SAFETY STANDARD NOS. (APPLICABLE FMVSS NUMBERS). WILL CONFORM TO STANDARD NOS. (APPLICABLE FMVSS NUMBERS) IF IT IS COMPLETED IN ACCORDANCE WITH THE INSTRUCTIONS CONTAINED IN THE AMENDED INCOMPLETE VEHICLE DOCUMENT FURNISHED PURSUANT TO 49 CFR PART 568. CONFORMITY TO STANDARD NOS. (APPLICABLE FMVSS NUMBERS) IS NO LONGER SUBSTANTIALLY AFFECTED BY THE DESIGN OF THIS CHASSIS-CAB.

INTERMEDIATE MANUFACTURE BY (NAME). (MONTH/YEAR)

Exhibit 4-9. Sample Intermediate Vehicle Manufacturer’s
FMVSS Sticker

 

MANUFACTURED BY (NAME).

DATE: (MONTH/YEAR)

 

(NAME)(MONTH/YEAR)

INCOMPLETE VEHICLE MANUFACTURED BY (NAME).

DATE: (MONTH/YEAR)

 

(NAME)(MONTH/YEAR)

GVWR:(WEIGHT) LB

WEIGHT
FRONT GAWR: (WEIGHT) LB
WITH (
SIZE) TIRES,
(
SIZE/TYPE) RIMS,
AT PSI COLD (
SINGLE/DUAL)
REAR GAWR:(WEIGHT) LB
WITH (
SIZE) TIRES,
(
SIZE/TYPE) RIMS,
AT PSI COLD (
SINGLE/DUAL)
CONFORMITY OF THE CHASSIS-CAB TO FEDERAL MOTOR VEHICLE SAFETY STANDARDS, WHICH HAVE BEEN PREVIOUSLY FULLY CERTIFIED BY THE INCOMPLETE VEHICLE MANUFACTURER OR INTERMEDIATE VEHICLE MANUFACTURER, HAS NOT BEEN AFFECTED BY FINAL-STAGE MANUFACTURE, THE VEHICLE HAS BEEN COMPLETED IN ACCORDANCE WITH THE PRIOR MANUFACTURER’S INSTRUCTIONS, WHERE APPLICABLE. THIS VEHICLE CONFORMS TO ALL OTHER APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT IN (MONTH/YEAR).

VIN: (VEHICLE IDENTIFICATION NUMBER)

TYPE: (VEHICLE TYPE)

VEHICLE TYPE

or

CONFORMITY OF THE CHASSIS-CAB TO FEDERAL MOTOR VEHICLE SAFETY STANDARD NOS. (APPLICABLE FMVSS NUMBERS) HAS NOT BEEN AFFECTED BY FINAL-STAGE MANUFACTURE. WITH RESPECT TO THE STANDARD NOS. (APPLICABLE FMVSS NUMBERS), THE VEHICLE HAS BEEN COMPLETED IN ACCORDANCE WITH THE PRIOR MANUFACTURER’S INSTRUCTIONS. THIS VEHICLE CONFORMS TO ALL OTHER APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT IN (MONTH/YEAR).

VIN: (VEHICLE IDENTIFICATION NUMBER)

TYPE: (VEHICLE TYPE)

VEHICLE TYPE

or

THIS VEHICLE CONFORMS TO ALL OTHER APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT IN (MONTH/YEAR).

VIN: (VEHICLE IDENTIFICATION NUMBER)

TYPE: (VEHICLE TYPE)

VEHICLE TYPE

Exhibit 4-10. Samples of Final-Stage Vehicle Manufacturer’s
FMVSS Stickers