Recall reimbursement: getting paid back for a repair you already made

The rule in one paragraph

Every manufacturer that files a safety recall has to include a plan for reimbursing owners who already paid to fix the problem. The law is 49 U.S.C. 30120(d), and the details are in NHTSA's regulation at 49 CFR 573.13. If your repair falls inside the window the rule sets and you have the paperwork, the manufacturer has to act on your claim within 60 days.

The window

The regulation fixes both ends of the eligibility period.

When it opens. It opens one year before the manufacturer reported the defect to NHTSA. If NHTSA had opened an engineering analysis into the problem, the window opens on the date the EA opened instead, whenever that's earlier.

When it closes. For vehicles, it closes 10 calendar days after the manufacturer mails the last of its owner notification letters. For replacement equipment such as tires or child seats, it closes 10 days after the last letter or 30 days after the manufacturer finishes its public notice efforts, whichever is later.

The engineering analysis rule can open the window years early. Here are the latest investigations on this site's vehicles where an EA was followed by a recall that NHTSA's file links to it:

On EA19-005, for example, the engineering analysis opened more than two years before the recall was filed. An owner who paid for that repair in 2020 would fall inside the window, though a rule that starts one year before the recall wouldn't reach back that far. Our guide to NHTSA investigation stages explains what an EA is.

The age limit

The rule doesn't cover everyone. Under 573.13, the reimbursement requirement doesn't apply to a vehicle first sold more than 10 calendar years before the recall notice, or to a tire first sold more than five years before. That's shorter than the 15-year limit on the free recall repair itself, so an older car can qualify for the free fix but not for a refund of an earlier repair.

What you have to send

The manufacturer's plan can require documentation, but 573.13 caps it. At most, you can be asked for:

• your name and mailing address
• the vehicle's make, model, model year and VIN
• the recall number (NHTSA's or the manufacturer's)
• who owned the car when the repair was done
• a receipt, original or copy
• if the repair happened while a warranty would have covered it, proof that the dealer refused the warranty repair or that the warranty repair didn't fix the problem

For a repair, the receipt may need to show that the work addressed the recalled defect (or a symptom of it) and the total paid. The manufacturer can't demand an itemized breakdown of parts, labor and tax unless it's unclear from the receipt that the repair was only for the recalled problem.

A shop invoice with the VIN, the date, the mileage, a clear description of the fault and the total covers most of what the rule lets a manufacturer ask for about the repair itself. That's one more reason to ask for a proper repair order every time, which the Federal Trade Commission also recommends.

What a manufacturer can refuse

The regulation lists the only conditions a plan may use to exclude a claim. For vehicles, a plan may refuse to pay:

• for costs that the original or an extended manufacturer warranty would have covered for free, unless a franchised dealer denied the warranty claim or the warranty repair didn't fix the problem (and the extended-warranty exclusion only applies if owners were told the terms in writing)
• if what you got wasn't the same type of remedy as the recall, measured as repair, replacement or refund
• if the repair didn't address the defect or a manifestation of it
• if it wasn't reasonably necessary to correct the defect
• if you didn't send adequate documentation

It can't insist that your repair was identical to the manufacturer's fix. If the recall replaces a part and your shop replaced the same failed part with a different brand, that alone isn't grounds to refuse.

How much you get back

The plan has to state the amount. For a vehicle, reimbursement can't be less than the smaller of two figures: what you actually paid, or the cost of the parts plus labor at local rates, fees and taxes (the parts can be priced at the manufacturer's list price). Taxes and fees such as waste disposal can't be capped. For replacement equipment the reimbursement ordinarily matches what you paid for the replacement item. If you bought a different brand or model of equipment, the manufacturer can cap it at the retail list price of the recalled item plus tax.

How to claim

1. Check the recall letter. Under 49 CFR 577.11, the owner notice must say you may be eligible for reimbursement and tell you how to get the details, either in an enclosure or through a toll-free number.
2. Get the plan's terms. The manufacturer must make its reimbursement plan available to the public on request, including the address for claims and any dealers that accept them.
3. Send the documents listed above. Keep copies.
4. Wait up to 60 days. The manufacturer must act on the claim within 60 days of receiving it. A denial has to come with a clear statement of the reasons. If the claim is incomplete, it has to tell you what's missing within 60 days and let you resubmit.

If you're denied

NHTSA won't referee. The regulation says disputes over eligibility or the amount are between you and the manufacturer, and NHTSA won't mediate them. Your options then are the manufacturer's customer relations process, your state attorney general's consumer office, or small claims court, which the FTC points to for repair disputes generally.

One special case is covered in NHTSA's recall booklet. If a manufacturer is fighting a recall order in court and you pay for the repair meanwhile, you may be entitled to reimbursement if the court upholds NHTSA's decision. Keep every receipt.

Keep records before there's a recall

You can't claim a refund for a repair you can't document. If something fails that seems like it could be a safety defect, keep the invoice and file a complaint with NHTSA. Our complaint guide shows how. If a recall follows, you'll have what the plan asks for.