The FTC Buyers Guide requirements come from the Used Motor Vehicle Trade Regulation Rule at 16 C.F.R. Part 455, and they obligate used car dealers to post a standardized window form on every covered vehicle offered for sale. The form states whether the car comes with a warranty or is sold without one, identifies the vehicle, and names a person to contact if something goes wrong after the sale. Dealers who ignore the rule face civil penalties of up to $53,088 per violation.1eCFR. 16 CFR 1.98 – Adjustment of Civil Monetary Penalty Amounts
Who the Rule Covers
The rule applies to anyone who sells, or offers to sell, a used vehicle after having sold or offered five or more used vehicles in the previous twelve months.2eCFR. 16 CFR 455.1 – General Duties of a Used Vehicle Dealer; Definitions Traditional car lots are the obvious target, but the threshold also captures smaller operators and side businesses that move enough inventory to cross the line. A private owner selling a personal vehicle is not covered.
Three sellers are carved out even when they hit the volume threshold. Banks and financial institutions selling repossessed cars directly are excluded, though a dealership operated by a bank as a separate business must still comply. A business selling a used vehicle to its own employee is excluded. And a leasing company selling a vehicle to the person who leased it, or to that person’s employee, is excluded.
Which Vehicles Need a Buyers Guide
A vehicle is “used” under the rule once it has been driven beyond what is necessary to move it on a lot or road-test it before delivery, regardless of whether it has ever been titled. Demonstrator cars and manufacturer program cars count.3Federal Trade Commission. Dealers Guide to the Used Car Rule
The vehicle also has to fall within all three size limits:2eCFR. 16 CFR 455.1 – General Duties of a Used Vehicle Dealer; Definitions
- Gross vehicle weight rating below 8,500 pounds
- Curb weight below 6,000 pounds
- Frontal area below 46 square feet
Heavy-duty trucks, large commercial vehicles, and most full-size vans sit outside those limits. Motorcycles are excluded regardless of size. Vehicles sold only for scrap or parts, where the title has been surrendered and a salvage certificate issued, are also outside the rule.
What the Guide Must Contain
The Buyers Guide is a printed form, at least 11 inches tall by 7¼ inches wide, black ink on white stock. Its wording, headings, and checkboxes have to match the FTC’s prescribed format exactly.4eCFR. 16 CFR 455.2 – Consumer Sales; Window Form The information falls into four buckets: warranty status, vehicle identification, service contract availability, and a post-sale complaint contact.
Warranty Status
This is the heart of the form. The dealer checks one of three boxes:
- As Is — No Dealer Warranty. The dealer pays for no repairs after the sale. Available only in states that permit as-is used car sales.
- Implied Warranties Only. The dealer makes no specific promise, but the buyer keeps whatever implied warranty rights state law gives them. Dealers in states that prohibit or limit as-is sales use this version.3Federal Trade Commission. Dealers Guide to the Used Car Rule
- Warranty. The dealer is providing an express warranty. The guide then has to specify whether it is full or limited, list each covered system individually, state the duration for each, and show the percentage of parts and labor the dealer will pay.
Shorthand like “drive train” or “power train” is not allowed; each covered system has to be named separately so the buyer can see what is actually included.
Other Warranties and Service Contracts
Separate boxes cover warranty protection that does not come from the dealer: an unexpired portion of the manufacturer’s original warranty, a manufacturer’s used vehicle warranty, or another used vehicle warranty that applies.4eCFR. 16 CFR 455.2 – Consumer Sales; Window Form If the dealer offers a service contract for an extra charge, that box is checked too. States that regulate service contracts as the business of insurance are an exception; in those states the service contract box does not need to be checked.
Vehicle and Contact Details
The guide has to identify the vehicle by make, model, model year, and VIN. A stock number space is optional. The dealer’s name and address appear on the form, along with the name and telephone number of a specific person the buyer should reach if problems come up after the sale.
Displaying the Guide
The Buyers Guide must be displayed prominently on or in each vehicle offered for sale, with both sides visible. Hanging it from a side mirror, tucking it under a wiper, or attaching it to a side window all work. A shopper should be able to read it without opening a door or asking anyone.3Federal Trade Commission. Dealers Guide to the Used Car Rule
At closing, the dealer must give the buyer the original guide or a copy reflecting all final terms. That copy is not a receipt. It carries legal weight and can override contrary language in the sales contract.
Required Sales Contract Language
Posting the guide is not the end of it. The sales contract must include this statement: “The information you see on the window form for this vehicle is part of this contract. Information on the window form overrides any contrary provisions in the contract of sale.”3Federal Trade Commission. Dealers Guide to the Used Car Rule This is the clause that gives the Buyers Guide real force. Fine print in the contract that contradicts the guide loses.
Spanish-Language Transactions
When a sale is negotiated primarily in Spanish, the dealer has to provide a Spanish-language Buyers Guide with the same content as the English form.5eCFR. 16 CFR 455.5 – Spanish Language Sales This reaches any dealership that negotiates predominantly in Spanish, including those employing Spanish-speaking salespeople or marketing to Spanish-speaking communities. A partial or rough translation does not meet the requirement.
Changes During Negotiations
If terms shift during the deal, the guide has to shift with them. A vehicle initially posted as-is that later gains a warranty needs the as-is box crossed out and the warranty section filled in. The same applies to changes in coverage percentages, covered systems, or duration. The final guide the buyer takes home controls. A verbal promise to fix a specific problem or replace a component needs to be written into the guide, or it will be very hard to enforce later.
State Law and the Federal Rule
The Used Car Rule is a federal floor. States can add requirements, and several restrict or prohibit as-is used vehicle sales, which is why the FTC issued the separate “Implied Warranties Only” version of the form. Dealers unsure which version applies in their state should check with their state attorney general’s office.
The rule also allows a state to obtain a full exemption by demonstrating that its own program provides equal or greater consumer protection. Wisconsin and Maine hold statewide exemptions, so the federal Buyers Guide requirements do not apply in those states as long as their state programs remain in effect.6eCFR. 16 CFR Part 455 – Used Motor Vehicle Trade Regulation Rule
Penalties and What a Buyer Can Do
The FTC enforces the rule through civil penalty actions, with a maximum of $53,088 per violation after the most recent inflation adjustment; a White House memorandum cancelled the 2026 scheduled increase, so that figure still stands.1eCFR. 16 CFR 1.98 – Adjustment of Civil Monetary Penalty Amounts Each vehicle sold without a proper Buyers Guide can count as a separate violation, so exposure builds quickly for a busy lot.
Part 455 does not give consumers a direct federal right to sue a dealer over a Buyers Guide violation. Enforcement runs through the FTC.6eCFR. 16 CFR Part 455 – Used Motor Vehicle Trade Regulation Rule Many states, however, have consumer protection or deceptive practices statutes that do allow private suits, and a missing or false Buyers Guide can serve as evidence of deceptive conduct under those laws. If a dealer failed to give you the required disclosures, file a complaint with the FTC and contact your state attorney general’s office, which may have its own enforcement authority.
The rule does not require dealers to keep copies of completed guides, and there is no federal retention mandate. Hold onto your copy. If a warranty dispute develops later, it is the single most useful document you will have.