We support the agency's efforts to reduce regulation and rescind agency requirements that are outdated, outmoded, or otherwise not useful. CU believes however, that the existence of federal guidelines intended to prevent the passing off of used auto parts as new and providing guidelines for distinguishing between remanufactured auto parts and other used parts provide a basic and necessary protection for consumers. In the experience of Consumers Union, an industry whose members support the use of federal guidelines to maintain the quality and standards of the product is unusual. Yet in the case of the Guides for Rebuilt, Reconditioned and Other Used Automobile Parts Industry, it appears that members of the used auto parts industry believe these Guides have helped keep industry standards high, enabled the industry to police itself, and provided protections to consumers through labeling and disclosure on rebuilt, reconditioned and other used parts. CU supports the availability to consumers of high quality rebuilt, reconditioned and other used auto parts as an economical alternative to new parts.
Consumers enjoy significant savings through availability of such parts.
There are important environmental benefits, as well, to be derived from the use of rebuilt and reconditioned auto parts that come through savings in materials and energy required to manufacture a new part. We cannot explain the absence of consumer input during the agency's comment period on these Guides in April of this year, but we speculate that most consumers of auto parts believe that the government already protects them against fraudulent labeling of new and used parts without knowing specifically how. As in many areas of consumer protection regulations, most consumers likely have no knowledge that these Guides exist though they benefit from the protections they provide. Indeed, they depend on them day in and day out. If these Guides have had the effect of setting an industry standard, as the APRA and AERA claim, then the incidence of passing off used auto parts as new has been successfully curtailed, which translates into fewer consumer complaints.