Automotive Repair Documentation and Authorization: A Comprehensive Guide for Dealers

Updated January 2025

Automotive repair dealers are legally obligated to adhere to the Automotive Repair Act and its associated regulations. This compliance includes strict requirements for documentation and obtaining proper authorization for all repair transactions. Key aspects of these requirements include:

• Keeping customers well-informed throughout the repair process.
• Providing clear and accurate estimates and invoices.
• Performing only the repairs explicitly authorized by the customer.
• Maintaining meticulous records of all work performed and parts utilized.

This “Write It Right” guide serves as a practical resource to help automotive repair dealers navigate these crucial requirements and more. It’s important to note that this guide is intended for quick reference and may not cover every detail. For in-depth information, please refer to the complete Laws and regulations.

(Note: BPC refers to Business and Professions Code. HSC refers to Health and Safety Code. CCR refers to California Code of Regulations.)

Estimate Requirements

An estimate, whether in paper or electronic form, is a crucial document that details the anticipated costs for parts and labor for a specific repair job. (BPC § 9884.9, CCR § 3352(a))

Unless otherwise specified, all references to “estimate” pertain to a ‘standard’ estimate.

Alt text: Sample automotive repair estimate document illustrating required sections and information for customer transparency.

When is an Estimate Necessary?

Providing an estimate is mandatory for an automotive repair dealer before commencing any repairs on a motor vehicle. (BPC § 9884.9)

When is an Estimate Not Necessary?

An estimate is not required for preventative maintenance services as defined in BPC § 9880.1(j) if the customer authorizes the service and one of the following conditions is met:

1. The preventative maintenance service is provided free of charge. (BPC § 9884.9(e)(1))
2. The complete price for parts and labor for the service is clearly displayed or communicated to and acknowledged by the customer. (BPC § 9884.9(e)(2))

If a repair job includes both standard repairs and preventative maintenance, an estimate is still required for the repair portion. While not mandatory, it is highly recommended to include preventative maintenance services on the estimate for clarity. (BPC § 9884.9, CCR § 3353(a))

Essential Components of an Estimate

A comprehensive estimate must include a clear description of the specific repair job and the estimated price for all necessary parts and labor. Each part listed must be identified as new unless explicitly stated as used, rebuilt, or reconditioned. (BPC § 9884.9, CCR § 3353(a))

Sales Tax in Estimates

Sales tax should not be included in the estimate. It is only incorporated into the final invoice. (BPC § 9884.8, CCR § 3356(c)(5))

Inclusion of Toxic Waste Disposal Costs

Yes, any fees associated with the handling, management, and disposal of toxic or hazardous waste directly related to the repair must be clearly itemized as separate line items on both the estimate and the invoice. If a disposal fee is charged, both documents must also include the automotive repair dealer’s Environmental Protection Agency (EPA) identification number. (BPC §§ 9884.8, 9884.9(a), CCR § 3357)

Labor Rate Disclosure in Estimates

The labor rate is not required to be explicitly stated on either the estimate or the invoice. However, vehicle safety systems inspection stations are required to conspicuously post their inspection prices. Similarly, Smog Check stations must prominently display a price list for their services and their hourly labor rate for repairs. (CCR §§ 3312.2(d), 3340.15(d))

Shop Supplies and Miscellaneous Charges

Charging customers for generic “shop supplies” or “miscellaneous parts” is not permitted. Customers can only be charged for supplies directly used on their vehicle. These supplies must be included in the estimate and itemized on the invoice. (BPC § 9884.9, CCR § 3356(g))

Return of Replaced Parts

If a customer requests the return of replaced parts at the time of estimate authorization, this must be accommodated and therefore included in the estimate information. (BPC § 9884.10, CCR §§ 3355, 3356(i))

Core Charges on Parts

If a customer requests a replaced core part (like a battery) sold on an exchange basis, the core charge can be included in the estimate. Core charges do not apply to parts replaced under warranty, as these must be returned to the manufacturer. (BPC § 9884.10, CCR §§ 3355, 3356(i))

Sublet Repairs and Responsibilities

Sublet repairs are permissible with customer consent. The estimate must disclose any sublet repairs to be performed. The automotive repair dealer remains responsible for all sublet repairs as if they were performed in-house. Upon customer request, the dealer must disclose the name and location of the sublet repair facility. (BPC §§ 9884.7(a)(9), 9884.9(b), CCR § 3353(d))

Subletting Smog Check Services

Smog Check inspections cannot be sublet. (CCR § 3340.15(h)) However, Smog Check stations performing repairs can sublet specific services:

• Exhaust Systems: Repairs typically handled by muffler shops, provided the malfunction was initially diagnosed by the authorizing Smog Check station. (CCR § 3340.15(h)(1))
• Defective Components: Repair of components already diagnosed as defective and removed by the initially authorized Smog Check station. (CCR § 3340.15(h)(2))
• Diesel Vehicles: Repairs on diesel-powered vehicles, requiring customer authorization to sublet. (CCR § 3340.15(h)(3))
• Transmissions: Transmission repairs, also requiring customer authorization to sublet. (CCR § 3340.15(h)(4))
• On-board Computer System Software: Corrections to vehicle software, provided the issue was diagnosed by the Smog Check station initially authorized by the customer. This may include scenarios where Additional Vehicle Specific On-car Programming Must Be Performed, requiring specialized expertise or equipment that the original station may not possess. (CCR § 3340.15(h)(5))

Specialized Estimates

Tear Down Estimates

A tear down estimate is required before disassembling a vehicle or component for diagnostic purposes. (BPC § 9884.9, CCR § 3353(c))

Requirements for Tear Down Estimates

Tear down estimates must include the same information as standard estimates, plus: (BPC § 9884.9, CCR § 3353)

• The cost to reassemble the vehicle or component. (CCR § 3353(c)(1)(A))
• The cost of parts and labor to replace items typically destroyed during tear down, such as gaskets and seals. (CCR § 3353(c)(1)(B))
• A notification if the tear down process might prevent restoring the vehicle or component to its original condition. (CCR § 3353(c)(1)(C))

The timeframe for these estimates is counted from the date of tear down authorization. (CCR § 3353(c)(1)(D))

Second Estimate After Tear Down

Yes, after a tear down, a second estimate is mandatory. The tear down process isn’t complete until the customer receives an itemized estimate for the parts and labor needed for repair. Customer authorization is needed for either repair or reassembly before proceeding or incurring further charges. (BPC § 9884.9, CCR § 3353(c)(2))

If the customer declines repair or reassembly after tear down, this must be documented on the tear down invoice. (CCR §§ 3353(c)(3), 3356(h))

Smog Check Estimate Requirements

Smog Check estimates must include the standard estimate information, as well as: (BPC § 9884.9, CCR § 3353)

• A notice informing the customer of their right to choose a different Smog Check station for repairs, installations, adjustments, or subsequent tests. (HSC § 44033(c))
• Disclosure, both verbally and in writing, if the station may not be equipped to repair the vehicle, has policies against repairing certain vehicle types, or certain types of inspection failures. (CCR § 3340.16.5(b)(1-3))

Auto Body or Collision Repair Estimates

Auto body or collision repair estimates must be itemized and contain the same information as a standard estimate.

Furthermore, new replacement crash parts must be OEM unless explicitly identified as non-OEM aftermarket or used parts. Vague descriptors are not acceptable. (BPC §§ 9884.8, 9884.9, CCR § 3353)

Alt text: Example of an auto body repair estimate, highlighting the detailed breakdown required for collision damage assessment and repair costs.

Insurance company estimates can be attached to and referenced in the automotive repair dealer’s estimate if they meet all regulatory requirements.

Automatic Transmission Estimates

Automatic transmission estimates must adhere to standard estimate requirements and include a notification if a diagnostic check of the electronic control module is not possible due to the transmission’s condition. (BPC § 9884.9, CCR §§ 3353, 3361.1(a))

Specific terminology related to automatic transmissions (exchanged, rebuilt, etc.) is permitted in estimates and invoices only if specific work standards outlined in CCR § 3361.1(c) are met.

Windshield Installation Estimates

Windshield installation estimates must include standard information and specify whether the windshield is OEM or non-OEM. They must also inform the customer about the vehicle inoperability period following installation. (BPC § 9884.9, CCR §§ 3353, 3365.1(c)(3))

Automotive Air Conditioning Estimates

Automotive air conditioning estimates must follow standard estimate guidelines. (BPC § 9884.9, CCR § 3353)

Terms used for air conditioning work (service, inspection, etc.) in estimates and invoices must correspond to procedures defined in CCR § 3366 as accepted industry standards.

Authorization Procedures

Authorization is the customer’s consent for a specific repair job, given either:

1. By written signature on the estimate. (CCR § 3352(e)(1))
2. Orally or electronically, documented on the estimate. (CCR § 3352(e)(2))

Obtaining Customer Authorization

All repairs must be authorized by the customer in written, oral, or electronic form before any work begins. A copy of any signed document must be provided to the customer at the time of signing. (BPC § 9884.7(a)(3), CCR § 3353.1(a))

• Written Authorization: Requires the customer’s signature and date. (CCR § 3353.1(b))
• Oral Authorization: Requires recording the date, time, authorizing person’s name, and phone number called (if applicable). (CCR § 3353.1(c))
• Electronic Authorization: Requires recording the date, time, authorizing person’s name, and email or phone number (for text messaging). (CCR § 3353.1(d))

Supporting documents for authorization, like email or text exchanges, must be uniquely identified and kept as part of the transaction record. (CCR § 3353.1(e))

Work Order Requirements

A work order must contain the authorized estimate, the repairs requested and authorized, and the vehicle’s odometer reading. (BPC § 9884.7(a)(2), CCR § 3352(b))

Alt text: Example of a work order form, illustrating sections for repair details, customer authorization, and vehicle information like odometer reading.

Mobile automotive repair dealers must provide a copy of their dealer sign (as per CCR §§ 3351.3 and 3351.4) when providing a work order copy. (CCR §§ 3351.3, 3351.7.3(e))

Modifying Work Orders

Changes to repair methods or parts listed in the work order are allowed only with prior customer authorization. (CCR § 3354(b))

Authorization in Unusual Circumstances

Unusual circumstances occur when the customer cannot deliver the vehicle during normal business hours or is not present upon vehicle delivery (e.g., drop-off after hours, towed vehicle). (BPC § 9884.9, CCR § 3353.2)

For towing and storage services operated by the repair dealer, separate itemized invoices are required, and towing authorization must be documented separately from repair estimates. (Vehicle Code section 22651.07, Civil Code Division 3, Part 4, Title 14, Chapter 6.5)

Authorizing Repairs in Unusual Circumstances

To authorize repairs under unusual circumstances:

1. Prepare an estimate. (CCR § 3353.2(a))
2. Contact the customer by phone, email, text, or electronically to convey estimate information and obtain authorization. (CCR § 3353.2(b))
3. Document the authorization on both the estimate and invoice. (CCR § 3353.2(c))

Authorization is required before any repairs, even for vehicles dropped off with notes requesting repairs. A note alone does not constitute authorization.

Additional Authorization for Unforeseen Repairs

Procedure for Additional Authorization

Before proceeding with repairs beyond the original estimate or incurring additional charges: (BPC § 9884.9, CCR §§ 3353.1, 3354(a))

1. Prepare a revised work order detailing additional parts and labor, their costs, and the new total revised cost.
2. Contact the customer by phone, email, text, or electronically with the revised work order information and obtain authorization.
3. Document the additional authorization on both the work order and invoice.

Alt text: Example of text message authorization for additional car repairs, demonstrating electronic consent documentation.

Designating Another Person for Authorization

Customers can designate another person to authorize additional repairs at the time of initial authorization. This designee cannot be the repair dealer, their employee, agent, insurer, or anyone acting on their behalf. (BPC § 9884.9(d), CCR § 3354(c)(2))

Documenting Designee Authorization

Document the following on the work order or a separate form:

• Title: “DESIGNATION OF PERSON TO AUTHORIZE ADDITIONAL DIAGNOSIS, REPAIR, OR PARTS” (CCR § 3354(c)(1)(A))
• Statement: “I hereby designate the individual named below to authorize any additional work not specified or parts not included in the original estimate for parts and labor.” (CCR § 3354(c)(1)(B))
• Designee’s Name (CCR § 3354(c)(1)(C))
• Designee’s Contact Information (CCR § 3354(c)(1)(D))
• Customer’s Signature (CCR § 3354(c)(1)(E))
• Date of Signing (CCR § 3354(c)(1)(F))
• Work Order Number (CCR § 3354(c)(1)(G))

Invoice Requirements

An invoice, paper or electronic, is provided to the customer upon repair completion, detailing the final costs for parts and labor. (BPC § 9884.8, CCR § 3352(c))

Unless stated otherwise, “invoice” refers to a ‘standard’ invoice.

Alt text: Sample automotive repair invoice, showcasing the required itemization of services, parts, costs, and dealer information for billing transparency.

When to Provide an Invoice

The invoice is provided upon completion of all repairs, including preventative maintenance. (BPC § 9884.8, CCR § 3356)

Essential Invoice Components

An invoice must include:

• Automotive Repair Dealer Information: Registration number, business name, and address as per BAR records. (CCR § 3356(b))
• Parts and Labor:
  • Itemized list of all services and repairs, including diagnosis, warranty work, and no-charge repairs. (BPC § 9884.8, CCR § 3356(c)(1))
  • Itemized list of each part, described in common terms, indicating if new, used, reconditioned, rebuilt, and OEM/non-OEM for crash parts. Part kits can be listed as single items with brand and part number. (BPC § 9884.8, CCR § 3356(c)(2))
  • Notation of replaced parts not returned to the customer, if applicable. (CCR §§ 3355(c)(1)(B), 3356(i))
• Prices/Costs:
  • Subtotal for all service and repair work. (BPC § 9884.8, CCR § 3356(c)(3))
  • Subtotal for all parts (excluding sales tax). (BPC § 9884.8, CCR § 3356(c)(4))
  • Sales tax, if applicable. (BPC § 9884.8, CCR § 3356(c)(5))
  • Toxic waste fee (if any, as per estimate) and EPA number. (CCR § 3357)
  • Total cost for services, parts, and sales tax. (BPC § 9884.8, CCR § 3356(c)(6))
  • Prohibited separate billing for shop supplies, miscellaneous parts, electronic communication fees, etc. (CCR § 3356(g))
• Authorization Documentation:
  • Customer declination of repair/reassembly after tear down (if applicable). (CCR §§ 3353(c)(3), 3356(h))
  • For unusual circumstances authorization, include date/time of estimate authorization, authorizing person’s name, and contact information used. (BPC § 9884.8, CCR § 3356(d))
  • For additional authorization (oral or electronic), include date/time, authorizing person’s name, contact information, description and cost of additional parts/labor, and total price. (BPC § 9884.8, CCR § 3356(e))
  • Alternatively to detailed additional oral authorization on the invoice, use a signed “Acknowledgement of Notice and Consent” form with specific language, documenting revisions on the work order. (BPC § 9884.9(a)(2), CCR § 3356(e)(2))

Invoices for No-Charge or Warranty Repairs

Yes, invoices are required for all repairs, including no-charge, warranty, and insurance-paid repairs, detailing all parts and labor. (BPC § 9884.8, CCR § 3356)

Returning Replaced Parts to Customer

Replaced parts must be returned if requested at estimate authorization, except for core parts or warranty-return parts. Customers must be offered inspection of non-returned parts. Non-returned parts must be noted on the invoice. (BPC § 9884.10, CCR §§ 3355, 3356(i))

Core Charges on Invoices

Core charges can be included on invoices for exchange-basis parts like batteries. Warranty-replaced parts returned to the manufacturer are excluded from core charges. (BPC § 9884.10, CCR §§ 3355, 3356(i))

Use of Industry Acronyms

Avoid industry acronyms when describing parts and labor in estimates and invoices. Use clear, understandable language for customers. (BPC §§ 9884.8, 9884.9, CCR §§ 3353, 3356)

Multiple Registration Numbers for Mobile Businesses

Mobile repair businesses with multiple registrations only need to include the registration number associated with the specific vehicle repair job on the invoice. (CCR § 3356(b))

Lien Sales for Non-Payment

Lien sales are permissible for unpaid authorized repair costs, provided all invoice requirements are met as per Civil Code section 3068(a). (BPC § 9884.16, Civil Code Division 3, Part 4, Title 14, Chapter 6.5, www.dmv.ca.gov)

Specialized Invoices

Smog Check Invoices

Smog Check invoices must meet standard invoice requirements and include a copy of the Vehicle Inspection Report. (BPC § 9884.8, CCR §§ 3340.41(a), 3356)

Automatic Transmission Invoices

Automatic transmission invoices adhere to standard invoice requirements. (BPC § 9884.8, CCR § 3356)

Using specific terms for automatic transmissions in invoices is allowed only if work standards in CCR § 3361.1(c) are met.

Windshield Installation Invoices

Windshield installation invoices must include standard information, cure time, installation date/time, and OEM/non-OEM part designation. (BPC § 9884.8, CCR §§ 3356, 3365.1(c)(4))

Automotive Air Conditioning Invoices

Air conditioning invoices must follow standard invoice guidelines and include system operating pressures and center air outlet temperature. (BPC § 9884.8, CCR §§ 3356, 3366(a)(15), 3366(a)(16))

Terms used for air conditioning work in invoices must align with industry standards in CCR § 3366.

Maintenance of Records

Required Records for Automotive Repair Dealers

Dealers must maintain records in written or electronic form:

• All invoices (BPC § 9884.11, CCR § 3358(a))
• All estimates, including authorization records (emails, texts) (BPC § 9884.11, CCR § 3358(b))
• All work orders, including additional authorization records (BPC § 9884.11, CCR § 3358(c))

Scan signed documents if storing records electronically.

Record Retention Period

Records must be kept for at least three years and accessible for BAR inspection during business hours. (BPC § 9884.11, CCR §§ 3340.15(e), 3358(d))

Unique Record Identifiers

All transaction-related records must have a unique identifier linking them to the specific transaction. (CCR § 3358(e))

Business Conduct and Compliance

Registration can be denied, suspended, revoked, or probated for business conduct violations, including: (BPC §§ 490, 9884.7)

1. Misleading statements
2. Customer signing incomplete work orders
3. Failure to provide copies of signed documents
4. Fraud
5. Gross negligence
6. Non-compliance with Automotive Repair Act or regulations
7. Disregarding trade standards
8. False promises to obtain authorization
9. Subletting without customer consent (unless notification is unreasonable)
10. Conviction of Penal Code section 551 (fraud)
11. Conviction of crimes related to automotive repair qualifications

Definitions

• Automotive repair dealer (ARD): Business repairing/diagnosing vehicle malfunctions for compensation, or collecting compensation for referred/sublet repairs. (BPC § 9880.1(a))
• Repair of motor vehicles: All vehicle maintenance and repairs by ARDs, excluding commercial agreements and roadside services. (BPC § 9880.1(k))
• Preventative maintenance services: Oil changes, tire rotation, and services in BPC § 9880.1(j).
• Customer: Person presenting vehicle for repair and authorizing repairs. (BPC § 9880.1(f))
• Crash part: Non-mechanical exterior sheet metal or plastic parts. (CCR § 3303(o))
• Original equipment manufacturer (OEM) crash part: Crash part made by/for original vehicle manufacturer. (CCR § 3303(p))
• Non-original equipment manufacturer (non-OEM) crash part: Aftermarket crash part not made by original vehicle manufacturer. (CCR § 3303(q))
• Estimate: Document with estimated price for parts and labor. (BPC § 9884.9, CCR § 3352(a))
• Tear down: Disassembling vehicle for estimate preparation. (CCR § 3352(d))
• Authorization: Customer consent for a specific job (written or documented oral/electronic). (CCR § 3352(e))
• Electronic: Technology with electrical, digital, magnetic, wireless, optical, electromagnetic capabilities. (CCR § 3352(f))
• Oral: Voice communication (in-person, phone, electronic). (CCR § 3352(g))
• Work order: Document with requested repairs, estimate, authorization, and odometer reading. (BPC § 9884.7(a)(2), CCR § 3352(b))
• Invoice: Document with final price for parts and labor upon repair completion. (BPC § 9884.8, CCR § 3352(c))

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