Most dealers know they need a Buyers Guide on every used vehicle. Only some know that the sticker has to be visible on both sides, that a glove-compartment copy doesn't count, or that conducting a sale in Spanish triggers a separate posting requirement.
The rule is more specific than most people realize, and the penalties are not small. Here's what the FTC actually requires.
The short answer: if you sell or offer for sale more than five used vehicles in a 12-month period, you must display a completed Buyers Guide on every used vehicle before you show it to a customer. It must be in plain view with both sides visible, and the buyer must receive the original or a copy at the sale.
What is the FTC Buyers Guide?
The Buyers Guide is a window disclosure form required by the FTC's Used Car Rule, formally the Used Motor Vehicle Trade Regulation Rule (16 CFR Part 455), in effect since 1985 and revised in 2016.
It tells the buyer:
- The major mechanical and electrical systems on the vehicle, and common problems to watch for
- Whether the vehicle is sold "as is" or with a warranty
- What percentage of repair costs the dealer will cover under any warranty
- That oral promises are difficult to enforce, and to get everything in writing
- To have the vehicle inspected by an independent mechanic before buying
- To get a vehicle history report and check for safety recalls
- To ask for a Spanish Buyers Guide if the sale is conducted in Spanish
- To keep the Guide for reference after the sale
- It is a disclosure document, not a warranty. That distinction matters — more on it below.
Who has to comply?
Any dealer who sells or offers for sale more than five used vehicles in a 12-month period. That's the threshold. It captures nearly every franchise and independent lot in the country.
Exempt from the Rule:
- Banks and financial institutions
- Businesses selling vehicles to their own employees
- Lessors selling a leased vehicle to the lessee, an employee of the lessee, or a buyer the lessee found
Two states are exempt: Maine and Wisconsin, because both have their own comparable disclosure regulations. The Rule does apply in the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, and American Samoa.
Which vehicles need a Buyers Guide?
Any vehicle driven for purposes other than moving or test driving counts as used... whether or not it was previously titled. That includes light duty vans, light duty trucks, demonstrators, and program cars meeting all three of these:
- Gross vehicle weight rating (GVWR) under 8,500 pounds
- Curb weight under 6,000 pounds
- Frontal area under 46 square feet
Not covered: motorcycles, agricultural equipment, and vehicles sold for scrap or parts where the dealer submits title documents to the state and obtains a salvage certification.
A point dealers often miss: you must post the Guide before you display the vehicle for sale or let a customer inspect it, even if the car isn't fully prepped for delivery. Reconditioning is not an exemption. The requirement also covers vehicles on your lot through consignment or power of attorney.
For vehicles that genuinely aren't ready to sell, use a Not For Sale sticker ($22.90) or the Detailed Not For Sale version ($44.80) to make the status unambiguous to both customers and staff.
Where does the Buyers Guide have to be posted?
Prominently, in plain view, with both sides visible. That last part trips up a lot of lots.
Acceptable placements per the FTC:
- Hanging from the rear-view mirror inside the vehicle
- On a side-view mirror outside the vehicle
- Under a windshield wiper
- Attached to a side window
- Not acceptable: glove compartment, trunk, or under the seat. None of those are in plain sight.
You may remove the Guide for a test drive, but it has to go back as soon as the test drive ends.
Because both sides must be readable, the format you choose matters. Mirror Hanging Buyers Guide Forms ($35.90) are built for the rear-view mirror placement, and Buyers Guide Form Holders (from $44.10) keep window-mounted forms visible and protected. For lots that display forms outside the vehicle, Exterior Buyers Guide Forms ($74.30) are made to survive weather.
At public auctions, both the dealer and the auction company must comply. Auctions closed to consumers are not covered.
As Is vs. Implied Warranties Only: which version do you use?
The Buyers Guide comes in two versions, and picking the wrong one is a compliance problem.
"As Is — No Dealer Warranty." Use this version, and check the corresponding box, if your state permits as-is sales and you're offering no warranty at all — written or implied. Our Buyers Guide Form – As Is starts at $19.30.
"Implied Warranties Only." Use this version in states that limit or prohibit eliminating implied warranties, when you aren't offering a written warranty. Our Used Car Buyers Guide Form – Implied Warranty starts at $20.20.
Offering an express warranty? Check the "Warranty" box and complete that section on either version. Any warranty your state requires must be disclosed here.
An important caveat: in some states the "As Is" Buyers Guide alone is legally sufficient to eliminate implied warranties. In others, as-is sales require specific additional language or a separate document. Your state Attorney General's office can confirm which applies to you.
Filling out the Guide correctly
Vehicle information. Make, model, model year, and VIN at the top. A dealer stock number is optional.
Dealer information. On the back: your dealership name and address, plus the name or position and phone number of the person a customer should contact with complaints after the sale. A rubber stamp or preprinted form is fine.
Optional signature line. You may ask the buyer to sign acknowledging receipt. If you do, you must include this exact language near the line: "I hereby acknowledge receipt of the Buyers Guide at the closing of this sale." It has to appear in the space provided for the post-sale contact name.
Warranty coverage percentage. Fill in the percentage of parts and labor costs covered. If a deductible applies, mark it with an asterisk and explain it in the systems section, for example, "*A $50 deductible applies to each repair visit."
Systems covered. List each covered system specifically. The Rule prohibits shorthand like "drive train" or "power train" because those terms don't clearly identify which components are included. This is one of the more commonly missed requirements.
Manufacturer's warranty. If it hasn't expired, you may check the box stating so. But if the customer has to pay anything extra to get that coverage, it counts as a service contract, not a warranty, don't check the Warranty box.
Negotiated changes. If terms change during negotiation, the Guide must reflect it. Cross out the original figure and write in the new one. If you started at "As Is" and agreed to a warranty, cross out the As Is disclosure and complete the Warranty section properly.
The Spanish-language requirement
If you conduct a used car transaction in Spanish, you must post a Spanish-language Buyers Guide on the vehicle before you display or offer it for sale.
This is a posting requirement, not just a document-at-signing requirement — and it's one of the most frequently overlooked provisions in the Rule. If your sales floor regularly does business in Spanish, you need Spanish Buyers Guide Forms ($22.30) stocked alongside your English inventory.
Printing your own: the format rules are strict
You can generate Buyers Guides yourself, but the Rule specifies the wording, type style, type sizes, and format exactly. Specifically:
- 100% black ink on white paper
- Cut to at least 11" × 7¼"
- No additional wording or symbols — including your dealership logo
- Colored ink is permitted only for filling in the blanks
These requirements cannot be modified. A branded Buyers Guide is a non-compliant Buyers Guide.
If you'd rather print in-house, laser-compatible options include Interior Buyers Guide Forms ($30.90) and Used Car Buyers Guide Forms – No Tape ($22.60). For preprinted forms with adhesive already applied, the 2-Part Adhesive Buyers Guide Forms run $52.60.
A related point on window stickers. The Buyers Guide can't carry your branding — but a separate addendum or dealer window sticker can. That's what Auto Dealer Window Stickers (from $55.20), Kleer Edged Car Dealer Window Stickers ($33.30), Exterior Car Window Labels (from $64.70), and Exterior Addendum Labels (from $47.30) are for. Keep them as separate documents from the Guide.
What you must give the buyer at the sale
Hand over the original Buyers Guide or a copy, reflecting all final negotiated changes. If you use a signature line, make sure the buyer signs the version that reflects those final terms... not an earlier draft.
You also must include this exact disclosure in your sales contract:
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.
The Buyers Guide is not your written warranty
The warranty information on the Buyers Guide does not satisfy the FTC's Warranty Disclosure Rule. Your written warranty and the Buyers Guide must be two separate documents.
If you offer a written warranty, or if the manufacturer's warranty still applies, you also have to comply with the Magnuson-Moss Warranty Act. Among other things, that Act prohibits eliminating implied warranties when you provide a written warranty. A separate FTC rule on Pre-Sale Availability of Written Warranty Terms requires you to display written warranties near the vehicle or make them available on request before purchase.
What happens if you don't comply?
Dealers who violate the Used Car Rule may face penalties of up to $53,088 per violation in FTC enforcement actions. That figure is adjusted for inflation and was last updated in early 2025.
"Per violation" is the part worth sitting with. A lot with thirty improperly posted vehicles is not one violation.
Many states also have laws mirroring the Used Car Rule, and some incorporate it by reference. That means state and local officials may independently have authority to inspect your lot, fine you, or sue.
What about the CARS Rule?
You may have heard about the FTC's Combating Auto Retail Scams (CARS) Rule, which would have added significant advertising and pricing disclosure requirements.
It is not in effect. The Fifth Circuit Court of Appeals vacated the CARS Rule on January 27, 2025, finding the FTC had skipped a required procedural step in its rulemaking. The FTC did not appeal, and formally withdrew the rule from the Code of Federal Regulations effective February 12, 2026.
This changes nothing about the Buyers Guide. The Used Car Rule is a separate, long-standing regulation and remains fully in force.
It's also worth noting that deceptive pricing remains illegal under Section 5 of the FTC Act regardless. In March 2026 the FTC sent warning letters to 97 dealership groups stating that an advertised price must be the total price including all mandatory dealer-imposed fees, with only government taxes and registration excluded.
A quick compliance self-check
Run through this on your own lot:
- Is a properly completed Buyers Guide posted on every used vehicle offered for sale?
- Is it in plain view with both sides visible - not in a glove box or trunk?
- Are Guides going up before reconditioning is finished, not after?
- If you use a signature line, does it carry the exact required acknowledgment language?
- Does your sales contract include the required window-form disclosure?
- Are you using the correct version - As Is or Implied Warranties Only -for your state?
- Do systems-covered entries list specific systems rather than "power train"?
- If you sell in Spanish, are Spanish Guides posted on the vehicle?
- Does the buyer get a copy reflecting final negotiated terms?
- Are your forms plain black-on-white with no logo?
Stock the right forms
Browse FTC Buyers Guide forms in As Is, Implied Warranty, Spanish, laser-printable, adhesive, mirror-hanging, and exterior formats — plus holders and Not For Sale stickers.
Not sure which version your state requires? Call 888-928-2768, Monday through Friday, 8:00am–5:00pm PST. Orders over $100 ship free.
This article summarizes federal requirements for general informational purposes and is not legal advice. State requirements vary, particularly around as-is sales and implied warranties. Consult your state Attorney General's office or your dealership's counsel for guidance on your specific situation.
Comments