We urge the National Highway Traffic Safety Administration (NHTSA) to modernize and simplify its vehicle recall practices. As vehicles continue to get more technologically advanced, these common sense changes will help improve vehicle safety and consumer awareness.

Part 1: Stop Requiring Paper Recall Notifications

The NHTSA currently requires all automakers in the United States to send paper letters via First Class mail to notify all affected owners of a recall, even if a recall can be addressed with an over-the-air (OTA) software update and has already been completed by the vehicle's owner. This requirement is costly, wasteful, and unnecessary. Paper notifications are harmful to the environment and cause consumer confusion. Oftentimes, most owners have already completed a critical software update and then receive an unnecessary paper letter notification weeks later explaining that an unreasonable risk to safety or noncompliance exists in their vehicle-causing consumer confusion over whether the unreasonable safety risk still exists on their vehicle. The NHTSA should implement a modern recall notification policy that allows manufacturers to send owners an electronic notification, including via email, text message, in-vehicle, or in-app notifications, instead of a paper notification.

Part 2: Stop Classifying OTA Software Updates as Recalls

Currently, there is no distinction between recalls that require an in-person hardware remedy and recalls that can be remedied over-the-air. Many recall remedies can be performed with OTA software updates at home, for free, and at the touch of an owner's fingertip rather than requiring consumers to bring vehicles into service centers for physical repairs. Properly classifying remedies performed through OTA software updates to distinguish this type of remedy from a physical repair will provide consumers greater understanding of their vehicle's real-time condition and improve vehicle safety. Furthermore, news reports of automatic OTA software updates, sometimes affecting millions of vehicles, may sensationalize a very small, non-critical issue and mislead the public and create distrust among future electric vehicle adopters. Clearer communication and proper classification from NHTSA for OTA software updates-both for critical and non-critical OTA software updates-is needed.

We call for the NHTSA to allow manufacturers to send electronic recall notifications, and to stop classifying over-the-air software updates as recalls.