Executive Summary

The Magnuson-Moss Warranty Act (MMWA) is codified at 15 U.S.C. sections 2301 to 2312 ¹ and implemented through 16 CFR Parts 700 to 703 ². It governs written warranties on consumer products costing more than 5 USD, with designation rules above 10 USD and pre-sale availability above 15 USD (Cornell LII, accessed May 2026 ³).

July 2024: the FTC sent right-to-repair warranty warning letters to 8 companies, including Aeris Health, Blueair, Medify Air, Oransi, InMovement, ASRock, Zotac, and Gigabyte (FTC press release, July 2, 2024 ⁴).

October 2022: final FTC consent orders against Harley-Davidson, Weber-Stephen, and MWE Investments (Westinghouse) required revised warranty language affirming that independent repair does not void coverage (FTC press release, October 7, 2022 ⁵).

June 2024: a Wisconsin federal court dismissed the Harley-Davidson MMWA class action and declined to follow the FTC’s expansive reading of the anti-tying rule (Seyfarth Shaw analysis, June 2024 ⁶).

Plaintiff-bar exposure has scaled: at least 23 MMWA class actions filed in Arkansas in recent months, with copycats in Pennsylvania, Illinois, and California (Lexology, 2024 ⁷). The US extended warranty market reached 48.38 billion USD in 2024 with projected 9.43% CAGR through 2034 (Precedence Research, 2025 ⁸).

In October 2022 the FTC approved final consent orders against Harley-Davidson Motor Company, Weber-Stephen Products, and MWE Investments (Westinghouse outdoor power) over warranty practices that the Commission said violated the Magnuson-Moss anti-tying rule (FTC, October 7, 2022 ⁵). Less than two years later, in July 2024, the FTC sent fresh warning letters to eight more companies, from air purifier makers to gaming PC component manufacturers, giving each 30 days to revise its warranty language or face enforcement (FTC press release, July 2, 2024 ⁴).

Then, in June 2024, a Wisconsin federal court dismissed the Harley-Davidson MMWA multidistrict class action, declining to defer to the FTC’s expansive reading of the same rule (Seyfarth Shaw, June 2024 ⁶). The takeaway for any compliance lead reading this: Magnuson-Moss is the federal warranty rule most retailers misread. The text is from 1975. The enforcement is from this quarter. The interpretive split between the FTC and the federal courts is live, and the plaintiffs’ bar is filing dozens of class actions while it remains unsettled.

Most product teams treat their written warranty as boilerplate. In 2026 that posture is expensive. This field guide walks the statute, the four FTC rules, the 2022 to 2024 enforcement record, and the operational playbook that keeps a custom warranty program clean across both consumer-product and service-contract surfaces.

Download the Magnuson-Moss Compliance Checklist PDF

Who this report is for

• Compliance and legal leads auditing a product warranty program against MMWA and the 16 CFR Part 700 to 703 rule set.
• GMs and operations leaders sizing the cost of revising warranty language across SKUs, packaging, and retailer-facing collateral.
• F&I directors and dealer principals evaluating tie-in language, “warranty void if” stickers, and independent-repair posture across rooftops.
• OEM product and brand managers deciding whether warranty language sits with legal, with marketing, or in a shared compliance workflow.
• Founders at DTC and ecommerce brands running written warranties on consumer products sold into all 50 states without a formal compliance function.

Why Magnuson-Moss still matters in 2026

The Magnuson-Moss Warranty Act was signed into law on January 4, 1975 (Cornell LII ¹). The text has barely moved in five decades. What has moved is the enforcement context and the litigation exposure attached to it.

Three forces drive 2026 relevance.

First, federal enforcement is active. The FTC opened the right-to-repair file with its April 2018 warranty warnings ⁹ to Sony, Nintendo, Microsoft, HTC, Asus, and Hyundai over “warranty void if removed” stickers. It escalated to consent orders against Harley-Davidson, Weber, and Westinghouse in 2022, then issued eight more warning letters in 2024. The Commission has now built a clear posture across two administrations.

Second, the plaintiffs’ bar has picked up the file. At least 23 MMWA class actions filed in Arkansas alone in recent months, with copycats in Pennsylvania, Illinois, and California (Lexology, 2024 ⁷). The MMWA fee-shifting provision at 15 U.S.C. section 2310(d)(2) ¹⁰ makes these economical for plaintiffs’ counsel even on modest individual claims.

Third, the commercial stakes are big. The US extended warranty market reached 48.38 billion USD in 2024 with projected 9.43% CAGR through 2034, reaching 117.02 billion USD (Precedence Research, 2025 ⁸). A retailer-channel extended warranty attach rate of roughly 5.07% on product sales sits on top of that (Warranty Week, November 21, 2024 ¹¹). Approximately one in three vehicle buyers purchases a vehicle service contract (Warranty Week baseline ¹²). Warranty design is a margin lever and a compliance surface at the same time.

What the Magnuson-Moss Warranty Act actually covers

Scope, codification, and the consumer-product definition

MMWA is codified at 15 U.S.C. sections 2301 to 2312 ¹, Chapter 50 of Title 15. Definitions live at section 2301 ¹³. The Act applies to “consumer products,” meaning tangible personal property distributed in commerce and normally used for personal, family, or household purposes. That category is broad: appliances, electronics, motor vehicles, lawn and garden equipment, fitness gear, gaming hardware, even residential building materials in their finished, separable form.

The Act does not require a manufacturer or retailer to offer a written warranty at all. If you offer one, MMWA tells you what it must say and how it must be made available.

The three price thresholds

Three dollar amounts trigger three different MMWA obligations. They have been unchanged since 1975 and they are easy to miss.

• Over 5 USD. Basic MMWA coverage attaches: definitions, attorney-fee shifting, and the tie-in prohibition all apply.
• Over 10 USD. Section 2303 designation rule: any written warranty must be designated either “full” or “limited” (15 U.S.C. section 2303 ³).
• Over 15 USD. 16 CFR Part 701 disclosure rule ¹⁴ and 16 CFR Part 702 pre-sale availability rule ¹⁵ attach. The single-document rule, the disclosure list, and the pre-sale availability obligation all trigger here.

Almost every regulated product sits above 15 USD. Almost every consumer product warranty therefore carries all three sets of obligations.

Does Magnuson-Moss apply to B2B?

The clean answer: generally, no. MMWA defines a “consumer” as a buyer (other than for purposes of resale) of a consumer product, plus any person to whom the product is transferred during the duration of the written or implied warranty, plus any other person entitled by state law to enforce the obligations (15 U.S.C. section 2301 ¹³). True B2B transactions, where a business buys an industrial good for use in its operations, generally sit outside the consumer-product definition.

The wrinkle: many products are “dual-use.” A power tool, a portable air conditioner, or a vehicle can be a consumer product in one sale and a commercial good in the next. Courts apply a “normally used” test rather than a buyer-by-buyer test. If a product is normally used for personal, family, or household purposes, it carries MMWA coverage even when an individual sale is to a commercial buyer.

16 CFR Part 700 to 703 in plain English

The FTC’s implementing rules sit at 16 CFR Subchapter G ². The four parts each do one job.

The single-document rule

Part 701 requires the warranty disclosure to appear in a single document. Splitting the warranty across multiple documents, or burying terms in a separate “limited warranty” booklet that is not provided with the principal warranty, fails the rule. The FTC’s Businessperson’s Guide to Federal Warranty Law ¹⁹ details the 13 required disclosure items.

The pre-sale availability rule for ecommerce

Part 702 originally required brick-and-mortar retailers to make warranty terms available before purchase via on-package text, a display binder, or in-store posting. The FTC’s 2015 final action ²⁰ updated the rule to allow online disclosure for catalog and internet sales, provided the warranty terms are clearly linked from the product detail page and accessible before the consumer commits to purchase.

Most ecommerce platforms now host warranty terms on a dedicated warranty page linked from product detail templates. A site map link alone, with no PDP-level surface, does not satisfy the rule.

The IDSM 40-day rule

Part 703 governs any “informal dispute settlement mechanism” the warrantor offers as a prerequisite to litigation. The mechanism must issue a decision within 40 days of notification (47 days if the consumer did not first contact the warrantor), and must meet minimum standards on staffing, recordkeeping, and disclosure. A warrantor cannot require the consumer to use the IDSM unless the mechanism meets Part 703.

Full versus limited warranty designation

Section 2303 ³ requires every written warranty on a consumer product costing more than 10 USD to be designated “full” or “limited.”

Full warranty (section 2304)

A “full” warranty must meet the federal minimum standards at 15 U.S.C. section 2304 ²¹:

• Repair or replace within a reasonable time without charge.
• No limitation on the duration of any implied warranty.
• No exclusion or limitation of consequential damages for breach of any written or implied warranty, unless the exclusion appears conspicuously on the face of the warranty.
• Refund or replacement at the consumer’s election after a reasonable number of repair attempts.

If you cannot meet all four standards, you cannot label the warranty “full.” Labeling it “full” anyway is a 2303 violation on its face.

Limited warranty

A “limited” warranty is anything that does not meet the four 2304 standards. Labeling a warranty “limited” is not a penalty. Most consumer-product warranties on the market are limited warranties. The federal rule is honest disclosure, not a mandate to offer a full warranty.

Mixed warranty

The Act allows a “multiple warranty” structure in which part of the coverage meets 2304 standards and part does not. Each section must be designated and the designation must be clear to the consumer.

The tie-in sale prohibition

Section 2302(c) ²² is the rule the FTC has spent the last six years enforcing. It says:

No warrantor of a consumer product may condition his written or implied warranty of such product on the consumer’s using, in connection with such product, any article or service (other than article or service provided without charge under the terms of the warranty) which is identified by brand, trade, or corporate name.

16 CFR section 700.10 ¹⁷ is the FTC’s interpretive companion. The Commission reads the rule expansively. “Warranty void if removed” stickers, language requiring use of brand-name parts, and language requiring service by authorized dealers can all trigger anti-tying scrutiny.

The 2018 starting point

The FTC’s April 2018 warranty warnings ⁹ put six companies (Sony, Nintendo, Microsoft, HTC, Asus, and Hyundai) on notice over “warranty void if removed” sticker language. The letters did not result in enforcement but established the FTC’s position.

The 2022 consent orders

In June 2022 the FTC filed complaints against Harley-Davidson and MWE Investments (Westinghouse) for illegally restricting customers’ right to repair (FTC, June 2022 ²³). In October 2022 the Commission approved final consent orders against Harley-Davidson, Weber-Stephen, and MWE Investments requiring revised warranty language affirming that independent repair does not void coverage (FTC, October 2022 ⁵).

The 2024 warning letters

On July 2, 2024 the FTC sent warning letters to eight companies: Aeris Health, Blueair, Medify Air, Oransi, InMovement, ASRock, Zotac, and Gigabyte (FTC, July 2024 ⁴; FTC business blog, July 2024 ²⁴). The category mix is informative: air purifiers, treadmills, and PC components. Anything with a serviceable internal component is on the Commission’s radar.

The Harley-Davidson dismissal

In June 2024 the Western District of Wisconsin dismissed the consolidated MMWA class action against Harley-Davidson (Seyfarth Shaw, June 2024 ⁶). The court found that Harley’s written warranty did not on its face violate the tie-in prohibition because it described modifications that “may” void powertrain coverage rather than language tying coverage to branded parts. The court declined to defer to the FTC’s interpretive reading.

The dismissal is significant. It does not undo the 2022 consent orders. It does signal that federal courts are willing to scrutinize the FTC’s expansive anti-tying theory, and that warranty language drafted carefully on the “modifications may void” axis may survive a 12(b)(6) motion even where the Commission would have objected to it.

The practical test

A practitioner test: does the written warranty condition coverage on the use of a specific branded article or service? If yes, redraft. If the warranty addresses the consequences of modifications or independent repair (rather than tying coverage to a branded part), the language is in a different (and more defensible) zone, though it should still be reviewed against 16 CFR section 700.10 ¹⁷ and the current FTC posture.

Implied warranties and the no-disclaimer rule

15 U.S.C. section 2308 ²⁵ is short and surprisingly often missed: a supplier offering a written warranty or selling a service contract on a consumer product may not disclaim or modify any implied warranty.

A supplier who issues a limited warranty may limit the duration of implied warranties to the duration of the written warranty, provided the limitation is conspicuous and reasonable. A supplier who issues a full warranty may not limit the duration of implied warranties at all.

Three operational points fall out of this rule.

1. A “no implied warranties” clause is unenforceable on a consumer product covered by a written warranty. Boilerplate disclaimers of merchantability or fitness do not survive 2308.
2. Selling a service contract converts the analysis. If the supplier separately sells a service contract, the disclaimer prohibition kicks in for any associated written warranty, even if the principal warranty would not otherwise have triggered 2308.
3. The agent exception is narrow. A supplier acting only as an agent for a third-party warrantor is not subject to 2308 disclaimer prohibition. Most retailers selling private-label products are not in this exception.

The service contract carve-out and its interaction with state law

A “service contract” is defined separately at 15 U.S.C. section 2301(8) ¹³ as a written contract for repair or maintenance for a specified period.

Service contracts are not “written warranties” under the Act, which means most of the Part 700 to 702 rules do not apply directly to service contract terms. The 2308 implied-warranty rule does apply: selling a service contract triggers the no-disclaimer rule for the underlying product.

The bigger carve-out is at 15 U.S.C. section 2311 ²⁶: MMWA does not preempt state warranty law that gives consumers greater protection. The McCarran-Ferguson Act independently prevents Magnuson-Moss from displacing state laws “enacted for the purpose of regulating the business of insurance.” Most state service contract regulation runs through state insurance codes. The practical result: the service contract you sell into 50 states sits under 50 different state regimes on top of the federal floor.

A retailer or OEM running a multi-state service contract program has to satisfy both layers. The federal layer is MMWA. The state layer is the NAIC Service Contracts Model Act 685 ²⁷, as adopted with state-specific modifications. AllShield wrote a full state-by-state map of those state regimes; the federal piece is this guide.

Remedies, litigation exposure, and arbitration

15 U.S.C. section 2310 ¹⁰ governs remedies in consumer disputes.

Attorney fees and class actions

Prevailing consumer plaintiffs can recover attorney fees and costs under section 2310(d)(2) ¹⁰. The fee-shifting provision is what makes the plaintiffs’ bar interested in MMWA class actions even on modest individual claims.

Federal-court jurisdictional thresholds for MMWA claims sit at 50,000 USD for an individual claim (exclusive of interest and costs) and 25 USD per individual claim with 100 named plaintiffs for a class action (section 2310(d)(3) ¹⁰). Many MMWA class claims are paired with state UDAP or consumer-protection claims to meet the threshold.

The arbitration circuit split

Federal circuits are divided on whether pre-dispute binding arbitration is enforceable on MMWA claims. The Eleventh Circuit has held that MMWA claims are arbitrable. The Ninth Circuit has held that pre-dispute binding arbitration is invalid under MMWA. The Supreme Court has not resolved the split. Warrantors offering arbitration clauses face inconsistent treatment depending on circuit.

Statute of limitations

MMWA breach-of-warranty claims generally carry a 4-year statute of limitations under UCC section 2-725 ²⁸, measured from delivery for most warranties (later for warranties extending to future performance).

Penalty and enforcement-cost callout

For a compliance lead pricing the cost of doing nothing, the numbers below are the board-ready exposure:

• Federal enforcement. Consent orders carry no automatic civil penalty under MMWA itself, but FTC orders under Section 5 of the FTC Act ²⁹ can carry civil penalties up to 51,744 USD per violation (2025 adjusted) and, more importantly, agreed compliance burdens that can run for 20 years. Warning letters are free, but they set up the Section 5 violation if behavior does not change.
• Class-action exposure. With at least 23 Arkansas filings in recent months and additional cases in Pennsylvania, Illinois, and California (Lexology, 2024 ⁷), the defense cost alone runs into the high six figures on each filing.
• Fee-shifting on individual cases. The section 2310(d)(2) ¹⁰ attorney-fee provision means an individual MMWA win on a single defective consumer product can cost the warrantor tens of thousands of dollars in plaintiff-side fees even where the underlying claim is small.
• State right-to-repair statutes. New York, Minnesota, California, Oregon, and Colorado have enacted right-to-repair laws layering on top of MMWA. State-level civil penalties run on top of any federal exposure.
• Operational cost. A consent order typically requires a written compliance program, training, retention of records for 5 to 10 years, and biennial reporting. Build it in advance and you save the cost of building it under a deadline.

The number to plan against is not any single headline FTC action. It is the cumulative cost of running a non-compliant written warranty across SKUs, retailers, and states.

Operational playbook: 5 steps to clean MMWA posture

The following five steps map directly to the operational checklist below. They are the work, in order, to bring a written warranty program into 2026 compliance.

Step 1: Audit your designation

Pull every written warranty in market. For each one priced over 10 USD, confirm that the warranty is conspicuously designated “full” or “limited” per section 2303 ³. If “full,” confirm the four section 2304 ²¹ standards are actually met. Mis-designation is the most common 2303 violation we see in audit.

Step 2: Consolidate into a single document

Confirm the warranty meets the 16 CFR Part 701 ¹⁴ single-document rule and contains the 13 required disclosures. Split warranties (warranty card + supplemental booklet + website page) are a recurring finding. Consolidate into one canonical document and link to it from every other surface.

Step 3: Verify pre-sale availability across channels

For brick-and-mortar: on-package, display binder, or in-store posting per 16 CFR Part 702 ¹⁵. For ecommerce and catalog: a clearly linked PDP-level warranty page meeting the 2015 final action standards. Audit the PDP template, not the brand site footer.

Step 4: Strip tie-in and “void if” language

Pull every written warranty and every package label. Identify and remove language that conditions coverage on the use of a brand-name part or service, or that says coverage is void if an independent repair is performed or a sticker is removed. Replace with neutral “modifications or improper service may void coverage” language and a 16 CFR section 700.10 review pass.

Step 5: Stand up an IDSM workflow (if you offer one)

If you require informal dispute settlement before litigation, the mechanism must meet 16 CFR Part 703 ¹⁸: 40-day decision rule (47 days if the consumer did not first contact the warrantor), staffing standards, recordkeeping, and disclosure. If you do not meet Part 703, you cannot require IDSM as a prerequisite to suit, and any clause that says you can is unenforceable.

How a custom warranty platform absorbs the federal compliance load

A custom warranty program built on a compliance-forward platform handles the federal layer at the configuration tier, not the contract tier.

Designation logic. The platform routes each SKU to a “full” or “limited” template based on coverage parameters at product setup, and surfaces a conspicuous designation at every consumer-facing rendering of the warranty.

Single-document rendering. The platform serves a single canonical warranty document per product, with all 13 Part 701 ¹⁴ disclosures rendered server-side. Marketing surfaces and retailer-facing collateral link to that canonical document rather than restating its terms.

Pre-sale availability API. A warranty terms endpoint plugs into PDP templates, catalog systems, and POS surfaces. The same compliance-reviewed terms appear at every channel before purchase, satisfying Part 702 ¹⁵ for in-store, catalog, and ecommerce simultaneously.

Tie-in scrubber. Template-level review flags branded-part and “void if removed” language at draft, before the warranty goes live. The compliance team reviews exceptions; the engineering team does not have to.

IDSM workflow. A built-in dispute workflow records consumer notification, routes to a designated staff queue, and surfaces the Part 703 ¹⁸ 40-day clock with audit-trail recordkeeping.

State overlay. The platform’s state engine handles the McCarran-Ferguson overlay on service contracts: financial-security method, state-specific disclosure scripts, free-look windows, and SERFF or state-portal filings. Federal compliance and state compliance run from one configuration, not two.

A white-label, API-friendly platform of this type lets a retailer, OEM, or dealer launch a compliant written warranty or service contract program across all 50 states without standing up a separate compliance function or relearning Magnuson-Moss for every product line.

Download the Magnuson-Moss Compliance Checklist PDF

A printable, board-ready checklist mapping the five operational playbook steps to the underlying statute and CFR cite, with a 13-item Part 701 disclosure audit grid and a tie-in language self-scorer.

Recent FTC enforcement and court rulings, last 36 months

A compressed timeline for the file.

• April 2018. FTC staff sends warranty warnings to 6 companies over “warranty void if removed” stickers (FTC business blog, April 2018 ⁹).
• June 2022. FTC files complaints against Harley-Davidson and Westinghouse (MWE) for illegally restricting customers’ right to repair (FTC, June 2022 ²³).
• October 2022. Final consent orders against Harley-Davidson, Weber-Stephen, and MWE Investments require revised warranty language (FTC, October 2022 ⁵).
• In 2023, Fifth Circuit in Elson v. Black, 56 F.4th 1002, affirms striking of class allegations in an MMWA-related class action.
• June 2024. W.D. Wisconsin dismisses the consolidated Harley-Davidson MMWA class action and declines to defer to the FTC’s anti-tying interpretation (Seyfarth Shaw, June 2024 ⁶).
• July 2, 2024. FTC sends warranty warning letters to 8 companies: Aeris Health, Blueair, Medify Air, Oransi, InMovement, ASRock, Zotac, Gigabyte (FTC, July 2024 ⁴).
• October 2024. US PIRG “Warranties in the Void” report finds most surveyed appliance manufacturers continue to oppose independent repair six months after FTC warnings (US PIRG, October 2024 ³¹).
• 2024 to 2025. Plaintiff-bar wave: at least 23 MMWA class actions filed in Arkansas alone, with copycats in Pennsylvania, Illinois, and California (Lexology, 2024 ⁷).
• March 2025. Jeep Wrangler and Gladiator class action filed over alleged defective power steering pump electrical connector in 2021 to 2023 model years, asserting MMWA among other claims (ClassAction.org ³²).

Frequently asked questions

What is the Magnuson-Moss Warranty Act?

The Magnuson-Moss Warranty Act is the federal statute governing written warranties on consumer products, codified at 15 U.S.C. sections 2301 to 2312 ¹. It does not require manufacturers to issue warranties, but it sets the rules for any written warranty that is issued, including designation, disclosure, pre-sale availability, and a prohibition on tie-in sales.

Does the Magnuson-Moss Warranty Act apply to B2B sales?

Generally no. MMWA governs “consumer products,” meaning tangible personal property normally used for personal, family, or household purposes. True industrial or commercial-only goods sit outside the Act. A product with dual consumer-and-commercial use generally carries MMWA coverage if it is normally used in a consumer setting, regardless of any particular sale.

What is the difference between a full warranty and a limited warranty?

A full warranty meets the four federal minimum standards at 15 U.S.C. section 2304 ²¹: repair or replace without charge, no duration limit on implied warranties, no consequential-damages exclusion (unless conspicuous), and refund or replacement after a reasonable number of repair attempts. A limited warranty is anything that does not meet those standards. The designation must be conspicuous on the warranty document.

What is the tie-in sale prohibition?

15 U.S.C. section 2302(c) ²² prohibits a warrantor from conditioning a written or implied warranty on the consumer’s use of a branded article or service. 16 CFR section 700.10 ¹⁷ provides the FTC’s interpretive gloss. The FTC has enforced the rule against Harley-Davidson, Weber, and Westinghouse in 2022 and sent warning letters to eight more companies in 2024.

Are “warranty void if removed” stickers legal under federal law?

The FTC takes the position that “warranty void if removed” stickers violate the section 2302(c) ²² tie-in prohibition and 16 CFR section 700.10 ¹⁷. The Commission sent warning letters on the issue in 2018 and again in 2024. Court treatment is more mixed, but the regulatory risk is clear: remove the stickers and the language.

Can a written warranty disclaim implied warranties?

No. 15 U.S.C. section 2308 ²⁵ prohibits a supplier offering a written warranty or selling a service contract from disclaiming any implied warranty. A limited written warranty may limit the duration of implied warranties to the duration of the written warranty if the limitation is conspicuous and reasonable. A full warranty may not limit implied warranty duration at all.

What is the pre-sale availability rule and how does it apply to online sales?

16 CFR Part 702 ¹⁵ requires the warranty terms to be available to the consumer before purchase. Brick-and-mortar retailers can use on-package text, a display binder, or in-store posting. Catalog and internet sellers, since the FTC’s 2015 final action, can satisfy the rule by clearly linking the warranty terms from the product detail page. A site-map link alone is not sufficient.

Do service contracts fall under the Magnuson-Moss Warranty Act?

Service contracts are defined separately at 15 U.S.C. section 2301(8) ¹³ and are not “written warranties” under the Act. The Part 700 to 702 rules do not directly apply. The 2308 implied-warranty rule does apply, and selling a service contract triggers the no-disclaimer rule for the associated product. Most state regulation of service contracts runs through state insurance codes under the McCarran-Ferguson carve-out.

Can consumers recover attorney fees in a Magnuson-Moss lawsuit?

Yes. Prevailing consumer plaintiffs can recover attorney fees and costs under 15 U.S.C. section 2310(d)(2) ¹⁰. The fee-shifting provision is the main reason the plaintiffs’ bar is active under MMWA even on modest individual claims.

What is an informal dispute settlement mechanism (IDSM) under 16 CFR 703?

An IDSM is a warrantor-established dispute resolution mechanism that the warrantor requires the consumer to use before filing suit. 16 CFR Part 703 ¹⁸ sets minimum standards: a 40-day decision rule (47 days if the consumer did not first contact the warrantor), staffing standards, recordkeeping, and disclosure to consumers. A warrantor cannot require the consumer to use an IDSM that does not meet Part 703.

What are the FTC’s recent enforcement actions under the Magnuson-Moss Warranty Act?

The most recent file: July 2024 warning letters to 8 companies on right-to-repair language (FTC, July 2024 ⁴); October 2022 final consent orders against Harley-Davidson, Weber, and MWE Investments (FTC, October 2022 ⁵); April 2018 warning letters to 6 companies on “warranty void if removed” stickers (FTC, April 2018 ⁹).

Do state right-to-repair laws change my Magnuson-Moss obligations?

State right-to-repair statutes in New York, Minnesota, California, Oregon, and Colorado are not direct MMWA amendments, but they reinforce the federal anti-tying regime and create additional state-law exposure for warrantors who restrict independent repair. A warranty program that complies with MMWA generally needs a layered review against state right-to-repair statutes in those jurisdictions.

Download the Magnuson-Moss Compliance Checklist PDF

Book a 30-minute call with All Shield. White-label, API-friendly custom warranty programs with built-in Magnuson-Moss compliance, NAIC Model Act 685 state coverage, and a single configuration across designations, disclosures, pre-sale rendering, and IDSM workflow.

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   20. Federal Trade Commission — 16 Cfr Parts 239 700 701 702 703 Final Action Magnuson Moss Warranty Act Interpretations Rules. https://www.ftc.gov/legal-library/browse/federal-register-notices/16-cfr-parts-239-700-701-702-703-final-action-magnuson-moss-warranty-act-interpretations-rules
   21. Cornell Legal Information Institute — 2304. https://www.law.cornell.edu/uscode/text/15/2304
   22. Cornell Legal Information Institute — 2302. https://www.law.cornell.edu/uscode/text/15/2302
   23. Federal Trade Commission — Ftc Takes Action Against Harley Davidson Westinghouse Illegally Restricting Customers Right Repair 0. https://www.ftc.gov/news-events/news/press-releases/2022/06/ftc-takes-action-against-harley-davidson-westinghouse-illegally-restricting-customers-right-repair-0
   24. Federal Trade Commission — Warranty Warnings Dont Interfere Consumers Right Repair. https://www.ftc.gov/business-guidance/blog/2024/07/warranty-warnings-dont-interfere-consumers-right-repair
   25. Cornell Legal Information Institute — 2308. https://www.law.cornell.edu/uscode/text/15/2308
   26. Cornell Legal Information Institute — 2311. https://www.law.cornell.edu/uscode/text/15/2311
   27. National Association of Insurance Commissioners — Model Law 685.Pdf. https://content.naic.org/sites/default/files/model-law-685.pdf
   28. Consumer Law Group — Magnuson Moss Warranty Act. https://clgplc.net/magnuson-moss-warranty-act/
   29. Federal Trade Commission — Federal Trade Commission Act. https://www.ftc.gov/legal-library/browse/statutes/federal-trade-commission-act
   30. All Shield — Contact page. https://allshield.co/contact/
   31. U.S. PIRG — Warranties Void. https://uspirg.org/reports/usp/warranties-void
   32. ClassAction.org — Moss Magnusson Warranty Act. https://www.classaction.org/news/category/moss-magnusson-warranty-act

Disclosure

This report is provided for informational purposes only and does not constitute legal, insurance, regulatory, tax, or compliance advice. Service contract, warranty, and protection-plan requirements vary by state, product type, obligor structure, financial-security method, and sales channel. Readers should consult qualified counsel or regulatory advisors before launching, modifying, or expanding a service contract or warranty program.