Introduction
Over the past several years, discrepancies have emerged in how manufacturers evaluate and approve dealers’ warranty parts and labor rate adjustment requests. Across multiple stores and years, dealers have observed inconsistent application of rules and policies, shifting and inconsistent interpretations of ‘warranty-like’ qualifications, and contradictory inclusion and exclusion decisions.
These inconsistencies — found in submissions for a given store year-over-year, in parts and labor submissions for the same store(s), and between similarly situated dealers — constitute what can only be described as disparate treatment. This article presents multiple documented examples illustrating how identical or near-identical repair orders and methodologies have been treated differently by the same manufacturer under changing or variable internal guidelines.
Each case study highlights the lack of evaluation consistency, transparent standards, and uniform enforcement of manufacturer policies across all dealer submissions.
Case Study 1: Same Store Parts & Labor Submissions with Different Rules
A dealer submitted requests for warranty parts and labor rate increases during mid-2025. The requests were submitted to their manufacturer in quick succession – both within a one-month period. After reviewing the labor request (which was submitted for review first) the manufacturer approved the dealer for a slightly reduced warranty labor rate, having made several adjustments inconsistent with rules and policies upheld in years prior. Just two days later, the dealer filed a parts request using nearly the same set of repair orders; 89 out of 90 days used in each request overlapped, with a variance of only a single day. Each submission was prepared under identical rules, with parts having been adjusted based on the manufacturer’s RO-by-RO feedback as provided in response to the dealer’s labor request. Despite the nearly identical range , the manufacturer cited and adjusted the handling of 19 entirely different repairs that were not cited in the manufacturer’s review of the previously approved labor sample. In other words, the manufacturer’s rules regarding what constitutes a “qualifying repair” had changed within just a 48-hour period.
The dealer therefore requested that the parts markup be approved using the same methodology and logic that governed the labor approval, proposing an amended markup aligned with the original figure requested, rather than the 3-point reduction resulting from this disparate treatment.
When submissions are prepared utilizing the same methodology, manufacturers should ensure parity across evaluations. Divergence in review criteria between labor and parts requests undermines procedural fairness and erodes dealer confidence in manufacturer processes.
Case Study 2: Statutory Interpretation and Shifting Rules
In another case, a dealer challenged a manufacturer’s inconsistent interpretation of a state warranty statute, year-over-year, with no relevant change to the state statute in reference.
In early 2025, the manufacturer in question cited the absence of ‘warranty-like’ language in the applicable state statute, asserting that repairs completed due to damage/outside influence, (rodent damage, accident damage, and other factors that would never be covered under a manufacturer warranty) should be included in the calculation. This interpretation was completely off base considering the fact that the entire intent of the statutory language is to include work that would be covered under a manufacturer’s warranty and to exclude work that is not. The manufacturer’s very own behavior contradicted their previously stated stance. In 2023, the manufacturer took the exact opposite stance to reduce the exact same dealer’s request, having stated that repairs completed due to “outside influence” should be removed from the calculation, only to reverse that position in 2025 when doing so worked to the manufacturer’s advantage. In both cases, the stance taken resulted in a submitted rate that was reduced; the exclusion of such repairs reduced the dealer’s approved rate in 2023, while the inclusion of this category reduced the approved rate in 2025.
Having taken notice of this contradiction, the dealer asserted a claim of disparate treatment, arguing that the manufacturer’s inconsistent rule application constituted an unfair practice. However, the manufacturer was unwilling to amend their stance, ultimately stating that their handling of the request in 2025 was aligned with the state statute’s guidelines, offering no further insight as to why the dealer’s requests were handled differently, year-over-year, following the same statutory guidelines.
When manufacturers alter interpretive positions without transparent rationale, they invite credible claims of disparate treatment. Even if statutory language supports flexibility, manufacturers should maintain internal consistency to preserve fairness and trust.
Case Study 3: Year-over-Year and Store-to-Store Inconsistency
Between 2020 and 2023, this dealer completed retail warranty submissions successfully under state law without issues, achieving full approvals for each request. Over the course of this time frame the manufacturer in question consistently excluded certain repair categories as maintenance and/or “not warranty-like”, these include brakes, wiper blades, keys, wheel locks, and carbon cleaning, to name a few — from retail warranty calculations.
In 2024, however, with no change to the language in the state statute, the manufacturer erroneously included these categories for the first time without explanation, significantly lowering the dealer’s requested rate. When the dealer challenged the inconsistency, citing the handling of their requests in years past and the non-warranty-like nature of the now-included repairs.
In 2025, just a few months later, the dealer proceeded with submitting new requests for both parts and labor, following the same policies that the manufacturer had followed from 2020-2023 – excluding categories consistent with maintenance and/or non-warranty like circumstances, and disregarding the manufacturer’s 2024 stance that these categories should now be included. Surprisingly, the manufacturer reverted to the pre-2024 standards, approving both parts and labor submissions without any adjustments, and without reference to the prior year’s disagreements.
When manufacturers apply policies regarding the qualification of repairs inconsistently and without rationale or notice in determining retail warranty rates, dealers are left in with uncertainty and doubt regarding manufacturer expectations and intentions to reimburse their dealers at true retail.
Conclusion
Across all cases, one theme persists: inconsistent manufacturer application of evaluation criteria. Dealers have demonstrated that identical methodologies, repair categories, and submission frameworks have been treated differently depending on timing, store, or request type.
This body of evidence illustrates how some manufactures change their interpretation of statutory language, whether in designating ‘warranty-like’ qualifications, adhering to state statute requirements, or determining inclusion and exclusion of specific repair categories based on internal criteria. This is not an indictment of all manufacturers, in all fairness, there are several of them that properly adhere to statutory requirements and have a consistent application of their internal policies.
For fairness and credibility to prevail in manufacturer–dealer relationships, evaluation criteria should be applied uniformly, transparently, and consistently across all rate requests — regardless of year, dealer, or submission type. Only through consistency can the process maintain legitimacy and support mutual trust between dealers and manufacturers.
Author Bio: Joe Jankowski is the Managing Member of the Hunt Valley, Maryland-based Armatus Dealer Uplift, a firm specializing in Retail Warranty Reimbursement submissions. Armatus has completed over 21,000 successful submissions nationwide. Joe has been personally involved in consulting on twenty-five retail warranty statutes and is widely recognized as a subject matter expert in this highly technical arena. Previously, Joe spent more than 20 years as CFO, COO, and CEO of a large automotive group in Maryland.
