New York Regulates the Radius of the Arc on Your Body Shop's Sign
Short answer: New York registers repair shops under Vehicle and Traffic Law article 12-A, and the operating detail lives in 15 NYCRR Part 82, published by the DMV as CR-82. It is the most prescriptive shop rulebook we have read, and it is prescriptive in a very particular way: it does not tell you how to repair a car. It tells you what to write down, what to keep, what to say on paper, and what your sign looks like.
Including the radius of the arc of one word on it.
82.7(b)(1)(iii): "The word 'REGISTERED' shall be in an arc which shall have a radius of two feet, nine inches."
The sign, specified
Every registered New York repair shop posts an official outdoor sign it must buy itself. Part 82 tells it exactly what that sign is.
- Size. "three feet wide and two feet high and made of a durable material which will withstand the outdoor elements", single or double faced, hung so it is visible to the public (82.7(b)).
- Colour. "The background of the sign shall be kelly green and the lettering and numbering shall be white." (82.7(b)(1)(i)). Not green. Kelly green.
- Letter heights. "The letters in the words 'STATE OF NEW YORK' shall be two inches high, with a stroke of approximately one-half inch. All other letters shall be four inches high, with a stroke of approximately three-fourths of one inch." (82.7(b)(1)(ii)).
- The arc. Radius of two feet nine inches, above.
- The number. "Such numbers shall be two inch block numbers with a stroke of approximately one-half inch", directly below the word REGISTERED (82.7(b)(1)(iv)).
- Deadline. "Such signs must be in place within 30 days from the date of issuance of the registration."
- Mobile shops get a proportionally smaller sign, "but no smaller than one (1) foot high by two (2) feet wide" (82.7(b)(3)).
There is a second, separate sign. 82.7(c) requires a sign "at least 8 1/2 by 14 inches" showing how the labour charge is computed, posted next to the official indoor sign, again supplied by the shop. The regulation prints suggested wording, including the line "YOU HAVE A RIGHT TO ADDITIONAL INFORMATION ON LABOR COSTS UPON REQUEST."
It is easy to read the arc radius as bureaucracy for its own sake. There is a defensible reading: a sign specified this tightly is one a consumer can recognise at a glance and one a counterfeiter cannot casually approximate. We are not endorsing that reading. We are noting the rule exists and is unusually exact.
What must be on the estimate, and on the invoice
This is where Part 82 gets genuinely useful, and where a body shop should read it twice.
The estimate (82.5(a)) is required "Upon the request of any customer", and once given, the shop "shall not charge for work done or parts supplied in excess of the estimate without the consent of such customer." It must contain the customer's name, the shop's name and facility number, the date, a list of parts with the cost of each, the labour charge for each repair with its cost, year and make, plate number or VIN, a description of the problem as the customer reported it, and a statement of the customer's right to receive replaced parts on written request.
Then the collision-specific line: "for body parts, the repair shop must indicate if the part is a new original equipment manufacturer part, a new after market equipment manufacturer part or a used part." Three classes, and a blanket statement that all body parts are one class except as indicated is expressly allowed.
And a requirement that sounds trivial and is not: "All information on an estimate must be legible."
The invoice (82.5(c)) carries everything above plus more, and two items stand out because almost nowhere else asks for them:
- Two odometer readings. "the odometer reading on the vehicle at the time it was left with the repair shop and the odometer reading at the time the invoice was prepared." Not one. Both.
- The guarantee, in writing, with its limit. "the terms and time limit of any guarantee for the repair work performed."
82.5(b) bars any work not authorised by a work order, and handles the oral case explicitly: an oral work order "shall be noted on the invoice and shall include the date, time and manner of authorization and by whom such authorization was given."
Your old parts, and a right you cannot give up by phone
82.5(d) requires replaced parts to be returned on timely written demand. Then it does something unusual:
"If work is authorized over the telephone, it shall be presumed that the customer wants his parts returned", and the shop must hold them until the customer collects the vehicle. Then, flatly: "Customers may not waive their rights to replaced parts over the telephone."
A right that cannot be waived in the medium where waivers are easiest to extract. The carve-out is narrow: parts normally sold on an exchange basis, or subject to a manufacturer's warranty.
The airbag chain, in a bound book with numbered pages
If a New York shop removes or installs an inflatable restraint system, 82.9(b) requires a log, and specifies its physical form: "a bound log book", and the records "must be maintained in a bound book with consecutively numbered pages."
For every airbag repair the book records the date of installation, the VIN, the registration plate number, the make, the model, and the replacement restraint's part number.
If the replacement is a salvage unit, 82.9(b)(2) also records the VIN of the vehicle the airbag came out of, and the "name, tax identification number and registration number of the dismantler from whom the salvaged restraint system was purchased."
The invoice side matches. 82.5(c) requires the invoice to name the supplier and its tax identification number, and for a salvage unit to state the dismantler's registration number, the donor VIN and the part number, and to say "salvage inflatable restraint system" in terms. It also requires that "The insurer and consumer shall receive a copy of the purchase invoice for the replacement inflatable restraint system."
And the book is not just for the DMV. It must be available to "an agent of the commissioner or any police officer."
That is a full provenance chain for one component, ending in a bound paper book that a police officer can ask to see. Whatever you think of the paperwork, it is the most complete parts-traceability requirement on any repair page we have built.
A job rate is banned for body work
82.8(a) lets a shop use a job rate covering both labour and parts, but only "on mechanical and electrical repairs costing less than two hundred dollars", and only with a parts list still shown. Then: "A job rate may not be used for body repair work."
Body work in New York is priced by parts and labour, itemised, and the estimate must say the hourly rate and how it is computed. If flat rate, 82.8(a) requires the manual to be specified, and 82.8(b) entitles the consumer to be shown the relevant time rates from that manual on request.
82.8(e) then contemplates something the trade argues about constantly: "One manual may be used for mechanical repairs, one for body repairs and a different one for paint and refinishing materials." Three manuals, expressly permitted, provided each is "objective and has wide acceptance in the industry." A manual may be printed or electronic.
Storage has a clock
82.8(c)(1): no storage charge unless written notice was given, which can be a line on the estimate.
82.8(c)(2): "Storage may not be charged during the period from which the customer has authorized repairs to one business day after the repair shop has notified the customer to pick up the repaired vehicle."
So the storage meter is off for the entire time the car is being worked on, and stays off for one business day after the shop calls. 82.8(d) also lets a customer take the vehicle away mid-repair on reasonable notice, paying only for labour actually performed, parts actually installed, non-returnable parts ordered specifically for the car, and storage properly charged.
Records, complaints, and the clock that closes
82.9(a) covers estimates, work orders, invoices, parts purchase orders and appraisals: "Such copies shall be kept for two years and shall be available for inspection by the commissioner or his designee during all business hours."
82.10: "The commissioner will accept complaints against a repair shop up to 90 days or 3,000 miles after completion of the repairs, whichever comes first."
That is the sentence most worth knowing and the one most likely to catch a consumer out. Ninety days is short for a repair defect and 3,000 miles is roughly two months of ordinary driving. Whichever expires first, expires the complaint. A settlement reached through the commissioner "shall not act to bar the commissioner from proceeding to a hearing", so settling does not close the regulatory file even though it may close yours.
One rulebook, statewide, and no local copies
82.11 is a preemption clause with an unusual second half. The act and Part 82 are "applicable and uniform throughout this State", no local authority may enact anything in conflict, and no local authority may "enact or duplicate any provisions of the act or this Part as a local law."
Not merely no conflicting rules. No duplicate rules either. Zoning and fire safety are expressly left alone, and 82.3(d)(1) makes municipal zoning and building compliance part of the registration application, so the local layer sits underneath rather than beside.
On the claim that this is the most prescriptive rulebook in America
We wrote this page expecting to say that, and we are not going to.
We have now read the repair regimes of the fourteen states that license or register repair shops, and Part 82 is the most prescriptive of those by a distance. That is not the same as the most prescriptive in America, which would require reading all 51 jurisdictions' rules rather than the fourteen with a credential to hang them on. States without a licence still regulate disclosure, and one of them could be more exacting on paper than New York without ever issuing a registration.
So the honest claim is the narrower one, and everything above is why we are comfortable with it: colour, dimensions, letter strokes, arc radius, two odometer readings, a bound book with numbered pages, a banned pricing method, a right that cannot be waived by telephone. We have not found that density anywhere else. We have also not looked everywhere.
What we are not saying
- We are not saying Part 82 makes New York repairs better. It is a documentation and disclosure regime. It does not set a repair standard and this page makes no claim about outcomes.
- We are not saying the sign specification is pointless. There is a real anti-counterfeiting reading of it, and we are not in a position to judge which reading is right.
- We are not claiming the 90 day window bars a lawsuit. It is the window for a complaint to the commissioner. Other remedies have their own clocks and we have not traced them.
- We do not claim Part 82 is the most prescriptive rulebook in America. We have read fourteen states. That is the claim we can support.
What we could not verify
- How the arc radius and stroke widths are enforced in practice, if at all. We read the regulation. We did not find inspection or enforcement data on sign compliance.
- Whether the bound airbag log book may be kept electronically. The text says bound, with consecutively numbered pages, which reads as physical. We did not locate a DMV interpretation permitting an electronic equivalent, and we are not asserting one way or the other.
- How the 90 day or 3,000 mile limit interacts with a guarantee the shop gave under 82.5(c). The complaint window and the guarantee term are different instruments and we did not trace how the DMV treats a complaint about a breached guarantee after day 91.
- The current registration fee. CR-82 as published states a ten dollar application fee and a one hundred fifty dollar two-year registration fee per location. Fee schedules change more often than regulations are reprinted and we did not confirm these against a current fee page.
- Whether the air conditioning provision at 82.3(d)(3) is still operative. It carries a compliance date of 1 January 1992 for small shops, which suggests text that has outlived its transition.
Sources
- 15 NYCRR Part 82, read first-party on 2026-08-19 from the New York State Department of Motor Vehicles' own publication CR-82 (5/26), Motor Vehicle Repair Shop Regulations, published by the DMV Division of Vehicle Safety Services, 23 pages. Sections quoted above: 82.1 introduction and stated purposes, 82.2 definitions, 82.3 registration and the exclusions at (b), 82.4 grounds for suspension or revocation, 82.5 obligations, 82.7 signs, 82.8 charges, 82.9 records, 82.10 consumer complaints, 82.11 local law.
- Vehicle and Traffic Law article 12-A, the Motor Vehicle Repair Shop Registration Act, created by Chapter 946 of the Laws of 1974, whose stated purposes Part 82 quotes at 82.1: "to further highway safety by promoting the proper and efficient repair of malfunctioning or disabled motor vehicles, to protect consumers from dishonest, deceptive and fraudulent practices."
- The registration requirement itself, N.Y. Veh. & Traf. Law § 398-c, is quoted and sourced on the fourteen states that license body shops.
- The fourteen states that license body shops
- How to verify a body shop license in New York
- New York's hazardous waste line on your estimate
- How our data is verified
General consumer information: not legal, insurance, or financial advice. Requirements, coverage, and practices vary by state, policy, and manufacturer.