Non-OEM Parts Disclosure on Canadian DRP Claims: What Shops Owe the Customer at Write-Up
How MPI, SGI, and private-carrier DRP rules treat aftermarket, recycled, and remanufactured parts - and what must be itemized on the estimate before repairs begin.
Authors
Myles Chaput & Ali Jakvani
Published
Length
12 min read
Abstract
Canadian DRP programs - including MPI's Light Vehicle Accreditation Agreement (LVAA), SGI's Accredited Repair Program, and private-carrier DRPs from Intact, Aviva, Wawanesa, and Definity - all require that replacement parts be classified and disclosed on the estimate as new OEM, aftermarket, recycled, or remanufactured. Recent US legislative activity (notably New York's 2026 OEM-parts bills) has renewed scrutiny on whether customers receive proper notice of part type, warranty implications, and price comparability. This article maps how Canadian programs handle aftermarket-parts disclosure today, where shops most often fall short at write-up, and how the line items, parts source, and customer authorization should be structured before a single bolt is removed. Limited recent source material was available for this topic; where current public bulletins were not located, the article relies on standing program documents and cross-references US developments to flag likely directional changes.
Key findings
- 1Every Canadian DRP program requires part-type classification (OEM, aftermarket, LKQ/recycled, reman) on the estimate; what varies is the disclosure language, the customer-signature requirement, and the warranty pass-through obligation.
- 2MPI's LVAA framework directs accredited shops to use the parts hierarchy specified in the estimate authorization; deviation without prior approval triggers chargebacks during audit.
- 3SGI's Accredited Repair Program emphasizes Realized Parts Savings (RPS) on alternative parts; shops that fail to document why a non-OEM part was rejected (fit, finish, availability) lose program credit and risk supplement denial.
- 4US activity, including New York Assembly bills introduced in January 2026, would require itemized part-type notice and explicit consumer consent before non-OEM parts are installed - a model Canadian carriers are watching.
- 5Documentation failures at write-up (missing part-type codes, no customer signature on parts authorization, no rejection rationale for aftermarket alternatives) are the single largest source of avoidable parts-related chargebacks on Canadian DRP audits.
Body
1. What non-OEM parts disclosure means on a Canadian DRP claim
Non-OEM parts disclosure is the requirement that every replacement part on the estimate be classified by source - new OEM, certified aftermarket, recycled (LKQ), or remanufactured - and that the customer be informed in writing before the part is ordered or installed. On a Canadian DRP claim, the obligation sits with both the insurer (which specifies the parts hierarchy in the program agreement) and the accredited shop (which writes the estimate and obtains the customer authorization). The disclosure is not optional language; on MPI, SGI, ICBC, and most private-carrier DRPs, it is a condition of the repair authorization.
The classification matters because each part type carries a different warranty path, a different liability profile, and a different cost basis. Aftermarket sheet metal is warranted by the distributor (often CAPA or NSF certified); recycled assemblies carry no manufacturer warranty beyond the yard's policy; remanufactured mechanical parts carry a remanufacturer warranty distinct from the OEM. If the estimate does not distinguish these on the printed copy the customer signs, the shop has not met the disclosure standard - regardless of whether the part performs adequately.
2. How MPI treats aftermarket and alternative parts under the LVAA
MPI's Light Vehicle Accreditation Agreement (LVAA) governs how accredited shops in Manitoba handle part selection. The program specifies a parts hierarchy that shops are expected to follow when writing estimates in Mitchell Connect: OEM where required by procedure or vehicle age, certified aftermarket where available and equivalent, and recycled assemblies where appropriate for the damage profile. MPI's Body Shop & Glass Information portal publishes program bulletins outlining when each tier applies and how alternative parts should be priced and documented.
The disclosure obligation runs through the estimate itself. Each replacement line must carry a part-source indicator, and the customer's signed authorization references the parts list as written. If an aftermarket part is later rejected for fit and replaced with OEM via supplement, the supplement must document the rejection reason - photographs of fit issues, gap measurements, or finish defects. MPI audit teams flag claims where supplements move parts up the hierarchy without that documentation, treating the upgrade as a discretionary cost rather than a program-authorized one.
3. How SGI's Accredited Repair Program scores alternative parts use
SGI's Accredited Repair Program tracks Realized Parts Savings (RPS) - the dollar value of alternative parts (aftermarket, recycled, reman) actually installed versus the OEM equivalent. RPS is a program-scorecard metric in Saskatchewan and influences accreditation standing. Shops that consistently default to OEM without documenting why an alternative was not viable lose RPS points; shops that install alternative parts but fail to disclose the part type to the customer create a separate exposure if the customer disputes the repair later.
SGI's bulletins direct shops to record availability searches, fit verification, and any rejection rationale within the claim file. The estimate the customer receives must list each part with its source category. If an aftermarket bumper cover is specified, the line should read accordingly; if it is later swapped to OEM, the supplement must justify the change. This is the same documentation discipline MPI applies, expressed through a slightly different program framework.
4. How private Canadian DRPs (Intact, Aviva, Wawanesa, Definity) handle parts disclosure
Private-carrier DRPs in Canada generally require parts classification on the estimate and customer authorization before alternative parts are installed, but the specific language and enforcement vary by carrier. Most carrier program manuals mirror the LKQ/aftermarket/reman/OEM nomenclature used in CCC ONE and Mitchell Connect and require the printed estimate to itemize part type. Where private DRPs diverge from MPI and SGI is in how aggressively they enforce alternative-parts use through scorecards versus how flexibly they allow OEM substitution on newer vehicles.
| Program | Part-Type Itemization | Customer Signature Required | Alternative-Parts Scorecard | Upgrade Documentation |
|---|---|---|---|---|
| MPI (LVAA) | Yes - on estimate | Yes - authorization references parts list | Tracked via audit | Photo + rationale required |
| SGI Accredited Repair | Yes - on estimate | Yes | RPS metric (formal) | Availability + fit notes required |
| ICBC c.a.r. shop | Yes - on estimate | Yes | Tracked via program scorecards | Documented rejection required |
| Intact / Aviva / Wawanesa DRP | Yes - per program manual | Yes | Varies by carrier | Supplement rationale required |
5. What the US picture tells Canadian shops about where disclosure rules are heading
US legislative activity in early 2026 signals where North American parts-disclosure standards are likely to tighten. According to Repairer Driven News, New York Assembly bills introduced in January 2026 would require insurers to notify customers in writing of each replacement part's classification - new OEM, aftermarket, recycled, or remanufactured - and would restrict non-OEM part use during the manufacturer's warranty period without explicit consent. California's Insurance Code (CCR 2695.8(g)) already requires that non-OEM parts be of like kind and quality and that the consumer be notified.
Canadian programs already require itemization on the estimate, but the trend in US legislation toward explicit per-part consumer notice and warranty-period restrictions is directionally relevant. Carriers operating cross-border (Intact, Definity, Aviva) and OEM certification networks that span both countries tend to harmonize procedures over time. Shops that build write-up workflows around explicit per-line part-type disclosure now will be ahead of any tightening that follows.
| Jurisdiction | Itemization on Estimate | Customer Notice Required | Warranty-Period OEM Mandate |
|---|---|---|---|
| Manitoba (MPI LVAA) | Required | Via signed estimate | Procedure-driven, not statutory |
| Saskatchewan (SGI) | Required | Via signed estimate | Procedure-driven |
| British Columbia (ICBC) | Required | Via signed estimate | Program-driven |
| California (CCR 2695.8(g)) | Required | Required - LKQ notice | Like kind and quality standard |
| New York (2026 bills, pending) | Would be required | Would be required per part | Proposed during OEM warranty |
6. Where shops typically lose ground on parts disclosure
The most common failure is not part selection - it is documentation at write-up. Shops choose the right part for the job, install it correctly, and warranty it appropriately, but the printed estimate the customer signed did not specify the part type, the supplement did not justify the upgrade from aftermarket to OEM, or the photograph supporting the rejection was never uploaded to the claim file. On audit, those gaps become chargebacks.
- Generic part descriptions on the estimate that do not indicate source category (no LKQ, AM, RM, or OEM tag on the line).
- Customer authorization signed against a parts list that was later changed by supplement without re-disclosure.
- OEM upgrades after aftermarket rejection with no rejection photo, no gap measurement, no fit narrative in the file.
- Recycled assemblies billed without the donor VIN, mileage, or yard warranty terms attached to the claim.
- Remanufactured mechanical parts billed without the reman warranty document available for the customer at delivery.
- Missing availability search records when a non-OEM alternative was specified by the program but not used.
7. How RocketPros aligns to non-OEM parts disclosure
RocketPros runs alongside Mitchell Connect and CCC ONE and surfaces parts-disclosure completeness signals at write-up. The published program rules - MPI's LVAA bulletins, SGI's RPS framework, the private-carrier DRP manuals - remain the source of truth. RocketPros makes compliance with those rules mechanical by checking, on every estimate, that each replacement line carries a part-type classification, that the customer authorization is captured against the current parts list, and that any later upgrade carries the supporting documentation the program expects.
- Per-line part-type check: confirms each replacement part is tagged as OEM, AM, LKQ, or RM before the estimate is locked.
- Authorization-versus-actuals reconciliation: flags when an installed part differs from the part the customer signed for.
- Supplement rationale check: prompts the estimator for the photo or note required when a line moves up the parts hierarchy.
- Program-aligned signaling: surfaces MPI, SGI, and ICBC parts-hierarchy expectations at write-up rather than after audit.
- Claim-level reporting back to the shop: shows parts-disclosure completeness rates and where supplements consistently lack documentation.
8. The carrier perspective: why parts disclosure matters to MPI and SGI program managers
From the carrier side, parts disclosure is both a consumer-protection obligation and an audit-cost driver. When part type is consistently itemized on the estimate and customer authorization is captured cleanly, program managers spend less time adjudicating disputed supplements and fewer claims require post-delivery rework. When disclosure is inconsistent, the carrier inherits the reputational and regulatory risk of a customer who believed an OEM part had been installed when an aftermarket part actually was - and the shop inherits the chargeback.
Program managers at MPI and SGI use parts-related audit findings to calibrate accreditation standing and to prioritize shop-level coaching. Shops with clean disclosure records compete more favorably for severity mix and program access; shops with chronic gaps face escalating audit attention. The trend in US legislation toward per-part consumer notice reinforces what Canadian programs already require - and signals that the documentation standard is unlikely to relax.
Implications
For shop owners and estimators
- Audit the printed estimate template: confirm part-type classification (OEM, AM, LKQ, RM) prints on every replacement line before customer signature.
- Build a write-up checklist that requires availability search, fit rationale, and photo capture before any line is changed by supplement.
- Train estimators to treat the customer authorization as a parts-specific document, not a generic repair authorization.
- Retain donor VIN, mileage, and yard warranty terms for every recycled assembly and attach them to the claim file.
- Reconcile installed parts against the authorized parts list at delivery; resolve any discrepancy in writing before keys-to-keys.
- Track parts-disclosure completeness as a shop-level KPI alongside cycle time and supplement frequency.
For insurance carriers
- Reinforce part-type itemization expectations in program bulletins and audit guides; consistency across MPI, SGI, ICBC, and private DRPs reduces shop confusion.
- Use parts-disclosure completeness as a leading indicator in shop scorecards; it correlates with supplement quality and customer satisfaction.
- Monitor US legislative developments (New York, California precedent) for directional cues on per-part notice and warranty-period OEM mandates.
- Provide clear rejection-documentation standards (photo, gap measurement, fit narrative) so shops know what supports an OEM upgrade.
- Coach repeat-offender shops on write-up discipline before escalating to formal accreditation review.
Frequently asked
Do MPI and SGI require customer signature on the parts list itself, or just the repair authorization?+
Both programs require the customer authorization to reference the estimate as written, which includes the itemized parts list with source classification. In practice, the customer signs a repair authorization that incorporates the printed estimate by reference. If the parts list changes after that signature - for example, an aftermarket part is upgraded to OEM via supplement - the change must be documented in the file with rejection rationale, and most programs expect the customer to be informed of the change. The signature on the original authorization does not cover undisclosed substitutions.
What is the difference between aftermarket, recycled, and remanufactured parts in terms of disclosure?+
Aftermarket parts are new replacement parts produced by a manufacturer other than the OEM, often CAPA or NSF certified for fit and finish. Recycled (LKQ) parts are used assemblies harvested from donor vehicles, typically with a yard warranty rather than a manufacturer warranty. Remanufactured parts are used cores rebuilt to a defined standard, common for mechanical components like alternators and steering racks. Each must be itemized separately on the estimate with its own line code and warranty terms disclosed to the customer.
Can a Canadian customer demand OEM parts even when the DRP specifies aftermarket?+
Generally yes, but the customer typically pays the price difference. Most Canadian DRP programs - MPI, SGI, and private-carrier programs - specify a parts hierarchy that the insurer will pay for. If the customer prefers OEM where the program authorizes a certified aftermarket equivalent, the shop documents the customer's election and the cost difference becomes a customer-pay line. The disclosure works in both directions: the shop must inform the customer of what the program covers, and the customer's election must be captured in writing before parts are ordered.
How does the New York 2026 OEM-parts legislation affect Canadian shops?+
It does not affect Canadian shops directly, but it signals where North American disclosure standards are heading. According to Repairer Driven News reporting in January 2026, the New York bills would require per-part consumer notice and restrict non-OEM use during the OEM warranty period. Canadian carriers operating cross-border and OEM certification networks tend to harmonize procedures over time. Shops that already build per-line part-type disclosure into their write-up workflow will be aligned with any tightening that follows in Canadian programs.
What documentation supports an OEM upgrade after an aftermarket part is rejected for fit?+
At minimum: a photograph showing the fit or finish defect (panel gap, surface irregularity, mounting-point misalignment), a written narrative describing the rejection, gap measurements where relevant, and the availability search confirming whether a second aftermarket source was checked. The supplement should reference these in the line note. MPI and SGI audit teams treat undocumented upgrades as discretionary costs that may be charged back, even when the OEM upgrade was operationally correct.
Does RocketPros decide what part type to use?+
No. The carrier program rules and the OEM procedure decide what part type is appropriate. RocketPros runs alongside Mitchell Connect or CCC ONE and surfaces whether the estimate has the disclosure elements the program expects - part-type tag on each line, customer authorization tied to the current parts list, rejection documentation when a line is upgraded. The published program rules and OEM position statements remain the source of truth; RocketPros makes compliance with those rules mechanical at write-up.
Citations
- [1]Repairer Driven News - New York bills require OEM parts through warranty and consumer notification of crash part type (January 14, 2026).https://www.repairerdrivennews.com/2026/01/14/new-york-bills-require-oem-parts-through-warranty-and-consumer-notification-of-crash-part-type/
- [2]California Department of Insurance - Bulletin on Insurer Designations Involving Original Equipment Manufacturer (OEM) Parts.https://www.insurance.ca.gov/0250-insurers/0300-insurers/0200-bulletins/bulletin-notices-commiss-opinion/upload/InsurerDesignationsInvolvingOriginalEquipmentManufacturer-OEM-Parts.pdf
- [3]California Code of Regulations 2695.8(g) - Non-original equipment manufacturer parts requirements and consumer notice.https://www.insurance.ca.gov/0250-insurers/0300-insurers/0200-bulletins/bulletin-notices-commiss-opinion/CCR2695-8g.cfm
- [4]Manitoba Public Insurance - Body Shop & Glass Information portal (program documents, bulletins, accreditation framework, Light Vehicle Accreditation Agreement (LVAA)).https://www.mpi.mb.ca/
- [5]SGI - Accredited Repair Program documentation, including Realized Parts Savings (RPS) framework and accreditation standards.https://www.sgi.sk.ca/
- [6]Insurance Corporation of British Columbia (ICBC) - c.a.r. shop program standards and parts-use guidance.https://www.icbc.com/
- [7]Insurance Bureau of Canada (IBC) - consumer information on auto insurance claims and replacement parts.https://www.ibc.ca/
- [8]Society of Collision Repair Specialists (SCRS) - guidance on non-OEM parts use, customer disclosure, and like kind and quality standards.https://www.scrs.com
- [9]I-CAR Repairability Technical Support - OEM position statements on parts selection and structural repair.https://rts.i-car.com/
- [10]Craftsman Collision - consumer-facing explainer on OEM versus aftermarket parts in Canadian insurance claims.https://craftsmancollision.com/news/does-insurance-cover-oem-parts/
- [11]CCC Intelligent Solutions, Crash Course Report - parts mix trends and alternative-parts utilization benchmarks.https://cccis.com
- [12]Canadian Collision Industry Forum (CCIF) - industry briefings on parts procurement and DRP program evolution.https://www.ccif.ca/
What this looks like inside RocketPros
The audit logic, scoring, and documentation patterns in this paper map directly to four RocketPros modules. If you want this applied to your shop's real estimates, start with the module that fits the workflow you're trying to fix.
- RPS ComplianceTrack MPI, SGI, and DRP program risk before it affects scorecards.
- Estimate AnalysisCatch missed labor, materials, parts, and documentation gaps before submission.
- AutomationRead saved Mitchell, CCC, and Audatex files without manual upload.
- ADAS CalibrationSurface calibration triggers tied to sensors and OEM procedures.
Figures cited from CCC Crash Course, Mitchell Industry Trends, IIHS-HLDI, AAA Foundation, BLS, Statistics Canada, IBC, and provincial insurer reports are sourced from those organizations' published materials. Where RocketPros corpus analysis is referenced, it reflects aggregated estimate data across the platform's customer base and is presented for directional accuracy. Nothing in this paper constitutes legal, regulatory, or coverage advice. RocketPros is independent software and is not endorsed by or affiliated with MPI, SGI, ICBC, SAAQ, or any private auto insurer.