OEM Position Statements as the New Standard of Care

Key findings

1. 1Seebachan v. John Eagle (2017, $42M verdict) established OEM repair procedures as evidence of standard of care in U.S. collision-repair negligence litigation.
2. 2Honda/Acura, Toyota/Lexus, Ford, GM, Hyundai/Kia, Nissan/Infiniti, BMW, and Tesla all maintain published position statements that mandate pre- and post-scan on virtually all collision-damaged vehicles.
3. 3OEM position statements covering ADAS calibration are converging on a uniform requirement: any R&I or replacement of a sensor-bearing component triggers calibration before vehicle return.
4. 4Refusal to fund OEM-mandated procedures has supported bad-faith claim development in multiple state jurisdictions; the documentation trail is decisive.
5. 5A shop's defensible position and a carrier's defensible position are the same position: the OEM procedure, paid as written, documented as performed.

Body

1. The case that changed everything

Seebachan v. John Eagle Collision Center is the case every shop and every adjuster should know by name. Dallas County, Texas, 2017. A body shop replaced the roof on a 2010 Honda Fit using adhesive instead of the spot welds Honda's procedure called for. The car was later in another collision. The driver and passenger were severely burned. The expert testimony was straightforward: the bonded roof had compromised the vehicle's crash structure. The jury came back with a $42 million verdict.

Before Seebachan, OEM repair procedures were widely treated as guidance — useful but optional. After Seebachan, they became evidence. Cases in Florida, Mississippi, and California have all moved in the same direction since: where the OEM publishes the procedure and the repair deviates from it, the deviation is the cause of action. SCRS and ASA both have formal positions saying the OEM procedure is the right reference for the repair plan. I-CAR's RTS database puts the procedures in one searchable place, and adjusters and estimators alike are quoting it routinely now.

2. The position statements that move the most dollars

Out of every position statement an OEM publishes, a small handful drive most of the dollar impact on a modern estimate. The big ones, in rough order of how often they show up in disputes:

Pre-repair and post-repair vehicle scan

Honda/Acura, Toyota/Lexus, Ford, FCA, GM, Hyundai/Kia, Nissan/Infiniti, and Volkswagen Group have all published position statements requiring a pre-repair scan on any collision-damaged vehicle and a post-repair scan before returning the vehicle to the customer. The scope is substantively the same across the corpus: the scan is required, the documentation is required, and the resulting fault codes drive the supplement pipeline.

ADAS calibration after R&I

Most OEMs now mandate calibration of forward-facing cameras, front and rear radar, blind-spot radar, and surround-view cameras whenever the carrying component is removed and reinstalled — even if no parts are replaced. Toyota, Honda, Subaru, and Nissan have particularly explicit windshield-camera calibration requirements when glass is replaced.

Sectioning restrictions and foam replacement

OEMs publish sectioning maps that designate where structural members may and may not be cut. They also publish foam-replacement requirements (most notably for cavity foam in the rocker, A-pillar, and B-pillar) that are routinely missed on initial estimates and become supplements after teardown.

Pull and measurement documentation

Major OEMs require that any structural straightening operation be measured, documented, and recorded against the OEM's published dimensional data. The documentation is the difference between a defensible structural repair and an undefendable one.

3. What the position statement actually requires

The single most common operational mistake in 2026 estimating is treating an OEM position statement as a coverage question rather than a procedure question. The position statement does not say 'calibration may be appropriate'; it says 'calibration is required after this triggering event, performed in the following way, documented as follows.' The estimate is the operational response to the procedure, not a venue to negotiate it.

4. The carrier perspective

From a carrier's perspective, paying for an OEM-mandated procedure is rarely the expensive outcome. The expensive outcomes are bad-faith development on a refusal, indemnity exposure on an inadequate repair, and customer-experience damage from a re-supplemented vehicle that returns for fault-code work two weeks after pickup. The line-item exposure of paying scan plus calibration is bounded; the systemic exposure of refusing it is not.

Operationally, the highest-leverage carrier intervention is not deeper line-item scrutiny on calibrations that are not optional in the first place. It is faster authorization on the published procedure, paired with documentation requirements that are clear at write-up. A shop that knows what evidence the carrier requires can attach it once; a shop that does not will iterate the supplement three times.

5. The shop perspective

From a shop's perspective, the OEM procedure is both protection and product. It is protection because deviation is the basis of liability; it is product because the procedure is what the customer is buying. Documenting compliance with the procedure — pre/post-scan reports, calibration reports, measurement logs, sectioning notes — is the artifact that sustains the repair against later challenge.

The estimating practice that follows is straightforward: every line that is required by an OEM position statement should be written at write-up, cite the procedure on the line note, and attach the documentation as soon as it exists. Lines that are not in the procedure should not be written at all. The result is an estimate that defends itself, paid as written, faster than the negotiated alternative.

Frequently asked

Citations

1. [1]Seebachan v. John Eagle Collision Center, Dallas County, Texas, 2017 ($42M jury verdict, settled post-verdict).
2. [2]Society of Collision Repair Specialists, position on OEM repair procedures as the appropriate reference for the repair plan.https://scrs.com
3. [3]Automotive Service Association, position statements on OEM repair procedures and standards of repair.https://asashop.org
4. [4]I-CAR Repairability Technical Support (RTS) database — aggregated OEM repair procedures and position statements.https://rts.i-car.com
5. [5]OEM1Stop.com — consortium repair-procedure portal: Honda/Acura, Toyota/Lexus, Ford, GM, Hyundai/Kia, Nissan/Infiniti, BMW, Volkswagen Group, Volvo, Subaru, Mazda, Tesla.https://www.oem1stop.com
6. [6]Honda/Acura position statement on pre- and post-repair scanning of collision-damaged vehicles.
7. [7]Repairer Driven News, ongoing coverage of OEM-procedure case law and position-statement updates.https://www.repairerdrivennews.com

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.

← Back to all research