What is the “As Is” Buyers Guide on a used car?

What the Buyers Guide is

Before a dealer offers a used vehicle to a consumer, the rule says it “must prepare, fill in as applicable and display on that vehicle the applicable ‘Buyers Guide’,” placed so that “both sides are readily readable” (16 CFR 455.2(a)). A dealer, for this rule, is a seller that has sold or offered “five (5) or more used vehicles in the previous twelve months,” with exceptions such as banks (16 CFR 455.1(d)(3)).

The form opens with a warning: “IMPORTANT: Spoken promises are difficult to enforce. Ask the dealer to put all promises in writing. Keep this form” (Buyers Guide, Figure 1, 81 FR 81680).

The final form becomes part of your contract: “The information on the final version of the window form is incorporated into the contract of sale,” and “Information on the window form overrides any contrary provisions in the contract of sale” (16 CFR 455.3(b)). The FTC’s example: “if the Buyers Guide says the car comes with a warranty and the contract says the car is sold ‘as is,’ the dealer must give you the warranty described in the Guide” (FTC).

The warranty boxes

• As Is: No Dealer Warranty. The form says, “THE DEALER DOES NOT PROVIDE A WARRANTY FOR ANY REPAIRS AFTER SALE” (Buyers Guide, Figure 1, 81 FR 81680). In the FTC’s words, “You’re assuming the risk of anything that goes wrong after the sale” (FTC).
• Implied Warranties Only. “The dealer doesn’t make any promises to fix things that need repair when you buy the vehicle or afterward. But implied warranties under your state’s laws may give you some rights to have the dealer take care of serious problems that were not apparent when you bought the vehicle” (16 CFR 455.2(b)).
• Dealer Warranty. Marked full or limited, with the systems covered, how long, and the percentage of repair costs the dealer pays (16 CFR 455.2(b)(2)).
• Service Contract. The box notes: “If you buy a service contract within 90 days of your purchase of this vehicle, implied warranties under your state’s laws may give you additional rights” (16 CFR 455.2(b)).

Implied warranties

“Implied Warranties are unspoken, unwritten promises from a dealer to the buyer,” the FTC explains. “If a used car doesn’t come with a written warranty, it’s still covered by implied warranties,” unless it’s an “as is” sale. The FTC adds: “Implied warranty coverage can last as long as four years, although the length of the coverage varies from state to state” (FTC).

Federal law limits when a seller can disclaim them. It can’t if it gives you a written warranty, or if, “at the time of sale, or within 90 days thereafter,” it sells you a service contract on the car (15 U.S.C. 2308(a)). The FTC’s example: “if you buy a service contract covering the engine, you automatically get implied warranties on the engine” (FTC).

States that limit “as is” sales

The rule defers to state law: “If your State law limits or prohibits ‘as is’ sales of vehicles, that State law overrides this part and this rule does not give you the right to sell ‘as is’” (16 CFR 455.2(b)). The FTC’s guidance for dealers explains the alternative form: “In states that limit or prohibit the elimination of implied warranties, you must use the ‘Implied Warranties Only’ version and check the box next to the ‘Implied Warranties Only’ if you don’t offer a written warranty.” In other states, it notes, “‘as is’ sales are allowed only if specific action is taken or certain language is used” (FTC). The FTC doesn’t list the states; it suggests asking your state attorney general what disclosures your state requires for “as is” sales (FTC).

Before you buy

The FTC says that if the “as is” box is checked, “make sure any verbal promises … are written on the Buyers Guide,” including “promises to repair the car or cancel the sale if you’re not satisfied” (FTC). Warranty coverage can be negotiated, “as long as the final warranty terms are identified in the contract of sale and summarized on the copy of the window form you give to the buyer” (16 CFR 455.4). The form itself says, “ASK THE DEALER IF YOUR MECHANIC CAN INSPECT THE VEHICLE ON OR OFF THE LOT,” and “OBTAIN A VEHICLE HISTORY REPORT AND CHECK FOR OPEN SAFETY RECALLS” (Buyers Guide, Figure 1, 81 FR 81680). Recall Check lists a car’s recalls, and How do I check a car for open recalls? covers the VIN search. If a service contract is offered, The finance office and dealer add-ons covers what to ask.

What to say

Before you sign: checklist

State notes

FAQ

Sources

1. 16 CFR 455.1 (eCFR): who is a dealer, (d)(3) (accessed Oct 2026)
2. 16 CFR 455.2 (eCFR): posting the Buyers Guide, (a); the As Is, Implied Warranties Only, dealer warranty and service contract disclosures and state law limiting “as is” sales, (b) (accessed Oct 2026)
3. 16 CFR 455.3 (eCFR): the Buyers Guide is given to the buyer, is part of the contract and overrides contrary terms (accessed Oct 2026)
4. 16 CFR 455.4 (eCFR): negotiated warranty terms go in the contract and on the form (accessed Oct 2026)
5. Federal Register – Used Motor Vehicle Trade Regulation Rule, 81 FR 81664 (Nov 18, 2016), PDF: the As Is Buyers Guide form, Figure 1: the opening warning, the As Is statement, the inspection and recall lines (accessed Oct 2026)
6. FTC – Dealer’s Guide to the Used Car Rule: the two versions of the form; states that limit implied-warranty disclaimers; Maine and Wisconsin (accessed Oct 2026)
7. FTC – Buying a Used Car From a Dealer: what the Guide covers; as is and implied warranties; promises in writing; service contracts within 90 days; Maine and Wisconsin forms; no federal three-day return (accessed Oct 2026)
8. 15 U.S.C. 2308 (U.S. Code, 2024 ed., govinfo): no disclaimer of implied warranties with a written warranty or a service contract within 90 days, (a) (accessed Oct 2026)
9. Cal. Civ. Code 1784.43: three-day right to cancel for used vehicles at $50,000 or less, the 400-mile limit and the restocking fee, (a); operative Oct 1, 2026 (accessed Oct 2026)

About this guide

This page is general information about federal rules, and some state rules, as of October 2026. It isn’t legal advice. Your contract and the law control, including your state’s law, and the law can change. If the Buyers Guide doesn’t match what the dealer told you, ask for the difference in writing.