Monroney Label Mistakes to Watch for During Year End Car Sales

by Matthew P. Suzor and Alden Hey

During end-of-year clearance events, dealerships often advertise aggressive discounts to clear out older inventory—but rushed sales can also lead to inaccurate or outdated Monroney labels. If the window sticker misrepresents equipment, safety ratings, or pricing, consumers may have legal recourse under federal and state consumer protection laws. Miller Shah LLP helps buyers understand their rights and recover damages when misleading vehicle labels result in financial harm.

What is a Monroney Label and Why Does it Matter in Year-End Car Sales?

A “Monroney label” refers to the window sticker that appears on new cars at car dealership. The name comes from the  Automobile Information Disclosure Act of 1958 (the “Monroney Act”), which required automakers to disclose certain information on a label affixed to every new car. This does not apply to used cars. By law, manufacturers are required to make “true and correct” disclosures of the following information:

• The manufacturer’s suggested retail price (MSRP)

• The make, model and Vehicle Identification Number (VIN)

• The final assembly point

• The name and location of the dealer to whom the vehicle is being delivered

• Environmental Protection Agency (EPA) fuel-economy data

• Safety ratings

This kind of information is critical to a car buyer’s determination of whether to take advantage of a year-end sale on a car. While these are examples of legally required information to be included on the label, manufacturers and dealerships oftentimes include other information to help advertise the car’s features. This can include the engine, color, interior material, trim level, or any other detail that might vary from one car to another.

How Can Consumers Spot Errors or Omissions on Window Stickers?

Car buyers can avoid falling victim to mislabeled cars this holiday season by researching the car they are considering buying independent of the information displayed at the dealership. The most common way to search for a specific car is through the VIN, which can be found on the driver’s side dashboard and driver’s side door jam. Many vehicle evaluation companies, including J.D. Power, offer a free VIN-lookup website where you can confirm all of the details advertised on a car’s label.

If the incorrect information on a Monroney label is derived from incorrect information attached to a car’s VIN, this could be ineffective. In such a case, confirming the make, model, trim, and packages on a car could be a more effective way of researching which features a given car has. If, for example, a car has the base model badge, a label that advertises the top-trim engine is likely incorrect.

What are Common Mistakes Dealers or Manufacturers Make During High-Volume Sales Periods?

While all cars are required by law to be properly labeled, small mistakes can often mean the difference between purchasing and not purchasing a car at the listed price. Mistakes will typically occur in sections on a car label with high variance between individual cars such as color, VIN number, engine, transmission, or accessories such as speaker or infotainment systems. Because of the massive amount of inventory being sent out during the holiday season, mistakes can and will occur in the labelling of new cars—potentially misleading consumers.

In July 2025, a class action lawsuit was filed in the Northern District of Illinois alleging that Mazda promised an “8-speaker audio system” and “HD radio” on Mazda3 models that contained 6-speaker audio systems and standard definition radios. These kinds of high variance, trim-dependent mistakes can be even more common during high-volume sales periods like the holiday season.

What Laws Protect Consumers from Misleading Monroney Labels or Window Stickers?

Since the passing of the Automobile Information Disclosure Act in 1958, various additional disclosure requirements have been developed through subsequent legislation. One example is the New Car Assessment Program (NCAP), which established National Highway Traffic Safety Administration (NHTSA) standards for determining safety ratings alongside requirements for these safety ratings to be displayed on new car labels.

Incorrect or misleading information on Monroney labels is policed through Section 5 of the Federal Trade Commission (“FTC”) Act, which federally prohibits “unfair or deceptive acts or practice in or affecting commerce” under 15 U.S. Code § 45. Additionally, various states have passed legislation prohibiting false or misleading advertising (e.g. Illinois). False advertising class actions will oftentimes combine federal statutes with state-level deceptive or unfair trade practices laws.

What Types of Damages or Remedies Are Available in Monroney Label Misrepresentation Cases?

Monroney label misrepresentation cases, or any other false advertising case, have a variety of damages available to class members. The first and typically largest form of damages are actual damages, which include any difference between what consumers would have paid and what consumers did pay based on the false advertising. Plaintiffs may also seek restitution damages for unjust enrichment. Additionally, federal agencies like the Federal Trade Commission (FTC) may also seek statutory penalties on a per-advertisement basis.

While more common in false advertising cases launched by competing firms, a preliminary injunction may be filed against the manufacturer requiring they pause the alleged false advertising until the case has reached a conclusion. If a false advertising case is successful, a permanent injunction will almost always be ordered as part of the relief.

How can Miller Shah Assist if You Overpaid Due to False Advertising on a Vehicle Label?

If you believe you have overpaid for a vehicle based on incorrect information on a Monroney label, Miller Shah LLP can represent you. By holding manufacturers that engage in false advertising accountable, consumers can both support fellow car-buyers that were harmed by false advertising and hold violators accountable.

Miller Shah has an extensive track record of investigating, litigating, and winning false advertising cases. By retaining our team of experienced and diligent attorneys, you maximize both your chance of victory and the size of your settlement. If you believe that you could have been victim to false advertising or need legal representation in another matter, fill out the form below for a free consultation and one of our attorneys will reach out to you shortly for a free consultation.