Dealer addendum disclosures in 2026: what changed and what didn't

Short version: the FTC's CARS Rule never took effect and was formally withdrawn in February 2026. But dealers still face federal scrutiny of how prices and add-ons are presented, and California's own CARS Act took effect on October 1, 2026. For dealer addendums, the practical rule hasn't changed: every add-on should be clearly listed with its price, and the price a shopper sees should be one they can actually pay.

What happened to the FTC CARS Rule

The FTC finalized the Combating Auto Retail Scams (CARS) Rule in late 2023. It would have restricted misrepresentations about vehicle pricing and add-on products and required specific disclosures.

The rule never reached its compliance date:

• January 2025. The U.S. Court of Appeals for the Fifth Circuit vacated the rule, holding that the FTC failed to follow its own procedural requirements when it skipped an advance notice of proposed rulemaking.
• February 2026. The FTC formally withdrew the rule through a notice in the Federal Register, conforming its regulations to the court's decision.

If you see a vendor or article describing the CARS Rule as current federal law, it's out of date.

What still applies at the federal level

The CARS Rule's withdrawal didn't change the FTC's underlying authority. Section 5 of the FTC Act prohibits unfair or deceptive acts and practices, and the agency continues to apply it to dealers.

In March 2026, the FTC sent warning letters to 97 auto dealership groups about their price advertising. The concerns it raised included:

• Advertised prices that leave out mandatory fees
• Prices that depend on rebates or discounts not every buyer qualifies for
• Prices that require dealer financing or a specific down payment
• Requiring buyers to purchase additional items not reflected in the advertised price

That last point is the one closest to the addendum. If products are already installed and the dealership requires them, the advertised price and the addendum need to tell the same story.

The FTC Used Car Rule also remains in force, which means used vehicles offered for sale still need a Buyers Guide, whether or not they carry an addendum.

California's CARS Act (SB 766)

California passed its own Combating Auto Retail Scams Act (SB 766), effective October 1, 2026, for licensed dealers selling or leasing light-duty vehicles. Among its provisions:

• Dealers may not misrepresent an add-on's benefits, limits, or cost.
• Add-ons that provide no benefit to the consumer are prohibited.
• Dealers must clearly disclose the offering price and state that buying an add-on is voluntary.
• Dealers must keep compliance records for two years.

Other states have their own consumer protection laws and dealer regulations, and more may follow California. Check the rules where each of your rooftops operates.

What this means for your addendum

These are practical habits, not legal advice:

1. List every add-on with its own price. Bundled "protection packages" with a single number are harder to defend than an itemized list.
2. Make sure the product was actually installed. Only list what's on the vehicle.
3. Keep wording consistent across vehicles. The same package should carry the same description and disclosure on every car.
4. Align the addendum with your advertising. If the online price doesn't include the addendum total, make sure that's clear and lawful in your market.
5. Keep a record of what you printed. If a buyer or regulator asks what was on a specific vehicle's sticker, you should be able to show it. California now requires two years of records.

How QP Addendums supports a controlled process

QP Addendums doesn't give legal advice, and it doesn't decide which add-ons your dealership sells. What it does is take retyping and improvised wording out of the sticker:

• The disclosure block is fixed. Every sticker carries the same disclosure text: that the addendum was added by the dealer, not the manufacturer, and what the price excludes. Nobody edits it vehicle by vehicle.
• Products are itemized with their prices, pulled from your store's product list rather than typed in each time.
• Every print is saved, so you can look up what was printed for a vehicle and when.
• Three roles, Group Admin, Store Admin, and Print User, separate the people who manage products and pricing from the people who print.

Learn more about how QP Addendums handles controls.