Most repair shop disputes start with the estimate. A customer expects one number and the invoice shows another. A technician finds a second problem after teardown and the approval call is never documented. A shop holds a car for payment and learns it had no right to. In Washington, these situations are governed by a specific law, the Automotive Repair Act, chapter 46.71 RCW, and a shop that does not follow it can lose the right to collect, lose its lien and face a Consumer Protection Act claim. This guide walks through what the law requires and how to build estimating habits that prevent disputes.
General information, not legal advice
This summary is based on the statute as published by the Washington State Legislature. Have your attorney review your estimate and repair order forms. Shops outside Washington should check their own state's rules.
What Washington's Automotive Repair Act requires
A written estimate, or a signed choice
Under RCW 46.71.015, all estimates that exceed $100 must be in writing. Under RCW 46.71.025, before providing parts or labor the shop must give the customer a written price estimate of the total cost of the repair, including parts and labor, or offer the alternatives printed on the form. The customer indicates a choice by signing or initialing. The three alternatives are:
- A written estimate before repairs begin, with a call if the price will exceed it by more than ten percent.
- Proceed with repairs, with a call if the price will exceed a dollar amount the customer specifies.
- No written estimate ("I do not want a written estimate").
What the estimate must show
RCW 46.71.015 lists the information the estimate must include:
- The date, and the shop's name, address and telephone number.
- The customer's (or designee's) name, address and telephone number, if available.
- If the vehicle is delivered for repair: year, make and model; license plate number or the last eight digits of the VIN; and the odometer reading.
- A description of the problem the customer reported or the specific repairs requested.
- The customer's choice among the alternatives above.
The 110 percent rule
A shop may not charge more than 110 percent of the written estimate total, excluding retail sales tax, unless the customer gives oral or written authorization before the additional parts or labor are provided. For example, as WashingtonLawHelp.org illustrates, a $200 estimate could rise to $220 without further approval.
Documenting authorization the right way
Phone approvals are allowed, but the statute requires them to be written down. When a customer authorizes additional work orally, the shop must note on the estimate:
| Record this | Why it matters |
|---|---|
| Date and time of the authorization | Shows approval came before the extra work |
| Additional parts and labor authorized | Defines exactly what was approved |
| Estimated cost of the additional work | Sets the new amount the customer agreed to |
| Employee name or ID number | Identifies who took the call |
| Name and telephone number of the person authorizing | Confirms who approved, especially if it was not the owner |
When a vehicle is dropped off without face-to-face contact, such as an after-hours key drop, no written estimate is required, but authorization is still required before work begins. The shop must note on the estimate or repair order the date and time of the oral authorization, the total amount authorized, the employee's name or ID number, and the name of the person who authorized the repairs.
Texts and emails
Many shops now send estimates and supplements by text or email. A written reply from the customer is good evidence, but your record should still capture every item the statute lists. Save the messages to the repair order, and have your attorney confirm your electronic approval process.
Our article on written repair authorization covers form design and approval workflows in more detail.
Invoices, replaced parts and the customer rights sign
Invoices
Under RCW 46.71.015, when repairs are complete the customer must receive an invoice that includes the estimate information, a description of the services performed, and a list of parts with names and part numbers where available. The invoice must state whether parts are rebuilt or used, and whether body parts are aftermarket or non-OEM, where applicable. It must show the price per part, the total parts charge, the total labor charge and the total charge. Parts and labor need not be separated for advertised specials, predisclosed menu pricing or routine service packages, and warranty or no-charge work needs only a parts list or service description.
Replaced parts
Under RCW 46.71.021, if the customer asked for replaced parts when authorizing the repair, the shop must return them, unless a warranty or return-to-distributor arrangement applies. If a part must be returned to a manufacturer, remanufacturer, distributor, recycler or rebuilder, or disposed of by law, the shop must offer to show it to the customer. Tag and hold requested parts until the customer picks up the vehicle.
The sign
RCW 46.71.031 requires one or more signs, in a prominent place readily visible to customers, with the "YOUR CUSTOMER RIGHTS" text. The first line must be at least one and one-half inches tall and the remaining lines at least one-half inch. Check that your sign matches the current statutory wording.
What is at stake if the rules are not followed
- Collection limit. Under RCW 46.71.035, a shop that fails to meet the estimate requirements cannot recover more than 110 percent of the authorized amount, unless it proves its conduct was reasonable, necessary and justified. The court may award costs and attorneys' fees to the prevailing party.
- Loss of lien. Under RCW 46.71.041, a shop that fails to comply with the replaced-parts, estimate or sign requirements cannot assert a possessory or chattel lien for the unauthorized parts or labor. Holding the car may not be an option.
- Consumer Protection Act exposure. Under RCW 46.71.070, violations are unfair or deceptive acts under chapter 19.86 RCW.
- Prohibited practices. The Act also prohibits practices such as charging for parts not installed or labor not performed, misstating estimates and charging for unnecessary repairs, as WashingtonLawHelp.org summarizes.
WashingtonLawHelp.org also notes that shops must keep estimates and invoices for one year and provide copies on request, and under RCW 46.71.045 a customer may request a copy of any document they signed at no charge.
Estimating habits that prevent disputes
- Write the customer's words. Record the complaint as the customer described it, not as a diagnosis.
- Separate diagnosis from repair. Estimate and authorize diagnostic time first, then estimate the repair once you know what is needed.
- Flag the unknowns. If teardown may reveal more, say so on the estimate and explain how you will contact the customer.
- Use one approval workflow. Every service advisor should record approvals the same way, every time.
- Disclose parts choices. Note OEM, aftermarket, used or rebuilt parts on the estimate. See parts liability.
- Document condition at drop-off. Walk-around photos protect you from damage disputes later. See documenting pre-existing damage.
- Review before release. Compare the invoice to the authorized amount before the customer arrives.
- Audit monthly. Pull a sample of repair orders and check them against the statute.
Good communication matters as much as good forms. See customer communication for auto service and handling customer complaints.
How insurance fits, and where it usually does not
Insurance responds to some repair disputes, but not to most billing disputes. Forms vary by carrier, but in general:
- Garage liability typically covers bodily injury and property damage to others arising from your operations, but commonly excludes the cost to redo your own faulty work.
- Garagekeepers coverage typically covers damage to customer vehicles in your care, such as fire, theft or a collision during a road test, depending on the form chosen.
- Billing and Consumer Protection Act claims over overcharges or unauthorized work are generally not covered by liability policies, because they are not bodily injury or property damage. Prevention is the main protection.
See our auto repair shop insurance page and our article on garagekeepers liability.
When to call a broker
Call us if a customer dispute turns into a demand letter or lawsuit, if a car was damaged while in your care, or if you are adding services such as collision repair or EV work. We can review how your garage liability and garagekeepers coverage would respond and where your forms and procedures can do more of the work.