Magnuson-Moss Warranty Act for Appliances: Where It Stops

The federal warranty law reaches the furnace in your basement and stops at the duct collar. That boundary is written into a regulation, 16 CFR 700.1(d), and it matters more than most homeowners holding a replacement bid realise: of the warranty lines on a typical HVAC estimate, the Magnuson-Moss Warranty Act governs roughly one kind and leaves the rest to your state and to the contract itself.

This page reads the Act (15 U.S.C. 2301 to 2312, govinfo's 2024 edition) and its four FTC rules (16 CFR Parts 700, 701, 702 and 703, pulled from the eCFR versioner API at the version dated 15 October 2026) against the warranty lines that show up on home-equipment bids. Everything was read on 19 October 2026. Rules get amended, so check the eCFR date on any section quoted here before relying on it. The usual caution applies: this is a comparison of documents, written by someone with no law licence, and it is not legal advice about your claim.

Equipment is a consumer product; the house around it is not

The Act only applies to written warranties on a "consumer product," and the statutory definition was drafted with houses in mind. Section 2301(1) covers tangible personal property normally used for personal, family, or household purposes, "including any such property intended to be attached to or installed in any real property without regard to whether it is so attached or installed."

The FTC spells out what that means in 16 CFR 700.1(c): "This provision brings under the Act separate items of equipment attached to real property, such as air conditioners, furnaces, and water heaters." Paragraph (d) extends it to "appliances and other thermal, mechanical, and electrical equipment," and then draws the line in a parenthesis:

(It does not extend to the wiring, plumbing, ducts, and other items which are integral component parts of the structure.)

That sentence also explains why the rule bothers to say this at all. Many states treat a furnace as a fixture, which makes it part of the real estate. The regulation says the federal definition is "designed to bring such products under the Act regardless of whether they may be considered fixtures under state law." So the condenser on the pad and the water heater in the garage are consumer products. The new supply plenum, the branch ducts, and the circuit run from the panel are part of the building.

Building materials sit in between, and the answer turns on the transaction. Under 700.1(e), materials bought over the counter, or bought by a consumer "in connection with the improvement, repair, or modification of a home," are consumer products, and the rule's own examples include siding, roofing and storm windows. A reroof contract therefore puts the shingle manufacturer's written warranty under the Act. Paragraph (f) reverses that for new construction: when you contract with a builder for a home, "a substantial addition to a home," a garage or an in-ground pool, the building materials are not consumer products. The same paragraph keeps one thing constant across both cases: separate items of equipment attached to that new structure are still covered.

On a bid, that sorts the lines like this:

Two practical points follow. A duct-sealing or duct-replacement warranty from the contractor is not something the Act will help you enforce. And a line set, condensate drain or disconnect box is not named in either direction in Part 700, so this page does not guess which side of the parenthesis it falls on.

Your installer's labor promise sits outside the Act

Most replacement bids carry two warranty lines: a manufacturer's parts term, and the contractor's own labor or workmanship term, often one or two years. Only the first is reliably a Magnuson-Moss warranty.

The FTC's Businessperson's Guide to Federal Warranty Law lists what the Act does not do before it lists what it does. It does not require anyone to give a written warranty. It does not apply to oral warranties. And "the Act does not apply to warranties on services." 16 CFR 700.1(h) puts it in the language of repair work: "warranties which apply solely to a repairer's workmanship in performing repairs are not subject to the Act."

The same paragraph has a turn in it that matters for bids. "Where a written agreement warrants both the parts provided to effect a repair and the workmanship in making that repair, the warranty must comply with the Act and the rules thereunder." A contractor's paper that says "we warrant the parts we furnish and our labor for two years" is inside the Act. One that says "labor warranted for one year" is not. Neither is a promise the salesperson made out loud and never wrote down.

None of this makes a labor-only promise worthless. It is a term of your contract, enforced under your state's contract law. What you lose is the federal disclosure rules, the federal limits on disclaiming implied warranties, and the federal fee-shifting provision described further down. So when a bid says "1-year labor," the useful question is whether the labor promise is written into the signed contract, and against whom it runs. The parts and labor warranty page traces how each manufacturer's certificate excludes labor and who carries it instead.

There is a second distinction inside the dealer relationship. Under 16 CFR 700.4, a supplier who does no more than distribute or sell a product covered by someone else's written warranty, and identifies that other business as the warrantor, is not liable for that warranty's compliance with the Act. Your dealer is selling you Carrier's or Goodman's ten-year parts warranty, not giving it. The rule adds a caveat that cuts the other way: a seller's own "written and oral representations" can make it a co-warrantor if state law treats the seller as having "adopted" the promise. A sales sheet that restates the manufacturer's terms in the dealer's own words, with the dealer's name on it, is the kind of document worth keeping.

Almost every equipment warranty is "limited," and that word does most of the work

Section 2303 requires every written warranty on a consumer product costing more than $10 to carry one of two labels. A warranty that meets the federal minimum standards in section 2304 must be designated "full (statement of duration) warranty." Anything that does not must be designated "limited warranty."

The full-warranty standards are strong. Under 2304(a), the warrantor must remedy a defect "within a reasonable time and without charge," cannot limit how long implied warranties last, must print any exclusion of consequential damages conspicuously on the face of the warranty, and must let you choose a refund or a replacement after "a reasonable number of attempts" fail. If it replaces a component, the statute says "such replacement shall include installing the part in the product without charge." The FTC's rule at 16 CFR 700.9 adds that where a product "has utility only when installed," a full warranty has to provide the installation free, whether or not you paid for installation the first time.

Section 2304(b)(1) also bars a full warrantor from imposing "any duty other than notification" as a condition of getting the remedy, unless it can show the duty is reasonable. The FTC applied that to registration cards in 16 CFR 700.7(b), and the example it gives as forbidden is exactly the sentence a homeowner fears:

"This warranty is void unless the warranty registration card is returned to the warrantor"

Read that and the natural conclusion is that registration deadlines are illegal. They are not, for one reason. Every one of those protections attaches to full warranties. A manufacturer that labels its certificate "limited" has opted out of section 2304 entirely, which the statute lets it do, and that is what residential HVAC certificates are. Carrier's own registration page, read on 19 October 2026, describes the fallback this way: "If you register after 90 days, the standard 5-year parts warranty applies with no labor coverage." Registering within 90 days of installation is what unlocks the longer terms: the same page says that upon timely registration an owner can "select either a 10-year parts-only limited warranty or a 5-year parts plus 3-year labor limited warranty," the second only through a participating dealer. Limited at every length, and therefore free under federal law to tie the longer term to registration.

What removes the registration condition in some places is state law. Goodman's warranty information page, marked "Updated January, 2026," lists four jurisdictions where limited coverage on its HVAC equipment cannot be conditioned on registration, each with a different start date:

Carrier's page carries a matching note, that jurisdictions where benefits cannot be conditioned on registration "will automatically receive a 10-year parts limited warranty," without naming them. Neither page is a statute, and the registration deadline page goes through the state laws themselves, including where Florida's statute and the manufacturers' readings of it disagree. The point for this page is narrower: if you live outside those places, Magnuson-Moss will not rescue a missed registration window, because the warranty you were given never promised you the full-warranty standards.

What a limited warranty still owes you

Being "limited" exempts a warranty from section 2304. It does not exempt it from the rest of the Act or from the disclosure and pre-sale rules, which apply to products costing more than $15. Several of those rules bear directly on equipment you have not yet agreed to buy.

The terms in one document. 16 CFR 701.3(a) requires a warrantor to disclose, "in a single document in simple and readily understood language," nine items. They include who the warranty runs to if it is limited to the original buyer, what parts are covered and excluded, what the warrantor will and will not pay for, when the term starts if that is not the purchase date, the step-by-step claim procedure, and any informal dispute mechanism. Item four is the one that catches HVAC owners, because equipment terms often start from installation or from a manufacture date decoded from the serial number. The registration page covers that clock in detail.

The right to read it before you sign. Part 702 requires sellers to make warranty text available before the sale. For a sale made in your home, the rule has a specific paragraph. Section 702.3(d) defines a door-to-door sale as one where the seller "personally solicits the sale, including those in response to or following an invitation by a buyer," and the buyer's agreement is made somewhere other than the seller's place of business. A seller in that position must, before the sale is completed, tell you that the representative has copies of the warranties and that you may inspect them "at any time during the sales presentation." Whether a given in-home HVAC estimate meets every element of that definition is a question for your state's consumer office, but the request costs nothing: ask the estimator for the certificate that matches the model numbers on the bid, not the brochure.

Implied warranties you cannot sign away. This is the provision that does the most for owners of limited warranties. Section 2308(a) says no supplier may disclaim or modify any implied warranty if it makes a written warranty on the product, or if it sells you a service contract at the time of sale "or within 90 days thereafter." The implied warranty of merchantability is state-law protection: in the FTC guide's words, "a merchant's basic promise that the goods sold will do what they are supposed to do."

A manufacturer giving a limited warranty may shorten how long that implied promise lasts, but under 2308(b) only to the length of the written warranty, only if the limit is conscionable, and only if it is "set forth in clear and unmistakable language and prominently displayed on the face of the warranty." It must also carry the 701.3 sentence: "Some States do not allow limitations on how long an implied warranty lasts, so the above limitation may not apply to you."

Implied warranties have edges too. The FTC guide says they "do not cover problems such as those caused by abuse, misuse, ordinary wear, failure to follow directions, or improper maintenance," and that state statutes of limitations for breach "are generally four years from date of purchase." That is a window to discover a defect that existed at sale, not a promise that the unit lasts four years.

No "our decision is final." Under 16 CFR 700.8, a warrantor may not say, directly or indirectly, that its own decision or a designated third party's is final or binding in a warranty dispute. "Nor shall a warrantor or service contractor state that it alone shall determine what is a defect under the agreement." If a claim denial is phrased as unappealable, that phrasing is not something the rule allows the certificate to say.

The "use our parts" sentence, and where the rule draws it

Section 2302(c) bars any warrantor from conditioning a written or implied warranty on your using an article or service "identified by brand, trade, or corporate name," unless that article or service is provided free under the warranty. The FTC can waive the ban, but only if the warrantor shows the product "will function properly only if" the named item is used, and the Commission finds the waiver is in the public interest. Waiver applications go through the Federal Register.

The FTC's interpretation at 16 CFR 700.10 applies that to equipment in two ways that matter for HVAC and water heaters.

First, under a limited warranty that pays for parts and not labor, the warrantor cannot require that you use labor it identifies to install those replacement parts, and it "may not provide parts under the warranty in a manner which impedes or precludes the choice by the consumer of the person or business to perform necessary labor." If the warranty covers the part only, you choose who installs it.

Second, 700.10(c) says no warrantor "may condition the continued validity of a warranty on the use of only authorized repair service and/or authorized replacement parts for non-warranty service and maintenance." Its forbidden example is a clause voiding the warranty if anyone other than an authorized dealer does the service, or if replacement parts are not the brand's own. The same paragraph limits the protection in the other direction, and this is the part sales conversations leave out. The warrantor may still expressly exclude "liability for defects or damage caused by" unauthorized articles or service, and may deny a claim where it "can demonstrate that the defect or damage was so caused."

So a homeowner who has the annual tune-up done by an independent technician has not voided the compressor warranty by doing so. A homeowner whose independent technician installs the wrong replacement part, which then damages the compressor, may well find that particular failure excluded. The difference is causation, and the evidence of it is your service records.

Read manufacturer pages with that line in mind. Carrier's warranty FAQ, read on 19 October 2026, says "you should always insist on genuine Carrier parts for any repairs," and that using approved parts helps the equipment "stay in compliance with your warranty terms." That is advice addressed to the owner, phrased as a recommendation. Whether the certificate for your model number turns it into a condition is a question only that certificate answers, and the certificates themselves were not part of the source set for this page.

The FTC has acted on the tie-in rule in other industries. In April 2018 its staff sent warning letters to six major companies selling automobiles, cellular devices, and video gaming systems, quoting provisions such as "This warranty shall not apply if this product . . . is used with products not sold or licensed by [company name]." The letters said staff would review the companies' websites after 30 days. No home-equipment matter was among the documents read for this page, and the absence of one here is not evidence that none exists.

When a claim is refused

The Act gives consumers their own lawsuit. Section 2310(d)(1) lets a consumer "damaged by the failure of a supplier, warrantor, or service contractor to comply" with the Act, a written warranty, an implied warranty, or a service contract sue in any state court of competent jurisdiction. Under 2310(d)(2), a consumer who "finally prevails" may recover costs and expenses, "including attorneys' fees based on actual time expended," unless the court decides fees would be inappropriate.

That fee provision is the Act's real weight in a furnace or water-heater dispute, because the federal-court route is mostly closed to a single household. Section 2310(d)(3) bars a federal claim where any individual claim is under $25, or where the total amount in controversy is under $50,000, exclusive of interest and costs, computed on all claims in the suit. A single replacement heat exchanger or compressor claim will normally be a state-court case.

Two conditions come first. Under 2310(e), a warrantor must be given "a reasonable opportunity to cure" before a suit for breach of a written or implied warranty. Put the claim in writing, with the serial number, installation date and the failure, and keep the response.

Second, if the warranty itself requires you to use an informal dispute mechanism before suing, and the mechanism complies with the FTC's Part 703 rule, section 2310(a)(3) makes that step mandatory. The warranty has to say so: 703.2 requires the name and address of the mechanism, or a free telephone number, on the face of the warranty. Under 703.5(d) the mechanism must decide "at least within 40 days of notification of the dispute," subject to listed exceptions, and under 703.5(j) its decisions "shall not be legally binding on any person," though the decision is admissible in a later suit. A certificate that names no mechanism imposes no such step.

Federal law also does not crowd out state law here. Section 2311(b)(1) says nothing in the Act "shall invalidate or restrict any right or remedy of any consumer under State law or any other Federal law." State lemon-style statutes, home-improvement contract laws, and the registration statutes mentioned above all keep operating alongside it.

Checking each warranty line on the bid against the Act

Before signing, the documents in hand should let you answer these for every warranty line the estimate lists:

1. What is it attached to? Equipment named in 700.1(c) and (d) is covered. Ducts, wiring and plumbing are not. On a reroof or remodel contract, materials are; on new construction or a substantial addition, they are not.
2. Who is the warrantor? The manufacturer's name and form number should be on a certificate, not just in a sales sheet. If the dealer restates the terms on its own letterhead, keep that sheet: under 700.4 it may matter.
3. Full or limited? Look for the designation required by 2303, normally in the heading. "Limited" means the registration, labor and claim-procedure conditions are as strong as the certificate makes them, subject to state law.
4. Is the labor promise written, and does it cover parts too? Labor-only is a contract term outside the Act (700.1(h)). Parts plus labor in one written promise is inside it.
5. What does the certificate say about implied warranties? A limit on their duration must be on the face, tied to the written term, and followed by the 701.3(a)(7) sentence.
6. Is there a dispute mechanism? If 703.2 disclosures appear, that step comes before any lawsuit. If not, it does not.
7. Does any page condition coverage on brand-name service or parts? Compare the wording to 700.10(c). A condition on non-warranty service is what the rule prohibits; an exclusion for damage actually caused by unauthorized work is what it permits.

The 14-line HVAC bid checklist covers the rest of the estimate. For warranty lines, the federal rule reduces to a short test. Magnuson-Moss governs what the manufacturer wrote down about the equipment, sets a floor under implied warranties once anything is written, and stops at the duct collar and at the installer's labor promise. Past those two edges, the documents that bind are your state's statutes and the contract you sign.