Axle Weld may Fail Allowing Wheel to Separate – 2021-2022 C.E. Smith Company Multi-Sport 48810 & 48815, Multi-Sport Plus 48870, Malone Auto Racks MicroSport MPG460, EcoLight MPG585 Boat Trailers

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1594979v2 IMPORTANT SAFETY RECALL This notice may apply to your boat trailer July 22, 2022 «Ship_To_Address_1» «Ship_To_Address_2» «Ship_To_City», «Ship_To_State» «Ship_Zip» RE: C.E. Smith Co. Recall: Axle Replacement Models Nos.: MPG535 Malone Auto Racks MegaSport Trailer, Dear «Ship_To_Address_1»: This notice is being sent to you in accordance with the National Traffic and Motor Vehicle Safety Act. C.E. Smith Company, Inc. (“C.E. Smith”) has determined that a defect which relates to motor vehicle safety may exist in certain 2021 and 2022 trailers. According to Malone Paddle Gear LLC’s (“Malone Auto Racks”) records, you purchased a MegaSport trailer that may have been equipped with a potentially defective axle that was manufactured and supplied to C.E. Smith by Sure Trac, Inc. (“Sure Trac”). Testing has determined that the process used in welding the wheel spindle to the axle tube could potentially cause the weld to be weaker than designed. This could result in the wheel spindle becoming disconnected from the axle. If this happens during use, the spindle, wheel, and tire would disconnect from the trailer resulting in a loss of control of the trailer and potential crash. C.E Smith has initiated a product recall affecting the C.E Smith Trailers sold under the Malone Auto Racks brand: the MPG535, Malone Auto Racks MegaSport Trailer, which utilize the same axle hardware provided by Sure Trac manufactured during the period that the welding issue has been identified. It has been determined that these trailers may be unsafe. The serial number on the affected axles begin with the following numbers: 2111. Please check the serial number for the axle currently on your trailer to see if it begins with those four numbers. The serial number can be located by looking at the sticker on the middle of the square axle tube. If the serial number on your trailer’s current axle is begins with those numbers, please contact C.E. Smith at [email protected] or 1-800-334-2490 and provide your serial number or VIN number to request a replacement axle. If you contact C.E. Smith to notify us that your trailer contains an axle with one of these serial numbers, we will send a replacement axle. The replacement part can be swapped out for 1594979v2 the potentially defective hardware and will include instructions for doing so. This replacement part is covered by your warranty, and you will not be charged for the replacement axle. It is estimated that it will take approximately 60 minutes or less for you to swap out the potentially defective piece with the new piece. You should not operate your trailer until the defective piece has been replaced. This recall has been initiated to serve the best interest of you as a C.E. Smith customer. We recognize that this may be an inconvenience to you, and we ask for your patience and understanding regarding the recall. Federal regulations require that any vehicle lessor receiving this notice must forward a copy of this notice to the lessee within ten (10) days. If you have sold your trailer to another party, please contact us at [email protected] or 1-800-334-2490 with the name and address of the new owner. We regret any inconvenience that this action may cause you. However, we are concerned about your safety. If C.E. Smith fails to remedy this defect without charge and within a reasonable time, you may submit a written complaint to the Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Ave., S.E., Washington, D.C. 20590, or call the toll free Vehicle Safety Hotline at 1 888-327-4236; (TTY: 1-800-424-9153); or go to http://www.safercar.gov. Refer to recall number 22V-398. Please accept C.E. Smith’s sincerest apologies for the inconvenience caused by the implementation of this recall. We remain committed to providing you excellent service and products and to keep you as safe as possible while enjoying our products. Thank you for your cooperation. Sincerely, C.E. Smith Company

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1594979v2 IMPORTANT SAFETY RECALL This notice may apply to your boat trailer June 24, 2022 «Ship_To_Address_1» «Ship_To_Address_2» «Ship_To_City», «Ship_To_State» «Ship_Zip» «Country» RE: C.E. Smith Co. Recall: Axle Replacement Models Nos.: MPG460 Malone Auto Racks MicroSport Trailer, MPG585 Malone Auto Racks EcoLight Trailer, 48810, 48870, 48815 C.E. Smith Multi-Sport and Multi-Sport Plus Trailers Dear «Ship_To_Address_1»: This notice is being sent to you in accordance with the National Traffic and Motor Vehicle Safety Act. C.E. Smith Company, Inc. (“C.E. Smith”) has determined that a defect which relates to motor vehicle safety may exist in certain 2021 and 2022 trailers. According to Malone Paddle Gear LLC’s (“Malone Auto Racks”) records, you purchased a «Item» trailer that may have been equipped with a potentially defective axle that was manufactured and supplied to C.E. Smith by Sure Trac, Inc. (“Sure Trac”). Testing has determined that the process used in welding the wheel spindle to the axle tube could potentially cause the weld to be weaker than designed. This could result in the wheel spindle becoming disconnected from the axle. If this happens during use, the spindle, wheel, and tire would disconnect from the trailer resulting in a loss of control of the trailer and potential crash. C.E Smith has initiated a product recall affecting the C.E. Smith Multi-Sport trailers with the model numbers 48810, 48870, and 48815; as well as C.E Smith Trailers sold under the Malone Auto Racks brand: the MPG460, Malone Auto Racks MicroSport Trailer, and MPG585, Malone Auto Racks EcoLight Trailer, which utilize the same axle hardware provided by Sure Trac manufactured during the period that the welding issue has been identified. It has been determined that these trailers may be unsafe. The serial number on the affected axles begins with the following numbers: 2109, 2111, or 2201. Please check the serial number for the axle currently on your trailer to see if it begins with those four numbers. The serial number can be located by looking at the sticker on the middle of the square axle tube. If the serial number on your trailer’s current axle is begins with those numbers, please contact C.E. Smith at [email protected] or 1-800-334-2490 and provide your serial number or VIN number to request a replacement axle. 1594979v2 If you contact C.E. Smith to notify us that your trailer contains an axle with one of these serial numbers, we will send a replacement axle. The replacement part can be swapped out for the potentially defective hardware and will include instructions for doing so. This replacement part is covered by your warranty, and you will not be charged for the replacement axle. It is estimated that it will take approximately 60 minutes or less for you to swap out the potentially defective piece with the new piece. You should not operate your trailer until the defective piece has been replaced. This recall has been initiated to serve the best interest of you as a C.E. Smith customer. We recognize that this may be an inconvenience to you, and we ask for your patience and understanding regarding the recall. Federal regulations require that any vehicle lessor receiving this notice must forward a copy of this notice to the lessee within ten (10) days. If you have sold your trailer to another party, please contact us at [email protected] or 1-800-334-2490 with the name and address of the new owner. We regret any inconvenience that this action may cause you. However, we are concerned about your safety. If C.E. Smith fails to remedy this defect without charge and within a reasonable time, you may submit a written complaint to the Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Ave., S.E., Washington, D.C. 20590, or call the toll free Vehicle Safety Hotline at 1 888-327-4236; (TTY: 1-800-424-9153); or go to http://www.safercar.gov. Refer to recall number 22V-398. Please accept C.E. Smith’s sincerest apologies for the inconvenience caused by the implementation of this recall. We remain committed to providing you excellent service and products and to keep you as safe as possible while enjoying our products. Thank you for your cooperation. Sincerely, C.E. Smith Company

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-398 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : C.E. Smith Company, Inc. Submission Date : JUN 06, 2022 NHTSA Recall No. : 22V-398 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : C.E. Smith Company, Inc. Address : 1001 BITTING ST. Greensboro NC 27403 Company phone : 336-273-0166 Population : Number of potentially involved : 92 Estimated percentage with defect : 1 % Vehicle Information : Vehicle 1 : 2021-2022 C.E. Smith Company 48815, Multi-Sport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : shipped between October 2021 and May 2022. These are light weight, recreational trailers, sold as kits and assembled by the purchaser. Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 22, 2021 – MAR 29, 2022 VIN Range 1 : Begin : 4KF411210MG003443 End : 4KF41121XMG003532 ✔ Not sequential Description of Defect : Description of the Defect : The welding which connects the trailer axle tube to the wheel spindle can fail, causing the wheel to come off of the axle. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : If there is a weld error, the wheel spindle could break off of the axle, causing the wheel to fall off while the trailer is in motion. Description of the Cause : The supplier of the axle component began using a new robotic welding machine as part of its manufacturing process. Sure Trac believes that the robotic welder did not consistently line up a flush contact between the axle tube and the spindle before welding due to the jig assembly. If the operator did not ensure a flush fit, the weld could potentially fail by not holding the axle tube and the spindle together. Identification of Any Warning that can Occur : There have been five reports of trailer kits being delivered to the customer with the spindle broken off the axle tube at the time of receipt. Part 573 Safety Recall Report 22V-398 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Involved Components : Component Name 1 : Trailer Axle Component Description : Axle tube with welded-on wheel spindle Component Part Number : 33001G Supplier Identification : Component Manufacturer Name : Sure Trac, Inc Address : 635 Hwy 9 By-pass West Loris South Carolina 29569 Country : United States Chronology : In spring 2022, C.E. Smith and/or Malone Auto Rack received notice from five(5) customers that they had received the trailer kits which included a broken axle upon arrival and notice from two(2) customers that the axle had broken on the trailer while on the road. C.E. Smith then undertook a detailed, in-depth investigation to determine whether there was a defect and/or safety issue, and if so, the cause of that issue. C.E. Smith contacted Sure Trac, the manufacturer of the axle component and worked in tandem with Sure Trac on the investigation. Sure Trac was able to trace the issue back to a combination of a new robotic welding machine which Sure Trac implemented into its process and operator failure to make sure there was a flush fit between the axle tube and the spindle before the robotic welding was performed. This combination is the likely cause of the weld not securely joining the axle tube and wheel spindle in the limited number of reported 33001G axles failures which were produced by Sure Trac for C.E. Smith from September 2021 through January 2022. With this information, Sure Trac and C.E. Smith were able to determine that the defective axle part was manufactured by Sure Trac from September 2021 through January 2022. The reported failures are limited at this point to three batches of axles produced between September 2021 and January 2022, but in the abundance of caution all 33001G axles which were made in all batches produced between September 2021 and January 2022 and which were subsequently shipped by C.E. Smith could potentially be affected and therefore will be addressed. Sure Trac has provided the serial part numbers of the axles made during the time period of concern which C.E. Smith has used to identify by VIN which of its trailer kits had been sold with a potentially defective part. On June 1, 2022, C.E. Smith determined that it did have a defect and notified Sure Trac of its determination. To date, there have been no reported injuries. Part 573 Safety Recall Report 22V-398 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Remedy : Description of Remedy Program : For the 48810, 48870 and 48815 models sold under the C.E. Smith brand which were drop-shipped directly to the purchaser by C.E. Smith, C.E. Smith will send a notice and a replacement axle part directly to customers who purchased a trailer with the potentially defective axle. For the 48810, 48870 and 48815 models sold under the C.E. Smith brand which were shipped to a distribution center of a retailer who sold the trailer for delivery to the purchaser, C.E. Smith is notifying and will work with the retailer to identify the customers with a potentially defective axle to send a notice and ship a replacement axle part. A replacement axle and instructions for assembly will then be sent to each customer who confirms they purchased a trailer with the potentially defective axle. The shipment of the replacement axle will include instructions for the consumer to swap out the potentially defective axle with the replacement axle using steps similar to the original assembly of the trailer kit by the consumer. How Remedy Component Differs from Recalled Component : The replacement axle is welded to the wheel spindle using new processes implemented by Sure Trac to ensure that the wheel spindle and axle are held flush together during the welding process, making the axle weld stronger and preventing breakage. Identify How/When Recall Condition was Corrected in Production : Following its investigation, Sure Trac discovered the flaw in its welding process and implemented process changes to ensure that the wheel spindle and axle remained flush during the welding process. None of the trailer models using the Sure Trac axles since that correction was made have been reported as having any issues. Recall Schedule : Description of Recall Schedule : C.E. Smith has notified Malone Auto Rack and other retail distributors of the issue and intends to notify consumers shortly after its notification letter to owners is approved by the NHTSA. Assuming that NHTSA can approve the letter within ten (10) days of receipt, C.E. Smith anticipates that it will be able to begin mailing out the notification letter and replacement parts beginning on approximately June 30, 2022. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : JUN 30, 2022 – NR * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-398 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : C.E. Smith Company, Inc. Submission Date : JUN 27, 2022 NHTSA Recall No. : 22V-398 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : C.E. Smith Company, Inc. Address : 1001 BITTING ST. Greensboro NC 27403 Company phone : 336-273-0166 Population : Number of potentially involved : 2,043 Estimated percentage with defect : 1 % Vehicle Information : Vehicle 1 : 2021-2022 C.E. Smith Company 48815, Multi-Sport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : shipped between October 2021 and May 2022. These are light weight, recreational trailers, sold as kits and assembled by the purchaser. Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 22, 2021 – MAR 29, 2022 VIN Range 1 : Begin : 4KF411210MG003443 End : 4KF41121XMG003532 ✔ Not sequential Vehicle 2 : 2021-2022 C.E. Smith Company 48810, Multi-Sport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 20, 2021 – MAY 09, 2022 VIN Range 1 : Begin : 4KF311210MG005043 End : 4KF31121XNG002281 ✔ Not sequential Vehicle 3 : 2021-2022 Malone Auto Racks MPG460, MicroSport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 11, 2021 – MAY 09, 2022 VIN Range 1 : Begin : 4KF611145NG001484 End : 4KF6114XNG0001335 ✔ Not sequential Part 573 Safety Recall Report 22V-398 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Vehicle 4 : 2021-2022 C.E. Smith Company 48870, Multi-Sport Plus Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length Production Dates : OCT 20, 2021 – MAY 11, 2022 VIN Range 1 : Begin : 4KF411410MG004895 End : 4KF41141XNG000094 ✔ Not sequential Vehicle 5 : 2021-2022 Malone Auto Racks MPG585, EcoLight Vehicle Type : TRAILERS Body Style : ALL Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length Production Dates : NOV 05, 2021 – MAY 18, 2022 VIN Range 1 : Begin : 4KF211110MG005198 End : 4KF21111XNG003055 ✔ Not sequential Description of Defect : Description of the Defect : The welding which connects the trailer axle tube to the wheel spindle can fail, causing the wheel to come off of the axle. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : If there is a weld error, the wheel spindle could break off of the axle, causing the wheel to fall off while the trailer is in motion. Description of the Cause : The supplier of the axle component began using a new robotic welding machine as part of its manufacturing process. Sure Trac believes that the robotic welder did not consistently line up a flush contact between the axle tube and the spindle before welding due to the jig assembly. If the operator did not ensure a flush fit, the weld could potentially fail by not holding the axle tube and the spindle together. Identification of Any Warning that can Occur : There have been five reports of trailer kits being delivered to the customer with the spindle broken off the axle tube at the time of receipt. Involved Components : Part 573 Safety Recall Report 22V-398 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Component Name 1 : Trailer Axle Component Description : Axle tube with welded-on wheel spindle Component Part Number : 33001G Supplier Identification : Component Manufacturer Name : Sure Trac, Inc Address : 635 Hwy 9 By-pass West Loris South Carolina 29569 Country : United States Chronology : In spring 2022, C.E. Smith and/or Malone Auto Rack received notice from five(5) customers that they had received the trailer kits which included a broken axle upon arrival and notice from two(2) customers that the axle had broken on the trailer while on the road. C.E. Smith then undertook a detailed, in-depth investigation to determine whether there was a defect and/or safety issue, and if so, the cause of that issue. C.E. Smith contacted Sure Trac, the manufacturer of the axle component and worked in tandem with Sure Trac on the investigation. Sure Trac was able to trace the issue back to a combination of a new robotic welding machine which Sure Trac implemented into its process and operator failure to make sure there was a flush fit between the axle tube and the spindle before the robotic welding was performed. This combination is the likely cause of the weld not securely joining the axle tube and wheel spindle in the limited number of reported 33001G axles failures which were produced by Sure Trac for C.E. Smith from September 2021 through January 2022. With this information, Sure Trac and C.E. Smith were able to determine that the defective axle part was manufactured by Sure Trac from September 2021 through January 2022. The reported failures are limited at this point to three batches of axles produced between September 2021 and January 2022, but in the abundance of caution all 33001G axles which were made in all batches produced between September 2021 and January 2022 and which were subsequently shipped by C.E. Smith could potentially be affected and therefore will be addressed. Sure Trac has provided the serial part numbers of the axles made during the time period of concern which C.E. Smith has used to identify by VIN which of its trailer kits had been sold with a potentially defective part. On June 1, 2022, C.E. Smith determined that it did have a defect and notified Sure Trac of its determination. To date, there have been no reported injuries. Part 573 Safety Recall Report 22V-398 Page 4 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Remedy : Description of Remedy Program : For the 48810, 48870 and 48815 models sold under the C.E. Smith brand which were drop-shipped directly to the purchaser by C.E. Smith, C.E. Smith will send a notice and a replacement axle part directly to customers who purchased a trailer with the potentially defective axle. For the 48810, 48870 and 48815 models sold under the C.E. Smith brand which were shipped to a distribution center of a retailer who sold the trailer for delivery to the purchaser, C.E. Smith is notifying and will work with the retailer to identify the customers with a potentially defective axle to send a notice and ship a replacement axle part. A replacement axle and instructions for assembly will then be sent to each customer who confirms they purchased a trailer with the potentially defective axle. The shipment of the replacement axle will include instructions for the consumer to swap out the potentially defective axle with the replacement axle using steps similar to the original assembly of the trailer kit by the consumer. How Remedy Component Differs from Recalled Component : The replacement axle is welded to the wheel spindle using new processes implemented by Sure Trac to ensure that the wheel spindle and axle are held flush together during the welding process, making the axle weld stronger and preventing breakage. Identify How/When Recall Condition was Corrected in Production : Following its investigation, Sure Trac discovered the flaw in its welding process and implemented process changes to ensure that the wheel spindle and axle remained flush during the welding process. None of the trailer models using the Sure Trac axles since that correction was made have been reported as having any issues. Recall Schedule : Description of Recall Schedule : C.E. Smith has notified Malone Auto Rack and other retail distributors of the issue and intends to notify consumers shortly after its notification letter to owners is approved by the NHTSA. Assuming that NHTSA can approve the letter within ten (10) days of receipt, C.E. Smith anticipates that it will be able to begin mailing out the notification letter and replacement parts beginning on approximately June 30, 2022. Planned Dealer Notification Date : JUN 30, 2022 – NR Planned Owner Notification Date : JUN 30, 2022 – NR * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-398 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : C.E. Smith Company, Inc. Submission Date : SEP 09, 2022 NHTSA Recall No. : 22V-398 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : C.E. Smith Company, Inc. Address : 1001 BITTING ST. Greensboro NC 27403 Company phone : 336-273-0166 Population : Number of potentially involved : 2,134 Estimated percentage with defect : 1 % Vehicle Information : Vehicle 1 : 2021-2022 Malone Auto Racks MPG585, EcoLight Vehicle Type : TRAILERS Body Style : ALL Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length Production Dates : NOV 05, 2021 – MAY 18, 2022 VIN Range 1 : Begin : 4KF211110MG005198 End : 4KF21111XNG003055 ✔ Not sequential Vehicle 2 : 2021-2022 Malone Auto Racks MPG460, MicroSport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 11, 2021 – MAY 09, 2022 VIN Range 1 : Begin : 4KF611145NG001484 End : 4KF6114XNG0001335 ✔ Not sequential Vehicle 3 : 2022-2022 Malone Auto Racks MPG535, MegaSport Trailer Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : MAR 23, 2022 – JUN 07, 2022 VIN Range 1 : Begin : 4KF911410NG001843 End : 4KF91141XNG003535 ✔ Not sequential Part 573 Safety Recall Report 22V-398 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Vehicle 4 : 2021-2022 C.E. Smith Company 48810, Multi-Sport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 20, 2021 – MAY 09, 2022 VIN Range 1 : Begin : 4KF311210MG005043 End : 4KF31121XNG002281 ✔ Not sequential Vehicle 5 : 2021-2022 C.E. Smith Company 48870, Multi-Sport Plus Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length Production Dates : OCT 20, 2021 – MAY 11, 2022 VIN Range 1 : Begin : 4KF411410MG004895 End : 4KF41141XNG000094 ✔ Not sequential Vehicle 6 : 2021-2022 C.E. Smith Company 48815, Multi-Sport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : shipped between October 2021 and May 2022. These are light weight, recreational trailers, sold as kits and assembled by the purchaser. Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 22, 2021 – MAR 29, 2022 VIN Range 1 : Begin : 4KF411210MG003443 End : 4KF41121XMG003532 ✔ Not sequential Description of Defect : Description of the Defect : The welding which connects the trailer axle tube to the wheel spindle can fail, causing the wheel to come off of the axle. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : If there is a weld error, the wheel spindle could break off of the axle, causing the wheel to fall off while the trailer is in motion. This increases the risk of a crash involving the trailer. Description of the Cause : The supplier of the axle component began using a new robotic welding machine as part of its manufacturing process. Sure Trac believes that the robotic welder did not consistently line up a flush contact between the axle Part 573 Safety Recall Report 22V-398 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 tube and the spindle before welding due to the jig assembly. If the operator did not ensure a flush fit, the weld could potentially fail by not holding the axle tube and the spindle together. Identification of Any Warning that can Occur : There have been five reports of trailer kits being delivered to the customer with the spindle broken off the axle tube at the time of receipt. Involved Components : Component Name 1 : Trailer Axle Component Description : Axle tube with welded-on wheel spindle Component Part Number : 33001G Component Name 2 : Trailer Axle Component Description : Axle tube with welded-on wheel spindle, version used for MPG535 Component Part Number : 33204G Supplier Identification : Component Manufacturer Name : Sure Trac, Inc Address : 635 Hwy 9 By-pass West Loris South Carolina 29569 Country : United States Chronology : In spring 2022, C.E. Smith and/or Malone Auto Rack received notice from five(5) customers that they had received the trailer kits which included a broken axle upon arrival and notice from two(2) customers that the axle had broken on the trailer while on the road. C.E. Smith then undertook a detailed, in-depth investigation to determine whether there was a defect and/or safety issue, and if so, the cause of that issue. C.E. Smith contacted Sure Trac, the manufacturer of the axle component and worked in tandem with Sure Trac on the investigation. Sure Trac was able to trace the issue back to a combination of a new robotic welding machine which Sure Trac implemented into its process and operator failure to make sure there was a flush fit between the axle tube and the spindle before the robotic welding was performed. This combination is the likely cause of the weld not securely joining the axle tube and wheel spindle in the limited number of reported 33001G axles failures which Part 573 Safety Recall Report 22V-398 Page 4 The information contained in this report was submitted pursuant to 49 CFR §573 were produced by Sure Trac for C.E. Smith from September 2021 through January 2022. With this information, Sure Trac and C.E. Smith were able to determine that the defective axle part was manufactured by Sure Trac from September 2021 through January 2022. The reported failures are limited at this point to three batches of axles produced between September 2021 and January 2022, but in the abundance of caution all 33001G axles which were made in all batches produced between September 2021 and January 2022 and which were subsequently shipped by C.E. Smith could potentially be affected and therefore will be addressed. Sure Trac has provided the serial part numbers of the axles made during the time period of concern which C.E. Smith has used to identify by VIN which of its trailer kits had been sold with a potentially defective part. On June 1, 2022, C.E. Smith determined that it did have a defect and notified Sure Trac of its determination. To date, there have been no reported injuries. Description of Remedy : Description of Remedy Program : For the 48810, 48870 and 48815 models sold under the C.E. Smith brand which were drop-shipped directly to the purchaser by C.E. Smith, C.E. Smith will send a notice and a replacement axle part directly to customers who purchased a trailer with the potentially defective axle. For the 48810, 48870 and 48815 models sold under the C.E. Smith brand which were shipped to a distribution center of a retailer who sold the trailer for delivery to the purchaser, C.E. Smith is notifying and will work with the retailer to identify the customers with a potentially defective axle to send a notice and ship a replacement axle part. A replacement axle and instructions for assembly will then be sent to each customer who confirms they purchased a trailer with the potentially defective axle. The shipment of the replacement axle will include instructions for the consumer to swap out the potentially defective axle with the replacement axle using steps similar to the original assembly of the trailer kit by the consumer. How Remedy Component Differs from Recalled Component : The replacement axle is welded to the wheel spindle using new processes implemented by Sure Trac to ensure that the wheel spindle and axle are held flush together during the welding process, making the axle weld stronger and preventing breakage. Identify How/When Recall Condition was Corrected in Production : Following its investigation, Sure Trac discovered the flaw in its welding process and implemented process changes to ensure that the wheel spindle and axle remained flush during the welding process. None of the trailer models using the Sure Trac axles since that correction was made have been reported as having any issues. Recall Schedule : Description of Recall Schedule : C.E. Smith has notified Malone Auto Rack and other retail distributors of the issue and intends to notify consumers shortly after its notification letter to owners is approved by the NHTSA. Assuming that NHTSA can Part 573 Safety Recall Report 22V-398 Page 5 The information contained in this report was submitted pursuant to 49 CFR §573 approve the letter within ten (10) days of receipt, C.E. Smith anticipates that it will be able to begin mailing out the notification letter and replacement parts beginning on approximately June 30, 2022. Planned Dealer Notification Date : JUN 30, 2022 – NR Planned Owner Notification Date : JUN 30, 2022 – NR * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-398 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : C.E. Smith Company, Inc. Submission Date : JUN 16, 2022 NHTSA Recall No. : 22V-398 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : C.E. Smith Company, Inc. Address : 1001 BITTING ST. Greensboro NC 27403 Company phone : 336-273-0166 Population : Number of potentially involved : 2,043 Estimated percentage with defect : 1 % Vehicle Information : Vehicle 1 : 2021-2022 C.E. Smith Company 48815, Multi-Sport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : shipped between October 2021 and May 2022. These are light weight, recreational trailers, sold as kits and assembled by the purchaser. Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 22, 2021 – MAR 29, 2022 VIN Range 1 : Begin : 4KF411210MG003443 End : 4KF41121XMG003532 ✔ Not sequential Vehicle 2 : 2021-2022 C.E. Smith Company 48810, Multi-Sport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 20, 2021 – MAY 09, 2022 VIN Range 1 : Begin : 4KF311210MG005043 End : 4KF31121XNG002281 ✔ Not sequential Vehicle 3 : 2021-2022 Malone Auto Racks MPG460, MicroSport Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length. Production Dates : OCT 11, 2021 – MAY 09, 2022 VIN Range 1 : Begin : 4KF611145NG001484 End : 4KF6114XNG0001335 ✔ Not sequential Part 573 Safety Recall Report 22V-398 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Vehicle 4 : 2021-2022 C.E. Smith Company 48870, Multi-Sport Plus Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length Production Dates : OCT 20, 2021 – MAY 11, 2022 VIN Range 1 : Begin : 4KF411410MG004895 End : 4KF41141XNG000094 ✔ Not sequential Vehicle 5 : 2021-2022 Malone Auto Racks MPG585, EcoLight Vehicle Type : TRAILERS Body Style : ALL Power Train : NR Descriptive Information : Boat trailers for use as small marine or recreational trailers capable of transporting jet skis, kayaks, and boats that are 12 feet or less in length Production Dates : NOV 05, 2021 – MAY 18, 2022 VIN Range 1 : Begin : 4KF211110MG005198 End : 4KF21111XNG003055 ✔ Not sequential Description of Defect : Description of the Defect : The welding which connects the trailer axle tube to the wheel spindle can fail, causing the wheel to come off of the axle. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : If there is a weld error, the wheel spindle could break off of the axle, causing the wheel to fall off while the trailer is in motion. Description of the Cause : The supplier of the axle component began using a new robotic welding machine as part of its manufacturing process. Sure Trac believes that the robotic welder did not consistently line up a flush contact between the axle tube and the spindle before welding due to the jig assembly. If the operator did not ensure a flush fit, the weld could potentially fail by not holding the axle tube and the spindle together. Identification of Any Warning that can Occur : There have been five reports of trailer kits being delivered to the customer with the spindle broken off the axle tube at the time of receipt. Involved Components : Part 573 Safety Recall Report 22V-398 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Component Name 1 : Trailer Axle Component Description : Axle tube with welded-on wheel spindle Component Part Number : 33001G Supplier Identification : Component Manufacturer Name : Sure Trac, Inc Address : 635 Hwy 9 By-pass West Loris South Carolina 29569 Country : United States Chronology : In spring 2022, C.E. Smith and/or Malone Auto Rack received notice from five(5) customers that they had received the trailer kits which included a broken axle upon arrival and notice from two(2) customers that the axle had broken on the trailer while on the road. C.E. Smith then undertook a detailed, in-depth investigation to determine whether there was a defect and/or safety issue, and if so, the cause of that issue. C.E. Smith contacted Sure Trac, the manufacturer of the axle component and worked in tandem with Sure Trac on the investigation. Sure Trac was able to trace the issue back to a combination of a new robotic welding machine which Sure Trac implemented into its process and operator failure to make sure there was a flush fit between the axle tube and the spindle before the robotic welding was performed. This combination is the likely cause of the weld not securely joining the axle tube and wheel spindle in the limited number of reported 33001G axles failures which were produced by Sure Trac for C.E. Smith from September 2021 through January 2022. With this information, Sure Trac and C.E. Smith were able to determine that the defective axle part was manufactured by Sure Trac from September 2021 through January 2022. The reported failures are limited at this point to three batches of axles produced between September 2021 and January 2022, but in the abundance of caution all 33001G axles which were made in all batches produced between September 2021 and January 2022 and which were subsequently shipped by C.E. Smith could potentially be affected and therefore will be addressed. Sure Trac has provided the serial part numbers of the axles made during the time period of concern which C.E. Smith has used to identify by VIN which of its trailer kits had been sold with a potentially defective part. On June 1, 2022, C.E. Smith determined that it did have a defect and notified Sure Trac of its determination. To date, there have been no reported injuries. Part 573 Safety Recall Report 22V-398 Page 4 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Remedy : Description of Remedy Program : For the 48810, 48870 and 48815 models sold under the C.E. Smith brand which were drop-shipped directly to the purchaser by C.E. Smith, C.E. Smith will send a notice and a replacement axle part directly to customers who purchased a trailer with the potentially defective axle. For the 48810, 48870 and 48815 models sold under the C.E. Smith brand which were shipped to a distribution center of a retailer who sold the trailer for delivery to the purchaser, C.E. Smith is notifying and will work with the retailer to identify the customers with a potentially defective axle to send a notice and ship a replacement axle part. A replacement axle and instructions for assembly will then be sent to each customer who confirms they purchased a trailer with the potentially defective axle. The shipment of the replacement axle will include instructions for the consumer to swap out the potentially defective axle with the replacement axle using steps similar to the original assembly of the trailer kit by the consumer. How Remedy Component Differs from Recalled Component : The replacement axle is welded to the wheel spindle using new processes implemented by Sure Trac to ensure that the wheel spindle and axle are held flush together during the welding process, making the axle weld stronger and preventing breakage. Identify How/When Recall Condition was Corrected in Production : Following its investigation, Sure Trac discovered the flaw in its welding process and implemented process changes to ensure that the wheel spindle and axle remained flush during the welding process. None of the trailer models using the Sure Trac axles since that correction was made have been reported as having any issues. Recall Schedule : Description of Recall Schedule : C.E. Smith has notified Malone Auto Rack and other retail distributors of the issue and intends to notify consumers shortly after its notification letter to owners is approved by the NHTSA. Assuming that NHTSA can approve the letter within ten (10) days of receipt, C.E. Smith anticipates that it will be able to begin mailing out the notification letter and replacement parts beginning on approximately June 30, 2022. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : JUN 30, 2022 – NR * NR – Not Reported

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