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Got into an accident...

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I was going to say, the shop that did my work in 2018 certainly placed more than 2 parts orders! But now that I look, they are no longer on the Body Shop Support list on the Tesla website. Perhaps the standards are working as intended?
Tesla does have to balance enforcing the requirements with having enough certified shops to actually handle repairs too, so they're probably not religiously strict about these standards. But overall, based on conversations with a certified body shop owner - yes, they do keep track and will issue warnings to shops that consistently require more than 2 parts orders per VIN.