2013 Mercedes-Benz ML350

NHTSA VEHICLE SAFETY COMPLAINT SUPPORTING STATEMENT Vehicle: 2013 Mercedes-Benz ML350 I am submitting this complaint regarding a continuing safety concern involving water intrusion and electronic system damage in my 2013 Mercedes-Benz ML350. My vehicle was subject to a Mercedes-Benz recall involving water intrusion and related components. Despite recall-related repairs being performed, moisture and water intrusion concerns remain unresolved. During the diagnostic process, Mercedes-Benz personnel identified evidence of water and humidity in areas associated with vehicle electronics and control modules. The vehicle has experienced repeated mechanical and electronic issues following discovery of the water intrusion condition. Multiple repair facilities have been involved, and I have incurred significant diagnostic and repair expenses while attempting to determine the full extent of the damage. The primary concern is not ordinary wear and tear. The concern is that water intrusion has affected vehicle systems and that the recall remedy has not resulted in a complete resolution of the condition. I am concerned that moisture exposure may continue to impact vehicle electronics, control modules, sensors, and other safety-related systems. Mercedes-Benz USA has been notified and a case has been opened. The dealership has also been involved. However, despite escalation requests and requests for management review, I have not received a meaningful resolution. The dealership continues directing me back to Mercedes-Benz USA while Mercedes-Benz USA has not provided a final management response. I respectfully request that NHTSA review whether the recall remedy adequately addressed the water intrusion condition and whether additional investigation is warranted regarding continuing moisture intrusion, electronic system exposure, and potential safety risks associated with this condition. I am prepared to provide repair orders, recall documentation, photographs, diagnostic findin

NHTSA ID

11741266

Incident

Dec 17, 2025

Re: My 2013 ML350- Intermittent Start/ Vehicle cutting off while in heavy traffic. Fuel Pump and Fuel modulator failed due to water collecting in the spare tire wheel-weld causing water intrusion into the fuel system. I paid out of pocket for this service twice, AND then found out from MB Tacoma there was a RECALL with the exact same issue. I took the vehicle in to the closest dealer- Seattle Mercedes to handle the outstanding recall issues. I was advised to contact MERCEDES BENZ USA GOODWILL DEPARTMENT. My initial claim was approved, as I submitted ALL DOCUMENTATION of the repairs related to this issue. NOW, after 5 months of my RECALL REIMBURSEMENT CLAIM BEING BOUNCED AROUND by customer service agents that were not trained to handle recall issues- my dealership needed approval to process it. I even provided MB-USA w/a Bulletin # (FROM MB-USA) that clearly states to claim reimbursement IF THESE PARTS FAILED AND THE CUSTOMER PAID OUT OF POCKET.

NHTSA ID

11734678

Incident

Aug 1, 2025

The contact owns a 2013 Mercedes-Benz ML350. The contact stated that while driving approximately 40 - 45 MPH, the vehicle stalled in the middle lane. The driver was able to push the vehicle safely to the roadside. There were no warning lights illuminated. The vehicle was towed to the local dealer, where it was diagnosed, and determined that the fuel pump needed to be replaced. The vehicle was repaired. The following day, it took two minutes to start the vehicle. The vehicle was drivable, but the vehicle eventually stalled while driving. The vehicle was towed to another local dealer, Mercedes-Benz of South Orlando (4301 Millenia Blvd, Orlando, FL 32839), where it was diagnosed with a faulty fuel sensor and control valve. The parts were replaced. The contact stated that the fuel pump was replaced four times, but the failure persisted. The manufacturer was contacted and escalated the failure was escalated to an engineer for assistance. The failure mileage was approximately 96,000.

NHTSA ID

11711198

Incident

Dec 1, 2025

Mileage

96,000 mi

Good morning ! I am an owner of a 2013 ML 350 . I live in San Diego ,CA ,92103 . I was driving my car on [XXX] and it was raining a lot . After around 30 miles I got to my destination parking area and my car died 20 feet away from the parking zone .I tried to reignite it but it wouldn’t start . I checked it with a OBD2 scanner and it was indicating a code U0109 - Lost communication with fuel pump control module . After looking into solutions and reasons for the issue online I came across a post regarding an existing recall with NHTSA with ID 22v955 regarding water intrusion in the spare wheel well portion of the trunk( The Wheel well is not water proofed and doesn’t have a drain port for water to escape ) . I proceeded with inspecting the area and of course it was full of water . The fuel pump control module is located in that area and it was damaged which shorted it and cause the malfunction of the vechile and the error code U0109 stated above . Tried calling Mercedes Benz but they confirmed about that specific recall but said my VIN is not part of it and I should file a claim or complain with you . I will attach proof and pictures of the water and the damaged component. My car now need to be towed and fixed on my expense because of Mercedes Benz negligence… Hopefully you can add my car to this recall and when this happens I would get some kind of reimbursement… Thank you for your time and understanding. INFORMATION REDACTED PURSUANT TO THE FREEDOM OF INFORMATION ACT (FOIA), 5 U.S.C. 552(B)(6)

NHTSA ID

11699776

Incident

Nov 15, 2025

The engine locked up after blowing the top part of the engine off, fire shot out of the engine and quickly went out like a flam thrower. I was driving on the expressway when the accelerator would not work without any warning I didn’t have any issues with this truck. The car cut off immediately thank God I was able to coast to the side of the expressway because it stopped in the left lane on the expressway I was scared for our lives. The dealership has the truck and they said the engine is locked up. This morning s unacceptable for a car I’ve had for a year.

NHTSA ID

11686235

Incident

Aug 17, 2025

Brake Booster failure, this vehicle is exhibiting the EXACT same symptoms as described in Recall Campaign: Campaign No. 2024050001, May 2024 TO: ALL MERCEDES-BENZ CENTERS SUBJECT: Model GL-Class, ML-Class, and R-Class (X164, W164 and 251 platform) Model Year 2006 – 2012 Inspect Brake Booster – without Pedal Rework Mercedes-Benz AG, the manufacturer of Mercedes-Benz vehicles, has determined that on certain MY 2006-2012 ML-Class, GL-Class, and R-Class (164 and 251 platform) vehicles, the function of the brake booster might be affected due to advanced corrosion in the joint area of its housing. After extended time in the field and in conjunction with prolonged water exposure, this corrosion might lead to a vacuum leak at the brake booster. Loss of braking power puts me and everyone I am near while operating this vehicle in eminent danger!! This problem has been inspected and documented by Mercedes Benz of Macon Ga. 9-3-25 There were no warning lamps or messages present.

NHTSA ID

11685348

Incident

Sep 1, 2025

Fuel system failed carbon and shut off without any notification while driving two times put me at risk of getting hit both times as the vehicle was not in a safe spot. This has been confirmed at the dealership where my vehicle is at this point. It has been inspected by the dealership in Georgetown, Texas. Again, no warning lights just cut off two times while driving. I already had one recall fixed two times dealing with the fuel system and now it’s shutting off with no notice while I’m driving 60 70 mph and causing a dangerous safety hazard. Dealer stated… pressure regulator and control valve field as it is designed to maintain and regulate the amount fuel flowing into the engine.

NHTSA ID

11677894

Incident

Jul 11, 2025

On [XXX], while driving on the highway about 30 miles from Columbus, Ohio my 2013 Mercedez Benz ML350 suddenly stalled and lost power. There was no prior warning. Luckily, we were in the outer lane with no car close behind us so my husband slowly guided the car to the side road. The car has since been towed and is currently at the Service Department at Mercedez Benz of North Olmsted, Ohio, 44070, for repairs. I have been informed by the Service Manager that they have identified the fuel pump to the problem and that it needs to be replaced. Coincidentally, this vehicle went for Maintenance Servicing at the same dealership and was returned to me on Monday December 16th. No problem with the fuel pump was identified or reported to me. This vehicle is available for inspection About 4 years ago, the exact same incident happened with this same vehicle where it suddenly stalled and completely lost power on the highway in the middle of nowhere on our way from Ohio to Iowa. There was no prior warning. Similarly, the car was towed to Mercedez Benz North Olmsted but per the same service manager their inspection revealed no problem and the car restarted on its own so nothing needed to be fixed. I am reporting this recurring problem with my vehicle because of the obvious safety risk of sudden stalling and power loss on the highway, the fact that 4 years ago when this happened Mercedez Benz should have recognized what the issue was and replaced the fuel pump but did nothing about it, and also due to the fact that many Mercedez Benz vehicles have experienced this same problem leading to multiple recalls including many 2013 ML 350s. I believe my vehicle has a defective fuel pump from the manufacturer just like the recalled vehicles and that my vehicle and many more need to be recalled INFORMATION REDACTED PURSUANT TO THE FREEDOM OF INFORMATION ACT (FOIA), 5 U.S.C. 552(B)(6)

NHTSA ID

11632362

Incident

Dec 20, 2024

Single throttle lift-off clunking noise from the side shaft when moving off (audible at the outboard end). The noise is heard once in each instance when changing direction of travel. Note: Sound file in attachment Cause If the complaint is eliminated by experimentally loosening the outboard collar nut (by 1 turn), the problem is due to cracking of the microweld between the wheel bearing inner race and the joint housing of the side shaft. Note: The collar nut must always be replaced after being loosened. See also LI33.20-P-078406 Remedy Coat contact surface of side shaft with wheel bearing with Molykote paint. To do this, proceed as follows: 1. Remove side shafts 2. Clean contact surface A (see image file in attachment "Outer joint housing before") before coating with Molykote, using "spirit" (free of dust and grease) 3. Coat contact surface A (see image file in attachment "Outer joint housing after") with Molykote and leave to dry for "one hour" in removed condition 4. Reinstall side shafts Note: Before using the antifriction coating (Molykote), stir it or shake it thoroughly for (at least 1 minute).

Complaint Creaking noise, in irregular sequence when driving slowly in combination with slight steering movements and/or Creaking/crackling noises from the area of the wheel bearing on the front axle when cornering/ maneuvering. Sound file attached for comparison. MUST match noise for proper diagnosis. NOTE: Steering functionality is not affected. Cause Contact area between wheel bearing and steering knuckle. See also: LI35.30-P-058566 (Throttle Lift-Off Noise - Rear) LI33.30-P-056665 (Throttle Lift-Off Noise - Front) LI40.10-P-059248 (Wheel cracking noise when cornering) Remedy 1. Perform Operation A and evaluate by testing vehicle. 2. If noise is still present after re-testing: • If 192/232 chassis, verify FIN is in the listed range below in "Operation B" and perform. • If not 192/232 chassis or vehicle is a 192/232 not in the listed FIN range, additional verifications of where the noise is coming from are needed. Use multiple channel NVH method to narrow down location. Verify the LI's listed above were completed or if there are other similar noises associated with the chassis (Example: 192/232 also has under panel noises and an associated LI). Operation A: 1. Clean contact surfaces of wheel bearing and steering knuckle with brake cleaner (see areas marked blue in pictures "2.jpg" and "3.jpg"). NOTE: The front area of the wheel bearing and the seals must not come into contact with the cleaner, otherwise, the sealing rings will be damaged. 2. Clean threads of wheel bearing mounting. 3. Thinly coat contact surfaces of wheel bearing, steering knuckle, and axle mating face with Molykote (annular joint grease) (see areas marked blue in pictures "2.jpg" and "3.jpg"). NOTE: Axle mating face greasing is also covered in LI35.30-P-058566 and LI33.30-P-056665. Operation B (Only applies to 192 and 232 in listed FIN range): Only affects vehicles up to FIN end number: • Model series 192: xxx xxx xx 002 876 • Model series 232: xxx xxx xx 022 312 1. Replace steering knuckle. 2. Wheel bearings do not need to be replaced.

Complaint After successful commissioning of the HERMES control unit (N112/9) with XENTRY Diagnosis DVD 03/2026, the message "SOS - service not activated" appears on the instrument cluster. In addition, the following two conditions are also met: • HERMES (N112/9) control unit: event code B15CE00 is ACTIVE and STORED (A+S) • Vehicle Documentation System: For the HERMES control unit, the EID1, EID2, ICCID, IMEI, IMSI, TELNR fields in the "Identification/Serial number" column have the value "-" Cause Still under analysis Remedy Recommission the HERMES control unit (N112/9) with XENTRY Diagnosis 03/2026 and add-on 33399 installed or carry out the procedure with a newer version of XENTRY Diagnosis: XENTRY→ "N112/9 - Control unit for telematics services (HERMES)" -> "Adaptations" -> "Control unit commissioning" -> "Commissioning of previously installed control unit"

Complaint Creaking noise, in irregular sequence when driving slowly in combination with slight steering movements and/or Creaking/crackling noises from the area of the wheel bearing on the front axle when cornering/ maneuvering. Sound file attached for comparison. MUST match noise for proper diagnosis. NOTE: Steering functionality is not affected. Cause Contact area between wheel bearing and steering knuckle. See also: LI35.30-P-058566 (Throttle Lift-Off Noise - Rear) LI33.30-P-056665 (Throttle Lift-Off Noise - Front) LI40.10-P-059248 (Wheel cracking noise when cornering) Remedy 1. Perform Operation A and evaluate by testing vehicle. 2. If noise is still present after re-testing: • If 192/232 chassis, verify FIN is in the listed range below in "Operation B" and perform. • If not 192/232 chassis or vehicle is a 192/232 not in the listed FIN range, additional verifications of where the noise is coming from are needed. Use multiple channel NVH method to narrow down location. Verify the LI's listed above were completed or if there are other similar noises associated with the chassis (Example: 192/232 also has under panel noises and an associated LI). Operation A: 1. Clean contact surfaces of wheel bearing and steering knuckle with brake cleaner (see areas marked blue in pictures "2.jpg" and "3.jpg"). NOTE: The front area of the wheel bearing and the seals must not come into contact with the cleaner, otherwise, the sealing rings will be damaged. 2. Clean threads of wheel bearing mounting. 3. Thinly coat contact surfaces of wheel bearing, steering knuckle, and axle mating face with Molykote (annular joint grease) (see areas marked blue in pictures "2.jpg" and "3.jpg"). NOTE: Axle mating face greasing is also covered in LI35.30-P-058566 and LI33.30-P-056665. Operation B (Only applies to 192 and 232 in listed FIN range): Only affects vehicles up to FIN end number: • Model series 192: xxx xxx xx 002 876 • Model series 232: xxx xxx xx 022 312 1. Replace steering knuckle. 2. Wheel bearings do not need to be replaced.

Complaint Headlamp, front fog lamp leaky or fogged. Cause Fogging of the headlamps is a natural phenomenon, which can occur under certain climatic conditions. It does not lead to any technical impairment of the headlamp. If a pressure compensation diaphragm is fitted in the housing cover, then the lamp unit is a "closed system". Remedy Headlamp: Remedy 1 Clearing fogged/condensed LED headlamps: 1. Drive vehicle into workshop (temperature higher than +18 °C/+64.4 °F) and connect the exhaust extraction. Note: Do not perform an engine wash before the defogging test. 2. Switch off the engine and connect battery support via a charger. 3. Open the hood. 4. Switch on the lights. 5. Leave the vehicle in this state for 60 minutes. 6. Check for formation of condensation, a significant reduction in the formation of condensation must be clearly recognizable (thawing progress). Clearing of fogged/condensed LED headlamps and LED rear lamps on electric vehicles: 1. Drive the vehicle into the workshop (temperature higher than +18 °C/+64.4°F). 2. Connect battery backup via a charger. 3. Open the front-end flap and ensure sufficient ventilation. 4. Switch on the lights. 5. Leave the vehicle in this state for 60 minutes. 6. Check for formation of condensation, a significant reduction in the formation of condensation must be clearly recognizable (thawing progress). Clearing fogged/condensed halogen/xenon headlamps: 1. Drive the vehicle into the workshop (temperature higher than +18 °C/+64.4°F). Note: Do not perform an engine wash before the defogging test. 2. Switch off the engine. 3. Open the hood. 4. Switch off the lights. 5. Leave the vehicle in this state for 60 minutes. 6. Check for formation of condensation, a significant reduction in the formation of condensation must be clearly recognizable (thawing progress). Note: If there is no visible reduction in condensation, check the headlamp for malfunctions. (see Remedy 2) It is not physically possible to defog the headlamps completely. Fogging does not impair the operation or the service life of the headlamp. Note: Only implement Remedy 1 for model series 463 (from model year 2018) and model series 465. Remedy 2 A defective headlamp can be identified as follows: 1. Check the headlamp for external damage and that the cover caps and the diaphragm are correctly seated. 2. Check the electrical connectors of the plugs and pins. 3. Check for leak tightness according to LI82.10-P-078307. The test can only be conducted on headlamps. 4. If the headlamp or the rear lamp has any external damage, replace the component part in accordance with the WIS instructions. Note: External damage to the headlamp/rear lamp or faulty seating of the cover caps does not present a warranty or goodwill case. Note: With headlamps, it is possible to install desiccant packs if the problem occurs repeatedly. • Open ventilation system LI82.10-P-078302 • Closed ventilation system LI82.10-P-078304

Complaint Headlamp, front fog lamp leaky or fogged Cause Fogging of the headlamps is a natural phenomenon, which can occur under certain climatic conditions. It does not lead to any technical impairment of the headlamp. If a pressure compensation diaphragm is fitted in the housing cover, then the lamp unit is a "closed system". Remedy Headlamp: Remedy 1 Clearing fogged/condensed LED headlamps: 1. Drive vehicle into workshop (temperature higher than +18 °C/+64.4 °F) and connect the exhaust extraction. Note: Do not perform an engine wash before the defogging test. 2. Switch off the engine and connect battery support via a charger. 3. Open the hood. 4. Switch on the lights. 5. Leave the vehicle in this state for 60 minutes. 6. Check for formation of condensation, a significant reduction in the formation of condensation must be clearly recognizable (thawing progress). Clearing of fogged/condensed LED headlamps and LED rear lamps on electric vehicles: 1. Drive the vehicle into the workshop (temperature higher than +18 °C/+64.4°F). 2. Connect battery backup via a charger. 3. Open the front-end flap and ensure sufficient ventilation. 4. Switch on the lights. 5. Leave the vehicle in this state for 60 minutes. 6. Check for formation of condensation, a significant reduction in the formation of condensation must be clearly recognizable (thawing progress). Clearing fogged/condensed halogen/xenon headlamps: 1. Drive the vehicle into the workshop (temperature higher than +18 °C/+64.4°F). Note: Do not perform an engine wash before the defogging test. 2. Switch off the engine. 3. Open the hood. 4. Switch off the lights. 5. Leave the vehicle in this state for 60 minutes. 6. Check for formation of condensation, a significant reduction in the formation of condensation must be clearly recognizable (thawing progress). Note: If there is no visible reduction in condensation, check the headlamp for malfunctions. (see Remedy 2) It is not physically possible to defog the headlamps completely. Fogging does not impair the operation or the service life of the headlamp. Note: Only implement Remedy 1 for model series 463 (from model year 2018) and model series 465. Remedy 2 A defective headlamp can be identified as follows: 1. Check the headlamp for external damage and that the cover caps and the diaphragm are correctly seated. 2. Check the electrical connectors of the plugs and pins. 3. Check for leak tightness according to LI82.10-P-078307. The test can only be conducted on headlamps. 4. If the headlamp or the rear lamp has any external damage, replace the component part in accordance with the WIS instructions. Note: External damage to the headlamp/rear lamp or faulty seating of the cover caps does not present a warranty or goodwill case. Note: With headlamps, it is possible to install desiccant packs if the problem occurs repeatedly. • Open ventilation system LI82.10-P-078302 • Closed ventilation system LI82.10-P-078304