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Mobile Sources

Introduction

Emissions from an individual car or passenger truck are generally low, relative to smokestack plumes that many people associate with air pollution. But in numerous cities across the country, the personal automobile is the single greatest pollution category, as emissions from millions of vehicles on the road add up. Driving a private car is probably a typical citizen’s most “polluting” daily activity. The power to move a car comes from burning fuel in an engine. Pollution from cars comes from by-products of this combustion process (exhaust) and from evaporation of the fuel itself. A wide range of information on pollution from mobile sources, including cars and trucks, and EPA’s programs to reduce pollution can be found on the EPA Office of Mobile Sources Homepage

What are the emissions of concern that come from cars and trucks?

HYDROCARBONS
Hydrocarbon emissions result when fuel molecules in the engine do not burn or burn only partially. Hydrocarbons react in the presence of nitrogen oxides and sunlight to form ground-level ozone, a major component of smog. Ozone irritates the eyes, damages the lungs, and aggravates respiratory problems. It is our most widespread and intractable urban air pollution problem. Volatile organic compounds (VOCs) are the most commonly tracked hydrocarbons and are emitted from the tailpipe and by the evaporation of fuel and refueling. About 31 percent of anthropogenic VOC emissions are from cars and trucks. A number of exhaust hydrocarbons are also toxic, with the potential to cause cancer.

NITROGEN OXIDES (NOx)
Under the high pressure and temperature conditions in an engine, nitrogen and oxygen atoms in the air react to form various nitrogen oxides, collectively known as NOx. Nitrogen oxides, like hydrocarbons, are precursors to the formation of ozone. They also contribute to the formation of acid rain. About 30 percent of NOx emissions are from cars and trucks.

CARBON MONOXIDE
Carbon monoxide (CO) is a product of incomplete combustion and occurs when carbon in the fuel is partially oxidized rather than fully oxidized to carbon dioxide (CO₂ ). Exposure to carbon monoxide reduces the flow of oxygen in the bloodstream and is particularly dangerous to persons with heart disease. About 60 percent of CO emissions are from cars and trucks.

PARTICULATE MATTER
Particulate Matter (PM) includes both fine and coarse particles. Fine particles (PM-2.5) result from fuel combustion including cars and trucks. Coarse particles (PM-10) generally result from vehicles traveling on unpaved roads with a small amount caused by combustion. These particles can accumulate in the respiratory system and are associated with numerous health effects. Exposure to coarse particles is primarily associated with the aggravation of respiratory conditions, such as asthma. Fine particles are most closely associated with increased hospital admissions and emergency room visits for heart and lung disease, increased respiratory symptoms and disease, decreased lung function, and even premature death. About 25 percent of anthropogenic PM-10 emissions are from cars and trucks.

GREENHOUSE GASES
Greenhouse gas emissions are primarily carbon dioxide (CO₂), which is a product of fuel combustion. CO₂ does not directly impair human health, but it is a "greenhouse gas" that traps the earth's heat and contributes to the potential for global warming. About 26 percent of anthropogenic greenhouse gas emissions are from cars and trucks.

In the Pacific Northwest, car and truck emissions are a higher percentage of total emissions than the national averages, primarily because there are fewer stationary industrial sources.

Inspection and Maintenance (Emissions Check Programs)

1. What is the difference between emission certification and emission inspection?

The emissions certification process applies to automotive manufacturers, not to individual passenger car or truck owners. Before an automobile manufacturer can sell a new model of any passenger car or truck in the United States, it must “certify” or guarantee that the new model meets stringent emissions standards. The Clean Air Act authorizes EPA to test new model passenger cars and trucks to ensure that they meet these emissions standards. This testing process is known as the Federal Test Procedure or FTP and is very rigorous and expensive, costing tens of thousands of dollars on average per vehicle model. If more than 40 percent of the new model vehicles tested fail to meet the emissions standards, EPA may deny or revoke a manufacturers “certificate” to sell the new model.

Emission inspection programs apply to individual passenger car or truck owners. These programs provide a way to check whether or not the emission control system on a vehicle is working correctly over the life of the vehicle. About 35 states design and operate Inspections and Maintenance (I/M) programs (also called Emissions Check Programs or Vehicle Inspection Programs), which include emissions inspection tests. Individual owners of passenger cars and trucks are required to have their vehicles inspected, and if necessary repaired, under these programs. The I/M test is used primarily to address gross polluters. Test fees average $20 to $25.

2. What is an emissions inspection test?

An emissions test under an Inspection and Maintenance (I/M) Program is designed to ensure that vehicles stay relatively clean from year to year. Through periodic checks (usually once every year or two) of pollution control equipment and repairs for vehicles that fail the test, the program encourages proper vehicle maintenance and discourages tampering with devices that control emissions.

Two types of tests are generally performed under an I/M Program. The first is a test of exhaust emissions from the tailpipe. The second test involves a visual inspection to ensure that important emission control components, like the catalytic converter, are present and operational. Cars that fail the test because of dirty exhaust or faulty emission controls must be repaired and re-inspected.

Some states, like Washington and Oregon, require more comprehensive and sophisticated emissions testing or “enhanced” programs. For example, in addition to testing the exhaust from the tailpipe, these programs address “evaporative emissions”, an increasingly important aspect of the pollution problem. Pollutants can escape into the air through fuel evaporation from the car’s hood and from the gas tank during refueling or from a leaking gas cap. Hydrocarbons, which contribute significantly to ground-level ozone or smog problems in many urban areas, is the primary pollutant of concern from evaporative emissions.

3. Am I required to have my car inspected?

Whether or not you must get your car inspected depends on where you live. Many states require Inspection and Maintenance (I/M) programs in certain areas to maintain or improve air quality and meet Clean Air Act requirements. Some states require annual inspection checks, while others require testing once every two years (biennially). Depending on the state, owners can have their vehicles inspected at government or privately owned inspection stations that do not perform repairs. Other states license service station and repair shops to do inspections. I/M tests are required in certain Pacific Northwest cities in Washington, Oregon, Alaska and Idaho. These areas or cities include Puget Sound, Spokane, Vancouver, Portland, Medford, Fairbanks, Anchorage, and Boise. For more information about the I/M program requirements in these areas, you may contact the following state environmental agencies:
Alaska DEC http://www.muni.org/healthesd/vehicle.cfm 907-343-4200 (Anchorage)
http://co.fairbanks.ak.us/Transportation/im/ 907-459-1005 (Fairbanks)
Idaho DEQ http://emissiontest.org/ 208- 377-9191 (Boise)
Oregon DEQ http://www.deq.state.or.us/aq/vip/ 1-877-476-0583 (Portland, Medford)
Washington State Department of Ecology http://www.ecy.wa.gov/programs/air/cars/automotive_pages.htm
1-800-453-4951 (Puget Sound, Vancouver, Spokane)

Additional information on Vehicle Inspection and Maintenance

4. Why is Inspection and Maintenance (I/M) needed?

Substantial reductions in vehicle emissions are essential in cities trying to achieve clean air. Depending on the sophistication of the program, I/M can reduce vehicle-related pollution (mostly hydrocarbon and carbon monoxide emissions) by 5 percent to more than 30 percent. A comprehensive I/M program can also yield reductions in nitrogen oxide emissions of up to 10 percent. Nitrogen oxides contribute significantly to the formation of ground-level ozone (smog). A well-designed I/M program remains the single most effective way to achieve major reductions in vehicle pollution.

Well-maintained vehicles generate less pollution and provide cost savings to vehicle owners. Regular maintenance will help ensure better gas mileage and performance, and can allow problems to be caught early before repairs get costly.

5. How much does an Inspection and Maintenance (I/M) test or emission inspection test cost?

The cost of an I/M test varies depending on where you live. Nationwide the cost to drivers for an I/M test ranges from $0 in a few states that subsidize the testing to as high as $60 in parts of California. Cost for the I/M or emission check test in the Pacific Northwest states are as follows: Washington ($12); Alaska (tests range from $25-50 in Fairbanks and Anchorage); Oregon ($21 in Portland and $10 in Medford); Idaho ($12 in Boise only)

6. How much are the repair costs if my car fails an I/M test?

Repair costs also vary considerably, depending on the cause of failure. EPA estimates the average bill nationwide to be about $100 to $150 per vehicle that fails the I/M test. The cost of some repairs is covered under emission performance or defect warranties required by the Clean Air Act or under other manufacturer warranties. States consider the model and year of a vehicle in setting the pass/fail cutoff for I/M tests. Older vehicles are not held to the same standard as newer models that are equipped with more sophisticated emission controls. In addition, most states waive some repair requirements if the cost exceeds a predetermined limit. Cost waiver limits vary by state. For more information on performance and defect warranties, see Questions 9 - 11.

Mileage Ratings/Fuel Economy

7. How do I interpret EPA mileage ratings or fuel economy estimates on cars?

There are two different fuel economy estimates or mileage ratings for passenger cars and trucks, one for city driving and one for highway driving. Each year the U.S. Department of Energy publishes the Fuel Economy Guide to aid consumers in considering the purchase of a new vehicle. The Guide lists estimates of miles per gallon (mpg) for each vehicle available for a new model year. To generate these two estimates, EPA requires tests on pre-production vehicles to represent typical everyday driving in a city and in a rural setting. The Guide is intended to help consumers compare the fuel economy of similarly sized passenger cars and trucks and special purpose vehicles, such as 2-and 4-wheel drive vehicles. In addition to the Guide, mpg ratings for individual vehicles appear on window stickers of all new passenger cars and trucks prior to sale.

There are many factors that impact fuel economy or mpg. No test can simulate all possible combinations of conditions, climate, driver behavior and car care habits. Actual mileage depends on how, when, and where the vehicle is driven. For example, keeping tires inflated to the manufacturers’ recommendations can raise or improve fuel economy, while traveling at higher speeds lowers fuel economy. Traveling at 65 mph instead of 55 mph lowers fuel economy over 15 percent.

Factors that Can Raise Fuel Economy
-Combine errands into one trip.
-Turn an engine off rather than letting it idle for more than a minute.
-Get tune-ups regularly; the car will run more smoothly and efficiently.
-Keep tires inflated to the manufacturer's recommended maximum pressure.
-Anticipate traffic stops.

Factors that Can Lower Fuel Economy
-Jackrabbit starts.
-Traveling at higher speeds: traveling at 65 mph instead of 55 mph lowers fuel economy over 15 percent.
-Carrying unnecessary weight in the vehicle.
-Revving the engine before it is shut off, which is not necessary for today's vehicles.
-Operating a vehicle with the front wheels out of alignment.
-Allowing a vehicle to “warm-up” for a long time.

More information on fuel economy including the new EPA milage standards for 2008.

8. How do I estimate motor vehicle emissions?

Emissions from a particular vehicle can only be determined accurately through laboratory testing of that vehicle. For average emissions estimates nationally or for specific areas (such as a given urban area), EPA maintains a computer program called MOBILE that estimates emission factors for major pollutants from gasoline-fueled and diesel highway motor vehicles. These emission factors are expressed in grams/mile (or in grams/minute for idling) for the following pollutants: hydrocarbons, carbon monoxide, nitrogen oxides. There is also a separate model for particulate emissions, known as PART. More information on certification test results for new cars.

Emissions Warranties

9. Is my passenger car or truck covered by an emissions warranty?

Federally required emission control warranties protect vehicle owners from the cost of repairs for certain emission-related failures that result from manufacturer defects in materials and workmanship, or that cause your vehicle to exceed federal emission standards. Emissions warranties vary depending on the model year of your car or truck and the mileage on your vehicle.

Emissions warranties for 1995 and newer passenger cars and trucks:

There are two types of emissions warranties that apply to 1995 and newer model year cars and trucks: “Performance Warranty” and “Design and Defect Warranty.”

PERFORMANCE WARRANTY (1995 and newer)
Emission control warranties protect vehicle owners from the cost of repairs for some emission related failures that are beyond the owners’ control. The Performance Warranty covers any repair or adjustment that is necessary to make your vehicle pass an approved, locally-required emission test, as long as your vehicle has not exceeded the warranty time or mileage limitations and has been properly maintained according to the manufacturer’s specifications.

The manufacturer must pay for all repairs necessary for your vehicle to pass the emissions test for the first 2 years or 24,000 miles, whichever comes first. Similarly, manufacturers must also cover the costs of repairing primary emission control parts in your vehicle for the first 8 years or 80,000 miles, whichever comes first. The major emission control devices are catalytic converters, electronic emissions control units or computers, and onboard emissions diagnostic devices or computers.

DESIGN AND DEFECT WARRANTY (1995 and newer)
The Design and Defect Warranty covers repairs of emission related parts which become defective during the warranty period. This warranty covers emission control and emission-related parts for the first 2 years or 24,000 miles of vehicle use, whichever comes first; and specified major emission control components for the first 8 years or 80,000 miles of use, whichever comes first.

Federal law requires the vehicle manufacturer to repair or replace free of charge an emission control or emission-related part (or a specified major emission control component) that fails because of a defect in materials or workmanship, as long as the vehicle has not exceeded the warranty time or mileage limitations for the failed part. To determine the length of warranty coverage that applies to your vehicle, look for the emissions warranty information in your owner’s manual or warranty book.

Emission control parts that are covered by the Design and Defect Warranty, and detailed information on emissions warranties for 1995 and newer model cars and trucks. (Note that parts may be given different names by different manufacturers and certain manufacturers may use more parts than another, so the list may not be complete for all vehicles.)

Emissions warranties for light-duty vehicle (passenger car or truck) model years 1981-1994

There are two types of emissions warranties that apply to 1981-1994 model cars and trucks: “Performance Warranty” and “Design and Defect Warranty.”

PERFORMANCE WARRANTY (1981 - 1994)
Emission control warranties protect vehicle owners from the cost of repairs for some emission related failures that are beyond the owners’ control. If your vehicle fails an emissions test, repairs may be covered if (1) your State or local government requires that you repair the car; and (2) the test failure did not result from misuse of the vehicle or a failure to follow the manufacturer’s written instructions. You must present the vehicle to a warranty-authorized manufacturer representative, along with evidence of the emissions test failure during the warranty period.

The manufacturer must pay for all repairs necessary for your vehicle to pass the emissions test for the first 2 years or 24,000 miles, whichever comes first. Similarly, manufacturers must also cover the costs of repairing primary emission control parts in your vehicle for the first 5 years or 50,000 miles, whichever comes first.

DESIGN AND DEFECT WARRANTY (1981 - 1994)
The Design and Defect Warranty requires that car manufacturers repair or replace a defective part on your vehicle free of charge if the following circumstances apply: your car is less than 5 years old and has less than 50,000 miles; and an original equipment part or system fails because of a defect in materials or workmanship; and the failure would cause your car to exceed federal emission standards.

More detailed information and a list of the emission control parts and emission related parts covered by the warranty. (Note that parts may be given different names by different manufacturers and certain manufacturers may use more parts than another, so the list may not be complete for all vehicles.)

10. Do emission warranties apply to used vehicles?

Yes. It does not matter if you bought your vehicle new or used from a dealer or anyone else. As long as the vehicle has not exceeded the warranty time or mileage limitations, the performance and design and defect warranties apply. IMPORTANT NOTE: Before buying a used vehicle, have the vehicle inspected to be sure that all of the emission control components as originally installed by the manufacturer are present and functioning properly. If emission control components are missing or have been tampered with, or the configuration of the exhaust system has changed, the emissions warranties on this vehicle may be void. In addition, if you live in an area with an Inspection and Maintenance program, the vehicle will probably not pass inspection unless you incur the expense of parts or repairs necessary for the vehicle to pass.

11. Do emission warranties apply for large (heavy-duty) gas or diesel vehicles, including motor homes?

Yes. Vehicles under 8500 pounds are classified as “light-duty” vehicles or trucks and are covered by the warranties for light-duty vehicles/trucks. Vehicles over 8500 pounds are classified as “heavy-duty engines” and are covered by the warranties for heavy-duty engines. Motor homes can fall in either category, depending on their weight. The warranties for heavy-duty engines are as follows:

Otto-cycle heavy-duty engines (most of which are gasoline-fueled) and heavy-duty diesel engines have an emissions defect warranty and emissions performance warranty of 5 years or 50,000 miles, whichever comes first. All other heavy-duty diesel engines have a warranty period of 5 years or 100,000 miles, whichever comes first. However, in no case may this period be less than the manufacturers’ basic mechanical warranty period for the engine family.

Beginning for model years 2004 and later, this period may not be less than the basic mechanical warranty period that the manufacturer provides (with or without additional charge) to the purchaser of the engine. Extended warranties on select parts do not extend the emissions warranty requirements for the entire engine but only those parts. In cases where responsibility for an extended warranty is shared between the owner and the manufacturer, the emissions warranty shall also be shared in the same manner as specified in the warranty agreement.

Nonroad or "Off-Road" Vehicles (e.g., Lawn & Garden Equipment, Boats, etc.)

12. How are nonroad (also referred to as “off-road” or “off-highway”) engines regulated?

EPA has been regulating passenger cars and trucks since the early 1970s and continues to set increasingly stringent standards for such vehicles. EPA has also developed programs for nonroad categories of mobile sources, which also contribute significantly to air pollution.

"Nonroad" is a term that covers a diverse collection of engines, equipment, and vehicles. Also referred to as "off-road" or "off-highway," the nonroad category includes outdoor power equipment, recreational equipment, farm equipment, construction equipment, lawn and garden equipment, and marine vessels. Though dealt with separately in the Clean Air Act, locomotives and aircraft can also be considered nonroad categories of equipment. Except for aircraft, nonroad equipment was not regulated by EPA prior to the mid-1990s. EPA's nonroad control programs assist states in complying with national air quality standards by significantly reducing the impact of nonroad equipment on the nation's air quality.

Emissions from the nonroad categories of engines are a significant source of oxides of nitrogen (NOx), volatile organic compound (VOC), and particulate matter (PM) emissions. In some areas of the country, emissions from nonroad engines represent a third of the total emissions of NOx and VOC from all mobile sources, including cars and trucks, and over two-thirds of emissions of PM from all mobile sources. In response, EPA initiated regulatory programs for several categories of nonroad engines. The following is a brief summary of EPA’s regulatory programs for the various nonroad equipment categories:

MARINE ENGINES
Like land-based nonroad engines, marine engines serve a wide variety of applications. The smallest marine engines, virtually all of which use gasoline, are used in recreational outboards and personal watercraft. Small gasoline or diesel marine engines provide auxiliary power on many vessels. Larger marine engines provide propulsion for both recreational and commercial applications. Recreational sterndrive and inboard engines tend to be gasoline, though diesel engines are making inroads into that market.

Commercial engines, virtually all diesel, power vessels such as tugs, ferries, and crew/supply boats. These engines also provide auxiliary power on larger vessels. The largest marine diesel engines, sometimes exceeding 60,000 hp, propel ocean-going vessels. EPA intends to have emission control requirements for all marine engines. Engines are grouped under three control programs reflecting their application and, to some extent, the fuel they use.

- Gasoline Outboards and Personal Watercraft Marine Engines
Gasoline outboards and personal watercraft contribute about 5 percent of the national mobile source VOC inventory. However, in areas with large boat populations, the contribution of these recreational marine engines may exceed 10 percent of the regional hydrocarbon inventory. These engines typically employ 2-stroke technology, which changed very little over the last 50 years. Regulations to control exhaust emissions from new outboards and personal watercraft went into effect in July 1996. The emission controls for these engines involve increasingly stringent standards over the course of a nine-year phase-in period beginning in model year 1998. By the end of the phase-in, each manufacturer must meet an emission standard, on a corporate-average basis, that represents a 75 percent reduction in hydrocarbons compared to unregulated levels. The gradually decreasing emission standard allows manufacturers to determine the best approach to achieving the targeted reductions over time. Manufacturers are able to phase in the types of control technologies in the most sensible way, while minimizing the cost impact to the consumer.

- Commercial Diesel Marine Engines
Commercial diesel marine engines contribute about 8 percent of the national mobile source NOx inventory, and about 1 percent of the national mobile source PM inventory. In areas with large commercial ports or near busy shipping lanes, the contribution of diesel marine engines to the local NOx and PM inventory may be much higher.

EPA proposed regulations for the control of exhaust emissions from new marine diesel engines in November 1998. The proposed emission limits, which vary depending on the size of the engine, are similar to emission limits for corresponding land-based nonroad or locomotive engines. These limits would apply beginning with engines manufactured in 2004. In addition, a more stringent set of emission limits will be evaluated in 2003. The more stringent emission limits would apply beginning with engines manufactured in 2008.

The proposed emission limits for very large commercial marine diesel engines are the same as those contained in Annex VI of the International Convention on the Prevention of Pollution from Ships (MARPOL). Consistent with MARPOL Annex VI, these proposed limits will apply to engines installed on ships constructed on or after January 1, 2000.

- Recreational Sterndrive and Inboard Engines
Recreational sterndrive and inboard engines can be either gasoline or diesel engines. While their contribution to national mobile VOC and NOx levels is smaller than the other two marine engine categories, their emissions are expected to increase due to the growing number of recreational vessels. EPA did not finalize emission limits for gasoline sterndrive and inboard engines as part of the 1996 marine rule. Likewise, EPA did not propose limits for recreational diesel engines in the commercial diesel engine rule. Consequently, these recreational engines remain unregulated at this time. EPA has started in a separate rulemaking to consider emission limits for these engines however.

LAND-BASED DIESEL ENGINES
Nonroad diesel engines, also referred to as compression-ignition engines, dominate the large nonroad engine market and comprise approximately 25 percent of the current mobile source NOx emissions inventory and 40 percent of the current mobile source PM emissions inventory. Examples of applications falling into this category include: agricultural equipment such as tractors; construction equipment such as backhoes; material handling equipment such as heavy forklifts; and utility equipment such as generators and pumps.

Under EPA regulations, diesel engines greater than 50 horsepower (hp) must comply with emission standards that are being phased in between 1996 and 2000, depending on the size of the engine. Under the these standards, EPA projects that NOx emissions from new diesel nonroad equipment will be reduced by over 30 percent from uncontrolled levels of unregulated engines. These standards do not apply to engines used in underground mining equipment, locomotives, and marine vessels. (The Mine Safety and Health Administration is responsible for setting requirements for underground mining equipment. Locomotives and marine vessels are covered by separate EPA programs.)

In August 1998, EPA adopted more stringent emission standards for NOx, hydrocarbons, and PM for new nonroad diesel engines, to be phased in over several years beginning in 1999. Engines used in underground mining equipment, locomotives, and marine vessels over 50 hp are not included. This comprehensive new program includes the first set of standards for nonroad diesel engines less than 50 hp to be phased in from 1999 to 2000. It also phases in more stringent standards for all engine sizes from 2001 to 2006, and yet more stringent standards for engines over 50 hp from 2006 to 2008. Finally, the new program includes a voluntary program to encourage the production of advanced, very-low emitting engines. Under these new standards, EPA projects that emissions from new nonroad diesel equipment will be further reduced by 60 percent for NOx and 40 percent for PM compared to the emission levels of engines meeting the original standards.

- Lawn & Garden Equipment (Small Land-Based Spark-Ignition Engines)
Small spark-ignition (SI) engines (e.g., engines operating on gasoline, natural gas, propane, or methanol) at or below 25 hp (19 kilowatts) comprise about 9 percent of the mobile source VOC inventory. These small engines are used primarily in lawn and garden equipment, such as lawn-mowers, string trimmers, edgers, chain saws, commercial turf equipment, and lawn and garden tractors.

Under Phase 1 of EPA’s regulations, new small engines must comply with emission standards for hydrocarbons, CO, and NOx beginning in 1997. The Phase 1 standards apply to all spark-ignition engines at or below 25 hp, except for those used in aircraft, marine vessels, and recreational equipment. EPA expects that these Phase 1 standards will result in a 32 percent reduction in hydrocarbon emissions from small spark-ignition engines. Phase 2 regulations, including more stringent emission levels and new provisions to ensure low in-use emissions, are being developed. The Phase 2 program may reduce combined emissions of hydrocarbons plus NOx from these engines by approximately 60 percent beyond Phase 1 levels.

- Large Land-Based Spark-Ignition Engines
Spark-ignition engines above 25 hp are currently not regulated by EPA. These engines are used in a variety of industrial equipment, including forklifts, airport ground-service equipment, generators, and compressors. The California Air Resources Board adopted new emission standards for these engines in October 1998. EPA intends to pursue an emission control program for these engines that would extend the California requirements to the rest of the nation. Application of basic automotive emission control technologies to this engine category would reduce NOx and hydrocarbon emissions by 70 to 90 percent.

Engines used in recreational applications, such as go-carts, all-terrain vehicles, and snowmobiles, are not currently regulated by EPA. EPA intends to pursue appropriate emission standards for these engines.

LOCOMOTIVES
Locomotives are estimated to contribute about 9 percent of the nationwide mobile source NOx emissions inventory. These engines are generally larger and last longer than any land-based nonroad diesel engines. In April 1998, EPA finalized emission standards for NOx, hydrocarbons, carbon monoxide (CO), PM, and smoke for locomotives. The new standards are expected to reduce NOx emissions by two-thirds, while hydrocarbon and PM emissions from these engines will decrease by 50 percent.

A unique feature of the locomotive program is that it includes emission standards for remanufactured engines, including all those that were originally built since 1973. Regulation of the remanufacturing process is critical because locomotives are generally remanufactured 5 to 10 times during their total service lives, which is typically 40 years or more.

Three separate sets of emission standards have been adopted, with applicability of the standards dependent on the date a locomotive is first manufactured. The first set of standards apply to locomotives and locomotive engines originally manufactured from 1973 through 2001, any time they are manufactured or remanufactured.

The second set of standards apply to locomotives and locomotive engines originally manufactured from 2002 through 2004. The locomotives and locomotive engines will be required to meet these standards at the time of original manufacture and at each subsequent remanufacture.

The final set of standards apply to locomotives and locomotive engines originally manufactured in 2005 and later. These locomotives and locomotive engines will be required to meet the applicable standards at the time of original manufacture and at each subsequent remanufacture. Electric locomotives, historic steam-powered locomotives, and locomotives originally manufactured before 1973 do not contribute significantly to the emissions problem and, thus, are not included in this rulemaking.

AIRCRAFT
Aircraft emissions comprise less than 2 percent of the mobile source NOx emissions inventory, but they are significant contributors to the NOx inventory in some cities. In addition, commercial aircraft emissions are a fast growing segment of the transportation emissions inventory. Aircraft emissions are potentially important contributors to global climate change and may also contribute to the depletion of the stratospheric ozone layer.

Emission standards for gas turbine engines that power civil aircraft have been in place for about 20 years. Such engines are used in virtually all commercial aircraft, including both scheduled and freight airlines. The standards do not apply to military or general aviation aircraft. Controls on engine smoke and prohibitions on fuel venting were instituted in 1974 and have been revised several times since then. Beginning in 1984, limits were placed on the amount of unburned hydrocarbons gas turbine engines can emit per landing and takeoff cycle.

In April 1997, EPA adopted the existing International Civil Aviation Organization (ICAO) NOx and CO emission standards for gas turbine engines. ICAO, a specialized agency of the United Nations, is the most appropriate forum for first establishing commercial aircraft engine emission standards due to the international nature of the aviation industry.

EPA is also exploring other ways to reduce the environmental effects associated with air travel throughout the nation. EPA is working with the Federal Aviation Administration (FAA) to encourage continuing progress in reducing emissions from airport ground service equipment and aircraft auxiliary power units. EPA sponsored compilation of technical data and emission inventory methods, which the FAA will use to develop an Advisory Circular for airlines and airport authorities interested in reducing emissions from these sources.

More information on nonroad engine programs

Heavy-Duty Vehicles (Trucks & Buses)

13. Does EPA regulate emissions from diesel trucks and buses?

Yes, EPA regulates emissions from, and has an emission certification process for, large, or “heavy-duty,” diesel engines used in trucks and buses. Trucks and buses have been regulated since the mid-1970s with progressively more stringent standards. In October 1997, EPA issued a new combined emission standard for oxides of nitrogen (NOx) and hydrocarbons (HC) for model year 2004 and later engines. EPA’s standards represent a 50 percent reduction in NOx from the 1998-2003 model year NOx standard. In 2020, EPA projects a reduction of 1.1 million tons per year in ozone precursors (NOx and Hydrocarbons) as a result of the new standard. PM is also a regulated pollutant for heavy-duty engines.

14. Are heavy-duty diesel trucks and buses required to pass an inspection and maintenance or emissions tests like passenger cars and trucks?

Many of the I/M programs include testing of diesel vehicles, but these tests apply only to those vehicles registered in the I/M test area. New heavy-duty engines must be certified by their manufacturers as meeting the appropriate standards for the year in which they are manufactured. Generally, the manufacturer continues to be responsible for meeting the standards for the useful life of the engine. For vehicles, I/M focuses on high levels of hydrocarbons, carbon monoxide, and nitrogen oxides due to deterioration, poor maintenance, and tampering. For trucks, several states have programs or are investigating programs targeting high smoke levels. EPA has worked with states on these programs and has issued guidance to help ensure consistency from state to state.

More information on heavy-duty highway engines.

Tampering &Replacement Parts and Engines

15. What is considered motor vehicle tampering?

The federal Clean Air Act prohibits motor vehicle emissions control tampering. The motor vehicle tampering provisions of the Clean Air Act apply to everyone. The Clean Air Act prohibits removing or rendering inoperative any emission control device or element of design installed on or in any motor vehicle or engine designed to meet federal standards. The tampering provisions also prohibit the manufacture, installation, sale or offering for sale of any part or component used on any motor vehicle, including motorcycles or motor vehicle engines, where the primary objective is to bypass, defeat, or render inoperative any emission control device, such as the catalytic converter, or element of design of any emission control system. The maximum civil penalty under this section of the Clean Air Act is $25,000 per violation for a manufacturer or dealer, $2,500 for any other person, . This law applies across the U.S. regardless of whether the vehicle is registered in an I/M test area.

16. How do I report vehicle tampering?

Vehicle emission control tampering in Alaska, Idaho, Oregon, and Washington can be reported to the EPA Regional office in Seattle, Washington. Contact EPA’s Public Environmental Resource Center at 1 (800) 424-4EPA or in Seattle, Washington at (206) 553-1200. EPA is responsible for enforcing the tampering provisions under the Clean Air Act. Consumer protection issues should be resolved with the better business bureau, state attorney general’s office or small claims court.

17. What replacement parts can be legally used in my vehicle?

Replacement parts related to emissions controls, such as carburetors and catalytic converters, are made by “aftermarket part” manufacturers to replace original equipment in a vehicle. These parts are legal to use as long as the manufacturer has shown that they are functionally identical to the part they are replacing and they do not increase emissions.

The California Air Resources Board (CARB) maintains a list of parts that have undergone an engineering evaluation. If the part or modification is shown to not increase vehicle emissions, it is granted an exemption to emission control system anti-tampering laws.
List of CARB evaluated replacement parts, or call CARB at (626) 575-6848.
Aftermarket catalytic converters guidance (PDF)

18. Can engines be replaced legally in passenger cars and trucks?

Entire engines can be replaced. As with any other replacement part, the replacement engine should be identical to the original. If the replacement block or engine is obtained without emissions equipment, all the equipment from the original engine must be installed on the replacement block. An engine family number should be located on a sticker on the original vehicle; the replacement engine should also come from a vehicle that has a sticker showing the same engine family number. The mechanic or person replacing an engine should ensure that the original engine and the replacement engine have the same engine family number before any work begins.

If the engine is not identical to the original then it is not a replacement part, instead it is considered an engine “change”. Engine changes entail modifications that must meet certain requirements to be legal. Engine changes are legal as long as the following requirements are met to ensure that the change does not increase pollution from the vehicle:

_The engine must be the same year as (or newer than) the vehicle.
_The engine must be from the same type of vehicle (passenger car, light-duty truck, heavy-duty truck, etc.) based on gross vehicle weight.
_If the vehicle is a California-certified vehicle then the engine must also be a California-certified engine.
_All emissions control equipment from the “donor” vehicle must be installed in the vehicle receiving replacement parts to ensure it is identical to the one that was certified to meet federal standards for the model year of the vehicle.

After an engine change, vehicles may need to be inspected by a state referee station. The vehicle will be reinspected to ensure that all the required equipment is in place, and may be required to have an emission test.

Used engines imported from Japan can be used as replacement engines as long as the engine being used has been identified as functionally identical to the original engine. Please refer to the engine importers catalogue to determine if a replacement engine is legal for installation in your vehicle.

Refrigerants & Automotive Air Conditioners

Information on the use of refrigerants in automotive air conditioning systems or call EPA’s Ozone Hotline at (800) 296-1996 between 10 a.m. and 4 p.m., Monday through Friday.

19. Do EPA regulations prohibit topping-off the refrigerant in my car without getting the leak fixed first?

EPA regulations do not dictate any particular service, as long as your service technician is certified to work with refrigerant and any recycling equipment used meets EPA standards. EPA does not require that leak repair be performed before refrigerant is charged into a vehicle, although certain states and localities may require leak repair. If your technician tells you that EPA requires evacuation and recharge and does not permit top-off, he or she is mistaken. For answers to other questions concerning automotive A/C servicing, check out the EPA fact sheet “Recharging Your Car's Air Conditioner with Refrigerant” or call EPA’s Ozone Hotline at (800) 296-1996 between 10 a.m. and 4 p.m., Monday through Friday.

20. How can I convert my car’s air conditioning system from using R-12 (Freon) to another refrigerant?

Guidelines for retrofitting vehicles from R-12 to substitute refrigerants are located in the EPA fact sheet “Guidance on Retrofitting to R-134a”. In addition, to find out which refrigerants have been listed by EPA as acceptable for use in automotive A/C systems, see “Choosing and Using Alternative Refrigerants”. You can also obtain these documents by calling the Ozone Hotline at (800) 296-1996.

Cars & Global Warming

21. How Can I Estimate the Carbon Dioxide Emissions from My Vehicle?

You can figure out about how much carbon dioxide your vehicle emits each year with this simple calculation:

Your vehicle's carbon dioxide emissions (tons per year)=
[miles you drive each year] divided by [miles per gallon multiplied by 100]

22. What Can I Do to Reduce the Carbon Dioxide Emissions from My Vehicle?

The carbon dioxide emissions from your vehicle are directly proportional to the amount of gasoline you use (i.e., the more gasoline you use the more carbon dioxide emissions you create.) Every gallon of gasoline yields about 20 pounds of carbon dioxide. There are many things you can do to reduce carbon dioxide emissions from your vehicles.

1. DRIVE FEWER MILES. Live as close to work, school, day care, family and friends, etc. as you can. "Trip chain" by combining errands as much as possible. Consider mass transit, carpool, bicycle or walking when feasible.

2. DRIVE EFFICIENT VEHICLES. Buy a new or used vehicle with as high of fuel economy as possible and consider the tradeoffs between fuel economy and other attributes such as size, power, and utility. If you or your family own more than one vehicle, try to drive the one with higher fuel economy as much as possible.

3. MAINTAIN YOUR VEHICLE. Keep vehicles in proper tune, pay attention to your "check engine" light and other on-board diagnostics, keep your tires properly inflated.

4. DRIVE GREEN. Do not drive too fast, avoid hard braking and jackrabbit starts, do not idle for long periods, use the air conditioner only when necessary, use overdrive for highway driving.

More information on greenhouse gas emissions from highway engines and nonroad equipment.

Introduction

Some individuals have expressed an interest in purchasing a vehicle from a foreign country and importing it into the U. S. for personal use. Also, U.S. citizens sometimes purchase a vehicle while living temporarily in foreign countries, and wish to bring the vehicle with them on their return to the U.S.

Because international emissions standards differ, the same vehicle model will typically be built to different standards for sale in different countries. Vehicles built for sale in the United States must meet U.S. emission requirements as established by the U.S. Environmental Protection Agency (EPA). Similarly, for a foreign vehicle to be imported into the U.S., that vehicle must also meet requirements established by EPA.

The following questions-and-answers allow an individual who wishes to import a vehicle to get a general idea about the applicable EPA requirements. This document is only a guideline to the more detailed requirements found in the EPA entry form 3520-1, and the EPA Automotive Imports Facts Manual. Prior to shipping your vehicle to the U.S., EPA strongly suggests that you view the Importing Vehicles into the U.S. guidance page and view the Automotive Imports Facts Manual about your specific situation.

General Questions: EPA’s Importation Requirements

1. Why should prospective car buyers be concerned with the EPA importations rules?

Knowledge of EPA’s requirements for importing vehicles may impact your buying decisions, especially if you are buying a car from another country. By knowing the rules beforehand, you can avoid unnecessary costs and problems, such as the risk of being unable to import your vehicle into the United States and having to pay for its return to its originating country.

2. Why has EPA established rules for importing vehicles from other countries?

EPA developed rules to make sure that imported vehicles meet the U.S. emission standards required under the Clean Air Act to protect public health and the environment. The rules require that a nonconforming vehicle that is permanently imported into the United States must generally be imported by an independent commercial importer (ICI) and be modified and tested to demonstrate that it meets the same EPA emission standards that apply to vehicles originally built for sale in the United States.

3. What is a ‘nonconforming’ vehicle?

A nonconforming vehicle is defined as any motor vehicle (car, truck, van, motorcycle, etc.) or heavy-duty engine (such as those contained in large buses and trucks) that was not originally manufactured to meet U.S. emission requirements.

4. Are there certain older vehicles that do not need to comply with the EPA’s importation rules?

Yes. The following vehicles are not covered by the Clean Air Act and, therefore, are not subject to the importation rules (excluded vehicles): (1) gasoline-fueled passenger cars and trucks originally manufactured before January 1, 1968; (2) diesel-fueled passenger cars originally manufactured before January 1, 1975; (3) diesel-fueled passenger trucks originally manufactured before January 1, 1976; (4) motorcycles originally manufactured before January 1, 1978; and (5) gasoline-fueled and diesel-fueled heavy-duty engines, such as large trucks and buses, originally manufactured before January 1, 1970.

These vehicles and engines can be imported by anyone. You may need to provide Customs with proof of vehicle age at the time of importation.

5. Can I import a vehicle from another country that does not meet U.S. emissions requirements?

No. You must arrange for the importation and other activities, such as necessary modifications or changes to your car and emissions testing, through an independent commercial importer (ICI). The ICI is authorized by EPA to modify nonconforming vehicles and import them according to U.S. emissions standards.

6. What are the responsibilities of the ICI when they import my car for me?

An independent commercial importer (ICI) is responsible for the following when they import your car: (1) performing all modifications necessary for your car to meet U.S. emissions standards and emission testing; (2) ensuring that the vehicle contains an emission label and vacuum hose diagram, and providing you with prepaid emission warranties and maintenance instructions for the vehicle; and (3) reporting the results of the modification and testing to EPA; and holding the vehicle for 15 working days (or longer if EPA wishes to examine the vehicle.)

7. May I import a “conforming vehicle” from another country?

Any individual may import a vehicle that meets the definition of a “conforming vehicle”, provided they supply proof that the vehicle meets U.S. emissions standards and all other requirements at the time of importation. This proof can be generally obtained from a U.S. EPA emission control label located on the vehicle engine which designates compliance with U.S. emission standards or an official letter from the original manufacturer stating that the vehicle to be imported is built to meet U.S. emission standards. A vehicle cannot be imported under a manufacturer letter for the purpose of resale.

8. Can I ask the dealer, seller or shipper of the vehicle to confirm that the vehicle meets the U.S. emission standards?

No. If you cannot prove the vehicle meets U.S. emission standards from any notable information on the vehicle itself, you must generally obtain this confirmation from the original manufacturer’s U.S. representative. In general, you will have to supply the manufacturer with the following information: vehicle make and model, engine size and vehicle identification number, as provided in the vehicle’s title. The manufacturer’s letter in response to you should also reference this information.

9. What kind of import forms do I need to fill out in order to bring my vehicle into the United States?

Most vehicles require an EPA Form 3520-1, Importation of Motor Vehicles and Motor Vehicle Engines, to be imported. This form must generally be completed for each vehicle imported into the United States. It is available from EPA’s Imports faxback system at (202) 564-9660, option 4.

10. Who Can I Call For Additional Assistance?

If I have a question about whether I can import a specific vehicle I own or am interested in buying from another country, who can I call?

Anyone who has additional questions regarding how to import their vehicle or needs clarification on the importation restrictions is welcome to call EPA’s national information line at (202) 564-9240.

11. Who do I contact if I need a special waiver, a special exemption or EPA approval to import my vehicle?

Anyone who needs special attention for approval of an importation request will need to call EPA’s Office of Mobile Sources national program at (202) 564-9660 or (202) 564-9240.

12. Who do I contact if I want to buy vehicles from other countries (such as Canada or Germany) and bring them to the United States to sell?

Generally, 1988 and later model year Canadian vehicles may be imported into the United States for resale, subject to certain conditions. Under most other circumstances, only an independent commercial importer can import vehicles from other countries for resale. It is recommended that interested parties reference the detailed faxback system information available at EPA’s Office of Mobile Sources national information line, at (202) 564-9660.

Other Importation Requirements

13. Are there other requirements which must be fulfilled prior to importing a vehicle?

Aside from meeting the U.S. emission requirements for a vehicle to be imported, Federal safety requirements must also be met. For information on compliance requirements, contact the U.S. Department of Transportation at (202) 366-5313 or by mail, at 400 7th Street, S.W., Room 6115, Washington, DC 20590.

14. Are there any other financial concerns to consider when importing a vehicle?

There may be a requirement to pay a “Gas Guzzler Tax” on certain vehicles which are imported into the United States. These taxes may range from $500 to $3,850 (charges are subject to change) per vehicle. Older vehicles, for instance, may be subject to this tax if it is determined that a particular model year is not considered fuel-efficient. For more information on whether a specific vehicle is subject to such a tax, contact the Internal Revenue Service at (202) 622-4920 or, by mail at Public Affairs Office, 1111 Constitution Avenue, N.W., Washington, DC 20224.

15. Are there certain State requirements that may also apply when considering the importation of a specific vehicle?

Some states, such as California, may have additional emission- and non-emission-related requirements before imported vehicles can be registered with that state. It is best to contact the specific state’s vehicle licensing department to ensure that all requirements are fulfilled prior to both importation into the U.S. and registration in the state. Many states require proof of legal entry into the country, and it is best to keep copies of all documents and confirmations submitted as part of the U.S. Customs entry process. Contact the specific state of the vehicle’s ultimate destination for full details and requirements for importing and registering the vehicle.

Imports from Outside the U.S.

16. How can I import a vehicle into the United States permanently for my own use?

An individual can import a vehicle if it is proven to be manufactured to meet U.S. emission requirements. The vehicle must be manufactured in accordance with specific EPA specifications (certificate of conformity), and must have a U.S. EPA emissions control label in the engine compartment that identifies (in English) that it conforms to all EPA requirements. If this label is not found on the vehicle, an official letter from the vehicle manufacturer’s U.S. representative confirming that the vehicle meets all U.S. requirements must accompany the vehicle. This type of letter is not accepted from vehicle dealers because they are not authorized to confirm U.S. emission conformity for the vehicles they sell.

17. What is a U.S. version vehicle?

A U.S. version vehicle is a vehicle built for sale and use in the U.S. The vehicle may have been built outside the U.S., to specific U.S. emission requirements. The vehicle will generally carry a U.S. EPA emissions control label.

18. Are all U.S. version vehicles automatically allowed to be imported?

No. EPA enforces certain requirements to restrict the importation of U.S. version vehicles in which the engine or emissions- related components are not in the original configuration. Any vehicle which has been modified or altered, or no longer can be considered EPA certified equivalent, will be “conditionally” imported under Customs bond; this is the responsibility of the importer. Under this conditional importation, the vehicle must be repaired or restored to the exact configurations or specifications that were certified by its manufacturer.

19. How can I import a U.S. version vehicle?

If the vehicle’s U.S. EPA emission control label is intact, and the vehicle emission control system is still in its original configuration, the vehicle owner need only complete the EPA entry form 3520-1 and present the form to Customs. However, if only a U.S. version vehicle’s catalyst, oxygen sensor and/or fuel filler neck restrictor were modified or removed for vehicle operation overseas, the vehicle owner may import the vehicle without bond by agreeing to replace those components upon importation.

Temporary Importations from Outside the U.S.

20. Can I temporarily import a vehicle into the United States?

Yes. However, your vehicle can only be temporarily imported if it falls within one of the following five circumstances:

(1) Anyone may import a vehicle solely for repair or alteration; however, a Customs bond will be required upon the vehicle’s entry into the U.S. The vehicle is prohibited from being driven on any public road or highway in the U.S., and it must be exported directly after the alteration or repair, or upon the expiration of the temporary exemption to import, whichever comes first.

(2) Anyone may import a vehicle for legitimate display purposes as established by the EPA. This import action requires a Customs bond to be posted upon entry to the U.S. The vehicle is prohibited from being driven on any public road or highway, cannot be sold, cannot be offered as a gift or prize, and must be exported or destroyed at the end of the display period or when the temporary exemption expires.

(3) A vehicle or engine can be temporarily imported for testing purposes involving research, investigations, studies, demonstration or training. The vehicle or engine may not be operated on public roads unless such an activity is an integral part of the testing program. Anyone may import a vehicle for testing purposes, but a Customs bond will need to be posted upon entry into the U.S. The vehicle must be exported or destroyed upon completion of the testing program or when the temporary exemption expires.

(4) A vehicle may be temporarily imported by a member of the armed forces of a foreign country, or a representative of an international organization, or personnel of a foreign government on assignment in the U.S. (must be within the class of persons for whom free entry has been authorized in writing by the U.S. Department of State.) A copy of the Department of State’s authorization or orders for duty in the U.S. for foreign personnel must be provided upon entry into the U.S. The vehicle may not be sold or otherwise transferred to another party in the U.S., and it must be exported at the end of the authorizing assignment.

(5) A vehicle may be temporarily imported by a nonresident who is a citizen of a foreign country, if he is temporarily residing in the U.S. and plans to use the vehicle for personal use. Only individual nonresidents may import a vehicle under this exemption. The vehicle must be used primarily for personal use by the importer or members of his/her family. EPA does not require a Customs bond be posted upon entry. The vehicle must be exported upon expiration of the time period authorized by Customs, or upon the importer’s departure from the U.S.

Imports From Canada

21. Can I buy a Canadian vehicle and import it to the United States for my own use?

Canadian vehicles are certified to Canadian requirements and originally manufactured for sale in Canada. While many are manufactured to be identical to the U.S. certified vehicles with respect to emission requirements, they may not have a U.S. emissions compliance label identifying them as conforming to U.S. EPA requirements.

In cases where the Canadian vehicle actually has a label which identifies it as conforming to U.S. EPA requirements, any individual may import this type of vehicle without EPA restriction. Most 1988 and later model year Canadian vehicles may be imported into the United States, subject to certain conditions. Consult the list of Canadian vehicles considered by EPA to conform with U.S. emission requirements, available from EPA’s Imports faxback system at (202) 564-9660, option 1. For other vehicles, the importer must obtain a letter from the manufacturer’s U.S. or Canadian representative (not a dealer) stating that the Canadian vehicle they wish to import was built to meet U.S. requirements.

22. Are there ways for me to import Canadian vehicles not considered U.S. version equivalent?

There are three additional situations in which an individual can permanently import their Canadian vehicle into the U.S. These include:

(1) If the Canadian vehicle is 21 original production years old or older, the importer can receive an ‘age exemption’ for the vehicle. The importer must be able to prove the original production years of the vehicle upon entry into the country. Original production years are calculated by subtracting the calendar year of the vehicle import date from the calendar year the vehicle was manufactured. There is no Customs bond requirement for this type of import.

(2) If any individual is changing permanent residency from Canada to the U.S., he/she may import that vehicle with the ‘immigrant exemption’. No Customs bond is required. The importer will need to show proof of permanent change in residency and proof that their vehicle was manufactured in Canada.

(3) Canadian residents may give or sell personal vehicles to an immediate family member who resides in the U.S. Immediate family members including, spouses, parents, grandparents, children, grandchildren, brothers or sisters, aunts, uncles, nieces, nephews or first cousins, may import such vehicles. The importer must supply proof that the vehicle is Canadian. In addition, the Canadian resident selling or giving the vehicle must prove that he/she originally purchased the vehicle for his/her own use (that is, a Canadian cannot buy a Canadian vehicle and then sell or give the vehicle to a U.S. citizen.) The Canadian resident must supply a signed statement, invoice or other evidence that this transfer of the vehicle is a sale, gift or inheritance.

23. Are there any other exemptions for importing Canadian vehicles?

Yes. Anyone may alternately be able to import a vehicle into the U.S. under the options provided for “non-U.S. version vehicles” if the importer and/or vehicle do not meet any of the circumstances allowed for importing Canadian vehicles. See the section on “non-U.S. version vehicles” for additional options for importing vehicles.

Importation of Non-U.S. Version Vehicles

24. What is a non-U.S. version vehicle?

“Non-U.S. version vehicles” are (1) not manufactured in conformity with U.S. emission requirements, or (2) not manufactured in accordance with a specific EPA certificate of conformity, or (3) not manufactured with a U.S. emissions compliance label in the engine compartment that identifies (in the English language) its conformity to all U.S. EPA requirements. Non-U.S. version vehicles also include any vehicle originally manufactured as a U.S. version vehicle, but has been altered or changed in such a way that it no longer complies with the U.S. requirements.

25. Can an individual import a non-U.S. version vehicle?

An individual may import a non-U.S. version vehicle only if the individual qualifies for an exclusion (see “General Questions”, #4), or an exemption from the emission requirements.. In some cases EPA approval must be obtained before the vehicle is cleared at Customs. See the EPA entry form 3520-1 for details, available from EPA’s Imports faxback system at (202) 564-9660, option 4.

26. How can an individual import a non-U.S. version vehicle if he/she does not qualify for the above exemptions?

There are four types of exemptions for non-U.S. version vehicles. Below is a description of each type of exemption along with the requirements and restrictions for importation:

(1) 21 years or older exemption: If the vehicle is 21 original production years old or older, it is exempted for importation into the U.S. Original productions years are calculated by subtracting the calendar year in which the vehicle is being imported from the calendar year it was manufactured. The owner must provide proof of the vehicle’s age. There is no Customs bond requirement.

(2) Hardship exemption: If an individual encounters “unforeseen cases of extreme hardship or extraordinary circumstances,” such as financial constraints or restrictions for a specific or special use vehicle, he/she is exempted to import his/her vehicle. For financial consideration, the importer must demonstrate to EPA’s satisfaction that the vehicle is needed for essential transportation, and the importer is unable, due to circumstances beyond his/her control, to afford either a “reasonable” used U.S. version vehicle or conversion of the non-U.S. version vehicle to meet the U.S. requirements. No Customs bond is required; however, the importer must receive approval for a hardship exemption from EPA before he/she can import the vehicle through Customs.

The following circumstances DO NOT fall under the definition of a “hardship exemption”: (1) the importer did not know that the vehicle needed to be converted to comply with U.S. requirements; (2) the importer did not find out or make attempts to estimate the general cost of converting a non-U.S. version vehicle to meet U.S. requirements, even if the cost exceeds the value of the vehicle; (3) costs, losses, or other difficulties associated with poor financial judgment or the acceptance of a high level of risk, such as purchasing a non-U.S. version vehicle for specific import to the United States without knowing whether or not it will meet U.S. emissions requirements; (4) change of geographical location caused by employment status or employer requirements, whether or not the requirement to change location of employment was given unexpectedly or with little notice; (5) and lack of cooperation from the vehicle manufacturer.

In requesting EPA approval of a hardship exemption, the importer must submit the following information: (1) the importer’s name, address and daytime phone number; (2) financial information which substantiates the hardship; (3) a description of the need for the vehicle to be imported; (4) and a description of the “unforeseen cases or extreme hardship” circumstances. The importer should make certain he/she keeps a copy of the EPA approval for future need.

(3) Identical to U.S. version vehicle exemption: If the vehicle, prior to importation, is identical in all material respect to a vehicle identified in an original equipment manufacturer’s certification application, an importer may bring the vehicle to the U.S. The importer must obtain a letter from the manufacturer’s U.S. representative stating the vehicle, at the time of manufacture, conformed to all U.S. emission requirements applicable to the appropriate model year. There is no Customs bond requirement; however, the importer must present the letter of documentation at the time of import. This exemption is not available for the purpose of resale.

(4) Modified to be identical to U.S. version vehicles: If the vehicle has been modified, prior to importation, to be identical in all respects to a vehicle identified in the original manufacturer’s certification application, the importer may bring the vehicle into the U.S. The importer must obtain a detailed letter from the manufacturer which outlines the necessary modifications to make the vehicle identical to its U.S. certified counterpart. Once these modifications are completed, the importer then needs to obtain EPA approval. The importer must submit to the EPA their name, address and daytime phone number, the vehicle information, the manufacturer’s letter specifying necessary modifications and a clear copy of the paid invoice documenting that the necessary parts and changes were made to the vehicle to match the manufacturer specifications. This exemption is not available for the purpose of resale. The importer should keep copies of all documents for future needs.

Independent Commercial Importers (ICIs)

27. What is an Independent Commercial Importer (ICI)?

An ICI is an independent commercial importer that is registered with EPA. An ICI is not the original vehicle manufacturer, but does have a contractual agreement with the original manufacturer to act as its authorized representative for the distribution of vehicles or engines into the U.S. market. ICIs act independently of the original manufacturer, but must follow the same emission requirements imposed on the manufacturers. All ICIs are located in the United States.

28. What must an ICI do to be in compliance with its EPA Vehicles Program and Compliance Division registration?

For more information regarding ICI compliance requirements, program responsibilities and becoming an ICI, contact EPA’s national program office at (202) 564-9240.

29. In what case is an ICI required for importing a vehicle?

ICIs import vehicles into the U.S. for modification and testing purposes so that the vehicles, upon final admission by EPA, comply with Federal emission requirements. If a vehicle is a non-U.S. version, and it is ineligible for exemption or exclusion, then the vehicle must be imported through an ICI.


Document# EPA 910-B-99-005

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