Conversion Regulations
All vehicle and engine conversions must meet standards instituted by the U.S. Environmental Protection Agency (EPA), the National Highway Traffic Safety Administration (NHTSA), and state agencies like the California Air Resources Board (CARB).
This section provides information on:
Emissions Regulations
Under the Clean Air Act, EPA has the authority to regulate vehicle emissions. Vehicles and engines from original equipment manufacturers (OEMs) must be certified to meet applicable emissions standards. Regulations are in place to ensure those emissions do not increase as a result of changes made to a vehicle or engine, including in a conversion. The Clean Air Act prohibits anyone from knowingly removing or rendering inoperative any device or design element installed on a certified vehicle or engine. These actions could be considered tampering, a violation that carries a significant fine.
EPA issued Mobile Source Enforcement Memorandum 1A (Memo 1A) in 1974 to help clarify what qualifies as tampering. Memo 1A was revised by an Addendum in 1997 and a Revision to the Addendum in 1998 to institute more stringent emissions requirements for vehicle and engine conversions. These regulations specify that if a conversion system is certified with EPA or CARB, the manufacturer is exempt from the tampering prohibition for that particular system.
Refer to EPA's Alternative Fuel Conversion website for the complete regulations, compliance procedures, and related information.
Manufacturers selling conversion systems for use in California must meet CARB requirements and obtain approval from CARB. EPA Certificates or tampering exemptions are not required, nor will they take the place of CARB certification. For information on CARB procedures and requirements, visit the Certification of Alternative Fuel Retrofit Systems section of the CARB website.
Safety Regulations
Vehicle conversions that require the addition of heavy battery systems or additional fuel tanks that may alter a vehicle's center of gravity, payload capacity, or handling characteristics may need to be safety crash tested and certified to comply with Federal Motor Vehicle Safety Standards (FMVSS) and/or other NHTSA regulations.
Demonstrating Compliance with EPA Regulations
All manufacturers must prove that a given vehicle or engine conversion complies with EPA regulations. Required demonstration and notification procedures differ according to the age of the converted vehicle or engine.
Vehicle owners and fleet managers interested in pursuing a conversion must work with the manufacturer or an authorized representative. The actual conversion work must be performed by a licensed technician associated with the manufacturer that holds the relevant emissions-related certifications and tampering exemptions.
New and Relatively New Vehicles and Engines: This category includes conversions that take place within a calendar year that is not more than one year after the original model year of the vehicle or engine. Vehicles and engines in this category need a certificate to qualify for an exemption from EPA's tampering prohibition. Manufacturers must submit applications to EPA, including test data, certification fees, and other information. EPA then issues a certificate to verify that the appropriate regulations and requirements have been met. Certificate documentation indicates the following:
- The original test group, as determined and provided by the manufacturer
- The evaporative emissions family
- The state(s) in which the test group is certified
- The "car line," which includes the model and engine size
- The model year of the vehicles included in the test group
- The emissions standards met.
A certificate is valid through Dec. 31 of the specified certification year (referred to as the Model Year at the top of the certificate). Certificates can be renewed, and when they do expire, tampering exemptions remain in place as long as the conditions under which a certificate was issued do not change.
Intermediate Age Vehicles and Engines: This category includes conversions of vehicles or engines that are no longer "new or relatively new" but still fall within EPA's definition of full useful life. Manufacturers of conversion systems designed for vehicles and engines within this category must demonstrate that the conversion meets emissions standards. EPA does not issue certificates for this category but will list the conversion systems online. Annual renewal is not required to maintain a tampering exemption, as long as the conditions under which the exemption was granted do not change.
Vehicles and Engines Outside Their Full Useful Life: This category includes conversions of vehicles or engines that are outside EPA's definition of useful life. Manufacturers must submit information showing the system is technically sound. As with the intermediate age category, EPA does not issue certificates but will publicly list the conversion systems as having satisfied the requirements. Annual renewal is not required to maintain a tampering exemption, as long as the conditions under which the exemption was granted do not change.
If certification or a tampering exemption has not been issued for a vehicle or engine you are interested in, a manufacturer may consider completing the certification process for that vehicle or engine. Manufacturers will usually provide cost estimates for converting your vehicle or fleet. See the Federal and State Incentives and Laws section to find incentives and other programs that could help offset conversion costs. Select Conversion Companies in the related links search to identify companies that manufacture or perform conversions.