EPA Vehicle & Engine (VNE) Compliance for Importations

Owned by Sarai Sepulveda
Jul 08, 2024
4 min read

EPA Regulates Mobile Sources

  • Cars, motorcycles, trucks, ATVs, trains, boats, ships, lawnmowers, chainsaws....

  • Such vehicles and engines must be certified by EPA

  • Certification is most easily demonstrated by the presence of an EPA Emission Control Information (ECI) Label

  • Imports of aircraft and aircraft engines are regulated by FAA, not EPA

Which Mobile Source Equipment is Regulated and Since When?

  • Light Duty Vehicles: 1970s

  • Motorcycles: 1978

  • Heavy Duty Engines: 1980s

  • Nonroad Compression Ignition (CI): 1996

  • Nonroad Small Spark Ignition (SI): 1997

  • Marine Spark Ignition: 1998

  • Locomotive: 2000

  • Marine Compression Ignition: 2004

  • Large Spark Ignition: 2004

  • Recreational Vehicles: 2006

  • Stationary IC Engines: Diesel: 2007 Gasoline: 2009

image-20240705-165922.png

Examples

image-20240705-170031.png

Larger Machines

Other Unique Items

Yes, all are regulated

  • The pictures above included a scooter, UTV, snowmobile, a truck, motorcycles, a gas-powered chainsaw, large nonroad equipment and an engine for a bicycle. All of these are required to be certified by EPA if they are imported unless they are eligible for an exemption or exclusion.

What do Brokers/Importers need to show Compliance?

  • Submission of either EPA Form 3520-1 (ACE Doc ID 942) or EPA form 3520-21 (ACE Doc ID 943)

  • Make sure to indicate if vehicle is certified or exempted from certification

  • Engine family names assigned to certified engines/vehicles and displayed on emission control information labels on the engine/vehicle are recorded in LPCO field of PG14

  • Engine Family Naming Conventions

Example of an EPA Label with Emission Control Information

Format of EPA Engine Family or Test Group Names

A family name is a 12 character code that identifies all parts of that particular engine.

The typical naming convention is shown below, although some sectors have slight variation.

Example of Labels Without Emission Control Information

How do Brokers & Importers declare vehicles or engines?

EPA Form 3520-1

(Ace Doc ID 942)

  • Motor Vehicles

    • Motorcycles

    • Light duty cars and trucks

EPA Form 3520-21

(ACE Doc ID 943)

  • Marine Engines

  • Heavy Duty highway engines

  • Non-road Gas Engines (generators, chainsaws, lawn mowers, etc.)

  • Non-road Diesel Engines (tractors, excavators, etc.)

  • Recreational Vehicles (ATVs, UTVs, etc.)

EPA Declaration Form 3520-1

EPA Declaration Form 3520-21

 

How can I avoid long delays at the port as a Broker/Importer?

  • File for Entry early and submit all relevant EPA/CBP documents

  • If submitting information electronically using ACE, make sure the correct engine family name or exemption code is included

What are we currently seeing as the biggest problems?

  • MY2004 and newer Tampered Diesel Trucks (trucks with the emission controls removed)

Logo = Diesel??

How can I tell if a Truck is Tampered?

Look under the vehicle and see if a new straight pipe has been installed

What is wrong with straight pipes?

  • Most MY2004 and newer diesel pickup trucks have emission control systems that control emissions from the engine

  • The bulges in the previous picture are indicative of emission control systems present

  • Straight pipes have no emission control systems and therefore no bulges

Used excavators and other large diesel-engined machines

What is the problem?

  • Since 2015, large diesel-engined nonroad equipment must meet Tier 4 standards.

  • Tier 4 standards generally require aftertreatment equipment.

  • Unscrupulous vendors abroad are offering “great deals” on uncontrolled non-compliant equipment with forged serial number plates and EPA labels.

  • Importer is liable for importing non-compliant equipment.

Examples of false labels

Resources

For guidance prior to importation:

Once importation has occurred: