United States Air And EPA-420-F-93-002A
Environmental Protection Radiation January 1993
Agency (6405-J)
v>EPA Automotive
Imports
Fact Sheet
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
- .. ¦ __ . - * AIR AND RADIATION
AUTOMOTIVE IMPORTS FACT SHEET
Page
A. IMPORTERS BEWARE! A-l
B. IMPORTING NONCONFORMING VEHICLES
Introduction B-l
Background B-l
Importation Requirements B-l
Vehicles That Must Be
Entered By a Certificate Holder B-3
Phase-In Period B-4
Certificate Holder
Compliance Requirements B-5
Exemptions and Exclusions B-5
Other Requirements B-9
C. IMPORTING CANADIAN VEHICLES
Importation By An Individual C-l
Importation By A Commercial Entity C-4
Special Importations C-5
Vehicles Made For Sale In Canada
That Meet U.S. Emission Requirements C-6
D. U.S. VERSION VEHICLES DRIVEN OVERSEAS
Catalytic Converter D-l
Protecting Your Converter D-2
EPA's Policy D-3
Demonstrating Compliance
With Federal Emission Requirements D-3
Plumbtesmo Test Report Form D-6
Catalytic Converter Replacement Form D-8
Catalyst Control Programs Approved By EPA D-9
E. FOR ADDITIONAL INFORMATION E-l
ATTACHMENTS:
Manufacturers U.S. Representatives List
Application For EPA Pr'ior Written Approval
Current List Of Independent Commercial Importers
* U.S. Environmental Protection Agency emission requirements only
Revised 11/2/92
Printed on Recycled Paper
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AUTOMOTIVE IMPORTS FACT SHEET
(U.S. Environmental Protection Agency Requirements Only)
DISCLAIMER:
This fact sheet is produced by the U.S. Environmental Protection Agency (EPA)
and is updated periodically. It is the responsibility of the importer to refer
to the most recent version of the fact sheet when importing motor vehicles.
Updates to the fact sheet may be obtained from the EPA free of charge. See
Attachment 2 of the fact sheet for ordering address and phone number.
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A-l
IMPORTERS BEWARE!
1) The EPA policy which permitted a first-time individual
importer to import one nonconforming vehicle at least five
model years old without the need to meet Federal emission
standards WAS ELIMINATED AS OF DECEMBER 31, 199 0.
2) EPA STRONGLY RECOMMENDS THAT YOU BUY A VEHICLE THAT IS
LABELED BY THE MANUFACTURER AS MEETING U.S. EMISSION
STANDARDS. because of the expense and potential
difficulties involved with importing a vehicle not originally
built to meet U.S. emission requirements.
3) FOR U.S. VERSION VEHICLES DRIVEN OVERSEAS, a bond may
be required to be posted upon entry into the U.S. For U.S.
version vehicles driven in Europe, the bond may be avoided if
the vehicle participates in, and is shipped by, one of the EPA
approved catalyst control programs. See Section D for
details.
4) U.S. VERSION VEHICLES THAT HAVE BEEN MODIFIED OR
ALTERED ARE CONSIDERED TO BE NONCONFORMING VEHICLES.
THEY ARE NO LONGER U.S. VERSION VEHICLES. (i.e.,
modifications, alterations, or substitutions of the
engine, emission control system, transmission,
transaxial, differential fuel system or any other feature
that defines the exact vehicle configurations that are
certified by the manufacture.)
5) NOT ALL NONCONFORMING MOTOR VEHICLES ARE ELIGIBLE FOR
IMPORTATION UNDER THE IMPORT REGULATIONS. Authorized
independent commercial importers (ICIs) are allowed to import
only certain vehicles based on what certificates of conformity
they have obtained. In addition, an ICI may choose not to
import a vehicle that it is eligible to import. For example,
no ICI has chosen to import any motorcycle and ICIs seldom
choose to import diesel-fueled vehicles.
6) Before buying or shipping a nonconforming motor vehicle/
EPA strongly recommends that final arrangements be made with
an ICI, or that written Ef>A prior approval or exemption be
obtained, otherwise, costly storage fees may be assessed at
the port of entry and/or the vehicle may not be eligible for
importation.
Revised 11/2/92
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IMPORTING MOMCONFORMING VEHICLES
I. INTRODUCTION
On September 25, 1987, the U.S. Environmental Protection
Agency (EPA) adopted new rules for importing motor vehicles and
motor vehicle engines that, at the time of entry into the United
States, do not conform with Federal emission requirements.
Vehicles being imported into the United States that do not comply
with U.S. emission standards are generally European luxury
automobiles. Because these vehicles were originally built for sale
in Europe (and elsewhere), they generally are not designed to meet
emission requirements in the United States. These rules are
effective for all vehicles imported after June 30. 1988.
II. BACKGROUND
The regulations governing EPA's program for the importation of
vehicles that do not comply with U.S. emission requirements were
originally provided for in 1972 pursuant to the Clean Air Act
(Act) . Section 203 of the Act prohibits the importation of any new
motor vehicle or engine (hereafter referred to as "vehicle") not
covered by a certificate of conformity unless it is exempted by EPA
or otherwise authorized jointly by EPA and the U.S. Customs Service
(Customs) regulations. With respect to imported vehicles, Section
216 of the Act defines an imported vehicle as a "new" motor
vehicle. Therefore, every vehicle imported into the United States
is considered a "new" motor vehicle under the Imports regulations.
Such regulations are appropriate to ensure that imported vehicles
are brought into conformity with applicable emission standards.
The authority to allow importation of such "nonconforming vehicles"
is discretionary with EPA and Customs. Customs will not permit
admission of your vehicle until both emission (EPA) and safety
(.(Department of Transportation) requirements are met.
III. IMPORTATION REQUIREMENTS
The Act requires that new or used vehicles (cars, trucks,
motorcycles, or heavy-duty engines) imported into the U.S. comply
with Federal emission requirements. (Certain vehicles are not
subject to Federal emission requirements due to date of
manufacture; refer to section VII. A. for a list of these
vehicles).
Revised 11/2/92
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There are basically two vehicle categories which are subject
to import restrictions:
A. Vehicles manufactured in conformity with U.S. emission
requirements and originally equipped with a catalytic
converter and/or oxygen sensor and operated outside the U.S..
Canada. Mexico. Japan, \ustralia. Taiwan and Bahama Islands.
Vehicles in this category will contain U.S. emissions
compliance labels that will identify them as such in the English
language and may be imported by individuals. For more information
on vehicles falling within this category and their importation
reguirements, please refer to Section D of this fact sheet.
B. Vehicles which were not manufactured in conformity with U.S.
emission requirements.
These vehicles will not be labeled1 as complying with U.S.
emission reguirements. The rules do not prohibit an individual,
such as one who might vacation in Europe and return with a
nonconforming European built vehicle, from importing a vehicle into
the U.S. Instead, the rules reguire individuals to arrange for
such importations through an independent commercial importer (ICI)2
holding a valid EPA "certificate of conformity".3
1/ HOW TO FIND THE U.S. EMISSIONS COMPLIANCE LABEL
1) 1971 and later conforming vehicles will have a label in
the engine compartment entitled "Vehicle Emission Control
Information" which will contain the name and trademark of
the manufacturer and an unconditional statement of
compliance with EPA emission regulations. For
MOTORCYCLES, this label will be on the frame,
2) 1968 through 1970 conforming motor vehicles will have a
label on the doorpost indicating compliance with Federal
motor vehicle safety standards, and
3) 1967 and earlier motor vehicles are excluded from meeting
U.S. emission reguirements and will not have a compliance
label.
2/ "Independent commercial importer or ICI" means a commercial
importer who is not an original eguipment manufacturer (like
Mercedes-Benz) and who does not have a contractual agreement
with an original eguipment manufacturer to act as its
authorized representative "for the distribution of vehicles or
engines into the U.S. market.
3/ A "certificate of conformity" is a document issued by EPA to
a manufacturer or ICI to certify a particular class of
vehicles (like Mercedes-Benz 500, 5.0 liter engine having a
specific emissions configuration) which has been tested and
shown to be capable of meeting U.S. emission requirements.
Other vehicles in the manufacturer's or ICI's production line
are built or modified to be identical to the prototype vehicle
as described in the manufacturer's or ICI's application for
certification.
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ICI certificate holders bear the responsibility not only for
performing all necessary modifications and testing, but also for
assuring compliance of the vehicles they import with EPA emission
requirements for 5 years/50,000 miles. In effect, this imposes on
certificate holders the same emission requirements imposed on
original equipment manufacturers (OEM) by the Act. Further, these
vehicles must be held by the ICI for at least 15 Federal working
days after the modifications and testing to allow EPA the
opportunity to inspect the vehicles. These vehicles would be part
of the certificate holder's "production line" and the certificate
holder would be responsible for complying with all requirements for
the vehicles they modify, whether or not they are actually owned by
the certificate holder. A certificate holder must explicitly agree
and comply with these responsibilities before EPA will approve the
final admission of the vehicle into the U.S. (See also Section VI:
Certificate Holder Compliance Requirements)
IV. VEHICLES THAT MUST BE IMPORTED BY A CERTIFICATE HOLDER
WARNING: Not all vehicles are eligible to be imported.
Eligibility varies from year to year and may vary with the
certificate holder. You need to determine whether your
vehicle is eligible to be imported by a certificate holder and
make arrangements just prior to purchasing and shipping your
vehicle I You may contact one of the certificate holders
listed on Attachment 3 to determine if that certificate holder
is qualified and willing to import your vehicle.
A. Vehicles less than six years old4
Imported nonconforming vehicles less than six years old must
be modified so as to be covered by a certificate of conformity.
Whether a vehicle may be imported depends on several factors
(including the year in which the vehicle will be imported and
whether the certificate holder has a certificate for a vehicle like
yours). An ICI certificate holder wishing to import these vehicles
must either: 1) obtain an EPA certificate of conformity for the
model/model year (for example, Mercedes-Benz 500 originally
manufactured in 1990) it desires to import, or 2) obtain EPA prior
written approval to use the vehicles as prototypes to obtain the
certificate of conformity. After modification of the vehicle,
every third vehicle must be tested to measure its emissions.
4/ For the purposes of EPA regulations, a vehicle's age is
determined by subtracting the calendar year in which it
was originally manufactured from the calendar year of
importation. For example, a vehicle built by a European
manufacturer in 1986 and imported into the U.S. in 1988
would be two years old.
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B—4
B. Vehicles six years old or older
Any vehicle six years old or older may be imported by any ICI
holding a valid certificate of conformity if the ICI certificate
holder is willing to be responsible for modifying and testing the
vehicle and complying with the other emission requirements.
Vehicles imported by a certificate holder under this option are
subject to a "modification/test" procedure rather than the
certification procedure outlined above. EPA permits entry of these
older vehicles under the "modification/test" procedure in part to
provide a greater degree of models available to consumers.
C. Vehicles twenty-one years old or older
Any vehicle twenty-one years old or older may be imported by
any ICI holding a valid certificate of conformity. Modifications
and testing are not required. Vehicle age is calculated by
subtracting the year of manufacture from the year of importation.
V. PHASE-IN PERIOD
EPA provided for a five year phase-in period for the
certification program beginning in 1988, which expired December 31,
1992.
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B-5
VI. CERTIFICATE HOLDER COMPLIANCE REQUIREMENTS
A certificate holder who imports your nonconforming vehicle is
responsible for:
1) Performing all modifications and emission testing, if
required, within 120 days after the vehicle enters the United
States,
2) Reporting the results of the modification and testing (if
required) to EPA and holding the vehicle for 15 working days
beginning with the date that EPA receives this report (or
longer if EPA so notifies the certificate holder). During
this period and the period preceding this report, the vehicle
cannot be sold, offered for sale, returned to the owner, or
driven on public roads or highways.
3) Bearing responsibility for the vehicle's compliance with
emission standards over the vehicle's useful life.6 This
includes pre-release inspections and subsequent recall
requirements.
4) Ensuring that the vehicle contains an emission label and
vacuum hose diagram, as well as providing you with prepaid
emission warranties and maintenance instructions for the
vehicle.
5) Performing fuel economy tests and providing you with gas
guzzler tax forms.
VII. EXEMPTIONS AND EXCLUSIONS
A. Exclusions based on aae7 of vehicles or engines
The following vehicles are excluded from the emission
requirements of the Act and may be imported without a bond by any
individual or business (although the importer must file with U.S.
Customs, upon entry, an EPA Form 3520-1, declaring entry category
"R" through "V" as applicable):
6/ The useful life of an imported nonconforming vehicle or engine
begins when the certificate holder sells the vehicle or
delivers it to its owner. For cars, the useful life is five
years or 50,000 miles, which ever occurs first.
a
7/ Vehicles or motorcycles which satisfy any of the criteria
in 1-4 may no longer satisfy the criteria if they have
been upgraded with newer engines.
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1) Gasoline-fueled light-duty vehicles and light-duty trucks
originally manufactured prior to January 1, 1968. (EPA Form
3520-1 declaration category MRM)
2) Diesel-fueled light-duty vehicles originally manufactured
prior to January 1, 1975. (EPA Form 3520-1 declaration
category "S")
3) Diesel-fueled light-duty trucks originally manufactured prior
to January 1, 1976. (EPA Form 352 0-1 declaration category "T")
4) Motorcycles originally manufactured prior to January 1, 1978.
(EPA Form 3520-1 declaration category "U")
5) Gasoline-fueled and diesel-fueled heavy-duty engines
originally manufactured prior to January 1, 1970. (EPA Form
3520-1 declaration category "V")
6) Methanol-fueled vehicles and engines originally
manufactured prior to January 1, 1991. (EPA Form 3520-1
declaration category "Y")
B. "Identical to Certified U.S. Version" Exemption
PROVE PRIOR TO IMPORTATION THAT THE VEHICLE IS IDENTICAL, IN ALL
MATERIAL RESPECTS, TO A VEHICLE IDENTIFIED IN AN ORIGINAL EQUIPMENT
MANUFACTURER'S (OEM's) CERTIFICATION APPLICATION.
This exemption is available for use of the vehicles in the U.S. by
the current owners. This exemption is not allowed for the purpose
of resale of the vehicles in the U.S.
Two options are available:
1) The owner must obtain a letter from the OEM's U.S.
representative (for a list see Attachment 1) attesting to the
compliance of the vehicle. The letter must contain an
unconditional statement that the vehicle (make, model, model
year, VIN), at the time of manufacture, conformed to all U.S.
emission requirements applicable to the appropriate model
year. You must then obtain prior written approval from EPA
before you attempt to import. To obtain prior written
approval from EPA, you must provide:
a) A completed application for prior written approval
(Attachment 2) . These importations will be covered under the
"Hardship Exemption" (code letter M) as described on the
application form.
b) The original letter described above from the U.S.
representative of the manufacturer on company letterhead.
NOTE: Regardless of the requirements above being
satisfied, a vehicle is not eligible for this exemption if
it has been modified or altered such that the vehicle
configuration is not covered under the manufacturer's
certificate of conformity.
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2) MODIFY THE VEHICLE (PRIOR TO IMPORTATION) TO MAKE IT
IDENTICAL, IN ALL MATERIAL RESPECTS, TO A VEHICLE IDENTIFIED IN
AN OEM'S CERTIFICATION APPLICATION. The owner must obtain a
letter from the OEM's U.S. representative (for a list see
Attachment 1) outlining the necessary modifications to make the
vehicle identical to it's U.S. certified counterpart. The letter
must list specific parts (including part numbers)
which must be installed or replaced to bring the vehicle into
conformity. The individual must then have the vehicle modified
in accordance with those modification instructions. After the
modifications are completed, the individual may then obtain prior
written approval from EPA before attempting to import. To obtain
prior written approval from EPA, the individual must provide:
a) A completed application for prior written approval
(Attachment 2). These importations will be covered under the
"Hardship Exemption" (code letter M) as described on the
application form.
b) The original letter described above from the U.S.
representative of the manufacturer on company letterhead.
c) A clear copy of the paid invoice documenting that the proper
parts (including part numbers) were installed or replaced and
any necessary adjustments were made.
NOTES:
1) Regardless of the requirements above being satisfied, a
vehicle is not eligible for this exemption if it has been
modified or altered such that the vehicle configuration is not
covered under the manufacturer's certificate of conformity.
2) Generally, EPA only accepts compliance information from the
OEM's U.S. representative. However, as an exception to this
rule, statements of conformity will be acceptable to EPA as
evidence of conformity from General Motors of Canada if they are
signed by a representative of the Vehicle Emission Compliance
Department. This policy of accepting letters from someone other
than the U.S. representative of the vehicle manufacturer does not
apply to other manufacturers at this time.
C. Racing Exclusion
YOU MUST RECEIVE EPA'S PRIOR WRITTEN APPROVAL FOR THIS TYPE
OF IMPORTATION. NOT ALL RACING VEHICLES ARE EXCLUDED FROM
EMISSIONS COMPLIANCE. Racing vehicles which are not capable of
being operated on streets/highways AND which are to be used only
for racing events are excluded from the emission requirements of
the Act and may be imported i>y any individual or business. As
noted on the attached Prior Approval Application form, the
following information must be submitted to EPA: the name of the
sanctioning body and competition class; a schedule of racing
events, including dates and locations where the vehicle will
participate; a copy of the competition racing license; a letter
from the state's Department of Motor Vehicles that states that
the vehicle cannot be licensed for use on public streets or
highways, and explains why it cannot be licensed; and four
photographs of the vehicle must be included, one each of front,
rear and each side. Additional information may be required in
some cases.
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D. Other exemptions which are outlined on the attached Prior
Approval Application form
Other exemptions and the documentation required by EPA are
described on the Prior Approval Application form (Attachment 2).
EPA's written approval should be obtained prior to shipping your
vehicle from overseas.
VIII. OTHER REQUIREMENTS
A. Customs
General questions regarding the importation of your vehicle
should be directed to the Customs port where your vehicle will be
entered. However, for further assistance you may contact:
U.S. Customs Service
Office of Trade Operations
Other Agency Enforcement Branch
1301 Constitution Avenue, N.W.
Washington, DC 20229
(202) 927-0402
B. Safety
Customs will not admit your vehicle into the U.S. until both
emission and safety requirements are met, as well as other
applicable Federal requirements. The EPA rules do not impact or
reflect the Federal safety requirements to which the vehicles must
comply. For information on safety requirements contact:
U.S. Department of Transportation
400 7th Street, S.W.
Room 6115
Washington, D.C. 20590
(202) 366-5313
C. Gas Guzzler Tax
A "Gas Guzzler Tax" may need to be paid on your vehicle.
These taxes range from $500 to $3,850 per vehicle. For more
information, contact:
Internal Revenue Service
Public Affairs Office'
1111 Constitution Avenue, N.W.
Washington, D.C. 20224
(202) 622-4920
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D. California emission requirements
The State of California has its own program for regulating the
importation of nonconforming vehicles that are sold, registered, or
operated in California: If you are a resident of, principally
drive your car in, register or intend to sell vehicles in the State
of California, you vill need to comply with California*s emission
requirements in addition to the Federal emission requirements. For
more information on California's requirements, contact:
State of California
Air Resources Board
Mobile Source Control Division
9528 Telstar Avenue
El Monte, CA 91731
(818) 575-6858
E. Other State requirements
1. Proof of Federal Emissions Compliance
Many State Department of Motor Vehicles (DMVs) require
documentation indicating that Federal emission requirements have
been met and proof of ownership before registration and/or titling
of the vehicle will be permitted. Since Federal law prohibits the
sale or operation of a nonconforming motor vehicle until Federal
emission requirements have been met, EPA supports these State
efforts to ensure that Federal laws are not being violated. EPA
has indicated to representatives of State DMVs that the following
documentation would be necessary in order to show that a vehicle
being imported under this new imports program meets Federal
emission requirements:
A. a copy of the EPA entry form 3520-1, and
B. for vehicles entered by ICIs, a verification letter from
EPA which states that all applicable emission requirements
have been met. To obtain such a letter, call (202) 233-9660.
C. for vehicles that EPA granted prior approval, a copy of
the EPA letter of Prior Approval.
2. Proof of Gas Guzzler Payment
Some states will require proof of payment of the gas guzzler
tax, if applicable to your vehicle (for information on this tax,
see Section VIII. C.).
3. Inspection/Maintenance Requirements
Your state may operate an Inspection/Maintenance (I/M) program
which is designed to satisfy the state's requirement for reducing
excess emissions caused by vehicles that are not properly tuned or
are in need of repair. Because I/M programs are customized to the
needs of each local area, you should contact your local I/M office
for more information on its requirements. A state test is not the
same as a Federal test, and EPA will not accept state test results
to satisfy Federal requirements.
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IMPORTING CANADIAN VEHICLE8
On July 1, 1988, the U.S. Environmental Protection Agency
(EPA) introduced new regulations which considerably revised the
then existing regulatory program for the importation of
nonconforming vehicles. This action affected models not
manufactured for sale in the U.S., including nonconforming
vehicles from Canada which are not labeled with an unconditional
statement of conformity with U.S. emission requirements.1 If
your vehicle does not contain such a label, then you must import
your vehicle according to one of the options described below.
NOTE: These options relate only to compliance with EPA
requirements; your vehicle may be subject to additional
requirements of the U.S. Department of Transportation.
IMPORTATION BY AN INDIVIDUAL
Five options are available:
Option l)
PROVE THAT THE VEHICLE IS IDENTICAL, IN ALL MATERIAL
RESPECTS, TO A VEHICLE IDENTIFIED IN AN ORIGINAL EQUIPMENT
MANUFACTURER'S (OEM'S) CERTIFICATION APPLICATION (prior to
importation). To do this, the individual must obtain a
letter from the OEM's U.S. representative {for a list see
Attachment 1) attesting to the compliance of the vehicle.
The letter must contain an unconditional statement that the
vehicle (make, model, model year, VIN), at the time of
manufacture, conforms to all U.S. emission requirements
applicable to the appropriate model year. You must then
obtain prior written approval from EPA before you attempt to
import. To obtain prior written approval from EPA, you must
provide:
Revised 11/2/92
HOW TO FIND THE U.S. EMISSIONS COMPLIANCE LABEL
1) 1971 and later conforming vehicles, will have a
label in the engine compartment entitled "Vehicle
Emission Control Information" which will contain
the name and trademark of the manufacturer and an
unconditional statement of compliance with EPA
emissions regulations. For MOTORCYCLES, this label
will be on the frame,
2) 1968 through 1970 conforming motor vehicles will
have a label on the doorpost indicating compliance
with Federal motor vehicle safety standards, and
3) 1967 and earlier motor vehicles are excluded from
meeting U.S. emission requirements and will not
have a compliance label.
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IMPORTATION BY AN INDIVIDUAL (cont.)
a) A completed application for prior written approval
(Attachment 2). These importations will be covered under
the "Hardship Exemption" (code letter M) as described on the
application form.
b) The original letter described above from the U.S.
representative of the manufacturer on company letterhead.
NOTE: Regardless of the requirements above being
satisfied, a vehicle is not eligible for this exemption
if it has been modified or altered such that the
vehicle configuration is not covered under the
manufacturer's certificate of conformity.
Option 2)
MODIFY THE VEHICLE (prior to importation) TO HAKE IT
IDENTICAL, IN ALL MATERIAL RESPECTS, TO A VEHICLE IDENTIFIED
IN AN OEM'S CERTIFICATION APPLICATION. The individual must
obtain a letter from the OEM's U.S. representative (for a
list see Attachment 1) outlining the necessary modifications
to make the vehicle identical to it's U.S. certified
counterpart. The letter must list specific parts (including
part numbers) which must be installed or replaced to bring
the vehicle into conformity. The individual must then have
the vehicle modified in accordance with those modification
instructions. After the modifications are completed, the
individual may then obtain prior written approval from EPA
before attempting to import. To obtain prior written
approval from EPA, the individual must provide:
a) A completed application for prior written approval
(Attachment 2). These importations will be covered under
the "Hardship Exemption" (code letter M) as described on the
application form.
b) The original letter described above from the U.S.
representative of the manufacturer on company letterhead.
c) A clear copy of the paid invoice documenting that the
proper parts (including part numbers) were installed or
replaced and any necessary adjustments were made.
NOTES:
1) Regardless of the requirements above being
satisfied, a vehicle is not eligible for this exemption
if it has been modified op altered such that the
vehicle configuration is not covered under the
manufacturer's certificate of conformity.
2) Generally, EPA only accepts compliance information
from the OEM's U.S. representative. However, as an
exception to this rule, statements of conformity will
be acceptable to EPA as evidence of conformity from
General Motors of Canada if they are signed by a
representative of the Vehicle Emission Compliance
Department.
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IMPORTATION BY AN INDIVIDUAL (cont.)
This policy of accepting letters from someone other
than the U.S. representative of the vehicle
manufacturer does not apply to other manufacturers.
Option 3)
VEHICLE IS ON THE ATTACHED LIST. These vehicles have been
proven to be identical in all material respects to a U.S.
certified version of the same make, model and model year.
You must obtain prior written approval from EPA before you
attempt to import. To obtain prior written approval from
EPA, you must provide:
a) A completed application for prior written approval
(Attachment 2). These importations will be covered under
the "Hardship Exemption" (code letter M) as described on the
application form.
b) A description of the vehicle (make, model, model year,
and VIN).
Option 4)
IMMIGRANTS FROM CANADA MAY NOT NEED EPA'8 PRIOR APPROVAL TO
IMPORT A VEHICLE. To qualify for this exemption the
immigrant must demonstrate to the U.S. Customs Service at
the border crossing the following:
a) The immigrant must have a document from the Immigration
& Naturalization Service (INS) proving that he/she has been
granted U.S. immigrant status.
b) One of the following: (i) vehicle must have in a door
jamb a Transport Canada label with the CMVSS designation,
(ii) the owner must present a letter from the manufacturer's
U.S. representative (for a list see Attachment 1) which
unconditionally states that for the applicable model year,
the vehicle complied with all applicable Canadian emission
requirements or all applicable U.S. EPA emission
requirements, or (iii) a sales receipt showing that the
vehicle was purchased from a Canadian dealership and was new
at the time it was purchased.
c) The immigrant must have proof that he/she owned the
vehicle prior to immigration. The vehicle's Canadian title
or registration in the name of the importer is required.
d) The immigrant must write the word "Immigrant" at the top
of the EPA entry Form 3520-1 and declare code M. Form 3520-
1 may be obtained from the U.S. Customs Service at the
border crossing.
e) Alternatively to waiting to get to the border
crossing for approval, the immigrant may send the
information required in a, b, and c above directly to
EPA for a prior letter of approval.
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IMPORTATION BY AN INDIVIDUAL (cont.)
Option 5)
ANY INDIVIDUAL CHANGING HIS/HER PERMANENT RESIDENCE
FROM CANADA TO THE U.S. FOR AT LEAST THREE YEARS.
a) Importer must demonstrate he/she is changing
permanent residence for at least three years.
Acceptable documentation includes any of the following:
a document from the Immigration & Naturalization
Service (INS) proving that the importer has been
granted immigrant status, a Visa valid for at least
three years, a letter from the importer's employer
verifying transfer to the U.S. for at least three
years, acceptance to a three year or longer program at
a college or university in the U.S., a written
statement that self certifies the importer is
permanently moving to the U.S., or other
related documentation.
b) Proof that vehicle is a Canadian vehicle.
Acceptable documentation includes a letter from the
manufactures U.S. representative (for a list see
attachment 1) which unconditionally states that for the
applicable model year, the vehicle complied with all
applicable Canadian emission requirements or all
applicable U.S. EPA emission requirements, or (iii) a
sales receipt showing that the vehicle was purchased
from a Canadian dealership and was new at the time it
was purchased.
c) The importer must have proof that he/she owned the
vehicle prior to immigration. The vehicle's Canadian
title or registration in the name of the importer is
required.
d) You must then obtain prior written approval from
EPA before you attempt to import.
IMPORTATION OF A "COMPANY" VEHICLE BY A BUSINESS
A business located in Canada may import a Canadian vehicle
that has been owned by the business to a location in the U.S. for
the purposes of continued use by the business, NOT FOR RESALE.
The conditions of option 1, 2 or 3 of the previous section
entitled IMPORTATION BY AN INDIVIDUAL must be met.
-------
C-5
IMPORTATION BY A BUSINESS FOR THE PURPOSES OF RESALE
No business may import used Canadian cars for the purpose of
resale. Only designated Canadian importers (DCIs) approved by
EPA may import new Canadian vehicles for resale. To be included
on EPA's list of approved DCIs, the company must agree in writing
to the terms and conditions that apply to it as an importer of
Canadian vehicles. In general terms, an importer of vehicles
from Canada who wishes to be included on the list must agree to
import only preapproved new models and provide labeling,
warranties, recall obligations, and a three working day hold
period. EPA will send a copy of the agreement to interested
parties upon request. DCIs cannot import under any option
available to individuals.
SPECIAL IMPORTATIONS
1) Conforming vehicles that have a label which attests to the
compliance of the vehicle with U.S. emission requirements
(either on the door jamb or underhood) may be imported by
any individual or business and may pass freely across the
border with respect to emissions requirements. EPA approval
is not required.
2) In some cases, for Canadian vehicles that do not have a U.S.
emissions label, Customs will allow temporary importations
for a limited period of time. This generally applies to
tourists and commercial vehicles. This is handled by
Customs, not EPAI
Attachment
-------
VEHICLES MADE FOR SALE IN CANADA
THAT MEET U.S. EMISSION REQUIREMENTS*
These vehicles meet U.S. Federal emission requirements except
possibly for labeling, warranty, and recall requirements.
These vehicles may not all comply with applicable Federal
safety standards or local emission requirements.
-------
C-7
1993 Model Year Vehicles Made for Sale in
Canada that Conform to U.S. Emission Requirements
I. 1993 General Motors Products
1.0 All 1993 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be P (1993 model year)
1992 Model Year Vehicles Made for Sale in
Canada that Conform to U.S. Emission Requirements
I. 1992 Mercedes-Benz Products
All 1992 model year Mercedes-Benz vehicles conform to
U.S. emission requirements.
II• 1992 General Motors Products
1.0 All 1992 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be N (1992 model year)
1991 Model Year Vehicles Made for Sale in
Canada that Conform to U.S. Emission Requirements
I. 1991 Honda/Acura Products
1.0 All 1991 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be M (1991 model year)
II. 1991 Ford Products
1.0 All 1991 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be M (1991 model year)
III. 1991 General Motors Products
1.0 All 1991 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be M (1991 model year)
IV. 1991 Mercedes-Benz Products
All 1991 model year Mercedes-Benz vehicles conform to U.S.
emission requirements.
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C—8
1990 Model Year Vehicles Made for Sale in
Canada that Conform to U.S. Emission Requirements
I. 1990 Ford Products
1.0 All 1990 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be L (1990 model year)
2.0 All 1990 model year light-duty trucks (under 8,501 lbs.
GVW) conform to U.S. emission requirements.
2.1 10th digit of VIN must be L (1990 model year)
2.2 4th digit of VIN cannot be H, J, K, L, M, N, P,
R, S, T, U, V, W, X, Y, and Z (excludes GVW over
8,500 lbs.)
II. 1990 General Motors Products
1.0 All light-duty vehicles conform to U.S. emission
requirements.
1.1 10th digit of VIN must be L (1990 model year)
2.0 All light-duty trucks (under 8,501 lbs GVW) except
those with the 6.2 liter diesel engine conform to
U.S. emission requirements.
2.1 10th digit of VIN must be L (1990 model year)
2.2 8th digit of VIN cannot be J (excludes 6.2 liter
diesel engine)
2.3 4th digit of the VIN must be B, C, D, E or F
(GVW under 8,501 lbs)
III. 1990 Honda/Acura Products
1.0 All 1990 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be L (1990 model year)
-------
C-9
1990 Products (cont.)
IV. 1990 Mazda Products
1.0 All 1990 model year light-duty passenger cars conform to
U.S. emission requirements.
1.1 10th digit of VIN must be L (1990 model year)
V. 1990 Mercedes-Benz Products
All 1990 model year Mercedes-Benz vehicles conform to U.S.
emission requirements.
-------
C-10
1989 Model Year Vehicles Made for Sale in
Canada that Conform to U.S. Emission Requirements
I. 1989 BMW Products
1.0 All BMW 3 Series with the following VIN designation.
WBAAA230-K'
WBAAA130-k'
WBAAD230-K'
WBAAD130-K
WBABB230-K
WBABB130-K
WBAAB030-K
WBAAB930-K
WBAAE030-K
WBAAE930-K
WBSAK030-K
2.0 All BMW 5 Series with the
WBAHC230-K
WBAHC130-K
3.0 All BMW 7 Series with the
WBAGB431-K
WBAGB331-K
following VIN designation.
WBAHD131-K
WBAHD231-K
following VIN designation.
WBAGC431-K
WBAGC831-K
II. 1989 Ford Products
1.0 All 1989 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be K (1989 model year)
2.0 All 1989 model year light-duty trucks (under 8,501 lbs.
GVW) conform to U.S. emission requirements.
2.1 10th digit of VIN must be K (1989 model year)
2.2 4th digit of VIN cannot be H, J, K, L, M, N, P,
R, S, T, U, V, W, X, Y, and Z (excludes GVW over
8,500 lbs.)
III. 1989 General Motors Products
1.0 All light-duty vehicles conform to U.S. emission
requirements.
1.1 10th digit of VIN must be K (1989 model year)
-------
C-ll
1989 General Motors Products (cont.)
2.0 All light-duty trucks (under 8,501 lbs GVW) except
those with the 6.2 liter diesel engine conform to
U.S. emission requirements.
2.1 10th digit of VIN must be K (1989 model year)
2.2 8th digit of VIN cannot be J (excludes 6.2 liter
diesel engine)
2.3 4th digit of the VIN must be B, C, D, E or F
(GVW under 8,501 lbs)
IV. 1989 Honda/Acura Products
1.0 All 1989 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be K (1989 model year)
V. 1989 Hyundai Products
1.0 All 1989 Sonatas with 2.4 liter engines conform to U.S.
emission requirements.
1.1 8th digit of VIN must be K (1989 model year)
1.2 6th digit of VIN must be S (designates 2.4 liter
gasoline engines)
VI. 1989 Jeep Products
1.0 All 1989 model year light-duty trucks conform to U.S.
emission requirements.
1.1 10th digit of VIN must be K (1989 model year)
IV. 1989 Mazda Products
1.0 All 1989 model year light-duty passenger cars conform to
U.S. emission requirements.
1.1 10th digit of VIN must be K (1989 model year)
V. 1989 Mercedes-Benz Products
All 1989 model year Mercedes-Benz vehicles conform to U.S.
emission requirements.
-------
C—12
1988 Model Year Vehicles Made for Sale in
Canada that Conform to U.S.. Emission Requirements
I. 1988 Ford Products
1.0 All 1988 model year light-duty vehicles conform to U.S.
emission requirements except some Tracer and Tempo/Topaz
models and those vehicles with the 351 cubic inch engine.
1.1 For Tracer models the 6th and 7th VIN digits cannot
be 10, 11, 12, 13, 15 or 16
1.2 For Tempo/Topaz models the 6th and 7th VIN digits
cannot be 30 or 35
1.3 8th digit of VIN cannot be G (excludes 351 cubic
inch engine)
1.4 10th digit of VIN must be J (1988 model year)
2.0 All 1988 model year light-duty trucks (under 8,501 lbs.
GVW) conform to U.S. emission requirements.
2.1 10th digit of VIN must be J (1988 model year)
2.2 4th digit of VIN cannot be H, J, K, L, M, N, P,
R or S (excludes GVW over 8,500 lbs.)
II. 1988 General Motors Products
1.0 All light-duty vehicles built with the RPO designation
NA5 conform to U.S. emission requirements.
1.1 10th digit of VIN must be J (1988 model year)
2.0 All light-duty trucks (under 8,501 lbs. GVW) built with
the RPO designation NA5 conform to U.S. emission require-
ments except those with the 6.2 liter diesel engine.
2.1 10th digit of VIN must be J (1988 model year)
2.2 8th digit of VIN cannot be J (excludes 6.2 liter
diesel engine)
2.3 4th digit of the VIN must be B, C, D, E or F
(GVW under 8,501 lbs.)
3.0 On GM light-duty vehicles and light-duty trucks is a
Service Parts Identification label that contains codes
for certain parts and options originally installed on
the vehicle along with thd'vehicle identification number.
-------
C-13
1988 GM Products (cont.)
The labels are in one of four places.
3.1 Under the rear deck lid (trunk lid)
3.2 Under the rear load flow (trunk floor under carpeting)
3.3 In the glove compartment
3.4 In station wagons they may be on the back of the
rear seat, on a wheel well under carpeting, or under
the carpet on the floor.
Service Porfs ld«nfificotioh
OO NOT REMOVE
i
1G2JU27J2G7599735
AAA A 03 AKL AR 9 AU3 AO I A31 A4K A4L A90 8C8 BS1 BV2 BUI BW8
Bw9 B XI BYl B20 02 3 8*8 856 884 CO* C49 C60 004 007 008 034
035 0*R 060 080 086 09C §5Z GX3 H05 - - -
NA5 NKV N33 N40 N78 QPV T*9 7 74
U21 'J2J U25 U2 7 U29. U66 VK3 VY9
YT9 Y-33 235 ~ """
K22 *34 LAS L00 *09 MXl
737 T63 T83 UM6 UM US6 UT1
„ .... V73 MS6 HX3 WX7 VR1 YSl T7I
Z49 02A 25L 27C 271 279 31U 68F 7BM 8HY 9MY
0 IS • LACQUER ¦*- L8574 Ue592 31U
L
Identification Des Pieces De Rechange NE PAS ENIEVER
rtlMTf D If* U S A f»BT NO H0t39S9 A
If the label contains the code NA5 it is a U.S. certified
version vehicle. The only exception are 1988 model
year trucks with the 6.2 liter diesel engine. These
trucks do not meet U.S. emission requirements even if
they have the NA5 code.
NOTE: The importer must provide EPA with a picture of the
label clearly showing the NA5 designation. This picture
should accompany any other documentation required for obtaining
prior approval.
III. 1988 Honda/Acura Products
1.0 All 1988 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be J (1988 model year)
-------
C-14
IV. 1988 Chrysler Products (does not include Jeep Eagle
vehicles)
1.0 All 1988 model year light-duty vehicles conform to U.S.
emission requirements.
1.1 10th digit of VIN must be J (1988 model year)
2.0 All 1988 model year light-duty trucks (under 8,501 lbs.
GVW) conform to U.S. emission requirements except those
with the 360 cubic inch engine.
2.1 10th digit of VIN must be J (1988 model year)
2.2 8th digit of VIN cannot be 1, 5, 8, or W (excludes
360 cubic inch engine)
2.3 4th digit of VIN must be D, E, F, G, H or J
(excludes GVW over 8,500 lbs.)
V. 1988 Jeeps
1.0 All 1988 model year light-duty trucks with a label
(applied by the original equipment manufacturer) on the
door jamb that states that it meets U.S. EPA regulations
applicable to 1988 model year new motor vehicles, conform
to U.S. emission requirements.
1.1 10th digit of VIN must be J (1988 model year)
VI. 1988 Mazda Products
1.0 All 1988 model year light-duty passenger cars conform
to U.S. emission requirements.
1.1 10th digit of VIN must be J (1988 model year)
VII. 1988 Mercedes-Benz Products
All 1988 model year Mercedes-Benz vehicles conform to U.S.
emission requirements.
-------
C-15
1987 Model Year Vehicles Made for Sale in
Canada that Conform to U.S. Emission Requirements
X. 1987 Volvo Products
1.0 All 1987 model year 240, 740, and 760 series vehicles
conform to U.S. emission requirements.
1.1 The tenth digit of the VIN will have an H to signify
the 1987 model year.
1.2 The fourth digit of the VIN will have an A, F or G
to signify the 240, 740 or 760 series respectively.
II. 1987 Ford Products
1,0 The following 1987 model year light-duty vehicles conform
to U.S. emission requirements.
1.1 The tenth digit of the VIN will have an H to signify
the 1987 model year.
1.2 Complying light-duty vehicles.
Escort/Lynx/EXP
Tempo/Topaz
all
all except those with
digits 18, 21, 71, or 74
in the 6th and 7th VIN
positions. Except those
with an R in the
8th VIN position.
Mustang
all
Taurus/Sable
only those with D in the
8th VIN position.
Merkur XR4TI
Thunderbird/Cougar
all
all
Crown Victoria/Grand Marquis all except those with G
Country Squire/Colony Park in the 8th VIN position
Town Car
Continental/Mark VII
Mark VII lsc
all
all
all
-------
C—16
1987 Ford Products (cont.)
1.3 Complying Light Trucks (under 8500 lbs. GVW)
Club Wagon
E Series Vans
F Series Pick-ups
Bronco
all except those with H
through Z in the 4th
VIN position.
Aerostar
Bronco II
Ranger
all
all
all except those with E
in the 8th VIN position
III. 1987 GM Products
1.0 All. light-duty vehicles built with the RPO designation
NA5 conform to U.S. emission requirements.
1.1 10th digit of VIN must be H (1987 model year)
2.0 All light-duty trucks (under 8,501 lbs. GVW) built with
the RPO designation NA5 conform to U.S. emission require-
ments except those with the 6.2 liter diesel engine.
2.1 10th digit of VIN must be H (1987 model year)
2.2 8th digit of VIN cannot be C or J (excludes 6.2
liter diesel engine)
3.0 On GM light-duty vehicles and light-duty trucks is a
Service Parts Identification label that contains codes
for certain parts and options originally installed on
the vehicle along with the vehicle identification number.
The labels are in one of four places.
3.1 Under the rear deck lid (trunk lid)
3.2 Under the rear load flow (trunk floor under carpeting)
3.3 In the glove compartment
3.4 In station wagons they may be on the back of the
rear seat, on a wheel well under carpeting, or under
the carpet on the floor.
If the label contains the code NA5 it is a U.S. certified
version vehicle. The only exception are 1987 model
year trucks with the 6.2 liter diesel engine. These
trucks do not meet U.S. emission requirements even if
they have the NA5 code. See "1988 GM Products" on page 4
for more information about, the NA5 code.
• *
NOTE: You must provide EPA with a picture of the label clearly
showing the NA5 designation. This picture should accompany any
other documentation required for obtaining prior approval.
IV. 1987 Mercedes-Benz Products
All 1987 model year Mercedes-Benz vehicles conform to U.S.
emission requirements.
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C-17
1986 Model Year Vehicles Made for Sale in
Canada that Conform to U.S. Emission Requirements
1986 Ford Products
0 The following 1986 model year light-duty vehicles conform
to U.S. emission requirements.
1.1 The tenth digit of the VIN will have a G to signify
the 1986 model year.
1.2 Models that meet U.S. emission requirements
Escort/Lynx/EXP all
Tempo/Topaz all except those with
R in the 8th VIN
position.
Mustang/Capri all except those with 3
LTD/Marquis in the 8th VIN position.
Thunderbird/Cougar
Continental/Mark VII all
Crown Victoria/Grand Marquis only those with M in 8th
VIN position
Town Car all
0 The following 1986 model light-duty trucks conform to U.S.
emission requirements.
1.1 The tenth digit of the VIN will have a G to signify
the 1986 model year.
1.2 The 4th digit of the VIN must have an A, B, C, D,
E, F, or G to indicate a GVWR less than 8500 lbs.
1.3 Models that meet U.S. emission requirements.
Ranger all
Bronco II all
Aerostar all
E-Series (Vans) all except those with Y
F-Series (Pick-ups) in the 8th VIN position
and use leaded fuel.
-------
C-18
III. 1986 GM Products
1.0 All vehicles built with the RPO designation NA5 conform
to U.S. emission requirements.
1.1 10th digit of VIN must be G (1986 model year)
2.0 On GM light-duty vehicles and light-duty trucks is a
Service Parts Identification label that contains codes
for certain parts and options originally installed on
the vehicle along with the vehicle identification number.
The labels are in one of four places.
2.1 Under the rear deck lid (trunk lid)
2.2 Under the rear load flow (trunk floor under carpeting)
2.3 In the glove compartment
2.4 In station wagons they may be on the back of the
rear seat, on a wheel well under carpeting, or under
the carpet on the floor.
See "1988 GM Products" on page 4 for more information
about the NA5 code.
NOTE: If the label contains the code NA5 it is a U.S. certified
version vehicle. The importer must provide EPA with a picture
of the label clearly showing the NA5 designation. This picture
should accompany any other documentation required for obtaining
prior approval.
IV. 1986 Mercedes-Benz Products
All 1986 model year Mercedes-Benz vehicles conform to U.S.
emission requirements.
-------
C-19
1985 Model Year Vehicles Made for Sale in
Canada that Conform to U.S. Emission Requirements
I. 1985 Volvo Products
1.0 1985 Volvo 240 Series with the following VIN designation.
2.0 1985 Volvo 740 Series with the following VIN designation.
3.0 1985 Volvo 760 Series with the following VIN designation.
YV1DX694XF1000000
YV1DX874XF1000000
YV1DX874XF2000000
YV1DX764XF1000000
II. 1985 Mercedes-Benz Products
YV1AX474XF1000000
YV1AX475XF1000000
YV1AX474XF2000000
YV1AX475XF2000000
YV1AX474XF3000000
YV1AX475XF3000000
YV1AX884XF1000000
YV1AX885XF1000000
YV1AX884XF2000000
YV1AX885XF2000000
YV1AX884XF3000000
YV1AX885XF3000000
YV1DX884XF1000000
YV1DX884XF2000000
YV1AX884XF1000000
YV1AX885XF1000000
YV1AX884XF2000000
YV1AX885XF2000000
YV1AX884XF3000000
YV1DX694XF1000000
YV1AX885XF3000000
YV1DX884XF1000000
YV1DX884XF2000000
YV1DX87 4XF1000000
YV1DX874XF2000000
YV1DX764XF1000000
All 1985 model year Mercedes-Benz vehicles conform to U.S.
•mission requirements.
-------
C-20
1984 arid Earlier Model Year Vehicles Made for
Sale in Canada that Conform to U.S. Emission Requirements
I. GM Products
1.0 All 1968 through 1974 light-duty vehicles.
2.0 All 1970 through 1978 trucks having a GVWR of more
than 6000 pounds.
3.0 All 1968 through 1984 Chevrolet Corvettes.
II- Ford Products
1.0 All 1968 through 1974 light-duty vehicles.
2.0 All 1970 through 1978 trucks having a GVWR of more
than 6000 pounds.
III. Chrysler Products
1.0 All 1968 through 1974 light-duty vehicles.
2.0 All 1970 through 1978 trucks having a GVWR of more
than 6000 pounds.
IV. AMC Products
1.0 All 1968 through 1974 light-duty vehicles.
2.0 All 1970 through 1978 trucks having a GVWR of more
than 6000 pounds.
V. Mercedes-Benz Products
1.0 All Mercedes-Benz vehicles manufactured from September
1, 1980 through December 31, 1984 conform to U.S.
emission requirements.
VI* Other Manufacturers
1.0 All 1968 through 1978 International Harvester
passenger cars and trucks. 1979 Scout model,
if equipped with a diesel engine.
2.0 All Mack trucks manufactured from 1970 through 1979.
3.0 All 1970 through 1979 JKenworth trucks, except 1979
trucks using the Detroit Diesel 12V71 model engine.
4.0 All 1970 through 1979 White, White Western Star, and
Autocar trucks.
5.0 All Peterbuilt trucks manufactured from 1970 through
1979.
-------
C-21
Other Manufacturers (cont.)
6.0 All 1970 through 1979 Caterpiller engines used in
trucks having a GVWR of more than 6000 pounds.
7.0 All 1970 through 1979 Cummins engines used in trucks
having a GVWR of more than 6000 pounds.
8.0 All 1970 through 1978 Detroit Diesel engines used in
trucks having a GVWR of more than 6000 pounds.
-------
D-l
U.8. VERSION VEHICLES DRIVEN OVERSEAS
The use of leaded fuel in a vehicle equipped with a
catalytic converter will affect the ability of the catalyst to
effectively reduce emissions. In many overseas countries
unleaded fuel is not yet widely available. Because your
vehicle's catalytic converter and oxygen sensor (if applicable)
play an important part in reducing the emissions of your vehicle,
EPA must ensure that their effectiveness has not been impaired by
the use of leaded gasoline.
MOTE:
1) NOT ALL VEHICLES EQUIPPED WITH CATALYTIC
CONVERTERS ARE CERTIFIED U.S. VERSION
VEHICLES. For a vehicle to be eligible for
importation under this section, it must have
an EPA emissions label in the English
language in the engine compartment, or it
must be accompanied by a letter from EPA or
the U.S. representative of the original
equipment manufacturer that states the
vehicle was either manufactured to be a U.S.
certified version or identical in all
material respects to a U.S. version.
Otherwise, the vehicle must be imported as a
nonconforming vehicle under section "B"
Importing Nonconforming Vehicles.
2) ANY U.S. VERSION VEHICLE THAT HAS BEEN
ALTERED SUCH THAT IT IS NO LONGER IN AN EPA
CERTIFIED CONFIGURATION (other than removal
of the catalyst and oxygen sensor) IS NOT
ELIGIBLE TO BE IMPORTED AS A U.S. VERSION
VEHICLE. SUCH VEHICLES MUST BE IMPORTED AS
NONCONFORMING VEHICLES UNDER SECTION B.
3) ALL U.S. VERSION DIESEL-FUELED VEHICLES ARE NOT SUBJECT
TO THE REQUIREMENTS IN THIS FACT SHEET AND MAY BE
IMPORTED WITHOUT BOND FOR EPA PURPOSES. Importers must
declare category "CC" on the EPA 3520-1 submitted to
U.S. Customs upon entry.
-------
D-2
4) ANY GASOLINE-FUELED U.S. VERSION VEHICLE THAT
WAS NOT ORIGINALLY MANUFACTURED WITH A
CATALYTIC CONVERTER IS NOT SUBJECT TO IMPORT
RESTRICTIONS AND MAY BE IMPORTED WITHOUT BOND
CONCERNING EPA REGULATIONS. However, the
importer must obtain prior written approval
by EPA and declare entry category MDD" on the
EPA Form 3520-1 submitted to U.S. Customs
upon entry.
5) THE RESULTS OF A STATE OR SERVICE STATION OR DEALERSHIP
EMISSION TEST DO NOT PROVE THAT THE VEHICLE COMPLIES
WITH FEDERAL EMISSION REQUIREMENTS since these tests
were designed to detect automobiles with excessively
high emissions for certain pollutants and does not
measure other Federally regulated pollutants.
6) U.S. VERSION VEHICLES DRIVEN SOLELY WITHIN THE U.S.,
CANADA, MEXICO, JAPAN, AUSTRALIA, TAIWAN OR BAHAMA
ISLANDS ARE NOT SUBJECT TO THE REQUIREMENTS OF THIS
FACT SHEET. Submission of EPA Form 3520-1 to U.S.
Customs is not required and an importation bond is not
required for EPA purposes.
7) A U.S. VERSION VEHICLE THAT HAS ALL EMISSION
CONTROL EQUIPMENT INSTALLED AND PROPERLY
FUNCTIONING, AND THAT IS NEW (driven less
than 50 miles) MAY BE IMPORTED WITHOUT EPA
RESTRICTION. IMPORTERS MUST DECLARE CATEGORY
"BB" ON THE EPA FORM 3520-1 SUBMITTED TO U.S.
CUSTOMS UPON ENTRY
I. Protecting Your Converter
If you are contemplating exporting your U.S. version vehicle
from North America, you may obtain authorization to have the
catalytic converter and oxygen sensor (if your vehicle was
manufactured with one) removed prior to shipment. When returning
your vehicle to the U.S., the catalytic converter and the oxygen
sensor will only have to be reinstalled, rather than replaced.
For more information concerning such authorization, call EPA's
Field Operations and Support Division at (202) 233-9060. (Note:
information concerning all importation issues other than
authorization to remove catalytic converters and oxygen sensors
should be directed to EPA's Manufacturers Operations Divisions at
(202) 233-9660)
Revised 11/3/92
-------
D-3
II. EPA'3 Policy
Vehicles which were originally equipped with a catalytic
converter or a catalytic converter and oxygen sensor, and were
built to meet U.S. emission requirements (i.e., covered by a
certificate of conformity and equipped with a U.S. emissions
label) but have been driven outside the United States, Canada,
Mexico, Japan, Australia, Taiwan and Bahama Islands may be
imported by any individual. However, these vehicles are subject
to import restrictions.
Generally, EPA's regulations require that the catalytic
converter, or catalytic converter and oxygen sensor (certain 1978
and newer models are equipped with both a catalytic converter and
oxygen sensor), be replaced on vehicles which may have been
contaminated with leaded gasoline overseas.
Vehicles manufactured prior to the 1974 model year (i.e.,
1973 model year vehicles and earlier) were not equipped with a
catalytic converter. 1976 and later model year vehicles which
were equipped with a catalytic converter may be identified by the
word "Catalyst" found either on the underhood emissions label or
on the door jamb adjacent to the DOT safety label. The vehicle's
fuel filler inlet restrictor will also have to be replaced if it
has been removed or disabled. This requirement is necessary
because unleaded gasoline is still not widely available in all
areas outside North America, and use of leaded fuel can damage
these components.
Ill. Demonstrating Compliance with Federal Requirements
A. Bonded Entries
EPA requires an importation bond to assure that components
which are vital to reducing emissions are fully operational after
use overseas. The amount of the bond is determined by Customs
and is generally the value of the vehicle. To enter a vehicle
built to U.S. emission requirements into the U.S., you must file
an EPA Form 3520-1 with Customs using category F. This form may
be obtained from either your bonding company or Customs. After
an entry has been made with Customs, you have 120 days to bring
your vehicle into compliance with EPA requirements. You must
choose one of the following options, as applicable, in order to
gain EPA release of your bond:
1) Replace the catalytic converter and oxygen sensor (if
applicable) and verify the functional ability of the
fuel filler inlet restrictor. Have the work performed
by a qualified mechanic in the U.S. using new original
equipment parts. Submit to EPA (address on page E-l) a
clear copy of the paid invoice from the facility where
the work was done along with a completed EPA form 3520-
9 "Application for Final Admission of a Catalytic
Converter and Oxygen Sensor Equipped Vehicle" (copy on
page D-7). This form must be signed by both you and
the mechanic who performed the work.
-------
D-4
2) If you had your catalytic converter and oxygen sensor
(if applicable) removed prior to going overseas, new
parts replacement will not be necessary when the
vehicle is returned to the U.S. However, the original
parts must be reinstalled by a qualified mechanic
according to the manufacturers instructions. The
mechanic must also verify that your vehicle's fuel
filler inlet restrictor is operational and has not been
tampered with. Submit to EPA (address on page E-l)
clear copies of the paid invoices showing that the
parts were removed prior to export and reinstalled
after returning to the U.S. along with a completed EPA
Form 3520-9 "Application for Final Admission of a
Catalytic Converter and Oxygen Sensor Equipped Vehicle"
(copy on page D-7). This form must be signed by both
you and the mechanic who performed the work.
3) If your vehicle was driven only on unleaded gasoline,
you may verify this by having your vehicle tested for
the presence of lead. THIS OPTION IS ONLY AVAILABLE
FOR VEHICLES DRIVEN OVERSEAS IN THE FOLLOWING
COUNTRIES: Portugal, Spain, France, Italy, Greece,
Austria, Germany, Belgium, Netherlands, Luxembourg,
Switzerland, Sweden, Norway, Denmark, Iceland, Finland,
United Kingdom, Ireland, South Korea, Liechtenstein and
Hong Kong.
Verification of unleaded gasoline usage must be made as follows:
a. The test must be performed by a certified mechanic in
the United States according to the instructions provided with the
attached "Plumbtesmo Test Report Form" (copy on page D-5).
b. You must complete your portion of the form and take the
vehicle along with the enclosed packet of test paper (if not
enclosed please call (202) 233-9660) to the mechanic for testing.
CAUTION: CARE MUST BE TAKEN TO AVOID CONTAMINATION OF THE TEST
PAPER. Keep the packet of test paper dry, out of direct sunlight
and do not open until the test is to be performed.
c. Upon completion of the test, the mechanic must sign the
form to verify that the test was performed according to EPA's
instructions.
d. As the instructions indicate, if the test results are
positive (indicating leaded fuel usage) or the inspection reveals
that the fuel filler inlet restrictor was damaged or tampered
with or missing, your catalytic converter and oxygen sensor (if
applicable) must be replaced with original equipment parts. You
must provide EPA with a completed EPA Form 3520-9 (copy on page
D-7) along with a paid work invoice documenting that the parts
were replaced.
1/ Some catalytic converters contain removable pellets. In
such a case, only the pellets need to be removed and
reinstalled, and the outside casing may remain on the
vehicle.
-------
D-5
e. If the test results are negative, the test report
form (with the Plumbtesmo paper strip attached) must be
mailed to EPA for confirmation.
f. If EPA determines that the test results are
satisfactory, EPA will release its obligation on the
Customs importation bond. Component replacement will
not be necessary for your vehicle.
B. Unbonded Entries
YOU MAY NOT NEED TO POST A BOND! The importation of U.S.
version vehicles equipped with a catalytic converter or a
catalytic converter and oxygen sensor from countries other than
Canada, Mexico, Japan, Australia, Taiwan, and Bahama Islands will
not be subject to bonding for EPA purposes in the following
cases:
1) Vehicles participating in and meeting the requirements
of the Department of State (DOS), Department of Defense
(DOD), or Panama Canal Commission (PCC) programs
approved by EPA. For more information regarding DOD1s
program you should contact the DOD POV Action Officer
at (703) 614-4082; for the DOS program you should
contact the General Services Officer at (202) 647-3658;
and for the PCC program you should contact the
Assistant to the Secretary for Commission Affairs at
(202) 634-6441. An EPA Form 3520-1 with category "AA"
declared and a certification statement from one of the
above programs must be submitted to U.S. Customs upon
entry of the vehicle into the U.S.
2) Any vehicle which is equipped with a catalytic
converter or a catalytic converter and oxygen sensor
and participates in one of the EPA approved
Manufacturers or Shippers Catalyst Control Programs on
page D-8. An EPA Form 3520-1 with category MAA"
declared and a certification statement from one of the
above programs must be submitted to U.S. Customs upon
entry of the vehicle into the U.S.
-------
D-6
OUR Mo fltttttMWS Aai
!»rowl .»ptr.. S-31-g«
&EPA
United States Environmental Protection Agency
Washington, DC 20460
Application for Final Admission • Plumbtssmo Tsst Rsport
¦ES0LTS
Warning: Any porxon who knowingly make* any fsiet or fraudulent etatement or oono—h a material feet ahaM be fined
nat more than $250,000 or hnprieoned not more then S years or both. 1t Unit*/ Statu* Cod* 1001
1. Port of Entry
2. Enry Data (m&dftyr) 3. Entry Number
4. Vehicle ktonMcation Number (VIN)
5. Vehicle Manufacturer
6. Vehicle Modal
7. Vehicle Modal Year
Vehicle Own* Name (Last, First, Ml)
9AMats (Stneet. City, Stale, ZIP and TelephoneNumber)
10. Vahida Storage location (if different than owners addressXNo. P.O. Boxaa)
11. List of counties in which vehicle was driven:
12. I certify under penalty of perjury that ihit vehicle was diven by me overseas on unleaded hel exclusively and at no lime was leaded
M mtoduced into this vehicle. t understand that I oodd be subject to cr'wY and/or criminal prosecution If I knowingly make a false or
fraudulent statement or conoeal a material fact. I certify that the information I have provided is oorract
Signature of Owner
Taxpayer ID# (SSN)
Date
Telephone Number
13. I certify under penalty of perjury that I have conducted the EPA approved test for detection of leaded fuel usage in acoordance
with the attached instructions and have attached the test paper results above. AM test procedures and guidelines were adhered to.
Furthermore, I confirm that the fuel filler inlet restridor, catalytic convener and oxygen sensor, it intact and operational. I understand the
warning regarding the submission of false or fraudulent statements or oonceaSng material fact and I certify fiat the information I have
provided is correct.
Signature, Business Name and Address of Licensed Mechanic
Date
Mailing Instructions
Mail this form to tfte following address
when using certified U.S. Express Mail,
or regular mail:
Attn. FINAL ADMISSION
U.S. Environmental Protection Agency
Manufacturers Operations Division (6405J)
401 M. St., S.W.
Washington, DC 20460 (202) 233-9660
For delivery by a courier service
(a. g., Federal Express, DHL, etc....)
Only use the following adtfress:
Attn. FINAL ADMISSION
U.S. Environmental Protection Agency
Manufacturers Operations Division (6406J)
501 3rd St, N.W.
Washington, DC 20001 (202) 233-9660
Privacy Act Statement
Cotectfon of the information on tfiis form is authorized by the Clean Air Act, 42 USC sec. 7401 at . seq. (see40CFR sec. 65.1501 etseq..
Importation of Motor Vehicles and Motor Vehicle Engines). The Environmental Protection Agency (EPA) uses this information to determine
compliance of imported motor vehicles and heavy-duty engines with U.S. emission requirements and for investigations with respect to
EPA's import regulations. Disclosure o( this information may be made to other Federal. State or focal law enforcement agencies when
there is a violation of crvi or criminal law. Furnishing the information on this form, is voluntary, but failure to do so may result in
dsapproval for entry into the U.S. of the motor vehicle or heavy-duty engine identified on this form.
Paperwork Reduction Act Notice
The public reporting burden for this collection of information is estimated to average 30 minutes per response. This estimate includes
lime for reviewing instructions, searching existing data souroes, gathering and maintaining the needed data/and completing and
reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information
to the Chief, Information Policy Branch (PM-223), U. S. Environmental Protection Agency, 401 M Street, SW, Washington, DC 20460,
and the Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. marled Attention:
Desk Officer for EPA.
EPA Form 3520-1S (Rev. 5-92)
Previous versions are obsolete
-------
D-7
MECHANICS INSTRUCTIONS - FLUMBTESMO TEST
1. Inspect the fuel filler inlet restrictor. Using a nozzle
gauge with an outside diameter of 0.930 inches (2.363 cms)
which is the size of a leaded fuel nozzle, verify that the
fuel filler inlet restrictor has not been tampered with.
If the nozzle gauge fits into the inlet restrictor (which
indicates leaded fuel usage), the catalytic converter,
oxygen sensor, and fuel filler inlet restrictor must be
replaced (regardless of the plumbtesmo test results).
2. Do not clean or wipe inside the tailpipe prior to testing.
3. Make sure hands are cleaned before handling plumbtesmo test
paper.
4. Apply 3 to 5 drops of distilled water to one strip of test
paper. The paper should never be moistened such that water
drips from it.
5. Press moistened strip to an area inside the tailpipe with
a screwdriver (or other suitable tool) for 2 to 5 minutes.
6. Lay strip on a clean surface and let dry for 15 minutes.
7. If any shade of pink or red is indicated on the strip, the
catalytic converter and oxygen sensor must be replaced.
Replacement parts must be original equipment.
NOTE: It is not necessary to have the engine running while
performing this test.
-------
D-8
Form Approved OMB Mo. 02QgQ-O95 Atmrovsl «»plr»i 3-31-94
United State* Environmental Protection Agency
P Cp/V WuNnglM, DC 204*0
\/Crr\ Application for Final Admission • U.S. Version Vehicle
Warn/nff: Any pareon who knowingly makee any falae or fraudulent atatement or oonoaala a material tact ahall ba fined
not mora than $250,000 or Imprisoned not mora than 5 yaara or both. It United Stataa Coda 1001
1. Porto*Entry
S. Vehicle Manufacturer
2. Entry Date (rrxVdy/yr) 3. Entry Number
6. Vehicle Model
4. Vehicle Identification Number (VIN)
7. Vehicle Model Year
Name®, Addresses, and Telephone Numbers of Relevant Parties
8. Vehicle Owner Name (but. First, Ml)
Address (Street, City, State, ZIP and Telephone Number)
0. Vehicle Storage Location (if different than owners addres«XNo. P.O. Boxes)
10. I have road and understand the warning above regarding the submission of falsa or fraudulent statements or concealing a material
fact, and I certify that the information I have provided is correct
Signature of Owner
Taxpayer 10* (SSN)
Date
Telephone Number
11. I certify under penalty of perjury that I am a licensed mechanic and that the catalytic convener and oxygen sensor (if the vehicle was
manufacturered with an oxygen sensor), have been replaced with new original equipment, or with the original catalytic converter and oxygei
sensor which were removed prior to exportation from the U.S. The replaced catalytic converter and oxygen sensor are functioning properly
on the vehicle identified on this form. A copy of the invoice for parts and labor is attached to this form. I have read and understand the
warning above regarding the submission of false or fraudulent statements or concealing a material fad and I certify that the information I
have provided is correct.
Signature of Licensed Mechanic
Mailing instructions
Date
Mail this form to (he following address
when using oertified U S Express Mail,
or regular mail:
Attn. FINAL ADMISSION
U.S. Environmental Protection Agency
Manufacturers Operations Division (6405J)
401 M. St.. S.W.
Washington, DC 20460 (202)233-9660
For delivery by a courier service
(e. g., Federal Express. DHL, etc....)
Only uie the following address:
Attn. FINAL ADMISSION
U.S. Environmental Protection Agency
Manufacturers Operations Division (6405J)
501 3rd St, N.W.
Washington. DC 20001 (202) 233-9660
Privacy Act Statement
Collection of the information on this form ts authorized by the Clean Air Act, 42 USC sec. 7401 et. seq. (see 40 CFR sec. 85.1501 et seq.
Importation of Motor Vehicles and Motor Vehicle Engines). The Environmental Protection Agency (EPA) uses this information to determine
compliance of imported motor vehicles and heavy-duty engines with U.S. emission requirements and for investigations with respect to
EPA's import regulations. Disclosure of this information may be made to other Federal, Stats or local law enforcement agencies when
there is a violation of civil or criminal law. Furnishing the information on this form, is voluntary, but failure to do so may result in
disapproval for entry into the U.S. of the motor vehicle or heavy'-duty engine identified on this form.
Paperwork Reduction Act Notice
The public reporting burden for this collection of information is estimated to average 30 minutes per response. This estimate includes
time for reviewing instructions, searching existing data sources, gathering and maintaining the needed data, and completing and
reviewing the collection of information. Send oomments regarding the burden estimate or any other aspect of this collection of information
to the Chief, Information Policy Branch (PM-223), U. S. Environmental Protection Agency, 401 M Street SW, Washington, DC 20460,
and the Office of Information and Regulatory Affairs, Office of Management and Budget Washington, DC 20503, marked Attention:
Desk Officer for EPA.
EPA Form 3520-9 (Rev. 5-92)
Previous versions are obsolete
-------
D-9
CATALYST CONTROL PROGRAMS APPROVED BY EPA
Note: Hot all vehicles associated with these parties are included in • retrofit prograa. Each vehicle
which has participated in one of these progress will either have a "Catalyst Approved For Iaport" label
under the hood (or on the door jaab) or a certification statement provided to the owner and signed by an
agent of the approved coapany.
* These programs are approved for use by employees of the agency/organization only.
A. Manufacturers
BMW
BHU of North America
Montvale, NJ 07645
Rep: Mr. Bill Bitting
(201) 573-2195
APO, NY 09405
Rep: Mr. Patrick Coyne
03943-6101
Ferrari/Fiat
Fiat Research and Development
Parklane Towers West
Suite 1210
Dearborn, MI 48126
Rep: Mr. Mark Recchia
(313) 336-2400
Jaguar
Jaguar Cars, Inc.
Product Legislation and Compliance
600 Willow Tree Road
Leonia, NJ 07605
Rep: Ms. Diane Black
(201) 818-8171
Mercedes Benz
Mercedes Benz of North America
Product Regulation and Compliance
One Mercedes Drive
Montvale, NJ 07645
Rep: Mr. Harold Polz
(201) 573-6000
B. Shippers
Auto Driveaway Co.
310 S. Michigan Avenue
Chicago, IL 60604
Rep: Mr. Perry L. Barcroft
(312) 341-1900
(800) 621-4155
E.H. Harms GmbH & Co.
Postfach 105040
2800 Bremen 1
West Germany
Rep: Ms. Helga Pietsch
421-3689-104
G. Albrecht Co.
Steubenstrasse 7b
Postfach 120426
2850 Bremerhaven 12
West Germany
0471-40174
The American Way
29 Market Place
MiIdenhalI, Suffolk 1P28 7EF
England
Rep: Mr. Allan Kri11
(0638) 717132
Peugeot
Peugeot U.S. Technical
Research Co.
1099 Wall Street, West
Lyndhurst, NJ 07071
Rep: Mr. Richard Lucki
(201) 438-1113
Porsche
Porsche of North America, Inc.
100 W. Liberty Street
Reno, Nevada 89051
Rep: Mr. Mike Love
(702) 348-3000
Rolls Royce
Rolls Royce Motor Cars, Inc.
P.O. Box 476, 120 Chubb Avenue
Lyndhurst, NJ 07071
Rep:
(201) 460-9600
Saab
Saab/Scania of America, Inc.
P.O. Box 697
Orange, CT 06477
Rep: Mr. David Raney
(203) 795-5671
Karl Gross Co.
Hafenhaus Columbusbhf
Postfach 120244
2850 Bremerhaven
West Germany
Rep: Mr. Karl Gross
0471-4838-20
Transcar GmbH
Langer Kornweg 16
6092 Kelsterbach-Frankurt
West Germany
Rep: Mr. Ernst P. Grossman
06107-8051
U.S. Trade Corporation
1661 Katy L*ane
Fort Mill, SC 29715
Rep: Pieter Moes
(803) 548-6177
Ozark Fast Freight LTD
PSC #2
Box 1457
VoIkswagen/Audi
Volkswagen of America, Inc.
888 W. Big Beaver Road
Troy, MI 48007
Rep: Mr. Leonard Kata
(313) 362-6344
Volvo
Volvo Cars of North America
Rockleigh, NJ 07647
Rep: Hr. Gregory Buffalino
(201) 768-7300
Imorex Shipping Services Ltd.
32 St. Peters Street
Ipswich, Suffolk IP1-1XB
England
Rep: Mr. Alan Nunn
(0473) 213-411
European Automotive Compliance
Gevers Deynootweg 1130A
2586 BX Den Haag
Holland
Rep: Mr. Mervyn Calder
31-70-559245
-------
D—10
C. Other Organizations*
U.S. Department of Defense
Department of the Army
Deputy Chief of Staff Logistics
Washington, DC 20310
Rep: Mr. Gary Bull
(703) 614-4082
U.S. Department of State
2201 C Street, NU
Washington, DC 20520
Rep: Mr. John Miller
(202) 647-3658
Panama Canal Coftfltission
2000 L Street, NU
Suite 550
Washington, DC 20036
Rep:
(202) 634-6441
-------
E-l
FOR ADDITIONAL IMFORMATION
If you have any additional questions that are not answered by
this fact sheet, you may contact the Investigation/Imports Section
by telephone at (202) 233-9660, by fax at (202) 233-9596, or by
mail (regular, certified or registered) at:
U.S. Environmental Protection Agency
Manufacturers Operations Division (6405J)
Investigation/Imports Section
401 M Street, S.W.
Washington, D.C. 20460
For delivery by a courier service (e.g., Federal Express,
Airborne, etc.) only, use the following address:
U.S. Environmental Protection Agency
Manufacturers Operations Division (6405J)
Investigation/Imports Section
501 3rd Street, N.W.
Washington, D.C. 20001
When calling EPA concerning a particular vehicle, please have
the make, model, year and vehicle identification number (VIN) of
your vehicle (from the registration card) and, if it has already
been imported, the importer of record, the port of entry, date of
entry and entry number (from the EPA form 35^0-1) (You can only get
an EPA form 3520-1 from the port of entry and you should keep a
copy for your records) . When writing to EPA, include this
information, plus a telephone number (with area code) where you can
be reached during the day.
*** For further information concerning the regulations, you may
find the Federal Regulations in the September 25, 1987
Federal Register Vol. 52, No. 186 pages 36136 through 36164.
Revised 6/18/92
-------
ATTACHMENTS
-------
MANUFACTURERS U.S. REPRESENTATIVES
Car Companies
Contact
Citv & State
Phone No.
1.
Alpha Romeo
Mr. Hick D'Uva
Orlando, FL
(407) 856-5000
2.
Austin Morris
Rover, Triimph, MG
Mr. Dennis Johnston
Lanham, MD
(301) 731-8709
3.
BMW
Environmental Engineering
Department
Montvale, NJ
(201) 307-4000
4.
Chrysler
Jeep, Eagle,
Customer Relations
Detroit, MI
U.S.
Canada
1 (800) 992-1997
(313) 497-1934 or
(313) 497-1961
5.
Fiat, Ferrari
Lancia
Mr. Albert Hegro
Dearborn, MI
(313) 488-5600
6.
Ford
Mr. James Dubke
Dearborn, MI
(313) 446-5961
7.
GM, Opel,
Vauxhall
Mr. Robert Cowell
Warren, MI
(313) 947-1782
8.
Honda
Customer Assistance
Torrance, CA
(213) 783-2000
9.
Hyundai
Mr. I ban Lee
Arm Arbor, MI
(313) 747-6600
10.
Isuzu
Customer Relations
Southfield, MI
(313) 455-7595
11.
Jaguar
Mr. Doug Taylor
Leonia, NJ
(201) 818-8500
12.
Lotus
Customer Relations
Norwood, NJ
(201) 784-0726
13.
Maserati
Mr. Donel Olson
Huntington Beach,
, CA
(714) 891-4821
14.
Mazda
Mr. Takahasi
Ann Arbor, MI
(313) 930-2507
15.
Mercedes-Benz
Product Compliance
Department
Montvale, NJ
(201) 573-2784
16.
Mitsubishi
Customer Assistance
Ann Arbor, MI
(313) 971-0900
17.
Nissan-Datsun
Mr. Mike Beckage
Gardena, CA
(310) 719-5463
18.
Peugot
Citroen
Mr. Richard Lucki
Lyndhurst, NJ
(201) 438-1113
19.
Porsche
Mr. Mike Love
Reno; NV
(702) 348-3198
20.
Renault
Mr. John Fellenberg
Detroit, MI
(313) 493-8767
21.
Rolls Royce
Mr. Kenneth Preece
Lyndhurst, NJ
(201) 460-9600
22.
Saab
Ms. Marylou Wickwire
Orange, CT
(203) 795-5671
23.
Subaru
Ms. Beth Sinclair
Cherry Hill, NJ
(609) 488-8630
24.
25.
Toyota
Volkswagen, Audi
Customer Assistance
Customer Service
Torrance, CA
Troy, MI
U.S.
Canada
(310) 781-2801
1800-331-4331
1 (800) 822-8987
(313) 362-7300
26.
Volvo
Mr. Gregory Buffalirio
Rockleigh, NJ
(201) 768-7300
Ext: 7125
Motorcycle Companies
Contact
Citv & States
Phone No.
1.
BMW
Environmental Engineering
Department
Montvale, NJ
(201) 307-4000
2.
Harley-Davidson
Mr. Robert Miller
Milwaukee, WI
(414) 342-4680
3.
Honda
Customer Assistance
Torrance, CA
(213) 532-9811
4.
Kawasaki
Ms. Julie Birch
Santa Ana, CA
(714) 770-0400
5.
Suzuki
Mr. Jeffrey Link
Brea, CA
(714) 996-7040
6.
Triimph
Mr. Wayne Moulton
Placentia, CA
(714) 996-8200
7.
Yamaha
Customer Relations
Cypress, CA
(714) 761-7330
Revised 6/3/92
-------
/ J2L \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
| ^XlAZ ? WASHINGTON, D.C. 20460
v7
' PflO^
OFFICE OF
AIR AND RADIATION
The following is a list of independent commercial importers (ICIs) who
hold a currently valid certificate of conformity from EPA as of the date
of this list. This certificate allows the ICI to import certain
nonconforming vehicles into the United States until December 31, 1992.
THE MAKES OR MODELS THAT AN ICI CAN IMPORT ARE LIMITED. You should
contact the ICI to determine if he/she is qualified to import your
particular vehicle.
Chanpagne Imports Inc.
200 West 5th Street
Lansdale, PA 19446
Rep: Nr. Joe Marino
Phone: 1-800-535-9728
(215) 361-1304
ICI International
4490 35th Street
Orlando, FL 32811
Rep: Nr. Ed Sequel
Phone: (407) 839-3663
Import Trade Services USA Inc.
177 Red Hill Road
P.O. Box 677
New City, NY 10956-0677
Rep: Nr. Ken Shaffer
Phone: 1-800-USA-EPAS
(914) 638-9039
Fax: (914) 638-9016
Liphardt Associates, Inc.
15 Trade Zone Drive
Ronkonkoma, NY 11779
Rep: Nr. Peter Dibernardi
Phone: 1-800-322-3702 (in U.S.)
(516) 588-8288 (abroad)
J.K. Ho torcars. Inc.
3500 Sweet Air Street
Baltimore, HD 21211
Rep; Nr. Jonathan Weisheit
Phone: (301) 366-6332
Wallace Environmental
Testing Laboratories
2140 Uirtcrest
Houston, TX 77055
Rep: Nr. Les Weaver
Phone: (713) 956-7705
G I K Automotive Conversion
3231 S. Standard Ave.
Santa Ana, CA 92705
Rep: Nr. George Geaayel
Phone: (714) 545-9503
EPA DOES NOT ENDORSE OR RECOMMEND ANY PARTICULAR ICI ON THIS LIST.
EPA cautions that an ICI^s capability of bringing a vehicle into
conformity with U.S. emission requirements does not guarantee that in
individual cases the work will be properly performed. Test documentation
for an individual vehicle and other information concerning the quality of
modifications will be carefully scrutinized to determine whether such
vehicle meets all applicable EPA requirements under the imports
regulations.
This may not be an exclusive list of ICIs that are capable of
modifying/testing nonconforming vehicles. Individuals should contact EPA
if they need information regarding ICIs that have obtained approval since
the issuance of this list.
@ Printed on Recycled Paper
-------
Form Approved. OMB No. 02060-095 Approval expires 3-31-94
&EPA
United State* Environmental Protection Agency
Washington, DC 20460
Application for EPA Prior Written Approval
1. Importer's Name (Last, First, Ml)
2. Importers Address (Street, City, State, Zip Code)
3. Expected or actual date of arrival at U.S. port of
entry
4. Vehicle Identification Number (VIN) or Heavy-duty Engine Number
5. Original Manufacturer and Model of Vehicle
6. Date of original manufacture
7. Date vehicle purchased
8. Port of entry (UNK if unknown)
9. Code letter of requested exemption or exclusion, (refer to back of form)
10. Explanation of requested exemption or exclusion, use additional sheets if necessary (attach documentation). Also, 1st special mailing
instructions for prior approval.
11. 1 certify under penalty of perjury that the information 1 have provided is correct and complete and that the attached documentation
does not contain any false or fraudulent statements or conceal any material facts.
Signature of Importer
Daytime Telephone Number
Date
Mailing Instructions and Privacy Act Statement
This form may be used to request admission by EPA of an imported motor vehicle that qualifies for an exemption from
compliance with Federal emission requirements. All of the above information must be submitted in order for your case to be
reviewed. Failure to submit an adequate explanation or documentation as to your qualification for an exemption or an
exclusion wM delay EPA's review of your case or may result in a denial of your request When this form is completed,
submit rt along with proper documentation to:
Mail this form to the (blowing address
when using certified U.S. Express Mail,
or regular mail:
Attn: PHor Approval
U.S. Environmental Protection Agency
Manufacturers Operations Division (6405J)
401 M St.. S.W.
Washington. DC 20460 (202) 233-9660
For delivery by a courier service
(e. g., Federal Express, DHL, etc....)
Only use the following address:
Attn: Prior Approval
U.S. Environmental Protection Agency
Manufacturers Operations Division (6405J)
501 3rd St, N.W.
Washington, DC 20024 (202) 233-9660
Cotection of the information on this form is authorized by the Clean Air Act, 42 USC sec. 7401 et.. seq. (see 40 CFR sec. 85.1501 et seq.,
Importation of Motor Vehicles and Motor Vehicle Engines). The Environmental Protection Agency (EPA) uses Ms information to determine
compliance of imported motor vehicles and heavy-duty engines with U.S. emission requirements and for investigations with respect to
EPA's import regulations. Disclosure ot this information may be made to other Fodoral, State or locaI law enforcement agencies when
there is a violation of civi or criminal law. Furnishing the information on this form, is voluntary, but failure to do so may result in
disapproval for entry into the U.S. of the motor vehicle or heavy-duty engine identified on this form.
Paperwork Reduction Act Notice
The public reporting burden for this collection of information is estimated to average 30 minutes per response. This estimate
includes time for reviewing instructions, searching existing data sources, gathering and maintaining the needed data, and
completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect
of this collection of information to the Chief, Information Policy Branch (PM-223), U. S. Environmental Protection Agency.
20503, marked Attention: Desk Officer for EPA.
EPA Form 3520-14 (5-92)
Previous version* are obsolete
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Exertions or exclusions are granted by EPA In the following cases (see categories on for* 3520-1, Item 14):
(6) Repair/Alteration Exemption - the vehicle is imported solely for repair or alteration. It may
not be operated on public roads in the U.S. and it must be exported upon completion of the repair or
alteration. Include location and type of repair or alteration. There is an EPA obligation on the
Customs bonds for these vehicles.
(I) Testing Exemption - the vehicle is imported for testing. It may be operated on public roads
provided that the operation is an integral part of the test. The vehicle may not be sold. It must
be exported one year from the date of entry unless an extension is granted. The following information
must be submitted to EPA: location and type of testing; a testing purpose which is appropriate for an
exemption in accordance with section 203(b)(1) of the Clean Air Act; an explanation of the necessity,
scope, reasonableness of the testing program; the method of disposal of the vehicle upon completion;
and all other information required by 40 CFR 85.1705. There is an EPA obligation on the Customs bonds
for these vehicles.
(J) Pre-certification Testing Exemption - the vehicle is imported by an ICI for testing in order to
obtain a certificate of conformity. In general, an ICI may not receive more that one exemption per
engine family. The vehicle must be exported in 180 days if no certificate is issued for the vehicle,
and the importer must otherwise comply with the provisions of 40 CFR 85.1706. There is an EPA
obligation on the Customs bonds for these vehicles.
(K) Display Exemption - the vehicle is imported solely for display. It may not be operated on public
roads or sold. The following information must be submitted to EPA: a statement of the necessity of
and reason for display; a schedule of dates and locations for the display program; explanation of the
use of the vehicle on the roads or highways; the method of disposal of the vehicle upon completion of
the display period; a description of who will view the display; a listing of all vehicles currently
in the display program; a statement that the vehicle will not be sold in the U.S.; and any other
information required by 40 CFR 86.1707. There is an EPA obligation on the Customs bonds for these
vehicles.
(L) Racing Exclusion - the vehicle meets one or more of the exclusion criteria outlined in 40 CFR
85.1703. It may not be registered or licensed for use on or operated on public roads or highways in
the U.S. The following information must be submitted to EPA: the name of the sanctioning body and
competition class; a schedule of racing events, including dates and locations where the vehicle will
participate; a copy of the competition racing license; a letter from the state's Department of Motor
Vehicles that states that the vehicle cannot be license for use on the public streets or highways,
and explains why it cannot be licensed; and four photographs of the vehicle must be included, one each
of front and rear and each side. There is no EPA obligation on the Customs bonds for these vehicles.
(M) Hardship Exaction - the vehicle is imported by an individual under circumstances of severe •
hardship. Documentation appropriate to demonstrate the case must be submitted. This applies only to
those "...unforeseen cases of extreme hardship or extraordinary circumstances." (40 CFR 85.1511(c)(2))
An example of a possible hardship exemption is a handicapped person who needs a special vehicle which
is unavailable in a U.S. certified configuration. The following information must be submitted to EPA:
financial information, if applicable, demonstrating need; a statement that the vehicle is strictly for
personal use; and other documents relevant to the individual request. Here lack of knowledge of the
regulations or the lack of availability of an ICI to import your vehicle is not alone sufficient to
grant a hardship exemption. There is no EPA obligation on the Customs bonds for these vehicles.
(H) National Security Exemption - the vehicle is imported by manufacturer for national security
reasons. The request is endorsed by an agency of the Federal Government charged with responsibility
for national defense (40 CFR 87.1708). There is no EPA obligation on the Customs bonds for these
vehicles.
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