Instructions for Certifying Imported
Mini Trucks
Protection
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Instructions for Certifying Imported
Mini Trucks
Certification and Compliance Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
United SsotoM FPA-A?n-R-nQ
^A 4A) B Ub
June 2009
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I. Introduction
EPA has revised regulations that affect the importation of vehicles that were
originally built and used as motor vehicles but have been converted for nonroad use.
These regulatory provisions were published in the Federal Register on October 8, 2008
(73 FR 59053), and can be found on our web site at:
http://www.epa.gov/otaq/regs/nonroad/marinesi-equipld/bondfrm.pdf. Under the revised
regulations, EPA now requires certification of engines and vehicles converted for
nonroad use that are imported on or after December 8, 2008.
Japanese Kei-class light-duty trucks, also known as mini trucks, which have been
converted to limit speed to 25 miles per hour (mph), are impacted by the new
regulations. Generally, mini trucks are small trucks or vans with small spark-ignited (SI)
engines with displacement below 1000 cubic centimeters and maximum engine power
less than 30 kilowatts (kW) with a governed maximum speed of 25 mph or less. Mini
trucks can also fall into the Large SI category if they are either >1000cc displacement
or > 30kW maximum engine power with a governed maximum speed of 25 mph or less
(after 2011 model year the maximum engine power will be determined without any
mechanical governor).
The revised regulations do not abolish importation of these products, but they do
add the requirement to certify engines before importation. Certification of nonroad
engines generally involves testing the engines to show that emission levels are below
the standards, applying to EPA for a certificate of conformity, and complying with other
requirements specified in the applicable regulations (either 40 CFR 90, 40 CFR 1054 or
40 CFR 1048) for certified engines. In order to be considered nonroad, mini trucks must
be speed limited to less than 25 mph, and the manufacturer (the importer will be
referred to as the manufacturer through out this document) must prove the minitruck
has a robust tamper-proof speed limiting method.
If the imported engine/vehicle was originally equipped with automotive-type
emission controls, we would expect only minor modifications to be needed to meet
nonroad engine emission standards. If the engine/vehicle does not have emission
controls, extensive modifications may be needed to comply with nonroad engine
emissions standards.
EPA has determined that only mini trucks that have been permanently modified
from the original motor vehicle design such that the resulting vehicle speed is 25 mph or
less are considered to be nonroad vehicles. All other mini trucks are classified as motor
vehicles and must meet all applicable regulations for motor vehicles. This is consistent
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with EPA's motor vehicle exclusion determinations per the Code of Federal Register
(CFR), 40 CFR 85.1703 for mini trucks.
As discussed above, mini trucks generally fall into the Small SI (40 CFR 90)
category which includes engines < 19 kW (engines with displacement < 10OOcc and
power < 30kW may optionally meet Small SI standards). Engines with power >30 kW
or displacement > 1000 cc must be certified to the Large SI (40 CFR 1048) standards.
The following requirements apply uniquely to Large SI engines:
• More stringent exhaust emissions standards including a useful life of
5000 hours (§1048.101)
• Field-testing standards (§1048.101 (c) and 1048.515)
• Evaporative controls (§1048.105)
• Diagnostic requirements (§1048.110)
• Different steady state duty cycle (§1048.505)
• Transient duty cycle for engines governed to operate with maximum
test speed at or below 3400 rpm (§1048.510)
• In-use testing program for manufacturers (Part 1048 Subpart E)
• Lower threshold for production line testing (Part 1048 Subpart D).
This document is intended to provide an overview of the processes and
procedures that must be completed in order to obtain an EPA certificate of conformity,
found in 40 CFR 90. However, beginning in 2011 Model Year, the procedures that must
be completed in order to obtain an EPA certificate of conformity can be found in 40 CFR
1054. 40 CFR 1054 establishes a new set of emission standards and also includes
additional reporting requirements. Most other general certification procedures remain
the same. The following outlines the new/expanded requirements for 40 CFR 1054:
• Evaporative emissions compliance - full requirements are outlined in
40 CFR 1060. Requirements include:
o Fuel line permeation (§1060.102) 15 g/m2/day standard
o Fuel tank permeation (§1060.103) 1.5 g/m2/day standard @
28°C (2.5 g/m2/day @ 40°C)
o Optional Diurnal certification (to replace fuel line and fuel tank
certification) (§1060.105(e))
o Running Loss demonstration (§1060.104)
• Compliance at varying atmospheric pressures (§1054.205®)
• Listing of ports at which engines have been imported over the last
twelve months (§1054.205(aa)(1))
• Names and addresses of agents you have authorized to import your
engines (§1054.205(aa)(2))
• Location of a test facility in the US where your engines can be tested
(§1054.205(aa)(3)
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Any individual or company intending to certify and/or import mini trucks into the U.S.
should read all of the applicable regulatory provisions as the certificate holder is
responsible for all warranty and in-use compliance activities. The applicable regulations
for minitrucks (certified as nonroad engines) are as follows:
Power <30 kW AND Engine Displacement < 1000 cc
2009 and 20 10 MY
40 CFR 90
201 1 MY and Beyond
40 CFR 1054, 40 CFR
1060, 40 CFR 1068,
40 CFR 1065
Power >30 kW OR Engine
Displacement > 1000 cc
(and power >1 9 kW)
2009 MY and Beyond
40 CFR 1048
II. Pre-Application
In order to hold a certificate you have to be the importer of the product or the
manufacturer of record. In order to be established as the manufacturer of record, the
items in this section must be completed by the certificate holder prior to preparation and
submission of the certification application. Be sure to allow ample time to complete the
steps in this section.
A. Obtaining a Manufacturer Code
The CFR defines a nonroad engine manufacturer as any person engaged in the
manufacturing or assembling of new (as defined in 40 CFR 1048.801) nonroad engines
or the importing of such engines for resale, or one who acts for and is under the control
of any such person in connection with the distribution of such engines.
All manufacturers that plan to certify vehicles or engines with EPA must first
obtain a three-character EPA manufacturer code. This code will be used in each
certified engine family name and provides a direct link to the certifying company.
Obtaining a manufacturer code is done via the Agency's Central Data Exchange
(CDX). CDX is the single point of entry for electronic environmental information
submissions to the Agency. Once you complete this process, the manufacturer code for
your company will be sent to the business e-mail address you provided.
If you are a new manufacturer who has not obtained a three-character
manufacturer code from EPA, please follow the steps in the manufacturer code request
instructions found at http://www.epa.gov/otaq/verifv/index.htm
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B. EPA Contact Persons
The manufacturer must assign a primary contact person to work with EPA. EPA
will direct all communications, including issuance of the Certificate of Conformity, to the
manufacturer's primary contact, unless otherwise directed.
Information for the manufacturer's primary contact person may be mailed via
standard U.S. mail to (express Mail such as FedEx or UPS to this address will be
returned to sender):
Heavy-Duty and Nonroad Engine Group
U.S. Environmental Protection Agency
1200 Pennsylvania Ave. N.W.
Mail Code 6405J
Washington, DC 20460
For express mail deliveries such as FedEx or UPS, please use the following
address: (regular U.S. mail delivered to this address will be returned to sender):
Heavy-Duty and Nonroad Engine Group
U.S. Environmental Protection Agency
131OL Street, NW
Suite 656C
Washington, DC 20005
Each manufacturer will be assigned a primary EPA contact. However, initial
Questions should be directed to Mike Marko at the above address or by e-mail at
marko.michael(S)epa.gov. Mr. Marko will direct manufacturers to the primary EPA
certification contact person as appropriate.
C. Manufacturer's Model Year Certification Plans (Letter of Intent)
EPA suggests that each manufacturer provide written certification plans for each
model year in advance of submitting the certification application. The submission of the
certification plan allows manufacturers to notify EPA of any variations from the
certification requirements that may require advanced approvals, such as deviations from
the required test procedures, test equipment, or test facilities specified in the regulatory
requirements. This is also the time to provide justification for the worst case test engine
selection. Any issue where EPA approval is needed should be addressed in advance of
acting on the issue to avoid non-approval and required retesting, reselection, etc. The
plans should include an estimate of the number of engine families to be certified as well
as any unusual circumstances that may affect certification.
Manufacturers who choose not to request advance approval in a timely manner
may face delays in processing the certification application. As a general rule, the EPA
certification contact will not respond to model year plans that have been submitted
unless further discussion or clarification is needed.
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D. Bond Requirement and U.S. Agent for Service
40 CFR 90.1007 (40 CFR 1054.690) specifies the bond requirement which
covers any possible compliance action- recall, penalties, warranty failure, etc. A fact
sheet explaining the bond requirements as well as the worksheet that must be
submitted at the time the Application for Certification is submitted can be found on our
web site at http://www.epa.gov/otaq/certdat2.htm.
An Agent for Service is defined as a contact located in the United States that will
receive all correspondence (test orders, subpoenas, etc.) and ensure that the certificate
holder is informed. The agent for service information is required to be submitted at the
time of certification.
III. Application for Certification
A. Model Year
The model year of an imported used mini truck will be the same as the calendar
year of importation or date of conversion if operated as a speed-limited mini truck before
importation. A mini truck that is converted near the end of a calendar year and not
imported until the following calendar year is required to meet the standards of the
following calendar year. For example, if a mini truck is converted in November of 2010
and is imported in January of 2011, it will be required to meet the 2011 model year
standards as defined in the appropriate section of the regulations. Manufacturers must
apply for certification on an annual basis.
B. Determining Engine Families
Manufacturers' product lines are divided into engine families. In order for
multiple engines to be classified in the same engine family, in addition to the base
engine being from the same engine manufacturer, the following criteria must be
identical for all of the engines, as defined 40 CFR 90.116 (d) (40 CFR 1054.230 (b)):
• Combustion cycle
• Cooling mechanism
• Cylinder configuration
• Number of cylinders
• Engine class. Engines of different displacements that are within 15%
of the largest displacement may be included within the same engine
family as long as all engines are within the same class
• Location of valves, where applicable
• Number of catalytic converters, location, volume and composition
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• Thermal reactor characteristics
• Fuel required
• Useful life - which will be 1000 hours for all minitrucks
EPA is willing to consider grouping multiple model years of original production of
a given brand of mini truck into a single model year of importation if a manufacturer can
provide a complete justification that they are identical in all material respects.
C. General Certification Application Requirements
A complete Certification Application must include the following:
1. Certification Application Fee
2. Signed Statement of Compliance
3. FileMaker Pro Application
1. Certification Application Fee
Once engine families have been determined, certification application fees can
be submitted. EPA will not start the review process until confirmation is received
that all required fees have been paid. To expedite review of the certification
application, payment should be submitted at least two weeks in advance of the
submission of the rest of the application.
The fee filing form and corresponding fees must be submitted for each engine
family to be certified. Fee regulations, amounts, filing forms, and guidance letters
can be found at: http://www.epa.gov/otaq/fees.htm
2. Statement of Compliance
A signed statement of compliance is required as part of a complete
certification application. The signed statement of compliance signifies that the
manufacturer understands and accepts the emission standards and other
requirements of the applicable CFR section to which the engines are being certified.
In the statement of compliance, manufacturers should specifically refer to the set of
regulations to which the engine complies. The signed statement of compliance
should be mailed to the Heavy-Duty and Nonroad Engine Group address given
above.
Requirements for this statement are specified in 40 CFR 90.107 (1054.205
(u)) and a sample statement of compliance are included in Appendix A.
3. FileMaker Pro Application
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Engine family applications must be submitted using a FileMaker Pro template
created by EPA for Nonroad SI engines. The files for this template and instructions
can be found at: http://epa.gov/otaq/certdat2.htm
D. Application Data Requirements
1. Confidential Business Information (CBI)
Information considered CBI is clearly marked in the FileMaker Pro
template. Only non-CBI material entered into the template will be posted on
EPA's engine certification data website. For additional information on CBI,
please refer to 40 CFR 90.4 (40 CFR 1054.815).
2. Durability Testing / Deterioration Factor (DF) Calculation
The manufacturer is required to test the worst case engine, which is
defined as the engine most likely to exceed the emission standard within a given
engine family (40 CFR 90.117, 40 CFR 1054.235). The most important factors
for determining the worst-case vehicle for mini trucks are substantially different
than for manufacturers producing engines from an assembly line. We consider
the extent of service outside the United States to be the most important factor in
selecting a worst-case test engine. This approach allows a manufacturer to
adequately demonstrate that all imported engines from the engine family will
comply with all emission standards for the post-importation useful life of the mini
truck, which is 1000 hours.
The emission results from the test engine serve to predict the maximum
emission level for all engines in the engine family throughout the engine's useful
life. There will be a multiplicative deterioration factor applied to the test results
from the test engine to show that it complies with the standards for the post-
importation useful life of 1000 hours. For small-volume manufacturers (up to
10,000 U.S. sales per year for the whole company) and for small-volume
emission families (up to 5,000 U.S. sales per hear for the engine family), this
deterioration factor can be assigned by EPA. Please contact your certification
representative for assigned deterioration factors.
Manufacturers that do not qualify for an assigned deterioration factor must
follow the procedures specified in 40 CFR 90 (40 CFR 1054) to determine a
deterioration factor based on durability testing, which is generally based on
service accumulation in a laboratory. This is the conventional approach used by
engine manufacturers for certifying their new engines.
If a manufacturer tests the worst-case engine, based on the engine's
service outside the U.S., then we would allow the manufacturer's application and
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certificate of conformity to include any engines, within the same engine family,
installed in vehicles that had a lower mileage than the test engine.
An example of this is as follows: A mini truck has 120,000 kilometers at
the time of importation; the engine is taken out of the vehicle and tested. The
deterioration factors are applied to the test results and the resulting certification
levels pass all applicable emission standards. These test results are considered
to be the worst-case emissions for the engine family. The certificate of
conformity may therefore cover engines from the same engine family that are
installed in mini trucks with an odometer reading of less than 120,000 kilometers
at the time of importation.
3. Certification Testing
Please refer to 40 CFR 90.119 (a) and Table 2 of Appendix A to Subpart E
of 40 CFR 90 (40 CFR 1054 Subpart F) to determine the applicable test cycles
for the engines to be certified. Please refer to 40 CFR 90 Subpart E (40 CFR
1054 Subpart F) for information about certification testing allowed in the
regulations. When testing an engine at its full useful life, you may follow the
scheduled maintenance instructions in 40 CFR 90.118(b) (40 CFR 1054.245 (b)
(4).
4. Certification Fuel
There are three options for certification fuel permitted in 40 CFR Part 90.
The first fuel option is average in-use gasoline (e.g., Clean Air Act Baseline),
specified in 40 CFR 90, Subpart D, Appendix A, Table 3 (40 CFR 1065 Subpart
H). The second option is to use the fuel specified in 40 CFR 1065, subpart H, for
gasoline-fueled engines. The third option allows small SI engine manufacturers
to use other fuels, such as natural gas, propane, methanol, or others, under
conditions described at 40 CFR 90.308(b)(2) and (3) (40 CFR 1054.645).
5. Data Carry Over
Under 40 CFR 90.119 (c) (40 CFR 1054.235 (d)), the engine manufacturer
may request to use test data from a previous EPA model year to represent a new
EPA model year. This is known as data carry over. Spaces are provided in the
FileMaker Pro certification template for manufacturers to designate "carry over"
data. Any differences between the previous and new model year engines must
be shown. The engine for which the carry over data is being used must fully
comply with the applicable standard.
Calendar year is the only change that allows data to be carried over. Data
may not, for example, be carried over into an engine family that has different
catalyst loading.
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6. Test Data Used by Multiple Manufacturers
Due to the nature of the used mini truck industry, EPA anticipates multiple
manufacturers contracting with a testing facility to use the same set of test
results. This may be acceptable given the following conditions are satisfied:
• The test data is representative. The test data must be used for an
engine family that is identical (as described above in the definition of
an engine family). The only difference in the engine family would be
the manufacturer code.
• The statement of compliance (found in Appendix A) includes a
statement referencing the contract between the manufacturer and the
testing facility generating the test data.
The in-use and warranty liability resides with the certificate holder. For
example if the same set of test data is used by 5 manufacturers, all 5
manufacturers would be subject to the recall investigation.
7. Labeling
All vehicles are required to have an engine information label per 40 CFR
90.114 (40 CFR 1054.135). The label must be permanently affixed prior to
importation or introduction into U.S. commerce in order to be compliant.
Label requirements and sample language are included in Appendix B. If
mini trucks have a label from the original manufacturer's initial certification in
Japan, the label to be installed per U.S. EPA regulations should include an
additional sentence. This sentence should read: "This label replaces the label
from the original manufacturer." The original label must not be removed.
8. Warranty
Warranty period is defined in 40 CFR 90.1103 (40 CFR 1054.120), two
years of engine use from the date of sale to the ultimate purchaser.
9. Production Line Testing
Manufacturer Production Line Testing (PLT) is required for all Small SI
engines covered under part 90 and the procedures are described in Subpart H of
40 CFR 90 (40 CFR 1054 Subpart D). Per 40 CFR 90.701 (b) (40 CFR 1054.301
(a) PLT is optional for small volume engine manufacturers (annual U.S.-directed
production volume <10,000 engines for non-handheld) and small volume engine
families (annual U.S.-directed production volume < 5000 engines). All Small SI
engines are subject to Selective Enforcement Audit (Subpart F of 40 CFR 90,
Subpart E of 40 CFR 1068).
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E. Completing the Application
1. EPA Review
EPA generally reviews each application within 30 calendar days of receipt
and fees payment confirmation. As part of the review, EPA will determine
whether to reguest additional information (audit) and/or to perform confirmatory
testing. Manufacturers should keep the test engine in its certification
configuration until the end of production.
EPA will contact the manufacturer should additional information or other
circumstances cause a delay.
2. Certificate of Confirmatory
Once EPA determines that the regulatory requirements are met, it will
issue a certificate of conformity for an engine family. Engines covered by the
certificate can be introduced into commerce as of the date listed on the
certificate. The certificate ceases to be valid for new production at the end of the
production period or December 31 of the calendar year for which the model year
is named, whichever date is sooner.
The certificate of conformity is signed by the Director of the Compliance
and Innovative Strategies Division who is delegated with signature authority by
the EPA Administrator. A certificate is not valid without this signature. An
electronic version of the original signed certificate will be e-mailed to the "Contact
Person" listed on the Engine Family page of the FileMaker Pro application.
Check to ensure that the correct contact person and contact information (mailing
address, phone number, fax number, and e-mail address) are listed on the
application.
A sample certificate is included in Appendix C.
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IV. Appendices
A. Appendix A - Sample Statement of Compliance
Manufacturer Primary Contact
XY Engine Company
4567 Industrial Highway
El Monte, CA91731
March 1, 200x
Heavy-Duty and Nonroad Engine Group
U.S. Environmental Protection Agency
Mail Code 6403J
1200 Pennsylvania Ave, NW
Washington, DC 20460
Dear :
Please find enclosed the model year 200x application for engine family
6XYES.1452GR. On behalf of XY Engine Company, I hereby certify that the test
engine(s), as described in this application for certification, has been tested in
accordance with the applicable test procedures, utilizing the fuels and equipment
required under subparts D and E of 40 CFR 90, and that on the basis of such tests the
engine(s) conforms to the requirements of 40 CFR 90. I further certify that the test
engine(s) was/were tested by {Name of Test Laboratory}, the testing facility identified in
this certification application, under a contract between XY Engine Company and [Name
of Test Laboratory]. I further certify that all engines in this engine family comply with all
requirements of 40 CFR 90 and the Clean Air Act and that the engines are not modified
in any way that would affect emissions performance.
Sincerely,
[MANUFACTURER PRIMARY CONTACT]
SIGNATURE
Enclosures
Refer in this letter to any alternate or special test procedure approvals or any other approvals required
from EPA for this engine family. It is recommended that manufacturers print the statement of compliance
o n company letterhead.
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B. Appendix B - Sample Label Wording
General engine label requirements are included in 40 CFR 90.114.
The following is a list of items which must be included on the permanent and
legible label identifying each nonroad engine:
1. The heading "Important Engine Information"
2. The full corporate name and trademark of the engine manufacturer
3. Date of engine manufacture [day (optional), month and year] - this
information may be excluded from the label if it is stamped on the
engine and included in the owner's manual
4. The statement "This engine conforms to [model year] U.S. EPA
regulations for small nonroad engines."
5. EPA standardized engine family designation
6. Engine displacement [in cubic centimeters]
7. Other information concerning proper maintenance and use or
indicating compliance or noncompliance with other standards may
be indicated on the label
8. For Phase 2 engines, the useful life category as determined by the
manufacturer pursuant to 40 CFR 90.105. Such useful life category
shall be shown by one of the following two statements to be
appended to the statement "This engine conforms to [model year]
U.S. EPA regulations for small nonroad engines."
a. "EMISSIONS COMPLIANCE PERIOD: [useful life] HOURS"
b. "EMISSIONS COMPLIANCE PERIOD: CATEGORY [fill in C,
B or A as indicated and appropriate from the tables in 40
CFR 90.105], REFER TO OWNER'S MANUAL FOR
FURTHER INFORMATION"
The following is a list of items which may be omitted from the label and included
in the owner's manual if there is insufficient space on the engine:
1. The statement "This (specify vehicle or engine, as applicable) is
certified to operate on (specify operating fuel(s))."
2. Identification of the Exhaust Emission Control System
(Abbreviations may be used and must conform to the nomenclature
and abbreviations provided by the Society of Automotive Engineers
procedure J1930, "Electrical/Electronic Systems Diagnostic Terms,
Definitions, Abbreviations, and Acronyms," September 1991.
3. All engine lubricant requirements
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The following is a sample emission label which conforms to these requirements:
Important Engine Information
Company XY. inc
This engine is certified to operate on gasoline.
This engine conforms to 2006 U.S. EPA regulations for small nonroad engines.
EMISSIONS COMPLIANCE PERIOD: 500 HOURS
Engine Family: 6XYXS .1451AB
Engine Displacement: 145 cc
Date of Manufacture: 4/2006
Exhaust Emission Control: TWC
Lubricant Requirements: SF15W-40
!f a manufacturer wants to modify the label (according to 40 CFR 90.114), then
the manufacturer must submit in writing a request for an alternate label.
Requests for alternate labels should be directed to the certification representative
listed in the body of this guidance document. The following is guidance on
engine label wording when engines are certified to meet only federal regulations
or both California and federal regulations:
Federal-Only Label
Labels indicating compliance with federal regulations only should follow wording
specified at 40 CFR 90.114(c)(7):
"This engine conforms to (model year) U.S. EPA regulations for small nonroad
engines."
As an option, the manufacturer may substitute PH1 or PHASE 1 (PH2 or PHASE
2, PH3 or PHASE 3, etc.) for model year.
Common California and Federal Label
To indicate that a CARB certified engine also meets federal standards, the label
should read as follows:
"This engine conforms to U.S. EPA PH2 (or PHASE 2) and [DATES] California
emission regulations for Small [Off-Road or Nonroad] engines."
or
"This engine conforms to U.S. EPA PH2 (or PHASE 2) regulations for small
nonroad engines and [DATES] California emission regulations for Small [Off-
Road or Nonroad] engines."
(Substitute PH2, PHASE 2, PH3, PHASE 3, etc. for PH1 or PHASE 1 wherever
applicable.)
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C. Appendix C - Sample Certificate of Conformity
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC 20460
200x Model Year Certificate of Conformity
Manufacturer: ABC Inc.
Small SI Engine Family \ABCS.0685AA
Certificate Number: ABCXNRSI-Ox-42
HC+NOx EEL: g/kW-hr 68
Date Issued: 6/30/200x ,-
Karl J. Simon. Director '"""""" C —
* *««
Compliance and Innovative Strategies Division .• ' =±, ^,-""
Office of Transportation and Air Quality ,~r— '-,- **
Pursuant to Section 213 of the Clean Air Act aa:||;S,C. sl&sBsp 7547)and 40 CFR 90,
and subject to the terms and conditions presjjffbed iftJbpse prt^^on^tlris certificate of
conformity is hereby issued for the Ibllowfiit^ifU.all nfl$iroad engtlp'Tamily. more fully
described in the documentation required! by 40 "CpKtJJt) and produced in the stated model
year. This certificate of conformity cdlptii, onh' thaSfrjiew small nonroad engines which
confomi in all material respects to the ^S§b.,specificfl^eB£ described in the
documentation required by 40 CFR 90 awl wjjjsji are pKkluced during the model year
stated on this certificate. TMKJeaificate Sf confitoitv does not cover small nonroad
engines imported prior to the "SfE&eftllUjfete-of the^eertificate.
This certificate of Hpnformity is conditional upon compliance of said manufacturer with
the averaging, baukl^gjtiidl trading prd^pfons of 40 CFR Part 90, Subpart C both during
and after model year |^odue(i|fc Jrai.hrfe to comply with these provisions may render this
certificate Jffpid ab initfe. "~"' "~r~
It is aierm of this certififi|te that the manufacturer shall consent to all inspections
descril|d«"il-,^^t,§0.lP*and 90.506 and authorized in a warrant or court order.
Failure to comply \vitfc the requirements of such a warrant or court order may lead to
revocation oi^iispemffon of this certificate for reasons specified in 40 CFR 90. It is also a
term of this that this certificate may be revoked or suspended or rendered void
ab initio for other reasons specified in 40 CFR 90.
This certificate does not cover small nonroad engines sold, offered for sale, or introduced.
or delivered for introduction, into commerce in the U.S. prior to the effective date of the
certificate.
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