Instructions for Certifying Imported
Mini Trucks

    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

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: 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

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

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

   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) 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.

      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

      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

            •  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:

       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

         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

      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:
   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

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.  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.

      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).

      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

            A sample  certificate is included in Appendix C.

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.


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.

      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

    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.
             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

    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."


    "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

C. Appendix C - Sample Certificate of Conformity
                                   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