Frequently Asked Question about Trailers Standards for Fuel Efficiency and Greenhouse Gas Emissions February 2017

Frequently Asked Questions about
Trailer Standards for Fuel Efficiency
and Greenhouse Gas Emissions
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• A manufacturer's Model Year for EPA/NHTSA compliance need not align with model
years defined for marketing purposes or for other regulations. Model Year may align with
calendar year. See the definition of Model Year at 40 CFR 1037.801.
• NHTSA's trailer program is optional until Model Year 2021.
3. What is the relationship between EPA and NHTSA for the trailer standards?
• EPA's GHG regulations and NHTSA's fuel consumption regulations are fully harmonized.
• The agencies have different regulatory authorities. NHTSA's fuel consumption standards
are authorized under the Energy Independence and Security Act of 2007, and EPA's
GHG emission standards are authorized under the Clean Air Act.
• EPA provides the certification/compliance portal for both EPA and NHTSA compliance
programs. Manufacturers annually submit compliance data to EPA to show compliance
with both programs.
• Manufacturers should contact EPA with any requests for determinations or approvals, or
for any other questions about the program; EPA will consult with NHTSA as needed to
ensure that the two programs remain harmonized.
• Manufacturers may ask EPA to submit Model Year 2018-2020 data to NHTSA.
4. How do I know if my company qualifies as a small business?
• Regulated trailer manufacturers will be considered small businesses for purposes of Phase
2 if their employee counts for the past three years, as described at 13 CFR 121.106, is
below 1,000, including employees of affiliated companies. Affiliations are described at 13
CFR 121.103.
• EPA and NHTSA apply this small business criterion based on the North American
Industry Classification System (NAICS) code 336212. We will update the program as
appropriate based on the latest published threshold at 13 CFR 121.201. This threshold
applies even if a business is registered under a different NAICS industry code.
Reg u lated Tra i I er Types
5. What types of trailers are regulated?
• Long-box dry vans (greater than 50.0-feet in length)
• Long-box refrigerated vans (greater than 50.0-feet in length)
• Short-box dry vans (50.0 feet and shorter in length)
• Short-box refrigerated vans (50.0 feet and shorter in length)
• Tank trailers designed to transport liquids or gases
• Flatbed trailers with continuous, flat platforms
• Container chassis (all lengths)
• See 40 CFR 1037.107, 1037.230(a)(3), and 1037.801
6. Which trailers are excluded?
• Trailers built before January 1, 2018
• Trailers pulled exclusively by pintle hook or hitch; not designed to be pulled by Class 7
or 8 tractors
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• Non-box trailers that do not meet the definition of flatbed trailers, tank trailers or
container chassis
• Trailers with four or more axles, and trailers less than 35-feet with three axles
• Trailers intended for temporary or permanent residence, office space or other work space
• Trailers with a gap of 120 inches between adjacent axle centerlines
• See 40 CFR 1037.5
7. Do I have to contact EPA if I produce excluded trailers?
• Trailers that meet our definitions of excluded vehicles have no regulatory requirements;
you do not have to contact EPA if you are a manufacturer producing only excluded trailers.
• You may contact EPA if you are unsure if your trailer is excluded. See Question 37.
8. Are imports from Canada and other countries regulated?
• A trailer is subject to EPA/NHTSA regulation when it is sold, offered for sale, or
introduced or delivered into commerce in the United States or imported into the
United States.
• Manufacturers based outside of the US must certify trailers that will be imported or
introduced into commerce in the US.
• Only importers registered with NHTSA may import trailers.
9. When should trailer manufacturers contact EPA to discuss certification?
• Manufacturers are welcome to register with EPA anytime. See Question 11.
• After you have registered with EPA, you will receive notice regarding your assigned
compliance representative.
• After you have been assigned an EPA compliance representative, we recommend
contacting your representative prior to submitting a certification application.
• If you have general questions and you have not yet been assigned a compliance represen-
tative. See Question 37.
10. If small manufacturers take advantage of the 1-year delay, do they have to do anything
before 2019?
• Standards for trailers produced by small manufacturers apply on a delayed schedule.
Small businesses do not have to certify trailers produced before January 1, 2019.
• Small manufacturers must notify EPA that they will make use of delayed standards by
submitting a declaration to EPA before introducing trailers into US commerce in 2018.
• Declarations should describe how the company meets the employee threshold described
in Question 4.
• Trailers excluded under the small business flexibility must include a label with the
following statement: "THIS VEHICLE IS EXCLUDED UNDER 40 CFR 1037.150(c)."
11. How do I register with EPA for certification?
• Company registration
o As part of registration, trailer manufacturers must electronically register for a
unique manufacturer code.
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• All NHTSA guidance is available through their Public Information Center:
http://www.nhtsa.gov/CAFE_PIC/CAFE_PIC_Home.htm
Trailer Types, Technology Options, and Measuring Trailer Performance
16. Can I still use my old trailer? Do I have to add technologies to my old trailer?
• These standards only apply to new trailers. There are no requirements for owners or
operators to retire or retrofit trailers.
17. Do new trailers need specific technologies to meet the standards?
• Maybe, it depends on what type of trailer it is.
• Non-box trailer standards for flatbed trailers, tank trailers and container chassis and
standards for box vans designated as "non-aero" are design standards that require trailer
manufacturers to install a certain level of lower rolling resistance tires and a tire pressure
system (either TPMS or ATIS).
o The design standards do not require the use of any specific make or model of
technology.
• Box van standards (other than "non-aero") are performance-based standards. Manufactur-
ers can meet the overall trailer performance requirements with any combination of tech-
nologies, including the use of aerodynamic improvements, lower rolling resistance tires,
tire pressure systems (ATIS or TPMS) weight reduction, or other "off-cycle technology."
See Question 29. Manufacturers have several options of technologies that can help them
meet the performance standards for a given model year:
o The performance standards do not require the use of any specific technology
type, make, or model Manufacturers must demonstrate that the trailer meets the
performance standard.
18. Does the end-user have to install the same LRR tires when they need replacement?
• Trailer manufacturers must include sufficient rolling resistance information in their
maintenance instructions to allow end-users to purchase replacement tires that meet the
appropriate performance specifications.
• End-users can replace tires with tires of a different make or model as long as their rolling
resistance performance is equivalent to or better than the original tires' performance.
19. Must trailer manufacturers perform testing?
• Performance-based standards apply as described in Question 17, but the agencies designed
the trailer program to limit the amount of testing needed.
• Manufacturers can install tire pressure systems (ATIS or TPMS) or lightweight compo-
nents with pre-determined performance values (no testing needed).
• They can also obtain tire rolling resistance performance data directly from tire manufacturers.
• Aerodynamic device manufacturers may conduct testing and submit their test data to
EPA for pre-approval, for trailer manufacturers to use for certification.
• Manufacturers have the option to measure the performance of their tires, aerodynamic
improvements, or lightweight components, but we expect them to be able to certify their
trailers without performing their own tests.
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• Delta CdA values calculated from SmartWay's coastdown results do not have to be
wind-averaged values. Simply calculate delta CdA using the near-zero yaw results from
the coastdown test of the baseline and improved aero configurations (delta CdA = CdA_
base - CdA_improve).
23. Do device manufacturers have to submit data to both Smart Way and the Phase 2 program?
• Device manufacturers may continue to seek SmartWay verification without submitting
pre-approval requests for devices to be used for Phase 2 certification.
• Device manufacturers may test their devices using the Phase 2 test procedures and sub-
mit their pre-approval requests directly to EPA's compliance program for pre-approval
without pursuing SmartWay verification.
• However, trailer manufacturers cannot directly apply SmartWay data for certification.
Trailer manufacturers will have to obtain delta CdA data from another source (their own
or third-party testing) to use the device on their trailers to meet the standards.
24. Can a trailer be certified for Phase 2 without using any aerodynamic technologies?
• This is potentially true, as long as the trailer has sufficient other technologies to meet the
EPA GHG and NHTSA fuel consumption standards.
25. If a trailer is certified for Phase 2 using no aerodynamic technologies, is it possible for
this trailer to be verified under SmartWay?
• SmartWay Verification is for trailer aerodynamic devices and low rolling resistance tires.
A SmartWay Designated Trailer uses one or more SmartWay verified devices to achieve
a fuel savings benefit. Therefore, a trailer that is certified to GHG Phase 2 without using
any aerodynamic technologies cannot be considered a SmartWay Designated Trailer.
26. Are there approved software packages for CFD testing?
• There are specifications for software that can be found in 40 CFR 1037.532. A manufac-
turer may also check with its certification representative before purchasing CFD software.
27. What is the purpose of attestation by device manufacturers?
• Component manufacturers are responsible for emission test results provided to EPA or
certifying vehicle manufacturers for the purpose of certification (see 40 CFR 1037.620).
• If a component manufacturer attests to the validity of its performance data, it is respon-
sible for the performance of its component.
• As an example, EPA will not accept a delta CdA value from an aerodynamic device
manufacturer without an attestation.
• Component manufacturers may contractually agree to process emission warranty claims
on behalf of the certifying manufacturer.
28. What if trailer manufacturers believe their trailer technologies will perform better than
as measured by others?
• Trailer manufacturers always have the option to perform their own testing.
They must do testing if the data aren't otherwise available.
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29. Which trailer technologies can be tested using off-cycle provisions?
• Off-cycle provisions are available for trailers subject to performance standards if a tech-
nology is expected to reduce C02 emissions, but its performance is not captured in the
trailer compliance equation.
• Manufacturers can evaluate lightweight components by comparing the weight of a light-
weight trailer to a baseline trailer, as in 40 CFR 1037.515(e)(1).
• Additional examples of off-cycle technology include the use of solar power or regenera-
tive braking.
• Manufacturers are encouraged to contact EPA prior to testing off-cycle technologies.
Labeling
30. Does my regulated trailer need a label?
• Yes, all regulated trailers are required to have a permanent label indicating that they are
certified vehicles.
• See 40 CFR 1037.135 and Appendix III to Part 1037.
31. Does the label need to be in a specific location on the trailer?
• We do not specify a location for the label, but it must be easily visible for inspection.
32. Do I have to create a separate label or can I place emissions information on my current
label?
• We do not require emissions information be on a stand-alone label
• The information required by 40 CFR 1037.135 can be added to an existing label as long
as it meets the durability requirements outlined in 40 CFR 1068.45.
33. What information must be included on the label? Must it list all devices used on the
trailer? Must it include compliance equation results?
• Specific requirements for the label are outlined in 40 CFR 1037.135.
• The label must list the components installed on the trailer for compliance with the
standards: For every trailer where any of the technologies listed in Appendix III to Part
1037 are used to demonstrate compliance during certification of that configuration, the
Emission Control Identifier must be listed on the label.
• If a manufacturer uses technologies from Appendix III but does not rely on that technology
to demonstrate compliance, that technology does not need to be included on the label.
• Many weight reduction components and off-cycle technologies are not listed in
Appendix III and therefore are not required to be listed on the label.
• The label does not include compliance equation results.
34. Do I need to affix a label on excluded trailers?
• No label is required for trailers excluded under 40 CFR 1037.5.
• MY 2018 trailers excluded as part of the small business flexibility outlined in 40 CFR
1037.150(c) must have a label with the following statement: "THIS VEHICLE IS
EXCLUDED UNDER 40 CFR 1037.150(c)."
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35. Do I need to affix a label on trailers exempted using the transitional allowance for
MYs 2018-2026?
• Yes, trailers exempt under the transitional allowance provision outlined in 40 CFR
1037.150(v) must include a permanent label that meets the requirements of 40 CFR
1068.45(a), the corporate name of the trailer manufacturer, and a statement that the
trailer is exempt under 40 CFR 1037.150.
36. Do we need a label for trailers built for export?
• Labels are required for trailers that will be exported, but the labels can be removable
(see 40 CFR 1068.230).
Other Resources
37. How can I get more information?
• For further information about complying with the trailer regulations, please contact
OTAQ's Compliance Division at:
U.S. Environmental Protection Agency
Office of Transportation and Air Quality
2000 Traverwood Drive
Ann Arbor, MI 48105
E-mail: ComplianceInfo@epa.gov
• You may also access rulemaking documents and related material on the following
web pages:
o EPA's Phase 2 Rule web page:
https://www.epa.gov/regulations-emissions-vehicles-and-engines/regulations-
greenhouse-gas-emissions-commercial-trucks
o Slides from the November 16, 2016 Trailer Workshop:
https://www.epa.gov/sites/production/files/2016-12/documents/phase2-hd-ghg-
fuel-trailer-workshop-11-16-2016.pdf
o Phase 2 Rule Docket (EPA-HQ-OAR-2014-0827):
www. regulations. gov;
https://www.regulations.gov/searchResults ?rpp=25&po=0&s=EPA-HQ-OAR-
2014-082 7&fp=true&ns=true
o Federal Register (81 FR 73478):
www. feder alregister. gov;
https://www.gpo.gov/fdsys/pkg/FR-2016-10-25/pdf/2016-21203.pdf
o Code of Federal Regulations: Heavy-Duty Vehicles (40 CFR 1037):
www.ecfr.gov;
http://www.ecfr.gov/cgi-bin/text-idx?SID=391al5fbble6517d53ad4bf07a519901
Sutlc=true Stnode=p t40.36.103 7&r gn=di v5
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