Frequently Asked Questions from
Marine Engine Owners and Rebuilders
about EPA's Marine Remanufacture
Program
The U.S. Environmental Protection Agency (EPA) has adopted a new
emission control program for marine diesel engines that, for the first
time, includes emission standards for certain engines already in operation.
This information sheet answers questions about the Marine Remanufac-
ture Program from owners and rebuilders.
Why did EPA adopt the Marine Remanufacture Program?
Marine diesel engines are significant contributors to ambient levels of ozone and
particulate matter (PM) pollution in our nation's ports and along our rivers and coastal
waterways. EPA's emission standards for new engines will result in substantial reduc-
tions of nitrogen oxides (NOX) and PM emissions from marine vessels. Engines built
before the new-engine standards went into effect, however, will continue operating with
higher emissions for a long time. Like locomotives, the service life of many of these
engines can be 30 years or more. The Marine Remanufacture Program provides air
quality benefits by reducing PM emissions from this legacy fleet sooner than would be
the case through the normal turnover of the fleet to vessels with new engines.
Who should read this fact sheet?
You should read this fact sheet if you own a propulsion or auxiliary commercial marine
diesel engine with power at or above 600 kW, manufactured in 1973 or later. You
should also read this fact sheet if you are in the business of rebuilding or maintaining
such marine diesel engines.
a
United States
Environmental Protection
^1 *mAgency
Office of Transportation and Air Quality
EPA-420-F-22-014
March 2022
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What engines are covered by the Marine Remanufacture Program?
Your marine diesel engine is covered by the Marine Remanufacture Program if it meets all of the
following criteria:
1. It is a commercial marine diesel engine
2. It was manufactured between 1973 and the last Tier 2 model year.1 (footnotes)
3. It has power at or above 600 kilowatts (kW).2 (footnotes)
4. It has a displacement of less than 30 liters per cylinder.3 (footnotes)
5. It is installed on a vessel that is flagged or registered in the United States.
I have a covered engine, what must I do?
Essentially, if your commercial marine diesel engine is covered by the Marine Remanufacture
Program, you are required to use a certified remanufacture system when you remanufacture your
engine, if one is available. These terms and criteria are described in more detail below. The deci-
sion tree set out in Figure 1 will help you determine if you have to do something under the Marine
Remanufacture Program. Further information about each of the steps in the decision tree, as well
as other related information, is provided in the remainder of this information sheet.
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Figure 1: Remanufacturing Decision Tree
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Is my commercial diesel engine > 600 kW,
disp. < 30 L/cylinder and
on a U.S. flagged vessel?
Am I replacing or requalifying all cylinder
liners (either during a single maintenance
event or over a period less than 5 years)?
r-
Is there a certified remanufacturing
System ("kit") for my engine? To
Determine this, contact the engine OEM
And visit the EPA's web site at: This Link
YES
You must remanufacture your
engine using a certified kit,
unless one is not "available" or
you have obtained an exemption
as explained in this information sheet
Stop. Your engine is
not covered by this
program.
You are not remanufacturing.
Keep maintenance records
And review this step again at
Your next maintenance event.
Continue to comply with
40CFR Part 1042, as applicable
regarding engine rebuilds.
If there is no certified kit for your engine,
you may remanufacture without a kit for
this maintenance event. Continue to
comply with Part 1042, as applicable,
regarding engine rebuilds. Review this
step again at your next maintenance
event.
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Which scheduled maintenance activities does EPA consider to be
remanufacturing?
Remanufacturing, for the purposes of this program, is the removal and replacement - including
requalifying - of all cylinder liners, either all in a single maintenance event or over a period of five
(5) years or less. If your cylinder replacement/requalifying schedule takes longer than five years,
EPA does not consider this to be remanufacturing under this rule. As used here, "requalifying"
means to remove and inspect a cylinder liner to make sure it is qualified for continued use.
Even though an engine may be "remanufactured" during a rebuild event, not all rebuild events and
not all maintenance events are considered to be remanufacturing. A rebuild may include extensive
maintenance that increases the service life of the engine. However it will not be considered to be
remanufacturing unless all of the cylinder liners are replaced, either at once or over a period of
5 years.
What is a remanufacture system and how do I know if one has been
certified for my engine?
A remanufacture system, commonly referred to as a "remanufacture kit," is a process for making
an engine meet certain emission criteria - in this case, a 25 percent reduction in PM emissions.
The kit may consist of instructions, specifications, limitations and/or engine components. In most
cases, a kit is expected to consist of "better" versions of parts normally replaced at rebuild and
should not adversely affect engine reliability, durability, or power. For example, a kit could include
different fuel injectors or different piston rings to reduce oil consumption. However, in some cases
it may consist of only instructions for tuning the engine or calibrating adjustable features. If there
are several remanufacture systems certified for your engine, you may choose among them.
In addition to engine-based kits, EPA will allow certification of fuel-based kits. These would consist
of a process of reducing the PM emissions by changing fuel or using a fuel additive. However, owners
of engines covered by fuel-based kits are not required to use them. Instead, they may be used as an
alternative to the use of certified engine-based kits.
EPA maintains a list of certified remanufacture systems for marine diesel engines.
Visit EPA's web site to see if a kit has been certified for your engine model.
When is a certified remanufacture kit considered available?
Most of the remanufacture kits certified today have been designated as available. The first time a
new kit is introduced to the US market, it would generally be considered to be available 120 days
after it is certified. When you visit EPA's web site you will see both the certificate issuance date and
the date of availability.
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There are two other important criteria that determine if a kit is available for your engine. First, you
must be able to obtain the kit in a timely manner according to normal remanufacturing practices.
For example, a kit would not generally be considered to be available if you would need to remove
the engine from your vessel and send it to a factory to be remanufactured. Second, the kit must
not be too costly, in terms of dollars spent for each ton of PM reduced. EPA considers a kit to be
too costly if it exceeds a marginal cost threshold of $45,000 per ton of PM reduction. The mar-
ginal cost of a kit is the added cost of using the kit over and above the cost of remanufacturing the
engine conventionally, divided by the total amount of PM reductions expected over the useful life
of the remanufactured engine.
Kits may be certified if they exceed the cost limit; however they will not be designated as available.
If you think a kit that EPA has designated as available for your engine is not feasible either for cost
reasons or because it is difficult to obtain and install in a timely manner consistent with normal
procedures, you should contact EPA.
When must I use a kit if I'm doing a rolling rebuild?
A rolling rebuild typically refers to the practice of replacing and upgrading parts incrementally over
many years. If you are doing a rolling rebuild and your schedule includes replacing/requalifying all
your cylinder liners over five years or less, you are remanufacturing your engine according to this
program. In the case of a rolling rebuild, the clock that determines your deadline for complying
with the rule starts on the date when the first set of cylinder liners is replaced, after a kit is avail-
able. This compliance clock stops on the date of replacement of the last set of cylinder liners that
completes the remanufacturing, even if this is less than five years from when the clock started.
If the components of your kit are compatible with your engine's current configuration, you may
install them incrementally at your discretion. However, the latest a certified remanufacture kit must
be applied to your engine is when the last set of cylinder liners is replaced, as determined from the
clock start date described above.
What are my obligations if a kit is not available today?
If a certified remanufacture kit is not available for your engine, you must continue to comply with
the otherwise applicable engine rebuilding requirements in 40 CFR Part 1042 when you rebuild
your Category 1 or Category 2 marine engine.
Also, before you schedule your next cylinder liner replacements, you should check EPA's web site
to see if a kit has become available for your engine.
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I want to certify a marine remanufacture kit. How can I do this?
Anyone can certify a marine remanufacture kit, by applying to EPA for certification. If you have
not registered with EPA as a manufacturer, you will need to set up an account. You must submit
test results showing that the kit will reduce PM emissions as required by the rule. Your application
must also show whether owners may obtain and install the remanufacturing kit in a timely manner
for a total cost that is less than $45,000 per ton of PM reduced. The details on submitting
an application can be found at 40 CFR Part 1042, Subparts C and I, as well as EPA's web page
with instructions for certifying marine diesel engines. You should contact EPA with any questions
on your application.
Due to similarities between the Marine Remanufacture Program and the Locomotive Engine
Remanufacture Program, we have a streamlined process to allow locomotive kits to be certified for
use with marine engines. You should contact EPA if you think your kit qualifies for this process.
What exemptions apply for special situations?
Revenue-Based Deferral:
You do not have to use a certified kit when you remanufacture your engine, if you can show that
your gross annual sales revenue (including all revenues from any parent company and its subsidiaries)
was less than $5 million in 2008 dollars4 (footnotes), during the calendar year prior to the remanu-
facture event (or the compliance date in the case of a rolling rebuild). Although you do not need to
apply to EPA to receive this deferral, you should keep records of your calculations for each year that
you qualify.
Hardship Exemptions:
There are two ways to qualify for a hardship exemption under this program. You must apply to
EPA for either of them.
• EPA may approve an exemption if you demonstrate that circumstances out of your control
prevent you from meeting all the requirements of this rule. You must submit a compliance
plan, explaining how much more time you need to comply.
EPA may approve an exemption if you can show that a remanufacture kit is not "available"
for your vessel (see"When is a certified remanufacture kit considered available?," (above).
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Where can I get more information?
You can review the regulation online using the electronic Code of Federal Regulations to browse
40 CFR 1042 Subpart I.
You can also review supporting documents related to this rule by visiting EPA's web page for
Domestic Regulations for Emissions from Marine Compression Ignition Engines.
You can also contact us at:
U.S. Environmental Protection Agency
Office of Transportation and Air Quality
Compliance Division
2000 Traverwood Dr.
Ann Arbor, MI 48105
E-mail: complianceinfo@epa.gov
Web: Contact Us
1 Depending on engine size, this could be 2008, 2011, 2012, or 2013. Information about the standards to
which an engine is certified is located on the engine label. For help identifying your engine's tier, contact
the engine manufacturer or EPA.
2 This is roughly equivalent to 800 horsepower (hp). This information is also on the engine label.
3 This program does not apply to Category 3 marine engines. There is a separate existing program for Cat-
egory 3 marine diesel engines; you may contact EPA for more information about that program.
4 Visit the Bureau of Pabor Statistics web page for the Producer Price Index to calculate the equivalent 2008
dollars for another year.
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