SKYTEAM

[MJH]

http://www.epa.gov/otaq/regs/roadbike/3-steps-hmc-certdoc.pdf

Certification and Compliance Guidance

• Guidance Documents and References for 2006 and Later Model Year Highway Motorcycles (HMC) Certification and Compliance Program

[MJH]

Thank you for contacting EPA. While you are waiting for our responses,
please read the following highlight which will assist you in your
certification and compliance process.

The highlight is intended only for manufacturers/importers wishing to
sell new motorcycles and ATVs in the United States.

For small/large spark ignition engine (that are not used for motorcycles
and ATVs) and snowmobile certification, please contact Mr. Mike Wolfe
(Wolfe.Michael@epa.gov or 202-343-9539); for marine spark ignition
engine certification, please contact Nydia Reyes Morales (202-343-9264).
Those certification programs are managed by another group of this Office
located in Washington D.C.

Motorcycles/ATVs Certification Highlight

1. Applicable Regulations

Motorcycles and ATVs must demonstrate compliance with emission standards
and requirements set forth in the following listed regulations:
- For highway motorcycles: 40 CFR Part 86, Subpart F and E
- For off-road (off-highway) motorcycles and ATVs: 40 CFR Parts
1051, 1065 and 1068

The regulations are accessible online


2. Certification Guidance:

EPA certificates are required in order to sell motorcycles/ATVs in the
United States. Under the motorcycle and ATV programs, EPA issues
certificates to U.S. Manufacturers/U.S. importers only. New certificate
(s) must be applied for each model year. The process of obtaining a
certificate for a new manufacturer is complex and we strongly urge any
new manufacturers wishing to obtain an EPA certificate of conformity to
read and understand the regulations and our step-by-step guidance posted
online at:
- for on-road (highway) motorcycles: www.epa.gov/otaq/roadbikes.htm
- for off-road (off-highway) motorcycles and ATVs:
www.epa.gov/otaq/recveh.htm

Motorcycles and ATVs indented to be sold in California must comply with
the emission requirements in California. If your sale occurs in
California only, an Executive Order (EO) issued by the California Air
Resources Board (CARB) must be obtained prior to EPA certification.
Further information on obtaining the EO from CARB may be obtained by
contacting Mr. Duc Nguyen at: dnguyen@arb.ca.gov

3. General Process
A new U.S. manufacturer/U.S. importer must send a Letter of Intent by
following the instructions in the above mentioned guidance to
MC-cert@epa.gov. After receiving a response from EPA, a qualifying U.S.
manufacturer/U.S. importer then may fill out a form to apply for your
manufacturer Code ID and register to use EPA’s interactive online
computer system named VERIFY. Applications are submitted online via
website www.epa.gov/CDX .

In order to obtain a Certificate of Conformity in time, a completed
application, including both application documentation and Certification
Information Summary (CSI) Data that meet EPA requirements, must be
submitted electronically online to EPA Two separate application
documentations may be submitted; one labeled CBI (confidential business
information) which may contain sales projections, catalyst loading
details and other information which is manufacturer proprietary
information, and one labeled FOI which contains information releasable
to the public under the Freedom of Information Act (FOIA). If there is
no confidential information, only the FOI version need be submitted. All
certificates are sent electronically to a manufacturer designated e-mail
address. It is a manufacturer’s responsibility to keep the email
up-to-date in your VERIFY user account.

Manufacturers may anticipate that EPA will conduct auditing testing on
your certifying motorcycles/ATVs at an EPA specified emission testing
laboratory.

4. Certification Fees

EPA requires a certification fee for each certificate (40 CFR Subpart Y,
85.2408(c)) in advance of any EPA services related to certification
activities. In general, EPA will accept and begin work on an application
only after the fee is received. Manufacturers are advised to plan
approximately two weeks for the EPA to receive the fee and log the
payment into our database. Proper and timely fee payments will minimize
the time necessary to process an application.

The fee for each certificate will change each year as it is adjusted for
inflation and to reflect changes in the numbers of certificate issued.
All information necessary for submitting the required fees is located
at: www.epa.gov/otaq/fees.htm.

5. Importation Issues
Motorcycles/ATVs importation issues are handled by the EPA Imports Team.
Please contact them via imports@epa.gov.


Motorcycle/ATV Certification Team
Office of Transportation and Air Quality
U.S. EPA
2000 Traverwood Drive
Ann Arbor, MI

[MJH]

Many paths lead to one destination, not all paths are the same and not all paths carry the same tolls, choose your guide wisely?

[MJH]

If you are an OEM and have formal operations in the USA you do not necessarily have to pay for EPA testing. If you are an ICI you will if you do not have a contractual agreement with an OEM and that would be related to whether that OEM does or does not have its own testing facility/capability. Basically it is not cut and dried, the path you take is a matter of who you are and how capable you are as in how much real and actual knowledge and or ability you possess.

The EPA offers all the information needed….it is not exhaustive, it is actually comprehensive, but in that it requires comprehension.

I am here to offer both comprehension and also some composition, the attempt is to express it to any that may have an interest.

If you do not have the ability and or knowledge….you then have to pay for it, obviously.

[MJH]

This is the question sent to the EPA:
I am researching the EPA compliance procedure for Imported motorcycles. Specifically my question is about testing, does the testing for compliance have to be done by the EPA or can a manufacturer test and submit an application for a certificate based on its own testing.

This is the response I received from the EPA:
Testing of motor vehicle is done by the manufacturers. For manufacturers that do not have a recognized testing facility they will need to contract out the testing to be done by an independent recognized testing facility. If a vehicle is being imported for testing then the importer will need to apply for a Testing exemption from EPA.

David C. Hurlin
EPA Imports Line
Exemptions & Exclusions
Managed by URS, Federal Services
(734) 214-4100

[culcune]

MJH, I think that that is what got some manufacturers in trouble a few years ago--I think they were testing their own bikes which, of course 'passed' and later did not pass muster from the EPA.

[MJH]

Then they made false claims. It is a faith based systems that can be audited when fraud is suspect the EPA will show up unannounced, they will take a sample, then it better be what what it was claimed to be on the application to the EPA and perform under testing within the levels claimed on that application.

[culcune]

I don't recall the company, but it might have been Roketa (don't quote me) or the factory that claims to be Roketa in China (I know now they are more of a distributor vs. a 'manufacturer') Do you recall anything along this line?

[MJH]

I don't recall the company, but it might have been Roketa (don't quote me) or the factory that claims to be Roketa in China (I know now they are more of a distributor vs. a 'manufacturer') Do you recall anything along this line?

Nope only the Petboys incident and a case in 2004 which was a BMW dealer altering stock and selling those altered bikes.

[culcune]

Nope only the Petboys incident and a case in 2004 which was a BMW dealer altering stock and selling those altered bikes.

Yes, that is correct, and I remember reading the article--Baja was the 'brand' name sold through Pepboys stores. Sorry Roketa.....