What is needed in the EPA database is a field for testing, that being who submitted the application, that being who actually did the tests. Then as for the other identifiers they should be only propagated from the information that comes through the SAE and subsequently the filings with the NHSTA. That being the required legal disclosure of who actually manufactures it and who is the legal entity distributing it.

So that may require going into the federal regulations and adding a section, I could do that and eventually submit it to congress. Simply explaining that these agencies are at odds and this change would synchronize them.

Before getting an EPA certificate a product must have an assigned WMI and listed in the WMI database.
Then that certificate cannot be issued until that WMI has a VIN decoding document and a statement of the agent of process. That agent of process should also require validation in each state systems respectively. Which is typically a license issued by that states office of Secretary of State.