EPA Certification on Boats Imported to the US

[Sand crab]

I was checking on this because I know this can be an issue with some boats. From what I can find it seems that all boats made prior to 2009 are exempt because there were no rules in place before then. Possibly boats refitted with newer engines may have issues. Is this how it works? And if you have anything else to add feel free.

[Dsanduril]

It depends on the size of the engine (and whether diesel or gas) there’s a table at the back of EPA Form 3520-21.

Smaller engines go back to 1999/2000, larger 2006/2007.

[Sand crab]

Thanks for the link. My brief look at another webpage had me thinking it was 2009. So, has anyone on the forum done this? I see that current engines have many certifications and wonder about this from 20 years ago? Did the engines from boats built in Europe, South Africa, Oz, etc have the necessary EPA docs? Or were they different non-complying engines?

[billknny]

It's really complex.

There are new engines today that are not "fully certified" that CAN be used to replace an older engine, but not as a new install or to replace a newer "fully certified" engine.

There are engines that can be imported into the USA for one purpose, but not another.

I do not know of issues with importing a used boat, no matter what its engine status (but others might have more up to date info on this!). A new boat's engine would need to meet current standards.

Are you asking for general knowledge, or is there a specific situation you are dealing with?

[Montanan]

Originally Posted by Sand crab

Thanks for the link. My brief look at another webpage had me thinking it was 2009. So, has anyone on the forum done this? I see that current engines have many certifications and wonder about this from 20 years ago? Did the engines from boats built in Europe, South Africa, Oz, etc have the necessary EPA docs? Presumably Yes if they were legally imported to be sold in the USA they would have a registered certificate of conformity, and / or if they had been brought into compliance due to defect or recall non-compliance issues, or by post production modification to compliance. Or were they different non-complying engines? Some boats where non-compliant to USA standards. There was an evolution of Tiers of emissions standards and specific dates of effectiveness of each Tier.

Answers in red above.

Every compression engine and its many configurations are unique as to whether it was certified to EPA standards. One has to look at each individual vehicle or vessel, not just the make and model.

With CI engines one also has the issue of the

The EPA has established the Engines and Vehicles Compliance Information System (EV-CIS), formerly the Verify System, as the EPA's compliance information system

http://https://www.epa.gov/regulatio...ne-compression

EPA has adopted exhaust emission standards for marine diesel engines installed in a variety of marine vessels ranging in size and application from small recreational vessels to tugboats and large ocean-going vessels.

These domestic emission standards apply for engines installed on U.S. vessels.

Additional international requirements may apply for engines installed on U.S. vessels that operate in foreign ports and waters and for foreign vessels.

[Dsanduril]

FWIW, our 1999 boat was re-powered in Italy in 2012/2013. We then bought her in NZ in 2016 and imported her last year. From what I could tell in my own research, Volvo and Yanmar seem (trust but verify) to have EPA certification on all of their engines regardless of where sold. This may be, in part, because there are other countries that use the EPA certification so they don’t have to write their own regulations and do their own testing. I only really looked at those two brands because they were what powered 99% of the boats we considered. Don’t know about the Betas/Nannis/Kubotas/Westerbekes/etc. that power lots of other boats.

The boat we bought had Perkins/Volvos that were certified compliant. They were then recalled over emissions, initially only in the US, but then in China, India, and a few other places. Because we were a US boat Volvo replaced the engines last year.

The importation process itself was quite easy. CBP has a couple of pieces of paperwork they require, plus the EPA form. The only thing they looked at, on the whole boat, was the sticker on the engines. The rest was just paperwork and $.

[Edit] one caution, the Volvo recall was for D1, D2, (and D3?) series engines from ~2007 to ~2016. These engines have an EPA sticker but the certification was withdrawn. The recall is ended and Volvo will no longer replace the engines. So, at least technically, there is a fleet of Volvo powered boats out there that appear compliant but likely aren’t.

[Montanan]

As to rebuilding and maintenance of your older engines, reference: https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100U8YL.pdf How to Maintain or Rebuild Engines
Certified to EPA Standards

[Sand crab]

Thanks everyone. My interest is general in nature. Is the EPA sticker a new thing or were they there on the engine 15 years ago even if the boat with engine originated outside the US?

[Dsanduril]

I know labeling requirements were in place for off-road compression ignition engines under 37kW (~50HP) as far back as 1999. Don’t know if they labeling requirement precedes that, and haven’t looked at larger engine requirements.

https://www.epa.gov/sites/production...selengines.pdf

Whether or not an individual company applied them to engines sold outside the US is very variable. Companies that want a nearly global product comply with EPA and CE, others may have non-global model variants.