What this checklist covers
Under the Clean Air Act, new vehicles and engines must be covered by an EPA certificate of conformity before they are introduced into US commerce. Manufacturers group vehicles into test groups or engine families, submit certification data to EPA, and label each vehicle with an emission control information label. EPA publishes certification data that identifies certified vehicles.
The EPA Vehicle Emissions Certification Checklist is a 15-point scorecard for emissions standards, test groups, Certificates of Conformity, EV-CIS records, and introduction into US commerce. Each criterion is scored from 1 to 5 on what the auditor sees on the day, and every gap goes into an action plan with an owner and a close date.
AutoSmart tip: EPA emissions certification is a precondition of legal sale in the US — introduction of a vehicle or engine without a valid Certificate of Conformity for its test group is a violation of the Clean Air Act, subject to civil penalties per vehicle per day of violation. The most common compliance gap is model- year changeover: confirm that the new model year’s certificate is received and valid before the first vehicle of that year is sold.
The checks
Tap Yes, No or Maybe to try it: your answers stay in this page and clear when you refresh. For a detailed walkthrough, download our PDF or book a demo.
Emissions standards and test groups
- Are the applicable EPA emissions standards (Tier 3, Light-Duty Greenhouse Gas, or Heavy- Duty as applicable) identified for every vehicle or engine model year placed on the US market?
- Are vehicles grouped into test groups (formerly engine families) as required by EPA certification regulations, with each test group covered by a valid Certificate of Conformity before any vehicle in that group is sold?
- Is emissions test data on file for each test group — confirming the emission levels demonstrated during EPA certification testing are within the applicable standard for each regulated pollutant?
- Are model year changes and carryover test groups managed correctly — confirming whether a new Certificate of Conformity is required for the new model year or whether a carryover certification is applicable?
Certificate of conformity
- Is a valid EPA Certificate of Conformity held for every test group of vehicles or engines introduced into US commerce, accessible for review if requested by EPA?
- Is the Certificate of Conformity coverage confirmed to include all engine configurations, fuel types, and optional equipment combinations actually offered for sale in the US market?
- Are Certificates of Conformity retained for the period required by EPA regulations, in a format that remains retrievable for the duration of the retention obligation?
- Where a Certificate of Conformity has been amended or superseded, is the current version clearly identified and the prior version archived — preventing a superseded certificate from being relied upon in error?
Ev-cis records and reporting
- Is the EPA's Emissions and Vehicle Information System (ELVIS or equivalent current system) used to submit required certification data, with submissions completed within the required timeframes before introduction into commerce?
- Are annual in-use compliance testing and deterioration factor obligations monitored, with testing completed and results submitted as required by the Certificate of Conformity conditions?
- Are in-use surveillance program obligations (random vehicle selection, testing, and reporting) understood and managed as part of ongoing post-certification compliance?
Market introduction and governance
- Is a process in place to prevent any vehicle from being introduced into US commerce before its test group's Certificate of Conformity is confirmed as valid and in force?
- Are emission control system label requirements (under hood label, VECI) confirmed as correct and affixed to every vehicle before it leaves the manufacturer's or importer's control?
- Is a named person designated as responsible for EPA emissions certification compliance, with authority to halt market introduction if certification documentation is incomplete?
- Are EPA certification obligations reviewed when new engines, powertrain changes, or emissions control system modifications are introduced — confirming whether a new or amended Certificate of Conformity is required before production or importation begins?
How to run it
How the scoring works
Before the visit, fill in the dealer or centre, the auditor, the date and the audit cycle. Then score each of the 15 checks from 1 to 5 on what you see on the day, not on what the site aims for, and add them up out of 75.
- 1Not in place
- 2Attempted
- 3Defined
- 4Managed
- 5Fully sustained
- Green60–75 · 80–100%Compliant. Keep the standard.
- Amber38–59 · 50–79%Improvement needed: a structured action plan within 30 days.
- Red0–37 · Below 50%Priority intervention, escalated to regional management.
Then close every gap
Each gap goes into the action plan tracker and moves through four stages until the auditor closes it.
- 1PendingOwner and close date set
- 2In progressWork under way, evidence gathered
- 3CompletedEvidence submitted for review
- 4ApprovedVerified and closed by the auditor
Questions about this checklist
Who needs a certificate of conformity?
Manufacturers, including importers acting as manufacturers, of new vehicles and engines introduced into US commerce. Check EPA’s guidance for your vehicle category.
Is California different?
California sets its own standards through CARB, and many vehicles need CARB certification as well; see the CARB compliance checklist.
Can dealers use this checklist?
Dealers mostly need the label checks and the rule not to sell modified or uncertified vehicles; the rest is for manufacturers and importers.
