What this checklist covers
Vehicles and engines imported into the United States must meet EPA emission requirements. In most cases that means they are covered by an EPA certificate of conformity and carry the original emission control information label; otherwise they must qualify for an exemption or exclusion, or be imported through an EPA-approved independent commercial importer. Importers declare the basis for entry to US Customs and Border Protection, typically on the EPA declaration form.
The EPA Vehicle Import Compliance Checklist is a 15-point scorecard for EPA import requirements, emissions eligibility, documentation, exemptions, declarations, and import records. 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 vehicle import non-compliance carries significant financial penalties and can result in US Customs refusing entry or requiring export at the importer’s cost. The most common errors occur at the declaration stage — an incorrect compliance basis claimed on EPA Form 3520-1, or a vehicle released from customs before a non-conforming vehicle modification program is completed. Confirm the compliance basis in writing before import, not after the vehicle has entered the country.
The checks
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Import eligibility and classification
- Is each imported vehicle, engine, or piece of nonroad equipment correctly classified under EPA's import rules — distinguishing between light-duty, heavy-duty, recreational, and nonroad categories, each of which carries different compliance requirements?
- Is the vehicle or engine confirmed as either originally certified for the US market (EPA Certificate of Conformity holder is the original manufacturer) or eligible for importation under an applicable exemption or modification program?
- Where a heavy-duty engine is imported separately from the vehicle, are the engine- specific certification and import requirements addressed independently from any vehicle-level certification?
- Are imported recreational vehicles and nonroad engines assessed for compliance with the applicable EPA emission standards for their category and model year before importation?
EPA import declaration and documentation
- Is an EPA Declaration Form (EPA Form 3520-1 or equivalent current form) completed accurately for every imported motor vehicle or engine, declaring the applicable EPA compliance basis?
- Is the EPA Declaration Form submitted to US Customs and Border Protection at the time of entry, not retrospectively after the vehicle or engine has been released from customs?
- Is the basis for the EPA declaration (e.g., 'originally certified for sale in the US', 'non- conforming vehicle imported under an ICI exemption') confirmed by documentary evidence at the time of import?
- Are import declaration records retained for the period required by EPA regulations, retrievable if the EPA or Customs requests documentation to verify the declaration?
Exemptions and special import rules
- Where a vehicle is imported under the 25-year exemption (vehicles manufactured at least 25 years before the date of importation), is the vehicle's manufacture date confirmed by documentary evidence before the exemption is claimed?
- Where a vehicle is imported by an Independent Commercial Importer (ICI) for modification to US standards, is the ICI's EPA certificate on file and the required modifications confirmed as completed before the vehicle is sold?
- Are personal use exemptions (one-time importation for personal use, not for sale) applied only to vehicles that genuinely meet the exemption criteria — with no exemption claimed for vehicles intended for commercial sale?
Import records and governance
- Is a complete import file maintained for every imported vehicle or engine — covering the EPA declaration, customs entry, certification basis, and any exemption documentation — retained for the required period?
- Is a process in place to identify and resolve any EPA import declaration discrepancy before a vehicle is offered for sale — with no vehicle sold under an unresolved import compliance question?
- Is EPA import compliance reviewed as part of the pre-import due diligence for every new sourcing arrangement involving vehicles or engines from non-US markets?
- Is a named person responsible for EPA import compliance, with direct access to import records and authority to halt a sale if the EPA compliance basis for a specific vehicle cannot be confirmed?
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
Does EPA approval cover NHTSA safety requirements too?
No. EPA covers emissions; NHTSA covers safety standards and has its own import rules and forms. Most imports need to satisfy both.
What is an independent commercial importer?
A company holding EPA approval to import and modify nonconforming vehicles so that they meet EPA requirements. Check EPA’s current list and rules before relying on one.
Who keeps the records?
The importer of record. Keep them per VIN so an EPA or customs query can be answered quickly.
