Amaurer makes some really good points. You should be totally fine as far as FMVSS requirements since the federal 25 year exemption is clearly written into the California statute, so the DMV is probably after you for emissions. Looking at the link you posted to the law regarding Direct Import Vehicles, the DMV wants to see:
But, even though California has stricter emissions standards than the EPA, this statute says evidence of compliance with U.S. EPA AND / OR California emission standards is sufficient. Well, under EPA standards, if it's over 21 years old and still has the original unmodified engine it's exempt. Do you have EPA form 3520-1 with Code E marked? If not, you should be able to go to your local port of entry and get it stamped. This should be sufficient evidence of compliance with U.S. EPA emissions standards.
Of course the California DMV might argue that being exempt is not the same as being in compliance, and they might point out that while the 25 year exemption to FMVSS is clearly in the California statute, the 21 year EPA exemption is clearly not in the California statute. But I think it's your best shot.
Evidence of compliance with U.S. EPA and/or California emission standards. Any of the following are acceptable:
You don't have the emissions label; the licensed labs can't or won't test diesel vehicles (from what I read earlier in this thread); and the manufacturer is not going to give you a letter. - A U.S. EPA and/or California emission label affixed to the vehicle.
- A Certificate of Conformance issued by a laboratory licensed by the ARB. No smog certification is required if this document is submitted for original registration.
- A letter from the manufacturer stating the vehicle complies with U.S. FMVSS and U.S. Emissions requirements (usually only attainable for Canadian vehicles).
But, even though California has stricter emissions standards than the EPA, this statute says evidence of compliance with U.S. EPA AND / OR California emission standards is sufficient. Well, under EPA standards, if it's over 21 years old and still has the original unmodified engine it's exempt. Do you have EPA form 3520-1 with Code E marked? If not, you should be able to go to your local port of entry and get it stamped. This should be sufficient evidence of compliance with U.S. EPA emissions standards.
Of course the California DMV might argue that being exempt is not the same as being in compliance, and they might point out that while the 25 year exemption to FMVSS is clearly in the California statute, the 21 year EPA exemption is clearly not in the California statute. But I think it's your best shot.
