EPA form importing 12ht (1 Viewer)

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Hey guys

Looking for some fast info

Importing a 12HT and h55 (engine and trans only) from the Netherlands ...

I’m filling in the US EPA form and want to make sure I tick (literally) all the correct boxes.

Has anyone done this before?

The form isn’t clear. The definition on the decision flow chart seems to classify the diesel under a “marine, locomotive, or other land-based nonroad” vehicle as it is not a “spark-ignition engine”
So would it be box “B” for locomotive engines, or something else?

The other options on the EPA form 3520-21 would make me think it would be classified as an “ancient engine”. Would that be a correct assumption?

Thanks — hoping someone can shed some light on this form
 
You should be asking your customs broker. Notice the last sentence of the top paragraph on form 3520-21. I tried to copy and paste it here but having technical difficulties. Don't use 3520-21. Use 3520-1 which is for both vehicles and regular vehicle engines.
 
Last edited:
You should be asking your customs broker. Notice the last sentence of the top paragraph on form 3520-21. I tried to copy and paste it here but having technical difficulties. Don't use 3520-21. Use 3520-1 which is for both vehicles and regular vehicle engines.

Thank you Steve!
 
looking at the EPA website this seems to be the relevant section to me

3.2 Engines Not in a Vehicle or Chassis
EPA regulates the entire vehicle, not individual parts, for cars, light trucks, medium duty passenger vehicles (MDPVs), chassis-certified HDVs, and motorcycles. If an engine is not installed, and is to be used in a car, motorcycle, or light truck, it may be imported as an automotive part. Anyone may import a non-chassis-mounted light-duty engine for use in a motor vehicle which is currently covered by an EPA certificate or will be covered by an EPA certificate prior to introduction into commerce. No approval or Customs bond is required by EPA. However, importers should be aware that several engine uses are violations of the Clean Air Act:
● Mounting an engine to a chassis to "manufacture" a vehicle without proper certification of conformity from EPA;
● Mounting a non-identical engine to a certified vehicle; and
● Importing an engine for use in an engine-certified heavy-duty vehicle or heavy-duty truck without a proper label indicating that it is covered under a certificate of conformity, or was built prior to 1970, or is otherwise excluded or exempted.

To import an engine for use in a car, light truck, MDPV, chassis-certified HDV, or motorcycle, the importer must file with Customs, upon entry, an EPA Form 3520-1 and declare code "W" on the form

the full document is at https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100AKFO.pdf

So it looks like you can import the engine easily enough but as soon as you put it in something ("Mounting a non-identical engine to a certified vehicle") then you've violated the Clean Air Act.
 

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