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  #1  
Old April 22nd, 2010, 02:40 PM
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Advise needed : Importing engine

A few years ago I imported a 1981 Land Rover 88''. No problems with customs because of the 25 years rule, excemted from EPA and DOT.

Now after some years the engine is tired and I imported an engine from Europe.

This is at customs now and they won't lett it in because all engines after 1968 need EPA certificate. Ofcourse I don't have this.

I cannot even proof that this engine is 25 years old but they beleved me it is for a 1981 truck. But based on that I can still not get it in the country.

Any advise ?
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  #2  
Old April 22nd, 2010, 05:01 PM
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You have a cutoms officer that doesn't really know the rules. You might need to hire a broker to get it through but it should be allowed. There is a thread on here detailing a similar experience.





Quote:
Originally Posted by johan View Post
A few years ago I imported a 1981 Land Rover 88''. No problems with customs because of the 25 years rule, excemted from EPA and DOT.

Now after some years the engine is tired and I imported an engine from Europe.

This is at customs now and they won't lett it in because all engines after 1968 need EPA certificate. Ofcourse I don't have this.

I cannot even proof that this engine is 25 years old but they beleved me it is for a 1981 truck. But based on that I can still not get it in the country.

Any advise ?
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  #3  
Old April 22nd, 2010, 06:02 PM
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I agree it would appear the officer does not know the rules, I would ask for clarification, I just cleared a recon LT77 on Monday and asked about engines particilarly a 200 TDI being a retrofit and they said no problem.
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  #4  
Old April 22nd, 2010, 08:46 PM
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jim pendleton
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Do you have the engine ID #? Is it a 2.25 gas engine? If it is basically say it is the same engine as a 1971 Land Rover series IIa. Find a workshop manual describing it as the same engine. Or a parts manual. They should have the engine for a 1971 on file.


Quote:
Originally Posted by johan View Post
A few years ago I imported a 1981 Land Rover 88''. No problems with customs because of the 25 years rule, excemted from EPA and DOT.

Now after some years the engine is tired and I imported an engine from Europe.

This is at customs now and they won't lett it in because all engines after 1968 need EPA certificate. Ofcourse I don't have this.

I cannot even proof that this engine is 25 years old but they beleved me it is for a 1981 truck. But based on that I can still not get it in the country.

Any advise ?
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  #5  
Old April 23rd, 2010, 09:06 AM
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Did some research and it looks like if customs follows the rules they are right.

Bringing in an vehicle or an engine for a vehicle you need to declare EPA form 3520-1.
http://www.epa.gov/oms/imports/
http://www.epa.gov/oms/imports/factmtop.htm

This form gives a code E for vehicle at least 21 years old
http://www.epa.gov/oms/imports/forms/3520-1.pdf

For just an engine there is no other code then code W, which obliges EPA certificate.

I am now in contact with the EPA and at least they say I should be able to bring in the engine although the from says different. See what is going to happen now !

Jim, thanks for your tip. I will go that way if I still have problems.
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  #6  
Old April 23rd, 2010, 10:32 AM
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as usual the regs are poorly written thus allowing several interpretations:

for example: (from http://www.epa.gov/oms/imports/quikt...m#nonusversion)

(actually I think you want ot do it as an "E" being over 21 years old, they group vehicles in with engines...sometimes)

4. Non-U.S. version vehicles

A. What is a non-U.S. version vehicle?
B. Exclusions
B. (1) For old vehicles manufactured before the EPA regulations
B. (2) For an engine not installed in a vehicle or chassis
B. (3) For a vehicle not safe or practical to drive on streets and highways
B. (4) For a racing vehicle
B. (5) For a vehicle powered by unregulated fuel

C. Exemptions
C. (1) For situations of extreme hardship
C. (2) For vehicles that are identical to U.S. versions

D. Importations by an independent commercial importer (ICI)

4. Non-U.S. version vehicles

A. What is a non-U.S. version vehicle?

Non-U.S. version vehicles generally are those that are sold in foreign countries. They will not have the U.S. EPA compliance label. Non-U.S. version vehicles may also include U.S. version vehicles that have been modified or altered.
Besides EPA, several other Federal agencies regulate the importation of nonconforming vehicles, including the Department of Transportation, Customs and Internal Revenue Service.
EPA does not recommend the importation of nonconforming vehicles. Conversion of nonconforming vehicles is usually very expensive, and sometimes impossible or impractical.
EPA will permit the importation of a nonconforming vehicle only if it qualifies for an exclusion or an exemption, or is imported by an independent commercial importer (ICI), who is a current holder of a valid EPA certificate of conformity.
B. Exclusions

Excluded vehicles are those vehicles that have been excluded from the emission requirements of the Clean Air Act
B. (1) Manufactured before the EPA Regulations

The following vehicles and engines are excluded because they were manufactured before the EPA emission regulations. These vehicles are now imported under EPA declaration code "E":
Gasoline-fueled car or light truck built before 1968
Diesel-fueled car built before 1975
Diesel-fueled light truck built before 1977
Motorcycle built before 1978
Gasoline- or diesel-fueled engine for heavy duty truck built before 1970
No approval or Customs bond is required by EPA.
The importer must file with U.S. Customs, upon entry, an EPA Form 3520-1 and declare code "E" on that form.
The importer must also prove to Customs, as required, that the vehicle or engine was manufactured prior to EPA regulation. Documents such as a title, or letter from the original manufacturer may be used for this purpose.
Other vehicles or engines 21 years or older may also be imported without modification, using code "E".
B. (2) Engine not in Vehicle or Chassis

EPA regulates the entire vehicle, not individual parts, for cars, light trucks, 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. No approval or Customs bond is required by EPA. Importers should be aware, however, that replacement of an engine in a U.S. version vehicle with an engine of a different type or model year which is not currently covered by an EPA certificate or will be covered by an EPA certificate prior to introduction into commerce may violateEPA regulations.
To import an engine for use in a car, light truck or motorcycle, the importer must file with U.S. Customs, upon entry, an EPA Form 3520-1 and declare code "W" on that form.
For a "heavy" vehicle or "heavy" truck, EPA regulates the engine, whether or not it is installed. EPA considers a vehicle or truck as "heavy" if it has a gross vehicle weight rating of more than 8,500 pounds, or a curb weight of more than 6,000 pounds. To be imported, such an engine must be either excluded, exempted, covered by an EPA certificate of conformity, or imported by an independent commercial importer.


Quote:
Originally Posted by johan View Post
Did some research and it looks like if customs follows the rules they are right.

Bringing in an vehicle or an engine for a vehicle you need to declare EPA form 3520-1.
http://www.epa.gov/oms/imports/
http://www.epa.gov/oms/imports/factmtop.htm

This form gives a code E for vehicle at least 21 years old
http://www.epa.gov/oms/imports/forms/3520-1.pdf

For just an engine there is no other code then code W, which obliges EPA certificate.

I am now in contact with the EPA and at least they say I should be able to bring in the engine although the from says different. See what is going to happen now !

Jim, thanks for your tip. I will go that way if I still have problems.
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  #7  
Old April 23rd, 2010, 12:29 PM
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Indeed very strange.

Section B2 starts with no EPA necessary. But it ends with saying you have to declaring code W at form 3520-1.

Code W on its turn says:
code W - non-chassis-mounted engine to be used in a light-duty vehicle or light-duty truck or motorcycle which is currently covered by an EPA certificate or will be covered by an EPA certificate prior to introdution into commerce



so, it doesn't need EPA but it needs EPA ?????
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  #8  
Old April 29th, 2010, 11:13 AM
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Thanks everyone for your input, I finally picked up the engine yesterday.

After customs refusing to allow the engine entering the country because no EPA certificate I gave them all the information you gave me. Beside that a confirmation from my self that it is for replacing an engine in a EPA excampt vehicle. After this I got the stamp.

Customs didn't inform me why they accepted it the third time and I was to afraid to ask. Just said ''thank you'' paid $ 9,= duties, picked up the engine and tried to get out as soon as possible.

thanks everyone.
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