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Td5 EPA legal?

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19K views 111 replies 47 participants last post by  Beaver87 
#1 ·
There are folks here with a lot more time/ search skills than I have to check this out, but I found this curious.
A later model 110 Td5 came in for service and under the hood we find this decal (see image).
I did a little digging and the 40 CFR 88 comes up as EPA light duty truck regulations.
This decal looks like an original. It certainly could be made up, but...
Does this indicate that the Td5 meets 2002 EPA regulations?
 

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#7 ·
The EPA answer will be interesting It says the engine is EPA compliant to the 2002 model year but a 2002 MY vehicle is not allowed in the USA under Customs so ...?:popcorn:
 
#8 · (Edited)
Here's what I have back so far.

"Mr. Crowther,
We can’t find record of this Engine Family number in the data base so we will have to track it down. As you see on the label it is for a Light Heavy Duty vehicle and part of the Clean-Fuel Vehicles Regulations, so not a standard set up.

Keep in mind LDV’s are certified as a complete unit, engine, converters, emissions system and fuel system. The Engine Family number indicates it is a Heavy Duty Engine which only requires the engine to be certified by the manufacturer."


I asked the question as to the engine being epa approved. His response was that the classification listed on the decal is manufacturer certification that it is compliant, meaning EPA didn't certify it.
Where this will play with imports is that IF he comes back indicating it is indeed approved, td5 engines will be a legal retrofit into 25yr old trucks prior to importation. It would also mean we can import the engines as stand alone units to retrofit.

I'd love to have a td5 setup in my d2 for instance and since all td5's were obd 2 that would be a relatively simple swap.
 
#9 ·
Where this will play with imports is that IF he comes back indicating it is indeed approved, td5 engines will be a legal retrofit into 25yr old trucks prior to importation.
My understanding is that even if it's a compliant motor, but wasn't the "original configuration" it left the factory with, that it wouldn't fly for import?
 
#13 · (Edited)
On the EPA import form 3520 under code EE section 2 "With a letter attached to this form from the manufacturer that the vehicle is identical to a US certified vehicle with respect to emissions"-IE what the sticker says.

Granted getting this in writing from JLRNA may be a pain, the picture of the decal should go a long way.

That said I need to dig deeper on the "heavy duty engine" thing as it even requires a different form.
 
#16 ·
If that turns out to be real, then the EPA lied to me on my Freedom of Information Act request, which is no small matter.
 
#19 ·
Wouldn't be the first time we stirred the pot. :demented

Perhaps it was the case that diesels of this type were exempt from testing in certain vehicles at the time? So Rover was able to make the decal even without an EPA test of the engine.

Doug should be able to sort it out.
 
#22 · (Edited)
I don't think a FOIA request is necessary as all epa certs for my2002 are publically available. On that list, the only 2.5L engine certified is the one in the freelander (gas).

The question then becomes, are any engines allowed for import that "meet EPA" regs, but are not explicitly "certified" by the epa? If so, then there would be precedence, or so my strange brain thinks.
 
#27 · (Edited)
Exactly, which is why it is a choice on the entry form. I think the letter referenced above was incorrectly attributed to US Customs where it most likely was from DOT's Import Dept. I deal with three different agencies on a regular basis. US Customs doesn't do opinion letters, they do seizure letters. When I ask for permission/opinion on a questionable vehicle before shipping to the US I ask DOT and EPA, not Customs. Customs role is to enforce EPA and DOT's rules @ the borders and ports of entry. When questioned they defer to those agencies.

DOT is strictly safety. Since these vehicles aren't anywhere close to current standards DOT is adamant that updates (even ones that make a vehcile safer) cannot be made if you are asking for the 25yr exemption, the truck and all associated bits need to be 25 or @ least original spec. Seats, seat belts, window glass codes, different spec doors, alloy wheels, brake and suspension mods are all area's where DOT has taken issue with defenders and can and has denied entry.

DOT has no say over what's under the hood, that is EPA's domain. In short the engine has to be what the truck was built with or an EPA approved engine. It cannot be a 21yr old non- approved engine even through we allow any engine over 21yrs old to be imported by itself.
 
#43 ·
I'm keeping my fingers crossed that the TD5 will get the green light. I PCS from Germany in May and will add a TD5 to my household goods shipment if this turns out to be legit.
 
#45 ·
If it is legit, I'll convince the wife to ditch the antiques she aquired and we'll see how many we can fit in our household goods. :)
 
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