EPA issue: Importing used excavators from China
Almost all Chinese used equipment companies struggle with EPA issues. When they sell their machines to the United States, it’s basically a gamble. I believe buyers feel the same way.
So, I put together this video to share what I know and give a simple overview of EPA issues, just for reference.
First, I want to make one thing clear. During the import process, CBP reviews equipment documents according to EPA regulations. Common reasons for rejection include incomplete documents, problems with serial numbers, the inability to prove that the engine is used, and unclear manufacturing dates.
Also, please understand that selling companies usually can only provide historical records of the used equipment, and these records may not always be complete. These documents are used as a reference for customs to determine whether the engine is used, whether the manufacturing date is accurate, and whether it qualifies for the EPA used-engine exemption. Because of possible errors or gaps in the documents, we cannot guarantee 100% clearance.
Whether an engine qualifies for an exemption mainly depends on its manufacturing year and its emission tier, which could be Tier 2, Tier 3, or Tier 4. You can roughly estimate the tier by looking at the engine’s build year. Engines built between 1996 and 2000 are considered Tier 2. Engines built from 2001 to 2006 are Tier 2. Engines built from 2006 to 2011 are Tier Three. Engines built from 2011 to 2014 are Tier 4 Interim, and engines built from 2014 onwards are Tier 4 Final.
It is important to note that the emission standard is determined by the engine’s manufacturing year, not the machine’s production year. For example, if a machine was built in 2010 but it has a Tier 2 engine made in 2007, legally it is still Tier 2, not Tier 3.
Once the selling company provides complete historical documents, the customs clearance should be handled by a customs broker assisting the consignee. Customs clearance is the broker’s professional responsibility, and everyone should stick to their own role.
If we, as a selling company, could handle EPA clearance ourselves, I can guarantee that we would be able to dominate the import business for all used excavators in the United States, because every Chinese used equipment company is eager to find a company that can completely eliminate EPA risks. If you can guarantee 100% EPA approval, please contact us. Thank you.
Even if we prepare perfectly, this market still cannot be 100% risk-free. At the end of the day, we are all just ordinary people, aren’t we?
Finally, if your company can guarantee that our used equipment will pass EPA review 100%, please contact us. Thank you again.
Additional explanation: Canada’s ECCC is similar to the EPA, but it adds requirements from Transport Canada. You need to provide a statement that the equipment meets safety standards, the operation manual, warning labels, lights, signals, and so on. The specific requirements should be confirmed in advance with customs by a customs broker, and the sales company provides documents according to the broker’s instructions.
This process may generate extra costs, so usually, before the customer pays a deposit to confirm their purchase intention, the sales company will only provide partial documents. There’s no way around it. For example, when I was helping a client inspect machines, I checked many excavators from nearly ten different companies according to his requirements, and the process wasn’t even finished yet. In the end, he would only choose one. So, the market is always a bit complicated, and no sales company would rely solely on a customer’s verbal promise.