U.S. environmental compliance — guidance for importersRef. 40 CFR · Form 3520-21
SK Used Equipment · Export Compliance Desk
The EPA certificate,
explained for
used-equipment buyers.
What an EPA certificate is, why U.S. customs asks for it, which machines qualify — and how we prepare the compliance paperwork before your machine ships from China.
Exhibit A — EPA certificate of conformity
Definition
Understanding the EPA emissions certificate
An EPA certificate (also called an EPA emissions compliance certificate or EPA label) is an official document issued by theU.S. Environmental Protection Agency. It certifies that a non-road engine — such as the diesel engine in an excavator, bulldozer, or wheel loader — meets the required U.S. emission standards for its model year and power rating.
For used construction equipment imported into the United States, the engine must either hold a valid EPA certificate of conformity at the time of import, or qualify for an exemption. Without one, the machine cannot legally enter the U.S. market.
For machines exported to other regions, an EPA certificate can also serve as supporting documentation in countries that reference U.S. standards.
Schedule I — EPA tiers, non-road diesel
| Tier | Model years | Requirement |
|---|---|---|
| Tier 1 | 1996–2002 | Basic emission controls |
| Tier 2 | 2001–2005 | NOx and PM reduced ~60% |
| Tier 3 | 2006–2011 | Further NOx reduction |
| Tier 4 Interim | 2011–2013 | DOC/DPF or SCR introduced |
| Tier 4 Final | 2014+ | Ultra-low emissions · DEF/SCR |
The required tier follows the engine's model year and power band.
Consequences
Why compliance matters at the port of entry
Legal entry requirement
U.S. Customs and Border Protection requires proof of EPA compliance at the port of entry. Without it, your machine may be detained or refused.
Costly delays
Missing or incorrect EPA documentation leads to storage fees, demurrage charges, and months of customs delays while paperwork is sourced.
Resale value
Machines with clear EPA documentation are easier to resell in the U.S. market and typically command higher prices than uncertified units.
Eligibility
Which machines qualify?
Most used excavators, bulldozers, wheel loaders, and other non-road construction equipment with diesel engines built after 1996 can qualify for EPA certification, provided the original engine is intact and the emission control systems have not been tampered with.
For engines without a valid certificate — typically older models or grey-market equipment — there may be alternative pathways such as theEPA 1060 exemption for engines imported for testing, demonstration, or replacement purposes.
Tier 1 — Tier 4 Final engines
All standard non-road diesel engines with intact emissions hardware and original ECM calibration.
EPA 1060 exemption
Available for engines imported for replacement, testing, or demonstration purposes where the original certificate does not apply.
Verified engine label & documentation
Machines with legible EPA engine labels, original export certificates, and traceable manufacturer records.
Our support
How we prepare your EPA paperwork
Machine review
We check the engine model, model year, serial number, and EPA label to determine which tier applies.
Document preparation
We gather manufacturer records, EPA certificates of conformity, and any existing exemption letters.
Export documentation
EPA-related export paperwork prepared alongside the invoice, packing list, and customs declaration.
Buyer guidance
We advise your customs broker or importer on what EPA documents to present at the port of entry.
Not sure if your machine needs EPA certification?
Send us the machine details and destination country — we'll check the requirements for you.
§5 · Questions from importers
EPA certificate FAQ
Do I need an EPA certificate to import a used excavator into the USA?+
In most cases, yes. The non-road diesel engine must have a valid EPA certificate of conformity at the time of import, or qualify for an approved exemption. Without one, U.S. Customs and Border Protection can hold or refuse the machine at the port. See our full guide to importing a used excavator into the USA.
What is EPA Form 3520-21?+
Form 3520-21 is the EPA declaration filed at import that states the engine's emissions compliance status — whether it holds a certificate of conformity or is entering under a specific exemption code. Your customs broker files it with the entry paperwork.
Which used excavators are exempt from EPA requirements?+
Machines whose engines lack a valid certificate may still qualify under exemptions such as engines imported for replacement, testing, or demonstration purposes. Eligibility depends on the engine's model year, power rating, and intended use — send us the details and we will confirm which path applies.
How do I find my excavator's EPA tier?+
The tier (1 through 4 Final) is set by the engine's model year and power band, and is shown on the engine's EPA label. We check the engine model, year, serial number, and label to confirm the tier before the machine ships.
Can you provide EPA documents for excavators exported from China?+
Yes. We prepare the EPA-related export paperwork alongside the invoice, packing list, and customs declaration, and advise your customs broker on what to present at the port of entry.
Compliance desk — closing note
Ready to check EPA compliance
for your next purchase?
Browse our current stock or contact us with the machine you need — we'll confirm EPA eligibility and prepare the documentation.