On October 9, 2025, the CSCB and the Environment and Climate Change Canada (ECCC) held the webinar "CSCB Webinar: ECCC Regulatory Compliance for the Vehicle and Engine Emission Regulations". Thank you all for your active participation in the webinar, your engagement sparked numerous insightful questions for the ECCC team.
The list of questions that were taken away have now been answered by ECCC please see below.
For clarity, the abbreviations for specific regulations are listed below:
- Off-Road Compression-Ignition (Mobile and Stationary) and Large Spark-Ignition Engine Emission Regulations (CI-LSI)
- Marine Spark-Ignition Engine, Vessel and Off-Road Recreational Vehicle Emission Regulations (MERV)
- Off-Road Small Spark-Ignition Engine Emission Regulations (SSI)
- On-Road Vehicle and Engine Emission Regulations (ORVEER)
- Heavy-duty Vehicle and Engine Greenhouse Gas Emission Regulations (HDV GHG)
- If the consignee submitted the transactional declaration directly to ECCC prior to importation and has been approved, and then Customs Broker will process the shipment when it arrived or prior to arriving. what exception process codes are we using ? and do we still need to go through and process the VEEP/VP form on SWI EDI Thanks
Importers should choose one way to submit an importation declaration. If an engine is declared through the Single Window Initiative (SWI) Integrated Importation Declaration (IID) and is declared completely and accurately, you are not required to and should not provide a transactional declaration form directly to Environment and Climate Change Canada (ECCC). Regulated products entered into SWI must select the appropriate code (i.e. XE01 for On-Road products, XE02 for products subject to the CI-LSI Regulations, XE04 for MERV products).
- If you are representing an importer, you should inform them that you are submitting the information on their behalf. The SWI is intended to reduce their regulatory reporting requirements. The broker should be working with the importers they are representing to confirm all the Importation Declaration reporting requirements can be fulfilled via the SWI.
If an importer is provided the NEM authorisation, does this allow us to use the XE05 code for both vehicles and engines or not.
If an importer of on-road products has authorization to use the National Emissions Mark (NEM) for a product category (prescribed classes) and the NEM is applied, exception code XE05 should be used. Please note that the NEM is not equivalent to the US EPA certification. For Off-road products, XE05 is not an applicable code and we recommend you review the presentation provided.
- If the engine was reported through a paper transactional declaration [the importer provided the Importation Declaration directly to ECCC], how can it be declared in the IID to avoid rejection? There are only "Not regulated" or "bulk reporting" options.
Importers should choose one way to submit an importation declaration, if an engine is declared through the Single Window Initiative (SWI) Integrated Importation Declaration (IID) and is declared completely and accurately, you are not required to and should not provide a transactional declaration form directly to Environment and Climate Change Canada (ECCC). Regulated products entered into SWI must select the appropriate code (i.e. XE01 for On-Road products, XE02 for products subject to the CI-LSI Regulations, XE04 for MERV products).
If you are representing an importer, you should inform them that you are submitting the information on their behalf. The SWI is intended to reduce their regulatory reporting requirements. The broker should be working with the importers they are representing to confirm all the Importation Declaration reporting requirements can be fulfilled via the SWI.
- Individual contacts have received 'generic' notifications from ECCC advising of errors relating to XE06 [client has bulk reporting approval] however only transaction numbers are provided. Is there anyway that IOR [Importers of Record] names be provided as well so we can follow through on correcting the data going forward? Also various IOR clients have received the same communications. Is this something IOR's/Brokers will continue to receive?
Sending notices on common and larger scale issues may continue to be one strategy ECCC employs to improve data quality going forward. The recent XE06 mailout was sent to notify those (both brokers and IORs) who may be misusing the XE06 code to assist them in making better selections in the future. We are happy to answer any questions that recipients of this mailout, or future ones, may have if they reach out to us directly.
- Is ECCC working with CBSA to Flag Vendors that are producing Fake labels to prevent Canadians from importing engines that are inadmissible.
ECCC works closely with CBSA to prevent the importation of inadmissible products such as those bearing fake labels. It is the responsibility of the person importing products into Canada to ensure that those products are compliant with any applicable vehicle and engine emission regulations and to demonstrate compliance. ECCC conducts various compliance promotion activities, including responding to public inquiries, to assist importers in understanding the administrative and technical provisions of the regulations, which includes labeling requirements.
- Is there a way to contact ECCC in regards to urgent matters especially in the case of asking if a label is admissible.
Importers can reach out to ECCC at [email protected] for assistance including label reviews. We are committed to providing you with high quality service and responding in a timely manner. However, please be aware that due to high demand, the service standard for response from the ECCC’s Transportation Division is ten (10) business days.
- SSI - If the importer cannot get the evap family name, do we just advise they cannot import the product? 2nd - Can the EVAP be the same as the Engine Family on the label?
Section 19(1) of the SSI Regulations requires that a declaration contain all the information listed therein, including “all applicable emission families”.
An engine whose label does not say “THIS ENGINE MEETS U.S. EPA EXH/EVP REGS FOR [MODEL YEAR]” should be checked further. This may be because the engine manufacturers do not install the evaporative components (i.e. fuel lines and fuel tanks) themselves, and the machine manufacturers likely install them themselves. The evaporative components should each have an associated EPA Certificate of Conformity, and the machine manufacturer should be able to provide you with this information.
A machine/equipment manufacturer who is adding the fuel lines and fuel system separately would need to apply for certification with the EPA and thus the labelling requirements of 40 CFR 1060.135 apply. This is where you might see another emission control information label that states the EPA evaporative family and the statement “THIS [equipment] MEETS U.S. EPA EVAP STANDARDS”. If the machine manufacturer is not certified but using certified components, then the statement “MEETS U.S. EPA EVAP STANDARDS USING CERTIFIED COMPONENTS” would be used.
There are instances where the engine manufacturer meets both the exhaust and evaporative (permeation) requirements and the Exhaust Family listed on their certificate covers both the evaporative and exhaust emissions standards. In these instances, the statement “THIS ENGINE MEETS U.S. EPA EXH/EVP REGS FOR [MODEL YEAR]” should be present, and there may be only the Exhaust Family on the label.
Engines with gaseous fuels (natural gas, propane) do not need to report Evaporative (Permeation) Families.
- A customs broker acted in good faith and relied on the documents and information provided by the importer would still subject to penalties and considered as an agent of the importer due to any non conformance on part of the importer?
The Environmental Violations Administrative Monetary Penalties Act is an absolute liability regime. As such, acting in good faith and honest mistakes are not reasons for setting aside administrative monetary penalties. If found to have acted as an agent of the importer, depending on the specific context and circumstance, a broker may be held liable for participating in a non-compliant importation and could be subject to administrative monetary penalties.
- What good source of information on Engine location? Evidence location?
The importer should be able to advise where an engine will be stored if required by the import declaration. Similarly, the importer is responsible for maintaining evidence of conformity and they should provide its location if required on the declaration.
If a record is retained by another person [eg NOT the importer] on a company’s behalf, the company must keep a record of that other person’s name, telephone number and civic address and, if different, their mailing address.
If the Minister makes a written request for a record [such as the Evidence of Conformity information], the company must submit it in either official language within 40 days after the day on which the request is made.
- Generators that are stationary but not emergency generators as the end use if for companies or households in case of power loss these are still to be recorded in ECCC yes?
All engines subject to the CI-LSI Regulations or the SSI Regulations must be declared to ECCC, including those that are for emergency purposes.
The CI-LSI Regulations apply to stationary compression-ignition (SCI) engines (diesel engines) if they are manufactured on or after June 4, 2021SCI engines manufactured prior to June 4, 2021 are not subject to the regulatory requirements of the CI-LSI Regulations. Although not a regulatory requirement in this case, you may wish to maintain documentation related to the engines or products for your records (i.e. manufacture dates of the engines). The CI-LSI only applies to mobile large spark-ignition engines, while stationary large spark-ignited engines are not subject to the CI-LSI regulations.
All engines subject to the SSI Regulations, must be reported.
- If the importer files end of model year reports does the broker have to submit emissions at time of import?
Yes, it is still required to submit emission families at the time of import.
Under ORVERR, end of model year reports are only required for class 2b&3 non-vocational vehicles.
Under the SSI Regulations, the emission families are required as part of the importation declarations.
Under the MERV Regulations, the emission families are not required to be reported in the Importation Declarations. However, reporting these can aid your importer when they are filling out their End of Model Year (EoMY) reports.
- for importers that file end of model year reports that are not required to be reported at time of import, what exception code do we use.
End of Model Year(EoMY) reports and their requirements are separate and not equivalent to any requirements to submit import declarations. The EoMY reports are outside of the scope of the CBSA SWI and therefore no code has been allocated under the Electronic Commerce Client Requirements Document. However, information reported via the IID including emission families and model year can be helpful to the Importer when fulfilling the EoMY regulatory reporting requirements.
To view the recorded webinar, please click here.