Submission requirements for evidence of conformity for several types of vehicles: appendices A to I
Official title: Guidance document - Submission requirements for evidence of conformity for light-duty vehicles, light-duty trucks, medium-duty passenger vehicles and heavy-duty class 2b and 3 vehicles in relation to the On-road Vehicle and Engine Emission Regulations and the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations made under the Canadian Environmental Protection Act, 1999
Disclaimer
This document is intended to provide guidance only. It does not in any way supersede or modify the Canadian Environmental Protection Act, 1999 (CEPA), the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations (PALTGGER), the On-Road Vehicle and Engine Emission Regulations (ORVEER), or their amendments. In the event of an inconsistency between this document and the CEPA, the PALTGGER and/or the ORVEER, the CEPA, the PALTGGER and the ORVEER prevail.
List of appendices
Appendix A - Example of an EPA certificate
Appendix B - Example of a letter demonstrating that the NEM is affixed
[Company Name]
[Insert Date]
Director, Transportation Division
Energy and Transportation Directorate
Environmental Protection Branch
Environment and Climate Change Canada
351 St. Joseph Blvd.
Gatineau, Québec, K1A 0H3
Subject: Proof that the vehicles covered by the EPA certificate bears the NEM for 20XX model year [Vehicle Make Model] (Test Group: [Test Group Name]).
Dear Director:
[Company Name] has been authorized by the Minister of Environment and Climate Change to apply the National Emissions Mark (NEM) to their on-road vehicle, as per section 151 of the CEPA and section 8 of the ORVEER. The authorization number assigned by the Minister to [Company Name] is [Authorization Number].
[Company Name] attests that all vehicles in the above referenced test group, manufactured in, or imported into Canada, are affixed with the NEM.
As the signatory of this letter, I, [Name], certify that I am authorized to act on behalf of [Company Name] concerning the 20XX [Vehicle Model]. Should you have any questions in regard to the information provided, please contact [Name, Position and Company Name].
[Signature]
[Insert Name]
[Position]
[Contact Information]
Appendix C - Example of a statement of compliance letter (for vehicles equivalent to a vehicle covered by an EPA certificate as per Section 35.1)
[Company Name]
[Insert Date]
Director, Transportation Division
Energy and Transportation Directorate
Environment and Climate Change Canada
351 St. Joseph Blvd.
Gatineau, Québec, K1A 0H3
Subject: Submission of Evidence of Conformity pursuant to the On-Road Vehicle and Engine Emission Regulations (ORVEER) and the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations (PALTGGER) for the 20XX model year [vehicle make and model] (Test Group: [test group] EVAP Family: [evaporative family]).
Dear Director:
[Company Name] intends to sell a 20XX model year [Vehicle Make and Model], in Canada. Evidence of conformity is being submitted as per section 35.1 of the ORVEER and section 36 of the PALTGGER. The subject vehicle model is not covered by a certificate of conformity issued by the U.S. Environmental Protection Agency, but it may be considered equivalent to a vehicle listed on a valid EPA certificate (attached), as per section 19.1 of the ORVEER.
Standards to which the vehicle conforms
Exhaust emission standards & useful lives
LD[XX] Tier[X] (Bin Y) – XXX,XXX miles
Pollutant Specific Emission Standards:
- PM: Tier[X] - XXX,XXX miles
- SFTP NMOG+NOx FEL : XXX g/mi
- Cold NMHC FEL: XXX g/mi
- CH4: XXX g/mi
- N2O: XXX g/mi
Evaporative emission standards & useful life
Tier [X] – XXX,XXX miles
FEL: X.XXX grams
The equivalent vehicle has the same emission control features as the vehicle tested to obtain the EPA certificate and has no features that could cause it to have a higher level of emissions than that certified vehicle.
[Company Name] attests that all vehicles of this test group comply with all applicable standards set out in the ORVEER and the PALTGGER made under the Canadian Environmental Protection Act, 1999. Attached, please find [Company Name]’s evidence of such conformity, including a detailed description of the subject vehicles. [Company Name] also attests that the vehicles of this test group are manufactured to the same specifications as those set out in the evidence of conformity and will be affixed with an appropriate vehicle emission control information label.
[Company Name] requests that Environment and Climate Change Canada acknowledge that the attached evidence of conformity has been obtained and produced in a form and manner satisfactory to the Minister.
As the signatory of this letter, I, [Name], certify that I am authorized to act on behalf of [Company Name] concerning the 20XX [Vehicle Model]. Should you have any questions in regard to the information provided, please contact [Name, Position and Company Name].
[Parts (as listed)] of the information supplied in this package is classified as confidential.
[Signature]
[Insert Name]
[Position]
[Contact Information]
Encl.
Appendix D - Example of a comparison table for equivalent vehicles
The following table is an example of the information required to demonstrate that a vehicle could be equivalent to a model that is specifically listed on an EPA certificate.
|
EPA certificate model |
Canadian model |
|---|---|---|
Make |
|
|
Model |
|
|
Body style |
|
|
EPA certificate number |
|
Not applicable |
Test group |
|
|
Evaporative/refueling family |
|
|
|
EPA certificate model |
Canadian model |
|---|---|---|
1. Durability Group a) Combustion Cycle (e.g., 2-stroke, 4-stroke, Otto Cycle, Diesel Cycle, Dedicated Electric) |
|
|
1. Durability Group b) Engine Type (e.g., piston, rotary, air-cooled, water-cooled, Electric) |
|
|
1. Durability Group c) Fuel Used (e.g., gasoline, diesel, methanol, ethanol, CNG, LPG, flex-fuel, Electric) |
|
|
1. Durability Group d) Basic Metering System (e.g., throttle body injection, port injection, CNG fuel mixer) or Battery Type (e.g.,Lithium-Ion, NiMH) |
|
|
1. Durability Group e) Catalyst Construction (e.g., beads, monolith) |
|
|
1. Durability Group f) Precious metal composition of the catalyst by type of principal active material (e.g., platinum based ox-cat, palladium based ox-cat, platinum and rhodium 3-way cat, palladium and rhodium 3-way cat, platinum and palladium and rhodium 3-way cat) |
|
|
| 1. Durability Group g) Catalyst Grouping Statistic (GS) or other criteria (40 CFR 86.1820-01(b)(7)(i) or (ii)) | ||
| 1. Durability Group h) Other Durability Grouping strategy (based on 40 CFR 86.1820-01(c), (d), or (e) | ||
| 2. Engine Displacement (within 15 percent or 50 in3, whichever is larger) or Electric Motor capacity (kW) | ||
| 3. Electric vehicle range in the case of BEVs or PHEVs | ||
| 4. Number of cylinders or combustion chambers | ||
| 5. Arrangement of cylinders or combustion chambers (e.g., in-line V, horizontally opposed) or Type and Voltage of Electric Motor | ||
| 6. Emission standards (same or more stringent) | ||
| Other Grouping criteria based on 40 CFR 86.1827-01(b), (c), (d), (e) or (f) |
(For gasoline-, ethanol-, methanol-, liquefied petroleum gas-, and natural gas-fueled vehicles) |
EPA certificate model |
Canadian model |
|---|---|---|
1. Type of vapor storage device (e.g., canister, air cleaner, crankcase) |
|
|
2. Basic Canister Design a) Working capacity (within a 10 gram range) |
|
|
2. Basic Canister Design b) System configuration (Number of canisters, method of connection (e.g., series or parallel)) |
|
|
2. Basic Canister Design c) Canister geometry, construction and materials |
|
|
3. Fuel system |
|
|
4. Type of refueling emission control system (e.g., integrated or non-integrated with evaporative control system) |
|
|
| 5. Fillpipe sealing mechanism (e.g., mechanical, liquid, other) | ||
| 6. Vapor control system or method of controlling vapor flow through the vapor line to the canister (e.g., type of valve, vapor control strategy) | ||
| 7. Purge control system (e.g., type of valve, purge control strategy) | ||
| 8. Vapor hose material | ||
| 9. Fuel tank material | ||
| Other: Grouping criteria based on 40 CFR 86.1821-01(c), (d), or (e) |
Statements
The equivalent vehicle described above has the same emission control features as the vehicle tested to obtain the EPA certificate and has no features that could cause it to have a higher level of emissions than that certified vehicle.
Our Company has access to all records submitted to the EPA in support of the application for the issuance of the EPA certificate.
Comments / additional information
Appendix E - Example of a statement of compliance letter (for vehicles not covered by an EPA certificate or not sold concurrently in Canada and the United States)
[Company Name]
[Insert Date]
Director, Transportation Division
Energy and Transportation Directorate
Environment and Climate Change Canada
351 St. Joseph Blvd.
Gatineau, Québec, K1A 0H3
Subject: Submission of Evidence of Conformity pursuant to the On-Road Vehicle and Engine Emission Regulations (the ORVEER) and the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations (PALTGGER) for the 20XX model year [Vehicle Make and Model] (Test Group: [Test Group Name] EVAP Family: [Evaporative Family Name]).
Dear Director:
[Company Name] intends to sell a 20XX model year [Vehicle Make and Model], in Canada. Evidence of conformity is being submitted as per [Subsection 35(1.1) OR Section 36] of the ORVEER and section 37(1) of the PALTGGER. The subject vehicle model [Is Covered OR Is Not Covered] by a certificate of conformity issued by the U.S. Environmental Protection Agency.
Standards to which the vehicle conforms
Exhaust emission standards & useful lives
LD[XX] Tier[X] (Bin Y) – XXX,XXX miles
Pollutant Specific Emission Standards:
- PM: Tier[X] - XXX,XXX miles
- SFTP NMOG+NOx FEL : XXX g/mi
- Cold NMHC FEL: XXX g/mi
- CH4: XXX g/mi
- N2O: XXX g/mi
Evaporative emission standards & useful life
Tier [X] – XXX,XXX miles
FEL: X.XXX grams
[Company Name] attests that all vehicles of this engine family comply with all applicable standards set out in the On-Road Vehicle and Engine Emission Regulations and the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations made under the Canadian Environmental Protection Act, 1999. Attached, please find [Company Name]’s evidence of such conformity, including a detailed description of the subject vehicles. [Company Name] also attests that the vehicles of this test group are manufactured to the same specifications as those set out in the evidence of conformity and will be affixed with an appropriate vehicle emission control information label.
[Company Name] requests that the Minister of Environment and Climate Change Canada acknowledge that the attached evidence of conformity has been obtained and produced in a form and manner satisfactory to the Minister.
As the signatory of this letter, I, [Name], certify that I am authorized to act on behalf of [Company Name] concerning the 20XX [Vehicle Model]. Should you have any questions in regard to the information provided, please contact [Name, Position and Company Name].
[Parts (as listed)] of the information supplied in this package is classified as confidential.
[Signature]
[Insert Name]
[Position]
[Contact Information]
Encl.
Appendix F - Technical information requirements
Cover page
Requirements |
Comments |
Location found (TEMP) |
|---|---|---|
Model year |
Identify the model year. |
|
Make, models and carlines |
Identify the make(s) and model(s) covered by the submission. |
|
Durability Group Name |
Alpha numeric code to identify the Durability Group for the vehicle. |
Previous EC guidance document |
Test Group name |
Identify the test group. |
|
Evaporative family name |
Identify the evaporative family. |
|
Brief description of durability group |
Provide a brief description of the durability group (e.g. combustion cycle, fuel type, catalyst code, etc.) |
Previous EC guidance document |
Brief description of test group |
Provide a brief description of the test group (e.g., engine displacements, fuel delivery system, emission control systems, catalyst type, oxygen sensor config., etc.). |
|
Vehicle Class |
LDV,LDT,HDV, etc. |
|
Applicable standards, including but not limited to: exhaust, greenhouse gas, evaporative/refueling or any interim in use standards. |
Identify exhaust and evaporative emission standards applicable to the test group, (including CH4, N2O and FELs when applicable). Indicatice if vehicle is Tier 3 or Interim Tier 3 compliant. |
|
Applicable useful life |
Identify the useful life of the test group, and evaporative family. |
|
Vehicles tested (EDVs) |
List each vehicle identity and configuration number tested and the corresponding test type(s) for each combination. Include data for any carry over EDVs. |
|
Company name |
Identify the company’s name (See definition in CEPA 1999, section 149). |
|
Vehicle manufacturer |
Identify the vehicle’s original equipment manufacturer name. |
|
Laboratory accreditation
Requirements |
Comments |
|---|---|
Provide the name and address of the laboratory where accreditation testing was carried out. Also include the accreditations of the laboratory where the testing was performed. The laboratory where the tests are carried out would have to be capable of certifying to Canadian or U.S. standards |
This is normally demonstrated by the lab having previously completed testing to support the issuance of a U.S. EPA certificate. View the list of Environmental Laboratory Accredition programs |
Section 1 – Correspondence and communications
Identify person(s) both within and outside the company authorized to be in contact with staff from the Transportation Division of Environment and Climate Change Canada and who may be contacted with regards to the submission. Identify areas of responsibility for each person listed, if applicable.
Requirements |
Comments |
Name of company |
Provide the company’s name. |
Address of company |
Provide the company’s postal address. |
Company representative(s) |
Provide the representative’s name, including title/position and their individual area of responsibility. |
Representative address |
Provide the representative’s postal address, if different than listed above. |
Email address |
Provide the representative’s email address. |
Phone number |
Provide the representative’s phone number. |
Section 2 – Durability group description
Requirements |
Comments |
Location found (TEMP) |
|---|---|---|
Durability group name |
Provide durability group name. |
|
Combustion cycle or indicate that vehicle is a hybrid, fuel cell or dedicated electric vehicle. |
e.g. four stroke- Otto cycle, compression ignition, etc. |
|
Engine type or type of electic motor
|
e.g. piston, rotary, DC brushless, etc. |
|
Fuel used or battery type (including cell chemisty) |
e.g. gasoline, diesel, Nickel Metal Hydride, etc. |
|
Basic fuel metering system |
e.g. multi-port fuel injection, direct fuel injection, etc. |
|
Catalyst construction and general location |
e.g. ceramic monolith, etc. |
|
Precious metal composition of the catalyst by the type of active material(s) used |
e.g. palladium based oxidation catalyst, platinum and rhodium three way catalyst, etc. |
|
Precious metal loading for all catalysts in the durability group |
As defined in paragraph 86.1820-01(b)(7)(i)(A) of the CFR |
|
Range of Catalyst Grouping Statistics |
Provide if applicable |
1820-01(b)(7)(i) |
Durability Data Vehicle (DDV) Description |
Specify which vehicle was used for testing, and its applicable configuration number. |
|
Test Groups included in Durability Group |
List all test groups. |
|
Section 3 – Evaporative/refuelling family description
Requirements |
Comments |
Location found (TEMP) |
|---|---|---|
Evaporative/refuelling family name |
Provide name of evaporative/refuelling family. |
|
Schematics or general descriptions |
May be placed in the commons section. |
|
Evaporative/Refueling Family Parameters including:
|
As specified in 40 US CFR §86.1821
|
40 CFR §86.1821-01 |
Section 4 – Durability procedure description
Provide the following information for all emission data vehicles (EDVs).
Requirements |
Comments |
|---|---|
Durability group |
Provide the name of the durability group. |
Amount of aging required and performed |
|
Description of exhaust durability procedure |
Procedure used as specified in §86.1823 as well as the equivalency factor required to be calculated in §86.1823-08(e)(1)(iii)(B) if applicable |
Description of evaporative/refuelling durability procedure |
Procedure used as specified in §86.1824 and §86.1825 |
Deterioration factor list, calculated to full or intermediate useful life as applicable. |
If listed in Section 7 - Test Results, those locations may be referenced in lieu of tabulating deterioration factors in Section 4. |
Indicate whether additive or multiplicative DF’s are used |
Specify deterioration factor as either multiplicative or additive. |
Indicate if aged components were used |
Specify if aged components were used to determine certification levels. |
Section 5 – Test group description
Requirements |
Comments |
|---|---|
Test group name |
Provide the name of the test group. See Appendix H for test group naming convention. |
Engine displacements covered |
List all which apply. |
Arrangement and number of cylinders or combustion chambers |
e.g. V6, I4, etc. |
Vehicle class(es) covered |
e.g. LDV, LDT1, LDT2, etc. |
Emission standards class |
e.g. Tier 3, Interim Tier 3, etc. |
Applicable emission standards |
e.g. Bin 0, Bin 125, etc. |
A manufacturer of hybrid electric vehicles must create separate test groups based on type of battery technology employed and upon features most related to their exhaust emission characteristics. |
Refer to 40 US CFR §86.1827-01(e). |
A manufacturer of electric vehicles is required to create separate test groups based on:
|
Refer to 40 US CFR §86.1827-01(f) |
Section 6 – Test vehicle description
Provide the following information for all emission data vehicles covered by this test group.
Requirements |
Comments |
|---|---|
Vehicle identification numbers |
VIN, test vehicle number and configuration number |
Test group and evaporative family |
|
Provide justification as to why vehicle chosen as test vehicle is representative of the worst case scenario. |
A detailed description as to why the chosen test vehicle will have the highest level of emissions over other vehicles of the same test group or evaporative emission family. |
Tests performed |
Identify which tests were performed (e.g. EVAP/Refueling, Cold CO, SFTP, etc.). |
US EPA Certification and Fuel Economy Information System (CFEIS) or VERIFY vehicle information |
Provide printouts of all that apply. |
Basic vehicle description |
Include the make, model, model year, drive source, fuel system, and vehicle layout (e.g. 4-door sedan) |
Engine code |
|
Engine displacement or size/capacity of electric motor |
|
Number of cylinders |
|
Valves per cylinder |
|
Rated horsepower or kW |
In hp for conventional engines or kW for electric vehicles |
Curb weight |
|
Equivalent test weight (ETW) |
|
Gross weight |
|
If there are multiple fuels, indicate if they are stored separately or together |
|
If there are multiple fuels, indicate if they are combusted together or separately |
|
Indicate if vehicle is equipped with a rechargeable energy storage system |
List the type and describe the system |
Indicate if the vehicle is capable of off board charging |
|
Tire size |
|
Transmission type and number of gears |
|
Axle ratio |
|
N/V Ratio |
Range of values acceptable |
Emission Control System |
List all exhaust emission related components (e.g. air injection pump, detonation sensor, three-way catalyst, oxygen sensor, etc.). Indicate catalyst preheating method, if applicable. |
Vehicle drive mode while testing |
Indicate if vehicle is to be tested in a selectable driving mode such as sports, dyno mode, etc. |
Aged emission components |
Identify if aged emission control components were installed on the EDVs |
Main fuel tank capacity or battery energy capacity |
Specify in Liters for combustion fuels or kWh for electric vehicles. |
Battery type if applicable |
Lithium Ion, NiMH, etc. |
Dynamometer Target force coefficients |
|
Dynamometer Set force coefficients |
|
Road Load Horsepower |
|
Turbo/Supercharger |
Indicate which is installed, if applicable. |
Identify if vehicle is equipped with air conditioning |
If applicable |
Section 7 – Test results
Requirements |
Comments |
|---|---|
Official test results (listing all applicable constituents) on all test vehicles which are applicable to this submission. |
A comprehensive list of all test results and the applicable intermediate (if applicable) and full useful life emission standards to which the test group is deemed to comply with as specified in sections 11 through 13 of the ORVEER and sections 8 through 12 of the PALTGGER. At least one separate sheet of results should be provided for each test performed (e.g. HWFCTE, Cold FTP, Federal fuel 2-day exhaust, USO6, SCO3, ORVR, etc.). U.S. EPA CFEIS or VERIFY CSI PDFs are acceptable, if all required information is included and if available. |
Standards for pollutants for which testing is waived (see section 8 of this appendix) and interim in-use standards |
Include all emission standards for which a manufacturer is using compliance statements in lieu of testing and any interim in-use standards that are applicable. |
Calculation and list of the emission levels for each constituent |
For each emission constituent tested and for each odometer level which requires reporting, the company must show the measured test result, the deterioration factor used, indicate if it is Multiplicative or Additive, indicate the useful life in which it complies, the upward and downward adjustment factors (if applicable), list the calculated emission level and also list the emission standard value it is being measured against, including the applicable Tier and Bin numbers. |
NMOG/NMHC ratio |
When applicable, specify how NMOG values were calculated as described in 40 CFR 1066.635. |
Indicate EDV used for each test performed |
Identify the EDV used for each test performed. |
Indicate test fuel used for each test performed |
Identify test fuel used for each test performed. Also identify the method of accounting for ethanol in determining evaporative emissions for gasoline fueled vehicles. |
Section 8 – Emission compliance statements (in lieu of conducting emission testing)
Subsections 1806, 1810 and 1829 of Title 40, chapter I, subchapter C, part 86, subpart S, of the of the CFR describes general testing procedures and includes several provisions allowing for statements of compliance instead of testing in certain circumstances. Please refer to these subsections of the CFR for the appropriate compliance statements as applicable. Below are examples of some of the emission data vehicle compliance statements which may be submitted.
| Requirements | Comments | Location found (TEMP) |
|---|---|---|
| Gasoline or methanol fueled particulate matter | Indicate what approach is being followed to comply with PM phase in standards and if the test group is included in the percentage of vehicles required to meet Tier 3 PM standards under section 17 of the ORVEER. If vehicle is covered by an EPA certificate, include appropriate statement per 40 US CFR §86.1829-15(d)(1) or (d)(2) or (d)(3). | CFR and ORVEER |
| High altitude Exhaust/Evaporative | If applicable. As per 40 US CFR §86.1829-15(c) | CFR |
| Formaldehyde Emissions | If applicable. May provide a statement that vehicles comply with the applicable formaldehyde standard instead of submitting test data. As per 40 US CFR §86.1829-15(d)(4). | CFR |
| N2O Emissions | If applicable. Prior to MY 2019, may provide a statement that vehicle complies to applicable standards instead of measuring N2O emissions. As per 40 US CFR §86.1829-15(d)(6). Also must indicate which standard under PALTGGER 10(1) that N2O complies. | CFR |
| Refueling emission standard for diesel, natural gas or LPG fueled vehicles | If applicable. May provide a statement that vehicle complies to applicable standards instead of submitting test data for refueling standards. As per 40 US CFR §86.1829-15(e)(1),(2)&(3).Note that natural gas vehicles must meet the refueling connection requirements of 40 CRF 86.1813-17(f)(1). | CFR |
| Evaporative emission standard for natural gas or LPG fueled vehicles | If applicable. May provide a statement that vehicle complies to applicable standards instead of submitting test data for evaporative standards. As per 40 US CFR §86.1829-15(e)(2)&(3). | CFR |
| Leak Standard | If applicable. May provide a statement that vehicles not tested in a given model year comply with the leak standard in §86.1813 instead of submitting test data. As per 40 US CFR §86.1829-15(e)(4). | CFR |
| Fuel Spitback | If applicable. May provide a statement that vehicles comply with the fuel dispensing spitback standard instead of submitting test data. As per 40 US CFR §86.1829-15(e)(5). | CFR |
| Supplemental Two-Diurnal Test Sequence | If applicable. In lieu of testing for supplemental two-diurnal test sequence, may provide a statement that vehicles comply. As per 40 US CFR §86.1829-15(e)(6). | CFR |
| Refueling test for incomplete class 3 HD vehicles or complete class 3 HD vehicles with fuel tanks exceeding 35 gallons nominal capacity. | Company may provide a statement as per 40 US CFR §86.1829-15(e)(9). | |
| OBD Compliance Statement | The company must state that the OBD system complies with the On-Road Vehicle and Engine Emission Regulations. If available, a US EPA or CARB letter indicating OBD system approval without deficiencies could be included. | |
| Electric Vehicles and Fuel Cell Vehicles | Manufactureres may provide a statement that vehicles powered solely by electricity comply with all the requirements of this subpart instead of submitting test data as per 40 US CFR §86.1829-15(f). | |
| 91 RON Fuel Testing | A company must provide a statement that the knock sensor is not a defeat device when vehicles are tested with RON 91 test fuel (as per EPA Guidance VPCD-97-01). | |
| US06 SFTP A/F ratio lean best torque | Include a statement that vehicles covered under will comply with the requirements of 40 US CFR 86.1811-17(d)(1) and include an explanation for any conditions where additional enrichment is required to protect the engine or emission control system as per 40 CFR 86.1844-01(d)(11)(iii). | |
| Leak free exhaust statement | Include a statement of compliance that exhaust system is designed according to 40 CFR 86.1844-01(d)(16). May reference the complete exhaust system. Description as per section 16 of this Appendix. | |
| 20°F to 86°F emissions | Include a statement as per 40 CFR 86.1809-12(e) that no discontinuity exists in emissions of NMOG, CO, CO2, NOx, CH4 or HCHO within the specified temperature range. | |
| Fixed liquid level gauge waiver for testing refueling emissions (LPG vehicles) | If applicable. As per 40 US CFR §86.1810-09(n). |
Section 9 – OBD system description
Requirements |
Comments |
|---|---|
A description of the functional operation characteristics of the onboard diagnostic system. |
As per 40 US CFR §86.1806-17. |
The general method of detecting malfunctions for each emission-related component. |
As per 40 US CFR §86.1806-17. |
Statement that no OBD deficiencies exist within test group |
As per paragaph 12(b) of the ORVEER. |
Section 10 – Description of alternate-fueled vehicles
Requirements |
Comments |
|---|---|
Description of all flexible or dedicated alternate fuel vehicles. May choose to include descriptions of electric fueled vehicles in this section. |
This includes, but is not limited to, the fuel and/or percentage of alternate fuel for all such vehicles if applicable. |
Section 11 – AECD description
Requirements |
Comments |
|---|---|
A list of all auxiliary emission control devices (AECD) installed on any applicable vehicles including the sensed and controlled parameters. |
The detailed description of the AECD should include parameters sensed and controlled, and the expected effect the AECD has on emissions (both on- and off-cycle). All AECDs that reduce the effectiveness of the emission control system and therefore require a justification include “lean-oncruise” and “air-conditioner-on” strategies. This information should be supplied in a form that can be easily understood by an engineer skilled in automotive emissions control (e.g. not in computer language). Preferred format is a table listing AECDs (down) and sensed and controlled parameters (across). |
A detailed justification of each AECD which results in a reduction in effectiveness of the emission control system, and rationale why the AECD is not a defeat device as defined in subsection 11(3) of the ORVEER. |
AECD descriptions and justifications of why they are not defeat devices can be included in a common sections submission. Additionally, manufacturers could include statements in their evidence of conformity as to why an AECD is not a defeat device as per subsection 11(4) of the ORVEER. |
Section 12 – Description of vehicles covered by certificate and test parameters
Requirements |
Comments |
|---|---|
Carline |
|
Model name |
|
Vehicle classification |
e.g. LDV, LDT1, etc. |
Engine code |
|
Number of valves per cylinder |
|
Engine displacement |
|
Transmission and overdrive |
|
Shift light indicator |
|
Tire size |
|
N/V ratio |
Range of values acceptable. |
Equivalent test weight (ETW) |
Range of values acceptable. |
Fuel tank volume or battery storage capacity |
Range of values acceptable. |
Engine starting procedures |
|
Transmission test mode or modes if equipped with a driver selectable multimode or select shift type |
|
Shift schedules |
If applicable. List EPA shift schedule number and shift speeds. |
Dyno loading Information |
Either: (1) Twin roll Dyno DPA (Dyno Power Absorption) and coastdown times, or (2) single roll dyno roadload coefficients, as appropriate; indexed by the vehicle characteristics (models, ETW, tires) covered. Roll diameter will also be required. |
Evaporative testing parameters |
i.e. canister loading, running loss fuel tank temperature, etc. |
Emission test site cooling fan location |
|
Advanced technology system test mode or modes |
e.g. idle start/stop enabled or disabled. |
Emission control system description
Requirements |
Comments |
|---|---|
Type, number and configuration of catalyst(s) |
|
Exhaust gas recirculation (EGR) type |
If applicable. |
Air pump type |
|
Fuel system type |
|
Intake air aspiration method |
|
Other |
|
Advanced technology vehicle description
Requirements |
Comments |
|---|---|
Electric motor size (in kW) and type |
|
Indicate if vehicle is equipped with a rechargeable energy storage system |
Battery type and cell chemistry, fuel cell description, etc. |
Battery voltage and energy storage capacity |
|
Advanced technology test mode or modes |
e.g. idle start/stop enable and disable, etc. |
Indicate if vehicle is capable of off-board charging |
|
Other |
Any additional parameters used by the manufactuer to classify advanced technology vehicles. |
Section 13 – Projected sales
Requirements |
Comments |
|---|---|
Projected Canadian sales for each “Canada-unique” test group and evaporative/refueling family combination. |
Please note that the company will still be required to comply with the applicable fleet average requirements and to file an end of model year report no later than May 1 after the end of the model year. |
Section 14 – Request for certification
Requirements |
Comments |
|---|---|
Contains a copy of the written request for a review of the evidence of conformity, signed by an authorized representative of the company. |
Include copy of your cover letter. The request must include the statement of compliance. |
Section 15 –Information specific to HEVs and EVs
Requirements |
Comments |
|---|---|
Any additional information regarding the range, starting and recharging procedures, methods for determining battery performance or control system logic for fuel fired auxiliary heaters. |
Include any applicable information as specified in 40 CFR 86.1844-01(d)(15). |
Section 16 – Exhaust system design
Requirements |
Comments |
|---|---|
A statement that the exhaust system has been designed according the the requirements for leak free operation. |
See 40 CFR 86.1844-01(d)(16) for requirements. |
Section 17 – Name of agent for services of process
Requirements |
Comments |
|---|---|
May reference the correspondence and communications section of your submission. |
|
Section 18 – Vehicle emission control information (VECI) label
Requirements |
Comments |
|---|---|
An image or drawing of the VECI label as it will appear once affixed to the vehicle. |
VECI label requirements are included in Appendix G of this document. Manufacturers may also include a diagram identifying the location of the VECI label on the vehicle. |
Appendix G - VECI label requirements
A sample drawing or copy of the Vehicle Emission Control Information (VECI) label must be included in the submission of evidence of conformity for all vehicles that are imported into, or manufactured in Canada and must contain the information provided in this section. The technical information presented on the VECI label should be in English and the compliance statement must be in English and French. The technical information required on the VECI label is consistent to that listed in section 35 of the ORVEER, which references §1807 of Title 40, chapter I, subchapter C, part 86, subpart S, of the of the CFR.
- A permanent, legible label must be affixed in a readily accessible location. Multi-part labels may be used;
- The label shall be affixed in such a manner that it cannot be removed without destroying or defacing the label, and shall not be affixed to any part which is easily detached from the vehicle or is likely to be replaced;
- The label must be resistant to, or protected against, any weather condition;
- The label must have lettering in block capitals and numerals that are not less than 2 mm in height and must be in a colour that contrasts with the background colour of the label;
- The label must have units that are identified by the appropriate name or symbol;
- The label must contain the following information;
- The label heading shall read: “Vehicle Emission Control Information”;
- Full corporate name and trademark of the vehicle’s manufacturer (optionally, the name of the Canadian importer may also be included);
- Engine displacement;
- Test group, evaporative/refueling family and applicable exhaust emission standards of family emission limit;
- Identification of the exhaust emission control system;
- Minimum fuel octane requirement and engine lubricant requirements; and
- An unconditional statement of conformity: “THIS VEHICLE CONFORMS TO ALL APPLICABLE STANDARDS PRESCRIBED BY THE ON-ROAD VEHICLE AND ENGINE EMISSION REGULATIONS / CE VÉHICULE EST CONFORME À TOUTES LES NORMES QUI LUI SONT APPLICABLES EN VERTU DU RÈGLEMENT SUR LES ÉMISSIONS DES VÉHICULES ROUTIERS ET DE LEURS MOTEURS.” For Type 3 or equivalent if NEM is not affixed.
- Paragraphs (vi) and (vii) may be excluded if the information is in owner’s manual. In such circumstances, the following statement must be on the label “See owner’s manual for tune-up specifications and fuel / lubricant details”.
VEHICLE EMISSION CONTROL INFORMATION
[Company Trademark]
[Company Name]
TEST GROUP: [ΩΩΩΩC####ΩΩΩ]
EVAPORATIVE/REFUELING FAMILY: [ΩΩΩΩPαΩΩΩαΩΩ]
EXHAUST EMISSION CONTROL SYSTEM:
EXHAUST EMISSION STANDARDS: Tier #, BIN ###
ENGINE DISPLACEMENT: [##.#] L
FUEL OR ENGINE LUBRICANT REQUIREMENTS:
ENGINE TUNEUP SPECIFICATIONS AND ADJUSTMENTS:
*THIS VEHICLE CONFORMS TO ALL APPLICABLE STANDARDS PRESCRIBED BY THE ON-ROAD VEHICLE AND ENGINE EMISSION REGULATIONS / CE VÉHICULE EST CONFORME À TOUTES LES NORMES QUI LUI SONT APPLICABLES EN VERTU DU RÈGLEMENT SUR LES ÉMISSIONS DES VÉHICULES ROUTIERS ET DE LEURS MOTEURS
*If the NEM is affixed, there is no need for the statement of compliance.
Where:
α: are alpha fields
#: are numeric fields
Ω: are alphanumeric fields
Appendix H - Consolidated naming convention for durability groups, test groups and evaporative/refueling family names
The EPA guidance letter CD-17-10 outlines how to create a test group name, evaporative/refueling family name and durability group name. Vehicles are grouped into test groups based on expected similar emission characteristics, as described in section §1827, 1821 and 1820 of Title 40, chapter I, subchapter C, part 86, subpart S, of the of the CFR .
Durability group name
Position |
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
Code |
Model Year |
EPA or ECCC 3-character manufacturer code |
Combustion Cycle Code |
Engine Type Code |
Fuels Used (8 and 9 are for Second and Third Fuels Used) |
Manufacturer Assigned Character to create a unique group name or Manufacturer Assigned Battery Code if applicable |
Manufacturer Assigned Character to create a unique group name or Manufacturer Assigned Catalyst Code if applicable |
|||||
Position 1: Model Year Codes
Use the list below to select the appropriate model year code for the durability group name.
- A – 2010
- F – 2015
- L – 2020
- S – 2025
- Y –2030
- 5 –2035
- B – 2011
- G – 2016
- M – 2021
- T – 2026
- 1 –2031
- 6 –2036
- C – 2012
- H – 2017
- N – 2022
- V – 2027
- 2 –2032
- 7 –2037
- D – 2013
- J – 2018
- P – 2023
- W –2028
- 3 –2033
- 8–2038
- E – 2014
- K – 2019
- R – 2024
- X –2029
- 4 –2034
- 9–2039
Positions 2-4: EPA 3-character manufacturer code
Insert the 3-character alphanumeric EPA manufacturer code assigned to your company. If your company does not have an assigned EPA manufacturer code, please contact Environment and Climate Change Canada at the contact information found within this document.
Position 5: Combustion Cycle Code
The following list includes position 5 code descriptions for durability group names.
- 2
- Otto Cycle – two stroke
- G
- Otto Cycle – four stroke
- A
- Diesel Cycle – two stroke
- D
- Diesel Cycle – four stroke
- E
- Dedicated Electric
- H
- Hybrid Electric with Otto Cycle – four stroke engines (includes PHEVs)
- J
- Hybrid Electric with Diesel Cycle – four stroke engines (includes PHEVs)
- C
- Fuel Cell
Position 6: Engine Type Code:
The following includes position 6 code descriptions for durability group names.
- P
- Piston
- R
- Rotary
- E
- Electric (including fuel cell)
- H
- Hybrid Electric (including PHEV)
- A
- Other
Position 7, 8 and 9: Fuels Used
See below for code descriptions to identify types of fuels used. Position 7 refers to the primary fuel used for the durability group. Positions 8 and 9 refer to second and third fuels used.
- G
- Gasoline
- D
- Diesel
- M
- Methanol
- E
- Ethanol
- C
- CNG
- L
- LNG
- P
- LPG
- V
- Electric (from off-board charging)
- I
- Hydrogen
- N
- Not Aplicable (for second or third fuels)
Position 10: Manufacturer Specific Character
The character in position 10 are reserved for a manufacturer specific code used to creat a unique durability group name. If applicable, manufacturer may specify a character to identify an Assigned Battery Code.
Position 11 and 12: Manufacturer Specific Character
The characters in position 11 and 12 are reserved for a manufacturer specific code used to create a unique durability group name. If applicable, manufacturer may specify characters to identify an Assigned Catalyst Code.
Test Group Name
Position |
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
Code |
Model Year |
EPA or ECCC 3-character alphanumeric manufacturer code |
Industry Sector Code |
Engine Displacement or Family Type Descriptor |
Manufacturer's self-designated code to identify a unique family name. |
|||||||
Position 1: Model Year Codes
Use the list included with durability group position 1 to select the appropriate model year code for the test group name.
Positions 2-4: EPA 3-character manufacturer code
Insert the 3-character alphanumeric EPA manufacturer code assigned to your company. If your company does not have an assigned EPA manufacturer code, please contact Environment and Climate Change Canada at the contact information found within this document.
Position 5: Industry Sector Codes
For Light-Duty Vehicles and Light-Duty Trucks/Medium Duty Passenger Vehicles, the industry sector code is “J” as per EPA guidance letter CD-17-10. Alternatively the industry code “T” can be used for Light-Duty Trucks or “V” for Light-Duty Vehicles.
Positions 6-9: Engine Displacement
Insert the applicable engine displacement for each engine family. Engine displacement units must be in Liters (##.# or .###) .
Positions 10-12: Sequence Characters
Enter any combination of valid characters in positions 10 through 12 in order to provide a unique identification for a test group name. At a minimum, the sequence characters, in combination with the other characters in the test group name, must provide a unique identifier for each test group name for a manufacturer for each model year. Further, it is recommended that numbers and letters be selected that minimize possible confusion. The sequence characters themselves could be used to represent other information such as the applicable EPA or California emission standards, however Environment and Climate Change Canada will treat these as simple sequence characters with no additional meaning.
Evaporative/Refueling Family Name
Position |
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
Code |
Model Year |
EPA or ECC 3-character alphanumeric manufacturer code |
Industry Code |
Total evap canister working capacity in grams. |
Manufacturer's self-designated code for this permeation family |
|||||||
Position 1: Model Year Codes
Use the list provided with durability group names to select the appropriate model year code for the evaporative/refueling family name.
Positions 2-4: EPA 3-character manufacturer code
Insert the 3-character alphanumeric EPA manufacturer code assigned to your company. If your company does not have an assigned EPA manufacturer code, please contact Environment and Climate Change Canada at the contact information found within this document.
Position 5: Industry Sector Codes
For Light-Duty Vehicles and Light-Duty Trucks/Medium Duty Passenger Vehicles, the industry sector code is “R” as per EPA guidance letter CD-17-10.
Positions 6-9: Canister Total Working Capacity in Grams
The total working capacity of all evap canisters installed on the vehicle, reported in grams.
Positions 10-12: Sequence Characters
Enter any combination of valid characters in positions 10 through 12 in order to provide a unique identification for an evaporative/refueling family name. At a minimum, the sequence characters, in combination with the other characters in the evaporative/refueling family name, must provide a unique identifier for each evaporative/refueling family name for a manufacturer for each model year. Further, it is recommended that numbers and letters be selected that minimize possible confusion.
Examples
Test Group:
- JXYLV03.5ABC = Company XYL has a 2018 model 3.5L light duty vehicle
- J = 2018 model year
- XYL = EPA manufacturer code for XYL corporation
- V = Light-Duty vehicle
- 03.5 = engine displacement of 3.5 L.
- ABC = 3-character code which uniquely identifies the engine family name
Evaporative/Refueling Family:
- JXYLR0120DEF = Company XYL has a 2018 light-duty evaporative/refueling family with 120 g total working capacity
- J = 2018 model year
- XYL = EPA manufacturer code for XYL corporation
- R = Light-Duty evaporative/refueling family
- 0120 = 120 grams total working capacityDEF = 3-character code which is used by the manufacturer to uniquely identify the evaporative/refueling family name
Appendix I - Example of a statement of compliance letter for Canada unique advanced technology vehicles
[Company Name]
[Insert Date]
Director, Transportation Division
Energy and Transportation Directorate
Environment and Climate Change Canada
351 St. Joseph Blvd.
Gatineau, Québec, K1A 0H3
Subject: Submission of Evidence of Conformity pursuant to the On-Road Vehicle and Engine Emission Regulations (ORVEER) and the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations (PALTGGER) for 20XX model year [Vehicle Make and Model] (Test Group: [Test Group Name]).
Dear Director:
[Company Name] intends to sell a 20XX model year [Vehicle Make and Model], in Canada. Evidence of conformity is being submitted as per [Subsection 35(1.1) OR Section 35.1 OR Section 36] of the ORVEER. The subject vehicle model [Is Covered OR Is Not Covered] by a certificate of conformity issued by the U.S. Environmental Protection Agency[ONLY FOR 35.1: , but it may be considered equivalent to a vehicle listed on a valid EPA certificate (attached), as per section 19.1 of the ORVEER].
Standards to which the vehicle conforms
Exhaust emission standards & useful life
LD[XX] Tier[X] (Bin Y) – XXX,XXX miles
[ONLY FOR 35.1: The equivalent vehicle has the same emission control features as the vehicle tested to obtain the EPA certificate and has no features that could cause it to have a higher level of emissions than that certified vehicle.]
The above mentioned [Vehicle Model] is an advanced technology vehicle and is equipped with a(n) [HEV, PHEV, EV, FCV] propulsion system. [Company Name] attests that all vehicles of this Test Group comply with all applicable standards set out in the On-Road Vehicle and Engine Emission Regulations and the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations made under the Canadian Environmental Protection Act, 1999. Attached, please find [Company Name]’s evidence of such conformity, including a detailed description of the subject Vehicle.
[Company Name] also attests that the vehicles of this test group are manufactured to the same specifications as those set out in the evidence of conformity and will be affixed with an appropriate vehicle emission control information label.
[Company Name] requests that Environment and Climate Change Canada acknowledge that the attached evidence of conformity has been obtained and produced in a form and manner satisfactory to the Minister.
As the signatory of this letter, I, [Name], certify that I am authorized to act on behalf of [Company Name] concerning the 20XX [Vehicle Model]. Should you have any questions in regard to the information provided, please contact [Name, Position and Company Name].
[Parts (as listed)] of the information supplied in this package is classified as confidential.
[Signature]
[Insert Name]
[Position]
[Contact Information]
Encl.
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