Enforcement of EPA Requirements on Vessel Importation

EPA enforcement is becoming a more prevalent issue for vessels importing into the US. This has been in the regulations for a while but has rarely been enforced. Before a few weeks ago we had only been asked 2 or 3 times in 15 years for the EPA conformity of the engines in a boat.

Within the last month Customs has started requesting this on a regular basis and in Miami, Customs is requiring the WPA 3520-21 Engine declaration form be submitted at the time the importation is filed or they will not accept the entry. It requires proof that a vessel’s engines are EPA compliant for the year they were manufactured. In most cases it is not too hard to get a manufacturer to get the information that is required if you have the serial number of the motor. Some motors, especially the newer ones, actually have the EPA compliance stickers or plates on the motor itself. This is helpful as it has all the relevant information required.

As a favor to yourselves and your clients we recommend that you start having your surveyors look for this information and take pictures of the EPA stickers/plates as part of the valuation survey. We wanted to share this information with all of you, as we suspect that with the new Customs enforcement minded system that they have recently put into place called ACE, we will be seeing this as the new normal throughout the US in the not too distant future.

Howard S Reeder Inc