Buying used European Yacht/ EPA Tier 3

We are a company specialized in aftertreatment , what are you reporting is not yet known to me, but fir sure we have to check quickly. In case, we are working on both sea side in order to comply used engine in USA to EPA III or some in case IV, and in Europe to comply new Engine with IMO Tier III for yacht > 500GT.

Surely if they have standard engines like Cummins or Volvo, these engines have already been rated & this would be available from the USA Main distributor?
I've just bought a Carver in France for shipment back to my county NZ & it has Cummins engines which will be no different from any other Cummins marine engine of the same type.

The EPA is an American organisation. It's rules do not control what the rest of the world can and does do

From the EPA

Nonconforming vehicles and engines can be imported in two circumstances:
By Certification:
Nonconforming vehicles can be imported, if they are modified, tested and certified by an Independent Commercial Importer (ICI).
By Exemption:
EPA regulations also allow nonconforming vehicles and engines to be temporarily imported under United States Customs bond, if they qualify for an EPA exemption. EPA and Customs regulations allow for the temporary importation of nonconforming vehicles with EPA pre-approval for the following purposes:

• Testing
• Display
• Repair or alteration
• Nonresident
• Competition/Racing

PROSPECTIVE IMPORTERS BEWARE! BEFORE shipping a nonconforming vehicle or engine to the United States, importersMUST either:

• make arrangements with an ICI for modifications, testing, and certification, or
• obtain EPA pre-approval for the exemptions listed above.
• Importation of Vehicles Over 21 Years Old - The EPA has long interpreted the equivalence requirement to mean that the engine must be identical to the engine that was originally installed. Such an engine is one that is the same model and configuration as the original engine. Importers wishing to utilize this provision are strongly encouraged to contact the EPA Imports Hotline prior to importation of such vehicles to ensure that the equivalency requirements are met. The Imports Hotline can be reached at imports@epa.gov or 734-214-4100.

Importers are encouraged to read the detailed information on the importation of nonconforming vehicles and engines, which can be found in the Procedures for Importing Vehicles and Engines into the United States.

Also be aware that United States Customs and/or EPA can seize and/or export any goods that arrive at a United States port of entry without the appropriate ICI arrangements or a valid EPA exemption, and can levy other fines and penalties.

Here is a link to form 3520-21 which must be filled out. Note that there are different effective dates based on size and type of engines. For inboards it's model year 2010.

https://www.epa.gov/sites/production/files/2014-06/documents/3520-21.pdf

Note that there is a somewhat similar issue going the other way. All boats imported into Europe must have CE Certification.

Beneteau has an interesting article on buying in Europe for the US. Although written on New Boats, much applies to all. Some people have though bought in Europe, used a year or two and then shipped to the US and all the problems mentioned still apply.

http://www.beneteau.com/us/news/pitfalls-buying-your-new-boat-europe

Ok. So we are looking at a bunch of 2001-2007 80-90ft yachts in Europe. Prices and selection is better. Most are either 3412s or Mtu 12 or 16cyl.

So if I'm reading the doc posted above, anything newer than 2006 on med engines and 2009 on larger engines will need to be tier 3.

So what's the odds on a 2007 predator 82 w 12v MTUs be compliant for example?

I don't think the odds would be very good, but I think it would be far better if you contacted Sunseeker with that question. You could also get a quote from an ICI on making one compliant.

Are your plans to use it in Europe a while before bringing it to the US?

You may want to look carefully at the differences in equipment and set up as well. There are several items included in standard "USA Package"'s that are not necessarily found on Sunseeker's boats sold in Europe.

One thing that you'll find on some brands during that time period, Sunseeker and Riva being two very good examples, is there are just not very many in the US and there are none of some models. So, where you'll see a wide range of prices on those in Europe, you will see a very small selection in the US.

This has been an interesting discussion with significant ramifications. For a compliant EPA 3520-21 form, as I understand it, engines will have to conform to EPA requirements at the date of import, not the date of construction. So, most European yachts will not have EPA compliant engines, and will not be able to secure a compliant form.

Now factor in a repower on any yacht imported into the US that is less than 21 years old or ?

Another angle is to keep I foreign flagged. Most bigger boats seem to be under a U.K. Island nation anyway. There are some limitations but I would think it would get around the EPA issues.

And when I read the EPA guidelines it seems that for the largest marine engines it is 2008 and newer?

Outside chance would be to investigate if an SCR (Selective Catalytic Reduction) Aftertreatment System could be retrofitted at who knows what cost. Would require space and access for maintenance, urea tankage and pumps onboard, and the kicker - testing / validation / certification onboard with an agency or representative there of. Systems typically run up to about 10% of new engine costs, but certification / validation is key, along with the space issue.

EPA Tier 4 looms on the horizon for all Commercial Marine vessels with engines over 805hp as of 2017, which can ONLY be satisfied with SCR Aftertreatment Systems, so maybe the technology / size / application will become mainstream for all boats and we could see a reduction of costs and size. Hopefully, they can become part of the exhaust silencer with the necessary maintenance access and urea injection point.

U.S. Recreational boats are currently in the EPA Tier 3 level for the seen future, BUT, it gets more complicated with what are called ECA (Emission Control Areas), which is essentially the entire North American Coast out to 200nm. This is where IMO III kicks in, and the games between International and American regulatory agencies will take place. https://www.dieselnet.com/standards/inter/imo.php

ECA Zones will most likely require IMO III, which is the near equivalent of EPA Tier 4, which requires SCR Aftertreatment, etc. Not sure at the moment if this will flow down to U.S. Recreational craft, but certainly for large yachts that charter.

If they are the exact same make and model of engines that met EPA guidlines in the US at the same time, you should be able to get a letter from the engine manufacturer stating that.

What time frames are you talking about - time of title in a foreign country or time of import to US?
These dates could cover a number of years as highlighted in the discussions, even spanning two different EPA Emission levels. No engine manufacturer can provide a legal certificate in that case.