EPA’s New ERT Requirements for IC Engine Testing: Your Guide to Compliance

As environmental regulations continue evolving, new electronic reporting requirements are being introduced for emissions testing of internal combustion engines. Electronic reporting, such as reporting done utilizing the EPA’s Electronic Reporting Tool (ERT), has become an essential part of emissions testing and compliance reporting, ensuring that information is standardized, transparent, and accessible to regulatory agencies like the EPA. By streamlining data collection, ERTs enhance the ability to enforce air quality standards and provide a clearer picture of compliance across industries. According to a study from the EPA, over 85% of facilities that adopted ERTs reported quicker turnaround times for regulatory approvals and a significant reduction in data errors. ERTs will play a growing role in emissions monitoring, especially as the EPA expands its digital reporting requirements. Starting February 26, 2025, new mandates will require ERT submissions for specific emissions test results under the following regulations: 

• 40 CFR Part 60 Subpart JJJJ – Stationary Spark Ignition Internal Combustion Engines 

• 40 CFR Part 60 Subpart IIII – Stationary Compression Ignition Internal Combustion Engines 

• 40 CFR Part 63 Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines 

Expanded ERT Submission Requirements 

The upcoming changes require facilities to use the ERT or an alternative electronic format that meets specific compliance standards for internal combustion engine emissions testing. The following sections outline the new submission protocols in detail. 

ERT-Supported Test Methods 

For 40 CFR Part 60 Subpart JJJJ, 40 CFR Part 60 Subpart IIII, and 40 CFR Part 63 Subpart ZZZZ, any test method the EPA’s ERT supports at the time of testing must be submitted using an ERT-generated file format. This requirement ensures that emissions testing data is reported in a structured, digitized format, allowing regulatory agencies to analyze compliance trends efficiently. 

Non-Supported Test Methods 

For emissions test methods not supported by the EPA’s ERT, the data must be submitted as either: 

• An attachment within the ERT, or 

• An alternative electronic file format, as specified in the rule. 

These provisions allow facilities flexibility in submitting test results that cannot be directly integrated into the ERT but still must comply with electronic reporting requirements. 

Electronic Submission Timeline & Compliance Deadlines 

Under the new requirements, all electronic reports must be submitted to the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI) within 60 days following the completion of emissions testing. CEDRI serves as the centralized platform for emissions test report submissions, aligning with the EPA’s broader efforts to transition regulatory compliance data to digital platforms. 

ERT Reporting Time Considerations 

Facilities preparing for these changes should account for the additional time required to complete ERT submissions, as the time for preparing and submitting an ERT report may vary depending on the complexity of the test program.  

Additionally, impacted facilities that do not yet have a CEDRI account should: 

• Register on the EPA’s Central Data Exchange (CDX) platform 

• Set up a CEDRI account 

• Establish a role as “Certifier” or “Delegated Certifier” in CEDRI 

By registering with CDX and CEDRI in advance of the new regulation start date, facilities can avoid the stress of the registration process time lag.  

Looking Ahead 

These new electronic reporting requirements mark a shift in how emissions testing data is submitted for internal combustion engines. The transition to mandatory ERT submissions reflects the EPA’s push for greater data transparency and efficiency in emissions monitoring. As digital compliance tools like the ERT become more prevalent, facilities must adapt to these evolving standards to maintain regulatory compliance and avoid potential enforcement actions. 

For additional resources, refer to: 

• EPA Electronic Reporting Tool (ERT) Overview: https://www.epa.gov/ert 

• EPA Central Data Exchange: https://cdx.epa.gov

• Compliance and Emissions Data Reporting Interface (CEDRI): https://www.epa.gov/cedri 

• 40 CFR Part 60 and Part 63 Regulations: https://www.ecfr.gov 

By staying informed and proactive, industry professionals can ensure a smooth transition to the new reporting requirements while maintaining compliance with evolving environmental regulations. 

Do you need assistance navigating the new ERT requirements? We’re here to help ensure your compliance with these new regulations.