awatkins Posted July 22, 2021 Share Posted July 22, 2021 No. I’ve never heard of an SB100 engine needing to meet any federal standard when the car in question is listed as a replica of (in this case) a Lotus Seven, because when Lotus Sevens were made there were no federal emission standards. The whole point of SB100 is that you are registering a replica of a vehicle from before there was significant smog control, as you should have stated in your application and hopefully on the MSO. For example, If you state (as I and my MSO did) “replica of 1966 Ford GT40” then your engine needs to meet only the CA standards in effect in 1966 (which was having a PCV system). There are no engine stickers involved. The fundamental question is: how exactly has your car been described in your application and on your MSO? It should say “replica of <year> <make> <model>“. So please tell us what it says for those three fields. Link to comment Share on other sites More sharing options...
KnifeySpoony Posted July 22, 2021 Share Posted July 22, 2021 My MSO from Caterham (a 420R that was ordered in May 2020, and shipped Dec 2020) states it is a 2019 Caterham... Link to comment Share on other sites More sharing options...
awatkins Posted July 22, 2021 Share Posted July 22, 2021 (edited) KnifeySpooney -- Is yours registered under SB100 in California? If so where exactly (in which field) on the MSO does it say that? In particular, what does it say in the "year" field, the "make" field, and the "model" field? Edited July 22, 2021 by awatkins Link to comment Share on other sites More sharing options...
rnr Posted July 22, 2021 Share Posted July 22, 2021 My SB-100 Stalker MSO said "Replica/ Facsimile of circa 1962 Lotus 7" Link to comment Share on other sites More sharing options...
TomSalter Posted July 22, 2021 Author Share Posted July 22, 2021 So, I think they're following the letter of the law of this: https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100AKFO.pdf Which yeah, doesn't sound great for the engine if you don't have an emissions label. However, specific to kit cars: https://www.epa.gov/importing-vehicles-and-engines/kit-car-policy Point 4 there should see me through, as I read this. The sub-bullet there is absolutely appropriate for the EPA/local DMV to have concerns on this, if some importers are importing complete vehicles and mis-representing it. But for the majority of our cases where they are privately built, they should be fine. -Tom Link to comment Share on other sites More sharing options...
KnifeySpoony Posted July 22, 2021 Share Posted July 22, 2021 19 hours ago, awatkins said: KnifeySpooney -- Is yours registered under SB100 in California? If so where exactly (in which field) on the MSO does it say that? In particular, what does it say in the "year" field, the "make" field, and the "model" field? I am only just beginning the SB100 process. It says: Make: Caterham Model: Seven Model year: 2019 Which is interesting as I rec'd the kit in 2021. Link to comment Share on other sites More sharing options...
BMW RACER Posted July 23, 2021 Share Posted July 23, 2021 (edited) 1 hour ago, KnifeySpoony said: I am only just beginning the SB100 process. It says: Make: Caterham Model: Seven Model year: 2019 Which is interesting as I rec'd the kit in 2021. KnifeySpoony. Good luck with your SB100. It's not been good for Caterhams in California post Covid. It seems to go fine until you get to the Referee Station visit. We're all puling for you. Please update us on your experiences. Edited July 23, 2021 by BMW RACER Add verbiage Link to comment Share on other sites More sharing options...
awatkins Posted July 23, 2021 Share Posted July 23, 2021 (edited) Tom -- Really important question: did the BAR people point you to those documents? If not, why do you think they are related to your situation? KnifeySpooney — Please read this text from the ARB web site at (https://www.arb.ca.gov/msprog/aftermkt/spmv_test.htm): ”SB 100 allows up to 500 specially constructed vehicles per year to be assembled and registered for on-road use, the individual builder/owner is given the option to choose the vehicle’s make and model year based on the representation of how the vehicle looks or its engine configuration. These vehicles are exempt from the state’s smog check requirements” [underlining mine] “How the vehicle looks” should have been written as “what year car it replicates”. Given the above, the fact your MSO does not describe your car as a replica of a pre-70s Lotus or Caterham dumps you out of SB100. You should go back to Caterham or your dealer and get a correct MSO before proceeding. Edited July 23, 2021 by awatkins correction Link to comment Share on other sites More sharing options...
TomSalter Posted July 23, 2021 Author Share Posted July 23, 2021 Alan, verbally the ARB told me that it’s the next step. Otherwise my car is recognized as a specially constructed vehicle, but they wanted the car itself to have the EPA sticker, which it does not. That EPA page states the special situations where the Clean Air Act does not apply to these vehicles, hopefully allowing the car through. Link to comment Share on other sites More sharing options...
awatkins Posted July 23, 2021 Share Posted July 23, 2021 Which exact EPA text do you see as stating special situations where the Clean Air Act does not apply? Link to comment Share on other sites More sharing options...
TomSalter Posted July 23, 2021 Author Share Posted July 23, 2021 Section 4 - that a vehicle imported as a collection of parts does not require an EPA Emissions label. That’s my understanding at least…! Link to comment Share on other sites More sharing options...
awatkins Posted July 23, 2021 Share Posted July 23, 2021 (edited) "The production, sale and importation of vehicle parts (engines, transmissions, chassis, vehicle bodies, etc.) are not regulated by EPA because parts are not considered motor vehicles under the Clean Air Act. However if the parts constitute a disassembled vehicle or an approximate disassembled vehicle, the combination is considered a motor vehicle under the Clean Air Act. Any attempt to use this policy to circumvent the Clean Air Act or the Imports regulations will be considered a violation of the Clean Air Act and will be strictly enforced. An example of such circumvention is: A kit car maker who also provides the engine and transmission before or after production/importation of the body/chassis." Referring to the part starting with "However": they are saying that a collection of parts that could be assembled into a vehicle is a vehicle under the CAA. A Caterham kit is just such a collection of parts. The first sentence means "if you import an engine alone that is a part, not a car." "if you import a transmission alone, that is a part, not a car".... etc. The next sentence means "If you import a box containing an engine and transmission and chassis and body and all the other stuff you need in order to make a car, it's a car." This is what they meant in the text in your first post: "They [Caterham] are bypassing customs, EPA, and CARB regulations by shipping the vehicle in parts" Edited July 23, 2021 by awatkins Link to comment Share on other sites More sharing options...
KnifeySpoony Posted July 24, 2021 Share Posted July 24, 2021 I thought buying the drivetrain from a different company on a different invoice helps to circumvent that issue? Link to comment Share on other sites More sharing options...
TomSalter Posted July 24, 2021 Author Share Posted July 24, 2021 Yeah, that’s what my interpretation of that EPA Kit Car Policy is. But for all of these, you have to point to the specific line item in the CA DMV/ARB/BAR regulations… waiting to hear back from the ARB now on my case, as they said it needs the EPA sticker. Link to comment Share on other sites More sharing options...
awatkins Posted July 24, 2021 Share Posted July 24, 2021 “I thought buying the drivetrain from a different company on a different invoice helps to circumvent that issue?” Which issue are you referring to? Link to comment Share on other sites More sharing options...
KnifeySpoony Posted July 24, 2021 Share Posted July 24, 2021 44 minutes ago, awatkins said: “I thought buying the drivetrain from a different company on a different invoice helps to circumvent that issue?” Which issue are you referring to? The next sentence means "If you import a box containing an engine and transmission and chassis and body and all the other stuff you need in order to make a car, it's a car." Link to comment Share on other sites More sharing options...
awatkins Posted July 24, 2021 Share Posted July 24, 2021 There are two different sets of laws in this discussion: California SB100 which says you can register a self-built replica of something originally made before around '68 but you have to buy the engine from a different business than the one that sold you the chassis (or kit), and if you do that it needs to comply only with pre-72 emission laws, which require nothing but a PCV. Federal Clean Air act. It says among other things that you can't play games by pretending an engine in one box and a chassis or kit in another is not really a whole car. Link to comment Share on other sites More sharing options...
TomSalter Posted July 24, 2021 Author Share Posted July 24, 2021 It would be really helpful for each of these if you could point to the relevant ARB / BAR / EPA / DMV documentation Link to comment Share on other sites More sharing options...
awatkins Posted July 24, 2021 Share Posted July 24, 2021 The EPA docs came from you. The others are scattered and I don’t know any particular links off hand. Most of my SB100 knowledge is in my head from doing it years ago. Just Google kit car, replica, SB100, Special construction, etc. Link to comment Share on other sites More sharing options...
awatkins Posted July 24, 2021 Share Posted July 24, 2021 Here is an old but good treatment of how to get through SB100: http://www.clubcobra.com/forums/bay-area-cobra-club/101739-sb100-conference-mustang-ranch.html#post1013652 Orher good sources are the club cobra, GT40s.com, factory five, etc forums. Link to comment Share on other sites More sharing options...
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now