Submission requirements for evidence of conformity for light-duty vehicles: chapter 5


5.0 Administrative Information

5.1 Who Should Present Evidence of Conformity?

The company that seeks to import or offers for sale a vehicle or apply a national emission mark is responsible for submitting the evidence of conformity to the Regulations as required under sections 35 and 36.

When equivalent vehicles are imported or offered for sale by two different companies, the evidence of conformity has to be submitted by each company. Both companies need to submit a compliance letter and the proper evidence of conformity. However, instead of submitting the information twice, both letters of compliance may reference the information submitted by only one of the two companies and indicate that a copy of the letter has been sent to the other company. It is each company's responsibility to ensure compliance with all applicable sections of the Regulations such as national emission mark requirements, fleet average NOx requirements, end-of-model-year reports, maintenance of records, etc. Regarding evidence of conformity, subsections 38(2) and (3) of the Regulations states that:

38. (1) A company shall maintain, in writing or in a readily readable electronic or optical form

  • (a) the evidence of conformity referred to in paragraphs 35(1)(a) to (c) and section 36 and records referred to in paragraph 153(1)(g) of the Act for a period of
    • (i) at least eight years after the date of manufacture, for engines and vehicles, other than motorcycles…

(2) If the evidence of conformity and records referred to in subsection (1) are maintained on behalf of a company, the company shall keep a record of the name and street address and, if different, the mailing address of the person who maintains those records.

(3) If the Minister makes a written request for the evidence of conformity or the records referred to in subsections (1) and (2), or a summary of any of them, the company shall provide the Minister with the evidence of conformity, records or summary, in either official language, within

  • (a) 40 calendar days after the request is delivered to the company; or
  • (b) if the evidence of conformity or records referred to in section 35 or 36 must be translated from a language other than French or English, 60 calendar days after the request is delivered to the company.

5.2 Where Should Evidence of Conformity Be Sent?

Submit the evidence of conformity to the Regulations, in either English or French, in paper copy or electronically, to the addresses that follow:

Electronic versions

The electronic documentation must be in PDF or Microsoft Office format. It should be sent to Emission-Verification@ec.gc.ca with a case specific subject line:

  • To submit a submission for a Canada-unique vehicle under section 36 of the Regulations (Type 1, 2 or 3):

    "Canada-unique submission - Name of Company - ECA # (once assigned)"
  • To submit a submission to demonstrate that a vehicle should be considered deemed covered by an EPA certificate under section 4 of the Regulations:

    "Deemed covered submission - Name of Company ECD # (once assigned)"
  • To submit a submission for a vehicle that falls under section 35 of the Regulations (when requested):

    "Confirmatory testing submission - Name of Company - EC200X-XXX"

Paper copies

Paper copies should be sent to:

Director
Transportation Division
Energy and Transportation Directorate
Environment Canada
351 St. Joseph Blvd.
Gatineau, QC K1A 0H3

5.3 Response From Environment Canada

Environment Canada will send acknowledgements to the manufacturer or the importer when evidence of conformity is received and considered to be "in a form and manner satisfactory to the Minister" based on the elements discussed in this document. The acknowledgement that "form and manner" are satisfactory to the Minister does not relieve the company of the obligation to comply with the Regulations and the Act.

In cases where a company is submitting applications for more than one test group, it would be helpful if it stated the order in which it would prefer EC to process them.

When a company submits information for a test group for which an identical submission was received and acknowledged by Environment Canada the previous year, the company should notify Environment Canada that the submission is a direct carry-over (identical to the preceding year) to facilitate and accelerate the process.

Environment Canada will strive to respond to submissions according to the timelines shown in Table 3, but incomplete submissions may cause delays beyond the dates given in the table. When information is found to be missing and Environment Canada is waiting to receive additional information from a company, that wait time is added to the processing time listed below.

Table 3. Environment Canada response time for submissions of evidence of conformity to the On-Road Vehicle and Engine Emission Regulations
Type of vehicle Environment Canada's turnaround time when COMPLETE information is provided
Section 35 Specifically listed on an EPA certificate (section 19 and 35)
  • Information receipt: 15 calendar days after date of reception
Deemed covered by an EPA certificate (section 4)
  • Info provided for "deemed covered" satisfactory: 20 calendar days after date of reception
Section 36 Type 1 - Specifically listed on an EPA certificate
  • Form and manner are satisfactory to the Minister: 15 calendar days after date of receptionn
Type 2 - Deemed covered by an EPA certificate
  • Form and manner are satisfactory to the Minister: 20 calendar days after date of reception
Type 3 - Neither specifically covered nor deemed covered by an EPA certificate
  • Information receipt: 15 calendar days after date of reception
  • Form and manner are satisfactory to the Minister: 60 calendar days after date of reception

 

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