General approach:

• Set clear definitions & retrofit principles;
• Split engine retrofit from vehicle retrofit with an approved engine;
• Ensure fair competition among all the manufacturing routes (“in-line” and “off -line” before registration and after-registration) and do not generate loopholes (no relaxed routes to certification);
• No ambiguity regarding liability, responsibility and branding:

• - The retrofitter becomes new engine manufacturer;
• - The engine becomes a new engine-type with a new approval number

Possibilities for next regulatory actions:

• Retrofit Emissions Control system process (REC) – dedicated to emissions control devices
• Amend R.115: challenge to introduce major revisions for HDVs in regulation that has been based on LDVs
• Create a new regulation (their preferred option)

• - New structure
• - Not limited to gas retrofits
• - Consistency with other regulations (w/R.83 vs R.49+REC+other) but much more complex administratively