Under the current AEPA, ‘the modification of major contents of the certification shall be subject to modification certification.’ However, the current Enforcement Regulations of AEPA specify that ‘if the modification of major item does not cause the emissions to increase, it shall be reported… In this case, the modification certification… shall be regarded as granted’. Accordingly, if the vehicle manufacturer does not report any modification judging that it does not cause the emissions to increase, he/she may be subject to criminal punishment, which is excessively severe for a minor offense.
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