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Title : Greenhouse Gas Phase 2 Regulatory Compliance Implementation
Applies To : Cummins® and International® Engines Built After January 1, 2021

CHANGE LOG
Please refer to the change log text box below for recent changes to this article:
01/26/2026 - Updated Certificates and branding. Removed multiple VIN request
09/30/2025 - Updated Change Request Form and added link to form instructions.
06/18/2024 - Clarified info under "Process". Added clarification for Neutral at Coast and Neitral at Idle/Stop
03/28/2023 - Updated new form and work instructions
02/15/2023 - Update new form to REV 9
03/30/2022 - Updated change request documents

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DESCRIPTION
This document provides guidance for assessing the feasibility of implementing a customer-requested change to an engine or vehicle parameter/feature. Customer
requested changes will be approved in accordance with the requirements specified in 40 CFR Part 1037 to ensure continued compliance with greenhouse gas
(GHG) regulations.

Scope
These instructions apply to all Class 2B to Class 8 vehicles and engines for which GHG phase II requirements are applicable. These
requirements became applicable starting with model year 2021 and are applicable to all later model years including new vehicles and
engines.
Background
U.S. EPA 40 CFR Part 1037 – CONTROL OF EMISSIONS FROM NEW HEAVY-DUTY MOTOR VEHICLES defines Phase 2 GHG
regulations. To comply with these regulations, the engine must meet specific standards based on the emissions of Carbon Dioxide,
Methane, and Oxides of Nitrogen (NOx). In addition, a profile of the GHG emissions for each vehicle sold under Phase 2 is calculated
using the specific engine performance characteristics along with the specific vehicle characteristics, some of which are identified on the
Vehicle Emissions Control Information (VECI) label on the vehicle. (Refer to the VECI label for a list of emissions reduction components.
For further information, please review the vehicle operator’s manual.)
Vehicles manufactured by International Motors, LLC. have been built to comply with all applicable vehicle emissions standards.
Modifications to the vehicle that will cause noncompliance are prohibited by regulations. Additionally, records of actual vehicle
configurations and their GHG profile are kept, and they must be updated as changes are made in order to maintain their accuracy.
Changes can affect the GHG emission profile or the classification of a vehicle. The profile of the GHG emissions for each vehicle is
calculated from specific engine and vehicle characteristics using the Greenhouse Gas Emissions Model (GEM). Classification of the
vehicle affects how it is treated by GEM and determines the GHG emission standard against which the GEM result is compared.
Therefore, International Motors, LLC. must be informed and approve of any relevant desired changes. Unapproved changes may violate
anti-tampering provisions of the Clean Air Act.
Deadline
Requests for changes that may affect GHG compliance or reporting must be submitted no later than September 1 of the year following
the vehicle’s compliance year. This timeline ensures adequate processing and alignment with federal reporting requirements.

SPECIAL TOOL(s) / SOFTWARE
N/A
Tools Resource Center

SERVICE PARTS INFORMATION
N/A

Process
The steps taken depend upon the feature and/or parameter for which a change is desired, and they are detailed in the table below.
The change request form is available in the "Other Resources" section of this document.
"Reporting Period" means until September 1 of the year following the compliance year of the vehicle (e.g. September 1, 2024 for
vehicles of compliance year 2023).
See the Glossary for further description of certain Features/Parameters.
NO CHANGE IS ALLOWED
Feature/Parameter

Notes:

Tire Pressure Monitoring
Systems (TPMS) or
Automatic Inflation
Systems

Units that are built with TPMS (Tire Pressure Monitoring Systems) are not
eligible to have that feature removed from the system as it is an integral part of
the overall safety systems associated with that particular truck. International
Motors, LLC. will not authorize removal of this system.

Load based speed control

This is not a GHG-affecting item but may affect vehicle compliance in other
ways.

APPROVAL REQUIRED
Feature/Parameter

Notes:

Steps to be Completed By
Technician

Automatic engine
shutdown

Tractors: Approval required only when
within the reporting period.

WHERE APPROVAL IS
REQUIRED:

Changes include enable/disable and timer 1. Identify which parameter needs
values.
to be changed

APU removal

Predictive Cruise

Tractors

2. Complete the change request
form

Tractors: Approval required

3. Start a case file with the
programming group requesting the
parameter change

Vocational: Not applicable

Neutral at Coast

See special instructions for Eaton
transmissions below.

4. Attach the completed change
request form to the case file

Neutral at Idle (Neutral at
Stop)

Tire changes or additions

See special instructions for Allison
transmissions below.
(This feature cannot be disabled in trucks
using VISTA (6.6L) engines.)
Includes tires associated with newly
installed axles.

Axle or axle lubricant

Transmission Type

GVWR/GCWR

Certain changes in GVWR or GCWR
impact GHG compliance. The (separate)
GVWR/GCWR change process will
determine if there is an impact, and if so,
this GHG change request process must be
followed.

APPROVED WITHOUT REQUEST
Feature/Parameter

Notes:

Steps to be Completed By
Technician

Automatic engine
shutdown

Tractors: After the reporting period ends, For tractors, approval request must
approved without request.
be submitted if still within the
reporting period (as indicated in
Vocational: Approved without request at the section above).
any time

Low idle speed adjustment Approved without request if within
predefined acceptable adjustment range.
Otherwise, not allowed.

Global vehicle speed limit

Pedal, cruise speed
settings, and droop

These do not affect GHG.

SPECIAL SITUATIONS, INSTRUCTIONS
Feature/Parameter

Notes:

Steps to be Completed By
Technician

Horsepower (HP) Rating
Change

Either case below requires that a change 1. Determine via lineset whether or
request form be submitted.
not the unit has the following
feature code installed: “12WGK
engine re-rate capable.”
Case 1. Vehicles originally sold with
“12WGK” feature code:
2. If yes, or otherwise within
reporting period, proceed with
Change may be made at any time in
completing the change request
vehicle’s life.
form located in the other resources
Case 2. Vehicles NOT originally sold with section of this document, and start
a case file with the programming
“12WGK” feature code:
group.
If approved, change may be made only
3. If approved, the engine
during reporting period.
manufacturer responsible will
schedule the programming and
provide the updated engine label.

Re-rate HP and torque change will
be dependent on chassis
components as well.
Additional charge for re-rate may
be applicable at time of re-rate.
Cummins Engines: A letter of approval will Provide letter of approval to
be issued to Cummins as part of the final Cummins as they will require this
approval package, along with
before changing ECM parameters.
the approved change request form.
Neutral at Coast
Parameter – Eaton

Provide approved change request
form to Eaton as they will require
International Motors, LLC. will provide
assistance for engine parameter changes. this before changing TCM
parameters.
Eaton will log in remotely to change TCM
parameters. (Dealer must have
ServiceRanger installed.)

Neutral at Idle (Neutral at
Stop) Parameter - Allison

Provide special approval letter to
Special letter for Allison will be provided as Allison as they will require this
before changing TCM parameters.
part of approval, in addition to the
approved change request form.

Aerodynamic feature
changes

Special approval required. Changes
Contact International Motors, LLC.
include modification, replacement, or
removal of components such as fairings,
air deflectors, and skirts; or the addition of
externally mounted devices or features.

Weight changes

GHG credit is taken for certain weight
Contact International Motors, LLC.
savings – usually because a lighter
material is used. Features that may be
affected include wheel rim or hub, bumper,
steps, fifth wheel, transmission case, and
clutch housing. Approval may be required
for replacing these items.

Other parameters that affect the overall GEM score such as axle ratios, and tire rpms may still be dealer programmable, but a
completed change request form is still required to complete the process.
U.S. EPA 40 CFR Part 1037 – CONTROL OF EMISSIONS FROM NEW HEAVY-DUTY MOTOR VEHICLES
Vehicles manufactured by International Motors, LLC. have been built to comply with all applicable vehicle emissions standards.
Modifications to the vehicle which will cause
noncompliance are prohibited by regulations. Refer to the Vehicle Emissions Control Information (VECI) label on the vehicle for a list of
Emissions reduction
components. For further information, please review the vehicle operator’s manual.
To comply with the Phase 2 GHG regulations, the engine must meet specific standards based on the emissions of Carbon Dioxide,
Methane, and Oxides of
Nitrogen (NOx). In addition, a profile of the GHG emissions for each vehicle sold under Phase 2 is calculated using the specific engine
performance
characteristics along with the vehicle characteristics, some of which are identified on the VECI label.

Glossary
The following table provides further description of certain features and parameters.

Feature/Parameter

Notes:

Automatic engine
shutdown (AES)

System that shuts down the engine if the vehicle is parked and there is no
activity for a certain amount of time. This may also be known as “Extended
Idle Reduction,” though this term covers other technology besides AES.

Global vehicle speed limit

Maximum limit of vehicle speed allowed by engine controls.

Predictive Cruise

A system that anticipates changes in terrain (e.g. using GPS) to control
operator demand in order to ultimately optimize GHG and fuel economy
during cruise control operation.

Neutral Coast

Controls that automatically shift the transmission into neutral when there is no
load demand from the engine, and the vehicle is still in motion – such as when
it is coasting.

Neutral at Idle (Neutral at
Stop)

Controls that automatically shift the transmission into neutral when the engine
is idling and the vehicle is not in motion, and activation must NOT require
parking brake application.

Auto Neutral

This is a control feature, similar to Neutral at Idle, but requires parking brake
activation. (This does not qualify as a GHG feature.)

Stop/Start

This is a control feature that stops the engine at zero vehicle speed and
restarts it upon detected desire to move (as indicated by lifting the brake or
pressing the accelerator pedal). Not currently offered.

REPAIR STEP(s)
N/A

WARRANTY INFORMATION
N/A

Warranty Claim Coding:
Refer to the Warranty Coding Manual for Group and Noun Codes.

Standard Repair Time(s):
Refer to the SRT Manual for Repair Times

OTHER RESOURCES
Link

Description

Master Service Information Site

Service Portal

G-6527
G-3443

Change Request Form - PDF

Hide Details

Engine Re-Rating Process for Cummins
and International Engines Built After
1/1/2021
New 2022 California Emission Control
Warranty Requirements
Download form and fill it out. See Change
Request Form Instructions for information
about how to properly fill out the
form. Submit filled-out form with new case
attachment - select the programming
group when starting the case file.

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