EPA Kit Car Policy
The production, sale and importation of automotive bodies alone (i.e., no chassis, engine or transmission) are not regulated by EPA since such units are not considered “motor vehicles” under the Clean Air Act. EPA form 3520-1 is not required for imported automotive bodies. A motor vehicle from which the engine has been removed is still a motor vehicle and is not considered a body.
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.
“Motor vehicles” must comply with the Clean Air Act and may not be disassembled nor purchased in a disassembled form for the purposes of evading the Clean Air Act or the Imports regulations.
http://www.epa.gov/otaq/imports/kitcar.htm
