Owner`s manual
40
Miscellaneous
Replacement Engine Reminder
This is a reminder when replacing an engine you must
check to see if the original engine is emission compliant.
When re-powering a piece if equipment, it is required by
U.S. law that a compliant engine be used if the original
engine was EPA or CARB compliant.
The information regarding whether an engine is compliant
or not can be found on the engine information tag located
on the engine. Replacement engines, short blocks, and
compliance component parts can be found in any of the
engine parts look up formats.
When a non-compliant engine (PX engine) is used as a
replacement it is required that the engine be registered.
This card can be found in an envelope attached to the
box. Complete the card with the information found on both
engine ID labels and return it to Kohler using the postage
paid card.
On engines that are not emissions compliant, a suitable
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replacement. If none exists, then a non-compliant engine
can be considered.
There is also a card that comes with non-
compliant engines. It is found inside the box.
This card should be completed and retained for
two years.
Emissions Compliant
Replacement
April 17, 2007
TO: All Servicing Dealers
RE: Sale of Replacement Engines
This is a follow up to a letter that was sent several years ago as a reminder of the responsibility as an
engine manufacturer, Central Distributor, and Servicing Dealer when selling uncertified engines as
replacements.
The U.S. EPA and the California Air Resources Board (CARB) allow the sale of engines that do not
comply with the current emission regulations as “replacement engines” provided that:
1. The engine manufacturer has ascertained that no engine that would comply with the
applicable regulations is available with the appropriate physical or performance characteristics
to repower the equipment; and
2. The engine manufacturer or its agent takes ownership and possession of the engine being
replaced or renders it inoperative; and
3. The replacement engine is clearly labeled with language approved by the regulatory agencies
stating that it is a replacement engine and that is all it can be used for.
The European Union also allows the sale of replacement engines as long as the engine complies with
the emission standards that the engine being replaced had to meet when originally placed on the
market. The engine needs to be labeled as a replacement engine.
These “replacement engines” cannot be sold for use by an OEM in the production or manufacture of
any new product. They are only to be used to satisfy service requirements.
Following are details intended to clarify what Kohler Co. is doing to comply with the requirements for
sale of non-certified “replacement engines” and what we need from Central Distributors and Servicing
Dealers.
1. PX Prefix and Record Keeping - All engines produced by Kohler Co. as basic service or
replacement carry a PX designation prior to the specification number. The engine ID nameplate states
that these engines are to be sold for export (to countries that do not have emission regulations) or
replacement purposes only.
Note: OEMs who manufacture outside the U.S. and sell finished goods back into the United
States, Canada, or the European Union must use compliant engines.
Kohler has implemented a program to satisfy the regulatory guidelines by attaching a tag to the spark
plug and applying a plastic envelope with a postage-paid reply card enclosed to the exterior of each
engine carton. Both cards ask for model and specification information of the replacement engine and
the engine being replaced. It also asks for the date the engine being replaced was rendered
inoperative. The postage-paid card is to be returned to Kohler for our records, and the tag is to be
retained at the dealership for a recommended two-year time frame, in case the regulatory agencies
Letter Regarding Compliancy