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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:
04/22/2026 - Updated form link
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

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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
because 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 values.

1. Identify which parameter

needs to be changed.
2. Complete the change

APU removal

Tractors

request form.
3. Start a case file with the

Predictive Cruise

Tractors: Approval required
Vocational: Not applicable

programming group
requesting the parameter
change.
4. Attach the completed

change request form to the
case file.

Neutral at Coast

See special instructions for Eaton
transmissions below.

Neutral at Idle (Neutral See special instructions for Allison
at Stop)
transmissions below.
(This feature cannot be disabled in
trucks using VISTA (6.6L) engines.)

Tire changes or
additions

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

For tractors, approval
request must be submitted if
still within the reporting
period (as indicated in the
section above).

ends, approved without request.
Vocational: Approved without

request at 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

1. Determine via lineset

change request form be submitted.

whether or not the unit has
the following feature code
Case 1. Vehicles originally sold with installed: “12WGK engine re“12WGK” feature code:
rate capable.”
Change may be made at any time
in vehicle’s life.
Case 2. Vehicles NOT originally
sold with “12WGK” feature code:
If approved, change may be made
only during reporting period.

2. If yes, or otherwise within

reporting period, proceed
with completing the change
request form located in the
other resources section of
this document, and start a
case file with the
programming group.
3. If approved, the engine

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.

Neutral at Coast
Parameter – Eaton

Cummins Engines: A letter of
approval will be issued to
Cummins as part of the final
approval package, along with
the approved change request form.

Provide letter of approval to
Cummins as they will require
this before changing ECM
parameters.

International Motors, LLC will
provide assistance for engine
parameter changes.

Provide approved change
request form to Eaton as
they will require this before
changing TCM parameters.

Eaton will log in remotely to change
TCM parameters. (Dealer must
have ServiceRanger installed.)

Neutral at Idle (Neutral Special letter for Allison will be
at Stop) Parameter provided as part of approval, in
Allison
addition to the approved change
request form.

Provide special approval
letter to Allison as they will
require this before changing
TCM parameters.

Aerodynamic feature
changes

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

Contact International Motors,
LLC.

Weight changes

GHG credit is taken for certain
weight savings – usually because a
lighter material is used. Features

Contact International Motors,
LLC.

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 rpm 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 operation and maintenance 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 (for example, 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

International® Service PortalSM

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 completed form with new
case attachment - select the programming
group when starting the case file.

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