Document OJ4j7o3zOkvvqjN6QY9rL3N1p
EPA OECA Air Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
04/06/2023 Air Title II Mobile Sources
Medway Imports Medway Imports Flint Storage Facility 3337 Lapeer Rd., Flint, MI 48503
3337 Lapeer Rd., Flint, MI 48503
Genesee County Alanna Heagle
Operations Manager
FRS Number: Identification/Permit Number: Media Number: NAICS: SIC:
Facility Representatives:
N/A
N/A N/A N/A Alanna Heagle
Operations Manager 810-422-9735
EPA Inspectors:
State Inspector(s):
Other Inspector(s):
Title: Author: Subject:
Keywords: EPA Lead Inspector Signature/Date
Supervisor Signature/Date
Mario Jorquera
OECA/OCE/AED/VEEB 202-564-1079
{name} {name} {name} Brodie Mack Kim Childers
{affiliation/mailcode} {affiliation/mailcode} {affiliation/mailcode} NHTSA NHTSA
{phone no.} {phone no.} {phone no.} 202-366-6089 202-366-2820
Medway Imports Inspection; Flint, MI Mario Jorquera Inspection of Potentially Uncertified Mexican Dodge Chargers imported into the U.S. Inspection Report, Vehicle and Engine, Dodge Chargers, Mexico
{Inspector name}
MARK PALERMO
{Supervisor name}
Digitally signed by MARK PALERMO Date: 2023.09.07 14:13:04 -04'00'
Date Date
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
At the request of managers from the National Highway Traffic Administration (NHTSA), on April 6, 2023, EPA HQ Air Enforcement Division, Vehicle and Engine Branch inspector Mario Jorquera joined NHTSA inspectors at the premises of Medway Imports (Medway) in Flint, Michigan for an unannounced inspection of a number of vehicles at their facility. NHTSA had intelligence that suggested some 22 Dodge Charger sedans at this facility were claimed as being Canadian despite the fact that they had been built for sale in Mexico. The role of the EPA inspector was to check the vehicles for evidence of compliance with EPA requirements and to help determine if the vehicles were truly Mexican and thus ineligible for importation as Canadian vehicles, which have emission control requirements identical to U.S. vehicles.
FACILITY DESCRIPTION
The Medway Imports facility consists of an office building and a surrounding gravel parking lot with a large number of cars. The lot had a tall chain-link fence around it. Medway specializes in importing vehicles from Canada for sale and use in the United States. Medway has two facilities: one in Medway, MA and the other in Flint, MI. Medway is a Registered Importer (RI) under NHTSA regulations and makes changes to the Canadian vehicles to meet US. Laws. The changes may include changing the speedometers, lights and glass.
As this was an inspection primarily directed by NHTSA, the EPA inspector had little contact with facility personnel. Rather, the EPA inspector spent his time examining the vehicles at issue in the gravel lot of the facility.
All vehicles inspected were Model Year (MY) 2020 Dodge Charger sedans manufactured at Fiat Chrysler Automobiles (F white and were powered by 5.7 liter V8 engines.
The facility operates 5 days a week from 8:00am to 5:00pm. It is closed on weekends.
Section II - OBSERVATIONS
Inspector Mario Jorquera proceeded to inspect the Dodge Chargers at the facility. The inspection consisted of observing and photographing all the labels on each vehicle, including the EPA Vehicle Emission Control Information (VECI) label in the engine compartment and the DOT
warning labels such as on the sun visors of each v manuals in several vehicles. As an additional test, Mr. Jorquera obtained Onboard Diagnostic (OBD) data from two of the vehicles to determine its consistency with EPA-certified OBD parameters. Mr. Jorquera also checked the underside of several vehicles to ensure that emission control components such as catalytic converters were present.
Inspections at the Gravel Parking Lot:
Inspection #
1
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
4/6/23 3568-3580 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT3LH213030 July 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
2 4/6/23 3581-3592 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT9LH215686 September 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
3 4/6/23 3593-3604 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT8LH213086 September 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
4 4/6/23 3605-3612 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT9LH215610 July 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
5 4/6/23 3613-3620 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT5LH219346 July 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
6 4/6/23 3621-3628 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT7LH213080 September 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
7 4/6/23 3629-3636 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT9LH219382 September 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
8 4/6/23 3637-3644 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT7LH212964 September 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
9 4/6/23 3645-3652 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT4LH212968 September 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
10 4/6/23 3653-3660 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT8LH212908 September 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
11 4/6/23 3661-3668 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT8LH215677 August 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
12 4/6/23 3669-3678 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT9LH213095 October 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
13 4/6/23 3679-3694 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT5LH215667 July 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
14 4/6/23 3686-3694 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT6LH2113023 July 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
15 4/6/23 3695-3701 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT6LH215600 September 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
16 4/6/23 3702-3706 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT6LH212969 Not noted Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
17 4/6/23 3707-3715 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCT7LH215685 July 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Inspection # Date Inspection Photos Inspector Type of equipment Brand Equipment Manufacturer Model VIN Equipment Build Date ECI Label Company on ECI TGN Emission Controls listed Engine Build Date Fuel EPA Regs Certified to Emission Controls Observed Used or New? Imported?
18 4/6/23 3716-3727 (Canon) Mario Jorquera Highway Motor Vehicle (Sedan) Dodge Fiat Chrysler Automobiles N.V. Charger 2C3CDXCTXLH215633 August 2020 Under hood FCA US LLC LCRXV03.65P3 HO2S, SFI, TWC 2020MY Gasoline 40 C.F.R 40/Chapter-I/Subchapter-C/part-86 TWC
Used Yes
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
As shown above, 18 vehicles were examined by inspector Mario Jorquera. This was the extent of the inspections conducted at the Medway Imports facility in Flint. Inspector Jorquera also obtained data from the Onboard Diagnostic (OBD) system of two of the vehicles by means of a data logger. The last five digits of the VIN for the two vehicles scanned for OBD data at
s facility were 213086 and 215686. The data obtained from these scans is shown in the table 1, below:
Table 1: Analysis of Data Obtained from Scans of Vehicle OBD Systems
VIN Chassis Local Log Supported
Engine Family OBD Compliance
VIN File 10th MY Start Controllers Protocol (Mode 9, PID 13) (Mode 1, PID 1C)
digit
Time
3D06134
1 2C3CDXCT8LH213086
8.IOS
L
3D06140
2 2C3CDXCT9LH215686
3.IOS
L
2020 2020
4/6/23 9:48 AM
4/6/23 10:03 AM
E8, E9 E8, E9
J1979
LCRXV05.75P5
Hex Value = 1*
J1979
LCRXV05.75P5
Hex Value = 1*
* OBD Compliance Value of 1 = California-only (including other "CAA Sec. 177" states) OBD II certified systems. "Certified to California OBD II" should only be included if the actual test group is intended for certification by CARB. The EPA Test Group Name is listed if it was reported under Mode 9 and OBD compliance from Mode 1.
Section III AREAS OF CONCERN
Upon importing these vehicles, Medway declared them to be admissible under Code FF in -
imported for resale or lease. In using this code, the importer must demonstrate that the vehicles are truly Canadian by means of Canadian emission control labels, registrations or titles, or a
with respect to emissions. The importer is also required to satisfy all labeling, warranty and CAFE requirements as specified by EPA.
NHTSA informed inspector Jorquera that Medway had provided a letter from the manufacturer
indicating that the vehicles were built for the Canadian market. However, FCA representatives
denied that the letter had originated with them. The vehicles Inspector Jorquera examined had no
labels that suggested they were Canadian. In fact, all of the labels that were obviously installed
by the manufacturer were in Spanish, including the tire and load limit labels, the airbag warnings
on the sun visors
There were several labels that appeared to be
installed by Medway, including the EPA VECI labels under the hood, the Canadian certification
labels, the DOT tire safety label and the DOT Federal Motor Vehicle Safety Standards (FMVSS)
compliance labels.
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
Inspector Jorquera observed that the labels installed by Medway were of very poor quality when compared to those had poor print quality and easily peeled off. In addition, several Medway labels were obviously placed over other (presumably OEM) labels that had been removed. The Medway labels also had obvious errors that an OEM would never make. For example, the FMVSS labels required by DOT listed the date of manufacture of each vehicle, but the months listed on the label had no
ehicle Identification Number (VIN). These discrepancies are shown in the Table 2:
Table 2: Comparison of vehicle serial number and month of manufacture
Last 6 Digits of VIN (in ascending order) 202908 212964 212968 213023 213030 213080 213086 213095 215600 215610 215633 215667 215677 215685 215686 219346 219382
Claimed month of manufacture in 2020 September September September July July September September October September July August September August July September July September
OEMs assign the serial number portion of VINs in a sequential manner. So, it is impossible that the vehicle with VIN 2C3CDXCT6LH215600 was built in September while the one with VIN 2C3CDXCT9LH215610 was built in July. Clearly, these labels were crafted with no attention to the regulatory requirement to provide accurate dates. Another problem with the labels required by DOT is that the Dodge Chargers are clearly passenger cars (Both definitions are in DOT regulations at Title 49, Subtitle B, Chapter V, Part 571).
Similar problems occur with the EPA VECI labels installed under the hood of all inspected vehicles had the EPA Test Group Name LCRXV03.65P3, yet indicated the engines were 5.7 liter V8 engines. This label has an internal inconsistency that OEM labels would be unlikely to have, and does not correspond to the label that FCA included in its application for a Certificate of Conformity (COC) for MY 2020 Dodge Chargers equipped with their 5.7 liter engines for sale in the U.S. and Canada. The LCRXV03.65P3 Test Group Name is only for FCA
, and this was the number
Medway Imports Flint, Michigan Inspection Date: 04/06/2023
reported by the OBD system in the three Medway cars tested. Accordingly, it is evident that the VECI labels installed in the inspected vehicles did not correspond to those vehicles.
Based on the evidence discussed above, inspector Jorquera believes all of the Medway vehicles he examined were manufactured in Canada for the Mexican market, and, as such, are not Canadian vehicles. Even if these vehicles were Canadian vehicles, Medway does not meet the requirements necessary to use Code FF in the EPA 3520-1 declaration form as a rationale for claiming the vehicles are eligible for importation because the VECI labels used on all vehicles correspond to a different engine configuration than that with which they are equipped.
Section IV FOLLOW UP
EPA will be following up with Medway to discuss resolving any possible violations triggered when all of these vehicles were imported into the U.S.
Section V LIST OF APPENDICES
Appendix 1 Photo Log 160 photos taken on 04/06/2023 with the Cannon camera (IMG_3568IMG_3727.JPG)
Appendix 2 -- COC Application for TGN LCRXV03.65P3.pdf Appendix 3 COC Application for TGN LCRXV05.75P5.pdf