Guidance document on Off-Road Compression-Ignition Engine Emission Regulations: chapter 7

G. Evidence of conformity

G.1 Introduction to emission standards

This section aims to provide guidance on the provisions of the regulations regarding evidence of conformity requirements: specifically, what is required and what procedures should be followed when submitting evidence of conformity for off-road compression-ignition engines manufactured for sale^Footnote5 in Canada or imported into Canada.

G.2 Definitions

Provided below are definitions of terms used throughout this section. A bolded term indicates that the definition was created solely for the purpose of this document. Terms that are not bolded are defined either in the Regulations or in the Act.

“Canada-unique engine” means an engine of a specific engine family that is either not covered by a valid Environmental Protection Agency (EPA) certificate or not sold concurrently in Canada and in the United States. Generally, all engines that do not meet the criteria set out in section 16 of the Regulations fall under paragraph 17(1)(b) and are called “Canada-unique”. Transition engines are a particular case. More information is provided later in this section.

“Company” means a person who:

(a) is engaged in the business of manufacturing vehicles, engines or equipment in Canada

(b) is engaged in the business of selling to other persons, for the purpose of resale by those persons, vehicles, engines or equipment obtained directly from a person described in paragraph (a) or the agent of such a person, or

(c) imports any vehicle, engine or equipment into Canada for the purpose of sale

“Engine” means an off-road engine that is prescribed under subsection 5(1) of the regulations. regulations apply to all engines of the 2006 and later model years manufactured or imported into Canada (section 3 of the regulations). Engines that are referred in subsection 5(2) of the regulations are excluded.

“Engine family” means a group of similar engine models within a manufacturer’s product line that are similar with respect to their design and emissions characteristics. Engine family classifications are used for the purpose of demonstrating compliance with emission standards. The provisions pertaining to engine family specifications are contained in sections 89.116 or 1039.230 of the Code of Federal Regulations (CFR).

“Engine family specifically listed” means an engine for which the engine family is specifically listed on a valid EPA certificate of the same model year, and which is in a configuration permitted by the EPA certificate.

“EPA certificate” means a certificate of conformity to United States federal standards issued by the EPA.

“Transition machine” means a machine that contains a transition engine as defined in section 13 of the regulations.

“Type 1” means an engine family that is covered by an valid EPA certificate, and sold in Canada but not in the United States.

“Type 3” means an engine family that is neither covered by an valid EPA certificate nor sold concurrently in Canada and the United States.

G.3 Background on the evidence of conformity

An off-road compression-ignition engine must conform to the standards applicable at the time when its manufacture was completed. Evidence of conformity for those standards must be produced in the prescribed form. The following flow-chart illustrates the different “types” of engines and identifies which section addresses the appropriate evidence of conformity requirements.

G.3.1 Engines covered by an EPA certificate and sold concurrently in Canada and in the United States (Section 16)

Section 16 of the regulations identifies the evidence of conformity that is required for an engine that is covered by a valid EPA certificate^Footnote6 and sold concurrently in Canada and in the United States.

Engines covered by an EPA certificate:

For the purpose of the regulations, an engine is considered to be covered by an EPA certificate if its engine family is specifically listed on a valid EPA certificate. “Engine family specifically listed” is defined in G.2.

Engines sold concurrently:

For the purpose of the regulations, an engine sold in Canada is considered to be sold concurrently if any one of the following applies within one year (365 days) preceding the engine’s importation into Canada, the application of the EC or, in the case of 153(2), before the engine leaves the possession or control of the company:

1. An engine of the same engine family and model year is sold to the first retail purchaser or leaser in the United States. This must be substantiated with any of a, b or c below:
   1. copy of dated invoice to the first U.S. retail purchaser/leaser
   2. copy of dated invoice to a U.S. party who sells or leases at the U.S. retail level (for example, dealer)
   3. copy of dated purchase order between a U.S. party and the first U.S. retail purchaser/leaser
2. A dated advertisement of the same engine family of the same model year targeted at U.S. consumers (this could include sales brochure, printed ad, magazine, price list, etc.) demonstrating that the product was actively marketed and available for delivery in the U.S.
3. A dated U.S. manufacturer/importer/dealer list for the same engine family of the same model year for the U.S. demonstrating that the product was actively marketed and available for delivery in the U.S.

If the above evidence of conformity pertains to a machine within which an engine is installed, then the evidence must include supporting documentation matching the engine to the machine.

Before the import of an engine, before applying the NEM, or, in the case of 153(2), before the engine leaves the possession or control of the company, a company must ensure that it has the complete evidence of conformity available (including EPA certification) and at least one of the above-listed concurrent sale documents that is appropriately dated. The evidence of conformity must be available prior to any of the above action taking place. Otherwise, a company must produce a Canada-unique submission of evidence of conformity as per G.4.2.

G.3.2 Canada-unique engines (paragraph 17(1)(b))

Type 1^Footnote7 - Specifically listed on an EPA certificate, and sold in Canada but not in the United States

The engine family is specifically listed on a valid certificate issued by the EPA, but it is not sold concurrently in the United States. Evidence of conformity must be submitted to Environment Canada as per paragraph 17(1)(b) of the regulations because the engine is not sold concurrently in the two countries.

Type 3 - Neither specifically listed on an EPA certificate or sold concurrently in Canada and the United States

Evidence of conformity to the regulations must be submitted to Environment Canada as per paragraph 17(1)(b), because there is no valid EPA certificate covering that engine of that model year, and the engine is not sold concurrently in the two countries.

The requirements for submitting evidence of conformity to the regulations are stated in paragraph 17(1)(b):

17(1)(b) with respect to an engine other than one referred to in paragraph (a), evidence of conformity shall be obtained and produced by a company in a form and manner that is satisfactory to the Minister and shall include a copy of the label referred to in section 10.1, 11.1, 12 or 13, as the case may be.

G.4 Submission of the evidence of conformity: required documentation and timing

When a company submits evidence of conformity to Environment Canada, the company is responsible for identifying which information in the submission is confidential. Any confidential information will be dealt with in accordance with the Access to Information Act and the Privacy Act.

G.4.1 Engines sold concurrently as described in section 16

If the engine family of the engine is specifically listed on a valid EPA certificate (and is sold concurrently in Canada and in the United States), it automatically falls under section 16 of the regulations, and the evidence of conformity information listed in that section is to be submitted only upon written request from Environment Canada. This information should be maintained and provided in accordance with section 18 of the regulations. The following are the documentation requirements to meet section 16:

16. In the case of an engine referred to in subsection 14(1), evidence of conformity for the purposes of paragraph 153(1)(b) of the Act in respect of a company shall consist of:

(a) a copy of the EPA certificate covering the engine

(b) a document demonstrating that the engine covered by the EPA certificate is sold concurrently in Canada and in the United States

(c) a copy of the records submitted to the EPA in support of the application for the issuance of the EPA certificate in respect of the engine

(d) a United States emission control information label that is permanently affixed in the form and location set out in section 110, subpart B, of CFR 89, section 135, subpart B, of CFR 1039 or, if applicable, section 645(d)(1) of that subpart for the applicable model year of the engine

G.4.2 Canada-unique engines as described in paragraph 17(1)(b)

Since the regulations are aligned with those of the United States, the general intent is to enable companies to establish compliance by submitting information similar to that which is provided to obtain an EPA certificate and required under paragraph 16(c) of the regulations. The following paragraphs summarize the information that shall be obtained and produced “in a form and manner satisfactory to the Minister”, for Canada-unique engines other than transition engines. It should be noted that this list may change from time to time to respond to evolving testing and information requirements for different types of engines, and to remain aligned with the requirements in the United States.

A separate submission is required for each engine family. For an engine that is either not covered by an EPA certificate of conformity or sold concurrently in Canada and in the United States, the evidence of conformity in this situation must be submitted before the importation of the subject engine, or in the case of 153(2) before the engine leaves the possession or control of the company,^Footnote8 or before affixing the national emissions mark to the engine.

Appendix II illustrates the procedure to provide evidence of conformity “in a form and manner satisfactory to the Minister” for the engines referred to in paragraph 17(1)(b) of the regulations.

The information that needs to be submitted varies according to the type of Canada-unique engine under consideration, as shown in Table 7:

Notes for Table 7:

^g The submission of an EPA certificate as the evidence of conformity for a type 1 engine is acceptable where it establishes that the engine family of the engine complies with all applicable standards set out in the Off-Road Compression-Ignition Engine Emission Regulations established under the act, as should be stated in the statement of compliance letter (for example, no deviations from prescribed standards).
^h A company that submits its evidence of conformity following the importation of the subject engines in reliance on subsection 153(2) of the act must submit to the Minister, prior to importation, an importation declaration, as per section 21 of the regulations.

It should be noted that the information requirements that are listed above reflect what information constitutes a form and manner satisfactory to the Minister. This information must be submitted before the importation of the subject engine, or in the case of 153(2) before the engine leaves the possession or control of the company, or before affixing the national emissions mark to the engine.

G.4.2.1 Statement of compliance letter

A submission of evidence of conformity to the regulations for Canada-unique engines must contain an original signed letter from an authorized representative of the company. An example of a statement of compliance letter is provided in Appendix III.

The letter must include as a minimum:

1. name and address of the company
2. business number assigned to the company by the Minister of National Revenue
3. the identification (for example, make, model, model year, engine family) of the engines and machines (if applicable)
4. estimated projected Canadian sales
5. an unconditional statement of compliance with all the applicable exhaust emission standards set out in the Off-Road Compression-Engine Emission Regulations established under the Canadian Environmental Protection Act, 1999
6. a statement that the engines are manufactured to the same specifications as those set out in the evidence of conformity
7. a statement acknowledging that the signatory is authorized to act on behalf of the company
8. a request for an acknowledgment by Environment Canada that the evidence of conformity submitted has been obtained and produced in a form and manner satisfactory to the Minister

The following additional information may also be included:

9. the identity of persons (both inside or outside of the company) that Environment Canada may contact regarding the submission (for example, technical contacts for importers)
10. an indication of whether some information is to be treated as confidential
11. any other information believed to be relevant

G.4.2.2 Technical information

The technical information required is equivalent to that specified in paragraph 16(c) of the regulations. The list of technical information that Environment Canada requires can be found in Appendix V. It is based on information that is equivalent to the records submitted to the EPA in support of the application for the issuance of the EPA certificate.

If the engine is or was covered by an EPA certificate, a copy of the most recent records submitted to the EPA in support of the application for the issuance of the EPA certificate is deemed to be satisfactory for the technical information of the evidence of conformity. The engine covered by the submission must be manufactured to the same specifications as those set out in the most recent records submitted to the EPA.

G.4.2.3 Sample engine information label

For a type 1 submission, a sample drawing or copy of the engine information label must be included in the submission of evidence of conformity. The engine information label must meet all requirements of its applicable section under the appropriate part of the CFR, either section 110 of CFR 89, or section 135 or 645(d)(1) of CFR 1039.

For a type 3 submission, a sample drawing or copy of the engine information label must be included in the submission of evidence of conformity. The engine information label must meet the requirements provided in section 10.1 of the regulations. A sample label can be found in Appendix VII. It can be provided in English or in French; however, it must contain the following bilingual compliance statement:

“THIS ENGINE CONFORMS TO ALL APPLICABLE STANDARDS FOR THE [insert model year] MODEL YEAR PRESCRIBED BY THE CANADIAN OFFROAD COMPRESSION-IGNITION ENGINE EMISSION REGULATIONS IN EFFECT ON THE DATE OF MANUFACTURE / CE MOTEUR EST CONFORME À TOUTES LES NORMES QUI SONT APPLICABLES À L’ANNÉE DE MODÈLE [inscrire l’année de modèle] EN VERTU DU RÈGLEMENT SUR LES ÉMISSIONS DES MOTEURS HORS ROUTE À ALLUMAGE PAR COMPRESSION CANADIEN EN VIGUEUR À LA DATE DE SA CONSTRUCTION”

In lieu of the compliance statement, a company has the option of affixing the national emissions mark. In that particular situation, the engine information label must also be applied to provide the necessary technical information sufficient to identify the engine for which the evidence of conformity has been assessed to be satisfactory (name of engine manufacturer, model year, engine family, etc.). It should be noted that the national emissions mark is generally required for engines that are manufactured in Canada. Before affixing the national emissions mark, the company must obtain the authorization of the Minister. Further information on the national emissions mark can be found in chapter E.

G.5 Evidence of conformity for transition engines

This subsection will describe the evidence of conformity for a transition engine, when to submit the evidence of conformity, and other requirements applicable to transition engines.

A transition engine may be manufactured or imported if the engine either is or will be installed in or on a machine before the end of the time frame corresponding to its power category (see F.6.1).

Note that for transition engines, the requirements for evidence of conformity depend on whether the machine in which the transition engine is or will be installed is concurrently sold or not. This is different from non-transition engines, where this determination is based on the engine alone.

G.5.1 Concurrent sale of transition engines

For the purpose of the regulations, concurrent sale of these engines is based on the machine model (see C.9) containing the transition engine. A transition engine sold in Canada is considered to be sold concurrently if any one of the following applies within the calendar year and prior to the engine’s importation into Canada, the application of the NEM or, in the case of 153(2), before the engine leaves the possession or control of the company:

1. A machine of the same model is sold to the first retail purchaser or leaser in the United States. This must be substantiated with any of a, b, or c below:
   1. copy of dated invoice to the first U.S. retail purchaser/leaser
   2. copy of dated invoice to a U.S. party who sells or leases at the U.S. retail level (for example, dealer)
   3. copy of dated purchase order between a U.S. party and the first U.S. retail purchaser/leaser
2. A dated advertisement of the machine model targeted at U.S. consumers (this could include sales brochure, printed ad, magazine, price list, etc.) demonstrating that the product was actively marketed and available for delivery in the U.S.
3. A dated U.S. manufacturer/importer/dealer list for the machine model demonstrating that the product was actively marketed and available for delivery in the U.S.

Before the import of a transition engine, before applying the NEM, or, in the case of 153(2), before the engine leaves the possession or control of the company, a company must ensure that it has the complete evidence of conformity available (including evidence that the engine was manufactured as per the U.S. flex engine program set out in CFR1039.625) and at least one of the above-listed concurrent sale documents that is appropriately dated. The evidence of conformity must be available prior to any of the above action taking place. Otherwise, a company must produce a Canada-unique submission of evidence of conformity as per G.5.3.

G.5.2 What is the evidence of conformity required for a transition engine that will be installed in a transition machine that is sold concurrently, and when should it be submitted to the Minister?

If the transition engine is installed or will be installed in a transition machine that is sold concurrently in Canada and in the United States, it automatically falls under subparagraph 17(1)(a)(i) for loose transition engines and subparagraph17(1)(a)(ii) for transition engines installed in or on a machine, and the evidence of conformity information listed in that section is to be submitted only upon written request from Environment Canada. However, this information should be maintained and provided in accordance with section 18 of the regulations.

The following list presents the required documentation to meet the requirements of subparagraph 17(1)(a)(i) for loose transition engines and subparagraph17(1)(a)(ii) for transition engines installed in or on a machine:

1. a statement, dated and signed by the company or its duly authorized representative, certifying that the engine conforms to section 625(e), subpart G, of CFR 1039
2. a document demonstrating that at least one machine of the same model as the one in which the engine is installed (or will be installed) is sold concurrently in Canada and in the United States
3. a copy of the documentation submitted to the EPA under section 625, subpart G, of CFR 1039:
   1. a copy of the machine manufacturer’s calculation described in paragraph 1039.625(c) of the CFR
   2. a copy of all documentation provided to the United States EPA related to the flexibility provisions pursuant to CFR 1039.625(g)
   3. a copy of the machine manufacturer’s records referred to in paragraph 1039.625(h) of the CFR
   4. a copy of all documentation provided to the United States EPA related to the flexibility engine pursuant to CFR 1039.625(j)
   5. a copy of the most recent United States EPA certificate of conformity
   6. a copy of all records submitted to the United States EPA in support of the application for the issuance of the most recent United States EPA certificate of conformity
   7. a copy of the engine information label indicating that the engine is part of the United States EPA flexibility program under CFR 1039.625
   8. a copy of the equipment label indicating that the machine has an engine that meets the United States EPA emission standards under CFR 1039.625
   9. the transition engine production period
   10. in the case of a loose engine, a statement that the engine will be installed on a machine that is sold in the United States
4. A copy of the label referred to in subsection 13(3) or (4), if applicable.

Note that the proper importation declaration must be sent to the Minister prior to importation (see chapter H for more information), and the annual report must be sent no later than 90 days after the end of the calendar year during which the engine is imported or manufactured (see F.6.5 for more information). In addition, the transition engine must be labelled accordingly (see Appendix VI for more information).

G.5.3 What is the evidence of conformity required for a transition engine in a transition machine that is not sold concurrently, and when should it be submitted to the Minister?

Since the regulations are aligned with those of the United States, the general intent is to enable companies to establish compliance by submitting information similar to that which is provided to the EPA under their equipment manufacturer flexibility program and required under subparagraphs 17(1)(a)(i) and 17(1)(a)(ii) of the regulations. A transition engine that will be installed in a transition machine that is not sold concurrently in Canada and the United States will be referred to as a Canada-unique transition engine.

The following paragraphs summarize the information that shall be obtained and produced ”in a form and manner that is satisfactory to the Minister”, for Canada-unique transition engines. It should be noted that this list may change from time to time to respond to evolving testing and information requirements, and to stay aligned with the requirements in the United States.

A separate submission is required for each engine family and transition machine. The evidence of conformity for a Canada-unique transition engine must be submitted before the importation of the subject engine, or in the case of 153(2) before the engine leaves the possession or control of the company,^Footnote9 or before affixing the national emissions mark to the engine.

Appendix II illustrates the procedure to provide evidence of conformity “in a form and manner that is satisfactory to the Minister” for the Type 1 and Type 3 Canada-unique engines referred to in paragraph 17(1)(b) of the regulations. The same procedure applies to Canada-unique transition engines; however, the information to be supplied is different as the evidence of conformity of a transition engine differs from that of a Type 1 or Type 3 Canada-unique engine.

A submission of evidence of conformity for Canada-unique transition engines must contain a statement of compliance letter signed by an authorized representative of the company. The letter must contain the same elements prescribed in section G.4, as well as identification that this is a Canada-unique transition engine submission and information identifying the machine manufacturer.^Footnote10 An example of a statement of compliance letter for Canada-unique transition engines is provided in Appendix IV.

The evidence of conformity for a Canada-unique transition engine consists of:

1. a statement, dated and signed by the company or its duly authorized representative, certifying that the engine conforms to the requirements under section 13
2. documentation demonstrating that the emission standards are met:
   1. a copy of the most recent United States EPA certificate of conformity (if applicable)
   2. a copy of all records submitted to the United States EPA in support of the application for the issuance of the most recent United States EPA certificate of conformity or the technical information that can be found in Appendix V
   3. a copy of the label referred to in subsection 13(3) or (4)
   4. a copy, in both official languages, of the emission-related maintenance instructions
3. Information identifying the engine manufacturer:
   1. the name and address of the engine manufacturer
   2. the transition engine production period
4. In the case of a loose engine, proof that the engine will be installed in a machine:
   1. this could be a written contract between the importer and the machine manufacturer stating that the engine will be installed prior to the end of the time frame (see F.6.1 for table of time frames)^Footnote11

For Canada-unique transition engines, the proper importation declaration and evidence of conformity must be sent to the Minister (see chapter H for more information). In addition, the annual report must be submitted no later than 90 days after the end of the calendar year during which the engine is imported or manufactured (see F.6.5 for more information). In addition, the transition engine must be labelled accordingly (see Appendix VI for more information).

G.6 Administrative information

G.6.1 Who is responsible for submitting the evidence of conformity?

Each company that either seeks to import or that is required to apply a national emissions mark is responsible for submitting the evidence of conformity as required under section 16 and paragraphs 17(1)(a) and (b).

When the same engines are being imported or offered for sale by different companies, the evidence of conformity has to be submitted by each company. All companies need to submit a compliance letter and the proper evidence of conformity. However, instead of the same information being submitted to Environment Canada twice, companies may collaborate where only one company (Company A) submits the complete information. In this case, all statement of compliance letters may reference the information submitted by Company A and indicate that a copy of the letter has been sent to Company A. Note that it is each company’s responsibility to ensure compliance with all applicable sections of the regulations.

To reduce the regulatory paperwork burden upon companies seeking to import Canada-unique engines, some engine manufacturers may voluntarily submit relevant technical documentation directly to Environment Canada. In this case, companies (importers) would then be required to submit a statement of compliance letter, for each submission, prior to the importation of the subject engine or, in the case of 153(2), before the engine leaves the possession or control of the company^Footnote12, or before affixing the national emissions mark to the subject engine for each submission. It is the responsibility of companies (importers) to ascertain whether this technical documentation has been submitted for engines and/or machines they plan to import.

Regarding the evidence of conformity, section 18 of the regulations states that:

18 (1) A company shall maintain records, in writing or in a readily readable electronic or optical form, that contain the following information and retain the record for the following periods:

(a) a copy of the annual report referred to section 13.1 for a period of eight years following the end of the calendar year in question;

(b) the evidence of conformity referred to in section 16 or 17, as the case may be, for a period of eight years following

(i) if the engine is imported, the date of import, or

(ii) in any other case, the end of the calendar year that corresponds to the model year of the engine.

(2) If the records referred to in subsection (1) are retained on a company’s behalf, the company shall keep a record of the name and civic street address and, if different, the mailing address of the person who retains those records.

(3) If the Minister makes a written request to the company for a record referred to in subsection (1) or (2), the company must submit it to the Minister in either official language

(a) within 40 days after the day on which the request is made to the company; or

(b) within 60 days after the day on which the request is made to the company, if the record must be translated from a language other than French or English.

G.6.2 Where should evidence of conformity be sent?

Submit the evidence of conformity to the regulations, in either English or French, in paper copy or electronically, to one of the addresses that follow:

Electronic versions

The electronic documentation must be either in PDF, Microsoft Office format or FileMaker Pro format. It should be sent to the Vehicle and Engine Testing and Emissions Verification Section with an appropriate case-specific subject line:

• For a submission pertaining to a Canada-unique compression-ignition engine under paragraph 17(1)(b) of the regulations (Type 1 or 3 and Canada-unique Transition Engines):

“Canada-unique Submission - Name of Company - ECA # (once assigned)”

• For a submission pertaining to an engine that falls under section 16 or paragraph 17(1)(a) of the Regulations (when requested):

“Evidence of Conformity Submission - Name of Company - EC200X-XXX”

Paper copies

Paper copies should be sent to:

Director
Transportation Division
Energy and Transportation Directorate
Environment Canada
351 Saint-Joseph Boulevard
Gatineau QC  K1A 0H3

G.6.3 Environment Canada acknowledgements

Environment Canada will send acknowledgements to the manufacturer or the importer when evidence of conformity is received and considered to be “in a form and manner that is satisfactory to the Minister” based on the elements discussed in section G. The acknowledgement that the “form and manner” are satisfactory to the Minister does not relieve the company of the obligation to comply with the regulations and the act.

In cases where a company is submitting applications for more than one engine family, it would be helpful if the company were to state the order in which it would prefer Environment Canada to process them.

When a company submits information for an engine family for which an identical submission was received and acknowledged by Environment Canada in a previous year, the company should notify Environment Canada that the submission is a direct carry-over to facilitate and accelerate the process.

Environment Canada will strive to respond to submissions according to the timelines shown in Table 8. When information is found to be missing and Environment Canada is waiting to receive additional information from a company, that wait time is added to the processing time listed below.

G.6.4 Whom should I contact if I have questions or concerns?

For concerns relating to evidence of conformity, please contact the Vehicle and Engine Testing and Emissions Verification Section, Transportation Division of Environment Canada by email or at 613-998-3579.

For concerns relating to other administrative requirements, please contact the Regulatory Administration Section, Transportation Division of Environment Canada.

G.7 Engine labelling requirements, declarations and suggested text

Engines imported into or manufactured in Canada require a label or, in some cases, an accompanying declaration. All labels must meet the characteristics of labels outlined in subsections 8(1) and 8(2) of the regulations. Finally, all engines must be labelled with a unique identification number as set out in section 8.1 of the regulations (see G.9). Please note that engines are to be labelled differently depending on the circumstances surrounding the engine. The table in Appendix VI outlines the various labelling requirements.

G.8 What are the labelling requirements?

The physical requirements are outlined in the regulations in subsections 8(1) and 8(2). The requirements state that any label required by the regulations, other than a United States emission control label (which has similar requirements in the applicable CFR), must:

• be on, or immediately next to the United States emission control label (if applicable)
• in a visible location
• be permanently applied
• be resistant to or protected against any weather condition
• bear characters (letters and numerals) that are readable and permanent and are indented or embossed in a colour that contrasts with the label’s background

G.9 What is the unique identification number referred to in subsection 8.1(1) of the regulations?

A unique identification number is defined as a number, consisting of Arabic numerals, Roman letters or both that the manufacturer assigns to the engine for identification purposes. It is the responsibility of the importer or the Canadian engine manufacturer or distributor to ensure that a unique identification number is affixed to every engine. The unique identification number shall be legible and may be engraved or stamped on the engine or may be on a label that meets the requirements set out in subsections 8(1) and 8(2) of the regulations (see G.8).