Sidley Represents SEMA in Securing Landmark EPA Approval of Its Emissions Certification Program for Auto Products

Sidley represented the Specialty Equipment Market Association (SEMA) — the leading trade association for the $500 billion specialty automotive aftermarket industry — in securing recognition from the U.S. Environmental Protection Agency (EPA) that SEMA’s Certified-Emissions (SC-E) program may serve as a federal pathway for demonstrating emissions compliance for aftermarket vehicle products under the Clean Air Act (CAA) and EPA’s longstanding Tampering Policy. 

EPA announced on July 1, 2026, that, moving forward, companies may use SEMA’s SC-E program to show compliance with the CAA and verify that approved aftermarket parts do not negatively impact vehicle emissions. EPA framed the action as implementing President Trump’s “Lowering the Cost of Living by Promoting the Freedom to Fix” memorandum, which directed EPA Administrator Lee Zeldin to reduce reliance on the California Air Resources Board (CARB) emissions certification process for aftermarket vehicle products.

The recognition is significant for an industry that has long faced uncertainty regarding how aftermarket parts and equipment may demonstrate compliance with federal emissions requirements. Before this action, CARB had the only EPA-recognized certification process for this purpose — a process EPA itself described as “faulty and backlogged,” with certifications timelines of 12 to 18 months that left small businesses sidelined while foreign counterfeits flooded the market.

The Sidley team, led by Justin Savage, Brittany Bolen, and Riley Desper, worked closely with SEMA’s leadership through multiple engagements with EPA to explain the legal and technical foundation for SEMA’s SC-E program and its fit within EPA’s longstanding Tampering Policy. That policy recognizes several ways aftermarket manufacturers may establish a reasonable basis for compliance, including by documenting that an appropriate vehicle equipped with an aftermarket product will pass the same emissions tests used by the original equipment manufacturer to certify the vehicle under the CAA. SEMA developed SC-E to give aftermarket manufacturers a rigorous, standardized testing framework for making that showing.

In a July 1, 2026 letter to SEMA CEO Mike Spagnola, Jeffrey A. Hall, EPA’s Assistant Administrator for Enforcement and Compliance Assurance, agreed that, as described in SEMA’s materials, emissions testing performed through the SC-E program meets the Tampering Policy’s requirements. EPA further stated that aftermarket part manufacturers and vendors may ordinarily rely on an SC-E certificate as reasonable documentation that a part does not adversely affect emissions.

SEMA characterized the recognition as a “landmark” for the entire aftermarket industry. CEO Mike Spagnola described EPA’s recognition as validating SEMA’s longstanding position that the aftermarket industry has a rigorous mechanism to support emissions testing compliance with federal law, and as an important example of public-private collaboration in support of regulatory compliance.