The compliance standard for the performance automotive aftermarket.
Each member shop receives a complete Clean Air Act compliance program — fifteen customized documents, an issued Compliance Certificate, an embeddable Verified Member badge for the shop's website, and a public Member Registry entry that any customer, insurer, or regulator can verify.
Enrollment from $995, one-time, lifetime registration. 130 EPA cases · $720.5M in disclosed civil penalties on the public file.
Adopted by diesel performance shops, import tuners, race-prep operations, off-road builders, and multi-location aftermarket retailers nationwide.
EPA enforcement against the aftermarket is not theoretical.
Section 203 of the Clean Air Act (42 U.S.C. § 7522) prohibits the manufacture, sale, or installation of devices that defeat emission controls — and that authority extends to dealers, retailers, and installers, not only manufacturers.
The U.S. EPA has resolved 130 Clean Air Act vehicle and engine cases between FY2021–FY2025, with $720.5M in disclosed civil penalties on file. FY2025 alone produced $583M in resolved settlements, including the $525M Hino Motors settlement. Enforcement is not slowing down.
The shops EPA actually settles cases against.
Enforcement is not evenly distributed. Every aftermarket case in our database with a settlement above $500,000 involved one or more of the product categories below. If your shop operates in any of these areas, the median statistical case is not your case — the larger settlements are.
Diesel performance retail
Complete ProgramShops that sell DPF, EGR, or DEF delete kits, programmer tunes that disable emission controls, or related diesel modification products.
- Diesel OPs LLC$10,455,925FY2022
- Rudy's Performance Parts$7,000,000FY2024
- Premier Performance, LLC$3,000,000FY2021
Catless exhaust + test pipe sales
Complete ProgramManufacturers, distributors, and installers of exhaust components that remove or replace the factory catalytic converter.
- Allied Exhaust Systems$1,100,000FY2022
- Borla Performance Industries$1,022,500FY2022
- Pypes Performance Exhaust$84,000FY2021
Multi-location retailers + distributors
EnterpriseBusinesses selling aftermarket parts across multiple states, online channels into California or Section 177 jurisdictions, or distribution to other retailers.
- Turn 14 Distribution$3,600,000FY2025
- Keystone Automotive$2,500,000FY2022
- Autosales / Summit Racing$600,000FY2022
ECU tunes + custom calibrations
Complete ProgramShops that sell or install custom tunes that disable, alter, or bypass any factory emission control function — even when bundled with hardware that is itself certified.
- PPEI / Kory Willis$1,550,000 + felony pleaFY2022
- Kooks Custom Headers$300,000FY2023
- Wehrli Custom Fabrication$267,680FY2024
Race-prep + off-road builders
Complete ProgramShops selling race-only or off-road-only components without documented off-road use declarations executed at point of sale. The declaration is the principal documentary defense; without it the burden shifts back to the shop.
- Thunder Diesel + Performance$1,600,000FY2022
- Thoroughbred Performance Products$1,250,000FY2024
- Full Tilt Performance, LLC$450,000FY2024
California + Section 177 state operations
EnterpriseShops operating in California or any of the seventeen Section 177 jurisdictions that have adopted CARB standards. Federal EPA + parallel state enforcement, with separate settlement totals.
- Hino Motors (federal + CA)$525M + $153.9M to CAFY2025
- Lane Automotive (CA)$291,000FY2022
- Subject jurisdictions17 states + DCSection 177
Not sure which tier applies to your operation?
Submit an inquiry describing what your shop sells and your primary state of operation. Our compliance team responds within one business day with a tier recommendation — or, if Legal Tuning is not the right fit, a referral to qualified counsel.
Three tiers. One Standard. Calibrated to exposure.
Each tier delivers a customized set of operational compliance instruments, a permanent member registration, and a public Registry entry. All three tiers are one-time enrollments — registration never expires. Tier selection is driven by the shop's exposure profile.
Foundation
Shops with predominantly 50-state-legal inventory and limited off-road exposure
- Six (6) customized compliance instruments — Customer Sale Terms, Privacy Policy (CCPA/CPRA-compliant), Customer FAQ, Off-Road Use Declaration, Warranty Reference Card, Staff Training Acknowledgment
- Permanent member registration with public Member Registry entry, stamped with the issuance date
- Three (3) years of regulatory updates included — instruments re-issued at no additional charge as federal and state rules change
- Issued Compliance Certificate (digital) — confirming program completion and bearing the registered member number
- Verified Member badge — embeddable on the shop's website
Complete Program
Shops with substantive Clean Air Act exposure — diesel performance, catless exhaust, race-only components, defeat-device-adjacent inventory
- All fifteen (15) customized compliance instruments — full Standard adoption
- Three (3) years of regulatory updates included — instruments re-issued at no additional charge as federal and state rules change
- Founder's Kit included — bound compliance binder, framed Compliance Certificate, member display plaque, priority shipping
- Clean Air Act Compliance Standard Operating Procedure & Implementation Action Plan — the foundation of a defensible compliance program
- EPA Holding Letter, Litigation Hold & Records Preservation, Crisis Communications Protocol — instruments deployed when regulatory contact occurs
Enterprise
Multi-location operations, shops in Section 177 jurisdictions, or shops in active or anticipated regulatory contact
- Bundled lifetime value over $25,000 — Member Defense + lifetime updates + counsel hours + dev time, included with one-time enrollment
- All fifteen (15) instruments from Complete Program
- Member Defense included for life — operational support coordinated with retained counsel in the event of regulatory contact (otherwise $597/yr)
- Lifetime regulatory updates — instruments re-issued at no additional charge as federal and state rules change (otherwise $197/yr)
- Founder's Kit — bound binder, framed Certificate, display plaque, priority shipping
Verifiable on demand.
Each member shop receives a registered member number that any third party can verify in five seconds at LegalTuning.com/verify. Customers, insurers, suppliers, and counsel use the registry as the authoritative reference for program standing.
Member Defense, when contacted.
If a member shop is contacted by the EPA, CARB, or a state authority, Member Defense activates. Our compliance team prepares the evidence file, issues the litigation hold, and drafts response materials in coordination with the shop's retained counsel. Included with the Enterprise tier.
Adopt the Standard before contact, not after.
A documented compliance posture is a recognized mitigating factor in the calculation of civil penalties under the Clean Air Act. Adoption before regulatory contact materially changes the position available to retained counsel.
Legal Tuning is not a law firm. The Standard's instruments are operational templates and should be reviewed by qualified counsel before adoption.