EPA “Freedom to Fix” Guidance
What It Means for Independent Repair Shops
Prepared for NWACA Membership | Thomas Richardson, Mechanical Chair | July 2026
On June 29, 2026, President Trump signed a Presidential Memorandum, “Lowering the Cost of Living by Promoting the Freedom to Fix,” directing EPA to clarify vehicle owners’ and independent shops’ rights to perform emissions-related repairs under the Clean Air Act (CAA). EPA Administrator Lee Zeldin noted this is a memorandum, not a formal executive order. EPA responded with implementing guidance on July 1, 2026 (letter IACD 2026-08), plus a certification-authority action recognizing SEMA as an alternative to CARB. None of this changes the underlying law, weakens emission standards, or reduces compliance obligations it is EPA’s clarification of existing CAA provisions and manufacturer obligations. Timeline
Date and Action
Feb 3, 2026 – EPA issued IACD-2026-01, affirming Right-to-Repair for nonroad diesel equipment (ag/farm machinery).
Jun 29, 2026 – Presidential Memorandum signed, directing EPA to issue on-road guidance within 30 days.
Jul 1, 2026 – EPA issued IACD-2026-08 to on-road manufacturers (LDV, LDT, HDE), clarifying service info and repair obligations.
Jul 1–2, 2026 – EPA recognized SEMA’s Certified Emissions (SC-E) Program as an alternative CAA certification authority to CARB.
Key Points for Shops
1. Manufacturer Service & Repair Information
EPA reaffirmed that under existing CAA regulations, manufacturers of light-duty vehicles/trucks and heavy- duty engines must make available to independent shops and owners the same emissions-related service information they give their own franchised dealers. Per the July 1 letter, this includes:
● Full emissions-related service information and training materials, published on the manufacturer’s
website
● Passthrough reprogramming capability information for tool makers
● Enhanced OBD diagnostic information for scan tool developers
● Manufacturer-specific diagnostic tools, available for purchase
● Additional required OBD technical information
This does not extend to proprietary designs, source code, or legitimately protected confidential business information — that stays shielded.
2. Temporary Emission-System Overrides for Repair
EPA’s letter reiterates the long-standing CAA position (42 U.S.C. 7522(a); 40 CFR 1068.101) that temporarily taking a vehicle out of its certified emissions configuration is not a prohibited act if it’s done for the purpose of repair, provided the vehicle is restored to proper certified function before being returned to service. This covers things like clearing/overriding a DEF-related derate or disabling a sensor temporarily to diagnose a fault — as long as the vehicle goes back out the door in proper working configuration.
3. Aftermarket Parts Certification — SEMA as Alternative to CARB
CARB has been the sole recognized certifier of aftermarket emissions-related parts, with a backlog EPA describes as routinely exceeding a year. EPA has now recognized SEMA’s Certified Emissions (SC-E) Program as an additional certification pathway. Parts certified through SC-E can be represented as CAA- compliant without a CARB Executive Order. This is aimed at increasing aftermarket parts supply and reducing cost, and at making it easier to avoid counterfeit/knockoff parts.
Caveat worth flagging to members: using a non-certified or generic part does not obligate the manufacturer to honor an emissions warranty claim tied to that part. Certified generic/equivalent parts are protected from being treated as “tampering,” but warranty coverage is a separate question.
4. Enforcement Posture
The memorandum directs EPA to “consider deprioritizing” civil tampering enforcement actions against individuals who, in good faith, attempt to restore their own vehicle to its original certified configuration. This is a discretionary enforcement-priority signal, not a change to the statute — CAA anti-tampering provisions (Section 203) remain in force for genuine tampering that isn’t in the course of a bona fide repair.
What This Does Not Do
● Does not repeal or amend the Clean Air Act or its anti-tampering provisions
● Does not eliminate CARB’s role — CARB certification remains valid, SEMA is now an additional option
● Does not create new warranty obligations for manufacturers when non-OEM parts are used
● Does not shield genuine tampering (permanent defeat devices, disabling controls with no intent to repair) from enforcement
● Carries no force of law itself — EPA’s letter explicitly states it does not bind EPA or manufacturers and is offered only as clarification Practical Takeaways for Member Shops
● Expect manufacturers to face renewed pressure to publish complete service info online (already partly required since 2003/2009 EPA rules) — worth testing access on your OEM portals if you’ve had gaps.
● SEMA SC-E certification may open up a faster-to-market supply of compliant aftermarket parts, particularly useful for shops fighting CARB backlog on part sourcing.
● Document repairs involving temporary emission-system overrides (DEF systems, sensor bypass for diagnosis) showing the vehicle was restored to proper certified function — this is exactly the kind of good-faith repair record the guidance is meant to protect.
● This is guidance, not law — a future administration or EPA action could revise or withdraw it. Don’t treat it as a permanent shield; keep documentation habits regardless.
Sources
EPA, “Freedom to Fix” — epa.gov/ve-certification/freedom-fix
EPA Letter IACD-2026-08 (LDV, LDT, HDE), July 1, 2026
EPA Press Release, “EPA Delivers on President’s ‘Freedom to Fix’ Memorandum for Vehicles and Equipment,” July 2026
The White House, Presidential Memorandum “Lowering the Cost of Living by Promoting the Freedom to Fix,” June 29, 2026
