The full implications of China’s Non-Road Stage IV (NR IV) Off-Road Emissions Regulations are just now beginning to come into focus as manufacturers begin to understand the their requirements. And while they are widely – and rightly – perceived as engines emissions requirements, machine manufacturers need to possess a strong understanding of China’s NR IV rule-making process, what the regulations require and – perhaps most importantly – its impacts on the product design process and the unique requirements it places on equipment OEMs.
With that fact in mind, AEM recently hosted a webinar on the topic of NR IV featuring valuable insights from Chris Walters, manager of global regulatory affairs with AEM member company CNH Industrial. The purpose of the webinar was to share information with fellow member company as they review China NR IV’s requirements.
“The work that we’ve done in the United States and China on NR IV has been quite the long and winding road,” said Walters. “Thankfully, we’re getting to the end of that road. At this point, with the requirements being finalized for several months, we can start to digest all of this and share our understanding of what the rulemaking looks like and what will be required to maintain compliance.”
Here are some key takeaways, courtesy of the recent AEM webinar:
Timeline, Applicability and Scope
The effective date of China NR IV is Dec. 1, 2022. – However, it should be noted that Beijing, China has adopted its own metropolitan region rule with an effective date of Dec. 1, 2021.
China NR IV will apply to all non-road mobile machinery diesel applications in all power ranges, including Ag, CE and portable power generation. – China NR IV applies to diesel applications only. NR IV does not apply to compressed natural gas (CNG), liquified natural gas (LNG) or gasoline engines.
China NR IV sets the standard for all power ranges, even above 560 kilowatts (kW). – However, it does not set an effective date for engines above 560 kW. At some point in time, there will likely be an amendment to define the above-560-kilowatt effective date.
There are no transition or sell-off periods. – Current NR III engines and machines must be built, imported and sold before the effective date.
The China NR IV emissions limits follow the European Union Stage IIIB standards, but also include particulate number (PN) count limits for engines 37-560 kW. Diesel particulate filters (DPFs) are mandatory.
Emissions Warranty Period
The emissions warranty period starts from the date of sale and the duration is aligned with U.S. EPA requirements for non-road engines. However, information about what is warranted is also a key consideration.
“We term these as emissions-related components. And it’s basically any part that, if it fails, can have an adverse impact on emissions of the engine,” explained Walters. “Things like turbochargers or fuel pumps are included. This is a new requirement in China. China NR 3 engines do not have a warranty period requirement.”
Emissions Control Diagnostics
Engines using SCR or EGR systems will need to meet NOx control diagnostic requirements. In addition, there are particulate control diagnostics related to engines using DPFs.
“There are several annexes in the regulation that describe this information, but there also is ongoing development of other standards that will relate to these control diagnostic requirements,” said Walters.
Additional requirements related to software and diagnostics include GPS for all machines equipped with engines greater than 37 kW and a first-of-its-kind remote terminal requirement related to telematics data that is to be sent to the authorities for construction machines with engines greater than 37 kW.
PEMS (Portable Emissions Measurements System) Testing
PEMS testing is required for all machines above 37 kW as a conformity of production check and as an in-use compliance check. The manufacturer’s plan for PEMS testing of the machinery must be submitted at type approval.
For More Information
A variety of regulatory documents are available for engine and machine manufacturers looking for additional details related to China NR IV and its impact. (AEM membership log-in is required.)
- GB20891-2014 amendment
- GB36886-2018 (smoke)
- HJ437-2008 (software diagnostics)
AEM Safety & Product Leadership
“Do it once, do it right, do it globally” has been the longstanding motto of AEM’s Safety & Product Leadership Department, and it guides their efforts in addressing ever-increasing global demands on equipment manufacturers to develop machines that are safe, productive and compliant. To learn more, visit https://www.aem.org/safety-product-leadership.