Emissions Standards for Gray Market Vehicles
Idrive a gray market 1982 Mercedes 200, a W123 model with the 2-liter M102 engine with a Stromberg carburetor. When it was time for the dreaded missions inspection in August, the emissions
testing facility informed me that there was a
Virginia law stating that gray market vehicles do not
need to undergo the emissions test (Section 46.2-
1177 sub-paragraph 3 of the Air Pollution Control
Law of Virginia, link below) because of an exemption
for any “vehicle which, at the time of its manufacture,
was not designed to meet emissions standards
set or approved by the federal government.” That
was good news.
I called the emissions officer on duty at the
Northern Virginia Regional Office of the Department
of Environmental Control at (703) 583-3800, and he
explained that he either needed to see the EPAimport
documentation or check the car himself at his office
in Woodbridge, Va. So I made the drive down over
lunch and met with a very nice representative of the
office who took down my VIN number and visually
inspected the car while I explained some of the history
of my 200 to him.
The next day he called me and confirmed that I
did not need to undergo the emissions test and that he
would send me a memo to take to the DMV for the
registration renewal. At the DMV, I needed the assistance
of a supervisor to finalize the registration, but
things went fast and smooth overall.
My research seems to indicate that this law has
probably been in effect since at least 1995, and I
would not have had to take the test in 2003 (the original
owner always underwent the test as well), but I
was only aware of the waiver for cars older than 25
model years. This experience serves as a reminder
that there is no perfect information no matter how
much we think we know about a subject.
— Eric Wagner
Link to the Air Pollution Control Law on the DEQ website:
www.deq.state.va.us/regulations/pdf/airlaw2003.pdf