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Truck OEMs | EPA 27 Update Provides More Flexibility
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Truck OEMs | EPA 27 Update Provides More Flexibility
gives OEMs
a more workable bridge into '27. A hard stop on legacy engines seems less likely with a small
carve-out of pre-2027 engines without eating credits, plus NCPs for engines that are close but
not fully compliant. As a result, the '27 supply cliff is less likely, and the pre-buy incentive is less
about scarcity risk and more about price/warranty timing.
Non-conformance penalties an interesting influence on pricing. The NCP framework allows
manufacturers whose engines cannot yet meet the new NOx standard to continue selling
MY26 engines in MY27 by paying a per-engine penalty, provided NOx does not exceed 200 mg/
hp-hr (the MY26 standard). Penalties scale with the shortfall: up to c$4.3k in MD and $6.8k in
HD vs zero if the engine is compliant. In Heavy Duty, for example, the penalty is on a sliding
scale from $0 at 35mg to $6.8k at 200mg. This gives lower NOX-emitting '26 engines a pricing
edge in '27.
What certification data shows about current NOX emissions. Using EPA MY26 heavy-duty
highway certification data, the ranking on steady-state NOx results and SS certified results is
clear. Paccar (MX engines) has the single lowest reading in the dataset, with the next family
clustered around Daimler (Detroit). Volvo sits in the middle of the pack. Cummins is the clear Michael Aspinall * | Equity Analyst
laggard, with all four sampled engine families clustered much higher. As a result, Paccar and +44 (0) 20 7029 8431 | maspinall@jefferies.com
Daimler look best positioned for a smooth EPA27 transition, Volvo has enough efficient engine Stephen Volkmann, CFA ^ | Equity Analyst
families to work with, and Cummins has the furthest to travel. +1 (212) 284-2031 | svolkmann@jefferies.com
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