Chinese Non-Road Stage 4Facing the current severe environmental situation in China, the Chinese Ministry of Ecology and Environment (MEE) is very determined to regulate future non-road mobile machinery engine emissions to one of the most stringent levels worldwide.

The latest information indicates that the regulation will be in effect Jan. 1, 2020, leaving a very short time for engine and equipment manufacturers to prepare.

Unlike the previous Stage 1 through Stage 3 Chinese non-road emissions regulations, ones that only regulated diesel engine manufacturers, the draft Chinese non-road Stage 4 emission regulation (NR-4) applies to both engines and non-road machines. The first draft of NR-4, released in February of 2018, was a mixture of:

  • EU Stage III-B requirements
  • EU Stage IV inducement
  • Portable Emissions Measurement System (PEMS) requirements
  • EU Stage V Particulate Number (PN) requirements
  • Chinese unique satellite positioning requirements

These requirements, along with a number of other regulatory demands, make for a complicated regulation that brings unprecedented challenges to equipment manufacturers, especially those who manufacture non-road mobile machines.

As drafting of NR-4 began in the fall of 2016, AEM has worked closely with MEE and its regulatory partners to represent AEM members concerns with a unified voice backed by 89 representatives from 33 member companies.

Thanks to the great contributions and technical input from members, AEM managed to gain trust and support from MEE. In addition, AEM has been the only non-Chinese organization invited by the Ministry to its Industry Expert Panel Meetings, which serves as the last step to finalize the draft. AEM will participate along with a handful of Chinese domestic non-road machinery trade associations and domestic manufacturers of diesel engines and non-road machines. Throughout this effort, AEM has also collaborated with the Truck and Engine Manufacturers Association (EMA) from the United States and the European Association of Internal Combustion Engine Manufacturers (EUROMOT).

After rounds of explanatory discussions held with MEE and the drafting committee, approximately 70 percent of AEM’s proposals were accepted, including a number of major breakthroughs.  

Key AEM proposals, some verbally agreed to by MEE as of June 2018, include the following:

  • MEE agreed to allow the assigned/specific Deterioration Factors (DF) to be used, with manufacturers ensuring compliance to the limits of the regulation. This can help members simplify the test procedures required and reduce type approval time requirements significantly, even by approximately six months.
  • MEE agreed to significantly reduce the number of Portable Emissions Measurement System (PEMS) tests required and to use PEMS tests mainly for surveillance purposes. This can help members to reduce the number of PEMS tests required and save a significant amount of testing expense.
  • MEE agreed to delete/rewrite a requirement that each new machine be tested for smoke emissions at the end of the production line and that the test results be published in the MEE system.
  • MEE agreed to allow for more test facilities to be authorized, including manufacturers’ own in-country facilities. With thousands of manufacturers needing to conduct compliance testing to NR-4 and China on-highway Tier 6, required testing would overwhelm the originally approved test facilities.
  • MEE agreed to change the warranty requirements to match the U.S. requirements. The original draft had a much longer warranty period than the U.S. requirements.
  • MEE agreed to allow engines over 560 kW to remain at current Chinese NR Stage 3 level instead of NR Stage 4 levels.

AEM has presented a webinar providing a high-level update on the China NR 4 regulation and its requirements. This webinar provides valuable information to both engine manufacturers and equipment manufacturers in light of the proposed Jan.1, 2020 implementation date and lack of transition period.

Access the webinar now.

For more information, contact Amy Wang in AEM’s China Office (, tel: 86-10-8519-1566).

Subscribe to our AEM newsletters for more information related to industry regulations.