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this post was submitted on 11 Jan 2024
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EPA only requires recall tracking for 18 months. After that they give up. Also:
Enforcement of emissions regulations are very reliant on state inspection programs, and not every state has an inspection program.
In this case, Cummins would only contract with outside mechanics if dealers were unable to handle the volume or modifications. If an owner brings their vehicle to a third-party, Cummins is still responsible for paying for the fix. But in this case the fix seems to be an update to the ECU, which is generally only accomplished at a dealer.
Driver licensing/vehicle registration is handled by the states, and would only be in jeopardy if a state has an inspection program.
The EPA reserves the right to extend a recall program, and in this case the publicity certainly warrants it. But aside from living in a CARB state or having to pass a different inspection, there's no enforcement of recall compliance.