July 21, 2025
By Edward Coffey, EPA Region 9 Office of Public Affairs

LOS ANGELES — Every day, workers at the Ports of Long Beach and Los Angeles, the highest-volume ports in America, move approximately 50,000 containers, translating to about $1.2 billion of goods movement that support retailers, construction, the automotive industry and other sectors of the economy. Among those containers, and those at multiple ports in Region 9, are products like pesticides, engines, appliances and vehicle emission defeat devices that can potentially pollute the communities where they end up.

Enter U.S. Environmental Protection Agency inspectors, working with Customs and Border Protection (CBP), to ensure the cargo offloaded daily complies with U.S. laws like the Clean Air Act (CAA) and the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

"I ensure engines, vehicles, refrigerants that are coming into the country are conforming to the Clean Air Act," said Gem Guzman, a life scientist and enforcement inspector with EPA Region 9's Enforcement and Compliance Assurance Division (ECAD). "I look to see that the engines are certified or that the refrigerants are coming from approved sources."

Erika Pauley, another enforcement inspector with ECAD, focuses on imports into the Ports of Long Beach and Los Angeles and imports on the southern border, where she works closely with the CBP.

"I have always been very focused on the environment and what it means to people," said Pauley. "I feel like I can be part of the solution, ensure that everyone's in compliance so that way we can all equally enjoy clean air together."

Both Pauley and Guzman are part of a small, dedicated team of Clean Air Act and FIFRA inspectors located in EPA's Southern California Field Office. The team's work typically originates from recommendations from CBP, a vital federal agency partner that ECAD works closely with to prevent illegal products from entering the country. Whenever potential products of concern are identified, CBP sends referrals to EPA to determine if those imports comply with the CAA, FIFRA and the American Innovation and Manufacturing Act.

"They are inspecting engines that would come into the United States to determine if they are heavy polluters of nitrous oxides or nitrogen oxides, sulfur, carbon monoxide," said Pauley.

When Guzman or Pauley inspect engines in shipments, they look for vehicle control information that indicates the engine is certified by the EPA. Additionally, they will check if labels are fraudulent.

"Most of the time, I would say, unfortunately, the engines don't have the vehicle emission control information sticker," said Guzman. "That means they are not certified at the time they're declared. Then I reach out to the broker or importer, and I request supporting documentation."

If there's no supporting documentation, inspectors seize the items and provide CBP with a recommendation for denial. Additional items that come through our ports, such as pesticides, appliances and defeat devices, undergo the same scrutiny.

Guzman will reach out to offenders to allow them to rectify issues with imports. "A lot of them are foreign importers. A lot of them are shell companies, unfortunately. Once we do have confirmation from the importer, then we often issue a civil penalty, and then once they pay that penalty, we close the case," said Guzman.

Understanding the background of an importer often entails business research provided by the Region 9 Environmental Information Center librarians. "We look into as many factors as we can possibly find to determine the size of the violator," said Pauley. "If this is a first-time violator, if this is someone who's violated before, and we take all those factors into consideration in our formal enforcement actions."

Formal enforcement actions are done in close coordination with the Region 9 Office of Regional Counsel and can lead to penalties. In the case of illegal engines, the penalties can include the statutory maximum per engine. The work of EPA personnel at these ports has resulted in the seizure of tens of thousands of illegal engines and chemicals and fines into the millions of dollars. Most importantly, these efforts ultimately protect human health and the environment.

Past interventions by ECAD inspectors have led to enforcement actions like a $1.6 million settlement with Sinister Diesel for aftermarket emission defeat devices; over $530,000 in civil penalties to multiple offenders for thousands of illegal small engines meant for ATVs, motorcycles, generators and lawn equipment; and the intercept of unregistered disinfectants at the Port of Los Angeles falsely claiming to protect against viruses, including COVID-19.

Region 9 inspectors are on the front lines in the fight against illegal imports throughout the country. Working with Region 9 personnel and our CBP partners, enforcement and compliance assurance prevents illegal products from entering the country while protecting our environment and communities and ensuring companies that play by the rules are not disadvantaged by those that don't.