Defect and Voluntary Emission Report System

Guidance for Submitting Emission Defect 

Information Reports and Voluntary Emission 

Recall Reports to the Verify Document Module
EPA-420-B-10-001

February 2009

Compliance and Innovative Strategies Division

Office of Transportation and Air Quality

U.S. Environmental Protection Agency

Defect and Voluntary Emission Report System

Guidance for Submitting Emission Defect 

Information Reports and Voluntary Emission 

Recall Reports to the VERIFY Document Module
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BACKGROUND AND INTRODUCTION

All manufacturers are required to submit reports to the United States 

Environmental Protection Agency (EPA) describing emission-related defects and 

plans for remediation of indicated defects to the EPA according to the regulations 

in 40 CFR §85.1903 and §85.1904, respectively. This document describes the 

general process for submitting electronic versions of Emissions Defect 

Information Reports (DR), Voluntary Emission Recall Reports (VERR), and 

VERR Quarterly Update Reports (QR) to the Verify Document Module. 

Previously, manufacturers submitted DRs, VERRs, and QRs to EPA in hard-copy 

form via regular mail delivery or in various electronic files via e-mail. To 

standardize the forms, improve the submission process, and provide for 

improved storage and use of the data EPA developed electronic forms to allow 

electronic submittal of DRs, VERRs, and QRs. In order to use existing systems 

and automate the submittal process, EPA is using the Document Module of the 

Verify data management system to collect these electronic files. 

Once the new DR/VERR/QR electronic forms are implemented, the process 

described in this document will be the only method available to manufacturers for 

submitting DR/VERR/QRs unless otherwise directed. 
DEFECT AND VOLUNTARY EMISSION REPORTS - 

VERIFY DOCUMENT MODULE SUBMITTAL PROCESS 

VERIFY DOCUMENT MODULE ACCESS VIA CDX

1. Log on to the Central Data Exchange (CDX) home page at 

http://www.epa.gov/cdx/ and enter your login name and password. 
2. Select “Log-in to CDX” in the blue panel on the left side of the page and 

enter your user name and your password on the CDX log-in page. (If you 

do not have a CDX account, see http://www.epa.gov/otaq/verify/setup.htm 

for the required steps to take). 

3. Following log-in, your personal CDX page, the “MyCDX” page, will load. 

On this page, you should select “Verify: Upload Compliance Documents” 

under the “Available Account Profiles” box. 

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4. Next, the page for submitting a document to Verify via CDX will load. You 

are now ready to enter the information needed for submitting DR/VERR 

Forms and Attachments to the Verify Document Module. 

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DEFECT AND VOLUNTARY EMISSION REPORTS - 

VERIFY DOCUMENT MODULE SUBMITTAL PROCESS

SUBMITTING DEFECT AND VOLUNTARY EMISSION RECALL REPORT 

FORMS AND ATTACHMENTS - INSTRUCTIONS FOR ENTERING 

INFORMATIION IN THE VERIFY DOCUMENT MODULE 

1. EPA Manufacturer Code: This field will be auto-populated based on the 

manufacturer code you entered during the CDX registration process. 

2. Document Path and File Name: You can type in the filename or you can 

select “Browse” and locate the file on your computer. The file that is being 

uploaded must already be saved on the submitter’s workstation according 

to the naming convention shown at the end of this document, which is 

much simpler than the document naming convention shown on the Verify 

Document Module’s Help Page. 

3. Industry: Select an industry from the pull-down menu. In the rare case 

that the DR/VERR you are submitting applies to multiple industries, you 

can select them all by holding down “Ctrl” on your keyboard and left click 

your mouse on each of the applicable industries. 

4. Compliance Document Type: Within the pull-down menu, there are 

several options depending on the type of document you are submitting 

(e.g. report or attachments). Below are the different options for entering 

data in this field. From the pull-down menu, you should select: 

a. “Defect Report (Report)” for submitting a defect report (DR); 

b. “Voluntary Emission Recall Report” for submitting a voluntary 

emission recall report (VERR) or a VERR quarterly update report 

(QR). 

DO NOT SELECT THE “VERR QUARTERLY UPDATE” OPTION! 

This will be handled under the subsequent field, “General 

Document Type”; or 

c. “Other” for a DR/VERR Attachment. A text box will appear that you 

are required to enter data into since you selected “Other”. In this 

field, you should indicate what type of report (e.g., DR or VERR) 

that this attachment applies to and the applicable report number 

(e.g., “DR attachment – 3522” or “VR attachment - 0021”). 

d. Note that attachments should not be submitted for QR’s. New 

documents that are created during the period covered by a QR 

should be submitted as an attachment to a revised VERR. 

 

5. Compliance Document Topic: Data can only be entered in this field 

when you have selected “Defect Report (Report)” or “Voluntary Emission 

Recall Report” for “Compliance Document Type” (see paragraph 4c 
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above). Below are the different options for entering data in this field. 

Depending on the type of report you are submitting, you should select: 

a. “Initial Report” or “Follow-up Report” for submitting a DR, 

depending on whether you are submitting it for the first time or are 

correcting/updating an existing DR, respectively; 

b. “Notification of Voluntary Recall” or “Follow-up Report” for 

submitting a voluntary emission recall report (VERR), depending on 

whether you are submitting it for the first time or are 

correcting/updating an existing VERR, respectively; 

c. “Quarterly Update Report” for submitting a VERR quarterly update 

report (QR). 

DO NOT SELECT THE “REMEDIAL PLANS” OPTION! The 

VERR includes the information that constitutes a remedial plan and, 

therefore, this option is not necessary. 

6. General Document Type: Data can only be entered in this field when 

you have selected “Other” for “Compliance Document Type” (see 

paragraph 4c above). Select the appropriate entry from the pull-down 

menu. 

7. Confidentiality Status: For manufacturers filing a report(s) for Light-Duty 

and Complete Heavy-Duty Vehicles and Trucks, you must select FOIA. 

For manufacturers filing a report(s) for Heavy-Duty or Nonroad engines, 

you may select CBI. 

8. Document Applicability: Since manufacturers will be including the test 

group information on the report(s) submitted to the Verify Document 

Module, manufacturers should select “General Applicability (do not specify 

any EF/TGs)” for this field. 

9. Does this document apply to one/multiple specific model year(s)?: In 

almost all cases, you should select “Yes” for this field. You will then be 

required to select the applicable model year(s) in the subsequent field. If 

Model Year is not applicable to your product or industry, please select 

“No”. 

10.Model Year: If the report applies to a single model year, please select the 

applicable model year. If the report applies to multiple model years, 

depress the “Ctrl” button on your keyboard and select each applicable 

model year. 

11.Document Date: Click the “Select” button to bring up a calendar and then 

select the date of the report. (The submittal date will be automatically 

recorded by the system.) 

12.Title: Enter the title of the document as it appears on the document you 

are submitting. For more guidance, you may click the “Help” button at the 

top of the form and follow the instructions given for this field. 
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13.Abstract: At the beginning of this field, you should enter the applicable 

DR or VERR number (e.g., 3522) to allow searching for a particular report. 

Note that in the case of a QR that applies to more than one VERR, the 

VERR numbers that the QR applies to should be entered as a comma 

separated list. 

Following the DR/VERR number, you may enter information that describes 

the document. For more guidance, you may click on the “Help” button at 

the top of the form and follow the instructions given for this field. 

14.Keywords: For all report types (DR/VERR/QR), you should select “InUse” at a minimum. For the VERR/QR, in addition to selecting “In-Use”, 

you should also select “Recall”. 

15.Are you the document owner?: If the person submitting the document 

to the Verify Document Module is also the person that should be 

contacted regarding details in the document being submitted, you should 

check “Yes” for this field. The Verify Document Module will automatically 

enter the information for the document owner name, phone number and email address in the appropriate boxes based on your Verify user account 

information. Otherwise, you should check “No” and enter the appropriate 

document owner’s name, phone number and e-mail address in the 

required text boxes. 

This information, along with the Verify user account information, will be 

used to automatically populate the submitter and contact information in 

EPA’s database and for reference by the EPA. Therefore, please ensure 

the accuracy of this information when entering data. 

16.Comments: You may enter any additional details or notes in this field 

that you feel are relevant and necessary. For more guidance, you may 

click on the “Help” button at the top of the form and follow the instructions 

given for this field. 

17. As noted throughout these instructions, there is a Help button at the top of 

the page that will provide guidance for each field in the Verify Document 

Module submittal page. 

18.If you want to resubmit a document: Each document that is submitted 

to the Verify Document Module must have a unique name. If you have to 

resubmit a document because it was not accepted by the Verify Document 

Module, you will have to rename the file with a unique file name. In this 

case you only need to add a lower case letter, starting with the letter “a” 

and incrementing upward in alphabetical order, at the end of the “Version 

Indicator” field. For example, if you submitted a file with a minor error in it 

named: 

 FOI_ABC_DRE_0013_BD_R00.pdf 

the corrected and resubmitted file should be renamed: 
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 FOI_ABC_DRE_0013_BD_R00a.pdf 

If multiple resubmissions are required, increment the lower case letter for 

each successive resubmission (e.g., “a”, “b”, “c”). 

NOTE: This character is only necessary if a document you 

submitted was not accepted by the Verify Document Module. 

Otherwise, you may leave this character off of the file name. 
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Naming a Document File 

A name of a document file consists of four sections: 

Confidentiality_ Applicability_ Information Type_ Version Indicator. suffix [file type] 

Each section has multi-elements as listed in the following table: 

Section 1 

Confidentiality 

(3 characters + underscore) 

Section 2 

Applicability 

(3 characters + underscore) 

Section 3

Information Type

(9 characters + 3 underscores) 

Section 4 

Version and 

Submission 

Indicator 

(4 characters) 

• CBI_: a confidential file 

that will not be released to 

the public 

• FOI _: a non-confidential 

file after remove 

confidential information 

from a CBI file so that it is 

readily releasable to the 

public after your 

vehicles/engines are 

introduced into commerce 

• Manufacturer Code_: the 

three character code used by 

the manufacturer in VERIFY

• DRE_XXXX_BD_: Defect report (1) (4)

• VER_ XXXX_BD_: Voluntary emission 

recall report (1) (4) 

• QR#_ YYYY_BD_: Voluntary emission 

recall quarterly report (2)(3)(4) 

Notes: 

 (1)

“XXXX_” should be the four digits DR or 

VERR number assigned by the manufacturer. 

(2)

“#”should be 1, 2, 3 or 4 indicating the 

quarter of the calendar year that the report 

applies to. 

 (3)

“YYYY_” should be the calendar year the 

report applies to. 

(4)

“BD_” (Base Document) should only be 

changed to one of the following when a 

document is an attachment to a DR or a 

VERR: 

 ED: Emissions Data 

 DN: Dealer Notification 

 ON: Owner Notification 

 RI: Repair Instructions 

 SB: Technical Service Bulletin 

 SL: Sample Repair Label 

 OT: Other 

Version Indicator 

(Characters 1-3) 

• R00: original 

• R01: 1

sty 

revision 

• R02: 2

nod 

revision 

• ..... etc. 

Submission 

Indicator 

(Character 4; 

optional: only 

required if you are 

resubmitting a 

document following 

an unsuccessful 

submission) 

• RXXa: 1st

resubmission of same 

document 

• RXXb: 2nd

resubmission of same 

document 

• ..... etc. 

 
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Examples: 

Reports submitted by manufacturer ABC: 

b1. Example Names for DR/VERR/QR Report Files

Application File Name Name Explanation 

FOI_ABC_DRE_0013_BD_R02 Public file with CBI (Confidential Business 

Information) removed, for manufacturer ABC, Defect 

Report #0013, second revision. 

CBI_ABC_VER_0014_BD_R00 File containing Confidential Business Information, for 

manufacturer ABC, Voluntary Emission Recall Report 

#0014, original version. 

FOI_ABC_QR3_2009_BD_R00 Public file with CBI (Confidential Business 

Information) removed, for manufacturer ABC, 

Voluntary Emission Recall Quarterly Reports for 3Q 

2009, original version. 

FOI_ABC_DRE_0013_BD_R02a Public file with CBI (Confidential Business 

Information) removed, for manufacturer ABC, Defect 

Report #0013, second revision, first resubmission 

following unsuccessful submission 

b2. Example Names for Attachments to DR/VERR Report Files 

Application File Name Name Explanation 

CBI_ABC_DRE_0013_ED_R00 File containing Confidential Business Information, for 

manufacturer ABC, Defect Report #0013, Available 

Emissions Data, original version. 

FOI_ABC_VER_0014_SB_R00 Public file with CBI (Confidential Business 

Information) removed, for manufacturer ABC, 

Voluntary Emission Recall Report #0014, Technical 

Service Bulletin, original version.