They Sold 635 Illegal Smog Devices. The Government Let Them Off for $12,415.
TL;DR
- Domestic Gaskets, a motor vehicle parts company based in El Monte, California, sold 635 illegal “EGR delete kits” between January 1, 2019, and July 8, 2021, devices whose sole function is to destroy the emissions control systems built into diesel trucks by Ford, General Motors, and Fiat Chrysler.
- Each of those 635 sales was a separate violation of the Clean Air Act, and each carried a maximum penalty of $5,580 per violation, meaning the EPA could have assessed up to $3,543,300 (enough to fund a full year of clean air monitoring across an entire metropolitan region).
- Instead, the EPA settled for just $12,415 (roughly the cost of a decent used car, or four months of groceries for a family of four), after Domestic Gaskets claimed it could not afford more.
- The company sold 27 distinct defeat device products across multiple truck platforms including Ford Powerstroke, Dodge Ram Cummins, and Chevy/GMC Duramax diesel engines, reaching customers across the entire United States.
- Domestic Gaskets has certified it stopped selling these parts, but the penalty it paid amounts to less than $20 per illegal device, creating almost zero deterrence for any future violator.
A California auto parts company sold 635 devices specifically engineered to gut the pollution controls on diesel trucks, and the federal government’s punishment was $12,415 (roughly what a single family pays in rent over three months in Los Angeles).
What an EGR Delete Kit Actually Does to Your Air
Exhaust Gas Recirculation, or EGR, is a technology that diesel truck manufacturers are legally required to install. It works by cycling exhaust back through the engine, dropping combustion temperatures and cutting oxides of nitrogen, known as NOx, before those gases ever reach the tailpipe. NOx is not a minor inconvenience. It is a primary driver of smog, ground-level ozone, and particulate matter, all of which the EPA links directly to lung disease, heart attacks, and premature death.
An EGR delete kit does exactly one thing: it physically blocks the EGR port so exhaust gases bypass the recirculation system entirely. The truck runs hotter, burns dirtier, and pumps uncontrolled NOx and particulate matter into the air. Every vehicle equipped with one of these kits becomes a rolling violation of federal emissions law, and every community those trucks drive through breathes the consequences.
Domestic Gaskets sold 27 different versions of these kits, marketed specifically for Ford F-250s, Ford F-350s, Dodge Ram 2500s, Dodge Ram 3500s, Chevrolet Silverados, and GMC Sierras. They listed these products openly on business-to-consumer e-commerce websites. They knew exactly what the kits were for, because the products themselves said so in their names.
β EPA Consent Agreement and Final Order, February 6, 2024
The Scale: 635 Violations, 27 Products, Three Major Truck Platforms
The EPA’s investigation covered a period of just over two and a half years, from January 1, 2019, through July 8, 2021. In that window, Domestic Gaskets moved 635 individual defeat devices. The single best-selling product, part number SD-EGRD-6.0, an EGR delete kit for the 2003-2007 Ford F-250/F-350 with the 6.0L Powerstroke diesel engine, accounted for 319 units on its own. That is more than half the total, sold under a single SKU.
The EPA identified these violations through two channels: a formal Information Request sent to the company on July 8, 2021, and a direct review of the company’s own e-commerce sales listings. Domestic Gaskets responded to that information request and provided data that the EPA then used to count and categorize every violation. The company, in other words, handed regulators the evidence.
The Non-Financial Ledger: What Money Cannot Measure
The word “defeat” in “defeat device” is doing real work. These kits do not tune a truck. They do not improve performance in any way that emissions controls would not also allow. They defeat a safety system. They defeat technology that Congress mandated after recognizing, in the text of the Clean Air Act itself, that “the increasing use of motor vehicles has resulted in mounting dangers to the public health and welfare.” Every one of Domestic Gaskets’ 635 customers put one of these kits on a working diesel truck and then drove that truck through neighborhoods, past schools, alongside pedestrians, and over roads shared with everyone else.
Those 635 trucks did not stay in the driveway. Diesel F-250s and F-350s, Ram 2500s and 3500s, Silverados and Sierra 2500s: these are working trucks. They haul loads. They idle at job sites. They sit in traffic in communities that already carry disproportionate pollution burdens. Each one, once the EGR system was deleted, became a machine producing uncontrolled NOx and particulate matter with zero federal oversight, for every mile driven after the kit was installed. The EPA’s settlement covers the sales window of January 2019 through July 2021. There is no accounting in this document for how many miles those trucks logged after the kit went in, or for how many years they will continue to run dirty.
There is a particular kind of betrayal embedded in how these products were marketed. The kits carried product names like “Complete EGR Delete Kit” and “EGR Valve Cooler Delete Kit,” and they listed the exact vehicle models they were designed to compromise. Domestic Gaskets did not obscure what these products were. They advertised them openly on business-to-consumer e-commerce websites where anyone could find them. The company’s own product descriptions, used by the EPA as evidence, are a catalog of emissions sabotage sold retail, like a toolbox or a set of floor mats.
The dignity loss here belongs to every person who breathes the air in the communities where these trucks operate. It belongs to the child with asthma who lives near a highway. It belongs to the elderly resident whose cardiovascular system is already compromised. It belongs to the outdoor worker who has no choice but to be in the air. None of these people consented to being a recipient of Domestic Gaskets’ products. None of them received notice that a truck near them had been deliberately stripped of its pollution controls. And none of them will receive a cent from the $12,415 (about the cost of four months of insulin for an uninsured diabetic American) that the company paid to make this case go away.
Legal Receipts: The Documents That Condemn Them
“The Subject Parts were EGR delete kits. Each Subject Part, at all relevant times herein, was intended for use with certified motor vehicles and motor vehicle engines including those manufactured by General Motors Company, Ford Motor Company, and Fiat Chrysler Automobiles U.S. LLC. The purpose of these EGR delete kits were to block the EGR port to prevent recirculation of the exhaust gases.” EPA Consent Agreement and Final Order, Paragraphs 23β25
“Respondent’s sale of the Subject Parts constitute 635 separate violations of section 203(a)(3)(B) of the CAA, 42 U.S.C. Β§ 7522(a)(3)(B), which prohibits any person from manufacturing, selling, offering to sell, or installing parts or components where a principal effect is to bypass, defeat, or render inoperative a motor vehicle emission control device or element of design, where the person knows or should know that the part is being offered for sale or installed for such use.” EPA Consent Agreement and Final Order, Paragraph 30
“Congress found, in part, that ‘the increasing use of motor vehicles . . . has resulted in mounting dangers to the public health and welfare.'” EPA Consent Agreement and Final Order, Paragraph 5, citing Section 101(a)(2) of the Clean Air Act, 42 U.S.C. Β§ 7401(a)(2)
“Respondent claimed it was unable to pay the full penalty as originally proposed and submitted financial information to the EPA to support its claim. Based on those findings, the parties agree to the assessment of a civil penalty in the amount of twelve thousand four hundred fifteen dollars ($12,415) as final settlement of the civil claims against Respondent arising under the CAA as alleged above.” EPA Consent Agreement and Final Order, Paragraph 32
“Respondent knew or should have known that each Subject Part was being offered for sale or installed for such use or put to such use.” EPA Consent Agreement and Final Order, Paragraph 28
The Penalty Gap: What the EPA Could Have Charged vs. What They Accepted
Societal Impact: Who Actually Pays the Price
Public Health: Every Breath Costs Someone Something
The Clean Air Act exists because Congress made a formal finding that vehicle emissions endanger public health and welfare. The EPA’s own case document cites this finding explicitly: “the increasing use of motor vehicles has resulted in mounting dangers to the public health and welfare.” EGR technology specifically targets NOx, which the EPA regulates because it forms ground-level ozone and particulate matter, both of which are directly linked to respiratory disease, cardiovascular disease, and early death.
The 635 trucks equipped with Domestic Gaskets’ defeat devices did not all park in one place. They spread across the United States, driven by customers who bought them on e-commerce platforms with nationwide shipping. Every truck that ran with a deleted EGR system contributed uncontrolled NOx to whatever air it moved through. There is no geographic containment. There is no community that could opt out.
The public health harm is structural, not incidental. Diesel engine emissions are already associated with disproportionate health burdens in communities near freight corridors, highways, and industrial zones. Adding 635 more uncontrolled diesel trucks to that load compounds an existing crisis. The people breathing the worst air in America were already doing so before Domestic Gaskets made it worse, and the $12,415 (less than a single emergency room visit for a severe asthma attack) does nothing to address the harm caused.
Economic Inequality: Poverty as a Corporate Defense Strategy
The most clarifying sentence in the entire EPA settlement document is in Paragraph 32: “Respondent claimed it was unable to pay the full penalty as originally proposed and submitted financial information to the EPA to support its claim.” The maximum penalty for 635 violations at $5,580 each is $3,543,300 (enough to fund a school district’s entire environmental education program for a decade). Domestic Gaskets paid $12,415 (roughly what an average American worker earns in four months of minimum-wage labor).
This is how the system works for small operators. Large corporations like Volkswagen faced penalties in the billions for defeat device fraud. Small companies claim poverty and walk away for the cost of a car payment. The people breathing the pollution from those 635 trucks do not get a poverty discount on their medical bills. They do not get to tell the hospital they cannot pay their deductible because the business that poisoned their air settled for pennies. Economic inequality does not end at the point of pollution; it runs through the enforcement system as well.
The per-device penalty Domestic Gaskets paid works out to approximately $19.55 per defeat device sold. For any future actor watching this settlement, the message is clear: the financial risk of selling illegal emissions-defeating hardware is lower than the cost of a tank of diesel fuel.
The “Cost of a Life” Metric
What Now? Here Is Where the Power Is
Who Signed This Agreement
The settlement was signed on behalf of the EPA’s enforcement division by Kaoru Morimoto, Assistant Director of the Air, Waste, and Chemicals Branch, Enforcement and Compliance Assurance Division, EPA Region IX. The Final Order was issued by Beatrice Wong, Regional Judicial Officer, EPA Region IX. Domestic Gaskets is represented of record by attorney Tom Keiser, listed as counsel on behalf of Mizumo Auto.
Regulatory Bodies With Jurisdiction Here
- EPA Region IX Enforcement and Compliance Assurance Division (primary regulator in this case)
- EPA Office of Enforcement and Compliance Assurance (national oversight)
- Department of Justice (civil enforcement escalation path under the CAA)
- California Air Resources Board (CARB) (California-specific emissions authority for vehicles operated in-state)
- Federal Trade Commission (consumer protection angle: these products were sold openly on e-commerce platforms)
The Watchlist
- Search EPA’s enforcement case database for future actions against Domestic Gaskets or related entities
- Watch for EGR delete kit listings on major e-commerce platforms. Reporting them to the EPA is legal and encouraged under the CAA’s information provision powers
- Track CARB enforcement actions, which carry higher penalties and stronger enforcement posture than federal minimums
- Follow the EPA’s “Tampering Policy: The EPA Enforcement Policy on Vehicle and Engine Tampering and Aftermarket Defeat Devices under the Clean Air Act” (November 23, 2020), cited in this settlement
What You Can Do Right Now
Connect with local environmental justice organizations in your region, particularly those working in communities near freight corridors and highways where diesel truck traffic is heaviest. Groups like the Sierra Club’s environmental justice programs, local air quality coalitions, and mutual aid networks tied to public health advocacy are already doing this work and need bodies, voices, and resources. Contact your congressional representative and demand they ask the EPA to explain why a company that committed 635 federal violations paid less than $20 per violation. Pressure the EPA to close the “inability to pay” loophole that allowed this settlement, or at minimum to require ongoing compliance monitoring, public disclosure, and third-party auditing as conditions of any reduced-penalty agreement. The system will not fix itself. Enforce it yourself by showing up, speaking loudly, and refusing to let $19.55 per violation be the standard.
The source document for this investigation is attached below.
Please click on this EPA link to see the above EPA documentation on this case: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/AC0E503741E35E2285258ABC000BDF14/$File/Domestic%20Gaskets%20(CAA-09-2024-0027)%20-%20Filed%20CAFO.pdf
There is also a press release from the EPA’s website: https://www.epa.gov/newsreleases/epa-fines-southern-california-auto-parts-companies-defeat-devices-harming-air-quality
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