Caught at the Warehouse Door

Step One: Claim They’re Not Regulated. Wrong.

When the shipment was flagged, Naomi Trading’s first move was to claim the chainsaws fell under Disclaim Code A, which is the official designation importers use to assert that a product is not regulated by the EPA. Federal inspectors checked. The EPA regulates gas-powered chainsaws. The disclaim code did not apply. The claim was rejected outright.

Rather than come clean, the importer or its broker then submitted EPA Form 3520-21 and pointed to a specific engine family certification: SZJTS.0525ZJ. This is the paperwork move that was supposed to make everything look legitimate.

There was one critical problem. That engine family certification only covers engines with a displacement of 52cc. The two chainsaw models in the shipment had engine displacements of 62cc and 68cc. The certification did not match the product, and the mismatch was not subtle.

Step Two: The Database Doesn’t Lie

EPA investigators searched their own certification database, known as EV-CIS. The certificate holder for engine family SZJTS.0525ZJ is a company called Zhejiang ZhongJian Technology Co. Ltd., a Chinese manufacturer with no documented certification for 62cc or 68cc engines. That company had never certified an engine of either size.

Proyama, the brand name on the chainsaws, is not a certificate holder with the EPA at all. Proyama has never certified any product with the agency. The EPA found zero evidence that the 180 chainsaws in this shipment were certified, exempt, or otherwise excluded from federal clean air requirements.

What this means in plain English: 180 gas engines entered the country with no proof they met any air pollution standard. No label. No certificate. No exemption. Nothing. The company had two chances to produce legitimate paperwork, and both attempts fell apart under basic scrutiny.

What This Actually Cost — Beyond the Fine

The Air That Working People Breathe

Gas-powered chainsaws are tools used by landscapers, tree trimmers, construction crews, and forestry workers. These are overwhelmingly working-class jobs. The people who run these machines breathe the exhaust directly, at close range, for hours at a time. The entire purpose of the Clean Air Act’s non-road engine certification program is to ensure that engines sold and used in the United States meet minimum standards for emissions that harm human lungs: hydrocarbons, carbon monoxide, and nitrogen oxides.

When Naomi Trading imported 180 uncertified chainsaws, it introduced 180 engines into the U.S. market with no documented proof they met those standards. No Emission Control Information label. No Certificate of Conformity. No baseline accountability. The people using those tools, if they had reached the market, would have had no way of knowing what they were breathing.

The Fraud Is the Insult on Top of the Injury

The emissions violation alone would be damaging enough. But what the EPA documents reveal is a company that made two active attempts to avoid accountability through deception. First, Naomi Trading claimed the chainsaws were not EPA-regulated products at all, a claim that would have allowed the shipment to pass without any emissions scrutiny. When that failed, the company’s broker submitted forms tying the chainsaws to a certification that covers a physically different engine, apparently banking on inspectors not cross-referencing the engine displacement figures against the certificate database.

These are not the actions of a company that made an honest paperwork mistake. These are sequential, deliberate maneuvers to move non-compliant product through a system that was specifically built to stop it. The workers who would have used these chainsaws, the communities downwind of wherever these tools operated, the people who trusted that the import system was working: all of them were the intended victims of that strategy.

The Customs System as the Last Line of Defense

The fact that this shipment was caught is credit to the CBP officer named Ryan who detained the cargo at H&M Warehouse in Kearny, New Jersey on July 11, 2025. Without that inspection, 180 uncertified engines could have entered the market, been sold, and been put to work. The people who would have bought them would have had no idea the products carried no emissions certification. The regulatory framework caught this one. The question the public should ask is how many it does not catch.

A Fine That Fits in a Checking Account

The settlement penalty was $9,144 (roughly two months of full-time minimum wage earnings for a single worker). That is the price Naomi Trading paid for 180 documented violations of the Clean Air Act, after two attempts to fraudulently disclaim regulatory coverage. The EPA’s own documents state that the maximum penalty available under the regular enforcement process was $59,114 per violation (enough, at the maximum, to total $10.6 million for the 180-violation count; more on that math below). The company paid a fraction of one percent of that potential exposure.

Straight From the Enforcement Document

These are direct quotations and factual statements taken verbatim from the EPA’s Clean Air Act Vehicle and Engine Expedited Settlement Agreement. No paraphrasing. No editorializing. Just what the federal government put in writing.

“The importer claimed these gas-powered chainsaws were covered under Disclaim Code A – product not regulated by the EPA. However, these products are regulated by the EPA and the disclaim code does not apply.” — EPA Settlement Agreement, Table 2, Description of Violation

“After initially attempting to disclaim these products using Disclaim Code A, the importer/broker submitted EPA form 3520-21 and claimed that both chainsaw models were covered under engine family name SZJTS.0525ZJ. This is inaccurate because the engine family name SZJTS.0525ZJ only covers engines that are 52cc, not the engine sizes of the chainsaw models in this shipment.” — EPA Settlement Agreement, Table 2, Description of Violation

“No relevant Certificates of Conformity were found in EPA’s databases. The certificate holder for engine family SZJTS.0525ZJ is Zhejiang ZhongJian Technology Co. Ltd. A search of EPA’s EV-CIS confirms that this certificate holder has not certified a non-road spark ignition engine with an engine size of 62cc or 68cc.” — EPA Settlement Agreement, Table 2, Description of Violation

“Proyama is not a certificate holder (i.e., it has not certified a product with the EPA). The EPA has found no evidence indicating the Subject Engines are certified, exempt or otherwise excluded from coverage under Title II the Clean Air Act (CAA) and its implementing regulations.” — EPA Settlement Agreement, Table 2, Description of Violation

“If you do not sign and return the enclosed Agreement as presented within thirty (30) calendar days of its receipt… the EPA is authorized to… seek penalties of up to $59,114 per violation pursuant to Section 205(a) of the CAA.” — EPA Cover Letter, Kathleen Anderson, Director, Enforcement and Compliance Assurance Division

Who Pays When Importers Dodge Emissions Rules

Environmental Degradation

The Clean Air Act’s non-road engine certification program exists because small gasoline engines — chainsaws, leaf blowers, generators — contribute meaningfully to ground-level ozone, smog, and particulate pollution. The EPA estimates that non-road equipment accounts for a significant share of nationwide hydrocarbon and nitrogen oxide emissions. Every engine that enters the U.S. market without certification is an engine whose emissions output has never been validated against any standard.

This shipment contained 180 such engines. Those 180 chainsaws, if deployed commercially, would have operated in backyards, forests, construction sites, and neighborhoods. The people breathing that exhaust would have no legal assurance that the engine burning near their face met even the floor-level standard for clean combustion. The certification system exists precisely because the market will not self-regulate this. Without it, any importer can flood the country with maximally polluting equipment and collect a profit while externalizing the health cost onto the public.

Public Health

Chainsaw operators face direct, sustained exposure to engine exhaust during operation. Hydrocarbons and carbon monoxide emitted by small gasoline engines are associated with respiratory irritation, reduced lung function, and in long-term occupational exposure, elevated risk of cardiovascular and pulmonary disease. The workers most likely to be using commercial-grade chainsaws are landscapers, arborists, and forestry crews, populations that are disproportionately Latino and immigrant, and who already face documented barriers to occupational health protections.

The EPA’s certification requirement is not bureaucratic box-checking. It is the mechanism by which the federal government guarantees that every engine sold commercially in the U.S. has been tested and confirmed to meet minimum air quality standards. When Naomi Trading bypassed that requirement with fraudulent paperwork, it removed that guarantee for every potential end-user of those 180 chainsaws. The workers who would have run those tools had no voice in that decision. They were not consulted. Their lungs were simply factored out.

Economic Inequality

Compliant importers spend real money to certify their products. They pay engineers to test engines against EPA standards. They pay for the paperwork, the lab time, the certification process. That cost gets built into the price of the product. An importer who skips all of that can undercut compliant competitors on price, capturing market share by cheating rather than by building a better or cheaper product legitimately.

That dynamic punishes the honest operators. It rewards the dishonest ones. And the workers who end up using the cheaper, uncertified equipment absorb the health cost that the importer refused to pay. The fine in this case, $9,144 (about what a full-time worker earning the federal minimum wage takes home in two months before taxes), does nothing to restore the competitive harm done to compliant businesses. It does not come close to recapturing the profit Naomi Trading may have realized on a shipment of 180 commercial chainsaws.

What the Numbers Actually Mean

Who Watches This, and What You Can Do

The Named Party

The enforcement document names Jianshe Su as Director and CEO of Naomi Trading Co. Ltd., headquartered at 1031 S Broadway, Los Angeles, CA 90015. The company signed the agreement through a representative identified only as “Cindy,” listed with the title “OP” and the email address document@link-trans.com. The customs broker involved is listed as JL Customs Service LLC, based in Diamond Bar, California.

The Regulatory Watchlist

• EPA Office of Enforcement and Compliance Assurance (OECA): The body that issued this settlement. Track their enforcement actions at epa.gov/enforcement.
• U.S. Customs and Border Protection (CBP): The agency whose officer detained this shipment. CBP’s import safety division is the front-line stop for non-compliant goods.
• EPA’s EV-CIS Database: The public certification database that confirmed Proyama had no certified products. You can search it yourself at cfpub.epa.gov.
• EPA Contact for This Case: Julian Velez at velez.julian@epa.gov and Richard Kan at (212) 637-4017. These are the enforcement officers of record.

The Expedited Settlement Problem

The EPA’s own letter explains that the expedited settlement process offers “significantly lower penalties than those sought through the regular enforcement process.” That is the mechanism that allowed 180 violations to resolve for $9,144 (less than most Americans pay for a semester of community college). The program exists to move cases quickly, but the result is a fine so small it functions as a cost of doing business rather than a deterrent.

What Everyday People Can Do

Regulatory capture and weak enforcement are not natural disasters. They are policy choices. Push your federal representatives to fund EPA enforcement at levels that make deterrence real. Support organizations that monitor import compliance and air quality standards. If you work with gas-powered outdoor equipment, know your rights under OSHA’s air quality standards for occupational exposure.

Mutual aid networks in port cities and industrial zones are already tracking environmental justice issues tied to import chains and warehouse districts. Connect with community air-quality monitoring groups in your region. The people most exposed to the consequences of non-compliant emissions equipment are the same people who are most likely to be excluded from the regulatory feedback loop. Changing that requires showing up locally, not just digitally.