The Non-Financial Ledger: What $2,681 Doesn’t Cover

Eighty-three engines. Not one of them certified to meet federal air quality standards. Not one of them carrying the emissions label that any buyer, mechanic, or neighbor has a right to expect. When Lucky Trading Co., Ltd shipped those bicycle engine kits into the United States, they weren’t just cutting a bureaucratic corner. They were making a quiet decision that the air other people breathe is a cost worth offloading onto everyone else.

Bicycle engine kits aren’t an industrial product. They’re sold to hobbyists, to working-class commuters looking for cheap transportation, to teenagers and adults who want something that moves without a car payment. The people who buy these kits aren’t experts in emissions compliance. They trust that what’s on the shelf has been checked. They trust that someone, somewhere, made sure the exhaust coming off that little engine isn’t pumping out hydrocarbons and particulate matter at levels nobody agreed to absorb.

That trust is exactly what Lucky Trading betrayed. The company didn’t import one test unit. It imported 83 of them. And when inspectors asked for the paperwork, what came back was documentation for a completely different engine, one that was 37% smaller in displacement than what was actually in those boxes. Whether that mismatch was deliberate fraud or catastrophic carelessness, the result is the same: 83 small combustion engines entered the country with no verified emissions controls, no traceable certification, and no way for a buyer to know what they were getting into.

The settlement price came to $2,681 total. That’s about $32 per engine. That is the dollar amount the federal government decided was sufficient to account for 83 violations of the law designed to protect the air Americans breathe. The people living near warehouses, near the port in Kearny, New Jersey, near wherever those engines might have ended up if CBP hadn’t caught the shipment, they don’t get a check. They don’t get a notice in the mail. They just get the air.

Legal Receipts: What the Documents Actually Say

Every quote below comes verbatim from EPA Docket No. CAA-02-2026-1202. Nothing is paraphrased. This is the paper trail.

“Respondent provided a COC that does not apply to the Subject Engines; the COC for the claimed engine family presented is for materially different engines. The COC the Importer presented is for an engine with a displacement of 63.3cc, while the packaging label for the Subject Engines refer to an engine with a displacement of 100cc.” Table 2, Description of Violation — Docket No. CAA-02-2026-1202

• This establishes that the certification paperwork Lucky Trading submitted was for an engine physically smaller than what was in the boxes. A 63.3cc engine and a 100cc engine are not the same product; they have different fuel consumption, different combustion characteristics, and different emissions profiles.
• Presenting a certification for a materially different product is not a paperwork oversight. It means the company either didn’t know what it was importing, didn’t check, or submitted documentation it knew didn’t match.

“CBP did not observe any Emissions Control Information label affixed to the Subject Engines. The importer also did not provide a completed EPA Form 3520-21 when requested by CBP.” Table 2, Description of Violation — Docket No. CAA-02-2026-1202

• The Emissions Control Information label is a physical requirement, not a digital filing. Its absence on all 83 engines means every unit was imported without the basic consumer-facing proof that it meets U.S. air quality standards.
• EPA Form 3520-21 is the standard import declaration for engines subject to Clean Air Act oversight. Failing to produce it when directly requested by Customs officers is a second, independent compliance failure piled on top of the bad COC.

“EPA searched the EV-CIS database and did not find any applicable certifications held by the importer or manufacturer for the Subject Engines.” Table 2, Description of Violation — Docket No. CAA-02-2026-1202

• The EPA’s Engine and Vehicle Compliance Information System (EV-CIS) is the federal registry where all valid engine certifications are recorded. A search of that system turned up nothing for these engines, confirming the problem wasn’t a misfiled document. These engines had no valid certification anywhere in the federal system.
• Combined with the false COC submission, this means Lucky Trading had no legal pathway to import these engines under any framework.

“By importing the Subject Engines, Respondent has committed eighty-three (83) violations of CAA Sections 203(a)(1) and 213(d), 42 U.S.C. §§ 7522(a)(1) and 7547(d), and the regulations codified at 40 C.F.R. § 1068.101(a)(1) and (b)(5).” Table 2, Description of Violation — Docket No. CAA-02-2026-1202

• The EPA counted each individual engine as a separate violation. 83 engines equals 83 violations, not one consolidated infraction. This is legally significant because the maximum penalty is assessed per violation.
• The statutory maximum of $59,114 per violation, applied to all 83 counts, would produce a total exposure of $4,906,462. The expedited settlement resolved all 83 violations for $2,681, a reduction of over 99.9%.

• This clause in the cover letter means settling this case does not give Lucky Trading a clean record going forward. The EPA retains full authority to pursue any additional violations the company may have already committed or commits in the future.

Societal Impact Mapping

Public Health

Uncertified small engines are not a niche regulatory concern. They are a documented source of disproportionate air pollution in dense urban and lower-income communities.

• Small non-road engines, including bicycle engine kits, can emit hydrocarbons, carbon monoxide, and fine particulate matter (PM2.5) at rates far exceeding what certified engines produce. Certification exists precisely to cap these emissions at levels considered safe for ambient air quality under the Clean Air Act.
• The shipment was intercepted at a warehouse in Kearny, New Jersey, a community that sits within one of the most heavily industrialized air corridors in the northeastern United States. Additional uncertified engine emissions in this area compound existing cumulative pollution burdens already carried by residents.
• Had these 83 engines reached buyers and been operated, there would be no manufacturer accountability, no emissions warranty, and no way for a consumer to verify what the engine was actually emitting. The buyer assumes the full risk of operating an unvetted combustion device.
• Small engine emissions are a known contributor to ground-level ozone formation. People with asthma, heart disease, and respiratory illness bear the greatest health burden from incremental ozone and particulate increases, and those populations are concentrated in the same urban and peri-urban communities where inexpensive motorized bicycle kits are most commonly used.

Economic Inequality

The enforcement gap between the statutory maximum penalty and the settlement amount paid reflects a structural feature of how the EPA’s expedited settlement process works, and who bears the costs of that gap.

• The maximum penalty for 83 violations at $59,114 each totals approximately $4,906,462. Lucky Trading paid $2,681, representing a penalty reduction of over 99.9%. The expedited settlement program is explicitly designed to allow lower penalties in exchange for fast resolution. The tradeoff benefits the corporation’s balance sheet; it provides nothing to communities exposed to the non-compliant engines.
• Bicycle engine kits are predominantly marketed to working-class buyers seeking affordable transportation. The communities most likely to purchase and operate these products are the same communities most exposed to the health consequences of uncertified engine emissions. They pay twice: once in price, and once in air quality.
• The customs brokerage firm facilitating this import, Leesa Customs Brokerage Inc in El Monte, California, is copied on the enforcement correspondence. Two named individuals at that firm, Lawrence Zhu and Jimmy Tou, received notice of the violations. Their role in the compliance failure is not explained in the source document; however, their inclusion in the EPA’s correspondence confirms they were part of the import chain.
• The $2,681 penalty, spread across 83 engines, amounts to roughly $32.30 per unit. For a small importer, this fine may cost less than the profit margin on a single shipment. Penalties calibrated below the economic benefit of the violation do not deter the violation.

The “Cost of a Life” Metric

What Now? Accountability, Watchlists, and Action

This case is settled on paper, but the systemic conditions that made it possible remain fully in place. Here is who to hold accountable and where to apply pressure.

Named Parties in This Case

• Lucky Trading Co., Ltd, 10220 Brighton Rd, Henderson, CO 80640-8643. The respondent importer. Signed by Wendy (COO), email l-u-cky@outlook.com.
• Leesa Customs Brokerage Inc, 9040 Telstar Avenue, Suite 112-115, El Monte, CA 91731. The customs brokerage firm copied on the enforcement letter. Named contacts: Lawrence Zhu and Jimmy Tou.
• Kathleen Anderson, Director, Enforcement and Compliance Assurance Division, USEPA Region II. The EPA official who approved, signed, and ratified this settlement agreement.
• EPA enforcement contacts for this case: Richard Kan, (212) 637-4017, Kan.Richard@epa.gov; and Julian Velez, (212) 637-3464.

Regulatory Watchlist

• U.S. Environmental Protection Agency (EPA) — Region II: The agency that handled this case. Monitor its enforcement docket for follow-up actions against Lucky Trading or Leesa Customs Brokerage. Public enforcement records are searchable at EPA’s ECHO database (echo.epa.gov).
• U.S. Customs and Border Protection (CBP): CBP officers detained this shipment at the port of entry. CBP’s enforcement of emissions compliance at the border is a first line of defense against uncertified engine imports. Track CBP import enforcement advisories for small engine categories.
• EPA Office of Enforcement and Compliance Assurance (OECA): The national office overseeing the expedited settlement program used in this case. Citizens can submit tips about suspected Clean Air Act violations at epa.gov/enforcement/report-environmental-violations.

What You Can Do

• File a public records request for the full inspection report and any prior compliance history for Lucky Trading Co., Ltd through EPA’s Freedom of Information Act (FOIA) portal at foia.epa.gov. The settlement agreement is already public; additional inspection records may not be.
• Report suspected uncertified engine imports directly to the EPA via the tip line at 1-888-372-7341 or the online form at epa.gov/enforcement/report-environmental-violations. You do not need to be an expert. If a product lacks an Emissions Control Information label, that is grounds for a report.
• Support community air monitoring efforts in overburdened neighborhoods like Kearny, NJ, where cumulative industrial pollution is already above national averages. Organizations like the Clean Air Task Force (catf.us) and local environmental justice groups provide resources for residents tracking pollution in their ZIP codes.
• Demand stronger expedited settlement minimums from your elected representatives. When a $4.9 million maximum penalty settles for $2,681, the deterrent effect is functionally zero. Contact the Senate Environment and Public Works Committee and the House Energy and Commerce Committee to push for minimum settlement floors tied to economic benefit of the violation.
• Check before you buy. If you purchase a small engine kit, request documentation of the engine family’s EPA Certificate of Conformity and verify it against the actual engine displacement listed on the product. A mismatch between the COC displacement and the product label is a red flag that mirrors exactly what happened in this case.