One of the biggest questions after the memorandum came out was simple: now what?
The answer came fast. Within two days, the EPA issued guidance explaining how it plans to carry out the President's Freedom to Fix memorandum. The guidance doesn't change the Clean Air Act or create new legal rights, but it does give shop owners, vehicle owners, and aftermarket manufacturers some real clarity.
If you read my breakdown of the original memorandum, this is the next chapter. Here's what actually changed.
The EPA reaffirmed that manufacturers are obligated under the Clean Air Act to make emissions-related service information, training materials, onboard diagnostics (OBD) information, pass-through reprogramming information, and certain manufacturer-specific tools available for purchase by independent repair facilities.
In plain terms: that information isn't supposed to be locked up inside dealership networks. If you've run into a wall trying to get it, this guidance backs up your position.
The guidance also confirms that consumers aren't required to use only OEM-branded emissions components. Equivalent aftermarket replacement parts are fine, as long as they comply with applicable emissions requirements. One catch worth knowing: the EPA notes that using non-certified parts could affect warranty coverage, so it's still worth being upfront with customers about that tradeoff.
This is probably the most practical change in the whole guidance. The EPA recognized SEMA's Certified Emissions (SC-E) Program as an additional certification pathway for aftermarket emissions parts.
Up to now, manufacturers have leaned almost entirely on California's CARB certification process to prove compliance. Adding a second recognized pathway is meant to ease that bottleneck, improve parts availability, and bring costs down, all while still meeting Clean Air Act requirements.
The guidance is a real step for emissions-related repairs, but it doesn't touch the bigger issues independent shops are dealing with. It doesn't require manufacturers to open up proprietary software, security gateway systems, telematics platforms, or other protected technology beyond what the Clean Air Act already requires.
Those questions are still sitting at the center of the Right to Repair conversation, and they're still what the REPAIR Act is built to address.
The EPA moving this fast tells me the administration intends to follow through on what the memorandum promised, not just let it sit.
In the near term, you should expect more clarity around emissions repairs, expanded access to compliant aftermarket parts, and a second certification pathway that could improve supply and cut down on delays.
At the same time, the bigger conversation hasn't gone anywhere. Access to OEM software, programming tools, cybersecurity gateways, and connected vehicle data is still essential for servicing modern vehicles, and none of that is part of this guidance.
The speed here says something. The EPA didn't just take the memo under advisement, it acted on it almost immediately. That's a good sign for how the certification and access pieces might actually play out.
But don't mistake this for the bigger fight being over. The things that actually keep your shop dependent on manufacturer goodwill, diagnostic software, security gateway credentials, telematics access, none of that changed here. That's still the REPAIR Act's fight to have.
Two days. That's how fast the EPA moved on this. If you want a CPA who moves just as fast when something changes in this industry, book a call and let's see if we're the right fit.
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