Modern agricultural equipment operates under strict federal emissions requirements. Selective catalytic reduction systems, diesel exhaust fluid systems, and the inducement strategies that enforce their proper operation aren ' t optional features— they are compliance mechanisms mandated by the Clean Air Act.

EPA Administrator Lee Zeldin went further, declaring that manufacturers had " wrongly used the Clean Air Act to monopolize the repair markets, hurting our farmers." It was a compelling narrative. It was also incomplete.

The actual guidance— a three-page letter from Assistant Administrator Aaron Szabo dated January 30, 2026— tells a more complicated story. And understanding that complexity matters for anyone tracking what this guidance actually changes, and what it doesn ' t.

The Contradiction Manufacturers Were Navigating

Modern agricultural equipment operates under strict federal emissions requirements. Selective catalytic reduction systems, diesel exhaust fluid systems, and the inducement strategies that enforce their proper operation aren ' t optional features— they are compliance mechanisms mandated by the Clean Air Act. Manufacturers built those systems under direct EPA guidance that, for years, was unambiguous: generic scan tools could not be used to clear final inducements, and manufacturers should not make that capability widely available. A 2010 joint EPA and California Air Resources Board workshop stated plainly that use of generic scan tools to clear inducement was

KIPP McGUIRE is the director of government affairs for NAEDA.

" not acceptable." Subsequent guidance reinforced the point.

At the same time, the Clean Air Act has always included an exception. Section 203( a)( 5) of the CAA states that temporarily disabling an emission control element is not a prohibited act when the action is for the purpose of repair and the system is restored to proper functioning upon completion. The law anticipated that repairs sometimes require taking an engine out of certified configuration.

Manufacturers faced a genuine contradiction, not a manufactured one. Comply with explicit EPA guidance restricting inducement override access, or interpret a statutory exception broadly and risk enforcement action. The Szabo letter acknowledges this directly, noting that some manufacturers had read the CAA ' s anti-tampering prohibition as barring them from facilitating third-party repairs that required temporary disablement of emissions controls. That interpretation, however wrong the current administration now says it was, was not conjured from thin air. It was the logical product of years of regulatory signals pointing in exactly that direction.

What Deere Actually Did

EPA Administrator Zeldin ' s framing implies manufacturers exploited federal law to corner repair markets. The documentary record complicates that picture significantly. On June 3, 2025, John Deere ' s Manager of Product Safety and Compliance submitted a formal letter to EPA requesting approval to provide customers and independent repair technicians the capability to reset engine final inducements— precisely the capability now celebrated as a farmer victory. Deere cited the regulatory history, acknowledged EPA ' s prior guidance restricting that access, and asked EPA to update its position for the nonroad sector, just as it had done for heavy-duty onhighway engines in 2023.

This was not a company fighting to protect a repair monopoly. It was a company that had been following the rules it was given, watching EPA change those rules for one sector, and asking for the same clarity in its own. The January 2026 guidance letter was the response to that request.

What the Guidance Actually Changes

The Szabo letter is careful about its own scope. It explicitly states that its contents " do not have the force and effect of law and are not meant to bind the public in any way." It changes no regulations and weakens no emis-

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KIPP McGUIRE is the director of government affairs for NAEDA. He comes from the consulting world, where he was an advisor to the U. S. Navy’ s Commander of Pacific Fleet as a member of the Commander’ s Action Group and Government Affairs and Outreach teams. Prior to his time as a consultant, he was an Advance Officer for the Office of the Secretary of Defense, which took him across the globe coordinating nation-to-nation engagements. He has extensive experience in the legislative and policy fields, and has previously worked for state and federal legislators, as well as an advisor on several political campaigns. His military service includes five years enlisted with the Marine Corps and is presently an Intelligence Officer with the Navy Reserves. He has degrees from the University of Montana and the Institute of World Politics.

SPRING 2026 • EQUIPMENT DEALER MAGAZINE 5