Given that the certification process takes a while even if you don't need to retest, and a failure may see you going back to your engineers to change the stove, 8-9 months before the deadline isn't what I'd call overachiever territory. The new rules go live March 15. Even if the stove passes 2020 emissions in your lab, conditions won't be exactly the same in the third party lab... so as a manufacturer, I'd not want to cut it close on that one. Shipping your dealers a stove that you think will definitely meet the standard, and then it doesn't? Ugh.
@BKVP : From the time that you finish in-house testing and decide it's time to lab test your stove, how long is the process before the stove is officially EPA compliant?
Is 2020 adding to this figure because labs are busy?