On or about March 23 and 26, 2007, Komatsu imported into Savannah, Georgia 12 excavators and 7 bulldozers that contained diesel nonroad engines. The engines bore Emissions Information Labels that were not permanently affixed and could be removed without destroying or defacing the labels, in violation of 40 CFR 89.110(a)(1). EPA required the manufacturer and certificate holder of the engines (Komatsu) to remove the noncomplying labels and affix complying labels, to conduct a root cause analysis to determine the cause of the violations and undertake corrective action to prevent future violations, and to implement a corrective action compliance plan.