Cevans , I see your point, and to the Letter its would be consider a violation, BUT one has to ask the Question if it could MEET the Certification, We mod lots of engines in states That Have Testing and they Pass..
The siffter we used with WITECH it passes, But that's NOT meaning it would Pass NVFEL testing
This why I put the note at the end. States have different emissions testing, some states have ZERO emissions testing. If you have this truck in Kentucky or New Hampshire, you can do whatever you want to it and still pass inspection.
The process of "certification" by the EPA is a total crapshoot. We have regulations to limit emissions, but, those are only for a certain baseline set of conditions. It is completely impossible for any vehicle to always be under the limits because driving conditions change - a car full of people pulling up a 6% grade trying to pass a slow truck will be exceeding the emissions regulations.
Because of this, once an the engine shows to meet the regulations at the baseline, the manufacturers and the EPA negotiate the "working parameters" for the engine - when the engine can exceed the limits, for how long, how often, etc. There literally is zero way for any of us to measure if our trucks meet what they are certified for - even stock - and the EPA is only now realizing that their whole regulator regime has very little to do with real-world usage.
So, as for your suggesting that it would "meet" certification - if by certification you mean state inspections, depending on the state that is true. If you mean certification as it pertains to the EPA, even the EPA wouldn't know how to answer that.
In short...who knows, who the hell cares.
What is 100% undeniably true, however, is the the EGR and DPF systems are damaging for engine components. It is your choice to violate the CPA in the name of protecting your truck or getting more power or MPG.