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This report explains the rationale for supporting engine-based standards in the first phase heavy-duty vehicle fuel efficiency regulation in India. As policymakers and stakeholders in India begin the regulatory development process for fuel efficiency standards in this area, one of the key debates is whether separate performance standards for engines are an appropriate first step. The ICCT indicates that regulatory experience and technology cost-effectiveness data from the United States provide evidence that engine technologies are quite cost-effective compared to technology interventions in other vehicle areas.