The product is EPA registered per 40 CFR 79.23 - a requirement for all gasoline additives sold in the US. Registration involves providing a chemical description of the product and certain technical, marketing and health-effects information. The EPA did not test the claims of increased engine power and reduced emissions, and does not endorse, certify or approve the product. The company report attached to the EPA report "provides technical documentation for this product as a lead replacement in gasoline for use in engines susceptible to valve seat recession".
Distribution
The company retails MPG-CAPS directly or through multi-level marketing via "independent distributors". To become a distributor there is an initial buy-in and an emphasis on the necessity of recruiting other people in order to receive commissions. This follows the structure of multi-level marketing, although there are recruiting bonuses after three retail sales a month as an incentive to grow the sales force, the majority of the cash-flow is said to be generated by commissions on sales.
Independent testing
An example of a recognised independent testing program to "evaluate aftermarket retrofit devices which claim to improve automotive fuel economy and/or reduce exhaust emissions" is that run by the US Environmental Protection Agency identified by test program authorities 42 USC 7525 and 49 USC 32918, and formerly known as the "511 Program". The EPA requires a formal statement that the test laboratory "shall have no financial interests in the outcome of these tests other than the fee charged for each test performed". The Federal Test Procedure comprises a simulated city drive trace, and a simulated highway drive test. The tests are conducted in triplicate using two different vehicles. The vehicles should be from two different manufacturers and should be examples of the largest selling engine/transmission combinations on the US market. Tests are conducted in a "back-to-back" fashion. In the case of fuel additives that don't require an engine retune, then triplicate tests with and without the additive are required. The tests on MPG-Caps do not apparently conform to this standard. Examples of such tests are:
A study conducted by ABC News affiliate WPVI found no improvement at lower speeds and only a 4% improvement at highway speeds.
Tests by a former distributor in the program used "70 tablets to test 7 vehicles in Missouri and California according to the FFI instructions. All the test showed an initial improvement but then showed no improvement over a longer period of time and most of them showed less mpg than the vehicles were getting before any usage".
A critical appraisal of some test results was conducted by the website www.fuelsaving.info, which notes that the MPG-Caps were originally designed to allow older engines to run on unleaded gas without valve recession and much of the fuel economy data presented is based on older vehicles. The very slight improvement in octane rating claimed might make an engine poorly tuned to the fuel it is run on perform better, especially in older vehicles without engine management computers.