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This paper examines the issues concerning particulate matter (PM) emissions measurement at the 3 mg/mi level proposed as the future LEV III standard. These issues are general in nature, but are exacerbated at the low levels contemplated for upcoming emissions standards. They are discussed in the context of gasoline direct injection (GDI) engines, where they can have an important impact on the continued development of this technology for improved fuel economy. GDI particulate emissions, just as engine-out diesel PM, contain a high fraction of soot. But the total PM mass is significantly lower than from diesel engines, and there can be significant variations in emissions rate and apparent PM composition between cold-start and running emissions. PM emissions levels depend on sampling method and location. As a result, there can be substantial differences in PM sampled and diluted directly at the exhaust pipe, as opposed to measurements from a dilution tunnel.