Trucking Regulations - CARB
California Air Resource Board
Below is a listing of safety-CARB regulations that are approved or pending, as well as their potential impact on the market.
| Regulation | Status |
|---|---|
| Omnibus Low NOx Rule | In August 2020, CARB adopted HD Omnibus, which lowers NOx and PM emissions standards for MY 2024 and subsequent MY CA heavy-duty engines. It received final approval by the CA Office of Administrative Law in December 2021. However, after requesting that EPA hold off granting CARB’s request for a waiver of preemption (in spring 2023), CARB decided, as part of an agreement with the EMA in July 2023, that it would align with the EPA’s NOx standards for MY 2027. In July 2024, CARB requested that the EPA recommence waiver consideration for HD Omnibus. THe determination is still pending. CARB and the EMA announced the Clean Truck Partnership agreement in July 2023, which includes CARB’s agreement to amend HD Omnibus MY 2024-26 compliance pathways and to align with the EPA’s 2027 HD Low NOx emissions standards. CARB has formally proposed amendments for MY 2024-26. The previous alternative compliance option for MY 2024-25 included a legacy HD diesel engine sales cap of 45% and 25%, respectively. CARB has finalized two alternative compliance options (approved by CA Office of Administrative Law 5/31/24). Amendments to incorporate the 2027 changes are also pending. CARB also has yet to receive a waiver of preemption from the EPA for HD Omnibus, which could impact its ability to enforce the regulation. Alongside CA, CO, MA, NJ, NM, NY, OR, RI, VT, and WA have adopted the HD Omnibus rule (see map). CO, NJ, NM, and RI adopted HD Omnibus last year, meaning it will be effective for MY 2027. PA has an existing regulation that would require it to adopt CA vehicle emissions standards, as PA requires HD engines sold in state to have a CA certification. However, PA put a hold on this requirement through 2023, and on June 10, 2023, the PA Dept. of Environmental Protection extended this suspension until January 2, 2026. This means that, if there are no changes before then, the state will be required to follow CA's standards beginning with MY 2027 engines and vehicles. The five states that are set to start HD Omnibus compliance in MY 2027 will now effectively be complying with the national standard set by the EPA with which CARB has agreed to align. Oregon and Massachusetts are planning to delay compliance start by one year (from MY25 to MY26), citing lack of available engines. |
| Regulation | Status |
|---|---|
| Advanced Clean Truck Regulation | The CARB Advanced Clean Trucks rule was approved and filed with the CA Secretary of State in March '21. The regulation aims to speed the transition to on-road ZEVs in the CV space using a credit-deficit market. Starting MY '24 and continuing through MY '35, manufacturers are required to sell ZEVs as an increasing percentage of their annual sales in CA and states that have also adopted the regulation. CA begins compliance in '24. In '25, MA, NJ, NY, OR, and WA phase in. VT comes in in '26. In '27, CO, MD, NM, and RI phase in. However, there is some indication that some of the early ACT adopters are starting to rethink timelines. Both NY and NJ state legislatures have introduced bills to delay implmentation.The table outlines the gradual increase in ZEV sales requirements. In October 2024, CARB adopted amendents to ACT that inlcude some clarifying language, and among other things, compliance flexibility for manufacturers that are in a credit deficit at the end of any given year. |
| Regulation | Status |
|---|---|
| California Phase 2 Unilateral GHG Trailer Certification | Trailers sold in CA must meet CA requirements. OEMs will need to certify and receive Exec. Order to sell in CA. The program was initially set to being in Jan '20, but enforcement was delayed two years until 2022. |
| Innovative Clean Transit 2018 | The Innovative Clean Transit (ICT) rule was approved and finalized in California in August 2019. The ICT, similar to Advanced Clean Fleets, is a purchase requirement. It mandates a certain percentage of transit agencies’ new bus purchases be zero-emission buses (ZEB). All new purchases must be 100% ZEB by 2030. “Purchases” in this instance also means leases or any new bus under operation by the transit authority. The ICT rule also requires all transit agencies to submit a plan to convert to a 100% ZEB fleet by 2040. Within the scope is any transit agency that leases, rents, owns, operates, or contracts to operate buses. The ICT does not apply to trolleybuses, school buses, or any rail operated vehicles, nor does it apply to Caltrans, Caltrain, Amtrak, or local school districts. Large transit agencies are those that operate in either the San Joaquin Valley or South Coast Air Basins and operate more than 65 buses in annual maximum service, or do not operate in those air basins but have at least 100 buses in annual maximum service in an urban area with a minimum population of 200,000. ZEB purchase requirements began in 2023 for large transit agencies. Small transit agencies are transit agencies that are not considered large transit agencies. Small transit agencies’ purchase requirement does not begin until 2026, but this means the ramp to 100% is steeper than the more gradual requirements for large agencies, as both hit 100% in 2029. |
| Heavy-Duty Inspection and Maintenance Program | The Clean Truck Check program is a comprehensive HD vehicles and inspection maintenance regulation designed to ensure emissions control systems are complaint and properly functioning on CA roadways. The program included periodic vehicle testing requirements as well as other emissions monitoring techniques and enforcement strategies to ID vehicles that need emissions related repairs. Periodic testing requirements began July '24. |
| New TRU Regulations | In California, in addition to regulating ZEVs, CARB has adopted rules for TRUs through the TRU Airborne Toxic Control Measure (ATCM). Originally adopted in 2004, the goal of the TRU ATCM rule has been to reduce emissions from diesel-powered TRUs. In February 2022, CARB approved amendments to further reduce emissions by improving diesel-powered truck TRUs and requiring zero-emission truck TRUs. CARB compliance to adopt zero-emission truck TRUs began December 31, 2023, and the required adoption rate increases annually. By 2029, California will require all truck TRUs to be zero-emission. A zero-emission truck TRU can draw power from the truck or a stored energy source charged by the truck, only if the truck produces no exhaust emissions while operating. This means that a zero-emission truck TRU cannot draw power from a truck’s internal combustion engine but could draw power from a battery charged by an alternative energy source. See compliance schedule for Truck TRUs below: |
| Regulation | Status |
|---|---|
| Advanced Clean Fleets | CARB adopted the Advanced Clean Fleets rule, as a counterpart to the Advanced Clean Trucks rule, to further the decarbonization of medium- and heavy-duty vehicles. Advanced Clean Fleets will focus on operation as opposed to sales. The regulation has been adopted, approved, and was filed with the California Secretary of State in October 2023. While compliance for some segments was supposed to start this year, CARB announced it will delay enforcement of the rule until the EPA makes a decision regarding CARB’s November 2023 request for a waiver of preemption. The announcement to delay enforcement occurred amid a legal challenge by the California Trucking Association (CTA). CARB will begin enforcing Advanced Clean Fleets if the EPA either a) grants the waiver or b) decides a waiver is not necessary for this regulation. The EPA held a public hearing on ACF waiver consideration on 8/14/24 and is accepting comments until 9/16/2024. The rule has four primary components: STATE AND LOCAL PUBLIC FLEETS: California state and local government agencies of all kinds (cities, counties, utilities, special districts) that own, lease, or operate vehicles with a GWV over 8,500 pounds will have to comply. Some exceptions exist for school buses, emergency vehicles, military tactical vehicles, snowplows, and vehicles subject to the Innovative Clean Transit Rule. Purchase requirements for California state and local government fleets are as follows: 50% ZEV required for new purchases from 2024-202 and 100% ZEV required for purchases beginning 2027. DRAYAGE: Starting this year, any vehicles newly entering drayage service and the registry for the first time would need to be ZEVs. Beginning 2025, legacy drayage trucks that are registered in the CARB Online System must not exceed a minimum UL threshold (the latter of 13 years from the MY that the vehicle was first certified for use by CARB or the EPA, OR the date the vehicle exceeded 800,000 vehicle miles traveled or 18 years from the MY that it was certified for use by CARB or the EPA (whichever is earlier)). Starting in 2035, all drayage trucks in the CARB Online System must be ZEV and only zero-emission drayage trucks will be allowed to provide drayage service in California. SALES REQUIREMENT: Advanced Clean Fleets also includes a rule that requires all Classes 2b-8 vehicles sold in California be ZEV starting MY 2036. Also starting in 2036, manufacturers must report VIN, fuel, and drivetrain type, and if not ZEV, documentation that the vehicle is an authorized emergency vehicle for each on-road vehicle produced and delivered for sale in California. HIGH-PRIORITY AND FEDERAL FLEETS: “High-priority” fleets means entities that either: own or dispatch 50 or more vehicles under common ownership/control, earn more than $50 million in gross annual revenue, or are any federal agency that has one or more vehicles operating in California. There are two compliance pathways for these fleets: 1) Starting this year all vehicles added to the California fleet must be ZEV, and starting 2025, ICE vehicles must be removed from the fleet at the end of useful life. Alternatively, 2) fleet owners may opt into the “ZEV Milestones Option” where the transition to ZEV would occur on a sliding schedule of the percentage of the total fleet depending on body type and ZEV suitability (see table). There are a number of extensions fleet owners may request, including for ZEV infrastructure and vehicle delivery delays. |
