California New Truck Law: Compliance, Exemptions, and Penalties

The California new truck law is actually two linked California Air Resources Board regulations: the Advanced Clean Trucks (ACT) rule, which forces manufacturers to sell a growing share of zero-emission medium- and heavy-duty trucks starting with model year 2024, and the Advanced Clean Fleets (ACF) rule, which requires larger fleet owners and drayage operators to retire diesel trucks on a set schedule. Both cover Class 2b through Class 8 vehicles, both apply to trucks operating in California regardless of where they are registered, and both drive toward the same endpoint: 100 percent zero-emission new truck sales by model year 2036.¹

Is the Law Still in Effect?

Yes, at the state level. California’s authority to set its own vehicle standards runs through a waiver from the U.S. EPA under the Clean Air Act. The EPA granted the waiver for ACT in April 2023, which let the manufacturer sales rule take effect. CARB then withdrew its federal waiver request for the ACF fleet purchase mandate in January 2025.²

In May 2025 the U.S. Senate voted to revoke two EPA waivers tied to California’s heavy-duty truck standards. If both chambers complete the process and the President signs, those waivers would be formally withdrawn, which could limit California’s ability to enforce the manufacturer sales mandate and block other states from adopting the same rules. CARB continues enforcing its regulations at the state level while the federal picture shifts, so if you operate trucks in California you should treat the rules as active and watch federal developments before placing large orders.

Who Has to Comply

The ACF rule hits hardest for what CARB calls “high-priority fleets”: businesses that own or dispatch 50 or more trucks, or that generate $50 million or more in annual gross revenue. Federal government fleets fall into this group regardless of size. State and local government fleets follow their own track with somewhat later deadlines.³

If your fleet falls below both the 50-vehicle and $50-million thresholds, you are not high-priority and the direct fleet purchase mandate does not apply to you. You will still feel the law through the manufacturer side: as the ACT rule forces OEMs to sell more zero-emission trucks each year, new diesel inventory shrinks and eventually ends. Smaller operators also remain subject to the Clean Truck Check inspection program described below.

The weight classes covered run from heavy-duty pickups (Class 2b) through fully loaded 18-wheelers (Class 8), based on the manufacturer’s gross vehicle weight rating. Both ACT and ACF apply to trucks operating in California, not just those registered in the state. For interstate carriers that routinely dispatch loads into California, that distinction matters: your California-operating vehicles can trigger obligations even if your yard is in Nevada or Arizona.

Drayage Trucks: The Tightest Timeline

Drayage trucks serving California seaports and intermodal railyards face the hardest deadlines of any category. Since January 1, 2024, only zero-emission drayage trucks can be newly registered in CARB’s online system. Diesel and natural gas drayage trucks already registered by December 31, 2023, became “legacy” vehicles and can run through their useful life.⁴

Starting in 2025, legacy drayage trucks 12 years or older must report mileage annually and come off the registry once they exceed useful life. By January 1, 2035, every drayage truck entering a California seaport or intermodal railyard must be zero-emission, with no further extensions for combustion power.⁴ Out-of-state drayage trucks are included; if the truck enters a California port or railyard, it must be in CARB’s system and meet the same timeline.

Fleet Compliance: Two Paths

High-priority and federal fleet owners pick one of two routes.

Model Year Schedule

Starting January 1, 2024, every truck you add to your California operations by purchase, lease, or transfer must be zero-emission or a qualifying near-zero-emission plug-in hybrid. Existing combustion trucks stay in service until they hit end of useful life, then retire. From model year 2036 forward, near-zero-emission vehicles no longer count; only full zero-emission vehicles satisfy the requirement.³

ZEV Milestones Option

This path lets you decide which trucks to replace and when, as long as your fleet hits escalating zero-emission percentage targets by set compliance years. You can keep harder-to-replace specialty vehicles longer and prioritize swaps where zero-emission alternatives are cheapest. The trade-off is that the targets ratchet up every year, so once you fall behind the climb back is steep.

How Useful Life Works

Under either path, a combustion truck’s useful life sets its retirement date. Every truck gets a minimum of 13 years from its engine certification model year, even if it has already crossed 800,000 miles. Past 13 years, the truck can keep running until it hits 18 years from certification or 800,000 miles, whichever comes first.⁵ A truck that crosses 800,000 miles at year 15 gets pulled then, not at 18.

Why Diesel Will Disappear Even if You Are Not a High-Priority Fleet

The ACT rule works on the supply side. Manufacturers who sell medium- and heavy-duty vehicles in California must make a growing share of those sales zero-emission, starting with model year 2024 and reaching 100 percent across all covered classes by model year 2036.¹ Larger Class 4–8 trucks carry steeper early targets than Class 2b–3 vehicles, and manufacturers earn credits for zero-emission sales to offset deficits from combustion sales.⁶ For a small operator that means new diesel inventory in California will keep tightening on a predictable schedule.

Clean Truck Check: Separate Obligation, Nearly Everyone

Separate from the ACF purchase rules, California runs a Clean Truck Check inspection program for nearly all diesel and alternative-fuel trucks with a gross vehicle weight rating over 14,000 pounds operating in the state, including out-of-state trucks that regularly cross in.⁷

Three requirements apply: register the vehicle in CARB’s Clean Truck Check database, pay a $30 annual compliance fee per vehicle, and submit a passing emissions test from a credentialed tester within 90 days before the registration deadline. If the truck is not marked compliant in CARB’s system, the California DMV blocks registration renewal. The block lifts automatically when CARB confirms compliance.⁷

Exemptions and Extensions

CARB built escape valves into ACF for situations where a zero-emission truck genuinely is not available or workable. Each one requires documentation and CARB approval.

ZEV Purchase Exemption

If no zero-emission truck exists in the same configuration as the vehicle you need to replace, you can ask to buy a new combustion truck instead. You have to show no manufacturer offers a zero-emission model matching the body type, weight class, and operational specs.⁸

Daily Usage Exemption

When a zero-emission truck exists in the right configuration but cannot handle your daily workload due to range or payload limits, you can apply for this exemption. You submit mileage and usage logs showing no available zero-emission option can meet the documented duty cycle, and your fleet must already be at least 10 percent zero-emission to qualify.⁹

Infrastructure Delay Extension

If you have started installing charging or hydrogen fueling infrastructure but face delays beyond your control, you can request a time extension. The project must have started at least one year before the next compliance deadline. Construction delay extensions can run up to two years; site electrification delay extensions can stretch up to five years with proper documentation.⁹ You submit executed contracts, utility applications, and written documentation from the contractor, utility, or building department explaining the delay.¹⁰

Backup and Emergency Vehicles

A truck driven fewer than 1,000 miles per year can be designated as a backup vehicle and left out of zero-emission requirements entirely. You register the designation in TRUCRS at the start of each compliance year, and miles driven during a declared emergency do not count toward the cap. Used combustion trucks can be bought and immediately designated as backups without affecting fleet compliance.⁹

Vehicles deployed under contract for a declared emergency are temporarily excluded from the California fleet for compliance purposes, and TRUCRS reporting is waived during the response if you have proof of the emergency management contract. Fleets with mutual aid agreements can request an exemption to keep buying combustion emergency-response vehicles, but only after reaching 25 percent zero-emission, and the exemption covers at most 25 percent of the fleet.⁹

Reporting Deadlines

Fleet owners subject to ACF report through the Truck Regulation Upload, Compliance and Reporting System (TRUCRS). High-priority and federal fleets file by February 1 each year; state and local government fleets file by April 1.¹¹ For each vehicle you report the VIN, engine family name from the emission control label, GVWR, and primary fuel type. Backup vehicles, exempted vehicles, and tractors with engines 12 years or older also need odometer or hubodometer readings. If a backup vehicle exceeds its mileage limit, you have 30 calendar days to report the change. CARB cross-references submissions against engine certification records, so verify the emission control label physically rather than trusting internal records, especially on older trucks that may have had engine swaps.

Incentives That Narrow the Price Gap

Zero-emission trucks still cost significantly more than diesel, but stackable incentives can offset a meaningful share.

California’s Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP) delivers point-of-sale vouchers. For a Class 8 battery-electric truck the base voucher is $120,000, rising to $330,000 for small businesses. Drayage and refuse haulers get $150,000 base vouchers. Hydrogen fuel cell Class 8 trucks qualify for $240,000 to $300,000 depending on the application.¹² Funding availability moves, so check the HVIP portal before ordering.

At the federal level, Internal Revenue Code Section 45W gives businesses buying qualifying commercial zero-emission vehicles a credit worth 30 percent of the vehicle’s cost or the incremental cost over a comparable diesel, whichever is less. The cap is $7,500 for vehicles under 14,000 pounds GVWR and $40,000 for heavier vehicles. The vehicle must be subject to depreciation and acquired for business use rather than resale, and the credit runs through the end of 2032.¹³

The EPA Clean Heavy-Duty Vehicles Grant Program funds truck replacements, charging and fueling infrastructure, and workforce training, with priority for projects in areas that do not meet federal air quality standards.¹⁴

What Noncompliance Costs

CARB’s main enforcement tool is the DMV registration system. The California DMV database connects directly to CARB’s compliance records, and a truck not marked compliant cannot be registered or renewed. That turns noncompliance from a paper fine into an operational shutdown: a truck that cannot be registered cannot legally operate on California roads.

Beyond registration blocks, CARB can impose civil penalties under the California Health and Safety Code of up to $10,000 per vehicle per day, with the actual amount depending on severity and duration. Operators who discover a compliance gap generally fare better contacting CARB proactively than being caught in an enforcement action.

1
California Air Resources Board. Zero-Emission On-Road Medium-and Heavy-Duty Strategies
2
US EPA. Vehicle Emissions California Waivers and Authorizations
3
California Air Resources Board. Advanced Clean Fleets
4
California Air Resources Board. Advanced Clean Fleets Drayage Truck Regulation Overview
5
California Air Resources Board. Drayage Truck Minimum Useful Life Factsheet
6
California Air Resources Board. Path to Zero Emission Trucks FAQ
7
California Air Resources Board. Clean Truck Check (HD I/M)
8
California Air Resources Board. Advanced Clean Fleets Regulation – Zero-Emission Vehicle Purchase Exemption
9
California Air Resources Board. Advanced Clean Fleets Regulation Exemptions and Extensions Overview
10
California Air Resources Board. ZEV Infrastructure Delay Extension Checklist
11
California Air Resources Board. High Priority and State and Local Government Fleet Reporting Guidance
12
California Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project. Funding – Clean Truck and Bus Voucher Incentive Project
13
Office of the Law Revision Counsel. 26 USC 45W Credit for Qualified Commercial Clean Vehicles
14
US EPA. Clean Heavy-Duty Vehicles Grant Program Awards