California’s truck emissions landscape is in flux—here’s how the regulatory tug-of-war between CARB, EPA, and federal courts will impact your fleet planning and registration strategy.
If you operate heavy-duty trucks in or through California—or if you’re a dealer serving interstate fleets—the last year has turned California’s emissions landscape upside down. Between the May 2025 legal settlement that forced California to repeal major portions of the Advanced Clean Fleets (ACF) rule, the August 2025 EPA proposal to block California’s “Clean Truck Check” requirements for out-of-state vehicles, and ongoing federal lawsuits targeting state emissions authority, the compliance picture for 2026–2027 is anything but clear.
For fleet managers trying to plan vehicle purchases, routing decisions, and registration strategies—and for dealers trying to understand which trucks can be sold where and to whom—the question isn’t just “what are the rules?” It’s “which rules are actually being enforced, which are being challenged, and how do I stay compliant while everything’s in motion?”
This article breaks down the current regulatory battleground and explains exactly how these changes affect interstate trucking operations, fleet registration decisions, and dealer compliance in California.
The Regulatory Tug-of-War: What’s Actually Happening Right Now
California’s push toward zero-emission trucks has hit major roadblocks in 2025, creating a patchwork of enforced rules, suspended requirements, and pending repeals that’s nearly impossible to navigate without a roadmap.
Advanced Clean Fleets (ACF): Partial Repeal in Progress
California’s Advanced Clean Fleets regulation was designed to transition medium- and heavy-duty truck fleets to zero-emission vehicles (ZEVs) by mandating specific purchase requirements for different fleet types. However, following a legal settlement in May 2025 with a coalition of 17 states led by Nebraska, California agreed to repeal the most controversial portions of the rule.
What’s Being Repealed (Effective Late 2025/Early 2026):
- High Priority Fleet Requirements – These applied to private fleets with either $50 million+ in annual revenue OR 50+ vehicles operating in California, regardless of where the fleet was headquartered
- Drayage Fleet Requirements – These required all new drayage truck registrations (port and railyard operations) to be ZEV beginning January 1, 2024
- 2036 Zero-Emission Sales Mandate – California agreed not to enforce the requirement that 100% of new medium- and heavy-duty truck sales be ZEV by 2036 unless it receives an EPA waiver (which appears highly unlikely)
According to the settlement, the California Air Resources Board (CARB) must present a formal repeal proposal to its board by October 31, 2025, with final action by August 31, 2026. Until the repeal is official, California has agreed not to enforce any of these provisions.
What’s STILL in Effect:
- State and Local Government Fleet Requirements – These were NOT part of the repeal and remain fully enforced:
- 50% of new vehicle purchases by state/local government fleets must be ZEV or near-ZEV from 2024–2026
- 100% of new purchases must be ZEV or near-ZEV by 2027
- Small government fleets (10 or fewer vehicles) and designated low-population counties have delayed compliance starting in 2027
This creates a critical distinction: if you’re a commercial fleet or dealer serving the private sector, the ACF purchase mandates are essentially dead. If you’re a government fleet or a dealer supplying municipal/state agencies, those ZEV requirements are alive and well.
The Clean Truck Check Program: EPA vs. California on Out-of-State Trucks
While the ACF fleet purchase mandates are being repealed, California’s Heavy-Duty Inspection and Maintenance (HD I/M) program—commonly called “Clean Truck Check”—remains operational. But it’s now facing its own federal challenge.
What the Clean Truck Check Requires:
Since 2023, all heavy-duty vehicles over 14,000 pounds operating in California must undergo periodic emissions inspections to verify that emissions control systems are functioning properly. This applies to:
- Vehicles registered in California
- Vehicles registered out-of-state that operate in California
- Foreign-registered vehicles that enter California
Fleet owners pay an annual compliance fee ($30 per vehicle) plus inspection costs, with total annual costs ranging from $225–$701 for single-vehicle owner-operators to $772–$2,180 for typical seven-vehicle fleets. These fees come on top of California’s already rising registration costs.
EPA’s Constitutional Challenge (August 2025):
On August 25, 2025, the EPA proposed to disapprove California’s Clean Truck Check requirements as they apply to out-of-state and foreign-registered vehicles. The EPA’s argument centers on two constitutional and statutory concerns:
- Commerce Clause Violation – The EPA contends that requiring out-of-state trucks to comply with California’s inspection program imposes an unconstitutional burden on interstate commerce. Since trucks registered in Nevada, Arizona, Oregon, and other states must comply with California’s rules when operating there, the EPA argues this effectively allows one state to regulate commerce nationwide.
- Foreign Affairs Preemption – By requiring foreign-registered vehicles (such as those from Mexico) to comply, California may be overstepping into foreign affairs, which is solely a federal power.
Current Status:
The EPA proposal was published in the Federal Register on August 26, 2025, and is open for public comment for 30 days. If finalized, the EPA disapproval would mean California could NOT enforce Clean Truck Check requirements on out-of-state or foreign-registered vehicles—though California-registered trucks would still be subject to the program.
Major industry groups including the Owner-Operator Independent Drivers Association (OOIDA) have formally supported the EPA’s proposal, arguing that while Congress gave California flexibility to experiment with emissions rules, it never authorized the state to impose unreasonable burdens on interstate commerce.
The Bottom Line for 2026–2027
Here’s where things stand right now:
- ACF fleet purchase mandates: Not being enforced for private/commercial fleets; formal repeal expected by late 2026
- Government fleet ZEV requirements: Fully enforced and increasing to 100% ZEV purchases by 2027
- Clean Truck Check for CA-registered trucks: Fully operational and enforced
- Clean Truck Check for out-of-state trucks: Operational NOW, but EPA has proposed blocking enforcement—final decision expected in late 2025 or early 2026
- 2036 zero-emission sales ban: Not enforceable without EPA waiver
The result? Maximum uncertainty for interstate fleet planning and vehicle registration strategy.
What This Means for Fleet Managers: Planning in the Fog
If you operate trucks that cross California’s borders or if you’re considering whether to register vehicles in California versus other states, the current regulatory environment creates several strategic challenges.
Challenge 1: Where Should You Register Your Vehicles?
Under the now-defunct ACF high priority fleet rules, it didn’t matter where your trucks were registered—if your fleet operated in California, you were subject to the ZEV purchase requirements. With that provision being repealed, the question of registration jurisdiction becomes critical again.
For Out-of-State Fleets Operating in California:
If the EPA’s proposal to block the Clean Truck Check for out-of-state vehicles is finalized, registering trucks outside California could exempt you from the $225–$2,180 annual inspection and compliance costs. Individual owner-operators and small fleets can learn more about their California DMV options for car owners. However, you’d still need to:
- Comply with federal emissions standards for the truck’s model year
- Meet any emissions requirements in your home state
- Ensure trucks can legally operate in California under federal rules
For California-Based Fleets:
Even if the EPA blocks enforcement of Clean Truck Check on out-of-state vehicles, California-registered trucks will remain subject to the program. This creates a potential cost advantage for registering trucks in neighboring states—but only if your operational patterns support it.
Key considerations:
- Do you have a physical presence in another state that would allow legal registration there?
- Would the cost savings from avoiding Clean Truck Check ($772–$2,180/year for a typical fleet) justify the administrative burden of out-of-state registration?
- Have you properly updated your California DMV address if you’ve relocated operations?
- How will California respond if the EPA blocks enforcement? Will they create new compliance requirements for California-registered vehicles to close the “loophole”?
These are questions that Quick Auto Tags’ fleet registration experts can help you work through, evaluating your specific operational footprint and compliance obligations.
Challenge 2: How to Plan Vehicle Purchases When Rules Keep Changing
The collapse of ACF’s high priority fleet requirements removes the immediate pressure to invest in zero-emission trucks for commercial fleets. But it doesn’t eliminate the long-term trajectory toward cleaner vehicles or the operational realities of running trucks in California.
Strategic Questions for 2026–2027 Fleet Planning:
- Is ZEV technology ready for your use case? Even without mandates, some applications (last-mile delivery, short-haul drayage) may benefit from ZEV economics and operational advantages
- What happens if federal policy shifts again? A future administration could reinstate waivers or implement new federal emissions standards
- Will California find another path to ZEV requirements? The state has agreed not to enforce ACF, but nothing prevents them from crafting new regulations that don’t require an EPA waiver
- Are incentives still available? California has distributed over $780 million in ZEV truck incentives—those programs may remain available even as mandates are repealed
For fleet managers, the takeaway is this: don’t buy ZEVs just because California said you had to (those mandates are gone), but don’t avoid them just because the mandates disappeared. Evaluate economics, operational fit, and long-term risk independently.
Challenge 3: Managing Compliance Documentation Across Jurisdictions
With different rules potentially applying to California-registered versus out-of-state-registered trucks, documentation becomes critical. Fleet managers need to be able to demonstrate:
- Where each vehicle is registered and why
- Compliance with Clean Truck Check requirements (if California-registered)
- Exemption from Clean Truck Check (if out-of-state-registered and EPA proposal is finalized)
- Emissions certification status for each vehicle
- Operational history showing where trucks actually operate
This is where having a professional DMV registration partner like Quick Auto Tags becomes strategically important. Managing registration across multiple jurisdictions, tracking compliance requirements, and maintaining the documentation to prove exemptions or compliance can easily overwhelm in-house administrative staff—especially when rules are changing mid-stream.
What This Means for Dealers: Navigating Uncertainty in the Sales Process
California truck dealers and those serving California-based fleets face their own set of challenges as emissions rules shift.
The Advanced Clean Trucks (ACT) Rule: Still Alive, Still Controversial
While the Advanced Clean Fleets purchase mandates are being repealed, California’s Advanced Clean Trucks (ACT) rule—which requires manufacturers to sell a certain percentage of ZEVs—remains in effect. This creates a disconnect:
- Manufacturers are still required to sell an increasing percentage of ZEVs in California (and in states like Washington, Oregon, New York, and New Jersey that adopted California’s standards)
- Private fleets are no longer required to buy those ZEVs
The result? Dealers may find themselves with ZEV inventory that private fleets don’t want or need, while government fleets—who ARE required to buy ZEVs starting in 2027—may struggle with limited availability or high prices.
Some states that previously adopted ACT have begun delaying enforcement:
- Oregon: Issued enforcement discretion for model years 2025–2026
- Massachusetts and Maryland: Delayed enforcement in spring 2025
- Pennsylvania: Extended suspension of Heavy-Duty Diesel Emissions Control Program until January 2028
This creates additional complexity for multi-state dealers who need to understand which standards apply in which markets.
Resale Values and Title Transfer Complications
The uncertainty around California’s emissions rules is already affecting truck resale values and creating title transfer headaches:
For Newer Trucks:
Trucks that were purchased to comply with now-repealed ACF requirements may not command the premium they once did in the California market. Conversely, conventional diesel trucks that were expected to lose value may retain more worth if ZEV mandates don’t materialize.
For Used Out-of-State Purchases:
Dealers and fleets buying used trucks from out-of-state sellers need to carefully verify:
- Whether the truck meets California emissions standards (even if ACF is repealed, base emissions requirements still apply)
- Whether there are outstanding Clean Truck Check violations or fees
- Whether the truck’s emissions control systems are intact and functional
- What the registration history looks like—has it been registered in California before? In an ACT-adopting state?
The Dealer’s Due Diligence Checklist for California Truck Sales
When selling a truck to a California-based buyer or a fleet that operates in California, dealers should be documenting:
- Emissions certification status – What standards does this truck meet? Is it CARB-certified?
- Registration eligibility – Can this truck be registered in California under current rules?
- Clean Truck Check history – If it was previously California-registered, are there compliance issues?
- Government vs. commercial fleet – Is the buyer subject to ZEV requirements (government) or not (private sector)?
- Interstate operation plans – Will the truck operate only in California, or across state lines?
These questions affect not just the sale itself but also the registration and title transfer process that follows. Partnering with an experienced DMV registration service can prevent post-sale complications that damage customer relationships and create costly delays.
Registration Strategy: How to Avoid Headaches When Trucks Cross California’s Borders
The intersection of changing emissions rules and vehicle registration creates several tripwires that can turn a straightforward transaction into an administrative nightmare. Many fleet managers and dealers are discovering that using a professional DMV alternative saves both time and costly mistakes. Here’s how to navigate the most common problems.
Scenario 1: Registering an Out-of-State Truck into a California Fleet
You’re a California fleet manager who just purchased trucks from an Arizona or Nevada dealer. Those trucks need to be registered in California for your operations. Here’s what you need to verify:
Step 1: Emissions Compliance
Even with ACF fleet mandates gone, base California emissions standards still apply. You’ll need to confirm:
- The truck meets CARB emissions standards for its model year (or has the appropriate exemptions)
- Emissions control equipment is intact and functional
- If the truck is diesel, it complies with California’s anti-tampering and opacity requirements
Step 2: VIN Verification and Prior Registration History
California DMV requires VIN verification for out-of-state registrations. You’ll also want to research:
- Whether the truck has prior California registration (which could mean pending fees or violations)
- Whether it has Clean Truck Check violations in CARB’s database
- Whether there are outstanding liens or title issues from the prior state
Step 3: Fee Assessment and Payment
Registering an out-of-state vehicle in California involves multiple fees:
- Standard registration fees ($74 base + VLF + TIF based on vehicle value)
- CHP fee ($32)
- County/district fees (varies by location)
- Smog inspection fees (if applicable)
- Use tax (unless you can prove you already paid sales tax in another state)
For heavy-duty trucks, these fees can easily exceed $500–$1,000 depending on the vehicle’s value and weight class. Navigating California’s complex fee structure is one reason many fleets and dealers work with a California DMV services partner.
Step 4: Clean Truck Check Enrollment (If California-Registered)
Once you register the truck in California, it becomes subject to the Clean Truck Check program. You’ll need to:
- Create an account in CARB’s Truck Regulation Upload Compliance and Reporting System (TRUCRS)
- Report the vehicle within required timeframes
- Pay the annual compliance fee
- Schedule and pass required inspections
Where Quick Auto Tags Adds Value:
Handling these steps yourself means navigating DMV appointment delays, CARB database systems, and complex fee calculations. Quick Auto Tags’ out-of-state registration services handle the entire process:
- Verifying emissions compliance before purchase
- Managing VIN verification and documentation
- Calculating and paying all required fees correctly
- Enrolling the vehicle in Clean Truck Check
- Delivering completed registration and plates without DMV visits
Scenario 2: Moving a California-Registered Truck to Out-of-State Fleet
If the EPA finalizes its proposal to block Clean Truck Check enforcement on out-of-state vehicles, some fleets may consider re-registering California trucks in other states to avoid the $225–$2,180 annual compliance costs.
Key Considerations:
- Establish legitimate nexus: You can’t just pick a state because it’s convenient—you need a legitimate business presence or operational base there
- Understand new state requirements: Your new registration state will have its own emissions, safety, and registration requirements
- Cancel California registration properly: Avoid penalties and violations by formally canceling California registration and surrendering plates
- Handle pro-rated refunds: California may owe you a partial registration refund; failure to claim it leaves money on the table
- Update insurance and liability coverage: Registration changes affect insurance requirements and jurisdictional liability
Compliance Risk:
California can (and does) verify whether trucks operating in the state are properly registered. If you re-register in Nevada but the truck spends 90% of its time in California, you could face:
- Registration violations and suspended registration
- Operating without valid registration citations
- Insurance complications if there’s an accident
- Tax liability if California determines you’ve established nexus there despite out-of-state registration
Scenario 3: Dealer Title Transfers with Mixed Registration Jurisdictions
Dealers selling trucks that will operate in multiple states face documentation challenges when processing title transfers:
For California Buyers:
- Verify the truck qualifies for California registration (emissions certification, equipment compliance)
- Provide documentation showing prior registration history and any outstanding obligations
- Coordinate with the buyer’s fleet registration strategy (centralized vs. distributed)
- Ensure lienholder information is correct if financing is involved
For Out-of-State Buyers Who Will Operate in California:
- Clarify whether the truck needs California registration or can remain registered elsewhere
- Provide emissions certification documents that will be needed if the buyer later re-registers in California
- Advise the buyer about Clean Truck Check requirements and current EPA challenges
- Coordinate timing to avoid gaps in registration or double-payment scenarios
Common Title Transfer Mistakes:
- Submitting California title applications for trucks that don’t meet CARB emissions standards
- Failing to disclose prior California registration and outstanding fees
- Processing title transfers before resolving lien releases or lost titles from previous owners
- Missing filing deadlines that trigger late fees or penalties
How Quick Auto Tags Prevents These Errors:
Quick Auto Tags’ dealer services specialize in complex commercial title transfers. We handle:
- Pre-sale due diligence on registration eligibility
- Coordination between multiple states’ DMV systems
- Lien release verification and processing
- Accurate fee calculation, including use tax considerations
- Expedited processing to minimize financing holds and customer delays
Government Fleets: The ZEV Requirements That Didn’t Go Away
While private fleets got a reprieve from ACF purchase mandates, state and local government fleets in California are still fully subject to zero-emission vehicle requirements—and those requirements are accelerating.
What Government Fleets Must Do in 2026–2027
2024–2026 (Current Phase):
- 50% of new vehicle purchases must be ZEV or near-ZEV (NZEV)
- NZEVs include plug-in hybrid electric vehicles (PHEVs) and can be counted the same as full ZEVs until 2035
- Small government fleets (10 or fewer vehicles) are exempt until 2027
- Fleets in designated low-population counties are exempt until 2027
2027 and Beyond:
- 100% of new vehicle purchases must be ZEV or NZEV
- NZEVs continue to count until 2035, when only full ZEVs will meet requirements
- Exemptions for small fleets and low-population counties expire
Alternative Compliance: ZEV Milestone Option
Government fleets can choose between two compliance pathways:
- Model Year Schedule (default): Buy ZEVs according to the percentages above
- ZEV Milestones Option: Meet specific fleet composition targets based on vehicle size and model year, allowing more flexibility in phasing ZEVs into the fleet over time
Temporary Exemptions and Extensions
CARB has provided flexibility for government fleets facing real-world obstacles:
- Infrastructure Delays: If the fleet starts a charging/fueling infrastructure project but faces construction delays, it can request a one-year extension.
- Electrical Delays: If the utility cannot provide necessary electrical upgrades on schedule, the fleet may delay ZEV purchases (extensions sunset in 2030).
- Vehicle Availability: If specific ZEV models aren’t yet available in required classes, purchases can be delayed
- Intermittent Snow Removal Vehicles: Temporarily exempt until 2030
- Transit Agency Maintenance Vehicles: Temporarily exempt until 2030 to allow focus on electrifying transit buses first
What This Means for Dealers Serving Government Fleets
If you supply vehicles to California state agencies, cities, counties, or special districts, you need to be prepared for:
Increased ZEV Demand in 2027:
The 100% ZEV purchase requirement kicks in for most government fleets in 2027. This creates a deadline-driven buying cycle that could strain ZEV inventory availability.
Complex Compliance Documentation:
Government fleet purchases require detailed documentation showing:
- Whether the vehicle qualifies as a ZEV or NZEV under ACF definitions
- How the purchase fits into the fleet’s compliance pathway (Model Year Schedule vs. ZEV Milestones)
- Whether the fleet has claimed any extensions or exemptions
- Reporting requirements to CARB (initial report due April 1, 2024; ongoing annual reports)
Specialized Registration Requirements:
Government fleets may use Permanent Fleet Registration (PFR) for qualifying commercial vehicles, which has its own rules and processes. Dealers need to understand:
- Which vehicles qualify for PFR vs. standard registration
- How to process title transfers for fleet vehicles
- Coordination with the government agency’s fleet manager and registration coordinator
Procurement Process Complications:
Government purchasing often involves formal RFPs, specifications, and approval processes. Adding ZEV requirements creates additional layers:
- Specifications must explicitly identify ZEV-qualified models
- Pricing must account for higher ZEV purchase costs (though offset by fuel/maintenance savings)
- Delivery timelines may be longer for ZEV models with limited production
- Infrastructure planning must be coordinated with vehicle purchases
Keeping Your Fleet Compliant: The Quick Auto Tags Advantage
California’s truck emissions landscape is in flux, but your registration and compliance obligations aren’t going away—they’re just getting more complex. This is where partnering with an experienced DMV business partner becomes not just convenient but strategically essential.
Why DIY Registration Doesn’t Work When Rules Keep Changing
When you handle registration in-house, you’re betting that:
- You have the current version of every rule (not the version from six months ago)
- You understand how federal challenges affect state enforcement timelines
- You can accurately calculate fees across multiple jurisdictions
- You have time to track down VIN verifications, lien releases, and emissions certifications
- You can recover quickly when documents are rejected for technical errors
Most fleet managers and dealers can’t make all those bets consistently—especially when they’re trying to run their actual business operations at the same time.
Quick Auto Tags eliminates that risk through:
1. Real-Time Regulatory Expertise
Our team tracks California emissions rules, federal challenges, court settlements, and EPA proposals daily. When the EPA proposes to block Clean Truck Check on out-of-state vehicles (as happened in August 2025), we know about it, understand the implications, and can advise clients on strategy immediately—not six months later when someone stumbles across the Federal Register notice.
This means you get answers to questions like:
- “Should I register this truck in California or Nevada given the current EPA proposal?”
- “Is this used truck I’m buying subject to Clean Truck Check or not?”
- “What documentation do I need to prove exemption from ACF if California audits my fleet?”
- “How do title transfer timelines work when trucks are moving between California and other states?”
2. Controlled Processing Across Jurisdictions
Managing multi-state fleet registration in-house means juggling different DMV systems, appointment schedules, fee structures, and documentation requirements. Quick Auto Tags handles:
- California registrations with proper emissions verification and Clean Truck Check enrollment
- Out-of-state registrations for fleets establishing nexus in other jurisdictions
- Interstate transfers when trucks move between registration states
- Lien coordination for financed vehicles across multiple states’ DMV databases
- Temporary permits and trip permits for trucks operating across state lines while permanent registration processes
3. Government Fleet Specialization
For dealers and agencies managing California government fleet requirements, Quick Auto Tags provides:
- ZEV compliance documentation showing how purchases meet ACF requirements
- Permanent Fleet Registration expertise for qualifying commercial government vehicles
- CARB reporting coordination for annual compliance reports and milestone tracking
- Extension and exemption guidance for infrastructure delays, vehicle availability, and temporary exemptions
4. Dealer-Specific Services for Complex Transactions
For truck dealers navigating the intersection of California emissions rules and customer registration needs, Quick Auto Tags offers:
- Pre-sale registration eligibility assessment to identify issues before money changes hands
- Title transfer services that handle lien releases, out-of-state coordination, and fee calculations
- Customer delivery support so buyers receive their trucks with proper California registration and plates
- Clean Truck Check onboarding for customers who need to enroll vehicles after purchase
5. Protection from Costly Mistakes
Processing errors don’t just cause delays—they cost real money:
- Late fees when paperwork sits in DMV queues due to missing documentation
- Duplicate payments when registration renewals cross state lines
- Violations and penalties for operating trucks without valid registration while “straightening things out”
- Lost incentives when ZEV purchase documentation isn’t filed correctly or on time
- Customer disputes when dealers deliver vehicles with registration problems
Quick Auto Tags’ two-year document retention, audit trail systems, and quality control processes prevent these errors before they happen—saving far more than our service fees cost.
The Bottom Line: Navigate Uncertainty with Expert Partners
California’s truck emissions rules are in the middle of a major regulatory realignment. The Advanced Clean Fleets purchase mandates for private fleets are being repealed. The Clean Truck Check program for out-of-state vehicles is being challenged by the EPA. Federal courts are questioning California’s authority to regulate interstate commerce. But government fleet ZEV requirements are accelerating, and base California emissions standards aren’t going anywhere.
For fleet managers and dealers, this uncertainty creates operational challenges that go far beyond “Which truck should I buy?” You need to make strategic decisions about:
- Where to register vehicles to minimize compliance costs
- How to document exemptions and compliance for future audits
- Which rules are actually being enforced versus which are in legal limbo
- How to handle title transfers and registrations when trucks cross jurisdictions
- What happens if federal policy shifts again in 2027 or 2029
Making these decisions requires current knowledge, strategic thinking, and practical execution—all while running your core business operations.
Quick Auto Tags provides the expertise, processing capability, and regulatory intelligence to keep your fleet compliant without draining management time.
Whether you’re registering a single out-of-state truck into California, managing a 200-vehicle interstate fleet, or processing dealer title transfers for government and commercial customers, we ensure your paperwork is right, your fees are correct, and your vehicles are legally registered—no matter how many times the rules change.
Ready to simplify your California truck registration and compliance strategy? Contact Quick Auto Tags at (951) 409-9091 or visit us in Riverside to discuss how we can help you navigate California’s evolving emissions landscape with confidence.
California Truck Emissions Compliance Checklist
For Interstate Fleet Managers:
- [ ] Review where your heavy-duty trucks are currently registered (California vs. other states)
- [ ] Assess potential cost savings if EPA finalizes disapproval of Clean Truck Check for out-of-state vehicles
- [ ] Verify all California-registered trucks are enrolled in CARB’s TRUCRS database
- [ ] Confirm emissions certification status for all vehicles operating in California
- [ ] Identify vehicles approaching replacement cycle and reassess ZEV vs. conventional diesel economics
- [ ] Review registration strategy with Quick Auto Tags fleet experts to optimize compliance costs
- [ ] Document operational nexus in any states where you’re considering registration
- [ ] Update insurance policies to reflect registration jurisdiction changes
For California Government Fleets:
- [ ] Confirm your compliance pathway (Model Year Schedule vs. ZEV Milestones Option)
- [ ] Calculate how many ZEV purchases are required in 2026 to meet 50% target
- [ ] Prepare for 100% ZEV purchase requirement starting in 2027
- [ ] Identify vehicles that qualify for temporary exemptions (snow removal, transit maintenance, etc.)
- [ ] Review infrastructure projects and identify potential delays that might require extensions
- [ ] Coordinate with utility providers on electrical upgrades needed for charging infrastructure
- [ ] Evaluate Permanent Fleet Registration eligibility for commercial government vehicles
- [ ] Ensure annual CARB compliance reports are filed on time
For Dealers Serving California Customers:
California dealers are already navigating the complexities of the CARS Act (SB 766) taking effect in October 2026. Adding emissions compliance uncertainty to the mix makes expert registration partnership even more critical.
- [ ] Verify which trucks meet California emissions standards before accepting inventory
- [ ] Clarify with commercial fleet customers whether they’re subject to government ZEV requirements
- [ ] Update sales processes to document registration jurisdiction strategy for interstate customers
- [ ] Coordinate with Quick Auto Tags dealer services for title transfer and registration processing
- [ ] Develop pre-sale due diligence checklist for used out-of-state trucks
- [ ] Track which states have delayed or paused Advanced Clean Trucks (ACT) enforcement
- [ ] Update customer education materials to reflect ACF repeal and Clean Truck Check changes
- [ ] Ensure financing coordination accounts for potential registration jurisdiction complexities
About Quick Auto Tags
Quick Auto Tags is a California DMV-authorized business partner providing comprehensive registration, titling, and fleet services to dealerships, commercial vehicle operators, and government agencies throughout the state. With specialized expertise in interstate registration, emissions compliance, and complex title transfers, Quick Auto Tags helps fleet managers and dealers navigate California’s evolving regulatory landscape with confidence and efficiency.
Sources:
- California Air Resources Board – Advanced Clean Fleets Regulation
- EPA Proposed Rule – California Heavy-Duty Vehicle Inspection and Maintenance Program
- Nebraska v. California Settlement Agreement – May 2025
- ACT News – EPA Proposes to Block California’s Heavy-Duty Truck Rule
- California Air Resources Board – Advanced Clean Fleets Regulation Summary
