CARB Regulations for TRUs

In August 2019, we reported on the proposed new regulations by California Air Resources Board (CARB) that would impact TRUs that operate in California. As of March 2020, all but one of these proposals have changed. Most are specific to a date adjustment or the use of a diesel particulate filter (DPF). As a fleet owner, we want you to be aware of and prepared for how these regulations could impact your business.

Latest CARB proposed regulations

Concept Intent Draft Intent Summary of Change
All TRU's must register with CARB - Timing 2022. All TRUs must register with CARB by Dec. 31, 2021. No Change

Concept Intent Draft Intent Summary of Change
All newly manufactured truck, trailer, domestic shipping containers and rail TRUs manufactured with refrigerant must have a Global Warming Potential (GWP) less than or equal to 2,200 - timing 2022. On or after Dec. 31, 2021, all newly manufactured truck, trailer, domestic shipping containers and rail TRUs manufactured with refrigerant must have a Global Warming Potential (GWP) less than or equal to 2,200. Firm date of Dec. 31, 2021 versus 2022.

Implications:

TRU equipment manufacturers will be able to meet requirements by 2022 of the lower GWP on new equipment. Customers with maintenance facilities should proactively reach out to their suppliers to assure their shops can transition to the new refrigerant while supporting legacy equipment.


Concept Intent Draft Intent Summary of Change
All trailer and domestic shipping containers TRUs will meet zero-emission operation when parked or stationary for more than 15 minutes at an applicable facility - timing 2025.
On or after Dec. 31, 2023 all new trailer and domestic container TRUs and gen-sets must have the ability to operate in zero-emission mode. TRUs cannot operate in a manner that exceeds a stationary operating time limit (SOTL) of 15 minutes within an applicable facility. Firm date of Dec. 31, 2023 for new equipment versus 2025.
On or after Dec. 31, 2027 all trailer, domestic container TRUs and gen-sets must comply with the 15 minute stationary operating time limit at applicable facilities. Firm date of Dec. 31, 2027 for all equipment versus 2025.

Implications:

Operating a TRU without the ability to meet stationary operating time limits (SOTL) creates significant risks for carriers that pickup and deliver at facilities that have the ability for them to plug in and operate in zero-emission mode. Beginning immediately, for fleets operating in CA and run their equipment for 7+ years, purchasing units with electric standby or the ability to convert to electric standby needs to be given consideration in the TRU selection process.


Concept Intent Draft Intent Summary of Change
All trailer and domestic shipping container TRUs must be equipped with electronic telematics system - timing 2025.
New equipment must be equipped with electronic telematics system by Dec. 31, 2023. Firm date of Dec. 31, 2023 for new versus 2025.
All equipment must be equipped with electronic telematics system by Dec. 31, 2027. Firm date of Dec. 31, 2027 for all versus 2025.

Implications:

Selecting a TRU with a factory integrated ETS assures current and future compliance regardless of regulatory requirements and timing.


Concept Intent Draft Intent Summary of Change
All trailer, domestic shipping container, rail box car TRUs, and gensets must meet the US EPA Tier 4 final emission standards for 25-50 hp engines.
On or after Dec. 31, 2023 all new trailer, domestic shipping containers, rail TRUs and gen-sets must meet US EPA Tier 4 final emission standards for 25-50 HP engines. Firm date of Dec. 31, 2023 for new equipment versus 2025 for all equipment.1
On or after Dec. 31, 2023 all legacy <25 HP TRUs with a manufacturing date prior to Dec. 31, 2023 must have a level 3 verified diesel emission strategy device, such as a diesel particulate filter (DPF). Any <25 HP unit to operate with a diesel particulate filter (DPF) regardless of unit age.2
On or after Dec. 31, 2030 all trailer, domestic shipping containers, rail TRUs and gen-sets must meet US EPA Tier 4 final emission standards for 25-50 HP engines. Firm date of Dec. 31, 2030 for all TRUs to meet 25-50 horsepower emissions versus 2025.3

Implications:

1 Evergreen solutions will continue to see escalating residual values versus <25 HP solutions, with or without a diesel particulate filter (DPF).

2 <25 HP product will have a full 7 year useful life if purchased by 2023, assuming DPF is added. Diesel particulate filters (DPF) are no longer a means to indefinitely meet emission regulations. The end of life for DPF units is 2030.

3 >25 HP TRUs purchased now, require no additional investment to meet emissions requirements in California.


Draft Regulatory Language:
https://ww3.arb.ca.gov/cc/cold-storage/documents/Draft%20TRU%20Regulatory%20Language_03122020.pdf

CARB Presentation:
https://ww3.arb.ca.gov/cc/cold-storage/documents/tru_conceptslidesworkshop3192020.pdf

*The information provided herein does not, and is not intended to, constitute legal advice; instead, all information, content, and materials are provided for general informational purposes only. If you have any questions about this information, you should consult with your individual attorney to provide assurances that the information – and your interpretation of it – is applicable or appropriate to your particular situation. The information is provided "as is;" no representations are made with respect to the accuracy of the information.

TRUs developed to meet both CARB and EPA Emission compliance

Contact your local Thermo King Dealer to find out about our compliant Precedent Units.