CARB Regulations for Trucks, Trailers & Domestic Shipping Containers

What are CARB regulations?

The California Air Resources Board (CARB) is a department within the California Environmental Protection Agency that is working to address air pollution in the state.

CARB has adopted a series of regulations aimed at reducing emissions from Transport Refrigeration Units (TRUs) by transitioning to zero-emission operation where practical. The 2022 and 2023 amendments, which increase the use of zero-emission (ZE) technology, are designed to protect the health of the public and the environment.

CARB regulations apply to all TRUs operating in California, regardless of the home state of the unit or company. Currently, 16 additional states are committed to the new requirements, with more states expected to join.

The information provided below is intended to serve as a guide. It is not to be used as legal advice.

Which CARB regulations apply to your fleet?

Current CARB regulations for trucks, trailers & domestic shipping containers

Refrigerant ≤ 2,200 global warming potential (GWP)

  • 2477.13(a) - Beginning December 31, 2022, TRU OEMs shall not manufacture for sale or use in California, a truck TRU, ZE truck TRU, trailer TRU, or DSC TRU, unless that TRU uses a refrigerant with a GWP value less than or equal to 2,200, or uses no refrigerant at all.
    • 2477.13(a)(1) - The TRU shall include a refrigerant label that is readily visible and legible, and include the following statement, or its equivalent: “THIS UNIT CONTAINS REFRIGERANT WITH A GWP LESS THAN OR EQUAL TO 2,200 AND IS COMPLIANT FOR USE IN THE STATE OF CALIFORNIA.”
  • 2477.5(a)(1) - Beginning December 31, 2022, no owner or owner/operator shall operate or cause to be operated in California, a TRU with a manufacture date after December 31, 2022, unless the TRU uses a refrigerant with a GWP value less than or equal to 2,200, or uses no refrigerant at all.
  • 2477.5(a)(2) - Beginning December 31, 2022, no owner or owner/operator shall operate or cause to be operated in California, a TRU with a manufacture date after December 31, 2022, with an unreadable or inadequately maintained TRU OEM supplied refrigerant label.

Registration

  • 2477.5(g)(3) California-based TRUs added to an owner’s or owner/operator’s operations after January 31, 2009 and non-California based TRUs added to an owner’s or owner/operator’s operations after December 31, 2023 shall be brought into compliance with section 2477.5(g)(1) and (2) within 30 days of the unit entering the owner or owner/operator’s control or beginning operations in California. The owner or owner/operator shall request:
    • 2477.5(g)(3)(A) A CARB IDN for a new TRU that was not previously numbered, or
    • 2477.5(g)(3)(B) A change in owner or owner/operator for a TRU that already has a CARB IDN number.

Labeling

  • 2477.5(i)(2) Beginning December 31, 2023, upon verifying the information reported under section 2477.5(g) and all TRU operating fees have been received in accordance with section 2477.5(h), the Executive Officer shall issue two compliance labels for each TRU. 
  • 2477.5(i)(3) Within 30 days of receipt of the CARB compliance labels, owners or owner/operators shall affix the labels in clear view, correct side up, un obstructed; and kept and maintained in a manner that retains legibility. The location of the label shall be as follows: 
    • 2477.5(i)(3)(A) Truck and trailer TRUs - both sides of TRU chassis housing. 
  • 2477.5(i)(4) TRU compliance labels shall be valid for three (3) years from date of issuance.

Current CARB regulations for trucks (self-powered)

Zero emissions

  • 2477.5(b)(1) Beginning December 31, 2023, no owner or owner/operator shall operate or cause to be operated in California, any truck TRU in the owner’s truck TRU fleet, unless the fleet meets or exceeds the required ZE truck TRU fleet percentages specified below.

Compliance Date as of December 31
2023 - 15% Required ZE Truck TRU Fleet Percentage

2024 - 30% Required ZE Truck TRU Fleet Percentage

2025 - 45% Required ZE Truck TRU Fleet Percentage

2026 - 60% Required ZE Truck TRU Fleet Percentage

2027 - 75% Required ZE Truck TRU Fleet Percentage

2028 - 90% Required ZE Truck TRU Fleet Percentage

2029 and thereafter - 100% Required ZE Truck TRU Fleet Percentage

The required number of ZE truck TRUs is based on the truck TRU fleet size reported to CARB on December 31, 2023 or December 31 of each year, whichever reported truck TRU fleet size is greater.

  • 2477.5(b)(3) If the calculated ‘number of ZE Truck TRUs’ is not equal to a whole number, the owner shall round up to a whole number when the fractional part of the required number of ZE truck TRUs is equal to or greater than 0.5, and round down if less than 0.5. For example: 
    • 2477.5(b)(3)(A) A fleet consisting of one truck TRU that operates in California shall contain one ZE truck TRU by December 31, 2026. 
    • 2477.5(b)(3)(B) A fleet consisting of two truck TRUs that operate in California shall contain one ZE truck TRU by December 31, 2024 and two ZE truck TRUs by December 31, 2027.

Downsizing a Fleet

  • 2477.5(b)(2) A TRU owner may have a smaller “Total Truck TRU Fleet” than otherwise required for a given Compliance Date if, between January 1 and December 31, inclusive, of the prior Compliance year, the TRU owner has not purchased any additional direct-drive refrigeration units in which the compressor is powered from the truck’s diesel engine, to replace the original diesel-powered units being sold or retired.

Requirements for TRU original equipment manufacturers

  • 2477.13(b) Beginning December 31, 2023, TRU OEMs shall not manufacture for sale or use in California, a truck TRU, unless it is a ZE truck TRU. 
    • 2477.13(b)(1) TRU OEMs shall warrant to the ultimate purchaser and each subsequent purchaser that the ZE truck TRU is free from defects in materials and workmanship which cause the failure of any warranted part. 2477.13(b)(1)(A) The warranty shall be comprehensive and cover all parts of the ZE truck TRU. 
    • 2477.13(b)(1)(B) The warranty period shall cover a period of three years from the date of purchase or 5,000 hours of compressor run time, whichever occurs first.

Current CARB regulations for trailers & domestic shipping containers

Engine ultra-low emissions TRU (ULETRU)

  • 2477.5(d) PM Emission Standard for MY 2023 and Newer TRU and TRU Gen Set Engines. The term TRU as used in this subsection (d) refers only to trailer TRUs, DSC TRUs, railcar TRUs, and TRU gen sets. Truck TRUs are exempt from the requirements of this subsection (d). Beginning December 31, 2022, no owner or owner/ operator shall operate or cause to be operated in California, a MY 2023 and newer TRU or TRU gen set engine, unless it meets a PM emission standard of 0.02 g/hp-hr or lower. 
  • 2477.5(c )(4)(A) Beginning December 31, 2022, no owner or owner/operator shall operate or cause to be operated in California, a MY 2022 and older TRU or TRU gen set engine, unless it meets the in-use performance criteria set forth in section 2477.5(c ) for ULETRU on or before December 31st of the seventh year past the engine’s model year. For example: 
    • 2477.5(c )(4)(A)(1) No owner or owner/operator shall operate or cause to be operated in California, a MY 2020 TRU or TRU gen set engine, unless it meets ULETRU on or before December 31, 2027. 
  • 2477.13(c ) Beginning May 31, 2023, TRU OEMs shall not manufacture for sale or use in California, a trailer TRU, DSC TRU, railcar TRU, or TRU gen set, unless it is equipped with an engine that meets or outperforms the performance standard set forth in section 2477.5 (d).

How Thermo King is helping to reduce emissions


Let Thermo King assist with CARB compliance

Contact your local Thermo King Dealer to find out about our CARB compliant trucks, trailers and shipping containers.