James Ledbetter
If you have spent the past two years trying to track whether your fleet faces a zero-emission vehicle purchase requirement, you are not alone — and the answer has changed. The regulatory picture for private commercial fleets in 2026 is fundamentally different from what many operators were bracing for in 2023 and 2024. This post is a factual, policy-neutral summary of where things stand, what still applies, and what fleets should watch going forward.
I am not going to editorialize about why the rules changed. My job here is to give you an accurate operating picture so you can plan intelligently.
The Mandates Most Fleets Were Watching
Two California Air Resources Board (CARB) rules drove most of the compliance concern among private carriers over the past several years:
Advanced Clean Trucks (ACT): A manufacturer-side rule requiring truck makers to sell an increasing percentage of zero-emission vehicles (ZEVs) as a share of total California sales, beginning in 2024 and scaling toward 2035.
Advanced Clean Fleets (ACF): A buyer-side rule that would have required certain fleet operators — “high priority” fleets (100+ trucks or $50M+ in revenue) and drayage fleets — to begin purchasing ZEVs on a set schedule, ultimately transitioning their full fleets to zero-emission operation.
Seventeen or more states had adopted or were in the process of adopting California’s rules under Section 177 of the Clean Air Act, which allows states to follow California’s stricter emissions standards rather than federal standards.
What Changed in 2025 and 2026
CARB Withdrew Its EPA Waiver Request for ACF
In January 2025, CARB withdrew its application for the EPA waiver that would have allowed enforcement of the Advanced Clean Fleets rule’s purchase mandate for High Priority and Drayage fleets. Without the waiver, CARB cannot enforce those provisions against most private fleet operators.
CARB has since moved toward formally repealing the High Priority fleet and Drayage fleet ZEV purchase mandate provisions. The formal repeal action is expected to be finalized by August 31, 2026.
The practical effect: the rule that would have required large private fleets and drayage operators to buy a set percentage of ZEVs has been pulled back. It is not being enforced, and the repeal process is underway.
Congressional Review Act Actions Rescinded Federal Waivers
Separately, Congressional Review Act (CRA) resolutions were passed and signed, rescinding the EPA waivers that California had been granted for three rules:
- Advanced Clean Cars II (ACC II)
- Advanced Clean Trucks (ACT)
- Omnibus Low-NOx rule
The rescission of these waivers halts enforcement of those rules in California and in the states that had opted in under Section 177. The ACT waiver rescission is significant for the commercial trucking market because ACT set the ZEV sales percentage requirements on truck manufacturers selling into California — which effectively shaped production decisions nationwide.
What this means for states that had adopted California’s standards: Those states can no longer enforce the opted-in rules for which the federal waiver has been rescinded. The regulatory framework that was being built toward a phased national transition to ZEV truck purchases has been substantially dismantled at the state mandate level.
What Still Applies: Government Fleet Requirements
One portion of CARB’s ACF rule remains intact and is being enforced: requirements for state and local government fleets.
Under CARB’s current enforcement posture, government-operated fleets face:
- A 50% ZEV purchase requirement for 2025 and 2026
- A 100% ZEV purchase requirement beginning in 2027
These requirements apply to California state agencies, local government entities, and other government-operated fleets — not to private carriers, for-hire trucking companies, or commercial fleets.
If you operate a private or for-hire commercial fleet, the government fleet provisions do not apply to you. If you do business with government entities that operate their own fleets, their ZEV procurement requirements may affect their operations and, indirectly, your service contracts with them.
What Fleets Should Still Watch
The rollback of the purchase mandates does not mean the EV conversation is over. Several dynamics continue to evolve and deserve attention in your fleet planning:
Federal Emissions Standards
Federal EPA emissions standards for heavy-duty engines — separate from California’s rules — continue to apply. The EPA’s Phase 2 and Phase 3 Greenhouse Gas standards set fuel efficiency and emissions requirements for newly manufactured trucks. These standards affect what manufacturers build and what is available on the market. Verify current federal standards with your equipment manufacturer or a compliance advisor.
Manufacturer Commitments and Inventory
Several major truck manufacturers have made public commitments to increase ZEV production — driven in part by their own fleet customer relationships, fuel efficiency calculations, and global market pressures. The availability, spec variety, and pricing of electric trucks continues to evolve. Fleets evaluating large equipment purchases over the next 3–5 years should track what is available, what the total cost of ownership looks like at current electricity rates and with available incentives, and what the resale market looks like for battery-electric trucks as the technology matures.
Federal and State Incentive Programs
Even without purchase mandates, incentive programs for ZEV adoption continue at the federal level (IRA tax credits, among others) and through various state programs. Fleets with the right operational profile — consistent routes, depot-charging feasibility, lower daily mileage requirements — may find the economics of electrification compelling on their own terms independent of any mandate. The incentive landscape changes frequently; verify current availability.
Infrastructure Development
Charging infrastructure for Class 8 trucks is expanding but uneven. Fleet operators evaluating ZEV integration need to assess charging infrastructure at their terminals and along their primary lanes — not just vehicle availability and cost.
Resale and Total Cost Considerations
Fleets that acquired electric trucks in anticipation of the mandate requirements face a resale market for battery-electric commercial vehicles that is still developing. Total cost of ownership calculations — acquisition price minus incentives, fuel savings at current rates, maintenance cost differences, battery replacement and warranty terms — are worth running carefully before committing to either accelerating or delaying ZEV adoption.
How Fleets Should Plan in This Environment
Here is my opinion, offered directly: the smartest fleet planning posture in 2026 is structured optionality, not a hard bet in either direction.
The mandates that drove fear of forced ZEV adoption have been paused or repealed. But assuming the EV question is permanently off the table is also a planning error. Federal standards will continue to evolve. Major shippers are increasingly including carbon footprint metrics in carrier RFPs. Fuel economics shift with diesel price cycles. The technology is improving, and total cost comparisons will look different in three years than they do today.
What that means operationally:
- Do not make large fleet commitments based solely on compliance avoidance — the mandates that drove that calculus have changed.
- Do not dismiss ZEV evaluation entirely — for the right routes, depots, and operational profiles, the economics may justify it on their own merits.
- Maintain visibility into incentive windows — some incentive programs have expiration dates or phase-out structures. Fleets with ZEV-suitable operations that delay evaluation may miss favorable economics.
- Watch state-level developments — California and other states retain the authority to develop new or revised rules. The current repeal and waiver rescission landscape reflects the regulatory posture of 2025–2026, not necessarily 2028 or 2030.
The freight business demands long-horizon equipment planning. The regulatory environment right now rewards careful, scenario-based thinking over reactive decisions in either direction.
For carriers navigating fleet planning decisions where compliance and supply chain strategy intersect, our fleet and supply chain advisory services and the team at Logistics Assistance Now are available to think through the specifics with you.
Frequently Asked Questions
Q: Does the ACF repeal mean I do not have to buy any electric trucks? For private commercial fleets, the ACF purchase mandate for High Priority and Drayage fleets is not being enforced and is in the process of formal repeal. You are not currently required under ACF to purchase ZEVs. However, federal emissions standards on manufactured equipment continue to apply, and other requirements (shipper contracts, state programs, etc.) may exist depending on your operation. Verify the current status with a compliance advisor.
Q: My state had adopted California’s Advanced Clean Trucks rule. Does the federal waiver rescission affect me? Yes. States that had adopted California’s ACT rule via Section 177 can no longer enforce the rule now that the EPA waiver underlying it has been rescinded through the Congressional Review Act process. Verify your specific state’s current posture with a local compliance or regulatory attorney.
Q: Are drayage operators at California ports still subject to ZEV requirements? The ACF drayage fleet provisions that would have required ZEV purchases are part of the rules being repealed. CARB’s waiver withdrawal and repeal actions cover these provisions. Drayage operators should verify current enforcement status directly with CARB, as the formal repeal timeline extends to August 31, 2026.
Q: What about the Omnibus Low-NOx rule? Does its waiver rescission affect my fleet? The Omnibus Low-NOx rule set stringent nitrogen oxide emissions standards for new heavy-duty engines sold in California and opt-in states. The CRA rescission of the waiver halts enforcement. As with ACT, the effect extends to states that had adopted California’s rule. This primarily affects new equipment purchases rather than existing fleet operations; engine manufacturers should be consulted on current available equipment specifications.
Q: Should we be tracking the IRA tax credits for electric trucks? Yes, if you are evaluating ZEV purchases. The Inflation Reduction Act includes commercial clean vehicle credits (Section 45W) for qualifying vehicle purchases. Eligibility rules, credit amounts, and program continuity should be verified with your tax advisor, as incentive programs are subject to legislative and regulatory change.
Navigating Fleet Planning Amid Regulatory Uncertainty
The zero-emission mandate picture has shifted significantly, but the equipment and operational decisions you make today will run on your fleet for years. Good planning requires both current regulatory accuracy and forward-looking scenario discipline.
Book a free consultation with Logistics Assistance Now. We work with carriers and fleets to evaluate compliance posture, supply chain strategy, and fleet planning decisions — with real operational experience behind the advice. Learn more about our services for carriers and fleets or explore our full range of consulting services.
Disclaimer: The regulatory status of clean truck mandates, EPA waivers, and state rules is actively evolving. The information in this post reflects the situation as of mid-2026. Always verify current federal and state requirements with CARB, the EPA, or a qualified regulatory advisor before making fleet or compliance decisions.
