California ACF and State ZEV Mandates: US Compliance Guide

A Head of Compliance at a US logistics company reviews the fleet electrification regulatory exposure for the next five years. The original brief from the operations team referenced “zero-emission zones” — language borrowed from European regulations like Amsterdam, Paris, and London. The US doesn’t have geographic ZEZs at the European scale. What it has instead is a fleet-mandate regulatory framework, originating in California and spreading through state-level adoption — though as of mid-2026, that framework looks considerably narrower than it did even a year ago.

For US compliance leaders, the regulatory landscape is genuinely different from the European playbook — and it has also moved meaningfully since this guidance was first published. California’s Advanced Clean Fleets regulation has been pulled back to cover state and local government fleets only. The Advanced Clean Trucks rule it relied on for manufacturer-side supply is paused in several adopting states. Port and warehouse-related programs, by contrast, have continued operating largely on schedule. The compliance question for 2026 isn’t “how aggressive is this framework” — it’s “which parts of it actually still apply to us.”

This is a compliance framework for US logistics operations as of June 2026. It covers what remains of California Advanced Clean Fleets and Advanced Clean Trucks, the state of the ACT adoption wave, port emissions programs, warehouse indirect source rules, and operational planning under a regulatory environment that has proven genuinely volatile.

According to the California Air Resources Board (CARB), the Advanced Clean Fleets regulation adopted in 2023 was originally one of the most operationally consequential fleet electrification regulations adopted in any major economy. Its scope has since been substantially reduced for private operators, though it remains active for state and local government fleets and continues to set the policy template other states reference.

Don’t Let Shifting Mandates Outpace Your Fleet Plan

Locus’s agentic TMS manages mixed diesel, NZEV, and ZEV fleets on one platform — so a repeal, a delay, or a new state mandate doesn’t force a re-architecture of your dispatch and routing stack.

Explore the Locus TMS

The Five Operational Territories

1. CARB Advanced Clean Fleets Compliance

ACF, adopted by CARB in 2023, originally regulated three fleet categories operating in California: high-priority fleets ($50 million-plus revenue or 50-plus vehicles), drayage fleets at California ports and intermodal facilities, and state/local government fleets. That is no longer the current state of the regulation. On September 25, 2025, CARB voted to repeal the High-Priority Fleet and Drayage Fleet requirements after it became clear the federal EPA would not grant the Clean Air Act waiver CARB needs to enforce ZEV mandates on private and federal fleets. CARB had already withdrawn its waiver request in January 2025. The repeal takes effect January 1, 2027.

What remains in scope: state and local government (SLG) fleets operating medium- and heavy-duty on-road vehicles with a GVWR over 8,500 pounds in California. Amendments approved alongside the repeal also extended the SLG compliance timeline — the 50% ZEV purchase requirement moved from January 1, 2024 to January 1, 2027, and the 100% requirement was delayed from 2030 (originally proposed for 2027) further out, with CARB continuing rulemaking through 2026 (a Second 15-Day Notice of Modifications was released June 1, 2026) to finalize exemption and contractor-fleet language.

The honest operational framing for 2026: ACF compliance is now primarily a public-sector and contractor-to-government issue, not a general private-fleet issue. National 3PLs and shippers whose California exposure was purely private-fleet or drayage-based should re-scope their compliance programs — continuing to build for a mandate that no longer applies to them is itself a compliance gap, just an inverted one. Compliance leaders who do work under contract for California state or local government agencies should note that CARB has maintained, in its June 2026 rulemaking draft, that contracted vehicles performing public-agency services count toward that agency’s fleet obligations — a more expansive reading than many contractors initially assumed.

2. The State Adoption Wave

CARB’s Advanced Clean Trucks rule (the manufacturer-side regulation requiring increasing ZEV sales percentages) was adopted in modified form by 11 states beyond California, including Washington, Oregon, Massachusetts, New York, New Jersey, Vermont, Colorado, Maryland, New Mexico, and Rhode Island. Adoption, however, is not the same as active enforcement, and 2025–2026 has been a year of enforcement pauses rather than expansion. Oregon’s Department of Environmental Quality halted ACT enforcement for two years. Vermont’s governor signed an executive order suspending ACT until 2027. Washington’s Department of Ecology has extended its enforcement pause through June 2026 amid ongoing litigation. Maryland pushed back enforcement to 2028, and Massachusetts to 2027, both citing immature Class 7–8 electric truck supply and insufficient charging infrastructure. New York and New Jersey, while not formally pausing, face active legislative pressure to delay.

For multi-state operations, the practical compliance question for 2026 is no longer “what’s our cumulative ACT-aligned footprint” in the way it was framed a year ago — it’s “which of our ACT-aligned states are actually enforcing right now, and on what timeline.” Treating adopted-but-paused regulation as live regulation leads operators to over-invest in compliance infrastructure ahead of need; treating paused regulation as cancelled regulation risks getting caught when enforcement resumes, since none of these pauses are repeals. The variance is genuinely state-by-state and needs per-state tracking, not a single assumed timeline.

Also Read: Sustainable Last-Mile Delivery: 2026 Enterprise Guide

3. Port Programs and Drayage

US ports operate distinct emissions reduction programs that overlay state-level fleet regulations — and these have proven more durable than CARB’s drayage mandate. The Port of Los Angeles / Port of Long Beach Clean Air Action Plan sets requirements for drayage operators serving California’s largest ports independently of the now-repealed CARB Drayage Fleet rule. The Port Authority of New York and New Jersey runs its own emissions reduction program. The Port of Seattle and Port of Tacoma operate the Northwest Ports Clean Air Strategy.

Because CARB’s Drayage Fleet requirement is being repealed at the state level (effective January 1, 2027), port-level programs are now the primary source of mandatory ZEV drayage timelines, not CARB. Operators serving California ports should confirm current TRUCRS registration requirements directly with the relevant port authority rather than assuming the prior CARB drayage schedule still governs — the two have effectively decoupled.

4. Warehouse and Distribution Center Exposure

The South Coast Air Quality Management District (AQMD) Rule 2305, adopted in 2021, takes a different regulatory approach. Rather than regulating fleet operators directly, the rule regulates warehouses 100,000 square feet and larger in the South Coast AQMD jurisdiction (much of the LA basin), requiring those warehouses to reduce emissions from the trucking activity they generate.

Rule 2305 is no longer just a regional rule: the EPA approved it into California’s State Implementation Plan in 2024, making it federally enforceable under the Clean Air Act. The US District Court for the Central District of California has also resolved preemption challenges brought by the California Trucking Association and Airlines for America, upholding SCAQMD’s authority to enforce it. Of the four regulatory territories covered here, Rule 2305 is the one that has gotten more durable, not less, since 2025.

The implication is significant: even logistics operators that don’t own trucks face exposure through their warehouses. Operations using contracted carriers can be required to track, report, and reduce emissions from those carriers’ activity at the warehouse. Other air quality management districts in California and other states are evaluating similar indirect source rule frameworks.

Also Read: What is 3PL Sustainability? Benefits & Key Strategies for 2025

Plan Dispatch Around Mixed Fleets, Not Around the Next Mandate Shift

Locus’s dispatch planning engine accounts for 250+ real-world constraints — including vehicle type, range, and warehouse-level emissions reporting — so your routing stays compliant whichever way state and federal rules move next.

See dispatch planning

5. Compliance Planning Under Regulatory Uncertainty

US fleet electrification regulation faced genuine uncertainty at the start of 2026 — and that uncertainty has now resolved into specific, documented outcomes rather than remaining hypothetical. Federal EPA Phase 3 GHG standards remain subject to legal challenges and shifting administration posture. California withdrew its own Clean Air Act waiver request in January 2025 rather than wait for a federal denial, then repealed ACF’s private-fleet provisions in September 2025 once it was clear no waiver was coming. Multiple ACT-adopting states followed with their own enforcement pauses through 2025 and into 2026.

The operational planning implication is not paralysis — it’s recalibration. State-administered programs that don’t require a federal waiver (SLG fleet rules, port programs, warehouse indirect source rules) have proven more durable than programs that did require federal sign-off (private and federal fleet ZEV mandates). The honest framing for compliance leaders heading into the rest of 2026: track enforcement status state-by-state and program-by-program rather than assuming adoption equals enforcement, and continue to architect fleet electrification on operational and economic merits that hold regardless of regulatory outcome. Operations electrifying because the unit economics work hold up under any regulatory scenario; operations that built compliance programs purely around the now-repealed private-fleet mandate are absorbing avoidable cost today.

Also Read: Why Sustainable Last-Mile Matters for Business Growth and Customer Loyalty

Five Common Compliance Gaps in US Fleet Operations

Across US logistics operations approaching ACF and state ZEV mandate compliance in 2026, five gaps appear consistently. Misjudged regulatory scope in either direction — operators either continue compliance spend against ACF provisions that no longer apply to private fleets, or assume the entire framework has collapsed and miss that SLG, port, and warehouse exposure remain live. Drayage exposure misattributed to the wrong authority — operators assume CARB still sets drayage ZEV timelines when port-specific programs are now the operative source. Warehouse exposure missed in fleet-focused planning — Rule 2305 affects operations through the warehouse, not the truck, is now federally enforceable, and is invisible to fleet-only compliance frameworks. Charging infrastructure planning lagging vehicle procurement — operators procure ZEVs without securing site infrastructure on parallel timelines, a problem several states have cited as a reason for their own enforcement pauses. No process for tracking enforcement status, not just adoption status — operators planning against the original 2023–2024 ACF/ACT timelines without a mechanism for catching repeals, pauses, and amendments as they happen through 2025 and 2026.

Also Read: How 3PL CFOs Can Quantify the ROI of Dispatch Automation

The Compliance Planning Framework

Five questions for US compliance leaders evaluating fleet electrification regulatory exposure as of mid-2026.

1. Have we re-scoped our regulatory exposure against the current status of each framework — CARB ACF (now SLG-only), ACT-aligned state regulations (several paused), port emissions programs, and warehouse indirect source rules — or are we still planning against the 2023–2024 versions of these rules?
2. Do our drayage operations have a compliance plan anchored to the relevant port authority’s program, given that CARB’s own drayage requirement is being repealed effective January 1, 2027?
3. Have we evaluated our warehouse exposure under Rule 2305, including operations using contracted rather than owned carriers — and accounted for the fact that it is now federally enforceable, not just regionally adopted?
4. Is our charging infrastructure planning realistic given that several states have cited infrastructure gaps as their own reason for delaying enforcement — are we over- or under-building relative to actual near-term mandate timing?
5. Do we have a standing process to track enforcement status changes — repeals, pauses, amendments — across every framework we’re exposed to, rather than re-discovering them when a compliance date we assumed was fixed turns out to have moved?

US fleet electrification regulation in 2026 looks meaningfully different from how it looked even twelve months ago. It still operates through fleet mandates, manufacturer requirements, port programs, and indirect source rules rather than through geographic delivery zones — but several of those mandates have narrowed or paused, while the facility-based and port-based programs have held or strengthened. The compliance framework still affects most national logistics operations, just through a different and more state/program-specific cumulative footprint than the 2023–2024 version of this story suggested.

The strategic question for US compliance leaders is no longer “are we ready for California’s mandate as written in 2023?” It is: across the regulatory footprint as it actually stands today — not as it was adopted, but as it is currently enforced — do we have a compliance framework that adapts as fast as the rules do, and are we electrifying on operational merit alongside regulatory compliance?

Also Read: The Three-Workforce Fleet Reality: How Owned, 3PL, and Gig Drivers Actually Operate at Most Enterprises

Get a Compliance-Ready Fleet Operating Model

See how Locus helps logistics teams run mixed ICE/NZEV/ZEV fleets, track warehouse-linked emissions exposure, and adapt routing as state and federal mandates shift — without re-platforming every time a rule changes.

Schedule a demo