California Implements New Generator Requirements

Oct 28, 2020

Motorhome manufacturers installing generators fueled by gasoline, also referred to as gensets, should be aware of new requirements in California applicable to the installation of model year 2020 and newer generators.

As has been the case for many years, compliance with evaporative emissions regulations in California requires motorhome manufacturers to carefully follow installation instructions provided by the generator manufacturer and vehicle chassis supplier. Failure to follow such instructions can void the California Air Resources Board (CARB) certificate of compliance for generators and/or chassis fuel evaporative emissions systems and subject the installer to noncompliance penalties.

When installing motorhome generators, manufacturers must take care to use only the fuel hoses and related components specified for use by the generator’s manufacturer. The generator manufacturer’s installation manual will provide guidance for fuel hoses permissible for use.

In 2017, CARB amended its evaporative emissions regulation for small off-road engines. applicable to RV generators, to require fuel hoses and other components used in generators along with their associated fuel systems, to have new CARB certificates of compliance (known as Executive Orders or EOs). These EOs provide an indication that the component, such as a fuel hose, has been tested to conform with CARB’s 2020 evaporative emissions requirements. Failure to use a component accompanied by a new EO may void the generator manufacturer’s EOs and subject the installer to substantial nonconformance penalties.

Motorhome manufacturers should consult the installation guidelines provided by the generator manufacturers, as well as the chassis supplier to ensure full compliance with the current 2020 CARB emissions regulations.

In the past, the burden of compliance proof has typically been placed on the component supplier, such as the generator manufacturer. However, with the multitude of changes that are made over the course of time, these manufacturers are not providing specific guidance on fuel hose usage. Instead, it is now up to the RV motorhome manufacturer to determine if the hose being used is compliant.

To assist in this effort, the CARB website lists acceptable gasoline fuel hoses. Please check this link and verify that the hose you are using for the California market and CARB compliance is listed. All the fuel hose EOs listed at the link (even the ones from 2018 and 2019) are for hoses certified to comply with the 2020 standards.

We recommend manufacturers review the information at this link often as hoses may be added and deleted without other notice. It is the responsibility of businesses regulated by CARB to be aware of and comply with its rules and regulations.

Manufacturers should always consult with legal counsel on decisions related to CARB’s regulations. If you have any questions, please contact Mike Ochs at 571-665-5860 or mochs@rvia.org.