Impact of CARB’s ACT Regulation On Motorhomes: What You Need To Know

RV Industry Association Statement:

Because there are no certified zero emissions chassis rated for motorhomes, the California Air Resources Board’s (CARB) ACT regulation could impact the availability of motorhomes in California beginning January 1. Motorhomes can still be sold either through utilizing the credit market or generating a carry forward deficit that will have to be offset by the chassis manufacturer credits within three years.

The RV Industry Association is in active discussions with CARB, along with our manufacturers and dealer partners, to identify and implement practical solutions that will ensure consumers and RVers can purchase and enjoy all types of RVs in California. We remain committed to working toward a sustainable path forward that supports both CARB’s goals and the RV and active outdoor lifestyle. We are also exploring all options to ensure all Americans will continue to be able to purchase new motorhomes.

UPDATE 12/4/24: On Tuesday, December 3, the RV Industry Association held a webinar to discuss the Advanced Clean Trucks (ACT) regulation and its impact on the RV industry. The presentation as well as video recording are available below. 

Additionally, updates to the FAQs have been made throughout.

Presentation Slides

UPDATE 12/2/24: We have added an additional FAQ about the three-year deficit make-up period. Please see FAQ #6.

UPDATE 11/20/2024: RV Industry Association Government Affairs staff, along with several of our motorhome manufacturer members, met on Tuesday afternoon (11/19/24) with the California Air Resources Board (CARB) staff overseeing the Advanced Clean Trucks (ACT) regulation. The meeting was requested by CARB to discuss in more detail the RV industry comments submitted as part of the ACT amendments proceeding in October. They also wanted to hear more directly from our members about what they are being told by the chassis manufacturers about why they are unable to deliver products.

CARB staff reviewed the various regulations that are impacting the motorhome industry at present, including the Omnibus Low NOx rule, the ACT, and the Advanced Clean Fleets rule. Following their presentation, a wide-ranging discussion was held with our members. We repeated our belief that an exemption or a delay in implementation from the ACT would be of greatest benefit to allow the industry to continue to provide motorhomes to dealers and customers in the state. Of note, CARB said it does have the authority to create exemptions to the regulation. This is different than what CARB has said on other regulations when they stated that allowable exemptions are set by the law which created the rule, not by CARB.

While no final resolution was attained, all sides agreed to continue talking and another meeting is being arranged in early December. The RV Industry Association will continue to explore all its options to find an equitable solution.

UPDATE 11/18/24: RV Industry Association staff continue to work with CARB, our members, and other stakeholders on this issue. As updates are available, this article will be updated to reflect any developments or any changes to the FAQs. Following additional clarification from CARB, the FAQ regarding a dealer's ability to sell a non-compliant RV to residents outside of California has been updated to note that is possible, provided the customer intends to register the motorhome in a non-ACT state. 

Original Article 11/7/2024:

In 2025, California's Advanced Clean Trucks (ACT) regulation, aimed at promoting zero-emission vehicles (ZEVs), will impact the availability of motorhomes in the state, as well as in additional states that follow the California Air Resource Board (CARB) regulations. While the regulation does not specifically ban motorhome sales, the ACT regulation mandates manufacturers of medium and heavy-duty vehicles to sell an increasing percentage of ZEVs each year. This has led some chassis manufacturers to halt sales of traditional internal combustion engine chassis for motorhomes in California, stemming from the lack of ZEV chassis suitable for motorhomes.

Since 2020, the RV Industry Association has been working with CARB on the ACT regulations through conversations directly with CARB staff as well as written and oral testimony at multiple public hearings. When CARB filed its proposed amendments earlier this year, the RV industry met with CARB staff to discuss the impact on the industry. The Association also submitted comments laying out the the negative impact of the regulation on the motorhome industry.

Unfortunately, CARB did not make any further amendment which would alleviate the problem of motorhome manufacturers being told by chassis manufacturers that they would not be able to supply ICE (internal combustion engine) chassis for sale into California since they could not offset their ZEV deficits by sales of a ZEV motorhome chassis.

Making the matter more complicated, it is not just the ACT that is causing the issue right now; it is the trio of regulations passed in the last 2-3 years: the ACT, along with the Omnibus Low NOx rule and the Advanced Clean Fleets rule. These three rules work together with the goal of gradually transitioning medium- and heavy-duty vehicles to zero emission vehicles (ZEVs) by 2036. We have commented to CARB on each of them, and also on the Small Off-Road Engine regulation which threatens spark-ignition engines on generators.

Below are some FAQs on the Advanced Clean Trucks Regulation and how it is specifically impacting the RV industry and RV consumers both in California as well as other states. For more information or questions on the impact of the Advanced Clean Trucks (ACT) regulation, please contact Mike Ochs, RV Industry Association Director of Government Affairs at mochs@rvia.org. 

Advanced Clean Trucks Regulation FAQs 

(Updates made throughout 12/4/24)

1. What is the Advanced Clean Trucks (ACT) regulation and does it ban the sale of motorhomes in California? When was this regulation passed?
The Advanced Clean Trucks (ACT) regulation was adopted by the California Air Resources Board (CARB or Board) in 2021 to establish zero emission vehicle standards for medium and heavy-duty vehicles. The ACT regulation establishes requirements for manufacturers that certify on-road vehicles over 8,500 lbs. gross vehicle weight rating (GVWR) to produce and sell an increasing portion of their sales as vehicles that emit no criteria or GHG emissions, i.e., zero emission vehicles (ZEVs) starting in the 2024 model year and ramping up through the end of the 2035 model year. All chassis manufacturers who produce more than 500 medium and heavy-duty vehicles being sold into California annually are covered by the regulation.

Amendments to the ACT regulation approved by the Board in October of 2024 addressed issues that have arisen through the rule’s implementation, including OEMs restricting sales of motorhome chassis. The amendments also sought to establish a new Zero-Emission Powertrain Certification test procedure and ensure alignment with the original intent of the rule as well as CARB’s commitments contained in the Clean Truck Partnership agreement.

While the ACT regulation does not impose an outright “ban” on motorhomes as claimed by various social media commentators, it has as its primary component a sales requirement that applies to manufacturers that certify incomplete chassis or complete vehicles greater than 8,500 lbs. GVWR (i.e., Class 2b-8 vehicles). Chassis manufacturers (e.g., Daimler, Ford, GM, Mercedez Benz, Navistar, Stellantis, etc.) are required to sell ZEVs as a certain percentage of their annual total sales. Because chassis manufacturers have no ZEV chassis that are rated for applications to motorhomes, some have been informing motorhome manufacturers that they will not be able to provide them with any internal combustion engine chassis for motorhomes for the California market.

2. Does the ACT apply only to motorhomes or are other vehicle types covered?
The goal of the ACT is to establish zero emission vehicle sales standards for medium-duty and heavy-duty vehicles – gas and diesel. While it applies to nearly all medium-duty and heavy-duty vehicles (see FAQ above for vehicle types exempted), motorhomes make up a tiny percentage of the vehicle miles traveled annually by medium-duty and heavy-duty vehicles in California. In fact, as we stated in our comments to CARB, motorhomes represent only 11.8 million miles versus the 4.8 billion miles for medium- and heavy-duty trucks (.2%), making it obvious that an exemption for motorhomes will not have an adverse impact on environmental concerns.

3. Is it all motorhomes or just diesel that are covered by the ACT regulation? Is there a weight limit? Are Class Bs affected?
While the majority of the attention thus far has focused on Class A and Class C diesel motorhomes, the regulation, with a few exceptions, applies to all medium-duty or heavy-duty vehicles with combustion engines. Any non-exempted on-road vehicle over 8,500 GVWR is included is covered by the regulation, including Class B motorhomes most of which have a GVWR over that amount.

Vehicles exempted from the ACT regulation include emergency vehicles, military tactical vehicles, transit vehicles subject to the Innovative Clean Transit regulation, school buses purchased by K-12 school districts and other entities, and light-duty vehicles dispatched but not owned by transportation network companies (ACT reg, Section 2012(c) Exemptions).

4. Does CARB consider this a ban, or are there options CARB has laid out for the industry? Are these options feasible? 
CARB insists that this regulation gives flexibility to chassis manufacturers in being able to buy and sell ZEV credits to allow them to build combustion engine chassis. The amendments approved last month will also permit secondary vehicle manufacturers to buy and sell these credits. However, neither of these provisions will guarantee that chassis manufacturers will utilize these credits, which are likely to be expensive on the open market and would add another layer of cost to producing a motorhome with a combustion engine chassis. Thus, the RV Industry Association does not believe that a solution that offers only one path for compliance (purchasing expensive ACT credits) is actually a solution at all.

5. What is the three-year deficit make-up period?
The expanded deficit make-up period provision in the ACT amendments approved in October permits a chassis manufacturer that has an outstanding deficit after the end of a given model year to make up that deficit within a consecutive three-model year period (previously it was only a one-year period). This provision does not apply to motorhome manufacturers, who are considered secondary vehicle manufacturers.

The three-model year period begins following the model year in which a chassis manufacturer generated the outstanding deficit. For example, if there is an outstanding deficit by the end of the 2024 model year, the makeup period would apply to the 2025, 2026, and 2027 model years. 

To utilize the entire three-model year period, a chassis manufacturer would have to reduce the net deficit to below 30% by the end of the first and second years of the makeup period. Using the same example as above, this means that the manufacturer would need to reduce their net deficit balance, which would include the deficit from 2024 and any newly-accrued deficit from 2025, to below 30% by the end of the 2025 model year. By the end of the 2026 model year, the manufacturer would need to again reduce their net deficit balance, which includes outstanding deficits from 2024, 2025, and 2026, to below 30%. The entire net deficit balance would need to be offset by the end of the 2027 model year. 

6. Is the ACT regulation limited to California or are other states following this same regulation? 
There are ten states which have adopted the CARB ACT rule. Rules in Massachusetts, New Jersey, New York, Oregon, and Washington will take effect with the 2025 model year while rules in Vermont will take effect with the 2026 model year, and those in Colorado, Maryland, New Mexico, and Rhode Island with the 2027 model year.

States that adopt California emission standards (so-called Section 177 states) are required by federal law to maintain consistency with California’s requirements. Thus, amendments made in California will eventually be adopted by the states listed above.

7. When does the ACT go into effect? Will dealers be able to sell motorhomes currently on their lots? Can consumers still register their new motorhomes after January 1, 2025?
The ACT rule applies to model year 2024 and later chassis. The rule has no effect on motorhomes that have already been legally produced and delivered to California. The regulation also has no enforcement provision for consumers or RV dealers. The ACT does not prevent RV consumers from registering their new motorhomes or RV dealers from selling motorhomes. 

8. If a consumer buys an RV from another state that does not comply with ACT, will the consumer be able to register the RV in California?
In the amendments adopted in October 2024, CARB adopted new vehicle labeling and reporting requirements that will help regulators in California ensure that new vehicles registered in California are compliant with the ACT regulation. The amendments take effect with the 2025 model year. In response to a question at the hearing about non-compliant vehicles coming in from out of state, CARB said that a used vehicle, defined as one with more than 7,500 miles on the odometer, could be brought in and registered. Any motorhome with less than 7,500 miles would be considered a new vehicle and would have to be compliant in order to be registered.

9. Can dealers sell non-compliant RVs to residents outside of California?
According to CARB, California RV dealers are able to sell a non-compliant motorhome to a resident of another state provided the customer intends to register the motorhome in a non-ACT state. 

10. How is the ACT regulation enforced? Is it enforced on sales or enforced on registering non-compliant motorhomes?
The ACT regulation directly regulates the companies that certify chassis meet the applicable ZEV production percentages set forth in the regulation. There is no enforcement provision for consumers or RV dealers. 

Sales and reporting requirements contained in Section 1963.4 of the regulation require chassis manufacturers to report to CARB on how they are complying with the requirements. Section 1963.5 of the regulation sets forth enforcement requirements which indicate that CARB has the authority to audit the compliance records of any manufacturer or secondar vehicle manufacturer to confirm the accuracy of their compliance reports. CARB may assess penalties for noncompliance.