ACT / ACF

What ACT and ACF require

Advanced Clean Trucks (ACT), adopted by CARB in 2020, is a manufacturer sales mandate: makers certifying Class 2b-8 combustion trucks must sell zero-emission trucks as a rising share of annual California sales, MY2024-2035, reaching 55% (Class 2b-3), 75% (Class 4-8 rigid), and 40% (Class 7-8 tractors) by MY2035. EPA granted the ACT waiver in spring 2023. Several Section 177 states adopted it.

Advanced Clean Fleets (ACF), adopted 2023, is a fleet-purchase mandate covering drayage trucks, high-priority and federal fleets, and state and local government fleets (50% of purchases ZEV in 2025-2026, 100% from 2027), targeting a 100% ZEV medium-/heavy-duty fleet by 2045 where feasible.

What changed in 2025-2026

Both regulations lost their federal footing:

• ACF: On January 13, 2025 CARB withdrew its pending EPA Clean Air Act waiver requests, including ACF, citing the incoming administration. The waiver-dependent portions (drayage, high-priority/federal fleets) cannot be enforced, and CARB moved to repeal them. CARB asserts the state and local government fleet purchase rules need no waiver and remain in effect.
• ACT: On June 12, 2025 the President signed H.J.Res.87 (Public Law 119-15), a Congressional Review Act resolution nullifying the EPA ACT waiver ("no force or effect"). Without the waiver, ACT is preempted and unenforceable; the CRA also bars EPA from reissuing a substantially similar waiver. Companion resolutions hit ACC II (PL 119-16) and the Omnibus Low-NOx rule (PL 119-17) the same day.
• The 2023 Clean Truck Partnership (in which OEMs had pledged to comply regardless of waivers) was neutralized: the FTC closed its antitrust probe on August 12, 2025 after manufacturers disavowed enforcement, and on October 31, 2025 a federal court enjoined CARB from enforcing the Clean Truck Partnership against OEMs. That order left ACT and ACF themselves intact; their unenforceability flows from the nullified waiver, not the injunction.

Hiring relevance

With both rules unenforceable, ZEV-truck production planning and fleet-electrification compliance roles tied to California's medium-/heavy-duty market lose their regulatory anchor. Activity shifts to litigation, the ACF repeal proceeding, and the narrower public-fleet purchase rules CARB still asserts.