On May 27, 2025, the California Air Resources Board (CARB) announced that that they will not be enforcing their planned Zero-Emission Forklift regulation that was set to be implemented on January 1, 2026.[1]
Overview of the Zero-Emission Forklift regulation
Approved in June 2024, the Zero-Emission Forklift (ZEF) regulation sought to regulate the production and sales of forklifts in the state of California as a part of CARBs Mobile Source Strategy, State Implementation Plan, and Sustainable Freight Action Plan. The regulation also included a phase out plan- referred to as the Model Year (MY) Phase-Out Schedule-to assist existing fleet operators in replacing their non-ZEF vehicles between 2028 to 2038.
CARB announced that they have not yet received approval from the United States Environmental Protection Agency to begin the enforcement of this regulation and will not do so until they receive it.
What qualifies as a Zero-Emission Forklift?
A ZEF is a forklift whose operation results in zero exhaust emissions of any criteria pollutant, precursor pollutant, or greenhouse gas, under any operating scenario. ZEFs replace the combustion powered engine with the use of fuel-cell-electric, battery-electric, or other zero-emission powertrain technology.
CARB’s ZEF regulation applies to cushion-tired forklifts of all lift capacities, as well as pneumatic-tired forklifts with lift capacities of 12,000 pounds or less that are powered by a large spark-ignited (LSI) engine. LSI engines have a power rating of 25 horsepower or greater. These forklifts are referred to as Targeted Forklifts and include those fueled by propane, natural gas, and gasoline; however, the regulation does not apply to off road or rough-terrain forklifts and fleets. CARB defines a fleet as “all applicable [targeted] forklifts that are owned or controlled by a common entity and are operated within California.”[2]
Who is impacted?
The ZEF regulation applies to manufacturers and fleet operators of LSI powered forklifts. The regulation includes production and sales restrictions on LSI powered forklifts and requires the reporting of Targeted Forklifts in California. Additionally, fleet operators, including rental companies, would be restricted from acquiring these Targeted Forklifts.
What happens now?
Until authorization, CARB will not prohibit manufacturers, dealers, or fleet operators and rental agencies from producing, offering for sale, selling, or renting LSI forklifts in California, if they meet all other federal and state regulations.
In the meantime, CARB suggests that fleet operators contact their electric utility provider, no later than March 31, 2026, to initiate discussions regarding potential electrical-service installation or necessary upgrades for facilities where Targeted Forklifts are currently operated.
Self-Reporting – Prepare for the Future
Although not required, CARB staff encourages manufacturers and fleet operators of Targeted fleets to voluntarily report until the regulation is implemented. Self-reporting would include the submittal of any reports as required by the Final Regulation Order, Title 13, Sections 3000 through 3011 of the “Zero-Emission Forklift Regulation” or “ZE Forklift Regulation.” These reports should include the following:
- General facility information
- Forklift information
- MY Phase-Out Schedule
- Initial Report to the Executive Officer
- Phase-Out Schedule selection and details
Exemptions and extensions to this regulation are also available. If you believe you might qualify for one of these, details can be found in §3007 sections (a) through (b).
Further Information
Please refer to the CARBs website for any updates on the implementation of this regulation: https://ww2.arb.ca.gov/our-work/programs/zero-emission-forklifts
Questions? We’re here to help
For support with reporting and understanding the regulation, or to discuss any questions or concerns you may have, please contact Taylor Wheelon at taylor.wheelon@ehs-support.com or Jessica Myer at jessica.myer@ehs-support.com.
[1] Appendix A-1 Final Regulation Order Zero-Emission Forklift Regulation
