In October, the recreational vehicle world was shocked by the revelation that California and other states announced incoming emissions rules that had the unintentional impact of harshly limiting the sales of large motorhomes. We’re now into 2025 when the ominous Advanced Clean Trucks (ACT) regulation is supposed to go into effect. The expected effects of the regulation are worrying manufacturers and buyers in California and 10 other states, and the heavy-vehicle industry is fighting back. But what’s going on? What does the future look like? Let’s dig into it.
When I wrote about the California Advanced Clean Trucks (ACT) regulation in November, many weren’t certain if California was going to go through with it. However, as Family RVing Magazine writes, it does appear that California is going through with this. At the very least, we now have some more clarity about what is likely to happen.
The U.S. Environmental Protection Agency has the ability to grant waivers to the state of California that allow the state to enact tougher emissions rules than exist on the federal level. As Politico writes, these waivers also give California one extra layer of tape the federal government would have to cut through to stop the state. Thus, California is rushing to get the Biden Administration to grant its waivers in the handful of days remaining before President-elect Trump takes office.
On December 18, the California Air Resources Board (CARB) announced that the U.S. EPA approved waivers for its Advanced Clean Cars II (ACCII) rule as well as the Heavy-Duty Engine and Vehicle Omnibus Regulation. These rules join forces with the Advanced Clean Trucks regulation and other regulations in an effort to phase out the sales of new internal combustion engines in everything from small lawn equipment to heavy mining rigs in California. The state also got a waiver for its zero-emissions plan for ferries while it also awaits potential approval for waivers concerning emissions-free locomotives as well as the state’s plan for zero-emissions fleets.
Advanced Clean Trucks
The Advanced Clean Trucks (ACT) regulation’s waiver was granted a couple of years ago, but now California has even more levers to pull. The Omnibus regulation, which sets stricter emissions standards for ICE engines, had its waiver granted last month. ACT, which was adopted by CARB in 2020, requires the manufacturers of trucks and motorhome chassis with a gross vehicle weight rating of over 8,500 pounds to produce a percentage of zero-emission vehicles (ZEV).
The goal is to eventually phase out the sales of new internal combustion engines. California hopes to phase out the sales of all new internal combustion cars by 2035. Medium-duty and heavy-duty trucks have a little longer, with the state hoping that all new trucks sold in the state will be zero-emission vehicles by 2045. However, in the interim years, the state will require a manufacturer to sell a percentage of ZEVs in order to be able to sell ICE vehicles in the state. According to the rule, makers of medium-duty and heavy-duty trucks were required to begin building a small percentage of ZEVs beginning in 2024 and gradually rising from there. Here’s a chart:
Here’s how the classes break down in the chart above: Class 2b-3 is for on-road trucks with a GVWR between 8,501 and 14,000 pounds. Class 4-8 is for on-road trucks with a GVWR greater than or equal to 14,001 pounds. Finally, Class 7-8 covers vehicles with a GVWR greater than or equal to 26,001 pounds.
When I covered the rules back in November, five other states had followed California’s lead. The RV Industry Association is reporting that there are now 10 states following California’s lead on ACT. Those states are: Colorado, Maryland, Massachusetts, New Jersey, New Mexico, New York, Oregon, Rhode Island, Vermont, and Washington. Of those states, Vermont is seeking to begin its implementation of ACT for the 2026 model year while Colorado, Maryland, New Mexico, and Rhode Island will be waiting for the 2027 model year.
Those states will refer to the above chart for their required ZEV percentages.
ACT Hits More Than Just RVs
According to Land Line Now, the media organization for the Owner-Operator Independent Drivers Association, ACT was met with heavy pushback. Truck dealers, drivers, and fleet owners all attempted to point out to these states that the market for zero-emission Class 7 and Class 8 is microscopic. Earlier in 2024, FreightWaves reported, 19 states petitioned the U.S. Court of Appeals for the District of Columbia to review and possibly challenge ACT.
The heat on ACT was cranked up in November when the state of Nebraska, Renewable Fuels Nebraska, and Energy Marketers of America filed a lawsuit against Daimler Truck, Navistar, Paccar, Volvo and the Truck and Engine Manufacturers Association. The suit alleges that the truck builders are colluding to force the adoption of electric trucks with the help of CARB and ACT.
On December 17, the hits to ACT kept on coming when trucking associations in Colorado, Massachusetts, New Jersey, New Mexico, New York, Oregon, Rhode Island, and Washington wrote letters to their governors pleading for their states to delay the implementation of ACT. The organizations claim that because ZEV technology just isn’t there yet to allow for the trucking industry to change over, truckers will just end up driving older trucks that pollute more. The organizations also claim that there just isn’t a good enough charging infrastructure for big trucks yet, either.
ACT has provisions to help manufacturers that either do not have ZEVs to sell or do not sell enough ZEVs to meet the required percentages. One is a sort of grace period, which we’ll get to later. The other is a credit system. Manufacturers that build ZEVs generate credits. The manufacturer can then use those credits for themselves as well as sell those credits to manufacturers that aren’t selling enough ZEVs.
The effects of ACT are already being felt in Oregon, FreightWaves reports. Daimler Truck, the parent of Freightliner, Western Star, Fuso, Thomas Built Buses, Detroit Diesel, Setra, Rizon, and more, has halted ICE sales in the state. The state claims this stems from a misunderstanding of ACT regulations on Daimler’s part, but Daimler claims that Oregon implemented ACT differently than California and that is preventing it from selling vehicles in the state. The two entities are still talking about it, but for now, Oregon-based dealers are under orders to halt new ICE sales.
The RV Industry Reacts
The RV industry is dealing with a related nightmare. RV manufacturers are considered to be secondary vehicle manufacturers. In other words, they take a base vehicle made by someone else and use that vehicle as a platform for an RV. At first, ACT didn’t really handle this, the RVIA says, which left the RV industry without answers. In October, ACT was amended and it now allows secondary vehicle manufacturers to buy credits to keep selling ICE vehicles.
The bulk of the RVs that would get caught up in the entanglement of ACT are primarily large Class A motorhomes and Super C motorhomes, the kinds of motorhomes rolling on specialized chassis. ACT’s 8,500-pound threshold does endanger far more RVs than just the biggest ones and more than just diesel engines, too. For example, the vans underneath Class B campers often have gross weight limits above that 8,500-pound limit. That includes variants of the Mercedes-Benz Sprinter, Ford Transit, and Ram ProMaster. However, the automakers that build the base vans also sell EVs, so more of them will be available compared to monster RVs.
This brings complications for the manufacturers of large motorhomes. Their coaches are built on platforms produced by heavy truck makers. There presently isn’t a single zero-emission Class A or Super C RV on the market. The market for all zero-emission motorhomes is also remarkably tiny with only startups selling small handfuls of all-electric camper vans. No big brand sells a low-emission or zero-emission motorhome of any kind, though some are in development. Likewise, these chassis manufacturers either aren’t building zero-emission trucks or aren’t building enough of them.
CARB does offer a path for builders wanting to sell large diesel-powered coaches, from SFGate:
CARB told SFGATE via email that “there is no motorhome ban.” A system of credits allows manufacturers that can’t meet the requirements to buy credits from those that do, giving them “the flexibility needed to sell as many internal combustion engines as is needed to meet market demands,” said spokesperson Lys Mendez. According to the board, manufacturers can also focus ZEV production on other vehicle types where that technology is more viable to meet the requirements.
The RV Industry Association says that chassis manufacturers also have a grace period of sorts:
Motorhomes can still be sold and registered either through utilization of the credit market or generating a carry forward deficit that will have to be offset by credits within three years.
This deficit make-up period provision 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. 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.
The RVIA also notes that the rule has no effect on model year 2024 and model year 2025 RVs that have already been built and shipped to dealers. ACT goes after new builds. Thus, if you go to a California dealership website today, you’ll find 2024 and 2025 models for sale. If you buy one of these already-delivered RVs, you should be fine registering it. Likewise, if an RV dealer does have stock that cannot be sold in California, the state does allow the dealer to sell to an out-of-state buyer. That being said, the RVIA notes that buyers in California will not be able to buy a non-compliant RV from another state and register it in the state unless it’s used with at least 7,500 miles.
To be clear here, there are so many headlines about RV and truck “bans” but that is not strictly true. Truck and RV manufacturers do have avenues to continue selling products. However, as you can tell, doing so will come with extra and potentially expensive hurdles. For some manufacturers, that might as well be the same thing as a ban.
What Happens Next
According to RV Travel, Spartan and Freightliner, two major diesel RV chassis builders, have decided to pull out of states implanting ACT. In response, Newmar RV told its dealers in those states that it would no longer be able to sell coaches that use those platforms. As of writing, you can still buy new Newmars in California. It’s unclear when buyers may begin to see the effects of ACT at dealerships. RVTravel believes RV buyers will begin seeing the effects later on in the year as stock begins drying up. However, Family RVing Magazine writes that the exact date for the enforcement of ACT has not been set yet.
Sadly, this means there are still a lot of unknowns. While the RV Industry Association admits that RV manufacturers technically do have a path forward, it expects the credits sold on the open market to be expensive. The organization also says that it has not received guidance from CARB on even if a chassis builder like Spartan can just buy credits to get around ACT.
Some manufacturers are having better luck than others. Ford, which sells a lot of EVs, will be able to sell its Godzilla V8-powered Ford F53 Class A motorhome chassis in these states.
In the eyes of the RVIA, CARB is not giving RV manufacturers enough options. As I said before, there are no ZEV RV chassis currently available for RV companies to build on. Thor and Harbinger are working on low-emission and zero-emission RVs, but those are not near-term solutions. Thus, for the foreseeable future, the only real option for a large RV manufacturer would be to buy credits or leave the market in up to 11 states.
Next week, I will be at the Florida RV SuperShow, where I hope to ask RV company representatives how their manufacturers plan to move forward in these states. But until we have more answers, it appears the RV industry is hoping the trucking industry’s various lawsuits and calls to delay regulation will be successful. If you’re looking to buy a large RV in one of these states, the guidance appears to be to buy one now while the model you want is still on the market.
I’d like to see a story about the depreciation of these monster RV’s. It has to be one of the worst financial decisions anyone can make, right up there with buying a Cybertruck. People buy both for the same reason.
Out of curiosity, what states see the highest number of RV sales? I could see CA being both a huge market (lots of people with obscene amounts of disposable income) and also a very small market (those people tend to live in cities and thus have nowhere to store one).
Obscene amounts of disposable income corrects the problem of not having a place to store it. At least around west Michigan, out of state vacationer RVs tend to be stored where they’re maintained, so the owner can fly in and go where they want with the turn of a key.
It’s interesting to come to this enthusiast site and read all the comments from people who are happy that others may have difficulty buying the vehicle they want.
Regulate me harder daddy. So unamerican
Autopian has a heavy bend towards urban living, and many things go alone with that.
Something not brought up yet: these rules for Semi Trucks is asinine and will cause a dramatic increase in the price of goods.
It is too bad Edison Motors isn’t further along in going to production, since their battery vehicle with on board generator design is perfect for RVs.
They claim that since the generator isn’t directly power the wheels, they can use red diesel. Similar hand waiving can probably get an Edison’d RV through CARB/ACT compliance.
I’ve got a Lladro my mom gave me, and some leaded crystal my mother in law gave us to throw in with that giant motorhome.
California needs to fall into the ocean.
Surely the answer is to build your own. Never quite understood the attraction of living with other people’s design ideas.