In June 2024, the California Air Resources Board (CARB) adopted the Zero-Emission Forklift (ZEF) Regulation, a landmark rule designed to phase out polluting large spark-ignition (LSI) forklifts across the state. The regulation officially took effect on January 1, 2025, with the first major compliance deadlines beginning in 2026. This guide provides a comprehensive overview of the regulation, its requirements, timelines, and what it means for fleet operators, dealers, and manufacturers in California.
What Is the ZEF Regulation?
The ZEF Regulation aims to reduce emissions of nitrogen oxides (NOx), particulate matter (PM), and greenhouse gases (GHG) from LSI forklifts—those powered by propane, natural gas, or gasoline. At the time of adoption, approximately 100,000 LSI forklifts were operating in California. The regulation targets these emissions by restricting the sale of new LSI forklifts and requiring the gradual phase-out of existing ones between 2028 and 2038.
Which Forklifts Are Covered?
The regulation applies to:
Class IV cushion-tired forklifts of all lift capacities
Class V pneumatic-tired forklifts with a rated capacity of 12,000 pounds or less
Exemptions include:
Rough-terrain forklifts
In-field forklifts
Low-use and dedicated emergency use forklifts
Key Requirements and Deadlines
January 1, 2026 – Sales and Acquisition Restrictions
Manufacturers cannot produce or offer for sale in California a Class IV LSI forklift unless the engine or powertrain qualifies as Zero-Emission.
Fleet operators are restricted from acquiring or taking possession of LSI forklifts at any location in California.
Dealers cannot sell, lease, or deliver LSI forklifts to fleet operators in California.
March 31, 2026 – Utility Notification
Fleet operators must contact their electric utility provider to initiate discussions regarding potential electrical service installation or necessary upgrades for facilities where LSI forklifts are operated.
2028–2038 – Phase-Out Schedule
Fleet operators are required to phase out existing LSI forklifts by model year, addressing the oldest equipment first. The phase-out schedule differs based on fleet size and forklift class.
Fleet Sizing Definitions:
Large Fleet: 26 or more LSI forklifts + ZEFs
Small Fleet: 25 or fewer LSI forklifts + ZEFs
Phase-Out Schedule (Model Years):
Compliance Date Class IV (All Fleets) Class IV (Small/Crop Fleets)* Class V (All Fleets)
Jan 1, 2028 ≤ 2018 MY (cap: 50% large / 25% small) – –
Jan 1, 2029 – – ≤ 2016 MY (cap: 25%)
Jan 1, 2030 – – ≤ 2017 MY (cap: 50% large / 25% small)
Jan 1, 2031 2019 – 2021 MY – –
Jan 1, 2032 – – 2017 – 2019 MY
Jan 1, 2033 2022 – 2023 MY – 2018 – 2020 MY
Jan 1, 2034 – – 2020 – 2021 MY
Jan 1, 2035 2024 – 2025 MY ≤ 2025 MY 2021 – 2022 MY
Jan 1, 2036 – – 2022 – 2023 MY
Jan 1, 2037 – – 2018 – 2020 MY
Jan 1, 2038 – 2024 – 2025 MY 2023 – 2028 MY
*Alternative schedule available for small fleets and agricultural crop preparation service fleets.
Phase-Out Caps – To reduce burden, the required turnover for the first compliance date is capped at no more than 50% for large fleets and 25% for small fleets and agricultural crop preparation services.
Recordkeeping and Reporting
Starting January 1, 2026, all regulated entities must:
Maintain records for all LSI forklifts within their fleet in California
Ensure manufacturer labels for the forklift engine and forklift are intact and readable at all times
Submit annual reports via CARB's DOORS reporting system or email to zeforklifts@arb.ca.gov
Reporting Deadlines:
April 30, 2026: Initial report for large fleets due
September 30, 2026: Initial report for small fleets due
Annually thereafter: April 30 for large fleets, September 30 for small fleets
Extensions and Exemptions
The regulation provides extensions for delays outside the fleet operator's control, including:
Delays in delivery of zero-emission forklifts
Delays in installation of charging/fueling infrastructure
No commercially available ZEF model that meets operational needs
Exemptions are available for:
Low-use forklifts
Dedicated emergency use forklifts
In-field forklifts
Current Enforcement Status
As of the latest update, CARB has not yet sought authorization from the U.S. Environmental Protection Agency (EPA) for the ZEF Regulation pursuant to Section 209(e)(2)(A) of the Clean Air Act. Until U.S. EPA grants such authorization or determines authorization is not necessary, CARB staff will not enforce the ZEF Regulation against any privately-owned or operated fleets.
However, CARB encourages affected industries to voluntarily reduce emissions and comply with the regulation. The regulation does apply to state and local government agencies.
Incentive Programs
Funding is available to help offset the cost of transitioning to zero-emission forklifts:
Carl Moyer Memorial Air Quality Standards Attainment Program
FARMER Program
Clean Off-Road Equipment Voucher Incentive Project (CORE) – approximately 90 models/configurations of zero-emission forklifts with a rated capacity over 12,000 pounds are eligible
What This Means for Your Business
For Fleet Operators – As of January 1, 2026, you cannot acquire new LSI forklifts. You must begin planning for electrification, including utility discussions and infrastructure upgrades. The phase-out schedule gives you a clear timeline for replacing existing equipment.
For Dealers – You cannot sell or lease new LSI forklifts in California as of 2026. Your inventory and sales strategy must shift to zero-emission models.
For Manufacturers – Production and sales of Class IV LSI forklifts for California are restricted starting 2026, with Class V restrictions beginning 2029.
Next Steps
Assess your fleet – Determine how many LSI forklifts you operate and their model years
Contact your utility provider – By March 31, 2026, to discuss electrical upgrades
Explore zero-emission options – Battery-electric and fuel-cell forklifts are commercially available and have been successfully used for decades
Apply for incentives – Explore funding through CORE, Carl Moyer, and FARMER programs
Stay informed – Monitor CARB's ZEF webpage for updates on enforcement and reporting tools