Policy Overview

The Advanced Clean Trucks (ACT) policy is a state-level regulation that requires manufacturers to sell increasing percentages of zero emission vehicles (ZEVs) each year, requiring sales of 7% zero-emission vehicles for the largest trucks (class 7-8) in 2025, ending at 40% in 2035. California is the only state allowed to design its own emissions standards that are stricter than federal ones, but as per Section 177 of the Clean Air Act, other states are allowed to follow suit and adopt regulations California has crafted. These states are commonly referred to as Section 177 states.

The California Air Resources Board (CARB), and other state agencies that have enacted the ACT regulation, require a waiver of preemption from the Environmental Protection Agency (EPA) in order to enforce the policy. EPA granted a waiver of preemption for the ACT regulation in March 2023, and this has enabled other US states to adopt and enforce the regulation. To date, the ACT regulation has been adopted by California, Colorado, Maryland, Massachusetts, Rhode Island, Vermont, and Washington.

In an agreement known as the Clean Trucks Partnership, many major manufacturers agreed to meet the targets of the Advanced Clean Trucks rule in California regardless of any attempts by other entities to challenge California’s authority.

Policy Status

As of June 2025, the waiver of preemption required for the California and other US states to enforce Advanced Clean Trucks rule has been revoked by the federal government, which should prevent US states from enforcing the rule. The US Congress and EPA utilized the Congressional Review Act (CRA) to revoke the waiver, ignoring warnings from the Government Accountability Office that the EPA’s waiver of preemption for the rule was not subject to the Congressional Review Act.

After an investigation from the Federal Trade Commission, Daimler, PACCAR, Volvo Group, Volkswagen, and the Truck and Engine Manufacturers Association stated that the Clean Trucks Partnership was “rendered unenforceable.”

Policy Status

Federal Approval Repealed

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Policy Engagement Overview

Major Truck Manufacturers Oppose Clean Trucks Partnership

After the federal government revoked US states authority to enforce the Advanced Clean Trucks rule, Daimler Truck, PACCAR, Volvo Group, and Volkswagen subsidiary International Motors filed a lawsuit against California in August 2025, seeking to void the Clean Trucks Partnership. The Clean Trucks Partnership is an agreement truckmakers voluntarily reached with California regulators, in which they stated they would meet the targets of the Advanced Clean Trucks rule. The manufacturers claimed in their lawsuit that the Advanced Clean Trucks rule was unlawful, given the recent federal decision to revoke the waiver for the rule. On August 14, the US Department of Justice joined the manufacturers in their lawsuit against California and the Advanced Clean Trucks rule.

Furthermore, after an investigation from the Federal Trade Commission, Daimler, PACCAR, Volvo Group, Volkswagen, and the Truck and Engine Manufacturers Association declared that the agreement was “rendered unenforceable” following the repeal of federal waivers of preemption for the rule.

Congressional Review Act Challenges Against Advanced Clean Trucks (ACT) Rule

This legislation is coupled with the Advanced Clean Cars II rule

  • Oil and gas industry associations support rollback of ACT via CRA. The American Petroleum Institute, which represents major petrochemical companies such as Chevron, Enbridge, Shell, Sempra, and Phillips 66, supported the ACT rollback in a June 2025 statement, claiming that overturning the rule would support consumer choice. The Consumer Energy Alliance, which represents companies such as Chevron, Enbridge, Marathon Petroleum, and others, applauded the rollback of the ACT after the CRA passed the House of Representatives in a May 2025 statement and after its finalization in a June 2025 statement.

  • Utilities and EV manufacturers opposed the rollback of the ACT. The Zero Emission Transportation Association, an industry association representing electric utilities such as Consolidated Edison, Duke Energy, PG&E, and EV manufacturers such as Tesla and Rivian, strongly opposed repealing the rule in a June 2025 statement.

  • Cross-sector Industry Associations support the rollback of ACT. The US Chamber of Commerce supported the CRA in May 2025 letter to the US Senate, urging the government to pass the CRA and roll back the ACT. The National Association of Manufacturers supported the rollback in a May 2025 statement.

  • The Transport Project applauded the rollback of the ACT. The Transport Project represents companies such as Volvo Group, Amazon, Shell, Chevron, and Frito-Lay, and has consistently advocated against the Advanced Clean Trucks rule.

Advocacy on the Transportation Freedom Act

The automobile industry has largely supported the Transportation Freedom Act, which would stop enforcement of Advanced Clean Trucks in all participating states. General Motors, Stellantis, and Toyota Motor all supported the Transportation Freedom Act in March 2025 statements issued on US Senator Moreno’s website. The CEO of the Alliance for Automotive Innovation, John Bozzella, also supported the bill in statements on the same press release.

Waiver Comment Period

In a November 2024 letter to Mr. Trump, the Alliance for Automotive Innovation described California’s emissions regulations as a headwind to auto manufacturers, stating that they were “out-of-step with current auto market realities and increase costs for consumers.” The incoming Trump administration is expected to attempt to remove the waiver of preemption for the Advanced Clean Truck waiver. The Alliance for Automotive Innovation represents most major auto manufacturers, including Ford, General Motors, Toyota, and Stellantis, and others.

A wide range of businesses expressed support for the Advanced Clean Trucks rule. In an October 2023 letter to all state governors considering adoption of the rule, IKEA, Siemens, National Grid, Nestlé, Unilever, the Zero Emission Transportation Association, and a number of other companies supported the adoption of the Advanced Clean Trucks rule across the US.

The US Chamber of Commerce opposed the ACT regulation in a November 2023 lawsuit which opposed the EPA’s decision to grant CARB a waiver of preemption. The Chamber joined the Western States Petroleum Association in seeking to prevent the ACT rule from being enforced.

Clean Trucks Partnership

In July 2023, 10 major truck and auto manufacturers entered the Clean Trucks Partnership with California regulators. The signatories agreed to comply with the Advanced Clean Truck rule in California regardless of the outcome of any litigation challenging the waiver/authorizations for the ACT rule. The participating manufacturers are Cummins Inc, Daimler Truck North America, General Motors Company, Hino Motors, Ford Motor, Volkswagen subsidiary Navistar, PACCAR, Stellantis, Volvo Group, and the Truck and Engine Manufacturers Association (EMA).

In the agreement, EMA and the engine manufacturers agreed to remain neutral in response to the adoption of the Advanced Clean Trucks rule in any Section 177 states, with the exception that EMA and engine manufacturers are permitted to provide comments expressing concerns with implementation, or with a lack of complementary policies. The EMA has appeared to utilize this exemption to strongly emphasize concerns with the implementation of the Advanced Clean Trucks rule in Illinois, In the association’s October 2024 comments on Illinois’ adoption of ACT, the EMA appeared to suggest that the ACT rule would have issues related to “efficacy” due to the existing federal GHG rules for trucks, potentially implying that the ACT rule is redundant. However, federal GHG rules do not mandate any zero-emission vehicles to be sold and are technology neutral, and the EPA has outlined possible pathways the rule can be complied with without the use of any battery-electric or fuel-cell vehicles. CARB’s Advanced Clean Trucks rule however, requires the sale of zero emission vehicles, requiring that by 2035, zero-emission truck/chassis sales would need to be 55% of Class 2b – 3 truck sales, 75% of Class 4 – 8 straight truck sales, and 40% of truck tractor sales. In August 2023, the EMA made similar comments in New Mexico, Rhode Island, Maine, and Connecticut, but these comments focused on advocating for a change to the regulation that would introduce more flexibilities to the crediting program.

Policy Status

Federal Approval Repealed

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Live Lobbying Alerts

Auto industry supports aggressive regulatory rollbacks in the US

06/03/2025

General Motors, Stellantis, Toyota, and the CEO of Alliance for Automotive Innovation issued statements on 1 March supporting the Transportation Freedom Act. The bill would repeal existing emissions standards for light-, medium-, and heavy-duty transport in the US, and also remove California and other states' authority to enforce zero-emission vehicle sales targets.

Specifically, Title II of the Transportation Freedom Act would repeal existing light- and medium duty GHG emissions standards for passenger cars and trucks MY2027+, phase 3 GHG emissions standards for heavy-duty motor vehicles MY2030+, and corporate average fuel economy standards for passenger cars and light trucks MY2027+ and heavy duty trucks MY2030-2035. New, less stringent GHG emissions standards would be drafted by the current EPA. Title III would remove the waivers granted to California to enforce its own emissions standards and zero-emission vehicle sales targets, and also repeal Section 177 of the Clean Air Act, which enables other US states to follow California's emissions standards. These actions would prevent California and all other participating US states from enforcing the Advanced Clean Trucks rule, Advanced Clean Cars II rule, Advanced Clean Fleet rule, and other California-led policies.

Entities Engaged on Policy

Influencemap Performance BandOrganizationPolicy PositionPolicy Engagement Intensity