Phasing Out LSI Forklifts Starting in January 2026 for Owner & Operators
California Air Resources Board (CARB) is in the final stages of adopting the Zero-Emission Forklift regulation, with a final decision date of September 16, 2024. The Zero-Emission Forklift (ZEF) regulation applies to any company that operates, allows the operation of, owns, leases, rents, offers for sale, offers for lease, or offers for rent one or more large spark-ignition (LSI) Forklifts within California, including forklift and engine manufacturers. This article focuses on owner and operators of LSI forklifts.
This regulation aims to reduce emissions of NOx, PM, and GHG emissions from LSI forklifts and will go into effect starting January 1, 2026.
Compliance Requirements
Starting January 1, 2026, facilities shall not acquire, possess, or operate an LSI forklift in California unless the forklift is a used 2025 or previous model year LSI forklift that hasn’t been phased out yet according to the phase-out schedule.
Phase-Out Requirements and Schedules
By March 31, 2026, fleet operators are required to contact their electricity providers to initiate discussion regarding potential electrical installation or upgrades for each location with LSI forklifts subject to phase-out requirements. When contacting electricity providers, fleet operators will report the site address and estimated number and types of chargers that will be required to comply with the phase-out requirements as well as other power information.
Important Clarifications
The phase-out schedules differ based on the number of forklifts the entity owns, class of forklifts, and the forklift capacity.
- Fleet Sizing:
- Large Fleet: ≥26 LSI forklifts + ZEFs
- Small Fleet: ≤25 LSI forklifts + ZEFs
- Classes of LSI Forklifts:
- Class IV: Not designed to be operated with pneumatic tires.
- Class V: Designed to be operated with pneumatic tires.
- Capacity:
- High Capacity: Rated capacity >12,000 lbs
- Low Capacity: ≤12,000 lbs
The phase-out schedules are shown in Table 1 below.
Table 1. Phase-out Schedule Relating to Specific Model Years (MY)
| Compliance Deadline | Class IV | Class V |
| All Fleets | Alternate for Small / Crop Preparation Services Fleets | All Fleets |
| Low Capacity | High Capacity | Low Capacity | High Capacity | Low Capacity2 |
| 1/1/2028 | ≤ 2018 MY (25% for Small Fleet, 50% for Large Fleets)1 | – | – | – | – |
| 1/1/2029 | – | – | ≤ 2016 MY (25%)1 | – | – |
| 1/1/2030 | – | – | – | – | ≤ 2017 MY (25% for Small Fleet, 50% for Large Fleets)1 |
| 1/1/2031 | 2019 – 2021 MY | – | – | – | – |
| 1/1/2032 | – | – | 2017 – 2019 MY | – | – |
| 1/1/2033 | 2022 – 2023 MY | – | – | – | 2018 – 2020 MY |
| 1/1/2034 | – | – | 2020 – 2021 MY | – | – |
| 1/1/2035 | 2024 – 2025 MY | ≤ 2025 MY | – | – | 2021 – 2022 MY |
| 1/1/2036 | – | – | 2022 – 2023 MY | – | – |
| 1/1/2037 | – | – | – | – | 2018 – 2020 MY |
| 1/1/2038 | – | – | 2024 – 2025 MY | ≤ 2025 MY | 2023 – 2028 MY |
| 1Phase-out percentage cap may be applied. |
| 2High capacity forklifts are not required to be phased out as long as an annual report is submitted. |
For the compliance dates and model years indicated in the table above, a phase-out percentage cap may be applied. Forklifts will be phased out in the order of oldest to newest based on model year (MY). Fleet operators are not required to phase out any additional applicable LSI forklifts by the compliance date once the cap has been reached. All applicable LSI forklifts not phased out due to the percentage cap must be phased out by the next compliance date.
To calculate the number of LSI forklifts the fleet operator must phase out on a compliance date, the fleet operator should multiply the percentage cap as a decimal by total number of Class IV or Class V forklifts within the fleet as of January 1, 2026. The percentage of phased-out LSI forklifts should be rounded up to the nearest whole number.
Labeling Requirements
Fleet operators are required to permanently label forklifts visibly with at least one EIN label within 30 days of receiving it from CARB. They are also required to maintain records of forklift purchase dates for forklifts that have not been labeled yet.
Reporting Requirements
All reports and documentation will be submitted to CARB via a CARB reporting system or by email to [email protected].
| Report | Fleet Size | Due Date |
| Initial Report | | April 30, 2026 |
| Annual Report | Large | April 30th, Annually |
| Final Report | | April 30, 2035 |
| Initial Report | Small / Crop | September 30, 2026 |
| Annual Report | Preparation | September 30th, Annually |
| Final Report | Services | September 30 of Final Compliance Year |
Initial Report
The Initial Report must include the following information:
- Entity Information.
- Total number of Class IV LSI forklifts within the fleet on January 1, 2026, not including exempt forklifts.
- Total number of Class V LSI forklifts within the fleet on January 1, 2026, not including exempt forklifts.
- A copy of the information provided to the electric utility provider and confirmation that the information was received by the electric utility provider.
- If applicable, the date in which existing panel capacity is expected to be insufficient for charging ZEFs
- For small fleets, if the operator decides to use the alternative phase-out schedule for small fleets, for each LSI forklift and ZEF within the fleet, the initial report must include:
- Forklift information
- Primary operating address.
Annual Report
Annual Reports must include the following information:
- Updates to any entity or forklift number information.
- Information on whether panel capacity is sufficient for ZEFs
- If applicable, the date in which existing panel capacity is expected to be insufficient for charging ZEFs
- For small fleets, if the fleet operator decides to use the alternative phase-out schedule, the annual report must include:
- Forklift information
- Date the forklift entered the fleet
- Primary operating address for each LSI forklift
- ZEF added the previous calendar year
- EIN and date the forklift was removed from the fleet for each LSI forklift and ZEF removed from the fleet in the previous calendar year.
Final Reports
For each class of forklift (Class IV and/or Class V), a final report should be submitted, which contains confirmation that the operator has completed its phase-out of the respective classes’ forklifts.
Exemptions
The ZE forklift regulation includes exemptions for the following:
- Low-Use LSI Forklifts: <200 hours/calendar year
- Exempt from the previous requirements, but they shall not be operated beyond December 31, 2030.
- The reporting requirements still apply.
- Monitored through a non-resettable hour meter.
- Emergency Forklifts
- Temporary Storage and Transfer of Non-Compliant LSI Forklifts
- In-Field Forklift
Extensions
Fleet Operators may request extensions to the compliance dates due to the following reasons:
- Zero-Emission Forklift Deliver Delay – the operator has already ordered ZEFs to replace LSI forklifts but cannot be delivered by the upcoming compliance date.
- Infrastructure Delay – Delays beyond operator control due to ZEF-related charging and infrastructure.
- Infrastructure Site Electrification Delay – Operators’ utility providers determine they cannot provide the requested power by the upcoming compliance date.
- Operational Delay – No commercially available ZEF models that meet the needs of the fleet operators by the upcoming compliance date.
Additional Information
Additional information can be found on the CARB website. More detailed information on the Zero-Emissions Forklift Regulation can be found in the Final Regulation Order.
If you have any questions regarding the regulation and maintaining compliance for your facility, please email Tiffany Wang, or Trinity’s Irvine office.
