EPA GHG Rescission: What It Means for Your Fleet

The EPA repealed two things:

• The 2009 Endangerment Finding — the legal determination that greenhouse gas emissions from motor vehicles threaten public health. This finding was the legal foundation for every federal GHG vehicle rule issued since 2009.
• All federal GHG emission standards for new light-duty, medium-duty, and heavy-duty vehicles and engines, covering model years 2012 and beyond.

The six greenhouse gases covered: carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF₆).

The rule takes effect 60 days after it is published in the Federal Register. It can be found at EPA's Final Rule Website and Regulations.gov Docket EPA-HQ-OAR-2025-0194.

That same 60-day window is when legal challenges must be filed — typically in the U.S. Court of Appeals for the D.C. Circuit. The rule could be stayed or overturned during litigation, so some uncertainty remains. See Section 9 for what that means for your planning.

No — your existing trucks are not affected. The rescission does not require any modification, recall, or retrofit of vehicles already on the road. Specifically:

• Trucks built through 2024: No impact. The emission systems on those vehicles are unchanged.
• 2025–2026 model year trucks: No practical impact on you as an operator. Any remaining compliance obligations fall on manufacturers, not buyers.
• 2027+ model year trucks: These will no longer be required to meet federal GHG targets — but will still need to meet air-quality and fuel economy standards (see section below). International S13 Integrated Powertrain is already on the path to EPA 2027 compliance, without adding unnecessary complexity.

Several important standards remain fully in effect and are not changed by this rescission:

• NOx and particulate matter (PM) standards — The rules that limit smog-forming and soot emissions from diesel engines remain in place. Your trucks must still meet these.
• Fuel economy standards (CAFE) — The National Highway Traffic Safety Administration (NHTSA) administers fuel economy standards for commercial trucks. These are separate from GHG rules and continue unchanged.
• Fuel economy labels — New vehicles must still carry fuel economy labels required under the CAFE program.
• California and CARB-state standards — If you operate or register vehicles in California or states that follow California's rules, those states' GHG and emission standards remain fully in effect. See Section 5.

The EPA issued three major rounds of GHG standards for heavy-duty trucks over the past 15 years. All are now repealed:

• 2011 Phase 1 Rule — Applied to MY 2014–2018 trucks and engines; set initial CO₂-per-mile reduction targets for tractors, vocational trucks, and trailers.
• 2016 Phase 2 Rule — Extended requirements through MY 2027 with progressively stricter CO₂ targets and efficiency improvements for tractor-trailer combinations.
• 2024 Rule (Most Recent — Now Repealed) — Covered MY 2027 and beyond; included aggressive targets that effectively pushed manufacturers toward electric and alternative-fuel powertrains.

With these rules gone, manufacturers face no federal obligation to reduce CO₂ per mile on new heavy-duty trucks starting with the 2027 model year.

No. Nothing about this rule requires fleet operators to modify, upgrade, or retrofit trucks already in service. Specifically:

• Your existing emissions control systems (DPFs, DEF systems, EGR systems) remain required and must stay operational — they meet air-quality standards that are still in force.
• If you operate electric trucks, nothing changes about how you operate or maintain them.
• Emissions test requirements (for state inspections or CDL compliance) are set by state law, not federal GHG standards, and those continue independently.

Yes — though product offerings may shift over time. International® has made no mention of changes to the International eMV. Manufacturers have strong commercial reasons to continue clean-technology development:

• State requirements: California and more than a dozen other states retain their own GHG and zero-emission vehicle standards. Manufacturers serving those markets must still comply.
• International markets: Most major export markets (Europe, Canada, etc.) maintain or are strengthening GHG standards.
• Customer demand: Many fleet operators — especially those with sustainability commitments or fuel-cost-sensitive operations — continue to prefer efficient and electric options.
• Sunk investment: Manufacturers have already spent billions developing electric and low-emission truck platforms and won't abandon that investment overnight.

What may shift: manufacturers could slow EV development for markets with no state-level mandates, and conventional diesel options may become more competitive in the near term.

Modestly, and in both directions:

• Possible downward pressure: Manufacturers can reduce R&D spending on GHG compliance technology, and some of that savings may be passed to buyers over time. A wider range of powertrain options (diesel, gas, electric) could also increase competition.
• Possible upward pressure: Legal uncertainty may delay new model introductions. Supply-chain adjustments as manufacturers recalibrate product plans could cause short-term disruptions. Tariffs on imported vehicles (unrelated to this rule) may also affect pricing.

The bigger picture: Material costs, steel prices, labor, and freight demand historically drive truck prices far more than regulatory compliance. Don't expect dramatic price swings (positive or negative) solely because of this rule.

Potentially, though the effects will likely be modest:

• Diesel trucks: Residual values may be supported if diesel becomes the de facto powertrain choice for non-regulated markets.
• Used electric trucks: May face pricing volatility if federal EV incentives shrink and charging infrastructure expansion slows in non-CARB states.
• General market: Fuel prices, interest rates, freight demand, and driver availability will continue to be the dominant drivers of used truck values — not GHG policy.

Medium-duty (MD) trucks are vehicles with a Gross Vehicle Weight Rating (GVWR) between 10,001 and 33,000 lbs — commonly referred to as Class 4 through Class 6. Examples include:

• Box trucks and step vans used for local and last-mile delivery
• Flatbed and utility trucks in the Class 4–6 range
• Shuttle buses and passenger transport vehicles
• Vocational trucks such as smaller dump trucks, concrete mixers, and service bodies

The medium-duty/heavy-duty boundary is determined by GVWR, not engine displacement or payload capacity.

Two major sets of medium-duty GHG rules are now gone:

• 2012 Rule — Covered MD vehicles in MY 2017–2025; set CO₂ reduction targets aligned with light-duty standards.
• 2024 Rule — Covered MY 2027+; combined GHG and criteria pollutant requirements; included aggressive electrification targets that would have required a growing percentage of zero-emission MD vehicle sales.

With both rules repealed, manufacturers of Class 4–6 trucks face no federal GHG obligation for future model years. State rules — especially California's — may still apply depending on where the vehicles are sold and registered.

Yes, with no restrictions. Trucks already manufactured under the prior GHG standards can be:

• Purchased, registered, and operated anywhere in the country (subject to state registration rules)
• Evaluated and marketed based on their fuel efficiency and real-world operating costs
• Serviced and maintained the same as any other vehicle

The repeal does not require any retrofit, recall, or modification of previously built vehicles. A truck built to a stricter standard is simply a more efficient vehicle — that's a feature, not a liability.

Yes, if you operate in certain states. Several states maintain their own vehicle emission standards that are independent of federal rules:

• California: California's Air Resources Board (CARB) has its own MD GHG and zero-emission vehicle rules. If you register or operate vehicles in California, those requirements still apply.
• States following California's standards: Connecticut, Delaware, Maine, Maryland, Massachusetts, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, and Washington have adopted or may adopt California's vehicle rules.

Not immediately — and potentially more options over time:

• All trucks currently in production and inventory remain available to purchase. Nothing about this rule removes any vehicle from the market.
• Over the next few model years, manufacturers may reintroduce or expand diesel and natural gas options that had been deprioritized under prior GHG mandates.
• Electric trucks will remain available, especially for California-market and fleet customers with sustainability requirements.
• The range of powertrain choices — diesel, natural gas, electric, hybrid — will likely broaden rather than narrow.

The practical effect for buyers: more flexibility, not less. You won't be forced toward a particular powertrain by federal mandate. Your decision can be driven entirely by operating costs, application, and route profile.

Probably not — but it depends on your situation:

• If you need trucks now: Buy based on your current operational needs and total cost of ownership. The trucks available today are the same trucks that will be available in 6–12 months.
• If you're planning a large fleet refresh: It's reasonable to monitor legal developments in the coming months. Each business is unique and has specific business needs. Contact us to talk to a knowledgeable sales expert about your options before committing to a particular powertrain strategy — especially for 2027+ model year orders where manufacturer specifications may change.
• If you operate in California or CARB states: State-level rules are unchanged. Your purchasing criteria remain the same as before this federal rescission.

For trucks already in inventory or in current production, GHG compliance costs are already factored into the price — they're a sunk cost in the manufacturer's development and production cycle. You're not paying a separate "GHG fee."

Going forward:

• Manufacturers may change prices modestly on future model years as GHG R&D costs are eliminated.
• Some truck models designed specifically to hit aggressive 2027+ GHG targets may be revised, discontinued, or repriced.
• Electric and hybrid trucks — which carry a price premium partly driven by regulatory compliance investment — may see that premium compress over time if federal mandates are gone.

For ongoing fleet costs: fuel, maintenance, tires, driver wages, and financing rates will always dwarf any regulatory cost component. Focus on total cost of ownership.

No. California's emission rules are completely separate from federal EPA standards:

• Under Clean Air Act section 209(b), California has the authority to set its own emission standards — independent of what EPA does at the federal level.
• California's Heavy-Duty Engine and Vehicle GHG standards remain in full effect.
• California's standards are more stringent than the federal standards that were just repealed.

If you operate or register trucks in California, your GHG obligations are unchanged by this federal action.

California maintains several active heavy-duty vehicle rules:

• California Low NOx Standard — Applies to heavy-duty engines and vehicles; limits nitrogen oxide emissions; fully independent of federal GHG standards and unaffected by this rescission.
• California GHG Standards — CARB's own CO₂ standards for heavy-duty vehicles; still apply to vehicles sold or registered in California.
• Advanced Clean Trucks (ACT) Rule — California's zero-emission vehicle sales mandate for heavy-duty trucks; requires a growing percentage of manufacturers' truck sales to be zero-emission; under ongoing development and regulatory review but not affected by federal rescission.
• Truck and Bus Regulation — Requires older diesel trucks operating in California to meet current emission standards or be replaced; still in effect.

Your compliance obligations depend on where your trucks operate and are registered:

• Operating in California: You must comply with California's emission standards — including GHG and NOx rules. The federal rescission does not change this. Work with your fleet manager or compliance team to confirm your trucks meet California's requirements.
• Operating in CARB-aligned states: The following states have adopted or are in the process of adopting California's standards: Connecticut, Delaware, Maine, Maryland, Massachusetts, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, and Washington. Confirm current status with each state's environmental agency.
• Operating only in non-CARB states: You have full flexibility post-rescission. Choose powertrains based on your operational and economic needs.

Yes — significantly stricter in several respects:

• California sets more aggressive CO₂ reduction targets for heavy-duty vehicles than the federal standards that were just repealed.
• California's Advanced Clean Trucks rule would require a fixed percentage of zero-emission truck sales by specific dates — essentially a sales mandate. The federal rule that was repealed set reduction targets but did not mandate a specific percentage of electric sales.

For fleet operators: if you buy trucks in California or operate there regularly, expect to continue adapting to California's evolving standards — including potential future requirements for zero-emission vehicles on certain routes or in certain years.

Yes. States can act through two pathways:

• Adopt California's standards: Any state can choose to follow California's vehicle rules under Clean Air Act section 209(b). Many already have. This includes any future California GHG or ZEV truck rules.
• Pass their own legislation: States can also enact independent emission programs for criteria pollutants or other air quality goals, though federal preemption rules limit how far they can go with GHG-specific mandates outside of California's framework.

Unlikely, but product lineups will likely shift depending on market and geography:

• Electric trucks will remain available — especially for California-market buyers, fleet operators with sustainability targets, urban delivery applications, and international markets where GHG rules remain in force.
• Diesel and natural gas options may expand — manufacturers serving non-regulated markets may invest more in conventional powertrains now that federal GHG mandates are gone.
• Charging infrastructure growth may slow in regions without state-level EV mandates, which could affect range and operational feasibility for electric trucks over long haul routes.

For most fleet operators, this means more choices — not fewer. The key question shifts from "what am I required to buy?" to "what makes the most financial sense for my routes and operations?"

Not necessarily. The economics of electric trucks don't change just because the federal mandate disappears:

• Advantages that remain: Lower energy cost per mile (electricity vs. diesel); significantly lower maintenance costs (fewer moving parts, no oil or DEF); quiet operation preferred for urban and overnight delivery; potential state and local incentive programs still in place.
• Challenges to watch: Higher upfront acquisition cost vs. diesel; range limitations for long-haul applications; residual value uncertainty if charging infrastructure doesn't expand as expected; service network availability outside major metro areas.

Alternative-fuel options gain flexibility from this rescission:

• Natural Gas (CNG/LNG): No federal GHG mandate means natural gas trucks compete on a level playing field with diesel and electric. Can offer lower fuel costs where infrastructure exists. Best suited for return-to-base operations and high-mileage applications near fueling stations.
• Renewable Natural Gas (RNG): Remains an attractive option for fleets with sustainability commitments — very low lifecycle carbon footprint; Renewable Fuel Standard (RFS) credits still apply.
• Hydrogen / Fuel Cell: Currently limited availability for heavy-duty applications; infrastructure is nascent; may attract renewed investment as an alternative to battery-electric absent GHG mandates pushing only toward BEV.
• Renewable Diesel and Biodiesel: Drop-in replacements for diesel that work in existing engines; RFS compliance pathway remains intact.

Without a federal GHG mandate pushing toward a specific technology, the decision is yours — and it should be driven by your operation, not compliance:

• Diesel: Lowest upfront cost; widest service network; proven for high-mileage long-haul; must meet criteria pollutant (NOx/PM) standards; best total cost for long-haul and rural operations.
• Natural Gas: Competitive fuel cost in some regions; established for return-to-base fleets; smaller dealer/service network than diesel; lower upfront cost than electric.
• Battery Electric: Highest upfront cost; lowest per-mile energy and maintenance costs; best fit for urban delivery, regional routes under 300 miles, and return-to-base operations with overnight charging.
• Hybrid: Moderate premium over diesel; improved fuel economy in stop-and-go and vocational cycles; proven reliability for transit and municipal applications.

The right answer depends on your routes, duty cycles, fueling infrastructure, and total cost of ownership. Contact us to help you run the numbers.

Yes — and they are entirely separate from the GHG standards that were just repealed:

• CAFE standards (Corporate Average Fuel Economy) are administered by the National Highway Traffic Safety Administration (NHTSA) under different federal law (EPCA/EISA). They are not affected by this EPA action.
• Fuel economy labels on new trucks remain required.
• NHTSA's fuel economy standards for heavy-duty trucks and vocational vehicles remain in full effect.

This means manufacturers still face fuel economy compliance obligations — so new trucks will continue to be designed with fuel efficiency in mind, even without federal GHG targets.

Likely modestly worse for trucks designed outside of state-regulated markets, absent voluntary manufacturer effort:

• Prior GHG standards were, in practice, a strong driver of fuel economy improvement — reducing CO₂ per mile requires burning less fuel. CAFE standards alone do not push as hard.
• Manufacturers may shift to less expensive conventional diesel configurations that are optimized for cost and reliability rather than maximum fuel efficiency.
• Actual fleet fuel economy depends heavily on real-world factors: load, terrain, driver behavior, idle time, and spec selection — these will matter more than any regulatory change.

Focus on total cost of ownership over your actual duty cycle — not just purchase price or sticker fuel economy:

1. Model your actual routes — fuel cost per mile varies dramatically by terrain, load, and speed. Get fuel consumption data from operators running similar applications.
2. Diesel: Proven per-mile cost; infrastructure everywhere; best for high-mileage and long-haul.
3. Natural gas: Competitive where CNG/LNG infrastructure exists on your routes; locked in by fueling location availability.
4. Electric: Lowest per-mile energy cost in urban and regional applications; calculate based on your electricity rate and duty cycle, not national averages.
5. Factor in maintenance: Electric trucks have significantly lower maintenance costs — no oil, DEF, or exhaust system service. This can offset higher upfront cost over a 5–7 year cycle.

Resources: fueleconomy.gov — EPA's fuel economy database remains active and up to date; ATRI's trucking cost-per-mile benchmarks; your fuel provider's route modeling tools.

Yes — for trucks you've already purchased, all warranties remain valid and unchanged:

• Emissions-system warranties (DPF, catalytic converter, EGR, SCR/DEF systems) remain in force for the full warranty term.
• Battery warranties on electric trucks remain valid.
• Nothing in this rescission modifies or voids any existing purchase contract or warranty agreement.

For trucks you buy going forward: manufacturers will set warranty terms for new model year vehicles. You may see changes as manufacturers adapt their product and warranty strategies for post-rescission lineups. Review warranty terms when spec'ing new orders.

No action required on your part:

• Labels on trucks you already own accurately describe the emission equipment installed — nothing about that equipment changes, so the labels remain correct.
• There is no requirement to remove, replace, or modify emission labels on existing vehicles.
• Fuel economy labels on new trucks remain federally required under the CAFE program, so new vehicles will continue to carry those.

For fleet record-keeping: your vehicles' emission certifications remain on file with EPA and are unaffected. If you participate in state registration or inspection programs that reference federal standards, those programs operate independently and are unchanged by this rescission.

Review any contracts that reference GHG or emission performance:

• Emission-performance clauses: If your lease or purchase agreement requires the vehicles to meet specific GHG standards, those standards are no longer federal requirements. Discuss with your lessor or counterparty — the clause may be moot or open to renegotiation.
• GHG cost-sharing provisions: Some fleet agreements include language about allocating the cost of GHG compliance. With federal standards gone, those provisions may be reopened.
• Powertrain specification terms: If contracts specify a particular powertrain to meet regulatory requirements, you may now have more flexibility in what you can order.

Action steps: Pull any fleet agreements referencing "GHG," "greenhouse gas," "emission standard," or "CO₂"; flag them for your legal team; and update template language for new agreements going forward.

Yes — legal challenges are expected and likely already underway:

• The rule takes effect 60 days after Federal Register publication; petitions for judicial review must also be filed within 60 days, in the U.S. Court of Appeals for the D.C. Circuit.
• Expected challengers: Environmental organizations, states (especially California), and potentially some automakers or technology companies whose products are disadvantaged by the repeal.
• Possible outcomes: The rule could be upheld in full; partially vacated; sent back to EPA for reconsideration; or temporarily stayed while litigation proceeds.
• Full resolution could take one to three years.

Proceed carefully — assume some uncertainty will persist:

• Courts could stay or reverse the rule, potentially restoring federal GHG requirements for MY 2027+ trucks.
• A future administration could re-issue GHG standards through a new rulemaking.
• California and CARB-state rules are unaffected regardless of what happens federally.

Practical approach for fleet planning:

1. Don't make irreversible commitments based solely on the assumption that federal GHG standards are gone permanently.
2. Maintain some powertrain diversity in your fleet — don't go all-in on one technology while litigation is pending.
3. Keep relationships with suppliers of clean and electric technologies; you may need them.
4. Plan for the markets where you actually operate — California rules aren't going away regardless of what happens federally.

Any reinstated standards would almost certainly apply prospectively — to future model years — not retroactively:

• Courts are very reluctant to impose retroactive regulatory obligations on parties who relied on a valid rule. Trucks you purchased or ordered during the rescission period are highly unlikely to face retroactive compliance requirements.
• If standards are reinstated, the effect would most likely be that MY 2027+ (or a later model year) trucks must again meet federal GHG targets.
• Manufacturers who maintained clean-technology development pipelines would be better positioned; those who abandoned EV development entirely may face a difficult ramp-up.

For your current fleet:

• No operational changes required — continue running and maintaining your trucks as normal.
• Confirm that emission systems on your trucks (DPFs, EGR, SCR) are properly maintained — NOx and PM standards are unchanged and enforcement continues.
• If you operate in California or CARB states, verify your vehicles continue to meet applicable state standards.

For fleet purchasing and planning:

• Near-term purchases: proceed based on your operational needs and total cost of ownership — don't wait for legal certainty if you need equipment now.
• Longer-term fleet plans: maintain powertrain flexibility; don't overcommit to a single technology during the litigation period.
• Review and update any fleet procurement templates or RFP language that references federal GHG compliance requirements.

For your contracts and finances:

• Audit fleet leases and purchase agreements for GHG-related performance clauses or cost-sharing provisions.
• Consult legal counsel if you have contracts where GHG terms create uncertainty.
• Talk to your CPA about any asset values tied to emission-technology investments.

With federal GHG mandates gone, your conversation with a truck sales team should focus on operational and economic fit:

1. "What are the real-world fuel costs per mile for this truck in my application?" Ask for data from operators in similar duty cycles — not just EPA test numbers.
2. "Does this truck meet California/CARB standards if I operate there?" If any of your routes or terminals are in California or a CARB state, this is non-negotiable.
3. "What are the total maintenance costs over a 5-year cycle vs. alternatives?" Compare diesel, natural gas, and electric on total cost — not just sticker price.
4. "What does the warranty cover for emissions and powertrain components, and for how long?"
5. "What financing or incentive programs are available for electric or alternative-fuel options in my state?" State and utility incentives may significantly change the cost calculus.

The impact depends heavily on your operation type:

• Long-Haul (500+ miles/day): Diesel remains dominant. Electric trucks are not viable for most long-haul applications given current range and charging time limitations. Natural gas is an option where fueling infrastructure aligns with routes. Federal rescission has minimal short-term impact on your buying decision.
• Regional (100–400 miles/day, return to base): Electric trucks are increasingly viable and cost-competitive in this application. The rescission doesn't change the operational economics. If your state has ZEV incentives, electric may still be the right choice regardless of federal mandates.
• Urban / Local Delivery (under 100 miles/day): Electric trucks are well-suited and often the lowest total-cost option. State incentives, route density, and overnight charging at your facility make this the application where the business case is clearest — independent of any regulatory requirement.

Federal sources:

• EPA Final Rule on Rescission of GHG Endangerment Finding — epa.gov (search docket EPA-HQ-OAR-2025-0194)
• Regulations.gov — docket EPA-HQ-OAR-2025-0194 for full rulemaking record
• fueleconomy.gov — fuel economy database for new trucks; remains active and current

State sources:

• California Air Resources Board (CARB) — ww2.arb.ca.gov — for California-specific GHG, NOx, and ZEV standards
• Your state's Department of Environmental Quality or equivalent for state-specific rules

Industry sources:

• American Trucking Associations (ATA) — regulatory alerts and fleet guidance
• National Truck Equipment Association (NTEA) — vocational truck regulations
• Your truck manufacturer's regulatory affairs or fleet team

Legal and compliance:

• Consult qualified legal counsel for contract review and state-specific compliance questions
• Monitor D.C. Circuit Court docket for litigation updates on this rule