More than 30,000 orders were placed for Class 8 trucks across the United States and Canada in December. That total was down slightly from November, but far outpaced December 2023 and showed an industry on an upswing during its peak order season.
From September through December, Class 8 orders were up 6% year over year, FTR reported at the time, while ACT Research President and Senior Analyst Kenny Vieth said, “Strength continues to be the applicable descriptor of Class 8 order activity as the industry looks to 2025.”
Then the calendar turned to 2025.
January saw orders immediately slip by more than 5,000 units. February was worse. Orders fell to numbers typically reserved for the market’s summer doldrums, collapsing nearly 40% month-over-month and year-over-year.
Trade and economic uncertainty were cited as reasons for the drop, but to pin falling truck orders exclusively on Washington dysfunction overlooks a critical detail. As of January, there are now six states where placing a new truck order has never been harder.
The sales barriers produced by the California Air Resources Board (CARB) Advanced Clean Trucks (ACT) rule are spreading.
Sales buckle under regulatory requirements
“We have not taken an order for a new Class 8 tractor here since September 2024,” Kevin Holmes, CEO at Advantage Truck Group, told Trucks, Parts, Service last month about his operations in Massachusetts. “We are delivering trucks, and will continue to do so for the next several months. But we are not taking new orders.”
“Our salesmen are busy now, but they’re not busy because they’re selling,” Brian Buckley, vice president of sales at Ballard Truck Center, told TPS at the same time. “When we stop delivering trucks, I don’t know what they’re going to do.”
Massachusetts is one of five states (New Jersey, New York, Oregon and Washington are the others) that opted into CARB’s ACT rule for medium- and heavy-duty trucks on Jan. 1. Enacted in California the prior year, CARB describes ACT as a “holistic approach to accelerate a large-scale reduction of tailpipe emissions focusing on zero-emission medium- and heavy-duty vehicles from Class 2b to Class 8.”
The rule features sales and fleet reporting components, but it is exclusively the former that is proving cumbersome for the industry. Under ACT, truck manufacturers are required to sell zero-emission vehicles (ZEV) as a growing percentage of their sales on a rising annual scale before banning the sales of diesel trucks in 2036.
ACT also calculates its percentages on a per-sale basis, meaning OEMs are required to sell ZEV equipment before earning credits for to sell diesel equipment. Credits also vary based on vehicle class and engine, meaning ZEV-to-diesel ratios are unique based on the equipment being sold. (In the Class 8 market, BEV to diesel ratios range from 1:9 to 1:13 based on state, make, model and engine.)
Published by CARB in 2020, ACT was agreed to by manufacturers in July 2023 under the Clean Truck Partnership, which committed manufacturers to support ACT and its sister rule, Advanced Clean Fleets (ACF). California agreed to align its state regulations with EPA 2027 regulations, alter its NOx regulations and commit to four-year lead times for industry to align with future state rules.
Both sides have maintained the agreement, but the details have changed. In January, CARB withdrew its EPA waiver request for authorization of Advanced Clean Fleets and announced it would not enforce portions of the regulation requiring the waiver. Though CARB says it is “evaluating next steps,” ACF’s future is unclear.
For dealers in CARB opt-in states, implementing ACT without ACF has created an imperfect storm — manufacturers are required to sell ZEVs to earn diesel credits, but customers are under no obligation to buy them.
So they aren’t.
Joe Cambria is the owner of Cambria Truck Center, a Mack, Volvo and Peterbilt dealer with two locations in New Jersey. Cambria has sold trucks in the Garden State his entire career and, since New Jersey committed to adopting ACT in 2021, has been working hard to generate interest in battery electric trucks across his customer base.
“We have a lot of customers who have tried them out, but eventually they have to charge them and there’s nowhere to go,” Cambria says. “Then they call their utility and realize it might take 10 years to get the power they need to put in a charger. You can’t run a business like that.”
“I can count on one hand, less than one hand, the number of customers expressing interest in EVs,” says Matt Preston, vice president, New England, for The Pete Store. “We’ve had two municipalities ask us for quotes. We don’t have one EV truck on order for Massachusetts right now.”
The story doesn’t change on the West Coast.
“We’ve worked really hard to sell these solutions to our customers but the ROI just isn’t there. And they can’t see it,” says a dealer located among the western opt-in states. “We even know some customers who have tried them and put them in their fleet, only to start to drift away from them because of the challenges.”
Too many barriers to adoption
Selling a Class 8 ZEV is a hurdles race without a finish line, dealers say.
“We have customers come in and say, ‘I want to try an electric truck’ and you quote them and they can’t believe it. It’s almost three times the cost of a regular day cab,” Cambria says.
For customers who are eligible, state and federal incentive programs can bring prices down some. Manufacturers have worked hard in this area to support interested customers.
“The greatest incentives for purchasing and operating a BEV can be found through local and state incentive and grant programs. Some federal incentives also are available but will be less common in the next years,” says Daimler Truck North America (DTNA) in a statement to TPS. “The incentive landscape can be complicated and overwhelming for fleets and some dealership groups. DTNA has a dedicated team of consultants ready to help dealerships and their customer sort through the many incentive programs available in areas across the U.S.”
But price parity remains out of reach, which makes selling especially tough when considering the other challenges an EV brings a fleet.
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“I’ve had customers show me their exact route and we’ll map out where they’d need to stop and charge and there are no chargers anywhere. Not close,” he says. “You’re not pulling into a Wawa and hooking up to a Tesla charger for these things. It’s a whole different deal.”
“There is no place to publicly charge a [Class 8 BEV] in New Jersey today. None,” says Eric DeGesero, lobbyist with the New Jersey Trucking Association. He says the state received $90 million through two federal grants to install public charging for commercial vehicles, but, to date, that money remains tied up in development with the earliest charging stations set to come online in 2029. He also notes a single bus charging depot being installed at the Meadowlands is expected to cost $100 million, which doesn’t bode well for electrifying the entire state.
“We have a member of our association who is an early adopter. He’s bought an electric truck and he wants to buy more. But he’s been vocal that we need to delay [ACT]. He says there’s no way he can run his business with EVs right now until we have charging,” DeGesero says.
It’s no better in Massachusetts, where Transportation Association of Massachusetts Director Kevin Weeks reports “We don’t have a single medium- or heavy-duty charging station available to the public.”
Like New Jersey, Weeks says money is allocated, but chargers remain uninstalled. For a state with 2,300 fueling stations, he says electrifying trucking today is impossible. That is why no one in the state is ordering trucks.
“We had a meeting in November 2024. At that time of year, our group would normally have placed about 1,300 orders for the next year. There were none,” he says.
“We have customers who come in almost daily to place orders and we have to tell them [about ACT],” Preston says. “They don’t understand. ‘What do you mean I can’t order a truck?’”
“There is a huge awareness issue. It’s something we’ve been dealing with for a while,” adds Chris Thompson, vice president of truck sales at TEC Equipment. TEC has locations across the West Coast and wasn’t new to ACT when the rule arrived in Oregon and Washington in January. But many customers were, despite the efforts of dealers and trucking associations in both states.
Thompson recalls a panel discussion he participated in at an Oregon Trucking Association (OTA) conference last year.
“The panel was called ‘Can I Buy a New Truck in 2025?’ and we basically got up there and had to say, ‘No. Not unless you also plan to buy an EV,’” he says. “There was silence in the room.”
“We have tried very hard to lobby the state and show them this isn’t the right time for this but we’ve had very little success,” says OTA President and CEO Jana Jarvis. “There are so many issues with adopting [ACT] now. We need time to be able to discuss the real-world implications of moving transportation toward electrification.”
States could offer a reprieve
At this time, no opt-in state has postponed ACT implementation, but winds appear to be shifting.
In February, the EPA formally requested Congress review California's previously granted emissions waivers. The Agency also announced last week it will reconsider its Phase 3 GHG regulations. The latter would not remove ACT mandates could eliminate Federal ZEV sales requirements expected later this decade.
Additionally, late last year, Massachusetts, New York and Oregon delayed implementation of CARB’s Low NOx Omnibus regulation to 2026 due to availability issues with compliant engines, and bills have been introduced in those states and New Jersey to pause ACT implementation until infrastructure in each state catches up to industry requirements.
In a Jan. 30 Oregon House committee meeting regarding House Bill 3119, a bipartisan bill to delay ACT, Director of Oregon’s Department of Environmental Quality (DEQ) Leah Feldon stated, “Reducing transportation emissions is important. As is reducing those emissions in an intentional way that works for Oregon.”
But Feldon noted later in the meeting DEQ is aware of the impact of the regulation on dealers due to the OEM sales mandates, while DEQ Transportation Strategies Section Manager Rachel Sakata acknowledged the credit transfer apparatus available to OEMs for lower equipment classes does not help sell Class 8 trucks.
“I will note, the Class 7-8 tractor trucks lack many of these flexibilities, and that is where we are hearing the struggle,” she says. “And so, for example, the credits from the sale of Class 2B, 3 and Class 4-6 vehicles cannot be used to meet the Class 7 and 8 tractor requirements.”
Feldon added, “We want to look at multi-state solutions focusing on the tractor class. We know of all the truck classes Class 7-8 tractors will be the toughest to transition. DEQ must maintain identicality with California as you’ve heard, but we can and will use our voice to address challenges faced by this particular sector.”
Yet the DEQ also remains committed to the long-term goal of the ACT rule, which Public Affairs Specialist Susan Mills says “is a critical step in reducing greenhouse gas emissions and improving air quality. Pausing that implementation would delay much-needed progress in transitioning to cleaner transportation and undermine the state’s climate and public health goals.”
“The ACT Rule is designed to drive market growth and innovation,” she adds. “Delaying the rule would slow advancements in ZEV technology, hinder price reductions, stall necessary investments in charging and fueling infrastructure and ultimately result in higher costs down the road. Keeping the ACT Rule in place signals long-term regulatory certainty. It encourages manufacturers to accelerate production and bring down costs through economies of scale.”
A similar evaluation is underway in New York, where a bill introduced in October advocated likewise for a delay.
“This legislation is essential to ensure our trucking industry and municipal highway departments are not set up to fail. The ACT regulation, though well-intentioned, will pose significant challenges for businesses and communities that are not yet prepared for such a rapid transition,” said Assemblyman Brian Miller, a sponsor of the bill. “By delaying implementation of the ACT regulation, we are giving New York time to build the necessary infrastructure and ensure that businesses like Utica Mack and our highway departments can continue to serve the public without disruption.”
The Trucking Association of New York strongly supports the delay for the same reasons referenced in other states, says Zach Miller, TANY’s vice president of governmental affairs.
“We all want a realistic roadmap to reduce emissions and we believe we can get there with a menu of options,” he says. “ACT is a one-size-fits-all approach and that’s not how our industry operates. It takes away from where EVs are making progress and places them into applications where they’re not ready.”
He adds, “To the extent that the government is looking at a realistic roadmap, we are hopeful.”
In a statement to TPS, the New York State Department of Conservation (NYSDEC) wrote “New York’s adoption of the ACT rule is one of several steps the state is taking to advance the transition to a cleaner, healthier and more efficient transportation future by cutting greenhouse gases, reducing harmful pollution and promoting the growth of the green transportation industry.
“In addition to providing manufactures with significant flexibility in implementing the original rule, DEC will also be proposing new regulations that include more flexibilities and would not require compliance determinations until March 2029. This extended timeframe would provide medium- and heavy-duty vehicle manufacturers additional time to achieve compliance, either by selling additional ZEVs or purchasing credits from other manufacturers.
“DEC is communicating with members of the legislature and other key stakeholders regarding the implementation of ACT to address concerns and counter misinformation.”
Dealers nervous about future
Until a state chooses to pause the regulation or CARB decides to alter it, dealers will remain hamstrung, forced to sell ZEVs to customers uninterested in them while neither party is able to bring new, cleaner diesel equipment into their states.
“That’s the thing, 50% of all Class 8 trucks are model year 2010 or older. If we want to reduce emissions that’s where we need to start,” says Holmes.
DeGesero agrees.
“You need 60 trucks today to equal the emissions from one truck from 1988. These new trucks are not the problem,” he says.
“We have brought that point up over and over and over,” Jarvis says. Trucking cannot reduce its emissions if carriers aren’t allowed to replace their older dirtier equipment for new units, she says. And the longer carriers are forced to manage with suboptimal equipment by a state, the more likely they become to leave it.
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“Oregon is the most expensive state for trucking taxes and fees,” she says. “That’s been one of my biggest concerns for a while … It seems [regulators] tend to think it’s hard for businesses to move, but for trucking companies it isn’t.”
She adds, “If you don’t allow our members to move into newer, cleaner equipment, you’re just going to have them move out of state, or hold onto equipment longer. Neither one is good for the state.”
“Upgrading old diesel trucks to newer, high-performance diesel engines can significantly improve emissions and reduce CO2 levels. Postponing the replacement of older vehicles with these more efficient engines may hinder efforts to lower emissions in the transportation sector today,” states DTNA.
And dealers and trucking groups add cratering new truck sales will eventuality hit opt-in states in their pocketbooks too.
“I think it’s possible — around the time we sell out of our existing stock and have no new trucks to deliver — volumes will drop to a level where the state has to ask, ‘Where did this tax revenue go?’” says Preston.
“We’ve never wanted that to be our focus, but it has to be a part of this,” adds Weeks. “If customers who always bought trucks in Massachusetts are suddenly domiciled and buying trucks in Vermont, how does that help us?”
In the meantime, dealers across opt-in states are doing their best to maintain high absorption rates and keep the lights on. But fears for their salespeople and operations are real.
“I just had personal meetings with my six Massachusetts sales guys. Four of the six, my senior guys, all told me they will retire in the next 18 months because of this,” says Buckley. “And truck salesmen are not falling off the turnip truck. To replace those guys will be a monumental task. How do you hire somebody into a market where you can only sell snowplows?”
“That’s what keeps us up at night,” adds Thompson. “We haven’t lost anybody yet, but if you walk out on sales floor there is concern and fear in everybody’s eyes.”
“I came on full time in 1989 and for my career, there’s always been a path [for truck sales],” says Cambria. “When the market’s been bad, when we’ve had the EPA rollouts, there’s always been a way to tighten your belt, get creative. Find ways to help the customer. This ACT business is a dead end. It’s a concrete wall.”
He adds, “I can sell about anything in this industry — but I cannot work any harder, think any deeper or invest any more in our business to get our customers to buy these things.”
“You don’t want to try and put the customer into a unit that’s not good for their application just so you can get the credits,” adds the West Coast dealer. “That’s not helpful and it’s not going to work out for them.”
It also might sour them on considering a non-diesel option in the future, he says — even one that might make sense.
“What if we’re looking back in the 2030s and thinking ‘This could have worked if we didn’t force it too early? What if we waited for the infrastructure to catch up?’”
