Insights to California’s Straight-Truck TRU Rules 2022 Effect

Truck TRU Rules 2022

California’s refrigerated transport market will make significant changes by next year. The refrigerated straight-truck fleets operating in California must convert at least 15% of their trucks to electric transport refrigeration units by the end of next year.

The California Air Resources Board (CARB) changed the rules for mobile transportation refrigeration units, known as TRUs or reefers, which are mounted on the straight truck chassis. CARB stated that it has developed regulations for addressing the toxic and harmful emissions from diesel-powered TRUs. Diesel particulate matter (diesel PM), fine particulate matter (PM 2.5), oxides of nitrogen (NOx), and greenhouse gases (GHG).

One of the most notable parts of the rule states that van and straight truck operators turn over at least 15% of their fleet to zero-emissions refrigeration systems every year for the upcoming seven years till they reach 100% zero emissions by 2029. The last deadline for the first 15% transition is Dec 31, 2023. The fleets do not face sanctions, which usually include the grounding of the entire fleet.

The deadline is just a year away, and there is a remarkable discussion in the trucking industry that is being overshadowed by proposals for advanced clean fleets. Many fleets are not aware of the rules. Therefore, some believe that CARB will again implement the requirement. 

There is a six-month extension for individual fleets due to private financing, private manufacturing delays, or installer delays.

In addition to zero-emissions TRU replacement, there are two main requirements with the effect by the end of 2022.

  1. The lower PM emissions for railcar TRUs, TRU generator engine sets, and domestic shipping container TRUs.
  2. The usage of new refrigerants with a global warming potential is much lower than 2200. The transport refrigeration unit suppliers have made standard R452A, which has been available for several years.

Sales of ICE Reefer Frozen: 

By the end of 2023, the TRU rule prohibits the sale of diesel-powered refrigeration medium-duty trucks and freezes the sales of traditional truck-mounted reefer units in California. 

As of Jan 1, 2024, the TRU manufacturers cannot pull any power from the internal combustion diesel engine in California. It means an end to electric TRUs driven by the truck’s battery system.

The TRU must be electric so that the trucks can use an internal combustion engine. Another rule in effect is that there will be zero-emission trucks which will be phased in at the rate of 10% per year over a prescribed period. As there are few available battery-electric trucks even though there will be some cases in which the customers need to install an electric reefer on an internal combustion truck. It signifies that the refrigeration units are required to have their battery packs.  

It will be very easy and effortless if the electric reefer unit is attached to an electric truck and shares a similar higher voltage battery. 

Principal Elements of California’s Straight-Truck TRU Rules: 

With the effect from December 31, 2023, some of the important elements of the new rules which affect trucking fleets under California’s 2022 Amendments to Airborne Toxic Control Measure for In-use Diesel-Fuelled Transport Refrigeration Units (TRU) and TRU Generator Sets and Facilities where TRUs operate.

  1. Increased TRU reporting: The TRU owners must report to CARB that all TRUs operate in California, even though they are not based in the state.
  2. Compliance Labels and TRU operating fees: The fleet owners are supposed to pay TRU operating fees and affix CARB compliance to their TRUs every three years.
  3. Zero-emission truck TRU requirements: The TRU owners should turn over at least 15% of the California truck TRU fleet to the technology of zero-emissions every year or the next seven years. All the truck TRUs that are operating in California should have zero emissions by Dec 31, 2029.
  4. The compliance extension of up to six months should be considered for delays in terms of manufacturing, installation, or financing. 
  5. For leasing and rental services to customers, the rule suggests that the TRU owner might delegate compliance responsibility to the TRU operator if the rental or lease agreement is for a period of one year or more.
  6. The manufacturers of the zero-emission truck TRUs will provide comprehensive warranty coverage and will have a service network in the state for providing repairs and services. 

The 15% turnover portion of the rule is what most apprehend fleets and TRU manufacturers. The rule is based on the number of trucks the fleet owns and is in service and therefore includes a “rounding” provision which could signal that some fleets need additional zero-emissions units to comply.

Some important deadlines for smaller fleets:

  1. The single-track operations will not have to adhere to the rule until 2026.
  2. The Fleets with two or more trucks are supposed to convert at least one truck to ZE by 2024.
  3. The Fleets with four, five, or six trucks are supposed to have at least one in service by the end of 2023 and up to two by the end of 2024.
  4. The Fleets with seven or more trucks must be governed by the 15% requirement.