Manufacturer information

Under Advanced Clean Trucks, each manufacturer generates a deficit based on how many new internal combustion engine vehicles they sell. They must make up that deficit — or sales requirement — with credits generated through zero-emission vehicle (ZEV) sales. 

Manufacturers can comply by generating their own credits or buying credits from others. 

The regulation took effect with model year 2025, but manufacturers have been able to generate credits since model year 2021. Table 1 below shows reported vehicle sales for model years 2021-2023.  

Table 1. Reported model year 2021, 2022, and 2023 vehicle sales in Washington state

Manufacturer vehicle sales and credits

With the exception of semi-trucks (Class 7-8 tractors), credits generated through the sale of one type of ZEV can be used to meet requirements for others — even across weight classes. Table 2 shows how reported ZEV sales for model years 2021-2023 translate into credits that can be used for compliance.

We estimate manufacturers will need roughly 1,300 non-tractor credits in 2025 and about 2,000 non-tractor credits in 2026. Manufacturers already have more than enough credits to meet these requirements, and they’ll generate even more through 2024-2025 sales. 

We estimate manufacturers will need about 320 tractor credits in 2025 and roughly 310 tractor credits in 2026. Zero-emission tractor sales have been slower and less predictable, so it’s unclear whether manufacturers are on track to comply. However, Ecology’s current rulemaking eases Class 7-8 tractor sales requirements and gives manufacturers three years to make up shortfalls. Additionally, the Washington State Department of Transportation is set to launch a $110 million program this year that could generate over 1,000 tractor credits, far exceeding 2025 and 2026 requirements.

Table 2. Projected 2021-2023 model year medium- and heavy-duty vehicles credit bank for Advanced Clean Trucks

*Does not include sales of 470 Class 2b-3 vehicles credited under Advanced Clean Cars.

Note: These are preliminary projections of credit banks based on manufacturer reported sales and do not represent final credit banks. We will update this information as needed once reported sales are validated.

Manufacturers are on track to exceed Advanced Clean Cars’ 2025 requirement that 8-9% of new light-duty vehicles sold in Washington must be electric or plug-in hybrid. In Q3 of 2024, electric and plug-in hybrid vehicles made up more than 24% of Washington’s new vehicle sales.  

The sales requirement rises to 35% in 2026, when Advanced Clean Cars II takes effect, but we expect electric and plug-in hybrid sales to continue growing.

Table 1 below shows early-action credits generated by Washington’s 2023 model year sales, which can be used to comply with Advanced Clean Cars and Advanced Clean Cars II. Manufacturers will earn additional credits from model year 2024 and 2025 sales. Manufacturers can use excess credits from previous model years to comply, too. 

Acronyms 

• ZEV = zero-emission vehicle 
• FCEV = hydrogen fuel cell electric vehicle 
• BEV = battery electric vehicle 
• BEVx = battery electric vehicle with a range extender (onboard motor that can charge the battery but not provide propulsion) 
• NEV = neighborhood electric vehicle (top speed of 25 miles per hour) 
• TZEV = transitional zero-emission vehicle (often a form of hybrid) 

Table 1 – Total 2023 light-duty vehicles sales and current credit bank for Advanced Clean Cars and Advanced Clean Cars II. 

*Volume status indicates what level of standard that manufacturer is subject to, with the largest volume manufacturers producing the most vehicles and being subject to the highest standards under Advanced Clean Cars and Advanced Clean Cars II. The smallest manufacturers can earn credits from their ZEV and plug-in hybrid electric vehicle (PHEV) sales, but they are not subject to the requirements.

**After 2025, any remaining credits will be converted into Advanced Clean Cars II credits.

Vehicles are classified as light-, medium- or heavy duty depending on their size and the maximum weight they're designed to carry, called "gross vehicle weight rating," or GVWR.

Light-duty vehicles are typically passenger cars used for personal commuting. Medium- and heavy-duty vehicles are typically commercial vehicles, with the exception of some larger pick-up trucks.

There are some exceptions depending on which vehicle you're looking at, such as military tactical vehicles and authorized emergency vehicles. See the WAC 173-423-060 for more details.

Manufacturers submit their vehicles to the California Air Resources Board (CARB) to be certified to the low-emission vehicle standards. Once approved, CARB issues executive orders for each vehicle that are sent to all states that have adopted California’s low-emission vehicle standards. This ensures the vehicles sent to those states for sale are in compliance and can be registered.

This process applies to light-, medium- and heavy-duty vehicles.

To comply with the zero-emission vehicle standards laid out in Advanced Clean Cars and Advanced Clean Cars II, manufacturers must sell enough light-duty clean vehicles to meet the sales requirement for each model year or purchase credits from those who exceed the requirements to make up their shortfall.

The sales requirements for each model year are underpinned by a credit system. Each new clean vehicle sold receives a credit value that varies depending on whether it’s a true ZEV versus a plug-in hybrid and whether the manufacturer claims additional environmental justice credits. Additional environmental justice credits can be earned for selling discounted ZEVs and selling ZEVs to dealers offering financial assistance. Manufacturers must sell enough clean vehicles to meet the credit requirement for each model year, which pencils out to a certain percentage of their new vehicle sales.

Advanced Clean Cars* only applies to model year 2025. Under this regulation, each vehicle receives 1-4 credits. The credit percentage required is 22%, which translates to roughly 8-10% of new light-duty vehicle sales. 

Under Advanced Clean Cars II, the credit system was simplified so that the credit requirement for each model year is roughly the same as the sales percentage requirement. Advanced Clean Cars II begins with model year 2026 and requires 35% of new light-duty vehicles sold in Washington to be ZEVs. The sales requirement rises 6-9% each year until we reach 100% in model year 2035. 

When we reach the 100% sales requirement, new light-duty vehicles made in model year 2035 or later that don't meet Washington’s standards won’t be able to be sold, registered, licensed, or rented within the state, even if they meet federal standards. Manufacturers can continue to sell plug-in hybrids, as long as they don't exceed 20% of new vehicle sales. 

Advanced Clean Trucks is a flexible policy that allows manufacturers to comply by selling increasing percentages of new medium- and heavy-duty ZEVs in Washington or purchasing credits generated by those who exceed sales requirements.

Advanced Clean Trucks sales requirements under vary by vehicle weight class:

If a manufacturer exceeds the sales requirements for a particular model year, the credits they generate can be saved to comply in the future or sold to those who fall short of sales requirements. Ecology allowed manufacturers to start generating credits four years before Advanced Clean Trucks took effect in model year 2025. Fifty percent of a manufacturer’s requirements each year can also be met with credits generated by plug-in hybrid vehicles.  

Manufacturers that miss the sales requirement for a particular model year have a full year to make it up. California is considering extending this grace period to three years. 

Most light-duty ZEVs have a range between 150 and 400 miles. Many light-duty vehicles can reach 80% charge in just 30 minutes, depending on the type of charger. 

When it comes to medium- and heavy-duty vehicles, driving range averages 150-300 miles. But some models, like Tesla’s Semi, can drive up to 500 miles. Nikola’s hydrogen fuel cell tractor is rated for up to 750 miles of range. Many of today’s trucking routes can be served by existing ZEV technology, especially shorter haul and regional routes or routes that don't require maximum payloads. And truck buyers can choose which routes make sense for ZEVs.

There are more and more zero-emission trucks coming to market each year, and promising technologies that increase payload and range are being developed. Clean vehicle regulations are expected to drive even more innovation in this technology.

All new internal combustion engine vehicles available for sale in Washington must meet LEV standards, which can be found in Advanced Clean Cars I and II. This is the manufacturer’s responsibility.

If the new vehicle is purchased in Washington, it will meet LEV standards. This may not be the case for new combustion engine vehicles purchased out of state, unless that state has adopted the same LEV standards as Washington. However, new combustion engine vehicles that don't meet LEV standards can't be registered in Washington even if they are purchased out of state. 

Under medium- and heavy-duty LEV standards, manufacturers are allowed to sell some new engines and vehicles that have been certified to older standards if they offset emissions in other ways. So smaller quantities of these “legacy” engines and vehicles will still be available for purchase and registration. We’ll provide further guidance on legacy sales and registrations before these standards take effect in 2026.

Current regulations only require manufacturers to sell more new ZEVs in Washington, and they don’t place purchasing requirements on dealers or fleet owners. 

We've heard that some manufacturers are passing on their compliance obligation by imposing sales requirements on dealers. We don’t require or recommend this practice, and we’re working to educate the industry about the many compliance options available to them.

Instead of meeting ZEV sales requirements, manufacturers have the option to purchase credits from those who have exceeded the sales requirements. We've allowed manufacturers to generate credits for their ZEV sales since 2021 — about four years before ZEV standards started taking effect.

Credits can't be saved indefinitely. ZEV credits have limited lifetimes as follows: 

• Credits generated in the 2021, 2022, and 2023 model years expire at the end of the 2030 model year and are no longer available to to be used to meet compliance for 2031 and later model years.
  • For example: ZEV credits generated during the 2022 model year can be used to meet compliance requirements until the end of the 2030 model year. They can't be used to meet 2031 model year compliance requirements.
• Credits generated in 2024 and subsequent model years can be used only for five model years after the model year in which they're generated.
  • For example: ZEV credits generated for the 2024 model year can be used to meet compliance requirements until the end of the 2029 model year. They can't be used to meet 2030 model year compliance requirements. 

Manufacturers that miss the sales requirement for a particular model year have a full year to make it up. 

No. Advanced Clean Trucks isn't ramping up more quickly in Washington than it did in California. The ZEV requirements for each model year are the same in both states, as required by the federal Clean Air Act. 

In California, Advanced Clean Trucks took effect with model year 2024, which had a 5-9% ZEV sales/credit requirement. In Washington, Advanced Clean Trucks took effect with model year 2025, which has a 7-11% ZEV sales/credit requirement, matching the 2025 requirement in California.

Manufacturers selling in Washington have been able to generate and bank credits since 2021 without having to use them for compliance until model year 2025 — one more year of early-action credits than California.

The upfront cost of a ZEV is currently higher than comparable gas- or diesel-powered vehicles. However, in many cases, ZEVs have a lower total cost of ownership. Those that don’t are expected to reach parity in the early 2030s, with exact timing varying by vehicle type.

The main driver of these total cost of ownership savings is the fact that electricity is cheaper than gasoline or diesel, and Washington has one of the largest gaps between electricity rates and fuel prices. Additionally, ZEVs tend to have lower maintenance costs. They don’t require oil changes, transmission fluid, spark plugs, air filters, or many other consumables found in combustion vehicles. Their brake pads usually last much longer because the vehicles capture and reuse as much as one-fifth of the energy normally lost during braking through “regenerative braking.”

The financial benefits of owning ZEVs are expected to continue to grow as purchase prices come down and charging infrastructure costs decline.

Advanced Clean Trucks requirements were designed to be feasible even in the absence of public charging infrastructure; they were written with only depot charging in mind. However, Washington is committed to robust support of the trucking industry through the transition to clean vehicles.

Over $130 million in funding from the Climate Commitment Act is being provided to help truck owners cover the costs of electric medium- and heavy-duty vehicles, as well as charging infrastructure. Additional state support has been made available through the Clean Fuel Standard, state tax credits on commercial ZEVs and associated infrastructure, as well as Volkswagen Settlement grants, Clean Diesel grants, and the Zero-Emission School Bus grant program. 

We’re leveraging federal funding, too. Recently, the federal government announced awards under the Charging and Fueling Infrastructure grant program for Washington, Oregon, and California to build an electric truck charging corridor along the entirety of I-5, and the state has secured over $55 million in state and federal funding to electrify drayage trucks operating in and around ports.

The federal government also provides tax credits on charging infrastructure and tax credits on commercial ZEVs valued at up to $40,000 per vehicle, in addition to funding available through other programs, like the EPA’s Clean School Bus program.

To find a charging station on the west coast, visit the West Coast Green Highway map. For charging stations around the nation, visit the Plug Share website.

Washington has several resources for customers who want to buy a ZEV and charging equipment:

• Investing in cleaner transportation webpage
• Reducing diesel emissions webpage
• Washington State Electric Vehicle Council webpage