The California Air Resources Board (CARB) is the governmental agency responsible for achieving and maintaining healthy air quality in California. Created in 1967, the agency operates under a unique provision of the federal Clean Air Act that allows California to set its own, often stricter, standards for emissions from vehicles and other sources. For any manufacturer intending to sell products that affect air quality in California, obtaining CARB certification is necessary to demonstrate compliance with these regulations. This guide outlines the structure of the CARB certification process.
What Is the California Air Resources Board?
CARB functions as the lead agency for air pollution control and climate change programs within California, working to reduce pollutants while considering economic effects. Its mission is rooted in protecting public health from the harmful effects of air pollution, which is a significant concern due to California’s geography and population density. CARB’s authority to set standards that exceed federal requirements is granted through a waiver from the United States Environmental Protection Agency (EPA).
This legal framework allows California to implement programs that have driven innovation in the automotive and manufacturing sectors. Other states are permitted to adopt California’s vehicle emission standards, extending the influence of CARB regulations beyond the state’s borders. The agency enforces compliance through its own regulations, targeting sources contributing to smog and greenhouse gas emissions.
Identifying Products That Require CARB Certification
Determining whether a product falls under CARB jurisdiction is the first step for any manufacturer planning to operate within the state. Regulations cover a diverse range of products, from internal combustion engines to chemical and wood products that emit harmful vapors. The specific regulatory path depends on the product’s function and its potential impact on air quality.
On-Road Motor Vehicles and Engines
New motor vehicles, including passenger cars, light-duty trucks, and heavy-duty vehicles, must meet California’s emission standards before they can be sold or registered. Manufacturers must certify entire engine families and vehicle platforms, demonstrating compliance with the latest hydrocarbon, nitrogen oxide, and carbon monoxide limits. This requirement applies to the engine, the entire emissions control system, and in some cases, the onboard diagnostics (OBD) systems.
Off-Road Engines and Equipment
CARB regulations extend to engines used in non-road applications, such as construction equipment, marine vessels, and small utility equipment. Small off-road engines (SORE), typically used in lawnmowers and generators, are specifically regulated to limit emissions. Compliance is also required for equipment converted or retrofitted with an alternative fuel system, even if the original equipment was already certified.
Aftermarket and Add-On Parts
Any aftermarket component that affects a vehicle’s emissions control system must receive approval before it can be legally sold in California. This includes parts like catalytic converters, engine programmers, and air intake systems. This regulation ensures that modifications do not negate the effectiveness of the vehicle’s pollution control equipment.
Consumer Products
Beyond engines and vehicles, CARB regulates various consumer goods that release toxic air contaminants or volatile organic compounds (VOCs). Examples include aerosol coatings, architectural paints, and cleaning products. A separate regulation covers composite wood products, such as particleboard, to limit formaldehyde emissions and protect indoor air quality.
Navigating the Different Certification Pathways
Manufacturers typically pursue one of two primary pathways for CARB approval: the Certificate of Conformity (CoC) or the Executive Order (EO). The choice depends on whether the product is original equipment or a modification.
Certificate of Conformity (CoC)
The CoC is the compliance document sought by Original Equipment Manufacturers (OEMs) for new engines and vehicles. This certification affirms that the entire engine family meets the applicable exhaust and evaporative emission standards for a given model year. The CoC is the foundational approval for mass-produced, factory-built products intended for sale in California. OEMs seeking a CoC must submit extensive technical data on their engine family design and durability.
Executive Order (EO)
The EO is the primary approval mechanism for aftermarket parts, add-on emission control devices, and modifications to existing vehicles or equipment. An EO is a formal exemption, issued by CARB’s Executive Officer, that certifies the aftermarket product does not reduce the effectiveness of the original vehicle’s emission control system. For example, a manufacturer of a performance air intake system must obtain an EO to prove the part maintains regulatory compliance. Aftermarket manufacturers seeking an EO must focus their submission on demonstrating no adverse effect on the existing emissions system.
Step-by-Step Guide to the CARB Application Process
The procedural journey toward certification begins with the manufacturer registering with CARB. This registration establishes credentials and assigns a staff engineer to coordinate the process. Manufacturers are encouraged to engage in a pre-submission consultation to review their strategy and testing plans.
The application process follows these steps:
- The manufacturer prepares the application package, including the required fee invoice and technical documentation. Most applications are submitted electronically through systems like E-Cert.
- The formal submission marks the start of the CARB Review Phase, where staff examine the application for completeness and technical accuracy.
- Emissions Testing Protocol must be carried out by a CARB-recognized laboratory. The lab performs official emissions tests to measure pollutants like hydrocarbons, nitrogen oxides, and carbon monoxide. The certified test report confirms the product meets established emission limits.
- CARB staff verify the completeness and content of the application, including engine family definitions, emissions control systems, and durability data.
- Upon a satisfactory finding, the agency issues the Certificate of Conformity or the Executive Order, which legally permits the sale and use of the product in California.
Essential Documentation and Technical Requirements
A successful certification application hinges on the submission of technical documentation demonstrating the product’s compliance. Manufacturers must include detailed Emissions Data Sheets, which contain the raw results from the emissions testing conducted by the accredited laboratory. This data must clearly demonstrate that the certified engine family or product falls below the applicable regulatory limits for all measured pollutants.
For new engines, a Durability Demonstration Plan is required. This plan outlines how the manufacturer proves the emissions performance will be maintained over the product’s full useful life. It often involves submitting Deterioration Factors (DFs), which are multipliers used to project the engine’s emissions performance at maximum mileage or operating hours.
The application package requires several documents:
- Detailed description of the emission control system.
- Production quality control plan.
- Installation Instructions (for aftermarket parts seeking an Executive Order).
- Warranty information.
- Proposed emissions labeling to be affixed to the certified product.
Maintaining Compliance After Certification
Receiving certification initiates a period of ongoing compliance. Manufacturers are required to maintain records related to the certified product for a specified period, covering production, quality control testing, and any subsequent modifications made to the design.
Manufacturers must report changes or modifications to the certified product. Any non-minor change to the engine design, emission control hardware, or production methods may necessitate a review or a new application to ensure continued compliance with the original standards. This oversight ensures that products sold remain consistent with the tested and approved design.
CARB may conduct ongoing quality assurance testing and audits to verify that production models match the original certified specifications. Failure to maintain required records, report significant changes, or uphold emission standards can result in enforcement action, including substantial fines, product recalls, or the revocation of the certification.