Back to the Zero-Emission Forklift Regulation fact sheet page (//ww2.arb.ca.gov/zero-emission-forklift-fact-sheets)

What is the Zero-Emission Forklift Infrastructure Construction Delay Extension?

The Zero-Emission Forklift Infrastructure Construction Delay Extension is available to address situations where a Fleet Operator to remain in compliance with the Zero-Emission
Forklift (ZEF) regulation if there are delays during the construction of charging or fueling infrastructure. Fleet Operators may request this extension if they experience a construction delay due to circumstances beyond their control.

What criteria qualifies for the Zero-Emission Forklift Infrastructure Construction Delay Extension?

To qualify for the Infrastructure Construction Delay Extension, a Fleet Operator must have a construction related delay for a project where the construction permit was issued one year prior to the compliance date. In addition, the following criteria must be met:

1. A construction delay is anticipated as a result of any of the following circumstances beyond the Fleet Operator’s control:
   1. change of a general contractor;
   2. delay in manufacture and shipment of zero-emission charging or fueling infrastructure equipment;
   3. delay in the delivery of necessary building materials;
   4. delays obtaining power from a utility;
   5. delays in construction of ZEF-related storage or shelter;
   6. delays due to unexpected safety issues on the project;
   7. delays obtaining permits;
   8. delays due to landlord-tenant issues regarding the installation of charging or fueling infrastructure;
   9. delays due to discovery of archeological, historical, or tribal cultural resources; or
   10. delays due to natural disasters.
2. The Fleet Operator or other entity responsible for infrastructure at the operating location, has entered into a contract for the installation of the charging, fueling, and/or required physical infrastructure, and a construction permit has been obtained at least one year ahead of the compliance date, or the Infrastructure Site Electrification Delay Extension expiration date, if applicable.
3. The Fleet Operator has deployed the maximum number of ZEFs that can be supported by existing infrastructure.
4. If operating at multiple sites, the Fleet Operator has relocated Forklifts to maximize compliance across its sites.
5. The Fleet Operator has submitted information in Section 3007(b)(3)(A)(4) prior to the upcoming compliance date.

Are there any additional requirements after being approved for an Infrastructure Construction Delay Extension?

Yes. After approval, all Large Spark Ignition (LSI) Forklifts covered by the extension must be labeled with their California Air Resources Board (CARB) issued Equipment Identification Number (EIN) in accordance with Section 3010.

How long will the Infrastructure Construction Delay Extension last and what if I need to extend it longer?

An Infrastructure Construction Delay Extension may be granted for up to two years after the compliance date per project. This extension cannot be renewed.

What should I do if a permit was not issued at least one year ahead of the compliance date?

If a construction permit was not issued at least one year ahead of the compliance date, the Fleet Operator shall demonstrate that the construction permit application, including all necessary architectural and engineering plans, was submitted at least 18 months prior to the upcoming compliance date. For fleets experiencing delays due to landlord-tenant issues regarding the installation of charging or fueling infrastructure, in lieu of a construction permit or construction permit application, the Fleet Operator demonstrates that necessary architectural and engineering plans were completed at least 18 months prior to the upcoming compliance date.

How do I apply for the Zero-Emission Forklift Infrastructure Construction Delay Extension?

Make sure the fleet information reported in DOORS is up to date. Extension requests may be submitted to CARB by email to zeforklifts@arb.ca.gov (mailto:zeforklifts@arb.ca.gov). The following information is required for fleets applying for the Infrastructure Construction Delay Extension:

1. Entity information specified in Section 3009(b)(1);
2. For each LSI Forklift required to be phased out by the upcoming compliance date:
   1. Forklift information as specified in Section 3009(b)(2) or EIN, as applicable;
   2.  Primary operating location address
3. Documentation showing the delay is a result of any of the circumstances provided in Section 3007(b)(3)(A)1.a;
4. A letter to the Executive Officer from the Responsible Official with the following:
   1.  The reason for the delay;
   2. The estimated completion date of the project; and
   3. Documentation supporting the reason for the delay from the licensed contractor performing the work, related utility, building department, or other organization involved in the project
5. For Fleet Operators not experiencing delays due to landlord-tenant issues regarding the installation of charging or fueling infrastructure, documentation showing the executed contract for the infrastructure installation with necessary construction permit showing a permit-issue date that is at least one year prior to the upcoming compliance date, or the Infrastructure Site Electrification Delay Extension expiration date, if applicable;
6. For charging infrastructure construction delays, the Fleet Operator’s plan for charging ZEFs, including information on the number of chargers to be installed per Forklift, the types of chargers to be installed, and the integration of charging into the operation’s workflow;
7. For multiple sites where Forklifts are operated, maximized the amount of ZEFs deployed at the other locations to facilitate the relocation of compliant LSI Forklifts to the location subject to the construction delay;
8. Copies of the executed ZEF purchase or lease agreement(s).

After reviewing the information, CARB staff will update the compliance status in DOORS to reflect the Infrastructure Construction Delay Extension.

A draft template application can be found below. Use of the template is encouraged and may help submit a complete application. When filling out the application please refer to the regulation language for all requirements.

ZEF Construction Delay Extension Request Template (//ww2.arb.ca.gov/sites/default/files/2026-01/TEMPLATE%20ZEF%20Infrastructure%20Construction%20Delay_0.docx)

This document is provided to assist regulated entities in complying with the ZEF regulation. In the event any discrepancy exists between this document and the ZEF regulation, the regulatory text of the ZEF regulation applies.