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 Operational Extension?

The Operational Extension is available to allow a Fleet Operator to remain in compliance with the Zero-Emission Forklift (ZEF) regulation if there is no commercially available ZEF that can meet the needs of an operation currently served by a Large-Spark Ignition (LSI) Forklift required to be phased out by the upcoming compliance date. Fleet Operators may request this extension to continue operating the LSI Forklift required to be phased out until a sufficient ZEF model becomes available or until the extension renewal date.

What criteria qualifies for the Operational Extension?

To qualify for the Operational Extension, the following criteria must be met:

1. The Fleet Operator has successfully demonstrated, through documentation and information provided pursuant to Section 3007(b)(4)(D)1, at least one of the following:
   1. There is no commercially available ZEF model that can be used in place of the LSI Forklift to be phased out by the upcoming compliance date without causing a greater demonstrable safety risk to the operator, other employees, or the facility in which the Forklift operates;
   2. The LSI Forklift to be replaced is dedicated to a push-pull type of operation; the primary attachment for the Forklift is specifically designed to push and pull, rather than lift; and there is no commercially available ZEF model capable of performing the work adequately; or
   3. There is no commercially available ZEF model capable of fulfilling operational needs based on published specifications (e.g., Rated Capacity, drawbar pull, etc.).
2. The LSI Forklift required to be phased out by the upcoming compliance date is a 2013 or subsequent Model Year (MY) Forklift.
3. The LSI Forklift is dedicated to the operation for which the Fleet Operator is requesting an Operational Extension. In other words, the LSI Forklift shall not be used for any operation not covered by the Operational Extension.
4. The Fleet Operator has managed operations such that the need for Operational Extensions has been minimized.
5. The Fleet Operator has submitted the information in Section 3007(b)(4)(D)1 prior to the upcoming compliance date.

Are there any additional requirements after being approved for an Operational Extension?

Yes. After approval, all 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 Operational Extension last and what if I need to extend it longer?

1. An Operational Extension granted by the Executive Officer for an extension of an upcoming compliance date is valid for one year from the applicable compliance date. This extension can be renewed until a suitable ZEF model becomes available. Extension renewals are also valid for one year.
2. An extension granted by the Executive Officer for replacement of an LSI Forklift prior to the compliance date shall be valid up to the compliance date of the replaced LSI Forklift. For example, if a MY 2022 Class IV LSI Forklift with Rated Capacity of 12,000 pounds or less in a large fleet is replaced with a MY 2029 Class IV LSI Forklift per this extension, the replacement MY 2029 Class IV LSI Forklift would need to be phased out by the compliance date of January 1, 2033, which is the compliance date for the MY 2022 Class IV LSI Forklift. Renewal of the extension is subject to Section 3007(b)(4)(B)(1).

Which type of forklift qualifies as a replacement for the Operational Extension?

The Operational Extension may be applied to replace an LSI Forklift with another LSI Forklift, pursuant to Section 3007(b)(5), even if the replacement needs to be made years in advance of the upcoming compliance date. The replacement LSI Forklift would be allowed even when its acquisition, possession, or operation would otherwise be prohibited by Sections 3002(a), 3002(b), 3003(a), 3003(b)(1), and 3005(a).

Can I replace my LSI Forklift covered by an Operational Extension with another LSI Forklift? 

Yes. Per Section 3007(b)(5), subject to the following conditions, a Fleet Operator may acquire a 2026 MY or newer LSI Forklift to replace an LSI Forklift covered by an Operational Extension that has been removed from the fleet. 

1. The LSI Forklift being replaced must be covered under a valid Electrification Delay Extension at the time of replacement.
2. The LSI Forklift being replaced must be removed from the Fleet within 30 calendar days of the delivery of the replacements LSI Forklift.
3. Prior to taking delivery of the replacement LSI Forklift, the Fleet Operator shall provide the following to the Executive Officer (EO):

1. EIN of Forklift covered by Infrastructure Site Electrification Delay Extension
2. The purchase or lease agreement identifying the make and model of the replacement LSI Forklift

4. The Fleet Operator shall provide the following to the EO within 30 calendar days of delivery:

1. For replacement LSI Forklift, Forklift info specified in Section 3009(b)(2), as applicable
2. For the LSI Forklift being replaced, documentation that Forklift has been removed from service, such as sales contract or certificate of destruction

5. Any LSI Forklift acquired pursuant to an Infrastructure Site Electrification Delay Extension shall be phased out of the fleet by the date said extension expires or otherwise becomes invalid.

How do I apply for a Zero-Emission Forklift Operational 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 Site Electrification Delay Extension:

1. 1. Entity information specified in Section 3009(b)(1);
   2. For each LSI Forklift required to be phased out pursuant to Section 3006 during the term of the extension:
      1. Forklift information specified in Section 3009(b)(2) or EIN, as applicable; and
      2. Primary operating location address;
   3. A detailed description of the operation in which the applicable LSI Forklifts operate, including site maps with operating areas, Forklift storage areas, and areas of concern identified; a description of the potential operational and safety issues; a description of the nature of the work or duty cycle; a description of the operating environment; and a detailed explanation of how the need for Operational Extensions has been minimized;
   4. A detailed description of the required characteristics a Forklift must have in order to perform the work effectively and/or safely;
   5. An explanation as to how the Fleet Operator will manage applicable LSI Forklifts such that they only perform the operation covered by the Operational Extension;
   6. A comprehensive market evaluation and determination using engineering judgement that demonstrates that no available ZEF models of similar configuration as the LSI Forklift to be phased out is capable of safely operating as a replacement, considering the duty cycle and operational characteristics (evaluation shall be completed based on ZEF model availability. For replacements prior to the applicable compliance date, the ZEF model availability evaluation window shall be within the six-month period immediately preceding the application submittal date. For extensions of the applicable compliance date, the ZEF model availability evaluation window shall be within the six-month period immediately preceding the upcoming compliance date);
   7. Statements or information from applicable Forklift manufacturers, Dealers, insurance companies, and/or other entities substantiating the operational or safety issues cited in the extension request; and
   8. As applicable, Forklift specification sheets, copies of warranty conditions, leasing criteria, and/or other documentation and information supporting the request.

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 Operational Extension Request Template (//ww2.arb.ca.gov/sites/default/files/2026-01/TEMPLATE%20ZEF%20Operational.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.