NOTE: This document does not constitute legal advice. Only the Minnesota Pollution Control Agency (MPCA) can issue authoritative guidance on the CARB regulations. MADA sent a draft of these FAQs to the MPCA for review. The MPCA declined to provide any substantive feedback.
Q1. What does CARB certification mean?
A1. CARB certification indicates that a vehicle meets the emissions standards established by the California Air Resources Board (CARB). Vehicles with emissions systems approved for use in all 50 states are often CARB certified. However, vehicles labeled as meeting the "federal" standard, "federally certified," or compliant with EPA standards are not CARB certified.
Q2. Are all vehicles sold in Minnesota required to have CARB certification?
A2. No, only new model year (“MY”) 2025 vehicles are required to have CARB certification. New MY 2024 (or earlier) vehicles do not require CARB certification. Heavy duty trucks do not require CARB certification. Additionally, the following vehicles do not require CARB certification:
• a used motor vehicle;
• a new motor vehicle sold to another dealer;
• a new motor vehicle sold to be wrecked or dismantled;
• a new motor vehicle sold for registration out-of-state; and
• a new motor vehicle purchased and registered in another state by a person who is a resident of that state and who subsequently establishes residency in Minnesota.
Upon registering the new motor vehicle in Minnesota, the person must provide evidence to the MPCA of the previous residence and registration. For a full list of exempt vehicles, please refer to Minn. R. 7023.0250, subp. 2.
Q3. How can I tell if the new vehicles I order from my supplier have CARB certification?
A3. Your manufacturer should be able to tell you how to order Minnesota compliant vehicles properly when you place orders for MY 2025 inventory. When the delivery is received, there are two methods for verifying that a vehicle is CARB certified:
• The Manufacturer’s Certificate of Origin (MCO) or Manufacturer’s Statement of Origin (MSO). For a CARB certified vehicle, this document usually indicates that the vehicle is certified to or meets emissions standards for either all 50 states or the State of California. If the certification language states that the vehicle is “federallycertified, ” or certified to “federal standards, ” or “Tier II” standards alone, the vehicle is not CARB certified. If there is no language on the MCO/MSO indicating the emission certification, the vehicle may still be CARB-certified. CARB-certification must be confirmed in another manner.
• The Vehicle Emissions Control Information (VECI) sticker mounted in the vehicle’s engine compartment confirms CARB certification if it has language indicating that the vehicle’s emissions systems comply with California emissions requirements or requirements for all 50 states. If the language states that the vehicle is “federally certified” or certified to “federal standards” or “Tier II” standards alone, the vehicle is not CARB certified.
Q4. Do daily rentals and leased vehicles require CARB certification?
A4. Yes; however, you may rent or lease non-CARB certified vehicles to the general public if the vehicle is registered and principally operated outside of Minnesota.
Q5. Can my dealership sell new non-CARB certified MY 2025 vehicles to non-Minnesota residents?
A5. Yes, so long as the customer purchasing the vehicle does not reside in a state that also requires CARB certified vehicles. While a non-CARB certified MY 2025 vehicle is on your lot, you may wish to prominently mark it as not available for sale to Minnesota residents.
Q6. Is my dealership allowed to transfer non-CARB certified vehicles to another dealer?
A6. Yes. CARB certification is not required for “a new motor vehicle sold to another dealer.”
Q7. Can I accept a customer trade-in of a non-CARB MY 2025 vehicle?
A7. Yes. In this case, the vehicle would be considered a used motor vehicle and therefore does not require CARB certification.
Q8. Can I acquire new non-CARB MY 2025 vehicles through a dealer trade with an out- of-state dealer (located in a non-CARB state)?
A8. Yes, but without further verification, you may only sell that vehicle to (1) a customer located in a non-CARB state or (2) another dealer. Given that some manufacturers are only producing CARB-certified MY 2025 vehicles, many out-of-state dealers located in non-CARB states likely have CARB-certified vehicles available for trade. Accordingly, before you engage in a dealer trade, it is advisable to ask the out-of-state dealer to send you a copy of the vehicle’s MCO/MSO or VECI sticker. If the MCO/MSO or VECI sticker provides that thevehicle is certified for use in all 50 states or California-certified, then you may proceed with the trade and sell that vehicle to a Minnesota customer.
Q9. Will CARB certification be required for model years after 2025?
No, unless the Walz administration adopts California’s recent revisions to its emissions laws.
Q10. What are the penalties for a dealer failing to comply with CARB emissions regulations?
A dealer who fails to comply with the CARB emissions regulations is subject to the following penalties: criminal prosecution (misdemeanor offense); action to recover civil penalties (up to $15,000 per day of violation); injunction; action to compel or cease performance; or other appropriate action.