Demystifying the Changes to California’s Smog Law for 2025

The Beginning of the 2025 Smog Law Changes

Due to a history of severe air pollution generated by vehicle emissions, California has had a very stringent emission control system in place for many years, including various requirements for smog checks. Different vehicles are subject to various exemptions and procedures but, generally speaking, if you live in the greater Los Angeles region of California or in another area where smog is prevalent, your vehicle will be affected. Generally speaking, vehicles are subject to the state smog certification check every two years and the vehicle has to pass a smog check before it can be registered.
The California Air Resources Board and the United States Environmental Protection Agency began crafting changes to smog certification on smog compliance and certification for a new cleaner burning cleaner burning engine that were designed to comply with the California Clean Air Act. A series of amendments to the California Code of Regulations (CCR) Title 13, Sections 1960.1, 1977, 1960.1 and 2033 adopted revisions to smog certification and compliance requirements for new engine manufacturers . The amendments establish a different certification process and certification test requirements and establish a California-only emission-control system designed to reduce emissions of certain air pollutants. In short, this has resulted in new engine compliance and requirements for new 2025 vehicles.
It also changes the general requirements for aftermarket parts, sales disclosures for engine manufacturers, labeling requirements, and labeling and emission control system installation and use requirements and exemptions. In particular, Section 1960.1 of the CCR now creates general requirements for certifying aftermarket engine parts for on-road vehicles.
The most significant law change was the creation of a new General Certificate of Compliance for Engine Manufacturers beginning with model year 2025. Unlike previous requirements, there will be a Bi-national Regional Technical Forum that sets standards for all North American vehicles. Currently, mechanics and dealerships in California are tasked with keeping up on the amendments and changes to smog compliance, which are quite frequent and difficult for the private mechanic to maintain.

Details of the Changes to Vehicle Emissions

In 2025, the new smog rule will go into effect and bring a series of changes that impact how cars are sold for the next three decades. Even though the new law has not yet taken effect, car manufacturers are already devising new technologies and features that will meet or exceed the 2025 standards. The more stringent requirements will have the following effects:
· New Sales. The rule further tightens standards on vehicle emissions from model year 2015 through 2025. When the measure passes, the CARB will require an emissions limit of 3.4 grams per mile for all new cars. A standard of 1.5 grams per mile will apply to light trucks.
· Existing Cars. The new 2025 emissions standards also strengthen the expected lifespan of pre-existing vehicles and trucks. Government and manufacturers must bring the yearly emissions down from 3.4 to 1.5 grams per mile. By 2035, all vehicles and trucks must meet a 1.5 gram per mile limit. If approved, consumers will remain safe from usual emissions for five years longer than previously anticipated.
· Updated Features. Changes in the rule will alter common features such as the regulations on particulate filters. Manufacturers must meet the new 2025 standards on all catalysts from the model year 2015. The heat treatment expectations remain the same, but the melter test and age bench requirements will change. The new rule will also require a reduction of the water vapor test to 8.7 percent oxides of nitrogen emissions.
· United States EPA Requirements. The United States EPA proposes adopting the California program as it stands. California has over 53,000 OEM-assigned recalls that are outstanding due to faulty emissions equipment. The automakers that attempt to sidestep the California program will need to implement their own national recall, which may be a significant expenditure on the manufacturer’s part. The United States EPA requires the California program to reduce the wholesale margin by one percent in 2025.

Car Makers and The 2025 Smog Law

The new 2025 smog law requirements, the "Advanced Clean Car" program, will pose unique issues to car manufacturers, who will need to adopt new compliance strategies to ensure that they remain ahead of the curve and thus avoid liability for noncompliance with smog rules and regulations.
Enforcement and Penalties
By its plain terms, the smog law states that "[i]n general, the smog check program shall not apply to a motor vehicle which has an approved emission control system for which the manufacturer has established a legally enforceable warranty program . . . [consistent] with [Air Resources Board] regulations." If the smog check program applies, however, manufacturers can expect that the ARB will meaningfully enforce the program, given the increased revenue stream that the 2025 regulations will provide to state and local governments.
It is worth noting that California enacted several new enforcement and penalty provisions as part of the Smog Check Repair Assistance Program. These include provisions that allow ARB and Bureau of Automotive Repair ("BAR") staff to enter into private property to inspect vehicles for emissions compliance. CVSP Inspectors can also issue citations to private property owners, which, if not corrected within 35 days, can lead to a $2,500 fine.
Compliance Strategies for Manufacturers
For manufacturers and dealers, the first step towards compliance with new emission control systems for the 2025 smog law requirements will be to stay tuned for ARB’s new emissions test and certification procedures. As is currently proposed, starting in model year 2016, manufacturers will need to develop and propose new certification procedures in their 2018 Annual Certification Report and must propose new certification procedures beginning with model year 2019.
Once CARB develops the new certification requirements, manufacturers will also be able to begin developing new emisson control systems for the 2025 smog law requirements.

Consequences to California Drivers

While the upcoming stringent smog regulation changes will not take effect until 2025, California residents and car owners would be wise to begin their efforts to plan for this legal alteration in state law. The most obvious way in which this alteration in California law will affect the residents of this state will be with regard to vehicle compliance. The new smog standard has been set at an average of 43 grams of smog forming compounds per mile. As the laws evolve, certain models of vehicles will not meet the new standard and will be required to be retrofitted. These non-compliant vehicles are typically older models that have a higher chance of breaking down. The equation very much involves the costs of maintaining old vehicles versus the costs of purchasing or maintaining new vehicles.
For all vehicles, it will become necessary to invest in constant monitoring, frequent replacement of parts, and increased maintenance costs. In addition, the cost to upgrade a vehicle to meet the smog standards are higher than the cost of maintaining an older vehicle. This might theoretically make the maintenance of an older vehicle more advantageous to the average California resident.
The up-front benefits of the new emissions standards would be cleaner air. While it is not possible to tell what the health effects may be, cleaner air is something almost everyone can agree on, but especially residents of California with asthma, severe allergies and other respiratory problems.

Responding to the 2025 Smog Law

The new smog standards are expected to create a big drop in the health costs related to air pollution in the state , according to a recent study by the California Air Resources Board and UCLA. "The 2025 Smog Check Program Improvements" report predicts that the state will reap $14.4 billion in public health benefits from these changes.
The California desert will see some of the largest gains where ozone is the major concern and for which the new rules should create a 35% reduction in emissions. The San Francisco Bay Area is pegged to see the second largest overall benefit.
UCLA professors also predict an 85% reduction in smog levels by 2035 with the more stringent smog checks in place. This reduction could end up saving the state $12.9 billion in health care costs in 15 years. Half of these savings are related to hospitalizations for asthma, respiratory infections, and heart disease, according to the study.

Health and Environmental Effects

To help consumers and businesses navigate the upcoming changes under the California Smog Check Program, several resources are available. First, individuals can keep abreast of any announcements and guidelines on the California Bureau of Automotive Repair (BAR) website. This page contains the most up-to-date information regarding proposed Smog Check changes, as well as a compilation of all relevant California laws and regulations that could be impacted by the 2025 Smog Check change. There are also many ways that the government incentivizes consumers to consider switching to cleaner transportation options. Currently, the Clean Vehicle Rebate Project (CVRP) offers state rebates on new, clean vehicles. The CVRP program is available for battery electric and plug-in hybrid electric vehicles, hydrogen fuel cell vehicles, and neighborhood electric vehicles. The CVRP program aims to boost demand for low-emission and zero-emission vehicles and reduce air pollution in urban areas in California. The CVRP program is funded by the California Air Resources Board (CARB) and is administered by the Center for Sustainable Energy. These incentives are in addition to the federal electric vehicle tax credit. In addition to the CVRP, the California Clean Fuel Reward provides rebates to encourage Californians’ use of low-carbon fuels, electric vehicles, and plug-in hybrids. CARB administers the program jointly with Pacific Gas and Electric Company (PG&E) and Southern California Edison (SCE). Consumers interested in participating in the program must be a customer of PG&E or SCE and have the vehicle registered in California. The program offers a $1,500 rebate for all battery electric vehicles, plug-in hybrid electric vehicles, and fuel cell electric vehicles, and an additional $500 rebate for low income consumers. Counties set to be impacted by the 2025 Smog Check changes can begin implementing strategies to encourage residents to switch to zero emissions vehicles. For example, jurisdictions may implement charging stations for electric vehicles as a strategy to promote zero emissions transportation. At the same time, counties may offer incentives to promote rideshare programs and convenient public transportation options. As all counties in California work towards achieving a 100% zero emissions goal by 2045, transitioning to cleaner transportation options is vital.

The Future and Reactions

Looking beyond 2025, the future of California’s smog regulations will likely continue to evolve and expand. With goals to reduce greenhouse gas emissions and improve air quality, the state is poised to tighten its restrictions and push for advancements in emissions control technology. Such changes will also align with federal initiatives and other state regulations aimed at combating air pollution and climate change.
In the automotive industry, the response has been generally positive, with manufacturers expressing their willingness to comply with the new standards. Automotive manufacturers see this as an opportunity to invest in cleaner technologies and achieve significant reductions in smog-producing emissions.
Environmental advocates have praised the 2025 amendments to the smog regulations, seeing them as an important step towards a sustainable future. They believe that the stricter standards will have a positive impact on air quality, public health, and the environment . These groups continue to push for even stricter limits and more innovative technologies, urging lawmakers to require increased environmental stewardship from vehicle manufacturers and consumers alike.
Despite the support for the new laws, there are concerns over the potential economic impact. Smaller dealerships worry about the additional costs of maintaining compliance, while manufacturers are unsure of the long-term effects on the industry. Some industry experts argue that increased transparency and clarity in these regulations can help mitigate potential issues.
Ultimately, how California chooses to move forward with its smog regulations will set a precedent for the rest of the country. Other states often look to California when creating their own vehicle emission laws, so there is a good chance the changes will have ripple effects nationwide. The future of California’s smog laws beyond 2025 will likely be determined by an ongoing dialogue between the government, industry leaders, consumers, and environmental advocates.