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Internal Combustion Engines: Emissions Regulations for Small Off-Road Engines

Internal Combustion Engines: Emissions Regulations for Small Off-Road Engines

OEMs and internal combustion engine (ICE) manufacturers currently face their most rigorous environmental and emissions compliance burden. And the applicability and extent of the regulations have only increased in recent years, now extending to bans on small off-road engines (SOREs).

With the first ban already enacted by California via its Air Resources Board, more governments at all levels have begun or are considering following suit. The article below explores these new regulations and what the changes mean for OEMs and ICE manufacturers—particularly those still considering whether to electrify their products. 

CARB’s Off-Road Engine Regulations

Toward the end of 2021, the California Air Resources Board approved new regulations (AB1346) for all SOREs. The new California emissions standard takes effect in 2024 and prohibits selling any new equipment under 25 hp (or 19 kW) if it does not achieve “zero emissions” during operation.

AB1346’s ban presents OEMs and ICE manufacturers with a substantial challenge. Regulations and professional and consumer sentiment have all reached a point that OEMs risk losing considerable market share across OPE, agriculture, construction, material handling, and other industries if they don’t embrace alternatives to SOREs.

And OEMs directly transfer this challenge onto ICE manufacturers that may lose essential contracts if they don’t provide viable alternatives like electric drive. OEMs need a solution, but ICE manufacturers bear a larger burden of providing it.

Understanding “Zero Emissions”

Per California’s definition, “zero emissions” refers to vehicles, machinery, or equipment “that produces no emissions from the onboard source of power.” As a result, electric motors and hydrogen fuel cell technology remain the only recognized zero-emission options currently available.

The California zero-emission vehicle program does not refer to the power source’s presale emissions (e.g., manufacturing, transportation) or disposal, nor does it relate to providing the energy necessary for operation (e.g., battery charging). It strictly applies to the equipment’s operation. However, with the continuous adoption of sustainable energy sources (e.g., wind, solar), this equipment can genuinely achieve zero emissions between sale and disposal.

CORE Voucher Program and Green Incentives

California is financially incentivizing OEMs and professionals to choose electric in addition to restricting small ICE engines. By facilitating the sale of zero-emissions, SORE-powered equipment via subsidies, California is helping alleviate OEM’s electrification and go-to-market costs while aiding consumer and professional adoption.

And these incentive programs only benefit ICE manufacturers as well, helping to protect the emerging market’s existence. With a more developed market and better revenue guarantees, ICE manufacturers can confidently invest in zero-emissions solutions to meet OEMs’ new (and increasing) demand for alternatives.

For example, through the Clean Off-Road Equipment (CORE) Voucher Program in partnership with CALSTART, $27 million was made available for consumers to purchase zero-emission landscaping equipment. As of March 2023, $17.2 million remains available.

The qualification criteria for this program involve:

  • For OEMs – Eligible equipment must be:
    • Newly purchased equipment (or new conversion kits)
    • Not corded
    • Covered by a two-year warranty protecting the equipment, battery, and charger
    • Sold through approved CORE dealers
    • Found in the CORE Eligible Equipment Catalog
    • Approved by CARB following an application process
  • For dealers – Dealership voucher eligibility requires:
    • Selling CORE-approved equipment
    • A perfect score on the CORE Dealer Training Quiz
    • Provide requested documents (e.g., registration form, OEM authorization)
    • Attend an information session
  • For professional landscapers – Equipment users looking to participate must:
    • Operate a professional landscaping business, small business, microbusiness, or sole proprietorship
    • Purchase CORE-eligible equipment through an approved dealer
    • Submit voucher request information to the dealer

Significance of CARB Action

OEMs and ICE manufacturers should always pay attention to CARB regulatory developments because they commonly pave the way for the rest of the US. The board was founded in 1967 to address smog and other airborne health hazards resulting from burning carbon-based fuels and other industrial processes.

When the Clean Air Act passed in 1970, it federally recognized CARB. More importantly, the legislation permitted CARB to establish stricter regulations than the newly formed Environmental Protection Agency’s nationwide standards. This was so that it could contend with California’s unique circumstances regarding population, industrial density, topography, and climate that created the US’ worst air pollution.

Since then, CARB has commonly introduced regulations that eventually become adopted by other states or at the federal level. And in the interim—partially due to California’s market size—OEMs generally find it easier and more cost-effective to maintain economies of scale by adhering to one standard. To ensure compliance in the US, they typically choose CARB’s.

Other US Cities and States Following CARB’s SORE Regulations

Maintaining CARB’s past trends, other governments are joining the list of which states have adopted California emissions standards:

  • New YorkSenate Bill S7462A would require all in-state sales of new lawn equipment to be zero emissions by 2027; as of March 2023, this bill remains active.
  • IllinoisSB3313 would have prohibited the sale or use of gas-powered leaf blowers beginning in 2022, but the bill’s last status was “session sine die”—or an adjournment without a specified date to reconvene—at the end of the state’s 2021 congressional session.
  • Michigan – The introduction of HF1715 in February 2023 would prohibit the sale of new gas-powered OPE under 25 hp beginning in 2025. The specific types of banned equipment listed in the bill are:
    • Lawn mowers
    • Leaf blowers
    • Hedge clippers
    • Chainsaws
    • Lawn edgers
    • String trimmers
    • Brush cutters

The Future of SORE Manufacturing

Although California’s and similar legislation targets OEMs and dealers, ICE manufacturers must contend with one of the most difficult challenges: production. Those who haven’t started investigating SORE alternatives or don’t plan to may have a hard time maintaining their current OEM contracts or market share.

OEMs must determine when they intend to electrify their gas- and diesel-powered SORE equipment rather than if.

But with their strategies restricted by regulations and meeting demand shifts, OEMs will be seeking new partners if their current ones can’t facilitate their products’ electrification. This means electric drive and hydrogen fuel cell research and development is now mandatory. Further complicating ICE manufacturers’ situation is the entry of new competitors that exclusively focus on these alternative options rather than facilitating electric drive transitions end-to-end.

But electrification actually represents a significant opportunity for those manufacturers that do pivot to facilitating both sides of that end-to-end transition. Working directly with OEMs, ICE manufacturers can help plan electric product rollouts in a way that minimizes the other design and manufacturing challenges.

For example, ICE manufacturers can release SORE and electric drive options with comparable sizes. This would enable OEMs to sell both gas- or diesel-powered equipment alongside electric options without significant alterations to product design and production. These types of value-add or cost-reduction strategies will be crucial for ICE manufacturers looking to not only survive but thrive amidst electrification.

How Delta-Q Can Help

ICE manufacturers and OEMs looking to electrify their products must collaborate with other partners to ensure seamless integration with existing offerings or other systems in new designs. Meeting regulatory requirements, market demand, and current hydrogen limitations positions electric drive as the primary path forward for SORE alternatives.

As a leader in battery charger design, development, and testing, Delta-Q Technologies will help guide partners through their electrification and strategic decision-making down to specific considerations (e.g., recharge time, charger connector design). This insight will be invaluable for ICE manufacturers and OEMs’ frictionless transition.

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Vikram Anandan
Written By:

Vikram Anandan, Business Development Manager

Vikram Anandan is a Marine Corps veteran with 10 years of experience in the battery and charging industry and joined Delta-Q in 2022. Specializing in custom solution applications, he is a trusted authority in driving business growth, delivering tailored battery and charging solutions and identifying new market applications.

Leveraging his military background, Vikram brings a unique perspective and unwavering commitment to excellence. He combines deep technical knowledge with business acumen to develop and implement custom battery and charging solutions that optimize performance and meet specific client needs. With comprehensive knowledge of the latest technologies and industry trends, Vikram navigates complex challenges to ensure solutions adhere to regulations and exceed expectations. He prioritizes exceptional customer service, actively listening to client needs and providing tailored recommendations for superior outcomes.