TRU Compliance Information

This page last reviewed November 29, 2017


The public may use this link to search ARB’s Equipment Registration (ARBER) system to check the compliance status of TRUs and TRU generator sets and provide comments or provide tips on violations about specific TRUs. ARB will monitor these comments/tips and follow up with enforcement action, if warranted.  Or, you may report noncompliant TRUs to ARB's Complaint Hotline.

TRU ATCM Home Page Compliance Schedule Compliance Assistance
TRU Compliance Extensions Resources for Carriers, Brokers, Forwarders, Shippers and Receivers 100% Compliant Carrier List


Compliance Schedule

Current Schedule:
December 31, 2016
MY 2009 engines must meet ULETRU.  MY 2002 engines that met LETRU by the end by 2009 must meet ULETRU
December 31, 2017
MY 2010 engines must meet ULETRU.  MY 2003 engines that met LETRU by the end of 2010 must meet ULETRU
December 31, 2018
MY 2011 engines must meet ULETRU.  MY 2004 less than 25 hp engines that met LETRU in 2011 must meet ULETRU
December 31, 2019
MY 2012 engines must meet ULETRU.
End of each year Must meet ULETRU by the end of the 7th year after the engine model year if new engine standard doesn't meet ULETRU.

Expired Deadlines:
July 31, 2009 All California-based TRUs must be registered with ARB.  Initial Operator Report must also be submitted by this date.
August 2009 ARB staff began field enforcement for registration of all California-based TRUs.
December 31, 2009 Model year (MY) 2001 and older and MY 2002 engines must meet the Low-Emission TRU (LETRU) In-Use Performance Standard.
January 2010 In-Use Performance Standard enforcement began.
December 31, 2010 MY 2003 engines must meet either LETRU or the Ultra-Low-Emission TRU (ULETRU) In-Use Standard (Enforcement begins March 31, 2011)
December 31, 2011 MY 2004 engines less than 25 hp must meet LETRU or ULETRU.  MY 2004 engines 25 hp and greater must meet ULETRU
December 31, 2012 MY 2005 engines must meet ULETRU.
December 31, 2013 MY 2006 engines must meet ULETRU.
December 31, 2014 MY 2007 engines must meet ULETRU.
December 31, 2015 MY 2008 engines must meet ULETRU.  MY 2001 & older engines that met LETRU by the end of 2008 or 2009 must meet ULETRU

Please be aware that 30 days after compliance with the in use performance standards, compliance information must be entered into ARBER for each California-based unit. Operator Reports for California terminals where TRUs operate must also be updated to add new IDNs within 30 days of the unit coming under the control of the operator.  IDNs must be affixed to both sides of the TRU housing (see TRU Advisory 08-10) within 30 days of receipt. Additional information is available in TRU Advisory 08-15.

New TRU Models that Meet the ULETRU In-Use Performance Standard.  
TRUs that meet the ULETRU In-Use Performace Standard have no further in-use standard requirements.  
CAUTION:  Current TRU models equipped with less than (<) 25 horsepower (HP) engines do NOT meet ULETRU and therefore have a ULETRU compliance deadline at seven years.  TRU Advisory 12-22 explains the compliance requirements and options for <25 HP TRU engines.

Compliance Assistance
    • In-Use Performance Standards (see page 4)
    • Registration applications for ARB Identification Numbers (see page 7)
    • Operator Reports (see page 8)
  • Compliance Assistance Documents:
    Below are documents to help TRU owners find TRU unit and engine labels and the information on those labels that is needed to apply for an ARB number:
    • Carrier Transicold Unit and Engine Labels  - This provides helpful pictures showing where to look for the Carrier unit labels and Kubota engine labels. It also shows pictures of where to look on the unit label for the unit model, model year, and serial number. There are also pictures showing where to look on the engine label to find the engine manufacturer, model, model year, and serial number.  For further assistance, contact a local Carrier Transicold dealer
    • Thermo King Unit and Engine Labels - This provides helpful pictures showing where to look for the Thermo King unit labels and Isuzu or Yanmar engine labels. It also shows pictures of where to look on the unit label for the unit model, model year, and serial number. There are also pictures showing where to look on the engine label to find the engine manufacturer, model, model year, and serial number. Thermo King Service Bulletin TT505 provides a look-up table that uses the engine serial number to determine the engine model yearof Isuzu engines. For further assistance, contact a local Thermo King dealer.
  • Alternative Technology
    • UPDATED Regulatory Guidance for Electric Standby and Hybrid Electric Systems for Alternative Technology Compliance (Espaņol):   These electric systems are hereinafter referred to as E/S.  This guidance explains how E/S must be used to qualify as an Alternative Technology and the recordkeeping and reporting that is required with this compliance option.  In addition, the automated recordkeeping and reporting requirements, using electronic tracking systems (ETS), that are phased in, beginning January 1, 2013, are explained.  Specifications are explained for businesses interested in providing ETS to E/S-equipped TRU owners.  ARB's ETS Supplier List is available, but users are warned that the list is not intended to imply ARB endorsement of any kind.  Users of this list are advised to use due diligence in evaluating offerings from the companies on this list.
    • TRU Verified Diesel Emission Control Strategy (VDECS) Information
      • Complaints:  Owners that have problems with their VDECS should first contact the installer.  The installer should be able to assist with diagnosis and repairs as well as warranty work, if available.  If the installer is unable to resolve the problem, contact the manufacturer of the VDECS.  Also, contact ARB at (916) 327-5636 or send an email to tru@arb.ca.gov.

Level 3 VDECS (85 percent PM control) - meets ULETRU

Fully verified as a Level 3 Plus diesel emission control strategy that reduces particulate matter (PM) emissions by 85 percent or more without increasing NO2 emissions more than 20 percent of NOx.  The Carrier Legacy EES is verified for use on Carrier TRU models (X2-Series, XT-Series, XTC-series, Genesis TM900, Genesis TM1000, Ultra XL (with and without standby), Vector 6500, and 6600MT) equipped with model year 2004 through 2012 Kubota engines.  Only engines listed on the Carrier Legacy EES' Engine Family List are potentially eligible for use with the Carrier Legacy EES, if they also meet other terms and conditions for use.  There is no limit on the accrued hours of operation at time of installation; but engines must be maintained in accordance with Carrier’s specifications.  The Carrier Legacy EES uses an automatic filter regeneration system to oxidize the collected diesel soot and control engine backpressure to within the engine manufacture’s specifications.  The regeneration system uses an engine intake air control valve, a diesel fuel doser, a flameless diesel oxidation catalyst, and a catalyzed silicon carbide wall-flow filter with an electronic control unit to achieve reliable backpressure control.  Double-wall insulation is used to reduce exhaust system component surface temperatures, providing operator and equipment safety.  The Legacy EES uses commercially available fuel that meets the federal and California sulfur limits – the same fuel sold at trucks stops in the U.S.A.  Lab and field tests showed fuel consumption increased less than 1 percent with the Legacy EES, compared to baseline.  The terms and conditions for which the Carrier Legacy EES has been approved may be found in ARB’s Executive Order at ARB's Verification Procedure Website for the Carrier Legacy EES at:  http://www.arb.ca.gov/diesel/verdev/companies/carrier/carrier_legacy-ees.htm.  Additional information about the Carrier Legacy EES may be found at Carrier Transicold’s Legacy EES webpage: www.carrier.com/tru-legacy.

Fully verified as a Level 3 Plus diesel emission control strategy that reduces particulate matter (PM) emissions by 85 percent or more without increasing NO2 emissions more than 20 percent of NOx.  The Carrier EES is verified for use on Carrier X4 7300 and 7500 TRUs, Vector 8500 and 8600MT TRUs, and Carrier UG and RG TRU generator sets equipped with model year 2012 through 2015 Kubota model V2203L-DI-EF01e engines rated at less than 25 horsepower. The Carrier EES' Engine Family List shows which TRU engines are potentially eligible for use with the Carrier EES, if they meet other terms and conditions for use listed in Executive Order DE-14-003 . There is no limit on the accrued hours of operation at time of installation; but engines must be maintained in accordance with the engine and original equipment manufacturer’s specifications.  New TRUs may be retrofit with the Carrier EES, concurrent with the sale or lease of the new TRU.  The Carrier EES uses an automatic filter regeneration system to oxidize the collected diesel soot and control engine backpressure to within the engine manufacture’s specifications.  The regeneration system uses an engine intake air control valve, a diesel fuel doser, a flameless diesel oxidation catalyst, and a catalyzed silicon carbide wall-flow filter with an electronic control unit to achieve reliable backpressure control.  Double-wall insulation is used to reduce exhaust system component surface temperatures, providing operator and equipment safety.  The EES uses commercially available fuel that meets the federal and California sulfur limits – the same fuel sold at trucks stops in the U.S.A.  Lab and field tests showed fuel consumption increased less than 1 percent with the EES, compared to baseline.  Additional information about the Carrier EES may be found at Carrier Transicold’s True Power of Blue webpage.

(Formerly designated as the FS‑MK 40S and the FS‑MK 50S) has been verified as Level 3+ diesel emission control strategy for use with certain 1998 through 2010 diesel Transport Refrigeration Unit (TRU) engines.  Executive Order DE-11-004-01's  Engine Family List shows which TRU engines are potentially eligible for use with these DPFs if they also meet other terms and conditions for use.  These DPFs are capable of reducing emissions of particulate matter (PM) by 85 percent or more.  The HUSS MK 35 and MK 50 DPF consist of an active exhaust filter system and an automatic filter regeneration system.  The system has three modules with silicon carbide filter material that uses a diesel burner for regeneration.  Specific terms and conditions for which the MK 35 (for 0 to 25 hp TRU engines) and MK 50 (for 26 to 50 hp TRU engines) DPF has been approved are listed in Executive Order DE-11-004-01. Other information related to this VDECS is posted at:  Verification Procedure - Huss MK 35 and MK 50. See Huss, LLC's webpage for more information.
Huss LLC's "kit" for installing their MK-35 and MK-50 diesel particulate filters (DPF) on bobtail TRUs has been approved.  Huss MK series DPFs use active regeneration to burn off the collected diesel soot.  This allows the filter to be mounted away from the engine, if necessary.  Since there is not enough space in the TRU housing to mount the Huss DPF, a frame-rail mount, under the refrigerated van, was evaluated and approved.  This mounting configuration meets all of the conditions in ARB's verification Executive Order for MK-35 and MK-50 DPFs.  Temperatures around the DPF and exhaust tubing, and the integrity of the installation have been monitored and approved.  The Huss MK-35 and MK-50 DPFs reduce diesel particulate matter emissions by greater than 85 percent (verified to meet  Level 3), which means they can be used as an Ultra-Low-Emission TRU (ULETRU) in-use performance standard compliance option for bobtail TRUs.  See Huss, LLC's webpage for more information.

Verified as a Level 3+ diesel emissions control strategy to comply with the Ultra-Low-Emission TRU (ULETRU) in-use perfomance standard on single temp trailer TRUs using certain 2003 through 2011 model year engines manufactured by Kubota and Yanmar.  The DPF/ULETRU consists of flow-through filters made out of electrically conductive sintered metal fiber medium.  The system uses active electric resistance regeneration to control backpressure.  Warning indicators notify the operator when service is necessary.  Interested parties should read the Executive Order DE-11-008-01, which lists the terms and conditions that must be met to qualify for use.  Engine models and families that are eligible for use with this DPF if these terms and conditions are met are listed in the Engine Family List.  See the Rypos website for more information.

Level 2 VDECS (50 percent PM control) - meets LETRU

Level 2 Plus (greater than or equal to 50 percent reduction in PM plus complies with the 20 percent NO2 limit before January 1, 2009) flow-through filter verification allows this VDECS to be used to comply with the Low-Emission TRU In-Use Performance Standard (LETRU).  The FTF is verified for use on most Thermo King trailer TRUs using 25 to 50 horsepower, 1985 through 2003 model year engines of the following engine models:  Isuzu D201, Yanmar 4TNE82-TK and -ETK, and Yanmar 4TNE86-TK and –ETK.  The Proventia FTFTM consists of a catalyzed knitted wire mesh flow-through filter with backpressure control system, an exhaust system insulation package, and a backpressure warning indicator. TRU owners should read about the specific conditions and engine families for which the FTFTM has been approved in the Executive Order which has been posted on the ARB website for Level 2 VDECS. For more information contact Proventia Americas LLC

Verified as a Level 2 Plus flow-through-filter to reduce diesel particulate matter at least 50 percent, plus complies with the 20 percent NO2 limit.  This verification allows this VDECS to be used to comply with the Low-Emission TRU In-Use Performance Standard (LETRU).  The Bobtail FTFTM is verified for use on most Thermo King truck TRUs using less than 25 hp, 1987 through 2004 model year engines of the following Yanmar engine models:  3TNE66-TK, 3TNE66KC-ETK, 3TNE72-TK, and 3TNE72KC-ETK. The Bobtail FTFTM is also verified for use on Carrier Transicold truck TRUs using less than 25 hp, 1994 through 2004 model year engines manufactured by Kubota with the following engine models: D722, D1105, D722-E, and D1105-E.  The Proventia Bobtail FTFTM consists of a catalyzed knitted wire mesh flow-through filter with backpressure warning indicator. TRU owners should read about the specific conditions and the specific engine families for which the Bobtail FTFTM has been approved in the Executive Order which has been posted on the ARB Verification Procedure - Level 2 website. For more information contact Proventia Americas LLC1-800-609-7686.

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(Level 2 Plus) diesel particulate filter, has been verified to comply with the Low-Emission TRU (LETRU) In-Use Performance Standard on most trailer TRUs using 2003 and older model year engines manufactured by Isuzu, Kubota, and Yanmar.  The Rypos DPF/LETRUTM consists of active flow-through filters made out of an electrically conductive sintered metal fiber medium. It is microprocessor controlled with a backpressure control system, an electrical control circuit, and a backpressure warning indicator.  TRU owners should read about the specific conditions for which the DPF/LETRU has been approved in the Executive Order, which has been posted on ARB's website for Level 2 VDECS. Specific engine models and families that apply are listed in the EOs attachment, also listed at this webpage. See Rypos, Inc.'s website for more information. .

TRU Compliance Extensions

Compliance extensions are available if delivery or installation is delayed through no fault of the owner.  To qualify, an applicant must demonstrate, with documentation, that they made a good-faith effort to comply by December 31st of the applicable compliance year by ordering compliance equipment early enough to take into account delivery, installation, holiday, and year-end lead times.  We recommend that owners research compliance options in June and place orders in July to avoid delays.

Purchase order deadlines apply:

  • Replacement engines, units, and vehicles:  No later than August 31st of applicable compliance year
  • VDECS Retrofits (diesel particulate filters):  No later than October 31st of applicable compliance year
             * Earlier orders are recommended because the maximum extension allowed by law is four months.*

Compliance extension application (with documentation) deadline:  Close of business, December 31st.

Resources for Carriers, Brokers, Forwarders, Shipper, and Receivers
TRU Tutorial for Broker, Forwarder, Shipper, Receiver, Carrier, and Driver Requirements.  Tutorial slides with notes below each slide to explain the new requirements for freight brokers, forwarders, shippers, receivers, carriers, and drivers that went into effect January 1, 2013.  These PowerPoint slides are based on ARB's Guidance for Brokers, Forwarders, Shippers, Receivers, Carriers, and Drivers on Hiring and Contracting TRU-Carrier Transport of Perishable Goods on California Highways and Railways. (Espaņol)

TRU Compliance Check Resources for Carriers, Brokers, Forwarders, Shippers, and Receivers.  This webpage provides optional links for determining the compliance status of a TRU or company that owns TRUs. There are links to the ARBER Login Page, Public TRU Compliance Search Page, and TRU 100 Percent Compliant-Carrier Report Page in one convenient location to facilitate quicker navigation.  TRUs and carriers that are based outside of California may not be included depending on whether they have voluntarily chosen to register TRUs in ARBER.  In addition, companies will not be included on the TRU 100 Percent Compliant-Carrier Report if they have non‑compliant units, or if the TRUs they operate are owned by another business entity, such as a lessor, parent company, or holding company. 


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