Page  1TRU A TCM Implementation Update
December  18, 2023
On December  4, 2023,  a California  trial court  prohibit ed CARB  from  collecting  the fees  
included  in the 2022  amendments  to the Airborne  Toxic  Control  Measure  for In-Use 
Diesel -Fueled  Transport  Refrigeration  Units  (TRU)  and TRU  Generator  Sets,  and Facilities  
Where  TRU s Operate  (TRU  ATCM)  at this time .1
CARB  intends  to proceed  with  implementation  of all other  requirements2included  in the 
2022  amendments  and begin  issuance  of TRU  compliance  labels  in early  2024.
What  does  this mean  for TRU owners  or owner/ operators?
TRU  owners  or owner/ operators  are not required  to pay TRU  operating  fees  at this time.
Staff  will issue  two TRU  compliance  labels  to each  compliant  unit reported  in the ARB  
Equipment  Registration  Program  (ARBER) . However,  TRU  owners  will not receive  TRU  
compliance  labels  by December  31, 2023.  In the meantime,  owners  may  print  a copy  of 
their  ARBER  certificate  to show  proof  of compliance.  The TRU  ATCM  requires  that owners  
affix the TRU  compliance  labels  on their  unit(s)  within  30 days  of receipt.
As a reminder,  the TRU  ATCM  requires  owners  to report  all TRUs  that operate  in California  
to CARB,  regardless  of where  they  are based.  TRU  owners  should  update  their  ARBER  
accounts  to ensure  contact  information  is up-to-date  and remove  units  no longer  in 
operation  or under  their  control.  For more information , see guidance  document  onHow to 
Report  a TRU  to CARB .
What does this mean  for applicable  facility  owner s or owner/ operators ?
Applicable  facility  owners  or owner/ operators  are not required  to pay applicable  facility  
registration  fees  at this time.
Owners  are required  toregister their  facility  with  CARB  by December  31, 2023.  For more  
information,  seeApplicable  Facility  Requirements  Frequently  Asked  Questions  document . 
CARB  will mail  confirmation  of the applicable  facility  registration  to the address  provided  on 
the applicable  facility  registration  form .
1The Office  of Administrative  Law approved  the 2022  amendments  to the TRU ATCM  and filed the rulemaking  
with the Secretary  of State  on July 18, 2022.  The amendments  became  effective  on October  1, 2022.
2Cal. Code  Regs.,  title 13, § 2477.21,  subd.  (c), provides  that a court’s  holding  that the fees are 
“unenforceable”  does  “not affect  the validity  of the remaining  portions  of this TRU Regulation.”
Page  2Beginning  December  31, 2023,  the TRU  ATCM  also requires  applicable  facility  owners  to 
either  ensure  compliance  of TRUs  operating  onsit e or report  all TRU  activity  to CARB.  For 
applicable  facilities  that choose  to ensure  compliance,  there  are four ways  a facility  may  
verify  a TRU  is complian t with  the TRU  ATCM :
1)Unit has a valid  TRU  compliance  label,  (or)
2)Unit shows  as compliant  on theARBER  TRU Compliance  Search  page , (or)
3)Unit is owned  by a company  on the100 Percent  TRU  ATCM  Compliant  Carrier  List 
page , (or)
4)Unit is listed  in the Kiteworks  Compliant  TRU  file.
If a TRU  does  not have  TRU  compliance  label s, then  compliance  should  be verified  by using  
one of the other  three  available  options . For more information , see the guidance  document  
onHow  to Check  TRU  Compliance . As a reminder,  facilities  may  change  their  selected  
compliance  option  by notifying  CARB  by September  30 of the preceding  year.
For more  information  on the TRU  ATCM,  visit https://ww2.arb.ca.gov/our -
work/programs/transport -refrigeration -unit. If you have  questions,  email arber@arb.ca.gov
or call the TRU  Help  Line at 1-888-878-2826 .