Your Carbon Report Skips 2 Lines: Trucks Aren't Counted

The big picture:

I have read both agency notices, and they pull supply chains in opposite ways.

The state air board’s rule targets firms formed under U.S. law that do business in the state and clear $1 billion in yearly sales [1][2]. These firms must report their direct carbon and bought power by 10 November [1][2]. A firm that held no such data and was not collecting it by 5 December 2024 can send a one-page note instead, but it still pays the fee [1].

The federal Greenhouse Gas Reporting Program (GHGRP) is sliding backward [4][6]. The federal program makes fuel sellers and plants file every year across 47 source types, more than 8,000 of them [4][6]. The federal agency just pushed the 2025 date for the second time. Its reasons: delays with its web tool, and a plan that might cancel most of the program [4][5].

That is the collision. One agency nails a date to the wall. The other says its own filing portal will miss the old date, and the whole program may end [4][6].

By the numbers

• 10 November 2026 — First state deadline: The filing arrives in 18 days, counting only direct fuel and power. Fee bills follow on 10 December [1][2].
• 131 days — Federal date slip: The federal agency moved 2025 reports from 30 October 2026 to 10 March 2027. The rule started the day it was issued [4].
• 5 of 15 — Planned freight rows: State staff plan to require lines 1, 3, 5, 6 and 7 starting in 2027. The two transport lines stay a choice [3].
• $1,000,000,000 — Sales cutoff: This revenue line decides whether a firm files at all, no matter how much freight it moves [1].

What I’d watch:

What strikes me here is that a carrier’s carbon number enters neither rule by itself. The state rule targets the shipper with the sales, while the federal rule targets the fuel seller or plant [1][4]. A fleet only shows up on a ledger if its buyer decides to count it.

• The line question: If the state board keeps the two transport lines a choice in the final 2027 rule, a shipper’s freight carbon stays a choice rather than a duty [3].
• The method question: The same gallon makes a different number when counted from fuel burned rather than from miles and weight [3]. I expect buyers writing the contracts to dictate the math.
• The fixed bill: Fee bills land on 10 December whether or not a company actually filed the data [1].
• The comment file: Public comments on the federal delay close 30 November [4]. A final word on the proposed cut will prove whether the March date is real.
• The quiet route: The one-page note lets a first-year filer skip the filing with no fine [1]. I want to see how many large shippers take this exit.

The catch

This rule gap cuts both ways. A carrier with sales above $1 billion is a filer itself. The split between the filing firm and the data provider is a sales test, not a job title.

That both transport lines are only a choice is also a plan, not a settled rule. State staff showed this plan at a July workshop for the 2027 phase, and a final text could easily put freight transport back in [3].

I could be wrong about how fast buyers agree on a format, but the state’s own websites already lag its rule process. The official state page still describes the rule as pending, even though five separate read-outs confirm the 12 October approval and the November date [2][7].

One final limit: The federal date has moved twice since February. A March 2027 deadline that only exists to make room for a potential program cut is a bad base for building a tracking system.

At a glance

• The Big Shift: California fixed 10 November 2026 as the first carbon filing date for large firms, just as the federal agency pushed its own reporting date out to 10 March 2027 [2][4].
• Why It Matters: Neither rule targets freight carriers directly. The state rule hits shippers clearing $1 billion in sales. The federal rule hits fuel sellers. California plans to leave fleet transport lines as a choice in 2027 [1][3][4].
• What I’d Watch: How shippers define the freight data they demand from fleets, given that no agency has set a standard format.
• Transport lines: The two rows covering the movement of bought and sold goods, which regulators plan to leave as a choice [3].
• Method choice: The choice to count a load from fuel burned or from miles and weight, which changes the final number a carrier reports [3].
• The cancellation file: The federal plan to drop filings for most source types, which caused the March date slip [4][6].
• The Catch: The transport lines are only a choice in a draft plan. Large carriers above the sales cutoff must file anyway, and the federal deadline has already shifted twice [1][3][4].

Related reading

• Electric Trucks Just Doubled Overnight — more on Supply Chain & Operations
• Your Fuel Surcharge Hides Three Negotiated Numbers — more on Supply Chain & Operations
• Your Last-Mile Carbon Number Is a Rate Table — more on Supply Chain & Operations

Sources

[1] California Air Resources Board, reminder letter to potentially in-scope entities (October 2026) — https://ww2.arb.ca.gov/sites/default/files/2026-10/2026_Climate_Disclosure_Mailer.pdf [2] California Air Resources Board, California Corporate Greenhouse Gas Reporting and Climate Related Financial Risk Disclosure Programs — https://ww2.arb.ca.gov/our-work/programs/california-corporate-greenhouse-gas-reporting-and-climate-related-financial-risk [3] California Air Resources Board, public workshop presentation on the 2027 reporting plan (21 July 2026) — https://ww2.arb.ca.gov/sites/default/files/2026-07/SB_253_Presentation_July_2026.pdf [4] U.S. Environmental Protection Agency, “Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for Reporting Year 2025 to March 10, 2027”, 91 FR 65112 (14 October 2026) — https://www.federalregister.gov/documents/2026/10/14/2026-20982/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-reporting-year-2025-to [5] U.S. Environmental Protection Agency, “Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for 2025”, 91 FR 9712 (27 February 2026) — https://www.federalregister.gov/documents/2026/02/27/2026-03995/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-2025 [6] U.S. Environmental Protection Agency, “EPA Releases Proposal to End the Burdensome, Costly Greenhouse Gas Reporting Program, Saving up to $2.4 Billion” (16 September 2025) — https://www.epa.gov/newsreleases/epa-releases-proposal-end-burdensome-costly-greenhouse-gas-reporting-program-saving-24 [7] Vinson & Elkins, analysis of the state approval of the climate reporting rule (13 October 2026) — https://www.velaw.com/insights/oal-approves-carbs-initial-regulation-locking-in-november-10-2026-sb-253-reporting-deadline