What this checklist covers
California sets its own vehicle emission standards through the California Air Resources Board (CARB). Vehicles sold there must be certified for California, and aftermarket or performance parts that can affect emissions may only be sold or installed for road use when CARB has granted an exemption, known as an Executive Order (EO). Replacement catalytic converters must also be CARB-approved for the vehicle.
The CARB Compliance Checklist is a 15-point scorecard for California emissions rules, aftermarket parts approval, catalytic converters, emissions labels, and CARB Executive Order documentation. Each criterion is scored from 1 to 5 on what the auditor sees on the day, and every gap goes into an action plan with an owner and a close date.
AutoSmart tip: CARB compliance applies not only in California but in every state that has adopted California’s emissions standards — currently approximately one-third of the US vehicle market. Selling a non-CARB-approved aftermarket part or an uncertified replacement catalytic converter in any of these states carries the same penalty exposure as a California sale. Confirm CARB status for every emissions- related part before installation in any CARB-adopting state.
The checks
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California emissions standards
- Are vehicles sold in California (and other CARB- adopting states) confirmed as meeting the California Air Resources Board's emissions standards rather than only the federal Tier 3 standards?
- Is the California-specific certification (CARB Executive Order for vehicle compliance) confirmed as current and covering all variants sold in California-complying states?
- Are the Zero Emission Vehicle (ZEV) mandate obligations understood and tracked for manufacturers required to meet California's ZEV program requirements?
- Are California Advanced Clean Cars, Advanced Clean Trucks, or equivalent current CARB program requirements tracked for applicable model years and vehicle categories?
Aftermarket and performance parts approval
- Are aftermarket parts that affect vehicle emissions — performance air filters, exhaust systems, tune modules, EGR modifications — confirmed as CARB-approved (holding a CARB Executive Order) before being sold or installed in California?
- Is a process in place to prevent installation of aftermarket parts on California vehicles that do not have a valid CARB Executive Order for the specific vehicle application?
- Are staff responsible for parts and accessories sales trained on the CARB aftermarket parts compliance requirement — distinguishing between federally legal parts and California- legal parts?
- Is the CARB Executive Order number for each approved aftermarket part confirmed and recorded at point of sale in California, providing traceability if a smog check or CARB inspection raises a query?
Catalytic converters and emissions labels
- Are replacement catalytic converters sold or installed on California vehicles confirmed as CARB-approved — with the CARB Executive Order number verifiable for the specific application?
- Is the California emissions label (CARB label) confirmed as present and legible on every California-certified vehicle, with no label removed or obscured during service work?
- Are non-CARB-approved catalytic converters clearly identified and not sold for use on California vehicles — even if they are legal for use in other states?
Executive order documentation and governance
- Is a register maintained of CARB Executive Orders applicable to the vehicles and aftermarket parts sold, with expiry dates tracked and renewals confirmed before previous orders lapse?
- Is CARB compliance reviewed when new models, new aftermarket products, or new California program requirements are introduced — confirming that California-specific approval is obtained before California sales begin?
- Are CARB compliance obligations in California- adopting states (currently 17 states including New York, Massachusetts, and Washington) tracked alongside California itself, as the same CARB standards apply?
- Is a named person designated as responsible for CARB compliance, with the authority and process to confirm California-specific approval status before any parts or vehicles are sold in CARB-adopting states?
How to run it
How the scoring works
Before the visit, fill in the dealer or centre, the auditor, the date and the audit cycle. Then score each of the 15 checks from 1 to 5 on what you see on the day, not on what the site aims for, and add them up out of 75.
- 1Not in place
- 2Attempted
- 3Defined
- 4Managed
- 5Fully sustained
- Green60–75 · 80–100%Compliant. Keep the standard.
- Amber38–59 · 50–79%Improvement needed: a structured action plan within 30 days.
- Red0–37 · Below 50%Priority intervention, escalated to regional management.
Then close every gap
Each gap goes into the action plan tracker and moves through four stages until the auditor closes it.
- 1PendingOwner and close date set
- 2In progressWork under way, evidence gathered
- 3CompletedEvidence submitted for review
- 4ApprovedVerified and closed by the auditor
Questions about this checklist
What is a CARB Executive Order?
An exemption CARB grants for an aftermarket or modified part after showing it does not increase emissions. It applies to the vehicles listed in it.
Do other states follow CARB rules?
Several states have adopted California’s vehicle standards. Check the current list for your state.
Can AutoSmart track EO checks?
Yes. The checks become a recurring audit per site, with photos of labels and an action for every part that fails.
