| Carbon-intensity (CI) trajectory | 20% reduction by 2030 relative to 2010 baseline | 30% reduction by 2030; 90% by 2045. (California Air Resources Board) | Expect tighter CI margins and greater value for low-CI pathways; ensure actual data and verification packages are audit-ready under ISCC to defend CI claims across markets. |
| Effective date/status | Existing LCFS framework in place | OAL approved CARB’s 2024 rulemaking; amendments effective July 1, 2025. (California Air Resources Board) | Begin gap assessments now; align documentation and contracts to the amended rule text and timelines. |
| Palm oil eligibility | Not categorically barred in regulation text | Transportation fuels from palm oil or derivatives are ineligible for LCFS credits; any such volumes must use the ULSD CI in reporting. (California Air Resources Board) | Confirm feedstock origin declarations and supplier attestations; keep ISCC chain-of-custody evidence to demonstrate no palm content. |
| Crop-oil share limits for biomass-based diesel | No company-level cap specified in the prior text | Company-level cap: soybean/canola/sunflower-based biomass diesel eligible only up to 20% of annual production/import reporting; excess assigned benchmark CI or certified CI, whichever is greater; phased applicability beginning Jan 1, 2028. (California Air Resources Board) | Contract and portfolio planning: increase waste/residue feedstock share; maintain ISCC documentation to evidence qualifying waste/residue status for market premiums. |
| Third-party sustainability certification of biomass feedstocks | No explicit ongoing third-party sustainability certification requirement for all biomass | New requirement for continuous third-party sustainability certification under an Executive Officer-approved system, with phase-ins tied to pathway timing (e.g., new applications using covered biomass from Jan 1, 2028; additional phase-in from Jan 1, 2031). (California Air Resources Board) | ISCC provides a recognized framework for sustainability and chain of custody; obtain or renew ISCC now to de-risk LCFS credit generation and documentation. |
| Specified-source feedstocks in verification scope | Less explicit treatment | Specified-source feedstocks must be included in the scope of third-party verification; even when a pathway itself doesn’t require validation, quarterly transaction verification must include these feedstocks. (California Air Resources Board) | Keep supplier-level ISCC evidence (certificates, delivery records) organized; align quarterly verification packages with ISCC mass-balance records. |
| Bio-CNG/LNG use in CNG vehicles | Eligible under qualifying pathways | For projects breaking ground after Dec 31, 2029, bio-CNG/bio-LNG/bio-L-CNG used in CNG vehicles become ineligible after Dec 31, 2040; post-date volumes assigned ULSD CI. (California Air Resources Board) | Re-evaluate long-dated RNG mobility strategies; document alternative uses and retain ISCC traceability where biomethane attributes continue to matter. |
| Hydrogen content rules | No minimum renewable/CCS content threshold | From Jan 1, 2030, at least 80% must be renewable and/or produced with CCS; fossil-gas H₂ ineligible from Jan 1, 2035 unless biomethane matched 100% or CCS applied. (California Air Resources Board) | For future H₂ supply, collect ISCC-aligned evidence for biomethane attribution and emission accounting; prepare supplier attestations and metering data. |
