California E15 and Vapor Recovery (EVR)
California is the hardest state in the country to add E15 to an existing station. The fuel itself is now legal. The obstacle is the vapor recovery equipment on the dispensers, which California certifies under its own program, and most of which is only certified for blends up to E10.
This chapter explains how that program works, which parts of a station are affected, and what to check before you plan a conversion.
Where things stand
| Date | Action | What it did |
|---|---|---|
| Oct. 2, 2025 | AB 30 signed | Made E15 legal to sell in California until CARB adopts a permanent regulation. |
| After AB 30 | Multi-agency equipment guidance | Said Phase II EVR equipment must be re-certified through UL for service up to E25 before it can dispense E15. Most existing equipment isn’t certified above E10, which stalled conversions. |
| Sept. 19, 2026 | SB 795 signed | Directs the Office of the State Fire Marshal (OSFM) to finalize the rules needed to fully implement AB 30. |
| Sept. 24, 2026 | CARB vote | Adopted the permanent regulation approving E15 in California. |
Until OSFM finishes those rules, the practical question for most stations is whether their Phase II vapor recovery equipment can legally dispense E15. The rest of this chapter covers how to answer it.
What vapor recovery is
Vapor recovery captures gasoline vapor that would otherwise escape during fuel transfers and returns it to the storage tank. It cuts evaporative (VOC) emissions and product loss.
- Stage I covers deliveries: vapor pushed out of the underground storage tank (UST) while a tanker unloads.
- Stage II covers dispensing: vapor pushed out of a vehicle’s tank while it’s being filled.
Stage I is required almost everywhere, including in all federal non-attainment areas. Stage II is not. In 2012, EPA let states drop Stage II because nearly every gasoline vehicle now carries onboard refueling vapor recovery (ORVR), which captures refueling vapor in the car and burns it in the engine. ORVR phased into new light- and medium-duty vehicles from 1998 to 2006, and into heavy-duty vehicles by 2018. Nearly every state has since phased out Stage II. The holdouts are states that follow California’s rules.
How California’s program is different
California went further and created the Enhanced Vapor Recovery (EVR) program. In California, Stage I equipment is called Phase I EVR and Stage II equipment is called Phase II EVR.
- Equipment has to meet strict design and performance requirements, verified through emissions and drip testing.
- General requirements are in the California Code of Regulations, Title 17, Sections 94010 through 94017. Section 94011 covers stations with USTs.
- Manufacturers certify equipment under CARB procedure CP-201 (Certification Procedure for Vapor Recovery Systems at Gasoline Dispensing Facilities Using Underground Storage Tanks).
- CARB approves equipment as complete systems through executive orders. A station must use components listed together on the same order.
- CARB enforces the program. The State Fire Marshal, Cal/OSHA, and the state weights and measures program also approve equipment.
CARB has said Phase II EVR still matters because some vehicles on the road lack ORVR. In a 2020 rulemaking it estimated that by about 2030, roughly 95% of California gasoline would go into ORVR-equipped vehicles, and that it might then consider removing Phase II in some areas. No such change has been made.
E85 is exempt from Phase II
E85 dispensers in California don’t have to meet Phase II EVR requirements, and won’t until CARB certifies Phase II systems for E85. CARB granted this through Executive Order G-70-212, based on E85’s much lower vapor pressure and the spread of ORVR. E15 has no equivalent exemption.
Phase I EVR (deliveries): usually not the problem
Phase I EVR executive orders (VR-101, VR-102, VR-104, and VR-105) do not limit the ethanol content of the fuel. Phase I components are also commonly rated for higher ethanol blends, especially at sites that have been rebuilt or upgraded. California’s requirement to permanently close single-walled UST systems has sped up that turnover.
For component-by-component compatibility of tanks, piping, and delivery equipment, see NREL E15 and Infrastructure in this library.
Phase II EVR (dispensing): where E15 gets stuck
Phase II EVR systems come in two types. They are not interchangeable, so the first thing to know is which one your station has. The executive order number is on the system’s certification paperwork and your air district permit.
| Vacuum assist | Vapor balance | |
|---|---|---|
| How it works | A pump in the dispenser pulls vapor back to the UST. | Pressure from the vehicle tank pushes vapor back to the UST through a coaxial nozzle and hose. No pump. |
| Executive orders | VR-201, VR-202 | VR-203, VR-204 |
| Common equipment | Franklin Fueling Systems (Healy series) | VST, EMCO Wheaton |
| Ethanol limit in the executive order | Up to 15% | Up to 10% |
| Warranty and UL listing | Warrantied to E15 by the manufacturer, but UL listed only to E10 | Generally warrantied or UL listed only to E10 |
| Upkeep | More maintenance, instrumentation, and testing | Simpler; more equipment options |
Several Phase II components have no product on the market that is listed for E15: hoses, nozzles, swivels, and breakaways. That doesn’t mean the parts can’t handle E15. It means they haven’t been certified for it.
Why certification matters: the fire code
The California Fire Code requires dispensing and vapor recovery equipment to be listed by an approved testing laboratory (see Sections 2306.7 and 2306.8, including 2306.7.9.1.1 and 2306.7.9.2.1). The code adopts NFPA 30 (Flammable and Combustible Liquids Code) and NFPA 30A (Motor Fuel Dispensing Facilities and Repair Garages).
Both NFPA codes include an equivalency provision (Section 1.5) that lets the authority having jurisdiction approve an alternative that provides the same level of safety. That provision is the basis for proposals to accept manufacturer compatibility statements instead of new UL listings. Whether OSFM accepts that approach is part of the rules it is finalizing under SB 795.
How equipment gets certified for E15
OSFM has confirmed the following process for manufacturers (correspondence with Growth Energy, March 2026):
- Equipment must be tested to the UL standards with an “A” suffix (certification above E10) that appear on OSFM’s list of approved testing laboratories for the vapor recovery program. Manufacturers work with UL to decide which tests apply.
- Manufacturers apply to OSFM using the vapor recovery certification application.
- If a component passes without design changes, the manufacturer files a revision to its existing certification. A new design needs a new application.
- OSFM reviews dispensers for both vacuum assist and vapor balance systems.
UL testing at these levels is slow and expensive, and several major manufacturers have shown little interest in doing it for California alone. Ask your equipment supplier directly whether your system’s components are in testing.
Blending and supply limits
Most California E15 will come blended from the terminal. Blending at the station is more restricted than in other states:
- Fuel composition limits. California reformulated gasoline (CaRFG) has limits on benzene, aromatics, olefins, and other components (Title 13, CCR, Sections 2250 to 2273.5). The petroleum portion of E85 can push a station-blended fuel outside those limits.
- Blending oxygenates past the terminal. Title 13, CCR, Section 2262.5(d) restricts adding ethanol downstream of the terminal, which rules out most splash blending.
- Single-hose (unihose) dispensers. CP-201 design requirements for multi-product dispensers can make adding a separately blended grade impractical.
Suppliers have also asked whether current CARBOB formulations used for E10 can be blended to E15. Check with your supplier on how CARB’s September 2026 regulation applies to your contract.
Before you plan a conversion
- Identify your Phase II EVR system type and its executive order number.
- List every Phase II component (dispenser, hoses, nozzles, swivels, breakaways) and get each manufacturer’s written E15 compatibility statement and current UL listing.
- Check Phase I and UST components against the NREL compatibility guidance.
- Talk to your local air district (vapor recovery permit) and your Certified Unified Program Agency (UST permit) before changing fuels.
- Confirm E15 supply and blending method with your supplier.
- Watch for OSFM’s final rules under SB 795, which may change what equipment is allowed.
Growth Energy’s market development team can help review your site. Visit the Retailer & Supplier Hub.
Sources
- California Code of Regulations, Title 17, Sections 94010 to 94017 (vapor recovery), and Title 13, Sections 2250 to 2273.5 (California reformulated gasoline)
- CARB CP-201, Certification Procedure for Vapor Recovery Systems at Gasoline Dispensing Facilities Using Underground Storage Tanks
- CARB Executive Orders VR-101, VR-102, VR-104, VR-105 (Phase I EVR); VR-201, VR-202, VR-203, VR-204 (Phase II EVR); G-70-212 (E85)
- CARB, Initial Statement of Reasons, vapor recovery amendments (2020)
- CARB, California Multimedia Evaluation of E10 to E15 Gasoline-Ethanol Blends, Tier I Report (2020) and Tier II Report (2023)
- California Fire Code, Chapter 23; NFPA 30 and NFPA 30A
- Office of the State Fire Marshal, Vapor Recovery Program, correspondence with Growth Energy, March 20, 2026
- Growth Energy Applauds Enactment of California E15 Bill (Sept. 19, 2026)
- Growth Energy Applauds CARB for E15 Approval (Sept. 24, 2026)
- Growth Energy market development, California Vapor Recovery and Regulatory Issues briefing
Last reviewed: October 2026.