Well, it’s say to say the pre-buy is over.
ACT Research and FTR on Friday reported preliminary North American Class 8 truck orders of 18,700 and 21,300 units, respectively, in September. Due to the expanse between both estimates, these totals are slightly below and slightly above 2025 totals (but safely ahead of August) and indicate an uncertainty across the market tied to the still yet to be finalized EPA 2027 NOx rule.
New truck demand has been firm throughout 2026, but September and the opening of new order boards signifies the transition to model year (MY) 2027 equipment purchasing. And with surcharge-free MY 2026 engines no longer available, the firms believe it is likely September orders were somewhat muted as the larger industry waits to determine the full cost impact of the upcoming regulations on new equipment.
FTR reports underlying demand remains fairly solid, supported by replacement needs, tight capacity and firmer freight rates.
“The 2027 regulatory engine transition is clearly impacting order seasonality this year, but the underlying demand for new equipment remains robust, supported by strong spot rate momentum,” adds Carter Vieth, research analyst at ACT Research. “Fleets are eager to replace aging equipment and prepare for cost increases on the horizon, but the lack of regulatory clarity is making it difficult for them to plan effectively.”
FTR agrees, adding because MY 2027 order boards are opening before the EPA’s 2027 NOx regulation is finalized, pricing could change once the final rule is issued. Until there is greater regulatory and cost clarity, orders over the next month or two could remain near year-ago levels, the company says — a period when tariff and EPA 2027 NOx uncertainty weighed on demand.
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For the 2025-2026 order season, FTR says Class 8 orders totaled 351,244 units over the last 12 months, and orders are up 95% year-to-date at 263,499 units.
“With the EPA 2027 NOx pre-buy now complete, attention is shifting to MY 2027 engine choices and costs,” says Dan Moyer, FTR senior analyst, commercial vehicles. “EPA’s July proposal would reduce some transition risk by allowing NCPs, emissions credits, warranty relief and other compliance flexibility. For Class 8, NCPs could result in an estimated $6,000 to $7,000 fleet pass-through, compared with an estimated $8,000 to $12,000 upcharge for a fully compliant engine.
He continues, “Truck and engine manufacturers have announced varying strategies for handling the emissions transition, and some have not yet made their plans clear. The final EPA rule could still materially alter the economics of these strategies. Higher NCPs would narrow the cost advantage of current-generation engines while lower NCPs would make that pathway more attractive.
[RELATED: Annual truck order season concludes in August as EPA pre-buy ends]
“That major issue, along with other potential changes, could affect 2027 engine availability, fleet acquisition costs and the mix of technologies ultimately selected.”
