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Updated September 17, 2025

Manufacturers Face Mixed Signals as Orders Lag and Regulatory Uncertainty Persists

With Class 8 orders still subdued, tariffs taking firmer hold, and regulatory ambiguity stretching into Q4, North American commercial vehicle manufacturers continue to operate in a balancing act between production stability and fading demand visibility.

ACT Research’s October NA Commercial Vehicle OUTLOOK indicates that the industry remains defined by below-replacement Class 8 order activity, a dormant prebuy environment, and fleet customers prioritizing cost control and capital preservation over growth.

While supply chains are functioning efficiently and build rates remain stable, OEMs report slower quoting activity, longer sales cycles, and reduced order visibility. The focus across the industry has shifted decisively from volume expansion to backlog quality, spec flexibility, and inventory discipline.

Class 8 Orders Continue to Undershoot Expectations

Class 8 orders remained weak in September, extending the multi-quarter pattern of underperformance. Net orders totaled 20,562 units, down y/y, signaling continued caution among fleet buyers. OEMs are managing production to match the market’s replacement-level cadence while keeping backlogs stable and inventories from building further.

Fleet hesitation remains concentrated around three primary factors:

• Margin compression, with operating ratios elevated and freight demand still uneven.
• Tariff-driven cost inflation, adding roughly 3–5% y/y to new vehicle pricing.
• Ongoing regulatory uncertainty tied to the EPA’s 2027 low-NOx and GHG Phase 3 rules, which continue to cloud multi-year ROI models.

Large for-hire and private fleets alike are delaying replacement decisions, deferring orders until cost clarity and compliance timelines become more predictable. Order pipelines remain thin, especially for long-haul tractors, though cancellation rates remain low—signaling stable but cautious commitments.

Prebuy Activity Remains on Hold as Regulatory Clarity Slips Further

The EPA 2027 regulatory timeline continues to lack resolution, leaving prebuy activity effectively frozen. Fleets are holding off on multi-unit commitments pending guidance on:

• Final compliance enforcement and timeline clarity
• System architecture and certification requirements
• Funding support and incentive frameworks
• Residual value risk post-implementation

Manufacturers have shifted into strategic readiness mode, maintaining flexible production and supplier networks while mapping potential spec transitions and certification pathways. However, orderbooks reflect no meaningful prebuy acceleration, underscoring that fleet planning remains anchored in near-term replacement, not regulatory anticipation.

This prolonged limbo is distorting normal replacement cycles and stretching planning horizons for both OEMs and suppliers.

Medium-Duty and Vocational Segments Show More Stability

Compared to the heavy-duty market, medium-duty (Classes 5–7) and vocational activity continue to demonstrate relative stability. Medium-duty orders were down 19% y/y, but replacement activity remains steady, supported by ongoing infrastructure projects, municipal purchases, and regional delivery applications.

Food and beverage distribution, utilities, and local service fleets continue to anchor demand, while housing and private construction remain subdued. Lead time sensitivity and credit access are persistent concerns, but body builders and dealers are finding success by focusing on spec optimization, delivery certainty, and lifecycle cost performance rather than price competition.

Outlook: A Strategic Reset Year Continues

October reinforces that 2025 remains a reset year—one characterized by operational discipline, not expansion. Manufacturers are managing through the trough with a focus on margin protection, cash conversion, and production agility.

Key imperatives through year-end include:

• Maintaining output discipline to match replacement-level demand
• Aligning inventory and dealer pipelines to current market velocity
• Preserving flexibility in production and supplier sourcing to pivot quickly once regulatory clarity or prebuy signals emerge

Until EPA 2027 timelines are finalized and fleet profitability improves, OEMs are best served by emphasizing backlog quality, working capital efficiency, and customer retention over unit throughput. The next growth phase will favor manufacturers positioned for rapid execution once confidence and clarity return—and the groundwork laid in 2025 will determine who captures that advantage.

Want to hear more from ACT Research? Analysts Lydia Vieth and Ann Rundle explain the current market and regulations, as well as their projections for future electric truck adoption, battery technologies, and beyond.

Where's the electric truck market headed now? (12:56 minute watch)

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