CALGreen Wants Two Words on Your Panel — Not Just an EV Raceway

The raceway passes. The directory doesn't say the magic words. Still a correction.

Here's the thing: most crews get the hard part of CALGreen's EV rule right. They run the conduit. They leave breaker space. Then they eat a correction anyway — because the section asks for two specific words, in two specific places, and nobody wrote them down.

The rule is CALGreen §4.106.4, and it governs EV charging for new construction. New construction has to comply with either 4.106.4.1 or 4.106.4.2, and any EV supply equipment has to meet the California Electrical Code. For a new one- and two-family dwelling — or a townhouse with an attached private garage — you're in §4.106.4.1.

What 4.106.4.1 actually asks for

Three physical things, for each dwelling unit:

• A listed raceway, not less than trade size 1 (nominal 1-inch inside diameter). It has to originate at the main service or subpanel and terminate into a listed cabinet, box or other enclosure in close proximity to the proposed location of an EV charger. It also has to run continuous through any enclosed, inaccessible, or concealed spaces.
• Panel capacity for a 40-ampere, 208/240-volt minimum dedicated branch circuit.
• Reserved space(s) in the service panel and/or subpanel for the branch-circuit overcurrent protective device.

That's the electric-ready shell. It's a cousin of the CEC 422.3 electric-ready wiring rule — the one that pre-wires a gas house for an electric cooktop, dryer, and heat-pump water heater — but keep them straight: 422.3 is the Electrical Code pointing at appliance circuits, and this is CALGreen pointing at the EV raceway. Different books, different requirement.

The part that generates the correction

Getting the raceway sized and the capacity reserved is not the whole job. §4.106.4.1.1 adds an identification step, and it's the piece inspectors actually check.

Verified against the live code text (§4.106.4.1.1): "The service panel or subpanel circuit directory shall identify the overcurrent protective device space(s) reserved for future EV charging as 'EV CAPABLE'. The raceway termination location shall be permanently and visibly marked as 'EV CAPABLE'."

Two words. Two places. "EV CAPABLE" goes on the panel or subpanel circuit directory, identifying the reserved breaker space — and it goes at the raceway termination, permanently and visibly marked. A correctly-sized raceway with the capacity reserved but no label is still a correction. The inspector is looking for the literal words, not the intent behind them.

So the checklist is short: raceway, capacity, reserved OCPD space, and the label in both spots. Miss the label and you've done all the expensive work and still failed the cheap part.

There's an exception worth knowing — and a trap

The raceway exception: you don't have to run the raceway at all if you install a minimum 40-ampere, 208/240-volt dedicated EV branch circuit in close proximity to the proposed charger location at the time of original construction, in accordance with the California Electrical Code. If the circuit is already there, the conduit-for-later logic is moot.

The reverse trap — and this is where money gets wasted: §4.106.4 Exception 2 exempts Accessory Dwelling Units (ADU) and Junior Accessory Dwelling Units (JADU) without additional parking facilities from the entire section. No raceway, no capacity, no label. Designers keep speccing full EV infrastructure onto ADUs and JADUs that don't owe a thing under this rule. If the unit adds no parking, the section doesn't reach it — and over-building it isn't compliance, it's just cost.

There's also a case-by-case out: Exception 1 lets the local enforcing agency determine EV infrastructure isn't feasible — where there's no adequate local utility power, or documented evidence that the utility-side design work would adversely affect the project's construction cost. That's a jurisdiction call, not something you self-certify on the plans.

The takeaway

New one- and two-family homes and townhouses with attached garages: run the trade-size-1 raceway (or drop in the 40-amp circuit instead), reserve the 40-amp/208-240V capacity and the breaker space, and write "EV CAPABLE" on both the circuit directory and the raceway termination. ADU or JADU with no added parking? You're exempt — don't over-build it. As always, confirm scope and any local amendments with your local jurisdiction before you finalize the panel schedule; cities can go stricter, and none of this is legal advice.

What CrossBeam does with it

CrossBeam reads a residential submittal against the whole of §4.106.4 — the raceway, the reserved 40-amp capacity, and the "EV CAPABLE" labels that plan sets routinely forget — and flags the gap between what the drawing shows and what the section requires. It also catches the reverse case: an ADU or JADU without added parking that's been over-specced for EV infrastructure it never owed.