Question 9: What are your views on the proposed minimum requirements for ZEVs (emissions, minimum range and warranty)?
A majority of those who responded to this question disagreed with the proposed minimum requirements for ZEVs though views differed across the minimum technical specifications.
On warranties, many welcomed the proposals as helpful for consumers. Most were content with specifications for cars but several vehicle manufacturers and some fleet operators suggested that battery degradation may be higher for vans given the different use cases and that the specification should be aligned with existing and emerging international standards.
On minimum range, many welcomed this as something that would give a positive experience for users, build consumer confidence, and support the fledgling second-hand market. Logistics sector stakeholders supported the need for suitable vehicles with an appropriate minimum range and other respondents expressed concern that 120 miles could be viewed as the lowest common denominator. Others viewed it as a minimum that should not be increased, with some making the point that the specific requirements should be subject to review.
Several respondents, including several vehicle manufacturers, expressed the view that the market could decide what range is needed and no minimum should be required, indicating a potential role for smaller range vehicles for some use cases, and that the proposals could limit consumer choice. Concern was raised that special consideration should also be given to multi-stage-build vehicles, given the different uses and unique testing protocols in this segment of the market.
On emissions, there was general agreement that the definition should be 0 grams CO2/km and that the definition should be simple. Opinions were split on alternative fuels and e-fuels with some respondents in favour and others against. Some sought clarification on the role of hydrogen combustion, while others suggested that zero nitrogen oxides (NOx) emissions should be added to the criteria.
Joint response
We will implement the warranty requirements for cars as proposed. We acknowledge the challenges presented by battery warranty requirements for some vans and will amend battery warranty from 70% to 65% capacity at 8 years/100,000 miles, aligning with the international United Nations Economic Commission for Europe (UNECE) standards that are under development with a minimum of 3 years or 60,000 miles (whichever comes first) for the remainder of the vehicle.
We define a ZEV as vehicle that has 0 grams CO2/km according to the Worldwide Harmonized Light Vehicles Test Procedure (WLTP). We will retain the existing convention that fuel cell electric vehicles are classified as 0 grams CO2/km. Our definition of a ZEV will not include other targeted greenhouse gases (GHGs) under the Climate Change Act, such as NOx, because there are no current internationally agreed testing regimes for cars that test for these. Any vehicle, regardless of drivetrain technology, could qualify as a ZEV under this regulation, should they be considered to emit 0 grams CO2/km.
We will reduce the minimum range by 20 miles from 120 to 100 and exempt ZEVs that have a range lower than 100 miles but that received, in 2023 or earlier, a type approval that is valid in the UK from that requirement. For multi-stage vans (MSVs), range is taken from the base model.
We will keep minimum requirements under review and consider changes as appropriate, as technology and consumer requirements develop.