How electric laggards can hit 22% EV mandate in 2024

23 October 2023

“There’s not 22% of demand out there,” Autocar has been told

Several brands sell far fewer than 22% electric cars, and private sales are stagnating

Discounts, more launches of small cars and unlikely alliances are all viable tactics for those car makers least strong on EVs as they look to comply with the government order that states almost one in every four cars they sell next year must be electric.

Car makers have to boost demand from the average 16% EV share in the UK to the end of September to 22% next year or face fines of £15,000 for every car they are shy of the target.

Several brands – including Ford, Toyota, Suzuki, Mazda, Honda and Land Rover – recorded EV sales of between 0-3% of their total in the 12 months to the end of September, according to figures from market analysts Dataforce.

Without higher EV sales from sibling brands to offset their shortfall, these car makers will be in danger of having to shell out fines totalling millions if they can’t find a way sell more electric cars or offset the shortfall using some of the loopholes allowed by the government order.

The so-called zero-emission vehicle (ZEV) mandate technically includes any zero-CO2-emission vehicle as measured at the tailpipe, which includes fuel-cell-powered vehicles. However, given the lack of an alternative, effectively it’s an order to sell more battery-electric cars.

The problem for car makers is that three-quarters of all EV sales to the end of September went to fleets, with private sales actually falling 14% in September. With minimal incentives available, private buyers are still not convinced in large enough numbers to pay higher prices for EVs.

“There’s not 22% of demand out there,” one senior automotive executive said, on condition of anonymity.

Car makers have called for a return of subsidies for private buyers to boost sales away from fleets. Manufacturers without strong EV sales will have to deploy a range of strategies or face fines, something that every company Autocar spoke to said they were keen to avoid.

“It’s going to take some managing in the coming year and beyond, especially after the Sunak intervention last month around the 2030 date,” said Richard Peberdy, UK head of automotive and mobility at consultants KPMG.

That’s a reference to prime minister Rishi Sunak’s decision to postpone the ban on most combustion-engined sales to 2035, something the ZEV mandate ratification as good as reverses given the need to have 80% EV sales by 2030. “It puts the OEMs in a tough spot,” Peberdy said.

ZEV mandate: the credit loophole

Car makers are allowed to exploit a series of loopholes, of which perhaps the biggest is the agreement that they can ‘borrow’ against future over-compliance. So if they think they can beat the (tougher) EV targets, in say, 2026, they can sell more combustion-engined cars in 2024.

A source close to JLR (formerly Jaguar Land Rover) said this was how it was going to overcome the fact that it sells only the Jaguar I-Pace currently and won’t have its new electric Range Rover until later next year.

Another loophole is to transfer over-compliance of CAFE (corporate average fuel economy) targets to offset up to 65% of the shortfall. That rewards those that sell higher percentages of plug-in hybrids, helping, for example, Ford.

Companies can also buy credits from the likes of EV-only brands like Tesla, Polestar or BYD, or from those who over-index on EVs, like MG (41% of sales in the 12 months to the end of September).

What car makers can’t do is ‘pool’ with a competitor, as has been allowed with CO2 targets, unless they’re in the same broader company (eg Volkswagen Group or Stellantis brands). This could lead to the creation of ‘joint-venture alliances’ between established companies and EV newcomers – for example, China manufacturers perhaps in exchange for access to retail outlets, Peberdy predicted.

Car makers can also earn an extra half credit per electric car by selling EVs to car-share schemes such as Zipcar, or even earn credits selling EVs to companies converting them for use by disabled people.

But loopholes can only cover so much shortfall. “Where the gap to the target is significant, at some point the cure becomes worse than the disease,” Peberdy said. “Some OEMs will need interventions to push them over the line.”

KMPG predicts tactics will include holding back EV models to the start of the year so they’re included in the 2024 figures. This is what Honda has said it will do with the introduction of the new e:NY1 electric small SUV, a car on which the company is pinning its hopes to meet the ZEV mandates.

ZEV mandate could mean cheaper electric cars

We can expect to see more discounting, low-interest rates and other incentives to make EVs more appealing, at the cost of car maker profits.

Small cars, including city cars, could make a comeback, given that the mandate doesn’t distinguish between the sale of small and large EVs. For example, Citroën and the wider Stellantis group will be using the new ë-C3 small electric car that will start at around £20,000 when it arrives next year (although too late to properly feed into the 22% target).

Dacia, meanwhile, will finally bring the Spring electric city car to the UK starting in 2024 with an expected start price of below £20,000.

What is clear is that strategies won’t depend on just a couple of big decisions on new models, but more on constant assessment of what’s selling, where to apply discounts to stimulate one model over another while keeping the financial department happy, and threading together the help from different loopholes.

As a spokesman from Mazda said: “Until we are seeing what we are selling and our CO2 value, we are remaining fluid on what levers we will pull.”

We asked the EV laggards how they planned to reach the target

(EV share based on 22 October to 23 September figures. Source: Dataforce)

Mazda

EV sales: 3%

“Our plans will result in us remaining penalty-free”

New EV models coming from 2025. Now relying on slow-selling MX-30 EV, but will hope to harvest CO2-goal overshoot from current CX-60 and new MX-30 plug-in hybrids

Ford

EV sales: 2%

“We will always comply with regulations”

Has addressed slow sales of the Mach-E electric SUV with recent £7000 price cut and will open order book on new model with cheaper LFP battery in “next few weeks”. Will launch new Explorer compact SUV on the Volkswagen Group MEB platform in summer next year

Toyota

EV sales: 1%

No response to our question, but will offset slow sales of bZ4X electric SUV with over-performance on CO2 targets thanks to hybrids and plug-in hybrids

Land Rover

EV sales: 0%

“JLR supports the ZEV mandate”

JLR can’t rely on Jaguar I-Pace sales (27% of Jaguar total) to pass ZEV so needs a strategy beyond offsetting its potential CO2 overshoot on strong plug-in hybrid sales as it waits for the Range Rover BEV. Will look to ‘borrow’ from over-compliance in future years, according to one source

Suzuki