Why China should not postpone implementation of the China 6 emission standard for new cars

In late February of this year, the China Association of Automotive Manufacturers wrote a letter to the Ministry of Ecology and Environment requesting, on behalf of the Chinese automotive industry, a six-month delay in the nationwide implementation of China Stage 6 Limits and Measurements Methods for Emissions from Light-duty Vehicles (the China 6 standard). The standard applies to light-duty vehicles and is scheduled to be implemented at the national level in two phases, China 6a starting on July 1, 2020 and China 6b starting on July 1, 2023. Weeks after the letter, an automobile magazine further clarified that the industry is essentially seeking two accommodations: (1) allow the sale and registration of their stock of China 5 vehicles for an additional six months, until December 31, 2020; and (2) delay the implementation of the particle number (PN) limit of 6 x 10^11#/km required in the standard, also for six months.

The ICCT believes that this delay is neither needed nor wise. For the following reasons, it would not benefit the Chinese economy, the auto industry, or, most importantly, public health.

• Since March 2020, auto sales have shown strong evidence of rebounding. There is sufficient time for the industry to sell the China 5 and transitional China 6-PN12 vehicle inventories and for a complete shift to the China 6 standard, including the final PN limit, on July 1, 2020.
• China 6 cars already dominate the new vehicle market and the vast majority of car manufacturers are well prepared. Any delay would simply penalize these early technology adopters and reward technology laggards. 
• The requested delay would result in extra emissions of 0.5–2.8 x 10^24 numbers, or approximately 610 tonnes of fine particles, about 440 tonnes of black carbon (a strong global warming agent), and about 310,000 tonnes of nitrogen oxides (NOx) over the lifetime of these vehicles. The total societal cost is estimated to be CNY3.1 billion, which possibly outweighs any short-term benefit to the few automakers that would take advantage of the delay.

Lastly, China is not without other alternatives. For one, India was recently successful in leapfrogging from Euro 4-equivalent BS IV to BS VI vehicle emission standards, which are roughly equivalent to Euro 6 and China 6 standards. While India is a different context and therefore not totally comparable, the only concession made was short—after the Coronavirus lockdown is lifted, car dealers will be given an extra 10 days to sell BS IV vehicles. This could be an encouraging example for China.