Meeting the Mark: Aligning regulations and standards with ZEV targets
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What the European Union can learn from the United Kingdom’s EV success in 2024—and what’s next on both sides of the Channel
From 2020 to 2023, the United Kingdom and Germany battled among large countries in Europe for the highest sales share of battery electric cars, and as 2023 drew to a close, Germany had the upper hand (Figure 1). By 2024, however, the situation had reversed: The United Kingdom finished the year with a battery electric vehicle (BEV) sales share of 19% (up from 16% the year before) while Germany’s share fell to 13% (from 18% in 2023). This was enough to give the United Kingdom the crown not only in BEV sales share among large European countries but also the top spot in BEV sales volume, despite having a smaller car market than Germany.
This was no fluke. The UK zero-emission vehicle (ZEV) mandate, which sets targets each year from 2024 to 2030, played a crucial role in boosting sales. In contrast, regulations in the European Union did not tighten and thus created no incentive for manufacturers to increase BEV sales. This is the latest evidence that ambitious and consistent regulations can help accelerate the market transition to cleaner transportation, and it offers lessons for other regulators.

Source: Dataforce
With the United Kingdom’s performance, achieved without substantial purchase incentives, it’s also hopefully clear that the fears of an “electric shock” in the press in late November 2024 were unfounded. Indeed, as the ICCT’s response to an official UK government consultation to review the ZEV mandate highlighted, there are important benefits from staying the course and keeping compliance flexibilities to a minimum. Finalizing the next stage of the ZEV mandate that covers 2031–2035 soon would also align the United Kingdom with California, Canada, and the European Union, all of which have a binding 100% ZEV requirement for 2035.
An effective framework
The UK ZEV mandate sets annual targets for the percentage of new cars and vans sold that must be ZEVs, and it must be met by every manufacturer. (While both BEVs and hydrogen fuel-cell electric vehicles are ZEVs, the vast majority of zero-emission cars sold around the world today are BEVs.) The ZEV mandate is complemented by a carbon dioxide (CO2) emission standard for all non-ZEV vehicles to ensure that emissions from those vehicles don’t rise through 2030.
For new cars, the mandate called for 22% ZEVs in 2024 and that increases to 80% in 2030. There are limited flexibilities in the mandate, including credits for selling non-ZEVs with lower CO2 emissions, and the flexibilities are designed to be carbon-neutral over the long term while allowing manufacturers to pursue their own strategies. Although the 19% share of battery electric cars in 2024 was slightly below the mandated target, it should still be sufficient for compliance when factoring in these flexibilities.
This regulatory framework not only supports strong sales but also gives charging providers the confidence to invest ahead of demand. This was emphasized in a letter from industry association ChargeUK this past fall. In addition to the private sector investments in charging, the UK government is contributing with programs like LEVI and the Rapid Charging Fund. As the United Kingdom lacks the certainty provided by EU Alternative Fuel Infrastructure Regulation (AFIR), the ZEV mandate is especially crucial for supporting continuous charging buildout.
A pivotal year for EU CO2 standards
The EU CO2 emissions target for cars has been the same since 2021 and in 2025, manufacturers are required to meet a new target, a 15% emissions reduction relative to 2021. With this in place, we expect sales of battery electric cars in the European Union to be similar to those in the United Kingdom by the end of the year, giving Germany and other countries a chance to claim the crown.
However, the stepwise design with new targets every 5 years is a weak spot in the EU regulation due to the lack of consistent incentives. Once targets are met, manufacturers show little interest in further reducing CO2 emissions, and as new targets approach, they rush to deliver these reductions. Figure 2 compares the annual targets in the United Kingdom and European Union. Though the two markets should see similar average CO2 in 2025, and will both end up at zero in 2035, the consistent reductions in the United Kingdom should give them the edge in ZEV sales in the years in between and lead to lower cumulative emissions as the fleet slowly turns over.
Figure 2. Fleet-average CO2 emissions from regulations in the United Kingdom (including those proposed for 2031–2035) and the European Union

All of that said, this week’s European Commission proposal could further delay the European Union’s progress. As part of the ongoing Strategic Dialogue on the future of the automotive industry, the Commission is set to propose a new mechanism to extend the deadline for compliance with the 2025 target through 3-year averaging. In practice, this is a relaxation of ambition. Additionally, introducing any changes at this point risks disrupting planning and investment and confusing consumers. There is already good certainty from the European Union’s 2035 ZEV requirement and the AFIR targets for charging infrastructure, and it’s important to support those by following through on the CO2 targets, including fines in cases of noncompliance starting with 2025. Changes now could create confusion about market progress and be counterproductive to both a competitive vehicle market and climate goals.
Despite holding a consultation on the nuances of the regulation, the UK government is not considering any weakening of the adopted 2024–2030 targets or suspending fines for non-compliance. It’s also not retreating from its commitments to end the sale of new gasoline and diesel cars from 2030 onward and for all new cars and vans to be ZEVs from 2035 onward. That’s wise, because the UK ZEV mandate proves that sticking to predictable targets delivers positive results in the electric car market. Now, the government can focus on finalizing the 2031–2035 targets, introducing a strong-but-feasible non-ZEV requirement in 2030, and working on a regulation for heavy-duty vehicles, as the United Kingdom still has no answer to the European Union’s strong heavy-duty CO2 standards.
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