Which automakers support EPA’s proposed greenhouse gas emissions standards? There are more than meet the eye.

In 2008, U.S. taxpayers bailed out U.S. automakers to the tune of billions of dollars. What did we get in exchange? Among other things, a promise that automakers would do more and better to promote cleaner vehicles. They’ve had lots of chances to make good on that promise in the last 15 years. In fact, their latest opportunity came in April 2023, when the U.S. Environmental Protection Agency (EPA) announced its latest proposal on multi-pollutant emission standards for Model Year (MY) 2027 and later light-duty and medium-duty vehicles.

The proposal aims to reduce harmful emissions of greenhouse gases (GHG) and criteria pollutants, improve public health, and save drivers money through reduced fuel and maintenance costs. To comply with proposed standards, automakers would have to manufacture and sell new passenger cars and trucks that emit substantially less pollution. Unfortunately, EPA’s proposal was with a wide range of public responses, including attacks that pushed false information and ignored major net benefits.

Most automakers have also weighed in publicly on EPA’s proposal in some way. Several have expressed support. But even automakers that don’t seem to support the new proposal actually do support what the proposed regulation would do, in some ways.

At first glance, automakers are all over the map in their responses to EPA’s proposal, though several support at least one of EPA’s proposed alternative regulatory pathways, even if they haven’t said so explicitly. Table 1 summarizes the positions of 19 automakers based on their public comments, broadly lumped into five categories: 1) those that support EPA’s most stringent regulatory alternative; 2) those that support EPA’s central proposal; 3) those that support the slower-ramp alternative; 4) those that support aligning standards with up to 50% electric vehicle sales by 2030; and 5) those that oppose EPA’s rule entirely.

We found that three companies (Lucid, Rivian, and Tesla) recommend EPA adopt the most stringent Alternative 1. One automaker, Volvo, supports EPA’s central proposal. Four companies (Ford, Mercedes-Benz, Stellantis, and Volkswagen) recommend Alternative 3, which has a slower emission reduction rate in early years but ends at the same GHG emission target as the central proposal in 2032. Ten companies (BMW, General Motors, Honda, Hyundai, Jaguar Land Rover, Kia, Mitsubishi, Nissan, Subaru, and Toyota) suggest that EPA align more closely with either the Biden Administration’s goal or the Alliance for Automotive Innovation’s recommendation for adopting requirements for up to 50% battery-electric, plug-in hybrid, and fuel cell vehicles by 2030. Only one company, Mazda, opposes the EPA’s proposal entirely.

Table 1. Summary of automaker public comments on EPA’s proposed GHG standards

Automaker	Support most-stringent Alternative 1	Support the central proposal	Support Alternative 3	Support up to 50% EV sales by 2030	Oppose
Lucid	x
Rivian	x
Tesla	x
Volvo		x
Ford			x
Mercedes-Benz			x
Stellantis			x
VW			x
Hyundai				x
GM				x
JLR				x
BMW				x
Honda				x
Kia				x
Mitsubishi				x
Nissan				x
Subaru				x
Toyota				x
Mazda					x

However, since EPA’s proposal is a per-mile GHG emission standard, automakers could choose from many options to meet requirements. For example, there are numerous cost-effective pollution-reducing combustion and zero-emission technologies available today that automakers could pursue to comply.

Table 2 illustrates just a few potential compliance pathways. The internal combustion engine (ICE) vehicle fleet, as modeled in the proposal, shows an average 0.1% annual emission reductions in MY27–2030, which corresponds with a projected 60% battery electric vehicle (BEV) share by 2030 to comply. With improved ICE performance however, the number of BEV sales needed to comply with the rule is reduced. As shown, an ICE improvement of 3.5% annually corresponds with a 50% 2030 BEV share to comply, and a 5% annual ICE improvement corresponds with 46% BEV sales. If automakers improve ICE by 5% annually and sell 10% plug-in hybrid electric vehicles (PHEVs), then 40% of new sales would need to be BEVs in 2030 to comply. From this analysis, we find that automakers who sell 40% to 50% plug-in electric vehicle sales by 2030 would still comply with EPA’s proposal as long as they also improve their gasoline cars.

Table 2. Illustrative compliance pathways to meet MY2027–2030 proposed standards

	Proposal	1%/year	3.5%/year	5.0%/year	5%/year and 10% PHEV sales share
Assumed ICE annual emissions reductions MY27-30	0.1%	1%	3.5%	5.0%	5.0%
Net MY27-30 ICE improvement*	0.4%	3.7%	13%	18%	18%
Projected MY2030 BEV share	60%	55%	50%	46%	40%

* Net improvement is fleet average, weighted by the share of ICE cars and ICE trucks.

That means that, in fact, 18 of 19 automakers that submitted public comments support BEV targets that are aligned with EPA’s proposal, even if they didn’t say so explicitly. Our analysis shows that with modest ICE vehicle improvements, a 50% or lower electric vehicle sales share in 2030 would meet EPA’s proposed standards. And all automakers but one are recommending that EPA align its standard with 50% or greater electric vehicle sales shares in 2030. Accordingly, EPA finalizing its proposed regulation as quickly as possible would help reduce pollution, save consumers money, respond to consumer demand for cleaner cars, and send the right long-term market signals that industry stakeholders need to confidently make investments that they’re already supporting anyway.