What is the UK Government's new Zero Emission Vehicle (ZEV) Mandate?

6 minute read
03 May 2023

In 2021, the UK signed the COP26 global climate change declaration to transition to 100% zero emission car and van sales by 2035 (as a "leading market").[1] Last autumn, the Government's Net Zero Strategy (NZS) confirmed that the UK will adopt a zero emission vehicle (ZEV) mandate.

The UK Government published a consultation, 'Policy design features for the car and van zero emission vehicle (ZEV) mandate'[2], in April 2022 (the "ZEV Mandate Consultation") which included proposals for how the ZEV Mandate would operate. The outcome of that consultation was published on 30 March and confirms that the Government will require car manufacturers from 1 January 2024 (until 2035) to meet ZEV targets. The ZEV Mandate will have a significant impact on the car industry and will change the way car manufacturers sell cars in the UK.

What is the ZEV Mandate?

The ZEV Mandate will introduce ZEV targets that will require an increasing percentage of a manufacturer's annual new car and van sales in the UK to be zero emission until reaching 100% in 2035. This will be accompanied by a CO2-based regulatory framework for the new non-ZEV fleet, ensuring that emissions from these vehicles do not increase over time.

The ZEV Mandate will introduce a trading scheme that includes allowances and credits. Manufacturers will receive allowances to sell non-ZEV vehicles up to a given percentage of their fleet of new cars and vans, with the intention that ZEVs account for the remainder of sales (the ZEV target).

The consultation outcome confirms that the Government will adopt the proposed ZEV target for cars requiring car manufacturers to sell a minimum percentage of electric vehicle (EV) cars between 2024 and 2035 as set out below:

  • 2024: 22%
  • 2025: 28%
  • 2026: 33%
  • 2027: 38%
  • 2028: 52%
  • 2029: 66%
  • 2030: 80%
  • 2031: 84%
  • 2032: 88%
  • 2033: 92%
  • 2034: 96%
  • 2035: 100%

To qualify as a ZEV, new cars and vans will need to meet certain minimum eligibility criteria. Manufacturers will have the possibility of earning additional credits for deploying ZEVs for use in specific applications, such as car clubs.

Derogations from the ZEV mandate requirements will apply for manufacturers selling less than 2,500 cars or vans per annum (small volume manufacturers, SVMs).

Each manufacturer's specific, non-weighted average CO2 emissions from the year 2021 will be used as the baseline to regulate the non-ZEV portion of the fleet.

Exceeding the minimum requirements of the ZEV mandate can be used to offset non-compliance with the non-ZEV CO2 regulation.

During the years 2024 to 2026, any overachievement against the minimum requirements of the new non-ZEV CO2 emission targets can be used to offset non-compliance with the ZEV mandate, though this will be capped.

What happens next?

The consultation outcome confirms the Government's intention to bring legislation before Parliament in 2023. For both new cars and vans, the ZEV mandate and CO2 regulation are planned to enter into effect on 1 January 2024. We will be keeping an eye on the introduction of legislation that is brought before Parliament in respect of the ZEV Mandate and will provide an update in due course.

If you would like to speak to us about any sustainability issues presented in this article, including how your organisation can take steps to comply with the ZEV Mandate, please contact either associate Ben Sasson or sustainability partner Ben Stansfield.


[1] COP26 declaration: zero emission cars and vans - GOV.UK (www.gov.uk)

[2] Policy design features for the car and van zero emission vehicle (ZEV) mandate - GOV.UK (www.gov.uk)

NOT LEGAL ADVICE. Information made available on this website in any form is for information purposes only. It is not, and should not be taken as, legal advice. You should not rely on, or take or fail to take any action based upon this information. Never disregard professional legal advice or delay in seeking legal advice because of something you have read on this website. Gowling WLG professionals will be pleased to discuss resolutions to specific legal concerns you may have.