Consumer Scotland Submission to the UK Parliament Transport Committee Inquiry
About us
Consumer Scotland is the statutory body for consumers in Scotland. Established by the Consumer Scotland Act 2020, we are accountable to the Scottish Parliament. The Act defines consumers as individuals and small businesses that purchase, use or receive in Scotland goods or services supplied by a business, profession, not for profit enterprise, or public body.
Our purpose is to improve outcomes for current and future consumers, and our strategic objectives are:
- to enhance understanding and awareness of consumer issues by strengthening the evidence base
- to serve the needs and aspirations of current and future consumers by inspiring and influencing the public, private and third sectors
- to enable the active participation of consumers in a fairer economy by improving access to information and support
Consumer Scotland uses data, research and analysis to inform our work on the key issues facing consumers in Scotland. In conjunction with that evidence base we seek a consumer perspective through the application of the consumer principles of access, choice, safety, information, fairness, representation, sustainability and redress.
Consumer Principles
The Consumer Principles are a set of principles developed by consumer organisations in the UK and overseas.
Consumer Scotland uses the Consumer Principles as a framework through which to analyse the evidence on markets and related issues from a consumer perspective.
The Consumer Principles are:
- Access: Can people get the goods or services they need or want?
- Choice: Is there any?
- Safety: Are the goods or services dangerous to health or welfare?
- Information: Is it available, accurate and useful?
- Fairness: Are some or all consumers unfairly discriminated against?
- Representation: Do consumers have a say in how goods or services are provided?
- Redress: If things go wrong, is there a system for making things right?
- Sustainability: Are consumers enabled to make sustainable choices?
Why we are responding
Our 2023-2027 Strategic Plan[i] identifies three cross-cutting consumer challenges, which guide our work during this period:
- Affordability
- Climate change mitigation and adaptation
- Consumers in vulnerable circumstances
In addition, one of Consumer Scotland’s statutory outcomes is to promote sustainable consumption.
As part of our work on climate change, we have been working since 2023-24 on consumer views and adoption of Electric Vehicles. In 2024, we published research[ii] based on the experience of both current and prospective EV drivers in Scotland.
Key headlines emerging from that research were that EV drivers at that time were very satisfied with their vehicles, but that further work was needed to:
- significantly improve the public charging network, particularly in areas with housing types such as flats where consumers are unlikely to be able to charge at home
- reduce the cost of public network charging
- improve information on the performance of EVs in advance of purchase including seasonal variations in battery range and degradation in battery life
- consider the need to increase capacity of servicing and repair as the second-hand EV market develops
Following the publication of the research, we continue to engage with stakeholders on actions to address the concerns raised by drivers at that time, within broader contexts of climate change, transport and energy policy.
We are currently carrying out further research to:
- Explore, in detail, the current experience of EV drivers unable to charge at home and therefore dependent on the public charging network, as well as their views on measures which would best improve their experiences; and
- Update our 2024 survey evidence of the experience of EV drivers more widely
Our Submission
a. How effective have Government policies been in driving EV adoption to date, and what further action is required to accelerate take-up?
b. How robust is the current rate of EV take-up relative to the Government’s targets?
When we carried out our initial research in March 2024, 34,254 privately registered battery electric cars were registered in Scotland. As of June 2025, that number had risen to 54,047[iii]. These figures do not include company owned vehicles on the road in Scotland.
While this represents a small proportion of the total fleet - as a comparison, at the end of June 2025 there were 2.4 million privately registered cars in Scotland - it nonetheless also represents a significant shift in consumer behaviour. Our wider work includes consideration of the take up by consumers of domestic low carbon technologies (solar PV, heat pumps, home batteries). By comparison with those technologies, EV take up in Scotland by private consumers is faster.
At UK level, the proportion of new cars which are EVs is rising[iv] and represents a rather higher proportion of all cars than the private figures in Scotland suggest. This suggests that EV take up is driven in part by the company car market.
Our wider work on consumers and climate change[v] has consistently found that, whatever their views on climate change as an issue, consumers’ day to day behaviours are most clearly influenced by cost, convenience, clarity and confidence.
Both our own and other research[vi] shows that patterns of EV adoption are entirely consistent with this framework; adoption of EVs is concentrated among drivers who are able to charge their cars at home – and who very largely do so - generating substantial savings in running costs and with minimal inconvenience compared to running a petrol or diesel vehicle.
On the other hand, our research also found that EVs are a much less attractive proposition for drivers dependent on the public charging network, given rather lower levels of convenience and typically significantly higher costs.
Our research showed that concerns about different aspects of EV ownership, including around charging and battery life, fell consistently throughout the journey: EV drivers were much less concerned about these issues than the same drivers were before purchase, and in turn all drivers were less concerned than those considering an EV purchase.
Recent surveys[vii] suggest that many petrol and diesel car drivers would not at present consider an EV as their next purchase. This emphasises the need for clear and consistent information, as well as improvements to the cost and convenience of the public charging network.
Overall, Consumer Scotland’s view is that the transition from petrol and diesel to EVs is progressing positively. But, the transition will only continue if all consumers have a positive experience of EVs across all aspects of the customer journey, from information at the point of purchase, through all aspects of driving experience.
Improving the convenience of charging and – in particular in respect of running costs - reducing prices of public charging are central challenges that must be tackled.
c. How effective are existing incentives (such as the Electric Car Grant) in influencing EV take-up, and to what extent might further or different forms of support be required?
Our research shows that consumer behaviour in relation to climate change actions is strongly influenced by cost, convenience, clarity and confidence, and patterns of EV adoption are consistent with this.
From this perspective, financial support applied at the point of purchase helps bridge the price gap between EVs and petrol and diesel vehicles. However, a sizeable majority of UK drivers – 79% in 2023[viii] - never buy a new vehicle of any type and therefore do not benefit directly from subsidies on new vehicles. Although subsidies may reduce used car prices indirectly, limited supply and the newer age of the EV fleet means used vehicles may not currently be financially accessible to many potential drivers. We note that the Scottish Government, through the Energy Saving Trust, provides low-cost loans for used EVs for certain groups[ix], subject to budget limits, in recognition of this.
However, our research suggests the financial attractiveness of EVs is more closely related to their significantly lower running costs. In turn, those running costs – unlike for petrol or diesel cars – vary hugely depending on where EVs are charged. We therefore consider that action on public charging prices will have greater long-term impact on EV demand, and we expand on this in our answer to question d, below.
Hence, we would prefer to see a higher proportion of available public financial support being directed towards improvements to the public charging network, with explicit aims of improving access to, and significantly reducing the costs of, charging in residential areas where the majority of drivers will be unable to charge at home.
Such an approach would extend the attractiveness of EVs, especially to those living in towns and cities with associated improvements in air quality would have greater positive impact.
d. What are the likely implications of the introduction of Electric Vehicle Excise Duty (eVED) for the wider EV transition, and what factors should guide the Government’s approach to its implementation? What has been the effect of the introduction of VED on zero-emission cars since April 2025?
As above, the attractiveness of EVs for drivers is strongly linked to their running costs.
Zapmap provide typical costs, depending on charging pattern, for EV drivers covering 10,000 miles each year[x] on which the table below is based. The final two columns are Consumer Scotland calculations showing the impact of eVED on the cost differential between EV and ICE fuel costs.
|
Archetype |
Annual Cost (2025) |
Cost including eVED |
Cost differential EV / ICE inc eVED |
|---|---|---|---|
|
80% home charging, 20% rapid public |
£660 |
£960 |
Positive - £450 saving |
|
50% home charging, 25% slow public, 25% rapid |
£1100 |
£1400 |
Neutral - (£10 saving) |
|
80% slow public charging, 20% rapid |
£1750 |
£2050 |
Negative - £640 more expensive |
|
ICE |
£1410 |
£1410 |
N/A |
As the figures show, for those able to charge at home and who rely less frequently on the public network, EV ‘fuel’ running costs, even with the proposed eVED charge included, are much lower than petrol or diesel cars.
In contrast, the financial incentive for EV drivers more dependent on the public network is currently smaller and can already be negative for those fully dependent on the public network. The introduction of eVED will significantly impact the attractiveness of EVs for these drivers. While the absolute costs will be lower for those driving shorter annual distances, the relative position of costs will remain similar.
There is a significant associated risk that the introduction of eVED will create a push away from EVs. The introduction of a similar charge for EV drivers in New Zealand occurred alongside the removal of the Clean Car Discount, a purchase subsidy, and an increase in national insurance charges for EV owners[xi], creating a combined reduction in financial incentives. As a result, the relative cost of EV running costs rose to that at best equal to and sometimes significantly greater for petrol or diesel vehicles, again depending on charging location. Following these changes, the New Zealand EV market suffered a sharp decline in new car sales in 2025, falling to 4% from a previous peak of 19%[xii].
The introduction of a road user charge in Iceland was similarly followed by reduced rates of EV adoption, although to a lesser extent; EVs / PHEVs fell from a combined market share of 56% in 2022 but had partially recovered to 42% in 2025.[xiii]
This experience suggests that eVED will slow the take-up of EVs, but also that the scale of impact will depend on the degree of momentum behind the transition. While eVED is not intended to be introduced until April 2028, UK adoption rates[xiv] are currently closer to those in New Zealand than to those in Iceland at time of the respective changes were introduced.
More widely, Zapmap found a significant minority of drivers in the UK (43% in 2025) had access to both an EV and a petrol or diesel car, including hybrid vehicles. Our research found that drivers in that situation, while using their EV as their primary vehicle, often chose petrol or diesel for longer journeys. It is possible that the introduction of eVED could further influence the selection of vehicle for a particular journey away from EVs for drivers who have a choice, especially when that journey might already involve charging at a more expensive location.
In relation to other aspects of this question, we are not able to comment on the technical detail of eVED implementation, other than to emphasise the need for consideration of the consumer journey during the process, and the benefits of early testing to inform this.
We are not able to comment on any impacts of the extension of VED to EVs as introduced in April 2025.
e. How should the Government support further development of the second-hand EV market?
Complaints associated with the second-hand car market are consistently high, and this market is the subject of a current Consumer Scotland Investigation[xv]. While the EV fleet is currently relatively young, and therefore less likely to cause concern, it is important to consider additional issues related to EVs, particularly standardised information on battery health, which will be of specific concern to potential second-hand car drivers.
In addition, the information and financial measures discussed above in relation to the attractiveness of new EVs obviously also apply to used EVs.
In relation to up-front costs, the Scottish Government has, through the Energy Saving Trust, previously made available zero interest loans for second hand EVs. [1] Scottish Government figures[xvi] show that the purchase of some 8,700 used vehicles has been supported through the scheme, approximately 16% of all privately owned EVs in Scotland at the time the figures were published.
Decisions on the replication of such an approach and interaction with private sector financial offers at UK level are matters for the UK Government. We would however suggest that a similar scheme might offer two advantages:
- Making EVs a more accessible and attractive option for the significant majority of consumers, including those on lower incomes, who purchase a used, rather than new, car each year; and
- Helping develop the second hand market, and therefore adding confidence to buyers of new EVs who might be concerned about residual values
Concerns about the battery health of used EVs have also been identified as an issue of concern for consumers.[xvii] Clear, standardised information on this at the point of used EV sale has been suggested as a solution, and would be in line with our findings.
f. What are the most significant factors affecting consumer confidence in EVs, including purchase and running costs, chargepoint availability, concerns about battery longevity, safety and fire risk, and what are the best steps Government and the sector could take to address them?
Our 2024 research found no evidence of driver concern about safety or fire risk in either survey responses or focus group discussion, and purchase and running costs are covered in detail in responses to previous questions.
Of the other issues listed in this question:
Drivers participating in our research highlighted a range of issues around the public charging network, especially in relation to reliability and variations in cost and tariff structures, and frustration at the number of individual apps required for payment. We appreciate however that significant investments have been made in the charging network since our research was carried out, and more recent survey evidence[xviii] shows positive change in driver experience. Further, aggregated apps and the introduction of requirements to allow drivers to pay by contactless card at fast and rapid chargers may have improved the experience for consumers.
Following from our responses above, we consider that the most significant intervention Government could make would be to direct an element of financial support towards the expansion of the (slower) charging network, targeting areas where drivers would typically not be able to charge at home.
This should have the aims of firstly, improving the convenience of charging, and secondly, reducing the unit costs of use of those chargers – effectively seeking to replicate, as far as possible, the positive experience of those who are able to charge at home.
At present, private sector investment, not surprisingly, appears to be more directed towards rapid chargers on motorways and the strategic road network. While this is welcome, it will not be sufficient alone to encourage wider take up.
Drivers in our survey also raised issues about different aspects of battery performance, including battery life, variations from quoted range depending on driving style and weather conditions, and long term degradation. We appreciate that there have been improvements in EV technology, and it is not clear how far these issues remain critical for new vehicles; but, as above, information on battery health for used vehicles is likely to remain a critical issue underpinning consumer confidence in that market.
Lack of clear and consistent information on running costs of specific vehicles also remains a related consumer concern. While real world, technical information is already available[xix], it is not always accessible. A single source of information, ideally linked to a calculator, which allowed individual prospective drivers to compare costs taking into account their personal circumstances (car choice, range, driving style, location, etc), would be helpful. Both our own and other research has reported variable experiences in terms of the advice received from dealers by drivers at point of purchase.
g. What further action is required to ensure that the rollout of EV charging infrastructure facilitates transition at the necessary rate?
As public charging is a devolved issue, we are not able to comment in detail on this question. In general, however, survey evidence suggests that greater emphasis should be given on installation of slower chargers in locations convenient for drivers who cannot charge at home.
h. How effectively is the Department for Transport addressing issues in the rollout of charging infrastructure such as affordability, geographic equity, accessibility, administration of funding, and the availability of grid connections?
No response
i. What lessons should be learned from other countries' successes or setbacks?
Norway is the obvious country from which to learn in terms of success in relation to EV adoption. Consistency of approach across successive Norwegian Governments, including significant financial incentives at point of purchase, and associated roll out of charging infrastructure appear to offer clear lessons, as highlighted by stakeholders[xx].
In addition, more localised incentives – allowing EVs to use bus lanes, toll road discounts or exemptions, preferential public parking – are also employed in Norway. These, or parallel measures appropriate to local circumstances, could be promoted or translated to the UK. For example, in densely populated urban areas which make a charge for residents parking permits – and where access to home charging is likely to be more limited – discounts on parking could be an attractive additional benefit.
In relation to eVED charges in particular, the negative experiences of New Zealand and Iceland outlined above are also relevant.
Endnotes
[v] A consumer framework for addressing climate change - toolkit for policymakers (HTML) | Consumer Scotland
[vi] Zapmap EV Charging Survey 2025: driver satisfaction rises as hubs overtake motorway services - Zapmap
[xii] Will pay-per-mile raise Reeves money or drive people away from electric vehicles? | Electric, hybrid and low-emission cars | The Guardian
[xiii] Newly registered electric cars by country | New registrations of electric cars in Europe | European Environment Agency (EEA)
[xviii] Zapmap EV Charging Survey 2025: driver satisfaction rises as hubs overtake motorway services - Zapmap
[xix] For example, ClearWatt: The Second-Hand Electric Revolution