Zero emission vehicle mandate review

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.

Introduction

Consumer Scotland welcomes the opportunity to contribute to this consultation on the review of the Zero Emission Vehicle Mandate. From a public policy perspective, we recognise the issues involved as set out in the consultation document, including national resilience to fossil fuel price shocks, electricity grid balancing, reduction of carbon emissions, and improvements in local air quality, while at the same time providing a sustainable pathway to new markets for industry.

Ultimately, however, delivery of these benefits depends on decisions made by individual drivers to adopt an EV. Those decisions in turn depend on EVs offering a more attractive experience to petrol or diesel alternatives for drivers.

Our response concentrates on this consumer perspective. Our remit includes promoting sustainable consumption of natural resources, and our cross-market research in support of this aim shows that, regardless of their views on climate change as an issue, consumers’ behaviours in practice are influenced to a high degree by cost, convenience, clarity and confidence.

Our EV work is entirely consistent with this framing. Our research includes online surveys with EV drivers in Scotland in 20241 and 2026, together with focus group work with EV drivers not able to charge at home. Our research shows that:

• Drivers are concerned about costs, including of EVs themselves but more strongly in relation to running costs
• The convenience of EV charging varies hugely for drivers, depending on whether or not they can charge at home
• To underpin wider EV take up, drivers need clarity and confidence, most immediately around experience of the public charging network in terms of reliability, accessibility and costs

Given this background, although ownership is widening, it is not surprising that take-up of EVs in Scotland remains concentrated among better off households with access to private parking, which allows them to charge at home. As highlighted in the consultation, home charging offers both convenience and very significant direct financial savings to drivers compared to petrol and diesel costs.

However, our research also shows clearly that EVs do not as yet offer as attractive an experience for drivers unable to charge at home and who therefore depend on the public network. For those drivers, EV charging is at present much less convenient, and at least as expensive, as running a 
comparable petrol or diesel car.

While our research also shows that overall driver satisfaction with both EVs and the public charging network rose between 2024 and 2026, there remains a need for continuing further improvement of the charging network in particular. Without such improvement, there is a risk that the achievement of the wider public benefits highlighted in the consultation document.

For consumers, the ZEV mandate is therefore important for three reasons: 

• It gives a signal to consumers, as well as to industry, on the direction and speed of change and of long term Government commitment. However, the mandate is less influential on consumers directly than through the influence it has on the industry sector providing EVs and services to consumers
• It influences the offers the automotive industry now makes, and will make in future, to potential drivers at the point of sale, including pricing
• It influences decisions of investors in the public charging network, in turn impacting the speed of growth and improvement of the charging network, which remains the key issue for EV drivers

More widely, we recognise that, as the consultation states, adoption of new technologies tends to follow an S curve, with a slower start followed by faster growth and then a final slower period. This pattern is clearly evident in the pattern of purchase of new EVs in Norway, for example.

The proposed changes in targets contrast with this pattern. We therefore consider that softening the approach now is likely in practice to make achievement of the 2030 and 2035 targets significantly more challenging.  

We expand on these points in relation to selected consultation questions below and we would welcome the opportunity to expand on these points at any time.

Our response  

Question 1: Do you think any change is required to the current ZEV Mandate trajectory for cars? Please explain your answer including any supporting evidence.

As the consultation notes, the Mandate has and continues to deliver the task for which it was designed, evidenced through the rising proportion of new vehicles which are EVs. As outlined in our introductory comments, our research shows that, for consumers to continue to adopt EVs, they must be offered an attractive proposition. In practice, this involves:

• Attractive offers for EVs at the point of purchase
• Confidence that the public charging network will continue to improve, and will offer affordable running costs, in turn requiring confidence on the part of investors in that network

Forthcoming research by Consumer Scotland suggests that while even many current EV drivers are unaware of the existence or detail of the Mandate at present, they are nonetheless benefiting from its delivery. Against this background, it is more important for consumers that government puts in place appropriate safeguards and monitoring to ensure the above success factors are not undermined, than that specific targets in the Mandate itself are maintained or changed. In particular, there is a need – at present being met – for expansion of the EV fleet and public charging network to expand in parallel.

Question 2: What are your views on the current ZEV Mandate car trajectory, and the four alternative car trajectories presented? Which, if any, is your preference? Please explain your answer including any supporting evidence.

While we are not able to comment on the detail of the specific proposals, we recognise that, as the consultation states, adoption of new technologies tends to follow an S curve, with a slower start followed by faster growth and then a final slower period. This pattern is clearly evident in the pattern of purchase of new EVs in Norway, for example.

The proposed changes in targets all imply a change in the curve, to lessen the targets over the next few years, while retaining the end goal of EV sales on by 2025. The revised trajectories all imply steeper gains in the share of EVs sold in the latter years compared to earlier ones, which contrasts with the highlighted S pattern.

As the consultation recognises, the Mandate drives industry investment in public charging infrastructure. Without this, EVs will be less attractive to drivers. We therefore consider that softening the Mandate in the next few years is likely, in practice, to make achievement of the 2030 and 2035 sales targets significantly more challenging.

Question 16: What are your views on introducing a V2G/V2H credit, including the proposed approach to technical eligibility criteria, and any additional criteria (if any) the UK and Devolved Governments should consider? Please explain your answer including any supporting evidence 

While we are not able to comment on the detail of a proposed credit, we would want to see V2G/V2H encouraged and supported generally. There are three reasons for this:

Firstly, access to bi-directional charging is likely to make EVs more attractive to individual consumers as it offers the opportunity to use their EVs as ‘batteries on wheels’, allowing them to store electricity when available at lower cost, for later use or for export

Secondly and related, this helps balance the grid, potentially reducing overall costs for all electricity consumers by helping balance peaks and troughs in the electricity grid, and also by avoiding investment which would otherwise be required in industrial scale battery storage – which would in turn raise prices to recover investment costs

Third, bi-directional charging can also play a role in providing security of supply during power cuts – of particular value for disabled people who depend on electrically powered medical devices. This approach is currently being explored at pilot project level. We would also note that these benefits will almost entirely be experienced by those who can charge at home. This again emphasises the need to consider the circumstances of drivers who cannot do so, and to identify parallel approaches wherever possible.

Question 20: What are your views, if any, on whether compliance payments should remain at current levels? Please explain your answer including any supporting evidence.

While we are not able to comment on the detail of compliance payments, our understanding is that they provide a clear economic incentive to manufacturers to transition to EVs, and to make attractive offers to consumers to achieve that. If compliance payments are to be changed, the 
Government should put in place appropriate monitoring and safeguard to ensure that current progress is not undermined.

Question 28: What are your views on the effectiveness of current measures to support EV uptake? What if any additional measures should be introduced to support more rapid EV uptake? Please explain your answer including any supporting evidence.

It is important to note that EVs are now, by some distance, the most popular low carbon technology adopted by consumers, by comparison with take up of solar PV or heat pumps. Current measures are therefore already proving comparatively effective.

However, our research shows that there remain three areas where further work will be needed.

Firstly, there is evidence of an information challenge. Although satisfaction with the information provided by dealers at the point of EV purchase has improved over recent years, information concerns have increased overall. This suggests a continuing need for the promotion of clear and objective information and addressing mis- and dis-information.

Secondly, as current patterns of take up and our research both show,  drivers moving to EVs are most influenced by cost. Those able to charge at home and therefore make the most substantial savings are much more likely to adopt an EV than those unable to do so. Hence, the most significant challenge is to replicate as far as possible the home charging experience for those unable to do that because of their housing circumstances.  

Thirdly, our research with EV drivers unable to charge at home highlights the need for considerable improvement in that experience in terms of convenience as well as cost.

Those drivers were aware of the binary split between their own and home charging drivers experience. At present, they recognise EV ownership is a choice, but they also felt strongly that improvement of the charging network would be a necessary prerequisite to EVs becoming more widespread among people in their circumstances.

In practice, we consider this could translate as a significant expansion in slower, lower cost, on street AC chargers, so that such chargers are available to drivers in places they would park overnight anyway. Such a pattern of charging would also place less strain on grid and generation 
capacity than relying only on rapid and ultra rapid chargers.

In summary, measures which make EVs more attractive to consumers only at the point of purchase while relying on private investment in charging are not likely to be sufficient. At present, charge point operators and investors are more likely to concentrate on fast chargers in profitable areas.

Question 38: What are your views, if any, on the current design of the car club credit? Please explain your answer including any supporting evidence.

While we do not take a view on the detail of the credit, we recognise that car clubs provide both a general solution to car access without ownership and a chance for consumers to experience EVs as drivers without commitment.