Consultation outcome

Outcome and response to the consultation on when to phase out the sale of new, non-zero emission HGVs

Updated 12 May 2022

Ministerial foreword

The UK’s road freight system is one of the most efficient in the world, contributing at least £13.6 billion to the UK economy each year. Heavy goods vehicles (HGVs) ensure our medicines are delivered, keep food on our shelves and facilitate the seamless transportation of goods we rely on. But our road freight sector also contributes harmful emissions, making up 19% of domestic transport’s annual greenhouse gas emissions (GHG) in 2020, and HGVs are a main source of roadside nitrogen oxides that are damaging to human health.

That is why zero emission HGVs are an essential, and why at COP26 in Glasgow last year, government announced phase-out dates to ensure all new HGVs are zero emission by 2040 at the latest. This important step puts the UK on course to be the fastest G7 country to decarbonise its fleet of heavy goods vehicles and will significantly reduce carbon emissions to safeguard our planet, reduce harmful pollutants in our towns and cities, create skilled jobs and reduce our reliance on fossil fuels, increasing our energy security.

With zero emission HGVs now appearing in increasing numbers, including many built here in the UK, now is the time to keep up the global momentum towards zero emission vehicles and accelerate the transition to zero emission road freight. Our approach is amongst the most ambitious anywhere in the world, which means the UK will be poised to capitalise on the benefits of this transition and grasp new opportunities for growth and innovation. We will work in partnership with the automotive and logistics industry to achieve a thriving zero emission road freight sector, helping to cut emissions while driving the UK to a brighter, greener future.

Trudy Harrison MP
Parliamentary Under Secretary of State for Transport

Introduction

Government is committed to going further and faster to tackle climate change by decarbonising all motor transport, from the smallest two-wheelers to the largest trucks on our roads. That is why we launched our consultation on phase-out dates for the sale of new, non-zero emission heavy goods vehicles alongside Decarbonising Transport: A Better, Greener Britain in July 2021. The proposals outlined in the consultation demonstrated government’s ambitious but achievable targets for decarbonising the UK’s road freight fleet which, in 2020, accounted for 19% of the UK’s domestic transport emissions.

After hearing views from industry and others we announced at COP26 that a phase-out date for the sale of new, non-zero emission HGVs less than or equal to 26 tonnes will be introduced from 2035 and, from 2040, all new HGVs sold in the UK must be zero emission. This means new HGVs will no longer produce harmful tailpipe emissions including greenhouse gases and pollutant emissions while operating on our roads. This will significantly reduce carbon emissions from road freight, moving the UK forward in our journey to net zero while tackling poor air quality and supporting economic growth. Confirming these dates now provides market certainty, giving the logistics and automotive industries time to plan investments and increase the supply of zero emission HGVs.

Since the consultation closed, the Russian invasion of Ukraine has demonstrated how the continued reliance on fossil fuels makes the UK susceptible to geopolitical issues when those issues impact on global fuel production. As an island nation, the UK has the best wind, wave, and tidal resources in Europe. This makes the transition to zero emission HGVs, powered increasingly by domestic green energy, even more vital to reduce our reliance on imports from elsewhere and secure the UK’s energy security.

To support the uptake of zero-emission HGVs, government recently announced an extension to the plug-in truck grants (PITrG) until 2024/25. The plug-in truck grant reduces the purchase price of zero emission commercial vehicles for consumers with grant rates for eligible trucks set at 20% of the purchase price, with up to £25,000 of funding available for the largest HGVs. Introduced in 2017, the number of vehicles eligible for the plug-in truck grant is rapidly expanding providing greater choice to operators. To date, the grant has supported the purchase of over 100 zero emission HGVs across the UK. Plug-in truck grant orders were nearly 8 times higher in 2021 than in 2020, demonstrating the growing appetite for these vehicles, and the extension of the plug-in truck grant will support the continuation of this increased uptake.

In the Net Zero Strategy government committed to expand on the successful first year of our zero emission road freight HGV demonstrators programme (ZERFT) by demonstrating three zero emission HGV technologies at scale on UK roads. With an investment of over £200m this makes it the world’s largest comparative demonstration of zero emission HGV technologies. We will shortly announce details of funding competitions for the battery electric and hydrogen fuel cell strands of ZERFT, with further competitions to follow in due course.

Crucially, ZERFT will collect data to create a strong evidence base to enable strategic decisions on national HGV refuelling and recharging infrastructure to be made, accelerating the uptake of these technologies across the UK. Demonstrators will provide evidence of the real-world capability and operational benefits of zero emission technologies, giving freight operators and vehicle manufacturers confidence to invest in them.

While hauliers and the automotive sector are poised to embrace the opportunities presented by zero emission HGVs, we recognise this transition also presents challenges, with investment and collaboration needed across the public and private sector. Setting phase-out dates for the sale of new, non-zero emission HGVs is the first step in our journey to a cleaner, greener freight system. Government remains committed to working in partnership with the freight and logistics industries to ensure the road freight sector reaches net zero while continuing to be able to efficiently and reliably deliver the goods and services we all rely on.

Reflecting on views submitted during this consultation process and lessons learned with zero emission cars and vans, government recognises the importance of a widespread, reliable refuelling and recharging network to provide confidence in the commercial viability of zero emission HGVs. We will convene industry stakeholders to work together to develop a plan for zero emission HGV infrastructure rollout and the role of the public and private sectors to achieve this. The plan will build on data gathered through ZERFT and draw on the expertise of the Freight Council, a cross-modal forum driving collaboration between government and the freight sector, to set out how we can deliver a public refuelling and recharging network to support the swift and efficient uptake of zero emission HGVs. At the same time, government is considering a wider appraisal of the purchase and support incentives for zero emissions HGVs, including the Plug-in Truck Grant, to further support the early zero emission HGV market.

Alongside this written response, we have published a call for evidence for industry partners to identify a potentially limited range of exemptions to our 2035 phase-out date for HGVs weighing 26 tonnes or under, which may require until 2040 to transition. This call for evidence is the first step in a process which will eventually see end of sale dates for new, non-zero emission HGVs enforced through regulation, possibly through the same regulatory framework that is being developed for zero emission cars and vans. Consultation on what this future regulation may look like will take place in due course.

Who responded

This document forms the government response to the consultation following several months of engagement activity with a wide variety of stakeholders.

A total of 92 consultation responses were received spanning a number of sectors as well as members of the public. A range of views were raised across a number of topics. 88 of the responses received were from organisations. These included:

• vehicle manufacturers
• companies with large fleets of vehicles
• trade and professional associations/ bodies
• companies throughout the automotive supply chain
• energy companies
• environmental groups
• charities
• academia
• local authorities and public bodies

This summary aims to capture the main themes and arguments raised by respondents and sets out our decisions in response to these.

Scope

The phase-out dates in this consultation apply to new, non-zero emission vehicles in vehicle categories N2 and N3 as defined in Article 4 of Regulation (EU) 2018/858, as it applies in Great Britain. They do not apply to:

• off road vehicles (categories N2G and N3G)
• buses and coaches
• non-road mobile machinery (NRMM) (PDF, 688KB)
• vehicles exempt from road vehicle type approval, such as vehicles with NRMM engines, military vehicles and fire engines
• special purpose vehicles
• agricultural equipment

Non-zero emission HGVs are defined as those which produce harmful emissions at the exhaust, including greenhouse gas (GHG) and pollutant emissions. Zero emission HGVs are defined as vehicles which do not produce harmful exhaust emissions. Emissions which do not damage public health, such as water vapour, are permitted. Emissions associated with the construction of HGVs and their supporting infrastructure are out of scope.

HGV phase out dates will be applied according to vehicle weight. The 2035 phase out date will apply to rigid vehicles with a gross vehicle weight less than or equal to 26 tonnes, and any articulated HGVs with a gross combination weight of 26 tonnes and under. The 2040 phase out date applies to articulated HGVs with a gross combination weight greater than 26 tonnes.

The HGV phase-out dates announced only apply to new HGVs. Existing diesel and other non-zero emission HGVs can continue to be driven, bought and sold on the second-hand market.

Stakeholder views and government response

The case for phase-out dates

Do you agree or disagree that introducing a phase-out date for the sale of new non-zero emission HGVs will help us meet our legally binding net zero target?

An overwhelming majority of respondents agreed with the need to introduce HGV phase-out dates for polluting vehicles, with feedback focusing on the regulatory certainty that phase-out dates will provide. Vehicle manufacturers, trade bodies and energy companies felt strongly that phase-out dates would create the business case for investment in zero emission HGV technologies, infrastructure and manufacturing by driving innovation and clarity over its future direction. This certainty will help to ensure road freight is on a credible decarbonisation pathway. It was highlighted that phase-out dates were particularly important to accelerate the overall decarbonisation of the transport sector which has seen only minor falls in its emissions output in recent years. Respondents also suggested a phase-out date would provide certainty to manufacturers and operators when planning their future fleet cycles.

While some respondents supported the introduction of phase-out dates in principle, they believed measures such as financial support and infrastructure roll out should be highlighted. These measures are covered in detail in later responses in this document.

A minority of respondents, including some trade bodies and energy companies, did not agree that introducing a phase-out date based on the government’s definition of a zero emission vehicle would support achieving net zero.

These respondents felt the proposed HGV phase-out dates focussed on exhaust (tank-to-wheel) emissions at the expense of lifecycle (well-to-wheel) emissions. They are concerned this approach does not address emissions generated through the production of fuels, electricity or vehicle disposal and manufacture and, as such, could continue to allow fossil fuels to be used in the production process. Consequently, some respondents opposed phase-out dates for HGVs unless government took a lifecycle approach and accounted for emissions generated across the lifecycle of a vehicle.

Our response

Government is committed to introducing phase-out dates for the end of sales of new non-zero emission HGVs to end our reliance on fossil fuels, improve energy security and achieve net zero. With transport the highest emitting sector of the UK economy, and road vehicles by far the largest source, we must act now to tackle emissions from road freight and unlock many of the benefits, such as cleaner air and quieter streets, that zero emission vehicles provide. Phase-out dates for the sale of new, non-zero emission HGVs will support fleet turnover to ensure that most HGVs used on UK roads are zero emission by 2050.

HGV phase-out dates clarify the direction of travel for UK road freight, giving industry and energy providers the confidence to continue to invest. Furthermore, with phase-out dates more than a decade away, we are positive the automotive, freight and logistics sectors have the necessary time and flexibility to adapt, supported by government action.

Do you agree or disagree with our approach to split the phase-out dates for new non-zero emission HGVs into two weight categories? Please explain your answer.

Most respondents agreed with our proposals to use two categories, with respondents from all stakeholder groups agreeing that heavier HGVs are more challenging to decarbonise than lighter ones. It was noted by respondents including trade associations and operators that electric and hydrogen fuel cell powered HGVs are coming to market in lighter weight categories with zero emission models already in commercial operation. It was noted that it will take longer for heavier, long-haul HGVs, most of which face more demanding operational requirements.

A two phased approach was seen as logical by most respondents, allowing government to phase out lighter HGVs earlier while allowing the market for heavier zero emission HGVs to mature. Logistics companies and parcel delivery firms suggested that introducing a singular phase-out date could in fact delay the transition of lighter HGVs which, due to their shorter journeys and generally lighter loads, are primed to transition to zero emission technologies earlier than heavier ones.

Some respondents, including some energy suppliers and vehicle manufacturers, disagreed with the setting of two phase-out dates and argued for a singular phase-out date to allow time for all zero emission HGVs to reduce in price. They saw other benefits to a single phase-out date including better alignment with commitments from the Europe automotive industry who have committed to being fossil free by 2040. They suggested that splitting phase-out dates along vehicle weight could have adverse effects, such as incentivising hauliers to purchase non-zero emission HGVs over more expensive, zero emission models. Zero emission vehicle manufacturers also argued for the introduction of a single phase-out date but asked for this to be brought forward, possibly to as early as 2030 to maximise carbon savings. Other points raised in this area included the potential for market distortion for smaller vehicles, or penalising smaller retailers who largely operate lighter HGVs as they would have 5 fewer years to turn over their fleet.

A proportion of respondents including some operators, vehicle manufacturers and representatives from the low carbon fuels (LCF) industry agreed with the principle of using two phase-out dates but disagreed with our approach to base these splits on vehicle weight. They reasoned that the technical and operational complexity of HGVs required a more nuanced approach. They recommended government look to split HGV phase-out dates according to vehicle use case which better accounted for a vehicle’s weight, duty cycle and power train requirements. It was argued this approach would enable government to phase out vehicles with simpler use cases, such as refuse collection vehicles, earlier than HGVs with more demanding use cases.

Our response

We believe our approach of using two phase-out dates based on weight categories is appropriate. This allows lighter HGVs, which have a clearer path to decarbonisation and are already on the market to complete their transition earlier than heavier vehicles, and we do not want to risk delaying this. This approach provides more time for the heaviest HGVs, where zero emission technologies are less mature, to develop.

We consider vehicle weight to be an objective measure indicative of HGV use case. Information on vehicle weight is recorded at the type approval stage and is not subject to change. DVLA/DfT data shows that lighter HGVs (≤26 tonnes) are overwhelmingly rigid. Rigid HGVs typically travel shorter distances and carry lighter loads, making them well suited to battery electric technology with depot-based charging. They are also less space constrained for the packaging of battery or hydrogen tanks. These factors make lighter, typically rigid HGVs suited to adopt zero emission technologies earlier than their heavier counterparts.

Heavier HGVs are more typically used in long haul applications with longer journeys and heavier loads and there is some uncertainty about which technology may be best suited for them. These vehicles can see high daily and annual mileages that require large amounts of on-board energy storage, which is currently challenging to provide with batteries or hydrogen both in terms of packaging and cost. ZERFT will help determine the zero emission technologies best suited for UK operations.

There may be some HGV use cases for which an earlier phase-out date is not possible. That is why we are publishing a call for evidence alongside this document to identify a limited range of exemptions for vehicles weighing 26 tonnes or under which may take further time to transition.

Proposed phase-out date split

Do you agree or disagree that 26 tonnes and under, and more than 26 tonnes are the right categories? What evidence do you have for or against?

Respondents were split on whether 26 tonnes was an appropriate point to split phase-out dates. Much of the debate focused on the diversity of HGV operations and our proposal to divide the fleet into rigid and articulated vehicles.

Respondents from the logistics and energy sectors as well as fleet operators agreed our proposal was sensible given the fleet largely divides into rigid and articulated HGVs at 26 tonnes. Since it is unclear which of the three principal zero emission technologies will emerge as market leader for heavier, long-haul HGVs they agreed it was logical to split HGV phase-out dates between rigid and articulated vehicles, pushing smaller and mid-sized HGVs to transition earlier where zero emission technologies are more developed. Vehicle manufacturers and their supply chains agreed, noting that zero emission HGVs under 26 tonnes are likely to be widely available before those weighing above 26 tonnes due to their generally lower range and energy consumption.

Some respondents including non-governmental organisations highlighted that splitting the fleet at 26 tonnes had the advantage of acknowledging zero emission technologies were less developed for heavier HGVs while signalling the direction of travel, encouraging vehicle manufacturers to invest in fully zero emission solutions.

Respondents who disagreed with a split at 26 tonnes largely believed this did not adequately reflect the complexity of HGV operations. They argued a 26-tonne split failed to recognise the diversity of HGV use cases and duty cycles, rendering it unfit for purpose. They stated the 26 tonnes and under category included construction, servicing and refrigerated vehicles which would take longer to decarbonise than urban distribution vehicles with lighter loads and shorter routes.

Several respondents proposed alternative means to separate the phase-out dates. Of these, the most common suggestions were:

• splitting the fleet at 18 tonnes i.e. between 2 and 3-axled HGVs
• creating more segments below 26 tonnes, such as grouping vehicles into 3.5-12 tonnes, 12-18 tonnes and 18-26 tonnes
• adopting EU regulatory groupings (i.e. VECTO categories)
• dividing the fleet based on a vehicles operational profile e.g. urban, regional and long-haul HGVs etc

Our response

We have carefully considered the different options available to ensure we are splitting the fleet in a way that maximises the benefits without putting undue pressure on manufacturers and operators and remain convinced that splitting the HGV fleet at 26 tonnes is the best option.

A telematics data sample shows HGVs with a weight of 26 tonnes or less primarily service urban and regional routes, with typically shorter ranges and more predictable journeys. Due to the smaller amounts of energy required to power the shorter distances these vehicles travel, they are already available in the market, with future supply expected to increase. As batteries get cheaper and the supply chain scales up, battery electric technology could be a direct swap for diesel in this weight category.

In contrast, HGVs over 26 tonnes are more typically used for long-haul applications with longer journeys and heavier loads. Their duty cycles mean these vehicles are more likely to need to refuel away from base, making adequate refuelling and recharging infrastructure essential to support their take up. There is less certainty around the zero emission technologies for HGVs above 26 tonnes, with battery electric, hydrogen fuel cells and electric road systems all potential solutions to decarbonise heavier HGVs. A later phase-out date for HGVs above 26 tonnes will allow time for us to learn from ZERFT and for technology to mature.

We recognise there may be a small number of use cases for HGVs weighing 26 tonnes and under where an earlier phase-out date could be challenging. This may include vehicles that power auxiliary equipment or operate challenging duty cycles. We have published a call for evidence alongside this consultation response to identify the need for a limited range of exemptions for vehicles weighing 26 tonnes or under which may need further time to transition.

Do you agree or disagree with our proposal to end the sale of new non-zero emission HGVs, for vehicles weighing from 3.5 tonnes up to and including 26 tonnes, by 2035? What evidence do you have for or against?

Most respondents, including vehicle manufacturers, logistics firms and non-governmental organisations agreed with our proposal to phase out the sale of new non-zero emission HGVs less than or equal to 26 tonnes by 2035. The primary reason given was the ability of zero emission HGV technology to meet the energy demand from these vehicles and the shared expectation that zero emission technologies will develop more quickly for lighter HGVs. Respondents highlighted that battery electric technology is particularly suited to the urban and regional use cases served by the majority of the HGV fleet weighing 26 tonnes or under, with a good supply of zero emission HGVs expected to meet operational requirements for these use cases by 2035.

Respondents also commented that since the bulk of investment into zero emission HGVs was focussed on lighter vehicles, with commercial models in lighter weight categories already available, HGVs weighing 26 tonnes and under could be a cost-effective alternative to diesel by 2035, especially when factoring in the expected improvements in the cost and performance of batteries in the coming decade.

Some respondents pointed to the longer average lifespan of HGVs weighing 26 tonnes and under which tend to be on the roads longer than heavier HGVs. These respondents viewed a 2035 phase-out date as appropriate because it would reduce the number of diesel HGVs in circulation post 2050. Respondents also reasoned that setting a 2035 phase-out date for HGVs weighing 26 tonnes and under gave clarity to industry, providing a clear timeline for fleet replacement cycles and encouraging investment in zero emission HGV research and development. Some respondents pointed to the competitive advantage a 2035 phase-out date could leverage. With the EU yet to announce phase-out dates for the sale of new, non-zero emission HGVs, some respondents felt introducing an earlier phase-out date for lighter HGVs could see additional investment diverted to the UK.

Some respondents who agreed with our proposal felt it aligned well with the phase-out dates announced for the sale of new petrol and diesel cars and vans. These respondents took the view that lighter HGVs, particularly those below 7.5 tonnes, are utilised similarly to large vans. Therefore, a 5-year grace period following the 2030 phase-out was seen as reasonable for the additional infrastructure and technological requirements of HGVs 26 tonnes or under to develop.

A minority of respondents disagreed with our proposed 2035 phase-out date for HGVs weighing less than or equal to 26 tonnes, with three broad positions emerging. Firstly, respondents questioned the feasibility of a 2035 phase-out date, pointing to a lack of recharging and refuelling infrastructure, the expense of zero emission vehicles and the uncertainty surrounding vehicle technology. These respondents were not convinced the required infrastructure and policy framework would be implemented in time to make a 2035 phase-out date feasible.

Secondly some vehicle manufacturers and logistics operators felt the HGV fleet was more complex than the consultation suggested, with HGVs weighing less than or equal to 26 tonnes serving a range of duty cycles. They reasoned it was not possible for all vehicles weighing 26 tonnes or less to be phased out by 2035. Some of these respondents stated they could support a 2035 phase-out date if it applied to HGVs weighing 18 tonnes or less, which were felt to be easier to decarbonise.

Others reasoned that challenges around zero emission vehicle and charging technology, as well as cost, made 2035 unrealistic regardless of vehicle weight. Instead, they proposed a single 2040 phase-out date which was felt to better align the UK with the wider European market where ACEA, whose members produce the majority of trucks sold in the UK, have announced all new trucks sold will be fossil-free from 2040. Respondents felt more time would enable barriers to zero emission HGV adoption to be overcome and reduce uncertainty around the transition.

Conversely, zero emission vehicle manufacturers stated the 2035 phase-out date should apply to sales of all new HGVs, not just those weighing 26 tonnes and under. They believed 2035 allowed sufficient time for the supply of zero emission HGVs to ramp up and criticised the government’s lack of ambition regarding HGV decarbonisation, arguing the whole sector could and must move faster. Respondents from the energy sector suggested the 2035 phase-out date could be reviewed following market developments, keeping the option open to phase out the sale of lighter new, non-zero emission HGVs earlier if technology permitted.

Some low carbon fuels suppliers, distributors and operators disagreed with our proposed 2035 phase-out date unless it only applied to HGVs 26 tonnes and under running on diesel and excluded those utilising low carbon fuels. These respondents suggested that prohibiting the use of low carbon fuels in new HGVs could delay the journey to net zero by excluding fuels which could play a crucial and complimentary role in the transition to net zero. It was therefore seen as premature to preclude their use from HGVs 26 tonnes and under in 2035 at this stage.

Respondents who agreed and disagreed with this proposal both noted the importance of additional measures if we are to meet the 2035 phase-out date for HGVs 26 tonnes and under. Respondents asked for appropriate fiscal incentives to support uptake and long-term research and development funding for zero emission technologies.

Our response

Government takes the view that a 2035 phase-out date is appropriate for HGVs less than or equal to 26 tonnes. Research commissioned by the Climate Change Committee shows that zero emission technology already meets the range requirements of small rigid HGVs under 16 tonnes. New rigid models 26 tonnes and under are already appearing on the market, with models already eligible under the plug-in truck grant. Combined with the predicted improvements to battery electric technology in the coming years and the fewer space constraints to accommodate hydrogen tanks and/or batteries in smaller HGVs, we are confident that zero emission technologies will meet the majority of use cases for HGVs weighing 26 tonnes and under by 2035.

The longer average lifespan of HGVs of 26 tonnes and under makes an earlier phase-out date appropriate. Lighter, rigid HGVs tend to run shorter daily distances and have longer average lifespans than heavier HGVs, with some remaining on UK roads for up to 20 years. An earlier phase-out date for HGVs 26 tonnes and under allows for the majority of these non-zero emission vehicles to be removed from the roads by 2050 through natural fleet turnover, protecting assets and minimising business disruption. Delaying leaves a larger legacy fleet of diesel or other fossil fuelled HGVs on the roads in 2050.

We have heard respondents’ views on the complexity of the HGV market and that commercial vehicles perform a variety of operations. That is why we have published a call for evidence alongside this response seeking views on potential exemptions to the 2035 phase-out date based on vehicle use case. This call for evidence is the first step in a process that will eventually see end of sale dates for new, non-zero emission HGVs enforced through regulation. The exact detail of this regulation and possible exemptions will be the subject of further public consultation.

Do you agree or disagree with our proposal to end the sale of new non-zero emission HGVs, for vehicles weighing more than 26 tonnes by 2040? What evidence do you have for or against?

The majority of respondents agreed with our proposal to introduce a 2040 phase-out date for the sale of new, non-zero emission HGVs heavier than 26 tonnes. The reason given most frequently was that phase-out dates send a strong policy signal on the direction of travel for zero emission HGVs. Respondents liked the clarity and market certainty this provided which would increase investor confidence.

Respondents including vehicle manufacturers, logistics operators and environmental groups expressed confidence that zero emission technologies would meet the needs of the heaviest HGVs by 2040. They pointed out that zero emission technologies were already commercially available and cited announcements by major European manufacturers that all new trucks sold will be fossil free from 2040. Respondents saw such announcements as an indication that the market was moving towards fossil free (although not altogether zero emission) technologies and proof that a pathway to zero emission technologies existed even for the heaviest vehicles. They reasoned that since HGVs above 26 tonnes were more challenging to decarbonise a 2040 phase-out date allowed time for heavier zero-emission technologies to develop and scale up.

Others who agreed with this proposal pointed to our 2050 net zero target reasoning that if HGVs travelled on UK roads for upwards of ten years, then the last new, non-zero emission vehicles should be sold ten years before 2050. Environmental groups, and some hauliers and vehicle manufacturers also cited Climate Change Committee advice that sales of new diesel HGVs should be phased out by 2040, which government should follow. A smaller group reserved judgement, stating it was too early to know whether the conditions to support zero emission HGV uptake would be in place by 2040. Others agreed in principle, on the condition that cost, infrastructure and supply barriers to zero emission HGVs above 26 tonnes were overcome.

Some respondents were split over whether a 2040 phase-out for new, non-zero emission HGVs above 26 tonnes was too ambitious, or not ambitious enough. Some trade bodies and vehicle manufacturers saw 2040 as too ambitious, arguing that zero emission technology and infrastructure needed additional time to develop for heavier HGVs with more challenging duty cycles. They were doubtful that zero emission technology would meet all HGV use cases by 2040 because zero emission articulated HGVs are at an early stage of development.

Some stakeholders questioned whether there would be sufficient grid capacity to power fleets of zero emission HGVs by 2040, making it impossible to meet this phase-out date. A minority of stakeholders suggested 2045 as a more appropriate phase-out date, assuming the technology and infrastructure to support HGV operations above 26 tonnes was in place. On the other hand, environmental groups along with some vehicle manufacturers and operators argued a 2040 phase-out date was not ambitious enough and suggested government should phase out HGVs above 26 tonnes from 2037 or 2035. Other respondents asked for the phase-out date to be kept in review to determine if a more ambitious phase-out date for HGVs above 26 tonnes is possible in the future.

Respondents who disagreed disliked government’s proposal to extend the 2040 phase-out date to all new, non-zero emission HGVs above 26 tonnes, including those using low carbon fuels (with the exception of renewable hydrogen used in fuel cells). Respondents from the low carbon fuels industry, as well as vehicle manufacturers and hauliers, felt strongly that government should continue to permit new HGVs running on low carbon fuels to be sold after 2040. They felt government was conflating concerns over greenhouse gas and air quality emissions, arguing that clean air zones would rule out the use of technologies with tailpipe emissions in urban areas. Instead, they argued low carbon fuels had an important role to play in reducing or removing carbon emissions from long-haul and heavier HGV operations well beyond 2040 and thought government was acting prematurely.

Our response

Government believes phasing out the sale of new, non-zero emission HGVs above 2040 is vital if we are to reduce our reliance on fossil fuels and achieve net zero. Introducing a phase-out date for HGVs above 26 tonnes will lead to a significant reduction in emissions from road freight vehicles and is a significant step towards meeting our commitment to eliminate carbon emissions from all new road vehicles by 2040.

We are confident that, with the right policy framework, zero emission technologies will scale up to meet even the most challenging HGV use cases. That is why we have announced over £200m of additional funding to extend our zero emission road freight demonstrators. This will support research and development into zero emission technologies for the heaviest HGVs and the roll out of supporting infrastructure. Projects will provide evidence of the real-world capability of zero emission technologies for the heaviest vehicles, giving freight operators and vehicle manufacturers confidence to invest in them.

We do not underestimate the challenges ahead but, with 2040 almost two decades away, we are confident we can work with road freight stakeholders to realise our phase-out dates and deliver the environmental and economic benefits zero emission HGVs offer. That is why this response commits us to work with industry to develop a plan for the rollout out of zero emission HGV infrastructure. We will review whether we can use the plug-in truck grants more effectively to support the early zero emission HGV market.

Note the 2040 phase-out date does not apply to the use of existing non-zero emissions HGVs. The sale of used non-zero emission HGVs on the second-hand market will still be permitted, and vehicles already registered will continue to be allowed to be driven.

Challenges and barriers to meeting HGV phase-out dates

What do you consider the main challenges and barriers to meeting phase-out dates for the sale of new, non-zero emission HGVs?

How can these barriers be addressed?

This summary combines the answers to questions 5, 6, 8 and 9. We have drawn out specific challenges to meeting 2035 or 2040 where they were raised. As responses were similar across vehicle manufacturers, trade bodies, logistics providers, energy companies and environmental groups we have grouped them into themes.

Cost

The cost of zero emission HGVs was frequently raised as the foremost barrier to their adoption. Respondents highlighted that zero emission technologies were more expensive than diesel and that simply introducing phase-out dates for the sale of new, non-zero emission HGVs did not make them cheaper. Trade associations and hauliers pointed out that HGVs, unlike passenger vehicles, are commercial products bought to perform specific functions. They reasoned that if the economics of adopting zero emission technologies did not stack up operators would simply refuse to adopt them and would instead hold on to existing vehicles for longer. Respondents questioned whether the economics for adopting zero emission HGVs weighing 26 tonnes and under could be even more challenging, as lighter HGVs drove shorter distances and therefore had fewer opportunities to recoup their higher purchase price through reduced running costs.

Respondents asked for the plug-in truck grant to be extended and for the grant to cover more of the price differential between diesel and zero emission vehicles. There were calls for operational benefits such as toll exemptions for zero emission HGVs and for financial support targeted at businesses who lease rather than purchase their vehicles.

HGV refuelling and recharging infrastructure

Refuelling and recharging infrastructure was seen as a major barrier to the adoption of zero emission HGVs. Vehicle manufacturers, logistics fleets and trade associations questioned whether the required levels of infrastructure would be rolled out to meet the timescales set out. They suggested that recharging and refuelling infrastructure, combined with existing challenges around installing depot charging for lighter commercial vehicles, could slow down the uptake of zero emission HGVs even where models were available.

Respondents recommended government work with industry to develop a comprehensive plan for a network of HGV refuelling and recharging infrastructure which met the needs of smaller and larger vehicles. They suggested refuelling and recharging infrastructure should cover the range of zero emission technologies, from hydrogen refuelling to induction and catenary charging, and meet the needs of a range of HGV operations. Respondents agreed that access to public recharging and refuelling infrastructure should be unrestricted, with adequate provision along strategic roads and trucks stops to support HGV operations. Several respondents asked government to expand the scope of Project Rapid to consider HGV charging requirements. They felt this would pave the way for the roll out of HGV infrastructure and avoid costly delays.

Technological readiness

Respondents, particularly vehicle manufacturers and trade bodies, pointed to the limited number of zero emission HGVs, particularly hydrogen fuel cells, in commercial operation. This demonstrated the immaturity of zero emission HGV technology. Respondents questioned whether zero emission technologies would develop sufficiently to be economically and commercially viable in time to meet phase-out dates, particularly for long haul, articulated HGVs. Some hauliers and low carbon fuels producers argued this uncertainty warranted the continued use of low carbon fuels (in addition to renewable hydrogen used in fuel cells) beyond our phase-out dates.

Increased funding for research and development was seen as a solution to this challenge, with many respondents pointing to a recommendation that government fund large scale trials of zero emission HGVs to develop, test and advance the feasibility and scalability of battery electric and hydrogen fuel cell technologies. Others asked for R&D funding for assistive technologies which could support the uptake of zero emission HGVs, such as zero emission refrigeration or solar technologies. Such solutions could compensate for some of the challenges presented by zero emission technologies such as reduced range.

Range and payload

HGV operators and vehicle manufacturers saw the additional weight from zero emission powertrains as a barrier to uptake. Their weight reduced vehicle range and disrupted journeys by increasing the time vehicles spent recharging or refuelling. This was flagged as a particular challenge for HGVs operating in rural or remote areas, where there would be limited public refuelling and recharging infrastructure, further disrupting operations. Similarly, respondents flagged that the weight and space required for zero emission technologies reduced the payload, reducing the viability of zero emission HGVs compared to their diesel or low carbon fuelled counterparts. Both these challenges were seen as more acute for HGVs above 26 tonnes, whose heavier loads required longer charging times and where zero emission technologies take up more of the vehicle’s size and weight allowances.

Respondents largely agreed that our proposals to increase the maximum permissible weights for certain zero emission vehicles by up to two tonnes (see the outcome to consultation questions 11-13 later in this response) could compensate for the additional weight of zero emission technologies, reducing their commercial disadvantage. Some vehicle manufactures felt there was a need to increase axle weight limits and overall vehicle length alongside a blanket gross vehicle weight (GVW) increase to support the uptake of zero emission HGVs.

Vehicle supply

Respondents were concerned about the small number of zero emission HGVs eligible for the plug-in truck grant. The limited availability of zero emission HGVs was seen as barrier even among operators keen to adopt zero emission technologies, who felt their efforts were constrained by the limited range of vehicles available. Until a secure supply of zero emission HGVs was guaranteed across technology types and use cases many felt uptake of these vehicles would be constrained.

There were few direct recommendations about how government could secure vehicle supply. Some respondents called for government to set review periods for HGV phase-out dates in case they proved unfeasible. Many respondents also called on government to set up an industry-led, technology neutral working group to tackle the challenges and barriers to zero emission HGVs and advise on how to support uptake.

Our response

There is a global move to zero emission vehicles. We recognise our proposed dates are ambitious and government is committed to support industry to adopt zero emission HGVs. In fact, by becoming the fastest G7 country to decarbonise heavy goods vehicles, the UK can capitalise on the opportunities of this transition and seize new opportunities for growth and innovation.

To support operators with purchase costs of zero emission HGVs government recently announced the extension of the plug-in truck grant (PITrG) until 2024/25. The PITrG reduces the purchase price of zero emission commercial vehicles for consumers, with grant rates for eligible trucks set at 20% of the purchase price, with up to £25,000 of funding available for the largest HGVs. This extension improves confidence among fleets and truck makers, supporting the early market for zero emission HGVs.

Changes to eligibility for the PITrG, recategorizing vehicles between 3.5 and 4.25 tonnes as large vans rather than small HGVs, will ensure the grants deliver improved value for money for the taxpayer and allows us to target the larger truck grant on heavier HGVs where there is greater need for support. We have listened to feedback that the PITrG could be better utilised and are considering a wider appraisal of the purchase and support incentives for zero emissions HGVs to further assist the early market.

Government agrees that widespread refuelling and recharging infrastructure will provide confidence in the commercial and operational viability of zero emission HGVs. That is why we are delighted to confirm £212m additional funding to extend our zero emission road freight trials (ZERFT) and build on the exploratory work undertaken in the 2021/22 financial year to demonstrate three zero emission HGV technologies at scale on UK roads. ZERFT will be the world’s largest comparative demonstration of zero emission HGV technologies supporting the development of different zero emission technologies and collecting evidence to enable decisions on national HGV refuelling and recharging infrastructure to be made. In turn this will accelerate the uptake of these technologies across the UK. Demonstrators will provide evidence of the real-world capability of zero emission technologies, giving freight operators and vehicle manufacturers confidence to invest in them.

In one of the largest and most significant deployments of zero emission trucks in the UK to date, last year ZERFT put 20 DAF LF battery electric 19-tonne HGVs, together with the required charging infrastructure, into commercial service. The trucks are gathering real-world data which will be used to create an interactive website to inform future fleet purchasing decisions. The £10m demonstrator focuses on an end-to-end solution to understand how battery electric HGVs, charging infrastructure, user training, repair and maintenance and total cost of ownership stack up in the real world across a range of duty cycles.

To support the roll out of HGV recharging and refuelling infrastructure government is committed to working with industry to develop a plan for zero emission HGV infrastructure rollout and the role of the public and private sectors to achieve this. The plan, which will take shape in the coming years, will build on data gathered through ZERFT and draw on the expertise of the Freight Council to set out how we can deliver a public refuelling and recharging network to support the swift and efficient uptake of zero emission HGVs. We are assessing HGV and wider freight energy infrastructure requirements alongside work on Project Rapid.

We have listened to respondents’ concerns about the complexity of the HGV fleet and the fact that not all vehicles of 26 tonnes or less may be able to transition to zero emission technologies by 2035. We have published a call for evidence aimed at industry partners alongside this response to identify a limited range of exemptions for HGVs 26 tonnes and under which may need longer to transition. This call for evidence is the first step in a process which will eventually see end of sale dates for new, non-zero emission HGVs enforced through regulation. Regulation will provide certainty to operators, energy and infrastructure providers, vehicle manufacturers and the supply chain by securing a regular supply of zero emission HGVs across different weight classes. Further consultation on what future regulation may look like and how it may impact the sector will take place in due course.

We will implement a flat weight limit increase of two tonnes for specified zero emission vehicles and a weight limit increase for specified alternatively fuelled vehicle types of up to one tonne, relative to the additional powertrain weight. These changes reduce the payload penalty incurred by adopting zero emission and alternatively fuelled powertrains, helping pave the way for the mass adoption of zero emission HGVs. We have listened to respondents concerns around the technical challenges posed by the adoption of zero emission technologies such as axle weight and vehicle length limits. We will work with industry to better understand these barriers and explore potential solutions.

The scope of fuels included within phase-out dates for new, non-zero emission HGVs

Do you agree or disagree that these phase-out dates should be extended to all new, non-zero emission HGVs, including those using low carbon fuels, in their respective weight categories? Please explain your answer.

This section summarises views on whether the proposed phase-out dates put forward within the consultation should include new HGVs running on low carbon fuels (LCFs) in their respective weight categories. Low carbon fuels refer to those fuels commonly used in place of fossil diesel in HGVs and deliver carbon savings compared to fossil fuels including, but not limited to, biodiesel (FAME & Hydrotreated Vegetable Oil), compressed and liquified biomethane and renewable hydrogen. Please note renewable hydrogen used in fuel cells meets our definition of a zero emission technology and is therefore out of scope for this question.

Respondents overwhelmingly agreed that low carbon fuels are crucial to reduce HGV emissions during the transition to zero emission technologies, except renewable hydrogen used in fuel cells which will continue to be used in the long term. Responses highlighted the market ready nature of LCFs, the carbon savings they offer compared to diesel and the fact they are currently cheaper than hydrogen fuel cell or battery electric technologies. This view was shared across the spectrum of respondents, with manufacturers, operators, local authorities and environmental groups all holding similar views.

However, respondents did not agree on whether LCFs were a long-term solution to HGV decarbonisation. Environmental organisations and some public sector bodies argued that low carbon fuels should be phased out alongside other new, non-zero emission technologies since they produce carbon and other pollutant emissions. In contrast, respondents including most vehicle manufacturers, low carbon fuel producers and trade bodies argued that low carbon fuels were a long-term solution to HGV decarbonisation. They stated that LCFs can be carbon neutral or even carbon negative on a lifecycle basis, making them suitable for use in a net zero future. These respondents also argued that technological improvements would reduce the carbon emissions of LCFs over time. There was particularly strong support for hydrogen combustion from engine manufacturers and some trade groups who viewed this as a cheaper and more mature decarbonisation option than hydrogen used in fuel cells.

Respondents from local authorities and environmental groups raised concerns that low carbon fuels produce pollutant emissions which damage public health. They argued that technologies such as batteries or hydrogen fuel cells, which do not produce harmful exhaust emissions, were a better solution to HGV decarbonisation because they addressed greenhouse gas and air quality concerns. This view was strongly refuted by some, particularly low carbon fuel producers and distributors, who consider the pollutant emissions produced from LCFs to be so insignificant they pose little risk to human health. Furthermore, when combined with exhaust emissions capture or after treatment technologies, LCFs would not produce harmful tailpipe emissions.

Environmental groups and local authorities noted the finite nature of sustainable LCFs. They reasoned their limited supply meant they should be prioritised in harder to abate transport modes such as aviation and maritime, where there are fewer zero emission technology options. These respondents, including some from the energy sector, felt that continuing to allow the use of LCFs in new HGVs could delay the decarbonisation of other transport modes due to competition over limited supply. Environmental groups raised concerns that if LCFs were widely used across transport this could contribute to carbon emissions and environmental damage outside the UK.

A strong theme was the need for government neutrality around LCFs in transport. Some trade bodies, automotive manufacturers and LCF producers argued that this proposal promoted battery electric and fuel cell technologies at the expense of LCFs. They thought this was unwise due to the early stage of HGV decarbonisation, which made it important to leave technology options open. Other respondents argued the market should be left to innovate and determine the role of different technologies in HGV decarbonisation, with manufacturers and operators able to decide for themselves whether LCFs were right for their business.

However, respondents in favour of this proposal felt differently. They viewed the consultation as an opportunity for government to signal the transitional role of LCFs in road freight decarbonisation and argued any role for LCFs beyond this was misguided. They worried that without this signal industry could be reluctant to adopt zero emission technologies when LCFs are cheaper and deployed similarly to diesel. They felt an announcement from government on the role of LCFs in the HGV fleet could therefore accelerate the transition away from polluting vehicles and maximise carbon savings.

Respondents wanting to exempt LCFs from HGV phase-out dates agreed on the need for clarity over the long-term use of LCFs in HGVs. However, they worried a signal from government could disincentivise investment in and adoption of LCFs if they were no longer seen as a viable long-term option. It was argued this could suppress uptake of LCFs, reducing their contribution to carbon savings in the coming decades and adversely influencing the LCF market. Some respondents also raised concerns that phasing out LCFs in HGVs could penalise businesses who have already invested in low carbon fuels through the risk of stranded assets.

A common theme among respondents who either disagreed or did not know whether the government should extend phase-out dates to LCFs was the immature state of HGV decarbonisation. These respondents, including some trade groups, retailers and energy providers, felt government should wait until the economic viability of zero emission technologies were better understood, and public refuelling infrastructure rolled out, before deciding on the long-term role of LCFs and whether they were needed following HGV phase-out dates. Others argued it was premature to phase out LCFs at this early stage, and that doing so could jeopardise future carbon savings. Finally, many respondents took the view that LCFs were still likely to be needed in certain segments of the HGV fleet beyond 2040, namely in heavier vehicles or those operating in rural areas where refuelling infrastructure may take time to roll out, and that any LCF decision should consider this.

Our response

We recognise that LCFs are an important and readily available source for road freight decarbonisation. They contribute a significant proportion of transport emission reductions and will continue to do so for decades to come. In recognition of this government supports LCFs via the Renewable Transport Fuel Obligation (RTFO). A duty incentive is in also place for natural gas, which, in conjunction with the RTFO, supports the deployment of biomethane and other gaseous fuels in HGVs. Along with our commitment to explore additional measures that could overcome market barriers for higher blend fuels, these policies signal government’s strong support for LCFs in the transition to zero emission road freight.

We take the view that HGV phase-out dates should include new HGVs using LCFs, with the exception of fuel cell vehicles using renewable hydrogen. Government is committed to tackling sources of air pollution to improve public health and we aim to achieve zero harmful tailpipe emissions across road transport. For this reason, we agree with respondents who believe LCFs do not adequately address air quality concerns. In contrast, technologies such as batteries or hydrogen fuel cells address greenhouse gas and air quality concerns simultaneously as well as delivering noise reductions. We recognise that some LCFs, such as biomethane when produced through anaerobic digestion of manure or waste feedstocks, can achieve net zero carbon emissions over their lifecycle. However regardless of feedstock these fuels still produce tailpipe emissions, making them unsuitable for urban areas. That is why our aim is to support the development of zero emission HGVs.

We recognise the challenges some respondents raised around the transition to zero emission HGVs. Road freight has identified viable zero emission HGV technologies and supporting infrastructure will advance significantly in the coming decades. A valuable and limited resource like sustainable biomass must be prioritised for use in harder to abate sectors such as industry, aviation and shipping, though in the immediate future LCFs will remain important in supporting greenhouse gas emission reductions from existing HGVs. This is in line with advice from the Climate Change Committee who do not see a long term role for biofuels in surface transport as they are best used in other sectors.

We take seriously the need for clarity over the role of LCFs in road freight up to 2050. We are developing a low carbon fuels strategy to address concerns on the deployment of low carbon fuels across different transport modes in the period to 2050. The strategy will be published later this year and seeks to improve planning certainty for all stakeholders involved in the LCFs sector.

We recognise the interest in hydrogen combustion to reduce carbon emissions. At present all internal combustion engines produce harmful exhaust emissions and would therefore be subject to end of sale dates for new, non-zero emission HGVs. However, if technology developments enable renewable hydrogen to be used in combustion engines with zero harmful tailpipe emissions then we would welcome this development.

As some respondents highlighted, we recognise there may be a limited role for the continued use of low carbon fuels in new HGVs following the introduction of the 2035 phase-out date. We will therefore consider a limited range of exemptions for HGVs below 26 tonnes which may need further time to transition beyond 2035. We welcome evidence on this in our exemptions call for evidence, published alongside this response.

It is important to note HGV phase-out dates will only apply to the sale of new vehicles and will not apply to the use of LCFs in registered HGVs. Low carbon fuels will remain an important option to achieve greenhouse gas savings from the existing HGV fleet following the introduction of phase-out dates.

Increasing permissible weight allowances for zero emission vehicles

Do you agree or disagree that maximum permissible weights for certain zero emission vehicles (mainly HGVs) on both international and domestic journeys should increase by up to 2 tonnes (without exceeding 44 tonnes)? Please explain your answer.

Most respondents agreed that certain zero emission vehicles should have their weight limits increased by up to two tonnes. The main reason was that current zero emission powertrain technology weighs more than existing diesel powertrains and is likely to remain so for several years. Heavier powertrains reduce the payload weight that can be carried or reduce the range of the vehicle, acting as a disincentive for operators to adopt zero emission HGVs by reducing their economic appeal. This could result in slower uptake. This view was shared across the spectrum of respondents, with manufacturers, operators and interest groups all holding similar views.

Some respondents also highlighted that without payload parity with non-zero emission vehicles, operators may need to use a higher number of vehicles to move the same weight of goods. This would increase congestion, noise and air quality emissions related to pollutants from brake and tyre wear.

A second benefit raised in several responses (in particular from manufacturers or groups representing manufacturers) was that implementing the extra weight allowance would maintain regulatory alignment with the EU. This is relevant because many vehicles sold in the UK are manufactured in the EU and frequently travel there. If weight limit increases were not available, prices for UK based operators could increase due to the need for altered designs and there could be difficulties for cross-border traffic if weight limits varied between the UK and EU.

A minority of respondents disagreed with the proposal outright. One reason, raised by several respondents, was that weight limit increases are only relevant for vehicles using on board batteries. They argued that in contrast, vehicles running on hydrogen or using electric road systems technology would have weights similar to existing diesel technology. Several respondents with an interest in hydrogen said that space on the vehicle rather than weight was a greater barrier to the adoption of these vehicles and suggested that government also review vehicle dimensions limits to provide more flexibility in this regard.

Although there were low numbers of responses that disagreed with the proposal outright, various issues with how and where weight limit increases would be applied were discussed, including by respondents who agreed with the proposal overall. One topic with contrasting views was whether the two-tonne weight limit increase should apply to HGVs already operating at 44 tonnes (the standard maximum for six-axle combinations). Some responses, particularly from manufacturers, suggested it should as these vehicles have the biggest extra weight requirements. Others disagreed, suggesting that weight increases beyond 44 tonnes would be incompatible with road infrastructure in the UK. These views were mirrored in discussions relating to axle weight limits - with some suggesting that these should be increased to allow for easier use of the extra weight limit and others arguing that these should remain in place to avoid excessive road wear. Finally, various respondents suggested that the two-tonne weight limit suggested would not entirely offset the additional weight of batteries required for the vehicles being considered.

Similar to the specific weight increases themselves, there was a variety of views on which vehicles should be eligible for weight limit increases. A small number of respondents suggested that the issue of extra weight caused by zero emission and alternative fuel technology affects all vehicle types, not just those specified in the consultation, and therefore weight limit increases should be universal. One response suggested that weight limit increases should be restricted to zero emissions vehicles only, in contrast to the proposal in question 12. Another argued that if the standard maximum weight of 44 tonnes were to remain, weight limits for diesel vehicles should be reduced to 42 tonnes, to maintain a weight differential which reflects the varying powertrain weight.

One third of respondents either said they did not know or left the question blank. The most common reason was that there is still some uncertainty over which technology (or technologies) will be most widely adopted for the vehicles being considered and until there is more clarity about this, decisions about higher weight limits should not be taken.

Our response

Having considered the views provided by respondents, the department will work to adopt the weight limit increase of two tonnes for zero emission vehicles in the categories described in the consultation document. This is based on the clear view that doing so would help the pace of adoption of these vehicles and that maintaining regulatory alignment with the EU is useful (for both manufacturers and operators) in this case.

We recognise that weight limit increases beyond 44 tonnes and changes to axle weight could be helpful to operators. However, these limits are in place to avoid problems with road structures and excessive road wear and are not currently under review. The issue of axle weights remains under review, but changes will not be pursued now.

Increasing permissible weight allowances for alternatively fuelled vehicles

Do you agree or disagree that weight limits should increase by up to a maximum of 1 tonne for certain alternatively fuelled HGVs on both international and domestic journeys (without exceeding 44 tonnes)? Please explain your answer.

Less than half of respondents agreed with this proposal, although this was the most common response received. This view was shared across the spectrum of organisations who responded to the consultation. The main reasons for this were similar to those expressed in response to the previous question on increasing weight limits for zero emission vehicles. Specifically, respondents felt the use of alternative fuels should be supported due to their potential to reduce carbon emissions, particularly before significant numbers of zero emission vehicles are available to operators. Removing any payload or range penalty for operators, or the need to use more vehicles than with existing diesel technology, helps ensure the business case for the use of these vehicles stacks up. A small number of respondents suggested that the increased weight limits for alternatively fuelled vehicles would support hydrogen combustion.

A small number of respondents disagreed. The most common reason given was due to questions over whether alternatively fuelled vehicles are significantly heavier than diesel comparators and therefore whether any weight limit increase was necessary. It was highlighted than gas powered HGVs are already in use in relatively high numbers, with this number growing, demonstrating that any extra weight was not proving a significant barrier to their uptake by operators.

The second reason for disagreement related to whether alternatively fuelled vehicles should be encouraged at all, with some respondents suggesting that only zero emission vehicles should have their weight limits increased. This was due to either concerns about the impact of these vehicles on air quality, or the view that they still emit carbon and are therefore incompatible with efforts to reduce carbon emissions.

Finally, some respondents raised concerns over the impact of heavier vehicles on road infrastructure. In particular, respondents felt these vehicles would increase road wear and may need to divert around weight-limited structures, potentially onto roads unsuitable for heavier vehicles.

Around a third of respondents either said they did not know or left the question blank. Of those offering a reason, it was similar to those in the previous question: uncertainty over future vehicle powertrain technology means decisions about changing weight limits are premature.

Another common issue raised by both respondents who agreed and disagreed with the overall proposal was around whether other vehicle types should have their weight limits increased and what these should be. As with the previous question, various respondents, mainly operators or their representative groups, argued that weight limit increases should also apply to vehicles currently operating at 44 tonnes (taking their weight limits to 45 or 46 tonnes depending on the powertrain being used) as extra powertrain weight would be most pronounced for the largest vehicles. Some respondents argued that weight limits should be increased for all vehicle types (not just those specified in the consultation) and that maximum axle weights should be increased to allow for any overall increases in weight limits to be used effectively.

Our response

Government agrees that alternatively fuelled vehicles play an important role in reducing carbon emissions before zero emission HGVs become widespread and can minimise emissions from the non-zero emission fleet while it remains in operation. This view is discussed further on page 13 of the consultation document (PDF, 631KB). Based on this view and the responses received to the consultation, the department will work to adopt the weight limit increase of up to one tonne for alternatively fuelled vehicles in the categories outlined in the consultation document.

Defining what level of weight increase should be permitted

Do you agree or disagree that weight limit increases should only offset any additional weight due to the alternatively fuelled or zero emissions technology?

Almost half of respondents agreed with the proposal that weight limit increases should only offset the increased weight of the alternative fuel or zero emission powertrain. The most frequently cited reason for this, from respondents across sectors, was that only offsetting the additional weight (rather than providing a flat one or two tonne weight increase) would prevent operators using alternatively fuelled or zero emission vehicles from carrying increased payloads. If alternatively fuelled or zero emissions vehicles were able to carry increased payloads, operators using diesel vehicles would be disadvantaged and respondents considered this unfair, particularly as these newer vehicle types may be more expensive and therefore unaffordable for smaller operators.

The second most common reason for agreeing with the proposal was that by only offsetting the additional weight of the technology, rather than a flat increase to the weight limit regardless of the actual weight of the equipment, it reduces the external impacts of heavier vehicles in particular road wear and noise. Providing flat weight increases would result in higher numbers of heavier vehicles on the road, increasing these negative externalities.

Some respondents disagreed with the proposal, particularly vehicle operators and some manufacturers. The main reason for this was the view that a flat weight limit increase would retain the incentive for manufacturers to make their powertrains as light as possible, to allow any remaining weight to be used for the carriage of goods or passengers. Only allowing weight limits to offset additional weight removes that incentive (assuming the additional weight was within the one or two tonnes being considered.) Some responses indicated that the adoption of these vehicles should be encouraged and if those operating them were able to carry slightly more payload per vehicle that was a positive thing, as it would incentivise their uptake and help to reduce carbon emissions.

A second reason for disagreement outlined by several manufacturers was that for those who do not produce comparable diesel vehicles, working out how much weight was due to the different powertrain would be very difficult. This is because alongside obvious items like engines, motors, fuel tanks or batteries, lots of other vehicle components may be specifically designed with alternative fuel or zero emissions powertrains in mind. Therefore, where to draw the line on the additional weight could be difficult to determine.

A third reason for disagreement, raised mainly by vehicle operators or their representative groups, was a view that weight limits should be raised generally, for all vehicles including diesels and those already operating at 44 tonnes. This could allow for increased freight efficiency. As with the previous two questions, some respondents who agreed with the proposal overall thought that vehicle weight limits and axle weight limits should also be reviewed, either to increase freight efficiency or to improve the uptake of alternatively fuelled and zero emission vehicles.

Our response

Based on the views set out and discussion with our arm’s length bodies, we will implement a weight limit increase for the specified alternatively fuelled vehicle types of up to one tonne, depending on the additional powertrain weight. We will implement a flat weight limit increase of two tonnes for the specified zero emission vehicles. Maximum weights for individual axles and the overall maximum of 44 tonnes for six-axle combinations will not change at present. These changes provide the maximum incentive for the adoption of zero emission vehicles while recognising that some manufacturers do not have diesel comparator vehicles.

Next steps

We are grateful for the extensive engagement from respondents throughout this consultation process and look forward to working closely with stakeholders in the future to deliver the economic, environmental and fuel security benefits from zero emission HGVs.

In recognition of the complexity of HGV use cases we have published a call for evidence alongside this consultation aimed at industry partners. The call for evidence seeks to gather evidence on a potential limited range of exemptions for vehicles weighing 26 tonnes or under which may require until 2040 to transition. We welcome your responses. The call for evidence opens on 12 May 2022 and will close on 22 July 2022. We will publish a summary of responses and a government response in due course.