Closed consultation

Zero emission vans: regulatory flexibility

Published 24 December 2024

Applies to England, Scotland and Wales

Executive summary 

This consultation concerns regulations related to zero emission goods vehicles (ZEGVs) connected with annual vehicle testing, drivers’ hours and tachographs and speed limiter devices. It follows the announcement in October 2023 of the response to a consultation about driving licence flexibility for alternatively-fuelled vehicles. 

In 2019, the UK committed to meeting net zero greenhouse gas emissions by 2050 to ensure that it ends its contribution to climate change. To help achieve this, the zero emission vehicle (ZEV) mandate started in January 2024. This requires increasing percentages of new sales to be ZEVs - 10% of vans in 2024, rising to 100% by 2035.

A ZEGV is a ZEV which is a category N vehicle - a power-driven vehicle with at least 4 wheels, used for the carriage of goods. 

The ZEGV market is growing with record numbers of registrations in 2023. However, it remains at an earlier stage of development compared to the car market. Drivers should be able to use a ZEGV with as much ease as a petrol or diesel equivalent, provided that this can be done while maintaining road safety.

Typically, ZEVs have a higher mass compared to their petrol and diesel equivalents. This is due to the additional weight of their powertrain, including the battery in most cases. Despite this extra weight, these vehicles are equivalent in function and appearance to petrol and diesel vans. 

The proposals in this consultation relate to ZEGVs whose maximum authorised mass (MAM) is 3.5t to 4.25t. Where the consultation relates to the driving of the vehicle, it also considers towing allowances for combinations with a total MAM of up to 7t. 

The main proposals in this consultation are to: 

• transfer the annual testing of ZEGVs, with a MAM of 3.5t to 4.25t, from the heavy vehicle testing system to the MOT network, with the tests used for 3t to 3.5t goods vehicles put in place 
• amend annual testing schedules for ZEGVs, with a MAM of 3.5t to 4.25t, so their first test is after 3 years from first registration (and annually thereafter) 
• remove ZEGVs with a MAM of 3.5t to 4.25t (and when used with a trailer in a combination with a MAM up to 7t) from the requirements for tachograph use, the assimilated drivers’ hours rules (Regulation (EC) 561/2006, as it has effect in the UK) and specific road transport working time rules when used within Great Britain (GB) 

On speed limiters, the department is not proposing any changes at this stage but is seeking evidence about:

• the effects this requirement has on ZEGVs of 3.5t to 4.25t MAM
• if there are any benefits to removing the requirement, or safety benefits to keeping the requirement for speed limiters in place

National speed limits would be unaffected.

This consultation concerns ZEGVs only. The vehicle testing and tachograph thresholds for passenger vehicles relate to the number of seats they have, as opposed to just the MAM. 

The focus of this consultation is on domestic road transport within GB. The UK government has legislative competence across GB in the areas covered by this consultation. The Northern Ireland Executive has legislative competence in these areas in Northern Ireland. 

Introduction 

The UK has committed to reaching net zero greenhouse gas (GHG) emissions by 2050. To reach this goal, emissions from the transport sector need to significantly reduce. In 2021, transport was the highest emitting sector of the economy, producing 26% of the UK’s total GHG emissions, with vans representing 17% of all transport emissions in 2021. 

In January 2024, the Zero Emission Vehicle (ZEV) Mandate came into force in GB. The ZEV Mandate requires that, in 2024, 10% of new vans sold in GB are zero emission, rising annually to 70% in 2030 and to 100% by 2035. The Northern Irish Assembly has approved for the ZEV Mandate to be expanded to apply to Northern Ireland. Northern Ireland will join the ZEV mandate on 1 January 2025.

From January to June 2024, 4.7% of new vans sold in the UK were battery electric, down from 5.2% during the same period in 2023, highlighting the need for further measures to support uptake of ZEGVs. The number of ZEGVs weighing 3.5t to 4.25t has increased rapidly, albeit from a low baseline. At the end of 2021, 188 of these vehicles were registered, rising to 819 at the end of 2022 and to 2,233 by September 2024 (the latest available figure). 

To support uptake of ZEGVs, in 2018 the UK introduced a derogation to driving licence rules, which allowed category B licence holders (the standard car driving licence) to drive alternatively fuelled goods vans with a maximum authorised weight of 4.25t. To access the derogation, category B licence holders:

• must undertake 5 hours of additional training
• can only drive for the purpose of transporting goods
• cannot tow a trailer

Usually, to drive a vehicle above 3.5t a C or C1 licence would be required. The aim of this derogation was to ensure that the heavier powertrain of these vehicles (mainly caused by batteries) did not prevent holders of standard (category B) driving licences from using them. This reduced administrative burdens on drivers and operators with mixed fleets. 

In October 2023, the previous government published a consultation response on additional flexibility for the driving licence derogation. This announced that the derogation would remain in place. It also said that further flexibility would be introduced by:

• removing the additional training requirement
• expanding the types of vehicles covered - for example minibuses
• allowing the same towing capabilities as internal combustion engine (ICE) equivalents

The government is now considering the proposals in the consultation response, to explore how the driving licence flexibility can be further optimised.

Current regulatory framework for zero emission vans 

Alongside driving licence requirements, there are other rules related to vehicles, which may be disincentivising uptake of heavier ZEGVs, which often take effect when a vehicle moves over the 3.5t weight threshold. 

Roadworthiness testing 

Light goods vehicles (LGVs), also known as light commercial vehicles, are defined as any goods vehicle with a gross vehicle weight (GVW) of up to 3.5t and can be subject to either class 4 or class 7 MOT testing. Class 4 MOT testing is for passenger vehicles and goods vehicles up to 3t, with the class 7 test category having been introduced specifically for heavier vans between 3t and 3.5t, inclusive.

There are around 6,400 MOT test stations that provide class 7 testing, which is just over a quarter of all MOT test stations. Any goods vehicle heavier than 3.5t falls into heavy goods vehicle (HGV) testing. 

Class 4 and class 7 MOT testing are very similar, both in the test content and price, and may be able to be conducted in the same garages (provided that the testing equipment is rated to be safe with the higher weight of class 7 vehicles). However, HGV testing has significant differences, including in content, failure thresholds, frequency and cost, and tests are carried out in an entirely separate network of authorised testing facilities (ATFs) by testers from the Driver and Vehicle Standards Agency (DVSA). 

Due to the weight of the battery, many battery-electric vans have a GVW above the 3.5t threshold and are therefore classed as HGVs, falling within scope of HGV testing. However, the equivalent ICE vehicles (in terms of size, look and usage) are often lighter than 3.5t and therefore fall into class 7 MOT testing.

This has meant there are additional requirements for operators of battery electric vans, compared with managing conventional ICE van fleets. Vehicles falling into HGV testing are subject to additional burdens which include:

• a first test after 1 year from registration versus after 3 years from registration for class 4 or 7 vehicles
• higher test fees
• a smaller, more saturated network of testing facilities to book tests with

This has reportedly resulted in more vehicle downtime during testing and therefore greater costs for fleet operators. Operators of fleets with a mix of battery electric and ICE vans may find the variation in testing procedure particularly burdensome, as vehicles being used for the same task by the same group of drivers may have to be on separate testing schedules. 

Table 1: Differences between Class 7 MOT testing and HGV testing

Test element	Class 7 MOT test	HGV test
Maximum fee	£58.60	£146.00
Approximate test facility network size	6,400	500
Testers	Private sector	DVSA employees
Minimum tyre tread depth	1.6mm	1.0mm
Maximum tyre age	No limit	10 years
Other differences		Inspection of:  - rear under-run bars  - sideguards  - side marker lamps  - side reflectors  - spray suppressions  - wings and wheel arches  - pawl control  - power train  - battery mountings

The differences listed in Table 1 are not exhaustive. There are many more differences in failure thresholds and potential defect categorisations not listed here. 

Drivers’ hours and tachographs 

Within GB, either GB domestic drivers’ hours rules (contained in Part V of the Transport Act 1968, as amended) or assimilated drivers’ hours rules (Regulation (EC) 561/2006, as it has effect in the UK) may apply. Which set of rules applies depends on the type or size of the vehicle being used and the type of driving or journey.

Both sets of drivers’ hours rules are in place to improve road safety by reducing the risk of drivers being involved in fatigue related incidents and to improve the working conditions of drivers. The rules also ensure fair competition in the industry by setting a common standard of rules under which all are required to operate. 

Drivers of goods vehicles weighing 3.5t or less fall in-scope of the GB domestic drivers’ hours rules, with separate, similar rules in Northern Ireland. According to these domestic rules, in any 24-hour period the:

• maximum driving time is 10 hours
• maximum duty time is 11 hours

Duty includes all periods of work and driving, but does not include rest or breaks. There are no specific break or rest requirements for goods vehicles under these rules. 

The only exemptions from the GB drivers’ hours rules are for: 

• drivers of vehicles used by the armed forces, the police and fire brigade 
• drivers who always drive off the public road system 
• private driving - driving not in connection with a job or in any way to earn a living 

In addition, drivers in-scope of the GB drivers’ hours rules need to comply with 4 provisions of the Working Time Regulations 1998, as amended. These are:

• an entitlement to 5.6 weeks paid annual leave
• a weekly working limit of 48 hours - with an opt out available
• health checks for night workers
• an entitlement to adequate rest

Adequate rest is defined as being long and continuous enough to ensure that a driver does not harm themselves, fellow workers or others and that they do not damage their health in the long or short term. 

Drivers of goods vehicles weighing over 3.5t (and passenger vehicles with more than 10 seats) fall in-scope of the assimilated drivers’ hours rules and, therefore, the assimilated tachograph rules.

Tachographs are recording devices fitted to vehicles in compliance with the assimilated tachograph rules (Regulation (EU) 165/2014, as it has effect in the UK). They are used to record a driver’s compliance with the assimilated drivers’ hours rules. The assimilated drivers’ hours rules prescribe maximum limits on driving time and minimum requirements for breaks and rest periods, which can be summarised as: 

• a daily driving limit of 9 hours - which can be extended to 10 hours twice a week 
• a requirement to take a break of at least 45 minutes after no more than 4 hours 30 minutes driving 
• a weekly driving limit of 56 hours and fortnightly driving limit of 90 hours 
• a daily rest of at least 11 continuous hours - which can be reduce to 9 hours 3 times a week
• a weekly rest of at least 45 continuous hours (which can be reduced to at least 24 continuous hours every other week) after 6 consecutive 24-hour periods of working, starting from the end of the last weekly rest period taken 

Drivers operating under the assimilated drivers’ hours rules are also subject to the sector specific Road Transport (Working Time) Regulations 2005, as amended. These regulations set limits on the total amount of work that can be carried out in one week, including driving, but also any other work carried out. The weekly limit must average 48 hours per week over a specific reference period (with no opt out available), although in any particular week the limit can be 60 hours provided the average is no more than 48 hours. 

There are a number of exemptions and national derogations from the assimilated drivers’ hours rules and assimilated tachograph rules (and thus the need to install and use a tachograph), including a national derogation for: 

Vehicles used for the carriage of goods within a 100 km radius from the base of the undertaking and propelled by means of natural or liquefied gas or electricity, the maximum permissible mass of which, including the mass of a trailer or semi-trailer, does not exceed 7.5 tonnes.

This national derogation covers electric goods vehicles weighing up to 4.25t used to transport goods within a 62-mile (100 kilometre) radius of their base (these distances are the same, 62 miles is used in this document). However, if these vehicles are being used over 62 miles radius from their base, they are required to comply with the assimilated drivers’ hours rules and would also need to install and use a tachograph.

There are a number of other national derogations which may apply to ZEVs (also included in the Schedule to the Community Drivers’ Hours and Recording Equipment Regulations 2007) which are not restricted to a specific distance, but which are used for specific purposes (not normally associated with long distance driving) such as vehicles:

• used on small islands
• used in connection with sewerage, flood protection, water, gas or electricity maintenance services

To protect road safety, exemptions and derogations are limited in scope to mitigate risks. For example, the 62-mile radii in the above and certain other national derogations, are in place to ensure larger vehicles over 3.5t are not used for long distance journeys, without their drivers coming under scope of the break and rest requirement in the assimilated drivers’ hours rules. This reflects that these vehicles could still pose a threat to road safety if their drivers drive whilst tired. The larger the vehicle, the more likely an incident would result in road users being killed or seriously injured. 

As the range and uptake of 4.25t ZEGVs increases, it is expected that more will need to travel beyond 62 miles from their base. This would mean they would fall out of scope of the current derogation, and would need to follow the assimilated drivers’ hours rules and also use a tachograph. This presents the potential for a discrepancy in the rules applying to vans within the same fleet (if it included a mix of ICE vehicles and ZEGVs) and could be particularly complex if drivers used different vehicle types on different days. Any change here would need to carefully consider whether permitting the heavier ZEGVs to follow the same rules as lighter ICE vans presented an increased safety risk.  

Speed limiters 

Goods vehicles weighing up to 7.5t are limited to a maximum speed of 60mph on single and dual carriageways. This category includes the lighter ICE equivalents of 4.25t ZEGVs. Vehicles weighing above 3.5t (that are in scope of speed limiter requirements) are further limited to a maximum speed of 56mph via built-in speed limiters, with the intention of maintaining road safety. 4.25t ZEGVs fall into this category.

Therefore, the removal of a requirement to fit a speed limiter to 4.25t ZEGVs would only make a marginal difference to the maximum speeds these vehicles are able to travel at on those roads. 

The initial fitting of a speed limiter may add additional cost to the use of a (new) 4.25t ZEGV and may therefore be a barrier to their adoption. However, some speed limiters may be installed as a piece of software which does not incur a cost to fit. Goods vehicles weighing up to 7.5t, where speed limiters are not required, are allowed to travel at up to 70mph on motorways. So there would be a greater difference in the speed that could be travelled on those roads if the requirement for a speed limiter were removed.

Under the Motorways Traffic (England and Wales) Regulations 1982 (as amended), goods vehicles weighing 3.5 to 7.5t that are required to be fitted with a speed limiter are not permitted to use the right-hand lane of a motorway with 3 or more lanes - except in certain circumstances. The removal of the requirement to fit a speed limiter to ZEGVs weighing up to 4.25t would mean these vehicles were not restricted in this way. 

Industry feedback has indicated that drivers may find the reduction in maximum speed frustrating, as they are unable to pass HGV traffic on motorways. However, the use of speed limiters supports road safety by reducing the chances of a collision and reducing the impacts in the event of a collision.  

Operator licensing 

Goods vehicles with a MAM of 3.5t to 4.25t fuelled wholly by electricity, hydrogen, natural gas, or liquified petroleum gas and used within GB are currently exempt from operator licensing requirements and no changes are proposed in this consultation.  

Proposals 

Roadworthiness testing 

Moving ZEGVs with a MAM of 3.5t to 4.25t from HGV testing into the class 7 MOT testing system would reduce costs and administrative burdens currently experienced by operators of these vehicles. The statutory fees for class 7 MOT tests are less than those for HGV tests (mainly because the fee does not fund enforcement in the same way) and there is a wider pool of garages able to conduct them.

There are a higher number of available testing locations, and hence less average drive time to test locations and lower risks of delays to obtaining a test booking. This results in less vehicle downtime and administration, compared to the existing HGV testing requirement. Shifting these vehicles into class 7 testing would also mean that zero emission and ICE vehicles performing an equivalent role (such as home delivery of groceries) undergo equivalent tests, reducing administrative burdens and the potential for confusion for those with mixed vehicle fleets.

One of the primary barriers to this change, however, is that it is not yet clear exactly what proportion of the class 7 tester network have sufficiently rated equipment to accommodate vehicles up to 4.25t. An initial survey was done, which demonstrated promising results, but responses to this consultation may help to provide a stronger indicator of the capacity and the appetite in the network for this change. 

The Heavy Vehicle Testing Review published in 2021 found that a small number of HGV operators experienced difficulty in quickly and easily booking tests. Although the requirement for a planned and preventative maintenance system should mean there is some planning, and since then DVSA have increased availability of test slots.

For ZEGVs there have been anecdotal reports of operators having to transport vehicles to a test on a trailer as the ATF was out of its own range, and of operators needing to book tests several months in advance to secure bookings at preferred times and places.  

Shifting ZEGVs weighing from 3.5t to 4.25t into class 7 testing would, to a small extent, reduce overall future demand on the HGV testing system and allow for operators to more easily book testing slots. This would reduce the number of vehicles required to be tested at ATFs, so they would lose some customers, who would instead be using garages able to test class 7 vehicles. However, ZEGVs weighing between 3.5t and 4.25t represent a very small proportion of HGVs requiring testing, so this effect is unlikely to be significant. Although it would be expected to increase over time as more ZEGVs are on the road. 

While shifting ZEGVs from HGV testing to class 7 MOT testing would reduce the burden on operators, class 7 testing does not cover all of the same areas as HGV testing and may therefore reduce assurance of road safety for these vehicles. While heavier ZEGVs are likely to undertake similar tasks to ICE vans weighing under 3.5t, their higher weight means that collisions would be more forceful and therefore potentially more dangerous.

However, from 2019, when registration of these vehicles was first recorded, to 2022 there were only 4 reported injury collisions involving fully electric good vehicles weighing 3.5 to 4.25 tonnes (DfT STATS19 road collision data). It should be noted however that as of September 2024, there were 2,233 registered electric vans between 3.5 and 4.25t in the UK (DfT/DVLA vehicle statistics). So the low number of injury collisions may reflect the low number of these vehicles on the road. 

As discussed in this consultation, the requirement for tachograph equipment could be removed. If not, checks of tachographs (or speed limiters) would not necessarily need to be added into the MOT test, as these items could be assessed via DVSA roadside enforcement - although this is limited in volume for vans.

In future there will be other goods vehicles with tachographs in the MOT system, because goods vehicles weighing 2.5t to 3.5t will require a tachograph when being used internationally for hire or reward from 1 July 2026. Regardless of whether speed limiter and tachograph rules also change, there will be some vehicle features on in scope ZEGVs that would be tested in an HGV test but would not be tested in a class 7 MOT test (such as side guards where fitted) unless the class 7 test requirements are changed. It is proposed to use the current class 7 test requirements for 3.5t to 4.25t ZEGVs and to not make any changes to the test for these vehicles. 

Alongside moving vehicles from HGV testing into class 7 MOT testing, the intervals at which tests are required could be changed. At present HGV tests are required annually from a year after first registration, rather than annually after 3 years from first registration for class 7 vehicles. If 4.25t ZEGVs were shifted into class 7 testing, the intervals they are tested at could also be shifted, to match other vehicles in this class, including their ICE equivalents. Only requiring an annual test after 3 years from first registration would reduce the administrative burden on operators. However, it may also increase road safety risk in cases where defects are not picked up which otherwise would have been in tests one and 2 years from first registration. 

An alternative is to move vehicles into class 7 testing but maintain their existing testing schedule. 4.25t ZEGVs are likely to be commercial vehicles recording greater average mileages than many of the vehicles with the first test at 3 years and they are heavier than vehicles with the first test at 3 years. The higher weight of these vehicles may mean that some parts wear more quickly, particularly tyres and suspension, which may have a negative effect on road safety.  

The MOT fail rate for vans is higher than that for cars, which in turn is higher than that for HGVs. Results from roadside checks also show that vans in general are less well maintained than HGVs. Most vans, unlike HGVs, are out of scope of the operator licensing regime and its requirements for planned and preventative maintenance systems, which has an effect on statutory test pass rates. For the electric vehicles that currently pass through the MOT system, their failure rate is higher than their ICE equivalents at equivalent ages, with items such as tyres wearing quicker because of higher torque and weights. Any change therefore will need to consider if the risks of the move of 4.25t ZEGVs into class 7 MOT testing can be mitigated.  

It is proposed that ZEGVs weighing from 3.5t to 4.25t are moved out of the HGV roadworthiness testing system and into class 7 MOT testing, with a first test 3 years from initial registration.

Testing requirements for ICE vans would remain unchanged, so if they weigh over 3.5t, they would be tested in the HGV system, with a first test from a year after first registration, and testing then done annually.

It is proposed that test content for the class 7 should remain as is, without adding items that would otherwise be tested in the HGV test. 

Questions for all respondents 

These questions are included here so you can read them in the context of this document. See the Ways to respond section of the GOV.UK home page for this consultation for an online response form and other ways to respond. 

• Should 4.25t zero emission vans undergo class 7 MOT testing, (rather than HGV testing)? Please explain your answer. 

• Should 4.25t zero emission vans be MOT tested after 3 years from first registration (and then annually), rather than after one year from first registration (and then annually)? Please explain your answer. 

• Would MOT testing 4.25t zero emission vans via a class 7 MOT have an effect on road safety? Please explain your answer. 

• Would MOT testing 4.25t zero emission vans after 3 years from first registration (and then annually), rather than after one year (and then annually) have an effect on road safety? Please explain your answer. 

• Assuming that tachograph and speed limiter rules do not change, do you think that the Class 7 MOT test content should be changed to include the basic checks of these items (which are currently contained within the HGV test)? 

• Are there other features that would be tested in an HGV test (such as sideguards) for which it would be important to update the Class 7 MOT if it included 4.25t zero emission vans (which all vehicles would be subject to)? Please explain your answer.  

• Is HGV testing for 3.5t - 4.25t zero emission vans more burdensome than MOT testing for 3.5t ICE vans? Please explain your answer. 

• Would moving 4.25t zero emission vans from HGV testing into scope of class 7 MOT testing reduce the burden on vehicle operators? Please explain your answer. 

• Would testing 4.25t zero emission vans after 3 years from first registration (and then annually), rather than after one year (and then annually) reduce the burden on vehicle operators? Please explain your answer. 

Questions for vehicle operators with 3.5t to 4.25t ZEGVs 

• Approximately how long is the downtime for an electric van during its annual HGV test (downtime includes preparation, driving to the test centre, test time etc, until the van is back in operation)?  

• Does the driver continue working during downtime or is this lost business time? 

• Do you own ICE vans weighing up to 3.5t, with a similar cargo weight to a 4.25t zero emission van?  

• If yes, can you give an estimate for the downtime of testing if electric vans were moved into class 7 testing? 

• In this scenario, would the driver continue working or is this lost business time? 

Questions for class 7 MOT test centres 

• With current vehicle testing equipment and expertise, would your centre be able to carry out a Class 7 MOT test on a 3.5t-4.25t zero emission vehicle? 

• If no, would you consider investing in the additional equipment/expertise that would be required if the regulations were to be put in place? Please explain your answer. 

Questions for ATFs  

• With current vehicle testing equipment and expertise, can you carry out an HGV test on a 3.5t-4.25t zero emission vehicle? 

Drivers’ hours and tachographs 

As the uptake and range of ZEGVs up to 4.25t increases, it is expected that more of them will need to travel beyond 62 miles from their base, meaning they would need to follow the assimilated drivers’ hours rules and also use a tachograph.

Shifting ZEGVs with a MAM of 3.5t to 4.25t out of scope of the assimilated drivers’ hours rules would mean they were subject to the GB drivers’ hours rules, like equivalent diesel vans weighing 3.5t or less. Whether moving into the GB rules would lead to an increase in driving hours would depend on the nature of the task a driver was doing. For example, while the daily driving limit is one hour higher in the GB rules, the daily duty limit may restrict working on other non-driving tasks. 

One element that would change for all operators is that a tachograph would not be required to be fitted in the vehicle, as this is not a requirement within the GB rules. This would remove the cost of both initially fitting a tachograph and maintaining it (although some businesses may choose to still do so, as a way of recording driving time).  

The other area that would be of significant benefit to businesses with mixed fleets (with some vehicles in scope of the assimilated rules and others in the GB rules), would be simplifying drivers’ hours requirements by making them uniform for both sets of vans, reducing administrative burden and the potential for confusion. This may provide a particular benefit for companies where drivers use both ICE goods vehicles and ZEGVs on different days, as they would only have to manage compliance with one set of rules.  

Although similar-sized ICE goods vehicles are already under the domestic rules, as are the ZEGVs up to 4.25t within 62 miles radius of base, this consultation seeks evidence to try and estimate whether driver welfare and road safety would be affected by the proposed changes to increase the weight of the ZEGVs that could be driven while in scope of the GB drivers’ hours rules by 0.75t. 

Given the potential for benefits to businesses and significantly reduced administration, it is proposed to move ZEGVs weighing from 3.5t to 4.25t out of scope of the assimilated drivers’ hours rules, leaving them in scope of the GB drivers’ hours rules, and the assimilated tachograph rules, unless there are any significant road safety implications of doing this.  

Questions for all respondents 

• What would be the benefits and risks of removing ZEGVs up to 4.25t from the scope of the assimilated drivers’ hours rules (leaving them in scope of the GB rules)? Please explain your answer. 

• Should ZEGVs up to 4.25t be removed from scope of the assimilated drivers’ hours rules (leaving them in scope of the GB rules)? Please explain your answer. 

• What would be the benefits and risks of removing ZEGVs up to 4.25t from the scope of the assimilated tachograph rules (so they would not be required to use a tachograph)? 

• Should ZEGVs up to 4.25t be removed from scope of the assimilated tachograph rules (so they would not be required to use a tachograph)? Please explain your answer. 

Questions for vehicle operators with 3.5t to 4.25t ZEGVs 

Drivers’ hours 

• How many ZEGVs with a MAM of 3.5t to 4.25t are currently in operation in your fleet? 

• Are you aware of the existing differences in drivers’ hours rules between 4.25t ZEGVs and 3.5t ICE equivalents? 

• What drivers’ hours rules do you currently follow? 

• Approximately, how long are electric van drivers’ shifts?  

• How much of this time on average is spent driving per shift?  

• On average, how many shifts per week does each full-time electric van driver do? 

• On average, how many shifts per week are completed in each 3.5t-4.25t electric van (with any driver)?  

• How long and how often are breaks for drivers of electric vans?  

• Do you find drivers need to stop and charge 4.25t electric vans during a shift?  

• If yes, on average how long does this take and is this considered as work time or taken as a break? 

• How do you expect business operations to change if 4.25t zero emission vans were moved into scope of GB drivers’ hours? Please provide as much detail as possible.  

• Do you think this would increase your uptake of 4.25t zero emission vans in future?  

Tachographs 

• Would you continue to use a tachograph if 4.25t ZEGVs moved into GB rules?  

• What are, and how much are the approximate ongoing maintenance costs associated with tachographs for each 4.25t ZEGV per year? 

• Do the 4.25t ZEGVs you operate currently stay within a 62-mile radius from your base of operations? 

Familiarisation 

• Roughly how much time would it take you to adjust business operations if regulations were changed as outlined in the Drivers’ hours and tachographs section?  

Questions for vehicle manufacturers 

• Do you fit tachographs onto all goods vehicles over 3.5t? 

• If yes, are there any reasons why customers may ask for a tachograph not to be installed onto their vehicle? Please explain these reasons. 

Speed limiters 

Requiring the installation of speed limiters may add costs to the initial purchase of 4.25t ZEGVs and be a business burden during their use. The lower motorway speed limit compared to an equivalent 3.5t ICE van may be frustrating for drivers and reduce the amount of work than can be done in one shift. As vehicle range increases and these vehicles are used for longer journeys, the effect may become more significant.  

Speed limiters do reduce risks of crashes and injuries when they occur. The department seeks evidence about the effects of speed limiters related to 3.5t to 4.25t ZEGVs. It is prepared to consider removing the requirement for a speed limiter but is not proposing that in this consultation. 

Question for all respondents 

• In your view, should the requirement for speed limiters to be fitted to 4.25t zero emission vans be removed? Please explain your answer. 

• In your view, what effect would removing the requirement for speed limiters for 4.25t zero emission vans have on road safety? Please explain your answer. 

• In your view, are requirements for speed limiters a significant barrier to adoption of 4.25t zero emission vans? 

• If yes, is the more significant barrier the initial fitting and maintenance of the speed limiter itself, the speed limit imposed or are they both significant? 

How to respond 

See the Ways to respond section of the consultation page on GOV.UK to find out how you can respond to this consultation. 

The consultation period began on 24 December 2024 and will run until 3 March 2025. Please ensure that your response reaches us before the closing date.  

What will happen next 

We will publish a summary of responses and the government response on the homepage for this consultation. Paper copies will be available on request.  

If you have questions about this consultation please contact: 

Rob Evans 
3/03 Great Minster House 
33 Horseferry Road 
London SW1P 4DR 

07971 110212 

ZeroEmissionVanConsultation@dft.gov.uk 

Full list of questions 

Questions for all respondents 

These questions are listed here to give you an overview of what we are asking.  

See the Ways to respond section of the GOV.UK home page for this consultation for an online response form and other ways to respond. 

• What is your name and email address? 

• Are you responding on behalf of an organisation? 

• If you are responding on behalf of an organisation, what is the name of the organisation? 

• How many employees are in your organisation? 

• 1 to 9 employees 

• 10 to 49 employees 

• 50 to 249 employees 

• 250 to 499 employees 

• 500 to 1,000 employees 

• above 1,000 employees 

Vehicle testing 

• Should 4.25t zero emission vans undergo class 7 MOT testing, (rather than HGV testing)? Please explain your answer. 

• Should 4.25t zero emission vans be MOT tested after 3 years from first registration (and then annually), rather than after one year from first registration (and then annually)? Please explain your answer. 

• Would MOT testing 4.25t zero emission vans via a class 7 MOT have an effect on road safety? Please explain your answer. 

• Would MOT testing 4.25t zero emission vans after 3 years from first registration (and then annually), rather than after one year (and then annually) have an effect on road safety? Please explain your answer. 

• Assuming that tachograph and speed limiter rules do not change, do you think that the Class 7 MOT test content should be changed to include the basic checks of these items (which are currently contained within the HGV test)? 

• Are there other features that would be tested in an HGV test (such as sideguards) for which it would be important to update the Class 7 MOT if it included 4.25t zero emission vans (which all vehicles would be subject to)? Please explain your answer.  

• Is HGV testing for 3.5t - 4.25t zero emission vans more burdensome than MOT testing for 3.5t ICE vans? Please explain your answer. 

• Would moving 4.25t zero emission vans from HGV testing into scope of class 7 MOT testing reduce the burden on vehicle operators? Please explain your answer. 

• Would testing 4.25t zero emission vans after 3 years from first registration (and then annually), rather than after one year (and then annually) reduce the burden on vehicle operators? Please explain your answer. 

Drivers’ hours and tachographs 

• What would be the benefits and risks of removing zero emission vans up to 4.25t from the scope of the assimilated drivers’ hours rules (leaving them in scope of the GB rules)? Please explain your answer. 

• Should zero emission vans up to 4.25t be removed from scope of the assimilated drivers’ hours rules (leaving them in scope of the GB rules)? Please explain your answer. 

• What would be the benefits and risks of removing ZEGVs up to 4.25t from the scope of the assimilated tachograph rules (so they would not be required to use a tachograph)? 

• Should ZEGVs up to 4.25t be removed from scope of the assimilated tachograph rules (so they would not be required to use a tachograph)? Please explain your answer. 

Speed limiters 

• In your view, should the requirement for speed limiters to be fitted to 4.25t zero emission vans be removed? Please explain your answer. 

• In your view, what effect would removing the requirement for speed limiters for 4.25t zero emission vans have on road safety? Please explain your answer. 

• In your view, are requirements for speed limiters a significant barrier to adoption of 4.25t zero emission vans? 

• If yes, is the more significant barrier the initial fitting and maintenance of the speed limiter itself, the speed limit imposed or are they both significant? 

(If answered ‘yes’ to ‘are you responding on behalf of an organisation’, questions continue. If they answered ‘no’, continue to the final questions for all respondents) 

Questions for vehicle operators 

• Does your organisation currently have zero emission vans weighing 3.5t-4.25t in its fleet?  

• If no, what has prevented you from using them? (then go to next section) 

• If yes, how many zero emission vans between 3.5t-4.25t are currently in operation in your fleet? 

Vehicle testing 

• Approximately how long is the downtime for an electric van during its annual HGV test (downtime includes preparation, driving to the test centre, test time etc, until the van is back in operation)  

• Does the driver continue working during downtime or is this lost business time? 

• Do you own ICE vans weighing up to 3.5t, with a similar cargo weight to a 4.25t zero emission van?  

• If yes, can you give an estimate for the downtime of testing if electric vans were moved into class 7 testing? 

• In this scenario, would the driver continue working or is this lost business time? 

Drivers’ hours 

• How many ZEGVs with a MAM of 3.5t to 4.25t are currently in operation in your fleet? 

• Are you aware of the existing differences in drivers’ hours rules between 4.25t ZEGVs and 3.5t ICE equivalents? 

• What drivers’ hours rules do you currently follow? 

• Approximately, how long are electric van drivers’ shifts?  

• How much of this time on average is spent driving per shift?  

• On average, how many shifts per week does each full-time electric van driver do? 

• On average, how many shifts per week are completed in each 3.5t-4.25t electric van (with any driver)?  

• How long and how often are breaks for drivers of electric vans?  

• Do you find drivers need to stop and charge 4.25t electric vans during a shift?  

• If yes, on average how long does this take and is this considered as work time or taken as a break? 

• How do you expect business operations to change if 4.25t zero emission vans were moved into scope of GB drivers’ hours? Please provide as much detail as possible.  

• Do you think this would increase your uptake of 4.25t zero emission vans in future?  

Tachographs 

• Would you continue to use a tachograph if 4.25t zero emission vans moved into GB rules?  

• What are, and how much are the approximate ongoing maintenance costs associated with tachographs for each 4.25t ZEGV per year? 

• Do the 4.25t ZEGVs you operate currently stay within a 62-mile radius from your base of operations? 

Familiarisation 

• Roughly how much time would it take you to adjust business operations if regulations were changed as outlined above?  

Questions for vehicle manufacturers 

• Are you responding on behalf of a vehicle manufacturer? 

• If no, go to next section. 

• If yes, do you fit tachographs onto all goods vehicles over 3.5t?  

• If yes, are there any reasons why customers may ask for a tachograph not to be installed onto their vehicle? Please explain these reasons.  

Questions for class 7 MOT test centres 

• Are you responding on behalf of a class 7 MOT test centre? 

• If no, go to next section. 

• If yes, with current vehicle testing equipment and expertise, would your centre be able to carry out a Class 7 MOT test on a 3.5t-4.25t zero emission vehicle?  

• If yes, go to next section. 

• If no, would you consider investing in the additional equipment/expertise that would be required if the regulations were to be put in place? Please explain your answer. 

Questions for ATFs  

• Are you responding on behalf of an ATF? 

• If no, go to next section. 

• If yes, with current vehicle testing equipment and expertise, can you carry out an HGV test on a 3.5t-4.25t zero emission vehicle? 

Questions for all respondents 

• Do you think there are other zero emission vehicle types or classes that require regulatory flexibility, where they are more heavily regulated than ICE counterparts? 

• If yes, which vehicles? 

• Do you have any further comments? 

Freedom of information 

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004. 

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence. 

In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the department. 

Data protection 

The Department for Transport (DfT) is carrying out this consultation to gather evidence on regulatory flexibility for ZEGVs. This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, DfT will, under data protection law, be the Controller for this information.  

As part of this consultation we’re asking for your name and email address. This is in case we need to ask you follow-up questions about any of your responses. You do not have to give us this personal information. If you do provide it, we will use it only for the purpose of asking follow-up questions. 

DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact the Data Protection Officer.

Consultation principles 

This consultation is being conducted in line with the government’s consultation principles. 

If you have any comments about the consultation process, contact: 

Consultation Co-ordinator
Department for Transport
Zone 1/29 Great Minster House
London
SW1P 4DR 

 Email consultation@dft.gov.uk