2 FAQ on EPA Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles (“GHG Rule”) Q 5. How does the final rule compare to the proposed rule? A The final rule is a significant improvement over the proposed rule for model years 2027 to 2030. The final rule introduces a more lenient approach for model years 2027 to 2030, reducing the CO2 emissions targets by 25% to 32% compared to the original proposal. MY2031 and 2032, however, will require CO2 emissions, and the corresponding vehicle mix, to be very similar to the aggressive standards in the proposed rule. The improvement is a result of two changes: (1) the required Co2 emissions allowance was greatly increased for MY2027 to 2030, and (2) flexibilities that were proposed to be phased out immediately are now phased out over the life of the rule. Q 6. What happens if manufacturers do not comply with the regulations? A Manufacturers that fail to meet the rule’s emissions standards will not face “fines” (but could be subject to civil penalties). However, they are required to ensure their fleet’s compliance retrospectively, potentially necessitating an increased production of BEVs in future years to offset any discrepancies. As a practical matter, the OEMs will produce and deliver vehicles in line with the regulations. Q 7. How is the EPA rule different than CARB’s ZEV mandates? A The California Air Resources Board (CARB) has implemented its Advanced Clean Car II (ACCII) program, spanning model years 2026 to 2035, demanding a more aggressive shift towards Zero Emission Vehicles (ZEVs). While there is overlap in the objectives of both regulations, CARB’s mandates are more stringent, necessitating a larger proportion of EV sales annually compared to the EPA’s standards. For reference, PHEV sales historically have been about 25% of BEV sales. This table is based on EPA’s Pathway A: 2027 2028 2029 2030 2031 2032 EPA ICE+HEV 68% 63% 54% 47% 38% 32% PHEV 6% 6% 8% 9% 11% 13% BEV 26% 31% 39% 44% 51% 56% CARB ICE+HEV 57% 49% 41% 32% 24% 18% PHEV 9% 10% 12% 14% 15% 16% BEV 34% 41% 47% 54% 61% 66% So far, 11 states have explicitly adopted CARBs ACCII regulation under § 177 of the Clean Air Act—though 6 of the states will begin requirements in 2027 as opposed to 2026. (2026: MA, NY, OR, VT, and WA; 2027: CO, NJ, MD, DE, RI, NM). As seen in the graph1 below, many CARB states are nowhere near the new car sales required by ACCII for MY2026/2027. 1. Alliance for Automotive Innovation Comments on ACCII Waiver (https://www.regulations.gov/comment/EPA-HQ-OAR-2023-0292-0182). 10
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