““amendments” means the amendments made by articles 110 and 113;
The Vehicle Emissions Trading Schemes (Amendment) Order 2025
Published: Wed 18th Jun 25
The Vehicle Emissions Trading Schemes (Amendment) Order 2025 amends the 2023 and 2024 Orders to clarify the calculation of vehicle emissions targets for manufacturers.
It specifies that vehicles first registered in either the UK or EU are to be included in these calculations, using the EU Regulation (EU) 2019/631 as a basis for calculation for both a UK specific and EU specific target.
The manufacturer's final target is the higher of the two calculated in this way.
The Order ensures consistency and clarity in application, supporting the UK's climate change goals while considering the implications of Brexit and retaining UK control and clarity over emission reduction targets.
The Order takes effect on 2nd October 2025 and applies across the UK.
Arguments For
Improved Clarity and Consistency: The amendments clarify the calculation of specific emissions targets, ensuring a more consistent and fair approach for manufacturers.
Enhanced Compliance: By specifying the inclusion of UK-registered vehicles, the Order ensures better compliance with emission reduction targets and promotes environmental objectives.
Legal Basis: The Order is made under the powers conferred by sections 44, 54 and 90(3) of, and paragraph 9 of Schedule 3 to, the Climate Change Act 2008, with consultation of relevant stakeholders.
Alignment with EU Regulations (While Maintaining UK Sovereignty): The order maintains the use of EU regulations for calculation, but allows use of UK registered vehicles, enabling better monitoring and compliance with greenhouse gas emission reduction targets, while retaining UK control over aspects of the system.
Arguments Against
Potential Administrative Burden: Calculating both UK and EU targets might add administrative complexity for manufacturers and the relevant authorities.
Unintended Consequences: Changes to the calculation methodology may unintentionally affect the overall effectiveness of the emissions trading scheme.
Lack of Wider Consultation (Potential): While the order mentions consultations, there may be concerns about the level of public or industry-wide engagement on the precise amendments made.
Citation, commencement and extent1.
(1)
This Order may be cited as the Vehicle Emissions Trading Schemes (Amendment) Order 2025 and comes into force on 2nd October 2025.
(2)
This Order extends to England and Wales, Scotland and Northern Ireland.
Section 1 provides the official title of the Order as the Vehicle Emissions Trading Schemes (Amendment) Order 2025 and states its effective date of October 2nd, 2025.
It also defines the geographical scope of the Order as covering all four nations of the United Kingdom: England, Wales, Scotland, and Northern Ireland.
Amendment of the Vehicle Emissions Trading Schemes Order 20232.
(1)
The Vehicle Emissions Trading Schemes Order 20232 is amended as follows.
(2)
In article 116(1)—
(a)
before the definition of “old scheme year”, insert—
“EU target” means a manufacturer’s specific emissions target calculated using vehicles of the manufacturer first registered in the European Union in the calculations in points 1 to 3 of Part A or B of Annex I to Regulation (EU) 2019/631 in accordance with article 116(4);”;
(b)
after the definition of “specific emissions obligation”, insert—
““UK target” means a manufacturer’s specific emissions target calculated using vehicles of the manufacturer first registered in the United Kingdom in the calculations in points 1 to 3 of Part A or B of Annex I to Regulation (EU) 2019/631 in accordance with article 116(4);”.
(3)
In article 116(2)—
(a)
before “revocations”, in both places it occurs, insert “amendments and”
;
(b)
in sub-paragraph (b), before “revoked”, insert “amended or”
.
(4)
In article 116(3), before “revocations”, insert “amendments and”
.
(5)
After article 116(3) insert—
“(4)
For the purposes of paragraphs (2) and (3), when calculating the specific emissions target in Annex I of Regulation (EU) 2019/631—
(a)
in points 1 and 2 of Part A, any reference to “new passenger car” must be read as if it means “motor vehicle of category M1 as defined in Article 4 of Regulation (EU) 2018/858, as it has effect in domestic law (in respect of vehicles with GB type-approval) or, where relevant, Article 4 of Regulation (EU) 2018/858 as it has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), which is registered in the United Kingdom or European Union for the first time and which has not previously been registered outside the United Kingdom or European Union”;
(b)
in point 3 of Part A, any reference to “average specific emissions of CO₂” must be read as if it means “in relation to a manufacturer, the average specific CO₂ emissions of motor vehicles of category M1 as defined in Article 4 of Regulation (EU) 2018/858, as it has effect in domestic law (in respect of vehicles with GB type-approval) or, where relevant, Article 4 of Regulation (EU) 2018/858 as it has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), which are registered in the United Kingdom or European Union for the first time and which have not previously been registered outside the United Kingdom or European Union, of which it is the manufacturer”;
(c)
in points 1 and 2 of Part B, any reference to “new light commercial vehicle” must be read as if it means “motor vehicle of category N1 as defined in Article 4 of Regulation (EU) 2018/858, as it has effect in domestic law (in respect of vehicles with GB type-approval), or, where relevant, Article 4 of Regulation (EU) 2018/858 as it has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), with a reference mass not exceeding 2 610 kg, and vehicles of category N1 to which type-approval is extended in accordance with Article 2(2) of Regulation (EC) No 715/2007, as it has effect in domestic law (in respect of vehicles with GB type-approval) or, where relevant, as that Regulation has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), which is registered in the United Kingdom or European Union for the first time and which has not previously been registered outside the United Kingdom or European Union”; and
(d)
in point 3 of Part B, any reference to “average specific emissions of CO₂” must be read as if it means “in relation to a manufacturer, the average specific CO₂ emissions of motor vehicles of category N1 as defined in Article 4 of Regulation (EU) 2018/858, as it has effect in domestic law (in respect of vehicles with GB type-approval), or, where relevant, Article 4 of Regulation (EU) 2018/858 as it has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), with a reference mass not exceeding 2 610 kg, and vehicles of category N1 to which type-approval is extended in accordance with Article 2(2) of Regulation (EC) No 715/2007, as it has effect in domestic law (in respect of vehicles with GB type-approval) or, where relevant, as that Regulation has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), which are registered in the United Kingdom or European Union for the first time and which have not previously been registered outside the United Kingdom or European Union, of which it is the manufacturer”.
(5)
When determining the specific emissions target in Annex I, the Secretary of State must calculate a UK target and an EU target.
(6)
A manufacturer’s specific emissions target is the higher of the UK target or the EU target, unless the manufacturer notifies the Secretary of State otherwise within 30 days of receipt by the manufacturer of their specific emissions target.”.
Section 2 details amendments to the Vehicle Emissions Trading Schemes Order 2023.
Subsections (2), (3) and (4) make textual amendments involving inserting the words “amendments and” before instances of the word “revocations” in article 116.
Subsection (5) introduces a new article 116(4), defining how to calculate emission targets (using both UK and EU registered vehicle data sourced from EU Regulation 2019/631) for passenger cars and light commercial vehicles.
Subsection (6) clarifies how a manufacturer’s final target is determined as the higher of the calculated UK or EU target, unless notified otherwise.
Amendment of the Vehicle Emissions Trading Schemes (Amendment) Order 20243.
(1)
The Vehicle Emissions Trading Schemes (Amendment) Order 20243 is amended as follows.
(2)
In article 25(1)—
(a)
before the definition of “old scheme year”, insert—
““EU target” means a manufacturer’s specific emissions target calculated using vehicles of the manufacturer first registered in the European Union in the calculations in points 1 to 3 of Part A or B of Annex I to Regulation (EU) 2019/631 in accordance with article 25(4);”;
(b)
after the definition of “specific emissions obligation”, insert—
““UK target” means a manufacturer’s specific emissions target calculated using vehicles of the manufacturer first registered in the United Kingdom in the calculations in points 1 to 3 of Part A or B of Annex I to Regulation (EU) 2019/631 in accordance with article 25(4);”.
(3)
After article 25(3) insert—
“(4)
For the purposes of paragraphs (2) and (3), when calculating the specific emissions target in Annex I of Regulation (EU) 2019/631—
(a)
in points 1 and 2 of Part A, any reference to “new passenger car” must be read as if it means “motor vehicle of category M1 as defined in Article 4 of Regulation (EU) 2018/858, as it has effect in domestic law (in respect of vehicles with GB type-approval) or, where relevant, Article 4 of Regulation (EU) 2018/858 as it has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), which is registered in the United Kingdom or European Union for the first time and which has not previously been registered outside the United Kingdom or European Union”;
(b)
in point 3 of Part A, any reference to “average specific emissions of CO₂”must be read as if it means “in relation to a manufacturer, the average specific CO₂ emissions of passenger cars of category M1 as defined in Article 4 of Regulation (EU) 2018/858, as it has effect in domestic law (in respect of vehicles with GB type-approval) or, where relevant, Article 4 of Regulation (EU) 2018/858 as it has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), which are registered in the United Kingdom or European Union for the first time and which have not previously been registered outside the United Kingdom or European Union, of which it is the manufacturer”;
(c)
in points 1 and 2 of Part B, any reference to “new light commercial vehicle” must be read as if it means “motor vehicle of category N1 as defined in Article 4 of Regulation (EU) 2018/858, as it has effect in domestic law (in respect of vehicles with GB type-approval), or, where relevant, Article 4 of Regulation (EU) 2018/858 as it has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), with a reference mass not exceeding 2 610 kg, and vehicles of category N1 to which type-approval is extended in accordance with Article 2(2) of Regulation (EC) No 715/2007, as it has effect in domestic law (in respect of vehicles with GB type-approval) or, where relevant, as that Regulation has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), which is registered in the United Kingdom or European Union for the first time and which has not previously been registered outside the United Kingdom or European Union”; and
(d)
in point 3 of Part B, any reference to “average specific emissions of CO₂” must be read as if it means “in relation to a manufacturer, the average specific CO₂ emissions of light commercial vehicles of category N1 as defined in Article 4 of Regulation (EU) 2018/858, as it has effect in domestic law (in respect of vehicles with GB type-approval), or, where relevant, Article 4 of Regulation (EU) 2018/858 as it has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), with a reference mass not exceeding 2 610 kg, and vehicles of category N1 to which type-approval is extended in accordance with Article 2(2) of Regulation (EC) No 715/2007, as it has effect in domestic law (in respect of vehicles with GB type-approval) or, where relevant, as that Regulation has effect in EU law as amended from time to time and by virtue of the Northern Ireland Protocol (in respect of vehicles with UK (NI) type-approval or EU type-approval), which are registered in the United Kingdom or European Union for the first time and which have not previously been registered outside the United Kingdom or European Union, of which it is the manufacturer”.
(5)
When determining the specific emissions target in Annex I, the Secretary of State must calculate a UK target and an EU target.
(6)
A manufacturer’s specific emissions target is the higher of the UK target or the EU target, unless the manufacturer notifies the Secretary of State otherwise within 30 days of receipt by the manufacturer of their specific emissions target.”.
Similar to Section 2, this section details amendments to the Vehicle Emissions Trading Schemes (Amendment) Order 2024.
Subsection (2) amends article 25(1) by introducing definitions for “EU target” and “UK target”, mirroring the changes made to the 2023 Order.
Subsection (3) inserts a new article 25(4) which specifies the calculation of emissions targets in the same manner as in the amendments to the 2023 order, using information from both UK and EU registered vehicles.
Subsections (5) and (6) mirror the corresponding sections in the amendments to the 2023 Order regarding the Secretary of State’s calculation of UK and EU targets and the manufacturer’s final target determination.
Explanatory Note
(This note is not part of the Order in Council)
This Order amends the Vehicle Emissions Trading Schemes Order 2023 (“the 2023 Order”) and the Vehicle Emissions Trading Schemes (Amendment) Order 2024 (“the 2024 Order”).
The 2023 Order and 2024 Order revoked and saved provisions of Regulation (EU) 2019/631 of the European Parliament and of the Council of 17 April 2019 setting CO2 emission performance standards for new passenger cars and for new light commercial vehicles, and repealing Regulations (EC) No 443/2009 and (EU) No 510/2011. Provisions of that regulation may still be exercised for monitoring and compliance purposes. The amendments specify that vehicles first registered in the UK or the EU may be used when exercising provisions saved by the 2023 Order and 2024 Order, and calculating specific emissions targets under that regulation.
A full impact assessment has not been produced for this instrument as no, or no significant, impact on the private, voluntary or public sector is foreseen. A copy of this instrument together with the Explanatory Memorandum is available on the UK legislation website www.legislation.gov.uk.
The Explanatory Note summarizes the Order's purpose; it clarifies that the amendments adjust previous legislation (the 2023 and 2024 Orders) that dealt with EU regulations on CO2 emissions.
The note explains that the amendments allow for the inclusion of UK-registered vehicles in calculations, maintaining the overall intention of the EU regulation in light of the UK's departure from the European Union.
Finally, it mentions that a full impact assessment wasn't deemed necessary.
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