Select Committee on Environmental Audit First Special Report


Appendix: Government response


Government response to Environmental Audit Committee report on Vehicle Excise Duty as an environmental tax

1. We agree with the Exchequer Secretary: the rebanding of cars bought since 2001 is not retrospective taxation. The only retrospective element in these changes is that the new rates will apply to cars that have already been bought. In itself there is nothing intrinsically unfair or unusual about this. Variable VED was first introduced in 1999 and the creation of new bands, with the single exception of Band G, has always been applied to cars already purchased. (Paragraph 12)

The Government welcomes the Committee's report on Vehicle Excise Duty as an Environmental Tax. The Committee continues to provide a constructive focus on environmental issues.

The Government welcomes the acknowledgement from the Committee that the 2008 Budget changes to Vehicles Excise Duty (VED) are not retrospective. As confirmed in the Pre-Budget Report, the changes will only come into effect from April 2009 and the duty will not apply to previous tax years.

The aim of these reforms is to ensure that when people choose a lower-carbon car they will be rewarded financially. As the Committee notes, it is important that the environmental signal within VED applies in the second-hand market—where around three quarters of purchases are made each year—as well as in the new car market.

The CO2-based VED system has been designed in order to respond to changes in fuel efficiency in vehicle manufacture. With forthcoming EU targets on cutting average new car emissions, it is important that the UK maintains the flexibility to respond to these changes through the VED system. However, if every time that new VED bands were introduced they could only be applied to new cars, the Government could potentially end up introducing multiple systems which would greatly undermine the clarity and consistency of the overall regime, as well as creating administrative burdens for business and the Driver and Vehicle Licensing Agency (DVLA).

For these reasons, and others identified by the Committee, the principle that VED changes should apply to existing cars remains sound.

However, in order to reduce pressures on motorists during the current economic downturn, the Government recognises that it is no longer appropriate to take forward the major changes to taxes announced at Budget in April 2009. Therefore, in the Pre-Budget Report 2008, the Government announced that there will be no significant rate changes in CO2-based VED until 2010. As a result of this announcement:

  • in 2009, no driver will pay more than £5 extra in 2009;
  • in 2010, no driver will pay more than £30 extra, and many in the lower bands will see a £30 tax cut. A majority of drivers will pay the same or less than in 2009.

The Pre-Budget Report also confirmed the introduction of differential first-year rates of VED in 2010, to strengthen the signal to consumers at the point of purchase that they can save money by buying a lower emitting new car.

2. We are not aware of any hard evidence about the numbers of those affected by a doubling of VED rates who are on lower incomes. We recommend the Treasury publish a detailed analysis of the financial effects of VED on different income distributions so that the impact of any future changes to VED can be more easily understood. (Paragraphs 20, 22)

In 1997, there was only one VED band, meaning that all car owners were taxed the same amount, regardless of the type of car that they drove. By introducing and then reforming graduated VED since 2001, the Government has made the system less regressive, as well as ensuring that the most polluting cars pay more than the least polluting.

The Government does not possess comprehensive evidence linking specific levels of household income to the VED rate, in the way that is available for other taxes. However, National Travel Survey (NTS) data strongly suggests that low-income households are likely to be either unaffected by, or benefit from VED changes, whereas high-income households are more likely to face tax increases. The Pre-Budget Report announced that these tax increases will be a maximum of £30 in any one year.


The data in this table confirms that low-income households are less likely to own a car. Indeed over half of the households in the bottom income quintile do not own a car at all.

Furthermore, low-income households—if they do own cars—are more likely to own cars registered before 2001 than high-income households. Around one third of the total UK car fleet is made up of pre-2001 cars, and these are not subject to the CO2-based VED regime, as there is no consistent information available in relation to their CO2 emissions. NTS data shows that over 30 per cent of cars owned by households in the lowest income quintile are over 10 years old, compared with only 15 per cent of cars owned by households in the highest income quintile.

The Pre-Budget Report announced a £5 increase in both the lower and higher rates for pre-2001 cars, in line with the changes announced to main VED rates. It also announced that in 2010, the higher rate will increase by £15 and the lower rate will be frozen. As a result of these changes, none of these cars will pay more in real terms in 2010, than in 1997.

Of cars that have been registered after 2001 and are therefore subject to the CO2-based VED regime, NTS data also suggests that low-income households are generally more likely to own cars in the lower VED bands, and high-income households are more likely to own cars in the higher VED bands. Over 60 per cent of cars owned by households in the lowest income quintile are in the current bands B to D. The data in Table 2 confirms that the overall correlation between car cost and VED band is extremely strong: in general, cars in higher VED bands are likely to cost more.

Table 2: Average cost of new cars within VED bands, from data provided by JATO Dynamics, 2007
2008-9 bandSales-weighted average car price[1] in 2007
Band B£11,000
Band C£12,000
Band D£16,000
Band E£18,000
Band F£24,000
Band G£42,000

3. We welcome the fact that those on higher rate disability benefit are exempt from paying VED, and can have their cars paid for them through the Motability scheme. However, we are concerned that this will leave many people, who do not qualify for the higher rate disability benefit, still having to pay VED; many of this group may need a larger vehicle to accommodate wheelchairs or medical equipment. We recommend that the Treasury urgently reviews the impacts of VED changes on disabled people and their carers, and takes steps to ensure they are not financially disadvantaged. In particular, we recommend the Treasury considers extending the exemption on paying VED to all recipients of disability benefit. (Paragraph 23)

The Government provides a package of measures that help support disabled people, including benefits, tax credits and other disability-related financial support. Disability Living Allowance (DLA), a main source of direct financial support provided to disabled people, is designed to take into consideration additional living costs and is available to adults and children who need help getting around and/or have care needs because of severe illness or disability. The care component of DLA is available at three rates and the mobility component at two rates—both are awarded according to the level of need. The higher rate mobility component of DLA is targeted on those who are unable or virtually unable to walk.

Those on the higher rate mobility component of DLA and those receiving the War Pensioners Mobility Supplement can claim an exemption from paying VED. As of June 2008, over 1.1 million disabled people were claiming the exemption. An exemption from VED is also available for vehicles in the Disabled Passenger Vehicle taxation class, used by organisations concerned with the care of mentally or physically disabled people. The exemptions are deliberately targeted at those with disabilities that severely impair mobility. To extend the VED exemptions to further groups would include those who are not mobility impaired.

Receipt of the higher rate mobility component of DLA and the War Pensioners Mobility Supplement also confers eligibility to the Motability scheme, which provides help in buying or leasing a car, and associated assistance such as the helping to meet the costs of vehicle adaptations.

The Government also provides other support to disabled people, such as VAT relief. The leasing or hiring of certain equipment and vehicles may qualify for VAT relief, and other goods may also qualify if the item has been designed or adapted solely for a disabled person's use. This includes some medical appliances, certain adjustable beds and hoists and some adapted vehicles.

The local authorities-administered Blue Badge scheme also provides a range of parking benefits for disabled people with severe walking difficulties who travel either as drivers or as passengers. Disabled people are also entitled to a discount of up to a third on rail travel, and concessionary bus fares.

The Government believes its current approach to the provision of assistance to disabled people—including the exemption from VED for the mobility impaired—is the fairest way to go about offering targeted support to those that are in greatest need of it.

4. We recommend that VED bands and carbon emissions should be made clearly visible to prospective buyers of second-hand cars. (Paragraph 27)

The labelling scheme for new cars was launched by the Government in 2005, in conjunction with the Society of Motor Manufacturers and Traders (SMMT) and the Low Carbon Vehicle Partnership (LowCVP). Participation in the scheme by car showrooms has steadily increased, to the extent that 91 per cent of showrooms now use the labels on their vehicles. The labels are designed to provide information—including on overall fuel consumption, VED rates and CO2 emissions—to consumers in as clear, consistent and useful a way as possible, and their introduction was welcomed by the King Review.

The scheme supports the UK's implementation of the EU directive on car labelling, under which manufacturers are required to provide clear information on fuel consumption and CO2 emission figures for new vehicles at the point of sale.

The Department for Transport and the Treasury are actively looking at the current label design in the context of reforms to VED, along with SMMT and LowCVP. This work is being taken forward via the LowCVP Passenger Car Working Group. The Department for Transport is currently working with industry to ensure that any future rollout of the label into the second-hand market is effective and useful for consumers.

5. We support the widening of differentials between VED bands for existing cars. It makes perfect sense to do this for existing cars, not just new cars, given that this is a way of influencing buyers of second-hand cars towards choosing models with lower emissions. This is enormously important, given that three-quarters of all cars bought each year are second-hand. (Paragraph 29)

6. We were disappointed that the Treasury had not modelled what impact the rebanding of existing cars will have on carbon emissions. Presumably this means the Treasury does not have any idea of what levels of VED will either persuade people to trade in their existing cars sooner than they would otherwise, or choose a more efficient model when they next come to buy a second-hand car. This is particularly surprising given the Exchequer Secretary told us the changes to VED in the Budget were primarily made for environmental purposes. We recommend the Treasury urgently carry out and publish research on the impacts that these and other potential changes to VED would make to the second-hand car market, and resultant carbon emissions. (Paragraph 30)

The Government welcomes the Committee's support for increasing the number of VED bands. The number of bands was increased in order to improve the financial incentive on motorists to purchase the cleanest vehicles within their preferred class of car. Under the current bands, around 30 per cent of cars in graduated VED fall into just one band, current Band C, which under these reforms will be split into three separate bands, allowing customers to make a financial gain of £30 in 2010 by shifting to a more fuel-efficient version of their preferred car, where previously they might have paid the same VED rate.

The Government has modelled as much of the carbon impact of the Budget 2008 changes as is possible given the data available at this point in time. This modelling by HM Revenue and Customs was based upon the results of an econometric study undertaken during 2007 and published in January 2008 by Economics for the Environment Consultancy (EFTEC). Using a large and uniquely detailed data set recording new car purchase decisions of households in the UK, the study analysed how different attributes of a car (including physical appearance, motoring capabilities and purchase and running costs) determine households' new car purchasing decisions.

As the Committee heard in its evidence session, this study only covered impacts in the new car market, and purchases by individuals, rather than companies. It is therefore likely that the actual carbon savings could be different. It is also likely that the level of publicity that these reforms have received will have contributed to far greater consumer awareness about the benefits of choosing a lower-emitting car, with concomitant impact on carbon savings.

However, the Government takes the view that, given the immediate need to reduce greenhouse gas emissions in order to meet environmental objectives, it would have been wrong to wait until further studies are complete before taking forward the restructuring of VED.

7. We recommend that the Treasury urgently reviews and consults on how lower income households could be economically supported to trade in their cars for low emission replacements. In particular, we recommend that the Treasury urgently examines the proposal for a "car scrappage scheme", which would provide payments in return for taking high emission cars off the road. In any scheme that were implemented, it would be important to ensure that high emission vehicles were genuinely scrapped—with as much of their materials recycled as possible—rather than allowed to stay on the road under different ownership, for instance in another country. (Paragraph 38)

The Treasury is aware of the French bonus-malus scheme that rewards motorists for trading in their older, more polluting cars for less polluting models. However, it is too soon to be able to tell whether it has been effective in incentivising the purchase of more fuel-efficient cars. The Government has made no commitment to legislate for a similar scheme to be introduced in the UK. Nevertheless, the Government will monitor the results of the French scheme, and other similar schemes, closely.

The Government agrees with the Committee that, with any scheme, it would be imperative to get the structure right, to ensure it was successful in helping to reduce overall emissions. For example, it would be necessary to avoid paying incentives to motorists who were already planning on scrapping their vehicles, creating a deadweight loss.

8. We recommend the Treasury looks again at what more it could do to ensure that the first-year VED rates are prominently displayed before and at point of sale, and not simply incorporated into an "on the road" price. (Paragraph 43)

9. The Treasury must address concerns that the new system of VED will make the efficiency labelling of cars too complicated to impact on the public in practice. We recommend it undertakes research and develops guidance and publicity to inform traders and consumers. (Paragraph 45)

Although some showrooms may present customers with an on the road price that does not include the cost of VED, it should still be clear to buyers what the first-year rate of a vehicle is. In advance of purchase, vehicle buyers are able to look at the VED band and corresponding rate for a particular vehicle on its colour-coded fuel efficiency label, which, as mentioned above, 91 per cent of showrooms are currently displaying. In many showrooms, the exact amount of VED payable will also be included in the paperwork accompanying the car as part of the on the road price.

As was set out above, the Treasury is working with the Low Carbon Vehicle Partnership and other government departments in looking at the current fuel efficiency label design in the context of reforms to VED, to ensure that the labels continue to provide clear and consistent information. This work will of course take into account the introduction of first year rates.

Vehicle buyers are also able to find out about the emissions level and VED rate for particular vehicles using the Vehicle Certification Agency's car fuel data website, which identifies the VED on individual vehicles based on their emissions.

Of course, it may also be in car dealers' interests to make sure that the customer is aware of the amount of first-year rate that applies to a new car. If the first-year rate is low, this will of course be an additional selling point to make to customers. Indeed, results from a survey undertaken by LowCVP indicate that dealers are increasingly likely to refer to the fuel economy label when discussing vehicle options with car buyers. LowCVP found that over 75 per cent of dealers surveyed made use of the label in conversations with customers, while 61 per cent of dealerships made reference to the financial savings illustrated by the label.

10. We recommend the Treasury commission research on the impacts, on purchasing decisions and carbon emissions, of implementing a range of different first-year rates of VED. (Paragraph 47)

11. Unlike other forms of transport, such as aviation, very significant cuts in emissions from cars could be made extremely rapidly, if prospective buyers could be persuaded consistently to choose the most efficient models in each class that are already on the market. That the Government could achieve this without stopping people driving, merely directing their choice of vehicle to the most efficient available, provides a strong argument for market intervention—larger differentials and bigger incentives—that could be robustly conveyed to the public. (Paragraph 48)

12. At the same time, to develop the market for very low emissions cars, we further recommend that the Treasury examine the merits of some kind of "feebate" system, similar to the "bonus/malus" scheme in France, in which levies on high emission cars are accompanied by subsidies on low emission cars. (Paragraph 49)

The Government welcomes the Committee's support for the introduction of differential first-year rates of VED, and the support for the direction of travel taken in VED reform as a whole.

In shaping VED policy, the Treasury models a variety of different possible structures, to assess their impact on business, as well as on income groups, carbon emissions and Government revenues.

When considering proposals for further increases to the differentials between VED bands, it is important to take into account all relevant economic, social and environmental factors, including proportionality and fairness to motorists, and transparency and consistency of signals to motorists and manufacturers. Setting VED rates at levels significantly beyond those announced in Budget 2008, as desired by the Committee, could have disproportionate effects on certain groups of motorists and manufacturers.

The Government believes the differential first-year rates announced at Budget and confirmed in the Pre Budget Report will act as a strong signal to encourage consumers to pick the most environmentally friendly new car in their preferred class. Motorists do not necessarily need to buy a car in a different class of vehicle altogether—for example by switching from a large Multi Person Vehicle to a smaller supermini—in order to take advantage of the lower rates on cleaner cars. Large savings can be made by choosing the vehicle that is environmentally best in the motorist's preferred class, such as the lowest CO2-emitting Multi Person Vehicle within that class, or by choosing the lowest CO2-emitting version of a particular model of car.

For example, the lowest emitting version of the Ford Focus currently on the market will fall into the new band C in 2009, while the highest emitting version will fall into new band K. From 2010, motorists buying a brand new car who choose the former version would pay no VED in the first year in 2010, while those choosing the latter would pay £550 of VED in the first year. Similar differentials in the emission levels between different versions of car models exist among other vehicles.

As the Exchequer Secretary pointed out in evidence to the Committee, the Government believes that the right approach is to make gradual changes to the structure of VED rates and thresholds. This will allow motorists to get used to the recent changes, and for the Government to be able to assess the change in purchasing behaviour that takes place as a result of the reforms. The Government keeps all taxes under review, and maintains the option to alter the VED structure further in the future in order to meet its environmental objectives.

13. The Treasury should have taken greater care to explain that the new VED bands would apply to all vehicles registered on or after March 1 2001. If the point of green taxes is to change behaviour, they need to be properly publicised, so that people are fully aware of what they are being encouraged to do. A failure to advertise green tax details to the public, or explain them in a timely manner to Parliament, breeds suspicion about their objectives, increasing the perception of them as revenue raising measures with no environmental purpose. (Paragraph 52)

14. We recommend that the Treasury pays far more attention to communicating the details and objectives of VED—and other environmental taxes—in the future. (Paragraph 55)

The Government's announcement of Budget 2008 was made in line with past practice: the reforms were set out in the environment chapter of the Red Book with accompanying rates tables in Annex A of the report. Rates were also set out in the Budget 2008 press notice. There has been no shortage of publicity surrounding the VED reforms announced at Budget 2008 and it is likely that the level of public awareness around car purchasing choices has increased as a result.

In light of the high level of public interest in these reforms, however, at the Pre-Budget Report the Government has taken steps to ensure that the public are able to access easily information about VED rates for the next two years. This includes through:

  • information in the Budget document and press notices, available on the Treasury website;[2]
  • information on the specific details of reform to VED, also available on the Treasury website;[3]
  • a Frequently Asked Questions page specific to the VED reforms on the motoring section of Directgov,[4] which will help the public to understand which VED rate their car will be subject to. A link to this is also provided on DVLA's homepage; or
  • contacting DVLA or the Treasury directly.

15. We would further observe that if changes to VED were introduced on a revenue-neutral basis, with reductions for low emissions cars matching in value the revenue raised from increased rates for high emissions vehicles, the policy would be both more acceptable to the public and could unequivocally be communicated as green taxation. (Paragraph 56)

Road tax was first introduced in 1910 and has been used principally as a revenue raising tax since that time. In March 2001, the Government made the decision to charge it on a CO2 basis for the first time—making the UK the first member state in the EU to do so. This change was made so that, in addition to raising revenue for the Exchequer, VED would also play a role in incentivising the purchase and manufacture of lower-carbon vehicles.

The Government does therefore not see VED principally as an environmental tax, in the same sense as, for example, the Climate Change Levy, which was set up purely with environmental purposes; however, it is a tax that is charged on an environmental basis.

That said, the impetus for the Budget 2008 reforms was an environmental one: as the Exchequer Secretary said in her evidence, had the Government simply aimed to raise revenue from VED, there are considerably more straightforward ways of doing so. The decision at Pre-Budget Report to maintain the creation of new bands, underlines this commitment.

The case for increasing the number of VED bands is, as set out above, one that has been widely supported, including by SMMT. However, in order for VED to be effective, it is necessary not only for the number of rates to increase, but for differentials between the rates to be clear. To achieve this, it remains necessary to raise some rates, and decrease others.

16. We are surprised that the Treasury has risked provoking such political opposition for an environmental measure which, according its own projections, is of limited benefit. We recommend the Treasury consults on and examines the case for a much more ambitious reform of VED. While this might provoke more opposition from those wanting to buy or already owning higher emissions vehicles, it might also provide the opportunity for a more positive presentation, based on higher carbon savings and bigger tax discounts for low emissions vehicles. (Paragraph 63)

As set out above, the Government believes the right approach is to introduce gradual changes to VED rates and thresholds. In shaping VED policy, the Government scrutinises a range of options for reforms to rates and thresholds, taking into account the effects of each on a variety of factors. As with all tax policy, tax rates policy will continue to be made in the Pre-Budget Report and Budget.

17. Complementing the use of VED to shift the market towards more efficient cars, the Government should do much more to accelerate the development of new vehicle technology (such as hybrids and fully electric cars); improve public transport nationally; and encourage the growth of car-sharing clubs and schemes, especially for groups that are particularly car-dependent, such as the elderly, disabled, large families, and those in rural areas. (Paragraph 65)

The Government is working hard to improve the sustainability of transport in the UK. As the Exchequer Secretary mentioned in her evidence to the Committee, the reforms to VED are part of a package aimed at reducing greenhouse gas emissions in the UK. As part of this package, Budget 2008 announced a £40 million investment in Research and Development, to encourage the development of low carbon vehicle concepts. This investment has subsequently been increased to £100m, with contributions from One North East and Advantage West Midlands.

The Government also announced in October that, as part of this £100m programme, motor manufacturers will be invited to bid for the opportunity to participate in a £10 million project to run electric car and ultra low carbon vehicle demonstration projects. The Government has also launched new competitions dedicated to UK research into improving technology that could make electric and other green cars more practical and affordable.

Furthermore, the Government is calling on the European Investment Bank to double its financial support for the next generation of greener cars by making available €8 billion over the next two years. This support should target significant carbon dioxide reductions through research, development and innovation expenditure, as well as improving the energy efficiency of related infrastructure and production. The funds should be made available quickly on a fair, equitable and commercial basis across all Member States.

In addition to VED, the tax framework also provides other incentives for the development, purchase and use of low carbon fuel-efficient vehicles. Company car tax was reformed in 2002 and is now based on CO2 emissions to encourage employers and employees to choose less polluting vehicles. Fuel duty rewards those driving fuel-efficient vehicles with reduced running costs. The Government also provides tax incentives for purely electric vehicles, including: an exemption from VED, a reduction in the percentage used for the calculation of company car tax and the provision of enhanced capital allowances for companies purchasing electric and low carbon cars. Electric vehicles also pay no fuel duty.

Over the last decade, there has been a significant increase in investment in transport in the UK—by over 70% in real terms. This investment has contributed to, for example, the construction of the UK's first high-speed rail link—the Channel Tunnel Rail Link—and the upgrading of the West Coast Main Line. In addition, since April 2008, free off-peak bus travel for older and eligible disabled people has been extended nationally.

Additionally, the Department for Transport encourages local authorities to include car-based initiatives such as car clubs and car sharing schemes as part of their local transport strategies. Car sharing is being specifically promoted by the DfT as part of its ACT on CO2 campaign. The Department has also set up Cycling England in 2005, to develop cycling programmes. The scheme's budget is being increased to £20 million in the current financial year, and to £60 million in the two following years. Increased investment such as this, coupled with reforms to delivery, has ensured significant improvements in the performance of the transport network.

18. We strongly support the Treasury's use of VED as an environmental tax, and we welcome the changes announced in the Budget. However we are seriously concerned that even the projected differentials between VED bands remain too small to be effective and, in consequence, the projected carbon savings are far less than they could be. We also believe that both the proposed changes in VED rates and the objectives of VED as an environmental tax, have been poorly explained and communicated. (Paragraph 66)

19. We recommend the Treasury looks again at hypothecating VED revenues to areas such as public transport and subsidies for car clubs or electric vehicles. Alternatively VED changes could always be made on a revenue neutral basis with cuts in the rates levied on low emission cars to match the increases on high emission models. This might increase both the environmental benefits of VED changes and the level of public support for them. (Paragraph 69)

The Government welcomes the Committee's support for the use of VED in providing environmental signals.

However, the Government does not hypothecate taxes, and it remains the case that the Government's spending priorities are not, in general, determined by the way in which the money is raised. As the Committee noted in its report on the Pre Budget Report 2007 and Comprehensive Spending Review, hypothecation of tax revenues for particular purposes can reduce flexibility in managing public finances.

It is true that VED does have a double benefit in that it provides finances for the public services, as well as encouraging the take-up of low emission vehicles. However, it makes sense that, when raising revenue to fund public services, the Government should target those revenue sources that will help shift the burden of taxation from goods to bads. The polluter-pays philosophy inherent in the VED system is central to that principle.

HM Treasury

December 2008



1   The average price is the volumes-weighted average of the retail price, excluding delivery but including all other taxes and charges (VAT, First Registration Fee and VED). Back

2   www.hm-treasury.gov.uk/prebud_pbr08_index.htm Back

3   http://www.hm-treasury.gov.uk/vehicle_excise_duty.htm Back

4   http://www.direct.gov.uk/en/Motoring/OwningAVehicle/HowToTaxYourVehicle/DG_172916 Back


 
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