Can a ‘charging mandate’ keep plug-in hybrids alive after 2035?

The German car lobby is pushing an unusual idea to boost sales of plug-in hybrids as the EU seeks to measure their real-life emissions more accurately. The proposal? A legal obligation for plug-in hybrid drivers to charge their cars regularly. The punishment for not abiding by that obligation is reduced power. A creative solution, but does it stand a chance?

The plan is championed by Hildegard Müller, head of the German Association of the Automotive Industry (VDA). It’s a response to the upcoming European Union homologation rule, Euro 6ebis FCM (Fully Conformity Mileage), which is poised to tighten how carbon emissions from plug-in hybrids are calculated.

Larger batteries

Since the beginning of this year, the reference distance for the homologation test for PHEVs is 2,200 kilometers, but it will almost double to 4,260 kilometers under Euro 6ebis FCM as of 2027. Proportionally, the covered zero-emission distance will shrink, thereby raising the average CO2 emissions from PHEVs. Fewer and fewer models will be eligible for tax incentives, as many countries apply a 50 g/km threshold.

During the first adaptation of the EU homologation rules, as of 1 January 2025, plug-in hybrids became equipped with much larger batteries to compensate for the longer distance. Capacities of 20 kWh are no exception these days. But under FCM, sizes will need to grow even further, making PHEVs undoubtedly more expensive than BEVs.

“Targeted encouragement”

Rather than accepting the new homologation rules, the VDA argues for what it calls “targeted encouragement” of electric driving. It’s proposed fix: make charging compulsory. Cars would be built so that after a specific mileage, the driver must recharge the battery or face reduced engine performance. 

In effect, the car would automatically enforce the hybrid’s intended use. The proposal serves as a measure to facilitate continued sales of PHEVs beyond the 2035 deadline, as the EU is under pressure to revise it. 

Exemptions

The political backdrop is tense. It’s the German manufacturers and the government under Chancellor Friedrich Merz that are pushing to soften the 2035 phase-out of petrol and diesel engines. Berlin wants exemptions for plug-in hybrids and range-extender models, arguing that many consumers are still hesitant to buy fully electric cars.

Brussels wants to use real-world data showing how the cars are actually driven, and these surveys aren’t good publicity for PHEVs. For manufacturers, this could turn the supposedly green hybrid into a regulatory liability, and potentially cost billions in emissions penalties.

Privacy concerns

The VDA’s idea has been met with raised eyebrows in Brussels and Berlin alike. Environmental campaigners dismiss it as a desperate attempt to keep plug-in hybrids on the market beyond 2035. Privacy advocates also warn that any system tracking a driver’s charging habits could become a surveillance tool.

Plug-in hybrids have long been marketed as a bridge to fully electric cars. They promise the best of both worlds: short journeys powered by electricity, longer ones by fuel. But their reality is far dirtier. Many owners rarely charge their cars, treating them instead as conventional combustion models with an expensive battery on board.

A recent analysis by Transport & Environment, based on data from the European Environment Agency, found that real-world carbon emissions from plug-in hybrids can be up to five times higher than official figures suggest.

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