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ICCT comments on the proposed 2021-2025 fuel consumption limits and fuel
consumption evaluation methods and targets for passenger cars
Zifei Yang, Hongyang Cui

On Jan 24, 2019, the Ministry of Industry and Information Technology (MIIT) released
for public comment the proposed China 2025 Phase 5 fuel consumption standards (GB
19578) and fuel consumption evaluation methods and targets for (GB 27999) for
passenger cars1. The International Council on Clean Transportation (ICCT) welcomes
the opportunity to provide comments on the proposed regulatory documents.

In the proposed standards, the average fuel consumption of new passenger cars is to
be reduced to 4 l/100km under the New European Driving Cycle (NEDC) in 2025. Below
are some highlights of the proposed regulation:

➢ As in previous phases, the proposal has two sets of standards: a per-vehicle

standard and corporate average fuel consumption (CAFC) standard. The per-
vehicle standard sets caps for individual vehicles with different vehicle weights.
The CAFC standard is more stringent than the per-vehicle standard.

➢ The per-vehicle standards apply to gasoline, diesel, dual-use fuel, and dual-fuel
M1 vehicles (passenger cars with a maximum of 9 seats). The CAFC standards
apply to both conventional vehicles and all vehicles with alternative fuels, such as
electric, compressed natural gas (CNG), liquified natural gas (LNG), liquefied
petroleum gas (LPG), and methanol.

➢ Both the CAFC and per-vehicle standards are based on vehicle weights, but the
limits are based on a linear curve as opposed to classified in bin categories.

➢ Compliance with the standards will be measured using the Worldwide

Harmonised Light Vehicle Test Procedure (WLTP) test cycle beginning in 2021.
Since the previous fuel consumption limits and targets of 4L/100km in 2025 were
all based on NEDC, the proposal makes adjustments of 13.34% to 16.64%
depending on vehicle weight bins to convert the fuel consumption baseline from
NEDC to WLTP based on data from China 6 testing2.

1
Available at http://www.miit.gov.cn/n1146295/n1652858/n1653100/n3767755/c6616494/content.html
2
According to the technical supporting document, these adjustments include technology-specific
adjustments of 1% more for vehicles with turbo engine, 3% more for vehicle with GPF, and 0.02 L/100km
more for PHEV. The proposal does not specify how these technology-specific adjustments are used in
the baseline conversion.

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➢ As in previous standards, the proposal sets different fuel consumption limits for
regular and special vehicles, e.g. vehicles with automatic transmissions and 3
rows of seat. The latter vehicle type is subject to more lenient limits (Figure 1).

Figure 1 Proposed China 2025 fuel consumption standards

➢ Off-cycle technologies will be awarded some off-cycle credits, but the credit
details and accounting rules will be specified in a separate document.

➢ The fuel consumption of battery-electric vehicles (BEVs) and fuel cell electric
vehicles (FCEVs) are counted as zero when calculating fleetwide emissions.
Super credit multipliers will continue applied for BEVs, FCEVs, and plug-in hybrid
electric vehicles (PHEVs), but will decrease from 2 in 2020/2021 to 1 in 2025
(Table 1).

Table 1 Super credit multipliers of electric vehicles and efficient vehicles

BEVs/PHEVs/FCEVs Vehicle with FE<=3.2L/100km

(WLTP)
2021 2.0 1.4
2022 1.8 1.3
2023 1.6 1.2
2024 1.3 1.1
2025 1.0 1.0

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Strengthening fuel consumption standards in order to achieve 4 l/100km under NEDC

by 2025 is critical for pushing advanced efficiency technology into the market and
reducing fuel consumption in the transportation sector. It is also an essential strategy to
spur the uptake of new energy vehicles (NEVs) as a way to comply with stringent fuel
consumption standards. We especially support the following approaches in the
proposed standards:

➢ Extend the per-vehicle standards applied to vehicles categorized as M1 with

gross weight less than 3500kg to all M1 vehicles. In addition, expand the fleet-
average standards to methanol vehicles and those which run on alternative fuels
that are already covered by Phase 4 standards.

➢ The standard categories will switch from bin classification to a linear curve with
minimum and maximum limits for both per-vehicle standards and fleet-average
standards. This will assure continuous incentives to reduce fuel consumption
across the fleet.

➢ The standard sets flat limits for very heavy vehicles. This design ensures the
heaviest vehicles are subject to a more stringent standard, therefore encouraging
the advancement of fuel efficiency technologies in larger vehicles and helping to
reverse the fleet-wide trend toward heavier vehicles. However, the minimum
vehicle weight subject to the flat limit could be further reduced.

We are concerned about the limitation of the proposed standards in promoting efficiency
technologies and new energy vehicles in China and see great potential to improve the
standard design. Below are highlights of our suggestions:

➢ Eliminate the lenient standards for special vehicles (automatic transmission or 3

rows of seats), as this weakens the standard’s effectiveness by encouraging the
manufacturing of vehicles subject to less stringent standards. In addition, these
vehicles should not technically be granted compliance credits.

➢ Reconsider the baseline adjustment when converting from NEDC to WLTP and
eliminate unnecessary elements that significantly weaken the standards. The
existing conversion method takes into account a variety of elements that should
not be included in the test cycle conversion. For example, there is no engineering
justification for different adjustments for turbocharger and GPF engines. The
results also contradict findings from other sources and countries.

➢ Strengthen the per-vehicle maximum target to match improved NEDC-WLTP

conversion factors. The conversion factors used for the proposed standards
significantly diminish the baseline fuel consumption under WLTP, which makes
2025 per-vehicle maximum target more lenient than pre-2021 standards.

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➢ Set the CAFC target at 4 l/100km for only conventional vehicles. The proposed
standards will only require conventional vehicles to achieve 5 l/100km on
average, which will result in minimal technology improvement. The 4 l/100km
fleet average target can be met without NEVs and with much less cost than
stated in the standards.

➢ Use lifecycle fuel consumption (FC)-equivalent accounting for NEVs and remove
the NEV super credits starting in 2021 to maximize social benefit of the
standards. The zero-emission accounting method for NEVs and the NEV super
credit together erode 69% of the expected fuel consumption saving and CO2
emission reductions of this standard.

➢ Switch to size-based standards and reduce the maximum fuel consumption limit
to 2280 kg in order slow down the trend towards heavier and larger vehicles.

➢ Design the off-cycle credit program to reflect actual in-use reductions and be
transparent with clear constraints to enhance its credibility. An A/C test cycle
should be developed to take account of fuel consumption of air conditioner and
thermal load-reducing technologies.

➢ Strengthen compliance through cooperation with the Ministry of Ecology and

Environment (MEE). The representative vehicle should accurately reflect what is
in production and in-use testing should be required. MIIT can pre-screen type
approvals based on emission standard compliance and share CO2 type approval
data with MEE, who will verify in-use performance during vehicle emission tests.

Detailed explanations of the suggestions above:

➢ Eliminate the lenient standards for special vehicles (Automatic transmission
or 3 rows of seats).
o Even if the existing market shows fuel consumption differences between the
regular vehicle and special vehicles, it is not appropriate for standards to pick
winners and losers. This weakens the overall standard stringency by
encouraging vehicles built to less stringent standards.
o Modern automatic transmissions, such as CVT, DCT, and 8+ speed automatics,
are more efficient than manual transmissions. Thus, the standards are applying
less stringent limits to more efficient vehicles when the market penetration of
automatic transmissions are expected to increase significantly in the future
(Figure 2).

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Figure 2 Historic and projected penetration of different transmission technologies3

o Vehicles with three rows of seats or more are heavier and thus already subject to
a curb weight adjustment. Adding a special adjustment results in double-counting
the adjustment. The increased uptake of automatic transmissions and
SUVs/MPVs illustrated in Figure 2 and Figure 3 show an increasing number of
vehicles are taking advantage of the lenient standards.

Figure 3 Market penetration of vehicle by vehicle type

➢ Reconsider the adjustment to baseline converting from NEDC to WLTP and

eliminate unnecessary elements that weaken the standards.
o The standards apply a 13.34% to 16.46% adjustment when converting the fuel
consumption baseline from NEDC to WLTP. This is far larger than the gap found
in other studies. The MEE-Vehicle Emission Control Center (VECC) found an
average gap of 10% between WLTP and NEDC through the testing of two cars.
Specifically, they found a 16% gap for a lighter car and a 4% for a heavier car.

3
Fuel-efficiency technology trend assessment for LDVs in China: Transmission technology. Available at
https://www.theicct.org/publications/fuel-efficiency-tech-china-transmission

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An ICCT study of the EU vehicle fleet4 suggests an adjustment of 5.7% to 7.7%

is appropriate when switching from NEDC to WLTP. A study conducted by Joint
Research Center (JRC) of the European Commission identified an adjustment of
10.5% taking into consideration different advanced technologies5.
o An ICCT study6 found that most differences in fuel consumption of China
vehicles comes from change of road load from NEDC to WLTP (Figure 4). Even
though the original intention of the NEDC is identical to WLTP, NEDC is
imprecise in defining parameter in road load compared to WLTP, which allows for
modifications of a vehicle that is used for coast-down testing. The road load
factors used for testing to set the standard were reported by manufacturers from
their own coast-down testing. We have found evidence that the NEDC road load
reported by manufacturers is generally significantly lower than road load tested
by other independent entities. The lower road load would reduce fuel
consumption under NEDC testing, therefore enlarge the difference in fuel
consumption between NEDC and WLTP. The vehicle adjustment for road load
testing completed by manufacturers does not reflect real-world driving of normal
production vehicles and was never intended to be allowed by the regulators. So,
the impact of change in road load, estimated to be 8%to 16% in ICCT sample
testing, should not be included in the NEDC-WLTP conversion factors.
250

A/C
Road load & 9%-12%
200 vehicle mass Driving cycle
8%-16% 3%

150
g/km CO2

NEDC
100
160 g/km
WLTP driving procedure Off-cycle
impact

50

0
NEDC WLTP road load Driving cycle A/C

Figure 4 Graphical illustration of estimated CO2 emissions impact from switching from NEDC to WLTP and turning on
A/C

o The baseline adjustment conversion used in the conversion from NEDC to WLTP
in the standard document is far different from the conversion factors established

4
The WLTP: How a new test procedure for cars will affect fuel consumption values in the EU. Available at
https://www.theicct.org/publications/wltp-how-new-test-procedure-cars-will-affect-fuel-consumption-
values-eu
5
A simulation-based methodology for quantifying European passenger car fleet CO2 emissions. Available
at https://www.sciencedirect.com/science/article/pii/S0306261917304336
6
Evaluation of real-world fuel consumption of light-duty vehicles in China. Available at
https://www.theicct.org/publications/real_world_fuel_consumption_ldv_China.

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by ICCT in 20177, particularly for heavier vehicles. ICCT’s conversion factors are
generated by simulating a large number of existing and advanced vehicles,
including hybrid vehicles and those with advanced fuel-efficiency technology,
with the Data Visualization Tool (DVT). This simulation tool used in the
development of the U.S. fuel economy standards and the generation of EU CO2
cost-benefit curves. Contradicting the supporting evidence for the standards,
ICCT’s conversion factors shows that the gap between WLTP and NEDC
decreases as fuel consumption goes up, and the gap closes when the fuel
consumption reach at 12 l/100km (Figure 5). The reversal of the gap occurs even
earlier in the JRC study– the WLTP CO2 emission are lower compared to those
of NEDC at approximately 250 gCO2/km (10.7 l/100km).

Figure 5 Relationship between NEDC and WLTP with ICCT conversion factors

o We suggest using the same adjustment for all vehicle weights. The coefficient of
determination of WLTP/NEDC correlations by curb weight are just 0.63 and
0.66. This is too weak to justify the different adjustments by curb weight. The
European JRC study shows opposite results; that the WLTP/NEDC ratio
decreases with the increase of mass, capacity, and power.
o We suggest using the same adjustment for the technologies listed in the
supporting document. There is no engineering reason why turbo engines should
have a different adjustment than naturally aspirated engines, or why an
adjustment should be used for vehicles with gasoline particulate filters (GPF). A
number of studies have found that the use of coated GPFs has minimal impact
on fuel consumption during both the NEDC and WLTP test cycles8.

7
Development of test cycle conversion factors among worldwide light-duty vehicle CO2 emission
standards. Available at https://www.theicct.org/publications/development-test-cycle-conversion-factors-
among-worldwide-light-duty-vehicle-co2.
8
Gasoline particulate filters- A review. Available at
https://www.researchgate.net/publication/328747326_Gasoline_Particulate_Filters-a_Review

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o Base on ICCT conversion, the 2021 CAFC phase standards (light blue lines) are
even more lenient than 2020 Phase 4 CAFC standards (green lines). This is due
to the conversion method in the proposed standards (Figure 6).

Figure 6 China Phase 5 fuel consumption standards compared with previous standards using different conversion
factors

➢ Strengthen per-vehicle max target to match with the improved NEDC-WLTP

conversion factors (close to ICCT conversion factors)
o As Figure 6 shows, the linear Phase 5 maximum standards (yellow lines) for
individual vehicles are similar to bin-steps in the Phase 4 maximum standards
under WLTP (orange lines). However, ICCT’s conversion of Phase 4 maximum
standards to WLTP (pink lines) shows much more stringent baseline. The
conversion factors used for the standards significantly diminish the baseline fuel
consumption under WLTP, which makes the per-vehicle maximum target more
lenient than pre-2021 standards. We suggest reducing Phase 5 maximum targets
to match the improved NEDC-WLTP conversion factors, ideally close to the ICCT
conversion factors. That said, the targets should be reduced by at least 0.5% for
lighter vehicles and 14% for heavier vehicles.

➢ Set CAFC target at 4 l/100km for only conventional vehicles

o Fleet-wise, conventional internal combustion engine vehicles can achieve lower
fuel consumption levels with lower costs. The 4.0 l/100km fleet-average target
can be met without NEVs. The cost to achieve the standards should be much
less. According to ICCT and U.S. EPA estimations, complying with the U.S. 2025
standards compared with the 2021 standards, or a reduction of 5.1 l/100km to
4.2 l/100km under NEDC, would cost $551-$8759 per vehicle, or 3,703-5,880
RMB10. According to ICCT’s estimate of compliance cost in Europe, reducing the
fleet average from 5 l/100km to 4 l/100km under NEDC would cost approximately

9
The ICCT estimation is $551 and the US. EPA estimation is $875. See
https://www.theicct.org/publications/US-2030-technology-cost-assessment
10
U.S. dollar to RMB exchange rate = 6.72

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€150 - €75011 per vehicle, or 1143-5715 RMB12, assuming no penetration of

NEVs. Both estimations are far less than the 17,000 RMB stated in the
supporting document.
o As shown in the Figure 7, by allowing zero-emission accounting of NEVs,
conventional vehicles will only be required to achieve 5 l/100km on average. This
reduction could be less depending on the consideration of super-credits for
super-efficient vehicles, off-cycle credits, and the trading of excess credits from
NEV mandates. The 5 l/100km target is 25% higher than the fleet target of 4
l/100km, which results in no change or, at most, minimal efficiency
improvements. This will significantly slow down the efficiency technology
advancement in conventional vehicles. Thus, a fleet-average target of 4 l/100km
under NEDC should be set only for conventional vehicles in order to encourage
technology improvement in the entire fleet. An alternative is to remove super-
credits and NEV accounting.
6.5

6 5.8
l/100km Standard proposal (0 upstream + super credits)

5.5
NEDC L/100KM

5.0
l/100km
Suggest standards (Upstream, no super credits)
5

4.5 4.2
l/100km
PV fuel consumption goals

4 Allowable conventional PV fuel consumption

Allowable conventional PV fuel consumption (0 upstream)
4 l/100km
Allowable conventional PV fuel consumption (super credits)
Allowable conventional PV fuel consumption (0 upstream+super credits)
3.5
2021 2022 2023 2024 2025

Figure 7 Comparison of fuel consumption requirement for conventional vehicles between proposed standards and
ICCT suggested accounting method (excluding impact from efficient vehicle multiplier and off-cycle credit program)

➢ Use lifecycle FC equivalent accounting method for NEVs and remove NEV
super credits from 2021 to maximize social benefit of the standards.
o The use of super credits and zero-emission accounting is intended to stimulate
EV uptake at their early development stage. And the compromise is the erosion
of conventional vehicle fuel consumption performance. When the EV market is
small, such erosion effect or environmental loss is minimal. However, as the EV
market grows, that impact can be increasingly significant. An ICCT study showed

11
The upper and lower cost bound has different assumptions on various elements. See
https://www.theicct.org/publications/2020-2030-co2-standards-eu-cars-lcvs-20171026
12
Euro to RMB exchange rate = 7.62

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that in U.S. and Europe, once the EV market is above 5% of all new PV
production, the environmental benefit erosion effect begins to show its
significance. The study estimated that if the NEV market share is above 20%, the
CO2 reduction benefit loss can be as high as 20%+ in the U.S. and roughly 30%
in Europe13. In China, with multiple NEV incentive policies in place, we project
NEVs will reach approximately a 5% market share in 2020, which is close to the
threshold of triggering significant CO2 reduction losses based on the U.S. and EU
analysis. We conducted a similar analysis to the Chinese market and had
following findings:
▪ Applying a zero-accounting method and super credits for NEVs, the actual
fleet average fuel consumption will only need to meet 4.6 l/100km in order to
achieve 4 l/100km in 2025. From 2021 to 2025, the standards are relaxed by
16-18%.
▪ Although the NEV super credit will be reduced to 1 by 2025, in the preceding 5
years it will cause 4.3 billion liters more fuel to be consumed and 10.3 million
tons more CO2 emissions. Together with zero-emission counting method, the
mechanism will increase fuel consumption by 11.9 billion liters and CO2
emission by 28.3 million tons. As shown in Figure 8, these two rules together
erode at least 69% of the expected fuel consumption savings and CO2
emission reductions of this standard, which is a significant loss in social
benefits.

Figure 8 Difference between expected and actual fuel saving/CO2 emission reduction (excluding impact from efficient
vehicle multiplier and off-cycle credit program)

o To minimize the erosion of social benefits, we suggest removing NEV super

credits and switching from the zero-accounting method to a lifecycle FC-
equivalent accounting method for NEVs. As shown in the Figure 7, switching to
an upstream accounting method will effectively reduce the targets for
conventional vehicles from 5 l/100km by 2025 to 4.2 l/100km.

➢ Switch to size-based standards and reduce cut-off point for maximum fuel
consumption to 2280 kg to slow down the transition trend to heavier and
larger vehicles.

13
Integrating electric vehicles within U.S. and European efficiency regulations. Available at
https://www.theicct.org/integrating-EVs-vehicle-CO2-regs

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o As the supporting document states, “The Standard Working Group has observed
the change of the average curb weight of China's passenger car since 2012 and
realize that the trend of heavy and large-scale passenger cars in China is
significant in recent years.” We have also observed the same trend and are
concerned it will prevent China from meeting its 2025 fuel average fuel
consumption target (Figure 9). As demonstrated by a number of ICCT studies14,
switching to a size-based target system is a viable and effective solution to help
reverse this trend and it will create a level playing field for all efficiency
technologies, including lightweighting technologies.
1500 0.25

1400 0.2
Fleet average curb weight(kg)

1300 0.15

1200 0.1

Annual increase rate 4.6%

1100 0.05

1.7% 1.6% 2.1%

1.2% 1.2%

1000 0
2010 2011 2012 2013 2014 2015 2016

Figure 9 2010-2016 Fleet average curb weight trend

o We suggest lowering the cut-off point for maximum fuel consumption on the
linear standards– a backstop from upweighting the fleet. Some luxury vehicle
models, such as the Rolls Royce Phantom, which fall into the flat part of the US
rule are not included in the flattened curve in the proposed standards in China.
Additional luxury imported models fall under the cutting point. We suggest
lowering the cut-off point from 2510 kg to 2280 kg, or to the corresponding
footprint level if footprint-based standards are adopted, in order to slow down the
increasing preference to larger and heavier vehicles.

➢ Carefully design the off-cycle credit program

o Off-cycle credits could reduce manufacturers’ cost of compliance in short run.
However, inappropriate off-cycle credits can easily erode the standards. Based

14
See Incentivizing passenger vehicle mass reduction technologies in China. Available at
https://www.theicct.org/publications/incentivizing-passenger-vehicle-mass-reduction-technologies-china;
and Size or Mass? The Technical Rationale for Selecting Size as an Attribute for Vehicle Efficiency
Standards. Available at https://www.theicct.org/publications/size-or-mass-technical-rationale-selecting-
size-attribute-vehicle-efficiency-standards.

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on lessons learned from the U.S. off-cycle credit program15, we highly suggest
MIIT take advantage of the results from the China test cycle project to identify
representative driving behavior and conditions. This can be used for all off-cycle
credits and can help standardize and streamline the approval process. In
addition, we highly recommend the following principles are adhered to when
establishing an effective off-cycle credit program:
▪ Avoid double-counting benefits that also occur on regulatory test cycles.
▪ Be based on robust data showing real, quantifiable, and verifiable energy
savings that are not captured on the test cycles.
▪ Be limited to those technologies whose activation is autonomous and
independent from the driver. Technologies such as gear shift indicators and
tire pressure monitoring systems depend on driver activation therefore should
not be awarded off-cycle credits.
▪ Require real-world energy-saving benefits be independently verified.
▪ Reflect actual in-use reductions, with demonstrable impacts on vehicle
efficiency over the vehicle lifecycle.
▪ Not be required by other laws (e.g., if tire pressure monitoring systems is
mandatory for safety purpose, it should not be given off-cycle credits).
▪ Build a transparent system with clear constraints to enhance off-cycle
program credibility.
o An A/C test cycle could be developed in the next phase of standards in order to
take account of fuel consumption impact from air conditioner and thermal load-
reducing technologies in real driving.

➢ Strengthen compliance through cooperation with the Ministry of Ecology and

Environment (MEE)
o Require vehicle manufacturers to test vehicles produced and ensure the test
vehicle is representative of those actually in production:
▪ The highest-selling vehicle within a model type should be tested.
▪ Additional testing should be performed based on vehicle production, such that
at least 95% of the vehicle configurations are tested for the CAFC
calculations.
▪ The equipment on the test vehicles should be representative of those
produced, such as use of the highest-volume tire available for each vehicle
with an appropriate road load test conducted or analytically derived for that
vehicle/tire combination.
o Set in-use vehicle fuel consumption compliance requirements and require
manufacturers to test in-use vehicles. Given MIIT does not have in-use
compliance authority, we suggest the Ministry share CO2 type-approval data with

15
How will off-cycle credits impact U.S. 2025 efficiency standards? Available at
https://www.theicct.org/publications/US-2025-off-cycle

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MEE and allow MEE to verify in-use performance during vehicle in-use emission
tests.
o Conduct regular confirmatory tests paid by manufacturers. This should include
both fuel consumption tests and road load tests.
o We understand that MIIT authority is limited to controlling the type-approval
process, so MIIT could deny type approval for new models that cannot meet their
specific fuel consumption standards. We suggest MIIT pre-screen type approvals
based on emission standard compliance, so that only vehicles that pass emission
standards are eligible for applying type approval. Moreover, enforcement will be
more effective if the imposed fines are high enough to increase noncompliance
cost.

We would be glad to clarify or elaborate on any points made in the attached comments.
If there are any questions, please feel free to contact Zifei Yang
(zifei.yang@theicct.org).

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