Official Report: Minutes of Evidence

The Chairperson (Mrs Erskine): We are joined remotely by Mr Symon Cook, head of the National Franchised Dealers Association (NFDA); Brian Robinson, member of the National Franchised Dealers Association and franchise director of Agnews; and Dave Sheeran, member of the National Franchised Dealers Association and group managing director of the Donnelly Group. Thank you for joining us remotely. We greatly appreciate you joining us on this important issue. We have some of the written evidence that you provided to the Committee. We appreciate that and thank you for it. I ask for a brief opening statement of about five minutes, and then we will go to members' questions.

Mr Symon Cook (National Franchised Dealers Association): Thank you for the opportunity to speak to the Committee and allowing us to present our position paper on the proposed introduction of the zero emission vehicle (ZEV) mandate in Northern Ireland.

As a bit of background about us, the National Franchised Dealers Association represents approximately 3,500 dealer members across the UK and Northern Ireland. Currently, battery electric vehicle (BEV) sales in the UK's new car market are at risk of plateauing. Year-to-date figures show that BEVs currently command a market share of 17·2% in the new car market, which is well below the initial ZEV mandate target of 22% for 2024. An even more pessimistic story is emerging in the van market, in which year-to-date figures indicate that BEVs under 3·5 tonnes hold a market share of only 4·8%, a decrease of 0·5% when compared with the same point last year. Critically, both car and van year-to-date market shares are well below the ZEV mandate targets for this year of 22% and 10% respectively. Rather than paying fines, manufacturers may choose to completely exit the Northern Ireland market, a market that already faces disruption due to chronic MOT backlogs and recent issues with type approval, limiting dealer access to certain stock. That could result in reduced consumer choice, higher vehicle prices and an overall negative impact on Northern Ireland consumers.

NFDA is calling for a critical grace period before the mandate is introduced to ensure that dealers have adequate time to purchase BEV stock to be able to meet the thresholds. If Northern Ireland is to implement a ZEV mandate, NFDA proposes realignment of the targets to better suit Northern Ireland's market. A gentler profile of targets, potentially starting at 18% in 2025 on a more gradual trajectory towards the 100% target in 2035, would give manufacturers and retailers a more reasonable time frame in which to complete the transition to EVs.

In the past month, new EV car registrations in the UK were sitting at a market share of 17·2%. If approved in Northern Ireland without any changes, the ZEV mandate would start with a 28% electric vehicle target for new car sales in 2025 in line with the rest of the UK. Those targets could rise if the UK Government decide to bring the 2035 phase-out date forward to 2030. The minimum ZEV mandate target trajectory for new vans sold begins at 10% in 2024 and reaches 70% in 2030 on the way to 100% in 2035. The van market is struggling to reach even the 10% target for 2024. EV market share for vans has actually decreased compared with last year, with year-to-date figures showing a 5·3% market share in 2023 falling to 4·8% this year so far. The target for 2025 is set at 16%, which seems completely unachievable.

When we look at the original equipment manufacturer (OEM) comparison tracker that we supplied you with in the briefing paper, we see that vehicle manufacturers such as Volkswagen and Ford, which are historically volume brands, are not predicted to hit the 22% target. Several other brands, including Hyundai, Toyota, Nissan, Jaguar Land Rover and Mazda, are still far from reaching that target. Manufacturers who do not meet the required threshold will have to pay penalties of £15,000 per non-compliant car. Similarly, in the van market, manufacturers will have to pay penalties of £9,000 per non-compliant van in 2024, increasing to £18,000 from 2025. If manufacturers are unable to leverage credits, those are hefty penalties, running into the hundreds of millions.

I will move on to the impact on dealers and the economy in Northern Ireland. There is serious concern in the dealer network that the automotive industry in Northern Ireland could collapse. Many manufacturers still do not have a clear EV plan. Some businesses are looking to move to hybrid as a mode of transition. Some have even indicated that, without demand stimulation from government, rather than face strict fines, they will pull out of the UK in order to avoid paying penalties. If that happens, the impact on the UK market could be significant. Established brands withdrawing could result in fewer choices for consumers compared with their European and US counterparts, which could have the knock-on effect of driving up prices for the remaining brands. That is already happening, as some brands have removed popular models, such as the Ford Fiesta, to streamline their inventory.

The situation is even worse in Northern Ireland, where car sales account for approximately only 2% of UK registrations. That is compounded by the fact that international manufacturers still view the UK as a relatively small market, so any attempt to force demand could be seen as excessive and not worth the investment. That would ultimately lead to less choice for the Northern Ireland consumer, which would lead in turn to car prices increasing. Dealers are at the mercy of their OEM partners. NFDA members account for some of the largest companies in the motor trade industry, and automotive retail employs approximately 14,000 people across Northern Ireland. If the ZEV mandate is introduced as proposed, it will have a hugely detrimental impact on the dealer network, employment and thus the wider automotive industry in the Province.

The Chairperson (Mrs Erskine): OK. Thank you for that introduction. We are acting as four jurisdictions moving together on this. Therefore, we are in line with the rest of the UK when we are moving along with this. There was a consultation on the mandate, and car manufacturers overwhelmingly stated their desire that Northern Ireland be included in the mandate. There are no manufacturers that operate independently in Northern Ireland. You talked about targets not being met: have you had any discussions or any indication that the Government will introduce an increase, given that manufacturers are not meeting their targets, as you indicated? Surely it would be strange if the Government were to do that and put pressure on the manufacturers that way.

Mr Cook: There is a target there, and the concern from the manufacturers is that they are not reaching the targets. I do not believe that there is any position that the targets will be changed, but we are going now into the last quarter of the first year of the ZEV mandate, and there are several manufacturers that are way off.

The Chairperson (Mrs Erskine): You said in your briefing paper that manufacturers may choose to exit the NI market: can you point to that in any way?

Mr Cook: I do not know whether my colleagues online can talk about some of the discussions that they have had directly with the manufacturers.

Mr Brian Robinson (National Franchised Dealers Association): Good morning, everyone. Thank you for the invitation to participate. As manufacturers approach the last three months of the year, clearly the targets are very much front of mind. The feeling has been that there are two ways to achieve the target. One is to sell the appropriate number of electric vehicles per se, and the other is to suppress the sale of combustion engine vehicles as a way of achieving the same ratio. As this point, I am not able to say exactly how it will pan out for each manufacturer, but the fear of losing production of internal combustion engine (ICE) vehicles remains a concern. Given that NI has 2% of the overall UK number for vehicle sales, we could easily become a backwater in this situation.

The Chairperson (Mrs Erskine): There is an assertion that the automotive industry in Northern Ireland could collapse. Why are we more vulnerable than the rest of the UK?

Mr Cook: There is also the fact that, potentially, we have concern about GB type approval and manufacturers not being able to get vehicles into the country because of the incorrect type approval for their vehicles. That is another factor that adds to the concern regarding the ZEV mandate.

Mr Stewart: Thanks very much, gentlemen, for coming along today and for your presentation. To follow up on that, is Northern Ireland a less appealing place for someone to purchase an EV car compared with the rest of the United Kingdom? Is that one of the barriers to EV car sales?

Mr Robinson: The current market data shows that the EV share is 17·2% in the UK; in NI, it is 11·9%. On the basis of existing pricing and consumer appetite, we are running at a delta of 5% compared with the overall UK average. The barriers to adoption are vehicle cost; a level of uncertainty around EVs from general press and media comment; charging infrastructure; the delta between home charging cost and public charging cost; and incentives to purchase where, effectively, fleet and business customers have been much quicker to adopt EVs compared with retail or private buyers.

Mr Stewart: OK. Thanks for that, Brian. That is really useful and is what I hear anecdotally. Is there a geographical spread in that as well? I assume that it is more appealing to someone living in a city, compared with the west of the Province. Are you noticing that through your dealerships and among those trying to sell the vehicles?

Mr Robinson: I do not have that level of detail, unfortunately.

Mr Stewart: OK. No problem. It might be something to look into.

I will move on to the gentler profile of targets. Symon, you referred to that, and there is an illustrative example of what that could be. How impactful would that be? Is that something that you propose primarily for Northern Ireland as opposed to the rest of the UK, or would you expect those figures to be rolled out across the United Kingdom?

Mr Cook: No, that would be for Northern Ireland, just to have that gentler trajectory. We cannot expect the Northern Ireland market to react to a 28% 2025 target. That would just be absolutely [Inaudible.]

If we can look at maybe softening that entry-level percentage, that would make a massive difference.

Mr Stewart: You gave an example of the targets. Do you think that they are feasible, or do you think that they will still be challenging but feasible?

Mr Cook: They would still be a struggle. As Brian said, you are still way behind the current UK figures in regard to battery electric vehicle sales. On your initial point about the infrastructure, that will be a key driver in getting people into the vehicles. The main concern from a consumer perspective is where they will charge. It is a twofold concern.

Mr Stewart: I have one last point, Symon. I am not sure who will take this. You referred to the offsetting or the banking that dealerships can do with other jurisdictions and areas. Can you talk me through how that works for the dealerships and how they are able to offset some of the targets?

Mr Cook: Sorry, in regard to what?

Mr Stewart: The ability of dealers or manufacturers to bank or offset some of their targets through sales elsewhere.

Mr Cook: That would be from the manufacturers' perspective. There is an implied target, because a lot of this relates to the CO2 emissions from their hybrid vehicles as well. Although they have the initial ZEV 22% target, there is an implied target that sits behind that with regard to their hybrid sales or their CO2 emission sales of ICE vehicles. They can offset it to a certain percentage, but the concern is that they are not reaching the BEV targets to generate that sort of lesser target for the hybrids.

Mr Stewart: That is useful. Thank you very much.

Mr McReynolds: Thank you, Symon, Brian and Dave, for your presentation. What length of time are you looking for as a grace period? Can you detail some of the negative experiences of your members in Great Britain?

Mr Cook: The grace period could be as long as possible, in theory. Hopefully, we can push it back two or three years to allow the infrastructure in Northern Ireland to be in a position where consumers will adopt. The issue that we have in the UK with particular dealer members is getting the charge point access to the dealerships. There is a serious backlog — potentially an 18-month backlog — just to get the distribution network operator facilities into the dealerships to put some charging infrastructure at ground level. Again, that is a massive concern for our dealers in the UK, and, no doubt, it will be an increasing concern for the Northern Ireland members as well when that comes to fruition.

Mr McReynolds: Yes, 18 months is the figure that I have heard from charge operators. It was raised in the last session with the Minister and the permanent secretary. Have you carried out any assessment of consumer behaviour and consumer understanding over here about their desire for increased numbers of EVs?

Mr Cook: Not yet. That is something that we need to focus on. I do not know whether other members on the call will be able to give us any insight on feedback that they have had from consumers.

Mr Dave Sheeran (National Franchised Dealers Association): The appetite amongst retail consumers is somewhat muted. The share that BEVs take of the retail segment has actually declined year-on-year. In 2023, 6·8% of retail sales in Northern Ireland were electric vehicles, and it is running at 4·5% this year. There is a lot of misinformation and conflicting information in the marketplace about deadlines for switching, the effectiveness or otherwise and the cost of running the vehicles. There is a lot of noise in the system. While there is a level of curiosity about electric vehicles and you get asked, "Should I be thinking about electric?", most of the retail customers with whom we deal are postponing that decision until their next purchase.

Brian picked up on the fact that there is generally a lack of stimulus or incentive in the retail market to buy an electric vehicle, while there is huge stimulus in the fleet market. Part of the problem in Northern Ireland is that the region's fleet market is the smallest in proportion of the total market of all the regions. There is an inbuilt bias to the calculation in Northern Ireland relating to the weighting of the fleet market in the overall UK achievement. That is why you see that 17% penetration being driven by the fleet market. Until there is retail stimulus across the UK or specifically in Northern Ireland, it will be the retail consumer who drives take-up here. Without the stimulus or infrastructure being put in place, it is difficult to see how we can catch up even to the UK average at this point.

Mr Robinson: On Dave's point, whilst the car market in NI has risen by 10% year-on-year, if that is split into the private and fleet markets, we see that the private element is down by 9% and the fleet element is up by 21%. There is a distortion in the two market sectors.

Mr K Buchanan: Gentlemen, thank you for coming along. I am a wee bit unclear. In layman's terms, are you saying that UK electric vehicle sales are at 17%? Is that correct?

Mr Cook: Yes.

Mr Robinson: That is correct.

Mr K Buchanan: That is obviously a combination of the four nations. What is the breakdown of that for the four nations?

Mr Cook: Unfortunately, I do not have that detail, but we can certainly find out for you.

Mr Sheeran: The Northern Ireland content is 11·9%. The other three nations are clearly higher. England has the highest level. I do not have the figures to hand, but I am 99% sure that England is the highest. Part of that is because of the structure of the market, when you balance the relative weightings of fleet, Motability and retail.

Mr K Buchanan: I did not see it; I might have missed it. In your paper, is there a breakdown of the weightings for fleet and private sales across the whole of the UK? We need to see how Northern Ireland is or is not contributing to the problem, if we can call it that. It will be interesting to see what that 11·9% is made up of. I appreciate that Dave made the point about the fleet and private sectors, but it would be good to see what the rest of the UK does in making up that figure.

Am I correct in saying that 2% of UK sales are sales of new vehicles in Northern Ireland?

Mr Robinson: Yes.

Mr Sheeran: Circa 2%.

Mr K Buchanan: OK. It may be that 11·9% is not bad, if we do not know the rest of the figures for the UK. I know it is a long way from the 22% target, if that is correct, but we need to see the figures from the rest of the nations.

Mr Cook: Unfortunately, I do not have that information to hand, but I can certainly get it over to you guys.

Mr K Buchanan: We are smaller. Looking on down, we have fewer chargers, but we may be as good when it is put as a percentage. It would be good to see that.

Mr Boylan: Thank you very much for your presentation. Dave, you were saying that there are a couple of issues. You talked about infrastructure and everything else, but it seems to me that the challenges lie between the manufacturing and the consumer in regard to getting the message out and incentivising people. That is a key element. What more can be done on that matter?

On the grace period, you have looked at the mandate. How do you perceive that happening? Is it a case of there being a regulatory or legislative change, or it is just policy? If we ask for or support a grace period, how do you perceive it coming through?

Mr Robinson: I think that recognising that NI is at 11·9% against an average of 17·2% and that the 5% delta is already inbuilt, on the basis of like-for-like product and pricing this year, is the starting point going into next year.

Mr Boylan: How do we address the grace period issue? How do we communicate that? Where do you see the challenge in that?

Mr Cook: It is just about relaying how far behind the potential market is in Northern Ireland. The situation that we face is that, potentially, going into 2025, the 28% target is so far ahead of what you guys are currently achieving, and it just needs to be reviewed. When we look at the grace period, it is more of a reduction in target than a timescale. It is more of a review to look at Northern Ireland independently, outside of the UK market.

Mr Robinson: The danger is that, if it is a UK-wide target for a manufacturer — let us say that it is 28% — the manufacturer will simply apportion 28% of my annual target or sales contract, which would give me an unsustainable number of EVs to be absorbed into the marketplace.

There is a counter-issue, which is type approval, which, potentially, will have further implications around the management of vehicle supply into NI and will make that more difficult to manage.

Mr Boylan: Brian, you mentioned the offset of combustion vehicles. I might not have heard you correctly or did not understand your point about EV versus combustion vehicles because it can meet the target. Is that an easier route to travel? Would that play a part?

Mr Robinson: That is a route that manufacturers will be actively considering and are probably already impacting that. Order times and bill times for combustion cars are stretching out, almost certainly because manufacturers are withholding supply to get their EV ratio near to the 22%. That is detrimental to consumers.

Mr Boylan: That is what I thought you said. Finally, obviously, you have had conversations with consumers and manufacturers, but have you had any discussions with government?

Mr Cook: Not in regard to Northern Ireland as yet, but we have had discussions with the Department for Transport in regard to the UK targets. Unfortunately, it says that the targets are not moveable at this current status, so it is a concern. We just need to make sure that, if Northern Ireland is going to join in, we can have a review of the current situation and do not impose those large targets going forward.

Mr Boylan: OK. Thank you very much for your responses and for your presentation.

Mr Durkan: It is interesting and alarming in equal measure. The percentage of fleet vehicles in the North is smaller than in other jurisdictions, yet it represents the biggest uptake. I do not know whether it is our place to do some analysis — maybe you have done some analysis — of public-sector fleet and what effort Departments, arm's-length bodies and councils have done to electrify their fleets, because that could drive the percentage up considerably. I know that your main concern is the commercial and private customer, but it could help us in our performance, and, of course, it would be government leading by example. If people see public bodies putting their faith in electric vehicles, they are perhaps more likely to follow suit.

The Chairperson (Mrs Erskine): I think that we might have some research. I think that a research paper that was included last week may have some figures.

Mr Durkan: I missed last week.

The Chairperson (Mrs Erskine): Symon, Brian or David, do you have any information that might point to that?

Mr Robinson: I do not, no.

Mr Sheeran: No, only anecdotal evidence that there is interest in electric vehicles on the public procurement side of things. We already see some uptake of electric in, let us call them, government or local authority fleets. Where the fleet market is strong in the broader UK or GB market is in the leasing sector, where there are tax incentives for company car drivers to adopt benefit-in-kind-saving vehicles. Also, there is a proliferation of the salary sacrifice scheme, which, again, is a tax-efficient way to purchase a vehicle.

We simply do not have the numbers of companies, employees or people on the higher rate of tax in Northern Ireland to participate in that as fully as some of the other regions. Tax incentives are, to a large degree, driving the uptake of the fleet sector. We have a smaller fleet sector. There is some uptake but —

Mr Durkan: Are those the only incentives in the other areas?

Mr Sheeran: The incentives are available to all of the regions. It is just that the volume of people eligible to take them up in Northern Ireland will be significantly lower than in the other three regions. By dint of that, we may be taking a fair share of a small market, but, when you take that weighting into consideration, it results in us being 5% behind the UK average.

The overall ZEV target will be achieved across the UK, including here, when there is some momentum in the retail market. Until there is momentum in the retail market through incentives or other mechanisms, it will be difficult for us to get back onto the glide path. We have a structural imbalance in Northern Ireland. If that is removed in the UK, we will naturally catch up. We are just in a market where there is less opportunity in the fleet segment.

Mr Durkan: I know a bit about the structural imbalance, all right, but those incentives around electric vehicles did exist. When did they go and why? It seems that they took them away when we needed them most.

Mr Cook: There was the plug-in vehicle grant under the previous Government, but I just think that the cost-effectiveness of running that scheme went against the Government. The uptake initially was strong, and it drove the retail market into electric vehicles, but, as soon as that grant was removed, the retail market just collapsed. It was significant. That was probably April or May of last year.

Mr Robinson: Once you fulfil the need for early adopters, which was done with the grant incentive, the market starts to flatten out. At transactional pricing level, you are looking at probably a 20% difference between an ICE and an EV for similar models. That is a barrier or hurdle for the private consumer. Rapid public charging is about four times more expensive than home charging, so you now see articles in the press about a journey using public charging being more expensive than diesel or petrol, and that was not the situation previously. Once you had bought your EV, you could be deemed to be fuelling it for a lot less than diesel or petrol: that is changing.

Mr Durkan: Yes, it was said that you would make up the price difference —.

Mr Robinson: Yes: that you would offset some of the price gap. That is correct.

Mr Durkan: Finally, we are at 11·9%, and the UK average is 17·2%. I do not know whether you will have these figures, but do we know the percentage of market penetration in the Republic of Ireland?

Mr Robinson: We do. Bear with me.

Mr Durkan: I suppose that it would be similar in terms of geography.

Mr Robinson: It is 13·5%.

Mr Durkan: Did you say 13·5%?

Mr Robinson: Yes. I think that what I am looking at is correct.

Mr Durkan: OK, that is dead on. Thanks, gents.

The Chairperson (Mrs Erskine): Sorry, Mark, I referred to a paper from last week. I checked up on it, and there is a small indication. We can check with the Department about that progress, if you are content.

Mr Durkan: Yes.

The Chairperson (Mrs Erskine): Brian, I listened to your response to Cathal about the type approval issue. What exactly is the issue?

Mr Robinson: Symon, do you want to give a quick overview of that?

Mr Cook: In layman's terms, we have an issue with manufacturers seeking type approval to sell cars in GB. GB has its own type approval jurisdiction, and manufacturers say that they will potentially need dual approval — an EU approval and a GB approval — to sell vehicles to Northern Ireland and to sell vehicles from the Northern Ireland market back to the UK. A lot of manufacturers allude to the fact that they are not willing to go down the route of getting dual approval for vehicles.

The Chairperson (Mrs Erskine): Which manufacturers are those?

Mr Robinson: The scenario is probably different for each manufacturer. The starting point for one of our large groups, certainly, was that cars would have dual approval to be either UK mainland or NI. As the EU and GB approvals diverge, however, those manufacturers are not able to accommodate that logistically.

The Chairperson (Mrs Erskine): That is a GB and Northern Ireland issue.

Mr Robinson: Factories built cars to what they called "UK specification", which meant that they were for England, Scotland, Wales and NI. When Brexit happened, however, there was divergence between the two approval levels: the EU and what is now GB. Manufacturers appear to be moving towards building their cars to GB approval level. Cars for NI would therefore have to be built to an EU approval level, which means that stock could not flow freely between NI and the UK. That is fundamental to how the industry operates or has operated.

Mr Sheeran: In addition, because vehicles in the GB markets run off a GB type approval, which may be of a lower standard than the EU threshold, some of those vehicles cannot be sold in Northern Ireland. Therefore, there will potentially be a restriction on access to stock and on the range of stock. That will most likely worsen as time moves on, because the regulation and requirement to have an EU type-approved vehicle for Northern Ireland and a GB type-approved vehicle for the other nations is staggered: from February of this year, every time a vehicle changes, the new type approval rules apply. A vehicle that existed prior to February of this year can carry on with the old type approval, but, over the next number of years, we will see increasing divergence, which will potentially be impactful on choice and availability of stock here.

The Chairperson (Mrs Erskine): From your engagement with manufacturers, do you know whether they have specific targets for Northern Ireland per se?

Mr Robinson: Yes. They have a UK-wide target and will allocate a proportion of it to NI on the basis of our market opportunity. The fundamental flow of new vehicle stock between NI and the mainland is pretty essential to how the industry operates. That will come under pressure.

The Chairperson (Mrs Erskine): What percentage is that proportion?

Mr Robinson: We have circa 2% of the overall UK new vehicle market.

Mr Sheeran: We source probably 50% of our vehicles from the pipeline of physical stock that could be located at dealerships in the other three regions or in compounds at ports of entry. Effectively, we will not have access to those vehicles, because they will have been born with the wrong type approval. We will have to order our own stock on day one, which will not allow us to move with the market, trends, customer demand or consumer offers that the manufacturers may have. It will somewhat restrict our ability to trade.

The Chairperson (Mrs Erskine): Is that regardless of the mandate?

Mr Sheeran: Yes. It is a consequence of Brexit. GB has its own type approval to replace the EU type approval, but Northern Ireland is considered to be still in the EU jurisdiction, so our vehicles have to have EU type approval. It has to be done specifically for vehicles registered in Northern Ireland. A GB type approval will not be able to be registered in Northern Ireland, and an EU type approval will not be able to be registered in GB.

The Chairperson (Mrs Erskine): May I check the preparedness of dealerships in Northern Ireland? When did you become aware of it? What work did your Northern Ireland members undertake to support their readiness and meet their requirements under the scheme?

Mr Robinson: Clarity on the ZEV mandate position and on type approval has probably emerged over the past six months. The ZEV mandate started in January this year on the mainland, and we have been watching the numbers develop and getting feedback from manufacturers on their performance and what the consequences might be. With type approval, it has been broadly the same. We were led to believe that cars would be dual-approved and that there would be free movement of stock, but, as manufacturers have sought to understand the detail, they have changed their position into one of probably building a majority of their vehicles for the lower-level GB type approval. It is a fluid and emerging picture.

The Chairperson (Mrs Erskine): OK. Do Members want to come in with any other questions?

Mr Boylan: How does it work for manufacturers operating in Europe? Is this just because of the mandate?

Mr Cook: No. It has nothing to do with the mandate.

Mr Boylan: Are they coming out of the European market altogether?

Mr Cook: It is more to do with the GB type approval. GB is —

Mr Boylan: I appreciate that; I am trying to get a better understanding. You are talking about the GB regulation and the European regulation. You are saying that, in the North, we need a certain regulation but it will not fit here when a car travels across to here. That is my point. How is the European one in manufacturing dealing with the European market and dealing with here?

Do you understand my question?

Mr Robinson: I do not understand.

Mr Boylan: Well, define exactly what the major problem is in moving cars here compared with what the EU regulations say.

Mr Robinson: Typically, between a third and a half of the vehicles that we sell will be ordered by a customer to a specification. Those cars are built for a customer. The remainder of the cars that are ordered are ordered for stock. Those cars have been built previously to the EU approval level, and they have landed at a port of entry in the UK. Whilst they are notionally cars that we have ordered, after a period of, say, 30 days, those cars become freely available to any other retailer, so you get free movement of unsold available stock across the four nations.

Mr Boylan: Right, OK.

Mr Robinson: That is fundamental to how the market works. With the approvals changing and NI being linked to the higher level of EU approval, we will lose that fluidity of stock movement. Essentially, we will own the cars that we order. Stock management is how the industry lives or dies, in truth: it is so fundamental.

Mr Boylan: OK. That is fair enough.

Mr Robinson: Does that help?

Mr Boylan: Yes, that is fair enough.

The Chairperson (Mrs Erskine): I just want clarity before we finish the conversation. Surely the dual type approval will be an issue regardless of whether we agree the mandate. It is a separate issue.

Mr Cook: Yes.

Mr Robinson: Yes, it is separate.

The Chairperson (Mrs Erskine): Why is it fundamental, then, to a grace period or holding back the mandate?

Mr Cook: It is not, Deborah. This is a completely separate issue that needs to be addressed accordingly.

The Chairperson (Mrs Erskine): As a Committee, our remit is to agree or not agree to the mandate coming forward alongside the other jurisdictions. That issue is something that will have to be separated out from the mandate.

Mr Cook: Yes, that is correct.

Mr Robinson: My only comment is that, however the mandate lands or whatever the percentage for NI is, that task will become more difficult because of the consequences of type approval and the lack of free movement of stock.

The Chairperson (Mrs Erskine): OK. Are members content? OK, thank you very much for your time today to give evidence to the Infrastructure Committee. We appreciate you coming forward today on the issue. No doubt we will be in communication throughout the rest of the mandate with regard to infrastructure in Northern Ireland. We appreciate your time today, and thank you.

Mr Sheeran: Thank you.

Mr Cook: Thank you.

Mr Robinson: Thank you for the opportunity.