Hi Friends,

Even as I launch this today ( my 80th Birthday ), I realize that there is yet so much to say and do. There is just no time to look back, no time to wonder,"Will anyone read these pages?"

With regards,
Hemen Parekh
27 June 2013

Now as I approach my 90th birthday ( 27 June 2023 ) , I invite you to visit my Digital Avatar ( www.hemenparekh.ai ) – and continue chatting with me , even when I am no more here physically

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Tuesday, 21 April 2026

CAFE‑3 Shake‑Up

CAFE‑3 Shake‑Up

Why this April mattered

I woke up on April 16 thinking about rules, formulas and a very Indian paradox: we want cleaner cars, but we also want them to stay affordable. The Cabinet-level consultations and the stakeholder meeting convened that day were meant to close that loop — to turn a contested draft into a workable policy that automakers can plan for and consumers can live with.

Over the last few weeks the debate has boiled down to one central question: how do you treat small cars?

  • Do you give them an explicit special carve‑out?
  • Or do you change the underlying maths so lighter cars naturally get gentler targets?

The draft that the Bureau of Energy Efficiency circulated in April has done a bit of both — but more of the latter. The explicit 3 gCO2/km small‑car concession that appeared in earlier drafts was quietly removed. Instead, the formula that links fleet targets to vehicle weight has been flattened and re‑referenced, producing a more generous effective target for lighter vehicles without a separate carve‑out on paper.

That technical tweak matters. For an entry‑level hatchback (the kind the market thinks of as a “small car”), analysts showed the effective emission limit would rise by several grams per km under the revised formula — the sort of relaxation that can materially reduce the need for expensive hardware changes, at least in the near term.

What the April 16 meeting did (and didn’t)

The April 16 consultation was the likely final inter‑ministerial/industry round before the government moves to notify the norms. The mood, according to multiple industry updates, was one of broad alignment — most of the 16 discussion points had converged — but two issues still split opinion:

  • Weight‑based categorisation and how (or whether) to explicitly define "small cars"
  • Super‑credits and their treatment (especially for flex‑fuel, hybrid and other low‑carbon technologies)

The meeting appears to have resolved to proceed with the April draft as a complete framework rather than reopening settled points. That means:

  • No separate small‑car carve‑out on paper, but a flatter weight‑slope that benefits lighter cars in practice.
  • Continued use of flexibility measures: credit trading, pooling, block‑period compliance and recognition of off‑cycle technologies.
  • Retention (with tweaks) of super‑credits for certain technologies, notably flex‑fuel solutions.

Two practical outcomes follow: manufacturers get more predictable compliance mechanics (a three‑year block approach rather than year‑to‑year surprises), and the government signals it is unlikely to push back the April 2027 implementation timeline.

Why this matters beyond margin and marketing

I look at these rules not just as an engineer or a policy‑wonk, but as someone thinking about the long arc of mobility in India:

  • A flatter formula helps preserve affordability for first‑time car buyers and eases the transition for manufacturers who rely on high volumes of compact petrol cars.
  • At the same time, the framework nudges OEMs toward cleaner powertrains — batteries, hybrids, flex‑fuel — through volume derogation factors and carbon‑neutrality discounts.
  • The credit trading approach moves us away from pure punitive fines and toward a market for compliance. That’s a pragmatic way to preserve momentum while the EV ecosystem matures.

There are trade‑offs. The more concessions the regime permits (even as formulaic relaxations), the slower the pressure to invest in deep decarbonisation. Conversely, too blunt a stick risks steep price rises and a stall in the shift from two‑wheelers to affordable four‑wheel mobility.

Where my past notes come in

I have written about the tension between incentivising green tech and keeping mobility inclusive before. In earlier posts I argued that incremental regulatory nudges must be matched with explicit incentives for alternative fuels and hybrids — tax relief, procurement support and supply‑chain safeguards — to avoid simply passing costs to consumers while postponing structural change (Tighter CAFE norms to electrify the government’s EV push).

The CAFE‑3 draft moves in that direction: it leans on market mechanisms, gives breathing room to lighter vehicles, and preserves super‑credits for technologies that can scale. The missing piece remains stronger, aligned incentives for infrastructure (charging, bio‑ethanol supply chains, flex‑fuel adoption) so that manufacturers aren’t choosing short‑term compliance hacks over long‑term zerocarbon investments.

What I’ll be watching next

  1. Exact finalisation of the weight‑slope equation — the numbers matter as much as the headline.
  2. The final design of super‑credits and carbon‑neutrality factors — will flex‑fuel and strong hybrids get enough headroom to scale commercially?
  3. How credit trading and BEE’s direct‑sell credit mechanism are operationalised — transparency and a deep market will make this credible.
  4. Any near‑term signal on tax or procurement incentives for flex fuels and hybrids. Policy is half the equation; incentives complete it.

My take — a simple summary

CAFE‑3 is an awkward, but necessary, balancing act. The April changes and the April 16 consultations show the government wants to hold industry to higher ambitions without breaking the affordability thread that binds millions of buyers to small cars. If executed well, the approach buys time for infrastructure and technology to catch up while still tightening the national fuel‑efficiency trajectory.

But words and formulas aren’t enough. If we want these norms to accelerate a just green transition, regulators must pair them with targeted incentives for cleaner fuels, a roadmap for charging and ethanol scaling, and clear timelines for when leniencies phase out.

I’ll keep watching, and I hope the final notification has that pragmatic long‑view.


Regards,
Hemen Parekh


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