The Mayor Wants to Tax a Marketing Term

I am not a big fan of the Mayor of London, and found myself once more dismayed by him by learning that he is considering new charges for SUV drivers. A Vision Zero action plan published by Transport for London floats the idea of higher parking fees or surcharges for SUVs, following lobbying by the campaign group Clean Cities and taking cues from Paris, which tripled SUV parking charges in 2024.

The case, as TfL presents it, runs something like this: SUV registrations in London have grown roughly 40% since 2020. TfL’s own research claims these vehicles create “intensifying risks across London.” City Hall says SUVs are much more likely to kill a pedestrian than smaller cars if involved in a collision, that their higher bonnets create dangerous blind spots (particularly for children), and that they take up more road space and contribute more to tyre-wear particulate pollution. The stated goal is road safety – fewer deaths, fewer serious injuries – under the Mayor’s Vision Zero target of eliminating all road fatalities by 2041.¹

Noble aims! But the policy, as proposed, is a mess – built on vague definitions, imported American anxieties, and a revenue motive dressed up as road safety.

The definition problem

This is the question that should end the conversation before it starts, but somehow never does. There is no legal definition of an SUV in the UK. The term “sport utility vehicle” is a marketing category, not a regulatory one. The Society of Motor Manufacturers and Traders calls them “dual purpose” vehicles, which is about as precise as calling something “food.”

I drive a 2021 Hyundai Kona Electric. On the DVLA database, it is classified as an SUV, because that is how Hyundai chose to market it. In reality, it is 4,180mm long and 1,800mm wide. A Volkswagen Golf – the ur-hatchback, the car that says “I am a normal person making normal choices” – is 4,284mm long and 1,789mm wide. My SUV is shorter than a Golf. It is eleven millimetres wider. It produces zero tailpipe emissions. If you saw it in a car park you would not think “that’s one of those menacing SUVs the Mayor is worried about.” You would think “that’s a small car.”

And the Kona is not unusual. The growth in SUV registrations in London (roughly 40% since 2020, from about 693,000 to 974,000 according to Clean Cities) is not being driven by people buying Range Rover Defenders and Ford F-150s. It is overwhelmingly driven by crossovers: Kia Niros, Nissan Qashqais, Hyundai Konas, Peugeot 2008s. Cars that are, in every meaningful dimension, hatchbacks that sit a couple of inches higher off the ground. The BBC article’s header image is a mud-splattered Range Rover. The median “SUV” on a London street is a Nissan Juke.

Good tax policy needs a base that is legible and hard to game. “SUV” is neither. The state would either have to rely on manufacturer labelling (which is arbitrary and changes with marketing trends) or invent some new technical definition, which would immediately produce absurd boundary cases. Is a Skoda Karoq an SUV? What about a Volvo V60 Cross Country, which is an estate with plastic cladding? Where exactly is the line?

More importantly, any hard boundary creates an incentive to game it. Public choice economists from James Buchanan to Gary Becker have documented how tax classifications reliably produce exactly this kind of strategic relabelling. The American experience is the cautionary tale par excellence: US fuel economy regulations drew a line between “passenger cars” and “light trucks,” with the latter subject to weaker emissions and safety standards. The result was not fewer trucks, but a decades-long shift by manufacturers towards vehicles classified as light trucks, because that’s where the regulatory advantage lay. The Chicken Tax – a 25% tariff on imported light trucks dating back to a 1960s trade war over poultry – further distorted the market, with manufacturers going to extraordinary lengths to reclassify vehicles. Subaru bolted rear-facing seats into the bed of the BRAT to get it classified as a passenger vehicle. Ford shipped Transit Connects from Turkey with seats installed, only to strip them out dockside in Baltimore – a scheme that eventually cost them $365 million in fines. If London introduces an “SUV charge,” the most predictable outcome is not fewer large vehicles. It is manufacturers relabelling their crossovers as something else, while the vehicles themselves remain identical.

The perverse incentives don’t stop at labelling. Depending on the design, the charge could actively encourage people to hang on to older, dirtier, less safe vehicles rather than switch into newer ones that happen to be classified as SUVs. A 2015 diesel Ford Mondeo Estate would likely escape an SUV surcharge, while a brand-new zero-emission Hyundai Kona Electric would be caught in the net. If road safety and environmental outcomes are really what we’re after, this gets the incentives exactly backwards. And consider: a Mercedes-Benz S-Class (a petrol-powered luxury saloon) stretches to 5,289mm long and 1,921mm wide – over a metre longer and 120mm wider than most mid-size crossover SUVs. It would almost certainly escape an “SUV charge.” My 4,180mm electric Kona would not. The policy is targeting a marketing label, not the physical characteristics it claims to care about.

Politicians also talk as if every buyer is standing in a showroom choosing between a supermini and a hulking 4×4 on equal terms. In reality, the market has already moved. Manufacturers have shifted production decisively towards crossovers – they now account for over half of new vehicle registrations in Europe. Walk into a Hyundai, Kia, or Peugeot dealership today and crossovers dominate the range. The superminis are being discontinued or de-emphasised. This is even more pronounced in the used-car market, where most purchases actually happen. The pool of available vehicles reflects what was manufactured three, five, seven years ago. Penalising buyers for responding to a product mix they had no role in shaping is punishing people after the fact.

Britain is not America

There is a genuine problem with vehicle size in the United States. American pickup trucks and full-size SUVs have grown dramatically over the past two decades. A modern Ford F-150 is taller than a Second World War Sherman tank. American pedestrian fatalities have risen sharply, and there is real evidence linking this to vehicle size, hood height, and poor forward visibility.

But here’s the thing: Britain is not America! Our roads are much, much safer already! Patrick McKenzie has an essay called “The optimal amount of fraud is non-zero,” and the core insight generalises well beyond payments: the cost of eliminating the last few cases of any bad outcome can vastly exceed the benefits, especially when the baseline is already low. The UK had roughly 1,600 road deaths in 2024 across the whole of Great Britain – the lowest figure on record outside pandemic years. The UK sits at 25 deaths per million inhabitants, fifth-lowest in Europe, behind only Norway, Sweden, Malta and Denmark. London specifically is even safer, with serious injuries 24% below the 2010–14 baseline. The majority of UK road fatalities – 60% – happen on rural roads. They are not being caused by Nissan Qashqais in Kensington.

I think of this as West Wing Brain: the tendency of British politicians to import American culture war battles wholesale, without checking whether the underlying conditions apply here. America has a genuine vehicle-size crisis driven by regulatory loopholes, tax incentives, and a fundamentally different automotive culture. We have a crossover-popularity trend driven by practical consumer preferences in a country where the best-selling vehicle is a Vauxhall Corsa. If you genuinely want to target the attributes that matter for pedestrian safety – vehicle mass, bonnet height, front-end profile, sightlines – then regulate those variables directly. Don’t tax a marketing category and hope it approximates the right thing.

People are choosing crossovers over superminis for reasons that are entirely rational. You get more boot space. You sit higher, which is easier on ageing joints. You can fit three child seats across the back row, which you cannot do in most superminis. As incomes rise, it is not some moral failing that people stop buying Kia Picantos. It’s just revealed preference.

This matters particularly for families, and London has a fertility problem that dwarfs anything the SUV discourse is grappling with. London’s total fertility rate was 1.35 in 2024, and Inner London was at an astonishing 1.16 – the lowest of any region in England by a wide margin. England and Wales as a whole hit 1.41, the lowest since records began in 1938. Schools across Inner London are merging and closing because there aren’t enough children. Making it more expensive for families to own a car with enough space for children and a pushchair is not going to help with any of this. It is pouring petrol on a fire to warm your hands.

Then there’s the EV transition paradox. For years, the government has been spending billions to incentivise the switch to electric vehicles – grants, tax breaks, the ULEZ expansion. And what do many popular EVs look like? Crossovers and SUVs. The Hyundai Kona Electric. The Kia Niro EV. The MG ZS EV. The Tesla Model Y. This is not a coincidence: most EVs are designed as crossovers because the “skateboard” battery chassis naturally produces a vehicle that sits higher. The platform dictates the form factor. By taxing the SUV shape, the Mayor would effectively be penalising the exact vehicles he has been subsidising and encouraging through ULEZ. We told people to buy electric crossovers, they did, and now we’re going to charge them more for it.

A lot of City Hall policy is written with Zone 1–2 assumptions and then imposed on people in less well-served parts of outer London. Inner London has the Tube, dense bus networks, and walkable high streets. Outer London has orbital bus routes that run every twenty minutes, patchy rail coverage, and journeys that involve awkward interchanges or no public transport option at all. There are still many journeys – school runs with small children, weekly shopping, visiting older relatives, anything involving a buggy and two bags – where a car is simply more practical². The burden of another motoring charge would not fall evenly across London. It would land heaviest on the people with the fewest alternatives. London already has the congestion charge, ULEZ, residential parking permits, and some of the most expensive parking in Europe. Each was introduced with safety or environmental justifications. Each has become, over time, primarily a revenue mechanism. The SUV surcharge is the next layer of the same cake.

Revenue dressed as safety

The stated justification is Vision Zero – the goal of eliminating road deaths entirely by 2041. But how, precisely, does a parking surcharge on “SUVs” achieve this? The causal mechanism is never spelled out, because it doesn’t really exist.

At the margin, some people might choose a slightly smaller car. But marginal shifts in new car purchases will take years to flow through the fleet. Meanwhile, the charge will be paid by people who already own the car, which means it functions as a pure revenue extraction with no behavioural change. And the tell is that nobody is saying “the revenue raised will be hypothecated for road safety improvements.” There is no commitment to better junction design, more traffic enforcement officers, or upgraded pedestrian crossings. The tax is presented as if the act of collecting it is itself the intervention. This is political cakeism from a Mayor who has elevated cakeism to an art form.

Paris already tried this. The vote passed on 5.7% turnout, with Parisian residents themselves exempt from the charges – a lovely bit of NIMBYism where inner-city voters imposed costs exclusively on people driving in from outside. Even France’s own Environment Minister called it “punitive environmentalism.” Despite the policy, SUV sales across Europe have continued to climb. The policy did not change behaviour! It ended up being more performative greenwashing³ than real positive change.

A recurrent problem in British policy is going after easy-to-observe proxies rather than costly-to-enforce actual misconduct. It is administratively easier to slap a surcharge on a lawfully registered, insured car than to clamp down on uninsured drivers, cloned plates, hit-and-run offenders, serial speeders, and repeat drink-drivers. But easier is not the same as effective. Only about 7% of the UK’s 50 million driving licence holders have any points on their licence at all. But within that 7%, there are people with 30, 40, even 51 points who are still on the road, because magistrates routinely exercise discretion to avoid disqualification. The DVLA’s own data suggests 90% of drivers not disqualified at 12+ points retain their licence through judicial discretion. The courts’ leniency towards dangerous drivers is a documented scandal. Lifetime bans for repeat serious offenders would do more for road safety than any number of parking surcharges. Ghost plates, uninsured drivers, unlicensed drivers, drink drivers ⁴ – these are the populations that disproportionately cause serious harm. Targeting them requires enforcement, which requires spending. It is less photogenic than announcing a new charge on a category of vehicle that people love to hate, but it is where the actual gains are.

Better junction design matters too. The majority of pedestrian and cyclist fatalities in London happen at junctions, and many of those junctions have known design deficiencies. Protected cycle lanes, better sight lines, Dutch-style junction treatments – these are infrastructure investments with proven safety records. None of this is as politically convenient as a surcharge on “SUVs.” Enforcement is expensive and invisible. Infrastructure takes years. But they work, and a vaguely-defined surcharge on a marketing category does not.

The great irony of the Mayor’s ‘Vision Zero’ is that it lacks actual vision. It ignores the January 2026 Road Safety Strategy’s own findings: that the real threat on our roads isn’t the height of a family car’s bonnet, but the 26,000 repeat drink-drivers and the 11% surge in uninsured vehicles that the current system is failing to stop.

London does not have an SUV problem so much as it has a political class that prefers symbolic proxies to precise interventions. The vehicles being swept into this category are often not especially large, not especially polluting, and not especially dangerous by any sensible British standard. What makes them attractive targets is not that they are the main source of road danger, but that they are visible, unpopular in the right circles, and easy to tax.

If City Hall were serious about reducing deaths and serious injuries, it would focus on the things that actually drive them: dangerous junctions, repeat offenders, uninsured and unlicensed drivers, and the small minority of motorists who generate a disproportionate share of the harm. Those measures are harder, costlier, and less photogenic than a surcharge on “SUVs”. They also happen to be more likely to work. ⁵

That is the real objection here. This is not a serious safety policy aimed at the main sources of risk. It is a badly targeted tax built around a vague marketing category, justified with imported imagery and moral theatre. London can have safer roads, or it can have another performative motoring surcharge. What it should not do is confuse the latter for the former.

I wrote two companion posts alongside this one: Rebuttals I Expect to My SUV Piece, where I steelman the strongest objections to my argument and respond to them honestly, and How to Lie With SUV Statistics, where I look at how London’s Walking & Cycling Commissioner presented the safety data underpinning this proposal.