The Exempt Marques: Hypercar Engineering Beyond the Mandates

Four hypercar makers sit permanently outside the EU’s CO2 mandates. They share one regulatory position, the de-minimis exemption for the smallest-volume manufacturers, and all four are still building combustion engines because no target obliges them to stop. Regulation 2019/631 defines the obligation each of the four carries. It sets no requirement bearing on propulsion, materials, or transmission choice, and the hypercar engineering each one has chosen sits entirely in those three.

Koenigsegg, Pagani, Zenvo, and Gordon Murray Automotive each register fewer than 1,000 vehicles per year in the European Union, placing them below the de-minimis threshold in Regulation 2019/631. The mandate that applies to Ferrari by 2036, the pooled fleet targets that bind Lamborghini and Porsche now, the derogation Bugatti holds and must eventually surrender: none of those obligations extends to these four. The freedom follows from registration volume rather than from any concession granted, and Regulation 2019/631 contains no expiry date for it.

A companion analysis of the 2035 CO2 regulation maps every exotic marque to its compliance tier and sets out what each one is required to do. Measured against Ferrari, Porsche, and Lamborghini, the four exempt makers look alike: less constrained than any of them and less altered by the regulation. Hypercar engineering below 1,000 registrations a year proceeds without the fleet-average CO2 target that shapes propulsion decisions at larger companies. With no target to meet, each of the four set its own rule for what a new technology has to do before it goes into the car.

Koenigsegg built a camless engine for the Gemera, then put a twin-turbo V8 in the production car. Zenvo commissioned its own quad-turbo V12, and added 600 electric horsepower to an engine already making 1,250. Pagani spent four years developing a battery-electric car and canceled it. Gordon Murray Automotive built a 986 kg car around a V12 that revs to 12,100 rpm.

Four Makers the Mandates Cannot Bind

The de-minimis exemption applies to any manufacturer registering fewer than 1,000 new vehicles per year in the EU, counted together with any connected undertakings. It carries no individual CO2 target, no fleet-average obligation, and no end date.

Three further marques hold related positions under the same regulation. McLaren and Aston Martin are exempt by volume under the same provision. Bugatti sits in a different position entirely, holding a negotiated small-volume derogation that covers compliance years through 2035, with the zero-emission target applying to it from 2036. A manufacturer applies for a derogation, and the European Commission grants it. No manufacturer applies for the exemption; it follows from the registration count.

The two jurisdictions compared, exempt tier only

	European Union	United Kingdom
Instrument	Regulation (EU) 2019/631	Vehicle Emissions Trading Schemes
Threshold	Under 1,000 EU registrations per year	Under 1,000 GB registrations per year
Obligation below it	No CO2 target, no fleet average	No interim zero-emission or CO2 target
Endpoint	None in the instrument	2035 phase-out
Who the endpoint binds	Not applicable	Every manufacturer, the exempt included

The exemption is an EU statutory rule, and only Gordon Murray Automotive, the one UK-domiciled maker among the four, sits on both sides of its territorial boundary. Britain left the EU regulatory framework at the end of the Brexit transition period and now runs its own schemes on its own thresholds. Below 1,000 registrations a year neither jurisdiction imposes an obligation. From 2035 they diverge, and Britain’s phase-out reaches manufacturers of every size.

Koenigsegg, Zenvo, Pagani, and Gordon Murray Automotive fixed their engine architectures without having to meet CO2 targets, each pursuing its own design principles.

Koenigsegg Built a Camless Engine and Held It in Reserve

Koenigsegg developed camless valve actuation through its affiliated Freevalve AB, replacing the camshaft with individually actuated intake and exhaust valves under pneumatic, hydraulic, and electric control. The system controls timing and lift independently on each cylinder. That control improves brake thermal efficiency and supports combustion strategies no fixed camshaft can reproduce.

The first production application was to be the Tiny Friendly Giant, a camless three-cylinder shown with the Gemera at the car’s reveal in 2020. The Gemera that entered production carries a 5.0-liter twin-turbo V8. Koenigsegg completed the camless engine and delivered its flagship with a conventional valvetrain.

Christian von Koenigsegg has given the reason directly, and it is not that the technology failed. A V8 that already satisfies type-approval emissions limits and Koenigsegg’s output target gains little from camless actuation beyond fuel savings, because cylinder deactivation delivers much of the same benefit with less complexity. Koenigsegg holds Freevalve for the case where the rules change.

“Regarding our V8, if there is a drastic change in regulations, we can make a drastic change with Freevalve.”

Christian von Koenigsegg, founder and CEO, Koenigsegg Automotive AB (CarBuzz, July 2025)

A company carrying a binding fleet target would develop that capability as part of its compliance planning. Koenigsegg has no fleet target to plan against and, on the current instrument, will never have one. The company built the capability anyway. No rule required it.

What Direct Drive Replaced and What It Cost

The Regera removed the conventional multi-speed gearbox entirely. Koenigsegg Direct Drive (KDD) replaces the transmission with a hydraulic coupling and electric machines, delivering direct mechanical drive at speed while electric torque fills the low-speed range. The combustion engine charges the battery and drives the rear wheels through a single-speed connection.

KDD is as much a packaging decision as a performance one. Removing the gearbox stripped mass and mechanical complexity from the drivetrain, but the battery pack and the electric motors added mass back, and the net weight saving is modest. The complexity saving is substantial: KDD leaves the drivetrain with fewer moving parts and fewer failure points, and it produces torque without a shift interruption. Koenigsegg presents KDD as a system-level improvement rather than an emissions measure, and addresses carbon separately through the Regera’s E85 flex-fuel capability.

Fuel flexibility extends across the entire range. The engines are calibrated for E85, for gasoline, and for renewable or synthetic fuels where they exist. Von Koenigsegg has described a future in which synthetic fuel produced from captured atmospheric CO2 and renewable energy replaces the gasoline fraction. He has argued that a fuel made this way can approach carbon neutrality across the full cycle rather than at the tailpipe alone. The working example he points to is Icelandic methanol produced from volcanic CO2 capture (Bloomberg, 2021; Motor1 factory interview, 2025). No branded e-fuel commitment and no dated timeline have been confirmed.

Where KDD removed the gearbox, the CC850 restores it in an unusual form. That car carries the Engage Shift System, a nine-speed multi-clutch that presents as a gated manual with a physical H-pattern or shifts automatically. Koenigsegg has now built two transmission architectures with nothing in common, and treats the transmission as an open engineering question.

2,300 Horsepower from a V8 and a Single Electric Motor

The Gemera is a four-seat hypercar, a configuration unique to Koenigsegg among the four. The production car pairs a twin-turbo V8 with a single in-house Dark Matter electric motor. Both drive through the Light Speed Tourbillon Transmission, a nine-speed multi-clutch with four-wheel drive and four-wheel torque vectoring.

Koenigsegg Gemera, Combustion Engine

Koenigsegg Gemera, Electric System

Koenigsegg Gemera, Complete Car

Koenigsegg designs and produces the battery and the transmission in-house.

Von Koenigsegg has attributed the powertrain change to customers rather than engineering. Almost every buyer who had specified the three-cylinder chose the V8 instead, and the three-cylinder was left without orders. He has said the technology remains interesting and that a camless Gemera variant is still possible, without committing to one (Top Gear, July 2024).

The Dark Matter motor is the electric half of the powertrain. It weighs 39 kg, produces 800 hp, and uses a patented raxial-flux configuration combining radial and axial flux architecture with six-phase operation. Koenigsegg designed it and manufactures it in-house, and it is alone among the four in controlling both its combustion technology and its electric propulsion technology end to end. That control is what lets Koenigsegg argue a carbon case none of the other three can make.

The Only Exempt Maker Arguing an Emissions Case

Of the four exempt makers, Koenigsegg is the only one that attaches a lower-carbon engineering rationale to its own technology rather than treating emissions as a matter closed by type approval.

The argument rests on lifecycle emissions rather than tailpipe emissions. Von Koenigsegg’s position is that hypercars cannot be assessed by mass-market criteria, because a car carrying a very large battery has to be driven a long way before the emissions cost of manufacturing that battery is repaid, and hypercars are barely driven. Motor1’s account of his estimates puts the break-even near 50,000 miles against a car with a small battery or none, rising to roughly 87,000 miles once renewable fuels enter the comparison. His premise is that cars of this type accumulate very low annual mileage and stay far below either break-even point. For vehicles produced and driven in small numbers, his conclusion is that a light hybrid with a small battery, running an engine calibrated for renewable fuel, is the lower-lifecycle-carbon answer rather than mandated full electrification, and that conclusion holds only if the mileage premise is correct.

What separates Koenigsegg from the other three is that its electrification is dual-purpose. The KDD system and the Dark Matter motor improve the car and are presented as part of a lower-carbon system when combined with renewable fuel. The other three deploy their technologies for output or character, with emissions reduction either absent as a stated goal or arriving as a consequence of lightness, as it does at Gordon Murray Automotive. The difference is one of stated purpose rather than of engineering quality.

Koenigsegg applies the broadest criterion of the four when deciding whether a new technology enters the car. The company admits propulsion innovation whenever the technology improves the car on Koenigsegg’s own terms of output, mass, system efficiency, or lifecycle carbon. Electrification, camless combustion, and fuel flexibility have all qualified under it. Koenigsegg treats propulsion as a core competence rather than a purchased component, and no fleet target limits the range of propulsion work it can take on.

1,250 bhp From a Bespoke V12, and What All-Wheel Drive Costs

The V12 Mjølner, developed with Mahle Powertrain in Northampton, reaches a combustion output of 1,250 bhp with a 9,800 rpm redline. Three 150 kW motors lift combined output to 1,850 bhp. One sits in the gearbox, where it also serves as starter and reverse, and one drives each front wheel.

Zenvo Aurora, Powertrain

Whether the Aurora is fast is settled by the combustion engine alone. Two questions follow from that. The first is what the front motors cost when the V12 already produces more than any owner will use, and the Aurora is one of the few cars where a maker publishes both sides of that answer. The second is what a company reveals about its engineering priorities when it builds its own V12 rather than buying one, and then puts electric drive on top of it.

A Danish Company That Built Its Own V12

Zenvo’s earlier cars, the TS1, TSR, and TSR-S, used modified GM-derived supercharged and twin-turbo V8 engines. The Aurora breaks with that engine strategy completely. Building a bespoke V12 from scratch makes no commercial sense for a company producing single-digit annual volumes. A purchased engine from an established supplier would have been cheaper, faster, and lower risk. Zenvo developed its own.

Chairman Jens Sverdrup has described the decision as beginning from first principles, with the company asking why a buyer should choose a Zenvo at all before deciding what the car should be (Autocar, 2023). The answer was physical presence and sound, and the V12 delivers both. Zenvo’s own launch material frames the V12 as the vital element in an emotional brief, and notes that the output figure was a by-product of pushing the architecture rather than a target set at the outset (Zenvo press release, 2025).

Mjølner, Engine Architecture

Mjølner is a 90 degree hot-V, which puts the four turbochargers inside the vee rather than outboard of the cylinder heads. Almost every road V12 runs at 60 degrees, and Ferrari’s runs at 65. Zenvo moves thirty. Opening the angle that far clears room between the banks for the turbochargers and their manifolds, which a 60 degree vee cannot hold, and it lowers the engine in the chassis, which brings down the center of gravity and the rear bodywork above it. Exhaust runs inward to the turbines instead of out through the flanks, and the shorter path sharpens throttle response.

The angle was not chosen for this engine alone. Zenvo states that Mjølner was designed for modularity, with V8 and V6 derivatives intended for future models, and Sverdrup has since confirmed a naturally aspirated V10 for a smaller car. The natural angle for a V8 is 90 degrees. One block, drawn once, yields four engine families, which spreads the development cost of a bespoke V12 across every engine Zenvo intends to build. The V12 that made no commercial sense on its own makes considerably more as the first of four.

Zenvo built the Aurora’s other major systems in-house as well. The car sits on a carbon monocoque, and Zenvo carries forward the active aerodynamic work it developed on the TSR-S, whose centripetal wing rotated to load the inside of a corner rather than to generate downforce in a straight line. The V12 follows the same pattern.

What Jet Ignition Was Built to Do

Mjølner uses Mahle Jet Ignition, a pre-chamber combustion system in development at Mahle Powertrain for over a decade. A lean fuel and air mixture ignites in a small pre-chamber, and the flame front propagates into the main chamber from multiple jets. It improves combustion completeness and thermal behavior, and its underlying purpose is efficiency.

Zenvo does state an emissions rationale, and it addresses pollutants. Mahle Powertrain’s John Hollingworth set out what the combustion system was for while the engine was still in development.

Holding lambda one at that output is the harder part. High-output turbocharged engines conventionally run rich under load, feeding surplus fuel through the chamber to carry heat away from the turbine, which is why stoichiometric operation and high specific output normally arrive as alternatives rather than together. Jet ignition extends the knock limit far enough to remove the choice. Zenvo runs stoichiometric across the whole map and still takes 189 bhp from every liter.

Mjølner, Combustion

Euro 7 governs pollutants and type approval: nitrogen oxides, particulates, the composition of what leaves the exhaust. Regulation 2019/631, which the four exempt makers sit outside, governs fleet-average CO2. Zenvo states a rationale on pollutants and none on fleet-average CO2. The company has published no lower-carbon narrative, no lifecycle argument, and no synthetic-fuel commitment.

The efficiency gain is real, and the output figure shows where it went. Jet ignition extracts more work from each combustion cycle. In a mass-market application the same technology lowers a manufacturer’s fleet-average figure. At Zenvo it appears as 1,250 bhp from 6.6 liters.

150 Kilograms and 400 Horsepower Separate the Agil from the Tur

The Aurora Agil carries a single rear electric motor and a bias toward agility and lower mass. The Aurora Tur adds a motor at each front wheel for all-wheel drive, with the front pair also serving as an electric torque vectoring system. The two share the same engine, the same 120 kg (265 lb) carbon monocoque, and the same gearbox motor. One variable separates them, and Zenvo publishes both sides of it.

Zenvo Aurora, One Variable

The Agil is quoted at 1,300 kg (2,866 lb) and 1,450 bhp. The Tur is quoted at 1,450 kg (3,197 lb) and 1,850 bhp. Zenvo attributes the difference to the drivetrain addition, which covers more than the two motors: mounts, cooling, power electronics, and the battery capacity the front axle draws on. Run the arithmetic and the 150 kg (331 lb) arrives carrying 400 bhp, which is 2.67 bhp for every kilogram added against a car whose own figure is 1.11. The heavier Aurora ends up with the better power-to-weight ratio, 1,276 bhp per tonne against 1,115.

What the 150 kg does not price is hybridization. The Agil is already a hybrid, and its 1,300 kg includes the gearbox motor and its battery. Zenvo has never built or quoted an Aurora without one, so the first 200 bhp of electric assistance has no published weight at all. The available figure prices the front axle, not the decision to electrify.

Koenigsegg presents its electrification as serving carbon and performance together. Zenvo presents its own as serving performance.

Zenvo revealed the production-specification Aurora Tur at Goodwood in July 2026, with Sverdrup, by then executive chairman, describing the car as setting the company’s direction and as an equilibrium of extremes bringing together power, lightness, and technical ambition. Customer deliveries had not begun at that reveal, and the output and top-speed figures attached to the Aurora remain manufacturer projections rather than measured results. What is already built is the engine: a bespoke quad-turbo V12 running pre-chamber ignition, from a company that had never built a V12 before.

The Seven-Speed Manual Seventy-Five Percent of Buyers Chose

The hypercars Pagani competes against, the Ferrari SF90 and Lamborghini Revuelto among them, have moved to dual-clutch or automated transmissions for faster shifts, better launch control, and higher consistency. Pagani revealed the Utopia in 2022 with a seven-speed manual built by Xtrac, and offered an automated single-clutch alternative for buyers who wanted one.

The manual is slower. It demands more from the driver and it will occasionally produce an imperfect shift. The company accepted the slower shift because the brief required it. Horacio Pagani has described that brief in flat terms: no heavy batteries, no hybrid power, a V12, and a manual or automated transmission rather than a dual-clutch (Top Gear, 2022). Seventy-five percent of the 99 coupe buyers took the manual (CarBuzz, Goodwood 2025), a figure that had risen from the roughly seventy percent Pagani’s commercial director reported a year earlier.

864 PS from an Engine Homologated to 2030

The Utopia uses a Mercedes-AMG twin-turbo V12, the bespoke M158, producing 864 PS (852 hp) at 6,000 rpm and 1,100 Nm between 2,800 and 5,900 rpm. The engine weighs 262 kg dry and meets current EU standards without hybridization. Pagani sources it under an AMG relationship dating to 1999, though no contract duration has ever been disclosed publicly.

Mercedes-AMG M158, as supplied to Pagani

What is on the record is the homologation window. AMG has homologated the V12 until 2030 in the EU and 2032 in California, and Pagani’s Sebastian Berridi stated at Goodwood in 2025 that the company expects the homologation to be extended. AMG has made no public commitment to extend it. Pagani describes the arrangement in partnership terms rather than contract terms, and the approvals themselves sit with AMG.

Pagani’s engineering identity therefore rests on work other than the engine. The company works in composite materials, in chassis architecture, and in the human-machine interface. The materials are its own: Carbotanium, a carbon fiber interwoven with titanium, and its successor Carbo-Triax. Pagani sources its propulsion externally and holds it deliberately at the twin-turbo V12.

The stated reason for excluding batteries is mass, and Pagani has given the same reason through several of its executives. Christopher Pagani, the marketing director, has said that current technology does not allow the company to create the car the way it would want to, and has framed performance at Pagani as vehicle dynamics rather than horsepower or top speed.

Berridi has quantified the mass penalty, citing simulations showing an electric Pagani would weigh 600 to 700 kg more, and noting that the annual mileage of the company’s cars undercuts the environmental case for building one. Horacio Pagani has been blunter, describing a hybrid V8 as considered and rejected on weight, and arguing that a hybrid combines the problems of both propulsion types.

Four Years of Battery-Electric Development, Then Cancellation

Pagani developed a fully battery-electric model between 2018 and 2022, on a modified version of the combustion platform, and showed it to dealers and customers before committing to production. Dealers and customers did not want it.

Berridi confirmed at Goodwood in 2025 that Pagani canceled it, describing a family-owned company unable to proceed against its own economic interest despite substantial research investment. Pagani kept the research and closed the production program.

Ninety-nine Utopia coupes were built, and every one was allocated to a buyer. A roadster followed in 2024, limited to 130 units. Horacio Pagani has made one brief, favorable-in-principle reference to synthetic fuel (Luxcior, November 2024), and nothing has followed it. Pagani has announced no e-fuel policy, made no investment in one, and entered no partnership to develop one. The continuity strategy is supply security and lightweighting rather than propulsion reinvention.

The Engineering Pagani Keeps In-House

Pagani’s combustion-only lineup rests on a supply arrangement. Pagani is the only one of the four that buys its engine: Koenigsegg, Zenvo, and Gordon Murray Automotive each design or commission their own, while AMG supplies Pagani’s and Pagani concentrates its own engineering on mass and craft.

Pagani’s criterion is mass and loss of response together. A system enters the car only if it adds neither the weight nor the dulled response the company associates with batteries and hybrid drivetrains.

On propulsion Pagani relies on the AMG engine’s compliance with current EU standards and puts its efficiency work into mass instead. Carbotanium structures are lighter than conventional carbon fiber, which means less fuel burned per kilometer for the same performance envelope. Pagani does not present that as a CO2 benefit. The company presents it as feel. The carbon consequence is real and unstated, a by-product of a materials science program rather than its objective.

986 Kilograms with a V12 and No Hybrid

The Gordon Murray Automotive T.50 weighs 986 kg with fluids. It carries a naturally aspirated Cosworth-GMA V12 and a six-speed manual gearbox weighing 82 kg. Gordon Murray reviewed the average weight of supercars built over the previous fifteen years, found it near 1,400 kg, and set a target under 1,000 kg.

Curb weight, T.50 against three current hypercars

The T.50 undercuts the McLaren W1, the next-lightest of those cars, by 413 kg, and that gap carries Murray’s entire engineering argument. He founded the company on a single conviction: mass degrades every dynamic quality a driver values, including acceleration, braking, cornering, steering response, and the directness of the connection between input and reaction. Murray has organized GMA’s hypercar engineering around that conviction, and it is the reason propulsion electrification does not appear in the T.50’s drivetrain. Koenigsegg adds electric machines to improve the system. Gordon Murray Automotive removes mass wherever it can find it.

The Highest-Revving Road-Car V12 Ever Built

The Cosworth-GMA V12 displaces 3,994 cc and revs to 12,100 rpm, the highest redline of any road-car V12. The engine weighs 178 kg. Output is 663 PS (654 hp) at 11,500 rpm with 467 Nm at 9,000 rpm, and 71 percent of peak torque is available from 2,500 rpm.

Murray could have turbocharged it for more power. He chose naturally aspirated because turbocharging adds mass in intercoolers, plumbing, and the turbochargers themselves, adds delay between throttle input and response, and changes power delivery from linear to boosted. Cosworth’s managing director Bruce Wood has described the brief as among the toughest the company has taken on. He has explained that the 12,000 rpm development target came from a decision to put clear distance between this engine and anything else on the road rather than from a target sheet of numbers. The production engine passed that target and redlines at 12,100. Murray has said he has no interest in chasing acceleration or top-speed records at all.

The T.33 uses the same V12 family in a broader-torque state with a different aerodynamic approach, built for road use rather than the T.50’s track focus. The T.50s Niki Lauda is the track-only version. One hundred T.50 units were produced. All three share the naturally aspirated V12 core and the manual gearbox.

Why the 48V System Does Not Drive the Wheels

The T.50 carries a 48V electrical system. It powers the 400 mm rear-mounted ground-effect fan, which accelerates airflow beneath the car to generate downforce, and it powers ancillary systems. It does not drive the wheels. GMA does not market the car as a mild hybrid, because the architecture serves aerodynamics rather than propulsion.

“No, there’s no mild hybrid at all… It generates 48 volts for the fan motor.”

Professor Gordon Murray CBE, founder and chairman, Gordon Murray Automotive (Jalopnik, 2020)

The integrated starter-generator does the work of both starter and alternator, a substitution that saves around 20 kg, and running the fan at 48V rather than 12V keeps the fan motor small. Murray accepts electrification where it removes mass. He refuses it in the drivetrain because a battery and motors heavy enough to contribute meaningful propulsion would push the car well above 986 kg. His criterion subtracts where the other three add, since each of those tests what a technology contributes. A materially lighter battery would change the answer, and the batteries available today weigh too much.

Where the Lightness Argument Stops

Murray has made the wider case in public, arguing that weight reduction is the last significant lever the industry has left for lowering emissions, that engine design, control systems, tires, and transmissions have all reached diminishing returns, and that a step change in vehicle mass is what remains (Autocar, 2017). Murray’s case is an emissions argument, and GMA does not present it as an environmental position.

A car weighing 986 kg burns less fuel per kilometer than one weighing 1,772 kg for the same work. The T.50’s emissions per unit of distance are lower than its output would suggest, not because of catalytic or electronic intervention but because there is less car to move.

The manufacturing side of the same argument does not transfer as cleanly. Gordon Murray Group operates the iStream chassis and production architecture, developed originally for the T.25 city car in 2009 and later licensed to Yamaha and others. In that licensing era, Gordon Murray Design published figures of up to 60 percent less manufacturing energy and a factory footprint 20 percent the size of a conventional plant (PRNewswire, 2010; Automotive Manufacturing Solutions, 2015).

GMA is based in Surrey. Its EU registrations fall below the de-minimis threshold and carry no target at any date. Its UK-registered cars sit under the VETS low-volume provision, which sets no interim obligation, and then meet the 2035 phase-out that binds every manufacturer in Britain regardless of size. GMA builds under both jurisdictions, and only the British one sets a date.

Having previously described the current V12 as his last, Murray told the press after the European Commission’s December 2025 proposal that the changed outlook might permit another. Regulatory direction shapes product decisions at GMA even though no target binds the company.

What Four Approaches to Hypercar Engineering Reveal

Four companies hold one regulatory position between them, and each applies a different criterion to what a new technology has to do before it goes into the car.

Four Criteria, One Exemption

The four criteria measure four different things: whole-system improvement, output, preserved response, and mass removed. Koenigsegg admits any technology that improves the car on the company’s own terms, which include lifecycle carbon. Zenvo admits what adds output. Pagani excludes what adds weight or dulls response. Gordon Murray Automotive admits only what takes weight out, which is what keeps electrification out of the drivetrain.

What each maker requires of a new propulsion technology

Maker	What a technology must do to enter the car	Where electrification appears	Stated emissions rationale
Koenigsegg	Improve the car on Koenigsegg’s terms: output, mass, system efficiency, or lifecycle carbon	Direct drive and an in-house motor, serving performance and carbon together	Lifecycle carbon, argued directly and at length
Zenvo	Add output the combustion engine cannot deliver instantaneously	Hybrid layer for power and all-wheel traction	Pollutant compliance only, lambda one for Euro 7. None on carbon
Pagani	Add neither mass nor loss of response	None in the combustion cars. The battery-electric program was canceled	Met by the supplied AMG engine. No carbon rationale stated
Gordon Murray Automotive	Remove mass rather than add it	48V for the fan and ancillaries. Never propulsion	None stated. Lightness argued as an industry lever, not a company claim

Only one of the four pursues carbon reduction as its own engineering objective. Koenigsegg develops camless combustion for efficiency, builds its own electric motors, and calibrates its engines for renewable fuel. GMA’s 986 kg car burns less fuel than the 1,772 kg hybrids it is measured against, and the company frames that reduction as a consequence of lightness rather than a design objective. Zenvo states a pollutant rationale and has published no carbon rationale. Pagani relies on the supplied AMG engine for compliance with current EU standards and directs its own engineering toward materials science and craft.

A fifth case belongs outside the exempt group. The Chevrolet Corvette, examined in the companion analysis, electrifies for performance, with no emissions rationale attached to the hybrid system. The Corvette’s European position is widely read as too small to regulate. The compliance record shows otherwise: General Motors is assessed individually rather than within a pool, carries a binding target under a small-volume derogation, and exceeded that target in the 2023 compliance year. Only three manufacturers across the EU missed their targets that year. So the four exempt makers are freer in Europe than the Corvette is.

What Separates a Threshold from a Negotiation

The Corvette is not free in Europe. General Motors holds a derogation and carries a target it has missed, and its position in the United States rests on federal penalties that were reset to zero rather than repealed from the statute. These are two different positions, and only one of them follows from a statutory threshold the holder never had to apply for.

General Motors sits only a few hundred European registrations above the point that would place it inside the permanent exemption, which means GM could reach that exemption by registering fewer cars in Europe, an outcome available in no other part of the market. None of the four sits near that threshold. Koenigsegg registered three cars in the EU in 2023. Pagani registered one. Zenvo and Gordon Murray Automotive do not appear in the compliance record at all. The four hold their exemption by a margin of nearly a thousand registrations a year, and no commercial decision available to them would close it. Every other position in the market can be renegotiated with a regulator, reversed if the penalty rate is restored, or lost by registering a few hundred more cars.

What the market will pay for the last internal combustion engine cars, the ICE premium, depends on what each maker does with the years the exemption leaves open. For owners of cars from these four companies, two things will decide how the market comes to remember a given car: the manufacturer’s engineering identity, and the propulsion path it chose when nothing compelled a choice. One kind of car stands as the record of how far hypercar engineering took combustion. The other is remembered chiefly as the last of its type.

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