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Tesla wins Dutch speed-cap cut; China October sales lag market

  • Good news: Dutch regulator cut the Assisted Driving speed margin from +50% to +10%, meeting Germany's conditions and easing the path to EU approval.
  • Bad news: China October wholesale was 67,829, up 10.3% year on year but behind the market's 12%, with growth leaning on exports.
  • Mixed: Megapack plant won foreign-trade zone status, helping cash flow, but tariffs on Chinese LFP cells still rise from 7.5% to 25%.
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On 3 Nov the Dutch vehicle authority approved cutting the speed margin on Tesla Assisted Driving from +50% to +10% and renaming the system. Both conditions Germany set on 6 Oct are now met, which removes the biggest obstacle to EU approval, but Sweden's zero-speeding requirement remains a risk.

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In China, October wholesale was 67,829 vehicles, up 10.3% year on year, yet it lagged the market (national new-energy vehicles rose 12%). Growth leaned on exports while domestic sales fell. The half-price deposit and 5-year 0% financing offer launched on 30 Oct needs November insurance registration data to be judged. The Brookshire Megapack 3 plant in Texas won foreign-trade zone status, which helps cash flow, but tariffs on Chinese LFP cells still apply. The rate rises from 7.5% to 25% on 1 Jan 2026, and relief has to wait for LG's Michigan plant to start production in the second half of 2027. The Cybercab test fleet has appeared outside Texas and California for the first time: about 20 vehicles are testing winter ice and snow conditions in Detroit.

Key evidence

  • Official RDW notice, 3 Nov: the speed margin on Tesla Assisted Driving falls from +50% to +10%, resets to zero at each start, and other speed-related functions are off by default. HW4 vehicles get the change over the air
  • The change is folded into the existing type approval, so no fresh approval is needed. The number of countries that recognise the Dutch approval rises from 8 to 10
  • Both conditions Germany set on 6 Oct (a rename and a 10% cap) are now met. The EU technical committee could vote as early as December, and needs 15 of 27 member states representing 65% of the population
  • Sweden objected in June, demanding zero speeding, which a 10% margin does not satisfy. In Brussels, 55% of vehicles were found speeding on 30 km/h roads, and France refused recognition over urban speeding
  • Electrek notes that the system's own speed-limit recognition is inaccurate, and a lower cap does not fix that
  • China October wholesale was 67,829 vehicles (preliminary CPCA data, CnEVPost, 3 Nov): up 10.3% year on year, down 28.9% month on month, and the lowest since February. January to October total was 810,889, up 21.4% year on year
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  • National new-energy passenger-vehicle wholesale in the same month was about 1.8 million, up 12% year on year and 8% month on month. Tesla trailed the market on both measures
  • In the first nine months, domestic deliveries were 381,088, down 11.9% year on year, while exports were 361,972, up 108%. Exports rose from 28.6% to 48.7% of the total
  • October is a seasonal low. The base was 68,280 in 2024 and 61,497 in 2025. Since 30 Oct Tesla has offered half-price deposits and 5-year 0% financing
  • US Federal Register, 2 Nov: the Brookshire plant (Megapack 3, planned capacity 50 GWh a year) was granted foreign-trade zone status, valid for 14 months
  • Benefits of the zone: duties are deferred until goods leave the plant, which helps cash flow. Megapacks exported directly pay no US duty. Parts not subject to special tariffs pay the lower finished-product rate (0-3.4%)
  • Parts covered by Section 301, 232 and 122 measures, including Chinese LFP cells, still pay the original rates. The Section 301 tariff on Chinese non-EV lithium batteries rises from 7.5% to 25% on 1 Jan 2026
  • LG Energy Solution's Michigan plant has a $4.3 billion LFP cell contract, with mass production due in the second half of 2027
  • Detroit News exclusive, 3 Nov: about 20 Cybercabs, based at a paint and body centre in Southfield, are testing on I-696, M-10 and Eight Mile Road. Waymo tested in the area last year
  • The Cybercab test fleet has appeared outside Texas and California for the first time. Tesla has not officially said what the tests are for

Catalysts to watch

  • EU technical committee could vote on Tesla Assisted Driving as early as December (needs 15 of 27 member states representing 65% of the population)
  • China November insurance registration data will show whether the half-price deposit and 5-year 0% financing offer works
  • 1 Jan 2026: Section 301 tariff on Chinese non-EV lithium batteries rises from 7.5% to 25% (more cost pressure on Megapack)
  • Second half of 2027: LG's Michigan LFP cell production starts (eases Megapack tariff pressure)
  • Cybercab expansion to northern cities (once winter testing is complete)

Risks

  • Sweden demands zero speeding and a 10% cap does not satisfy it, so EU approval could still stall
  • Electrek notes that speed-limit recognition is itself inaccurate, and the technical problem is unresolved
  • Domestic sales in China are falling (down 11.9% year on year in the first nine months), and relying on exports for year-on-year growth is not sustainable
  • Cell tariff pressure on energy storage margins will not ease until the second half of 2027
  • Tesla has not said what the Cybercab tests are for, so the purpose is inference

Sources 5

  1. Official RDW notice, 3 Nov
  2. CnEVPost, 3 Nov (preliminary CPCA data)
  3. US Federal Register, 2 Nov
  4. Detroit News exclusive, 3 Nov
  5. Electrek