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No it doesn't. It just requires an auxiliary heater, which has been a common feature in cars sold in Europe for at least 20 years. It's a feature you can find in cars sold during the 80s, like the W214.

> This is not a common feature in Europe, except in EVs.

It's a common feature in fancy cars and has been so for ages. Most EVs definitely fall into the fancy car category.

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Fair point, but what, maybe 5% or so of gas cars are fancy enough to have a fuel-burning auxiliary heater in Europe? (not just Scandinavia)

Where as most EVs have a "remote HVAC control" feature - even the pretty basic ones. And EVs, of course, will cool the cabin in summer time as well, something that an auxiliary heater can't do.

It's definitely much more than 5% of new ICE cars.

Across all of Europe? No way. No cars sold in Southern Europe have this, and afaik it's rare (at best) in the UK. In Scandinavia? Maybe.

But aren't most premium new ICE cars in Europe now (mild) hybrids anyway? Why not use the big 48V battery to power an electric aux heater? Surely way cheaper, simpler, and less dangerous?

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