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2023 AG Letter Toyota Complaint, New York

Download the pdf here.

Attorney General Letitia James
Office of the New York State Attorney General
The Capitol
Albany, NY 12224

Dear Attorney General James,

Public Citizen respectfully requests that your office investigate and take enforcement action against Toyota Motor Corporation and Toyota Motor North America (“Toyota”) for its misleading marketing of gasoline-powered vehicles as electric vehicles (“EVs”) and issue clear policy guidance explaining that marketing like Toyota’s is a deceptive practice prohibited by General Business Law §§ 349 and 350.

Toyota is the world’s largest automaker.[1] As the maker of the Prius hybrid vehicle, it was long considered a leader in the field of clean cars.[2] But now the market is shifting rapidly toward electric vehicles. Toyota long ignored this technology, and today it lags far behind other automakers in a market that is growing exponentially.[3]

In response to this market shift, as detailed in the attached memo, Toyota has launched  a marketing campaign that uses the term “electrified” to paint its existing hybrid models—which are gasoline-powered—as electric vehicles. Through its “Beyond Zero,” “Electrified Diversified,” and “To Each Their Own Electric” marketing campaigns and other advertising practices, Toyota is mendaciously relabeling a number of cars with internal combustion engines “EVs” and representing vehicles that run on fossil fuels as “electric” and “electrified.” These representations are misleading consumers about the climate and economic benefits of Toyota’s hybrid cars as compared to EVs. Consumers typically understand the words “EVs” and “electric vehicles” to refer to cars that are fully, or at least meaningfully, electric—and for that reason materially superior to hybrids regarding climate impacts, cost of ownership and maintenance, and other factors. Toyota’s practices are also introducing disinformation and confusion into the market for electric vehicles, undermining fair competition and consumer choice in one of the most important, dynamic, and fast-developing sectors in the U.S. economy.

For the benefit of consumers, fair competition, and the livable future that many consumers are attempting to use their market choices to foster, we urge the Attorney General to investigate and take enforcement action against Toyota to end its deceptive marketing of gasoline-powered cars as “EVs,” “electric,” or “electrified,” which is prohibited under GBL §§ 349 and 350.

Respectfully submitted,

Aaron Regunberg, Senior Policy Counsel
David Arkush, Director
Public Citizen’s Climate Program
1600 20th Street, NW
Washington DC, 20009
(202) 588-1000

[1] Mike Costello, Toyota remains world’s biggest car company, Car Expert (Jan. 30, 2023), https://www.carexpert.com.au/car-news/toyota-remains-worlds-biggest-car-maker.
[2] Hiroko Tabuchi, Toyota Led on Clean Cars. Now Critics Say It Works to Delay Them, The New York Times (Jul. 25, 2021), https://www.nytimes.com/2021/07/25/climate/toyota-electric-hydrogen.html.
[3] International Energy Agency, Global EV Outlook 2023, 8 (2023),