The Platform for Electromobility, representing a broad coalition of industries committed to the decarbonisation of transport, reiterates its firm support for the timely implementation of the ETS 2 (Emissions Trading System for road transport and buildings) as scheduled in the previous mandate, in line with the vote of the European Parliament on April 18, 2023.

We nevertheless acknowledge the agreement to delay the start of ETS 2 from 2027 to 2028 in front of political and social concerns linked to its implementation[i]. This additional year, however, must not be understood as pressing a “snooze button” on Europe’s effort for road transport decarbonisation. A snooze delays action without changing the outcome, and thus risks triggering more delays in decisive actions. By contrast, the extra preparatory year should be used actively and purposefully to ensure that ETS 2 starts on solid foundations: predictable, socially fair, and effective in driving emission reductions.

Used well, this time can strengthen infrastructure readiness, accelerate social support mechanisms, and provide market clarity. Used poorly, it risks prolonging uncertainty, weakening investment signals, and reducing the effectiveness of both ETS 2 and the Social Climate Fund (SCF). The recent Council agreement therefore creates not a pause, but a responsibility.

Against this backdrop, the additional year before 2028 must be used to remove uncertainty, ensure social fairness, and prioritise cost‑efficient measures. We thus call for the following measures.

[i] European Commission (2025), Commission proposes targeted adjustments to the Market Stability Reserve Decision to support a smoother start of ETS2, 27 November 2025. https://climate.ec.europa.eu/news-other-reads/news/commission-proposes-targeted-adjustments-market-stability-reserve-decision-support-smoother-start-2025-11-27_en

First, the extra year should be used to stabilise expectations for all actors.

• Expectations should be anchored early through clear communication on the ETS 2 timeline, scope, and interaction with other instruments.
• Core design elements of ETS 2 should not be reopened unless strictly necessary. Repeated renegotiation being in itself a driver of delay, uncertainty, and higher costs.
• Member States should establish clear national earmarking frameworks for ETS 2 revenues, giving visibility to how funds will support households, infrastructure, and mobility alternatives.

In this context, the possibility to launch early auctions in 2026 is a positive step. Early auctions can help market participants anticipate carbon prices, enhance transparency, and reduce the risk of price shocks at the start of the system.

Second, social fairness must be operational before ETS 2 starts, not addressed retroactively.

• The Social Climate Fund should be fully operational ahead of the entry into force of ETS 2.
• Approval of national Social Climate Plans should be accelerated to avoid implementation gaps.
• Member States should be encouraged to frontload national measures, using the flexibility offered to advance support to vulnerable households and small businesses.
• Infrastructure deployment must be facilitated[i].

Social acceptability will depend less on the existence of compensation mechanisms on paper than on their timely and visible delivery. In this context, the possibility for Member States to frontloading ETS 2 revenue is a step in the right direction[ii].

[i] See our proposal for targeted AFIR review: Platform for Electromobility (2025), From targets to consumer-friendly deployment of publicly accessible charging points for EVs, 5 December 2025. https://www.platformelectromobility.eu/2025/12/05/from-targets-to-consumer-friendly-deployment-of-publicly-accessible-charging-points-for-evs/

[ii] Platform for Electromobility (2025), ETS 2: Staying the course for an effective and fair transition to e-mobility, 7 October 2025. https://www.platformelectromobility.eu/2025/10/07/ets-2-staying-the-course-for-an-effective-and-fair-transition-to-e-mobility/

Third, the extra preparatory year should be used to prioritise measures that deliver the highest emission reductions per euro spent.

• Stronger links between ETS 2 and the EU’s Multiannual Financial Framework (MFF) should be explored to ensure coherence and scale[i].
• Social leasing schemes should focus on the most cost‑efficient mobility solutions, for example e-bikes and small affordable electric cars[ii] that also have the potential to boost the European electric transport industry at a crucial moment, bringing volumes and thus driving down costs and prices.
• Phase out fossil fuel subsidies and tax exemptions that weaken the carbon price signal and slow the shift to cleaner mobility options.

[i] Platform for Electromobility (2025), Boosting Europe’s competitiveness with an ambitious MFF for clean transport, 13 October 2025. https://www.platformelectromobility.eu/2025/10/13/boosting-europes-competitiveness-with-an-ambitious-mff-for-clean-transport/

[ii] This reference does not constitute the official position of the Platform for Electromobility on the Small EV Initiative, which will be addressed through a dedicated analysis and set of recommendations.

ETS 2 should continue to cover at least industrial and heavy-duty vehicle applications. Unlike household energy use or private mobility, the transport of goods does not raise the same direct social or political concerns, as associated costs do not immediately or directly affect citizens. Maintaining this scope is therefore essential to preserve investment certainty for manufacturers, operators, and infrastructure providers, and to avoid fragmenting the decarbonisation framework for road transport.

ETS 2 is a central pillar of the road decarbonisation package proposed in 2021 and adopted under the previous EU mandate. Any delay in its implementation mechanically translates into reduced and postponed revenues for the Social Climate Fund, meaning fewer resources, and later, for Member States and households. At the same time, the increased flexibility introduced under the revision of the CO2 Standards for cars and vans makes a robust ETS 2 even more important to preserve a clear economic signal in favour of zero-emission mobility.

The delay of ETS 2 to 2028 should be seen as a final preparation window, not as an invitation to postpone difficult decisions. Pressing the snooze button would only defer costs and weaken Europe’s predictability on road transport decarbonisation. Using the extra year to prepare infrastructure, secure social fairness, and stabilise expectations can instead ensure that ETS 2 starts strong, predictable, and effective from day one.