Stop diverging priorities, stop disrupting investments.
Supply & Industry
Recent political debate has raised the risk that the EU’s clear decision to phase out combustion engines in 2035 will once again be called into question. We believe this could prove fatal for the future of the European automotive industry.
In opposing this dangerous instability, the Platform for Electromobility is highlighting the importance of creating the enabling conditions to allow clean tech industries to prosper, notably in the transport sectors. Ultimately, this will help achieve the EU’s ambitious decarbonisation goals. As we advance towards zero-emission mobility, we are concerned by recent discussions surrounding the revision of the CO2 standards for cars and vans, which foresee introducing CO2-neutral fuels (such as e-fuels) into the post-2035 regulatory landscape.
This paper outlines the vital importance of supporting the ongoing progress towards the mass adoption of EVs and electromobility. It also highlights the risks of diverting the focus – and the vital investments required for electrification – towards the fictitious solution of e-fuels.
We therefore reiterate our full support for both the 2035 zero-emission targets for cars and vans and the inter-institutional agreement set out in a European Commission statement and confirmed by recital 11 of the CO2 Standards Regulation on the introduction of synthetic fuels beyond this date. If there were to be any role for alternative fuels, it should be minimal, and limited to vehicles running exclusively on 100% climate neutral RFNBOs.
1. Investment certainty for the electromobility ecosystem
Investment in the net-zero industrial ecosystem requires a clear, consistent and properly implemented regulatory framework. European transport industries are committed to, and are building, this ecosystem. EU auto manufacturers have committed around €250 billion to electrification by 2030, while 86 new electric vehicle models will be launched between 2024-26 (58 in segments A, B and C). The EV charging industry is already investing heavily in expanding both public and private charging infrastructure; and – with an average of €33 billion per year invested in our distribution grids over recent years – financing for utilities are continuing to grow to accompany the transition of the grid.
However, adding e-fuels to this regulatory framework will create investment uncertainty. This will ultimately deter stakeholders from fully committing to electric vehicle manufacturing and infrastructure roll-out. Given the combination of increasing competition from non EU countries, rising energy prices and a shortage of qualified EU workers, it is ever-more crucial to focus EU investments on electric vehicles to reach critical mass and help the EU remain globally competitive. A stable regulatory environment remains essential for maintaining Europe’s leadership in sustainable transport and ensuring that investments are directed towards proven, scalable technologies rather than nascent ones such as e-fuels.
2. Strategic prioritisation of proven, sustainable technologies
With limited resources, Europe must prioritise its investments in the technologies most capable of delivering effectively on sustainability and performance. Unlike e-fuels, EV technologies are already proven, energy-efficient and supported by an expanding infrastructure that continues to develop. Allocating resources to establish a separate, parallel infrastructure for e-fuels will only multiply the financial demands and divert away funds that could otherwise be used to enhance EV infrastructure and accelerate the adoption of electric transport.
Decarbonising transport will also necessitate the expansion of rail, public transport and active mobility modes; substantial investments will be essential for scaling up both services and infrastructure to meet these ambitions. The Letta report highlights that “the investment needs associated with realising the TEN-T core network by 2030 are estimated at around €500 billion, with a significant portion still lacking sufficient financial resources”. The Draghi report estimates that completing TEN-T is projected to increase GDP by €467 billion by 2050. For active mobility, Europe would require approximately €40 billion per year to double the number of cycle trips within 10 years.
Europe cannot afford to fragment its investment focus by pursuing less-efficient alternatives, particularly when electromobility is already delivering on its promises for cleaner transport and industrial competitiveness.
3. Enabling the transition to electromobility: skills and innovation
Europe’s transition to electromobility is generating demand for a skilled workforce capable of driving innovation and advancing Europe’s standing in the global clean tech market. Any delays to the transition to electromobility would in turn delay the urgently required shift of the workforce from the fossil fuel industries to the electromobility supply chain and the e-mobility infrastructure ecosystem. Given the current regulatory framework and CO2 standards, jobs in energy production and energy infrastructure in Europe are expected to increase by 128% and 543%, respectively. E-fuels also do not offer the same potential for creating the quality, high-value and future-proof jobs in emerging sectors.
By investing in electromobility, Europe can build a workforce that is properly equipped for the green transition. It will bring skilled employment to local communities and ensure that the transition to clean mobility is supported through jobs with long-term prospects and benefits for European workers. A 2021 BCG study showed almost 80,000 extra operational production workers will be needed in the manufacture of batteries and accumulators, while OEMs will require 30,000 new software and system developers to manufacture electric motor vehicles.
4. Strategic autonomy and energy security
Given the growing need for energy security, electromobility offers Europe the opportunity to establish robust local supply chains based on locally recycled materials and locally produced renewable energy, thus reducing the need for imported fossil fuels. This is important, given that the vast majority of any future e-fuels used in Europe would be imported. As the global market for EVs continues to grow, Europe must concentrate its efforts on bridging the gap to other global leaders.
5. The cost of energy and Europe’s industrial competitiveness
The rising cost of energy is a key factor in the recent difficulties facing Europe’s industries. Developing a transport mode as energy intensive as e-fuels (e-fuels require five times the energy of direct electrification; hydrogen three times) would only drive energy costs higher across Europe.
The production of synthetic fuels is already highly energy intensive; each kilowatt-hour used to produce synthetic fuels is precious energy that cannot provide for other, more efficient, means. Synthetic fuels generated to store electricity during production peaks will be far from sufficient to match Europe’s demand and should be directed to hard-to-abate sectors such as aviation, shipping and energy intensive industries, not road transport for which more energy efficient technologies exist.
With electricity demand continuing to escalate, using synthetic fuels for land transport risks further undermining Europe’s industrial competitiveness by inflating operating costs for manufacturers, reducing the appeal of Europe as a hub for industrial investment. Prioritising energy-efficient, directly electrified transport modes is therefore essential for maintaining energy affordability, supporting industry and ensuring Europe’s long-term economic resilience.
Conclusion
The Platform for Electromobility urges European lawmakers to prioritise investments in clean mobility, and to avoid policies that would instead divert the required critical resources towards inefficient and expensive alternatives. By focusing on electromobility, we can create a sustainable, competitive and resilient transport sector that serves Europe’s citizens, economy and environment.
We consequently reiterate our full support for both the 2035 zero-emission targets for cars and vans and for the inter-institutional agreement – expressed in a European Commission statement1 and confirmed by recital 11 of the CO2 Standards regulation2 – on introducing synthetic fuels past this date. If any future role were to be given to alternative fuels, it should be minimal and restricted to vehicles running exclusively on 100% climate neutral RFNBOs (renewable liquid and gaseous fuels of non-biological origin).
"The e-fuels debate has been a massively unhelpful distraction. The future of road transport is electric, and we as Europe have to go all-in to get ahead in the global market. Our competitors are not wasting time on false debates, they are charging forward."
— Chris Heron, Secretary General, E-Mobility Europe
E-fuels: a costly Pandora’s box for European drivers
Vehicles & Markets
The Platform for Electromobility calls on Members of the European Parliament (MEPs) to consider carefully the impact of integrating e-fuels into Europe’s decarbonisation strategy, most notably into the post-2035 regulatory landscape. We advocate for policies that will prioritise energy efficiency, affordability and transparency for consumers; the proposal to expand e-fuel use risks undermining this. As the EU seeks to revise its CO2 standards for cars and vans, MEPs should evaluate how adopting e-fuels will affect Europe’s consumers in terms of increasing costs, creating regulatory ambiguity and ultimately impacting public health and air quality.
1. High costs of e-fuels for consumers
E-fuels are likely to be prohibitively expensive for everyday consumers, increasing the overall cost of mobility in Europe. By 2030, e-fuels are projected to cost consumers 4 times more per kilometre than battery electric vehicles (BEVs).1 While fossil fuel-industry advocates argue that large-scale production will reduce these costs, BEV technologies are also progressing, with prices expected to fall. The comparative cost burden on consumers – particularly low-income families and rural populations who need to cover the greatest distance – would hinder the EU’s ambition of affordable clean mobility accessible for all.
Without strong regulatory guardrails to support and incentivise the transition to electric mobility, drivers may face increased costs for synthetic fuels for internal combustion vehicles. Such a cost will disproportionately impact the most economically vulnerable consumers. These individuals rely on affordable mobility options; advancing high-cost technologies such as e-fuels threaten to exacerbate existing inequalities in accessing transportation. Producing a truly climate-neutral e-fuel will make the cost per kilometre driven significantly higher than any other modes of transports2.
[1]Clean solutions for all: T&E’s car decarbonisation roadmap - Transport & Environment [2] E-Fuels and Their Role in the Transport Sector - Transport & Environment
2. Regulatory instability: impacts on consumer decisions to shift to clean mobility
Inconsistent regulations and enabling conditions delays create uncertainty for consumers, leading to delayed decision-making in purchasing clean vehicles. This in turn is lowering the demand for the clean vehicles that European manufacturers urgently need to reach their decarbonisation targets. If e-fuels are introduced alongside BEVs, it may result in a complex and fragmented regulatory environment, one that is confusing for fleet managers. For example, approximately one-third of new cars in Europe are company vehicles, reflecting corporate fleet purchasing decisions. Companies seeking to decarbonise their fleets are encountering uncertainty over which technologies will ultimately be compliant with EU CO2 emissions standards. As a result, fleet buyers are delaying their decisions to switch to zero-emission vehicles, leading to a detrimental slowdown in clean vehicles market conditions.
Technology-neutral policies that increase regulatory ambiguity risk jeopardising Europe’s decarbonisation targets and lead to delays in adopting proven low-emission vehicles. In committing to a unified and energy-efficient path forward, the EU can provide consumers and companies alike with the certainty needed to make sustainable choices.
3. The Pandora’s box of fraud and ambiguity
Given that transport fuels derived from fossil or renewable energy are chemically identical, the process of monitoring and verifying the environmental benefits of e-fuels is loaded with logistical challenges.
In order to be fully transparent to consumers, fossil and e-fuels should not be blended, and their price should be clearly indicated at petrol stations. Otherwise, consumers committed to choosing clean energy sources for their vehicles may unwittingly purchase fuel that does not deliver the promised environmental benefits.
While control mechanisms are possible, introducing e-fuels alongside existent fossil-fuel pumps would require additional infrastructure investments. Such measures include dedicated e-fuel nozzles, adding additive to e-fuels to tell them apart from fossil fuels, while car makers would have to retrofit vehicles with new onboard sensors to ensure that the vehicle does not drive on fossil fuel. This burden would likely fall on consumers, who may face higher prices and additional maintenance costs. It would be better to invest these resources in more mature and energy-efficient technologies such as battery-electric vehicles. In contrast, BEVs offer transparency, with the energy source directly linked to an increasingly green electric grid, which is increasingly being decarbonised. Allowing e-fuels onto the market without robust consumer protection policies risks misleading consumers and potentially undermining public trust in the EU’s environmental objectives.
4. Impact on air quality and public health
E-fuels produce comparable levels of pollutants – such as nitrogen oxides (NOx) and particulate matter – as traditional fossil fuels. These impact air quality and public health, particularly in urban areas.[1] Europe’s cities already face air quality challenges; introducing e-fuels could further compromise efforts to reduce pollution in densely populated areas. By simply maintaining levels of harmful emissions, e-fuels undermine the EU’s objective of improving public health outcomes through cleaner transportation.
[1] E-Fuels: Current Status and Projections - PIK Potsdam Institute for Climate Impact Research
Policy recommendations for protecting consumers’ interest in the clean mobility transition
- Limit e-fuel use post-2035
Minimise the role of e-fuels in post-2035 vehicle sales, ensuring that only renewable-based e-fuels qualify. This measure will help direct investments to technologies with clear and measurable environmental benefits. We therefore reiterate our full support for both the 2035 zero-emission targets for cars and vans and the inter-institutional agreement set out in a European Commission statement[1] and confirmed by recital 11 of the CO2 Standards Regulation on the introduction of synthetic fuels beyond this date. If there were to be any role for alternative fuels, it should be minimal, and limited to vehicles running exclusively on 100% climate neutral RFNBOs.[2]
- Introduce consumer protections against high costs and misrepresentation
Develop consumer protection policies to mitigate against the high cost of e-fuels, provide transparency around their pricing and use and to prevent misleading claims on their benefits. For example, establishing clear labelling standards and specific nozzles for e-fuels could reduce confusion and help consumers avoid paying premiums for fuels that fail to meet expected environmental standards. In addition, supporting demand for energy-efficient transports (such as BEVs) will create more affordable mobility options.
- Prioritise energy efficiency in mobility investments
Encourage energy efficiency as a guiding principle for all public and private transport investments. By supporting the deployment of proven energy-efficient solutions such as BEVs, the EU can build a more affordable and accessible pathway to clean mobility.
[1] Commission Statement on CO₂ Standards for Light Commercial Vehicles - European Commission [2] Renewable liquid and gaseous fuels of non-biological origin
Conclusion
The Platform for Electromobility calls on MEPs to consider the risks posed by e-fuels. While potentially valuable in hard-to-abate sectors, e-fuels threaten to introduce higher costs, regulatory uncertainty and health risks in the transport sector. By maintaining its focus on energy efficiency and consumer protection, the EU can safeguard the interests of its citizens and ensure a smoother, more-affordable transition to clean mobility.
"While e-fuels hold potential for hard-to-electrify sectors, their use in road transport would drive up costs, delaying decarbonisation, and harming public health. MEPs must ensure energy efficiency and consumer protection remain the cornerstones of Europe’s mobility transition."
— Alex Keynes, Clean Vehicles Manager at T&E
[Chairs' edito] EVs & batteries: for 2025 we need clear policy objectives maintained with more action to build local industries.
Edito
The Green Deal offers Europe the framework to lead in clean mobility. However, realising its full potential requires regulatory certainty, industrial strategy, and people-centred policies, write Kinga Timaru-Kast and Julia Poliscanova.
The European Green Deal, the flagship legislative package of the previous European Commission, has set Europe on a transformative journey toward clean mobility. It gave the continent a framework of what it needs to succeed in this transition. Agreements across the package were reached thanks to strong collaboration among sectors of the clean mobility ecosystem, from industries to civil society organisations. Such cooperation is paramount to ensuring this transition happens swiftly, competitively, and sustainably.
In recent months, the international competition in the e-mobility and batteries value chain race took another dimension. Looking forward to the starting European mandate, three pillars must stay clear in mind of policy makers: regulatory certainty and simplification, industrial strategy, and people-centred policies.
Creating an investment friendly continent
The success of the Green Deal lies in its comprehensive regulatory framework, including landmark measures such as the Battery Regulation, the Alternative Fuels Infrastructure Regulation (AFIR), Energy Performance of Building Directives (EPBD), Renewable Energy Directive (REDIII), and the CO2 Standards for both cars and heavy-duty vehicles, not to mention later acts on critical raw materials and net zero industries. Implementation must now be the focus. These laws will provide the necessary infrastructure, clean energy, supply of clean vehicles, provided they are fully implemented and enforced. Implementation of these acts should come with simplification and streamlining of reporting requirements.
Any regulatory U-turns on the EU’s mobility decarbonisation objectives would destabilise and penalise industries already investing heavily in this transition. Additional, larger, investments into European clean industries are still needed from private sector stakeholders. But no investor will choose Europe without a clear path forward. A commitment to fully implement these measures, including at the Member State level, is critical to maintaining momentum and attracting future investments. Europe’s industries need stability to continue driving innovation and competing globally.
The Green Deal provides a good vehicle but the race on competitive clean mobility remains to be won.
An industrial policy taking full advantage of the e-mobility value chain
Regulatory frameworks must be paired with a robust industrial strategy, focussing on scaling up manufacturing projects and developing EU Green Deal secondary legislation designed to enhance, not undermine, European competitiveness.
Industrial policy needs to include public investment into clean technology – in particular in the entire clean transport value chain, lowering energy costs for manufacturing, and fostering a robust recycling value chain to harness the potential of “urban mines” from end-of-life batteries.
Simplifying permitting processes will unlock great renewable energy potential to decarbonise electricity and lower costs, facilitate the establishment or scale up of manufacturing or material processing sites and the roll-out of clean transport infrastructure.
Finally, Europe must also weigh in to ensure a level the playing field with global competitors in terms of subsidies and support mechanisms. For certain industries, level playing field can only be reached by matching competitors’ support: for examples, for battery manufacturing, the US IRA provides a significant op-ex support per kWh produced; for reskilling workers, massive support for training automotive workers is proposed.
Without these measures, the transition risks stalling under competitive pressures from other regions.
People-centred transition is key
The transition to clean mobility cannot succeed without addressing the needs of Europeans. Providing high-quality and future-proof job opportunities is a first step in including Europeans in the transition.
Europe’s new industrial policy approach must also include upskilling and reskilling programs, so that the European workforce is adequately trained to develop and deploy new technologies and thus ensure that the continent’s industries are future-proof.
Lifting the burden of transitioning and ensuring affordability of clean mobility is a second step. Electric vehicles will become more accessible, and even more so once there is a sufficient second-hand market. Considering that two-thirds of new vehicles are purchased by fleet managers, not by individual drivers, and owned for just three years, corporate fleet electrification mandates would accelerate the creation of a second-hand market by a decade.
Going beyond, technologies like vehicle-to-grid (V2G) and vehicle-to-home (V2H) can empower individuals to actively participate in the energy transition – and remunerate them to do so. Multiplying mobility options, by investing in safe infrastructure for light and actives modes, as well as in public transport and high-speed rail will help a lot more people embark on the clean mobility transition.
In summary, the new legislative mandate needs to go all in on electric mobility and clean tech, including taking it as an EU-wide reindustrialisation strategy brining Europeans along. 2025 will be decisive if the EU Green Deal is set on course to succeed.
As we step into this new year and legislative cycle, let us strengthen these priorities and demonstrate that the EU can not only lead in climate policy, but match it with equally effective industrial leadership. This is essential for Europe’s transformative journey toward clean mobility to deliver on prosperity and sustainability.
A strong European recycling ecosystem for electromobility
Fostering a recycling ecosystem in the European electric transportation value chain is crucial for enhancing the region’s strategic autonomy and for reaching its sustainability goals. Currently, Europe relies heavily on third-country producers for critical materials and components essential to the production of electromobility solutions and their infrastructures. By creating conditions for a strong recycling ecosystem within the e-mobility sectors, Europe can reduce this dependency, ensuring a more resilient and self-sufficient supply chain and reduce emissions associated with the use of primary materials. Providing conditions that enable a recycling value chain in the e-mobility ecosystem will not only help mitigate geopolitical risks but will also strengthen Europe’s position in the global market.
As we support the ambitious recycling targets set in the Critical Raw Material Act, it is now key to enable European industry to reach them. With the right legislative framework, significant progress can be made. Indeed, with numerous legislative ‘low-hanging fruits’ up for grabs, the EU can support its local recyclers. The industry is at a crucial juncture as recycling is poised to ramp up and develop rapidly; it is essential that we seize this moment to establish effective frameworks and practices, ensuring that we get a head-start in global competition.
In this paper, we outline the importance of enhancing the recycling industry in Europe and set out a manual for policy makers to use the existing toolkit of legislation to drive forward such a recycling industry. We recognise recycling is only one element of the broader circularity ecosystem that Europe needs to build for a sustainable transport value chain, however this paper focuses solely on recycling.
Box 1/ Benefits of an electromobility value chain supported by recycling practices
Recycing in the emobility value chain enhances Europe’s strategic autonomy by reducing dependency on imported raw (or secondary) materials, particularly for batteries. By fostering domestic recycling and the use of secondary materials, Europe is increasing security of its value chain. It can mitigate supply chain risks, reduce trade imbalances, and strengthen its control over essential resources, supporting resilience and reduce imports of materials.
Recycling of batteries and material recovery from end-of-life vehicles support material efficiency and thus environmental sustainability by minimizing waste and reducing the need for raw material extraction. This can lead to substantial ecological benefits, including lower carbon footprints and less environmental degradation.
Promoting recycling in the e-mobility value chain can also significantly increase the affordability of clean vehicles. By reducing reliance on primary materials through more effective recycling processes, production costs may be lowered in the longer run, making EVs more accessible to a broader range of consumers.
Recycling also fosters innovation, as businesses invest in new technologies and processes to recycle and repurpose materials, driving economic growth and creating new job opportunities within the green economy. Beyond resiliency, Europe can thus be a proactive leader with a prosperous recycling industry in Europe complying with environmental standards, Europe will be able to set its own, highest, international standards.
Our proposal to leveraging existing regulation to create conditions enabling a recycling ecosystem
Regulatory stability is the bottom-line condition for enabling investments to create circular value chains in the emobility ecosystem. Entrepreneurs and investors require a predictable and consistent regulatory environment to confidently commit resources to the development and expansion of circular practices in the electromobility industrial value chain. Safeguarding the clear, long-term policies already agreed by co-legislators will provide the necessary certainty for businesses to innovate and invest in sustainable production and recycling capacities in Europe. This is particularly true for the CO2 Standards for cars and vans’ 2035 zero-emission objective which needs to be maintained to guarantee that EU-based battery production is used in BEVs that will be sold to meet the zero-emission target by 2035.
A slowdown of the EV market as well as of the battery cells production in Europe creates high investment uncertainty for companies ready to invest into recycling on the continent. Feedstock uncertainty is furthermore increased when the shipment rules to destinations outside of the EU are not clear and not ambitiously implemented and controlled.
In the short term, we do not identify the need for new legislative acts but rather the need to effectively implement and enforce the toolkit of legislations already in the hands of European policy makers and to introduce clarifications or improvements where needed. The following suggestions thus focus on optimising and fully utilising existing legislations rather than creating new ones. Our aim is to ensure that the current regulatory framework effectively supports the development of a sustainable and competitive battery recycling industry within the EU. By making targeted improvements, clarifications or by ambitious implementation, we can leverage what is already in place to support European recyclers to reach our targets.
1. Battery Regulation
Secondary acts implementing the Battery Regulation’s provisions on recycling targets and recycled content should acknowledge the current limitations in local recycling capacity, which may necessitate sourcing secondary materials from outside the EU in the short-term. To change this for the mid and long term, it is crucial to focus on developing dedicated local recycling capacity and processing industry within the EU to ensure sustainability and reduce reliance on external sources. EU legislation should incentivise the uptake of needed recycling technology as regulatory frameworks are key drivers for innovation and large-scale solutions. The calculation of the recycling efficiency and material recovery targets as well as of the recycled content (EU Batteries Regulation) are being currently defined in the delegated and implementing acts which need to set the right condition for the development of a competitive and prosperous batteries recycling industry in Europe. Innovation to new recycling solutions needs to be strengthened, and sourcing of secondary materials within Europe facilitated.
An important element of the Secondary acts implementing the Battery Regulation are the ‘Equivalent conditions’. It is essential and we call on the Commission to deliver in 2025 the definition of the criteria for the assessment of the ‘equivalent conditions’ for waste treatment outside the EU as identified in the Batteries Regulation and Waste Shipments Regulation. How Member States assess the fulfilment of equivalent conditions when such documentation is handed to them by the competent authority of destination where the treatment took place also needs to be clarified. The problem with the ‘equivalent conditions’ when there are no clear criteria for assessment, is that it needs to be “demonstrated that the requirements applied in the country of destination ensure a similar level of protection of human health and the environment” (Waste Shipments Regulation Article 56), which leaves room for interpretation and may be implemented differently from MS to MS.
2. List of Waste Legislation
Currently, the List of Waste (LoW) does not adequately address the diverse chemistries of batteries, lacks a consistent definition of battery black mass across EU countries, and results in varied shipment conditions and costs. This not only creates administrative burdens but also distorts the market in the battery recycling sector and suboptimal material recovery. Addressing these gaps through specific measures can streamline processes and enhance the recycling landscape across Europe.
A rapid formal updating of the list of waste codes and its uniform enforcement, including harmonised transport conditions is needed to significantly facilitate intra-EU shipments, establish equivalent recycling conditions both inside and outside the EU. Member States have a great opportunity to support potential EU recycling players in developing activities to capture battery material recovery value in Europe and prevent these materials from being shipped elsewhere. Addressing issues such as the definition of black mass and harmonizing transport conditions are critical steps that could greatly contribute to this goal.
In this context, the Platform for Electromobility welcomes the Commission’s updated List off Waste proposal. Overall, the definition of the new waste codes is expected to improve clarity and will hopefully foster a homogenous use of the waste codes across Member States, which will contribute to clarify intra-EU shipment.
Introducing a definition for black mass is necessary to ensure that no waste material inadvertently becomes classified as a product. A harmonized definition will facilitate easier intra EU shipment of black mass, streamlining European recycling efforts and contributing to a more efficient European recycling industry. The recent Commission’s updated List off Waste proposal classifies black mass as hazardous waste. We welcome this classification which needs to be rigorously and swiftly implemented across Europe to ensure uniformity and compliance with the latest standards.
Classifying black mass as hazardous waste is a significant step towards securing the feedstock of secondary raw materials in Europe as it will help prevent the export of critical minerals outside the Union to non-OECD countries. This is a crucial step forward to a circular economy but these important amendments to the LoW can only be effective if they are thoroughly implemented. The key role here is with Member State market surveillance authorities that need to do effective border controls to ensure that waste shipments and documents fully comply with this new delegated decision. In addition, the EU’s anti-fraud service (OLAF) must be allocated sufficient resources to monitor, investigate, and prevent illegal exports to non-OECD countries.
3. Waste Shipment Regulation
To foster a competitive waste market, it is essential to ensure the successful implementation of the Waste Shipment Regulation (WSR). This includes the deployment of automated, digital authorisation requests from 2026 onward, which will simplify the handling of hazardous waste and significantly reduce the administrative burden on stakeholders involved in waste management and in inter-EU waste shipment.
4. End-of-Life Vehicle Regulation
The ELVR revision needs to effectively address the illegal export of used EVs and therefore prevent material leakage and further help build a recycling ecosystem. Additional measures are required to enable high-quality recycling of a larger array of materials, especially considering the increasing complexity of vehicles. Similarly to the Battery Regulation, the revision should be leveraged to incentivise the use of low-carbon materials and processes. While we support the introduction of targets for producers and public procurement provisions to increase the use of low-carbon materials such as steel and plastics to drive ever more sustainable EVs, those targets should be accompanied with incentives for producers. Beyond the proposed regulation, we would also welcome incentives for consumers to further drive the market to ever more sustainable EVs.
5. Net-Zero Industry Act
By prioritising local manufacturing, we support NZIA provisions that favour local bids and tying EU and national grants to conditions that promote local labour usage. It could be associated to a label encouraging the use of recycled materials of European origin, including for critical materials (in particular for copper recovered from EV recycled engines which is critically exposed to supply risks).
6. Critical Raw Materials Act
It will be key to prioritise the selection of strategic projects under the CRMA in line with the benchmarks set out in the Act, with at least a quarter of selected projects in the recycling sector.
Conclusion
The CRM Act proposed by the European Commission is a much-needed step in securing the supply of raw materials essential to the EU’s economic and strategic interests. The Act acknowledges the increasing demand for critical raw materials, as well as their limited availability, and aims to establish a comprehensive framework for ensuring their sustainable and responsible sourcing.
However, there are some concerns and reservations that need to be addressed to ensure that the Act is fully effective. First, it must balance the need to secure critical raw materials against environmental and social sustainability, as well taking account of ethical considerations. In addition, it is essential to ensure that the implementation of the Act does not lead to trade barriers or lead to unfair competition that could ultimately harm the EU’s industrial competitiveness.
Careful consideration and monitoring are needed to ensure that the implementation of the CRM Act is effective, sustainable and equitable. By addressing these concerns and reservations, the EU can pave the way for a more resilient and sustainable supply chain for critical raw materials, while upholding its values and commitments.
Box 2/ Investment and Market incentives to support local recycling
Looking forward, new policy initiatives and market incentives to support local manufacturing will be instrumental in developing a resilient and sustainable e-mobility value chain. This can be achieved by:
By translating market incentives into consumer incentives, we can accelerate recycling practices and choices and thus drive the market. This can be done through tax breaks and rebates (e.g., offering tax incentives for best-in-class sustainable batteries in EVs), and Green procurements that prioritise best-in-class sustainable battery products or companies that are frontrunners in implementing the Batteries Regulation provisions.
A joint terminology and standards are at the core of scalability and transparency for market actors. In the case of steel, the quality of recycled steel is different for automotive (very high) compared to construction (low). Defining economy-wide quality standards – or a recycling taxonomy – for steel, aluminium and other products will greatly aid both recyclers and end users by creating a clear market.
Beyond legislation, facilitating investment in local battery manufacturing, recycling and material processing businesses is critical element of the puzzle for establishing a circular economy. Today, such technologies and expertise are not yet mature in Europe. Focus on scale and commercialisation are thus critical, with targeted industrial support and consistent prioritisation across all policy fields. This can be achieved by introducing an EU Green Industrial Fund. The Fund could build on the resources of already existing and scalable EU financing instruments: the EU Innovation Fund and the InvestEU Fund.
Accelerating the deployment of the EU Innovation Fund dedicated battery facility is essential and it should be designed to support best-in-class projects in battery production with a spillover effect on the upstream part of the value chain, helping to foster recycling in the EU. Increasing support from the European Investment Bank for exemplary projects that lead the way in sustainable battery manufacturing and recycling is also important.
[Open letter] Accelerating the electrification of fleets as soon as possible is key to cut transport emissions, increase demand and affordability of electric vehicles
Open letter
To President Ursula von der Leyen
To Executive-Vice-President for the Prosperity and Industrial Strategy, Stéphane Séjourné
To European Commission for Sustainable Transport and Tourism, Apostolos Tzitzikostas
To European Commissioner for Climate, Clean Growth and Net Zero, Wopke Hoekstra
16th December 2024,
Brussels
First of all, we would like to congratulate you and the entire Collège of Commissioners for the Parliamentary approval of the 27th November. We look forward to working together with you and supporting you during the upcoming mandate.
As Commissioner Tzitzikostas rightfully mentioned during your hearing of the 4th November in the European Parliament, the EU action to accelerate fleet electrification represents a golden opportunity to not only tackle transport emissions, the EU’s largest source of greenhouse gas emissions, but also widen access to cheaper second-hand electric vehicles. We therefore very much welcome the announcement in the Commissioner for Transport’s mission letter to “put forward a legislative proposal for clean corporate fleets,” an initiative that Commissioner for Climate views as “a great opportunity to move the needle in terms of climate impact,” as expressed during the hearing of the 7th November. We strongly encourage the Commission to propose a regulation as soon as possible in 2025, ideally as part of the Clean Industrial Deal’s Automotive Action Plan.
6 out of 10 cars sold in the EU are company cars, with those vehicles driving twice as much as private cars. The purchasing decisions of corporate fleets have far wider implications than just for that enterprise. Company cars tend to spend 3 to 5 years in a fleet before going into the used car market. With 8 out of 10 Europeans buying their cars in the used car market, this is a crucial channel for EU citizens.
At the same time heavy-duty vehicles remain one of the challenging segments with the largest potential to decarbonize, with less than 1% of the EU’s truck fleet currently being zero-emission. Electric trucks are gaining momentum rapidly, with costs declining and infrastructure being rolled out. However, without a supporting regulatory framework for big corporate fleets, adoption risks lagging the levels required to achieve the EU’s climate goals.
Accelerating the transition towards electric vehicles beyond existing policies is a necessity to achieve transport’s net-zero and the 2040 climate target of -90%. As such, the faster fleets electrify their company cars, the faster more households and businesses will be able to access more affordable electric vehicles powered by clean European electricity, the faster we can reduce transport emissions. This is a win-win for climate and consumers.
In line with the Mission Letters, Clean Industrial Deal, and the EU industrial action plan for the automotive sector that they mention, a regulation setting binding targets for large fleets is crucial to accompany supply-side policies with strong demand-side measures and thus ensure a successful decarbonation of road transport. We call on the Clean Industrial Deal to include the legislative initiative on corporate fleets.
Corporate fleets are in a great position to lead the way on electrification, with many already committed to fully transitioning their fleets by the end of the decade through Climate Group’s EV100 campaign. On a total cost of ownership basis, electric vehicles have the advantage over polluting vehicles, meaning electrification makes strong business sense too. A clear regulatory framework would simply ensure that all fleets are playing their part while at the same time create investment certainty and clarity for company fleets.
That’s why the Platform for Electromobility, the alliance of land transport industries, NGOs, civil society and cities, and EV100/+, the leading global initiative bringing together fleets committed to electrification, are uniting and calling on you to make this a key priority of your upcoming mandate and come forward in your 2025 Work Programme with a Greening corporate fleet regulation setting binding electrification targets for cars, vans and heavy-duty vehicles.
We would very much appreciate a meeting where we can discuss this initiative. We count on your leadership to bring forward a regulation setting binding zero-emission targets for large fleets.
With kind regards,
The members of the Platform for Electromobility
Prioritising energy efficiency in EU's transport ecosystem
Energy & Infrastructures
The Platform for Electromobility highlights the critical importance of maximising energy efficiency in achieving the EU’s decarbonisation goals. We are collectively worried of the proposal to bring forward the revision of the CO2 Standards for Cars and Vans and the proposal to expand the use of e-fuels, masquerade through a call for “technology-neutrality”. As the European law-makers prepare to review the upcoming amendment to the regulation on CO2 emission performance, we highlight risk such amendment poses to overall energy consumption of the continent.
1. What is energy efficiency in transport?
Energy efficiency refers to the amount of energy, measured in kilowatt-hours (kWh), required to travel a certain distance (kilometers) per passenger. The more energy-efficient a mode of transport is, the less primary energy is needed to be produced for the vehicle to travel the same distance, regardless of the energy’s source—whether it comes from fossil fuels, nuclear energy, or renewable sources.
2. Why is energy efficiency crucial?
Energy efficiency should be a cornerstone of the EU’s energy transition for transport. As transport remains one of the largest consumers of energy, improving energy efficiency directly supports European energy autonomy and security by reducing Europe’s reliance on imported fossil fuels, particularly from politically unstable regions. According to BloombergNEF, favoring energy-efficient transport could save up to 1.5 million barrels of oil per day, equivalent to over €40 billion annually in reduced imports[1].
In addition to strengthening energy security, energy efficiency has direct economic benefits. As energy costs may continue to rise, more efficient transport solutions can help reduce operational costs for businesses and drivers alike. This would make travel more affordable for citizens and improve the competitiveness of European industries.
Furthermore, a key objective of the EU is to increase the share of renewable energy in its energy mix. However, less energy-efficient transport modes would require a unnecessarily increase in renewable energy production to meet demand. It would increase the risk of “Not-In-My-BackYard” movement against such renewable energy plants, and ultimately Europeans’ resistance against energy transition. Prioritising energy efficiency helps maximize the utility of renewable energy and minimize the impact in Europe.
[1]https://about.bnef.com/blog/electric-cars-have-dented-fuel-demand-by-2040-theyll-slash-it/#:~:text=So%20far%2C%20the%20growing%20fleet,far%20off%2C%20arriving%20in%202027.
3. Which transport modes are the most energy efficient?
Among all transport modes, trains are by far the most energy-efficient for long distances[1]. Europe is already a global leader in rail transport, and a concerted push to increase modal shift from road to rail could unlock substantial efficiency gains. We thus support the call to further roll-out of TEN-T as well as plans for an ambitious European high-speed rail network, night train and rail freight. The ecological advantage is especially there for freight transport. On the local level, public passenger transport by metro, tram, bus and urban rail collectively moves large numbers of people, using less energy and emitting less CO2 per passenger-kilometre than private vehicles.[2]
However, passenger cars remain at the center of current political debate. They represent the most widespread form of personal transport and are undergoing major changes amid political debates and upcoming review of the CO2 Standards for cars and vans. When it comes to energy efficiency, not all cars are equal. Energy efficiency among cars varies dramatically, depending on the type of propulsion used. For example, as illustrated by graph 1 above, on the same amount of energy of 15 kWh, similar passenger cars travel very different distances[3]:
- An internal combustion engine vehicle running on synthetic fuels created from renewable energy and climate neutral can travel 20km;
- a hydrogen fuel cell vehicle, running on synthetic fuels created from renewable energy and climate neutral can travel 35km, using the same amount of energy.
- a battery electric vehicle (BEV) can travel 100 km on the same amount of energy, five times more the range of the ICE car.
It is clear that BEVs significantly outperform vehicles powered by e-fuels in terms of energy efficiency.
[1] https://www.iea.org/energy-system/transport/rail [2] In its Urban Mobility Framework (point 2.4), the Commission writes "Public transport such as urban rail, metros, trams, buses, water buses, ferries or cable cars represent the safest, most efficient and sustainable ways for large numbers of people to travel.". There is also a comparison of emissions per mode that includes buses (and coaches) in the EEA Transport and Environment Report 2021 (figure 4.3) [3] Research Center for Energy Networks and Energy Storage
4. Why are they differences in energy efficiency?
Producing e-fuels requires much more energy than producing fossil fuels or using direct electrification when looking at energy use from production to tank. The main issue with e-fuels is their low efficiency throughout the production process. In order for an e-fuel to truly be carbon-neutral, each step—making hydrogen, capturing carbon, and then synthesizing the fuel— needs to be renewable. However, each of these steps require energy and result in large energy losses. This makes e-fuels less efficient in areas where electrification use is possible, especially since electric motors are far more efficient than combustion engines[1].
While a BEV uses 77% of the primary energy to move its wheels, a vehicle powered by e-fuels converts only 20% of the original energy input into motion[2]. The later would thus need about four times more primary energy than the former to travel same amount of kilometres. This large difference underscores the need to prioritise more efficient technologies. Energy efficiency is not a marginal criteria.
Additionally, such an efficiency gain is without counting on the benefits BEVs can have for the energy system if grid-integrated thanks to smart and bidirectional charging, where their batteries can improve the efficiency of the entire energy system. As the making synthetic fuels in itself is already very energy intensive. Each Kwh used for the production of synthetic fuels is one that cannot serve other, more efficient means.
[1] https://www.spglobal.com/_assets/documents/ratings/research/101595057.pdf [2] https://www.transportenvironment.org/articles/e-fuels-too-inefficient-and-expensive-cars-and-trucks-may-be-part-aviations-climate-solution
Which policies can promote most energy-efficient transport?
To ensure that Europe’s future vehicle fleet is as energy efficient as possible, we recommend the following policy actions:
- No U-turn: Any early review or any U-turn in already agreed policy is detrimental for investment confidence in the energy transition.
- Limit the role of e-fuels in CO2 standards: In the upcoming review of the CO2 standards for cars and vans, we urge policymakers to restrict the use of e-fuels to niche markets that cannot be directly electrified, for emergency services, or vehicles of specific usages such as forestry.
- Focus e-fuels on hard-to-abate sectors: Divert the use of limited e-fuels to other sectors where electrification is still not an option and where so much is needed: aviation, long-haul maritime.
- Introduce differentiated taxation: Vehicle taxation should be tied to energy efficiency. Registration taxes, road taxes, and fuel duties should favour energy-efficient vehicles. For instance, a bonus-malus system could be introduced, where less efficient vehicles face higher taxes, and more efficient options benefit from tax breaks. The revision of the Energy Taxation Directive could be instrumental in this perspective.
- Prioritise energy efficiency in public procurement: Public procurement can be a powerful tool to set an example. Green public procurement criteria should prioritize the energy efficiency of vehicles used in the public sector. By including energy efficiency requirements in public tenders, governments can drive demand for the most efficient technologies. The Net Zero Industrial Act already paves the way in this direction.
Conclusion
Energy efficiency is not just a technical consideration, it is a strategic imperative for Europe’s energy security, economic competitiveness, Europeans’ cost of living, and environmental sustainability. By prioritising the development and use of the most energy-efficient transport modes, the EU can reduce its dependence on imported fossil fuels, lower costs for consumers, and ensure that the shift to renewable energy is as efficient as possible.
We strongly urge you to take decisive action in the upcoming CO2 standards review and to adopt policies that will promote the most energy-efficient transport solutions. This is essential to meeting the EU’s decarbonisation objectives and securing a sustainable future for all Europeans.
"Enhancing the resilience of our energy system is crucial and be achieved by optimising the efficiency of our energy use. Electrification plays a key role in this transition: EVs consume significantly less energy than traditional alternatives, while also supporting the grid by offering flexibility and facilitating the cost-efficient integration of renewable energy."
— Anaïs Faucher, SolarPowerEurope
[Videos] Maintaining 2035 CO2 reductions objectives for Europe's industries beyond automotive.
Energy & Industry
What would a revision of the CO2 Standards for cars mean for public transports, renewable energy production, and clean tech's industrial ecosystem in Europe?
Our members Eurocities, European Geothermal Energy Council, and Danfoss, all passed in front of the camera to bring their perspective to what a weakining of the 2035 emission targets would mean for, respectively, consumers interests, renewable energy developmenet, and industrial investments in Europe.
1/ Sanjeev Kumar (EGEC) on importance of cars' CO2 Standards for renewable energy industries in Europe
The synergies between electric vehicles and renewable energy sources are significant. For example, EVs can act as flexible loads and storage units, helping balance and match renewable energy production and consumption. In the geothermal sector, we see an added advantage. Lithium, a critical material for EV batteries, can be produced as a byproduct of geothermal energy extraction. This creates a synergistic relationship between clean energy, e-mobility and European industrial autonomy.
Reopening the CO2 standards would create uncertainty for investors and businesses, not only in the renewable energy sector but also for technologies that enable synergies between EVs and renewables, such as grid flexibility solutions. It could hinder the development of new renewable energy plants and delay the integration of innovative energy systems that are essential for a clean energy future.
If your goal is to decuple the energy demand by four times, then yes, synthetic fuels are the answer. A car running on e-fuels requires three to four times more energy to travel the same distance as an battery electric vehicle. So, if you want to build four times more wind turbines and other renewable energy plants to decarbonise transport, synthetic fuels might seem appealing (ironic). Besides, e-fuels can still be produced using fossil fuels, which doesn’t provide the clarity or investment certainty needed for renewable energy development.
2/ Thomas Lymes (Eurocities) on importance of cars' CO2 Standards for European city dwellers
While electric mobility offers significant benefits, especially when it comes to improving air quality and reducing noise pollution, the revolution won’t happen without strong and stable regulatory framework. The phase-out of internal combustion engines will push us to adopt more diverse, sustainable mobility solutions for urban residents and commuters. Together with a shift towards alternative modes of transport, the phase-out is the missing piece in the puzzle of a sustainable urban mobility.
Reopening the CO2 standards would create uncertainty for both public and private investments in cities. It would wobble the incentive of local authorities in designing and building the clean mobility ecosystems that benefit city residents. Cities mobility plans are build around the promise of a mainstream zero-emissions mobility. The same goes for investments in areas like charging infrastructure, road renovation, power grid upgrades, and smart infrastructure are crucial. Any uncertainty could stall these efforts.
Additionally, this would confuse consumers, delaying their vehicle purchase decisions and postponing the essential decarbonisation of transport in our cities. On that note, large fleet owners have a key role to play. We strongly welcome the announcement of initiatives to clean large corporate fleets as a way to accelerate the shift to zero-emission mobility and make it affordable for the majority of the population.
There’s still uncertainty about the cost of driving with synthetic fuels and whether they truly benefit air quality. We could only consider their use if we can ensure that e-fuels are at least as energy-efficient, clean, and affordable to operate as electric vehicles. Otherwise, they will not represent a viable alternative for sustainable urban mobility.
3/ Bonaldi Da Costa (Danfoss) on importance of cars' CO2 Standards for European clean tech industries
Electric mobility is central to Europe’s industrial future. The 2035 zero-emission cars goal provides a clear and stable framework that attracts investments into sectors like automotive, batteries, and infrastructure. CO2 Standards are actually Europe’s most straightforward clean industrial strategy, helping companies across the continent transition to a net-zero economy. Without this clarity, we risk slowing down investments and innovation needed to develop the net-zero industrial ecosystem.
Reopening the CO2 standards would create significant uncertainty for industrial actors who have already made substantial investments in this transition. It would penalize companies like Danfoss and others in the automotive, battery, and infrastructure sectors who have committed to zero-emission solutions. Attracting further investment is only possible with a consistent and clear regulatory framework, and reversing now would disrupt the progress we’ve made.
We have limited resources to invest in the clean tech revolution—whether it’s for research, development, and innovation or the infrastructure required to support the transition, such as charging networks. And so we simply don’t have the luxury to invest in two parallel value chains: battery electric and synthetic fuels, and their related infrastructures. Let’s focus our effort on tested technologies.
Furthermore, clean e-fuels will be available in very limited quantities, and they should be reserved for hard-to-abate sectors like aviation and shipping. For road transport, battery electrification remains by far the most energy-efficient option. Diverting resources to e-fuels for road transport would slow down the progress we need in more critical areas.