Electromobility Stakeholders' Manifesto Compilation for 2024-2029

EU Elections

Compilation of Electromobility Stakeholders' Manifestos for 2024-2029

A unique document for policy-makers to tackle challenges ahead of us and make electric mobility transition a success for people, climate and businesses.

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Europe’s future, decarbonised mobility ecosystem will be composed by a myriad of stakeholders. To make the energy transition a success, they all present both specific and cross-sectoral needs. All presented in this unique document.

Hereby, we present a unique compilation of the political manifestos from several members of the Platform for Electromobility. It stands as a testament to the collective effort and unified vision driving the advancement of electric mobility across all sustainable modes of transportation; but also showcases the diversity of legislative measures and political steps that remain to be taken for each and every sectors.

Within these manifestos lie the cornerstone recommendations crucial for the development and integration of electric mobility into European societies and economies. They stem from a diverse range of entities spanning industries, associations, NGOs, and local authorities, underscoring the breadth and depth of stakeholder involvement in shaping the decarbonised mobility ecosystem. As we approach the EU elections, this consolidated document serves as an exceptional resource for policymakers and stakeholders alike, providing them with a comprehensive overview of the priorities and aspirations of all the sectors composing the clean mobility system of tomorrow.

Transpiring from all manifestos presented here are cross-sectoral imperatives captured by the triple priority : Implement, Invest, Industrialise. Implement the Green Deal’s legislative measures. Invest to make the Green Deal a concrete reality. And industrialise to make the Green Deal beneficial for all Europeans, climate, people and businesses alike. These overarching goals gathered in the Platform for Electromobility’s manifesto, represent the pillars upon which our collective success rests. I invite you to delve into this compilation and explore the nuanced perspectives and unique contributions of each sector. Each of them is a milestone on the path towards a sustainable, electrified mobility.

Access each individual manifesto for 2024-2029 below.


Platform's statement: PFAS in sustainable e-mobility

Supply chain

PFAS in sustainable e-mobility

In the pursuit of the electrification of the mobility sector for the years to come, it is essential to recognise concerns surrounding certain PFAS use cases and their production, use and disposal.

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The Platform for Electromobility acknowledges the significance and broad presence of Per- and Polyfluoroalkyl Substances (PFAS) in the electromobility ecosystem. PFAS represent a group of artificial/ anthropogenic chemicals with different physical, chemical, and biological properties[1]. PFAS have been widely utilised in most industries for their valuable properties (including resistance to heat, water, and oil) that enhance product performance and safety. However, their production and disposal raise concerns about environment and human exposure[2].

In the context of clean mobility manufacturing, e.g components of electric vehicles of all modes to renewable energy infrastructures, PFAS have played an enabling role. They are  used in sustainable transportation, energy systems and components, such as batteries, wiring, and battery thermal management systems.

In the pursuit of the electrification of the mobility sector for the years to come, it is essential to recognise concerns surrounding certain PFAS use cases and their production, use and disposal. Considering that environmental and human health protection are critical, we are committed to supporting the transition to PFAS-free solutions in the sustainable mobility sector, and would support measures to eliminate all emissions released during the life cycle as soon as viable industrial alternatives[3] are available[4]. Our primary collective objective is to reduce, and where possible, phase out the use of PFAS following the REACH risk management approach across all mobility industries. We advocate for continuous innovation to replace such PFAS application in sustainable mobility.

We outline below crucial points for consideration to the Regulators during the whole restriction proposal negotiation process:  

1. Minimize uncertainties for investors

While Europe has shown its intention to take a global leading role in environmentally conscious battery production, ongoing uncertainties around PFAS use in the battery industry represents a real threat to this nascent and needed industry for the coming years. The PFAS restriction proposal presented by the four Member States and Norway to ECHA is putting investments in Europe into the mobility sector today at risk, while other parts of the world are actively promoting the development of a domestic e-mobility value chain. Uncertainties regarding the duration of the derogation period pose a potential risk of exposing the sectors to a phase-out without adequate alternatives.

We call upon legislators to take a detailed approach ensuring predictability for battery value chain operators while future-proofing the industry from further restrictions.

 

2. Allow appropriate, open-ended derogation periods

The proposed phase-out of PFAS, which does not take into account the long lead times for developing alternatives will likely hinder the deployment of ‘made-in-Europe’ essential sustainable mobility solutions, particularly in uses when no viable substitutes exist. Legislators must recognise that, up to date, some components of e-mobility applications cannot work without PFAS[5], because no viable alternative solutions exist on the market or possible alternatives have been ruled as unviable. In order to avoid disastrous consequences for the battery industry and therefore the e-mobility roll-out, the proposed PFAS restriction requires careful and specific consideration:

We call on legislators to grant appropriate derogation periods for as long as necessary for testing alternatives and bringing them to the market[6] and allow for the use of PFAS where no alternative is available.

Encourage continuous and increased research and development to accelerate the testing and research around possible alternatives.

We also support reducing the scope of the current restriction proposal to exclude applications where no significant emissions happen during the whole life cycle, such as for batteries.[7]

 

3. Consider appropriate tools to increase transparency along the e-mobility supply chain:

Transparency and monitoring requirements could help improve the appropriate capture and destruction of PFAS using complementary abatement technologies and improve depollution standards.

 

4. Ensure consistent and future-proof legislation

Consistency across various EU legislations is key. Upstream, the issue of PFAS should be addressed within the context of Article 6, which pertains to Substances of Concern in the EU Batteries Regulation. Downstream, matters related to the disposal of materials containing PFAS in electric vehicles are currently under discussion in the End-of-Life Vehicle Regulation proposal.

We urge legislators to pay special attention to the issue of legacy substances under the revision of the EU End-of-Life Vehicles Directive.

Any ban on substances must be applied only on new types of vehicles.

 

Subsequent set of policies

Following the above-mentioned principles, we call for adopting the following balanced set of policies, which support  reducing PFAS use where possible, mitigate their impact on the environment and human health, while supporting the energy transition and path towards climate-neutrality:

Encourage and invest in research and development to identify and promote viable alternatives to currently used PFAS in the electromobility sectors

The derogations which will be defined in the European Commission’s restriction for the use of PFAS substances in MAC (Mobile Air Conditioning) should be the same for all vehicles including EVs and combustion engine vehicles with mechanical compressors;

Ensure legislative predictability and science-based principle in chemicals management so that PFAS restrictions do not unintentionally increase the risk of investment diversion in battery manufacturing, potentially shifting operations from Europe to third countries.

Increase transparency and traceability on PFAS presence across the EV value chain, beyond battery production, notably by merging requested information of the Vehicle passport as proposed in the ELVR and the Battery passport behind a single QR Code.

It is imperative to foster sustainable and viable alternatives to PFAS in a balanced approach to align with the EU’s wider objective of accelerating a  sustainable and resilient clean mobility sector.

[1] https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/terminology-per-and-polyfluoroalkyl-substances.pdf

[2] The PFOA, a sub-group of PFAS, have notably been included in recent WHO classification as group one carcinogen (IARC Monographs evaluate the carcinogenicity of perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) – IARC (who.int)). Resulting from this, PFOA have been already globally regulated and phased out. They are not in the scope of this document.

[3] Industrial viable alternatives are defined as innovations that have been tested, approved and scalable, ready for mass-market applications.

[4] Regarding vehicles, only new types should be concerned by the upcoming restrictions.

[5] https://rechargebatteries.org/wp-content/uploads/2023/09/FINAL-SECOND-SUBMISSION-.pdf

[6] ready for mass-market applications

[7] ECOS have decided to dissociate from other members of the Platform for Electromobility and not to support this last specification.


Open Letter to Prof. Draghi and EU Heads of States on EU Competitiveness Strategy

Open letter

Platform Chair: Prioritizing EU Competitiveness in the Transport Sector

to Prof. Mario Draghi and EU Heads of States

Our open letter on industrial strategy

Industrial competitiveness will be high on the agenda of the Special European Council of 17th and 18th April in Brussels. It has lately tended to overshadow sustainability. We, members of the Platform for Electromobility, a unique coalition of industries, NGOs, and civil society organizations committed to advancing electric mobility across all modes of transportation in Europe, firmly believe there can be no industrial competitiveness without sustainability. The Green Deal has set the course. It is imperative to implement it swiftly and continue in that direction.

The EU does need an industrial strategy to ensure its businesses can complete the transition as planned. In our latest publication, “A 360° e-mobility industry strategy“, you will find five recommendations we believe should be a priority of the next strategic agenda:

  1. Ensuring regulatory stability for industries and investors. This means first and foremost ensuring that the European Green Deal legislations as voted in the 2019-2024 mandate remain steady over time.

  2. Enhancing value chain competitiveness and resilience. European industrial policy initiatives should see their focus widened from specific components to a more comprehensive approach, spanning from raw materials to end products and from individual to all modes of sustainable transportation.

  3. Financing the short-term transition through accessible opportunities. Existing EU funds can already serve as valuable assets if they are distributed efficiently and intelligently, notably by streamlining access to finance, particularly for net-zero industries, through instruments such as the Innovation Fund and InvestEU.

  4. Establishing a Net Zero Investment Plan for long-term financing. The STEP platform, although welcomed, unfortunately far from the pan-European response to global competition on cleantech that the EU needs.

  5. Strengthening international cooperation. Strengthening ties with diverse regions would diversify sources, reduce geopolitical risks and uncertainties, ensure a secure supply chain, enhance global industrial collaborations, and uphold a fair competitive environment for all clean transport industries.

We urge the European Council and the upcoming report of the future of European Competitiveness to recognise that industrial competitiveness and sustainability are intrinsically linked and cannot go one without the other. Hoping that our recommendations will help shape the policy priorities of the upcoming EU legislative cycle, we stand ready to contribute to the discussions further.

Céline Domecq
Chair of the Platform for Electromobility, 2024


Five steps towards a 360° e-mobility industry strategy

EU Industrial Strategy

Our recommendations for a “Green Deal Industrial Plan”

Any “Green Deal Industrial Plan” would not be complete without a strong chapter on the electromobilities manufacturing ecosystem.

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In the context of the forthcoming EU legislative mandate, the Platform for electromobility endorses the overall shift in European policy priorities set by the European Green Deal as a welcome long-term compass. Recent institutional declarations[1] aligned with Platform’s EU Election Manifesto[2] support  the development of a robust industrial policy. This is essential to ensure Europe’s competitiveness, resilience in a rapidly evolving global landscape, and maintain its leadership in climate change mitigation. Any “Green Deal Industrial Plan” would not be complete without a strong chapter on the electromobilities manufacturing ecosystem. To achieve these goals, we propose a multifaceted approach that considers the entire value chain’s competitiveness in green transport solutions while revitalizing their financial support. Such policies must be implemented within a framework of regulatory stability and close international cooperation with other regions.

We will set out these proposals below under 5 headings:

  • Ensuring regulatory stability for industries and investors
  • Enhancing value chain competitiveness and resilience
  • Financing the transition in the short term: the “low hanging fruits”
  • Financing the transition in the long term: Net Zero Investment Plan
  • Strengthening international cooperation

We welcome questions and cooperation with the Platform for Electromobility on our proposals.

1. Ensuring regulatory stability for industries and investors

A stable regulatory system is crucial. Attracting investment to create the net-zero industrial ecosystem for electromobility will be facilitated by maintaining a consistent, clear regulatory framework and climate objectives. This means first and foremost ensuring that the European Green Deal legislations as voted in the 2019-2024 mandate remain steady over time. We strongly warn against disruption of the Green Deal and their long-term planning notably by limiting the scope of major reviews. At a more granular level, we call for stability in the regulatory frameworks of all transport modes. It is a key element for successful risk management. A consistent, clear regulatory framework secondly means performing sound impact assessments before proposing new legislation. Potential legislations should be in line with the direction taken by the Green Deal as voted during this mandate. Thirdly, regulatory stability means  focus on proper implementation through the swift adoption of all necessary complementary acts In a nutshell, implementing before reviewing.

2. Enhancing value chain competitiveness and resilience

a. A 360° e-mobility industry strategy

While recent European industrial policy initiatives, such as the Net Zero Industry Act (NZIA), have focused on key components and sub-systems[1], we have observed that an emphasis and consideration of full value chain competitiveness is lacking. It is crucial that these policies take into account the comprehensive nature of mobility industry value chains across sectors and support their global competitiveness as they navigate the green transitions. We call for a 360° e-mobility industry strategy, widening the focus from specific components to a more comprehensive approach, spanning from raw materials to end products and from individual to all modes of sustainable transportation.

B. Upstream and downstream

While the presence of gigafactories is fundamental for the development of green industries in Europe, with production capacity on some parts of the value chain (so far mostly focused on end products), it is important to highlight that they alone do not guarantee a competitive and non-dependant industry[2]. Indeed future industrial policy should go beyond the end-product and also consider upstream (refining) and downstream (recycling), both sectors being, so far, not located in Europe. A European industrial network of innovative companies from all sizes would help securing all stages of e-mobility value chains for the manufacturing and recycling of key components. The EU should channel purchases toward “made in Europe” products and increase production chains within Europe. Given the high demand for strategic raw material to manufacture electric vehicles, securing the value chains also includes a strong focus on security of supply of such materials and other available alternative technologies, as well as the recyclability of engines and batteries.  The creation of new industrial hubs in Europe should go hand-in-hand with this strategy.

c. Energy-cost efficient strategy

Energy costs play an integral part of manufacturing competitive transport solutions. The availability of affordable, decarbonised energy is paramount to maintaining Europe’s competitiveness in the global low-carbon technology competition. We ask policymakers to work urgently on mitigating electricity prices disparities between the Union, China and the US, which are severely disadvantaging EU manufacturers. We endorse other calls[3] for the introduction of incentives that reward low-carbon technology producers favouring local materials and components.

d. Public procurement driven sectors

Similarly, for mobility sectors where investment decisions are predominantly the responsibility of public authorities, such as rail, the relevant EU legal framework must be properly enforced. That starts with public procurement, ensuring that tender evaluation criteria set the right focus on the sustainability of the selected solutions but also include all available tools to ensure fair competition, such as the foreign subsidy regulation. We strongly support the NZIA’s non-price criteria proposal in public procurement supporting sustainable development and resilient European industries. Those criteria will help favour European industries in public auctions and ultimately promote technologies produced in Europe.

e. Accompany workers and employers in skills transition

Industrial sectors must be supported in their skills development and employment policies for a successful decarbonisation of its values chains. For this purpose, EU institutions and Member States should undertake a mapping of skills shortages. This should consider both traditional and new skills. That way, we can assess the needs for jobs and skills in each sector, developing tools to identify and publicise available training, and highlight those that need to be created. Based on the identified needs, measures should be undertaken by the EU – such as NZIA’s initiative for “Net-Zero Academy” – and the Member States to support existing training structures in Member States as well as to ensure that the trainings are conducted by practitioners from companies.

3. Financing the transition in the short term: The “low hanging fruits”

Existing EU funds can already serve as valuable assets if they are distributed efficiently and intelligently, notably by streamlining access to finance, particularly for net-zero industries, through instruments such as the Innovation Fund and InvestEU. To do so, we have identified five “low-hanging fruits” measures that can be taken without further delay:

  • Low hanging fruit 1: Guarantees. As a matter of priority, public investment tools should crowd in private investments by increasingly making use of instruments like guarantees. Firstly, the InvestEU Fund should be further mobilised in support of a 360° e-mobility industry strategy. Secondly, the European Investment Bank (EIB) Group should strengthen the provision of commercial bank guarantees for investments by companies across the EV value chain, replicating the recently announced €5 billion guarantee facility for the wind sector[1].
  • Low hanging fruit 2: Innovation Fund. We welcome the recent initiative under the Innovation Fund to dedicate €3 billion to the EV battery value chain. This new mechanism needs to focus on the most sustainable EU battery and components manufacturers[2]. A robust mechanism needs to be built, including for channelling increased funding from Member States to match EU funding.
  • Low hanging fruit 3: Capacity building. To enhance accessibility, we propose that EU or national administrations train and appoints specific staff to provide advisory services to both applicants and national authorities responsible for distributing EU funds. A substantial portion of these funds, especially in the case of Recovery funding, may remain unallocated due to the constrained administrative capacity of Member States[3] to prepare projects or process applications. Supporting project preparation and speeding up authorization procedures at the national level would thus benefit both the applicants and the authorities involved.
  • Low hanging fruit 4: Mid-term MFF revision. The mid-term revision of the MFF is the opportunity for European institutions and Member States to significantly raise funds of strategic programmes (STEP but also CEF) to provide appropriate financing instruments to support a competitive decarbonisation of the EU industry and support investments in clean, sustainable mobility solutions.

3. Financing the transition in the long term: Net Zero Investment Plan

a. Why a Net Zero Investment Plan now?

The climate investment gap is deepening by the day and the way to fill the gap will be a major challenge for decision-makers in the coming years. European elections are the democratic the window of opportunity to set priorities about where EU funds should flow and the level of support that EU will provide to shift the continent to clean mobility. 2024 is thus a milestone year for the green transition. The STEP platform is, although welcomed, unfortunately far from the pan-European response to global competition on cleantech that the EU needs. Therefore, we support the creation of a major Net-Zero Investment Plan after the EU elections.

b. Predictable and upfront support for op-ex

The EU should ensure that financial instruments do not exclusively prioritise innovation but also consider the importance of providing strategic support for operating expenses and production, for a limited duration. We highlight the fact that operational expenses (op-ex) are not covered by the current InvestEU funding framework. This means that in addition to promoting innovation, financial support should be directed towards sustaining and optimizing day-to-day operations and the production processes of net-zero industries, thereby creating a more balanced approach to funding allocation. Beyond deciding the level of support that will be provided to the green and digital transition of the transport sectors, upfront predictability and certainty about possible funding should also be provided. A rulebook for financing should make sure op-ex support is both predictable and upfront.

c. Consider ventures with higher risk profiles

To complement this new approach and move closer to a truly comprehensive funding allocation, it’s essential to also consider ventures with higher risk profiles. For instance, when it comes to the Alternative Fuels Infrastructure Fund, the current financing terms are notably stringent. These terms often exclude high-risk endeavours, as they require a minimum of 50% funding from national banks or partners, effectively limiting opportunities for investment in riskier projects. This, in turn, disproportionately affects emerging industries and initiatives in Central and Eastern Europe. To address this issue, the European Investment Bank (EIB) should explore investments in riskier ventures, and InvestEU should be equipped to provide loans and equity for such undertakings. The InvestEU Program, designed to offer guarantees to both public and private banks, can play a pivotal role in enabling them to take more substantial risks in their lending and equity operations. This approach can facilitate the inclusion of ‘investments in riskier ventures’ and contribute to a more diverse and dynamic investment landscape.

d. How to finance a Net Zero Investment Plan?

This Net-Zero Investment Plan should be structured under the EU Multi Financial Framework on the one hand, and via new bond issuance programme replacing the Next Generation EU programme on the other hand. In addition, this broader investment plan should ensure that sufficient European and national funding resources, leveraging private sector investment, are available to achieve Europe’s objectives as set in the Climate Law and in the Smart and Sustainable Mobility Strategy. On top of the achievement of dedicated programs such as the TEN-T, it should include a dedicated Green Industry fund. State Aid measures should be re-designed and local supports coordinated at EU level to ensure a level playing field at European level,. The future State Aid regime should mandate EU governments to integrate environmental and social considerations to their support schemes, so that only best-in-class projects benefit from public support at regional and national level.

5. Strengthening international cooperation

Stability also requires robust international cooperation. Strengthening ties with diverse regions would diversify sources, reduce geopolitical risks and uncertainties, ensure a secure supply chain, enhance global industrial collaborations, and uphold a fair competitive environment for all clean transport industries.

  1. Proactively setting a Level Playing Field

The EU response to other regions’ recent green industry support program should be prepared with care, to avoid provoking a global subsidy race. The goal should be to create an international level playing field between all economies, aimed at reaching Paris Agreement climate targets (COP21) together and aligned on WTO rules. 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. We call for EU policymakers to match such support in some manner to help its European battery industry compete on more equal terms. Without such matching, there can be no global level-playing-field for e-mobility related manufacturing.

  1. Cooperation to avoid trade disruption

With several studies by the OECD[1] highlighting the challenges faced by European railway producers in the Chinese market, as well as the public assistance received by their companies, the question of China’s undisclosed subsidies benefiting its products is not new for the railway industry. Cooperations should be reinforced to ensure there are no such practices risking unbalancing global competition.

  1. Cooperation to diversify sources

Dependence on one single third country for green transport technologies is tangible[2] and should also be mitigated. China dominates the production of solar panels, batteries for EVs and part of the world trade in wind turbines. To diversify sources, we support proposals to form a green technology partnership between governments and businesses of the major economic powers to reduce strategic dependencies. Such partnership would be intended to complement, not replace, existing supply chain. Beyond cooperation with third countries, cooperation should also be within European countries and industrial partnerships to multiply joint purchases and thus secure supply of strategic raw materials at advantageous prices.

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[1] President von der Leyen’s State of the Union, European Commission’s Work Programme. Executive Vice President Sefcovic’s speech at Environment Council. [2]2024-2029: Five years to make e-mobility transition a success”, Platform for electromobility, September 2023.

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[1] A "sub-system" refers to a specialized and interconnected set of components that collectively perform a specific function within the overall system.

[2]How to Meet the Industrial Challenge of Electric Mobility in France and in Europe?”, Notes de l’Ifri, Ifri, November 2023.

[3]Call for EU Clean Industrial Deal and urgent actions to keep Europe in the world’s clean technology race”, Eurofer, October 2023.

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[1] Press Release, EIB, December 2023

[2] Press Release, European Commission, December 2023

[3]How Europe should answer the US Inflation Reduction Act”, Bruegel, February 2023

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[1]Measuring distortions in international markets: The rolling-stock value chain”, OECD, February 2023

[2]De-risking and decarbonising: a green tech partnership to reduce reliance on China”, Bruegel, October 2023.


[Video] Charging Infrastructures: A perspective on 2024 by Jayson Dong


Our five recommendations to CO2 Standards for trucks and buses trilogue negotiators

CO2 Standards for HDVs
Our recommendations to trilogue negotiators

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The members of the Platform for Electromobility welcome the position adopted in November by the European Parliament on the revision of the CO2 Standards for trucks and buses Regulation. Welcomed overall, the text provides a robust and ambitious yet realistic and business-friendly path toward decarbonisation of road transport in Europe. Ahead of trilogue negotiations, we hereby highlight key elements that negotiators should keep in mind to safeguard the Regulation’s added value

1

First and foremost, we urge negotiators to reach a conclusion before March 2024 to avoid losing one year in our collective fight against climate change. Considering the deadline of the text, a late agreement would delay its application by a full year, hence jeopardising our joint effort to reduce CO2 emissions and reach net-zero society in 2050. A timely resolution is paramount to providing certainty to the truck and bus industries, its customers as well as adjacent infrastructures and energy industries, enabling them to plan and invest in the necessary innovations for compliance.

2

Industrial certainty and environmental progress are also jeopardised by a potential loophole that could open the way for unrealistic use and expectation of e-fuels and biofuels. Both alternative fuels solutions are inherently inefficient[1] and should remain out of the CO2 standards. Renewable and low carbon fuels and, most notably, e-fuels will not be carbon-neutral in time to decarbonize the road transport sector and meet our climate targets, and as a result should be limited where direct electrification is not feasible, namely in maritime and aviation sectors. These fuels are scarce resources sorely needed to reduce greenhouse gas emissions in the aviation and shipping sectors, whereas the road transport sector is well-suited for electrification. They do not provide a viable alternative to existing zero-emission solutions. In addition, e-fuels aren’t currently produced at commercial volumes. Scaling up additional renewables, electrolysers, direct air capture (DAC) and e-fuel production facilities would take time and larger e-fuel quantities would likely not be available before 2040.

3

Thirdly, considering that in 2022 30% of new buses in Europe were already zero emission, an urged confirmation of the 100% Zero Emission mandate target at 2030 for urban buses, with no postponements, is an optimal option, notably with the move of the two subcategories of urban buses, namely class II low-entry (i.e. 31L2 and 33L2) into the coach segment, as they are often used by local and regional authorities for longer distance public transportation. While reducing the CO2 emissions of those groups of vehicles, this choice would also bring substantial public health benefits by lowering the amount of particulate matters (PM) emitted.

4

Fourthly, we praise the European Parliament’s extension of the emission debts and crediting system from 2030 to 2040 gives additional flexibility to manufacturers to earn credits (when reducing emissions more than required) and use them to offset debts (if emissions are above what is required). Credits now can be used for 15 years to offset debts. Credit’s lifetime should have a maximum of 5 years as do the debts. This would force manufacturers to continuously invest in reducing their CO2 emissions. This mechanism is pivotal in encouraging industry players to adopt sustainable practices and contribute meaningfully to the reduction of greenhouse gas emissions.

5

 Platform members also recognise the positive impact a fleet mandate mechanism would have on the decarbonation of heavy-duty vehicles. On this point, Platform members equally stress the importance of support mechanisms for the rollout of office-based charging, from subsidies to tax discounts.

With a timely conclusion, unequivocal standards without place for questionable alternative fuels, the strongest ambition on decarbonization of urban buses, an ambitious definition of zero-emission heavy-duty vehicles and fit-for-purpose emission debts and crediting system, the CO2 Standards for trucks and buses would truly be the regulatory framework that promotes sustainability, innovation, and the accelerated adoption of zero-emissions road transport.

[1] Estimates indicate that the electricity requirements for the production, transportation, and distribution of various e-fuel types are significantly higher, ranging from approximately 1.6-1.8 times greater for compressed gaseous hydrogen to between 2.2 and 6.7 times higher for liquid e-fuels, in comparison to the direct use of electricity, depending on the specific fuel type. When we account for not just the fuel production phase but also the efficiency losses within the vehicle powertrain during e-fuel usage, the overall efficiency diminishes even further.