CO2 Standards for trucks and buses: our reaction

Recommendation paper of the Platform on the revision of the HDV CO2 emission standards following the Commission’s proposal

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The Platform for electromobility very much welcomes the proposal by the European Commission for revision of the CO2 standards for heavy-duty vehicles (HDV) and sees the regulation as a fundamental tool to electrify trucks and buses and thus advance the rapid roll out of zero emission vehicles (ZEV) in the road heavy transport sector. Currently, trucks and buses together make about 27% of the EU road transport emissions and trucks make up more than three quarters those. The proposal of the Commission for the revision of HDV CO2 standards falls short to align the CO2 targets for the sector with the EU’s overall -55% GHG reduction target in 2030 and the climate neutrality target of 2050.

In order to transition the road freight sector to zero emission, more ambitious standards are needed to set the right pace and a clear trajectory for manufacturers, logistics operators as well as for the supply chains in the electromobility and automotive industry. Scaling effects in production and technology development in the e-mobility and transport sector contribute to making electric HDVs more competitive and widespread.

Uniting ambitious green supply-side policy making with investments into cleantech industries, as done with the Net Zero Industrial Act, allows Europe to remain a climate leader whilst paving the way for thriving industries. The Platform calls on the European Parliament and Member States to notably strengthen the targets of the HDV CO2 standards, reducing emission, air pollution levels and setting pace for a greening road transport sector.

     The ambitious charging infrastructure targets as finally adopted in the AFIR enabler a successful rollout of ZEVs. Additional private as well as public investments are needed to ensure higher grid capacity to serve the growing trucks and buses charging demand. The revenues from excess emission premiums should be channeled back into the sector for the roll out of the infrastructure network.

Investing in reskilling of workers is essential for both, those currently employed in the HDV manufacturing and therefore see a conversion of current skills, and new ones who will be increasingly specialized in new production value-chain. It can reduce social risk and increase labour resiliency. Other measures such as job-search assistance to jobseekers and income and early retirement support could make the transition more “just”.

The positive effects of electrifying trucks and buses are far-reaching and go beyond reducing Europe’s GHG emissions – accelerating the zero emission HDVs roll out also allows to drastically improve noise and air pollution. The high increase of energy efficiency in the case of BETs is particularly beneficial when road transport accounts for 29% of the EU’s final energy consumption[1]. The Platform for electromobility also wants to highlight that the transition to electric trucks and buses is a considerable opportunity for the European e-mobility value chain and the competitiveness of the economy. Ambitious targets would make Europe a leader in zero emission HDVs and thus further unlock the potential of the e-mobility value chain.


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Weight & Dimensions Directive: the hidden milestone for e-trucks

Six points to make the Weights & Dimensions Directive
better incentivize zero emission trucks and buses

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The Heavy Duty Vehicle (HDV) segment needs to accelerate its decarbonisation. In 2022, battery electric heavy trucks made up only 0.6% of new truck registrations in Europe. Diesel  represented 96.6%[1].

Buses are decarbonising much faster, as new urban bus sales in 2022 saw a higher share of zero emission vehicles – 30%. Diesel buses represented 67.3% of the new sales in Europe[2].

While the CO2 standards for trucks and buses are important in setting decarbonization targets for the HDV sector, they will not solve the issue of incentivizing Zero Emission (ZE) trucks and buses.

ZE trucks will be able to benefit from mandatory toll discounts under the Eurovignette directive and the expansion of ETS to road transport. Currently, ZE trucks benefit from a minimum tax on diesel, and a weight allowance of 2 tonnes more than a diesel truck. As zero emission vehicles weigh more than diesel-powered vehicles due e.g. to the battery weight, the additional weight allowance is a must-have measure for decarbonizing the HDV segment.

Even though the additional weight allowance of 2 tonnes is a good starting point, there are additional measures that can help the uptake of ZEHDVs, which has so far been limited. The proposed revision of the Weights & Dimensions Directive (WDD) provides an excellent opportunity for non-monetary incentives for zero emission trucks and buses in Europe. The European Commission should focus on the following measures:

  • Implement clear cross-border rules
  • Modify the methodology governing the additional weight allowance
  • For long-range ZE trucks, permit one further tonne, linked to range, to a max of 3t
  • Allow ZEHDVs a time-limited increase in the maximum authorised drive axle weight
  • European Modular System (EMS) should be zero-emission by 2028
  • Set explicit time limits for WDD transposition and type-approval

  • Implement clear cross-border rules

As it stands now, the WDD enables the additional weight allowance only at border crossings of 13 EU Member States as the weight allowance only applies at borders of countries that have the lowest authorised vehicle weight. Furthermore, it does not provide an incentive for ZE HDV activities at the national level.

The current WDD has led to disputes between Member States on the allowed weight of HDVs on border crossings. In order to avoid any new disputes and remove the existing ones, the EC should develop rules that apply to the entire EU and not to selected border crossings.

The Benelux countries have done exactly that in 2022[3]. Although Benelux countries have different authorised weight allowances, when freight vehicles cross borders, the lowest weight limit in both countries is applicable. And for zero-emission vehicles, the additional weight allowance is automatically added.

Therefore, the European Commission should expand the scope of the WDD and clearly define that:

  1. The lowest authorised weight limit at border crossings is equal to the lowest authorised weight limit between two adjoining Member States;
  2. That the additional weight allowance for ZE HDVs is automatically added to the lower authorised weight limit;
  3. The additional weight allowance applies also for national transport.
  • Modify the methodology governing the additional weight allowance

In practice, the current system requires the vehicle-maker to present a diesel comparator, with up to 2 additional tonnes then allowed above the weight of the comparator vehicle.

This system causes issues for new ZE vehicle-makers, which by definition, don’t have comparator vehicles to reference.

The WDD revision should grant some flexibility to new entrants by saying that the relevant authorities must have due regard to the position of new entrants in the selection and assessment of comparator vehicles.

  • For long-range ZE trucks, permit one further tonne, linked to range, to a max of 3t

Up to ranges of approximately 400km, the additional 2t already granted is sufficient. Beyond this range, however, the allowance should be increased according to greater range provided. We suggest 2.5kg per km of ZE certified range above 400km to a maximum of 3t (i.e. the maximum is reached at 800km).

  • Allow ZEHDVs a time-limited increase in the maximum authorised drive axle weight

The change most sought by truck and bus-makers is an increase in the maximum authorised axle weight placed on the axle connected to the zero emission powertrain, more commonly known as the drive axle. Today the weight limit applied to the drive axle is 11.5t, and due to the higher weight of ZE powertrains (e.g. batteries), truck and bus-makers ask that this limit be raised to 12t. This ask concerns two-axle tractor units and buses in the EU, which are the most-sold configurations.

On the one hand, such a change would boost the pace and scale at which zero-emission trucks and buses are deployed. On the other hand, without safeguards and phase-down dates, it could increase road wear.

Therefore, we advocate considering this change on the basis of a number of safeguards covering:

  1. tyre configuration and maintenance;
  2. the speed at which such vehicles can take off from a stopped position (“acceleration from rest”); and
  3. timeframe, namely that ZE truck & bus-makers can deploy 12t drive axles – under certain conditions – until a certain year (2029 for trucks).

Taking each of these in turn, for a qualifying vehicle, it would be necessary to deploy:


  • On the steer (front) axle, wide base high-efficiency tyres
  • On the drive (rear) axle, dual tyre configuration (assembly) using high-efficiency tyres
  • A Tyre Pressure Monitoring system that alerts the driver to a loss of pressure any greater than 0.5 bar, and with a duty to restore pressure to recommended levels at the nearest available facility having regard to the direction of travel

Acceleration limiter

  • Ensuring take-off-from-rest is between 1 and 1.2m/s2


  • 4×2 ZE trucks registered from entry into force [in ~2026] to 1.1.2029 can carry 12t on the drive axle – once the above conditions are met
  • More flexibility on the end date could be considered for buses (and coaches) given their smaller sales numbers.
  • European Modular System (EMS) should be zero-emission by 2028

There are calls across the trucking sector for more opportunities to use EMS. However, it can only be guaranteed that EMS will reduce emissions if the trucks are ZE. Therefore if proposals are made to permit cross border EMS, it can only be by ZE trucks, and where each route is checked and approved by the relevant authorities for road safety (i.e. that approach roads used to access the highway are suitable for EMS movement) and freight modality (coherence with overall freight policy goals).

  • Set explicit time limits for WDD transposition and type-approval

The WDD does not have a formal time limit for transposing the existing 2 tonnes weight allowance into national law. This needs to be done as soon as possible as the business case for long-range zero emission HDVs depends on clear rules across Member States.

As the previous transposition of weights and dimensions rules to type approval law took four years, it is important to set a stricter deadline. This will enable manufacturers to achieve the recently proposed HDV CO2 reduction targets.

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Critical Raw Materials Act: Reaction paper of the Platform for electromobility

Critical Raw Materials Act :

Reaction paper of the Platform for electromobility

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The European Commission’s proposed Critical Raw Materials Act is a much-needed initiative in today’s world. Demand for critical raw materials (CRMs) will continue to increase, in order to underpin a sustainable transport system in the near future. Indeed, the proposed Act aims to ensure the sustainable supply of those CRMs essential for electric mobility-enabling sectors, electric cars themselves and renewable energy technologies. We particularly welcome the Act’s efforts to balance resilience, security of supply and environmental protection with the new focus on refining and remining, which are crucial steps in producing and securing CRMs. ‘Refining’ refers to the process of purifying raw materials, which can reduce the waste and environmental impact of their extraction. ‘Remining’, meanwhile, involves the extraction of raw materials from the waste or by-products generated during the production process or from legacy mining sites.

Furthermore, the Act also stresses the importance of the responsible extraction and processing of CRMs. This includes promoting the use of new and innovative technologies for reducing the environmental impact of extraction and processing activities. By adopting these measures, the European Union (EU) can lead the way in sustainable mining practices, while also ensuring the ongoing availability of critical raw materials for the production of high-tech products. These measures will also help reduce the dependency of the EU on raw materials sourced from outside its borders, thereby ensuring a stable, sustainable and secure supply of these much-needed CRMs.

For these reasons, the CRMs Act proposed by the European Commission is a generally welcome initiative, one which can help ensure the sustainable supply of critical raw materials. However, the following addition improvements, proposed by all members of the Platform for electromobility, from NGOs to industries, should be considered by co-legislators:


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.

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EUSEW Session: "Upskilling the EU’s industrial workforce to create clean energy systems for electric mobility"

All about the event and the skills for the transition

Slides of the speakers

Download the slidedeck as presented  by the speakers during the event.

Our recommendations

Our recommendations to make the transition to electric mobility a social success story

BCG Study

Download the BCG Study presented in the introduction and refered to during the debate.

Want to know more?


 16.30 – Welcoming

Théo Fievet - Coordinator, Platform for electromobility

16:40 – Panel discussion

Eric Feunteun, Ex. Vice-President, Software Republique

Tzeni Varfi, Principal, E.DSO

Patrik Kristanski, Chair of the Slovak Electric Vehicles Associations

Federic Fucci, Policy Officer at EuropeOn

Alex Keynes, Manager at Transport & Environment

17:30 – Discussion with audiance


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Between 2021-2030, 42% of employees in the energy and mobility sectors will need training to assist Europe’s transition to a zero-emission mobility ecosystem. How best to achieve this for both workers and employers?


Smart, clean Energy and Electric Vehicles for the city




Leicester - Loughborough - Kortrijk - Amsterdam - Oslo


Jan. 2020 / Dec. 2023



Hogeschool van Amsterdam - City of Amsterdam - Amsterdam Arena - KU Leuven - Cenex - Leicester City Council - Northumbria University - Olso Kommune


Main questions

The core of the SEEV4-City project is making a huge step forward in green city development by a smart combination of electric vehicles, renewable energy sources and ICT solutions.

Main findings

The operational pilots will exhibit the V2G potential at different scales, and aiming for the same three goals:

  • An increase in energy autonomy.
  • An increase of ultra-low emission kilometres.
  • Avoiding extra investments to make existing electrical grids compatible with an increase in electro mobility and local energy production.


Interreg North Sea Region - European REgional Development Fund

Emilia Valbum (3M) explains the Critical Raw Materials Act

Critical Raw Materials Act
The Platform's position introduced by Emilia Valbum

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Why does Europe need a Critical Raw Materials Act?

Emilia: It is true that some Raw Materials exists in Europe, but we still remains way too dependent on third countries for mining, processing, refining and recycling. Those processes are very much done in resource-rich third countries, which more experienced and more competitive. This is endangering both Europe’s autonomy in CRMs but also the respect of our environmental standards.

And the current geopolitical events and supply chain tensions increase this dependency. But also create volatility, higher prices and uncertainties over global supply. This is why we welcomed on principle Commission’s Act.

Three clear flaws for Europe on CRMs

Emilia: We urgently need to ramp up a domestic Electric Vehicle value chain if we want to reach our climate goals. On this path, we identified three obstacles:

First, Europe should look beyond battery manufacturing to ensure access to resources themselves, and create capacity to refine, process, and recycle those resources.

The second flaw is the excessive hurdles to the permitting that can become counterproductive to defend social and environmental protection. And third obstacle is Europe’s incomplete and limited mapping of geological and remining potentials.

What are the solutions?

Emilia: At the Platform we identified twelve areas where we think the Act should change things up. I won’t cover them all now but a large part of the solution is to remove barriers to the reuse and repurposing of EV parts, which could extend the lifespan of critical raw materials prior to recycling, thereby reducing the overall demand for CRMs. I invite everyone interested to have a close look at our details recommendations.


cleanmobilenergy logo

Clean mobility and energy for cities




Arnhem (NL) - Nottingham (UK) - Schwäbisch Gmünd (DE) - Stuttgart (DE)


2017 - 2022


POLIS - Luxembourg Institute of Science and Technology - Centre of Excellence for Low Carbon and Fuel Cell Technologies - Europäisches Institut für Innovation - Technologie e. V. - Nottingham City Council - Walvoorzieningen Nederland B.V. - Institut d’aménagement et d’urbanisme de l’île-de-France - Cenex Nederland - eflow Europe GmbH


Main questions

Across North West Europe, cities are increasingly investing in renewable energy production and charging infrastructure for electric vehicles. However, the control systems for energy generation, energy utilisation, energy storage and electric vehicle charging work are currently separate from each other.

Main findings

In the CME pilots, e-mobility solutions were implemented together with local renewables, storage and an open-source energy management system (the REMove tool) to connect, monitor and optimise the energy flows. By matching local energy needs with local renewables through smart solutions, such a system increases renewable energy's economic value and significantly reduces carbon emissions. This also contributes to increased energy security and independence of European cities and regions, at a time when the cost of energy has been increasing to record levels throughout Europe.


Interreg North-West Europe

Strengthening EU’s electromobility ecosystem in the global race.

Strengthening EU’s electromobility ecosystem in the global race.

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The investment in manufacturing technologies required to develop the net-zero, clean technologies and renewable energies is urgently needed at European and global levels. The Platform for electromobility therefore welcomes the ambition shown in the European Commission’s Green Deal Industrial Plan, which is designed to improve a number of European policies in response to the new industrial ‘Inflation Reduction Act’ (IRA) in the United States.

Given the importance of reducing greenhouse gas emissions from the transport sector, and the fact that Europe’s transport systems are part of its critical infrastructure, we believe that mobility industries providing zero-emission vehicles – all transport modes considered – should be considered part of the ‘Clean Tech’ sector. This should also extended in order to include charging stations, software and other EV enabling tech, given their important manufacturing footprint in Europe. This way, it will help anchor the manufacturing facilities for EV chargers on our continent.

An effective European response should go further than the IRA, and rapidly ensure the resilience of European industries against a backdrop of growing geoeconomic challenges. These have already seen both the United States and China invest heavily to try to secure the control of the electric mobility industrial value-chain.

Together, the IRA and the Made in China 2025 (MIC) plan should be treated as a wake-up call and a trigger for a robust European response. Indeed, Europe needs a holistic and long-term strategy that sets out the specific financial and regulatory support to address all the global current and future challenges. This should be capable of securing an EU-built industrial ecosystem of sustainable transport, and should ensure bespoke strategic autonomy for each key sector identified.

Importantly, the EU response should be prepared with care, in order 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.

Disregarding trans-Atlantic subsidies schemes, the European industrial strategy should define a long term-strategic ambition which, as a priority, should support the zero-emissions mobility, along its entire value chain and through all sustainable transport modes.

The Platform for electromobility is willing to bring its expertise and ecosystem perspective to the democratic debate by drafting detailed proposals that would lead way to a) short-term non-financial measures, such as regulatory certainty, bureaucratic delays, energy taxation, European research and shipment rules; b) State Aid rules and European Sovereignty Fund; and c) financial support.

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Where the Critical Raw Material Act should critically act

Where the Critical Raw Material Act should critically act

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The vital transition away from fossil fuels to cleaner technologies such as electric transportation – cars, trucks, buses, trains and public transport – will drive the demand for raw materials. Lithium, nickel, copper and cobalt will all be required in varying amounts depending on the technologies and applications.

Whilst certain Critical Raw Materials (CRMs) are accessible on the EU territory, Europe remains largely dependent on third countries for mining, processing, refining and recycling. This dependency has been accentuated by current geopolitical events and supply chain tensions, which have led to volatility, increasing prices and uncertainties over global supply. For this reason, we strongly welcome the principle of today’s Commission’s CRM Act, and we will shortly publish a detailed assessment from the perspective of the electromobility ecosystem.

Three clear flaws for Europe on CRMs

In light of the urgently required transition to e-mobility, and the need to ramp up a domestic Electric Vehicle (EV) value chain in Europe, there is a clear flaw; the EU is primarily deficient in domestic capacity beyond that of battery manufacturing. It lacks access to resources to extract, and – critically – the capacity to refine and process, as well as to recycle. Such processes are still undertaken almost entirely in resource-rich, more experienced and more competitive third countries. This is endangering both Europe’s autonomy in CRMs and the respect of the upmost environmental standards.

It is therefore vital that Europe builds its own processing and refining capacity for battery materials, using existing domestic sources of valuable materials. Europe must also increase its recycling capability and competitiveness in order to reduce the EU’s dependence on primary raw materials.

The second flaw is the excessive hurdles to the permitting. In particular, the range of mining codes that exist in Europe creates incoherence and differences in the levels of ambition between Member States, which in some cases may threaten safeguards to social and/or environmental protection. The processes for granting permits becomes excessively lengthy when multiple permits are needed for both renewable energy production and for sustainable mineral extraction projects.

The third flaw is the limited availability of sustainably sourced, highest quality materials, in no small part due to incomplete and limited mapping of geological and remining potentials. There are also barriers to the reuse and repurposing of EV parts, which could extend the lifespan of CRMs prior to recycling, thereby reducing the overall demand for CRMs. Member States lack the expert capacity to ensure the efficient, robust and timely evaluation of Environmental Impact Assessments and Area Assessments.

Consequently, the Platform for electromobility wishes to highlight the need for the EU’s Critical Raw Materials Act (the Act) to consider to the following 12 areas:

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Open letter to German Chancellor Scholz on CO2 Standards for cars and vans

Open letter

Industry and civil society call for certainty, ambition, and respect of co-legislators’ agreement on CO2 standards for cars and vans

Adressed to German Chancellor Olaf Scholz

Our open letter on CO2 Standards

Dear Chancellor Olaf Scholz,

The recent yet indefinite postponement of the vote on the CO2 Standards for cars and vans within the Council of the European Union has brought concerns to both business and civil society organisations alike.

With this open letter, the Platform for electromobility, uniting both spheres in a 47-member strong alliance to ensure the conditions for the full electrification of new light-duty vehicles by 2035, renews its support to the overall greenhouse gas emissions reduction target of 55% by 2030 and the climate neutrality objective by 2050. Reducing – and ultimately eliminating – emissions from cars, vans and trucks will be key to achieving these objectives.

As validated by the European Parliament in February, the cars and vans CO2 legislation will increase the offer and promote the market uptake of zero-emission vehicles. With an increased market, zero-emissions vehicles will also become more affordable with a continuously reduced total cost of ownership and more choice for consumers and will also help tackle air quality and noise issues, bringing an overall benefit to society.

 The EU CO2 standards regulation delivers genuine benefits for transport, ensuring planning and investment certainty, setting clear signals to not only car makers and consumers but also to EV infrastructure providers on the required pace for the transition to zero-emission mobility. However, recent political backpedalling has severely blurred those signals to European industries, investors and infrastructure providers as well as the legal certainty formerly established by the EU’s institutional procedures.

The Platform for electromobility thus urges the Swedish Government, as President of the Council, to first provide clarity and certainty on the agenda and secondly to safeguard the agreement as was already agreed in good faith between the EP and Council. Reneging on this deal not only puts at risk the EU Green Deal’s goal to fully decarbonise road transport by 2050, but undermines the very credibility of the EU’s established democratic norms.

Sincerely yours,