Weights and Dimensions Directive: How to accelerate the uptake of zero-emission heavy-duty vehicles

Review of the Weights and Dimensions (W&D) Directive:

 

How to accelerate the uptake of zero-emission heavy-duty vehicles

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In July 2023, the European Commission published the Greening Freight Package with the purpose of making freight more sustainable and efficient. As part of this Package, the review of the Weights and Dimensions (W&D) Directive aims to promote the uptake of electric and hydrogen trucks and buses.

The Commission proposes to increase the weight and length limits of zero-emission (ZE) heavy-duty vehicles. These provisions are intended to ensure ZE trucks don’t have to sacrifice cargo weight on long-haul routes, and ZE buses don’t have to decrease the number of passengers, in comparison to a comparable combustion model. However, the proposal fails to ensure the full application of the ZE weight allowance.

Despite noble intentions, the Commission includes several provisions which would keep the EU anchored to diesel trucks. In particular, the proposals on gigaliners[1] and combustion vehicles of 44 tonnes risk steering investment away from the zero-emission sector. Furthermore, the review should pay more attention to road wear and bridges.

The proposal also needs changes to make it truly intermodal and interoperable with other modes like (electric) rail. Such changes cannot be designed without having a perspective on what the Combined Transport Directive (CTD) will look like. This Directive plays an important role in reducing the carbon footprint of the whole logistic sector. For this reason, and as detailed in the Platform’s recent letter, we ask the European Commission to present the CTD without further delay. As such both proposals can be truly treated “as a package”, as was originally intended.

The need for a review of the W&D Directive

The heavy-duty vehicle (HDV) sector needs to decarbonize rapidly. In the first half of 2023, diesel trucks accounted for 95.6% of newly registered trucks[2]. While trucks account for just 2% of vehicles on the road, they are responsible for nearly 30% of greenhouse gas emissions from road transport in Europe.

Under current policies, this share is set to grow. According to the European Commission, truck activity will increase by about 40% between 2019 and 2050. Over the same period, bus and coach activity is expected to grow to a smaller but still considerable extent (+10%). Although buses are decarbonising much faster – 30% of new urban bus sales in 2022 were ZE – diesel buses still represented 67.3% of the new sales in Europe in 2022[3].

The EU thus needs to rapidly transition to 100% zero-emission HDV sales. As ZE trucks and buses weigh more than their diesel counterparts, a review of the W&D Directive is needed to really incentivise their uptake and set the sector in line with the Union’s goal of climate neutrality by 2050.

Our shared vision

We welcome the Commission’s intention to give zero-emission trucks a 4t weight allowance (as well as 2t to ZE buses). However, co-legislators need to intervene and ensure zero-emission trucks can fully use it, so that it is ensured that under no use case long-haul ZE trucks, which require bigger batteries, would have to sacrifice cargo weight. The proposal severely hampers the application of the ZE allowance, leaving road freight across key national borders (e.g. between France and Belgium) largely to diesel trucks.

The Commission requires the use of the ZE weight allowance for cross-border movement only, underestimating the relevance of national transport. Also, the wording of the Annex risks giving the 4t ZE allowance to diesel tractor units only because they pull electric trailers.

An increase in driving axle weight is essential for long-established truck-makers to switch from making fossil vehicles to electric. However, truck-makers don’t need the proposed 1t increase (from current 11.5 to 12.5t), which also fails to incentivise them to switch to clean sheet designs (lighter, optimised e-trucks).

The proposed regularisation of the cross-border movement of 44t combustion vehicles and of European Modular Systems (so-called gigaliners) brings them out of their current legal grey area. These longer, heavier vehicles will however only achieve real emission reductions if they are zero-emission. Unfortunately, the Commission does not provide any sunset clause for the cross-border movement of fossil gigaliners, nor does it propose a ZE weight allowance for these vehicles, thereby offering no incentive for the use of ZE gigaliners by fleet operators. Extending the use of 44t combustion vehicles and gigaliners risks delaying the take-up of electric vehicles, particularly during the 2020s. Making internal combustion trucks more attractive for long-haul transport also increases the fossil fuel dependency of the European freight sector, and therefore the EU’s dependence on imports.

Intermodal logistics system

Enhancing intermodal logistics in Europe is crucial to reach CO2 reduction objectives. Intermodal compatibility must be ensured throughout the revision process of the W&D Directive (which should not penalise rail freight) and the upcoming Combined Transport Directive.

Therefore, the Platform supports prior assessment for new gigaliner routes / movements so that they do not take traffic from rail or waterway. This prior assessment should also include an analysis of road safety and the need for additional driver training. As Kristian Schmidt, DG MOVE’s land transport director, has noted, reform should not promote truck traffic at the expense of rail, or “we’re in all kinds of political trouble[4].”







[1] Longer and heavier vehicle combination consisting of more modules and with a typical length of 25,25m.

[2] ACEA (2023). New commercial vehicle registrations: vans +11.2%, trucks +20%, buses +15% in the first half of 2023. Link.

[3] This share decreased to 63% in the first half of 2023.

[4] Politico, 29 September 2023.

[5] UK Department for Transport (2010). HGV maximum weights. Link.

[6] More specifically, wide-base high-efficiency single tyres on the steering axle and a dual tyre configuration on the driving axle; the alert threshold of the Tyre Pressure Monitoring system set at 0.6 bar, rather than current 1.2 bar, with a duty to restore under- or over-inflation at the nearest available facility; an acceleration limiter, with 1.2 m/s2 as a limit.

[7] An indicative phase-out date of 2035 should be set for ZE buses.


Recommendations to trilogue negotiators on EPBD

EPBD Trilogue
Our recommendations to negotiators

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In 2023, battery electric vehicle (EV) sales reached a milestone, accounting for 15% of total sales in the European automotive market. At the same time, about 25% of bicycles sold are e-bikes. These positive trends are expected to continue, driven by ambitious EU objectives and legislations and national recovery plans.

To ensure the success of Europe’s transition to zero-emission mobility, the deployment of private charging infrastructure is of utmost importance, given that 75% of all charging takes place at home or in the workplace. While the EPBD consider the upcoming needs of electromobility, we believe that safeguarding the strongest agreements are needed to establish the right conditions for widespread EV adoption.

The Platform for electromobility fully supports the revision of the EPBD, particularly the introduction of Article 12, which focuses on electromobility infrastructure in buildings. We commend to preserve provisions that guarantee a strong and coherent right to plug in all buildings, remove regulatory barriers, and require smart charging-readiness for new and renovated chargers, among other measures.

As the EU institutions start trilogue talks, it’s clear the European Parliament wants more than the Council. But the many exceptions for installing infrastructure could make things confusing and inconsistent across Europe, we would like to present five additional recommendations:

  1. Clarify the scope of application of Art 12

The current wording could be interpreted restrictively. We seek clarification to ensure that requirements apply to parking spaces both adjacent to and inside buildings.

  1. Ensure charging solutions in existing buildings

Given that a significant portion of existing buildings will remain in use by 2050, we propose extending the scope of Article 12 to require clear and transparent rules for EV charging points in existing buildings. Incentives and compliance mechanisms should be introduced.

  1. Complete charging requirements for new and renovated buildings

Extend requirements to cover depots, logistic hubs, and distribution centres, ensuring they are ready for future EV charging.

  1. Reinforce smart charging functionalities

Mandate that all newly installed chargers in buildings are capable of smart charging. Ensure consistency in definitions and provisions with related regulations and recognize the value of mobile storage.

  1. Reinforce measures to ensure pre-cabling

Provide an explicit definition of pre-cabling, inform about readiness in Energy Performance Certificates, and simplify permit and installation procedures. Address administrative hurdles and encourage Member States to financially support EV charging installations.

  1. Ensure adequate bicycle parking:

Opt for bicycle parking to represent 15 % of total user capacity in non-residential buildings, and with space required also for bicycles with larger dimensions than standard bicycles.

  1. Reject opt outs for SMEs

98% of all commercial enterprises are SMEs, therefore the Directive would no longer apply to 98% of commercial non-residential buildings. This is a tool that is too moderate.

  1. Re-ensure provision on Right-to-plug

The Right-to-plug lowered since in point 8 both co-legislators mentioned a “request by tenants or co-owners to install CPs can only be refused if there are serious reasons for doing so”. This could weaken provision on Right-to-plug, giving the possibility to landlords and condominium assemblies to refuse the Right-to-plug and install a charging infrastructure in not so clarified cases. We call to remove or clarify the point 8.

  1. Preserving precabling

In contrast to prevailing targets, where the European Commission’s proposal advocates for 100% precabling, the Council suggests a balanced approach of 50% precabling and 50% ducting. Additionally, in the case of new and renovated residential buildings, the Parliament recommends a complete shift towards 100% ducting if 100% precabling is deemed unfeasible. However, we propose retaining the precabling targets in alignment with the European Commission’s proposal. This approach ensures the preservation of cost-efficiency in future installations and reinforces the fundamental right to access plug-in infrastructure.

 

Now, it’s crucial for policymakers to act and make sure that every European can charge their electric vehicles at home and work, be it an EV or an e-bike. This is where most EV charging happens already. By doing this, we can make EV charging available to everyone and fully harness the environmental benefits it offers, contributing to the development of an energy system powered by renewables.

 

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2024 Election Manifesto

PLATFORM’S MANIFESTO FOR THE 2024 EU ELECTIONS

2024-2029: Five Years to make the e-mobility transition a Success

The agreement to pursue zero emissions for Europe’s new cars and vans by 2035 backed up by strong charging infrastructure and development of alternatives such as rail network, and the sustainable batteries regulation, has set a clear direction and an unequivocal target for sustainable transport measures.

However, in order to make the Green transition a reality, and bring its benefits to people, the planet and business, it is vital that we act now. Making the transition to e-mobility must be a priority, not simply to deliver environmental sustainability but also to reinforce the EU’s industrial strength, security and competitiveness.

Time to put the Green Deal into action

● The support of the legislative efforts and ambitions of the EU Green Deal and notably The agreement to pursue zero emissions for Europe’s new cars and vans.

● Now it is time to implement those ambitions to reduce Europe’s dependency of fossil fuels, make it a global leader in the sustainable transport industries and priorities quality of life and workspace for Europeans.

● An effective green industrial policy will bring the benefits of Europe’s Green Deal to all.

1st Pillar

A Green and Just Industrial Policy

● Creating an integrated recycling industry ecosystem in Europe.

● Smartening and upgrading existing grid infrastructure to allow it to support greater levels of renewable energy.

● Ensuring strong end-of-life vehicles regulation, focused on low carbon and recycled materials.

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2nd Pillar

Investment Plan to implement the Green Deal

● Making it easier for green energy transition sectors to access current EU funding mechanisms.

● Deploying infrastructures to support zero-emission passenger and freight transport across Europe.

● Introducing a dedicated budget for urban nodes, to avoid cities becoming a weak link.

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3rd Pillar

People at the heart of the e-mobility ecosystem

● Supporting reskilling programmes to attract workers from traditional industrial sectors and aiding their transition into these emerging sectors.

● Enabling Vehicle-to-Grid (V2G).

● Mandating electric vehicle adoption in corporate fleets.

Find out more

"It’s time to look ahead and see how the next legislative mandate can put the Green Deal into action. The agreement to pursue zero emissions for Europe’s new cars by 2035 has set a clear direction but this trajectory now needs to be implemented right."

— Julia Poliscanova, Vice-Chair Platform for electromobility

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Spanish (upcoming)

Italian (upcoming)


EU Election Manifesto: People at the heart of the e-mobility ecosystem

Manifesto Third Pillar

People at the heart of
the E-mobility ecosystem

As Europe shifts to a green economy, the demand for workers in industries such as critical raw materials, batteries and renewable energy industries will grow. Therefore, it will be essential to allocate EU resources and support to help steer young people into those technical fields essential for the green transition. There should be communication campaigns aimed at raising the visibility – and value – of these technical fields. It will also be crucial to implement well-funded reskilling programmes that will attract workers away from existing traditional industrial sectors and into emerging sectors such as renewable energy, grid management, infrastructures and recycling. These programmes will upgrade workers’ skills, train future workforces and ensure a just transition for the workers, their employers, and regional authorities.

The wider adoption of electric vehicles and rooftop photovoltaic solutions offer significant opportunity to unleash ‘prosumer potential’ in Europe. Restructuring Europe’s electricity market will allow us to maximise this potential, specifically through creating opportunities for Vehicle-to-Grid (V2G) where appropriate. This would enable EV drivers to take an active part to the transition by supplying power back to the grid. Allowing them to be rewarded for providing additional grid capacity and thus making the energy system more dynamic and resilient.

It is critical that zero-emission mobility is affordable to everyone. To that end, both old and new electric mobility solutions must be scaled up across Europe: Existing facilities include public transport offerings, shared cars and e-bikes for situations where individual cars are unnecessary. When they are unavoidable, newer solutions include low-cost leasing options, targeted purchase incentives policies and industrial strategies that support the deployment of smaller, more-efficient battery models should be provided. The rapid uptake of electric vehicles within corporate fleets will accelerate their second-hand availability. Implementing the Climate Social Fund should help drive this transition with the least possible impact on lower income families.


EU Election Manifesto: Investment Plan to Implement the Green Deal

Manifesto Second Pillar

An Investment Plan
to Implement the Green Deal

The 2023 Net Zero Industrial Act and the Critical Raw Materials Act needs an accompanying European Net-Zero Infrastructure Investment Plan. A long-term, easy-to-access investment facility – aimed at sectors key to Net Zero – should be a core issue during the European elections.

Freight and logistics infrastructure are a vital component in the movement of goods within Europe. There should be comprehensive investment in developing and deploying sustainable logistics infrastructure. The key elements for decarbonising freight in Europe while remaining competitive are the roll-out of high-power charging infrastructure required for deploying electric trucks of all ranges, the completion of a high quality, interoperable rail network with very high-speed connections, while ensuring a level playing field with other non-emitting modes of transport of goods.

Europe must also improve support for urban transport. Cities are working to accelerate the modal shift and to increase the electrification of their vehicle fleets. To avoid cities becoming the weakest links Europe should be providing parallel support to investments in zero-emission public transport networks and to the deployment of smart and efficient charging infrastructure within urban areas. To support the required local infrastructure investments, the next Connecting Europe Facility (CEF) transport programme should include a dedicated budget for urban nodes, building upon the experience of the Alternative Fuel Infrastructure Facility. Further support from EU research and innovation programmes as well as guidance, will also be needed to overcome challenges such as the constraint of public space, uneven distribution of private investments in EV charging infrastructure in cities or their integration in multimodal hubs, as well as lack of grid capacity.

Net Zero Sectors include the sustainable mining, processing and recycling of critical minerals and metals, modernising power grids and facilities for industrial material recovery as well as renewable energy production. Although existing European funds could contribute significantly, prioritising access to the current EU funding mechanisms and tailoring them to the specific needs of the sustainable transports value chain participants is essential.


EU Election Manifesto: A Green and Just Industrial Policy

Manifesto First Pillar

A Green and Just
Industrial European Policy

One of the richest ‘urban mines’ available to Europe is the supply of old batteries and other waste materials. By investing in integrated recycling and repurposing facilities for collecting, dismantling, recovering or reusing valuable metals from batteries, Europe can, by 2040, secure a large share of the metal resources it needs for battery production. Such an approach not just reduces waste, it is also scalable, preserving and reusing precious raw materials and keeping a greater proportion of them within Europe, increasing our strategic autonomy.

The overall concept of Europe keeping potentially valuable waste within its borders is one that should be widely adopted. Environmental recycling standards vary; exporting waste for processing to locations without equivalent standards undermines our own attempts to reduce environmental impacts. The EU should encourage recycling by establishing a harmonised approach to the intra-EU shipment of spent batteries. All. Executed properly, this can make Europe competitive in battery recycling, ensure the highest environmental standards and help create a flourishing recycling industry in the future

Resilient, affordable renewable energy will be key to a successful industrial policy; however, this demands that the correct grid assets are in place. With a European Grids Package, Europe can refresh and upgrade its infrastructure to meet the demand to accommodate higher levels of renewable energy. Although this will require investment, doing so will allow Europe to tap into its future grid asset – electric vehicles. It will accelerate the connection of chargers and other Green Deal enabling technologies and allow Europe to tap into the huge energy storage potential offered by electric vehicles.

Europe must also go further than simply reducing vehicle engine emissions; it needs a more-holistic approach to reducing the environmental footprint of all road vehicles. This means decarbonising manufacturing materials, increasing manufacturing efficiency and maximising the circularity of the materials used. Introducing digital product passports, revamping EU products policy to reduce environmental footprints and committing to deliver a strong end-of-life vehicles regulation based on low carbon and recycled materials, will be the key drivers for such change in the years ahead.

Finally, while a renewed European industrial policy has focused on key components and sub-systems, it is important that it considers the full scope of the mobility industries’ value chains supporting their global competitiveness as they address the green transitions.


Our statement on the reform of the Electricity Market Design

Electricity Market Design
The Platform for electromobility urges ambitious adoption of EMD reform to drive grid-friendly e-mobility

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The Platform for electromobility, uniting industries, civil society organisations and cities from the transport, energy and clean tech sector, welcomes the Electricity Market Reform (EMD) proposal as an important opportunity to support the build-out of grid-friendly e-mobility across Europe. We appreciate the proposals improve the existing electricity market framework in a way that facilitates cost-effective deployment of individual or aggregated smart and bidirectional electric vehicles (EVs) charging. As the EV market is growing rapidly, smart and bidirectional charging will quickly become one of the most important sources of demand-side flexibility. In the collective European effort to decrease fossil gas imports, EV charging flexibility will be instrumental to reduce consumer costs, greenhouse gas emissions and better integrate solar and wind in the grid.  Importantly, by offering additional revenues or cost saving opportunities to EV owners, the reform accelerates EV take-up and the clean transport transition.

The Platform therefore urges co-legislators to keep the level of ambition and a swift adoption. The European Commission’s EMD reform proposal supports the uptake of e-mobility in the following ways:

The reform recognises EVs as flexibility resource

Member States will have to make a detailed assessment of the needs and the potential of demand-side response and storage. Based on the assessment, an indicative objective  shall be set and supportive measures, such as a flexibility support scheme, may be introduced. It is important to properly include EVs as a source of demand response and storage in both the assessment of the flexibility needs and the objective for demand response and storage, and ensure appropriate participation of EV stakeholders in these assessments processes.

The reform further supports the participation of EVs in the markets

The threshold for participation in the day ahead and intraday markets get lowered to 100 kW, which makes them more accessible to aggregations of EV fleets. This will help develop the market for user-centric smart and bidirectional charging services. It may be advisable to extend this lower threshold also to capacity markets.

The reform accelerates planning for EV charging infrastructure

Transmission and distribution system operators will be financially incentivized to fully consider local demand side resources, such as EVs, when looking for solutions for grid congestion. System operators will propose further transparency and proactivity on their planning for connecting EV charging infrastructure, for example by sharing hosting capacity available for EV charging. This is essential information for providers of EV charging services and helps accelerate grid-efficient build-out of EV charging infrastructure.

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The reactions from the electric mobility ecosystem on Net Zero Industry Act

Green Deal Industrial Plan:
the reactions from the electric mobility ecosystem on Net Zero Industry Act and State Aid framework.

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The Platform for electromobility welcomes the European Commission’s Net Zero Industrial Act (NZIA) and Temporary Crisis and Transition State aid Framework (TCTF) for accelerating the transition of the EU’s net zero industrial sectors towards climate neutrality by 2050. As currently proposed, the NZIA is a positive start for a necessary holistic and long-term strategic plan, detailing specific financial and regulatory support measures for addressing all global current and future challenges, securing an EU-built industrial ecosystem of sustainable transport and ensuring bespoke strategic autonomy for every key sector identified.

We understand and welcome the package of both NZIA and TCTF as a tool for accelerating clean-tech industries with proposed non-financial regulatory measures. In this paper, we outline how the narrow scope of the proposed NZIA may fail in its aim of supporting European specificities. In addition, certain financial measures should also be included; without these, the NZIA may fall short of achieving its intended goals and fail to provide the required support for European clean industries.

Scope

Given the importance of reducing greenhouse gas emissions from the transport sector and industries, and the fact that Europe’s transport systems make up part of its critical infrastructure, we consider that mobility industries that provide zero-emission vehicles (ZEV) – all transport modes considered – as well as charging stations, software and other ZEV enabling tech, should be considered part of the ‘Clean Tech’ sector.

We welcome the inclusion of battery, charging infrastructures and grid technologies in the Annexes as Strategic Net Zero Technologies, yet we remain concerned about the lack of recognition for the entire EV value chain in the proposal. Net Zero Technologies should be extended to include other EV enabling technologies, including smart and bidirectional charging as well as component manufacturers.

A more flexible approach to those sectors that will be key for the EU’s future competitiveness should be adopted. Downstream industries, such as ZEV manufacturers, should be better considered and included in the scope of the Regulation to secure economic opportunities for supported upstream industries, such as cell manufacturing. Considering the NZIA as a non-financial tool, extending the scope to other sectors of the energy transition would increase Europe’s ability to be competitive in strategic sectors for the decarbonisation of transport, without undermining the support of already-included sectors such as battery manufacturing.

Non-financial measures

To create the enabling conditions for the European clean transport industry to prosper, several issues must be urgently tackled.

Financial measures

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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.

[1] https://theicct.org/transport-could-burn-up-the-eus-entire-carbon-budget/

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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:

Tyres

  • 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

Timeframe

  • 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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