Clean Corporate Vehicles Regulation: Completing an essential legislation
Platform for Electromobility’s reactions and recommendations to strengthen a regulation that can effectively boost the electric mobility transition
VEHICLES & MARKETS
The Platform for Electromobility welcomes the European Commission’s proposal for a Regulation on clean corporate vehicles. The initiative moves in the right direction by finally addressing the demand side of road transport decarbonisation and recognising the central role of corporate fleets in the European vehicle market and its transition to zero-emission mobility.
At the same time, the proposal remains short, cautious and marked by several ambiguities that risk limiting its effectiveness. With targeted clarifications and adjustments, this regulation could become a powerful and credible lever to accelerate electrification, support European industry, and deliver tangible emissions reductions.
The Platform would first like to welcome the followings.
The right tool for the right target
The Platform strongly supports the rationale of the proposal. For too long, EU road transport policy has relied almost exclusively on supply-side instruments, notably the CO2 standards for cars and vans. Introducing binding requirements on corporate demand is both necessary and overdue.
Corporate vehicles represent over 60%[i] of new registrations, travel longer distances, and on average emit more CO₂ than privately owned vehicles[ii] . Acting on this segment is therefore one of the most efficient ways to: accelerate the mass uptake of zero-emission vehicles (ZEVs); support EU-based car makers to reach their CO2 reduction targets, while ensuring the transition efforts are shared across sectors. provide investment certainty to charging infrastructure providers, grid operators, and broader ecosystem; rapidly develop a second-hand EV market, which is essential for affordability and social acceptance; achieve early and substantial CO₂ reductions in road transport, and increase the demand for European-made cars.
We particularly welcome the Commission’s choice of a regulation. This instrument provides the level of legal certainty and harmonisation that the market needs, especially for companies operating across multiple Member States.
The right scope and fleet definition
The Platform welcomes the proposal’s broad definition of corporate fleets, including large leasing companies and all major private and commercial fleet segments. This approach reflects the reality of the European fleet market, where a significant share of corporate vehicles is managed through leasing and rental arrangements. By focusing on the size of the undertaking rather than on specific business models, the proposal helps avoid loopholes and ensures that all major corporate fleet operators are subject to a consistent framework.
The right differentiation between cars and vans
We welcome the proposal’s separate trajectories for passenger cars and light commercial vehicles, acknowledging differences in use cases, technological maturity, and production capacity in Europe. This differentiation is justified and should be preserved, provided that ambition is real for both segments.
Further amendments to the text are needed to ensure the regulation’s ambitions are set at the right level and improving clarity and predictability for investment decisions.
[i] Transport & Environment. (2020, October). Company car report (Dataforce). https://www.transportenvironment.org/uploads/files/2020_10_Dataforce_company_car_report.pdf [ii] Dataforce. (2024). Car market forecast 2024–2025 (corporate cars emissions share). Retrieved from https://www.dataforce.de/en/news/dataforce-car-market-forecast-2024-2025/#:~:text=Another%20effect%20considered%20in%20the,range%20of%20full%2Dhybrid%20models
Area 1 | Targets striking an ambitious, clear and realistic trajectory to full decarbonisation
Recommendation 1/Targets that stimulate the market without freezing it
The Platform supports the introduction of binding minimum shares of clean vehicles in new corporate registrations. That said, the level and design of the targets require careful adjustment to be impactful.
Recommendations:
- Setting ambitious, proportionate and attainable targets that go beyond current market trends, ensuring the whole ecosystem moves forward and drives innovation and investment while fostering the second-hand car market for European citizens.
- Setting a clear, long-term decarbonisation target and credible pathways towards full decarbonisation for all Member States for fleets covered by the proposal in order to reach carbon neutrality by 2050.
Recommendation 2/Avoiding a fragmented, two-speed Europe
The proposal introduces Member State–specific targets, reflecting differences in economic conditions. While this granularity is understandable, it should not undermine the core objective of convergence towards zero-emission mobility across Europe evenly. While we recognise that differentiated targets aim to account for variations in purchasing power across Member States, this rationale must be relativised in the context of multinational corporate fleets operating across Europe. More broadly, the objectives of clean air and access to modern mobility solutions are shared across the Union.
Recommendation:
- While maintaining national targets, the regulation should explicitly ensure that lagging Member States are encouraged—and supported—to catch up, in particular in infrastructure deployment[i], rather than locking in structural disparities and creating a two-speed Europe in corporate electrification.
[i] Platform for Electromobility. (2025, December 5). From targets to consumer-friendly deployment of publicly accessible charging points for EVs. https://www.platformelectromobility.eu/2025/12/05/from-targets-to-consumer-friendly-deployment-of-publicly-accessible-charging-points-for-evs/
Recommendation 3/ Low-emission vehicles: a blurred pathway
The inclusion of low-emission vehicles (LEVs) alongside zero-emission vehicles raises concerns. This approach dilutes the signal towards full electrification; diverting investments from future-proof, zero-emission technologies towards transitional solutions that still emit CO2.
Recommendation:
Prioritising zero-emission vehicles across the Regulation, with a clear and credible pathway towards its future uptake in corporate fleets.
Area 2 | Coherent financial provisions and supports for SMEs and Made-in-Europe ZEVs
Recommendation 4/ End any support to CO2-emitting vehicles
We support the principle, set out in Article 4 of ending public financial support for CO2-emitting vehicles but we urge to end any support to low-emission vehicles too. This is essential to ensure coherence between public spending and climate objectives. Moreover, the proposal remains vague as to what precisely constitutes “financial support” and how this prohibition will be implemented and enforced at national level.
Recommendations:
- The scope of prohibited financial support should be clearly defined, and financial support for the procurement or purchase of a new vehicles, as well as their operation, should be strictly reserved for zero-emission solutions.
- Article 4 should apply to all incentives, not only those for large fleets included in the scope of the regulation.
Recommendation 5/ Made-in-Europe requirements
We support conditioning public financial support for uptake of corporate cars on “Made-in-Europe” criteria. This measure must be used carefully and smartly to avoid possible negative side effects. Industrial realities, notably the complexity of broader European supply chains, must be properly acknowledged to make sure that it does not result in making EVs less competitive and thus less affordable, which would ultimately slow down the electric transition.
Recommendation 6/ Lack of demand-side incentives
The proposal shifts all responsibility for demand-side incentives to Member State implementation. Following up on previous guidance, the Commission missed the opportunity to create a comprehensive list of measures that Member States should implement, both for new vehicle acquisition, operations, and residual value guarantees.
Recommendation:
- The Regulation should be more precise on demand-side incentives that Member States should include.
Area 3 | Gaps and missed opportunities in the Regulation
Recommendation 7/ Multimodality and light electric transport
The proposal does not recognise the growing role of multimodal, public, and light electric mobility solutions for corporate needs. Companies increasingly rely on a mix of solutions to meet mobility needs: small cars, public transports (buses, trams, metros, local and regional trains, etc.), sharing of e-cars, e-bikes and e-scooters, etc.
Recommendation:
- A broader and more forward-looking perspective on corporate mobility, encouraging the use of all electric mobility solutions, should be promoted, for example through a recital within the regulation and through strong accompanying measures such as recommendations for tax incentives at Member States level.
Recommendation 8/ Smart and bidirectional charging
Corporate fleets are ideally suited to become early adopters of smart and bidirectional charging, given their predictable usage patterns and focus on cost efficiency. Vehicle-to-Grid (V2G) and smart charging technologies can support a grid-friendly rollout of electromobility; enhance energy system resilience; facilitate renewable energy integration; reduce costs for both fleet operators and the electricity system.
Recommendation:
- Without delaying implementation, the Regulation should explicitly encourage the deployment of smart and bidirectional charging solutions alongside fleet electrification.
Recommendation 9/ Heavy-duty vehicles (HDVs)
We regret the absence of any binding commitments for heavy-duty vehicles, as large fleets (except bus fleets, for which the Clean Vehicles Directive applies) have not been regulated at EU level. While the challenges differ from light-duty segments, HDV fleets also represent a major decarbonisation opportunity.
Recommendation:
- The Regulation should at least establish a clear roadmap or review clause to progressively integrate HDVs (other than buses) into the clean corporate vehicle framework.
Area 4 | Key measures for Member States’ national plans
Recommendation 10/ Enable second-hand market creation
Specific support should be provided to the second-hand market through National implementation plans, including measures such as:
- Removing registration and circulation taxes;
- Offering favourable depreciation and vat treatment;
- Providing incentives and premia for high-mileage and second-life vehicles to support vulnerable communities;
- Reduce residual value risk for professional fleets via guarantees, risk-sharing, or resale support schemes
Recommendation 11/ Professional mobility fleets in national compliance plans
While the Regulation’s scope allows for the inclusion of taxis, ride-hailing services, and other professional or shared mobility fleets when operated by large undertakings, in practice many of these operators will not meet the thresholds set out in the proposed regulation. These vehicles are intensively used, predominantly urban, and can have a significant positive impact on air quality and emissions.
Rather than reopening the core fleet definition, the Platform considers it more effective to address these segments through Member States’ compliance and implementation plans. This would allow national authorities to design targeted measures for high-impact professional fleets, improve visibility on national actions, and partially address the absence of a strong EU-level compliance mechanism.
Recommendation:
- Encourage Member States to explicitly include taxis, ride-hailing services, and other professional and shared mobility fleets in national implementation and compliance plans, with tailored measures reflecting their high utilization and environmental impact.
Recommendation 12/ Comprehensive and impactful compliance mechanisms
A credible and transparent compliance framework is essential to ensure the Clean Corporate Vehicles Regulation delivers real-world emissions reductions. To maintain market confidence, the Regulation must focus on Member State accountability while allowing for national flexibility in policy design.
Recommendations:
- The Regulation should establish EU-wide monitoring and proportionate consequences for missed national targets. Enforcement revenues should be reinvested into electrification, charging infrastructure, and clean mobility.
- In line with Article 6, MS should report annually on the effectiveness of their chosen policy mix (e.g., fiscal incentives or mandates).
Recommendation 13/ Thresholds and support for SMEs and fragile actors
The Platform supports the use of size thresholds to focus binding obligations on large undertakings and avoid disproportionate burdens on SMEs and one-person companies. While not in the scope, smaller and more fragile actors will be directly affected by market shifts driven by large fleets and must be supported to ensure a fair and effective transition. Targeted incentives, access to charging infrastructure, and adapted financing solutions will be essential to enable SMEs and individual operators to absorb the costs of electrification and fully benefit from the increased availability of electric vehicles.
Recommendation:
- Retain size thresholds for binding obligations while ensuring that SMEs and one-person companies are supported through dedicated incentives and enabling measures at national level.
Conclusion
The Platform for Electromobility considers that the tool chosen by the Commission is the right one. A binding regulation addressing corporate demand is both timely and necessary. Strong, ambitious and credible targets can become an effective driver of Europe’s transport decarbonisation. Broadening the perspective is essential for this regulation to rapidly increase the demand for zero-emission vehicles in the EU. Beyond the CCV regulation, policymakers should create conditions that let authorities, fleet operators, and investors plan confidently, coordinate infrastructure, and scale up ZEVs to meet the EU’s climate and industrial goals.
"Coming up with a Clean Corporate Vehicles Regulation is a key step to ensure Europe’s decarbonization targets achievement. So far, demand-side tools have been lacking. With fleets making up 60% of the automotive market, and provided it is properly calibrated and accurately accounts for market realities, this Regulation can provide a crucial lever to support the EV ramp up.”
— Victor Demiaux
RENAULT GROUP
ETS 2: An extra year to prepare, not to snooze
WG Vehicles & Markets
Our reaction to the delay of the ETS 2 implemention from 2027 to 2028
The Platform for Electromobility, representing a broad coalition of industries committed to the decarbonisation of transport, reiterates its firm support for the timely implementation of the ETS 2 (Emissions Trading System for road transport and buildings) as scheduled in the previous mandate, in line with the vote of the European Parliament on April 18, 2023.
We nevertheless acknowledge the agreement to delay the start of ETS 2 from 2027 to 2028 in front of political and social concerns linked to its implementation[i]. This additional year, however, must not be understood as pressing a “snooze button” on Europe’s effort for road transport decarbonisation. A snooze delays action without changing the outcome, and thus risks triggering more delays in decisive actions. By contrast, the extra preparatory year should be used actively and purposefully to ensure that ETS 2 starts on solid foundations: predictable, socially fair, and effective in driving emission reductions.
Used well, this time can strengthen infrastructure readiness, accelerate social support mechanisms, and provide market clarity. Used poorly, it risks prolonging uncertainty, weakening investment signals, and reducing the effectiveness of both ETS 2 and the Social Climate Fund (SCF). The recent Council agreement therefore creates not a pause, but a responsibility.
Against this backdrop, the additional year before 2028 must be used to remove uncertainty, ensure social fairness, and prioritise cost‑efficient measures. We thus call for the following measures.
[i] European Commission (2025), Commission proposes targeted adjustments to the Market Stability Reserve Decision to support a smoother start of ETS2, 27 November 2025. https://climate.ec.europa.eu/news-other-reads/news/commission-proposes-targeted-adjustments-market-stability-reserve-decision-support-smoother-start-2025-11-27_en
1. Remove uncertainty and stabilise expectations
First, the extra year should be used to stabilise expectations for all actors.
- Expectations should be anchored early through clear communication on the ETS 2 timeline, scope, and interaction with other instruments.
- Core design elements of ETS 2 should not be reopened unless strictly necessary. Repeated renegotiation being in itself a driver of delay, uncertainty, and higher costs.
- Member States should establish clear national earmarking frameworks for ETS 2 revenues, giving visibility to how funds will support households, infrastructure, and mobility alternatives.
In this context, the possibility to launch early auctions in 2026 is a positive step. Early auctions can help market participants anticipate carbon prices, enhance transparency, and reduce the risk of price shocks at the start of the system.
2. Ensure social fairness from day one
Second, social fairness must be operational before ETS 2 starts, not addressed retroactively.
- The Social Climate Fund should be fully operational ahead of the entry into force of ETS 2.
- Approval of national Social Climate Plans should be accelerated to avoid implementation gaps.
- Member States should be encouraged to frontload national measures, using the flexibility offered to advance support to vulnerable households and small businesses.
- Infrastructure deployment must be facilitated[i].
Social acceptability will depend less on the existence of compensation mechanisms on paper than on their timely and visible delivery. In this context, the possibility for Member States to frontloading ETS 2 revenue is a step in the right direction[ii].
[i] See our proposal for targeted AFIR review: Platform for Electromobility (2025), From targets to consumer-friendly deployment of publicly accessible charging points for EVs, 5 December 2025. https://www.platformelectromobility.eu/2025/12/05/from-targets-to-consumer-friendly-deployment-of-publicly-accessible-charging-points-for-evs/ [ii] Platform for Electromobility (2025), ETS 2: Staying the course for an effective and fair transition to e-mobility, 7 October 2025. https://www.platformelectromobility.eu/2025/10/07/ets-2-staying-the-course-for-an-effective-and-fair-transition-to-e-mobility/
2. Ensure social fairness from day one
Third, the extra preparatory year should be used to prioritise measures that deliver the highest emission reductions per euro spent.
- Stronger links between ETS 2 and the EU’s Multiannual Financial Framework (MFF) should be explored to ensure coherence and scale[i].
- Social leasing schemes should focus on the most cost‑efficient mobility solutions, for example e-bikes and small affordable electric cars[ii] that also have the potential to boost the European electric transport industry at a crucial moment, bringing volumes and thus driving down costs and prices.
- Phase out fossil fuel subsidies and tax exemptions that weaken the carbon price signal and slow the shift to cleaner mobility options.
[i] Platform for Electromobility (2025), Boosting Europe’s competitiveness with an ambitious MFF for clean transport, 13 October 2025. https://www.platformelectromobility.eu/2025/10/13/boosting-europes-competitiveness-with-an-ambitious-mff-for-clean-transport/ [ii] This reference does not constitute the official position of the Platform for Electromobility on the Small EV Initiative, which will be addressed through a dedicated analysis and set of recommendations.
4. Maintain ETS 2 for heavy duty vehicles and industrial applications
ETS 2 should continue to cover at least industrial and heavy-duty vehicle applications. Unlike household energy use or private mobility, the transport of goods does not raise the same direct social or political concerns, as associated costs do not immediately or directly affect citizens. Maintaining this scope is therefore essential to preserve investment certainty for manufacturers, operators, and infrastructure providers, and to avoid fragmenting the decarbonisation framework for road transport.
Conclusion: ETS 2 is a cornerstone of the road decarbonization framework
ETS 2 is a central pillar of the road decarbonisation package proposed in 2021 and adopted under the previous EU mandate. Any delay in its implementation mechanically translates into reduced and postponed revenues for the Social Climate Fund, meaning fewer resources, and later, for Member States and households. At the same time, the increased flexibility introduced under the revision of the CO2 Standards for cars and vans makes a robust ETS 2 even more important to preserve a clear economic signal in favour of zero-emission mobility.
The delay of ETS 2 to 2028 should be seen as a final preparation window, not as an invitation to postpone difficult decisions. Pressing the snooze button would only defer costs and weaken Europe’s predictability on road transport decarbonisation. Using the extra year to prepare infrastructure, secure social fairness, and stabilise expectations can instead ensure that ETS 2 starts strong, predictable, and effective from day one.
“ETS 2 is a central pillar of the road decarbonisation package. The delay in its implementation must be used to create measures that can help as many Europeans as possible to make the switch to zero-emission mobility. For example, social leasing
schemes should focus on the most cost-efficient
solutions such as e-bikes.”
— Holger Haubold
Director, European Cyclists Federation
Weight & Dimensions Directive: Prioritising Decarbonisation
WG Vehicles & Markets
Our recommendations ahead of Trilogue for a underestimated legislation, key for the decarbonisation of logistic transportation in Europe
As the European Parliament and the Council enter trialogue negotiations on the revision of the Weights and Dimensions Directive (96/53/EC), the Platform for Electromobility calls on co-legislators to ensure that this file serves as a powerful accelerator for the transition to zero-emission transport of goods and safeguard a level-playing-field across all electric modes. The core objective of this revision must be clear: any necessary, additional allowances in weight or dimensions must be reserved exclusively for zero-emission vehicles (ZEVs) and intermodal transport operations without undermining rail and combined transport competitiveness.
1. Benefits must be exclusive to ZEVs and intermodal transport
The Platform supports the direction taken in the Council’s General Approach, which aligns more closely with the principle of “green incentives” that remain targeted without leading to a shift from rail to road.
- Targeted Incentives: The Council’s proposal for Article 4b correctly focuses on allowing zero-emission motor vehicles and intermodal combinations to cross borders with weights exceeding standard limits where this demonstrably supports intermodal transport and does not create infrastructure incompatibilities, and provided they respect national limits on both sides.
- ZEV Bonus: We support inclusion of additional weight allowance for zero-emission trucks in order to compensate for battery weight, incentivize fleet renewal, and are subject to regular review.
- No “Free Pass” for Diesel: In contrast, the European Parliament’s position includes a “sunset clause” (Recital 12) that would allow 44-tonne fossil-fuel (diesel) trucks to circulate in cross-border traffic until 31 December 2034, risking a significant reverse modal shift and weakening the business case for zero-emission transport investments.
2. Benefits must be exclusive to ZEVs and intermodal transport
To make electric trucking viable, the directive must accommodate the technical needs of ZEVs:
- Length Derogations: We support the expansion of the 0.90-meter extension for articulated ZEVs to an unlimited length derogation, provided this does not compromise interoperability with intermodal terminal or rail operations, and as long as the turning circle requirement is met, as proposed by the European Parliament.
- Weight allowance only for zero-emission trucks: Both the Council and the European Parliament clarified that increased weight allowance is not allowed in combinations of a diesel truck with a zero-emission trailer. Clear enforcement mechanism is needed to prevent circumvention of weight limits and ensure consistent application across Member States.
3. A Call for urgent conclusion under the Cypriot Presidency
This legislative file has been under discussion for far too long, creating investment uncertainty for transport operators and manufacturers alike.
- We urge the negotiating teams to reach a swift agreement and conclude the trialogues under the Cypriot Presidency.
- Market Readiness: The industry needs a stable regulatory framework to scale up the production and deployment of zero-emission trucks. Every month of delay is a month where diesel remains the default choice for logistics.
Conclusion:
The Weights and Dimensions Directive is a key enabler for reaching targets set out in the HDV CO2 standards. We urge co-legislators to adopt the Council’s restrictive approach to 44-tonne cross-border traffic—limiting it to ZEVs and intermodal—while incorporating the Parliament’s focus on length derogations.
“This legislative file has been under discussion for far too long, creating investment uncertainty. Reaching a swift agreement can now provide the needed certainty for transport operators and manufacturers alike. We urge the negotiating teams to reach a swift agreement and conclude the trialogues under the Cypriot Presidency.”
— Bernardo Galantini, T&E
ETS 2: Staying the course for an effective and fair transition to e-mobility
Vehicles & Markets
The Platform for Electromobility, representing a broad coalition of industries committed to the decarbonisation of transport, reiterates its firm support for the timely implementation of the ETS 2 (Emissions Trading System for road transport and buildings) as scheduled in the previous mandate, in line with the vote of the European Parliament on April 18, 2023.
1. Uphold ETS 2 to unlock investments
Rolling back or delaying the ETS 2 would undermine investor confidence and reduce the available financial tools to accelerate the uptake of electric vehicles, the development of alternative and collective mobility modes, and related infrastructures. The new system is not only a pillar of the Fit for 55 package, it is also a key driver for directing public and private capital towards the clean transition ecosystem and industries.
Any deviation from the agreed implementation path would generate uncertainty, reduce the credibility of the EU’s climate framework, and jeopardise our ability to meet emissions reduction targets.
2. Timely transposition: a key step for fair and effective implementation
As of today, only 10 Member States have transposed the ETS 2 directive into national law. Accelerating transposition is essential to ensure a coherent and effective rollout of the system across the EU. It will provide legal certainty, enable better coordination among stakeholders, and help deliver the expected climate and social benefits in a timely manner. Encouraging swift action from all Member States will also strengthen the credibility and impact of ETS 2 as a key pillar of the EU’s climate policy.
Moreover, citizens and businesses need a clear price signal. A stable and well-communicated carbon price will encourage behavioural change, spur investment in energy efficiency and zero-emission solutions, and support long-term planning across the value chain.
3. Ensuring ETS 2 is effective and socially fair
To guarantee that ETS 2 delivers both environmental and social outcomes, we recommend the following measures:
- Reinvest 100% of ETS 2 revenues into decarbonisation and targeted social support. We call to ensure transparency and additionality of Member State spending, so EU funds do not replace existing national support schemes.
- Strengthen complementary policy tools: ETS 2 must work alongside a robust regulatory framework. This includes preserving the CO₂ reduction ambitions for cars and heavy-duty vehicles, supporting the Clean Corporate Vehicles initiative, and ensuring the rollout of charging and multimodal infrastructure.
- Frontload ETS 2 revenues. We must accelerate investment to protect vulnerable groups from the impact of rising carbon prices and to deliver visible benefits early in the transition.
- Reinforce the Social Climate Plans (SCPs): push Member States to increase the co-financing rate above 25% to ensure meaningful national action.
- End fossil fuel subsidies: Use ETS 2 as an opportunity to rebalance taxation in favour of electrification, including reducing the tax burden on electricity and removing outdated exemptions for fossil fuels.
- Early auctions should be launched in 2026. Early auctions would help market participants form their view on expected prices. It would be a market friendly move to enhance transparency and ensure a smoother transition into full system operation.
Conclusion
"ETS 2 is not only about cars – it is also key to decarbonising heavy-duty transport. By sending a predictable price signal, the system will support investment in zero-emission trucks, strengthen the CO₂ standards for heavy-duty vehicles, and accelerate the rollout of charging and refuelling infrastructure needed for long-haul freight."
— Koen Noyens, Head of Public Affairs, MILENCE
ETS 2 is a cornerstone of Europe’s decarbonisation strategy. It must be implemented as planned to send a clear signal to markets, enable effective carbon pricing, and channel investments into clean mobility. Our coalition of industries stands ready to support this effort and ensure that ETS 2 is both socially just and economically effective.
Corporate Fleet Initiative? Towards a fair, sustainable, multimodal, and smart transition
VEHICLES & MARKETS
The Platform for Electromobility welcomes the European Commission’s plans to present, by the end of 2025, a legislative proposal aimed at accelerating the uptake of zero-emission vehicles (ZEVs) in corporate fleets.
The Commission’s communication on this initiative, referred to as “Greening Corporate Fleets,” clearly outlines the strategic importance and objectives of the proposal. With this document, the Platform presents the perspective of the electric mobility industrial ecosystem in response to the remaining open questions ahead of the legislative proposal. These include considerations regarding the type of legislative instrument, the scope and inclusion of light and collective electric transport, the integration of an ecoscore to complement the “Greening Corporate Fleets” initiative, and the potential use of funds collected through penalties or enforcement mechanisms.
1. Legal instrument - Regulation vs. Directive
We first wish to underline the urgency of this measure: there is a critical need to boost demand for electric vehicles (EVs) in order to support EU-based automotive manufacturers in meeting CO₂ standards targets. This urgency should guide the choice of legal instrument.
A directive would not be sufficiently timely, as its transposition into national law would likely delay market impact in some Member States until the 2030s, far too late to support EU-based manufacturers in meeting the 2035 targets.
A regulation, by contrast, would provide greater legal certainty and allow for faster implementation. It would offer clarity for both manufacturers and companies purchasing fleet vehicles. Such certainty, alongside ambitious CO₂ standards for new cars and vans, will ensure that the supply of EVs can meet the EU’s climate ambitions and avoid competition among companies for a limited pool of ZEVs.
The Clean Vehicles Directive should be integrated into this new framework, following a one-in-one-out approach, which would streamline obligations for both public and private fleet operators. Coordination between the Clean Vehicles Directive and the upcoming corporate fleet initiative must also be ensured, with a view to harmonising obligations. In the longer term, the integration of both frameworks into a single, comprehensive regulation could be considered—provided it supports the objective of simplifying requirements and improving overall policy coherence.
2. Trajectories – Segments & Scopes
We recommend setting a target that effectively accelerates demand for ZEVs and facilitates the development of a second-hand EV market, while remaining aligned with market realities. Battery electric vehicles (BEVs) represent the most straightforward and efficient solution for decarbonising road transport for passenger cars. Therefore, the definition of ZEVs under this initiative should clearly reflect this assessment.
We believe the legislation should cover all fleet segments: company cars, rentals, leasing, true fleets (including taxis, ride-hailing, carsharing, logistics vans, buses and coaches), and trucks. We highlight the importance to establish a clear distinction between the cars and the vans. Market realities, usages and greening speed (including production capacities in Europe) are different. Moreover, this regulation should also include measures to increase demand for zero emission heavy duty vehicles.
3. Scope – Light, Shared and Collective Mobility
We recommend adopting a broad and forward-looking perspective on the scope of the initiative, to reflect the rapidly evolving landscape of corporate mobility options and solutions. As in wider society, all means of transport that are meeting companies’ mobility needs should be promoted, from light electric vehicles (LEVs) and electric collective transports to electric vehicles (LDV & HDV). In the context of company-provided mobility solutions (e.g. benefit-in-kind schemes), the focus should be on reducing emissions from overall corporate mobility, including solutions such as shared mobility vouchers or public transport subscriptions.
To support this transition, particularly for SMEs, we recommend that the Commission provide access to tailored advisory services to help design sustainable corporate mobility strategies.
4. Supporting more sustainable, smarter, EU-made solutions
In parallel with the urgent need to accelerate EV uptake, we support the introduction of an EU-level ecoscore to guide fleet purchasing decisions toward the most sustainable vehicles. An ecoscore, defined in close coordination with stakeholders, would enable fleet purchasers to assess the overall sustainability of vehicles beyond their ZEV status.
Such a tool could also be used to support EU-based vehicle and batteries manufacturing by rewarding production practices aligned with EU environmental and social standards, thereby strengthening European industrial competitiveness.
In addition, the fleet mandate should, without delaying the implementation of the initiative, encourage the deployment of smart and bidirectional charging technologies. These are essential to enabling a grid-friendly rollout of electromobility by turning vehicles into active grid assets, enhancing energy system resilience, better integrating renewables into the grid, and enabling cost savings for both users and the electric system. Given their predictable usage patterns and focus on cost-efficiency, corporate fleets are ideal early adopters of Vehicle-to-Grid (V2G) technologies and should be at the forefront of this development.
We also recommend calling on the Commission and Member States to assess and address regulatory barriers to unlocking the flexibility potential of corporate fleets, and to develop and exchange guidance and best practices to this end. Companies above a certain size should be encouraged to evaluate how their fleet could contribute to, and benefit from, demand-side flexibility, including through a clear cost-benefit analysis.
5. Social fairness – Targeting funds toward EU-wide purchase scheme and infrastructures
To enforce the legislation, the first step should be the establishment of a clear reporting system to track new vehicle procurement. As a follow-up, an incentive and/or penalty framework should
be created. Where possible, we recommend that any funds collected through enforcement mechanisms or penalties for non-compliance be redirected to support the purchase of all types of fully electric vehicles and related infrastructure, notably for local authorities and SMEs. This would enhance both the social fairness and the overall effectiveness of the initiative. Alternatively, such penalties could be channelled into the Social Climate Fund.
Beyond the corporate fleet initiative
FISCAL INCENTIVES – A KEY DRIVING FACTOR
We believe that no fleet greening initiative will be effective without the right enabling conditions and enforcement mechanisms. Fiscal policy remains one of the most powerful levers for accelerating the transition to clean corporate mobility. To ensure the success of the fleet greening initiative, the Commission should strongly encourage Member States to align their tax systems in support of all types of electric vehicles. Well-designed fiscal incentives (such as tax deductions, exemptions, or reduced benefit-in-kind rates) have proven to be among the most effective tools for driving behavioural change in the corporate mobility sector.
INFRASTRUCTURE – UNLOCKING BROADER BENEFITS
This regulation will catalyse substantial investments in EVs and the charging infrastructure needed to support them. As companies electrify their fleets, the total number of EVs in both primary and secondary markets will increase, thereby accelerating the deployment of charging points, at depots and workplaces, as well as at public and semi-public charging stations, with benefits for all EV drivers
"We recommend adopting a broad and forward-looking perspective on the scope of the initiative, to reflect the rapidly evolving landscape of corporate mobility options and solutions. As in wider society, individual car ownership should not be the sole approach to meeting companies’ mobility needs."
— Holger Haubold, Director at the European Cyclists' Federation
E-fuels: a costly Pandora’s box for European drivers
Vehicles & Markets
The Platform for Electromobility calls on Members of the European Parliament (MEPs) to consider carefully the impact of integrating e-fuels into Europe’s decarbonisation strategy, most notably into the post-2035 regulatory landscape. We advocate for policies that will prioritise energy efficiency, affordability and transparency for consumers; the proposal to expand e-fuel use risks undermining this. As the EU seeks to revise its CO2 standards for cars and vans, MEPs should evaluate how adopting e-fuels will affect Europe’s consumers in terms of increasing costs, creating regulatory ambiguity and ultimately impacting public health and air quality.
1. High costs of e-fuels for consumers
E-fuels are likely to be prohibitively expensive for everyday consumers, increasing the overall cost of mobility in Europe. By 2030, e-fuels are projected to cost consumers 4 times more per kilometre than battery electric vehicles (BEVs).1 While fossil fuel-industry advocates argue that large-scale production will reduce these costs, BEV technologies are also progressing, with prices expected to fall. The comparative cost burden on consumers – particularly low-income families and rural populations who need to cover the greatest distance – would hinder the EU’s ambition of affordable clean mobility accessible for all.
Without strong regulatory guardrails to support and incentivise the transition to electric mobility, drivers may face increased costs for synthetic fuels for internal combustion vehicles. Such a cost will disproportionately impact the most economically vulnerable consumers. These individuals rely on affordable mobility options; advancing high-cost technologies such as e-fuels threaten to exacerbate existing inequalities in accessing transportation. Producing a truly climate-neutral e-fuel will make the cost per kilometre driven significantly higher than any other modes of transports2.
[1]Clean solutions for all: T&E’s car decarbonisation roadmap - Transport & Environment [2] E-Fuels and Their Role in the Transport Sector - Transport & Environment
2. Regulatory instability: impacts on consumer decisions to shift to clean mobility
Inconsistent regulations and enabling conditions delays create uncertainty for consumers, leading to delayed decision-making in purchasing clean vehicles. This in turn is lowering the demand for the clean vehicles that European manufacturers urgently need to reach their decarbonisation targets. If e-fuels are introduced alongside BEVs, it may result in a complex and fragmented regulatory environment, one that is confusing for fleet managers. For example, approximately one-third of new cars in Europe are company vehicles, reflecting corporate fleet purchasing decisions. Companies seeking to decarbonise their fleets are encountering uncertainty over which technologies will ultimately be compliant with EU CO2 emissions standards. As a result, fleet buyers are delaying their decisions to switch to zero-emission vehicles, leading to a detrimental slowdown in clean vehicles market conditions.
Technology-neutral policies that increase regulatory ambiguity risk jeopardising Europe’s decarbonisation targets and lead to delays in adopting proven low-emission vehicles. In committing to a unified and energy-efficient path forward, the EU can provide consumers and companies alike with the certainty needed to make sustainable choices.
3. The Pandora’s box of fraud and ambiguity
Given that transport fuels derived from fossil or renewable energy are chemically identical, the process of monitoring and verifying the environmental benefits of e-fuels is loaded with logistical challenges.
In order to be fully transparent to consumers, fossil and e-fuels should not be blended, and their price should be clearly indicated at petrol stations. Otherwise, consumers committed to choosing clean energy sources for their vehicles may unwittingly purchase fuel that does not deliver the promised environmental benefits.
While control mechanisms are possible, introducing e-fuels alongside existent fossil-fuel pumps would require additional infrastructure investments. Such measures include dedicated e-fuel nozzles, adding additive to e-fuels to tell them apart from fossil fuels, while car makers would have to retrofit vehicles with new onboard sensors to ensure that the vehicle does not drive on fossil fuel. This burden would likely fall on consumers, who may face higher prices and additional maintenance costs. It would be better to invest these resources in more mature and energy-efficient technologies such as battery-electric vehicles. In contrast, BEVs offer transparency, with the energy source directly linked to an increasingly green electric grid, which is increasingly being decarbonised. Allowing e-fuels onto the market without robust consumer protection policies risks misleading consumers and potentially undermining public trust in the EU’s environmental objectives.
4. Impact on air quality and public health
E-fuels produce comparable levels of pollutants – such as nitrogen oxides (NOx) and particulate matter – as traditional fossil fuels. These impact air quality and public health, particularly in urban areas.[1] Europe’s cities already face air quality challenges; introducing e-fuels could further compromise efforts to reduce pollution in densely populated areas. By simply maintaining levels of harmful emissions, e-fuels undermine the EU’s objective of improving public health outcomes through cleaner transportation.
[1] E-Fuels: Current Status and Projections - PIK Potsdam Institute for Climate Impact Research
Policy recommendations for protecting consumers’ interest in the clean mobility transition
- Limit e-fuel use post-2035
Minimise the role of e-fuels in post-2035 vehicle sales, ensuring that only renewable-based e-fuels qualify. This measure will help direct investments to technologies with clear and measurable environmental benefits. We therefore reiterate our full support for both the 2035 zero-emission targets for cars and vans and the inter-institutional agreement set out in a European Commission statement[1] and confirmed by recital 11 of the CO2 Standards Regulation on the introduction of synthetic fuels beyond this date. If there were to be any role for alternative fuels, it should be minimal, and limited to vehicles running exclusively on 100% climate neutral RFNBOs.[2]
- Introduce consumer protections against high costs and misrepresentation
Develop consumer protection policies to mitigate against the high cost of e-fuels, provide transparency around their pricing and use and to prevent misleading claims on their benefits. For example, establishing clear labelling standards and specific nozzles for e-fuels could reduce confusion and help consumers avoid paying premiums for fuels that fail to meet expected environmental standards. In addition, supporting demand for energy-efficient transports (such as BEVs) will create more affordable mobility options.
- Prioritise energy efficiency in mobility investments
Encourage energy efficiency as a guiding principle for all public and private transport investments. By supporting the deployment of proven energy-efficient solutions such as BEVs, the EU can build a more affordable and accessible pathway to clean mobility.
[1] Commission Statement on CO₂ Standards for Light Commercial Vehicles - European Commission [2] Renewable liquid and gaseous fuels of non-biological origin
Conclusion
The Platform for Electromobility calls on MEPs to consider the risks posed by e-fuels. While potentially valuable in hard-to-abate sectors, e-fuels threaten to introduce higher costs, regulatory uncertainty and health risks in the transport sector. By maintaining its focus on energy efficiency and consumer protection, the EU can safeguard the interests of its citizens and ensure a smoother, more-affordable transition to clean mobility.
"While e-fuels hold potential for hard-to-electrify sectors, their use in road transport would drive up costs, delaying decarbonisation, and harming public health. MEPs must ensure energy efficiency and consumer protection remain the cornerstones of Europe’s mobility transition."
— Alex Keynes, Clean Vehicles Manager at T&E
Our recommendations to Commissioner for Climate
INDUSTRY - FLEET
The Clean Industrial deal’s success relies on stable legislation on both demand and supply sides
Our recommendations for Wopke Hoekstra
Commissioner-designate for Climate, Net-Zero and Clean Growth
As a new EU mandate begins, the members of the Platform for Electromobility remain dedicated to advancing sustainable transport solutions that drive decarbonisation across all land transport modes in Europe. To achieve this and support Europe in its energy transition, it is crucial to align supply-side policies and strong demand-side measures to ensure a successful decarbonisation of transport; one of the EU’s most polluting sectors. This will require a balanced approach where climate goals are met while addressing the needs of citizens, consumers, and industry. A coordinated effort between the European Green Deal and a Clean Industrial Deal will be key to driving sustainable progress and maintaining Europe’s leadership in clean mobility.
Below, we outline our recommended priorities for the incoming Commissioner for Climate, Net-Zero and Clean Growth for ensuring that European climate policies consider industries and consumers needs while meeting Europe’s long-term climate objectives.
1/ Supply side policies: a steady regulatory framework covering the whole value chain
The Clean Industrial Deal should complement and perfect the European Green Deal, rather than replace it. The two packages must work together to achieve Europe’s climate and industrial goals, particularly as we enter a period of rapid transformation in the transport and mobility sectors. Industrial policy should enable —not dilute— the climate targets that the EU has committed to, ensuring Europe maintains its leadership in clean transportation deployment.
When it comes to decarbonation of transport, legislative clarity and objectives are key. This is particularly true to ensure the successful roll-out of zero-emission vehicles by 2035. We must first safeguard such a flagship target while ensuring that consumers—whether individuals or businesses—are buying-in to the transition and support European car manufacturers in this centurial challenge.
The Platform for Electromobility is very concerned by recent statements calling on the incoming European Commission to reverse the already agreed on CO2 Standards for cars and vans. Today, the 2035 zero emission cars goal is Europe’s most straight-forward EV industrial strategy bringing vital investments to European companies. We thus strongly warn against undermining key EU legislation already agreed by MEPs and EU countries in the last legislative period. Attracting investments to create the net-zero industrial ecosystem for zero-emission mobility is not possible without a consistent, clear regulatory framework. To “hit reverse” now would also significantly penalise all industrial actors, including many of our members, who have already invested in this transition (automotive, batteries, infrastructure, etc.).
More details: Reversing the 2035 zero emission cars goal will harm EU industry (June 2024)
Key Policy Asks:
Ensure the continued implementation of the 2035 zero-emission vehicles target to maintain regulatory certainty and attract investment.
Ensure swift and coherent implementation at national level of other Green Deal measures notably related to charging infrastructures and renewable energies.
The Platform for Electromobility sees the European Green Deal as a long-term strategy to ensure Europe’s global competitiveness and climate leadership. This long-term strategy should now be accompanied by an actionable industrial policy plan. Any such future industrial policy, to be comprehensive, should include a focus on the electromobility manufacturing ecosystem. We underline the need for a holistic approach, covering the entire value chain for clean transport solutions (upstream and downstream) and understanding the particularities of Europe industrial and transport systems. Finally, industrial policy should rely on a stable regulatory framework and reinforced international cooperation.
We advocate for a 360° e-mobility industry strategy that addresses the full value chain—from raw materials to end products—across all modes of sustainable transportation. This includes a focus on upstream (refining) and downstream (recycling) sectors to strengthen Europe’s industrial base. Additionally, we stress the need for policies to address energy-cost disparities and support public procurement that favours European-made products. It is also crucial to support workers in transitioning to new skills required for the green economy.
– More details: Five steps towards a 360° e-mobility industry strategy (March 2024)
– More details: Invest skills for competitive, sustainable, European transport industries (June 2024)
Given the escalating climate investment gap, we propose the creation of a comprehensive Net Zero Investment Plan. This plan should not only focus on innovation but also provide limited-in-time yet predictable support for operating expenses and production. It should consider higher-risk ventures and be structured under the EU Multi Financial Framework and new bond issuance programs. Coordination of state aid measures at the EU level will ensure a level playing field and support Europe’s climate and mobility objectives.
More details: Invest in manufacturing for competitive, sustainable, European transport industries (June 2024)
Robust international cooperation is essential to mitigate geopolitical and dependency risks. The EU should prepare responses to global green industry support programs carefully to avoid a subsidy race. Strengthening cooperation with major economic powers and diversifying sources of green technology will help reduce dependencies and secure supply chains. Furthermore, intra-European cooperation should be encouraged to optimize the procurement of strategic raw materials.
– More details: Strengthening EU’s electromobility ecosystem in the global race. (March 2023)
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 call next Commissioner to supporting the transition to PFAS-free solutions in the sustainable mobility sector, and call for measures to eliminate all emissions released during the life cycle as soon as viable industrial alternatives are available. Primary collective objective should be to reduce, and where possible, phase out the use of PFAS following the REACH risk management approach across all mobility industries.
– More information: Our statement on PFAS in sustainable e-mobility (April 2024)
Key Policy Asks
Ensure upcoming Clean Industrial Deal considers the whole e-mobility value chain’s competitiveness rather than focusing on a few components or modes.
Financing the energy transition in the long term with a Net Zero Investment Plan
Strengthening international cooperation to avoid trade disruption and diversify sources while ensuring a level-playing field.
Grant appropriate derogation periods necessary for testing alternatives and bringing them to the market and allow for the use of PFAS where no alternative is available while ensuring they are replaced as quickly as possible.
2/ Demand-side measures: a stable framework for consumers to show the way, corporate fleets to pave the way.
The next step in accelerating the transition to electric mobility is to propose a legally binding a corporate fleet mandate, ensuring that companies and large fleet owners, currently lagging behind[1], play their part in electrifying transport. Corporate fleets represent a significant portion of vehicle sales and are pivotal to creating a vibrant second-hand market for EVs. A well-regulated corporate fleet mandate would not only speed up the decarbonization of the transport sector but also ensure that EVs become more affordable for the broader public. We trust the next European Commissioner for Climate will work closely with next European Commissioner for Sustainable Transport in proposing clean corporate fleet initiatives.
– More details: Guidelines for mandating ZEV in corporate and urban fleets (September 2021)
The previous European Commission already laid the groundwork with the public consultation on corporate fleets, and now is the time to build on that momentum. A strong mandate would require companies to transition their vehicle fleets to electric, generating a steady supply of second-hand EVs. Two-third of Europeans purchase their vehicle on the second-hand market. Such measures would particularly benefit lower-income households who might otherwise struggle to afford new electric models and be left aside of the energy transition.
This policy will also support a smoother and more inclusive transition to e-mobility, helping to lower transportation costs for consumers while contributing to the reduction of air pollution and greenhouse gas emissions. To go further, we also invite the European Commission to investigate other potential demand-side measures to be implemented at national level (e.g. social leasing, scrappage schemes, sustainable taxation) to support the transition.
Key policy ask:
Propose a legally-binding corporate fleet mandate to accelerate the electrification of transport and generate a second-hand EV market that broadens access to affordable, zero-emission vehicles.
Investigate the opportunity of other measures to boost the demand of clean mobility solutions.
[1] https://evmarketsreports.com/corporate-ev-adoption-in-eu-lags-behind-private-households-raising-concerns/
Support the roll-out of zero-emissions vehicles across all modes
Net Zero Investment Plan
Area 7: Invest in new, decarbonised fleets (5.7%)
Accelerating the transition to sustainable transport involves electrifying corporate and leasing car fleets, van and truck fleets, and acquiring zero-emission trains, with targeted funding and incentives playing a crucial role in promoting widespread adoption and achieving ambitious climate goals.
Investment Areas
Fleet renewal Priorities
Electrification of Corporate and Leasing Car Fleets
Electrification of Van and Truck Fleets
Acquisition of Zero-Emission Trains
- Electrification of Corporate and Leasing Car Fleets
Electrification of corporate and leasing car fleets presents a significant opportunity for accelerating the transition to sustainable transport. A European ‘Marshall Plan’, akin to the post-COVID recovery plan, could play a pivotal role in expediting fleet renewal over a ten-year period. By providing targeted funding and incentives, Europe can encourage the widespread adoption of electric vehicles within corporate and leasing fleets, thus reducing emissions, promoting innovation and stimulating economic growth.
- Electrification of Van and Truck Fleets
Electrification of van and truck fleets is essential for achieving ambitious climate goals and reducing emissions from the transport sector. Investing in electrification of commercial fleets can yield substantial environmental and economic benefits.
- Acquisition of Zero-Emission Trains
As Europe transitions to zero-emission transport, there is a pressing need to acquire new zero-emission rolling stock to replace ageing diesel fleets. Given that the average lifespan of rolling stock in Europe is approximately 30 years, targeted investments in zero-emission trains will be crucial for phasing out diesel propulsion and advancing rail electrification efforts. Infrastructure managers and operators – particularly in Central and Eastern Europe where rolling stock fleets are older – stand to benefit significantly from investments in new zero-emission rolling stock. By supporting the acquisition of zero-emission trains, Europe can modernise its rail infrastructure, reduce emissions and promote sustainable mobility throughout the continent.
Eight steps for an efficient legislation to increase the share of zero-emission vehicles in corporate fleets
Greening corporate fleets initiative
Eight steps for an efficient European legislation in 2023
In June 2022, the European Parliament voted for a de facto ban on sales of internal combustion engines (ICE) vehicles by 2035. To reach this objective, the Parliament also voted in favour of creating additional measures, notably to support the demand for zero-emission passenger cars and light-commercial vehicles (ZEV) within the Union market (AM. 80). It is essential that these accompanying measures are as ambitious as those of the end goal. A fleet mandate to cover the period prior to 2030 would ensure that demand meet supply.
In May 2021, the Platform for electromobility, an alliance of 40+ industries, NGOs and associations covering the whole value chain and promoting the acceleration of the shift to electric mobility, outlined the benefits and opportunities of dedicated legislation to complete the decarbonisation of corporate fleets. This paper now provides policy makers with overarching principles that should lead the elaboration of the upcoming legislative proposal that will bind the electrification of corporate fleets.
1. Standalone legislation on private fleet
As indicated by the use of the plural ‘proposals’ in the approved text, we recommend that the European Commission prepare two separate, dedicated pieces of legislation; one on the private fleet, the other on the public fleet. While the latter should be addressed in the revision of the Clean Vehicle Directive (CVD), and invite Member States (MSs) to lead by example with ambitious electrification plan for public authorities’ fleet, we must note that 99%1 of fleet-owned cars are the property of private individuals. The dynamics between private and public fleets are also different in areas such as size, procurement rules, and thus should be treated separately. In addition, as the first reference period under the CVD has only just begun, we believe any revision to the Directive would be premature.
The priority should therefore be given to address the decarbonisation of private fleets, which represent more than 60% of EU sales.
2. Need for a Regulation
While the revision of the CVD is appropriate to decarbonise the public fleet, we believe a Regulation, rather than a Directive, is essential to electrify the private fleet. A Regulation would:
- Stimulate deployment of electric mobility throughout the EU before ICE phaseout, by accelerating decarbonisation of the corporate cars that drive more than 2.25 times further than individually owned cars.
- Boost zero-emission uptake in the B2B segment, for which the total cost of ownership is superior, because of higher annual mileages.
- Create a plentiful second-hand market that ensures affordability of zero-emission vehicles before 2035.
- Avoid the delays in implementation that a Directive might entail, such as those that can currently be seen with the Clean Vehicle Directive. While climate change remains an ongoing threat, the time needed to conclude negotiations on a Regulation would be compensated for by the inevitability of its direct implementation. A Regulation will reduce the transition time to electric mobility between those Member States that have already announced the phaseout of ICEs by 2030 and those yet to do so.
- Bring certainty to both EV manufacturers and those companies purchasing targeted fleets. Such certainty for manufacturers, along with ambitious CO2 emission performance standards for new cars and vans, will ensure that the supply of EVs is able to meet the EU’s climate ambitions. It will also help avoid companies competing for a limited supply of ZEVs.
- Introduce stronger safeguards than a Directive against potential Member State market distortions, notably in the form of unfair price increases for the private fleet owners.
3. Almost-complete decarbonisation by 2030
The final target should be 95% of new fleet purchases of passenger cars to be ZEVs by 2030. The last 5% would be difficult to decarbonise, both technically and economically, due to the existence of some specialty vehicles. Setting the final target at a lower level, or after 2030, would not unlock the 10 benefits of mandating the decarbonisation of corporate fleets.
In the area of light-duty vehicles, the market of vans is more limited in supply compared to passenger cars. Therefore, the sector should have both a dedicated trajectory and a dedicated fleet size threshold, above which the Regulation will apply. Vans, with their own specificities, cannot follow at the same pace as cars. Their lifecycle is longer (28 years average) and their usages are usually unique and adapted to specific professional needs. In order to respect the nature of this market, targets must be adapted accordingly. Platform members agree on the need to build a dedicated trajectory and targets for Light Commercial Vehicles (LCVs), although an impact assessment is needed to shape the timeline and the curve appropriately.
While a 95% final target for passenger cars would already ensure a certain level of flexibility, the text voted by the Parliament invites the Commission to also take into account regional disparities.
4. Flexibility measures
Targets should therefore be set at EU level rather than differing targets per Member State. This would prevent some arbitrage strategies from manufacturers and overpricing in those countries in which targets would have been higher.
Setting targets at a European level, based on a certain fleet size, would also ensure that large companies meet the fleet target in each Member State in which they operate. This would ensure that separate strategies are not in place in different countries. Currently, in the numerous electrification strategies of companies operating across Europe, efforts are being centralised on more advanced markets, setting aside those markets where electrification of transport is lagging behind. This must change, as a ZEV second-hand market should be developed in CEE Member States as a matter of urgency.
Given the need to decarbonise the B2B segment in every Member State, while simultaneously taking into account the current differing starting points and ability for companies to effectively procure new
ZEVs, we strongly suggest two types of flexibilities that could be granted. One, a delay of a maximum of two years of the mandate, and two, an increase in the minimum fleet size to which the mandate applies.
It is important that, when it comes to eligibility for such flexibilities, the two types should be applied either at Member State level or at company level. Whichever option is chosen, the flexibility requests should be reviewed and assessed by the European Commission to ensure harmonisation at EU level.
Flexibility is essential to ensure the fair transition to clean fleets, as are interim targets:
5. Interim targets
Interim targets are essential to ensure a gradual and smooth transformation of the European private fleets. Without ambitious short-term targets, and even taking into account the proposed flexibilities above, fleets covered by the Regulation would need to undergo drastic change shortly before the final deadline. An unanticipated increase in demand risks triggering uncertainties not only for the business models of fleet owners and users but also for the availability, sustainability and security of the value chain for ZEVs. Hence the importance of ambitious interim targets, clearly set ahead, to increase visibility for car manufacturers and fleet managers alike. The objective of the Regulation is to accompany the shift introduced by the de facto ban on sales of ICE vehicles for users, but also to ensure demand matches supply all along the transition.
Although setting an interim target for 2025 may seem a tight timeline for a legislation to enter into force in 2024, a 2025 target close to half of all newly procured vehicle in corporate fleets to be zero-emissions is reachable: market analysis show an organic share of ZEV in fleet purchases of up to 35%. A recent study, based on 1300 fleets representing over 46,000 vehicles across Europe, shows that nearly 60% of fleets could save money by transitioning to electric vehicles without any incentives.2 With little impact – and a positive one in most cases – on the purchase decisions of corporate fleets, such a target for 2025 would allow the creation of a secondary market to make EVs more accessible by 2030. A linear trajectory for a convenient transition to 95% final target procurement would then set the following interim targets:
(1) by 2025, 45% of renewed vehicles are zero-emission;
(2) by 2026, 55% of renewed vehicles are zero-emission;
(3) by 2027, 65% of renewed vehicles are zero-emission;
(4) by 2028, 75% of renewed vehicles are zero-emission;
(5) by 2029, 85% of renewed vehicles are zero-emission;
(6) by 2030, 95% of renewed vehicles are zero-emission.
6. Stock target
In addition to renewal targets focusing on the share of ZEV in the new acquisitions of corporate fleets, stock targets should also be included. Stock targets would avoid creating long-term leasing contracts on ICE vehicles just before each interim renewal targets enter into force. On top of annual targets for new vehicles entering the fleet, a 75% zero-emission target for the whole fleet by 2030 should be inserted to prevent companies signing long-term ICE lease or bulk-buying ICE vehicles in 2023 or 2024, in other words before the regulation enters into force.
7. Reporting
Reporting should be managed by Member States and supervised by the European Commission. Alternatively, France offers a testbed for reporting obligation for a similar mandate. In France, there are reporting obligations for all companies based in the country that fall under the decarbonisation mandate of January 2021. Declarations are made on an annual basis, and are reported on the French government’s open data website. These include a CSV file with information relating to company registrations, descriptions of the fleet and of the low emissions / very low emissions renewal of vehicles Y1. Member States could rely on such a declarative open data by the companies to then aggregate the input and send it to the European Commission for compilation. A control, based on licence plates registered to a national registration agency or equivalent, should be conducted by the Government to verify the data entered by companies for their annual reporting.
Member States should, on an annual basis, send the aggregated data collected nationally to the European Commission to provide an EU-wide overview of the situation.
8. Revision of the objectives
The Regulation should introduce a review clause, by 2028, in the event that the objectives are not achieved. This clause would allow the European Commission to propose additional measures to ensure the Regulation is properly applied in every Member State.
Platform members also recognise the positive impact that such a mechanism would have on the decarbonation of heavy-duty vehicles. At the same time, platform members equally stress the importance of support mechanisms for the rollout office-based charging, from subsidies to tax discounts.