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

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

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

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

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

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

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

Ahead of the vote on the CO2 Standards for trucks and buses Regulation in Plenary of the European Parliament on the 21st November, the members of the Platform for electromobility would like to express their deep concern regarding the potential introduction of low-carbon fuels (advanced biofuels), synthetically produced fuels (e-fuels) and a Carbon Correction Factor (CCF) to account for them, in the CO2 Standards for Heavy-Duty Vehicles (HDVs). We urge you to carefully consider the implications of such a measure and, in the best interests of our regulatory framework and environmental goals, reject its introduction unequivocally.

Opening the door to these fuels into the revisions of the CO2 Standards poses significant challenges. The introduction of a Carbon Correction Factor (CCF) to account for them would be equivalent in lowering the average specific emissions of a certain manufacturer, as per the Impact Assessment of the EC^[1]. Since the Renewable Energy Directive – REDIII already rewards the use of low-carbon fuels like bioethanol, bio-methane or synthetic fuels produced from renewable electricity, with the strongest possible economic incentives by setting sales mandates for the deployment of such low-carbon fuels across all sectors, including freight transport, this would mix well-to-tank (fuels and electricity from RED) and tank-to-wheel (vehicle tailpipe emissions from CO2 standards) regulation,  leading to potentially regulatory inconsistencies and, at its worst, result in unenforceable legislation. This would blur the roles and responsibilities of different market participants, even though this regulation primarily applies to vehicle manufacturers, potentially constituting double counting, as highlighted by NGOs^[2] and studies^[3]

Moreover, beyond the immediate concern of CO2 emissions, the introduction of a CCF could adversely impact air quality, especially in urban areas. Allowing last-mile delivery trucks to emit more pollutants in cities could contradict existing legislation, such as the Air Quality Directive, which was recently adopted in the European Parliament. The directive aims to achieve improved air quality, particularly in cities, by 2030, aligning with the World Health Organization (WHO) standards and ultimately striving for zero pollution by 2050. Lowering the ambition of the CO2 standards for HDVs would run counter to these efforts to enhance air quality.

We understand that there has been debate regarding the competitive advantages of e-fuels compared to battery-electric technologies. However, it is important to note that battery-electric technologies can already satisfy almost all of European freight road transport needs, a share that will likely increase with the growth of intermodal logistical systems.

Furthermore, we emphasize the inherent inefficiency of e-fuels. Renewable and low carbon fuels and, most notably, e-fuels will not be carbon-neutral in time to decarbonize the road transport sector and meet our climate targets. It is worth noting that these fuels are scarce resources sorely needed to reduce greenhouse gas emissions in the aviation and shipping sectors, whereas the road transport sector can easily be electrified. As a result, e-fuels do not provide a viable alternative to existing zero-emission solutions. Estimates indicate that the electricity requirements for the production, transportation, and distribution of various e-fuel types are significantly higher, ranging from approximately 1.6-1.8 times greater for compressed gaseous hydrogen to between 2.2 and 6.7 times higher for liquid e-fuels, in comparison to the direct use of electricity, depending on the specific fuel type. When we account for not just the fuel production phase but also the efficiency losses within the vehicle powertrain during e-fuel usage, the overall efficiency diminishes even further. In addition, E-fuels aren’t currently produced at commercial volumes^[4]. Scaling up additional renewables, electrolysers, direct air capture (DAC) and e-fuel production facilities would take time and larger e-fuel quantities would likely not be available before 2040.^[5]

In conclusion, we urge Members of the European Parliament to carefully consider the potential ramifications of introducing a Carbon Correction Factor in CO2 Standards for Heavy-Duty Vehicles, as it would not bear significant results, while setting a dangerous precedent and creating great uncertainty for European truck manufacturers. We believe that maintaining a clear and consistent regulatory framework, along with our commitment to improving air quality, should guide our decisions in this matter. We appreciate your attention to this critical issue and look forward to further discussions.

In addition, we would like to remind the key recommendations from previously published position:

• keep the ambition of the CO2 emission reduction targets (final and intermediate), to fully decarbonize the sector by 2050, at least as per EC proposal;
• The proposed 2030 target of -45% is lacking ambition and is below what manufacturers have announced. It should be increased to an emission reduction level of at least 65%.
• The proposal’s new definition of zero emission (5 gCO2/tkm) creates a dangerous loophole for continuous sales of emitting vehicles even after 2050. The Platform strongly advocates to keep it as it is (1 gCO2/kWh).
• Keep the 100% ZEV mandate target at 2030 for urban buses, including an intermediary target with a 70% ZEV mandate by 2027 . Two subcategories of urban buses, namely class II low-entry (i.e. 31L2 and 33L2), should be moved into the coach segment.

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].”

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/

The Platform for Electromobility strongly welcomes the revision of the CO2 standards for heavy-duty vehicles (HDV). The Platform sees the Regulation as a fundamental tool for electrifying trucks and thus advancing the zero emission transition within the road freight sector. Currently, this sector is responsible for 24% of the EU’s transport emissions, with trucks making up the largest part. The revision of HDV CO2 standards should align the CO2 targets for the sector with those of 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 emissions, more ambitious standards are needed to set the correct pace and a clear trajectory for manufacturers, logistics operators and for the supply chains in the electromobility and automotive industry. Scaling effects in production and technology development in the e-mobility and transport sector all contribute to making electric HDVs more competitive and widespread.

The Platform calls upon the European Commission to adopt the following recommendations as part of the revision of the HDV CO2 standards:

Strengthening the emission reduction targets to fully decarbonize the sector by 2050.

• Almost all newly registered HDVs (including long-haul) should be 100% zero emission by 2035 at the latest, given the average lifespan of a truck of approximately 15 years.
• An exemption should be considered for some niche vocational vehicles (such as those operating in remote areas or of abnormal weight) with a 100% Zero Emission Vehicle (ZEV) target by 2040, due to their more complex operational requirements and usually significantly lower mileage, which postpones the year of cost parity for the total cost-of-ownership for those vocational vehicles.
• The introduction of an intermediary CO2 target in 2027 of 30% for medium and heavy lorries is necessary to accelerate the transition to electric trucks during the 2020s.
• Strengthening the ambition of the 2030 CO2 target is crucial in providing momentum to, and further scaling up, the production and sales of ZETs. The 2030 target should be increased to an emission reduction level of at least 65%.

Extend the scope of the regulated HDV categories.

• Medium-sized lorries should be regulated through CO2 reduction targets, with the interim target of 30% in 2027 and the 2030 target of 65%.
• Small lorries – as well as urban buses and coaches – should have a mandated ZEV target, as they are not included in either the VECTO monitoring, or the datasets are deficient and hence have no CO2 reduction targets.
• The Platform recommends including small lorries with a ZEV target of 35% in 2027 and of 70% by 2030.
• Urban buses can decarbonise faster, and hence 100% of these should be ZEV by 2027. [1]
• Finally, coaches will transition a bit slower – due to the different vehicle design – with 20% ZEVs by 2027, 60% by 2030 and 100% by 2035.
• Trailers and semi-trailers will benefit from the introduction of energy efficiency targets, as this will unlock the deployment of zero-emission long-haul tractor-trailer combinations. The targets should be set where technically and practically feasible and as early as 2027. The full energy-efficiency potential of 12% for long-haul and 8% for regional delivery should be reached by 2030.

Other regulatory elements.

• The zero or low emissions vehicles (ZLEV) mechanism should be transformed into a ZEV-only mechanism with an enhanced benchmark of 15% by 2027. After 2030, the benchmark mechanism should be removed.
• The possibility of pooling of resources should be explored in the impact assessment, next to the introduction of a straight credit-trading scheme, which might allow for greater flexibility and less regulatory barriers.
• There should not be an exemption for small-volume manufacturers, as it risks creating a loophole for continuing to produce ICE-powered trucks.
• There should be no mechanism for renewable and low-carbon fuels to be included under this Regulation. Under such a mechanism, manufacturers could continue to produce ICE-powered trucks and delay the transition to ZEVs whilst not actually being able to control how fuels are ultimately being used (yet still being rewarded for it).

Ambitious charging infrastructure targets, as discussed in the Alternative Fuels Infrastructure Regulation (AFIR), are elementary for a successful rollout of ZETs. In addition, private as well as public investments will be needed to ensure higher grid capacity to serve the growing truck-charging demand. The revenues from excess emission premiums should be channelled back into the sector for the rollout of the infrastructure network. Related files, such as the Energy Performance of Buildings Directive (EPBD) can act an enabler for a smooth deployment of electric trucks. The platform therefore recommends including infrastructure requirements for charging at depots and logistic hubs.

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

The positive effects of electrifying heavy trucks are far-reaching, and go beyond reducing Europe’s GHG emissions; accelerating the zero-emission truck roll out also allows for drastic improvements to noise and air pollution. The high increase of energy efficiency in the case of battery-electric trucks is particularly beneficial when road transport accounts for 29% of the EU’s final energy consumption. The Platform for Electromobility also wishes to highlight that the transition to electric trucks and buses provides 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 accelerate the unlocking of the potential of the e-mobility value chain.

[1] UITP is currently still considering its alignment with this objective.

The Platform for electromobility very much welcomes the Commission’s willingness to revise the HDV CO2 standards. The standards are a fundamental tool to advance the zero emission transition, as outlined in the European Green Deal and advance the transport sector. More ambitious standards set the right pace and a clear trajectory  for manufacturers and logistics operators. Hence, the revision of the Directive (EC) 2019/1242 is a needed and welcome step of the Commission to lower emissions from trucks and other heavy-duty vehicles. The revision should align the CO2 targets for the transport sector with the EU’s overall -55% GHG reduction target in 2030 and the climate neutrality target of 2050. Importantly the HDV CO2 standards are the single most effective tool to achieve scaling effects in production and technology development, which contributes to making electric HDVs more competitive and widespread.

In particular, the Platform calls the European Commission to prioritise the following:

• Almost all newly registered heavy duty vehicles (including long haul) should be zero emission at the latest by 2035, whilst an exemption can be considered for some niche vocational vehicles (such as construction trucks) with a 100% ZEV target by 2040.
• The introduction of an intermediary target in 2027 is necessary to accelerate the transition to electric trucks already in the 2020s
• Strengthening the ambition in 2030 is crucial to spur the momentum and further scale up production and sales of ZETs.
• Crucially, no mechanism for renewable and low-carbon fuels should be included under this regulation

The Platform wants to stress that with regards to urban buses the revision of the CO2 standards should also take into account the demand-side targets from the Clean Vehicle Directive (Directive 2019/1161), especially when taking into account the purchasing of heavy-duty ZEVs for public authorities. The standards are an important tool to drive down the prices of buses of publicly procured vehicles, making them affordable for public institutions.

Lastly, the Platform highlights that the transition to electric trucks and buses is a considerable opportunity for the European electromobility 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 electromobility value chain.

Electrifying heavy trucks is particularly crucial in the wider context of reducing Europe’s GHG emissions as it makes up the largest part of the HDV emissions and allows to drastically improve noise and air pollution.

Investments need to be made for higher grid capacity to serve truck charging demand.

Directive 92/106/EEC is the only EU legal instrument directly targeting combined transport (CT), incentivising a more sustainable operational model for freight transport. Nearly thirty years later, the effectiveness of the Directive needs to be improved as the freight market and transport have gone through considerable changes. Furthermore, the political context has shifted as well, with an increased ambition on emissions-reduction objectives deriving from the European Green Deal and the Sustainable and Smart Mobility Strategy.

The Platform for Electromobility agrees with the European Commission that, without an intervention to promote the use of multimodal transport, the uptake of more sustainable transport options will not take place to the desired degree and in the desired time-frame to reach 2030 and 2050 EU objectives.

Strengthening combined transport fits perfectly into the vision of an integrated and sustainable comprehensive mobility system. The role of intermodal terminals, in this context, stands out through the optimisation of the connectivity of the different modes, and incorporating rail, roads and waterway systems into the freight logistics chain.

Among the options envisaged by the Inception Impact Assessment, Option 3 appears as setting the most effective way to crucially improve the framework for combined transport in Europe. The extension of the support from today’s narrowly defined combined transport operations to all intermodal or multimodal operations, and the categorisation of terminals based on infrastructure and operational efficiency – both proposed also under Option 2 – would broaden the Directive’s scope and streamline investments for combined transport’s infrastructures.

Moreover, Option 3 foresees an assessment of the efficiency of the measures to support the attainment of the objectives of the revised Combined Transport Directive. This measure would  improve the reporting and monitoring conditions of the Directive.

Following this further, the Platform remains cautious about the viability of Option 4, which envisages mandatory harmonised support measures – such as a support to transhipment costs. Such proposal may open the door to state aid-related questions and be challenged across Member States.

The Platform for Electromobility looks forward to work with the European Commission to ensure that freight transport do not miss the decarbonization revolution and contributes efficiently to a sustainable, integrated and multimodal mobility system for Europe and set best practices for the world.