Ref. Ares(2022)8257309 - 29/11/2022
June 2022
Review of the CO2 emission
standards regulation for
heavy-duty vehicles
ACEA Position (draft v6)
REVIEW OF THE CO2 EMISSION STANDARDS
REGULATION FOR HEAVY-DUTY VEHICLES (EU)
2019/1242
KEY MESSAGES
• Vehicle manufacturers are committed to swiftly reducing CO2 emissions by
bringing an increasingly wide range of zero-emission vehicles to the
market, their uptake largely depends on transport operators being able to invest
in and operate them profitably. The right
enabling conditions must be put in
place, namely a sufficiently dense network of charging and refuel ing
infrastructure and an effective carbon pricing system, to ensure a swift adoption
of zero-emission vehicles.
• ACEA supports the review of the CO2 emissions reduction target which should
now be set as a
fixed ambition level for 2030.
•
Target levels for 2035 and 2040 can be set now but should be reviewed
again in due time in view of the status of the enabling conditions, especial y the
charging and refuel ing infrastructure network.
•
ACEA does not support setting intermediate targets before 2030.
• Despite manufacturers’ focus on zero-emission vehicles, the internal
combustion engine (ICE) wil continue to play an important and long-term role
in several heavy-duty applications if and to the extent they are powered by
fossil-free fuels. Therefore,
ACEA does not consider a general 100%-target
or an ICE phase-out date across the board or for all vehicle groups to be
a reasonable policy measure at this point in time.
• ACEA strongly recommends that the current
credit and debit system is
improved further and extended beyond 2030. Provisions that prevent credits
from being transferred to a subsequent compliance period should be removed,
so that surplus credits can be better matched with product cycle developments.
•
Strong and effective incentives schemes for zero-emission vehicles must
be put in place to encourage and enable transport operators to invest in the new
vehicles and accelerate fleet renewal investments with a focus on the latest
technologies.
• ACEA supports the inclusion of
additional vehicle groups in the CO2 emission
standards regulation where a CO2 certification framework is already in place
www.acea.auto
1
and provided that the specificities of the different vehicle segments are ful y
accounted for. Adding new vehicle groups implies that new, individual baselines
for these vehicles will need to be determined.
www.acea.auto
2
BACKGROUND
CO2 emission standards for heavy-duty vehicles have been in force since 2019 when
regulation (EU) 2019/1242 was first enacted. The regulation set targets to reduce CO2
emissions from the most relevant heavy-duty vehicle segments by -15% in 2025 and
by -30% in 2030 relative to a baseline of the average certified emissions of new
vehicles registered in the reporting period 2019. As stipulated in Article 15, key
elements of the emission standards regulation shal be reviewed by the end of 2022.
ACEA welcomes this review as an important opportunity to assess the effectiveness
of the regulation, adjust different elements, expand its scope and most importantly to
ensure alignment with other important regulations, such as the ‘Fit for 55’ package, as
part of the enabling framework that facilitates and drives the transition to climate
neutrality.
With the fol owing remarks, ACEA provides its perspective on the review of the CO2
standards regulation for heavy-duty vehicles.
GENERAL REMARKS
European commercial vehicle manufacturers have repeatedly expressed their
commitment to the climate neutrality targets and to decarbonisation by 2050 at the
latest. It is the joint understanding of all manufacturers that climate neutrality in road
transport by 2050 at the latest implies that by 2040 al new commercial vehicles sold
must be fossil-free1. The CO2 standards regulation for heavy-duty vehicles is one,
albeit important element of the wider regulatory framework that shal enable, facilitate
and drive the transition of the road transport sector to climate neutrality.
Even though the CO2 emission standards regulation has only been in force less than
three years, manufacturers are already wel on the way of implementing their strategies
for a rapid decarbonisation of road transport. It requires a fundamental shift in the
powertrain technologies used in road transport, away from diesel as the dominant
energy carrier to low- and especial y zero-emission vehicles. Zero-emission vehicles,
namely battery-electric and hydrogen-powered vehicles, wil have to become the
backbone of road transport if the sector is to reach its decarbonisation targets.
Accordingly, al manufacturers have started the series production of battery-electric
trucks or are in final stages before series production. More than a dozen different
1 ACEA – PIK Joint statement “The Transition to zero-emission road freight transport”, December 2020
https://www.acea.auto/files/acea-pik-joint-statement-the-transition-to-zero-emission-road-freight-
trans.pdf
www.acea.auto
3
battery-electric truck models are available today in various configurations that can be
adapted to the individual specifications needed. Availability of battery-electric vehicles
is expanding rapidly. The models already available today offer up to 44t GTW (gross
train weight) with regular payloads. Depending on configuration, they can be operated
in different mission profiles such as long-haul, regional distribution, construction.
The first hydrogen-powered (fuel-cel electric) trucks, as the second major zero-
emission powertrain technology, are already in customers’ hands to gain real-world
experiences in regular day-to-day operations. Several manufacturers have announced
the start of series production of fuel-cel electric vehicles (FCEV) from 2024. It is
expected that hydrogen powered-trucks wil become widely available during the
second half of this decade (2025 – 2027).
Zero and low-emission heavy-duty vehicles (buses and coaches)
Name
GVW (t) Application
Range (km)* Availability
Iveco
EWAY
BEV
20/30 t
City bus
Series production
CREALIS
Trol eybus 30 t
City bus BRT
unlimited
Series production
CROSSWAY LE
BEV
20 t
City bus
2023
CROSSWAY LE
BEV
20 t
Intercity bus
2023
Daimler Truck
eCitaro Solo
BEV
20t
City Bus
200 - 320
Series production
eCitaro Artic.
BEV
20t
City Bus
180 - 220
Series production
eO500U
BEV
City Bus
up to 250
announced 2022
MAN
Lion's City 12 E
BEV
City Bus
up to 350 km Series Production
Lion's City 18 E
BEV
City Bus
up to 350 km Series Production
Lion's City 12 E
BEV
City Bus
up to 350 km Series Production
Scania
Citywide
HEV
20t
City Bus
Series Production
Citywide
BEV
City Bus
250
Series Production
Volvo Trucks
7900 Electric
BEV
19,5
City bus
7900 Electric Articulated
BEV
30
City bus
7900 S-Charge
HEV
19
City bus
7901 S-Charge Articulated
HEV
29
City bus
BZL Electric
BEV
19,5
* Currently, there is no official methodology how the range of alternatively powered vehicles should
be determined. Figures are based on the manufacturers’ individual assessment.
www.acea.auto
4
Zero and low-emission heavy-duty vehicles (trucks)
Name
GVW (t) GTW (t)* Application
Range (km)**
Availability
Iveco
Nikola Tre
BEV
40t
General Haulage
up to 550
2022
Nikola Tre
FCEV 40t
General Haulage
>800
2023
DAF
LF Electric
BEV
19t.
Urban/National
240-270km
Series production
distribution
Urban/National
CF Electric
BEV
20t
37t
200-230km
Series production
distribution
Urban/ National
CF Electric
BEV
29t
37t
200-230km
Series production
distribution
CF Hybrid
HEV
20t
40t
National distribution
50km electric
Field trial
ICE
National distribution/
XF Hydrogen
20t
44t
600-800km
prototype
H2
long-haul
Daimler Truck
Series production
eCanter
BEV
7.49t
Urban delivery
100 km
since 2017
Series production
eActros 300
BEV
19t - 27t 40t
Regional delivery
300 km
since 2021
Series production
eActros 400
BEV
27t
Regional delivery
400 km
since 2021
eEconic 300
BEV
27t
Municipality / urban
100 - 150 km
2022
delivery
eActros
Regional
Series announced for
BEV
40t
500 km
LongHaul
delivery/long haul
2024
GenH2
FCEV
40t
Long haul
Prototypes
Series announced for
GenH2
FCEV
40t
Long haul
up to 1,000 km 2027
MAN
eTGM
BEV
26
Distribution
up to 180 km
Short Series
Series Production
eTruck
BEV
tbd
tbd
Distribution
tbd
announced for 2024
Customer demo fleet
Bayernflotte
FCEV tbd
tbd
Long Haul
tbd
2024
Scania
Long haul /
HEV
36
15
Series Production
distribution
PHEV
36
Distribution
60
Series Production
25L or 25P
BEV
19
Distribution
100
Series Production
25L or 25P
BEV
29
Distribution
250
Series Production
R- or S-
BEV
29
64
Regional
Up to 420
Sales start 2022
Distribution/
BEV
29
64
Regional/ Long haul/ Up to 490
Series production 2024
Construction
Volvo Trucks
FH Electric
BEV
44
Regional
300
Sales start 2021
FM Electric
BEV
44
Regional
380
Sales start 2021
www.acea.auto
5
FMX Electric
BEV
44
Construction
320
Sales start 2021
FE Electric
BEV
27
Distribution
200
Sales start 2019
FL Electric
BEV
17
Distribution
300
Sales start 2019
Renault
Trucks
Master Z.E.
BEV
3,5
Distribution
up to 120
Series production
D Z.E.
BEV
16
Distribution
up to 400
Series production
D Wide Z.E.
BEV
20&27
Distribution & city
up to 200
Series production
construction
Production start Q4
T electric
BEV
44
Regional
300
2023
Production start Q4
C electric
BEV
44
Urban construction
300
2023
* Gross Train Weight (in t)
** Currently, there is no official methodology how the range of alternatively powered vehicles should
be determined. Figures are based on the manufacturers’ individual assessment.
Rapid technological developments are currently under way on zero-emission
powertrain technologies that enable the transition to climate neutrality. It is clear
already today that suitable low- and zero-emissions solutions for almost al vehicle
segments and many use cases are either available or wil be ready within the decade.
ACEA expects that zero-emission technologies wil evolve further and mature rapidly,
so that the main chal enge wil be in creating an enabling framework that facilitate a
swift market uptake.
DECARBONISATION PATHWAYS
VEHICLES WILL NOT BE THE BOTTLENECK
While vehicles wil not be the bottleneck for the decarbonisation of road transport, the
market adoption of low- and especial y zero-emission vehicles largely depends on
transport operators and their ability to invest in and profitably operate them. Vehicle
manufacturers pursue different strategies to meet the CO2 reduction targets. However,
al these strategies are based on a growing share of zero-emission vehicles, namely
battery-electric and hydrogen-powered vehicles.
Already the current 2030 target (-30%) requires a significant share of these zero-
emission vehicles. Based on the current regulatory framework, ACEA estimates that
by 2025, approximately 40,000 battery electric medium- and heavy-duty vehicles wil
need to be in operation in Europe. By 2030 this figure wil have to increase to at least
270,000. In addition, at least 60,000 hydrogen-powered trucks wil have to be in
www.acea.auto
6
operation by 2030. Different manufacturers have announced even higher ambitions for
the share of new zero-emission vehicles by 2030, provided that al elements of a
comprehensive enabling framework are in place. Industry projections which ensure
compliance with the current CO2 targets do exceed earlier projections made by the
European Commission2, but they do heavily rely on respective adjustments to the
enabling framework.
MARKET UPTAKE OF ZERO-EMISSION VEHICLES
(ZEV)
For the last 100 years, road transport has relied entirely on increasingly fuel-efficient
and low-emission combustion engines and is now at the beginning of a transition to
new powertrain vehicles which help pave the way to climate neutrality. This
fundamental transformation of the whole sector wil have to take place rapidly within
the next one or two decades. At the same time, the transformation and market uptake
of new powertrain vehicles does not only rely on the availability of the vehicles
themselves, but also on a comprehensive framework of enabling conditions, such as
a dense infrastructure network of charging and hydrogen refuel ing stations and
competitive total costs of ownership (TCO). While the deployment of zero-emission
vehicles and the necessary charging and refuel ing infrastructure wil have to progress
2 In its Smart and Sustainable Mobility Strategy (SSMS), December 2020, the Commission a
milestone of 80,000 zero-emission lorries in operation by 2030 https://eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=CELEX:52020DC0789&from=EN
www.acea.auto
7
hand-in-hand, the market uptake for the main vehicle segments (long haulage) wil
remain limited in the beginning. However, once the enabling conditions are well
established, the vehicle market uptake wil be swift across al vehicle segments.
THE FUTURE OF THE INTERNAL COMBUSTION
ENGINE (ICE) IN HEAVY-DUTY VEHICLES
It is the joint understanding of al commercial vehicle manufacturers, that despite their
focus on zero-emission vehicles, the internal combustion engine (ICE) wil continue to
play an important and long-term role in several heavy-duty applications. Therefore,
ACEA does not consider a general 100%-target or an ICE phase-out date across the
board or for al vehicle groups to be a reasonable policy measure at this point in time.
According to current industry assessments, the ICE wil have a long-term future in
heavy-duty vehicles until 2040 and beyond, if powered by fossil-free fuels. In fact,
internal combustion engine vehicles powered by fossil-free fuels wil be part of the
decarbonisation pathway of the road transport sector. In any case, their relative
contribution to road transport emissions wil likely be limited as applications wil be
focussed on very demanding, heavy-payload and long-haul applications, especial y
where a sufficiently dense network of recharging and refuel ing stations is missing.
Contrary to the arguments of some, setting a general ICE phase-out date for al heavy-
duty vehicle segments now would not provide or increase confidence of market actors
in the need or increase the pace of the transition to zero-emission vehicles. Instead,
such a measure would overly simplistical y focus on the supply-side only, ie vehicle
manufacturers, while neglecting the role of the demand-side, i.e. transport operators.
However, both sides are equal y crucial for a successful transition to climate neutrality
and must therefore be addressed in the regulatory framework.
The political need for a Euro VII regulation covering new ICE is understood, despite
the fact that a new Euro VII regulation would have a minimal impact on reducing heavy-
duty road transport emissions (ie. NOx and particles) compared with fleet renewal by
the latest clean Euro VI vehicles in paral el to increasing decarbonisation. However,
the stringency of Euro VII wil have a big impact on (a) fuel consumption and CO2
emissions, (b) taking resources (engineering and financial) away from decarbonisation,
(c) the viability of recovering investment through diminishing ICE sales and (d) the
attractiveness and TCO of Euro VII vehicles compared to ZEV options. All in al , and
also considering world events, future CO2 targets and Euro VII cannot be looked at in
isolation because the combination of both coming in a similar timeframe could present
a major problem for the HDV industry.
www.acea.auto
8
ESTABLISHING AN ENABLING FRAMEWORK
In addition to
functional, reliable and efficient low- and especially zero-emission
vehicles, two more building blocks are essential for a successful transition to climate
neutrality and must be put into place simultaneously.
• A dense network of charging and refueling infrastructure suitable for heavy-duty
vehicles
• A coherent policy framework which enables and drives the transition to climate
neutrality and ensures affordability and competitive TCOs
Vehicle manufacturers are clearly committed to bringing zero-emission vehicles to the
market and are wel on the way by providing an increasingly wide offering for different
use cases, payloads and ranges (see above). However, the pace of market adoption
of the new powertrain vehicles largely depends on the abilities of transport operators
to invest in and viably operate them. It is therefore essential to establish a solid
enabling framework which is ful y aligned with the necessary emission reductions and
the ambition levels set for manufacturers.
With respect to the
charging and refuelling infrastructure, ACEA reiterates that
policymakers need to be aware that setting AFIR targets for heavy-duty vehicles now,
i.e. ahead of the revision of the HDV CO2 standards, effectively predetermines the
CO2 reductions that can be expected from road transport by the end of this decade. In
other words, if the AFIR targets are set too low, vehicle manufacturers (and the road
www.acea.auto
9
transport sector as a whole) may be severely constrained in their ability to contribute
to the required CO2 reductions.
ACEA therefore refers to its published position on AFIR3 and encourages al
policymakers to agree to the proposed targets that ensure a minimum network
charging and refuel ing stations suitable for heavy-duty vehicles becomes available by
2025 and 2030.
Market adoption of zero-emission vehicles also depends on a supportive regulatory
framework that effectively incentivises fleet renewal and favours zero-emission
vehicles by shifting key cost factors and facilitating TCO-parity. Despite the anticipated
technology improvements, the total costs of ownership and especial y the upfront
investments costs of zero-emission vehicles wil likely remain higher than for
conventional vehicles. However, as long as diesel remains cheaper, low- and
especial y zero-emission vehicles wil not become an attractive and commercial y
viable option for transport operators. The price differential between conventional fossil
fuels (diesel) and zero-emission alternatives (e.g. electricity, hydrogen) does have a
significant impact on the total costs of ownership.
ACEA therefore reiterates that meaningful and effective incentives must be provided
to encourage and enable transport operators to regularly adjust their investments in
the latest technology’ vehicles. The proposed establishment of an emission trading
system for road transport (ETS-24) and the implementation of road charging systems
differentiated by CO2-emissions (Eurovignette5) in member states are key in that
respect.
Several member states have also provided substantial incentive schemes for transport
operators which cover a significant share of the additional costs of new zero-emission
vehicles6.
3 ACEA Position Paper: Proposal for the Alternative Fuels Infrastructure Regulation (AFIR), November
2021 https://www.acea.auto/files/ACEA_Position_Paper-
Alternative_Fuels_Infrastructure_Regulation.pdf
4 ACEA Position Paper: EU Emissions Trading System (ETS) for road transport, December 2021
https://www.acea.auto/files/ACEA_Position_Paper-ETS_road_transport.pdf
5 Directive (EU) 2022/362 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520, as
regards the charging of vehicles for the use of certain infrastructures.
6 Incentive schemes which support transport operators have been put in place in -
amongst others -
the Netherlands, Germany and France. They provide subsidies for investments in zero-emission
vehicles which are limited in time, and which have regularly attracted significant interest from transport
operators. To the extent possible, their key parameters should be harmonized across the European
Union and be offered with a medium-term perspective to provide planning perspective for operators
while especial y incentivizing early investments and market adoption.
www.acea.auto
10
SPECIFIC ELEMENTS OF THE REVIEW
AMBITION LEVELS
The commercial vehicle market is
driven by demand and the strong focus of
transport operators on the total cost of ownership (TCO). Making vehicles more
efficient has always been a top priority for the truck industry, as this is a key competitive
factor for operators that drives competition between manufacturers. At the same time,
manufacturers need substantial lead times (~5 years) and a predictable and stable
regulatory framework to manage the transition and allow the market to adopt new
vehicle technologies.
While vehicle manufacturers are ful y committed to doing their part for a rapid transition
to climate neutrality, the timing of the transition is not only set by vehicle manufacturers
or their regulations. The road transport market is a B2B market. The ability of the
stakeholders to adjust to changing conditions must be considered. Manufacturers must
be enabled to move with and push the market forward without pushing them to having
to comply with targets that cannot be met by demand.
Especial y the ambition levels in 2030 and beyond are highly dependent on the
enabling conditions, the market uptake in earlier years etc. where the timeframe 2025
– 2030 is particularly sensitive as the ZEV uptake can only be as fast as the
infrastructure rol -out. Therefore, ACEA does not support setting intermediate targets
before 2030 and recommends another review of the 2035 and 2040 targets and other
key elements of the regulation by 2028.
SCOPE OF THE REGULATION
It is expected that the CO2 standard review will add more vehicle groups. Adding new
vehicle groups implies that new, individual baselines for these vehicles need to be
determined.
Since the regular development time for new vehicles is relatively long (in the range of
5 – 7 years), the ambition levels for these new vehicle groups must be set accordingly.
Since some of the new vehicle groups already include a relatively high share of zero-
emission vehicles at the time the baseline is set, this should also be reflected when
setting the CO2 standards. Different market conditions can justify different targets for
different subgroups.
ACEA supports the inclusion of additional vehicle groups in the CO2 emission
standards regulation where a CO2 certification framework is already in place and
provided that the specificities of the different vehicle segments are ful y accounted for.
www.acea.auto
11
The current provision to balance target compliance between different subgroups
should be maintained.
ADDITIONAL VEHICLE SEGMENTS (BUSES, MEDIUM
LORRIES)
Smal and medium lorries
Smal and medium lorries make only relatively low contributions to the total CO2
emissions of the road transport sector. Especial y compared to heavy-duty vehicles,
this segment only represents a relatively smal number of vehicles, many of which
include customised and tailor-fit multi-stage vehicles. It should also be noted that the
CO2 certification framework is currently only available for vehicles above 5t (TPLM).
These specific circumstances should be considered when setting targets for this
vehicle segment.
Set ing standards for buses and coaches
The structure of the industry for bus manufacturing is diverse and several business
models exists. Complete buses are manufactured by OEMs but also by some
bodybuilders. In addition, bus chassis at an early stage of completion are delivered by
OEMs to external bodybuilders for the final completion. From the chassis it is not clear
if it wil become a city bus, an interurban bus or a coach or if it wil be designed as a
single- or double-deck vehicle.
As the bus chassis delivered by the OEMs is too incomplete to identify the intended
use/ mission it cannot be used as basis for a representative declaration of the final bus
or coach. For buses and coaches, ACEA therefore proposes to include actual data of
the bodywork in the CO2 standards
The last stage vehicle manufacturer is legally the responsible party for part of the final
bus and should hence also be responsible for CO2 target compliance for buses and
coaches. As a result, other manufacturers besides the OEMs would also be addressed
with the bus and coach standards regulation. Stil , the ‘big 5’ manufacturers would
remain responsible for about 80% of the vehicles with respect to target compliance.
This structure of the bus business differs significantly from the case of the lorries. The
delivered lorry chassis is at a much more complete stage, including also a cab, and
the correct CO2 subgroup of the lorry can be identified. The bodywork for a lorry has
less impact on the CO2 declaration and are sufficiently covered by relying on standard
bodies in the regulation. For heavy lorries, ACEA considers the chosen approach
www.acea.auto
12
appropriate and cost-effective and believes that it should therefore be maintained in
the future.
A significant share of zero-emission vehicles is already in operation in the European
city bus markets because favourable conditions are already in place in many cases.
This contrasts with the coach market, where the chal enges for the infrastructure
deployment for the shift to zero-emission vehicle is similarly high as for long-haul
lorries.
A relatively higher ambition level of CO2 reduction compared to other vehicle groups
is therefore justified for city buses because of the status of the enabling conditions and
the high share of zero-emission city buses already present.
Vocational vehicles
Vocational vehicles should continue to be exempted from the CO2 emission targets.
These vehicles are designed to meet other specific demands than vehicles which are
designed for the transport of goods (e.g. crane trucks, cement trucks etc.). They are
therefore very difficult to characterise correctly. They also have relatively low annual
mileages; hence their relative CO2 reduction potential is limited and measures for
reducing CO2 emissions and energy consumption are not as cost effective as for other
heavy-duty vehicles used for the delivery of goods.
Trailers/ Semi-trailers
The energy efficiency and emission performance of road transport does not exclusively
depend on the performance of motor vehicles. Efficient trailers and semi-trailers do
contribute significantly to low emissions and high energy efficiency. Therefore, fleet
renewal in the trailer and semi-trailer market should be encouraged to accelerate the
uptake of new, more efficient trailers/ semi-trailers and associated technologies with
energy efficiency standards.
As with VECTO, transport operators should be given transparent information and
guidance to enable them to invest in new, more energy efficient trailers/ semi-trailers.
The currently used VECTO ‘standard trailer’ should be updated accordingly.
With zero-emission tractors becoming more widely available it wil become even more
important to also focus on efficient trailer-/ semi-trailers. However, emission/ efficiency
standards for trailers/ semitrailers class should be regulated separate from motor-
vehicles in a dedicated regulation.
www.acea.auto
13
Credit/ Debit system
ACEA strongly recommends that the current credit and debit system is improved
further and extended beyond 2030. The way the system is currently designed, does
not work effectively. Excess credits should not be removed after every compliance
period.
The exact timing and trajectory of the transition to zero-emission vehicles is difficult to
predict, not the least because it is highly dependent on the enabling framework,
including the rol -out of a dense network of charging and refuel ing stations suitable for
the different vehicle segments. Significant changes of key factors facilitating the market
uptake of zero-emission vehicles can occur between and during each year, especial y
in the 2025 - 2035 period. At the same time, the development of (completely) new
vehicles does usual y require 5 – 7 years. While the commitment and ambition of
vehicle manufacturers to swiftly transition to low- and especial y zero-emission vehicles
is clear, it is particularly chal enging to match the development and required target
compliance, especial y when enabling conditions are highly volatile.
Pooling
Pooling can be an instrument that provides flexibility for manufacturers in reaching their
CO2 reduction targets. It has been successful y implemented in the CO2 regulation for
light-duty vehicles, but important differences must be considered with respect to the
commercial vehicle market. In view of the structure of the commercial vehicle market,
i.e. different manufacturers with differing product portfolios across different vehicle
segments, a pooling mechanism must most importantly not have negative impacts on
competition, disadvantage individual manufacturers and therefore must avoid market
distortion. A pooling mechanism for heavy-duty vehicles should be designed according
to these requirements and with respect to the design of the compliance conditions.
ZLEV incentive mechanism
The ZLEV incentive mechanism should be designed in a way which actual y
incentivises the deployment of zero-emission vehicles in a meaningful and effective
way.
Any change of the current benchmark mechanism, and particularly its level should be
connected to a revision of the current provisions on the cap which should be increased
substantial y or ideal y ful y removed. The current ZEV-benchmark (2% in 2025, cap
5%) was set to stimulate the ZEV deployment. A higher overal reduction target (e.g. -
30% in 2030) obviously requires a higher ZEV-share, beyond the current benchmark.
www.acea.auto
14
The nature and level of the current benchmark should therefore be adjusted
accordingly.
ACEA recommends prolonging the current ZLEV incentive mechanism beyond 2030.
A bonus mechanism should be considered which particularly incentivizes the
deployment of long-haul vehicles as these represent the vehicle segment with the
highest relative emission share. At the same time, due to its specific performance
requirements with high payloads and long distances, this vehicle segment presents the
biggest chal enges for commercial y viable operations of zero-emission vehicles.
A minimum range and transport performance are important parameters for the
classification of a vehicle as a long-haul truck that corresponds to related regulations
on resting times and taxation.
Each vehicle is designed for and adapted to its specific transport mission. Yet, zero-
emission vehicles, with batteries or fuel-cel s, usual y do have a higher total weight.
Setting a ZLEV mechanism that essential y incentivises vehicles to be equipped with
more energy storage than is usual y required for the specific mission would effectively
reduce payload capacity, add extra costs and increase energy consumption. A balance
between these contradictory requirements needs to be found.
ZEV mandates
Manufacturers have strong reservations with respect to ZEV mandates since they
potential y create significant market distortions. They only address the supply side
(vehicle manufacturers) but do not simultaneously also address and with similar
ambition levels the demand side (transport operators). The demand side would gain
one-sided advantages and could potential y strategical y delay investments in zero-
emission vehicles which a manufacturer would have to sel to meet the requirements
of the ZEV mandate. This carries risks of significant market distortion and could also
incentivise transport operators to delay investment decisions for a swift fleet renewal.
More importantly, a ZEV mandate would – per definition – only focus on zero-emission
vehicles while neglecting the CO2 reduction potentials of further improvements of
conventional vehicles. Those improvements would not be recognized with a ZEV
mandate and manufacturers with more fuel-efficient vehicles would effectively be
disadvantaged. These improvements are, however, one of the driving forces behind
the CO2 regulation.
www.acea.auto
15
Fuels
As a matter of principle, ACEA supports flexibilities in the regulation which facilitate
compliance with the CO2 targets without increasing the overal stringency of the
regulation. As described, renewable and low-carbon fuels wil have to play an important
role in cutting CO2 emissions of road transport. The current vehicle fleet and new low-
emission vehicles, that wil be part of manufacturer portfolios to help meet CO2 fleet
targets, wil continue to be composed of vehicles with old, current, and future internal
combustion engine (ICE) technologies for many years. That fleet should also contribute
to road transport CO2 reduction by having faster and greater access to non-fossil low-
carbon sustainable liquid and gas fuels.
The decarbonisation of al energy carriers, including of road transport fuels, electricity,
H2 etc., is therefore a crucial cornerstone of successful transition to climate neutrality.
Despite a declining market share of ICE-vehicles low-carbon and renewable fuels wil
have to play an increasing role in road transport. However, the regulatory framework
to ensure the widespread availability of such fuels in necessary quantities is currently
insufficient. It must be adjusted now to incentivise and rapidly deliver the
decarbonisation of fuels by ensuring that sufficient quantities become quickly and
easily available for all road transport users and at convincing prices.
High-Capacity Transport
High-capacity vehicles, such as the European Modular System (EMS), do positively
contribute to the decarbonisation of road transport. They should not be penalised, but
their more widespread use should instead be incentivised across the European Union
to help further improve transport efficiency and thus reduce emissions.
Today, there are no clear criteria to determine the usage of these vehicles. However,
future reviews should be used to revise provisions that effectively disadvantage
vehicles which are capable of being used in HCT configurations and support their role
in improving overal transport efficiency.
---
www.acea.auto
16
ABOUT THE EU AUTOMOBILE INDUSTRY
• 12.7 million Europeans work in the auto industry (directly and
indirectly), accounting for 6.6% of al EU jobs
• 11.5% of EU manufacturing jobs – some 3.5 million – are in the
automotive sector
• Motor vehicles are responsible for €398.4 billion of tax revenue for
governments across key European markets
• The automobile industry generates a trade surplus of €76.3 bil ion
for the European Union
• The turnover generated by the auto industry represents more than
8% of the EU’s GDP
• Investing €58.8 bil ion in R&D per year, automotive is Europe's
largest private contributor to innovation, accounting for 32% of the
EU total
REPRESENTING
EUROPE’S
15
MAJOR
CAR, VAN, TRUCK AND BUS MANUFACTURERS
ACEA
twitter.com/ACEA_auto
European Automobile
Manufacturers’ Association
linkedin.com/company/acea
+32 2 732 55 50
xxxx@xxxx.xxxx
www.acea.auto
youtube.com/c/ACEAauto