16/12/2025 |Articles are machine translated
European Commission. | Photo: EC
Although the Automotive Industry Association welcomes the fact that the European Commission is finally coming up with the promised package of measures to mitigate the impacts of overly ambitious automotive targets, at first glance it unfortunately appears that the proposed measures do not provide a clear solution and, on the contrary, create a new level of uncertainty and administrative burden for the sector.
From the perspective of meeting the currently set fleet targets for 2030, when further dramatic tightening is to occur, the proposal unfortunately does not bring the necessary rationalization of targets and at the same time neglects a number of flexibilities that this legislation has historically used.
The only de facto mitigating element is the possibility of averaging the achievement of targets for the period 2030–2032. However, this is completely insufficient from the perspective of the estimated development of the market, infrastructure and demand. The demand for electric vehicles estimated by analysts in 2030 at around 38% remains far behind the regulatory requirement of around 55% of electric vehicles in sales. We are in danger of witnessing a situation similar to that of this year, when the regulation required customers to buy 25% of electric vehicles, but the actual market interest was at 16%. This continues to mean high penalties for car manufacturers and a significant reduction in the supply of vehicles for customers.
AutoSAP has long pointed out that in the case of averaging annual targets over several years, it is appropriate to work with a wider time window, i.e. at least 2028–2032. The proposed three-year averaging means in practice that the European market would have to absorb the de facto same share of 54–58% of battery electric vehicles in each of the years 2030–2032 or start significantly exceeding the targets in 2031 in order to balance out the expected low result in 2030.
As another measure, the Commission proposes partial support for small battery electric vehicles through so-called super credits. Even if we ignore the fact that this category of vehicles only represents around 15% of total vehicle sales in the EU, the benefit of such a measure will only be possible to assess after a detailed analysis – especially considering the fact that they should only apply to vehicles marked as “made in the EU”. However, the content of this definition remains unclear at this point, with the Commission adding it in one of its upcoming proposals.
As regards the 2035 targets, AutoSAP welcomes the slight shift towards technological openness and a future for the combustion engine. This consists of reducing the target from 100% to 90%, with manufacturers to compensate for the remaining 10% through a credit system based on the use of CO₂-neutral fuels and green steel. However, the proposed mechanism is extremely complex, administratively demanding and again conditional on the “made in the EU” criterion, which raises serious doubts about its practical applicability and real benefit.
“The resulting proposal is more of a missed opportunity than a real response to real customer preferences and a deteriorating geopolitical environment. The EU’s original ambitions were set for a world of cheap energy, smooth supply chains and rapidly growing confidence in electromobility – such a world no longer exists. We already see a clear discrepancy between the roughly 16% market share of electric vehicles and regulatory expectations, which are set to increase dramatically in 2030. This discrepancy will deepen dramatically without real flexibilities and will lead to sanctions for manufacturers. Although the proposal formally speaks of technological neutrality, it conditions it with new administrative burdens and its impact on the market remains unclear,” says Zdeněk Petzl, Executive Director of the Automotive Industry Association.
The targeted regulation of heavy-duty vehicles is a positive first step that must now be implemented without delay. However, it must be immediately followed by an accelerated revision of the entire regulation on CO₂ emission limits for heavy-duty vehicles, which cannot be postponed until 2027.
The draft regulation introduces binding targets only for passenger cars and light commercial vehicles at Member State level, for “large enterprises”, while heavy commercial vehicles are explicitly exempted from the proposal.
AutoSAP considers this approach to be wrong and contrary to market reality. For passenger cars, mandatory fleet targets are not an appropriate tool, although the domestic market for electric cars remains relatively small (around 10%), corporate customers already account for around 86% of electric car registrations without any binding quotas. The introduction of mandatory targets could therefore be counterproductive for those entities that naturally drive electromobility. For heavy commercial vehicles, on the other hand, targets for corporate fleets could represent a meaningful tool, as stronger demand impulses from transport customers can help reduce investment risks and accelerate the introduction of zero-emission transport by the transport operators themselves.
AutoSAP considers it fundamentally problematic that the term “made in the EU” is already being used across the entire legislative package without a clear and legally binding definition. This is only to be presented at the end of January as part of the so-called “Industrial Accelerator Act”.
The industry thus finds itself in a situation where it has to implement or evaluate measures with potentially major impacts without knowing their basic parameters. This approach creates a high level of regulatory uncertainty – not only in the area of CO₂ regulation, but across the entire package. All of this will negatively impact the ability of supply chain companies to plan production, as well as further restricting customer supply.
“If the ‘made in the EU’ concept is to be truly beneficial, it must have clear rules and be developed in cooperation with the industry. Otherwise, there is a risk of a level playing field and further deepening investment uncertainty. The European Commission is already working with this concept in several legislative proposals without a clear definition. It is also proposing to introduce it, among other things, into the regulation of CO₂ standards via a delegated act – i.e. without a full-fledged political debate between the member states and the European Parliament,” says Marco Boggian, Head of Regulatory Affairs at the Automotive Industry Association.
The Automotive Omnibus package was intended to be a tool for the real simplification of a number of related regulations of the regulatory framework. In practice, however, it de facto only brings a new definition of small electric cars, which will be able to draw on a number of benefits, but even here it is still necessary to assess whether the proposed parameter – a maximum vehicle length of 4.2 meters – will be beneficial for the relevant spectrum of European manufacturers, or will only benefit a narrow circle of them.
At the same time, the Omnibus mainly brings partial adjustments and reformulations of existing provisions. These may lead to some financial cost savings, however, it is mainly about correcting previously identified shortcomings – that is, correcting “errors” that were pointed out from the very beginning. At the same time, it should be emphasized that the Omnibus does not address the cumulative regulatory burden that the industry has long been pointing out and that the European Commission itself has committed to reducing.
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[1] Assessment based on materials published so far, which do not include the complete text of the legislative proposal.
