AutoSAP’s response to the demand for accelerated introduction of electric drives in trucks and buses – revision of the regulation on CO2 emission targets for heavy goods vehicles and buses

15/2/2023 |Articles are machine translated

On 14 February 2023, the European Commission presented a revision of the CO2 emission limits for heavy vehicles (trucks and buses). The new rules amend the existing EU Regulation 2019/1242, which set the first ever EU greenhouse gas emission standards for new heavy-duty vehicles. Under the existing framework, manufacturers were required to ensure that new heavy vehicles produced from 2030 emit 30% less CO2 than in 2019, with an interim target of -15% from 2025. However, less than 3 years after setting the target, the European Commission is now substantially tightening the existing target from 2030, while setting new targets. For 2040, the target is as high as a 90% reduction. The proposal thus effectively accelerates the introduction of electromobility, whether battery or hydrogen.


“Perhaps never in history has the automotive industry been in such a complicated situation as now. Apart from production disruptions caused by persistent global chip shortages or the impact of high energy and material prices, vehicle manufacturers are literally overwhelmed by the excessive amount of incoming European legislation. Particularly in the context of the recent proposal for new Euro 7/VII emission standards, we consider the requirement for speed in reducing CO2 emissions to be extremely tough.” Says David Kříž, CEO of Iveco Czech Republic and member of the Board of Directors of the Automotive Industry Association.


The need for a comprehensive regulatory framework and the need for support at Member State level

Although the volumes of heavy vehicles produced are orders of magnitude lower than for passenger cars, it should be recognised that more than 78% of goods and passenger transport in the EU is carried out by road. The proposed changes will therefore affect not only manufacturers but also transport operators and, above all, citizens and businesses, for whom it will make goods and services more expensive. The real decarbonisation of road transport requires much more than just stricter CO2 targets for manufacturers. Technology alone is not today a barrier to the transition to climate neutrality. At the moment, it is both the lack of resources, especially batteries, and the virtual absence of the necessary charging and recharging infrastructure. At the same time, there is a complete lack of conditions that would motivate transport operators to change their fleets, be it the tax environment or the availability of infrastructure. As committed as truck manufacturers are to bringing zero-emission vehicles to the market, a coherent regulatory framework is urgently needed to make this transition a reality, alongside massive support at Member State level, particularly in terms of

  • Commit to ambitious targets in the framework of the revision of the Alternative Fuels Infrastructure Directive (AFIR) for charging and refuelling infrastructure suitable for heavy vehicles – as existing passenger vehicle infrastructure is inadequate both in terms of performance and physical accessibility;
  • Encourage investment in heavy vehicle specific infrastructure and grid capacity development, including speeding up permitting processes;
  • Introduce CO2-based road charges for heavy goods vehicles (Eurovignette);
  • Support the early introduction of the ETS2 emissions trading scheme;
  • Encourage transport operators to invest in heavy duty zero emission vehicles in a timely manner;
  • Help manufacturers to focus their efforts and investments in clean mobility by reviewing the Commission’s proposal for Euro VII.


Call for changes in the legislative process

Commercial road transport is a B2B market driven by demand and pressure for low TCO (total cost of ownership and operation). Transport operators will quickly move to zero emission vehicles when charging/refuelling infrastructure is no longer seen as a barrier and the total cost of ownership is clearly in favour of battery electric or hydrogen vehicles. Setting a near zero fleet CO2 emissions target or a fixed date for the phase-out of internal combustion engine vehicles does not address either of these fundamental conditions. Beyond the focus on zero-emission powertrains, manufacturers believe that internal combustion engines powered by fossil-free fuels should continue to play an important long-term role, at least in a type-limited but irreplaceable range of heavy-duty applications. This is not only in the military field, but especially in firefighting, police or construction vehicles, or for travel outside the EU. The Automotive Industry Association is therefore calling on government representatives to push for the following during the forthcoming legislative process:

  • Relaxation of the newly revised 2030 emission reduction targets from the original -30% to -45%. Further tightening of the targets significantly increases the requirements for building infrastructure that is now defacto non-existent. At least until 2030, it is expected to be a bottleneck, effectively disincentivising operators to buy new vehicles, leading to fleet obsolescence and in turn an increase in emissions. In addition, the current -30% targets already imply a requirement to build over 40 000 dedicated charging stations and a minimum of 500 filling stations across the EU.
  • Mitigating the requirement to reduce CO2 emissions by -90% by 2040. We consider this to be unrealistically ambitious, since even according to the Commission’s own preparatory studies, the share of battery and hydrogen heavy-duty vehicles in 2040 is estimated at less than 50%.
  • Setting the targets as follows: 2035/40% and 2040/50%. Setting targets too ambitiously may put manufacturers and the market in a difficult situation where, although they will meet the targets, their vehicles will not be marketable due to the high price and lack of recharging infrastructure. This would mean the closure of many production sites and job losses.
  • Removing the Commission’s proposed early ban on internal combustion engines for the urban bus category by 2030. These vehicles are mostly sold through public procurement, which is regulated by EU directives such as the Clean Vehicles Directive. This sets minimum quotas for “clean buses” to replace diesel vehicles, based on the principle of technology neutrality. Thanks to the rules set out in this Directive, clean technologies such as biomethane-fuelled city buses are increasingly appearing in EU cities alongside battery electric vehicles. The new CO2 standards should also not contradict the provisions of the Clean Vehicles Directive and should leave all EU cities with affordable alternatives to electric buses until at least 2035.
  • Not extending the scope of the proposal across the board to ‘all’ vehicles, as proposed by some EU countries, but taking into account the need for ‘special purpose’ vehicles. The current regulation affects 72% of all heavy vehicles, which account for 73% of CO2 emissions from heavy vehicles. However, the present proposal extends its scope to cover a further 25% of CO2 emissions, i.e. 95% of CO2 emissions from heavy vehicles overall. During the 1930s and 1940s, there will continue to be a number of categories of heavy vehicles that will require the use of internal combustion engines (firefighters, soldiers, police, some construction machinery such as mixers or vehicles for non-EU journeys…).
  • The addition of a mechanism to take into account the potential for the use of renewable/CO2 neutral fuels in the spirit of technological neutrality.
  • The debit/credit system was kept in place as an incentive after 2030 and its use was in turn streamlined by not applying it for fixed five-year periods (i.e. for the period between 2020-2025 and 2025-2030) and as a so-called five-year rolling plan.


Mgr. Zdeněk Petzl, LL.M.
Mgr. Zdeněk Petzl, LL.M.

Executive Director
Ing. Tomáš Jungwirth
Ing. Tomáš Jungwirth

Communications Manager

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