The 30 signatories support the objectives of the Paris Agreement and achieving net greenhouse gas neutrality in the European Union (EU) by 2050. Meeting this goal will require decisive action to decarbonise road transport, supported by policy improvements that encourage innovation and further unlock investments in clean technologies. The CO₂ regulations for passenger cars as well as light-duty vehicles (LDVs), the Renewable Energy Directive (RED), and the ETS II are central instruments in this regard.

 

The signatories support a technology-open approach in which electric mobility represents the main path to decarbonisation of LDVs. Therefore, we call for more flexibility in the revision of the CO2 emission performance standards. In addition to electric mobility, renewable fuels will play an indispensable role in meeting climate targets. Consequently, their role must also be incorporated within the CO₂ emission performance standards, in addition to the important contribution of vehicle technologies such as Plug-in-Hybrid Vehicles (PHEVs) and Electric Range Extender Vehicles

(EREVs).

 

Within the framework of the upcoming review of the CO₂ regulation for LDVs, we jointly call for the following adjustments:

 

 

 

Climate policy must apply to all vehicles. While the CO₂ fleet regulation targets only new vehicles, the Renewable Energy Directive applies to fuels used in both new and existing fleets. To unlock their full potential and drive investment across the value chain, the use of renewable fuels must also be recognised in new vehicles. Limiting renewable fuels to the existing fleet would weaken investment incentives along the entire value chain. Effective decarbonisation will only be achieved if renewable fuels can be equally accepted in both new and existing vehicles.

 

 

 

Under the current CO₂ fleet regulation, vehicles with internal combustion engines are still treated as 100 percent powered by fossil fuels, regardless of the actual fuel used. This approach distorts reality, since the EU fuel mix is no longer entirely fossil. According to the EU SHARES database, the share of renewable fuels in the EU fuel mix already exceeded five percent in 2022. A CCF must take this real share into account and systematically integrate the actual CO₂ emission reductions from renewable fuels into the fleet regulation. This is necessary for the regulation to accurately reflect real progress in the fuel sector and make the contribution of renewable energies to climate protection visible. In practical terms, this would mean that the official CO₂ value of a vehicle would be reduced by the share of renewable fuels in the EU fuel mix, as reported in the SHARES database. For example, with a five- percent renewable fuel share, a vehicle emitting 100 g/km of CO₂ would be accounted as only 95 g/km.

 

 

Vehicles running exclusively on renewable fuels¹, must be recognised as zero-emission vehicles – in the same way that battery-electric vehicles and fuel-cell-electric vehicles are. Downstream taxation and charges for vehicles running exclusively on renewable fuels should likewise be aligned with those of battery-electric vehicles. It is essential that vehicles running exclusively on renewable fuels can be introduced into the market shortly after the review, and thus before 2030. There is no factual basis for delaying their introduction until 2035. On the contrary, an early market opening would accelerate the

urgently needed investments in production, infrastructure, vehicle development and the manufacturing of renewable fuels, thereby ensuring long-term demand certainty for renewable fuels.

 

 

 

A binding European legal definition for renewable fuels is required. In principle, all RED eligible fuels should be classified as renewable fuel. The following definition, aligned with the RED, should be included in the CO2 regulation:

 

“Renewable Fuel” means all fuels defined by the Renewable Energy Directive (EU) 2018/2001, provided that they meet the sustainability criteria

as biofuel, biogas, biomass fuel, renewable liquid and gaseous transport fuel of non-biological origin (RFNBO) or a recycled carbon fuel (RCF).”

 

A clear and practical definition will create legal and investment certainty for producers, operators and users, forming the basis for planning, certification and accounting within the CO₂ regulation on LDVs.

 

 

 

The minimum CO₂-reduction requirement for renewable fuels must continuously and realistically be increased. The review of the CO₂ fleet regulation should therefore include a recital stating that RED IV and its subsequent regulations should establish a long-term trajectory for new production units, ensuring that investments in existing facilities are not compromised, by defining a progressive level of emission reduction. This trajectory should ensure regulatory coherence with the EU’s long-term climate objectives, thus stimulating investment in new, highly efficient production facilities and fostering technological innovation within the fuel sector.

 

The concrete implementation of this provision should subsequently be included as part of the review of the RED. The evolution of these criteria will be guided by technical and economic assessments, ensuring planning and investment security along the entire value chain and supporting the scale-up of renewable fuels.

 

A successful European climate policy requires technology-open instruments and incentive-based framework conditions. The proposals set out above outline the long-term perspective urgently needed for the scale-up of renewable fuels in road transport, strengthening investment, innovation, and industrial capacity sustainably. The signatory associations therefore call on the European Commission to swiftly implement and legally integrate renewable into the CO₂ regulation for LDVs as part of the forthcoming review. Only then will Europe be able to achieve its climate goals efficiently, economically and socially responsibly.

 

 

Signatories: