Lobbying on Revision of the CO2 emission standards for cars and vans

Revision of the CO2 emission standards for cars and vans

Climate action

Road transport has a key role to play to reach the objectives of the European Green Deal. The legislation on CO2 emission performance standards for cars and vans is a key policy driver to reduce road transport emissions. Therefore, it will be revised, to ensure a clear pathway from 2025 onwards towards zero-emission mobility.

Links

Public consultation

ID: 12655

Lobbying Activity

129 responses

Transport & Environment Backs 2035 Zero-Emission Vehicle Mandate

Transport and Environment (European Federation for Transport and Environment), 8 Nov 2021

The organization supports the 2035 zero-emission requirement but demands stronger intermediate targets. They want at least 30% CO2 reduction by 2025, 45% by 2027, and 80% by 2030. They also call for removing loopholes that weaken compliance requirements.

This would accelerate the transition to electric vehicles and strengthen climate action.

Automakers face tighter compliance requirements and lose flexibility loopholes that reduce obligations.

Transport and Environment urges higher targets for zero-emission mobility

Transport and Environment (European Federation for Transport and Environment), 23 Nov 2020

The organization calls for higher CO2 reduction targets and an annual target system to ensure continuous market growth. They recommend a 2035 phase-out of combustion engine vehicles and the removal of loopholes like the plug-in hybrid multiplier.

Stricter standards would accelerate electric vehicle adoption and secure Europe's leadership in the automotive transformation.

Traditional carmakers and fuel industries lose by facing stricter annual compliance and a ban on combustion engines.

Consultation response

Bureau Européen des Unions de Consommateurs, 25 Nov 2020

BEUC welcomes the focus on zero-emissions vehicles and the link with the Zero Pollution Ambition. To achieve both the climate and air quality goals, it is essential to accelerate the uptake of battery electric vehicles (BEVs) which truly deliver on both ends. Promoting BEVs will benefit consumers…

ACEA urges more charging infrastructure to meet emission targets

Association des Constructeurs Européens d'Automobiles, 8 Nov 2021

ACEA demands that higher emission targets be matched by significantly more public charging infrastructure. They suggest delaying the 2035 phase-out goal until charging networks are guaranteed. Finally, they argue for maintaining exemptions for small-volume manufacturers.

Delaying targets and keeping exemptions would protect their business models from disproportionate costs.

European automakers demand infrastructure and support for CO2 targets

Association des Constructeurs Européens d'Automobiles, 26 Nov 2020

ACEA insists that tighter CO2 targets require significant expansion of charging infrastructure. They also urge for continued super-credits and a stable investment period.

This strategy helps the industry avoid fines while maintaining market share for hybrids.

Environmental organizations lose if climate targets are tied to slow infrastructure rollouts.

German Industry Group Urges Keeping Internal Combustion Engines

Bundesverband der Deutschen Industrie e.V., 8 Nov 2021

BDI rejects a de facto ban on vehicles with internal combustion engines. They demand technological openness to include CO2-neutral fuels and a 2028 review clause.

This strategy protects the existing automotive sector and provides needed investment certainty.

Innovation and cost-efficient policy paths suffer if technology neutrality is abandoned.

Consultation response

Bundesverband der Deutschen Industrie e.V., 25 Nov 2020

The IIA correctly states that "CO2 standards give vehicle manufacturers the legal certainty to invest more in related R&D, to produce more zero-emission vehicles so that with increased supply and economy of scale they can become more affordable for citizens”. Against this background, and taking…

Consultation response

European farmers, 8 Nov 2021

Copa and Cogeca believe that the proposed revised regulation on CO2 standards for cars and vans is a missed opportunity to establish the principle of technology neutrality and recognize the cost-efficient role of certified crop-based and advanced biofuels such as biomethane. The revision of the EU…

Consultation response

The European Steel Association, 26 Nov 2020

The revision of the CO2 regulations for cars and vans is an opportunity to ensure future vehicle designs can meet the objectives of the Paris Climate agreement, without risking the shifting of emissions from the tailpipe to other lifecycle stages. This requires the consideration of the increasingly…

Consultation response

Eurelectric aisbl, 8 Nov 2021

The European electricity industry, represented by Eurelectric, welcomes the publication of this Commission's initiative to tackle the emissions from road transport. With the proposed CO2 emission performance standards for cars and vans, the European Commission has shown a real commitment to reach…

Consultation response

ENEL SpA, 25 Nov 2020

Since 1990, emissions from road transport have increased significantly and as of today account for almost a fifth of EU's GHG emissions. The next years are critical for curbing CO2 emission. If action is insufficient in the short-medium term, it will likely be impossible to make up for the deficit…

Fuel industry urges recognition of liquid fuels in CO2 standards

FuelsEurope, 4 Nov 2021

FuelsEurope wants the regulation to recognize low-carbon liquid fuels as a complementary solution to electrification. They propose a fuel crediting system that would allow car manufacturers to meet CO2 targets by using renewable fuels. They argue the current proposal creates a de facto ban on internal combustion engines regardless of fuel type.

This would support production at scale of their fuels and create a lead market for technologies they are developing.

Climate advocates lose faster fleet decarbonization by extending the life of combustion engines.

FuelsEurope calls for recognition of climate-neutral fuels in regulations

FuelsEurope, 25 Nov 2020

The organization requests that the Commission adopt a technology-neutral approach by allowing renewable fuels to count toward vehicle emission targets. They propose a fuels crediting system for new vehicles to address the current competitive disadvantage against electric mobility.

This would allow the refining industry to remain relevant and unlock massive investments in liquid fuels.

Electric vehicle manufacturers may face increased competition as internal combustion engines remain a viable regulatory option.

German Auto Industry Warns Against 2035 Combustion Engine Ban

Verband der Automobilindustrie, 5 Nov 2021

The industry supports the 2030 targets but demands rapid, binding expansion of charging infrastructure and coordinated EU-wide support programs for electric vehicles. They reject the proposed 2035 zero-emission target as a technology ban and want the post-2030 targets delayed until 2028 based on infrastructure progress.

This would give manufacturers more time to adapt while avoiding mandatory phase-out of profitable combustion engine models.

Climate advocates lose faster emissions reductions and face continued fossil fuel vehicle sales.

German automotive industry demands technology-neutral framework and infrastructure investment

Verband der Automobilindustrie, 26 Nov 2020

The organization calls for a technology-neutral regulatory framework that includes investments in charging infrastructure and the use of alternative fuels. They request a thorough impact assessment that considers social and economic consequences before tightening any emission targets.

These measures would protect existing jobs and help the industry maintain its market position during the transition.

Automotive workers and medium-sized suppliers face significant risks from rapid regulatory shifts without support.

Consultation response

Hydrogen Europe, 8 Nov 2021

Hydrogen Europe would like to present the following recommendations regarding the recent proposal on the review of the CO2 Emission Performance Standards for cars and vans: 1) Maintain the positive aspects of the proposal, such as the level of ambition for the personal cars segment. 2) Ensure…

Neste urges EU to credit renewable fuels in vehicle emission standards

Neste Oyj, 5 Nov 2021

Neste requests that the EU either widen the definition of zero-emission vehicles to include renewable and low-carbon fuels, or introduce a voluntary crediting system. They argue this would allow sustainable fuels in internal combustion engines to contribute to emission reduction targets.

This would create market demand for their renewable diesel and alternative fuel products.

Battery electric vehicle manufacturers face increased competition from combustion engine vehicles using alternative fuels.

Consultation response

ENGIE, 26 Nov 2020

Europe is striving to become the first carbon-neutral continent by 2050 and as a key milestone on this path, the European Commission proposes to raise the greenhouse gas (GHG) reduction target for 2030 to at least 55%. Transport is identified as one of the sectors which need to step up efforts…

Consultation response

European Association Automotive Suppliers, 8 Nov 2021

CLEPA, the association representing the automotive suppliers’ industry in Europe is pleased to provide feedback on the Amendment of the Regulation setting CO2 emission standards for cars and vans. CLEPA represents over 3.000 companies supplying state-of-the-art components and innovative…

Consultation response

European Association Automotive Suppliers, 26 Nov 2020

CLEPA, the Association of the Automotive Suppliers’ industry in Europe, is pleased to comment on the inception impact assessment on the Amendment of the regulation setting CO2 emission standards for cars and vans. CLEPA represents over 3.000 companies supplying state-of-the-art components and…

Bosch advocates for renewable fuel credits in vehicle CO2 standards

Robert Bosch GmbH, 26 Nov 2020

Bosch calls for a well-to-wheel approach and a voluntary crediting system for carbon-neutral fuels. They advocate for technological neutrality instead of banning the internal combustion engine.

The company would gain flexibility to meet targets while avoiding costly regulatory penalties.

Consultation response

IBERDROLA, 8 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.…

Consultation response

IBERDROLA, 24 Nov 2020

Electrification is the most effective, efficient and sustainable way to decarbonise the transport sector, achieve EU’s long-term climate objectives and reduce air pollution. The electric vehicle (EV) is the real, competitive and mature alternative to decarbonise road transport at least cost,…

Consultation response

Deutsche Umwelthilfe e.V., 8 Nov 2021

DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate…

Consultation response

Deutsche Umwelthilfe e.V., 26 Nov 2020

The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the…

Eurogas urges EU to recognize renewable gas in vehicle standards

EUROGAS, 8 Nov 2021

Eurogas wants a lifecycle accounting approach to recognise the environmental performance of fuels. They suggest a crediting system to account for renewable and low-carbon alternatives.

This would prevent a total market ban on gas-powered vehicle technologies.

Makers of zero-emission vehicles would lose their exclusive advantage in meeting climate targets.

Consultation response

E.ON SE, 26 Nov 2020

E.ON welcomes the Commission´s roadmap consultation on the CO2 Emissions Performance Standards for Cars and Vans, we consider this a pivotal policy for the decarbonization of transport. Please see attached our full response.

Consultation response

Siemens Energy AG, 26 Nov 2020

Siemens Energy welcomes the opportunity to provide feedback on the roadmap "CO2 emissions for cars and vans - revision of performance standards". Please find attached the Siemens Energy position paper "Emission performance standards for cars and vans – the case for a well-to-wheel approach".

Consultation response

European Biogas Association, 8 Nov 2021

Please find attached the feedback of EBA including links to supporting studies.

Consultation response

European Biogas Association, 26 Nov 2020

EBA welcomes the efforts of the European Commission to revise the existing legislation to achieve the required 90% emissions reduction in the transport sector by 2050. To make this necessary green transition in the transport sector, the EC must understand the interlinkages between different sectors…

Consultation response

EnBW Energie Baden-Württemberg AG, 25 Nov 2020

For input: CO2 standards for cars and vans - revision (Roadmap) EnBW Energie Baden-Württemberg AG fully supports the 2050 decarbonization target of the European Union and the European Commission’s amendment of the Regulation setting CO2 emission standards for cars and vans. Decarbonizing the EU…

Consultation response

Naturschutzbund Deutschland e.V., 8 Nov 2021

NABU (Nature and Biodiversity Conservation Union) is the biggest environmental NGO in Germany with more than 800.000 members and supporters. NABU welcomes the European Commission’s (EC) proposal for a revision of the EU CO2 standards for cars and vans. The transport sector is the only sector in…

Repsol urges EU to include renewable fuels in vehicle emission standards

Repsol, S.A., 5 Nov 2021

Repsol requests technology-neutral approach allowing renewable and low-carbon fuels to count toward emission targets. They propose credit system for fuel suppliers and zero-emission vehicle status for cars designed for net-zero-carbon fuels.

This would expand market opportunities for their renewable fuel products alongside electric vehicles.

Electric vehicle manufacturers lose competitive advantage if fuel-based alternatives count as zero-emission.

Repsol urges EU to include low-carbon fuels in CO2 targets

Repsol, S.A., 26 Nov 2020

Repsol advocates for a technological neutrality approach that recognizes sustainable biofuels and synthetic fuels as solutions alongside electrification. They propose moving beyond tailpipe emission measurements to a well-to-wheel assessment that accounts for fuel production.

This would preserve the company's refining business and existing infrastructure by allowing internal combustion engines to remain viable.

Electric vehicle manufacturers and infrastructure providers may face slower adoption rates if focus shifts from pure electrification.

Consultation response

European Public Health Alliance, 8 Nov 2021

The European Public Health Alliance (EPHA) welcomes the European Commission’s proposal to sell exclusively zero-emission new vehicles in the EU from 2035. Stricter emissions standards for all petrol and diesel cars and vans are crucial to get to 100% zero emissions mobility. This proposal should…

Consultation response

Verbraucherzentrale Bundesverband, 28 Sept 2021

Please find attached the positions and feedback of the Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband – vzbv). vzbv is the umbrella organisation for more than 40 consumer organisations throughout Germany and represents the interests of German consumers vis-à-vis…

Consultation response

Snam S.p.A., 8 Nov 2021

Please find SNAM's feedback in the attached document.

Consultation response

Snam S.p.A., 26 Nov 2020

Snam welcomes the opportunity to provide feedback to the EC initiative on the Amendment of the Regulation setting CO2 emission standards for cars and vans and would like to provide the following comments and suggestions: 1. Transport and future mobility will be a central element of the climate…

Consultation response

Green Power Denmark, 26 Nov 2020

Danish Energy highly welcomes the European Commission’s decision to revisit and strengthen the CO2 standards for cars and vans for 2030 and thanks the Commission for this opportunity to share our views on the revision. Danish Energy is a non-commercial organisation for Danish energy companies,…

Consultation response

Tesla Motors Netherlands B.V., 26 Nov 2020

Recommendations for analysis: • Make a trend analysis of the annual rate of improvement required between 2019 and 2030 according to current legislation, including the impact of the ZLEV benchmark on required CO2 cuts and the inclusion of MAC improvements in eco-innovations; • On the basis of that…

Consultation response

International Copper Association Europe, 26 Nov 2020

The European Copper Institute (ECI) welcomes the opportunity to comment on the Commission’s inception impact assessment on the Regulation setting CO2 emission standards for cars and vans. One of the missions of the association is to promote the sustainable use of copper in electric vehicles. One…

Consultation response

MAHLE International GmbH, 26 Nov 2020

The MAHLE Group is a leading international supplier to the automotive industry as well as a pioneer for the mobility of the future. We are committed to making transportation more efficient and more environmentally friendly and support the EU’s objective of becoming carbon-neutral by 2050. To…

eFuel Alliance Urges Voluntary Crediting System for Synthetic Fuels

eFuel Alliance, 3 Nov 2021

The eFuel Alliance requests a voluntary crediting system for renewable fuels. This allows internal combustion engines to contribute to CO2 reduction targets alongside electric vehicles.

The proposal secures market demand for eFuels while providing a safety net for the automotive industry.

The proposal would complicate regulatory responsibilities and potentially undermine the overall effectiveness of emission standards.

eFuel Alliance Urges Inclusion of Renewable Fuels Crediting System

eFuel Alliance, 26 Nov 2020

The eFuel Alliance advocates for a voluntary crediting mechanism that allows vehicle manufacturers to count renewable synthetic fuels toward their fleet emission targets. They also propose shifting from tailpipe-only measurements to a full life-cycle assessment of a vehicle's carbon footprint.

This would create market demand for synthetic fuels and lower compliance penalties for manufacturers.

Direct electrification goals may be diluted, potentially slowing the transition to purely battery-electric transport.

FIA urges well-to-wheel emissions approach over combustion engine ban

Fédération Internationale de l'Automobile, 8 Nov 2021

The organization requests replacing tailpipe emissions calculations with well-to-wheel analysis by 2030, and opposes the 2035 ban on internal combustion engines. They advocate for technology-neutral policies that keep mobility accessible and affordable while achieving climate goals.

This would allow continued sales of combustion engine vehicles using alternative fuels beyond 2035.

Climate action loses urgency as delaying the combustion engine phase-out slows emission reductions.

Consultation response

European Biodiesel Board, 8 Nov 2021

- The current EU CO2 standards for vehicles only account for tailpipe emissions (Tank-To-Wheel). This restrictive approach distorts competition between powertrain technologies and misleadingly labels electromobility as emissions free. It fails to incentivise biofuels and biogas with a lower GHG…

Consultation response

European Biodiesel Board, 26 Nov 2020

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Biodiesel constitutes a significant European renewable energy source, and the main European solution to reduce emissions from transport and dependence on…

Consultation response

Liquid Gas Europe, 4 Nov 2021

Please find attached Liquid Gas Europe's joint response with other Members of the Renewable & Low Carbon Liquid Fuels Platform on the open public consultation on the revision of CO2 emission performance standards for cars and vans [Regulation (EU) 2019/631].

Consultation response

Liquid Gas Europe, 26 Nov 2020

Please find Liquid Gas Europe's feedback on the Impact Assessment attached.

Gas Distributors urge EU to recognize biomethane vehicles in emissions standards

Gas Distributors for Sustainability, 8 Nov 2021

The organization requests a switch from tank-to-wheel to well-to-wheel emissions measurement and recognition of biomethane's emissions reductions. They want derogations for efficient natural gas vehicles that can achieve negative emissions through biomethane use.

This would protect their members' investments in natural gas vehicle infrastructure and biomethane production.

Electric vehicle manufacturers lose competitive advantage from zero-emission standards focusing on tailpipe emissions.

Gas Distributors Urge EU to Recognize Biomethane for Mobility

Gas Distributors for Sustainability, 25 Nov 2020

The organization calls for a shift from tailpipe-only emission measurements to a full Life Cycle Analysis. They urge the Commission to implement a crediting system that accounts for the contribution of renewable fuels.

This would remove market barriers for gas-powered vehicles and foster the use of their distribution networks.

Electric vehicle manufacturers may face increased competition as the regulatory 'playing field' shifts toward gas-based technologies.

Consultation response

The EU Vegetable Oil and Proteinmeal Industry, 8 Nov 2021

FEDIOL, as a member of the Renewable & Low-Carbon Liquid Fuels Platform, is committed to the climate-neutral economy by 2050, supporting a pathway which encompasses breakthrough technologies and an appropriate enabling policy framework. The Commission’s Fit-for-55 package is a step in the right…

Consultation response

Enagás S.A., 8 Nov 2021

Enhanced ambition regarding road transport emissions is one of the key levers towards carbon neutrality of the EU. They represent almost 20% of total EU GHG emissions, and have significantly increased since 1990. Further emission reduction as stated on the Green Deal will require the contribution…

Consultation response

Nordic Logistics Association, 26 Nov 2020

Nordic Logistics Association (NLA) represents around 17.000 road transport operators and companies in the Nordic countries. NLA welcomes a revision of the CO2 emissions performance standards for cars and vans in line with the revised 2030 climate target. Measures to reach 2030 targets and measures…

Consultation response

Allgemeiner Deutscher Automobil-Club e.V., 14 Oct 2021

Der ADAC e.V. ist mit derzeit über 21 Millionen Mitgliedern der größte Automobilclub in Europa und der zweitgrößte in der Welt. Die vier Buchstaben stehen für einen Verein, der seinen Mitgliedern rund um die Uhr Hilfe, Schutz und Rat bietet und sich als Interessenvertreter für alle Themen rund um…

Consultation response

Allgemeiner Deutscher Automobil-Club e.V., 23 Nov 2020

Der Allgemeine Deutsche Automobil Club (ADAC e.V.) bekennt sich ausdrücklich zum Klimaschutz und unterstützt die Ziele des Pariser Klimaabkommens. Für den Straßenverkehr folgt daraus, dass bis 2050 die vollständige Dekarbonisierung notwendig ist. Die getroffenen Maßnahmen müssen vorhersehbar und…

Consultation response

UNION FRANCAISE DE L'ELECTRICITE - UFE, 26 Nov 2020

UFE welcomes warmly the EC’s intention to revise the Regulation 2019/631/EU setting CO2 emission standards for cars and vans. Given the planned increase of the 2030 target of GHG emission reduction from 40% to 55% and the new reduction objective of 90% of emissions by 2050 for the transport sector,…

Consultation response

Statkraft AS, 8 Nov 2021

Joint response by Statkraft and Mer to public consultation: CO2 emissions for cars and vans - revision of performance standards As Europe’s largest renewable energy producer, Statkraft is committed to contributing to the EU becoming climate-neutral by 2050. The Mer Group is fully owned by…

Consultation response

Statkraft AS, 25 Nov 2020

We strongly support the strengthened ambitions of the European Green Deal and specifically emissions reductions from transport. For these ambitions to be realised we need improved regulation. Emissions standards should in as much as possible be based on real driving emissions of the vehicle and…

Consultation response

AECC, 8 Nov 2021

The Association for Emissions Control by Catalyst (AECC) welcomes the opportunity to comment on the public consultation of the European Commission’s proposal for amending the CO2 emissions performance standards for cars and vans . The EU Green Deal zero-emissions transport objective can best be…

Consultation response

AECC, 26 Nov 2020

The Association for Emissions Control by Catalyst (AECC) welcomes the welcomes the opportunity to comment on the proposed inception impact assessment. More sustainable and renewable fuels should be used in cars with internal combustion engines. A mechanism to consider the contribution of these…

Consultation response

International Council on Clean Transportation, 8 Nov 2021

Please find attached our evaluation, including a set of recommendations.

Consultation response

Svenskt Vatten, 5 Nov 2021

We welcome strict requirements in the EU’s CO2 emission performance standards, but we believe that EU legislation should be built around research-based well-to-wheel or life-cycle analysis on climate emissions. We are very critical of the persisting with the tailpipe approach, as proposed by the…

Consultation response

International Council on Clean Transportation, 26 Nov 2020

Our own analysis confirms the Commission's finding that, without further policy intervention, emissions from road transport are not on a trajectory for achieving the 2030 target and climate neutrality by 2050. We find that with the policies currently adopted, CO2 emissions from cars and vans will…

Ferrari urges EU to maintain CO2 derogations for small-volume carmakers

Ferrari, 8 Nov 2021

Ferrari is suggesting to keep the SVM derogations beyond 2030. They argue efforts should be proportionate to the negligible emissions share of high-performance vehicles.

This would help Ferrari avoid a highly disproportionate 80% emission reduction requirement.

Consultation response

European Producers Union of Renewable Ethanol, 30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and…

Consultation response

European Producers Union of Renewable Ethanol, 19 Nov 2020

ePURE would like provide recommendations to make the most out of this upcoming revision. As the process of revising climate and energies policies in line with the increased ambitions set in the Green Deal unfolds, these recommendations aim at incentivising low carbon technologies and reducing…

Consultation response

Gasum Oy, 5 Nov 2021

Gasum welcomes strict requirements in the EU’s CO2 emission performance standards, but we believe that EU legislation should be built around research-based well-to-wheel or life-cycle analysis on climate emissions. We are very critical of the persisting with the tailpipe approach, as proposed by…

Consultation response

Verband der Deutschen Biokraftstoffindustrie, 8 Nov 2021

Please find attached our comments on the initiative.

Consultation response

Verband der Deutschen Biokraftstoffindustrie, 26 Nov 2020

Policies to reduce the GHG emissions of newly registered cars are one of the most important instruments within the transport sector. Within this instrument ambitious performance standards for passenger cars are needed. However, it must be noted that 1. policy measures must have a significant and…

Consultation response

NaTran, 8 Nov 2021

GRTgaz acknowledges that this Regulation is an important step in the decarbonisation of light land transport. While we welcome its high level of ambition, we consider that a different approach would be more effective in achieving its objectives. One of the objectives of the modified 2019/613…

Consultation response

NGVA Europe, 8 Nov 2021

NGVA Europe welcomes this opportunity to further comment on the proposal of the European Commission to revise the CO2 standards for cars & vans. Setting an ambitious 2035 target of a 100% reduction in GHG emissions solely based on tailpipe, without recognizing the potential of renewable fuels in…

Consultation response

NGVA Europe, 26 Nov 2020

The publication of the 2030 Climate Plan by the European Commission increased the overall GHG emissions reduction target for 2030 from -40% up to -55% (vs 1990 level). The long-term reduction goal for 2050 remains unchanged, but the new plan asks for an acceleration across multiple sectors in the…

Consultation response

NaTran, 26 Nov 2020

GRTgaz is fully committed to the Paris Agreement and supports the European Commission’s ambition to reach carbon neutrality by 2050, and as such welcomes the forthcoming initiatives on climate and environmental action under the Green Deal. As GRTgaz, we are convinced that we must act now, and take…

Consultation response

German Renewable Energy Federation, 8 Nov 2021

The proposal's main focus is set towards the "CO2 emission standards for passenger cars and light commercial vehicles" by "boosting the uptake of zero emission vehicles and related infrastructure" [p. 2]. In general, the German Biogas Association supports this approach, especially since at first…

Consultation response

Hospodářská komora České republiky, 8 Nov 2021

Připomínky zasíláme v příloze.

Spanish car makers demand infrastructure before tighter CO2 limits

ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE AUTOMÓVILES Y CAMIONES, 26 Nov 2020

ANFAC insists that stricter CO2 targets must be matched by massive investment in infrastructure. They advocate for maintaining incentive mechanisms like super-credits to support the market transition. The association also seeks a predictable investment environment with fixed legislative acts by 2025.

Retaining super-credits and delaying strict targets would reduce their regulatory compliance costs.

Climate goals suffer if regulatory stringency is reduced to protect car manufacturers' profit margins.

Consultation response

Stadtwerke München GmbH, 26 Nov 2020

Die SWM und ihre 100%-Tochter MVG unterstützen ausdrücklich Vorgaben für einen ambitionierten Klima- und Umweltschutz. Diese sind bereits heute Teil unserer langfristigen Unternehmensvision. Als öffentlicher Personennahverkehrsdienstleister stehen wir für nachhaltige und zukunftsfähige…

Independent fuel suppliers urge technology neutrality in CO2 standards

The Voice of Europe's Independent Energy and Mobility Suppliers, 8 Nov 2021

The group requests a shift from tailpipe-only monitoring to a well-to-wheel approach. They propose a voluntary crediting system for car manufacturers to use renewable liquid fuels.

This would protect their existing infrastructure and secure future demand for fuel products.

Low-income families may lose access to affordable transport without these liquid fuels.

Consultation response

The Shift Project, 26 Nov 2020

The Shift Project welcomes the revision of the CO2 emission standards for cars and vans and allow them to contribute to their fair share of the 2030 CO2 emission reduction target. We support an effective holistic approach across three overarching axes: decrease in demand for transportation in…

Independent fuel suppliers urge CO2 credits for renewable fuels

The Voice of Europe's Independent Energy and Mobility Suppliers, 26 Nov 2020

UPEI wants a Well-to-Wheel assessment instead of focusing only on tailpipe emissions. They propose a voluntary crediting mechanism for renewable fuels.

This allows suppliers to remain competitive by using their existing fuel distribution infrastructure.

Consultation response

EWABA, 26 Nov 2020

Many thanks for the opportunity to respond to this inception impact assessment on the upcoming revision of Regulation on CO2 standards for cars and vans. EWABA, the EU association representing the interests of EU waste-based biodiesel producers, strongly supports the introduction of a new mechanism…

Consultation response

Polskie Gornictwo Naftowe i Gazownictwo SA - Polish Oil and Gas Company, 8 Nov 2021

PGNiG welcomes the possibility to comment on the proposal for a regulation amending Regulation 2019/631 as regards strengthening the CO2 emission performance standards for new passenger cars and new light commercial vehicles in line with the Union’s increased climate ambition (Cars Regulation). The…

Consultation response

Equilibre des Energies, 25 Nov 2020

The current text of the Regulation on CO2 emissions for cars and vans focuses on reducing tailpipe emissions as it is the source of most CO2 emissions related to internal combustion vehicles. Such a focus however has led to unintended consequences that can increase the GHG emissions related to the…

Japanese automakers call 2035 combustion engine ban unrealistic

Japan Automobile Manufacturers Association, Inc. European Office, 7 Nov 2021

JAMA argues that a total ban on internal combustion engines by 2035 is unrealistic and urges the EU to maintain technology neutrality. They suggest that engines powered by renewable fuels should remain a valid climate-neutral option after the deadline.

This would allow manufacturers to continue utilizing existing engine technologies while waiting for market demand to mature.

Automotive workers and regional economies could suffer if the transition does not include employment protection measures.

Japanese carmakers urge balanced CO2 targets and EV incentives

Japan Automobile Manufacturers Association, Inc. European Office, 26 Nov 2020

The organization requests a balanced approach to stricter emission targets that considers the economic impact of the pandemic. They also call for an improved incentive system to accelerate the adoption of low-emission vehicles.

A more flexible incentive scheme would help manufacturers avoid costly fines while navigating economic recovery.

Climate advocacy groups lose if the transition is slowed by prioritizing industry economic stability.

Consultation response

Gas Networks Ireland, 26 Nov 2020

Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the revision of performance standards of CO2 Emissions for Cars and Vans. Emission targets have been increased under the Climate Action Plan 2030 from -40% to -55%. This requires the mobility sector to accelerate its efforts…

Consultation response

Federation of European Tank Storage Associations, 4 Nov 2021

The Renewable and Low-Carbon Liquid Fuels Joint Response to the Open Public Consultation on the Revision of CO2 Emission Performance Standards for Cars and Vans [Regulation (EU) 2019/631] The members of the Renewable & Low-Carbon Liquid Fuels Platform are committed to the climate-neutral economy by…

Consultation response

Methanol Institute, 4 Nov 2021

The Methanol Institute agrees with the European Commission's assessment that in order to achieve the European Green Deal's objective of climate neutrality in the EU by 2050, significant policy action must be undertaken in the passenger vehicle segment. We uphold that such policy action should…

Consultation response

Methanol Institute, 26 Nov 2020

Feedback on CO2 emissions for cars and vans – revision of performance standards 26 November 2020 Dear Executive Vice-President Timmermans, Dear Commissioner Vălean, Dear Commissioner Simson, The Methanol Institute (MI) firmly supports the climate action plan of the European Union and its…

Consultation response

Climate Group (UK registered name: The Climate Change Organisation), 26 Nov 2020

Introduction The Climate Group is an international non-profit, with offices in London, New Delhi and New York. Our mission is to drive climate action, fast, by forming networks of business and government to move whole systems to a clean future. Our EV100 initiative brings together 92 global…

Consultation response

DVGW Deutscher Verein des Gas- und Wasserfaches e.V. - Technisch wissenschaftlicher Verein, 26 Nov 2020

The DVGW welcomes the opportunity to comment on the design of the impact assessment regarding on the Amendment of the Regulation setting CO2 emission standards for cars and vans. The DVGW advocates to: Implement a technology-open approach that supports the development of natural-gas powered…

Finnish bioenergy industry calls for biofuels recognition in vehicle emissions

Bioenergia ry - Bioenergy Association of Finland, 8 Nov 2021

The association urges the EU to move beyond tank-to-wheel emissions accounting to include well-to-tank performance and biogenic content. They want biofuels and power-to-x fuels recognized through a voluntary crediting mechanism for manufacturers.

This would expand market demand for their biofuels beyond hard-to-electrify sectors.

Electric vehicle manufacturers lose regulatory advantage if biofuel vehicles count as low-emission.

Consultation response

Lantmännen ekonomisk förening, 5 Nov 2021

Please find enclosed the feedback on the Vehicle CO2 regulation from Lantmännen, Sweden.

Finnish Bioenergy Association urges crediting for renewable fuels

Bioenergia ry - Bioenergy Association of Finland, 26 Nov 2020

The association requests a move away from tailpipe-only emission measurements and the introduction of a voluntary crediting mechanism. This would allow renewable fuels to help manufacturers meet their CO2 targets.

This would boost demand for biofuels and ensure their continued use in road transport.

Electric vehicle manufacturers might face stiffer competition from combustion engine vehicles using renewable fuels.

Consultation response

Avfall Sverige, 8 Nov 2021

Consultation response

Clean Air Action Group (Levegő Munkacsoport), 6 Nov 2021

A Levegő Munkacsoport (LMCS; Clean Air Action Group) örömmel értesült róla, hogy az Európai Bizottság nekilát a személyautók és kisteherautók széndioxid-kibocsátását szabályozó rendelkezések felülvizsgálatának, és javaslatot készül tenni az EP-nek és az Európai Tanácsnak. A személygépkocsikra…

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Iogen Corporation, 8 Nov 2021

Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep…

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NORTH SWEDEN EUROPEAN OFFICE, 8 Oct 2021

European Forum of Northern Sweden (EFNS) is a network for politicians at the local and regional levels from Norrbotten, Västerbotten, Jämtland Härjedalen and Västernorrland. EFNS is a meeting place and knowledge arena where EU policies are analysed and discussed in respects where it affects…

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CITTADINI PER L'ARIA, 24 Nov 2020

Cittadini per l'aria shares T&E's view EU car CO2 standards are a climate and industrial policy, to achieve automotive transformation and securing supply of affordable electric cars to achieve zero carbon transport in Europe. T&E’s analysis shows that the 2020/21 standard of 95g/km will result in…

Consultation response

Associazione Nazionale Industriali Gas, 8 Nov 2021

Proposta di Regolamento sugli standard di emissione di CO2 di auto e furgoni Anigas ha accolto con favore le proposte del pacchetto Fit for 55, esprimendo piena condivisione rispetto agli sfidanti obiettivi climatici e confermando la volontà del settore gas di dare il proprio contributo al…

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2030 sekretariatet, 5 Nov 2021

The Swedish 2030 secretariat is an independent Think tank committed to the decarbonization of the transport sector. We are not looked into any specific technological solution, the GHG reduction is what matters. Rather sooner than later - we cannot wait until electric vehicles dominate the light…

Consultation response

Mittelstandsverband abfallbasierter Kraftstoffe e.V. (Waste-based Fuels Association), 26 Nov 2020

Thank you for the opportunity to respond to this inception impact assessment on the upcoming revision of Regulation on CO2 standards for cars and vans. The MVaK, a Berlin-based association representing the interests of German, Austrian and Dutch waste-based biodiesel producers, strongly supports…

Consultation response

Westport Fuel Systems Inc., 26 Nov 2020

The recently published 2030 Climate Plan by the European Commission would increase the overall GHG emissions reduction target for 2030 from -40% up to -55% (vs 1990 level). The long-term reduction goal for 2050 remains unchanged, but the new plan asks for an accelerated ambition across multiple…

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European Confederation of Fuel Distributors, 26 Nov 2020

The European Confederation of Fuel Distributors (ECFD) shares the Commission’s assessment that road transport will need to play a key role in achieving the EU’s climate targets. Therefore, ECFD welcomes the Commission’s plan to amend the CO2 emission standards for cars and vans since it provides a…

Consultation response

Fachverband der Gas- und Wärmeversorgungsunternehmungen, 26 Nov 2020

The recent publication of the 2030 Climate Plan by the European Commission increased the overall GHG emissions reduction target for 2030 from -40% up to -55% (vs 1990 level). The long-term reduction goal for 2050 remains unchanged, but the new plan asks for an acceleration across multiple sectors…

Consultation response

Brazilian Sugarcane and Bioenergy Industry Association, 26 Nov 2020

The Brazilian Sugarcane Industry Association, UNICA, supports the objective of reviewing CO2 emission standards for cars, particularly to accelerate the decarbonisation of the transport sector. Setting stringent CO2 emission standards and including an incentive mechanism has helped to increase…

Consultation response

Suomen Biokierto ja Biokaasu ry, 26 Nov 2020

Finnish Biocycle and Biogas Association welcomes the efforts of the European Commission to revise the existing legislation to achieve a new 2030 target and the climate neutrality objective by 2050. Despite all the current efforts at the EU level, the greenhouse gas emissions are not decreasing in…

Consultation response

Asociación de la Industria del Combustible de España, 26 Nov 2020

The IIA opens the door to support many more technologies that are vital for transport and industrial decarbonisation AOP supports the EU 2050 Climate Neutrality ambition and has published its pathway to be an essential part of reaching this goal: https://bit.ly/3nSh3mZ. We show that liquids are a…

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Energifabriken i Sverige AB, 8 Nov 2021

Energifabrikens feedback, Vehicle regulation 8 november The valuation of vehicles must be based on emissions throughout the life cycle (well-to-wheels) and not on emissions from the exhaust pipe (tailpipe regulation). This would also be the logical regulation considering that the climate target in…

Consultation response

, 8 Nov 2021

The EU's climate targets are the most ambitious in the world. To achieve the 2030 and 2050 objectives, all possible technological solutions must be used – this includes electric mobility as well as efuels and hydrogen. Electric mobility is rightly picking up momentum, but even with a very ambitious…

Consultation response

CNG-Club e. V., 8 Nov 2021

Die Überprüfung der CO2-Flottenregulierung innerhalb des New Green Deal bietet nach Ansicht des CNG-Clubs e. V. beste Chancen, die Klimaziele im Verkehr zu erreichen. Unerlässlich dafür sind eine ehrliche Betrachtungsweise der Gesamtemissionen verschiedener Antriebe und Fahrzeugarten, die…

Consultation response

Svenska Bioenergiföreningen, 8 Nov 2021

The EU regulation has to change from zero tail-pipe to well-to-wheels and conventional biofuels from crops are much needed also for cars. The EU climate target for the transport sector is far too low, only 13 percent in emission reduction by 2030 compared to the Swedish target of 70 percent…

Consultation response

Bayerischer Handwerkstag, 8 Nov 2021

Fit-for-55-Paket: Verkehrspolitische Aspekte Der Bayerische Handwerkstag (BHT) unterstützt das Bestreben, den Klimawandel zu bremsen. Handwerksbetriebe sind der Motor für klimapolitische Kernkonzepte wie beispielsweise energetische Gebäudesanierungen, Ausbau regenerativer Energiekonzepte oder der…

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Swedish Gas Association / Energigas Sverige, 8 Nov 2021

Consultation response

Český plynárenský svaz, 29 Oct 2021

• CGA argues for a change in the methodology for environmental impact assessment of vehicles from "tank-to-wheel" approach, i.e. emissions measured on the tailpipe to "well-to-wheel" approach or "life-cycle assessment" with an open cycle taking into account the so-called "end-of-life" of…

Consultation response

International DME Association, 26 Nov 2020

The International DME Association (IDA) welcomes the opportunity to provide comments on the inception impact assessment on the Amendment of the Regulation setting CO2 emission standards for cars and vans. Please find the IDA's feedback in the document attached.

Consultation response

Agora Verkehrswende, Agora Transport Transformation gGmbH, 26 Nov 2020

Agora Verkehrswende appreciates the opportunity to provide feedback at the beginning of this process. Generally, as electrification progresses, it would be more suitable to base the standards on energy efficiency rather than CO2 emissions in order to address the imbalance between electric and…

Consultation response

, 26 Nov 2020

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe. With around 1,3 million employees in Germany and a turnover of…

Consultation response

Swedish Gas Association / Energigas Sverige, 26 Nov 2020

The EU has committed itself to carbon neutrality by 2050. The Swedish Gas Association supports this commitment, and we are convinced that all sustainable technologies will be needed if the EU is to have a chance of succeeding. This is especially true for the decarbonization of the transport sector…

Consultation response

European Technology and Innovation Platform Bioenergy, 26 Nov 2020

The European Technology and Innovation Platform Bioenergy (ETIP Bioenergy) would like to confirm the position that biofuels have the potential to contribute significantly to the energy transition, in order to achieve a reduction of CO2 emissions from cars and vans cost-effectively, in line with the…

Consultation response

Inter-Environnement Wallonie, 26 Nov 2020

Les actuels objectifs 2025-2030 manquent cruellement d'ambition et ne sont pas compatibles avec une réponse appropriée aux enjeux climatiques. Rappelons que, dans son rapport 1,5°C, le GIEC soulignait que « Dans les trajectoires qui limitent le réchauffement planétaire à 1,5 °C sans dépassement ou…

Consultation response

, 26 Nov 2020

Consultazione comunitaria su norme su emissioni di CO2 per autovetture e furgoni. Contributo unem L’industria della raffinazione italiana, rappresentata da unem, è pronta ad affrontare il processo di decarbonizzazione dei prodotti e dei processi a sostegno del raggiungimento degli obiettivi…

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, 26 Nov 2020

Consultation response

, 25 Nov 2020

Greenhouse gas emissions and climate change are, by nature, a global issue which calls for an integrated approach in which all sectors and industries need to play a role. Given the magnitude of the issue and to achieve the European Union’s 2050 climate-neutrality objective, we must save as much CO2…

Consultation response

CNG-Club e. V., 24 Nov 2020

Wegen der befürchteten klimatischen „tipping points“ ist der Rückgang der globalen THG-Emissionen in den nächsten 10 oder 15 Jahren und das Nichtüberschreiten des THG-Restbudgets die entscheidende Frage – bei endlichen Budgets der Verbraucher und öffentlichen Haushalte. Wichtig sind daher diese…

Consultation response

Confederación Española de Empresarios de Estaciones de Servicio, 24 Nov 2020

La reciente publicación del Plan del Clima 2030 por parte de la Comisión Europea ha aumentado el objetivo general de reducción de emisiones de GEI para 2030 del -40% al -55% (frente al nivel de 1990). El objetivo de reducción a largo plazo para 2050 permanece sin cambios, sin embargo, el nuevo plan…

Consultation response

Region Östergötland, 23 Nov 2020

Region Östergötland ser mycket positivt på Europeiska kommissionens ambition att minska transportsektorns miljöpåverkan genom ökad användning av fossilfria drivmedel och teknik som möjliggör emissionsfri drift. Kraftfulla åtgärder och en mångfald av lösningar kommer att krävas för att nå ambitiösa…

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Český plynárenský svaz, 20 Nov 2020

The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose…