Institut Mobilités en Transition
IMT
L'IMT est une association à but non lucratif agissant comme un Think-tank indépendant dédié aux enjeux de la transition environnementale dans le domaine de l'industrie et du transport.
ID: 008697197178-54
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
Please find our feedback in the attached document.
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
10 Oct 2025
The Institut Mobilités en Transition (IMT-Iddri) contributes to the European debate on the evolution of CO2 emission performance standards for new passenger cars and vans. 1. PHEV/EREV: More Emissions and Higher Total Costs of Ownership (TCOs) than BEVs An independent study by IMT on battery electric vehicles (BEV), plug-in hybrid vehicles (PHEV) and extended-range electric vehicles (EREV) for the 20352040 horizon to be published at the end of October 2025 shows that across all use cases (over 1000 studied combinations), PHEVs and EREVs would remain significantly more GHG-intensive and more costly than BEVs. The findings indicate that loosening the current rules or extending PHEV sales beyond 2035 would slow down decarbonisation, increase mobility costs for households, and send contradictory signals to industry. By 2035, medium-range battery PHEVs are expected to emit on average +67% more GHG than BEVs; HEVs would emit even more, and EREVs slightly less, but still well above BEV levels. The total TCO of medium-range battery PHEVs would exceed that of BEVs in all use cases especially for second-hand buyers, who account for the majority of car users: +8% for new car buyers, and +18% for third-hand buyers (vehicles over 10 years old). Even in a hypothetical scenario of 100% biofuels, PHEVs would still emit +19% more GHG than BEVs and cost +14% more for new vehicles and +29% more for third-hand buyers. They would also generate, an average trade deficit twice as high as BEVs due to their continued reliance on imported fossil fuels. 2. Made in Europe Electric Vehicles The low-carbon transition must go along with an industrial strategy that strengthens European sovereignty and creates value and jobs. IMT proposes that a BEV should be considered Made in Europe if (cumulative criteria): Battery cells are assembled in Europe and strategic components (cathodes, anodes, BMS) are produced domestically, with increasing thresholds over time (20% of the battery bill of materials by 2027, progressively reaching 50% by 2035); At least 80% of the non-battery value comes from European components, with steel and aluminium produced and processed in the EU and all other components undergoing their last substantial transformation in the EU; From 2030 onwards, a minimum share of low-carbon materials is required (e.g. 40% low-carbon steel, including recycled content); Additional criteria may be applied to raw material origin to recognise European production of upstream components and parts. This definition would turn the Made in Europe label into an industrial lever to secure supply chains and support a just and competitive transition. Implementation could rely on crediting or bonus mechanisms within national regulatory or fiscal systems, or other public policy tools designed to boost demand for affordable electric vehicles. 3. Small Electric Vehicles Electrifying the small vehicle segment (A and B segments) is essential for the mass uptake of BEVs and for ensuring accessibility for low- and middle-income households, as well as responding to strong existing market demand. IMT proposes to define these vehicles as: 100% electric; Price capped at 20,000 until 2030, then 15,000 thereafter; Maximum width 170 cm and length 375 cm; Fully compliant with European local content rules; Optional: with a below 50 kWh battery capacity criterion. 4. Recommendations IMT therefore recommends maintaining the current trajectory of Regulation (EU) 2019/631, ensuring economic and climate security for European citizens and industries, namely: Complete phase-out of internal combustion vehicles including hybrids and EREVs by 2035; Maintenance of the current reforming of the PHEV utility factor, so it get closer to reallife emissions; Strict tailpipe emission standards; Exclusion of biofuels. There is no demonstrated need to introduce flexibilities for car manufacturers, who are already on track to meet their targets by 2029, as confirmed by the EV Trans
Read full responseMeeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Transport and Environment (European Federation for Transport and Environment) and International Council on Clean Transportation
9 Oct 2025 · Automotive
Response to Clean corporate vehicles
5 Sept 2025
For Member States and the EU to green the running car stock and reach their road transport decarbonization targets, greening corporate fleets with the incorporation of zero-emission vehicles (ZEVs) is a key lever that cannot be overlooked. Corporate fleets renew twice faster than households vehicles, and register almost of new cars entering the EU market. As of now, BEVs account for 17% market share of the total in the first half of 2025 in the EU, which does not suffice to contribute significantly towards OEMs CO2 Standards for cars and vans, while corporate fleet electrification is lagging behind in most EU Member States. This delay and disparities in corporate fleets' electrification in Europe justifies new tools. Given the needed acceleration at EU level to match the decarbonisation targets, we cannot rely solely on national and disparate initiatives. We need an homogenised Clean Corporate Vehicle Initiative for maximised efficiency. Key Messages 1. Accelerating the uptake of ZEVs in corporate fleets in Europe requires legally binding greening quotas for large corporate fleets. We recommend that the quotas account for zero emission vehicles only (all Plug-in Hybrids are excluded). The objective of 90% of ZEVs in large fleets annual renewals by 2030 is accurate both in terms of feasibility and tapping the seam of business investment vs households. 2. Driving demand for zero-emission vehicles by businesses across all European Member States implies putting in place an EU-wide Regulation in order to ensure a collective, coherent and coordinated move of European business fleets, and a level-playing field with fair competition amongst stakeholders on the Single Market. 3. Greening trajectories should be differentiated depending on the vehicle segment (passenger cars vs vans) and depending on the maximum permissible laden weight categories for trucks. Targets could also be distinct from one Member State to another, to account for EV readiness national disparities. 4. For freight, introducing greening procurement quotas for shippers and large cargo owners (that could be complemented with an incentive mechanism for transporters at national level) could secure demand for zero tailpipe emissions trucks while ensuring a fair effort sharing amongst logistics actors. 5. The Regulation could introduce a weighting of the greening quotas by some European preferential criteria, like an eco-score, to mobilise the industrial potential of this initiative. Regulatory and Fiscal impulses do work : France's Case Study Compulsory greening quotas and an evolutive fiscal setup are bringing results in France. Fiscal thresholds are becoming impactful and the first half of 2025 marks a turning point : companies are catching up with private buyers in electric vehicle adoption. H1 2025 has seen a surge in corporate fleet electrification in France, with the coming into force of a penalty for non-compliance to the quotas. We need an EU Regulation on Corporate Fleets. Member State based initiatives alone are insufficient to efficiently spur ZEV uptake across Europe. Proposing a Regulation on a Pan-European greening quota system for corporate fleets will play highly in favour of the fulfilment of the EU decarbonization targets, European automotive industry, competitiveness, and stability.
Read full responseMeeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)
5 Sept 2025 · Automotive
Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)
1 Jul 2025 · Battery
Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)
8 May 2025 · Automotive
Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)
9 Jan 2025 · Future of the automotive sector