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Photo of two semi trucks with trailers, branded Zero Emissions

How the EU can decarbonise overlooked heavy-duty vehicles 

October 11, 2023 Work Area: Zero-Carbon Fuels

The EU has managed to cut greenhouse gas emissions in every sector – except one. Transport emissions represent about a quarter of the EU’s total GHG emissions and they continue to grow1. And while the much talked about European Green Deal has made great strides towards cutting emissions from cars, shipping, and aviation, the heavy-duty road transport segment is not yet aligned with a net zero future. 

The good news is that we have tools at our disposal to tackle these emissions that are harming our climate and our health. In contrast to many other emitting areas that will need significant innovation and technologies that are not yet commercially available, trucking does not need a scientific breakthrough to decarbonise. Zero-emission vehicles using battery electric technology or fuel cells already exist and are ready to be deployed. What is missing is a strong signal to all the market participants, so they know at what pace to invest, produce, build and buy. 

The ongoing revision of CO2 emission performance standards for new heavy-duty vehicles is a key opportunity to enshrine such a signal in EU law. Clean Air Task Force has three key recommendations for how a strong regulation would look like: 

  1. Bold CO2 emissions reduction targets 

As its core mechanism, CO2 emissions reductions required will make or break this legislation. The EU has already committed to a 90% reduction in GHG emissions from transport by 2050 in its Sustainable and Smart Mobility Strategy. Without relying on not-yet-scaled solutions like carbon removals that will be badly needed elsewhere, heavy road transport has very limited room for manoeuvre. In fact, projections2 show that this segment must cut its emissions completely by 2038 for the EU to comply with its own Climate Law. A 100% CO2 emissions reduction target for new heavy-duty trucks by 2035 and an enabling intermediary target for 2030 will put the segment on a decarbonisation path that is consistent with Europe’s overarching commitments. 

  1. No additional incentives for “low-emission” vehicles 

In a world where *zero*-emission vehicles exist, there is no compelling reason to continue providing additional incentives to low-emission vehicles that only have to cut their emissions by half to qualify. Incentivising the deployment of worse-performing vehicles will detract from the ultimate objective – decarbonising the sector completely. The so-called zero- and low-emission factor should therefore not be applied to low-emission vehicles anymore and should be removed completely as of 2030, as proposed by the Commission. 

  1. No loopholes for technologies that are not able to meet the standards 

The Commission has designed CO2 emission standards regulation as a technology-neutral incentive for the heavy-duty vehicle sector to progressively move from fossil fuels to more climate-aligned propulsion systems. Ultimately, only vehicles with no tailpipe CO2 emissions will be compatible with high standards. Accordingly, there’s no room for loopholes like the so-called ‘carbon correction factor’, proposed by some Members of the European Parliament in their amendments, that perpetuate reliance on trucking technologies that cannot deliver zero tailpipe CO2 emissions. The Commission concluded in its Impact Assessment3 that any form of fuel-promoting mechanism in this regulation would not be cost-efficient but would in fact undermine effectiveness, blur the responsibilities of different stakeholders, and increase complexity and administrative burden. Likewise, the majority of vehicle manufacturers are not in favour of introducing such mechanisms4. Accounting for emissions across the full lifecycle is crucial but should be done in a rigorous, comprehensive manner in a separate fit-for-purpose legislation. 

Crucially, many world regions now recognise a business case in producing and selling clean technologies. The US has tens of billions of dollars, through the Inflation Reduction Act, to spend on various clean technologies relevant for the trucking sector and China is putting its weight behind a global expansion of its burgeoning electric vehicle-manufacturing operations. But it’s not just about government funds – regulatory certainty helps the industry plan their investments, innovate and create value. The US state of California has captured headlines this year as the first jurisdiction in the world requiring manufacturers to only sell zero-emission vehicles to distinct truck fleet types as of 2036, demonstrating clear leadership in this space. 

The automotive industry as a whole accounts for over 7% of the EU’s GDP and provides jobs to 14.6 million Europeans5. While EU manufacturers produce fewer heavy-duty vehicles than cars (about half a million units per year), the value added per unit produced is significantly higher in the heavy-duty vehicle segment6. Analysis shows that the EU could lose up to 11% of the market to China and the US by 2035 if it doesn’t speed up the clean transition of this segment7. Conversely, adopting the standards as proposed above would add 27 billion EUR in GDP and 23 000 jobs to the EU economy. 

The EU can and must use of this key opportunity to show that Europe will stake a claim on the clean automotive market of the future. 


1European Environment Agency, 2023. Transport and mobility. https://www.eea.europa.eu/en/topics/in-depth/transport-and-mobility

2 Mulholland et al., 2022. The CO2 Standards Required for Trucks and Buses for Europe to Meet its Climate Targets. https://theicct.org/wp-content/uploads/2022/03/hdv-co2standards-recs-wp-mar22.pdf

3 European Commission, Commission Staff Working Document Executive Summary of the Impact Assessment Report Accompanying the document Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2019/1242, 2023. https://climate.ec.europa.eu/system/files/2023-02/policy_transport_hdv_20230214_impact_assessment_en_0.pdf

4European Commission, Commission Staff Working Document Executive Summary of the Impact Assessment Report Accompanying the document Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2019/1242, 2023. https://climate.ec.europa.eu/system/files/2023-02/policy_transport_hdv_20230214_impact_assessment_en_0.pdf

5 European Commission, Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2019/1242, 2023. https://climate.ec.europa.eu/system/files/2023-02/policy_transport_hdv_20230214_proposal_en_0.pdf

6 European Commission, Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2019/1242, 2023. https://climate.ec.europa.eu/system/files/2023-02/policy_transport_hdv_20230214_proposal_en_0.pdf

7 Boston Consulting Group, 2023. Impact Assessment of the Transition to Zero-Emission Trucks in Europe. https://www.transportenvironment.org/wp-content/uploads/2023/09/2023_09_BCG_Impact_assessment_transition_ZE_trucks_Europe.pdf

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