Analysis on Europe’s heavy-duty CO2 standards

This report provides a comprehensive analysis of the electric vehicle (EV) recharging market in the EU27 + UK, focusing on the publicly accessible recharging infrastructure and related services. The goal is to assess the industry dynamics, regulatory initiatives, public support, and competitive outcomes across the region. The analysis includes a more detailed investigation of four EU Member States: Ireland, Italy, Croatia, and Belgium.
Under the proposal, the targets for CO2 reductions are set to increase significantly. By 2030, a reduction of 45% is targeted, followed by 65% by 2035, and an ambitious 90% reduction by 2040. These targets will be applicable to a range of vehicles, including trucks, coaches, and buses, with specific targets tailored to each vehicle type. Furthermore, the proposal allows for differentiated targets based on factors such as vehicle weight and configuration.

The reference period for the new targets will be the 2025 reporting period for newly added vehicles, while vehicles already regulated will continue to use the 2019 reporting period. To ensure that reported CO2 emissions are not artificially inflated, the EC plans to closely monitor emissions data in 2025.

Source: An analysis on the revision of Europe’s heavy-duty CO2 standards | The ICCT

The proposed target for city buses

One notable requirement of the proposal is that city buses must achieve a 100% reduction target from 2030 onwards. This aligns with the increasing trend of zero-emission buses in the market, driven by investments from established manufacturers as well as new players, including Chinese manufacturers. To secure a sustainable supply of zero-emission technologies, public contracts will be awarded based on specific criteria that prioritize net-zero technologies.

Projected emissions reductions

The projected impact of the proposed regulation is substantial, with an estimated avoidance of 1.8 billion tons of CO2 emissions through 2050. Model projections indicate that by 2050, all buses, coaches, and medium trucks could achieve an 86% reduction in emissions, while heavy trucks could achieve a 68% reduction. Two alternative scenarios, Target Level Medium (TL_Med) and Target Level High (TL_High), illustrate varying levels of emissions reduction compared to the proposal.

Source: An analysis on the revision of Europe’s heavy-duty CO2 standards | The ICCT

Anticipating the increased adoption of zero-emission HDVs, the proposal envisions a significant surge in their numbers. By 2030, it is projected that there could be 675,000 zero-emission HDVs on European roads, with the number rising to nearly 3 million trucks and 6 million vehicles by 2040 and 2050, respectively.

Source: An analysis on the revision of Europe’s heavy-duty CO2 standards | The ICCT


Compliance with the proposed standards will be assessed on a fleet-wide basis, separately for freight vehicles and passenger vehicles, to prevent the offsetting of high-emitting trucks with low-emitting buses. This ensures that larger manufacturers do not gain an unfair competitive advantage over medium-sized manufacturers that solely produce buses.


Certain exemptions are allowed within the proposal. Small and medium enterprises producing fewer than 100 vehicles in a reporting period are exempted, while a separate exemption allows a limited proportion of buses to remain exempt if they cannot be replaced by zero-emission vehicles due to technical constraints.

The credit and debt system

A credit and debt system is introduced to incentivize manufacturers to reduce emissions below the targets and penalize those who fail to do so. Notably, the proposal extends the credit life for credits earned from 2025 to 2040, which raises concerns about potential delays in the deployment of zero-emission technologies and could undermine the effectiveness of the standards.

In conclusion, the proposed revisions to Europe’s heavy-duty CO2 standards are designed to achieve more substantial emission reductions through higher targets, expanded coverage, and enhanced compliance measures. The proposal anticipates a significant increase in the number of zero-emission trucks and buses on the road, but the extended credit life raises concerns about the pace of transitioning to zero-emission technologies.

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