Eurogas Position Paper: Review of the CO2 Emission Standards Regulation
Full Eurogas position here.
Eurogas welcomes the inclusion of flexibilities for OEMs on new vehicle registrations, de facto recognizing the role that renewable fuels play in the decarbonization of the sector. Counting emissions of renewable fuels over their lifecycle finally aligns this Regulation, at least in the concerned part, with the counting methodology included in the Renewable Energy Directive (2018/2001).
However, allowing this flexibility to count only as of 2035 and the overall contribution being capped to 3%, will not change much to the current framework, especially since emissions outside of this calculus are still measured at the tailpipe and the avoided emissions, over the fuel’s lifetime, are not accounted for. Accordingly, Eurogas insists that the following improvements to the text are taken into account:
- Anticipate the application of fuel credits (Article 5a) to when the revised Regulation will enter into force and remove all caps (3% cap to the contribution of fuel credits and the 10% cap to OEMs’ EU fleet targets).
- Align the list of fuels eligible for the fuel credits of Article 5a with Articles 29, 29a and the lists in Annex IX part A and B of the RED (2018/2001).
- Implement recital 11 of the current Regulation by extending the definition of “zero emission vehicle” (ZEV) to a new vehicles category
Download full PDF below.
