Response to Call for Evidence: Impact Assessment for Revision of CO2 Emission Standards Regulation for LDVs

Read the full response here.

The Network for Sustainable Mobility, of which Eurogas is an active member, has responded to the European Commission's Call for Evidence regarding an impact assessment for the revision of the CO₂ Emission Standards Regulation for new cars and vans.

The current CO₂ standards Regulations (LDVs and HDVs) are based on a “tailpipe approach”, where emissions are considered only in the use phase of the vehicle. Therefore, the proposed definition by the Commission creates a distortion between CO₂-neutral fuels being evaluated on a Well-to-Wheel basis while other technologies, such as electric vehicles, remain under the “tailpipe approach.”

These vehicles, operating solely on CO₂-neutral fuels, should be eligible for a zero-emission status. This designation would ensure that carbon- neutral fuels are given the same regulatory and market recognition as electric vehicles while maintaining consumer choice, competitiveness and technological diversity.

The revision offers the opportunity to reassess the pathway to decarbonise the sector and ensure that all sustainable solutions are valued as a complement to electrification. All technologies able to reduce GHG emissions should be recognised and allowed to fairly contribute to decarbonisation efforts, including renewable and low-carbon fuels, hydrogen, as well as vehicle technologies like Plug-in Hybrids (PHEVs), Range Extender Electric Vehicles (REEVs), and highly efficient internal-combustion-engine vehicles.

Therefore, we believe the impact assessment accompanying the Revision of the CO₂ Standards for cars should model the economic, social and environmental benefits of the introduction of the following provisions in the Regulation:

• A technology-neutral definition of CO₂-neutral fuels based on the Renewable Energy Directive, to be included in both the light-duty and heavy-duty CO₂ standards
• A Carbon Correction Factor (CCF) to reflect the share of CO₂-neutral fuels already available
• A new vehicle category exclusively powered by CO₂-neutral fuels, leveraging all potential monitoring methodologies, such as digital solutions and mass-balancing approaches

Read the full response below.