Recommendations for the proposed heavy-duty vehicle CO2 standards in the European Union

On May 17, 2018, the European Commission issued a regulatory proposal that would set initial carbon dioxide (CO₂) emission standards for new heavy-duty vehicles (HDVs) sold in the European Union. Drawing on the ICCT’s research and international regulatory experience, this position brief makes certain recommendations aimed at improving the environmental outcomes of the proposed standards.

• Modify the reduction targets to at least 20% in 2025 and 35% in 2030, to utilize the available cost-effective technology potential supported by the impact assessment.
• Evaluate the net economic and societal benefits of more stringent targets and explicitly consider the role of the standards in meeting long-term climate targets.
• Include engine standards in order to cover the vehicle groups that are not subject to any CO₂ regulation.
• Amend the certification procedure to ensure unequivocal identification of vocational trucks based on technical parameters.
• Redefine the mileage and payload weighting factors for the calculation of manufacturer-specific average CO₂ emissions so the compliance metric is an actual weighted average with physical meaning.
• Apply the ZLEV super-credit correction to the average CO₂ emissions of the individual subgroups in order to consider the differences in payload and mileage of the different vehicle subgroups and make the ZLEV incentive proportional to lifetime CO₂ savings of ZLEVs.
• Limit the ZLEV incentives to only the regulated vehicle classes. Vehicle groups not subject to mandatory CO₂ reductions (e.g., vocational trucks and buses) that therefore have no associated compliance cost should not be part of the ZLEV incentive.
• Develop a validation mechanism for the future 2019 baseline based on the data available to the Commission for the development of the regulatory impact assessment.
• Freeze the CO₂ certification procedure, and the weighting of the different payloads and mission profiles used in the context of the CO₂ standards until the 2022 review. Any change in methodology should be retroactively applied to the 2019 baseline and readjust the 2025 targets.
• Implement regulatory safeguards to ensure that the proposed 30% reduction target by 2030 represents a minimum ambition level and that the 2022 review does not result in a 2030 target less stringent than the ones currently proposed.
• Implement regulatory safeguards to guarantee the inclusion of trailers in the planned 2022 review.
• Make public the reference, target, and actual CO₂ emissions of each subgroup for each manufacturer, in addition to manufacturer-specific average CO₂ emissions.

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