Technology-neutral approach to CO2 regulation for heavy-duty vehicles

A collective of 65 companies and associations from the logistics, bus, fuel, commercial vehicle, and supplier industries have penned an open letter to the German government, advocating for a technology-neutral approach to CO2 regulation for heavy-duty vehicles. They emphasise the importance of recognising renewable fuels to achieve more effective and rapid climate protection in the transportation sector.

The transformation to climate neutrality is a significant challenge for heavy-duty vehicles, especially with the expected increase in transport volume. The authors of the letter argue for a technology-neutral CO2 regulation, which they believe is the only path to effective climate protection. They stress the need to consider all options, including renewable fuels, to counter the slow market penetration of emission-free heavy-duty vehicles and the gradual development of a suitable refueling and charging network.

Renewable fuels are already contributing to the reduction of traffic-related CO2 emissions. Studies, including those by the Fraunhofer Institute, confirm the substantial potential of these fuels. However, the current proposal by the EU Commission on CO2 emission standards for heavy-duty vehicles undermines these efforts by not being technology-neutral. It leans towards battery-electric, fuel cell electric drives, and hydrogen engines, neglecting the contribution of renewable fuels.

The letter introduces the concept of the Carbon-Correction-Factor (CCF), which promotes the use of renewable fuels and ensures technology neutrality. The existing VECTO vehicle emission calculation tool operates under the mistaken assumption that combustion engine vehicles are exclusively powered by fossil fuels. The CCF aims to correct this by considering the emission reduction contributions of renewable fuels, leading to a fair and realistic calculation of a vehicle’s CO2 emission values.

The signatories call on the German government to actively support the introduction of the CCF in the regulation of CO2 emission standards for heavy-duty vehicles at the European level. They believe that joint efforts and a technology-neutral design of the CO2 regulation will enable the EU to meet ambitious climate targets and succeed in transforming the heavy-duty vehicle sector in Europe.