EU: Heavy-Duty Vehicles: GHG Emissions

Background

The first carbon dioxide emission performance standards for new heavy-duty vehicles (HDV) in the European Union were set by Regulation (EU) 2019/1242 in June 2019 [4416]. The regulation required that the average CO₂ emissions from selected HDV categories be reduced by 15% in 2025 and by 30% in 2030, relative to a 2019/2020 baseline. The baseline value is determined from the certified CO₂ emissions of new trucks collected under a separate regulation on CO₂ monitoring and reporting [4593].

In May 2024, Regulation (EU) 2019/1242 was amended to tighten the 2030 target and introduce new targets for 2035 and 2040. A 45% reduction would now be required by 2030, 65% by 2035 and 90% by 2040. These targets are intended to force the adoption of zero tailpipe emission vehicles such as battery electric trucks. The revised rules also expand the scope of the regulation to make almost all new heavy-duty vehicles with certified CO₂ emissions—including smaller trucks, urban buses, coaches and trailers—subject to emission reduction targets [6336].

Emission Reduction Targets

The amended 2024 regulation greatly expanded the scope to include more truck types, buses, coaches, trailers, and vocational vehicles, Table 3 [6337].

The CO₂ standards follow a tank-to-wheel approach, addressing only the tailpipe CO₂ emissions of the regulated vehicle groups [4595][6337]. For each manufacturer, the CO₂ emissions are regulated on a fleet-wide basis through a metric called average specific CO₂ emissions, expressed in grams of CO₂ per tonne-kilometer (g/t-km) and computed using a simulation tool. The standards are limited to CO₂ emissions—other GHG gases such as CH₄ or N₂O are not regulated (however, CH₄ emissions from gas engines have been regulated since the Euro III stage).

The calculation starts with CO₂ emissions for all vehicles in each sub-group, which are weighted for different cycles and payloads. Then, emissions are averaged over all sub-groups using a mileage and payload weighting factor (MPW) that reflects the difference in freight activity between the vehicle sub-groups. Finally, the emissions are multiplied by a zero- and low emissions (ZLEV) factor. The ZLEV factor will no longer apply from 2030.

The regulation mandates relative fleet-averaged CO₂ emission reductions against a fixed set of baseline emission values for each vehicle sub-group that is common to all manufacturers. The baseline emissions for the 2019 version of the regulation are based on data resulting from the monitoring and reporting regulation from 1 July 2019 to 30 June 2020. For the 2024 amended regulation, the baseline emissions period is shown in Table 3.

For a given year, the reporting period includes vehicles registered from 1 July of the given year to 30 June of the next year. The implementation of the regulation is divided into five-year terms with different stringencies, Table 3.

Achieving these targets would require that a sizable proportion of each manufacturer’s fleet be zero tailpipe CO₂ emission vehicles, such as electric or hydrogen fueled trucks.

Incentives for Zero- and Low Emission Vehicles

Zero emission vehicles (ZEV) are vehicles certified to zero tailpipe CO₂ emissions. A truck is designated as a low emission vehicle (LEV) if its CO₂ emissions are less than 50% of the baseline CO₂ emissions of the respective sub-group. The regulation includes two types of incentives to accelerate the development and deployment of ZEV and LEV vehicles [4595][6337]:

• “Super-credits” are available over the period of 2019-2024
• “Benchmark” incentive system is effective from 2025 to 2029

In each case, the incentive is applied as a ZLEV factor that reduces the manufacturer’s emissions. The ZLEV factor is capped at a minimum of 0.97, meaning that the ZLEV incentives can only reduce the average emissions of a manufacturer by a maximum of 3%. The final incentives for ZLEVs are limited to vehicles category N (i.e., buses are excluded). In regulated vehicle groups (Table 3), both ZEVs and LEVs count towards the incentives. In unregulated truck categories, only ZEVs are part of the incentive’s scope.

From 2025 to 2029, two calculations are applied to freight vehicles to determine a manufacturer’s fleet-average emissions. In calculating a manufacturer’s accrued debits, the ZLEV factor is applied. In calculating credits, the ZLEV factor is not used. Thus, the ZLEV factor can only help a manufacturer earn credits until 2025 but can help them avoid debts until 2029.

Super-Credits. Under the super-credit scheme, ZLEVs are counted as more than one vehicle in the calculation of the average CO₂ emissions of a manufacturer. ZEVs are double counted in the averaging set, while LEVs are counted as up to 2 vehicles, depending on their CO₂ emissions—their super-credit multiplier increases linearly from 1 to 2 as their CO₂ emissions decrease from 50% below the baseline to zero (e.g., a LEV with emissions 75% below the baseline counts as 1.5 vehicle).

The calculation of the super-credit ZLEV factor depends on the share of ZLEVs in a manufacturer’s fleet and on the applicable super-credit multiplier for each ZLEV. For a given manufacturer, the ZLEV factor is defined as:

ZLEV factor = V / (V_conv + ZLEV_in + ZEV_out)(1)

where V is the total number of regulated HDVs, V_conv is the total number of regulated HDVs with conventional powertrains, ZLEV_in is the resulting number of ZLEV vehicles within the regulated groups after accounting for super-credits, and ZEV_out is the resulting number of ZEV vehicles outside of the regulated groups multiplied by 2.

Benchmark System. From 2025 to 2029, manufacturers are rewarded for the sale of ZLEVs only after they meet a sales benchmark of 2%. If the benchmark is not achieved, there are no negative consequences.

LEVs are counted between 0 and 1, depending on their CO₂ emissions—for instance, an LEV with CO₂ emissions 75% below the sub-group’s baseline would count as 0.5 in the ZLEV sales share calculation. The benchmark ZLEV factor is defined as:

ZLEV factor = 1 – (ZLEV_{sales share} – 0.02)(2)

As the ZLEV factor is capped at a minimum of 0.97, the maximum allowable benefit is reached when a manufacturer’s ZLEV share reaches 5%. A minimum ZLEV sales share of 0.75% is required from the regulated vehicle groups to benefit from the incentives. Otherwise, the ZLEV factor is set to 1, regardless of the number of ZEVs sold outside of the regulated groups.

Flexibilities & Other Provisions

The regulation contains certain flexibilities and a number of other provisions, including:

• Banking and Borrowing Scheme—Manufacturers are allowed to accumulate CO₂ emission credits and debts during specific periods of time. At any given time, the total debt of a manufacturer cannot be higher than 5% of its 2025 target multiplied by the respective number of vehicles. All debt must be cleared by 2029—the accumulated credits or debt cannot be carried over to 2030. Credits and debts are not transferable between manufacturers.
• Penalties—Manufacturers are required to pay a per-vehicle penalty of €4,250 for each gCO₂/t-km of excess emissions from 2025 onward. An increased penalty of €6,800 per gCO₂/t-km from 2030 onwards was dropped in the amended regulation.
• Real-World CO₂ Emissions and Energy Consumption—The HDV CO₂ standards contain amendments to the HDV type approval regulation that mandate the introduction of on-board fuel consumption and payload meters.
• In-service Verification of CO₂ Emissions—Type-approval authorities are responsible for verifying that the certified CO₂ emission values correspond to those measured during in-service verification tests. The on-road verification test (introduced in 2019 as an amendment to the CO₂ certification regulation [4596]) measures the wheel torque, engine speed and fuel consumption of the HDV. To pass the test, the measured CO₂ emissions must not exceed the certified values by more than 7.5%.

Review Clause

The 2019 regulation required a review by the end of 2022 to determine the effectiveness of the CO₂ standards, assess the appropriateness of the 2030 CO₂ reduction target, consider the possibility of introducing binding 2035 and 2040 emission targets, setting emission standards for other vehicle types, as well as the development of a methodology for the assessment of the full life-cycle CO₂ emissions of HDVs and a number of other aspects of the regulation [4416]. Apart from introducing a life-cycle CO₂ emissions assessment methodology, these issues were addressed in the amended regulation.

The amended 2024 regulation requires a review to be carried out by the end of 2027 to determine the effectiveness of the regulation, especially regarding the objective of climate neutrality by 2050 [6336]. In particular, the Commission is asked to assess several factors including:

• The state alternative fuels recharging and refueling infrastructure for heavy-duty vehicles in the EU and in countries outside the EU in which EU-registered heavy-duty vehicles frequently operate.
• The impact of establishing minimum energy efficiency thresholds for new zero emission heavy-duty vehicles.
• The impact of extending the scope of the regulation to cover small trucks with a GVW ≤ 5 t and special-purpose and off-road vehicles.
• The role of a methodology for registering heavy-duty vehicles running exclusively on CO₂ neutral fuels.
• The role of a carbon correction factor (which would credit the certified emissions of a vehicle based on the share of alternative fuels in Europe’s road transport) in the transition towards zero-emission mobility in the heavy-duty vehicles sector.
• The possibility of developing a common methodology for the assessment of the full lifecycle CO₂ emissions of new heavy-duty vehicles.