Decarbonizing heavy-duty can’t be only based on an early-stage technology

On November 21, 2023, the plenary vote for CO2 emission standards for heavy-duty vehicles (HDVs) will take place in the European Parliament. Growing evidence about potential raw materials shortages, insufficient battery production capacity in the EU, increased repair costs for BEVs, together with large infrastructure and grid needs reinforce the call to vote for a technology-inclusive approach, to ensure that the decarbonization of HDVs can be achieved within the proposed timeframe by expanding technology options for compliance, for the benefit of climate, security of supply, transport value chain and consumers.

Today the resilience and flexibility of European logistics is based on liquid fuels

Heavy-duty transport is a vital sector for the functioning of the EU internal market, but today it is also responsible for just over a quarter of the greenhouse gas (GHG) emissions from road transport, and for about 6 percent of the EU’s total GHG emissions.

Today, the vast majority of trucks sold have an ICE using liquid fuels. Out of the total fleet of over 6 million heavy-duty vehicles for transport of goods in the EU, about 2 million vehicles are used in the long-haul transport goods (40-76 tons). Technologies for battery-electric and fuel-cells trucks are developing fast and have a big decarbonization potential. But at present, there is only a tiny fraction (< 1 percent) of electric or fuel-cell trucks in operation worldwide, often in pilot programs.  These routes will require development of an entire new ecosystem for trucks and energy supply, and distribution. Extrapolating today’s very early progress to legislate the long-term exclusive solution creates large unnecessary risks for European industries and supply chains.   Instead, all options that can have a rapid impact should be equally supported.

CO2-neutral fuels could speed up the decarbonization of heavy-duty transport

Nonfossil liquid fuels are progressively replacing fossil fuels, and the pace will depend on whether there is a long-term role in road transport. Therefore, transport operators and vehicle manufacturers should be encouraged and allowed to use ‘CO2-neutral fuels’ (liquid and gaseous biofuels, and synthetic fuels) to speed up this transformation. Depending on use cases, technology diversity is needed, including electrification/hybridization, hydrogen, and sustainable and renewable fuels.

CO2-neutral fuels are complementary to electrification to speed up emission reductions.

A Carbon Correction Factor (CCF) is not a measure to reduce the level of ambition, it could enable the opposite

The quicker way to abate GHG emissions from road transport is to replace fossil-based fuel as fast as possible, hence the need to create a business case for the upscale of the production of CO2-neutral fuels to decarbonize both the existing and the upcoming fleet. CO2-neutral fuels are complementary to electrification to speed up emission reductions.

The quicker way to abate GHG emissions from road transport is to replace fossil-based fuel as fast as possible

The CCF is a methodology that corrects the ‘tailpipe’ approach, by taking into account the contribution of CO2-neutral fuels for compliance with the HDV CO2 standards. As a starting point, the RED obliges fuel suppliers to deliver a share of 29 percent of renewable energy in the transport sector, which will deliver a reduction of GHG emissions of at least 14.5 percent by 2030. ETS 2 will further limit CO2 emissions from transport. Both are not recognized in the CO2 standards for vehicles. But recognizing a route where trucks could be supplied with high or 100 percent levels of CO2-neutral fuels could grow renewables supply faster through incentivizing investment in sustainable/advanced bio and synthetic fuel technologies.

There is enough biomass in Europe

The study by Imperial College London consultants for Concawe shows that biomass is not scarce. The potential availability of sustainable biomass is more than sufficient to allow advanced and waste-based biofuel to contribute together with other solutions. With no harm to biodiversity, it is possible to support an advanced and waste-based biofuel production in the EU of up to 97 Million tonnes of oil equivalent in 2030 and up to 175 Mtoe in 2050.

Legislation should be based on sound science and a fair assessment of all options

The current HDV CO2 standards regulation is based on a pure ‘tank-to-wheel’ approach, so only the vehicle emissions at time and place of use are counted.  This method, a relic of fuel economy measurement, became an efficiency measurement, but is scientifically unsuitable for measuring the overall impact of the choice of vehicle and energy today.  For an EV truck, this method has no influence on the efficiency, weight, aerodynamics or energy carbon intensity used by the truck.  Regardless of any of these important factors, good or bad, the truck gets a ‘zero’.  Meanwhile all biogenic or captured carbon is treated as fossil emission. This is scientifically wrong and contradicts the methodology used in other CO2 regulations, such as ETS.

Vehicle CO2 regulation urgently needs a revised methodology.

From a climate perspective, it does not matter whether GHGs are emitted during the production of the car or of the energy carrier, or at the tailpipe

A scientific life-cycle assessment of the different technology and energy options shows that in reality there is no zero-emission vehicle, and electric trucks and ICEs powered with CO2-neutral fuels can certainly match electrified or fuel-cells vehicles for the decarbonization of transport. Vehicle CO2 regulation urgently needs a revised methodology.

The Concawe comparator developed by IFPEN to assess the life-cycle GHG emissions from HDVs in real-world conditions, shows that when comparing a plug-in hybrid ICE truck, fueled with CO2-neutral fuels, with a battery electric truck the CO2 emissions performances of the different powertrains are very similar, and in some cases the hybrid technology performs even better. Renewable fuels are as effective as electromobility for abating GHG emissions.

Vehicle Regulation that recognizes renewable fuels will support investment and better energy resilience in Europe

Proper recognition of CO2-neutral fuels could speed up the decarbonization of heavy-duty transport. MEPs can make a forward-looking decision for HDVs by supporting a coherent and RED-compliant definition of CO2-neutral fuels and the CCF methodology.  The arbitrary exclusion of competing technical solutions could result in an inefficient decarbonization process with increased risk to resilience of Europe’s logistics and to progress toward decarbonization goals.


John Cooper, Director General, FuelsEurope