Green Mobility Policy Brief — 28 November 2025— Omnibus Scrutiny, HDV infrastructure, UK Budget Adds EV Tax

Green Mobility Policy Brief — 28 November 2025— Omnibus Scrutiny, HDV infrastructure, UK Budget Adds EV Tax

Headlines

  • TRAN study urges performance-based overhaul of Combined Transport Directive to unlock modal shift
  • Ombudswoman finds maladministration in Commission’s handling of sustainability Omnibus and other urgent proposals
  • European mayors urge Commission to uphold 2035 CO₂ phase out for cars and vans
  • Ten Member States call for delayed and more flexible HDV charging targets ahead of AFIR revision
  • UK Budget introduces mileage-based charge for electric vehicles from 2028, prompting industry warnings over transition risks
  • UK government selects Heathrow’s third runway proposal for ANPS review and seeks CCC advice on net zero compatibility
  • UK to impose anti-dumping duties on Chinese biodiesel following TRA recommendation
  • NGO legal analysis concludes EU can extend ETS to international flights even where CORSIA applies
  • Honda calls for a cooperative EU local content model recognising inputs from like-minded partners
  • Dutch parliament backs steep rise in private jet flight tax as part of 2026 fiscal package

TRAN study urges performance-based overhaul of Combined Transport Directive to unlock modal shift

New research for the European Parliament’s transport committee called for a fundamental redefinition of combined transport and targeted infrastructure upgrades, after finding persistent structural bottlenecks and uneven intermodal connectivity across the Union. The accompanying expertise, prepared for the review of the Combined Transport Directive, concluded that a performance-based approach focused on at least forty per cent external cost savings over road-only alternatives would be more effective than the current mode or distance criteria.

The study found that intermodal terminals are unevenly distributed, with Germany accounting for around a quarter to one third of all EU facilities. Rail access is available at close to ninety per cent of terminals, but barge, Rolling Highway and short sea options remain limited. Connectivity analysis identified Busto Arsizio, Gallarate, Madrid, Abroñigal and Praha Uhříněves among the most connected inland hubs, with six of the ten best served terminals located in Central Europe. Spain’s non-standard gauge and insular network were highlighted as constraining factors.

Distance modelling showed that both road and rail routes are substantially longer than straight line distances, with average rail paths slightly longer than road and a higher median overhead for rail of 36.7 per cent compared with 24.5 per cent for road. The report said these detours reflect infrastructure constraints and routing inefficiencies that erode rail’s competitiveness, particularly on short and medium haul flows where road retains cost and flexibility advantages.

The analysis confirmed that rail freight’s market share has stagnated at around seventeen per cent, well below EU 2030 targets, while inland waterways continue to lose ground. Capacity limits at terminals, short tracks, port congestion, lower service reliability and high transhipment costs were identified as key barriers to modal shift. Data gaps and an outdated legal framework under the Combined Transport Directive further undermine policy design.

The authors recommended clarifying and modernising the Directive by anchoring eligibility to measurable external cost savings, combined with a public EU register of terminals. They proposed EU funding to expand and electrify cross-border infrastructure, develop urban proximate terminals, and modernise handling equipment and ICT systems. Additional measures would include minimum transparency standards for terminal services, more frequent trains and around-the-clock access, a more unified contracting framework and financial incentives to offset transfer costs, supported by road pricing to strengthen rail’s relative position.

The study also called for stronger national frameworks, with Member States required to set combined transport targets and report harmonised data, and for the Directive to provide greater operational flexibility, including exemptions from driving bans for short road legs where justified by safety and environmental standards.

Ombudswoman finds maladministration in Commission’s handling of sustainability Omnibus and other urgent proposals.

The European Ombudswoman found that the Commission committed maladministration in the preparation of several urgent legislative proposals, including the corporate sustainability due diligence Omnibus I package, revisions to the Common Agricultural Policy and a proposed framework to counter migrant smuggling. Teresa Anjinho said the Commission failed to follow key elements of its own Better Regulation rules, which are intended to ensure evidence-based, transparent and inclusive law-making.

Three complaint-based inquiries identified systemic shortcomings, including inadequate justification of urgency, poor documentation of deviations from Better Regulation procedures and reduced internal consultation. In the case of the sustainability Omnibus, consultation between Commission departments was limited to less than twenty-four hours over a weekend. Evidence supporting the migrant smuggling proposal was published late, while analytical material for the CAP file appeared after the legislation had been approved. The Ombudswoman also identified an absence of clear internal records demonstrating that climate consistency assessments had been carried out for the CAP and Omnibus proposals.

The inquiry found that the Commission had stated that climate consistency assessments had been performed, but could not provide documents showing they had been completed before the relevant proposals were adopted. This raised concerns about compliance with Article 6(4) of the European Climate Law, which requires the Commission to conduct and publish such assessments for any draft measure or legislative proposal, irrespective of whether a full impact assessment accompanies the initiative.

The Ombudswoman said the Commission must strike a better balance between procedural agility and minimum good administration standards when acting under urgency. She urged the Commission to clarify in its forthcoming revision of the Better Regulation rules that climate consistency assessments should be conducted for all legislative proposals and clearly published when initiatives are adopted. She also called for predictable, non-arbitrary application of Better Regulation requirements, including minimum standards for stakeholder consultation during accelerated procedures.

The European Climate Law requires EU institutions to ensure that all legislative proposals are consistent with the binding objective of net zero greenhouse gas emissions by 2050. The Ombudswoman said the lack of clear evidence that climate assessments had been conducted undermined transparency and accountability, noting that the Commission had previously committed to applying its own Better Regulation framework even where it is not legally binding.

European mayors urge Commission to uphold 2035 CO₂ phase out for cars and vans.

Twenty-four mayors from major European cities called on the European Commission to maintain the 2035 phase-out of CO₂-emitting cars and vans, warning that any attempt to weaken the standards would undermine climate policy, reduce investment certainty and jeopardise public health. Their intervention follows the Commission’s decision to advance the review of the EU framework on CO₂ emissions for road vehicles.

The signatories, representing cities across the Eurocities, C40, ICLEI Europe and POLIS networks, said the 2035 target is essential for compliance with the EU Ambient Air Quality Directive at a time when ninety per cent of urban residents remain exposed to harmful pollution. They cited evidence from local measures, including a sixty per cent drop in black carbon in Brussels following its low-emission zone and lower asthma medication prescriptions for young children in German cities with similar schemes.

The letter argued that cities have already demonstrated that phasing out polluting vehicles delivers tangible economic benefits, including job creation and strengthened local economies. Citing research that transport decarbonisation could generate ninety thousand green jobs in Italy alone, the mayors warned that political hesitation at the EU level risks destabilising investment and weakening Europe’s position in the global zero emission mobility market.

The group said that maintaining the 2035 timeline is also critical for climate diplomacy and energy security. Any softening of the target would send negative signals to international partners, reduce Europe’s credibility and increase reliance on fossil fuel imports from countries not aligned with EU interests.

Several mayors warned that reopening the door to synthetic fuels would undermine air quality improvements because such fuels have been found to produce toxic emissions comparable to petrol and diesel. They argued that policy clarity is needed to support continued electrification of public fleets, expansion of charging networks and the development of zero emission zones.

The signatories said cities are prepared to accelerate the transition but require predictability at the EU level. Weakening the 2035 commitment would undercut local initiatives, disrupt market signals and discourage consumers from switching to electric vehicles. They urged the Commission to preserve the phase-out in order to deliver a healthier, fairer and more competitive Europe.

Ten Member States call for delayed and more flexible HDV charging targets ahead of AFIR revision.

A group of ten Member States urged the European Commission to extend implementation deadlines for heavy-duty vehicle charging infrastructure and ease the requirements set under the Alternative Fuels Infrastructure Regulation, arguing that current 2030 targets are unrealistic under prevailing economic and geopolitical conditions. The joint declaration, to be presented at the Transport, Telecommunications and Energy Council on 4 December, was signed by Bulgaria, Czechia, Estonia, Finland, Hungary, Italy, Latvia, Poland, Romania and Slovakia.

The signatories said the AFIR framework was adopted in a markedly different context and that recent crises, including the pandemic and Russia’s war against Ukraine, had weakened investment capacity in the road transport sector. They warned that low demand for zero-emission trucks, high vehicle costs and strained national budgets limit the feasibility of meeting the mandated charging densities along the TEN-T network. Private operators reportedly prefer depot-based charging to public charging pools, reducing the business case for large-scale public infrastructure deployment.

The declaration said declining cargo volumes and inflationary pressures have hindered fleet renewal and made uptake of electric heavy-duty vehicles a low priority for operators focused on commercial survival. Grid connection challenges were identified as a critical barrier, with several planned charging pools cancelled due to high costs or insufficient capacity. Member States with low population density said strict distance requirements of sixty kilometres on core networks and one hundred kilometres on comprehensive networks are difficult to achieve, given the location of existing grid assets.

The ministers cautioned that demand for heavy-duty charging could also decline over the next decade due to the completion of major rail projects and expected improvements in truck range, reducing the frequency of charging stops. They noted that CO₂ standards for new heavy-duty vehicles require a ninety per cent reduction by 2040 relative to 2019 levels, implying that early large-scale infrastructure may be underused until market uptake accelerates.

Ahead of the 2026 AFIR revision, the group called for at least one of three adjustments: a five-year extension of implementation deadlines, easing of charging network requirements, or targeted flexibilities and derogations. Suggested options include allowing greater distance from the TEN T network where justified by technical constraints, adapting spacing requirements to reflect grid availability, lowering minimum power thresholds for charging pools, enabling dual use by light-duty vehicles and easing obligations on roads with lower traffic volumes.

The declaration warned that without adjustments, Member States risk costly investments in infrastructure that may not be sufficiently utilised and face public scrutiny at a time when defence spending is absorbing a growing share of national budgets.

UK Budget introduces mileage-based charge for electric vehicles from 2028, prompting industry warnings over transition risks.

The UK government will introduce a mileage-based charge on battery electric and plug-in hybrid vehicles from April 2028 as part of its Autumn Budget, alongside a short-term freeze in fuel duty. The charge will be set at three pence per mile for battery electric cars and one and a half pence for plug-in hybrids in 2028 to 2029, with annual CPI indexation. According to the Office for Budget Responsibility, the measure is expected to raise £1.1 billion in its first year, rising to £1.9 billion by 2030 to 2031.

The OBR’s leaked assessment said the new tax would reduce demand for electric vehicles by increasing lifetime ownership costs and estimated around four hundred and forty thousand fewer EV sales across the forecast period compared with the pre-Budget baseline. Manufacturers subject to the zero-emission vehicle mandate may need to respond by lowering EV prices or reducing sales of non-electric models. The OBR also expects a small reduction in average electric vehicle mileage as a behavioural response, lowering the projected revenue by around two hundred million pounds by 2030 to 2031.

The Budget included compensatory measures intended to offset some of the impacts on uptake, including an increase in the Expensive Car Supplement threshold for battery electric vehicles from £40,000 to £50,000 from April 2026 and an expansion of the electric car grant through to 2029 to 2030. The Expensive Car Supplement is an additional Vehicle Excise Duty charge applied to higher value vehicles. The OBR estimated that these incentives would recover around one hundred and thirty thousand of the EV sales lost as a result of the new charge.

Industry reactions highlighted the risk that the measure could slow the transition. The RAC said the government would be aware that taxing plug-in vehicles per mile from 2028 could dampen demand, which it argued explains the expansion of the grant. Jon Lawes of Novuna Vehicle Solutions said the charge amounted to a form of Vehicle Excise Duty plus and warned that inconsistent policy signals risked undermining confidence. He added that persistent barriers, including high upfront costs, limited charging access and higher prices for drivers without home charging, must be addressed if zero-emission vehicle mandate targets are to be met.

The Chartered Institute of Logistics and Transport welcomed the move to modernise the framework for transport taxation but warned that the three pence per mile levy is not sufficient without a coherent long-term strategy for funding roads, rail and wider mobility. CILT said declining fuel duty revenues require an integrated national plan that is fair, future-proof, and aligned with decarbonisation objectives. It stressed the need for clarity for freight operators and called for safeguards to ensure rural communities are not disproportionately affected.

Commenting on the Budget, the RAC also noted that the government had not reduced VAT on public charging from twenty per cent to five per cent to match domestic electricity, leaving drivers without home charging at a disadvantage.

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