Inside The Commission’s Car CO2 Proposal: What Changes in Law, and What Does Not

Inside The Commission’s Car CO2 Proposal: What Changes in Law, and What Does Not

The Commission’s proposal to amend Regulation (EU) 2019/631 does not undo the EU’s post-2030 climate framework for road transport. It rewrites its legal expression. What changes is not the existence of a 2035 endpoint, but the way that endpoint is framed in primary law and the range of compliance tools made available to manufacturers.

As drafted, COM(2025)995 amends Article 1 and Annexe I of the Regulation to replace the current requirement for a 100 per cent reduction in average fleet-wide CO₂ emissions from new passenger cars and light commercial vehicles from 2035 with a 90 per cent reduction relative to the 2021 baseline. Tailpipe CO₂ emissions remain the sole legal metric. The Regulation would no longer require average emissions to reach zero, but it would still require manufacturers to account for any remaining emissions within a tightly defined compliance framework.

The proposal also adjusts the 2030 target for light commercial vehicles, lowering the required reduction from 50 per cent to 40 per cent compared with the 2021 baseline. This change applies only to vans and leaves the passenger car trajectory unchanged. In legal terms, cars and vans continue to be governed by the same Regulation, but the targets diverge where the Commission considers feasibility constraints to be structurally different.

Beyond numerical targets, the proposal introduces new compliance instruments directly into legislation. From 2035, manufacturers would be permitted to compensate a limited share of residual tailpipe emissions through two mechanisms: credits linked to greenhouse-gas savings from certain sustainable renewable fuels, and credits linked to the use of low-carbon steel produced in the EU. The Regulation itself sets binding caps. Fuel-related credits may not reduce a manufacturer’s average emissions by more than 3 per cent of the 2021 fleet-wide target, low-carbon steel credits by more than 7 per cent, with a combined ceiling of 10 per cent. Any emissions above that threshold would have to be eliminated at the vehicle level.

In the second episode of “Policy Driven,” co-hosts Mark and Tom are joined by Julia Poliscanova, Senior Director for Vehicles & Emobility Supply Chains at the Green NGO Transport & Environment in Brussels. The conversation explores Julia’s journey in transport and mobility, her academic and professional experiences in the UK, and the role Western markets like the UK and Canada play in influencing global transport decarbonisation policy.

The episode delves into the EU’s Strategic Dialogue on the Automotive Sector and the subsequent Action Plan, highlighting how current EU legislation has fallen short in incentivising gradual decarbonisation. Julia explores the pressures facing the automotive sector and emphasises the need for a comprehensive and robust approach to decarbonisation by securing and supporting the EV supply chain.

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