Moving towards a lifecycle approach
The current CO₂ emission standards for new vehicles do not consider renewable fuels. The EU legal framework for reducing CO₂ emissions in road transport splits the responsibility along the supply chain.
Compare the lifecycle emissions
of cars and vans
A Carbon Correction Factor (CCF) to account for CO2 savings provided by renewable fuels
- The current Tank-to-Wheel (TtW) approach fails to distinguish between the renewable and fossil origin of the fuels and represents an outdated way of comparing different vehicle technologies.
- A CCF would take into consideration the share of renewable fuel in the fuel mix for different fuel types in a reference year. Such an option would reduce the CO2 emission targets for cars and vans manufacturers by the amount of renewable fuels already included in the current fuel mix.
- This would take into account that, in addition to technological and efficiency improvements by manufacturers, the fuel mix is decisive for how much CO2 a car or van emits.
A new vehicle category for the exclusive use of CO2 -neutral fuels
- In the latest revision of the EU CO₂ Emission Standards, legislators introduced a key provision on the future role of CO₂-neutral fuels (CNF). Recital 11 of Regulation (EU) 2023/851 establishes the basis for an agreement that, following consultation with stakeholders, the European Commission will put forward a proposal to allow the registration of vehicles running exclusively on CO₂-neutral fuels after 2035.
- In response to the European Commission’s request for industry-led solutions to track and verify CO₂-neutral fuels in road transport, the Working Group on Monitoring Methodologies (WGMM), a coalition of 55 industry players, presented 11 solutions within their report.
- The WGMM proposes to introduce a definition of CNF in line with the Renewable Energy Directive ((EU) 2023/2413) - including all sustainable fuels. Monitoring methodologies should not be limited to a physical supply. Digital and other solutions should not be excluded. For instance, Switzerland just introduced a Crediting System based on mass balancing (more information about such systems here). In addition, a pragmatic inducement system should be introduced to increase consumers acceptance.

Why include renewable fuels
in the new CO2 emission standards for cars and vans
Enabling climate friendly individual mobility.

What needs to be done now
Including CO2 neutral fuels in the CO2 emission standards can provide a greater choice of climate neutral and socially just mobility options that doesn’t overburden the European citizens and businesses, keeps the supply chain intact and leads to a more comprehensive climate policy along the lifecycle of vehicles.
Road Transport
Road transport is one of the biggest CO2 emitters in the EU, accounting for one fifth of CO2 emissions. Passenger cars and vans make up for almost 61 % of all road transport emissions. CO2 emission standards play a significant role in meeting the 2040 climate targets and climate neutrality by 2050. The enormous potential of climate protection solutions, such as biofuels as well as hydrogen and its derivative products, which include eFuels, can strengthen defossilisation efforts in Europe.
Fuel Sector
The Fuel Industry is regulated by Renewable Energy Directive ((EU) 2023/2413) and European Emission Trading System 2 ((EU) 2023/959). Both regulations guarantee carving out fossil fuels in line with EU climate targets – already 29% of consumed energy in the transport sector as to come from renewable sources in 2030. These ambitions should be taken into account in the CO2 emission standards for new vehicles. Currently, the share of renewable energy is about 10.8% (2023).
More choices
fewer emissions
The current regulation on CO₂ emission standards for cars and vans does not take CO2 neutral fuels into account. Currently, only the electric drivetrain and hydrogen fuel cells are considered a climate-friendly option – customers have no choice since other available technologies are de-facto excluded.
The EU’s electricity mix is still dependent on fossil fuels, which contradicts the goal of reducing emissions in the transport sector. A combustion engine powered by renewable, sustainable fuels is as climate-friendly as an electric vehicle powered by green electricity. Legistors already agreed in the last revision to include CO2 neutral fuels – so far nothing has happened. A change of the European Energy Taxation (2003/96/EC) as proposed by the EU-Comission would increase the affordability of CNF solutions.
Technology Openness
Especially in light of the EU climate goals of reaching climate neutrality by 2050, a wide range of technologies should be allowed to contribute to emission reduction. A consideration of renewable fuels in the CO2 emission standards would be a first step to a more holistic and socially acceptable climate approach in transport. This can be reached by implementing a Carbon Correction Factor and a new vehicle category for the exclusive use of CO2 neutral fuels, which can also be combined.

Debunking: Why the negative impacts of
including CO2 neutral Fuels are negligible
The negative effects identified often mentioned by different stakeholders are the following:
Broad support for renewable fuels from industry, science and society:

Supporters
Further information
and relevant studies
Glossary
- BEV
- Battery Electric Vehicle
- CCF
- Carbon Correction Factor
- CNF
- CO2 Neutral Fuel
- COM
- EU-Commission
- ETS
- European Emission Trading System
- GHG
- Greenhouse Gas
- ICE
- Internal Combustion Engine
- RED
- Renewable Energy Directive
- TTW
- Tank to Wheel
- WGMM
- Working Group on Monitoring Methodologies
- WLTP
- Worldwide Harmonized Light Vehicles Test Procedure
- WTT
- Well to Tank
- WTW
- Well to Wheel




















