CO2 emission performance standards for new light duty vehicles and vehicle labelling

Polish Automotive Industry Association (PZPM) - a member of ACEA - endorses the ACEA input to the public consultation as attached. According to current market estimates, the 2030 target is unachievable and penalties could range between 20 and 25 billion euros for the EU car industry. Giving Poland as an example, even with subsidies in place the current share of registrations of new zeroemission cars is around 6%.

Revision of the CO2 emission standards for cars and vans Stellantis submission to the European Commission’s public consultation Introduction and context Stellantis appreciates the opportunity to add its voice to this important consultation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Towards a coherent, fair and technologically neutral European framework 1. A European framework to consolidate CSIAM fully supports the climate objectives set by the European Union and considers Regulation (EU) 2019/631 as a key instrument for achieving carbon neutrality by 2050.

Filed in French · English published by the European Commission

CZ Biom Czech Biomass Association (non-governmental organisation) welcomes the open discussion on the EU rules on CO emission performance standards for new cars and vans and calls on the European Commission to take the following aspects into account during the review process: The current rules have effectively led to the phase-out of CNG-powered vehicle production.

Shell welcomes the opportunity to respond to the Call for Evidence on the revision of the CO2 emission performance standards for cars and vans. Decarbonisation of road transport is a key pillar in the EUs climate targets.

The Automotive Industry Association of the Slovak Republic (ZAP SR) fully supports the European Unions climate neutrality objectives. However, the current CO regulation pathway, including the 100% reduction target by 2035, is no longer realistic under current market, industrial and infrastructure conditions.

The European Conference of Transport Research Institutes (ECTRI) welcomes the opportunity to contribute to the review of the CO2 emission standards for cars and vans. This piece of legislation is a cornerstone for decarbonising road transport in line with the Green Deal and the Sustainable and Smart Mobility Strategy.

The automotive industry and its suppliers are of strategic importance for Germany and Europe as industrial locations. The industry, which includes many small and medium-sized enterprises and family businesses, faces enormous challenges due to the dual transformation toward climate neutrality and digitalization, geopolitical risks, challenging business conditions and fierce international competition.

Please find attached our position paper. The European automotive industry, more committed than ever to the 2050 climate neutrality goal set by the Paris Agreement, positions itself as a solutions-driven sector in the face of the climate challenge.

For NABU as the biggest German eNGO, the EUs CO2-emission standards are a central pillar of the climate and industrial policy for the automotive sector. Its trajectory has created planning-security for the automotive industry and the emobility value chain to make the necessary investments and plan the transition. The regulation includes timely review dates to adapt the instrument if needed.

To ensure a fair and inclusive transition to zero-emission mobility, this transformation must benefit all Europeans, leaving no workers, regions or consumers behind. In order to maintain social acceptance, measures must support employment, affordability, and regional cohesion. Dedicated social funds and retraining programmes are essential to help automotive workers adapt to new technologies and value chains.

We believe that a technology-neutral approach is essential to achieve reductions in transport emissions. Drawing on experience with biofuels, we see value in combining different low-carbon pathways - such as electrification, sustainable biofuels, hybrids, and flex-fuel technologies - supported by consistent life-cycle assessments that capture their full environmental impact.

To achieve de-carbonization of the European mobility sector, Automotive Mobility Europe recommends: Broaden the methodology maintaining technology neutrality: Introduce a Carbon Correction Factor (CCF) to recognise renewable and climate-neutral energy carriers alongside BEVs, moving from a purely tailpipe-based approach to a system-based perspective.

The CO2 emission standard regulation has not been successfull in delivering progress towards the objectives. It has, on the contrary, caused major uncertainty for the end customers and limited their choices for cutting climate impact of transportation. From the Finnish point of view, CO2 standard development has led to discrediting of ICE in the near future.

UNRAE welcomes the launch of the revision of Regulation (EU) 2019/631 as a key step towards making the transition to zero-emission mobility more sustainable, effective and industrially competitive. The association confirms its full support for Europe’s decarbonisation objectives and climate neutrality by 2050, recognising that the ecological transition is now underway and should be governed with pragmatism…

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ZVEI, the German Electro and Digital Industry Association, emphasizes that maintaining a stable and predictable regulatory framework is essential to safeguard investments and drive Europes transition to zero-emission mobility.

The EUs CO2 regulation remains one of the most ambitious climate initiatives worldwide, designed to accelerate the transition toward zero-emission mobility by 2035. It has triggered unprecedented investments into electrification, infrastructure and new technologies. Yet, five years into implementation, a significant gap has emerged between regulatory expectations and market developments.

With reference to the attached position paper, the VDMA takes a position on the discussion on the CO2 fleet limits for cars and light commercial vehicles and calls in particular for: 1. A timely discussion and presentation of a Commission proposal The ramp-up of electro-mobility in the EU lags behind political and industrial expectations.

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Eni welcomes the opportunity to provide feedback on the forthcoming revision of the Regulation on CO2 standards for light-duty vehicles (LDV). We support the Commissions initiative to evaluate the effectiveness of the current framework and to adapt it in response to evolving market conditions and technological advancements.

Johnson Matthey stands ready to support the EU in delivering a resilient, inclusive, and competitive transition to zero-emission mobility. Embracing a broad mix of technologies is essential to meet climate targets and safeguard Europe's industrial leadership and social equity.

You can find our position paper attached. The EDF Group firmly supports the electrification of road transport and the current 2035 target prohibiting the sale of new combustion engine vehicles. Indeed, the 2035 ban for new internal combustion engines is the only way to achieve the zero-emission target by 2050.

CLTM/BR10105/CWH Brussels, 10 October 2025 IRU CONTRIBUTION TO THE EC CALL FOR EVIDENCE ON CO2 STANDARDS FOR LIGHT-DUTY VEHICLES ... IRU contribution to the EC Call for Evidence on the revision of the CO2 standards for light-duty vehicles The International Road Transport Union (IRU), representing over 3.5 million mobility and logistics road transport operators worldwide, including 1 million in the EU, the majority…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CFDT input (main French Trade Union) The EUs car and van CO2 regulation is Europe's cornerstone climate and industrial policy for the automotive sector. It has set a clear and credible trajectory for the automotive industry and the emobility value chain to make the necessary investments and plan the transition.

To achieve de-carbonization of the European mobility sector, Mobilians recommends: Broaden the methodology maintaining technology neutrality: Introduce a Carbon Correction Factor (CCF) to recognise renewable and climate-neutral energy carriers alongside BEVs, moving from a purely tailpipe-based approach to a system-based perspective.

Maranello, 10.10.2025 Ferrari input to public consultation on the revision of the CO2 emission standards for cars and vans CONTEXT Ferrari appreciates the opportunity to contribute to the public consultation on CO2 Regulation review, aimed to achieve automotive industry’s 0 gCO2/km target by 2035 and to meet EU Commission decarbonization ambition of achieving net zero by 2050.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European steel industry supports maintaining the ambition of CO2 emission targets, however, in line with other stakeholders in the automotive sector (e.g. ACEA and CLEPA), there needs to be flexibilities for OEMs in meeting the targets. This can be achieved in a collaborative way that benefits the whole supply chain.

To achieve de-carbonization of the European mobility sector, Automotive Mobility Europe recommends: Broaden the methodology maintaining technology neutrality: Introduce a Carbon Correction Factor (CCF) to recognise renewable and climate-neutral energy carriers alongside BEVs, moving from a purely tailpipe-based approach to a system-based perspective.

The Network for Sustainable Mobility, of which the eFuel Alliance is part of, envisions a climate-neutral transport system that leverages all breakthrough technologies to fast-track the reduction of emissions in an affordable and competitive manner, encourages investments in decarbonisation solutions, and promotes a truly technology-neutral policy framework where both vehicle and fuel innovations are advanced as…

The Revision of the CO2 standards for LDVs Regulation represents a strategic lever to accelerate the decarbonisation of Europes automotive ecosystem while at the same time balancing the competitiveness of the European Automotive sector and its suppliers. European Aluminium believes that technology neutrality should be a guiding principle in the upcoming revision.

Deutsche Umwelthilfe (DUH) strongly opposes any dilution or flexibilization of the EUs CO fleet regulation. These standards are essential to drive decarbonization in transport, and they must remain binding, rigorous, and free from loopholes. 1. Keep binding CO targets & trajectory: The 2030 and 2035 CO fleet targets must be maintained or strengthened.

Europe must hold firm on the 2035 CO standards for cars and vans. Weakening or delaying these rules would derail investment, undermine competitiveness, and damage climate credibility. Europes e-mobility ecosystem is already delivering: EV sales are growing, costs are falling, and Europe is building a strong industrial base.

BEUC strongly support the current targets set in Regulation (EU) 2019/631. Electric cars are to be the go-to choice for consumers looking to cut their mobility costs. For some, it is already the case today. Most importantly, financial benefits of EVs are the most pronounced in the second-hand market, where the vast majority of consumers buy their car.

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, welcomes the Commissions call for evidence and public consultation on the future revision of the Regulation on CO2 standards for light-duty vehicles.

By de facto focusing only on pure electrification, the Regulation has forced the EU industry to compete in sectors where it does not enjoy a comparative advantage. This has led to inefficient decarbonisation and unintended deindustrialization in the EU auto sector.

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents thirty members who collect, prepare and convert suitable waste lipids, mainly used cooking oils and waste fatty acids, into waste-based and advanced biodiesel or trade the feedstocks and finished products. Our members are based in Germany, Austria and the Netherlands. Please find our feedback attached.

The Grand Est region is characterised by the size of its automotive sector, the 1st industrial branch, which accounts for 117 000 jobs in 2300 establishments. The Grand Est accounts for a quarter of French automotive activity in terms of production and export volume.

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The Swedish Gas Association welcomes the Commissions efforts to decarbonize the transport sector. To ensure the success of this transition, The Swedish Gas Association stresses the need to implement a revision of the CO2 emission standards for cars and vans regulation that seeks a truly technology-neutral approach.

Berlin, October 10th 2025 German Chamber of Commerce and Industry (DIHK) Statement on the revision of the CO2 emission standards for cars and vans We would like to thank the European Commission for the opportunity to comment on its initiative concerning the revision of the CO₂ emission standards for cars and vans.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Why BEVs outperform PHEVs and Range-Extended EVs for light transport decarbonization by 2035 in Europe September 2025 CHARGEFRANCE 0 Contents 1. The EV transition, initiated by regulation and essential to decarbonization, is now in motion across Europe 11 a. Transport sector needs to be at 0% emissions to enable Europe to reach decarbonization objectives 11 b.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European automotive sector is going through a hotspot, marked by rapid technological developments, trade restrictions and growing global competition, in a context very different from that of the current CO reduction targets.

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Horse Powertrain Revision CO2 Emissions Standards Regulation Consultation Feedback Summary Electrification will play a major role in reducing emissions from the EU road transport sector. However, we urge the EU to ensure this pathway is complemented, not replaced, by other innovative low-carbon technologies and powertrain solutions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

At CRECEMOS, the association representing the renewable fuels value chain, the circular economy in Spain, and sustainable mobility, we warmly welcome the launch of this dual European consultation on an issue that is crucial for the future of the European automotive industry and, at the same time, for the decarbonization of transport.

BDEW Federal Association of Energy and Water Management e. V. [address removed] www.bdew.de Berlin, 10 October 2025 Statement Revision of the EU Regulation setting CO2 emission standards for new cars and vans Version number: 1.0 The German Association of Energy and Water Industries (BDEW) and its regional organisations represent over 2,000 companies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EU Affairs l October 2025 Moeve’s contribution to the revision of the Regulation on CO2 emissions standards for Light Duty Vehicles Moeve’s Commitment to Comprehensive Transport Decarbonisation Moeve is a leading Spanish energy company, actively investing in renewable hydrogen, second-generation biofuels, biomethane, ultra-fast electric charging.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UFE considers the decarbonisation of the EUs vehicle fleet as a major issue in achieving carbon neutrality by 2050. The electrification of LDVs is the cornerstone of this transition to sustainable mobility. Ahead of the review of the CO2 standards regulation for cars and vans, UFE would like to reaffirm its support to the regulation and the 2035 zero-emission target: 1.

Climate Group EV100 welcomes the opportunity to contribute to the European Commissions consultation on the review of the CO standards for new cars and vans. We represent major businesses committed to achieving the EUs climate neutrality goal by 2050, and the 55% GHG reduction target by 2030.

In UNITI’s view, it is crucial that European regulation translates into the recognition that it is not the type of propulsion itself that determines the carbon footprint of a vehicle, but above all the real fossil carbon footprint of the propulsion energy used, such as electricity, hydrogen or fuels.

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The WGMM (formerly known as Stuttgart Group) was formally founded in 2024 out of the necessity to substantiate the commitment by the European Commission in Recital 11 of the Reg. on CO standards for LDV, which was agreed by the co-legislators.

The CO2 fleet limit legislation has been a success, as it has helped to limit CO2 emissions from passenger car traffic and promote the ramp-up of e-mobility. However, this journey is not yet over, and it is imperative that we adhere to the existing CO2 limits.

The forthcoming revision of the Regulation on CO emission standards for new cars and vans provides an opportunity to create lead markets for low-emission steel produced in the EU, which supports the call for a more flexible policy approach to decarbonising road transport. While electrification will be the dominant path to zero-emission mobility, reducing the CO2 footprint of the production phase is the next step.

The Czech Republic remains fully committed to the EUs climate objectives and to the decarbonisation of road transport. At the same time, we consider it essential that the forthcoming revision of the CO2 standards for cars and vans ensures a realistic, socially fair, and economically viable transition that maintains Europes industrial competitiveness and technological leadership.

EGs Feedback on the Revision of CO₂ Emission Performance Standards for Cars and Vans While Envien Group fully supports the EU’s climate neutrality goals, it is essential that the transition to low-emission mobility remains technologically neutral, economically feasible and socially fair.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EU CO2 standards for cars and vans have been successful in reducing transport related CO2 emissions by driving the development of vehicle technologies that improve efficiency. This not only reduced the adverse climate impact of cars and vans but also created and secured a large number of jobs in the automotive industry.

Stand Firm: Maintain the 2035 Zero-Emission Target Without Exceptions Lucid Group, Inc. (“Lucid”) welcomes the opportunity to submit this response to the Commission’s Call for Evidence on CO2 emission standards for cars and vans.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This initiative represents a key opportunity to accelerate the decarbonisation of the transport sector while reinforcing Europes industrial competitiveness, resilience, and technological leadership. In this context, CELSA would like to make the following observations for the Commissions assessment: It is essential that the revised framework takes into account the full life-cycle CO emissions of vehicles, including…

Fleet Cards Europe is the EU business association representing the leading independent fleet card providers operating across Europe. Our members play a vital role in the logistics, transport, and mobility sectors, serving thousands of companies every day. Fleet card providers are an essential pillar of the CRT ecosystem.

The European Commissions review of Regulation (EU) 2019/631 must recalibrate the path towards climate-neutral mobility. Market reality shows that the 2030 and 2035 targets are not achievable under todays conditions. It is therefore imperative to revise these targets and introduce flexibilities, ensuring that the transition remains credible, affordable and safeguards industrial competitiveness.

The Nordic Logistics Association (NLA) representing Danish Transport and Logistics (DTL), the Norwegian Road Transport Association (NLF), the Swedish Association of Road Transport Companies (SÅ) and our associated member SKAL, the Finnish Transport and Logistics Association are pleased to submit the attached feedback to the call for evidence on the CO2 emission standards for LDV's.

UPEI, the Voice of Europes independent energy and mobility suppliers, focuses its contribution on: - flexibility, simplification and reduction of administrative burden: we recommend the EU to systematically improve consistency of all relevant legislation, in particular definitions and methodologies) and to keep a scientifically based approach.

Please refer to the enclosed contribution of the Bavarian State Ministry for Economic Affairs, Regional Development and Energy to the consultation on the revision of the CO2 emission standards for new passenger cars and for new light commercial vehicles.

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The Institut Mobilités en Transition (IMT-Iddri) contributes to the European debate on the evolution of CO2 emission performance standards for new passenger cars and vans. 1. PHEV/EREV: More Emissions and Higher Total Costs of Ownership (TCOs) than BEVs An independent study by IMT on battery electric vehicles (BEV), plug-in hybrid vehicles (PHEV) and extended-range electric vehicles (EREV) for the 20352040 horizon…

Current vehicle CO2 emission standards are based solely on tailpipe targets, whereas total life-cycle emissions are the real issue to tackle. Road transport decarbonisation policy must be grounded in current life-cycle data and robust scientific evidence, not outdated assumptions that favour electromobility over other viable solutions. Electromobility will be a key enabler for road transport decarbonisation.

Reaching the 2035 target of climate neutrality for cars, meaning 100% of new vehicles sold are zero-emission, is not only possible and necessary, but also an opportunity to transform our mobility system in a positive and socially beneficial way. We need to stay on course and maintain a clear and consistent goal.

The Japan Automobile Manufacturers Association, Inc. (JAMA) is a non-profit industry organisation comprising Japans fourteen manufacturers of passenger cars, light commercial vehicles, trucks, buses, and motorcycles. Attachment is our response on CO2 emission standards for cars and vans.

The European Regulation on CO2 Emissions for Passenger Cars and Light Commercial Vehicles constitutes the main pillar of the European Unions climate and industrial policies in the automotive sector. It has historically provided a clear and credible trajectory, enabling the industry and the entire electric mobility value chain to plan investments and organize an orderly transition towards zero-emission vehicles.

EWABA represents over 60 stakeholders across the waste-based and advanced biodiesel value chain, collecting and processing sustainable feedstocks such as used cooking oil (UCO), animal fats, and other residues listed in Parts A and B of Annex IX of the Renewable Energy Directive (RED).

The last legislature highlighted the limits of an overly rigid approach to the ecological transition, which favoured leletric as the only solution, neglecting the fundamental principle of technological neutrality. This orientation has created uncertainty in the market, slowed down investment and put pressure on the entire European automotive chain, with significant employment and industrial impacts.

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Tereos is a French agricultural cooperative that produces ethanol (1G and advanced) in an integrated way into priority food production (sugar and starches – human and animal). The bioethanol outlet is important for the competitiveness of the tools, the income of our 10 300 co-operators and employment, particularly in rural areas. Like our major international competitors (e.g.

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Avere-France, the national association for the development of electric mobility in France, strongly supports the maintenance of the 2035 targets for a 100 % reduction in CO emissions for new light vehicles. These objectives are essential to ensure regulatory predictability, incentivise innovation, and secure the massive industrial investments already engaged in electrification by the whole ecosystem (charging…

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Comments from the Spanish Office for Climate Change to the Impact Assessment of the Revision of the CO2 emission standards for cars and vans: Comments Issue 1: Flexibility, simplification and reduction of administrative burden Regarding the use of potential revenues from excess emissions premiums (available from 2027 onwards), the OECC/Spain considers that these revenues should be specifically directed towards BEVs…

We call on the Commission to carry out a review that captures the full spectrum of technological and market realities. The upcoming revision should recognise the essential role of CO neutral fuels for the CO2 reduction targets of car manufacturers. The need for a more flexible and pragmatic EU approach to de-fossilising road transport has never been clearer.

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Verification of the environmental and market performance achieved by the various available or promising technologies must be carried out immediately, without waiting until the end of 2026 (2027 for make-up), to prevent the electrification of assembly lines from becoming irreversible at that time.

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Since 2012, the EU has set ambitious targets for CO2 emissions from new cars. They are constantly under attack. Nevertheless, all manufacturers have always complied with their respective CO2 targets, sometimes even over-achieved. And at a much lower cost than previously claimed. CO2 legislation is thus a success story and one of the key tools to decarbonise the transport sector.

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The U.S. Grains & BioProducts Council (USGBC; former U.S. Grains Council) thanks the European Commission for the opportunity to provide feedback on the important topic of the Revision of the CO2 emission standards for cars and vans. The USGBC feedback is included in a separate file provided with this response.

Modifications to CO2 emission standards for technology neutrality should be complemented with stricter Euro 7 standards: The CO2 standards for light-duty vehicles are the EUs main policy instrument to decarbonise road transport, whereas the Euro 7 standards are the EUs main policy instrument to reduce all other exhaust and non-exhaust criteria pollutant emissions, including particulate matter, nitrogen oxides, and…

Federmetano represents owners of compressed and liquefied natural gas/biomethane (CNG and LNG) fuelling stations in Italy, companies that transport and supply NG and biomethane via cylinder trucks and tank trucks for automotive, civil and industrial uses as well as for emergencies on NG pipelines, and NGV workshops specialized in the installation and maintenance of (bio)CNG systems on vehicles powered by NG.

Retrofit Mobility Europe brings together retrofit stakeholders in Europe whose activity aims to convert diesel or internal combustion engine vehicles to electric motors on an industrial scale. It should be noted that in some European Union countries, retrofitters carrying out series conversions have the legal status of manufacturers.

The Federal Association of the German Bioethanol Economy (BDBe) welcomes the European Commission’s initiative to revise the Regulation setting CO emission performance standards for new passenger cars and light commercial vehicles.

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The EUs car and van CO2 regulation is EU's cornerstone climate and industrial policy for the automotive sector. It has set a clear and credible trajectory for the automotive industry and the emobility value chain to make the necessary investments and plan the transition.

FinMobility, as the EU-level umbrella organisation representing the Finnish road transport and mobility sector through eight national member associations, endorses and fully aligns with the position submitted by the Network for Sustainable Mobility for this public consultation.

The EUs car and van CO2 regulation is Europe's cornerstone climate and industrial policy for the automotive sector. It has set a clear and credible trajectory for the automotive industry and the emobility value chain to make the necessary investments and plan the transition.

The location of the public consultation allows the Lombardy Region’s Department for Economic Development to reiterate with due vigour all our priorities that we have highlighted in recent years, including through various scientific publications, referring to the following main strategic issues for the protection of competitiveness and employment in Europe and directly linked to the CO2 mission: (1) urgently…

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Stellungnahme zur Bewertung der Verordnung zu Festsetzung von Co2-Emmissionsnormen für PKW und LNF 1 Der Zentralverband Deutsches Kraftfahrzeuggewerbe (ZDK) setzt sich für eine zukunftsorientierte Verkehrspolitik ein, die individuelle Straßenmobilität und nachhaltige Entwicklung miteinander verbindet.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

INEOS Automotive strongly believes that Europe should adopt a more customer-centric and realistic approach to decarbonisation with a comprehensive strategy to reduce emissions and improve efficiencies across all industry sectors in a more structured manner.

Gas Distributors for Sustainability (GD4S), representing major gas distribution operators from ten European countries, supports the EUs net-zero objective by advancing renewable gas collection and distribution across 929,500 km of networks serving over 60 million customers.

The future will reserve a number of tractions, each with its own elective mission, to the service of the final customer, who must be able to choose on the basis of the performance necessary for their own needs, compliance with environmental constraints and the TCO-Total Cost of Ownership calculated throughout the ecological life that can be identified by the Life Cycle Assessment (LCA) analysis.

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Network For Sustainable Mobility – Call for Evidence for an impact assessment for the Revision of the Regulation setting CO₂ emission standards for new cars and vans About the Network for Sustainable Mobility. The Network for Sustainable Mobility is a voluntary and informal gathering of stakeholders along the value chain representing the transport, engineering, fuel manufacturing and energy sectors supporting the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Konsultation zu CO2-Grenzwerten für PKW und leichte Nfz Sehr geehrte Damen und Herren, die Wirtschaftskammer Österreich nimmt zur gegenständlichen Konsultation wie folgt Stellung: 1. Allgemeines Die CO₂-Flottenziele der EU für 2030 und das geplante Verbot von Verbrennungsmotoren 2035 sind zentrale Säulen der Klimapolitik der EU. Doch seit der Festlegung dieser Ziele hat sich die Welt verändert.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Iberdrola welcomes the European Commissions initiative to revise Regulation (EU) 2019/631 and Directive 1999/94/EC. We believe this legislative effort presents a unique opportunity to accelerate the decarbonisation of road transport while enhancing its competitiveness, resilience, and technological leadership. We suggest the following considerations for the Commissions assessment: 1.

The European Biodiesel Board (EBB) underlines the strategic importance of the automotive sector, which contributes about EUR 1 trillion to EU GDP and sustains 13 million jobs. As the sector faces an industrial and environmental transformation driven by technological innovation and global competition, the review of Regulation (EU) 2019/631 on CO standards for LDVs represents a critical opportunity to align…

ePURE the European Renewable Ethanol Association represents bioethanol producers from crops, wastes and residues committed to sustainable transition towards zero-emission mobility. Our 20 producing members operate about 50 state-of-the-art biorefineries across the EU and the UK, transforming primary agricultural biomass into renewable ethanol, high-protein animal feed, food, and other valuable co-products including…

Moin, as a medium-sized enterprise providing services to the energy sector and general engineering services, has 25 years of experience in Germany and France. We know that this can only be expected for a transitional period. For a successful future, it is necessary to take the sometimes cumbersome course of action in the economy. Take new paths, develop new technologies.

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The European Biogas Association (EBA) welcomes the Commissions efforts to decarbonise the transport sector and echoes the critical role of the automotive industry in meeting the EUs climate targets. With the automotive industry being responsible for 29% of all CO emissions in 20221, and employing over 13.8 million people across the continent in 20252, this transformation must be fast and effective, but also just…

IASTEC welcomes the EU Commission´s offer to start consultations on revising the current CO2 vehicle fleet emissions legislation. An urgent need for a revision of the current legislation exists because of ecological and economic reasons.

The current call by DPG and DMG shows that climate action is extremely urgent, i.e. not delaying it (see Annex). Shifting the burner out would be a completely wrong signal here. It would also weaken the EU car industry in competition with other car-producing nations, in particular China.

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Contribution of the Automotive Regions Alliance on the revision of the CO emission performance standards for light-duty vehicles Regulation The Automotive Regions Alliance (ARA) is an initiative of the European Committee of the Regions that brings together 39 regions across Europe with a strong automotive footprint.

Page | 1 Ref. Ares(2025)8329674 - 02/10/2025 SUPPORTING THE EUROPEAN GRAPHITE INDUSTRY THROUGH COMPREHENSIVE LIFECYCLE ASSESSMENTS The European Advanced Carbon and Graphite Materials Association (ECGA) welcomes the Commission's review of CO₂ emission standards for light-duty vehicles. This revision represents an opportunity to strengthen European industrial competitiveness without compromising climate ambition.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EU rules on CO2 emissions from new cars and vans are useful to reduce CO2 emissions from road transport and achieve the EU’s ambitious climate targets. I do not agree with the European Commission’s first approach, which, by ordering the end of the production of endothermic motor vehicles since 2035, has led to a profound crisis in the entire European automotive sector and the many connected industries (steel and…

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UVE, the Portuguese Association of Electric Vehicle Users, welcomes the opportunity to provide feedback on the revision of Regulation (EU) 2019/631 setting CO emission performance standards for new passenger cars and light commercial vehicles. Our mission is to promote and accelerate the transition to battery electric vehicles (BEVs) in Portugal, and our contribution therefore focuses on land-based transport.

Given that the Community approach to the green transition shows in fact its limitations and the damage it is causing to the detriment of the major European automotive sector, we call for immediate verification of the environmental and market results achieved by the various available or promising technologies: the electrification of mounting lines should not become irreversible by the end of 2026 (or 2027 for…

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Attached feedback by the Finnish Central Organization for Motor Trades and Repairs (AKL) on the Revision of Regulation on CO emission standards for new passenger cars and light commercial vehicles. The regulation on carbon dioxide emission standards for light-duty vehicles sets requirements concerning carbon dioxide emissions for new passenger cars and light commercial vehicles (vans).

Good day, it is vital for the European economy to revise the emission targets and the stop to internal combustion cars initially set for 2035. It is clear to all that the targets need to be revised and de-carbonisation assumptions should be rethought by extending the time limits to 2045. The market, technology and costs that are emerging make these targets no longer achievable.

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FEDERAUTO POSITION PAPER “Veicoli leggeri Obiettivo di riesame delle emissioni di CO2” INTRODUZIONE FEDERAUTO (Federazione Italiana Concessionari Auto), facente parte di AECDR, si riconosce nella posizione proposta da AECDR nella consultazione in materia di emissioni di CO2 dei veicoli leggeri.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This feedback was jointly developed by the Network for Sustainable Mobility, a voluntary and informal gathering of stakeholders along the value chain representing the transport, engineering, fuel manufacturing and energy sectors supporting the role of sustainable renewable fuels in a climate-neutral road transport system. More information can be found in the attachment.

SEPTEMBER 2025 AECDR Position Paper Light-duty vehicles CO2 emissions review target 1 INTRODUCTION This position paper sets out the perspective of European car dealers on DG CLIMA's assessment of Regulation (EU) 2023/851 on CO2 emissions from light-duty vehicles, Article 1.13.a: "In 2026, the Commission shall review the effectiveness and impact of this Regulation, based on the biannual reports, and shall submit a…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In relation to the evaluation and revision process of Regulation (EU) 2019/631, Atlante wishes to provide the attached remarks, particularly regarding the emerging approach towards introducing technological flexibility in the definition of zero-emission vehicles.

Position Paper LDV target CO2 – NGV Italy Since 1996, NGV Italy has represented industrial excellence in sustainable transportation powered by natural gas (CNG and LNG) and, progressively, by biomethane, hydromethane, hydrogen and other innovative technological solutions (such as recycling to biofuels).

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome any initiative that supports sustainability while strengthening the international competitiveness of processes and products in and from the EU. Therefore, we would like to ask to take into account: Premise: Security of supply International competitiveness Somit: Technological neutrality across the EU, as far as possible worldwide, consistent implementation Efficient and effective demonstration of whole…

Filed in German · English published by the European Commission

Circle K (CK) welcome the opportunity to give our views on the Revision of the CO2 emission standards for cars and vans CK is a global fuel and convenience retailer present in 29 countries including 12 European. CK operates 17,000 stores of which approx. 4,800 sites in Europe. We have about 146,000 employees of which some 50.000 are in Europe.

The European Union must review the ban on registering cars with an endothermic engine from 2035, recognise liquid and gaseous biofuels, in particular biomethane, as sustainable low-carbon fuels and change the method of calculating emissions, which must be measured throughout the vehicle’s lifecycle and not only at tailpipe.

Filed in Italian · English published by the European Commission

S Group is a customer-owned Finnish network of companies in the retail and service sectors, with approximately 2,000 outlets in Finland and Estonia. S Group consists of 19 regional cooperatives and their central organization SOK owned by the co-operatives. S Group engages e.g.

ChargeUp Europe strongly supports the continuation of the Regulation setting CO2 standards for cars and vans and recommends maintaining the current level of ambition for 2030 and 2035 without introducing new elements into the framework which would weaken the market signal given by the 100% emissions reduction target in 2035.

The Fédération Internationale des Véhicules Anciens (FIVA) urges and recommends EU decisionmakers to take the valued contribution of historic vehicles (HVs) to cultural heritage into consideration. To keep historic vehicles on the road, as a living example of our motoring heritage that is shared with the public, and especially the younger generations, it is indispensable that fuel is available to keep vehicles…

The role of the European legislator is to set clear and binding targets to steer industrial policies towards carbon neutrality in 2050. For most businesses, climate is not the central goal: the European regulatory framework should provide a clear and stable trajectory. In this context, the date of 2035 for the end of the sale of new thermal vehicles is an indispensable milestone.

Filed in French · English published by the European Commission

Industrialists and Europeans need, above all, a clear, fixed line that does not change every year. Thus, the 2035 target concerning the ban on the sale of CO2 emitting vehicles must be respected. There should be no room for doubt as to whether this objective might be called into question.

Filed in French · English published by the European Commission

Lubrizol supports the EUs continued commitment to technological neutrality and policy coherence as outlined in the call. However, we believe that the current regulatory framework, centred exclusively on tailpipe emissions, risks creating unintended imbalances. A regulation that mandates 100% tailpipe CO reduction by 2035 does not account for the full climate impact of different technologies across their lifecycle.

EU rules on CO2 emission performance standards for new cars and vans are a key policy to reduce CO2 emissions from road transport and achieve the Union’s climate targets. This initiative will revise the current rules on the basis of a factual analysis, taking into account all relevant technological developments and the importance of an economically sustainable and socially fair transition towards zero-emission…

Filed in Italian · English published by the European Commission

I think it is essential to decide on burners. It is already seen that the production of green electricity is becoming cheaper and, in countries such as China, which are often referred to as a negative example of climate change, the development of renewable energy to produce electricity is extremely rapid and astonishing.

Filed in German · English published by the European Commission

Europe accounts for around 6 % of global CO2 emissions. Any intervention in Europe does not serve to achieve nullity. It only contributes to impoverishing people and deindustrialising Europe. Do to decarbonise, stop incentives for electricity and renewable energy. Stop at the end of endothermic engines in 2035.

Filed in Italian · English published by the European Commission

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Absolutely CONTRART, both to the abolition, but also to the reduction by law of endothermic engines. We are unprepared for such a change, the electricity grid would not be as much as the high load of an electric fleet. Electric motors can only be used for short journeys, not to mention the harm caused to citizens by the survivor of the elective used.

Filed in Italian · English published by the European Commission

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

It is important, to ensure a carbon free future. Unfortunately, it seems, that the commission only looks at electric solutions, thus preventing development of other carbon free drive lines for vehicles. We need to have open eyes, to be able to support innovative companies with good ideas. Furthermore, in these times, our electric systems are aims for hybrid wars.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The co-existence of both powertrains, electric motor and combustion, is the solution. Both have their specific advantages and certainly also their disadvantages. It seems to me to be short-sighted to categorise and even prohibit the combustion engine (a highly socialist idea, noted incidentally). It is long known that the engine is not the problem, but the fuel burned for it.

Filed in German · English published by the European Commission

I am Ad of a cold printing company that works 90 % for the Automotive sector, I think that the decision taken by the EC to impose the Green Deal in 2035 is a crowd decision and is taken without objective and economically unsustainable data. I am fully in favour of CO2 abatement, but totally disagree with the imposition of electric technology alone. Why this choice?

Filed in Italian · English published by the European Commission

I fully support the goal of decarbonization. In my opinion, however, the European Commission's role is to set target emission levels for manufacturers to meet, not to mandate specific technologies. Companies must have the freedom to innovate and reach these goals without technological constraints. I say this as a very satisfied electric car owner.

Our feedback addresses the strategic integration of Digital Product Passports (DPPs) into the revised Regulation (EU) 2019/631, which sets CO emission standards for new passenger cars and light commercial vehicles. We highlight how DPPs can provide a robust digital infrastructure for tracking emissions, vehicle lifecycle data, and sustainability metrics across the automotive sector.

The revision of the EU CO rules is a key step, but more than ever, we need a vision based on evidence and real, non-ideological innovation. I believe in a transition to zero-emission mobility that is technologically neutral, economically sustainable and socially fair.

Filed in Italian · English published by the European Commission

The revision of the EU CO rules is a key step, but more than ever, we need a vision based on evidence and real, non-ideological innovation. I believe in a transition to zero-emission mobility that is technologically neutral, economically sustainable and socially fair.

Filed in Italian · English published by the European Commission

For the revision of the CO2 standards for cars and vans, the following are of particular importance: - No backsliding. It would be unacceptable for the EU to delay or weaken its climate targets, particularly with recent evidence on the urgency of combating climate change - Predictability.

For the automotive sector, TECHNOLOGICAL NEUTRALITY without yourself and without. The process of producing the electric car due to rare earths to the batteries is 300 % higher than that of the endothermic motor car. The more electric it goes and the more polluted as renewables are remote to power a fleet of electric cars only.

Filed in Italian · English published by the European Commission

Comments from the VFAS (Verband Freihandel Schweiz) on the evaluated vehicle CO emissions targets from 2030 onwards, Dear Als Verband Frei Autohandel Schweiz (VFAS) represent the interests of independent vehicle importers and distributors, which contribute significantly to market diversity and competition in the automotive sector.

Filed in German · English published by the European Commission