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A key point that Motus-E would like to convey concerns the classification of ZEVs. In this respect, we note that the Commissions proposal for the revision of the CO Regulation introduces a pragmatic approach whereby zero-emission vehicles of category N may be counted as light commercial vehicles when the reference mass minus the mass of the energy storage system remains below 2840 kg.

ACEA is the voice of the European auto industry representing 17 major car, truck, van and bus makers. ACEA welcomes the Commissions aim to use public procurement to accelerate decarbonisation and strengthen industrial resilience. Our submission addresses the potential use of made in the EU requirements for the heavy duty vehicle segment.

The new regulatory framework should address the current market needs in order to ensure an efficient batteries’ life cycle management, both from an environmental and economic point of view. From this perspective and as highlighted during the consultation activities, here is what we recommend regarding: extended producer responsibility for second-life, battery recycling, battery design and manufacturing.

ACEA believes that any collection target would be inefficient to recycle more batteries. Therefore no changes are necessary to the actual legislation.Efficient and well-working collection and recycling processes, not only for automotive batteries and traction batteries, but for vehicles as such, are already implemented in many Member States.

Motus-E welcomes the European Commission’s Regulation Proposal and fully supports the measures that aim to ensure a competitive, circular, sustainable and safe value chain for all batteries placed on the internal Union Market, overcoming the barriers to the functioning of recycling industry and the environmental problems related to the production, use and End-of-Life management of batteries.

In line with the overall contribution to the Green Deal implementation published by ACEA on 22 January (https://www.acea.be/publications/article/paving-the-way-to-carbon-neutral-transport-10-point-plan-to-help-imple), automobile industry considers investment into alternative fuels infrastructure absolutely essential and the proposal on the AFID review should be presented by the Commission even sooner than foreseen…

MOTUS-E welcomes the initiative of the Commission to evaluate the Directive 2014/94/EU. We believe the current provisions fail to support the goals of establishing a common framework of measures to mitigate the environmental impact of transport, since many of the alternative fuels allowed in the present release emit CO2 and some of them are pure or derivate fossil fuels.

Motus-e strongly welcomes the European Commission’s Proposal for a Regulation and fully supports the measures that aim to deploy alternative fuels infrastructure as a necessary instrument to reduce emissions from the transport sector in the long term in the European Union.