International Council on Clean Transportation

The International Council on Clean Transportation (ICCT) is pleased to provide feedback to the call for evidence of the Commissions Circular Economy Act. The ICCT is an independent nonprofit organization founded to provide first-rate, unbiased research and technical and scientific analysis to environmental regulators.

[Please see more detailed feedback in the attached file.] The ICCT appreciates the IDAAs objective to increase sustainable and resilient industrial production in energy-intensive industrial sectors in the EU. In addition to the focus sectors mentioned in the call for evidence, ICCT recommends including battery production and supply chain projects, including battery recycling projects, into the scope of the IDAA.

International Council on Clean Transportation consultation response on Amendment to the Renewable Energy Directive to implement the ambition of the new 2030 climate target November 17, 2021 This consultation response is submitted by the International Council on Clean Transportation (ICCT).

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

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the inception impact assessment for the revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources. The ICCT applauds the European Commission’s goal to reduce the use of fossil fuels and achieve a net zero-carbon economy by 2050.

The ICCT appreciates the opportunity to provide input through this call for evidence. We strongly support the Taxonomy's role as a cornerstone of the EU's sustainable finance framework and recognize its importance in directing capital toward environmentally sustainable economic activities.

International Council on Clean Transportation consultation response on Review of the EU ETS for maritime, aviation and stationary installations, and of the Market Stability Reserve July 8, 2025 The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the Proposal to provide input on the review of the EU Emissions Trading System (ETS) and the Market Stability Reserve (MSR).

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

The International Council on Clean Transportation (ICCT) (EU Transparency # 06250094777-73) is replying to the call for evidence for the Clean Corporate Vehicles initiative. In the attached document we provide selected research and findings from recent ICCT publications relevant to decarbonizing corporate fleets. The findings are intended to support informed consultation.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the Proposal for the extension of the EU ETS to cover maritime shipping. The ICCT is an independent non-profit organization founded to provide first-rate, unbiased technical and scientific analysis to environmental regulators.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide input on the initiative Setting a renewable energy framework for the decade ahead. The ICCT is an independent non-profit organization founded to provide first-rate technical and scientific analysis to policymakers.

The ICCT appreciates the opportunity to provide input through this public consultation. We strongly support the Taxonomy's role as a cornerstone of the EU's sustainable finance framework and recognize its importance in directing capital toward environmentally sustainable economic activities.

The ICCT welcomes the opportunity to comment on the Regulation of the European Parliament and of the Council on circularity requirements for vehicle design and on management of end-of-life vehicles, amending Regulations (EU) 2018/858 and 2019/1020 and repealing Directives 2000/53/EC and 2005/64/EC.

Our own analysis confirms the Commission's finding that, without further policy intervention, emissions from road transport are not on a trajectory for achieving the 2030 target and climate neutrality by 2050. We find that with the policies currently adopted, CO2 emissions from cars and vans will only decrease by about 70% in 2050 relative to 2020.

The ICCT appreciates the opportunity to provide input through this call for evidence. The Commissions initiative comes at an important time for European aviation. Over the past decade, the EU has established itself as a global leader in aviation climate policy through targeted policy instruments, such as the EU Emissions Trading System (EU ETS) and ReFuelEU Aviation, as well as innovative research programs…

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the Commission’s proposed ReFuel EU Aviation regulation. We commend the Commission for its continuing efforts to promote a cleaner, lower-carbon transportation sector that uses less petroleum-based fuels. This proposal builds upon the impressive steps the Commission has undertaken to promote low-carbon biofuels.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the inception impact assessment for the ReFuelEU Aviation Initiative. The Commission’s suggestion in the roadmap that food and feed-based fuels have limited potential for decarbonization is sound and evidence-based.

In response to the European Commission's call for evidence, the International Council on Clean Transportation (ICCT) welcomes the European Commissions EU Electrification Action Plan, supporting the plans aim of promoting cost-effective and system-friendly electrification. Please refer to the attachment for detailed feedback and evidence.

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.

International Council on Clean Transportation (ICCT) is an independent non-profit organization founded to provide first-rate, unbiased research and technical and scientific analysis to environmental regulators. ICCT welcomes the opportunity to comment on the European Commission’s FuelEU Maritime Proposal.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the FuelEU Maritime inception impact assessment roadmap. We approve of the Commission’s intention to support the decarbonization of the marine sector.

The proposed revision to the CO2 standards for heavy-duty vehicles introduces one of the worlds most stringent CO2 standards for a major market. It would significantly accelerate the market for zero-emission technology vehicles, and provides a framework to increase the emissions reductions over those from the current standards.

ICCT’s general position: Heavy-duty vehicles (HDVs) play a crucial role in Europe’s efforts to move towards climate neutrality by 2050. The sector is responsible for 2.5% of total road vehicles yet contributes to 27% of the EU27’s annual road CO2 emissions, and 6% of annual total net greenhouse gas emission.

The International Council on Clean Transportation (ICCT) is pleased to respond to the public consultation on the Commission's proposal for a Delegated Regulation supplementing the EU Battery Regulation with a methodology for the calculation and verification of the carbon footprint of electric vehicle batteries.

The International Council on Clean Transportation (ICCT) supports the proposed enhancements to the EUs roadworthiness package, particularly the strengthened emission screening and inspection program. Excess pollutant and noise emissions from on-road vehicles present a serious public health and economic burden across the EU.

ICCT welcomes the development of Euro 7/VII standards. Of the preliminary set of policy options put forward by the Commission, ICCT favors Option 3. Below ICCT’s recommendations. Further details can be found in the file attached. RECOMMENDATIONS FOR EURO 7 (LDV) Emission limits should be fuel-, technology- and application-neutral.

The ICCT welcomes the opportunity to comment on the Impact Assessment for the Delegated Act on iron and steel products, within the Ecodesign for Sustainable Products Regulation. Out of the three main policy options that are suggested for the Impact Assessment, the ICCT would like to comment on the first two, concerning information requirements and the performance classes. Please see below our main comments.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the Proposal to revise the EU Emissions Trading Scheme (ETS) treatment of aviation emissions. The ICCT is an independent non-profit organization founded to provide first-rate, unbiased technical and scientific analysis to environmental regulators.

The ICCT applauds the European Commission’s intention to secure the aviation sector’s contribution to EU climate goals. While other sectors have made significant progress in deploying renewable energy and improved efficiency to curb or even reduce their emissions, emissions from international flights in Europe have increased by 141% since 1990.