Transport & Environment

The Circular Economy Act (CEA) will be key to scaling Europes recycling industry across batteries, steel, aluminium and beyond, whilst also promoting greater materials recovery from other waste streams. Building up local recycling companies and getting recycling production going will be key to building a sustainable electric vehicle industry, whilst driving industrial opportunities in Europe and creating resilient…

T&E has several policy recommendations for the Industrial Decarbonisation Accelerator Act (more details can be found in the note attached to this feedback): 1) Introducing EU-made green steel targets in new cars: the evidence shows that 40% in 2030, 75% in 2035 and 100% in 2040 are feasible thresholds, covering both recycled and primary green steel.

In order to boost domestic production and the deployment of clean technologies at the heart of the green transition, T&E supports the development of lead market standards in the EU Single Market. The revision of the EU Public Procurement directives is a golden opportunity to introduce sustainability and resilience criteria in the future public procurement framework.

T&E welcomes the possibility to put forward its recommendations ahead of the revision of EU Taxonomy technical screening criteria (TSCs) for transport. Overall T&E believes that simplification efforts must not weaken existing ambitious rules, stressing that the Omnibus proposal risks confusion, reduced investment certainty, and a race to the bottom that rewards laggards and penalises first movers.

T&E welcomes the opportunity to provide feedback on the European Commission's Call for Evidence regarding the upcoming legislative initiative on Clean corporate vehicles. In summary, T&E believes that the upcoming EU Clean Corporate Fleets Initiative is an opportunity to boost demand for zero emission cars and trucks in Europe.

Extending CBAM to downstream products would level the playing field by ensuring that cars imported from abroad follow the same regime as EU-made ones by paying a price on the carbon. Granting such a level playing field between vehicles produced in Europe versus those produced outside of Europe would reinforce the competitiveness of the European car industry.

The Renewable Energy Directive (RED) must remain the backbone of the EUs post-2030 energy framework. As Europe faces yet another energy crisis, it is crucial that we finally put an end to our dependence on fossil fuels and strengthen the role of domestic renewable energy.

T&E welcomes the opportunity to provide feedback on the revised draft delegated act and supports the ongoing efforts to simplify and streamline the EU Taxonomy criteria. However, we are deeply concerned that the current direction of revision risks lowering the overall level of ambition rather than improving the usability of the framework.

Attached is a report commissioned by T&E, which reviews current practices in France, Germany, Hungary, Italy, the Netherlands, Poland, Spain and the UK and identifies some best practices for connecting recharging points. The development of EV charging infrastructure across Europe is shaped by differing levels of policy ambition, regulatory maturity, and grid readiness.

In light of the current crisis in Iran and broader conflicts such as the Ukraine war, the dependency of European aviation on fossil fuels and imported kerosene is clearer than ever. Countries like China are quickly catching up in the field of aerospace technologies.

Transport Electrification: The Math for 32-33% EU Energy Target T&E aligns with the Commission's diagnosis that stagnant electricity consumption slows decarbonisation. Transport electrification with Vehicle-to-Grid (V2G) capability offers the fastest path to the 32-33% target while solving system-level flexibility challenges.

The EU must ensure that CO infrastructure planning is aligned with emission reduction as the first priority. CCS and CCU must not deter from emission avoidance: A lock-in of abatable fossil emissions from fossil power generation or unsustainable biogenic emissions from forestry biomass combustion must be avoided.

T&E welcomes the initiative to streamline DNSH across the entire EU budget. We recommend the Commission to 1) Further build on the EU taxonomy and existing Social Climate Fund (SCF) guidance to design a simple and universally applicable guidance for the entire MFF, 2) Ensure that environmentally positive interventions (contributing to spending targets) adhere to the DNSH principle and that 3) The guidance results in…

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.

T&E Response to Annex V / VI Consultation T&E welcomes the opportunity to comment on the proposed updates to Annex V and VI of the Renewable Energy Directive. While we appreciate the Commission's efforts to reflect recent changes in biofuels emissions, several areas require greater clarity and transparency.

Transport & Environment (T&E) welcomes the opportunity to respond to the public consultation launched by the European Commission on the potential role of international carbon credits in the EUs 2040 climate target. Please, see attached our suggestions.

Energy efficiency is essential to decarbonize shipping and reduce the cost of transitioning to expensive clean fuels. The Energy Efficiency Directive (EED), a cornerstone of the EUs climate action alongside the RED and the ETS, currently excludes the shipping sector - despite its significant emissions and energy consumption.

The EU must prevent material leakage from end-of-life products and all waste products, including scrap, relating to aluminium. This should preferably be achieved via export bans, more harmonised waste criteria, or levied export fees, which would make exporting to third countries more expensive and burdensome.

Transport & Environment (T&E) welcomes the revision of Governance of the Energy Union and Climate Action (Governance Regulation) as a key opportunity for shaping the EUs post-2030 climate and energy architecture. The 2018 Regulation has played an important role in coordinating Member State planning and monitoring progress towards the EUs 2030 climate and energy targets.

Transport & Environment (T&E) supports the continuation and strengthening of binding national climate targets beyond 2030 as a core pillar of the EUs climate and energy architecture. While EU-level carbon pricing under the EU Emissions Trading System (ETS) has proven effective in driving cost-efficient emissions reductions, it should be complemented by additional measures to ensure the delivery of the EUs climate…

The CRM centre, supported by robust industrial policy and building on work in Member States, must provide real financial power to deliver on raw materials projects and secure resilient, sustainable supply chains for Europe. Despite numerous attempts and good intentions, the EUs efforts so far to secure access to raw materials and deliver progress on the ground have had mixed results.

T&E welcomes the Commissions draft act on the methodology for calculating the carbon footprint of electric vehicle batteries. Prioritising direct connection to renewable energy, thus rewarding clean manufacturing, and opting for a battery approach for the functional unit are key principles and should be kept.

Clean Cities, Europe's largest network of more than 140 civil society organisations advocating for healthy, safe and affordable urban mobility, welcomes the European Commissions initiative to collect harmonised urban mobility data per urban node.

T&E welcomes the opportunity to give feedback to the EU Air Services Regulation. In view of the preparatory work to revise Regulation 1008/2008, T&E stresses the importance of using this revision as an opportunity to build on the Regulation to promote environmentally sustainable connectivity.

Transport & Environment (T&E) welcomes the opportunity to respond to the public consultation launched by the European Commission on the update of the list of approved recycling sites for ships sailing under the flag of an EU country.

Transport & Environment (T&E) welcomes the European Commissions consultation on the update to the list of neighbouring container transhipment ports under the EU Emissions Trading System (ETS) for maritime transport, and supports the extension of this list to include Damietta and Abu Qir. Our position and arguments in favor of this inclusion are further explained in the document attached.

Transport & Environment (T&E) welcomes the European Commissions consultation on the update to the list of neighbouring container transhipment ports under the FueleEU Maritime and EU Emissions Trading System (ETS) for maritime transport, and supports the extension of this list to include Damietta and Abu Qir. Our position and arguments in favor of this inclusion are further explained in the document attached