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.

The review of the Renewable Energy Directive (RED) is a unique opportunity to accelerate the use of renewable alternative fuels needed for the long-term decarbonisation of transport - renewable electricity, renewable hydrogen and e-fuels - while strengthening the sustainability safeguards for advanced biofuels and phasing-out of crop based biofuels.

T&E is the leading clean transport organisation in Europe. Supported by more than 60 organisations, T&E focuses advocacy efforts on clean vehicles, decarbonisation of shipping and aviation and clean energy for the transport sector. In the context of the EU Green Deal, we welcome the Commission’s intention to revise the Renewable Energy Directive and, in particular, its transport aspects.

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 supports Strategic Projects across the critical metals value chain, notably in processing, recycling & mining from waste. T&E analysis shows there can be sufficient processing capacity in lithium, cobalt and (with a push) nickel to meet Europes 2030 goals. - Environmental & social safeguards cannot be compromised, and should be strengthened in the area of indigenous peoples rights and waste management.

The fight against climate change is a race against the clock. Transitioning to renewable energy, efficient buildings and electric vehicles rapidly and at unprecedented scale is essential if we are to limit warming to 1.5°C. Beyond climate, our reliance on fossil fuels also undermines our energy security and sovereignty as the Russian invasion of Ukraine has highlighted.

The EPBD is the only EU legislation to address private charging and by failing to make this a focal point of the roadmap and the IA, the EU would be missing an essential piece of the European Green Deal and the Climate Target plan. The recent surge in electric vehicles (EV) sales (10.5% EV sales in 2020) highlights the need to ensure charging infrastructure keeps pace with the rapid growth of the EV market.

The EPBD is the only EU legislation to address private charging and by failing to make this a focal point of the roadmap and the IA, the EU would be missing an essential piece of the European Green Deal and the Climate Target plan. The recent surge in electric vehicles (EV) sales (10.5% EV sales in 2020) highlights the need to ensure charging infrastructure keeps pace with the rapid growth of the EV market.

T&E appreciates the opportunity to participate in this public consultation on the revised ESRS. T&E welcomes the retention of key principles such as double materiality, fair presentation, and the integration of sustainability due diligence considerations, which constitute the backbone of the EU sustainability reporting framework.

Please find attached our detailed feedback to this consultation. The attached file includes two different papers. The first one is a response to the consultation, while the second one goes into more detail into one of the issues. The first paper makes the following recommendations about the climate law: 1. Whole economy targets 2. Net-zero vs. decarbonisation 3. Intermediate targets and carbon budgets 4.

As the cornerstone of the EU climate architecture, the ETS is an essential tool to reach EU climate targets and internalise the climate costs of emitting GHG. To meet the EUs 2040 climate targets and ensure a fair, effective decarbonisation of the shipping sector, the EU Emissions Trading System (ETS) must be preserved and strengthened alongside other policy measures.

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.

This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.

T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.

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.

While every other sector’s climate emissions have decreased since 1990, on average, transport emissions have increased by almost 30% since 1990 (aviation emissions, for one, have more than doubled). Each mode of transport faces varying challenges to reverse this trend and reduce them in the coming decade.

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.

In view of the European Commissions initiative to amend the European Climate Law, see attached a briefing setting out T&Es key recommendations for a 2040 EU climate target that accelerates and deepens the process started with the European Green Deal and its objective to decarbonise the continent by 2050.

This submission is made on behalf of four European NGOs: ECOS, EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany, and Transport & Environment, all with an interest in the development of an environmentally sustainable battery value chain in Europe.

Lithium-ion batteries will be the backbone of the economy’s decarbonisation, notably the EU transport. Unlike combustion engines that burn oil and release harmful emissions, batteries can be reused and recycled at the end of their lives. Batteries are the best technology we have today to make our road transport emissions-free.

T&E welcomes the revised and renamed Corporate Sustainability Reporting Directive, which is an important milestone within the wider EU Sustainable Finance framework, the overarching goal of which is to channel the financial flows towards truly impactful and sustainable activities. We applaud in particular, the following elements: 1. Scope – extended and clarified, to include for all large and listed companies 2.

Transport & Environment, Europes leading clean transport campaign group, welcomes the Commissions proposal for a revised End of Life Vehicles law. This law is fundamental to ensure circularity of cars and greening of their production. The revised legislation should be as much about what goes into making a new car (low carbon and recycled materials) as about how its recycled at the end of its life.

In the face of growing international competition in green technology, the launch of the Green Deal Industrial Plan (GDIP) is welcome. By focusing on the regulatory environment for clean technologies, financing, skills and trade, the GDIP is a building block towards an ambitious green industrial policy at the EU level.

Transport & Environment feedback on car CO2 standards. Transport & Environment (T&E) welcomes the Commission’s (EC) proposal for a revision of the EU CO2 standards for cars. The 2020/21 EU car CO2 standards have resulted in an unprecedented drop in CO2 emissions from new cars (18%) compared to 2019, driven by the production and sale of a growing offer of EVs (reaching 16% in the first half of 2021).

Linked to the surge in home deliveries, vans are the EU’s fastest growing source of road transport emissions. Unlike for cars, the EU's van CO₂ standards have failed to put electric vans on the market in any real numbers. Only 2% of van sales were electric in 2020, compared to 11% for cars. The Commission’s Fit for 55 proposal that all new vans must be zero emission from 2035 is welcome.

T&E welcomes the opportunity to input into the design of the impact assessment regarding van CO2 standards, and advocates to: (1) Assess CO2 emission reduction targets of 20% for 2025, 31% for 2027 (brought forward from 2030), at least 60% for 2030, at least 86% for 2033 and 100% for 2035 (i.e.

EU car CO2 standards are a modern day climate and industrial policy, pushing investment into automotive transformation and securing supply of affordable electric cars to achieve zero carbon transport in Europe. T&E’s analysis shows that the 2020/21 standard of 95g/km will result in plug-in sales of 10% this year and 15% in 2021, making Europe a leading electric car market.

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.

Transport & Environment (T&E) welcomes the Commission’s (EC) proposal for a regulation on the deployment of alternative fuels infrastructure. In particular the change of the legislative instrument from directive to a regulation T&E considers an important step in the right direction. (detailed feedback in attachment).

The EU urgently needs a new and robust legislative framework on zero emission infrastructure to support the 33-44 million electric cars (battery and plug-in hybrid) expected on the road in 2030 to align with transport decarbonisation goals. Consumers should have access to the EU single market for chargers.

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.

Dear Madam or Sir, Please find attached T&E's position paper on the ReFuelEU Aviation Regulation, which includes our recommendations for SAF targets. We believe that the text has a solid basis, especially when it comes to its scope applying to all departing flights and its exclusion of food and feed crop-based biofuels.

Overview T&E supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty.

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.

We welcome the EC initiative to develop an effective EU regulation to drive the uptake of sustainable alternative fuels in EU shipping. We agree with the EC assessment that creating a predictable demand in the shipping industry is essential for the investment and mass scale deployment of sustainable alternative fuels.

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 European Commission's proposal to review the CO2 emission standards for new heavy-duty vehicles (HDVs) is the most important legislative initiative to regulate climate emissions from trucks and buses in Europe.

To achieve the EU's climate targets, heavy-duty vehicles (HDVs) need to be decarbonised and the sale of most conventional trucks and buses ended by 2035. The review of the HDV CO2 standards is the once in a decade opportunity to put HDVs on a Green Deal compliant trajectory.

Transport & Environment (T&E) welcomes the proposal for a revised Ambient Air Quality Directive (AAQD). The proposal is a step in the right direction. However, more ambition is needed to protect European citizens from the dangers of air pollution (especially so in cities) and incentivise policies like low emission zones to accelerate the shift to zero emission transport.

Transport & Environment, Europe's leading clean transport campaign group, welcomes the European Commission’s plan to review the Ambient Air Quality Directives (AAQD). While EU clean air laws have driven stepwise reductions in toxic air pollution, the Second Clean Air Outlook clearly shows that current and planned policies remain insufficient, especially in cities.

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.

T&E welcomes the opportunity to input into the design of the impact assessment of the TEN-T regulation. We particularly concur that the regulation is not delivering on stimulating zero-emission (ZE) transport and advocate for: 1) An exclusive focus on ZE technologies (battery electric and fuel cell electric vehicles) and not on low-emission technologies as suggested by the roadmap, to be consistent with the new EU…

Transport & Environment feedback on Euro 7. Transport and Environment (T&E) welcomes the publication of the Commissions (EC) proposal for a revision of the EU vehicle emission standards, however remains disappointed by the lack of ambition, especially for cars. Fixing toxic air caused by road transport in Europe is of paramount importance since it kills 70,000 people prematurely every year.

Transport & Environment (T&E), Europe's leading clean transport campaign group with 63 national member and supporter organisations in 24 countries representing more than 3.5 million people, welcomes the opportunity to provide feedback on the combined Evaluation Roadmap and Inception Impact Assessment for the post-Euro 6/VI standards.

T&E wishes to provide feedback on this initiative on to avoid deforestation associated with products placed in the EU. Please refer to the document in attachment for a full background note as a basis for our feedback. We welcome and appreciate the efforts of the EU in terms of deforestation to try and reduce the EU’s impact in forests.

T&E welcomes the proposal put forward by the Commission to substantially improve the ESG ratings market in the context of the EU renewed sustainable finance strategy. However, T&E also considers that the significant improvement proposed in the governance and transparency of the sector is not enough to make it a reliable indication of sustainability.

T&E welcomes the draft delegated act on the calculation and verification of recycled content in batteries, as a key step towards driving a circular battery value chain in Europe. At this stage of market development, we consider the chain of custody model of mass balance with volume reconciliation and credit allocation to be acceptable.

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.

Global deforestation needs to be halted if we are to win the fight against climate change, and the EU needs to lead by example. It is good the EU acknowledges its consumption is a part of the deforestation problem and that stepping up action is needed. The overall objective of the roadmap is hence welcome. The EU cannot afford any more false solutions in the name of climate change.

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.

T&E strongly believes that the development and adoption of sector-specific standards is crucial to help companies in their materiality assessment, reducing costs and making the reporting processes easier, while ensuring investors have access to meaningful information and auditors exercise is simplified.

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 and Environment (T&E) supports the European Commissions proposed Implementing regulation amending the MRV Regulation (Implementing Regulation (EU) 2018/2066) which aims to enhance transparency in airlines annual emission reporting, particularly with regards to their Sustainable Aviation Fuels (SAF) usage.

The Commission is proposing to reform the EU ETS rules for aviation to try and address some unfair privileges the sector was benefiting from and start applying a more effective price on aviation emissions. But it unfortunately continues to implement Corsia, ICAO’s carbon offsetting scheme despite its confirmed lack of economic and environmental integrity.

While every other sector’s climate emissions have decreased since 1990, on average, aviation emissions have more than doubled. If the European Green Deal is to radically reduce the EU’s climate impact, it has to reshape European aviation by using all necessary carbon pricing tools at its disposal, including revising the Emission Trading System (ETS).

Emobility is at the core of decarbonising Europe’s transport, since all new cars and vans and most new trucks sold in early-2030s will have to be zero emission if Europe is to comply with the Paris Agreement. This requires a speedy and comprehensive roll-out of charging infrastructure across Europe, but the current Directive 2014/94/EU is not aligned with EU’s climate goals or in line with the expected roll-out of…

A shift towards greener taxation can (among other things) help fight climate change, reduce labour taxes, boost the economy and provide flexibility for member states (MS) in determining tax policy. There are several EU tools at the disposal of MS, but existing legislation, which would require unanimous voting to amend, currently prevents it.

EU shipping MRV has 3 main objectives: 1. Provide accurate and transparent bottom-up ship emissions data 2. Address market barriers for uptake of efficient ships 3. Incentivise operational efficiency ships by providing clear metrics for real transport work By moving first, the adoption of the EU MRV incentivised the IMO to start work on a global Data Collection System (DCS) and as such, this clear leadership by the…

The main objective should be to reduce the overall environmental footprint of the whole battery supply chain from the upstream materials sourcing to the downstream battery and car manufacturing. Only ethically sourced materials and sustainable battery manufacturing can underpin EU decarbonisation. Some downstream companies have already launched initiatives to improve mining standards and local benefit sharing, e.g.

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.

Intro: The Commissions proposal is welcome. Reducing tolls for more efficient trailers will reduce energy use and emissions in road transport. It is an important demand-side measure supporting the truck CO2 standards currently under revision, with emission reduction targets for trailers added by the recent proposal.

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

The Clean Arctic Alliance welcomes the European Commission initiative to revise the EU rules on illegal discharges from ships and to ensure comprehensive coverage of all of the MARPOL annexes within EU regulations, along with robust mechanisms for monitoring of compliance including the issues that were not considered in Directive (2005/35/EC).