CLEPA Position Paper on post 2020 CO2 emissions targets for Europe

CLEPA believes that Europe must maintain its leading position in reducing CO2 emissions from light-duty vehicles. This is an important driver in sustaining technology leadership, employment and the global competitiveness of the European automotive industry.


Building on the significant record of achievement in recent years, realistic and achievable targets for the next decade, 2021 to 2030, need to be developed. In this timeframe, the already started market introduction of highly-efficient powertrains will accelerate.


Improving internal combustion engine efficiency and increasing electrification


The internal combustion engine (ICE), in conjunction with progressively increasing levels of electrification, is expected to continue to be fitted to the majority of new vehicles. Therefore, technological advances to improve ICE efficiency must be maintained as well as electrification in its various forms (mild, full, plug in hybrid, full battery electric, and hydrogen fuel cell electric). At the same time, efforts to realise the potential for ICE powered cars with alternative (regenerative) fuels need to be intensified.


Certainty is required on whether future targets are to be set using the Tank to Wheel or Well to Wheel approach. CLEPA is committed to measures that can make a real impact on the global climate change challenge and therefore believes that Well-to-Wheel is the most appropriate, thereby taking into consideration how electricity is generated.


Further CO2 reduction potential beyond the 2020 limits exists, but is not linear, becoming more difficult to achieve due to the physical limits of the ICE and uncertainties regarding the costs and market uptake for alternative powertrains. Therefore a broader strategy is required including the use of alternative fuels.


Alternative powertrains, ICE technology and low carbon fuels


As part of this broader strategy, both alternative powertrains and ICE technologies running on low-carbon fuels must have a long-term future. By opening up both these paths to low-carbon mobility, as part of the revised EU CO2 Regulation, the EU can, in environmental terms, maximise the CO2 reduction potential and, in industrial terms, benefit from EU leadership in highly-efficient combustion technologies to finance investments in alternative powertrains. This broader strategy would also avoid the environmental and industrial danger of cuts in investments in “politically excluded” technologies.


One additional advantage of broadening the regulatory approach to cover fuels is that it would target the entire car fleet. Measures to de-fossilise fuel present a key addition to any future tightening of the CO2 regulation.


Technological neutrality and transparency


  • Technological neutrality should remain as a key principle. This will ensure that innovation will be widely spread across all promising CO2 paths, both ICE and alternative powertrains including but not limited to electrification.
  • CLEPA believes that g/km should remain as the most appropriate metric.
  • The setting of new targets needs to be done in a transparent manner with due consideration of the following points:
    • CLEPA is open to a 2030 target, but believes that such a target should include a gliding path in the preceding years in order to create planning and environmental certainty. Furthermore CLEPA recommends the creation of a banking mechanism, in case of overachieving targets, to encourage early adoption of new technologies.
    • CLEPA supports the WLTP introduction as a more realistic and robust test procedure, but stresses that the conversion from NEDC must not change the ambition level or undermine the 2020 compliance. Furthermore, clarity on the NEDC – WLTP is necessary before any future targets are set.
    • CLEPA believes that Eco innovations have a big role to play in reaching the GHG reduction ambitions as a driver of innovation, therefore they should be expanded beyond the current 7g limit. Eco innovations should also be extended to capture the fuel saving benefits available from certain technologies which are currently classified as “comfort” functions. We further believe that technologies related to connectivity (C2X) which can lead to better traffic management and consequent reduction in fuel consumption should be included.
    • In order to accelerate the uptake of new low emission technologies, CLEPA supports the continuation super credits.
    • CLEPA believes there is currently insufficient data available to support the life cycle analysis approach and in any case there are insufficient tools and resources for enforcement.


If the stated points are taken into consideration, we believe that Europe can continue to lead the way in reducing GHG emissions from transport, maintaining at the same time the technological leadership of the European automotive industry and its 12 million jobs.


Setting targets for CO2 emissions reduction


Setting a future target range for CO2 emissions is challenging considering the key uncertainties referenced above. The most important of these is the test cycle where the 2020 targets are set using the NEDC and any future targets should be set using WLTP, and there is not yet a clear conversion factor from one to the other. Furthermore, a decision on whether to pursue a Well to Wheel approach instead of the Tank to Wheel approach is required.


In order to set a future target, at this time, we have to rely on the known NEDC test cycle and a Tank to Wheel basis. Any figures mentioned will need to be converted to WLTP when a clear conversion method is defined.  With available technologies, compared to 2020 targets, an approx. 20% to 25% reduction in CO2 per kilometer can be reached by 2030.


Finally, in pursuit of real reduction of GHG emissions it is important to emphasise that the current and future CO2 regulations apply only to the new vehicles sold each year. However, they do not promote the renewal of the existing car park/fleet, a crucial element which must be taken into account if we are to achieve the goal of climate protection through lower CO2 emissions.


For a pdf version, please click here.




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