eFuels for Trucks
One instrument to reduce greenhouse gas emissions in the transport sector is the revision of CO2 emission standards for heavy-duty vehicles. We are convinced that a balanced mix of strict but achievable CO2 emission standards and a level playing field for all emission reduction technologies will have the most positive impact on our climate. To determine the actual contribution of a technology to climate protection, the CO2 balance of a vehicle must ideally be assessed on the basis of its entire life cycle. The inclusion of renewable fuels in CO2 emission standards is a first step towards a more holistic and inclusive climate approach to transport.
Our demands
Every possibility to reduce emissions should be allowed in a technology-neutral way, in the sense of a holistic and successful climate policy. A fair competition between emission-reduction technologies is vital. Especially where the market ramp up of the electric mobility faces challenges and difficulties other climate-neutral options must be available.
Compliance with CO2 standards for trucks through renewable fuels must be made possible. There are two possibilities that can be used complementarily: a so-called "carbon correction factor" and a crediting mechanism for renewable fuels.
Renewable fuels can address the specificities of heavy-duty transport
Freight transport by truck is the basis for our everyday security of supply, from the daily delivery of food to the transport of parts for industrial production. Cross-border supply chains with a functioning infrastructure are essential to guarantee this security of supply.
A technology mix in heavy goods transport is therefore essential: around 60% of truck freight in 2020 was transported over more than 300 km, most of it over long distances between 500 km and 1000 km. A battery for such ranges weighs between 5 and 6 tonnes - this battery weight would not only limit the payload due to the higher weight, but also increase the carbon footprint of vehicle production tremendously. Another challenge in the defossilisation of heavy-duty transport is the need for a Europe-wide, resilient infrastructure. Not only would electrification require the necessary capacity in the power grid to be expanded across the board, but charging timeswould take several hours even with today's fast-charging technology.
In contrast, eFuels can be blended into the current fuel mix throughout Europe and can be used in existing trucks unproblematically, without the payload being restricted by a larger drive system. Synthetic fuels can thus defossilise heavy-duty transport and at the same time guarantee the smooth functioning of cross-border supply chains.
In order to responsibly tackle the GHG issue for heavy-duty vehicles, taking into account the economic, social and climatepolicy implications, solutions must address the various demands of the different use cases: A delivery van in ametropolitan region requires different technical solutions than a long-haul 40- tonne truck that drives thousands of kilometres every day. A municipal refuse truck has different operation modes than an off-road construction machine. For that reason, a “one-size-fits-all solution” with a focus on electrification is not suitable for heavy-duty vehicles.
Thinking electrification and renewable fuels together
Heavy-duty transportation is the backbone of trade and commerce on the European continent. Most goods and daily necessities are shipped by trucks, with 73% of all freight transported by land being carried by trucks in the EU. At the same time, heavy-duty transportation is responsible for 27% of the EU's road transport CO2 emissions and 5% of total CO2 emissions in the EU – more than aviation and maritime transport combined.
Electrification is important, but not sufficient to achieve defossilisation of heavy goods transport. More than 6.2 million trucks were operating on European roads in 2020. According to the European Commission, 86% of the truck fleet alone will be powered by combustion engines in 2040 and will continue to emit additional CO2 emissions unless synthetic fuels are used. Allowing renewable fuels in fleet standards is therefore a critical building block to enable sustainable, low-emission heavy-duty transport.
Need for action: Taking renewable fuels into account
The proposal for the revision of CO2 emission standards for heavy-duty vehicles by the European Commission do not consider renewable fuels. Instead, it separates the separates responsibility along the supply chain: Fuel suppliers are responsible for emissions from transport fuels from the original energy source (“well”) to the vehicle (“tank”). They are subject to regulations such as the revised Renewable Energy Directive (“RED”) and further regulatory requirements that essentially focus on the quantities of fuel consumed. Vehicle manufacturers (often referred to as Original Equipment Manufacturers, “OEMs”) are responsible for direct emissions from the vehicle, i.e. on the way from the tank to the wheels. The main element regulating emission reductions are the CO2 emission standards for new vehicles. OEMs have to fulfill a certain average fleet target for the yearly sold new vehicles. By not connecting these two areas, the EU legal framework leaves out significant environmental advantages and restricts the possible powertrain options for heavy-duty vehicles.
Building a bridge can be done by two means, which can be implemented separately or simultaneously: The first option, a voluntary crediting system for renewable fuels, enables an additional option for the truck manufacturers to fulfill the targets of the CO2 standards with additional volumes of renewable fuels. The second possibility is a Carbon Correction Factor, which would reduce the CO2 emission targets for truck manufacturers by the amount of renewable fuels that already exists the current fuel mix.
The Commission has a clear task to include renewable fuels
In the current CO2 emission standards for new heavy-duty vehicles ((EU) 2019/1242) the Commission has a clear order to develop a more comprehensive assessment, taking into account the full life-cycle CO2 emissions of new heavy-duty vehicles as well as the possible contribution of synthetic and renewable fuels, including eFuels.
This has not been implemented in the proposal for a new regulation: The Commission chose to measure emissions at the tailpipe, which excludes eFuels and focuses almost purely on electrification.
In addition, the Impact Assessment shows the Commission’s questionable approach in comparing electrification and synthetic fuels: Additional costs for battery electric vehicles stemming from the necessary charging infrastructure, additional space requirements for charging, impact on supply chain etc. seem to not have been taken into account at all. At the same time, the impact assessment is extremely intransparent and does not give detailed assumptions of the calculations e.g. battery prices and capacity or future prices for eFuels. This makes the calculations on which the proposal is build as well as the conclusions of the Commission not verifiable for associations, industry players or scientists.
This clearly shows that the Commission’s goal is not to reduce CO2 emissions as quickly as possible in a technology-neutral way, but to simply switch to zero-emission vehicles production without considering valid complementary options.
Broad support for eFuels from industry and science
The public consultation of the CO2 emission standards for new heavy-duty vehicles clearly signals a need for implementing a mechanism to introduce renewable fuels in the heavy-duty regulation. Two third of the stakeholders – most from the industry – are in favour of a consideration of renewable fuels. Just 23% of 137 stakeholders oppose such a mechanism. Public authorities are split. However, the result of the public consultation shows that the Commission has to act and should propose a mechanism to consider renewable fuels in the regulation for new trucks.
A joint letter to European decision-makers, signed by around 120 companies and associations as well as more than 90 scientists, also shows: Industry and scientific community agree that all climate-neutral options for action must be used in heavy goods transport.
Position papers
Position Paper: CO2 Emission Standards for Heavy Duty Vehicles
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