Therefore, fuel credits, CCF and biogas should not be included in the EU's CO2 requirements for new heavy-duty vehicles
- Inclusion of fuel credits and carbon correction factor, including biogas and efuels, significantly weakens the level of ambition in regulation and will mean that the transition and the reduction in the cost of zero-emission trucks will be delayed, to the detriment of hauliers and the climate. For the same reason, The EU Commission has actively opted out of the use of alternative mechanisms such as carbon correction factor, type approval and fuel credits in the regulation.
- A majority of truck manufacturers in the EU are against the inclusion of fuel in the regulation. Including Volvo, Scania and Daimler.
- A weakened level of ambition means that thea European industry is lagging behind in relation to the USA and China in particular, where significant amounts of support drive development forward and make it more attractive to establish production and value chains for e.g. vehicles, batteries, raw materials, etc. in e.g. the USA.
- A high level of ambition ensures faster innovation and development in the EU without the use of huge amounts of support, and also ensures the competitiveness of cheaper truck transport with electric trucks in the long term. California has also put forward a proposal for a 100% reduction for trucks by 2040.
- Without a high level of ambition, the EU will become increasingly dependent on, among other things, China, which in the current situation may be safety concern, just as a major conflict could in practice delay the EU's green transition to the detriment of businesses and the climate.
- Denmark needs ambitious CO2 requirements for new heavy vehicles in order to achieve its climate goals. Denmark does not have its own automotive industry and therefore has limited ability to influence their emissions – especially trucks, which do not have a registration tax. On the other hand, Denmark a large component industry, e.g. Danfoss, which supplies necessary technologies that used in electric buses and trucks.
- Denmark has compared to all previous regulations and revisions always had a position on avoiding fuel credits, carbon correction factor and type approval – most recently in relation to the revised CO2 requirements for passenger cars in 2022, where all major parties supported the mandate.
- Denmark has signed a Memorandum of Understanding in connection with COP26 with, among others, the USA stating that 100% of new trucks and buses must be zero-emission by 2040Furthermore, Denmark has signed a non-paper to the EU Commission stating that all new buses and trucks must be zero-emission as soon as possible, which in practice, in relation to the regulation, will be 2040.
- Fuels and the EU regulated in the Renewable Energy Directive and the Fuel Quality Directive – including types and level of ambition. Use of biogas is a national matter – not an EU matterIn addition, additional requirements for the use of, for example, biofuels and e-fuels will neither reduce the climate impact from the transport sector nor increase the amount of available alternative fuels.
- A large number of large Danish companies (such as Maersk, DSV, DFDS, Bluewater, Danish Freight Forwarders, Grundfos, IKEA, COOP, Brintbranchen and Schulstad) has asked Denmark in a consultation response to work towards a goal of 100% zero-emission target for new trucks sold by 2035.
- In the government's foundation it says that the government will work to promote zero-emission trucks. It also says that they will work for more biogas to replace natural gas (which is in short supply from Russia). It is a really bad idea to work to increase the use of gas.
- Biogas for trucks makes no sense. The biogas is not there, the infrastructure is not there and it will be far too expensive – also in road taxation. EU regulation will establish infrastructure for zero-emission vehicles in the period 2025-30, but not for gas. The EU Road Taxation Directive allows member states to give discounts to zero-emission vehicles in road taxation. Any type of gas vehicle is treated as a fossil vehicle and does not receive a separate discount – regardless of fuel. Germany's illegal discount will stop and German road tax will be doubled, which means that gas vehicles will not actually be allowed to drive through Germany. It will and will remain too expensive, at the same time with bio-LNG not being available in most EU countries.
- Fuel credits, carbon correction factors and type approval are not a cost-effective way to meet the targets, as opposed to zero-emission trucks. Therefore, bio-based fuels are used to, among other things, convert aircraft, shipping and industry, which is much more challenging to transition and where we need carbon-based fuels.
- Even with a Danish mandate for a 100% zero-emission target for new trucks sold by 2040, it is It is highly unlikely that the regulation will end up being more ambitious than proposed by the Commission. This means that new trucks overall only need to reduce emissions by less than 80% and there is ample flexibility built in, which in practice means that Danish hauliers can buy gas trucks even after 2040.
Green Transition Denmark is an independent non-profit environmental organization that has advised on the green transformation for more than three decades. Like a green solution tank we will deliver concrete, realizable and ambitious solutions that can accelerate the transition to an absolutely sustainable society.