ACEA-立场文件——重型车辆二氧化碳排放标准法规审查（英）-2023.3-8页_600kb

ACEA Position Paper: Review of CO2 Emissions Standards Regulation for Heavy-Duty Vehicles

March 2023

Summary

1. Context: The EU set ambitious CO2 reduction targets for heavy-duty vehicles (HDV) in 2019 (15% by 2025, 30% by 2030 vs. 2019/2020 baseline). These targets necessitate significant industry investment (e.g., in battery electric and hydrogen powertrains) and value chain restructuring.

2. Key Message: Focus on Enabling Conditions: Achieving these targets requires complementary enabling conditions (infrastructure, carbon pricing). These are lagging and constitute a major barrier, potentially endangering the transition and EU competitiveness.

3. Current Challenges:

   • Insufficient charging/refueling infrastructure for HDVs.
   • Inadequate carbon pricing mechanisms.
   • The newly proposed (EC, Feb 2023) 45% reduction target by 2030 (vs. 2019 baseline) is considered unrealistic. It demands rapid deployment of ZEVs/trailblazer tech 2-3 years earlier than expected and unprecedented infrastructure expansion.
   • New proposals for different vehicle groups (e.g., coaches) based on a 2025 baseline are also deemed unambitious timeline-wise.
   • The urban bus ZEV sales mandate risks overburdening operators and infrastructure.

4. Recommendations:

   • Implement an annual review of enabling conditions (infrastructure rollout, carbon pricing, etc.) based on binding KPIs to prevent target non-compliance by manufacturers due to lack of enablers.
   • Maintain a reasonable annual reduction rate for all vehicle groups.
   • Provide flexibilities (like a credit/debit system) but clarify they cannot replace enabling conditions.
   • Decarbonization must be technology-neutral, supporting battery electric and hydrogen designs.
   • Industry Commitment: Manufacturers aim for fossil-free mobility by 2040.
   • Align the Euro 7 HDV emissions standards with the stricter CO2 targets to avoid contradictions.
   • Ensure EU competitiveness by securing raw materials and fostering green investments without protectionism.

5. Criticality: Madatory to coordinate policy actions across the transport, industry, and energy sectors to avoid disruption and achieve climate neutrality.