What the amendment does
The newly adopted amendment corrects an overly restrictive design flaw in the current rules by adjusting the emission credit calculation mechanism for the reporting years 2025 to 2029. Manufacturers will now be able to generate emission credits when their new vehicle emissions fall below the legal 2025 – 2029 target of -15%, rather than being measured against an artificial linear emissions-reduction trajectory.
By improving the industry’s ability to accumulate emission credits before 2030, this flexibility helps smoothen the transition toward the significantly more demanding 2030 targets, without altering legal obligations. The rules apply specifically to heavy-duty vehicles covered by the regulation, explicitly excluding urban buses due to their distinct public procurement deployment patterns and more advanced infrastructure readiness.
The real-world challenge remains
Despite this welcome procedural fix, the transition to zero-emission (ZE) HDVs is progressing too slowly. In 2025, zero-emission vehicles accounted for just 2.0% of heavy-duty truck (>16t) registrations and 14.8% of medium-duty trucks (3.5 – 16t) in the EU. This stark reality reflects a growing gap between the increasingly ambitious CO2 targets imposed on manufacturers and the sluggish pace of progress on necessary enabling conditions. Dedicated charging and hydrogen infrastructure for HDVs remains grossly insufficient, energy costs remain too high, and the business case for transport operators is fragile at best.
What the amendment does not do
ACEA stresses that while this amendment is a necessary step, it is narrow in scope and does not:
- Change the targets: The amendment does not revise, lower, or reopen the ambitious HDV CO2 targets for 2030, 2035, or 2040, fully preserving the regulation’s overall ambition and the long-term decarbonisation pathway.
- Solve the infrastructure deficit: The proposal does not address the structural lack of enabling conditions. It introduces no demand-side measures, provides no strengthened Alternative Fuels Infrastructure Regulation (AFIR) obligations, and offers no new financial support to accelerate the deployment of vital infrastructure for the ZE transition.
Karin Rådström, President and CEO of Daimler Truck and Chair of ACEA’s Commercial Vehicle Board: “The commercial vehicle industry is firmly committed to decarbonisation—and we have been investing heavily in zero-emission technologies for years. We very much welcome the latest move of the European Institutions: The fact that exceeding our CO2 targets will be credited in the future is a fair and important corrective step. But it is not enough to ensure the transition toward CO2-neutral transport. We urgently need a comprehensive review of CO2 regulations so that the ambitious reduction goals are linked to infrastructure rollout and economic viability for our customers – this will enable us to move forward together.”
Next steps: Accelerating the upcoming review
This targeted amendment maintains a strong incentive for manufacturers to accelerate ZE market adoption early, but its success ultimately depends on faster progress in real-world conditions.
Crucially, this narrow adjustment does not pre-empt the upcoming review of the HDV CO2 Regulation. A fundamental gap remains between regulatory ambition and infrastructure readiness, posing a critical threat. ACEA therefore insists on the importance of accelerating the review, with a clear priority: closing this gap and ensuring the shift to zero-emission transport is workable across the entire European transport ecosystem.