立场文件——重型车辆生命周期评价方法

ACEA position paperHeavy-duty vehicleLCAmethodology INTRODUCTION This position paper presents the industry’s perspective on DG CLIMA assessment on EU2024/1610 HDV CO2regulation Article 15 (l)i: “the possibility of developing a common Unionmethodology for the assessment, and the consistent data reporting, of the full lifecycle CO2emissions of new heavy-duty vehicles that are placed on the Union market.” ACEA acknowledges the importance of Life Cycle Assessment (LCA) as a tool forunderstanding the environmental impacts of vehicles and supports the extensions ofharmonisationefforts on national and international level to HDVs.However, the application ofLCA methodologies toheavy-dutyvehicles(HDVs)presentsignificant limitations that hinderits effectiveness as a potential regulatory tool. This position paper outlines ACEA’sperspective on why currently LCA is not suitable for regulatory target settingfor HDVs. Thebelow mentioned consideration should be taken into account by DG CLIMA in the HDV LCAmethodology feasibility assessment, as per the mandate in HDV CO2 regulation ofdeveloping automotive LCA methodology for HDVs. KEYMESSAGES 1.NoHDVregulatorytarget setting for 2040 based upon LCA methodologyWhile LCA is useful for internalenvironmentaldecision-making, ACEA opposes itsuse for setting 2040 HDV regulations.It couldlead to unintended consequenceslikemarketdistortions.Instead,the automotive industrypromotesdirect emissionreduction strategies and targeted, non-redundant legislationto avoid high efforts forvery limited environmental benefits. 2.Focus on battery LCA decarbonisation covered bytheEU Battery RegulationIntroducing a lifecycle assessment (LCA) methodology for heavy-duty vehicles(HDVs) would create regulatory overlap and compliance burdens without significantenvironmental benefit, as existing EU legislation,including theEUBatteryRegulationii, already comprehensively addresses emissions and impacts across alllife-cycle phases. 3.One-size-fits-all approach is unrealistic The application of LCA to HDVs is inherently more complex than for light-dutyvehicles (LDVs)due tohigher variety of vehicle specifications, leading to diverseenvironmental profiles. 4.SupporttheUNECE A-LCA guidelines to promote global harmonisationACEA advocates for globally harmonisedAutomotive Life Cycle Assessmentstandards aligned with UNECE's A-LCA. Currently focused on light-duty vehicles,asimilarapproachshould be considered forheavy-duty vehicles,ensuring fair, robust,and realistic comparisons. FOCUS ONBATTERYLCADECARBONISATIONCOVERED BYTHEEU BATTERY REGULATION Due to the high contribution of use phase emissions during the life cycle climate impact ofHDVs, the vast majority of emissions is already covered by EU fleet legislation. The CO2emission standards for heavy-duty vehicles already set targets for fleet-wide average CO2emissions. For battery-electric HDVs, the decarbonisation potential is significantly tied tobattery production and efficiency. The EU Battery Regulationiialready addresses the impactsof battery manufacturing, including resource sourcing, carbon footprint, and recyclingrequirements. Introducing LCA as an additional regulatory layer creates redundancy andcomplicates compliance without offering substantialenvironmental benefits. TheEuropean Commission Green Deal developed and enforced multipleregulations anddirectivesthat cover allthe different life-cycle phases of HDVs.Forexample,the third versionof theRenewable Energy Directive(REDIII)iii,Emissions Trading Systems(ETS)IandIIiv,End-ofLifeVehicles(ELV)Directivev,CorporateSustainabilityReportingDirective (CSRD)vi,etc.The introduction of HDV LCA methodologywouldcreateoverlapping regulations withpotentially not alignedscopes, boundaries,and calculation methodologiesthatwould onlylead toadditionalburden to manufacturers. ONE-SIZE-FITS-ALL APPROACH ISUNREALISTIC The application of LCA to HDVs is inherently more complex than forlight-dutyvehicles(LDVs).HDVs vary significantly in size, design, operational patterns, and usage intensity,leading to diverse environmental profiles. Standardised LCA metrics struggle to account forthese variations, resulting in inconsistent and potentially misleading comparisons. Suchcomplexity undermines LCA’s reliability as a basis for regulatory target setting.Multi-stagevehicles1even create further challenges due to the responsibility share between OEMs andbodybuilders.This also applies for the impact of trailer design and production in trailer-truckcombinations.Thereisa significantchallenge to find a representativeheavy-dutyvehicle thatcovers allsignificantvehicle configurationsto reduce LCA development burden,butat thesame time allowdecentcomparabilityand representativeness.This complexity is furtherhighlighted by theVehicle Energy Consumption calculation TOol(VECTO)viidevelopmenttiming and principle,whichare completely different totheWorldwide harmonised Light-dutyvehicles Test Procedure (WLTP)viiidevelopmentandshould be studi