Position Paper - Eurovignette: ACEA's Comment on the Second Amendment

ACEA position paper Eurovignette:ACEA commentstothe2ndamendment (COM(2025)589 final, 2023/0134 (COD)) GENERAL REMARKS The introduction of CO2-based road charges with full exemptions for zero-emission vehicles(ZEVs)is one of the most effective and targeted levers to accelerate the transition to zero-emission trucks and buses. The Eurovignette Directive1provides a common EU framework KEY ISSUES AND RECOMMENDATIONS 1.Full and timely implementation by all Member States Too few Member States have introduced CO2-differentiated road chargesat an incentivelevel that makes a difference for the TCO2, and only a limited number make full use of thepossibility to exempt zero-emission vehicles. All Member States should introduce distance-based CO2-linked charging without delay or, at a minimum, adopt alternative measures that 2.Reference values are too low to generate strong demand for zero-emission The current reference values under the Directive are not sufficient to make zero-emissionvehicles economically attractive. Germany provides a ZEV benefit of around€0.30/km, whilethe Netherlands offers roughly half of that amount. By contrast, applying the Directive’sexisting reference values would lead to a ZEV discount of only around€0.08/km, which is too 3.Interaction with ETS2 and the “double taxation” concern Some stakeholders argue that applying both Eurovignette charges and ETS23obligationsconstitutesa“double taxation”. This claim is only valid if the combined price of the ETS2 andthe Eurovignetteexceedreal-world abatement costs, which is currently not the case. In fact,the overall price signal from the Eurovignette and ETS2 remains too weak to drive therequired market transition to ZEVs, especially if the ETS2 price will be capped at€45/tonne 4.Use of revenues to support the ZEV transition Revenues generated from CO2-based road charges should be earmarked and reinvested inmeasures that directly support the deployment of zero-emission vehicles. Priority areasinclude public charging and hydrogen refuelling infrastructure for heavy-duty vehicles, as well 5.Alignment with the HDV CO2 Regulation It is important that the Eurovignette Directive and the HDV CO2 Regulation4remain fullyaligned. Introducing a well-to-wheel (WtW) approach under the Eurovignette, for instance bytaking account of the WtW performance of different energy carriers, while the CO2 standardscontinue to rely on a tank-to-wheel (TtW) methodology, could lead to regulatory 6.Adjustment of the emissions trajectory Under Regulation (EU) 2024/16104, heavy-duty vehicle manufacturers are legally required toreduce fleet-wide CO2 emissions by 43% by 2030 compared to 2019 levels. Achieving this The increasing stringency of the HDV CO2targets will require manufacturers toprogressively phase out vehicles currently eligible for CO2emission classes 2 and 3 by At the same time, the Eurovignette framework should continue to incentivise the uptake ofthe latest low-and zero-emission vehicles that deliver improved fuel efficiency and reducedCO2emissions. In this context, theEuropeanCommission’s proposal to maintain thetrajectory at a-30% level beyond 2030 would benefit from better alignment with the Ensuring consistent application across all Eurovignette classes should be duly reflected inthe impact assessment accompanying the forthcoming review of the HDV CO2regulation. ABOUT THE EU AUTOMOBILE INDUSTRY •13.6million Europeans work in the auto industry (directly andindirectly), accounting for6.9% of all EU jobs•8.1%of EU manufacturing jobs–some2.5million–are in theautomotive sector•Motor vehicles are responsible for €414.7billion of tax revenue for •The automobile industry generates a trade surplus of €93.9billion •The turnover generated by the auto industry representsover8% of •Investing €84.6billion in R&D per year, automotive is Europe'slargest private contributor to innovation, accounting for 33% of the ACEA REPRESENTSEUROPE’S 17MAJORCAR, VAN, TRUCK AND BUS MANUFACTURERS ACEAEuropean AutomobileManufacturers’ Association+32 2 732 55 50 x.com/ACEA_auto linkedin.com/company/acea youtube.com/c/ACEAauto