Proposal for a Regulation amending Regulation (EU) 2019/631 setting CO2 emission performance standards for new passenger cars and for new light commercial vehicles
Date: 2025-12-16
Institutions: Directorate-General for Climate Action, European Commission
Subjects: climate change policy, common transport policy

Factual Summary Report 

Disclaimer:  This  document  should  be  regarded  solely  as  a  summary  of  the  contributions  made  by 
stakeholders  in  the  open  consultation  on  the  revision  of  the  Regulation  setting  CO 2  emission 
performance standards for new  passenger cars and light commercial vehicles and the Car Labelling 
Directive. It cannot in any circumstances be regarded as the official position of the Commission or its 
services. Responses to the consultation activities cannot be considered as a representative sample of 
the views of the EU population.  

1.  OBJECTIVE AND METHODOLOGY 

As part of the revision of the Regulation setting CO2 emission performance standards for new passenger cars 
and light commercial vehicles (‘LDV CO2 standards Regulation’) and the Car Labelling Directive, an  online 
public consultation was carried out between 7 July and 10 October 2025 on the EU Survey website1.  

The  consultation  was  divided  into  three  sections  focusing  on,  respectively,  the  evaluation  of  the  LDV  CO2 
standards Regulation, the review of that Regulation and the review of the Car Labelling Directive. The online 
questionnaire contained 29 questions, mainly multiple-choice questions but with the possibility to elaborate on 
the given response and to submit position papers.  

This factual summary provides an overview of the contributions received.  

The high number of responses from citizens from Italy (805) compared to 55 replies from citizens from other 
EU countries suggested that there was at least one campaign in Italy to encourage people to respond to the 
consultation. Consequently, responses from Italian citizens have been treated and reported upon separately.    

2.  OVERVIEW OF RESPONDENTS 

The consultation received 1115 replies, of which 72% (805) were from Italian citizens and 55 (5%) were from 
other citizens. Responses from a company / business contributed the next highest number of responses (120, 
11%); these were split nearly equally between SMEs (57, 5%) and large companies (63, 6%), with a further 
76 (7%) replies coming from business associations. Half of the 10 responses from public authorities (1%) came 
from national bodies covering five Member States, with the remaining responses being from individual cities 
(three), a region (one) and a city network2. The remaining 4% of responses were split between NGOs (14, 
1%), academic/research institutions (12, 1%), consumer organisations (9, 1%) and ‘other’ (10, 1%), with the 
remaining four (0.4%) coming from trade unions. The breakdown by category is presented in Figure 1. 

Figure 1: Distribution of respondents by stakeholder category 

1  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14765-Revision-of-the-CO2-emission-standards-for-cars-and-
vans_en  
2 Belgium, Ireland, Italy, Latvia and Spain. 

 
 
 
 
The majority of responses came from respondents based in Italy (80%, 894), followed by Germany (6%, 72), 
Belgium (4%, 46), France (2%, 23), Spain (1%, 12) and the Netherlands (1%, 7). No responses were received 
from seven Member States: Croatia, Cyprus, Denmark3, Estonia, Lithuania, Malta and Romania. In addition, 
responses were received from stakeholders in other countries, of which the largest number came from the 
United Kingdom (1%, 11). The breakdown by country is presented in Figure 2.      

Figure 2: Distribution of respondents by country 

3.  RESULTS OF THE PUBLIC CONSULTATION 

The  aggregated  responses  to  a  selection  of  key  questions  from  each  section  of  the  questionnaire  are 
presented  below.  This  summary  focuses  on  responses  from  stakeholders  that  were  not  Italian  citizens, 
including in Figure 3, Figure 4, Figure 7 and Figure 8 where views on a range of statements are presented. 
The views of Italian citizens are mentioned separately, where this is informative.    

3.1  EVALUATION OF THE LDV CO2 STANDARDS REGULATION 

The evaluation looked at the implementation of the key elements of the legal framework from 2015 up to 2024, 
including the 2020 CO2 targets (fleet-wide and manufacturer-specific targets), the scope of the Regulation, the 
various modalities (e.g. pooling, derogations, eco-innovations) and the monitoring and reporting provisions. 
The targets for 2025 and later years were not covered. 

Effectiveness:  Overall,  many  respondents  were  not  convinced  that  the  Regulation  had  been  effective  in 
reducing  CO2  emissions  from  cars  or  vans  (cars/effective4:  33%,  87  out  of  262;  48  no  responses; 
cars/ineffective5: 38%, 100; vans/effective: 29%, 74 out of 258; 52 no responses; vans/ineffective: 52%, 135)6. 
The overall negative response was driven by the views of industry, as, for example, a majority of SMEs (60%, 
33 out of 55) stated that the Regulations had been ineffective for cars, as did many large industry respondents 
(39%, 40 out of 103)7. A majority of public authorities indicated that the Regulation had been effective (four out 
of seven, three no responses, for both cars and vans), as did a majority of ‘Other’ stakeholders, which includes 
consumer organisations and NGOs, (cars: 58%, 26 out of 45, four no responses; vans: 55%, 24 out of 44, five 
no responses). 

When asked to explain, ten business associations and companies from the electricity supply sector underlined 
that the Regulation had been effective, both in reducing CO2 emissions and in increasing the number of ZEVs 
on the market. Twenty-three business associations and companies from the fuel supply sector either stated or 
implied that the Regulation had not been effective, as it focused only on tailpipe emissions, and so excluded 

3 A separate response was submitted by the Danish Government.  
4 So responded ‘4’ or ‘5’.  
5 So responded ‘1’ or ‘2’. 
6  Italian  citizens  were  even  less  convinced  about  the  effectiveness of  the  Regulation  in reducing  CO 2  emissions  from  cars  and  vans 
(cars/effective: 20%, 157 out of 796; nine no responses; cars/ineffective: 61%, 482; vans/effective: 14%, 110 out of 790; 15 no responses; 
vans/ineffective: 68%, 540). 
7 The figures for vans were similar (SMEs/ineffective: 73%, 40; large industry/ ineffective: 60%, 60).  

 
 
 
 
other decarbonisation options for road transport, such as alternative fuels. While four manufacturers or their 
associations noted that there had been some progress as a result of the Regulation, ten argued that to be 
more effective there would need to have been better enabling conditions and/or more flexibilities.  

Efficiency:  Nearly  one  half  of  stakeholders  (46%;  114  out  of  250)  considered  the  Regulation  to  be  ‘very 
efficient’ or ‘moderately efficient’. This view was shared by a majority of  public authorities (71%, five out of 
seven) and ‘Other’ stakeholders (including NGOs and consumer organisations) (69%, 29 out of 42), but was 
not supported by SMEs (26%, 14 out of 54), nor by Italian citizens (20%, 159 out of 792).   When asked about 
the elements of the Regulation that caused the highest administrative burden, industry respondents (mainly 
manufacturers) mentioned the annual reporting, processing and checking of vehicle registration data (seven), 
real world reporting (11), the administration around eco-innovations (five) and pooling (three). 

Relevance:  The  majority  of  stakeholders  believed  that  EU  level  action  remains  relevant8  in  relation  to  the 
needs/problems addressed by the Regulation (79%, 217 out of 273), whereas only 39% (294 out of 753) of 
Italian citizens held this view. Support for the relevance of continued EU action ranged from nearly two thirds 
(36 out of 57) of SMEs to around three-quarters of large industry respondents (101 out of 139) and ‘Other’ 
stakeholders (37 out of 49), including NGOs and consumer organisations.  

Coherence: A minority of respondents considered that the Regulation was largely coherent9 with other EU 
legislation  and  policies  (stakeholders:  27%,  75  out  of  273;  Italian  citizens:  19%,  140  out  of  754).  Industry 
respondents were least convinced about the coherence of the Regulation (SMEs: 11%, six out of 57; large 
industry: 13%, 18 out of 139). In contrast, the majority of public authorities (six out of seven) and around half 
of other citizens (24 out of 44,) and ‘Other’ stakeholders (21 out of 44) thought that the Regulation was largely 
coherent with other EU legislation and policies. When asked to identify policies for which coherence could be 
improved, respondents fell into two distinct groups. A first group argued that the Regulation was not coherent 
with other legislation, such as the Renewable Energy Directive (66, of which 23 were fuel suppliers) and the 
Emissions  Trading  Directive  (42,  of  which  19  were  fuel  suppliers),  as  these  instruments  give  more 
consideration and prominence to the role of renewable fuels in decarbonising transport. The second group 
argued that the  ambition of other legislation was not coherent with the ambition of  the Regulation, thereby 
referring to the Alternative Fuels Infrastructure Regulation (21, of which seven manufacturers and four from 
the electricity supply sector) and the Energy Performance in Buildings Directive (15 industry respondents).  

EU added value: The majority of stakeholders (72%, 190 out of 265) considered that there was high added 
value10 in having an EU-level instrument to reduce CO2 emissions from new passenger cars and vans. This 
was the case for just over half of SMEs (29 out of 55), over three quarters (34 out of 42) of ‘Other’ stakeholders, 
which includes NGOs and consumer organisations, and all public authorities (seven replies). In contrast, only 
a minority (32%, 249 out of 772) of Italian citizens considered such an instrument to have a high EU added 
value. Respondents explained their positive views on the EU added value of the Regulation by noting that the 
new car and van market is EU-wide, so EU level action was needed to avoid fragmentation (43, of which 10 
were  fuels  suppliers  and  six  were  manufacturers)  and  that  EU  level  action  helped  to  support  the 
competitiveness of the relevant EU industries (14, seven of which were fuel suppliers).          

3.2  REVIEW OF THE LDV CO2 STANDARDS REGULATION 

3.2.1  Needs, market barriers and additional measures  

Respondents were asked to rank a list of needs that the Regulation should address. The responses can 
be seen in Figure 3, which only covers the replies from stakeholders other than Italian citizens11. The number 
in brackets next to each need indicates the total number of stakeholders who ranked each need first, second, 
third, fourth or fifth, so is the sum of the numbers in the respective horizontal bar.  

The  most popular responses were the need  to  “reduce  CO2 emissions from road transport in line with the 
climate neutrality objective” (59%, 184 out of 310 ranked as first or second), followed by the need to “strengthen 
the competitiveness and industrial leadership of the EU automotive industry” (38%, 117 out of 310). 

8 So responded “to a very large extent” or “to a large extent”. 
9 So responded “to a very large extent” or “to a large extent”. 
10 So responded “very high” or “high”. 
11 The responses amongst Italian citizens were more evenly distributed.  

 
 
 
Figure 3: Stakeholder rating of the needs that the Regulation should address (rank 1: most important; rank 5: 
fifth most important). 

Amongst the market barriers for the further uptake of zero-emission vehicles “limited affordability due to 
high purchase price” received the highest score (47%, 146 out of 310 ranked this first or second), followed by 
“limited availability of recharging and refuelling infrastructure” (25%, 77 out of 310), “high price of electricity” 
(23%, 70 out of 310) and “lack of adequate information or misinformation” (22%, 69 out of 310) See Figure 4.  

Figure 4: What are the main barriers for the further market uptake of zero-emission vehicles? (Rank the top 3 
most important barriers, with 1 being the most important, up to 5 for the fifth most important) 

 
 
 
 
The highest scoring additional measure needed to make zero-emission car and vans more attractive to 
customers  and  businesses  amongst  stakeholders  was  for  “EU  coordinated  incentive  schemes  for  ZEV 
purchase” (34%, 106 out of 310), followed by a favourable fiscal regime (29%, 91 out of 310).  

As regards additional measures needed to promote a resilient and sustainable automotive value chain 
in  Europe,  stakeholders  identified  “further  promoting  the  use  of  sustainable  renewable  fuels  in  internal 
combustion engine vehicles” (43%, 133 out of 310) and “stable long term industrial strategy for the value chain” 
(37%, 114 out of 310) as the most important ones12. 

3.2.2  Targets and flexibilities   

A small majority (52%, 132 out of 255) supported keeping the 2035 CO2 emissions targets for cars and 
vans  unchanged.  The  respondents  that  wanted  the  targets  to  be  changed  were  asked  what  should  be 
changed. For both cars and vans, the highest scoring answer was ‘Other’ (cars: 48%; 53 out of 111; vans: 
44%; 49 out of 112). In clarifying their reply, many fuel suppliers and vehicle manufacturers (large and small) 
called for a technology neutral approach and/or the use of a lifecycle approach (LCA), arguing that this would 
allow to meet the CO2 reduction targets through a wider range of technologies, such as renewable fuels and 
biofuels.  In  terms  of  the  additional  flexibilities  needed,  only  amongst  large  industry  stakeholders  more 
respondents were in favour of than against a three-year averaging for 2030-2032 (35 out of 74 in favour; 18 
against) or a five-year averaging for 2030-2034 (45 out of 72 in favour; 18 against).   

Only 19% (144 out of 775; 30 no responses) of Italian citizens supported keeping the 2035 CO2 emissions 
targets for cars and vans unchanged. The highest scoring response amongst Italian citizens was for the 
100% target to be postponed (cars: 38%; 242 out of 630; vans: 39%; 243 out of 627). 

3.2.3  Role of PHEV/EREV 

A majority of SMEs (67%, 34 out of 51) and large industry (67%, 69 out of 103), and half of Italian citizens 
(50%,  368  out  of  731)  indicated  that  the  usefulness  of  plug-in  hybrids  (PHEVs)  and  electric  range 
extended vehicles (EREVs) should be recognised in the LDV CO2 emission standards, also in the longer-
term. On the other hand, a majority of public authorities (four out of six), non-Italian citizens (70%, 35 out of 
50) and ‘Other’ respondents (including NGOs and consumer organisations) (58%, 25 out of 43) replied that 
there should be less of a role for PHEVs and EREVs due to their limited environmental benefit. 

3.2.4  Role of fuels 

A majority of Italian citizens (77%, 598 out of 774), SMEs (87%, 48 out of 55) and large industry (80%, 98 out 
of 122) indicated that sustainable renewable fuels should have a role in the LDV CO2 emission standards). 
Amongst large industry, a majority of manufacturers supported sustainable renewable fuels having a role (13 
out  of  17),  while  only  those  involved  in  the  electricity  supply  sector  (11  out  of  12)  replied  that  sustainable 
renewable fuels should not have a role. A majority of public authorities (four out of seven; three no responses), 
non-Italian citizens (34 out of 51) and ‘Other’ stakeholders (24 out of 43; these included NGOs and consumer 
organisations) also believed that sustainable renewable fuels should  not have a role, including a majority of 
NGOs (12 out of 14).See Figure 5.  

On which fuels should have a role, the highest scoring response amongst large industry (53%, 74 out of 
139) and SMEs (40%, 23 out of 57) was “other fuels”), which was most commonly further specified as all fuels 
that are compliant with the sustainability and minimum GHG saving criteria set out in the Renewable Energy 
Directive (EU) 2018/2001 (34 respondents, particularly fuel suppliers). Amongst  Italian citizens the highest 
scoring response was “advanced biofuels and renewable fuels of non-biological origin” (43%; 346 out of 805). 
See Figure 6. 

12 Again, the responses amongst Italian citizens were more evenly distributed, although similar responses were considered most important. 

 
 
 
Figure 5: Should sustainable renewable fuels have a role in the CO2 emission standards for cars and vans? 

Figure 6: Which fuels should have a role in the CO2 emission standards for cars and vans?  

 
 
 
 
Respondents were asked about the design of the mechanism to include sustainable renewable fuels in 
the CO2 emission standards for cars and vans. Common responses – mainly from industry, and particularly 
fuel suppliers – were for the definition of a new vehicle class for vehicles that only used CO2 neutral fuel (CNF; 
26 times), to use a carbon correction factor (CCF) to reflect the fuel mix (64 times) or for the use of LCA and/or 
a technology neutral approach (undefined) (32), or some combination of these.  

Respondents  were  asked  to  indicate  their  level  of  agreement  with  a  number  of  statements  regarding  the 
impacts of sustainable renewable fuels playing a role in the LDV CO2 emission standards. A majority of 
large industry (81%, 96 out of 118), SMEs (70%, 35 out of 50) and Italian citizens (59%; 431 out of 725) agreed 
that  this  would  provide  for  a  more  technology  neutral  approach.  Amongst  large  industry  respondents,  the 
electricity supply sector was the only sector in which a majority of respondents disagreed with this (82%, nine 
out of 11). Five out of six public authorities responding to the question and a majority of non-Italian citizens 
(57%, 27 out of 47) also disagreed.  

This pattern was reversed for other statements, focusing on the potential negative impacts of a greater role for 
sustainable  renewable  fuels.  For  example,  a  majority  of  non-Italian  citizens  (53%,  24  out  of  45;  10  no 
responses)  agreed  that  the  inclusion  of  sustainable  renewable  fuels  would  come  at  the  expense  of  the 
availability  of  those  fuels  for  other  sectors  or  transport  modes  that  have  more  challenges  to  decarbonise, 
whereas a majority of large industry disagreed (74%, 88 out of 119, 20 no responses). Similarly, a majority of 
non-Italian citizens (60%, 29 out of 48; seven no responses) agreed that the inclusion of sustainable renewable 
fuels could weaken the long-term certainty needed for investments in zero emission technologies, whereas a 
majority of large industry disagreed (76%, 91 out of 120, 19 no responses). 

3.2.5  Excess emissions premiums 

On how the revenues from excess emissions premiums should be used,  the highest scoring response 
was to provide support for the zero-emission transport transition (37%, 116 out of 310; see Figure 7). Italian 
citizens  (43%,  349  out  of  805)  preferred  using  the  revenues  to  support  the  companies  and  regions  most 
affected by job losses or value chain restructuring. 

Figure 7: Which should be the specific destination for revenues derived from the excess emission premiums 

3.2.6  Monitoring and reporting 

Opinions were divided about annual reporting requirements relating to vehicle registration data, with the 
exception of the statement that monitoring should be based on the electronic Certificate of Conformity 
(eCoC), with which two thirds (68%, 83 out of 122) of stakeholders indicated a high level of agreement13. The 

13 So responded “1” or “2”, indicating a high level of agreement. 

 
 
 
 
 
majority of large industry respondents also indicated a high level of agreement with limiting the number of 
parameters to be reported (71%, 32 out of 45) and that Member States should only report the vehicle 
identification numbers (VINs), leaving manufacturers to report relevant eCoC data (68%, 28 out of 41). A 
majority of ‘Other’ stakeholders, which includes NGOs and consumer organisations, indicated a high level of 
agreement  with  both  Member  States  reporting  the  VINs  and  the  type  approval  authorities  reporting 
relevant eCoC data (64%, 14 out of 22) and the Commission/EEA being granted direct access Member 
States’ vehicle registration data (73%, 22 out of 30). 

There  was  no  majority  in  agreement  or  disagreement  with  the  statements  about  real-world  reporting 
requirements, with the exception of a high level of agreement with limiting the number of parameters to be 
reported (57%, 76 out of 134).  

3.2.7  Efficiency of Zero Emission Vehicles 

A majority of large industry respondents (69%, 47 out of 68) and half of SMEs (23 out of 46) agreed there is 
no need to regulate the energy efficiency of ZEVs. A majority of non-Italian citizens (57%, 20 out of 35) and 
‘Other’ stakeholders, which includes NGOs and consumer organisations (66%, 21 out of 32), supported the 
introduction of a “target value for the fleet-wide average energy efficiency” (other citizens: 53%, 17 out of 32; 
‘Other’ stakeholders: 55%, 18 out of 33).  

3.2.8  Other Provisions 

Eco-innovations:  Many  respondents  indicated  that  there  is  a  need  to  change  the  provisions  on  eco-
innovations (Italian citizens: Yes: 46%, neutral: 44%, No: 10%; other stakeholders: Yes: 49%, neutral: 39%, 
No: 12%). In particular, four manufacturers and a supplier noted that the administrative process to apply for 
an eco-innovation is complex and lengthy, which creates a disincentive for their use. A couple of companies 
called for the role of eco-innovations to be strengthened or to be applicable to technologies reducing emissions 
other than those from the tailpipe. A consumer organisation argued that eco-innovations sometimes pushed 
up prices. Amongst NGOs, one called for the removal of eco-innovations, and one for the credits to reflect real-
world performance. 

Pooling: Respondents were ambivalent on the  need to  change the pooling provisions  (stakeholders: Yes: 
31%, neutral: 39%, No: 30%; Italian citizens: Yes: 33%, neutral: 54%, No: 13%).  

Exemption and derogations: In relation to the exemption for manufacturers responsible for less than 
1000 vehicles registered per year, most stakeholders were against a change (Yes: 19%, neutral: 40%, No: 
41%). The responses in relation to the small volume manufacturers derogation showed a similar pattern.  

3.3  REVIEW OF THE CAR LABELLING DIRECTIVE 

Harmonisation: A large majority of stakeholders agreed14 that the design of the label should be the same 
in all Member States (Italian citizens: 80%, 558 out of 700; other stakeholders: 86%, 160 out of 186). There 
was similar support for having the information included on the label being the same in all Member States 
(Italian citizens: 81%; 565 out of 696; other stakeholders: 87%; 163 out of 187). A little less than half of the 
respondents disagreed15 that Member States should be able to require manufacturers to include additional 
information. 

Information elements: There was broad support for the inclusion of different information elements on the 
label for zero-emission vehicles, including energy consumption (83%, 156 out of 188 considered that this 
was important16), electric range (79%, 148 out of 187), charging time (72%, 134 out of 185) and battery capacity 
(75%,  139  out  of  186)17.  When  asked  to  rank  the  most  important  additional  information  that  should  be 
displayed on the label, ‘real-world fuel or energy consumption’ received the highest score18 (28%, 87 out of 
310), with ‘lifecycle CO2 emissions’ second (22%, 67 out of 310; see Figure 8)19. 

14 So responded ‘4’ or ‘5’. 
15 So responded ‘1’ or ‘2’. 
16 So responded ‘4’ or ‘5’. 
17 The numbers were similar for Italian citizens:  energy consumption (80%, 506 out of 721), electric range (82%, 545 out of 724), charging 
time (79%, 503 out of 723) and battery capacity (77%, 484 out of 716). 
18 So responded ‘1’ or ‘2’. 
19 The numbers were similar amongst Italian citizens: real-world fuel or energy consumption (30%, 244 out of 805); lifecycle CO2 emissions’ 
second (27%, 221 out of 805) 

 
 
 
Figure 8: Which are the most important additional information elements that should be displayed on the label 
for potential buyers of a vehicle? (rank 1 representing the most important, rank 5 being the fifth most important) 

Information channels: Stakeholders agreed that the  label should  be displayed both at the point of sale 
(78%, 142 out of 181) and be accessible online (90%, 164 out of 183), and that it should include a weblink to 
other  relevant  information  (80%,  143  out  of  179).  There  was  similarly  a  high  level  of  agreement  amongst 
stakeholders that a  guide should  allow  for a  comparison  between brands and models (70%, 117 out  of 
166), and that this should be accessible online (72%, 131 out of 169)20. 

Scope: The majority of stakeholders considered that it was important to extend the scope of the labelling 
requirement to cover new vans (stakeholders: 75%, 121 out of 162; Italian citizens: 61%, 405 out of 664). 
Half of the stakeholders supported extending the labelling requirements to cover second hand cars and vans 
sold through a dealership (cars: 50%, 80 out of 159; vans: 51%, 79 out of 156), although there was less support 
amongst Italian citizens (second hand cars: 37%, 248 out of 665; second hand vans: 38%, 250 out of 652). 

20 The numbers were similar for Italian citizens: label shown at point of sale (69%, 398 out of 686), label accessible online (83%, 596 out 
of 715); label including a weblink to other relevant information (72%, 494 out of 683); guide available (68%, 371 out of 687); and guide 
accessible online (73%, 505 out of 690).