Position of the Netherlands on
future CO2 standardisation for
heavy-duty vehicles

2 | Ministery of Infrastructure and Water Management

Management Summary

This document sets out the joint position of the Ministry of
Infrastructure and Water Management, evofenedex (Dutch
Shippers Council), Natuur & Milieu (environmental NGO),
TLN (Dutch association for transport and logistics) and
BOVAG (Dutch trade association of entrepreneurs engaged
in mobility) on future European emission standards for
heavy-duty vehicles (lorries and buses). The position is
based on technological and market developments and the
urgent need to reduce CO2 in order to achieve the Paris
Agreement goals. When drawing up the position paper, the
parties sought the advice of four technical agencies, namely
TNO (Netherlands Organisation for Applied Scientific
Research), CE Delft (independent research and consultancy
organisation), ECN (Energy Research Centre of the
Netherlands) and Sidekick Projects.
The European Commission will put forward a proposal
mid-2018 for emission standards for heavy-duty vehicles for
the period of 2025 to 2030. The Commission’s proposal will
serve as the point of departure for upcoming European
negotiations about those new standards. This position
paper forms the basis of the Dutch input for the negotiations.
The document also serves as guidance for lobbying among
the rank-and-file of the individual parties in the run-up to
the Commission’s expected proposal.

Research conducted by TNO revealed that vehicles with
conventional power technology have a cost-effective
reduction potential of 28%1 in 2030 compared with the base
reference year of 2015. If trailers and car bodies are factored
in as well, the potential comes to as much as 33%. Other
sources, including ICCT, claim potentials of 30% and 40%2,
i.e. excluding respectively including measures for trailers
and car bodies. Besides being cost-effective from a societal
point of view, the applied technologies will within a few
years pay for themselves from an end-user’s perspective.
Introduction of emission standards for heavy-duty vehicles
has advantages for carriers, consignors (i.e. shippers and
logistic service providers) and manufacturers alike and will
also reduce societal costs.
The new emission standards need to strike a balance
between leadership, the transition to zero emission,
investment certainty and technical feasibility. The EU has a
role, as a frontrunner, in achieving ambitious climate goals.
The Netherlands takes the view that the EU should retain
this frontrunner role and should also pursue the transition
to zero emissions by heavy-duty vehicles wherever possible.

TNO study: Assessments with respect to the EU HDV CO2 legislation, TNO
2018 P10214, March 2018
2
ICCT, Fuel Efficiency Technology in European Heavy-Duty Vehicles:
Baseline and Potential for the 2020–2030 Time Frame
1

Position of the Netherlands on future CO₂ standardisation for heavy-duty vehicles | 3

Parties advise the European Commission to draw up
ambitious European emission standards that will reduce
on-road CO2 emissions by new heavy-duty vehicles in 2025
by 20 to 25% relative to 2015. This ambition needs to be
expressed by:
• a hard standard for 2025 for vehicles in categories 4, 5, 9
and 10 to bring about a reduction of at least 20% relative
to the reference year 2015;
• a standard for trailers and car bodies, to be developed
before 2022 and introduced in 2025, to bring about an
additional reduction of at least 5%;
• an incentive enshrined in legislation for zero emission
vehicles in 2025 in order to accelerate the transition
towards electric driving, also for heavy-duty vehicles.
Parties advise the European Commission to publish a 2030
target in the form of a provisional bandwidth based on the
full reduction potential for conventional HD vehicles. At a
later stage, the precise emission standards for 2030 can be
defined based on technological developments, the

4

emergence of zero emission alternatives for these vehicle
categories and other new insights. This revision of the
objective, for example in 2022, is the ideal time to widen the
standard to include other vehicle categories and trailers. It
has to be clear that an emission standard in 2025 is not the
end-goal.
Parties jointly conclude that there needs to be a standard at
the level of the entire vehicle, initially based on default
assumptions for trailer or car body. This standard needs to
be differentiated according to the different vehicle
categories defined in the certification. The standard needs
to be binding for the salesweighted average of all vehicles of
a manufacturer within the designated category and should
be set ex-ante. A standard expressed in grams of CO2 per
kilometre is strongly preferred. Provided that they are
appropriately defined, parties support flexibilities in
applying the standard. Parties advise the Commission to
devote attention to enforcement of the standard and a
policy on penalties.

Background and urgency

In the coming years, the mobility sector faces a major
challenge to go ahead with sustainability. The Paris Climate
Agreement represents a breakthrough. No fewer than
195 countries signed up to limiting the global temperature
increase to well below 2°C, and to pursue a further reduction
of warming to not more than 1.5°C. The Paris climate goals
require overall reductions of 80 to 95% CO2 in 2050 relative
to 2015. But in the shorter term, too, the emissions must be
significantly reduced in order to remain within the maximum emission scope (carbon budget) for 1.5 to 2 C°3. This
makes it necessary to pursue virtually zero emissions for all
modes of road transport.
Approximately one-quarter of all CO2 emissions by road trans­port in the EU originate from heavyduty vehicles. Transport
activities in the EU are expected to continue increasing over
the coming 40 years, while the reduction of fuel consumption through technological advances will insufficiently
compensate for the effect on total CO2 emissions. Based on
the policy as presently adopted, the CO2 emissions of
heavy-duty vehicles will, both in 2030 and 2050, be roughly
35%4 above the 1990 level. Figure 1 shows the estimated
emission from road transport, based on the current policy
framework in relation to the reduction which is needed in
order to stay on rack with the Paris agreement.

Figure 1: Expected European emissions of greenhouse gases by road traffic per mode of transport
based on existing policy (blue sections) and reductions required to achieve the Paris objective
(red lines)

See CE Delft, 2017, Klimaatbeleid mobiliteit op de kaart en de analyses van
I&W voor het INEK voor de doorrekening van de opgave
4
Commission Notice sent to the Council and European Parliament.
Strategy for reducing fuel consumption and the CO2 emissions of
heavy-duty vehicles
3

Position of the Netherlands on future CO₂ standardisation for heavy-duty vehicles | 5

In the Netherlands, road traffic accounted for roughly 29
Mtons of CO2 emissions in 2016. Of this, 5.4 Mtons were
caused by rigid trucks and and tractor semi-trailer combinations5. This represents a 17% share of total emissions from
road transport, even though trucks and semi-trailers do not
even account for 2% of the total number of vehicles in the
Netherlands. Around the time of the crisis, the emissions
did go down, but this was due to the decline in demand for
transport6. In the past year, the demand for transport
increased again and consequently so did CO2 emissions.
The European Commission is currently working on a
package of measures to reduce the CO2 emissions from
heavy-duty vehicles. The Commission has developed
simulation software called the ‘Vehicle Energy
Consumption Calculation Tool’ (‘VECTO’) in order to
calculate the fuel consumption and CO2 emissions by new
heavy-duty vehicles in a similar and cost-efficient way.

5
6

CBS Statline: Emissions into the air on Dutch territory; road traffic
Panteia, August 2017. Transport and Logistics sector study, Stilstand
CO2-reductie in Transport & Logistiek

6 | Ministery of Infrastructure and Water Management

The VECTO tool creates the basis for the certification of
vehicles, for the monitoring and reporting system and for
future emission standards. The certification and monitoring
will start in 2019 for the four vehicle categories with a gross
vehicle weight above 16 tons (categories 4, 5, 9 and 10) that
contribute most to CO2 emissions by heavy-duty vehicles.
This will be followed in January 2020 by certification of six
other categories. The European Commission will put
forward by mid-2018 a proposal for introducing emission
standards for the four aforementioned vehicle categories.
This position paper presents the joint standpoint of the
Dutch signatory parties on the standards.

Position

The Netherlands has committed to the 1.5°C target contained in the Paris Agreement and recognises that this will
necessitate all sectors striving for zero emissions in 2050.
A reduction of approximately 50% is necessary before 2030.
To achieve this goal in the transport sector, there will be a
need in the short and medium term for the large deployment
of highly-efficient conventional vehicles and, in the medium
and long term, the large deployment of zero emission
vehicles. By adopting this position, the parties are giving
substance to the declaration of intent in the SER Energy
Agreement “... jointly to endeavour to ensure that European
emission standards and policy are laid down or tightened up,
including for modes of transport in freight haulage”7.
European emission policy is the cornerstone of Dutch policy
for achieving the climate goals. Emission standards have
proven effective, provide a level playing field, pull down
market barriers, promote innovation and thus contribute
efficiently to the attainment of the climate goals. Emission
standards can bring about a bigger market offering of low
and zero-emission clean vehicles. Emission standards for
vehicles must be set at the European level. In addition at
national level, the European certification and registration of
CO2 emissions will make it possible to develop policies to
incentivise the deployment of clean vehicles. Stringent
emission standards are necessary for the Netherlands in
order to meet the Europe-wide reduction target for non-ETS
sectors.

7

The main goal of emission regulation is firstly to reduce
significantly the climate impact of the transport of goods
and people. Secondly, this measure will help to reduce
operational costs of the transport sector, because the
benefits of lower fuel consumption outweigh the investment
costs. Thirdly, this measure will contribute to strengthening
the competitiveness of European manufacturers, who will
be encouraged to use the most innovative technologies.
That will also create major advantages in markets outside
Europe. The United States, Canada, China and Japan already
have standards for reducing CO2 emissions from heavy-duty
vehicles. The regulation of emissions in the US is expected
to lead in the short term to an average CO2 emission that is
lower than in Europe.

Ambition
Parties advise the European Commission to set ambitious
European emission standards that will reduce on-road CO2
emissions by new heavy-duty vehicles by 20 to 25% in 2025
relative to 2016. This ambition needs to be expressed in the
first instance by:
• a hard standard for 2025 for vehicles in categories 4, 5, 9
and 10 to bring about a reduction of at least 20% relative
to the reference year 2015;
• a standard for trailers and car bodies, to be developed
before 2022 and introduced in 2025, to bring about an
additional reduction of at least 5%;

Agreed in the SER Agreement
Position of the Netherlands on future CO₂ standardisation for heavy-duty vehicles | 7

• an incentive enshrined in legislation for zero emission
vehicles in 2025 in order to accelerate the transition
towards electric driving also for heavy-duty vehicles.
Parties advise the European Commission to publish a 2030
target in the form of a provisional bandwidth that fully
utilises the reduction potential of conventional HD
vehicles. At a later stage, the precise emission standards for
2030 can be defined based on technological developments,
the emergence of zero emission alternatives for these
vehicle categories and other new insights. This revision of
the objective, for example in 2022, may also be the ideal
time to widen the standard to include other vehicle
categories and trailers. It has to be clear that an emission
standard in 2025 is not the end-goal.

Elements and usability
Parties jointly conclude that there must in any event be a
standard at the level of the entire vehicle, initially based on
default assumptions for trailer or car body. The standard for
the entire vehicle must be designed in a way that encourages manufacturers to use all available technologies,
including all specific engine-related technologies. An
additional engine efficiency standard may be useful,
provided that the standard is based on a test cycle that is
more appropriate to the specific usage of the vehicle (or the
category to which the vehicle belongs) than the WHDC8 used
for European pollutants emission standards. A distinction
needs to be made between an emission standard in the
form of:
a. a weighted average per vehicle category;
b. a weighted average for all new sales;
c. maximum limit not to be exceeded
(“not-to-exceed-limit”).
A standard based on a weighted average will help manufacturers to develop and implement innovative technologies in
a cost-effective manner. Parties prefer a standard per vehicle
category, applied to the sales weighted average of a
manufacturer within the category concerned. This is
because it offers a possibility to differentiate the standard
according to the technological potential of each category.
This design of the standard is, moreover, similar to the
standard for passenger cars. A not-to-exceed limit for
individual vehicles is unnecessarily stringent and would,
with the stated broad definition of categories, be far more
stringent for some vehicles in the same category than for
others.

8

WHDC: Worldwide Heavy-Duty emissions Certification procedure

8 | Ministery of Infrastructure and Water Management

Parties express their preference to limit exceptions. As a rule
vehicles are designed for specific purposes, but in 7 out of
10 cases they fall into one of the four main categories
designated by the European Commission. An exception can
obviously be made for usage profiles that are non-relevant
for a specific vehicle. A refuse collection vehicle that hardly
ever drives on a motorway does not need to satisfy specific
requirements for a user profile with a high degree of
motorway usage. However, the definitions of specific
vehicle categories and usage profiles must be worded
carefully. VECTO simulates four different CO2 emission
values, namely short distance, long distance, no load and
full load. These four emission profiles must apply to every
vehicle. The standard must be applied to a weighted average
of the various emission profiles. Allowance needs to be
made for realistic conditions of use and at the same time a
situation must be avoided where incorrect incentives arise,
for example the use of more powerful engines where such is
not necessary.

Baseline and ex-ante reduction
potential
Parties are in favour of defining ex-ante a fixed timeline for
the emission standards, with 2025 as a first step. This will
create clarity and ensure the market gets sufficient time to
work towards the goal. The objectives can be laid down
based on knowledge of the expected technological
developments. Determination ex-ante will lead to more
ambitious objectives, because the saving potential -and the
reduction that is necessary in light of the Paris objective – is
greater than the current difference between an average and
a best-in-class vehicle. Therefore, it is advisable to determine
the standard ex-ante in legislation, taking into account the
realistic potential for technological improvements
compared with a certain baseline. Sufficient data is available
at the European Commission to determine a baseline and a
realistic saving potential. This same system is used in the
United States.

Unit of emission standard
The primary objective of CO2 emission standards is to reduce
direct emissions of vehicles by applying CO2-reducing
technologies to the vehicles. Therefore, parties greatly
prefer an emission standard expressed in grams CO2 per km.
A standard expressed in g/tonkm gives vehicles with greater
capacity de facto a higher g/km target. The relationship
between CO2 in g/km and load capacity, however, is weaker
than the implicit relationship that follows from a standard
based on grams CO2 per ton km. As a result, bigger vehicles
would get an excessively high g/km target and smaller ones
an overly stringent target. As long as the load is a default
value a g/tonkm target is effectively equivalent to a g/km
target multiplied by a constant. In the longer term, however,
a g/tonkm based standards opens the way to differentiation
on the basis of payload with the adverse effects as mentioned.
A target in g/km encourages manufacturers to use the most
efficient technology, including for vehicles with a greater
capacity. The difference in emission between a vehicle with
a full load and a vehicle without any load will subsequently
be calculated and weighted in the VECTO simulation.

Flexibilities in applying the standard
Flexibilities in application of the standard will make a
stringent target more feasible and acceptable for OEMs,
may help to stimulate utilisation of the best and most
cost-effective technologies and reward manufacturers that
respond to this situation. However, such instruments must be
chosen carefully because they can also be counter-productive.
Moreover, flexibilities may make legislation unnecessarily
complex and increase administrative burdens. Provided that
they are appropriately defined, parties support the types of
flexibilities stated below. Parties note in this regard that
flexibilities must also be determined based on independent
(financial) research into the financing and risks in the
period that the total cost of ownership (TCO) still differs too
much from the regular energy carriers.

Flexibilities per manufacturer
• Exchanging credits between vehicle categories:
Exchanging credits between categories is effective only
when a weighting of credits is applied, based on the
expected CO2 emission during the life of the vehicle, i.e.
based on the average lifetime mileage.
• Banking & borrowing: the use of accrued credits from
earlier years (banking), or advance use of credits from
future years (borrowing), can only be meaningful in
combination with binding annually declining targets.

Flexibilities between manufacturers
• Trading credits between different manufacturers may
provide an extra stimulus for innovative technology.
Financial resources coming from “laggards” will go to
“front-runner” manufacturers that lead the way. At the
same time, this will be an incentive for manufacturers not
to be laggards.
• Pooling: the combination of targets between manufacturers can also contribute to this, because it is an implicit
form of trading credits.

Specific incentives for zero emission
vehicles
Zero emission powertrains for inner-city haulage are on the
verge of a breakthrough. The expectation is that electric
trucks, post-2025, will in many applications have a lower
total cost of ownership (TCO) than the present conventional
vehicles. To accelerate the transition to electric heavy-duty
vehicles, the European Commission should develop specific
incentives for zero emission vehicles. This might include a
system in which zero emission vehicles get credits or extra
credits. The introduction of a reward/penalty (or bonus/
malus) system for zero emission vehicles is a highly effective
measure for encouraging their production and sale. It is
advisable to set a maximum for the number of credits that
manufacturers can earn in this way, and the credits must
take into account the expected deployment (number of
kilometres over the lifetime) within the vehicle category.
The level of any quota must be in line with the technological feasibility of zero-emission vehicles in the various
categories and provide an effective incentive for all manu­
facturers to put on to the market sufficient zero emission
vehicles. The specific embodiment of the incentives for
2030 needs to be laid down at the time of the evaluation in
2022, based on further evolved insights in the feasibility and
costs of zero-emission propulsion technologies for HD
vehicles.

Position of the Netherlands on future CO₂ standardisation for heavy-duty vehicles | 9

Enforcement and penalty policy
Parties advise the European Commission to devote
attention to the enforceability of the standard. Elements
that play a role in this context are independent checking of
vehicles against the standards (and thus the certified CO2
value) and the consequences for manufacturers if the
standards are not met. Parties request the European
Commission to set up an adequate policy on penalties.
The size of the penalty per g/km CO2 must be set in a way that
ensures that it can never be worthwhile for manufacturers
not to use available technologies that are cost-effective for
the end-user. One idea might be a similar regime to the one
for passenger cars, but with a ‘lifetime mileage’ correction.
This will assure the proportionality and the consistency
between different vehicle categories.

Additional policy
Fuel consumption is a major cost component for businesses.
Besides the standards, it is essential to ensure good
information for buyers. Customers must be supplied in a
simple manner with accessible and reliable information on
the fuel consumption of vehicles, based on the VECTO
simulations, including the option to be able to evaluate the
effects of additional technologies.

10 | Ministery of Infrastructure and Water Management

The impact of emission standards can be increased by
having additional policies that encourage replacement of
the on-road fleet by newer, more economical vehicles. At
national level, a differentiated kilometre price, environmental zones and subsidy schemes will help to bring this
about. Similarly, the roll-out of charging and alternative
tank infrastructure is essential to the success of the transition
to zero emission vehicles. National investments in charging
infrastructure, including fast chargers, are indispensable for
the deployment of the vehicles. Harmonisation of weightand-dimensions legislation in Europe and the allowing of
cross-border use of longer and heavier commercial vehicle
combinations (“EMS trucks”) Europe-wide can also help to
reduce CO2 emissions. It is definitely not the intention to
tag national measures on to European rules. There is no
question of an additional national standard.

Reduction potential of trucks

The technically feasible reduction potential was identified
in order to be able to provide advice on the level of the
emission standards. Preferably, in €/ton CO2 the CO2
reduction should not be more expensive than CO2 reductions in other sectors. The emissions of trucks and the
reduction potential will depend on several factors. Some of
these factors are directly related to the physical properties of
the trucks, while others depend upon their usage. Figure 2
shows factors that may contribute to reducing CO2 emissions in goods transport.
Research conducted by parties including TNO shows that
between now and 2030 a wide array of technologies will be
available that will reduce fuel consumption and CO2
emissions of HD vehicles at limited cost. Based on cost
estimates applicable to large-scale use of the technologies,
with economies of scale and learning effects being fully
utilised, various studies have concluded that the technologies available up to 2030 will yield a reduction potential of
28% to 40% and that the additional costs of the technologies used can be earned back within five years (refer to
example in Figure 3). With a reduction potential of 20-25%
and the stated earn-back time, the annual benefits will be
three times higher than the costs. Beyond 20-25% the
investment costs for further reduction do increase, but the
entire reduction potential of around 30% will still be
attainable at net negative cost to society and end-user. If
trailers and car bodies are also factored in, the potential
rises towards 40%.

Figure 2: Factors that contribute to the reduction of CO2 emissions from vehicles and from freight
transport in general9

9

TNO, workshop, 28 November 2017
Position of the Netherlands on future CO₂ standardisation for heavy-duty vehicles | 11

Figure 3. Annuity of the additional purchase costs (blue lines), annual saving on fuel costs (green lines) and resulting impact on total cost of ownership (red lines)
as a function of the CO2 reduction achieved with technical measures for the example of a medium tractor trailer combination. Annuities were determined based
on a depreciation period of 5 years and an discount rate of 4% (societal) and 8% (end-user perspective).

The assumption of large-scale use is consistent with a
situation where application of the measures is imposed
through CO2 emission standards. In the short term, many
technologies will still be expensive, however, which may
deter individual manufacturers from using them. The level
playing field that will be created by introducing emission
standards can break this ‘early mover’ dilemma.

Carriers are very loyal to the brand of truck they drive and
for information they rely on the dealer10. A study conducted
by ECN revealed that buyers often have little confidence in
the consumption stated by manufacturers and that fuel
efficiency still plays a relatively small role alongside other
factors in the decision to purchase trucks11. Here again we
see an ‘early mover’ dilemma, but now from the user’s
perspective. A wide offering of new technologies by all
brands, stimulated by European emission standards, and
reliable information about the achievable savings, based on
European certification using VECTO, will persuade fleet
owners to purchase trucks with new, fuel-saving
technologies.
These technologies may form part of the vehicle newly
delivered by the manufacturer, but it is also conceivable
that a separate supply industry will come about for this,
for example a supplier with a package of aerodynamic
improvements to lower the air resistance of a trailer.
If VECTO and the associated input data were to become
available to this supply industry, it might even be possible
for fleet owners to determine in very concrete terms the
earn-back time of those technologies.

10
11

12 | Ministery of Infrastructure and Water Management

T&E webinar June 2017, GIPA market survey
ECN study “A perspective of truck dealers on CO2 emissions from
trucks”

Advantages of ambitious emission
standards for the Netherlands

sustainability strategy by purchasing or renting fuel-efficient
and clean vehicles. If the standard is directly aimed at
increasing the market share of zero emission vehicles, this
will also be conducive to achievement of the ambition
defined in the Green Deal for Zero Emission Urban Logistics.
Current CO2 emissions by trucks in urban logistics are
estimated at 4 Mtons CO2 per year12.

Ambitious standards will ensure that cost-effective
technologies for reducing emissions will become available
and affordable for carriers and consignors. Higher fuel
efficiency will produce, through the lower consumption of
fuel, a direct saving on operating costs. By reducing their
carbon footprint, companies can give substance to their

For manufacturers of trucks, the standards will provide a
boost to innovation in the field of emission-reducing
technology. As a knowledge-driven economy with a key
logistics sector, the Netherlands can benefit from this
situation. A market will come about for suppliers of
components and Dutch industry can play a role in that
market. By defining standards at EU level, a level playing
field will be created both for manufacturers and for
customers. Outside Europe, European players will become
more competitive, because standards exist also in other
countries and parts of the world and they will be tightened
up. For the Netherlands as a whole, the standards will
contribute to lower societal costs. This will be accomplished
directly through lower vehicle usage costs and indirectly
through lower external costs.

12

CE Delft, July 2016, Segmentering CO2-emissies goederenvervoer in Nederland
Position of the Netherlands on future CO₂ standardisation for heavy-duty vehicles | 13

Goal, process and method

In the SER (Social and Economic Council) Energy
Agreement, the importance of reducing emissions from the
transport sector was recognised and it was agreed that
parties would jointly pursue and advocate ambitious
European standards. This position paper describes the joint
position adopted by parties. The objective is to influence
the process of establishing European standards on the one
hand, and to provide a basis for the Dutch input during
negotiations in the European Council on the other. This will
also put the importance to Dutch stakeholders of having
sufficiently ambitious standards on the agenda of European
policymakers.
Parties obtained the advice of four technical agencies, namely
CE Delft, ECN, Sidekick Projects and TNO. The Ministry of
Infrastructure and Water Management commissioned the
publication of two studies, namely “A perspective of truck
dealers on CO2 emissions from trucks” (ECN), and
“Assessments with respect to the EU HDV CO2 legislation”
(TNO). A picture was provided of what the reduction
potential is for conventional lorries, what the potential is
of zero emission vehicles and what investment costs and
savings on fuel costs are involved. The outcomes of the
studies were of great importance when formulating this
joint position paper.
Parties will in due course agree follow-up arrangements for
how to bring this Dutch position paper to the attention of
relevant players in Europe in the preliminary phase and
during the negotiations on a new standard and to this end
will develop a joint lobbying strategy.
14 | Ministery of Infrastructure and Water Management

Position of the Netherlands on future CO₂ standardisation for heavy-duty vehicles | 15

Dit is een uitgave van het

Ministerie van Infrastructuur en Waterstaat
In samenwerking met:

Postbus 20901 | 2500 ex Den Haag
www.rijksoverheid.nl/ienw
April 2018