Initiative for green transformation: The CNG Club is involved

Active climate protection does not need wishful thinking, but a sound basis. That is why we, together with 64 other signatories, are calling for the use of renewable fuels for the green transformation of freight and passenger transport. Nothing works faster and better than the use of this immediately available alternative fuel and vehicle technology. It is important to be honest about the actual CO₂ emissions at all levels and one way to do this is to track the CCF (Corporate Carbon Footprint) of companies.

Berlin, 28 September 2023

Dear Federal Chancellor Scholz,
Dear Federal Minister Dr Habeck,
Dear Federal Minister Dr Wissing,
Dear Federal Minister Lemke,
Ladies and Gentlemen Minister Presidents,
Honourable Members of the German Bundestag,

We, 65 companies and associations from the logistics and bus industry as well as the fuel, commercial vehicle and supplier industry, strongly support the target of climate neutrality by 2045. In this context, we emphasise the importance of a technology-neutral design of Regulation (EU) 2019/1242 on CO₂ emission standards for new heavy-duty vehicles in the course of the ongoing revision (2023/0042(COD)).

In the upcoming negotiations in the Council, the German government should advocate a technology-neutral regulation that recognises renewable fuels in order to enable more effective and faster climate protection in the transport sector. The transformation to climate neutrality poses a major challenge for heavy commercial vehicles. The volume of freight and passenger transport will continue to rise (BMDV 2023, long-term traffic forecast to 2051). This will lead to an increase in CO₂ emissions despite ongoing efficiency improvements in vehicles and despite the optimisation of transport due to the predominantly fossil-fuelled existing fleet.

Only a technology-neutral design of the CO2 regulation for new heavy commercial vehicles will lead to effective climate protection.

Locally CO₂-emission-free commercial vehicles will play an important role in climate protection in the future. In view of the only gradual market penetration of zero-emission heavy commercial vehicles, the uncertainty about market acceptance on the part of fleet operators and the slow development of an adequate refuelling and charging network, all options for effective climate protection must be made possible through regulation.Renewable fuels are already making a significant contribution to the reduction of transport-related CO₂ emissions and must therefore be taken into account. In the area of renewable fuels, studies by the Fraunhofer Institute¹, among others, confirm a considerable volume potential that can still be developed. It is thus even more unfortunate that the contribution of these fuels is not acknowledged². The ramp-up is being supported throughout Europe by targeted support measures. The EU Commission's current proposal on CO₂ emission standards for heavy-duty commercial vehicles counteracts these efforts. These climate protection efforts must now be further supported by additional incentives.

The Commission's proposal to revise Regulation (EU) 2019/1242 on CO₂ emission standards for new heavy-duty commercial vehicles is not technology-neutral.

The proposed regulation leads to a technological focus on battery electric and fuel cell electric drives as well as hydrogen engines. Due to the exclusive consideration of emissions at the tailpipe, vehicle manufacturers and suppliers can only rely on these technologies to achieve the specific CO₂ reduction targets; the use of renewable fuels is not taken into account and ultimately penalised. Vehicles with combustion engines are therefore penalised regardless of the source of power. This technological stipulation restricts the opportunities for freight, transport and bus companies to operate commercial vehicles in a climate-neutral or low-emission manner by using renewable fuels such as bio-LNG, eLNG, bio-CNG, HVO100, B100 and, in future, electricity-based synthetic fuels. In addition, there is great potential for reducing CO₂ emissions by using renewable fuels to power auxiliary units on the vehicle, such as cooling units. 

The carbon correction factor promotes the ramp-up of renewable fuels and ensures greater climate protection through technology neutrality.

In order for renewable fuels to play their decisive role in the transformation of the commercial vehicle sector, a technology-neutral fuel factor must be added to the VECTO vehicle emissions calculation tool required for CO₂ regulation. The VECTO tool currently works under the incorrect assumption that vehicles with internal combustion engines run exclusively on fossil fuels. However, this does not correspond to the reality in Europe. The EU database Shares³ records the quantities of renewable fuels used in transport today. Based on this data, the fuel factor in the final certification of the vehicle's CO₂ emissions can take into account the actual emission reduction contribution made by these fuels. This adjustment is known as the carbon correction factor and enables a fair and realistic calculation of a vehicle's CO₂ emission values. One example is CNG/LNG: Around 15% of the fuelled volume in the EU comes from biogenic sources (Shares data 2021). It is incomprehensible that this emission reduction contribution is not credited to vehicles with combustion engines. The incorrect assumption of 100% fossil fuel operation can result in CO₂ penalties of up to 10,000 euros. These unjustified costs ultimately lead to avoidable additional economic burdens. The carbon correction factor can remedy this situation and promote the further ramp-up of all renewable fuels.

We therefore call on the German government to actively campaign at European level for the introduction of a carbon correction factor in the regulation of CO₂ emission standards for heavy commercial vehicles.

The German government's current position on the proposed regulation does not take renewable fuels into account. We, the companies and associations of the logistics and bus industry as well as the fuel, commercial vehicle and supplier industry, call on you to support holistic climate protection through the introduction of the carbon correction factor. Joint efforts and a technology-neutral design of CO₂ regulation will enable us to achieve the ambitious climate targets and succeed in transforming the commercial vehicle sector in Europe.

In German: Offener Brief an die Bundesregierung zum Carbon Correction Factor (CCF)

1 Fraunhofer: https://www.isi.fraunhofer.de/content/dam/isi/dokumente/cce/2019/klimab…. (S.54). Abgerufen am: 04.09.2023.

2 DENA: https://www.dena.de/fileadmin/powerfuels.org/Dokumente/Global_Alliance_…. Abgerufen am: 07.09.2023.

3 Share: https://ec.europa.eu/eurostat/web/energy/database. Abgerufen am: 04.09.2023

Signatories of this letter (associations):

Signatories of this letter (companies):