A leaked internal ACEA document, seen by the Green Mobility Magazine, reveals growing alarm among European carmakers over the feasibility of EU CO₂ targets, warning that the bloc’s current climate policy risks eroding industrial competitiveness, deepening social divisions, and entrenching dependence on Asian battery supply chains.
The paper argues that the 2030 and 2035 CO₂ targets for light-duty vehicles are “no longer realistic to achieve” and calls for an urgent recalibration of the regulatory trajectory. It warns that the present framework, centred exclusively on new vehicle supply, “is not working”, citing insufficient charging infrastructure, inconsistent national incentives and a widening affordability gap across Member States.
The document portrays the 2035 zero emission requirement as a “one dimensional pathway” detached from market realities. It claims that penalties for non-compliance could drain up to €25 billion in investment capacity from manufacturers without accelerating decarbonisation. ACEA urges the European Commission to reopen the file ahead of the 2026 review and adopt a more flexible, technology-neutral approach that integrates plug-in hybrids, hydrogen fuel cell vehicles and renewable fuels into the compliance regime.
The association’s position reflects a broader political shift. Citing former Italian Prime Minister Mario Draghi’s competitiveness report, the document endorses his conclusion that the “2035 deadline for zero tailpipe emissions was meant to trigger a virtuous circle” of investment, but that this has not materialised. It echoes Draghi’s call for a “joined up approach” linking industrial policy, supply chains and infrastructure rather than relying solely on regulatory pressure.
ACEA argues that Europe faces a “three speed” transition, with electrification progressing in northern and western Member States but stagnating in southern and eastern regions. It warns that the car, once a symbol of prosperity, risks becoming a “symbol of social division” as affordability declines. The document highlights the withdrawal of purchase incentives in Germany in 2023 as a trigger for what it describes as a “BEV market collapse”, undermining regulatory projections that assumed faster uptake.
Among the detailed proposals are a five-year averaging system for compliance between 2028 and 2032, extended super credits for small battery electric vehicles, a fixed renewable fuels coefficient and new allowances for vehicles operating exclusively on carbon-neutral fuels. ACEA also calls for an “urgent reassessment” of the 2030 target for vans, describing the segment as “in dire straits”, with battery electric market share at 8.5 per cent, less than half the level required for compliance.
