Europe’s Internal Combustion Engine Ban Saga

The New Law   

On the 28th of March, the European Council adopted a regulation that put the automotive industry on a stricter path towards carbon neutrality. The new regulation requires a 55% CO2 emission reduction for new passenger cars and a 50% reduction for new light commercial vehicles from 2030 to 2034 in comparison to 2021 CO2 emission levels. In addition, both forms of transport will be required to reach 100% carbon reduction from 2035.  

Call for Submissions!

Road transport is one of the biggest emitters of greenhouse gases (GHG) within the transport sector. According to the European Commission, in 2019 road transport accounted for over 70% of the entire transport sector’s GHG emissions. In addition, the NewClimate Institute stated that in 2017 the transport sector accounted for 27% of EU emissions. With the announcement of the ‘Fit for 55’ package in the summer of 2021, which aims to reduce GHG emissions by 55% before 2030, compared to 1990 levels, action in road transportation is crucial. Issued by the European Commission, the ‘Fit for 55’ package recognised this cruciality, and, hence, included the new road transportation legislative act, with the aim to strengthen innovation and competitiveness in the EU industry.   

A regulatory incentive mechanism is set to be in place between 2025 and 2029 for zero- or low-emission vehicles. With an aim to encourage the transition to carbon neutrality and sustainable development, the mechanism will reward manufacturers with certain benchmarks for the sales of low-emission vehicles (25% for passenger vehicles and 17% for vans) with less strict CO2 targets. Furthermore, this regulatory incentive includes a reference to e-fuels whereby the European Commission will propose possible legal registration of vehicles running on CO2-neutral fuels following the year 2035. The Commission is set to assess the progress towards carbon-neutral road mobility in 2026, which will take into account technological developments and requirements.   

The regulation also states that manufacturers need to ensure that CO2 emissions of newly registered vehicles do not exceed their specific annual emissions target. Should they fail to comply, the manufacturer will have to pay a premium of 95 euros per CO2/km above the target per newly registered vehicle.    

To avoid ‘potential market distorting effects’ (pg. 23), emission reduction requirements for all Union market manufacturers should be aligned. However, the regulation includes a derogation for smaller manufacturers until the end of 2035. This derogation includes any manufacturers that produce under 1,000 new registered vehicles in a calendar year. Manufacturers producing between 1,000 to 10,000 passenger cars or 1,000 to 22,000 light commercial vehicles that are newly registered annually have the possibility of applying for a derogation from their specific emission targets from the 1st of January 2036 (pg. 23).   

A small step back into history – How the EU came to accept the ICE ban

On the 4th of November 2016, the Paris Agreement came into force under the United Nations Framework Convention on Climate Change (UNFCCC). All parties to the agreement promised to keep global temperatures below 2 degrees Celsius above pre-industrial levels. This commitment was altered to just 1.5 degrees Celsius during the Glasgow Climate Pact on the 13th of November 2021. The European Parliament called for climate neutrality by 2050 on the 15th of January 2020, with the European Green Deal setting measures and initiatives to achieve this. As part of this objective, Europe realised that it needed to decrease transport emissions which, in 2020 (compared to 1990 emissions levels), had increased by 7%.   

Europe’s reasons for the strengthened CO2 emissions reduction   

The stricter requirement for a reduction in CO2 emissions should encourage the increased deployment of zero-emission passenger cars and light commercial vehicles in the EU market, with a European Parliament report claiming this would strengthen energy security and efficiency, improve air quality, and aid innovation in the automotive sector. Passenger cars and light commercial vehicles, according to the European Council, account for 15% of EU CO2 emissions, showing that action is necessary and should be reflected in the ‘Fit for 55’ package.    

Regulation faces backlash

On the 27th of March 2023, statements from Italy, Poland, and Finland issuing concerns about the potential impacts of the new regulations were published by the Council of the European Union (CoEU).


Italy claimed that the automotive industry and transport sector should shift to green energy and low-emission technologies only if the targets remain in line with the principles of an ‘economically sustainable and socially fair transition’ (pg. 1). Although Italy expressed its support for the electrification of light vehicles, the country highlighted its preference for an alternative solution, claiming that combustion engines will remain on the market for low-income households and citizens. Furthermore, Italy stated the deployment of combustion engines running on renewable energy should ensure an immediate reduction in CO2 emissions and the push for electrification could threaten rejection on the EU market. According to EuroNews, Italy is home to big luxury car brands such as Fiat and Ferrari, which rely heavily on combustion engine vehicles, with around 270,000 people directly or indirectly employed in the country’s automotive industry. It is, therefore, no surprise Italy is concerned about economic and social factors regarding the new Regulation. Italy concluded that it will not support the new regulations and ultimately abstained in the final vote.


Poland was strong with its views on the then-proposed regulations, stating they firmly oppose the legislation act. The main argument Poland put forward was the strain these stricter CO2 emissions requirements could have on citizens, claiming it will increase the cost of access to fuels. Instead, Poland suggested the EU legislation should offer an incentive that would ultimately lead car manufacturers to offer zero-emission vehicles at the lowest prices possible. Ultimately, Poland declared that they opposed the act (pg. 4) and was the only country to vote against it. Poland’s Prime Minister later insisted that he would ‘do anything’ to stop the ban, even after the law had received final assent from the Council.

Finland’s statement stressed that while they agree with the aims of the Regulation, the Commission neglects to consider gas-fueled vehicles and called for the Commission to consider registering vehicles running on co2 neutral fuels even after 2035 (pg. 4).   


At the end of March, Bulgaria had joined opposition against the EU’s ban on combustion engines from 2035. With the high prices of electric cars, the low incomes of the population within the country, and the lack of infrastructure, the regulation would be an extremely difficult target for Bulgaria to achieve. With Bulgarians using cars for an average of 19 years, the likelihood that an uptake in electric vehicles as a result of the regulation is low.  


Germany was also opposed to the legislation, however, the automotive powerhouse has now reached a deal relating to the continued sales of carbon-neutral synthetic fuels (e-fuels) to run vehicles after 2035. The law will now allow combustion engine cars to be registered so long as they run on climate-neutral fuels such as e-fuels. However, to allow these ‘climate-neutral’ combustion cars to be registered, the Commission is creating a new category and will present a delegated act to define how such cars and vehicles can aid a green transition. Nonetheless, not all are supportive of this e-fuel compromise, with EU Climate Chief Frans Timmermans claiming he does not see any role for e-fuels in road transport.  


Infrastructure, mining, and recycling implications – how feasible is the new regulation?   

According to the European Parliament, this target is possible. Advancing technologies remain available for deployment and enable the satisfaction of the zero-emission target (pg. 10). Technological innovation is vital to decarbonise the automotive sector, and significant funding is available to ensure innovation in the mobility industry. Such funding and research include Horizon Europe, which is a Framework Programme for Research and Innovation, InvestEU, European Regional Development Funds, the Cohesion Fund, and the Innovation Fund (pg. 12). However, the Member States and the Union itself should continue to encourage and filter through public and private sector investments into European automotive innovation (pg. 12) Trade unions and NGOs alike have raised significant concerns around the availability of critical raw materials.

Are EV’s really better?   

In 2020, Greenpeace claimed that an electric car has about half the climate impact, over its entire lifetime, than the average passenger car. Furthermore, petrol engines supposedly only use around 12-30% of the energy in the fuel to run the vehicle, with over half being wasted as noise or heat. In comparison, electric motors use 77% of the energy, creating an efficiency gap so big that Poland saw around a 25% reduction in carbon emissions in electric cars that run on fossil fuels (coal-fired power stations) than a normal combustion engine vehicle.   


The European Parliament also stated that pollution from combustion engine road transport is more harmful than that of alternative travel because the emissions released during vehicle use occur close to the ground, which is often higher in urban areas. The deployment of EVs lessens the threat of GHG emission-related illnesses and could significantly reduce air pollution. This is because EVs emit no tailpipe CO2 emissions and have considerably lower NOX emissions than a normal combustion engine vehicle. It should be noted that tyre and brake wear still occur when driving EVs and should be counted when considering the sustainability of the vehicles. In all, EVs are often heavier due to the materials, size of batteries, and structure of the car, and this can lead to higher energy consumption.   


A major problem that is currently holding back the increased deployment and purchase of EVs is the perception the vehicles cannot cover the desired distances without needing to be charged. Considering the new Legislation may result in an influx of EV vehicles in the near future, poor infrastructure may prevent the EU from meeting its targets. In 2019, the European Parliament claimed that despite increasing EV charging stations across EU countries, it is still insufficient in some Member States.


For example, the current charging infrastructure in Bulgaria is still in its early stages, with around 205 charging stations in total, 58 of these located in the Sofia City Province. In addition, there are concerns from the public surrounding on-street parking where users will not be able to charge from plug sockets within homes meaning electric charging stations would have to be placed on walking paths, potentially creating crowded neighbourhoods. In 2021, the continent had an estimated 375,000 charging stations, but a 2022 analysis by McKinsey showed that the EU-27 will need at least 3.4 million operational charging stations by 2030. Therefore, extensive utility grid upgrades are required to enable the flow of electricity to new charging stations. Furthermore, McKinsey notes that this new charging infrastructure may cost upward of 240 billion euros by 2030.  


Nevertheless, the European auto industry has also shown considerable commitment to the decarbonisation of passenger vehicles and vans with more than 250 billion euros being filtered into electrification. 

In addition, Andreas Carlson, the Swedish Minister for Infrastructure and Housing stated, in a Press release on the 28th of March 2023, that ‘user-friendly recharging infrastructure and refuelling stations for alternative fuels, such as hydrogen, will be installed throughout the EU. This means that more public recharging capacity will be available on the streets in urban areas as well along the motorways. Citizens will no longer have a reason to feel anxious about finding charging and refuelling stations for their electric or fuel-cell car’. The alternative fuel infrastructure regulation (AFIR) will play an important role in ensuring sufficient infrastructure is in place for the zero- and low-emission vehicle regulation and ensuring it is not impeded.   


One important point to consider in the decarbonisation of the automotive industry is that most charging happens at home. In the second issue of the Green Mobility Magazine, it was stated that the European Commission estimated that private charging would make up 85% of charging activity by 2030 (pg. 31). Furthermore, Element Energy found that 65-75% of the UK’s heavy goods vehicles could productively operate with a heavy reliance on their own charging stations situated at their home depot. This just further shows the importance of action in the private charging infrastructure industries.   


In addition, the Energy Performance of Buildings Directive (EPBD) can help deliver the necessary private infrastructure to aid the EV rollout expected over the next decade. IEA reports Europe ranked second in the world for public charger availability, with China taking first place. Article 12 of the EPBD, for example, focuses on infrastructure for the electric automotive industry, with the main goal of promoting rollout to widen access to chargers further (pg. 31).  

Mining and recycling of batteries   

Despite the praise for electric vehicles due to the low levels of emissions emitted throughout their lifetime, we often fail to consider the manufacturing stage. In a report published by the European Parliament, the main greenhouse gas emissions reduction occurs in the use phase of the EV vehicle, and it was noted that EVs typically emit larger volumes of greenhouse gases in the manufacturing stage than combustion engines. However, EVs often offset these higher manufacturing emissions in the use phase and, when considered holistically, EVs do emit less emissions (pg. 6).   


While we have seen that EVs do not emit CO2, lithium-ion batteries are made from raw metals such as cobalt and nickel which need to be either mined or maintained through the recycling of old components. According to the latest issue of the Green Mobility Magazine, lead and lithium will remain the dominant technologies through 2030. Mining can raise many environmental concerns, releasing emissions and causing damage to the ecosystem. Furthermore, with these metals facing a global shortage, with the introduction of the new Regulation, deep-sea mining (DSM) has been proposed as an alternative. Deep-sea mining could help provide the metals to manufacture lithium batteries and support a green transition.

While mining holds ethical concerns, such as human right violation, deep-sea mining lacks the knowledge and equipment currently to be done sustainably. Impacts to the marine ecosystem from this type of mining are currently unknown, as knowledge learnt from terrestrial mines most likely cannot be applied. Nevertheless, recycling metals from previous batteries could be an alternative solution to both terrestrial and deep-sea mining.   


One problem with electric vehicles is the recycling of batteries. While nearly 99% of lead batteries are recycled, according to a 2019 source, few lithium-ion batteries are (could be around 5%). In some cases, it is still less expensive to mine than it is to recycle.   


However, national research funders have founded centres that will help us to better understand how to recycle EV batteries better. Furthermore, Glencore (a Switzerland-based company) plans Europe’s biggest electric car battery recycling plant in Italy by 2027. This would give the company a leading role in battery recycling. The plant should hold the capacity to process up to 50,000 to 70,000 tonnes of black mass (shredded batteries) which is enough to recycle batteries from 600,000 EVs. This black mass would then undergo hydrometallurgical processes in order to extract raw materials.  


EU legislators have proposed that electric batteries must hold a certain threshold of recycled raw materials from 2030, including 20% recycled cobalt, 10% recycled lithium, and 12% for nickel five years later.

Collaboration within the automotive industry  

Planning for the decarbonization of the automotive industry requires close collaboration, particularly between different actors in the energy, infrastructure, and transport sectors. Within Germany, Berlin authorities undertook a study called ‘Elektromobilitat Berlin 2025’ which highlighted the charging infrastructure needs based on projections from traffic and parking patterns and needs. This included needs for inhabitants, tourists and visitors, and commuters. From here, planners were able to predict charging point needs by 2040. In addition, the present political and planning regulatory framework determined effective innovations to roll out such infrastructure to optimize the transition to sustainable development.  


Similarly, Stockholm, in Sweden, developed planning tools to increase EV rollout. The BABLE Platform, a planning map for public charging points, allows third parties, such as manufacturers and installers, to choose their location of interest. This not only allows security but also increases effective communication by presenting clear planning tools for building EV charging infrastructure.   

With a focus on the collaboration of actors, Rome, Italy, welcomed public opinion and encouraged inhabitants to choose their preferred location for charging points within zones already flagged for potential infrastructure. According to RAP, by March 2023, the platform had been used by over 1,150 people, with at least half considering a switch to EV.  

Discover the new Green Mobility Directory.

To conclude   

The transition to zero-carbon automotive mobility is looking promising. With the ambitious goal to reduce carbon emissions for passenger cars and light commercial vehicles, it is clear sufficient funding, planning, and collaboration are needed to ensure the target can be achieved. Actors in the transport industry will need to ensure that the manufacturing stage and recycling stages of EVs are as sustainable as possible. With plans to improve the recycling of batteries for electric vehicles and the improvement of infrastructure, the roll-out of EVs is possible. The most important part of such plans is the implementation stage. Actors must stay on track and deliver on promises of plans and funding.