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27 May 2021

Call to include a voluntary crediting system for sustainable renewable fuels into the vehicle CO2 regulations

Together with 223 associations, companies and scientists, we have signed a joint letter to the European Commission: 'Call to include a voluntary crediting system for sustainable renewable fuels into the vehicle CO2 regulations'


To the attention of:
Executive Vice-President Frans Timmermans
Commissioner for Transport Adina-Ioana Vălean
Commissioner for Energy Kadri Simson
Commissioner for Internal Market Thierry Breton
Director General Mauro Petriccione
Director General Henrik Hololei
Director General Ditte Juul Jørgensen
Director General Kerstin Jorna
Brussels, 26 May 2021

Call to include a voluntary crediting system for sustainable renewable fuels into the vehicle CO2 regulations

Dear Madam or Sir,

The 223 signing associations, companies and scientists of this letter fully support the EU’s target to be climate-neutral by 2050 and recognise the major role that the transport sector has to play in this regard. However, the current approach focusing only on tailpipe emissions from new vehicles falls short of ensuring the transition towards climate neutral mobility. In view of the ongoing preparation for the Fit for 55 package, we would therefore like to emphasise the need for a sustainable renewable fuels dimension in the revised CO2 standards for cars and vans regulation and for the next step revision for the HDV sector. The EU’s overall climate goals can be achieved faster and with greater certainty using sustainable renewable fuels as an additional path to reduce CO2 emissions from the EU vehicle fleet.

The results of the related EU stakeholder consultation demonstrate that a large number of respondents are in favour of a mechanism that takes into account the contribution of sustainable renewable fuels in the future CO2 fleet regulation. With more than 1,000 responses to the question: “A mechanism should be introduced in the CO2 emission standards for cars and vans so that compliance assessment for each manufacturer takes into account the contribution of renewable and low carbon fuels”, approximately 70% responded that this option is of “high importance”. (1)

Based on two studies (2), Frontier Economics proposes a voluntary crediting system that would allow automotive manufacturers (OEMs) to partially benefit from the use of sustainable renewable fuels for compliance with their targets (for the integrity of the system, Frontier Economics suggests capping the volumes of sustainable renewable fuels that OEMs can have credited against their fleet targets).

Only sustainable renewable fuels additional to the volumes mandated under the Renewable Energy Directive and fulfilling its sustainability criteria would qualify for such a crediting system. In doing so, the system would avoid the double counting of OEMs’ and fuel suppliers’ CO2 emission reduction efforts, with each of them having clearly defined responsibilities.

A voluntary crediting system would also send timely investment signals for fuel suppliers to embark on the volume production of sustainable renewable fuels, which are much needed for the decarbonisation of legacy vehicles as well as other transport modes, such as shipping and aviation. As a result, CO2 emissions from transport would be lowered along the value chain from well to wheel.

We, the signatories, would like to stress that sustainable renewable fuels are meant to complement and not lessen the EU’s efforts on electrification during the transition to zero-emission mobility and for as long as favourable conditions for battery electric and hydrogen mobility are not fully in place across all of the EU Member States (e.g. in terms of consumer acceptance, charging and refuelling infrastructure or the GHG intensity of the electricity mix). Sustainable renewable fuels are a long-lasting bridge that will enable the transition from conventional vehicles to zero-emission (tailpipe) mobility and freight transport. A voluntary crediting system would represent a safety net for the massive transformations that companies in transport are already undergoing towards net-zero emission mobility.

In case there are any questions regarding the exact design (3) of a voluntary crediting system, we would be happy to discuss with you the details of such a system in more depth and we remain at your disposal for any feedback or questions.

With kind regards,
The signees

This letter was also sent to respective Head of Cabinets and relevant Cabinet Members as well as to respective Directors, Head of Units and Policy officials in Directorate-Generals for Climate Action (DG CLIMA), Mobility and Transport (DG MOVE), Energy (DG ENERGY) and Internal Market, Industry, Entrepreneurship and SMEs (DG GROW). The letter will also be forwarded to Chairs and Vice Chairs of the committees of the European Parliament (TRAN, ITRE, ENVI, ECON, AGRI).


Download this joint letter as pdf here

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2 Frontier Economics “Crediting system for renewable fuels in EU emission standards for road transport - Report for the German Federal Ministry for Economic Affairs and Energy (BMWi)” (, and Frontier Economics “Crediting system for renewable fuels: functionality & benefits - Report prepared for Neste” ( com/media/4347/crediting-system-for-renewable-fuels.pdf)

3 Frontier Economics report’s amendment proposals from page 56 onwards: crediting-systems-for-renewable-fuels-in-eu-emission-standards-for-road-transport-en.pdf