The European automotive industry is calling for a series of exemptions to the EU’s car CO₂ regulation that could significantly reduce the bloc’s ambition to sell only zero-emission vehicles by 2035, according to analysis by campaign group Transport & Environment (T&E) of a leaked position paper from the European Automobile Manufacturers’ Association (ACEA).

The document reportedly outlines more than ten proposed loopholes, including provisions to count vehicles powered by so-called carbon-neutral fuels as zero-emission. It also calls on the European Commission to suspend work to update how emissions from plug-in hybrid vehicles are measured.

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According to T&E, ACEA’s proposals would have a cumulative impact that effectively lowers the required market share of electric vehicles (EVs) to 52% in 2035. The group’s analysis suggests that counting cars using e-fuels or biofuels as zero-emission could reduce EV sales by around a quarter.

ACEA is also said to support removing the 2027 “utility factor” for plug-in hybrids, which determines how much of their mileage is powered by electricity. This change, T&E claims, would lower electric car sales by 10%. Other measures, such as granting CO₂ credits for scrapping older vehicles or for emissions reductions in production processes, could further reduce the ambition of the regulation.

Lucien Mathieu, cars director at T&E, said the proposals would “undermine the investment certainty” needed for Europe’s transition to EVs, describing the approach as a “cynical attempt to dismantle a central pillar of Europe’s climate law.”

ACEA’s position comes as the European Commission prepares to review the car CO₂ legislation. Commission president Ursula von der Leyen has indicated that a legislative proposal is expected by the end of 2025.

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Mathieu added that manufacturers were “calling for a drastic acceleration of the review” but “asking for a shopping list of flexibilities and loopholes” without allowing sufficient time for evaluation.

Neither ACEA nor the European Commission has yet publicly commented on the leaked document.