Within the European Union, heavy duty vehicle manufacturers are legally required to comply with average CO2 emissions performance reduction targets for the new heavy duty vehicles (e.g. trucks, buses and coaches) that they supply to the EU market. The regulatory requirements which specify these CO2 emissions reduction targets for new heavy duty vehicles are contained within (EU) 2019/1242 on CO2 performance standards for new heavy duty vehicles, and within its Implementing Regulations. The CO2 emissions performance standards/reduction targets specified within this EU Regulation are based on individual vehicle CO2 emissions figures which are determined in accordance with EC Regulation No. 595/2009 on emissions from heavy duty vehicles and, more specifically, in accordance with Implementing Regulation (EU) 2017/2400 on the determination of the CO2 emissions and fuel consumption of heavy duty vehicles.
To allow the European Commission to monitor and assess the real world representativeness of the CO2 and energy consumption values determined in accordance with (EC) No. 595/2009 and (EU) 2017/2400, (EU) 2019/1242 amended (EC) No. 595/2009 to require the mandatory fitment of Onboard Fuel Consumption Measuring (OBFCM) devices to new heavy duty vehicles to determine and store the real world fuel and energy consumption of the vehicle throughout its life. Also, Article 12 of (EU) 2019/1242 specifies that the European Commission must regularly collect data on the real world CO2 emissions and energy consumption of heavy duty vehicles in service for the purposes of assessing the real world representativeness of the CO2 emissions and energy consumption values determined in accordance with (EC) No. 595/2009 and (EU) 2017/2400.
To implement the mandatory fitment of OBFCM devices to new heavy duty vehicles, EU Implementing Regulation (EU) 2025/2161 on the technical requirements of onboard devices for the monitoring and recording of fuel and energy consumption and mileage of certain heavy duty vehicles, and for determining and recording the payload or total weight thereof was published on October 31, 2025. To comply with the requirements of this Regulation, from July 1, 2027, most newly registered heavy duty vehicles will be required to be fitted with an OBFCM complying with the technical requirements of this Regulation.
To implement the data collection provisions specified in Article 12 of (EU) 2019/1242, on April 20, 2026, the European Commission published a draft new Implementing Regulation on the detailed procedure for collecting real world data relating to CO2 emissions from heavy duty vehicles for public comment on their ‘Better Regulation’ web site.
This draft Implementing Regulation, referred to as Ares(2026)3995778, specifies that, from January 1, 2028, the Authorities or entities responsible for carrying out roadworthiness testing in each EU Member State must collect the following data for each heavy duty vehicle fitted with an OBFCM device when it is presented for roadworthiness testing:
- The real world fuel/energy consumption data from the OBFCM device
- The vehicle’s Vehicle Identification Number (VIN)
- The vehicle’s odometer reading
- The date of the roadworthiness test
Member States must then collate all of the data collected within their country and, by November 30, each year, submit this data to the European Commission via electronic data transfer to the European Environment Agency, using electronic tools and procedural guidance provided by the European Commission and the European Environment Agency.
The draft Regulation also includes guidance on compliance with the EU General Data Protection Regulation for the bodies responsible for collecting and processing this data, due to the fact that, in certain circumstances, the vehicle’s VIN can be classified as ‘personal data’.