EU Proposes Revisions to the Post 2020 Average CO2 Monitoring Requirements for Light Duty Vehicles
Although the Worldwide Harmonised Light Duty Vehicle Test Procedure (WLTP) was first mandated for new types of passenger car from September 1, 2017, currently, it is still CO2 emissions data based on the New European Drive Cycle (NEDC) that is being used to determine vehicle manufacturer's compliance with the average CO2 emissions targets specified by EU Regulation 2019/631. However, this will change from January 1, 2021, when WLTP based average CO2 emissions targets will be implemented.
The requirements for the transition from NEDC based average CO2 emissions targets to WLTP based average CO2 emissions targets were already specified within (EU) 2019/631. However, on August 4, 2020, the European Commission published a draft amendment to (EU) 2019/631 which proposes some revisions to its requirements to further facilitate the transition to WLTP based average CO2 emissions targets.
(EU) 2019/631 specifies that, for each vehicle manufacturer, their average CO2 emissions target for 2021 and beyond will be based on their actual average CO2 emissions performance during 2020. Whilst the provisions prescribed in (EU) 2019/631 adequately cover the majority of vehicle manufacturers, they do not currently cater for vehicle manufacturers that did not sell or register any vehicles in the European Union during 2020 (i.e. vehicle manufacturers that will only begin marketing vehicles in the EU after January 1, 2021) or for vehicle manufacturers that only sold and registered zero CO2 emissions vehicles in the European Union during 2020. Therefore, the draft Regulation proposes new provisions to accommodate vehicle manufacturers falling into either of these categories.
The draft Amending Regulation also proposes some revisions to the data that must be recorded by Member States and reported to the European Commission for 2021 and beyond. The purpose of these proposed revisions are as follows:
- To remove any references to NEDC specific data.
- To ensure that all relevant WLTP specific data is recorded.
- To require that both CO2 emissions and fuel / energy consumption figures are recorded.
- To more closely align the data to be recorded for light commercial vehicles with that recorded for passenger cars.