T&E analyses the impact of the European Commission’s proposal on future electric car sales and CO₂ emissions.
Summary:
On December 16 2025, the European Commission published the proposal for the revision of the EU’s car CO2 emission regulation. T&E has analysed the impact of the proposed policy changes in terms of battery electric vehicle (BEV) sales and CO2 emissions:
• The weakening of the 2035 CO2 reduction target from 100% to 90% is expected to reduce the share of BEVs by 15%, down to 85% instead of 100%. However, the proposal also introduces high uncertainty as BEV sales would fall between 50% and 95%, depending on the powertrain mix strategy adopted.
• The 2030 target would be weakened by a 3 year averaging (2030-2032) of the target with super-credits given to small BEVs made in Europe. This implies a 10 percentage point reduction in BEV share in 2030: from 57% to 47%.
• Based on the proposal, cars would emit an additional 720 million tons of CO2 (MtCO₂e) between 2025 and 2050 — 10% more than under the current regulatory scenario.
Recommendations: see T&E’s position paper on the revision of the car CO2 regulation.
The fuel crediting system and the 3-year averaging are the most damaging flexibilities and should be cancelled. T&E recommends improving the design of the low-carbon steel credits and super-credits system to reward actual progress towards low-carbon steel and allocate bonus to the most affordable models. (....)