Position paper – Heavy-duty vehicle LCA methodology

Position paper – Heavy-duty vehicle LCA methodology

ACEA — 2025-07-08

News from Brussels

Life cycle assessment (LCA) is a key tool for evaluating the environmental impacts of vehicles and supports the extension of harmonisation efforts on national and international level to heavy-duty vehicles (HDVs). However, the application of LCA methodologies to HDVs present significant limitations that hinder its effectiveness as a potential regulatory tool.

The European Automobile Manufacturers’ Association (ACEA) firmly advises against using LCA methodology for HDV regulatory CO2 target setting for 2040. Instead, it recommends focusing on direct CO2 reduction measures, technology-neutral strategies, and avoiding redundant legislation that adds complexity without delivering substantial environmental benefits.

This position paper outlines the ACEA’s response to the European Commission’s assessment under EU Regulation 2024/1610 Article 15(l), which explores the development of a common EU methodology for assessing and reporting full life-cycle CO2 emissions of HDVs.

ACEA’s key recommendations include:

1. Promoting direct emission reduction strategies and targeted, non-redundant legislation to avoid high efforts for very limited environmental benefits
2. Focusing on battery LCA decarbonisation already covered by the EU Battery Regulation
3. Rejecting a one-size-fits-all approach as the application of LCA to HDVs is inherently more complex than for light-duty vehicles (LDVs)
4. Supporting the UNECE A-LCA guidelines to promote global harmonisation

Read the paper here.