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Single Article - The Association of European Vehicle Logistics
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Position paper – Eurovignette: ACEA comments to the 2nd amendment

Position paper – Eurovignette: ACEA comments to the 2nd amendment

ACEA — 2026-03-17

News from Brussels

The introduction of CO2-based road charges with full exemptions for zero-emission vehicles (ZEVs) is one of the most effective and targeted levers to accelerate the transition to zero-emission trucks and buses.

The European Automobile Manufacturers’ Association (ACEA) welcomes the Eurovignette Directive as it provides a common EU framework for CO2-differentiated charging, but its impact remains limited because implementation across Member States is slow, uneven, and inconsistent.

In this position paper, the European commercial vehicle manufacturers highlight key issues and showcase some recommendations for the Eurovignette Directive to become a real tool for the European transport decarbonisation.

  1. Full and timely implementation by all Member States
    The absence of strong, harmonised CO2‑differentiated road charges across Member States limits the uptake of zero‑emission vehicles and reduces the effectiveness of the EU’s transport policy.
  2. Reference values are too low to generate strong demand for zero-emission vehicles
    Because the Directive’s current reference values fail to make zero‑emission vehicles financially compelling, they must be raised so that these vehicles can achieve cost parity within a viable payback period.
  3. Interaction with ETS2 and the “double taxation” concern
    Claims of “double taxation” do not hold because the combined price signal from Eurovignette charges and ETS2 remains too weak to drive the shift to zero‑emission vehicles, making a stronger CO2‑based differentiation in the Eurovignette both justified and necessary.
  4. Use of revenues to support the ZEV transition
    Revenues from CO2‑based road charges should be reinvested in measures that directly accelerate zero‑emission vehicle uptake, such as charging and refuelling infrastructure and fleet‑renewal support.
  5. Alignment with the HDV CO2 Regulation
    Maintaining alignment between the Eurovignette Directive and the HDV CO2 Regulation is essential, as introducing a well‑to‑wheel approach in one while the other remains tank‑to‑wheel would create regulatory inconsistencies.
  6. Adjustment of the emissions trajectory
    The Commission’s proposal to maintain the trajectory at a -30% level beyond 2030 would benefit from better alignment with the Eurovignette’s underlying policy objectives. The pathway should therefore be recalibrated to reflect market developments and the increasing stringency of the HDV CO2 targets towards 2035 and 2040, while respecting the maximum achievable CO2 reduction potential of all low- and zero-emission technologies.


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