Clean Mobility Package




RED II Implementing Rules for voluntary schemes – Union Database

Feedback on the EU CO2 emissions performance standards for cars and vans

Feedback reference F2750854
Submitted on 8 November 2021
Submitted by Mariam ED-DBALI
User type Business association
Organisation Gas Distributors for Sustainability
Organisation size Large (250 or more)
Transparency register number 382692732615-35
Country of origin Belgium
Initiative CO2 emissions for cars and vans – revision of performance standards


Gas Distributors for Sustainability (GS4S) welcomes the European Commission's proposal to facilitate the decarbonisation of the transport sector.

We firmly believe in the principle of technology neutrality; therefore, we are not in agreement with the Commission's approach which effectively limits new vehicles to technology which meets the requirement of Zero Emission Vehicles (ZEV). While GD4S fully recognises the considerable benefits such technologies offer, provided that the energy used in their production and use is renewable or low-carbon, our concern is that this singles out the technology to be promoted. Furthermore, this exhaust-oriented approach is not aligned with other EU legislation supporting de-fossilisation, namely RED and ETD and technology neutrality.

In order to re-establish the subsidiarity principle, allowing the Member States to decide on their energy mix (as long as the required emissions’ savings are reached), and with a view to attaining the EU’s objective to decrease transport sector emissions, GD4S proposes the opportunity to use available, sustainable solutions to accelerate and optimize the total decarbonisation of EU mobility. GD4S firmly believes that a holistic approach, leveraging the benefits of all decarbonisation solutions, should be put in place, as a priority. The EC’s proposal potentially increases the risk for ongoing projects based on low emissions urban zones, or in rural areas where BioNGV appears as the best option to consumers and municipalities willing to commit to immediate climate change actions. Biomethane and e-methane can be used as a renewable fuel, helping achieve zero or even negative levels of CO2 emissions. It also supports the development of local circular economies because it can be generated using locally produced organic residues and waste streams. A mature technology, available throughout Europe, biomethane production levels can be easily upscaled to ensure ample future supply and to enable a higher incorporation of those fuels in the mix. Finally, biomethane is among the most affordable advanced biofuels, while compressed natural gas (CNG) vehicles offer citizens with low- and middle-income access to low-carbon mobility.

GD4S calls on EU institutions to consider our recommendations:

1. Harmonise the approach to CO2 emissions in all EU transport policies by switching from a tank-to-wheel (TtW) approach to a more comprehensive and science-based Well-to-Wheel (WtW) approach, as the EC assessed in the FuelEU for Maritime proposal.

2. Recognise the emissions’ reduction of biomethane mobility within the CO2 standards. If no crediting scheme or a carbon correction factor is to be introduced, as indicated in the EC’s assessment, manufacturers of the most efficient NGV vehicles – able to reach emissions savings beyond zero, i.e. negative emissions mobility – should receive derogations in line with the Article 10. This should be introduced at least in those Member States that define a clear decarbonisation path and commit to a minimum 40% share of renewable gas in the transport mix by 2030.

3. Replace fossil fuels with advanced biofuels by encouraging a growing share of sustainably produced biofuels and renewable gases in mobility fuel use, as assessed in RED.

Several Member States’ gas distributors call for further investment in the NGV/BioNGV mobility in order to help them reach climate targets. European institutions should neither preclude sales of new NGV vehicles, nor undermine investments from vehicles manufacturers in cost-effective and available solutions that can reach cleaner mobility than any electric or fuel cell vehicle. The current approach of the European Commission would also create an excessive dependence on a single technology accompanied by high risks: the need to produce and recycle an enormous quantity of batteries, without full clarity on its impact on environment, costs, and European industry.

Feedback on the EU Alternative Fuels Infrastructure Regulation Directive

Feedback reference F2750921
Submitted on 8 November 2021
Submitted by Mariam ED-DBALI
User type Business association
Organisation Gas Distributors for Sustainability
Organisation size Large (250 or more)
Transparency register number 382692732615-35
Country of origin Belgium
Initiative Low-emission vehicles – improving the EU’s refuelling/recharging infrastructure


Gas Distributors for Sustainability (GD4S) welcomes the European Commission's proposal to invest in infrastructure to facilitate the decarbonisation of transport and deliver on energy transition objectives. GD4S believes that a technology-neutral approach is essential in the context of designing infrastructure models, adapted to a decarbonised energy system.

In recent years, incentives have been focused predominantly on electricity in preference to other clean alternative fuels. There is a diverse range of clean fuel options in Europe, such as bio-LNG and bio-CNG, which may be exploited, and which can also contribute to achieving the zero CO2 emissions’ targets in the energy mix. In addition, our view is that the Commission's tailpipe analysis approach may potentially lead to inaccurate measurements, thereby jeopardising the EU's objective of reducing emissions from the transport sector and moving away from third country dependency.

GD4S strongly advocates for an approach based on life-cycle assessment (LCA) to ensure a technology neutral approach based on a holistic analysis of the carbon footprint of vehicles and GHG emissions, from well-to-tank and during the production and recycling phase. Several studies show this approach is the most accurate, and most beneficial to the climate and to a cost-effective transition (IFPEN, Carbone 4, and JRC).

Biomethane (and e-methane) can be used as renewable fuels, helping achieve zero or even negative levels of CO2 emissions. It also enables the development of local circular economies because it can be generated using locally produced organic residues and waste streams. A mature technology across Europe, biomethane production can be easily upscaled to ensure ample future supply. At present, the compressed natural gas (CNG) network is only concentrated in a few Member States, even as the ambition is to increase the uptake of alternative fuels in the EU as a whole. GD4S believes that a sufficient level of support should be implemented, to include the period from 2025 onwards, to help all Member States achieve the decarbonisation of their transport sector. Introducing more ambitious targets, to send robust investment signals to stakeholders would also be welcome.

CNG and LNG are also valid options for non-electrified railroads still relying on more polluting fuels such as diesel or fuel oil. Some of these lines cannot be reasonably electrified. CNG/LNG would unlock significant GHG emissions savings and pave the way to higher renewable incorporation and decarbonisation.

In essence, investments in CNG and LNG infrastructure are future-proofed since they enable the deployment of decarbonised energy over time, when compressed biomethane and bio-LNG are used, in the same way that electric vehicles initially source their electricity from a carbon-emitting generation plants. Additionally, CNG and biomethane are among the most affordable fuels. Encouraging their adoption would pave the way for a more socially inclusive decarbonisation of transport.

The energy mix is a necessary for future infrastructure deployment. In many Member States, electricity supply is still predominantly generated by fossil fuel and has a very high carbon footprint, while the transport gas mix in several Member States, including in the Nordic countries and the Netherlands, is close to 100% renewable. Taking all these criteria into account, in the Article 2 (Definitions) of the proposal, “Alternative Fuels for Zero-Emission Vehicles” should be removed and replaced by a sub-definition dedicated to low carbon fuels, ideally taking into account lifecycle considerations.

contact GD4S.eu
66, Avenue de Cortenbergh
B-1000 Bruxelles
+ 32 2 280 39 94

contact GD4S.eu
66, Avenue de Cortenbergh
B-1000 Bruxelles
+ 32 2 280 39 94

contact GD4S.eu
66, Avenue de Cortenbergh
B-1000 Bruxelles
+ 32 2 280 39 94