Parliament and Council have amended the HDV CO2 Regulation to allow truck manufacturers to generate more emission credits between 2025 and 2029 than the existing framework permitted. The 2030 targets remain unchanged; what changes is how credit accumulation is calculated in the years leading up to them
Regulation (EU) 2026/1046, adopted on 29 April 2026, amends Regulation (EU) 2019/1242, which sets legally binding CO2 emissions reduction targets for new heavy-duty vehicles. The amendment does not touch the 2030 targets themselves (a 45% reduction in average CO2 emissions for new trucks against the 2019 baseline) but it changes the formula used to calculate emission credits in the five reporting years between 2025 and 2029. The change is narrow in scope but directly relevant to manufacturers’ compliance strategies.
Under the existing framework, emission credits are generated when a manufacturer’s average specific CO2 emissions fall below the CO2 emissions reduction trajectory, a mathematical path connecting today’s baseline to the 2030 target. The amendment replaces that reference point for the 2025–2029 period with a different benchmark: the specific CO2 emissions target for the 2025 reporting period. In practice, the 2025 target is more lenient than the trajectory for the same years, meaning a manufacturer performing at the same absolute emissions level will generate more credits under the new formula than under the old one. Those additional credits can be carried forward and offset against potential shortfalls as the 2030 deadline approaches.
The stated rationale is the slow rollout of public fast-charging infrastructure along European motorways for heavy-duty vehicles. The 2019 regulation was premised on charging infrastructure being sufficiently available by the mid-2020s to support a viable market for zero-emission trucks. That infrastructure has not materialised on the anticipated timeline. Manufacturers argue (and the co-legislators have accepted) that this creates a genuine market barrier to the early deployment of battery-electric and hydrogen long-haul trucks, and that the credit calculation mechanism should reflect this reality without softening the end-point.
The amendment explicitly carves out urban buses from its scope. The recitals note that the deployment of zero-emission urban buses is already advanced and is not affected by the charging infrastructure gap that constrains long-haul freight. Urban bus manufacturers therefore remain on the original trajectory-based credit calculation for all reporting periods. The regulation enters into force on the twentieth day following publication — 27 May 2026 — and applies with immediate effect to the 2025 reporting year already underway.
For fleet operators, the practical effect of this regulation is indirect but real: manufacturers who accumulate more credits in 2025–2029 face reduced pressure to push zero-emission truck prices below cost or restrict supply to non-compliant configurations in the approach to 2030. For compliance professionals tracking the HDV regulation, the change in Annex I introduces two new algebraic expressions, ET2025(NO)Y and ET2025(M)Y, defining the alternative trajectory benchmarks for non-urban and motorised vehicle categories respectively. These replace the generic ET(NO)Y and ET(M)Y terms in the credit calculation table for the 2025–2029 window only.
