The EU’s CO₂ fleet regulation is based on the CO₂ emissions measured during driving for new passenger cars and light commercial vehicles. Battery-electric vehicles produce no CO₂ exhaust emissions in this context. This does not classify them as climate-neutral over their entire life cycle.
On 1 September 2026, the CirculaTUM research network at the Technical University of Munich presented a white paper entitled “Defossilisation, Not Decarbonisation”. In it, the researchers advocate giving greater consideration to the vehicle life cycle in regulation. The assessment of existing regulation represents the study authors’ position.
Distinguishing life cycle assessment from exhaust measurement
A life cycle assessment includes factors such as raw material extraction, vehicle manufacturing, energy supply, use and recycling. Measuring CO₂ exhaust emissions covers a different part of the picture. Results from these two approaches must therefore not be treated as equivalent.
In the eFuels Forum’s view, propulsion systems and fuels should be assessed using transparent, comparable criteria. For eFuels too, the greenhouse gas balance must be determined on the basis of electricity and CO₂ sources, production, transport and use. This does not establish blanket environmental superiority.
Sources: TUM announcement of 1 September 2026 on the white paper; European Commission: CO₂ emission standards for cars and vans.
