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Which Way to Turn: Navigating a Route to Net Zero
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18.11.2025
Matthias Maedge

Which Way to Turn: Navigating a Route to Net Zero

Understanding the forces shaping the decarbonisation of commercial road transport – and the support available to manage the transition

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Eurowag recently ran a survey of its commercial road transport (CRT) customers from across Europe, which explored the main barriers and motivators affecting the decarbonisation of the sector. Two of the main findings were that our customers:

  1. see decarbonisation as a top priority
  2. understand that decarbonisation is essential to future-proofing their business

We know that these views often reflect the pressure that CRT companies are facing from their own customers – who are pushing them to deliver emissions savings. In many cases, this is being driven by the Corporate Sustainability Reporting Directive (CSRD), which requires larger shippers and transport buyers to report indirect emissions in the value chain (Scope 3). This, in turn, leads to pressure on CRT companies to reduce their own direct (Scope 1) emissions as they rely predominantly on road transport services for combined transport and inland freight movements. 

Eurowag cares passionately about this issue. We are firmly committed to the decarbonisation of the sector – because it’s necessary for the health of the planet – and have taken a role in leading that change. At the same time, we are equally committed to safeguarding the long-term competitiveness of our customers and ensuring a thriving CRT sector – without which no modern economy can survive.

From talking to our customers every day, we also know two other important things:

First, the regulatory context is confusing for many CRT companies. And second, the barriers to shifting to lower emission vehicles and fuels are daunting for companies already under pressure and operating on tight margins.

This blog is designed to address both of these points – it will:

  1. Provide an overview of the regulatory environment at European level, explaining what is coming, and when.
  2. Outline how Eurowag can help CRT companies manage the decarbonisation transition in a way that safeguards their long-term competitiveness, mitigates risk, and creates business opportunities. 

What are the most important pieces of European legislation driving the decarbonisation of commercial road transport? And is it having the required impact?

One of the challenges for our entire sector is that there are several pieces of European legislation which are shaping the operating environment when it comes to decarbonisation. Here are the most important: 

Box: The key pieces of European legislation driving CRT decarbonisation

  1. Revised CO₂ Emission Standards for Heavy-Duty Vehicles 
  • Status: Adopted and published in May 2024 (Regulation (EU) 2024/1610)
  • What it does: Sets tighter CO₂ reduction targets for new heavy-duty vehicles (HDVs):
  • 45% reduction by 2030
  • 65% by 2035
  • 90% by 2040
  1. Alternative Fuels Infrastructure Regulation (AFIR)
  • Status: Adopted and published in September 2023 (Regulation (EU) 2023/1804
  • What it does: Mandates minimum electric vehicle and hydrogen refuelling infrastructure across the EU:
  • Electric charging for trucks: At least every 120 60 km on core TEN-T corridors (and every 100km on the comprehensive network) by 2030
  • Hydrogen refuelling stations: At least every 200 km by 2030
  1. Renewable Energy Directive III (RED III)
  • Status: Adopted and published in October 2023 (Directive (EU) 2023/2413)
  • What it does: Member states can either opt for a target of 14.5% greenhouse gas emissions intensity reduction in the transport sector by 2030, or for a share of at least 29% of renewables (mainly electricity) within the final consumption of energy in the sector by the same date. It also introduces a combined sub-target of 5.5% for advanced biofuels, including liquid or gaseous fuels produced from municipal waste, manure, used cooking oils, etc., and renewable fuels of non-biological origin (RFNBOs), within which at least 1% must be explicitly RFNBOs (green hydrogen, e-fuels).
  1. Emissions Trading System (ETS2) for Road Transport
  • Status: Adopted and published in May 2024 (Directive (EU) 2023/959); it comes into effect in 2027
  • What it does: Introduces carbon pricing for fuels used in road transport, including HDVs; the aim is to incentivise low-emission alternatives by making diesel more expensive
  1. Euro 7 Emissions Standards 
  1. Greening Corporate Fleets initiative
  • Status: In February 2024, the European Commission opened a public consultation on the Greening Corporate Fleets initiative, which considered which mechanisms should be used to facilitate a transition to zero-emission vehicles, including mandatory targets and incentives. A legislative proposal from the Commission is expected by the end of 2025. 
  • What it will do: It is currently unclear whether mandates or incentives will be adopted in the legislation
  1. CountEmissions EU
  • Status: In July 2023, the European Commission tabled a legislative proposal (COM(2023) 441 final – known as ‘CountEmissions EU’) on an EU framework for the harmonised calculation and reporting of transport and logistics emissions. In July 2025, negotiators from the European Parliament, the Council of the EU and the European Commission opened discussions around the proposal. 
  • What it will do: The proposed regulation uses a ‘well-to-wheel’ approach for measuring emissions and prioritises the use of primary energy data

This provokes two related questions: Is this legislation having the required impact? Are we on track to hit the targets that are being pursued at European level?

The short answer to both of these questions is ‘no.’

In May 2025, the European Commission published a Communication on the “technological and market readiness of heavy-duty road transport vehicles” (COM/2025/260 final). 

It was a useful – if less than encouraging – snapshot of where we currently stand in terms of the transition to zero-emission vehicles in the CRT sector. It revealed that, in 2024:

  • The zero-emission fleet registered in the EU consisted of more than 15,000 eTrucks and 170 hydrogen lorries (approximately 0.25% of the total truck fleet)
  • More than 7,500 eTrucks were newly registered in 2024, accounting for 2.3% of all registrations

This therefore indicates growth – significant growth compared to previous years – but the share of zero-emission trucks remains extremely small.

The available data underlines the current state of play. Road freight volumes have grown by 20% over the last 15 years, while greenhouse gas emissions have also grown – but more slowly. We’re making some progress, but not enough:

However, truck manufacturers are bullish about the expansion of the zero-emission segment. They told the European Commission that approximately one in three new heavy-duty vehicles could be expected to be zero-emission by 2030 – taking the zero-emission vehicle fleet to 410,000-600,000 vehicles (5-9% of the HDV fleet). However, in a recent letter to European Commission President Ursula von der Leyen, they start to raise doubts and called for “correcting the course”. 

Even the Commission is sceptical about those estimates. The Communication said this: “Even though prices of zero-emission heavy-duty vehicles are expected to fall in the coming years and the TCO [Total Cost of Ownership] will become significantly more favourable, this would be a sharp market increase in a very short period of time in a market characterised by small profit margins and many SME operators with limited capital to invest and a very small share of zero-emission vehicles in 2025.”

At Eurowag, our view is that the Commission is right to be sceptical about the expected market projections, but they reflect the pressure the OEMs are under to drive the transition. And even if they are over-estimates, there is no doubt that change is coming – and coming quickly.

What is preventing CRT companies from transitioning to one of the available alternative fuels? Do policy-makers understand these barriers?

Eurowag has more than 30,000 road transport companies as active customers, so it is our business to understand the pressure they are under and the challenges they are facing. For us, the fact that the take-up of zero-emissions trucks and the growth of the necessary infrastructure has been slower than planned is no surprise – because transitioning to alternative energies is not an easy decision for most CRT companies to make. 

We know how competitive and price sensitive the industry is. We understand how big a decision every truck purchase is, and how carefully the TCO is calculated. We therefore appreciate how tough it is for most firms to consider an eTruck when the purchase price is more than twice as high as a diesel truck (let alone a hydrogen truck, which is even more expensive than that).

We also understand the concerns over the limited recharging / refuelling network, especially on long-haul routes.

But do policy-makers understand? 

As always, some do and some don’t – but not enough do, which is why Eurowag is educating policy-makers across Europe so that they understand the realities of our industry. Our objective is not to try to slow down the decarbonisation agenda. On the contrary, our objective is to champion the interests of our customers by helping policy-makers formulate policies which have a realistic chance of working in the real world. 

Most importantly, we are emphasising the challenges created by policy incoherence. As an example, while RED III and CountEmissions EU propose a life cycle approach to emissions, the CO₂ Emission Standards for Heavy-Duty Vehicles focuses solely on tailpipe emissions, effectively closing the door on alternative fuels. This inconsistency conflicts with the principle of technology neutrality and could slow progress on decarbonisation. The European Commission must also refrain from picking winners and losers and allow market-driven solutions to compete on equal terms.

These issues are a particular threat in Central & Eastern Europe (CEE), which plays a leading role in international road transport. Indeed, four of the top five European countries for international freight transport are in CEE, representing about 250,000 businesses. 

In March this year, Eurowag took a leading part in the Fuel Congress 2025 in Warsaw, at which representatives from across CEE signed a joint Call for Action to the European Commission. The Call for Action has now been endorsed by more than 30 organisations across Europe and sent to Commission President Ursula von der Leyen. Eurowag is also actively working with Fleet Cards Europe (FCE), a Brussels-based trade organisation representing the fleet card business which is in very close touch with road transport companies and serves their interests. FCE is part of the Network for Sustainable Mobility (NSM), an informal coalition of like-minded stakeholders which is calling on the European Commission to adapt the legal framework.  

Amongst other policy priorities, Eurowag is pushing for:

  1. No binding purchasing mandates for HDVs – which would severely undermine the competitiveness and growth potential of the CRT sector. 
  2. Technology neutrality in pursuit of carbon neutrality goals – because the full range of alternative fuels (including bioLNG and HVO) are urgently needed alongside electrification and hydrogen to reach net-zero emissions in transport.
  3. A coherent policy framework of enabling conditions to encourage CRT companies to make the transition to lower carbon vehicles and fuels – recognising that light-duty and heavy-duty vehicles are very different challenges.
  4. Harmonisation in the way EU Member States implement the EU sustainability directives that affect our industry.
  5. A consistent, coherent approach to fuel taxation and road user charging – with levied taxes and charges being reinvested in the industry to support innovation, decarbonisation and digitalisation.

If you would be interested to hear more about Eurowag’s advocacy work, or support us in this area, please get in touch.

The key question: can CRT companies afford to wait any longer?

Amid military conflicts and rising energy supply ambiguities, over the last few months, the conversation has been building around the future of the EU’s Green Deal and the recently presented Clean Industrial Deal. In certain areas, some detect a change in tone from the European Commission – a shift towards greater pragmatism, even a dialling down of ambition.

But the direction of travel is already set for the transport sector. The legislation is already in place and the deadlines are fixed. OEMs are mobilising to meet their own targets.

Companies are fooling themselves if they believe that the decarbonisation wave will miss them. It is coming, and it will change the entire sector. 

Those who respond now, by adopting electric vehicles and replacing diesel with decarbonised fuels, acting before they are left with no choice, will gain a competitive advantage in the short-term and protect their long-term viability in the longer-term.

Those who don’t respond are taking a huge risk.  

The four main alternative fuel options 

Different technologies and fuels are suitable for different types of transport – urban and regional transport are very different from long-haul international trucking – and the right choice for each business will depend on multiple factors. 

Here are the four options when it comes to alternative fuels: 

  1. HVO

HVO (Hydrotreated Vegetable Oil) is a drop-in fuel, which means you can start reducing your CO2 emissions with your current fleet and use it without any restrictions in diesel engines. The preferred feedstocks for producing HVO are either animal fat residues or used cooking oils, which can deliver a CO2 reduction of up to 90% on a well-to-wheel basis.

HVO is the fastest and easiest solution to deliver a significant emissions reduction. Right now, the price is 10-25% higher than diesel, but it is gaining popularity while diesel prices will gradually go up. 

  1. BioLNG, bioCNG

BioLNG (biomethane-based Liquefied Natural Gas) and bioCNG offer up to a 100% CO₂ reduction compared to conventional diesel. Biomethane is making strong inroads in heavy-duty transportation, available at over 30% of European LNG refuelling stations – and growing all the time.

BioLNG trucks can also do more than 1,500 km on a single tank, and switching to bioLNG can reduce operational costs by over 30% compared to diesel. It is even cheaper than diesel in Germany, for example, because of the greenhouse gas quota system. More countries are expected to introduce such greenhouse gas quotas to comply with the REDIII objectives.   

  1. Electromobility

eTrucks are favoured by EU policy-makers because they are zero tailpipe emissions, and there are around 40 eTruck models already available on the market. With fewer moving parts, there are also maintenance savings available.

As the e-charging network develops across Europe, and as subsidies become available in more countries, eTrucks will become a more and more viable option for CRT companies – particularly those focused on last-mile delivery, regional transport and point-to-point regular medium- to long-haul routes. 

  1. Hydrogen

Hydrogen is also popular in Brussels for the same reason: it is a zero tailpipe emission technology. Hydrogen trucks can also be refuelled in about the same time it takes to fill up with diesel, offering a significant advantage over electromobility.

Hydrogen will, in time, have a major impact on the industry, particularly as its availability and the refuelling network expands. However, it is still in the early stages of development – and therefore prohibitively expensive right now. 

How can Eurowag help you manage the decarbonisation transition?

There are a variety of ways in which Eurowag is supporting customers to manage the decarbonisation transition:

Decarbonisation as a Service 

More and more CRT companies are looking for a trusted, informed partner to help them navigate this transformation and stay ahead of compliance requirements – but also to maintain their competitive edge in a shifting marketplace. Eurowag’s Decarbonisation as a Service (DaaS) offer is a holistic approach to helping customers transition to net-zero and stay relevant in business.

This includes:

  1. Advisory Services
  • Fleet transition planning: Eurowag’s customer advisory services around the renewal of customers’ fleets are becoming a bigger and bigger part of our business. We are working very closely with vehicle manufacturers as well as customers to ensure that the advice we are giving is fully up-to-date at all times.
  • Regulatory risk / opportunity management: Advice on the regulatory environment and future compliance requirements – helping customers get ahead of the curve and future-proof their businesses.
  • Advice on subsidy programmes: One of the weaknesses of the policy response to CRT decarbonisation is how fragmented the landscape is – with every country handling things differently. Eurowag’s pan-European footprint gives us a panoramic view of the situation across Europe, allowing us to advise customers on the best options available. 
  1. Access to an unrivalled network of alternative fuel stations (Green Fuel Corridors)

Eurowag’s acceptance network for alternative fuels is continually expanding to meet the growing demand. Right now, it includes:

  • 2,000 alternative fuel stations, in 23 countries, including access to 60% of all LNG stations in Europe via the Eurowag fuel card and offering bioLNG at over 150 locations. 
  • Extensive HVO availability for heavy goods vehicles in Europe, including the first HVO corridor in CEE (in which we offer HVO at our own truck parks in Austria, Czech Republic, Slovakia and Spain), at over 500 places in our acceptance network, and via Eurowag’s new Biofuel Swap (book and claim) service. 
  • Eurowag’s Sustainability Certificate for all fuel transactions and including information on used feedstocks and CO2 reduction in compliance with ISCC standards and verification methods.
  1. 360° eMobility (eMSP and CPO) services

In 2024, Eurowag became the first eMobility Service Provider in Europe entirely focused on the CRT industry. As well as offering CRT companies access to a comprehensive network of electric charging stations for trucks and vans across Europe, our eMobility services include:

  • Access to over 900,000 charging points, mainly for  for both light commercial and heavy-duty vehicles. However, the CRT charging infrastructure is underdeveloped continuously developed and but good data is still missing. Eurowag helps customers in planning their journey and partners up with relevant charge point operators (CPOs) to integrate and improve charging networks. 

We are also continuing to grow the dedicated heavy-duty vehicle charging network and support customers with integrated fleet and charging services, including in depots and on-route co-financing and commercialisation (semi-public access). 

  • Charging as a Service (CaaS): We support customers with the installation, maintenance and energy management of charging stations at depots, hubs or other locations.
  • Integrated payments and billing: A single platform and account for all charging sessions, and consolidated invoicing and VAT-compliant billing across borders.
  • Real-time network information: Dedicated support on location mapping and charger availability, including power level, connector type and truck accessibility – so CRT firms can plan efficient, uninterrupted routes.

Sustainability data that empowers smarter decision-making

The importance of data is not, of course, restricted to eMobility. Across the full range of alternative fuels, we go beyond infrastructure access to deliver what truly drives change: reliable sustainability data that empowers smarter decisions. 

Our platform gives fleet operators and logistics companies the ability to track emissions in real time, assess the true impact of route and fuel choices, and report with confidence – backed by accurate, independently verified data. From meeting CO₂ reporting standards to demonstrating progress towards customers’ sustainability goals, Eurowag helps make every charge, refill, and route a step toward measurable decarbonisation.

How the main alternative fuel options compare with diesel trucks

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The time for action is now

The CRT sector is entering a decisive phase. The legislation is in place, the infrastructure is expanding, and the expectations from partners, policymakers and end-customers are rising fast. The direction of travel is clear: the future belongs to alternative energies.

This is no longer just about avoiding risk. Transitioning early can reduce costs, unlock new business opportunities and signal leadership in a low-carbon economy. And the sooner you move, the stronger your position will be in tomorrow’s market.

Don’t wait for the change to be forced upon you. Let Eurowag help you get ahead of it.

Schedule a consultation with our experts today – and take your first step toward a cleaner, more competitive future.