Position paper - Review of the Weights and Dimensions Directive

December 2022 ACEA Position Paper REVIEW OF THE WEIGHTS AND DIMENSIONS DIRECTIVE www.acea.auto 1 BACKGROUND The European Commission plans to revise Council Directive 96/53/EC on the maximum weights and dimensions of heavy-duty vehicles (‘Weights and Dimensions Directive’) with the aim of aligning it with targets set for the reduction of greenhouse emissions from transport. ACEA welcomes the revision as it provides the opportunity to address several shortcomings in the directive, including removing inconsistencies and barriers that hinder an accelerated market uptake of zero-emission vehicles. RECOMMENDATIONS In general, ACEA recommends that the structure of the current regulation is simplified as much as possible, as it currently includes a range of different provisions for several very specifically defined vehicle segments, eg road trains, articulated vehicles, motor vehicles, buses and coaches. In particular, ACEA recommends that the revision is focused on two key elements: • Specific provisions on vehicle dimensions, total weights and axle weights to accelerate the market uptake of zero-emission vehicles. • Longer and heavier vehicle combinations: European Modular System (EMS). PROVISIONS ON VEHICLE DIMENSIONS, TOTAL WEIGHTS AND AXLE WEIGHTS TO ACCELERATE THE MARKET UPTAKE OF ZERO-EMISSION VEHICLES Commercial vehicle manufacturers have repeatedly expressed their commitment to meeting climate neutrality targets, and to decarbonisation by 2050 at the latest. Achieving climate neutrality in road transport by 2050 implies that all new commercial vehicles sold must be fossil-free by 2040. This will require a fundamental shift in powertrain technologies – moving away from diesel as the dominant energy carrier, towards low- and especially zero-emission vehicles. Zero-emission vehicles (ZEVs), namely battery-electric and hydrogen-powered vehicles, will have to become the backbone of road transport if the sector is to reach its decarbonisation targets. These new powertrain technologies come with additional requirements with respect to available space in the vehicles, total vehicle weight and axle weights. These differences to conventionally powered vehicles should be addressed in the review to enable and support the market uptake of zero-emission vehicles. The objective of ACEA’s recommendations is to remove barriers that hinder the market uptake of zero-emission vehicles and place them on a level playing field with conventionally powered vehicles with respect to payload etc. The proposals are specifically not aimed at increasing the loading capacity of vehicles. With this in mind, the review of the Weights and Dimensions Directive should address the following: www.acea.auto 2 For trucks • With respect to weight and axle load provisions for zero-emission vehicles, ACEA recommends that: • When setting out additional weight allowances for zero-emission vehicles, any reference to conventional vehicles should be removed • All low-emission vehicles should be granted at least an additional 1 ton. • All zero-emission vehicles should be granted at least an additional 2 tons. • Additional weight allowances for ZEVs should not be taken into account when calculating road charging rates, irrespective of whether or not they are differentiated by CO2 according to the Eurovignette. This is to avoid ZEVs being subject to higher tolls/user charges, or granted discounts that are calculated based on a reference value that is too high. • The axle load of the driven axle and driven axle combinations should be increased by at least 0.5 tons, ideally 1 ton. • For all ZEVs, the additional weight allowance should be increased by up to 4 tons, instead of the current additional ZEV allowance of 2 tons. o The additional allowances (2 tons) that have been granted to date support the design and market uptake of vehicle segments that can relatively quickly be adapted to zero-emission powertrains. However, despite foreseeable technology improvements, it has become clear that this additional allowance is insufficient, especially for vehicles in particularly demanding use cases. Thus, to fully eliminate any payload disadvantages and ensure sufficient performance and range, the additional weight allowance for ZEVs should be increased to 4 tons, rather than the current 2 tons. • New powertrain technologies require more space (eg for batteries and tanks) than is currently provided for under the Weights and Dimensions Directive. Therefore, ACEA requests that all zero-emission vehicles (category N) are granted additional length of up to 1.5 m. These vehicles would still comply with turning-circle requirements and meet all safety-related requirements (eg Direct Vision, General Safety Regulation etc). In addition to the proposals relating to zero-emission vehicles set out above, and irrespective of a specific powertrain technology, for 3-axle vehicle/3-axle trailer combinations (articulated vehicles and road tra