Brussels Knew the True Carbon Cost
The Directorate-General for Climate Action commissioned a comprehensive life-cycle analysis as early as 2018. The 456-page Commission study was published in 2020 and covered the production, operation and disposal of numerous powertrains and fuel pathways. It explicitly noted that manufacturing emissions play a much larger role for electric vehicles.
Nevertheless, the EU tightened its fleet rules in 2023 and required a 100% reduction in direct emissions by 2035. The same regulation also required a method for recording life-cycle emissions. Since June 2026, manufacturers have been able to report these data voluntarily. Brussels thus acknowledged the full carbon footprint but excluded it from the binding limits.
Manufacturers also knew how little their own calculations had in common with the politically imposed zero. In April 2019, Volkswagen published a certified life-cycle assessment in which a diesel Golf came in at 140 g of CO₂ per kilometer and the comparable e-Golf at 119 g. Production alone accounted for 57 g for the electric car, compared with only 29 g for the diesel.
BMW stated in 2020 that battery cells could account for up to 40% of the total CO₂ emissions of an electric car. In the same release, the company listed the BMW iX3 at 0 g/km under statutory testing rules. The European Automobile Manufacturers’ Association (ACEA) later pointed to the industry’s “long and solid experience” with life-cycle assessments, but argued in a position paper that they should remain voluntary.
The Massaged Figure Became Industrial Policy
Fleet limits determine which vehicles manufacturers can sell and whether they face penalties. Every electric car is counted at 0 g/km, regardless of battery size, production location or the electricity used for charging. A fuel-efficient hybrid is counted according to its tailpipe emissions even if its overall carbon footprint is lower than that of a heavy electric car with a battery produced using carbon-intensive energy.
The EU therefore rewarded a particular type of powertrain rather than proven CO₂ savings. Manufacturers shaped model lineups, factories and billions in investment around the politically defined zero. Low-carbon steel, more efficient combustion engines, recycling and renewable fuels for the existing vehicle fleet carried little regulatory weight.
The EU’s Automotive Package of December 2025 changes little. The Commission now proposes a 90% rather than 100% reduction in direct emissions by 2035. The remaining share could be offset with low-carbon steel, biofuels or e-fuels. Yet the benchmark remains the tailpipe.
According to the TUM paper, 78% of Europe’s vehicle fleet is still expected to be powered by combustion engines in 2030. Under the current approach, the fleet’s CO₂ balance can improve only through the slow replacement of combustion-engine vehicles with electric cars, while immediate CO₂ savings from more efficient technology or the use of alternative fuels are not credited in a car’s official CO₂ calculation. That is dishonest.
A realistic assessment of all cars based on life-cycle accounting would judge every type of powertrain according to its actual fossil-fuel emissions.
Brussels chose the opposite course, making the political intent remarkably clear. First, the electric car was declared the political winner. Then only the figure that justified that decision was taken into account, while factors that undermined the positive narrative were simply kept out of the calculations. The aim was quite simply to phase out the internal combustion engine in Europe and force an entire industry to adapt accordingly. The carbon footprint served as a welcome argument, but nothing more.
