The following is a translated PR originally submitted by UNITI (eFuels Lobby group) in Berlin, September 2, 2026.
Press Release from UNITI Bundesverband EnergieMittelstand e.V. (Federal Association of Energy SMEs)
The Practice of Whitewashing the Carbon Footprint of Electric Cars Must End
A new meta-study by the Technical University of Munich (TUM) demonstrates once again that the CO2 emissions balance of purely battery-electric vehicles is being systematically under-reported by EU lawmakers. The underlying measurement methodology fails to account for the actual CO2 emissions from electric mobility. A legal opinion commissioned by UNITI more than two years ago had already amply demonstrated that the CO2 fleet regulation violates EU law, in part due to the use of this outdated measurement method.
The European CO₂ fleet regulation categorises purely battery-electric vehicles across the board as zero-emission vehicles, which are thus considered 100% climate-neutral. This is based on the so-called “tailpipe approach,” which measures only emissions from a vehicle’s exhaust while it is in operation. All other emissions – such as those from a vehicle’s production and disposal, as well as from the generation of its propulsion energy – are not taken into account.
A new TUM study emphasises that the actual carbon footprint, however, depends heavily on where a vehicle is built, how carbon-intensive its upstream production processes are, and what energy source or energy mix is used to power it during its operational life. According to the TUM study, corresponding life-cycle analyses show that purely battery-electric vehicles achieve an average CO2 reduction of only 41% compared to internal combustion engine vehicles powered by conventional fuels. This means that, over their entire life cycle, purely battery-electric vehicles emit, on average, 59% of the emissions produced by internal combustion engines running on conventional fuels.
“The study’s authors demonstrate that the tailpipe approach in EU fleet regulations systematically under-reports the carbon footprint of electric mobility. It should be replaced by a methodology that accounts for all emissions over the entire life cycle of a vehicle and its propulsion energy. Only then will it be possible to make a fair comparison of the carbon footprints of the various propulsion technologies,” says UNITI Executive Director Elmar Kühn. He continues: “The current CO2 fleet regulation, as well as the proposed amendments presented so far by the European Commission, do not ensure this; rather, they cement the ‘all-electric’ course in road transport and force the internal combustion engine out of the market through a de facto ban on new registrations.”
Renewable fuels offer significant real CO2 reduction potential for internal combustion engines
Due to EU regulations that are heavily skewed toward the expansion of electric mobility, the significant CO2 reduction potential of renewable fuels for internal combustion engines has not yet been fully realised. For example, while HVO100 diesel is already available at gas stations and enables CO2 savings of up to 90 percent during operation compared to conventional fuels, the rollout of e-fuels based on green electricity, in particular, continues to be held back by regulations.
Elmar Kühn of UNITI: “With HVO100, CO2 emission reductions can already be achieved today in internal combustion engines that far exceed the average value of 41% currently cited for electric cars in the TUM study. The fact that these CO2 savings are not recognised in any way by regulators is simply scandalous.” As a general rule, it is not the propulsion technology itself that determines a vehicle’s carbon footprint, but rather whether the energy used to power it (charging current or fuel) comes from fossil or renewable sources.
Legal Opinion Shows: European CO2 Fleet Regulation Violates EU Law
There are also legal concerns regarding the measurement methodology underlying the fleet regulation. For example, Prof. Dr. Martin Kment, a constitutional law expert at the University of Augsburg, concluded as early as 2024 in a legal opinion commissioned by UNITI that the tailpipe approach is outdated, violates EU law and EU principles, and should be replaced by a modern measurement methodology that accounts for CO2 emissions over the entire life cycle.
With regard to the revision of the EU fleet regulation currently under discussion in Brussels, UNITI CEO Elmar Kühn states: “The proposals debated so far at the EU level fall far short of what is needed and do not represent a genuine departure from the EU’s regulatory push toward an all-electric future.
“True technological openness regarding propulsion systems can only be achieved if the contribution of renewable fuels to climate protection is fully recognized.
“Given the hundreds of thousands of jobs in Germany’s automotive industry that are directly dependent on the internal combustion engine, the federal government must bring all its political clout to bear in Europe and ensure a genuine change of course.”
ABD Policy Director, Brian Gregory, observed that the UNITI study confirms the conclusions of ABD’s 2024 Cradle To Grave Report; which carried out an objective Life Cycle Analysis of Internal Combustion Vehicles (ICEVs), with Battery Electric Vehicles (BEVs).
This report established that there is little to differentiate between the two in overall environmental impact; but the optimal (lowest environmental impact) course of action is to run a typically 20 – 30 year lifespan ICEV it to its natural scrappage point, in preference to two (or indeed up to three, depending on battery lifespan) 10 year lifespan BEVs.
See the detailed report here: https://abd.org.uk/wp-content/uploads/2023/07/Cradle_Grave_Report_-Final_JULY2023.pdf
ENDS
Original Press Release from UNITI Bundesverband EnergieMittelstand e.V. (Federal Association of Energy SMEs), translated into English with added comments by Brian Gregory, Policy Director for the Alliance of British Drivers.
For all media enquiries, contact Paul Naylor on 07914 304 504 or email paul@mediaandyou.co.uk
Notes: Founded in 1992, the Alliance of British Drivers (ABD) is the leading organisation promoting the interests and concerns of drivers in the United Kingdom.
The UK has over 37 million drivers – that is a majority; we should stop tolerating the way we are treated by the government and local councils.
Cars, vans and taxis account for 80% of the mileage of all trips in the UK, and over 65% of goods being carried by road. The road network, and the people who use it, are of vital importance to the nation’s economy. Drivers should expect the road network to be improved and maintained to a standard that is fit for purpose. They should be able to use the roads in a safe and responsible manner without being subject to unreasonable charges, restrictions or penalties.
