This position was distributed by the Network for Sustainable Mobility (NSM) of which the EBB is a member, on 2 October 2025. The Network for Sustainable Mobility (NSM) is a voluntary, cross-sectoral group uniting stakeholders from transport, engineering, energy, and fuel manufacturing who support the role of renewable and sustainable fuels in achieving a climate-neutral transport system. The Network promotes a technology-neutral approach that values both vehicle and fuel innovations, ensuring an affordable, competitive, and accelerated reduction of emissions. The upcoming revision of the CO₂ emission standards for cars and vans provides an opportunity to reassess how to decarbonise road transport and recognise all technologies – renewable fuels, hydrogen, plug-in hybrids, range extenders, and efficient combustion engines – that can contribute to emission reductions on an equal footing with electrification. The NSM proposes that the impact assessment for the CO₂ standards revision should include three key provisions. First, a technology-neutral definition of CO₂ neutral fuels, aligned with the Renewable Energy Directive, to ensure all compliant renewable and synthetic fuels – biofuels, biogas, RFNBOs, and recycled carbon fuels – are recognised for their carbon savings. Second, the introduction of a Carbon Correction Factor (CCF) to reflect the actual share of CO₂-neutral fuels in the market, ensuring that liquid and gaseous fuels are no longer automatically treated as fully fossil-based. Third, the creation of a new vehicle category exclusively powered by CO₂-neutral fuels, which should qualify as zero-emission vehicles under the Regulation, supported by EU-wide monitoring and verification methods. The NSM highlights that the Commission’s current proposal, limiting the definition of CO₂-neutral fuels to RFNBOs ensuring a 100% GHG reduction on a “Well-to-Wheel” approach (WtW), unfairly excludes sustainable biofuels, which are already available at scale. Moreover, assessing renewable fuels on a WtW basis while keeping electric vehicles under a tailpipe-only approach creates regulatory inconsistency. Technical evidence shows that RED-compliant renewable fuels deliver very competitive GHG performance, often outperforming electricity when average EU grid intensity is considered. The NSM calls for harmonised GHG accounting across EU legislation and recognises the complementarity of sustainable fuels and electrification. Proper recognition of renewable fuels will strengthen investment certainty, support industrial resilience, and accelerate Europe’s progress toward climate neutrality. [ READ THE POSITION PAPER ]