The trailer industry supports the objective of effectively reducing CO₂ emissions and the consumption of fossil energy in road freight transport. Trailers and semi-trailers have no propulsion system of their own and therefore cannot directly influence CO₂ emissions. Their impact arises exclusively through the interaction between the towing vehicle, payload and operating profile. Optimisation must therefore always take place at the level of the overall transport system. Regulation should consequently be as practical as possible, take into account the high complexity of trailers, and appropriately reflect both technical feasibility and the economic capacity of this predominantly SME-based European industry.
Available market data do not demonstrate that the CO₂ fleet targets applicable from 2030 onwards of -10% for semi-trailers and -7.5% for other trailers can be reliably achieved by all affected manufacturers using the technologies that are currently available on the market, recognised within the VECTO model, and economically viable. Even for portfolios already optimised for weight and rolling resistance, a significant need for further CO₂ reductions remains. This would primarily require the widespread deployment of additional aerodynamic or other technologies whose market penetration, economic viability and operational suitability have not yet been sufficiently demonstrated.
Despite the possibility of accumulating emission credits between 2025 and 2029, the target requirements will apply in full from 2030 onwards. At the same time, penalties of €4,250 per unit of excess CO₂ emissions create disproportionate burdens in relation to vehicle value, profit margins and the limited influence of trailer manufacturers on actual emissions performance.
An early review, a phased and vehicle-type-specific CO₂ target pathway, fair treatment of special-purpose vehicles and small series, further development of VECTO-TRAILER, and a proportionate penalty regime are therefore required.