From Compliance to Leadership: Reshaping the Value Engine of Commercial Vehicles through Carbon Management

Recently, the European Union has sent out new signals regarding its climate policy: on the one hand, under pressure from industry, it formally proposed relaxing the 2035 "zero-emission" target for passenger cars and light commercial vehicles to a "90% reduction"; on the other hand, it released a draft revision of the Carbon Border Adjustment Mechanism (CBAM), expanding its scope for the first time to include automobiles and their components (involving pure electric vans, chassis, transmissions, etc.).

The EU's policy direction often swings back and forth, but its core objective has always been to drive the industry toward a zero-carbon future and enhance industrial competitiveness. For commercial vehicle companies, the focus should not be limited to current export compliance requirements, but should extend to understanding the fundamental logic of policies and their impacts through the regulations, in order to plan a long-term development path for global markets.

EU regulations 2019/631 and its amendment 2023/851, among others, together form the EU CO₂ emissions regulatory system for passenger cars and light commercial vehicles. This article will interpret the key rules within them, explore the industry trends they reflect, and provide insights for the green strategic transformation and value reconstruction of China's commercial vehicle industry.

This system sets "achieving zero emissions for new vehicles" as a clear end goal, establishing a clear decarbonization roadmap for light commercial vehicles. The regulations require that from 2025 to 2029, the average CO₂ emissions of newly registered light commercial vehicles in the EU must be reduced to below 153.9 g/km, with further tightening thereafter.

A company's specific emission targets are determined by a combination of the EU's emission targets and the average weight of the vehicles it sells. If a company exceeds its emission target, it will face substantial fines—95 euros per vehicle for each gram/km of CO₂ exceeding the limit.

The regulatory practices of the European Union are a microcosm of the evolution of global green trade rules. As of November 2025, 55 countries have committed to timelines for light-duty vehicles that are in line with the goals of the Paris Agreement. Therefore, for Chinese commercial vehicle companies aiming at the global market, green transformation is far from being merely a compliance burden for a single market; it is a core strategy for reshaping global competitiveness.

To provide a certain degree of flexibility, the EU allows light commercial vehicle manufacturers to form a 'CO₂ emission credit pool' to calculate compliance as a whole.

This mechanism provides a buffer for enterprises that cannot meet the standards independently in the short term. However, the essence of carbon emission credit pools is to create a small carbon pricing market between companies, and companies pay a considerable fee to competitors ("sellers").

On the other hand, for small-scale enterprises (with an annual production of 1,000 to 22,000 light commercial vehicles), the EU does allow them to apply for exemptions from regulatory emission targets, but they must submit detailed and feasible deployment plans and timetables for emission reduction technologies, which is basically equivalent to legally binding personalized emission reduction commitments.

Both show that the "cost of carbon emissions" will be part of the business of commercial vehicle companies anyway. Under the pressure of the regulatory system, EU companies are investing more resources in technological innovation in order to maintain their competitiveness. For Chinese commercial vehicle companies, taking the initiative to actively accelerate the construction of a low-carbon technology system is an inevitable strategic choice to maintain and strengthen their own advantages in the next stage of global industrial competition.

The EU's regulatory vision is expanding to the full life cycle. The European Commission has clearly stated that it will propose a methodology for assessing CO₂ emissions data for the full life cycle of vehicles by December 31, 2025, and accept voluntary declarations from June 1, 2026.

This means that the competitive core of the commercial vehicle industry will be advanced and deepened from the performance of terminal products to the carbon management level of the entire supply chain in the future. Combined with the mandatory requirements of the EU Battery and Waste Battery Regulation on battery carbon footprint, in the future, the green competitiveness of a commercial vehicle will depend on its carbon management capabilities in various supply chains such as steel, aluminum, and batteries. The transparency and low-carbon capabilities of the entire value chain will become a new yardstick to measure the future competitiveness of commercial vehicle companies. This requires OEMs to extend their management tentacles upstream and build a close alliance with suppliers to reduce carbon emissions.

In the face of the above systemic changes, enterprises can transform their immediate compliance challenges into valuable opportunities for long-term and differentiated green competitiveness by internalizing external mandatory green rules into continuous driving forces for technological innovation, supply chain optimization and management upgrades.

Therefore, enterprises should take into account both short-term pragmatism and long-term layout in the process of going overseas, and take the initiative to reshape carbon management from a cost center to a value engine. In the short term, companies should accurately manage compliance risks, factor carbon costs (such as potential credit purchase expenses) into export decisions, and carefully evaluate flexible compliance options based on export strategies. In the long run, enterprises should pay more attention to green transformation, gradually establish a quantifiable and traceable green management system covering R&D, procurement, production, and recycling, and build a collaborative carbon reduction mechanism with suppliers.

Traveling alone is fast, while many travelers are far. Wuhan Inspection Center continues to pay attention to and study the EU and global carbon policies and industrial transformation trends, and is willing to work with commercial vehicle companies to jointly address carbon barriers, transform challenges into new momentum for global and future leadership, and jointly build a new chapter in industrial sustainable development.