The European Parliament and the Council of the European Union signed Regulation (EU) 2025/1214 on 17 June 2025; it was published in the Official Journal on 19 June. For new passenger cars and light commercial vehicles, compliance with CO₂ targets in 2025 to 2027 will no longer be finally assessed for each year but averaged across the three-year period. The emissions targets themselves remain unchanged.
Position covered: 19 June 2025. The Regulation has been published and will enter into force on the twentieth day following publication, 9 July 2025. The new calculation applies only to 2025 to 2027. It does not give manufacturers a three-year reporting pause; annual data and new registrations remain necessary for weighting.
A three-year figure weighted by new registrations is decisive
A manufacturer must ensure that its average specific CO₂ emissions over 2025 to 2027 do not exceed its specific emissions target for that period. Annual averages are weighted by the number of vehicles newly registered in each calendar year. The target is likewise calculated from annual specific targets and the corresponding registrations.
Better performance in one year may therefore offset poorer performance in another. The number and composition of registrations still affect the result. Sales planning, vehicle mix and CO₂ data must be coordinated across all three years and recorded in a traceable manner.
The targets are not reduced
The amendment changes the compliance calculation, not the emissions requirements in Regulation (EU) 2019/631. A manufacturer gains more time to balance performance between years, but no general reduction of its target. The three-year assessment can absorb deviations but can also carry an adverse trend to the end of the period.
One forecast is therefore insufficient for internal planning. Manufacturers should model registrations, electrified models, combustion vehicles and light commercial vehicles under several scenarios. Changes in launch dates, demand or supply capability may materially alter the weighted outcome.
Pooling remains available with extended conclusion periods
For every year in which a manufacturer belongs to a pool, the pool's annual average emissions and annual target enter the three-year calculation. Pooling agreements covering 2025 or 2026 may, in derogation from the former deadline, be entered into until 31 December 2027.
A pooling decision therefore affects more than an isolated annual figure. Partners need rules on data, registration forecasts, costs, security and the consequences of departure or changed model planning. The later conclusion date does not replace timely examination of suitable partners and commercial terms.
The excess emissions premium and supply contracts remain relevant
The European Commission is to impose an excess emissions premium on a manufacturer whose average specific emissions over the three years exceed its target for 2025 to 2027. The flexibility does not transfer the manufacturer's statutory responsibility to suppliers.
Supply agreements may nevertheless allocate commercial consequences. Volumes, launch dates, technical changes, CO₂-related product data and the consequences of delayed supplies should be defined clearly. A broad clause attributing every fleet deviation to a supplier disregards causation, sphere of influence and proof of loss.
Review points for OEMs and suppliers
- Record registrations and specific emissions separately for 2025, 2026 and 2027.
- Model weighted three-year scenarios for different vehicle and powertrain mixes.
- Review pooling agreements for data access, costs, security and exit.
- Align supply agreements on volumes, launches, changes and CO₂ data.
- Assign internal responsibility for fleet planning, regulatory data and contractual consequences.
Related insights
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- Electric cars from China: definitive EU countervailing duties from 30 October 2024
Official sources
- EUR-Lex: Regulation (EU) 2025/1214 of 17 June 2025
- European Commission: CO₂ emission standards for cars and vans
This article describes the measure published on 19 June 2025. The specific target calculation depends in particular on manufacturer status, pool membership, new registrations, specific emissions and any derogation under Regulation (EU) 2019/631.