A More Resilient Europe Needs an Enduring Transport Target under the Renewable Energy Directive

To: Commissioner for Energy Dan Jørgensen, Commissioner for Climate Wopke Hoekstra, and Commissioner for Sustainable Transport Apostolos Tzitzikostas

Dear Commissioners,

Dear Directors-General,

As the European Commission prepares the post-2030 renewable energy framework, we, the undersigned organisations* would like to emphasise the importance of a clear, binding and economically efficient framework that continues to drive renewable energy deployment and greenhouse gas (GHG) emission reductions in transport through robust and predictable demand signals.

The post-2030 framework should build on what has proven successful under the existing architecture and provide a clear long-term trajectory to effectively enable further deployment of renewable energy in transport.

The EU has recently strengthened its climate ambition by adopting a legally binding target to reduce net greenhouse gas emissions by 90% by 2040 compared with 1990 levels, as a milestone on the path to climate neutrality by 2050. Achieving this objective will require all sectors to contribute, but transport deserves particular attention given the pace of its decarbonisation and its continued reliance on fossil fuels.

The transport sector remains the largest source of greenhouse gas emissions in the EU:

• Transport emissions increased by 0.7% in 2024 compared with 20230F[1], while emissions from several other major sectors remained stable or declined;
• The uptake of renewable energy in transport was only 11.2% of EU transport energy consumption1F[2] in 2024 significantly below the 29% target2F[3] established for 2030 under the current Renewable Energy Directive (RED III);
• Reducing the EU's heavy reliance on imported petroleum products, such as diesel, VLSFO and aviation fuel would strengthen Europe's energy security and resilience while supporting the deployment of domestic renewable fuel value chains.

Over the past two decades, transport-specific obligations under the RED energy targets have provided a clear regulatory signal for investment and market development. The progressive introduction of these obligations has helped create demand for renewable transport fuels and establish the market framework within which a broad range of renewable fuel solutions can develop. A transport fuel supplier obligation should continue beyond 2030 as part of the REDIV framework to support investment decisions and provide visibility for the development of European production.

There will be no energy transition of transport modes without liquid and gaseous fuels, including in parts of road transport and in sectors such as aviation and maritime transport where electrification faces greater technical and economic constraints.

Moreover, road transport currently lacks a dedicated post-2030 framework comparable to the long-term sector-specific frameworks for aviation and maritime transport. Relying predominantly on the ETS I and ETS II to provide the necessary incentive would leave a significant gap in the renewable energy policy framework. Clear and predictable demand-side instruments are needed to provide sufficient incentive for renewable fuels investments in Europe.

The central challenge is not a lack of ambition in the targets, but the pace at which renewable energy is being deployed in transport and a long enough regulatory horizon. A strong, predictable and coherent policy framework is needed now more than ever.

We also support the Commission's objective of simplifying and improving the coherence of the upcoming EU renewable energy framework. The EU's current legal framework provides Member States with a choice between a renewable energy content target and a GHG-intensity reduction target while introducing specific sub-targets. Maintaining a dedicated transport obligation and flexibility for Member States would ensure that simplification does not come at the expense of effective decarbonisation.

Enduring and predictable transport targets under the RED is not only a climate policy issue. It is also an essential component of Europe's resilience and industrial competitiveness.

We therefore urge the Commission to retain dedicated and enduring transport-specific targets in the post-2030 Renewable Energy Framework, building on what has proven successful under the existing architecture while improving its coherence, effectiveness and implementation.

[1] European Environment Agency, Change in EU GHG emissions across sectors (2024 Vs 2023)

[2] Eurostat SHARES database

[3] Under RED III, Member States must achieve either a 29% share of renewable energy in transport or a 14.5% reduction in the GHG intensity of transport fuels and energy