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End of the sale of cars running on combustion engine in 2035. Where are we ? Where are we going ?

Olivier ABULI, advice and analyses consultant

Jun 26, 2022

Road transport is responsible for 22% of the European Union CO2 emissions, 61% of which are due to light vehicles (cars and commercial vehicles weighing less than 3.5 tons).
On June 8th, by ratifying the end of the sale of cars with internal combustion engines (gasoline, diesel and hybrid engines) on January 1st, 2035, MEPs have opened a way that aims at eliminating one fifth of the emissions of the European space in 2050 ; the conditions of application of the measure to two-wheelers and heavy goods vehicles will be examined later.

At COP26, several major car manufacturers rallied to this trajectory. This adherence to the political course was essential, but many challenges and uncertainties remain to be resolved in order to make this ambition a reality.

The challenges deal with energy balance but are also technological, logistical and social : some 240 million vehicles need to be replaced or adapted, while at the same time it will be compulsory to help and support the transformation of a sector that produces 17 million cars per year and provides more than 12 million jobs worldwide.

Technology and sovereignty issues

As a matter of fact, the decarbonisation of the road fleet will essentially involve electrification.

A parallel could then be drawn with the mature smartphone market. The business model and profitability of the most prominent manufacturers are based on three pillars : the autonomy and life expectancy of batteries, the command of operating software that contributes to this energy optimization, and the security of supplies of semiconductors, metals and rare earths. It is no coincidence if the American company Tesla claims to be a « tech company » as much as a car manufacturer !

It is therefore a new verticality that needs to be imagined in a few years’time in order to maintain the share of value creation necessary to transform and consolidate a historical industrial flagship within the European space.

The main continental Alliances and Brand Groups are working on this. Volvo, Renault, Stellantis, Volkswagen... are investing in start-ups, R&D and building up partnerships to bring out a new generation of batteries. There are 38 factory projects in the EU.
This change in attitude and paradigm, partly triggered by the 2015 « diesel gate », is beginning to bear fruit in the premium segment : in this market, range performance has improved significantly and price elasticity is only partly correlated with public incentives for conversion.

Making electric cars more environmentally friendly

As a matter of fact, today, the electric cars on the road are less polluting than vehicles running on combustion engine... However, there are still quite far from being ecological if we take into account their entire life cycle.

As mentioned above, the first issue is the manufacturing and recycling of batteries. Mining of metals and rare earths in Africa and China is a highly polluting activity, so is production, which is concentrated in Asia on sites that are mainly powered by the combustion of fossil fuels. On top of this, there are emissions from shipping and the lack of efficient recycling-recovery processes of batteries.
So yes, as long as Europe does not have domestic production capacity and circular recycling units for 70 to 80% of the rare earths and metals contained in batteries, new electric cars will continue to have a carbon footprint corresponding to 4 to 7 years more and a few tens of thousands of kilometers longer (depending on the model and its weight) than the most recent equivalent vehicles running on combustion engine.

In addition, we must also take into account the origin of the « electric fuel » which, as it is still mostly produced by fossil fuel power plants in several European countries, can add 20 to 30% to this initial liability.

To sum it up, from a strictly environmental point of view, it is not globally « virtuous » to replace a combustion engine propelled vehicle in 2022 halfway through its life (7 to 8 years) by an electric vehicle, despite the attractiveness of financial bonuses.

The most positive factors, which are far from being insignificant, are the drastic reduction of fine particle emissions (only those due to tyre abrasion and braking remain) and, consequently, a significant contribution to the improvement of air quality.

The energy challenge : producing and distributing the electricity needed to decarbonise mobility

Solving the clean mobility equation in the medium term therefore depends on two main factors : on the one hand, designing and recycling new-generation batteries in Europe... and, on the other hand, above all, having adequate electrical production capacity, emitting little (nuclear) or no (renewable) carbon. This second point is a crucial point, which cuts across the issues of light vehicles (electrification) and heavy transport modes (hydrogen).

Densify and standardize the network of charging stations

According to RTE - the French electricity transportation network operator - the national production and distribution infrastructure is already capable of supporting the regular supply of millions of vehicles. Nevertheless, the operator underlines the limits (time, constraints) of domestic charging and advocates the technology of bi-directional charging stations (V2G, Vehicle to Grid), which would schematically make each vehicle a storage point and a one-time contribution to the network during downtime in order to finely balance variations and peaks in needs.

In fact, as in any emerging market, for the time being, unorganized competition between players and solutions prevails (car manufacturers, energy companies, start-ups, etc…), which does not contribute to simplify users' lives, nor to densify a coherent recharging network (variable power and interoperability).

By 2030, there should be 7 million charging stations in Europe, including 1 million in France. To date, 70% of public charging points are concentrated in three countries: the Netherlands, Germany and France, which has only 60,000 of the 100,000 initially planned for the end of 2021.

An « early » adaptation, ahead of the French Presidency of the EU

As it was brought before the European Court of Justice because of its repeated failures to comply with the Air Quality Directive in 2018, France has been working to fall in line (obligations to create Low Emission Zones) and to anticipate the end of the sale of vehicles running on combustion engine thanks to the vote of the Climate and Resilience Law in August 2021.
This is an essential political prerequisite to legitimately pursue strong ambitions, shared with the Commission, in terms of energy-climate transitions during the French presidency of the EU.

End of internal combustion vehicles in France : sooner and faster

While this is not a formal ban on sale, it looks like one.
The law passed ten months ago by France specifies that « private cars emitting less than 123 gCO2/km according to the WLTP standard must represent at least 95% of new car sales by January 1st, 2030. In concrete terms, today, the enforcement of this threshold would exclude from the market all vehicles that are similar to SUVs and most of the latest-generation internal combustion engine models, including hybrids, which are popular with the French (Citroën C3 Aircross, Renault Mégane, Peugeot 2008...).
In fact, several manufacturers have already announced that they will not take the plunge and will concentrate on the 100% electrification of their range.

Professional fleets put to work

At the same time, the law maker has created a mandatory mechanism for the progressive renewal of professional fleets in order to accelerate the decarbonisation of thermal vehicle stock. This mechanism is mandatory for public and private actors according to the following criteria and schedule :

State and public bodies (more than 20 vehicles up to 3.5 T)
Purchase of 50% of low-emission vehicles when renewing or extending their fleet as of January 1st, 2026, and 70% as of January 1st, 2027.

Local authorities and state companies (over 20 vehicles, including those weighing more than 3.5 T)
Since July 1st, 2021, local authorities have been required to purchase 30% low-emission vehicles (up to 3.5 tons) when renewing or expanding their fleets. On January 1st, 2025, this rate will be increased to 40% while, on January 1st, 2030, it will reach 70%.

Private company fleets (over 100 vehicles, including 3.5 T)
10% of the renewal from January 1st, 2022 ; 20% from January 1st, 2024 ; 40% from January 1st, 2027 ; 70% from January 1st, 2030.

Low Emission Zones (LEZ) : a progressively regulated access to Major Urban Centers

The Climate and Resilience Act also requires metropolises with more than 150,000 inhabitants to establish LEZs, which prohibit the traffic of the most polluting vehicles within their boundaries. Urban areas with a population of between 100,000 and 150,000 are required to conduct a study on air quality (annual average value, frequency of pollution peaks and streets where they occur) in order to judge the appropriateness of voluntary implementation for public health reasons.
Sixteen local authorities have now taken the step ; elected officials have some leeway in terms of the progressive nature of restrictions and penalties, as well as in granting incentives. However, they must respect the spirit of the following national timetable : exclusion of Crit'air 5 stickers in 2023, Crit'air 4 in 2024 and Crit'Air 3 in 2025 (except for targeted and justified exemptions). In 2025, 40% of the current car fleet would therefore no longer be allowed to circulate, or only to a limited extent (at specific times or on specific days, etc…).

Heavy vehicles are not concerned
But... this only deals with unregistered equipments, which are not intended to be used regularly on open roads (excavators...). However, construction and public works operators are noting a rise in the level of requirements of specifications (noise pollution, cleanliness, etc…) and must deal with the RE 2020 standard for new buildings. This standard, which came into force on January 1st, 2022 aims at passive energy throughout the life cycle of buildings, from their design to their pulling down.
According to a recent paper in Le Moniteur, electrified machines exist for lifting and earthmoving equipment weighing up to 5 tons but they need an efficient way to reload them on site. The trade is therefore testing innovations and encouraging the marketing of new equipments that are more powerful, easy to use and carbon-free.

The accomodation of historic vehicles remains in the hands of the local authorities
This is one of the other items that have been the subject of analysis and consultation. The government finally decided to create a specific « tax disc » for classic cars over 30 years old, and then invited the local authorities, which keep this power, to grant them a local exemption.
To date, 9 metropolises are considering a positive response. For the others, and in the event of an opposite decision, the owners of vehicles that are still relatively common will be able to consider retrofitting, which is now mastered by specialized operators and eligible for subsidies.

The transformation of mobility that has just been approved by MEPs is undoubtedly the most sensitive change to be managed in the « Fit For 55 » trajectory, because it will have a direct impact on every European, both in his or her professional and private life.
The success of this industrial challenge presupposes the ability to combine significant technological progress with rapid economies of scale. The example of the French adaptation framework illustrates how public authorities can create and support, on a transitional basis, the ecosystem that is essential for the emergence of a profitable low-carbon market in the medium term (R&D grants, accelerated fleet renewal, conversion incentives).
Beyond these technical and financial aspects, we must neither neglect the millions of direct and indirect employees in the automotive sector, nor the populations least ready to accept the transitions.

At, we are committed to informing you regularly and objectively about the developments in this sector, while researching and listing for you the best tried and tested low carbon options and solutions.

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