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CirculaTUM, the interdisciplinary research network of the Technical University of Munich (TUM), has been researching the decarbonization of the automotive sector since the beginning of the year. The findings of the most comprehensive study in this field to date reveal substantial misdirection in the European Union’s climate policy regulation. They were presented today, Tuesday, September 1, 2026, at a press briefing at TUM in Munich.
• Purely battery-electric vehicles reduce CO₂ emissions by only 41 percent on average compared to combustion vehicles. Yet the European Commission counts them as 100 percent climate-neutral.
• The reason: EU regulation measures CO₂ emissions only through tailpipe exhaust. Fossil carbon released during a vehicle’s production and through the electricity used to operate it, or not recovered during recycling, is not captured by EU Regulation 2019/631.
• This scientifically indefensible stance by the EU will cause the passenger car sector’s 2030 target of reducing CO₂ emissions by 188 million tons to be missed by more than 100 million tons. Combustion vehicles are expected to still make up 78 percent of the vehicle fleet in 2030.
• The researchers therefore propose a life-cycle-based standard for defossilization.
Drawing on 19 studies with 47 modeled scenarios, the White Paper documents a substantial misdirection of EU climate policy in the automotive sector, both economically and environmentally. Given the political decisions on the future of Europe’s automotive industry expected this fall, TUM President Prof. Thomas F. Hofmann commissioned the study at the beginning of the year.
Under the leadership of the three professors Johannes Fottner, Magnus Fröhling, and Tim Büthe, the study became the most comprehensive analysis to date of vehicles’ climate footprint across their entire life cycle, from production through use to disposal. The study demonstrates the central flaw in the EU’s CO₂ regulation, which measures a car’s climate footprint at a single point: the tailpipe. Instead, the TUM researchers propose a life-cycle-based standard that credits every verifiable contribution to reducing fossil emissions.
TUM’s analyses show that battery-electric vehicles reduce life-cycle emissions by an average of 41 percent (in about 92 percent of cases). The range of deviation from combustion vehicles’ CO₂ emissions extends from a reduction of 89 percent to an increase of as much as 21 percent. The tailpipe-only metric masks these differences, along with any climate contribution beyond the powertrain.
If a manufacturer invests in near-CO₂-free steel, a supplier decarbonizes battery production, or a recycling company keeps critical raw materials in the loop, none of that improves the regulation’s metric under the EU’s current rules by a single gram. Regulation that does not capture relevant contributions to decarbonization cannot reward them either. And what it does not reward, industry will not finance at scale.
“The greatest economic and environmental misdirection lies in the fact that the European Commission’s regulation is based exclusively on CO₂ emissions from tailpipe exhaust,” says Prof. Johannes Fottner. “Under this logic, purely battery-electric vehicles are considered climate-neutral. The industry’s diverse efforts to reach climate targets – through green steel or circular economy practices, for instance – go unrewarded as a result.” Europe, he adds, can no longer afford to overlook this emissions reality.
EU will miss its own target without reform
According to one of the studies considered (Tang et al., 2023), at the pace of electric-vehicle adoption targeted by the EU, the passenger car sector would deliver only about 80 million tons of CO₂ reduction by 2030 – yet roughly 188 million tons would be needed to meet the EU’s own targets.
The reform of Regulation (EU) 2019/631 is part of the Automotive Package presented by the European Commission in December 2025. The vote in the European Parliament’s plenary session is currently scheduled for November 23, 2026.
According to the study, however, the current Automotive Package, with its credits for steel and fuels, covers at most 10 percent of a manufacturer’s mandated CO₂ reduction and does not close the actual gap. The CirculaTUM study therefore considers the proposed life-cycle-based standard additionally necessary.
Scientists call for sustainable CO₂ accounting
“We are currently seeing a substantial misdirection in the European Union’s climate strategy. If it takes its own targets seriously, it can no longer rely solely on tailpipe measurement,” says TUM President Prof. Thomas F. Hofmann. “I call on Parliament and the Council to use the ongoing revision of the Automotive Package to introduce mandatory, verified life-cycle reporting. Time is short, and the scientific findings must be factored into the reform debate.”
From a logistics perspective, the situation is better than current regulation would suggest, says Prof. Johannes Fottner of the Chair of Materials Handling, Material Flow, Logistics at TUM: “There is already real progress today in building traceable supply chains for green steel and in recovering materials at the end of a vehicle’s life – progress that current regulation simply fails to capture. Regulation that does not recognize this gives industry no incentive to realize this potential, even though it is already prepared to do so.”
Life-cycle assessment is not regulatory uncharted territory either, emphasizes Prof. Magnus Fröhling of TUM’s Chair of Circular Economy and Sustainability Assessment: “European precedents already exist in the Ecodesign Regulation and the Carbon Border Adjustment Mechanism. What matters is that a new standard be built on performance-based crediting that treats every ton of fossil carbon actually saved equally – regardless of where in the life cycle it is saved – while also being practically operable. Steel already offers the most reliable data basis for this and is therefore the right starting point.”
Prof. Tim Büthe of the Chair of International Relations at the Munich School of Politics and Public Policy at TUM sees opportunities for a political agreement: “At its core, the dispute between the factions in the European Parliament is not about whether a vehicle’s life cycle should be captured by regulation, but about how binding that should be. This distinction is often lost in the political sharpening of the debate, but it is decisive for whether a pragmatic solution can still be found in the coming months.”
Prof. Dr.-Ing. Johannes Fottner
Chair of Materials Handling, Material Flow, Logistics
TUM School of Engineering and Design and TUM School of Management
j.fottner@tum.de
Prof. Dr. Magnus Fröhling
Chair of Circular Economy and Sustainability Assessment
TUM Campus Straubing for Biotechnology and Sustainability and TUM School of Management
magnus.froehling@tum.de
Prof. Dr. Tim Büthe
Chair of International Relations
Munich School of Politics and Public Policy at TUM
TUM School of Social Sciences and Technology and TUM School of Management
buthe@hfp.tum.de
Technical University of Munich (ed.): “Defossilisation, Not Decarbonisation: Toward a Lifecycle-Based Standard for Automotive Greenhouse Gas Regulation.” White Paper, Munich, September 2026. DOI 10.14459/2026md1861116, https://mediatum.ub.tum.de/doc/1861151/1861151.pdf
https://www.picdrop.com/astrideckert/5un8st7zcj - Photos for download - Passwort: 7EPEWNF4, Credit: Astrid Eckert / TUM
https://transport.ec.europa.eu/transport-themes/action-plan-future-automotive-se... - European Commission’s Automotive Package
https://www.mission-networks.tum.de/en/circular-economy/home/ - TUM Mission Network CirculaTUM
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