英文立场文件——重型车辆生命周期评价方法

July 2025 ACEA position paper Heavy-duty vehicle LCA methodology www.acea.auto 1 INTRODUCTION This position paper presents the industry’s perspective on DG CLIMA assessment on EU 2024/1610 HDV CO2 regulation Article 15 (l)i: “the possibility of developing a common Union methodology for the assessment, and the consistent data reporting, of the full lifecycle CO2 emissions of new heavy-duty vehicles that are placed on the Union market.” ACEA acknowledges the importance of Life Cycle Assessment (LCA) as a tool for understanding the environmental impacts of vehicles and supports the extensions of harmonisation efforts on national and international level to HDVs. However, the application of LCA methodologies to heavy-duty vehicles (HDVs) present significant limitations that hinder its effectiveness as a potential regulatory tool. This position paper outlines ACEA’s perspective on why currently LCA is not suitable for regulatory target setting for HDVs. The below mentioned consideration s