The new CO2 obligations for heavy-duty vehicles will enter into force on 10 September 2026. Commission Delegated Regulation (EU) 2026/1282 expands the information that manufacturers of trucks, buses, coaches, trailers and semi-trailers must report. The reform also affects national authorities and certain technical services, while suppliers and other companies in the sector will need to adapt their processes accordingly.
However, the Regulation does not introduce a new emissions limit. Instead, it changes the information system used to calculate, verify and monitor compliance with the European CO2 reduction targets.
Which Regulation changes the CO2 obligations for heavy-duty vehicles?
Commission Delegated Regulation (EU) 2026/1282 amends and corrects Annexes IV and V to Regulation (EU) 2019/1242, which sets the European CO2 emission standards for new heavy-duty vehicles. The update mainly responds to three earlier developments in the legal framework:
- The extension of Regulation (EU) 2019/1242 to new groups of trucks, buses, coaches, trailers and semi-trailers through Regulation (EU) 2024/1610.
- The inclusion of hydrogen-powered vehicles and other technologies in the emissions determination methodology through Regulation (EU) 2025/258.
- The development of the rules governing the energy performance of trailers and semi-trailers.
To understand the background to these changes, you can read our analysis of the implications of Regulation (EU) 2025/258 for vehicle manufacturers and suppliers.
As a result, the reform requires closer coordination between legal, type-approval, engineering, quality, purchasing and information systems departments. Companies operating in several Member States may therefore require advice on European Regulatory Law to determine which obligations apply according to the vehicle category and the relevant stage of production.
Timetable for the CO2 obligations applying to heavy-duty vehicles in 2026
The date of entry into force, the reporting period and the deadline for submitting information are three different points in time. It is therefore important to distinguish between them in order to avoid mistakes when preparing the data.
| Date or period | What happens? |
|---|---|
| 21 August 2026 | Commission Delegated Regulation (EU) 2026/1282 is published in the Official Journal of the European Union. |
| 10 September 2026 | The amendments to Annexes IV and V to Regulation (EU) 2019/1242 enter into force. |
| From 1 July to 30 June | This is the annual period used to determine which vehicles must be included in the relevant report. |
| 30 September of each year | As a general rule, this is the deadline for submitting the information to the European Environment Agency. |
Companies should not wait until September to check their information. The safest approach is to review the data throughout the manufacturing process and before closing the file for each vehicle. This makes it easier to correct any differences between the type-approval documents, VECTO files, installed components and the information that will ultimately be reported.
Why is it important to improve vehicle CO2 data?
According to the latest statistics, heavy-duty vehicles account for a significant proportion of transport emissions. In 2022, heavy-duty road transport generated 27.5% of CO2 emissions from road transport, even though heavy-duty vehicles represented only 2.4% of the total vehicle fleet. Their emissions also accounted for more than 6.9% of the European Union’s total emissions. At the same time, the transition towards zero-emission vehicles remains gradual.
In 2024, zero-emission vehicles represented 3.9% of new heavy-duty vehicle registrations. For trucks weighing more than 12 tonnes, the proportion was approximately 1.2%, while zero-emission buses and coaches accounted for around 17% of new registrations. According to Eurostat, road freight transport in the European Union also increased by 0.9% in 2025 compared with 2024.
Who is affected by the CO2 obligations for heavy-duty vehicles?
The reform affects several different parties. However, they are not all responsible for reporting the same information.
Manufacturers of heavy-duty vehicles
Manufacturers must report the data listed in Annex IV for heavy-duty vehicles whose CO2 emissions and fuel or energy consumption have been determined in accordance with the applicable rules. The scope includes medium and heavy trucks in category N, buses and coaches in category M, and trailers and semi-trailers in category O. However, not every parameter applies to every vehicle.
Manufacturers of completed vehicles and category M vehicles
For buses and coaches, the rules strengthen the identification of the manufacturer of the completed vehicle. Member States must report the manufacturer’s name and World Manufacturer Identifier, known as the WMI. If the third character of the WMI is the number 9, certain characters from the VIS section must also be reported in order to identify the manufacturer correctly.
Component manufacturers and suppliers
The reform does not make every supplier directly responsible for submitting the annual report to the European Environment Agency. However, supplier information now forms part of the data that the vehicle manufacturer must retain and report. Therefore, supply agreements, component certificates, technical documentation and data flows must make it possible to identify the name, address and trade name of the relevant supplier.
Designated technical services
Where a designated technical service determines the CO2 performance of vehicles in categories O3 and O4 under Commission Implementing Regulation (EU) 2022/1362, it may also be responsible for transmitting the data.
In that case, it must provide the European Commission and the European Environment Agency with its name, the Member State that designated it, the contact person responsible for uploading the data, the manufacturers on whose behalf it acts and the relevant WMIs.
National authorities
Member States remain responsible for reporting information to the Commission on heavy-duty vehicles registered for the first time. For category M vehicles, the new rules add information that makes it possible to identify the manufacturer of the complete vehicle or the manufacturer that completed the vehicle.
Fleet managers
A fleet manager that only purchases and operates vehicles does not become responsible for submitting the data required by Commission Delegated Regulation (EU) 2026/1282 for that reason alone.
Nevertheless, the information may be used to compare models, calculate operating costs, prepare tenders, support ESG commitments and, in the future, verify consumption figures.
Summary table
| Category | Vehicles included | Particularly relevant aspects |
|---|---|---|
| Category N | Medium and heavy trucks | Engine, transmission, axles, tyres and propulsion systems |
| Category M | Buses and coaches | Manufacturer identification, WMI, VIS and propulsion system |
| Categories O3 and O4 | Heavy trailers and semi-trailers | Energy performance, specialised configurations and the possible involvement of a technical service |
The inclusion of a category does not mean that every reporting field applies to every vehicle within that category.
What new data must manufacturers report?
The reform replaces and expands the table of additional information contained in Annex IV. The data can be divided into six main groups, which are explained below.
Identification of the vehicle and the responsible party
The Regulation strengthens the identification of the manufacturer to which the vehicle is attributed, the relevant trade name and, for category M vehicles, the manufacturer and its WMI. The contact person responsible for electronically submitting the data must also be identified. In other words, it is not enough to know the data itself. The company must also be able to identify who validated it and who reported it.
Data on transmissions, axles and tyres
For the relevant vehicle categories, the following information must be reported:
- The name and address of the transmission manufacturer.
- The trade name of the transmission manufacturer.
- The name and address of the axle manufacturer.
- The trade name of the axle manufacturer.
- The name and address of the tyre manufacturer.
- The trade name of the tyre manufacturer.
This information makes it possible to link the simulation result to the components actually installed in the vehicle. If several components of the same type have been produced by different companies, the relevant information must be reported for each manufacturer.
Combustion engine and test results
For certain trucks and category M vehicles, the required or clarified information includes the engine type-approval number, the name, address and trade name of the internal combustion engine manufacturer, the mass CO2 emissions and the engine’s fuel consumption under the WHTC and WHSC test cycles. For dual-fuel vehicles, the CO2 information must be provided separately for each fuel.
Electric, hybrid and hydrogen propulsion and energy storage
The table introduces new fields to identify the technologies used in electric, hybrid and hydrogen-powered vehicles.
| Technology or component | Information to be identified |
|---|---|
| Electric machine system | Name of the manufacturer and trade name |
| Integrated electric powertrain component (IEPC) | Components forming part of the integrated electric system |
| Type 1 integrated hybrid powertrain component (IHPC) | Components forming part of the integrated hybrid system |
| Fuel cell | Name of the manufacturer and trade name |
| Electric energy storage system | Name of the manufacturer and trade name of the system, including the batteries used by the vehicle |
In this way, the rules reflect the technological development of the sector and no longer focus exclusively on vehicles fitted with conventional combustion engines. They also make it possible to identify more precisely the components used in electric, hybrid and hydrogen-powered vehicles.
Specific parameters for trailers and semi-trailers
For category O vehicles, mainly trailers and semi-trailers, additional fields are introduced to identify particular configurations and characteristics.
| Configuration or characteristic | Information to be reported |
|---|---|
| Refrigeration unit | Whether the vehicle has a combustion engine used to power the refrigeration unit |
| Thermal insulation | The K coefficient for thermal insulation of certain trailers holding an ATP certificate |
| Moving floor | Whether the vehicle has a powered moving floor |
| Internal body height | Whether the internal height exceeds 3.5 metres |
| Second deck | Whether there is a second deck occupying more than 50% of the vehicle’s internal length |
| Combined transport | Whether the vehicle is certified for rail-road or ferry-road combined transport |
| Transport of dangerous goods | The ADR certificate number for certain trailers classified as EX/III |
| Other specific technologies | Optional information on technologies or configurations not covered by the other fields |
These data make it possible to describe the configuration of each trailer or semi-trailer more accurately. They also help ensure that the energy performance calculation and the information reported correspond to the characteristics of the vehicle that was actually manufactured.
Reporting data: who must submit the information?
As a general rule, the manufacturer must submit the information to the European Environment Agency. The contact person designated by the company sends the data and also notifies the European Commission and the Agency. General deadline is 30 September of each year. The report must include the vehicles calculated or simulated during the relevant reporting period.
For certain O3 and O4 trailers and semi-trailers, a designated technical service may submit the data instead of the manufacturer. In addition, every data item must be verifiable. The company must retain the documentation needed to show what information was used, which certificate or file it came from, who reviewed it, which version was submitted and who made the submission.
Therefore, if an error is identified or an authority requests information, the company will be able to explain where each data item came from and how it was reported. This traceability should form part of the company’s European regulatory compliance system, with procedures that make it possible to review, retain and correct the information both before and after submission.
What is the relationship between type approval and VECTO?
VECTO is a European tool that simulates the energy consumption and CO2 emissions of heavy-duty vehicles. To perform the calculation, it takes into account the vehicle’s characteristics, including the engine, transmission, axles, tyres, aerodynamics, load and type of journey. It also considers electric, hybrid and hydrogen systems.
Type approval certifies the vehicle’s technical data and values. VECTO then uses that information to calculate its energy consumption and emissions. Commission Delegated Regulation (EU) 2026/1282 does not change the type-approval rules or the way VECTO operates. Instead, it changes how the results must be identified, retained and submitted to the European authorities.
Terms and abbreviations
| Abbreviation | Simple explanation |
|---|---|
| VECTO | European tool used to simulate the energy consumption and CO2 emissions of heavy-duty vehicles |
| WMI | International code that identifies the vehicle manufacturer |
| VIS | Section of the vehicle identification number that helps identify the vehicle and, in certain cases, the manufacturer |
| VIF | Vehicle information file containing the technical information used during the calculation or simulation |
| VIN | Unique vehicle identification number |
| IEPC | Integrated electric powertrain component forming part of the vehicle’s propulsion system |
| IHPC | Integrated hybrid powertrain component combining different forms of propulsion |
| WHTC and WHSC | Test cycles used to measure engine consumption and emissions |
| O3 and O4 | European categories for heavy trailers and semi-trailers |
How will the data be checked?
The data will be reviewed at both national and European level. First, Member States will report information on heavy-duty vehicles registered for the first time. This information will then be compared with the data submitted by manufacturers. The annual reporting period runs from 1 July to 30 June.
The authorities may also select certain vehicles to check whether the declared CO2 values are correct. When selecting vehicles, they may consider possible risks connected with the engine, transmission, axles, tyres or propulsion system.
For this reason, it is important to identify the manufacturer and trade name of each component. If several vehicles have the same problem, this information will help determine whether the error is linked to a particular part or supplier. If the authorities identify differences between the declared and verified values, they may request an explanation and require the information to be corrected. These differences may also be taken into account when calculating the manufacturer’s average emissions.
The data reported will be used to determine whether each manufacturer complies with its CO2 targets. If a manufacturer exceeds its target, it may have to pay an excess emissions premium. Furthermore, submitting incorrect or incomplete information may create problems during type approval, an inspection or another administrative procedure. More information is available in our article on corporate liability for failure to comply with European Union rules.
Practical cases that may affect CO2 reporting for heavy-duty vehicles
The following examples help explain the types of problem that may arise. However, the appropriate solution will depend on the vehicle, its technical characteristics and the documents available.
Tyres are replaced after the VECTO simulation
A manufacturer performs the VECTO simulation using data for a specific tyre model. However, before production is completed, the supplier replaces that tyre with another model that appears to be equivalent. Although the change may seem minor, the data used in the simulation may no longer correspond to the vehicle that was actually manufactured. An error may also arise in the identification of the component manufacturer or trade name.
💡 To avoid this problem, every replacement should be reported. The manufacturer should then determine whether the change requires a new simulation, an update to the technical documentation or a correction of the data before it is submitted.
A bus is reported with the wrong WMI
One company manufactures the base vehicle, while another installs the bodywork and completes the bus. However, the report identifies only the original manufacturer and does not include the WMI of the company that completed the vehicle. This error may result in the bus being attributed to the wrong company. In addition, the information submitted by the manufacturer may not match the data reported by the Member State. Before the data is submitted, the certificate of conformity, the vehicle identification number or VIN, the WMI, the relevant VIS characters and the documents for each stage of manufacture should therefore be compared.
💡 It is also advisable to appoint a person responsible for reviewing data relating to vehicles completed by another company.
Data for an O3 or O4 trailer is not submitted
A technical service calculates the CO2 performance of a trailer on behalf of the manufacturer. However, neither party has clearly stated who is responsible for submitting the information to the European Environment Agency. In this situation, the manufacturer may believe that the technical service is responsible for the submission, while the technical service may understand that its role ends once the performance has been calculated. As a result, the data could be submitted twice or, more seriously, not submitted at all.
💡 To prevent this, the parties should agree in writing who prepares the data, who checks it, who submits it and who will act as the contact person. They should also retain evidence showing that the submission was completed correctly.
A fleet compares vehicles using only VECTO values
A fleet manager compares several trucks and chooses the one with the lowest VECTO value, assuming that this vehicle will consume less fuel or energy on every route. However, VECTO uses standardised conditions. Actual consumption also depends on the type of route, the weight transported, the temperature, aerodynamics, traffic conditions and driving style.
Therefore, VECTO values are a useful starting point, but they should not be used in isolation. The company should compare them with real-world operating data, vehicle trials, route characteristics, energy costs, maintenance requirements and a calculation of the total cost of ownership. This approach will help the company choose the vehicle that best meets its actual operational needs.
Relationship with the European emission reduction targets
The information reported makes it possible to calculate the average emissions of each manufacturer’s new vehicles. The European Commission can then use these data to determine whether companies are meeting the targets established by Regulation (EU) 2019/1242. As a general rule, the legislation requires emissions reductions of 45% from 2030, 65% from 2035 and 90% from 2040. However, the precise timetable may vary according to the type of vehicle.
Different targets apply to new urban buses. By 2030, at least 90% must be zero-emission vehicles. From 2035, this percentage must reach 100%. Trailers and semi-trailers will also be subject to their own efficiency targets from 2030. In addition, Regulation (EU) 2026/1046 introduces a temporary measure for the reporting periods from 2025 to 2029. During those years, manufacturers may earn credits when their emissions are below their applicable annual target.
What does the Regulation mean for suppliers and fleet managers?
Suppliers will have to provide more information about the components they supply. The data must be accurate, up to date and supported by certificates or other documents. It must also be possible to link each component to the vehicle in which it was installed. This traceability will make it possible to verify whether the data used in VECTO correspond to the parts actually fitted to the vehicle. It will also help identify whether several errors are linked to the same product or supplier.
For this reason, contracts should be reviewed. They should specify who is responsible for the accuracy of the data, how a change of component must be reported and how long the relevant documents must be retained. The contract should also explain how the parties will cooperate if an inspection takes place or additional information is requested.
For fleet managers, the new rules may be useful when purchasing or financing a fleet, calculating costs and planning emission reductions. Nevertheless, VECTO values do not necessarily represent the vehicle’s actual consumption, as this will also depend on the route, load, temperature, traffic and driving style, among other factors.
Is your company ready for the new CO2 obligations for heavy-duty vehicles?
Adapting to Commission Delegated Regulation (EU) 2026/1282 requires companies to verify the type-approval information, VECTO files and installed components for each vehicle. They must also determine who prepares the data, who reviews it and who submits it. Correcting problems before submission reduces the risk of errors and facilitates cooperation between legal, technical and regulatory compliance departments.
Our law firm advises vehicle manufacturers, suppliers, operators and public authorities on European Regulatory Law, European Union Law, type approval and compliance with European Union obligations concerning CO2 emissions from heavy-duty vehicles.
If your company needs to determine whether the Regulation applies to its activities, review its data, amend its contracts or prepare its next report, you can contact us at info@arthurmarin.com or by telephone on +32 465 34 53 45.
Frequently asked questions about Regulation (EU) 2026/1282
What exactly happens on 10 September 2026?
Commission Delegated Regulation (EU) 2026/1282 enters into force, twenty days after its publication in the Official Journal of the European Union. From that date, the amendments and corrections to Annexes IV and V to Regulation (EU) 2019/1242 apply. However, the specific application of each parameter will depend on the vehicle category, technology and date of determination or simulation.
Does the Regulation impose a new CO2 limit on 10 September 2026?
No. It updates the data that must be monitored, reported and published. The emission reduction targets arise from Regulation (EU) 2019/1242 and its subsequent amendments.
Does the Regulation also affect bus manufacturers?
Yes. It strengthens the identification of manufacturers of complete or completed category M vehicles by requiring their name, WMI and, in certain cases, additional VIS characters.
Must suppliers submit the report directly?
Not necessarily. Responsibility for submitting the data normally lies with the vehicle manufacturer or, for certain O3 and O4 trailers, a designated technical service. However, manufacturers need reliable information from their suppliers in order to comply correctly with the CO2 obligations applying to heavy-duty vehicles.
Do fleet managers have a new reporting obligation?
Not merely because they operate a fleet. The Regulation applies to the monitoring system for new heavy-duty vehicles, manufacturers, Member States and certain technical services. Nevertheless, fleet operators may be indirectly affected through contractual requirements, procurement procedures or future systems for collecting real-world consumption data.
Will all reported data be made public?
No. The Regulation excludes certain commercially sensitive information from publication. However, this does not mean that the data no longer have to be submitted to the Commission or the European Environment Agency when Annex IV requires their transmission.
What happens if an error is identified after the data have been submitted?
The company must assess the type of error, the affected vehicle and reporting period, and the information that has already been submitted. If a correction is required, the company should document the original data, the cause of the error, the corrected version, the person who validated it and the date of the new submission.
Official sources
- Commission Delegated Regulation (EU) 2026/1282.
- Consolidated Regulation (EU) 2019/1242.
- Regulation (EU) 2024/1610 on strengthened CO2 reduction targets.
- Regulation (EU) 2026/1046 on emission credits for 2025-2029.
- Commission Implementing Regulation (EU) 2025/35 on in-service verification.
- European Commission: lorries, buses and coaches.
- European Commission: data and market information on zero-emission heavy-duty vehicles.
- Eurostat: road freight transport statistics.
Written and reviewed by Diego Espinosa, a lawyer admitted to the Brussels and Spanish Bars, specialising in European Union law, regulatory law and international trade.
