In its latest report published on Wednesday, the International Council on Clean Transportation (ICCT) concludes Europe is close to being on track to meet its near-to‐mid-term vehicle emission goals. The report says only a relatively small further reduction in fleet CO₂ emissions – some 9 grams CO₂/km- is needed to hit the interim target for 2027.
“Electrification in the EU is not only on track, it is actually picking up speed, Peter Mock, managing director of ICCT Berlin, told German press agency dpa. According to ICCT, the EU has now become a net exporter of fully electric vehicles (BEVs) and is the world’s second-largest producer of EVs. In the first half of 2025, BEVs reached a record market share of 17 percent on average in Europe.
Danger of delays
However, ICCT warns that delays in electrifying the transport sector, as asked for by (mainly German) carmakers, could endanger the competitiveness of European industry, according to the current analysis. “Manufacturers should worry less about the next EU targets and more about their global competitiveness,” said Mock.
“Every delay undermines the confidence of investors and consumers, while other markets—especially China—continue to grow in importance, the ICCT director emphasized.
The ICCT study is titled “The EV Transition Check: Measuring progress towards zero-emission for passenger cars in the European Union”. It looks at how far the EU is in its transition to electric vehicles (EVs) for light-duty vehicles (passenger cars and vans), and how well it is tracking against emissions targets.
To that extent, it compares current data on EV uptake, fleet emissions, supply chain, and battery production with the requirements under EU legislation. It uses various performance indicators to see where progress is being made (or lagging), what the EV registration rates are, the battery supply and production chain, and how fast ‘zero-emission’ vehicle (ZEV) uptake is happening.
“Automakers are on track to meet the EU CO2 performance targets for new vehicles, relying mostly on electric cars as a compliance option,” the report says. “Among the major markets, EV uptake has been strong in Germany and France and has recently increased in Italy and Spain. Several smaller markets show particularly high EV market shares.”
These markets, besides pioneering EV country Norway, with 94% electric car registrations, include Denmark (63%), the Netherlands (35%), Sweden (34%), and Belgium (32%).
Belgium being among the top five is merely due to new company car sales, as these are required by law to be zero-emission from 2026 on, and companies mostly have adopted an EV-only car policy earlier on to replace existing fleets.
Belgium: 82% company cars
According to the latest figures available from Statbel, the Belgian statistics office, as of August 1, 2024, there were 254,240 fully electric cars registered in Belgium. Of those, 208,542 (approximately 82%) were registered by companies. And the remaining 45,348 (17.8%) were bought by private owners.
Looking at the car manufacturers, on average, they are 9 g/km (about 9%) from their 2025–2027 fleet-average CO2 target, the report says. However, not everybody is doing as well. That’s why the pooling systems exist, giving a somewhat distorted image when looking at the monthly ICCT European Vehicle Market Monitor.
Pooling to avoid fines
Under EU law, each manufacturer (or “pool”) has to meet a fleet-average CO₂ target for new passenger cars (and vans). Instead of going it alone, companies can form pools: their combined sales are averaged, and the pool as a whole must meet the CO₂ target.
Each year, manufacturers must notify the EU by September 30 of the year before if they want to join a pool. For instance, if Nissan, which is the worst performer in the ICCT ranking, didn’t formally notify that it wanted to pool with Renault, it appears as a separate pool in ICCT’s compliance tracking.
Historically, Renault and Nissan often did pool (given the Renault-Nissan Alliance). Still, Renault may prefer to stand alone, as Nissan, by contrast to the French brand, has very few EVs left in its EU lineup (Leaf aging, Ariya low volumes, ICE SUVs dominating). Alone, it is some 30 g/km over target in 2025 snapshots.
Mercedes: textbook pooling example
Mercedes is a textbook example of why pooling exists. If you look only at Mercedes-Benz brand cars without pooling with Volvo and Polestar, the ICCT shows they are well above their 2025 CO₂ target. In early 2025, Mercedes was about +27 g/km behind its brand-level target because their fleet is still dominated by large ICE and PHEV SUVs and sedans.
BEV share is rising (EQE, EQS, EQA, EQB, etc.), but not yet at a pace comparable to competitors like BMW or Volvo, due to a more conservative buyer base. Volvo has a very high BEV share, already above 40% in 2025, despite declining EV sales.
It is already below target, with 27 to 35 g/km, while its sister brand, Polestar, is 100% BEV. By pooling with them, Mercedes benefits: avoids heavy fines and buys time to ramp its BEV portfolio.
Standing alone, Mercedes would risk huge compliance fines: every g/km gap × 600,000 to 700,000 cars × €95 = hundreds of millions of euros. No wonder Mercedes-Benz CEO Ola Källenius, currently president of ACEA, is the loudest in arguing to postpone or rethink the EU ban on new internal combustion engine (ICE) cars from 2035.
No wonder, too, on the other hand, that Källenius’ colleague CEOs in the pool, Håkan Samuelsson (Volvo) and Michael Lohscheller (Polestar), are loudly advocating the opposite and urging the EU not to give in to the pressure.
BMW manages on its own
Mercedes’ longtime competitor from Munich, BMW, is doing far better. It goes alone, but includes its sub-brands Mini and Rolls-Royce, and is already compliant in 2025 YTD with a significant BEV mix of 25–26% in July.
Other best-in-class pools are Hyundai with strong Kona, Ioniq 5/6 sales, and Kia being the accelerator with EV6 and Niro EV, doing even better with the new, more affordable EV3.
Volkswagen is still the furthest behind in 2025, even with pooling with all its brands, as the gap remains 15 to 17 g/km. Audi drags averages up with heavier ICE sales (+35/km gap to close), while Cupra, as a SEAT brand alone, helps to lower CO₂, being 15 g/km below target. No wonder if you’re pool also includes Porsche, Bentley, or Lamborghini.
Toyota’s hybrid obsession
Toyota knows very well why it still wants to buy credits from Tesla, by partnering with the American electric-only brand. It has a very low BEV share of 6% of new registrations and a fleet still dominated by hybrids that it loudly advocates (Corolla, Yaris, RAV4, CH-R). These reduce fuel use but still emit CO₂ under WLTP.
Toyota alone would be heavily non-compliant with a 20 g/km gap, facing billions in fines. Stellantis would still miss the target by 10 to 15 g/km, but the shortfall is more minor than Toyota’s. It has a BEV share of 10 to 12% across brands (Peugeot e-208, Opel Corsa-e, Fiat 500e, Jeep Avenger), but still large volumes of ICE cars.
Other laggards are besides Nissan, Ford (+28 g/km), Mazda (27 g/km), or Suzuki (13 g/km). They chose not to pool at all for 2025 and risk full exposure to EU fines later on if the gap persists through the 2025–2027 averaging period. It explains Ford’s aggressive plan to launch seven new EV models in Europe by 2027, but in 2025, it’s clearly behind.
