LEVA-EU Position on Technology Neutrality, LEVs, and Sustainable Fuels

The European Roundtable on Climate Change and Sustainable Transition (ERCST) hosted the Brussels event “Public Debate – Flexibility in the EU’s Road Transport Decarbonization Policy: Electrification and Sustainable Fuels“. One of the panel members was LEVA-EU Managing Director, Annick Roetynck. At the event, she made the statement on technology neutrality, LEVs and sustainable fuels.

At LEVA-EU, we believe that the future of transport is not only electric but also light. Together with our members, we advocate for a massive transition away from heavy vehicles towards light electric vehicles (LEVs). The LEV offer is already extensive, including e-scooters, e-(cargo)bikes, speed pedelecs, e-mopeds/motorcycles, and vehicles in the L5/L6/L7 categories.

The Emission-Saving Potential of LEVs

In 2022, LEVA-EU commissioned the LEV4Climate study from DLR on the emission-saving potential of LEVs. Using a theoretical model for Germany, researchers calculated that:

• 76% of all motorised car trips could be substituted by one or another type of LEV.
• This would replace around 50% of car mileage.
• On average, LEV greenhouse gas emissions per kilometre are only about 12% of those from passenger cars.

The result? Substitution at this scale could deliver a 44% reduction in CO₂-equivalent emissions.

This evidence shows that under a genuinely technology-neutral policy, LEVs would be among the most effective tools for decarbonisation, energy efficiency, and congestion reduction. Yet in practice, EU policy frameworks remain biased toward “big vehicle” solutions, leaving LEVs undervalued and under-supported.

The Barriers Holding Back LEVs

Despite their huge potential, the substitution of car and van trips by LEVs faces technical, economic, and social challenges that prevent the right policy approach from taking root.

Technical Challenges

• Regulatory Misfit
  Current EU vehicle legislation, including Regulation 168/2013 and the Machinery Directive, was designed for mopeds, motorcycles, or industrial machines — not LEVs. This creates unnecessary technical barriers and leaves the LEV sector without proper consultation channels at EU level.
  LEVA-EU has repeatedly called for a dedicated LEV Regulation and a Commission expert group on LEVs, both backed by EGUM. Yet the Commission prioritises traditional automotive industries, sidelining LEVs.
• Infrastructure Gaps
  Road space remains dominated by cars. LEVs are either pushed onto already inadequate cycling infrastructure or forced to mix with heavier, faster traffic — compromising safety and rider comfort. Although many cities are rethinking car use, there is no consistent redesign of infrastructure to integrate LEVs.
• Legislative Burden and Fragmentation
  EU technical legislation for LEVs is overly complex and fragmented, with dozens of uncoordinated rules. Member States add further requirements, undermining the single market. The result: higher costs, legal uncertainty, and slower scaling for LEV companies.

Economic Challenges

• Unfair Competition
  Illegal or non-compliant vehicles continue to reach the market, undercutting companies that invest heavily in legal compliance. Weak market surveillance leaves issues such as unsafe e-scooters and “fat bikes” unresolved.
• Unbalanced Subsidies and Incentives
  Public funding overwhelmingly favours cars. LEVs, despite their efficiency and sustainability benefits, remain under-supported in comparison.
• Trade Distortions
  Anti-dumping measures on bicycles and e-bikes, together with inconsistent customs classifications, create unnecessary costs and uncertainty. These measures restrict consumer access, stifle innovation, and limit diversity in the LEV market.

Social Challenges

• Public Perception
  Transport decarbonisation policies remain car-centric, meaning LEVs are overlooked in public and political debates. Their role in cutting emissions, reducing congestion, and lowering mobility costs remains undervalued.
• Equity and Accessibility
  LEVs offer affordable, flexible mobility for people without cars, those living in dense cities, or individuals facing transport poverty. Adapted solutions can also serve people with disabilities. If car-centric policies persist, these social benefits risk being lost.

LEVA-EU Position: Decarbonisation policy must go beyond electrifying existing car fleets. A modal shift toward LEVs is essential, backed by adapted regulation, fair incentives, and infrastructure designed for all vehicle types.

Sustainable Fuels and Electrification: Complementary or Competitive?

From the LEV sector’s perspective:

• Short-distance, light-duty mobility is best served by electrification and weight reduction. LEVs consume only a fraction of the energy of cars per kilometre and can run entirely on renewable electricity.

The Competitive Dimension

In urban mobility, promoting sustainable fuels for cars risks diverting policy support, subsidies, and infrastructure investment away from electrification and weight reduction. This strengthens the car-centric system instead of enabling the modal shift to LEVs that sustainable cities urgently need.

LEVA-EU Position: While sustainable fuels and electrification may be complementary at the system level, they become directly competitive in practice if treated as equal solutions for all transport modes. For urban and light transport, electrification through LEVs must be prioritised for its unmatched efficiency, affordability, and decarbonisation potential.

The Way Forward

Light electric vehicles represent one of the most effective, immediate, and scalable solutions for decarbonising transport, cutting emissions, and making mobility more accessible. But for this potential to be realised, policymakers must:

• Establish a dedicated LEV regulatory framework.
• Ensure fair incentives and funding for LEVs.
• Redesign infrastructure for a variety of small, light vehicles.
• Actively promote LEVs as a mainstream mobility solution, not a niche alternative.

The transition to sustainable transport cannot be achieved by electrifying heavy cars alone. It requires a bold shift towards light, efficient, and accessible electric mobility.