Dear President von der Leyen,

We write this open letter on behalf of associations and companies from the sustainable transport sector in Central Eastern and Southern European countries to express our concern that the flexibilities you are considering for the 2025 CO2 limits will worsen today’s “two-speed Europe” for electric vehicle roll-out and undermine their critical role as as an investment framework.

If this change happens, it is the less developed e-mobility markets—primarily in Central, Eastern, and Southern Europe—that will pay the price. Without a strong, guiding investment & regulatory framework, our regions will see fewer EV sales and struggle to attract capital and build infrastructure, further widening the existing gap between EU countries. This will reinforce fragmentation, leaving half of Europe behind in the shift to clean transportation.

The CO2 regulation is an investment framework for the electrification economy that will drive Europe’s competitiveness, which has already led to hundreds of millions of EUR of public and private capital being invested in CEE/SEE countries. Adding in uncertainties (‘flexibilities’) now will make it far more difficult to achieve a common EU-wide industrial policy, which will in turn undermine the ability of emerging markets to leverage the transition to sustainable mobility as a driver of economic growth, innovation, and competitiveness.

Indeed, in this period of geopolitical turbulence, harnessing energy produced in Europe to power European homes, vehicles, and industry, is more important than ever. Europe’s industrial policy should be stable, focused, and coherent.

We ask you to maintain the ambition of the 2025 CO2 limits to support demand in our countries, combined with stronger EU and national demand measures.

If this year’s CO2 limits are relaxed, our countries will face a significantly greater impact than the leading electric vehicle markets in Western Europe. Experience shows that, without strong, guiding investment and regulatory framework, the development of e-mobility will accelerate in already established markets while lagging regions struggle to catch up. Without targeted support, the gap in Europe’s electric vehicle adoption will continue to widen, leaving many countries behind in the transition.

Last year’s electric vehicle registration data already shows this divide in practice:

• In 15 Central Eastern Europe and Southern European countries, only 191,000 electric vehicles were registered
• In the other 12 EU countries, 1.256 million battery electric vehicles were registered – with EVs making up over 15% of total vehicle registrations across those markets

Without the clear direction and guidance of the EU’s CO2 limits, our forecasts show that this trend will persist. For example, without the 2025 targets, Poland’s electric vehicle market will see only minimal growth in 2025, increasing from 3% to just 4%—compared to nearly 7% if the limits remain in place.

We acknowledge that CO2 limits alone will not resolve market challenges in our countries and that our governments must also take responsibility by implementing smart and sustainable incentives to support the electric vehicle transition. But they are an essential enabler of both the EV market and Europe’s industrial goals.

Therefore, it is crucial that the European Commission’s Automotive Action Plan prioritizes demand stimulation measures across all EU Member States. However, the 2025 CO2 limits must remain in place to ensure that affordable electric vehicles will be actively promoted in all markets, not just the most developed ones.

Yours sincerely,

Maciej Mazur, Managing Director, PSNM – Poland electric vehicle association

Patrik Krizansky, Director, SEVA – Slovakia electric vehicle association

Francesco Naso, Secretary General, Motus-E – Italy electric vehicle association

Arturo Perez de Lucia, General Manager, AEDIVE – Spain electric vehicle association