Jaunumi

Opinion on European Commission proposed Regulation Clean Corporate Vehicles09.09.2025 // 8:52

We fully support the European Union’s climate objectives and recognize the strategic importance of corporate fleets in advancing the transition to zero-emission mobility. As an active contributor to Latvia’s transport ecosystem, members of the Latvian Car Rental Association have already undertaken substantial investments in zero-emission vehicles (ZEVs), and associated infrastructure. However, we wish to express several concerns regarding the feasibility and proportionality of the proposed regulatory framework, particularly in the context of Latvia’s current infrastructure and market conditions.

 

Infrastructure Limitations

Latvia’s public fast-charging network remains underdeveloped. More than 60% of the EU’s public charging infrastructure is concentrated in just three Member States—namely the Netherlands, Germany, and France—which together account for only around 20% of the EU’s total territory. In contrast, the remaining 39% of public charging stations are dispersed across the other 80% of the EU, highlighting a significant imbalance in infrastructure deployment (DG GROW, 2024, Dashboard towards zero-emission vehicles #route35). This presents substantial operational challenges for rental zero-emission vehicles (ZEVs).

Moreover, the proposed regulation would disproportionately impact short-term mobility service providers—including car rental, car sharing, and ride-hailing companies—due to the critically low level of charging infrastructure at key transport hubs such as airports, railway stations, and ports, as well as within urban environments. This challenge is particularly acute for long-distance and cross-border travel, where reliable access to fast-charging stations is essential for maintaining operational efficiency, ensuring customer convenience, and supporting the broader transition to zero-emission fleets.

Consumer Behavior and Utilization

Efforts to promote zero-emission vehicles (ZEVs), in the short-term rental market have yet to yield significant results, with utilization rates still falling below 40%. This is notably lower than the industry norm of 65–80% for internal combustion engine (ICE) vehicles. Utilization reflects the proportion of time a vehicle is actively rented compared to its availability in the fleet. Lower figures for ZEVs suggest they are idle more often, generating less revenue and are used less efficiently than ICE alternatives.

Both domestic and international customers consistently report concerns regarding limited driving range, prolonged charging times, and the inconsistent reliability of public charging infrastructure. Notably, even private ZEV owners often opt for ICE vehicles when renting for travel purposes, particularly for longer distances or cross-border journeys.

While service providers have undertaken extensive sustainability campaigns to promote electric mobility, demand for ZEVs in the short-term rental segment remains subdued. This is largely attributable to the profile of rental customers—many of whom are either infrequent drivers or foreign nationals—who encounter difficulties locating and accessing charging stations, as well as navigating fragmented payment systems associated with electric vehicle charging.

Cost Implications and Strategic Supply Dependencies

ZEV mandates will significantly raise fleet costs and deepen the EU’s reliance on China. Compared to internal combustion engine (ICE) vehicles and plug-in hybrid electric vehicles (PHEVs), ZEVs are more expensive to purchase and retain lower residual values, resulting in higher total cost of ownership and increased rental and leasing prices for consumers. At the same time, China dominates both the affordable ZEV market and the supply of critical battery materials such as lithium and rare earth elements. This dependence contradicts the EU’s broader goal of reducing strategic vulnerabilities and exposes operators to price volatility, supply chain disruptions, and regulatory uncertainty—particularly for SMEs. Without diversified sourcing and competitive European alternatives, the affordability and scalability of zero-emission mobility will remain constrained.

Regulatory Risks and Strategic Considerations

Mandating zero-emission fleet quotas without first ensuring infrastructure readiness and consumer acceptance risks undermining service continuity, reducing fleet availability, and imposing disproportionate financial burdens on rental operators. Such measures may also negatively impact tourism and regional mobility, particularly in Member States with less mature EV ecosystems.

In addition, the geopolitical situation in the region must be considered. In emergency scenarios, portions of corporate fleets may be requisitioned for civil protection, evacuation, or military mobilization purposes. At present, electric vehicles are not suitable for fulfilling such functions due to limitations in range, charging logistics, and operational resilience under crisis conditions.

Moreover, the operational dependence of ZEV fleets on continuous electricity supply introduces a strategic vulnerability in the event of grid disruptions. The widespread blackout across the Iberian Peninsula in April 2025—impacting Spain, Portugal, and parts of France—resulted in nearly ten hours of power loss, severely affecting transport systems, emergency services, and communications. In such circumstances, fleets composed predominantly of electric vehicles face significant limitations in mobility and responsiveness, undermining their capacity to support crisis management and essential service continuity. This underscores the importance of maintaining a diversified fleet composition and integrating contingency planning into the regulatory framework.

Recommendations

The Latvian Car Rental Association respectfully urges the Commission to consider the following:

1. Infrastructure-First Approach: Prioritize EU and national investment in fast-charging stations along major transport corridors and tourist routes.
2. Flexible Implementation: Allow Member States to tailor transition timelines based on local infrastructure maturity and market readiness.
3. Incentive-Based Measures: Promote ZEV adoption through fiscal incentives, VAT exemptions, and operational benefits rather than rigid mandates.
4. Support for SMEs: Ensure that regulatory obligations do not disproportionately affect small and medium-sized operators within the rental and leasing sector.
5. Crisis Readiness: Recognize the strategic role of corporate fleets in emergency response and ensure that regulatory frameworks preserve operational flexibility for such scenarios.