Europe's e-Truck Boom: The Real Roadblocks to 2030

The EU's CO2 targets are a hard deadline, not a suggestion. For new heavy-duty trucks, the rules are clear: a 15% reduction by 2025 and a 43% reduction by 2030 compared to the 2019-2020 baseline. This isn't just policy talk; it's a compliance regime with real teeth. The first hurdle, hitting -15% by mid-2025, is already in motion, pushing manufacturers to accelerate production.

The good news? The industry is on track to hit the 2025 target. A new analysis finds five out of seven European truckmakers will easily reach the -15% CO2 target. The bad news is the path they're taking. Instead of betting big on electrification, they're prioritizing cleaner diesel. The data shows truckmakers have so far preferred higher ICE truck efficiency over electrification as their main compliance route. This is a dangerous gap.

Here's the math: for the front-runners like Volvo and Renault, only about one-third of their CO2 savings so far come from zero-emission sales. For the others, it's a rounding error. The result? Only 1.7% of new registrations were zero-emission in 2024. That's far below the pace needed to hit the next target.

The regulatory framework has built-in flexibility to ease the short-term pressure. Manufacturers can use CO2 credits earned in the years leading up to 2030 and have been granted three years to clear debts if they miss the 2025 mark. This gives them breathing room, but it risks slowing the essential ramp-up of zero-emission production. The system is working to improve diesel efficiency, but it's not forcing the shift to electric. As the ICCT warns, this focus on cleaner ICE trucks is putting electrification at risk.

The bottom line is a ticking clock. To meet the 2030 target, the market must jump from 4% to roughly a third of all new medium and heavy-duty truck sales. The regulatory engine is running, but the fuel is diesel. The real test is whether the policy will force the industry to switch to electric before the 2030 deadline.

The Infrastructure Gap: Charging Power vs. Reality

The regulatory push is clear. The market need is massive. But can Europe's charging network actually keep up? The numbers tell a story of ambition clashing with reality.

The scale of the challenge is staggering. By 2030, the expected fleet of electric trucks will need between 22 GW and 28 GW of installed charging power capacity. That's a colossal demand, split almost equally between public and private chargers. To put that in perspective, the entire EU's current HDV charging infrastructure is a fraction of that need.

Right now, the network is a patchwork. As of November 2025, there are only 937 heavy-duty vehicle charging locations across Europe. Of those, just 313 offer the crucial 350 kW+ ultra-fast charging. That's a tiny fraction of the 60,000 to 80,000 public chargers projected to be needed. Germany leads the pack with 275 locations, but even that concentration is insufficient for the continent-wide scale required.

The EU's own policy, the Alternative Fuels Infrastructure Regulation (AFIR), aims to bridge this gap. However, its targets are a floor, not a ceiling. The AFIR is expected to cover only 50% to 70% of public charging needs by 2030. In some key countries like the Netherlands and Belgium, the targets cover just 30% to 50% of the projected demand. In others, like Romania, the target is actually higher than the need. This creates a dangerous mismatch: policy is setting a baseline, but the market is racing toward a much higher bar.

The real bottlenecks are physical and political. Grid congestion at high-power charging sites is a major risk, especially along the core transport corridors of the Trans-European Transport Network. Permitting procedures are lengthy and fragmented, slowing deployment. The current network is also geographically concentrated-dominated by Germany, Sweden, and the Netherlands-leaving vast swaths of Central, Eastern, and Southern Europe under-served.

The bottom line is a critical infrastructure gap. The AFIR provides a starting point, but it's not enough to power the 2030 fleet. Without a massive, coordinated build-out that accelerates permitting and upgrades the grid, the charging network will become the next major roadblock to electrification. For now, the promise of a clean truck fleet is still waiting for the power to charge it.

The Market Signal: Sales Growth vs. Policy Lifeline

The market is showing real traction, but it's a fragile signal. Zero-emission heavy-duty vehicle sales hit a 4.2% share in the first nine months of 2025, with medium trucks and vans doubling their share to 20.6%. That's growth, but it's still a tiny fraction of the market. The overall HDV sector is contracting, with sales down 10% year-to-date, and the new CO2 standards only came into effect in Q3. In that environment, the sales growth we're seeing is a positive sign of early adoption, but it's not yet a broad-based shift.

The critical question is what happens next. The EU's primary financial incentive-the Eurovignette Directive granting toll exemptions to e-trucks-expires at the end of 2025. That's a major cost advantage vanishing for operators in countries like Germany, where they could start paying at least 25% of regular tolls in January. This creates a huge risk of stalling momentum just as the industry needs to accelerate.

The good news is the policy lifeline is being extended. The Commission has proposed prolonging the full exemption until 30 June 2031, aligning it with the 2030 CO2 targets. The European Parliament already voted in favor, and the Council is expected to deliberate later this year. This is a vital signal. As industry groups note, long-term incentives are "vital to achieve a market share of at least 35% zero-emission trucks by 2030".

The bottom line is a race against time. The market is showing it can grow, but it's entirely dependent on policy certainty. The current legislative push to extend the toll exemption is not just bureaucratic-it's the single most important financial lever to close the total cost gap and give fleet operators the planning certainty they need to invest. Without this policy lifeline, the sales growth we're seeing could quickly fade. With it, the industry has a fighting chance to hit the 2030 targets. Watch the Council's final vote.

The Investment Playbook: Who Wins and What to Watch

The regulatory engine is running, the market is showing early signs, and the infrastructure gap is clear. Now, the real alpha leak comes down to execution. The winners will be the companies that can scale production, the investors betting on policy certainty, and the regions that get their charging networks built. The losers? Those stuck in the diesel compliance game or caught in political gridlock.

The first signal to watch is production. Mercedes-Benz is already the market leader with almost 50 percent market share for heavy-duty electric trucks. Their recent move to start series production of the new eActros 400 in early December is a critical test. This isn't just a model launch; it's evidence of scaled manufacturing capability. The pace of new model deliveries from all OEMs in 2026 will be the primary metric for whether the industry is truly ramping up or just talking.

But the biggest risk isn't technical-it's political. The industry's call for long-term incentives is a double-edged sword. As the ICCT analysis shows, manufacturers are using the slow uptake of zero-emission trucks as a pretext to call on the European Commission to bring forward the review of the CO2 standards. That's a direct threat to the policy lifeline. If regulators cede to this lobbying and delay the 2030 targets, it would be a massive blow to investment certainty and stall the entire transition. The primary risk is a policy reversal that kills the investment thesis.

So what are the key watchpoints for investors? First, the 2031 toll exemption legislation. The Commission's proposal to extend the full exemption for zero-emission heavy-duty vehicles until 30 June 2031 is vital. The European Parliament has already backed it, but the Council's final vote this year is the make-or-break moment. Without this financial lever, the total cost gap for operators remains too wide.

Second, the pace of charging infrastructure deployment. The AFIR targets are a floor, not a ceiling. The EU's own study shows it will cover only 50% to 70% of public charging needs by 2030. Investors need to watch for accelerated permitting and grid upgrades, especially along key transport corridors. The network must be built to power the fleet.

Finally, the ultimate metric: the actual 2030 zero-emission truck sales share. The market must jump from 4.2% today to roughly a third of all new medium and heavy-duty truck sales. That's the number that will determine if this is a real transition or just a regulatory exercise.

The bottom line is a race for coordinated action. Policy must stay firm, infrastructure must accelerate, and production must scale. The playbook is clear. Watch the 2026 model deliveries, the Council's vote on the toll exemption, and the charging build-out. The winners will be those who bet on the policy staying the course and the infrastructure getting built.