This article is a part of Poland Unpacked. Weekly intelligence for decision-makers
XYZ’s editorial team has obtained a letter dated December 4, 2025, which the heads of government of six EU member states sent to Ursula von der Leyen, president of the European Commission. The document – signed by Donald Tusk (Poland), Giorgia Meloni (Italy), Rossen Zhelyazkov (Bulgaria), Petr Fiala (Czechia), Viktor Orbán (Hungary), and Robert Fico (Slovakia) – addresses a package of decarbonization regulations that, they argue, is increasingly undermining the competitiveness of Europe’s automotive industry and companies specializing in the production of automotive components.
Ideological dogmatism brings sectors to their knees
In their joint position, the prime ministers recall a recent discussion in the European Council on competitiveness and approaches to climate regulation. In their view, those debates showed that the European Union must “once and for all abandon ideological dogmatism that has brought productive sectors to their knees.” They also note that measures taken so far have delivered almost no tangible benefits in terms of reducing global carbon dioxide (CO₂) emissions.
They emphasize the importance of technological neutrality – that is, pursuing emissions reductions through a range of new technologies. They agree that there is no single silver bullet on the path to decarbonization. Imposing one prescribed approach would stifle research, innovation, and fair competition. Even so, they argue that current and planned regulations are particularly damaging to the automotive sector.
Prime ministers call for changes to regulations
The authors note that a broad set of new regulations is currently on the agenda. They point in particular to the forthcoming revision of the European Emissions Trading System (ETS), the Carbon Border Adjustment Mechanism (CBAM) for goods imported into the EU, new CO₂ emissions standards for heavy-duty vehicles (Regulation 2023/851), and the recent proposal for an ETS2 system.
They urge that Regulation 2019/631, which sets CO₂ emissions standards for new passenger cars, should explicitly recognize the role of plug-in hybrid electric vehicles (PHEVs) and fuel-cell technologies, while also taking into account extended-range electric vehicles (EREVs) and other future technologies that could make a tangible contribution to emissions reductions.
They argue that the proposal should also reflect the role of zero- and low-emission fuels, as well as renewable fuels, in the decarbonization of transport. On this basis, they call for biofuels to be recognized as climate-neutral fuels. They also propose appropriate adjustments to regulations governing heavy-duty vehicles, in order to meet policy objectives while avoiding the risk of penalties.
They warn that fleet rules will increase red tape
The prime ministers also refer to a new regulation due to be announced by the European Commission on December 16, 2025. It is part of the Clean Industrial Deal package and would cover both the “greening” of corporate fleets and the introduction of additional obligations related to minimum shares of zero-emission vehicles (ZEVs) and caps for corporate fleets.
“These measures would lead to overlapping regulations and an increase in bureaucracy, which runs counter to the objective of simplifying regulation at the level of the European Union. The European regulation on CO₂ emissions for passenger cars and light commercial vehicles already constitutes an effective decarbonization tool for the automotive sector,” the authors of the letter argue.
Incentives instead of caps and mandates
In their view, Brussels’ proposal should focus on best practices, tax incentives, and support programs. They also stress that regulations should reflect a technologically neutral approach to promoting the transition to low- and zero-emission vehicles.
“Restricting fleets exclusively to ZEVs would undermine the competitiveness of businesses—especially small and medium-sized enterprises—and would impose new economic and administrative burdens. Extending the scope of the regulation to heavy-duty vehicles would also be destructive for the transport system as a whole,” the six prime ministers warn.
They add that the European Union is at a pivotal moment—both for the automotive industry and component manufacturers, and for Europe’s climate ambitions.
“We can and must effectively pursue our climate objective without destroying our competitiveness, because there is nothing green in an industrial desert,” the representatives of the member states conclude.
Zdaniem eksperta
Expert's perspective
New Mobility Association (PSNM): Restoring the early-2000s status quo is not an option
The Polish government’s position stands in stark contrast to the approach taken by Spain.
Almost in parallel, Madrid unveiled a comprehensive and substantive strategy for transforming its domestic automotive sector through 2035. Other countries recognize that the transition is already under way and will only accelerate, regardless of targets set at the EU level. They are seeking to adapt to global trends - and to benefit from them. Spain expects the implementation of its strategy to generate more than EUR 35 billion in gains.
Poland’s administration, by contrast, appears to believe that legal changes alone will be enough to restore the status quo of the early 2000s. That is not how markets work. The gap is widening, and Europe’s two-speed reality is becoming ever more entrenched.
Any potential—and widely anticipated - easing of EU emissions-reduction targets will not resolve the problems confronting Poland’s automotive sector, many of which have been accumulating for years. The vast majority have little to do with the planned ban on internal-combustion vehicles. Poland’s automotive industry still rests primarily on Tier-2 and Tier-3 component suppliers. This leaves it heavily dependent on decisions taken “elsewhere” and on policy instruments aimed directly at other countries.
The tariffs imposed by the administration of Donald Trump offer a telling example. Although directed primarily at Germany, in practice they will hit Polish firms hard. Poland is producing fewer passenger cars than at any point since 1976, and last year the sector’s exports fell by almost one-tenth. The industry is trying to offset this decline by expanding the production of light commercial vehicles, but in practice this has proved extremely difficult.
At this stage, what is needed are concrete, comprehensive solutions that - following Spain’s example - would raise the long-term competitiveness of Poland’s automotive industry, boost its innovative capacity, and strengthen its resilience to global shocks.
Industry representatives also write to the Commission
This was not the only letter to reach Brussels. On December 8, a separate letter landed on the desks of Ursula von der Leyen and other EU commissioners, signed by 67 organizations. The lengthy list of signatories includes car manufacturers such as Germany’s BMW and Japan’s Toyota. It also features major car-rental companies: America’s Avis, Budget, and Hertz, Germany’s Sixt, and France’s Europcar.
Leasing companies added their names as well, including Austria’s Erste Leasing and Raiffeisen Leasing. Poland was represented by the Polish Leasing Association (Związek Polskiego Leasingu, ZPL), the Polish Vehicle Rental and Leasing Association (Polski Związek Wynajmu i Leasingu Pojazdów, PZWLP), the Union of Entrepreneurs and Employers (Związek Przedsiębiorców i Pracodawców, ZPP), and the Employers’ Association “Transport and Logistics Poland” (Transport i Logistyka Polska, TLP).
“We express deep concern that the European Commission’s proposal mandating the compulsory purchase of zero-emission vehicles would place an additional burden on the competitiveness of European businesses. What is at stake is the European automotive industry and the surrounding mobility ecosystem, with millions of jobs in industry and services,” the authors of the letter warn.
Zdaniem eksperta
Expert's perspective
A timely letter
Europe’s automotive industry has been in dialogue with the European Commission for some time, although only three meetings have taken place over the past two years. We have been saying, among other things, that meeting the CO₂-reduction targets planned for 2030–2035 is impossible. We are still feeling the effects of the COVID-19 pandemic, the semiconductor crisis, and soaring raw-material prices. China’s decision a few weeks ago on export licenses also gives pause for thought. Tenfold higher tariffs on cars exported to the United States will almost certainly reduce exports to the American market. And finally, there is the transition to zero-emission mobility itself – a process that will cost close to EUR 250 billion.
This year, Europe will fall short of its target to cut CO₂ emissions from new cars by around 7–8 percentage points in terms of the share of zero-emission vehicles registered – that is roughly 700,000–800,000 vehicles. This means penalties will have to be paid. Although these will be averaged over three years (2025–2027), we are talking about billions of euros.
The letter from the six prime ministers shows that the industry’s interests transcend politics. The prime ministers are saying what the industry is saying. There is no chance of meeting the 2035 emissions target for passenger cars, vans, and heavy-duty vehicles. For trucks, the targets are shifted by roughly five years compared with other vehicle categories. Even so, the chances of quickly building a charging network for vehicles over 16 tonnes are very slim.
There is a plan for nearly 200 charging hubs to be built in Poland by 2030. By “hubs” we mean at least ten connectors on each side of the road, each with a capacity of 1.5 megawatts, allowing a truck to charge without uncoupling the trailer. This is an enormous challenge.
The prime ministers also argue that hybrid cars, including plug-in hybrids, are a sensible bridge during the transition. Yet plug-in hybrids may soon disappear from the market altogether. This is because the Commission is changing the way emissions are calculated, extending the distance a car must travel using its internal-combustion engine. The prevailing view is that users do not charge plug-in hybrids. As a result, a proposal has emerged to try to technically prevent cars from being driven without charging. After a certain number of kilometers without electric drive, the vehicle’s power would be reduced. That is one possible solution.
The letter also stresses the importance of technological neutrality. What matters is the goal – reducing harmful emissions – not prescribing a single pathway. Synthetic fuels, for example, though expensive today, could yet prove to be part of the solution.
Another controversial idea from the Commission concerns the “greening” of corporate fleets. By 2030, electric vehicles would probably account for around 90% of cars registered by companies – including leasing and long-term rental – although we do not have access to the Commission’s documents. In Poland, that would mean roughly 80–85% of all passenger-car registrations. Today the figure is about 8%, which makes the target appear unrealistic.
The prime ministers have emphasized that without solutions to support Europe’s automotive industry, its competitiveness could fall dramatically. The sector employs several tens of millions of people across Europe.
That is why we welcome this letter. It is good that it has come now – there is still time for the European Commission to take it into account. What the Commission will propose in a few days’ time remains to be seen; I cannot predict it.
High costs and limited infrastructure are the main obstacles for companies
The authors of the letter stress that company vehicles are an integral part of Europe’s economy, enabling the movement of people, goods, and services across the continent at all times. According to Bloomberg, company cars account for roughly 50–60% of new-vehicle sales in the EU. It is businesses that are driving the shift to electric vehicles most forcefully – far faster than individual consumers. Yet a major obstacle stands in the way of sustaining this trend.
“The main barriers to accelerating the deployment of ZEVs are the combination of total cost of fleet ownership and the lack of sufficient charging infrastructure across Europe, which in turn results in growing but still too slow consumer demand. The situation is further exacerbated by grid-capacity constraints and permitting challenges for infrastructure, as well as difficulties in delivering sufficient power to business locations, especially when rolling out fleets at scale,” the letter states.
They warn of troubling consequences
The signatories call for the removal of barriers that are slowing the uptake of ZEVs in Europe. They view as harmful any package that would impose mandatory purchases of zero-emission vehicles on companies. In their assessment, this would lead to financial paralysis and leave firms facing a stark choice: either keep older vehicles in service for longer or sharply reduce purchases of new cars.
“This would result in fewer new-vehicle registrations, weaken companies’ ability to serve customers or to perform core employee, service, and delivery functions. It would damage the competitiveness of European vehicle manufacturers and their suppliers, as well as fleet operators – at a time when economic conditions are already challenging,” the signatories warn.
They call for incentives as the foundation
The signatories emphasize that the experience of European countries that are rolling out ZEVs most rapidly shows that mandates are not the recipe for success. A more effective approach combines incentives with sustained investment in conditions that support decarbonization over the long term. In their view, the right incentives are essential to reduce the massive oversupply and to stimulate demand for new vehicles.
“A highly harmful market intervention in the EU would produce effects directly contrary to the Commission’s stated objectives – namely, improving the competitiveness of European businesses and supporting more sustainable and affordable mobility,” the letter concludes.
Expert's perspective
Appeals are necessary because they highlight negative consequences
For us in the leasing industry, this is especially crucial: poorly designed regulations could have the opposite effect of the European Commission’s intentions. Instead of investing in electric vehicles, companies would continue using their existing fleets for longer.
In the letter we signed with other organizations, we propose focusing on additional incentives rather than mandatory requirements. These incentives would encourage a growing share of electric vehicles in the fleets of Polish companies.
At ZPL, we note that in Scandinavian countries—where the adoption of such vehicles is highest - regulators have exempted electric cars from VAT, making them more affordable.
It is also important to rely on “soft” incentives, such as lower parking fees, reduced charging costs, or access to bus lanes.
Crucially, any measures must be long-term. Policies limited to a single year are of little interest to companies, which evaluate vehicle purchase and operating costs over the long term.
Key Takeaways
- The editorial team at XYZ has obtained a letter in which the prime ministers of six countries—led by Donald Tusk, Giorgia Meloni, and Viktor Orbán—call for a sensible approach to implementing regulations that could undermine the competitiveness of the automotive industry and its component suppliers. “The Union must once and for all abandon ideological dogmatism that has brought entire manufacturing sectors to their knees,” they write in the letter addressed to Ursula von der Leyen.
- The countries urge the European Commission not to impose mandatory requirements for “greening” corporate fleets. In their view, such measures lead to regulatory overlap and increased bureaucracy. “We can and must effectively pursue our climate goals without destroying our competitiveness, because there is nothing green in an industrial desert,” the member states’ representatives conclude.
- A separate appeal to the European Commission was also sent by 67 companies and organizations from the automotive sector—including car manufacturers, rental companies, and leasing firms. They emphasize that countries with the highest shares of electric vehicles in corporate fleets achieved this through incentive-based policies and investment, rather than by imposing caps and mandates.