In its judgment of 1 October 2026 in case C-522/25 P, the CJEU dismissed the appeal brought by Krone Commercial Vehicle, Schmitz Cargobull, Kögel Trailer, System Trailers, Wecon, Schwarzmüller, Langendorf and Fliegl Fahrzeugbau. The dispute concerns Regulation 2024/1610, which extended EU CO₂ reduction requirements to O3 and O4 trailers and semi-trailers.
The ruling is the latest development in a legal dispute that began in 2024. The manufacturers sought the partial annulment of the new rules, arguing that their products do not emit CO₂ themselves. They were nevertheless made subject to reduction targets and could face charges if those targets are missed.
The CJEU did not rule on whether VECTO reflects real-world haulage
The key point is that the court did not assess the technical merits of the VECTO system. It did not decide whether the reduction targets for trailers and semi-trailers can be achieved or whether the methodology properly represents actual road transport conditions.
The case instead concerned whether the manufacturers had standing to challenge the regulation directly. On 22 May 2025, the General Court declared their action inadmissible. It found that the companies were not individually concerned by the regulation within the meaning of Article 263(4) of the Treaty on the Functioning of the European Union. The CJEU has now upheld that assessment.
The judges found that the regulation is general in nature and applies to every manufacturer meeting the objective criteria set out in the legislation. The fact that particular companies may face significant economic consequences or receive individual targets was not enough to establish that they were individually affected by the legal act.
Trailers do not emit CO₂, but that did not decide the case
One of the manufacturers’ central arguments was that trailers and semi-trailers have no independent powertrain and do not emit CO₂ themselves.
The companies argued that assigning them reduction targets and imposing potential penalties effectively made them responsible for emissions produced by the tractor unit.
The court did not consider this argument sufficient to establish that the manufacturers were individually affected by the regulation.
It noted, however, that a trailer’s technical characteristics can influence the aerodynamic drag of the entire vehicle combination. This can affect the tractor unit’s fuel consumption and emissions, meaning that the impact of trailers and semi-trailers on the emissions of the complete combination may provide an objective basis for including them in the rules.
The same reasoning is reflected in EU implementing legislation. The European Commission has noted that a more aerodynamically efficient trailer can reduce drag across the combination and lower the energy consumed by the tractor unit.
Targets remain unchanged: 10% for semi-trailers and 7.5% for trailers
Regulation 2024/1610 therefore remains in force. For reporting periods beginning in 2030, the rules require a 10% reduction for semi-trailers and a 7.5% reduction for trailers compared with reference values calculated using the VECTO methodology.
The regulation also includes a charge mechanism for manufacturers that exceed their individual emissions target. Under Article 8 of amended Regulation 2019/1242, the charge is calculated using a formula that takes into account the size of the exceedance and a rate of €4,250 per g CO₂/tkm.
For manufacturers, the compliance challenge begins well before the rules take full effect. They must adapt vehicle designs, investment plans and product portfolios to the parameters used by the VECTO model.
Eight manufacturers tried to stop the rules in 2024
The action was brought by Krone, Schmitz Cargobull, Kögel, System Trailers, Wecon, Schwarzmüller, Langendorf and Fliegl. Among other arguments, the companies said that the rules imposed a particular burden on them even though CO₂ emissions are generated by the motor vehicle towing the trailer, not by the trailer itself.
They also argued that the Commission would later set individual targets for each company and impose charges if those targets were missed. In their view, this meant that the regulation affected them specifically enough to give them the right to challenge it directly.
The CJEU disagreed. It found that future Commission decisions would merely implement rules that apply generally. Even potentially serious financial consequences for individual companies do not automatically create a right to bring a direct challenge against the regulation.
Trailer makers are taking the VECTO fight to Brussels
The judgment comes as European trailer manufacturers step up their efforts to change the rules through the political process. In July 2026, the chief executives of 30 European manufacturers signed a joint petition addressed to the European Commission and the European Parliament. The industry is calling for the review scheduled for 2027 to be brought forward and for the VECTO methodology as applied to trailers to be revised.
Manufacturers say the current simulation model does not adequately account for factors such as actual payload, cargo volume, empty runs, return loads and combined transport.
They also warn that forcing design changes solely to improve a VECTO score could produce results contrary to the policy’s objective in some applications. For example, reducing cargo space could require operators to run more trips.
The industry wants the review brought forward to 2026
In July, manufacturers called for the review required under Article 15 of Regulation 2019/1242 to be moved from 2027 to 2026. Some also want the target for semi-trailers to be lowered and the importance of these requirements gradually reduced as zero-emission tractor units become more common.
Kögel previously warned that, in its case, potential charges for missing the targets could reach as much as €64 million per year. The company also estimated that passing those costs on to the market could increase trailer prices by up to 50%. These figures are the manufacturer’s estimates, not calculations published by the European Commission.
The direct court challenge is over, but the VECTO debate is not
The judgment of 1 October 2026 ends this particular attempt to challenge the rules directly before the EU courts. The CJEU rejected all four grounds raised by the manufacturers and ordered them to pay the costs incurred by the European Parliament and the Council.
That does not mean the court has endorsed the reduction targets, the potential charges or the VECTO methodology. None of those substantive issues was decided in this proceeding. For the industry, the focus now shifts more clearly to the legislative process and the planned review of the rules. Until any amendments are adopted, manufacturers must continue preparing their vehicles and investment strategies for the reduction targets that apply from 2030.
