Clean Vehicle Directive (2019/1161)

The Clean Vehicle Directive (Directive 2019/1161/EU), which amends Directive 2009/33/EC, is the EU's mandatory procurement policy for low-emission road vehicles. Unlike the voluntary Green Public Procurement (GPP) framework, the Clean Vehicle Directive imposes legally binding minimum targets that EU member states must achieve through the public procurement of vehicles. It covers the purchase, lease, hire, and hire-purchase of road vehicles, as well as public service contracts for road passenger transport and certain service contracts involving a vehicle fleet.

What is the Clean Vehicle Directive (2019/1161)?

The Directive establishes a two-period structure of national minimum procurement targets:

First reference period (2021 to 2025). Each member state must ensure that a defined percentage of vehicles procured by contracting authorities and contracting entities are "clean vehicles." For passenger cars and light commercial vehicles (LCVs), a clean vehicle is defined as one meeting a maximum tailpipe CO2 emission threshold (set by the Regulation 2019/631 CO2 standards). For heavy-duty vehicles (trucks, buses, coaches), a clean vehicle is a zero- or low-emission vehicle powered by alternative fuels, including battery electric, hydrogen fuel cell, natural gas (CNG/LNG), or other specified alternatives.

Second reference period (2026 to 2030). Targets increase substantially. For buses, at least 45% of the target share must be zero-emission vehicles (ZEVs), typically battery electric or hydrogen fuel cell buses, by the end of the period. For heavy trucks, targets also tighten. Member states with smaller fleet sizes have somewhat lower initial targets to account for market maturity differences.

The Directive applies to contracting authorities (central, regional, and local governments and bodies governed by public law) under Directive 2014/24/EU and to contracting entities in the utilities sector under Directive 2014/25/EU. It also captures service contracts above the Directive 2014/24/EU thresholds where the services involve the operation of a vehicle fleet, such as public bus service concessions, waste collection services, and ambulance service contracts.

Member states have flexibility in how they meet the national targets: the aggregate of all qualifying procurements across all contracting authorities counts towards the national target, which means individual authorities can exceed or fall below the target, provided the national total is met. In practice, many member states have encouraged or required individual authorities to set their own vehicle procurement targets.

The Directive interacts directly with EU GPP Criteria for road vehicles and with the EU Taxonomy in Procurement, which sets taxonomy technical screening criteria for passenger cars and road transport based on vehicle CO2 emissions thresholds. Zero-emission vehicles align with the taxonomy's climate mitigation objective, providing a further policy incentive for authorities to favour ZEVs.

Why the Clean Vehicle Directive matters for bidders

The Directive creates a large and growing mandatory market for clean vehicles and for the services that use them. Fleet operators bidding for public service contracts (bus franchises, logistics, waste collection, road maintenance) must be prepared to demonstrate that their proposed fleet meets or contributes to the applicable clean vehicle targets. Authorities assessing bids for service contracts that involve vehicle use will increasingly require fleet composition data and may set minimum clean vehicle proportions as technical specifications or award criteria.

Vehicle manufacturers and leasing companies selling to public sector fleet buyers face a structural shift in purchasing patterns driven by the Directive's targets. Suppliers of electric and hydrogen powertrains, charging infrastructure, and alternative fuel depots benefit directly from mandatory demand creation.

Example

A Polish city authority issues a tender for a 10-year urban bus service concession. To comply with the Clean Vehicle Directive first-period target applicable to Poland, its technical specification requires that at least 33% of the bus fleet used to deliver the contract be clean vehicles, with at least half of that proportion being zero-emission electric buses. A bidder proposing an entirely diesel fleet cannot meet this specification and is excluded. A bidder proposing 40% electric buses (exceeding the minimum) scores additional points on the environmental award criterion linked to fleet emission intensity.

Frequently Asked Questions

Does the Directive apply to all vehicle purchases by public bodies?

No. The Directive applies to purchases and contracts above the EU procurement threshold for vehicles and related service contracts. Below-threshold purchases are not covered by the mandatory target mechanism, though member states and individual authorities may extend equivalent targets to below-threshold procurement voluntarily.

What counts as a "zero-emission vehicle" under the Directive?

A zero-emission vehicle is defined as a vehicle with no tailpipe CO2 or pollutant emissions, which currently encompasses battery electric vehicles (BEVs) and hydrogen fuel cell electric vehicles (FCEVs). Plug-in hybrid electric vehicles (PHEVs) and natural gas vehicles do not qualify as zero-emission, though they may qualify as clean vehicles depending on the category and period.

How does the UK approach clean vehicle procurement after leaving the EU?

The UK did not transpose the 2019/1161 Directive revision after Brexit. UK public authorities are instead guided by the Government's Zero Emission Vehicle mandate and by Procurement Policy Notes encouraging the procurement of zero-emission vehicles, but these are policy commitments rather than legally mandatory minimum targets equivalent to the EU Directive.