Urban logistics tested by the low emission mobility zones (ZFE-m)

The implementation of low emission mobility zones (ZFE-m) is a concern for last mile logistics players. What are the grievances of mobility players and, above all, what solutions do they recommend to adapt to the constraints of a measure that they all recognise as being well-founded?

A few reminders about low emission mobility zones

Introduced by the 2019 Mobility Orientation Law (LOM), the ZFE-m zones aim to preserve air quality in the most densely populated areas by prohibiting the circulation of vehicles that emit the most air pollutants (NOx and fine particles), which are responsible for more than 40,000 premature deaths in France each year.

Under the LOM law, only 11 metropolises were concerned by the low emission zones: Grenoble, Paris (Greater Paris Metropolis), Lyon, Reims, Rouen, Toulouse, Strasbourg, Saint-Etienne, Nice, Aix-Marseille, Montpellier. However, by 1 January 2025, the number of such zones will have risen to 43 or 45, as the 2021 Climate and Resilience Act makes it compulsory for all urban areas with more than 150,000 inhabitants to set up a ZFE.

In practice, the ZFEs will be implemented by progressively banning vehicles according to their Crit’Air sticker, a national classification that takes into account the engine type and age of the vehicles.

The higher the number on the Crit’Air sticker, the more polluting the vehicle is. As a result, older diesel vehicles (Crit’Air 4 and 5) are the first to be banned from driving in the ZFE perimeters. At the end of a transition period, which varies according to the agglomeration, only Crit’Air 1 vehicles and zero-emission vehicles (electric and hydrogen) will be authorised.

The challenges of ZFEs for professionals

While no one fundamentally questions the principle and purpose of ZFEs, the way in which they are implemented is now being strongly criticised by both citizens and businesses. For all professionals who have to travel within the existing or future ZFE-m perimeters, first and foremost for urban logistics operators, the introduction of ZFEs means that they have to renew their fleet of vehicles within very restrictive deadlines. The transport and logistics professional organisations denounce in particular:

>> untenable timetables

As the legislator has delegated the implementation of the ZFE-m zones to the local authorities, each city is free to define not only the perimeter concerned, but also the timetable for the implementation of the traffic bans. As a result, the 11 ZFEs that are already active follow different timetables that are generally too ambitious in view of the actual rate of renewal of the vehicle fleet.

This is particularly true for the Greater Paris ZFE, where the initial timetable foresees a ban on Crit’Air 3 vehicles on 1 July 2023, followed by a ban on Crit’Air 2 vehicles from 1 January 2024. However, in the current state of the fleet, 13.4% of light commercial vehicles (LCVs) in Greater Paris are classified as Crit’Air 3 and 69.8% as Crit’Air 2 [Source: SDES, Ministry of Ecological Transition and Territorial Cohesion].

For Christophe Schmitt, President of the Urban Logistics Commission of the Union des Entreprises de Transport et Logistique de France (TLF) and Director of Institutional Relations at Heppner:

“It is totally unrealistic to imagine that 83% of LCVs in Greater Paris — or more than 310,000 vehicles — will be Crit’Air 1 or electric by 1 January 2024. It is equally unlikely for trucks. Today, it is very difficult to replace a diesel vehicle with a clean vehicle. The delays are at least one year, if not 24 months! Production can’t keep up. At this rate, even in 10 years’ time we won’t make it. We need to find intermediate paths. ”*

For the local authorities concerned, the first option is to make the overly-ambitious timetables more flexible: at the end of 2022, the President of the Greater Paris Metropolis announced his intention to postpone the ban on the circulation of Crit’Air 3 vehicles to 1 January 2025; in February 2023, the President of Greater Lyon announced plans to postpone the ban on the circulation of Crit’Air 2 vehicles to 1 January 2028 (instead of 1 January 2025). These postponements certainly give professionals a little more time to adapt their fleets (provided that manufacturers are able to meet demand), but this does not solve the second problem they face, namely:

>> the heterogeneity of the rules depending on the local authorities

Not only do the timetables vary from one ZFE to another, but within the same ZFE the timetable may be different for passenger cars, light commercial vehicles and heavy goods vehicles. In addition to these provisions, there are many local derogations – permanent or temporary – for certain categories of vehicles.

The heterogeneity of local derogations poses very concrete operational problems for transport companies. For example, refrigerated vans are allowed to circulate in Lyon, even if they do not have the correct Crit’Air sticker. On the other hand, they are prohibited in the ZFE-m of Grenoble and Saint-Etienne if they do not have the appropriate Crit’Air sticker (in this case, Crit’Air 2, 1 or electric). This means that the same vehicle cannot deliver to both Saint-Etienne and Lyon, even though the two cities are close enough to be part of the same delivery round. It is easy to imagine the organisational complications for hauliers operating in the north of France if the timetables and local derogations in force in the future Lille, Valenciennes, Béthune and Douai-Lens ZFEs are not harmonised. As Jean-Philippe Elie, Digital Project Manager and Business Services Development at Logistic Low Carbon, points out:

“Today, there are about 30 specific derogations per local authority. Multiplied by 11 ZFEs to date, this makes more than 330 derogations to be taken into account. When there are 43 or 45 ZFEs, each with its own derogations, it will be a nightmare for professionals! ”*


To help professionals see things more clearly, Logistic Low Carbon (a subsidiary of the French Confederation of Wholesale and International Trade, CGI) has set up the platform as part of the Innovations Territoriales et Logistique Urbaine Durable (InTerLUD) programme. Companies and private individuals can check the traffic permits for their vehicles in all the ZFEs currently active.

>> the introduction of additional load disruptions

The introduction of the ZFEs and their multiplication throughout the country will make it almost impossible for trucks making the connections between cities to deliver to city centres, as these trucks are mainly diesel. This will oblige companies, local authorities and/or logistics operators to create bounce-back platforms on the outskirts of the ZFEs where cargo will be transferred to authorised vehicles within the ZFE. This disruption will inevitably result in additional costs and longer delivery times for end customers, both private and corporate. As Patrick Martin, Deputy Chairman of the MEDEF and Chairman of the Martin Belaysoud Expansion Group, which operates its own fleet of 200 trucks, explains:

“My group is investing massively in the creation of new logistics platforms. But the optimum location that existed in the past is being challenged by the ZFEs. Rebound platforms create extra costs and delays, but there is no real alternative when electric trucks cost 2.5 times more than a combustion engine truck, with 5 times less autonomy. ”*

The availability of ‘clean’ vehicles and their cost is constantly in the spotlight, as there are so many discrepancies between manufacturers’ announcements and the reality of the market. In addition, the inadequacy of the refuelling station network and the European Commission’s procrastination regarding the end of production of thermal vehicles in 2035 or 2040 make fleet renewal decisions more difficult. “It is imperative that the ZFEs keep pace with manufacturers’ technology and refuelling facilities. The manufacturers must be involved in the consultation process,” says Christophe Schmitt.

Patrick Martin points out another difficulty that should concern all company directors with sites within a ZFE perimeter: access to these sites by employees whose vehicles do not have the right Crit’Air sticker. It is true that there is significant local and national aid for individuals to buy an electric car, but for a very large number of employees, the remaining costs are still too high. “In a political climate that is quite electric, and after the painful precedent that was the Yellow Vests movement, I am disappointed and shocked that all the dimensions of the subject are not better taken into account, so as to arrive as consensually as possible at pro-active but pragmatic decisions”, adds the company director.

For a best possible solution…

In the opinion of all stakeholders, including local elected representatives, the economic and social impact of the ZFEs has been poorly assessed and insufficiently anticipated. Hence the unrealistic timetables, the multiplication of derogations and, ultimately, the postponements of deadlines announced by certain local authorities. In order to overcome the difficulties observed in the 11 existing ZFEs and while 33 additional agglomerations are in the process of defining their ZFEs, Union TLF published in October 2022 a series of 10 proposals, including 2 emergency measures:

  • The establishment of a national coordination committee for ZFE-m zones to ensure harmonisation of timetables and controls. In January 2023, the Minister of Ecological Transition and Territorial Cohesion appointed a national coordinator and launched a national consultation committee on the ZFE-m.
  • The introduction of a transitional phase allowing goods vehicles to drive under Crit’Air 2 until 2030 in cities where diesel is banned.

Other proposals include the harmonisation of financial assistance and support between territories (one-stop shop) and the establishment of corridors allowing “long-distance” Euro 6 vehicles and below to access the ZFEs.

All of this requires negotiation and coordination, as all stakeholders want the deployment of ZFEs to be a success.

>> In the meantime, Nomadia is supporting companies that operate in existing ZFEs. The perimeters of these ZFEs are integrated into our solutions and can be taken into account by our route planning and optimisation solutions. The perimeters of the ZFEs currently being defined will be included as they are formalised by the authorities concerned.


*All quotes are from the conference “ZFE: What are the perspectives and good practices?” which took place on 28 March 2023 in the framework of the SiTL