COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on type-approval of motor vehicles and of engines and of systems, components and separate technical units intended for such vehicles, with respect to their emissions and battery durability (Euro 7) and repealing Regulations (EC) No 715/2007 and (EC) No 595/2009

EN EN
EUROPEAN
COMMISSION
Brussels, 10.11.2022
SWD(2022) 359 final
PART 3/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
ANNEX 5-8
Accompanying the document
PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF
THE COUNCIL
on type-approval of motor vehicles and of engines and of systems, components and
separate technical units intended for such vehicles, with respect to their emissions and
battery durability (Euro 7) and repealing Regulations (EC) No 715/2007 and (EC) No
595/2009
{COM(2022) 586 final} - {SEC(2022) 397 final} - {SWD(2022) 358 final} -
{SWD(2022) 360 final}
Offentligt
KOM (2022) 0586 - SWD-dokument
Europaudvalget 2022
1
Contents
ANNEX 5: EVALUATION EURO 6/VI EMISSION STANDARDS........................................................... 1
1. INTRODUCTION ................................................................................................................................ 1
1.1. Purpose of the evaluation ................................................................................. 1
1.2. Scope of the evaluation.................................................................................... 1
2. BACKGROUND TO THE INTERVENTION ..................................................................................... 1
2.1. Description of Euro 6/VI emission standards and its objectives............................... 1
2.2. Baseline and points of comparison ..................................................................... 1
3. IMPLEMENTATION / STATE OF PLAY .......................................................................................... 1
3.1. Current situation............................................................................................. 1
3.2. Implementation Euro 6/VI emission standards..................................................... 1
4. METHOD ............................................................................................................................................. 1
4.1. Short description of methodology ...................................................................... 1
4.2. Limitations and robustness of findings................................................................ 1
5. ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ............................................ 1
5.1. Effectiveness .................................................................................................. 1
Evaluation question 1: To what extent and through which factors has Euro 6/VI made
cleaner vehicles on EU roads a reality? Which obstacles to cleaner vehicles on EU roads
remain taking into account possible unintended consequences on the environment?......... 1
Evaluation question 2: How effective are the Euro 6/VI testing procedures to verify the
emission standards?................................................................................................................ 1
Evaluation question 3: What are the benefits of Euro 6/VI emission standards and how
beneficial are they for industry, the environment and citizens?............................................ 1
5.2. Efficiency ....................................................................................................... 1
Evaluation question 4: What are the regulatory costs related to the Euro 6/VI emission
standards and are they affordable for industry and consumers? Have Euro 6/VI achieved a
simplification of vehicle emission standards?......................................................................... 1
Evaluation question 5: To what extent has Euro 6/VI been cost-effective? Are the costs
proportionate to the benefits attained?................................................................................. 1
5.3. Relevance ...................................................................................................... 1
Evaluation question 6: To what extent do the Euro 6/VI objectives of ensuring that vehicles
on EU road are clean correspond to the current needs? Is there a demand/potential for
cleaner vehicles on EU roads over their whole lifetime?........................................................ 1
5.4. Coherence...................................................................................................... 1
2
Evaluation question 7: Are the Euro 6/VI emission standards coherent internally and with
other legislation pieces applying on the same stakeholders and with similar objectives? Are
there any inconsistencies, overlaps or gaps?.......................................................................... 1
5.5. EU-added value .............................................................................................. 1
Evaluation question 8: What is the added value of Euro 6/VI compared to what could have
been achieved at merely national level? Do the needs addressed by Euro 6/VI continue to
require harmonisation action at EU level?.............................................................................. 1
6. CONCLUSIONS................................................................................................................................... 1
ANNEX 6: POLICY OPTIONS..................................................................................................................... 1
6.1. Policy option 1: Low Green Ambition .................................................................. 1
6.2. Policy option 2: Medium and High Green Ambition................................................ 1
6.3. Policy option 3a: PO2a and Medium Digital Ambition ............................................ 1
ANNEX 7: IMPACT OF THE COVID-19 CRISIS IN AUTOMOTIVE INDUSTRY ON POLICY
OPTIONS.............................................................................................................................................. 1
ANNEX 8: ALTERNATIVE SET OF ASSUMPTIONS ON EMISSION LIMITS AND
DURABILITY ...................................................................................................................................... 1
8.1 Alternative set of assumptions on emission limits................................................. 1
8.2 Alternative set of assumptions on durability ........................................................ 1
3
Annex 5: Evaluation Euro 6/VI emission standards
1. INTRODUCTION
The Euro emission standards were put in place in order to address ongoing concerns for
public health and the environment related to air pollution caused by road transport and to
also address risk of fragmentation of the European Single Market by the adoption of
national standards and restrictions introduced by Member States. Vehicle emission
standards for light-duty vehicles (i.e. cars and vans) and heavy-duty vehicles (i.e. lorries
and buses) were implemented since 1992 through a series of Euro emission standards
reflecting technical progress while addressing the emerging air quality issues. These
standards are part of the type-approval framework in which new vehicle models are
tested and granted type-approval to meet a minimum set of regulatory and technical
requirements before entering into service on the EU market. Over the years, not only the
specific limits for air pollutants were tightened over the successive Euro emission
standards, but also the testing procedures were gradually modernized.
The current Euro emission standards which entered into force in 2013 for lorries and
buses (Euro VI) and in 2014 for cars and vans (Euro 6), are referred to as Euro 6/VI
emission standards in the following1
. In comparison to Euro 5/V2
, the new standards
introduced more demanding emission limits for some categories of pollutants (nitrogen
oxide NOx, particulate matter (PM), hydrocarbon (HC)), while other pollutants remained
at the same level. In addition, significant changes to the testing procedures for emissions
have been introduced in the implementing Regulations.
In September 2015, it was revealed that some European car manufacturers were using
illegal defeat devices which recognise that the car was being tested and changed the car’s
behaviour to reduce emissions during the test, while on the road, the cars emitted much
more. The scandal became widely known as Dieselgate and shook the confidence of the
citizens in the Euro 6 regulations. Together with the European Parliament and the
Member States, the Commission has since changed the European regulatory framework
to restore the confidence of EU citizens in the type-approval system and in European car
manufacturers and to include controls during market surveillance. Regulation (EU)
2018/858 has introduced from September 2020 new related EU type-approval rules
(better quality and independence of vehicle type-approval and testing authorities, more
controls of technical services, more checks on the roads, new EU wide recalls and
penalties). Important progress was also made with the adoption of implementing
regulations to ensure that emissions of cars are tested not only in the laboratory (the
1
Regulation (EC) No 715/2007 on type-approval of motor vehicles with respect to emissions from light
passenger and commercial vehicles (Euro 5 and Euro 6) and its implementing Regulation (EU) 2017/1151.
To ensure a smooth transition from the previous Directives to this Regulation, certain exceptions for
vehicles designed to fulfil specific social needs were foreseen in the Euro 5 stage. These exceptions ceases
with the entry into force of the Euro 6 stage; Regulation (EC) No 595/2009 on type-approval of motor
vehicles and engines with respect to emissions from heavy-duty vehicles (Euro VI) and its implementing
Regulation (EU) No 582/2011
2
Directive 2005/55/EC on the approximation of the laws of the Member States relating to the measures to
be taken against the emission of gaseous and particulate pollutants from compression-ignition engines for
use in vehicles, and the emission of gaseous pollutants from positive-ignition engines fuelled with natural
gas or liquefied petroleum gas for use in vehicles, referred to as Euro V in the following
4
Worldwide Harmonised Light Vehicle Test Procedure – WLTP) but also on the road (the
Real Driving Emissions testing – RDE).
1.1. Purpose of the evaluation
The purpose of this evaluation of the Euro 6/VI emission standards is to analyse to what
extend the Euro 6/VI emission standards have achieved their specific objectives of
setting harmonised rules on pollutant emissions from cars, vans, lorries and buses and
improving the air quality by reducing pollutants emitted by the road transport sector and
their operational objective of setting the next stage of emission limit values in a cost-
effective way with specific focus on NOx, PM and HC3
. In line with the Better
Regulation Guidelines4
, the evaluation examines the five evaluation criteria, namely: the
effectiveness, efficiency, relevance, coherence and EU added-value of the measures
established under both Euro 6 emission standards for cars and vans, and Euro VI
emission standards for lorries and buses.
This evaluation is being carried out following the presentation of the European Green
Deal5
in December 2019 as a new growth strategy that will foster the transition to a
climate-neutral, resource-efficient and competitive economy and the move towards zero-
pollution in Europe. To accelerate the shift to sustainable and smart mobility, transport
should become significantly less polluting, especially in cities. The EU automotive
industry must lead the global transition to zero-emission vehicles, rather than follow the
lead of others. This will allow the industry to take advantage of the business
opportunities offered.
Significant efforts have been made over the last 5 years to reduce emissions of air
pollutants, in particular in the wake of the Dieselgate. The European Parliament Inquiry
Committee into Emission Measurement in the Automotive Sector (EMIS) also made
several recommendations in order to improve the compliance with emission rules as well
as a recommendation to proceed with the development and proposal of new emission
rules, i.e. Euro 76
. Most of the recommendations were also repeated in the Briefing
Paper7
of the European Court of Auditors on the EU’s response to the “dieselgate”
scandal.
In parallel, new power trains – battery electric and hydrogen – are emerging as an
alternative to the combustion engine. However, although the roll out of such technologies
is accelerating, it is still slow. In the meantime, more needs to be done to “clean” the
combustion engine to ensure protection of human health in urban areas and to prevent the
Single Market from fragmenting due to individual national initiatives (e.g. diesel bans,
petrol bans). The European Green Deal roadmap therefore includes a proposal for more
stringent air pollutant emissions standards for combustion-engine vehicles by 2021.
The Commission decided to follow a back-to-back approach in which the evaluation and
3
SEC(2005) 1745 Commission Staff Working Document, Impact Assessment on Euro 5/6 emission
standards; SEC(2007) 1718 Commission Staff Working Document, Impact Assessment on Euro VI
emission standards; together referred to as Euro 6/VI impact assessments in the following
4
https://ec.europa.eu/info/sites/info/files/better-regulation-guidelines-evaluation-fitness-checks.pdf
5
COM(2019) 640 final, The European Green Deal
6
EMIS, 2017. European Parliament recommendation of 4 April 2017 to the Council and the Commission
following the inquiry into emission measurements in the automotive sector
7
European Court of Auditors, 2019. The EU’s response to the “Dieselgate” scandal
5
impact assessment are conducted in parallel as a single process. The findings of the
evaluation will be used to inform further reflection on whether the Euro 6/VI emission
standards continue to provide the appropriate legislative framework to provide high level
environmental protection in the EU and to ensure proper functioning of the Single
Market for vehicles.
This back-to-back evaluation and impact assessment requires to work with all
stakeholders involved in emission standards to gather lessons learnt and optimise future
emissions standards for vehicles in a short period of time. A first stakeholder conference
in October 20188
took place in order to frame the needs. The Commission put together an
Advisory Group on Vehicle Emission Standards (AGVES)9
, in which all relevant expert
groups working on emission legislation involving industry, NGOs, academia and
Member States were combined to discuss the Euro 6/VI emission standards and their
future development. Potential issues or pitfalls of the back-to-back approach were
identified continuously, such as the adjustment of problems identified and preliminary
policy options following the evaluation, and subsequently targeted in the impact
assessment of the Euro 7 initiative.
1.2. Scope of the evaluation
The evaluation covers the Euro 6/VI emission standards and their respective
implementing measures:
 Regulation (EC) No 715/2007 on type-approval of motor vehicles with respect to
emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and
its implementing Regulation (EU) 2017/1151;
 Regulation (EC) No 595/2009 on type-approval of motor vehicles and engines
with respect to emissions from heavy-duty vehicles (Euro VI) and its
implementing Regulation (EU) No 582/2011.
The evaluation covers the period since the entry into force of the regulations, namely
2014 for Euro 6 and 2013 for Euro VI, up until now (2020). Considering that the steps
Euro 6d and Euro VI E have yet to enter into force for all vehicles, that Euro 6/VI
vehicles on the market are expected to remain on EU roads for a significant period of
time and that the vehicles fleet is expected to be composed out of 100 percent Euro 6/VI
vehicles in 2050, the impacts of Euro 6/VI are expected to last until 2050.10
Therefore,
the evaluation also covers the expected impacts of the adopted measures in the future.
Geographically, the evaluation focuses on the achievements of Euro 6/VI emission
standards in the European Union. Hence, the evaluation covers the EU-27 Member States
and additionally considers the implementation in former Member State, the United
Kingdom. However, the EU automotive sector is not an isolated sector, since many of the
manufacturers and their suppliers selling vehicles on the EU market are global players.
These players come in direct contact with similar requirements in terms of pollutant
emissions on other major market, which will be taken into account throughout the
analysis.
8
https://ec.europa.eu/growth/content/stakeholder-event-preparing-future-european-emission-standards-
light-and-heavy-duty-vehicles_en
9
AGVES CIRCABC
10
CLOVE, 2022. CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, hereinafter
referred to as supporting Euro 6/VI evaluation study
6
This evaluation addresses the following key topics: the effectiveness of the Euro 6/VI
emission standards on clean vehicles on EU roads, the effectiveness of newly introduced
testing requirements, the Euro 6/VI regulatory costs for automotive industry, public
authorities and consumers and its proportionality to the achieved benefits, the current and
future need for rules on vehicle emissions, coherence within the Euro emission standards
and with other relevant legislation – such as the CO2 emission standards, Air Quality
Directives and Roadworthiness Directives – and the continued need for harmonisation at
EU level. Hence all relevant elements regarding effectiveness, efficiency, relevance,
coherence and EU added-value are assessed.
This evaluation notably builds on a 18-week public stakeholder consultation carried out
between 6 July and 9 November 2020 as well as a 14-week targeted stakeholder
consultation on Euro 6/VI evaluation between 4 March to 8 June 2020, expert meetings
between October 2018 and February 2021, see details in Annex 2, and extensive desk
research.
This staff working document is supported by a study on post-Euro 6/VI emission
standards in Europe - PART B: Retrospective assessment of Euro 6/VI vehicle emission
standards, referred to as supporting Euro 6/VI evaluation study in the following, which
was carried out from January 2020 to July 2021.
2. BACKGROUND TO THE INTERVENTION
2.1. Description of Euro 6/VI emission standards and its objectives
The vehicle emissions standards in Europe, also known as the Euro standards, are guided
by the overarching need to reduce air pollution emerging from road transport and
subsequently minimise harmful effects on human health and environment. In addition,
harmonised technical requirements over the Member States were considered essential to
ensure the proper functioning of the Single Market for vehicles11
. That way, the pathway
for control of emissions has commenced in 1992 with the introduction of Euro emission
standards and has gradually progressed over 28 years with more stringent provisions.
While progress was made in the emission performance of vehicles moving from Euro
emission standards 1/I to 5/V12
, the concern for public health and environment in
combination with the risk of the emergence of varying product standards across the EU
and the imposition of unnecessary barriers to intra-EU trade continued to be relevant. In
particular, particulate matter (PM) as well as ozone precursors such as nitrogen oxide
(NOx) and hydrocarbons (HC) were considered problematic due to their adverse effects
to the health and the environment. A wide range of different stakeholder groups were
affected by the problem: EU citizens were affected by poor air quality, manufacturers
and their suppliers by necessary development and introduction of better pollution-control
devices, consumers by potential price changes of new vehicles and national authorities
by granting new emission type-approvals for vehicles.13
11
See footnote 3
12
Arabic numerals refer to Euro emission standards for cars and vans, Roman numerals refer to Euro
emission standards for lorries and buses. Euro 1/I to 4/V emission standards were adopted as Directives,
which had to be transposed into each Member State. Euro 5 and 6/VI emission standards were adopted as
Regulations directly applicable to all EU Member States.
13
See footnote 3
7
Figure 17 provides an overview of how these overarching needs or problems were
translated into general, specific and operational objectives for the Euro 6/VI emission
standards which were in line with the aims of both the Lisbon strategy14
and the
Sustainable Development strategy15
. These objectives were on their turn translated into
specific activities at EU level. That way, the Euro 6/VI emission standards aimed at
ensuring the dual objectives of (i) ensuring the proper functioning of the Single Market
for vehicles and (ii) providing high level of environmental protection in the EU. The
intervention logic how Euro 6/VI standards were expected to work can be summarised
along three main operational elements.
Figure 17 – Intervention logic of Euro 6/VI vehicle emission standards16
, supplemented
by the supporting Euro 6/VI evaluation study
The Euro 6/VI vehicle emission standards set emission limit values for new cars, vans,
lorries and buses, in two separate Regulations for cars/vans and lorries/buses with an
almost identical legal structure. The Euro 6/VI emission limits are compared to the
previous Euro 5/V emission limits in Table 35. Euro 6 introduced for cars and vans more
demanding emission limits for NOx, HC and particulates - more stringent limits for
particulate mass (PM) and new limits for particulate number (PN). Since the switch from
Euro 4 to Euro 5 emission standards already resulted in significant reductions to the
limits for gasoline cars and vans, the decrease in limits are mainly found in diesel
vehicles. Also, Euro VI emission standards introduced for lorries and buses tighter limits
for NOx, HC and particulates. Following the tightening of NOx, emission limits were
14
SEC(2010) 114 final, Commission Staff Working Document, Lisbon Strategy evaluation document
15
COM(2001)264 final, Communication from the Commission, A Sustainable Europe for a Better World:
A European Union Strategy for Sustainable Development
16
See footnote 3
8
introduced in Euro VI for ammonia (NH3) for diesel lorries and buses, to control the
expected release of NH3 as by-product to the use of NOx pollution-control devices. In
addition, methane (CH4) limits were tightened for gasoline lorries and buses.
The Euro 6/VI emission standards revised and subsequently defined appropriate and
effective test procedures for controlling and verifying that the tailpipe and evaporative
emissions are effectively limited (see Table 34)17
. Through implementing legislation,
significant changes were made compared to Euro 5/V to the testing procedures with the
intention to reduce the gap between laboratory and real-world emissions. For cars and
vans, this meant the replacement of the laboratory New European Driving Cycle testing
(NEDC) by the laboratory Worldwide harmonised Light vehicles Test Procedure
(WLTP) and introducing the Real Driving Emissions testing (RDE) on the road against
temporary and final conformity factors1819
. For lorries and buses, off-cycle emissions
(OCE), in-service conformity (ISC) and Portable Emission Measurement Systems
(PEMS) testing were introduced in several steps20
. In addition, Euro 6 emission standards
revised the procedures for testing evaporative emissions, such as extension of the test
procedure from 24 to 48 hours. That way, the Euro 6/VI emission standards were
introduced in various steps, i.e. Euro 6 b-d(-temp) and Euro VI A-E.
Lastly, Euro 6/VI emission standards establishes appropriate provision and monitoring
requirements to make sure that all new vehicles meet the standards. Depending on the
specific vehicle type, the Euro 6/VI emission standards set or tightened requirements for
manufacturers to check in-service conformity and durability of their vehicles for certain
period or mileage. This ranges from five years or 100 000 km for cars and vans (no
change compared to Euro 5)21
up to 700 000 km or 7 years for heavy lorries and buses
(500 000 km under Euro V)22
. In addition, Euro 6/VI emission standards tightened the
thresholds for the provision of information from on-board diagnostics (OBD) systems.
These thresholds are intended to monitor the functioning of powertrain systems and
components for reducing tailpipe emissions in order to identify possible areas of
malfunction. In comparison to Euro 5/V emission standards, the OBD systems should be
more sensitive to minor irregularities in the pollution-control devices. That way,
malfunctions can be detected and corrected earlier.
17
Tailpipe emissions means the emission of gaseous and particulate pollutants (see emission limits in
Table 1). Evaporative emissions means the hydrocarbon vapours emitted from the fuel system of a vehicle
other than those from tailpipe emissions. Euro 5 and 6 emission standards set an emission limit for the
evaporative emissions test at 2.0 g evaporative emissions/test.
18
Regulation (EU) 2017/1151 supplementing Regulation (EC) No 715/2007 of the European Parliament
and of the Council on type-approval of motor vehicles with respect to emissions from light passenger and
commercial vehicles (Euro 5 and Euro 6)
19
The conformity factor introduces for the respective pollutant a margin that is a parameter taking into
account the measurement uncertainties introduced by the PEMS equipment, which are subject to an annual
review and shall be revised as a result of the improved quality of the PEMS procedure or technical
progress.
20
Regulation (EU) No 582/2011 implementing and amending Regulation (EC) No 595/2009 of the
European Parliament and of the Council with respect to emissions from heavy duty vehicles (Euro VI)
21
Regulation (EC) No 715/2007 on type-approval of motor vehicles with respect to emissions from light
passenger and commercial vehicles (Euro 5 and Euro 6). Durability testing of pollution control devices
undertaken for type-approval shall cover 160 000 km.
22
Regulation (EC) No 595/2009 on type-approval of motor vehicles and engines with respect to emissions
from heavy-duty vehicles (Euro VI). For light buses and lorries, the durability period should be 160 000
km (100 000 km under Euro V) or 5 years. For medium lorries and buses the durability period should be
300 000 km (200 000 km under Euro V) or 6 years.
9
Table 34 – On-road testing conditions set out in Euro 6d/VI E23
Parameter RDE (cars and vans) PEMS (lorries and buses)
Ambient temperature Moderate: 0 – 30o
C |
Extended: -7 – 0o
C & 30 – 35o
C
-7°C to 35°C
Average speed Urban: 15-40 km/h +Limitations for trip
distance and duration, and speed range
coverage
Test evaluation from tcoolant
> 30°C on;
cold start weighted with 14%
Maximum speed 145 km/h (160 km/h <3 % of motorway) -
Auxiliaries No limitation None
Trip characteristics 90-120 min,
34% urban, 33% rural, 33% highway
> 4x WHTC work
depending on class of vehicle
Engine loading Speed based limits on the basis of v*a[95th
]
[W/kg]
Only work windows > 10% valid
Maximum altitude Moderate: 0 – 700m | Extended: 700 –
1 300m
1 600 m
Positive elevation gain Total: <1 200 [m/100km]
Urban: <1 200 [m/100km]
-
Vehicle age ISC 100 000 km/5 years | MaS 160 000 km N2, N3 < 16t, M3 < 7.5t: 300 000 km
N3 > 16t, M3 > 7.5t: 700 000 km
23
On-road test conditions, as set in latest step Euro 6d (Regulation (EU) 2017/1151) and Euro VI E
(Regulation (EU) No 582/2011)
10
Table 35 – Emission limits set out in Euro 5/V and Euro 6/VI emission standards (changes in bold)24
A) Cars and vans
24
Positive ignition engine vehicles includes mainly petrol vehicles but also CNG and LPG vehicles, while compression ignition engine vehicles include diesel vehicles.
25
PN emission limits for positive ignition vehicles are applicable only for direct injection engines.
Air pollutants
(mg/km)
Positive ignition vehicles Compression ignition vehicles
Cars Vans category 1 Vans category 2 Cars Vans category 1 Vans category 2
Euro 5 Euro 6 Euro 5 Euro 6 Euro 5 Euro 6 Euro 5 Euro 6 Euro 5 Euro 6 Euro 5 Euro 6
NOx 60 60 75 75 82 82 180 80 235 105 280 125
PM 5.0 4.5 5.0 4.5 5.0 4.5 5.0 4.5 5.0 4.5 5.0 4.5
PN (#/km)25
- 6 x 1011
- 6 x 1011
- 6 x 1011
6 x 1011
6 x 1011
6 x 1011
6 x 1011
6 x 1011
6 x 1011
CO 1 000 1 000 1 810 1 810 2 270 2 270 500 500 630 630 740 740
THC 100 100 130 130 160 160 - - - - - -
NMHC 68 68 90 90 108 108 - - - - - -
THC+NOx - - - - - - 230 170 295 195 350 215
11
B) Lorries and buses26
26
See footnote 3. From the collected data for the Euro VI impact assessment, two representative test cycles, the World Harmonized Transient driving Cycle (WHTC) and the World
Harmonised Steady state Cycle (WHSC), have been created covering typical driving conditions in the European Union, the United States of America and Japan. The WHTC and
WHSC replaced the Euro V test cycles consisting of a sequence of test points each with a defined speed and torque to be followed by the engine under steady state (European Steady
state Cycle (ESC) test) or transient operating conditions (European Transient Cycle (ETC) test, European Load Response (ELR) test).
Air pollutants
(mg/kWh)
Positive ignition vehicles
(Gas)
Compression ignition vehicles
(Diesel)
Euro V
Transient
testing (ETC)
Euro VI
Transient testing
(WHTC)
Euro V
Transient testing
(ETC)
Euro VI
Transient testing
(WHTC)
Euro V
Steady-state testing
(ESC and ELR)
Euro VI
Steady-state testing
(WHSC)
NOx 2 000 460 2 000 460 2 000 400
PM 30 10 30 10 20 10
PN (#/kWh) - 6.0 x 1011
- 6.0 x 1011
- 8.0 x 1011
CO 4 000 4 000 4 000 4 000 1 500 1 500
THC - - - 160 460 130
NMHC 550 160 550 - - -
NH3 (ppm) - 10 - 10 - 10
CH4 1 100 500 - - - -
Smoke - - - - 500 -
12
2.2. Baseline and points of comparison
Before Euro 6/VI emission standards came into place, pollutant emissions emerging from
road transport had already been targeted since 1992 by five previous generations of
standards. The Thematic Strategy on air pollution27
already showed significant progress
in the reduction of main air pollutants in 2000 for Europe. Nevertheless, road transport
was still considered a significant source of pollution, as it was responsible for 43% of
total NOx emissions and 27% of total volatile organic compound (VOCs)28
emission in
2002. In addition, the total transport sector (which also includes shipping, aviation and
rail) accounted for 29% of total PM2.5 emissions in 2000.29
In a baseline scenario in which Euro 6/VI emission standards were not implemented, the
previous Euro 5/V emission standards would have remained in place. Therefore, the
performance of Euro 6/VI entails the additional or marginal effects of the intervention
against a scenario in which Euro 5/VI was still in full force. In addition, the baseline
scenario assumes that in the absence of the Euro 6/VI emission standards no further
changes would have been made to the Euro 5/V emission limits and relevant testing
procedures for the emission type-approval of new vehicles.30
Next to this baseline
scenario, an alternative baseline scenario is considered for cars and vans that assumes
that the RDE test procedure was not introduced (i.e. effects of implementation of Euro 6
up to Euro 6c compared to Euro 6d). Hence, this alternative baseline scenario aims at
evaluating and comparing the performance of Euro 6 emission standards before and after
the implementing legislation introducing on-road RDE testing (see chapter 1.1).
The new Euro 6/VI emission limits have triggered a change in pollution-control devices
compared to Euro 5/V, as manufacturers do not voluntary fit additional pollution-control
devices to improve the pollutant emissions performance of their vehicles beyond those
required to comply with the Euro 5/V emission standards.31
Although the
Roadworthiness Directives32
have objectives similar to Euro 6/VI, they primarily aim at
detecting and removing from circulation vehicles which are over-polluting due to
technical defects. Hence, the Roadworthiness Directives could not have triggered the use
of additional pollution control devices in new vehicles.
In order to assess the reduction of pollutant emissions from new vehicles until 2020 and
further until 2050 when the combustion-engine vehicle fleet will consist of Euro 6/V
vehicles only, other external factors or relevant developments that could have potentially
affected these pollutant emissions are taken into account as counterfactual. The CO2
emission performance standards for cars, vans, buses and lorries3334
might have played a
27
COM(2005) 446 final Thematic Strategy on air pollution
28
Hydrocarbons (HC) and Volatile Organic Compounds (VOC) are used in this staff working document
interchangeably.
29
See footnote 3
30
That means, the points of comparison are the Euro 5/V emission limits against the Euro 6/VI emission
limits. The original points of comparison of the preferred option in the Euro 6/VI impact assessment has
been updated to take on-board the changes made between the Commission’s impact assessment and the
adoption of the Euro 6/VI emission standards.
31
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 2.6 Baseline definition
and point of comparison
32
Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers; Directive
2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating
in the Union
33
Regulation (EU) 2019/631 setting CO2 emission performance standards for new passenger cars and for
new light commercial vehicles, and repealing Regulations (EC) No 443/2009 and (EU) No 510/2011;
13
role through the introduction of requirements that led to the adoption of new technologies
to achieve fuel efficiency and reductions in CO2 emissions. The adoption of such
technologies may positively (e.g. more electric vehicles) or negatively (i.e. potential
trade-offs for combustion-engine vehicles) affect the effectiveness of certain technologies
used for combatting air pollutant emissions. That way, the quantitative analysis presents
the maximum that can be assigned to the Euro 6/VI emission standards and takes into
account the possibility that other external factors have played a role. These CO2 standards
affect the vehicle fleet and in particular the penetration of zero- or low-emission vehicles
(e.g. electric vehicles, hybrids) in Europe. To fully account for the impacts of these
climate policies on the air pollution emission resulting from road transport, the resulting
vehicle fleets are taken into account for assessing Euro 6/VI effectiveness and efficiency.
In 2005, the Thematic Strategy on air pollution for 2000-2020 forecasted what was
expected to happen in a scenario where no further policy action related to air pollution
was taken. With no policy changes related to air pollution and its respective sources after
2005, health impacts from air pollution across the EU were still projected to be
considerably high in 2020. Without further reductions of ozone (which is formed by
reaction between HC and NOx), the health impacts related to this pollutant were
expected to result in 20 000 premature deaths in the year 2000. Figure 18 demonstrates
that for particulates, the average loss in statistical life expectancy without further EU
action was expected to reach five months by 2020.
Apart from the impact of no further action on public health and the environment from
pollutants from new vehicles, also the Single Market for vehicles would have been at risk
without the introduction Euro 6/VI emission standards. In a scenario where emissions
from road transport emitted by new vehicles remained an issue, the use of other measures
by Member States, such as bans on certain types of vehicles entering urban areas or low
emission zones were expected to become widespread. That way, the proper functioning
of the Single Market for vehicles could have been hampered.35
Figure 18 – Effects of particles on mortality in 2000 and 2020 (with fixed 2005
policies)36
Regulation (EU) 2019/1242 setting CO2 emission performance standards for new heavy-duty vehicles
34
SWD(2017) 650 final Commission Staff Working Document, Impact Assessment on setting emission
performance standards for new passenger cars and for new light commercial vehicles as part of the Union's
integrated approach to reduce CO2 emissions from light-duty vehicles; SWD(2018) 185 final Commission
Staff Working Document, Impact Assessment on setting CO2 emission performance standards for new
heavy-duty vehicles
35
See footnote 3
36
COM(2005) 446 final Thematic Strategy on air pollution
14
On the other side, the Euro 6/VI impact assessment estimated the expected results of the
preferred policy options for the Euro 6/VI initiative.37
The new Euro 6 limits for cars and
vans were expected to result in a 24% reduction in NOx emissions and no further
reduction in PM and HC emissions, compared to Euro 5 by 2020. For Euro VI for lorries
and buses, the new limits were expected to deliver a 37% reduction in overall NOx
emissions, 22% reduction in PM emissions and no further reduction in HC emissions,
compared to Euro V by 2020.
3. IMPLEMENTATION / STATE OF PLAY
3.1. Current situation
In order for the Euro 6/VI emission standards to have an impact on air pollution, vehicles
type-approved under these standards should have a larger penetration in the European
fleet of vehicles. Therefore, the Euro 6/VI evaluation considers not only the current
situation in 2020 but also the further evolution of the penetration of Euro 6/VI vehicles in
the fleet by estimating the sales of Euro 6/VI vehicles until 2050.
The Euro 6/VI impact assessments suggested that the monitoring of the effect of the Euro
6/VI emission standards should be undertaken by type-approval authorities who oversee
the compliance processes to ensure that requirements of the regulations are met.
However, no such reporting requirements or specific monitoring indicators have been
included in the Euro 6/VI emission standards. Therefore, data from the SIBYL model,
complemented by data from type-approval authorities and vehicle sales statistics, was
applied.38
The SIBYL model is a vehicle stock, activity and emissions projection tool
that allows to make estimations and projections up to 2050 and will be further discussed
in Sections 4 and 5. The number of emissions type-approvals reflects the compliance
with the respective vehicle pollutant emissions. The estimation from the SIBYL model
for the projected development of the European vehicle fleet is represented in Figure 19.
Figure 19 – Projected development of EU-27+UK39
vehicle fleet40
A) Cars and vans (Euro 6 pre- and post-RDE), Source: CLOVE based on data from
SIBYL model
37
For cars and vans, the preferred Euro 6 policy option included a NOx limit of 75 mg/km and a PM limit
of 5 mg/km for diesel vehicles, which deviated from the actual limits adopted (see Table 1). For lorries and
buses, the preferred Euro VI policy option included a NOx limit of 400 mg/kWh and a PM limit of 10
mg/kWh for diesel and gas engines, which also deviated from the actual limits adopted (see Table 1).
38
SIBYL: Ready to go vehicle fleet, activity, emissions and energy consumption projections for the EU 28
member states. The SIBYL model was updated with data on emission type-approvals from 10 Member
States, data on vehicle sales in the EU-28 from 2013-2020 from IHS Markit and vehicle fleet projections
by the impact assessments for CO2 emission standards for cars, vans, lorries and buses (SWD(2017) 650
final, SWD(2018) 185)
39
The Euro 6/VI evaluation covers the period 2013 to 2020 and hence the geographical coverage is EU-28.
However, as the impact of Euro 6/VI vehicles is projected until 2050, EU-27+UK is considered from 2021.
40
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 3.5.1 Evolution of sales
of Euro 6/VI vehicles over time
15
B) Lorries and buses (Euro VI), Source: CLOVE based on KBA, 202041
According to Figure 19, the penetration of Euro 6 cars and vans is still limited to 20% of
the total fleet in 2020. This indicates that the introduction of Euro 6 vehicles – and
particularly of vehicles type-approved to the latest two steps including RDE testing – is
still at its initial stages. However, by 2026 the cars and vans fleet is expected to consist of
50% Euro 6 type-approved vehicles, from which the large majority will be subject to
RDE testing. This includes both diesel- and petrol-fuelled combustion-engine vehicles,
but also alternative-fuelled vehicles. As can be seen in Figure 19, the latter are expected
to take over the European combustion-engine fleet in the long run.
41
KBA, 2020: Data extracted from multiple tables provided in vehicle statistics dataset
https://www.kba.de/DE/Statistik/Fahrzeuge/fahrzeuge_node.html, Themensammlungen (FZ 13) and
Themensammlungen (FZ 14)
16
While the SIBYL model suggests a rather fast uptake of RDE tested vehicles in the Euro
6 fleet with a share of over 50% by 2018, observed evidence from the Netherlands and
Germany where RDE Euro 6 vehicles only represent a small share of vehicles on EU
roads indicates that the SIBYL estimate might be an overestimation.42
For Euro VI lorries and buses, SIBYL model suggests that their share in the total fleet
across the EU will reach 34% by the end of 2020. As shown in Figure 19, lorries and
buses type-approved to Euro VI are expected to completely take over the fleet by 2040.
Data from Germany (KBA) on vehicle registrations and stock of vehicles for 2013-2018
confirm the rapid uptake of newer Euro VI vehicles since 2017, reaching 17% of the
heavy-duty fleet by 2018.43
3.2. Implementation Euro 6/VI emission standards
The Euro 6/VI emission standards outline the responsibilities of different actors,
including for manufacturers to ensure that their vehicles meet the emission limits and
durability requirements, and for Member States’ type-approval authorities to grant type-
approval if the requirements are fulfilled. Since the Euro 6/VI emission standards are
legislated through Regulations44
, these requirements are binding in their entirety and
directly applicable in all Member States. The actual implementation of Euro 6/VI
emission standards is characterized by the gradual development of testing procedures and
technical requirements introduced in the implementing Regulations through different
steps, i.e. Euro 6b-d(-temp) and Euro VI A-E summarised in Table 36.
As already outlined in chapter 1.1, Dieselgate has occurred as important unexpected
event during the implementation of the Euro 6 emission standard for cars. At the same
time Euro 6d(-temp) was introduced with on-road Real Driving Emissions (RDE) NOx
and PN testing with temporary and final conformity factors.
Table 36 – Overview of the implementation of Euro 6/VI emission standards
A) Cars and vans (Euro 6)
Regulation (EC) 715/2007
- Emission limits covering NOx, PM, PN, CO and THC for diesel vehicles and
NOx, PM, PN, CO, THC and NMHC for petrol vehicles (see Table 35)
- In-service conformity of vehicles and engines
- Durability of pollution-control devices
- On-board diagnostic (OBD) systems
- Measurement of CO2 emissions and fuel consumption
Commission Regulation (EC) 692/2008 – Euro 6b
- Implementing regulations as in Euro 5 plus the following:
- Full OBD requirements with OBD thresholds
- Revised measurement procedure for PM and PN (preliminary values for petrol
direct injection)
42
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 3.5.1 Evolution of sales
of Euro 6/VI vehicles over time
43
https://www.kba.de/DE/Statistik/Fahrzeuge/fahrzeuge_node.html
44
See footnote 1
17
Commission Regulation (EU) 2017/1151 – Euro 6c
- Replacement of the laboratory New European Driving Cycle testing (NEDC) by a
new laboratory test procedure - the World Harmonised Light Vehicle Test
Procedure (WLTP) for measuring CO2 emissions and fuel consumption
- Introduction of the on-road Real Driving Emissions (RDE) NOx testing for
monitoring only
- Revised evaporative emissions test procedure
- All else as in Commission Regulation (EC) 692/2008
Commission Regulation (EU) 2017/1151 – Euro 6d-temp
- Introduction of the on-road Real Driving Emissions (RDE) NOx and PN
compliance with temporary conformity factors45
- Full Euro 6 tailpipe emission requirements, 48H evaporative emissions test
procedure and new in-service conformity (ISC) procedure
Commission Regulation (EU) 2017/1151 – Euro 6d
- Introduction of the on-road Real Driving Emissions compliance (RDE) with final
conformity factors
- More advanced emissions checks of cars for In-Service Conformity and testing by
member states, independent and accredited third parties
- Improved World Harmonised Light Vehicle Test Procedure (WLTP) procedure by
eliminating test flexibilities
- Introduction of devices for monitoring the consumption of fuel and/or electric energy,
thereby making it possible to compare laboratory WLTP results for CO2 emissions
with the average real driving situation
B) Lorries and buses (Euro VI)
Regulation (EC) 595/2009
- Emission limits covering NOx, PM, PN, CO, THC and NH3 for diesel vehicles
and NOx, PM, PN, CO, NMHC, NH3 and CH4 for gas vehicles (see Table 35)
- In-service conformity of vehicles and engines
- Durability of pollution-control devices
- On-board diagnostic (OBD) systems
- Measurement of CO2 emissions and fuel consumption
Commission Regulation (EU) 582/2011 – Euro VI A-C
- Specific technical requirements for emissions type-approval
- Introduction of the worldwide harmonised transient driving cycle (WHTC) and
the worldwide harmonised steady state driving cycle (WHSC)
45
The conformity factor (2.1 to 1.43) introduces for the respective pollutant a margin that is a parameter
taking into account the measurement uncertainties introduced by the PEMS equipment, which are subject
to an annual review and shall be revised as a result of the improved quality of the PEMS procedure or
technical progress. For example, a conformity factor of 2.1 means 168 mg/km NOx instead of 80 mg/km.
18
- Procedures for the measurement of in-service conformity (ISC) requirements
- NH3 measurement procedure
- Measurement of CO2 emissions and fuel consumption
- Introduction of requirements with respect to the off-cycle in-use emissions testing
procedures
- Engine installation
Commission Regulation (EU) 582/2011 – Euro VI D
- Refined requirements for in-service conformity testing of engines using Portable
Emission Measurement System (PEMS) testing
- Trip requirements
Commission Regulation (EU) 582/2011 – Euro VI E
- Measurement of emissions during cold engine start periods
- Use of PEMS for measuring PN
Since the Euro 6/VI emission standards were implemented in different steps, the
standards are characterised by different application dates for Euro 6b-d(-temp) and Euro
VI A-E. Furthermore, there are different application dates for new types of vehicles and
new vehicles, which can be found in Annex I, Appendix 6 of Regulation (EC) 2017/1151
for cars and vans and in Annex I, Appendix 9 of Regulation (EU) 582/2011 for lorries
and buses. Table 37 attempts to summarise the main dates for the implementation
roadmap for Euro 6/VI emission standards. It shows that the most recent steps of Euro 6
(Euro 6 d) and of Euro VI (Euro VI E) have yet to be implemented for several vehicle
categories.
Table 37 – Simplified implementation roadmap Euro 6/VI emission standards
A) Cars and vans
Euro 6b Euro 6c Euro 6d-temp Euro 6d
Cars
New types of vehicles 09/2014 09/2017 01/2020
New vehicles 09/2015 09/2018 09/2019 01/2021
Vans
New types of vehicles 09/2015 09/2018 01/2021
New vehicles 09/2016 09/2019 09/2020 01/2022
B) Lorries and buses
Euro
VI A
Euro VI
B (diesel)
Euro VI
B (gas)
Euro
VI C
Euro
VI D
Euro
VI E
Lorries
and buses
New types
of vehicles
01/2013 01/2013 09/2014 01/2016 09/2018 01/2021
New
vehicles
01/2014 01/2014 09/2015 01/2017 09/2019 01/2022
19
As of these application dates, manufacturers of vehicles are responsible for ensuring that
their vehicles meet the pollutant emission limits set out in the Euro 6/VI emission
standards. To make sure that the vehicles actually comply with the Regulations, the
emission tests are performed at several phases and monitored by national type-approval
authorities, as follows:
Firstly, type-approval testing is done on pre-production vehicle models to ensure that
the set emission limits are met and is granted by type-approval authorities in the Member
States in collaboration with technical services acting on their behalf. The latter either
carries out the testing at their facilities or supervises it at the manufacturers’ facilities.
That way, Certificates of Conformity (CoC) are granted for all vehicles for which the
pre-production model has confirmed compliance with the emission limits.
Secondly, testing in the Conformity of Production (CoP) procedure aims at ensuring
that the newly produced vehicles continue to comply with the limits as required by the
legislation. Concretely, the manufacturer has to select a sample of vehicles from the
production facility (i.e. not registered vehicles) that will undergo the same testing
procedure as for type-approval. The type-approval authority audits the relevant tests
performed by the manufacturers for which it may bring in a technical service.
Thirdly, In-Service Conformity (ISC) is applied to make sure that the emissions remain
below the Euro 6/VI limits over the normal lifetime of the vehicles. For this compliance
check, the manufacturer is generally responsible for performing the relevant tests, while
the respective granting type-approval authority is required to test a number of selected
vehicle types each year and is responsible for enforcement. Moreover, in the wake of
Dieselgate, ISC testing by independent and accredited third parties is possible.
Lastly, Market Surveillance (MaS) should be performed by authorities that are
independent from the authorities responsible for type-approval. These market
surveillance authorities should assess the continued conformity with the limits, by testing
registered vehicles against all the requirements of the Regulation. However, until 2020
Market Surveillance checks by Member States were not required by the Regulation.
From 1 September 2020, the new EU vehicle type-approval framework46
is applicable
that demands Member States to test a minimum number of vehicles and requires that the
market surveillance authorities reserve sufficient funds to perform the checks. Hence,
Market Surveillance checks have been improved fundamentally.
Member States have the discretion to decide on penalties to infringements by
manufacturers and technical services, including the level of penalties, and recalls of
vehicles if they do not comply with the Euro 6/VI emission standards. Typically Member
States have introduced a range of penalties levels depending on the type of infringement
of the Regulations. What level of sanctions is applied within that bracket is at the
Member State's discretion and is decided case by case.
In the wake of Dieselgate, the Commission has coordinated recalls of vehicles equipped
with illegal defeat devices47
organised by the Member States since January 2018 through
46
Regulation (EU) 2018/858 on the approval and market surveillance of motor vehicles and their trailers,
and of systems, components and separate technical units intended for such vehicles, amending Regulations
(EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC
47
A defeat device is defined in Regulation (EC) No 715/2007 as “any element of design which senses
temperature, vehicle speed, engine speed (RPM), transmission gear, manifold vacuum or any other
parameter for the purpose of activating, modulating, delaying or deactivating the operation of any part of
20
the Platform on Recall Actions related to NOx emissions48
. Since then, the Commission
has been regularly monitoring progress of recall actions and remind Member States of
their obligation to recall the vehicles with illegal defeat device and to bring them into
conformity with the type-approval rules. From 1 September 2020, the new EU vehicle
type-approval framework empowers also the Commission to initiate EU-wide recalls and
impose fines of up to €30 000 per non-compliant vehicle if no fine is being imposed by
the Member State. In addition, the Commission may also fine technical services if they
fail to carry out the test rigorously. The level of fines depends on an assessment of the
gravity and extent of the non-compliance and are specified by a Commission delegated
act.49
The existing obligation for Member States to lay down rules for effective,
proportionate and dissuasive penalties is maintained. With the new EU vehicle type-
approval framework, Member States have to report to the Commission every year on the
penalties they have imposed in the preceding year, and the Commission shall elaborate
each year a summary report on the penalties imposed by Member States and submit it to
the Forum for Exchange of Information on Enforcement composed of representatives
appointed by the Member States representing their approval authorities and market
surveillance authorities.
4. METHOD
4.1. Short description of methodology
The evaluation of the Euro 6/VI emission standards was carried out in 2020-2021 by the
Commission and guided by a combined evaluation roadmap and inception impact
assessment50
that described potential issues in the Euro 6/VI emission standards and how
the evaluation will provide a detailed analysis on the basis of the Better Regulation
evaluation criteria. For this purpose, eight overarching evaluation questions were
formulated to assess the regulations’ effectiveness (three questions), efficiency (two
questions), relevance (one question), coherence (one question) and EU-added value (one
question). To inform the responses to these eight evaluation questions, a supporting Euro
6/VI evaluation study carried out by CLOVE consortium in 2020-202151
analysed a total
of fourteen evaluation (sub-) questions which have been summarized into the eight
questions considered here. Table A.1 in Appendix shows how the responses to the sub-
questions in the supporting study have been re-aggregated in the Staff Working
Document.
the emission control system, that reduces the effectiveness of the emission control system under conditions
which may reasonably be expected to be encountered in normal vehicle operation and use”. The use of
defeat devices that reduce the effectiveness of emission control systems is prohibited. The prohibition does
not apply where the need for the device is justified in terms of protecting the engine against damage or
accident and for safe operation of the vehicle, the device does not function beyond the requirements of
engine starting or the conditions are substantially included in the test procedures for verifying evaporative
emissions and average tailpipe emissions.
48
Platform on Recall Actions related to NOx emissions, Compilation of information and data received
from Member States' authorities on the progress of recall actions carried out in their territories for
improving the performance of vehicles in use as regards their pollutant emissions. As recall actions are
currently still on-going, updated data will be provided on a regular basis.
49
Commission Delegated Regulation (EU) 2022/1209 of 5 May 2022 supplementing Regulation (EU)
2018/858 of the European Parliament and of the Council as regards the procedure for the imposition of
administrative fines and the methods for their calculation and collection, OJ L 187, 14.7.2022, p. 19–22
50
Combined Evaluation Roadmap / Inception Impact Assessment: Development of post-Euro 6/VI
emission standards for cars, vans, lorries and buses
51
See footnote 10
21
The supporting Euro 6/VI evaluation study helped collecting evidence and data through
different channels, including several means for gathering stakeholder views and
expertise.
As a first step for the evaluation an extensive literature review and analysis of data were
undertaken through the supporting Euro 6/VI evaluation study focussing on the impacts
of pollutant emission from new road vehicles. This included literature reviews of and
data from the Euro 6/VI impact assessment52
, the study on post-Euro 6/VI emission
standards in Europe carried out by the CLOVE consortium compromising key experts in
Europe from the Laboratory of Applied Thermodynamics of the Aristotle University of
Thessaloniki (LAT) (GR), Ricardo (UK), EMISIA (GR), TNO (NL), TU Graz (AT),
FEV (DE) and VTT (FI)53
, other relevant studies and databases, and automotive market
studies54
. The literature review contributed to establishing the baseline and to collecting
information on all evaluation questions.
As presented in Annex 2, the public and targeted stakeholder consultations in 2020 and
AGVES expert meetings from 2019-2021 collected evidence and views from a broad
range of stakeholders, in order to assess the relevance, effectiveness, efficiency,
coherence and EU added value of the Euro 6/VI emission standards. In total, 32
contributions were received from public authorities, 6 from type-approval authorities, 8
from technical services, 38 from vehicle manufacturers, 64 from component suppliers, 80
from other industry stakeholders (including associations and fuel and energy industry),
11 from consumer organisations, 17 from environmental NGOs, 64 from citizens and 12
from other stakeholders to the targeted and public consultations regarding Euro 6/VI
evaluation.
Nevertheless, limited data were provided by stakeholders during the targeted consultation
on the evaluation. For the assessment of Euro 6/VI’s effectiveness and efficiency (and to
a lesser extent relevance), additional data from publicly available sources, namely the
EEA NECD database6
OECD statistics8
, the handbook on external costs and emission
factors of Road Transport9
and data on structural business statistics from Eurostat10
;
additional data on emission type-approvals from 10 type-approval authorities55
and on
Euro 6/VI vehicle sales in the EU-28 from IHS Markit56
and cost estimations by CLOVE
experts validated by key stakeholders57
were therefore of great importance to supplement
the limited data provided in the stakeholder consultation.
The assessment of Euro 6/VI’s effectiveness and efficiency and the quantification of the
impacts of the Euro 6/VI emission standards were supported by the use of the COPERT
and SIBYL model. The SIBYL and COPERT model were updated with the data
collected, latest emission factors and literature reviews as outlined in the previous
paragraphs. More details on the COPERT and SIBYL model are provided in Annex 4.
For this evaluation, no case studies were conducted. Reason for this being that in view of
52
See footnote 3
53
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
54
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, Chapter 7 References
55
Type-approval authorities provided emission type-approval data at the request of the European
Commission
56
IHS Markit, 2021. Provision of data on vehicle sales in the EU-28 for Evaluation of Euro 6/VI vehicle
emission standards
57
CLOVE, 2022. Euro 6/VI Evaluation Study. Annexes 1-6 ISBN 978-92-76-56522-2, Annex 4:
Presentation of Cost-Benefit Analysis Model
22
the limited data provided by stakeholders during the stakeholder consultation (only 3
manufacturers contributed, no contributions from automotive associations or suppliers),
no representative stakeholder from the most important stakeholder group, the automotive
industry, could be identified to carry out a case study. Instead, the comprehensive data
collection procedures outlined above were chosen as the best way forward.
4.2. Limitations and robustness of findings
The evaluation of the Euro 6/VI emission standards entails certain limitations that might
have certain implications on the validity of the conclusions. This section will discuss the
main limitations, the related repercussions and how the issues are addressed.
The main limitation in the analysis is related to the efficiency criterion. A limited
provision of cost data occurred during the targeted stakeholder consultation with data
from 3 manufacturers and 3 approval-authorities only, which were not representative for
EU-28. The shortcoming was tried to overcome without success by follow-up interviews
and extension of the consultation by 6 weeks, also due to COVID-19. This lack of cost
information had implications on the robustness of findings from Euro 6/VI’s efficiency
and hampered the credibility of the answers on the efficiency questions and related
conclusions. This potential weakness has been addressed through the additional
collection of data from numerous public sources and the Commission requested
additional data from type-approval authorities and bought additional data on Euro 6/VI
vehicle sales. Furthermore, cost estimates have been developed based on scaled-up desk
research and input provided by CLOVE experts to fill in the remaining gaps and have
been validated by key stakeholders. By these means, robust conclusions could be
achieved on the efficiency criterion.
A second limitation is related to discrepancies that have occurred between different
information sources. While limited data from type-approval authorities have been made
available in the first place, these data were not always in line with the estimations
provided by the SIBYL model. For example, when it came to the penetration of Euro
6/VI vehicles in the vehicle fleet, the SIBYL estimations seemed to overestimate the
uptake of the most recent steps of Euro 6/VI vehicles and the related timing. Since this
inconsistency could give wrong impression on the effectiveness of the Euro 6/VI
emission standards, the SIBYL model was updated with new data on emission type-
approvals from 10 Member States and vehicle sales in the EU-28 from 2013-2020
provided by IHS Markit. This approach is considered as appropriate mitigation measure.
A third limitation is the lacking implementation of monitoring requirements in the Euro
6/VI emission standards as suggested by Euro 6/VI impact assessments. Thus, neither
Member States have reported on the compliance processes to ensure that requirements of
the regulations are met, nor specific monitoring data on type-approval of vehicles, air
pollution levels and epidemiology on health impacts from road transport were available.
This problem was tried to overcome with the above-mentioned data collection, including
existing data on air quality from the European Environment Agency (EEA), and
literature review in 2020 and use of the updated SIBYL and COPERT model but could
not fully compensate the non-availability of monitoring data for Euro 6/VI emission
standards.
Overall, and despite the limitations presented above, the analysis underpinning this
evaluation is sufficient to formulate answers to the evaluation questions. As regards to
the monetised cost for industry and type-approval authorities, it is unlikely that further
analysis based on available data would yield considerably different results or would
23
significantly influence the overall findings.
5. ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS
5.1. Effectiveness
Evaluation question 1: To what extent and through which factors has Euro 6/VI
made cleaner vehicles on EU roads a reality? Which obstacles to cleaner vehicles on
EU roads remain taking into account possible unintended consequences on the
environment?
Overall conclusion: Evidence from literature and pollutant modelling shows that
Euro 6/VI emission limits have contributed to cleaner vehicles on EU roads for NOx
and particulate (PM and PN) emissions. For the other pollutants CO, HC (THC and
NMHC) and, for lorries and buses, NH3 and CH4 the impact of Euro 6/VI emission
limits seems less positive. When considering other factors than emission limits, the
enhanced Euro 6/VI testing procedures appear to have contributed most to cleaner
vehicles on EU roads, in particular the RDE testing introduced in the last Euro 6d
step.
Several obstacles to cleaner vehicles on EU roads have been detected which have
negative consequences on the environment: Evidence suggests that unregulated
NH3, N2O and NO2 emissions have emerged as unintended consequences by Euro
6/VI emission limits and the related changes in emission control technologies. In the
targeted stakeholder consultation, Member States and civil society underlined that
problems still exist with OBD monitoring resulting in high pollutant emissions and
that different limits for petrol and diesel vehicles did not have the positive effect that
was envisaged. Industry considered different application dates for the stepwise Euro
6/VI approach and for new vehicle types and new vehicles as an obstacle. All
stakeholder groups pointed out that Euro 6/VI testing procedures have become too
complex and that Euro 6/VI provisions are not effective to prevent tampering.
Effect of Euro 6/VI emission limits on cleaner vehicles on EU roads
Since providing a high level of environmental protection is one of Euro 6/VI’s
objectives, the impact of the Euro 6/VI emission standards58
on actually achieving
cleaner vehicles on EU roads is an important measure for its effectiveness. In this
context, the overall impact of the Euro 6/VI emission standards should depend on both
the emission performance of Euro 6/VI vehicles and on their share in the fleet.
Emission levels per vehicle:
Following the introduction of Euro 6/VI limits59
, large reductions in NOx emissions were
realised compared to Euro 5/V vehicles and with the Euro 6/VI vehicles becoming
progressively cleaner towards Euro 6d and Euro VI E60
. Evidence from PEMS tests and
remote sensing61
, comparing Euro 5/V and Euro 6/VI vehicles, has demonstrated that
58
See footnote 1
59
The changes in the emission limits moving from Euro 5/V to Euro 6/VI are summarized in Table 1 in
Section 2.
60
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.2.2 Are Euro 6/VI
vehicles cleaner (i.e. less polluting) in relation to Euro 5/V vehicles?
61
Remote sensing is an emissions measurement technique that evaluates emissions from passing motor
24
NOx emissions from Euro 6 diesel cars have reduced by more than 50%, while NOx
emissions from diesel vans have almost reduced by 70%.6263
Also, the NOx emissions
from Euro VI lorries and buses have reduced significantly in comparison to their Euro V
counterparts with the actual reduction depending on the specific heavy-duty category
(between 58 and 88%).64
Additionally, large reductions in PN emissions were realised for
Euro 6 petrol vehicles with the introduction of PN limits making the use of Gasoline
Particulate Filters (GPF) for Gasoline Direct Injection (GDI) vehicles inevitable.65
This
introduction in combination with more stringent PM limits also resulted in significant
PM reductions for petrol cars and vans, while the changes are less evident for diesel
vehicles.66
Also, PEMS measurements on a bus in urban operation found PM to be
approximately 85% lower.67
For the other pollutants CO, THC, NMHC and CH4 no similar information was found in
the literature.68
For this reason, the COPERT model69
was used to estimate potential
reductions to learn whether vehicles have become less polluting.70
For THC and NHMC,
these results indicated emission reductions of 38 and 33% for Euro 6 vehicles and 30 and
30% for Euro VI vehicles. Also for CO emissions from Euro 6/VI vehicles considerable
decreases were found in comparison to the emission from Euro 5/VI vehicles. While CO
limits did not change for Euro 6/VI, Euro 6 vehicles were found to pollute 70% less CO
in comparison to 86% less for Euro VI vehicles. These reductions can be explained by
the introduction of diesel particulate filters (DPF). CH4 emissions for new lorries and
buses decreased by 27% with the introduction of Euro VI. For NH3 emissions, however,
Euro VI buses were found to emit 70% more NH3 and Euro VI lorries even 75%71
Overall, this evidence is largely supported by all stakeholder groups that participated in
the targeted consultation: close to all stakeholders from automotive industry, Member
States and civil society72
strongly agreed that Euro 6/VI standards have led to cleaner
vehicles on the market.73
Similar results were found for the public consultation in which
the stakeholders from all groups including citizens indicated that air pollution originating
from new vehicles decreased slightly or even significantly over the past 10 years.74
Fleet Emission levels:
vehicles in real-world driving
62
O'Driscoll, et al., 2018. Real world CO2 and NOx emissions from 149 Euro 5 and 6 diesel, gasoline and
hybrid passenger cars.
63
Ricardo Energy & Environment, 2017. The Joy of (Euro) Six?
64
See footnote 63
65
AECC, Concawe, Ricardo, 2017. Real-World Emissions Measurements of a Gasoline Direct Injection
Vehicle without and with a Gasoline Particulate Filter
66
Giechaskiel, B., et al., 2019. European Regulatory Framework and Particulate Matter Emissions of
Gasoline Light-Duty Vehicles: A Review
67
TNO, 2014. NOx and PM emissions of a Mercedes Citaro Euro VI bus in urban operation
68
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.2.2 Are Euro 6/VI
vehicles cleaner (i.e. less polluting) in relation to Euro 5/V vehicles?
69
COPERT: The industry standard emissions calculator and Annex 4
70
Since this model also takes into account aspects such the effect of cold start phase, operation under hot
engine or after treatment system conditions, the degradation of emission control systems and the impact of
malfunctions or tampering, this analysis deviates from the approaches from the literature discussed above.
71
See footnote 60
72
In this context, civil society includes stakeholders from environmental NGOs, consumer organisations
and research organisations.
73
See footnote 60
74
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 3)
25
While the Euro 6/VI emission standards have succeeded in progressively making new
vehicles cleaner, these benefits are not yet fully felt on the EU roads.75
In 2020 less than
half of the EU vehicle fleet is type-approved to the Euro 6/VI emission standards (20%
Euro 6 cars and vans, 34% Euro VI lorries and buses)76
. Hence, the actual contribution of
the Euro 6/VI emission standards towards realizing cleaner vehicles on EU roads appear
to be a work in progress that will depend on the rate of uptake of cleaner Euro 6/VI
vehicles replacing more polluting Euro 5/V vehicles.
Taking into account these findings per vehicle, the COPERT model77
has quantified the
expected level of total emissions from all vehicles until 205078
and the emission saving
achieved to determine the impact of Euro 6/VI emission standards on the total level of
emissions of the regulated pollutants. Given the emission reductions per vehicle and the
fleet composition, considerable reductions in emission levels for NOx have been realized,
in particular for diesel vehicles.79
For cars and vans, NOx emission levels decreased by
22% between 2014 and 2020, while for lorries and buses a decrease by 36% was realised
between 2013 and 2020. Figure 20 presents the emission savings resulting from Euro
6/VI in comparison with the previous Euro standards with its specific focus on NOx, PM
and HC. It shows that the emission reductions for Euro 6 have been mainly realised after
the introduction of RDE testing, in the wake of Dieselgate. Significant savings have been
also realised for PM emissions emerging from cars and vans , especially for exhaust PM
emissions (28%). The emission savings achieved from lorries and busses were slightly
less with a 14% decrease in exhaust PM emissions which is normal considering the low
PM levels already achieved. For cars and vans, THC and NMHC emission levels have
decreased by 13 and 12%, while for lorries and buses THC decreased 14%.80
Although the emission limits were not changed for CO, significant savings have been
realised for CO emissions which were linked to the use of DPF. Following the new limit
for NH3 in Euro VI, emissions from this pollutant emerging from road transport actually
increased by approximately 30%. The emission limit seems not to be strict enough to
reduce NH3 emissions effectively.81
In the targeted stakeholder consultation on the evaluation, stakeholders across all
groups82
considered that the Euro 6/VI limits were highly or somewhat successful in
reducing actual pollutant emissions with only two stakeholders disagreeing on the
success of the limits for cars83
. Similarly, among the respondents to the public
consultation almost everyone indicated that the standards have been appropriate for
75
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.2.3 Are vehicles on
the EU roads cleaner?
76
SIBYL: Ready to go vehicle fleet, activity, emissions and energy consumption projections for the EU 28
member states
77
For more information see Annex 5 Evaluation Euro 6/VI emission standards: chapter 4.2. Limitations
and robustness of findings and Annex 4
78
See chapter 1.2: The vehicles fleet is expected to be composed out of 100 percent Euro 6/VI vehicles in
2050, hence the impacts of Euro 6/VI are expected to last until 2050.
79
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.2.4 What was the
impact of Euro 6/VI on the total level of emissions?
80
See footnote 79
81
See footnote 79
82
The stakeholder groups are civil society (research organisations, consumer organisations, environmental
NGOs), industry (manufacturers, suppliers) and Member States (public authorities, type-approval
authorities, technical services).
83
One supplier and one technical service
26
reducing pollutant emissions from road transport.84
In particular, the new PN limit was
considered an important step to better regulate fine particles and for Europe to take a
leading role in this. Nevertheless, there still seems to be room to lower the limits for solid
particles without large investment costs nor significant technical modifications.85
When
the stakeholders were asked in the public consultation whether the Euro 6/VI limits are
sufficiently strict, the majority of Member States’ and civil society stakeholders
somewhat or completely disagreed.86
Especially the limits for NOx and PM/PN were
considered not sufficiently low by the respondents that expressed discontent about the
strictness of the limits.87
Figure 20 – NOx, PM and HC savings for Euro 6 cars and vans, and Euro VI lorries and
buses88
84
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 5)
85
See footnote 79
86
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 12)
87
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 12.1)
88
CLOVE, 2022. Euro 6/VI Evaluation Study. Annexes 1-6. ISBN 978-92-76-56522-2, Annex 3. 9.3.3
Total emission savings
27
Effect of other Euro 6/VI factors on cleaner vehicles on EU roads
When considering other factors than Euro 6/VI emission limits that positively affected
the achievements of cleaner vehicles on EU roads, the enhanced Euro 6/VI testing
procedures appear to have contributed the most.
In-service conformity (ISC) testing including RDE testing for cars and vans and PEMS
testing for lorries and buses are widely reported effective in ensuring low emissions.89
During the EMIS committee90
, the JRC emphasised the ability of ISC testing and market
surveillance to ensure compliance and subsequently emission reduction.91
In addition,
stakeholders from most groups generally consider RDE and the introduction of
conformity checks through PEMS to be very successful and effective. Several
environmental NGOs expect that third party ISC testing will have a significantly positive
impact for tackling emissions but argue that it is too early to assess this for cars and
vans.92
The introduction of cold-start emissions to testing procedures is also considered highly
effective in ensuring that most emissions are accounted for cars, vans, lorries and buses.
Before these emissions were regulated, the first five minutes of a trip – in which
emissions are generally higher – were excluded from the data and hence not accounted
for. When adding cold-start to the PEMS data, the importance of this aspect of testing
becomes very clear.93
While diesel cars can contribute up to 38% more to the total NOx
emissions when cold-start is included, cold-starts contribute up to 86% of PN emission of
petrol vehicles without a particulate filter.94
Unintended consequences and obstacles of Euro 6/VI to cleaner vehicles on EU roads
While the Euro 6/VI emission standard aims at reducing the regulated pollutant
emissions from new vehicles, evidence suggests that emissions of other unregulated air
pollutants could be affected by Euro 6/VI and the related changes in emission control
technologies. There is no NH3 emission limit for cars and vans, despite the fact that cars
89
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.4.2 To what extent
have specific provisions/aspects of the legal framework played a role in terms of achieving the objective of
reducing pollutant emissions?
90
See footnote 6
91
JRC, 2016. EMIS hearing on 19 April 2016: Replies to the Questionnaire to the Joint Research Centre
(JRC), Committee of Inquiry into Emission Measurements in the Automotive Sector
92
See footnote 89
93
See footnote 89
94
Hooftman, N., et al., 2018. A review of the European passenger car regulations – Real driving emissions
vs local air quality
28
are actually the largest contributors to NH3 emissions from transport in Europe.95
The
reason is that emission control technologies used to restrict NOx emissions in line with
the Euro 6 requirements cause an ammonia slip due to dosing of urea.96
As a result, the
use of ammonia slip catalysts (ASC) has been increased in recent Euro 6d diesel
vehicles, in which N2O may be produced as a by-product. For gasoline vehicles,
particularly high NH3 and N2O emissions have been observed on positive ignition (PI)
engines equipped with three-way catalysts.97
Additionally, aftertreatment systems to
reduce NOx in Euro 6/VI have increased the NO2 to NOx ratio of vehicle exhaust.98
However, this effect seems to have been mitigated in the latest Euro 6/VI steps. These
unintended consequences on the environment by new NH3, N2O and NO2 emissions will
be further discussed under the relevance criterion (see chapter 5.3).
Some obstacles of Euro 6/VI emission standards to cleaner vehicles on EU roads have
been detected in the targeted stakeholder consultation on the evaluation99
:
 Threshold OBD – While many industry stakeholders consider the threshold for on-
board diagnostics (OBD) to have been successful, non-industry stakeholders (e.g.
public authorities, technical services, environmental NGOs) identified that problems
still exist with OBD due to unclear requirements for monitoring and occurring
failures in identifying malfunctions resulting in high emissions. In addition, the
majority of respondents from all stakeholder groups to the public consultation
indicated that the limited effect of OBD at least contributes somewhat to an increase
in pollutant emissions. For industry, however, 28 of the 57 respondents indicated that
the limited effect of OBD only contribute very little or not at all to this increase.100
 Differences in Euro 6/VI limits based on technology and fuel – Differences such as
different limits for diesel, petrol and CNG cars did not have the positive effect that
was envisaged, but it actually prevented greater achievements101
. In the public
consultation, 87 of 124 stakeholders from all groups indicated that developing fuel-
and technology-neutral limits would be (very) important to improve the effects of
emission limits for vehicles102
.
 Different application dates for the stepwise Euro 6/VI approach and for new vehicle
types and new vehicles – Industry stakeholders were the most sceptical regarding
these different application dates, indicating that it is important to introduce common
dates to ensure regulatory planning reliability. This concern was emphasised in public
consultation were 101 out of 128 stakeholders from all groups indicated that the
different application dates for the stepwise approach were considered complex or
very complex. For the different application dates for new types and vehicles, 88 out
95
EEA, 2020. National Emission Ceilings Directive emissions data viewer 1990-2018
96
ICCT, 2019. Recommendations for post-Euro 6 standards for light-duty vehicles in the European Union
(submitted through AGVES)
97
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.3.1.4 Do the standards
properly cover all relevant/important types of pollutant emissions from vehicles that pose a concern to air
quality and human health?
98
See footnote 96
99
See footnote 89
100
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 15)
101
Suarez-Bertoa et al., 2019. On-road emissions of passenger cars beyond the boundary conditions of the
real-driving emissions test. Environmental Research, Volume 176
102
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 13)
29
of 128 from all groups indicated that this feature of the legislation is at least
somewhat complex.103
 Complexity of Euro 6/VI emission tests – Stakeholders from all groups, except
environmental NGOs, indicated in the targeted consultation that the complexity of
emission tests has played a negative role as it resulted in errors in performing the
emission tests and calculations and significantly increased the capacity needed by
manufacturers to comply with the Regulations, which in its turn increased prices and
slowed down the uptake of Euro 6/VI vehicles. Moreover, the introduction of
temporary and final conformity factors104
are expected to have had a negative effect
on the achievements of Euro 6/VI so far. This result was also confirmed in the public
consultation where 98 out of 126 respondents from all stakeholder groups considered
that the standards are complex or even very complex.105
Especially the procedures of
the emission tests and the number of emissions are considered (highly) complex by
most respondents. Only civil society was less convinced of the complexity related to
the number of tests, which they consider appropriate to achieve effective emission
standards.106
 Tampering – Stakeholders from all groups indicated that the Euro 6/VI provisions
taken to prevent tampering107
with the emission control computer, odometer or other
vehicle control unit are not effective and are expected to have had a negative effect
on the achievements of Euro 6/V so far. A similar result was found in the public
consultation in which a substantial majority across all stakeholder groups indicated
that tampering still contributes to an increase in emissions.108
Evaluation question 2: How effective are the Euro 6/VI testing procedures to verify
the emission standards?
Overall conclusion: The new on road RDE testing introduced under Euro 6d-temp
for cars and vans reduced the gap between type-approval and real-world emissions.
The Portable Emission Measurement Systems (PEMS) testing introduced under
Euro VI D for lorries and buses was less effective. While cold start emissions is
already addressed in the last Euro VI E step that still has to enter into force, the gaps
in low-speed driving conditions and idle vehicles with low loads identified for Euro
V vehicles continued in Euro VI vehicles.
Euro 6/VI testing procedures have made a gradual progress towards increasing the
level of representativeness of the considered driving cycles and conditions of use,
especially in urban driving conditions. Nevertheless, despite these improvements,
important emissions remain unaccounted under Euro 6/VI emission testing. In
particular, test boundaries for cars and vans still exclude short trips, high mileage
103
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 9)
104
See footnote 19
105
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 8)
106
See footnote 102
107
Regulation (EC) No 595/2009 defines tampering as “inactivation, adjustment or modification of the
vehicle emissions control or propulsion system, including any software or other logical control elements of
those systems, that has the effect, whether intended or not, of worsening the emissions performance of the
vehicle”
108
See footnote 103
30
and high altitude circuits, and severe temperature conditions; and test boundaries for
lorries and buses low loads, low speed and idle times that are of great importance in
urban areas. Hence, a complete coverage of real-world driving cycles and all
conditions of use is still missing in Euro 6/VI emission standards.
The response to evaluation question 1 already indicated that the enhanced Euro 6/VI
testing procedures have been of great importance for making cleaner vehicles on EU
roads a reality. In particular, ISC testing with RDE and PEMS testing, and the
introduction of cold-start emissions to testing procedures are considered to be important
factors for making cleaner vehicles on EU roads a reality. Now, this question evaluates
the new Euro 6/VI testing procedures to check whether they reduced the gap between
real-world emissions and type-approved emissions and whether they are actually
representative for real-world driving cycles and conditions of use.
Gap between real-world emissions and type-approved emissions
For cars and vans, before Euro 6 emission standards, and in particular before the
introduction of RDE testing, significant levels of deviation between real-world and type-
approved emissions were reported. The JRC demonstrated that pre-RDE Euro 6 diesel
vehicles (Euro 6b) emit on average almost three times as much NOx emissions and 40%
more CO emissions than the respective emission limits allow.109
This level of deviation
decreased somewhat with the introduction of WLTP testing (Euro 6c)110
and much more
with the introduction of RDE testing (Euro 6d-Temp).111
The impact of RDE testing on
the gap between real-world and type-approved emissions is demonstrated in Figure 21
for NOx and PN emissions.
Figure 21 – NOx and PN emissions on a sample of vehicles before and after the
introduction of RDE testing112
109
JRC, 2018. Joint Research Centre 2017 light-duty vehicles emissions testing: Contribution to the EU
market surveillance: testing protocols and vehicle emissions performance
110
WLTP was primarily introduced to reduce the gap between real-world and type-approved CO2
emissions and fuel consumption
111
JRC, 2019. Joint Research Centre 2018 light-duty vehicles emissions testing: contribution to the EU
market surveillance: testing protocols and vehicle emissions performance
112
See footnote 53
31
Except for some reservations due to incompleteness in the RDE coverage for urban
driving conditions, the majority of stakeholders from all groups participating in the
targeted consultation agreed with the above findings for Euro 6 emission testing stating
that the introduction of RDE testing reduced the gap between type-approval and real-
world emissions. However, in the public consultation only a majority of industry and
citizen respondents indicated that RDE testing ensures that cars and vans are compliant
with the pollutant limits in all driving conditions.113
In addition, a majority across all
stakeholder groups, excluding industry, indicated that shortcomings in the existing on-
road test at least contributed somewhat to an increase in emissions.114
For lorries and buses, the introduction of new Euro VI testing procedures and on-road
testing procedures - WHTC, WHSC and PEMS testing - had limited positive results in
reducing the existing gap between real-world and type-approved emissions. In particular
for NOx emission, the large gaps in low-speed driving conditions and idle vehicles with
low loads identified for Euro V vehicles continued in Euro VI vehicles.115
Thus, the
driving cycle coverage proves to be insufficient and the margin for optimisation of
vehicle’s engine to the test remains.
However, stakeholders from all stakeholder groups broadly agreed in the targeted
stakeholder consultation on the effectiveness of the Euro VI new testing procedures,
which is not fully in line with the above findings. Especially for the introduction of on-
road testing procedures for in-service conformity testing (i.e. PEMS), this is perceived to
have reduced the gap between type-approval and real-world emissions by 44 out of 45
stakeholders that answered this question.116
Also in the public consultation a majority of
industry and citizen respondents indicated that PEMS testing ensures that lorries and
buses are compliant with the limits in all driving conditions.117
Hence, progress was
reported towards narrowing the gap between real-world emissions and type-approved
emissions. Nevertheless, stakeholders - mostly from Member States and civil society -
replied to the public consultation and the Combined Evaluation Roadmap/Inception
113
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 14)
114
See footnote 108
115
Grigoratos, T., et al., 2019. Real world emissions performance of heavy-duty Euro VI diesel vehicles;
TNO, 2018. Tail-pipe NOx emissions of Euro VI buses in the Netherlands
116
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.3.2. What has been
the impact of the changes to the testing procedures in terms of reducing the gap between real emissions and
type-approval emissions?
117
See footnote 113
32
Impact Assessment118
by saying that there is still a wide gap, especially in urban driving
conditions, which confirms the above findings on WHTC, WHSC and PEMS testing.
Coverage of actual real-world driving cycles and conditions of use
Moving from Euro 5 emission testing with laboratory NEDC testing to Euro 6c with
laboratory WLTP testing and Euro 6d-TEMP with a combination of WLTP and RDE
testing, gradual progress has been made towards increasing the level of
representativeness of the considered driving cycles and hence conditions of use and the
robustness against defeat strategies. This follows from the shift in requirements through
RDE testing requiring the inclusion of urban, rural and motorway driving cycles and
expanding boundary conditions by accounting for differences in ambient temperature and
altitude which deviates from the repeatable and reproducible testing cycles of NEDC and
WLTP testing. Nevertheless, despite these improvements, important emissions remain
unaccounted under Euro 6/VI emission testing. The test boundaries for cars and vans still
exclude short trips, high mileage and high altitude circuits, and severe temperature
conditions. Since pollutant emissions are generally higher in such driving cycles and
conditions of use, a large part of the overall emissions remains unaccounted for.119
Figure
22 illustrates how driving cycles with a very low average speed – and hence not covered
in RDE testing – tend to result in NOx emissions far above the current emission limit for
petrol cars.
Figure 22 - Emission performance of Euro 6d vehicles for NOx for different average
speeds (NOx limit for petrol cars = 60 mg/km)120
Moving from Euro V emission testing with ESC/ETC/ELR testing to Euro VI A with
WHTC/WHSC testing and Euro VI D with the addition of PEMS testing to ISC testing,
improvements were made to the reliability of testing for lorries and buses. New driving
cycles and hence conditions of use include urban, rural and motorway operations and
cover a wide range of load and speed operations. In addition, the new requirements
hamper defeat strategies by manufacturers through removing the possibilities for prior-
calibrating the emission control system to meet the limits. Nevertheless, the test
boundaries still exclude important emissions measured at low loads, low speed and idle
118
See footnote 50
119
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.3.3 Have the testing
procedures increased reliability in terms of the measurement of the vehicles’ emissions and verification of
the level of emissions in comparison to the emissions limits?
120
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
33
times that are of great importance for lorries and buses operating in urban areas. In
addition, an important level of tampering is still reported under Euro VI, following
lacking third-party verification and the fact that ISC is undertaken by the
manufacturer.121
Hence, a complete coverage of real-world driving cycles and all conditions of use is still
missing in Euro 6/VI emission standards. As the cycles and conditions that are not yet
included also result in extensive pollutant emissions, it is of great importance for human
health and environment to review the testing boundaries.
Evaluation question 3: What are the benefits of Euro 6/VI emission standards and
how beneficial are they for industry, the environment and citizens?
Overall conclusions: For industry, Euro 6/VI emission standards had overall
neither a clear positive nor a clear negative impact. It is difficult to determine
whether the increased regulatory costs, in particular for cars and vans after the
necessary introduction of RDE testing in the wake of Dieselgate, have affected the
respective profit margins and the overall profitability. Clearly, it cannot be
determined if a price increase of cars since 2014 is associated to regulatory costs
associated with the Euro 6 emission standards, it could also be the result of various
other factors affecting prices (e.g. difficult economic conditions, increased
installation of comfort equipment or changes in fleet composition towards more
heavy and expensive vehicles). The regulatory costs also do not necessarily imply a
direct negative impact on the competitiveness of the EU manufacturers compared to
non-EU competitors, as the latter are faced with similar costs. In the contrary, to
ensure the competitiveness of the EU automotive industry, it is of great importance
that stricter Euro 6/VI emission limits and testing procedures help to ensure access
to external markets for European manufacturers, which have adopted stricter limits,
in particular the United States and China. Considering the number of R&D projects
directly linked to Euro 6/VI emission standards, it is expected that the standards had
a positive impact on research activities in the EU. On the other hand, some
stakeholders suggested that most of the technologies were already available on the
market and the standards only fostered innovation through improving existing
technologies and subsequently decreasing their costs. Lastly, industry reports
differences in interpretation of Euro 6/VI emission standards at national level which
seems to hamper the full achievement of the objective to achieve harmonised rules
on the construction of vehicles.
For the benefit of the environment, Euro 6/VI emission standards reduced pollutants
emitted by the road transport sector, especially from NOx and particulates
emissions. However, no changes are observed in the share of road transport
emissions to total emissions from all sectors. Next to directly achieving benefits for
the environment, the Euro 6/VI emission standards could also benefit the
environment by raising public awareness on vehicle-related air pollution problems
and in that way, influencing public attitude.
For the benefit of citizens, Euro 6/VI emission standards curbs health impacts by
reducing pollutants emitted by the road transport sector that could cause respiratory
121
See footnote 119
34
and cardiovascular diseases upon inhalation, for example bronchitis, asthma or lung
cancer. On the other hand, there is no compelling evidence suggesting that the Euro
6/VI emission standards have had a positive or negative impact on employment.
Benefits for industry
1) Impact on harmonised rules on the construction of vehicles
A specific objective for the creation of Euro 6/VI emission standards was to achieve
harmonised rules on the construction of motor vehicles to limit distortions in competition
across Europe that would be realised by the Member States. That way, this harmonised
approach should benefit industry.
While there is an overall understanding amongst most stakeholders groups122
that the
introduction of the Euro 6/VI emission standards has resulted in a level of harmonisation
that would not have been achievable at the level of the Member States, several concerned
industry representatives do not agree that Euro 6 emission standards have ensured
harmonised rules (7 out of 30).123
They report discrepancies in the form of differences in
interpretations of the Regulations by different type-approval authorities. For example,
there would still be differences in interpretations in the authorisation to disable pollution-
control devices to protect components and in measurement devices’ errors. This situation
makes it possible for manufacturers to select the type-approval authority with the least
stringent interpretation of existing rules.124125
Overall a small majority of respondents to
the public consultation indicated that the complexity in the current standards leads to
misinterpretation amongst type-approval authorities. Especially stakeholders from civil
society seem to be convinced of the occurrence of such misinterpretations.126
Due to
these reported differences in interpretation, full harmonisation on the construction of
motor vehicles seems not to be achieved yet.
2) Impact on competitiveness of the EU automotive industry
a. Impact on cost and price competitiveness
For cars and vans, the introduction of Euro 6 emission standards resulted in significant
equipment costs for emission control technologies (see detailed cost assessment in
section 5.2). In particular, the introduction of RDE testing required improvements of
existing equipment and installation of new equipment. Moreover, the introduction of the
new standards also entailed considerable other costs during implementation phase for
vehicle testing and type-approval (see detailed cost assessment in section 5.2). While
there is uncertainty surrounding the exact rise in costs, it is clear that the actual
regulatory costs were higher than initially anticipated127128
.
122
See footnote 82
123
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.5.2. To what extent
has the adoption of the standards ensured the presence of harmonised rules on the construction of motor
vehicles?
124
de Sadeleer, N., 2016. Reinforcing EU testing methods of air emissions and the approval processes of
vehicle compliance in the wake of the VW scandal
125
Gieseke and Gerbrandy, 2017. Final report on the inquiry into emission measurements in the automotive
sector A8-0049/2017- Committee of Inquiry into Emission Measurements in the Automotive Sector
126
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 10)
127
For cars and vans, the estimated equipment costs are higher than the ones that were identified in
SEC(2005) 1745 (Euro 6 Impact Assessment). In addition, no other compliance costs were considered in
35
The transmitted regulatory costs by change in vehicle prices for consumers is less clear.
For cars, real prices have on average increased since 2014. While this increase could be
linked to the increase in regulatory costs associated with the Euro 6 emission standards, it
could also be the result of various other factors affecting prices (e.g. difficult economic
conditions, increased installation of comfort equipment or changes in fleet composition
towards more heavy and expensive vehicles).129130
Stakeholders from all groups
participating in the targeted consultation suggest that Euro 6/VI has resulted in a small
increase in vehicle prices with industry respondents generally indicating a more
extensive rise in prices. Similar input was provided to the public consultation where 121
out of 139 respondents from all stakeholder groups (including citizens) considered that
Euro 6/VI has led to an increase in the prices of cars, vans, lorries and buses.131
The profitability of the EU automotive sector was analysed. However, it is difficult to
determine whether the increased regulatory costs have affected the respective profit
margins and the overall profitability. According to industry stakeholders, the introduction
of Euro 6/VI emission standards had a significant or limited negative impact on the
profitability of the EU automotive sector. Since the Euro 6/VI emission standards apply
to all vehicles sold on the EU internal market, the regulatory costs do not necessarily
imply a direct negative impact on the competitiveness of the EU manufacturers compared
to non-EU competitors, as the latter are faced with similar costs. Therefore, competitive
disadvantages referred to by EU manufacturers are expected to be rather indirect through
the relatively higher compliance costs for EU manufacturers in comparison to their
competitors in lower cost countries.132
b. Impact on international competitiveness
To ensure the competitiveness of the EU automotive industry, it is of great importance
that stricter Euro 6/VI emission limits and testing procedures help to ensure access to
external markets for European manufacturers. When comparing the emission
requirements in Europe today with those in place in other key markets (i.e. the United
States and China), however, the EU appears to be lagging behind its main competitors.
Figure 23 demonstrates that with the exception of PM emissions, both the United States
and China have adopted more ambitious limit values for cars and vans. Also when it
comes to the testing procedures, the United States currently takes the lead through the
creation of detailed standards and OBD enforcement mechanisms that eliminate
loopholes.133
SEC(2005) 1745 and SEC(2007) 1718 (Euro 6/VI Impact Assessments)
128
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.7.3. What has been
the impact of the Euro 6/VI standards on the competitiveness of the EU automotive industry?
129
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, Chapter 5.1.6.2. Have there
been any impacts from the Euro 6/VI in relation to: prices of vehicles, CO2 and other emissions?
130
AEA, 2011. Effect of regulations and standards on vehicle prices. Report to the European Commission
– DG Climate Action
131
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 3.1)
132
See footnote 128
133
ICCT, 2015. Comparison of US and EU programs to control light-duty vehicle emissions
36
Figure 23 – Comparison of latest emission limits in the EU, United States and China for
light-duty vehicles, Source: ICCT, 2019134
Hence, the more stringent emission limits introduced in Euro 6/VI are not sufficient to
result in competitive gain for the European manufacturers given that their global
counterparts are implementing stricter standards.135
Nevertheless, the Euro 6/VI emission
standards are expected to have an impact on the access to markets by reducing the
emission reductions required to sell vehicles on other markets with even stricter
requirements.136
In addition, the stakeholders from all groups participating in the targeted
consultation widely indicated that the Euro 6/VI emission standards have actually
realised a positive effect on the EU automotive industry’s competitiveness, with industry
being slightly hesitant in their reply. Feedback from the ICCT indicated that without the
Euro 6/VI emission standards, European manufacturers could have lost the ability to
develop and produce desirable vehicles for the US and Chinese market.
c. Impact on the capacity to innovate
Considering the number of R&D projects directly linked to Euro 6/VI emission
standards, it is expected that the standards had a positive impact on research activities in
the EU.137
For example, the European Investment Bank (EIB) confirmed that loans
amounting to €13.6 billion were provided to car manufacturers for the development of
pollution-control devices between 2005 and 2015.138
These research activities were
mainly focussed on improvements in existing technologies rather than on the
development of completely new technologies. These findings are confirmed by all the
134
See footnote 96
135
Wells, P. et al., 2013. Governmental regulation impact on producers and consumers: A longitudinal
analysis of the European automotive market.
136
See footnote 128
137
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.8.2 To what extent
did the introduction of Euro 6/VI incentivise public and private research activity towards the development
of new clean vehicle technologies and emissions control technologies?
138
See footnote 125
37
stakeholder groups participating in the targeted consultation: 64 of 73 respondents across
all groups indicated that the Euro 6/VI emission standards have provided an incentive for
research activities towards the development of new clean vehicle technologies. In
addition, multiple stakeholders, mostly from civil society, stress that for Euro 6, there
was an acceleration in R&D activities following the introduction of RDE testing. On the
other hand, some stakeholders from industry suggested that most of the technologies
were already available on the market and the standards only fostered innovation through
improving existing technologies and subsequently decreasing their costs.139
In a similar
way, there are now technologies available on the market allowing for further emission
reductions than currently required under the Euro 6/VI emission standards.140
Although emission control technologies similar to the ones required for the Euro 6/VI
emission standards were already adopted in other major markets, their adoption in
Europe would most likely not have happened at a similar rate without the introduction of
Euro 6/VI emission standards in Europe. While the technology was largely available, its
voluntary uptake in Europe would have depended on costs and customer demand. With
emission control technologies only adding costs with little perceived value for
consumers, it is clear that manufacturers would most likely not have voluntarily adopted
the technology required under Euro 6/VI.141
To encourage technology advances and improvements following the introduction of Euro
6/VI emission standards, support instruments were put in place at EU and Member State
level. At EU level, manufacturers and suppliers were able to make use of Horizon 2020
projects focusing on the development of cleaner engine and aftertreatment technologies.
Next to that, EU support instruments – such as the above-mentioned loans from the
European Investment Bank - were available to finance related R&D activities. Member
State support occurred either through nationally funded R&D support projects or through
financial incentives. With 16 out of 30 industry stakeholders indicating in the targeted
consultation that they made use of national projects, this support mechanism has been
employed most frequently. Financial incentives by Member States, which have been
encouraged in the Euro 6/VI emission standards142
, have only been used by 6 out of 25
industry stakeholders that responded to this question in the targeted consultation.143
In
general, the responses to the public consultation suggest that the standards have
encourage the development of innovative technologies for cleaner vehicles, as this was
indicated by more than 90 percent of the respondent with no remarkable differences
between the stakeholder categories.144
These mixed results on the competitiveness of the automotive industry are reflected in
the responses to the public consultation. Most respondents from all stakeholder groups
considered that Euro 6/VI had at least somewhat of an impact on reinforcing the
competitiveness of the industry, while the majority of respondents from Member States
139
See footnote 137
140
See footnote 53
141
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.8.3 To what extent
did the introduction of Euro 6/VI incentivise the adoption of new clean vehicle technologies and emissions
control technologies?
142
Article 12 Regulation (EC) No 715/2007; Article 10 Regulation (EC) No 595/2009
143
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, Chapter 5.1.8.5 Were there
relevant mechanisms in place to support the development of relevant technologies?
144
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 4)
38
believe Euro 6/VI to be a great or very great contributor here.145
Benefits for environment
A specific objective for the creation of Euro 6/VI emission standards was to improve air
quality by reducing pollutants emitted by the road transport sector. In addition, the Euro
6/VI impact assessments146
indicated that monitoring data on air pollution levels and the
epidemiology on health impacts (see below) will point to the wider success of the
policies.
Euro 6/VI vehicles have realized large emission savings for NOx and particulate (PM and
PN) emissions, in combination with small savings for CO, HC (THC and NMHC) and
increasing emissions of NH3 (see evaluation question 1). All these pollutants are
regulated under the National Emission Ceilings Directive (NECD)147
, which requires
Member States to set national emission reduction commitments. That way, the emission
savings brought by Euro 6/VI emission standards for road transport sector have
contributed to efforts for achieving the NECD targets from all sectors. However, no
changes are observed in the share of road transport emissions to total emissions from all
sectors6
. This result could be influenced by the increasing trend in the number of motor
vehicles on EU roads, increasing mileage per vehicle or decreasing emission levels in
other polluting sectors.148
Most stakeholders from all groups agree that the Euro 6/VI
emission standards have improved air quality. However, one environmental NGO
stresses that road transport is still an important contributor to the total emission in the
EU, which limits the Euro 6/VI objective to improve air quality by reducing pollutants
emitted by the road transport sector.
Next to directly achieving benefits for the environment, the Euro 6/VI emission standards
could also benefit the environment by raising public awareness on vehicle-related air
pollution problems and in that way, influencing public attitude. Nevertheless, the direct
contribution of the Euro 6/VI emission standards in this context appears to be limited.
While the last Eurobarometer survey149
, which was conducted in 2017, illustrated that the
public seems to be more aware of air pollution issues and the role of motor vehicles in
creating those, it is possible that other trends might have a larger impact. In particular,
the growing use of Low Emission Zones (LEZs) in urban areas are likely to have
positively affected public awareness in this context.150
While the creation of LEZs could
have also taken place in the absence of the Euro 6/VI emission standards (i.e.
continuation of Euro 5/V emission standards), the further development of LEZs does
depend on the continuation of the Euro standards as Euro 6/VI vehicles allow local
145
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 6)
146
See footnote 3
147
Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants. The
Directive establishes the emission reduction commitments for the Member States' anthropogenic
atmospheric emissions of SO2, NOx, NMVOC, NH3 and PM2,5 and requires that national air pollution
control programmes be drawn up, adopted and implemented and that emissions of those pollutants and the
other pollutants referred to in Annex I, including CO, as well as their impacts, be monitored and reported.
NMHC can be considered equivalent to NMVOC.
148
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.5.3 What has been
the contribution of the standards to achieving National Emission Ceilings Directive (NECD) targets?
149
Special Eurobarometer 468, November 2017. Attitudes of European citizens towards the environment
150
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.8.6 Have the
standards contributed towards raising awareness on vehicle-related air pollution and influenced public
attitude?
39
authorities to impose access restrictions on up to Euro 5/V vehicles. That way, the
introduction of Euro 6/VI could have raised awareness on air pollution issues through
allowing cities to strengthen their LEZ. However, it is not possible to quantify this
possible benefit.
Benefits for citizens
1) Reduced impact on health
By reducing pollutants emitted by the road transport sector, the Euro 6/VI emission
standards provided also a benefit to citizens by curbing health impacts from road
transport emissions that could cause respiratory and cardiovascular diseases upon
inhalation, for example bronchitis, asthma or lung cancer. Combatting such health
impacts from road transport could result in a reduction in the external costs, that means,
medical treatment costs, production losses due to illnesses and even deaths.151
Table 38 shows the analysis carried out by the SIBYL model (see Annex 4), confirming
that the Euro 6/VI emission standards generated a decrease in external costs through the
reduction of health impacts originating from road transport. Euro 6 has resulted in a €31
billion decrease in external costs up to 2020 through the reduction of NOx and PM
emissions from cars and vans. While the largest share of the benefits were realized in the
early steps of Euro 6 following the new emission limits, additional benefits were realized
through the introduction of RDE testing and these benefits are expected to increase
significantly when more Euro 6d vehicles will be sold after 2020. With a total of €67
billion, health benefits of a different scale were realised with the introduction of Euro VI,
mainly from reduction of NOx emissions from lorries and buses. While health benefits
have already been realised at this point, they are expected to increase exponentially over
the next thirty years, exceeding external cost savings of €1.8 trillion.152
These positive health impacts are validated in the responses to the public consultation. A
majority of stakeholders from industry, citizens and especially Member States indicated
that Euro 6/VI contributed to protecting human health.153
Next to that, these impacts are
largely confirmed in the literature154
, remaining health risks related to certain regulated
and unregulated pollutant emissions remain a concern. Mainly emissions during
regeneration at short intervals, especially for PN emissions155
or emissions of unregulated
yet hazardous pollutants, such as NO2, present serious health risks.
Table 38 – Reduced health impact of Euro 6/VI emission standards: Changes in external
costs (in € billion)156
Vehicle Category Benchmark for savings 2014- 2020 2021-2050
NOx
Cars and vans
Euro 6 pre-RDE compared to Euro 5 26.4 446.3
Euro 6 RDE compared to Euro 6 pre- 2.1 305.8
151
European Commission, 2019. Handbook on the external costs of transport
152
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.7.2 Have there been
any changes in the levels of observed health impacts as a result of Euro 6/VI?
153
See footnote 145
154
European Commission 2019. Handbook on the external costs of transport; Grigoratos, T., et al.., 2019.
Real world emissions performance of heavy-duty Euro VI diesel vehicles.
155
Giechaskiel, B., 2020. Particle Number Emissions of a Diesel Vehicle during and between Regeneration
Events. Catalysts; Valverde, V. & Giechaskiel, B., 2020. Assessment of Gaseous and Particulate Emissions
of a Euro 6d-Temp Diesel Vehicle Driven >1300 km Including Six Diesel Particulate Filter Regenerations.
156
See footnote 152
40
Vehicle Category Benchmark for savings 2014- 2020 2021-2050
NOx
RDE
Total Euro 6 compared to Euro 5 28.5 752.2
Lorries and buses Euro VI compared to Euro V 65.1 979.8
Total monetised benefits from NOx reduction 93.6 1 732.0
PM10
Cars and vans
Euro 6 pre-RDE compared to Euro 5 1.9 31.4
Euro 6 RDE compared to Euro 6 pre-
RDE
0.1 7.8
Total Euro 6 compared to Euro 5 2.0 39.2
Lorries and buses Euro VI compared to Euro V 1.4 40.0
Total monetised benefits from PM10 reduction 3.4 79.2
2) Direct impact on employment
Employment in the automotive industry, both for manufacturers and suppliers, could
have been positively and negatively affected by the Euro 6/VI emission standards.
However, there is no compelling evidence suggesting that Euro 6/VI has had a positive
or negative impact on employment.
The introduction of Euro 6/VI emission standards could have resulted in a short-term
increase in labour costs, induced by the requirements to implement emission control
systems. Since the regulatory costs would have diminished over the application and
hence evaluation period, the short-term negative employment effects would follow this
trend and could even be transformed into a positive long-term employment effect. This
was demonstrated in the GEAR 2030 Strategy 2015-2017 study157
which used modelling
to understand the impact of EU regulations on the wider economy. The results from this
exercise showed that small changes in the industry’s composition of GDP, of
development of wages and labour productivity over time can change employment
numbers, while the total wage ratio remains constant. That way, employment effects can
turn significantly positive. Nevertheless, it should be stressed that the effect caused by the
Euro 6/VI emission standards cannot be disentangled from other factors that may have
affected labour costs in the automotive sector, including other environmental and safety
legislations.
In addition, positive employment effects could have been realised in the automotive
sector and in the type-approval authorities through the creation of new jobs in R&D
related activities or in activities associated with the implementation of the Euro 6/VI
emission standards. This assumption was confirmed by a number of type-approval
authorities and manufacturers that participated in the targeted stakeholder
consultation.158159
157
European Commission, 2017. GEAR 2030 Strategy 2015-2017. Comparative analysis of the
competitive position of the EU automotive industry and the impact of the introduction of autonomous
vehicles
158
4 out of 20 manufacturers that provided responses and 2 industry associations reported costs for staff
hired; 2 out of 4 type-approval authorities reported costs incurred for new staff and inspectors.
159
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.7.4 Has there been
any direct impact (positive/negative) on employment?
41
5.2. Efficiency
Evaluation question 4: What are the regulatory costs related to the Euro 6/VI
emission standards and are they affordable for industry and consumers? Have Euro
6/VI achieved a simplification of vehicle emission standards?
Overall conclusions:
The Euro 6/VI emission standards have led to considerable regulatory costs for
automotive industry, which were mainly driven by the emission control
technologies and are to a great extent passed through to the consumers. The total
regulatory costs compared to Euro 5/V are €21.1 to €55.6 billion for Euro 6 (2014-
2020) and €5 to €20.4 billion for Euro VI (2013-2020). These regulatory costs result
to 95-99% from direct compliance costs (hardware costs, R&D and related
calibration, facilities and tooling costs) and to 1-5% from costs during
implementation phase (testing and witnessing costs, type-approval fees) and
administrative costs.
The introduction of more demanding on-road RDE and PEMS testing procedures
has led to an increase of costs during implementation phase, namely testing and
witnessing costs increased by €150-€302 thousand per model family for Euro 6d(-
temp) and by €95.7-€232 thousand per engine family for Euro VI. The related
reporting procedures have increased the administrative costs by €16-€52 thousand
per type-approval for Euro 6d (-temp) and by €17.5-€27.5 thousand per type-
approval for Euro VI.
These regulatory costs are considered affordable to industry, approval authorities
and consumers, with the exception of vehicle price increases for small diesel cars
and vans. It is safe to assume that vehicle manufacturers pass through their
regulatory costs to consumers to a great extent and that any cost implication for
industry will only be for a short period until extra costs are recovered through
increased prices. Also suppliers pass through their hardware costs largely – if not
fully – to their clients, the vehicle manufacturers, and most type-approval authorities
pass through their costs to vehicle manufacturers by type-approval fees. The average
vehicle price increase due to Euro 6/VI is less than 2% for cars and vans, in the
range of 4.2-5% for lorries and of 2.1-3% for buses. However, for the most recent
step in Euro 6, the share of the cost for small segment cars and vans is found to be
significantly higher in the case of diesel vehicles – 4.3% for the small segment
vehicles, compared to 2.7% for the large segment vehicles.
No simplification was realised in the Euro 6/VI emission standards. Instead, the
emission tests introduced over the steps of Euro 6/VI increased the complexity
significantly resulting in a text of more than 1 300 pages with multiple references to
other pieces of legislation, different application dates of Euro 6/VI steps and the
above-mentioned increased costs during implementation phase. For stakeholders
from civil society this complexity is seen as, at least partly, justified in view of the
need to ensure that vehicles are clean on the basis of more demanding testing and
in-service conformity requirements.
Regulatory costs for automotive industry
In order to analyse the regulatory costs of Euro 6/VI emission standards borne by
automotive industry, different cost categories were identified in accordance with the
42
Better Regulation guidelines160
(see Table 39).
Table 39 – Description of cost categories, based on CLOVE, 2022161
Regulatory costs for automotive industry
Direct compliance costs
Substantive
compliance
costs
Equipment costs
 Hardware costs Recurrent costs arising from the need to install engine and
emission control technologies on vehicles to meet the emission
limits. As these needs will continue as long as Euro 6/VI is into
force, the hardware cost will carry on after 2020. However, they
are expected to decrease gradually following a strong learning
effect.
 R&D and related calibration
costs including facilities and
tooling costs
1) One-off costs related to the development of new emission
control systems or the necessary upgrades for existing systems
intended to ensure compliance with the new requirements,
including for new facilities, tools and logistics investments
required to support R&D and calibration directly linked to Euro
6/VI.
2) Recurrent costs in terms of calibration costs and related testing
for each new vehicle model or new engine to ensure that it meets
the Euro 6/VI requirements. These costs will continue after 2020,
but at a gradually decreasing level on the basis of a learning effect.
Costs during implementation phase
 Testing and witnessing costs Recurrent costs for testing in the context of type-approval, in-
service conformity and conformity of production performed or
witnessed by type-approval authorities in the facilities of the
manufacturers.
 Type-approval fees Recurrent costs including the fees for granting type-approval paid
to type-approval authorities, excluding the cost of witnessing
above.
Administ
rative
burden
Administrative costs
Recurrent costs including costs for reporting and to fulfil other information provision obligations as part of
the process for granting type-approval.
The costs for automotive industry were collected through questionnaires and interviews
in the first targeted stakeholder consultation on the evaluation and CLOVE expert
estimates (for more information on data collection, see method chapter 4) and have been
analysed in a bottom-up approach. That way, the cost per unit (e.g. per vehicle or engine)
were first verified for each cost category.162
These costs were then scaled up to estimate
the cost for the whole stakeholder group using relevant data including new vehicle
registrations per year, number of manufacturers affected, number of engine/model
families and number of emission type-approvals.163
In this context, the evaluation on the efficiency was faced with certain limitations (see
Chapter 4). In particular, the limited provision of cost data during the targeted
consultation – only 3 manufacturers and 3 type-approval authorities provided data – has
been an implication. However, major efforts have been made to tackle this problem
through extending data sources and estimating costs through a scaled-up desk research
using input provided by CLOVE experts. These cost estimates were then sense checked
160
European Commission, 2020. Better Regulation Toolbox, Tool #58. Typology of costs and benefits.
161
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.3 Analysis of
regulatory costs for industry
162
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.1 Introduction
163
See footnote 161
43
using data at the sector level (e.g. total turnover, total R&D expenditure) to ensure that
the estimates were plausible and to assess to which extent the regulatory cost are
reasonable for the respective stakeholders. Next to that, a conservative approach was
adopted using broad cost ranges allowing for a higher margin of error. Lastly, the main
assumptions on the unit costs per cost category were presented to the stakeholders
participating in the AGVES meeting of 26 November 2020, including more than 100
industry participants. Three industry stakeholders, one manufacturer, one supplier and
one association, reacted after the meeting and provided further input that has been
reflected in the analysis. Hence, robust conclusion should be achieved for the efficiency
section. 164
The analysis focused on identifying and quantifying the costs generated through the new
requirements of Euro 6/VI emission standards. Hence, the evaluation considered the
incremental change in regulatory costs related to Euro 6/VI in comparison to those
related to Euro 5/V. Additionally, for cars and vans the change in regulatory costs
moving from the first steps of Euro 6 to the later steps including RDE testing, i.e. Euro
6d(-temp), is considered. For Euro 6 (cars and vans), the variation in the costs per vehicle
type is accounted for by differentiating the costs for petrol vehicles and diesel vehicles.165
To account for the variation incurred depending on the vehicle type, size and
manufacturer (higher/lower end), different cost ranges (low/moderate/high) were
considered.166
1) Costs for vehicle manufacturers
Table 40 presents estimates of costs borne by vehicle manufacturers with the introduction
of Euro 6/VI emission standards, as net increases in the different costs for manufacturers
in total and per unit (vehicle or model/engine family).
Table 40 – Estimates of costs borne by vehicle manufacturers with the introduction of
Euro 6/VI emission standards, compared to Euro 5/V167
Petrol cars and vans Diesel cars and vans Lorries
and buses
Euro
6b-c
Introduction RDE
testing
Euro 6b-c
Introduction RDE testing
Euro VI
Euro
6d-temp
Euro 6d Euro 6d-
temp
Euro 6d
1) Equipment costs
 Hardware costs
Cost per vehicle (€) 0 84-103 228-465168
341-937 630-1 536 751-1 703 1 798-4 200
Total cost (€ billion ) 0 1.9-3.2 15.3-40 4.1-9.5
 R&D and related calibration costs including facilities and tooling costs
Cost per vehicle (€) 36-108 43-156 1 900-3 800
Total cost (€ billion) 1.3-4 1.8-6.7 5.35-10.7
164
See footnote 162
165
This is not necessary for Euro VI (lorries and buses), consisting mainly of diesel vehicles.
166
See footnote 161
167
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.3.1 Costs for
vehicle manufacturers
168
Following the presentation in the AGVES meeting of 26 November 2020, one automotive association
suggested that hardware costs were higher than this figure. However, no specific evidence or other figures
were provided to support this.
44
2) Costs during implementation phases
 Testing costs
Cost per model / engine family
(€ thousand)
0-34 138-286 0-34 138-286 93-227
Total cost (€ million) 0-118 360-747 0-118 360-747 51-126
 Witnessing costs
Cost per model / engine family
(€ thousand)
3-4 12-16 3-4 12-16 2.7-5
Total cost (€ million) 10-14 31-42 10-14 31-42 1.5-2.8
 Type approval fees
Cost per type-approval 0 0 0
Total cost (€ million) 6-10 6-10 0
3) Administrative costs
Cost per type-approval (€
thousand)
4-12 16-52 4-12 16-52 17.5-27.5
Total cost (€ million) 40-120 207-674 40-120 207-674 26-41
Total costs
Total cost until 2020 (€ billion) 21.1-55.6 9.5-20.4
Total cost until 2050 (NPV in €
billion - 2010 values)
80.6-186.6 16-35
Equipment costs - Hardware costs
To comply with the Euro 6/VI requirements, manufacturers had to introduce and
integrate new emission control technologies. To estimate the hardware costs that were
realised moving from Euro 5/V to Euro 6/VI, typical technology packages used to meet
the new requirements were considered.169
Table 40 shows that for Euro 6 diesel cars and
vans, the hardware costs were significant at the pre-RDE steps. This was mainly driven
by the introduction of the selective catalytic reduction (SCR) emission control
technology. With the introduction of RDE testing, hardware was also required for a share
of petrol vehicles, including the use of gasoline particulate filter (GPF) which introduced
with €69 moderate costs per vehicle. Thus, the hardware costs for cars and vans mostly
increased as a result of the introduction of RDE testing.170
Next to the hardware cost per vehicle, Table 40 also presents the net increase in total
hardware cost. In comparison with the other cost categories presented in the table, it
becomes clear that for cars and vans the rise in hardware costs is the most extensive. For
cost per vehicle in comparison to Euro 5, the costs of hardware installed in the most
recent Euro 6d vehicles are estimated at €228-€465 for petrol and at €751-€1 703 for
diesel vehicles. These estimates are higher than the estimation of the Euro 6 impact
assessment171
, in which the weighted average cost per diesel vehicle was estimated at
€213 (€280 in 2020 prices). This follows from the fact that analysis in the Euro 6 impact
assessment only focused on the cost of the key technology expected to be needed to
comply with the limits (SCR or LNT) and did hence not cover other aspects such as the
169
The Euro 6 diesel technology package includes lean NOx trap (LNT) in initial steps, selective catalytic
reduction (SCR) with Urea kit, SCR with a soot filter (SCRF), advanced exhaust gas recirculation (EGR)
and on-board diagnostics (OBD) sensors; the Euro 6 petrol technology package includes gasoline
particulate filter (GPF), second three-way catalytic converters (TWC), combustion optimisation and OBD
sensors. The Euro VI technology package includes diesel particulate filters (DPF), zeolite SCR, ammonia
slip catalyst (ASC) and OBD sensors.
170
See footnote 167
171
See footnote 3
45
costs of sensors and other supporting hardware (e.g. Lambda or NOx sensors)172
. In
addition, RDE testing was not yet taken into consideration, meaning that the estimates
from the IA are only comparable with the Euro 6 pre-RDE costs.173
For lorries and buses, however, the hardware cost per vehicle is estimated to be between
€1 798 and €4 200, which is comparable to the estimates of the Euro VI impact
assessment which were in the range of €2 539-€4 009 (€2 817-€4 419 in 2020 prices).174
Equipment costs - R&D, calibration, facilities and tooling costs
Estimating R&D, calibration, facilities and tooling costs was challenging considering the
limited availability of relevant data and the fact that R&D projects for the development
of new vehicles rarely focus on just one legal requirement such as the Euro 6/VI
emission standards. However, uncertainty has been addressed in the estimates by
allowing a wide cost range for which the high cost estimates were based on the input
from a high-end manufacturers and the low cost estimates stem from the literature.175
The
combined cost estimations are presented in Table 40.
For Euro 6, the costs for R&D, calibration, facilities and tooling costs is estimated at
€36-€108 per vehicle for petrol and at €43-€156 per vehicle for diesel. In total, this
makes up for a cost ranging from €3.1 to €10.7 billion for the period 2014-2020.
Calibration costs, which should be considered as recurrent costs since new models
brought to the market will have to be calibrated to ensure compliance, are expected to
represent more than 50% of the total R&D cost estimate for cars and vans.176
For Euro VI, it is assumed that only part of the reported R&D costs by manufacturers
through the targeted consultation are directly linked to Euro VI, since the R&D activity
was also relevant for the US EPA 10 standards177
. Hence, the R&D costs related to Euro
VI are estimated at €1.1 billion for large manufacturers and €0.3 billion for smaller ones.
The total R&D, calibration, facilities and tooling costs are presented in Table 40, together
with the costs per vehicle. The estimates suggest that the total costs in this context are
comparable to the total hardware costs incurred in the period 2013-2020. On a per
vehicle basis, they represent a cost of €1 900 and €3 800 per vehicle sold in this period.
While this high cost per vehicle in comparison to the cost for cars and vans can be
expected given the smaller volume of lorries and buses sold in the internal market, these
estimates based on data from manufacturers178
seem to be on the higher side compared to
results from an ICCT study179
, which suggested this cost to be 8 to 12 times lower.180
Similar to Euro 6, the calibration costs have also increased moving from Euro V to Euro
VI. In particular, expert estimates indicated that calibration costs have increased from
172
While the pollutants monitored by OBD did not change between Euro 5 and Euro 6, the threshold for
the provision of information from on-board diagnostics (OBD) systems did change both with the
introduction of Euro 6 and before the introduction of Euro 6d. Hence, additional sensors were still needed
to effectively control emissions (e.g. multiple Lambda or NOx sensors) for RDE compliance.
173
See footnote 167
174
See footnote 3
175
ICCT, 2012. Estimated Cost of Emission Reduction Technologies for Light-Duty Vehicles.
176
See footnote 167
177
US EPA standards are structured and tested quite differently to EU standards so direct comparisons are
not possible, but in practice a similar level of technology is considered necessary to meet either standard,
even if application and calibration approaches differ.
178
7 large manufacturers representing 90% of the HDV market and 10 small manufacturers representing
the remaining 10% of the market.
179
ICCT, 2016. Costs of emission reduction technologies for heavy-duty diesel vehicles
180
See footnote 167
46
€1.8 million to €3.5 million for a lead engine application.181
Costs during implementation phase – Testing and witnessing costs
The introduction of the Euro 6/VI emission standards has led to some changes to the
testing requirements and procedure for granting type-approval – including type-approval,
ISC and CoP – that were not applicable under Euro 5/VI (see chapter 3). As such, the
sixth generation of Euro standards is associated with net increases in the testing costs, as
well as increases in the time and effort type-approval authorities spend on witnessing
these tests. In this context, increases in testing activity and the number of emission type-
approvals is closely linked to the stepwise introduction Euro 6/VI. Moreover, a
manufacturer indicated that the level of effort in this context and the associated costs for
testing doubled between Euro 5 and Euro 6 pre-RDE, while it increased by a factor 5
between Euro 5 and Euro 6d. The introduction of Euro VI for lorries and buses, on the
other hand, has increased the time and effort needed for testing and witnessing by a
relatively lower extent of 50%.182
On the basis of the information made available by manufacturers and type-approval
authorities during the targeted stakeholder consultation on the evaluation, the cost
estimates for the testing and witnessing costs following the introduction of Euro 6/VI
emission standards are summarised in Table 40.183
Since not every vehicle needs to go
through the implementation procedures explained above, not the costs per vehicle are
relevant in this context, but the cost per model family for cars and vans, and per engine
family for lorries and buses. For Euro 6, the testing costs per model family are estimated
at €0-€34 thousand before the introduction of RDE testing and at €138-€286 thousand
after the introduction. For Euro VI, these costs per engine family are expected to be
between €93 and €227 thousand. As can be seen in the table, the increase in witnessing
costs moving from Euro 5/V to Euro 6/VI are expected to be less important.184
Costs during implementation phase – Type-approval fees
Type-approval authorities participating in the first targeted stakeholder consultation
provided input on the fees they charge on vehicle manufacturers, excluding the costs to
cover witnessing discussed above. Their input suggested that the fees charged by
authorities are generally very small ranging from €0 to €2 000 per type-approval to Euro
6 and ranging from €0 to €460 per type-approval to Euro VI depending on the specific
authority. Table 40 presents the changes in the fees moving from Euro 5/VI to Euro 6/VI.
There is no indication that these fees have systematically increased as a result of the
introduction of Euro 6/VI. However, a small increase has been detected in the total cost
associated with the fees for type-approval due to an increase in the number of emission
type-approvals to the Euro 6 standard.185
The Euro 6 requirements and the changes in
specific aspects of the testing procedures meant that manufacturers had to re-test and
request new type-approvals for existing models, while the introduction of CO2 related
monitoring and reporting obligations based on WLTP have led to an increase in the
number of type-approvals.186
181
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.3.1.2 Regulatory
costs of Euro VI
182
See footnote 167
183
See footnote 167
184
See footnote 167
185
See footnote 167
186
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 3.4 Implementation of
47
Administrative costs
Detailed input on administrative costs in the form of costs for reporting and to fulfil other
information provision obligations as part of the process for granting type-approval is not
generally available. The administrative costs are estimated at €20 to €64 thousand per
type-approval to Euro 6 and at €17.5 to €27.5 thousand per type-approval to Euro VI (see
Table 40). Given the limited input provided by manufacturers, however, there is
uncertainty which is partly covered in the range of the upper and lower cost estimates in
the calculation. Further to that, the significant increase in administrative costs moving
from Euro 5/V to Euro 6/VI still represent a relatively small share of the total costs.
Total regulatory costs for vehicle manufacturers
The total regulatory costs for manufacturers resulting from Euro 6 and Euro VI are
presented in Table 40. The Euro 6/VI emission standards have resulted in a total
regulatory cost estimated at €31-€76 billion. When looking into how these regulatory
costs will develop after 2020 and considering a social discount rate of 3.8%187
and a
learning effect188
, the total net cost associated with the Euro 6/VI emission standards up
to 2050 are estimated at €97-€222 billion. The weighted average of the total regulatory
cost for the period up to 2020 is estimated at around €357-€929 per diesel vehicle and by
€80-€181 per petrol vehicle for Euro 6 (cars and vans). For Euro VI for lorries and buses,
the weighted average of the total regulatory costs is €3 717-€4 326 per vehicle.189
2) Costs for component suppliers
Next to the cost implications for vehicle manufacturers, the regulatory costs for
component suppliers are also expected to be affected by Euro 6/VI emission standards. In
general terms, these costs may include R&D costs to ensure that components are in
compliance with the new requirements. In the case of aftertreatment technologies, this
would mean development and testing costs to ensure that technologies guarantee that
vehicles will be able to meet the new requirements. In the case of suppliers of engines
requiring type-approval, certain costs during implementation phase will also be
applicable.190
Suppliers participating to the targeted stakeholder consultation on the evaluation reported
varying levels of costs191
, while in general higher costs were identified for the larger
suppliers. Nevertheless, the feedback from three important suppliers to the targeted
consultations shows that these costs for suppliers should be largely – if not fully –
reflected in the increased costs for equipment paid by their client, the vehicle
manufacturers. The increased costs for manufacturers, capturing also the costs for
the legislation – Type-approval activity
187
This rate is taken equal to 4%, as recommended by the Better Regulation Toolbox, Tool#61. The
inflation rate within the EU was also taken into account in the calculations, which was -0.2% in October
2020, resulting to a total discount rate of 3.8%.
188
For hardware and calibration costs a linear reduction of costs over a six-year depreciation period was
assumed leading to a gradual reduction to 50% of the initial costs estimated.
189
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.8 Conclusions
190
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.3.2 Costs to
suppliers
191
Respondents indicated one-off costs ranging from less than 1 million to over 100 million for testing and
product development and typically to less than 0.1 million for the administrative costs. In terms of
recurrent costs, there were typically around 10% of the one-off costs.
48
suppliers, were already presented in Table 40.192
Regulatory costs for type-approval authorities
Apart from automotive industry, type-approval authorities are targeted by the Euro 6/VI
emission standards as they are in charge of granting type-approval. Therefore, these
authorities are expected to have been confronted with the following costs during
implementation phase193
:
- One-off costs for investment in new facilities and equipment as well as
preparatory action taken in the form of training, development of guidance
documents or other system updates.
- Recurrent costs associated with the increased need for human resources following
the introduction of Euro 6/VI emissions standards, including the time needed for
witnessing of type-approval, ISC and CoP tests and for reviewing documentation
provided by vehicle manufacturers.
Input from type-approval authorities to the targeted stakeholder consultation on the
evaluation showed that these authorities were faced with an increase194
in costs during
implementation phase following the introduction of Euro 6/VI emission standards.195
Similar to the case for component suppliers, the costs for authorities are expected to be
largely covered by vehicle manufacturers in the form of costs for witnessing the type-
approval, presented in Table 40.
Indirect regulatory costs for consumers, including citizens and business users of
vehicles
In evaluation question 3, the transmitted regulatory costs and its potential effect on the
vehicle prices for consumers, either being professional (business users such as transport
companies) or private, were already discussed. While it was difficult to identify evidence
showing that the observed increase in prices of cars is directly linked to the Euro 6
emission standards, it is generally expected that manufacturers would have passed on the
costs to consumers in the long term considering the monopolistic competition
characteristics of the automotive market.196
Assuming that manufacturers indeed pass on
the full cost to consumers through increased prices, the relative impacts of this can be
examined by comparing the vehicle prices with the net increase in costs per vehicle to
assess what share of a vehicle price they actually represent. In order to do this properly,
the lower cost estimates of Table 40 were compared to the weighted average of prices of
vehicles in the smaller size segments, while the high cost estimates were compared with
prices of vehicles in the higher segments.
As can be seen in Table 41, the estimated total costs per vehicle (2014-2020) in most
192
See footnote 190
193
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.4 Costs to type
approval authorities
194
For the recurrent cost, a large type-approval authority reported costs of up to €1 million, while another
large authority that a total of 20 new staff member has to be hired. The latter also reported an increase of
around 30% of the workforce responsible for granting type approvals. Also the smaller type-approval
authorities reported an increase in the number of staff ranging between 2 and 4 new staff members.
195
CLOVE, 2022. Euro 6/VI Evaluation Study. Annexes 1-6. ISBN 978-92-76-56522-2, Annex 6 chapter
9.6.8 Costs to Type-Approval authorities
196
Mamakos, A. et al., 2013. Cost effectiveness of particulate filter installation on Direct Injection
Gasoline vehicles
49
cases represent less than 2% of the average price for cars and vans. For the most recent
step in Euro 6, the share of the cost for small segment cars and vans is found to be
significantly higher in the case of diesel vehicles (4.3% for the small segment vehicles,
compared to 2.7% for the large segment vehicles). This is mainly driven by the higher
hardware costs linked to the technologies to ensure compliance with Euro 6d. For lorries,
these costs are in the range of 4.2-5% for the average lorry price and for the typically
more expensive buses, these costs should represent no more than 3% of the total
purchase price.197
Table 41 – Regulatory costs of Euro 6/VI in comparison to average purchase prices per
vehicle segment198
In all, there is no evidence suggesting that the impact of the regulatory costs associated
with Euro 6/VI are not affordable for consumers. When stakeholders were asked in the
public consultation to indicate what was the impact of Euro 6/VI on vehicle prices, the
large majority of respondents from all stakeholder groups – industry, Member States,
civil society and citizens – indicated that there has been an increase in the vehicle prices
for all categories (cars, vans, lorries and buses). However, when asked if they agree that
EU legislation makes cars unduly expensive a majority over all groups disagreed or even
strongly disagreed. Hence, the impact on vehicle prices and consumers is not expected to
have been significant or disproportionate.199
Are the costs affordable and justified?
While the affordability for consumers was already described above, also for automotive
industry the costs are generally expected to be affordable. As the regulatory cost will be
passed on to consumers to a great extent, any cost implication will only be for a short
period until manufacturers manage to recover the extra costs through increased prices.
But even in the absence of such a recovery, the total cost estimate for the period 2013-
2020 as a combined result of Euro 6 and Euro VI represents no more than 2% of the total
turnover of the sector (estimated at around €3.5-€4 trillion).200
This is partly confirmed
197
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.5 Impact of costs
on consumers
198
See footnote 197
199
See footnote 197
200
According to Eurostat Structural Business Statistics data (SBS_NA_IND_R2) for the manufacturer of
motor vehicles (NACE 29.1), the total turnover of the sector increased from €600 billion in 2013 to €820
billion in 2018, the last year available. Assuming the same level per year for 2019-2020, the total turnover
of the sector is around €5 trillion (2013 values) that includes revenues from the aftersales market and other
Vehicle segment
Regulatory cost
per vehicle ( in €)
Average vehicle
price (in €)
Share of vehicle
price
Cars and vans Small 265 17 209 1.5%
Medium 377 31 933 1.2%
Large 700 68 082 1%
Lorries Small 4 195 100 000 4.2%
Medium 6 447 130 000 5.0%
Large 8 998 200 000 4.5%
Buses Small 4 195 200 000 2.1%
Medium 6 447 250 000 2.6%
Large 8 998 300 000 3%
50
by the results of the public consultation: the majority of respondents from Member States
and civil society indicated that the costs of complying with the Euro 6 limits and tests are
affordable. Overall, industry seems to be more sceptical on the affordability. When
splitting the industry group further, the majority of respondents from component
suppliers and LNG fuel industry disagree with the affordability of the Euro 6/VI
standard. The majority of manufacturers does not provide a clear answer as they neither
agree nor disagree with the standards being affordable.201
Nevertheless, the costs related
to the legislation might be a challenge to some manufacturers with small production
volumes who may only be able to recuperate these costs over a longer period.202
The rise in costs is seen as a result of the multiple stages in the introduction of RDE
testing and the increasing complexity in the legislation. One manufacturer, for example
indicated that the changes to the testing provisions often come at short notice leading
manufacturers to change type-approval projects, leading to duplication of effort and
increases in the type-approval activity since 2017, resulting in higher costs. Thus, it can
be argued that some of these costs were unnecessary and could have been avoided if a
more streamlined approach had been adopted, possibly over a longer period. However,
this should be balanced against the benefits from the introduction of the RDE testing in
decreasing vehicle pollutant emissions.203
Was simplification achieved by Euro 6/VI emission standards?
The description of the implementation of the Euro 6/VI emission standards in chapter 3.2
already gives a strong indication that the legislation is quite complicated. Hence, no
tangible simplification has been achieved moving from Euro 5/V to Euro 6/VI. On the
contrary, the legislative text has built on the previous texts adding new elements and
additional requirements which has resulted in a text of more than 1 300 pages with
multiple references to other pieces of legislation. In addition, the Euro 6/VI emission
standards consist of several pieces of legislation, that are separate for light-duty (cars and
vans) and heavy-duty vehicles (lorries and buses). That way, requirements have been
introduced in various steps (Euro 6b-d(-temp) and Euro VI A-E) with different
application dates depending on the vehicle types. Next to that, the complexity has
increased as result of the new and more demanding testing requirements. In addition to
the numerous lab-based test, on-road testing of vehicles has been introduced in Euro 6 in
four different pieces of legislation via different enforcement mechanisms (type-approval,
CoP, ISC).204
These observations indicating that Euro 6/VI emission standards have not led to
simplification are widely supported by stakeholders from all groups. This is illustrated by
the responses to the public consultation in which 98 out 128 stakeholders considered
Euro 6/VI as very complex or complex. 205
A majority across all stakeholder groups
services. Data on turnover from the main activity of the sector is only available for some Member States.
Assuming a similar share of turnover from main activity to the total reported for all Member States, it leads
to a total turnover of €3.5-€ 4 trillion for the period 2013-2020. This does not include the turnover of
suppliers of components and equipment.
201
See footnote 86
202
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.6 Are the costs
affordable for industry?
203
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.7 Are there any of
the costs that are unjustified/unnecessary?
204
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.3 EQ10 Has Euro
6/VI achieved a simplification of vehicle emission standards in relation to EURO 5/V?
205
See footnote 105
51
considered the emission test procedures to be complex. Also, the number of emission
tests were perceived to be complex or even very complex across a majority of
stakeholders. However, civil society representatives consider the more demanding
emission tests and in-service conformity requirements as justified in view of the need to
ensure that vehicles are clean. Lastly, 101 out of 128 stakeholders from all groups
indicated that the different application dates for the stepwise Euro 6/VI approach, as
described above, are complex to very complex. 206
This identified complexity of Euro 6/VI emission standards is also seen in Table 40 as
contributing to the costs during implementation phase for type-approval testing and
witnessing, which increased between €153 000 and €368 000 per model family moving
from Euro 5 to Euro 6 for cars and vans and between €95 700 and €232 000 per engine
family moving from Euro V to Euro VI for lorries and buses. 88 out of 117 respondents
to the public consultation from all stakeholder groups agreed or strongly agreed that
complexity leads to significant costs207
.
Evaluation question 5: To what extent has Euro 6/VI been cost-effective? Are the
costs proportionate to the benefits attained?
Overall conclusions: The Euro 6/VI emission standards are in general cost-
efficient and have generated net economic benefits to society. The positive net
benefits are estimated at €192-€298 billion for Euro 6 cars and vans. In particular
diesel cars and vans have a high benefit associated with the emission savings for
these vehicles. On the other hand, petrol cars and vans seems to have negative net
benefits due to the limited NOx emission savings and compliance costs for gasoline
particulate filters. For Euro VI lorries and buses, very positive net benefits of
estimated €490-€509 billion have been realised.
The regulatory costs of Euro 6/VI emission standards have been considered justified
and proportionate in the public and targeted stakeholder consultation by a large
majority across all stakeholder groups – industry, Member States and civil society –
to ensure the necessary decrease in air pollutant emissions emerging from road
transport and hence prevent negative effects on human health and environment.
Industry stakeholders however were somewhat sceptical, indicating that consumers
do not really appreciate the improvements in aftertreatment technologies in vehicles,
in contrast to the situation for fuel efficiency. On the other hand, the majority of
stakeholders across all groups, including citizens, indicated that Euro 6/VI, and in
particular the introduction of RDE testing in the wake of Dieselgate, at least
contributed somewhat towards ensuring consumer trust in the type-approval system
and automotive products.
The evaluation question 4 analysed the regulatory costs related to the introduction of
Euro 6/VI emission standards and the related benefits of the intervention in terms of
emission savings and reduced environmental health impacts were discussed under
effectiveness (see chapter 5.1). In the following both will be compared to determine
whether the intervention has achieved its operational objective of setting the next stage of
emission limit values in a cost-effective way with specific focus on NOx, PM and HC208
.
206
See footnote 102
207
See footnote 126
208
See footnote 3
52
Hence, it will be determined whether the costs are proportionate to the benefits attained.
Since the benefits of the Euro 6/VI emission standards will continue in the future with
the further penetration of Euro 6/VI vehicles in the European vehicle fleet, the analysis of
the cost-effectiveness considers the period from the entry into force of Euro 6/VI in
2013/2014 until 2050, while considering a social discount rate of 3.8%209
. On the basis of
the damage costs for air pollutants210
, the benefits have been monetised for the main
pollutants NOx, PM and NMHC. The proportionality of these benefits to the costs for
these three pollutants have been analysed using two indicators: the net present value211
and benefit-cost ratio212
. In addition, a third indicator - abatement cost per tonne of most
dominant NOx emissions avoided213
- is used to further evaluate the cost-effectiveness of
the realized NOx savings over the discussed period.
Table 42 shows the results of the cost-effectiveness analysis. For Euro 6 and especially
for Euro VI, high net present values are realised when comparing to Euro 5/V emission
standards, meaning that the net present value of the benefits realised through Euro 6/VI
outweigh the net present value of the costs. When looking into Euro 6, this appears to be
driven by the high benefits associated with the emission savings for diesel cars and vans
resulting in benefit-cost ratio of 2.5-5.9. The cost-effectiveness of the final steps of Euro
6, which introduced RDE testing, is found to be lower (2.5-4.7 for diesel vehicles and
1.6-3.1 in total). This is mainly a result of the higher costs associated with the RDE
testing (see Table 40), (part of which are expected to continue in the future) as well with
the significant emissions savings already achieved with the introduction of Euro 6 before
RDE.
Table 42 – Analysis of cost-effectiveness of Euro 6/VI emission standards214
Euro 6 (RDE) to
Euro 5
Euro 6 RDE to
Euro 6 pre-RDE
Euro VI
to Euro V
Total cars and vans Total lorries and buses
Net Benefits (€ billion) 192-298 54-96 490-509
Benefit-cost ratio 2-4.7 1.6-3.1 15-33
Abatement costs for NOx [€/ton] 1.8-4.1 2.5-4.9 0.2-0.5
Only diesel cars and vans
Net Benefits (€ billion) 219-303.5 80-105.8
Benefit-cost ratio 2.5-5.9 2.5-4.7
209
See footnote 187
210
European Commission, 2019. Handbook on the external costs of transport
211
The net benefits are the monetary difference between the present value of the benefits and costs,
considering base year 2013 for lorries and buses and 2014 for cars and vans. Thus, a positive value for this
indicator (i.e. > 0) means that the net present value of the monetary benefits are greater than those of the
costs. The net benefits consider the effectiveness of the initiative in absolute terms (thus the larger the
difference between benefits and costs, the better).
212
The benefit-cost ratio is the ratio of the present value of the total monetised benefits in comparison to
the present value of the total regulatory costs for the automotive industry. If the ratio is greater than 1, the
net present value of the benefits outweighs the net present value of the costs. The ratio considers the
effectiveness of the initiative independent from the scale (thus larger benefits can have the same ratio as
smaller benefits when the costs are equally larger).
213
Abatement cost per tonne of NOx emissions avoided is found by dividing the regulatory costs over the
emission savings of NOx, which was found to be the most dominant pollutant in terms of the monetised
benefits. It has not been possible to disentangle the costs of focusing only on those covering NOx
emissions. The abatement cost is therefore underestimated to a certain extent.
214
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.2.2 Analysis of cost-
effectiveness
53
Euro 6 (RDE) to
Euro 5
Euro 6 RDE to
Euro 6 pre-RDE
Euro VI
to Euro V
Abatement costs for NOx [€/ton] 1.4-3.2 1.6-3.1
Only petrol cars and vans*
Net Benefits (€ billion) -26.7 / -5.3 -27 / -9.8
Benefit-cost ratio 0.3-0.7 0.2-0.4
Abatement costs for NOx [€/ton] / /
*Not including benefits related to savings of PN emissions
While the cost-effectiveness indicators showed that the benefits achieved by the Euro
6/VI emission standards generally outweigh the costs for stakeholders, the analysis
shows that this is not the case for petrol cars and vans. This is a reflection of the fact that
the analysis does not capture the benefits of reduced PN emissions due to the absence of
relevant data on emission factors, while it does take into account the moderate hardware
costs for the related gasoline particulate filter (GPF) technologies (see above). As such,
the monetised benefits for petrol cars and vans have been underestimated. Next to that,
these petrol vehicles only realise limited NOx emission savings under Euro 6 since the
emission limits for petrol cars and vans remained unchanged in Euro 6. As a
consequence, the negative net benefits are expected to underestimate the benefits for
these vehicles. On this matter, other literature sources performed ex-ante analysis on the
cost-effectiveness of the GPF technologies215
from which we can reasonably expect that
the total cost-effectiveness is higher than what is presented in Table 42, even though it
might still be the case that the net benefits are negative, which means that the costs might
not be proportionate to the benefits achieved for petrol cars and vans.216
The overall conclusion of a positive cost-effectiveness of Euro 6/VI emission standards is
also supported by the targeted and public consultation. When asked in the targeted
stakeholder consultation to evaluate the costs of Euro 6/VI emission standards in
proportion to the benefits for human health and environment, a large majority across all
stakeholder groups – industry, Member States and civil society – considered that the
costs were quite or very low. Environmental NGOs, national authorities, a consumer
organisation and a research institution argued that the benefits for human health and
environment from the reduction of emissions are so great, that the regulatory costs, even
if relatively high, are very well justified. In addition, two environmental NGOs stressed
that considering the large external costs of air pollution from road transport in the EU-28
– calculated at around €49 billion for cars and vans and at €18 billion for lorries and
buses in 2019217
– reported in the Handbook on the external costs of transport218
, any
emission savings can lead to significant reductions in the total external costs of air
pollution to society.219
Stakeholders were less positive when asked to compare the regulatory cost of Euro 6/VI
215
Mamakos, A. et al., 2013. Cost effectiveness of particulate filter installation on Direct Injection
Gasoline vehicles. Considering hardware and indirect costs and not accounting for the impact of non-
regulated sub-23 nm particles, the ex-ante study found that overall societal effect associated with the
installation of a GPF would be anywhere between a net benefit of €78 per vehicle and a net cost of €217
per vehicle.
216
See footnote 214
217
In the EU-28 alone the external costs of air pollution from passenger cars has been calculated at €33.36
billion and for light commercial vehicles (vans) at €15.49 billion in 2019. For heavy goods vehicles
(lorries), these external costs have been calculated at €13.93 billion, while for buses and coaches these
were calculated at €4.02 billion in 2019.
218
See footnote 210
219
See footnote 214
54
with the benefits for their own organisation. For cars and vans, 6 industry stakeholders
(including 4 manufacturers and 2 component suppliers), 3 Member States and 1 research
institute out of the 27 respondents perceived the cost-effectiveness of Euro 6 for their
organisation as negative. For lorries and buses, this were 4 respondents from industry
(including 2 manufacturers and 2 component suppliers) and 2 from Member States out of
the 19 stakeholders consulted.220
When comparing the regulatory costs of Euro 6/VI with the benefits realised for
consumers, in the context of cars and vans 3 manufacturers and 2 suppliers were
somewhat sceptical, while for lorries and buses this was 1 manufacturer. One component
supplier and a research institution indicated that consumers do not really appreciate a
direct benefit from pollutant emissions reduction and the respective improvements in
aftertreatment technologies in vehicles, in contrast to the situation for fuel efficiency.
That way, they indicate that consumers would not consider higher prices of vehicles
related to Euro 6/VI as justified. In contrast, several stakeholders over all groups
considered that the regulatory costs are justified by the benefits. One environmental
NGO pointed out that the introduction of RDE testing has also been significant in
addressing the important issue of consumer trust, which was severely affected in the
wake of Dieselgate. This result was also found in the public consultation in which the
majority of stakeholders across all groups – industry, Member States, civil society and
citizens – indicated that Euro 6/VI at least contributed somewhat towards ensuring
consumer trust in the type-approval system.221
In addition, local initiatives in the form of
restrictions for access to urban areas, such as Low Emission Zones, are also expected to
change consumer perception of the importance of a vehicle’s emissions performance.222
5.3. Relevance
Evaluation question 6: To what extent do the Euro 6/VI objectives of ensuring that
vehicles on EU road are clean correspond to the current needs? Is there a
demand/potential for cleaner vehicles on EU roads over their whole lifetime?
Overall conclusions: The Euro 6/VI objectives to improve air quality by reducing
pollutants from road transport and to set harmonised rules on the construction of
motor vehicles are still highly relevant. Progress has already been made to a certain
level but air quality issues associated to road transport remain a persistent issue in
European urban areas. Also new pollutant emission species being harmful for health
or environment have arised since the adoption of Euro 6/VI more than a decade ago
with the introduction of new engines, exhaust aftertreatment technologies, fuels and
additives. Harmonised rules on the construction of motor vehicles are necessary to
avoid the fragmentation of the Internal Market for vehicles by individual emission
standards and to allow industry and public authorities to take advantage from
economies of scale. There is also a demand for cleaner vehicles on EU roads over
their whole lifetime as the average age and lifetime mileage of vehicles on EU roads
have changed since the adoption of Euro 6/VI. The Euro 6/VI durability
requirements appear to be significantly lower than the average fleet age and lifetime
mileage for all vehicle types.
Recent policy developments, that means the European Green Deal and the New
220
See footnote 214
221
See footnote 145
222
See footnote 214
55
Industrial Strategy for Europe, support the Euro 6/VI objectives and the relevance to
improve air quality by reducing emissions from road transport. These policy
developments emphasise the need to make transport significantly less polluting,
especially in cities, in order to accelerate the shift to sustainable and smart mobility
and thus support the competitiveness of the EU automotive industry on the global
market. The European Green Deal roadmap therefore includes a proposal for more
stringent air pollutant emissions standards for combustion-engine vehicles by 2021.
At the same time, the European Green Deal underlines the EU’s objective of
achieving climate neutrality by 2050 and the roadmap includes a proposal for
strengthened CO2 standards for cars and vans by June 2021. The interplay of both
emission initiatives will provide a pathway to zero-emission vehicles, while at the
same time it will ensure that the remaining internal combustion engines are as clean
as they can be.
Today’s relevance of the objectives of Euro 6/VI emission standards
1) Improving air quality by reducing pollutants emitted by the road transport sector
Creating a toxic-free environment is of great importance to protect Europe’s citizens and
ecosystems. To realise this, it is vital to clean and remedy pollution, such as air pollution,
but also to take action to prevent pollution from being generated in the first place.
According to the World Health Organization (WHO), air pollution still represents the
biggest environmental risk to health as it is still responsible for many premature
deaths.223
In 2018, PM concentrations were responsible for around 379 000 premature
deaths in EU-28, NO2 for 54 000 and O3 for 19 400 deaths.224225
Since most activities
that actively increase air pollutant emissions are situated in urban areas, they also suffer
from higher ambient concentrations and greater exposure to such pollutants. While air
quality in European urban areas has improved over the last decade, in 2017 a significant
proportion of the urban population was still exposed to concentrations above the
threshold defined by the Ambient Air Quality Directive (AAQD)226
. When considering
the more stringent guideline values of the WHO, an even larger proportion of people
were exposed to exceeded levels, while these levels will be even higher with the revised
2021-WHO guidelines. Table 43 presents the significant, but still insufficient progress,
towards diminishing the populations exposed to air pollution. In addition, road transport
is still a major cause of this pollution, particularly when looking into NO2 and NOx
emissions. In a JRC study focussing on European urban areas, the contribution of road
transport to overall NOx emissions was found to be 47% on average.227
While a
minimum contribution of 20% percent was found in Lisbon, maximum values of more
than 70% were found in Athens and Milan.
223
WHO, 2016. Ambient air pollution: A global assessment of exposure and burden of disease
224
Emissions of NMVOCs, NOx, CO, which are regulated by Euro 6/VI emission standards, contribute to
the formation of tropospheric ozone (O3).
225
EEA, 2020. Air quality in Europe 2020
226
Directive 2008/50/EC on ambient air quality and cleaner air for Europe
227
JRC, 2019. Urban NO2 Atlas
56
Table 43 – Percentages of the EU urban population exposed to air pollution levels
exceeding the AAQD thresholds or the previous WHO guideline values in 2008 and
2018, based on data from EEA, 2020228
Exceedance levels in urban population
based on Ambient Air Quality
Directive (%)
Exceedance levels in urban population
based on WHO guidelines (%)
Pollutants 2008 2018 2008 2018
NO2 12.3 3.6 12.3 3.6
PM10 23.9 15.0 74.9 48.3
PM2.5 12.5 3.6 86.8 73.6
O3 15.3 34.1 98.5 98.6
On the other hand, pollutant emissions from road transport have decreased considerably
for key pollutants over the last two decades229
, even though gradual increases in
transported passenger and freight volumes were realized during this period. 230
The
majority of stakeholders from all groups – including industry, Member States and civil
society – consulted through the targeted consultation considers emission standards to be a
relevant mechanism to encourage a reduction in vehicle emissions that offsets potential
increases in the demand for transport.231
Amongst the stakeholders, there is a wide consensus when it comes to the general
relevance of air pollution issues and the respective role of road transport. 56 of 61
stakeholders from all groups confirm that there are ongoing issues, while 57 agree that
there is an ongoing need to limit vehicle emissions from vehicles. When looking into the
relevance of Euro 6/VI emission standards to reduce vehicle emissions, a majority across
all stakeholder groups strongly agrees that there is a further need to set and enforce Euro
emission standards. These stakeholders argue that air pollution is an externality that is not
captured in the economic incentives of consumers and producers. If not for the Euro 6/VI
emission standards, there would be no incentives for the development and deployment of
pollution-control devices. Nevertheless, 5 stakeholders – mostly from industry – disagree
that there is a further need for Euro emission standards to reduce vehicle emissions.
These stakeholders point to other needs in this area, including the need to promote fleet
renewal by Euro 6/VI vehicles and the need to ensure the interplay between pollutant and
CO2 emission standards.232
2) Setting harmonised rules on the construction of motor vehicles
As the previous Euro emission standards, Euro 6/VI sets and enforces emission standards
in a harmonised way across the EU. This approach was considered necessary to prevent
the emergence of different product standards across Member States as they would
negatively affect the Internal Market. Through the creation of barriers to intra-EU trade,
individual national emission standards are expected to result in the fragmentation of the
Internal Market for vehicles. Up until now, no changes have occurred to the operation of
either the EU internal market or the automotive sector that would suggest that a
228
EEA, 2020. Exceedance of air quality standards in Europe
229
The decrease in pollutant emissions emerging from road transport, however, slowed down since 2014.
230
EEA, 2020. Air pollutant emissions data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2018
231
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.3.1.2.1 Need to take
action in terms of reducing pollutants emitted by the road transport sector in order to improve air quality
232
See footnote 231
57
harmonised approach in setting and enforcing vehicle standards is no longer relevant.233
Stakeholders of all groups that participated in the targeted consultation widely confirm
the relevancy of tackling vehicle emissions in a harmonised manner. The majority
indicated that both the effectiveness and strictness of standards would be lower if they
were not developed at the EU level. According to three environmental NGOs, rules on
emissions would be less strict if set by each Member State individually, as they would be
incentivised to decrease the cost of compliance for their home industry and hence drive a
race to the bottom. In addition, stakeholders confirm the need for harmonised rules to
allow industry and public authorities to take advantage from economies of scale. One
supplier emphasised that a harmonised approach allows for efficiency of development
and certainty for product planning, while individual rules by Member States would have
led to a patchwork of initiatives requiring industry to manage their emission technologies
and fleets accordingly.234
Developments affecting the relevance of Euro 6/VI emission standards
Considering the recent policy developments at EU level, the relevance of the Euro 6/VI
emission standards has not been compromised. On the contrary, the European Green
Deal235
presented in December 2019 is a new growth strategy that will foster the
transition to a climate-neutral, resource-efficient and competitive economy and the move
towards zero-pollution in Europe. It includes key elements on a zero pollution ambition
for a toxic-free environment and on accelerating the shift to sustainable and smart
mobility. To protect Europe’s citizens and ecosystems, more action is required to prevent
pollution from being generated as well as measures to clean and remedy it. Transport
should become drastically less polluting, especially in cities. The European Green Deal
roadmap therefore includes a proposal for more stringent air pollutant emissions
standards for combustion-engine vehicles by 2021. These policy developments underline
that it is still relevant to improve air quality by reducing emissions from road transport as
they remain an issue for the EU. The New Industrial Strategy for Europe236
presented in
March 2020 lays the foundations for an industrial policy that will help Europe’s industry
to make this ambition a reality and further emphasises the relevance of setting and
enforcing the environmental rules in a harmonised manner across the EU. This follows
from the need for EU industry to become more competitive as it becomes greener.
The policy developments at local level also stress the relevance of the Euro emission
standards. This is shown by the adoption of Low Emission Zones (LEZs) in more than
250 European cities for which a large proportion use the Euro emission standards as a
basic criterion for granting access or determining the charge to be applied. Some cities
(e.g. Amsterdam, Brussels, London, and Paris) go even further with their zero-pollution
ambitions and have already announced different forms of Zero Emission Zones (ZEZs).
For example, there are ideas to tighten the restriction rules in certain high-traffic zones
that will result in a ban of diesel and petrol vehicles through a combination of access
restrictions and charging for non-zero emission capable vehicles. Both applications by
local authorities confirm the usefulness of Euro emission standards for kind of
“labelling” purposes in access regulations. Additionally, the ambition for ZEZs in certain
cities suggests that there is actually a need to update the Euro emission standards in line
233
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.3.1.2.2 Need to set
harmonised rules on the construction of motor vehicles
234
See footnote 233
235
See footnote 5
236
COM(2020) 102 final, A New Industrial Strategy for Europe
58
with a zero-pollution target.237
Next to these developments, the EU’s climate ambitions have been progressing over the
last years leading to the recent 2030 Climate target plan238
presented in September 2020,
which put forward an increase of the climate target for 2030, to reduce greenhouse gas
emissions by at least 55% by 2030. For road transport, CO2 vehicle standards have
proven to be an effective policy tool. By June 2021, the Commission will therefore
revisit and strengthen the CO2 standards for cars and vans for 2030.
This climate policy development goes hand in hand with the most relevant technological
and market development that potentially affects the relevance of the Euro emission
standards: the increasing uptake of electric and other alternative fuelled vehicles239
that
contribute to the decarbonisation of transport. Some of these vehicles (i.e. electric and
hydrogen fuelled vehicles) do not generate CO2 and tailpipe pollutant emissions, which
makes them very important for reaching zero-emission targets. Hence, the uptake of such
vehicles has been actively encouraged through a number of policy initiatives, including
the Alternative Fuels Infrastructure Directive240
, the Clean Vehicles Directive241
and CO2
emission standards for new road vehicles242
. Since the entry into force of Euro 6/VI
emission standards, there has been a clear rise in the share of electric and hybrid cars and
vans sold in the EU. This increase is illustrated in Table 44 and according to data
reported by ACEA243
for the third quarter of 2020, these percentage are still on the rise
with almost 1 in 10 cars sold in the EU being battery electric or plug-in hybrid. Also for
buses there is a clear trend towards alternative fuels with electric and CNG buses being
already widely deployed in many EU cities. Electric and hydrogen lorries, compared to
CNG/LPG lorries, are still in the development and testing phase, with commercial
solutions expected in the coming years with the pace depending vehicle operations and
weight.244 245
Table 44 – Share of electric vehicles in new vehicles registered in the EU, based on data
from European Alternative Fuels Observatory, 2020246
Share of battery electric vehicles
(BEV) in total new vehicles sold
(%)
Share of plug-in hybrid electric vehicles
(PHEV) in total new vehicles sold (%)
Vehicle type 2014 2019 2014 2019
237
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.3.1.3.2 Policy
developments at local level
238
COM(2020) 562 final, Stepping up Europe’s 2030 climate ambition. Investing in a climate-neutral
future for the benefit of our people
239
As defined in the Directive 2014/94/EU, ‘alternative fuels’ means fuels or power sources which serve,
at least partly, as a substitute for fossil oil sources in the energy supply to transport and which have the
potential to contribute to its decarbonisation and enhance the environmental performance of the transport
sector. This includes electricity, hydrogen, biofuels, synthetic and paraffinic fuels, natural gas, including
biomethane, in gaseous form (compressed natural gas (CNG)) and liquefied form (liquefied natural gas
(LNG)), and liquefied petroleum gas (LPG).
240
Directive 2014/94/EU on the deployment of alternative fuels infrastructure
241
Directive 2019/1161/EU on the promotion of clean and energy-efficient road transport vehicles
242
Regulation (EU) 2019/631 setting CO2 emission performance standards for new passenger cars and for
new light commercial vehicles; Regulation (EU) 2019/1242 setting CO2 emission performance standards
for new heavy-duty vehicles
243
ACEA, 2020. Press release 05/11/2020, Fuel types of new cars.
244
European Alternative Fuels Observatory, 2020. Vehicles and fleet
245
T&E, 2019. E-trucks: European automakers’ third and final chance to get electrification right
246
See footnote 244
59
Share of battery electric vehicles
(BEV) in total new vehicles sold
(%)
Share of plug-in hybrid electric vehicles
(PHEV) in total new vehicles sold (%)
Cars 0.3% 2.1% 0.3% 1.2%
Vans 0.6% 1.2% 0.0% (0 vehicles) 0.0% (115 vehicles)
Considering this technological and market development, one might raise the question as
to whether the need to introduce cleaner combustion engine vehicles through stricter
emission standards is still relevant when a large proportion of the fleet emits no tailpipe
emissions. When asked about this, stakeholders across all groups widely indicated that
cleaning combustion engine vehicles is relevant to protect the environment and reduce air
pollution (59 out of 64). Only 2 stakeholders from industry believed that the emergence
of electric vehicles made the need for cleaning combustion engine vehicles irrelevant.247
While the market is changing fast, internal combustion engine vehicles are still expected
to remain a significant part of the European fleet for several years, not only for heavier
long-haul lorries. Therefore, the zero-pollution ambition for a toxic-free environment,
introduced by the European Green Deal, can only be achieved with more stringent
emission standards for these vehicles. As long as vehicles equipped with internal
combustion engines - including hybrids (HEV, PHEV), CNG, LNG and any other
alternative fuel - are sold, there will still be a need to make them as clean as possible in
order to avoid adverse effects to human health and environment.
Changing needs for air pollutants and the considered lifetime of vehicles
The required coverage of air pollutants limits has potentially changed since the adoption
of Euro 6/VI emission standards more than a decade ago. The air pollutant limits covered
in the Euro 6/VI emission standards are presented in Table 35 (see section 2). While
many pollutants are covered, some new pollutant emission species are arising with the
introduction of new engines, exhaust aftertreatment technologies, fuels and additives.248
In addition, the majority of respondents from all stakeholder groups, including industry,
Member States, civil society and citizens, to the public consultation agreed that the Euro
6/VI emission limits do not cover all relevant pollutant.249
This majority, however, is less
convincing amongst industry respondent. 23 out of 68 industry respondents disagreed
that not all relevant air pollutants are covered in the legislation. Industry stakeholders
were especially reticent when asked whether there are currently unregulated pollutants
emerging from road transport. While in total, the majority of stakeholders agree with this
statement, 19 out of 52 industry stakeholders disagree and 16 neither agree nor
disagree.250
Table 45 presents an overview of air pollutants that are not covered in the Euro 6/VI
emission standards, while being harmful for health or environment. Some of these
pollutants are aggregated in regulated wider pollutant categories and should be assessed
separately if more precise pollution control is necessary (e.g. NO2, NMOG and HCHO).
Others pollutants, such as NH3, ultrafine particles, brake emissions, evaporative
247
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.3.1.3.3 Technological
and market developments
248
See footnote 53
249
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 2)
250
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 12)
60
emissions and CH4 require new measurement methods. Many of these pollutants also
came up in the public consultation, in which respondents that indicated that the current
list of regulated pollutants is insufficient were asked which air pollutants should be
added. 61 stakeholders answering this question from all stakeholder groups indicated that
adding brake and tyre emissions, ultra-fine particles and NH3 and CH4 for cars and vans
is most relevant. While also N2O was pointed out by the majority of stakeholders
answering this question, NO2, HCHO and NMOG were considered less relevant.251
Table 45 – Non-regulated pollutants related to road transport relevant to health and
environment252
251
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 12.2)
252
See footnote 97
253
See footnote 96
254
See footnote 253
255
Volatile, semi-volatile and solid particles smaller than 23 nm from vehicle exhaust
256
Grigoratos, T. & Martini, G., 2015. Brake wear particle emissions: a review
257
See footnote 253
258
EEA, 2020. Air pollutant emissions data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2018
259
See footnote 53
Air pollutants Why of concern
Nitrogen dioxide
(NO2)
The use of aftertreatment systems could cause an increase in the NO2 to NOx ratio of
vehicle exhaust. However, this effect seems to have been mitigated in the later steps of
Euro 6/VI as the SCR systems preferentially digest NO2, and the remaining NOx tends
to be dominated by NO.
Ammonia (NH3)
Current technologies used for restricting NOx emissions in line with the Euro 6/VI
requirements cause an “ammonia slip”, while high NH3 emissions are also seen in
gasoline vehicles.253
However, the use of ammonia slip catalysts (ASC) has mitigated
this effect in later steps of Euro 6/VI.
Formaldehyde
(HCHO)
Formaldehyde emissions are the result of the incomplete burning of the alcohol content
of the fuel. Therefore, they increase with high ethanol content in the fuel. Gasoline
with higher ethanol content (E10) seems to be gaining momentum.254
Non-methane organic
gases (NMOG)
Oxygenated hydrocarbons, including alcohols and aldehydes, are not adequately
quantified under the NMHC limits and are ozone precursors. Exposure to ozone levels
is still clearly exceeding recommended values (see Table 43).
Ultra-fine particles255
PN limits only take into account solid particles larger than approximately 23 nm, that
means only non-volatile particles; while smaller particles have detrimental health
effects.
Brake emissions
Brake wear has been recognized as the leading source of non-exhaust particles,
contributing up to 21% of all PM10 emissions related to traffic.256
A measurement
procedure is under discussion in the GRPE Particle Measurement Programme.257
Evaporative
emissions
Evaporative VOC emissions from vehicles account for an increasing proportion of total
vehicle emissions.258
This is due to improvements in NMVOC tailpipe emissions but
also to increasing share of petrol engines, ethanol content and high temperature
episodes.259
61
1
NH3 and CH4 are regulated for lorries and buses
Furthermore, the average age and lifetime mileage of vehicles on EU roads might have
changed since the adoption of Euro 6/VI emission standards in a way that the durability
provisions, which set requirements for manufacturers to check the in-service conformity
and the durability of their vehicles, no longer reflect the average lifetime and mileage of
vehicles.
In Table 46, a comparison is made of the Euro 6/VI provisions and the actual situation on
EU roads. Based on this evidence, the time limits and the durability requirements appear
to be significantly lower than the average fleet age and lifetime mileage for all vehicle
types. Especially when considering the recent upward trend in the average vehicle
lifetime for all vehicle types.263
In addition, the increasingly complex pollution-control
devices have introduced more complex engineering approaches in today’s vehicles which
require a more complete demonstration of durability. Also, recent developments in the
field of on-board monitoring introduce a need for more comprehensive monitoring which
is not properly reflected in the Euro 6/VI durability requirements.264
These finding are supported by the results of the public consultation. When asked to
evaluate the statement pointing out that real-world emissions are not adequately limited
over the entire lifetime of vehicles, the majority of respondents from Member States,
civil society and citizens indicated that that they somewhat or completely agreed. Within
the industry, 29 out of 59 respondents were of the opinion that emissions are adequately
monitored.265
In addition, a very strong majority of stakeholders from all groups
indicated that both vehicle ageing and the costs of vehicle maintenance contribute
somewhat or even to a (very) great extent to an increase in air pollutant emissions.266
260
ACEA, 2020. Natural and renewable gas: Joint call to accelerate the deployment of refuelling
infrastructure
261
See footnote 97
262
See footnote 253
263
ACEA, 2020. Average age of the EU motor vehicle fleet, by vehicle type
264
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.3.1.5 Are there any
developments that have introduced a need for action to appropriately monitor the emissions performance of
vehicles over their complete lifetime?
265
See footnote 113
266
See footnote 103
Methane (CH4)1
Methane emissions become especially concerning when methane is used as a fuel
(natural gas, bio-methane, synthetic methane). Less than 1% of the EU vehicle fleet is
powered with CNG. However, it is expected that natural gas vehicles will have a role
in the decarbonisation agenda, especially if blended with bio-methane.260
Nitrous oxide (N2O)
The use of aftertreatment systems could cause an increase in N2O emissions, which is
an important greenhouse gas. For gasoline vehicles, particularly high N2O emissions
have been observed on positive ignition (PI) engines equipped with three-way
catalysts.261
Tyre emissions
Similar to brake emissions, this unconventional source of emissions contributes to the
formation of PM and PN. As emissions arising from these sources have also amplified
through the increasing popularity of large and fast-accelerating vehicles (e.g. SUVs and
electric vehicles), these emissions become more concerning. However, measurement
procedures are still lacking for tyre emissions.262
62
Table 46 – Comparison Euro 6/VI durability requirements and average fleet in 2020,
based on data from ACEA, 2020 and Ricardo Energy & Environment, 2020 (see
columns)
Vehicle type Euro 6/VI
durability
requirement
Average
EU fleet267
Euro 6/VI
durability
requirement
Average EU
fleet268
Cars 5 years 10.8 years 160 000 km 225 000 km
Vans 5 years 10.9 years 160 000 km 200 000 km
Light / medium lorries and buses 5 / 6 years 12.3 years 160 000 /
300 000 km
510 000 / 570 000
km
Heavy lorries and buses 7 years 12.3 years 700 000 km 800 000 km
1
In-service conformity measures: 100 000 km
5.4. Coherence
Evaluation question 7: Are the Euro 6/VI emission standards coherent internally
and with other legislation pieces applying on the same stakeholders and with similar
objectives? Are there any inconsistencies, overlaps or gaps?
Overall conclusions: Stakeholders from all groups - including industry, national
authorities, technical services and civil society - confirm in the targeted consultation
that, overall, vehicle manufacturers are provided with a coherent policy and legal
framework to reduce vehicle emissions. Nevertheless, there are some
inconsistencies as follows.
Regarding internal coherence within Euro 6/VI emission standards, stakeholders
from all groups indicate that there are inconsistencies in the Euro 6 standards for
cars and vans, and to a lesser extent in the Euro VI standards for lorries and buses,
when it comes to different emission limits for diesel and petrol vehicles, deadlines
for compliance and the testing procedures. Moreover, ammonia and methane are
regulated in Euro VI only and there seems to be a lack of clear border between Euro
6 and Euro VI.
Regarding external coherence with other EU legislation, the Air Quality Directive,
CO2 emission standards and Roadworthiness Directive are of relevance.
Stakeholders from all groups indicated the existence of consistency issues between
Euro 6/VI emission standards and the Air Quality Directive. The main problem
seems to be that Euro 6/VI emission limits were based upon the best available
technology to provide cost-effective solutions, while there was too little
consideration of the actual air quality problems they should help to overcome. There
are some differences in the pollutants regulated in both legislations but this is
substantiated by Euro 6/VI covering tailpipe emissions from road transport and Air
Quality Directive covering all air pollution sources.
Mixed views and evidence are found for the relationship between Euro 6/VI and the
CO2 emission standards. While trade-offs could exist, no significant evidence was
found to suggest that Euro 6/VI emission standards resulted in unintended negative
267
ACEA, 2020. Average age of the EU motor vehicle fleet, by vehicle type
268
Ricardo Energy & Environment, 2020. Determining the environmental impacts of conventional and
alternatively fuelled vehicles through LCA
63
consequences for CO2 emission standards. It can, however, be expected that the
separate frameworks lead to some inefficiencies, both in terms of cost and in the
processes to develop and deploy technologies.
The Euro 6/VI emission standards and the Roadworthiness Directives on Periodic
Technical Inspections (PTI) and Roadside Inspections (RSI) do not yet operate in
the complementary way necessary to ensure the best possible level of environmental
and health protection by reducing air pollutant emissions from road transport. To
guarantee protection against degradation, failure or tampering of pollution-control
devices during the lifetime of vehicles, improvements in the requirements for on-
board diagnostics systems in the Euro 6/VI emission standards are important that
can be used for emission testing during PTI and RSI.
Regarding external coherence with other policy developments, it should be noted
that taxation is applied inconsistently across the EU for different types of vehicles,
that the competitive position of the EU industry is still undermined through the
lower stringency of the requirements in Euro 6/VI emission standards compared to
other key markets (i.e. US, China) and that arising local Low- and Zero Emissions
Zones are using Euro 1/I to 6/VI as “labelling” criteria in a different manner and
timing.
Stakeholders from all groups – including industry, national authorities, technical services
and civil society – confirm in the targeted consultation that, overall, vehicle
manufacturers are provided with a coherent policy and legal framework to reduce vehicle
emissions (in total 38 out of 47).269
Most stakeholders that responded negatively to this
statement include industry representatives, suggesting that the automotive industry has
more negative views when it comes to coherence in an emission standards context.
Internal coherence within Euro 6/VI emission standards
The assessment of internal coherence looks into the different components from Euro 6/VI
emission standards and examines how they operate together and to which extent there are
any inconsistencies, overlaps or gaps within and between the four Euro 6/VI
Regulations270
.
A large share of industry stakeholders indicate that there are inconsistencies in the Euro 6
standards for cars and vans when it comes to the emissions limits (16 out of 19), and the
testing procedures (17 out of 20). When it comes to the testing procedures, consistency
issues are for example identified in RDE and PEMS error margins, the use of WLTP for
heavy vans, differences in obligations for ISC and type-approval for specific vehicles and
redundancies of certain low-temperature requirements. Next to these testing issues,
differences in other provisions for cars and vans are indicated as causing internal
inconsistencies for Euro 6. Differing treatment for these types of vehicles in terms of
deadlines for compliance and emission limits could result in environmental costs to
society, as vans are allowed to pollute more than comparable cars. There are also
persistent differences based on fuels. While a PN limit was established in Euro 6, this
limit does not apply to all petrol vehicles, excluding port fuel injection (PFI) petrol
engine vehicles. Additionally, several stakeholders from industry, national authorities
269
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.4.1.1.2 Internal
coherence issues on Euro 6
270
See footnote 1
64
and one research organisation point out that by setting different emission limits for diesel
and petrol vehicles, the Euro 6 emission standards are lacking in fuel- and technology
neutrality. Also in the public consultation, a majority of stakeholder across all groups –
industry, Member States, civil society and citizens – indicated that these differences in
limits result in some complexity.271
While this lack of fuel-and technology neutrality can
be perceived as an internal coherence issue, it should be noted that the differences were
partly justified as they took into account the cost-effectiveness of imposing certain limits
for certain fuels. While these differences between diesel and petrol can have detrimental
effects in achieving lower levels of air pollution, they are rather a limitation of the
emission standard than an inconsistency.272
For the Euro VI emission standards for lorries and buses some stakeholders over all
groups – including industry and some national authorities - indicate consistency issues
with either emission limits (9 out of 20) or with testing procedures (7 out of 18).
Nevertheless, the majority of vehicle manufacturers directly responsible for the
implementation of Euro VI indicate that there are inconsistencies when it comes to
testing (5 out of 6) and the limits (6 out of 7), providing examples such as differences in
cold/warm weighing in WHTC and PEMS conformity factors. Also for Euro VI, some
suppliers and testing organisations describe several limitations that are not necessarily
inconsistencies, including the lack of fuel- and technology neutrality and the use of
unclear terminology.273
The identified inconsistencies in Euro 6/VI emission standards are, however, not
expected to result into costs for the manufacturers and type-approval authorities dealing
with the legislation on a daily basis according to the majority of stakeholders from all
groups. If negative effects on costs are identified, most stakeholders that provided
specific information (including a public authority and a consumer organisation) often
expect that these costs are likely to be borne by consumers or society at large.274
There are potential coherence issues between the Euro 6 emission standards for cars and
vans and the Euro VI emission standards for lorries and buses. As a first issue, a testing
organisation pointed to the fact that while Euro VI includes limits for ammonia (NH3),
Euro 6 does not. This pollutant is included in the Euro VI emission limits as the
pollution-control devices used in diesel lorries and buses can lead to sizeable NH3
emissions in case of malfunctioning or poor calibration. As already raised under
Evaluation Questions 1 and 6, similar technologies for restricting NOx emissions also
cause a similar “ammonia slip” for cars and vans, which leads to high levels of NH3
emissions. Nevertheless, no limit is in place for NH3 in the Euro 6 standards.275
The same
issue applies to methane (CH4) that is regulated under Euro VI but not under Euro 6,
although all type of vehicles use natural gas to an increasing degree, the main source of
CH4 emissions.
A second issue is related to the lack of a clear border between Euro 6 emission standards
for cars and vans and Euro VI emission standards for lorries and buses. The border cross-
271
See footnote 102
272
See footnote 269
273
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.4.1.1.6 Internal
coherence issues identified on Euro VI
274
See footnote 269
275
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.4.1.1.8 Incoherence
between Euro 6 and Euro VI
65
over from Euro 6 to Euro VI depends on the reference mass276
of the vehicle. In
principle, all vehicles with a reference mass exceeding 2 610 kg fall under Euro VI and
its engine test procedure, while vehicles up to this reference mass fall under Euro 6 and
its chassis dynamometer testing. However, there are some exceptions causing an overlap
in the reference mass range between >2 380 kg and ≤2 840 kg resulting in a grey zone
(see Figure 24). As pointed out by experts in the targeted stakeholder consultation on the
evaluation and in AGVES, vehicles which fall in this grey zone may have to be tested
under Euro 6 and Euro VI. Moreover, the use of reference mass prevents the alignment of
vehicle categories M and N for cars, vans, lorries and buses with the EU vehicle type-
approval framework277
and the CO2 emission performance standards for new heavy-duty
vehicles278
, which use technically permissible maximum laden mass279
. This coherence
issue between the Euro 6 and Euro VI emission standards causes obscurity and prevents
optimal environmental protection.280
The results from the public consultation show a gap between the industry respondents
and the other stakeholder groups (Member States, civil society and citizens) on whether
having a separate regulatory framework for cars/vans and lorries/buses brings any
complexity to the Euro standards. While a large majority of stakeholders from Member
States, civil society and citizens (49 out of 66) indicated that such a separate regulatory
framework is at least somewhat complex, a majority of industry stakeholders (39 out 60)
said that it was not complex at all.281
276
As defined in Regulation (EC) No 715/2007 and Regulation (EC) No 595/2009, ‘reference mass’ means
the mass of the vehicle in running order less the uniform mass of the driver of 75 kg and increased by a
uniform mass of 100 kg.
277
As defined in Regulation (EU) 2018/858, ‘Category M consists of motor vehicles designed and
constructed primarily for the carriage of passengers and their luggage, divided into: (i) Category M1: motor
vehicles with not more than eight seating positions in addition to the driver's seating position …; (ii)
Category M2: motor vehicles with more than eight seating positions in addition to the driver's seating
position and having a maximum mass not exceeding 5 tonnes …; and (iii) Category M3: motor vehicles
with more than eight seating positions in addition to the driver's seating position and having a maximum
mass exceeding 5 tonnes …; Category N consists of motor vehicles designed and constructed primarily for
the carriage of goods, divided into: (i) Category N1: motor vehicles with a maximum mass not exceeding
3,5 tonnes; (ii) Category N2: motor vehicles with a maximum mass exceeding 3,5 tonnes but not exceeding
12 tonnes; and (iii) Category N3: motor vehicles with a maximum mass exceeding 12 tonnes. … Maximum
mass means the technically permissible maximum laden mass.’
278
See footnote 33
279
As defined in Regulation (EU) No 1230/2012, ‘technically permissible maximum laden mass’ means
the maximum mass allocated to a vehicle on the basis of its construction features and its design
performances.
280
AGVES, 2020. Ad hoc meeting on Simplification 16 November 2020; HDV CO2 Editing Board, 2019.
HD CO2 Light lorries and light buses, TNO, 2 December 2019
281
See footnote 102
66
Figure 24 – Schematic picture of border between Euro 6 for cars and vans, and Euro VI
for lorries and buses282
External coherence with other EU legislation and other policy developments
1) External coherence with other EU legislation
One Directive that will not be further discussed in this section is the Fuel Quality
Directive283
. While this piece of legislation also indirectly regulates certain air
pollutants284
, these pollutants stemming from fuels, and not from tailpipe emissions, are
not regulated in the Euro 6/VI emission standards. Hence, there is no overlap between the
two legislations.
a. Ambient Air Quality Directive and the National Emission Ceilings Directive
The Ambient Air Quality Directive (AAQD)285
and the National Emission reduction
Commitments Directive (NECD)286
, which were already introduced in Evaluation
Questions 3 and 6, aim to improve air quality across the EU by setting concentration
limits in ambient air concerning specific air pollutants and long-term overall emission
reduction targets concerning the main air pollutants from all relevant sources.
Considering that Euro 6/VI emission standards focus on the reduction of tailpipe and
evaporative pollutant emissions from road transport to improve air quality, the objectives
of the different pieces of legislation and their intended achievements are connected.
Stakeholders from all groups participating in the targeted consultation – industry,
Member States and civil society – indicated the existence of consistency issues between
Euro 6/VI emission standards and the AAQD (27 of the 39). Reflecting on the specific
causes for this identified inconsistency, the following were mentioned. A type-approval
authority and an environmental NGO noted that when the Euro 6/VI emission standards
282
See footnote 53
283
Directive 2009/30/EC amending Directive 98/70/EC as regards the specification of petrol, diesel and
gas-oil and introducing a mechanism to monitor and reduce greenhouse gas emissions and amending
Council Directive 1999/32/EC as regards the specification of fuel used by inland waterway vessels on Fuel
Quality
284
Hydrocarbons such as benzene and polycyclic aromatic hydrocarbon (PAH), oxygenates, sulphur
content, lead content
285
See footnote 226
286
See footnote 147
67
were constructed, there was little consideration of the actual air quality problems they
should help to overcome. On the contrary, the limits were based upon the best available
technology to provide cost-effective solutions taking into account the implications on
competitiveness. However, the environmental NGO underlined that a significant
proportion of the EU’s population is still exposed to air pollution and road transport is
still an important contributor. As such, more stringent Euro emission standards are
potentially needed to ensure coherence with the overall EU objectives on air quality. On
the other hand, four industry stakeholders stressed that for AAQD targets to be achieved
through the Euro standards a very large turnover of the fleet would be needed, which
conflicts with the AAQD goal of turning non-compliance areas into compliance areas “as
soon as possible”.287
With the exception of CO which is regulated in the AAQD and the Euro 6/VI emission
standards, there are differences in the species or in their specification in the different
legislations. The Euro 6/VI emission standards regulate limits for THC, which is nearly –
but not quite – the same as VOCs which is regulated in AAQD, for NOx which is the sum
of the harmful NO2 regulated separately in AAQD and the much less harmful NO, and
for PM rather than the more specific PM10 and PM2.5 regulated in AAQD.288
O3 (ozone),
which is regulated in AAQD, is not a tailpipe emission and hence not regulated in the
Euro emission standards. Instead, O3 precursors (NOx, THC, NMHC and CO), are
regulated in Euro 6/VI. Other air pollutants regulated under the Ambient Air Quality
Directives such as SO2, benzene, lead, arsenic, cadmium, nickel, and benzo(a)pyrene are
considered less relevant for tailpipe emissions of vehicles but important for pollutants
emerging from other sources, as air quality targets cover all air pollution sources.
For road transport, the 2019 fitness check of the Ambient Air Quality Directives289
indicated that challenges in the implementation and enforcement of the vehicles emission
standards have had negative consequences for air quality. However, the changes
introduced in European regulatory framework since 2015 in the wake of Dieselgate –
including RDE testing – led to improvements and tighter EU supervision that should help
the Euro emission standards to further support the AAQD goals.
b. CO2 emission performance standards for cars, vans and heavy-duty vehicles
A narrow majority of industry stakeholders in the targeted consultation indicated to be
aware of inconsistencies between the objectives of Euro 6/VI and CO2 emission
standards (11 out of 21). One consumer organisation implied that the inconsistency is due
to the fact that pollutant and CO2 emissions are treated separately.290
While the Euro 6/VI emission standards aim at reducing air pollutant emissions from
287
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.4.2 EQ 13 - To what
extent is E6/VI consistent with other legislation pieces applying on the same stakeholders and with similar
objectives? Are there any inconsistencies, overlaps or gaps?
288
See footnote 287
289
SEC(2019) 427 final, Commission Staff Working Document, Fitness Check of the Ambient Air Quality
Directives (Directive 2004/107/EC relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic
hydrocarbons in ambient air and Directive 2008/50/EC on ambient air quality and cleaner air for Europe).
The Ambient Air Quality Directives define and establish objectives and standards for ambient air quality
for 13 air pollutants to be attained by all Member States across their territories against timelines laid out in
the Directives. These are: sulphur dioxide (SO2), nitrogen dioxide (NO2) and nitrogen oxides (NOx),
particulate matter (PM10 and PM2.5), ozone (O3), benzene, lead, carbon monoxide, arsenic, cadmium,
nickel, and benzo(a)pyrene.
290
See footnote 287
68
new cars, vans, lorries and buses, the CO2 emission performance standards aim at
reducing CO2 emissions from the same vehicles.291
Since both standards aim at reducing
emissions from different species, there is no direct overlap between their objectives.
Moreover, the Euro 6/VI emission standards set pollutant limits that each vehicle must
comply with due to the local impact of pollutant, whereas the CO2 emission standards set
CO2 targets for the vehicle fleet due to the global impact of CO2.
A limited number stakeholders from industry, national authorities and technical services
that participated in the targeted consultation consider that there are trade-offs between the
CO2 and Euro 6/VI emission standards (7 out of 64).292
The reasoning behind this is that
technologies for meeting Euro 6/VI emission limits could increase fuel consumption and
that the CO2 emission standards could increase pollutant emissions as they would
encourage the use of diesel vehicles which are usually more fuel efficient, but emit
higher NOx emissions than petrol vehicles. However, the CO2 standards also promote the
adoption of zero- and low-emission vehicles, which supports the reduction of pollutant
emissions and shows that synergies can also be realised in this context. Two industry
stakeholders agreed on this matter by indicating that while there are trade-offs in some
emission technologies, in others reductions in both air pollutant and CO2 emission can be
realised (e.g. for BEVs).293
Taking this into account, it is possible that the legal
frameworks provide somewhat inconsistent incentives for consumers. However, every
new vehicle has to comply with both the Euro 6/VI and the CO2 emission standards,
therefore any trade-off between CO2 and air pollutants – especially NOx – is expected to
be minimal.294
It should also be mentioned that consistency with the CO2 emission standards is also
realised through coherent CO2 and pollutant measurement methods under Euro 6/VI
emission standards. For cars and vans, the Euro 6 testing procedure WLTP is used for
determining CO2 and pollutant emissions. For lorries and buses, the CO2 emissions are
determined for the vehicle by the VECTO simulation tool due to the large number of
variants in engine, transmission, axles and bodies.295
The CO2 emissions of the engine
and the other components are input data to VECTO, and CO2 and pollutant emissions of
the engine are measured using the Euro VI testing procedures WHTC and WHSC.
Some stakeholder from industry also argued that in general there is limited coordination
between the Euro and CO2 emissions standards and that the duplication of legislative acts
aimed at different emissions also adds to the costs that the industry has to incur. While
the approach could affect the costs for industry, which also has to bear costs from other
advancements in for example automated vehicles, there is still room for further
cooperation to improve consistency between the standards to develop an integrated
approach which would provide a more consistent message to industry and consumers.296
291
Regulation (EU) 2019/631 setting CO2 emission performance standards for new passenger cars and for
new light commercial vehicles, and repealing Regulations (EC) No 443/2009 setting emission performance
standards for new passenger cars and (EU) No 510/2011 setting emission performance standards for new
light commercial vehicles; Regulation (EU) 2019/1242 setting CO2 emission performance standards for
new heavy-duty vehicles
292
See footnote 292
293
See footnote 287
294
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapters 5.1.4.3.2 Role of CO2
emission targets and 5.4.2.1.2 Coherence with vehicle CO2 standards
295
Regulation (EU) 2017/2400 implementing Regulation (EC) No 595/2009 as regards the determination
of the CO2 emissions and fuel consumption of heavy-duty vehicles and amending Directive 2007/46/EC of
the European Parliament and of the Council and Commission Regulation (EU) No 582/2011
296
See footnote 287
69
However, no significant evidence was found to suggest that Euro 6/VI emission
standards resulted in unintended negative consequences for CO2 emission standards.297
It
can, however, be expected that the separate standards lead to some inefficiencies, both in
terms of cost and in the processes to develop and deploy technologies.298
c. Roadworthiness Directives
The Directives on roadworthiness of vehicles299
have the objective to contribute to the
reduction of emissions from road transport through measures aiming at detecting more
effectively and removing from circulation vehicles which are over-polluting due to
technical defects. That way, roadworthiness testing for emissions is primarily focussed
on ensuring that key pollution-control devices are present and operating correctly and are
hence roadworthy. This is done through two types of inspections: the Periodic Technical
Inspection (PTI) – which takes place at fixed intervals allowing the owner to prepare for
a standard testing procedure – and the Roadside Inspections (RSI) – for which vehicles
are selected on the road and the inspector can more freely determine what is inspected.
Nevertheless, stakeholders from all groups in the targeted consultation, including 7 (3
type-approval authorities, 3 public authorities and 1 technical service) out of the 8
authorities or technical services that answered this question, indicate that there are
inconsistencies or conflicts between the Roadworthiness Directives and the Euro 6/VI
emission standards. Two main sources of inconsistency between the legislations were
discovered: the first one lies in the Roadworthiness Directives, while the second one is a
problem of the Euro 6/VI emission standards.
The Roadworthiness Directives do not take into account a potential need to assess
compliance with the emission limits set in the Euro 6/VI emission standards. Despite the
objectives of roadworthiness emission testing (both PTI and RSI) towards reducing
pollutant emissions, the limited nature of the unloaded tests results in poor alignment
with the Euro 6/VI emission standards. In this context, one research organisation, two
public authorities and one NGO300
agreed that roadworthiness testing – and especially
PTI – could and should be more directly correlated to the Euro 6/VI emission standards.
One environmental NGO and a technical service association replying to the Combined
Evaluation Roadmap/Inception Impact Assessment301
stressed the importance of
strengthening and improving PTI. In addition, the results of the public consultation
stressed that the majority of the participating stakeholders from Member States, civil
society and citizens indicated that inadequate PTI and RSI contribute to a great or even a
very great extent to an increase in emissions.302
The Euro 6/VI emission standards tightened the thresholds for the provision of
information from on-board diagnostics (OBD) systems that are used for emission testing
during PTI. However, Euro 6/VI emission standards do still not include requirements on
OBD that are sufficient to properly support emission testing during the lifetime of
vehicles. This is due to the fact that OBD systems currently have limited capacity and are
297
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1.6.2 Have there been
any impacts from the Euro 6/VI in relation to: prices of vehicles, CO2 and other emissions?
298
See footnote 287
298
See footnote 287
299
Directive 2014/45/EU and Directive 2014/47/EU
300
Transport & Environment, 2020. Road to Zero: the last EU emission standard for cars, vans, buses and
trucks
301
See footnote 50
302
See footnote 108
70
ineffective in detecting and diagnosing degradation, failure or tampering303
of pollution-
control devices. These issues may not only be technical but also behavioural. The issues
with OBD result in, for example, PTI not being capable of detecting whether a good
functioning particulate filter is in place in diesel vehicles.304
Four stakeholders – one
from industry, one type-approval authority, one research institution and one
environmental NGO305
– criticised the Euro 6/VI emission standards for not including
sufficient PTI/RSI provisions that could require checks of vehicles during their lifetime
and efficient tools, especially software, to prevent manipulation. As a result, the majority
of respondents to the public consultation from Member States and civil society disagreed
that OBD ensures that new vehicles are compliant with the pollutant limits over their
entire lifetime.306
2) External coherence with other EU and national policy developments
a. Other EU policy developments
Considering other EU policies (i.e. taxation, industry and employment), most coherence
issues were found in taxation policy. 11 out of 36 stakeholders from all groups identified
issues in this area. Industry indicated that taxation is applied inconsistently across the EU
for different types of vehicles307
. While unified tax incentives and disadvantages would
help manufacturers focus their efforts, this would also be beneficial for health and
environment as similar taxation across Member States avoids that old and less clean
vehicles are sold to Eastern Europe.308
As set out in the European Green Deal roadmap,
the Commission will propose by June 2021 to revise the Energy Taxation Directive309
,
focusing on environmental issues, and proposing to use the provisions in the Treaties that
allow the European Parliament and the Council to adopt proposals in this area through
the ordinary legislative procedure by qualified majority voting rather than by unanimity.
While no stakeholders expressed concerns regarding potential inconsistencies between
Euro 6/VI emission standards and EU employment policy, an environmental NGO
voiced its concerns on the coherence with EU industrial policy. The stakeholder
indicated that the unintended Dieselgate event negatively affected the reputation and
competitiveness of European industries and while the introduction of RDE testing
improved the industry’s competitiveness, the competitive position of the industry is still
undermined through the lower stringency of the requirements in Euro 6/VI emission
standards compared to other key markets (i.e. US, China). This opinion shows that there
might be some consistency issues between Euro 6/VI emission standards and industrial
policy. In addition, through the New Industrial Strategy for Europe310
, which was already
303
See footnote 107
304
Kadijk G., Spreen J.S. & van der Mark P.J., 2016. Investigation into a Periodic Technical Inspection test
method to check for presence and proper functioning of Diesel Particulate Filters in light-duty diesel
vehicles
305
See footnote 96
306
See footnote 113
307
ACEA, 2021. According to ACEA website accessed on 15 January 2021, there is still a huge variation
in both the basis for taxation and tax levels across the European Union. Several Member States tax cars on
their power, price, weight, cylinder capacity or a combination of these factors though, increasingly,
countries are adopting CO2-based taxation. Presently, 24 EU Member States tax vehicles on their roads
according to their CO2 emissions levels.
308
See footnote 287
309
Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and
electricity
310
COM(2020) 102 final, A New Industrial Strategy for Europe
71
discussed in Evaluation Question 6, some other coherence issues are found. The strategy
introduced the need for a new industrial way that is fit for the ambitions of today and the
realities of tomorrow, so the EU industry becomes more competitive as it becomes
greener and more circular. As Evaluation Question 3 already confirmed, the more
stringent requirements introduced in Euro 6/VI emission standards compared to Euro 5/V
are not considered sufficient to result in competitive gain for the European manufacturers
given that their global counterparts are implementing tighter standards. Hence, the Euro
6/VI emission standards appear not to be coherent with the New Industrial Strategy for
Europe.
b. Other national policy developments
While Low- and Zero Emissions Zones (LEZs and ZEZs) and their benefits for raising
public awareness and for supporting the relevance of the Euro emission standards were
already discussed in Evaluation Question 3 and 6, this section looks into the coherence
between these local initiatives and the Euro 6/VI emission standards.
As the Euro 6/VI emission standards, most local LEZs have the objective to improve air
quality by reducing air pollution caused by road transport. Some cities (e.g. Amsterdam,
Brussels, London, and Paris) go even further with their zero-pollution ambitions and
have already set course toward different forms of ZEZs. A large proportion of these local
initiatives use the Euro 1/I to 6/VI emission standards as a kind of “labelling” criterion
for granting access or determining the charge to be applied to enter a certain area.
Therefore, there is a consistency between both the objectives and the implementation of
the initiatives needed.311
However, manufacturers provided a coordinated response to the
targeted consultation in which they indicated that the arising of local restrictions by local
or regional authorities using Euro 1/I to 6/VI in a different manner and timing as
“labelling” criteria are actually considered inconsistent between each other and they
could result in the fragmentation of the EU internal market.312
5.5. EU-added value
Evaluation question 8: What is the added value of Euro 6/VI compared to what
could have been achieved at merely national level? Do the needs addressed by Euro
6/VI continue to require harmonisation action at EU level?
Overall conclusion: Overall, a clear EU-added value and respect of the subsidiarity
principle is confirmed for the Euro 6/VI emission standards, in line with the general
objectives of the Treaty ensuring a proper functioning of the Internal Market and
providing for a high level of environmental protection in the EU.
No indication was found of changing needs for the Internal Market suggesting that a
harmonised approach for vehicle emission standards would no longer be necessary.
If Member States were expected to act to reduce pollutant emissions, a fragmented
approach would be realised, resulting in less effective intervention at significantly
higher costs for industry and authorities. In addition, it continues to be more
effective to tackle vehicle pollutant emissions at EU level considering that more can
achieved there than at the national level. Hence, EU intervention is required to
achieve the desired results.
311
See footnote 237
312
See footnote 287
72
The objectives of Euro 6/VI emission standards could be achieved at international
level only to a much lower extent and at a much slower pace. Nevertheless, industry
takes a more reserved position when it comes to EU-added value in comparison
with what could be achieved at UN level.
EU-added value of Euro 6/VI emission standards
In the context of pollutant emissions emerging from road transport, there is a clear and
persistent need for Euro 6/VI emission standards at EU level. A first reason for this is
that both air pollution and road transport have a transboundary dimension. While air
pollution from road transport is primarily a problem in Europe’s urban areas,
atmospheric modelling shows that the pollution emitted in one Member State also
contributes to pollution in other Member States. In addition, neither freight nor passenger
transport stops at the national borders.313
Considering this, any efforts taken by Member
States in the absence of harmonised EU action could be offset by other (neighbouring)
Member States through cross-border spill-over effects, making it extremely difficult to
achieve the same level of environmental and health protection as achieved on EU level.
Hence, fulfilling the specific objective of Euro 6/VI emission standards to improve air
quality by reducing pollutants emitted by the road transport sector could not be realised
as effectively without EU action.314
The development and governing of Euro 6/VI emission standards at EU level is key to
prevent harm to the functioning of the Internal Market. While local or national initiatives
could in theory replace EU action, they would also create considerable obstacles for
automotive industry to enter into national markets, as numerous standards are expected to
arise. This shows that national action poses great risks for the Internal Market, which
comprises an area without internal frontiers where the free movement of goods, persons,
services and capital must be ensured. To safeguard the free movement of vehicles,
common emission standards for cars, vans, lorries and buses can only be achieved at EU
level. That way, a cobweb of technical requirements for different Member States would
not achieve the second specific objective of Euro 6/VI emission standards of setting
harmonised rules on the construction of motor vehicles in line with Article 114 of the
Treaty of the Functioning of the European Union315
.316
This shows that the needs and
challenges addressed by the Euro 6/VI emission standards clearly correspond to the
needs of the Internal Market.317
Both arguments emphasise that there is a clear case for a harmonised approach to combat
vehicle pollutant emissions through the development of Euro standards at EU level. To
313
See footnote 3
314
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.5.1.3 Is there
continued EU added value of requiring harmonisation at EU level? Could certain elements be added or
dropped?
315
The Treaty on the Functioning of the European Union, 2012. Article 114 stipulates “1. … The European
Parliament and the Council shall … adopt the measures for the approximation of the provisions laid down
by law, regulation or administrative action in Member States which have as their object the establishment
and functioning of the internal market. … 3. The Commission, in its proposals envisaged in paragraph 1
concerning health, safety, environmental protection and consumer protection, will take as a base a high
level of protection, taking account in particular of any new development based on scientific facts. …”.
316
See footnote 3
317
See footnote 320
73
validate these arguments, the evaluation will look into the EU-added value compared to
what could be achieved at both the national and the international level.
EU-added value of Euro 6/VI emission standards compared to action at national level
Member States are expected to take action if no Euro 6/VI emission standard were in
place. At the same time, like-minded Member States would be likely to cooperate
through harmonising their emission standards, either at a more or less stringent level,
while smaller Member States are expected to adopt the emission standards of larger
Member States. Hence, a collection of different emission standards would arise over the
EU.
This scattered approach is not expected to be equally effective in achieving the above-
mentioned objectives of the Euro 6/VI emission standards. Next to the cross-border
issues discussed above, the expected difference in willingness of Member States to
strictly regulate the emission from vehicles would contribute to this. These differences
were striking in the adoption process for the Euro 6d step where some Member States
were against the adoption of more stringent conformity factors318
or testing procedures.319
This shows that not all national emission standards are expected to be as ambitious as
Euro 6/VI emission standards or may even not be in place at all. A large majority of
stakeholders from all groups – industry, national authorities and civil society – agree in
the targeted consultation with this conclusion, indicating that the strictness of limits
would be either somewhat or significantly lower if action was taken at the national level.
Also, they expect that Member State action would be less effective in bringing cleaner
vehicles to the market and in reducing pollutant emissions. Hence, the high level
environmental protection that is currently achieved at EU level could not be realized at
national level. 320
Action at national level could also not ensure the proper functioning of the Internal
Market. According to an extremely large majority across all stakeholder groups in the
targeted consultation, harmonisation in terms of placing vehicles on the EU market
would have been lower if action was taken at Member State level. Similarly, in the public
consultation 138 out of 160 respondents from all groups - industry, Member States, civil
society and citizens - agreed that EU regulations on air pollutant emissions are more
efficient than national regulations.321
In addition, compliance and administrative costs for industry and national authorities
would be significantly higher in the absence of EU action, as confirmed by
manufacturers and type-approval authorities concerned in the targeted stakeholder
consultation. This could even trigger manufacturers to abandon certain Member State
markets where the cost of compliance would be higher than the expected revenues. 322
EU-added value of Euro 6/VI emission standards compared to action at international
level
318
See footnote 45
319
Gieseke and Gerbrandy, 2017. Report on the inquiry into emission measurements in the automotive
sector A8-0049/2017- Committee of Inquiry into Emission Measurements in the Automotive Sector
320
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.5.1.2 What would
have happened on the basis of action taken at national or regional level only?
321
See footnote 144
322
See footnote 320
74
Action at international level is often seen as an alternative for EU action by mostly
stakeholders from industry. In the context of vehicle emission standards, international
action would most likely take place through the UN’s World Forum for Harmonization
of Vehicle Regulations323
which focusses on the establishment of global harmonisation
of certain technical regulations for vehicles including mutual recognition of type-
approval amongst its signatories and limits air pollutant emissions through Regulation
No 83 for cars and vans, and Regulation No 49 for lorries and buses324
. The EU, which is
generally considered to be the driving force behind more stringent UN standards325
, has
achieved that the before mentioned UN Regulations were aligned with the Euro 6/VI
emission limits and testing procedures.326
The objectives of Euro 6/VI, however, could only be achieved to a much lower extent
and at a much slower pace at UN level than would be the case at EU level. This follows
from the fact that without the EU’s driving force, the standards that would eventually be
adopted at UN level would be based on the lowest common denominator and hence
provide lower environmental and health protection, which is confirmed by stakeholders
from civil society and public authorities. Additionally, the adoption of the international
emission standards would take way more time compared to EU regulation. This slow
progress for the development of UN regulations has been observed in the development of
a whole vehicle type-approval system and in several safety-related initiatives.327
While most stakeholders agree that UN standards would be less effective in reducing
pollutant emissions, industry seems less convinced. In addition, stakeholders from all
groups expect costs in this scenario to be the same or slightly lower for national
authorities, and slightly or significantly lower for industry. While no evidence was
provided for these statements, several industry stakeholders argued that global standards
could lead to cost-savings as they would provide room to achieve higher economies of
scale.328
In order to either confirm or refuse these statements from industry, a complex
cost-benefit analysis covering the major global markets and market segments would be
necessary.
Principle of subsidiarity and the Euro 6/VI emission standards
The principle of subsidiarity is defined in Article 5 of the Treaty on European Union329
.
It aims to ensure that decisions are taken as closely as possible to the citizen and that
constant checks are made to verify that action at EU level is justified in light of the
possibilities available at national, regional or local level.
323
WP29 World Forum for Harmonization of Vehicle Regulations (WP.29) is a permanent working party
in the institutional framework of the United Nations and offers a unique framework for globally
harmonized regulations on vehicles.
324
UN Regulation No 83 — Uniform provisions concerning the approval of vehicles with regard to the
emission of pollutants according to engine fuel requirements; UN Regulation No 49 — Uniform
provisions concerning the measures to be taken against the emission of gaseous and particulate pollutants
from compression-ignition engines and positive ignition engines for use in vehicles
325
Norman, J., 2018. Vehicle Type Approval
326
Transport Research Laboratory, 2014. Transposition of EC Euro 6 Regulation into UNECE Regulations
327
SWD (2015) 138 final. Progress report on the 2014 activities of the World Forum for Harmonisation of
Vehicle Regulations (UNECE WP.29)
328
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.5.1.4 How do the
results and impacts of Euro 6/VI compare with what would have been achieved by action taken at
international level (i.e. the UNECE)?
329
See footnote 315
75
In line with the Euro 6/VI impact assessments330
, this evaluation confirms that the Euro
6/VI emission standards respect the principle of subsidiarity. As discussed above, the
majority of stakeholders considers the EU approach to be considerably more effective in
tackling emissions from vehicles than both national or international action. In addition, a
majority of stakeholders across all groups indicated that without EU action and with
solely national action, harmonisation would have been significantly lower, which would
be detrimental for the proper functioning of the Internal Market and the high level of
environmental protection in the EU.331
Considering this, action at EU level is justified
and continues to be justified in light of what can be achieved at other levels of
governance.
6. CONCLUSIONS
The Euro 6/VI emission standards – being the sixth generation of harmonised emission
standards for cars, vans, lorries and buses – continued the progress toward enhancing the
pollutant emission performance of vehicles on EU roads that started with Euro 1/I in
1992. This stepwise approach of introducing more stringent pollutant emission standards
aimed at improving the contribution of new vehicles to air quality issues.
Considering the presentation of the European Green Deal332
in December 2019 as a new
growth strategy introducing a zero-pollution and climate-neutrality ambition, the Euro
6/VI emission standards have been evaluated through the five evaluation criteria.333
The
aim was to assess to what extend Euro 6/VI has achieved the objectives of setting
harmonised rules on pollutant emissions from vehicles and improving the air quality by
reducing pollutant emitted by road transport with specific focus on nitrogen oxide (NOx),
particle mass (PM) and hydrocarbon (HC). This evaluation covers the Euro 6 regulation
for cars and vans, the Euro VI regulation for lorries and buses and their respective
implementing measures, together referred to as Euro 6/VI emission standards.334
It
considers the EU-27 Member States and former Member State the United Kingdom and
covers the period since the entry into force of the Regulations (2014 for Euro 6 and 2013
for Euro VI) up until 2020. However, given that the impacts of Euro 6/VI are expected to
last after 2020 until the vehicle fleet consists of Euro 6/VI vehicles, the evaluation also
refer to the expected impacts of the Euro 6/VI emission standards until 2050.
It should be mentioned that the Euro 6/VI evaluation entails some limitations in the form
of limited provisions of cost data by automotive industry and type-approval authorities
for the efficiency assessment, discrepancies between different information sources on the
uptake of Euro 6/VI vehicles and lacking monitoring indicators for the Euro 6/VI
emission standards. Despite these limitations, the initiated analysis underpinning this
evaluation was sufficient to formulate answers to the evaluation questions.
Euro 6/VI realised partly cleaner vehicles on EU roads
330
See footnote 3
331
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.5.1.3 Is there
continued EU added value of requiring harmonisation at EU level? Could certain elements be added or
dropped?
332
COM(2019) 640 final, The European Green Deal
333
Effectiveness, Efficiency, Relevance, Coherence and EU-added value (in line with the Better Regulation
Guidelines)
334
Regulation (EC) No 595/2009 on type-approval of motor vehicles and engines with respect to emissions
from heavy-duty vehicles (Euro VI) and its implementing Regulation (EU) No 582/2011; Regulation (EC)
No 715/2007 on type-approval of motor vehicles with respect to emissions from light passenger and
commercial vehicles (Euro 5 and Euro 6) and its implementing Regulation (EU) 2017/1151.
76
Since the entry into force of Euro VI emission limits in 2013 and Euro 6 emission limits
in 2014 up until 2020, NOx emissions on EU roads have decreased by 22% for cars and
vans and by 36% for lorries and buses. In comparison with the estimates of the Euro 6/VI
impact assessments335
, the NOx savings linked to Euro 6/VI were only slightly lower than
the 24% which was initially expected for Euro 6 and the 37% expected for Euro VI. In
addition, exhaust PM emissions on EU roads have known a decrease of 28% for cars and
vans, and a decrease of 14% from lorries and buses. These savings for lorries and buses
were estimated somewhat higher in the Euro VI impact assessment at 22%.
Total hydrocarbons (THC) emissions from lorries and buses also went down by 14%
with Euro VI, while THC and non-methane hydrocarbons (NMHC) emissions from cars
and vans went down by 13 and 12%. However, for the other pollutant – including carbon
monoxide (CO) for cars and vans, and methane (CH4) for lorries and buses – no
significant emissions savings were observed following the introduction of Euro 6/VI. For
ammonia (NH3) from lorries and buses, the emission were even found to increase with
the introduction of Euro VI, which indicates that the limits for this pollutant are
insufficiently low.
For the benefit of citizens, Euro 6/VI emission standards curbs health impacts by road
transport that lead to long-term respiratory and cardiovascular diseases, for example
bronchitis, asthma or lung cancer. However, several obstacles to cleaner vehicles on EU
roads have been identified which have negative consequences on public health. Hence
the Euro 6/VI objective to improve air quality by reducing pollutants from road transport
is very relevant and requires actions as follows.
The Euro 6/VI emission limits for the above-mentioned regulated pollutants are found to
be insufficient. New pollutant emissions from road transport have arised since the
adoption of Euro 6/VI more than a decade ago with the introduction of new engines,
exhaust aftertreatment technologies, fuels and additives. Current technologies to restrict
NOx emissions in Euro 6 cause a NH3 slip, resulting in increasing emissions of NH3 as
this pollutant is not regulated in Euro 6. Euro 6/VI has also resulted in particularly high
N2O and NO2 emissions. In addition, some pollutant are not controlled sufficiently
precisely as they are currently aggregated in wider pollutant categories (e.g. NMOG,
HCHO, NO2). Other pollutants that are of concern today, but are not yet regulated
include ultrafine particle emissions, CH4 emissions for cars and vans and brake- and tyre
wear.
There is technological potential to go further without large investment costs as many
technologies to further decrease pollutant emissions are already on the market and partly
in place in other key markets (i.e. United States and China). Vehicle manufacturers are
not likely to adopt more effective emission control technologies to further combat
emissions from new vehicles, solely because they are already available on the market.
Euro 6/VI testing procedures partly effective
The above-mentioned RDE testing reduced the gap between type-approval and real-
world emissions for cars and vans. The Portable Emission Measurement Systems
(PEMS) testing introduced under Euro VI D for lorries and buses was less effective.
While cold start emissions was already addressed in the last Euro VI E step that still has
335
SEC(2005) 1745 Commission Staff Working Document, Impact Assessment on Euro 5/6 emission
standards; SEC(2007) 1718 Commission Staff Working Document, Impact Assessment on Euro VI
emission standards
77
to enter into force, the gaps in low-speed driving conditions and idle vehicles with low
loads identified for Euro V vehicles continued in Euro VI vehicles.
Euro 6/VI testing procedures have made a gradual progress towards increasing the level
of representativeness of the considered driving cycles and conditions of use, especially in
urban driving conditions. Nevertheless, despite these improvements, important emissions
remain unaccounted under Euro 6/VI emission testing. Test boundaries for cars and vans
still exclude short trips, high mileage, high altitude and severe temperature conditions;
and test boundaries for lorries and buses low loads, low speed and idle times that are
important in urban areas.
There is also a demand for cleaner vehicles on EU roads over their whole lifetime as the
average age and lifetime mileage of vehicles on EU roads have doubled in average since
the adoption of Euro 6/VI. The Euro 6/VI durability requirements appear no longer
effective in capturing vehicles’ real world emissions over their useful lifetimes, as they
are significantly lower than today’s average fleet age and lifetime mileage for all vehicle
types.
Hence, a complete coverage of real-world driving cycles and all conditions of use is still
missing in Euro 6/VI emission standards.
Euro 6/VI regulatory costs considerable but affordable
The Euro 6/VI emission standards have led to considerable regulatory costs for
automotive industry, which were mainly driven by the emission control technologies and
are to a great extent passed through to the consumers. The total regulatory costs
compared to Euro 5/V are €21.1 to €55.6 billion for Euro 6 (2014-2020) and €9.5 to
€20.4 billion for Euro VI (2013-2020). These regulatory costs result in average to 95-
99% from equipment costs (hardware costs, R&D and related calibration, facilities and
tooling costs) and in average to 1-5% from costs during implementation phase (testing
and witnessing costs, type-approval fees) and administrative costs.
The weighted average of the total regulatory cost for the period up to 2020 is estimated at
around €357-€929 per diesel vehicle and by €80-€181 per petrol vehicle for Euro 6 (cars
and vans). However, these estimates hide the fact that the costs per vehicle have been
significantly higher over the last few years since the introduction of RDE testing in year
2017. The largest part of these costs are hardware costs arising from the need to install
emission control technologies on vehicles to meet the emission limits. While initially the
hardware costs for petrol vehicles did not change moving from Euro 5 to Euro 6 (b-c),
moving to the final step of Euro 6 (d) has resulted in an increase of €228-€465 per petrol
vehicle. For diesel vehicles, the initial hardware costs for Euro 6 (b-c) were €341-€937,
while the moving from Euro 5 to the final step of Euro 6 (d) increased the hardware costs
by €751-€1 703. In all, the weighted average costs for Euro 6 are found to be higher than
the expected costs in the Euro 6 impact assessment in which the weighted average cost
per diesel vehicle was estimated at €213 (€280 in 2020 prices).336
For Euro VI for lorries and buses, the weighted average of the total regulatory costs
increased by €3 717-€4 326 per vehicle. As was the case for Euro 6, the hardware costs
represent the largest share of these costs and are mainly driven by the introduction of
diesel particulate filter (DPF) technology. Moving from Euro V to Euro VI, the hardware
costs for lorries and buses increased between €1 798 and €4 200 per vehicle. These cost
336
See footnote 335
78
estimates are comparable with the costs in the Euro VI impacts assessment which were
estimated in the range of €2 539-€4 009 (€2 817 to €4 419 in 2020 values).337
The analysis also pointed out sizeable R&D and related calibration costs including
facilities and tooling costs related to the sixth generation of Euro standards, estimated at
around €43-€156 per diesel vehicle and €36-€108 per petrol vehicle for Euro 6 (cars and
vans) and €1 900-€3 800 per vehicle for Euro VI (lorries and buses). In particular the
latter were higher than expected due to the lower sales number of heavy-duty vehicles.
The introduction of more demanding RDE and PEMS testing procedures has led to a
sizeable increase of costs during implementation phase as a result of the more demanding
testing regimes and the associated reporting procedures. Testing and witnessing costs
increased by €150-€302 thousand per model family for Euro 6d(-temp) and by €96-€232
thousand per engine family for Euro VI. The related reporting procedures have increased
the administrative costs by €16-€52 thousand per type-approval for Euro 6d(-temp) and
by €18-€28 thousand per type-approval for Euro VI. A main area where unnecessary
costs may have arisen is in the practical aspects of the introduction of the testing
procedures under Euro 6d(-temp), increasing the number of type-approvals considerably.
Type-approval authorities incurred one-off costs as well as an increase in recurrent costs
due to new staff and new testing facilities. However, these costs during implementation
phase are expected to be covered mainly through type-approval fees charged to
manufacturers.
These costs during implementation phase related to type approval and fees and
administrative costs represent a smaller amount of the total regulatory cost for both Euro
6 (4-5%) and Euro VI (1%). The only exception are the costs for petrol cars and vans
where, due to the fact that there was no need for new technologies in the initial stages,
the overall share of the other costs elements was higher (19%).
The average vehicle price increase for consumers due to Euro 6/VI is less than 2% for
cars and vans, in the range of 4.2-5% for lorries and of 2.1-3% for buses. However, for
the most recent step in Euro 6, the average price increase for diesel cars and vans is
significantly higher – 4.3% for the small segment vehicles, compared to 2.7% for the
large segment vehicles.
In conclusion, the total regulatory costs resulting from the Euro 6/VI emission standards
are significant. At the same time, there is no indication that they are not affordable for
industry, approval authorities and consumers, with the exception of vehicle price
increases for small diesel cars and vans.
Euro 6/VI was cost-effective
The Euro 6/VI emission standards are in general cost-effective compared to Euro 5/V and
have generated net economic benefits to society. The positive net benefits are estimated
at €192-€298 billion for Euro 6 cars and vans. In particular diesel cars and vans have
positive net benefits of €219-€304 billion associated with the emission savings for these
vehicles. On the other hand, petrol cars and vans seems to have negative net benefits due
to the limited NOx emission savings and high compliance costs for gasoline particulate
filters. For Euro VI lorries and buses, very positive net benefits of estimated €490-€509
billion have been realised.
337
See footnote 335
79
The regulatory costs of Euro 6/VI emission standards have been considered justified and
proportionate in the public and targeted stakeholder consultation by a large majority
across all stakeholder groups – industry, Member States and civil society – to ensure the
necessary decrease in air pollutant emissions emerging from road transport and hence
prevent negative effects on human health and environment.
Industry stakeholders however were somewhat sceptical, indicating that consumers do
not really appreciate the improvements in aftertreatment technologies in vehicles, in
contrast to the situation for fuel efficiency. On the other hand, the majority of
stakeholders across all groups, including citizens, indicated that Euro 6/VI, and in
particular the introduction of RDE testing in the wake of Dieselgate, at least contributed
somewhat towards ensuring consumer trust in the type-approval system and automotive
products.
Euro 6/VI did not impact the competitive position of automotive industry
For the competitiveness of industry, Euro 6/VI emission standards had overall neither a
clear positive nor a clear negative impact on the targeted market segments. It is difficult
to determine whether the increased regulatory costs, in particular for cars and vans after
the introduction of RDE testing, have affected the respective profit margins and the
overall profitability. Clearly, it cannot be determined if a price increase of cars since
2014 is associated to regulatory costs associated with the Euro 6 emission standards, it
could also be the result of various other factors affecting prices.
The regulatory costs also do not necessarily imply a direct negative impact on the
competitiveness of the EU manufacturers compared to non-EU competitors, as the latter
are faced with similar costs. In the contrary, to ensure the competitiveness of the EU
automotive industry, stricter emission limits and testing procedures would help
manufacturers to ensure access to external markets, which have adopted stricter limits, in
particular the United States and China.
Considering the number of R&D projects directly linked to Euro 6/VI emission
standards, it is expected that the standards had a positive impact on research activities in
the EU. On the other hand, some stakeholders suggested that most of the technologies
were already available on the market and the standards fostered innovation through
improving existing technologies and subsequently decreasing their costs.
There is no compelling evidence suggesting that the Euro 6/VI emission standards have
had a sizeable impact on employment or on increasing consumer awareness of air
pollution issues.
Recent policy developments make the Euro 6/VI objectives more relevant
Recent policy developments, that means the European Green Deal, support the Euro 6/VI
objectives and the relevance to improve air quality by reducing emissions from road
transport in a unified EU approach. The European Green Deal emphasises the need to
make transport significantly less polluting, especially in urban areas, in order to
accelerate the shift to sustainable and smart mobility and thus support the
competitiveness of the EU automotive industry on the global market. The European
Green Deal roadmap therefore includes a proposal for more stringent air pollutant
emissions standards for combustion-engine vehicles by 2021. At the same time, the
European Green Deal underlines the EU’s objective of achieving climate neutrality by
2050 and the roadmap includes a proposal for strengthened CO2 standards for cars and
vans by June 2021. The interplay of both emission initiatives will have to provide a
80
pathway to zero-emission vehicles, while at the same time it will have to ensure that the
remaining internal combustion engines are as clean as they can be in accordance with the
zero-pollution ambition of the European Green Deal.
Some coherence issues on vehicle emissions legislation
Stakeholders from all groups - including industry, national authorities and civil society -
confirm in the targeted consultation on the Euro 6/VI evaluation that, overall, vehicle
manufacturers are provided with a coherent policy and legal framework to reduce vehicle
emissions. Nevertheless, there are some coherence issues as follows.
Regarding internal coherence within Euro 6/VI emission standards, there is a lack of
fuel- and technology neutrality, when it comes to different emission limits for diesel and
petrol vehicles or PN limits set for petrol vehicles only. Moreover, there is a lack of
coherence between Euro 6 for cars and vans and Euro VI for lorries and buses, as there
are different application dates of the steps of Euro 6/VI, i.e. Euro 6b-d(-temp) and Euro
VI A-E, NH3 and CH4 are regulated in Euro VI only and there seems to be a lack of clear
border between Euro 6 and Euro VI vehicles.
Regarding external coherence with other EU legislation, the main issue identified is that
the Euro 6/VI emission standards and the Roadworthiness Directives on Periodic
Technical Inspections (PTI) and Roadside Inspections (RSI) do not yet operate in the
complementary way necessary. To guarantee protection against degradation, failure or
tampering of aftertreatment systems during the lifetime of vehicles, improvements in the
requirements for on-board diagnostics (OBD) systems in the Euro 6/VI emission
standards are important that can be used for emission testing during PTI and RSI.
There are some differences in the pollutants regulated in the Air Quality Directive and
Euro 6/VI emission standards but this is substantiated by Euro 6/VI covering tailpipe
emissions from road transport and Air Quality Directive covering all air pollution
sources. Some industry stakeholders raised concerns about trade-offs between CO2 and
NOx combatting technologies. However, no significant evidence was found to suggest
that Euro 6/VI emission standards resulted in unintended negative consequences for CO2
emission standards.
Euro 6/VI has simplification and burden reduction potential
No simplification was realised in the Euro 6/VI emission standards. In the contrary, all
stakeholder groups pointed out that Euro 6/VI testing procedures have become too
complex. More demanding emission tests introduced gradually over the steps of Euro
6/VI increased the complexity significantly resulting in a text of more than 1 300 pages
with increasing number of references to UN Regulations and different application dates
for different vehicle categories, new vehicle types and new vehicles. This development
increased the enforcement costs for industry and type-approval authorities. For
stakeholders from civil society this complexity is seen as, at least partly, proportionate in
view of the need to ensure that vehicles are clean on the basis of more demanding testing
and in-service conformity requirements.
Euro 6/VI has clear EU-added value
The Euro 6/VI evaluation confirmed a clear EU-added value to take action on vehicle
pollutant emissions through a harmonised approach at EU level, in order to avoid the
fragmentation of the internal market for vehicles by incoherent, national emission
standards and to allow industry and public authorities to take advantage from economies
81
of scale.
No indication was found of changing needs for the internal market suggesting that a
harmonised approach for vehicle emission limits would no longer be necessary. In the
contrary, a unified EU approach to curbing harmful emissions and ensuring cleanest
possible performance of a combustion engine during the transition phase towards zero-
emissions road transport, is needed. A phase out of combustion engines should not be left
to the decisions of individual Member States (e.g. ban of diesel and petrol vehicles),
risking to cause damage to the internal market. Such uncoordinated actions would create
inefficiencies for the automotive industry. Manufacturers would have to design, produce
and commercialise different vehicles for different Member States.
The objectives of Euro 6/VI emission standards could be achieved at international level
only at the cost of their effectiveness to a much lower extent and at a much slower pace.
While most stakeholders agree that UN standards would be less effective in reducing
pollutant emissions, industry seems less convinced. Several industry stakeholders argued
that global standards result in larger economies of scale and in more level playing field.
In order to either confirm or refuse these statements from industry, a complex cost-
benefit analysis covering the major global markets and market segments would be
necessary.
Lessons learned on monitoring and reporting
Some lessons can be learned from the lacking implementation of monitoring indicators
identified in the Euro 6/VI impact assessments in the Euro 6/VI legislation, which
considerably hampered the evaluation process.
The Euro 6/VI impact assessments identified the ‘number of vehicles which are
successfully type-approved according to the Euro 6 or Euro VI standard’ as the core
monitoring indicator. However, the Euro 6/VI legislation did not translate this
monitoring indicator into a reporting requirement for the Member States. The Euro 6/VI
evaluation had to rely on a limited number of contributions from Member States and
industry through the first targeted consultation and on costly private data to proceed with
the evaluation.
In addition, neither Member States have reported on the implementation to ensure that
requirements of the regulations are met nor specific monitoring data on air pollution
levels and epidemiology on health impacts from road transport were available.
82
Appendix: Details on methods and analytical models
The evaluation of Euro 6/VI emission standards and the impact assessment for Euro 7
emission standards were carried out in 2020/21 as back-to-back approach. Both used the
same procedure (see Annex 1), stakeholder consultation (see Annex 2) and analytical
methods (see Annex 4).
Supporting Euro 6/VI evaluation study
Eight overarching evaluation questions were formulated to assess the regulations’
effectiveness (three questions), efficiency (two questions), relevance (one question),
coherence (one question) and EU-added value (one question). To inform the responses to
these eight evaluation questions, a supporting Euro 6/VI evaluation study carried out by
CLOVE consortium in 2020/21338
analysed a total of fourteen evaluation (sub-) questions
which have been summarised into the eight questions considered here. Table A.1 shows
how the responses to the sub-questions in the supporting study have been re-aggregated
in the Staff Working Document.
Table A.1 – Mapping the nine evaluation questions of this staff working document
(SWD) against the 14 evaluation sub-questions addressed in the supporting Euro 6/VI
evaluation study
Criterion Evaluation question (SWD) Evaluation sub-question (supporting
study)
Effectiveness
(1) To what extent and through which
factors has Euro 6/VI made cleaner
vehicles on EU roads a reality?
Which obstacles to cleaner vehicles
on EU roads remain taking into
account possible unintended
consequences on the environment?
EQ1 - To what extent has Euro 6/VI
made cleaner vehicles on EU roads a
reality?
EQ3 - What are the factors that have
influenced positively and negatively the
achievements observed? In particular,
which obstacles to cleaner vehicles on
EU roads still remain?
EQ5 - Has Euro 6/VI had unintended
positive or negative consequences or
collateral effects?
(2) How effective are the Euro 6/VI
testing procedures to verify the
emission standards?
EQ2 - How effective are the existing
testing procedures to verify the emission
standards?
(3) What are the benefits of Euro 6/VI
and how beneficial are they for
industry, the environment and
citizens?
EQ4 - To what extent has Euro 6/VI
achieved other specific objectives?
EQ6 - What are the benefits of Euro 6/VI
and how beneficial are they for industry,
citizens and the environment?
EQ7 - To what extent has Euro 6/VI
supported innovative technologies and
other technological, scientific or social
development? Are adaptation
mechanisms in place to allow this?
338
CLOVE, 2022. CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3.
83
Criterion Evaluation question (SWD) Evaluation sub-question (supporting
study)
Efficiency
(4) What are the regulatory costs related
to the Euro 6/VI emission standards
and are they affordable for industry,
type-approval authorities and
consumers? Have Euro 6/VI
emission standards achieved a
simplification of vehicle emission
standards?
EQ8 - What are the compliance and
administrative costs? Is there evidence
that Euro 6/VI has caused unnecessary
regulatory burden? Are they affordable
for industry and approval authorities?
EQ10 - Has Euro 6/VI achieved a
simplification of vehicle emission
standards in relation to Euro 5/V?
(5) To what extent has Euro 6/VI been
cost-effective? Are the costs
proportionate to the benefits
attained?
EQ9 - To what extent has Euro 6/VI
been cost-effective? Are the costs
proportionate to the benefits attained?
What are the factors influencing the
proportionality of costs?
Relevance
(6) To what extent do the Euro 6/VI
objectives of ensuring that vehicles
on EU road are clean correspond to
the current needs? Is there a
demand/potential for cleaner
vehicles on EU roads over their
whole lifetime?
EQ11 - To what extent do the objectives
of Euro 6/VI of ensuring that vehicles on
EU road are clean correspond to the
current needs? Is there a
demand/potential for cleaner vehicles on
EU roads over their whole lifetime?
Coherence
(7) Are the Euro 6/VI emission
standards coherent internally and
with other legislation pieces
applying on the same stakeholders
and with similar objectives? Are
there any inconsistencies, overlaps
or gaps?
EQ12 - To what extent do Euro 6/VI
features work together sufficiently well?
Are there inconsistencies, overlaps or
gaps?
EQ13 - To what extent is Euro 6/VI
consistent with other legislation pieces
applying on the same stakeholders and
with similar objectives? Are there any
inconsistencies, overlaps or gaps?
EU-added
value
(8) What is the added value of Euro
6/VI compared to what could have
been achieved at merely national
level? Do the needs addressed by
Euro 6/VI continue to require
harmonisation action at EU level?
EQ14 - What is the added value of Euro
6/VI compared to what could have been
achieved at merely national level? Do
the needs and challenges addressed by
Euro 6/VI correspond to the needs of the
internal market? Do the needs and
challenges addressed by Euro 6/VI
continue to require harmonisation action
at EU level?
84
Annex 6: Policy options
6.1. Policy option 1: Low Green Ambition
Policy option 1 implies a narrow revision of Euro 6/VI emission standards with high
ambition on tackling the increasing complexity of the vehicle emission standards
(problem 1) and low ambition to improve vehicle pollutant limits (problem 2) and
insufficient control of vehicle real-driving emissions (problem 3). In line with the
specific objective to reduce complexity of the Euro 6/VI emission standards, option 1
addresses key simplification and consistency challenges through refining the architecture
of Euro 6 and Euro VI. It assumes that a single vehicle emission standard for cars, vans,
lorries and buses is developed, multiple application dates of Euro 6/VI steps are avoided
and the complexity of emission testing is reduced with obsolete tests removed.
Simplification measures
This option includes a number of measures to simplify and refine the legislative
architecture of the emission standards and the emission testing (see Table 47). The
simplification measures target a number of laboratory-based tests that have become less
relevant with the move towards on-road testing.
Table 47 – Simplification measures in policy option 1
Simplification of legislative architecture Reasoning
1. Merging the basic acts of Euro 6
(Regulation (EC) No 715/2007) and Euro
VI (Regulation (EC) No 595/2009) into
one basic act (Euro 7), while keeping
obligations for emission testing for
cars/vans and lorries/buses in separate
implementing acts.339
At least the following implementing acts will
be required:
1. Regulation on testing LDV vehicles (as in
Regulation (EC) 2017/115, including rules for
CoP, ISC and Market Surveillance)
2. Regulation on testing HDV vehicles
(methodology and testing of whole vehicles
with PEMS, part of Regulation (EU) 582/2011
including rules, for CoP, ISC and Market
Surveillance, and expansion to new
powertrains)
3. Regulation on engine type approval as a
separate implementing legislation addressing
engines, part of Regulation 582/2011)
4. Regulation on CO2 determination for HDV
vehicles
5. Regulation on replacement parts and
components (brakes, replacement emission
control systems, …)
2. Defining a new and unambiguous
legislative border between cars/vans and
lorries/buses based on total permissible
maximum laden mass instead of the Euro
6/VI reference mass.340
In order to harmonise with type approval
definitions of motor vehicles
With the request of the manufacturer upward
extension of the mass limit up to 4.0 tonnes
may be taken
339
CLOVE, 2022. Study on post-Euro 6/VI emission standards in Europe – PART B Potentials for
simplification of vehicle emission standards (hereafter “supporting simplification study”), chapter 5.1.1
Merging the main regulations for cars/vans (LDV) and lorries and/buses (HDV)
340
Supporting simplification study, chapter 5.1.2 Scope of regulation
85
3. Introducing a single application date per
vehicle category for Euro 7.341
No need for two application dates, one for new
vehicle types and one for new vehicles since
new vehicle types may be type approved
according to the rules from the moment of
entry into force. The possibility to provide
financial incentives for early introduction is
foreseen.
4. Improved on-board diagnostics (OBD) as a
support element to enable testing for in-
service conformity (ISC) and market
surveillance (MaS).342
Enhanced use of Malfunction Indicator Light
(MIL) to facilitate testing and enforce repairs.
Details to be defined in Implementing
Regulations.
5. Aligning EU and international UN
regulations by referencing UN
regulations343
in Euro 7 where
appropriate.344
In support to international harmonisation of
type approval rules, UN regulations developed
with the consensus of the EU, shall be
referenced in the Implementing Regulations.
6. Adopting appropriate verification
procedures for conformity of production
(CoP), in-service conformity (ISC) and
market surveillance (MaS).345
Enhancing the rules of CoP, ISC, and introduce
rules for MaS which were missing in Euro
6/VI, including the new role of testing by third
parties and the Commission.
A list of tests and actors responsibilities per
stage of type approval will be included in the
Annexes of the Regulation
Simplification of emission testing Reasoning
Cars and vans
1. Replacing the OBD, durability, and
crankcase tests at type-approval with OEM
declarations and checking them during
market surveillance. Repeal idle and
opacity tests as obsolete.346347
Simplifying test regime during initial type
approval by replacing tests with declarations
by the manufacturer that they comply with the
requirements. The compliance will be checked
during market surveillance checks. The idle
and opacity tests which were introduced for use
during periodical technical inspections were
proven not apt for recent vehicle technologies
and are repealed. Reflect this in the list of tests
(see point above).
2. Improved OBD provisions for malfunction
detection with appropriate OBD threshold
limits348
.349
Simplify and improve the OBD malfunction
detection capabilities that could be checked
also during market surveillance. For
341
Supporting simplification study, chapter 5.1.3 One introduction date
342
Supporting simplification study, chapter 5.1.4 Strengthening MIL (S-MIL)
343
Regulation No 83 of the Economic Commission for Europe of the United Nations (UN/ECE) —
Uniform provisions concerning the approval of vehicles with regard to the emission of pollutants according
to engine fuel requirements; Regulation No 49 of the Economic Commission for Europe of the United
Nations (UN/ECE) — Uniform provisions concerning the measures to be taken against the emission of
gaseous and particulate pollutants from compression-ignition engines and positive ignition engines for use
in vehicles
344
Supporting simplification study, chapter 5.1.8 Alignment of EU and UNECE regulations
345
Supporting simplification study, chapter 5.1.9 Alignment of CoP, ISC, MaS framework
346
Supporting simplification study, chapter 5.1.6 Idle emissions, smoke opacity, crankcase emissions and
OCE; chapter 5.1.7 Durability testing
347
Supporting simplification study, chapter 5.2.1 Testing requirements overview
348
In-use performance ratios (IUPR) currently give an idea of how often the conditions subject to
monitoring occurred and how frequent the monitoring intervals occurred. For example, a minimum IUPR
of 0,1 would mean that there should be at least one monitoring event during 10 trips.
86
Implementing Regulations.
3. Substituting the laboratory-based ambient
temperature correction test at type-
approval and replace it with declared
temperature correction which may be
checked during market surveillance350
Analysis of CO2 between the ATCT at 14 °C
and WLTP test at 23 °C showed that the
difference between the two tests is minimal.
Therefore it is not considered cost effective to
repeat the ATCT test during type approval and
the OEM may declare a Temperature
correction. Such declaration may be checked
during market surveillance tests.
Lorries and buses
1. Shifting emphasis and emission limits to
on-road testing of vehicles and keeping
laboratory tests mainly for CO2
evaluation.351
The true compliance of a heavy duty vehicle
with emission limits will be checked during on-
road testing during all phases of type approval,
while laboratory tests of engines and
components will still be required mostly for the
determination of CO2.
2. Replacing type-approval testing by
declarations from the manufacturers for
OBD, durability, crankcase emissions, NOx
control operation and reagent freeze
protection, while testing them at Market
Surveillance.352
Simplifying test regime during initial type
approval by replacing tests with declarations
by the manufacturer that they comply with the
requirements. The compliance will be checked
during market surveillance checks.
3. Improving OBD provisions for
malfunction detection with appropriate
OBD threshold limits 353
Simplify and improve the OBD malfunction
detection capabilities that could be checked
also during market surveillance. For
Implementing Regulations.
Technology-neutral emission limits
Another important driver for complexity in the Euro 6/VI emission standards follows
from the fact that they are not technology-neutral. To tackle this, policy option 1 makes
the Euro 6/VI emission limits coherent over the different ICE technologies in order to
achieve technology-neutral limits (see Table 48). NH3 limit is extended to cars and vans
for the same reason it was already introduced for lorries and buses in Euro VI, i.e. to
control ammonia slip from the current generation of catalysts.
Table 48 – Technology-neutral emission limits in policy option 1354
Air pollutants
Cars Small vans Large vans
Lorries and
buses
(mg/km) (mg/km) (mg/km) (mg/kWh)
NOx 60 75 82 460
PM 4.5 4.5 4.5 10
PN>10nm (#/km) 6×1011
6×1011
6×1011
6×1011
CO 500 630 740 4 000
349
See footnote 342
350
Supporting simplification study, chapter 5.1.5 Low temperature testing and ATCT
351
Supporting simplification study, chapter 5.2.2 Euro 7 on-road testing
352
Supporting simplification study, chapter 5.1.6 Idle emissions, smoke opacity, crankcase emissions and
OCE; chapter 5.1.7 Durability testing, chapter 5.2.1 Testing requirements overview
353
See footnote 342
354
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
87
THC 100 130 160 660
NMHC 68 90 108 160
NH3 20 20 20 10 (ppm)
Evaporative
emissions
2 g/test (for
gasoline only)
2 g/test (for
gasoline only)
2 g/test (for
gasoline only)
-
While the value of the emission limits are not stricter than the limits included in the Euro
6/VI regulations, the fuel-related specificities have been removed and the same pollutants
are limited for all ICE vehicles. Hence, also the problem of untapped and lacking vehicle
pollutant limits is partially addressed through this action. For example, option 1
introduces a common NOx emission limit of 60 mg/km for all cars. This replaces the
current NOx limits of 60 mg/km for petrol cars and 80 mg/km for diesel cars. NH3 and
CH4 limits are not only used for lorries and buses but also for cars and vans, as emission
control technologies that are necessary to comply with NOx emission limits may cause a
so-called ammonia slip due to excessive dosing of urea355
and CH4 may be emitted by
gaseous-fuelled vehicles. The threshold for particle numbers (PN) is lowered from 23 nm
to 10 nm, in line with the international work at UN level356
. Evaporative emissions
remain as today.
Extended real-driving testing
The measures aim at refining and simplifying the emission testing (see Table 47) by
moving towards extended real-driving testing with low ambition. Policy option 1 allows
testing of vehicles beyond the normal Euro 6 d RDE and Euro VI E PEMS conditions, as
presented in Table . No conformity factor is foreseen for this option as PEMS were
already assessed to measure accurately at these levels. For conditions that extend beyond
current RDE/PEMS, as depicted in Table 49, an emissions cap of 4× the emission limits
defined in Table will apply for both light-duty and heavy-duty vehicles. Implications for
what concerns vehicle technologies needed can be found in section 1.3.1 in Annex 4.
Table 49 – Normal and extended real-driving testing conditions in policy option 1 (low
ambition boundaries)354
Parameter Normal driving conditions Extended driving conditions
Cars and vans
Emission Limit
Multiplier
- 4 (applies once and only for the
period when any of the conditions
below apply)
Ambient temperature -7°C to 35°C -10°C to -7°C or 35°C to 45°C
Maximum speed Up to 145 km/h Between 145 km/h and 160 km/h
Trip characteristics
Any trip longer than 10 km
v×apos [95th
[W/kg] As in current RDE Outside current RDE
Towing, aerodynamic
modifications
Not allowed Allowed
Auxiliaries use Possible as per normal use -
355
Heeb et al. 2005. Three-way catalyst-induced formation of ammonia—velocity- and acceleration-
dependent emission factors
356
UNECE, 2020. 81st
session Informal Documents: GRPE-81-10 Revisions to
ECE/TRANS/WP.29/GRPE/2020/14: sub 23nm PN measurements, GRPE-81-11 of UN29:
Clarification of points regarding “UN Regulation WLTP“
88
Maximum altitude Up to 1 300 m From 1 300 to 1 600 m
Positive elevation gain No limitation -
Minimum mileage 10 000 km
Lorries and buses
Emission Limit
Multiplier
1 3 (applies once and only for the period
when any of the conditions below apply)
Ambient temperature -7°C to 35°C -10°C to -7°C or 35°C to 45°C
Cold start
Test evaluation from engine start on; no
weighting of cold start
-
Auxiliaries Possible as per normal use -
Minimum trip duration More than 4 WHTC Between 3 and 4 WHTC
Evaluation (MAW
357
) 1x WHTC window -
Engine loading All -
Payload Between 10% and 100% Less than 10%
Maximum altitude Up to 1 300 m From 1 300 to 1 600 m
Minimum mileage 10 000 km -
Trip characteristics Any -
6.2. Policy option 2: Medium and High Green Ambition
Policy option 2 implies a wider revision of Euro 6/VI emission standards with high
ambition to tackle the increasing complexity of the vehicle emission standards (problem
1) and to address untapped and lacking vehicle pollutant limits (problem 2) and medium
ambition to address insufficient control of vehicle real-driving emissions (problem 3).
Policy option 2 builds on the same simplification measures as option 1 to reduce
complexity of the Euro 6/VI emission standards. In addition, two stringency levels of
stricter pollutant emission limits (called medium ambition and high ambition emission
limits) are considered, to provide up-to-date limits for all relevant air pollutants.
Similarly, two sets of extended real-driving testing are considered in policy options 2
(called medium ambition and high ambition boundary conditions) to control real-driving
emissions throughout the vehicles’ lifetime and in almost all conditions of use.
Simplification measures
Policy option 2 considers the same simplification measures as policy option 1, to
simplify the legislative architecture and the emission testing (see Table 47) and to
propose technology-neutral limits coherent over the different ICE technologies.
Medium and high ambition stricter emission limits
Policy option 2 considers two possible sub-options of stricter emission limits to take into
account two levels of technological possibilities for achieving such emission levels and
the related investment costs for vehicle manufacturers and component suppliers. Policy
option 2a – Medium Green Ambition - considers strict air pollutant emission limits based
on currently available emission control technologies; policy option 2b – High Green
Ambition - considers more stringent air pollutant emission limits based on best available
emission control technologies (see Table 50 and Table 51).
357
Under the moving average window (MAW) method, the mass emissions are calculated for subsets of
complete data sets, called windows. The window size is defined by the work over the window which must
be equal to the work produced during the engine certification cycle. (WHTC).
89
Policy option 2a includes a reduction of the NOx limit for cars to 30 mg/km and for
underpowered358
vans to 45 mg/km. This is because vehicles with low power to mass
ratio, while needed for some applications, cannot handle emissions with the same
effectiveness as the normally powered vehicles. For lorries and buses the need to control
both cold and hot emissions leads to two limits expressed in mg/kWh (see Table 50).
This policy option also lowers all other pollutants regulated in Euro 6/VI (PM, PN, CO,
THC, NMHC, NH3, CH4) and introduces new ones (N2O, HCHO and brake emissions).
HCHO, CH4 and N2O emission limits are set at the level of today’s emissions (i.e. a cap
on emissions) to ensure that these emissions do not disproportionately increase beyond
today’s level with the introduction of new CO2 limits or new emission control
technologies in future vehicles or with new fuels but no new emission control technology
is required or foreseen.
For evaporative emissions, the diurnal emission limits are strengthened, while a limit is
also set for refuelling emissions. These reductions are achievable by emission control
technology available already in the market today359
, which is described in Table 21, and
addresses the problem driver of not exhaustive use of technological potential for reducing
emissions.
Table 50 – Strict emission limits in policy option 2a and 3a based on available emission
control technology359
Air pollutants
Cars and vans
Large vans if
underpowered
Lorries and
buses
Cold emissions360
Lorries and
buses
Hot
emissions361
(mg/km) (mg/km) (mg/kWh) (mg/kWh)
NOx 30 45 350 90
PM 2 2 12 8
PN>10nm (#/km) 1×1011
1x1011
5x1011
1x1011
CO 400 600 3 500 200
NMOG 45 45 200 50
NH3 10 10 65 65
CH4+ N2O 45 55 660 410
HCHO 5 10 30 30
Evaporative emissions362
0.5 g/worst day
+ ORVR363
0.7 g/worst day +
ORVR
-
-
Brake emissions 7 7 Review Review
Tyre emissions Review Review Review Review
Battery durability364
70% 70% Review Review
Policy option 2b includes a reduction of the Euro 6/VI limit for cars to even lower values
(see Table 51). These reductions can be achieved only by integrating best available
emission control technologies in the vehicle and related hardware and R&D costs for
358
Large vans with power to test mass ratio less than 35 kW/t
359
CLOVE, 2022. Technical studies for the development of Euro7: Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5
360
Expressed as 100% of MAW
361
Expressed as 90% of MAW
362
With random preconditioning at any temperature up to 38 °C
363
ORVR stands for “On-board Refuelling Vapour Recovery” and is a limit designed to avoid emissions
during the refuelling of the vehicles. Limit to be set at 0.05 g/L.
364
Expressed as Battery Energy Based. To be reviewed for lorries and buses and for inclusion of range
metric.
90
technology system integration and calibration365
.
Table 51 - Stricter emission limits in policy option 2b based on best available emission
control technology359
Air pollutants
Cars and vans
Large vans if
underpowered
Lorries and
buses Cold
emissions
Lorries and
buses
Hot Emissions
(mg/km) (mg/km) (mg/kWh) (mg/kWh)
NOx 20 30 175 90
PM 2 2 12 8
PN>10nm (#/km) 1×1011
1×1011
5x1011
1x1011
CO 400 600 1 500 200
NMOG 25 25 150 50
NH3 10 10 65 65
CH4+ N2O 20 25 660 410
HCHO 5 10 30 30
Evaporative
emissions
0.3 g/worst
diurnal test +
ORVR
0.5 g/worst
diurnal test +
ORVR
- -
Brake emissions 5 5 Review Review
Tyre emissions Review Review Review Review
Battery
Durability
80% 80% Review
Review
Both sub-options include limits for two not yet regulated exhaust emissions that are of
concern today: nitrous oxide (N2O) and formaldehyde (HCHO). High N2O emissions
have been observed on gasoline vehicles equipped with three-way catalysts, while
HCHO is a toxic and carcinogenic substance affecting human health which is released
through the combustion process and becomes increasingly relevant as gasoline vehicles
and higher ethanol content (E10) are gaining momentum.366
Since the emission limits
proposed for NOx are considered sufficiently low to also restrict emissions of nitrogen
dioxide (NO2), regardless of their relative proportion within the NOx group, policy option
2 does not include a separate limit for this pollutant.367
In addition to exhaust and evaporative emissions, both scenarios in option 2 introduce
limits for brake emissions368
. Brake wear has been recognized as the leading source of
non-exhaust particles which are harmful to human health and the environment and
emitted by all type of vehicles. A method and protocol is currently under development in
the UN.369
Progress has been made in developing a measurement method and protocol
365
See footnote 359
366
CLOVE 2022.Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3. 5.3.1.4 Do the standards properly
cover all relevant/important types of pollutant emissions from vehicles that pose a concern to air quality
and human health? Are there important types of pollutant emissions that are not covered?
367
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 4.4.3 Policy Option
2: Improved air pollutant limits and advanced tests for cars, vans, lorries and buses in addition to policy
option 1.
368
Next to brake emissions, tyre emissions are found to be a source of non-exhaust emissions as they
contribute to the formation of PM and PN. As it is not yet technologically feasible to develop limits or tests
for tyre emissions, they cannot be assessed in this impact assessment and it is suggested to include a review
clause in Euro 7.
369
UNECE, 2021. UNECE to develop global methodology to measure particle emissions from vehicles’
braking systems
91
for cars and vans370
, while the technologies to decrease brake emissions are already in the
market or close to becoming commercial.371
While the brake emission limits in sub-
option 2a can be realised using better brake pad material, the limits in sub-option 2b also
requires additionally a brake filter for the collection of the brake wear particles
produced.372
Brake emissions from heavy-duty vehicles will only be limited at a second
phase when the methodology is extended to cover them as well.
Medium and high ambition real-driving testing boundaries
While emission limit sub-options are assumed to be complied with under normal driving
conditions, a multiplier is needed in order to comply with the extended conditions of use
in policy option 2. Where policy option 1 introduced a set of low ambition extended
driving conditions, sub-option 2a and 2b are assumed to be complied with under a set of
medium and high ambition extended driving conditions respectively. Hence, the more
demanding conditions for the engine are taken into account (see Table 52 and Table 53).
Furthermore, a cap is imposed by a maximum budget of pollutants allowed on trips that
are smaller than a certain threshold required for the assessment to be made thoroughly
(enough data need to be collected for a thorough assessment). In this manner, all possible
trips are covered by a limit.
Policy option 2 will further expand the testing conditions of policy option 1, while policy
options 2b will cover almost all real-driving testing conditions. This action addresses the
driver of limited representativeness of on-road tests covering normal conditions of use.
The sub-options for stricter emission limits presented in Table 50 and Table 51 are
assumed to apply to the new normal driving conditions and extended driving conditions
as presented in Table 52 and Table 53 respectively. The tables illustrate that several
boundaries have been extended to cover more demanding normal circumstances for the
vehicle which may result in significantly higher emissions, without however allowing for
completely free and unbounded driving but limiting the conditions to those necessary to
cover the widest part of driving under European conditions. A further extension of the
testing conditions is designed to cover an even great part of the conditions of use,
approaching full coverage of all relevant European conditions in policy option 2b.
For extended driving conditions an emission limit multiplier will be used to account for
the harder conditions put on the engine and emission control system. The effect of such
an emission limit multiplier is limited since it is only applied in rare occasions.
Furthermore, the emission multiplier proposed here is milder than the one proposed in
the CLOVE study, due to the fact that the boundaries are also milder compared to the
CLOVE study and completely free driving is not allowed.
The ambient temperature conditions have been lowered to -10 °C and the maximum
altitude to 2 000 m in option 2a and to 2 200 m in option 2b in order to cover the highest
road elevations in Europe. As another example Figure 22 in Annex 5 illustrates how low-
speed driving, which is not covered in the Euro 6d RDE tests, has been linked to high
pollutant emissions.373
The Euro 6/VI average speed boundary conditions (see Table )
have therefore been removed. Implications for what concerns vehicle technologies
370
A measurement method for brake emissions from lorries and buses is not developed yet. It is suggested
to include a review clause in Euro 7.
371
See footnote 367
372
Supporting Euro 7 impact assessment study, Annex I, section 9.5 Cost modelling
373
See Annex 5: Evaluation Euro 6/VI emission standards, Figure 16 – Emission performance of Euro 6d
vehicles for NOx for different average speeds, based on CLOVE, 2022
92
needed can be found in Table 21.
Table 52 – Comprehensive real-driving conditions in policy option 2a and policy option
3a, in normal and extended driving conditions (medium ambition boundaries)374
Parameter Normal driving conditions Extended driving conditions
Cars and vans
Emission Limit
Multiplier
1 2 (applies once and only for the period
when one of the conditions below
apply)
Ambient temperature -7°C to 35°C -10°C to -7°C or 35°C to 45°C
Maximum speed Up to 145 km/h Between 145 km/h and 160 km/h
Trip characteristics
Any trip, normal limits for tests
longer than 10 km (budget approach
for trips less than 10 km)
-
v×apos [95th
[W/kg]
As in RDE Any condition but extreme driving is
prohibited
Towing, aerodynamic
modifications
Not allowed Allowed according to specification of
OEM and up to the regulated speed
Auxiliaries use Possible as per normal use -
Maximum altitude Up to 1 300 m From 1 300 to 1 800 m
Positive elevation gain No limitation -
Minimum mileage 10 000 km Between 3 000 km and 10 000 km
Lorries and buses
Emission Limit
Multiplier
1 2 (applies once and only for the period
when one of the conditions below apply)
Ambient temperature -7°C to 35°C -10°C to -7°C or 35°C to 45°C
Cold start
Test evaluation from engine start on; no
weighting of cold start
-
Auxiliaries Possible as per normal use -
Minimum trip duration Any (for MAW evaluation 4× WHTC) -
Evaluation (MAW
375
) 1x WHTC window -
Engine loading All -
Payload Higher than or equal to 10% Less than 10%
Maximum altitude Up to 1 600 m From 1 600 to 1 800m
Minimum mileage
5 000 km for <16t TPMLM
10 000 km for > 16t TPMLM
Between 3 000 km and 5 000 km for <16t
TPMLM
Between 3 000 km and 10 000 km for > 16t
TPMLM
Trip characteristics Any -
Table 53 – Comprehensive real-driving conditions in policy option 2b, in normal and
extended driving conditions (high ambition boundaries)374
Parameter Normal driving conditions Extended driving
conditions
374
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
375
Under the moving average window (MAW) method, the mass emissions are calculated for subsets of
complete data sets, called windows. The window size is defined by the work over the window which must
be equal to the work produced during the engine certification cycle. (WHTC).
93
Cars and vans
Emission Limit Multiplier
1 3 (applies once and only for the
period when any of the conditions
below apply)
Ambient temperature -7°C to 35°C -10°C to -7°C or 35°C to 45°C
Maximum speed Up to 160 km/h Above 160 km/h
Trip characteristics
Any trip, normal limits for tests
longer than 10 km
-
Towing, aerodynamic
modifications
Not allowed Allowed
Auxiliaries use Possible as per normal use -
Engine loading
Restriction for first 2 km Any condition but extreme driving
is prohibited
Maximum altitude Up to 1 600 m 2 200 m
Positive elevation gain No limitation -
Minimum mileage 3 000 km Between 300 km and 3 000 km
Lorries and buses
Emission Limit Multiplier
1 2 (applies once and only for the period
when any of the conditions below apply)
Ambient temperature -7°C to 35°C -10°C to -7°C or 35°C to 45°C
Cold start
Test evaluation from engine start on; no
weighting of cold start
-
Auxiliaries Possible as per normal use -
Minimum trip duration Any (for MAW evaluation 4× WHTC) Any (for MAW evaluation 4× WHTC)
Evaluation (MAW
376
) 1x WHTC window -
Engine loading All -
Payload Any -
Maximum altitude Up to 1 600 m From 1600 to 2 200m
Minimum mileage
3 000 km for <16t TPMLM
6 000 km for > 16t TPMLM
Between 300 km and 3 000 km for <16t
TPMLM
6 000 km for > 16t TPMLM
Trip characteristics Any -
Medium and high ambition durability, including security of emission control
systems and anti-tampering
Policy option 2 also considers the need to address inadequate durability provisions. In the
two sub-options and in policy option 3 the requirements to comply with the emission
limits for vehicles in use, i.e. the durability provisions, are extended from the current
inadequate period in Euro 6/VI. The Euro 6 durability provisions for cars which are
limited to 5 years or 100 000 km377
are extended to 10 years or 200 000 km, whichever
comes first in policy option 2a and 3a to reflect the average lifetime of vehicles in Europe
and extended further to 15 years or 240 000 km, whichever comes first in policy option
2b to reflect the maximum lifetime of vehicles in Europe378379
. Similarly ambitious
376
Under the moving average window (MAW) method, the mass emissions are calculated for subsets of
complete data sets, called windows. The window size is defined by the work over the window which must
be equal to the work produced during the engine certification cycle. (WHTC).
377
Or 160 000 km for checking the durability of the replacement emission control systems.
378
Supporting Euro 7 impact assessment study, chapter 4.4.3 Policy Option 2: Improved air pollutant limits
and advanced tests for cars, vans, lorries and buses in addition to policy option 1
379
ACEA, 2020. In 2020, passenger cars in use were on average 11.5 years old, vans 11.5 years, lorries 13
years and buses 11.7 years.
94
provisions are introduced for lorries and buses. In all cases, for the period of the extended
durability, i.e. between 160 000 km or 8 years and the periods in Table 55 below, a
durability multiplier shall be used to take into account the natural degradation of both the
emission control systems used for gaseous pollutants and the engine. This durability
multiplier is needed only for gaseous pollutants, because particle filters do not have
durability issues. They either work or fail, in which case they need to be replaced. The
new durability provisions can be seen in Table 54.
Table 54 – Durability provisions in policy option 2a, 3a and 2b380
Policy option 2a and 3a Policy option 2b
Cars and vans
Durability multiplier for gaseous
pollutants between 160 000 km/8
years and 200 000 km/10 years
Durability multiplier for gaseous
pollutants between 160 000 km/8
years and 240 000 km/15 years
Lorries and buses
Durability multiplier] for gaseous
pollutants
For N2, N3<16t, M3<7.5t:
between 300 000km and 375 000 km
N3>16t, M3>7.5t:
between 700 000 km and 875 000
km
Durability multiplier for gaseous
pollutants
For N2, N3<16t, M3<7.5t:
between 300 000km and 450 000 km
N3>16t, M3>7.5t:
between 700 000 km and 1 050 000
km
The requirement for increased durability means further reduction of excess emissions
created by older vehicles, but also helps to avoid the undesired effect of tampering of
older vehicles, i.e. removing or otherwise circumventing the emission control systems of
a vehicle. On top of the increased durability requirements, cybersecurity measures, such
as the ones recommended by the JRC381
and the European Parliament382
in their
respective reports, will be introduced as stronger requirements to protect the integrity of
the emission control systems.
A further improvement in terms of durability is adding provisions for the durability of
propulsion batteries of PHEVs and BEVs, according to the developments at UN level383
.
Such addition would not add any costs because the level of durability is currently set to
the level already achieved by the average (not the best) batteries of today and the costs
for the verification are already included in the other tests (i.e. no new test will be
required).
6.3. Policy option 3a: PO2a and Medium Digital Ambition
Policy option 3a implies a profound revision of Euro 6/VI emission standards with high
ambition to tackle the increasing complexity of the vehicle emission standards (problem
1), to address untapped and lacking vehicle pollutant limits (problem 2) and to address
insufficient control of vehicle real-driving emissions (problem 3).
380
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
381
JRC 2021 Technical Report: “Vehicles Odometer and Emission Control Systems - Digital Tampering
and Countermeasures”, Jose Luis Hernandez Ramos (JRC), L. Sportiello (JRC)
382
European Parliament, 2014-2019, P8_TA-PROV(2018)0235, European Parliament resolution of 31
May 2018 with recommendations to the Commission on odometer manipulation in motor vehicles: revision
of the EU legal framework
383
UN 2021. ECE/TRANS/WP.29/GRPE/2021/18 (IWG on EVE) Proposal for a new UN GTR on In-
Vehicle Battery Durability for Electrified Vehicles
95
Policy option 3a builds on the same simplification measures as option 1 to reduce
complexity of the Euro 6/VI emission standards and on more stringent air pollutant
emission limits and comprehensive real-driving conditions as policy option 2a to provide
appropriate and up-to-date limits for all relevant air pollutants. In addition, new
continuous emission monitoring of pollutants over the whole lifetime of the vehicle is
added, based on improved versions of available sensor technologies. Synergies with the
on-board fuel consumption meters (OBFCM) introduced under the CO2 emission
performance standards384
, in terms of reading and communicating the monitored
emission data, will be exploited.385
This option has the added benefit of further
simplifying and improving compliance controls for type approval and also allowing
future periodic technical inspections and roadworthiness tests to be performed online. A
prerequisite for the introduction of CEM is stronger cybersecurity measures, as those
described in the relevant JRC report386
. It is expected that such measures will already be
introduced under the baseline and therefore no cost will be necessary in this proposal.
Simplification measures
Option 3a considers the same simplification measures as option 1, to simplify the
legislative architecture and the emission testing (see Table 47).
Medium ambition stricter emission limits
Option 3a considers the same strict emission limits as option 2a (see Table 50). The
lowest emission limits of option 2b (see Table 51) are not considered since it is uncertain
whether the lowest emission limits can be reliably measured with on-board sensors
throughout the lifetime of vehicles.
Medium ambition real-driving testing boundaries
Policy option 3a considers the same real-driving testing conditions as option 2a, to cover
normal driving conditions and extended driving conditions (see Table 52).
Medium ambition durability, including security of emission control systems and
anti-tampering
This policy option considers the same durability provision as policy option 2a (see Table
54).
Continuous emission monitoring
384
Regulation (EU) 2019/631 setting CO2 emission performance standards for new passenger cars and for
new light commercial vehicles and Regulation (EU) 2019/1242 setting CO2 emission performance
standards for new heavy-duty vehicles both require in Article 12 that the Commission shall regularly
collect data on the real-world CO2 emissions and fuel or energy consumption of passenger cars, light
commercial vehicles and heavy-duty vehicles using on-board fuel and/or energy consumption monitoring
devices.
385
Regulation (EU) 2017/1151, supplementing Regulation (EC) No 715/2007 on type-approval of motor
vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6);
Regulation (EU) 2018/1832, amending Directive 2007/46/EC, Commission Regulation (EC) No 692/2008
and Commission Regulation (EU) 2017/1151 for the purpose of improving the emission type approval tests
and procedures for light passenger and commercial vehicles, including those for in-service conformity and
real-driving emissions and introducing devices for monitoring the consumption of fuel and electric energy,
implementing Regulation (EU) 2021/392 on the monitoring and reporting of data relating to CO2
emissions from passenger cars and light-commercial vehicles
386
JRC 2021 Technical Report: “Vehicles Odometer and Emission Control Systems - Digital Tampering
and Countermeasures”, Jose Luis Hernandez Ramos (JRC), L. Sportiello (JRC)
96
Option 3a introduces continuous monitoring of vehicle emission performance by means
of continuous emission monitoring (CEM) systems. The CEM system make use of
sensors installed inside the vehicles to measure or assess tailpipe emissions continuously.
The use of CEM will improve compliance checks of vehicles types and may additionally
provide a strong instrument to detect and therefore deter from tampering, especially if
linked with appropriate cybersecurity measures387388
. Additionally, CEM may be used as
a virtual periodic technical inspection/roadworthiness tool, to complement, or eventually
substitute the need for yearly inspections.
CEM further provides a very handy tool for market surveillance authorities that could
check thousands of emission data without direct access to the vehicles leading to further
simplification of the emission type approval and prioritisation of tests to vehicle types
that exhibit higher emission profiles. This leads to further savings in regulatory costs. For
purposes of checking the compliance of vehicles against the emission requirements,
detailed data of the vehicle owner, identification or geolocation will not be needed or
acquired, in full respect of GDPR rules. For the purposes of vehicle type approval and
market surveillance, the strength of this system lies in reading thousands of data from all
vehicles belonging to the same type.
Policy option 3a is based on sensors which are commercially available today and could
be introduced for NOx, NH3 and partly PM based on communication functionalities
already installed on vehicles due to the OBFCM requirements (see Table 55). It also
considers the possibility of geo-fencing that puts a vehicle automatically into zero-
emission mode when entering zero-emission zones, such as cities, although no impacts
can be assessed in regards to this option.
Table 55 – Continuous emission monitoring in policy option 3a based on available
sensor technologies389
Element CEM for cars, vans, lorries and buses
Pollutants CEM
NOx and NH3 sensors: Monitoring of emission performance and identification of
malfunctions of emission control systems.
PM sensors: Filter diagnostics (no PM measurement)
Communication
platform
Based on OBFCM protocol that brings data storage and data communication functionalities
to the vehicle and intermittent signal transmission with no transmission of personal data.
Functionalities
1. Limits exceedances via MIL and limp/mode and inducement strategy to enforce repairs
2. Enhanced malfunction detection over OBD
3. Information available to authorities for ISC/MaS testing (potential future access also for
purposes of PTI and roadworthiness and tampering detection)
4. Engine feedback to adjust emission control system performance (real-time calibration)
5. Possibility of enforcement of geo-fencing for zero emission mode for plugin vehicles
387
CLEPA, 2021. CLEPA recommendations for Euro 7/VII, Statement on on-board monitoring during
AGVES meeting of 24 February 2021
388
Supporting Euro 7 impact assessment study, chapter 5.3.1. Environmental impacts
389
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
97
Annex 7: Impact of the COVID-19 crisis in automotive
industry on policy options
The COVID-19 pandemic has heavily impacted the automotive sector world-wide,
posing unprecedented challenges for the industry as a whole. In EU-27, registration of
new passenger and commercial vehicles dropped by respectively by -23.7% and -18.9%,
with a trend following the GDP curve in the European Union (see Figure 25), which
shows that a close correlation between GDP and car registrations over the period in the
EU, contrary to what happened during the previous 2008-2009 crisis with average GDP
decline: -6.43% over 2020 in EU-27)390
. For passenger cars, 9.9 million units were sold
in 2020, which represents a drop of 3 million units compared to 2019391
: For commercial
cars, 1.7 million units were sold over the same period (i.e. 401 000 units less).
Figure 25 - New passenger cars and GDP growth in the EU 2008-2021 (source: ACEA,
IHS Markit, and European Commission DG ECFIN retrieved from ACEA)392
This has to be placed in the broader context of the economic crisis worldwide both from
the demand- and supply-side perspectives. The automotive market weighs heavily on
global manufacturing and on economies with a high exposure to this sector.
The global GDP has contracted by 3.3% in 2020.393
After an unprecedented sudden
shock in the first half of 2020, the economy has recovered gradually in the third quarter
as containment measures relaxed, allowing businesses and household spending to
resume. Still, the global GDP in the second quarter of 2020, was 10% lower than at the
end of 2019, which was immediately reflected in car sales globally.
Global sales of vehicles have fallen under 77 million units in 2020, down from 89.7
million units in 2019 with a previous peak of 94.3 million units in 2017 following 10
years of continuous growth (in 2020, 17.3 million less vehicles have been sold and 15
390
Eurostat, 2021. Newsrelease Euroindicators: GDP down by 0.7% in the euro area and by 0.5% in the
EU (17/2021 – 2 February 2021).
391
ACEA, 2021. Passenger car registrations: -23.7% in 2020; -3.3% in December
392
ACEA, 2020 31 December. Available at https://twitter.com/acea_eu/status/1344629151916040195
393
WEO IMF April 2021 p.7 , i.e. 1.1% smaller than projected in October 2020 – Also estimated
contraction of real global GDP (excluding the EU ) by -3.4% and in the EU by -6.3% (European Economic
Forecast Winter 2021 (interim)) – Institutional Paper 144 February 2021
98
million units less have been produced compared to 2019)394.
.
The impact on sales and recovery pace differed for each key regional bloc and
automotive market, respectively in China, Europe and the USA - as reflected in Figure 26
below -, also depending on the disease progression, overall sanitary situation and of the
status and level of lockdown measures.
Figure 26 - Monthly sales in 2020 (% change, Yoy) vs. GDP growth forecast in China,
Europe and USA (source: BCG)395
The EU economy contracted by 6.3% in 2020396
economic forecast projecting growth of
3.7% in 2021 and 3.9% in 2022397
. All economic aggregates have been significantly
impacted by the pandemic evolution and the containment measures with a direct effect on
the automotive industry: for instance, a decline in consumer spending was foreseen in
May 2020, up to 40% -50%, with numerous second- and third- order effects398
. Besides
decreasing sales and demand, this resulted in massive losses, liquidity shortages and
changes in customers’ behaviours. This was compounded by the already rapidly
394
IHS Markit, 2020. Daily Global Market Summary - 31 December 2020
395
BCG, 2020. COVID-19’s Impact on the Automotive Industry
396
European Commission, 2021. European Economic Forecast – Winter 2021 (Interim) – European
Commission Institutional Paper 144 February 2021
397
European Commission, 2021. European Economic Forecast – Winter 2021 (Interim) – European
Commission Institutional Paper 144 February 2021
398
Mc Kinsey, 2020. The-impact-of-COVID-19-on-future-mobility-solutions
99
advancing technology shift in a competitive environment which required significant
investment and strategic realignments.
In the EU, the economic consequences materialised through three main channels. First,
the partial or full shut down of entire sectors due to the measures put in place to contain
contagion has severely disrupted service sectors, including transport and mobility.
Second, such disruptions also affected production and distribution activities and the
access to extra-EU supply chains. Third, the consequent loss of income led to
diminishing demand. Mobility patterns and customers behaviours have been also
significantly modified in the long run.
Impact on transport services –As a consequence of global lockdown measures due to
the Covid-19 crisis, mobility fell by an unprecedented amount in the first half of 2020399
.
Road transport in regions with lockdowns in place dropped between 50% and 75%, with
global average road transport activity almost falling to 50% of the 2019 level by the end
of March 2020. Immediately after the crisis outbreak, public-transit ridership has fallen
70 to 90% in major cities across the world, and operations have been significantly
impacted by uncertainty and strict hygiene protocols—such as compulsory face masks
and health checks for passengers or restricting the number of riders in trains and stations
to comply with space requirements. Ride hailers have also experienced declines of up to
60 to 70%, and many micro-mobility and carpooling players have suspended their
services. As well, fleet leasing and car rental have been hit harder than most by the travel
bans to stem the spread of Covid-19.
Road freight transport has been significantly and negatively impacted by the epidemic
outbreak, at global level and in Europe in particular. Sales in the land transport sector
(which also includes freight and passenger rail transport in addition to road transport) in
the EU and other Western European countries contracted by 10.3% in 2020, in real
terms400
. The greatest disruption occurred during the first wave of the pandemic in spring
2020 but the sector recovered from the summer, with the lifting of border closures and
the return of business activity and household consumption. However, the activity
underwent another slowdown as the virus spread for a second time and many countries in
the region were forced to implement new guidelines, partially closing economies once
more. The impact through the year was greater for international than for domestic
transport. A difference according to the transported products can also be observed, with
the trade in pharma and ICT products having remained significant through last year. As
an exception, e-commerce and last-mile delivery have increased, which seems to
correspond to a long term trend.
Standstill in production and supply disruption – The impact of the COVID-19 crisis
has been sudden and universal. For Original Equipment Manufacturers (OEM), initial
concerns over a disruption in Chinese parts exports quickly pivoted to large-scale
manufacturing interruptions across Europe. Global production stopped and the supply
chain was critically disrupted. The most immediate and visible effect in the traditional
399
Compared to the period between 3 January and 6 February 2020 - before the outbreak of the pandemic
in Europe - average mobility in the EU was about 17% lower in the fourth quarter of 2020, and declined
further (to -26%) in January 2021. This compares to -25% and -9% on average in the second and third
quarters of 2020, respectively. See: European Commission, 2021. European Economic Forecast – Winter
2021 (Interim) – European Commission Institutional Paper 144 February 2021 – also Google Mobility
Index and Finish Ministry of Finance, 2021. Economic Effects of the COVID-19 Pandemic – Evidence
from Panel Data in the EU Discussion papers
400
See footnote 394
100
automotive sector was subsequently the standstill of many OEM and supplier factories.
The COVID-19 pandemic has had a severe impact on Europe’s vehicle manufacturing
sector401
. During the first half of 2020 alone, EU-wide production losses (cars and vans)
due to COVID-19 amounted to 3.6 million vehicles402
, worth around €100 billion and
around 20% of the total production in 2019. These losses were the result of both factory
shutdowns (especially during the 'lockdown' months of March, April and May) and the
fact that production capacity did not return to pre-crisis levels once the lockdown
measures have been eased403
.
Approximately, 24 million less vehicles are expected to be produced globally between
2020 and 2022.404
The industry would thus be hit two times harder by the coronavirus
pandemic than during the 2008-2009 financial crisis: indeed, benchmarked against pre-
COVID 19 forecasts made in January 2020, COVID-19 led to over 12 million units of
losses.
At the height of the crisis, over 90 percent of the factories in China, Europe, and North
America closed. With the stock market and vehicle sales plummeting, automakers and
suppliers have laid off workers or relied on public intervention, particularly short-time
work schemes and similar arrangements to support paying employees.
Several carmakers405
had to be bailed out due to liquidity problems. The massive use of
furlough schemes did not prevent the announcement of several plant closures/job
losses406
at manufacturer or supplier level.
Most factories and plants have reopened and relaunched production after the first
lockdown and have remained in operation.
Impact on demand – The sanitary COVID-19 crisis also had a direct impact on
consumer demand and distribution channels. The exogenous shock of the pandemic has
indeed exacerbated the already present downshift in the global demand. Dealers were
subject to regulations imposing an immediate closure of showrooms and retail network.
For customers, the impact was multifaceted as people, facing financial uncertainty,
reduced their purchasing, stayed home and postponed major investments. The confidence
indicator of the Transport-Mobility-Automotive Ecosystem was one of the most hit407
amongst all EU Industrial Ecosystems. Significantly the purchase intent for both new
cars and used cars remains low across all countries in the Union, with the least impact in
France (e.g. new car purchase intent decrease by -11% (France), -21% (Germany) and -
25% (Italy) compared to pre-COVID-19 crisis intent whereas used car purchase intent
decreased respectively by 11% (France), -31% (Germany) and -28% (Italy)). There was
still a positive net impact in maintenance and repair.
401
SWD (2020) 98 final, Commission Staff Working Document, Identifying Europe’s recovery needs
402
ACEA, 2021. Coronavirus / COVID-19
403
ACEA, 2020. Interactive map: COVID-19 impact on EU automobile production, first half of 2020
404
See footnote 394
405
FCA and Renault received state aid under the Temporary Framework to support the economy in the
context of the coronavirus outbreak.
406
Examples include plants operated by car manufacturers such as Nissan, Renault, Bridgestone,
Continental, etc.
407
SWD (2020) 98 final, Commission Staff Working Document, Identifying Europe’s recovery needs:
Chart 1 Confidence Indicator of EU industrial Ecosystems: Current and Expected Supply and Demand
Factors
101
Consequently, the automotive market, that was already on a downward trend, facing
structural challenges (CO2, pollutant emissions, electrification), was hard-hit and suffered
an unprecedented 23.7%408
decrease of passenger car sales in 2020. It is expected that
COVID-19 will negatively affect sales volumes for years to come.
In more details:
In April 2020 alone, vehicle sales in Europe dropped by 84% compared to the same
period in 2019. It also followed a decline of sales and production over the previous
period in 2019-2018: car sales had seen their steepest year-over-year decline in 2019 (-
4%)409
since the 2008/2009 Financial Crisis as consumer demand from the U.S. to China
softened.
- Passenger Cars: Demand for new vehicles slumped during the peak of the crisis, with
new registrations of passenger cars down 32% in the first 8 months of 2020 compared to
the previous year410
.
Figure 27 - New passenger car registrations in the EU 2020 vs. 2019 (monthly
registrations – source: ACEA)411
Spain posted the sharpest drop (-32.3%), followed closely by Italy (-27.9%) and France
(-25.5%), while full-year losses were significant but less pronounced in Germany (-
19.1%).
Despite uncertainties in the near term, demand still showed some signs of recovery after
the summer 2020, with new registrations higher in September by 3.1% (cars) and 13.3%
(vans) compared to 2019. New car registrations in Germany, EU’s largest market, were
8.4% above levels of September 2019412
, with impressive growth in all electrified
408
See footnote 391
409
See footnote 394
410
ACEA, 2020. Passenger car registrations: -32.0% eight months into 2020; -5.7% in July and -18.9% in
August
411
See footnote 410
412
KBA, 2020. Pressemitteilung Nr. 23/2020 - Fahrzeugzulassungen im September 2020
102
segments, thanks in particular to government stimulation measures aimed at electric and
hybrid vehicles. However, demand declined again in October, with EU-wide registrations
down 7.8% in October. New restrictions put in place in several EU countries in autumn
2020, due to the resurgence of the virus, put the recovery of economies under question.
The downwards trend continued for the whole October- December period despite
incentives and recovery packages: in December, high, double-digit losses were seen in
countries such as France (down 11.8%), Italy (down 14.7%), Portugal (down 19.6%).
Germany showed the best performance, with a solid gain of 9.9%, followed by Spain,
with a tiny loss of 0.01%.
All other segments have been impacted with un-even performances and recovery trends
from one EU Member State to the other:
- New light commercial vehicles (LCV) up to 3.5t: From January to December 2020,
new van registrations declined by 17.6% across the European Union, standing at 1.4
million units. Spain recorded the sharpest drop (-26.5%) so far this year, while losses
were less strong in France (-16.1%), Italy (-15.0%) and Germany (-12.2%).
In November, demand for new light commercial vehicles in the EU remained stable (-
0.5%) compared to same period in 2019, whereas it weakened in December 2020
compared to December 2019 (-6%). Results in the EU’s top four markets were mixed: in
November 2020, registrations in Italy and Germany were positive, growing by 10.3%
and 6.2% respectively, while LCV demand contracted in Spain (-8.1%) and France (-
3.8%). In December 2020, registrations fell by 10.4% and 2.3% respectively in Italy and
France, while Germany (+2.5%) and Spain (+1.6%) recorded modest gains.
- New heavy commercial vehicles (HCV) of 16t and over: all through 2020, 198 352
new heavy commercial vehicles were registered across the European Union, a decline of
27.3% compared to 2019. Despite the 2 last months’ positive performance, each of the 27
EU markets recorded double-digit drops so far this year, including Germany (-26%),
France (-25.8%) and Spain (-22.1%).
The two last months of the year showed positive results: in November 2020 alone, the
EU market for heavy lorries improved, with new registrations up by 6.0% to 20.620
units. Central European countries (+28.6%) largely contributed to this result. Among the
largest Western European markets however, only Italy (+28.5%) managed to post
growth. During the month of December, 16 839 new heavy commercial vehicles were
registered across the EU, a year-on-year rise of 11.8%. Central European markets
continued to provide a strong boost to this growth; Poland, one of the leading markets,
saw a 48.4% increase in heavy-lorry registrations in December 2020. Among the largest
Western European markets, Germany also made a sizeable contribution (+27.4%),
followed by Spain (+8.3%) and France (+2.6%).
- New medium and heavy commercial vehicles (MHCV) over 3,5t: 2020, registrations
of new lorries declined sharply across the European Union including in the four major
markets: France (-24.1%), Germany (-24.0%), Spain (-21.7%) and Italy (-14.0%). This
contributed to a cumulative decline of 25.7% to a total of 247 499 lorries registered in
2020.
In December 2020, demand for new medium and heavy lorries posted a solid growth
(+7.1%) following a modest upturn (+3.7%) in November 2020, benefiting from the
positive performance of the heavy-duty segment (which makes up the bulk of total lorry
demand). As for the biggest EU markets, Germany saw the highest percentage growth
103
(+12.3%), followed by Spain (+3.8%) and France (+2.9%). By contrast, MHCV
registrations slid fell slightly in Italy (-1.8%).
- New medium and heavy buses & coaches (MHBC) over 3,5t: from January to
December 2020, EU demand for buses and coaches contracted by 20.3%, counting
29 147 new registrations in total. Among the largest EU markets, Spain (-35.9%) and
Italy (-24.9%) ended the year in negative, while losses were more limited in France (-
10.8%) and Germany posted a slight growth over the same period (+0.4%).
In December 2020, new bus and coach registrations in the EU increased by 13.4%
compared to December 2019. With the exception of France (-20.9%), all major EU
markets gave a significant boost to the overall performance of the region: Italy (+13,4%),
Germany (+22.1%) and Spain (+60.9%) in particular.
Impact of Incentives and recovery packages - Member States and the Commission
announced a series of measures to support the economic recovery of the private sector,
including the automotive segment. Noticeably, the recession was finally not as deep as
expected in 2020413
despite reintroduction and tightening of containment measures by
Member States in response to the 2nd
wave. Stimulus packages and recovery measures
have also been instrumental for attenuating the recession.
Lessons have been learned from the 2008-2009 crisis in this respect414
: electric vehicle
targeted measures have been designed in countries such as Austria, France, Germany,
Greece, Italy, Romania and in the Netherlands whereas other measures already in place
and targeting also clean vehicles (e.g. bonus malus in Sweden) have been continued.
They were all cornerstones of the respective demand stimulus packages, aimed at
stimulating the recovery of the automotive sector, in particular through demand and
supply of zero and low emission vehicles and recharging infrastructure.
These measures may have contributed to avoiding steeper drops in demand of vehicles in
the EU: indeed, contrary to other markets, the electric passenger car markets in Europe
has not collapsed since the outbreak of the COVID-19 pandemic. On the contrary, in
March and April when mobility was most limited in many European countries, electric
vehicles still recorded high registration shares, up to 12% in France and Italy, as shown
in the Figure below. Even with fluctuations over 2020, electric passenger car
registrations recorded all-time highs.
Up to the end of May, before the introduction of the first recovery packages, this was
likely partially a result of more favourable taxes or cost benefits for electric vehicles in
markets. After June 2020, electric passenger car shares have rebounded the most in
France and Germany after a slight downfall since April 2020. Both countries introduced
recovery packages for electric car purchases in June, which had a positive effect on
consumer choices. There seems to be similar effects with the Spain’s program MOVES II
introduced in June 2020 as well as with the stimulus packages in Austria, Spain
(RENOVE 2020 Program), and Italy, introduced after June 2020, as well as in other EU
Member States having introduced similar measures (Greece, the Netherlands, Romania -
see Figure below).
413
European Commission, 2021. Press release: Winter 2021 Economic Forecast: A challenging winter, but
light at the end of the tunnel
414
International Council on Clean Transportation, 2020. Briefing: Green vehicle replacement programs as
a response to the COVID-19 crisis: Lessons learned from past programs and guidelines for the future
104
Figure 28 - Electric Vehicle shares in the EU and EU Member States’ Recovery
packages (Summer 2020) (based on ACEA415
and EAFO416
)
Outlook and perspectives
Global new-vehicle sales will return to double- digit growth in 2021, but will fail to
recover fully417
. EU economy would barely return to pre-pandemic levels in 2022418
.
Figure 29 - New Vehicle Sales 2020-2021 (source: The Economist Intelligence Unit)419
415
ACEA, 2021. Consolidated registrations – by country
416
EAFO, 2021. Vehicles and fleet – passenger cars
417
The Economist Intelligence Unit, 2021. Industries in 2021
418
European Commission, 2021. European Economic Forecast – Winter 2021 (Interim)
419
See footnote 417
105
As regards new vehicle sales, a recovery of demand in the EU at the same level as 2019
is foreseen by 2023 only420
. It is anticipated that the unprecedented shift away from fossil
fuel vehicles, in favour of low- emission or electric vehicles will continue and that
Europe’s share of global Electric Vehicle market will keep increasing. Global Electric
Vehicle sales are expected to rise sharply in 2021, to around 3.4 million units, supported
by the above-mentioned generous government incentives, and new launches.
The Figure 30 below illustrates the perspectives of recovery respectively in China, USA
and Europe:
 A significant demand rebound was recorded in China already, with 2020
corresponding to 23.6 million units, down by 4.9% compared to 2019. 2021
forecast is set at 24.9 million units (+5.6% compared to 2020).421
 Despite adverse COVID-19 trends, the automotive demand should continue to
recover in the USA, supported by OEM and dealer incentives, online sales,
government stimulus and improving economics. A positive trend of demand
should continue in 2021 with a forecast of 16 million units for 2021 (+10%
compared to 2020). Risks remain, notably from weak fleet sales and tight
inventories; restocking efforts, which remain vulnerable to any further potential
virus restrictions.
 European recovery prospects are mixed, with worrying virus resurgences, varied
economic and stimulus support, ongoing restrictions and uncertainties as regards
the sanitary situation (potential third wave). It is anticipated that the Western and
Central European automotive demand for 2021 achieves 15.3 million units for
2021422
, with a 11% growth compared to 2020423
. Governmental support
measures should be maintained in the EU Member States with major automotive
markets (e.g. France, Germany, Italy, Spain).
Figure 30 - Sales forecast for China, EU and USA (2019-2025) (source BCG, IHS
Markit)424
420
See footnote 395
421
IHS, 2021. Financial Services Commentary and Analysis
422
See footnote 421
423
See footnote 421
424
See footnote 395
106
Impact on mobility patterns and behaviours
Many uncertainties also exist on how the COVID-19 crisis may affect future mobility,
from the capacity of governments and companies to promote transport electrification to
what consuming and behavioural changes could potentially be expected from it. The
long-lasting impact of the crisis may differ significantly though from other earlier crisis
circumstances, particularly 2008-2009 as the automotive industry was already facing
multiple huge transformations across global markets when hit by the pandemic outbreak.
Still, beside challenges and economic immediate downturn, the COVID-19 has
undoubtedly led to an acceleration of the twin transition in the automotive sectors and to
some positive outcome:
- There is evidence already that the current crisis will not slow down the
current ongoing move to electrification. On the contrary, industry and
technological innovation experts expect the crisis to become a catalyst for the
transformation. Experts anticipate that “the next two or three years will be weak
years for sales of still-prevalent ICE (internal combustion engine) vehicles on
traditional technology platforms.” And “demand for the current car line-up will
be sluggish due to economic impairments and, at the point demand recovers,
customers will return to a more favourable environment for xEVs (battery electric
and plug-in hybrid) and demand 2023/2024 state-of-the-art technology.”425
- Reinforced individual mobility: in the short term, the COVID-19 crisis has
raised the importance of safety and the sense of security for consumers. There is
thus anecdotal evidence that car ownership will remain very important for
individuals in a market which remains on the rise overall. On the other hand, long
lasting trends to be noted towards more flexible models of use, financing and
subscriptions of cars, and mobility, also with effects on automotive after-sales.
- Powertrain electrification: Demand and supply were already shifting towards
electric and electrified vehicles, driven by CO2 regulation and technological
progress, e.g., improved battery chemistry, increased range, high-performance
charging.
- Digitalisation of automotive sales and services: Consumer trends are changing
the way we buy and drive cars and consume mobility, e.g., connected cars,
assisted driving.
- e-Commerce. Widespread confinement has given a massive boost to e-commerce
and home deliveries. More people are shopping online, accelerating a pre-existing
long-term trend which should last.
425
Arthur D Little, 2020. Win the automotive COVID-19 rebound
107
- Last mile delivery and autonomous cargo transportation. Companies involved
in last mile delivery, which were quite active prior to the pandemic crisis, are set
to gain from the Retail, e-commerce and logistics companies should increase
investment in technologies and innovation. The positive impact of the crisis on
the long-term e-commerce trend should also drive more investment in
autonomous driving tech and complete solutions for goods deliveries, in
particular for last mile delivery.
- Customer experience and dealership tools. During this period there was a push
towards pure online sales and contactless deliveries. Customers will likely benefit
from less friction in the sales process. Customer behavioural shift towards more
online is expected to last, as it parallels other shopping experiences. Most dealers
and repair shops are trying to adapt extremely
- Push to cross-sectorial innovation towards smart and green
mobility. Combined with strengthened charging station infrastructure and
innovation in battery technologies, there will be opportunities for uptake of
advanced technologies and new entrant technologies and new entrant players with
new business models and consumers opportunities at stake (e.g. Vehicle to Grid,
Smart grids).
108
Annex 8: Alternative set of assumptions on emission limits and
durability
In the stakeholder consultations, automotive industry and civil society representatives
raised concerns and expressed divergent opinions regarding the emission limits, length of
the durability requirements and the technological potential for reducing emissions over
the lifetime of the vehicles. Emission limits and durability are in particular relevant for
air quality benefits. In addition to the different emission limits and durability assumed in
the policy options 1, 2a, 2b and 3a for low, medium and high green ambition (see Table 2
in chapter 5), two alternative set of assumptions were assessed to evaluate the effect of
changes in emission limits and of durability.
8.1 Alternative set of assumptions on emission limits
An alternative set of emission limits was developed (see Table 56). In this alternative
scenario, slightly less strict emission limits are assumed for NOx, PM, PN, CO, NMOG
and NH3, for light-duty vehicles as well as for heavy-duty vehicles when compared to the
medium ambition emission limits in policy option 2a (see Table 50). The conclusions
drawn for this alternative are valid also for PO3a, since PO3a is based on the same
emission limits as PO2a.
Table 56 – Alternative set of emission limits to Policy Option 2a based on available
emission control technology
Air pollutants
Cars and vans
Large vans if
underpowered
Lorries and
buses
Cold emissions426
Lorries and
buses
Hot
emissions427
(mg/km) (mg/km) (mg/kWh) (mg/kWh)
NOx 35 45 440 110
PM 3 3 12 8
PN>10nm (#/km) 3×1011
3x1011
9x1011
2x1011
CO 450 600 5 300 300
NMOG 50 50 225 56
NH3 15 15 80 80
CH4+ N2O 40 50 660 410
HCHO 5 10 30 30
Evaporative emissions428
0.5 g/worst day
+ ORVR429
0.7 g/worst day +
ORVR
-
-
Brake emissions 7 7 Review Review
Battery durability430
70% 70% Review Review
The environmental impacts of the alternative set of emission limits in terms of emission
reductions of air pollutants were assessed for light- and heavy-duty vehicles and are
presented together with the environmental impacts of the policy option 2a in Table 57
and Table 58.
426
Expressed as 100% of MAW
427
Expressed as 90% of MAW
428
With random preconditioning at any temperature up to 38 °C
429
ORVR stands for “On-board Refuelling Vapour Recovery” and is a limit designed to avoid emissions
during the refuelling of the vehicles. Limit to be set at 0.05 g/L.
430
Expressed as Battery Energy Based. To be reviewed for lorries and buses and for inclusion of range
metric.
109
Table 57 – Assessment of the environmental impacts of policy option 2a and alternative
medium green ambition compared to the baseline: reduction of emissions of air
pollutants in 2035 for cars and vans, Data source: SIBYL/COPERT 2021
Pollutant Latest available
emissions
Baseline Alternative 2a
with less strict
emission limits
2a – Medium
Green Ambition
2018 in kt 2035 in kt, % compared to baseline
NOX
1 689.67 389.40 234.58
(-40%)
224.40
(-42%)
PM2,5,brake
emissions
14.90 16.04 11.82
(-26%)
11.82
(-26%)
PM2,5,exhaust
43.85 1.50 1.29
(-14%)
1.28
(-15%)
PN10 [in #]
6.55x1025
1.92x1024
1.29x1024
(-33%)
1.06x1024
(-45%)
CO
2 796.13 584.50 482.68
(-17%)
414.90
(-29%)
THC
412.22 146.10 116.03
(-21%)
113.20
(-23%)
NMHC
369.70 119.20 96.61
(-19%)
93.80
(-21%)
NH3
38.41 23.85 17.44
(-27%)
16.15
(-32%)
CH4
42.52 26.85 19.42
(-28%)
19.42
(-28%)
N2O
16.34 41.26 28.91
(-30%)
28.91
(-30%)
Table 58 – Assessment of the environmental impacts of policy option 2a and alternative
medium green ambition compared to the baseline: reduction of emissions of air
pollutants in 2035 for lorries/buses, Data source: SIBYL/COPERT 2021
Pollutant Latest available
emissions
Baseline Alternative 2a
with less strict
emission limits
2a – Medium
Green Ambition
2018 in kt 2035 in kt, % compared to baseline
NOX
1 689.73 705.40 354.20
(-51%)
316.10
(-55%)
PM2,5,brake
emissions
- - - -
PM2,5, exhaust
23.45 8.81 5.37
(-39%)
5.37
(-39%)
PN10 [#]
3.70x1025
7.49x1023
5.17x1023
(-31%)
4.06x1023
(-46%)
CO
412.92 111.50 99.30
(-11%)
97.90
(-12%)
THC
43.38 26.55 32.41
(-12%)
23.06
(-13%)
NMHC
36.71 16.66 13.31
(-20%)
12.95
(-22%)
NH3
6.46 9.64 9.64
(-0%)
6.45
(-33%)
CH4
6.67 9.89 10.10
(+2.1%)
10.10
(+2.1%)
N2O
57.13 97.80 58.30
(-40%)
58.30
(-40%)
Conclusion: In line with the assumed alternative emission limits which are less strict
than those in PO2a, there are 1-2% less emission savings of NOx, PM2.5 and NMHC and
110
5% less emission savings of NH3, compared to policy option 2a for light-duty vehicles.
However, for heavy-duty vehicles, there are 4% less emission savings of NOx and 33%
less emission savings of NH3.
Although the alternative assumption has been developed on the basis of less strict
emission limits, the regulatory costs associated with it are the same as in policy option
2a, for light- and heavy-duty vehicles.
This is explained by the fact that the same emission control systems will need to be
deployed in policy option 2a and in the alternative assumption.
More specifically, the choice of technology as shown in Table 21, is determined by the
level of emission limits of NOx and PN for all types of vehicles. For the emission levels
of NOx (30 mg/km for PO2a and 35 mg/km for the alternative) and for PN (1x10+11
for
PO2a and 3x10+11
for the alternative), the required technology is the same. The hardware
cost, which is the most important cost category, is therefore the same in PO2a and the
alternative. The appropriate level of emissions will be reached through the use of
software and appropriate calibration. The calibration costs do not change with the level
of emission limits, therefore the total regulatory costs remain the same in PO2a and the
alternative.
Therefore, not only the alternative assumption leads to lower emission savings when
compared with policy option 2a, but it still results in the same regulatory costs.
Table 59 below presents the efficiency of the alternative assumption as it was done in
Table 13 in chapter 7 for the policy options 1, 2a, 2b and 3a.
Table 59 – Assessment of efficiency compared to baseline* for medium-ambition policy
option 2a and alternative option 2a with less strict emission limits, 2025-2050,
Introduction of Euro 7 in 2025, Data source: SIBYL/COPERT 2021
Policy option
Alternative 2a with less
strict emission limits
2a – Medium Green
Ambition
Cars and vans
Health and environmental benefits, 2025
NPV in billion €
52.41 54.82
Regulatory costs savings, 2025 NPV in
billion €
3.45 3.45
Regulatory costs, 2025 NPV in billion € 33.73 33.73
Net benefits, 2025 NPV in billion € 22.13 24.55
Benefit-cost ratio** 1.7 1.7
Lorries and buses
Health and environmental benefits, 2025
NPV in billion €
124.94 132.54
Regulatory costs savings, 2025 NPV in
billion €
0.38 0.38
Regulatory costs, 2025 NPV in billion € 16.82 16.82
Net benefits, 2025 NPV in billion € 108.50 116.10
Benefit-cost ratio** 7.5 7.9
* The baseline considers an end-date of combustion-engine cars/vans in 2035, see section 5.1.
** The benefit-cost ratio gets disproportionally high when costs are low which gives an unjustified
advantage to low-cost options (here lorries and buses) and has the potential to mislead policy makers. The
benefit-cost ratio is disregarded to choose one option based on benefits and costs in absolute terms only
and included in this table for completeness purposes only.
Conclusion: Compared to policy option 2a, the alternative assumption leads to lower
health and environmental benefits and no cost changes. The net benefits for the
111
alternative assumption of the medium green ambition are for light- and heavy-duty
vehicles lower than policy option 2a due to the smaller reduction in harmful air
pollutants.
8.2 Alternative set of assumptions on durability
Most new vehicles that are purchased by a first user eventually end up on the second-
hand market. In addition, large flows of used cars are reported from Western to Central-
Eastern EU countries with the import of used cars exceeding the number of domestic new
registrations in almost all Central-Eastern EU countries.431
These flows are expected to
be an important contributor to the difference in the average age of vehicles in Western
and Central-Eastern EU countries raised by stakeholders from civil society. While the
lowest average ages of cars are found in Luxemburg, Austria, Ireland, Denmark and
Belgium (7-9 years), the highest average age are found in Lithuania, Estonia, Romania
and Greece (16-17 years).432
Used vehicles exported to other regions, like Africa or Middle East may remain in
circulation even longer. Such vehicles often comply with below Euro 4/IV standard and
they often present problems with the emission control technologies leading to high
emissions of PM and NOx.433
Despite efforts by several African countries, a lack of
adequate fuel quality in most African countries still prevents the optimal use of recent
advanced emission control technologies.434
The revision of the End-of-Life Vehicle Directive435
planned for 2022 is looking into the
problem of circulation and of export of used vehicles outside the EU in order to address
environmental and health problems created by them.
Since the Euro 6/VI durability provisions were found to be inadequate, all policy options
considered in the impact assessment were based on increased durability with different
levels of ambition (see Table 2 in chapter 5 and Table 54). This was done in order to
ensure good performance of the vehicle throughout their lifetime.
Policy option 2a on the medium green ambition reflects the average lifetime of vehicles
in EU-27. An alternative to option 2a was analysed where higher durability was
introduced to reflect the need for increased car performance in order to limit emissions
beyond the average lifetime (see Table 60). Since the durability assumptions are the same
in PO2a and PO3a, the conclusions drawn are also valid for PO3a.
Table 60 - Assessment of efficiency compared to baseline* for medium-ambition policy
option 2a and alternative option 2a with increased durability, 2025-2050, Introduction of
Euro 7 in 2025, Data source: SIBYL/COPERT 2021
Policy option 2a – Medium Green Ambition
Alternative 2a with increased
durability
Cars and vans
431
Transport & Mobility Leuven, 2016. Data gathering and analysis to improve the understanding of 2nd
hand car and LDV markets and implications for the cost effectiveness and social equity of LDV CO2
regulations
432
ACEA, 2021. Average age of the EU vehicle fleet, by country.
433
Dutch Ministry of Infrastructure and Water Management – Human Environment and Transport
Inspectorate, 2020. Used vehicles exported to Africa: A study on the quality of used export vehicles
434
United Nations Environment Programme (UNEP), 2020. Global Trade in Used Vehicles Report
435
Directive 2000/53/EC on end-of life vehicles
112
Durability 200 000 km or 10 years 240 000 km or 15 years
Health and environmental
benefits, 2025 NPV in billion €
54.82 55.78
Regulatory costs savings, 2025
NPV in billion €
3.45 3.45
Regulatory costs, 2025 NPV in
billion €
33.73 34.66
Net benefits, 2025 NPV in
billion €
24.55 24.58
Benefit-cost ratio** 1.7 1.7
Lorries and buses
Durability lorries < 16t, buses < 7.5t /
lorries > 16t, buses > 7.5t
375 000 km / 875 000 km 450 000 km / 1 050 000 km
Health and environmental
benefits, 2025 NPV in billion €
132.54 133.55
Regulatory costs savings, 2025
NPV in billion €
0.38 0.38
Regulatory costs, 2025 NPV in
billion €
16.82 18.06
Net benefits, 2025 NPV in
billion €
116.10 115.87
Benefit-cost ratio** 7.9 7.4
* The baseline considers an end-date of combustion-engine cars/vans in 2035, see section 5.1.
** The benefit-cost ratio gets disproportionally high when costs are low which gives an unjustified
advantage to low-cost options (here lorries and buses) and has the potential to mislead policy makers. The
benefit-cost ratio is disregarded to choose one option based on benefits and costs in absolute terms only
and included in this table for completeness purposes only.
Conclusion: The alternative set of durability assumptions results in slightly higher health
and environmental benefits for both cars/vans and lorries/buses while increasing
hardware costs lead to slightly higher regulatory costs. For light- and heavy-duty
vehicles, only minimal changes occur with regard to the net benefits moving from the
average durability assumptions in policy option 2a to increased durability.
This cost-benefit result is explained by the fact that the additional emission savings with
increased durability assumptions are only expected to occur towards the end of the
assessed period. Hence, the net present value of the health and environmental benefits
does not increase much. In a contrary manner, the additional hardware costs mostly occur
at the beginning of the vehicles lifetime, which increases the net present value of the
regulatory costs relatively more.
In conclusion, the alternative set of durability assumptions to reflect a longer lifetime of
vehicles in the EU-27 is not expected to be a more efficient solution for either cars/vans
or lorries/buses.


EN EN
EUROPEAN
COMMISSION
Brussels, 10.11.2022
SWD(2022) 359 final
PART 1/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Accompanying the document
PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF
THE COUNCIL
on type-approval of motor vehicles and of engines and of systems, components and
separate technical units intended for such vehicles, with respect to their emissions and
battery durability (Euro 7) and repealing Regulations (EC) No 715/2007 and (EC) No
595/2009
{COM(2022) 586 final} - {SEC(2022) 397 final} - {SWD(2022) 358 final} -
{SWD(2022) 360 final}
Offentligt
KOM (2022) 0586 - SWD-dokument
Europaudvalget 2022
1
Contents
1 INTRODUCTION: POLITICAL AND LEGAL CONTEXT............................................................... 1
1.1 Political context.................................................................................................1
1.2 Legal context .....................................................................................................2
1.3 Interaction between Euro emission standards and other EU air
pollutant policies ...............................................................................................3
2 PROBLEM DEFINITION .................................................................................................................... 6
2.1 What are the problems?.....................................................................................6
2.1.1 Problem 1: Complexity of vehicle emission standards ......................................... 13
2.1.2 Problem 2: Obsolete vehicle pollutant limits........................................................ 15
2.1.3 Problem 3: Insufficient control of vehicle real-world emissions........................... 16
2.2 What are the problem drivers? ........................................................................17
2.2.1 Drivers behind the complexity of vehicle emission standards.............................. 17
2.2.2 Drivers behind obsolete vehicle pollutant limits................................................... 18
2.2.3 Drivers behind insufficient control of vehicle real-world emissions..................... 19
2.3 How will the problem evolve? ........................................................................21
3 WHY SHOULD THE EU ACT? ........................................................................................................ 21
3.1 Legal basis.......................................................................................................21
3.2 Subsidiarity: necessity and added value of EU action.....................................22
4 OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................... 22
4.1 General objectives ...........................................................................................22
4.2 Specific objectives...........................................................................................22
5 WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................... 23
5.1 What is the baseline from which options are assessed? ..................................23
5.2 Description of the policy options ....................................................................27
5.2.1 Policy option 1 (PO1): Low Green Ambition.......................................................... 29
5.2.2 Policy option 2 (PO2a and PO2b): Medium and High Green Ambition................. 29
5.2.3 Policy option 3 (PO3a): PO2a and Medium Digital Ambition................................ 30
5.3 Options discarded at an early stage .................................................................31
6 WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 32
6.1 PO1: Low Green Ambition .............................................................................34
6.1.1 Economic impacts.................................................................................................. 34
6.1.2 Environmental impacts.......................................................................................... 38
6.1.3 Social impacts........................................................................................................ 39
2
6.2 PO2: Medium and High Green Ambition .......................................................41
6.2.1 Economic impacts.................................................................................................. 41
6.2.2 Environmental impacts.......................................................................................... 45
6.2.3 Social impacts........................................................................................................ 47
6.3 PO3a: PO2a and Medium Digital Ambition ...................................................49
6.3.1 Economic impacts.................................................................................................. 49
6.3.2 Environmental impacts.......................................................................................... 52
6.3.3 Social impacts........................................................................................................ 53
7 HOW DO THE OPTIONS COMPARE?............................................................................................ 55
7.1 Effectiveness....................................................................................................58
7.2 Efficiency ........................................................................................................58
7.3 Coherence........................................................................................................65
7.4 Proportionality.................................................................................................66
8 PREFERRED OPTION ...................................................................................................................... 70
9 HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?.................................. 73
1
Glossary
Acronym Meaning
AGVES Advisory Group on Vehicle Emission Standards
AAQD Ambient Air Quality Directive
ASC Ammonia Slip Catalyst
BEV Battery Electric Vehicle
CEM Continuous Emission Monitoring
CI Compression Ignition engine vehicles (diesel vehicles)
CNG Compressed Natural Gas
CoP Conformity of Production
HDV Heavy-Duty Vehicles (lorries and buses)
DPF Diesel Particulate Filter
EATS Exhaust Aftertreatment System
EHC Electrically Heated Catalyst
EGR Exhaust Gas Recirculation
GDP Gross Domestic Product
GHG Greenhouse Gas
GPF Gasoline Particulate Filter
ICE Internal Combustion Engine
ISC In-Service Conformity
LDV Light-Duty Vehicles (cars and vans)
LPG Liquefied Petroleum Gas
MaS Market Surveillance
NAO Non Asbestos Organic (brake pads)
NECD National Emission reduction Commitments Directive
NPV Net Present Value
OBD On-Board Diagnostics
OBFCM On-Board Fuel Consumption Meters
OTA Over-The-Air (data transmission)
PEMS Portable Emission Measurement Systems
PFI Port Fuel Injection
PHEV Plug-in Hybrid Electric Vehicle
PI Positive Ignition engine vehicles (petrol and gas vehicles)
2
PTI Periodic Technical Inspections
RDE Real Driving Emissions
RSI Roadside Inspections
SCR Selective Catalytic Reduction
TWC Three-Way Catalytic converter
UNECE United Nations Economic Commission for Europe
WHO World Health Organization
WHSC Worldwide Harmonised Steady State Driving Cycle
WHTC Worldwide Harmonised Transient Driving Cycle
WLTP World Harmonised Light Vehicle Test Procedure
Glossary emission species
Formulae Meaning
CH2O / HCHO Formaldehyde
CH4 Methane
CO Carbon monoxide
CO2 Carbon dioxide
HC Hydrocarbon (Total hydrocarbons (THC) and Non-methane
hydrocarbons (NMHC))
NH3 Ammonia
NMOG Non-methane organic gases
NMVOC Non-methane volatile organic compounds
N2O Nitrous oxide
NO2 Nitrogen dioxide
NOx Nitrogen oxide (Nitrogen dioxide (NO2) and Nitric oxide (NO))
O3 Ozone
PM Particulate matter
PM10 Particulate matter with an aerodynamic diameter smaller than 10
micrometres (<10 µm)
PM2,5 Particulate matter with an aerodynamic diameter smaller than 2.5
micrometres (<2,5 µm)
PN Particle number
1
1 INTRODUCTION: POLITICAL AND LEGAL CONTEXT
1.1 Political context
Air pollution remains the single largest environmental and health risk in Europe.1
While
air quality has improved, a significant proportion of the EU’s urban population is still
exposed to pollutant concentrations above the limits defined by the Ambient Air Quality
Directive2
. Even greater proportion faces the pollution concentrations above the
maximum levels recommended by the World Health Organization (WHO)3
, while even
low level of pollution was recently shown4
to be associated with increased mortality due
to cardiovascular, respiratory and lung cancer. Road transport is still a major contributor
to air pollution, while other sectors like residential heating, industry, energy supply or
agriculture are also important source of harmful emissions. It is estimated that road
transport caused about 70 000 premature deaths in the EU-28 in 2018.5
It was on average
responsible for 39% of the harmful NOx emissions in 2018 (47% of the NOx emissions in
urban areas6
), and 11% of total PM10 emissions in 20187
. The Dieselgate scandal8
unveiled the widespread use of illegal defeat devices9
in diesel vehicles, leading to
abnormally high emissions on the road, compared to emissions tested in the laboratory.
While the Commission has since introduced real driving emissions testing and
modernised type approval procedures, the European Parliament Committee of Inquiry
into Emissions Measurements in the automotive sector recommended that the
Commission also proposes new technology-neutral Euro 7 emissions limits.10
The European Green Deal11
(EGD) is a new growth strategy that aims to transform the
EU into a fair and prosperous society, with a modern, resource-efficient and competitive
economy. The EU should also promote and invest in the necessary digital transformation
and tools as these are essential enablers of the changes. In order to reach climate
neutrality by 2050 and zero-pollution ambition for a toxic-free environment, all sectors
need to transform, including the road transport. EGD foresees adoption of a proposal for
more stringent air pollutant emissions standards for combustion-engine vehicles (Euro 7).
1
EEA, 2020. Air quality in Europe – 2020 report
2
Directive 2008/50/EC on ambient air quality and cleaner air for Europe
3
EEA, 2020. Exceedance of air quality standards in Europe
4
Brunekreef, B. et al, 2021. Mortality and Morbidity Effects of Long-Term Exposure to Low-Level
PM2.5, BC, NO2, and O3: An Analysis of European Cohorts in the ELAPSE Project
5
See footnote 1 (EEA air quality report). This estimate is based on estimated 379 000, 54 000 and 19 400
premature deaths in the EU-28 in 2018 from fine particles pollution, NO2 and O3 emissions in the ambient
air, respectively, and the estimated share of road transport in 2018 of 39% of the harmful NOx emissions
and of 11% of total PM10 emissions.
6
JRC, 2019. Urban NO2 Atlas
7
EEA, 2020. Air pollutant emissions data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2018
8
The car emission scandal was set off by the revelation by the US Environmental Protection Agency
(EPA) in September 2015 that the Volkswagen Group had used defeat devices in 500 000 diesel cars in the
United States to comply with pollutant emission limits in laboratory conditions. Shortly after, it was
confirmed by the German authorities that Volkswagen had also used defeat devices in approximately 8.5
million cars in Europe for model years 2009-2015.
9
Defeat Devices are elements of car design that diminish the emission controls under certain
circumstances. They are mostly prohibited, unless there is a specific and well justified reason for their use.
10
EMIS, 2017. European Parliament recommendation of 4 April 2017 to the Council and the Commission
following the inquiry into emission measurements in the automotive sector
11
COM(2019) 640 final. The European Green Deal
2
To accelerate decarbonisation of the road transport, the Commission proposed in July
2021 legislation on CO2 emission performance standards for cars/vans12
, to ensure a clear
pathway towards zero-emission mobility.13
Moreover, the Commission adopted in
December 2020 the Sustainable and Smart Mobility Strategy14
and in May 2021 the
Zero-Pollution Action Plan15
. According to those strategies, transport should become
drastically less polluting, especially in cities and Euro 7 is considered as a vital part of
the transition towards clean mobility.
Last but not least, the New Industrial Strategy for Europe16
offers tools to address the
twin challenge of the green and the digital transformation and to support the European
industry in making the EGD ambition a reality. New pollutant emission framework will
offer legal certainty and first-mover advantage to the EU automotive sector, avoiding the
risk of falling behind other major jurisdictions setting new pollutant emission standards.
Transition towards only zero-emission vehicles fleet will however be spread across at
least two decades, not least given the average lifetime of vehicles of more than 11 years.
Meanwhile, in order to achieve the above policy objectives, it is imperative to ensure that
the internal combustion-engine vehicles which will continue to be placed on the market
are as clean as possible. This is a prerequisite for protection of human health, in
particular in urban areas17
.
1.2 Legal context
Emission standards for light-duty vehicles (cars/vans), and heavy-duty vehicles
(lorries/buses), were implemented in the EU since 1992 through a series of Euro
emission rules which addressed one of the major sources of air quality problems, i.e.
tailpipe pollutants emitted to the air. These standards are embedded in the general type-
approval framework18
, based on which new vehicle models are tested, granted type-
approval and verified against a minimum set of safety and emission requirements before
entering into service on the EU market. Over the years, with successive Euro standards,
not only the specific limits for pollutants were tightened, but also the pollutant testing
procedures were gradually modernised. The current emission standards were adopted in
2007 for light-duty vehicles (LDVs-Euro 6) and in 2009 for heavy-duty vehicles (HDVs-
Euro VI).1920
They entered into force in 2014 for LDVs and in 2013 for HDVs.21
12
COM(2021) 556 final. Proposal for a Regulation amending Regulation (EU) 2019/631 as regards
strengthening the CO2 emission performance standards for new passenger cars and new light commercial
vehicles in line with the Union’s increased climate ambition
13
In 2022, this will be followed by a proposal on CO2 emission performance standards for heavy-duty
vehicles.
14
COM(2020) 789 final. Sustainable and Smart Mobility Strategy – putting European transport on track for
the future
15
COM(2021) 400 final. Pathway to a Healthy Planet for All EU Action Plan: Towards Zero Pollution for
Air, Water and Soil
16
COM(2020) 102 final, A New Industrial Strategy for Europe, COM(2021) 350 final, Updating the 2020
New Industrial Strategy: Building a stronger Single Market for Europe’s recovery
17
Urban areas are characterised by high volume of traffic emitting air pollutants and high population
density. The population in urban areas is therefore exposed to higher concentrations of air pollutants than
in rural areas and more citizens are effected.
18
Regulation (EU) 2018/858 on the approval and market surveillance of motor vehicles and their trailers,
and of systems, components and separate technical units intended for such vehicles
19
Regulation (EC) No 715/2007 on type-approval of motor vehicles with respect to emissions from light
passenger and commercial vehicles (Euro 5 and Euro 6) and its implementing Regulation (EU) 2017/1151;
3
The testing procedures have been adjusted by implementing Regulations over the
different steps of Euro 6b-d and Euro VI A-E between 2013 and 2022 (see Annex 5,
Table 36 for details)22
. The introduction of Real Driving Emissions (RDE) testing in
2017 (footnote 24 below) required testing of pollutants in real-driving and no more only
in laboratory conditions, bringing about significant reduction of harmful emissions23
. In
2019 also more stringent verification by in-service conformity procedure (ISC), ensuring
that vehicles meet the emission limits during their service, was introduced.24
The Euro emission standards include references to testing procedures set out in UN
regulations25
. The UN World Forum for Harmonization of Vehicle Regulations focusses
on the establishment of global harmonisation of technical regulations for vehicles. The
EU as a contracting party, has ensured that all relevant UN Regulations are aligned with
the Euro 6/VI emission limits and testing procedures.
1.3 Interaction between Euro emission standards and other EU air pollutant
policies
As shown in Figure 1, Euro emission standards for vehicles are interlinked with several
other EU rules which tackle air pollutants of the road transport as well as with the CO2
emission standards26
which reduce air pollutants as a co-benefit.
Regulation (EC) No 595/2009 on type-approval of motor vehicles and engines with respect to emissions
from heavy-duty vehicles (Euro VI) and its implementing Regulation (EU) No 582/2011
20
SEC(2005) 1745 Commission Staff Working Document, Impact Assessment on Euro 5/6 emission
standards; SEC(2007) 1718 Commission Staff Working Document, Impact Assessment on Euro VI
emission standards; together referred to as Euro 6/VI impact assessments in the following
21
In 2014 for light-duty vehicles and 2013 for heavy-duty vehicles, air pollutant emission limits entered
into force for NOx (nitrogen oxide), PM (particulate matter), PN (particle number), CO (carbon monoxide),
THC (total hydrocarbons) and NMHC (non-methane hydrocarbons) and, for heavy-duty vehicles only, CH4
(methane) and NH3 (ammonia). (See Annex 5, Table 35 for details)
22
They also include trailers used in heavy duty vehicles for what concerns their effect on CO2 emissions.
23
Regulation (EU) 2017/1151, supplementing Regulation (EC) No 715/2007 on type-approval of motor
vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6)
24
Regulation (EU) 2018/1832 for the purpose of improving the emission type approval tests and
procedures for light passenger and commercial vehicles, including those for in-service conformity and real-
driving emissions and introducing devices for monitoring the consumption of fuel and electric energy
25
Regulation No 83 of the Economic Commission for Europe of the United Nations (UN/ECE) — Uniform
provisions concerning the approval of vehicles with regard to the emission of pollutants according to
engine fuel requirements; Regulation No 49 of the Economic Commission for Europe of the United
Nations (UN/ECE) — Uniform provisions concerning the measures to be taken against the emission of
gaseous and particulate pollutants from compression-ignition engines and positive ignition engines for use
in vehicles
26
Regulation (EU) 2019/631 CO2 emission performance standards for new passenger cars and for new
light commercial vehicles, Regulation (EU) 2019/1242 CO2 emission performance standards for new
heavy-duty vehicles
4
Figure 1- EU rules tackling air pollutants in the road transport sector
 The scale of policy actions undertaken in Europe to specifically address transport-
related air pollution has increased over recent years, reflecting the important
contribution of transport to air pollution, in particular in urban areas. Local and
regional air quality management plans — including initiatives such as low- or zero-
emission zones in cities and congestion charges — are now used in many areas where
the level of air pollution from transport is high. The Ambient Air Quality Directive
(AAQD)27
aims at improving air quality by setting limits for the ambient air
concentrations of specific air pollutants from all air pollution sources (e.g.
agriculture, energy, manufacturing, etc.). The National Emission reduction
Commitments Directive (NECD) aims at reducing national air pollutant emissions by
setting national reduction commitments for five specific air pollutants28
, with
reductions from all sectors, including road transport. The current AAQD/NECD
cover ambient levels of air pollutants and emissions of road transport and the Euro
emission standards for vehicles help Member States meeting their NECD reduction
commitments.
As part of the European Green Deal, the Commission announced that it will revise in
2022 EU rules on air quality proposing to strengthen provisions on monitoring,
modelling and air quality plans and revising the air quality legislation to align them
more closely with the new WHO recommendations29
. It is clear from the analysis30
carried out by one of the most authoritative air quality modelling group in Europe, i.e.
the International Institute for Applied Systems Analysis (IIASA), that full
compliance will not be achieved without extra measures. In 2030 more than 52
27
Directive 2008/50/EC on ambient air quality and cleaner air for Europe
28
Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants. The
Directive establishes the emission reduction commitments for the Member States' anthropogenic
atmospheric emissions of SO2, NOx, NMVOC, NH3 and PM2,5 and requires that national air pollution
control programmes be drawn up, adopted and implemented and that emissions of those pollutants and the
other pollutants referred to in Annex I, including CO, as well as their impacts, be monitored and reported.
29
World Health Organization, 2021. WHO global air quality guidelines: particulate matter (PM2.5 and
PM10), ozone, nitrogen dioxide, sulfur dioxide and carbon monoxide.
30
European Commission, 2022. Revision of the Ambient Air Quality Directives
5
million EU citizens will continue to be exposed to NOx concentrations higher than
the WHO recommended air quality concentration levels due to road traffic. This
analysis relied on incorporating the assumptions under the Option 3a of this Impact
Assessment. This demonstrates the importance of limiting emissions at the source, by
setting stricter emissions standards (such as the Euro ones for road transport) and
requirements for improved fuel quality. The introduction of stricter Euro emission
standards for all air pollutant emissions from road transport is needed in order for
Member States to achieve compliance with new targets on air quality, while limiting
the need to impose vehicle circulation bans. The interactions are further explored in
the next sections.
 The CO2 emission standards support the EU’s climate ambition set in European
Climate Law31
, which aims at reducing EU greenhouse gas emissions by at least 55%
by 2030, compared to 1990. Since the CO2 emission standards have proven to be an
effective policy tool in this respect32
, the Commission revised and strengthened the
CO2 emission standards for cars/vans in July 2021 (see 1.1). Significant positive
effects on air quality can be expected from the amendment of the CO2 standards,
setting an end-date of 2035 for placing new combustion-engine cars and vans in the
EU market. The revision of the CO2 emission standards for heavy-duty vehicles is
foreseen by end-2022, aiming at increasing uptake of zero- and low emission heavy-
duty vehicles and enhanced fuel efficiency of conventional engines.
 The Roadworthiness Directives33
have the objective to increase road safety in the EU
and to ensure the environmental performance of vehicles, by means of regularly
testing vehicles throughout their operational lifetime. As far as emissions are
concerned they have as objective to contribute to the reduction of air pollutant
emissions by detecting more effectively vehicles that are over-emitting due to
technical defects, through periodic technical inspections (PTI) and the roadside
inspections (RSI). The Euro emission standards and Roadworthiness Directives
should operate in a complementary way with the aim to reduce air pollutant
emissions from road vehicles.
 The Fuel Quality Directive34
sets obligation of reduction of air pollutants from liquid
transport fuels, the Eurovignette Directive35
sets common rules on road infrastructure
charges and the Clean Vehicles Directive36
promotes clean mobility solutions through
public procurement. While the Euro emission standards require clean performance of
vehicles, the Alternative Fuel Infrastructure Directive (AFID)37
promotes the use of
31
Regulation 2021/119 establishing the framework for achieving climate neutrality and amending
Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate Law’)
32
SWD(2021) 613 final, Commission Staff Working Document, Impact Assessment, Accompanying the
document Proposal for a Regulation amending Regulation (EU) 2019/631 as regards strengthening the CO2
emission performance standards for new passenger cars and new light commercial vehicles in line with the
Union’s increased climate ambition
33
Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers; Directive
2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating
in the Union
34
Directive 2009/30/EC as regards the specification of petrol, diesel and gas-oil and introducing a
mechanism to monitor and reduce greenhouse gas emissions
35
COM(2017) 275 final, Proposal for a Directive amending Directive 1999/62/EC on the charging of
heavy goods vehicles for the use of certain infrastructures
36
Directive 2019/1161/EU on the promotion of clean and energy-efficient road transport vehicles
37
Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the
6
alternative fuels for road transport. The Eurovignette Directive and Clean Vehicles
Directive may support the demand for clean vehicles by allowing Member States to
vary road charges based on pollutant emissions of vehicles and by setting
requirements for higher share of clean vehicles in public procurement.
2 PROBLEM DEFINITION
2.1 What are the problems?
The negative impact of road transport to air pollution has only marginally decreased over
the recent years. This relative stagnation is mainly due to the ever-growing vehicle fleet38
and increase in transport demand compared to more significant emission reductions in
other sectors39
. Also, despite improvements in the emission regulation, gaseous
pollutants, in particular NOx and exhaust particles are still emitted through tailpipes of
ICE vehicles while non-exhaust particles are a result of brake and tyre wear produced by
all vehicles, including zero-emission vehicles. This leads to more than 70% of ultrafine
particles40
in EU cities being attributed to road transport, either directly (primary
emissions) or indirectly (secondary aerosol).41
Furthermore, preliminary analysis done for
the revision of EU air quality legislation30
carried out by one of the most authoritative air
quality modelling group in Europe, i.e. the International Institute for Applied Systems
Analysis (IIASA), has shown that full compliance with NO2 limits cannot be reached
with today’s vehicle emission standards.
Since the entry into force of Euro 6/VI emission limits until 2020, NOx vehicle emissions
on EU roads have decreased by 22% for cars/vans and by 36% for lorries/buses.42
In
addition, exhaust PM emissions from cars/vans have decreased by 28%, and by 14%
from lorries and vans. THC emissions from lorries/buses went down by 14%, while THC
and NMHC emissions from cars/vans went down by 13 and 12%.42
Further emission
reductions are expected to be made as more Euro 6d and Euro VI E vehicles enter the
market43
.
In the same Euro 6/VI period, health impacts and the related external costs of medical
treatment and production losses due to illness and death were reduced by €97 billion EU-
wide due to reduced NOx and PM emissions from road transport.44
However, pollutant
emissions caused by road transport still affect hundreds of thousands of European
citizens and lead to significant health impacts and related external costs each year. In
2018 an EPHA study45
estimated that any inhabitant of European cities suffered an
average welfare loss of over €1 250/year due to direct and indirect health impacts of poor
air quality, which is equivalent to 3.9% of income earned in cities. While these air quality
problems are not exclusively caused by road transport, the same study demonstrated that
deployment of alternative fuels infrastructure
38
ACEA, 2021. Vehicles in use Europe
39
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-, chapter 5.1.5.3 What has been the
contribution of the standards to achieving National Emission Ceilings Directive (NECD) targets?
40
Ultrafine particles are defined here as those having less than 0.1 µm of diameter.
41
CORDIS, 2019. Ultrafine particles and health impact: revising EU policy
42
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3. Chapter 5.1.2.4 What was the
impact of Euro 6/VI on the total level of emissions?
43
The late introduction of RDE testing in the final Euro 6d step contributed to delayed progress in pollutant
emission reduction under Euro 6, which will materialise only after 2020 (see Figure 20 in Annex 5).
44
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.1 Effectiveness, Evaluation question 3
45
EPHA, 2020. Health costs of air pollution in European cities and the linkage with transport
7
a 1% increase in the number of cars in a city is expected to lead to an overall increase in
health costs by almost 0.5%.
NOx and particles (expressed as PM2.5) are the key air pollutants from road transport. In
Figure 2, the evolution of NOx and total (i.e. exhaust and non-exhaust) PM2.5 emission
between 2010 and 2040 is shown first for cars/vans and then for lorries/buses46
. The fit-
for-55 package of 14 July 2021, i.e. the adopted CO2 emission standards proposing an
end-date of 2035 for placing new combustion-engine cars and vans on the EU market as
well as the projected fit-for-55 HDV fleet evolution to contribute to the 55% net
greenhouse gas emission reduction by 2030 and the 2050 climate neutrality objective,
have been factored in. The fit-for-55 package results in an expected increase of zero-
emission vehicles in the vehicle fleet and, as Figure 2 shows, a decrease in both NOx and
exhaust PM2.5 emissions. Following the proposed end-date of 2035, the emissions of NOx
and exhaust particles from cars/vans are expected to decline more steeply than those from
lorries/buses. Still, combustion-engine cars and vans will continue to be part of the
European fleet after 2035. In 2040, 49% of European fleet of cars and vans is still
expected to consist of combustion-engine vehicles, including hybrids47
.
Moreover, increasing penetration of the latest Euro 6d/VI E vehicles in the fleet results in
NOx and exhaust PM2.5 reduction (see Figure 2). However, Figure 2 also shows that there
is no reduction of non-exhaust PM2.5 emissions from brake and tyre wear for neither
cars/vans or lorries/buses, given lack of emission control technologies in place.
Controlling such non-exhaust emissions is needed, not least because they are also emitted
from zero-emission vehicles. The difference between total and exhaust PM2.5 will
increase in the future for all vehicles. The projections to 2040 show that the zero-
pollution ambition for a toxic-free environment, as set out in the European Green Deal,
cannot be reached in the road transport sector in the near future with the current
legislation in place. To improve our health and well-being in line with the Zero-Pollution
Action Plan15
, air pollutants emission needs to be reduced towards zero-pollution as
rapidly as possible.
The NOx and exhaust PM2.5 emission limits are of particular concern given that they were
set as early as 2007 for cars/vans, and 2009 for lorries/buses (and assessed more than two
decades ago). Furthermore, approximately 20% of current real-driving mileages in
Europe are estimated to be outside the RDE testing boundaries and therefore may exceed
significantly the current emission limits63
. Significant technical evidence on this issue
was gathered by major research projects, including those of the Joint Research Center
(JRC), GreenNCAP and AECC48
,49
,50
,51
,52
,53
. The test data were collected in a database
46
The proposed end-date of 2035 for new combustion-engine cars/vans, projected fit-for-55 HDV fleet
evolution and fleet renewal with Euro 6/VI vehicles is taken into account. Additional effects from the
planned revision of the Ambient Air Quality Directives in 2022, which are estimated limited compared to
the effects of CO2 emission standards, cannot be taken into account yet.
47
SIBYL, 2021: Ready to go vehicle fleet, activity, emissions and energy consumption projections for the
EU 28 member states
48
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
49
Data provided by GreenNCAP (https://www.greenncap.com/ )
50
Real-world emission data measured on-road and on chassis-dyno of Light- and Heavy-duty demonstrator
vehicles were provided by the Association for Emissions Control by Catalyst (AECC). The scientific
publications can be accessed via https://www.aecc.eu/resources/scientific-publications/.
51
JRC Market Surveillance report at https://publications.jrc.ec.europa.eu/repository/handle/JRC122035
52
Scientific paper on “On-road emissions of passenger cars beyond the boundary conditions of the real-
8
run by the JRC54
. Analysis of the data proves that when driven outside RDE testing
boundaries, vehicles still emit significantly higher than when driven within RDE testing
boundaries. As an example, the average of NOx emissions by diesel passenger cars
outside RDE boundaries55
is 475% higher than when driven within RDE boundaries.
This means that just 1 km run outside the current RDE boundaries will pollute on
average the same as 475 km run inside current RDE boundaries.
In addition, there are currently no emission limits for particles emitted by brake and tyre
wear. As can be seen in Annex 4, the average tailpipe emissions of particles from a
passenger car is currently much less than 1 mg/km, while the average particle emissions
from the brakes is estimated to be 11 mg/km, i.e. more than 11 times higher.
Moreover, there is urgent need to address pollutants emission from heavy-duty vehicles.
The projected fit-for-55 share of new combustion-engine heavy-duty vehicles including
hybrids, placed on the EU market is expected to be 53% in 2040 (see Figure 7 in section
5.1), while the overall share of combustion-engine heavy-duty vehicles in the EU fleet
would still be 86%47
. At the same time, the NOx and exhaust PM2.5 emission limits for
these vehicles were set in 2009, on the basis of engine testing only. Emission limits
should be set on the basis of the emissions of the entire heavy-duty vehicle, as it is the
case for light-duty vehicles.
Conclusion: Despite proposed end-date of 2035 for placing new combustion-engine cars
and vans on the EU market, increasing share of zero- and low-emission heavy-duty
vehicles and new Euro 6d/VI E vehicles entering the market, a zero-pollution level
cannot be reached for NOx and total PM2.5 emissions from road transport. The main
reasons are obsolete vehicle emission limits adopted over a decade ago, unaccounted
real-driving emissions from cars and vans, not regulated vehicle brake emissions and the
slower transition of lorries to zero-emission powertrains.
As shown in the evaluation of the Euro 6/VI emission standards, cost-effective pollutants
emission reduction from road transport stems from the mandatory Euro standards
introduced at EU level, which also support Member States improving their local air
quality in line with current rules and in view of the proposed revision of the Ambient Air
Quality Directives and meeting their emission reduction commitments under the National
Emission reduction Commitments Directive.
Figure 2 – Magnitude and evolution of the problem of air pollutants related to road
transport in EU-27 split up for cars/vans (a) and lorries/buses (b), with end-date of
2035 for new combustion-engine cars/vans and fleet renewal with Euro 6/VI vehicles56
driving emissions test” in https://www.sciencedirect.com/science/article/pii/S001393511930369X
53
Scientific papers on “Assessment of Gaseous and Particulate Emissions of a Euro 6d-Temp Diesel
Vehicle Driven >1300 km Including Six Diesel Particulate Filter Regenerations”,
https://www.mdpi.com/2073-4433/11/6/645/htm
54
JRC link to database when available
55
Number quoted are the average of 172 tests on 54 diesel vehicles for trips outside the RDE boundaries,
and 144 tests on 64 diesel vehicles for trips inside the RDE boundaries.
56
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, Figure 4-3: Evolution of (a)
NOx and (b) PM2.5 emissions from road transport after “EU fit-for-55” package. NOx emissions are
harmful nitrogen oxide emissions (nitrogen dioxide (NO2) and nitric oxide (NO)). PM2.5 are harmful
particles with an aerodynamic diameter smaller than 2.5 micrometres.
9
a) Cars and vans
b) Lorries and buses
The evaluation of the Euro 6/VI emission standards identified three main problems,
relevant for the cars/vans as well as the lorries/buses segment, and the related problem
drivers limiting their effectiveness (see Figure 4). The problems: complexity of vehicle
emission standards, obsolete vehicle pollutant limits and insufficient control of vehicle
real-world emissions, explain why the current Euro 6/VI emission standards
insufficiently contribute to the necessary reduction of pollutant emissions from road
transport. This is of particular concern when considering the zero-pollution ambition of
the European Green Deal.
Next to the negative impacts on human health and on environment, other consequences
of the current Euro standards shortcomings have been identified. Firstly, the emergence
of national and local measures aiming at addressing significant pollutant emissions from
road transport. City or driving bans of vehicles with internal combustion engine put at
risk the functioning of the single market57
and could result in undermining consumer
confidence in the automotive products.58
Several Member States59
request an end date for
the sales/registration of new petrol and diesel cars or announced national initiatives to
57
More information on internal market can be found in 6.1.1.3 Single market.
58
More information on consumer trust can be found in 6.1.3.4 Consumer trust.
59
Austria, Belgium, Denmark, France, Greece, Ireland, Lithuania, Luxembourg, Malta, Netherlands, Spain,
Sweden
10
ban diesel or all combustion engines or to introduce zero-emission zones60
in order to
limit health impact of air pollution and address climate change concerns. In October
2021, there are already multiple Urban Vehicle Access Restrictions (UVARs) in the EU
in place or in planning: 328 Low-Emission Zone (LEZ), 130 emergency pollution
schemes, 36 zero-emission zones and 6 urban tolls61
. There is a risk that uncoordinated
action at national or local level could endanger the free movement of persons and goods
in the single market.
Secondly, global pressure to reduce transport emissions intensifies as key markets, in
particular China and the United States, plan more demanding vehicle emission standards.
China is progressing with an ambitious China 7 emission standards62
. The China 6b
emission standards for cars/vans (applicable in 2023), are already fuel-neutral and 40 to
50% more stringent than Euro 6/VI limits.63
The emission limits in the US (Tier 3 Bin
30) are already well below the limits for almost all Euro 6 pollutants.64
The US currently
works on proposals for more stringent emission rules to improve the US competitive
position on clean and efficient cars and trucks65,66
. Furthermore, both China and the US
have increased durability requirements up to 240 000 km or 15 years. In comparison, the
current European requirements reach only 100 000 km or 5 years for the complete
vehicle and 160 000 km for the emission control systems. These developments are
especially important when considering that in 2019 the US was next to the United
Kingdom the leading destination of EU exports of vehicles, with 19% of EU-27 motor
vehicles67
being exported to US (by value). With 12% of EU-27 motor vehicle exports,
China is the second most important trade partner for the EU automotive industry (see
Figure 13 Annex 4).68
Since Brexit, the United Kingdom has become the EU’s most important trade partner. In
2018, roughly one fourth of EU-27 exports was destined to the UK.68
It is assumed that
any future mutual agreement will have the ambition to continue the implementation of
Euro emission standards in the UK. Switzerland, Japan and South Korea are other main
destinations for exports of EU vehicles. In 2019, Switzerland was the destination of 5%
of EU motor vehicle exports. Since Switzerland participates in the EU Single Market for
motor vehicles, Switzerland also follows the Euro emission standards. Japan, who is the
destination of 5% of all EU exports of motor vehicles, employs emission control
requirements for vehicles which are close to EU ones. South Korea is the destination of
60
Politico, 2021. Nine EU countries demand an end date for petrol and diesel cars; Ministère de la
transition écologique (FR), 2020. Développer l'automobile propre et les voitures électriques; EURACTIV,
2021. Denmark to ban petrol and diesel car sales by 2030; BBC, 2019. Ireland to ban new petrol and diesel
vehicles from 2030; Reuters, 2018. Spain to propose ban on sale of petrol, diesel cars from 2040
61
Source: https://urbanaccessregulations.eu/
62
European Commission – JRC, 2021. Sino-EU Workshop on New Emissions Standards and Regulations
for Motor Vehicles
63
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
64
ICCT, 2019. Recommendations for post-Euro 6 standards for light-duty vehicles in the European Union
65
The Wall Street Journal, 2021. Biden Administration Moves to Unwind Trump Auto-Emissions Policy
66
The White House Briefing Room, 2021. Executive Order on Strengthening American Leadership in
Clean Cars and Trucks (August 05 2021)
67
Includes next to cars also commercial vehicles such as vans, lorries and buses. In value, the EU export of
cars presented approximately 92% of the EU export of all motor vehicles. For more information, see
section 1.4.1. in Annex 4.
68
ACEA, 2020. EU passenger car exports, top 10 destinations (by value); ACEA, 2020. EU motor vehicle
exports, top 10 destinations (by value)
11
4% of EU motor vehicle exports and has been following the European rules for diesel
vehicle emission standards since 2002 with the Euro 6-level standard entering into force
in 2020.69
At the same time, the EU automotive industry could maintain its competitive position on
the global market of internal combustion technologies that will still play a role in several
third markets for which a slower transition to zero-emission cars/vans is expected70
, such
as India, South-East Asia, Brazil or South Africa, and in the lorries/buses segment, where
internal combustion engines will prevail for longer. By accelerating investments in zero-
emission technologies, the EU automotive value chain should not put at risk its know-
how on more traditional technologies that will continue to be important for countries
with slower transitions.
In conclusion, key markets for EU export of vehicles, US and China, are developing
more stringent standards and other main markets are following the Euro standards.
Manufacturers can adapt the manufacturing of the vehicles’ emission control systems
themselves to keep their export market share in key markets that are not supposed to
follow the Euro emission standards, i.e. China and US. However, less regulatory entrance
costs to these markets are expected with an ambitious Euro emission standards matching
global developments. Without action, there is the risk that access to key markets could be
hampered for EU manufacturers as it would become more costly to meet emission
requirements in different markets.
Figure 3 – Comparison of latest emission limits in the EU, United States (Tier 3 Bin 30)
and China for light-duty vehicles, Source: ICCT, 201971
The problem analysis shows that there are differences in the problems and need to act
between cars/vans and lorries/buses segments (see Box 1).
69
See Annex 4, section 1.4.1. Competitiveness: Export of EU motor vehicles to key destinations
70
See Annex 4, section 1.5.4. Cumulative impacts on industry
71
ICCT, 2019. Recommendations for post-Euro 6 standards for light-duty vehicles in the European Union.
Differences in testing procedures not taken into account.
12
Box 1 – Differences of the problems and need to act between cars/vans and
lorries/buses segment
In 2022, electric powertrains are a widely accepted solution for urban and personal
mobility with a large number of pure electric vehicle types in the market and the
numbers of sales growing fast. However, for the long-haul transport of goods
electrification is significantly slower with only a few pure electric models currently
available.
Due to the planned phasing out of cars/vans with an internal combustion engine by
2035, and the technology-readiness of electric cars/vans, the emissions of traditional
pollutants from cars/vans are expected to decline more steeply than those from
lorries/buses (see Figure 2). Therefore, in the future there will be a higher contribution
from lorries/buses segment to the problem of pollutant emissions from road transport
and therefore a higher need to take measures to reduce pollutant emissions from this
sector.
Figure 2 also shows that without action, non-exhaust particles emissions for both
cars/vans and lorries/buses will not be reduced, given the lack of emission control
technologies in place.
Hence there is need to act in both vehicle segments to improve our health and well-being
in line with the Zero-Pollution Action Plan15
. Moreover, the new EU Urban Mobility
Framework from December 202172
underlines the overall importance of getting
transport drastically less polluting in cities and that the majority of urban vehicle access
regulations concern low (and zero) emission zones to address local air quality problems,
in particular in the cars/vans segment.
The need to act towards zero-pollution needs to consider the limited time remaining to
recoup the necessary investments for internal combustion engines in the cars/vans
segment as well as the limited number of heavy-duty vehicles sold each year to recoup
the necessary investment costs in the lorries/buses segment. For both vehicle segments,
the design of policy options needs to consider options that are achievable with existing
technologies and in a timely manner for introduction into vehicles by 2025.
By accelerating investments in going beyond exhaust emissions, as the Euro standards
need also cover particles emissions from brakes and tyres and battery durability, the EU
automotive value chain can continue to build up its competitive position in the fast
growing new market of zero-emission vehicles.
72
COM(2021) 811 final. The New EU Urban Mobility Framework
13
Figure 4 – Problem tree
2.1.1 Problem 1: Complexity of vehicle emission standards
The overwhelming majority of the respondents (98 of the 128) to the public
consultation73
from all stakeholder groups consider the Euro 6/VI emission standards to
be complex or even very complex, for the cars/vans as well as the lorries/buses
segment74
. While some stakeholders from industry consider this complexity to be
justified to ensure that vehicles are clean, the majority of stakeholders from Member
73
See Annex 2: Stakeholder consultation, Public Consultation, Question 8
74
Arabic numerals refer to Euro emission standards for cars and vans, Roman numerals refer to Euro
emission standards for lorries and buses.
14
States, civil society and citizens see complexity as a factor hampering the necessary
reduction of pollutant emissions from road transport.75
While the overall architecture of the Euro emission standards is complicated, the
evaluation of the efficiency of the Euro 6/VI rules has shown that in particular shift from
Euro 5/V to Euro 6/VI increased such complexity.76
A full overview of the Euro 6/VI
emission standards, including the multiple dates of introduction of different
requirements, clearly demonstrates it.77
Euro 6/VI rules were built on the legislative text
of their predecessors, adding new requirements on top of the already existing ones while
not always referencing the UN international harmonised testing procedures or
eliminating obsolete tests. As a result, the Euro 6/VI implementing Regulations span a
total of more than 1.300 pages to define properly laboratory testing and on-road testing
procedures for granting type-approval, Conformity of Production and In-Service
Conformity.78
The evaluation showed that moving from Euro 5/V to Euro 6/VI emission standards has
resulted in significant increase of costs during implementation phase for vehicle
manufacturers, consisting of testing and witnessing costs79
, type-approval fees80
and
administrative costs81
. The increase of these costs was mainly caused by more robust on-
road tests, however this was not accompanied by the removal of tests that became
obsolete. The costs of testing of pollutant emissions and of witnessing those tests by
type-approval authorities in the facilities of the manufacturers are estimated to have
increased about 50% per engine family82
for lorries/buses. Also for cars/vans, the
manufacturers’ effort related to the testing have doubled with the introduction of Euro 6
and quintupled with the introduction of RDE testing. The administrative costs increased
up to 50%, due to the additional manufacturers’ time and effort needed to meet the
obligations to provide information. These costs are expected to stay rather stable over
time, until new testing requirements are included.76
The complex matrix of Euro 6/VI rules is particularly burdensome for the type-approval
authorities and technical services. Both have experienced considerable increase of costs
in terms of human resources to perform additional testing and witnessing and in terms of
time it takes to complete a type-approval process. 76
75
See Annex 2: Stakeholder consultation, Public Consultation, Question 10
76
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.2 Efficiency, Evaluation question 4
77
CLOVE, 2022. Technical studies for the development of Euro 7: Simplification. ISBN 978-92-76-
56405-8.
78
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 2.1 Description of Euro 6/VI emission
standards and its objectives
79
Testing and witnessing costs: Recurrent costs for testing in the context of type-approval, in-service
conformity and conformity of production performed or witnessed by type-approval authorities in the
facilities of the manufacturers.
80
Type-approval fees: Recurrent costs including the fees for granting type-approval paid to type-approval
authorities, excluding the witnessing costs.
81
Administrative costs: Recurrent costs including costs for reporting and to fulfil other information
provision obligations as part of the process for granting type-approval, CoP and ISC.
82
Manufacturers are allowed to group cars/vans to model families, and lorries/buses, for which engines are
tested, to engine families. All members of the family shall comply with the applicable emission limit
values.
15
2.1.2 Problem 2: Obsolete vehicle pollutant limits
The second problem identified in the evaluation of the Euro 6/VI emission standards are
obsolete vehicle pollutant limits, for the cars/vans as well as the lorries/buses segment.83
The limits are of particular concern given that they were adopted over a decade ago (and
assessed more than two decades ago). While the testing procedures for cars, vans,
lorries/buses have been adjusted over the different steps of Euro 6b-d and Euro VI A-E,
the emission limits were set as early as 2007 for cars/vans, and 2009 for lorries/buses.
The evaluation of the Euro 6/VI effectiveness made clear that the emission limits have
achieved reductions for regulated NOx, PM, CO, CH4, THC and NHMC pollutants (see
Table 1). However, these emission reductions would have been much higher if more
pollutants than only NOx and PN were measured on the road and if state-of-the-art
emission control technologies had been used.84
In addition, the evaluation of the Euro 6/VI has made clear that new harmful pollutants
are emitted by road transport.85
The use of new engine types, emission control systems,
fuels and additives has led to worrying levels of pollutant emission not regulated by Euro
6/VI that cause significant harm to the environment and human health (ultrafine particles,
N2O, HCHO, non-exhaust brake- and tyre wear emissions and, for cars/vans, CH4 and
NH3). Table 1 shows that much lower emission reduction for unregulated pollutants
compared to regulated pollutants is observed. N2O emissions even increased by 160%
between 2010 and 2018 due to the use of catalysts.86
Table 1 – Pollutant emissions from road transport in 2018 compared to 2010, Source:
SIBYL 202187
Pollutant Regulated under
Euro 6/VI?
Air pollutant or
GHG?
2010 2018
NOx yes Air pollutant 3 674 kt 3 381 kt -8%
PM2,5,total no Air pollutant 174 kt 109 kt -37%
PM2,5,exhaust yes Air pollutant 134 kt 67 kt -50%
PN10 PN23 Air pollutant 2,1x1026
1,0x1026
-51%
CO yes Air pollutant 4 941 kt 3 210 kt -35%
THC yes Air pollutant 795 kt 455 kt -43%
NMHC yes Air pollutant 738 kt 406 kt -45%
NH3 HDV only Air pollutant 75 kt 45 kt -40%
CH4 HDV only GHG & air
pollutant
57 kt 50 kt
-12%
N2O no GHG & air
pollutant
28 kt 73 kt
+160%
While many technologies to further limit the emissions of regulated or unregulated
pollutants have been developed since the adoption of Euro 6/VI and are mostly available
on the market, only some high-end manufacturers adopted them proactively. Even more
83
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 6 Conclusions
84
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.1 Effectiveness, Evaluation question 1
85
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.3 Relevance, Evaluation question 6
86
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7.
87
SIBYL, 2021: Ready to go vehicle fleet, activity, emissions and energy consumption projections for the
EU 28 member states
16
advanced technologies that allow additional emission reductions are already under
development and will become available in the near future. These developments
demonstrate a significant untapped past and future potential of road transport emission
reductions that could have been achieved and can be achieved if such advanced emission
control technologies are used.
2.1.3 Problem 3: Insufficient control of vehicle real-world emissions
It is eye-catching that a majority of stakeholders from all groups consider that real-world
emissions are not adequately monitored (72 out of 124) over the lifetime of vehicles, for
the cars/vans as well as the lorries/buses segment.88
More than half of the respondents
from Member States and civil society89
are not convinced that RDE testing ensure that
vehicles are compliant with the pollutant limits in “all driving conditions” (while RDE
addresses only “normal conditions of use”).88
This is reinforced by the scientific
assessment performed during the supporting studies which estimates the distribution of
the actual driving mileages in the EU. Approximately 20% of current driving mileages in
Europe are estimated to be outside the RDE legal boundaries and therefore may exceed
significantly the current emission limits63
. Driving conditions or trips that are excluded
from RDE testing are usually characterized by too low (less than -7°C) or too high
ambient temperatures (more than 35°C), too aggressive driving, high altitude, etc. In
addition, too short (i.e. less than 15 000 km) or too long car mileage (more than 100 000
km) are also not part of RDE.
In 2017 real-world emissions of NOx were still several times above the allowed Euro 6
limit. Even though the latest Euro 6d step, adopted in the wake of Dieselgate, has
endeavoured to close this gap between real-world and type-approved emissions, evidence
from the evaluation of Euro 6/VI shows that this step only partially achieved it.90
Such
partial success is at least to a certain extent result of the regulatory choices made at the
time of adoption of the first Real Driving Emissions Regulation91
.
Moreover, Euro 6/VI durability requirements are significantly below the actual lifetime
of vehicles in the EU. While the average age of cars on EU roads is around 10.8 years,
the Euro 6 emission standards take into account a lifetime of only 5 years. Similar
discrepancies in the durability requirements are found for vans, lorries/buses (see Annex
5, Table 46). Since in-service conformity of vehicles and durability of their pollution
control devices is checked only for the prescribed 5 years, emissions are not properly
controlled over the entire lifetime of vehicles.92
An additional issue that was identified in the recent proposal of a Battery Regulation93
,
relates to the lack of control of the durability of the propulsion batteries in plugin hybrid
and battery electric vehicles. This problem may lead to lack of consumer trust in such
88
See Annex 2: Stakeholder consultation, Public Consultation, Question 14
89
7 of the 12 Member State respondents disagreed that RDE testing ensures that cars/vans are compliant
with the pollutant limits in all driving conditions (10 of the 18 respondents from civil society), and 6 of the
11 Member State respondents disagreed that that lorries/buses are compliant with the pollutant limits in all
driving conditions (8 of the 15 respondents from civil society).
90
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.1 Effectiveness, Evaluation question 2
91
In regards the scope of RDE testing boundary conditions and introduction of a conformity factor.
92
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.3 Relevance, Evaluation question 6
93
Proposal for a Regulation of the European Parliament and of the Council concerning batteries and waste
batteries, repealing Directive 2006/66/EC and amending Regulation (EU) No 2019/1020, COM(2020)
798/3.
17
new technologies but also higher emissions in the case of plugin hybrids, where
deterioration in the battery capacity will result in higher emissions from the internal
combustion engine.
2.2 What are the problem drivers?
2.2.1 Drivers behind the complexity of vehicle emission standards
 Lack of technology-neutral and coherent emissions standards
The Euro 6/VI emission standards lack technology-neutrality. Different combustion
engine technologies, spark-ignition (petrol), compression-ignition (diesel), used in the
same vehicle category – cars, vans or heavy-duty vehicles – have to comply with
different emission limits. Such differences of limits stringency and implementation dates
result from the intention, at the time of their setting, to provide more flexibility for diesel
technology. This distinction can no longer be supported.
Such technology preference limited the effectiveness and internal coherence of the
standards in reducing pollutants emissions from road transport.94
While diesel cars are
allowed to emit 80 milligrams of NOx/km, petrol cars have to comply with a more
stringent limit of 60 milligram NOx/km. Hence, sufficient NOx emission reduction is not
achieved by diesel cars despite availability of appropriate emission control systems.
Moreover, the PN limits do not apply to all petrol vehicles as the rules exclude port fuel
injection (PFI) vehicles, which have an estimated share of 30% of new petrol vehicle
registrations in 202095
.
89 out of 128 stakeholders from all groups participating in the public consultation
confirm that different limits based on fuel and technology are complex – with Member
States being relatively more convinced of this than industry.96
According to Member States and civil society, separate regulatory frameworks between
LDVs, and HDVs, are not coherent and contribute to complexity.96
While the obligations
for emissions testing for LDVs and HDVs set out in the implementing Regulations97
are
relatively different, the architecture of the basic acts of Euro 6 and Euro VI98
is almost
identical. This calls for a single basic act for both vehicle categories.
 Different application dates of Euro 6/VI limits and tests
Another driver of complexity for Euro 6/VI emission standards is the gradual phase- in of
different steps of Euro 6b-d and of Euro VI A-E, in combination with different
application dates for different vehicle categories and, additionally, for new types of
vehicles and for all new vehicles. Different emission limits due to different technologies
(see above) required different application dates and specific testing procedures, which
moreover continued to be improved.
94
See footnote 84; see Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.4 Coherence,
Evaluation question 7
95
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 2.1 What is/are the
problem(s)?
96
See Annex 2: Stakeholder consultation, Public Consultation, Question 9
97
Regulation (EU) 2017/1151 and Regulation (EU) No 582/2011
98
Regulation (EC) No 715/2007 and Regulation (EC) No 595/2009
18
119 out of 128 respondents to the public consultation from all stakeholder groups
indicated that different application dates for Euro 6/VI steps are complex.96
Industry
indicated that it would have been better to define the steps of Euro 6 b-d and Euro VI A-
E at the time of Euro 6/VI adoption, instead of continuous addition of the steps, with no
sufficient lead-time to industry.84
 Multiple and complex emission tests
The procedures and, to a lesser extent, the number of emission tests were pointed out by
stakeholders from all groups as complex or even very complex features of Euro 6/VI.99
In
the targeted consultation, industry stakeholders pointed to the complexity of the test
procedures as resulting in errors in performing of emission tests and calculations. Testing
complexity required additional costly capacity-building by manufacturers in order to
comply with the legislation. This significantly increased the overall costs during
implementation phase (see 2.1.1).100
Moreover, the evaluation identified various
technical inconsistencies in the legislation.101
2.2.2 Drivers behind obsolete vehicle pollutant limits
 Non-exhaustive use of technological potential for reducing emissions
Technological potential exists for reducing emissions by using best available emission
control technology. There are advances in thermal management, engine controls, filters
and catalyst technology in petrol and diesel powertrains available on the market that
allow vehicles to achieve emission significantly lower than the Euro 6/VI levels.102
In
addition, existing sensor technologies may contribute to the digital transformation and
allow keeping emissions under well under control throughout the lifetime of a vehicle.
Therefore obsolete vehicle emission limits for regulated pollutants may be corrected, i.a.
by introducing updated emission limits that lead to the use of available technology. In the
public consultation, the large majority of respondents (55 out of 67) from Member States,
civil society and citizens indicated that current technology offers room for additional
emissions reductions. Industry had different views on the matter103
.104
 Some technologies to reduce emissions of regulated pollutants cause emissions of
new pollutants
Reduction of a given pollutant may result in higher emissions of another unregulated
pollutant. This is for example the case for NH3 emissions resulting from cars/vans. The
emission control technologies that are necessary to comply with NOx emission limits may
cause a so-called ammonia slip due to excess dosing of urea.64
To tackle such collateral
emissions, additional technologies are already used on a voluntary basis.
99
See Annex 2: Stakeholder consultation, 2.2.1. Evaluation Euro 6/VI emission standards
100
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2.1.3.1 Costs for
vehicle manufacturers
101
Such inconsistencies include differences in the provisions for type-approval and In-Service Conformity
for specific vehicles or obsolete smoke opacity tests. (See Annex 5: Evaluation Euro 6/VI emission
standards, chapter 5.4 Coherence, Evaluation question 7)
102
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
103
19 of the 59 industry respondents agreed that the current emission control technology creates room for
additional reductions in emissions, while 20 disagreed to the statement and 20 neither agreed nor disagreed.
104
See Annex 2: Stakeholder consultation, Public Consultation, Question 12
19
 Not yet regulated emissions of concern today
The introduction of new technologies in the vehicle fleet over the last decade, such as
gas-fuelled heavy-duty vehicles that are expected to reach 5% market share by 202595
,
emit new pollutants. They are currently not covered by Euro 6/VI standards, although
they are of concern, as confirmed in the evaluation of Euro 6/VI and the public
consultation by all stakeholders105106
.
The current PN limits take into account particles larger than approximately 23 nm. As
research shows, particles smaller than 23 nm, may have detrimental health effects as they
can enter the bloodstream, thus reaching all organs. However, they are not yet covered in
Euro 6/VI107
.
CH4 emissions are up till now only regulated for lorries/buses. Natural gas lorries are
expected to play a role in decarbonisation agenda, especially if blended with bio-methane
or if full bio-methane is used. As CH4 fuel use is projected to increase (e.g. new
registrations of CNG cars108
), limiting this greenhouse gas and ozone precursor also for
cars/vans becomes important.
Brake and tyre emissions have become increasingly relevant sources of particles,
especially since the exhaust particles were drastically diminished with the use of particle
filters. This is due mainly to the number of vehicles on the road and km travelled leading
to an increase of road transport activity from 3 200 Gvkm in 2010 to 3 500 Gvkm in
2018 (see Figure 6 in section 5.1) but also due to the increasing share of heavier and fast-
accelerating vehicles such as SUVs and electric vehicles, although the later somewhat
reduce such emissions by regenerative braking. In 2018, PM10 emissions from tyre and
brake wear were equivalent to the PM10 levels of emissions that originate from the
tailpipe of light- and heavy-duty vehicles6
. According to the existing literature, it is
expected that the non-exhaust contribution to vehicle-related PM10 emissions will reach
90% of total PM10 emissions in 2040 (see Figure 2). This is mainly due to the drop of
exhaust emissions and the fact that brake- and tyre-wear is emitted by all types of
vehicles, including zero-emission vehicles. In particular brake wear is recognized as the
leading source of non-exhaust particles, harmful to human health due to its smaller size
and composition and is emitted also by zero CO2 emission vehicles. A method for
measuring brake wear emissions is under validation in the Particle Measurement
Programme of the UNECE109
.
2.2.3 Drivers behind insufficient control of vehicle real-world emissions
 Limited effectiveness of On-Board Diagnostics
On-Board Diagnostics (OBD) monitor the functioning of powertrain systems and
emission control technologies, in order to identify possible areas of malfunction during
the life of the vehicle and inform the user of the need to carry out vehicle maintenance.
105
See Annex 2: Stakeholder consultation, Public Consultation, Question 12.2
106
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.3.1.4 Do the standards
properly cover all relevant/important types of pollutant emissions from vehicles that pose a concern to air
quality and human health? Are there important types of pollutant emissions that are not covered?
107
Giechaskiel, B. & Martini, G., 2014. Review on engine exhaust sub-23 nm solid particles
108
European Alternative Fuels Observatory, 2020. Vehicles and fleet
109
UNECE, 2021. UNECE to develop global methodology to measure particle emissions from vehicles’
braking systems
20
The OBD is verified during In-Service Conformity (ISC) checks, Periodic Technical
Inspections (PTI) – which take place at fixed intervals – and Roadside Inspections (RSI)
– for which commercial vehicles are selected on the road.33
However, 78 of the 120 respondents to the public consultation from all stakeholder
groups indicated that the limited effect of OBD measurement at least somewhat
contributes to maintaining high levels of pollutant emissions110
. In addition, 17 out of 28
respondents from Member States and environmental NGOs to the public consultation
indicated that OBD does not ensure that new vehicles are compliant with the pollutants
limits over their entire lifetime, while industry respondents are generally less sceptical on
the functionality of OBD111
.88
Evidence provided to the Euro 6/VI evaluation study by
four key stakeholders – one from industry, one type-approval authority, one research
institution and one environmental NGO – and the relevant JRC report revealed that the
current OBD systems have only limited capacity to address durability and are ineffective
in detecting and diagnosing degradation, failure or tampering of pollution-control
devices.112
,113
In addition, today’s developments in the field of continuous emission
monitoring allow for more comprehensive monitoring which is so far not properly
reflected in the Euro 6/VI durability requirements.114
This shows that despite the enhancement of the OBD thresholds in Euro 6/VI, the current
OBD requirements do not allow for proper checks of emissions during the lifetime of
vehicles or emission testing during ISC, PTI and RSI. 101
 Limited representativeness of on-road tests
Another driver of insufficient control of vehicle real-world emissions is the limited
representativeness of the on-road tests. The shift towards RDE and PEMS testing in Euro
6/VI emission standards introduced a wide range of load, speed, temperature and altitude
conditions to make sure that the emission limits are respected under a broad range of
real-world driving conditions. However, not all driving conditions are covered by RDE
and PEMS testing. Emissions tend to be higher outside the coverage of RDE and PEMS
and important emissions remain therefore unaccounted for in the current testing115
. NOx
emissions, for example, were found to increase by 1.6 to 1.7 times in low ambient
temperatures.116
,102
 Inadequate durability and emission control tampering provisions
A final driver for insufficient control of vehicle real-world emissions is the risk of
ageing, lacking maintenance and tampering117
of vehicles and their emission control
110
See Annex 2: Public Consultation, Question 15
111
40 of 58 industry stakeholders that answered the question agreed that OBD ensures that new vehicles
are compliant with the pollutant limits over their entire lifetime.
112
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.4.2.1.3 Vehicle
roadworthiness legislation
113
JRC 2021 Technical Report: “Vehicles Odometer and Emission Control Systems - Digital Tampering
and Countermeasures”, Jose Luis Hernandez Ramos (JRC), L. Sportiello (JRC).
114
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.3 Relevance, Evaluation question 6
115
This is the case for short trips, idle times, low speed, strong acceleration, high loads, high altitude
circuits and severe temperature conditions in which emissions are usually considerably higher.
116
As another example, low speed driving, which is not covered in the current RDE tests, has been linked
to high pollutant emissions (See Annex 5: Evaluation Euro 6/VI emission standards, Figure 22 – Emission
performance of Euro 6d vehicles for NOx for different average speeds, based on CLOVE, 2022)
117
Regulation (EC) No 595/2009 defines tampering as “inactivation, adjustment or modification of the
21
technologies. The evaluation of Euro 6/VI emission standards emphasised that the
current durability requirements cover only the first half of the vehicle life (see 2.1.3).
Considering this and the increasing complexity of pollution-control devices, there is a
need for a more complete demonstration of durability in order to provide effective
emission control over the lifetime. 84
The replies from stakeholders from all groups to the public consultation have proven that
tampering (117 of the 124 replies), vehicle ageing (114 of the 127 replies) and the cost of
vehicle maintenance (101 of the 123 replies) have contributed to an increase in real-
world pollutant emissions. These results indicate that Euro 6/VI rules are not effective to
prevent tampering and to control effectively emissions throughout the vehicle lifetime.110
2.3 How will the problem evolve?
When considering the negative effects of air pollutant emissions from vehicles on human
health and environment, improvements are expected over time in the absence of new
action, for the cars/vans as well as the lorries/buses segment (see Figure 2 in section 2.1).
Fleet renewal will lead to an increased share of Euro 6/VI vehicles in the vehicle mix. As
only 20% of cars/vans, and 34% of lorries/buses in the fleet are of Euro 6/VI standards in
2020, including RDE testing, the benefits of cleaner Euro 6/VI vehicles compared to
previous Euro vehicles will continue to be felt in the coming years on EU road as older
vehicles are replaced by these new cleaner Euro 6/VI vehicles.84
In addition, significant positive effects on air quality can be expected from the adoption
of the package of proposals to make EU's climate policies fit for reducing net greenhouse
gas emissions by at least 55% by 2030 (‘fit-for-55 package’) in July 2021118
. The
proposed amendment of the CO2 emission performance standards for new cars and vans
sets an end-date of 2035 for placing new combustion-engine cars and vans in the EU
market12
. Additional effects from the planned revision of Ambient Air Quality Directive
in 2022, which are estimated to be limited compared to the effects of CO2 emission
standards, cannot be taken into account yet, but as explained earlier compliance with air
quality standards cannot be achieved without more stringent emission limits for motor
vehicles. See details in section 5.1.
At the same time, Figure 2 shows that there is need to act towards zero-pollution in the
cars/vans as well as the lorries/buses segment to improve our health and well-being in
line with the Zero-Pollution Action Plan and in particular in cities. See details in Box 1 in
section 2.1.
3 WHY SHOULD THE EU ACT?
3.1 Legal basis
The Euro emission standards are based on Article 114 of the Treaty of the Functioning of
the European Union. According to this Article, the European Parliament and the Council
shall adopt measures which have as their object the establishment and functioning of the
vehicle emissions control or propulsion system, including any software or other logical control elements of
those systems, that has the effect, whether intended or not, of worsening the emissions performance of the
vehicle”
118
Press release 14 July 2021. European Green Deal: Commission proposes transformation of EU economy
and society to meet climate ambitions
22
single market. Furthermore, the Euro emission standards have the objective to ensure a
high level of environmental and health protection.
3.2 Subsidiarity: necessity and added value of EU action
The evaluation of Euro 6/VI emission standards emphasized the necessity and added
value of EU action in this policy domain by illustrating that both action at national or
international level are unlikely to lead to optimal outcomes119
since both air pollution and
road transport have a transboundary nature. Secondly, the development and governance
of emission standards at EU level is key to ensure properly functioning single market.
Differences in air quality policy ambitions among Member States could easily lead to a
patchwork of different national measures (e.g. to measures limiting access to certain
areas) that would create considerable obstacles for industry and pose great risk to the
single market. Hence, continued harmonised EU action to further reduce vehicle
emission is fully justified. In conclusion, the objectives of the proposed action cannot be
achieved sufficiently by the Member States acting alone and can be better achieved at
Union level by reason of scale or effects of that action.
4 OBJECTIVES: WHAT IS TO BE ACHIEVED?
4.1 General objectives
The general objective of the initiative is twofold: (1) to ensure the proper functioning of
the single market by setting more adequate, cost-effective and future-proof rules for
vehicle emissions; and (2) to ensure a high level of environmental and health protection
in the EU by further reducing air pollutants emission from road transport towards zero-
pollution, as required by the Zero Pollution Action Plan, as rapidly as possible.
4.2 Specific objectives
This initiative will contribute to achieving the general objective by pursuing the
following three specific objectives in line with the identified problems, relevant for the
cars/vans as well as the lorries/buses segment (see chapter 2). It will:
1) Reduce complexity of the current Euro emission standards. This specific objective
directly addresses the defined problem of complexity in the standards. Tackling
complexities would allow for reduced administrative costs and costs during
implementation phase and would facilitate efficient implementation of the Euro
standards.
2) Provide up-to-date limits for all relevant air pollutants. This specific objective
addresses the problem of obsolete vehicle pollutant limits in the Euro 6/VI emission
legislation which prevent further reduction of air pollutants emission from road
transport. Up-to-date limits based on best available technology and today’s
knowledge on emission controls will allow to curb harmful emissions. That way, the
functioning of the single market could be ensured, together with high level
environmental and health protection in the EU.
3) Improve control of real-world emissions. This specific objective is a direct response
to the problem of current RDE boundaries that do not cover all conditions of use
119
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 5.5 EU-added value
23
throughout the lifetime of the vehicle which prevent further reduction of air
pollutants emission from road transport. Achieving this objective would reduce
vehicle emissions in a more systematic manner and improve environmental and
health protection in the EU. It could also help guarantee the functioning of the single
market by addressing challenges associated with urban vehicle access restrictions.
Figure 5 – Euro 7 objectives
5 WHAT ARE THE AVAILABLE POLICY OPTIONS?
5.1 What is the baseline from which options are assessed?
The baseline to assess impacts of the policy options takes the following into account: a)
the Euro 6/VI emission standards, b) the impact of COVID-19 on road transport
activity120
and c) the impact of the new 55% (cars) and 50% (vans) CO2 targets by 2030
and 100% CO2 targets for cars and vans by 2035121
and the projected fit-for-55 HDV
fleet evolution to contribute to the 55% net greenhouse gas emission reduction by 2030
and the 2050 climate neutrality objective122
.
The baseline cannot take into account the effect of future potentially more stringent air
quality targets which may lead to more cities banning combustion-engine vehicles and
therefore modify road transport activity or vehicle sales, in the absence of more stringent
emission standards for motor vehicles. Such possible effect of future air quality targets
would be difficult to quantify since it will depend on local actions taken at Member
States level and will not be uniformly applied throughout the EU. However, this
additional effect from the planned revision of Ambient Air Quality Directive in 2022 is
estimated limited compared to the effects of CO2 emission standards.
120
Road transport activity is the volume-km driven by vehicles on EU roads and is projected by the
estimated evolution of vehicle sales.
121
A linear interpolation was used for the year 2030 for both the activity and shares of vehicles between
the two existing scenarios in the CO2 Impact Assessment (TL_Med and TL_High), while the TL_High
scenario was used for the year 2035. This approach is the estimated representation of the impact of the
Commission proposal for CO2 targets for cars/vans.
122
For heavy–duty vehicles, the activity and fleet shares of vehicles are based on the SWD(2020) 176 final,
Impact Assessment on Stepping up Europe’s 2030 climate ambition: Investing in a climate-neutral future
for the benefit of our people (part 1) and SWD(2020) 176 final (part 2), supplemented for buses by
CLOVE, 2022.
24
The baseline is a "no policy change" scenario which implies that the relevant EU-level
legislation, addressing air pollutant emissions resulting from road transport will continue
to apply without change. That means that Euro 6/VI applies, taking into account impact
of the CO2 targets for vehicles, including the aforementioned new CO2 targets for
cars/vans, and COVID-19 on road transport activity. It is referred to in chapter 6 as the
baseline.
a) Euro 6/VI emission standards
The Euro 6/VI emissions standards19
and in particular the air pollutant emission limits
and real-driving testing conditions set out therein are summarised in Annex 5, Table 34
and Table 35. They are assumed to remain in force. Moreover, as shown in Annex 5,
Figure 19, the baseline assumes that fleet renewal would lead to a higher share of Euro
6/VI vehicles in the vehicles mix, mostly with cars/vans introduced under Euro 6 d step.
The benefits of cleaner Euro 6/VI vehicles compared to previous Euro norms will
increase in the next years as older vehicles are replaced with clean ones.84
b) Impact of COVID-19 on road transport activity
The COVID-19 pandemic continues to have significant impacts on the automotive sector,
which will shape the sector for years to come. First, various lockdown measures had
significant impact on sales. Following the 6,1% decrease of the EU GDP in 2020123
,
demand for new passenger and light commercial vehicles dropped by respectively 23.7%
(to 9.9 million units) and 18.9% (to 1.7 million units) in 2020 as a direct result of the
pandemic.124
The full long-term effects on the industry will only become clear after the
pandemic has come to an end and will largely depend on the pace of the economic
recovery125
. Over the first half of 2021, passenger car sales increased by 25.2% to almost
reach 5.4 million units registered in total. However, this is still 1.5 million units below
the 2019 pre-crisis level for the same period.126
In addition, industry is facing shortages
of semi-conductors. This shortage limits the capacity of industry to satisfy demand which
is already at historically low levels. Demand is only expected to return to the pre-
pandemic levels by 2023.127
This may affect the capacity of the industry to invest in new
technologies. See Annex 7 for more details on the impact of COVID-19 on automotive
industry.
The baseline takes into account the indirect impact of the COVID-19 pandemic on
vehicle emissions, mostly through its effect on transport activity and fuel consumption.
Estimations from the impact assessment on the 2030 climate target plan128
indicate that
the projected decrease of total fuel consumption of road transport was about 17% in 2020
compared to 2019. In addition, the JRC estimated that between February and April 2020
a total drop in vehicle activity of 60-90% for passenger cars compared to a 15% drop for
freight transport.129
123
Eurostat, 2021. Real GDP growth rate - volume
124
ACEA, 2021. Press release: Passenger car registrations: -23.7% in 2020; -3.3% in December 2020;
ACEA, 2021. Press release: Commercial vehicle registrations: -18.9% in 2020; -4.2% in December 2020
125
European Commission, 2021. Spring 2021 Economic Forecast: Rolling up sleves
126
ACEA, 2021. Passenger car registrations: +25.2% first half of 2021; +10.4% in June
127
BCG, 2020. COVID-19’s Impact on the Automotive Industry
128
SWD(2020) 176 final, Impact Assessment on Stepping up Europe’s 2030 climate ambition: Investing in
a climate-neutral future for the benefit of our people (part 1) and SWD(2020) 176 final (part 2)
129
JRC, 2020. Future of Transport: Update on the economic impacts of COVID-19
25
Based on this evidence and taking into account the impacts of COVID-19 on GDP, the
impact of the pandemic on road transport activity in various vehicle segments has been
estimated. The short-term estimates point to a sharp activity drop of 15% in 2020,
followed by significant recovery in 2021. Nevertheless, by 2030 the pandemic and
following crisis are projected to result to a permanent loss in total road transport activity
of 6% compared to the pre-COVID levels. Figure 6 presents the projected evolution of
transport activity taking into account the COVID-19 drop as counterfactual. In addition,
reduced private transport activity is assumed due to promotion of public means of
transport and advancing modal shifts to other than road transport means, especially when
it comes to passenger transport.128
The total activity for passenger transport in 2050 is
projected to 6.4% lower, whereas the activity levels for freight transport are not assumed
to differ. The counterfactual evolution of road transport activity is taken into account in
the baseline.
Figure 6 – Evolution of total road transport activity in EU-27 considered in the baseline
(in volume-km)130
c) CO2 emission performance standards
The CO2 targets for vehicles laid down in the CO2 Regulation, including the new CO2
targets for cars/vans proposed in July 202112
, also contribute to reduction of air pollutant
emission from road transport. This is due to the increased sales of zero- and low-emission
vehicles that are triggered by stringent CO2 targets for light- and heavy-duty vehicles,
scaling up towards an end-date of 2035 for placing new combustion-engine cars and vans
in the EU market. Electric and fuel cells powered vehicles do not have tailpipe emissions
but do emit particles from brakes and tyres. Low-emission vehicles, such as plugin
hybrids, also have less tailpipe air pollutant emissions. The CO2 targets, including the
new CO2 targets proposed for cars/vans and the projections for heavy-duty vehicles, and
their impact on the vehicle fleet, are included in the Euro 7 baseline.
130
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 4.2 The impact of
COVID-19 on the baseline development.
26
As can be seen in Figure 7, the share of new zero- and low-emission vehicles in the
European vehicle fleet is projected to increase substantially over time, for LDVs much
faster than for HDVs. The share of new zero-emission cars/vans is expected to increase
from 9% in 2025 to 100% in 2035, whereas the share of hybrid and low-emission
vehicles is expected to decrease from 35% in 2025 to 0% in 2035. The share of ICE
cars/vans is expected to decrease from 56% in 2025 to 0% in 2035.
The projected vehicle fleet evolution is different for HDVs131
. In particular long-haul
lorries are not projected to shift swiftly to zero- and low-emission performance due to
their need for high powered engines and long trips, while the electrification of buses is
expected to happen faster due to their predominant use in urban areas. The share of ICE
HDVs is expected to decrease from 70% in 2025 to 6% in 2050, whereas share of hybrid
and other low-emission lorries is expected to increase from 26% in 2025 to 33% in 2050.
New zero-emission lorries are expected to constitute 61% of the total in 2050.
Figure 7 – Projected powertrain changes in the vehicle fleet in EU-27 of new registration
of (a) cars/vans, (b) lorries and (c) buses in the baseline until 2050132
,133
131
The projected vehicle fleet evolution is consistent with the overall 55% net greenhouse gas emission
reduction by 2030 to achieve the 2050 climate neutrality objective.
132
A linear interpolation was used for the year 2030 for both the activity and shares of vehicles between
the two existing scenarios in the CO2 Impact Assessment (TL_Med and TL_High), while the TL_High
scenario was used for the year 2035. This approach is the estimated representation of the impact of the
Commission proposal for CO2 targets for cars/vans.
133
For heavy–duty vehicles, the activity and fleet shares of vehicles are based on the SWD(2020) 176 final,
Impact Assessment on Stepping up Europe’s 2030 climate ambition: Investing in a climate-neutral future
for the benefit of our people (part 1) and SWD(2020) 176 final (part 2), supplemented for buses by
CLOVE, 2022.
31.5%
18.4%
0.0% 0.0% 0.0% 0.0%
10.9%
6.1%
0.0% 0.0% 0.0% 0.0%
3.5%
8.7%
0.0% 0.0% 0.0% 0.0%
24.4%
10.6%
0.0% 0.0% 0.0% 0.0%
10.9%
4.5%
0.0% 0.0% 0.0% 0.0%
3.8%
6.3%
0.0% 0.0% 0.0% 0.0%
5.7%
4.8%
0.0% 0.0% 0.0% 0.0%
9.1%
39.6%
90.6% 90.2% 87.1% 83.5%
0.2% 0.9%
9.4% 9.8% 12.9% 16.5%
0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%
2025 2030 2035 2040 2045 2050
a) LDV (Cars & Vans) - New Registrations share
Fuel Cell
Electric
Other (gas)
Gasoline plug-in hybrid
Gasoline Hybrid
Gasoline Conventional
Diesel plug-in hybrid
Diesel Hybrid
Diesel Conventional
27
The contribution of a) Euro 6/VI vehicles, b) road transport activity and c) CO2-related
powertrain changes in the fleet to the evolution of NOx and PM2.5 emissions are shown in
Figure 2 in section 2.1. The NOx emissions are expected to decrease by 87% between
2015 and 2050. Exhaust PM2.5 coming from combustion-engine vehicles decrease
steadily over the next 30 years, while total PM2.5, include tyre- and brake emissions come
from all types of vehicles and therefore remain significant.
5.2 Description of the policy options
Table 2 gives a schematic overview of the policy options developed for this impact
assessment, while a detailed description of the policy options is available in Annex 6.
In light of creating an adequate, cost-effective and future-proof Euro 7 regulation
ensuring a high level of environmental and health protection in the EU, the policy options
consider the green and digital transformation required by the European Green Deal. The
transformation provides opportunities for more advanced solutions in terms of pollutant
emission reductions, such as the use of low emission technology and continuous
emission monitoring with advanced sensors and vehicle connectivity. The policy options
take also into account the shift to electrified powertrains requiring cost-effective and
adequate solutions for reducing pollutant emissions in the combustion-engine segment.
All options are relevant for the cars/vans as well as the lorries/buses segment, whereas
the impacts of the policy options are calculated separately for each segment in chapter 6.
All options presented in the tables require implementing legislation, with adequate lead
time for the industry. Elements such as measurement methodologies, procedures and
equipment, accuracy and repeatability of measurements, selection of vehicles and
statistical procedures will be part of the implementing legislation. Most of these elements
are either already available or under development both in the EU and in UNECE
framework. The work for the implementing legislation will start in 2022.
Table 2 - Description of the policy options
Baseline PO1 –
Low Green
Ambition
PO2a –
Medium
Green
Ambition
PO2b –
High Green
Ambition
PO3a – PO2a
and Medium
Digital
Ambition1
Simplification - Simplification
measures
Simplification
measures
Simplification
measures
Simplification
measures
Emission limits Euro
6/VI
Euro 6/VI but
technology-
neutral (60
Medium
Ambition
(30 mg/km
High Ambition
(20 mg/km
NOX,..)
Medium
Ambition
(30 mg/km
69.8%
50.8%
34.8%
13.7%
7.6% 5.6%
15.6%
23.0%
24.4%
26.5%
22.3% 23.0%
0.2%
0.3%
0.3%
0.4%
0.4% 0.4%
9.8%
15.4%
15.6%
12.6%
9.3% 10.0%
2.6%
6.5%
15.2%
25.9%
30.6% 29.5%
1.8% 4.0% 9.6%
20.9%
29.7% 31.6%
0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%
2025 2030 2035 2040 2045 2050
b) HDV (Lorries & Buses) - New Registrations share
Fuel Cell
Electric
CNG
LPG
Gasoline plug-in hybrid
Gasoline Hybrid
Gasoline Conventional
Diesel plug-in hybrid
Diesel Hybrid
Diesel Conventional
28
mg/km NOX,..) NOX,..) NOX,..)
Real-driving
boundaries
Euro
6/VI
Low ambition
of boundaries
(low/high
temperature…)
Medium
ambition of
boundaries
(+short trips…)
High ambition
of boundaries
(+high speed,
high altitude…)
Medium
ambition of
boundaries
(+short
trips….)
Durability Euro
6/VI
Euro 6/VI
(160 000 km or
8 years)
Average
Increase
(200 000 km or
10 years2
)
Full Increase
(240 000 km or
15 years3
)
Average
Increase
(200 000 km or
10 years2
)
Continuous
Emission
Monitoring
- - - - With available
sensors
1
A second sub-option in policy option 3 (i.e. PO3b – PO2a and High Digital Ambition) which added to
PO2a high ambitious continuous emission monitoring, i.e. the development of new sensors that would
require several years before they can be implemented, was discarded following the proposed end-date of
combustion engine cars/vans by 2035 (see 5.3).
2
For lorries < 16t, buses < 7.5t: 375 000 km and for lorries > 16t, buses > 7.5t: 875 000 km
3
For lorries < 16t, buses < 7.5t: 450 000 km and for lorries > 16t, buses > 7.5t: 1 050 000 km
In line with the specific objectives, all options aim at reducing complexity of the current
Euro emission standards by introducing simplification measures. Up-to-date emission
limits for all relevant air pollutants should be provided in PO1 with low ambition, in
PO2a and PO3a with medium ambition and in PO2b with high ambition. Control of real-
world emissions should be improved in PO1 by low ambitious real-driving testing
boundaries, in PO2a by medium ambitious real-driving testing boundaries and durability
requirements, in PO2b by high ambitious real-driving testing boundaries and durability
requirements and in PO3a by medium ambitious real-driving testing boundaries,
durability requirements and continuous emission monitoring. That means, the completely
new digital ambition of continuous emission monitoring to control real-world emissions
is considered in PO3 only.
As the policy options are built on existing emission control and sensor technology, it is
possible to introduce an application date of 1 January 2025 for all new registrations. As
adequate lead time is needed for the industry to implement new rules, all secondary rules
need to be finalised soon after entry into force of the Regulation.
The possibility for Member States to apply financial incentives at national level for early
implementation of Euro 7 (i.e. between its entry into force date and its application date,
i.e. the date by which all vehicles entering the market need to be Euro 7) are assumed in
the policy options.
The modular approach of the policy options was proposed in the inception impact
assessment and confirmed in the stakeholder consultations.
The simplification measures, emission limits, real driving boundaries, durability and
sensor requirements have been elaborated in the supporting studies63,77,134
and discussed
with stakeholders in the AGVES meetings.
134
CLOVE, 2022. Technical studies for the development of Euro 7: Durability of light-duty vehicle
emissions. ISBN 978-92-76-56405-8
29
5.2.1 Policy option 1 (PO1): Low Green Ambition
PO1 implies a narrow revision of Euro 6/VI emissions standards to tackle complexity of
the legislation (problem 1) somewhat addressing obsolete vehicle pollutant limits
(problem 2) and insufficient control of vehicle real-world emissions (problem 3) with a
low green ambition. This policy option was developed as a less intrusive approach.135
PO1 addresses key simplification and consistency challenges through refining the
architecture of the Euro 6/VI emission standards. It assumes that a single framework for
cars, vans, lorries/buses is developed, multiple application dates of Euro 6/VI steps are
avoided and the multitude and complexity of emissions tests is reduced. To ensure
technology-neutrality, this option foresees making the Euro 6/VI emissions limits
consistent across different ICE technologies (see Annex 6, Table 48). This improves only
marginally emission from diesel cars and vans, but all other emission remain the same, so
especially for lorries/buses there is no significant change. NH3 limit is extended for cars
and vans for the same reason it was already introduced for lorries and buses in Euro VI,
i.e. to control ammonia slip from the current generation of catalysts.
The measures aiming at refining and simplifying Euro 6/VI emissions testing (see Annex
6, Table 47) remove obsolete testing and other obsolete provisions. PO1 allows testing of
vehicles beyond the Euro 6d RDE and Euro VI E PEMS conditions (see Annex 6, Table
49). Both actions address the problem of insufficient control of vehicles’ real-driving
emissions with a low ambition. PO1 explicitly refrains from digital control of vehicles’
real-driving emissions, i.e. continuous emission monitoring that would be a completely
new element in the Euro standards and worldwide.
In light of creating a future-proof regulation, low-ambitious PO1 refrain from a green and
digital transformation in view of the shift to electrified powertrains.
5.2.2 Policy option 2 (PO2a and PO2b): Medium and High Green Ambition
PO2 implies a wider revision of Euro 6/VI emissions standards in order to tackle the
complexity of the legislation (problem 1), to address obsolete vehicle pollutant limits
(problem 2) and to partly address insufficient control of vehicle real-driving emissions
(problem 3). While a PO2a will tackle the last two problems with a medium green
ambition level, PO2b will address them with a high green ambition level.
PO2 builds on the same simplification measures as PO1. In addition, two ambition levels
(medium and high ambition) of pollutant emission limits and boundary conditions are
considered, to ensure up-to-date limits for all relevant air pollutants including some
unregulated ones (see Annex 6, Table 50 and Table 51). The new pollutants added are
HCHO, N2O, and particles from brakes136
. HCHO, CH4 and N2O emission limits are set
at the level of today’s emissions (i.e. a simple cap on emissions) to ensure that these
emissions do not disproportionately increase in future vehicles or with new fuels.
135
See Annex 2 Stakeholder consultation, Section 2.2 Analysis of responses
136
Next to brake emissions, tyre emissions are found to be a source of non-exhaust emissions as they
contribute to the formation of particles. As it is not yet technologically feasible to develop limits or tests for
tyre emissions, they cannot be assessed in this impact assessment and it is suggested to include a review
clause in Euro 7 proposal.
30
In addition, PO2 will cover comprehensive real-driving testing conditions with medium
or high ambition, to account for broader conditions than Euro 6d/VI E emission tests, e.g.
low ambient temperatures or low speed driving (see Annex 6, Table 52 and 53).
PO2 also considers the need to address inadequate durability provisions. PO2 extends the
requirements to comply with the emission limits for vehicles in use, i.e. the durability
provisions, over the current inadequate period in Euro 6/VI. While PO2a introduces a
medium ambition of durability provisions, e.g. 200 000 km for LDV; PO2b considers a
high ambition, e.g. 240 000 km for LDV (see Annex 6, Table 54). Durability
requirements will also cover propulsion batteries in PHEVs and BEVs, according to the
developments at international level137
.
In light of creating a future-proof regulation, PO2a considers a medium-ambitious and
PO2b a high-ambitious green transformation towards zero-emission vehicles. Both sub-
options refrain from a digital transformation, i.e. continuous emission monitoring that
would be a new element in the Euro standards and world-wide.
In the stakeholder consultations, automotive industry and civil society representatives
raised concerns, often having conflicting opinions, regarding the level of emission limits,
length of durability requirements and the technological potential for reducing emissions
over the lifetime of the vehicles. In addition to the different emission limits and durability
in the policy options for low, medium and high green ambition (see Table 2), an
alternative set of assumptions on emission limits and durability was therefore assessed to
address remaining uncertainty in the medium green ambition (see Annex 8).
5.2.3 Policy option 3 (PO3a): PO2a and Medium Digital Ambition
PO3 implies a profound revision of Euro 6/VI emission standards to tackle complexity of
the legislation (problem 1), to address obsolete vehicle pollutant limits (problem 2) and
to address insufficient control of vehicle real-driving emissions (problem 3) with a
medium green and digital ambition.
PO3 builds on the same simplification measures as PO1, on the medium ambitious air
pollutant emission limits, real-driving testing conditions and durability provisions of
PO2a given that the high ambitious emission limits of PO2b cannot be reliably measured
with either current or future sensor technology as was elaborated in the supporting
technical studies (see Annex 6, Table 50, 52 and 54).
In addition, new continuous emission monitoring of pollutants over the whole lifetime of
the vehicle is added in PO3. PO3a on Medium Digital Ambition is based on improved
versions of available sensor technologies for NOx, NH3 and partly PM (see Annex 6,
Table 55). Synergies with the on-board fuel consumption meters (OBFCM) introduced
under the CO2 emission performance standards138
will be exploited. PO3 would also
137
UNECE, 2021. UN GTR No 22 on In-Vehicle Battery Durability for Electrified Vehicles in
https://unece.org/transport/documents/2022/04/standards/un-gtr-no22-vehicle-battery-durability-electrified-
vehicles
138
Regulation (EU) 2019/631 setting CO2 emission performance standards for new passenger cars and for
new light commercial vehicles and Regulation (EU) 2019/1242 setting CO2 emission performance
standards for new heavy-duty vehicles both require in Article 12 that the Commission shall regularly
collect data on the real-world CO2 emissions and fuel or energy consumption of passenger cars, light
commercial vehicles and heavy-duty vehicles using on-board fuel and/or energy consumption monitoring
devices.
31
facilitate the implementation of geo-fencing that puts a vehicle automatically into zero-
emission mode when entering zero-emission zones.
New continuous emission monitoring is only part of PO3 because it adds a completely
new digital dimension to the Euro standards making PO3 overall the most profound
policy option. Such an approach has not been introduced up to now in any other emission
regulation world-wide. While this new measure was highly praised by stakeholders from
some Member States, component suppliers, civil society and citizens during the
consultation activities, vehicle manufacturers took a more sceptical position on the
matter.139
Taking the above into account, it was decided to not add new continuous
emission monitoring in PO1 to allow the assessment of lower ambition and less intrusive
policy option.
In light of creating a future-proof regulation, PO3a considers a medium-ambitious green
and digital transformation. Available pollutant sensors and the rise of connected vehicles
provide the opportunity for increased enforcement, by continuously monitoring the state
of the emission control systems. High emitting vehicles will thus be fixed earlier, or
tampering117
of vehicles will be avoided. Additional cost gains, which are not included in
this impact assessment, can be expected for the revision of the Roadworthiness
Directives by replacing costly inspection mechanisms with over-the-air control of
emissions.
A second sub-option, PO3b on High Digital Ambition, which would have been based on
future sensor technologies, such as PM/PN and NMOG, was discarded following the
proposed end-date of combustion-engine cars and vans by 2035 (see 5.3).
5.3 Options discarded at an early stage
During the technical work in support to the Euro 7 proposal, a variety of technology
driven policy option packages were evaluated both for light- and heavy-duty vehicles.
Such technology-driven policy option packages would lead to varying stringencies of the
emission limits. For light-duty vehicles 16 such variations were analysed (12 for gasoline
and 4 for diesel) both in terms of technology readiness as well as for their potential for
emission reduction. For heavy-duty vehicles 6 technology-driven policy option packages
were evaluated for diesel and gaseous fuelled engines. From these technology packages
only three levels were considered as compatible with the expected timeline of Euro 7 and
technically feasible without restricting driving habits and were therefore retained in the
policy options further analysed.140
Stakeholders’ responses to the different consultation areas (see Annex 2), make clear that
all three policy options initially developed for the inception impact assessment, i.e. PO1,
PO2 and PO3, presented for public and targeted consultation and discussed in AGVES
meetings received some support, although some simplification measures have been
rejected - see list after consultation in Annex 6, Table 47. No stakeholder group required
different ambition level and therefore policy options for the cars/vans and lorries/buses
segment.
139
See Annex 2 Stakeholder consultation, Section 2.2.5. Continuous emission monitoring
140
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
32
A second sub-option of PO3 (i.e. PO3b – PO2a and High Digital Ambition) was
discarded following the proposed end-date of 2035 for placing new combustion-engine
cars and vans on the EU market. PO3b added to PO2a high ambitious continuous
emission monitoring, i.e. more advanced sensors such as PN/PM or NMOG sensors that
are not yet available in the market and would require a few years of development before
being employed (see 5.2). This would require high investment costs for vehicle
manufacturers and component suppliers which would not be recuperated until 2035.
Sensors for vehicles are designed for application in all vehicles, light and heavy-duty
ones. With the planned end-date for combustion engines for cars and vans, the market for
such sensors diminishes significantly. Even though such sensors could eventually be
implemented in the heavy-duty sector for a longer period, such an investment for the
limited number of heavy-duty vehicles sold each year would not allow to recuperate the
high investment costs. Hence, PO3b was discarded, for light-duty as well as heavy-duty
vehicles, to only include policy options that are achievable with existing technologies and
in a timely manner for introduction into vehicles by 2025.
PO1 to PO3 are built in a modular approach by combining several policy measures with
increasing ambition levels. Hence, one could in principle build variations of these policy
options by making different combinations of measures. By changing the comprehensive
real-driving conditions from medium to high ambition in both PO2a and PO3a, all else
being equal, two other combinations of measures were assessed.141
Since neither of these
alternative combinations outperformed the effectiveness and efficiency of PO2a and
PO3a with medium ambition comprehensive real-driving conditions, these combinations
of measures were discarded at an earlier stage.
Next to the stakeholder support for building upon the Euro 6/VI emission standards with
PO1 to PO3, one could also think of solving the problems discussed in chapter 2 through
voluntary measures, especially considering that many technologies for further reducing
vehicle emissions are already available on the market. Nevertheless, their adoption is not
likely to happen using voluntary measures, as was already shown by the scarce
propensity of the industry to introduce any additional measures linked with emissions.
This was demonstrated clearly in the antitrust case of the Commission against three
major car manufacturers for restricting competition in emission after treatment systems
for new diesel cars.142
In particular, the manufacturers did not use better available
technology (AdBlue tanks), as this was not explicitly required by the type-approval
legislation. As discussed in section 2.3, this follows from the fact that emission control
technologies do result in costs and subsequently higher vehicle prices, while perceived
value of improved pollutant emissions performance by customers is often limited.
6 WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?
The quantification of the impacts of the three policy options, for the cars/vans as well as
the lorries/buses segments, relies on a number of models which use input of regulatory
costs and the emissions reduction performance of available or future technologies
necessary to comply with the different policy options. The models used, i.e. COPERT
and SIBYL, are amongst the most advanced in the field and are used widely both in
141
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 4.3
Description of the policy options.
142
European Commission, 2021. Press release: Antitrust: Commission fines car manufacturers €875
million for restricting competition in emission cleaning for new diesel passenger cars
33
Europe and around the world for the estimation of emissions from road transport. They
are at the basis of the national and EU submission of emission inventories to
Intergovernmental Panel on Climate Change (IPCC) and have been developed over the
years with input from numerous projects. A network of experts from 57 leading EU
institutions has been directing their development in Europe for the past decades143
.
Such detailed models are needed in order to provide adequate detail both on the
technological choices, mileage covered, vehicle age and other details which are crucial
for estimating the emissions from the European fleet now and in the future. Models often
used for other impact assessments assessing the fleet level (e.g. PRIMES, GAINS etc.)
are less suitable for detailed modelling at vehicle level required for estimating the effects
of changes in the type-approval legislation. Detailed information on the methodological
approach can be found in Annex 4.
Industry strongly opposes disproportionate burden which may eventually trigger a
decision to stop ICE production. They support in-between PO1 and PO2a solution. On
the other hand, there is a pressure from environmental and consumer organisations and
some Member States to set more ambitious requirements as in PO3a and PO2b to support
further improvement in air quality and thus contribute to protecting public health and the
environment, while it may be expected that such digital solution as proposed in PO3a
may raise concerns of social acceptability of continuous monitoring. However, such
potential concern of making pollutant data from vehicles available was not raised by
consumer organisations or citizens in the stakeholder consultations.
The aforementioned stakeholders were encouraged to verify or contest any result or
assumptions in the extensive public and targeted stakeholder consultations, including
interviews and confidential data sharing, and various AGVES meetings (see Annex 2). In
total, more than 200 experts were participating in each meeting. Feedback and
differences in stakeholders’ views received through these channels were carefully
analysed and taken into account. In the assessment of the impacts of the policy
options, in particular on industry competitiveness, consumer affordability and
employment, qualitative stakeholder data has been triangulated with quantitative
estimates and/or literary evidence depending on the specific impact (see each section
below). A detailed overview of the stakeholder views and the use of the consultation
results is included in Annex 2.
To ensure robustness of the analysis, the estimated impacts and their underlying
assumptions have been cross-checked with independent experts and the concerned
stakeholders, separately for the cars/vans and the lorries/buses segments. To address any
remaining uncertainty, the level of confidence for each regulatory cost category and the
health and environmental benefits was assessed. Based on the availability and quality of
information, data and shared input by stakeholders, the administrative costs and costs
during implementation phase (including testing and witnessing cost and type-approval
fees) are characterised by a high level of confidence, the equipment costs by medium
(R&D and related calibration costs) or medium-high (hardware costs for emission control
technology) confidence. Medium-high confidence is also assumed for the health and
environmental benefits that are calculated based on the models above and the
Commission’s Handbook on the external costs of transport.144
This medium to high level
of confidence of the cost and benefit estimates valid for the cars/vans as well as the
143
See Leading EU Models | ERMES GROUP (ermes-group.eu)
144
European Commission, 2019. Handbook on the external costs of transport
34
lorries/buses segments and verified by stakeholders and experts is considered sufficiently
robust to present in chapter 6 average values for the cost and benefit elements.
Nevertheless, the cost-benefit analysis in chapter 7 is complemented by providing ranges
of expected costs and benefits, separately for the cars/vans and the lorries/buses
segments, to make political choices based on the net benefits of the policy options. More
information can be found in Annex 4 section 1.3.2.1. Uncertainty.
6.1 PO1: Low Green Ambition
6.1.1 Economic impacts
6.1.1.1 Regulatory costs for automotive industry
The regulatory costs for automotive industry consist of substantive compliance costs
(equipment costs for emission control technologies and the related R&D and calibration
costs including facilities and tooling costs as well as costs during implementation phase
for testing, witnessing of tests by type-approval authorities and type-approval fees) and
administrative costs (reporting and other information obligations as part of the type-
approval procedures). A detailed description of the cost categories is available in Annex
5, Table 39.
The simplification measures introduced in PO1 aim at reducing complexity, eliminating
inconsistencies and improving effectiveness of the legislation. This policy option is
expected to result in some cost reductions, especially of costs during implementation
phase and administrative costs, largely due to the streamlined testing procedures or
removal of obsolete ones. However, these cost savings would be offset by the expected
increase in R&D, hardware and related calibration costs linked with technology-neutral
limits and extended real-driving testing for all vehicle categories except for
petrol/compressed natural gas (CNG) lorries/buses. For these vehicles, a small total
regulatory cost saving of €2 per vehicle is expected. For diesel lorries/buses, the
implementation of the simplification measures are expected to reduce costs during the
implementation phase and administrative costs by €49 per vehicle. However, such cost
savings would be offset by an increase in R&D and related calibration costs of €103 per
vehicle. The total regulatory cost for lorries/buses are estimated at €44 per vehicle.145
Also for cars/vans, no total regulatory cost savings are expected. While cost savings
during implementation phase and administrative cost savings are expected with the
simplification measures, these will likely be exceeded by hardware, R&D and related
calibration costs. The largest share of the latter costs follow from the need to ensure that
emission are also controlled in enhanced real-driving testing outside the current RDE
boundaries, while a smaller share is linked to introducing technology-neutral limits. In
all, the total regulatory cost for cars/vans for industry are estimated at €60 per vehicle.
To ensure that no administrative burden is added, administrative costs146
are assessed
145
The cost per vehicle is calculated by dividing the regulatory cost over the period 2025-2050 by the total
number of vehicles per vehicle category. This total cost is calculated by adding up all the different cost
categories (which include one-off and recurrent costs) (see Annex 5 Table 39) over their specific unit.
These units do not only include the number of new vehicle registrations per category, but also the number
of engine/model families, type-approvals, manufacturers and calibrations. Hence, the cost per vehicle and
regulatory cost is affected by changes in the fleet and in the specific unit.
146
Administrative costs are those costs incurred by stakeholders to comply with information obligations,
such as reporting or registration and include requirements for information documents, type-approval
35
separately. Euro emission standards trigger recurrent administrative costs, including costs
for reporting and compliance with other relevant information obligations as part of the
process for granting type-approval, Conformity of Production (CoP) and In-Service
Conformity (ISC).147
Since PO1 allows for reduction of the number of type-approvals and tests with reporting
requirements, the simplification measures translate into significant administrative cost
savings in all vehicle categories. For cars/vans, administrative cost savings are estimated
at €97 thousand per type approval for petrol cars/vans (€18 per vehicle) and at €126
thousand per type approval for diesel cars/vans (€17 per vehicle). For lorries/buses,
savings of €30 thousand are expected per diesel type-approval (€14 per vehicle) and of
€31 thousand per petrol type-approval (€31 per vehicle).
A detailed description of the total regulatory costs for automotive industry in PO1
compared to the baseline is available in Annex 4, section 1.3.1.1.
Table 3 presents the total regulatory costs in 5-year intervals over the period of
implementation of PO1. It shows that the largest share of the costs occur in the first five
years after 2025. Since PO1 does only introduce changes in the requirements and
emission testing for combustion-engine vehicles, the regulatory costs become zero after
the proposed end-date of combustion-engine cars and vans in 2035.
Table 3 – Expected distribution of total regulatory costs in PO1 compared to the
baseline, in billion € and 2025 NPV148
2025
2026-
2030
2031-
2035
2036-
2040
2041-
2045
2046-
2050
Total
Cars and vans 2.00 2.51 0.53 0.00 0.00 0.00 5.04
Lorries and buses 0.38 0.10 -0.09 -0.06 -0.04 -0.03 0.27
These costs consist of both recurrent costs (e.g. for hardware) – that increase with the
number of produced vehicles or type-approvals – and one-off costs (e.g. related to the
development of new emission control systems) that are expected to be similar for the
manufacturers, irrespective of size.149
Taking into account the market share of car/van
manufacturers in the EU150
, the two largest manufacturing groups151
, which together had
46% of the car market in 2019, would have to invest a maximum of €0.7 billion each for
the whole period 2025-2035. For all other car/van manufacturers, PO1 would only
require a total investment between €0.2 and €0.3 billion for the same period. The total
regulatory costs for the industry divided by the 12 main manufacturers of lorries/buses
mean that each lorries/buses manufacturer would have to invest €0.02 billion. This a very
certificates, result sheet, test reports, certificates of conformity and vehicle registration.
147
Commission Implementing Regulation (EU) 2020/683 implementing Regulation (EU) 2018/858 with
regards to the administrative requirements for the approval and market surveillance of motor vehicles and
their trailers, and of systems, components and separate technical units intended for such vehicles
148
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 5.1.2. Economic
impacts, Policy Option 1.
149 CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.2 Efficiency,
evaluation question 4; CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter
5.1.3.; 5.2.3.; 5.3.3. Cost-benefit analysis.
150
Car Sales Statistics, 2020. 2019 Europe: Best-Selling Car Manufacturers and Brands (based on ACEA)
151
Volkswagen Group and Stellantis Group (formed in 2021 through a merger between Fiat Chrysler
Automobiles and PSA)
36
small additional amount to the €59 billion each car manufacturer is estimated to invest
for the shift to automation, connectivity and electrification.152
With the end-date of combustion-engine cars/vans by 2035, the cumulative annual
investment of PO1 and proposed CO2 emission standards for cars/vans32,153,32
over 2021-
2040 amounts to €19.2 billion, out of which €19 billion is due to the proposed CO2 target
and €0.2 billion due to PO1 (see Annex 4, Table 33). Hence, the investment attributable
to PO1 is with 1% increase in annual investments not high. See detailed analysis on the
cumulative impacts on industry in Annex 4 section 1.5.4.
Table 5 (II.A) in Annex 3 presents an overview of these regulatory costs for
manufacturers split up in one-off and recurrent costs linked to the different policy
measures, including simplification measures and technology-neutral limits and extended
real-driving conditions.
6.1.1.2 Competitiveness
The views of stakeholders from industry, civil society and Member States on
competitiveness were collected as part of the targeted stakeholder consultation. No
specific views were expressed regarding PO1.
While the European automotive industry is considered to hold a strong position in
international trade, in recent years Europe has been overshadowed by other emerging
markets. In 2019, about 20% of motor vehicles produced globally was produced in
Europe154
, in comparison with 32% in the year 2000155
. The positive trade balance of EU
cars have continued to decrease since 2015 with imports rising while exports of EU cars
remained more stable.156
In 2018, EU exports of cars to main trade partners the United
States and China still amounted up to €37 and €22 billion, in comparison to imports
worth €6 and €0.5 billion respectively.157
A detailed description of EU export of motor
vehicles to key destinations is available in Annex 4, section 1.4.1., for EU-27 passenger
car exports as well as EU-27 motor vehicles (i.e. cars, vans, lorries and buses).
The evaluation of the Euro 6/VI showed that global pressure to reduce transport
emissions intensifies, not least because other key players, in particular China and the
United States, have introduced or are planning to introduce more demanding vehicle
emission standards.44
Despite the fact that the Euro 6/VI legislation have set the stage for
real-driving testing worldwide, today EU is found to be lagging behind when it comes to
i.a. pollutants coverage and emission limits.158
152
McKinsey Center for Future Mobility, 2020. Estimation of the level of investment from car
manufacturers to gain a defensible position in new technologies
153
Since the recently proposed CO2 emission standards only have implications for cars and vans and a
revision of the CO2 emission standards for heavy-duty vehicles is only planned for 2022, the cumulative
impact assessment focuses only on the cumulative impacts in the cars and vans segments. The scenario
TL_High in the CO2 impact assessment, which is the closest scenario to the final adopted CO2 proposal,
was used to calculate the cumulative impacts.
154
ACEA, 2021. Production
155
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 5.2.2. Economic
impacts.
156
Eurostat, 2020. International trade in cars.
157
ACEA, 2019. EU-US automobile trade: facts and figures; ACEA, 2019. EU-China automobile trade:
facts and figures
158
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
37
Nevertheless, PO1 is only expected to have a very limited effect in aligning the EU with
emission regulatory developments in the United States and China. Only the extended
RDE testing is expected to slightly improve the EU’s competitive position in real-driving
testing. PO1 is not expected to change the access to international markets of EU’s
automotive industry, given that other countries develop more ambitious emission
standards.
PO1 requires almost no R&D efforts for development of emission control systems,
neither for the cars/vans nor for the lorries/buses segments. Therefore, innovation of
European companies in the supply-chain will not be encouraged nor will their
competitive position improve in comparison to what is expected in the baseline. In all,
positive effects on the mobility ecosystem as a whole are expected to be limited.159
The assessment of access to international key markets, innovation and cumulative
investments with CO2 emission standards (see 6.1.1.1) leads to the conclusion that no
impacts are expected from PO1 on industry competitiveness.
6.1.1.3 Single market
PO1 is expected not to affect the intentions of Member States with regard to national
initiatives aiming at tackling significant pollutant emission from road transport, such as
bans for diesel or all combustion engines and the introduction of zero-emission zones
(see chapter 2), putting at risk the functioning of the single market.
6.1.1.4 SMEs
The European automotive industry mostly comprises of large manufacturers active in
vehicle assembly and component production. However, SMEs are present among the
suppliers of equipment. They may be indirectly affected by newly required emission
control technologies or other equipment.
Some SMEs manufacture vehicles or systems that require an EU emission type-approval.
35 SMEs160
were identified in the cars/vans segment161
, which are mostly small
companies (i.e. staff headcount < 50 and either turnover or balance sheet total ≤ €10m).
These 35 SMEs are building specialised vehicles on the basis of powertrains produced by
larger manufacturers162
. Nevertheless, these SMEs rarely carry out calibration of the
specific powertrains in order to make them comply with new emission standards. Since
no significant changes to the emission control technologies and calibration of engines are
expected in PO1, the impact on SME manufacturers is expected to be negligible.
A higher number of SMEs is expected to be indirectly affected by new vehicle emission
standards as users (e.g. transport or logistics services, vehicle rental or leasing
companies, companies using vehicles) due to price and affordability of light- or heavy
duty vehicles. Assuming that costs translate into vehicle prices as demonstrated in the
Limits. ISBN 978-92-76-56406-5, chapter 3.2 Emission standards outside of the EU.
159
Industrial ecosystems encompass all players operating in a value chain: from the smallest start-ups to
the largest companies, from academia to research, service providers to suppliers. For more information see
footnote 16 (industrial strategy).
160
SME definition (europa.eu)
161
No SMEs were identified in the lorries/bus segment.
162
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 5.1.2 Economic
impacts.
38
Euro 6/VI evaluation76
, the total regulatory costs in PO1 are expected to be less than
0.5% of the estimated light- or heavy-duty vehicle price (see Annex 4, Table 17). Hence,
only negligible impact is expected on the affordability of vehicles by SME users in
comparison to the baseline.
6.1.2 Environmental impacts
Air pollutant emission reductions are expected to increase with time even with Euro 6/VI
vehicle fleet renewal in combination with the impact of the new CO2 standards (see
chapter 5.1).
As illustrated for key pollutant NOx in Figure 8 and all pollutants in Annex 4, Table 11,
the emission reductions that can be expected in PO1 are rather limited. This is due to
maintaining the current emission limits (only ensuring technology neutrality). Broader
RDE testing conditions and improved OBD allowing for more effective ISC and MaS
over the lifetime of vehicles do not change this conclusion.
For cars/vans, NOx emissions are expected to further decrease by 13% in 2030 to 55% in
2050, compared to the baseline. This significant decrease follows from the introduction
of low ambition extended real-driving testing covering conditions outside the current
RDE boundaries and a technology-neutral NOx emission limit. Some reductions can be
expected for particles, NH3 and CO emissions from cars/vans compared to the baseline.
For lorries/buses, NOx emission reductions are the only reductions expected in PO1. The
Euro VI limits are already technology-neutral. The reduction of NOx emission, 7% in
2030 to 19% in 2050, derive from extended real-driving testing covering conditions
outside the current PEMS boundaries and assumed increased frequency of ISC and MaS
testing.163
Figure 8 – NOx reductions from light- and heavy-duty vehicles in PO1 compared to the
baseline, Source: SIBYL/COPERT 2021
163
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 5.1.1
Environmental impacts
39
6.1.3 Social impacts
6.1.3.1 Monetised health and environmental benefits
By reducing harmful pollutants, a new vehicle emissions standard benefits citizens by
curbing negative health impacts from road transport that cause respiratory and
cardiovascular diseases upon inhalation e.g. bronchitis, asthma or lung cancer. This
health benefit can be monetised using the concept of external costs developed for the
Commission’s Handbook on the external costs of transport. It reflects the damage costs
by air pollution from transport to health and environment. While benefits of reducing
emission are independent of the absolute emission levels, the differences in exposure for
metropolitan, urban and rural areas are taken into account. Combatting health impacts is
expected to result in a reduction of medical treatment costs, productivity losses due to
illnesses and even deaths.164165
Although the damage costs by air pollution from transport take into account
predominantly the impact on health, they also reflect impact on the environment such as
crop losses, material and building damage and biodiversity loss due to particulate matter
formation, photochemical oxidant formation, acidification, eutrophication and
ecotoxicity of air, water and soil (see Annex 4, Box 3 and Figure 10 and 11). Hence,
Table 4, in which the monetised health and environmental benefits are presented, also
reflects all relevant environmental Sustainable Development Goals (SDGs)166
of the 2030
UN Agenda for Sustainable Development. With monetary benefits estimated for these
parameters in all policy options (see 6.2.3 and 6.3.3), PO1, 2 and 3 are not expected to do
significant harm to any of the environmental SDGs.
Table 4 shows the monetised health and environmental benefits in PO1 compared to the
baseline. Since PO1 considers technology-neutral emission limits and some
improvements regarding extended real-driving testing, benefits are only expected to be
achieved through reductions of NOx, exhaust PM and NH3 emissions. Through the
reduction of NOx emissions from cars/vans, PO1 is expected to result in a €20.6 billion
reduction of external costs up to 2050. With a total reduction of €21.1 billion for
lorries/buses, reduction of NOx emissions from these vehicles is expected to have a
slightly larger benefit. Additional health and environmental benefits are expected from
the reduction of the particle number threshold from 23 nm to 10 nm in PO1. Lastly, the
emission reductions for NH3 for cars/vans are expected to result in benefits up to €0.9
billion.
Table 4 – Monetised health and environmental benefits for PO1 compared to the
baseline, Source: SIBYL/COPERT 2021
Monetised health and environmental benefits until 2050 (billion €)
NOx PMexhaust PMnon-exhaust NH3 NMHC
Cars and vans 20.63 0.33 0.00 0.94 0.01
Lorries and buses 21.14 0.00 0.00 0.00 0.00
164
European Commission, 2019. Handbook on the external costs of transport, Version 2019 -1.1
165
See Annex 4: Analytical methods, section 1.2.3 Damage costs
166
Goal 3: Good health and well-being, Goal 6: Clean water and sanitation, Goal 13: Climate action, Goal
14: Life below water and Goal 15: Life on land from United Nations, 2021. The 17 Goals
40
6.1.3.2 Employment and skills
The Euro 6/VI evaluation found no compelling evidence that emission regulations have a
negative effect on employment. On the other hand, Euro 6/VI may positively impact
employment through creation of new jobs in R&D domain or those related to production
of emission control systems at the suppliers.44
Almost half of the suppliers in the targeted consultation stressed that new limits will
create new business opportunities and quality jobs. Since PO1 only aligns the emission
limits for different vehicle technologies, no impact on employment is expected in PO1,
neither in the cars/vans nor the lorries/buses segments. Reason for this being that there is
no need for new workforce for the continued use of current emission control technologies
or to control emission outside the current RDE boundaries.
Nevertheless, resources for type-approval and testing services may slightly decrease
following the introduction of simplification measures and the expected lower number of
emission type-approvals in PO1, and subsequently also policy options 2 and 3.
Since PO1 does not require new emission control or ICT technologies, no up- or re-
skilling should be needed compared to the baseline.
6.1.3.3 Consumer affordability
It is expected that total regulatory costs following new policy measures for vehicles
initially borne by manufacturers are eventually passed on to the consumers, at least in the
longer term. It is difficult to establish a clear correlation between regulatory costs and
vehicle prices.167
The Euro 6/VI evaluation could not demonstrate if a price increase of
cars since 2014 is associated with regulatory costs stemming from the Euro 6/VI, since
the observed increase could also result from other factors affecting prices, e.g.
installation of comfort equipment or changes in fleet composition towards more heavy
and expensive vehicles.44
However, 121 out of 139 respondents to the public consultation
from all stakeholder groups, including citizens, considered that Euro 6/VI has led to an
increase in the prices of cars, vans, lorries and buses.168
The regulatory cost increase
could lead in the most relevant segment for low income consumers, i.e. small cars/vans,
to 0.1% vehicle price increase for petrol vehicles and 0.5% for diesel vehicles, which is
considered not significant. See detailed comparison of total regulatory costs per vehicle
segment in Annex 4, Table 17.
Private users are not considered relevant for heavy-duty vehicles. The impact on SME
users of heavy-duty vehicles are discussed in section 6.1.1.4.
While Euro emission standards are expected to increase costs for consumers, the newly
proposed CO2 emission standards for cars/vans32
are expected to decrease the total cost
of ownership (TCO)-first user169
of new cars/vans. This is explained by the fuel and
167
Mamakos, A. et al., 2013. Cost effectiveness of particulate filter installation on Direct Injection
Gasoline vehicles
168
European Commission, 2020. Presentation AGVES Meeting 26 November 2020: Post-Euro 6/VI public
stakeholders consultation (Question 3.1)
169
While the CO2 impact assessment also inspects the impacts on the total cost of ownership from the
second user perspective, for this assessment an analysis of the first user perspective is deemed sufficient.
The Euro emission standards mostly affect consumer affordability and the cost of ownership through the
impact on the price of vehicles for first users. Impacts on the second users market will be limited since the
increase is expected to be only a fraction of the price for first users, for all options.
41
electricity savings that are expected to outweigh the high upfront costs of zero- and low-
emission vehicles. In 2030, PO1 is estimated to slightly decrease the net saving in TCO
of €600 per vehicle achieved through the proposed CO2 targets by €13 for cars and by
€74 for vans. Overall, the net savings in the TCO are still found to be highly positive. See
detailed analysis on the cumulative impacts on consumers in Annex 4 section 1.5.2.
6.1.3.4 Consumer trust
While consumer trust was severely affected by Dieselgate in 2015, the last Euro 6d step
for cars/vans introducing RDE testing and the changes to the EU type-approval rules with
strengthened and independent testing, market surveillance and new enforcement
procedures had positive impact on consumer trust170
. PO1 is expected to have low
positive impact on consumer trust. Some positive impact is expected due to introduction
of technology-neutral limits, while real-driving testing is slightly enhanced in PO1.
6.2 PO2: Medium and High Green Ambition
6.2.1 Economic impacts
6.2.1.1 Regulatory costs for automotive industry
The total regulatory costs are expected to be higher in PO2 in order to meet medium
ambitious emission limits and testing boundaries of PO2a and high ambitious emission
limits and testing boundaries of PO2b, compared to PO1. The increase of hardware costs,
caused by the new emission control technologies available in the market today, and of
some R&D costs for technology system integration and calibration, raises the total
regulatory cost compared to the baseline for all vehicle categories. Total regulatory costs
per vehicle are higher for lorries/buses than for cars/vans due to the more robust emission
control systems required for such vehicles.
While the simplification measures lead to cost savings during the implementation phase
and administrative cost savings (€41 per vehicle), the new requirements for tailpipe,
evaporative and brake emission are expected to result in additional R&D, hardware and
calibration costs. The hardware cost per vehicle are calculated using the cost of different
technology packages weighted over the development of the fleet in the assessed period.
The different technology packages to achieve the requirements of PO2a and PO2b and
their costs were verified by stakeholders from automotive industry, civil society and
some Member States and are presented in Table 21 in Annex 4.
For diesel cars and vans, in PO2a regulatory costs linked to the requirements for tailpipe
and evaporative emissions are estimated at €399 per vehicle and in PO2b at €463 euro
per vehicle. For petrol cars and vans, these costs are expected to be lower estimated at
€144 per vehicle in PO2a and at €327 per vehicle in PO2b. In addition, the introduced
limits for brake emissions lead to additional hardware costs that differ between
combustion-engine and electric vehicles due to differences in technologies and braking
patterns. For combustion-engine cars and vans, in PO2a additional regulatory costs
linked to the requirements for brake emissions are estimated at €23 per vehicle and in
PO2b at €100 per vehicle. For electric cars and vans, these additional regulatory costs are
estimated at €13 per vehicle in PO2a and at €60 per vehicle in PO2b.
170
See Annex 2: Stakeholder consultation, 2.2.1 Evaluation Euro 6/VI emission standards
42
Overall, this would result in total regulatory costs for cars/vans of €297 per vehicle in
PO2a and of €475 per vehicle in PO2b.144171
This cost estimate for cars/vans in PO2a is
below the total regulatory costs associated with introduction of Euro 6 for diesel
cars/vans, but exceeds the total regulatory costs associated with the introduction of Euro
6 for petrol cars/vans. In case of PO2b, the total regulatory costs per vehicle for cars/vans
are in the range of the total regulatory costs of Euro 6 for diesel cars/vans.172
For lorries/buses (mainly diesel), in PO2a the cost per vehicle is estimated to increase by
€2 601 and in PO2b this cost is estimated to increase by €4 059 for internal combustion
engine vehicles. Similar to PO1, the cost savings following the simplification measures
(€60 per vehicle) are expected to be exceeded by the hardware, R&D and calibration
costs linked to the new limits, testing and durability requirements (€2 661 per vehicle in
2a and €4 119 per vehicle in 2b). For these vehicles, the total regulatory costs are found
below the total regulatory costs of the introduction of Euro 6/VI for PO2a and in the
range for PO2b.171
Following the same reasoning as in PO1, PO2 is also expected to result in savings in
administrative costs. Since PO2 includes the simplification measures introduced in PO1,
the administrative costs savings are estimated at the same levels.
A detailed description of the total regulatory costs for automotive industry in PO2
compared to the baseline is available in Annex 4, section 1.3.1.2.
Table 5 presents the total regulatory costs in 5-year intervals over the period of
implementation of stricter emission limits in PO2, including tailpipe, evaporative and
brake emissions. It shows that the largest share of the costs occur in the first ten years
after 2025. Subsequently, the costs will decrease with a small share of the costs
remaining after 2035, mainly resulting from the requirements regarding brake
emissions for all cars/vans, including zero-emission vehicles, and combustion-engine
lorries/buses. They will also be due to the need to continue market surveillance and in-
service conformity checks throughout the lifetime of vehicles (i.e. at least for another 10-
15 years after the first registration). For all categories, the five year costs decrease over
time as a consequence of the decreasing number of combustion engine vehicles.
Table 5 – Expected distribution of total regulatory costs in PO2 compared to the
baseline, in billion € and 2025 NPV
2025
2026-
2030
2031-
2035
2036-
2040
2041-
2045
2046-
2050
Total
PO2a – Medium Green Ambition
Cars and vans 8.62 14.77 4.26 1.03 0.86 0.72 30.27
Lorries and
buses
5.72 5.82 2.22 1.35 0.76 0.57 16.44
PO2b – High Green Ambition
171
For cars/vans, this cost per vehicle in PO2a corresponds to €280 per ICE vehicle for costs linked to
requirements for tailpipe and evaporative emissions and €17 per vehicle for all powertrains linked to
requirements for brake emissions. For cars/vans in PO2b, this is €399 per ICE vehicle and €76 per vehicle
for all powertrains.
172
See Annex 5: Evaluation Euro 6/VI emission standards, chapter 6 Conclusions: For Euro 6 cars/vans,
the total regulatory cost for the period up to 2020 increased by €357-€929 per CI vehicle and €80-€181 per
PI vehicle. For Euro VI lorries/buses, the total regulatory costs increased by €3 717-€4 326 per vehicle.
43
Cars and vans 12.99 28.62 10.33 4.70 3.93 3.27 63.84
Lorries and
buses
6.50 9.07 4.57 2.78 1.56 1.17 25.65
Taking into account the market share of car/van manufacturers in the EU149
, the two
largest manufacturing groups, would have to invest between €5.1 and €5.7 billion each in
PO2a and between €12 and €13.6 billion in PO2b for the whole period between 2025 and
2050, i.e. over 25 years. For all other car/van manufacturers, PO2a would only require a
total investment between €0.5 and €2.7 billion, while PO2b would require a total
investment between €0.5 and €6.1 billion for the same period depending on the size of
the manufacturer. The investment costs for PO2a can be translated €1.4 billion per
manufacturer of lorries/buses while for option 2b the costs increase to €2.1 billion
respectively. This is still expected to have a low impact on the estimated investment need
for car makers of €59 billion to address automation, connectivity and electrification
challenges151
, costs are still considered low for the automotive industry in particular those
for PO2a.
Especially automotive industry has raised concerns regarding too high cumulative
impacts in view of the CO2 investments and the technological potential for reducing
emissions. With the end-date of combustion-engine cars/vans by 2035, the cumulative
annual investment of PO2a/PO2b and proposed CO2 emission standards32
over 2021-
2040 amounts to €20.2/€21.4 billion, out of which €19 billion is due to the proposed CO2
target and €1.2/€2.4 billion due to PO2a/PO2b (see Annex 4, Table 33). The investment
attributable to PO2a is considered with 7% increase in annual investments not too high,
while the investment attributable to PO2b is considered with 13% high. See detailed
analysis on the cumulative impacts on industry in Annex 4 section 1.5.4.
Table 5 (II.B) in Annex 3 presents an overview of these total regulatory costs for
manufacturers split up in one-off and recurrent costs linked to the different policy
measures, including simplification measures, medium and high ambition emission limits,
real-driving testing boundaries and durability.
6.2.1.2 Competitiveness
The views of stakeholders on competitiveness were collected as part of the targeted
stakeholder consultation. While Member States and civil society generally expect a
positive relationship between stricter standards and competitiveness, differing views
were found amongst industry stakeholders with suppliers anticipating positive impacts
and manufacturers negative impacts (see Annex 2, Figure 7). Stakeholders did not
express different views on the cars/vans and lorries/buses segments.
Through the Euro standards, the EU has traditionally been the global emission standard
setter, and the EU automotive industry has traditionally been the technological leader for
internal combustion engines. PO2 would put the EU in the forefront of vehicle emission
reductions worldwide, overtaking the actual regulatory developments in other key market
such as China and the US for tailpipe pollutants except durability (see 6.1.1.2) as well as
for new ones that will be there irrespectively of the engine: from brakes and, in the
future, from tyres. This would maintain access to international markets.
In addition, over recent years EU export of cars has followed a downwards trend, while
import has known a steady increase. In 2019, car exports amounted up to €140 billion,
while imports to €63 billion.155
This downward trend is also visible for the export of all
motor vehicles, including all light-duty as well as heavy-duty vehicles. In 2019, EU
44
exports of motor vehicles added up to €157 billion and imports to €71 billion.173
The
stricter emission limits for internal combustion engines in PO2 should support EU
automotive industry to seize opportunities for further cleaning of internal combustion
engines that will still play a role in several third markets for which a slower transition to
zero-emission cars/vans is expected, such as in India, South-East Asia, Brazil or South
Africa, and in the lorries/buses segment174
. Choice of PO2 is expected to increase export
of EU goods compared to the baseline values, reversing current trends, thus positively
affecting the global market share of the EU.154
These findings for PO2 are also supported by the majority of component suppliers
participating in the targeted consultation, indicating that new emission limits will
encourage innovation in the supply-chain and increase the competitiveness of the EU
automotive industry on the global stage. Vehicle manufacturers, on the other hand, tend
to be more reserved on this point.175
For the whole mobility ecosystem the effects of PO2
are expected to be positive, given the strong competitive position of EU suppliers of
emission control systems.
Despite the total regulatory costs for industry and cumulative investments with CO2
emission standards for cars/vans (see 6.2.1.1), PO2a and PO2b are expected to have a
low to moderate positive effect on competitiveness in terms of access to international
markets and innovation. Stimulating innovation in zero-emission technologies by CO2
emission standards as well as in pollutant emission control technology, access to
international markets can be maintained while improving the competitive position of the
EU automotive sector over the baseline.
However, the assessment also shows that some of the concerns of automotive industry
regarding stricter Euro emission standards are justified, such as high investments in the
cars/vans segment with emission limits lower than 30 mg/km for NOx and high ambitious
real-world testing in all driving conditions in PO2b.
6.2.1.3 Single market
It is expected that PO2 will increase confidence in vehicles, in particular cars, being
clean in all conditions of use and may encourage Member States to reconsider
announcements for vehicle bans and local or regional vehicle access limitations, in
particular as those have to be notified as potential barriers of internal EU trade of
vehicles under Directive 2015/1535176
. PO2, by increasing confidence in clean vehicles
under extended conditions of use and subsequently making Member States reconsider
need for unilateral measures, positively affects the functioning of the single market
through setting more adequate, future proof rules for vehicles emission. Higher positive
impact is expected in PO2b than in PO2a as the former introduces high ambition
emission limits and testing boundaries.
173
ACEA, 2022. EU motor vehicle exports, main destinations (by value). ACEA, 2022. EU motor vehicle
imports, main countries of origin (by value).
174
Zhao, Fuquan et al, 2020. Challenges, Potential and Opportunities for Internal Combustion Engines in
China
175
See Annex 2: Stakeholder consultation, section 2.2.6. Impacts of a stricter emission standard
176
Directive (EU) 2015/1535 laying down a procedure for the provision of information in the field of
technical regulations and of rules on Information Society services; see also 2015/1535 notification
procedure
45
6.2.1.4 SMEs
The new requirements considered in PO2 could potentially be more difficult and costly to
implement for the 35 SME cars/vans manufacturers177
(see 6.1.1.4). Most of those SMEs
are specialised in sporty and lightweight cars that are predominantly equipped with petrol
engines, whose emission control systems present the lowest total regulatory costs in the
vehicle categories. Furthermore, several of these SMEs are supported by the research
facilities of larger manufacturers to whom they are linked in the supply chain. In the
targeted stakeholder consultation, differing views on the effect of PO2 on SME
manufacturers were found. While large manufacturers were pessimistic, suppliers were
uncertain or slightly positive considering that SMEs would not be significantly affected
in a positive or negative manner by the proposed measures in PO2.174
The SME users of motor vehicles, such as transport services, etc., are mostly concerned
about the effect of new requirements on the price and affordability of vehicles. When
fully passed on to SME users, the total regulatory costs in PO2a amount up to 2.1% for
small cars/vans and up to 3.1% for small lorries of the vehicle price, and in PO2b up to
2.8% for small cars/vans and up to 4.9% for small lorries (see Annex 4, Table 22).
Hence, the strictest emission limits are expected to have medium negative impact on the
affordability for SME users.
6.2.2 Environmental impacts
As illustrated for key pollutant NOx in Figure 9 and all pollutants in Annex 4, Table 12,
the emission reductions compared to the baseline that can be expected by introducing
strict emission limits (PO2a) are significant, in particular for lorries/buses. The reduction
of emissions for cars/vans is also important, as those vehicles are predominantly used in
densely populated urban areas where more citizens are exposed.
For cars/vans, NOx emission are expected to decrease significantly and rapidly compared
to the baseline, by 21% in 2030, 42% in 2035, 62% in 2040 to 88% in 2050. This
significant reduction follows from the introduction of medium ambition extended real-
driving testing covering almost all conditions outside the current RDE boundaries and a
technology-neutral NOx emission limit of 30 mg/km for cars. This replaces the diverging
NOx limits of Euro 6 of 60 mg/km for petrol cars and 80 mg/km for diesel cars. The
decrease in Figure 9 illustrates that cars/vans progress more rapidly toward zero-pollution
levels (about 0.08 Mt NOx/a) in 2040, compared to similar levels reached in 2050 in the
baseline.
Additional significant reductions can also be expected due to the stricter air pollutant
emission limits and increased durability requirements (see details in Annex 4, section
1.2.3.2). Brake emissions, an example for stricter emission limits, have become
increasingly relevant sources of non-exhaust particles and are assumed to go down by
16% in 2030 to 36% in 2050 through the use of improved brake pads178
.
For lorries/buses, the highest emission reductions can be expected under PO2a due to the
more stringent air pollutant emission limits for NOx, particles, hydrocarbons, CO, NH3
177
No SMEs were identified in the lorries/bus segment.
178
As there are no testing methods for brake emissions from lorries and buses and for tyre emissions from
all vehicle categories developed so far, the environmental impact of those non-exhaust particles cannot be
determined and subsequently assessed.
46
and N2O emission. NOx emission are assumed to decrease by 0.2 Mt in 2030 to 0.4 Mt in
2050. This high reduction comes from the fact that in the EU fleet a significant number
of HDVs, in particular diesel lorries, is still expected to be equipped with a combustion
engine vehicle until 2050 (see Figure 7).
Figure 9 – NOx reductions from light- and heavy-duty vehicles in PO2a compared to the
baseline, Source: SIBYL/COPERT 2021
As illustrated for key pollutant NOx in Figure 10 and for all pollutants in Annex 4, Table
13, the emission reductions compared to the baseline that can be expected by PO2b are
significant, in particular for lorries/buses. However, PO2b is expected to lead only to
marginal additional emission reductions compared to PO2a for all categories of vehicles
(compare Figure 9 and Figure 10).
For cars/vans, the small difference in emission savings between PO2a and PO2b is
explained by the small emissions levels. The only major difference are emissions during
cold start, which are more effectively controlled under the stricter emission limits under
PO2b, rather than under the medium ones in PO2a.
For lorries/buses, the marginal NOx effect is explained by the fact that the testing
conditions are already extended in PO2a leading to the major positive effect on the
emission performance. The additional reduction of the NOx limit from 150 mg/kWh to
100 mg/kWh in PO2b offers a low total emission reductions.87
On the other hand, additional reductions are expected for non-exhaust PM2.5 emissions
from cars/vans. PO2b includes more stringent limits for brake emissions which require
improved brake pads and the installation of brake dust particle filter.
Figure 10 – NOx reductions from light- and heavy-duty vehicles in PO2b compared to
the baseline, Source: SIBYL/COPERT 2021
47
6.2.3 Social impacts
6.2.3.1 Monetised health and environmental benefits
Table 6 shows the monetised health and environmental benefits for PO2 compared to the
baseline. The two different ambition levels for stricter emission limits, extended real-
driving testing boundaries and durability requirements have high health and
environmental benefits exceeding significantly the low benefit of PO1.
In PO2a, the reduction of NOx emissions for cars/vans until 2050 is expected to result in
health and environmental benefits of €32.7 billion, while the reduction for lorries/buses is
expected to result in benefits of €88.8 billion. For cars/vans, PO2 is also expected to
generate health and environmental benefits through a reduction in non-exhaust PM
emissions through the inclusion of a new brake emission limit. For all vehicles, PO2 is
additionally supposed to result in a reduction of N2O and CH4 emissions, of which health
and environmental benefits are monetised as climate change cost163,164
.
While the health and environmental benefits related to NOx, NMHC, N2O, CH4 and
brake emissions are marginally higher in PO2b, there are no changes for exhaust PM and
NH3 as their emission limits remain the same in both sub-options.
Hence, the impact assessment shows that some of the concerns are justified, such as the
marginal gains of PO2b with emission limits lower than 30 mg/km for NOx and high
ambitious real-world testing in all driving condition, resulting from high costs and
marginal additional health and environmental benefits compared to PO2a.
Table 6 – Monetised health and environmental benefits for PO2 compared to the
baseline, Source: SIBYL/COPERT 2021
Monetised health and environmental benefits until 2050 (billion €)
NOx PMexhaust
PMnon-
exhaust
NH3 NMHC
N2O+CH4
PO2a – Medium Green Ambition
Cars and vans 32.67 0.37 9.90 1.45 0.63 9.77
Lorries and
buses
88.80 6.22 0.00 0.79 0.10 36.63
PO2b – High Green Ambition
Cars and vans 33.24 0.44 14.85 1.46 0.70 14.46
Lorries and
buses
89.32 6.29 0.00 0.80 0.11 37.49
6.2.3.2 Employment and skills
A low positive impact on employment at vehicle manufacturers is expected in PO2.
Stricter emission limits in both stringency levels and comprehensive real-driving testing
will require some additional workforces in the cars/vans as well as the lorries/buses
segment due to the related R&D and manufacturing of new components in the vehicles’
emission control systems.
In the targeted consultation, automotive industry expressed concerns that stringent
emission limits and testing in all driving conditions may accelerate the shift to electric
cars. While this possible shift has not been assessed quantitatively (as the model takes as
a given the fleet of vehicles as projected in the high target level scenario of the impact
assessment on CO2 standards for cars and vans), no compelling reason was found to
48
justify such an accelerated shift due to PO2.174
The main driver to the electro-mobility
transition is, and is expected to remain, climate policies. In fact, stricter emission limits
and comprehensive real-driving testing are expected to result in small increase of
regulatory costs. This increase does not amount to more than 2.1% of the current
cars/vans prices in medium ambitious PO2a and 2.8% in the high ambitious PO2b (see
Annex 4, Table 22).
In the targeted consultation, almost half of the component and equipment suppliers
stressed that new emission limits will create new business opportunities and quality jobs,
particularly in relation to technologies required in the emission control systems, engine
optimisation and powertrain hybridisation components.174
Similarly, a low to moderate positive impact on skills at vehicle manufacturers and
suppliers is expected in PO2 compared to the baseline. Stricter emission limits, new
limits for brake emissions and extended coverage of pollutants and real-driving testing
will require some re- and up-skilling of the workforce in the automotive supply chain of
light- and heavy-duty vehicles to address the related R&D and manufacturing of new
components in the vehicles’ emission control systems. This is in line with the targeted
consultation where a large share of industry, Member States and civil society
stakeholders indicated that a higher-level education (38 out of 66) and new skills (47 out
of 66) will be required for the majority of the personnel in the entire automotive supply
chain to successfully apply the measures in PO2.174
For type-approval authorities, no
significant changes are expected in the required skills set. Stakeholders did not express
different views on the cars/vans and lorries/buses segments.
The overall contribution of PO2 to the cumulative impact with CO2 emission standards32
on employment is not significant, since the sub-options are based in general on existing
technologies not requiring a sector transformation. While the CO2 emission standards for
cars/vans are expected to result in the number of jobs increasing by 39 000 in 2030 and
even by 588 000 in 2040, the low positive impact of PO2b could indicatively still lead to
an additional increase of about 15 thousand jobs in 2030 in the cars/vans segment. On the
other hand, PO2a is expected to have a no impact on employment (i.e. also no cumulative
employment impact attributable to PO2a). See detailed analysis on the cumulative
impacts on employment in Annex 4 chapter 1.5.3.
6.2.3.3 Consumer affordability
The total regulatory costs for industry introduced by PO2 are expected to be passed on to
consumers, at least in the longer term. For PO2a and PO2b respectively, this leads in the
most relevant segment for low-income consumers, i.e. small cars/vans, to 0.8-2.2%
vehicle price increase for petrol vehicles and 2.1-2.8% for diesel vehicles (see Annex 4,
Table 22). Impact on consumers’ affordability will be low to moderate since diesel
engine, where the additional measures are most expensive, is no longer technology of
choice for this segment, especially in PO2a.
Private users are not considered as relevant for heavy-duty vehicles. The impact on SME
users of heavy-duty vehicles are discussed in section 6.2.1.4.
While automotive industry has indicated that more stringent limits would lead to more
costly vehicles and a slower fleet turn-over, the expected low impact on consumer
affordability in PO2 is more in line with the views of the other stakeholder groups. In the
targeted consultation, a consumer organisation stated that the previous Euro standards
illustrate that an appropriate level of ambition can make vehicles significantly cleaner
while not making them disproportionately more expensive.
49
Looking into the cumulative impact with the newly proposed CO2 emission standards for
cars/vans32
, PO2 is estimated to decrease the net saving in total cost of ownership (TCO)
for combustion-engine cars/vans until 2035, but also after this date for zero-emission
cars/vans through the proposed brake emission limits. For new cars and vans in 2030, the
net TCO savings-first user of €600 achieved through the proposed CO2 targets are
expected to decrease by €114 per car and €258 per van in PO2a compared to €244 per car
and €364 per van in PO2b. See detailed analysis on the cumulative impacts on consumers
in Annex 4 section 1.5.2.
6.2.3.4 Consumer trust
PO2 with stricter emission limits and comprehensive real-driving testing conditions
positively impact the consumer trust in automotive products as it ensures systematic
clean vehicles performance.
Also the responses to the targeted consultation suggest that stakeholders from all
groups, except from vehicle manufacturers,179
believe that there is potential for a new
Euro legislation to further improve consumer trust in emission performance of vehicles
and automotive products.180
6.3 PO3a: PO2a and Medium Digital Ambition
6.3.1 Economic impacts
6.3.1.1 Regulatory costs for automotive industry
The total regulatory costs for PO3a, adding medium digital ambition to PO2a by
introducing Continuous Emission Monitoring (CEM) based on available sensor
technology, are estimated in the range of PO2a.181
The main reason for this is that the
cost for available sensor technology is counterbalanced by higher costs savings due to
simplified type-approval using CEM data. This finding should support the buy-in of
industry stakeholders who raised concerns that the introduction of continuous emission
monitoring in combination with stricter emission limits could be too burdensome for
European car manufacturers. For cars/vans, total regulatory costs are estimated €304 per
vehicle in PO3a.182144
Similar to PO2a, these total regulatory cost estimate is below the
total regulatory cost associated with introduction of Euro 6 for diesel cars/vans, but
exceeds the costs associated with the introduction of Euro 6 for petrol cars/vans.171
Although PO3a requires the installation of available sensors to allow for CEM, the
respective increase in hardware, R&D and calibration costs (€21 per vehicle) is partly
cancelled out by reduced costs during implementation phase and administrative costs
(€14 per vehicle).
For lorries/buses, total regulatory costs are estimated at €2 681 per vehicle in PO3a.
Thus, the increase in hardware, R&D and calibration costs linked to the introduction of
CEM (€112 per vehicle) is partly offset by the increase in cost savings during
179
Automotive industry, Member States and civil society
180
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7, chapter 5.1.4. Social
impacts
181
PO3b on PO2a and High Digital Ambition has been discarded at an early stage (see 5.3).
182
For cars/vans, this cost per vehicle corresponds to €287 per ICE vehicle for costs linked to requirements
for tailpipe and evaporative emissions and €17 per vehicle for all powertrains linked to requirements for
brake emissions.
50
implementation phase and administrative costs (€31 per vehicle). The total regulatory
costs that came with the introduction of the Euro VI standards for lorries/buses are still
found to be in a higher range (€3 717-€4 326 per vehicle).
In PO3, the administrative burden is further decreased as the new CEM requirements are
expected to further simplify the reporting and other information provision obligations146
for granting type-approval and verification procedures through reduced number of type-
approvals. This leads to additional cost savings for all vehicle categories. In PO3a,
administrative cost savings are estimated at €224 thousand per type-approval (€22 per
vehicle) for diesel cars/vans and at €204 thousand per type approval for petrol cars/vans
(€26 per vehicle).
For lorries/buses, the administrative cost savings in PO3a amount up to €66 thousand per
diesel type-approval (€22 per vehicle) and €67 thousand per petrol type-approval (€47
per vehicle).
A detailed description of the total regulatory costs for automotive industry in PO3
compared to the baseline is available in Annex 4, section 1.3.1.3.
Table 7 presents the total regulatory costs in 5-year intervals over the period of
implementation of medium ambition emission limits and introduction of available CEM
in PO3, including tailpipe, evaporative and brake emissions. It shows that the largest
share of the costs occur in the first ten years after 2025. After that, the costs will decrease
with a small share of the costs remaining after 2035, mainly resulting from brake
emissions requirements for all cars and vans, including zero-emission vehicles, and
combustion-engine lorries/buses. They will also be due to the need to continue market
surveillance and in-service conformity checks throughout the lifetime to vehicles (i.e. at
least for another 10-15 years after the first registration).
Table 7 – Expected distribution of total regulatory costs in PO3a compared to the
baseline, in billion € and 2025 NPV
2025
2026-
2030
2031-
2035
2036-
2040
2041-
2045
2046-
2050
Total
Cars and vans 8.91 15.05 4.23 1.03 0.86 0.72 30.80
Lorries and buses 6.11 6.01 2.18 1.33 0.74 0.56 16.94
Taking into account the market share of car/van manufacturers in the EU149
, over the 25-
year period the two largest manufacturing groups, would have to invest between €5.1 and
€5.7 billion each in PO3a for the whole period 2025 to 2050. For all other car/van
manufacturers, PO3a would only require a total investment between €0.6 and €2.8 billion
depending on the size for the whole period. This a small additional amount to the €59
billion each car manufacturer is expected to invest for the shift to automation,
connectivity and electrification. 151
The total regulatory costs for the industry divided by 12 main manufacturers of
lorries/buses translate to investment of €1.4 billion per lorries/bus manufacturer for
PO3a.
Especially automotive industry has raised concerns regarding too high cumulative
impacts in view of the CO2 investments. With the end-date of combustion-engine
cars/vans by 2035, the cumulative annual investment of PO3a and proposed CO2
emission standards32
over 2021-2040 amounts to €20.2 billion, out of which €19 billion
is due to the proposed CO2 target and €1.2 billion due to PO3a (see Annex 4, Table 33).
51
The investment attributable to PO3a is considered with 7% increase in annual
investments not too high. See detailed analysis on the cumulative impacts on industry in
Annex 4 section 1.5.4.
Table 5 (II.C) in Annex 3 presents an overview of these regulatory costs for
manufacturers split up in one-off and recurrent costs linked to the different policy
measures, including simplification measures, medium ambition emission limits, real
driving testing boundaries and durability and medium ambition continuous emission
monitoring.
6.3.1.2 Competitiveness
Since the medium ambition stricter emission limits and real driving testing boundaries of
PO2a are also part of PO3a, the arguments relevant for PO2 are also applicable for both
vehicle segments in this policy option. While the majority of component suppliers
participating in the targeted consultation indicated that continuous emission monitoring
in combination with stricter emission limits would positively affect the competitive
position of the EU automotive industry, vehicle manufacturers consider it too
burdensome.
Next to a medium green ambition, PO3a also introduced a medium digital ambition by
introducing requirements regarding continuous emission monitoring systems. PO3a is
expected to have a moderate positive effect on competitiveness in terms of innovation
and access to international markets. Continuous emission monitoring systems are
relevant in several third markets for which cleaner ICE vehicles are still needed in view
of an expected higher age of the vehicle fleet than the up to 19 years in the EU cars/vans
fleet and up to 21 years in the EU lorries/buses fleet183
.
The introduction of CEM with modern IT functionalities in PO3a is considered as an
element of digital innovation in the automotive sector. In addition, the development of
sensors and digital communication systems creates opportunities, some of them beyond
the automotive supply-chain i.a. in cybersecurity area184
. European suppliers of
communication systems are expected to develop secure protocols for the transmission of
information and other IT solution to protect the emission control systems from tampering
under PO3 and to facilitate the secure transmission of data. Further synergies with the
access to data regulations are also expected, ensuring adequate protection of personal
data which are not needed for checking compliance of a vehicle type. It is also
worthwhile mentioning that the introduction of CEM is expected to be of high interest for
periodic technical inspections and roadside checks of vehicles.
Similar developments in other key markets in the field of continuous emission
monitoring (US with REAL initiative, China with remote on-board diagnostics for
heavy-duty vehicles) demonstrate that PO3a could further close the gap between the EU
and other countries emission standards.
Lastly, PO3a will also facilitate the implementation of geo-fencing. As a consequence,
new business models using the information collected can be developed to support the
183
ACEA, 2021. Average age of the EU vehicle fleet, by country.
184
UC Riverside, 2020. How to create a paradigm shift in vehicle emission regulation
52
concept of Smart Cities185
and to offer new solutions regarding the improvement of air
quality.
Despite the regulatory costs for industry and cumulative investments with CO2 emission
standards (see 6.3.1.1), stimulating digital, green and electric innovation would allow the
EU automotive sector to maintain access to international markets which would improve
its competitive position over the baseline. Since cost for available sensor technology, as
assumed in PO3a, is counterbalanced by costs savings due to simplified type-approval
(see 6.3.1.1), the investment for PO3a is not higher than for PO2a and not considered too
burdensome for vehicle manufacturers.
6.3.1.3 Single market
PO3 would significantly improve and simplify compliance of motor vehicles with
emission rules and therefore improve the trust on the automotive sector. The possibility
to introduce geo-fencing possibilities could allow a wider range of powertrains in zero-
emission zones (i.e. zero-emission enabled PHEVs). That way, PO3a could counter the
national measures (e.g. zero-emissions zones or phasing-out combustion engines, see
section 2.3) and preserve the single market.
6.3.1.4 SMEs
The CEM requirements could be more difficult and costly to implement for the 35 SME
cars/vans manufacturers186
(see 6.1.1.4). Considering that those SMEs use engines
equipped with on-board fuel consumption meters (OBFCM)137
from larger
manufacturers, the implementation of available sensor technologies based on the
OBFCM communication platform is not expected to be a challenge.
As the total regulatory costs related to PO3 are expected to be passed on to SME users,
they are mostly concerned about the affordability of vehicles. Similar to PO2a, the total
regulatory costs in PO3a amount up to 2.2% for small cars/vans and up to 3.2% for small
lorries of the vehicle price (see Annex 4, Table 25). Hence, the introduction of CEM is
expected to have medium negative impact on the affordability for SME users.
6.3.2 Environmental impacts
As illustrated for key pollutant NOx in Figure 11 and all pollutants in Annex 4, Table 14,
the emission reductions that can be expected in PO3a compared to the baseline are
significant, in particular for lorries/buses. Also for cars/vans, very low NOx emission
levels are reached in 2040, compared to 2050 in the baseline (see 6.2.2).
Through the introduction of continuous emission monitoring for NOx and NH3 emissions,
some additional emission reductions are expected compared to the introduction of strict
emission limits only (PO2a). This is due to improved compliance with emission limits
and improved protection against tampering with the emission control systems.
Figure 11 – NOx reductions from light- and heavy-duty vehicles in PO3a compared to
the baseline, Source: SIBYL/COPERT 2021
185
European Commission, 2022. Smart cities
186
No SMEs were identified in the lorries/bus segment.
53
6.3.3 Social impacts
6.3.3.1 Monetised health and environmental benefits
Table 8 shows the monetised health and environmental benefits for PO3a compared to
the baseline. New CEM requirements in a Medium Digital Ambition, in addition to the
medium ambition stricter emission limits and extended real-driving testing boundaries in
PO2a, are expected to result in additional benefits for nearly all pollutants.
In PO3a, some additional health and environmental benefits could be realised through the
monitoring of NOx and NH3 over the vehicle lifetime (see Annex 6, Table 55). The
reduction of NOx emissions for cars/vans until 2050 is expected to result in a health and
environmental benefit of €33.5 billion, while for lorries/buses it is expected to result in a
benefit of €89.6 billion. Also the emission reductions for NH3 in PO3 result in additional
health and environmental benefits beyond PO2, more so for lorries/buses than for
cars/vans. These benefits are expected to amount up to €1.5 billion for cars/vans (€60-
€50 million more than in PO2a and PO2b) and up to €0.9 billion for lorries/buses.
Table 8 – Monetised health and environmental benefits for PO3a compared to the
baseline, Source: SIBYL/COPERT 2021
Monetised health and environmental benefits until 2050 (billion €)
NOx PMexhaust
PMnon-
exhaust
NH3 NMHC
N2O+CH4
Cars and vans 33.45 0.37 9.90 1.51 0.67 9.77
Lorries and
buses
89.63 6.22 0.00 0.91 0.10 36.63
6.3.3.2 Employment and skills
In PO3, a low positive impact is expected on employment by vehicle manufacturers. The
introduction of CEM in addition to stricter emission limits, will require some additional
workforce for the manufacturing and R&D for new components in the vehicles’ emission
control systems and new specialised IT jobs on data communication. The CEM
functionality could simplify and modernise the existing on-board diagnostics.
PO3 is expected to result in a direct positive impact on employment, exceeding the
impacts of PO2a, in the supply segment of the industry. CEM would require the most
intensive R&D and innovation activity among all options to develop and implement the
necessary technologies (e.g. on-board sensors and intelligent vehicle communication
protocols). This would apply for cars/vans as well as lorries/buses, since sensors are
54
designed for application in all vehicles, light and heavy-duty ones. In addition, almost
half of the suppliers stressed in the targeted consultation that the requirements in PO3
could create new business opportunities and quality jobs in the field of sensor
technology.
A large share of industry, Member States and civil society stakeholders indicated that
a higher-level education and new skills will be required for the majority of the personnel
in the entire automotive supply chain to successfully apply the measures in PO3a.
Compared to the baseline and the previous policy options, a significant up- and re-
skilling of the workforce in the automotive supply chain is expected due to the
introduction of CEM.
While the automotive industry is already expanding relevant expertise by investing in
module integration, software development and semiconductor design187
, CEM is
expected to further encourage demand for connected vehicles with advanced electronic
information and communication. Therefore, the industry will need re- and up-skilling in
order to bridge the existing knowledge gap between the automotive and ICT sector and
contribute to the digital transformation. This will be a key enabler for reaching the Green
Deal objectives.
Some re- and up-skilling regarding sensor operation and verification may be required for
type-approval authorities. In PO3, in-service conformity and market surveillance are
expected to be mostly dependent on the verification of on-board monitored emissions of
the vehicle model family.
The contribution of PO3a to the cumulative impact with CO2 emission standards32
on
employment is expected to be low, since it is based on existing technologies not
requiring a sector transformation. While the CO2 emission standards for cars/vans are
expected to result in the number of jobs increasing by 39 000 in 2030 and even by
588 000 in 2040, the low positive impact of PO3a could indicatively lead to an additional
increase of about 9 thousand jobs in 2030 in the cars/vans segment. See detailed analysis
on the cumulative impacts on employment in Annex 4 section 1.5.3.
6.3.3.3 Consumer affordability
The total regulatory costs for industry introduced by PO3 are expected to be passed on to
the consumers, at least in the longer term. This is especially important for the segment of
small cars/vans which is the most relevant for low-income consumers. For small petrol
vehicles, PO3a is expected to lead to vehicle price increases up to 0.8% (see Annex 4,
Table 25). The impact on consumer affordability will be low since small diesel vehicles,
with an estimated price increase of 2.2%, are no longer the technology of choice for the
small vehicle segment. This conclusion is in line with the view from a consumer
organisation which stated that an appropriate level of ambition can make vehicles
significantly cleaner while not making them disproportionately more expensive.
Private users are not considered relevant for heavy-duty vehicles. The impact on SME
users of heavy-duty vehicles are discussed in section 6.3.1.4.
Looking into the cumulative impact with the newly proposed CO2 emission standards for
cars/vans32
, PO3 is estimated to decrease the net savings in total cost of ownership
187
Roland Berger, 2020. The car will become a computer on wheels
55
(TCO)-first user from €600 per vehicle by €112 for cars and by €255 for vans in 2030.
See detailed analysis on the cumulative impacts on consumers in Annex 4 section 1.5.2.
6.3.3.4 Consumer trust
Through continuous emission monitoring, more information regarding the emission
performance of vehicles could be made available to consumers. The digital solutions
offered in this policy option could positively affect the consumers’ perception of the
emission standards and subsequently improve consumer trust in good environmental
performance of vehicles. Continuous emission monitoring is expected to help detecting
non-compliance and malfunction at an early stage which should lead to vehicles emitting
less pollutants over their lifetime. Consumers and the general public get higher assurance
that their vehicles continues to be clean during its use. Hence, it is expected that PO3 has
an additional positive impact on consumer trust compared to PO2a.
7 HOW DO THE OPTIONS COMPARE?
The options are compared against the following criteria:
 Effectiveness: the extent to which the different options would achieve the specific
objectives;
 Efficiency: the extent to which the benefits can be achieved for a given level of
resource/at least cost;
 Coherence of each option with other EU rules tackling air pollutants in the road
transport sector;
 Proportionality: overall assessment of the effectiveness, efficiency and coherence
of each of the options.
Table 9 and Table 10 summarise the assessment of each option against those criteria,
differentiated between light- and heavy-duty vehicles and following the impacts assessed
in chapter 6. Given that there is no weighing of the impacts, major impacts and the other
impacts which have less impact on stakeholders are distinguished.
56
Table 9 – Comparison of the policy options for light-duty vehicles in terms of
effectiveness, efficiency and coherence1
Policy option
1 – Low Green
Ambition
2a – Medium
Green Ambition
2b – High Green
Ambition
3a – 2a and
Medium Digital
Ambition
Effectiveness
Reduce complexity of
the current Euro
emission standards
++ ++ ++ +++
Provide up-to-date
limits for all relevant air
pollutants
0 ++ +++ ++
Improve control of real-
world emissions
+ ++ ++ +++
Efficiency
A. Major impacts on industry
Regulatory costs:
Equipment costs
- -- --- --
Regulatory costs
savings: Testing,
witnessing, type-
approval and
administrative costs
savings
++ ++ ++ +++
Competitiveness:
Access to international
key markets
0 + + ++
Competitiveness:
Innovation
0 0 + ++
B. Other impacts on industry
Free movement within
the single market
0 0 + +
Affordability for SME
users
0 - -- -
C. Major impacts on citizens
Health and
environmental benefits
+ ++ +++ ++
Consumer affordability 0 - -- -
D. Other impacts on citizens
Consumer trust + ++ ++ +++
Employment and skills 0 0 + +
Quantitative efficiency
Net benefits 0 + -- +
Coherence
European Green Deal:
Green and digital
transformation
0 ++ +++ +++
Ambient Air Quality/
National Emission
reduction Commitments
Directives
0 + ++ +
CO2 emission standards 0 + ++ +
Roadworthiness + + + +++
1
--- high negative, -- moderate negative, - low negative, 0 neutral, + low positive, ++ moderate positive,
+++ high positive
57
Table 10 – Comparison of the policy options for heavy-duty vehicles in terms of
effectiveness, efficiency and coherence1
Policy option
1 – Low Green
Ambition
2a – Medium
Green Ambition
2b – High Green
Ambition
3a – 2a and
Digital
Ambition
Effectiveness
Reduce complexity of
the current Euro
emission standards
++ ++ ++ +++
Provide up-to-date
limits for all relevant air
pollutants
0 ++ +++ ++
Improve control of real-
world emissions
+ ++ ++ +++
Efficiency
A. Major impacts on industry
Regulatory costs:
Equipment costs
0 - -- -
Regulatory costs
savings: Testing,
witnessing, type-
approval and
administrative costs
savings
+ + + ++
Competitiveness:
Access to international
key markets
0 + + ++
Competitiveness:
Innovation
0 0 + ++
B. Other impacts on industry
Free movement within
the single market
0 0 + +
Affordability for SME
users
0 - -- -
C. Major impacts on citizens
Health and
environmental benefits
+ +++ +++ +++
Consumer affordability Private users not relevant for heavy-duty vehicles
D. Other impacts on citizens
Consumer trust + ++ ++ +++
Employment and skills 0 0 + +
Quantitative efficiency
Net benefits 0 +++ ++ +++
Coherence
European Green Deal:
Green and digital
transformation
0 ++ ++ +++
Ambient Air Quality/
National Emission
reduction Commitments
Directives
0 ++ +++ ++
CO2 emission standards 0 ++ +++ ++
Roadworthiness
Directives
+ + + +++
1
--- high negative, -- moderate negative, - low negative, 0 neutral, + low positive, ++ moderate positive,
+++ high positive.
58
7.1 Effectiveness
The policy options address to different degrees the specific objectives of the initiative,
without going beyond what is necessary.
Concerning the specific objective to reduce complexity of the current Euro emission
standards, it is effective that the proposed Euro 7 regulation combines Euro 6 emission
standards for cars/vans and Euro VI emission standards for lorries/buses in one single
regulation, with simplification measures such as references to relevant UNECE
regulations regarding testing procedures, fuel- and technology-neutral limits and the use
of a single date of Euro 7 introduction per vehicle segment applied for all cars/vans and
lorries/buses respectively in all policy options. For cars/vans as well as lorries/buses,
PO3a seems to be most suitable to reduce complexity, as continuous emission monitoring
equipment is expected to simplify the reporting and other information provision
obligations for granting of type-approval and ease the verification testing procedures.
Due to the strictest update of existing emission limits and setting of new ones, PO2b is
considered for cars/vans as well as lorries/buses as most effective regarding the specific
objective to provide up-to-date limits for all relevant air pollutants. PO1 is
considered to be not more effective than the baseline as the update of obsolete limits is
too limited. PO2a and PO3a are slightly less ambitious than PO2b, but go significantly
beyond PO1 for all vehicles.
Regarding the specific objective to improve control of real-world emissions, the effect
of PO1 is rather limited as the RDE testing conditions are only slightly and the durability
requirements are not expanded compared to Euro 6/VI. PO2a/PO2b go further by
extending the durability to the average/full lifetime of the vehicle and covering
medium/high ambitious real-driving testing conditions. However, the additional use of
continuous emission monitoring through on-board sensors, in addition to PO2a, leads to
the highest effectiveness in PO3a for cars/vans as well as lorries/buses.
7.2 Efficiency
Major impacts on industry
Regulatory costs (covering substantive compliance costs due to equipment costs for
emission control technologies and the related R&D and calibration costs including
facilities and tooling costs) are assessed to be highest for PO2b, in the order of €67
billion between 2025 and 2050 for light-duty vehicles and €26 billion for heavy-duty
vehicles, due to the use of more advanced equipment for emission control (brake filters
for cars/vans segment instead of brake pads used in PO2a and PO3a, and advanced
tailpipe emission control technology for both vehicle segments). PO1 is the least costly
as only limited emission control technologies are introduced for light-duty vehicles and
none for heavy-duty vehicles.
In terms of regulatory costs savings (covering substantive compliance costs savings
during testing, witnessing of tests by type-approval authorities and type-approval fees as
well as administrative costs savings for reporting and other information obligation as part
of the type-approval procedures), the assessment indicates for all policy options a
reduction compared to baseline in the order of €3.5 to €4.7 billion until 2050 for light-
duty vehicles and €0.4 to €0.6 billion for heavy-duty vehicles. This difference is due to
the limited number of heavy-duty vehicles sold each year. PO3a shows for all vehicles
59
higher reductions than the other options, as continuous emission monitoring equipment is
expected to facilitate the type-approval and testing procedures.
Especially automotive industry has raised concerns regarding too high cumulative
investments with CO2 emission standards. With the end-date of combustion-engine
cars/vans by 2035, the cumulative annual investment of PO2a/PO2b/PO3a and CO2
emission standards32
over 2021-2040 for the whole automotive industry amounts to
€20.2/€21.4/€20.2 billion, out of which €19 billion is due to the proposed CO2 target and
€1.2/€2.4/€1.2 billion188
due to PO2a/PO2b/PO3a. The investment attributable to PO2a
and PO3a are considered not too high, while the investment attributable to PO2b is
considered with 13% high.
Despite the regulatory costs for industry and cumulative investments with CO2 emission
standards, PO2 and PO3 are expected to have some positive effect on competitiveness.
PO3a shows for cars/vans as well as lorries/buses the highest positive impacts in terms of
access to international key markets and innovation. This is due to new market
opportunities stemming from the use of available sensors. The use of best available
emission control technologies and sensors in PO3a supports access to international key
markets, in particular United States and China. Stimulating twin innovation in zero-
emission technologies by proposed CO2 emission standards and in low emission
technology by proposed Euro 7 pollutant standards, the competitive position of the EU
automotive sector can be improved over the baseline.
Other impacts on industry
PO3a and PO2b are considered to have some positive impact on the single market for
both vehicle segments. Introduction of the best available emission control technologies
and continuous emission monitoring on EU level could prevent Member States from
taking unilateral decisions to address excessive emissions from road transport. PO3a
offers additionally the possibility of geo-fencing to support Member States and cities in
their journey towards improving air quality in densely populated areas. This technology
could make it possible to allow a wider range of powertrains in zero-emission zones (i.e.
zero-emission enabled PHEVs).
As far as SMEs are concerned, no significant impacts are expected, except of
affordability for SME users (e.g. transport or logistics services, vehicle rental or leasing
companies, companies using vehicles). Vehicle prices are expected to increase due to
additional costs for emission control systems. This effect is expected to be the most
pronounced in the smaller vehicle segments with lower average prices. For small
cars/vans, a low negative impact on the affordability for SME users is supposed in PO2a
and PO3a where total regulatory costs could reach about 2% of the vehicle price. A
medium negative impact is assumed in PO2b where the total regulatory costs could reach
about 3% of the vehicle price. For small lorries, also a low negative impact is expected in
PO2a and PO3a, whereas a medium negative impact is supposed in PO2b.
188
While in the CO2 impact assessment the investments are assessed over the period 2021-2040, Euro 7
investments only start in 2025 after its application. Nevertheless, the annual average of Euro 7 is still
calculated over the period 2021-2040 to provide comparable numbers with the investments in the CO2
impact assessment. (For more information see Annex 4: chapter 1.5.4. Cumulative impacts on industry)
60
Major impacts on citizens
PO2a, PO2b and PO3a offer substantial health and environmental benefits due to
reduced emissions of harmful air pollutants (see Table 11 and Table 12). The main
benefits for citizens are substantial health benefits, expected to result in a reduction of
medical treatment costs, production losses due to illnesses and even deaths. Since the
emission savings also reflect reduced damage costs on crop and biodiversity losses and
material and building damage, i.e. environmental benefits, no policy option is expected to
do significant harm to the environmental Sustainable Development Goals. The main
driver of the high positive impacts is the reduction of NOx and PM2.5 emissions,
while the reduction potential for heavy-duty vehicles is in kilotons twice as high as
for light-duty vehicles.
Table 11 – Assessment of the environmental impacts of policy options compared to the
baseline: reduction of emissions of air pollutants in 2035 for cars/vans, Data source:
SIBYL/COPERT 2021
Pollutant Latest
available
emissions
Baseline
1 – Low
Green
Ambition
2a –
Medium
Green
Ambition
2b – High
Green
Ambition
3a – 2a and
Medium
Digital
Ambition
2018 in kt 2035 in kt, % compared to baseline
NOX
1 689.67 389.40 285.30
(-27%)
224.40
(-42%)
221.80
(-43%)
220.80
(-43%)
PM2,5, brake
emissions
14.90 16.04 16.04
(-0%)
11.82
(-26%)
9.71
(-40%)
11.82
(-26%)
PM2,5,exhaust
43.85 1.50 1.31
(-13%)
1.28
(-15%)
1.25
(-16%)
1.28
(-15%)
PN10 [in #]
6.55x1025
1.92x1024
1.63x1024
(-15%)
1.06x1024
(-45%)
1.05x1024
(-45%)
1.06x1024
(-45%)
CO
2 796.13 584.50 550.50
(-6%)
414.90
(-29%)
405.10
(-31%)
414.90
(-29%)
THC
412.22 146.10 145.50
(-0%)
113.20
(-23%)
110.50
(-24%)
111.50
(-24%)
NMHC
369.70 119.20 119.00
(-0%)
93.80
(-21%)
91.10
(-24%)
92.11
(-23%)
NH3
38.41 23.85 18.73
(-21%)
16.15
(-32%)
16.14
(-32%)
15.90
(-33%)
CH4
42.52 26.85 26.52
(-1%)
19.42
(-28%)
19.38
(-28%)
19.42
(-28%)
N2O
16.34 41.26 40.69
(-1%)
28.91
(-30%)
23.81
(-42%)
28.91
(-30%)
61
Table 12 – Assessment of the environmental impacts of policy options compared to the
baseline: reduction of emissions of air pollutants in 2035 for lorries/buses, Data source:
SIBYL/COPERT 2021
Pollutant Latest
available
emissions
Baseline
1 – Low
Green
Ambition
2a – Medium
Green
Ambition
2b – High
Green
Ambition
3a – 2a and
Medium
Digital
Ambition
2018 in kt 2035 in kt, % compared to baseline
NOX
1 689.73 705.40 605.60
(-14%)
316.10
(-55%)
314.00
(-55%)
312.60
(-56%)
PM2,5, brake
emissions
- - - - - -
PM2,5,
exhaust
23.45 8.81 8.81
(-0%)
5.37
(-39%)
5.35
(-39%)
5.37
(-39%)
PN10 [#]
3.70x1025
7.49x1023
7.49x1023
(-0%)
4.06x1023
(-46%)
4.05x1023
(-46%)
4.06x1023
(-46%)
CO
412.92 111.50 111.50
(-0%)
97.90
(-12%)
89.08
(-20%)
97.93
(-12%)
THC
43.38 26.55 26.55
(-0%)
23.06
(-13%)
22.84
(-14%)
23.06
(-13%)
NMHC
36.71 16.66 16.66
(-0%)
12.95
(-22%)
12.77
(-23%)
12.95
(-22%)
NH3
6.46 9.64 9.64
(-0%)
6.45
(-33%)
6.43
(-33%)
6.00
(-38%)
CH4
6.67 9.89 9.89
(-0%)
10.10
(+2.1%)
10.07
(+1.8%)
10.10
(+2.1%)
N2O
57.13 97.80 97.80
(-0%)
58.30
(-40%)
58.10
(-41%)
58.30
(-40%)
The impact of the new requirements on consumer affordability in the cars/vans segment
would be limited189
. The total regulatory costs compared to baseline are expected to be
passed on to consumers, while the impact of the affordability for lorries/buses is
explained under the impacts to the industry and SMEs. This leads in PO2 and PO3 in the
segment of small petrol cars/vans, which is the most relevant for low-income consumers,
to a 0.8-2.2% increase in petrol vehicle prices. While the highest price increase of 2.8%
for diesel vehicles in PO2b is above the price increase in the previous Euro standard, the
impact on consumers’ affordability will be limited considering that this is no longer the
technology of choice for this segment. The impact on the affordability of the second-
hand consumers is expected to be even less. This conclusion is in line with the view from
a consumer organisation which stated that an appropriate level of ambition can make
vehicles significantly cleaner while not making them disproportionately more expensive.
When looking into the cumulative consumer affordability with the proposed CO2
emission standards for cars/vans, the concept of total cost of ownership (TCO)-first
user has to be used. Since fuel and electricity savings from the use of zero-emission
vehicles are significant for consumers, the CO2 emission standards decrease the total cost
of ownership (TCO) of such vehicles. The 1.7-2.3% increase in diesel vehicle prices in
PO2a, PO2b and PO3a leads for the consumer to a decrease of the TCO savings in 2030
from €600 per car/van when only the effect of a 100% CO2 target in 2035 is taken into
account to €486, €356 and €488 per car/van when additionally the effect of PO2a, PO2b
and PO3a are taken into account.
189
Private users/consumers are considered not relevant in the lorries/buses segment. The affordability for
SME users of this vehicle segment are discussed above under “other impacts on industry”.
62
Other impacts on citizens
All policy options are expected to have positive impacts on consumer trust, as they
improve vehicles’ environmental impact. The impact is expected to be most extensive for
all vehicles in PO3a which enables sharing more and reliable information on emission
performance of vehicles to consumers through continuous emission monitoring.
The introduction of stricter emission limits and continuous emission monitoring (PO2b,
PO3a) is expected to have for cars/vans as well as lorries/buses a low positive impact on
employment and re- and up-skilling of workforces.
Since the policy options are based in general on existing technologies not requiring a
sector transformation, the contribution to the cumulative impact on employment with
the CO2 emission standards is not significant. While the CO2 emission standards for
cars/vans are expected to result in the number of jobs increasing by 39 000 in 2030 and
even by 588 000 in 2040, the low positive impact of PO2b and PO3a could indicatively
still lead to an additional increase of about 15 thousand and 9 thousand jobs in 2030 in
the cars/vans segment. About half of the vehicle manufacturers also claimed that
employment in businesses focused on traditional combustion-engines would be
negatively affected. This employment effect due to the shift to electric vehicles has been
taken into account in these cumulative impacts.
Quantitative efficiency
In order to assess the quantitative efficiency of policy options, total regulatory costs are
compared to the monetised health and environmental benefits of a reduction of air
pollution (as net benefits i.e. the difference between the present value of the benefits
and costs)190
. The baseline against which the policy options are assessed until 2050
considers that fleet renewal would lead to a higher share of Euro 6/VI vehicles in the
vehicles mix, an end-date of combustion-engine cars/vans in 2035 and a decrease of
combustion-engine lorries/buses in line with the projected HDV fleets (see 5.1).
The main benefits of the policy options are substantial health and also environmental
benefits for citizens due to reduced emissions of harmful air pollutants from cars/vans as
well as from lorries/buses. This health and environmental benefit can be monetised using
the concept of external costs developed for the Commission’s Handbook on the external
costs of transport. It reflects the damage costs by air pollution to health and environment,
in particular medical treatment costs, production losses due to illnesses and even deaths.
In addition, the benefits reflect impact on the environment by air pollutants such as crop
and biodiversity losses as well as material and building damage.
The total regulatory costs in the cars/vans as well as in the lorries/buses segment consist
of 1) equipment costs for emission control technologies and the related R&D and
calibration costs including facilities and tooling costs, 2) costs during implementation
190
For methodological reasons and for clarity purposes, the focus of the efficiency assessment is on net
benefits which are an indicator of the attractiveness of an option in absolute terms (thus the larger the
difference between benefits and costs, the better) and do not bias the results for low-cost options, compared
to the benefit-cost ratio (BCR). The BCR gets disproportionally high when costs are low which gives an
unjustified advantage to low-cost options (i.e. PO1) and has the potential to mislead policy makers.
Moreover, the BCR is independent form the scale of options considered, which contradicts the necessity to
consider in absolute terms the regulatory costs and environmental and health benefits of reducing air
pollutants. The BCR is therefore disregarded to choose one option and is included in Tables 27, 29, 59 and
60 of the Annexes 4 and 8 for completeness purposes only.
63
phase for testing, witnessing of tests by type-approval authorities and type-approval fees
and 3) administrative costs (reporting and other information obligations as part of the
type-approval procedures). In all policy options the increase in total regulatory costs is
due to 1) equipment costs, reduced by 2) cost savings during the implementation phase
and 3) administrative costs savings both due to simplification measures (see Annex 4,
Table 15, 18, 19 and 23). Regulatory cost from 1) is considered as cost; and regulatory
costs savings from 2) and 3) are considered as benefit in the efficiency assessment.
As shown in Table 13, the benefits outweigh the costs in the policy options, except in
PO2b for cars/vans in which the benefits equal the costs. For the other policy options,
positive results are also expected when considering the medium to high level of
confidence of the benefits and cost estimations (see details on uncertainty of the cost-
benefit analysis in Annex 4, section 1.3.2.1).
For cars/vans, PO2a and PO3a are estimated to lead to sufficient net benefits among
the analysed options with an average of about €25 billion and a range from €22-€28
billion. However, for PO2b, based on more advanced emission control technologies such
as brake filters instead of brake pads leading to higher costs, the low net benefits are with
the range of €0.87-€1.81 billion considered not sufficient.
For lorries/buses, PO2a and PO3a offer very high net benefits with an average of
about €117 billion and a range from €99-€134 billion, while PO2b shows lower
relative benefits. The difference in net benefits compared to cars/vans can be
explained by the higher emission reduction potential for HDV.
For all vehicles, PO1 offers only low net benefits, compared to other options. Although
PO1 is estimated to lead to significantly lower regulatory costs due to minimal change to
the emission limits and testing requirements and cost savings by simplification measures,
the health and environmental benefits in terms of emission reductions are however lower
than for all other policy options.
To further analyse PO2a and PO3a having about the same average net benefit as well as
different net benefits in the cars/vans and lorries/buses segment, qualitative elements of
the effectiveness, efficiency and coherence analysis will be taken into account in the
proportionality analysis (see 7.4).
64
Table 13 – Assessment of quantitative efficiency of policy options for light- and heavy-
duty vehicles compared to baseline*, 2025-2050, Introduction of Euro 7 in 2025, Data
source: SIBYL/COPERT 2021
Policy option
1 – Low Green
Ambition
2a – Medium
Green Ambition
2b – High Green
Ambition
3a – 2a and
Medium Digital
Ambition
Cars and vans
Health and
environmental benefits,
2025 NPV in billion €
22.37±3.29 54.82±8.22 65.18±9.77 55.75±8.35
Regulatory costs
savings, 2025 NPV in
billion €
3.50±0.35 3.45±0.35 3.45±0.35 4.67±0.47
Regulatory costs, 2025
NPV in billion €
8.54±1.41 33.73±5.52 67.30±10.58 35.48±5.71
Net benefits, 2025 NPV
in billion €
17.33±2.23 24.55±3.05 1.34±0.47 24.94±3.11
Lorries and buses
Health and
environmental benefits,
2025 NPV in billion €
21.14±3.17 132.54±19.88 134.01±20.10 133.58±20.02
Regulatory costs
savings, 2025 NPV in
billion €
0.38±0.04 0.38±0.04 0.38±0.04 0.58±0.06
Regulatory costs, 2025
NPV in billion €
0.65±0.13 16.82±2.92 26.03±4.30 17.53±3.05
Net benefits, 2025 NPV
in billion €
20.86±3.08 116.10±17.00 108.36±15.84 116.64±17.03
* The baseline considers an end-date of combustion-engine cars/vans in 2035, see section 5.1.
Alternative set of assumptions on emission limits and durability
In the stakeholder consultations, automotive industry and civil society representatives
raised concerns, often having diverging opinions, regarding the level of emission limits,
length of durability requirements and the technological potential for reducing emissions
over the lifetime of the vehicles. In addition to the different emission limits and durability
assumed in the examined policy options an alternative set of assumptions was assessed to
address remaining uncertainty around the medium green ambition on emission limits and
durability in PO2a. It allows in particular to test the sensitivity of the environmental
gains to the choice of the emissions limits, and the respective costs and benefits of
increasing the durability of the measures.
The assessment has been carried out, based on two scenarios for each type of vehicle:
one scenario assumes slightly higher (i.e. less ambitious) emission limits when compared
to the medium ambition emission limits in PO2a (see Table 56 in Annex 8). Another
scenario assumes increased durability by extending the durability from the average to the
full lifetime of light- and heavy-duty vehicles. The alternative assumption on emission
limits leads to lower emission savings when compared with PO2a, but it still results in
the same regulatory costs (see Table 59 in Annex 8). The alternative assumption on
durability results in slightly higher health and environmental benefits, while also
increasing hardware costs lead to slightly higher regulatory costs (see Table 60 in Annex
8). In conclusion, the net benefits of the alternative set of assumptions are, in case of
durability requirements, the same or, in case of emission limits, just slightly worse than
PO2a, while remaining overall largely positive. This conclusion is valid for light- and
heavy-duty vehicles.
65
Since the emission limits and durability assumptions are the same in PO2a and PO3a, for
light-and heavy-duty vehicles, the conclusions drawn are also valid for PO3a.
7.3 Coherence
As aimed high in the European Green Deal, all sectors should undergo a green and
digital transformation, including the road transport, to reach zero-pollution ambition for
a toxic-free environment.
Transport should become drastically less polluting, especially in cities and Euro 7 is
considered as a vital part of the transition towards zero-emission vehicles on EU roads.
PO2b is considered for light-duty vehicles most effective towards zero-emission
cars/vans on EU road due to the use of best available emission control technology,
closely followed by PO3a using existing emission control and sensor technology. For
heavy-duty vehicles, PO3a is considered most effective towards zero-emission
lorries/buses on EU road. This difference between the vehicle segments is due to the fact
that effective brake filters that have a high benefit can be considered in PO2b for the
moment only for cars/vans (no brake emission data available for HDV). This may change
in the future, once the brake filters are a more mature technology, and they may also be
applied for heavy-duty applications. Moreover, NOx emissions are already at such a very
low average emission level in PO2a that further amelioration due to stricter emission
levels or continuous emission monitoring have also a very low effect on emissions.
Synergies should be looked for between the twin green and digital transformation, as
encouraged by the European Green Deal and the New Industrial Strategy. Indeed, digital
ambition by introducing continuous emission monitoring and vehicle connectivity in
PO3a can ensure the reduction of emission over vehicles’ lifetimes.
That way, the new Euro 7 standards can be considered as key element to deliver on a
zero-pollution ambition as set out by the Communication on the European Green Deal
and to contribute to the objectives of the EU’s clean air policy, including the planned
revision of the Ambient Air Quality Directives (AAQD)191 and the existing National
Emission reduction Commitments Directive (NECD)192. The commitment in the
European Green Deal to ''revise air quality standards to align them more closely with the
World Health Organization recommendations'' supports a high degree of ambition in
source legislation such as Euro 7. By ensuring a reduction of all relevant air pollutant
emissions from road transport consistent with AAQD/NECD air pollutant coverage and
targets, the Euro 7 standards notably support Member States in meeting their
commitments under the NECD. This is made in a similar way as the CO2 emission
standards support Member States in meeting their CO2 targets under the Effort Sharing
Regulation193
. PO2b with the highest emission reductions, in particular for lorries/buses,
offers the highest level of coherence with air quality policies, closely followed by PO2a
and PO3a. The cumulative impact with the planned revision of the AAQD in 2022 cannot
be calculated in this impact assessment but is estimated limited.
191
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12677-Air-quality-revision-of-
EU-rules_en
192
NECD is not planned for a revision in the short term.
193
Regulation (EU) 2018/842 of the European Parliament and of the Council of 30 May 2018 on binding
annual greenhouse gas emission reductions by Member States from 2021 to 2030 contributing to climate
action to meet commitments under the Paris Agreement and amending Regulation (EU) No 525/2013
66
Whereas the CO2 emission standards promote zero-emission technologies, such as
electric vehicles, the new Euro 7 standards address the emission of harmful air pollutants
from combustion engines, brakes and, in the future, tyres with the aim to protect human
health and the environment. Therefore the Euro 7 general objectives remain valid insofar
as the important share of ICE vehicles will continue to emit exhaust pollutants, and all
vehicles will contribute to non-exhaust emissions irrespectively of the engine. Despite
proposed end-date of 2035 for new combustion-engine cars/vans, the number of vehicles
placed on the market with combustion engines (including hybrids) remain important, in
particular for lorries/buses. Both CO2 emission and Euro pollutant standards are
considered as complementary to reach the climate and zero-pollution ambition of the
European Green Deal and contribute to the shift to sustainable mobility. All policy
options are in principle coherent with this approach, but PO1 to a rather limited extent,
given the lower expected pollutant emission reductions.
The cumulative investment challenge for the automotive sector to reach the climate
and zero-pollution ambition was already recognised in the European Green Deal, which
stated that “Delivering additional reductions in emissions is a challenge. It will require
massive public investment and increased efforts to direct private capital towards climate
and environmental action, while avoiding lock-in into unsustainable practices. […] This
upfront investment is also an opportunity to put Europe firmly on a new path of
sustainable and inclusive growth. The European Green Deal will accelerate and underpin
the transition needed in all sectors.” Clear regulatory signals to the automotive sector are
considered crucial for delivering climate and zero-pollution investment decisions. As
shown in section 7.1, the cumulative investment attributable to PO2a and PO3a are
considered not too high, while the investment attributable to PO2b is considered high. As
the regulatory costs are expected to be passed on to consumers, the assessment of the
cumulative consumer affordability comes to the same result.
The Roadworthiness Directives aim at detecting over-polluting light- and heavy-duty
vehicles due to potential technical defects by means of periodic testing and inspections
and roadside inspections. All policy options contain elements to support this objective,
with PO3a introducing effective continuous emission monitoring mechanisms and
contributing the most. Significant further cost savings are expected for PO3a in the
cars/vans as well as lorries/buses segments due to such more effective continuous
emission monitoring mechanisms. Such mechanisms could gradually become a primary
tool in the Roadworthiness Directives, modernise the current inspection procedures and
lead to lower administrative costs. While this cumulative impact could not be quantified
yet in this impact assessment, it shall be part of the upcoming revision of the
Roadworthiness Directives.
7.4 Proportionality
PO1: Low Green Ambition
The results from the previous sections illustrate that while PO1 is the least costly for
industry, both for cars/vans and lorries/buses, it is simultaneously the least effective in
achieving the objectives. PO1 is only expected to achieve significant success towards the
first specific objective of reducing complexity of the current Euro emission standards. In
particular, the simplification measures introduced in PO1 and continued throughout the
other options lead to moderately positive regulatory cost savings for industry (covering
costs for testing, witnessing of tests by type-approval authorities and type-approval fees
as well as administrative costs for reporting and other information obligations as part of
the type-approval procedures). Since PO1 is considered to be not more effective than the
67
baseline in updating obsolete emission limits and only slightly more effective in
improving control of real-world emissions, PO1 would only lead to minimal health and
environmental benefits for citizens.
The low net benefits in PO1, especially for lorries/buses, point towards an overall low
efficiency compared to other options. This indicates that this option is significantly less
worthwhile as a whole than the other options.
In addition, the policy option does not improve coherence with the green and digital
ambition of the European Green Deal or with other main EU rules tackling air pollutants
in the road transport sector (air quality legislation and CO2 emission standards). Still,
some improvements on the coherence with Roadworthiness Directives are expected in
PO1.
Considering the above, the low intensity and ambition level of PO1 are not found to
match the identified problems and objectives for cars/vans and even less so for
lorries/buses, for which the share of new zero- and low-emission vehicles in the fleet is
projected to increase at a slower pace. Therefore, PO1 is considered a rather
disproportionate policy option.
PO2a: Medium Green Ambition
Where PO1 scores poorly on effectiveness, efficiency and coherence, PO2a scores
significantly better on all aspects. In PO2a the higher pressure on regulatory costs for
industry is expected to have a moderately negative impact for cars/vans and low negative
impact for lorries/buses. Subsequently, a low negative impact on consumer affordability
is expected for cars/vans and on affordability for SME users for lorries/buses.
Nevertheless, PO2a is more effective in achieving the defined objectives. Since it
includes the same simplification measures as PO1, it is equally successful towards the
specific objective of reducing complexity. Next to that, PO2a goes significantly beyond
PO1 when it comes to the second specific objective of providing up-to-date limits for all
relevant air pollutants with only PO2b being more effective. Also for the third specific
objective, PO2a goes further than PO1 by extending the durability to the average lifetime
of the vehicle and covering medium ambitious real-driving testing conditions. That way,
PO2a would lead to the same regulatory cost savings for industry as PO1, while adding
medium positive health and environmental benefits for citizens in case of cars/vans and
even high positive health and environmental benefits in case of lorries/buses. In addition,
PO2a would enable a low positive impact on competitiveness by maintaining for industry
access to international key markets.
In contrast to PO1, PO2a is estimated to lead for cars/vans to sufficient net benefits and
for lorries/buses to very high net benefits. This difference can be explained by the higher
margin for emission reductions possible in HDV. Hence, PO2a is considered an efficient
policy option. The assessment of an alternative set of medium-ambitious durability
requirements has shown no important change in efficiency for PO2a, while the
alternative set of medium-ambitious emission limits has illustrated slightly lower
efficiency (see 7.2).
In addition, PO2a improves coherence with other EU policies to a certain extent. It
improves coherence with the green ambition of the European Green Deal, the air quality
policies, and the CO2 emission standards, especially for lorries/buses, as it contributes
complementary to reach the green and climate ambition of the European Green Deal and
the shift to sustainable mobility. The cumulative impacts with CO2 emission standards on
industry and citizens in terms of investments needs and consumer affordability are
68
expected not too high. PO2a also improves coherence with Roadworthiness Directives to
the same extent as in PO1.
Considering the above, the medium intensity and ambition level of PO2a are found to
match the identified problems and objectives for cars/vans and even more so
lorries/buses, for which there is a higher margin for emission reductions. Hence, PO2a is
considered a proportionate option, especially in comparison to PO1.
PO2b: High Green Ambition
While PO2b is similarly effective in achieving the objectives as PO2a, it does so at
significantly higher cost leading to a higher negative impact for industry compared to
PO2a, especially for cars/vans. Subsequently, a medium negative impact on consumer
affordability is expected for cars/vans and on affordability for SME users for
lorries/buses. Still, PO2b is considered for the cars/vans as well as the lorries/buses
segments as most effective regarding the second specific objective of providing up-to-
date limits for all relevant air pollutants. While achieving the same regulatory cost
savings for industry as PO1 and PO2a due to same simplification measures, PO2b does
achieve a higher health and environmental benefits for citizens than both for cars/vans
due to the reduction of harmful particles emission from brakes. For lorries/buses,
however, these benefits are of the same magnitude as in PO2a. For all vehicles, PO2b
would enable a low positive impact on competitiveness by maintaining for industry
access to international key markets such as PO2a.
In contrast to PO2a, for PO2b cars/vans the regulatory costs are estimated in the same
range as its benefits due to the still high costs for brake filters. For this reason, this policy
option is measured to lack efficiency as illustrated by the insufficient net benefits in
Table 13. For lorries/buses, the observation is different with PO2b still achieving high
net benefits which are however estimated at a lower level than in PO2a and PO3a.
Still, PO2b is expected to be overall the most successful is improving coherence with the
green ambition of the European Green Deal, the air quality policies and the CO2 emission
standards, especially for lorries/buses, as it has the highest ambition towards sustainable
mobility. However, the cumulative impacts with CO2 emission standards on industry and
citizens in terms of investments needs and consumer affordability are expected high.
PO2b also improves coherence with Roadworthiness Directives to the same extent as in
PO1 and PO2a.
The high intensity and ambition level of PO2b are still found to match the identified
problems and objectives for lorries/buses (at lower extent than PO2a and PO3a), but this
cannot be said about PO2b for cars/vans. PO2b for cars/vans is considered
disproportionate due to the not sufficient net benefits. PO2b for lorries/buses is
considered less proportionate than PO2a and PO3a due to the lower net benefits and
some negative impact on affordability for SME users.
PO3a: PO2a and Medium Digital Ambition
While PO3a is as effective as PO2a when it comes to the second specific objective of
providing up-to-date limits for all relevant air pollutants, PO3a is found to be the most
effective for achieving the other specific objectives. PO3a is most suitable to reduce
complexity through continuous emission monitoring. In particular, continuous emission
monitoring equipment is expected to simplify the reporting and other information
provision obligations for granting of type-approval and ease the verification testing
procedures. Subsequently, PO3a achieves the highest cost savings during the
69
implementation phase and administrative costs not only for lorries/buses, but also for
cars/vans. In addition, PO3a is also expected to achieve simplifications in the
implementation of interlinked Roadworthiness Directive (see below). Also when it comes
the third specific objective, PO3a is found to be the most effective to improve control of
real-world emissions for all vehicles, even in view of the end-date of 2035 for
combustion-engine cars/vans.
At an only slightly higher regulatory cost for industry than in PO2a through increased
equipment costs for all vehicles following the introduction of continuous emission
monitoring, PO3a is set out to achieve slightly higher health and environmental benefits
for citizens. In PO3a, high emitting vehicles are expected to be fixed earlier, while
tampering of vehicles should be avoided. Moreover, the additional regulatory costs are
for a large part outweighed by the additional regulatory cost savings expected in PO3a
over PO1, PO2a and PO2b during the implementation phase and administrative costs.
While PO3a leads to similar low negative impacts on affordability for consumers and
SMEs as PO2a, it is set out to outweigh the other options when it comes to positive
effects on competitiveness by improving for industry access to international key markets
and innovation. In particular, the development of sensors and digital communication
systems creates market opportunities, some of them beyond the automotive supply-chain.
The use of best available sensors supports access to international key markets, in
particular to United States and China where similar developments are taking place.
While PO3a surpasses PO2a when it comes to effectiveness, for efficiency the options
achieve similar results. When focussing solely on the quantifiable costs and benefits,
PO3a scores sufficiently for cars/vans as it achieves net benefits that are equal to those
estimated in PO2a. Also for lorries/buses, PO3a is found to be clearly efficient with high
net benefits in the ranges of PO2a. Still, PO3a is likely to have additional qualitative
benefits for all vehicles exceeding those in PO2a: a more positive impact on
competitiveness (see above) and additionally on free movement within the single market,
consumer trust and employment/skills (see Table 9 for light-duty vehicles / Table 10 for
heavy-duty vehicles).
Overall, PO3a is found to be most coherent with other EU policies. When it comes to
coherence with the air quality policies, PO3a is expected to achieve similar results as
PO2a. In the context of geo-fencing, new business models using the information
collected in PO3a can be developed to support the concept of Smart Cities in the EU and
therefore benefit further air quality. PO3a allows for improvements over PO2a in the
coherence with the green and digital ambitions of the European Green Deal through the
introduction of continuous emission monitoring which contributes to the digital
transformation.
When it comes to coherence with the CO2 emission standards, PO3a is expected to
achieve similar results as PO2a, while the relevant cumulative impacts with CO2
emission standards on industry and citizens are expected not too high.
In addition, continuous emission monitoring in PO3a would allow for an ambitious
revision of the Roadworthiness Directives in which a modernisation of inspection
procedures to control emissions from vehicles periodically can be put forward. Although
out of the scope of this impact assessment, this modernisation in inspections will likely
lead to additional cost savings for the competent authorities by reducing the time needed
to perform inspections. Such indirect positive impacts will likely also be felt by vehicle
owners.
70
Considering the above, the medium intensity and ambition level of PO3a, adding digital
to the green ambition compared to PO2a, are found to match in the best manner the
identified problems and objectives for cars/vans and even more so lorries/buses, for
which there is a higher margin for emission reductions. Hence, PO3a is clearly found to
be a proportionate option.
In summary, PO1 is considered a rather disproportionate policy option, for light- and
heavy-duty vehicles. PO2a and PO3a are both considered as proportionate, for light- and
heavy-duty vehicles. The additional effectiveness, efficiency and coherence of PO3a over
PO2a, for light- and heavy-duty vehicles, is mainly due to its positive impact on
competitiveness through the introduction of continuous emission monitoring and its
additional coherence with the green and digital ambitions of the European Green Deal
and the Roadworthiness Directives. This makes PO3a the most proportionate policy
option. PO2b, on the other hand, is considered disproportionate for light-duty vehicles
due to the not efficient net benefits and less proportionate than PO2a and PO3a for
heavy-duty vehicles due to the lower net benefits and some negative impact on
affordability for SME users.
8 PREFERRED OPTION
The overall proportionality assessment of the effectiveness, efficiency and coherence of
each of the options has demonstrated in section 7.4 that the policy options can be
narrowed down to preferred medium-ambitious PO3a, for light- and heavy-duty
vehicles. PO3a comprises simplification measures, medium ambitious pollutant emission
limits, real-driving testing conditions and durability provisions and introduction of
continuous emission monitoring with available sensors for all vehicles. All arguments
below are equally valid for light- and heavy-duty vehicles.
In addition, the assessment of an alternative set of medium-ambitious durability
requirements in Annex 8 (summarized in section 7.2) has shown no important change in
efficiency compared with PO3a, while the alternative set of medium-ambitious pollutant
emission limits has illustrated slightly lower efficiency.
Although PO3a and PO2a have about the same average net benefit as well as different
net benefits for cars/vans and lorries/buses (about €25 billion in PO3a and PO2a for
cars/vans, about €117 billion in PO3a and PO2a for lorries/buses), there are further
qualitative benefits of PO3a in terms of effectiveness, efficiency and coherence leading
to the overall conclusion that PO3a is most proportionate for both vehicle segments.
Moreover, there is a clear need to act in both vehicle segments to improve our health and
well-being.
PO3a is most effective in achieving all defined objectives, for light- and heavy-duty
vehicles. It provides up-to-date limits for all relevant air pollutants and is most suitable to
reduce complexity of the current Euro 6/VI emission standards and to improve
comprehensively control of real-world emissions by introducing continuous emission
monitoring and extending the durability requirements to the average lifetime of the
vehicle.
PO3a is cost-efficient by reaching, as PO2a, highest health and environmental benefits
for citizens at lowest total regulatory costs for industry and would lead to less than 1%
vehicle price increase for small petrol cars/vans. Despite the proposed end-date of 2035
for combustion-engine cars/vans, PO3a is estimated to lead for cars/vans to sufficient net
benefits in average of €25 billion and for lorries/buses to very high net benefits in
average of €117 billion (see quantitative efficiency assessment in Table 13). This
71
difference between light- and heavy-duty vehicles can be explained by the higher margin
for emission reductions possible for lorries/buses.
Nevertheless, also acting for cars/vans is essential for achieving the green ambition
of the European Green Deal, Zero Pollution Action Plan and new EU Urban
Mobility Framework to make transport drastically less polluting, especially in cities.
These net benefits cannot be ignored or assessed less relevant, since the PO3a
technologies are available for the cars/vans segment and the necessary investments
of €300 per car/van can be recouped until 2035. In addition, sensors for vehicles are
designed for application in all vehicles. With great numbers of combustion cars/vans still
being brought on the market until 2035, introducing PO3a for all vehicles will allow for
economies scale from which the heavy-duty segment will still be able to profit, even after
2035.
PO3a is likely to have additional qualitative efficiency benefits for all vehicles exceeding
those in PO2a: some positive impacts on competitiveness by improving for industry
access to international key markets and innovation, on the single market by possibly
preventing Member States from taking unilateral decisions to address excessive
emissions from road transport, on consumer trust by providing reliable information on
emission performance of vehicles and on employment and re- and up-skilling of
workforces.
PO3a is found to be to be most coherent with other EU policies. It is coherent with the
air quality legislation and CO2 emission standards. PO3a ensures a cost-efficient
reduction of all relevant air pollutant emissions from light- and heavy-duty vehicles,
supporting Member States in meeting their emission reduction commitments under the
National Emission reduction Commitments Directive and contributing complementary to
reach the GHG reduction objectives of the EU. The cumulative impacts with CO2
emission standards on industry and citizens in terms of investments needs and consumer
affordability are expected not too high.
In addition, PO3a ensures highest coherence with the European Green Deal and the
current and planned revision of the Roadworthiness Directives. It adds digital ambition to
PO2a through introducing continuous emission monitoring in line with the twin green
and digital transformation aimed at by the European Green Deal. While having the same
net benefits, PO3a goes significantly beyond PO2a by adding the advantages of
continuous emission monitoring. These advantages are valid for light- and heavy-duty
vehicles:
 PO3a is expected to achieve the highest administrative, testing and type-approval
cost savings, as continuous emission monitoring equipment is expected to
facilitate the granting of type-approval and the verification testing procedures,
which almost balance the additional equipment costs. These cost savings are
higher for light- than for heavy-duty vehicles.
 PO3a would offer the possibility of geo-fencing which would support Member
States and cities improving air quality in densely populated areas. This
technology puts a plug-in hybrid electric vehicle automatically into zero-emission
mode when entering zero-emission zones, such as cities. This would allow for the
development of new business models using the emission information collected to
support the concept of Smart Cities in the EU.
 Continuous emission monitoring introduced by PO3a would also be beneficial as
monitoring indicator for a mid-term evaluation under the European Green Deal.
72
The air pollution modelling tools used in this impact assessment could move from
limited test data to real world data.
 PO3a is expected to introduce effective continuous emission monitoring which is
likely to become a primary testing method for checking the environmental
compliance of vehicles. As such, it would help modernising inspection
procedures to periodically control the actual emission performance of vehicles
under the Roadworthiness Directives, which would allow to fix high emitting
vehicles earlier and avoid tampering of vehicles. This is expected to lead to
significant cost savings and health and environmental benefits that were not taken
into consideration in this impact assessment. If option PO3a were not to be
retained, the possibilities for the revision of the Roadworthiness Directives will
be significantly limited.
From the stakeholder consultations, there is a pressure from environmental and consumer
organisations and some Member States to set more ambitious requirements as in PO3a
and PO2b to support further improvement in air quality and thus contribute to protecting
public health and the environment. However, automotive industry has raised strong
concerns in the stakeholder consultations regarding the technological potential for
reducing emissions as proposed in PO2b. In particular, the question if the NOx emission
limits for cars could be reduced to a value lower than 30 mg/km and if high ambitious
real-driving testing boundaries (“free driving”) should be introduced led to high
stakeholder interest in Euro 7. Manufacturers’ concerns have been taken into account in
the design of the policy options by differentiation of emission limits, real-driving testing
boundaries and durability requirements and extensively discussed in AGVES meetings.
In fact the proportionality assessment agrees with some of the concerns, such as the
marginal gains of going to values lower than 30 mg/km for NOx proposed in PO3a and
that boundaries of testing need to be reasonable leading to PO2b being disproportionate
for cars/vans.
During the consultation activities, stakeholders from Member States, component
suppliers, civil society and citizens expressed their support for including the completely
new continuous emission monitoring, as considered in PO3a, as an important action to
measure real world emissions and to guarantee transparency and protection from
tampering. Concern of making pollutant data from vehicles available was not raised by
consumer organisations or citizens in the stakeholder consultations. These findings
illustrate that new continuous emission monitoring is generally found to be socially
acceptable. However, vehicle manufacturers were more reluctant on the matter, primarily
indicating the need for independent technology and equipment for continuous emission
monitoring to prevent high costs and risk for their international competitiveness. Still, the
results of the cost analysis in section 6.3.1 illustrate that the cost for available sensor
technology is counterbalanced by higher costs savings due to the expected simplified
type-approval.
The main consumer organisation and some automotive manufacturer and Member States
estimated in the targeted stakeholder consultation that even though more stringent
pollutant limits will have an impact on the vehicle price, it will also make battery electric
vehicles even more competitive. This potential accelerated shift to electric vehicles by
medium-ambitious Euro 7 has been taken into account in the modelling of the CO2
impact assessment for cars and vans32
by common econometric modelling of the
projected vehicle fleet (see Figure 7) and looking into the net benefits for high CO2 target
level taking into account other policies including stricter PO3a pollutant limits (see
Annex 4, Figure 14 and 15).
73
Automotive industry also raised concerns regarding competitiveness in view of the
investments that need be focussed on the climate ambition of the European Green Deal,
in particular in view of the proposed end-date for combustion-engine cars and vans. The
investment challenge for the automotive sector to reach the climate and zero-pollution
ambition was already recognised in the European Green Deal. The impact assessment
shows that the investment attributable to PO3a is not high. With the end-date of
combustion-engine cars/vans by 2035, the cumulative annual investment of PO3a and
CO2 emission standards amounts to €20.2 billion, out of which €19 billion is due to the
proposed CO2 target and €1.2 billion due to PO3a. Furthermore, the analysis of the
cumulative CO2 and PO3a investments also shows that there are benefits for the
competitiveness of the automotive industry for zero- and low-emission technologies
which will both be more and more demanded on the global market.
In conclusion, the preferred option for Euro 7 is medium-ambitious PO3a, for light-
and heavy-duty vehicles.
9 HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?
The Euro 6/VI evaluation identified as lesson learnt the lack of monitoring indicators in
the Euro 6/VI emission standards83
. Arrangements should be made to monitor and
evaluate the effectiveness of Euro 7 emission standards against operational objectives
and to establish causality between the observed outcomes and the legislation. For this
purpose, a number of monitoring indicators are proposed for the review of Euro 7
emission standards planned with the mid-term evaluation of the ‘fit-for-55’ initiatives.
Table 14 – Operational objectives and respective monitoring indicators for the preferred
policy option 3a
Operational objectives Monitoring indicators
Simplify the Euro
emission standards
 Number of emission type-approvals under Euro 7 per vehicle type
 Costs during implementation phase and administrative costs per emission
type approval
Provide appropriate air
pollutant limits for road
transport
 Proof of improved control of emissions under all conditions of use for all
regulated pollutants
 Enforcement costs, including costs for infringements and penalties in case
of non-compliance and monitoring costs
Enhance emission control
over the vehicles’ lifetime
 Evolution of emissions over the lifetime of vehicles as evidenced by
appropriate testing campaigns and continuous emission monitoring
The review of Euro 7 emission standards will also evaluate a set of more general
indicators from other EU air pollutant policies for road transport:
 Annual pollutant concentration levels in Europe’s urban areas and annual share of
road transport to the pollutant emissions as reported by the Member States to the
EEA under the National Emission reduction Commitments Directive (NECD)28
and
included in the annual report on air quality in Europe1
.
 Annual number of registered vehicles and share of powertrain technologies on EU
roads as reported by the Member States to the European Alternative Fuels
Observatory.108
 Annual development of impacts of air pollution on health (i.e. premature deaths
related to exposure of certain pollutants) as included in the annual report on air
quality in Europe.
74
 Annual share of road transport to the pollutant emissions of certain pollutants as
reported by the Member States to the EEA under the NECD.
 Annual number of notifications received from Member States for barriers of internal
EU trade of cars, vans, lorries/buses caused by technical prescriptions imposed by
national, regional or local authorities (i.e. bans of any kind) under the notification
procedure of Directive 2015/1535194
.
194
Directive (EU) 2015/1535 laying down a procedure for the provision of information in the field of
technical regulations and of rules on Information Society services; see also 2015/1535 notification
procedure


EN EN
EUROPEAN
COMMISSION
Brussels, 10.11.2022
SWD(2022) 359 final
PART 2/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
(ANNEX 1-4)
Accompanying the document
PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF
THE COUNCIL
on type-approval of motor vehicles and of engines and of systems, components and
separate technical units intended for such vehicles, with respect to their emissions and
battery durability (Euro 7) and repealing Regulations (EC) No 715/2007 and (EC) No
595/2009
{COM(2022) 586 final} - {SEC(2022) 397 final} - {SWD(2022) 358 final} -
{SWD(2022) 360 final}
Offentligt
KOM (2022) 0586 - SWD-dokument
Europaudvalget 2022
1
Contents
ANNEX 1: PROCEDURAL INFORMATION.............................................................................................. 1
1. LEAD DG, DECIDE PLANNING/CWP REFERENCES.................................................................... 1
2. ORGANISATION AND TIMING........................................................................................................ 1
3. CONSULTATION OF THE RSB ........................................................................................................ 1
4. EVIDENCE, SOURCES, QUALITY AND EXTERNAL EXPERTISE.............................................. 1
ANNEX 2: STAKEHOLDER CONSULTATION......................................................................................... 1
1. INTRODUCTION AND OVERVIEW CONSULTATION ACTIVITIES .......................................... 1
2. RESULTS OF THE CONSULTATION............................................................................................... 1
2.1. Description of the respondents.........................................................................................................................1
2.2. Analysis of responses.......................................................................................................................................1
2.2.1. Evaluation Euro 6/VI emission standards.................................................................. 1
2.2.2. Baseline ..................................................................................................................... 1
2.2.3. Simplification measures............................................................................................. 1
2.2.4. Stricter air pollutant limits for new vehicles.............................................................. 1
2.2.5. Continuous emission monitoring............................................................................... 1
2.2.6. Impacts of a stricter emission standard...................................................................... 1
2.3. Use of Consultation Results .............................................................................................................................1
ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................................................ 1
1. PRACTICAL IMPLICATIONS OF THE INITIATIVE ...................................................................... 1
2. SUMMARY OF COSTS AND BENEFITS ......................................................................................... 1
2.1 Euro 6/VI evaluation.................................................................................................................................................1
2.2 Euro 7 impact assessment.........................................................................................................................................1
ANNEX 4: ANALYTICAL METHODS AND RESULTS............................................................................ 1
1. DESCRIPTION AND RESULTS OF METHODS AND MODELLING TOOLS............................... 1
1.1. Fleet modelling with SIBYL............................................................................................................................1
1.2. Emissions modelling with COPERT................................................................................................................1
1.2.1. Emission factors ........................................................................................................ 1
1.2.2. Damage costs............................................................................................................. 1
1.2.3. Environmental impacts.............................................................................................. 1
1.3. Cost modelling, cost-benefit and cost-effectiveness analysis...........................................................................1
1.3.1. Cost modelling........................................................................................................... 1
1.3.2. Cost-benefit analysis.................................................................................................. 1
1.4. Methods for other direct and indirect economic and social impacts.................................................................1
1.4.1. Competitiveness: Export of EU motor vehicles to key destinations.......................... 1
2
1.5. Cumulative impacts on consumers, employment and industry competitiveness ..............................................1
1.5.1. Introduction ............................................................................................................... 1
1.5.2. Cumulative impacts on consumers ............................................................................ 1
1.5.3. Cumulative impacts on employment ......................................................................... 1
1.5.4. Cumulative impacts on industry ................................................................................ 1
2. BASELINE ........................................................................................................................................... 1
2.1. Evaluation Baseline..........................................................................................................................................1
2.2. Impact Assessment Baseline ............................................................................................................................1
3
Annex 1: Procedural information
1. LEAD DG, DECIDE PLANNING/CWP REFERENCES
This initiative is led by Directorate-General for Internal Market, Industry,
Entrepreneurship and SMEs (DG GROW).
The European Green Deal1
announces a proposal by 2021 for more stringent air pollutant
emissions standards for combustion-engine vehicles (Euro 7).
The Agenda Planning Reference is PLAN/2020/6308 for the development of Euro 7
emission standards for cars, vans, lorries and buses which is part of the Commission’s
2020/2021 Work Programme.
2. ORGANISATION AND TIMING
The evaluation of Euro 6/VI emission standards and impact assessment for more
stringent air pollutant emissions standards for combustion-engine vehicles (Euro 7) were
conducted in a back-to-back approach to meet the roadmap set by the European Green
Deal. That way, the findings of the evaluation which are included in Annex 5 are used to
inform further reflection on whether Euro 6/VI emission standards continue to provide
high level environmental protection in the EU and to ensure the proper function of the
internal market for motor vehicles.
DG GROW established on 10 February 2020 and chaired the Inter-Service Steering
Group for the development of Euro 7 emission standards for cars, vans, lorries and buses.
The following Directorates-General (DG) participated: Secretary-General, DG Climate
Action, DG Environment, DG Joint Research Centre, DG Justice and Consumers, DG
Mobility and Transport, DG Research and Innovation and DG Communications
Networks, Content and Technology. The following meetings took place:
1) 4 March 2020 – on the combined evaluation roadmap/inception impact assessment,
consultation strategy and public consultation
2) 10 July 2020 – on the Advisory Group on Vehicle Emission Standards (AGVES)
meeting of the 9 July, the first results from the Euro 6/VI evaluation and stakeholder
feedback to the inception impact assessment and targeted consultation of the
evaluation
3) 11 September 2020 – on the AGVES meeting of the 10 September, coherence to air
quality and Euro 7 in a global picture
4) 17 December 2020 – on the AGVES meeting of the 26/27 November, stakeholder
feedback to the public consultation and targeted consultation on the impact
assessment, on the final results from the Euro 6/VI evaluation and the inter-service
collaboration on the impact assessment
5) 7 April 2021 –on the first chapters 1-4 of the impact assessment staff working
document and the first results on the emission limits from the studies
6) 3 June 2021 – on the full impact assessment staff working document
7) 18 November 2021 – on the revised impact assessment staff working document
following RSB opinion
1
COM(2019) 640 final, The European Green Deal
4
3. CONSULTATION OF THE RSB
First submission
The Regulatory Scrutiny Board (RSB) of the European Commission assessed a draft
version of the present Impact Assessment on 7 July 2021 and issued its negative opinion
on 9 July 2021.
The Board’s main findings were the following and these were addressed in the revised
impact assessment report as indicated below.
Main RSB findings Revision of the Impact Assessment
Report
(1) The report does not present a
convincing case on the reasons for revising
the Regulation at this point of time. It lacks
clarity on the implications of related
initiatives such as the CO2 emission
standards for new cars and vans proposal
or the horizontal Ambient Air Quality
Directives.
The impact assessment has been fully
revised following the adoption of “fit-for-
55 package” and hence the end-date of
combustion-engine cars/vans by 2035
under the CO2 emission standards for new
cars and vans proposal was introduced in
the modelling.
The reasoning for the Euro 7 initiative, as
announced in the European Green Deal,
and the link to the Ambient Air Quality
Directives has been clarified in chapters 1,
2, 5, 7 and 8.
(2) The performance of the option
packages depends significantly on the final
political choices on the proposal for CO2
emission standards. The report does not
deal adequately with this critical
uncertainty
The implication of the end-date of
combustion-engine cars/vans by 2035 has
led to a revised baseline in chapter 5, a
revised assessment in chapters 6 and 7 and
discarded high ambitious policy option 3b
on future sensor technology in section 5.3.
(3) The report does not present a clear
comparison of option packages in terms of
effectiveness, efficiency and coherence.
The proportionality assessment of the
preferred option(s) is not sufficiently
balanced and informed by the most
important costs and benefits. It does not
sufficiently differentiate between light and
heavy duty vehicles.
Chapter 7 has been fully revised to present
a clear comparison of policy options in
terms of effectiveness, efficiency and
coherence and overall proportionality
assessment, differentiated between light-
and heavy-duty vehicles.
For methodological reasons and for clarity
purposes, the focus of the efficiency is on
net benefits (i.e. present value of the
benefits minus present value of the costs)
which do not bias the results for low-cost
options, in contrast to the benefit-cost ratio.
New chapter 8 on preferred options has
been elaborated, narrowing down the
options for light- and heavy-duty vehicles
based on the proportionality assessment in
chapter 7 and informed by the most
5
important costs and benefits.
(4) The report does not provide sufficient
information on the robustness of the
modelling work and the credibility of the
quantitative estimates. It does not address
the cumulative impacts from regulating
road transport emissions on consumers,
industry, competitiveness and employment.
Differences in stakeholders’ views have
not been reflected sufficiently in the
analysis.
The uncertainty and validation of the cost
and benefits have been further elaborated
in Annex 4, new section 1.3.2.1, discussed
in chapter 6 and considered in the
conclusions in chapters 7 and 8, to
underpin the robustness of the modelling
work and credibility of the quantitative
estimates.
Cumulative impacts from regulating CO2
and pollutant emissions from road transport
on consumers, competitiveness and
employment have been assessed in chapter
6 and Annex 4, new section 1.5, and
considered in chapters 7 and 8.
Differences in stakeholders’ views have
been further reflected in chapters 6, 7 and
8.
The Board also mentioned the following improvements needed, which were addressed in
the revised impact assessment report as indicated below.
RSB opinion: “what to improve” Revision of the Impact Assessment
Report
(1) The report should better explain the
evolution of the problem of air pollutants
related to road transport and the need for
further action on reducing them. It should
clarify upfront how a possible earlier end-
date for introducing new combustion engine
cars in the EU market would affect the
magnitude of the problem and how big the
problem of unaccounted real driving
emissions is.
The magnitude and evolution of the
problem of air pollutants related to air
pollutants has been clarified in chapter 2.
In particular, Figure 2 has been replaced to
clarify upfront how an end-date of
combustion engine cars and vans by 2035
affect the problem and how big the
problem of unaccounted real driving
emission is.
(2) For some emissions, the report should
present the reduction efforts in their broader
policy context. For example, the report
should describe how this initiative interacts
with the planned revision of Ambient Air
Quality Directives. It should explain why
industry specific action is necessary ahead
of this horizontal revision and how it will
ensure coherence and overall cost-efficient
emission reduction.
The interaction with the planned revision
of Ambient Air Quality Directives has
been elaborated in chapters 1, 2, 5, 7 and
8, including an explanation how Euro 7
standards will contribute coherently and
cost-efficiently to the horizontal revision,
notably by supporting Member States in
meeting their air quality commitments and
ensuring a consistent coverage of all
relevant air pollutants.
6
(3) The design of options packages should
facilitate an understanding of the
differences between certain types of actions.
The actions on comprehensive real driving
testing and extended durability are either
both absent or both present in all options.
The presentation of options should better
distinguish between the effects of these
measures.
The design of policy options has been
revised in chapter 5 and subsequently in
the analysis and conclusions, including a
differentiation of real driving testing
boundaries and durability and their effects
in all options. Cost and benefit of each
action included in the policy options are
presented in Annex 3, if possible.
(4) The report should narrow the range of
the preferred options, given the significant
performance differences between the option
packages, as well as between light and
heavy duty vehicles. It should present
clearly the trade-offs between the policy
packages. In view of the low benefit-cost
ratio of some option packages and the
uncertainty as regards the robustness of the
related estimates, the report should better
justify the proportionality of the policy
option packages.
Chapter 8 on preferred options has been
elaborated, narrowing down the options to
one preferred option 3a for light- and
heavy-duty vehicles based on the
comparison of the options in chapter 7,
informed by the most important costs and
benefits and presenting the main trade-offs
that are left to policy-makers to decide.
The proportionality of the preferred option
for light-duty vehicles has been elaborated
in chapter 7.4 in view of the low net
benefits.
(5) The report should explain to what extent
the analysis and the conclusions reached in
the support studies are uncontested and
verified. It should explain the buy-in of
stakeholders to the conclusions, especially
in relation to the technological potential for
reducing emissions, the potential
accelerated shift to electric vehicles and the
impacts on competitiveness, where industry
stakeholders seem to have different views.
In case of remaining uncertainty, the report
should complement the analysis by
providing ranges of expected costs and
benefits for the car and van option
packages, based on alternative sets of
assumptions on costs and benefits.
The uncertainty and validation of the cost
and benefits have been further elaborated
in Annex 4, new section 1.3.2.1. The
medium to high level of confidence of the
cost and benefit estimates verified by
stakeholders and experts is considered
sufficiently robust to present in chapter 6
average values for the cost and benefit
elements. Nevertheless, the cost-benefit
analysis in chapter 7 is complemented by
providing ranges of expected costs and
benefits to make political choices of the
policy options for light- and heavy-duty
vehicles.
The buy-in of stakeholders to the
conclusions is discussed in chapter 8,
especially in relation to the technological
potential for reducing emissions, the
potential accelerated shift to electric
vehicles and the impacts on
competitiveness.
In addition, an alternative set of
assumptions on emission limits and
durability to address remaining
uncertainty in relation to technological
potential for reducing emissions is
7
assessed in Annex 8 and considered in
chapters 7 and 8.
(6) The report should better discuss the
cumulative impacts on consumers,
employment and industry competitiveness.
For example, when discussing affordability
it should acknowledge that consumers will
face not only the pass-on of additional
regulatory costs from Euro7 but also from
the new CO2 emission standards.
Cumulative impacts from regulating CO2
and pollutant emissions from road
transport on consumers, employment and
competitiveness have been assessed in
chapter 6 and Annex 4, section 1.5 and
considered in chapter 7. For example,
Annex 4, section 1.5.2 discusses the
cumulative consumer affordability from
Euro 7 and the new CO2 emission
standards for cars/vans.
Resubmission
The Regulatory Scrutiny Board (RSB) of the European Commission assessed the revised
Impact Assessment and issued a positive opinion with reservations on 26 January 2022.
The Board’s main findings were the following and these were addressed in the final
impact assessment report as indicated below.
Main RSB findings Revision of the Impact Assessment
Report
(1) The report does not sufficiently reflect
the significant differences in the scale of
the problems, and corresponding need to
act, between the cars/vans and lorries/buses
segments.
The different contribution of light-duty
compared to heavy-duty vehicles to the
problem and need to act is better reflected
in chapter 2. A box was added to highlight
the differences between the two segments.
(2) The rationale behind the revised policy
packages is not fully clear.
The rationale behind the revised policy
packages is better explained in chapter 5.
(3) The report does not make a convincing
case for the preferred option. The
proportionality analysis does not bring out
clearly enough the significant performance
differences in terms of net benefits and
benefit-to-cost ratios between the preferred
options for cars/vans and lorries/buses
respectively. The evidence presented on
effectiveness, efficiency and coherence is
not compelling enough to narrow the
preferred options to one for both segments.
The reasoning for the preferred option 3a
for light- and heavy-duty vehicles has been
strengthened in chapter 8, including the
underlying effectiveness, efficiency,
coherence and proportionality analysis and
evidence in chapter 7.
The Board also mentioned the following improvements needed, which were addressed in
the final impact assessment report as indicated below.
RSB opinion: “what to improve” Revision of the Impact Assessment
8
Report
(1) The report should better reflect the
significant differences in the scale and
evolution of the problems between the
cars/vans and lorries/buses segments in the
analysis throughout the report. It should
better justify the need to act as regards both
segments in view of the planned phasing out
of cars/vans with an internal combustion
engine by 2035 and the limited time
remaining to recoup the necessary
investments. It should nuance the need to be
the ‘emission standard setter’ and
technological leader for a type of vehicle
that will disappear from the market
relatively soon.
The differences between light- and heavy-
duty vehicles have been better reflected in
the problem definition and throughout the
report (chapters 2, 6, 7, 8). The report
clarifies that the largest share of the costs
for light- and heavy-duty vehicles occur in
the first ten years after 2025 and only a
small share of the costs remain after 2035,
mainly resulting from the requirements
regarding brake emissions for all
cars/vans, including zero-emission
vehicles. The need to be the emission
standards setter and technological leader
in the future was nuanced.
(2) While the report presents a revised and
simplified set of policy packages, it should
clarify whether these are the packages
considered most relevant by stakeholders
and whether other, possibly better
performing, combinations of measures have
been assessed. This should include, for
example, an explanation why it has not
considered continuous emission monitoring
as part of the low ambition option package,
to avoid rendering it a weaker option by
design.
The rationale behind the revised policy
packages is better explained in chapter 5,
in particular why option 1 does not include
new digital ambition and why the options
presented are the best performing
combination of measures while the actions
have been differentiated in all options.
(3) The impact and proportionality analyses
should bring out more clearly the significant
performance differences between the
preferred options for cars/vans and
lorries/buses in terms of effectiveness and
efficiency. Given that both – the net
benefits and the benefit-cost ratios – are to a
large extent higher for the lorries/buses
segment, the report should argue more
convincingly why equally ambitious action
is justified as regards cars and vans. This
assessment should take into account that the
low green ambition option offers net
benefits that clearly outperform the high
green ambition options (2b) and comes
relatively close to those available under the
medium green ambition option (2a) while
offering by far the best benefit-cost ratio
among the considered cars/vans options.
The narrowing of preferred options should
The effectiveness, efficiency, coherence
and proportionality analyses have been
strengthened in chapter 7 acknowledging
the higher net benefit of heavy-duty
vehicles, while underlining that also the
lower net benefit of light-duty vehicles
would make transport drastically less
polluting, especially in cities.
Chapter 7 discusses better why for
methodological reasons and for clarity
purposes, the focus of the efficiency is on
net benefits (i.e. present value of the
benefits minus present value of the costs)
which do not bias the results for low-cost
options, in contrast to the benefit-cost
ratio.
The reasoning for the preferred option 3a
for light- and heavy-duty vehicles has
been strengthened in chapter 8, including
9
take into account all available evidence
presented in the report, including, to the
extent possible, the acceptance of the
stakeholders and the potential concerns of
social acceptability of continuous emissions
monitoring as the report states.
the acceptance of stakeholders (industry,
NGOs, citizens).
(4) The report (still) needs to be clearer on
how big the problem of unaccounted real
driving emissions is. It should assess the
robustness of the evidence that 20% of
current real-driving testing may exceed
significantly the current emission limits.
The results of the preliminary analysis done
for the revision of the EU air quality
legislation should be better presented,
including in a more accessible manner.
Evidence on the 20% unaccounted real
driving emissions and results of the
preliminary analysis done for the revision
of the EU air quality legislation have been
added in chapter 2.
4. EVIDENCE, SOURCES, QUALITY AND EXTERNAL EXPERTISE
In autumn 2018, preparatory work of the Euro 7 initiative started with the first
stakeholder conference organised in October. During this conference, an Advisory Group
on Vehicle Emission Standards (AGVES) was set up by joining all relevant expert
groups working on emission legislation (see Annex 2 for more details on AGVES). The
broad evidence and sources provided and discussed in this expert group are available in
the public AGVES CIRCABC2
.
In further preparation of the initiative and to collect convincing and robust scientific
evidence, a first post-Euro 6/VI study (Part A) was launched with the tasks to review,
compare and draw lessons from legislation in other part of the world, evaluate the
effectiveness of current EU emission tests and develop and assess new emission tests for
regulated and non-regulated pollutants3
. As a follow-up for this first study, a second
commissioned study, post-Euro 6/VI Study Part B, covered a thorough review of the
cost-effectiveness of measures that were introduced by the first study in addition to a
feasibility assessment of new pollutant emission limits for all vehicles and an analysis of
the simplification potential of vehicle emission standards. This study also supported the
evaluation of the Euro 6/VI framework, while providing the evidence necessary for this
impact assessment.4
Both studies were carried out by the CLOVE consortium which
2
AGVES CIRCABC, This group has been established to facilitate the exchange of information between
the members of the Advisory Group on Vehicle Emission Standards (AGVES).
3
CLOVE, 2022. Study on post-Euro 6/VI emission standards in Europe – Combined report: PART A
including PART B Techno-economic feasibility of new pollutant emission limits for motor vehicles. The
findings from the study were presented and discussed continuously in the AGVES meeting.
4
CLOVE, 2022. Study on post-Euro 6/VI emission standards in Europe – PART B Potentials for
simplification of vehicle emission standards; CLOVE, 2022. Study on post-Euro 6/VI emission standards
in Europe – PART B: Retrospective assessment of Euro 6/VI vehicle emission standards; CLOVE, 2022.
Study on post-Euro 6/VI emission standards in Europe - PART B: Assessment and comparison of post-
Euro 6/VI impact assessment options. The findings from the studies were presented and discussed
continuously in each AGVES meeting.
10
included key experts in Europe from the Laboratory of Applied Thermodynamics of the
Aristotle University of Thessaloniki (LAT) (GR), Ricardo (UK), EMISIA (GR), TNO
(NL), TU Graz (AT), FEV (DE) and VTT (FI). Both studies were underpinned by
analysis and tests performed by the Joint Research Centre of the Commission, in its
facilities located in Ispra Italy. Further elements were considered taking advantage of
work performed in the context of UN GRPE5
(Working Party on Pollution and Energy)
for the harmonisation of emission type approval regulations. Such elements included
battery durability and brake emissions.
Since the post-Euro 6/VI Study Part B supported both the evaluation and the impact
assessment, it also helped collecting evidence and data through different channels,
including both targeted stakeholder consultations on the evaluation and impact
assessment (see Annex 2). When it comes to estimating the costs for both the impact
assessment and the evaluation, the contractors had some difficulties due to limited
provision of cost data by stakeholders during the targeted consultations. To prevent
implications on the robustness of the findings, the methodology was changed to consider
additional data from various databases, including EEA NECD database6
, Euro 6/VI
vehicle sales data from IHS Markit7
, OECD statistics8
, the Handbook on external costs
and emission factors of Road Transport9
, structural business statistics from Eurostat10
,
data requests to type-approval authorities and CLOVE expertise. The subsequent
estimates have later been validated by key stakeholders to ensure robust results.11
5
https://unece.org/transportvehicle-regulations/working-party-pollution-and-energy-introduction
6
EEA, 2021. National Emission reduction Commitments Directive (NECD) emissions data viewer 1990-
2018
7
IHS Market, 2021. Provision of data on vehicle sales in the EU-28 for Evaluation of Euro 6/VI vehicle
emission standards
8
OECD, 2020. Statistics on Patents –Technology Development Environment
9
European Commission, 2019. Handbook on the external costs of transport
10
Eurostat, 2020. Annual detailed enterprise statistics for industry (NACE Rev. 2, B-E) [sbs_na_ind_r2];
Eurostat, 2020. Passenger cars, by age [road_eqs_carage]; Eurostat, 2020. Passenger cars, by type of motor
energy [ROAD_EQS_CARPDA]
11
For more information see CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3,
chapter 4.2. Study limitations.
11
Annex 2: Stakeholder consultation
1. INTRODUCTION AND OVERVIEW CONSULTATION ACTIVITIES
This synopsis report summarises all the consultation activities for the preparation of the
proposal for the development of Euro 7 emission standards for cars, vans, lorries and
buses. The consultation process for this development was more extensive than what is
usually reserved for similar regulations and went into details of the testing regime,
boundary conditions and technologies required to achieve the emission limits.
The initiative was discussed for the first time with stakeholders during a stakeholder
conference in October 201812
. Subsequently, the Advisory Group on Vehicle Emission
Standards (AGVES) was set up by merging relevant expert groups from industry, civil
society and Member States, with ten meetings and one ad-hoc workshop on
simplification from July 2019 to April 2021. The result of these extensive consultation
activities were used for the preparation of the Euro 6/VI evaluation and Euro 7 impact
assessment.
The Inception Impact Assessment (IIA) was launched on the “Have your say” page of the
Europa website on 27 March to 3 June 2020. The 18-week Public Consultation (PC) on
the proposal followed on 6 July 2020 and was open for contributions until 9 November
2020. In addition, two 14-week targeted consultations (TC) – one for the Evaluation of
Euro 6/VI (4 March to 8 June 2020) and one for the Impact Assessment of Euro 7 (3
August to 9 November 2020) – were performed by the CLOVE consortium focussing
more on the detailed and technical aspects of to the initiative. Due to the effects of
COVID-19 and containment measures, the public and targeted stakeholder consultations
were extended by 6 weeks.
The stakeholder consultation was intended to collect evidence and views from a broad
range of stakeholders and citizens with an interest in vehicle emissions. The aim was
assessing the five evaluation criteria of the Euro 6/VI13
(see Annex 5) as well as potential
impacts of the reviewed framework. Since this Impact Assessment took a back-to-back
approach, both questions on the implementation of the current Euro 6/VI emission
standards and potential policy options regarding the Euro 7 initiative were considered for
the different consultation activities. For this purpose, the views of each stakeholder group
were considered important (see 2.1).
The main communication channel was the “Have your say” portal for the PC and the
public AGVES CIRCABC and extensive bilateral communication with stakeholders for
the TC. Awareness of the PC was also raised on Commission websites, platforms such as
EIONET, social networks and newsletters. The link to the PC was also shared with
appropriate representatives from Member State authorities, who were encouraged to
reach out to national stakeholders, as well as with the European Economic and Social
Committee and the European Parliament. In addition, the stakeholders participating in
12
Preparing automotive emission standards for the future | Internal Market, Industry, Entrepreneurship and
SMEs (europa.eu)
13
Regulation (EC) No 715/2007 on type-approval of motor vehicles with respect to emissions from light
passenger and commercial vehicles (Euro 5 and Euro 6) and its implementing Regulation (EU) 2017/1151;
Regulation (EC) No 595/2009 on type-approval of motor vehicles and engines with respect to emissions
from heavy-duty vehicles (Euro VI) and its implementing Regulation (EU) No 582/2011
12
the AGVES meetings were especially encouraged to contribute.
2. RESULTS OF THE CONSULTATION
2.1. Description of the respondents
Table 1 provides an overview of the number of stakeholders that participated in each
consultation activity described above. The PC also includes the feedback received on the
IIA. Stakeholders are divided in three large groups, namely Member States and national
authorities (hereafter referred to as “Member States”), automotive industry and civil
society. The group, civil society, is a combination of separated groups from the
consultation strategy: consumer organisations, environmental NGOs and other
stakeholders. Since contributions from these separate groups were limited in certain
activities, the aggregate was considered for the analysis. In case of striking differences,
the categories are discussed in parallel. Citizens participated only in the consultation
activities open to the public.
Each stakeholder group has a different level of interest and is either directly or indirectly
affected by the current and future vehicle emissions standards. In the TC, a number of
interviews with stakeholders were also conducted by the CLOVE consortium, further
elaborating on the responses to the questionnaire. Comments received during these
interviews were integrated in the analysis.
Table 1 – Participation rates per stakeholder group, category and activity
Stakeholder group Category
Consultation activity
Public
consultation
Targeted
consultation
evaluation
Targeted
consultation
impact
assessment
Expert
groups of the
Commission
1.Member States
and National
Authorities
National, regional and
local authorities
20 9 7 3
Type-approval authorities 1 5 2 ―
Technical services 1 7 7 ―
2.Automotive
Industry
Vehicle manufacturers 20 14 16 4
Component suppliers 46 12 17 6
Associations/Other
industry stakeholders
54* 17 12 9
3.Civil Society
Consumer organisations 7 2 2 2
Environmental NGOs 12 3 2 2
Other stakeholders 8 4 2 ―
4.Citizens14
― 64 ― ― ―
Total ― 233 73 67 24
* including 30 contributions from fuel and energy industry
2.2. Analysis of responses
2.2.1. Evaluation Euro 6/VI emission standards
As presented in Figure 1, in the PC stakeholders from all groups believe that over the last
14
The lower response rate is not necessarily a problem, since the interest of the general public is
represented by both the respondents from civil society and from Member States and national authorities.
13
10 years, air pollution from new vehicles has reduced suggesting a positive perception of
Euro 6/VI’s effectiveness.
Figure 1 – PC Q3: Over the past 10 years, based on your experience what has happened
to air pollution originating from:
a) New cars and vans b) New lorries and buses
The responses from all groups participating in the TC suggest that the Euro 6/VI has
made vehicles on EU roads cleaner with the majority of automotive industry considering
Euro 6/VI as the most important factor. In TC and PC, two suppliers and an
environmental NGO also indicated that there is room for improvement to meet the targets
of the European Green Deal. While the responses from all stakeholder groups to TC
suggest that the introduction of RDE testing reduced the gap between type-approval and
real-world emissions, in PC the majority of industry and citizens indicated that RDE
testing truly ensures that cars and vans are compliant with the pollutant limits in all
driving conditions. In addition, responses from all groups to PC, excluding industry,
suggest that the current shortcomings in the existing on-road tests at least contribute
somewhat to increasing emissions. In different activities, automotive industry stressed
that the actual impact of the latest standards is not yet fully known and that air quality
modelling is important to determine what measures will lead to improved air quality.
While in TC the regulatory costs associated with the standards were reported to have
increased significantly with Euro 6/VI by the groups (civil society to a lesser extent), the
majority of automotive industry and Member States indicated that compared to the
benefits for their organisation the costs were not high. Additionally, the responses from
all stakeholder groups suggest that the costs compared to the benefits for society are low.
Next to that, Figure 2 illustrates that the vast majority of all groups in PC were of the
view that Euro 6/VI has increased vehicle prices. Further, the majority of stakeholders
from all groups in TC and PC indicated that instead of achieving simplification, Euro
6/VI has resulted in further complexities in nearly all aspects (e.g. tests, differences in
limits, reporting requirements). Lastly, a key consumer organisation in TC indicated that
the last Euro 6d step including the introduction of RDE testing had positive effects on
consumer trust damaged by Dieselgate.
14
Figure 2 – PC Q3.1: In your view, what effect did the Euro 6/VI standards have on the
price of the following vehicles?15
a) Price of cars b) Price of lorries
The responses from automotive industry, Member States and civil society to TC
highlight that there are ongoing air pollution and health issues associated with road
transport and that there is still need for action. In addition, key environmental NGOs
stressed that there is no safe level of air pollution. When asked to evaluate policy
measures based on their success in limiting vehicle emissions in the PC, the majority of
all groups indicated that strict regulations are the most successful. Still, the majority of
civil society and Member States indicated that the current emission limits are not strict
enough, while the majority of all groups believes that Euro 6/VI does not cover all
relevant pollutants. In addition, the results of PC suggest that the majority from all
groups apart from industry believes that vehicles do not comply with emission limits in
all driving conditions and over their entire lifetime. The responses to TC suggest that,
despite the emergence of electric vehicles, the cleaning of the ICE remains relevant for
all groups.
The responses from all groups to TC suggest that overall manufacturers are provided
with a coherent legal framework. However, a large share from industry indicated that
there are important internal inconsistencies in relation to the emission limits,
requirements and testing procedures, especially for cars/vans. Additionally, a significant
part of the respondents from industry and the Member States reported incoherence of
Euro 6/VI emission standards with Ambient Air Quality directive16
and the CO2
emissions17
. A majority of respondents from Member States and civil society indicated
incoherencies with the Roadworthiness Directives18
.
The results of TC and PC illustrate that the majority of from all groups believe that there
is significant added value in regulating vehicle emissions at EU level compared to what
could have been achieved at national or international level. Still, industry believes that
lower costs could be achieved when emissions were regulated at international level.
15
Similar results were found for the price of vans and buses.
16
Directive 2008/50/EC on ambient air quality and cleaner air for Europe
17
Regulation (EU) 2019/631 setting CO2 emission performance standards for new passenger cars and for
new light commercial vehicles, and repealing Regulations (EC) No 443/2009 and (EU) No 510/2011;
Regulation (EU) 2019/1242 setting CO2 emission performance standards for new heavy-duty vehicles
18
Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers; Directive
2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating
in the Union
15
2.2.2. Baseline
The results from PC emphasise that the majority of Member States, civil society and
citizens consider new Euro standards to be appropriate to further reduce vehicle
emission. For automotive industry 29 respondents disagree for cars/vans, while 30
disagree for lorries/buses (Figure 3).
Figure 3 – PC Q5: To what extent do you agree with the following statements? New
Euro standards would be appropriate to further reduce air pollutant emissions from:
a) Cars and vans b) Lorries and buses
Also in other activities, industry stressed that preserving the Euro 6/VI is a realistic and
balanced option. They claim that without action industry is given better stability, while
further improvements in air quality would be realised through the renewal of the fleet and
through focussing on CO2 measures. Several stakeholders from civil society and industry
indicated in PC that a new Euro emission standard is needed.
2.2.3. Simplification measures
The results from PC showed that the majority from all groups consider Euro 6/VI to be
complex (Figure 4). While a large share of industry stakeholders reported inconsistencies
for Euro 6/VI in TC, the responses from civil society and Member States suggest that the
legislation for lorries/buses is considered less complex. The responses to PC from all
groups show that complexities lead to significant compliance costs and administrative
burden. Additionally, all groups apart from industry believe that complexity hampers
environmental protection, while civil society adds that it leads to misinterpretations.
Figure 4 – PC Q8: Please indicate if you consider the Euro 6/VI simple or complex.
16
Single legislative tool
The responses to PC suggest that the majority from all groups, especially industry, does
not support introducing a single Euro emission standard for cars, vans, lorries and buses
due to lack of understanding what this would imply. Industry indicated that the two
standards should remain distinct to allow for proper differentiation and international
harmonisation. Still, Member States express support to merge the basic acts for Euro
6/VI with almost identical legal structure (715/2007 and 595/2008). Support from all
groups is given towards eliminating the currently overlapping area between the two
regulations.
Streamlined testing and uniform limits
The results of PC demonstrate that a large majority across all groups considers the
introduction of technology-neutral limits and testing to be important to reduce
complexity. Member States, civil society and citizens also support the introduction of
common application dates for new vehicle types and new vehicles, automotive industry
does not consider this to be feasible. Automotive industry showed great support for the
removal of obsolete tests in all consultation activities. Member States were rather divided
on the matter. In TC, industry was sceptical regarding the replacement of all laboratory-
based tests by extended on-road testing, which was generally supported by the other
groups. In PC the vast majority of Member States, civil society and citizens believe that
shortcoming in the existing on-road tests contribute to an increase in emissions.
Stakeholders from all groups already mentioned in their feedback to IIA that RDE and
PEMS need to be improved to cover all or more conditions of use. Additionally, Member
States and civil society (and industry to a lesser extent), consider it important to extend
the operation conditions (e.g. trip duration) and environmental conditions (e.g.
temperatures). Through AGVES, industry indicated that such extensions should take into
account the statistical relevance of these conditions.
2.2.4. Stricter air pollutant limits for new vehicles
Figure 5 shows that apart from industry, the majority of all groups in PC show support
for the development of stricter limits for regulated pollutants and new limits for non-
regulated pollutants.
Figure 5 – PC Q13: Indicate to what extent the following actions are important to
improve the effects of emission limits.
a) Developing stricter limits for regulated pollutants b) Setting new limits/testing procedures
for non-regulated pollutants
17
Stricter limits for regulated pollutants
The responses to PC indicate that the vast majority from Member States, civil society and
citizens believe that the current emission control technology leave room for additional
reductions. Through AGVES and IIA, three environmental NGOs, one main supplier and
a respondent from the fuel- and energy industry expressed that technologies to further
reduce the emissions are mature and either already or close to be commercially available.
Other industry stakeholders mentioned in the different activities that reviewing the limits
should start with a careful assessment of the real benefits for air quality. The result from
the public consultation shows that most stakeholders from civil society and Member
States consider the current limits for NOx and PM/PN to be insufficiently strict.
New limits for non-regulated pollutants
The large majority of stakeholder from Member States, civil society and citizens in PC
indicated that there are emerging unregulated air pollutants. In both PC and TC, several
stakeholders (mostly industry), declared that such pollutants should only be regulated if
they can be reliably measured and if regulating them would have real benefits for air
quality. When looking into which pollutants should be added, both consultation activities
suggest high support from Member States and civil society in reducing the size of PN
emissions to also cover ultra-fine particles. High support was also given towards the
inclusion of non-exhaust emissions (i.e. brake and tyre emissions). The majority of
respondents from Member States, civil society and citizens mentioned the increasing
importance of these emission sources following the rising popularity of larger and fast-
accelerating vehicles (e.g. SUVs, battery electric vehicles). Also, introducing an NH3
limit for cars and vans receives significant support from Member States and civil society.
Including limits for NO2, N2O and CH4 (for cars and vans) is also supported by these
groups, but to a lesser extent. In TC, however, the majority of industry and Member
States indicated that separate NO2 limits are not necessary, as long as NOx emissions
remain low in real-world conditions.
Through their feedback to IIA, several industry stakeholders underlined that legislative
changes should be preceded by a careful cost-benefit analysis, which considers the
current economic situation, and incentives for the introduction of more advanced
technology by early adopters are important.
Real-world emissions and durability
Figure 6 illustrates that in PC the majority of all groups, excluding automotive industry,
believe that in Euro 6/VI real-world emissions are not adequately monitored or limited
over the entire lifetime of vehicles. Tampering, vehicle ageing, inadequate technical
inspections and the cost of maintenance were indicated as potential causes. In all
activities all groups have shown support for the development of clear requirements for
the protection against tampering.
Through feedback to IIA, a number of stakeholders from industry, Member States and
environmental NGOs indicated that emission performance should remain consistent over
the real lifetime of vehicles and that durability requirements need to be extended to
ensure this. In TC, the majority from Member States, civil society and industry (to a
lesser extent) identified the importance of limiting emissions over the average age of
vehicles until the end-of-life. In the AGVES meetings, stakeholders from civil society
have stressed on several occasions that while on average cars in the EU are 10.8 years,
cars stay on the road much longer in Eastern and Southern Europe, often in excess of 15
18
years. Most manufacturers stressed in this consultation that the emissions of older
vehicles are generally dependent on maintenance which is outside their responsibility.
Figure 6 – PC Q14: To what extent do you agree with the following statements? Real-
world emissions are not adequately [insert a/b] over the entire lifetime of a vehicle in
Euro 6/VI.
a) monitored b) limited
2.2.5. Continuous emission monitoring
While only few manufacturers expressed support, the results of PC show that the
majority of the other stakeholder groups support the implementation of continuous
emission monitoring (CEM) of emissions as an action to measure real-world emissions.
In TC, a large majority from automotive industry and all respondents of Member States
and civil society indicated a combination of methods, such as new on-board monitoring
(OBM) and existing on-board diagnostics (OBD), may be required to ensure lifetime
compliance. The large majority of manufacturers, however, indicated that they do not
know whether such a combination of methods would be required. In addition, most
manufacturers added that OBM can only be used for a limited number of pollutants in the
near future. Regarding how OBM should be used, the majority of respondents from
industry, Member States and civil society in TC somewhat agreed that the relevant values
should be read-out during technical inspections. On the other hand, two suppliers and one
Member State consider “over the air transfers” to be more effective. In their feedback to
IIA, two industry respondents indicated that that CEM in combination with stricter limits
could be overly burdensome for European manufacturers.
In PC, geo-fencing was only considered to be an important action for improving the
effect of emission limits by a majority of respondents from the Member States and
citizens. The responses to TC suggest that civil society thinks that a vehicle should be
operated in zero-emission mode in more polluted areas. The responses from automotive
industry to this consultation, on the other hand, suggest that they think it would be
difficult to precisely monitor and enforce geo-fencing.
2.2.6. Impacts of a stricter emission standard
Through TC, views on the possible impacts of new emission standards on industry
competitiveness were collected. The results in Figure 7 show that while Member States
and civil society generally expect a positive relationship between stricter standards and
competitiveness, differing views were found amongst industry stakeholders with
suppliers anticipating positive impacts and manufacturers anticipating negative impacts.
Almost half of the suppliers stressed that new limits will create new business
19
opportunities and quality jobs. A large share of industry, Member States and civil society
stakeholders indicated that a higher-level education and new skills will be required for
the majority of the personnel. The majority of vehicle manufacturers, however, expressed
concern that stringent emission limits and testing over all driving conditions may
accelerate the shift to electric vehicles or even take the ICE off the market. About half of
industry claimed that employment in businesses focused on traditional ICE and/or
exhaust after treatment parts would be negatively affected.
Input from TC on consumer affordability indicated that the majority from industry
consider stringent emission limits to increase the price of vehicles and to reduce demand
and fleet turn-over. In PC, the majority from Member States and civil society disagreed
that the Euro standards are too costly and make cars unduly expensive. In, TC a
consumer organisation stated that the previous Euro standards illustrate that an
appropriate level of ambition can make vehicles significantly cleaner while not making
them disproportionately more expensive.
Figure 7 – TC Q14: Please indicate to what extent you agree or disagree with the
following statement(s) relating to how stricter post-Euro 6/VI standards may affect the
relevant EU industry19
19
Supporting Euro 7 impact assessment study, Annex II: Input from targeted stakeholder consultation
(10.6 Other impacts of new vehicle emission standards)
20
2.3. Use of Consultation Results
The replies to the three questionnaires as well as information and data through all
consultation activities were taken into consideration for the evaluation of the Euro 6/VI
and for the preparation of the Euro 7 impact assessment. The collected stakeholder
evidence made it possible to supplement, cross-check and confirm the evidence already
gathered through other research (see Annex 4) in this staff working document and the
supporting studies20,21,22,23,24
.
Depending on the nature of the specific questions, the responses were analysed in the
Euro 6/VI evaluation and Euro 7 impact assessment quantitatively or qualitatively for
each stakeholder group. For this purpose, the closed questions (Yes/No and Likert-scale
questions) in PC25
and TC26
were analysed using visual aids, such as bar charts, while the
responses to the open questions and other feedback were examined by labelling and
organising common elements in the responses over the different stakeholder groups. If no
clear position was expressed within the same group, the groups were further
disaggregated based on the sub-groups to identify common views. In the case of the
Member State and civil society stakeholder groups, the views were generally found to be
consistent. The further disaggregation was especially relevant in the case of automotive
industry, where vehicle manufacturers and component suppliers often had differing
views. In addition to this, the individual manufacturers and suppliers coordinated their
responses to the different consultation activities through the main manufacturers and
suppliers associations (ACEA and CLEPA).
The feedback from all stakeholder groups has been taken into account for evaluating
Euro 6/VI. Feedback and differences in stakeholders’ views were carefully analysed and
taken into account if credible. Stakeholder views from industry and Member States have
been particularly useful for identifying the standards’ effectiveness, efficiency and
coherence. For evaluating relevance and EU-added value, views from all stakeholder
groups have been taken into account. All feedback and concerns were taken into account
in the Euro 7 impact assessment. In particular, the views from industry and Member
States were helpful to analyse the problem of complexity and in that way develop option
1 and information provided by industry on the hardware costs for emission control
technologies were assessed in option 2 and 3. Feedback and concerns raised by the
Member States, industry, civil society and citizens have been taken into account in the
design and assessment of the options, particularly with regard to the technological
potential for reducing emissions by emission limits, durability, testing conditions and
CEM, the potential accelerated shift to electric vehicles and the impacts on
competitiveness, where industry stakeholders seem to have different views.
20
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
21
CLOVE, 2022. Technical studies for the development of Euro 7: Simplification. ISBN 978-92-76-
56405-8.
22
CLOVE, 2022. Technical studies for the development of Euro 7: Durability of light-duty vehicle
emissions. ISBN 978-92-76-56405-8.
23
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3.
24
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7
25
European Commission, 2020. Presentation AGVES Meeting 26 November 2002: Post-Euro 6/VI public
stakeholders consultation (Question 5)
26
See footnote 20 and 21
21
The widely supported view against the introduction of a single Euro emission standard
for cars/vans and lorries/buses was not entirely considered, since the objectives of proper
differentiation as well as international harmonisation stated by industry should be
achievable also with the basic acts (715/2007 and 595/2008) merged while the specific
implementing regulations are kept separate. This was confirmed with the stakeholders in
the follow-up interviews linked to the targeted consultation on the impact assessment and
in the AGVES meeting of 16 November 2020.
22
Annex 3: Who is affected and how?
1. PRACTICAL IMPLICATIONS OF THE INITIATIVE
The Euro 7 emission standards will apply to vehicle and component manufacturers active
in the automotive supply chain and national authorities responsible for type-approval of
vehicles in the Member States. They will need to comply with the requirements of the
Euro 7 emission standards summarised in Table 2.
Table 2 - Summary of Euro 7 requirements
What By whom By when
Option 1
Adapt vehicle production to
technology-neutral limits for
certain regulated pollutants.
Manufacturers, including component
suppliers.
2025
Apply or witnessing simplified
and revised testing procedures for
emission testing of cars, vans,
lorries and buses.
Manufacturers, including component
suppliers.
National authorities responsible for type-
approval.
2025
Granting Euro 7 emission type-
approvals
National authorities responsible for type-
approval.
2025
Checking compliance during
market surveillance
National authorities responsible for market
surveillance
2025
Option 2
Adapt vehicle production to
medium/high ambitious emission
limits, testing procedures and
durability.
Manufacturers, including component suppliers 2025
Apply or witnessing simplified
and revised testing procedures for
emission testing of cars and vans,
and lorries and buses.
National authorities responsible for type-
approval.
Manufacturers, including component
suppliers.
2025
Granting Euro 7 emission type-
approvals
National authorities responsible for type-
approval.
2025
Checking compliance during
market surveillance
National authorities responsible for market
surveillance
2025
Option 3
Adapt vehicle production to
medium ambitious emission
limits, testing procedures and
durability.
Manufacturers, including component suppliers 2025
Adapt vehicle production to
continuous emission monitoring
(CEM).
Manufacturers, including component
suppliers.
2025
Shift part of the emission testing
to controlling emissions through
CEM functions.
National authorities responsible for type-
approval.
2025
Granting Euro 7 emission type-
approvals
National authorities responsible for type-
approval.
2025
Checking compliance during
market surveillance
National authorities responsible for market
surveillance
2025
23
2. SUMMARY OF COSTS AND BENEFITS
2.1 Euro 6/VI evaluation
Table 3 - Overview of costs and benefits following the introduction of the Euro 6/VI
emission standards27
I. Overview of costs – benefits identified in the evaluation for EU-28
Type of costs and
benefits28
Stakeholder group
Overview of costs and benefits identified in the evaluation29
Manufacturers
and
suppliers
Administrations
Citizens
and
consumers
Direct costs (regulatory costs)
1) Equipment costs
Compared to the estimates
of the former Euro 6/VI
Impact Assessments:
€213 per diesel LDV30
€2 539-€4 009 per HDV
X  Hardware costs
Cost of €228-€465 per petrol LDV and €751-€1703 per diesel LDV
(moving from Euro 5 to Euro 6d)
Cost of €1 798-€4 200 per HDV
Total cost up until 2020:
€17.2–€43.2 billion for Euro 6
€4.1-€9.5 billion for Euro VI
High level of confidence that costs are within the above intervals. Costs
per vehicle are expected to decline gradually following a learning effect.
 R&D, calibration, facilities, tooling costs
€36-€108 per petrol LDV and €43-€156 per diesel LDV
€1 900-€3 800 per HDV
Total cost up until 2020:
€3.1-€10.7 billion for Euro 6
€5.35-€10.7 billion for Euro VI
Also for suppliers in the form of costs for the development of new
equipment, but partly covered by hardware costs for manufacturers.
Moderate level of confidence due to limited data points and variation
between manufacturers (wide range intended to capture this).
2) Costs during
implementation phase
X X  Testing and witnessing costs for manufacturers and suppliers
Cost of €150-€302 thousand per model family for LDV (moving from
Euro 5 to Euro 6 d)
Cost of €95.7-€232 thousand per engine family for HDV
Total cost up until 2020:
€401-€921 million for Euro 6
€52.5-€128.8 million for Euro VI
27
All estimates for the cost and benefits are based on the Supporting evaluation study (CLOVE, 2022),
which are featured in Annex 5: Evaluation Euro 6/VI emission standards
28
Detailed explanations of the cost typology for manufacturers and supplier can be found in Table 39 in
Annex 5: Evaluation Euro 6/VI emission standards
29
More detailed cost estimates for the regulatory costs for manufacturers can be found in Table 40 in
Annex 5: Evaluation Euro 6/VI emission standards
30
In the Euro 6 Impact Assessment, no estimates were made for petrol cars and vans. It only focused on the
cost of the key technology expected to be needed to comply with the limits (SCR or LNT) and did hence
not cover other aspects such as the costs of sensors and other supporting hardware. In addition, only the
initial stages of Euro 6 (prior to changes in the testing requirements, including RDE testing).
24
Medium level of confidence as a result of the limited data provided and
the different way that manufacturers go about type-approval (grouping of
model/engine families) (broad range reflects this uncertainty).
 Witnessing costs for type-approval authorities
Euro 6 resulted in a medium increase in costs mainly from training and
more demanding testing and witnessing requirements. Expected to be
largely covered by manufacturers.
 Type-approval fees for manufacturers
Total cost up until 2020:
€6-€10 million for Euro 6
The overall fee per type-approval remained small (€0-€1 500). Increase
in total costs for cars and vans realized through an increase in the number
of emission type-approvals. Medium to high level of confidence based on
data on fees charged by 6 authorities and confirmed by manufacturers.
3) Administrative costs X Cost of €16-€52 thousand per LDV type approval (moving from Euro 5
to Euro 6d)
Cost of €17.5-€27.5 thousand per HDV type approval
Total cost up until 2020:
€247-€794 million for Euro 6
€26-€41 million for Euro VI
Medium level of confidence (see explanation witnessing costs)
Total regulatory costs
1)+2)+3)
X X  Total costs for manufacturers and suppliers
Based on the sector market structure, all regulatory costs to industry are
expected to be passed down to consumers.
Total cost up until 2020:
€21.1-€55.6 billion for Euro 6
€9.5-€20.4 billion € for Euro VI
 Total costs for type-approval authorities
Total cost associated with the implementation process (see above).
Expected to be largely covered by manufacturers in the form of
witnessing costs for type-approval.
Indirect costs (prices)
X  Costs for users of vehicles (both citizens and businesses users)
Regulatory costs to industry are expected to be passed down to
consumers in the form of higher vehicle prices.
Cost increase per vehicle in comparison to average vehicle prices:
Increase of 2.7-4.3% for diesel LDV and 0.6-1.2% for petrol LDV (Euro
6d)
Increase of 4.2-5.0% for lorries and 2.1-3.0% for buses
Direct benefits (environmental and health benefits)
Compared to the estimates
of the former Euro 6/VI
impact assessment up until
2020:
Euro 6: 24% savings of
NOx resulting in 60-90%
increase in health benefits.
Euro VI: 37% savings of
NOx and 22% of PM
X High impact through reductions of emissions from a number of regulated
pollutants up to 2020 and even higher level of reduction expected in the
future.
Emission savings up until 2020:
NOx savings: 21.8% for Euro 6 and 35.7% for Euro VI
Exhaust PM10 savings: 28% for Euro 6 and 13.5% for Euro VI
THC savings: 20.5% for Euro 6 and 14% for Euro VI
NMHC savings: 11.9% for Euro 6
Total monetised benefits up until 2020:
For NOx: €28.5 billion for Euro 6 and €65.1 billion for Euro VI
For PM: €2 billion for Euro 6 and €1.4 billion for Euro VI
25
High confidence since calculations are based on best available
information on emission savings, including generally accepted emission
factors and factors to monetise external costs (handbook of external costs
of transport).
2.2 Euro 7 impact assessment
Table 4 – Overview of direct and indirect benefits in the policy options (2025-2050)
I.A Overview of Benefits (total for all provisions for light- and heavy-duty vehicles) – Option 1
Description Amount Comments
Direct benefits
Regulatory costs savings: Testing,
witnessing, type-approval and
administrative costs savings
€3.88 billion  Main recipients of the benefit: Automotive industry and
eventually citizens through reduced vehicle prices
Health and environmental benefits €43.50 billion  Main recipient of the benefit: citizens
Indirect benefits
Consumer trust Low benefit  Main recipient of the benefit: citizens
I.B Overview of Benefits (total for all provisions for light- and heavy-duty vehicles) – Option 2a
Description Amount Comments
Direct benefits
Regulatory costs savings: Testing,
witnessing, type-approval and
administrative costs savings
€3.83 billion  Main recipients of the benefit: Automotive industry and
eventually citizens through reduced vehicle prices
Health and environmental benefits €187.36 billion  Main recipient of the benefit: citizens
Indirect benefits
Competitiveness: Access to
international key markets
Low benefit  Main recipient: automotive industry
Consumer trust Moderate benefit  Main recipient: citizens
I.C Overview of Benefits (total for all provisions for light- and heavy-duty vehicles) – Option 2b
Description Amount Comments
Direct benefits
Regulatory costs savings:
Testing, witnessing, type-
approval and administrative
costs savings
€3.83 billion  Main recipients of the benefit: Automotive industry and
eventually citizens through reduced vehicle prices
Health and environmental
benefits
€199.18 billion  Main recipient of the benefit: citizens
Indirect benefits
Competitiveness: Access to
international key markets
Moderate benefit  Main recipient: automotive industry
26
Competitiveness: Innovation Low benefit  Main recipient: automotive industry
Free movement within the
single market
Low benefit  Main recipient: automotive industry
Consumer trust Moderate benefit  Main recipient: citizens
Employment and skills Low benefit  Main recipient: citizens
I.D Overview of Benefits (total for all provisions for light- and heavy-duty vehicles) – Option 3a
Description Amount Comments
Direct benefits
Regulatory costs savings:
Testing, witnessing, type-
approval and administrative
costs savings
€5.25 billion  Main recipients of the benefit: Automotive industry and
eventually citizens through reduced vehicle prices
Health and environmental
benefits
€189.33 billion  Main recipient of the benefit: citizens
Indirect benefits
Competitiveness: Access to
international key markets
Moderate benefit  Main recipient: automotive industry
Competitiveness: Innovation Moderate benefit  Main recipient: automotive industry
Free movement within the
single market
Low benefit  Main recipient: automotive industry
Consumer trust High benefit  Main recipient: citizens
Employment and skills Low benefit  Main recipient: citizens
Table 5 – Overview of direct and indirect costs in the policy options
II.A Overview of costs for light- and heavy-duty vehicles – Option 1
Billion €
Citizens/Consumers Manufacturers Administrations
One-off Recurrent
(annual)
One-off Recurrent
(annual)
One-off Recurrent
(annual)
Simplification
measures (cost
savings see
above)
Direct costs
(regulatory costs)
0.00 0.00 0.00 -0.15 0.00 0.00
Indirect costs
(prices)
0.00 -0.15 0.00 0.00 0.00 0.00
Technology-
neutral limits
and low
ambition real-
driving testing1
Direct costs
(regulatory costs)
0.00 0.00 3.19 0.23 0.00 0.00
Indirect costs
(prices)
0.00 0.35 0.00 0.00 0.00 0.00
1
It is not possible to detangle costs for low ambition (technology-neutral Euro 6/VI) limits and boundaries, as it is one low-
ambition emission control system.
27
II.B Overview of costs for light- and heavy-duty vehicles – Option 2 (including a and b)
Billion €
Citizens/Consumers Manufacturers Administrations
One-off Recurrent
(annual)
One-off Recurrent
(annual)
One-off Recurrent
(annual)
Simplification
measures (cost
savings see Table
4)
Direct costs
(regulatory costs)
0.00 0.00 0.00 -0.15 0.00 0.00
Indirect costs
(prices)
0.00 -0.15 0.00 0.00 0.00 0.00
Medium
ambition
emission limits,
real driving
testing
boundaries and
durability (2a)2
Direct costs
(regulatory costs)
0.00 0.00 16.30 1.32 0.00 0.00
Indirect costs
(prices)
0.00 1.94 0.00 0.00 0.00 0.00
High ambition
emission limits,
real driving
testing
boundaries and
durability (2b)2
Direct costs
(regulatory costs)
0.00 0.00 16.30 2.96 0.00 0.00
Indirect costs
(prices)
0.00 3.59 0.00 0.00 0.00 0.00
2
It is not possible to detangle costs for medium ambition limits, boundaries and durability, as it is one medium-ambition
emission control system. The same applies to the high-ambition emission control system.
II.C Overview of costs for light- and heavy-duty vehicles – Option 3a
Billion €
Citizens/Consumers Manufacturers Administrations
One-off Recurrent
(annual)
One-off Recurrent
(annual)
One-off Recurrent
(annual)
Simplification
measures (cost
savings see Table
4)
Direct costs
(regulatory costs)
0.00 0.00 0.00 -0.20 0.00 0.00
Indirect costs
(prices)
0.00 -0.20 0.00 0.00 0.00 0.00
Medium
ambition
emission limits,
Direct costs
(regulatory costs)
0.00 0.00 16.30 1.32 0.00 0.00
real driving
testing
boundaries and
durability (2a)3
Indirect costs
(prices)
0.00 1.94 0.00 0.00 0.00 0.00
Continuous
emission
monitoring
Direct costs
(regulatory costs)
0.00 0.00 1.25 0.05 0.00 0.00
Indirect costs
(prices)
0.00 0.09 0.00 0.00 0.00 0.00
3
It is not possible to detangle costs for medium ambition limits, boundaries and durability, as it is one medium-
ambition emission control system.
28
Annex 4: Analytical methods and results
1. DESCRIPTION AND RESULTS OF METHODS AND MODELLING TOOLS
Since the evaluation and impact assessment are carried out in parallel through a “back-to-
back” approach, the methods and modelling have been harmonised to ensure continuity
and consistency. In both cases, models have been important for calculating and
visualizing the future vehicle fleet and the related emission inventories. Cost models
have been applied to calculate all the relevant costs and benefits to support the
assessment of the impacts in Chapter 6 and 7 of the impact assessment.
COPERT is an internationally recognized and widely used tool for calculating
greenhouse gas and air pollutant emission inventories for road transport based on
real-world emissions coordinated by European Environment Agency (EEA) and by the
JRC3132
. The COPERT methodology is part of the EMEP/EEA air pollutant emission
inventory guidebook for the calculation of air pollutant emissions33
and is used by the
large majority of European countries for reporting official emissions data. The tool
uses vehicle population, mileage, speed and other data (e.g. ambient temperature) to
calculate emissions and energy consumption in a specific country or region. In particular,
COPERT develops reliable and widely recognised emission factors that indicate the level
of pollutant emissions released by a polluting activity
SIBYL was used to project the vehicle fleet. SIBYL is a specialised tool for projecting
the impact of detailed vehicle technology on future fleets, energy, emissions and
costs designed to support policy making. It has the ability to project emissions based
on fleet dynamics, expected market trends and forecasted fleet growth scenario up to
2050. Based on these features and by utilising proper emission (see COPERT above) and
consumption factors, SIBYL is able to project emission and energy evolutions from road
vehicles. SIBYL is also the core calculation module of the JRC DIONE34
model. The
latter has a successful record of use in the Commission’s transport, energy and climate
impact assessments, including the CO2 standards for light- and heavy-duty vehicles35
.
In addition and in order to maintain compatibility with other Commission policies and
modelling, the SIBYL baseline was calibrated to the EU reference scenario from the
PRIMES 2020 model36
, the main model used in the Commission’s energy and climate
policy assessments, and more specifically the 2030 climate target plan following the
31
COPERT: The industry standard emissions calculator
32
EEA, 2016. Copert 4
33
EEA, 2019. EMEP/EEA air pollutant emission inventory guidebook
34
JRC, 2017. Light Duty Vehicle CO2 emission reduction cost curves and cost assessment – the DIONE
Model and JRC, 2018. Heavy duty vehicle CO2 emission reduction cost curves and cost assessment –
enhancement of the DIONE model
35
Regulation (EU) 2019/631 CO2 emission performance standards for new passenger cars and for new
light commercial vehicles, Regulation (EU) 2019/1242 CO2 emission performance standards for new
heavy-duty vehicles
36
E3 Modelling, 2020. The core PRIMES model
29
announcement of the Fit-for-55 Commission proposal37
.
In combination with the COPERT, the SIBYL38
vehicle stock, activity and emission
projection tool was used to estimate emission reductions until 2050 and compare them
with the baseline, i.e. the "no policy change" scenario (see chapter 5.1). The SIBYL and
COPERT model were updated with the data collected, latest emission factors that
represent the quantity of a pollutant released to the atmosphere through a polluting
activity and literature reviews in the supporting Euro 7 impact assessment study39
and
synchronised with the PRIMES 2020 vehicle stock and vehicle activity used for the
revision of the CO2 emission performance standards for new passenger cars and for new
light commercial vehicles40
.
There is a close interaction between the models in the assessment. As shown in Figure 8,
the output from SIBYL serves as input for both COPERT and the cost models. That way,
the total emissions and associated technology costs can be calculated to support the
analysis of the effectiveness and efficiency of the Euro 6/VI emission standards and the
assessment of the impacts for a Euro 7 initiative.
In the context of the Euro 6/VI evaluation and Euro 7 impact assessment, the modelling
tools and methods cover:
 The broad vehicle categories, including: cars, vans, lorries and buses and for
each category a number of different segments. No distinction is made for small
volume manufacturers.41
 A broad range of fuel and powertrain vehicle technologies, including: petrol,
diesel, hybrids, LPG/CNG (bi-fuel), plug-in hybrids (PHEV), battery electric, fuel
cell electric vehicle (hydrogen) and flexi-fuel (bioethanol).
 Geography: While the backward-looking evaluation of Euro 6/VI considers the
dataset for the EU-27 countries and the United Kingdom, for the forward-looking
impact assessment of the Euro 7 initiative the EU-27 data file was used for
emission modelling. Hence, the geography of both assessments is limited to the
EU market.42
 Time horizon:
o evaluation of Euro VI: 2013-2050, Euro 6: 2014-2050
37
COM(2020) 562 final, Stepping up Europe’s 2030 climate ambition. Investing in a climate-neutral future
for the benefit of our people
38
SIBYL: Ready to go vehicle fleet, activity, emissions and energy consumption projections for the EU 28
member states
39
CLOVE, 2022. Euro 7 Impact Assessment Study. ISBN 978-92-76-58693-7.
40
SWD(2021) 613 final, Commission Staff Working Document, Impact Assessment, Accompanying the
document Proposal for a Regulation amending Regulation (EU) 2019/631 as regards strengthening the CO2
emission performance standards for new passenger cars and new light commercial vehicles in line with the
Union’s increased climate ambition
41
The contribution of small volume manufacturers (i.e. those with less than 10 000 vehicles produced
worldwide annually) to the overall emissions from road transport is minimal since they only comprise less
than 0.4 percent of total vehicle registrations in Europe each year. Moreover such vehicles travel far less
km (around 3 700 km/year) (ESCA, 2021) than the average cars in Europe. The combined effect on
emissions is therefore much less than 0.4% and can be considered as negligible. Any special provisions for
such manufacturers will thus have negligible effect in the impacts of Euro 7 and are therefore not addressed
in this impact assessment.
42
Since the Euro standards are only applicable to vehicles sold in the EU and not to vehicles produced in
the EU for other markets, exports are not considered in the cost-benefit analysis. Still, the indirect impact
of Euro 7 policy options on competitiveness of EU manufacturers is assessed (see Annex 4 section 1.4.1).
30
o impact assessment Euro 7: 2025-2050
Figure 8 – Interlinkage between SIBYL and COPERT43
1.1. Fleet modelling with SIBYL
The process towards fleet modelling with SIBYL is illustrated in Figure 9. As a first step,
the vehicle stock is balanced with the statistical data by taking into account the new
registered vehicles (including used vehicles) and scrappage44
statistics. Afterwards, the
vehicles are classified in the various Euro emission standards on the basis of a
“technology matrix” that connects the technology of new registrations with the year they
entered into the fleet by taking into account the introduction date of each Euro standard.
The annual mileage is then calibrated to ensure that the energy demand is consistent with
the statistical energy consumption. For the projected years, the stock and mileage are
then calibrated in line with the activity growth described in the EU reference
scenario from the PRIMES 2020 model.
Figure 9 – Process for developing the SIBYL baseline45
43
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.1 Introduction of
COPERT/SIBYL tools
44
Scrappage is the act of offering people money if they get rid of an old vehicle and buy a new one.
45
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.2 Fleet modelling
31
The reliability, quality, completeness and consistency of the SIBYL tool and data are
ensured by the high expertise of the developers in combination with an extensive level of
reviewing and cross-checking. Next to that, the SIBYL fleet data takes into account a)
the Euro 6/VI emission standards, b) the impact of COVID-19 on road transport
activity46
and c) the impact of the new 55% (cars) and 50% (vans) CO2 targets by 2030
and 100% CO2 targets for cars and vans by 203547
and the projected fit-for-55 HDV fleet
evolution to contribute to the 55% net greenhouse gas emission reduction by 2030 and
the 2050 climate neutrality objective48
. Lastly, it has been harmonised with official
statistics from several official EU sources (e.g., Eurostat, European Alternative Fuels
Observatory). Table 6 gives an overview of these official sources and the main
information provided, while also showing other sources used for the SIBYL fleet data. In
the context of the work on the Euro 6/VI evaluation and the Euro 7 impact assessment,
an effort was done to gather additional data directly from the Member States and research
institutes. Bilateral consultations took place which were targeted at acquiring data on
new vehicle registrations. These consultations led to the update of the datasets for a
group of 10 Member States. While not covering all Member States, this group is found to
have a rate of renewal of passenger cars which is close to the EU average.49
Next to that,
other relevant datasets on new registration50
were used for cross-checking.
Table 6 – Overview data sources for the SIBYL fleet modelling, based on CLOVE,
202251
46
Road transport activity is the volume-km driven by vehicles on EU roads and is projected by the
estimated evolution of vehicle sales.
47
A linear interpolation was used for the year 2030 for both the activity and shares of vehicles between the
two existing scenarios in the CO2 Impact Assessment (TL_Med and TL_High), while the TL_High
scenario was used for the year 2035. This approach is the estimated representation of the impact of the
Commission proposal for CO2 targets for cars/vans.
48
For heavy–duty vehicles, the activity and fleet shares of vehicles are based on the SWD(2020) 176 final,
Impact Assessment on Stepping up Europe’s 2030 climate ambition: Investing in a climate-neutral future
for the benefit of our people (part 1) and SWD(2020) 176 final (part 2), supplemented for buses by
CLOVE, 2022.
49
See footnote 45
50
See footnote 129
51
See footnote 45
52
Eurostat, 2021. New registrations of passenger cars by type of motor energy and engine size
53
Publications Office of the EU,2019.”EU transport in figures”
54
EEA, 2020.”Monitoring of CO2 emissions from passenger cars – Regulation (EU) 2019/631”,2020
Source Main information provided
Official EU sources
Eurostat52
Stock and new registrations per fuel and engine
capacity / GVW
EC Statistical Pocketbook53
(EU
Transport in figures)
Stock and new registrations
CO2
monitoring database54
New registrations per fuel and segment (PCs and
LCVs)
32
SIBYL reflects the real situation to the extent possible and contains highly accurate
emissions figures. The dataset of the SIBYL model covers the horizon from 1990 until
2050 and includes all Member States of the EU individually, as well as neighbouring and
candidate countries. Hence, a complete and consistent transport dataset has been created
and harmonised with official national statistics.
However, some issues have been identified with these data sources. None of these
sources provided all the necessary data at the required level of detail and some gaps or
incomplete time series (missing countries/years) were discovered. In addition, the
collected information was sometimes found to be inconsistent with different sources
presenting different values or vehicle classifications. In order to overcome such issues, a
processing methodology has been developed to combine the primary information from
various sources in order to produce total numbers for the vehicle fleet (for each vehicle
category/fuel/segment). The different steps for ensuring that the outcome of the
processing methodology is a complete and consistent dataset is explained in Box 1.
It is important that the SIBYL fleet data takes into account the age distribution of the
fleet. To ensure better modelling of the fleet structure, technologies and the specific Euro
standards per country, the average age of the vehicle category considered in the model
must be consistent with statistical data. Therefore, the methodological steps summarized
in Box 2 have been followed. The outcome of this phase is then an age distributions per
fuel and segment for each vehicle category so that the checking rules in Box 1 are
satisfied for all age bins61
. Once the age distributions have been finalised, vehicles have
been allocated to the different Euro emission standards based on the previously described
technology matrices.
The consistency of the SIBYL fleet data with the national inventory submissions of fuel
55
EAFO,2017.”The transition to a Zero Emission Vehicles fleet for cars in the EU by 2050”,2017
56
ACEA, 2020. Consolidated registrations by country
57
acem, 2021.
58
NGVA Europe, 2021.
59
NGV Global, 2021.
60
UNFCC,2020, “National Inventory Submissions 2020”
61
There are 30 age bins in the dataset: from age 0 (new registrations) to age 29. All stock vehicles are
allocated to these bins, so that the sum of vehicles in all age bins equals to the total number of vehicles.
EAFO55
(European Alternative Fuels
Observatory)
Stock and new registrations of alternative fuels (LPG,
NG, electric, H2
)
Other sources
ACEA56
Stock per fuel, new registrations per fuel and per
segment / GVW
ACEM57
Stock, new registrations per fuel and engine capacity
(L-vehicles)
NGVA Europe58
(Natural Gas Vehicle
Association) / NGV Global59
(Natural
Gas Vehicle Knowledge Base)
Stock of natural gas vehicles
UNFCCC60
Fuel sold, based on Eurostat and disaggregated per
vehicle category
Others: literature, studies, reports,
national statistics web sites
Various information (level of detail is country-
dependent)
33
consumption data was checked for the different vehicle categories through the UNFCC62
.
Subsequently, micro-adjustments have been made in the mileage of the vehicles in order
to match the calculated fuel consumption with the statistical one.
Box 1 – Data processing methodology for SIBYL fleet data63
 Comparison of the source – one data source is selected as the main source (based on data quantity and
quality).
 Gap-filling based on other sources taking into account possible inconsistencies. For example, in case
of significant differences between two sources, the relative trend is considered instead of the absolute
value.
 If gaps remain, these are filled in based on: 1) Interpolation, 2) Relative trend or data from another
country (e.g. percentages for split/disaggregation), 3) Estimates and expert judgement calculations.
 As a last step, some checks are performed based on the following questions (i.e. checking rules):
o Do all fuels add up to the total?
o Do all segments of a fuel add up to this specific fuel?
o Are there no negative values?
o Do all percentages add up to 100%?
Box 2 – Methodological steps for determining the fleet’s age distribution64
 An estimate was made for the age distribution in 1990 based on the new registrations of this year and
expert judgement.
 The age distribution for the following years have been derived using lifetime functions, which model
the ages at which vehicles are deregistered from the fleet.
 Then, modifications were made in the age distribution, by internal “transferring” of vehicles among
age groups to ensure coherence with the statistical average age data (from the different sources in
Table 6).
 This results in an age distribution for the total stock which has been used as a guide to produce age
distributions per fuel and segment, taking into account the characteristics of individual vehicle
subcategories. For example:
o Many LPG vehicles are conversions from petrol vehicles, not actual sales.
o The age distribution for electric vehicles is expected to be completely different compared to
conventional vehicles, as the former only entered the fleet recently.
o Differentiations in the age distribution for petrol and diesel vehicles which has been driven by past
sales patterns. That way, the petrol fleet is currently older than the diesel fleet.
1.2. Emissions modelling with COPERT
1.2.1. Emission factors
To calculate the environmental benefits in both the Euro 6/VI evaluation and Euro 7
impact assessment, the total annual emissions have to be analysed. The general scheme
for calculating the emissions of a pollutant for a specific vehicle category and year is
presented in the equation below.
Equation 165 Ep,j,x = Nj,x × Mj,x × EFp,j,x
62
See footnote 60
63
See footnote 45
64
See footnote 45
65
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.4.1 Emissions modelling:
overall methodological approach
34
Where
 E = total annual emissions
 N = number of vehicles in operation
 M = annual mileage per vehicle
 EF = estimated emission factor in g/km
 p = air pollutant or greenhouse gas
 j = vehicle category
 x = year of calculation
While the first two elements of the calculation (i.e. N and M) are a direct output from the
SIBYL fleet modelling discussed in the previous chapter, the sources for finding the
emission factors (EFp,j,x) differs for the Euro standard vehicle technologies. The
evaluation, which considers the different steps of Euro 6 and Euro VI, could mostly rely
on the COPERT model for determining the emission factors. However, for the latest
steps in Euro 6 – Euro 6d-temp and Euro 6d – other sources were consulted.66
Also for
the policy options in the impact assessment, different emission factor sources had to be
considered in the supporting impact assessment study67
to take into account future
technologies and assess their environmental impact which were included in the last
version of the COPERT model v5.4. The first update includes the revision of emission
factors for Euro 5 vehicles in order to be in line with the latest information on defeat
devices. This revision is expected to influence the current emissions benefits of Euro 6
over Euro 5 and was performed after screening with the Handbook Emission Factors for
Road Transport (HBEFA 4.1)68
. This handbook was originally developed on behalf of
the Environmental Protection Agencies of Germany, Switzerland and Austria. Over the
years, further countries as well as the JRC are supporting the HBEFA. The handbook
provides emission factors for all current vehicle categories for a wide variety of traffic
situations, while covering all regulated and the most important non-regulated
pollutants.69
Moreover, the emission factors for all Euro 5 - V and Euro 6 a/b/c - VI A/B/C
technologies were re-calculated in order to take into account the effect of driving
conditions outside the current RDE boundaries, including the effect of cold-start, the
operation under hot conditions, the degradation of emission control systems due to high
mileage or age, as well as the impact of tampering and malfunctions not detected by
OBD.
For cars and vans using the latest technology (Euro 6d-temp and Euro 6d), an emission
performance analysis has been conducted. In order to assess the emission levels of these
vehicles and to support the update of the existing databases for emission factors,
emission data from more than 500 tests from a pool of 45 vehicles were collected and
analysed. Data sources from nine partners have been consulted, including CLOVE, JRC,
H2020 projects and stakeholders. That way, these detailed data could be used over the
other models (COPERT, HBEFA and VERSIT70
) to achieve a higher accuracy for the
66
CLOVE, 2022. Euro 6/VI Evaluation Study. Annexes 1:6 ISBN 978-92-76-56522-2, Chapter 9.3 Annex
3: Euro 6/VI SIBYL/COPERT model data
67
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.4.2 Emission Factors (EFs)
calculation/modelling
68
Handbook emission factors for road transport (HBEFA), 2020.
69
See footnote 68
70
TNO, 2007. VERSIT+ state-of-the art road traffic emission model.
35
emission factors. For lorries and buses, input on the emission factors of Euro VI D/E
vehicles was derived from HBEFA, while experimental data provided by CLOVE were
used for calculating emission factors under test conditions not covered by HBEFA (e.g.
in terms of trip characteristics or composition).71
When it came to emission factors for future technologies following future possible
legislation, the current models fell somewhat short. Therefore, scenarios were created for
the policy options, resulting in corresponding estimated emission factors.
In general, emission factors of the various pollutants for each vehicle category depend on
many parameters, including driving patterns, environmental conditions, road gradient and
the level of maintenance of the vehicle (e.g. cold versus hot temperatures, evaporation,
degradation, tampering, malfunction etc.). To control for this, components or emission
processes related to such parameters and their individual effects on vehicle emissions are
considered separately to estimate the impact of the different policy options. That way,
only relevant parts of the emission factor will be affected when a new policy action is
introduced in the simulations. For example, if new requirements on On-Board
Diagnostics (OBD) were to be introduced, only the component on malfunctions will be
affected and not the base emission factor.
This is summarized in the following equation, which represents the general scheme for
calculating emissions factors.
Equation 272
EF = [(w1 EFhotRDE + w2 EFhotNonRDE) × DF(M) + w1 EFcoldRDE + w2 EFcoldNonRDE] × (1 –
Tamp.share) + (w1 EFhotRDE + w2 EFhotNonRDE) × (Tamp.share) × (Tamp.rate)
Where:
 w1: fraction of mileage to RDE conditions
 w2: fraction of mileage to non RDE conditions (w2 = 1 - w1)
 hotRDE: hot mean emission level over RDE driving
 hotNonRDE: hot mean emission level outside of RDE (incl. AES)
 coldRDE: cold mean emission level over RDE driving
 coldNonRDE: cold mean emission level over RDE driving
 DF(M): deterioration factor of emission at mean fleet mileage (M)
 Tamp.share : % of tampered vehicles
 Tamp.rate: tampering emission rate (tampered/ok)
The above equation decomposes the final emission factor into the various components
that are meaningful for the purpose of the impact assessment on the different policy
options. Every term in Equation 2 is calculated in a separate modeling activity based on
the available data (more information on these separate modeling activities can be found
in the supporting impact assessment study Annex 1)73
.
The emission factors for each pollutant considered in the Euro 6/VI evaluation are
presented in Table 7.
71
See footnote 65; and CLOVE, 2022. Technical studies for the development of Euro 7. Testing,
Pollutants and Emission Limits. ISBN 978-92-76-56406-5.
72
See footnote 65
73
See footnote 65
36
Table 7 – Emission factors for the different pollutants used in the evaluation baseline and
under the different steps of Euro 6/VI74
(Average ± standard deviation, mg/km)
Diesel cars and vans Petrol cars and vans
Euro 5 Euro 6
a-c
Euro 6d-
temp
Euro
6d
Euro 5 Euro 6
a-c
Euro 6d-
Temp
Euro
6d
NOx 1 204.37 ±
88.78
656.65 ±
95.40
148.14 ±
14.10
127.57
± 2.35
58.11 ±
1.34
43.11 ±
1.41
22.92 ±
1.55
20.66
± 0.20
PMtotal 26.98 ±
2.30
23.34 ±
2.46
23.00 ±
2.20
21.50 ±
0.68
21.38 ±
2.09
20.37 ±
2.15
19.34 ±
2.21
18.84
± 0.03
PMexhaust
4.88 ± 0.00
1.17 ±
0.10
0.45 ±
0.00
0.43 ±
0.01
2.37 ±
0.02
1.40 ±
0.06
0.34 ±
0.00
0.32 ±
0.01
CO
82.03 ±
5.22
74.75 ±
15.76
77.31 ±
13.47
61.15 ±
4.84
2 949.56
± 204.73
1. 55.45
± 79.61
582.26 ±
59.93
513.24
±
15.85
THC
20.70 ±
0.00
19.21 ±
4.16
20.18 ±
3.71
16.20 ±
1.86
1 714.87
±
2.897.72
1 667.61
±
2.956.09
781.70 ±
1.440.61
96.11
± 4.24
NMHC
2.61 ± 0.00
2.37 ±
0.42
2.47 ±
0.37
2.06 ±
0.18
1 694.22
±
2 897.11
1 648.51
±
2 956.23
777.30 ±
1 440.45
91.23
± 3.92
Lorries and buses
Euro V Euro VI
NOx 9 090.69 ± 170.38 2 014.95 ± 407.06
PMtotal 124.28 ± 1.97 92.63 ± 11.48
PMexhaust 65.47 ± 1.10 33.78 ± 9.34
CO 2 761.01 ± 45.71 224.00 ± 129.11
THC 61.18 ± 0.97 32.39 ± 7.54
NMHC 60.06 ± 0.95 31.75 ± 7.41
NH3 12.49 ± 0.24 22.35 ± 1.18
CH4 1.13 ± 0.02 0.63 ± 0.14
Table 8 presents the four sets of emission factors which are used in the impact
assessment baseline to calculate the emission savings. This set of conservative emission
factors reflects the limitation of available measurement data and a worsening of today’s
measured emission levels in the future75
:
 Current data mostly contains results from vehicles of the higher segments that often
contain expensive emission control systems. It has been shown that vehicles at lower
segments are generally not equipped with such sophisticated systems thus exhibiting
higher emissions over certain operation conditions.
 Current data is still limited and shows a significant range76
. Maximum values should
be taken into account by manufacturers to demonstrate compliance with emission
limits.
 The trade-offs between CO2 and air pollutants (primarily NOx) could potentially push
vehicle manufacturers to relax NOx control to benefit CO2 to reach the new and more
74
See footnote 190
75
Supporting Euro 7 impact assessment study, chapter 4.1 Baseline development without introduction of a
new emission standard
76
For example, the 33 RDE compliant tests of Euro 6d diesel cars by JRC, TNO and GreenNCAP
comprise 26 diesel cars without diesel particulate filter (DPF) regeneration with in average 33 mg NOx/km
(7-116 mg NOx/km) and 7 diesel cars with DPF regeneration with in average 58 mg NOx/km (18-136 mg
NOx/km).
37
ambitious CO2 emission standards. This is a behaviour observed in the past with each
new emission standard. Example is the recent increase in PN emissions from port-
fuel injection gasoline vehicles with the introduction of Euro 6 PN limit which did
not apply for these vehicles in order to better control other regulated emissions.
 As manufacturers gain experience in calibration and optimisation of the emission
control system while also improvements in the measuring techniques are made, this
can enable a decrease in the margin of safety over the limit value.
All these factors may contribute to higher real-world emission levels and an increase in
the real-world average emission levels of new registrations with time. Since such a trend
is not uncommon and has been observed in the past, this approach of conservative Euro
6/VI emission factors was taken.77
Table 8 – Average emission factors (EF) for the different pollutants under the impact
assessment baseline78
A) Cars and vans – Euro 6d (-temp) (in mg/km or #/km for PN10)
NOx CO PM PN10 THC CH4 NH3 N2O
Hot EFs for RDE driving
Petrol 10.2 186.6 0.160 7.6E+11 5.1 2.4 11.3 0.3
Diesel 33.1 31.6 0.150 3.3E+10 12.8 11.5 0.3 12.4
CNG 10.2 186.6 0.080 3.5E+11 37.7 20.8 11.3 0.3
Hot EFs for outside RDE driving
Petrol 22.1 1202.6 0.450 1.1E+12 5.1 2.4 11.3 0.3
Diesel 190.9 43.4 0.375 1.4E+11 12.8 11.5 0.3 12.4
CNG 22.1 1202.6 0.225 7.0E+11 37.7 20.8 11.3 0.3
Excess Cold EFs for RDE driving
Petrol 5.0 75.0 0.090 2.8E+11 17.1 1.2 1.2 0.5
Diesel 12.5 17.2 0.120 1.3E+10 0.6 0.1 0.0 0.6
CNG 5.0 75.0 0.045 2.0E+11 17.5 9.3 1.2 0.5
Excess Cold EFs for outside RDE driving
Petrol 21.2 250.8 0.170 5.9E+11 17.1 1.2 1.2 0.5
Diesel 54.4 19.5 0.310 9.6E+09 0.6 0.1 0.0 0.6
CNG 21.2 250.8 0.085 1.9E+11 17.5 9.3 1.2 0.5
77
For example, the first set of emission factors for Euro 6a/b vehicles developed by the ERMES group was
based on vehicles of higher segments and was actually lower than subsequent revisions which also used
data from lower segments. See also Keller, M. 2013. HBEFA Status Report ERMES Meeting Sept. 2013.
78
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.4 Emissions modelling
38
B) Lorries and buses – Euro VI D/E (in g/kWh or #/kWh for PN)
EF
HDV
type
Driving
mode
NOx PM PN THC NH3 N2O CH4 CO
Hot
RDE
Long
haul
lorries
Urban hot 0.377 0.0087 9.01E+10 0.0148 0.015 0.235 0.00038 0.060
Rural 0.128 0.0042 4.12E+10 0.0083 0.012 0.160 0.00016 0.035
Motorway 0.021 0.0036 4.05E+10 0.0073 0.012 0.128 0.00015 0.028
Rigid
lorries
Urban hot 0.377 0.0087 9.01E+10 0.0148 0.015 0.235 0.00038 0.060
Rural 0.128 0.0042 4.12E+10 0.0083 0.012 0.160 0.00016 0.035
Motorway 0.021 0.0036 4.05E+10 0.0073 0.012 0.128 0.00015 0.028
Urban
buses
Urban hot 0.377 0.0087 9.01E+10 0.0148 0.015 0.235 0.00038 0.060
Rural 0.128 0.0042 4.12E+10 0.0083 0.012 0.160 0.00016 0.035
Motorway 0.021 0.0036 4.05E+10 0.0073 0.012 0.128 0.00015 0.028
Hot
outside
RDE
Long
haul
lorries
-
8.20 0.0137 1.41E+11 0.0551 0.015 0.051 0.00144 0.216
Rigid
lorries
-
8.20 0.0137 1.41E+11 0.0551 0.015 0.051 0.00144 0.216
Urban
buses
-
8.20 0.0137 1.41E+11 0.0551 0.015 0.051 0.00144 0.216
Excess
Cold
start
Long
haul
lorries
-
12 0.1 6.00E+11 0.25 0.012 5.25 0.013 1.85
Rigid
lorries
-
6.36 0.027 3.18E+11 0.1326 0.006 2.78 0.007 0.980
Urban
buses
-
8.73 0.036 4.36E+11 0.1818 0.009 3.82 0.009 1.34
C) Brake emissions (in mg/km)
Vehicle category PM2,5 from brakes PM10 from brakes
Cars 4.37 11
Vans 7.71 19.4
Lorries 11.3 - 11.8 28.5 - 29.5
Buses 11.1 - 19.7 27.9 - 49.6
The emission factors for the different policy options are presented in Table 9. It is
important to note that the emission levels in PO2a/PO3a and PO2b are extremely low and
only differ with regard to the excess cold emission factors, while the hot emission factors
are assumed to be the same leading to overall small emission levels in PO2a/PO3a and
PO2b.
39
Table 9 -Average emission factors for the different pollutants in the policy options79
A) Cars and vans (in mg/km or #/km for PN10)
Policy
option
(PO)
Fuel NOx CO PM PN10 THC CH4 NH3 N2O
Hot EFs for RDE driving
PO1
Petrol 10.2 186.6 0.160 7.6E+11 5.1 2.4 11.3 0.3
Diesel 33.1 31.6 0.150 3.3E+10 12.8 11.5 0.3 12.4
CNG 10.2 186.6 0.080 3.5E+11 37.7 20.8 11.3 0.3
PO2a.
PO3a
Petrol 1.6 33.9 0.151 9.6E+09 0.3 2.4 5.3 0.3
Diesel 3.0 31.6 0.135 1.1E+10 6.5 5.2 0.3 12.4
CNG 1.6 33.9 0.076 3.8E+10 0.3 20.8 5.3 0.3
PO2b
Petrol 1.6 33.9 0.151 9.6E+09 0.3 2.4 5.3 0.3
Diesel 3.0 31.6 0.135 1.1E+10 6.5 5.2 0.3 6.6
CNG 1.6 33.9 0.076 3.8E+10 0.3 20.8 5.3 0.3
Hot EFs for outside RDE driving
PO1
Petrol 22.1 1.203 0.450 1.1E+12 5.1 2.4 11.3 0.3
Diesel 100.5 43.4 0.375 1.4E+11 12.8 11.5 0.3 12.4
CNG 22.1 1203 0.225 7.0E+11 37.7 20.8 11.3 0.3
PO2a.
PO3a
Petrol 4.2 114.9 0.435 3.4E+10 0.8 2.4 5.6 0.3
Diesel 10.0 43.4 0.314 6.3E+10 6.5 5.2 0.3 12.4
CNG 4.2 114.9 0.217 1.4E+11 0.8 20.8 5.6 0.3
PO2b
Petrol 4.2 114.9 0.435 3.3E+10 0.8 2.4 5.6 0.3
Diesel 10.0 43.4 0.314 6.3E+10 6.5 5.2 0.3 6.6
CNG 4.2 114.9 0.217 1.3E+11 0.8 20.8 5.6 0.3
79
See footnote 78
40
PO Fuel NOx CO PM PN10 THC CH4 NH3 N2O
Excess Cold EFs for RDE driving
PO1
Petrol 5.0 75.0 0.090 2.8E+11 17.1 1.2 1.2 0.5
Diesel 12.5 17.2 0.120 1.3E+10 0.6 0.1 0.0 0.6
CNG 5.0 75.0 0.045 2.0E+11 17.5 9.3 1.2 0.5
PO2a.
PO3a
Petrol 4.5 73.3 0.089 3.7E+10 10.1 1.2 0.6 0.5
Diesel 3.0 17.2 0.115 4.5E+09 0.2 0.1 0.0 0.6
CNG 4.5 73.3 0.044 1.5E+11 10.1 9.3 0.6 0.5
PO2b
Petrol 3.3 59.0 0.089 3.7E+10 6.8 1.2 0.6 0.5
Diesel 2.4 17.2 0.115 4.5E+09 0.2 0.1 0.0 0.4
CNG 3.3 59.0 0.044 1.5E+11 6.8 9.3 0.6 0.5
Excess Cold EFs for outside RDE driving
PO1
Petrol 21.2 250.8 0.170 5.9E+11 17.1 1.2 1.2 0.5
Diesel 35.1 19.5 0.310 9.6E+09 0.6 0.1 0.0 0.6
CNG 21.2 250.8 0.085 1.9E+11 17.5 9.3 1.2 0.5
PO2a.
PO3a
Petrol 21.2 105.1 0.170 6.3E+10 17.1 1.2 0.6 0.5
Diesel 12.9 19.5 0.306 4.4E+09 0.6 0.1 0.0 0.6
CNG 21.2 105.1 0.085 1.9E+11 17.5 9.3 0.6 0.5
PO2b
Petrol 21.2 90.8 0.170 5.8E+10 17.1 1.2 0.6 0.5
Diesel 10.2 19.5 0.306 4.4E+09 0.6 0.1 0.0 0.4
CNG 21.2 90.8 0.085 1.9E+11 17.5 9.3 0.6 0.5
B) Lorries and buses (in g/kWh or #/kWh for PN)
PO
Driving
mode
NOx PM PN THC NH3 N2O CH4 CO
Hot EFs for RDE driving
PO1
Urban hot 0.377 0.0087 9.01E+10 0.0148 0.015 0.235 0.00038 0.060
Rural 0.128 0.0042 4.12E+10 0.0083 0.012 0.160 0.00016 0.035
Motorway 0.021 0.0036 4.05E+10 0.0073 0.012 0.128 0.00015 0.028
PO2a.
PO3a
Urban hot 0.009 0.0028 2.88E+10 0.0019 0.005 0.082 0.00038 0.018
Rural 0.007 0.0013 1.32E+10 0.0010 0.004 0.056 0.00016 0.010
Motorway 0.005 0.0012 1.30E+10 0.0009 0.004 0.045 0.00015 0.008
PO2b
Urban hot 0.009 0.0028 2.88E+10 0.0026 0.005 0.082 0.00038 0.018
Rural 0.007 0.0013 1.32E+10 0.0014 0.004 0.056 0.00016 0.010
Motorway 0.005 0.0012 1.30E+10 0.0013 0.004 0.045 0.00015 0.008
Hot EFs for outside RDE driving
PO1 8.20 0.0137 1.41E+11 0.0551 0.015 0.051 0.0014 0.216
PO2a. PO3a 0.178 0.0035 3.63E+10 0.0046 0.005 0.018 0.0010 0.068
PO2b 0.124 0.0035 3.63E+10 0.0058 0.005 0.018 0.0009 0.060
41
PO HDV NOx PM PN THC NH3 N2O CH4 CO
Excess Cold EFs for inside and outside RDE driving
PO1
Long haul
lorries
12 0.050 6.00E+11 0.250 0.012 5.25 0.013 1.85
Rigid lorries 6.36 0.0265 3.18E+11 0.1326 0.006 2.784 0.0066 0.980
Urban buses 8.73 0.0364 4.36E+11 0.1818 0.009 3.818 0.0091 1.344
PO2a.
PO3a
Long haul
lorries
2.38 0.002 2.40E+10 1.182 0 0.693 0.330 25.23
Rigid lorries 1.26 0.0011 1.27E+10 0.6266 0 0.368 0.175 13.38
Urban buses 1.73 0.0015 1.75E+10 0.8593 0.0 0.504 0.240 18.35
PO2b
Long haul
lorries
0.853 0.002 2.40E+10 0.615 0 0.693 0.285 12.53
Rigid lorries 0.452 0.0011 1.27E+10 0.3260 0 0.368 0.151 6.64
Urban buses 0.620 0.0015 1.75E+10 0.4471 0.0 0.504 0.208 9.11
C) Brake emissions (in mg/km)
PO Vehicle category PM2,5 from brakes PM10 from brakes
PO1
Cars 4.37 11
Vans 7.71 19.4
Lorries 11.3 - 11.8 28.5 - 29.5
Buses 11.1 - 19.7 27.9 - 49.6
PO2a,
PO3a
Cars 2.8 7.0
Vans 4.9 12.3
Lorries 11.3 - 11.8 28.5 - 29.5
Buses 11.1 - 19.7 27.9 - 49.6
PO2b
Cars 2.0 5.0
Vans 3.5 8.8
Lorries 11.3 - 11.8 28.5 - 29.5
Buses 11.1 - 19.7 27.9 - 49.6
1.2.2. Damage costs
Based on the emissions factors, the environmental benefits in the form of emissions
savings can be calculated as an accumulated difference over the baseline over time. Since
emission savings are a form of prevented pollution which could have negative effects on
human health and environment, these savings create a benefit when expressed in
monetised terms. This monetised health and environmental benefit (in €) has been
calculated by multiplying the emission savings with the external damage costs per tonne
of pollutant for each examined pollutant based on the handbook on the external costs of
transport80
(hereafter “the Handbook”). While the Handbook includes 2016 values, the
Euro 6/VI evaluation and Euro 7 impact assessment are based on 2020 values by taking
into account the annual inflation in the Member States.81
The final damage costs were
calculated as the weighted average of the Member States’ damage costs over the activity
of each Member State. Box 3 summarises the four types of impacts caused by road
transport emissions resulting in damage costs according to Annex C.2 of the Handbook82
.
Box 3 – Impacts by air pollutants from road transport emissions based on the handbook
80
European Commission, 2019. Handbook on the external costs of transport
81
Eurostat, 2021. HICP – monthly data
82
See footnote 80
42
on the external costs of transport (2019)8384
 Health effects: The inhalation of air pollutants - such as particles and NOx - leads to a higher risk of
respiratory diseases (e.g. bronchitis, asthma, lung cancer) and cardiovascular diseases. These negative
health effects lead to medical treatment costs, production loss at work (due to illness) and even to
death.
 Crop losses: As a secondary air pollutant, primarily caused by the emissions of NOx and VOC,
ozone together with other acidic air pollutants (e.g. NOx) can damage the agricultural crops.
Therefore, higher concentrations of these pollutants can result in a lower crop yield.
 Material and building damage: Emissions of air pollutants can damage buildings and other
materials through two different mechanisms: a) Pollution of building surfaces through particles and
dust; b) Damage of building facades and materials due to corrosion processes caused by acidic
substances (e.g. NOx).
 Biodiversity loss: Air pollution can lead to damage of ecosystems. The acidification of soil,
precipitation and water and the eutrophication of ecosystems are of most concern in this context. Such
damages at ecosystems can lead to a decrease in biodiversity (fauna, flora).
The steps for the calculation of the damage costs are illustrated in Figure 10. This
diagram shows how transport emissions85
are released in the atmosphere of other regions
increasing these respective concentrations. Subsequently, this leads to changes in
‘endpoints’ relevant to human welfare. These changes can be monetarily valued by
quantifying the amount of damage caused at the endpoints.
While Box 3 illustrated that vehicle emissions result in damage to a variety of endpoints
through different interactions or midpoints, Figure 11 reflects the relationship between
intervention, midpoints, endpoints and values as reported in the Environmental Prices
Handbook86
. An intervention would have an effect on certain environmental themes –
midpoints – which would have an impact on the third level of the scheme: the endpoint
representing the broader topics discussed in Box 3. The impact of the intervention at the
endpoints is then represented by the impacts at each endpoint, calculated as damage
costs.
Figure 10 – Calculation of damage costs87
83
See footnote 80
84
Since damage costs of N2O and CH4 as air pollutant are not available, damage costs of N2O and CH4
are monetised as greenhouse gases. The Handbook monetises climate change costs from road transport as
the costs associated with all of the effects of global warming, such as sea level rise, biodiversity loss, water
management issues, more and more frequent weather extremes and crop failures.
85
In this diagram, emissions refer to air pollutants, and not to emissions to soils or water occurred by tyre
wear. As it is not yet feasible to develop limits or tests for tyre emissions, it is suggested to include a
review clause in Euro 7.
86
S. de Bruyn, M. Bijleveld, L. et al., 2018. Environmental Prices Handbook: EU-28 version (CE Delft)
87
See footnote 80
43
Figure 11 - Relationships between interventions, midpoints, endpoints and valuation of
environmental policies88
In order to estimate the damage costs per vehicle-kilometre (vkm) activity for different
vehicle categories, the Handbook uses the emission data from the COPERT model. Costs
are calculated to monetise the health and environmental impacts while taking into
account concentration-response functions, population size and structure, population
density, the relationship factors between damage and emissions for various emission
scenarios and the most recent valuation of human health. Table 10 gives an overview of
the damage costs for the pollutants that were considered in the monetisation scheme
based on the respective area where the vehicle activity took place. The Handbook,
however, does not cover the contribution of harmful NMHC (i.e. NMVOC) emissions to
the formation of secondary organic aerosols.89
Hence, information on the damage costs
related to this phenomenon have been collected from other sources.9091
In addition, the
damage costs are classified based on the area where a vehicle activity is considered to
take place. In the calculation for the cost-benefit analysis, the activity was obtained from
COPERT.
88
See footnote 86
89
While the damage costs for CH4 and N2O are considered through their global warming potential later in
the text, CO and THC are not taken into account as no damage costs information is available in the
Handbook for these pollutants.
90
Such as: Lu Q., Zhao Y., Robinson A.L., 2018. “Comprehensive organic emission profiles for gasoline,
diesel, and gas-turbine engines including intermediate and semi-volatile organic compound emissions”;
and He Y., et al., 2020. “Secondary organic aerosol formation from evaporated biofuels: comparison to
gasoline and correction for vapor wall losses”.
91
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.4.5 Emission benefits
44
Table 10 - Damage costs for air pollutants for transport92
Pollutant NOx NH3 NMHC PM2.5 (both exhaust and
non-exhaust)
Area City Rural
All
areas
Metro-
politan*
City Rural** Metro-
politan*
City Rural**
Damage
cost [€/kg]
24.5 14.5 19.5 3.41 2.06 1.78 401 132 76
*
Only for cities/agglomeration with > 0.5 million inhabitants **
Outside cities
In order to perform the Cost-Benefit Analysis (see Chapter 1.3.), the described benefits
were transformed into monetary values. The respective calculation takes into account the
weighted averages of the activity shares of the different vehicle categories, weighted over
the activity (in km/year) of the different categories and taking into account fleet
composition data, in order to split the emissions based on the vehicle activity in urban,
rural and highway traffic conditions, as included in COPERT. As an example, the
equation for calculating the monetary benefits for NOx is presented below. Similar
equations were established for calculating monetary benefits from NH3, NMHC and
PM2,5 are included in the supporting impact assessment study.93
The total monetised
benefit are then calculated as the sum of all the pollutant-specific monetised benefits.
In line with the WHO approach on health impacts from pollution94
and the Handbook on
the external costs of transport, the benefits of reducing emissions are independent of the
absolute emission levels. This means that health benefits of decreasing NOx emission by
1 ton is the same regardless of whether the concentration of the pollutant is low or high.
The exposure of citizens to these concentrations, however, is of great importance.
Therefore, Table 10 separates damage costs in metropolitan areas, urban areas and rural
areas transport. Hence, emission reductions in a metropolitan area this will lead to larger
health benefits than if this is decreased by the same amount in a rural area. This follows
from the fact that more people will be affected in the dense metropolitan environment
compared to the sparsely populated rural environment.
Equation 395
𝑁𝑂𝑥[€] = 𝑁𝑂𝑥[𝑡] ∗ (𝑁𝑂𝑥, 𝑐𝑖𝑡𝑦[€ 𝑡
⁄ ] ∗ 𝑠ℎ𝑎𝑟𝑒𝑢𝑟𝑏𝑎𝑛[%] + 𝑁𝑂𝑥, 𝑟𝑢𝑟𝑎𝑙 ∗ [€ 𝑡
⁄ ](𝑠ℎ𝑎𝑟𝑒𝑟𝑢𝑟𝑎𝑙[%] + 𝑠ℎ𝑎𝑟𝑒ℎ𝑖𝑔ℎ𝑤𝑎𝑦[%]))
Where:
 𝑁𝑂𝑥[€] indicates the resulting monetized benefits
 𝑁𝑂𝑥[𝑡] indicates the emission saving calculated from COPERT
 𝑁𝑂𝑥, 𝑐𝑖𝑡𝑦[€ 𝑡
⁄ ] indicate the damage/avoidance costs presented in Table 10
 𝑠ℎ𝑎𝑟𝑒𝑢𝑟𝑏𝑎𝑛/𝑟𝑢𝑟𝑎𝑙/ℎ𝑖𝑔ℎ𝑤𝑎𝑦 expressed in [%] indicate the respective vehicle activity
obtained from the COPERT
92
See footnote 68
93
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.4.6 Calculation of
monetised benefits
94
WHO, 2013. Health risks of air pollution in Europe – HRAPIE project
95
See footnote 93
45
1.2.3. Environmental impacts
1.2.3.1. Environmental impacts in policy option 1
The environmental impacts in terms of air pollutant emission reductions from road
transport are the emission savings that would be achieved over the savings expected in
the baseline with merely Euro 6/VI vehicle fleet renewal in combination with the impact
of the new CO2 standards.
As shown in Table 11, the overall emission savings that can be expected in policy option
1 are rather limited. Reason for this being that next to the introduction of low ambition
extended real-driving conditions covering conditions outside the current RDE or PEMS
boundaries and improved OBD to enable more effective ISC and MaS over the lifetime
of vehicles, the emission limits are not really reduced, but only made technology-neutral.
For cars and vans, NOx emissions are expected to further decrease compared to the
baseline by 13% in 2030 to 55% in 2050. This decrease follows from the introduction of
extended real-driving testing covering conditions outside the current RDE boundaries
and a technology-neutral NOx emission limit of 60 mg/km for cars, which replaces the
current diverging NOx limits in the Euro 6 standard of 60 mg/km for petrol cars and 80
mg/km for diesel cars.
Some savings can be expected for particles, NH3 and CO emissions from cars and vans
compared to the baseline. PM2,5,exhaust emissions are expected to decrease by 4% in 2030
to 29% in 2050, due to the increased use of improved particle filters and shift to electric
vehicles, whereas PM2,5,total is not expected to decrease as option 1 does not include limits
for unregulated brake and tyre emissions. PN emissions are expected to decrease by 5%
in 2030 to 30% in 2050 due to the extension of the threshold for particle numbers from
23 nm to 10 nm. NH3 emissions from cars and vans are expected to decrease by 7% in
2030 to 47% in 2050 due to the technology-neutral use of a NH3 limit for all vehicle
categories. CO emissions from cars and vans are expected to decrease to a lesser extent.
These emissions are expected to decrease by 3% in 2030 and by 12% in 2050 following
the introduction of a technology-neutral CO limit for cars and vans. It seems that to
optimise performance and to protect emission control components against high exhaust
temperatures, engines may be shifted to rich fuel operation when outside of the current
RDE conditions. Such fuel-rich conditions are known to produce high CO emissions in
the engine.96
For lorries and buses, NOx emission savings are the only emission savings expected in
policy option 1. No new emission limits are considered for these vehicles, as the Euro VI
limits are already technology-neutral. The decreases in NOx emissions, 7% in 2030 to
19% in 2050, derive from enhanced real-driving testing covering conditions outside the
current PEMS boundaries and assumed increased frequency of ISC and MaS testing.97
96
Supporting Euro 7 impact assessment study, chapter 5.1.1. Environmental impacts
97
See footnote 96
46
Table 11 – Emission savings for regulated pollutants from road transport in policy option
1 compared to the baseline98
Pollutant 2025 2030 2035 2040 2045 2050
Cars and vans
NOx in kt 17.79 87.9 104.10 80.60 44.56 15.80
in % 1.72 13.40 26.73 39.04 49.11 55.17
PM2.5,
total
in kt 0.04 0.17 0.19 0.14 0.07 0.02
in % 0.08 0.51 0.80 0.99 1.14 1.20
PM2.5,
exhaust
in kt 0.04 0.17 0.19 0.14 0.07 0.02
in % 0.29 4.31 12.80 20.54 25.72 28.78
PN10 in # 5.77E+22 2.69E+23 2.92E+23 2.04E+23 9.95E+22 3.22E+22
in % 0.32 5.06 15.18 22.54 26.97 30.33
CO in kt 5.64 28.30 34.06 26.36 13.86 4.72
in % 0.37 2.94 5.83 8.49 10.79 12.35
THC in kt 0.09 0.45 0.54 0.43 0.24 0.08
in % 0.03 0.21 0.37 0.49 0.50 0.42
NMHC in kt 0.04 0.19 0.22 0.16 0.08 0.03
in % 0.02 0.11 0.18 0.22 0.20 0.15
NH3 in kt 0.03 1.92 5.13 5.34 2.93 0.98
in % 0.12 7.32 21.49 33.36 41.22 46.61
CH4 in kt 0.05 0.25 0.33 0.27 0.16 0.06
in % 0.13 0.74 1.21 1.58 1.87 2.07
N2O in kt 0.05 0.34 0.57 0.55 0.34 0.12
in % 0.22 0.99 1.38 1.65 1.88 2.07
Lorries and buses
NOx in kt 9.43 57.81 99.86 112.89 98.15 84.96
in % 0.89 7.14 14.16 18.20 19.27 19.30
PM2.5,
total
in kt 0 0 0 0 0 0
in % 0 0 0 0 0 0
PM2.5,
exhaust
in kt 0 0 0 0 0 0
in % 0 0 0 0 0 0
PN in # 0 0 0 0 0 0
in % 0 0 0 0 0 0
CO in kt 0 0 0 0 0 0
in % 0 0 0 0 0 0
THC in kt 0 0 0 0 0 0
in % 0 0 0 0 0 0
NMHC in kt 0 0 0 0 0 0
in % 0 0 0 0 0 0
NH3 in kt 0 0 0 0 0 0
in % 0 0 0 0 0 0
CH4 in kt 0 0 0 0 0 0
in % 0 0 0 0 0 0
1.2.3.2. Environmental impacts in policy option 2
The environmental impacts in terms of air pollutant emission reductions from road
transport are the emission savings that would be achieved over the savings expected in
the baseline with merely Euro 6/VI vehicle fleet renewal in combination with the impact
98
See footnote 38
47
of the new CO2 standards.
In policy option 2, stricter emission limits in medium and high ambition are considered
for all vehicle categories and pollutants regulated under Euro 6/VI (NOx, PM, PN, CO,
THC, NMHC, NH3, CH4), new emission limits for the unregulated pollutants N2O,
HCHO and brake emissions99
and extended real-driving testing. Sub-option 2a considers
a Medium Green Ambition with medium ambition limits and real-driving testing
boundaries (see Table 50); sub-option 2b considers a High Green Ambition with high
ambition limits and real-driving testing boundaries (see Table 51).
Medium Green Ambition (option 2a)
As shown in Table 12, the emission savings that can be expected in sub-option 2a
compared to the baseline are significant, in particular for lorries and buses. However,
also the decrease of emissions for cars and vans is relevant, as those vehicles are
predominantly used in densely populated urban areas where more citizens are exposed to
respiratory health risk.
For cars and vans, NOx emissions are expected to decrease significantly and rapidly
compared to the baseline by 21% in 2030, 42% in 2035, 62% in 2040 to 88% in 2050.
This significant decrease follows from the introduction of medium ambition extended
real-driving testing covering more conditions outside the current RDE boundaries and a
technology-neutral NOx emission limit of 30 mg/km for cars, which replaces the current
diverging NOx limits in the Euro 6 standard of 60 mg/km for petrol cars and 80 mg/km
for diesel cars. The decrease illustrates that cars and vans go more rapidly toward zero-
pollution levels (about 80 kt NOx/a) in 2040, compared to similar levels reached in 2050
in the baseline.
Significant savings can be expected also due to the more stringent air pollutant emission
limits and increased durability requirements for particles, hydrocarbons, NH3 and N2O
emissions from cars and vans. Regarding particles, PM2,5 exhaust emissions are expected
to decrease by 5% in 2030 to 22% in 2050 and PN emissions by 15% in 2030 to 88% in
2050 (PM exhaust and PN emissions also thorough inclusion of DPF regeneration
control100
). Brake emissions, which have become increasingly relevant sources of non-
exhaust particles, are assumed to go down by 16% in 2030 to 36% in 2050 through the
use of brake pads. CO emissions are expected to decrease by 14% in 2030 to 47% in
2050, NMHC by 13% in 2030 to 26% in 2050 and CH4 emissions by 15% in 2030 to
32% in 2050. NH3 emissions from cars and vans are presumed to drop by 11% in 2030 to
74% in 2050, and N2O emissions by 7% in 2030 to 55% in 2050.
For lorries and buses, the highest emission savings can be expected under sub-option 2a
due to the more stringent air pollutant emission limits for NOx, particles, hydrocarbons,
NH3 and N2O emissions. NOx emissions are assumed to decrease by 209 kt in 2030 to
411 kt in 2050. This high reduction comes from the fact that in the EU fleet a significant
number of heavy-duty vehicles, in particular diesel lorries, is still expected to be
equipped with a combustion engine vehicle until 2050.
99
As there are no testing methods for brake emissions from lorries and buses and for tyre emissions from
all vehicle categories developed so far, the environmental impact of those non-exhaust particles cannot be
determined and subsequently assessed.
100
Supporting Euro 7 impact assessment study, chapter 5.2.1. Environmental impacts
48
PM2,5 emissions are expected to decrease by 2.1 kt in 2030 to 3.1 kt in 2050, with a
larger relative impact on PN emissions decrease due to the required particle filter for PI
vehicles101
. CO emissions are expected to fall by 6.4 kt in 2030 to 16 kt in 2050, also by
control of emissions under the complete engine operation map, as CO emissions could
increase somewhat for the vehicle to meet the required NOx reductions at cold-start102
.
Moreover, THC emissions are presumed to drop by 2 kt in 2030 to 3.3 kt in 2050, NH3
emissions by 2.0 kt in 2030 to 2.6 kt in 2050, and N2O emissions by 25 kt in 2030 to 32
kt in 2050.
Table 12 – Emission savings for pollutants from road transport in policy option 2a
compared to the baseline103
Pollutant 2025 2030 2035 2040 2045 2050
Cars and vans
NOx in kt 27.97 138.31 165.00 128.60 71.33 25.31
in % 2.71 21.07 42.37 62.28 78.61 88.37
PM2.5,brake
emissions
in kt 0.44 2.55 4.22 5.41 6.01 6.16
in % 2.96 16.34 26.32 32.63 35.52 36.28
PM2.5,exhaust in kt 0.04 0.20 0.23 0.15 0.06 0.02
in % 0.35 5.06 14.99 21.61 22.39 21.97
PN10 in # 1.73E+23 8.00E+23 8.67E+23 6.03E+23 2.90E+23 9.29E+22
in % 0.97 15.09 45.09 66.50 78.53 87.55
CO in kt 28.20 137.96 169.67 124.68 58.28 18.09
in % 1.86 14.31 29.03 40.16 45.36 47.36
THC in kt 5.99 28.87 32.89 24.34 13.29 5.31
in % 2.15 13.62 22.51 27.38 27.82 26.95
NMHC in kt 5.16 23.75 25.46 18.71 10.54 4.45
in % 2.13 13.34 21.36 26.13 26.83 26.16
NH3 in kt 0.41 2.83 7.70 8.38 4.68 1.56
in % 1.58 10.75 32.30 52.30 65.87 74.27
CH4 in kt 0.82 5.12 7.43 5.64 2.74 0.87
in % 2.23 15.09 27.66 32.57 32.42 31.86
N2O in kt -0.42 2.39 12.35 15.20 9.15 3.31
in % -1.85 6.88 29.93 45.18 51.08 54.80
HCHO in kt n.a. n.a. n.a. n.a. n.a. n.a.
in % n.a. n.a. n.a. n.a. n.a. n.a.
Lorries and buses
NOx in kt 32.44 209.13 389.30 480.90 455.90 410.60
in % 3.06 25.83 55.19 77.55 89.48 93.30
PM2.5, total in kt 0.37 2.08 3.44 3.88 3.50 3.08
in % 1.46 9.50 17.71 23.88 27.59 29.02
PM2.5,exhaust in kt 0.37 2.08 3.44 3.88 3.50 3.08
in % 2.61 19.40 39.08 54.35 62.74 65.37
PN10 in # 2.93E+22 1.94E+23 3.44E+23 4.30E+23 4.11E+23 3.70E+23
in % 0.37 10.08 45.88 71.66 78.38 79.95
CO in kt 0.69 6.42 13.58 18.42 17.66 15.95
in % 0.32 4.70 12.18 17.42 18.97 19.17
THC in kt 0.33 2.00 3.49 4.06 3.69 3.27
in % 1.35 8.08 13.15 15.06 15.44 14.90
NMHC in kt 0.36 2.13 3.70 4.30 3.92 3.47
101
See footnote 100
102
See footnote 100
103
See footnote 38
49
in % 1.70 11.73 22.24 29.04 31.65 30.09
NH3 in kt 0.37 2.04 3.19 3.41 2.98 2.58
in % 4.80 22.52 33.14 37.24 38.79 38.99
CH4 in kt -0.02 -0.13 -0.21 -0.25 -0.23 -0.21
in % -0.63 -2.03 -2.14 -2.02 -2.01 -2.00
N2O in kt 4.61 25.13 39.45 42.28 37.08 32.17
in % 4.68 23.97 40.35 51.72 58.16 60.06
HCHO in kt n.a. n.a. n.a. n.a. n.a. n.a.
in % n.a. n.a. n.a. n.a. n.a. n.a.
High Green Ambition (option 2b)
As shown in Table 13, the emission savings that can be expected in sub-option 2b
compared to the baseline are significant, in particular for lorries and buses. In
comparison to sub-option 2a, stricter emission limits are assumed for NOx emissions
from cars and vans (20 mg/km instead of 30 mg/km) and lorries and buses (100 mg/kWh
instead of 150 mg/kWh), and NMHC (20 mg/km instead of 40 mg/km) and brake
emissions (5 instead of 7 mg/km) from cars and vans.
It is important that sub-option 2b is expected to lead only to marginal reductions of NOx
and NHMC emission compared to sub-option 2a.
For cars and vans, the marginal NOx effect (-21.1% in 2030 and -88.4% in 2050 in sub-
option 2a and -21.4% in 2030 and -90.4% in 2050 in sub-option 2b) is explained by the
fact that manufacturers consider a safety factor to comply with emission limits, which
results in average emissions being lower than the emission limit. Assuming a 30 mg/km
emission limit for NOx under sub-option 2a would already lead to a very low average
emission level, which is not expected to be significantly lowered with a 20 mg/km
emission limit under sub-option 2b. For lorries and buses, the marginal NOx effect (-
25.8% in 2030 and -93.3% in 2050 in sub-option 2a and -26.0% in 2030 and -93.8% in
2050 in sub-option 2b) is explained by the fact that the testing conditions are already
comprehensively extended in sub-option 2a leading to the major positive effect on the
emission performance, whereas the reduction of the NOx limit from 150 mg/kWh to 100
mg/kWh and the extended real-driving testing boundaries in sub-option 2b offers a low
emission savings.104
Reductions are expected for non-exhaust PM2.5 emissions from cars and vans, since sub-
option 2b includes more stringent limits for brake emissions which require brake pads
and the installation of brake dust particle filter in the vehicle. That way, brake emission
savings are achieved (54% in 2050 in sub-option 2b compared to 36% in 2050 in sub-
option 2a).
Table 13 – Emission savings for pollutants from road transport in policy option 2b
compared to the baseline105
Pollutant 2025 2030 2035 2040 2045 2050
Cars and vans
NOx in kt 28.45 140.6 167.60 130.90 72.80 25.88
in % 2.76 21.42 43.04 63.43 80.27 90.35
104
See footnote 100
105
See footnote 38
50
PM2.5,br
ake
emissions
in kt 0.66 3.83 6.33 8.12 9.02 9.24
in % 4.44 24.51 39.48 48.95 53.28 54.42
PM2.5,
exhaust
in kt 0.05 0.23 0.25 0.19 0.10 0.03
in % 0.39 5.69 16.90 27.16 34.08 38.19
PN10 in # 1.74E+23 8.06E+23 8.73E+23 6.09E+23 2.94E+23 9.49E+22
in % 0.97 15.20 45.42 67.22 79.85 89.38
CO in kt 30.05 146.60 179.50 139.30 69.90 22.87
in % 1.98 15.20 30.70 44.86 54.42 59.86
THC in kt 6.50 31.29 35.61 27.67 15.79 6.51
in % 2.33 14.76 24.38 31.13 33.06 33.00
NMHC in kt 5.67 26.17 28.14 20.92 11.90 5.15
in % 2.35 14.70 23.60 29.22 30.29 30.28
NH3 in kt 0.41 2.83 7.71 8.46 4.81 1.63
in % 1.59 10.78 32.34 52.80 67.69 77.26
CH4 in kt 0.82 5.12 7.47 6.76 3.88 1.36
in % 2.23 15.09 27.82 39.04 45.91 49.96
N2O in kt 0.49 6.81 17.46 20.50 13.12 4.92
in % 2.16 19.59 42.31 60.93 73.28 81.48
HCHO in kt n.a. n.a. n.a. n.a. n.a. n.a.
in % n.a. n.a. n.a. n.a. n.a. n.a.
Lorries and buses
NOx in kt 32.66 210.40 391.50 483.60 458.60 413.20
in % 3.08 25.98 55.49 77.99 90.02 93.88
PM2.5,
total
in kt 32.66 210.40 391.50 483.60 458.60 413.20
in % 3.08 25.98 55.49 77.99 90.02 93.88
PM2.5,
exhaust
in kt 0.37 2.09 3.46 3.93 3.57 3.17
in % 2.61 19.44 39.31 55.14 64.16 67.17
PN10 in # 2.94E+22 1.95E+23 3.44E+23 4.31E+23 4.12E+23 3.71E+23
in % 0.37 10.08 45.91 71.76 78.54 80.15
CO in kt 1.67 11.92 22.43 28.77 27.48 24.80
in % 0.77 8.72 20.11 27.21 29.53 29.80
THC in kt 0.36 2.13 3.71 4.33 3.96 3.52
in % 1.44 8.62 13.97 16.07 16.59 16.06
NMHC in kt 0.38 2.24 3.89 4.53 4.15 3.69
in % 1.79 12.35 23.33 30.59 33.52 31.95
NH3 in kt 0.37 2.04 3.21 3.49 3.11 2.72
in % 4.80 22.52 33.31 38.12 40.41 41.12
CH4 in kt -0.02 -0.11 -0.18 -0.20 -0.19 -0.17
in % -0.53 -1.71 -1.80 -1.67 -1.63 -1.61
N2O in kt 4.61 25.13 39.68 43.43 38.88 34.21
in % 4.68 23.97 40.59 53.13 60.98 63.86
HCHO in kt n.a. n.a. n.a. n.a. n.a. n.a.
in % n.a. n.a. n.a. n.a. n.a. n.a.
1.2.3.3. Environmental impacts in policy option 3
The environmental impacts in terms of air pollutant emission reductions from road
transport are the emission savings that would be achieved over the savings expected in
the baseline with merely Euro 6/VI vehicle fleet renewal in combination with the impact
of the new CO2 standards.
Policy option 3a considers the introduction of continuous emission monitoring (CEM), to
control real-driving emissions throughout the vehicle’s lifetime in a Medium Green and
51
Digital Ambition. It is based on available NOx, NH3 and PM sensor technologies (see
Table 55). Policy option 3a builds on the medium ambition stricter air pollutant emission
limits, real-driving testing boundaries and durability requirements as policy option 2a
(see Table 50).
As shown in Table 14, the emission savings that can be expected in PO3a compared to
the baseline are significant, in particular for lorries and buses. Also for cars and vans
very low NOx emission levels are reached in 2040, compared to 2050 in the baseline.
Through the introduction of CEM for NOx and NH3 emissions, some savings are
expected to be achieved compared to the introduction of strict emission limits (PO2a), by
guaranteeing lifetime compliance with emission limits and improved protection against
tampering with the NOx emission control system. For cars and vans, NOx emissions are
expected to decrease by 141 kt in 2030, 132 kt in 2040 to 26 kt in 2050 (compared to 138
kt in 2030, 129 kt in 2040 to 25 in 2050 in policy option 2a). For lorries and buses, NOx
emissions are expected to decrease by 211 kt in 2030, 485 kt in 2040 to 415 kt in 2050
(compared to 209 kt in 2030, 481 kt in 2040 to 411 kt in 2050 in policy option 2a).
Some emission savings are also expected by the use of NH3 sensors over the vehicle’s
lifetime. For cars and vans, NH3 emissions are expected to decrease by 2.8 kt in 2030,
8.8 kt in 2040 to 1.7 kt in 2050 (compared to 2.8 kt in 2030, 8.4 kt in 2040 to 1.6 in 2050
in policy option 2a). For lorries and buses, NH3 emissions are expected to decrease by
2.3 kt in 2030, 4.0 kt in 2040 to 3.1 kt in 2050 (compared to 2.0 kt in 2030, 3.4 kt in 2040
to 2.6 kt in 2050 in policy option 2a).
Table 14 – Emission savings for pollutants from road transport in policy option 3a
compared to the baseline106
Pollutant 2025 2030 2035 2040 2045 2050
Cars and vans
NOx in kt 28.59 141.30 168.60 131.90 73.50 26.20
in % 2.77 21.53 43.31 63.90 81.03 91.33
PM2.5,brak
e emissions
in kt 0.44 2.55 4.22 5.41 6.01 6.16
in % 2.96 16.34 26.32 32.63 35.52 36.28
PM2.5,exha
ust
in kt 0.04 0.20 0.23 0.15 0.06 0.02
in % 0.35 5.06 14.99 21.61 22.39 21.97
PN10 in # 1.73E+23 8.00E+23 8.67E+23 6.03E+23 2.90E+23 9.29E+22
in % 0.97 15.09 45.09 66.50 78.53 87.55
CO in kt 28.20 138.00 169.70 124.70 58.30 18.10
in % 1.86 14.31 29.03 40.16 45.36 47.36
THC in kt 6.01 29.70 34.56 26.17 14.83 6.49
in % 2.16 14.01 23.65 29.44 31.05 32.92
NMHC in kt 5.19 24.58 27.13 20.53 12.09 5.62
in % 2.15 13.80 22.75 28.68 30.75 33.09
NH3 in kt 0.41 2.84 7.95 8.81 5.04 1.71
in % 1.58 10.80 33.33 54.97 70.87 81.13
CH4 in kt 0.82 5.12 7.43 5.64 2.74 0.87
in % 2.23 15.09 27.66 32.57 32.42 31.86
N2O in kt -0.42 2.39 12.35 15.20 9.15 3.31
in % -1.85 6.88 29.93 45.18 51.08 54.80
HCHO in kt n.a. n.a. n.a. n.a. n.a. n.a.
106
See footnote 38
52
in % n.a. n.a. n.a. n.a. n.a. n.a.
Lorries and buses
NOx in kt 32.78 211.20 392.80 485.30 460.20 414.70
in % 3.10 26.08 55.69 78.25 90.34 94.22
PM2.5,total in kt 0.37 2.08 3.44 3.88 3.50 3.08
in % 1.46 9.50 17.71 23.88 27.59 29.02
PM2.5,
exhaust
in kt 0.37 2.08 3.44 3.88 3.50 3.08
in % 2.61 19.40 39.08 54.35 62.74 65.37
PN10 in # 2.94E+22 1.95E+23 3.44E+23 4.30E+23 4.11E+23 3.70E+23
in % 0.37 10.08 45.88 71.66 78.38 79.95
CO in kt 0.69 6.42 13.58 18.42 17.66 15.95
in % 0.32 4.70 12.18 17.42 18.97 19.17
THC in kt 0.33 2.00 3.49 4.06 3.69 3.27
in % 1.35 8.08 13.15 15.06 15.44 14.90
NMHC in kt 0.36 2.13 3.70 4.30 3.92 3.47
in % 1.70 11.73 22.24 29.04 31.65 30.09
NH3 in kt 0.42 2.31 3.64 3.96 3.52 3.08
in % 5.44 25.50 37.72 43.17 45.76 46.56
CH4 in kt -0.02 -0.13 -0.21 -0.25 -0.23 -0.21
in % -0.63 -2.03 -2.14 -2.02 -2.01 -2.00
N2O in kt 4.61 25.13 39.45 42.28 37.08 32.17
in % 4.68 23.97 40.35 51.72 58.16 60.06
HCHO in kt n.a. n.a. n.a. n.a. n.a. n.a.
in % n.a. n.a. n.a. n.a. n.a. n.a.
1.3. Cost modelling, cost-benefit and cost-effectiveness analysis
1.3.1. Cost modelling
In order to perform the cost-benefit analysis, the total regulatory cost should be
calculated next to the health and environmental benefits. In order to model these costs,
the regulatory cost following the implementation of each policy option should be
considered, compared to the baseline. Equation 4 shows that this cost is the difference in
costs over the baseline without taxes and profit margins.
Equation 4107
Incremental Cost = ∆(Final Price – Taxes – Mark-up)
The total regulatory costs related to the introduction of Euro 6/VI for the evaluation and
related to the introduction of Euro 7 for the impact assessment are calculated as the sum
of the costs over multiple cost categories, comprising substantive compliance costs and
administrative costs. Considering the costs over these different categories should enhance
the accuracy of the total regulatory cost by minimising uncertainty. The considered cost
categories are presented in Tavle 39 in Annex 5. In the context of the impact assessment,
for each policy option one or more of these cost elements need to be assessed in order to
find the total societal cost, expressed as monetised health and environmental benefits. For
the evaluation of Euro 6/VI, these cost elements and the respective values are discussed
in detail and per stakeholder group in the Efficiency chapter.
The cost data have been verified by stakeholders and the remaining uncertainty has been
estimated for all vehicles in the cost-benefit analysis (see section 1.3.2.1).
107
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.5 Cost modelling
53
Each cost element is calculated over a specific unit and then scaled up to the total. These
units are summarized below:
- Number of new vehicle registrations per vehicles category – these are obtained
through the SIBYL model
- Number of engine/model families per vehicle category – estimated based on data
from IHS Markit Database108
. It was assumed that the current average per year
will not change significantly in the future.
- Number of type-approvals – based on data provided by a group of type-approval
authorities, presenting around 67% of the total WVTA, and extrapolated to the
total EU. On the basis of this number the total average number of TAA per year
was estimated. For the evaluation, an increase in the number of type-approvals for
the period 2018-2020 was observed, which was linked to the need for further
type-approvals following the staged introduction of Euro 6. However, the number
is expected to remain constant afterwards.
- Number of vehicle manufacturers affected – based on information on the number
of vehicle sales per manufacturer as provided by ACEA. The cost estimates
focused on the main manufacturers in the different vehicle categories that, put
together, represent more than 90% of the total sales.
- Number of calibrations – based on data from IHS Markit Database109
on number
of engine families to develop an estimate of the number of calibrations taking
place per manufacturer and per year.
In addition, the assumptions made for the cost assessment are summarized in Box 4.
Box 4 – Key assumptions for cost modelling110
 Discount rate: 4%
 Learning effect for new hardware: The hardware costs are expected to decrease over time as the
state of the art evolves and manufacturers and suppliers become more familiar with the new
technologies through a learning effect. The faster these effects play out, the lower the overall costs
will be. In the analysis, it is assumed that new technology incremental costs drop to 50% within a six
year time-frame after their first introduction.
 Amortization period for R&D costs: Since R&D costs are one-off incremental costs, the main R&D
investment is practically materialised before the emission standard becomes available and is then
amortized over a certain period that is assumed to be between 5-10 years111
. In our approach we have
assumed that R&D costs are linked to the first model families appearing at the year of introducing the
new emission standard and are amortized over the lifetime of this first model, which is of the order of
8 years in the EU.
 Learning effect for calibration costs: Any additional calibration effort is consider to drop to 50% of
the initial additional effort as the OEM becomes more experienced with calibrating the new
technology, which is already expected with the second model series after the introduction of a new
standard.
 No learning effect for testing and witnessing costs: Since costs are related to a procedure
108
IHS Market, 2021. Provision of data on vehicle sales in the EU-28 for Evaluation of Euro 6/VI vehicle
emission standards
109
See footnote 108
110
See footnote 107
111
Rogozhin et al. 2010. Using indirect cost multipliers to estimate the total cost of adding new technology
in the automobile industry.
54
demanded by the regulation, no significant cost reduction is expected over time.
The regulatory costs resulting from the cost modelling were used as input for assessing
impacts in the areas of affordability for consumers and SME users. Assuming that a pass
through of the costs takes place, consumers should be affected through an increase in
vehicle prices. Assessing the relative impact can be examined by comparing vehicle
prices with the costs per vehicle for Euro 6/VI or the different policy options to assess
what share of a vehicle price they represent. Since vehicles in small size segments may
not require all technologies identified in the default packages, prices and expected costs
were compared for vehicles of similar size. To be more specific, low-end cost estimates
were compared against the weighted average of vehicle prices112
in the small size
segments (mini/small), moderate cost estimates against the average price of the medium
size segments vehicles (lower medium/medium/off-road/multi-purpose) and the high-end
cost estimates against the higher cost segments of the large size segment vehicles (upper
medium/sport/luxury).
While average prices from the ICCT were weighted against sales in 2018 and used for
the assessment of affordability in the evaluation (see Table 41 Annex 5), in the impact
assessment three additional steps were added. First, the ICE price projections of the
Bloomberg New Energy Finance (BNEF) study113
were used. That way, 1.5% annual
price increases were assumed in the large vehicle segment, 2% in the medium vehicle
segment and 2.5% in the small vehicle segment. Then, these increasing vehicle prices
over the assessed period were discounted using the social discount rate of 4% and
expressed in 2025 values. Finally, these results were weighted against the modelled
vehicle registrations for each year. The results are presented in Table 17, Table 22 and
Table 25 below.
1.3.1.1. Regulatory costs in policy option 1
The simplification measures introduced in policy option 1 intend to reduce complexity,
remove inconsistencies and improve efficiency in the legislation. That way, the policy
option was expected to result in some cost reductions, especially for costs during
implementation phase and administrative costs, largely due to the streamlining of testing
procedures. Table 15 presents the regulatory costs for policy option 1 over those related
to the baseline.
112
Based on the respective shares of sales by vehicle segment and average price (including tax). Data are
provided by ICCT in the EU Pocketbook (ICCT, 2019).
113
Bloomberg New Energy Finance (BNEF), 2021. Hitting the EV Inflection Point – Electric vehicle price
parity and phasing out combustion vehicle sales in Europe
55
Table 15 – Regulatory costs for automotive industry in policy option 1 compared to the
baseline, in 2025 values114
Cars and vans Lorries and buses
PI CI PI CI
1) Equipment costs
 Hardware costs (emission control technologies)
Cost per vehicle (€) 33.26 104.10 0.00 0.00
Total cost (billion €) 1.31 4.70 0.00 0.00
 R&D and related calibration costs including facilities and tooling costs
Cost per vehicle (€) 27.55 32.17 102.86 102.86
Total cost (billion €) 1.08 1.45 0.13 0.52
2) Costs during implementation phase
 Testing costs (granting type-approval, verification procedures)
Cost per model/engine family (thousand €) -2 345.40 -9 385.64 -7 439.25 -3 121.19
Cost per vehicle (€) -22.31 -21.55 -70.83 -32.90
Total cost (million €) -878.49 -972.25 -87.34 -167.34
 Witnessing costs (by type-approval authorities)
Cost per model/engine family (thousand €) -156.66 -626.90 -263.47 -110.54
Cost per vehicle (€) -1.49 -1.44 -2.51 -1.17
Total cost (million €) -58.68 -64.94 -3.09 -5.93
 Type-approval fees, except witnessing costs
Cost per type-approval (thousand €) -1.83 -2.37 -0.52 -0.51
Cost per vehicle (€) -0.34 -0.33 -0.52 -0.24
Total cost (million €) -13.32 -14.74 -0.64 -1.23
3) Administrative costs (information provision)
Cost per type-approval (thousand €) -97.40 -126.32 -31.08 -30.35
Cost per vehicle (€) -18.03 -17.42 -31.12 -14.46
Total cost (million €) -710.18 -785.98 -38.38 -73.53
Total regulatory costs
Total regulatory cost per vehicle (€) 18.64 95.53 -2.12 54.09
Total regulatory cost until 2050 (NPV in
billion € - 2025 values)
0.73 4.31 0.00 0.28
The hardware costs represent recurrent costs arising from the need to install emission
control technologies on vehicles to meet the actions of policy option 1. In terms of
technology, no new hardware will be required to comply with technology-neutral
emission limits. Reason for this being that for petrol cars and vans no new limits are
proposed, while today’s Euro 6d diesel cars and vans seem to be compliant with the NOx
limit of 60 mg/km limit115
. This reasoning also applies to the decrease of particle size
threshold from 23 to 10 nm in policy option 1. New hardware is, however, required for
cars and vans to ensure that emissions are also controlled in low ambition extended real-
driving testing outside the current RDE boundaries. This would mean including a larger
three-way catalytic converter (TWC) and an improved gasoline particulate filter (GPF)
for some of the PI cars and vans, which is estimated to increase the hardware costs by
€33 per vehicle. CI cars and vans will need better thermal management and larger
114
Supporting Euro 7 impact assessment study, chapter 5.1.2. Economic impacts
115
Derived from 45 RDE compliant tests of Euro 6d diesel cars and vans by JRC, TNO and GreenNCAP.
56
components of exhaust aftertreatment components, which is estimated to increase the
hardware costs by €104 per vehicle. Since neither the emission limits nor the PEMS
testing conditions have changed for lorries and buses in comparison to the baseline, no
hardware costs are expected.
Table 16 - Assumed control technology packages for policy option 1 and the respective
hardware costs per vehicle for the average vehicle compared to the baseline, 2021
values116
Category Petrol Diesel CNG/LPG
Cars and vans
MHEV
 50% Mild hybrid, base TWC,
base GPF
 Cost per vehicle: €0
 50% current technology
 Cost per vehicle: €0
 100% Mild hybrid,
advanced calibration,
larger TWC
 Cost per vehicle:
€78.8
 50% Mild hybrid, advanced
calibration, larger TWC,
improved GPF
 Cost per vehicle: €108.8
 50 % Mild hybrid, advanced
heating calibration, larger
EATS cost per vehicle:
€201.7
PHEV
 100% Plugin hybrid, base TWC,
base GPF
 Cost per vehicle: €0
 100% Plugin hybrid,
advanced heating calibration,
larger EATS
 Cost per vehicle: €201.7
 100% Plugin hybrid,
advanced calibration,
larger TWC
 Cost per vehicle:
€78.8
Lorries and buses
- -
 100% current technology
 Cost per vehicle: €0
 100% current
technology
 Cost per vehicle: €0
Next to the hardware costs for cars and vans, automotive industry is faced with R&D and
calibration costs. In comparison to the baseline, these costs amount to approximately
€28-€32 per vehicle for cars and vans. Although no hardware costs is needed for lorries
and buses, R&D costs are required to introduce the improved OBD functionality (see
Table 47) on the vehicles and to attain the PN limits with decreased threshold of 10 nm.
Due to the much smaller production volumes for lorries and buses in comparison to cars
and vans, the R&D cost per vehicle is with €103 per vehicle higher, while the total cost
are closer in range for the different vehicle categories.
In contrast to the equipment cost, the costs during implementation phase – including
testing and witnessing costs and type-approval fees – are projected to decrease
significantly with the implementation of simplification measures (see Table 47). The
testing costs for PI cars and vans, for example, are estimated to decrease by €2 345
thousand per model family (€22 per vehicle), while the witnessing costs for this category
are estimated to decrease by €157 thousand per model family (-€1.49 per vehicle). For CI
vehicles, the savings in testing costs per model family go further with €9 386 thousand.
However, due to the larger number of vehicles in the average CI model family the cost
per vehicle also decreases by €22. The savings in witnessing costs per vehicle are found
to be lower for CI cars and vans, than for PI cars and vans. In addition, the simplification
measures would achieve significant costs savings during implementation phase for lorries
and buses, especially for PI vehicles. Following the implementation of the simplification
measures, the fees per type-approval are estimated to decrease to a similar extent for all
vehicle categories.
116
See footnote 107
57
Another set of significant cost savings is expected in administrative costs (information
provision). The simplification measures related to the legislative process and the testing
procedures is translated into an extensive decrease in administrative burden for all
vehicle categories. The administrative costs per type-approval are estimated to decrease
most for CI cars and vans. For CI cars and vans for example, a cost saving of €126
thousand per type-approval (€17 per vehicle) is expected to be realised.
Table 17 – Regulatory costs of policy option 1 compared to the baseline in comparison
to average purchase prices per vehicle segment, in 2025 values
Vehicle
segment
Regulatory cost per
vehicle (in €)
Average vehicle
price (in €)
Share of vehicle
price (in %)
Cars and vans PI Small 18.64 17 281.92 0.11
Medium 18.64 31 293.75 0.06
Large 18.64 65 099.78 0.03
Cars and vans CI Small 95.53 17 144.19 0.56
Medium 95.53 31 044.35 0.31
Large 95.53 64 580.95 0.15
Lorries Small 48.00 79 389.47 0.06
Medium 48.00 100 713.53 0.05
Large 48.00 151 183.30 0.03
Buses Small -4.92 152 198.85 0.00
Medium -4.92 185 653.41 0.00
Large -4.92 217 376.97 0.00
1.3.1.2. Regulatory costs in policy option 2
Policy options 2a and 2b consider two levels of ambition (medium and high) for
introducing stricter pollutant emission limits to the Euro 6/VI emission limits to provide
appropriate and up-to-date limits for all relevant air pollutants (see Table 50 and Table
51). In addition, option 2 develops extended real-driving testing boundaries in two
ambition levels (medium and high) to improve control of real-world emissions and builds
on the same simplification measures as option 1 to reduce complexity of the Euro 6/VI
emission standards. Stricter air pollutant limits for vehicles and comprehensive real-
driving testing result in regulatory costs for automotive industry, while the simplification
measures lead to the similar cost savings as in option 1. Table 18 presents the regulatory
costs for policy option 2a over those related to the baseline, while Table 19 represents
those for policy option 2b.
58
Table 18 - Regulatory costs for tailpipe and evaporative emissions for automotive
industry in policy option 2a (medium ambition stricter emission limits and real driving
testing boundaries) compared to the baseline, in 2025 values117
Cars and vans Lorries and buses
PI CI PI CI
1) Equipment costs
 Hardware costs (emission control technologies)
Cost per vehicle (€) 81.07 328.35 1 137.71 1 481.04
Total cost (billion €) 3.19 14.82 1.40 7.53
 R&D and related calibration costs including facilities and tooling costs
Cost per vehicle (€) 103.52 111.74 1 245.48 1 248.22
Total cost (billion €) 4.08 5.04 1.54 6.35
2) Costs during implementation phase
 Testing costs (granting type-approval, verification procedures)
Cost per model/engine family
(thousand €)
-2 228.49 -9 385.64 -7 439.25 -3 121.19
Cost per vehicle (€) -21.20 -21.55 -70.83 -32.90
Total cost (million €) -834.70 -972.25 -87.34 -167.34
 Witnessing costs (by type-approval authorities)
Cost per model/engine family
(thousand €)
-156.66 -626.90 -263.47 -110.54
Cost per vehicle (€) -1.49 -1.44 -2.51 -1.17
Total cost (million €) -58.68 -64.94 -3.09 -5.93
 Type-approval fees, except witnessing costs
Cost per type-approval (thousand
€)
-1.83 -2.37 -0.52 -0.51
Cost per vehicle (€) -0.34 -0.33 -0.52 -0.24
Total cost (million €) -13.32 -14.74 -0.64 -1.23
3) Administrative costs (information provision)
Cost per type-approval (thousand
€)
-97.40 -126.32 -31.08 -30.35
Cost per vehicle (€) -18.03 -17.42 -31.12 -14.46
Total cost (million €) -710.18 -785.98 -38.38 -73.53
Total regulatory costs
Total regulatory cost per vehicle
(€)
143.54 399.36 2 278.22 2 680.49
Total regulatory cost until 2050
(NPV in billion € - 2025 values)
5.65 18.02 2.81 13.63
Table 19 - Regulatory costs for tailpipe and evaporative emissions for automotive
industry in policy option 2b (high ambition stricter emission limits and real driving
testing boundaries) compared to the baseline, in 2025 values118
Cars and vans Lorries and buses
PI CI PI CI
1) Equipment costs
 Hardware costs (emission control technologies)
Cost per vehicle (€) 252.74 387.24 2 003.76 3 074.05
117
Supporting Euro 7 impact assessment study, chapter 5.2.2. Economic impacts
118
See footnote 117
59
Total cost (billion €) 9.95 17.47 2.47 15.64
 R&D and related calibration costs including facilities and tooling costs
Cost per vehicle (€) 115.21 116.26 1 249.73 1 255.19
Total cost (billion €) 4.54 5.25 1.54 6.38
2) Costs during implementation phase
 Testing costs (granting type-approval. verification procedures)
Cost per model/engine family (thousand €) -2 228.49 -9 385.64 -7 439.25 -3 121.19
Cost per vehicle (€) -21.20 -21.55 -70.83 -32.90
Total cost (million €) -834.70 -972.25 -87.34 -167.34
 Witnessing costs (by type-approval authorities)
Cost per model/engine family (thousand €) -156.66 -626.90 -263.47 -110.54
Cost per vehicle (€) -1.49 -1.44 -2.51 -1.17
Total cost (million €) -58.68 -64.94 -3.09 -5.93
 Type-approval fees. except witnessing costs
Cost per type-approval (thousand €) -1.83 -2.37 -0.52 -0.51
Cost per vehicle (€) -0.34 -0.33 -0.52 -0.24
Total cost (million €) -13.32 -14.74 -0.64 -1.23
3) Administrative costs (information provision)
Cost per type-approval (thousand €) -97.40 -126.32 -31.08 -30.35
Cost per vehicle (€) -18.03 -17.42 -31.12 -14.46
Total cost (million €) -710.18 -785.98 -38.38 -73.53
Total regulatory costs
Total regulatory cost per vehicle (€) 326.88 462.76 3 148.51 4 280.48
Total regulatory cost until 2050 (NPV in
billion € - 2025 values)
12.87 20.88 3.88 21.77
The hardware costs represent recurrent costs arising from the need to install engine and
emission control technologies for tailpipe and evaporative emissions on vehicles to meet
the requirements of policy option 2. The cost estimates in Table 18 and Table 19 show
that for all vehicle categories the hardware costs are considerably higher in policy option
2b than in policy option 2a and 1. This demonstrates that the further decrease in emission
limits and the further extension of real-driving testing boundaries in policy option 2b
requires further technology at a higher cost. In Table 21, the assumed technology
packages to comply with the stricter emission limits in policy option 2 for are presented,
together with the hardware costs of these packages compared to the baseline, i.e. costs for
Euro 6d / VI E technologies. These hardware costs show that higher effort is needed to
curb pollutant emissions from diesel vehicles and from larger vehicles, compared to
gasoline vehicles. Comparing the hardware costs with the other cost categories in the
tables above, it is clear that the rise in hardware costs is the most extensive for all vehicle
categories.
The hardware costs in Table 18 and Table 19 do not include the costs of technologies
required for introducing a brake emission limit, as costs for brake pads are different
between ICE/MHEV and PHEV/BEV vehicles due to the different technologies and
braking patterns used for these vehicles (see Table 20).
Table 20 –Regulatory costs for brake emissions in policy option 2 compared to the
baseline, in 2025 values
Cars and vans Lorries and buses
ICE/MHEV PHEV/BEV ICE/MHEV PHEV/BEV
60
Option 2a – Medium Green Ambition
1) Equipment costs
 Hardware costs (emission control technologies for brakes)
Cost per vehicle (€) 23.06 12.78 - -
Total cost (billion €) 1.95 4.65 - -
Cars and vans Lorries and buses
ICE/MHEV PHEV/BEV ICE/MHEV PHEV/BEV
Option 2b – High Green Ambition
1) Equipment costs
 Hardware costs (emission control technologies for brakes)
Cost per vehicle (€) 100.28 60.07 - -
Total cost (billion €) 8.47 21.62 - -
Table 21 - Assumed control technology packages for policy option 2 and the respective
hardware costs per vehicle for the average vehicle compared to the baseline, 2021
values119
a) Exhaust emissions
Policy
option
Category Petrol Diesel CNG/LPG
Cars and vans
2a
MHEV
 100% Mild hybrid, advanced
calibration, larger TWC,
improved GPF
 Cost per car: €88.0
 Cost per van:€78.2
 100% Mild hybrid,
advanced heating
calibration, larger
EATS, EHC
 Cost per car:
€312.2
 Cost per van:
€455.6
 100% Mild hybrid,
advanced calibration,
larger TWC
 Cost per car: €69.7
 Cost per van: €73.2
PHEV
 80% Plugin hybrid, base
TWC, base GPF
 Cost per vehicle: €0.0
 100% Plugin
hybrid, advanced
heating calibration,
larger EATS, EHC,
turbine bypass
 Cost per car:
€487.2
 Cost per van:
€630.6
 100% Plugin hybrid,
advanced calibration,
larger TWC
 Cost per car: €69.7
 Cost per van: €73.2
 20% Plugin hybrid, advanced
calibration, larger TWC,
improved GPF
 Cost per car: €88.0
 Cost per van: €78.2
2b
MHEV
 80% Mild hybrid, advanced
calibration, larger TWC,
improved GPF, 4kW EHC
 Cost per car: €233.8
 Cost per van: €222.8
 20% Mild hybrid,
advanced heating
calibration, larger
EATS, EHC
 Cost per car:
€326.7
 Cost per van:
€473.5
 80% Mild hybrid,
advanced calibration,
larger TWC, improved
GPF, 4kW EHC
 Cost per car: €290.2
 Cost per van: €298.5
 20% Mild hybrid, advanced
calibration, larger TWC,
improved GPF, 4kW EHC,
10s preheating, secondary air
injection, NH3 catalyst
 Cost per car: €334.6
 Cost per van: €320.9
 80% Mild hybrid,
advanced heating
calibration, larger
EATS, EHC,
preheating,
secondary air
injection
 Cost per car:
€404.7
 Cost per van:
€551.5
 20% Mild hybrid,
advanced calibration,
larger TWC, improved
GPF, 4kW EHC, 10s
preheating, secondary air
injection, NH3 catalyst
 Cost per car: €386.1
 Cost per van: €394.5
PHEV
 50% Plugin hybrid, advanced
calibration, larger TWC,
 100% Plugin
hybrid, advanced
 50% Plugin hybrid,
advanced calibration,
119
See footnote 107
61
improved GPF
 Cost per car: €108.8
 Cost per van: €97.8
heating calibration,
larger EATS, EHC,
turbine bypass
 Cost per car:
€501.7
 Cost per van:
€648.5
larger TWC, improved
GPF, 4kW EHC
 Cost per car: €165.2
 Cost per van: €173.5
 30% Plugin hybrid, advanced
calibration, larger TWC,
improved GPF, 4kW EHC
 Cost per car: €233.8
 Cost per van: €222.8
 30% Plugin hybrid,
advanced calibration,
larger TWC, improved
GPF, 4kW EHC
 Cost per car: €290.2
 Cost per van: €298.5
 20% Plugin hybrid, advanced
calibration, larger TWC,
improved GPF, 4kW EHC,
60s preheating, secondary air
injection, NH3 catalyst
 Cost per car: €334.6
 Cost per van: €320.9
 20% Plugin hybrid,
advanced calibration,
larger TWC, improved
GPF, 4kW EHC, 60s
preheating, secondary air
injection, NH3 catalyst
 Cost per car: €386.1
 Cost per van: €394.5
Lorries and buses
2a
-
 50% Advanced
heating calibration,
close-coupled
EATS, twin urea
dosing, optimised
DPF, EGR (w/ cold
SCR)
 Cost per vehicle:
€1 863
 50% Advanced heating
calibration, close-coupled
EATS, optimised
particulate filter, EGR (w/
cold SCR)
 Cost per vehicle: €1 863
 50% Advanced
heating calibration,
close-coupled
EATS, twin urea
dosing, optimised
DPF, EGR (w/ cold
SCR), EHC
 Cost per vehicle :
€2 913
 50% λ=1, advanced
heating calibration, close-
coupled EATS, optimised
particulate filter
 Cost per vehicle: €2 112.7
2b
-
 50% Advanced
heating calibration,
close-coupled
EATS, twin urea
dosing, optimised
DPF, EGR (w/ cold
SCR), burner,
preheating
 Cost per vehicle:
€3 463
 50% Advanced heating
calibration, close-coupled
EATS, optimised
particulate filter, EGR (w/
cold SCR), EHC
 Cost per vehicle: €2 913
 50% Advanced
heating calibration,
close-coupled
EATS, twin urea
dosing, optimised
DPF, EGR (w/ cold
SCR), EHC,
preheating
 Cost per vehicle:
€5 263
 50% λ=1, advanced
heating calibration, close-
coupled EATS, optimised
particulate filter, EHC
 Cost per vehicle: €3 162.7
b) Evaporative emissions
Policy option Emission control technology Hardware cost (€/vehicle)
Evaporative emissions from PI vehicles
2a ORVR canister, anti spitback/vapour seal valve, and a
high flow purge valve
16
2b Higher capacity canister and low permeability fuel tank
and hoses
40
62
c) Non-exhaust emissions
Policy option Emission control technology Hardware cost (€/vehicle)
Brake emissions from cars and vans
2a NAO brake pads – ICE and MHEV 37.5
NAO brake pads – PHEV and BEV 22.5
2b NAO brake pads – ICE and MHEV 37.5
NAO brake pads – PHEV and BEV 22.5
Brake dust particulate filter 160
In contrast to the findings for the hardware costs, the R&D and related calibration costs
including facilities and tooling costs are not expected to differ much between the
different ambition levels. In comparison to the baseline, these costs are estimated to
increase by €115 for PI and €116 for CI cars and vans in PO2a and by €104 for PI and
€112 for CI cars and vans in PO2b. The R&D and related calibration costs per vehicle for
lorries and buses is significantly higher and estimated at €1 245-€1 248 per vehicle in
PO2a and at €1 250-€1 255 in PO2b. This is related to the lower number of produced
vehicles in these segments, in comparison to cars and vans.
Since policy option 2 includes the simplification measures introduced in policy option 1,
the costs savings in the testing and witnessing costs, the type-approval fees and
administrative costs are for the largest share estimated at the same levels as in option 1.
No costs during implementation phase compared to Euro 6/VI are assumed for both
stringency levels and comprehensive real-driving testing.
On the other hand, battery durability requirements would not add any costs because the
level of durability is set to the level already achieved by the average batteries of today
and the costs for the verification are already included in the other tests, i.e. no new test
will be required.
Overall, policy option 2a (Medium Green Ambition) and policy option 2b (High Green
Ambition) are expected to result in a positive impact on European competitiveness in the
automotive sector. Nevertheless, the implementation of stricter emission limits is
expected to increase regulatory cost for automotive industry, to a higher extend in policy
option 2b than in option 2a (see Table 18 and Table 19). Since the regulatory costs in
both sub-options are significantly below the regulatory costs that came with the
introduction of Euro 6/VI and the proposed CO2 emission standards, any negative effect
on competitiveness through the price is expected to be limited. This is in line with the
evaluation of Euro 6/VI which illustrated that costs do not necessarily have a negative
impact on the competitiveness of the EU industry.
Table 22 – Regulatory costs of policy option 2 compared to the baseline in comparison
to average purchase prices per vehicle segment, in 2025 values
Vehicle segment
Regulatory cost per
vehicle ( in €)
Average vehicle
price (in €)
Share of vehicle
price (in %)
Option 2a - medium ambition stricter emission limits and real driving testing boundaries
Cars and vans
PI
Small 144.75 17 281.92 0.84
Medium 159.66 31 293.75 0.51
63
Large 174.58 65 099.78 0.27
Cars and vans
CI
Small 361.32 17 144.19 2.11
Medium 390.16 31 044.35 1.26
Large 428.26 64 580.95 0.66
Lorries Small 2 481.46 79 389.47 3.13
Medium 2 617.10 100 713.53 2.60
Large 2 796.34 151 183.30 1.85
Buses Small 2 328.11 152 198.85 1.53
Medium 2 453.26 185 653.41 1.32
Large 2 618.62 217 376.97 1.20
Option 2b - high ambition stricter emission limits and real driving testing boundaries
Cars and vans
PI
Small 383.86 17 281.92 2.22
Medium 402.39 31 293.75 1.29
Large 420.91 65 099.78 0.65
Cars and vans
CI
Small 483.43 17 144.19 2.82
Medium 511.78 31 044.35 1.65
Large 550.27 64 580.95 0.85
Lorries Small 3 855.85 79 389.47 4.86
Medium 4 082.62 100 713.53 4.05
Large 4 390.38 151 183.30 2.90
Buses Small 3 621.52 152 198.85 2.38
Medium 3 832.92 185 653.41 2.06
Large 4 119.83 217 376.97 1.90
1.3.1.3. Regulatory costs in policy option 3
Policy option 3a considers the introduction of continuous emission monitoring, to control
real-driving emissions throughout the vehicle’s lifetime and in all driving conditions. It is
based on available sensor technologies (see Table 55). In addition, option 3 builds on the
same simplification measures as option 1 to reduce complexity of the Euro 6/VI emission
standards and on more stringent air pollutant emission limits as option 2a and
comprehensive real-driving conditions to provide appropriate and up-to-date limits for all
relevant air pollutants.
On-board monitoring result in regulatory costs, while the simplification measures lead to
the same cost savings as in option 1 and the introduction of strict emission limits based
on available emission control technology lead to the same costs as in option 2a. Table 23
presents the regulatory costs for policy option 3a over those related to the baseline.
64
Table 23 - Regulatory costs for tailpipe and evaporative emissions for automotive
industry in policy option 3a compared to the baseline, in 2025 values120
Cars and vans Lorries and buses
PI CI PI CI
1) Equipment costs
 Hardware costs (emission control and sensor technologies)
Cost per vehicle (€) 128.94 353.93 1 160.56 1 507.41
Total cost (billion €) 5.08 15.97 1.43 7.67
 R&D and related calibration costs including facilities and tooling costs
Cost per vehicle (€) 78.68 104.90 1 334.22 1 332.10
Total cost (billion €) 3.10 4.73 1.65 6.78
2) Costs during implementation phase
 Testing costs (granting type-approval. verification procedures)
Cost per model / engine family
(thousand €)
-3 328.13 -11 630.89 -11 305.62 -4 775.22
Cost per vehicle (€) -31.66 -26.70 -107.64 -50.33
Total cost (million €) -1 246.57 -1 204.83 -132.73 -256.03
 Witnessing costs (by type-approval authorities)
Cost per model / engine family
(thousand €)
-230.11 -776.87 -400.41 -169.12
Cost per vehicle (€) -2.19 -1.78 -3.81 -1.78
Total cost (million €) -86.19 -80.48 -4.70 -9.07
 Type-approval fees. except witnessing costs
Cost per type-approval (thousand
€)
-3.83 -4.19 -1.12 -1.10
Cost per vehicle (€) -0.50 -0.40 -0.79 -0.37
Total cost (million €) -19.56 -18.26 -0.97 -1.88
3) Administrative costs (information provision)
Cost per type-approval (thousand
€)
-204.42 -223.60 -67.35 -66.30
Cost per vehicle (€) -26.49 -21.59 -47.30 -22.12
Total cost (million €) -1 043.14 -974.00 -58.33 -112.50
Total regulatory costs
Total regulatory cost per vehicle
(€)
146.79 408.36 2 335.25 2 764.90
Total regulatory cost until 2050
(NPV in billion € - 2025 values)
5.78 18.43 2.88 14.06
The hardware costs represent recurrent costs arising from the need to install emission
control technologies to comply with strict emission limits as assumed in policy option 2a
(see Table 20) and new sensor technologies for CEM, on vehicles to meet the actions of
policy option 3. For policy option 3a, hardware costs for available NOx, and NH3 and PM
sensor technologies are considered. Moreover, costs for over-the-air (OTA) data
transmission is included, allowing also the possibility of geo-fencing121
. A higher cost for
OTA data transmission is assumed for lorries and buses, due to the higher complexity of
the data monitoring system of a HDV over a car.
120
Supporting Euro 7 impact assessment study, chapter 5.3.2. Economic impacts
121
Geo-fencing puts a vehicle automatically into zero-emission mode depending on its geolocation, in
particular in urban areas.
65
The hardware costs for every vehicle category are estimated to be lower in policy option
3a than in policy option 2b which considers the most stringent set of emission limits. In
other words, the costs for available emission and sensor control technologies are lower
than for best available emission control technology.
In addition, policy option 3a assumes the same hardware costs for brake emissions from
cars and vans as in policy option 2a (see Table 20). That means, policy option 3a €21 per
ICE/MHEV vehicle and €12 per PHEC/BEV vehicle for brake pads.
Table 24 - Assumed control technology packages for policy option 3a and the respective
hardware costs per vehicle for the average vehicle compared to the baseline, 2021
values122
a) Exhaust emissions
Policy
option
Category Petrol Diesel CNG/LPG
Cars and vans
3a
MHEV
 100% Mild hybrid, advanced
calibration, larger TWC,
improved GPF
 Cost per car: €88.0
 Cost per van:€78.2
 100% Mild hybrid,
advanced heating
calibration, larger
EATS, EHC
 Cost per car:
€312.2
 Cost per van:
€455.6
 100% Mild hybrid,
advanced calibration,
larger TWC
 Cost per car: €69.7
 Cost per van: €73.2
PHEV
 80% Plugin hybrid, base
TWC, base GPF
 Cost per vehicle: €0,0
 100% Plugin
hybrid, advanced
heating calibration,
larger EATS,
EHC, turbine
bypass
 Cost per car:
€487.2
 Cost per van:
€630.6
 100% Plugin hybrid,
advanced calibration,
larger TWC
 Cost per car: €69.7
 Cost per van: €73.2
 20% Plugin hybrid, advanced
calibration, larger TWC,
improved GPF
 Cost per car: €88.0
 Cost per van: €78.2
Lorries and buses
3a
-
 50% Advanced
heating calibration,
close-coupled
EATS, twin urea
dosing, optimised
DPF, EGR (w/
cold SCR)
 Cost per vehicle:
€1 863
 50% Advanced heating
calibration, close-coupled
EATS, optimised
particulate filter, EGR (w/
cold SCR)
 Cost per vehicle: €1 863
 50% Advanced
heating calibration,
close-coupled
EATS, twin urea
dosing, optimised
DPF, EGR (w/
cold SCR), EHC
 Cost per vehicle :
€2 913
 50% λ=1, advanced
heating calibration, close-
coupled EATS, optimised
particulate filter
 Cost per vehicle: €2 112.7
b) Evaporative emissions
Policy option Emission control technology Hardware cost (€/vehicle)
Evaporative emissions from PI vehicles
122
See footnote 107
66
3a ORVR canister, anti spitback/vapour seal valve, and a high flow
purge valve, pump system for active leak detection (OBD)
41
c) Non-exhaust emissions
Policy option Emission control technology Hardware cost (€/vehicle)
Brake emissions from cars and vans
3a NAO brake pads – ICE and MHEV 37.5
NAO brake pads – PHEV and BEV 22.5
For lorries and buses, the R&D and the related calibration costs are in general expected
to be higher in policy option 3 than in the previous options. This follows from the fact
that policy option 3 is the most advanced option including the previous options and hence
bundling the R&D costs. For example, the R&D cost for CI lorries and buses is estimated
at €1 051 per vehicle in 3a, in comparison with €992 per vehicle in policy option 2.
A different observation is made for the costs for PI cars and vans, for which the R&D
and related calibration cost were estimated in policy option 2 with €80 per vehicle (due
to the new emission technology introduced for PI vehicles) in comparison to €49 in
policy option 3a. In case of CI cars and vans, the R&D costs and related calibration costs
for policy option 3a are expected to be lower than the costs in option 2. The reason for
this observation is that policy option 3 allows for some cost reductions through a
decreased need for calibration following the introduction of continuous emission
monitoring which makes it no longer necessary to infer emissions for the operation
conditions.
In comparison to the estimates for option 2, the cost savings during implementation
phase in option 3 go further for all three subcategories. This follows from the fact that the
introduction of CEM facilitates the granting of type-approval and verification testing
procedures (see Table 55), in addition to the simplification measures introduced in option
1 (see Table 47). The testing costs for PI cars and vans are estimated to decrease by €28
per vehicle in policy option 3a, compared to €19 per vehicle in policy option 2. Similar
cost savings over policy option 2 are realised for the other vehicle and costs
subcategories during implementation phase. The benefits from simplification of the type-
approval procedure come from the fact that a drop of 30% in the number of necessary
type-approvals is anticipated for policy option 3a. This drop is considered to reflect the
fact that CEM can enable a wider family concept than the current model or engine
family. By verifying a single OBM family, the type-approval authority would not need to
verify all details of the emission control system but ensure that the OBM system
measures and reports correctly.
The cost estimates for the administrative costs follow the same trend as the costs during
implementation phase. The new CEM requirements in policy option 3 are expected to
further simplify the reporting and other information provision obligations for granting
type-approval and verification procedures which leads to cost savings for all vehicle
categories compared to the other policy options.
67
Table 25 – Regulatory costs of policy option 3a compared to the baseline in comparison
to average purchase prices per vehicle segment, in 2025 values
Vehicle segment
Regulatory cost per
vehicle ( in €)
Average vehicle
price (in €)
Share of vehicle
price (in %)
Cars and vans
PI
Small 139.20 17 281.92 0.81
Medium 162.92 31 293.75 0.52
Large 186.64 65 099.78 0.29
Cars and vans
CI
Small 367.80 17 144.19 2.15
Medium 399.06 31 044.35 1.29
Large 440.38 64 580.95 0.68
Lorries Small 2 560.56 79 389.47 3.23
Medium 2 698.66 100 713.53 2.68
Large 2 881.14 151 183.30 1.91
Buses Small 2 380.35 152 198.85 1.56
Medium 2 507.82 185 653.41 1.35
Large 2 676.26 217 376.97 1.23
1.3.2. Cost-benefit analysis
For both the evaluation and the impact assessment, a cost-benefit analysis model was
developed to examine the specific regulatory requirements of the current Euro 6/VI
emission standards or the different policy options for a Euro 7 initiative. The aim of this
analysis is to indicate whether the societal benefits achieved following the past and future
initiatives at least even out the respective societal costs. Societal benefits comprise health
and environmental benefits for citizens and regulatory costs savings (cost savings during
implementation phase and administrative cost savings) for industry which are assumed to
be passed on to citizens, whereas societal costs comprise regulatory costs (equipment
costs) for industry which are also assumed to be passed on to citizens.
The introduction of new vehicle technologies following new policy requirements are
modelled with SIBYL/COPERT31,38
that calculate first the vehicle stock, activity and
energy consumption. Subsequently, these new requirements should have a positive
environmental and health impact through the reduction of total emission levels and
regulatory cost savings through the simplification measures. On the other side, they could
have a negative impact through increasing the regulatory costs. To compare the costs and
benefits, the equivalent monetised health and environmental benefits are calculated by
multiplying the emission savings in kg with the external marginal cost in €/kg for every
investigated pollutant. The costs and benefits are then scaled up to represent the total
regulatory costs and the total health and environmental benefit and total regulatory cost
savings. Finally, the subtraction of the total costs from the total benefit results in the net
benefit. If this number has a positive value, it means that a net benefit is achieved by the
intervention, while a negative value means that a net damage is realised.
The net-present value (NPV) is derived by allocating the cost and benefit to the period of
investigation based on a social discount rate. Following the recommendations from the
Better Regulation Guidelines123
, a social discount rate of 4% has been applied in the
analysis. To take into account the full range of the equivalent monetised benefits, a time
horizon up to 2050 was considered. The considered discount rate results in any benefits
reaching zero in approximately 30 years after the introduction of the new emission
123
European Commission, 2020. Better Regulation Toolbox, Tool #61. The use of discount rates
68
requirements for vehicles. If a higher social discount rate and shorter simulation horizon
was considered, many monetary benefits would have been neglected.
1.3.2.1. Uncertainty
Uncertainty in the cost-benefit analysis was reported for the cost modelling and was due
to the limited cost data received from stakeholders during the public and target
stakeholder consultations and the related follow-up on both Euro 6/VI evaluation and
Euro 7 impact assessment. Due to lessons learnt from the Euro 6/VI evaluation (see
Annex 5, section 4.2), the data collection, including confidential sharing of data by
stakeholders, and validation by key stakeholders of regulatory costs and health and
environmental benefits had a great importance in the impact assessment. The results and
underlying assumptions have been cross-checked with independent experts and the
concerned stakeholders.
The CLOVE consortium, in which key experts from a group of seven independent
research organisations and universities join forces, carried out the studies supporting this
impact assessment. While the Laboratory of Applied Thermodynamics of the Aristotle
University of Thessaloniki (LAT) took the lead on the supporting impact assessment
study, the work was subject to cross-checking between the different institutes. Next to
that, everything has been discussed and verified by experts from the JRC in Ispra
working on sustainable transport. In addition, concerned stakeholders were encouraged to
verify or contest any result or assumptions in the extensive stakeholder consultation.
During the ten official meetings of the Advisory Group on Vehicle Emission Standards
(AGVES), stakeholders (mostly from automotive industry, Member States and NGOs)
were brought up-to-date regularly on the ongoing work and were able to react on the
spot, in written after a meeting or in the next meeting. Feedback received through this
channel was carefully analysed by experts and taken into account if credible. For further
details please see Annex 1 and 2.
All relevant stakeholder groups and JRC experts were requested to validate the CLOVE
cost estimates124
. In addition, relevant datasets from other sources were used to cross-
check the estimates fleet or cost estimates, including the EEA NECD database6
, OECD
statistics125
, the handbook on external costs and emission factors of Road Transport126
and data on structural business statistics from Eurostat127
; additional data on emission
type-approvals from ten type-approval authorities128
and on Euro 6/VI vehicle sales in
the EU-28 from IHS Markit129
. Additionally, CLOVE calculated multiple scenarios for
critical assumptions, such as comparing emission limits for traditional tailpipe and
evaporative emissions versus new brake emissions or normal versus conservative
emission factor approach130
.
Following the validation, remaining uncertainty has been addressed and minimised by
124
Supporting Euro 7 impact assessment study, Table 9-41: Sources and assumptions made per cost
category
125
OECD, 2020. Statistics on Patents –Technology Development Environment
126
European Commission, 2019. Handbook on the external costs of transport
127
Eurostat, 2020. Annual detailed enterprise statistics for industry (NACE Rev. 2, B-E) [sbs_na_ind_r2]
128
Type-approval authorities provided emission type-approval data at the request of the European
Commission
129
IHS Markit, 2021. Provision of data on vehicle sales in the EU-28 for Evaluation of Euro 6/VI vehicle
emission standards
130
Supporting Euro 7 impact assessment study, chapter 6 Comparison of Policy Options
69
assessing the level of confidence for each regulatory cost category and the health and
environmental benefit used in the cost-benefit analysis based on the availability and
quality of information, data and the shared input by stakeholders. The assumed
uncertainty for a high confidence level is at 10%, for a medium-high confidence level
15% and medium confidence level 20% (see Table 26).
While the level of confidence is considered high for costs during implementation phase
and administrative costs, as the costs for testing, witnessing and type-approval is well
known based on granting type-approval and verification procedures by type-approval
authorities, the level of confidence for equipment costs is assessed medium to high. For
R&D costs the upper estimates were based on the responses provided by manufacturers
to the targeted consultations, and the hardware costs for Euro 7 emission control
technologies is well known by CLOVE and JRC experts. The level of confidence for
health and environmental benefits is assessed medium to high, as calculations are based
on best available information on emission savings, including emission factors adjusted to
the policy options by CLOVE and factors to monetise external costs. The concept of
emission factors and external costs was developed by a consortium led by CE Delft for
the Commission’s Handbook on the external costs of transport126
and is used by EU and
national air quality and climate policies for road transport.
Table 26 – Estimated uncertainty for all vehicles in the cost-benefit analysis
Cost category
Level of
confidence
Estimated
uncertainty1
Regulatory costs
1) Equipment costs
Hardware costs (emission control technologies) Medium/high 15%
R&D and related calibration costs including facilities and tooling costs Medium 20%
2) Costs during implementation phase
Testing costs (granting type-approval, verification procedures) High 10%
Witnessing costs (by type-approval authorities) High 10%
Type-approval fees, except witnessing costs High 10%
3) Administrative costs
Administrative costs (information provision) High 10%
Health and environmental benefits Medium/high 15%
In conclusion, the underlying methodology for the cost-benefit analysis is very robust
due to the extensive stakeholder consultation process, the long-standing reputation of the
SIBYL/COPERT models used by the Commission and EEA for pollutant modelling in
EU air quality policies and the medium to high level of confidence level of the
quantitative cost and benefit estimates. The cost-benefit analysis in Table 27 to Table 29
is complemented by providing ranges of expected costs and benefits to make political
choices based on the net benefits and benefit-cost ratios of the policy options for light-
and heavy-duty vehicles.
1.3.2.2. Efficiency of policy option 1-3
In order to assess efficiency of policy options, regulatory costs are compared with the
health and environmental benefit of a reduction of air pollution and regulatory cost
savings by simplification measures. The health and environmental benefit can be
monetised using the concept of external costs, which reflect the damage costs by air
pollution to environment and health, in particular medical treatment costs, production
losses due to illnesses and even deaths. Decreasing pollution leads to a decrease of
damage hence to an overall benefit. The results of this assessment (as net benefits i.e. the
70
difference between the present value of the benefits and costs and as benefit-cost ratio
(BCR)) is presented for tailpipe and evaporative emissions in Table 27. For
methodological reasons and for clarity purposes, the focus of the efficiency assessment
is on net benefits which are an indicator of the attractiveness of an option in absolute
terms (thus the larger the difference between benefits and costs, the better) and do not
bias the results for low-cost options, compared to the BCR.
The BCR gets disproportionally high when costs are low (see PO1 in Table 27 and Table
29) which gives an unjustified advantage to low-cost options and has the potential to
mislead policy makers. Moreover, the BCR is independent form the scale of options
considered, which contradicts the necessity to consider in absolute terms the regulatory
costs and environmental and health benefits of reducing air pollutants. The BCR is
therefore disregarded to choose one option and is included in the efficiency tables of the
Annexes for completeness purposes only.
Table 27 – Assessment of efficiency of policy options for tailpipe and evaporative
emissions compared to baseline*, 2025-2050, Introduction of Euro 7 in 2025, Data
source: SIBYL/COPERT 2021
Policy option
1 – Low Green
Ambition
2a – Medium
Green Ambition
2b – High Green
Ambition
3a – 2a and
Medium Digital
Ambition
Cars and vans
Net benefits 2025 NPV
(billion €)
17.33±2.23 21.25±2.55 16.58±1.82 21.64±2.61
Net benefits 2025 NPV
(€/ vehicle)
205.03±27.19 251.38±30.27 196.15±21.58 256.11±31.02
Benefit-cost-ratio** 3.0
(2.2-4.1)
1.8
(1.3-2.5)
1.4
(1.1-1.9)
1.7
(1.3-2.4)
Lorries and buses
Net benefits 2025 NPV
(billion €)
20.86±3.08 116.10±17.00 108.36±15.84 116.64±17.03
Net benefits 2025 NPV
(€/vehicle)
3 301.84±487.15 18 371.33
±2 690.29
17 145.63
±2 506.19
18 440.82
±2 694.87
Benefit-cost-ratio** 33.1
(23.5-47.5)
7.9
(5.7-11.0)
5.2
(3.8-7.1)
7.7
(5.5-10.7)
* The baseline considers an end-date of combustion-engine cars/vans in 2035, see chapter 5.1.
** The benefit-cost ratio gets disproportionally high when costs are low which gives an unjustified
advantage to low-cost options (i.e. PO1) and has the potential to mislead policy makers. The benefit-cost
ratio is disregarded to choose one option based on benefits and costs in absolute terms only and included
in this table for completeness purposes only.
In addition to tailpipe and evaporative emissions, policy options 2 and 3 introduce limits
for brake emissions from new vehicles. Brake wear has been recognized as the leading
source of non-exhaust particles which are harmful to human health and emitted by all
types of vehicles. Progress has been made in developing a measurement method in the
GRPE Particle Measurement Programme for cars and vans131
, while the technologies to
decrease brake emissions are already in the market or close to becoming commercial.
While the brake emission limit of 7 mg/km in policy option 2a and 3a can be realised
using better brake pad material, the stricter limit of 5 mg/km in policy option 2b and 3b
require also a brake filter for the collection of the brake wear particles produced. As
shown in Table 28 the use of brake filters is not cost-efficient (negative net benefits as
131
https://wiki.unece.org/display/trans/PMP+Workshop+on+Brake+Emissions++Regulation
71
costs are higher than benefits), resulting in significant decrease of the net benefits of
policy option 2b and 3b for total emissions of vehicles (tailpipe, evaporative and brake
emissions), as shown in Table 29. This may change in the future, once the brake filters
become a more mature technology, and are also be applied for heavy-duty.
Table 28 – Assessment of efficiency of policy options for brake emissions of vehicles
compared to baseline*, 2025-2050, Introduction of Euro 7 in 2025, Data source:
SIBYL/COPERT 2021
Policy option
1 – Low Green
Ambition
2a – Medium
Green Ambition
2b – High Green
Ambition
3a – 2a and
Medium Digital
Ambition
Brake emission limit - 7 mg/km 5 mg/km 7 mg/km
Cars and vans
Net benefits 2025 NPV
(billion €)
- 3.30±0.50 -15.24±2.29 3.30±0.50
Net benefits 2025 NPV
(€/ vehicle)
- 8.34±1.25 -38.48±5.77 8.34±1.25
Benefit-cost ratio
-
1.5
(1.1-2.0)
0.5
(0.4-0.7)
1.5
(1.1-2.0)
* The baseline considers an end-date of combustion-engine cars/vans in 2035, see chapter 5.1.
Table 29 – Assessment of efficiency of policy options for total emissions of vehicles
(tailpipe, evaporative, brake) compared to baseline*, 2025-2050, Introduction of Euro 7
in 2025, Data source: SIBYL/COPERT 2021
Policy option
1 – Low Green
Ambition
2a – Medium
Green Ambition
2b – High
Green Ambition
3a – 2a and
Medium Digital
Ambition
Cars and vans
Net benefits 2025 NPV
(billion €)
17.33±2.23 24.55±3.05 1.34±0.47 24.94±3.11
Net benefits 2025 NPV
(€/ vehicle)
205.03±27.19 259.72±31.52 157.67±15.81 264.45±32.27
Benefit-cost ratio** 3.0
(2.2-4.1)
1.7
(1.3-2.4)
1.0
(0.8-1.4)
1.7
(1.3-2.3)
Lorries and buses
Net benefits 2025 NPV
(billion €)
20.86±3.08 116.10±17.00 108.36±15.84 116.64±17.03
Net benefits 2025 NPV
(€/vehicle)
3 301.84±487.15 18 371.33
±2 690.29
17 145.63
±2 506.19
18 440.82
±2 694.87
Benefit-cost ratio** 33.1
(23.5-47.5)
7.9
(5.7-11.0)
5.2
(3.8-7.1)
7.7
(5.5-10.7)
* The baseline considers an end-date of combustion-engine cars/vans in 2035, see chapter 5.1.
** The benefit-cost ratio gets disproportionally high when costs are low which gives an unjustified
advantage to low-cost options (i.e. PO1) and has the potential to mislead policy makers. The benefit-cost
ratio is disregarded to choose one option based on benefits and costs in absolute terms only and included
in this table for completeness purposes only.
1.4. Methods for other direct and indirect economic and social impacts
Next to environmental benefits and economic costs discussed above, other direct and
indirect impacts should be considered. This is especially relevant for economic and social
impacts. Hence, this section focusses on the assessment of:
 General macro-economic indicators, such as creation of new jobs, skills required,
research and innovation, etc.;
 Competitiveness of the EU industry and internal market cohesion;
72
 Qualitative impacts on SMEs and consumers (incl. consumer trust).
Key information, data and findings from the different tasks in the supporting Part A and
Part B studies by CLOVE was used as the basis for the assessment of these socio-
economic impacts of the Euro 6/V emission standards and the different policy options in
Euro 7. Next to that, findings from relevant impact assessments or evaluations on similar
topics (i.e. air quality and road transport) provided key insights and evidence on how past
regulatory proposals and initiatives were projected to impact the social and economic
dimensions allowing for direct comparisons and assumption in the context of Euro 6/VI
and Euro 7. In parallel, an extensive literature review was conducted to find relevant
scientific and consultant studies which focus on assessing the impact of new
developments regarding technology, regulations, global markets, EU environmental
policy, and how they affect the key elements identified above.
An important source of information for evaluating the socio-economic impacts in both
the impact assessment and evaluation were the views of the different stakeholder groups
collected through the extensive stakeholder consultation. While input from manufacturers
and suppliers in the automotive industry were mostly crucial for assessing the impact on
competitiveness, SMEs, employment and skills, the views from civil society were
essential for assessing consumer trust and affordability for consumers.
In the impact assessment on Euro 7, matrices were created in order to compare
quantifiable impacts on a custom scale for the different policy options and identify the
most important topic areas. The scaling format in the assessment matrices includes both
negative and positive values, as the nature of the impacts – being positive or negative –
might be different for the different policy options and impacts. The quantifiable impacts
and the scores are summarized in Table 30. All impacts are expressed on a relative scale
to compare the different policy options to each other, with ‘+++’ assumed to correspond
to the maximum positive impact that any policy option can offer and “---” corresponding
to the maximum negative impact.
Table 30 – Scores for economic, environmental and social impacts 132
Impact Score Interpretation
High negative impact ---
High negative impact is considered when a negative impact is
expected that could fundamentally change the concerned criterion.
Moderate negative
impact
--
Moderate negative impact is considered when a negative effect that
can clearly be felt is expected, but is not to an extent that can
completely change the criterion concerned.
Low negative impact -
Low negative impact is considered when a visible negative impact on
the criterion is expected but not to an extent that would significantly
change the area.
No impact 0
No impact is considered when no real differences are expected in the
concerned criterion.
Low positive impact +
Low positive impact is considered when a visible positive impact on
the criterion is expected but not to an extent that would significantly
change the area.
Moderate positive
impacts
++
Moderate positive impact is considered when a positive effect that can
clearly be felt is expected, but is not to an extent that can completely
change the criterion concerned.
High positive impacts +++ High positive impact is considered when a positive impact is expected
132
Supporting Euro 7 impact assessment study, Annex 1: Analytical methods, 9.7 Other direct and indirect
economic, environmental and social impacts
73
that could fundamentally change the concerned criterion.
1.4.1. Competitiveness: Export of EU motor vehicles to key destinations
For the assessment of the impacts on competitiveness, the EU export of vehicles and the
key destinations are further analysed in this section.
Table 31 illustrates how the car segment is the most crucial part of the EU-27 exports and
trade surplus in the automobile trade. In 2019, €140.3 billion out of the €156.5 billion
(i.e. 90%) earned by EU vehicle manufacturers in third countries was actually generated
in this segment. Figure 12 illustrates that the United Kingdom, the United States and
China represent the two biggest export markets for the EU automotive industry with 1.3,
0.8 and 0.4 million cars exported to the UK, the US and China respectively, resulting in
exported in 2019 to the US and China respectively, resulting in €84 billion.133
Next to
China, East Asian countries Japan and South-Korea made up for a smaller 5 and 4
percent of the EU-27 export in cars in 2019. Also Norway, Switzerland and Turkey are
important destinations for EU car exports.
Table 31 – EU-27 motor vehicle trade by vehicle type in 2019 (in billion €)134
Cars Vans Lorries and buses Total
EU exports 140.3 7.6 8.6 156.5
Trade balance 71.2 2.2 5.8 85.2
Figure 12 – EU-27 passenger car exports, top 10 destinations (by value) in 2019 (total =
€140.3 billion135
)
133
ACEA, 2021. EU passenger car exports, top 10 destinations (by value)
134
ACEA, 2020. EU motor vehicle trade, by vehicle type
135
See footnote 133
74
Figure 13 – EU-27 motor vehicle (i.e. cars, vans, lorries and buses) exports, top 10
destinations (by value) in 2019 (total = €156.5 billion) 136
Comparing the key destinations for EU cars exports to the key destinations of EU motor
vehicles which also takes into account the values of the exports of vans, lorries and
buses, only minimal differences are found (Figure 13). This is largely explained by the
important share of cars in the trade numbers for the EU. Still, the share of exports to the
US and China decreases somewhat, while exports to the UK, Norway and the rest of the
world increases when looking into trade of all vehicle segments. Taking into account that
the rest category also includes other EFTA countries and Eastern Europe, exports appear
to be slightly more focussed on closer markets when also considering the larger vehicle
segments.
Through further analysis of the ‘rest of the world’ category, it is found that in 2019 the
EU-27 and the United Kingdom exported close to 7% of motor vehicles to the African
continent.137
However, this percentage is mainly due to the export of new EU motor
vehicles to South-Africa (1.5%) and countries in North Africa, e.g. Morocco (1.1%),
Egypt (0.9%), Algeria (0.7%) and Tunisia (0.4%). For the other African countries, the
export of used vehicles is relatively more important. A report of the United Nations
Environment Programme138
found that in 2018 alone, the EU exported over 1 million
used cars and vans to African countries, while more than 60% of vehicles added to their
fleet annually is through the imports of used vehicles.139
In addition, several of the manufacturers of lorries and buses operating in the EU have
also had a strong presence in the US market, in particular Daimler, PACCAR and
Volvo.140
However, in the Chinese and Asia Pacific markets this is less the case. These
markets are dominated mainly by domestic manufacturers141
, although some EU
companies such as Daimler and Volvo have joint agreements in place in these regions,
136
ACEA, 2021. EU motor vehicle exports, top 10 destinations (by value).
137
Eurostat, 2021. Extra-EU trade of machinery and transport equipment (SITC 7) by partner
[EXT_LT_MAINMACH]
138
UNEP, 2020. Global Trade in Used Vehicles Report
139
See Annex 8: Alternative set of assumptions on emission limits and durability for more details
140
ICCT, 2015. Overview of the heavy-duty vehicle market and CO2 emissions in the European Union
141
Roland Berger, 2017. Truck and trailer components – Success factors for suppliers in specialized
markets
75
which are securing them market access.142
Trade partners that are currently of somewhat less importance for the EU when it comes
to trade of vehicles, but are expected to become more relevant in the near future include
India and the ASEAN countries. The vehicle fleet in these countries has so far been
relatively small in comparison to their respective populations. For example, in 2019 only
18 out of 1 000 Indians own a car, compared with nearly 500 in the European Union.143
However, these fleets are growing rapidly, creating growth potential for European
manufacturers144
.
Most of these trade partners have adopted rules of vehicle emissions that are in line with
or more ambitious than the current Euro 6/VI vehicle emission standards. In addition,
key markets China and the United States plan more demanding vehicle emission
standards. While the China 6b emission standards for cars/vans (applicable in 2023), are
already fuel-neutral and 40 to 50% more stringent than Euro 6/VI limits145
, China is
progressing with an ambitious China 7 emission standards146
. Also the US who has in
place emission limits already well below the limits for almost all Euro 6 pollutants (Tier
3 Bin 30)147
is currently working on a proposal for more stringent emission rules148
. In
August 2021, President Biden issued an Executive Order with the objective of making
the US leader on clean and efficient cars and lorries by making 50% of all new passenger
cars and light lorries battery electric, plug-in hybrid electric or fuel cell electric
vehicles.149
Under this Executive Order “the Administrator of the Environmental
Protection Agency (EPA) shall, as appropriate and consistent with applicable law,
consider beginning work on a rulemaking under the Clean Air Act […] to establish new
multi-pollutant emissions standards, including for greenhouse gas emissions, for light-
and medium-duty vehicles beginning with model year 2027 and extending through and
including at least model year 2030.” For heavy-duty vehicles, the order imposes the EPA
to establish new oxides of nitrogen standards for vehicles with the same model years.
Hence, global pressure to reduce transport emissions intensifies.
Japan's emission control requirements for vehicles are the strictest in Asia.150
Other
Asian trade partners have been following the Euro standards to mitigate vehicle pollutant
emissions on their territory. South Korea has been following the European precedent for
diesel vehicle emission standards since 2002 and the Euro 6 standard entered into force
in 2020151
. Since India is grappling with high pollution levels, it has adopted Euro 6
equivalent emission standards in 2020. In addition, ASEAN countries have adopted
emission requirements based on the EU and Japanese rules. However, the specific Euro
142
SWD(2018) 185 final Commission Staff Working Document, Impact Assessment on setting CO2
emission performance standards for new heavy-duty vehicles: For example, Daimler holds a 90% stake in
the Japanese company Fuso, which has a 24% share of the Asia-Pacific market
143
Automotive News Europe, 2019. Why cracking India’s booming car market is not so simple
144
Automotive News Europe, 2020. Mercedes, BMW, others fear parts-rule hit in India
145
CLOVE, 2022. Technical studies for the development of Euro 7. Testing, Pollutants and Emission
Limits. ISBN 978-92-76-56406-5.
146
European Commission – JRC, 2021. Sino-EU Workshop on New Emissions Standards and Regulations
for Motor Vehicles
147
ICCT, 2019. Recommendations for post-Euro 6 standards for light-duty vehicles in the European Union
148
The Wall Street Journal, 2021. Biden Administration Moves to Unwind Trump Auto-Emissions Policy
149
The White House Briefing Room, 2021. Executive Order on Strengthening American Leadership in
Clean Cars and Trucks (August 05 2021)
150
ICCT, 2021. Japan
151
Transport Policy, 2021. South Korea: Light-duty emissions
76
standard differs between the different nations with ASEAN standards ranging from Euro
1/I to Euro 6/VI.152
Singapore is the clear frontrunner, having already implemented Euro
6/VI in 2018.153
Norway, Switzerland, Turkey and the United Kingdom are all currently following the EU
rules regarding the air pollutant emissions from vehicles. As member of the European
Economic Area (EEA), Norway is obliged to implement the current and future Euro
vehicle emission standards to ensure the functioning of the Single Market. Since
Switzerland participates in the EU vehicle market, it has also adopted the EU legislation
on vehicle emission standards. Turkey, who is a member of the EU Customs Union, but
not of EEA or EFTA, is required to enforce rules on competition, product and
environment that are equivalent to those in the EU in areas where it has access to the EU
market. For the United Kingdom, a future mutual agreement shall have the ambition to
continue the implementation of any future Euro standards in the country.154
1.5. Cumulative impacts on consumers, employment and industry
competitiveness
1.5.1. Introduction
A Euro 7 emission standard for new vehicles would not stand alone, but would instead
interact with other policies. The revised CO2 emission standards for cars and vans155
–
presented on 14 July 2021 – are of particular relevance in this context. The proposed CO2
emissions standards for cars and vans will accelerate the transition to zero-emission
mobility by requiring average CO2 emissions to come down by 55% for new cars and by
50% for new vans in 2030 (compared to 2021 levels) and by 100% for both categories in
2035. As a result, all new cars and vans registered as of 2035 should be zero-emission.
The CO2 standards affect the European vehicle fleet and subsequently result in economic,
environmental and social impacts. While most economic or social impacts associated
with the policy options introduced in Chapter 5 are in most cases expected to be limited
on their own, the cumulative impact – taking into account the effects of the CO2
standards – could be more extensive. This section will dive into such impacts on
consumers, employment and industry competitiveness.
Since the recently proposed CO2 standards only have implications for cars and vans and a
revision of the CO2 standards for heavy-duty vehicles156
is only planned for 2022, this
assessment will focus on the cumulative impacts in the cars and vans segments.
Similarly, a revision of the Ambient Air Quality Directive is only planned for 2022,
hence cumulative impacts through more local actions taken at Member State level such
as city bans cannot be quantified yet. Still, an ambitious Euro 7 (and CO2 standards) will
help Member States meet current and future air quality targets (especially for NOx and
PM2.5) and will contribute to the long-term reductions of these pollutants required by
NECD.
152
Fuels and lubes Magazine, 2019. ASEAN: a roadmap to Euro VI.
153
Dieselnet, 2021. Standards: Singapore
154
Institut for Government, 2020. Brexit Brief. Options for the UK’s future trade relationship with the EU
155
COM(2021) 556 final. Proposal for a Regulation amending Regulation (EU) 2019/631 as regards
strengthening the CO2 emission performance standards for new passenger cars and new light commercial
vehicles in line with the Union’s increased climate ambition
156
Regulation (EU) 2019/1242 CO2 emission performance standards for new heavy-duty vehicles
77
The CO2 impact assessment157
looked into the net savings (i.e. net benefits) over the
vehicle lifetime from a societal perspective for different CO2 target level (TL) scenarios
taking into account other policies including strengthening of the EU ETS (the possible
emissions trading for buildings and road transport), the increased use of renewable fuels
in road transport required under the Renewable Energy Directive and Euro 7 based on
preliminary assumptions close to the current PO2a. Scenario TL_High, which is the
closest scenario to the final adopted CO2 proposal, in Figure 14 presents the results of the
analysis for vehicles registered in 2030, 2035 and 2040. As a point of comparison, the
same scenario in Figure 15 shows the net savings resulting solely from the CO2 emission
standards.
The figures illustrate that the average net savings of the TL_High scenario decrease when
considering the cumulative impacts with Euro 7 and other policies, while still remaining
positive. The CO2 impact assessment indicated that the results in Figure 14 are primarily
driven by a decrease in the energy savings due to higher electricity and fuel prices158
following the revised EU ETS and Renewable Energy Directive and by an increase in
avoided CO2 emissions due to the combination of the policies.159
Figure 14 - Average net savings over the vehicle lifetime from a societal perspective
(EUR/vehicle) resulting from the combination of policies (cars (l) and vans (r)) (see
scenario TL_High)160
157
SWD(2021) 613 final, Commission Staff Working Document, Impact Assessment, Accompanying the
document Proposal for a Regulation amending Regulation (EU) 2019/631 as regards strengthening the CO2
emission performance standards for new passenger cars and new light commercial vehicles in line with the
Union’s increased climate ambition
158
Where the Euro 7 impact assessment considers the regulatory costs of manufacturing and type-
approving a new vehicle regarding pollutant emissions, the CO2 impact assessment analysed the total cost
of ownership also taking into account possible fuel savings for consumers which are not relevant following
more stringent air pollutant emission standards.
159
See footnote 157
160
See footnote 157
78
Figure 15 - Average net savings over the vehicle lifetime from a societal perspective
(EUR/vehicle) resulting from the CO2 emission standards (in a MIX policy scenario
context) (cars (l) and vans (r)) (see scenario TL_High)161
1.5.2. Cumulative impacts on consumers
When considering the impact of a 100% CO2 target for cars and vans in 2035 on
consumers, it is not solely the vehicle prices that are of concern. Since fuel and electricity
savings from the use of zero-emission vehicles are significant for the consumers and
exceed the higher upfront costs of more efficient and zero- and low-emission vehicles,
the newly introduced CO2 emission standards are expected to decrease the total cost of
ownership (TCO) of such vehicles.162
The third column in Table 32 shows the average
net savings in TCO resulting from the CO2 emission standards in Scenario TL_High
from a first end-user perspective163
in considering the first five years of a vehicle’s
lifetime for a new vehicle registered in 2030, 2035 and 2040.
With new internal combustion engine (ICE) cars and vans (including hybrids) still being
introduced in the EU fleet until 2035, it is of interest to assess the effect of the different
Euro 7 policy options on the net savings in TCO achieved through the new CO2
standards. In addition, the two sets of limits introduced for brake emissions in PO2a,
PO2b and PO3a also apply to zero-emission vehicles.164
Therefore, the policy options are
also expected to affect the TCO for cars and vans in 2035 and 2040.
To make the assessment, the total costs of the policy options in 2030, 2035 and 2040165
were split up for cars and vans and divided by the new vehicle registrations expected in
the respective year and segment taking into account the fleet developments. That way,
fleet average costs per vehicle were calculated in line with the approach in the Impact
161
See footnote 157
162
See footnote 157
163
While the CO2 impact assessment also inspects the impacts on the total cost of ownership from the
second user perspective, for this assessment an analysis of the first user perspective is deemed sufficient.
The Euro emission standards mostly affect consumer affordability and the cost of ownership through the
impact on the price of vehicles for first users. Impacts on the second users market will be limited since the
increase is expected to be only a fraction of the price for first users, for all options.
164
As illustrated in Table 20, the costs for including brake pads and filters to bring down harmful brake
emissions is not the same for vehicles that are or are not primarily equipped with an internal combustion
engine. Reason for this being that regenerative braking allows for reaching the brake emission limits at a
lower cost per vehicle for PHEV and EVs.
165
Supporting Impact Assessment Study, chapters 5.1.2, 5.2.2. and 5.3.2. Economic impacts
79
Assessment on CO2. These costs per vehicle were subsequently subtracted from the net
savings achieved by the CO2 standards. The results for all policy options are presented in
Table 32.
Table 32 – Cumulative impact of CO2 standards (Scenario TL_High) and the Euro 7
policy options on the total cost of ownership (TCO) first users of new cars and vans
year vehicle
Net savings in total cost of ownership (TCO) first users of new cars and vans
Only CO2
standards166
CO2 standards
and PO1
CO2 standards
and PO2a
CO2 standards
and PO2b
CO2 standards
and PO3a
2030
€ per car 600 587 486 356 488
€ per van 600 526 342 236 345
2035
€ per car 2 200 2 200 2 185 2 131 2 185
€ per van 4 000 4 000 3 985 3 931 3 985
2040
€ per car 3 100 3 100 3 088 3 043 3 088
€ per van 5 500 5 500 5 488 5 443 5 488
The table shows that the 1.7-2.3% increase in diesel vehicle prices in PO2a, PO2b and
PO3a due to the mounting of pollutant emission control and sensor technology leads for
the consumer to a decrease of the TCO savings from €600 per 2030 car when only the
effect of the CO2 emission standards is taken into account to €356-€488 per 2030 car
when additionally the effect of PO2a, PO2b and PO3a are taken into account. For vans
the decrease in savings is more extensive moving from €600 per 2030 vans to €236-€345
for PO2a, PO2b and PO3a. From 2035 on PO2a, PO2b and PO3a continue to have a
small impact on the TCO for the consumer through the costs associated with complying
with the limits for brake emissions for zero-emission vehicles. In 2035, TCO savings are
expected to decrease from €2 200 per car - when only the effect of the CO2 emission
standards are taken into account - to €2 131-€2 185 - when additionally the effect of
PO2a, PO2b and PO3a are taken into account. For vans, these policy options are
expected to lead to a decrease in TCO savings from €4 000 to €3 931-€3 985 per van.
Following learning effects related to hardware costs (see Annex 4 chapter 1.3), this
impact is expected to further decrease in 2040.
Even though the policy options are expected to decrease the net savings in TCO for first
users of new cars and to a larger extent for new vans, the overall cumulative effect of the
CO2 standards and the large share of policy options is still expected to be positive for the
European consumer.
Considering the high regulatory costs for PO2b and cumulative impacts on consumers
with the CO2 emission standards, PO2a and PO3a are considered most proportionate for
cars and vans to reach the zero-pollution and climate ambition of the European Green
Deal.
1.5.3. Cumulative impacts on employment
In the CO2 impact assessment167
, macro-economic models (i.e. E3ME and GEM-E3)
were used to quantify the impacts of the targets on the wider economy, including
employment. The new CO2 standards for cars and vans were found to positively affect
166
See footnote 157
167
See footnote 157
80
the economic-wide GDP and employment due to the significant sector transformation
from combustion-engine to zero-emission vehicles. The number of jobs are expected to
increase by 39 000 in 2030 (0.02% increase in all relevant sectors) and by 588 000 in
2040 (0.3% increase in all relevant sectors) in Scenario TL_High.168
Since the Euro 7 policy options are generally based on existing technologies that do not
require sector transformation, their impacts on GDP, sectoral output and employment are
expected to be limited. In particular, the average annual additional investments (see also
section 1.5.4) to reach the 100% CO2 target in 2035 are estimated to amount up to €19
billion between 2021 and 2040. The Euro 7 policy options, however, are estimated to
only result in average annual investments of €0.2, €1.2 or €2.4 billion during this same
period (see Table 33 below). Hence, the policy options require investments one to two
orders of magnitude below the investment required for CO2. Since investments of this
size are not likely to have any appreciable macroeconomic impact, the impacts on
employment in Chapter 6 have been evaluated in a qualitative manner.
While PO1 and PO2a are expected to have a neutral impact on employment (i.e. no
appreciable differences are expected), the qualitative assessment in Chapter 6 expected
the more ambitious to have a low positive impact over the period 2025-2050.
Indicatively, a low positive impact in employment was expected to correspond to far less
than 0.1% of jobs concerned. The International Energy Agency has estimated that for
every $1 million investment in ICE car manufacturing 5.2 to 9.2 jobs are created.169
Taking into account that such employment multipliers are usually at the lower side for
more advanced economies170
, the annual investment in 2030 of €1.5 billion for PO3a and
of €2.5 billion for PO2b could approximately lead to 9 161 – 15 269 jobs171
.
Taking into account the estimated positive impact of the CO2 standards and the low
positive impact of PO2b and PO3a, the cumulative impact on the number of jobs in 2030
could be approximated by an increase of 0.024-0.027%. This translates in a total increase
in the number of jobs of 48 161 – 54 269 in 2030.172
Hence, the cumulative impact of
CO2 and the Euro 7 policy options on employment is expected to be limited with positive
impacts mainly seen in the sectors supplying to the automotive sector as well as in the
power sector. Other sectors experience some positive second order effects, e.g. as a result
of overall increased consumer expenditure. Despite this estimated growth in
employment, the impact assessment still foresees a loss in jobs in sectors associated to
the production of internal combustion engines. Therefore, a certain level of reskilling of
workers will be necessary to facilitate the sectoral transition.173
1.5.4. Cumulative impacts on industry
In the context of industry competitiveness, it can be interesting to look into the
cumulative investments to comply both with the 100% CO2 targets for cars and vans in
2035 and the policy options considered for a Euro 7 standard for these vehicles. Table 33
presents additional the average annual investments associated to the new CO2 standards
168
See footnote 157
169
IEA, 2020. Sustainable Recovery World Energy Outlook Special Report: Transport
170
IMF, 2021. The Direct Employment Impact of Public Investment.
171
Considering the EUR/USD exchange rate of 17 August 2021 recorded at 1.1745.
172
These numbers are merely indicative considering the difficulties in modelling macroeconomic impacts
of this magnitude.
173
See footnote 157
81
over the baseline in Scenario TL_High for the period 2021-2030 and 2021-2040 in
billion euro174
as well as the cumulative investments for the CO2 standards and PO1,
PO2a, PO2b and PO3a respectively.
Table 33 - Average annual additional investments over 2021-2030 and 2021-2040 in €
billion (in 2021 values) (Scenario TL_High for CO2 standards) 175
Period 2021-
2030
Period 2021- 2040 % increase of PO on
additional cost 2021-2040
Only CO2 standards176
2.6 19.0 NA
CO2 standards and
PO1
3.0 19.2 1%
CO2 standards and
PO2a
4.6 20.2 7%
CO2 standards and
PO2b
6.2 21.4 13%
CO2 standards and
PO3a
4.6 20.2 7%
The table illustrates that in period 2021-2030 for all policy options, expect for PO1,
similar or higher average annual investments are expected than for meeting the new CO2
targets (€2.6 billion). This can be explained by the fact that most regulatory costs
associated to Euro 7 will occur closely after 2025. For the CO2 standards, on the other
hand, the most stringent target of 100%, will only come into force in 2035.
For 2021-2040, the average annual investments induced by the new CO2 standards
increase to €19 billion. The annual increase of the Euro 7 policy options varies from €0.2
billion for PO1 to €2.4 billion for PO2b, further increasing the annual investments by 1-
13%. In total, the average investments over 2021-2040 increase from €19 billion for the
100% CO2 target in 2035 to €19.2-€21.4 billion when the effect of PO1, PO2a, PO2b and
PO3a are taken into account.
This investment challenge for the automotive sector to reach the climate and zero-
pollution ambition was already recognised in the European Green Deal177
, which stated
that “Delivering additional reductions in emissions is a challenge. It will require massive
public investment and increased efforts to direct private capital towards climate and
environmental action, while avoiding lock-in into unsustainable practices. […] This
upfront investment is also an opportunity to put Europe firmly on a new path of
sustainable and inclusive growth. The European Green Deal will accelerate and underpin
the transition needed in all sectors.” Clear regulatory signals to the automotive sector are
considered crucial for delivering climate and zero-pollution investment decisions.
Another important aspect to assess are the cumulative impacts on international
competitiveness. As cleaner technologies have developed rapidly, new players focusing
on clean vehicles have emerged across the globe, some of which have started entering the
EU market. Policy developments towards have been a key driver for investments in zero-
emission and zero-pollution technologies. Hence, the cumulative investments are
expected to lead to benefits for the competitiveness of the automotive industry in a
context where zero-emission and zero-pollution technologies will be more and more
174
See footnote 157
175
Calculated based on Table 4, Table 6 and Table 9 in Chapter 6
176
See footnote 157
177
COM(2019) 640 final. The European Green Deal
82
demanded on the global market.
Figure 12 (Annex 4 Chapter 1.4.1.) illustrates that after the UK, the United States and
China represent two of the biggest export markets for the EU automotive industry with 1
million and 460 000 cars exported in 2019 to the US and China respectively, resulting in
€59 billion.178
The United States recently re-joined the Paris agreement and currently
works on a proposal for more stringent emission rules. China is progressing with an
ambitious China 7 emission standards and recently pledged to achieve climate neutrality
by 2060. They can be expected to continue to accelerate the deployment of zero-emission
vehicles through regulatory action and to tackle the serious air quality concerns in cities.
Next to China, East Asian countries South-Korea and Japan make up for a smaller 7 and
5 percent of the EU export in cars in 2019. Both countries have proclaimed their
ambitions to cut greenhouse gas emissions in the coming years to achieve carbon
neutrality by 2050.179180
While South Korea has been following the European precedent
for diesel vehicle emission standards since 2002 and the Euro 6 standard entered into
force in 2020181
, Japan's emission control requirements for vehicles are the strictest in
Asia.182
Also Norway, Switzerland, Turkey and, more recently, the United Kingdom are
important destinations for European car exports. In 2019, 2.2 million motor vehicles
(including also heavy-duty vehicles) were exported from the EU-27 to the United
Kingdom, representing 30% of the total EU vehicle exports.183
While these nations have
put together action plans towards battling climate change, all of them follow the current
EU rules regarding the emissions from cars and vans and are expected to continue to do
so (see 1.4.1.).
Trade partners that are currently of somewhat less importance for the Union, but are
expected to become more relevant in the near future for cleaner vehicles include India
and the ASEAN countries. The vehicle fleet in these countries has so far been relatively
small in comparison to their respective populations. However, they are growing rapidly,
making them a possible export destination for European manufacturers. Since India and
most ASEAN countries are grappling with high pollution levels, they have adopted Euro
emission standards. On the other side, nations like India are expected to be slower in
bringing fully electric vehicles to the market considering their higher cost and will
instead focus on compressed natural gas and hybrid vehicles for at least another
decade.143,144
Taking into account all of the above developments, stimulating innovation in zero-
emission technologies as well as in pollutant emission control and sensors technology the
EU would allow access to international markets to be maintained while improving the
competitive position of the EU automotive sector over the baseline.
178
ACEA, 2020. EU passenger car exports, top 10 destinations (by value)
179
AP News, 2021. Japan raises emissions reduction target to 46% by 2030
180
European Parliament Think Tank, 2021. South Korea’s pledge to achieve carbon neutrality by 2050.
181
Transport Policy, 2021. South Korea: Light-duty emissions
182
ICCT, 2021. Japan
183
ACEA, 2020. EU-UK Automobile Trade: Facts and Figures
83
2. BASELINE
Since the Euro 6/VI evaluation and the Euro 7 impact assessment were performed in
parallel, two baselines have been considered to assess on the one hand the achievements
of the current Euro 6/VI standards and on the other hand the impacts of a new initiative.
2.1. Evaluation Baseline
In the Euro 6/VI evaluation (see Annex 5) which covers the time period 2013/2014 until
2050, the proposed baseline represents what would have happened in the absence of the
intervention. Without the introduction of Euro 6/VI emission standards, the previous
emission standards – Euro 5 for cars and vans; and Euro V for lorries and buses – would
have remained in place (see Annex 5, Table 35).184
More specifically, the following
assumptions were made in the evaluation baseline185
:
For cars and vans, the baseline assumes that Euro 5 standards would remain in place and
that, in the absence of the Euro 6 intervention, there would have been no further changes
to pollutant emissions limits for new vehicles and no further changes to the relevant
testing procedures.
However, the evaluation analysis also examined a second Euro 6 pre-RDE baseline for
cars and vans. Considering the specific implications of the stepwise process of the Euro 6
implementation and, in particular, the significant changes to the testing procedures
introduced with the adoption of RDE testing in the wake of Dieselgate, this second
baseline reflects the evolution of the legal framework up to the point of the introduction
of RDE testing. Hence, the Euro 6 pre-RDE baseline corresponds to the Euro 6b/c
standards and assumes that RDE testing would not have been introduced. Therefore, the
analysis examines the impacts that are only associated with the introduction of RDE
testing in Euro 6d(-temp).
For lorries and buses, the continuation of the Euro V standard is assumed. As such, the
assumption is that there would be no further changes to the emission limits or testing
requirements. All new lorries or buses entering the market after 2013 would be Euro V
vehicles. In this case, no additional changes to the testing procedures are considered as
part of the baseline.
Next to the assumptions related to the Euro standards, the evaluation baseline considers
the following key policy developments:
 CO2 standards for cars and vans (Regulation (EC) No 433/2009 and (EU) No
510/2011, both since 1 January 2020 repealed and replaced by Regulation (EU)
2019/631) and for heavy-duty vehicles (Regulation (EU) 2019/1242). This
development has led to the adoption of new technologies to achieve fuel efficiency
and the reduction of greenhouse gas emissions. Hence, these standards are assumed
to have affected the share of new diesel vehicles and the vehicle fleet in general.
 Relevant national policies, for instance on the development of low-emission zones
(LEZ). In the baseline it is assumed that LEZs would have been based on the most
recent standard, which would have been Euro 5/V in the absence of Euro 6/VI.
184
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 2.6 Baseline definition
and point of comparison.
185
See footnote 184.
84
The baseline for the evaluation makes the assumption that in the absence of the Euro
6/VI emission standards, vehicle manufacturers would not have introduced technologies
to decrease pollutant emissions beyond what was required in the Euro 5/VI standards.
Considering the cost of emission control technologies, supported by evidence gathered
during the Dieselgate, it is not expected that any of the external trends would have
resulted in manufacturers voluntarily adopting additional technologies. In contrast to the
CO2 emissions standards where fuel efficiency represents a possible purchase criterion
for consumers, differences in the pollutant emissions levels are not expected to
significantly drive consumer choices.
Next to its impact on policy developments, Dieselgate is also assumed to have had an
impact on consumer awareness in the baseline, especially when it comes to pollution
resulting from diesel vehicles. Between 2015 and 2018, the share of diesels sold in the
EU (as a percentage of the total market for new passenger cars) declined from 52% to
36%.186
The evolution in the cost of raw materials is also relevant in terms of the costs of
emission control technologies, particularly for precious metals such as palladium or
rhodium which are used in catalytic converters. These raw materials have seen a
significant increase in unit price since 2015, which is also taken into account in the
baseline.
The macroeconomic assumptions for the baseline scenario follow the macroeconomic
trends over the evaluation period. During this time period, the EU experienced a small
but positive growth rate (in the range of 1.5-3% per year)187
following the decline during
the financial crisis. The number of new vehicle registrations also increased on an annual
basis since 2013 following the significant decline in the 2008-2013 period.188
In addition,
the impact of COVID-19 is also included in the baseline and will be further discussed in
Annex 6.
At the time of the adoption of Euro 6/VI, there were significant air quality problems
throughout the EU, especially in urban areas and in densely populated regions. Road
transport was responsible for a significant share of this pollution problem. According to
the Euro 6/VI impact assessments, it contributed to 43% of total NOx emissions, and 27%
of total volatile organic compounds (VOCs) in 2002. In the Euro 5/V evaluation baseline,
however, Euro 6/VI would not have entered into force which means that all new vehicles
entering the market since 2014 (in the case of Euro 6) and 2013 (in the case of Euro VI)
would have continued to be type-approved under the Euro 5/V standards. In the case of
the Euro 6 pre-RDE baseline, Euro 6d(-temp) would not have been adopted, meaning
that all cars and vans entering the market since 2018 would have continued to be type-
approved under Euro 6c.
On the basis of the assumptions for the evaluation baseline, the SIBYL and COPERT
models were used to develop projections of the expected evolution of the key variables in
the baselines, including the evolution of new vehicle registrations and the evolution of
emission factors per Euro standard/step.
The number of new vehicle registrations under Euro 5/V or Euro 6b and its evolution
186
ACEA, 2019. Share of Diesel in New Passenger Cars
187
Eurostat, 2021. Real GDP growth rate - volume [TEC00115]
188
OECD, 2019. Passenger car registrations Total, Percentage change
85
based on the SIBYL model are presented in Figure 16. For cars and vans, the blue curve
represents the number of new registrations under the Euro 5 baseline, while the green
curve represents the registration under the Euro 6 pre-RDE baseline. After 2018, the two
curves converge since the total number of new vehicles registered coincide at that point
in both baselines. The figures show that the number of new diesel and petrol cars and
vans was expected to decline over time as more vehicles with an alternative powertrain
(e.g. electric and hybrid vehicles) will enter the European fleet. This is effect is less for
lorries and buses for which the number of new registrations of traditional vehicles are
projected to remain stable.
The emission factors for each regulated air pollutant are expected to remain the stable
over time (within a margin of error) for each vehicle category. Equation 1 demonstrated
that the values for the emission factors are used to calculate the total emissions of a
specific pollutant by multiplying the values with the number of vehicles in operation and
the annual mileage per vehicle. The emission factors as used in the COPERT model for
both the baseline and the evaluated Euro 6/VI standard are summarized in Table 7 in
section 1.2.189
Figure 16 - Expected evolution in the number of new vehicle registrations under the
Euro 5/V and the Euro 6 pre-RDE baseline190
189
Emission factors for PN are not provided, due to the lack of such data in COPERT and because of the
lack of trustworthy test data.
190
CLOVE, 2022. Euro 6/VI Evaluation Study. Annexes 1:6 ISBN 978-92-76-56522-2. Annex 2:
Development of the baseline scenarios, 9.2.6 Evolution of key pollutants.
86
2.2. Impact Assessment Baseline
The baseline to assess impacts of the policy options takes the following into account: a)
the Euro 6/VI emission standards, b) the impact of COVID-19 on road transport
activity191
and c) the impact of the new 55% (cars) and 50% (vans) CO2 targets by 2030
and 100% CO2 targets for cars and vans by 2035192
and the projected fit-for-55 HDV
fleet evolution to contribute to the 55% net greenhouse gas emission reduction by 2030
and the 2050 climate neutrality objective193
.
The baseline cannot take into account the effect of future potentially more stringent air
quality targets which may trigger more city bans of combustion-engine vehicles and
therefore modify road transport activity or vehicle sales. Such possible effect of future air
quality targets would be difficult to quantify since it will depend on local actions taken at
Member States level and will not be uniformly applied throughout the EU. However, this
additional effect from the planned revision of Ambient Air Quality Directive in 2022 is
estimated limited compared to the effects of CO2 emission standards.
The baseline is a "no policy change" scenario which implies that the relevant EU-level
legislation, addressing air pollutant emissions resulting from road transport will continue
to apply without change. That means that Euro 6/VI applies, taking into account impact
of the CO2 targets for vehicles, including the aforementioned new CO2 targets for
cars/vans, and COVID-19 on road transport activity. It is referred to in chapter 6 as the
baseline.
a) Euro 6/VI emission standards
The provisions laid down in the Euro 6/VI emission standards194
and in particular the air
pollutant emission limits and real-driving testing conditions set out therein are
summarised in Annex 5, Table 34 and 35). This is the relevant EU-level legislation to
reduce air pollutant emissions from road transport in Europe, which is assumed to remain
in force.
Over time fleet renewal would lead to an increased share of Euro 6/VI vehicles in the EU
fleet. As only 20% of cars and vans, and 34% of lorries and buses are type-approved to
Euro 6/VI in 2020, including RDE testing for cars and vans introduced under final Euro
6d step, the benefits of cleaner Euro 6/VI vehicles compared to previous Euro vehicles
will continue to be felt in the next decades on EU road as older vehicles are replaced by
191
Road transport activity is the volume-km driven by vehicles on EU roads and is projected by the
estimated evolution of vehicle sales.
192
A linear interpolation was used for the year 2030 for both the activity and shares of vehicles between
the two existing scenarios in the CO2 Impact Assessment (TL_Med and TL_High), while the TL_High
scenario was used for the year 2035. This approach is the estimated representation of the impact of the
Commission proposal for CO2 targets for cars/vans.
193
For heavy-duty vehicles, the activity and fleet shares of vehicles are based on the SWD(2020) 176 final,
Impact Assessment on Stepping up Europe’s 2030 climate ambition: Investing in a climate-neutral future
for the benefit of our people (part 1) and SWD(2020) 176 final (part 2), supplemented for buses by
CLOVE, 2022.
194
Regulation (EC) No 715/2007 on type-approval of motor vehicles with respect to emissions from light
passenger and commercial vehicles (Euro 5 and Euro 6) and its implementing Regulation (EU) 2017/1151;
Regulation (EC) No 595/2009 on type-approval of motor vehicles and engines with respect to emissions
from heavy-duty vehicles (Euro VI) and its implementing Regulation (EU) No 582/2011
87
these new cleaner vehicles195
.
b) Impact of COVID-19 on automotive industry and of transport activity
The COVID-19 pandemic continues to have significant effects on the automotive sector,
which have the potential to shape the sector for years to come. In the short, the sector has
been affected by the containment measures and other restrictions throughout this period
(e.g. full-scale lockdowns) as well as uncertainty about the future which had an
unprecedented impact on car sales across the EU.
In the first six months of 2020, EU-wide cars and vans production losses due to COVID-
19 related factory shutdowns amounted to more than 3.5 million vehicles, around 20% of
total production in 2019. Following the trend of the EU’s GDP, demand for new
passenger and commercial vehicles dropped by respectively 23.7% (to 9.9 million units)
and 18.9% (to 1.7 million units) in 2020 as a direct result of the pandemic.196
The long-
term effects on the industry will only become clear after the pandemic has come to an
end and will largely depend on the pace of the economic recovery. EU economic activity
is set to pick up again in the first half of 2021197
, but it may remain constrained by virus
containment measures. Similarly, EU automotive manufacturing should continue to
recover in 2021, provided that supply chains remain functional. Demand, however, is
only expected to return to the 2019 levels by 2023.198
Please see Annex 7 for more
details on the impact of COVID-19 on automotive industry.
The baseline takes into account the indirect impact of the COVID-19 pandemic on
vehicle emissions, mostly through its effect on transport activity and fuel consumption.
Estimations from the impact assessment on the 2030 climate target plan199
estimated that
the projected decrease in total fuel consumption of road transport was about 17% in 2020
compared to 2019. In addition, the JRC estimated that between February and April 2020
a total drop in vehicle activity of 60-90% was realised for passenger cars compared to a
15% drop for freight transport.200
Based on this evidence and taking into account the impacts of COVID-19 on GDP201
, the
impact of the pandemic on activity in the different vehicle segments has been estimated
over the time period considered in the baseline. The short-term estimates point to a sharp
activity drop of 15% in 2020, followed by significant recovery in 2021. Nevertheless, by
2030 the pandemic and following crisis are projected to result to a permanent loss in total
activity of 6% compared to the pre-COVID levels. Figure 7 in chapter 5.1 presents the
comparison of the evolution in transport activity taking into account the COVID-19 drop.
Moreover, a decreased transport activity is assumed by promoting public means of
transport over private vehicles and advancing modal shifts to other transport means than
road transport, especially when it comes to passenger transport.202
The total activity for
195
CLOVE, 2022. Euro 6/VI Evaluation Study. ISBN 978-92-76-56398-3, chapter 5.1 Effectiveness,
Evaluation question 1.
196
ACEA, 2021. Press release: Passenger car registrations: -23.7% in 2020; -3.3% in December 2020;
ACEA, 2021. Press release: Commercial vehicle registrations: -18.9% in 2020; -4.2% in December 2020
197
European Commission, 2021. Spring 2021 Economic Forecast: Rolling up sleves
198
BCG, 2020. COVID-19’s Impact on the Automotive Industry
199
SWD(2020) 176 final, Impact Assessment on Stepping up Europe’s 2030 climate ambition: Investing in
a climate-neutral future for the benefit of our people (part 1) and SWD(2020) 176 final (part 2)
200
JRC, 2020. Future of Transport: Update on the economic impacts of COVID-19
201
See footnote 199
202
See footnote 199
88
passenger transport in 2050 is projected to 6.4% lower, whereas the activity levels for
freight transport are not assumed to differ.
c) CO2 emission performance standards
The CO2 emission performance standards203
for light- and heavy-duty vehicles are a
relevant EU-level measure which also reduce air pollutant emissions. This is due to the
increased sales of zero- and low-emission vehicles that are triggered by stringent CO2
targets for light- and heavy-duty vehicles. Battery and fuel cell electric vehicles do not
have tailpipe emissions of air pollutants such as NOx and particles but do emit non-
tailpipe particles from brakes and tyres. Low-emission vehicles, such as plug-in hybrids,
also have less tailpipe air pollutant emissions.
The CO2 targets, including the new CO2 targets proposed for cars/vans and the fit-for-55
projections for heavy-duty vehicles, and their impact on the vehicle fleet, are included in
the Euro 7 baseline. As can be seen in Figure 7 in chapter 5.1, the share of new zero- and
low-emission vehicles in the European vehicle fleet is projected to increase substantially
over time, for light-duty vehicles much faster than for heavy-duty vehicles up to an end-
date of 2035 for placing new combustion-engine cars and vans in the EU market.
203
COM(2021) 556 final. Proposal for a Regulation amending Regulation (EU) 2019/631 as regards
strengthening the CO2 emission performance standards for new passenger cars and new light commercial
vehicles in line with the Union’s increased climate ambition, Regulation (EU) 2019/1242 CO2 emission
performance standards for new heavy-duty vehicles
89