REGULATORY SCRUTINY BOARD OPINION Development of Euro 7/VII emission standards for cars, vans, lorries and buses

EUROPEAN COMMISSION
Brussels, 26.01.2022
SEC(2022) 397 final
REGULATORY SCRUTINY BOARD OPINION
{COM(2022) 586 final}
{SWD(2022) 358 final}
{SWD(2022) 359 final}
{SWD(2022) 360 final}
Development of Euro 7/VII emission standards
for cars, vans, lorries and buses
Offentligt
KOM (2022) 0586 - SEK-dokument
Europaudvalget 2022
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This opinion concerns a draft impact assessment which may differ from the final version.
Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: regulatory-scrutiny-board@ec.europa.eu
EUROPEAN COMMISSION
Regulatory Scrutiny Board
Brussels,
RSB
Opinion
Title: Impact assessment / Development of Euro 7/VII emission standards for cars,
vans, lorries and buses.
Overall 2nd
opinion: POSITIVE WITH RESERVATIONS
(A) Policy context
Road transport is responsible for 39% of harmful nitrogen oxide emissions and 11% of
total particulate matter emissions. Significant efforts have been made over the last four
years to reduce emissions of such air pollutants.
The European Green Deal action plan includes a proposal for more stringent air pollutant
emissions standards for combustion-engine vehicles by 2021.
Following evaluation findings, this initiative aims to revise the existing legislation to
address the complexity of vehicle emission standards, the obsolete vehicle pollutant limits
and the insufficient control of vehicle real-world emissions. The initiative is one measure
aiming to reduce road transport emissions in parallel with several related initiatives
stemming from the Climate Target Plan.
(B) Summary of findings
The Board notes the improvements in the revised report responding to the Board’s
previous opinion.
However, the report still contains significant shortcomings. The Board gives a
positive opinion with reservations because it expects the DG to rectify the following
aspects:
(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.
(2) The rationale behind the revised policy packages is not fully clear.
(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
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enough to narrow the preferred options to one for both segments.
(C) What to improve
(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.
(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.
(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 convingly 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 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.
(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.
The Board notes the estimated costs and benefits of the preferred option(s) in this
initiative, as summarised in the attached quantification tables.
(D) Conclusion
The DG must revise the report in accordance with the Board’s findings before
launching the interservice consultation.
If there are any changes in the choice or design of the preferred option in the final
version of the report, the DG may need to further adjust the attached quantification
tables to reflect this.
Full title Regulation of the European Parliament and of the Council on
the type-approval of motor vehicles and of engines in respect to
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emissions from motor vehicles (Euro 7/VII)
Reference number PLAN/2020/6308
Submitted to RSB on 6 December 2021
Date of RSB meeting Written procedure
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ANNEX: Quantification tables extracted from the draft impact assessment report
The following tables contain information on the costs and benefits of the initiative on
which the Board has given its opinion, as presented above.
If the draft report has been revised in line with the Board’s recommendations, the content
of these tables may be different from those in the final version of the impact assessment
report, as published by the Commission.
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
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
Error!
Reference
source not
found.)
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
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EUROPEAN COMMISSION
Regulatory Scrutiny Board
Brussels,
RSB
Opinion
Title: Impact assessment / Development of Euro 7/VII emission standards for cars,
vans, lorries and buses.
Overall opinion: NEGATIVE
(A) Policy context
Road transport is responsible for 39% of harmful nitrogen oxide emissions and 11% of
total particulate matter emissions. Significant efforts have been made over the last four
years to reduce emissions of such air pollutants.
The European Green Deal action plan includes a proposal for more stringent air pollutant
emissions standards for combustion-engine vehicles by 2021.
Following evaluation findings, this initiative aims to revise the existing legislation to
address the complexity of vehicle emission standards, the obsolete vehicle pollutant limits
and the insufficient control of vehicle real-world emissions. The initiative is one measure
aiming to reduce road transport emissions in parallel with several related initiatives
stemming from the Climate Target Plan.
(B) Summary of findings
The Board notes the additional information provided in advance of the meeting and
commitments to make changes to the report.
However, the Board gives a negative opinion, because the report contains the
following significant shortcomings:
(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.
(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.
(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
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important costs and benefits. It does not sufficiently differentiate between light
and heavy duty vehicles.
(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.
(C) What to improve
(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.
(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.
(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.
(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.
(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.
(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.
Some more technical comments have been sent directly to the author DG.
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(D) Conclusion
The DG must revise the report in accordance with the Board’s findings and resubmit
it for a final RSB opinion.
Full title Regulation of the European Parliament and of the Council on
the type-approval of motor vehicles and of engines in respect to
emissions from motor vehicles (Euro 7/VII)
Reference number PLAN/2020/6308
Submitted to RSB on 10 June 2021
Date of RSB meeting 7 July 2021
Electronically signed on 26/01/2022 10:34 (UTC+01) in accordance with article 11 of Commission Decision C(2020) 4482