COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT on the revision of the Directives of the Roadworthiness package Accompanying the documents Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers, and amending Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union Proposal for a Directive of the European Parliament and of the Council on the registration documents for vehicles and vehicle registration data recorded in national vehicle registers, and repealing Council Directive 1999/37/EC

•EN EN
EUROPEAN
COMMISSION
Brussels, 26.5.2025
SWD(2025) 96 final/2
CORRIGENDUM
This document replaces SWD(2025) 96 final of 24.4.2025
Insertion of the cross-reference to the COM(2025) 180 final
The text shall read as follows:
Roadworthiness package
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
on the revision of the Directives of the Roadworthiness package
Accompanying the documents
Proposal for a Directive of the European Parliament and of the Council amending
Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their
trailers, and amending Directive 2014/47/EU on the technical roadside inspection of the
roadworthiness of commercial vehicles circulating in the Union
Proposal for a Directive of the European Parliament and of the Council on the
registration documents for vehicles and vehicle registration data recorded in national
vehicle registers, and repealing Council Directive 1999/37/EC
{COM(2025) 179 final} - {SEC(2025) 119 final} - {SWD(2025) 97 final} -
{SWD(2025) 98 final} - {SWD(2025) 99 final} - {COM(2025) 180 final}
Offentligt
KOM (2025) 0179 - SWD-dokument
Europaudvalget 2025
I
Table of contents
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT.................................................1
2. PROBLEM DEFINITION.......................................................................................................7
2.1. What is/are the problems?.............................................................................................7
2.2. What are the problem drivers?....................................................................................14
2.3. How likely is the problem to persist? .........................................................................19
3. WHY SHOULD THE EU ACT?...........................................................................................21
3.1. Legal basis ..................................................................................................................21
3.2. Subsidiarity: Necessity of EU action..........................................................................21
3.3. Subsidiarity: Added value of EU action .....................................................................21
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................................................................................26
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? .............................................31
6.1. Economic impacts.......................................................................................................31
6.2. Social impacts.............................................................................................................56
6.3. Environmental impacts ...............................................................................................59
7. HOW DO THE OPTIONS COMPARE? ..............................................................................62
7.1. Effectiveness...............................................................................................................62
7.2. Efficiency....................................................................................................................63
7.3. Coherence ...................................................................................................................65
7.4. Subsidiarity and proportionality .................................................................................66
8. PREFERRED OPTION.........................................................................................................67
8.1. Identification of the preferred policy options and stakeholder views.........................70
8.2. REFIT (simplification and improved efficiency) .......................................................72
8.3. Application of the ‘one in, one out’ approach ............................................................73
9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?....................74
ANNEX 1: PROCEDURAL INFORMATION .............................................................................75
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................80
ANNEX 3: WHO IS AFFECTED AND HOW?..........................................................................100
ANNEX 4: ANALYTICAL METHODS.....................................................................................108
ANNEX 5: COMPETITIVENESS CHECK................................................................................262
ANNEX 6: BACKGROUND ON ROADWORTHINESS LEGISLATION AND PTI
ORGANISATION IN MEMBER STATES.................................................................................265
ANNEX 7: DETAILED DESCRIPTION OF THE RETAINED POLICY MEASURES...........271
ANNEX 8: DISCARDED POLICY MEASURES ......................................................................287
II
ANNEX 9: COMPARISON OF POLICY OPTIONS IN TERMS OF MEETING THE
OBJECTIVES ..............................................................................................................................290
ANNEX 10: SME TEST..............................................................................................................295
ANNEX 11: LINKS BETWEEN THE CONCLUSIONS OF THE EX-POST EVALUATION
AND THE IMPACT ASSESSMENT..........................................................................................298
ANNEX 12: IMPACTS ON FUNDAMENTAL RIGHTS..........................................................300
ANNEX 13: IMPACTS ON THE FUNCTIONING OF THE INTERNAL MARKET AND
COMPETITION...........................................................................................................................302
ANNEX 14: COHERENCE, SUBSIDIARITY AND PROPORTIONALITY (DETAILED
ANALYSIS).................................................................................................................................304
ANNEX 15: MONITORING.......................................................................................................308
ANNEX 16: SYNERGIES WITH OTHER POLICY INSTRUMENTS.....................................310
ANNEX 17: EVALUATION REPORT (SEPARATE DOCUMENT) .......................................313
III
Glossary
Term or acronym Meaning or definition
ADAS Advanced Driver Assistance Systems refer to systems that support the
driver in their primary driving task. These systems can inform or warn
the driver, but also take over (part of) vehicle control.
CARE CARE is a Community database on road crashes resulting in death or
injury (no statistics on damage-only crashes).
CITA International Motor Vehicle Inspection Committee, worldwide
association of authorities and authorised companies active in the field
of vehicle compliance
CO Carbon monoxide: colourless odourless very toxic gas that is formed
as a product of the incomplete combustion of carbon or a carbon
compound. The greatest sources of CO to outdoor air are vehicles or
machinery that burn fossil fuels.
CoC Certificate of Conformity: a statement by a vehicle manufacturer that
the vehicle conforms to EU type-approval requirements.
DPF Diesel Particle Filter, a component designed to remove diesel
particulate matter or soot from the exhaust gas of a diesel engine.
EEA European Environment Agency
ELV End-of-Life Vehicles
EReg Association of European Vehicle and Driver Registration Authorities
EUCARIS European car and driving licence information system
EV Electric vehicle, including battery electric, hybrid electric, and fuel cell
electric vehicles
GSR General Safety Regulation (EU) 2019/2144: type-approval
requirements to ensure the general safety of vehicles and the protection
of vulnerable road users
IV
HDV Heavy-duty vehicle, vehicles above 3.5t maximum permissible laden
mass, including trucks and buses/coaches
HGV Heavy goods vehicle, truck
LDV Light-duty vehicle (i.e., up to 3.5t maximum mass), including cars and
vans (light commercial vehicles, LCVs)
NO2, NOx Nitrogen dioxide, nitrogen oxides, including NO and NO2
NH3 Ammonia, NH3 contributes to acid deposition and eutrophication,
which in turn, can lead to potential changes occurring in soil and water
quality.
OBD A vehicle system that can generate on-board diagnostics. It collects
information from the network of sensors inside the vehicle, which the
OBD can use to regulate car systems or alert the user to problems. A
technician can plug into the OBD port to collect vehicle data and
diagnose problems. Recent models can communicate diagnostic
information over the air.
OBM On-Board Monitoring means a system on board a vehicle that is
capable of detecting and communicating either emission exceedances
or when a vehicle is in zero emission mode, via the OBD port and over
the air.
Plume chasing A new emission testing method used to detect high-emitting vehicles.
Also called mobile remote sensing where a chasing vehicle follows the
target vehicle, typically a truck.
PM(2.5) Particulate matter (with a diameter smaller than 2.5 micrometres
(<2,5 µm)): the emission limits for mass of particulate matter are
regulated by type-approval legislation for light (Euro 5 and Euro 6) as
well as heavy-duty vehicles (Euro VI)
PN Particle number, another measure of air pollution, the emission limits
for PN were introduced in the type-approval regulations from Euro 5b
light vehicles (first registered from 1 January 2013) and from Euro VI
HDVs (first registered from 1 January 2014)
PTI (Directive) Periodic technical inspection (Directive 2014/45/EU on periodic
roadworthiness tests for motor vehicles and their trailers)
V
PTI centre A PTI station, an authorised workshop or larger inspection centre with
one or more PTI lanes
PTI lane Test lanes along which the vehicle advances during the various stages
of PTI
Remote sensing A method that measures the various components of exhaust emissions
of vehicles that pass by the remote sensing device using a light beam
and detectors
RSI (Directive) Roadside inspection (Directive 2014/47/EU on the technical roadside
inspection of the roadworthiness of commercial vehicles circulating in
the Union)
RWP Roadworthiness package: Directive 2014/45/EU, Directive
2014/46/EU amending Directive 1999/37/EC, and Directive
2014/47/EU
SCR Selective Catalytic Reduction is a technology that reduces nitrogen
oxides (NOx) from exhaust gases of diesel engines. It converts NOx
into nitrogen and water vapour and improves fuel economy and the
performance of diesel engines.
SDG (Regulation) Single Digital Gateway (Regulation (EU) 2018/1724) establishing a
single digital gateway to facilitate online access to information,
administrative procedures, and assistance services that citizens and
businesses may need in another EU country
UN SDG United Nations Sustainable Development Goals
VRD (Directive) Vehicle registration documents (Directive 1999/37/EC, as amended by
Directive 2014/46/EU)
1
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT
This Impact Assessment accompanies legislative proposals for the revision of three Directives, collectively
called the Roadworthiness Package (hereinafter the “RWP”):
• Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers (hereinafter
the "Periodic Technical Inspection” or “PTI” Directive)1
;
• Council Directive 1999/37/EC on the registration documents for vehicles as amended by Directive
2014/46/EU (hereinafter the "Vehicle Registration Documents” or “VRD” Directive)2
;
• Directive2014/47/EUonthe technical roadsideinspection ofthe roadworthiness of commercial vehicles
(hereinafter the “Technical Roadside Inspection” or “RSI” Directive)3
.
Road transport plays a vital role in connecting businesses and consumers across the EU, facilitating trade,
and supporting economic growth and employment. It facilitates mobility of people and supports many
industries, such as manufacturing, construction and retail, by providing the means for thetransport ofgoods.
It also plays a critical role in emergency response. In 2021, road freight transport represented 54.3% (1,863
billion tonne-kilometres) of all the goods transported within the EU and was responsible for 87% (4,174
billion passenger-kilometres) of the total passenger transport activity4
. The road transport sector employs
more than 5 million people in the EU, of which 3.3 million work in freight and 1.8 million in passenger
transport. At the same time, it is a source of certain negative impacts that are addressed by various EU and
national transport policies, among which the Roadworthiness Package is a key building block.
Safe vehicles are part of the so-called “Safe System approach”, as presented in the EU Road Safety
Policy Framework 2021-2030 – Next steps towards “Vision Zero” (5
). In this road safety strategy,
the Commission proposed new interim targets of reducing the number of road deaths by 50% between
2020 and 2030 as well as reducing the number of serious injuries by 50% over the same period. The
UN Global Plan for the Decade of Action (6
) released in October 2021, also applying the “Safe
System approach”, promotes the same reduction targets already in place at EU level.
The Safe System approach considers death and serious injury in road collisions as being largely
preventable, while acknowledging that collisions will continue to occur. It takes as a point of
departure the fact that people make mistakes and aims to ensure that such mistakes do not cause
fatalities or serious injuries by acting on five pillars: safe roads and roadsides, safe speeds, safe road
users, safe vehicles, and fast and effective post-crash care, which all contribute to reducing the impact
of crashes. The Roadworthiness Package focuses on the safe vehicle part of this system.
In its Sustainable and Smart Mobility Strategy (7
) of 2020, the Commission reiterated the target of
zero fatalities in all modes of transport by 2050 and announced the revision of the roadworthiness
legislative framework, to ensure the lifetime compliance of vehicles with emission and safety
standards, under Flagship 1 “Boosting the uptake of zero-emission vehicles, renewable & low-carbon
fuels and related infrastructure”. In October 2021, the European Parliament adopted a resolution on
the EU Road Safety Policy Framework 2021-2030 (8
), calling on the Commission to consider, among
1
https://eur-lex.europa.eu/eli/dir/2014/45/oj
2
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A01999L0037-20220324
3
https://eur-lex.europa.eu/eli/dir/2014/47/oj
4
Statistical pocketbook 2023 (europa.eu)
(5
) SWD(2019) 283 final
(6
) Decade of Action - United Nations Sustainable Development
(7
) COM(2020) 789 final
(8
) P9_TA(2021)0407 https://www.europarl.europa.eu/doceo/document/TA-9-2021-0407_EN.pdf
2
others, tightening the roadworthiness test regime and to adapt it to the technical progress in vehicle
safety features.
Road crashes9
represent one of the most significant negative impacts of road transport. The external cost of
crashes represents almost EUR 250 billion per year, i.e., roughly 2% of GDP10
. There were around 20,600
fatal crashes in the EU in 2022, a 3% increase on 2021 as traffic levels recovered after the pandemic. This
represents however 2,200 fewer fatalities (-10%) compared with the pre-pandemic year 2019 (see Figure
1). The EU and UN target is to halve the number of road deaths by 203011
. The main causes of road crashes
are speeding, alcohol/drugs, distracted driving, and various driver errors (such as errors of interpretation or
fatigue). Other causes include the inadequate state or design of infrastructure (slippery surface, insufficient
markings, poor maintenance), and vehicle defects. In the EU, thanks to gradually improving vehicle
technology through EU type-approval rules and a well-developed system of technical inspections to
ascertainvehiclesafetyovertheentirelifetime,theshareofvehicledefects amongthecausesofroad crashes
is now limited to just a few percent12
. However, this also means that avoidable crashes caused by vehicle
defects are still taking place. The Safe System approach requires acting on all these fronts, recognising that
the parts of the entire system – including users, vehicles, infrastructure and emergency response – work
together as an entity13
.
Figure 1: Road fatalities in the EU (2001-2022 and the EU 2030 target)
Air pollutant emissions from road transport have been decreasing ever since the introduction of the first
Euro emission standard over 30 years ago. Although subsequent emission standards gradually reduced the
limits and extended the scope of air pollutants measured, real-life emissions were significantly above the
type-approval limits until recently (i.e. when RDE limits were introduced)14
. Recent remote sensing
campaigns indicate that even some of the newest vehicles exceed legal emission limits15
. According to the
9
In this document we use the term ‘road crash’ and not ‘road accident’. The word accident implies that a car crash
happened through the fault of nobody. On the other hand, the word crash indicates that someone caused the car wreck to
happen, or that someone is at fault. The reality is that it is very rare for a car crash to be just an accident, while many
studies point out the fact that most causes of the accidents are attributable to human error.
10
COM(2020) 789 final, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020SC0331. 1.87%
based on CE Delft et al. (2020), Handbook on the external costs of transport – Version 2019 – 1.1, Publications Office,
https://data.europa.eu/doi/10.2832/51388
11
https://transport.ec.europa.eu/news-events/news/road-safety-eu-fatalities-below-pre-pandemic-levels-progress-
remains-too-slow-2023-02-21_en
12
See Section 2.1.1.
13
European Commission (2020), Directorate-General for Mobility and Transport, Next steps towards ‘Vision Zero’ –
EU road safety policy framework 2021-2030, Publications Office, 2020, https://data.europa.eu/doi/10.2832/391271
14
Real-driving emission (RDE) limits were introduced following the “diesel-gate” scandal: https://single-market-
economy.ec.europa.eu/sectors/automotive-industry/environmental-protection/emissions-automotive-sector_en
15
https://cares-project.eu/cares-open-letters/
3
European Environment Agency (EEA), despite some improvement, air pollution remains the largest
environmental health risk in Europe. Exposure to fine particulate matter (PM) and nitrogen dioxide (NO2)
levels causedjust under300,000prematuredeaths in 2020.Roadtransport is the principal sourceof nitrogen
oxides, responsible for 35.5% of emissions in 2022, and accounts for a significant share of PM emissions
(8.1% of the PM2.5 and 9.5% of the PM10 emissions)16
. In 2022, the Commission proposed17
to revise the
Ambient Air Quality Directives18
which aims to put the EU on a path to achieve zero pollution for air at the
latest by 2050 and sets interim 2030 ambient air quality standards aligned more closely with the updated air
quality guidelines issued by the World Health Organization (WHO)19
for key air pollutants, requiring
enhanced measures to reduce emissions at source.
For noise emissions, EEA indicates that road transport plays the most significant role20
, with 70% of the EU
population living in urban areas and 25% of the population living outside urban areas being exposed to road
traffic noise with an equivalent sound pressure level exceeding 55 dB(A) during daytime21,22
. While a large
part of this can be attributed to the volume of traffic and a few other factors, noise emission levels of
individual vehicles play a key role, too. The permissible sound level of various road vehicles is regulated
by UNECE and EU type-approval legislation23
. However, here again, regulatory limits are not necessarily
respected in real life24
.
Legal context
To address the safety- and nuisance-related defects of vehicles, roadworthiness testing has been in place in
Europe for decades and subject to gradual harmonisation in the Union, with the first set of common rules
adopted in 197625
and last revised in 2014 as part of the RWP. Consecutive revisions gradually extended
the scope of vehicles to be tested, as well as the scope of harmonised rules, including requirements on
roadside inspections and vehicle registration documents to improve enforcement. They further specified
andupdatedtherequiredtestmethods,procedures and related documents to reflecttechnological progress26
.
Today, the PTI Directive requires that Member States carry out periodic technical inspections (PTI) on
most of the vehicles registered in their territory. This covers cars (M1), vans (N1), lorries (N2-N3), buses
(M2-M3), as well as heavy trailers (O3-O4) and high-speed tractors (T with design speed over 40 km/h). It
also covers heavy motorcycles, including tricycles and quadricycles (L3e, L4e, L5e and L7e), equipped
with a combustion engine above 125 cm3
, with certain possibilities for exemptions. The Directive sets out
the minimum content27
and frequency of testing for each vehicle category, except for motorcycles, where
16
National air pollutant emissions data viewer 2005-2022 | European Environment Agency's home page, EEA (2024),
Air Pollution in Europe; 2024 reporting status, https://www.eea.europa.eu/publications/national-emission-reduction-
commitments-directive-2024
17
COM/2022/542 final
18
Directive 2004/107/EC relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic hydrocarbons in ambient
air; Directive 2008/50/EC on ambient air quality and cleaner air for Europe.
19
WHO (2021) WHO Global Air Quality Guidelines.
20
https://www.eea.europa.eu/en/topics/in-depth/noise
21
During night-time, 49% of the EU population living in urban areas and 17% of the population living outside urban
areas are exposed to road traffic noise with an equivalent sound pressure level exceeding 50 dB(A).
22
Noise — European Environment Agency (europa.eu)
23
https://environment.ec.europa.eu/topics/noise/noise-pollution-main-sources_en
24
The UK and France have experimented with roadside trials to monitor excessive vehicle noise: Décret n° 2022-1;
https://www.gov.uk/government/publications/roadside-vehicle-noise-measurement-study-enforcement-and-technology
25
Council Directive 77/143/EEC of 29 December 1976 on the approximation of the laws of the Member States relating
to roadworthiness tests for motor vehicles and their trailers, OJ L 47, 18.2.1977, p. 47–51
26
The evolution of the PTI legislation is illustrated in Annex 6.
27
(0) Identification of the vehicle; (1) Braking equipment; (2) Steering; (3) Visibility; (4) Lighting equipment and parts
of the electrical system; (5) Axles, wheels, tyres, suspension; (6) Chassis and chassis attachments; (7) Other equipment;
(8) Nuisance; (9) Supplementary tests for passenger-carrying vehicles of categories M2 and M3.
4
Member States have a larger room for manoeuvre. Any deficiency found on a vehicle must be categorised
as minor, major or dangerous, with the latter two leading to the suspension of the vehicle’s authorisation to
be used in road traffic. The Directive also sets out minimum requirements as regards the independence of
testing centres and training of inspectors, testing equipment, and the content of the roadworthiness (PTI)
certificate. The validity of that certificate, as well as any other proof of test, must be recognised by Member
States for the purposes of free circulation and re-registration of a vehicle already registered in another
Member State.
The RSI Directive complements the PTI Directive by requiring Member States to carry out roadside
inspections (RSI) on heavy commercial vehicles, i.e., buses, lorries, and their trailers (above 3.5t), with a
target of 5% of the fleet each year. Those inspections must include an initial roadside inspection and, if
deemed necessary by the inspector, a more detailed technical roadside inspection. The scope of those
detailed inspections are the items tested at PTI and it may also include the inspection of cargo securing.
When a major or dangerous deficiency is found during a RSI, the Member State where the inspection took
place must notify the Member State of registration, in order to enforce the repair of the vehicle that has been
suspended from traffic.
Vehicle registration itself is a national competence. The VRD Directive specifies that Member States must
issue registration certificates for vehicles that are subject to registration under their national legislation. It
requires that those certificates be issued in either paper or smart card format. The certificates must contain
a minimum set of mandatory data elements, may contain certain optional data elements, and must be
recognised among Member States for the purpose of re-registration. The Directive requires certain vehicle
data to be registered electronically, including the suspension from traffic following a failed PTI, and the
cancellation of registration where a vehicle has been treated as an end-of-life vehicle in accordance with
Directive 2000/53/EC28
.
The most recent act adopted by the Commission in the area of roadworthiness testing is a recommendation
on particle number (PN) measurement at the periodic technical inspection of diesel vehicles29
. Although
non-binding, the recommendation aims at harmonising the methods of such measurements and the
corresponding pass/fail limit instead of the introduction of various methods at national and regional level.
Similar Commission recommendations on the assessment of defects during roadworthiness testing have
served as basis for the minimum requirements concerning the contents and recommended methods of
testing under the current PTI Directive30
.
Political context
AlthoughthePTI andRSI Directives weremarginally amendedthrough delegated acts31
,to alignthem with
updated vehicle categories intype-approval legislation32
andintroducethetestingof eCall33
at PTI,themain
rules remained the same since 2014. Due to rapid technological progress, some of these rules are however
already outdated. For this reason, the Sustainable and Smart Mobility Strategy34
called for adjustments to
the roadworthiness legislative framework to ensure lifetime compliance of vehicles with emission and
28
https://eur-lex.europa.eu/eli/dir/2000/53/oj
29
https://eur-lex.europa.eu/eli/reco/2023/688/oj
30
https://eur-lex.europa.eu/eli/reco/2010/378/oj
31
https://eur-lex.europa.eu/eli/dir_del/2021/1717/oj and https://eur-lex.europa.eu/eli/dir_del/2021/1716/oj
32
Regulation (EU) No 168/2013; Regulation (EU) No 167/2013; Regulation (EU) No 2018/858
33
https://eur-lex.europa.eu/eli/reg/2015/758/oj
34
COM(2020) 789 final
5
safety standards, thereby contributing to the EU Road Safety policy framework 2021 - 203035
and
supporting the European Green Deal’s objectives.
Roadworthiness inspections of vehicles are fundamental to road safety and to ensure the environmental
performance of vehicles during their lifetime. As a result of stricter safety and emission legislation, vehicles
in the EU have become technically ever more complex. To keep pace with this trend, certain adaptations to
how vehicles are inspected are necessary. In addition, enhanced and more effective EU-wide exchange of
roadworthiness-relevant vehicle data would help better enforcement of the rules, improving the functioning
of the internal market and protecting citizens from fraudulent malpractices, such as odometer tampering36
.
During the last five years, the European Parliament published a number of related reports and studies,
including aresolution ontheimplementationoftheRoadworthiness packageingeneral37
andonthespecific
issue of odometer fraud38
. In these documents, the Parliament pointed at the insufficient decrease in road
fatalities and a massive divergence between Member States, highlighting the importance of independent
inspections in the wake of emission scandal, the issue of odometer tampering, especially cross-border, as
well as the need for further harmonisation of test methods and updates required by the introduction of
advanced driver assistance systems and automated driving features. The Parliament called on the
Commission to consider tightening the test regime by introducing the obligation of additional checks after
reaching a specified mileage for cars used as a taxi or ambulance and for vans, ending the exemption of
motorcycles from PTI and introducing mandatory testing of powered two- and three-wheelers with an
engine below 125 cm3
and light trailers. In the resolution on the specific issue of odometer fraud, the
Parliament drew the attention to the economic and legal significance of odometer fraud in the EU and
requested the Commission to submit a proposal for a legislative framework to prevent odometer fraud.
Synergies with other EU policy instruments
Roadworthiness testing relies on the technical specifications of the vehicles that are harmonised at EU level
and beyond (UNECE39
). Vehicle registration remains a national competence, although it relies on the
Certificate of Conformity also defined in type-approval legislation40
. The most recent and relevant safety-
and emissions-related type-approval regulations are the General Safety Regulation (GSR)41
and the Euro
7 Regulation (EU) 2024/125742
. The GSR requires that, from July 2022, new types of motor vehicles are
equipped with advanced driver assistant systems aimed at reducing the number of fatalities and serious
injuries; these will also be used in automated vehicles. At the time of preparing this impact assessment, it
was expected that the co-legislators would adopt the Euro 7 standards replacing existing emission rules
35
http://eur-lex.europa.eu/resource.html?uri=cellar%3A0e8b694e-59b5-11e8-ab41-
01aa75ed71a1.0003.02/DOC_2&format=PDF
36
An odometer is an instrument measuring the distance travelled by a vehicle. Odometer fraud or tampering is the
disconnection, resetting or alteration of a vehicle’s odometer with the intention to change the number of kilometres
indicated. Both digital and analogue odometers can be tampered with and changed. Many newer vehicles have digital
control units or computers that may allow for the odometer to be replaced or re-programmed using fraudulent software.
37
European Parliament resolution of 27 April 2021 on the implementation report on the road safety aspects of the
Roadworthiness Package (2019/2205(INI)), https://www.europarl.europa.eu/doceo/document/TA-9-2021-0122_EN.pdf
and https://www.europarl.europa.eu/RegData/etudes/STUD/2020/654175/EPRS_STU(2020)654175_EN.pdf
38
European Parliament resolution of 31 May 2018 with recommendations to the Commission on odometer manipulation
in motor vehicles: revision of the EU legal framework: https://www.europarl.europa.eu/doceo/document/TA-8-2018-
0235_EN.html,
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf and
https://www.europarl.europa.eu/RegData/etudes/STUD/2017/602012/IPOL_STU(2017)602012_EN.pdf
39
World Forum for Harmonization of Vehicle Regulations of the United Nations Economic Commission for Europe
40
https://eur-lex.europa.eu/eli/reg/2018/858/oj
41
https://eur-lex.europa.eu/eli/reg/2019/2144/oj
42
Regulation - 2024/1257 - EN - EUR-Lex
6
for cars and vans (Euro 6) and lorries and buses (Euro VI), thus ensuring that new vehicles are cleaner in
real driving conditions and that they remain clean for longer than required by the existing (durability) rules.
However, the actual gains in emissions reduction are likely to be significantly reduced due to the final text
adopted by Council and by the European Parliament. In line with the Council position, the new rules keep
the Euro 6 standard for cars and vans as regards exhaust emissions43,44
. This means that the expected
baseline emission reductions will not materialise, thus increasing the potential impact of roadworthiness
testing in general, and this initiative in particular.
The focus of the RWP is different from the market surveillance legislation mentioned above. Whereas
marketsurveillanceprovisions aimtoensurethat vehiclescontinuetomeettheirtype-approval requirements
when placed on the market and for a limited period thereafter, and so are effectively focusing on the
responsibilities of the manufacturer, the RWP focuses on ensuring that minimum standards are maintained
by owners throughout the lifetime of the vehicle. Also, while market surveillance requires testing a limited
number of vehicles per model, PTI applies to almost all registered vehicles. Thus, the RWP complements
the market surveillance legislation in ensuring road safety and the environmental performance of vehicles
during their lifetime. Applying the best available test methods will also help Member States reach the
stricter air quality standards (limit values for the protection of human health) set by the revised
Ambient Air Quality Directive45
, notably as regards fine particulate matter and nitrogen oxides.
The Commission is also currently working on an initiative on fair and non-discriminatory access to in-
vehicle data46
, which is crucial for technical inspection centres to be able to carry out their daily tasks. That
initiative will include provisions on access to functions and resources, essential for the provision of data-
dependent services in the automotive sector. It will standardise the relevant datasets and ensure effective
non-discriminatory and secure access for aftermarket and mobility services. A range of automotive service
providers, including vehicle repair and inspection companies and authorities have called for an ambitious
Commissionproposal,toensurealevel-playingfieldandunhindered accesstotherelevantin-vehicledata47
.
The revision of the PTI Directive could complement the access to in-vehicle data proposal, through specific
provisions facilitating access to the data necessary for technical inspections. More details on synergies with
other EU policy instruments are provided in Annex 16.
Evaluation of the Roadworthiness Package
The Commission conducted an evaluation of the RWP ‘back-to-back’ with this impact assessment. The
evaluation concluded that the RWP was partially successful in achieving its objectives, contributing to
increased road safety, and helping reducing air pollutant emissions from road transport. Defective vehicles
may still not always be detected, as some categories of vehicles are not subject to PTI or RSI in some
Member States, or the frequency or scope of the testing is not adapted to their higher safety and
environmental risk. The identified weaknesses in the current RWP require the Directives to be adapted, to
address not only current needs but also future challenges. The links between the main conclusions of the
ex-post evaluation and the impact assessment are summarised in Annex 11. The evaluation of the RWP is
annexed to this impact assessment report (Annex 17).
43
https://www.consilium.europa.eu/en/press/press-releases/2023/09/25/euro-7-council-adopts-position-on-emissions-
from-cars-vans-buses-and-trucks/
44
https://eur-lex.europa.eu/eli/reg/2024/1257/oj
45
Directive (EU) 2024/2881 of the European Parliament and of the Council of 23 October 2024 on ambient air quality
and cleaner air for Europe (recast)
46
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-functions-and-
resources_en
47
See e.g. open letter from CITA: https://citainsp.org/wp-content/uploads/2023/03/L2023-006-Data-Act.pdf
7
Sustainable Development Goals
The initiative contributes to Sustainable Development Goal (SDG) 3 (Ensure healthy lives and promote
well-being for all at all ages), including targets 3.6 (halving the number of deaths and injuries from road
traffic accidents) and 3.9 (substantially reduce the number of deaths and illnesses from hazardous chemicals
and air, water and soil pollution and contamination).
2. PROBLEM DEFINITION
The problems, underlying problem drivers and consequences that are relevant for the revision of the
Roadworthiness Package are presented in Figure 2. The evidence underlying the problems and their drivers
is based on the best available evidence, including multiple studies involving scientific research, as well as
thorough consultation with experts.
Figure 2: Problem tree
2.1. What is/are the problems?
2.1.1. Presence of unsafe vehicles on EU roads
Although EU roads are the safest in the world and road safety has improved significantly over the last
decades, casualties of road crashes continue to represent high costs to society. Despite the improvement in
vehicle technology, including active safety and intelligent driver assistance systems in new vehicles, unsafe
vehicles still contribute to crashes, either as the main cause or as a contributing factor. A part of unsafe
vehicles is identified at PTI or RSI (i.e., vehicles with major or dangerous deficiencies). Others may not be
detected either because PTI cannot detect them or because they are not subject to testing. These include
vehicles with safety-related tampering and vehicles with incorrectly secured cargo.
Comparable PTI data on vehicles with major and dangerous deficiencies are only available for ten Member
States.
8
Table 1 shows the share of those vehicles by vehicle type and Member State, as well as the median by
vehicle type. There is great variability between the PTI results of Member States for each vehicle type,
which points to the need to interpret these data with care. A high share of vehicles with major and dangerous
defects may also reflect variation in the stringency with which testing is applied in a particular country and
not necessarily that vehicles are less roadworthy in that country. What is however clear is that the share of
unsafe vehicles is significant in all Member States and for all vehicle types where such data is available.
9
Table 1: Share of vehicles with major and dangerous defects in the vehicle fleet, by vehicle type - averages over
2018-2022
Source: Ricardo et al. (2023), Impact assessment support study
While not even a well-developed roadworthiness testing system can detect every defective vehicle through
PTI or RSI, not all defective vehicles will cause a crash either. Various studies48
indicate that their share as
acontributingfactorofthecauseofcrashes is between 3and19%,dependingonthescopeandmethodology
of the study; for motorcycles, it is 5% to 12% of crashes49
. Since PTI has been in place in Europe for a long
time, there are very few recent studies covering EU Member States50
. There are similar studies from other
parts of the world51
, the most relevant of them being a recent US study52
that looked at the difference in
crash rates between states with and without PTI. It shows that states with a safety inspection, even if only a
very simple one for light vehicles, have 5.5% fewer fatalities on average.
Naturally, older vehicles are prone to more frequent breakdowns, and studies have shown that older
vehicles with defects contribute more to the causes of crashes53
. The situation is not expected to improve
by itself as the contribution of older vehicles is becoming an increasing concern with the gradual ageing of
the vehicle fleet54
. Since cars are responsible for by far the largest share of fatalities (see collision
matrix55
in Figure 3 below), and even if technical defects only represent a relatively small share among
the causes of accidents, early detection of those defects can make a significant difference, especially
in terms of road safety.
48
Martín-delosReyes L.M. et al. (2021), Effect of Periodic Vehicle Inspection on Road Crashes and Injuries: A
Systematic Review, https://doi.org/10.3390/ijerph18126476
49
Ricardo et al. (2023), Impact assessment support study on the directives of the roadworthiness package, Contract no.
MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001
50
Hudec J. and Šarkan B. (2022), Effect of periodic technical inspections of vehicles on traffic accidents in the Slovak
Republic.
51
Schulz W.H. and Scheler S. (2019), Reducing the Death Toll of Road Accidents in Costa Rica through the Introduction
of Roadworthiness Inspections by the Government, available at SSRN: https://ssrn.com/abstract=3420341; Schulz W.H.
and Scheler S. (2020), Getting Ready for Europe: An Empirical Assessment for the Introduction of Periodical Technical
Inspections of Road Vehicles in Turkey, available at SSRN: https://ssrn.com/abstract=3523602
52
https://ascelibrary.org/doi/10.1061/JTEPBS.TEENG-7320
53
https://komunikacie.uniza.sk/artkey/csl-202203-0017_effect-of-periodic-technical-inspections-of-vehicles-on-traffic-
accidents-in-the-slovak-republic.php
54
For the most recent report on the vehicle fleet, see e.g.: https://www.acea.auto/publication/report-vehicles-in-use-
europe-2023/
55
https://transport.ec.europa.eu/background/road-safety-statistics-2022-more-detail_en
Total
M1 (passenger
cars)
N1 (vans; <3.5
tonnes)
N2 (small
lorries;3.5-12
tonnes)
N3 (large
lorries ;>12
tonnes)
M2
(buses/coaches
<5 tonnes)
M3
(buses/coaches
>5 tonnes)
O1 (trailers
<0.75 tonnes)
O2(trailers
0.75-3.5
tonnes)
O3 (trailers
3.5-12 tonnes)
O4 (trailers
>12 tonnes)
L3-L7
(motorcycles)
AT 11% 8% 11% 11% 10% 3% 4% 8% 10% 5%
DE 21% 25% 26% 26% 16% 16% 14% 14% 14% 14% 8%
DK 19% 15% 15% 16% 16% 8% 8% 20% 20%
ES 18% 24% 30% 30% 26% 26% 26% 26% 26% 26% 18%
FR 20% 24% 15% 15% 14% 15% 16% 13%
HR 22% 28% 33% 22% 35% 25% 14% 11% 13% 16% 10%
LT 48% 50% 52% 43% 55% 48% 24% 24% 34% 34% 35%
LV 38% 44% 55% 44% 29% 22% 12% 22% 44% 42% 17%
SE 25%
SK 12% 17% 23% 18% 22% 23% 4.70% 31% 21% 8%
Median 20.7% 24.3% 25.5% 23.6% 22.0% 22.0% 12.9% 13.7% 20.0% 20.0% 10.0%
10
Figure 3: Road traffic fatalities in the EU by road user and (other) ‘main vehicle’ involved in the crash
Source: CARE database
Since there is an element of uncertainty in the actual contribution of vehicle defects to road crashes,
a sensitivity analysis was justified.56
The shares used in this impact assessment (4% for cars, vans,
HDVs and 6% for motorcycles) are relatively conservative, e.g., compared to the range based on the
literature review presented above. This approach was used to avoid overestimating the benefits.
Secondly, there is an issue related to safety-related tampering, which includes the manipulation of engine
performance, torque, maximum speed and improved acceleration, representing an obvious safety risk.
According to experts, the chip-tuning of electric vehicles is as easy as in the case of those equipped with
internal combustion engines, with the added risk of an overheated battery, which can cause fire e.g., in the
case of faster charging or faster discharging (higher performance). According to others, while the share of
tampered carsintheentirefleet remains relativelylow,theirshareishigheramongthoseinvolvedincrashes.
Due to the nature of the problem, available data on it is rather limited. The European Transport Safety
Council, amongother stakeholders, has highlightedthe issue of safety-relatedtampering, notablyinthe case
of powered two- and three-wheelers57
. A survey carried out for the Austrian Ministry of Climate Protection,
based on police inspections, found that roughly every second moped was manipulated (tuned) in Austria58
.
In addition, incorrectly stowed or secured cargo can slide, roll, tip over and fall off a vehicle, potentially
causing it to overturn and lead to crashes with other vehicles59
. To address this problem, the 2014 revision
of the RSI Directive introduced detailed provisions on the inspection of cargo securing, including its
principles, applicable standards, and the assessment of specific deficiencies (as an optional measure). This
was complemented by best practice guidelines60
prepared by a Commission expert group to provide
practical advice to anyone involved in loading/unloading and securing cargo, as well as to enforcers. The
guidelines and the corresponding provision of the Directive are non-binding, however. In spite of existing
rules, according to a major operation of Roadpol in Italy in 2019, 22% of the 40,500 inspected heavy goods
56
Cf. section 6.2.1 and further details in section 6 of Annex 4.
57
https://etsc.eu/wp-content/uploads/2020-09-ETSC-Briefing-on-Roadworthiness-Package-Implementation-
Reports_update16Oct.pdf
58
https://www.bmk.gv.at/themen/verkehr/strasse/verkehrssicherheit/vsf/forschungsarbeiten/82_tune-it.html
59
See e.g., Königsberger Ladungssicherungskreis: https://www.klsk.de/en/
60
https://road-safety.transport.ec.europa.eu/eu-road-safety-policy/priorities/safe-vehicles/cargo-securing-and-abnormal-
loads_en
11
vehicles (HGVs) did not comply with cargo securing requirements61
.
The problem of unsafe vehicles affects not only the owners/users of the defective or tampered vehicles, but
also other road users, especially vulnerable ones. Such example of vulnerable road users are
motorcyclists and while several factors play a role in motorcycle crashes, such as motorcycles’ and
other vehicles’ design (motorcyclists are often overlooked in traffic) and road environment
shortcomings (poor road surfaces, poor road alignment, obstacles, limited line of sight), motorcycle
design elements such as tyres, brakes, frame, suspensions are nonetheless very relevant for the safety
of motorcyclists, and regular control of their technical condition is considered important for their
road safety62
.
Society as a whole is affected by the external cost of crashes through human and medical costs, production
losses, the cost of police, emergency services, congestion, etc.63
More systematic and targeted testing of vehicles, using improved and updated test methods, could reduce
the number of such avoidable crashes. 54 out of the 65 stakeholders who replied to the targeted survey
agreed with the problem identified, while only 6 disagreed and 5 were neutral. In the OPC, 78% of
respondents (123 out of 158) agreed that the issue of vehicles circulating on the roads with defects or
tampered components needs to be addressed.
2.1.2. Insufficient control of vehicle air pollutant and noise emissions64
Air pollution remains an important cause of poor health in Europe and contributes in particular to
respiratory and cardiovascular diseases.65
Road transport has significantly reduced its pollutant emissions since 1990, with the exception of
compounds NH3 and N2O. Their recent increase is mainly due to new catalytic systems for the
reduction of NOx in diesel engines and the use of enriched fuel mixtures to control NOx at high load
in petrol engines. While a significant reduction can be seen for both PM10 and PM2.5, the non-exhaust
fraction of these emissions (i.e. from brake and tyre wear or road abrasion) is increasing66
.
The development of sophisticated emission control technologies has allowed to gradually reduce air
pollutant emissions from road vehicles well (orders of magnitude) below pre-Euro standard levels.
However, overall emissions from road transport are still too high – they alone are responsible for
approximately 40.6% of the total NOx and 10.5% of PM2.5 emitted in Europe67
, and this has serious
implications on human health, the natural environment, and affects the lives of millions, especially in urban
61
https://etsc.eu/wp-content/uploads/PIN-FLASH39_FINAL.pdf
62
ERSO Road Safety Thematic Report – Motorcycles, 2023, https://road-safety.transport.ec.europa.eu/european-road-
safety-observatory
63
CE Delft et al. (2020), Handbook on the external costs of transport – Version 2019 – 1.1, Publications Office,
https://data.europa.eu/doi/10.2832/51388
64
The problem analysis focuses on NOx and PM as the main air pollutants from road transport with the highest impact
on environment and health. Other pollutants have not been considered although it is plausible that targeting these two
pollutants will also affect other air pollutants (e.g. CO, HC, SO2).
65
In 2021 in the EU-27, 253,000 deaths were attributable to exposure to PM2.5 concentrations above WHO’s guideline level of 5
µg/m3
(micrograms per cubic metre of air), 52,000 deaths were attributable to exposure to NO2 concentrations above WHO’s guideline
level of 10 µg/m3
and 22,000 deaths were attributable to short-term exposure to O3 concentrations above 70 µg/m3,
EEA, Europe's Air
Quality Status, 2023, Europe’s air quality status 2023 — European Environment Agency.
66
EEA, Emissions of air pollutants from transport, October 2024 Emissions of air pollutants from transport in Europe | European
Environment Agency's home page
67
EEA (2023), Air Pollution in Europe; 2023 reporting status, https://www.eea.europa.eu/publications/national-
emission-reduction-commitments-directive-2023
12
areas. Various studies have shown that real-world NOx emissions of modern vehicles were above type-
approval limits68
. Such exceedances can in some instances (due to tampering, for example) be as high as
older Euro Standards or even pre-Euro NOx emission levels69
. Other studies have shown that in the absence
of the appropriate emission reducing technology (selective catalytic reduction (SCR) and diesel particulate
filter (DPF)) on Euro VI HDVs, vehicles can emit up to a factor of 100 more NOx, CO, and PM than the
legal requirements70
.
The findings of the RWP evaluation show that some of the tests used in PTI are no longer sufficiently
sensitive to detect emission failures and the current testing procedures are not fit to meet the EU policy goals
as regards air pollution. Modern vehicle engines and exhaust gas systems have critical detection criteria that
are not covered by the currently prescribed test methods, and current PTI tools are not able to measure PN
and NOx. Considering these shortcomings, the current RWP’s contribution to reducing the number of
vehicles in circulation with high emissions has become less relevant. The measurement of nitrogen oxide
emissions or PM/PN values for new cars are still not covered by the current RWP and there are currently
no EU provisions for testing vehicles for NOx manipulation/defect or manipulation/defect of diesel
particulate filters. The share of vehicles found with defective emission control equipment or exhaust
emissions above the limits specified in the PTI and RSI Directives ranges from around 1-3% to up to 45%
depending on the Member State and the way checks are conducted. Targeted inspections identify higher
shares of over-emitting vehicles. Periodic testing has demonstrated that older vehicles can be much more
polluting than newer ones, as the effectiveness of emissions reduction systems declines with age. Since
some of the defective vehicles emit multiple times over the regulatory limit, even a relatively limited share
of such vehicles can be responsible for a large part of overall road transport emissions. This has been
demonstrated by various studies71
.
In addition, there is evidence72
that the emission control equipment of a non-negligible number of modern
vehicles are tampered with, either to avoid immediate replacement of filters or the cost of consumables,
such as diesel exhaust fluid (DEF)73
required for the proper functioning of SCR74
. Various tampering
techniques have been developed to alter on-board diagnostic information and to avoid that the vehicle
automatically switches to low-power (or limp) mode, e.g., after it has run out of DEF for a long time. This
is consistent with the observation that a small number of “high emitters” are generally responsible for a
disproportionate fraction of the overall emissions (e.g., a TNO study75
indicates that 6% of vehicles
defective emission control systems caused 36% of road transport NOx emissions). A recent study involving
remote sensing technology screening a large number of vehicles in Flanders, Belgium showed similar
results for particle emissions due to DPF failures76
.
68
see e.g., TNO report on NOx emissions of eighteen diesel light commercial vehicles:
http://resolver.tudelft.nl/uuid:21191e19-2dc7-4468-8559-1075ed6279f7
69
Giechaskiel, F. et al. (2022), Effect of tampering on on-road and off-road diesel vehicle emissions.
70
Ricardo et al. (2023), Impact assessment support study on the directives of the roadworthiness package, Contract no.
MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001Ricardo et al. (2023), Impact assessment
support study
71
Such as TNO (2022), http://resolver.tudelft.nl/uuid:b5d127c3-303c-4013-b1ac-c9ac01f66e2d and CARES (2023),
https://cares-project.eu/emission-factors-lez-impact/
72
Notably from roadside checks reported by inspectors of national authorities, including with the use of plume chasing
technology: https://citainsp.org/wp-content/uploads/2021/11/5-CITA-17-11-2021-for-upload.pdf
73
Diesel exhaust fluid (DEF), also known as AUS 32 (aqueous urea solution 32%) and marketed as AdBlue.
74
A basic illustration of the main components of an exhaust aftertreatment system is available at:
https://www.autoserviceworld.com/understanding-diesel-exhaust-aftertreatment-systems/
75
TNO report on NOx emissions of eighteen diesel light commercial vehicles: http://resolver.tudelft.nl/uuid:21191e19-
2dc7-4468-8559-1075ed6279f7
76
Hooftman N., Ligterink N., Bhoraskar A., (2020), Analysis of the 2019 Flemish remote sensing campaign.
Commissioned by the Flemish Government - Flanders Environment Agency - Team Air quality policy.
13
As regards the impacts of the problems on pollutant emissions, the links between cause and effect
are more straightforward than in the case of road safety. Even though in the absence of accurate
emission testing available on a wide scale, the share of high-emitting vehicles and their contribution
to total emissions can only be estimated, the available studies applying portable emission
measurement systems (PEMS), recent remote sensing campaigns and the first results of newly
introduced particle number (PN) testing in three Member States provide a high level of confidence
as regards the scale of the problem, and the calculations of the impacts.77
As outlined in section 1, road transport is by far the largest source of noise pollution in Europe and is the
second most harmful environmental stressor after air pollution78
. Modified or defective exhaust systems
can also contribute to noise pollution. The threshold of noise above which it is considered a nuisance can
vary. In the OPC, 91 out of 149 respondents expressed the view that it is very important to address the
problem of noise-related tampering/non-compliance in vehicles and 13 had no opinion. Most respondents
to the survey and interviews conducted as part of the evaluation believed that technological and market
developments had had a low impact on reducing the number of vehicles with tampered or defective noise
control systems (46 of 75 respondents; 15 did not know or did not respond). Representatives of the
automobile as well as motorcycle manufacturers (ACEA and ACEM) agree that illegal modifications
leading to single-event noise peaks need to be addressed through consistent control79
.
While these vehicles are supposed to be repaired or taken out of circulation, there are still many vehicles
with defective or tampered emission control systems that go undetected and continue to cause avoidable
damage. Noise tampering mainly affects powered two-wheelers, which are not subject to roadworthiness
testing in every Member State. The problem of air pollution and noise generated by vehicles mainly affects
people living in the vicinity of major roads, in particular in urban areas, and especially the most vulnerable.
Lower income groups tend to be exposed to higher levels of air pollution, while older people, children,
adolescents, and those with pre-existing health conditions are more susceptible to negative effects of air
pollution80
. 56 out of the 67 stakeholders who replied to the targeted survey agreed with the problem
identified, while only 4 disagreed and 7 were neutral.
2.1.3. Roadworthiness Directives are not effective in enforcing rules in EU cross-border
traffic and trade of vehicles
One of the objectives of the RWP was to facilitate free movement for EU citizens and ensure the smooth
functioning of theinternal market81
.This is reflected in different elements oftheRWP,including the mutual
recognition of roadworthiness certificates among EU Member States (as part of the PTI Directive), in
combination with the provisions of the VRD Directive aiming to ensure the authenticity, accuracy, and
mutual recognition of vehicle registration documents across EU Member States. Brought together, these
should facilitate the enforcement of the rules, efficient cross-border transport, and prevention of fraudulent
practices, eventually contributing to better road safety and less polluting vehicles on the roads.
According to the findings of the evaluation, communication between authorities across national borders
improved following the adoption of the RWP. The PTI and RSI Directives established contact points
through which information can be more swiftly exchanged between Member States. However, the
77
see e.g. DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations, or TNO (2022),
Approaches for detecting high NOx emissions of aged petrol cars during the periodic technical inspection. R10659v2
78
https://www.eea.europa.eu/publications/managing-exposure-to-noise-in-europe/noise-in-europe-updated-population-
exposure
79
https://www.acea.auto/files/ACEA-position-paper-Vehicle-noise-setting-appropriate-limits.pdf and
https://acem.eu/images/publiq/2021/ACEM_Position_Paper_Sound_Emissions_2021.pdf
80
https://www.eea.europa.eu/en/topics/in-depth/air-pollution
81
Cf. recitals 1 and 3 of the Directive 1999/37/EC (VRD) and recital 24 of Directive 2014/45/EU (PTI)
14
evaluation also highlighted that Member States still report difficulties in effectively enforcing road safety
measures in EU cross-border traffic and vehicle trade. These have their origin in: (a) Member States
registering different sets of vehicle data, and (b) difficulties for competent authorities in accessing vehicle
register data and other safety-relevant information of vehicles, notably when these are registered in another
Member State. These difficulties make the re-registration of vehicles less efficient and more cumbersome
for citizens82
. Related to cross-border trade of vehicles, the evaluation of the RWP found some
incoherencies between the VRD Directive and Regulation (EU) 2018/858 ontype-approval requirements83
:
in some cases, in the VRD Directive, definitions of the vehicle registration data and terminology do not
correspond tothosein thetype-approval legislation. This leads to confusion andpotential errors in recording
vehicle information at the time of re-registration. Furthermore, difficulties in the cross-border exchange of
informationbetweenMember States’ authorities can also negatively impact the fight against the widespread
malpractice of odometer tampering which, by itself, can negatively affect road safety and the environment
(due to poorer maintenance). It is also directly affecting consumers given that mileage is an important
determinant of used vehicles’ market value.
Odometer tampering rates were estimated at 20 to 40% for cars imported in EU15 countries and 30 to 80%
in EU12, according to a study commissioned by the European Parliament84
, while other studies indicate the
share of tampered vehicles to be between 5 and 12% of used cars in national sales and much more, between
30 and 50%, of cross-border sales85
. According to the support study of the European Parliament’s 2018
resolution on odometer manipulation in motor vehicles in the EU, the total economic costs of odometer
fraud in second-hand cars traded cross-border in the EU could be estimated at around EUR 8.77 billion per
year86
. This was found mainly due to the lack of effective cooperation between Member States' authorities
and an insufficient exchange of information on mileage readings of odometers in vehicles traded across the
Member States' borders. More recent estimates provided by CarVertical87
, based on analysis of vehicle
history reports, suggest overall lower odometer fraud rates for most of the countries reported that those in
the European Parliament study. Drawing on CarVertical and other assumptions, the impact assessment
support study88
shows however that fraud rates are still estimated to be significant (i.e., 2.2 to 10% of used
cars in national sales and 4.4 to 25.7% of cross-border sales)89
.
Even though odometer manipulation is a punishable offence under the PTI Directive, the fact that odometer
readings are recorded only at PTI does not prevent fraud since most cars and vans are not tested before they
are four years old and, in most Member States, only every two years thereafter. Furthermore, the evaluation
of the RWP also reported that regarding the obligation to introduce effective and dissuasive penalties when
an odometer is found to have been manipulated, the national measures appear in many cases rather generic,
not specifically aimed at odometer fraud. 39 out of the 60 stakeholders who replied to the targeted survey
agreed with the problem identified, while only 5 disagreed and 16 were neutral.
82
As illustrated by various complaints and SOLVIT requests received by the Commission.
83
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R0858
84
TRT (2017), Research for TRAN Committee (European Parliament) - Odometer tampering: measures to prevent it.
85
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
86
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
87
Overall mileage fraud analysis is available at: https://www.carvertical.com/blog/research-what-countries-have-the-
highest-percentage-of-cars-with-a-fake-mileage, and in the CarVertical Market transparency index:
https://www.carvertical.com/transparency-index. Specific analysis of the share of odometer tampering for national and
imported second hand vehicles is available at: https://www.carvertical.com/blog/research-local-or-imported-cars-have-
more-mileage-rollbacks.
88
Ricardo et al. (2023), Impact assessment support study on the directives of the roadworthiness package, Contract no.
MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001
89
See Annex 4 (section 2) for more detailed explanations on the estimations, and an overview by Member State.
15
2.2. What are the problem drivers?
2.2.1. PTI-methods not available to test electric vehicles, electronic safety & driver
assistance systems (PD1)
This problem driver links to problem 1 (Presence of unsafe vehicles on EU roads). The existing rules on
roadworthiness testing were designed more than 10 years ago, with the Commission’s proposal made in
2012. At the time, the share and expected development of the electric vehicle (EV) market was significantly
lower than today90
, which explains why there are no EV-specific requirements in the PTI Directive. The
same applies to electronic safety and driver assistance systems.
The General Safety Regulation91
requires that, from 6 July 2022, new vehicle types are equipped with
certain advanced driver assistance systems (ADAS), including intelligent speed assistance, reversing
detection with camera or sensors, attention warning in case of driver drowsiness or distraction, event data
recorders, an emergency stop signal (in all road vehicles), as well as lane keeping systems and automated
braking in cars and vans. These features will be mandatory on all vehicles registered from 7 July 2024
onwards. Thanks to the requirements of the GSR, new car and van models sold since July 2022 and every
new vehicle sold from July 2024 will be due for PTI between 2026 and 2028. Trucks and buses featuring
technologies helping to recognise blind spots, warnings to prevent collisions with pedestrians or cyclists
and tyre pressure monitoring systems will have to undergo their first roadworthiness tests even earlier
(usually one year after the first registration).
The RWP evaluation found that systems introduced by the revision of the GSR increases the relevance of
vehicle roadworthiness testing to verifying the operation of these mandated electronic systems. These
systems may malfunction, require software updates to ensure intended performance, and they could be the
target of tampering. In terms of keeping up of the RWP with the technological and scientific progress, most
of the stakeholders interviewed in the context of the evaluation considered that it is essential to update the
directives to include the functioning of ADAS and advanced lighting, which have been fitted in cars for
around adecade but are not tested by standardPTIs.Similarly,thesurvey respondents,especially ministries,
road safety authorities and PTI bodies, considered that the current RWP directives and their objectives
follow technological advancement only to a limited extent. The technology used in vehicles has surpassed
what the current directives cover and new rules for inspection of new safety systems, such as ADAS, are
needed. Although both EVs and ADAS bring about significant benefits by reducing emissions and
improving road safety, they also come with new risks to be mitigated. In the case of EVs, including plug-in
hybrids, the high voltage systems can be a source of such risks, which, if damaged, can overheat and cause
fire. While a few Member States have introduced national requirements (e.g., FR, NL) in relation to the
inspection of EVs, these are not generally applied in the EU. For ADAS, it is the possible malfunctioning
ofthesystems themselves that may createsafety hazards. However,noneofthese arecurrentlytested during
periodic technical inspections.
Next to the research and development efforts needed to define the appropriate test methods, an important
barrier to their application is the difficulty for inspection centres to access the necessary in-vehicle data.
Although the Commission Implementing Regulation (EU) 2019/621 requires that manufacturers make
certain vehicle data available to facilitate PTI tests, it does not apply to the data related to items/components
that are not part of the current minimum requirements on items to be tested. According to the findings of
the evaluation, there is data incoherence between the RWP and relevant type-approval legislation due to
90
While there were only about 200,000 EVs, including PHEVs, in Europe in 2014 (and much fewer in 2012 when the
proposal was made), in 2022, there were 7.8 million EVs on European roads, https://www.iea.org/reports/global-ev-
outlook-2023/trends-in-electric-light-duty-vehicles
91
https://eur-lex.europa.eu/eli/reg/2019/2144/oj
16
divergence of safety-relevant vehicle data. The interview respondents considered there was a common
problem with the RWP regarding the limited direct access to in-vehicle data and functions for authorised
inspection service providers. For example, even two models of the same manufacturer can require different
file formats, which makes the use of reference data very difficult and time-consuming. 74% of the OPC
responses (116 out of 156) were in favour of the need to address this problem driver; a similar percentage
of support was expressed by industry representatives during the targeted survey (58 out of 76 responses).
2.2.2. Current PTI & RSI-methods not suited to measuring the emission performance of
modern vehicles (PD2)
This problem driver affects problem 2 (Insufficient control of vehicle air pollutant and noise emissions).
The existing Directives require exhaust gas emission testing of diesel vehicles using opacity measurement,
or, in the case of Euro 5/V and Euro 6/VI vehicles, by reading the vehicle’s on-board diagnostic (OBD)
system. While exhaust gas opacity testing may detect a defective emission control system without a particle
filter in an older vehicle (pre-Euro 5/V) and has thus been considered sufficient to test the compliance of
those vehicles, multiple laboratory tests92
have proved that it cannot detect a malfunctioning or even
tampered diesel particle filter (DPF). DPFs were introduced to comply with significantly stricter limits than
before Euro 5/V and the emissions without a DPF could be about an order of magnitude (or two) higher93
.
Even in a Euro 4 vehicle equipped with a defective DPF, the exhaust’s opacity may be lower than the
instruments’ resolution. Studies have also shown that even when high smoke emissions are measured, in
most cases the OBD does not indicate any failure.
Furthermore, while the newly developed method of particle number (PN) counting94
has demonstrated high
levels of particle emissions in vehicles with defective DPFs, e.g., close to 10% of Euro 5 and 6 vehicles
tested in Belgium in 2022, the OBD showed malfunctioning in only 0.72% of the cases95
. This illustrates
the extent to which the current emission test requirements of the PTI and RSI Directives are obsolete and
inadequate concerning modern diesel vehicles. Concerns about the ineffectiveness of smoke opacity tests
were also expressed by stakeholders surveyed during the evaluation. The applicability of PN measurement
hasnot yetbeensufficientlytestedforvehicles equippedwithpositiveignitionengines,but relevantresearch
is ongoing. To address the issue of high NOx emissions, various methods have been studied to measure
them96
. However, while NOx emission limits are set by type-approval, and RDE (Real Driving Emissions)
tests have significantly tightened the requirements on new vehicles, the monitoring of NOx emissions from
road vehicles is currently not part of PTI.
92
Such as those carried out by the Commission’s Joint Research Centre: Comparisons of Laboratory and On-Road Type-
Approval Cycles with Idling Emissions. Implications for Periodical Technical Inspection (PTI) Sensors,
https://doi.org/10.3390/s20205790 and Evaluation of Measurement Procedures for Solid Particle Number (SPN)
Measurements during the Periodic Technical Inspection (PTI) of Vehicles, https://doi.org/10.3390/ijerph19137602.
93
See e.g., https://environnement.brussels/media/1883/download?inline
94
Already applied by Belgium, the Netherlands, Germany as well as Switzerland, and referred to in the Commission’s
recommendation on particle number measurement, https://eur-lex.europa.eu/eli/reco/2023/688/oj.
95
Figures reported by GOCA Vlaanderen for July 2022-April 2023: 12.4% of Euro 5 and 2.8% of Euro 6 vehicles failed
with the current 1.000.000 1/cm3
limit; 16.8% and 4.8%, respectively, would have failed the recommended limit of
250.000 1/cm3
.
96
E.g., Fernández (2022), Suitability Assessment of NOx Emissions Measurements with PTI Equipment,
https://doi.org/10.3390/vehicles4040050; CITA (2022), Monitoring of NOx emissions as part of the PTI – CITA
International Motor Vehicle Inspection Committee (citainsp.org); Franzetti et al. (2023), Assessment of a NOx
Measurement Procedure for Periodic Technical Inspection (PTI) of Light-Duty Diesel Vehicles,
https://doi.org/10.3390/en16145520.
17
2.2.3. Limited technical possibilities to detect vehicles with defective or tampered
components (PD3)
This problem driver is linked to all three problems. Firstly, together with PD1 (PTI-methods not available
to test electric vehicles, electronic safety & driver assistance systems), it is one of the reasons why there are
still, and will continue to be, unsafe vehicles on the roads. While new vehicle technology may require new
ways of testing (PD1), there are vehicles on the roads today with defects that carry a potential safety risk
and that PTI cannot detect, notably due to the limited vehicle data available to testing centres (or repair
shops). For example, where a windscreen of avehicle equippedwith cameras is replaced, precise calibration
requires not only the manufacturer’s specifications, but also the vehicle’s relevant data history (which for
some vehicles can provide details of the last time the vehicle underwent a recalibration). Such information
is currently not available to PTI.
Similarly, unauthorised modifications tothevehicle’s enginemanagement systemtoincreaseits power may
not be detected without access to the relevant in-vehicle data97
. Such tampering is relatively easy, and
devices are widely available, for internal combustion engines as well as for electric vehicles (a simple web
search would deliver multiple results). The situation is similar in the case of motorcycles98
. The ongoing
electrification of powered two-wheelers, especially mopeds, has apparently led to an increase in the same
kind of tampering of those vehicles, with multiple tutorials available online. Since manipulation is so easy
in the case of these vehicles, it is difficult to detect it even where such vehicles are subject to periodic testing
as the modifications can also be easily reversed. These vehicles represent an increased safety risk, in
particular in urban areas.
Secondly, tampering with emission control systems is equally easy with various solutions offered online99
,
even explaining why it is “good” for the user to disable the selective catalytic reduction (SCR) system,
which requires diesel exhaust fluid (DEF, or AdBlue). While DEF is a necessary consumable for the SCR
to significantly reduce the amount of NOx emissions, since running out of DEF may cause the vehicle not
to start, it is a convenient (and often significantly cheaper) solution to deactivate the entire system. It can be
especially viable in the case of commercial vehicles, where entire fleets may be tampered to decrease repair
and maintenance costs100
. Together with PD2 (Current PTI & RSI-methods not suited to measuring the
emission performance of modern vehicles), this contributes to the insufficient control of vehicle air
pollutant and noise emissions. Noise-related tampering, i.e., removing the exhaust silencer (or dB killer)
of amotorcycleis similarlyeasy withabundant instructions availableonline.AccordingtoACEM and some
experts in vehicle testing, PTI is not sufficiently effective when it comes to such tampering.
Thirdly, tampering with odometers is also a lucrative business and detecting it has been a challenge across
the EU, which negatively affects the effectiveness of the RWP in enforcing rules in EU cross-border
traffic and trade of vehicles. Recording odometer readings at PTI may have somewhat improved the
traceability of odometer history, or helped detect fraud (likely too late, when the vehicle is due for PTI with
its new owner). However, with PTI being a pre-announced inspection, it is not difficult to readjust the
mileage of the vehicle just before or after. Thus, in the absence of a better way to trace odometer history,
97
Before a recent fatal crash in Budapest, the maximum power of the vehicle causing the crash was increased from 612
to 690hp without it being noticed at PTI.
98
See e.g. https://buy-tuning-files.com/chiptuning/why-modify-your-motorcyles-rev-limiter-and-how-to-do-it/
99
See e.g., https://117speed.co.uk/adblue-removal-everything-you-need-to-know/;
https://www.canbusemulator.com/en/
100
See e.g., a case uncovered in Spain: https://www.guardiacivil.es/es/prensa/noticias/6944.html and
https://www.europol.europa.eu/media-press/newsroom/news/haulier-in-spain-caught-cheating-emission-regulations-
designed-to-prevent-air-pollution
18
mileage tampering remains largely possible in most Member States, and especially across borders101
.
2.2.4. Vehicle identification & status data not sufficiently available to, and recognised
among, enforcing authorities (PD4)
This problem driver links to problem 3 (Roadworthiness Directives are not effective in enforcing rules in
EU cross-border traffic andtrade of vehicles). In addition to the issues mentionedunderPD3,theinefficient
exchange of information among Member States further contributes to limiting the effectiveness of the
Directives. While most stakeholders consider that the RWP has contributed to facilitating communication
amongMemberStates,theyagreethatvehicleidentificationandstatus dataarestillnotsufficientlyavailable
to enforcing authorities. As mentioned in Section 2.1.3, there are sometimes significant differences in the
data elements recorded in national vehicle registers, largely due to the high number of optional data
elements, includingthose that arenot evenspecifiedinthe VRD Directive. Table2 summarises thediversity
in the registration of various data elements. 224 data elements are stored by only some of the Member States
(i.e., not by all, and not by any of them).
Table 2: Summary of the registration of various data elements
Number of data elements M1 Percentage of the MS that stores the item
11 11 data elements were stored by all of the MS (100%)
23 23 data elements were stored by a clear majority of the MS (80% – 99 %)
135 135 data items were stored by a substantial number of MS (30% – 79 %)
66 66 data elements were stored by a minority of the MS (1% – 29 %)
38 38 data elements were stored by none of the MS (0%)
Source: EReg/EUCARIS102
In addition to the regulatoryframeworkprovided bythe VRD Directive, EReg, the Association ofEuropean
Vehicle and Driver Registration Authorities, has worked on the voluntary harmonisation of registration
procedures and data quality, including on the scope of data that should be stored in vehicle registers to
facilitate cross-border trade (re-registrations) and issued various reports on the topic103
.
Although the VRD Directive requires Member States to assist one another in the implementation of the
Directive, it merely allows exchange of information and only hints at the possibility that this could be done
electronically. This has led to a situation where several Member States use EUCARIS104
for the exchange
of vehicle registration data, mileage data, PTI data or roadside inspection (RSI) reports. However, while
many Member States use EUCARIS for various services, not all of them use it systematically for the
relevant exchange of data. The lack of clear rules as regards the exchange of vehicle related information
among Member States therefore further complicates smooth communication between authorities.
To implement requirements of the RSI Directive to notify the Member State of registration of any major or
dangerousdeficiencies foundatRSI,sinceJune2020, thenotificationsmustbesentusingtheRSIsystem105
,
built on the functionalities of the European Register of Road Transport Undertakings (ERRU). ERRU and
101
While Belgium and the Netherlands have introduced dedicated systems with databases keeping much more frequent
odometer readings than what PTI can offer, and thus significantly reducing odometer fraud in both countries and between
them, such systems do not exist elsewhere and detecting odometer fraud, especially in imported vehicles, is less likely.
102
https://www.ereg-association.eu/media/2742/final-report-topic-group-xxi-proposal-on-the-registration-of-vehicle-
data.pdf
103
https://www.ereg-association.eu/topic-groups/topic-group-xxi/
104
EUCARIS (European Car and Driving Licence Information System) is a system developed by and for governmental
authorities to help fighting car theft and registration fraud. It enables the sharing of vehicle and driving licence
information between EU and non-EU countries: https://www.eucaris.net/
105
Commission Implementing Regulation (EU) 2017/2205 on detailed rules concerning the procedures for the
notification of commercial vehicles with major or dangerous deficiencies identified during a technical roadside
inspection: https://eur-lex.europa.eu/eli/reg_impl/2017/2205/oj
19
RSI messaging system, as well as several other road transport-related applications are hosted by the
Commission and use a central hub (MOVEHUB) to interconnect national registers. While certain EU
legislation requires the use of EUCARIS106
, and others, including the RSI Directive, refer to the
MOVEHUB for data exchange, there is no legal requirement to use such systems to facilitate the re-
registration of vehicles and the implementation of the PTI and VRD Directives. The inability to effectively
exchange a real-time data on the vehicle (de)registration status, including the information on cases when a
vehicle is temporary de-registered or its ownership has changed, contribute to the problem of a low
traceability of vehicles across the EU. Such administrative and regulatory failures hinder the uncovering of
illegal activities such as the illegal trade or illegal dismantling of vehicles, leading to the problem known as
“missing vehicles”107
.
Certain optional data registered in one Member State are not recognised by another EU country for re-
registration. The reason is that the second Member State registers a different set of data. This may concern
data related to the owner, the mass, the category, or the exhaust emissions of the vehicle. Moreover, even
though there is significant level of harmonisation in roadworthiness testing, there are very few cases where
the Member State of registration recognises the validity of a PTI certificate issued in another Member State
(one example is the Netherlands accepting PTI conducted in certain PTI centres in Spain). Such lack of
recognition of registration data and PTI reports lead to inefficiencies in administrative processes and cause
avoidable administrative burden for vehicle owners.
Stakeholders consulted during the evaluation emphasised in their interviews that digital data exchange and
harmonisation of vehicle documents is needed for streamlining the vehicle re-registration process since
standardising the content and format of vehicle files would facilitate the digital transfer of registration
information between national databases and reduce the administrative burden and costs associated with the
process. The interviewees stressed the need for a legal framework to support this exchange of data and
digital services for efficient re-registration process. 67% of the OPC responses (100 out of 149) were in
favour of the need to address this problem driver; a similar percentage of support was expressed by industry
representatives during the targeted survey (47 out of 72 responses).
2.2.5. Certain vehicles are not (sufficiently) tested for their roadworthiness (PD5)
Problem driver 5 relates to the fact that certain vehicle categories are not covered by or not necessarilytested
under the PTI/RSI Directives and, as a result, PTI/RSI is only required for such vehicles in a few Member
States. Furthermore, frequency or scope of testing of certain vehicles is not adapted to the higher safety and
environmental risk associated with them (very frequent use or vehicle age). This directly affects the first
two problems, i.e., the presence of unsafe vehicles on EU roads and insufficient control of air pollutant
and noise emissions. Indirectly, it also has an influence on the third problem, in that testing light vehicles
annually from the date of their first registration (as is the case for HDVs), and at the roadside, could also
increase the effectiveness of the directives, notably in preventing odometer fraud.
In 2014, the scope of the PTI Directive was extended to faster tractors (design speed >40km/h) and larger
two- and three-wheel vehicles and quadricycles (equipped with internal combustion engines >125cm3
),
effective from January 2022. However, the Directive allows for exemptingmotorcycles, tricycles and heavy
quadricycles (L3e, L4e, L5e and L7e) from PTI “where the Member State has put in place effective
alternative road safety measures” and on condition that the Commission is notified. At the end of 2023,
106
Such as https://eur-lex.europa.eu/eli/reg_impl/2021/133/oj and the Commission proposal on the revision of Directive
2015/413 on facilitating cross-border exchange of information on road-safety-related traffic offences.
107
This problem and its drivers are discussed in the Impact Assessment Report accompanying the proposal for an ELV
Regulation (SWD (2023)256 final) mentioned in section 1.
20
eight Member States108
made use of this possibility. France introduced PTI for powered two- and three-
wheelers and quadricycles in April 2024. As such, the scale of the problem is expected to reduce
significantly, especially thanks to the introduction of PTI in France.
Agriculture and forestry tractors may also be exempted. Since they are not covered by the PTI Directive,
mopeds are only subject to periodic roadworthiness testing in some Member States (e.g., Austria, Croatia,
Spain). Although not in the scope of the PTI Directive, more than half of the EU Member States (16) have
provisions for mandatory PTI for light trailers (3 Member States have provided this only for the larger O2-
category, i.e., with maximum mass above 750 kg and up to 3500 kg), while others exempt them under
certain characteristics or conditions of operation109
.
With regards to the RSI Directive, the requirements on technical roadside inspections currently only apply
to commercial vehicles of more than 3.5 tonnes, while vehicles below this weight and their trailers are
exempted from inspections in most Member States.
Finally, and most importantly, only 16 Member States apply more frequent (yearly) roadworthiness tests to
older cars (>10 years)110
, that is, eleven, including the Member States with the largest fleets111
, do not,
which represent an increased safety and environmental risk. Since the car and van fleets of these Member
States represent roughly half of the EU fleet, and the vehicles older than 10 years among them are
about half of that, annual testing of vehicles older than 10 years would affect around 25% of the EU
light duty vehicle fleet.112
2.2.6. Interlinkages between the problem drivers
Some of the problem drivers are interlinked with each other. This is the case in particular with PD3 (Limited
possibilities to detect vehicles with defective or tampered components), which is influencing or influenced
by all the other problem drivers. EVs and ADAS represent new technologies and test methods for such
systems are very recent or just being developed and are not widely used yet (PD1). The lack of legal
requirement to test such systems during PTI and RSI for their potential defects may also present a safety
risk. PD3 is also linked to PD2 (Current PTI & RSI-methods not suited to measuring the emission
performance of modern vehicles) in a similar way as to PD1. Emission control systems have also evolved
considerably and developing adequate test methods to verify their functioning in a PTI-environment (i.e.,
requiring a quick, simple, and cheap method) has taken some time, which partly explains why the current
PTI and RSI emission test requirements are outdated. While for the purpose of detecting tampered vehicles,
RSI has the advantage of the drivers not knowing that they would be tested, it has the limitation that it is
only organised in campaigns and can therefore only screen a small subset of the vehicle fleet. PD3 is linked
to PD4 (Vehicle identification & status data not sufficiently available to, and recognised among, enforcing
authorities)in that in most MemberStates it is currently not possible to verify whether the odometer reading
of a vehicle is correct or not. Finally, it is linked to PD5 (Certain vehicles are not (sufficiently) tested for
their roadworthiness) since it is not possible to detect defective or tampered vehicles that are not tested.
2.3. How likely is the problem to persist?
Problem 1 - Presence of unsafe vehicles on EU roads. While technological development is likely to further
improve vehicle safety, the uptake of new technologies in the EU vehicle fleet would take some time, and
108
BE (testing is only required before selling or after a crash), DK (requiring roadside checks instead), FI, FR, IE, MT,
NL, PT (PTI only above 250 cm3
). FR introduced PTI for powered two- and three-wheelers and quadricycles in 2024.
109
DK, EL, FI, FR, NL, IE, PT exempt all light trailers, while PL, SK, BE and ES exempt O1.
110
Cf. section 2 of Annex 6.
111
Those eleven are DE, FR, IT, CY, CZ, DK, EL, HU, LT, MT, and SK.
112
Sections 4.1.9, 4.2.10 and 5 of Annex 4.
21
some of the new features may also bring about new risks. Similarly, while tampering may be made more
difficult by technical solutions, it is unlikely that it would disappear without enabling vehicle testing to
detect illegal modifications, notably of the engine management software e.g., through securing better access
to in-vehicle data. Thus, in the absence of EU level intervention, the problem is likely to persist. Member
States may take unilateral measures (e.g., introducing PTI for specific vehicle categories, specific methods
forthetestingofEVs orADAS).However, thesemeasures cannotreplacethecoordinatingandharmonising
effect of the three Directives, with the risk of possible distortions of the internal market and only partially
addressing the problem.
Problem 2 - Insufficient control of vehicle air pollutant and noise emissions. The problem of insufficient
control of vehicle air pollutant emissions would persist as long as vehicles equipped with internal
combustion engines (ICE) are on the roads. Although with stricter emission standards and gradual
electrification the number of vehicles generating tailpipe emissions will decrease, they will still be
circulating in the EU decades from now. While the proposed Euro 7 standard should address tampering and
durability more effectively than its predecessors, vehicle aging and defects are unlikely to be completely
overcome and vehicle inspection will continue to be key. Without updating the current emission test
requirements at EU level however, Member States may not introduce the most effective and efficient test
methods already available based on Commission recommendations. Similarly, while more Member States
may start experimenting with roadside noise testing e.g., as mentioned in section 1, it is unlikely that the
problem of noise vehicles would reduce significantly without a more systematic and coordinated approach.
Problem 3 - Roadworthiness Directives are not effective in enforcing rules in EU cross-border traffic and
trade of vehicles. Without EU level intervention, certain Member States may take unilateral or bilateral
measures, such as systematic recording (and possibly exchanging) of odometer readings, or develop
agreements to recognise each other’s roadworthiness certificates. However, the systemic problem of
insufficient and inefficient exchange of roadworthiness-related vehicle data would remain, hindering
effective implementation and enforcement of existing rules.
Foresight tools. The analysis incorporates throughout all its dimensions relevant foresight tools. It does so
to anticipate trends and issues that may affect the initiative and build a robust, future-proof evidence base
for its likely impact. The megatrend “Accelerating technological change and hyperconnectivity” will have
a significant impact on the road transport sector and is relevant for the problems related to the presence of
unsafe vehicles on EU roads and the insufficient control of vehicle air pollutant and noise emissions.
However, as explained above,technological changeonits own would not be able to address these problems,
or at least not for decades from now. The 2022 Strategic Foresight Report113
points to the potential of
digitalisation and artificial intelligence to boost the emergence of more efficient mobility solutions, with a
new generation of digital technologies enabling a major shift towards more sustainable mobility for
passengers as well as heavy-duty freight transport. This trend will have an impact on all three problems
mentioned above. For example, while digital solutions play a crucial role in innovative safety features and
highly sophisticated emission control systems, the trend has also led to new tampering techniques in both
areas. The trend will also play a key role in addressing the third problem, however, in itself, it will not be
sufficient to resolve regulatory failures. The megatrend “climate change and environmental degradation”114
is directly related to the insufficient control of vehicle emissions, identified as one of the main issues to be
addressed in line with the air quality legislation referred to in section 1. The same foresight report identified
“enabling a greener transport sector with digital technologies” as one of the areas where the twinning of the
green and digital transitions is expected to have a major effect. As regards the expected transformation of
the vehicle fleet over the next decade, certain automakers (e.g., Volvo) plan to sell only EVs as of 2030.
113
https://commission.europa.eu/strategy-and-policy/strategic-planning/strategic-foresight/2022-strategic-foresight-
report_en
114
https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en
22
Those cars will also be connected and featuring the ADAS required by the General Safety Regulation.
3. WHY SHOULD THE EU ACT?
3.1. Legal basis
The legal basis giving the EU the right to act is Article 91 of the Treaty on the Functioning of the European
Union(TFEU. In particular, Article91(1)(c)providesthat theUnionhas competenceinthefield oftransport
to lay down measures to improve transport safety.
3.2. Subsidiarity: Necessity of EU action
In the absence of the EU level intervention, Member States would continue to carry out periodic and
roadside inspections, but it is very unlikely that test methods and the scope of inspections required by the
EU acquis (e.g. testing brakes, suspension and emissions reduction equipment, etc.) would be applied in a
harmonised or coordinated manner. Different and piecemeal solutions would be applied, which would lead
to even larger differences in the safety and environmental performance of vehicles than today, with the risk
of distorting the internal market, and creating further barriers to free movement. The initiative therefore
addresses safety and environmental protection needs with “Union relevance”.
Road transport, especially freight, is an international sector, with vehicle approval regulated at the EU and
international (UNECE) level. Therefore, it has by nature a strong cross-border dimension. According to the
evaluation and the various targeted stakeholder consultations carried out as part of the revision process, the
RWP has been considered to have contributed to road safety and environmental protection in the EU and
has even had positive spill-over effects in neighbouring countries.
The identified problems apply across the entire Union and have the same underlying causes. At the same
time, there is widespread agreement among national authorities and industry experts that the current
Directives are no longer aligned with the latest regulatory and technological developments in vehicle safety
and emission control. In the absence of EU action, EU Member States may implement national solutions
and will work in an uncoordinated and non-harmonised way. This could undermine the harmonised safety
and emission standards.
3.3. Subsidiarity: Added value of EU action
As road transport and the automotive industry are international sectors, it is much more efficient and
effective to address the issues at the EU level than at the level of Member States. While national practices
differ historically, a certain minimum level of harmonisation in vehicle testing and commonly agreed
solutions to exchange vehicle data between Member States is more effective than multiple uncoordinated
national solutions. With common rules applied to testing modern vehicle technologies (EVs, ADAS, and
the most recent emission control equipment), Member States will realise economies of scale and testing
equipment manufacturers can operate on a more homogenous market. The functioning of the internal
market would also be improved by vehicles being subject to similar tests under similar conditions, and
transport operators facing similar costs. Coordinating the conditions of access and exchange of vehicle data
at the EU level will not only be more efficient than bilateral agreements and negotiations with individual
manufacturers, but also level the playing field among Member States and put them, collectively, in a
stronger position vis-à-vis the automotive industry.
23
4. OBJECTIVES: WHAT IS TO BE ACHIEVED?
4.1. General objectives
To address the problems identified in section 2 and in line with the overall logic of the Roadworthiness
Package on the one hand, and with the Commission’s strategic priorities on the other hand (‘Vision Zero’
road safety policy framework, the European Green Deal, the Sustainable and Smart Mobility Strategy, the
Zero Pollution Action Plan) and Treaty principles, the general objectives of this revision are to: (i) improve
road safety in the EU; (ii) contribute to sustainable mobility; and (iii) facilitate the free movement of persons
and goods in the EU. Stakeholders were consulted on these objectives as part of public as well as targeted
consultations, including through the Roadworthiness Committee and the Expert Group representing
Member States and industry experts, and a large majority of them agreed with the identified general and
specific objectives (see Annex 2). Improving road safety in the EU and contributing to sustainable mobility
are in line with UN Sustainable Development Goal (SDG) 3 (Ensure healthy lives and promote well-being
for all at all ages), including targets 3.6 (halving the number of deaths and injuries from road traffic
accidents) and 3.9 (by 2030, substantially reduce the number of deaths and illnesses from hazardous
chemicals and air, water and soil pollution and contamination), notably through specific objectives 1 and 2
mentioned below.
4.2. Specific objectives
The specific objectives of the initiative are designed to address the problems and problem drivers described
above (Figure 4). As each of the specific objectives address two or three problem drivers, they complement
each other to help achieve the general objectives. Both SO1 and SO3 contribute to SO2, while there are no
trade-offs between them.
Figure 4: Correspondence between problem drivers and the objectives
SO1: Ensure the adequacy, consistency, objectivity, and quality of roadworthiness testing of today's and
tomorrow's vehicles. This objective aims to address the challenges presented by the need to test the latest
and emerging vehicle technologies in a coherent manner. More specifically, the testing of EVs and ADAS
must be ensured before most of the new vehicles equipped with such systems are due for their first PTI
(PD1)115
. To correct for the inability of existing emission tests to identify high-emitting vehicles (PD2),
115
While many electric vehicles are already on the roads, many more new vehicles equipped with ADAS will be due for
PTI in 2026.
24
newly developed test methods need to be incorporated in the minimum requirements. Similarly, measures
need to be taken to improve the detection rate of defective or tampered, thus polluting, excessively noisy
and potentially dangerous vehicles (PD3). Some of those vehicles are not tested today, or not frequently
enough to detect those deficiencies (PD5). The majority of stakeholders participating in the targeted
consultation (64 out of 67) agreed with this specific objective. Adapting testing to today's and tomorrow's
vehicles (SO1) will also help achieve SO2.
SO2: Significantly reduce fraud and tampering, and improve the detection of defective vehicles. This
objective aims to significantly reduce tampering and improve the detection of vehicles with deficiencies, to
allow for the detection of defective/tampered safety and emission (i.e., air pollution and noise emission)
control systems, as well as of odometer fraud, by improving the suitability of emission testing (PD2),
providing for better tools to detect safety-related modifications, notably of vehicle software (PD3), and by
more and targeted inspections (PD5). Most stakeholders participating in the targeted consultation (60 out of
66) agreed with this specific objective.
SO3: Improve electronic storage and exchange of relevant vehicle identification and status data. This
objective aims at improving electronic storage and exchange of specific vehicle data, therefore addressing
the problem of insufficient availability of such data and mutual recognition by enforcing authorities
(registration, PTI, RSI) (PD4). More accurate status data (such as mileage) and efficient exchange of
information among MemberStates will also help identify vehicles withtampered odometer (PD3). As such,
SO3 also complements SO2. The majority of stakeholders participating in the targeted consultation (54 out
of 61) agreed with this specific objective.
5. WHAT ARE THE AVAILABLE POLICY OPTIONS?
5.1. What is the baseline from which options are assessed?
The EU Reference scenario 2020 is the starting point for the impact assessment of this initiative. The
REF2020 takes into account the impacts of the COVID-19 pandemic that had a significant impact on the
transport sector. More detailed information about the preparation process, assumptions, and results are
included in the Reference scenario publication116
. Building on REF2020, the baseline has been designed to
include the initiatives of the ‘Fit for 55’ package proposed by the Commission on 14 July 2021117
and the
initiatives of the RePowerEU package proposed by the Commission on 18 May 2022118
. The baseline
scenario factors in the revision of the HDV CO2 standards Regulation119
and the new Euro 7 standards120
,
the proposed end-of-life vehicles (ELV) Regulation121
and the forthcoming initiative on fair and non-
discriminatory access to in-vehicle data122
, as well as other initiatives part of the Road Safety package123
and the Greening Freight package124
.
116
EU Reference Scenario 2020 (europa.eu)
117
https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en
118
https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131
119
Regulation (EU) 2024/1610
120
COM(2022) 586 final
121
The proposed ELV Regulation calls for data related to the reasons of deregistering vehicles to be recorded in the
national vehicle registers. See: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023PC0451
122
According to current plans, the proposal on access to in-vehicle data would provide for non-discriminatory access to
such data in a harmonised, machine-readable format. This will be key for vehicle inspection too, without, however,
specifying the means of data access, which will continue to allow manufacturers to set their own (often cumbersome)
rules.
123
Proposal for a Directive amending the Driving Licence Directive, proposal for a Directive amending the Cross-Border
Enforcement Directive and proposal for a Directive on the Union-wide effect of certain driving disqualifications.
124
Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu)
25
ThebaselinescenarioassumesnofurtherEUlevelinterventionbeyondthecurrentRoadworthinessPackage
(i.e., the PTI and the RSI Directives as amended by the delegated Regulations to align with the evolution of
type-approval legislation125
and to introduce the testing of eCall at PTI126
, and the VRD Directive as last
amended by the revision of the Eurovignette Directive127
). As some of the provisions of the RWP allowed
for a very long transition period128
, certain Member States are still notifying transposition measures to the
Commission. The baseline scenario assumes full transposition of the current Roadworthiness Package. In
addition, the baseline reflects the introduction of PN measurement by three Member States129
.
The baseline also incorporates foresight megatrends and developments captured in the 2022 Strategic
Foresight Report130
, as explained in section 2.3. Among others, it captures the trend of increasing demand
for transport as population and living standards grow, as well as the links between the digital and green
transition, and the accelerating technological change and hyperconnectivity. In particular, the projected
transport activity draws on the long-term population projections from Eurostat and GDP growth from the
Ageing Report 2021131
by the Directorate General for Economic and Financial Affairs.
In the baseline scenario, EU transport activity is projected to grow post-2020, following the recovery from
the COVID-19 pandemic. Road transport would maintain its dominant role within the EU by 2050. Road
passenger transport activity (expressed in passenger-kilometres)132
is projected to grow by 10% between
2015and2030(27%for2015-2050),whileroadfreighttransport activity(expressedintonne-kilometres)133
by 27% during 2015-2030 (52% for 2015-2050). Rail transport activity is projected to grow significantly
faster than for road, driven in particular by the completion of the TEN-T core network by 2030 and of the
comprehensive network by 2050, supported by the CEF, Cohesion Fund and ERDF funding, but also by
measures ofthe‘Fit for55’ package134
andtheGreening Freight package.Passengerrail activityis projected
to go up by 37% by 2030 relative to 2015 (86% for 2015-2050). Freight rail traffic would increase by 50%
by 2030 relative to 2015 (107% for 2015-2050).
The share of zero-emission vehicles in the light duty vehicle fleet (passenger cars and light commercial
vehicles) is projected at 15% in 2030, going up to 95% in 2050 in the baseline scenario, while for heavy
duty vehicle fleet (buses and coaches, and heavy goods vehicles) at 6% in 2030 and 72% in 2050. These
developments are driven by the CO2 standards Regulations, supported by the Alternative Fuels
Infrastructure Regulation. The current limitations of the emissiontesting methods applied underthePTI and
RSI Directives are expected to persist in the baseline scenario, with the shares of high-emitting vehicles135
in the Euro 5/V and Euro 6/VI fleet remaining largely the same. On the other hand, the share of high-
emitting vehicles in the Euro 7 fleet is expected to be lower than for Euro 5/V and Euro 6/VI. The uptake
of zero-emission vehicles, the penetration of Euro 7 vehicles in the fleet and the related introduction of on-
125
https://eur-lex.europa.eu/eli/dir_del/2021/1717/oj and https://eur-lex.europa.eu/eli/dir_del/2021/1716/oj
126
https://eur-lex.europa.eu/eli/reg/2015/758/oj
127
Directive (EU) 2022/362 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520, as regards the charging
of vehicles for the use of certain infrastructures, https://eur-lex.europa.eu/eli/dir/2022/362/oj
128
For example, PTI for motorcycles (with a possibility for exemptions) since January 2022; the deadline to equip all test
centres with all the required equipment was 20 May 2023 (five years after the date of application).
129
Belgium, Germany and the Netherlands.
130
COM(2022) 289 final.
131
The 2021 Ageing Report. Economic and Budgetary Projections for the EU Member States (2019-2070) (europa.eu)
132
Covering passenger cars, buses and coaches, and power-two wheelers.
133
Covering heavy goods vehicles and light commercial vehicles.
134
These measures increase to some extent the competitiveness of rail relative to road and air transport.
135
High emitters are vehicles with defective emission or noise control systems or vehicles with tampered emissions/noise
control systems.
26
board emissions monitoring systems136
, combined, are expected to result in significant reductions of air
pollution emissions from road transport in the baseline scenario. NOx emissions are projected to reduce by
52% in 2030 relative to 2015 (98% reduction for 2015-2050), while particulate matter (PM2.5) emissions
would decrease by 43% in 2030 relative to 2015 (98% reduction for 2015-2050). CO2 emissions from road
transport are projected to decrease by 32% by 2030 relative to 2015, and be close to zero by 2050, thanks
to the large-scale uptake of zero-emission vehicles and some use of renewable and low-emission fuels.
In the baseline scenario, the number of fatalities is projected to decrease by 24% by 2030 relative to 2015
and by 31% by 2050 relative to 2015137
. The number of serious and slight injuries is projected to decrease
by 19% between 2015 and 2030 and by 26% for 2015-2050. This is despite the increase in traffic over time.
Relativeto2019,thenumberoffatalities woulddecreaseby 15%by2030and 23%by2050,andthenumber
of serious injuries by 10% by 2030 and 18% by 2050. Thus, the targets of the EU Road Safety Policy
Framework 2021-2030 – Next steps towards “Vision Zero”, of reducing the number of road deaths and the
number of serious injuries by 50% between 2019 and 2030, would not be met. In addition, this is still far
from the goal of the Sustainable and Smart Mobility Strategy of a close to zero death toll for all modes of
transport in the EU by 2050. The external costs of noise emissions are projected to increase by 7% by 2030
relative to 2015 and to remain relatively stable post-2030. The uptake of zero-emission vehicles
compensates to some extent the increase in noise due to the higher traffic138
.
In the baseline scenario, the number of periodic technical inspections (PTI) for cars, vans, buses, trucks and
motorcycles is projected to increase from 151.5 million in 2015 to 168.9 million in 2030 and 192.3 million
in 2050139
. For O1 and O2 vehicles the number of inspections is projected at 7.9 million in 2030 and 8.7
million in 2050. Most of the technologies required for more advanced testing included in the policy
measures are available and part of the baseline; however certain test methods need to be developed. More
detailed explanations are provided in Annex 4 (section 8).
Thenumberofnational second-handvehiclesales withmileagefraud at EUlevel is projectedat 1.71 million
in 2030 and 1.90 million in 2050, and that of cross border vehicle sales with mileage fraud at 3.35 million
in 2030 and 3.64 million in 2050. The national and cross-border odometer fraud is estimated to lead to
damages for European consumers estimated at EUR 10.7 billion in 2030 and EUR 11.7 billion in 2050140
.
Expressed as present value over 2026-2050 this amounts to EUR 194.6 billion. More details on the baseline
scenario are provided in Annex 4 (section 2).
136
Considering the expected effects of the Euro 7 based on the Commission’s proposal, the currently dominant Euro 5/V
and 6/VI vehicles should be gradually replaced by new ones complying with the Euro 7 standard. This would result in
reduced levels of tampering and lower emissions, in particular for heavy-duty vehicles. A limitation to mention here is
that the baseline reflects the Commission proposal. Following the changes agreed by the co-legislators, the baseline likely
overestimates the reduction in the air pollution emissions over time and thus slightly underestimates the contribution of
this initiative to the air pollution emissions reduction. This is particularly relevant in the short to medium term. In the
medium to long term this is less relevant due to the expected large-scale penetration of the zero-emission vehicles in the
fleet.
137
Projections refer to injuries in accidents in which a car, a van, a bus or a truck, or a motorcycle is involved.
138
It should however be noted that the reduction in noise due to zero-emission vehicles is only linked to the powertrain.
The noise from tyres still remains.
139
They are derived based on the ‘testing frequency’ and the average number of PTIs in the statistical life of a vehicle.
140
The average cost of mileage fraud, due to higher purchase price and maintenance costs incurred, is estimated at EUR
2,119 per vehicle in 2022 prices drawing on a Belgian Car-Pass study (https://www.car-
pass.be/files/article_files/file/7/crm%2520study%2520final%2520report.pdf). More explanations are provided in section
2 of Annex 4.
27
5.2. Description of the policy options
As a first step, a comprehensive list of possible policy measures was established after extensive
consultations with stakeholders, expert meetings, and independent research in the context of the impact
assessment support study and the Commission’s own analysis. This list was subsequently screened based
on the likely effectiveness, efficiency and proportionality of the proposed measures in relation to the given
objectives, as well as their legal, political and technical feasibility.
Discarded policy measures and policy options
The possibility to adopt further recommendations or a communication from the Commission was discarded
at early stage as non-regulatory measures could not be sufficiently effective in addressing the problems
identified and would have limited effect on harmonisation. Most stakeholders, including public authorities
participating in the open public consultation, agree that a legislative review of the RWP would be more
effective (see Annex 2). Out of the more than 40 policy measures discussed at five meetings with the Expert
Group on Roadworthiness and vehicle registration documents (RWEG), 13 measures have been discarded.
A more detailed list with all discarded measures can be found in Annex 8.
Retained policy measures and policy options
A list of 26 policy measures has been retained. Table 3 presents an overview of the policy measures
includedinthe policy options andtheirlinks withthespecificobjectives. Adetailed description ofthepolicy
measures is provided in Annex 7.
The policy options offer choices with focus on different aspects such as means of testing (e.g., PTI vs
roadside inspections, tailpipe testing only vs its combination with remote sensing) or different levels of
harmonisation in the exchange of vehicle data, the scope and methods of testing and the mutual recognition
of PTI certificates.
Four policy options have been identified (PO1a, PO1b, PO2 and PO3), and each of the four policy options
includes a set of policy measures that are common for all options, as well as additional measures that are
includedinone ormoreoptions. Thecommon set ofpolicy measures (from PMC1toPMC9)are considered
as the minimum necessary to correct the shortcomings of the existing RWP Directives and to adapt to
technological and regulatory developments over the last ten years, and are supported by most
stakeholders. Beyond the common measures, PO1a and PO1b differ in their focus, while compared
to them PO2 and PO3 represent an increasing level of ambition and harmonisation. This reflects the
preferences of various stakeholder groups and genuine options for more or less convergence in the
areas covered by the three Directives.
Table 3: Policy measures and policy options
PM# Policy Measure Specific
objective
PO1a PO1b PO2 PO3
Measures common to all policy options
New PTI and RSI tests
PMC1 Adapt PTI to electric and hybrid vehicles (safety,
environmental performance, standardised data), including
training of inspectors
SO1 X X X X
PMC2 Update PTI and RSI due to new requirements in the
General Safety Regulation and checking emission
reduction systems (new test items, including checks of
software status/integrity), by reading on-board diagnostics
SO1 X X X X
28
PM# Policy Measure Specific
objective
PO1a PO1b PO2 PO3
PMC3 Mandatory PN testing of LDVs and HDVs equipped with
particle filter, at PTI, and of HDVs at technical roadside
inspections of commercial vehicles
SO1,
SO2
X X X X
PMC4 Mandatory NOx testing of LDV and HDV at PTI, and
HDVs at roadside inspections
SO1,
SO2
X X X X
Frequency of testing
PMC5 Mandatory roadworthiness testing following significant
modifications of the vehicle (e.g. change of class,
propulsion system)
SO2 X X X X
Facilitating exchange of PTI and registration data
PMC6 Require roadworthiness certificate in electronic format
only
SO3 X X X X
PMC7 Provide electronic access to relevant data, including on
PTI reports stored in national databases, to the registration
authorities of other Member States using a common
interface
SO3 X X X X
PMC8 Harmonisation and regular update of the technical data in
the vehicle registration documents (of currently optional
content)
SO3 X X X X
Tackling odometer tampering
PMC9 Member States to record odometer readings in a national
database and make the records available to other MSs in
the case of re-registration
SO2,
SO3
X X X X
Measures not included in all policy options
Scope of vehicles subject to PTI/RSI
PM1 RSI for heavy/powerful motorcycles (L category >
125cm3) as an alternative measure, in Member States
where they are not subject to PTI (i.e., using the available
opt-out)
SO2 X X
PM2 Mandatory PTI for motorcycles above 125cm3 (remove
opt-out)
SO2 X
PM3 Extend PTI to all motorcycles (incl. from 50cm3 = all L3e,
L4e), plus tricycles (L5e) and heavy quadricycles (L7e)
SO2 X
PM4 Mandatory PTI for light trailers (O1 and O2 categories) SO2 X
Frequency of testing
PM5 Annual emission testing for light commercial vehicles
(N1) instead of the currently required 4-2-2- frequency
SO2 X X X
PM6 Mandatory yearly testing for vehicles that are 10-year-old
or older
SO2 X X X
Recognition of PTIs conducted in another Member
State
PM7 PTI certificate issued in any EU MS is recognised by the
MS of registration + further harmonisation of test methods
SO1,
SO3
X
PM8 PTI certificate issued in any EU MS is recognised by the
MS of registration for a period of up to 6 months (for
passenger cars only), on the condition that the next PTI is
conducted in the MS of registration
SO3 X X
PM9 PTI in another EU MS recognised by MS of registration
based on bilateral agreement (voluntary recognition)
SO3 X
Improve current PTI tests and procedures
PM10 More advanced testing of noise for motorcycles SO2 X X X
29
PM# Policy Measure Specific
objective
PO1a PO1b PO2 PO3
PM11 Data governance: further define the procedures and the
means of access to vehicle technical information by
testing centres free of charge
SO1,
SO3
X X
RSI methods
PM12 NOx, PM, and noise measurement by remote sensing in
RSI of all vehicles (with option for simplified PTI if
vehicle passed recent RSI)
SO1,
SO2
X X X
PM13 Mandatory inspection of cargo securing SO1,
SO2
X X X
Scope of vehicles subject to RSI
PM14 Extend the scope of application of roadside inspections to
light commercial (N1) vehicles
SO2 X X
PM15 Extend the scope of application of roadside inspections to
2- and 3-wheeled vehicles (L-vehicles from L3)
SO2 X
Registration certificate and registered data
PM16 Introduce issuing the registration certificates in digital
format to gradually replace current paper (and smart card)
documents
SO3 X X X
PM17 Add new data to the vehicle register – minimum
mandatory set (including among others: country of 1st
registration, registration status, PTI status, changes due to
transformation)
SO3 X X X
Adapting PTI to EVs (PMC1) and including new test items through the ePTI (PMC2, including the testing
of software integrity of safety- and emission-relevant systems) will help align the PTI rules with
technological andregulatorydevelopments and hence contributeto SO1 (Ensurethe adequacy, consistency,
objectivity, and quality of roadworthiness testing of today's and tomorrow's vehicles). Similarly, new
emission test methods for both particles and NOx (PMC3 and PMC4) are necessary to adapt to more recent
emission control technologies (contributing to SO1) and to capture high emitting vehicles, including
tampered ones (contributing to SO2). PMC5 will also contribute to SO2 (Significantly reduce fraud and
tampering, and improve the detection of defective vehicles) by requiring that vehicles undergo a
roadworthiness test following any significant modification involving e.g., the change of the propulsion
system or the emission class. PMC6, PMC7 and PMC8 contribute to SO3 (Improve electronic storage and
facilitating exchange of relevant vehicle identification and status data) through digitalisation of the
roadworthiness certificate, linking national vehicle registers and extending the set of harmonised vehicle
data in those registers. PMC9 introduces a requirement for Member States to record odometer readings in
national databases and make those records available to other Member States in the case of re-registration.
Garages (including car manufacturers), tyre and other repair services, in addition to PTI bodies would have
to provide such readings for cars and vans following every visit. PMC9 contributes to SO2 and SO3.
Reasoning behind the packaging of options
PO1a and PO1b are designed rather conservatively as regards the scope of vehicles to be tested and
are limited to the measures that are indispensable to address each of the problem drivers and to meet
all specific objectives, while each of these two options has a specific focus: PO1a focuses primarily
on enhancing the exchange of vehicle data and enhancing digitisation. PO1b on the other hand
focuses more on improving the testing of vehicles and introducing additional and more ambitious
measures regarding emission testing and recognition of PTI.
30
PO2 is designed to provide a more integrated approach. It builds on the measures already included
in PO1a and PO1b and adds more ambition with additional measures such as the extension of
roadside inspections to vans. It also improves access to relevant technical and registration data
through specific measures, such as better access to vehicle data necessary for testing notably modern
electronic safety systems.
PO3 builds on PO2 and takes its integrated approach, but compared to PO2 it further extends the
scope of vehicles and items to be tested. It further extends the scope of PTIs to cover light trailers
and motorcycles with smaller engine size, combined with mandatory roadside inspection for
motorcycles. It also provides a wider recognition of PTI inspections taking place in other Member
States. Overall, it represents the most ambitious option.
Policy option 1a (PO1a)
This policy option aims primarily at more efficient use of vehicle (registration and status) data, further
focusing on addressing SO3. In addition to the common measures, PO1a would require adding certain new
data elements to national vehicle registers, notably related to the registration and roadworthiness status of
the vehicle, thus facilitating the implementation and enforcement of the RWP as well as that of the ELV
legislation (PM17). Issuing registration certificates in digital format (PM16) will further enhance the
efficiency of data exchange. Furthermore, PO1a would allow Member States to sign bilateral agreements
to enable the cross-border recognition of PTIs and thus facilitate the free movement of people and goods
(PM9). PM9, PM16 and PM17 contribute to addressing SO3.
Beyondthecommonmeasures,PO1aapplies arelativelylighttouchapproach to addressingSO2. Toreduce
the number of tampered and defective motorcycles due to their lack of testing, it would require those
Member State which exempt these vehicles from PTI to apply as alternative measure, testing a share of
them at the roadside (PM1). Most stakeholders, including Member States authorities and especially
EReg/EUCARIS support this policy option, while the PTI sector (CITA and others) and motorcycle
manufacturers (ACEM) would prefer stricter PTI and RSI requirements.
Policy option 1b (PO1b)
Beyond the common measures, PO1b further focuses on addressing SO2 through more effective technical
inspections. The most important measure in this respect is the use of remote sensing technology141
(PM12),
which allows targeted and thus much more effective and efficient emission testing at the roadside. Remote
sensing, using laser technology (LiDAR) to detect critical pollutants, has been demonstrated to be an
effective method to screen very large numbers of vehicles at relatively low cost142
. This measure will allow
monitoring the emissions of virtually the entire vehicle fleet, including older vehicles, depending on the
scale of its implementation. Remote sensing using microphones is able to single out unusually noisy
vehicles even in dense traffic143
. This allows the identification of potentially high-emitting vehicles that can
be either inspected at a subsequent roadside check immediately after being identified or invited to a
roadworthiness centre for an emission test.
In addition, to address specific groups of vehicles that are more prone to tampering or defects than the
average, PO1b introduces specific measures: it would remove the possibility to exempt motorcycles from
PTI (PM2) and require yearly emission testing of light commercial vehicles (PM5). Furthermore, it would
141
https://cares-project.eu/about/
142
See e.g., https://publications.tno.nl/publication/34638150/2gBdxC/hooftman-2020-analysis.pdf and https://nemo-
cities.eu/remote-sensing/
143
https://nemo-cities.eu/remote-sensing-device-for-noise/
31
introduce mandatory annual PTIs for vehicles older than 10 years (PM6), an improved noise test for
motorcycles based on type-approval requirements (PM10) and make the inspection of cargo securing
mandatory (PM13). As such, all these measures go further in addressing SO2 (beyond the common
measures included in all options). PO1b would further facilitate the free movement of people, and further
address SO3, by requiring that the Member State of registration recognises the PTI certificate issued by
another Member State for a period of up to six months, provided that the next PTI is conducted in the
Member State of registration (PM8). This policy option enjoys the support of the PTI industry (CITA, FSD
and others) as well as automobile manufacturers (ACEA), testing equipment (EGEA) and motorcycle
manufacturers (ACEM), while certain Member States and motorcycle users find it too demanding. Stricter
cargo securing requirements are strongly supported by the logistics industry (in particular by EUMOS).
Policy option 2 (PO2)
PO2 combines most of the measures of PO1a and PO1b. As regards the testing of motorcycles, PO2
includes a measure of PO1a (PM1), while for the recognition of PTIs conducted in another Member State,
it uses PM8 (temporary recognition),like in PO1b. To furtherimprove the consistency and quality oftesting
of modern vehicles (SO1) and the availability of relevant technical data to testing centres (SO3), it includes
an additional measure on data governance (PM11), aiming to define the procedures and the means of access
to vehicle technical information (including in-vehicle data). The measure would complement an existing
Implementing Regulation144
and build on the upcoming proposal on access to in-vehicle data145
.
To further reduce the number of tampered and defective vehicles and contribute towards SO2, in addition
to the measures of PO1b and PO1a, it would also introduce roadside inspections for light commercial
vehicles (PM14). RSI complements PTI and is arguably better suited to detect and reduce fraud thanks to
the vehicle users having no prior notice of roadside tests, in comparison to pre-planned periodical technical
inspections, where pre- and post-tempering of vehicles cannot be excluded. In addition to being a
combination of PO1a and PO1b, PM11 on data governance makes this policy option more favoured by the
PTI industry (CITA, FSD and others) as well as FIA, testing equipment (EGEA) and motorcycle
manufacturers (ACEM). It is supported also by some Member States, notably those that rely on thousands
of smaller roadworthiness testing centres. On the other hand, the issue of access to vehicledatais considered
less important by automobile manufacturers. Stricter cargo securing requirements included in this option
are strongly supported by the logistics industry (EUMOS).
Policy option 3 (PO3)
PO3 goes further on harmonising the scope and methods of roadworthiness testing and the mutual
recognition of PTI certificates. As such, it aims to further address SO2, as well as SO1 and contributes to
facilitating the free movement of people and goods more comprehensively than the other options also
further addresses SO3. To the measures of PO2, PO3 adds further extension of scope of PTI to cover all
motorcycles without exception (PM3) and light trailers (PM4), and it extends RSI to motorcycles (PM15).
All these measures further contribute to addressing SO2. PO3 is the only option to include PM7, a
requirement that PTI certificates issued in any other EU Member States are recognised by the Member State
of registration without limitations, further addressing SO1 and SO3. This necessitates further harmonisation
of test methods where the PTI Directive currently offers various options. It would thus mean less room for
manoeuvre for Member States, and fewer choices for inspection centres. This being the most ambitious
144
https://eur-lex.europa.eu/eli/reg_impl/2019/621/oj
145
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-functions-
and-resources_en
32
option, it is mainly supported by the PTI sector, including equipment manufacturers as well as by ACEM
and a few Member States that apply stricter requirements than the current RWP Directives.
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?
This section summarises the main expected economic, social and environmental impacts of each policy
option (PO)146
. The proposed measures are assumed to be implemented from 2026 onwards, so the
assessment has been undertaken for the 2026-2050 period and refers to EU27. Costs and benefits are
expressed as present value over the 2026-2050 period, using a 3% discount rate, in constant prices of the
year 2022. Further details on the methodological approach are provided in Annex 4. The evidence
underlying the assessment of impacts is based on the best available evidence, including multiple studies
involving scientific research, as well as thorough consultation with experts.
6.1. Economic impacts
This section focuses on the economicimpacts ofthepolicyoptions onnational publicauthorities, businesses
and citizens. It also provides an assessment of impacts on competitiveness, on innovation and technological
developments, on small and medium enterprises (SMEs), on the functioning of the internal market and
competition, and looks at territorial impacts and digital by default. The assessment of economic impacts
draws on multiple data sources, including the targeted stakeholders’ consultation (interviews and survey)
and OPC, and findings from desk research in the context of the impact assessment support study. The costs
and benefits of each policy measure by stakeholder group are described in detail in Annex 4 (sections 3 and
4), including the assumptions used to estimate them. In addition, the cost-benefit analysis for some key
policy measures is provided in Annex 4 (section 6).
6.1.1. Impacts on national public authorities
All policy options are expected to result in adjustment and administrative costs for national public
authorities, while PO1b and PO3 would also lead to additional enforcement costs. At the same time, all
policy options are expected to result in significant administrative costs savings for the national authorities
(seeTable4toTable6). The costs and costs savings bypolicyoption are discussedbelow, whilethedetailed
calculations by policy measure are provided in Annex 4 (section 3).
Adjustment costs. All policy options include adjustment costs related to three common measures (PMC2,
PMC3 and PMC4). They cover one-off adjustment costs (see Table 6) for: the acquisition of on-board
diagnostic (OBD) scanning tools for RSI and the training of inspectors to use the OBD tools147
(PMC2),
estimated at EUR 0.2 million in 2026 relative to the baseline; the purchase of PN measurement devices for
RIS and the training of inspectors to use them148
(PMC3), estimated at EUR 0.7 million in 2026; and, the
acquisition of NOx measurement devices for RIS and the training of inspectors149
(PMC4), amounting to
EUR 2 million. In addition, recurrent adjustment costs (i.e., maintenance and calibration costs) for the PN
and NOx measurement devices are assumed at 5% of the capital costs, based on stakeholders’ feedback,
and are estimated at EUR 32,750 per year from 2026 onwards in PMC3 and at EUR 98,250 per year in
146
The analysis in this section is based on Ricardo et al. (2024), Impact assessment support study on the directives of the
roadworthiness package, Contract no. MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001,
and on the analysis of stakeholders' feedback.
147
The costs are estimated at EUR 1,000 per tool. One tool is required per RSI unit, and the number of RSI units total
131 at EU level. Two hours of training are assumed for each of the 393 RSI inspectors across EU27.
148
One PN measurement device is needed per RSI unit, at a cost of EUR 5,000 each. 131 RSI units would need to
purchase PN testing equipment. An additional half-day of training related to the use of PN measurement devices is
assumed for the estimated 393 RSI inspectors across the EU in 2026.
149
One NOx measurement device is assumed per RSI unit, at a cost of EUR 15,000 each. 131 RSI units would need to
purchase the equipment. An additional half-day of training is assumed for the 393 RSI inspectors.
33
PMC4 (see Table 5). Expressed as present value over 2026-2050, the total one-off and recurrent adjustment
costs are estimated at EUR 0.2 million for PMC2, EUR 1.3 million for PMC3 and EUR 3.8 million for
PMC4 (see Table 4). Thus, the adjustment costs due to the common set of measures (PMC2, PMC3 and
PMC4) are estimated at around EUR 5.2 million, of which EUR 2.9 million one-off costs. In addition to the
common measures, the most significant one-off adjustment costs in PO1a are due to PM9, concerning the
recognition of PTIs conducted in another Member State than that of registration based on bilateral
agreements. National authorities are expected to incur expenses for establishing bilateral agreements and
implementing procedures to facilitate inspections in another Member State. Assuming each Member State
establishes three bilateral agreements, the total costs for 41 such agreements have been estimated at around
EUR 1.4 million in 2026 (EUR 53,550 per Member State). In addition, PM1 will require that those Member
States150
that do not have a PTI requirement for motorcycles to introduce roadside inspections for
motorcycles over 125cm3 as an alternative, leading to the need of purchasing additional equipment to
support these inspections (one-off adjustment costs) and of maintaining it (recurrent adjustment costs). The
one-off adjustment costs due to PM1 are estimated at EUR 0.1 million in 2026 and the recurrent adjustment
costs at EUR 12,000 per year from 2026 onwards151
(see Table 5 and Table 6). The total one-off and
recurrent adjustment costs for national public authorities due to PO1a are thus estimated at EUR 7 million
(see Table 4), expressed as present value over 2026-2050, of which EUR 4.4 million one-off costs.
In PO1b, in addition to the costs of the common measures (PMC2, PMC3 and PMC4), the most significant
additional adjustment costs for authorities arise due to the introduction of remote sensing, and the option to
use plume chasing to measure NOx emissions from trucks, as well as the installation of noise cameras
(PM12). PM12 involves one-off costs for the purchase of the necessary equipment, the setting up of the
corresponding IT infrastructure and related training of inspectors, as well as recurrent costs for the
maintenance of the equipment and data management, and labour costs for the inspectors performing the
plume chasing152
. The one-off adjustment costs due to PM12 amount to EUR 23.6 million in 2026, and the
recurrent adjustment costs to EUR 9.4 million per year (see Table 5 and Table 6). Total adjustment costs
due to this measure are thus estimated at EUR 192.9 million, expressed as present value over 2026-2050
relative to the baseline. In addition, PM13 is expected to lead to one-off adjustment costs for national public
authorities for training on cargo securing in the 14 Member States153
that currently do not require minimum
training of inspectors (EUR 26,916 in 2026), and recurrent adjustment costs for the retraining of inspectors
on a biennial basis (EUR 26,916 per year every second year after 2026)154
. Total adjustment costs for PO1b
are thus estimated at EUR 198.3 million (see Table 4), expressed as present value over the 2026-2050
period relative to the baseline, of which EUR 26.5 million one-off costs.
PO2 includes the adjustment costs related to the common measures (PMC2, PMC3, PMC4), the costs
150
These are: BE, FI, IE, NL, MT and PT. FR will introduce PTI for powered two- and three-wheelers and quadricycles in
2024. DK does not have mandatory PTI but since 1 January 2022 it has introduced roadside inspections. In the case of
PT, current requirements cover only motorcycles over 250cc.
151
For a 5% share of the motorcycles fleet one extra RSI unit per Member State is expected to be sufficient. The capital
costs are estimated at EUR 20,000 per unit and maintenance costs are assumed at around 10% of the capital costs.
152
For remote sensing, 250 devices would be needed in EU27 to be able to analyse at least 30% of the road fleet. The
capital cost of a remote sensing equipment is estimated at EUR 85,000. Maintenance and calibration costs are around 5%
of the capital costs, and the cost for the processing and data management EUR 24,000 per year per device. In addition,
one day of training for the use of NOx and PM remote sensing equipment is assumed for the 393 RSI inspectors. For
plume chasing, the capital costs are estimated at EUR 32,500 per equipment. On average, two vehicles are assumed per
Member State, for 26 Member States (DK has already implemented the system). The maintenance and calibration costs
are around 5% of the capital cost. Labour costs are estimated assuming one inspector per plume chasing vehicle and four
days per week of plume chasing. Two days of training on plume chasing are assumed for the 52 inspectors. For acoustic
cameras, the capital costs are estimated at EUR 2,000 per device, and the maintenance cost at 5% of the capital cost. A
half-day training would be needed for 393 RSI inspectors, for using the acoustic cameras.
153
BE, DK, DE, EE, FR, IE, LV, LU, BG, FI, IT, NL, PL and PT.
154
Training for cargo securing is assumed to take 3 hours, with 264 roadside inspectors requiring training.
34
related to PM1 as in PO1a, and the costs related to PM12 and PM13 as in PO1b. To this, PO2 adds one-off
costs for additional roadside equipment and training of inspectors due to the introduction of roadside
inspections for light commercial vehicles (PM14)155
, estimated at EUR 3.1 million in 2026, and recurrent
costs for the maintenance of equipment, estimated at EUR 0.3 million per year156
(see Table 5 and Table
6). Expressed as present value over 2026-2050, the total costs of PM14 are estimated at EUR 8.6 million.
Total adjustment costs for PO2 are thus estimated at EUR 207.2 million, expressed as present value over
2026-2050 relative to the baseline, of which EUR 29.7 million one-off costs.
PO3 includes the adjustment costs related to the common measures (PMC2, PMC3, PMC4) and the costs
related to PM12, PM13 and PM14 as in PO2. Moreover, it adds one-off adjustment costs for the purchase
of additional mobile inspection units due to the introduction of roadside checks for motorcycles (PM15)157
,
estimated at EUR 0.4 million in 2026, and recurrent costs for the maintenance of the inspection units (EUR
40,000 per year from 2026 onwards)158
.Expressed as present value over 2026-2050, thetotal costs ofPM15
are estimated at EUR 1.1 million. Thus, the total adjustment costs for authorities for PO3 are estimated at
EUR 208 million, expressed as present value over 2026-2050 relative to the baseline, of which EUR 30
million one-off costs.
Administrative costs. All policy options include administrative costs for public authorities related to four
common measures (PMC6, PMC7, PMC8 and PMC9). The digitalisation of the roadworthiness certificate
(PMC6)is expectedtoleadto one-offadministrativecosts forthedevelopment ofthesoftware for electronic
certificates, estimated at EUR 17.8 million in 2026159
, and recurrent administrative costs for the
maintenance and update of the system (EUR 0.9 million per year from 2026 onwards)160
. The
interconnection of national vehicle registers (PMC7) would result in one-off administrative costs for
developing the common interfaces for accessing the data, estimated at EUR 8.1 million in 2026 (EUR
300,000 per Member State), and recurrent administrative costs for providing access to the relevant data
(EUR 0.4 million per year from 2026 onwards). Further harmonisation and regular update of technical data
in the registration documents (PMC8) is expected to lead to one-off administrative costs for redesigning
and setting up the new template for the registration documents, estimated at EUR 0.7 million in 2026 and
recurrent administrative costs for the regular update of the vehicle registration documents with new items
thatmaybefoundrelevant inthefuture(EUR 0.5millionperyearfrom2026onwards).Themost significant
administrative costs in all policy options arise from PMC9, under which authorities (except Belgium and
the Netherlands that have already implemented the system) will need to develop a system for the recording
of odometer readings of vehicles at garages and other repair stations. Based on the information provided by
CAR-Pass161
, the one-off cost per database that will be collecting the odometer readings at Member State
155
Few Member States (ES, HU, SE, SK and FI) already conduct roadside inspections for light commercial vehicles.
This measure is thus relevant for 22 MS.
156
The extra inspections will be delivered by an estimated total of 182 inspectors in around 61 roadside inspection units.
These units will need to be equipped with relevant equipment. The one-off cost of the roadside equipment is around EUR
50,000, and the maintenance cost is estimated at 10% of the capital cost. One-day training per inspector is assumed.
157
Few Member States (SE, SI, AT, FI, DK, HU, RO) already perform such inspections and are thus part of the baseline.
158
On the basis of the additional number of inspections to be conducted it is estimated that a total of 32 inspectors will
be needed for the 20 Member States. With an average of 3 inspectors per unit, each Member State will need a minimum
of one additional set of roadside equipment for testing of motorcycles. The one-off cost per equipment is estimated at
EUR 20,000, and the recurrent maintenance cost at 10% of the initial cost. In addition, a one-day training is assumed per
inspector in 2026 for the 32 inspectors.
159
Assuming one-off costs of EUR 500,000 per IT system for each of the 15 Member States with smaller volumes of
inspections (BG, CY, EE, FI, HR, HU, IE, LT, LV, LU, MT, SI, SK, DK and CZ ), EUR 750,000 per IT system for each
of the 7 Member States with medium volumes of inspections (AT, BE, EL, NL, PT, RO and SE) and EUR 1,000,000 per
IT system for each of the 5 Member States with higher volumes of inspections (DE, FR, IT, PL and ES). More details are
provided in Annex 4 (section 3).
160
Assumed at 5% of the capital costs.
161
https://www.car-pass.be/en/
35
level is estimated at around EUR 1 million. Furthermore, the annual cost of operating the system was
estimated at around EUR 0.42 per vehicle (in 2022 prices)162
. In total, one-off administrative costs for
authorities are estimated at around EUR 25 million in 2026, and recurrent costs at EUR 111.4 million in
2030 and EUR 125.6 million in 2050 relative to the baseline163
. Expressed as present value over 2026-2050,
the total one-off and recurrent administrative costs are estimated at EUR 33.7 million for PMC6, EUR 15.4
million for PMC7, EUR 9.4 million for PMC8 and EUR 2.12 billion for PMC9 (see Table 4). Thus, the
administrative costs due to the common set of measures (PMC6, PMC7, PMC8 and PMC9) are estimated
at around EUR 2.18 billion, expressed as present value over 2026-2050, of which EUR 51.6 million one-
off costs.
In PO1a, beyond the costs of the common measures (PMC6, PMC7, PMC8 and PMC9), additional
administrative costs are expected from the introduction of RSI for motorcycles not covered by PTI in six
Member States (PM1), from the digitalisation of the registration certificates (PM16), and from adding new
data elements to the vehicle registers (PM17). The recurrent administrative costs (i.e., labour costs for the
additional inspections) due to PM1 are estimated at EUR 0.5 million in 2030 and EUR 0.6 million in 2050
relative to the baseline164
. For PM16, the one-off costs for the adaptation of the IT system are estimated at
EUR 12.8 million in 2026, while the recurrent costs for maintenance are estimated at EUR 1.3 million per
year165
. The one-off costs for harmonising the dataset in PM17 are estimated at EUR 0.5 million in 2026
and the recurrent costs for continuous data updates and broader maintenance of the dataset at EUR 0.4
million per year. Expressed as present value over 2026-2050, total administrative costs are estimated at
EUR 9.1 million for PM1, EUR 35.8 million for PM16 and EUR 8.4 million for PM17. Altogether, the
administrative costs for authorities under PO1a amount to EUR 2.23 billion expressed as present valueover
2026-2050 relative to the baseline.
On top of the common measures, PO1b includes only one measure that generates administrative costs for
authorities, namely the mandatory inspection of cargo securing (PM13). The recurrent administrative costs
relate to labour costs for the additional cargo securing inspections and are estimated at EUR 0.5
million in 2030 and EUR 0.6 million in 2050 relative to the baseline166
(EUR 9.8 million expressed as
present value over 2026-2050). The total administrative costs for authorities under PO1b are thus estimated
at EUR 2.19 billion, expressed as present value over 2026-2050.
PO2 includes the administrative costs related to the common measures, the costs related to PM1, PM16 and
PM17 as in PO1a, and the costs related to PM13 as in PO1b. In addition, it includes administrative costs
related to two other measures (PM11 and PM14). In the case of PM11 (adaptations related to data
governance ensuring access to vehicle data for PTI centres), total one-off costs for the adaptation of the IT
system are estimated at EUR 13 million in 2026167
, and recurrent administrative costs at EUR 1.3 million
per year168
. This is equivalent to total one-off and recurrent costs of EUR 36.3 million, expressed as present
value over 2026-2050. In addition, the roadside testing of vans (PM14) will also generate recurrent
administrative costs (i.e., labour costs for the additional inspections), estimated at EUR 5.6 million in 2030
162
European Parliament (2018), Odometer Manipulation in motor vehicles in Europe,
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
163
The number of cars and vans relevant for PMC9 are projected at 262.4 million in 2030 and 295.8 million in 2050.
164
The average cost per inspection is estimated at EUR 5.7 and the number of roadside inspections for motorcycles in
PM1 at 82,566 in 2030 and 104,321 in 2050 for the 6 Member States concerned (BE, FI, IE, NL, MT and PT).
165
The one-off costs for the adaptation of the IT system are estimated at EUR 300,000 to EUR 1,000,000 per MS,
depending on the volume of new registrations, and costs for maintenance at 10% of the capital costs.
166
A cargo securing inspection takes on average 20 minutes. Cargo securing inspections are expected to cover 5% of the
N2/N3 fleet in the Member States affected by the measure (EE, FR, IE, LV and LU).
167
Inputs from stakeholders (NL and SI authorities) suggest one-off costs for the adaptation of IT systems in the range of EUR
300,000 to EUR 1,000,000 per country, depending on the volume of PTI inspections per country.
168
Recurrent administrative costs for maintenance are estimated at around 10% of the capital costs.
36
and EUR 6.7 million in 2050169
relative to the baseline (EUR 107.5 million, expressed as present value over
2026-2050). All in all, the one-off and recurrent administrative costs for authorities under PO2 are expected
to amount to EUR 2.39 billion, expressed as present value over 2026-2050.
PO3includes the administrative costs relatedtothecommonmeasures andthecosts related to theadditional
measures under PO2 (except for PM1). In addition, the introduction of RSI for motorcycles (PM15) is
expected to lead to recurrent administrative costs (i.e., labour costs for the additional inspections), estimated
at EUR 1 million in 2030 and EUR 1.3 million in 2050170
(EUR 19.5 million expressed as present value
over 2026-2050). Thus, the total one-off and recurrent administrative costs for authorities due to PO3 would
be close to EUR 2.40 billion, expressed as present value over 2026-2050 relative to the baseline.
Enforcement costs. No enforcement costs for national authorities are expected in PO1a and PO2. In PO1b
recurrent enforcement costs are due to the introduction of mandatory PTI for motorcycles above 125cm3
(PM2) that will imply some extra costs for the authorities that are responsible for monitoring the operation
of the system, for evaluating the quality and impartiality of the additional tests. Recurrent enforcement costs
in PO1b are estimated at EUR 1.7 million in 2030 and EUR 2.1 million in 2050171
(see Table 5), or EUR
32.9 million expressed as present value over 2026-2050 relative to the baseline. Similarly, in PO3, the
extended scope of PTI to all motorcycles (PM3) is expected to result in monitoring costs of EUR 2 million
in 2030 and EUR 2.5 million in 2050 (EUR 38.1 million expressed as present value over 2026-2050) and
the mandatory PTI for light trailers (PM4) will lead to monitoring costs of EUR 2.1 million in 2030 and
EUR 2.3 million in 2050172
(EUR 39.2 million expressed as present value over 2026-2050). Total recurrent
enforcement costs for PO3 are thus estimated at EUR 77.4 million, expressed as present value over 2026-
2050 (see Table 4).
Administrative cost savings. Recurrent cost savings for national administrations arise from the common
measures PMC6 (roadworthiness certificate in electronic format) and PMC7 (the interlinking of national
vehicle registers) in all policy options, as well as from PM16 (issuing digital registration certificates)
included in PO1a, PO2 and PO3. The savings are expected to be significant in all options, and especially
under PO1a, PO2 and PO3, reaching EUR 5.23 billion, expressed as present value over 2026-2050 (see
Table 4). In PO1b they are estimated to be lower, at EUR 3.80 billion. The largest potential savings are
expected from PMC6, due to issuing the roadworthiness certificates in electronic format only, estimated at
EUR 167.3 million in 2030 and EUR 190.6 million in 2050 (EUR 3.16 billion expressed as present value
over 2026-2050)173
. Cost savings related to PMC7, due to the time saved for the re-registration of a vehicle
in another Member State, are estimated at EUR 35.8 million per year from 2026 onwards (EUR 641.8
million expressed as present value over 2026-2050)174
. In addition, PM16 will bring further recurrent
administrative costs savings for national public authorities, by avoiding the costs of printing, distribution
and handling of paper/plastic registration certificates, estimated at EUR 79.3 million in 2030 and EUR 86.3
169
The additional number of inspections due to the measures is estimated at 497,627 in 2030 and 588,721 in 2050. The
cost per inspection is estimated at EUR 11.3.
170
For the 20 Member States concerned (excluding SE, SI, AT, FI, DK, HU, RO that already perform such inspections)
the number of additional inspections is estimated at 176,228 in 2030 and 227,291 in 2050 relative to the baseline. The
cost per inspection is estimated at EUR 5.7.
171
An average monitoring cost of EUR 2.25 per PTI for motorcycles.
172
An average monitoring cost of EUR 1.5 per PTI for light trailers.
173
The cost of a paper roadworthiness (RW) certificate is estimated at 1 EUR per certificate. The number of RW
certificates issued in paper format in the baseline is estimated at 167.3 million in 2030 and 190.6 million in 2050.
174
PMC7 is expected to lead to time savings of around 15 minutes per re-registration of a vehicle in another Member
State because of less need of reaching out to other National Contact Points by phone/mail.
37
million in 2050 (EUR 1.43 billion expressed as present value over 2026-2050)175
.
Net benefits. All policy options are expected to lead to net benefits for national public authorities. Net
benefits, expressed as present value over 2026-2050 relative to the baseline, are estimated to be the highest
in PO1a (EUR 2.99 billion), followed by PO2 (EUR 2.63 billion), PO3 (EUR 2.54 billion) and PO1b (EUR
1.38 billion).
Table 4: Recurrent and one-off costs, and costs savings for national public authorities in the policy options,
expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 7.0 198.3 207.2 208.0
PMC2 0.2 0.2 0.2 0.2
PMC3 1.3 1.3 1.3 1.3
PMC4 3.8 3.8 3.8 3.8
PM1 0.3 0.3
PM9 1.4
PM12 192.9 192.9 192.9
PM13 0.3 0.3 0.3
PM14 8.6 8.6
PM15 1.1
Administrative costs 2,233.8 2,190.4 2,387.5 2,397.9
PMC6 33.7 33.7 33.7 33.7
PMC7 15.4 15.4 15.4 15.4
PMC8 9.4 9.4 9.4 9.4
PMC9 2,122.1 2,122.1 2,122.1 2,122.1
PM1 9.1 9.1
PM11 36.3 36.3
PM13 9.8 9.8 9.8
PM14 107.5 107.5
PM15 19.5
PM16 35.8 35.8 35.8
PM17 8.4 8.4 8.4
Enforcement costs 0.0 32.9 0.0 77.4
PM2 32.9
PM3 38.1
PM4 39.2
Administrative costs savings 5,226.3 3,796.8 5,226.3 5,226.3
PMC6 3,155.0 3,155.0 3,155.0 3,155.0
PMC7 641.8 641.8 641.8 641.8
PM16 1,429.5 1,429.5 1,429.5
Net benefits 2,985.5 1,375.2 2,631.6 2,543.1
Source: Ricardo et al. (2024), Impact assessment support study
175
The costs savings due to PM16 are limited to the time spent for preparing and printing the documents and the costs of
delivering the documents. It is assumed that around 2 minutes of work per document could be saved, at an average cost
per hour for technicians and associate professionals (ISCO level 3) of EUR 34, plus EUR 2 per document for paper and
mail cost.
38
Table 5: Recurrent and one-off costs, and costs savings for national public authorities in the policy options, in
2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Adjustment
costs
4.6 0.1 0.1 36.1 9.6 9.6 39.6 9.9 9.9 39.9 9.9 9.9
PMC2 0.2 0.2 0.2 0.2
PMC3 0.7 0.03 0.03 0.7 0.03 0.03 0.7 0.03 0.03 0.7 0.03 0.03
PMC4 2.1 0.1 0.1 2.1 0.1 0.1 2.1 0.1 0.1 2.1 0.1 0.1
PM1 0.1 0.01 0.01 0.1 0.01 0.01
PM9 1.4
PM12 33.0 9.4 9.4 33.0 9.4 9.4 33.0 9.4 9.4
PM13 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03
PM14 3.4 0.3 0.3 3.4 0.3 0.3
PM15 0.45 0.04 0.04
Administrative
costs
176.9 115.3 129.7 161.9 113.7 128.0 197.1 122.8 138.3 197.6 123.3 139.0
PMC6 18.6 0.9 0.9 18.6 0.9 0.9 18.6 0.9 0.9 18.6 0.9 0.9
PMC7 8.5 0.4 0.4 8.5 0.4 0.4 8.5 0.4 0.4 8.5 0.4 0.4
PMC8 1.2 0.5 0.5 1.2 0.5 0.5 1.2 0.5 0.5 1.2 0.5 0.5
PMC9 133.1 111.4 125.6 133.1 111.4 125.6 133.1 111.4 125.6 133.1 111.4 125.6
PM1 0.5 0.5 0.6 0.5 0.5 0.6
PM11 14.3 1.3 1.3 14.3 1.3 1.3
PM13 0.5 0.5 0.6 0.5 0.5 0.6 0.5 0.5 0.6
PM14 5.4 5.6 6.7 5.4 5.6 6.7
PM15 1.0 1.0 1.3
PM16 14.1 1.3 1.3 14.1 1.3 1.3 14.1 1.3 1.3
PM17 0.9 0.4 0.4 0.9 0.4 0.4 0.9 0.4 0.4
Enforcement
costs
0.0 0.0 0.0 1.6 1.7 2.1 0.0 0.0 0.0 3.9 4.0 4.8
PM2 1.6 1.7 2.1
PM3 1.9 2.0 2.5
PM4 2.0 2.1 2.3
Administrative
costs savings
272.7 282.3 312.7 197.3 203.0 226.4 272.7 282.3 312.7 272.7 282.3 312.7
PMC6 161.5 167.3 190.6 161.5 167.3 190.6 161.5 167.3 190.6 161.5 167.3 190.6
PMC7 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8
PM16 75.4 79.3 86.3 75.4 79.3 86.3 75.4 79.3 86.3
Net benefits 91.2 166.8 182.9 -2.4 78.1 86.7 35.9 149.6 164.5 31.2 145.0 159.0
Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs.
Table 6: One-off costs for national public authorities in the policy options, in 2026, 2030 and 2050, relative to the
baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Adjustment
costs
4.4 0.0 0.0 26.5 0.0 0.0 29.7 0.0 0.0 30.0 0.0 0.0
PMC2 0.2 0.2 0.2 0.2
PMC3 0.7 0.7 0.7 0.7
PMC4 2.0 2.0 2.0 2.0
PM1 0.1 0.1
PM9 1.4
PM12 23.6 23.6 23.6
PM13 0.03 0.03 0.03
39
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
PM14 3.1 3.1
PM15 0.4
Administrative
costs
64.9 0.0 0.0 51.6 0.0 0.0 77.9 0.0 0.0 77.9 0.0 0.0
PMC6 17.8 17.8 17.8 17.8
PMC7 8.1 8.1 8.1 8.1
PMC8 0.7 0.7 0.7 0.7
PMC9 25.0 25.0 25.0 25.0
PM11 13.0 13.0
PM16 12.8 12.8 12.8
PM17 0.5 0.5 0.5
Net costs 69.3 0.0 0.0 78.1 0.0 0.0 107.6 0.0 0.0 107.9 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
6.1.2. Impacts on businesses
This section describes the impacts on affected businesses, primarily PTI stations, but also garage equipment
manufacturers, garages, motor vehicle dealers, various repair workshops, vehicle manufacturers and other
businesses (i.e., vehicle owners). The costs, costs savings and other benefits by policy option are discussed
below, while the detailed calculations by policy measure are provided in Annex 4 (section 3).
6.1.2.1. Impacts on PTI centres
The vast majority of periodic technical inspections are conducted by businesses. In some Member
States periodic technical inspections can be performed by the central licencing authority in the
country and/or public inspection centres (i.e., governmental owned vehicle inspection centres), in
addition (e.g. EL, ES, HU, LV, RO) or instead (e.g. LU) of private inspection centres. On the other
hand, in AT and NL, they are performed by thousands of commercial garages. Annex 6 provides
more details on this point. Given the diversity at Member State level and the fact that in most Member
States PTIs are mostly performed by private inspection centres (e.g., in RO, less than 5% of the tests
are performed by public authorities), the PTI centres were classified under businesses for the purpose
of this impact assessment. The precise share of periodic technical inspections carried out by private
entities is not available.
All policy options result in adjustment costs for PTI centres, while PO2 and PO3 also lead to administrative
costs. On the other hand, all policy options are expected to generate benefits for PTI centres due to the
increased number of inspections, and PO2 and PO3 will also lead to administrative costs savings (see Table
7 to Table 10).
Depending on the Member State, the additional costs for the PTI centres due to the additional
requirements per PTI may be passed through to vehicle owners (i.e. citizens and businesses). This
will depend on how PTI charges are set by the Member State: where prices are not regulated, it is
likely that PTI centres will seek to recover investment costs, possibly on a relatively short term. On
the other hand, in Member States that regulate the level of PTI charges, the evolution of those charges
will depend on the public contract agreed with the PTI service provider, potentially subject to
renegotiation, or on the price-setting policy of the authority that is itself responsible for PTI. In these
cases, costs may either be borne by the service provider/authority or be recovered over a longer
period. Considering the complexity of the process, and the uncertainty related to the degree of pass-
through of the costs as well as the time horizon for passing-through the costs, in this impact
assessment it has been assumed that the additional costs for the PTI centres are partly borne by them
40
(i.e. for those measures that would increase the cost per PTI). On the other hand, the higher costs due
to the increased number of inspections (i.e. due to the extended scope) are fully passed through to the
vehicle owners, and represent benefits for the PTI centres.
Adjustment costs. In PO1a, adjustment costs for PTI centres are only due to common measures included
in all options, namely PMC1, PMC2, PMC3, and PMC4. They cover one-off adjustment costs (see Table
10)for:theacquisitionoftools adaptedtothePTIofelectricandhybridvehicles andtrainingofinspectors176
(PMC1), estimated at EUR 119.8 million in 2026 and EUR 24.4 million in 2030; the software update for
reading on-board diagnostics and training of inspectors177
(PMC2), estimated at EUR 96.1 million in 2026;
the purchase of devices for the PN counting and training of inspectors178
(PMC3), estimated at EUR 372.7
million in 2026; and, the acquisition of NOx measurement equipment and training of inspectors (PMC4)179
,
estimated at EUR 1.48 billion in 2026. In addition, recurrent adjustment costs (i.e., maintenance and
calibration costs) forthePN andNOxmeasurement equipment are assumed at 5%ofthe capital costs,based
on stakeholders’ feedback, and are estimated at EUR 18.1 million per year from 2026 onwards in PMC3
and at EUR 73.3 million per year in PMC4 (see Table 9). Expressed as present value over 2026-2050, the
total one-off and recurrent adjustment costs are estimated at EUR 143.6 million for PMC1, EUR 96.1
million for PMC2, EUR 697.1 million for PMC3 and EUR 2.80 billion for PMC4 (see Table 7). Thus,
PO1a results in total one-off and recurrent adjustment costs of around EUR 3.73 billion, expressed as
present value over 2026-2050 relative to the baseline, of which EUR 2.09 billion one-off costs. The largest
share of total adjustment costs in PO1a is due to PMC4 (75% of the costs), followed by PMC3 (19%).
In PO1b, in addition to the costs entailed by the common measures (same as under PO1a), the mandatory
PTI for motorcycles above 125cm3 (PM2), the annual emission testing for light commercial vehicles
(PM5), the mandatory yearly testing of vehicles that are 10-year-old or older (PM6), the more advanced
testing of noise for motorcycles (PM10), and the additional emission tests for vehicles that are found as
high emitters during remote sensing or plume chasing and are sent for emission tests in a PTI centre
(PM12) will also lead to one-off and recurrent adjustment costs. For PM2, the one-off adjustment costs are
driven by the additional PTI lanes needed to deliver the inspections and the training of inspectors in the
seven Member States where PTI is currently not in place for motorcycles above 125cm3180
and are
estimated at EUR 3.3 million in 2026 and up to EUR 40,000 per year post-2026 (see Table 10)181
, while
the recurrent costs (i.e., maintenance costs for the PTI lanes and labour costs for the additional
inspections)182
are estimated at EUR 8.9 million in 2030 and EUR 11.1 million in 2050 relative to the
baseline. For PM5, the one-off adjustment costs are due to the additional PN and NOx measurement
176
One stakeholder (FSD – the German PTI agency) provided a cost estimate of EUR 500 per tool for measuring
insulation resistance and equipotential bonding. One such tool per PTI centre would need to be acquired in 2026 by the
48,880 PTI centres in the EU, with a second one added in 2030. A three-day training per PTI inspector would be needed
for the 128,536 inspectors across EU.
177
The cost for the software update is estimated at EUR 500 per PTI tool and 128,536 PTI tools in the EU would need to
be updated. A one-day training per inspector would be needed.
178
For the 36,173 PTI centres in the EU affected by this measure (excluding BE, DE and NL, which have already
introduced such testing and are thus part of the baseline), two PN measurement devices per PTI inspection centre would
be needed. The price per PN measurement equipment is estimated at EUR 5,000. An additional half day of training related
to the use of PN-testing for 88,776 inspectors (excluding BE, DE and NL) is assumed to take place in 2026.
179
The cost per NOx measurement equipment is estimated at EUR 15,000 and each of the 48,880 PTI centres in the EU
is assumed to be equipped with two devices. An additional half day training related to the use of NOx testing is assumed
to take place for the 128,536 inspectors across EU.
180
BE, FI, IE, NL, MT, PT and DK.
181
The additional number of inspections in the 7 MS is estimated at 751,660 in 2030 and 941,911 in 2050. 204 additional
PTI lanes would be needed in total over 2026-2050 relative to the baseline. The cost per PTI lane is estimated at EUR
20,000. A two-day training for the additional inspectors is assumed.
182
Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e. EUR 2,000 per lane). The
labour costs per inspection are estimated at EUR 11.3.
41
equipment needed for the annual emission testing of light commercial vehicles and training of inspectors in
all Member States, and are estimated at EUR 20.1 million. At the same time, the recurrent costs associated
with PM5 cover the maintenance costs for the equipment and the labour costs for the additional PN and
NOx testing, and they are estimated at EUR 49.2 million in 2030 and EUR 4.9 million in 2050 relative to
the baseline183
. For PM6, 11 Member States that do not require annual PTI testing of cars and vans after 10
years of their registration would be affected184
. The additional number of PTIs for cars due to PM6 is
estimated at 42.1millionin2030 and47.5millionin2050and for vans at 4.5million in2030 and5.2million
in 2050. Thus, this measure would require a very significant increase in the number of PTI lanes and trained
inspectors over time, with one-off adjustment costs estimated at EUR 1.01 billion in 2026, EUR 4.9 million
in 2030 and EUR 1.7 million in 2050185
(see Table 10). It would also lead to significantly higher
maintenance costs for the PTI lanes and labour costs for performing the inspections, with total recurrent
costs estimated at EUR 886 million in 2030 and EUR 995.7 million in 2050 relative to the baseline. PM10
would result in one-off adjustment costs for the acquisition of noise measurement devices and training of
inspectors in the 23 Member States that currently do not measure L-vehicles noise emissions at PTI186
,
estimated at EUR 4.7 million (see Table 10)187
, andin recurrent costs (i.e.,maintenance costs forthedevices
and labour costs for the additional testing time)188
of EUR 61.8 million in 2030 and EUR 73.7 million in
2050relativetothebaseline. For PM12, the additional number of emission tests for internal combustion
engine vehicles (i.e. for vehicles that are found as high emitters during remote sensing or plume
chasing and are sent for emission test in a PTI centre) is estimated at 2.4 million in 2030 and 174,609
in 2050 relative to the baseline189
. PM12 is expected to lead to additional labour costs for performing
the tests, estimated at EUR 8 million in 2030 and EUR 0.6 million in 2050 relative to the baseline190
.
Expressed as present value over 2026-2050, the costs of PM2 are estimated at EUR 175.7 million, those of
PM5 at EUR 647.7 million, the costs of PM6 at EUR 17.68 billion, those of PM10 at EUR 1.17 billion and
the costs of PM12 at EUR 99 million. Thus, PO1b results in total one-off and recurrent adjustment costs of
around EUR 23.51 billion, expressed as present value over 2026-2050 relative to the baseline, of which
EUR 3.22 billion one-off costs (see Table 7 and Table 8). The largest share of the total adjustment costs in
PO1b is by far due to PM6 (75% of the costs), followed by PMC4 (12% of the costs), PM10 (5% of the
costs) and PMC3 (3% of the costs). The common measures, together, represent only 16% of the costs.
Total one-off and recurrent adjustment costs of PO2 are very similar to those of PO1b, without however
including the costs due to PM2. They are estimated at EUR 23.33 billion, expressed as present value over
2026-2050 relative to the baseline, of which EUR 3.22 billion one-off costs (see Table 7 and Table 8). The
most significant policy measures in terms of costs in PO2 are similar to those in PO1b.
PO3 includes the same adjustment costs as in PO2, but leads to additional one-off and recurrent adjustment
costs for extending the PTI to all motorcycles (PM3), for making PTI mandatory for light trailers (PM4)
183
The recurrent costs decrease over time due to the decreasing number of internal combustion light commercial vehicles
that require PN and NOx testing.
184
CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT and SK.
185
Based on an interview with TUV Rheinland, the cost of a new PTI lane is assumed at EUR 50,000. Each new lane for
cars in 2026 will also require one set of PN and NOx testing equipment. Additional PN testing and NOx testing equipment
is assumed only for cars as the costs for such equipment related to vans is already reflected in PM5.
186
Few MSs (DE, ES, HR and SK) are already measuring L-vehicles noise emissions at PTI.
187
The cost for purchasing a noise measurement device is estimated at EUR 800 per device, and 2 devices are assumed
to be needed for each PTI centre with a test track. A half a day of training is assumed per inspector.
188
Recurrent adjustment costs for the maintenance and calibration of devices are assumed at 5% of the capital cost. The
additional noise testing is estimated to take around 15 minutes per PTI.
189
The decrease in the number of emission tests is driven by the increase in the number of zero-emission vehicles over
time in the baseline.
190
Due to the small share of the fleet affected it is assessed that no additional emission testing equipment will be needed
and that the available PTI lanes will be able to serve the additional demand.
42
and for further harmonisation of test methods (PM7). For PM3, the one-off adjustment costs for extending
the PTI to motorcycles from 50cm3 in the eight Member States where such requirement is currently not in
place191
are estimated at EUR 3.8 million in 2026 and up to EUR 60,000 per year post-2026192
, while the
recurrent adjustment costs at EUR 10.2 million in 2030 and EUR 13 million in 2050 relative to the
baseline193
. For PM4194
, the one-off costs for the additional PTI lanes and the training of inspectors are
estimated at EUR 1 million in 2026 and up to EUR 20,000 per year post-2026195
, and the recurrent costs
(i.e., for the maintenance of the PTI lanes and the labour costs for the additional inspections) at EUR 11.9
million in 2030 and EUR 13.4 million in 2050. In PM7, PTI centres in the Member States with lower-
stringency roadworthiness systems will need to acquire new equipment to enhance their capacity, including
an advanced brake testing device and a suspension tester. One-off costs for equipment and training due to
PM7 are estimated at EUR 367 million in 2026 and EUR 122.2 million in 2030196
, and recurrent costs for
maintenance at EUR 48 million in 2030 and in 2050. Thus, PO3 results in total one-off and recurrent
adjustment costs of EUR 25.06 billion, expressed as present value over 2026-2050 relative to the baseline,
of which EUR 3.71 billion one-off costs (see Table 7 and Table 8). The largest share of the total adjustment
costs in PO3 is by far due to PM6 (71% of the costs), followed by PMC4 (11% of the costs), and PM7 and
PM10 (5% of the costs each). The common measures, together, represent only 15% of the costs in PO3.
Garage equipment manufacturers will benefit from the measures that require the acquisition of new
or more testing equipment by PTI centres197
.
Administrative costs. No administrative costs are expected for PTI centres under PO1a and PO1b. In PO2
and PO3, administrative costs would result from the data governance (PM11), related to the need of the PTI
centres to adapt their IT systems. The one-off administrative costs for the adaptation of the IT systems is
estimated at EUR 1,000 per centre. Total one-off administrative costs would therefore amount to EUR 48.9
million in 2026forthe48,880PTIcentres across theEU (see Table 10). In addition, recurrent administrative
costs for the maintenance of the IT systems are estimated at 10% of the capital costs, or EUR 100 per PTI
centre. Total recurrent administrative costs are thus estimated at EUR 4.9 million per year from 2026
onwards (see Table 9). Overall, PO2 and PO3 are estimated to result in total one-off and recurrent
administrative costs of EUR 136.5 million, expressed as present value over 2026-2050 (see Table 7).
Administrative costs savings. The data governance (PM11), included in PO2 and PO3, is also expected to
lead to administrative costs savings for the PTI centres. The access to relevant technical information would
191
BE, FI, IE, NL, MT, PT, DK and CY (in CY motorcycles above 125cm3 are already covered).
192
As in PM2, the one-off adjustment costs cover the additional PTI lanes needed to deliver the inspections and the training of
inspectors. The cost per PTI lane is the same as in PM2. This is also the case of the time required for the training of inspectors.
193
The recurrent adjustment costs, as in PM2, cover the maintenance costs for the PTI lanes and labour costs for the additional
inspections. More details are available in Annex 4 (section 3).
194
Eleven MS would be affected by PM4: 7 MS where there is currently no requirement for PTI for either O1 or O2 (DK,
EL, FI, FR, NL, IE, PT) and 4 MS where there is currently only a requirement for PTI for O2 (PL, SK, BE and ES).
195
The cost of an additional PTI lane for trailers is estimated at EUR 10,000 per lane.
196
For HDV brake testing using extrapolation methods, an average one-off cost of EUR 2,500 is assumed per PTI centre.
The purchase cost of a suspension tester for light vehicles is around EUR 10,000. Considering the 11 Member States with
lower-stringency roadworthiness systems, 29,922 of the 48,880 PTI centres would have to invest into advanced brake
testing equipment and 28,322 into suspension testers. An average of 4 hours of training is assumed per inspector.
197
Among the common measures and thus in PO1a, the most important in this respect are those related to the new
emission tests (PMC3 and PMC4). In PO1b, PO2 and PO3, these businesses would also benefit from additional demand
for testing equipment generated mainly by annual emission testing of vans (PM5), the noise testing of motorcycles
(PM10), and especially due to the annual PTI for cars and vans above 10 years of age (PM6). The benefits from mandatory
PTI for heavy motorcycles (PM2 in PO1b) would be limited since only a few Member States would be affected. PO3
would bring additional benefits to garage equipment manufacturers through testing all motorcycles and trailers (PM3 and
PM4). Furthermore, PM7 would increase the need for more advanced testing equipment.
43
bring some limited time savings for PTI centres for performing the PTIs198
, with recurrent administrative
costs savings estimated at EUR 87.1 million in 2030 and EUR 99.3 million in 2050 (see Table 9). This is
equivalent to EUR 1.64 billion, expressed as present value over 2026-2050 relative to the baseline (see
Table 7). No administrative costs savings are expected for PO1a and PO1b.
Benefits from additional periodic technical inspections. PTI centres will benefit from the extension of the
scope of PTI and more frequent testing of certain vehicle categories199
. In PO1a, the benefits stemming
from the mandatory roadworthiness testing following significant modifications of the vehicle (PMC5) are
estimated at EUR 45.5 million in 2030 and EUR 52.3 million in 2050, relative to the baseline (EUR 860.5
million expressed as present value over 2026-2050). PO1b includes the same benefits as PO1a, due to the
common measure (PMC5), and adds additional benefits for the PTI centres due to the mandatory PTI for
motorcycles above 125cm3 (PM2), the annual emission testing of light commercial vehicles (PM5), the
mandatory yearly testing of vehicles that are 10-year-old or older (PM6) and the additional emission tests
for vehicles that are found as high emitters during remote sensing or plume chasing and are sent for
emission tests in a PTI centre (PM12). Of these measures, the highest benefits are estimated for PM6
(1.94 billion in 2030 and EUR 2.19 billion in 2050; EUR 36.54 billion expressed as present value over
2026-2050), followed by PM5 (EUR 115 million in 2030 and EUR 9.4 million in 2050; EUR 1.46 billion
expressed as present value over 2026-2050), PM2 (EUR 15.1 million in 2030 and EUR 19 million in 2050;
EUR 294.1 million expressed as present value over 2026-2050) and PM12 (EUR 19.7 million in 2030 and
EUR 1.6 million in 2050; EUR 247.2 million expressed as present value over 2026-2050). Thus, PO1b
results in total benefits of 2.14 billion in 2030 and EUR 2.27 billion in 2050, relative to the baseline (EUR
39.39 billion expressed as present value over 2026-2050). In PO2 the total benefits are slightly lower than
in PO1b as it includes the same measures except for the mandatory PTI for motorcycles above 125cm3
(PM2). They are estimated in total at EUR 2.12 billion in 2030 and EUR 2.26 billion in 2050. Expressed as
present value over 2026-2050, the benefits for PTI centres due to PO2 amount to EUR 39.10 billion. The
highest benefits would be realised under PO3, which in addition to the measures of PO2, adds the extension
of PTI to all motorcycles (PM3) and the mandatory PTI for light trailers (PM4). They are estimated at EUR
2.17 billion in 2030 and EUR 2.31 billion in 2050, relative to the baseline (EUR 39.97 billion expressed as
present value over 2026-2050). PM6 generates around 93% of the total benefits for PTI centres in PO1b
and PO2 and 91% of the total benefits in PO3.
Net costs/benefits for PTI centres. PO1a results in net costs for the PTI centres estimated at EUR 2.87
billion, expressed as present value over 2026-2050 relative to the baseline. On the other hand, PO1b, PO2
and PO3 result in net benefits for the PTI centres, mainly driven by the measure on the yearly testing of
older vehicles. The highest net benefits are estimated for PO2 (EUR 17.27 billion, expressed as present
value over 2026-2050 relativetothebaseline), followed byPO3 (EUR 16.41 billion) and PO1b (EUR 15.89
billion).
Table 7: Recurrent and one-off costs, costs savings and benefits for PTI centres in the policy options, expressed as
present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 3,734.1 23,507.9 23,332.2 25,061.7
PMC1 143.6 143.6 143.6 143.6
PMC2 96.1 96.1 96.1 96.1
198
Time savings of 3 minutes are assumed per PTI. This represents 10% of the average of 30 minutes per PTI for a car.
Not all PTI centres are expected to benefit of this measure, as access to relevant information is often already available. It
is expected that only 30% of PTIs would benefit of PM11.
199
The benefits (i.e. revenues) for the PTI centres are derived based on the number of additional inspections performed
relative to the baseline, depending on the policy measure, and the PTI charges per vehicle category. More details are
provided in Annex 4 (section 3).
44
Difference to the baseline
PO1a PO1b PO2 PO3
PMC3 697.1 697.1 697.1 697.1
PMC4 2,797.3 2,797.3 2,797.3 2,797.3
PM2 175.7
PM3 203.9
PM4 225.4
PM5 647.7 647.7 647.7
PM6 17,680.8 17,680.8 17,680.8
PM7 1,300.2
PM10 1,170.6 1,170.6 1,170.6
PM12 99.0 99.0 99.0
Administrative costs 0.0 0.0 136.5 136.5
PM11 136.5 136.5
Administrative costs
savings
0.0 0.0 1,643.4 1,643.4
PM11 1,643.4 1,643.4
Benefits 860.5 39,394.2 39,100.1 39,968.0
PMC5 860.5 860.5 860.5 860.5
PM2 294.1
PM3 341.3
PM4 526.6
PM5 1,454.8 1,454.8 1,454.8
PM6 36,537.6 36,537.6 36,537.6
PM12 247.2 247.2 247.2
Net benefits -2,873.6 15,886.2 17,274.7 16,413.2
Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs.
Table 8: One-off costs for PTI centres in the policy options, expressed as present value over 2026-2050 relative to
the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 2,094.7 3,221.3 3,217.4 3,708.7
PMC1 143.6 143.6 143.6 143.6
PMC2 96.1 96.1 96.1 96.1
PMC3 372.7 372.7 372.7 372.7
PMC4 1,482.3 1,482.3 1,482.3 1,482.3
PM2 3.9
PM3 4.5
PM4 1.1
PM5 20.1 20.1 20.1
PM6 1,097.9 1,097.9 1,097.9
PM7 485.6
PM10 4.7 4.7 4.7
Administrative costs 0.0 0.0 48.9 48.9
PM11 48.9 48.9
Net costs 2,094.7 3,221.3 3,266.3 3,757.6
Source: Ricardo et al. (2024), Impact assessment support study
45
Table 9: Recurrent and one-off costs, costs savings and benefits for PTI centres in the policy options, in 2026, 2030
and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Adjustment
costs
2,162 115.8 91.4 4,186 1,130 1,177 4,175 1,121 1,166 4,603 1,313 1,241
PMC1 119.8 24.4 0.0 119.8 24.4 0.0 119.8 24.4 0.0 119.8 24.4 0.0
PMC2 96.1 0.0 0.0 96.1 0.0 0.0 96.1 0.0 0.0 96.1 0.0 0.0
PMC3 390.8 18.1 18.1 390.8 18.1 18.1 390.8 18.1 18.1 390.8 18.1 18.1
PMC4 1,556 73.3 73.3 1,556 73.3 73.3 1,556 73.3 73.3 1,556 73.3 73.3
PM2 11.9 8.9 11.1
PM3 13.7 10.2 13.0
PM4 12.3 11.9 13.4
PM5 69.6 49.2 4.9 69.6 49.2 4.9 69.6 49.2 4.9
PM6 1,870 886.0 995.7 1,870 886.0 995.7 1,870 886.0 995.7
PM7 402.8 170.2 48.0
PM10 63.6 61.8 73.7 63.6 61.8 73.7 63.6 61.8 73.7
PM12 8.6 8.0 0.6 8.6 8.0 0.6 8.6 8.0 0.6
Admin costs 0.0 0.0 0.0 0.0 0.0 0.0 53.8 4.9 4.9 53.8 4.9 4.9
PM11 53.8 4.9 4.9 53.8 4.9 4.9
Admin costs
savings
0.0 0.0 0.0 0.0 0.0 0.0 84.1 87.1 99.3 84.1 87.1 99.3
PM11 84.1 87.1 99.3 84.1 87.1 99.3
Benefits 44.1 45.5 52.3 2,086 2,135 2,275 2,071 2,120 2,256 2,115 2,166 2,309
PMC5 44.1 45.5 52.3 44.1 45.5 52.3 44.1 45.5 52.3 44.1 45.5 52.3
PM2 14.8 15.1 19.0
PM3 17.0 17.5 22.1
PM4 26.6 28.0 31.5
PM5 115.8 115.0 9.4 115.8 115.0 9.4 115.8 115.0 9.4
PM6 1,890 1,940 2,192 1,890 1,940 2,192 1,890 1,940 2,192
PM12 21.4 19.7 1.6 21.4 19.7 1.6 21.4 19.7 1.6
Net benefits -2,118 -70.3 -39.1 -2,100 1,006 1,097 -2,073 1,082 1,184 -2,458 934.7 1,163
Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs.
Table 10: One-off costs for PTI centres in the policy options, in 2026, 2030 and 2050, relative to the baseline, in
million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Adjustment
costs
2,071 24.4 0.0 3,111 29.4 1.7 3,107 29.3 1.7 3,479 151.6 1.7
PMC1 119.8 24.4 0.0 119.8 24.4 0.0 119.8 24.4 0.0 119.8 24.4 0.0
PMC2 96.1 0.0 0.0 96.1 0.0 0.0 96.1 0.0 0.0 96.1 0.0 0.0
PMC3 372.7 0.0 0.0 372.7 0.0 0.0 372.7 0.0 0.0 372.7 0.0 0.0
PMC4 1,482 0.0 0.0 1,482 0.0 0.0 1,482 0.0 0.0 1,482 0.0 0.0
PM2 3.3 0.02 0.04
PM3 3.8 0.02 0.06
PM4 1.0 0.02 0.00
PM5 20.1 0.0 0.0 20.1 0.0 0.0 20.1 0.0 0.0
PM6 1,012 4.9 1.7 1,012 4.9 1.7 1,012 4.9 1.7
PM7 367.0 122.2 0.0
PM10 4.7 0.0 0.0 4.7 0.0 0.0 4.7 0.0 0.0
Administrative
costs
0.0 0.0 0.0 0.0 0.0 0.0 48.9 0.0 0.0 48.9 0.0 0.0
46
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
PM11 48.9 0.0 0.0 48.9 0.0 0.0
Net costs 2,071 24.4 0.0 3,111 29.4 1.7 3,156 29.3 1.7 3,528 151.6 1.7
Source: Ricardo et al. (2024), Impact assessment support study
Net costs/benefitsperPTI centre. Lookingat thecosts andbenefits perPTIcentre (seeTable 11),expressed
as present value over 2026-2050, reveals that the highest total costs per PTI centre are expected in PO3
(EUR 516 thousand), followed by PO1b (EUR 481 thousand), PO2 (EUR 480 thousand) and PO1a (EUR
76 thousand). The highest benefits (including costs savings) are however also projected for PO3 (EUR 851
thousand), followed by PO2 (EUR 834 thousand), PO1b (EUR 806 thousand) and PO1a (EUR 18
thousand). The highest net benefits are however estimated for PO2 at EUR 353 thousand, followed by PO3
at EUR 336 thousand and PO1b at EUR 325 thousand, while PO1a results in net costs of around EUR 59
thousand. Net benefits in PO2 represent around 6.3% of the turnover per PTI centre, in PO3 around 6% of
the turnover, in PO1b around 5.8% of the turnover per PTI centre, while the net costs in PO1a around 1.1%
of the turnover.
Table 11: Recurrent and one-off costs, costs savings and benefits per PTI centre in the policy options, expressed
as present value over 2026-2050 relative to the baseline, in thousand EUR (2022 prices) and share of the turnover
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 76.4 480.9 477.3 512.7
Administrative costs 0.0 0.0 2.8 2.8
Administrative costs savings 0.0 0.0 33.6 33.6
Benefits from additional periodic technical inspections 17.6 805.9 799.9 817.7
Net benefits -58.8 325.0 353.4 335.8
Share of turnover (%)
Adjustment costs 1.4% 8.6% 8.6% 9.2%
Administrative costs 0.0% 0.0% 0.1% 0.1%
Administrative costs savings 0.0% 0.0% 0.6% 0.6%
Benefits from additional periodic technical inspections 0.3% 14.5% 14.4% 14.7%
Net benefits -1.1% 5.8% 6.3% 6.0%
Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs.
6.1.2.2. Garages, motor vehicle dealers, tyre and repair stations, etc.
Administrative costs. In all policy options, the requirement for Member States to set up a system to record
odometer readings from the cars and vans registered in their territory (PMC9), is expected to generate one-
off and recurrent administrative costs for vehicle repair shops (including tyre, windscreen service, etc.),
motor vehicle dealers and other garages. One-off costs for software updates, to allow them to transfer their
data to the central national database, are estimated at EUR 229 per company (in 2022 prices)200
. These costs
are relevant for 651,351 companies (470,765 repair shops and garages and 180,586 motor vehicle
dealers)201
, excluding those in Belgium and the Netherlands, which implemented the measure already and
are part of the baseline. Total one-off administrative costs are thus estimated at EUR 149.2 million in 2026.
In addition, recurrent administrative costs (i.e., for the maintenance of the software and the time spent for
200
European Parliament (2018), Odometer Manipulation in motor vehicles in Europe,
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
201
Eurostat, Structural business statistics, Enterprise statistics by size class and NACE Rev.2 activity.
47
recording the odometer readings) are estimated at EUR 19.4 million in 2030 and 14.9 million in 2050
relative to the baseline202
. Thus, total one-off and recurrent administrative costs would amount to EUR 460
million (EUR 706 per company), expressed as present value over 2026-2050. For the purpose of the ‘one
in one out approach’, the average annual recurrent administrative costs over 2026-2035 are estimated at
EUR 19.5 million per year203
. Considering the 651,351 companies relevant for PMC9, the average annual
cost per company is estimated at EUR 29.9. In addition, as explained above, the one-off administrative costs
are estimated at EUR 149.2 million in 2026.
6.1.2.3. Vehicle manufacturers
Administrative costs. In PO2 and PO3, automobile manufacturers will face administrative costs related to
the setting up of a governance framework for providing access to in-vehicle data necessary to carry out PTI
and RSI to inspection centres and competent authorities (PM11). According to one manufacturer, the
adjustments to their IT systems to ensure access to the relevant data are estimated at EUR 1 million. For the
20 manufacturers, the total one-off administrative costs are estimated at EUR 20 million in 2026. Recurrent
administrative costs (i.e., maintenance costs) are estimated at 10% of the capital costs or EUR 100,000 per
vehicle manufacturer. Total recurrent costs would amount to EUR 2 million per year from 2026 onwards.
Expressedaspresent valueover2026-2050,one-offandrecurrent administrativecosts areestimatedatEUR
55.9 million relative to the baseline (EUR 2.8 million per vehicle manufacturer). No administrative costs
are expected for vehicle manufacturers in PO1a and PO1b.
6.1.2.4. Other businesses (vehicle owners)
In all policy options, transport operators and various other businesses that own vehicles will face some
administrative costs linked to additional inspections. In all policy options they will benefit due to the
reduction in odometer fraud, while in PO1b, PO2 and PO3 they will also enjoy additional cost savings.
Administrative costs. In PO1a, the recurrent administrative costs are linked to one common measure
(PMC5), which requires that vehicles undergo a roadworthiness test following any significant modification
that could affect safety or the environmental performance of the vehicle. The number of vehicles affected
by the measure is projected at 0.66 million in 2030 and 0.75 million in 2050 in 20 Member States204
, and
the recurrent costs are estimated at EUR 27.8 million in 2030 and EUR 31.6 million in 2050 relative to the
baseline205
(see Table 13). Expressed as present value over 2026-2050, total administrative costs for PO1a
amount toEUR 524.2million (seeTable12). Somecommonmeasures,likethoserelatedtotheintroduction
of mandatory PN and NOx testing (PMC3 and PMC4), may lead to a higher charge per PTI for vehicle
owners (businesses and citizens), as PTI centres may pass the additional costs of investment in equipment
for these tests to their customers. Due to the very diverse organisation of PTI in Member States206
, including
different organisational and contractual setups between the competent authorities and PTI centres (which
may themselves be run by public authorities or agencies as well as by authorised private companies, large
or small), it is not possible to estimate the extent of such cost pass-through. Whether or not it will happen
and when will depend on the specific situation in each Member State, e.g., on the timespan of existing
202
The recurrent costs are decreasing over time due to the projected uptake of connected vehicles. No manual encoding
is needed for the connected vehicles.
203
This is calculated as a simple average over 2026-2035, non-discounted.
204
Around 0.6% of the vehicle fleet is assumed to undergo significant modifications, based on data for ES and DE. PTI
following modification is already a requirement in HR, FI, AT, NL, DE, SE and ES, and thus part of the baseline. 60%
of the cars registrations and 100% of vans, lorries and buses registrations are undertaken by businesses.
205
The charge per PTI is used to calculate the costs. For businesses, for the categories of vehicles relevant for them, the
average charge per PTI at EU level is estimated at EUR 42.1 per vehicle.
206
Cf. Annex 6, section 2 and 3.
48
agreements, service contracts, if they can be renegotiated or not, etc.207
. On the other hand, it should be
noted that the higher costs due to the increased number of inspections (i.e. due to the extended scope)
are fully passed through to the vehicle owners and reflected in the costs calculations.
In PO1b, in addition to PMC5, the annual emission testing for light commercial vehicles (PM5), the yearly
testing of vehicles that are 10-year-old or older (PM6), the additional emission tests for vehicles that are
found as high emitters during remotesensing or plume chasing andare sent for emissiontests in a PTIcentre
(PM12), and the regular inspection of cargo securing (PM13) will lead to recurrent administrative costs for
businesses. For PM5, affecting all Member States, the additional number of emission testing for internal
combustion light commercial vehicles is estimated at 14.2 million in 2030 and 1.2 million in 2050 relative
to the baseline208
, and the recurrent costs at EUR 115 million in 2030 and EUR 9.4 million in 2050 (EUR
1.46 billion expressed as present value over 2026-2050). For PM6, eleven Member States only require an
inspection every two years for cars and vans after 10 years of their registration209
. Thus, the measure is
expected to result in a doubling of the number of inspections for vehicles over 10 years old in these Member
States, with costs for businesses (vehicles owners) estimated at EUR 1.24 billion in 2030 and EUR 1.40
billionin 2050 (EUR 23.3 billion expressed as present value over 2026-2050). ForPM12, business that own
cars, vans and heavy duty vehicles will incur extra costs for emissions testing if the vehicles are identified
as high emitters via the use of remote sensing or plume chasing and are sent for PTI due to the 0.5% limit
in the capacity for roadside inspections. The recurrent administrative costs are estimated at EUR 14 million
in 2030 and EUR 1.2 million in 2050 (EUR 175 million expressed as present value over 2026-2050)210
. For
PM13211
, the extra costs for the additional time for cooperating on the cargo securing inspections would
amount to EUR 0.44 million in 2030 and EUR 0.55 million in 2050212
(EUR 8.5 million expressed as
present value over 2026-2050). Thus, total administrative costs for PO1b are estimated at EUR 25.46
billion, expressed as present value over 2026-2050. Costs related to PM6 would represent 92% of the total
costs of PO1b.
PO2 includes the same costs as in PO1b, and additional recurrent administrative costs related to the
extension ofthescopeof applicationof roadsideinspections to light commercial vehicles (PM14). The extra
costs for the additional time for cooperating on roadside inspections in PM14213
would amount to EUR 10.9
million in 2030 and EUR 12.9 million in 2050214
(EUR 208 million, expressed as present value over 2026-
2050). Total recurrent administrative costs for PO2 are therefore estimated at EUR 25.67 billion, expressed
as present value over 2026-2050 relative to the baseline. The largest share of the costs in PO2 would be due
to PM6 (91% of the costs).
PO3 includes the same costs as in PO2, and in addition it reflects costs related to the mandatory PTI for
light trailers (PM4). Businesses (vehicle owners) would be affected by PM4 when introduced in eleven
207
For example, in Ireland, the changes introduced by the 2014 RWP have not resulted in any increase in PTI charges. Any price
increasewould requiregovernmentdecisionbased on adetailedbusinesscase.However, the PTIoperator can stillclaim indexation
through the reduction of a levy that it pays to the competent authority after each test, while keeping the charge per PTI unchanged.
208
The decrease in the number of emission testing is driven by the decrease in the number of internal combustion light
commercial vehicles over time. This is due to the Regulation on CO2 standards for LDVs that is included in the baseline.
209
CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT and SK.
210
The cost of an emission test is estimated at 20% of the PTI charge per vehicle. Around 60% of cars and 100% of vans
and heavy duty vehicles are owned by businesses.
211
Owners of heavy-duty vehicles would be affected by the measure to be introduced by 5 MS (EE, FR, IE, LV and LU).
212
They are calculated considering an average hourly labour cost of EUR 21.9 for drivers (ISCO 8 - Plant and machine
operators and assemblers), the average time per inspection of 20 minutes, and the additional number of roadside
inspections (44,813 in 2030 and 55,526 in 2050).
213
22 MS will be affected by the measure (except ES, HU, SE, SK and FI, that already conduct such inspections).
214
They are calculated considering an average hourly labour cost of EUR 21.9 for drivers (ISCO 8 - Plant and machine
operators and assemblers), the average time per inspection of 20 minutes, and the additional number of roadside
inspections (497,627 in 2030 and 588,721 in 2050).
49
Member States215
, with recurrent administrative costs estimated at EUR 20.4 million in 2030 and EUR 23.1
million in 2050 (EUR 385.1 million, expressed as present value over the 2026-2050 period). Total recurrent
administrative costs for PO3 are thus estimated at EUR 26.05billion, expressed as present value over 2026-
2050. Costs related to PM6 represent 89% of the total costs of PO3 and PM5 6% of the costs.
Administrative costs savings. Administrative costs savings are expected to arise in PO1b, PO2 and PO3
from the possibility to avoid emission testing at PTI in case the vehicle passed a roadside inspection or was
found to be in line with the applicable emission limits during a screening by remote sensing (PM12). The
number of PTI tests avoided by businesses due to PM12 is estimated at 11.9 million in 2030 and EUR 1
million in 2050216
. The savings (see Table 12 and Table 13) would amount to EUR 102.6 million in 2030
and EUR 10.1 million in 2050 (EUR 1.29 billion expressed as present value over 2026-2050).
Benefits due to avoided odometer fraud. In all policy options, the requirement for mandatory recording and
reporting to a national central database of vehicle mileage, whenever a vehicle undergoes repair/
maintenance or in the case of tyre changes/replacement (PMC9)217
offers very significant benefits to
businesses in relation to the reduction of odometer fraud, which currently affects around 4.8% of vehicles
in national second-hand sales and 11.3% in cross-border sales. The benefits to businesses due to the avoided
odometer fraud reduction are estimated at EUR 6.35 billion in 2030 and EUR 6.99 billion in 2050218
.
Expressed as present value over 2026-2050 the benefits amount to EUR 118.34 billion, relative to the
baseline. It should however be acknowledged that there is uncertainty regarding the economic damage
caused by odometer fraud and the number of cars affected. For this reason, sensitivity analysis has been
performed and is reported in section 7.5 and Annex 4 (section 7).
Net benefits/costs for businesses (vehicle owners). All policy options are expected to result in significant
net benefits for businesses (vehicle owners), mainly due to the avoided odometer fraud. The highest net
benefits are estimated for PO1a (EUR 117.82 billion), followed by PO1b (EUR 94.17 billion), PO2 (EUR
93.96 billion) and PO3 (EUR 93.58 billion) (see Table 12).
Table 12: Recurrent costs, costs savings and benefits for other businesses (vehicle owners) in the policy options,
expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Administrative costs 524.2 25,458.4 25,666.4 26,051.5
PMC5 524.2 524.2 524.2 524.2
PM4 385.1
PM5 1,454.8 1,454.8 1,454.8
PM6 23,295.9 23,295.9 23,295.9
PM12 175.0 175.0 175.0
PM13 8.5 8.5 8.5
PM14 208.0 208.0
Administrative costs
savings
0.0 1,287.3 1,287.3 1,287.3
PM12 1,287.3 1,287.3 1,287.3
215
7 Member States where there is currently no requirement for PTI for either O1 or O2 (DK, EL, FI, FR, NL, IE, PT)
and 4 Member States where there is currently only a requirement for PTI for O2 (PL, SK, BE and ES).
216
The reason for the decreasing number of PTI tests avoided over time is the increasing share of zero-emission vehicles
in the baseline scenario.
217
PMC9 is relevant for all Member States, except Belgium and the Netherlands that have already introduced such requirement.
218
The average cost of mileage fraud, due to higher purchase price and maintenance costs incurred, is estimated at EUR
2,119 per vehicle in 2022 prices drawing on a Belgian Car-Pass study (https://www.car-
pass.be/files/article_files/file/7/crm%2520study%2520final%2520report.pdf). More explanations are provided in section
2 of Annex 4.
50
Difference to the baseline
PO1a PO1b PO2 PO3
Benefits 118,340.5 118,340.5 118,340.5 118,340.5
PMC9 118,340.5 118,340.5 118,340.5 118,340.5
Net benefits 117,816.3 94,169.4 93,961.3 93,576.3
Source: Ricardo et al. (2024), Impact assessment support study
Table 13: Recurrent costs, costs savings and benefits for other businesses (vehicle owners) in the policy options, in
2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Administrative
costs
27.0 27.8 31.6 1,362 1,394 1,443 1,372 1,405 1,456 1,392 1,425 1,479
PMC5 27.0 27.8 31.6 27.0 27.8 31.6 27.0 27.8 31.6 27.0 27.8 31.6
PM4 19.3 20.4 23.1
PM5 115.8 115.0 9.4 115.8 115.0 9.4 115.8 115.0 9.4
PM6 1,204 1,237 1,400 1,204 1,237 1,400 1,204 1,237 1,400
PM12 14.8 14.0 1.2 14.8 14.0 1.2 14.8 14.0 1.2
PM13 0.4 0.4 0.5 0.4 0.4 0.5 0.4 0.4 0.5
PM14 10.5 10.9 12.9 10.5 10.9 12.9
Administrative
costs savings
0.0 0.0 0.0 109.4 102.6 10.1 109.4 102.6 10.1 109.4 102.6 10.1
PM12 109.4 102.6 10.1 109.4 102.6 10.1 109.4 102.6 10.1
Benefits 6,043 6,353 6,991 6,043 6,353 6,991 6,043 6,353 6,991 6,043 6,353 6,991
PMC9 6,043 6,353 6,991 6,043 6,353 6,991 6,043 6,353 6,991 6,043 6,353 6,991
Net benefits 6,016 6,325 6,959 4,791 5,062 5,558 4,780 5,051 5,545 4,761 5,030 5,522
Source: Ricardo et al. (2024), Impact assessment support study
6.1.3. Impacts on citizens (vehicle owners)
Vehicle owners can be businesses or citizens. This section discusses only impacts on citizens219
. The
impacts on businesses as vehicle owners are discussed in section 6.1.2.4. In all policy options citizens are
expected to be faced with administrative costs, but also with adjustment costs savings and benefits due to
avoided odometer fraud. In addition, PO1b, PO2 and PO3 would result in administrative costs savings (see
Table 14 and Table 15).
Administrative costs for citizens. In PO1a, the recurrent administrative costs for citizens are linked to one
common measure which extends the PTI to cover vehicles with significant modifications (PMC5), and to
the introduction of roadside inspections for motorcycles over 125cm3 as an alternative to PTI (PM1). For
PMC5, the number of vehicles affected is estimated at 0.45 million in 2030 and 0.53 million in 2050 in 20
Member States220
, and the recurrent administrative costs (based on the number of vehicles affected and the
cost per PTI) at EUR 17.7 million in 2030 and EUR 20.6 million in 2050 (EUR 336.3 million, expressed
as present value over 2026-2050). For PM1, the extra costs for the time spent for cooperating on roadside
inspections with the public authorities are estimated at EUR 0.4 million in 2030 and EUR 0.5 million in
219
Around 40% of cars are owned by citizens (see e.g., https://www.transportenvironment.org/challenges/cars/company-
cars/ and https://cleantechnica.com/2022/12/08/european-company-car-market-goes-green/). For motorcycles, it is
assumed that 100% are owned by citizens, in lack of more detailed information.
220
Around 0.6% of the vehicle fleet is assumed to undergo significant modifications, based on data for ES and DE. PTI
following modification is already a requirement in HR, FI, AT, NL, DE, SE and ES, and thus part of the baseline.
51
2050221
(EUR 7.9 million, expressed as present value over 2026-2050). Total administrative costs in PO1a
are thus estimated at EUR 344.2 million, expressed as present value over 2026-2050. As explained in
section 6.1.2.4, some common measures, like those related to the introduction of mandatory PN and NOx
testing (PMC3 and PMC4), may lead to a higher charge per PTI for vehicle owners (businesses and
citizens), as PTI centres may pass the additional costs of investment in equipment for these tests to their
customers. However, as explained in section 6.1.2.4, it is not possible to estimate the extent of such cost
pass-through. On the other hand, it should be noted that the higher costs due to the increased number of
inspections (i.e. due to the extended scope) are fully passed through to the vehicle owners and reflected in
the costs calculations.
In the case of PO1b, in addition to the costs of the common measure (PMC5), there will be some additional
administrative costs for the owners of motorcycles in a few Member States222
as a result of the mandatory
PTI for motorcycles above 125cm3 (PM2), as well as additional costs due to the mandatory yearly testing
of vehicles older than 10 years (PM6) and due to the additional emission tests for vehicles that are found as
high emitters during remote sensing and are sent for emission tests in a PTI centre (PM12). The related
administrative costs for citizens due to PM2 are estimated at EUR 15.1 million in 2030 and EUR 19 million
in 2050 (EUR 294.1 million, expressed as present value over 2026-2050). PM6 generates administrative
costs estimated at EUR 703.4 million in 2030 and EUR 792.3 million in 2050223
(EUR 13.24 billion
expressed as present value over 2026-2050). For PM12, citizens that own cars will incur extra costs for
emissions testing if the vehicles are identified as high emitters via the use of remote sensing and are sent for
PTI due to the 0.5% limit in the capacity for roadside inspections. The recurrent administrative costs are
estimated at EUR 5.8 million in 2030 and EUR 0.3 million in 2050 (EUR 72.2 million expressed as present
value over 2026-2050)224
. Thus, total administrative costs for citizens underPO1b for the period 2026-2050
are estimated at EUR 13.94 billion relative to the baseline.
In PO2, the recurrent administrative costs for citizens are driven by the costs of the common measure
(PMC5), the introduction of roadside inspections for motorcycles over 125cm3 as an alternative to PTI
(PM1), the mandatory yearly testing of vehicles older than 10 years (PM6) and the additional emission tests
for vehicles that are found as high emitters during remote sensing and are sent for emission tests in a PTI
centre (PM12). The total administrative costs for citizens under PO2 for the period 2026-2050 are estimated
at EUR 13.66 billion relative to the baseline.
The highest impact on administrative costs for citizens is expected in PO3, where additional costs relative
to PO2 are due to mandatory extension of PTI to all motorcycles (PM3), mandatory PTI for light trailers
(PM4), and the extension of the scope of application of roadside inspections to 2- and 3-wheeled vehicles
(PM15). PM6 generates by far the highest administrative costs in PO3, estimated at EUR 703.4 million in
2030 and EUR 792.3 million in 2050 (EUR 13.24 billion expressed as present value over 2026-2050). For
PM3, the recurrent administrative costs are estimated at EUR 17.5 million in 2030 and EUR 22.1 million
in 2050225
(EUR 341.3 million over the period 2026-2050), while in PM4 at EUR 7.6 million in 2030 and
EUR 8.4 million in 2050 (EUR 141.5 million, expressed as present value over 2026-2050). Finally, the
extension of the scope of application of roadside inspections to 2- and 3-wheeled vehicles is expected to
221
The additional number of roadside inspections is estimated at 82,566 in 2030 and 104,321 in 2050 in the MS affected
(BE, FI, IE, NL, MT and PT). The average time required for a roadside inspection is estimated at 10 minutes and the
average hourly labour cost at EUR 29.5.
222
BE, FI, IE, NL, MT, PT and DK.
223
11 MS (CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT and SK) only require an inspection every two years for cars and
vans after 10 years of their registration. Thus, the measure is expected to result in a doubling of the number of inspections
for vehicles over 10 years old in these Member States. More details are provided in Annex 4 (section 3).
224
The cost of an emission test is estimated at 20% of the PTI charge per vehicle.
225
The additional number of inspections in the 8 MS affected (BE, FI, IE, NL, MT, PT, DK, CY) is estimated at 869,017
in 2030 and 1,097,479 in 2050. In Cyprus motorcycles above 125cm3 are already covered.
52
result in some costs due to the time spent for cooperating on inspections, estimated at EUR 0.9 million in
2030 and EUR 1.1 million in 2050 (EUR 16.9 million for the period 2026-2050). The total administrative
costs for citizens due to PO3 would amount to EUR 14.15 billion, expressed as present value over 2026-
2050 relative to the baseline (see Table 14).
Other costs for citizens. The measures aimed at increasing the effectiveness of the PTI and RSI, along with
new testing requirements regarding safety, air pollutant emissions and noise, will lead to an increased
number of vehicle owners experiencing repair costs to ensure that their vehicles can pass the PTI inspection
and remain in use. This may mean costs to replace breaks, axles, suspensions systems, lamps, or other
defective components, such as a defective emission control system. It is difficult to estimate these costs as
this may vary significantly in each case and for each vehicle type. Such costs are also expected to be higher
as vehicles get older. Due to the number of uncertainties, it was not possible to develop an estimate of such
costs. It should however be noted that these costs are not considered regulatory costs linked to this initiative.
Adjustment costs savings for citizens. Adjustment cost savings for citizens are expected to come from the
measures related to the recognition of PTI certificates in other Member States, as a result of avoided travel
costs back to the country of vehicle registration for a PTI. The highest costs savings are expected in PO3,
which includes the obligation for PTI certificate issued in any Member State to be recognised by the
Member State of registration (PM7). They are estimated at EUR 228.2 million in 2030 and EUR 254.8
million in 2050, relative to the baseline. Expressed as present value over 2026-2050, the cost savings for
PO3 amount to EUR 4.29 billion relative to the baseline. In PO1b and PO2 the cost savings are driven by
the recognition of the PTI certificate issued by a Member State other than Member State of registration of
up to six months (PM8) and are estimated at EUR 114.1 million in 2030 and EUR 127.4 million in 2050.
Expressed as present value over 2026-2050, they are estimated at EUR 2.14 billion relative to the baseline.
PO1a shows the lowest costs savings for citizens (vehicle owners) among the options, linked to the
recognition of PTI certificates on the basis of bilateral agreements (PM9). The savings are estimated at EUR
49 million in 2030 and in 2050 (EUR 878.2 million relative to the baseline, expressed as present value over
2026-2050).
Administrative costs savings for citizens. Under PO1b, PO2 and PO3, citizens will benefit from
administrative cost savings related to the option for Member States not to require emission testing at PTI
after the vehicle has successfully passed a screening by remote sensing (PM12), i.e., it has been found to
emit below the emission limits applicable to it. The corresponding savings amount to EUR 48.8 million in
2030 and are expectedtodrop to around EUR 2.8 million by 2050 (EUR 591.9 million expressed as present
value over the 2026-2050 period). No administrative costs savings are expected in PO1a.
Benefits due to avoided odometer fraud. In all policy options, the obligation for Member States to record
odometer readings in a national database, as well as to make them available to other Member States in the
case of a re-registration of a vehicle (PMC9), is expected to help reduce odometer fraud in the Member
States where such a system is not currently in place226
(i.e., both in domestic sales of used vehicles and in
cross-border sales, where odometer tampering has been found to be more common). The corresponding
benefits for citizens are estimated at EUR 3.55 billion in 2030 and EUR 3.86 billion in 2050. Expressed as
present value over 2026-2050, they are estimated at around EUR 65.67 billion relative to the baseline. As
explained in section 6.1.2.4, it should be acknowledged that there is uncertainty regarding the economic
damage caused by odometer fraud and the number of cars affected. For this reason, sensitivity analysis has
been performed and is reported in section 7.5 and Annex 4 (section 7).
Net benefits for citizens. All policy options are expected to result in net benefits for citizens (vehicle
owners). Expressed as present value over 2026-2050 relative to the baseline (see Table 14), they are
226
Only BE and NL have introduced such requirement.
53
estimated to be the highest in PO1a (EUR 66.20 billion), followed by PO3 (EUR 56.40 billion), PO2 (EUR
54.75 billion) and PO1b (EUR 54.46 million).
Table 14: Recurrent costs, costs savings and benefits for citizens (vehicle owners) in the policy options, expressed
as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 344.2 13,944.3 13,658.1 14,150.0
PMC5 336.3 336.3 336.3 336.3
PM1 7.9 7.9
PM2 294.1
PM3 341.3
PM4 141.5
PM6 13,241.7 13,241.7 13,241.7
PM12 72.2 72.2 72.2
PM15 16.9
Adjustment costs savings 878.2 2,144.6 2,144.6 4,289.3
PM7 4,289.3
PM8 2,144.6 2,144.6
PM9 878.2
Administrative costs savings 0.0 591.9 591.9 591.9
PM12 591.9 591.9 591.9
Benefits 65,666.9 65,666.9 65,666.9 65,666.9
PMC9 65,666.9 65,666.9 65,666.9 65,666.9
Net benefits 66,200.9 54,459.0 54,745.2 56,398.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 15: Recurrent costs, costs savings and benefits for citizens (vehicle owners) in the policy options, in 2026,
2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Administrative
costs
17.5 18.1 21.1 724.9 742.0 832.3 710.6 727.3 813.8 735.3 752.8 844.9
PMC5 17.1 17.7 20.6 17.1 17.7 20.6 17.1 17.7 20.6 17.1 17.7 20.6
PM1 0.4 0.4 0.5 0.4 0.4 0.5
PM2 14.8 15.1 19.0
PM3 17.0 17.5 22.1
PM4 7.3 7.6 8.4
PM6 686.5 703.4 792.3 686.5 703.4 792.3 686.5 703.4 792.3
PM12 6.5 5.8 0.3 6.5 5.8 0.3 6.5 5.8 0.3
PM15 0.8 0.9 1.1
Adjustment
costs savings
49.0 49.0 49.0 110.7 114.1 127.4 110.7 114.1 127.4 221.5 228.2 254.8
PM7 221.5 228.2 254.8
PM8 110.7 114.1 127.4 110.7 114.1 127.4
PM9 49.0 49.0 49.0
Administrative
costs savings
0.0 0.0 0.0 53.4 48.8 2.8 53.4 48.8 2.8 53.4 48.8 2.8
PM12 53.4 48.8 2.8 53.4 48.8 2.8 53.4 48.8 2.8
Benefits 3,381 3,554 3,857 3,381 3,554 3,857 3,381 3,554 3,857 3,381 3,554 3,857
PMC9 3,381 3,554 3,857 3,381 3,554 3,857 3,381 3,554 3,857 3,381 3,554 3,857
Net benefits 3,412 3,585 3,885 2,820 2,975 3,155 2,834 2,990 3,173 2,920 3,078 3,269
Source: Ricardo et al. (2024), Impact assessment support study
54
6.1.4. Impacts on competitiveness
The stakeholders that participated in the survey were requested to assess the impact of each measure on the
cost and price competitiveness of sectors affected, with a score of 1 representing a very negative impact and
a score of 7 representing a very positive impact. According to the consulted stakeholders, a somewhat
positive impact on the cost and price competitiveness of affected sectors would be expected from the
introduction of new PTI/RSI test requirements (average 3.89). A similarly positive impact on the cost and
price competitiveness of sectors affected is expected by the stakeholders that participated in the survey from
measures widening the scope of vehicles to be tested, and increased frequency of testing for certain vehicle
categories. Finally, recognising PTIs conducted in Member States other than the Member State of
registration would be expected by the stakeholders to achieve almost no impact (average 3.12).
As explained in section 6.1.2.1, the biggest share of the additional adjustment costs for PTI centres
compared to the baseline is related to measures requiring the upgrade of equipment and facilities (PMC3
and PMC4), included in all policy options, the annual emission testing for light commercial vehicles (PM5),
the mandatory yearly testing of vehicles that are 10-year-old or older (PM6) and the requirement for more
advanced emission and noise testing (PM10) in PO1b, PO2 and PO3, and the required investment in new
equipment, including an advanced brake testing device and a suspension tester (PM7) under PO3. To a
lesser extent, the extension of the scope of the vehicles covered (PM3 and PM4) also leads to additional
adjustment costs under PO3. All policy options, and in particular PO1b, PO2 and PO3 will also result in
greater revenue sources for testing centres, thanks to more vehicles having to undergo PTI. Overall, as
explained in section 6.1.2.1, PO2 results in net benefits of EUR 353 thousand per PTI centre expressed as
present value over 2026-2050 relative to the baseline, followed by PO3 with EUR 336 thousand and PO1b
with net benefits of EUR 325 thousand per PTI centre, while PO1a results in net costs of around EUR 59
thousand per PTI centre. Net benefits in PO2 represent around 6.3% of the turnover per PTI centre, in PO3
around 6% of the turnover, in PO1b around 5.8% of the turnover per PTI centre, while the net costs in PO1a
around 1.1% of the turnover. Even though the analysis shows that PO1a may result in net direct costs for
PTI centres, these costs may be passed through to vehicle owners (citizens and businesses) through higher
PTI charges or compensated by the competent public authorities (see discussion on cost pass-through under
administrative costs for other businesses - section 6.1.2.4, and for citizens - section 6.1.3). It can thus be
concluded that PO1a is not expected to have a significant negative impact, while PO1b, PO2 and PO3 are
expected to have very positive impact on the competitiveness of PTI operators.
Garages and other repair workshops will be affected by the requirement to record odometer readings of
every vehicle they service (PMC9). As described in section 6.1.2.2, total one-off and recurrent
administrative costs would amount to EUR 706 per company, expressed as present value over 2026-2050,
which is not expected to have any significant impact on their competitiveness. Some of them, as well as
vehicle manufacturers and dealers already record odometer readings for the purpose of keeping a
maintenance schedule.
Other businesses (vehicle owners) may face somewhat higher costs as a result of the additional PTI costs
and more frequent roadside inspections in all policy options (in particular in PO1b, PO2 and PO3), but the
estimated extra costs in the case of HGVs are limited; they are more significant for passenger cars. At the
same time, a more effective enforcement of the roadworthiness framework will ensure fair competition,
reducing the opportunities for gaining price advantage on the basis of lower vehicle standards, and
avoidance of the required maintenance costs of vehicles.
6.1.5. Impacts on innovation and technological development
Positive impacts on innovation are expected from requiring more stringent and advanced test methods that
also need to be adjusted to the general requirement for a PTI to be quick, simple and affordable. Although
55
new tests, such as PN- and NOx-measurement, ePTI or advanced brake and noise tests are based on existing
technologies, there is still a certain degree of development and adaptation necessary to ensure their
widespread application. The consulted stakeholders expect a positive impact on the innovative capacity of
thesectors affected from measures relatedto newPTI/RSItest requirements, improved access andexchange
of information and the digitalisation of vehicle documents. Furthermore, increased demand for new test
methods and equipment can be expected to generate further development of relevant technologies by
developers of measurement equipment, a viewpoint supported by the representatives of the sector in their
contribution to the stakeholder consultation. Together with that, relevant training of inspectors to the new
test methods will enhance the availability of technical skills and expertise that can have a broader positive
impact. As such, most of the common measures are expected to have some positive impact on innovation
(PMC1 on the testing of electric vehicles, PMC2 using ePTI, PMC3 and PMC4 on new emission tests,
PMC6 on digital PTI certificates, and PMC7 on more efficient exchange of vehicle data).
While in the case of PO1a the digitalisation of the registration certificates (PM16) may require further
innovation, PO1b would introduce remote sensing and plume chasing (PM12) to monitor air pollutants and
noise emitted by vehicles. Remote sensing also relies on existing technologies but requires adaptations to
scale them up to cover the desired share of the vehicle fleet. Deploying these technologies at a larger scale
than today would also necessitate process innovation. PO2 and PO3 combine the benefits of both measures.
6.1.6. Impacts on small and medium enterprises (SMEs)
Periodic technical inspections are in many Member States performed by smaller independent garages.
Moreover, roadside inspections under the RSI Directive have been specifically targeted at commercial
vehicle fleets, which are predominantly operated by SMEs. Garages, motor vehicle dealers, tyre and repair
workshops, etc., almost entirely SMEs, will be affected by the requirement for Member States to set up a
system to record odometer readings from the cars and vans registered in their territory. Therefore, the
initiativeis consideredrelevant forSMEs,andtheSMEtesthasbeenperformed.Moredetailedexplanations
on the impacts on SMEs and SME test (including the four SME steps) are provided in Annex 10.
As explained in section 2.2.3, various forms of tampering affect the safety and environmental performance
of vehicles. Next to odometer fraud, tampering may relate to disconnecting or altering the emission and
noise reduction systems or modifying the performance of the vehicle. As regards possible impacts on the
SME tuning sector, this initiative is not intended to cover legitimate tuning that is authorised and
documented/registered by the competent authorities. It only refers to illegal activity where modifications
are not authorised and documented/registered by the competent authorities. The possible impacts on the
SME tuning sector have thus not been considered.
6.1.7. Impact on the functioning of the internal market and competition
The existing divergence between vehicle registration documents and the information included and quality
of the data stored in the vehicle registers creates challenges in coordinating enforcement actions by Member
States. Furthermore, the non-recognition of roadworthiness certificates among EU Member State creates
additional trade barriers for cross-border operation or sale of vehicles, hindering the efficient functioning of
the internal market, business operations and the freedom of movement of people within the EU. All policy
options are expected to have a positive impact on the functioning of the internal market.
The combination of the measures related to improving the availability and exchange of vehicle-related
information, making the roadworthiness certificate available in electronic format, the specific measure on
odometer fraud, harmonising testing methods, the frequency of testing, requirements for the improvement
of the PTI and the scope of testing, can have a positive impact on the functioning of the internal market and
on competition. Qualitative assessment shows that PO2 and especially PO3 are expected to have the highest
positive impact on the internal market and competition. PO2 incorporates additional measures aimed at
56
extendingroadsideinspections tolight commercialvehicles,andfacilitatingaccesstovehicledatanecessary
for thorough testing by PTI centres. This comprehensive approach is expected to have a stronger impact
than PO1a and PO1b due. PO3 has a stronger positive impact due to PM7, which requires that a PTI
certificate issued in any Member State is recognised by the Member State of registration, as well as further
harmonisation of test methods. In addition, PO3 introduces mandatory PTI for all motorcycles and light
trailers, which are not currently tested by all Member States. The inclusion of L-category vehicles in the
scope of RSI (PM15) is expected to reduce the number of tampered vehicles. PO3 applies more ambitious
measures regarding the standardisation of tests methods than provisions already included in the other policy
options. As such, PO3 is expected to deliver the most significant positive impact on the internal market and
competition. A more detailed discussion is presented in Annex 13.
6.1.8. Territorial impacts
Thereis noinherent bias (positive ornegative) ofthe proposed options towards specific regions or territories
of the European Union, and no specific differences among the different policy options. The underlying
measures are expectedtobeappliedin amoreharmonised wayinterms ofthe test procedures tobe followed
in comparison to the baseline scenario. There may be a limited number of specific issues that arise for
authorities and vehicles owners in different regions of the European Union. These may relate to the
implications of different climatic conditions when performing relevant tests (e.g., warm engine NOx test in
Nordic countries) or the long distances needed to reach a PTI centre, and the extra costs that would arise for
citizens and businesses in less dense and/or remote regions from widening the scope of vehicles subject to
PTI and/or increasing the frequency of testing. Furthermore, there are different profiles of level of
ownership, frequency of use, and size of motorcycles across the EU (e.g., motorcycles in most Southern
European countries are smaller and are used more often for daily commute, in comparison to Northern
European countries where motorcycles are more often used for leisure). In that respect, PO3 (including an
extended scope to motorcycles of more than 50cc) could have a greater impact. However, PTI for smaller
size motorcycles is already mandatory in some Southern European countries including in Italy, Spain, and
Greece. It would be left open to Member States – in the implementation of the specific measures – to adapt
the testing procedures to reflect the specific climatic conditions or to support the operation of mobile PTI
units to minimise the time and cost for citizens in remote areas.
6.1.9. Digital by default
All policy options will have a positive impact on the application of the ‘digital by default’ principle. The
mandatory electronic format of roadworthiness certificates (PMC6) should have a positive impact on
administrative costs for authorities and contribute to digital transformation in the EU. PMC7 will, for the
process of re-registration, save time and costs for authorities and citizens by moving away from information
anddataexchangeviae-mail etc.whichis less efficientin accessingrelevant vehicledata.Theimpact would
be even higher in PO1a, PO2 and PO3 relative to PO1b, as those options also include the issuing of vehicle
registration certificates in electronic format (PM16), combined with an extension of the information to be
included in the certificates (PM17). A digital registration certificate should help reduce time and costs by
making access and exchange of the relevant information easier, faster. The introduction of digital
registration certificates will be a further step towards the alignment of the RWP legal framework with
Regulation (EU) 2018/1724 on the Single Digital Gateway, which requires that Member States ensure that
vehicle registration procedures are delivered in a fully digital way when a citizen moves from one Member
State to another. In all cases the expectation is that while roadworthiness and registration certificates will be
issued in electronic format, there will still be a possibility for vehicle owners to obtain (or print) the relevant
documents with the introduction of a QR code. This should help to minimise accessibility issues arising for
specific parts of the population.
57
6.1.10. Reporting obligations
In should be noted that the current reporting requirements under the three Directives is minimal. Therefore,
there is no scope for further reducing the reporting requirements.
6.2. Social impacts
6.2.1. Impacts on road safety
Given that the general objective of the initiative is to improve road safety in the EU, several measures to
achieve this objective were included in the policy options. Direct impact on road safety is expected due to
the more effective identification of vehicles with major and dangerous defects in the fleet, which should
lead to the reduction of road crashes caused by technical defects and, as a result, to reduced fatalities and
injuries (serious and light). Policy options also include other measures contributing to road safety, which
relate to better implementation and enforcement of the roadworthiness legislation (such as the exchange of
data among Member States’ authorities).
Several assumptions were used to establish the impacts on road safety. They are explained in detail, by
policy measure, in Annex 4 (section 4.1). These inputs227
were subsequently used in the PRIMES-
TREMOVE model to derive the impacts on the number of lives saved and injuries avoided. The impacts
on road safety assessed are only linked to the measures considered in this impact assessment. More detailed
explanations on the impacts by policy option and policy measure are provided in Annex 4 (section 5.1).
It should benotedthat animportant elementinthis assessment relates tothecontribution ofvehicletechnical
defects to road crashes228
. For this assessment, a conservative approach was taken assuming a 4%
contribution of technical defects to road crashes in the case of light-duty vehicles, heavy-duty vehicles and
trailers and 6% in the case of motorcycles. Considering the uncertainty, a sensitivity analysis has been
performed and is included in section 7.5 and Annex 4 (section 7).
All policy options are expected to result in lives saved and injuries avoided relative to the baseline scenario.
Table 16 provides the reduction in the number of fatalities and injuries relative to the baseline in 2030 and
2050, as well as the cumulative number of lives saved, and injuries avoided relative to the baseline over the
2026-2050 horizon. Cumulatively, over the period 2026-2050, PO3 is expected to result in 7,013 lives
saved, followed by PO2 (6,912 lives saved), PO1b (6,847 lives saved) and PO1a (4,661 lives saved). The
numbers of severe and slight injuries avoided follow a similar pattern with PO3 having the highest impact,
followed by PO2, PO1b, and PO1a. More explanations on the impacts by policy option and policy measure
are provided in Annex 4 (section 5.1).
Table 16: Expected reduction in the number of fatalities and injuries in the POs relative to the baseline, in 2030
and 2050, and cumulative reduction over the period 2026-2050
Fatalities Serious injuries Slight injuries
PO1a 2030 195 1,768 9,929
2050 173 1,587 9,011
Cumulative over 2026-2050 4,661 42,272 239,803
% reduction 1.1% 1.2% 1.3%
PO1b 2030 287 2,711 15,099
2050 253 2,420 13,658
Cumulative over 2026-2050 6,847 64,640 364,155
227
See more details in Annex 4 (section 4.1) on the inputs by measure and their aggregation into policy options.
228
As explained in section 2.1.1, various studies indicate that their share as a contributing factor of the cause of crashes
is between 3 and 19%, depending on the scope and methodology of the study; for motorcycles, it is 5% to 12% of crashes.
58
Fatalities Serious injuries Slight injuries
% reduction 1.6% 1.8% 1.9%
PO2 2030 289 2,721 15,162
2050 255 2,429 13,712
Cumulative over 2026-2050 6,912 64,885 365,665
% reduction 1.6% 1.8% 1.9%
PO3 2030 293 2,753 15,274
2050 259 2,460 13,826
Cumulative over 2026-2050 7,013 65,686 368,498
% reduction 1.6% 1.8% 2.0%
Source: Ricardo et al. (2024), Impact assessment support study
Table 17 provides the reduction in the external costs of accidents relative to the baseline, expressed as
present value over the 2026-2050 period. The 2019 Handbook on the external costs of transport229
was used
to monetise the costs230
. As a result of the positive impacts on lives saved and injuries avoided presented
above, PO3 shows the highest impact in terms of reduction in the external costs of accidents relative to the
baseline (expressed as present value over the 2026-2050 period), estimated at EUR 75.2 billion. It is
followed by PO2 with EUR 74.2 billion, PO1b with EUR 73.9 billion, and PO1a with EUR 48.1 billion.
Table 17: Reduction in the external costs of accidents in the POs relative to the baseline, expressed as present
value over the 2026-2050 horizon, in 2022 prices (million EUR)
PO1a PO1b PO2 PO3
Fatalities 11,677 17,498 17,633 17,902
Serious injuries 21,348 33,235 33,299 33,821
Slight injuries 15,053 23,196 23,251 23,521
Total 48,079 73,929 74,183 75,244
Source: Ricardo et al. (2024), Impact assessment support study
6.2.2. Impact on employment
Measures involving an extension of vehicle scope or increase in testing frequency for particular vehicle
categories will lead to additional inspections and the need for additional inspectors to perform them. The
impact on the number of full-time RSI and PTI inspectors employed, relative to the baseline, has been
estimatedonthe basis of the additional number ofinspections required in eachpolicyoption231
.Theimpacts
on the number of full-time RSI and PTI inspectors in 2026, 2030, and 2050, relative to the baseline, are
provided in Table 18 and Table 19, respectively. It should be noted that RSI inspectors are employed by
and generate costs for national public authorities (discussed in section 6.1.1), while PTI inspectors by PTI
centres (included under businesses and discussed in section 6.1.2.1).
Apart from the indirect positive impact on garage equipment manufacturers, related to the need for new
testing equipment (in particular under PMC3 and PMC4), no direct impacts on employment are expected
from the common set of measures. PO1a is expected to increase the number of full-time RSI inspectors by
16 in 2030 and 20 in 2050 relative to the baseline. The impact on employment for PO1a is solely driven by
PM1, which requires additional RSI inspectors to perform inspections of motorcycles over 125cc for those
229
https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1
230
Based on the Handbook, the external cost of a fatality in 2022 prices is estimated at around EUR 3.5 million, that of
a serious injury at around EUR 0.5 million and that of a slight injury at around EUR 0.04 million. These values are
multiplied by the number of fatalities, serious and slight injuries, respectively, to monetise the external costs of accidents
in the context of this impact assessment.
231
The number of inspections per inspector is dependent on the assumed time taken to perform the required procedure and the
location of the test (either at PTI centres or at the roadside).
59
Member States where there is no PTI currently in place. No direct impact on employment for PTI centres
is expected under this policy option.
PO1b is expected to increase the number of full-time PTI inspectors by 18,923 in 2030 and 20,322 in 2050,
relative to the baseline. The increase in employment is mainly a result of PM2 and PM5 (PTI for
motorcycles and annual emission testing for vans), PM6 (the mandatory yearly testing of vehicles that are
10-year-old or older), PM10 (noise testing of motorcycles at PTI) and PM12 (for the additional emission
tests for vehicles that are found as high emitters during remote sensing or plume chasing and are sent
for emission test in a PTI centre). Of these, PM6 is expected to have by far the largest impact as it involves
more frequent testing of around a quarter of the EU car and van fleet. No direct impact on employment for
RSI inspectors is expected under this policy option.
For PO2 the increase in the number of full-time PTI inspectors is slightly lower than in PO1b (18,752 in
2030 and 20,107 in 2050, relative to the baseline). This is driven by the annual emission testing of vans
(PM5), the mandatory yearly testing of vehicles that are 10-year-old or older (PM6), by the noise testing of
motorcycles at PTI (PM10) and by the additional emission tests for vehicles that are found as high
emitters during remote sensing or plume chasing and are sent for emission test in a PTI centre
(PM12).UnlikePO1b,PO2does not includetheeffectofPM2.PO2is alsoexpectedtoincreasethenumber
of full-time RSI inspectors by 204 in 2030 and 243 in 2050, relative to the baseline. The impact of PO2 on
thenumberof full-time RSIinspectors is mostlydueto PM14, whichrequires to extendroadsideinspections
to 2% of the fleet of vans. PM1 also requires additional inspectors relative to the baseline, to inspect
motorcycles over 125cc for those Member States where there is no PTI currently in place.
PO3 measures are expected to lead to 19,047 additional full-time PTI inspectors in 2030 and 20,357 in
2050, relative to the baseline. Similarly to PO2, PO3 includes the impacts of PM5, PM6, PM10 and PM12.
In addition, PM3 and PM4 also require additional inspectors from 2026 in PO3. PO3 is also expected to
lead to an increase in the full-time RSI inspectors of 248 in 2030 and 283 in 2050, relative to the baseline.
The increase in RSI employment for PO3, relative to the baseline, is due to the extension of the RSI scope
to cover vans (PM14) and L-category vehicles (PM15).
Table 18: Increase in the number of full-time RSI inspectors by policy option, relative to the baseline, in 2026,
2030 and 2050
Difference to the baseline
PO1a PO1b PO2 PO3
2026 15 - 197 242
2030 16 - 204 248
2050 20 - 243 283
Source: Ricardo et al. (2023), Impact assessment support study
Table 19: Increase in the number of full-time PTI inspectors by policy option, relative to the baseline, in 2026,
2030 and 2050
Difference to the baseline
PO1a PO1b PO2 PO3
2026 - 18,448 18,281 18,569
2030 - 18,923 18,752 19,047
2050 - 20,322 20,107 20,357
Source: Ricardo et al. (2023), Impact assessment support study
As well as the increase in the number of inspectors employed, there will be benefits from the additional
training for the inspectors that will be needed to be able to deliver the new testing methods. The impact on
inspectors’ skills will be positive for all policy options, with PO3 offering the greatest impact. Furthermore,
the need for additional testing equipment for new test procedures and additional inspections will lead to
60
indirect employment benefits for the wider equipment supply chain and distribution network. In particular,
the demand for additional and new testing equipment will lead to an increase in production-related jobs
within Member States (provided that manufacturing capabilities are available within the EU27). Also, there
will be employment benefits related to providing ongoing maintenance for the new testing equipment. In
particular, measures concerning new emission testing equipment (PMC3 and PMC4) could increase
equipment-related employment.
6.2.3. Impacts on fundamental rights
The policy options were assessedto determineifthey have an impact onthe fundamental rights and/or equal
treatment of EU citizens. The starting point of the assessment of the fundamental rights is the Charter of
Fundamental Rights of the European Union232
. All POs were assessed having regard to the relevant EU
instrument and it was concluded that they maintain full respect for human and fundamental rights, and none
will have any negative impact thereon. A more detailed analysis is provided in Annex 12.
6.3. Environmental impacts
The analysis of environmental impacts covers the air pollutant emissions, CO2 emissions, noise emissions
and natural resources. One of the general objectives is contributing to sustainable mobility, therefore the
environmental benefits are an important justification for the initiative. In the first step, the expected
contribution of each measure on the identification and removal of high emitter vehicles (whether due to
defective emissions control systems or tampering) from the fleet is defined. It is assumed that high emitters
identified will undergo repair (whether this refers to the replacement of malfunctioning filters, sensor or
noise reduction system or the necessary modifications of the engine). The reduction of high emitters by
policy option relative to the baseline is then used as input in the PRIMES-TREMOVE model to calculate
the reduction in air pollutant emissions, and in the external costs of air pollution emissions and noise233
. The
impacts on environmental outcomes assessed are only linked to the measures considered in this impact
assessment. More detailed explanations of the inputs used by policy measure are included in section 4.2 of
Annex 4. A detailed discussion of the impacts on air pollution and noise emissions by policy option is
provided in section 5.2 of Annex 4. A qualitative assessment is provided for the impacts on CO2 emissions
and natural resources.
Impacts on air pollutant emissions. The analysis of the impact on emissions has focused on the two
pollutants that are targeted in the proposed measures, NOx and particulate matter (particulates). Other
pollutants have not been considered although it is possible that by targeting high emitters for these two
pollutants, there will also be benefits related to other air pollutants (e.g. CO, HC, SO2). Table presents the
expected impact on the level of emissions in comparison to the baseline for each policy option. PO2 and
PO3 are expected to have the highest cumulative impact on air pollutants reduction over 2026-2050 (3,969
kilo-tonnes of NOx in PO2 and 3,970 kilo-tonnes of NOx in PO3, and 199 kilo-tonnes of PM in both PO2
andPO3), representing a decreaseof 21% and 18.7% for NOx andPM, respectively, relative tothe baseline.
PO1b shows somewhat lower levels of emissions reductions (20.8% for NOx and 18.5% for PM). PO1a is
expected to bring the least reduction of both air pollutants over the 2026-2050 period (3,176 kilo-tonnes of
NOx, representing a 16.8% reduction relative to the baseline, and 135 kilo-tonnes of PM, representing
12.7% reduction).
232
https://commission.europa.eu/aid-development-cooperation-fundamental-rights/your-rights-eu/eu-charter-
fundamental-rights_en
233
The 2019 Handbook on the external costs of transport (Source: https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs.
61
Table 20: Impact on air pollutant emissions (kilo tonnes of NOx and PM2.5 avoided relative to the baseline in 2030
and in 2050, and cumulative over 2026-2050; % change in cumulative air pollution emissions relative to the
baseline)
2030 2050 Cumulative
over 2026-2050
% change to
baseline
NOx (kilo tonnes of NOx avoided)
PO1a 200.5 12.1 3,176 -16.8%
PO1b 253.1 13.9 3,925 -20.8%
PO2 255.9 14.0 3,969 -21.0%
PO3 255.9 14.0 3,970 -21.0%
PM2.5 (kilo tonnes of PM avoided)
PO1a 7.8 0.6 135 -12.7%
PO1b 12.0 0.8 196 -18.5%
PO2 12.1 0.8 199 -18.7%
PO3 12.1 0.8 199 -18.7%
Source: Ricardo et al. (2024), Impact assessment support study
The external cost savings due to the reduction of air pollutant emissions (NOx and PM) were calculated
using the 2019 Handbook on the external costs of transport234
. PO2 and PO3 are expected to lead to the
highest levels of reduction in external costs, estimated at around EUR 76.1 billion, expressed as present
value over the 2026-2050 period. This is slightly higher than in PO1b (EUR 75.2 billion) and much higher
than in PO1a (EUR 58.7 billion). Results are presented in Table .
Table 21: Reduction in the external costs of air pollutant emissions relative to the baseline, expressed as present
value over 2026-2050, in 2022 prices (million EUR)
PO1a PO1b PO2 PO3
Reduction in external costs related to NOx emissions 46,966 58,054 58,646 58,659
Reduction in external costs related to PM emissions 11,707 17,193 17,429 17,429
Total reduction in external costs of air pollutant emissions 58,673 75,247 76,075 76,088
Source: Ricardo et al. (2024), Impact assessment support study
Impact on noise emissions. The impact on the reduction of high emitters and thereby on noise is expected
to be the lowest in PO1a as it does not contain any measure directly targeted at noise (it has a small positive
impact through 6, the assumed introduction of roadside checks for motorcycles in six Member States where
they are not fully covered by PTI235
). A higher impact is expected in the case of PO1b and PO2, combining
more advanced noise testing in PTI (PM10) and use of remote sensing to support roadside inspections
(PM12). For PO2 and PO3, additional positive impacts can also arise from the increase in roadside
inspection of vans but the highest impacts in terms of noise reduction are expected in PO3, due to the
mandatory RSI for motorcycles (PM15). Table 22 presents the estimated reduction in the external costs of
noise for the four policy options, with PO3 providing the largest savings of around EUR 7.8 billion,
expressed as present value over 2026-2050 relative to the baseline. PO1b and PO2 are expected to bring
similar reductions in the external costs of noise (EUR 7.3 billion over the same period). The reduction under
PO1a would be significantly lower (EUR 0.2 billion). As for the costs of accidents and air pollution, the
external costsofnoisewerecalculatedusingthePRIMES-TREMOVEmodel,basedonthe2019Handbook
on the external costs of transport.
234
https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1
235
BE, FI, IE, MT, NL, PL.
62
Table 22: Reduction in the external costs of noise emissions relative to the baseline, expressed as present value
over 2026-2050, in 2022 prices (million EUR)
PO1a PO1b PO2 PO3
Reduction in external costs related to noise emissions 154 7,323 7,319 7,757
Source: Ricardo et al. (2024), Impact assessment support study
Impact on CO2 emissions and climate change. CO2 emissions are not tested as part of the roadworthiness
and roadside inspections and the measures included in this analysis are not expected to have a direct impact
on the CO2 emissions of vehicles. Any impact on CO2 emissions may only be indirect in case there would
be reductions in the fuel consumption as a result of PTI inspections. Measure PM5 that introduces more
frequent emission testing for vans from year 1, and PM6 on the annual testing of vehicles older than 10
years could potentially have such an impact, but it is expected to remain very limited and has not been
quantified.Thereductioninparticulatematter (soot)is not only expectedtoimprove airquality but probably
also have a positive impact on climate change. Since dark particles absorb sunlight, warm the atmosphere
and cause faster melting of snow and ice, they have a warming effect on the climate236
. However, the extent
of the net impact taking various indirect effects (including in cloud formation) into account is still uncertain
and subject to ongoing research237
. Although such an impact on climate change has not been quantified,
recent calculations indicate that it may be substantial238
.
Impact on natural resources. Some of the measures under consideration are expected to have a direct
impact on the use of natural resources. These include the requirement for the PTI certificate to be issued in
electronic format only (PMC6, included in all policy options), and issuing the registration certificates in
electronic format (PM16, included in PO1a, PO2 and PO3). Both can be expected to bring saving in terms
of the use of paper that will be proportionate to the number of PTIs and vehicle registrations. However, their
impact may be lower in the short term due to continued provision of paper versions on request. The
replacement ofpaperPTIcertificates with digital copies is projectedtoaffect 161.5millionvehicles in2026,
167.3 million vehicles in 2030 and 190.6 million in 2050. The replacement of paper registration certificates
with digital copies is projected to affect 24.1 million new vehicles in 2026, 25.3 million new vehicles in
2030 and 27.6 million in 2050. Hence the savings from electronic PTI certificates are expected to be much
greater than for electronic registration certificates.
Regarding the impact on biodiversity, it is considered that the reduction of NOx emissions from road
transport may also have positive impact on the health of ecosystems, due to their reduced indirect exposure
related to chronic accumulation of nitrogen. This impact, while established in various studies and
reviews239
, was however not analysed and quantified for this initiative since it is expected to be indirect and
limited.
All policy options are consistent with the environmental objectives of the European Green Deal (though
contributing to these objectives at varying degrees as outlined above) and the European Climate Law240
.
All policy options contribute towards Sustainable Development Goals SDG 3. No significant harm is
expected on the environment in any of the policy options.
236
See e.g.https://climate.nasa.gov/explore/ask-nasa-climate/3271/aerosols-small-particles-with-big-climate-effects/
237
See also Bond, T. C., et al. (2013), Bounding the role of black carbon in the climate system: A scientific assessment,
J. Geophys. Res. Atmos., 118, 5380–5552, doi:10.1002/jgrd.50171.
238
Mayer, A.C., Mayer, J., Wyser, M. et al. Particulate Filters for Combustion Engines to Mitigate Global Warming.
Estimating the Effects of a Highly Efficient but Underutilized Tool. Emiss. Control Sci. Technol. (2024).
https://doi.org/10.1007/s40825-023-00236-x
239
Ricardo-AEA Ltd for Natural (2016), Such as the ecological effects of air pollution from road transport: an updated
review.
240
Regulation (EU) 2021/1119
63
7. HOW DO THE OPTIONS COMPARE?
7.1. Effectiveness
The assessment of effectiveness looks at the extent to which the policy options meet the general and specific
objectives (SO) of the intervention. Table provides the link between policy objectives and assessment
criteria.
Table 23: Link between objectives and assessment criteria
Objectives Assessment criteria
General objectives
GO1- Improve road safety in the EU % reduction in the level of fatalities and injuries and associated
external costs
GO2 – Contribute to sustainable mobility % reduction in the level of air pollutant emissions and noise
from road transport and associated external costs
GO3 - Facilitate the free movement of persons and
goods in the Union
Removal of obstacles to re-registration of vehicles in another
MS related to roadworthiness legal framework
Removal of obstacles related to the roadworthiness testing of
vehicles (recognition of certificates issued by other MSs)
Specific objectives
SO1 – Ensure the adequacy, consistency,
objectivity and quality of roadworthiness testing of
today's and tomorrow's vehicles
Use of available test methods and procedures to assess the
roadworthiness of vehicles, including new internal combustion
engine and electric vehicles, and their electronic safety and
emission control systems
SO2 – Significantly reduce fraud and tampering,
and improve the detection of defective vehicles
Impact (% of reduction) on the number of defective vehicles
Impact (% reduction) on the number of vehicles with tampered
emission/noise control system
Impact (% reduction) on the number of vehicles with tampered
odometer
SO3 - Improve electronic storage and exchange of
relevant vehicle identification and status data
Reduction of time/costs associated with the access to relevant
vehicle data by inspection centres and enforcement and
registration authorities.
All policy options contribute to the general objective of increasing road safety in the EU through more
effective identification of vehicles with major and dangerous defect in the fleet. The most effective policy
options are PO3 (7,013 lives saved and 65,686 serious injuries avoided), PO2 (6,912 lives saved and 64,885
serious injuries avoided) and PO1b (6,847 lives saved and 64,640 serious injuries avoided), while for PO1a
a smaller positive effect is expected (4,661 lives saved and 42,272 serious injuries avoided). All policy
options will also contribute to sustainable mobility by reducing air pollutant and noise emissions. This
will lead to a reduction of external costs of these emissions, with the most effective options being PO3
(external costs savings from the reduction of air pollutants and noise estimated at EUR 83.8 billion), PO2
(external costs savings estimated at EUR 83.4 billion) and PO1b (external costs savings estimated at EUR
82.6 billion). PO1a, as the least effective, is expected to bring external costs savings of EUR 58.8 billion.
All policy options will facilitate the free movement of persons and goods in the EU through removal of
obstacles to re-registration of vehicles in another Member State, where PO1a, PO2 and PO3 are expected
to be similarly effective, while PO1b is expected to be less effective due to the absence of measures on
digital vehicle registration certificate and additional data included in the vehicle register. Regarding
removing obstacles related to the roadworthiness testing of vehicles, PO3 is expected to be the most
effective option due to EU wide recognition of PTI certificates in another Member State extended to all
vehicles, followed by PO2 and PO1b (limited EU wide recognition of PTI certificates) and PO1a as the
least effective (bilateral agreements on recognition of PTI certificates).
64
Thanks to the common set of measures, all policy options are effective in reaching the specific objectives.
The differences in their overall effectiveness are linked to their focus, and thus the inclusion of additional
measures aimed at further addressing one or the other specific objective.
As regards SO1, all options can be expected to bring significant benefits through introducing test methods
for the inspection of electric vehicles, improved emission testing for internal combustion engine vehicles
(NOx and PN measurement), and the introduction of testing ADAS and other safety systems required by
theGeneral SafetyRegulation.PO1b, PO2 and PO3 are expectedtoperform betterthanPO1a as they would
bring additional positive impacts through the introduction of mandatory cargo securing inspections and new
ways of testing, such as plume chasing and remote sensing to monitor pollutant and noise emissions. PO2
and PO3 go even further than PO1b with the data governance measures to define the procedures and means
of access to vehicle technical information by PTI centres, that should also contribute to the enhanced quality
and consistency of inspections.
In terms ofthe achievement ofSO2,all options are expectedtoleadtoa reductionofdefective andtampered
vehicles through improved detection, thanks to the new ways of testing, as well as to systematically
addressing odometer fraud. PO1b, PO2 and PO3 are however expected to be significantly more effective,
due to the increase in the scope of vehicles covered (mandatory yearly testing of vehicles over 10 years old).
PO1b and PO3 are more effective than PO2 in reducing the negative externalities associated with
motorcycles (mandatory PTI versus optional in the other two options).
Roadside inspections are an effective complementary measure when it comes to the identification of
tampering of emission and noise control systems, the latter especially for motorcycles, that are much more
difficult to capture as part of the PTI since they are very easy to manipulate. Therefore, PO2 and PO3 are
expected to be more effective, given that both extend RSI to light commercial vehicles, and in the case of
PO3, also to motorcycles. Nevertheless, the differences between PO3 and PO1b and PO2 in terms of the
expected level of reduction of defective vehicles and high emitters are relatively small, essentially linked to
the more comprehensive approach of PO3, i.e. the inclusion of all motorcycles in both PTI and RSI. PO3 is
expected to be the most effective in addressing SO2, closely followed by PO2and PO1b, while PO1a is
expected to be significantly less effective.
In relation to SO3, all options can be expected to make a positive contribution based on the common
measures on the mandatory electronic roadworthiness certificate, access to relevant PTI and registration
data for national authorities by using a common interface and the harmonisation and regular update of
technical data in vehicle registration documents. PO1a, PO2 and PO3 are expected to bring additional
benefits due to the extension of data included in the vehicle register database and the introduction of the
vehicle registration document in digital format. Moreover, PO2 and PO3 are expected to be more effective
than PO1a and PO1b because of improved data governance and enhanced access to relevant vehicle
technical information for PTI centres. Taken together, while there are limited differences among the four
policy options in meeting the SO3, PO2 and PO3 appear to be most effective, followed by PO1a, and PO1b
being the least effective option.
Overall, option PO3 seems to be the most effective when considering the expected contribution towards the
achievement of all general and specific objectives, closely followed by PO2. PO1a is the least effective –
especially in relation to specific objectives SO1 and SO2. PO1b is almost as effective as PO2 in terms of
SO1 and SO2, but is expected to be less effective in the case of objective SO3. A more detailed assessment
of the effectiveness, including quantified impacts per objective can be found in Annex 9.
7.2. Efficiency
Efficiency concerns the ‘extent to which objectives can be achieved for a given cost (cost effectiveness)’.
The estimates of costs and benefits are summarised in Table .
65
Table 24: Summary of costs and benefits of policy options – present value over 2026-2050 compared to the baseline
(in million EUR), in 2022 prices
Difference to the baseline
PO1a PO1b PO2 PO3
PTI centres
Adjustment costs 3,734.1 23,507.9 23,332.2 25,061.7
Administrative costs 0.0 0.0 136.5 136.5
Administrative costs savings 0.0 0.0 1,643.4 1,643.4
Benefits 860.5 39,394.2 39,100.1 39,968.0
Garages, motor vehicle dealers,
tyre and repair stations, etc.
Administrative costs 460.0 460.0 460.0 460.0
OEMs
Administrative costs 0.0 0.0 55.9 55.9
Other businesses - vehicle owners
Administrative costs 524.2 25,458.4 25,666.4 26,051.5
Administrative costs savings 0.0 1,287.3 1,287.3 1,287.3
Benefits 118,340.5 118,340.5 118,340.5 118,340.5
Citizens
Administrative costs 344.2 13,944.3 13,658.1 14,150.0
Adjustment costs savings 878.2 2,144.6 2,144.6 4,289.3
Administrative costs savings 0.0 591.9 591.9 591.9
Benefits 65,666.9 65,666.9 65,666.9 65,666.9
National public authorities
Adjustment costs 7.0 198.3 207.2 208.0
Administrative costs 2,233.8 2,190.4 2,387.5 2,397.9
Enforcement costs 0.0 32.9 0.0 77.4
Administrative costs savings 5,226.3 3,796.8 5,226.3 5,226.3
External costs savings
Air pollution 58,673.1 75,246.6 76,074.5 76,087.7
Accidents 48,078.8 73,929.4 74,183.0 75,244.2
Noise 154.2 7,323.4 7,319.4 7,756.7
Total costs 7,303.3 65,792.3 65,903.9 68,598.9
Total benefits 297,878.5 387,721.5 391,577.8 396,102.1
Net benefits 290,575.2 321,929.2 325,674.0 327,503.2
Benefits to costs ratio 40.8 5.9 5.9 5.8
Source: Ricardo et al. (2023), Impact assessment support study
Total costs are projected to be the lowest in PO1a, estimated at EUR 7.3 billion expressed as present value
over 2026-2050 relative to the baseline, followed by PO1b (EUR 65.8 billion), PO2 (EUR 65.9 billion) and
PO3 (EUR 68.6 billion). Of these, adjustment costs for PTI centres (for equipment, training, and additional
inspectors to perform the inspections) represent around 51% of the total costs in PO1a, 36% in PO1b, 35%
of the total costs in PO2 and 37% in PO3. Administrative costs for other businesses (i.e., vehicle owners),
for additional periodic technical inspections and cooperating on roadside inspections with the public
authorities, represent another important element of the total costs (7% of total costs in PO1a, 39% in PO1b
andin PO2and38%inPO3). This is alsothe caseof administrative costs for citizens (for additional periodic
technical inspections and cooperating on roadside inspections with the public authorities), estimated at 5%
of the total costs in PO1a and 21% of total costs in PO1b, PO2 and PO3. The large share of administrative
costs for other businesses and citizens (i.e., vehicle owners) in PO1b, PO2 and PO3 is related to the
mandatory yearly testing for vehicles that are 10-year-old or older (PM6). Finally, administrative costs for
national public administrations are expected to represent around 31% of the total costs in PO1a and below
4% in PO1b, PO2 and PO3. In PO1a these relate to the setup of the database with odometer readings and
66
the operation of the system (PMC9). Other costs represent a relatively small share of the total costs in all
policy options.
Total benefits are estimated at EUR 297.9 billion in PO1a, EUR 387.7 billion in PO1b, EUR 391.6 billion
in PO2 and EUR 396.1 billion in PO3, expressed as present value over 2026-2050 relative to the baseline.
Of these, external costs savings related to air pollutant emissions, noise emissions and accidents would
represent around 36% in PO1a and 40% in PO1b, in PO2 and in PO3. Benefits for citizens and other
businesses (i.e.,vehicleowners)duetotheavoided odometerfraudwouldrepresent62%ofthetotal benefits
in PO1a, 47% in PO1b and in PO2 and 46% in PO3. In addition, the mandatory yearly testing for vehicles
that are 10-year-old or older (PM6) would lead to additional benefits for the PTI centres in PO1b, PO2 and
PO3 due to the higher number of inspections relative to the baseline. The total benefits for the PTI centres
are estimated at around 10% of the total benefits in PO1b, PO2 and PO3. Other costs savings represent a
relatively small share of the total benefits in all policy options.
Overall, all policy options result in net benefits relative to the baseline. PO3 shows the highest net benefits,
estimated at EUR 327.5 billion expressed as present value over 2026-2050, followed by PO2 (EUR 325.7
billion), PO1b (EUR 321.9 billion) and PO1a (EUR 290.6 billion). PO1a shows the highest benefits to costs
ratio among the options (40.8), followed by PO1b (5.9), PO2 (5.9) and PO3 (5.8).
Among the measures included in the policy options, it should be noted that the setup of the database with
odometer readings and the operation of the system (PMC9, included in all options) is estimated to lead to
the highest benefits to costs ratio (69.8). The mandatory yearly testing for older vehicles (PM6, included in
PO1b, PO2 and PO3) is estimated to lead to benefits to costs ratio of 1.4, the mandatory PTI for light trailers
(PM4, included in PO3) to benefits to costs ratio of 0.7, and the policy measures focusing on motorcycles
to benefits to costs ratios of 2.4 to 20.2. More specifically, for motorcycles the policy measures focusing on
roadside inspections (PM1, included in PO1a and PO2; and PM15, included in PO3) show much higher
benefits to costs ratio (20.2 for PM1 and 18.5 for PM15) than measures extending the PTI (PM2, included
in PO1b with benefits to costs ratio of 2.4; and PM3, included in PO3, with benefits to costs ratio of 2.5).
This is because of the higher effectiveness of the roadside inspections relative to PTI. More details on the
calculation of the benefits to costs ratios for these measures are provided in Annex 4 (section 6).
7.3. Coherence
Internal coherence assesses how various elements of the proposed options are expected to work together
to achieve the objectives. Although all four policy options address the identified specific objectives and
underlying problem drivers, they do so in different ways, and with a different level of intervention. All
policy options ensure internal coherence. Among the four options, PO2 and PO3 are expected to benefit
from a broader range of synergies that can contribute to a higher level of achievement of the objectives.
This is thanks to their more comprehensive approach compared to PO1a and PO1b. Synergies indicated
in relation to PO1a and PO1b are expected to increase in the case of PO2 and PO3, containing more
comprehensive sets of measures and even lead to extra synergies, for example due to measures on
registration certificates and more harmonised registered data. The differences between PO2 and PO3
are limited. They consist in PO3 proposing almost complete harmonisation in the area of roadworthiness
testing: in terms of testing methods, full recognition of PTI certificates, and the full coverage of smaller
motorcycles (down to 50 cm3
) and light trailers by PTI, as well as RSI for motorcycles. On the other hand,
PO2 addresses the bulk of the issues/inconsistencies.
External coherence focuses on the compliance of the initiative with other EU instruments and relevant EU
policies, as well as national policies or international obligations. All identified policy options show strong
links to several EU instruments. In terms of external coherence, all policy options are considered consistent
with relevant EU strategies and legal instruments and contribute to EU policy priorities. PO1b (focussing
67
on more and better testing), as well as PO2 and PO3 perform best when it comes to coherence with the road
safety policies, notably the “Vision Zero” objective. The same is true as regards coherence with the EU’s
green policies, such as the European Green Deal, the Sustainable and Smart Mobility Strategy, the Zero
Pollution Action Plan and the air quality legislation. On the other hand, PO1a, PO2 and PO3 are more
coherent with digital policies (e.g. the Single Digital Gateway, Data Act) than PO1b. In relative terms, PO3
and PO2 are expected to be the most coherent with the policy objectives in related EU legislation and
strategies, followed by PO1b and PO1a being slightly less coherent. In relation to the well-established
national policies in the field, however, stronger interventions, in particular in PO3, are less coherent. This is
further explained under section 7.4 below. Detailed comparison of policy options regarding internal and
external coherence is provided in Annex 14.
7.4. Subsidiarity and proportionality
Regarding subsidiarity, and as described in sections 3.2 and 3.3, EU action is justified on the basis that
MemberStates alone wouldnot be able to reachtheobjectives of the initiative,i.e., updating the harmonised
rules on roadworthiness testing, including coordinated exchange of vehicle-related data. What differentiates
the policy options beyond the common measures necessary to achieve the objectives at a minimum level is
their focus (between PO1a and PO1b) and the extent to which they can fulfil the objectives (PO2 and PO3
going beyond the other two). In terms of proportionality, as the level of intervention and associated costs
increase from PO1a to PO3, the level of positive impacts also increases, although not proportionally (as
shown by the efficiency ratios).
In general, the scope of the options is limited to what can best be achieved at the EU level (in terms of
harmonisation of methods and scope of testing, as well as in finding common solutions to ensure efficient
sharing and access to the necessary vehicle data). All policy options comply with the principle of
subsidiarity and proportionality, with PO3 possibly going somewhat beyond what is necessary to
reach the objectives. This may be the case in particular with requiring full recognition of PTI
certificates, which may not be compatible with existing structural differences in the way Member
States have set up their periodic testing involving, among others, significant differences in pricing,
granting concessions and differences in the structural organisation of the PTIs. In addition, it could
be argued that the need to introduce PTI for light motorcycles and trailers, which primarily circulate
on national territory, may be best assessed by Member States. More detailed analysis on subsidiarity
and proportionality is provided in Annex14.
Table 25 provides a summary of the comparison of the options against the baseline scenario in terms of
effectiveness, efficiency, coherence, subsidiarity, and proportionality. The following ranking symbols have
been used: from '+' (more effective/efficient/coherent/proportionate than the baseline) to '+++' (much more
effective/efficient/coherent/proportionate than the baseline).
Table 25: Comparison of options in terms of effectiveness, efficiency, coherence, subsidiarity and proportionality
relative to the baseline
Impacts PO1a PO1b PO2 PO3
Effectiveness + ++ ++/+++ +++
Road safety (GO1)
Reduced fatalities by 4,661 6,847 6,912 7,013
Reduced severe injuries by 42,272 64,640 64,885 65,686
Reduced slight injuries by 239,803 364,155 365,665 368,498
External cost savings (billion EUR) 48.1 73.9 74.2 75.2
(++) (+++) (+++) (+++)
Air pollution and noise (GO2)
Reduction of NOx emissions (kt) 3,176 3,925 3,969 3,970
68
Impacts PO1a PO1b PO2 PO3
Reduction of PM emissions (kt) 135 196 199 199
External cost savings - emissions (billion
EUR)
58.7 75.2 76.1 76.1
(++) (+++) (+++) (+++)
External cost savings - noise (billion
EUR)
0.2 7.3 7.3 7.8
(0/+) (++) (++) (++)
Free movement of persons and goods
(GO3)
Removal of obstacles to re-registration of
vehicles in another MS
(++) (+) (++) (++)
Removal of obstacles related to the
roadworthiness testing
(+) (++) (++) (+++)
Update of roadworthiness testing (SO1)
Roadworthiness of vehicles (incl. electric)
in terms of their road safety performance
(+) (+++) (+++) (+++)
Roadworthiness of vehicles in terms of
their environmental performance
(+) (+++) (+++) (+++)
Reducing tempering, improving
detection of defected vehicles (SO2)
Reduction defective and tampered
vehicles in terms of emission control
systems
(++) (+++) (+++) (+++)
Reduction of vehicles with tampered
emission/noise control system
(0/+) (+) (++) (+++)
Reduction of odometer tampering (+++) (+++) (+++) (+++)
Benefits due to reduction of odometer
tampering (billion EUR)
118.3 (businesses
owners)
65.7 (consumers)
118.3 (businesses
owners)
65.7 (consumers)
118.3 (businesses
owners)
65.7 (consumers)
118.3 (businesses
owners)
65.7 (consumers)
Electronic storage and exchange of
vehicle identification and status data
(SO3)
Reduction of time/costs related to the
access and exchange of relevant vehicle
data:
(+++) (+) (+++) (+++)
- Cost savings for authorities (billion
EUR)
0.64 0.64 0.64 0.64
- Cost savings for PTI centres (billion
EUR)
1.43 0.0 1.43 1.43
Efficiency +++ ++ ++ ++
Coherence ++ ++ +++ ++
Subsidiarity and proportionality ++ ++ ++ +
Source: Ricardo et al. (2024), Impact assessment support study
7.5. Sensitivity analysis
Sensitivity analysis on contribution of technical defects to road crashes and share of high emitting
vehicles of airpollution and noise in the fleet. As indicated in section 6.2.1, there is significant uncertainty
around the contribution of technical defects to road crashes. The central assumption used is that 4% of road
crashes are caused by technical defects in the case of cars, vans, heavy duty vehicles and trailers and 6% in
the case of motorcycles. A sensitivity analysis has been performed to understand the implications of lower
or higher contribution of technical defects to road crashes. The following cases have been assessed:
- Low case: 3% for motorcycles and 1% for all other categories;
- High case: 9% for motorcycles and 7% for all other vehicle categories.
69
In addition, considering the uncertainty of the share of high emitting vehicles of air pollution and noise in
the fleet, the implications of alternative shares of high and low emitters in the baseline scenario have been
assessed. More specifically, compared to the central case the following assumptions have been used:
- Low case: shares of high emitters 25% lower than in the baseline;
- High case: shares of high emitters 25% higher than in the baseline.
Subsequently, the impacts on external costs and the efficiency of the policy options is assessed for the low
and high case, including both elements related to safety and emissions.
Table 29 presents the impacts on total benefits, net benefits and benefits to costs ratio by policy option in
the low case, central case and high case. It shows that all policy options are expected to result in net benefits
under the three cases considered. It also shows that the ranking of the policy options is not expected to
change in the low case and high case relative to the central case estimates. More details on the sensitivity
analysis, including the details on the external costs by type, are provided in Annex 4 (section 7).
Table 26: Summary of costs and benefits of the policy options in the low case, central case and high case, expressed
as present value over 2025-2050 compared to the baseline (in million EUR, in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Total costs 7,303.3 65,792.3 65,903.9 68,598.9
Total benefits
Low case 282,344.8 347,977.0 351,341.5 355,230.4
Central case 297,878.6 387,721.5 391,578.3 396,102.2
High case 317,762.6 428,602.8 432,933.3 438,106.8
Net benefits
Low case 275,041.5 282,184.7 285,437.6 286,631.5
Central case 290,575.3 321,929.3 325,674.4 327,503.3
High case 310,459.3 362,810.5 367,029.4 369,507.9
Benefits to costs ratio
Low case 38.7 5.3 5.3 5.2
Central case 40.8 5.9 5.9 5.8
High case 43.5 6.5 6.6 6.4
Source: Ricardo et al. (2024), Impact assessment support study
Sensitivity analysis on odometer fraud. As explained in sections 6.1.2.4 and 6.1.3, it should be
acknowledged that there is uncertainty regarding the economic damage caused by odometer fraud and the
number of vehicles affected. For this reason, sensitivity analysis has been performed on the economic
damage caused by odometer fraud and the number of vehicles affected.
With regard to the economic damage caused by odometer fraud, a central estimate of EUR 2,119 per
vehicle has been used and it is explained in more detail in Annex 4 (section 2). The following cases have
been assessed:
- Low economic damage case: 20% lower damage costs/costs savings per vehicle (EUR 1,696 per
vehicle);
- High economic damage case: 20% higher damage costs/costs savings per vehicle (EUR 2,543 per
vehicle).
70
With regard to thenumber of vehicles affected, the central assumptions used for the shares of vehicles with
tampered odometers areprovided in Annex 4 (section 2), Table 37.Thefollowing cases have been assessed:
- Fewer vehicles affected case: share of affected vehicles 20% lower than in the central case;
- More vehicles affected case: share of affected vehicles 20% higher than in the central case.
In addition,thecombinedimpact ofthe economicdamagecausedbyodometer fraudandvehiclesaffected
has been assessed as follows:
- Low economic damage and vehicles affected case: 20% lower damage costs/costs savings per
vehicle (EUR 1,696 per vehicle) and the share of affected vehicles 20% lower than in the central
case;
- High economic damage and vehicles affected case: 20% higher damage costs/costs savings per
vehicle (EUR 2,543 per vehicle) and the share of affected vehicles 20% higher than in the central
case.
Subsequently, the impacts on the benefits due to avoided odometer fraud and the efficiency of the policy
options is assessed for the low case and for the high case. In this section, only the combined impact of the
sensitivity analysis for economic damage caused by odometer fraud and vehicles affected is presented. The
results of the separate sensitivity analysis for the economic damage caused by odometer fraud and for the
number of vehicles affected is presented in Annex 4 (section 7).
Table 27 presents the impacts on total benefits, net benefits and benefits to costs ratio by policy option in
the low economic damage and vehicles affected case, central case and high economic damage and vehicles
affected case. It shows that all policy options are expected to result in net benefits under the three cases
considered. It also shows that the ranking of the policy options is not expected to significantly change in the
low economic damage and vehicles affected case and high economic damage and vehicles affected case
relative to the central case estimates. More details on the benefits due to avoided odometer fraud in each
case are provided in Annex 4 (section 7).
Table 27: Summary of costs and benefits of the policy options in the low economic damage and vehicles affected
case, central case and high economic damage and vehicles affected case, expressed as present value over 2025-
2050 compared to the baseline (in million EUR, in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Total costs 7,303.3 65,792.3 65,903.9 68,598.9
Total benefits
Low economic damage and vehicles
affected case
231,635.9 321,478.8 325,335.2 329,859.5
Central case 297,878.5 387,721.5 391,577.8 396,102.1
High economic damage and vehicles
affected case
378,841.8 468,684.7 472,541.1 477,065.4
Net benefits
Low economic damage and vehicles
affected case
224,332.5 255,686.6 259,431.3 261,260.6
Central case 290,575.2 321,929.2 325,674.0 327,503.2
High economic damage and vehicles
affected case
371,538.5 402,892.5 406,637.2 408,466.5
Benefits to costs ratio
Low economic damage and vehicles
affected case
31.7 4.9 4.9 4.8
Central case 40.8 5.9 5.9 5.8
71
Difference to the Baseline
PO1a PO1b PO2 PO3
High economic damage and vehicles
affected case
51.9 7.1 7.2 7.0
Source: Ricardo et al. (2024), Impact assessment support study
8. PREFERRED OPTION
8.1. Identification of the preferred policy options and stakeholder views
Each of the policy options addresses the problems identified, their drivers and the specific objectives,
however some options are more effective in achieving the specific and general objectives. As indicated in
the previous sections, PO3 is the most effective option, as it performs best or among the best under all
assessment criteria (cf. Annex 9), since it aims to fill most regulatory gaps. It is followed very closely by
PO2, with PO1b and PO1a being less effective (especially PO1a at least in terms of bringing quantifiable
benefits). The fact that PO1a and PO1b perform less well on certain aspects is due to their focus on better
exchange of data (PO1a) and on better testing (PO1b), while PO2 and PO3 combine the key measures of
the first two options. While PO1b performs very well in relation to the objectives of improving road safety
(GO1) and reducing the number of high-emitting vehicles (GO2), PO1a does so in terms of improving free
movement (GO3). The advantages of PO2 and PO3 become clear when comparing the options against the
specificobjectives,wherethey achievehigh scores whilePO1aandPO1b arelimitedbytheirspecific focus.
PO1a is the least effective, especially in relation to specific objectives SO1 and SO2.
On the other hand, in terms of efficiency, PO1a performs much better as it generates the lowest costs, while
PO1b, PO2 and PO3 are more costly but also bring more benefits. PO1a is the most efficient option, with
benefits to costs ratio estimated at 40.8. PO1b, PO2 and PO3 show very similar benefits to costs ratio (5.8
to 5.9). In terms of net benefits that can be quantified, PO1b, PO2 and PO3 perform significantly better
than PO1a, while the quantifiable differences among these three options are relatively limited (they are
essentially down to the measures extending PTI or RSI to relatively smaller groups of vehicles). In addition,
compared to PO1b, PO2 brings cost savings for PTI centres due to improved data governance, as well as
increased and more accessible data for authorities and inspection centres in PO2 as compared to PO1b
which facilitates re-registration and roadside inspections. The efficiency and the net benefits of PO2 and
PO3 would further increase compared to PO1b if the benefits related to achieving the objectives related to
free movement (GO3) could be quantified. PO2 appears to strike the best balance between achieving the
objectives to a high degree, while performing at better the other options in terms of internal and external
coherence (by combining the most important measures of PO1a and PO1b while not having issues with
external coherence as PO3), as well as in terms of subsidiarity and proportionality (by including only what
is most needed to achieve the objectives).
While all options include the most efficient policymeasure (PMC9 addressing odometer fraud), which offer
very high benefits compared to limited costs, only PO1b, PO2 and PO3 feature relatively costly measures
that introduce new testing requirements. Among them, the mandatory yearly testing of vehicles older than
10 years generate the highest costs, but also the largest benefits, both in terms of road safety and emission
reductions. Crucially, this measure also generates a significant number of jobs, especially in Member States
where the automotive industry is facing historical challenges. Comparatively, the measures differentiating
between PO2 and PO3 are less significant, albeit still relevant. The detailed costs and benefits of those
measures are outlined in Annex 4, section 5 and 6.
PO2 addresses all identified issues in a comprehensive manner by adapting roadworthiness testing to new
vehicles with a capability of identifying a significant share of high-emitters and various forms of tampering,
including odometer fraud with the help of digitalisation and better exchange of vehicle data. What PO2 does
not do in comparison to PO3 is mandatory PTI for all motorcycles, trailers, including lighter ones, and the
72
full recognition of PTIs conducted in another Member State with further harmonisation of test methods.
While these measures could bring further benefits, they appear to be limited in comparison to the costs and
additional administrative efforts required, and thus lower the efficiency of PO3. In relation to the well-
established national policies in the field, PO3 also appears to be less coherent than PO2, and regarding the
full recognition of PTI certificates, PO3 could be going beyond what is necessary to reach the
objectives and it may not be compatible with existing structural differences of PTI testing setup in
the Member States.
The analysis above points at PO2 as the preferred policy option, given it is considered effective
in reaching the policy objectives, it presents high efficiency and net benefits and it appears to be
coherent with the well-established national policies in the field, while including in its set of measures
only those which are needed to achieve the objectives.
The preferred option enjoys the support of the PTI industry (CITA, FSD and others) as well as FIA, testing
equipment (EGEA) and motorcycle manufacturers (ACEM). It is supported also by some Member States,
notably those that rely on thousands of smaller roadworthiness testing centres. Regarding access and
exchange of information, various respondents (including CITA, EGEA and EReg), underlined the
importance of free and easy access to in-vehicle data to enable the proper inspection of vehicles.
Stricter cargo securing requirements included in this option are strongly supported by the logistics industry.
Various industry respondents, including PTI operators, called for the extension of the PTI Directive
to cover all road vehicles. While stakeholders belonging to motorcyclists’ groups at EU or national
level did not support such extension of the PTI to motorcycles in the OPC, in the survey most of the
respondents supported mandatory PTI for motorcycles with the objective to reduce tampering and
the detection of defected vehicles. Stakeholders also noted that many Member States already required
a PTI for motorcycles, as well as for tractors and/or trailers.
All policy options include mandatory testing after significant modification of a vehicle, which was
supported by stakeholders in the survey. Regarding the increased frequency of testing, PO2
introduces annual emission testing for vans, and it also contains a requirement for an annual PTI for
vehicles over 10 years old, both these measures being supported by a majority of stakeholders in the
survey.
Regarding the recognition of PTIs conducted in another Member State, PO3 introduces a full
recognition, while PO2 requires the recognition of the PTI from another MS than the MS of
registration for a period of up to 6 months. Stakeholder views on this differ to quite some extent:
vehicle owners and those not directly involved in PTI inspections tended to be more in favour of the
mutual recognition of PTI certificates under certain conditions, although some recognised that the
mutual recognition under bilateral agreements would be a good first step. Those more actively
involved with inspections were concerned that the difference between the approach taken to PTIs in
different Member States meant that mutual recognition would be difficult and potentially lead to
adverse effects on safety. Concerns were also raised that mutual recognition without the increased
harmonisation of PTIs would lead to “PTI tourism”, where drivers had their vehicles tested in
countries where it was easier to pass a PTI.
All policy options tackle odometer tampering. New methods for tackling odometer fraud were
considered as necessary by 69% (107) respondents in the OPC and adding odometer data to the
vehicle register was welcomed by 72% (111) respondents in the OPC. In the consultations, in relation
to odometer readings, some stakeholders suggested that it should be mandatory to record odometer
data at certain events, such as following accidents and the transfer of ownership, and that potential
buyers should have access to all this information. Not all stakeholders were however positive about
73
this measure: some called on odometer system manipulation to be addressed via type-approval
legislation, rather than the revision of the PTI Directive (FIA), and others questioned the potential
inclusion of new methods to tackle odometer fraud, arguing that inspection organisations did not
have the legal means or ways to detect and sanction such fraud (CITA).
Regarding the content of RSI, a majority of respondents (81% and 77% respectively) thought that
PN testing for commercial vehicles and NOx and noise testing for all vehicles using remote sensing
would improve the detection of defective vehicles and reduce tampering. In the OPC, a small majority
supported extended emission testing (e.g., NOx and PN), including the use of remote sensing
equipment, during RSI. Regarding cargo securing, there was a high level of support for mandatory
checks during roadside inspections of commercial vehicles to ensure the safe securing of cargo,
expressed in the survey and OPC.
In relation to introducing RSI to light commercial vehicles, around three quarters of respondents
thought that the extension of the scope of the RSI to light commercial vehicles would contribute to
better detection of defective and tampered vehicles, but some stakeholders also suggested that this
could bring additional costs, in terms of lost time, for SMEs operating such vehicles.
Regarding access and exchange of information/data, two-thirds of respondents in OPC supported
clarifying the existing rules on access to in-vehicle data. Vehicle and equipment
manufacturers/suppliers were less supportive of this provision than others. In response to the open
survey and interview questions, various respondents (including CITA, EGEA and EReg), underlined
the importance of free and easy access to in-vehicle data to enable the proper inspection of vehicles.
Finally, all policy options include measures aimed at facilitating exchange of PTI and registration
data. PO1a, PO2 and PO3 furthermore introduce measures on the digitalisation of registration
certificates and new data sets to be included. A large majority of stakeholders supported these
measures. National authority respondents highlighted that 17 Member States already used Eucaris
for the purpose of data exchange, and that this system worked well. They underlined that data on the
vehicle register should be harmonised and available to all organisations that were involved in
undertaking PTIs and RSIs for national authorities. EReg called for a larger set of data to be included
in the vehicle register and generally supported the digitalisation of the vehicle registration documents
and the mutual recognition of these. Various national authorities, and users, underlined the
importance of the data in the vehicle register being up to date as soon as relevant changes happen.
More details on stakeholder views are provided in Annex 2.
8.2. REFIT (simplification and improved efficiency)
This initiative is included in the Commission Work Programme 2023241
, item 3 in Annex II: REFIT
initiatives, under headline A – A European Green Deal. It contributes to increasing the efficiency of the
existing legislation in various ways: by replacing obsolete test methods with stat-of-the art solutions both at
periodic as well as at roadside checks by requiring to use the most recent measurement techniques and
technology to more effectively detect a large number of high-emitting vehicles; by introducing simple,
nevertheless meaningful tests to check the safety and environmental performance of modern vehicles in a
harmonised way; by interconnecting national databases to help share and access vehicle data that otherwise
would be exchanged using more cumbersome procedures. The initiative is expected to significantly reduce
fraud related to emission and safety-relevant systems as well as to the stated mileage of used vehicles
241
2023 Commission work programme – key documents (europa.eu)
74
especially in cross-border sales and would thus lead to significant savings in external costs as well as in
avoided damage to consumers.
8.3. Application of the ‘one in, one out’ approach
PO2 is expected toleadto administrative costs forPTI centres and vehiclemanufacturers due tothemeasure
on data governance (PM11), and for garages, motor vehicle dealers, tyre service and repair stations due to
the measure on odometer readings (PMC9).
For PTI centres, the one-off administrative costs for the adaptation of their IT systems are estimated at
EUR 1,000 per centre. Total one-off administrative costs would amount to EUR 48.9 million in 2026, for
the 48,880 PTI centres across the EU. The recurrent administrative costs for the maintenance of the IT
systems are estimated at 10% of the capital costs, or EUR 100 per PTI centre. Total recurrent administrative
costs are thus estimated at EUR 4.9 million per year from 2026 onwards.
Vehicle manufacturers will also need to adjust their own IT systems to ensure access to the relevant data.
The one-off costs are expected to be around EUR 1 million per vehicle manufacturer, with total one-off
administrative costs of EUR 20 million in 2026 for the 20 vehicle manufacturers across the EU. Recurrent
administrative costs are estimated at 10% of the capital costs or EUR 100,000 per vehicle manufacturer.
For the 20 vehicle manufacturers, they amount to EUR 2 million per year from 2026 onwards.
The costs for the garages, motor vehicle dealers, tyre service and repair stations will relate to possible
software updates to allow them to transfer their data to the central national database, maintenance costs for
the software and the time needed to record the odometer readings. Based on input from Car-Pass and the
European Parliament study242
, the costs for software updates are estimated at EUR 229 per garage in 2022
prices243
. In PMC9 these costs are relevant for 651,351 companies (470,765 repair shops and garages across
the EU and 180,586 motor vehicle dealers)244
, excluding those in Belgium and the Netherlands, which
implemented the measure already and are part of the baseline. Total one-off administrative costs are thus
estimated at EUR 149.2 million in 2026. In addition, for the purpose of the ‘one in one out approach’, the
average annual recurrent administrative costs over 2026-2035 are estimated at EUR 19.5 million per year245
or EUR 29.9 per company.
In total, the additional one-off administrative costs relative to the baseline relevant for the ‘one in one
out approach’ in PO2 are estimated at EUR 218 million in 2026. Expressed as annualised net present
value over the relevant period they amount to EUR 25.5 million. In addition, the recurrent
administrative costs relative to the baseline amount to EUR 26.4 million per year. Thus, the total
additional administrative costs (one-off and recurrent) relevant for the ‘one in one out approach’ in
PO2 are estimated at EUR 51.9 million per year relative to the baseline. Other administrative costs for
citizens and businesses (i.e., vehicle owners) in PO2 relate to additional periodic technical inspections and
cooperating on roadside inspections with the public authorities and are thus not subject to the ‘one in one
out approach’.
242
European Parliament (2018), Odometer Manipulation in motor vehicles in Europe,
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
243
The cost was estimated at EUR 200 per garage in 2018 prices. Using the harmonised index of consumer prices (HICP)
from Eurostat, this is equivalent to EUR 229 per garage in 2022 prices.
244
Eurostat, Structural business statistics, Enterprise statistics by size class and NACE Rev.2 activity.
245
This is calculated as a simple average over 2026-2035, non-discounted.
75
9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?
The Commission services will monitor the implementation and effectiveness of this initiative through a
number of actions and a set of core indicators that will measure progress towards achieving the operational
objectives. Five years after the revised legislation will have been applied, the Commission services should
carry out an evaluation to verify to what extent the objectives of the initiative have been reached.
Road safety: the Commission regularly monitors key road safety indicators, including the evolution of the
number of fatalities, serious and slight injuries per Member State and per vehicle category, age and certain
vehicle characteristics. Detailed information on the causes of crashes, notably on vehicle defects is unlikely
to become available at large scale soon. In the future, analysis of event data recorders mandated by the
General Safety Regulation may provide more detailed insight into the causes of a significant share of
crashes. Until then, existing reporting requirements should be updated to better respond to current
monitoring needs, as outlined in Annex 15.
Similarly, the evolution of air and noise pollution is continuously monitored by the EEA. Part of the
reduction expected over the years to come will be related to this initiative through better maintenance of
vehicles and reduced tampering with emission control systems. Progress towards the objective of
contributing to sustainable mobility can be measured through the evolution of PTI and RSI results, as well
as from remote sensing data. As for facilitating free movement, indicators of success will be the number of
Member States recognising PTIs conducted abroad.
To measure the success of the initiative, the following operational objectives are set: 1) Apply newly
available safety and emission testing methods; 2) Interconnect Member States’ vehicle registers and
odometer databases through a common hub; 3) Digitalise vehicle documents; 4) Reduce the number of
defective and tampered vehicles on EU roads. Indicators to monitor progress towards these objectives are
defined in Annex 15.
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ANNEX 1: PROCEDURAL INFORMATION
1. LEAD DG, DECIDE PLANNING/CWP REFERENCES
The lead DG is Directorate General for Mobility and Transport (MOVE), Unit C2: Road Safety
DECIDE reference number: PLAN/2021/10932
This initiative was referred to in point 16 of the Sustainable and Smart Mobility Strategy. Action 7
in the Action Plan called for improved emission testing in roadworthiness tests. Action 66 called on
the Commission to assess the need for a proposal to require efficient exchange of odometer readings
across the EU.
This initiative is included in the Commission Work Programme 2023246
, item 3 in Annex II (REFIT
initiatives), under headline A – A European Green Deal.
2. ORGANISATION AND TIMING
The impact assessment and the ex-post evaluation of the Roadworthiness Package were performed
in a back-to-back manner (i.e., the evaluation and impact assessment have been launched at the same
time) in 2021-2023.
The combined evaluation roadmap/inception impact assessment was published on Have your say on
4 October 2021247
. The ex-post evaluation and the impact assessment on a possible review of the
Roadworthiness Package were coordinated by an Inter-Service Steering Group (ISG). The
Commission Services participating in the ISG were: Secretariat-General, Legal Service, Directorates-
General GROW, RTD, CLIMA, ENV, JRC, CNECT, EMPL, JUST. The ISG met 6 times: 22
September 2021, 14 December 2021, 8 July 2022, 24 November 2022, 9 October 2023 and 9
November 2023. It was consulted throughout the different steps of the evaluation and impact
assessment process: notably on stakeholder consultation questionnaire and deliverables of the
external support study and on the draft Staff Working Documents. When necessary bilateral
discussions were organised with the concerned services.
3. CONSULTATION OF THE RSB
The draft impact assessment and evaluation reports were submitted to the RSB on 20 November 2023
and were discussed by the Board on 13 December 2023. The RSB issued a positive opinion with
reservations on 15 December 2023. The recommendations from the Board have been addressed in
this final version of the Impact Assessment report as detailed in the table below.
Table 28: Modifications of the impact assessment report in response to RSB recommendations
RSB recommendations Modifications to the IA report
Main considerations
(1) The report is not sufficiently clear about the
scale of the problem, the robustness of the
underlying evidence and the assumptions made
in the analysis.
Theses aspects have been clarified in section 2
of the impact assessment, as explained below
under (1) and (2).
246
2023 Commission work programme – key documents (europa.eu)
247
Vehicle safety – revising the EU’s roadworthiness package (europa.eu)
77
(2) The report does not clearly explain the
reasoning behind the packaging of options. It
does not sufficiently bring out the key policy
choices and the related trade-offs, including in
terms of reduced fatalities and injuries. The
costs and benefits implications of key safety
measures are not clearly presented.
The packaging of the options and the trade-offs
were revisited and clarified, and are further
described under points (3), (4), and (5) below.
The costs and benefits are now further detailed
in Annex 4 (e.g. in new section 6) and better
explained also in the comparion of options.
(3) The comparison of options is not sufficiently
detailed and nuanced, including in terms of
coherence with the ‘Vision Zero’ road safety
policy framework.
The comparison, including re ‘Vision Zero’ has
been further detailed as described under point
(6) below.
Adjustment requirements
(1) The report should make clear what the scale
of the problems identified is, including
regarding vehicles currently exempted, such as
motorcycles, or not subject to a yearly PTI, such
as vehicles older than 9 years. The strength and
robustness of the evidence underpinning the
analysis of the problems and impact analysis
and of related estimations should be made more
explicit. The report should clarify supporting
assumptions when it comes to the contribution
of defects in vehicles to road crashes and the
link between road safety and inspections. The
geographical distribution of the problems
identified should also be better explained, with
clear references to the situation in different
Member States.
The scale of the problem of unsafe and polluting
vehicles has been explained in more detail,
including geographical details, in section 2.1,
2.2 and 2.2.5. The level of confidence in the
underpinning evidence has been clarified and
backed by additional sensitivity analysis.
Further details as regards the underlying
assumptions and calculations are described
sections 4 and 5 of Annex 4 (impact on road
safety and emissions of individual measures and
policy options).
(2) The report should more clearly acknowledge
any uncertainties related to the evidence and
assumptions used, in particular in relation to the
analysis of the impacts of the odometer fraud
measure. A sensitivity analysis should be
carried out to show how these limitations affect
the overall cost-benefit analysis (looking for
instance at the assumptions on the number of
cars affected and the economic damage caused
by odometer fraud).
The report should be clearer about the
assumptions used and why different data points
(lower bound in some cases) were selected for
the estimations. It should also clarify to what
extent key assumptions were validated by
independent experts and represent the state of
the art on this matter. Similarly, the report
should clarify the scale and geographical
The uncertainty regarding the economic damage
caused by odometer fraud and the number of
cars affected is acknowledged in section 6.1.2.4
and section 6.1.3. Sensitivity analysis has been
performed on the assumptions on the economic
damage caused by odometer fraud and the
number of cars affected, and its impacts in terms
of overall cost-benefit analysis are reported in
section 7.5 and Annex 4 (section 7).
The calculations of the costs for measure PMC6
(Require roadworthiness certificate in electronic
format only) have been revised to account for
the volumes of inspections per Member State
instead of using the lower bound of the
estimates provided during the stakeholders
consultation. The evidence underlying the
problems and their drivers, as well as the
assessment of impacts, is based on the best
78
distribution of the problem when it comes to
older cars, lighter vehicles and mopeds not
being (sufficiently) tested for roadworthiness
and the consequences of this.
available evidence, including multiple studies
involving scientific research, as well as
thorough consultation with experts. This has
been further emphasised in section 2 and section
6. Additional sensitivity analysis has also been
performed and is reported in section 7.5 and
Annex 4 (section 7).
The scale and geographical distribution of the
problem of older vehicles and powered two- and
three-wheelers is clarified as explained above
(1).
(3) The report should explain more clearly the
reasoning behind the packaging of options. It
should clarify why certain policy measures,
such as recording the odometer reading or
registration of certificates in digital formats are
not included in all policy packages. Given that
the policy measure aimed at tackling odometer
fraud is expected to bring by far the most
significant net benefits, excluding this measure
in some policy packages would make them
underperforming by design. The report should
provide a clear justification why this key
measure should not be included in the set of
measures common for all options. If an
exclusion can be convincingly argued, the report
should present variants for options 1a/b
including the odometer measure to allow a fairer
and more balanced comparison of options.
Following the comments received from the
Board, the measure on recording the odometer
reading has now been included in all policy
options. In addition, the mandatory yearly
testing for vehicles that are 10-year-old or older
(PM6) is now included in PO1b, PO2 and PO3.
The changes are reflected in sections 5.2.
(4) The report should explain the reasoning
behind advocating a non-binding measure for
the testing of powerful motorcycles, despite its
more limited potential beneficial impact on road
safety. The explanation should also clarify why
a non-binding measure is considered as an
adequate measure exclusively in the safety case
of powerful motorcycles but not for any other
road safety problem area. When substantiating
this reasoning, the report should make clear
references to the evidence available from
different Member States (which are currently
applying a testing regime and which are not and
what a non-binding or binding EU measure on
this would bring)
Following the observations of the Board, the
measure in question (PM1 – roadside inspection
of motorcycles as an alterantive to PTI) has been
revised. It is now presented as a binding
measure, which indeed corresponds to the
relvant calculations in terms of costs and
benefits. The changes are reflected in sections
5.2, 6.1, as well as in the Annexes.
(5) The report should present better the key
policy choices and related trade-offs, in
particular regarding the benefits and costs of
The benefits of the measures were indeed
assessed as part of the policy options,
considering also the synergies between them.
79
several key road safety measures, including the
mandatory yearly testing for older vehicles and
the ending of the exemptions of motorcycles and
light trailers. These measures are currently
included as a bundle and assessed together only
in the most ambitious option package 3.
However, a complementary measure-by-
measure benefit-cost assessment should allow
the identification of potentially net beneficial
measures in terms of overall reduced fatalities
and injuries. As these are highly relevant for
decision-making, the report should bring them
out more clearly.
Their costs, however, were calculated
individually.
The estimated impacts (in terms of lives saved
and external costs savings) of the options have
now been split to show the impact of the
relevant individual measures.
The expected cumulative reduction in the
number of fatalities and injuries by policy
option and policy measure is now included in
section 5 of Annex 4. In addition, the trade-offs
regarding the costs and benefits of those policy
measures are presented in a new section 6 of the
same annex.
(6) The comparison of the revised set of options
needs to be more nuanced and granular. To
allow a more coherent effectiveness comparison
of options the report should present one clear set
of specific objectives avoiding overlaps with the
general objectives. Regarding coherence, the
report needs to demonstrate why packages 2 and
packages 3 are scored the same, despite the
significant differences with respect to
contribution to the Vision Zero road safety
goals. The comparison overview Table 25
should be reworked to allow a detailed overview
of quantitative and qualitative key impacts, so
that the key differences between the options
become more obvious. On this basis, the report
should better justify the choice of the preferred
option, while being clear on the key trade-offs
between options in terms of efficiency,
effectiveness and coherence.
In section 7, a more detailed presentation of the
key impacts (costs and benefits), both
quantifiable and qualitative, has now been
included.
The comparison of effectiveness now focuses
on achieving the specific objectives, while the
limited differences in coherence between PO2
and PO3 are also explained in section 7 and
Annex 14.
Table 25 has been replaced with a detailed
overview of the key impacts as requested.
In section 8, the differences and trade-offs
between the revised options are clarified in
relation to the three criteria.
4. EVIDENCE, SOURCES AND QUALITY
The impact assessment and evaluation are based on several sources, using both quantitative and
qualitative data, collected from Member States, industry, and other EU bodies. This includes:
• Stakeholder consultation activities (see dedicated annex);
• Regular meetings of the Expert Group on Roadworthiness and Vehicle Registration
Documents (RWEG);
• External support studies carried out by independent consortia (the study supporting the
evaluation was led by VVA and the one supporting the impact assessment was led by
Ricardo). The external support studies will be published alongside this report;
• Ad-hoc consultation of industry experts; and
80
• The Commission’s own experience in monitoring and implementing the Roadworthiness
Package.
81
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)
This stakeholder consultation synopsis report provides a summary of the outcomes of the stakeholder
consultation activities which were carried out as part of this back-to-back evaluation and impact
assessment in view of a possible revision of the Roadworthiness Package (RWP). It provides a basic
analysis of the responses of stakeholder groups involved in the consultation process and a summary
of the main issues which they raised. The full analysis of the consultation results is presented in the
stakeholder consultation reports annexed to the two external support studies. The same report is
included in the evaluation SWD and in the impact assessment SWD, as an annex to both reports.
Stakeholder involvement was vital for the evaluation and impact assessment in order to collect facts,
data and opinions enabling the Commission to:
• On the one hand, assess the performance of the RWP against the five evaluation criteria, identify
possible issues with the existing legal framework and, on this basis, learn lessons for future
action;
• On the other hand, (i) substantiate, validate and develop the problems and the underlying drivers,
(ii) conceive corresponding policy objectives, (iii) elaborate a list of specific possible policy
measures and policy options and (iv) assess their likely impacts on the various categories of
stakeholders.
This report also aims at informing stakeholders on how their input has been considered.
This document should be regarded solely as a summary of the contributions made by stakeholders in
the various consultation activities on the back-to-back evaluation and impact assessment in view of
a possible revision of the Roadworthiness Package (RWP). It cannot in any circumstances be
regarded as the official position of the Commission or its services. Responses to the consultation
activities cannot be considered as a representative sample of the views of the EU population.
1. OVERVIEW OF CONSULTATION ACTIVITIES
Consultation activities took place from October 2021 to August 2023.
The consultation strategy set different focuses for the consultation activities for the evaluation and
the IA to complement each other. The evaluation related survey and targeted interviews gathered
stakeholders’ views and input on the selected evaluation questions and evaluation criteria. They are
complemented with the views expressed at the OPC.
The focus of the survey and interviews for the IA were on defining the different policy measures to
meet the objectives set as part of the revision of the Roadworthiness Package, particularly the costs
and potential impacts of these policy measures. The underlying problem drivers of the RWP were
extensively discussed with stakeholders, e.g. in the Roadworthiness Expert Group and are also a
result of the stakeholder consultation activities of the evaluation. Having said that, both the survey
and interviews did briefly cover the baseline, problem drivers and objectives, as well as potential
impacts of the measures, so on all parts of the IA.
The stakeholder consultation included the following activities:
• Targeted online survey for the evaluation: two online surveys were conducted targeting the
stakeholders identified at the inception stage of the Evaluation Study and covered the 5 evaluation
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criteria of relevance, effectiveness, efficiency, coherence and EU value added. It was launched on
8 December 2022 and ran until 20 January 2023. One survey targeted relevant EU associations,
relevant ministries of EU Member States, road safety authorities and OEMs; In total 38 responses
were received: 17 from ministries and road safety authorities, 16 from EU associations, consumer
organisations and NGOs, 5 from vehicle registration authorities. The other survey was addressed
to PTI bodies and 11 responses were received.
• Targeted semi-structured interviews for the evaluation sought to explore the respondents’
views on the RWP for each evaluation question defined. They took place in the period between
November 2022 and April 2023. The interviews were conducted with representatives from 30
selected technical or policy related organisations including national registration authorities,
technical inspection bodies, the Roadworthiness Committee, the Roadworthiness Expert Group
and road safety and environmental NGOs. They were selected in order to gather additional
evidence, to ensure geographical coverage and to increase the sample size in a group of
interviewees by stakeholder type.
• Exploratory interviews for the IA. The aim of the exploratory interviews was to obtain early
engagement with key stakeholders (including authorities, industry and user representatives).
Introductory calls were made with key stakeholders, i.e. CITA, EReg, CORTE and EGEA, to
discuss the engagement of these organisations and their members with the initiative, including the
distribution of the survey and the identification of potential interviewees. In addition, user groups,
such as FIA (car drivers), IRU (lorry drivers) and FEMA (motorcyclists), were informed about
the initiative and were interviewed as well.
• Targeted online survey for the IA. The focus of the survey was on the policy measures under
consideration, particularly the details of the measures, their potential costs and savings and
potential impacts. The survey was online between 26 June and 14 August 2023. The survey
targeted national authorities involved in inspection activities at various levels, including policy
development, inspection supervision and enforcement, and industry representatives, including
those that undertake inspections and supply garage equipment and vehicles. 75 responses were
received to the survey.
• Targeted stakeholder interviews for the IA. The majority of interviews were based on the
interviewee’s survey response, with a focus on identifying information on costs. A minority of
interviews were undertaken independent of a survey response, e.g. for those organisations, such
as users and research representatives, for which a survey was less relevant. The interviews began
at the same time as the survey and continued until the end of August 2023. Overall, 37 interviews
were undertaken to refine responses provided in the targeted online survey and to collect evidence
from relevant stakeholders not covered in the survey.
• Evaluation roadmap / Inception impact assessment (IIA). As part of the initial feedback
mechanism, stakeholders had the possibility to provide views on the combined evaluation
roadmap / inception impact assessment published on the “Have your say” webpage between 4
October and 1 November 2021. Responses were received from 210 respondents: 171 from EU
citizens, 9 from business associations, 6 from companies or business organisations, 6 from NGOs,
3 from consumer organisations, 3 from non-EU citizens, 2 from public authorities, 1 from
academia and 9 other. 174 responses were linked to a campaign from predominantly French
citizens, while 36 were unique written responses, that were analysed individually.
• Open public Consultation (OPC) questionnaire, covering both the IA and the evaluation, was
accessible on “Have Your Say” webpage from 6 July to 28 September 2022. 907 replies were
received: 758 from EU citizens, 47 from companies or business organisations, 35 from business
associations, 18 from non-governmental organisations (NGOs), 10 from non-EU citizens, 10 from
public authorities, 5 from trade unions, 3 from consumer organisations, 2 from academic/research
83
institutions, 1 from an environmental organisation and 18 other. 731 of the responses received
were part of a campaign from predominantly French citizens. The factual summary report is
available on the consultation page.
2. STAKEHOLDER GROUPS CONSULTED
This section provides a short overview of the main types of stakeholders identified and targeted as
part of the consultation strategy. Overall, the consultation attracted interest from various types of
stakeholders, which resulted in a good participation level and numerous contributions received. All
identified stakeholder groups have been reached. However, the responses received are not
representative of the EU population.
Table 29: Identification of key stakeholder groups and mapping against consultation activities
High-level
stakeholder group
Description Stakeholder
engagement activity
Public authorities in
charge of road safety
Authorities involved in different activities relating to the RWP,
including vehicle registration, inspection, enforcement and
policy. Initial engagement was undertaken via their various
representative associations, such as CITA, EReg and CORTE.
Exploratory interviews
Targeted surveys
Targeted interviews
OPC
Call for Evidence
Industry associations
and companies
Associations and companies involved in different aspects of
RWP, particularly those involved in inspections and supplying
equipment to garages. These were engaged with initially via
their representative associations, such as CITA and EGEA. In
addition, vehicle manufacturers and vehicle component
suppliers were also contacted.
Exploratory interviews
Targeted surveys
Targeted interviews
OPC
Call for Evidence
Representations of
user groups
Groups representing the drivers of the various vehicles covered
by the RWP were engaged with to identify their views on the
potential measures.
Targeted interviews
OPC
Call for Evidence
Road safety and
environmental
NGOs
The views of specialist NGOs were also sought to ensure that
the safety and environmental aspects of the measures were
sufficiently considered.
Targeted interviews
OPC
Call for Evidence
Research / academia Interviews were undertaken with selected road safety academic
experts.
Targeted interviews
OPC
Call for Evidence
Citizens Citizens responded to the combined evaluation roadmap/IIA
and OPC both individually and as part of a campaign, both from
within and outside the EU.
OPC
Call for Evidence
3. ANALYSIS OF THE KEY RESULTS OF THE STAKEHOLDER CONSULTATION
This chapter presents key findings from the analysis of stakeholder contributions to the consultation
process.
3.1. Feedback received on the EU roadworthiness rules by evaluation criteria
Relevance
• Survey respondents and interviewed stakeholders generally consider that the scope and
objectives of the RWP are relevant as a well-designed legislative package. Interviewed
stakeholders overwhelmingly agree that the three Directives within the RWP are still
thematically relevant to the wider EU policy goals.
• However according to the overwhelming majority of survey and interview respondents, there
have been numerous significant changes in vehicle technology since the RWP came into
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effect, which the current RWP does not account for. There is a need to adapt the
Directives to environmental and technological developments and digitalisation.
Additionally, according to the respondents, the current measurement methods outlined by the
RWP are considered inadequate for obtaining accurate readings of air pollutants emitted by
vehicles, and traditional smoke opacity testing methods are deemed outdated and insufficient
in detecting various pollutants. Some interviewed stakeholders also emphasise the need to
increase the frequency of inspections for all vehicles due to the growing prevalence of shared
mobility strategies and suggest clarifying certain aspects of testing to make it more targeted.
• Relevance of the current EU rules on periodic roadworthiness testing and technical
roadside inspections in improving road safety. Several stakeholder categories, including
academic and research institutions, public authorities, and consumer organisations, who have
participated in the OPC, consider the rules relevant or very relevant in areas such as minimum
standards for testing centres, facilities, and equipment, as well as categorising deficiencies
during periodic tests. However, there are varying opinions from some responding NGOs, EU
citizens, and environmental organisations, who perceive some aspects of the rules as less or
not relevant. In particular, many respondents being part of the campaign consider the periodic
testing of high-speed tractors and heavy motorcycles and applying different time intervals
between periodic tests according to the age of vehicle and vehicle type as less or not relevant.
• Relevance of current EU rules on periodic roadworthiness testing and technical roadside
inspections in reducing air pollutant emissions. Business associations, public authorities,
and trade unions, who participated in the OPC consider the rules relevant in areas such as
establishing minimum standards for testing centres, facilities, equipment, and inspectors'
competence, training, and objectivity. However, there are varying opinions from responding
EU citizens, environmental organisations, and some public authorities, who perceive certain
aspects of the rules as not relevant in reducing air pollutant emissions. In particular, many
respondents being part of the campaign consider the rules related to periodic testing of high-
speed tractors and heavy motorcycles as not relevant for the purpose of reducing air pollutant
emissions.
• Relevance of current EU rules on registration documents for vehicles in facilitating free
movement of goods and people within the EU. The majority of the respondents, who
participated in the OPC, consider the current EU rules to be relevant or very relevant in
facilitating free movement, regarding the obligation on Member States to recognise
roadworthiness certificates upon change of ownership. Views among those who responded
being part of the campaign are more varied.
Effectiveness
• Effectiveness of the current EU rules on periodic roadworthiness testing and technical
roadside inspections in improving road safety and contributing to the reduction of road
fatalities and serious injuries in road transport in the EU. The majority of respondents, who
participated in the OPC, view the current EU rules as effective in improving road safety and
contributing to the reduction of road fatalities and serious injuries in road transport in the EU
in areas such as establishing minimum standards for testing centres, facilities, and equipment,
categorising deficiencies during periodic tests, obliging Member States to perform roadside
tests on commercial vehicles, and implementing different time intervals based on vehicle age
and type, except for periodic testing of high-speed tractors and heavy motorcycles on which
views are diverging. The respondents participating in the campaign, perceive the current EU
rules on roadworthiness as less or not effective in in certain aspects, such as periodic testing
of high-speed tractors and heavy motorcycles, and minimum standards for inspectors'
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competence, training, and objectivity. The majority of survey respondents and interview
stakeholders agree that PTIs and RSIs helped reduce the number of circulating vehicles with
dangerous defects.
• The feedback collected from survey respondents and interviewed stakeholders suggests that
vehicles on the road are perceived to have generally been made safer through the introduction
of common standards for testing centres and personnel training, as well as with the adoption
of same rules for frequency, scope and method for vehicle testing. However, interviewed
stakeholders acknowledge that reduction in road deaths witnessed over the past 10 years could
be due to a combination of factors (e.g. gas prices, driver behaviour, infrastructure) and it is
therefore difficult to determine how many accidents are directly caused by mechanical defects
and how many of the lives saved and injuries avoided are specifically linked to PTIs/RSIs.
• Effectiveness of current EU rules on periodic roadworthiness testing and technical
roadside inspections in reducing air pollutant emissions. 80 % of public authorities, who
have responded to the OPC, consider as effective the rules regarding minimum standards for
inspectors' competence, training, and objectivity. Respondents in the OPC part of the
campaign, have differing perspectives, with a majority of those respondents viewing the rules
as not effective for the periodic testing of high-speed tractors and heavy motorcycles and for
applying different time intervals between periodic tests, according to the age of vehicles and
vehicle type.
• However, interviewed stakeholders also pointed out that not all deficiencies can effectively
be detected by applying the current technical standards for vehicle inspections. Among the
survey respondents and interviewed stakeholders, there is no clear-cut opinion on the extent
to which the provisions of the RWP Package have contributed to reduced air pollutants from
road transport. According to surveyed ministries and road safety authorities, vehicles that
have been tampered with defects which are not covered by the EOBD system or those
specifically related to NOx emissions will not necessarily be detected by the current EU PTI
regimes.
• Effectiveness of current EU rules on registration documents for vehicles in facilitating
free movement of goods and people within the EU. The majority of respondents to the OPC
from public authorities and business associations find the current EU rules effective in
facilitating free movement. On the other side, the participants in the campaign have diverging
opinion on the effectiveness of the current EU rules on registration documents for vehicles in
facilitating free movement.
Efficiency
• Cost-effectiveness of the roadworthiness rules. Respondents in the targeted survey and the
interviews deemed the benefits associated with its implementation generally proportionate
to the costs, especially with regards to the improvement of air quality. This is in line with the
views expressed by the survey respondents, who consider that the implementation of the RWP
has generated limited extra costs for authorities, citizens, and businesses. PTI inspections have
not become more expensive, and the use of the EUCARIS system is cost-effective according
to survey respondents. However, certain provisions like OBD checks have incurred costs for
citizens. Ministries, road safety authorities, and EU associations participating in the survey
agree that the benefits of the RWP in terms of road safety and reduced air pollution justify the
costs. EU associations also emphasise its potential in combating illegal pollution and the
human costs of air pollution.
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• However, while some respondents did not consider RWP provisions as extraordinarily
expensive, others mentioned that the costs associated with installing and upgrading testing
equipment for testing stations is high.
• Interviewed stakeholders consider the administrative burden generated by the three Directives
to be smaller for businesses and citizens than for public authorities.
• Ministries and PTI bodies, who have participated in the survey, acknowledge that the RWP
and its implementing acts have created to some extents administrative burden for public
administration. They emphasise the need for digitalisation in vehicle re-registration to reduce
costs and administrative workload, particularly through data exchange and document
harmonisation. Vehicle registration authorities who have responded to the survey, call for
improved legal provisions and digitalisation to streamline the process. Additionally, EU
associations responding to the survey propose providing type-approval information to PTI
centres without charge.
• Most respondents of the survey did not express an opinion on whether the RWP package and
its implementing acts have imposed administrative burdens on businesses. Survey
respondents emphasised the importance of mutual recognition to enhance cost effectiveness
in inspections. They also recommended implementing systems like Car-Pass in Belgium on
an EU-wide scale to address odometer fraud. Furthermore, it was highlighted by them that a
well-assessed test methodology is crucial to avoid inaccurate outcomes in PTI and ensure a
standardised approach to testing procedures and equipment.
• The majority of survey respondents did not express an opinion on the administrative burden
imposed by the RWP Directives on citizens. However, EU associations suggested that
implementing mobile vehicle registration documents could enhance the digitalisation of
registration and data management processes, resulting in reduced costs for citizens.
Coherence
• While the Directives comprised in the RWP are deemed internally coherent by the
interviewed stakeholders, a few inconsistencies between the RWP and other road safety
legislations have been identified by interviewed stakeholders. As a response to the survey a
similar message was passed by responding ministries, road safety authorities, and EU
associations, who acknowledged that to some extent there are inconsistencies, overlaps, and
gaps between the RWP Directives and other EU and international interventions.
• According to the interviewed stakeholders the lack of harmonisation between the PTI and
the type-approval legislations makes it difficult to perform thorough inspections, as the
number of automated devices, sensors and safety features is growing faster than the PTI
operators’ ability to check them.
• The need for consistency between periodic technical inspection (PTI) requirements and type-
approval regulation was also emphasised by the respondents of the OPC. PTI should not go
beyond what is specified in type-approval regulations according to their views. Moreover,
according to OPC respondents, Member States have different conditions and contexts for L-
category vehicles, and they should have the flexibility to determine effective ways to reduce
accidents.
• The Registration Directive and the Type-approval Regulation are not fully consistent in
the view of interviewed stakeholders: the fact that each country has the possibility of allowing
a national type-approval with more flexibility than EU type-approval gives some Member
States the chance to be less strict than others, thus raising road safety issues.
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• According to the interviewed stakeholders the General Safety Regulation could better align
with the RWP: for instance, the GSR identifies more responsibilities for manufacturers during
the vehicle’s lifecycle than those foreseen by the PTI legislation.
• The feedback received from interviewed stakeholders points to a lack of data coherence,
whereby no one has a holistic view regarding the whole life of the vehicle: from vehicle
definition to vehicle scrapping.
• According to the OPC respondents, standardisation of rules among EU countries is considered
essential for the effectiveness of the EU technical control package. Disparate rules,
particularly concerning the approval of controllers, need to be addressed in their view.
EU added value
• The EU rules on roadworthiness have added value for citizens and businesses compared
to what could be achieved by Member States at national and/or regional and international
level according to the respondents to the OPC. There is disagreement among EU citizen
responding to the OPC whether the EU rules on roadworthiness provide added value
compared to what could be achieved at the national, regional, and international levels.
However, there is a significant agreement among academic and research institutions, who
have participated in the OPC that the EU rules do offer added value for citizens and
businesses.
• The interviewed stakeholders widely acknowledged the added value of the three Directives
in their contribution towards the harmonisation of roadworthiness rules among Member
States. By setting up minimum standards for carrying out periodical technical inspections and
roadside inspections, the RWP sets up a common framework to identify vehicle deficiencies,
prevent accidents, reduce vehicle emissions and promote fair competition in the field of road
transport.
• When expressing views in the survey, ministries, road safety authorities, and PTI bodies
considered that additional EU action is necessary to enhance the RWP and achieve the
objectives of reducing fatalities, serious injuries, and improving air quality through PTI and
RSI inspections in the EU. They emphasised the need for minimum requirements across
Member States to ensure effective PTI and RSI contributing to road safety and air quality.
• The overwhelming majority of interviewed stakeholders agree that if the RWP had not been
implemented, the road safety scenario in the EU would be far more fragmented, with Member
States taking greatly differing actions.
3.2. Feedback received on the problem definition
In the OPC, respondents were asked for their views on three problems that the revision of the RWP
could address. A majority of respondents – between two-thirds and four-fifths in each case –
supported a revision of the EU’s roadworthiness rules addressing each of the specified problems. The
problem that received most support was the need to address vehicles circulating on the roads with
defects or tampered components (78%; 123, six ‘no responses’ or ‘Don’t knows’), followed by
methods for PTI of vehicles to test electronic safety and driver assistance systems in vehicles (74%;
116, seven ‘no responses’ or ‘Don’t knows’). Two thirds (67%; 100, 14 ‘no responses’ or ‘Don’t
knows’) of respondents also believed that a revision to the legislation should address the availability
of relevant vehicle data to enforcement authorities in the EU Member States in cross-border traffic.
Themes raised in response to the open questions included that it was important to update inspections
to reflect changes to vehicles and their technology, that it was important to have access to in-vehicle
data to support inspections, that more action was needed to address tampering and that it was
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important to support public authorities in the inspection of foreign vehicles on their roads. Others,
while recognising that changes to inspections were needed, underlined that inspections had to remain
affordable for consumers.
The survey produced similar results of support for the revision of the EU’s roadworthiness rules
addressing the different identified problem areas, see Figure 4.
Figure 5: Survey results on stakeholders’ views on identified problems
Source: Ricardo et al. (2023), Impact assessment support study, survey results
In the survey, respondents were asked for their views on more detailed problem areas, and their
associated drivers and on three Specific Objectives (SOs):
• SO1: Adapt testing to today's and tomorrow's vehicles (improve consistency, objectivity and
quality)
• SO2: Significantly reduce fraud and tampering (of safety and emission control systems) and
improve the detection of defective vehicles)
• SO3: Improve electronic storage and exchange of relevant vehicle identification and status
data.
There was a high level of agreement – around two thirds or more – for each set of problems and
problem drivers, and overwhelming support (at least 89%) for each of the specific objectives.
Figure 6: Survey results: Stakeholders’ views on identified specific objectives
Source: Ricardo et al. (2023), Impact assessment support study, survey results
Respondents to the IIA made a number of general comments about the revision. A common theme
that was raised by those responsible for inspections was the importance of more consideration being
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given to coordinating between type-approval and roadworthiness legislation, and the importance of
maintaining the independence of inspection organisations and inspectors from other parts of the
automotive trade, including repair and maintenance. The importance of a more consistent approach
to roadworthiness testing across the EU was also mentioned.
3.3. Feedback received on the baseline/ existing legislation
In their response to the survey and interview questions, respondents were often split between those
who believed that the different factors listed had had a high impact on various aspects of
roadworthiness, and those who believed that the impact had been low. The question to which
respondents were mostly having a common view with 75% agreeing (51 of 75; seven ‘Don’t knows’
or no responses) – was in relation to the belief that the enforcement of roadworthiness legislation had
had a high impact on the number of unsafe vehicles on the EU’s roads since 2014. The majority (60%;
40 of 75; eight ‘Don’t knows’ or no responses) of respondents also felt that technological and market
developments had had a high impact on the number of unsafe vehicles on the EU’s roads since 2014.
On the other hand, a majority of respondents believed that technological and market developments
had had a low impact on reducing the number of vehicles with tampered or defective noise control
systems (77%; 46 of 75; 15 ‘Don’t knows’ or no responses), or tampered odometers (64%; 39 of 75;
14 ‘Don’t knows’ or no responses), since 2014. The responses relating to the impact on the number
of vehicles with tampered or defective emissions control systems and the vehicle re-registration
process were much more split between those who felt that the impact had been high or low.
Respondents were asked to explain their responses. A common reason listed amongst those
responsible for inspections, as well as users, was the need to update PTIs (and so the PTI Directive)
to take account of the way in which vehicles have developed and will continue to develop. Many of
these respondents also underlined the problem of detecting tampering during a PTI, particularly
tampered odometers.
3.4. Feedback received on possible solutions
Policy measures: Scope of PTI Directive
The first group of policy measures related to the potential extension of the scope of the PTI Directive.
In their responses to the IIA, various industry respondents, including those organisations responsible
for inspections, called for the extension of the PTI Directive to cover all vehicles that are able to use
roads. For example, In the response for IIA, CITA called for the extension of the scope of PTI to L-
category vehicles and light trailers, as it had undertaken a study that concluded that this would have
a positive cost-benefit impact; it also specified its proposed frequency for inspecting these vehicles.
The French National Council of Automotive Professions (Conseil national des professions de
l'automobile; CNPA) and GOCA Vlaanderen also supported extending the scope of PTI to these
vehicles. The Portuguese National Association of Automobile Inspection Centres (Associação
Nacional de Centros de Inspeção Automóvel; ANCIA) called for testing to be mandatory for all
motor vehicles used on public roads. Inspection company Applus also suggested that the general rule
should be that all vehicles that can circulate on roads in the EU should be covered by the PTI
Directive, although they proposed allowing some exceptions for certain L-category vehicles where
alternative measures were in place. The European Garage Equipment Association (EGEA) also
underlined the importance of extending roadworthiness testing to all road transport vehicles.
On the other hand, various motorcycle users’ groups that submitted contributions to the IIA argued
against the mandatory extension of the scope of the PTI to motorcycles, in line also with the responses
from the campaign. The Federation of European Motorcyclists’ Associations (FEMA) argued that
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the evidence was that the technical state of motorcycles only played a marginal role in accidents
involving motorcycles..
In the OPC, among the respondents not linked to the campaign, there was a small majority that
supported extending the scope of the PTI Directive to cover L-category vehicles (53%; 73, 25 ‘no
responses’ or ‘Don’t knows’), whereas again the responses that were part of the campaign were
against such an extension to motorcycles.
Figure 7: Survey responses: In your view what would the contribution of this measure be to:
Source: Ricardo et al. (2023), Impact assessment support study, survey results
Figure 8: Survey responses: In your view, to which categories of motorcycle should mandatory PTI be extended?
(multiple responses possible):
Source: Ricardo et al. (2023), Impact assessment support study, survey results
In the survey, respondents were asked about different potential measures to extend the scope of the
PTI Directive. For each of the potential measures, around two thirds or more of the respondents
believed that the respective measure would contribute to a high level to delivering Specific Objective
2, i.e. extending the scope to motorcycles (80%; 41, 24 ‘no responses’ or ‘Don’t knows’); agricultural
and forestry tractors (78%; 31, 35 ‘no responses’ or ‘Don’t knows’); and light trailers (66%; 27, 34
‘no responses’ or ‘Don’t knows’). In the survey and interviews, it was noted that many Member
States already required a PTI for motorcycles, tractors and/or trailers. Some potential challenges of
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this measure were mentioned by the respondents, including the distance that would need to be
travelled to take motorcycles and tractors for an inspection at an inspection centre, and whether a PTI
should be required for tractors that were not used on public roads. In addition, for the lightest trailers
(O1), it was questioned whether a PTI was needed for these, due to the way in which these were used,
and also due to the fact that these trailers are not registered in some countries, such as the Netherlands
and France.
In the responses to the OPC, SMEs who had responded were much less supportive extending the
scope of the PTI Directive to motorcycles than large enterprises participating in the OPC, with 38%
(eight) not supporting it, compared to no large enterprise. In the response to the survey and
interviews, the fear was expressed that costs for SME inspection companies could increase, if they
had to buy more equipment, or if SME rental companies had to have their vehicles tested more often.
Policy measures: Frequency of PTI tests
The second group of measures considered in the survey and interviews covered measures to increase
the frequency of testing for certain vehicles. In the survey, more than two thirds of respondents
believed that four of the measures would contribute to a high level to delivering Specific Objective
2, i.e. an annual PTI for N1 vehicles (70%; 30, 32 ‘no responses’ or ‘Don’t knows’), an annual PTI
for vehicles over 10 years olds (78%; 39, 25 ‘no responses’ or ‘Don’t knows’), a mandatory PTI for
crashed vehicles with significant damage (70%; 33, 28 ‘no responses’ or ‘Don’t knows’) and for
vehicles with significant modification (67%; 32, 27 ‘no responses’ or ‘Don’t knows’). On the other
hand, a significant majority of respondents (85%; 34, 35 ‘no responses’ or ‘Don’t knows’) believed
that the remaining measure, a simplified PTI for vehicles that had recently passed an RSI, would have
a low contribution to delivering Specific Objective 2.
In the IIA response, CITA called for an increased frequency of PTI for some vehicles. For example,
they supported annual tests for vehicles over 12 years’ old, as the number of these was increasing in
the EU and they would experience more frequent defects as they aged. GOCA Vlaanderen called for
more frequent PTIs for certain vehicles, such as N1 vehicles and vehicles of more than 10 years’ old.
The EGEA also mentioned possibly increasing the frequency of inspections for high mileage
vehicles. The French CNPA and a French inspection company called for the alignment of the
frequency of testing of N1 vehicles, with those of N2 and N3 vehicles, arguing that in France, where
N1 vehicles are tested at the same frequency as cars, they already often had many deficiencies by the
time of their first PTI. The Spanish Association of PTI service providers (AECA-ITV) called for
annual PTIs for all cars, light commercial vehicles and L-category vehicles. The Portuguese ANCIA
also called for an increased frequency of testing for vehicles used for shared mobility or for public
transport services. They also called for a mandatory PTI after a vehicle had been in an accident
affecting its main safety components, which should have the active involvement of insurers, and on
the transfer of ownership of a vehicle. Inspection company Applus also called for a mandatory PTI
after a vehicle had been in an accident (as reported by an insurer), and on the transfer of ownership
of a vehicle. Finally, they recommended that a quality standard for inspection entities and supervisory
bodies be created to improve vehicle inspection and to make this more consistent across the EU.
A common argument in favour of more frequent testing for N1 vehicles, which were mentioned in
different consultation exercises, was that such vehicles were used frequently, and often experienced
a number of technical issues by the time of their first PTI, although other respondents were not
convinced of the added value of this measure. For older vehicles, it was widely suggested that these
deteriorate more quickly than newer vehicles, and so should be tested more frequently. The main
argument against having a simplified PTI for vehicles that had recently passed an RSI was, that it
was not possible to test a vehicle in an RSI in the same way as it was in a PTI -while the potential
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cost of setting up a system to record and exchange this information was noted-, as was the time that
would be needed to amend each PTI to the take account of the recent RSI history of the vehicle. In
relation to requiring a mandatory PTI for crashed vehicles with significant damage and for vehicles
with significant modification, challenges were identified in relation to who makes the respective
judgements and how the information is exchanged. In addition, some respondents considered that a
standard PTI was not sufficient to determine the roadworthiness of some crashed or modified
vehicles.
Policy measures: Mutual recognition of PTI certificates
The third set of measures included two alternative approaches to enable the recognition of PTI
certificates in other countries, i.e. other than the one in which the PTI was undertaken. In the OPC,
a majority of respondents (63%; 97, 11 ‘no responses’ or ‘Don’t knows’) agreed with the proposal
that measures were needed to enable a vehicle owner to obtain a valid roadworthiness certificate, to
be accepted throughout the EU, in a Member State other than the Member State of registration of the
vehicle. In the survey, respondents were split on the extent of the contribution of each of the two
measures to Specific Objective 3. A marginal majority (51%; 19, 38 ‘no responses’ or ‘Don’t knows’)
felt that requiring the mutual recognition of PTI certificates under certain conditions would have a
high contribution to Specific Objective 3, whereas a minority (38%; 12, 43 ‘no responses’ or ‘Don’t
knows’) felt that way about mutual recognition under bilateral agreements.
In responses to the variation consultation exercises, users and those not directly involved in
inspections tended to be more in favour of the mutual recognition of PTI certificates under certain
conditions, although some recognised that the mutual recognition under bilateral agreements would
be a good first step. However, those more actively involved with inspections were concerned that the
extent of the variation between the approach taken to PTIs in different Member States meant that
mutual recognition would be difficult and potentially lead to adverse effects on safety, unless mutual
recognition was the subject of a bilateral agreement. Linked to this, concerns were also raised that
mutual recognition without the increased harmonisation of PTIs would lead to “PTI tourism”, where
drivers had their vehicles tested in countries where it was easier to pass a PTI.
Policy measures: Electronic roadworthiness certificates
The fourth set of measures consisted of a single measure, i.e. require that the roadworthiness
certificate is issued in an electronic format. In their responses to the survey, the overwhelming
majority of respondents (94%; 49, 23 ‘no responses’ or ‘Don’t knows’) believed that this measure
would have a high contribution to addressing Specific Objective 3, with a majority of these (63%;
33) believing that a paper version should still be available on request. In their responses to the survey
and interview, various respondents underlined their support for this measure, and for the increased
digitalisation of all aspects of the roadworthiness testing process more generally, due to its potential
benefits for efficiency, the environment (less paper use), enforcement and in potentially opening the
door for new services. The importance of retaining the option to have a paper copy of the certificate
was underlined, so as not to exclude owners who were less digitally literate. The importance of having
a standardised format for the electronic roadworthiness certificate was also a common remark of the
respondents. A potential challenge of such digitalisation was identified for SMEs that undertake PTIs
in some countries, if they were not yet digitally connected to the agency that oversaw inspections.
Policy measures: Content of PTI tests
The fifth group covered measures to improve the current PTI test requirements and procedures. In
their responses to the OPC, a small majority (60%; 91, 13 ‘no responses’ or ‘Don’t knows’) was in
favour of measures to specifically tackle noise-related tampering / non-compliance problems in
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vehicles inspected at the roadside. SMEs responding to the OPC were less supportive of this
measure, with 29% (six) not supporting it, compared to no large enterprise among the responding
large enterprises.
In the survey, around two thirds or more of respondents believed that the measures would contribute
to delivering the respective Specific Objectives to a high level, with one exception. The measure that
the vast majority (91%; 50, 20 ‘no responses’ or ‘Don’t knows’) thought would contribute at a high
level to achieving Specific Objective 1 was to require the training of PTI inspectors to inspect electric
vehicles. Around two thirds thought that advanced noise testing for motorcycles (65%; 28, 32 ‘no
responses’ or ‘Don’t knows’) and more advanced testing of braking for HDVs (69%; 27, 36 ‘no
responses’ or ‘Don’t knows’) would contribute to Specific Objective 2 at a high level. The response
was more ambivalent with respect to the contribution of advanced testing of advanced headlamps, as
only a slight majority (52%; 23, 31 ‘no responses’ or ‘Don’t knows’) thought that this would make a
contribution to addressing Specific Objective 2, although a majority (79%; 37, 28 ‘no responses’ or
‘Don’t knows’) thought that this measure would address Specific Objective 1 at a high level.
More detailed responses in both the survey and interviews regarding the advanced noise testing for
motorcycles ranged from that this was already done in a number of countries, such as Spain, to a
concern that such tests would not be effective, as users could remove any tampered devices before
the PTI. The latter responses came from national authorities, inspecting companies and user groups,
although some felt that such adaptation prior to the PTI was still an additional burden for users. With
respect to the advanced testing of advanced headlamps, some, such as the FIA, were not yet clear of
the scale of the problem, whereas others, such as CITA, argued that such testing was not yet possible.
On the other hand, in some countries it was considered that such tests were already undertaken, e.g.
in Germany and Belgium, using a range of different methods. Some respondents noted that there
could be additional costs for SMEs resulting from these measures, if a measure required new
equipment or additional training, particularly in countries with a decentralised testing system, such
as the Netherlands.
The introduction of new PTI test requirements and procedures was the subject of the sixth group
of measures. In the responses to the OPC, around two thirds of respondents supported similar
measures to those covered in the survey and interviews. For example, 70% (106, 13 ‘no responses’
or ‘Don’t knows’) supported methods to test the functioning of safety-relevant electronic components,
advanced driver assistance systems (ADAS) and automated functions being included in the revision
of the PTI Directive, with 66% (100, 12 ‘no responses’ or ‘Don’t knows’) supporting the inclusion
of new methods to test vehicles with alternative powertrain technologies (hybrid, full-electric,
hydrogen) and 64% (96, 13 ‘no responses’ or ‘Don’t knows’) new methods for measuring exhaust
emissions, for example particle number (PN) and nitrogen oxides (NOx). Many responses to the IIA
also called for similar measures.
In the responses to the survey, at least 80% of respondents thought that the respective measures
would address the specified Specific Objectives, e.g. 92% (46, 25 ‘no responses’ or ‘Don’t knows’)
believed that updating the PTI to cover the safety systems introduced by the General Safety
Regulation (GSR) would address Specific Objective 1 to a high level and 88% (45, 24 ‘no responses’
or ‘Don’t knows’) felt the same way about adapting the PTI to the particularities of EVs and hybrids.
Similar proportions, 81% (43, 22 ‘no responses’ or ‘Don’t knows’) for mandatory PN counting and
82% for requiring NOx testing according to the JRC methodology, thought that these measures would
address both Specific Objective 1 and Specific Objective 2 to a high level. In the open responses to
the survey and the interviews, there was some concern regarding the feasibility of applying NOx
testing according to the JRC methodology in northern Member States, particularly the requirement
that testing be undertaken when the vehicle has a warm engine. Again, there were some concerns
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about the impact of any additional costs from these measures on SMEs that undertake inspections,
particularly where the PTI system was decentralised.
Policy measures: Scope of RSI Directive
The seventh set of measures focused on extending the scope of RSIs. In the responses to the OPC,
there was a high level of support for mandatory checks during roadside inspections of commercial
vehicles to ensure the safe securing of cargo (70%; 99, 22 ‘no responses’ or ‘Don’t knows’).
However, there was only a marginal majority in favour of extending the rules to other vehicles, (e.g.,
light commercial vehicles, and passenger vehicles, including cars, powered two- and three-wheelers
(N1, M1 and L-category vehicles) (51%; 77, 14 ‘no responses’ or ‘Don’t knows’). In particular,
respondents who were SMEs were much less supportive of this measure, with 38% (eight) not
supporting it, compared to no large enterprise participating in the OPC.
In the survey, between two-thirds and three-quarters of respondents believed that the respective
measures would address the associated Specific Objectives at a high level, although in all cases at
least half of the respondents to the survey did not express a view. On one hand, two-thirds of
respondents (67%; 20, 45 ‘no responses’ or ‘Don’t knows’) believed that the introduction of
mandatory standards in relation to cargo securing inspections would address Specific Objective 1 at
a high level. On the other hand, around three quarters of respondents believed that the extension of
the scope of the RSI Directive to N1 and L-category vehicles would address Specific Objective 2 at
a high level (76%; 28, 38 ‘no responses’ or ‘Don’t knows’; and 74%; 23, 44 ‘no responses’ or ‘Don’t
knows’, respectively). In their responses to the survey and interview, various respondents noted that
some of these measures were already undertaken in their respective countries, although a minority of
respondents were not convinced of the added value of each of these measures. In relation to
introducing RSI for N1 vehicles, it was suggested that this could bring additional costs, in terms of
lost time, for SMEs operating such vehicles.
Policy measures: Content of RSIs
The introduction of new RSI test methods and procedures was the subject of the eighth group of
measures. In the responses to the OPC, a small majority supported consideration of relevant
measures, as 60% (91, 13 ‘no responses’ or ‘Don’t knows’) supported measures to specifically tackle
noise-related tampering / noncompliance problems in vehicles inspected at the roadside and 53%
(78, 17 ‘no responses’ or ‘Don’t knows’) supported extended emission testing (e.g., NOx and PN),
including the use of remote sensing equipment. SMEs participating in the OPC were much less
supportive of either of these measures (29% (six) and 40% (eight), respectively), compared to no
respondent large enterprise in both cases.
In the responses to the survey, a majority of respondents, who expressed a view, thought that each
of the proposed measures would contribute to addressing both Specific Objective 1 and Specific
Objective 2 at a high level, although more than half of respondents did not have a view on any of
these measures. For example, 81% (26, 43 ‘no responses’ or ‘Don’t knows’) believed that PN testing
for commercial vehicles would address Specific Objective 2 at a high level, as did 77% (24, 44 ‘no
responses’ or ‘Don’t knows’) for NOx and noise testing for all vehicles using remote sensing. The
measure that the fewest respondents believed would address Specific Objective 2 at a high level was
plume chasing for commercial vehicles (61%; 14, 52 ‘no responses’ or ‘Don’t knows’). The responses
relating to Specific Objective 1 were similar for each measure. In the responses to the open questions
in the survey and interviews, various respondents from national authorities were not convinced of
the added value of requiring PN counting during an RSI, if this was also measured in the course of a
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PTI. It was also suggested that remote sensing would only be able to identify vehicles that exceed the
respective emission standards significantly, rather than being able to identify slight exceedances.
In the IIA response in relation to the RSI Directive, CITA called for cargo securing requirements for
cargo vehicles to be set in type-approval, in order to facilitate the inspection of the security of cargo
in RSIs. Ireland’s RSA called for some changes to improve the RSI Directive, including more
specific wording around failures involving frontal protection systems and tampered emission control
systems. They also suggested that consideration could be given to expanding the scope of the RSI
Directive. The inspection company Applus suggested that the RSI Directive should be extended to
all vehicles that were able to circulate on roads in the EU to check their emission levels, noise levels,
overloading and other relevant technical issues. They also suggested that remote sensing could be
used to identify the need for additional inspections for high polluting vehicles. The Nordic Logistics
Association highlighted the importance of electronic data exchange and the storage of the results of
RSIs, and for RSI authorities to have access to this information, in order to prevent drivers being
subject to another RSI when they cross a border. They also underlined the importance of digital tools,
including those that could support the registration of vehicles, in making it easier to inspect vehicles,
and so make this more efficient, thus saving time for inspectors and for those being inspected.
Policy measures: Testing software in PTIs and RSIs
The ninth set of measures included a single measure relating to both the PTI and RSI Directives:
require the testing of software status/integrity of safety and/or emission relevant systems in the PTI
for all vehicles and as part of technical roadside inspections of commercial vehicles. The OPC
included a question on a similar measure, but only in relation to PTI, which was supported by two
thirds of respondents (65%; 100, nine ‘no responses’ or ‘Don’t knows’). The importance of checking
a vehicle’s software, at least during PTIs, was highlighted by a number of inspection bodies in the
IIA. In the survey, a high proportion of respondents believed that the measure would address both
Specific Objective 1 (86%; 42, 26 ‘no responses’ or ‘Don’t knows’) and Specific Objective 2 (81%;
38, 28 ‘no responses’ or ‘Don’t knows’) at a high level. In the open responses to the survey and
interviews, some authorities were concerned about the additional costs of this measure, particularly
on SMEs. On the other hand, those that undertook inspections believed that the test could be
relatively straightforward, even automated, as long as those undertaking inspections had easy access
to the relevant information within the vehicle and also to relevant manufacturer databases that
contained the necessary information on the software used.
Policy measures: Access and exchange of information/data
The tenth set of measures focused on access and exchange of information/data that was needed to
support PTIs and RSIs.
In the response to IIA, CITA called for all those undertaking inspections to have access to vehicle-
specific original data in a non-discriminatory, free and independent manner, given that technical
inspections are undertaken for the authorities of the Member States, They also underlined the
importance of relevant stakeholders being able to verify that the right version of approved software
was being used by the vehicle. Germany’s Central Agency for PTI, the FSD, also underlined the
importance of access to in-vehicle data and diagnostic information in an independent and reliable
way, specifically the information made available in the context of EU type-approval legislation, along
with unrestricted access to the vehicle data and software, covering the whole lifetime of the vehicle.
Similarly, the Spanish AECA-ITV underlined the importance of PTI inspection providers having
access to the original vehicle data, including up-to-date software, in a non-discriminatory, free and
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independent manner, so that vehicles could be appropriately tested. The Portuguese ANCIA also
underlined the importance of testing services having access to the technical specifications of a
vehicle’s safety systems to be able to properly test these, and to be able to check that a vehicle’s
software was approved and up to date. Austrian VFT and BdF, and the German DKZ also underlined
that, in order to facilitate the inspection of the functionality of safety systems, testing centres should
have easy access to the relevant OBD data, free of charge. They also noted that the implementation
of Regulation (EU) 2019/621 regarding ePTI had been more difficult than expected and so more
detailed provisions should be included in the revised RWP. GOCA Vlaanderen also emphasised the
importance of free access to specific PTI-related data for each individual vehicle in order to be able
to properly inspect modern vehicles. Similarly, Ireland’s RSA called for manufacturers to be required
to provide to Member States with “accessible and standardised” information relating to the test items,
at no cost to Member States, and to provide sufficient access to in-vehicle data in PTIs to enable the
necessary inspections. They also argued that testing inspection companies should have similar access
to these information and data. Inspection company Applus argued that organisations involved in
statutory activities, such as vehicle inspections, should have a “clear and unfiltered access” to vehicle
data, potentially via a central hub. They also called for the information needed for an inspection to
be made available in a standardised format in an easy-to-access, computer-readable format on the
European level, to facilitate access to the OBD, for example. Applus also underlined the importance
of inspections being able to check that the appropriate, non-modified software was present on the
vehicle. The EGEA underlined the importance of direct access to in-vehicle data to facilitate the
testing of safety and environmental control systems, and also called for all inspection equipment to
have digital network capability to enable the secure transmission of data between inspection sites and
the respective authorities. GTÜ, the German association of independent PTI inspectors, also
underlined the importance of being able to access vehicle data using standardised interfaces, and of
having internet access at all inspection sites. They also noted that they would welcome a system that
would allow Member States to issue inspection reports solely in a digital format. The FIA also
underlined that the relevant diagnostic data and functions must be made “conveniently accessible”
for inspection bodies free of charge, as these were undertaking a government activity, with the
explicit consent of users. They also called for the implementation of an independent, vehicle security
certification scheme to allow “efficient and effective” verification during testing to ensure that the
most up-to-date security, safety and environmental protection updates have been installed. The
ÖAMTC’s response made similar points.
In the OPC, questions were asked about relevant measures relating to both PTIs and RSIs. Two-
thirds of respondents (67%; 102, 11 ‘no responses’ or ‘Don’t knows’) supported extending (or
clarifying) existing rules on access to in-vehicle data…, with data protection safeguards for PTIs,
whereas a slightly smaller proportion (62%; 93, 15 ‘no responses’ or ‘Don’t knows’) supported this
for RSIs. In both cases, vehicle and equipment manufacturers/suppliers, who participated in the
OPC, were less supportive of this provision than other respondents, e.g. for PTI (58%; seven, three
‘no responses’ or ‘Don’t knows’) and for RSI (50%; six, three ‘no responses’ or ‘Don’t knows’). In
addition, 59% (92, nine ‘no responses’ or ‘Don’t knows’) supported new methods for reading out
onboard data stored in the vehicles for PTIs, although again vehicle and equipment
manufacturers/suppliers, who participated in the OPC, were less supportive of this measure (38%;
five, two ‘no responses’ or ‘Don’t knows’) than other respondents. In addition, nearly two thirds of
OPC respondents (64%; 96, 14 ‘no responses’ or ‘Don’t knows’) were supportive of granting
roadside inspection authorities access to electronic data, which again was less supported by vehicle
and equipment manufacturers/suppliers, who participated in the OPC, than other respondents (31%;
four, two ‘no responses’ or ‘Don’t knows’).
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In the survey, a majority of respondents believed that further defining data governance procedures
and the means of access to vehicle technical information by testing centres free of charge and in
standardised format would address both Specific Objective 1 (87%; 45, 23 ‘no responses’ or ‘Don’t
knows’) and Specific Objective 3 (75%; 38, 24 ‘no responses’ or ‘Don’t knows’) to a high level. A
similarly high proportion believed that enabling and use of independent remote access to in-vehicle
data in the RSIs of commercial vehicles would address both Specific Objective 1 (81%; 34, 33 ‘no
responses’ or ‘Don’t knows’) and Specific Objective 2 (73%; 30, 34 ‘no responses’ or ‘Don’t knows’)
to a high level. Around three-quarters of respondents (75%; 24, 43 ‘no responses’ or ‘Don’t knows’)
believed that requiring the electronic storage of RSI reports in national databases, as well as the
access and exchange of RSI-relevant data to RSI authorities in other EU Member States through a
common IT system would address Specific Objective 3 at a high level. In response to the open survey
and interview questions, various respondents underlined that enabling and use of independent remote
access to in-vehicle data was as important for PTIs as it was for RSIs, and so underlined that this
measure should also be considered in the context of PTIs. In this context, EReg underlined that they
supported the three measures in this section applying to all three Directives that are part of the RWP.
Various respondents, including CITA, EGEA and EReg, underlined the importance of free and easy
access to in-vehicle data to enable the proper inspection of vehicles. Many respondents also
underlined the importance of storing relevant data in a structured format, rather than storing the full
RSI report. A couple of respondents suggested that SMEs would benefit from having easier access
to information.
Policy measures: Measures relating to vehicle registration
The final – eleventh – set of measures focused on potential amendments to the Vehicle Registration
Documents Directive.
In the IIA response in relation to vehicle registration, CITA called for a standardised exchange of
data between type-approval and licencing authorities, to eliminate the need to carry the registration
certificate in the vehicle (or even its replacement entirely with an electronic version) and the
possibility for relevant authorities and bodies to access vehicle registration data, no matter which
Member State the vehicle was registered in. Spanish AECA-ITV called for the establishment of an
electronic platform in which Member States were able to access the registration documents and
certificates of conformity of all vehicles. The Nordic Logistics Association agreed with the
difficulties in enforcing road safety measures in cross-border traffic and trade in the EU, and
underlined its belief that sharing vehicle registration data, and other safety-relevant information, of
vehicles between Member States was important to address this problem.
In the OPC, respondents were asked whether they supported four relevant measures, each of which
was supported by around three-quarters of respondents, with the most popular being adding data on
major accidents of a vehicle to the vehicle register (76%; 115, 13 ‘no responses’ or ‘Don’t knows’).
This was followed by improved exchange of roadworthiness data between Member States in
electronic format (75%; 116, 10 ‘no responses’ or ‘Don’t knows’), full digitalisation of registration
documents (74%; 110, 16 ‘no responses’ or ‘Don’t knows’) and adding odometer data to the vehicle
register (72%; 111, nine ‘no responses’ or ‘Don’t knows’). Responses to the IIA also supported the
sharing of relevant information between Member States.
In the survey, a large majority of respondents that had a view (at least 85% in all cases) believed that
the respective measures would have a high impact on the respective Specific Objectives. Over 90%
of respondents believed that providing electronic access to relevant data to the registration
authorities of other EU Member States through the use of a common IT system (95%; 38, 35 ‘no
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responses’ or ‘Don’t knows’) and adding a minimum set of new data to the vehicle register (93%;
42, 30 ‘no responses’ or ‘Don’t knows’) would address Specific Objective 3 to a high level. Slightly
fewer respondents believed that introducing the requirement that any vehicle transformation has to
be approved and registered and increasing the harmonisation of the technical data in the vehicle
registration documents on the basis of a common standard would address Specific Objective 3 at a
high level (91%; 30, 42 ‘no responses’ or ‘Don’t knows’; and 88%; 28, 43 ‘no responses’ or ‘Don’t
knows’, respectively). The proportion believing that requiring issuing of the registration certificates
(Annex I) in digital format and that requiring that Member States update vehicle registration data on
a regular basis would address Specific Objective 3 at a high level was marginally lower (85%; 23,
48 ‘no responses’ or ‘Don’t knows’; and 86%; 25, 46 ‘no responses’ or ‘Don’t knows’, respectively).
In the responses to open questions in the survey and interviews, many national authority respondents
highlighted that 17 Member States already used Eucaris for the purpose of data exchange, and that
this system worked well. Many of the same organisations underlined that data on the vehicle register
should be harmonised and available to all organisations that were involved in undertaking PTIs and
RSIs for national authorities, while EReg and some if its members called for a larger set of data to be
included in the vehicle register. EReg also generally supported the digitalisation of the vehicle
registration documents and the mutual recognition of these. Various national authorities, and users,
underlined the importance of the data in the vehicle register being updated as soon as relevant changes
happen. It was suggested that additional costs could arise for SMEs that were not currently digitally
connected in order to be able to access electronic documentation and information, although it was
also suggested that SMEs would have a lot to gain by having better access to relevant standardised
information.
3.5. Feedback received on policy options
Various industry respondents, including PTI operators, called for the extension of the PTI Directive
to cover all road vehicles. PO3 and PO1b introduce the obligation to inspect motorcycles at PTI,
albeit at a various level of stringency and with PO3 being more ambitious, while PO2 and PO1a allow
to substitute PTI with RSI. While stakeholders belonging to motorcyclists’ groups at EU or national
level did not support such extension in the OPC, in the survey most of the respondents supported
mandatory PTI for motorcycles with the objective to reduce tampering and the detection of defected
vehicles. Stakeholders also noted that many Member States already required a PTI for motorcycles,
as well as for tractors and/or trailers. In the consultations, SMEs were much more likely not to support
extending the scope of the PTI Directive to motorcycles than large enterprises, arguing that costs for
SME inspection companies could increase, if they had to buy more equipment.
All policy options include mandatory testing after significant modification of a vehicle, which was
supported by stakeholders in the survey. Regarding the increased frequency of testing, PO1b and
PO2 introduce annual emission testing for vans and a requirement for an annual PTI for vehicles over
10 years old, all these measures being supported by a majority of stakeholders in the survey.
The recognition of PTIs conducted in another Member State was an issue that the majority of
stakeholders responding to the OPC considered as necessary to address. PO3 introduces a full
recognition, while PO1b and PO2 require the recognition of the PTI from another MS than the MS
of registration for a period of up to 6 months. PO1a on the other hand envisages only a recognition
based on bilateral agreements. Stakeholder views on this differ to quite some extent: vehicle owners
and those not directly involved in PTI inspections tended to be more in favour of the mutual
recognition of PTI certificates under certain conditions, although some recognised that the mutual
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recognition under bilateral agreements would be a good first step. Those more actively involved with
inspections were concerned that the difference between the approach taken to PTIs in different
Member States meant that mutual recognition would be difficult and potentially lead to adverse
effects on safety. Concerns were also raised that mutual recognition without the increased
harmonisation of PTIs would lead to “PTI tourism”, where drivers had their vehicles tested in
countries where it was easier to pass a PTI.
All policy options tackle odometer tampering. New methods for tackling odometer fraud were
considered as necessary by 69% (107) respondents in the OPC and adding odometer data to the
vehicle register was welcomed by 72% (111) respondents in the OPC. In the consultations, in relation
to odometer readings, some stakeholders suggested that it should be mandatory to record odometer
data at certain events, such as following accidents and the transfer of ownership, and that potential
buyers should have access to all this information. Not all stakeholders were however positive about
this measure: some called on odometer system manipulation to be addressed via type-approval
legislation, rather than the revision of the PTI Directive (FIA), and others questioned the potential
inclusion of new methods to tackle odometer fraud, arguing that inspection organisations did not
have the legal means or ways to detect and sanction such fraud (CITA).
Regarding the content of RSI, PO1b, PO2 and PO3 introduce mandatory NOx and PN measurement
and inspection of cargo securing. In the responses to the survey, a majority of respondents (81% and
77% respectively) thought that PN testing for commercial vehicles and NOx and noise testing for all
vehicles using remote sensing would improve the detection of defective vehicles and reduce tampering.
In the OPC, a small majority supported extended emission testing (e.g., NOx and PN), including the
use of remote sensing equipment, during RSI. Regarding cargo securing, in the responses to the OPC,
there was a high level of support for mandatory checks during roadside inspections of commercial
vehicles to ensure the safe securing of cargo (70%; 99). In the survey, two-thirds of respondents
(67%; 20) believed that the introduction of mandatory standards in relation to cargo securing
inspections would contribute to road safety.
PO2 and PO3 also introduce the extension of scope of RSI to light commercial vehicles. In the OPC,
there was only a marginal majority in favour of extending the rules to other vehicles (51%; 77). In
the survey, around three quarters of respondents thought that the extension of the scope of the RSI to
light commercial vehicles would contribute to better detection of defective and tampered vehicles
(76%; 28). In relation to introducing RSI for these vehicles, some stakeholders suggested that this
could bring additional costs, in terms of lost time, for SMEs operating such vehicles.
Regarding access and exchange of information/data, PO2 and PO3 both introduce the procedures for
access to vehicle technical information by testing centres free of charge. In the OPC, two-thirds of
respondents (67%; 102) supported clarifying the existing rules on access to in-vehicle data. Vehicle
and equipment manufacturers/suppliers were less supportive of this provision than others. In the
survey, a majority of respondents (87%; 45) supported this approach to address the objectives of the
initiative. In response to the open survey and interview questions, various respondents (including
CITA, EGEA and EReg), underlined the importance of free and easy access to in-vehicle data to
enable the proper inspection of vehicles.
Finally, all policy options include measures aimed at facilitating exchange of PTI and registration
data. PO1a, PO2 and PO3 furthermore introduce measures on the digitalisation of registration
certificates and new data sets to be included. A large majority of stakeholders supported these
measures. National authority respondents highlighted that 17 Member States already used Eucaris
for the purpose of data exchange, and that this system worked well. They underlined that data on the
vehicle register should be harmonised and available to all organisations that were involved in
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undertaking PTIs and RSIs for national authorities. EReg called for a larger set of data to be included
in the vehicle register and generally supported the digitalisation of the vehicle registration documents
and the mutual recognition of these. Various national authorities, and users, underlined the
importance of the data in the vehicle register being up to date as soon as relevant changes happen.
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ANNEX 3: WHO IS AFFECTED AND HOW?
1. PRACTICAL IMPLICATIONS OF THE INITIATIVE
Summary of the implementation of the preferred policy option
The primary objective of the initiative is to improve road safety in the European Union, by
contributing to the objective of decreasing the casualties and serious injuries resulting from road
crashes by 50% by 2030 as an important milestone of “Vision Zero” by 2050. At the same time, the
initiative aims to improve the environmental performance of vehicles and in this way contribute to
cleaner air and a lower environmental footprint of the road transport sector in the EU. The preferred
policy option will ensure that today’s and tomorrow’s road vehicles remain safe and maintain their
approved environmental performance throughout their lifetime. It will significantly reduce tampering
of safety-related and emission control systems as well as odometer fraud and improve data exchange
and cooperation among Member States, thereby reducing the external costs generated by road
transport, improving consumer protection, and facilitating the free movement of people and goods.
The benefits of the preferred policy option are expected to fall on different stakeholder groups:
citizens, vehicle owners, PTI centres, inspectors, public authorities.
Citizens will benefit from the increased road safety on EU roads, leading to less fatalities and injuries.
They will also benefit from healthier environment due to reductions in air pollutant emissions (NOx
and PM) and noise emissions thanks to better detection of defective and tampered vehicles.
Vehicle owners (businesses and citizens) will enjoy the benefits due to avoided odometer fraud.
This will require mandatory recording and reporting to a national central database of vehicle mileage,
whenever a vehicle undergoes repair/maintenance or in the case of tyre changes/replacement. It will
help reduce odometer fraud in both, domestic sales of used vehicles as well as in cross-border sales.
Additional benefits for vehicle owners will come from avoiding emission testing at PTI in case the
vehicle passed a roadside inspection or was found to be in line with the applicable emission limits
during a screening by remote sensing. They are also expected to save costs related to the recognition
of PTI certificates in other Member States (for up to 6 months), as a result of avoided travel costs.
Measures involving an extension of vehicle scope or increase in testing frequency for particular
vehicle categories will require additional inspections and will lead in increase of employment of
vehicle inspectors. Benefits are expected also from the additional training for the inspectors that will
have to deliver the new testing methods. Adapting PTI methods to the testing of electric vehicles,
including the training of inspectors, will also provide a safer workplace for vehicle inspectors.
PTI centres will benefit from more frequent emission testing of light commercial vehicles and from
the mandatory yearly testing for vehicles that are 10-year-old or older. They will also enjoy cost
savings due to new data governance measure and access to relevant technical information.
National administrations are expected to benefit from significant cost savings due to the
introduction of roadworthiness certificate in electronic format and the interlinking of national vehicle
registers. As regards roadworthiness certificates, they should become mandatory in electronic format
and gradually replace the paper and smartcard format. This would bring savings to national
authorities as they would avoid the costs of printing, distribution, and handling of paper/plastic
registration certificates. Additional saving should come from transition to issuing digital registration
certificates instead of paper ones. They can also expect cost savings due to the time saved for the re-
registration of a vehicle in another Member State.
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The costs of the measures included in the preferred policy option are expected to fall on different
stakeholder groups: national public authorities, periodic technical inspection (PTI) centres, vehicle
repair shops, garages, vehicle owners (citizens and businesses).
National public authorities will face one-off adjustment costs linked to setting up a database for
recording odometer history of the vehicles registered in their territory, the interconnection of national
vehicle registers, adding new data elements to the registers and introducing remote sensing, which
requires the purchase and installation of new roadside equipment as well as a monitoring system.
They will also face additional administrative costs due to an increased number of roadside
inspections.
PTI centres will face adjustment costs linked to updated and new test requirements, and an increased
number of tests will require additional investments in equipment, testing capacity and training of
inspectors. It is however expected that PTI centres will be able to recover the additional costs through
the additional business opportunities (increased number of tests) and in some cases (depending on
the Member State) through somewhat increased PTI charges (this aspect could not be quantified).
Vehicle repair shops, motor vehicle dealers and other garages will face additional administrative costs
due to the requirement for Member States to set up a system to record odometer readings from the
cars and vans registered in their territory. This includes one-off costs for software updates, to allow
them to transfer their data to the central national database, and recurrent costs for the maintenance of
the software and the time spent for recording the odometer readings.
Automobile manufacturers will face administrative costs related to the setting up of a governance
framework for providing access to in-vehicle data necessary to carry out PTI and RSI to inspection
centres and competent authorities. The costs are due to the adjustments to their IT systems to ensure
access to the relevant data, and maintenance costs.
Some vehicle owners will also face additional costs due to the extension of the scope or frequency of
PTI and roadside inspections. Vehicle owners may also face administrative costs related to the
roadworthiness test following any significant modification that could affect safety or the
environmental performance of the vehicle. Due to new testing requirements regarding safety, air
pollutant emissions and noise, some vehicle owners will incur repair costs to ensure that their vehicles
can pass the PTI inspection and remain in use. The regular inspection of cargo securing will lead to
recurrent administrative costs for businesses vehicle owners.
2. SUMMARY OF COSTS AND BENEFITS
I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)
Description Amount Comments
Direct benefits
Administrative costs
savings for Member States
administrations, expressed
as present value over
2026-2050, relative to the
baseline
EUR 5.23 billion Administrative cost savings for national
administrations due to issuing the
roadworthiness certificates in electronic
format only, the interlinking of national
vehicle registers, the time saved for the
re-registration of a vehicle in another
Member State, and due to avoiding the
costs of printing, distribution and
handling of paper/plastic registration
certificates, estimated at EUR 5.23
billion, expressed as present value over
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I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)
Description Amount Comments
2026-2050.
Administrative costs
savings for businesses
(PTI centres), expressed
as present value over
2026-2050, relative to the
baseline
EUR 1.64 billion Administrative costs savings for PTI
centres due to the access to relevant
technical information (data governance)
estimated at EUR 1.64 billion, expressed
as present value over 2026-2050.
Benefits for businesses
(PTI centres) from
additional technical
inspections, expressed as
present value over 2026-
2050, relative to the
baseline
EUR 39.10 billion Benefits from additional periodic
technical inspections for PTI centres due
to the extension of scope of PTI and more
frequent testing of certain vehicle
categories, including for the yearly
testing of vehicles that are 10-year-old or
older. Estimated at EUR 39.10 billion
expressed as present value over 2026-
2050.
Administrative costs
savings for other
businesses (vehicle
owners) expressed as
present value over 2026-
2050, relative to the
baseline
EUR 1.29 billion Administrative costs savings for other
businesses (vehicle owners) due to the
possibility to avoid emission testing at
PTI in case the vehicle passed a roadside
inspection or was in line with the
emission limits during a screening by
remote sensing. The savings are
estimated at EUR 1.29 billion, expressed
as present value over 2026-2050.
Benefits for other
businesses (vehicle
owners) due to avoided
odometer fraud
EUR 118.34 billion Benefits for other businesses (vehicle
owners) due to mandatory recording and
reporting to a national central database of
vehicle mileage, whenever a vehicle
undergoes repair/maintenance or in the
case of tyre changes/replacement which
helps reducing odometer fraud, estimated
at EUR 118.34 billion, expressed as
present value over 2026-2050.
Adjustment costs savings
for citizens (vehicle
owners) expressed as
present value over 2026-
2050, relative to the
baseline
EUR 2.14 billion Adjustment cost savings for citizens due
to the recognition of PTI certificates
issued by a Member State other than
Member State of registration of up to six
months, as a result of avoided travel costs
back to the country of vehicle registration
for a PTI. Estimated at EUR 2.14 billion
relative to the baseline (expressed as
present value over 2026-2050).
Administrative costs
savings for citizens
(vehicle owners)
expressed as present value
over 2026-2050, relative
to the baseline
EUR 591.9 million Administrative costs savings for citizens
due to not requiring emission testing at
PTI after the vehicle has successfully
passed a screening by remote sensing,
estimated at up to EUR 591.9 million,
expressed as present value over 2026-
2050.
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I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)
Description Amount Comments
Benefits for citizens
(vehicle owners) due to
avoided odometer fraud
EUR 65.67 billion Benefits due to the obligation for Member
States to record odometer readings in a
national database, as well as to make
them available to other Member States in
the case of a re-registration of a vehicle in
order to reduce odometer fraud.
Estimated at around EUR 65.67 billion,
expressed as present value over 2026-
2050.
Improvement in the
functioning of the internal
market
Positive impact on the functioning of the
internal market is expected due to the the
measures related to improving the
availability and exchange of vehicle-
related information, making the
roadworthiness certificate available in
electronic format, harmonising testing
methods, the frequency of testing,
requirements for the improvement of the
PTI and the scope of testing. Harmonising
vehicle registration documents across
Member States will help to verify the
vehicle's characteristics, and its
registration status in the country of origin.
This can help addressing potential
obstacles to re-registration in another EU
Member State where the vehicle is
reported stolen, or its registration
certificate is suspected of being
fraudulent.
Benefits for citizens and
administration due to
‘digital by default’
The mandatory electronic format of
roadworthiness certificates should have a
positive impact on digital transformation
in the EU. For the process of re-
registration, it will save time and costs for
authorities and citizens by moving away
from information and data exchange via
e-mail, which is less efficient and time
consuming. A digital registration
certificate should help reduce time and
costs for authorities and citizens by
making access and exchange of the
relevant information easier, faster.
Increase in employment of
PTI and RSI inspectors,
relative to the baseline
PTI inspectors: 18,752 additional full-time
inspectors in 2030 and 20,107 in 2050,
relative to the baseline
RSI inspectors: 204 additional full-time
inspectors in 2030 and 243 in 2050, relative
to the baseline
The preferred policy option will lead to
additional inspections and the need for
additional inspectors PTI and RSI to
perform them due to extension of vehicle
scope or increase in testing frequency for
particular vehicle categories (such as
annual emission testing of vans,
mandatory yearly testing of vehicles that
are 10-year-old or older, the noise testing
of motorcycles and extension of RSI to
vans). In addition, there will be benefits
from the additional training for the
inspectors that will be needed to be able
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I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)
Description Amount Comments
to deliver the new testing methods. The
demand for additional and new testing
equipment will lead to an increase in
production-related jobs within Member
States. There will also be employment
opportunity related to providing ongoing
maintenance for the new testing
equipment.
Indirect benefits
Reduction in the number
of fatalities and serious
injuries relative to the
baseline (cumulative over
2026-2050)
6,912 lives saved and 64,885 serious injuries
avoided
Indirect benefit to society at large.
Significant positive effects on road safety
are expected, in particular due to to the
more effective identification of vehicles
with major and dangerous defects in the
fleet, which should lead to the reduction
of road crashes caused by technical
defects and, as a result, to reduced
fatalities and injuries. Measures which
relate to better implementation and
enforcement of the roadworthiness
legislation will also contribute. The
impacts are estimated at 6,912 lives saved
and 64,885 serious injuries avoided over
the 2026-2050, relative to the baseline.
Reduction in external
costs of accidents
(fatalities and injuries),
expressed as present value
over 2026-2050, relative
to the baseline
EUR 74.2 billion Indirect benefit to society at large, due to
the lives saved and injuries avoided. The
reduction in the external costs of
accidents is estimated at EUR 74.2
billion, expressed as present value over
the 2026-2050 horizon (in 2022 prices)
relative to the baseline.
Reduction of air pollutant
emissions (kilo tonnes of
NOx and PM2.5 avoided)
(cumulative over 2026-
2050)
Air pollutants reduction: 3,969 kilo-tonnes of
NOx and 199 kilo-tonnes of PM
Indirect benefit to society at large
Significant positive effects on
environment are expected, due to the
measures having an impact on air
pollutant emissions and targeted at high
emitters of NOx and particulate matter in
the vehicle fleet, which should be
effectively identified and repaired, with
expected cumulative impact on air
pollutants reduction 3,969 kilo-tonnes of
NOx and 199 kilo-tonnes of PM over
2026-2050.
Reduction in the external
costs of air pollutant
emissions relative to the
baseline, expressed as
present value over 2026-
2050
EUR 76.1 billion Indirect benefit to society at large, due to
the reduced air pollutant emissions. The
reduction in the external costs of air
pollution is estimated at EUR 76.1
billion, expressed as present value over
the 2026-2050 horizon (in 2022 prices)
relative to the baseline.
Reduction in the external
costs of noise emissions
EUR 7.3 billion Indirect benefit to society at large, due to
the reduced noise emissions. The
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I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)
Description Amount Comments
relative to the baseline,
expressed as present value
over 2026-2050
reduction in the external costs of noise
pollution is estimated at EUR 7.3 billion,
expressed as present value over the 2026-
2050 horizon (in 2022 prices) relative to
the baseline.
II. Overview of costs – Preferred option (PO2)
Citizens/Consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurrent
Direct adjustment costs
(expressed as present value
over 2026-2050, relative to
the baseline)
- - For PTI
centres: EUR
3.2 billion
For PTI
centres: 20.1
billion
For
national
public
authorities:
EUR 29.7
million
For national
public
authorities:
EUR 177.5
million
Direct administrative costs
(expressed as present value
over 2026-2050, relative to
the baseline)
- For citizens
(vehicle
owners): EUR
13.7 billion
For
businesses:
EUR 218
million, of
which:
- EUR 48.9
million for
PTI centres
- EUR 149.2
million for
garages, repair
stations, etc.
- EUR 20
million for
vehicle
manufacturers
For
businesses:
EUR 26.1
billion, of
which:
- EUR 87.7
million for
PTI centres
- EUR 310.8
million for
garages, repair
stations, etc.
- EUR 35.9
million for
vehicle
manufacturers
- EUR 25.7
billion for
other
businesses
(for vehicle
owners)
For
national
public
authorities:
EUR 77.9
million
For national
public
authorities:
EUR 2.31
billion
Direct regulatory fees and
charges
- - - - - -
Direct enforcement costs
(expressed as present value
over 2026-2050, relative to
the baseline)
- - - - - -
Indirect costs - - - - - -
107
III. Application of the ‘one in, one out’ approach – Preferred option (PO2)
[M€] One-off
(annualised total net present
value over the relevant
period)
Recurrent
(nominal values per year)
Total
Businesses
New administrative
burdens (INs)
EUR 25.5 million, of
which:
- EUR 5.7 million for the
PTI centres
- EUR 2.3 million for
vehicle manufacturers
- EUR 17.5 million for
garages, repair stations
EUR 26.4 million, of which:
- EUR 4.9 million for PTI
centres
- EUR 2 million for vehicle
manufacturers
- EUR 19.5 million for garages,
repair stations, etc.
EUR 51.9 million, of
which:
-EUR 10.6 million for
PTI centres
-EUR 4.3 million for
vehicle manufacturers
-EUR 37 million for
garages, repair
stations, etc.
Removed
administrative burdens
(OUTs)
- - -
Net administrative
burdens
EUR 25.5 million EUR 26.4 million EUR 51.9 million
Adjustment costs
(expressed as present
value over 2026-2050,
relative to the
baseline)
For PTI centres: EUR
3.2 billion
For PTI centres: 20.1 billion
Citizens
New administrative
burdens (INs)
- - -
Removed
administrative burdens
(OUTs)
- - -
Net administrative
burdens
- - -
Adjustment costs - -
Total administrative
burdens
EUR 25.5 million EUR 26.4 million EUR 51.9 million
3. RELEVANT SUSTAINABLE DEVELOPMENT GOALS
IV. Overview of relevant Sustainable Development Goals – Preferred Option (PO2)
Relevant SDG Expected progress towards the
Goal
Comments
SDG 3 (Ensure healthy lives and
promote well-being for all at all
ages) including targets 3.6 (halving
the number of deaths and injuries
from road traffic accidents) and 3.9
(by 2030, substantially reduce the
Reduction in the number of
fatalities and serious injuries
relative to the baseline (cumulative
over 2026-2050):
6,912 lives saved and 64,885 serious
injuries avoided
Legislation on safe vehicles is a core
element of the Safe System Approach in
road safety and a core principle of the
108
IV. Overview of relevant Sustainable Development Goals – Preferred Option (PO2)
Relevant SDG Expected progress towards the
Goal
Comments
number of deaths and illnesses
from hazardous chemicals and air,
water and soil pollution and
contamination) for the air pollution
emissions.
Reduction of air pollutant emissions
(kilo tonnes of NOx and PM2.5
avoided), cumulative over 2026-
2050:
air pollutants reduction 3,969 kilo-
tonnes of NOx and 199 kilo-tonnes
of PM
2020 UN “Stockholm Declaration on
road safety”248
248
https://www.roadsafetysweden.com/contentassets/b37f0951c837443eb9661668d5be439e/stockholm-declaration-
english.pdf
109
ANNEX 4: ANALYTICAL METHODS
1. DESCRIPTION OF THE ANALYTICAL METHODS USED
The main model used for developing the baseline scenario for this initiative is the PRIMES-TREMOVE
transport model by E3Modelling, a specific module of the PRIMES models. The model has a successful
record of use in the Commission's energy, transport and climate policy assessments. In particular, it has
been used for the impact assessments underpinning the Communication on a 2040 climate target249
, the “Fit
for 55” package250
, the impact assessments accompanying the 2030 Climate Target Plan251
and the Staff
Working Document accompanying the Sustainable and Smart Mobility Strategy252
, the Commission’s
proposal for a Long Term Strategy253
as well as for the 2020 and 2030 EU’s climate and energy policy
framework. In addition, building on the PRIMES-TREMOVE model results, the baseline projections for
the number of periodic technical inspections (PTI) have been developed by Ricardo et al. in the context of
the impact assessment support study254
.
For the assessment of the impacts of the policy options, the PRIMES-TREMOVE model has been used for
quantifying the impacts on the number of fatalities and injuries, as well as the impacts on the air pollutant
and noise emissions. An Excel-based tool has been additionally developed in the context of the impact
assessment support study, to quantify the impacts on costs and costs savings. The Excel-based tool draws
on the Standard Cost Model. The proposed measures are assumed to be implemented from 2026 onwards,
so that the assessment has been undertaken for the 2026-2050 period and refers to EU27. Costs and benefits
are expressed as present value over the 2026-2050 period, using a 3% discount rate.
PRIMES-TREMOVE model
The PRIMES-TREMOVE transport model projects the evolution of demand for passengers and freight
transport, by transport mode, and transport vehicle/technology, following a formulation based on
microeconomic foundation of decisions of multiple actors. Operation, investment and emission costs,
various policy measures, utility factors and congestion are among the drivers that influence the projections
of the model. The projections of activity, equipment (fleet), usage of equipment, energy consumption and
emissions (and other externalities) constitute the set of model outputs.
The PRIMES-TREMOVE transport model can therefore provide the quantitative analysis for the transport
sector in the EU, candidate and neighbouring countries covering activity, equipment, energy and emissions.
The model accounts for each country separately which means that the detailed long-term outlooks are
available both for each country and in aggregate forms (e.g. EU level).
In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g. eco-driving,
labelling); economic measures (e.g. subsidies and taxes on fuels, vehicles, emissions; ETS for transport
when linked with PRIMES; pricing of congestion and other externalities such as air pollution, accidents and
noise; measures supporting R&D); regulatory measures (e.g. CO2 emission performance standards for new
light duty vehicles and heavy duty vehicles; EURO standards on road transport vehicles; technology
standards for non-road transport technologies, deployment of Intelligent Transport Systems) and
249
EUR-Lex - 52024DC0063 - EN - EUR-Lex (europa.eu)
250
Delivering the European Green Deal | European Commission (europa.eu)
251
SWD(2020)176 final.
252
EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu)
253
Source: 2050 long-term strategy (europa.eu)
254
Ricardo et al. (2024), Impact assessment support study on the directives of the roadworthiness package, Contract no.
MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001
110
infrastructure policies for alternative fuels (e.g. deployment of refuelling/recharging infrastructure for
electricity, hydrogen, LNG,CNG). Used as a module that contributes to the PRIMES energy system model,
PRIMES-TREMOVE can show how policies and trends in the field of transport contribute to economy-
wide trends in energy use and emissions. Using data disaggregated per Member State, the model can show
differentiated trends across Member States.
The PRIMES-TREMOVE has been developed and is maintained by E3Modelling, based on, but
extending features of, the open source TREMOVE model developed by the TREMOVE255
modelling
community. Part of the model (e.g. the utility nested tree) was built following the TREMOVE
model.256
Other parts, like the component on fuel consumption and emissions, follow the COPERT
model.
Data inputs
The main data sources for inputs to the PRIMES-TREMOVE model, such as for activity and energy
consumption, come from EUROSTAT databases and from the Statistical Pocketbook "EU transport
in figures257
. Excise taxes are derived from DG TAXUD excise duty tables. Other data comes from
different sources such as research projects (e.g. TRACCS and New Mobility Pattern projects) and
reports.
In the context of this exercise, the PRIMES-TREMOVE transport model is calibrated to 2005, 2010 and
2015 historical data. Available data on 2020 market shares of different powertrain types has also been taken
into account.
2. BASELINE SCENARIO
In order to reflect the fundamental socio-economic, technological and policy developments, the
Commission prepares periodically an EU Reference Scenario on energy, transport and GHG
emissions. The socio-economic and technological developments used for developing the baseline
scenario for this impact assessment build on the latest “EU Reference scenario 2020”258
. The same
assumptions have been used in the policy scenarios underpinning the impact assessments
accompanying the “Fit for 55” package259
.
255
https://www.tmleuven.be/en/navigation/TREMOVE
256
Several model enhancements were made compared to the standard TREMOVE model, as for example: for the number
of vintages (allowing representation of the choice of second-hand cars); for the technology categories which include
vehicle types using electricity from the grid and fuel cells. The model also incorporates additional fuel types, such as
biofuels (when they differ from standard fossil fuel technologies), LPG, LNG, hydrogen and e-fuels. In addition,
representation of infrastructure for refuelling and recharging are among the model refinements, influencing fuel choices.
A major model enhancement concerns the inclusion of heterogeneity in the distance of stylised trips; the model considers
that the trip distances follow a distribution function with different distances and frequencies. The inclusion of
heterogeneity was found to be of significant influence in the choice of vehicle-fuels especially for vehicles-fuels with
range limitations.
257
EU transport in figures: Statistical Pocketbook - European Commission (europa.eu)
258
EU Reference Scenario 2020 (europa.eu)
259
Policy scenarios for delivering the European Green Deal (europa.eu)
111
Main assumptions of the Baseline scenario
The main assumptions related to economic development, international energy prices and technologies are
described below.
Economic assumptions
The modelling work is based on socio-economic assumptions describing the expected evolution of the
European society. Long-term projections on population dynamics and economic activity form part of the
input to the model and are used to estimate transport activity, particularly relevant for this impact
assessment.
Population projections from Eurostat260
are used to estimate the evolution of the European
population, which is expected to change little in total number in the coming decades. The GDP
growth projections are from the Ageing Report 2021261
by the Directorate General for Economic and
Financial Affairs, which are based on the same population growth assumptions.
Table 30: Projected population and GDP growth per Member State
Population GDP growth
2020 2025 2030 2020-‘25 2026-‘30
EU27 447.7 449.3 449.1 0.9% 1.1%
Austria 8.90 9.03 9.15 0.9% 1.2%
Belgium 11.51 11.66 11.76 0.8% 0.8%
Bulgaria 6.95 6.69 6.45 0.7% 1.3%
Croatia 4.06 3.94 3.83 0.2% 0.6%
Cyprus 0.89 0.93 0.96 0.7% 1.7%
Czech Republic 10.69 10.79 10.76 1.6% 2.0%
Denmark 5.81 5.88 5.96 2.0% 1.7%
Estonia 1.33 1.32 1.31 2.2% 2.6%
Finland 5.53 5.54 5.52 0.6% 1.2%
France 67.20 68.04 68.75 0.7% 1.0%
Germany 83.14 83.48 83.45 0.8% 0.7%
Greece 10.70 10.51 10.30 0.7% 0.6%
Hungary 9.77 9.70 9.62 1.8% 2.6%
Ireland 4.97 5.27 5.50 2.0% 1.7%
Italy 60.29 60.09 59.94 0.3% 0.3%
Latvia 1.91 1.82 1.71 1.4% 1.9%
Lithuania 2.79 2.71 2.58 1.7% 1.5%
Luxembourg 0.63 0.66 0.69 1.7% 2.0%
Malta 0.51 0.56 0.59 2.7% 4.1%
Netherlands 17.40 17.75 17.97 0.7% 0.7%
Poland 37.94 37.57 37.02 2.1% 2.4%
Portugal 10.29 10.22 10.09 0.8% 0.8%
Romania 19.28 18.51 17.81 2.7% 3.0%
Slovakia 5.46 5.47 5.44 1.1% 1.7%
Slovenia 2.10 2.11 2.11 2.1% 2.4%
260
EUROPOP2019 population projections: Eurostat - Data Explorer (europa.eu)
261
The 2021 Ageing Report : Underlying assumptions and projection methodologies The 2021 Ageing Report:
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu)
112
Population GDP growth
2020 2025 2030 2020-‘25 2026-‘30
Spain 47.32 48.31 48.75 0.9% 1.6%
Sweden 10.32 10.75 11.10 1.4% 2.2%
Beyond the update of the population and growth assumptions, an update of the projections on the sectoral
composition of GDP was also carried out using the GEM-E3 computable general equilibrium model. These
projections take into account the potential medium- to long-term impacts of the COVID-19 crisis on the
structure of the economy, even though there are inherent uncertainties related to its eventual impacts.
Overall, conservative assumptions were made regarding the medium-term impacts of the pandemic on the
re-localisation of global value chains, teleworking and teleconferencing and global tourism.
International energy prices assumptions
Alongside socio-economic projections, transport modelling requires projections of international fuel
prices. The table below shows the oil prices assumptions of the baseline and policy options of this
impact assessment, that draw on the modelling underpinning the REPowerEU package262
.
Table 31: Oil prices assumptions
Oil 2015 2020 2030 2040 2050
in $'15 per boe 52.3 39.8 92.1 97.4 117.9
in €'15 per boe 47.2 35.8 83.0 87.8 106.3
Technology assumptions
Modelling scenarios is highly dependent on the assumptions on the development of technologies,
both in terms of performance and costs. For the purpose of the impact assessments related to the “Fit
for 55” policy package, these assumptions have been updated based on a rigorous literature review
carried out by external consultants in collaboration with the JRC and consulted with stakeholders263
.
In addition, the technology assumptions for heavy duty vehicles have been updated in the context of
the work on the impact assessment accompanying the revision of the HDVCO2 standards Regulation264
.
The same assumptions have been used in the context of this impact assessment.
Policies in the Baseline scenario
The EU Reference scenario 2020 (REF2020) is the starting point for the impact assessment of this
initiative. The REF2020 takes into account the impacts of the COVID-19 pandemic that had a
significant impact on the transport sector. More detailed information about the preparation process,
assumptions, and results are included in the Reference scenario publication265
. Building on REF2020,
the baseline has been designed to include the initiatives of the ‘Fit for 55’ package proposed by the
Commission on 14 July 2021266
and the initiatives of the RePowerEU package proposed by the
Commission on 18 May 2022267
. The baseline scenario factors in the revision of the HDV CO2 standards
262
SWD(2022)230 final.
263
EU Reference Scenario 2020 (europa.eu)
264
SWD(2023) 88 final
265
EU Reference Scenario 2020 (europa.eu)
266
https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en
267
https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131
113
Regulation268
andthenewEuro7standards269,270
,theproposedend-of-lifevehicles (ELV)Regulation271,272
and the forthcoming initiative on fair and non-discriminatory access to in-vehicle data273
, as well as other
initiatives part of the Road Safety package274
and the Greening Freight package275
.
The baseline scenario assumes no further EU level intervention beyond the current Roadworthiness
Package (i.e., the PTI and the RSI Directives as amended by the delegated Regulations to align with
the evolution of type-approval legislation276
and to introduce the testing of eCall at PTI277
, and the
VRD Directive as last amended by the revision of the Eurovignette Directive278
). As some of the
provisions of the RWP allowed for a very long transition period279
, certain Member States are still
notifying transposition measures to the Commission. In addition, the baseline reflects the introduction
of PN measurement by three Member States280
.
The baseline also incorporates foresight megatrends281
and developments captured in the 2022 Strategic
Foresight Report282
. Among others, it captures the trend of increasing demand for transport as population
and living standards grow as well as the links between the digital and green transition. In particular, the
projected transport activity draws on the long-term population projections from Eurostat and GDP growth
from the Ageing Report 2021283
by the Directorate General for Economic and Financial Affairs.
Baseline scenario results
Transport activityprojections. Inthebaselinescenario,EUtransport activityis projectedtogrowpost-2020,
following the recovery from the COVID pandemic. Road transport would maintain its dominant role within
the EU by 2050. Road passenger transport activity (expressed in passenger-kilometres)284
is projected to
grow by 10% between 2015 and 2030 (27% for 2015-2050), while road freight transport activity (expressed
268
Regulation (EU) 2024/1610.
269
COM(2022) 586 final.
270
Taking into account the expected effects of the Euro 7, based on the Commission’s proposal, the currently dominant
Euro 5/V and 6/VI vehicles should be gradually replaced by new ones complying with the Euro 7 standard. This would
result in reduced levels of tampering and lower emissions, in particular for heavy-duty vehicles. A limitation to mention
here is that the baseline reflects the Commission proposal. Following the changes by the co-legislators, the baseline likely
overestimates the reduction in the air pollution emissions over time and thus slightly underestimates the contribution of
this initiative to the air pollution emissions reduction. This is particularly relevant in the short to medium term. In the
medium to long term this is less relevant due to the expected large-scale penetration of the zero-emission vehicles in the
fleet.
271
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023PC0451
272
The proposal for a Regulation on end-of-life vehicles (ELV) (COM(2023) 451 final) calls for data related to the
reasons of deregistering vehicles to be recorded in the national vehicle registers (see Recital 86).
273
According to current plans, the proposal on access to in-vehicle data would provide for non-discriminatory access to
such data in a harmonised, machine-readable format. This will be key for vehicle inspection too, without, however,
specifying the means of data access, which will continue to allow manufacturers to set their own (often cumbersome)
rules.
274
Proposal for a Directive amending the Driving Licence Directive, proposal for a Directive amending the Cross-Border
Enforcement Directive and proposal for a Directive on the Union-wide effect of certain driving disqualifications.
275
Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu)
276
https://eur-lex.europa.eu/eli/dir_del/2021/1717/oj and https://eur-lex.europa.eu/eli/dir_del/2021/1716/oj
277
https://eur-lex.europa.eu/eli/reg/2015/758/oj
278
Directive (EU) 2022/362 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520, as regards the charging
of vehicles for the use of certain infrastructures, https://eur-lex.europa.eu/eli/dir/2022/362/oj
279
For example, PTI for motorcycles (with a possibility for exemptions) since January 2022; the deadline to equip all test
centres with all the required equipment was 20 May 2023 (five years after the date of application).
280
Belgium, Germany and the Netherlands.
281
https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore
282
COM(2022) 289 final.
283
doi:10.2765/733565.
284
Covering passenger cars, buses and coaches and power-two wheelers.
114
in tonne-kilometres)285
by 27% during 2015-2030 (52% for 2015-2050). Rail transport activity is projected
to grow significantly faster than for road, driven in particular by the completion of the TEN-T core network
by 2030 and of the comprehensive network by 2050, supported by the CEF, Cohesion Fund and ERDF
funding, but also by measures of the ‘Fit for 55’ package286
and the Greening Freight package. Passenger
rail activity is projected to go up by 37% by 2030 relative to 2015 (86% for 2015-2050). Freight rail traffic
would increase by 50% by 2030 relative to 2015 (107% for 2015-2050).
Zero-emission vehicles. The share of zero-emission vehicles in the light duty vehicle fleet (passenger cars
and light commercial vehicles) is projected at 15% in 2030, going up to 95% in 2050 in the baseline
scenario, while for heavy duty vehicle fleet (buses and coaches, and heavy goods vehicles) at 6% in 2030
and 72% in 2050. These developments are driven by the CO2 standards Regulations, supported by the
Alternative Fuels Infrastructure Regulation.
High-emitting vehicles. The current limitations of the emission testing methods applied under the PTI
and RSI Directives are expected to persist in the baseline scenario, with the shares of high-emitting
vehicles287
in the Euro 5/V and Euro 6/VI fleet remaining largely the same. On the other hand, the
share of high-emitting vehicles in the Euro 7 fleet is expected to be lower than for Euro 5/V and Euro
6/VI. The shares of high-emitting vehicles are further discussed in the section below.
Air pollution and CO2 emissions projections. The uptake of zero-emission vehicles and the
penetration of Euro 7 vehicles in the fleet, combined, are expected to result in significant reductions
of the air pollution emissions from road transport in the baseline scenario. NOx emissions are
projected to reduce by 52% in 2030 relative to 2015 (98% reduction for 2015-2050), while particulate
matter (PM2.5) emissions would decrease by 43% in 2030 relative to 2015 (98% reduction for 2015-
2050). CO2 emissions from road transport are projected to decrease by 32% by 2030 relative to 2015,
and be close to zero by 2050, thanks to the large-scale uptake of zero-emission vehicles and some
use of renewable and low-emission fuels.
Projected number of fatalities and injuries. In the baseline scenario, the number of fatalities is
projected to decrease by 24% by 2030 relative to 2015 and by 31% by 2050 relative to 2015288
. The
number of serious and slight injuries is projected to decrease by 19% between 2015 and 2030 and by
26% for 2015-2050. This is despite the increase in traffic over time. Relative to 2019, the number of
fatalities would decrease by 15% by 2030 and 23% by 2050, and the number of serious injuries by
10% by 2030 and 18% by 2050. Thus, the targets of the EU Road Safety Policy Framework 2021-
2030 – Next steps towards “Vision Zero”, of reducing the number of road deaths and the number of
serious injuries by 50% between 2019 and 2030, would not be met. In addition, this is still far from
the goal of the Sustainable and Smart Mobility Strategy of a close to zero death toll for all modes of
transport in the EU by 2050.
285
Covering heavy goods vehicles and light commercial vehicles.
286
These measures increase to some extent the competitiveness of rail relative to road and air transport.
287
It should be noted that there is no standard definition of a high emitter. One possible definition would be: a vehicle
whose average emissions are at least 2 standard deviations higher than the average emissions of the sample tested
(https://pure.iiasa.ac.at/id/eprint/10156/1/XO-12-019.pdf). A pragmatic approach has been used for the analysis, making
use of information/data provided in relevant studies, while recognising that they are not always consistent in the definition
applied. Furthermore, it should be noted that high emitters may be vehicles with defective emission or noise control
systems or vehicles with tampered emissions/noise control systems. In the absence of more detailed information, a 50%
share of defective and tampered vehicles is assumed in the total share of high emitters in the fleet.
288
Projections refer to injuries in accidents in which a passenger vehicle (car), a light commercial vehicle (van), a bus or
a truck, or a motorcycle is involved.
115
Number of periodic technical inspections and odometer fraud. In the baseline scenario, the number
of periodic technical inspections (PTI) for LDVs, HDVs and motorcycles is projected to increase
from 151.5 million in 2015 to 168.9 million in 2030 and 192.3 million in 2050289
. For O1 and O2
vehicles the number of inspections is projected at 7.9 million in 2030 and 8.7 million in 2050. More
details on these projections are presented below.
At the same time, the number of national second-hand vehicle sales with mileage fraud at EU level
is projected at 1.63 million in 2026, 1.71 million in 2030 and 1.90 million in 2050, and that of cross
border vehicle sales with mileage fraud at 3.18 million in 2026, 3.35 million in 2030 and 3.64 million
in 2050. The national and cross-border odometer fraud is estimated to lead to damages for European
consumers estimated at EUR 10.2 billion in 2026, EUR 10.7 billion in 2030 and EUR 11.7 billion in
2050290
. Expressed as present value over 2026-2050 this amounts to EUR 194.6 billion.
Share of high emitter vehicles of air pollution emissions
The limitation of the current testing methods to effectively identify vehicles with defective or
tampered emission control systems is expected to continue under the baseline scenario. As such, the
current situation in terms of shares of high emitter vehicles and the resulting level of emissions from
high emitters – per Euro standards and vehicle age group and Euro standard - is expected to remain
largely the same. On the other hand, the move towards Euro 7 and the use of OBM will help reduce
the level of tampering in comparison to Euro 5 and Euro 6. Therefore, the share of high emitters in
the Euro 7 fleet is expected to be lower, although still increasing for older age groups.
It should however be noted that the increase in the share of zero-emission vehicles in the fleet over
time, will reduce the number of defective/tampered vehicles and the associated tailpipe emissions in
the overall fleet.
In the context of the stakeholders’ consultation, the view expressed show no firm confidence that the
current RWP can reduce the number of vehicles with defective or tampered emission control systems
(weighted average of responses, in a scale of 1-None at all to 7-Very high, was 3.5). A similar
assessment was provided in terms of the expected contribution to reducing high emitting vehicles on
the road by technological development or by other measures taken at the Member State level
(weighted average of responses of 3.6 and 3.8, respectively).
Data is limited but the analysis of available evidence based on remote sensing campaigns in different
Member States has allowed to develop estimates on the shares of high emitters for different vehicle
type and age groups.
Information on high emitter shares for motorcycles - and more generally for L-category vehicles - is
even more limited. Data from PTI in Spain291 reveal that 15% of the deficiencies in L-category
vehicles are related to nuisance, which includes air pollutant and noise emissions. However, the
information available does not provide the proportion of the fleet this represents. Data from Germany
suggests that emission defects represent 0.4% of the total across the whole fleet tested. As expected,
the percentage of defective vehicles is higher among older motorcycles (>9 years). However, in both
cases the numbers refer to the results of PTI inspections that cannot effectively capture the occurrence
of tampering. Hence, this is expected to underestimate the share of high emitters in the fleet. As for
289
They are derived based on the ‘testing frequency’ and the average number of PTIs in the statistical life of a vehicle.
290
The average cost of mileage fraud, due to higher purchase price and maintenance costs incurred, is estimated at EUR
2,119 per vehicle in 2022 prices drawing on a Belgian Car-Pass study (https://www.car-
pass.be/files/article_files/file/7/crm%2520study%2520final%2520report.pdf).
291
UC3M (2019), Roadworthiness testing contribution to vehicle safety and environment.
116
motorcycles no data is currently available from remote sensing campaigns, in the baseline it is
assumed that motorcycles follow the same profile as petrol Euro 5 passenger car vehicles, in terms
of shares of high emitters and emissions ratios. This is considered a conservative estimate in the
absence of more specific data.
The tables below summarise the assumptions on the share of high emitters and their respective
emission rates in the baseline scenario. These have been assumed to remain stable over time for the
respective vehicle groups.
Table 32: Share (%) of M1 high emitter vehicles in the stock, by age group and Euro standard
Diesel Petrol
Vehicle’s age (years) Euro 5 Euro 6 Euro 7 Euro 5 Euro 6 Euro 7
NOx
0-4 2.5 2.5 1.3 3.5 3.3 1.6
5-9 5.0 5.0 3.0 6.5 6.5 3.3
10-14 7.5 7.5 4.5 9.8 9.8 4.9
15-19 10.0 10.0 5.0 13.0 13.0 6.5
PM/PN
0-4 2.5 2.5 1.3 2.6 2.6 1.3
5-9 5.0 5.0 3.0 5.2 5.2 2.6
10-14 7.5 7.5 4.5 7.8 7.8 3.9
15-19 10.0 10.0 5.0 10.4 10.4 5.2
Source: Ricardo et al. (2024), Impact assessment support study
Table 33: Share (%) of N1 high emitter vehicles in the stock by age group and Euro standard
Diesel Petrol
Vehicle’s age (years) Euro 5 Euro 6 Euro 7 Euro 5 Euro 6 Euro 7
NOx
0-4 6.0 6.0 3.0 7.8 7.8 3.9
5-9 9.0 9.0 4.5 11.7 11.7 5.9
10-14 12.0 12.0 6.0 15.6 15.6 7.8
15-19 15.0 15.0 7.5 19.5 19.5 9.8
PM/PN
0-4 6.0 6.0 3.0 6.2 6.2 3.1
5-9 9.0 9.0 4.5 9.4 9.4 4.7
10-14 12.0 12.0 6.0 12.5 12.5 6.2
15-19 15.0 15.0 7.5 15.6 15.6 7.8
Source: Ricardo et al. (2024), Impact assessment support study
Table 34: Shares (%) of N2/N3 and M2/M3 high emitter vehicles in the stock by Euro standard and age
Vehicle’s age (years) Euro V Euro VI Euro 7
NOx
0-4
10.3
7.2 3.6
5-9
12.6
8.8 4.4
10-14
14.9
10.4 5.2
15-19
17.2
12.0 6.0
117
Source: Ricardo et al. (2024), Impact assessment support study
Table 35: Shares (%) of L high emitter vehicles in stock by age
Source: Ricardo et al. (2024), Impact assessment support study
Emission rates
The emission rate is defined as the ratio between the emission of a defective vehicle and a vehicle
with its emission control system functioning according to the requirements.
The values used in the baseline scenario, summarised in the table below, are based on the evidence
available in the literature and on experts’ consultation. Valuable source of information were the DIAS
project292, the CITA paper293, and the TNO study294.
Table 36: Emission rates of high emitters vehicles (defective and tampered) for air pollutants by Euro standard
Source: Ricardo et al. (2024), Impact assessment support study
Share of high emitter vehicles of noise emissions
Data for motorcycles – vehicle category L – exceeding the legal noise threshold is very limited and
does not allow to reach specific conclusions. Feedback from stakeholders suggests that the issue of
292
DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations.
293
CITA (2022), Monitoring of NOx emissions as part of the PTI. Position Paper.
294
TNO (2022), Approaches for detecting high NOx emissions of aged petrol cars during the periodic technical
inspection. R10659v2.
PM/PN
0-4
10.3
7.2 3.6
5-9
12.6
8.8 4.4
10-14
14.9
10.4 5.2
15-19
17.2
12.0 6.0
Vehicle’s age (years) NOx PM/PN
0-4 3.5 2.6
5-9 6.5 5.2
10-14 9.7 7.8
15-19 13.0 10.4
Vehicle Euro 5/V Euro 6/VI Euro 7
NOx
M1/N1 diesel 4 10 20
M1/N1 petrol 6 10 20
N2/N3/M2/M3 4 10 20
L3-L7 5
PM/PN
M1/N1 diesel 10 10 50
M1/N1 petrol 5 5 25
N2/N3/M2/M3 4 10 50
L 5
118
vehicles with defective or tampered noise control systems on the EU’s roads has not been effectively
addressed till now and it is expected to persist. It was noted that based on differences in the
composition of the motorcycle fleet and the intensity of use of motorcycles between North and South
Europe, the share of high emitters may be higher in the South.
According to data from PTI in Spain295 around 15% of L-category vehicles tested showed major
deficiencies related to emissions and vehicle noise. In Germany, where noise is reported separately,
a very low share of total defects related to noise was identified (1%). However, especially in the case
of noise tampering, PTI is considered as particularly ineffective due to the ease with which the noise
control system can be activated or deactivated for L category vehicles. Therefore, the results from
PTI are expected to underestimate the scale of the problem. The fact that the problem is more
widespread than what shown at PTI is revealed by the 30% share of motorcycles with tampered noise
control systems found by police in Bavaria, during roadside checks, during the European Bike Week
in 2018296.
In the baseline it is assumed that on average 30% of L-vehicles emit noise above the legal limit.
Share of vehicles with tampered odometers
There are limited sources of evidence in terms of the level and evolution of odometer tampering.
According to a study commissioned by the European Parliament297
, tampering rates were estimated
between 5% and 12% of national second hand vehicles sales and between 30% and 50% of cross-
border second hand vehicles sales. Tampering was found to be more common among vehicles
imported in EU12 Member States, estimated in the range of 30% to 80%, in comparison to 20%-40%
of the second hand vehicles imported in EU15 countries.
More recent estimates provided by CarVertical298
, based on analysis of vehicle history reports,
suggest overall lower odometer fraud rates for most of the countries reported than those in the
European Parliament study. However, except for the Car-Pass system in Belgium, adopted in 2006,
and a similar system implemented in the Netherlands, no other Member State has taken action so far.
Both have achieved significant reduction to the level of odometer tampering – especially in relation
to national sales, by requiring that readings are submitted after any maintenance, repair, assembly or
inspection. It has been reported that odometer tampering has almost been eliminated (up to 97%
success rates)299
in Belgium, a point also supported by the Car-Pass manager during the stakeholders’
consultation. Other Member States (e.g. Slovakia, Luxembourg, France) are considering the
introduction of relevant measures but so far no action has been taken.
The table below presents the estimated shares of odometer tampering for national and imported
second hand vehicles. In the case of Member States where data is not available (cells in grey) the
median values for EU12 and EU15 have been used. Values in blue and italics, concerning cross-
border fraud rates, were based on the finding of the European Parliament study (also supported by
CarVertical data) that cross border odometer fraud rates are around twice those of national odometer
295
UC3M (2019), Roadworthiness testing contribution to vehicle safety and environment.
296
About motorcycles (2018), Police control Bike Week Faaker, see 2018. Retrieved from About motorcycles:
https://misfitmademotorcycles.com/police-control-bike-week-faaker-see-2018/
297
Research for TRAN Committee - Odometer tampering: measures to prevent it (europa.eu)
298
Overall mileage fraud analysis is available at : https://www.carvertical.com/blog/research-what-countries-have-the-
highest-percentage-of-cars-with-a-fake-mileage and in the CarVertical Market transparency index
(https://www.carvertical.com/transparency-index ). Specific analysis of the share of odometer tampering for national and
imported second hand vehicles is available at : https://www.carvertical.com/blog/research-local-or-imported-cars-have-
more-mileage-rollbacks
299
TRT (2017), Research for TRAN Committee (European Parliament) - Odometer tampering: measures to prevent it.
119
fraud rates. Values in green are drawing on the data from Car-Pass for Belgium300
. The same rates
are assumed for the Netherlands.
Table 37: National and cross-border odometer fraud rates as shares of national and cross-border second hand
vehicle sales, respectively
Cross border odometer fraud rates National odometer fraud rates
AT 12.0% 4.0%
BE 0.2% 0.1%
BG 9.7% 4.9%
CY 12.0% 4.0%
CZ 13.6% 7.1%
DE 6.8% 3.4%
DK 8.1% 4.1%
EE 18.9% 7.4%
EL 12.0% 4.0%
ES 10.3% 3.8%
FI 7.5% 3.8%
FR 10.4% 3.7%
HR 9.1% 6.8%
HU 13.8% 9.6%
IE 12.0% 4.0%
IT 15.4% 5.3%
LT 18.8% 7.3%
LU 20.0% 10.0%
LV 25.7% 9.2%
MT 12.0% 4.0%
NL 0.2% 0.1%
PL 12.9% 5.6%
PT 4.4% 2.2%
RO 18.7% 5.9%
SE 12.0% 10.0%
SI 7.4% 3.7%
SK 8.9% 4.5%
Source: Ricardo et al. (2024), Impact assessment support study; Note: Values in bold are from CarVertical. Values in
italics and blue are based on the finding of the European Parliament study (also supported by CarVertical data) that
cross border odometer fraud rates are around twice those of national odometer fraud rates. Cells in grey reflect the
median values. Values in green and italics are based on data from Car-Pass for Belgium.
There is no evidence that the fraud rates would change over time in lack of action. The input from
stakeholders suggests that the issue of odometer tampering has not be effectively addressed up to this
point. Respondents were rather sceptical in relation to the role of technological developments and of
the existing roadworthiness package, but more positive on the role of national measures (weighted
average of responses on a scale of 1-‘None at all’ to 7-‘Very high’ were 3.1, 3.6 and 4.3 respectively).
They were even more sceptical when asked to indicate the expected contribution of technological
developments, the existing roadworthiness package and national measures to reducing the level of
odometer tampering in the future (weighted average of responses on a scale of 1-‘None at all’ to 7-
‘Very high’ were 3.2, 3.2 and 4.1 respectively). While recognising the possibility for action taken at
national level by some Member States, in the baseline scenario it has been assumed that the odometer
tampering rates will remain constant over time.
300
Car-Pass annual report 2022 - News about Car-Pass
120
Based on the projected number of second hand vehicles sales and the fraud rates, the projected
odometer tampering for national and cross-border sales in the baseline scenario are presented in the
tables below.
Table 38: Odometer tampering for national sales by Member State (number of vehicles) in the baseline scenario
2026 2030 2040 2050
AT 27,663 29,082 31,537 28,931
BE 459 483 475 463
BG 11,023 11,589 9,047 11,114
CY 1,313 1,381 1,263 1,411
CZ 54,579 57,377 60,172 59,126
DE 247,601 260,298 269,488 259,158
DK 20,920 21,993 24,297 23,783
EE 4,677 4,917 5,663 7,371
EL 28,388 29,844 23,627 30,595
ES 77,388 81,357 91,773 81,513
FI 18,869 19,836 18,836 18,401
FR 226,930 238,567 274,456 260,370
HR 12,940 13,604 12,965 18,986
HU 89,001 93,565 112,148 114,756
IE 11,869 12,478 13,847 14,412
IT 443,025 465,744 604,117 581,076
LT 18,756 19,718 22,992 22,508
LU 16,511 17,357 21,486 21,893
LV 3,733 3,925 5,245 5,221
MT 2,166 2,277 2,278 2,292
NL 1,595 1,677 1,981 1,704
PL 92,942 97,709 63,577 91,578
PT 10,552 11,093 13,362 12,903
RO 47,649 50,092 60,704 59,554
SE 135,124 142,053 130,506 140,141
SI 5,503 5,785 6,098 6,220
SK 20,755 21,819 23,834 23,287
EU27 1,631,930 1,715,619 1,905,771 1,898,770
Source: Ricardo et al. (2024), Impact assessment support study
Table 39: Odometer tampering for cross-border sales by Member State (number of vehicles) in the baseline
scenario
2026 2030 2040 2050
AT 124,483 130,867 141,915 130,189
BE 3,978 4,182 4,110 4,013
BG 83,946 88,251 68,893 84,640
CY 24,202 25,443 23,280 26,006
CZ 98,613 103,670 108,719 106,829
DE 237,345 249,517 258,326 248,424
DK 32,862 34,547 38,165 37,359
EE 40,536 42,615 49,087 63,891
EL 127,748 134,299 106,320 137,675
ES 319,806 336,207 379,251 336,853
FI 38,438 40,409 38,372 37,485
FR 530,593 557,803 641,715 608,782
HR 37,087 38,989 37,159 54,415
HU 117,061 123,064 147,505 150,936
121
2026 2030 2040 2050
IE 53,558 56,305 62,483 65,035
IT 318,608 334,947 434,460 417,890
LT 150,151 157,851 184,061 180,185
LU 14,152 14,878 18,417 18,765
LV 28,139 29,582 39,530 39,352
MT 9,773 10,274 10,278 10,345
NL 3,419 3,594 4,245 3,651
PL 318,222 334,541 217,678 313,549
PT 51,145 53,768 64,764 62,543
RO 293,029 308,057 373,319 366,244
SE 65,211 68,555 62,983 67,633
SI 19,839 20,856 21,986 22,426
SK 49,222 51,746 56,524 55,227
EU27 3,191,167 3,354,817 3,593,545 3,650,341
Source: Ricardo et al. (2024), Impact assessment support study
Odometer damage cost per vehicle
Detailed analysis of the cost of odometer tampering is provided in a European Parliament study301
.
According to the study, the total damage from odometer fraud is a result of three elements, notably:
• Unaccounted depreciation, that results from a car’s nominal (sales) value being higher than its
actual market value. One of the key determinants of car price is its mileage. Cars from the same
production year with a higher mileage cost less than cars with lower mileage. Odometer fraud
leads to a situation where part of the existing depreciation is not reflected in the value of the car
sold.
• Higher maintenance costs, that result from a higher frequency of repairs needed on a car with more
mileage. This is due to the wear of mechanical components of the vehicle.
• Additional environmental damages, that are a result of the unaccounted emissions. Vehicle-
kilometres missing from the odometer record have already been driven and the associated
emissions have taken place. This third element is however not considered in the analysis as this is
not a direct cost to the user.
Estimates on the damage from odometer fraud vary depending on vehicle size and level of mileage
tampering. According to a Belgian Car Pass study302
, the costs of odometer fraud to the user,
expressed in 2022 prices, are:
- For small cars: 3.4 EUR cents per missing vehicle-kilometre (vkm) for depreciation and 1.3 EUR
cents per vkm for maintenance;
- For medium size cars: 5.2 EUR cents per missing vehicle-kilometre (vkm) for depreciation and
3.2 EUR cents per vkm for maintenance;
- For executive/large cars: 7.7 EUR cents per missing vehicle-kilometre (vkm) for depreciation and
3.8 EUR cents per vkm for maintenance.
On this basis, the total costs per vehicle for different levels of odometer tampering (i.e. different
levels of mileage change) can be estimated. An weighted average per vehicle can be further derived
301
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
302
https://www.car-pass.be/files/article_files/file/7/crm%2520study%2520final%2520report.pdf
122
based on the fleet distribution by vehicle size from the baseline scenario developed with the PRIMES-
TREMOVE model for the period 2020-2050.
Table 40: Damage costs from odometer fraud per vehicle for different levels of odometer tampering
Vehicle size Cost category EUR cents
per vkm
Tampering level (km)
10,000 30,000 60,000 90,000
Small (45% share)
Depreciation 3.4 345 1,035 2,069 3,104
Maintenance 1.3 128 383 766 1,150
Total 473 1,418 2,835 4,253
Medium (45% share)
Depreciation 5.2 524 1,571 3,142 4,713
Maintenance 3.2 319 958 1,916 2,874
Total 843 2,529 5,058 7,587
Executive/Large (10% share)
Depreciation 7.7 766 2,299 4,598 6,897
Maintenance 3.8 383 1,150 2,299 3,449
Total 1,150 3,449 6,897 10,346
Weighted average (in 2022 prices) 706 2,119 4,239 6,358
Source: Ricardo et al. (2024), Impact assessment support study
For estimating the total damage costs/costs savings from odometer fraud, the weighted average cost
of EUR 2,119 per vehicle has been used, corresponding to tampering levels of 30,000 km, which is
considered a conservative estimate303
.
Additional evidence was identified based on a number of sources providing estimates of the costs
from odometer tampering, although with limited information on the assumptions used (e.g. level of
mileage fraud, vehicle size) and, as a result, limited comparability. Nonetheless, all sources point to
damage costs that are higher than EUR 2,000 per vehicle:
• According to CarVertical, tampered cars buyers spend 21% more on average for their vehicles.
The higher price depends on many factors, such as the brand, year of manufacture, and the number
of tampered kilometres304
. The United Kingdom (29% higher price than a non-tampered car), Italy
(29% higher price), and Lithuania (25% higher price) are among the countries where the value
increase of tampered cars is the highest, while in Ukraine (17% higher price than a non-tampered
car), Poland (19% higher price), and Romania (20% higher price) odometer fraud has the lowest
impact on a car’s value. More specifically:
- For every 100,000 kilometres tampered, buyers overspend around EUR 2,000.
- There are significant differences between car brands, with price increases varying from 15 to
27%, resulting in overspending between EUR 2,000 and EUR 10,700.
- The highest fake increase in value is found for Land Rover (27%), Mercedes-Benz (24%), and
BMW (24%) vehicles, while Dacia (15%), Mazda (15%), and Nissan (17%) models are
impacted by odometer fraud the least.
• According to an European Parliament study, odometer tampering has seen the mileage rolled back
on up to 50% of second-hand cars traded in the EU, with the price of vehicles fraudulently
increasing by EUR 2,000 to 5,000 on average305
.
303
Evidence from UK (UK: average kilometers clocked on used cars with a tampered odometer by Model Year | Statista),
suggests that the average kilometres of tampering has reduced over time with 30,000 representing an average.
304
https://www.carvertical.com/blog/odometer-fraud-vs-car-value
305
https://www.europarl.europa.eu/news/en/headlines/society/20180525STO04312/fighting-mileage-fraud-on-used-
cars
123
• According to ADAC, the fraudsters increase the value by an average of EUR 3,000 per car306
.
Projected number of periodic technical inspections (PTI)
The approach used to estimate the number of annual PTI inspections in each Member State and for
each vehicle type draws on the ‘testing frequency’ and the average number of PTIs in the statistical
life of a vehicle.
The formula used is:
Number of annual PTI inspections = Number of inspections during average life of vehicle x
Number of registered vehicles
EU Directive 2014/45/EU defines the minimum testing frequency that Member States must comply
with, but in many cases the testing is more frequent, as determined by national legislation. These
testing regimes have been identified for light duty vehicles, motorcycles, trucks, buses and coaches,
and trailers. The key sources of information are the European Commission website307
and a 2022
report by EReg308
.
The average vehicle life by Member State draws on ACEA309
. No data was available for motorcycles
and trailers. Thus, for these two vehicle categories, an average life of 18 years has been used. This
defines the period over which the number of PTIs are counted to estimate the average PTI number
during the vehicle’s life. The tables below present the testing regimes by Member State, the average
life and the average number of inspections for each vehicle type over the vehicle’s life.
The annual number of registered vehicles is based on the baseline scenario developed with the
PRIMES-TREMOVE model.
Table 41: Testing regime for light duty vehicle
Member State Testing regime Average age Number of inspections
during average life
Croatia 1-1-1 13.0 13.0
Latvia 2-2-1-1 15.0 13.0
Belgium 4-1-1 10.0 7.0
Austria 3-2-1 9.0 6.0
Bulgaria 3-2-1 13.0 10.0
Sweden 3-2-1 10.0 7.0
Luxembourg 4-2-1 8.0 4.0
Ireland 4-2-2-2-1 9.0 3.5
Netherlands 4-2-2-1 11.0 6.0
Portugal 4-2-2-1 14.0 9.0
Slovenia 4-2-2-1 11.0 6.0
Spain 4-2-2-2-1 14.0 8.0
Finland 4-2-2-2-1 13.0 7.0
Romania 3-2-2-2-2-1 15.0 9.0
306
https://www.adac.de/rund-ums-fahrzeug/auto-kaufen-verkaufen/gebrauchtwagenkauf/tacho-manipulation/
307
https://road-safety.transport.ec.europa.eu/road-safety-member-states/roadworthiness-certificate-and-proof-test_en
308
2022-the-vehicle-and-driver-chain.pdf (ereg-association.eu)
309
ACEA (2023), Vehicles in use Europe 2023, https://www.acea.auto/files/ACEA-report-vehicles-in-use-europe-
2023.pdf
124
Member State Testing regime Average age Number of inspections
during average life
Cyprus 4-2-2 13.0 5.5
Estonia 4-2-2-2-1 17.0 11.0
Germany 3-2-2 10.0 4.5
Lithuania 3-2-2 15.0 7.0
Poland 3-2-1 15.0 12.0
Czechia 4-2-2 16.0 7.0
Denmark 4-2-2 9.0 3.5
France 4-2-2 11.0 4.5
Greece 4-2-2 17.0 7.5
Hungary 4-2-2 15.0 6.5
Italy 4-2-2 12.0 5.0
Malta 4-2-2 13.0 5.5
Slovakia 4-2-2 14.0 6.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 42: Testing regime for motorcycles (no values are shown for MS that have not yet introduce a testing regime)
Member State Testing regime Average age Number of inspections
during average life
Croatia 1-1-1 18 18.0
Latvia 2-2-2 18 9.0
Belgium
Austria 3-2-1 18 15.0
Bulgaria 2-2-2 18 9.0
Sweden 4-2-2 18 8.0
Luxembourg 4-2-2 18 8.0
Ireland
Netherlands
Portugal
Slovenia 4-2-2 18 8.0
Spain 4-2-2 18 8.0
Finland
Romania 2-2-2 18 9.0
Cyprus 4-2-2 18 8.0
Estonia 4-2-2-2-1 18 12.0
Germany 2-2-2 18 9.0
Lithuania 3-2-2 18 8.5
Poland 3-1-1 18 16.0
Czechia 6-4-4 18 4.0
Denmark
France 4-2-2 18 8.0
Greece 4-2-2 18 8.0
Hungary 4-2-2 18 8.0
Italy 4-2-2 18 8.0
Malta
Slovakia 4-2-2 18 8.0
Source: Ricardo et al. (2024), Impact assessment support study
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Table 43: Testing regime for heavy duty vehicles designed and constructed primarily for the carriage of goods,
having a maximum mass exceeding 3.5 tonnes (N2 and N3)
Member State Testing regime Average age Number of inspections
during average life
Croatia 1 14 14.0
Latvia 1 14 14.0
Belgium 1 13 13.0
Austria 1 7 7.0
Bulgaria 1 13 13.0
Sweden 1 13 13.0
Luxembourg 1 8 8.0
Ireland 1 11 11.0
Netherlands 1 10 10.0
Portugal 1 16 16.0
Slovenia 1 10 10.0
Spain 1 14 19.0
Finland 1 14 14.0
Romania 1 19 19.0
Cyprus 1 13 13.0
Estonia 1 18 18.0
Germany 1 10 10.0
Lithuania 1 10 10.0
Poland 1 13 13.0
Czechia 1 18 18.0
Denmark 1 8 8.0
France 1 9 9.0
Greece 1 23 23.0
Hungary 1 13 13.0
Italy 1 19 19.0
Malta 1 13 13.0
Slovakia 1 16 16.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 44: Testing regime for heavy duty vehicles designed and constructed primarily for the carriage of over eight
persons and their luggage (M2 and M3)
Member State Testing regime Average age Number of inspections
during average life
Croatia 1 12 12.0
Latvia 1-1-0.5 14 26.0
Belgium 1 11 11.0
Austria 1 5 5.0
Bulgaria 0.5-0.5-0.5 12 24.0
Sweden 1 7 7.0
Luxembourg 1 6 6.0
Ireland 1 11 11.0
Netherlands 1 10 10.0
Portugal 1-1-1… (0.5-0.5 ≥8 years) 15 23.0
Slovenia 1-0.5-0.5 10 19.0
Spain 1-1-1… (0.5-0.5 ≥5 years) 12 20.0
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Member State Testing regime Average age Number of inspections
during average life
Finland 1 12 12.0
Romania 1-0.5-0.5 20 39.0
Cyprus 1 12 12.0
Estonia 1-1-1…(0.5-0.5 ≥10 years) 13 17.0
Germany 1 8 8.0
Lithuania 1-0.5-0.5 14 27.0
Poland 1 16 16.0
Czechia 1 15 15.0
Denmark 1 8 8.0
France 0.5-0.5-0.5 8 16.0
Greece 1 19 19.0
Hungary 1 12 12.0
Italy 1 14 14.0
Malta 1 12 12.0
Slovakia 1-1-1 (0.5-0.5 ≥8 years for M3) 11 15.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 45: Testing regime for trailers designed and constructed for the carriage of goods or persons, as well as for
the accommodation of persons, having a maximum mass not exceeding 3.5 tonnes (O1 and O2) (no values are
shown for MS that have not yet introduce a testing regime)
Member State Testing regime Average age Number of inspections
during average life
Croatia 3-1-1 18 16.0
Latvia 2-2-2 18 9.0
Belgium 1-1-1 18 18.0
Austria 2-1-1 18 17.0
Bulgaria 1-1-1 18 18.0
Sweden 4-2-2 18 8.0
Luxembourg 4-2-2 18 8.0
Ireland
Netherlands
Portugal
Slovenia 4-2-2 18 8.0
Spain 1-1-1 18 18.0
Finland 2-2-2 18 9.0
Romania 2-2-2 18 9.0
Cyprus 4-2-2 18 8.0
Estonia 1-1-1 18 18.0
Germany 2-2-2 18 9.0
Lithuania 3-2-2 18 8.5
Poland 3-2-2 18 8.5
Czechia 4-2-2 18 8.0
Denmark
France
Greece
Hungary 4-2-2 18 8.0
Italy 4-2-2 18 8.0
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Member State Testing regime Average age Number of inspections
during average life
Malta 2-2-2 18 9.0
Slovakia 4-2-2 18 8.0
Source: Ricardo et al. (2024), Impact assessment support study
The projected number of total periodic technical inspections for light duty vehicles, heavy duty
vehicles and motorcycles in the baseline scenario by Member State is provided in the table below.
Table 46: Projected number of total periodic technical inspections for light duty vehicles, heavy duty vehicles and
motorcycles in the baseline scenario
Member State 2015 2026 2030 2040 2050
AT 4,155,271 4,289,162 4,530,504 5,147,602 5,405,069
BE 4,627,640 4,645,244 4,717,772 4,863,174 4,804,878
BG 2,939,951 2,998,948 3,163,260 3,402,701 3,586,559
CY 278,758 318,686 344,851 382,206 418,612
DE 24,143,239 25,306,809 26,146,795 28,373,603 29,042,084
EE 553,898 608,122 646,300 767,699 887,990
FI 2,137,187 2,329,681 2,392,392 2,495,553 2,460,964
FR 17,804,012 18,516,590 18,836,560 20,515,273 21,086,208
EL 3,797,487 3,784,340 3,863,813 3,948,544 4,345,918
HR 1,818,815 1,900,904 2,061,143 2,280,267 2,639,968
HU 1,748,586 2,018,861 2,213,884 2,688,078 2,998,731
IE 975,524 1,123,119 1,207,534 1,361,256 1,476,122
IT 21,787,538 23,125,847 23,515,772 25,687,923 27,671,372
LT 684,749 772,006 800,382 954,701 999,994
LU 230,981 242,455 265,514 330,792 346,504
LV 697,880 688,124 685,111 713,317 788,612
MT 144,079 166,296 179,665 213,693 223,523
NL 5,001,465 5,035,101 5,392,059 6,113,987 6,092,085
PL 21,838,488 24,495,294 25,523,350 26,597,403 27,301,601
PT 3,954,336 4,263,212 4,352,909 4,466,218 4,565,840
RO 3,837,465 5,544,479 5,915,902 6,822,807 7,107,093
SE 4,008,852 4,384,731 4,426,372 4,836,699 5,059,638
SI 704,916 839,788 880,475 851,091 895,080
SK 1,143,786 1,284,672 1,400,369 1,635,656 1,716,079
ES 18,516,367 19,984,375 20,604,857 22,849,906 24,427,719
DK 1,139,841 1,267,055 1,353,595 1,435,067 1,488,357
CZ 2,828,535 3,198,299 3,496,014 4,066,895 4,513,062
EU27 151,499,646 163,132,202 168,917,154 183,802,112 192,349,663
Source: Ricardo et al. (2024), Impact assessment support study
Table 47: Projected number of total periodic technical inspections for the carriage of goods or persons, as well as
for the accommodation of persons, having a maximum mass not exceeding 3.5 tonnes (O1 and O2)
Member State 2026 2030 2040 2050
AT 725,952 769,604 869,556 880,200
BE 241,444 245,555 251,418 244,638
BG 18,653 19,241 19,577 20,488
CY 4,785 5,200 5,758 6,263
DE 3,961,968 4,075,824 4,316,696 4,279,445
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Member State 2026 2030 2040 2050
EE 121,803 127,946 153,685 181,224
FI 564,199 575,727 600,400 579,017
FR
EL
HR 32,120 34,543 39,538 46,621
HU 225,089 246,708 292,630 323,983
IE
IT 129,160 130,008 142,941 153,072
LT 8,166 8,368 9,750 9,871
LU 11,428 12,537 16,081 16,879
LV 30,028 28,943 29,596 33,548
MT 1,258 1,406 1,613 1,630
NL
PL 299,327 309,885 325,458 326,384
PT
RO 218,840 240,811 274,248 281,309
SE 492,039 494,348 541,838 562,309
SI 12,203 12,755 11,999 12,573
SK 126,470 138,824 161,484 165,811
ES 216,501 223,033 252,025 260,511
DK
CZ 206,773 226,256 254,357 275,993
EU27 7,648,208 7,927,521 8,570,650 8,661,771
Source: Ricardo et al. (2024), Impact assessment support study
3. IMPACTS BY POLICY MEASURE ON COSTS AND COSTS SAVINGS
This section explains the inputs used and provides the assessment of the impacts of the policy
measures included in the policy options on costs and costs savings. The synergies between the
measures included in the options are already captured in this section.
3.1. PMC1 - Adapt PTI to electric and hybrid vehicles (safety, environmental performance,
standardised data), including training of inspectors
3.1.1. Adjustment costs for PTI centres
PMC1 will require PTI centres to make certain adjustments to be able to deliver PTI for electric and
hybrid vehicles. The exact nature of the adjustments will depend on the specific requirements for the
PTI and whether this will go beyond visual inspections. A number of stakeholders were in favour of
visual inspections on the basis of a checklist that would not require new equipment. Others suggested
that a specific electronic interface to support such inspection may be needed. One stakeholder (FSD
– the German PTI agency) provided a cost estimate of EUR 500 for additional tools to measure
insulation resistance and equipotential bonding. The number of PTI centres in the EU is estimated at
48,880. Given the current small share of EVs in the fleet and in the PTI tests, it is expected that one
such tool will be sufficient per PTI centre for the initial period (i.e., 2026), with a second one added
in 2030. The one-off adjustment costs are estimated at EUR 24.4 million in 2026 and EUR 24.4
million in 2030. Expressed as present value over 2026-2050, one-off adjustment costs are estimated
at EUR 48.2 million (in 2022 prices) relative to the baseline.
129
Tailored training for inspectors that will deliver such PTI services will also be needed to ensure
correct application of test procedure and, crucially, to maximise their own safety when checking high
voltage components. Stakeholders’ views differed as to whether the necessary training could be part
of periodic training and the qualification examinations, most indicating that specific training would
be needed. On the basis of the input from DEKRA – a PTI service provider – it is assumed that an
additional three-day training per PTI inspector will take place in 2026. With an hourly cost for
technicians and associate professionals (ISCO 3) of EUR 34/hour310
, and assuming 7.3 working hours
per day, a three day training for a total of 128,536 inspectors across EU is estimated at EUR 95.4
million in 2026.
The new PTI tests for EVs will replace emission testing for ICE, that last a few minutes, and it is
assumed that the new test will have a similar duration. Thus, no impact on PTI duration is expected
that could give rise to higher labour costs per PTI.
The total adjustment costs for PTI expected as a result of this measure are summarised in the tables
below. They are the same for all policy options.
Table 48: One-off adjustment costs for the PTI centres due to PMC1 in 2026, 2030, 2040 and 2050 in the policy
options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total one-off adjustment costs 119.8 24.4 0.0 0.0
One-off costs for adapting the PTI 24.4 24.4 0.0 0.0
One-off costs for training 95.4 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 49: One-off adjustment costs for the PTI centres due to PMC1 in the policy options, expressed as present
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total one-off adjustment costs 143.6 143.6 143.6 143.6
One-off costs for adapting the PTI 48.2 48.2 48.2 48.2
One-off costs for training 95.4 95.4 95.4 95.4
Source: Ricardo et al. (2024), Impact assessment support study
Depending on the Member State, the additional costs for the PTI centres may be passed through to
vehicle owners (i.e., citizens and businesses). This will depend on how PTI charges are set by the
Member State: where prices are not regulated, it is likely that PTI centres will seek to recover
investment costs, possibly on a relatively short term. On the other hand, in Member States that
regulate the level of PTI charges, the evolution of those charges will depend on the public contract
agreed with the PTI service provider, potentially subject to renegotiation, or on the price-setting
policy of the authority that is itself responsible for PTI. In these cases, costs may either be borne by
the service provider/authority, or be recovered over a longer period.
3.2. PMC2 - Update PTI and RSI due to new requirements in General Safety Regulation and
checking emission reduction systems (new test items, including checks of software
status/integrity), by reading on-board diagnostics
PMC2 requires to update the PTI and RSI to new requirements in the General Safety Regulation
(including software status/integrity of safety or emission relevant systems during PTI for all vehicles
310
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
130
and at technical roadside inspections of commercial vehicles), using ePTI (electronic PTI: ISO
20730:2021).
3.2.1. Adjustment costs for PTI centres
No significant adjustment costs are expected to implement the updates due to new requirements of
the General Safety Regulation, since ePTI uses the standard vehicle interface (OBD connector)311
and a PTI scan tool is a mandatory equipment of PTI stations since May 2023. Nonetheless, some
stakeholders indicated that there may be a need for software updates with cost estimates ranging from
EUR 100 to EUR 1,000 in case of a standardised solution. Assuming an extra cost for the software
update of EUR 500 per PTI tool and 128,536 PTI tools in the EU, the one-off adjustment costs are
estimated at EUR 64.3 million in 2026.
No additional costs are expected for PTI inspections to perform the software status and integrity
checks and update the safety and emission software. As these can be performed remotely (OTA) and
the additional time taken during a PTI or RSI test is considered negligible, no increase in the costs of
the PTI/RSI tests is assumed. For the PTI tests on vehicles, the tools necessary to perform the software
checks are already available as they may currently be used for OBD checks of the emission and safety
systems (such as anti-lock and electronic braking systems, steering or airbags).
In addition, training of 128,536 PTI inspectors would be needed, covering new test items for GSR
and software status/integrity of safety and/or emission relevant systems. Assuming one extra training
day per inspector, the one-off adjustment costs for training are estimated at EUR 31.8 million in 2026.
The introduction of ePTI will possibly lead to time and cost savings for PTI centres. However, PMC2
is not about the introduction of ePTI, but its use in relation to the new items to be checked as a result
of the General Safety Regulation and would therefore not directly lead to time savings.
The total adjustment costs for PTI centres as a result of PMC2 are summarised in the tables below.
Table 50: One-off adjustment costs for PTI centres due to PMC2 in 2026, 2030, 2040 and 2050 in the policy options
(for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 96.1 0.0 0.0 0.0
One-off costs for updates due to General Safety
Regulation
64.3 0.0 0.0 0.0
One-off costs for training 31.8 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
311
https://www.iso.org/standard/73801.html
131
Table 51: One-off adjustment costs for PTI centres due to PMC2 in the policy options, expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 96.1 96.1 96.1 96.1
One-off costs for updates due to General Safety Regulation 64.3 64.3 64.3 64.3
One-off costs for training 31.8 31.8 31.8 31.8
Source: Ricardo et al. (2024), Impact assessment support study
Depending on the Member State, the additional costs for the PTI centres may be passed through to
vehicle owners (i.e., citizens and businesses). As indicated under PMC1, this will depend on the way
PTI charges are set in the Member State.
3.2.2. Adjustment costs for national public authorities
Adjustment costs are also expected for national public authorities, in relation to equipment and
training that is required for RSI. The requirement for testing of software status/integrity of safety
and/or emission relevant systems at RSI would result in investments in OBD scanning tools. Based
on input from one equipment supplier (Texa) the costs are estimated at EUR 1,000 per tool. One tool
is required per RSI unit, and the number of RSI units total 131 at EU level. Training would also be
required for RSI inspectors on software checks using OBD scanning tool. Two hours of training are
assumed for each of the 393 RSI inspectors across EU27. An hourly cost for technicians and associate
professionals (ISCO 3) of EUR 34/hour312
is used for estimating the costs of training. The total one-
off adjustment costs are estimated at EUR 157,712 in 2026.
The adjustment costs for national public authorities responsible for RSI due to PMC2 are presented
in the tables below.
Table 52: One-off adjustment costs for national public authorities due to PMC2 in 2026, 2030, 2040 and 2050 in
the policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 0.2 0.0 0.0 0.0
One-off adjustment costs 0.2 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 53: One-off adjustment costs for national public authorities due to PMC2 in the policy options relative to
the baseline, expressed as present value over 2026-2050 (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 0.2 0.2 0.2 0.2
One-off adjustment costs 0.2 0.2 0.2 0.2
Source: Ricardo et al. (2024), Impact assessment support study
312
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
132
3.3. PMC3 - Mandatory PN testing of LDVs and HDVs equipped with particle filter, at PTI,
and of HDVs at technical roadside inspections of commercial vehicles
3.3.1. Adjustment costs for PTI centres
The introduction of a PN check as part of PTI, to replace the current exhaust gas opacity test at least313
for vehicles equipped with particle filters, would lead to additional costs for PTI centres that will
need to purchase and maintain the new PN testing equipment and provide additional training for
inspectors.
To introduce a new emission check during PTI requires that PTI centres will be provided with new
devices for the PN counting. For the 36,173 PTI centres in the EU affected by this measure (excluding
Belgium, Germany and the Netherlands, which have already introduced such testing and are thus part
of the baseline), the price per new PN measurement equipment is estimated at EUR 5,000, based on
stakeholders’ feedback. Two devices per PTI inspection centre would be needed. Thus, the one-off
adjustment costs for the purchase of the new equipment are estimated at EUR 361.7 million in 2026.
In addition, recurrent maintenance and calibration costs are assumed at 5% of the capital costs (i.e.,
EUR 250 per PN measurement equipment), based on stakeholders’ feedback314
. Total recurrent
adjustment costs are thus estimated at EUR 18.1 million per year from 2026 onwards. Expressed as
present value over 2026-2050, the total recurrent adjustment costs for the maintenance of new
equipment are estimated at EUR 324.4 million relative to the baseline.
In terms of training, an additional half day of training related to the use of PN testing for 88,776
inspectors (excluding Belgium, Germany and the Netherlands, which have already introduced such
testing and are thus part of the baseline) is assumed to take place in 2026. The one-off adjustment
costs are estimated at EUR 11 million in 2026315
.
No difference is expected in terms of emissions testing time by replacing the opacity test with the
new PN testing. Therefore, no additional labour costs for PTI are expected.
The total adjustment costs for PTI centres due to PMC3 are summarised in the tables below.
Table 54: One-off and recurrent adjustment costs for PTI centres due to PMC3 in 2026, 2030, 2040 and 2050 in
the policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 390.8 18.1 18.1 18.1
One-off costs for new equipment 361.7 0.0 0.0 0.0
Recurrent costs for the maintenance of equipment 18.1 18.1 18.1 18.1
One-off costs for training 11.0 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 55: One-off and recurrent adjustment costs for PTI centres due to PMC3 in the policy options relative to
the baseline, expressed as present value over 2026-2050 (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 697.1 697.1 697.1 697.1
313
Where technically possible (i.e., the measuring equipment allows it), this could be extended to older emission
standards. This possibility is not part of the cost calculations.
314
According to GOCA, the yearly calibration cost of a PN measurement device is EUR 305, while that of a smoke tester,
which it would replace is EUR 157.5. The 5% thus includes maintenance, too.
315
Calculated using an hourly cost for technicians and professionals (ISCO 3) of EUR 34/hour.
133
Difference to the baseline
PO1a PO1b PO2 PO3
One-off costs for new equipment 361.7 361.7 361.7 361.7
Recurrent costs for the maintenance of equipment 324.4 324.4 324.4 324.4
One-off costs for training 11.0 11.0 11.0 11.0
Source: Ricardo et al. (2024), Impact assessment support study
Depending on the Member State, the additional costs for the PTI centres may be passed through to
vehicle owners (i.e., citizens and businesses). As indicated under PMC1, this will depend on the way
PTI charges are set in the Member State.
3.3.2. Adjustment costs to national public authorities
Roadside inspection authorities will incur costs for the purchase of PN testing equipment, to be used
as part of roadside inspections. It is assumed that one PN measurement device is needed per RSI unit,
at a cost of EUR 5,000 each (which is the same cost used for the PN testing). In total, 131 RSI units
would need to purchase PN testing equipment316
. The one-off adjustment costs for measurement
equipment are estimated at EUR 0.7 million in 2026.
Recurrent maintenance and calibration costs are assumed at 5% of the capital cost, or EUR 250 per
PN measurement device, based on stakeholders’ feedback. Total recurrent adjustment costs are thus
estimated at EUR 32,750 per year from 2026 onwards. Expressed as present value over 2026-2050,
the total recurrent adjustment costs for the maintenance of new PN measurement devices are
estimated at EUR 0.6 million relative to the baseline.
An additional half day of training related to the use of PN measurement devices is assumed for the
estimated 393 RSI inspectors across the EU in 2026. The one-off adjustment costs are estimated at
EUR 48,616 in 2026.
The total adjustment costs for national public authorities due to PMC3 are summarised in the tables
below.
Table 56: One-off and recurrent adjustment costs for national public authorities due to PMC3 in 2026, 2030, 2040
and 2050 in the policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 0.74 0.03 0.03 0.03
One-off costs for new equipment 0.66 0.00 0.00 0.00
Recurrent costs for the maintenance of equipment 0.03 0.03 0.03 0.03
One-off costs for training 0.05 0.00 0.00 0.00
Source: Ricardo et al. (2024), Impact assessment support study
Table 57: One-off and recurrent adjustment costs for national public authorities due to PMC3 in the policy options
relative to the baseline, expressed as present value over 2026-2050 (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 1.29 1.29 1.29 1.29
One-off costs for new equipment 0.66 0.66 0.66 0.66
316
Estimation based on approximately 691 thousand of RSIs performed in 2021-2022, an average time per inspection of
30 minutes, and 3 inspectors per RSI unit.
134
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent costs for the maintenance of
equipment
0.59 0.59 0.59 0.59
One-off costs for training 0.05 0.05 0.05 0.05
Source: Ricardo et al. (2024), Impact assessment support study
3.3.3. Cost for vehicle owners (citizens and businesses)
The adjustment costs incurred by testing centres may be passed through to vehicle owners in the form
of higher PTI charges. In Member States where PTI charges are regulated, this may be more gradual
than in those where prices are set by the market.
Owners of faulty LDVs/HDVs vehicles will also face a charge for repairing the non-compliant
vehicle. This is not considered to be regulatory costs but is relevant in terms of the impact on
maintenance costs. Where a vehicle is found to be tampered with, the owner/holder will face a fine
that is supposed to be proportionate and dissuasive, as set by the Member State in which the offence
is detected.
3.4. PMC4 – Mandatory NOx testing of LDV and HDV at PTI, and HDVs at roadside (based
on ongoing work of JRC317)
This policy measure will introduce mandatory NOx emission testing during PTI for LDVs and HDVs
(from Euro 5b and Euro VI respectively) and at RSIs (for HDVs from Euro VI).
3.4.1. Adjustment costs for PTI centres
To introduce a NOx emission check during PTI requires that all PTI stations will be provided with
new devices for the NOx measurement. The cost per NOx measurement equipment is estimated at
EUR 15,000, which is the lower end of the range of estimates provided by stakeholders (between
EUR 15 thousand and 40 thousand). The reason for using the lower bound estimate is the fact that
this estimate is more recent and that experience with PN measurement device has shown a sharp
decrease in prices as demand increased (even after the introduction of such tests in just three Member
States). A similar trend is expected for NOx-measurement devices. Since the PN and NOx
measurement devices will most likely be combined in one piece of equipment in the future, these
numbers may still overestimate the costs. Each of the 48,880 PTI centres in the EU are assumed to
be equipped with two devices. The total one-off adjustment costs are estimated at EUR 1.5 billion in
2026.
Recurrent adjustment costs (i.e., maintenance and calibration costs) are assumed at 5% of the capital
cost. Total recurrent adjustment costs are thus estimated at EUR 73.3 million per year from 2026
onwards. Expressed as present value over 2026-2050, the total recurrent adjustment costs for the
maintenance and calibration of new equipment are estimated at EUR 1.3 billion relative to the
baseline.
In terms of training, an additional half day training related to the use of NOx testing is assumed to
take place for the 128,536 inspectors. The one-off adjustment costs for training are estimated at EUR
15.9 million in 2026318
.
317
https://www.mdpi.com/1996-1073/16/14/5520
318
Calculated using an hourly cost for technicians and associate professionals (ISCO 3) of EUR 34/hour.
135
No additional staff, and corresponding higher PTI cost, is expected as no difference is foreseen in
terms of emissions testing time.
The total adjustment costs for PTI centres expected as a result of this measure are summarised in the
tables below.
Table 58: One-off and recurrent adjustment costs for PTI centres due to PMC4 in 2026, 2030, 2040 and 2050 in
the policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 1,555.6 73.3 73.3 73.3
One-off costs for equipment 1,466.4 0.0 0.0 0.0
Recurrent costs for equipment 73.3 73.3 73.3 73.3
One-off costs for training 15.9 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 59: One-off and recurrent adjustment costs for PTI centres due to PMC4 in the policy options, expressed
as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 2,797.3 2,797.3 2,797.3 2,797.3
One-off costs for equipment 1,466.4 1,466.4 1,466.4 1,466.4
Recurrent costs for equipment 1,315.0 1,315.0 1,315.0 1,315.0
One-off costs for training 15.9 15.9 15.9 15.9
Source: Ricardo et al. (2024), Impact assessment support study
3.4.2. Adjustment costs for national public authorities
Roadside inspection authorities will incur costs for the purchase of NOx measurement equipment to
be used as part of roadside inspections on HDVs.
One NOx measurement device is assumed per RSI unit, at a cost of EUR 15,000 each (which is the
same value used for the NOx measurement equipment used in PTI centres). In total, 131 RSI units
would need to purchase the equipment. Thus, the one-off adjustment costs for the measurement
equipment are estimated at EUR 2 million in 2026.
Recurrent maintenance and calibration costs are assumed at 5% of the capital cost. Total recurrent
adjustment costs are thus estimated at EUR 98,250 per year from 2026 onwards relative to the
baseline. Expressed as present value over 2026-2050, they are estimated at EUR 1.8 million relative
to the baseline.
An additional half day of training related to the use of NOx testing is assumed for the 393 RSI
inspectors. The one-off adjustment costs for training are estimated at EUR 48,616 in 2026.
The total costs for national public authorities expected as a result of this measure are summarised in
the tables below.
Table 60: One-off and recurrent adjustment costs for national public authorities due to PMC4 in 2026, 2030, 2040
and 2050 in the policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 2.11 0.10 0.10 0.10
One-off costs for equipment 1.97 0.00 0.00 0.00
Recurrent costs for equipment 0.10 0.10 0.10 0.10
One-off costs for training 0.05 0.00 0.00 0.00
Source: Ricardo et al. (2024), Impact assessment support study
136
Table 61: One-off and recurrent adjustment costs for national public authorities due to PMC4 in the policy
options, expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 3.78 3.78 3.78 3.78
One-off costs for equipment 1.97 1.97 1.97 1.97
Recurrent costs for equipment 1.76 1.76 1.76 1.76
One-off costs for training 0.05 0.05 0.05 0.05
Source: Ricardo et al. (2024), Impact assessment support study
3.4.3. Cost for vehicle owners (citizens and businesses)
The adjustment costs incurred by testing centres may eventually be passed through to vehicle owners
in the form of higher PTI charges. As in the previous cases, this will change from Member State to
Member State.
Owners of faulty vehicles will face a charge for repairing the non-compliant vehicle. However, this
is not considered to be regulatory costs but is relevant in terms of the impact on maintenance costs.
3.5. PMC5 - Mandatory roadworthiness testing following significant modifications of the
vehicle (e.g. change of class, propulsion system)
3.5.1. Administrative costs for citizens (vehicle owners)
PMC5 would result in additional costs for some vehicle owners by introducing mandatory testing of
all vehicles that have undergone significant modifications. The average cost of a PTI for citizens is
estimated at EUR 39.1 per vehicle (i.e., calculated as the weighted average of the median by Member
State for M1 and L vehicle types). PTI cost data has been collected from CITA General Questionnaire
2020-21319
, and national online information sources.
Feedback from stakeholders indicated that in Spain and Germany the total number of modified
vehicles was around 245,000 and 200,000, respectively, in 2022. This represents an annual average
of 0.6% of the total fleet. However, many stakeholders highlighted that PTI following a modification
is already a requirement in their Member State320
. Therefore, the share of 0.6% is applied only to the
vehicle fleet from countries where this is not already implemented in the baseline. In addition, it has
been assumed that 40% of the cars registrations (M1 vehicle category) and 100% of motorcycles
registrations (L vehicle category) are undertaken by citizens. The number of vehicles affected is
estimated at 0.44 million in 2026, 0.45 million in 2030 and 0.53 million in 2050. The recurrent
administrative costs, based on the number of vehicles affected and the cost per PTI, are estimated at
EUR 17.1 million in 2026, EUR 17.7 million in 2030 and EUR 20.6 million in 2050. Expressed as
present value over 2026-2050, they are estimated at EUR 336.3 million relative to the baseline.
The total administrative costs for citizens due to PMC5 are summarised in the tables below.
Table 62: Number of vehicle affected and recurrent administrative costs for citizens due to PMC5 in 2026, 2030,
2040 and 2050 in the policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Number of vehicles affected (million) 0.44 0.45 0.50 0.53
319
https://citainsp.org/2021/06/28/cita-general-questionnaire-2020-21/
320
EU Member States where stakeholders identified PTI following modification as an existing requirement are: Croatia,
Finland, Austria, Netherlands, Germany, Sweden and Spain. This requirement is also in place for Iceland.
137
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative cost 17.1 17.7 19.4 20.6
Source: Ricardo et al. (2024), Impact assessment support study
Table 63: Recurrent administrative costs for citizens due to PMC5 in the policy options, expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative cost 336.3 336.3 336.3 336.3
Source: Ricardo et al. (2024), Impact assessment support study
3.5.2. Administrative costs for businesses (vehicle owners)
As explained above, PMC5 would result in additional costs for some vehicle owners by introducing
mandatory testing of all vehicles that have undergone significant modifications. The average cost of
a PTI for businesses is estimated at EUR 42.1 per vehicle (i.e., calculated as the weighted average of
the median by Member State for M1, N1, N2/N3 and M2/M3 vehicle types). PTI cost data has been
collected from CITA General Questionnaire 2020-21, and national online information sources.
Feedback from stakeholders indicated that in Spain and Germany the total number of modified
vehicles was around 245,000 and 200,000, respectively, in 2022. This represents an annual average
of 0.6% of the total fleet. However, many stakeholders highlighted that PTI following a modification
is already a requirement in their Member State321
. Therefore, the share of 0.6% is applied only to the
vehicle fleet from countries where this is not already implemented in the baseline. In addition, it has
been assumed that 60% of the cars registrations (M1 vehicle category) and 100% of vans, lorries and
buses registrations (N1, N2/N3 and M2/M3 vehicle category) are undertaken by businesses. The
number of vehicles affected is estimated at 0.64 million in 2026, 0.66 million in 2030 and 0.75 million
in 2050. The recurrent administrative costs, based on the number of vehicles affected and the cost
per PTI, are estimated at EUR 27 million in 2026, EUR 27.8 million in 2030 and EUR 31.6 million
in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 524.2 million relative
to the baseline.
The total administrative costs for businesses due to PMC5 are summarised in the tables below.
Table 64: Number of vehicle affected and recurrent administrative costs for businesses due to PMC5 in 2026, 2030,
2040 and 2050 in the policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Number of vehicles affected (million) 0.64 0.66 0.72 0.75
Recurrent administrative cost 27.0 27.8 30.2 31.6
Source: Ricardo et al. (2024), Impact assessment support study
Table 65: Recurrent administrative costs for businesses due to PMC5 in the policy options, expressed as present
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative cost 524.2 524.2 524.2 524.2
Source: Ricardo et al. (2024), Impact assessment support study
321
EU Member States where stakeholders identified PTI following modification as an existing requirement are Croatia,
Finland, Austria, Netherlands, Germany, Sweden and Spain. This requirement is also in place for Iceland.
138
3.5.3. Benefits for PTI centres
PMC5 would result in benefits for the PTI centres due to the mandatory testing of all vehicles that
have undergone significant modifications. The costs for vehicle owners (citizens and businesses)
discussed above represent revenues for the PTI centres. The total revenues for PTI centres due to
PMC5 are thus estimated at EUR 44.1 million in 2026, EUR 45.5 million in 2030 and EUR 52.3
million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 860.5 million
relative to the baseline.
Table 66: Benefits for PTI centres due to PMC5 in 2026, 2030, 2040 and 2050 in the policy options (for all options)
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Revenues for PTI centres 44.1 45.5 49.6 52.3
Source: Ricardo et al. (2024), Impact assessment support study
Table 67: Benefits for PTI centres due to PMC5 in the policy options, expressed as present value over 2026-2050
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Revenues for PTI centres 860.5 860.5 860.5 860.5
Source: Ricardo et al. (2024), Impact assessment support study
3.6. PMC6 - Require the roadworthiness certificate in electronic format only
3.6.1. Administrative costs for national public authorities
PMC6 requires that the roadworthiness certificate be issued in electronic format only. According to
national experts from Member States such as Finland, Croatia and Slovenia the measure would entail
some software development. Developing the software for electronic certificates is estimated in the
range of EUR 500 thousand to EUR 1 million. Assuming one-off costs of EUR 500,000 per IT system
for each of the 15 Member States with smaller volumes of inspections322
, EUR 750,000 per IT system
for each of the 7 Member States with medium volumes of inspections323
and EUR 1,000,000 per IT
system for each of the 5 Member States with higher volumes of inspections324
, the total one-off
administrative costs at EU27 level are estimated at EUR 17.8 million in 2026.
Recurrent administrative costs for the maintenance and update of the system for electronic certificates
are assumed at 5% of the investment costs, based on stakeholders’ feedback. They are estimated at
EUR 887,500 from 2026 onwards. Expressed as present value over 2026-2050, the recurrent
administrative costs for national public administrations are estimated at EUR 15.9 million relative to
the baseline.
3.6.2. Administrative costs savings for national public authorities
In the baseline, the cost of a paper RW certificate is estimated at 1 EUR per certificate, covering the
cost of printing and the time spent to print the document. Around 2% of the total RW certificates are
issued in a digital format in the baseline, in two Member States (Finland and Estonia). The number
322
Below 2% of the total number of inspections at EU level in 2026 by Member State. These are: BG, CY, EE, FI, HR,
HU, IE, LT, LV, LU, MT, SI, SK, DK and CZ.
323
Between 2% and 10% of the total number of inspections at EU level in 2026 by Member State. These are: AT, BE,
EL, NL, PT, RO and SE.
324
Above 10% of the total number of inspections at EU level in 2026 by Member State. These are: DE, FR, IT, PL and
ES.
139
of RW certificates issued in paper format in the baseline is estimated at 161.5 million in 2026, 167.3
million in 2030 and 190.6 million in 2050. Thus, the administrative costs saving due to issuing the
RW certificates in electronic format only are estimated at EUR 161.5 million in 2026, EUR 167.3
million in 2030 and EUR 190.6 million in 2050. Expressed as present value over 2026-2050, the
recurrent administrative costs savings for national public administrations are estimated at EUR 3.2
billion relative to the baseline.
Table 68: Costs and costs savings for national public authorities due to PMC6 in 2026, 2030, 2040 and 2050 in the
policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 18.6 0.9 0.9 0.9
One-off administrative costs 17.8 0.0 0.0 0.0
Recurrent administrative costs 0.9 0.9 0.9 0.9
Total administrative costs savings 161.5 167.3 182.0 190.6
Recurrent administrative costs savings 161.5 167.3 182.0 190.6
Source: Ricardo et al. (2024), Impact assessment support study
Table 69: Costs and costs savings for national public authorities due to PMC6 in the policy options, expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 33.7 33.7 33.7 33.7
One-off administrative costs 17.8 17.8 17.8 17.8
Recurrent administrative costs 15.9 15.9 15.9 15.9
Total administrative costs savings 3,155.0 3,155.0 3,155.0 3,155.0
Recurrent administrative costs savings 3,155.0 3,155.0 3,155.0 3,155.0
Source: Ricardo et al. (2024), Impact assessment support study
3.7. PMC7 - Provide electronic access to relevant data, including on PTI reports stored in
national databases, to the registration authorities of other EU Member States using a
common interface
3.7.1. Administrative costs for national public authorities
The measure under consideration entails costs for providing access to relevant data. All Member
States already store the PTI information in their national vehicle register. The associated costs are
however expected to be lower when existing systems (such as EUCARIS, ERRU or the MOVE-Hub)
are used by all Member States. Most of the enforcement authorities are already connected to their
local vehicle registration authority and could simply add this to the existing data exchange. Member
States are free to use a EUCARIS offering or build their own solution to satisfy any legal obligations
for data exchange. The costs and hence decisions will vary between Member States depending on the
organisation of their national public authorities. If the national public authority that manages the road
transport undertakings register (i.e., the connection to ERRU) also manages the PTI data then they
can extend the solution they already have in place. If those two databases are in different national
public authorities, it changes the decisions and the costs.
According to EReg’s survey responses, requiring Member States to use an IT system for registration
procedures that they are already using for other purposes would save costs compared to putting in
place a new central hub. Either the EUCARIS peer-to-peer exchange system, or the hub-and-spoke
system of MOVE-Hub could be adapted to the needs of PMC7, limiting the additional costs of
140
implementing the measure and ensuring an effective exchange data mechanism. According to EReg,
the creation of a central hub should not prevent the use of EUCARIS325
.
For the implementation of this measure, one-off administrative costs are expected for developing
common interfaces for accessing the data. The one-off administrative costs for the interconnection
of national registers are estimated at around EUR 300,000 per Member State in 2026. Thus, the total
one-off administrative costs are estimated at EUR 8.1 million for the 27 EU Member States in 2026.
The recurrent administrative costs (i.e., service supply costs) for providing access to the relevant data
are estimated at around 5% of the capital costs. They amount to EUR 405,000 per year from 2026
onwards. Expressed as present value over 2026-2050, recurrent administrative costs are estimated at
EUR 7.3 million.
3.7.2. Administrative costs savings for national public authorities
According to EUCARIS, if all countries would exchange their registration data in a structured way
via a common IT system, the number of situations when registration authorities would need to contact
each other via different, less secure ways (e.g. e-mail) to get the data, would decrease significantly.
PMC7 is expected to lead to time savings of around 15 minutes per re-registration of a vehicle in
another Member State because of less need of reaching out to other National Contact Points by
phone/mail. Considering the 3.5 million re-registrations per year in the EU326
, and the average labour
cost for ISCO 2 (professionals) of 40.9 EUR/hour327
, the administrative costs savings for national
public authorities are estimated at EUR 35.8 million per year, or EUR 641.8 million expressed as
present value over the 2026-2050 period relative to the baseline.
Table 70: Costs and costs savings for national public authorities due to PMC7 in 2026, 2030, 2040 and 2050 in the
policy options (for all options) relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 8.5 0.4 0.4 0.4
One-off administrative costs 8.1 0.0 0.0 0.0
Recurrent administrative costs 0.4 0.4 0.4 0.4
Total administrative costs savings 35.8 35.8 35.8 35.8
Recurrent administrative costs savings 35.8 35.8 35.8 35.8
Source: Ricardo et al. (2024), Impact assessment support study
Table 71: Costs and costs savings for national public authorities due to PMC7 in the policy options, expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 15.4 15.4 15.4 15.4
One-off administrative costs 8.1 8.1 8.1 8.1
Recurrent administrative costs 7.3 7.3 7.3 7.3
Total administrative costs savings 641.8 641.8 641.8 641.8
Recurrent administrative costs savings 641.8 641.8 641.8 641.8
Source: Ricardo et al. (2024), Impact assessment support study
325
As reported in the evaluation report, the use of EUCARIS does not currently represent a significant cost for Member
States.
326
Source: https://ggiforum.com/consulting/immigration-executive/127-cross-border-car-registration-within-the-eu-to-
be-simplified.html
327
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
141
3.8. PMC8 - Harmonisation and regular update of the technical data in the vehicle
registration documents (currently optional content)
3.8.1. Administrative costs for national public authorities
PMC8 will harmonise and clarify (where necessary) the contents related to the technical data of the
vehicle to be provided in the registration document, as indicated in annexes I and II of the Directive
1999/37, and requires regular update.
The measure would likely result in additional administrative costs for Member State authorities for
the harmonisation across MS, redesigning and setting up the new template for the registration
documents. This is accompanied by a continuous review and update of the documents, with the
addition of new items that may be needed in the future. Stakeholders provided a range of estimates
for the one-off costs for harmonisation, from no cost to up to EUR 80,000, with an average of EUR
26,667 per Member State. This range reflects the different views of Member States concerning the
need to transition to digital registration documents or the retention of physical documents (this
decision is not part of the policy measure and is left to the choice of each MS). The total one-off
administrative costs for the harmonisation of technical data in the vehicle registration documents are
estimated at EUR 720,000 in 2026 for the 27 EU Member States relative to the baseline.
In addition, recurrent administrative costs are expected for the regular update of the vehicle
registration documents with new items that may be found relevant in the future. Recurrent labour
cost of 40.9 EUR/hour for ISCO 2 (professionals)328
, working for this specific function an average
of 2 hours per day along the 220 working days of a regular year, are assumed. The total recurrent
administrative costs for updating the technical data in vehicle registers is estimated at EUR 485,849
per year from 2026 onwards for all the EU countries. Expressed as present value over 2026-2050, the
total recurrent administrative costs are estimated at EUR 8.7 million relative to the baseline (in 2022
prices).
The total administrative costs for national public authorities expected as a result of this measure are
summarised in the tables below.
Table 72: One-off and recurrent administrative costs for national public authorities due to PMC8 in the policy
options (all options), in 2026, 2030, 2040 and 2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 1.2 0.5 0.5 0.5
One-off costs to support the harmonisation of vehicle
registration documents
0.7 0.0 0.0 0.0
Recurrent costs for regular updates of the vehicle
registration documents
0.5 0.5 0.5 0.5
Source: Ricardo et al. (2024), Impact assessment support study
Table 73: One-off and recurrent administrative costs for national public authorities due to PMC8 in the policy
options, expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 9.4 9.4 9.4 9.4
One-off costs to support the harmonisation of vehicle
registration documents
0.7 0.7 0.7 0.7
328
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
142
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent costs for regular updates of the vehicle
registration documents
8.7 8.7 8.7 8.7
Source: Ricardo et al. (2024), Impact assessment support study
3.8.2. Administrative cost savings for national public authorities and citizens
Harmonisation of vehicle registration documents could potentially reduce administrative costs related
to cross-border vehicle registration and compliance, benefiting both national public authorities and
citizens. However, these cost savings cannot be quantified with available data.
3.9. PMC9 – MSs to record odometer readings in a national database and make the records
available to other MSs in the case of re-registration
PMC9 requires Member States to record odometer readings in a national database and make the
records available to other MSs in the case of re-registration. Odometer readings for cars and vans
(M1, N1) will need to be provided by garages, tyre and other repair service, in addition to PTI bodies,
following every visit. OEMs will be required to provide odometer readings from connected vehicles.
PMC9 is intended to replicate across the EU the approach already followed in the Netherlands and
Belgium. However, in comparison to the Belgian Car-Pass system PMC9 does not require the issuing
of a certificate as part of a vehicle transaction. This currently costs around EUR 10 in Belgium and
provides the main source of revenue to support the operation of the system in the country. In the
Dutch National Auto Pas system, the delivery of the vehicle report is free of charge.
There is no requirement for the development of an EU wide dataset in PMC9 but Member States will
need to share information on vehicle odometer readings from their respective national datasets when
a cross-border sale of a vehicle takes place.
The one-off and recurrent costs for the operation of a similar system established in each Member
State are estimated based on input from the Belgian Car-Pass and a 2018 European Parliament
study329
. PMC9 is expected to lead to costs for national public authorities for establishing and
operating the system (including a relevant database with odometer readings covering all registered
vehicles), for taking action when issues are identified, and for sharing data with other Member States
when they receive requests. In addition, the measure is expected to lead to costs for garages/tyre and
repair services for submitting the odometer readings (PTI centres already do so). No additional costs
relative to the baseline are expected for OEMs due to this measure.
3.9.1. Administrative costs for national public authorities
The initial cost to set up the database with the odometer readings and the overall system of monitoring
was around EUR 1.5 million in 2006 for Car-Pass330
. However, it is expected that this cost is lower
today, given the decrease in the costs of IT solutions in the recent past. For the assessment of PMC9,
the one-off administrative costs are assumed at EUR 1 million for each of the 25 Member States
concerned (i.e., excluding Belgium and the Netherlands which introduced the system already and are
329
European Parliament (2018), Odometer Manipulation in motor vehicles in Europe,
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
330
Based on an interview with Car-Pass.
143
part of the baseline). Thus, the total one-off administrative costs are estimated at EUR 25 million in
2026 relative to the baseline.
Based on the 2018 European Parliament study331
, the cost for operating the system is estimated at
EUR 0.42 per vehicle (expressed in 2022 prices)332
. The number of M1 and N1 vehicles relevant for
PMC9 are projected at 254.7 million in 2026, 262.4 million in 2030 and 295.8 million in 2050. The
recurrent administrative costs are estimated at EUR 108.1 million in 2026, EUR 111.4 million in
2030 and EUR 125.6 million in 2050. Expressed as present value over 2026-2050, they are estimated
at EUR 2.1 billion.
Table 74: Administrative costs for national public administrations due to PMC9 in 2026, 2030, 2040 and 2050 in
all policy options relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Number of vehicles relevant for PMC9 (thousand),
of which:
254,666 262,373 285,115 295,817
M1 vehicles 224,997 231,563 251,316 259,000
N1 vehicles 29,669 30,811 33,798 36,817
Total administrative costs (in million EUR) 133.1 111.4 121.0 125.6
One-off costs to set up the system 25.0 0.0 0.0 0.0
Recurrent costs for operating the system 108.1 111.4 121.0 125.6
Source: Ricardo et al. (2024), Impact assessment support study
Table 75: Administrative costs for national public administrations due to PMC9 in PO1a, PO1b, PO2 and PO3,
expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 2,122.1 2,122.1 2,122.1 2,122.1
One-off costs to set up the system 25.0 25.0 25.0 25.0
Recurrent costs for operating the system 2,097.1 2,097.1 2,097.1 2,097.1
Source: Ricardo et al. (2024), Impact assessment support study
3.9.2. Administrative costs for garages, motor vehicle dealers, tyre and repair stations, etc.
The costs for the garages, motor vehicle dealers, tyre and repair stations, etc. will relate to possible
software updates to allow them to transfer their data to the central national database and the time
needed to record the odometer readings. Based on input from Car-Pass system manager and the
European Parliament study333
, the costs for software updates are estimated at EUR 229 per garage in
2022 prices334
. In PMC9 these costs are relevant for 651,351 companies (470,765 repair shops and
garages across the EU335
and 180,586 motor vehicle dealers336
), excluding those in Belgium and the
331
European Parliament (2018), Odometer Manipulation in motor vehicles in Europe,
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
332
The cost estimate from the 2018 European Parliament study is EUR 0.37 per vehicle in 2018 prices. Using the
harmonised index of consumer prices (HICP) from Eurostat, this is equivalent to EUR 0.42 per vehicle in 2022 prices.
333
European Parliament (2018), Odometer Manipulation in motor vehicles in Europe,
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
334
The cost was estimated at EUR 200 per garage in 2018 prices. Using the harmonised index of consumer prices (HICP)
from Eurostat, this is equivalent to EUR 229 per garage in 2022 prices.
335
Eurostat, Structural business statistics, Enterprise statistics by size class and NACE Rev.2 activity (from 2021
onwards) [SBS_SC_OVW], Maintenance and repair of motor vehicles. Estimates for Ireland are based on 2020 data.
336
Eurostat, Structural business statistics, Enterprise statistics by size class and NACE Rev.2 activity (from 2021
onwards) [SBS_SC_OVW], Sale of cars and light motor vehicles. Estimates for Ireland are based on 2020 data.
144
Netherlands, which implemented the measure already and are part of the baseline. Total one-off
administrative costs are thus estimated at EUR 149.2 million in 2026.
The maintenance costs for the software are estimated at 10% of the one-off costs, or EUR 1.4 million
per year from 2026 onwards. In addition, in order to calculate the costs related to the time needed to
record the odometer readings, the European Parliament study assumed that 90% of the readings from
garages will be done automatically via the IT system and only 10% of them will be encoded manually
through a dedicated portal. Manual encoding is expected to take half a minute. Assuming an average
cost per hour for technicians and associate professionals (ISCO level 3) of EUR 34, manual encoding
is estimated at EUR 0.28 per encoding. In addition to the odometer readings during PTI, it is
estimated that 1.5 readings per vehicle would take place per year. Furthermore, the share of connected
vehicles is projected to increase over time from around 10% currently337
to 20% in 2026, 60% in
2030 and 100% by 2040. No manual encoding is needed for the connected vehicles. Based on these
assumptions and the projected M1 and N1 vehicles fleet size in the affected MS, the recurrent
administrative costs for garages, motor vehicle dealers, tyre and repair stations are estimated at EUR
23.6 million in 2026, EUR 19.4 million in 2030 and EUR 14.9 million in 2050. Expressed as present
value over 2026-2050, they are estimated at EUR 310.8 million relative to the baseline.
For the purpose of the ‘one in one out approach’, the average annual recurrent administrative costs
over 2026-2035 are estimated at EUR 19.5 million per year338
. Considering the 651,351 companies
relevant for PMC9, the average annual cost per company is estimated at EUR 29.9. In addition, as
explained above, the one-off administrative costs are estimated at EUR 149.2 million in 2026.
Table 76: Administrative costs for garages, motor vehicle dealers, tyre and repair stations due to PMC9 in 2026,
2030, 2040 and 2050 in all policy options relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 172.7 19.4 14.9 14.9
One-off costs for updating the software 149.2 0.0 0.0 0.0
Recurrent costs for operating the system 23.6 19.4 14.9 14.9
Source: Ricardo et al. (2024), Impact assessment support study
Table 77: Administrative costs for garages, motor vehicle dealers, tyre and repair stations due to PMC9 in PO1a,
PO1b, PO2 and PO3, expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022
prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 460.0 460.0 460.0 460.0
One-off costs for updating the software 149.2 149.2 149.2 149.2
Recurrent costs for operating the system 310.8 310.8 310.8 310.8
Source: Ricardo et al. (2024), Impact assessment support study
3.9.3. Reduction of odometer fraud and cost savings for citizens and businesses (vehicle owners)
PMC9 directly targets odometer tampering by aiming to replicate the key elements of the Car-Pass
system adopted in Belgium since 2006 and more recently in the Netherlands.
The requirement for mandatory recording and reporting to a national central database of vehicle
mileage, whenever a vehicle undergoes repair/maintenance or in the case of tyre
changes/replacement339
, allows to create a long record of a vehicle’s mileage since its first time of
337
https://www.car-pass.be/en/news/car-pass-annual-report-2022
338
This is calculated as a simple average over 2026-2035, non discounted.
339
This is in addition to the time of the PTI, which is part of the baseline.
145
registration. This allows to easily identify any tampering with the odometer. For example, the Car-
Pass system led within a year340
to a very significant drop in the level of odometer fraud in the case
of second-hand vehicles registered in Belgium, from 13% to no more than 2%341
. Similar
effectiveness levels have been reported for the Dutch system, that shares many common elements
with the Car-Pass system (albeit with no requirement for the issuing of a certificate). However, as
explained by the manager of the Car-Pass system during the stakeholders’ consultation, there are still
important limitations when it comes to cross-border vehicle sales since access to mileage records
from other countries is often limited or not available at all. Implementing the system across the EU
is thus expected to help reduce odometer fraud in the Member States where such a system is not
currently in place, both in terms of domestic sales of used vehicles, as well as in terms of cross-border
sales where odometer tampering has been found to be more common.
The total volume of second hand vehicle sales (M1 and N1 vehicles) by citizens and businesses in
the 25 Member States affected by PMC9 (excluding Belgium and the Netherlands, which have
already implemented the system) is projected at around 62.3 million in 2026, 65.5 million in 2030
and 71 million in 2050342
of which second hand cross border sales are estimated at 28.1 million in
2026, 29.5 million in 2030 and 31.7 million in 2050343
. The average share of odometer tampering in
national second-hand car sales is estimated at 4.8%344
and in cross border second hand car sales at
11.3%345
, and they are assumed to remain constant over time in the baseline scenario. Thus, the
number of national second-hand vehicle sales with mileage fraud is projected at 1.63 million in 2026,
1.71 million in 2030 and 1.90 million in 2050 in the baseline scenario, and that of cross border vehicle
sales with mileage fraud at 3.18 million in 2026, 3.35 million in 2030 and 3.64 million in 2050.
For assessing the benefits of PMC9 for citizens and businesses, the reduction in the level of odometer
fraud is assumed at 97% for domestic sales of second-hand vehicles, based on the experience with
Car-Pass346
, and at 90% for the cross-border vehicle sales. If frequent odometer recording is
implemented, and odometer history data is exchanged between Member States before re-registration,
it is reasonable to assume that odometer fraud can be reduced at a similar level as in Belgium and the
Netherlands. Furthermore, the rapid deployment of connected cars can be expected to significantly
support the effectiveness of the measure.
The national mileage fraud avoidance in terms of number of vehicles is estimated at 1.58 million in
2026, 1.66 million in 2030 and 1.84 million in 2050 while the cross-border mileage fraud avoidance
at 2.87 million in 2026, 3.01 million in 2030 and 3.28 million 2050. The average cost of mileage
fraud, due to higher purchase price and maintenance costs incurred, is estimated at EUR 2,119 per
vehicle in 2022 prices as explained in detail in section 2 of Annex 4. The total costs savings for
citizens and businesses are estimated at EUR 9.4 billion in 2026, EUR 9.9 billion in 2030 and EUR
340
EPRS_STU(2018)615637_EN.pdf (europa.eu)
341
The introduction of the system was supported by an extensive information campaign.
342
Projections of second hand vehicle sales are derived based on projections for new car sales from the PRIMES-
TREMOVE baseline and available data on the ratio of second hand car to new car sales for selected countries from:
https://www.bain.com/insights/the-outlook-for-the-european-used-car-market-brief/ and https://www.regitra.lt/lt/atviri-
duomenys/?datayear=2017&dataquery=. The ratio of second hand car to new car sales is assumed to remain constant
over time. For MS without relevant data, a ratio of second hand to new car sales of 4 has been assumed for EU12
countries and 3.5 for EU15 countries.
343
Projections for the second-hand cross border sales are developed based on data from
https://www.carvertical.com/gb/transparency-index/metrics with some data gaps filled using the median value.
344
Source: https://www.carvertical.com/blog/research-what-countries-have-the-highest-percentage-of-cars-with-a-fake-
mileage
345
Source:
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf
346
EPRS_STU(2018)615637_EN.pdf (europa.eu)
146
10.8 billion in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 184
billion.
Table 78: Costs savings for citizens and businesses due to PMC9 in 2026, 2030, 2040 and 2050 in all policy options
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Volume of second hand national sales in
the affected MS (million vehicles)
34.17 35.92 39.90 39.33
Volume of second hand cross border
sales in the affected MS (million
vehicles)
28.10 29.54 31.39 31.70
National second hand sales with mileage
fraud (million vehicles)
1.63 1.71 1.90 1.90
Cross border sales with mileage fraud
(million vehicles)
3.18 3.35 3.59 3.64
National mileage fraud avoidance
(million vehicles)
1.58 1.66 1.85 1.84
Cross border mileage fraud avoidance
(million vehicles)
2.87 3.01 3.23 3.28
Costs savings from fraud avoidance
(EUR million), of which:
9,423.8 9,907.1 10,751.7 10,847.6
National 3,350.8 3,522.6 3,913.0 3,899.1
Cross border 6,073.0 6,384.5 6,838.7 6,948.4
Source: Ricardo et al. (2024), Impact assessment support study
Table 79: Costs savings for citizens and businesses due to PMC9 in PO1a, PO1b, PO2 and PO3, expressed as
present value over 2026-2050 relative to the baseline (in billion EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Consumer savings from fraud
avoidance, of which:
184.0 184.0 184.0 184.0
National 65.9 65.9 65.9 65.9
Cross border 118.1 118.1 118.1 118.1
Source: Ricardo et al. (2024), Impact assessment support study
As shown in the table below, these cost savings are expected to be more significant for citizens and
businesses in Central and Eastern European countries where the level of odometer fraud has been
found to be higher in general and where cross-border sales of second-hand vehicles are higher than
average.
Table 80: Estimated fraud avoidance and costs savings for citizens and businesses due to PMC9 in 2030 in all
policy options relative to the baseline
National and cross border
mileage fraud avoidance
(thousand vehicles)
Share of national and cross
border mileage fraud
avoidance in the total second
hand vehicles sales (%)
Savings for citizens and
businesses from fraud
avoidance (million EUR, in
2022 prices)
AT 145,990 8% 309.4
BG 90,667 8% 192.2
CY 24,238 10% 51.4
CZ 148,959 9% 315.7
DE 477,055 4% 1,011.1
DK 52,426 5% 111.1
EE 43,122 15% 91.4
EL 149,818 8% 317.5
ES 381,502 7% 808.6
FI 55,609 5% 117.9
147
National and cross border
mileage fraud avoidance
(thousand vehicles)
Share of national and cross
border mileage fraud
avoidance in the total second
hand vehicles sales (%)
Savings for citizens and
businesses from fraud
avoidance (million EUR, in
2022 prices)
FR 733,433 6% 1,554.5
HR 48,286 8% 102.3
HU 201,515 11% 427.1
IE 62,778 8% 133.1
IT 753,224 7% 1,596.4
LT 161,193 15% 341.6
LU 30,226 12% 64.1
LV 30,430 19% 64.5
MT 11,455 8% 24.3
PL 395,864 9% 839.0
PT 59,152 3% 125.4
RO 325,840 13% 690.6
SE 199,491 10% 422.8
SI 24,382 6% 51.7
SK 67,736 6% 143.6
EU level 4,675,346 7% 9,907.1
Source: Ricardo et al. (2024), Impact assessment support study
To allocate the benefits due to the reduction of odometer fraud between citizens and businesses, the
second hand M1 vehicle sales have been split between citizens and businesses using the share of new
vehicle registered by citizens (i.e., 40%). For N1 vehicles it has been assumed that all benefits accrue
to businesses. The tables below provide the split of the benefits between citizens and businesses at
EU level.
Table 81: Costs savings for citizens due to PMC9 in 2026, 2030, 2040 and 2050 in all policy options relative to the
baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Volume of second hand national sales in
the affected MS (million vehicles)
12.24 12.87 14.37 14.06
Volume of second hand cross border
sales in the affected MS (million
vehicles)
10.00 10.51 11.11 11.15
National second hand sales with mileage
fraud (million vehicles)
0.59 0.62 0.69 0.68
Cross border sales with mileage fraud
(million vehicles)
1.14 1.20 1.27 1.29
National mileage fraud avoidance
(million vehicles)
0.57 0.60 0.67 0.66
Cross border mileage fraud avoidance
(million vehicles)
1.03 1.08 1.15 1.16
Costs savings from fraud avoidance
(EUR million), of which:
3,380.8 3,554.2 3,841.0 3,856.7
National 1,204.2 1,265.9 1,411.1 1,398.4
Cross border 2,176.7 2,288.3 2,429.9 2,458.3
Source: Ricardo et al. (2024), Impact assessment support study
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Table 82: Costs savings for citizens due to PMC9 in PO1a, PO1b, PO2 and PO3, expressed as present value over
2026-2050 relative to the baseline (in billion EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Consumer savings from fraud avoidance,
of which:
65.7 65.7 65.7 65.7
National 23.7 23.7 23.7 23.7
Cross border 42.0 42.0 42.0 42.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 83: Costs savings for businesses due to PMC9 in 2026, 2030, 2040 and 2050 in all policy options relative to
the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Volume of second hand national sales in
the affected MS (million vehicles)
21.92 23.05 25.54 25.26
Volume of second hand cross border
sales in the affected MS (million
vehicles)
18.10 19.03 20.28 20.56
National second hand sales with mileage
fraud (million vehicles)
1.04 1.10 1.22 1.22
Cross border sales with mileage fraud
(million vehicles)
2.04 2.15 2.31 2.35
National mileage fraud avoidance
(million vehicles)
1.01 1.07 1.18 1.18
Cross border mileage fraud avoidance
(million vehicles)
1.84 1.93 2.08 2.12
Costs savings from fraud avoidance
(EUR million), of which:
6,043.0 6,352.9 6,910.6 6,990.9
National 2,146.6 2,256.7 2,501.8 2,500.7
Cross border 3,896.4 4,096.2 4,408.8 4,490.1
Source: Ricardo et al. (2024), Impact assessment support study
Table 84: Costs savings for businesses due to PMC9 in PO1a, PO1b, PO2 and PO3, expressed as present value
over 2026-2050 relative to the baseline (in billion EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Consumer savings from fraud avoidance,
of which:
118.3 118.3 118.3 118.3
National 42.2 42.2 42.2 42.2
Cross border 76.1 76.1 76.1 76.1
Source: Ricardo et al. (2024), Impact assessment support study
3.10. PM1 - RSI for heavy/powerful motorcycles (L category > 125cm3) as alternative measure,
in Member States where they are not subject to PTI (i.e., using available opt-out)
3.10.1. Administrative costs for national public authorities
PM1 will require that those Member States (BE, FI, IE, NL, MT, PT)347
that do not have a PTI
requirement for motorcycles introduce roadside inspections for motorcycles over 125 cc as an
347
Until the end of 2023, France had not introduced mandatory PTI for motorcycles but the French authorities had
announced the intention to do so. For this reason, for the purposes of the analysis it was assumed that France would not
be affected by the proposed measure. Denmark does not have mandatory PTI but it has introduced roadside inspections,
and it is thus assumed to be part of the baseline. In the case of Portugal, current requirements cover only motorcycles
over 250cc.
149
alternative. The roadside inspections are expected to cover 5% of the number of motorcycles
registered every year.
The average duration of a roadside inspection for heavy goods vehicles is around 25-30 minutes348
but in the case of motorcycles it can be reasonably expected that this will be much shorter, given the
size of the vehicle and the list of parameters to be inspected. It is assumed that, on average349
, it will
take 10 minutes which translates into an average cost of EUR 5.7 per inspection (assuming an hourly
cost of EUR 34 for technicians and associate professionals – ISCO 3). The number of roadside
inspections for motorcycles in PM1 is estimated at 80,443 in 2026, 82,566 in 2030 and 104,321 in
2050 for the 6 Member States concerned. The recurrent administrative costs are estimated at EUR
0.46 million in 2026, EUR 0.47 million in 2030 and EUR 0.59 million in 2050. Expressed as present
value over 2026-2050, they are estimated at EUR 9.1 million relative to the baseline.
3.10.2. Adjustment costs for national public authorities
Under PM1 it is assumed that the national public authorities of the 6 MS affected by the measure
purchase additional equipment to support the additional inspections. For a 5% share of the
motorcycles fleet, one extra RSI unit per MS is expected to be sufficient. With an estimated cost of
EUR 20,000 per unit (according to input from stakeholders), the one-off adjustment costs are
estimated at EUR 120,000 in 2026.
Recurrent adjustment costs (i.e., maintenance costs) are assumed to be around 10% of the capital
costs and estimated at EUR 12,000 per year from 2026 onwards. Expressed as present value over
2026-2050, they are estimated at EUR 0.2 million relative to the baseline.
Table 85: Costs for national public authorities due to PM1 in 2026, 2030, 2040 and 2050 in policy options PO1a
and PO2 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of roadside inspections 80,443 82,566 93,459 104,321
Administrative costs (million EUR) 0.46 0.47 0.53 0.59
Recurrent administrative costs 0.46 0.47 0.53 0.59
Total adjustment costs (million EUR) 0.13 0.01 0.01 0.01
One-off costs for equipment 0.12 0.00 0.00 0.00
Recurrent maintenance costs 0.01 0.01 0.01 0.01
Source: Ricardo et al. (2024), Impact assessment support study
Table 86: Costs for national public authorities due to PM1 in PO1a and PO2, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Administrative costs 9.12 9.12
Recurrent administrative costs 9.12 9.12
Total adjustment costs 0.34 0.34
One-off costs for equipment 0.12 0.12
Recurrent maintenance costs 0.22 0.22
Source: Ricardo et al. (2024), Impact assessment support study
348
SWD(2012)206
349
This includes the larger share of inspections where there are no specific issues identified on the basis of an initial
inspection (where the duration can be even shorter than 10 minutes) and the smaller number of inspections that may
require more extensive testing.
150
3.10.3. Administrative cost for citizens (vehicle owners)
Vehicle owners will experience some costs for the time spent for cooperating on roadside inspections
with the public authorities. As explained, the average time required for a roadside inspection is
estimated at 10 minutes. Considering an average hourly labour cost of EUR 29.5 and the number of
roadside inspections, the administrative costs for citizens are estimated at EUR 0.40 million in 2026,
EUR 0.41 million in 2030 and EUR 0.51 million in 2050. Expressed as present value over 2026-
2050, they are estimated at EUR 7.9 million relative to the baseline.
Where a vehicle is found to be defective, the authorities may request the owner/holder of the vehicle
to pay a charge corresponding to the cost of the test, in addition to the cost of repair. It is not possible
to quantify the costs incurred in the form of such a charge, but they are expected to be limited. The
cost of repair would have to be borne by the vehicle owner anyway; the RSI only helps identify the
defects earlier.
The tables below summarise the costs expected for citizens due to PM1.
Table 87: Recurrent administrative costs for citizens due to PM1 in 2026, 2030, 2040 and 2050 in policy options
PO1a and PO2 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of roadside inspections 80,443 82,566 93,459 104,321
Administrative costs (million EUR) 0.40 0.41 0.46 0.51
Recurrent administrative costs 0.40 0.41 0.46 0.51
Source: Ricardo et al. (2024), Impact assessment support study
Table 88: Recurrent administrative costs for citizens due to PM1 in PO1a and PO2, expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Administrative costs 7.92 7.92
Recurrent administrative costs 7.92 7.92
Source: Ricardo et al. (2024), Impact assessment support study
3.11. PM2 - Mandatory PTI for motorcycles above 125cm3 (remove current opt-out)
This measure introduces removing the current opt-out from the mandatory PTI for motorcycles.
When motorcycles are not regularly tested, this has a non-negligeable impact on road safety. A
comparison between the countries that apply PTI (ES, IT, DE) and FR that only introduced PTI for
motorcycles in April 2024, is provided in the table below. The figures indicate the number of fatalities
of occupants of powered two-wheelers in comparison to the fleet size of those vehicles in the four
Member States. While the number of fatalities is highest in these Member States (with 542
motorcycle fatalities in DE, 417 in ES, 615 in FR, and 698 in IT, in 2019), the ratios below indicate
that PTI for these vehicles probably has a noticeable impact. In fact, the differences are significant
between the countries that apply PTI to both motorcycles and mopeds (ES and IT), to motorcycles
only (DE) and FR that only introduced PTI for motorcycles in April 2024.
Table 89: Fatalities of occupants of powered two wheelers (i.e., motorcycles and mopeds) per 1000 powered two
wheelers
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
DE 0.19 0.20 0.17 0.16 0.16 0.17 0.14 0.15 0.16 0.13
ES 0.10 0.08 0.07 0.07 0.07 0.08 0.08 0.08 0.08 0.08
FR 0.28 0.29 0.28 0.28 0.29 0.29 0.29 0.26 0.25 0.25
IT 0.13 0.12 0.11 0.10 0.09 0.10 0.09 0.09 0.08 0.08
151
Source: CARE database and Statistical Pocketbook "EU transport in figures”
3.11.1. Adjustment costs for PTI centres
PM2 implies that the capacity of PTI centres in the MS where PTI is not in place (BE, FI, IE, NL,
MT, PT, DK)350
should be increased. The way that PTI services are organised in each Member States
differ. The level of extra capacity and the associated costs that may arise to meet the extra demand
are estimated recognising that there may be some differences among Member States.
The additional number of inspections in the 7 MS is estimated at 733,056 in 2026, 751,660 in 2030
and 941,911 in 2050351
.
Additional PTI lanes to deliver these inspections will be needed. Assuming a typical PTI lane
operating 10 hours a day for 220 days, a total of up to 4,620 motorcycle inspections can be delivered.
On the basis of the projected number of inspections, around 159 additional PTI lanes will be needed
in 2026 and 45 additional ones by 2050 (204 additional PTI lanes in total over 2026-2050 relative to
the baseline). The cost per PTI lane is estimated at EUR 20,000. The one-off adjustment costs are
thus estimated at EUR 3.2 million in 2026, EUR 20,000 in 2030 and EUR 40,000 in 2050 relative to
the baseline. Expressed as present value over 2026-2050, they are estimated at EUR 3.8 million
relative to the baseline.
Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e., EUR
2,000 per lane). They are estimated at EUR 318,000 in 2026, EUR 326,000 in 2030, going up to EUR
408,000 in 2050 due to the additional PTI lanes added over time in line with the projected growth in
the number of inspections. Expressed as present value over 2026-2050, the recurrent adjustment costs
for the maintenance of the PTI lanes are estimated at EUR 6.3 million relative to the baseline.
The average duration of a PTI inspection for motorcycles is around 20 minutes. The labour costs per
inspection are estimated at EUR 11.3, assuming an hourly cost of EUR 34 for technicians and
associate professionals (ISCO 3). To deliver the estimated additional number of inspections, the
recurrent adjustment costs are estimated at EUR 8.3 million in 2026, EUR 8.5 million in 2030 and
EUR 10.7 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR
165.5 million relative to the baseline.
The number of additional inspectors that need to be trained for performing the PTIs in the 7 Member
States concerned by PM2 is estimated at 167 in 2026, and 48 additional ones by 2050 (215 inspectors
to be trained in total over 2026-2050 relative to the baseline). They are estimated based on the
projected number of additional PTIs in the 7 Member States and the average number of PTIs per
inspector (i.e., 4,380). Assuming a two-day training for the additional inspectors, at an hourly cost of
EUR 34 for technicians and associate professionals – ISCO 3), the total one-off adjustment costs for
training are estimated at EUR 82,634 in 2026, EUR 495 in 2030 and EUR 990 in 2050. Expressed as
present value over 2026-2050, they are estimated at EUR 98,875 relative to the baseline.
350
France has not introduced mandatory PTI for motorcycles up to now but the French authorities have announced the
intention to do so. For this reason, for the purposes of the analysis it is assumed that France will not be affected by the
proposed measure.
351
This is estimated as the number of motorcycles in the baseline from the PRIMES-TREMOVE model, multiplied by
the average number of inspections per motorcycle over its lifetime (estimated at 8) and divided by the average age of a
motorcycle (18 years). The average number of inspections per motorcycle is calculated based on the assumed frequency
and average age.
152
The tables below summarise the costs expected for PTI centres due to PM2.
Table 90: Adjustment costs for PTI centres due to PM2 in 2026, 2030, 2040 and 2050 in policy option PO1b relative
to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of inspections 733,056 751,660 847,034 941,911
Total adjustment costs 11.88 8.86 10.00 11.12
One-off costs for the additional PTI lanes 3.18 0.02 0.04 0.04
Recurrent costs for the maintenance of the PTI lanes 0.32 0.33 0.37 0.41
Recurrent labour costs for inspections 8.30 8.51 9.60 10.67
One-off costs for training 0.08 0.00 0.00 0.00
Source: Ricardo et al. (2024), Impact assessment support study
Table 91: Adjustment costs for PTI centres due to PM2 in PO1b, expressed as present value over 2026-2050
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 175.7
One-off costs for the additional PTI lanes 3.8
Recurrent costs for the maintenance of the PTI lanes 6.3
Recurrent labour costs for inspections 165.5
One-off costs for training 0.1
Source: Ricardo et al. (2024), Impact assessment support study
3.11.2. Enforcement costs for national public authorities
The introduction of mandatory PTI will also imply some extra costs for the authorities that are
responsible for monitoring the operation of the system, evaluating the quality of the PTI inspections.
The Dutch authorities (RDW) reported that around EUR 4.5 per PTI is charged to vehicle owners to
cover the costs of monitoring by authorities. The Dutch system includes random inspections of
vehicles done by RDW as a way to check the quality of PTI inspections. This is not an approach
adopted in other Member States and it is not a requirement of the Directive. As such, the cost of EUR
4.5 per PTI is not considered representative of the typical monitoring costs. For the calculations, an
average monitoring cost of EUR 2.25 per PTI is assumed (50% of the cost provided by RDW).
Recurrent enforcement costs are thus estimated at EUR 1.6 million in 2026, EUR 1.7 million in 2030
and EUR 2.1 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR
32.9 million relative to the baseline.
Table 92: Enforcement costs for national public authorities due to PM2 in 2026, 2030, 2040 and 2050 in policy
option PO1b relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent enforcement costs 1.6 1.7 1.9 2.1
Source: Ricardo et al. (2024), Impact assessment support study
153
Table 93: Enforcement costs for national public authorities due to PM2 in PO1b, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent enforcement costs 32.9
Source: Ricardo et al. (2024), Impact assessment support study
3.11.3. Administrative costs for citizens (vehicle owners)
Mandatory PTI for motorcycles translate into additional costs for vehicles owners in the Member
States affected. Using the median of the charges per PTI test from the other Member States, estimated
at EUR 20.1, the recurrent administrative costs for citizens are estimated at EUR 14.8 million in
2026, EUR 15.1 million in 2030 and EUR 19 million in 2050. Expressed as present value over the
2026-2050 period, they are estimated at EUR 294.1 million.
Motorcycle owners with identified defective motorcycles will incur costs to repair their motorcycles
while they will also need to spend some time to travel to PTI centres, thus incurring some extra costs.
However, these may vary significantly by vehicle and were not possible to quantify.
The tables below summarise the costs for citizens expected for PM2 in PO1b.
Table 94: Administrative costs for citizens (vehicle owners) due to PM2 in 2026, 2030, 2040 and 2050 in policy
option PO1b relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs 14.8 15.1 17.1 19.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 95: Administrative costs for citizens (vehicle owners) due to PM2 in PO1b, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 294.1
Source: Ricardo et al. (2024), Impact assessment support study
3.11.4. Benefits for PTI centres
PM2 would result in benefits for the PTI centres in the 7 MS affected, due to the mandatory PTI for
heavy/powerful motorcycles. The costs for vehicle owners (citizens) discussed above represent
revenues for the PTI centres. The total revenues for PTI centres due to PM2 are estimated at EUR
14.8 million in 2026, EUR 15.1 million in 2030 and EUR 19 million in 2050. Expressed as present
value over 2026-2050, they are estimated at EUR 294.1 million relative to the baseline.
Table 96: Benefits for PTI centres due to PM2 in 2026, 2030, 2040 and 2050 in policy option PO1b relative to the
baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Revenues for PTI centres 14.8 15.1 17.1 19.0
Source: Ricardo et al. (2024), Impact assessment support study
154
Table 97: Benefits for PTI centres due to PM2 policy option PO1b, expressed as present value over 2026-2050
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Revenues for PTI centres 294.1
Source: Ricardo et al. (2024), Impact assessment support study
3.12. PM3 - Extend PTI to all motorcycles (i.e., including from 50cm3 = all L3e, L4e, plus
tricycles (L5e) and heavy quadricycles (L7e))
3.12.1. Adjustment costs for PTI centres
PM3 extends the type of motorcycles covered by PTI to those from 50cm3 in the eight Member States
where such requirement is currently not in place (BE, FI, IE, NL, MT, PT, DK, CY352
).
The additional number of inspections in the 8 MS affected is estimated at 845,522 in 2026, 869,017
in 2030 and 1,097,479 in 2050353
.
Similarly to PM2, additional PTI lanes to deliver these inspections will be needed. Assuming a typical
PTI lane operating 10 hours a day for 220 days, a total of up to 4,620 motorcycle inspections can be
delivered. On the basis of the projected number of inspections, around 183 additional PTI lanes will
be needed in 2026 and 55 additional ones by 2050 (238 additional PTI lanes in total over 2026-2050
relative to the baseline). The cost per PTI lane is estimated at EUR 20,000. The one-off adjustment
costs are estimated at EUR 3.7 million in 2026, EUR 20,000 in 2030 and EUR 60,000 in 2050 relative
to the baseline. Expressed as present value over 2026-2050, they are estimated at EUR 4.4 million
relative to the baseline.
Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e., EUR
2,000 per lane). They are estimated at EUR 366,000 in 2026, EUR 376,000 in 2030, going up to EUR
476,000 in 2050 due to the additional PTI lanes added over time in line with the projected growth in
the number of inspections. Expressed as present value over 2026-2050, the recurrent adjustment costs
for the maintenance of the PTI lanes are estimated at EUR 7.3 million relative to the baseline.
The average duration of a PTI inspection for motorcycles is around 20 minutes. The labour costs per
inspection are estimated at EUR 11.3, assuming an hourly cost of EUR 34 for technicians and
associate professionals (ISCO 3). To deliver the estimated additional number of inspections, the
recurrent adjustment costs are estimated at EUR 9.6 million in 2026, EUR 9.8 million in 2030 and
EUR 12.4 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR
192.1 million relative to the baseline.
The number of additional inspectors that need to be trained for performing the PTIs in the 8 Member
States concerned by PM3 is estimated at 193 in 2026, and 58 additional ones by 2050 (251 inspectors
to be trained in total over 2026-2050 relative to the baseline). They are estimated based on the
projected number of additional PTIs in the 8 Member States and the average number of PTIs per
inspector (i.e., 4,380). Assuming a two-day training for the additional inspectors, at an hourly cost of
EUR 34 for technicians and associate professionals – ISCO 3), the total one-off adjustment costs for
352
In Cyprus motorcycles above 125cm3 are already covered.
353
This is estimated as the number of motorcycles in the baseline from the PRIMES-TREMOVE model, multiplied by
the average number of inspections per motorcycle over its lifetime (estimated at 8) and divided by the average age of a
motorcycle (18 years). The average number of inspections per motorcycle is calculated based on the assumed frequency
and average age.
155
training are estimated at EUR 95,499 in 2026, EUR 495 in 2030 and EUR 1,484 in 2050. Expressed
as present value over 2026-2050, they are estimated at EUR 115,102 relative to the baseline.
The tables below summarise the costs expected for PTI centres due to PM3.
Table 98: Adjustment costs for PTI centres due to PM3 in 2026, 2030, 2040 and 2050 in policy option PO3 relative
to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of inspections 845,522 869,017 985,326 1,097,479
Total adjustment costs 13.70 10.24 11.65 12.97
One-off costs for the additional PTI lanes 3.66 0.02 0.06 0.06
Recurrent costs for the maintenance of the PTI lanes 0.37 0.38 0.43 0.48
Recurrent labour costs for inspections 9.58 9.84 11.16 12.43
One-off costs for training 0.10 0.00 0.00 0.00
Source: Ricardo et al. (2024), Impact assessment support study
Table 99: Adjustment costs for PTI centres due to PM3 in PO3, expressed as present value over 2026-2050 relative
to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 203.9
One-off costs for the additional PTI lanes 4.4
Recurrent costs for the maintenance of the PTI lanes 7.3
Recurrent labour costs for inspections 192.1
One-off costs for training 0.1
Source: Ricardo et al. (2024), Impact assessment support study
3.12.2. Enforcement cost for national public authorities
The introduction of mandatory PTI will also imply some extra costs for the authorities that are
responsible for monitoring the operation of the system, evaluating the quality of the PTI inspections.
The Dutch authorities (RDW) reported that around EUR 4.5 per PTI is charged to vehicle owners to
cover the costs of monitoring by authorities. The Dutch system includes random inspections of
vehicles done by RDW as a way to check the quality of PTI inspections. This is not an approach
adopted in other Member States and it is not a requirement of the Directive. As such, the cost of EUR
4.5 per PTI is not considered representative of the typical monitoring costs. For the calculations, an
average monitoring cost of EUR 2.25 per PTI is assumed (50% of the cost provided by RDW).
Recurrent enforcement costs are thus estimated at EUR 1.9 million in 2026, EUR 2 million in 2030
and EUR 2.5 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR
38.1 million relative to the baseline.
Table 100: Enforcement costs for national public authorities due to PM3 in 2026, 2030, 2040 and 2050 in policy
option PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent enforcement costs 1.9 2.0 2.2 2.5
Source: Ricardo et al. (2024), Impact assessment support study
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Table 101: Enforcement costs for national public authorities due to PM3 in PO3, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent enforcement costs 38.1
Source: Ricardo et al. (2024), Impact assessment support study
3.12.3. Administrative cost for citizens (vehicle owners)
Mandatory PTI for motorcycles translate into additional costs for vehicles owners in the Member
States affected. Using the median of the charges per PTI test from the other Member States, estimated
at EUR 20.1, the recurrent administrative costs for citizens are estimated at EUR 17 million in 2026,
EUR 17.5 million in 2030 and EUR 22.1 million in 2050. Expressed as present value over the 2026-
2050 period, they are estimated at EUR 341.3 million.
Motorcycle owners with identified defective motorcycles will incur costs to repair their motorcycles
while they will also need to spend some time to travel to PTI centres, thus incurring some extra costs.
However, these may vary significantly by vehicle and were not possible to quantify them.
The tables below summarise the costs for citizens (vehicle owners) expected for PM3 in PO3.
Table 102: Administrative costs for citizens (vehicle owners) due to PM3 in 2026, 2030, 2040 and 2050 in policy
option PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs 17.0 17.5 19.8 22.1
Source: Ricardo et al. (2024), Impact assessment support study
Table 103: Administrative costs for citizens (vehicle owners) due to PM3 in PO3, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 341.3
Source: Ricardo et al. (2024), Impact assessment support study
3.12.4. Benefits for PTI centres
PM3 would result in benefits for the PTI centres in the 8 MS affected, due to the extension of PTI to
all motorcycles. The costs for vehicle owners (citizens) discussed above represent revenues for the
PTI centres. The total revenues for PTI centres due to PM3 are estimated at EUR 17 million in 2026,
EUR 17.5 million in 2030 and EUR 22.1 million in 2050. Expressed as present value over 2026-
2050, they are estimated at EUR 341.3 million relative to the baseline.
Table 104: Benefits for PTI centres due to PM3 in 2026, 2030, 2040 and 2050 in policy option PO3 relative to the
baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Revenues for PTI centres 17.0 17.5 19.8 22.1
Source: Ricardo et al. (2024), Impact assessment support study
157
Table 105: Benefits for PTI centres due to PM3 in policy option PO3, expressed as present value over 2026-2050
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Revenues for PTI centres 341.3
Source: Ricardo et al. (2024), Impact assessment support study
3.13. PM4 – Mandatory PTI for light trailers (O1 and O2 categories)
PM4 requires the mandatory PTI for light trailers (O1 and O2 categories). Eleven Member States
would be affected by PM4: 7 Member States where there is currently no requirement for PTI for
either O1 or O2 (DK, EL, FI, FR, NL, IE, PT) and 4 Member States where there is currently only a
requirement for PTI for O2 (PL, SK, BE and ES).
3.13.1. Adjustment costs for PTI centres
Assuming a frequency scheme of 4/2/2 the additional number of inspections due to PM4 in the 11
MS is estimated at 1.3 million in 2026, 1.4 million in 2030 and 1.6 million in 2050354
, of which for
O1 category 724,302 inspections in 2026, 753,381 in 2030 and 830,560 in 2050 and for O2 category
597,825 inspections in 2026, 638,053 in 2030 and 734,593 in 2050.
Additional PTI lanes to deliver these inspections may be needed, although it is possible that extra
utilisation of the existing capacity may allow to cover at least part of the extra demand. For the
assessment, it has been assumed that additional PTI lanes would be needed for inspections of O2
category trailers only355
. Assuming a typical PTI lane operating for 220 days and allowing the
inspection of 28 trailers per day, a total of up to 6,160 inspections can be delivered for O2 trailers per
year by a PTI lane. On the basis of the projected number of inspections, around 97 additional PTI
lanes will be needed in 2026 and 22 additional ones by 2050 (119 additional PTI lanes in total over
2026-2050 relative to the baseline). The cost of an additional PTI lane for trailers is estimated at EUR
10,000 per lane. The one-off adjustment costs are thus estimated at EUR 970,000 in 2026, EUR
20,000 in 2030 and no extra costs in 2050 relative to the baseline. Expressed as present value over
2026-2050, they are estimated at EUR 1.1 million relative to the baseline.
Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e., EUR
1,000 per lane). They are estimated at EUR 97,000 in 2026, EUR 104,000 in 2030, going up to EUR
119,000 in 2050 due to the additional PTI lanes added over time in line with the projected growth in
the number of inspections. Expressed as present value over 2026-2050, the recurrent adjustment costs
for the maintenance of the PTI lanes are estimated at EUR 2 million relative to the baseline.
The average duration of a PTI inspection for trailers is around 15 minutes. The labour costs per
inspection are estimated at EUR 8.5, assuming an hourly cost of EUR 34 for technicians and associate
professionals (ISCO 3). To deliver the estimated additional number of inspections, the recurrent
354
This is estimated as the number of trailers in the baseline, multiplied by the average number of inspections per trailer
over its lifetime (estimated at 8) and divided by the average age of a trailer (18 years).
355
For the inspection of O2 trailers a rolling brake test equipment will be needed (not needed for O1 trailers) which,
given the expected volume of trailers to be tested may lead to the need of extra capacity. Some stakeholders indicated
that the inspections can be carried out with the existing equipment but for the assessment it is considered that due to the
significant extra volume of inspections expected, extra investment would be needed in PTI lanes for O2 trailers. In the
case of O1 trailers visual inspection is expected to be sufficient and thus no additional PTI lanes are expected to be
needed. The feedback received from stakeholders in the context of the stakeholders’ survey indicated that no extra
equipment is needed for O1 trailers. No stakeholder mentioned the need for extra space and the costs associated to it.
Thus, although additional costs for O1 trailers are possible, they are not considered significant and not estimated.
158
adjustment costs are estimated at EUR 11.2 million in 2026, EUR 11.8 million in 2030 and EUR 13.3
million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 222.3 million
relative to the baseline.
No training costs are expected since the inspections required are similar to those of other vehicles.
Table 106: Adjustment costs for PTI centres due to PM4 in 2026, 2030, 2040 and 2050 in policy option PO3 relative
to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of inspections, of which: 1,322,127 1,391,434 1,513,772 1,565,153
for O1 category 724,302 753,381 810,970 830,560
for O2 category 597,825 638,053 702,803 734,593
Total adjustment costs 12.3 11.9 13.0 13.4
One-off costs for the additional PTI lanes 1.0 0.0 0.0 0.0
Recurrent costs for the maintenance of the PTI lanes
0.1 0.1 0.1 0.1
Recurrent labour costs for inspections 11.2 11.8 12.9 13.3
Source: Ricardo et al. (2024), Impact assessment support study
Table 107: Adjustment costs for PTI centres due to PM4 in PO3, expressed as present value over 2026-2050
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 225.4
One-off costs for the additional PTI lanes 1.1
Recurrent costs for the maintenance of the PTI lanes 2.0
Recurrent labour costs for inspections 222.3
Source: Ricardo et al. (2024), Impact assessment support study
3.13.2. Enforcement costs for national public authorities
Similarly to PM2 and PM3, the introduction of mandatory PTI will also imply some extra costs for
the authorities that are responsible for monitoring the operation of the system and evaluating the
quality of the PTI inspections. The approach for estimating the recurrent enforcement costs is similar
to that explained under PM3. However, lower costs per trailer are assumed for monitoring in this case
(EUR 1.5 per trailer inspection versus EUR 2.25 per motorcycle inspection). The recurrent
enforcement costs for the 11 Member States affected by PM4 are estimated at EUR 2 million in 2026,
EUR 2.1 million in 2030 and EUR 2.3 million in 2050. Expressed as present value over 2026-2050,
they are estimated at EUR 39.2 million.
Table 108: Enforcement costs for national public authorities due to PM4 in 2026, 2030, 2040 and 2050 in policy
option PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent enforcement costs 2.0 2.1 2.3 2.3
Source: Ricardo et al. (2024), Impact assessment support study
159
Table 109: Enforcement costs for national public authorities due to PM4 in PO3, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent enforcement costs 39.2
Source: Ricardo et al. (2024), Impact assessment support study
3.13.3. Administrative cost for businesses (vehicle owners)
Mandatory PTI for trailers translate into additional costs for vehicles owners in the Member States
affected. To calculate the costs, it is assumed that all O2 trailers and half of the O1 trailers are owned
by business. Charges for PTI for trailers are expected to be no greater than those for motorcycles,
considering also that there is no emissions test. Assuming a fee per PTI test for trailers of EUR 20.1,
the recurrent administrative costs for businesses are estimated at EUR 19.3 million in 2026, EUR
20.4 million in 2030 and EUR 23.1 million in 2050. Expressed as present value over the 2026-2050
period, they are estimated at EUR 385.1 million.
The tables below summarise the administrative costs for businesses expected for PM4.
Table 110: Administrative costs for businesses (vehicle owners) due to PM4 in 2026, 2030, 2040 and 2050 in policy
option PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs 19.3 20.4 22.3 23.1
Source: Ricardo et al. (2024), Impact assessment support study
Table 111: Administrative costs for businesses (vehicle owners) due to PM4 in PO3, expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 385.1
Source: Ricardo et al. (2024), Impact assessment support study
3.13.4. Administrative cost for citizens (vehicle owners)
As explained above, mandatory PTI for trailers translate into additional costs for vehicles owners in
the Member States affected. To calculate the costs citizens, it is assumed that half of the O1 trailers
are owned by citizens. Assuming a charge per PTI test for trailers of EUR 20.1, the recurrent
administrative costs for citizens are estimated at EUR 7.3 million in 2026, EUR 7.6 million in 2030
and EUR 8.4 million in 2050. Expressed as present value over the 2026-2050 period, they are
estimated at EUR 141.5 million.
The tables below summarise the administrative costs for citizens expected for PM4.
Table 112: Administrative costs for citizens (vehicle owners) due to PM4 in 2026, 2030, 2040 and 2050 in policy
option PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs 7.3 7.6 8.2 8.4
Source: Ricardo et al. (2024), Impact assessment support study
160
Table 113: Administrative costs for citizens (vehicle owners) due to PM4 in PO3, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 141.5
Source: Ricardo et al. (2024), Impact assessment support study
3.13.5. Benefits for PTI centres
PM4 would result in benefits for the PTI centres in the MS affected, due to the mandatory PTI for
light trailers. The costs for vehicle owners (citizens and businesses) discussed above represent
revenues for the PTI centres. The total revenues for PTI centres due to PM4 are estimated at EUR
26.6 million in 2026, EUR 28 million in 2030 and EUR 31.5 million in 2050. Expressed as present
value over 2026-2050, they are estimated at EUR 526.6 million relative to the baseline.
Table 114: Benefits for PTI centres due to PM4 in 2026, 2030, 2040 and 2050 in policy option PO3 relative to the
baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Revenues for PTI centres 26.6 28.0 30.5 31.5
Source: Ricardo et al. (2024), Impact assessment support study
Table 115: Benefits for PTI centres due to PM4 in policy option PO3, expressed as present value over 2026-2050
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Revenues for PTI centres 526.6
Source: Ricardo et al. (2024), Impact assessment support study
3.14. PM5 – Annual emission testing for light commercial vehicles (N1) instead of the currently
required 4-2-2 frequency
PM5 includes a requirement for annual emission testing for light commercial vehicles (N1) instead
of the currently required 4-2-2 frequency. It assumes additional emission testing in all Member States.
The assessment of PM5 (included in PO1b, PO2 and PO3) takes into account the synergies with
PMC3 on a proposed PN testing at PTI and with PMC4 on a new NOx test.
3.14.1. Adjustment costs for PTI centres
The additional number of emission testing for internal combustion light commercial vehicles due to
PM5 is estimated at 14.3 million in 2026, 14.2 million in 2030 and 1.2 million in 2050 relative to the
baseline356
. The decrease in the number of emission testing is driven by the decrease in the number
of internal combustion light commercial vehicles over time. This is due to the Regulation on CO2
standards for LDVs that is included in the baseline.
PM5 is expected to lead to one-off adjustment costs for additional emission testing equipment. Based
on stakeholders’ feedback, the price for new PN measurement equipment is estimated at EUR 5,000
per equipment and that for new NOx measurement equipment at EUR 15,000. One tool per inspector
is required.
356
The number of inspections is estimated based on the projected number of internal combustion light commercial
vehicles from the PRIMES-TREMOVE model.
161
The average number of full PTI inspections per inspector is estimated at 2,920 per year. However,
emission testing is estimated to take only around 20% of the time of a full PTI inspection (i.e., around
6 minutes). Thus, it is estimated that up to 14,600 emission inspections per year can be delivered per
inspector. Assuming that one emission testing equipment per inspector is needed, the required
number of additional PN and NOx measurement equipment due to PM5 is estimated at 979 in 2026.
Total one-off adjustment costs for equipment are thus estimated at EUR 19.6 million in 2026 relative
to the baseline. Recurrent adjustment costs for the calibration and maintenance of PN and NOx
equipment are estimated at 5% of the capital costs (i.e., EUR 250 per PN equipment and EUR 750
per NOx equipment), equivalent to EUR 979,000 per year from 2026 onwards. Expressed at present
value over 2026-2050, the recurrent adjustment costs are estimated at EUR 17.6 million.
Training of additional inspectors will also be required due to PM5. The number of inspectors to be
trained in 2026 is estimated at 979. Assuming a two-day training for the additional inspectors,
including for the PN and NOx testing, at an hourly cost of EUR 34 for technicians and associate
professionals – ISCO 3), the total one-off adjustment costs for training are estimated at EUR 484,425
in 2026.
Combined, the average duration of the new PN and NOx emission tests is around 6 minutes. The
labour costs per emission testing are estimated at EUR 3.4, assuming an hourly cost of EUR 34 for
technicians and associate professionals (ISCO 3). To deliver the estimated additional number of
emission testing, the recurrent adjustment costs are estimated at EUR 48.6 million in 2026, EUR 48.2
million in 2030 and EUR 3.9 million in 2050357
. Expressed as present value over 2026-2050, they
are estimated at EUR 610.1 million relative to the baseline.
Table 116: Adjustment costs for PTI centres due to PM5 in 2026, 2030, 2040 and 2050 in policy options PO1b,
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of emission testing 14,287,176 14,187,947 8,012,878 1,156,079
Total adjustment costs 69.6 49.2 28.2 4.9
One-off costs for equipment 19.6 0.0 0.0 0.0
Recurrent costs for the maintenance of
equipment
1.0 1.0 1.0 1.0
Recurrent labour costs for PN and NOx tests 48.6 48.2 27.2 3.9
One-off costs for training 0.5 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 117: Adjustment costs for PTI centres due to PM5 in PO1b, PO2 and PO3, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 0.0 647.7 647.7 647.7
One-off costs for equipment 0.0 19.6 19.6 19.6
Recurrent costs for the maintenance of equipment 0.0 17.6 17.6 17.6
Recurrent labour costs for PN and NOx tests 0.0 610.1 610.1 610.1
One-off costs for training 0.0 0.5 0.5 0.5
Source: Ricardo et al. (2024), Impact assessment support study
3.14.2. Administrative cost for businesses (vehicle owners)
The introduction of annual emission testing for N1 vehicles will result in recurrent administrative
costs for vehicle owners (i.e., businesses in case of N1 vehicles) due to the testing charges. Taking
357
The labour costs decrease over time due to the decreasing number of internal combustion light commercial vehicles.
162
into account feedback from stakeholder interviews, the new emission test (involving PN and NOx
testing) is expected to cover 20% (6 minutes) of the total PTI duration. Considering the median charge
per vehicle of EUR 40.5 per N1 vehicle and the 20% share of the time covering the PN and NOx
testing, the recurrent administrative costs for vehicle owners are estimated at 115.8 million in 2026,
EUR 115 million in 2030 and EUR 9.4 million in 2050. Expressed as present value over the 2026-
2050 period, they are estimated at EUR 1.5 billion relative to the baseline.
The tables below summarise the impact of PM5 (included in PO1b, PO2 and PO3) on businesses.
Table 118: Administrative costs for businesses (vehicle owners) due to PM5 in 2026, 2030, 2040 and 2050 in policy
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs 115.8 115.0 64.9 9.4
Source: Ricardo et al. (2024), Impact assessment support study
Table 119: Administrative costs for businesses (vehicle owners) due to PM5 in PO1b, PO2 and PO3 expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 1,454.8 1,454.8 1,454.8
Source: Ricardo et al. (2024), Impact assessment support study
3.14.3. Benefits for PTI centres
PM5 would result in benefits for the PTI centres due to the annual emission testing for light
commercial vehicles (N1) instead of the currently required 4-2-2 frequency. The costs for vehicle
owners (businesses) discussed above represent revenues for the PTI centres. The total revenues for
PTI centres due to PM5 are estimated at EUR 115.8 million in 2026, EUR 115 million in 2030 and
EUR 9.4 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 1.5
billion relative to the baseline.
Table 120: Benefits for PTI centres due to PM5 in 2026, 2030, 2040 and 2050 in policy options PO1b, PO2 and
PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Revenues for PTI centres 115.8 115.0 64.9 9.4
Source: Ricardo et al. (2024), Impact assessment support study
Table 121: Benefits for PTI centres due to PM5 in policy options PO1b, PO2 and PO3, expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Revenues for PTI centres 1,454.8 1,454.8 1,454.8
Source: Ricardo et al. (2024), Impact assessment support study
3.15. PM6 – Mandatory yearly testing for vehicles that are 10-year-old or older
Currently, 11 MS do not require annual PTI testing of light-duty vehicles after 10 years of their
registration (CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT, SK). All these Member States currently
require an inspection every two years which means that the proposed measure will double the number
of inspections for vehicles over 10 years.
The assessment of PM6 (included in PO1b, PO2 and PO3) takes into account the synergies with
PMC3 on a proposed PN testing at PTI and with PMC4 on a new NOx test. It also takes into account
163
the synergies with PMC1 concerning the PTI of electric vehicles and PMC2 on updates to cover
General Safety Regulation Requirements. However, no additional costs are expected in relation to
PMC1 and PMC2 given that the relevant update of the tools already used will need to take place
irrespective of the frequency of the test.
Furthermore, the costs related to PM5 (included in PO1b, PO2 and PO3) for emission testing
associated to N1 vehicles aged 10 years or older overlap with PM6 and are thus not considered under
the assessment of PM6, to avoid double-counting in estimating the costs of PO1b, PO2 and PO3.
3.15.1. Adjustment costs for PTI centres
The additional number of PTIs for M1 vehicles category due to PM6 is estimated at 41.1 million in
2026, 42.1 million in 2030 and 47.5 million in 2050 and for N1 vehicle category at 4.3 million in
2026, 4.5 million in 2030 and 5.2 million in 2050.
PM6 is expected to lead to one-off adjustment costs for inspection centres for the additional emission
testing equipment and for additional PTI lanes. As explained in PMC3 and PMC4, the cost per new
PN testing equipment is assumed at EUR 5,000 and for NOx testing at EUR 15,000 per equipment.
In addition, based on an interview with TUV Rheinland, the cost of a new PTI lane is assumed at
EUR 50,000.
Based on the capacity of a PTI lane to process 3,080 inspections of M1 and N1 vehicles per year, the
additional inspections will require 14,746 new PTI lanes across the EU27 in 2026 and 2,359
additional ones by 2050 (17,105 new PTI lanes in total over 2026-2050). Of this, the new PTI lanes
for M1 vehicles represent 13,353 in 2026 and 2,057 additional ones by 2050 (15,410 new PTI lanes
over 2026-2050). Each new lane for M1 vehicles in 2026 will also require one set of PN and NOx
testing equipment358
. Additional PN testing and NOx testing equipment is assumed only for M1
vehicles categories as the costs for such equipment related to N1 vehicles is already reflected in PM5.
Thus, the one-off costs for equipment are estimated at EUR 1 billion in 2026, EUR 4.9 million in
2030 and EUR 1.7 million in 2050. Expressed as present value over 2026-2050, they are estimated
at EUR 1.1 billion.
Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e., EUR
5,000 per lane). In addition, annual maintenance costs to calibrate, repair and update the additional
PN and NOx equipment for M1 vehicles inspections is estimated at 5% of the initial cost (around
EUR 250 for PN-PTI equipment and 750 EUR for NOx equipment). Total recurrent adjustment costs
for equipment are thus estimated at EUR 87.1 million in 2026, EUR 89 million in 2030, going up to
EUR 98.9 million in 2050 due to the additional PTI lanes added over time in line with the projected
growth in the number of inspections. Expressed as present value over 2026-2050, they are estimated
at EUR 1.7 billion relative to the baseline.
Training of additional inspectors will also be required due to PM6. On average an inspector performs
2,920 PTI inspectors per year. Thus, PM6 is expected to require an additional 14,746 inspectors to
be trained in 2026. Assuming a two-days training to cover the knowledge related to emission testing,
but also testing of electric vehicles and GSR software update, and an hourly cost of EUR 34 for
358
Additional equipment for PN testing and NOx testing is only assumed in 2026 and should accommodate the additional
number of inspections. This is because of the increase in the share of zero-emission vehicles over time and thus the
decrease in the number of PN and NOx testing relative to 2026.
164
technicians and associate professionals – ISCO 3), the one-off adjustment costs for training are
estimated at EUR 7.3 million in 2026.
The average duration of a PTI inspection is 30 minutes. The labour costs per PTI inspection are
estimated at EUR 17, assuming an hourly cost of EUR 34 for technicians and associate professionals
(ISCO 3). To deliver the estimated additional number of inspections, the recurrent adjustment costs
are estimated at EUR 771.7 million in 2026, EUR 792.1 million in 2030 and EUR 895.2 million in
2050. Expressed as present value over 2026-2050, they are estimated at EUR 14.9 billion relative to
the baseline.
Table 122: Adjustment costs for PTI centres due to PM6 in 2026, 2030, 2040 and 2050 in policy options PO1b,
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of inspections, of
which:
45,416,666 46,614,893 50,581,135 52,682,848
for M1 category 41,125,717 42,134,669 45,715,359 47,462,922
for N1 category 4,290,949 4,480,224 4,865,776 5,219,925
Total adjustment costs 1,870.5 886.0 962.4 995.7
One-off costs for equipment 1,004.4 4.9 7.5 1.7
Recurrent costs for equipment 87.1 89.0 95.5 98.9
Recurrent labour costs for inspections 771.7 792.1 859.5 895.2
One-off costs for training 7.3 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 123: Adjustment costs for PTI centres due to PM6 in PO1b, PO2 and PO3, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total one-off adjustment costs 17,680.8 17,680.8 17,680.8
One-off costs for equipment 1,090.6 1,090.6 1,090.6
Recurrent costs for equipment 1,664.7 1,664.7 1,664.7
Recurrent labour costs for inspections 14,918.2 14,918.2 14,918.2
One-off costs for training 7.3 7.3 7.3
Source: Ricardo et al. (2024), Impact assessment support study
3.15.2. Administrative cost for citizens (vehicle owners)
The introduction of annual testing for M1 and N1 vehicles that are aged 10 years or older will result
in recurrent administrative costs for vehicle owners due to testing charges. Considering the median
charge per M1 vehicle of EUR 41.7, and the fact that around 40% of M1 vehicles are owned by
citizens, the recurrent administrative costs for citizens are estimated at EUR 686.5 million in 2026,
EUR 703.4 million in 2030 and EUR 792.3 million in 2050. Expressed as present value over 2026-
2050, they are estimated at EUR 13.2 billion relative to the baseline.
Table 124: Administrative costs for citizens (vehicle owners) due to PM6 in 2026, 2030, 2040 and 2050 in policy
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs for citizens 686.5 703.4 763.2 792.3
Source: Ricardo et al. (2024), Impact assessment support study
165
Table 125: Administrative costs for citizens (vehicle owners) due to PM6 in PO1b, PO2 and PO3 expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs for citizens 13,241.7 13,241.7 13,241.7
Source: Ricardo et al. (2024), Impact assessment support study
3.15.3. Administrative cost for businesses (vehicle owners)
The introduction of annual testing for N1 and M1 vehicles that are aged 10 years or older will result
in recurrent administrative costs for vehicle owners due to testing charges. Considering the median
charge per M1 vehicle of EUR 41.7 and per N1 vehicle of EUR 40.5, and the fact that around 60%
of M1 vehicles and 100% of N1 vehicles are owned by businesses, the recurrent administrative costs
for businesses are estimated at EUR 1,203.7 million in 2026, EUR 1,236.6 million in 2030 and EUR
1,400 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 23.3
billion relative to the baseline.
Table 126: Administrative costs for businesses (vehicle owners) due to PM6 in 2026, 2030, 2040 and 2050 in policy
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs for businesses 1,203.7 1,236.6 1,341.9 1,400.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 127: Administrative costs for businesses (vehicle owners) due to PM6 in PO1b, PO2 and PO3 expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs for businesses 23,295.9 23,295.9 23,295.9
Source: Ricardo et al. (2024), Impact assessment support study
3.15.4. Benefits for PTI centres
PM6 would result in benefits for the PTI centres in the 11 MS affected due to the mandatory yearly
testing for M1 and N1 vehicles that are aged 10 years or older. The costs for vehicle owners (citizens
and businesses) discussed above represent revenues for the PTI centres. The total revenues for PTI
centres due to PM6 are estimated at EUR 1.89 billion in 2026, EUR 1.94 billion in 2030 and EUR
2.19 billion in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 36.5
billion relative to the baseline.
Table 128: Benefits for PTI centres due to PM6 in 2026, 2030, 2040 and 2050 in policy options PO1b, PO2 and
PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Revenues for PTI centres 1,890.2 1,940.0 2,105.1 2,192.4
Source: Ricardo et al. (2024), Impact assessment support study
166
Table 129: Benefits for PTI centres due to PM6 in PO1b, PO2 and PO3, expressed as present value over 2026-
2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Revenues for PTI centres 36,537.6 36,537.6 36,537.6
Source: Ricardo et al. (2024), Impact assessment support study
3.16. PM7 - PTI certificates issued in any EU MS is recognised by the MS of registration, plus
further harmonisation of test methods
PM7 requires that the Member State of registration recognises a PTI certificate issued by another
Member State. This requires that the stringency of roadworthiness testing be more even across the
EU than today. In addition to other relevant measures (such as PMC1, PMC2, PMC3 and others that
improve the quality of PTI), this measure includes further harmonisation of test methods notably in
the field of brake and suspension testing.
3.16.1. Adjustment costs for national public authorities
Several Member States have reported that their existing systems are capable of transferring data from
other national systems or have mechanisms in place that make such transfers negligible in terms of
costs. Therefore, no costs are expected for national public authorities due to PM7. Consequently, this
measure focuses on Member States identified as having lower-stringency roadworthiness systems359
,
which will need additional investments in the PTI centres.
3.16.2. Adjustment costs for PTI centres
PTI centres in the Member States with lower-stringency roadworthiness systems identified above
will need to acquire new equipment to enhance their capacity, including an advanced brake testing
device and a suspension tester360
.
Based on input from stakeholders, the advanced testing of HDV braking and of suspension (damping
efficiency of shock absorbers) will lead to additional equipment costs. For HDV brake testing using
extrapolation methods, VSG Italy indicated a cost range of EUR 2,000 to 3,000 for the necessary air
pressure sensor and a few hundred EUR per year for maintenance. For the assessment, an average
one-off cost of EUR 2,500 is assumed per PTI centre and EUR 250 annual maintenance costs. The
purchase cost of a suspension tester for light vehicles is around EUR 10,000 and the maintenance
costs are assumed at EUR 1,000 per year per tester. Considering the 11 Member States with lower-
stringency roadworthiness systems, 29,922 of the 48,880 PTI centres would have to invest into
advanced brake testing equipment and 28,322361
into suspension testers. In addition, for advanced
lighting testing, there is currently no method defined for advanced headlamp testing and stakeholders
were not able to provide an indication of costs. The same one-off and maintenance costs as for braking
have therefore been used, although it is assumed that all PTI centres will require new equipment and
the costs will not occur before 2030 (as no test procedure has been defined yet). Total one-off
adjustment costs are estimated at EUR 358 million in 2026 and EUR 122.2 million in 2030.
Expressed as present value over 2026-2050, they are estimated at EUR 476.7 million relative to the
baseline.
359
Based on a recent survey of national authorities conducted by the Commission services, these are: Bulgaria, Cyprus,
Greece, Hungary, Italy, Lithuania, Malta, Poland, Romania, Slovenia and the Netherlands.
360
Suspension testing is an optional element of PTI today.
361
Hungary already applies special equipment for testing the damping of shock absorbers.
167
Recurrent adjustment costs for maintenance are estimated at EUR 35.8 million per year for 2026-
2029 and at EUR 48 million per year from 2030 onwards, or EUR 814.5 million expressed as present
value over 2026-2050 relative to the baseline.
In conjunction with the introduction of new equipment, it is essential to provide training to inspectors
to enhance their proficiency in utilising these new methods. The number of inspectors that would
need such training in the 11 Member States with lower-stringency roadworthiness systems is
estimated at 65,976. Assuming an average of 4 hours of training at an hourly cost of EUR 34 for
technicians and associate professionals (ISCO 3), the one-off adjustment costs for training are
estimated at EUR 9 million in 2026.
The adjustment costs for PTI centres due to PM7 are summarised in the tables below.
Table 130: Adjustment costs for PTI centres due to PM7 in 2026, 2030, 2040 and 2050 in policy option PO3 relative
to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 402.8 170.2 48.0 48.0
One-off costs for equipment 358.0 122.2 0.0 0.0
Recurrent costs for equipment 35.8 48.0 48.0 48.0
One-off costs for training 9.0 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 131: Adjustment costs for PTI centres due to PM7 in PO3, expressed as present value over 2026-2050
relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 1,300.2
One-off costs for equipment 476.7
Recurrent costs for equipment 814.5
One-off costs for training 9.0
Source: Ricardo et al. (2024), Impact assessment support study
3.16.3. Adjustment costs savings for citizens (vehicle owners)
Due to PM7, citizens (i.e., vehicle owners) are expected to avoid driving unnecessary solely for the
purpose of a mandatory PTI. This particularly affects foreigners and tourists who have vehicles
stationed in a country different from their Member State of registration.
There is no data available for the number of vehicles registered in one Member State that are located
in a different Member State and would benefit from such option. According to a 2011 IA study362
,
1,000 vehicles registered in the Netherlands and 1,000 vehicles registered in Sweden stationed in
Spain, representing (on average) 0.015% of the total fleet of these countries. Assuming the same
share at the EU level and using the PRIMES-TREMOVE baseline projections for the vehicle fleet,
up to 967,379 vehicles may be stationed in a different MS than their registration country in 2026,
996,705 in 2030 and 1,112,669 in 2050. This represents an upper estimate since for a large number
of Member State pairs the number of vehicles should be much lower than the pair considered, given
that not all MS attract the same numbers of nationals of other countries for relatively long periods of
time.
362
Europe Economics (2011), Report of contribution to impact assessment of policy options to improve the EU system
of PTI and of roadside vehicle testing
168
The cost savings from avoiding a trip back to the country of vehicle registration for a PTI are
estimated based on the following assumptions. The average distance between European cities is
around 1,200 km363
. The travel cost for light vehicles is estimated at EUR 0.44 per km in 2022
prices364
. Assuming an average PTI frequency of around 0.43 times per year, the recurrent adjustment
cost savings for citizens are estimated at EUR 221.5 million in 2026, EUR 228.2 million in 2030 and
EUR 254.8 million in 2050. Expressed as present value over 2026-2050, the cost saving amount to
EUR 4.3 billion relative to the baseline.
The total cost savings for citizens (vehicle owners) due to PM7 are summarised in the tables below.
Table 132: Adjustment costs savings for citizens (vehicle owners) due to PM7 in 2026, 2030, 2040 and 2050 in
policy option PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Adjustment costs savings for
citizens
221.5 228.2 247.9 254.8
Source: Ricardo et al. (2024), Impact assessment support study
Table 133: Adjustment costs savings for citizens (vehicle owners) due to PM7 in PO3 expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs savings for
citizens
4,289.3
Source: Ricardo et al. (2024), Impact assessment support study
3.17. PM8 - PTI certificate issued in any EU MS is recognised by the MS of registration for a
period of up to 6 months (for passenger cars only), on the condition that the next PTI is
conducted in the MS of registration
3.17.1. Adjustment costs for national public authorities
Several Member States have reported that their existing systems are capable of transferring data from
other national systems or have mechanisms in place that make such transfers negligible in terms of
costs. Therefore, no costs are expected for national public authorities due to PM8.
3.17.2. Adjustment costs for PTI centres
PM8 is not expected to lead to any cost for PTI centres, considering that there are no changes to the
PTI requirements. Some increase in the demand for PTI services make take place in specific Member
States with higher number of nationals from other Member States. However, this is not expected to
be at a level that would require additional investments.
3.17.3. Adjustment costs savings for citizens (vehicle owners)
In PM8, after a PTI certificate is issued in other EU MS than that of the MS of registration, the next
PTI needs to be conducted in the MS of registration. Therefore, in PM8 it is assumed that the transport
activity avoided is half of that in PM7. All other assumptions used for the estimation of costs savings
are the same as in PM7. The recurrent adjustment cost savings for citizens are estimated at EUR
363
Source: www.engineeringtoolbox.com on the distance among EU cities across the EU and took the median value
among all pairs.
364
Source: https://www.eurodev.com/blog/mileage-reimbursement-in-europe-2022
169
110.7 million in 2026, EUR 114.1 million in 2030 and EUR 127.4 million in 2050. Expressed as
present value over 2026-2050, the cost saving amount to EUR 2.1 billion relative to the baseline.
The total cost savings for citizens (vehicle owners) due to PM8 are summarised in the tables below.
Table 134: Adjustment costs savings for citizens (vehicle owners) due to PM8 in 2026, 2030, 2040 and 2050 in
policy options PO1b and PO2 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Adjustment costs savings for citizens 110.7 114.1 123.9 127.4
Source: Ricardo et al. (2024), Impact assessment support study
Table 135: Adjustment costs savings for citizens (vehicle owners) due to PM8 in PO1b and PO2, expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs savings for citizens 2,144.6 2,144.6
Source: Ricardo et al. (2024), Impact assessment support study
3.18. PM9 - PTI in another MS recognised by MS of registration based on bilateral agreements
This measure would require that the PTI certificate issued in any other EU MS is recognised by the
MS of registration on the basis of bilateral agreements.
3.18.1. Adjustment costs for national public authorities
National authorities will incur costs associated with establishing bilateral agreements, modifying
national law as required and implementing procedures to facilitate inspections in another Member
State. PM9 is expected to lead to one-off adjustment costs, mainly for designing the bilateral
agreements. It is not expected that agreements will be signed among all pairs of Member states.
Assuming that each Member State establishes three bilateral agreements, a total number of 41
agreements would be established365
. Total one-off adjustment costs are estimated at EUR 1.4 million
in 2026 (EUR 35,265 per agreement or EUR 53,550 per Member State), expressed in 2022 prices.
The estimation is based on the bilateral agreements already in place between the Netherlands and
Spain, as well as between the Netherlands and Belgium.
The total adjustment costs for national public authorities due to PM9 are summarised in the tables
below.
Table 136: Adjustment costs for national public authorities due to PM9 in 2026, 2030, 2040 and 2050 in policy
option PO1a relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
One-off adjustment costs for setting up
bilateral agreements
1.4 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
365
The total number of agreements is derived by multiplying the number of agreements by MS with the total number of
MS and dividing by 2.
170
Table 137: Adjustment costs for national public authorities due to PM9 in PO1a expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
One-off adjustment costs for setting up
bilateral agreements
1.4
Source: Ricardo et al. (2024), Impact assessment support study
3.18.2. Adjustment cost savings for citizens (vehicle owners)
The cost savings for citizens (vehicle owners) due to the bilateral agreements, as a result of avoided
travel costs for performing the PTI tests, are estimated at EUR 1.19 million per bilateral agreement
(expressed in 2022 prices)366
. Considering the 41 bilateral agreements assumed to be signed, the total
recurrent adjustment costs savings are estimated at EUR 49 million per year from 2026 onwards.
Expressed as present value over 2026-2050, they are estimated at EUR 878.2 million relative to the
baseline.
The total cost savings for citizens (vehicle owners) expected as a result of PM9 are summarised in
the tables below.
Table 138: Adjustment costs savings for citizens (vehicle owners) due to PM9 in 2026, 2030, 2040 and 2050 in
policy option PO1a relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent adjustment costs savings
for citizens
49.0 49.0 49.0 49.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 139: Adjustment costs savings for citizens (vehicle owners) due to PM9 in PO1a, expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent adjustment costs savings
for citizens
878.2
Source: Ricardo et al. (2024), Impact assessment support study
3.19. PM10 - More advanced testing of noise for motorcycles
PM10 requires that all Member States perform noise testing for motorcycles at PTI, inspired by the
procedure for pass-by noise test described in the UN Regulation no. 41. Few MSs (DE, ES, HR and
SK) are already measuring L-vehicles noise emissions at PTI.
3.19.1. Adjustment costs for PTI centres
For the calculation of the adjustment costs incurred by the PTI centres it is assumed that only the
proportion of PTI centres with a test track will be concerned by the measure.
The number of PTI centres with a test track is estimated by applying the projected share of L3-L4
vehicles in the total vehicle stock in 2026 (i.e., 6.2%)367
to the total number of PTI centres in the
366
Europe Economics (2011), Report of contribution to impact assessment of policy options to improve the EU system
of PTI and of roadside vehicle testing
367
The projected vehicles stock is based on the baseline projections from the PRIMES-TREMOVE model.
171
affected MS. Thus, 2,827 inspection centres are estimated to have a test track, out of the total of
45,585 PTI centres in the affected MS (excluding DE, ES, HR and SK).
The cost for purchasing a noise measurement device is estimated at EUR 800 per device (i.e., the
average of the estimates provided by stakeholders, that is between EUR 600 and EUR 1,000), and 2
devices are assumed to be needed for each PTI centre with a test track. Thus, the total one-off
adjustment costs for the purchase of new equipment are estimated at EUR 4.5 million in 2026.
Recurrent adjustment costs for the maintenance and calibration of devices are assumed at 5% of the
capital cost, or EUR 226,160 per year from 2026 onwards. Expressed as present value over 2026-
2050, the recurrent adjustment costs for equipment are estimated at EUR 4.1 million relative to the
baseline.
The additional noise testing will imply longer PTI sessions and for this reason would result in
additional labour costs for the PTI centres. It is assumed that the noise measurement takes around 15
minutes, and the hourly cost is EUR 34 for technicians and associate professionals (ISCO 3). The
number of noise tests is estimated at 6.9 million in 2026, 7.2 million in 2030 and 8.6 million in 2050.
The recurrent adjustment costs are estimated at EUR 58.6 million in 2026, EUR 61.6 million in 2030
and EUR 73.4 million in 2050. Expressed as present value over 2026-2050, they are estimated at
EUR 1.2 billion.
The number of additional inspectors that need to be trained for performing the noise testing is
estimated at 1,575 in 2026. They are estimated based on the projected number of additional noise
tests and the average number of PTIs per inspector (i.e., 4,380). Assuming half a day of training, at
an hourly cost of EUR 34 for technicians and associate professionals (ISCO 3)368
, the total one-off
adjustment costs for training are estimated at EUR 194,834 in 2026.
The total adjustment costs for PTI centres expected due to PM10 are summarised in the tables
below.
Table 140: Adjustment costs for PTI centres due to PM10 in 2026, 2030, 2040 and 2050 in policy options PO1b,
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 63.6 61.8 66.4 73.7
One-off costs for equipment 4.5 0.0 0.0 0.0
Recurrent costs for equipment 0.2 0.2 0.2 0.2
Recurrent labour costs for inspections 58.6 61.6 66.2 73.4
One-off costs for training 0.2 0.0 0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 141: Adjustment costs for PTI centres due to PM10 in PO1b, PO2 and PO3, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 1,170.6 1,170.6 1,170.6
One-off costs for equipment 4.5 4.5 4.5
Ongoing costs for equipment 4.1 4.1 4.1
Ongoing costs for additional staff 1,161.8 1,161.8 1,161.8
One-off costs for training 0.2 0.2 0.2
Source: Ricardo et al. (2024), Impact assessment support study
368
Data Sources: Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs
172
3.19.2. Costs for vehicle owners
Depending on the Member State, the additional costs for the PTI centres may be passed through to
vehicle owners (i.e., citizens). As indicated under PMC1, this will depend on the way PTI charges
are set in the Member State.
The limitation to PTI centres equipped with a test track will mean that some vehicle’ owners will
have to travel further than to the closest PTI centre, which means higher costs in terms of time spent
for PTI and fuel consumed to get to the testing location. However, these costs are not expected to be
significant.
Owners of faulty L3-L4 vehicles will face a charge for repairing the non-compliant vehicles.
However, this is not considered to be regulatory costs but is relevant in terms of the impact on
maintenance costs.
3.20. PM11 - Data governance: further define the procedures and the means of access to vehicle
technical information by testing centres free of charge
PM11 is expected to result in one-off administrative costs for national public authorities and OEMs
for adapting the IT systems and their interconnection. This could for instance concern the testing
centres that are not digitally connected yet. Additional recurrent administrative costs are expected to
maintain the IT systems.
According to EUCARIS, using the same procedure as for the exchange of eCoC data369
could reduce
additional costs but costs are still expected during the transition. ACEA expects costs similar to the
introduction of Commission Implementing Regulation (EU) 2019/621 for PM11. EReg mentioned
costs for PTI centres that are not digitally connected, with varying impacts by Member State, and
negligible costs for those already digitally connected.
3.20.1. Administrative costs for national public authorities
Based on the NL and SI case studies and stakeholders’ interviews, the one-off cost for the adaptation
of the IT system is estimated at EUR 300,000 to EUR 1,000,000 per country, depending on the
volume of PTI inspections per country. Assuming one-off costs of EUR 300,000 per IT system for
each of the 15 Member States with smaller volumes of inspections370
, EUR 500,000 per IT system
for each of the 7 Member States with medium volumes of inspections371
and EUR 1,000,000 per IT
system for each of the 5 Member States with higher volumes of inspections372
, the total one-off
administrative costs at EU27 level are estimated at EUR 13 million in 2026. Recurrent administrative
costs for maintenance are estimated at around 10% of the capital costs, or EUR 1.3 million per year
from 2026 onwards. Expressed as present value over 2026-2050, the recurrent administrative costs
are estimated at EUR 23.3 million relative to the baseline.
369
EUR-Lex - 32021R0133 - EN - EUR-Lex (europa.eu)
370
Below 2% of the total number of inspections at EU level in 2026 by Member State. These are: BG, CY, EE, FI, HR,
HU, IE, LT, LV, LU, MT, SI, SK, DK and CZ.
371
Between 2% and 10% of the total number of inspections at EU level in 2026 by Member State. These are: AT, BE,
EL, NL, PT, RO and SE.
372
Above 10% of the total number of inspections at EU level in 2026 by Member State. These are: DE, FR, IT, PL and
ES.
173
Table 142: Administrative costs for national public administrations due to PM11 in 2026, 2030, 2040 and 2050 in
policy options PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 14.3 1.3 1.3 1.3
One-off costs for IT systems 13.0 0.0 0.0 0.0
Recurrent costs for maintenance of the IT systems 1.3 1.3 1.3 1.3
Source: Ricardo et al. (2024), Impact assessment support study
Table 143: Administrative costs for national public administrations due to PM11 in PO2 and PO3, expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 36.3 36.3
One-off costs for IT systems 13.0 13.0
Recurrent costs for maintenance of the IT systems 23.3 23.3
Source: Ricardo et al. (2024), Impact assessment support study
3.20.2. Administrative costs for OEM
OEMs will also need to make adjustments to their own IT systems to ensure access to the relevant
data. According to one manufacturer, the one-off costs are expected to be around EUR 1 million per
OEM. The total one-off administrative costs are estimated at EUR 20 million in 2026 for the 20
OEMs in the EU.
Recurrent administrative costs are estimated at 10% of the capital costs or EUR 100,000 per OEM.
For the 20 OEMs, they amount to EUR 2 million per year from 2026 onwards. Expressed as present
value over 2026-2050, they are estimated at EUR 35.9 million relative to the baseline.
Table 144: Administrative costs for OEMs due to PM11 in 2026, 2030, 2040 and 2050 in policy options PO2 and
PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 22.0 2.0 2.0 2.0
One-off costs for IT systems 20.0 0.0 0.0 0.0
Recurrent costs for maintenance of the IT systems 2.0 2.0 2.0 2.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 145: Administrative costs for OEMs due to PM11 in PO2 and PO3, expressed as present value over 2026-
2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 55.9 55.9
One-off costs for IT systems 20.0 20.0
Recurrent costs for maintenance of the IT systems 35.9 35.9
Source: Ricardo et al. (2024), Impact assessment support study
3.20.3. Administrative costs for PTI centres
For PTI centres, the one-off administrative costs for the adaptation of the IT systems are estimated at
EUR 1,000 per centre. Total one-off administrative costs would amount to EUR 48.9 million in 2026,
for the 48,880 PTI centres across the EU.
Recurrent administrative costs for the maintenance of the IT systems are estimated at 10% of the
capital costs, or EUR 100 per PTI centre. Total recurrent administrative costs are estimated at EUR
174
4.9 million per year from 2026 onwards, or EUR 87.7 million expressed as present value over 2026-
2050 relative to the baseline.
Table 146: Administrative costs for PTI centres due to PM11 in 2026, 2030, 2040 and 2050 in policy options PO2
and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 53.8 4.9 4.9 4.9
One-off costs for IT systems 48.9 0.0 0.0 0.0
Recurrent costs for maintenance of the IT systems 4.9 4.9 4.9 4.9
Source: Ricardo et al. (2024), Impact assessment support study
Table 147: Administrative costs for PTI centres due to PM11 in PO2 and PO3, expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 136.5 136.5
One-off costs for IT systems 48.9 48.9
Recurrent costs for maintenance of the IT systems 87.7 87.7
Source: Ricardo et al. (2024), Impact assessment support study
3.20.4. Administrative cost savings for PTI centres
The access to relevant technical information is also expected to bring some limited time savings for
PTI centres. Time savings of 3 minutes are assumed per PTI. This represents 10% of the average of
30 minutes per PTI for a passenger car. No potential for higher time saving per inspection is estimated
due to PM11 because most of the time during a PTI is allocated to the visual inspection or the
emissions and other testing. Furthermore, not all PTI centres are expected to benefit of this measure,
as access to relevant information is often already available. It is expected that only 30% of PTIs
would benefit of PM11. Assuming an average cost per hour for technicians and associate
professionals (ISCO level 3) of EUR 34, the recurrent administrative costs savings for PTI centres
are estimated at EUR 84.1 million in 2026, EUR 87.1 million in 2030 and EUR 99.3 million in 2050.
Expressed as present value over 2026-2050, they amount to EUR 1.6 billion relative to the baseline.
Table 148: Administrative costs savings for PTI centres due to PM11 in 2026, 2030, 2040 and 2050 in policy options
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs savings 84.1 87.1 94.8 99.3
Source: Ricardo et al. (2024), Impact assessment support study
Table 149: Administrative costs savings for PTI centres due to PM11 in PO2 and PO3, expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs savings 1,643.4 1,643.4
Source: Ricardo et al. (2024), Impact assessment support study
3.21. PM12 – NOx, PM, and noise measurement by remote sensing in RSI of all vehicles (with
option for simplified PTI if vehicle passed recent RSI)
PM12 (included in PO1b, PO2 and PO3) requires NOx, PM, and noise measurement by remote
sensing in technical roadside inspections of all vehicle types, and optional plume chasing in technical
roadside inspections of commercial vehicles. It also includes the option for simplified PTI (i.e., no
emission/noise testing) if the vehicle passed a recent RSI (including by remote sensing).
175
The introduction of this measure will require the purchase, maintenance and periodic calibration of
remote sensing equipment (for NOx and PM) and acoustic camera equipment by national public
authorities. It will also imply additional costs for vehicles and testing equipment for the plume
chasing option, as well as costs for training of inspectors to use the new equipment. In addition, it
will also imply some extra costs for additional emissions tests for the owners of vehicles (businesses
or citizens) identified as high emitters by the remote sensing or plume chasing measurements and
some extra adjustment costs for the PTI centres that will need to deliver these additional tests.
On the other hand, PM12 is expected to lead to costs savings for citizens and businesses (vehicle
owners) that successfully pass the remote sensing or plume chasing measurement by avoiding some
costs associated with PTI.
3.21.1. Adjustment costs for national public authorities
Remote sensing
Roadside inspection authorities are expected to incur costs for the purchase of remote sensing
equipment for measuring NOx and PM emissions of all vehicle types. 250 remote sensing devices
would be needed in EU27 to be able to analyse via remote sensing at least 30% of the road fleet373
.
The capital cost of a remote sensing equipment, based on stakeholders’ consultation, is assumed at
EUR 85,000. In addition, maintenance and calibration costs are assumed at 5% of the capital costs,
and the cost for the processing and data management at EUR 24,000 per year per device.
The total one-off adjustment costs for remote sensing equipment are thus estimated at EUR 21.3
million in 2026. Recurrent adjustment costs for maintenance and calibration, and for the processing
and data management are estimated at EUR 7.1 million from 2026 onwards. Expressed as present
value over 2026-2050, recurrent adjustment costs amount to EUR 126.7 million relative to the
baseline.
In addition, one day of training for the use of NOx and PM remote sensing equipment is assumed for
the 393 RSI inspectors. With an hourly cost for technicians and associate professionals (ISCO 3) of
EUR 34/hour374
, and assuming 7.3 working hours per day, the one-off adjustment costs for training
are estimated at EUR 97,231 in 2026.
Plume chasing (optional)
PM12 gives the possibility of implementing plume chasing to measure NOx and PM emissions of
HDVs (from Euro VI). The cost of plume chasing equipment is assumed at EUR 32,500 per
equipment, based on input from stakeholders. Assuming on average two equipped vehicles per
Member State for 26 Member States (Denmark has already implemented the system), the one-off
adjustment costs are estimated at EUR 1.7 million in 2026.
The maintenance and calibration costs are assumed at EUR 1,625 per equipment per year (5% of the
capital cost), based on inputs from stakeholders, resulting in total maintenance costs of EUR 84,500
per year from 2026 onwards for the 26 Member States relevant for PM13 (excluding Denmark). In
addition, labour costs are estimated assuming one inspector per plume chasing vehicle and four days
373
Hooftman N., Ligterink N., Bhoraskar, A., (2020) Analysis of the 2019 Flemish remote sensing campaign.
Commissioned by the Flemish Government - Flanders Environment Agency - Team Air quality policy
374
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
176
per week of plume chasing375
. Considering on average 44 working weeks per year and an hourly cost
for technicians and associate professionals (ISCO 3) of EUR 34/hour, the total labour costs are
estimated at EUR 2.26 million per year from 2026 onwards. Thus, total recurrent adjustment costs
for maintenance of equipment and labour costs amount to EUR 2.3 million per year from 2026
onwards, or EUR 42.1 million expressed as present value over 2026-2050.
In addition, two days of training are assumed for the 52 inspectors. With an hourly cost for technicians
and associate professionals (ISCO 3) of EUR 34/hour376
, and assuming 7.3 working hours per day,
the one-off adjustment costs for training are estimated at EUR 25,730.
Acoustic cameras
Acoustic cameras would need to be added to remote sensing equipment to measure noise at the
roadside. The one-off cost per acoustic camera is assumed at EUR 2,000377
, and the maintenance cost
at 5% of the capital cost. Thus, total one-off adjustment costs for equipment are estimated at EUR
500,000 in 2026 and the recurrent adjustment costs at EUR 25,000 per year from 2026 onwards.
Expressed as present value over 2026-2050, the recurrent adjustment costs for acoustic cameras are
estimated at EUR 448,389.
In addition, a half-day training would be needed for 393 RSI inspectors, for using the acoustic
cameras. The one-off adjustment costs for training are estimated at EUR 48,616.
The total adjustment costs for national public authorities expected due to PM12 are summarised in
the tables below.
Table 150: Adjustment costs for national public authorities due to PM12 in 2026, 2030, 2040 and 2050 in policy
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 33.0 9.4 9.4 9.4
One-off costs for remote sensing equipment 21.3 0.0 0.0 0.0
Recurrent costs for maintenance and data
management for remote sensing equipment
7.1 7.1 7.1 7.1
One-off costs for plume chasing equipment 1.7 0.0 0.0 0.0
Recurrent costs for maintenance and staff for
plume chasing equipment
2.3 2.3 2.3 2.3
One-off costs for acoustic cameras 0.5 0.0 0.0 0.0
Recurrent maintenance costs for acoustic cameras 0.03 0.03 0.03 0.03
One-off costs for training (for remote sensing, plume
chasing and acoustic cameras)
0.2 0.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 151: Adjustment costs for national public authorities due to PM12 in PO1b, PO2 and PO3 expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 192.9 192.9 192.9
One-off costs for remote sensing equipment 21.3 21.3 21.3
Recurrent costs for maintenance and data
management for remote sensing equipment
126.7 126.7 126.7
375
Four days per week of plume chasing, with an average of 44 working weeks per year, and 52 vehicles at a rate of 25
unique licence plates measured per day, would cover around 3% of the HDVs fleet in the 26 MS relevant for PM12.
376
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
377
Average of the stakeholders’ input, ranging between EUR 1,000 and EUR 3,000 per device.
177
Difference to the baseline
PO1a PO1b PO2 PO3
One-off costs for plume chasing equipment 1.7 1.7 1.7
Recurrent costs for maintenance and staff for
plume chasing equipment
42.1 42.1 42.1
One-off costs for acoustic cameras 0.5 0.5 0.5
Recurrent maintenance costs for acoustic cameras 0.4 0.4 0.4
One-off costs for training 0.2 0.2 0.2
Source: Ricardo et al. (2024), Impact assessment support study
3.21.2. Administrative costs for citizens (vehicle owners)
The remote sensing is expected to lead to an identification of a share of high emitters among M1
internal combustion engine (ICE) vehicles. The results will need to be verified via roadside
inspections (limited to 0.5% of the fleet) or sent for extra emissions tests in PTI centres. Owners of
these M1 vehicles - around 40% of which are citizens - will incur costs for these additional emissions
tests. These have been estimated to be around 0.86% of the internal combustion engine vehicles
fleet378
. Considering the fee for an emission test at 20% of the total PTI fee for an M1 vehicle (EUR
41.7), the cost per extra emission test is estimated at EUR 8.3. The recurrent administrative costs for
citizens are estimated at EUR 6.5 million in 2026, EUR 5.8 million in 2030 and EUR 0.3 million in
2050. The costs decrease over time as the share of zero-emission vehicles increases over time in the
baseline scenario. Expressed as present value over 2026-2050, the administrative costs for the citizens
are estimated at EUR 72.2 million relative to the baseline.
Table 152: Administrative costs for citizens due to PM12 in 2026, 2030, 2040 and 2050 in policy options PO1b,
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Extra PTI emission tests following the identification of high
emitters by remote sensing
781,040 713,217 340,538 40,325
Recurrent administrative costs (in million EUR) 6.5 5.8 2.8 0.3
Source: Ricardo et al. (2024), Impact assessment support study
Table 153: Administrative costs for citizens due to PM12 in PO1b, PO2 and PO3 expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 72.2 72.2 72.2
Source: Ricardo et al. (2024), Impact assessment support study
3.21.3. Administrative costs for businesses (vehicle owners)
Similar to citizens, business that own M1, N1 and heavy duty vehicles will incur extra costs for
emissions testing if the vehicles are identified as high emitters via the use of remote sensing or plume
chasing and are sent for PTI due to the 0.5% limit in the capacity for roadside inspections. It is
estimated that, on average, 0.86% of the M1 internal combustion engine vehicles will need an extra
emission test, 1.62% of the N1 internal combustion engine vehicles and 1.26% of the heavy duty
(N2/N3/M2/M3) internal combustion engine vehicles379
. Assuming that an emission test will cost
20% of the full PTI fee per vehicle (EUR 41.7 for M1, EUR 40.5 for N1, EUR 61.6 for N2/N3 and
EUR 70.8 for M2/M3) and the fact that around 60% of M1 vehicles and 100% of N1, N2/N3 and
M2/M3 vehicles are owned by businesses, the recurrent administrative costs for businesses are
378
More explanations are provided in section 4.2.12 of Annex 4.
379
More explanations are provided in section 4.2.12 of Annex 4.
178
estimated at EUR 14.8 million in 2026, EUR 14.0 million in 2030 and EUR 1.2 million in 2050.
Expressed as present value over 2026-2050, they are estimated at EUR 175 million relative to the
baseline.
Table 154: Administrative costs for businesses due to PM12 in 2026, 2030, 2040 and 2050 in policy options PO1b,
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Extra PTI emission tests following the identification of
high emitters by remote sensing or plume chasing, of
which:
1,748,404 1,644,389 858,688 134,284
for HDVs 88,279 89,827 71,883 33,635
for LDVs 1,660,125 1,554,562 786,805 100,649
Recurrent administrative costs (in million EUR) 14.8 14.0 7.4 1.2
Source: Ricardo et al. (2024), Impact assessment support study
Table 155: Administrative costs for businesses due to PM12 in PO1b, PO2 and PO3 expressed as present value
over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 0.0 175.0 175.0 175.0
Source: Ricardo et al. (2024), Impact assessment support study
3.21.4. Administrative costs savings for citizens (vehicle owners)
In PM12, passing a remote sensing test allows a simplified PTI for vehicle owners within the
following 6 months. This is expected to result in administrative costs savings related to inspections,
as they do not have to undertake the emissions and/or noise tests.
The emissions and noise tests represent a relatively small share of the total charge for an inspection,
estimated at around 20% of the total PTI fee380
. Around 30% of the EU fleet would be subject to
remote sensing in PM12 and it is assumed that a share of non high emitters (90% on average for M1
vehicles) that go through a remote sensing test would benefit of costs savings. Using the estimated
numbers of PTI tests per year for M1 vehicles that are not high emitters and pass a remote sensing,
half of them is assumed to benefit from the measure (i.e., those that are expected to go through a PTI
within six months). In addition, it is assumed that around 40% of the M1 vehicles are owned by
citizens. Thus, the number of PTI emission/noise tests avoided by citizens due to PM12 is estimated
at 6.4 million in 2026, 5.8 million in 2030 and 329,684 in 2050. The reason for the decreasing number
of PTI tests avoided over time is the increasing share of zero-emission vehicles in the baseline
scenario. Based on the charge per PTI test381
and the share of costs saved (i.e., 20% as explained
above), the recurrent administrative costs savings for citizens are estimated at EUR 53.4 million in
2026, EUR 48.8 million in 2030 and EUR 2.8 million in 2050. Expressed as present value over 2026-
2050, they are estimated at EUR 591.9 million relative to the baseline.
Table 156: Administrative costs savings for citizens due to PM12 in 2026, 2030, 2040 and 2050 in policy options
PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Number of PTI emission and noise tests
avoided
6,396,137 5,848,537 2,788,026 329,684
380
Based on the analysis of the PTI charges available.
381
The median PTI charge at EU level for M1 vehicles is EUR 41.7 per PTI.
179
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative costs savings (in
million EUR)
53.4 48.8 23.3 2.8
Source: Ricardo et al. (2024), Impact assessment support study
Table 157: Administrative costs savings for citizens due to PM12 in PO1b, PO2 and PO3 expressed as present
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs
savings
591.9 591.9 591.9
Source: Ricardo et al. (2024), Impact assessment support study
3.21.5. Administrative costs savings for businesses (vehicle owners)
Similar to citizens, in PM12 passing a remote sensing test allows a simplified PTI for businesses (i.e.,
vehicle owners) within the following 6 months. This is expected to result in administrative costs
savings related to inspections, as they do not have to undertake the emissions and noise tests.
The emissions and noise tests represent a relatively small share of the total fee for an inspection,
estimated at around 20% of the total PTI charge382
. Around 30% of the EU fleet would be subject to
remote sensing in PM12 and it is assumed that a share of non high emitters (90% on average for M1
and N1 vehicles and 85% on average for N2-N3 and M2-M3 vehicles) that go through a remote
sensing test would benefit of costs savings. Using the estimated numbers of PTI tests per year for
LDVs and HDVs that are not high emitters and pass a remote sensing, half of them is assumed to
benefit from the measure (i.e., those that are expected to go through a PTI within six months). In
addition, it is assumed that around 60% of the M1 vehicles are owned by businesses, and 100% of
the N1, N2-N3 and M2-M3 vehicles. Thus, the number of PTI emission/noise tests avoided by
businesses due to PM12 is estimated at 12.7 million in 2026, 11.9 million in 2030 and EUR 1 million
in 2050. The reason for the decreasing number of PTI tests avoided over time is the increasing share
of zero-emission vehicles in the baseline scenario. Based on the charge per PTI test383
and the share
of costs saved (i.e., 20% as explained above), the recurrent administrative costs savings for businesses
are estimated at EUR 109.4 million in 2026, EUR 102.6 million in 2030 and EUR 10.1 million in
2050. Expressed as present value over 2026-2050, they are estimated at EUR 1.3 billion relative to
the baseline.
Table 158: Administrative costs savings for businesses due to PM12 in 2026, 2030, 2040 and 2050 in policy options
PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Number of PTI emission and noise tests avoided,
of which:
12,689,889 11,863,044 6,166,765 1,032,002
for HDVs 956,206 969,249 768,250 359,122
for LDVs 11,733,683 10,893,795 5,398,515 672,880
Recurrent administrative costs savings (in
million EUR)
109.4 102.6 54.4 10.1
Source: Ricardo et al. (2024), Impact assessment support study
382
Based on the analysis of the PTI charges available.
383
The median PTI charge at EU level for M1 vehicles is EUR 41.7 per PTI, for N1 vehicles EUR 40.5 per PTI, for
N2/N3 EUR 61.6 and for M2/M3 EUR 70.8 per PTI.
180
Table 159: Administrative costs savings for businesses due to PM12 in PO1b, PO2 and PO3 expressed as present
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs
savings
1,287.3 1,287.3 1,287.3
Source: Ricardo et al. (2024), Impact assessment support study
3.21.6. Adjustment costs for PTI centres
The additional emission tests for internal combustion vehicles (M1, N1, N2/N3 and M2/M3) due to
PM12 (i.e. vehicles that are found as high emitters during remote sensing or plume chasing and are
sent for emission test in a PTI centre) are estimated at 2.5 million in 2026, 2.4 million in 2030 and
174,609 in 2050 relative to the baseline384
. The decrease in the number of emission testing is driven
by the increase in the number of zero-emission vehicles over time in the baseline.
PM12 is expected to lead to recurrent adjustment costs for the PTI for the additional emissions tests.
Due to the small share of the fleet affected it is assessed that no additional emission testing equipment
will be needed and that the available PTI lanes will be able to serve the additional demand. As such,
the only additional costs concern the labour costs for inspectors.
Combined, the average duration of new PN and NOx emission tests is estimated at around 6 minutes.
The labour costs per emission testing are estimated at EUR 3.4, assuming an hourly cost of EUR 34
for technicians and associate professionals (ISCO 3). To deliver the estimated additional number of
emission testing, the recurrent adjustment costs are estimated at EUR 8.6 million in 2026, EUR 8.0
million in 2030 and EUR 0.6 million in 2050385
. Expressed as present value over 2026-2050, they
are estimated at EUR 99 million relative to the baseline.
Table 160: Adjustment costs for PTI centres due to PM12 in 2026, 2030, 2040 and 2050 in policy options PO1b,
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of tests 2,529,443 2,357,606 1,199,226 174,609
Recurrent adjustment costs (in million EUR) 8.6 8.0 4.1 0.6
Source: Ricardo et al. (2024), Impact assessment support study
Table 161: Adjustment costs for PTI centres due to PM12 in PO1b, PO2 and PO3 expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent adjustment costs 99.0 99.0 99.0
Source: Ricardo et al. (2024), Impact assessment support study
3.21.7. Benefits for PTI centres
PM12 would also result in benefits for the PTI centres due to the vehicles that are found as high
emitters during remote sensing or plume chasing and are sent for emission test in a PTI centre. The
costs for vehicle owners (citizens and businesses) discussed above represent revenues for the PTI
384
The number of inspections is estimated based on the projected number of internal combustion engine vehicles from
the baseline scenario, developed with the PRIMES-TREMOVE model, and the estimated share of vehicles identified as
high emitters using remote sensing or plume chasing (for HDVs) and not checked via roadside inspections (0.86% for
M1, 1.62% for N1 and 1.26% for N2/N3 and M2/M3 vehicles).
385
The labour costs decrease over time due to the decreasing number of internal combustion engine vehicles.
181
centres. The total revenues for PTI centres due to PM12 are estimated at EUR 21.4 billion in 2026,
EUR 19.7 billion in 2030 and EUR 1.6 billion in 2050. Expressed as present value over 2026-2050,
they are estimated at EUR 247.2 billion relative to the baseline.
Table 162: Benefits for PTI centres due to PM12 in 2026, 2030, 2040 and 2050 in policy options PO1b, PO2 and
PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Revenues for PTI centres 21.4 19.7 10.2 1.6
Source: Ricardo et al. (2024), Impact assessment support study
Table 163: Benefits for PTI centres due to PM12 in PO1b, PO2 and PO3 expressed as present value over 2026-
2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Revenues for PTI centres 247.2 247.2 247.2
Source: Ricardo et al. (2024), Impact assessment support study
3.22. PM13 – Mandatory inspection of cargo securing
PM13 introduces mandatory standards in relation to cargo securing inspections. Currently 5 Member
States (EE, FR, IE, LV and LU) do not require either minimum training or specify test requirements
relating to cargo securing during RSI in their national transposition of Directive 2014/47/EC. N2 and
N3 vehicles in these Member States represent around 13% of the EU-wide fleet. 14 Member States386
,
covering 67% of the N2/N3 fleet, do not specify minimum training requirements for cargo securing.
3.22.1. Adjustment costs for national public authorities
PM13 is expected to lead to one-off adjustment costs for national public authorities for training in
the 14 MS which currently do not require minimum training of inspectors. Training for cargo securing
is assumed to take 3 hours, with 264 roadside inspectors requiring training. Assuming an hourly cost
for technicians and associate professionals (ISCO 3) of EUR 34/hour387
, the total one-off adjustment
costs for training are estimated at EUR 26,916 in 2026.
In addition, retraining of inspectors is foreseen on a biennial basis. Assuming 3 hours of training for
the 264 roadside inspectors, the recurrent adjustment costs for training are estimated at EUR 26,916
per year every second year after 2026. Expressed as present value over 2026-2050, they are estimated
at EUR 224,549.
3.22.2. Administrative costs for national public authorities
Recurrent administrative costs are expected for national public authorities, covering the labour costs
for the additional cargo securing inspections. It is assumed that Member States that do not have in
place minimum testing requirements for cargo securing do not perform cargo securing inspections.
Based on stakeholders’ interviews, a cargo securing inspection takes on average 20 minutes. Cargo
securing inspections are expected to cover 5% of the N2/N3 fleet in the Member States affected by
the measure (EE, FR, IE, LV, LU). Assuming an hourly cost for technicians and professionals (ISCO
3) of EUR 34/hour388
, the recurrent administrative costs for national public authorities in the 5
Member States are estimated at EUR 0.48 million in 2026, EUR 0.51 million in 2030 and EUR 0.63
386
BE, DK, DE, EE, FR, IE, LV, LU, BG, FI, IT, NL, PL and PT.
387
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
388
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
182
million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 9.8 million
relative to the baseline.
Table 164: Adjustment and administrative costs for national public authorities due to PM13 in 2026, 2030, 2040
and 2050 in policy options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total adjustment costs 0.03 0.03 0.03 0.03
One-off costs for training 0.03 0.00 0.00 0.00
Recurrent costs for training 0.00 0.03 0.03 0.03
Recurrent administrative costs 0.48 0.51 0.57 0.63
Source: Ricardo et al. (2024), Impact assessment support study
Table 165: Adjustment and administrative costs for national public authorities due to PM13 in PO1b, PO2 and
PO3 expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 0.25 0.25 0.25
One-off costs for training 0.03 0.03 0.03
Recurrent costs for training 0.22 0.22 0.22
Recurrent administrative costs 9.84 9.84 9.84
Source: Ricardo et al. (2024), Impact assessment support study
3.22.3. Administrative costs for businesses (vehicle owners)
From the vehicle owner point of view, there will be some extra cost for the additional time for
cooperating on the cargo securing inspections. Considering an average hourly labour cost of EUR
21.9 for drivers389
, the average time per inspection (20 minutes) and the number of roadside
inspections, the recurrent administrative costs for businesses (vehicle owners) are estimated at EUR
0.42 million in 2026, EUR 0.44 million in 2030 and EUR 0.55 million in 2050. Expressed as present
value over 2026-2050, they are estimated at EUR 8.5 million relative to the baseline.
Table 166: Administrative costs for businesses (vehicle owners) due to PM13 in 2026, 2030, 2040 and 2050 in policy
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Number of additional inspections 42,477 44,813 50,414 55,526
Recurrent administrative costs (in million
EUR)
0.42 0.44 0.50 0.55
Source: Ricardo et al. (2024), Impact assessment support study
Table 167: Administrative costs for businesses (vehicle owners) due to PM13 in PO1b, PO2 and PO3 expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 8.5 8.5 8.5
Source: Ricardo et al. (2024), Impact assessment support study
There may also be costs for subsequent adjustments following these inspections, which may result in
additional time and potential cost if the vehicle has to be taken to a garage for repair. These costs are
difficult to estimate, and they do not represent costs directly arising from the implementation of the
389
Part of ISCO 8 (Plant and machine operators and assemblers).
183
measure but are a consequence of the fact that specific vehicles may not be compliant with the
proposed minimum requirements.
3.23. PM14 - Extend the scope of application of roadside inspections to light commercial (N1)
vehicles
PM14 extends the scope of application of roadside inspections to N1 vehicles, and sets 2% as target
for the share of inspections of the N1 vehicle fleet. The extension of roadside inspections to cover
N1 vehicles is expected to lead to administrative costs for 22 Member States. On the basis of the
information available, few Member States (ES, HU, SE, SK and FI) already conduct roadside
inspections for N1 vehicles, although without a certain target set and thus checking a low number of
vehicles. For the purposes of the assessment it is assumed that these five Member States will not be
affected. To perform the inspections, additional roadside inspection units will be needed in the 22
Member States resulting in adjustment costs for national public authorities.
3.23.1. Administrative costs for national public authorities
Performing inspections for 2% of the N1 vehicle fleet in the Member States affected by PM14
translates into 479,626 additional inspections in 2026, 497,627 in 2030 and 588,721 additional
inspections in 2050. With an assumed average duration of 20 minutes per roadside inspection,
assuming an average wage of EUR 34 EUR/hour for ISCO 3 (technicians and associate
professionals), the cost per inspection is estimated at EUR 11.3. Thus, the total recurrent
administrative costs are estimated at EUR 5.4 million in 2026, EUR 5.6 million in 2030 and EUR 6.7
million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 107.5 million
relative to the baseline.
3.23.2. Adjustment costs for national public authorities
The extra inspections will be delivered by an estimated total of 182 inspectors390
in around 61
roadside inspection units (assuming three inspectors per roadside inspection unit). These units will
need to be equipped with relevant equipment. The one-off cost of the roadside equipment is around
EUR 50,000, and the maintenance cost is estimated at 10% of the capital cost. Thus, the total one-off
adjustment costs for the 61 roadside inspection units are estimated at EUR 3.1 million in 2026.
Recurrent adjustment costs amount at EUR 305,000 per year from 2026 onwards, or EUR 5.5 million
expressed as present value over 2026-2050.
Additional training costs may also arise for the additional inspectors. Assuming one-day training per
inspector and an average wage of EUR 34 EUR/hour for ISCO 3 (technicians and associate
professionals), the one-off adjustment costs for training are estimated at EUR 45,028 in 2026.
Table 168: Adjustment and administrative costs for national public authorities due to PM14 in 2026, 2030, 2040
and 2050 in policy options PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of inspections 479,626 497,627 547,848 588,721
Recurrent administrative costs 5.4 5.6 6.2 6.7
Total adjustment costs 3.4 0.3 0.3 0.3
One-off costs for equipment 3.1 0.0 0.0 0.0
Recurrent costs for equipment 0.3 0.3 0.3 0.3
390
Estimated assuming that each inspector performs roadside inspections on average 4 hours/day for a total of 220
days/year.
184
Difference to the baseline
2026 2030 2040 2050
One-off costs for training 0.05 0.00 0.00 0.00
Source: Ricardo et al. (2024), Impact assessment support study
Table 169: Adjustment and administrative costs for national public authorities due to PM14 in PO2 and PO3
expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 107.5 107.5
Total adjustment costs 8.6 8.6
One-off costs for equipment 3.1 3.1
Recurrent costs for equipment 5.5 5.5
One-off costs for training 0.05 0.05
Source: Ricardo et al. (2024), Impact assessment support study
3.23.3. Administrative costs for businesses (vehicle owners)
Business (vehicle owners) will incur some costs due to the time spent for cooperating on inspections.
Considering the average duration of 20 minutes per roadside inspection, and the average hourly
labour cost of EUR 21.9 for drivers391
, the recurrent administrative costs for businesses are estimated
at EUR 10.5 million in 2026, EUR 10.9 million in 2030 and EUR 12.9 million in 2050. Expressed as
present value over 2026-2050, they are estimated at EUR 208 million relative to the baseline.
There may also be costs for the repairs needed as a result of these inspections. These costs are difficult
to estimate and they do not represent costs directly arising from the implementation of the measure
but a consequence of the fact that the specific vehicles are non-compliant.
Table 170: Administrative costs for businesses (vehicle owners) due to PM14 in 2026, 2030, 2040 and 2050 in policy
options PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Number of additional inspections 479,626 497,627 547,848 588,721
Recurrent administrative costs (in million
EUR)
10.5 10.9 12.0 12.9
Source: Ricardo et al. (2024), Impact assessment support study
Table 171: Administrative costs for businesses (vehicle owners) due to PM14 in PO2 and PO3 expressed as present
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 208.0 208.0
Source: Ricardo et al. (2024), Impact assessment support study
3.24. PM15 - Extend the scope of application of roadside inspections to 2- and 3-wheeled
vehicles (L-vehicles from L3)
PM15 extends the scope of application of roadside inspections to 2- and 3-wheeled vehicles (L-
vehicles from L3) and establishes a threshold of 1% of the vehicle fleet for roadside inspections.
391
Part of ISCO 8 (Plant and machine operators and assemblers).
185
3.24.1. Administrative costs for national public authorities
The measure is expected to lead to additional costs for the enforcement authorities responsible for
roadside inspections. This will mainly cover the need to deploy more inspectors to conduct the
additional number of inspections, together with the additional mobile units needed to support the
increased number of roadside inspections. Few Member States (SE, SI, AT, FI, DK, HU, RO) already
perform such inspections although they do not report the exact number of inspections of motorcycles
separately and do not indicate a specific target. In the absence of more specific data it is assumed that
these Member States will not be affected by PM15.
Establishing a 1% threshold for roadside inspections of L3 vehicles for the 20 Member States would
result in 169,098 additional roadside inspections in 2026, 176,228 in 2030 and 227,291 additional
inspections in 2050. An average of 10 minutes per inspection is assumed. With an average wage of
EUR 34 EUR/hour for ISCO 3 (technicians and associate professionals), the cost per inspection is
estimated at EUR 5.7. The total recurrent administrative costs for inspections are estimated at EUR
0.96 million in 2026, EUR 1 million in 2030 and EUR 1.29 million in 2050. Expressed as present
value over 2026-2050, they are estimated at EUR 19.5 million relative to the baseline.
3.24.2. Adjustment costs for national public authorities
The additional volume of RSI will require the purchase of additional mobile inspection units to
support the extra inspections. On the basis of the additional number of inspections to be conducted it
is estimated that a total of 32 inspectors will be needed for the 20 Member States. With an average
of 3 inspectors per unit, each Member State will need a minimum of one additional set of roadside
equipment for testing of motorcycles. The one-off cost per equipment is estimated at EUR 20,000,
and the recurrent maintenance cost at 10% of the initial cost. Thus, the total one-off adjustment costs
amount to EUR 400,000 in 2026 and the recurrent adjustment costs at EUR 40,000 per year from
2026 onwards. Expressed as present value over 2026-2050, the recurrent adjustment costs are
estimated at EUR 717,422.
Additional training costs may also arise for the additional inspectors. Assuming one-day training per
inspector and an average wage of EUR 34 EUR/hour for ISCO 3 (technicians and associate
professionals), the one-off adjustment costs for training are estimated at EUR 7,917 in 2026 for the
32 inspectors.
Table 172: Adjustment and administrative costs for national public authorities due to PM15 in 2026, 2030, 2040
and 2050 in policy option PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Additional number of inspections 169,098 176,228 199,644 227,291
Recurrent administrative costs 0.96 1.00 1.13 1.29
Total adjustment costs 0.45 0.04 0.04 0.04
One-off costs for equipment 0.40 0.00 0.00 0.00
Recurrent costs for equipment 0.04 0.04 0.04 0.04
One-off costs for training 0.01 0.00 0.00 0.00
Source: Ricardo et al. (2024), Impact assessment support study
Table 173: Adjustment and administrative costs for national public authorities due to PM15 in PO3 expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 19.52
Total adjustment costs 1.13
One-off costs for equipment 0.40
186
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent costs for equipment 0.72
One-off costs for training 0.01
Source: Ricardo et al. (2024), Impact assessment support study
3.24.3. Administrative costs for citizens (vehicle owners)
Citizens (motorcycle owners) will incur some costs due to the time spent for cooperating on
inspections. Considering the average duration of 10 minutes per roadside inspection, and the average
hourly labour cost of EUR 29.5, the recurrent administrative costs for citizens are estimated at EUR
0.8 million in 2026, EUR 0.9 million in 2030 and EUR 1.1 million in 2050. Expressed as present
value over 2026-2050, they are estimated at EUR 16.9 million relative to the baseline.
There may also be costs for the repairs needed as a result of these inspections. These costs are difficult
to estimate and they do not represent costs directly arising from the implementation of the measure
but are a consequence of the fact that the specific vehicles are non-compliant.
Table 174: Administrative costs for citizens (vehicle owners) due to PM15 in 2026, 2030, 2040 and 2050 in policy
option PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Number of additional inspections 169,098 176,228 199,644 227,291
Recurrent administrative costs (in million
EUR)
0.8 0.9 1.0 1.1
Source: Ricardo et al. (2024), Impact assessment support study
Table 175: Administrative costs for citizens (vehicle owners) due to PM15 in PO3 expressed as present value over
2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative costs 16.9
Source: Ricardo et al. (2024), Impact assessment support study
3.25. PM16 - Introduce issuing the registration certificates in digital format to gradually
replace current paper (and smart card) documents
PM16 requires to issue the Registration Certificate (Annex I) for all vehicles types in digital format.
The measure is expected to lead to administrative costs for national public authorities for setting up
and operating the system, but also to administrative costs savings.
3.25.1. Administrative costs for national public authorities
Based on stakeholders’ interviews392
, the one-off cost for the adaptation of the IT system is estimated
at EUR 300,000 to EUR 1,000,000 per country, depending on the volume of new registrations.
Assuming one-off costs of EUR 300,000 per IT system for each of the 16 Member States with smaller
volumes of new registrations393
, EUR 500,000 per IT system for each of the 6 Member States with
392
Different agencies, such as the Centre for Vehicles of Croatia and the Norwegian Public Roads Administration,
anticipate various software and resource requirements, while DGT Spain foresees significant time and resource costs for
implementation. TÜV Rheinland expects additional IT development and management costs but considers them not
significant due to existing data availability.
393
Below 2% of the total number of new registrations at EU level in 2026 by Member State. These are: BG, CY, DK,
EE, FI, HR, HU, IE, LT, LV, LU, MT, PT, SE, SI and SK.
187
medium volumes of new registrations394
and EUR 1,000,000 per IT system for each of the 5 Member
States with higher volumes of new registrations395
, the total one-off administrative costs at EU27
level are estimated at EUR 12.8 million in 2026. Recurrent administrative costs for maintenance are
estimated at around 10% of the capital costs, or EUR 1.3 million per year from 2026 onwards.
Expressed as present value over 2026-2050, the recurrent administrative costs are estimated at EUR
23 million relative to the baseline. Since certain Member States (e.g. DE, ES, FI) have started to work
on the implementation of digital registration documents, the actual costs incurred by these Member
States may be lower than estimated here.
Table 176: Administrative costs for national public administrations due to PM16 in 2026, 2030, 2040 and 2050 in
policy options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 14.1 1.3 1.3 1.3
One-off costs for IT systems 12.8 0.0 0.0 0.0
Recurrent costs for maintenance of the IT systems 1.3 1.3 1.3 1.3
Source: Ricardo et al. (2024), Impact assessment support study
Table 177: Administrative costs for national public administrations due to PM16 in PO1a, PO2 and PO3,
expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total administrative costs 35.8 35.8 35.8
One-off costs for IT systems 12.8 12.8 12.8
Recurrent costs for maintenance of the IT systems 23.0 23.0 23.0
Source: Ricardo et al. (2024), Impact assessment support study
3.25.2. Administrative cost savings for national public authorities
PM16 is expected to bring administrative costs savings for national public authorities, by avoiding
the costs of printing, distribution and handling of paper/plastic documents.
Considering that the information related to registration certificates is already stored in national
databases, the costs savings due to PM16 are limited to the time spent for preparing and printing the
documents and the costs of delivering the documents. It is assumed that around 2 minutes of work
per document could be saved, at an average cost per hour for technicians and associate professionals
(ISCO level 3) of EUR 34, plus EUR 2 per document for paper and mail cost.
Recurrent administrative costs savings are estimated at EUR 75.4 million in 2026, EUR 79.3 million
in 2030 and EUR 86.3 million in 2050. Expressed as present value over 2026-2050, they are estimated
at EUR 1.4 billion relative to the baseline.
Table 178: Administrative costs savings for national public administrations due to PM16 in 2026, 2030, 2040 and
2050 in policy options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Recurrent administrative cost savings 75.4 79.3 85.2 86.3
Source: Ricardo et al. (2024), Impact assessment support study
394
Between 2% and 10% of the total number of new registrations at EU level in 2026 by Member State. These are: AT,
BE, CZ, EL, NL and RO.
395
Above 10% of the total number of new registrations at EU level in 2026 by Member State. These are: DE, FR, IT, PL
and ES.
188
Table 179: Administrative costs savings for national public administrations due to PM16 in PO1a, PO2 and PO3,
expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Recurrent administrative cost savings 1,429.5 1,429.5 1,429.5
Source: Ricardo et al. (2024), Impact assessment support study
3.26. PM17 - Add new data to the vehicle register – minimum mandatory set (including among
others: country of 1st registration, registration status, PTI status, changes due to
transformation)
PM17 provides for increasing the set of data to be included in the national vehicle registers. The
additional data that could be included is detailed in Annex 7 (section 2).
3.26.1. Administrative costs for national public authorities
A consensus has been reached among 18 vehicle authorities (including 15 from EU Member States)
regarding a minimum set of items for the vehicle registers396
. This data set comprises 94 items,
including mandatory and optional data elements referred to in the VRD Directive (Directive
1999/37/EC), as well as a number of additional elements.
In several Member States, some of these items might already be part of their registration databases,
making the costs associated with aligning their datasets with EReg's recommendations negligible.
For instance, according to EReg, inspection data is registered by Registration Authorities in most
MS, with the exception of HR, FR, IE and LT397
. Other MS will have to include new data items in
their vehicle registers. The Slovenian authorities, that provided input to the stakeholders’ consultation
survey, estimated the one-off costs of adding the minimum dataset to its vehicle register at around
EUR 50,000. Based on the hourly wage rate for clerks (ISCO 4) in Slovenia, of EUR 14.7/hour, the
one-off costs are equivalent to 2.1 full-time equivalents working 220 days per year, 7.3 hours per
day.
For the assessment of PM17, it should be acknowledged that not all Member States would need to
update their databases or integrate new data, as many of them already store most of these data items.
The Member States that store fewer data items than the average were identified, pointing to a cluster
of countries with insufficient data registration standards. This low-standard data storage group
includes eight countries: BE, FR, EL, HU, IE, LT, PL and PT. For the purpose of the assessment, it
is assumed that this specific group will bear one-off administrative costs for harmonising the dataset.
The one-off administrative costs are derived drawing on input from Slovenia, assuming 2.1 full-time
equivalents working 220 days per year, 7.3 hours per day. Using the hourly wage rate for clerks
(ISCO 4)398
in each of the 8 concerned Member States, the one-off administrative costs are provided
in the table below. At EU level, they are estimated at EUR 494,593 in 2026.
396
EReg (2021), EReg Topic Group XXI Harmonisation of registration procedures and data quality, Proposal on the
registration of vehicle data, available at: https://www.ereg-association.eu/media/2742/final-report-topic-group-xxi-
proposal-on-the-registration-of-vehicle-data.pdf
397
EReg (2021), ibid.
398
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
189
Table 180: One-off administrative costs for national public authorities, by Member State, due to PM17 in 2026 in
policy options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Low-standard data storage group Average hourly wage for
clerks (ISCO 4), in 2022
prices
One-off
administrative costs
(EUR)
BE 31.6 106,427
IE 31.0 104,390
EL 16.3 54,870
FR 30.1 101,353
LT 8.7 29,294
HU 9.1 30,551
PL 8.4 28,372
PT 11.7 39,336
Total 494,593
Source: Ricardo et al. (2024), Impact assessment support study
In addition, recurrent administrative costs are expected for the continuous data updates and broader
maintenance of the dataset for all EU Member States. The effort for data updates and broader
maintenance is assumed at 25% of the one-off costs, or around 0.5 full-time equivalents per Member
State. Assuming 220 working days per year, 7.3 working hours per day at an hourly wage rate for
clerks (ISCO 4)399
, the recurrent administrative costs by national public authority are provided in the
table below. At EU level, they are estimated at EUR 440,680 per year from 2026 onwards, or
expressed as present value over 2026-2050 at EUR 7.9 million relative to the baseline.
Table 181: Recurrent administrative costs for national public authorities, by Member State, due to PM17 in 2026,
2030, 2040 and 2050 in policy options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Average hourly wage for
clerks (ISCO 4), in 2022
prices
Recurrent
administrative costs
(EUR)
BE 31.6 25,340
BG 4.8 3,823
CZ 12.1 9,709
DK 45.1 36,152
DE 33.2 26,624
EE 12.7 10,149
IE 31.0 24,855
EL 16.3 13,064
ES 21.0 16,794
FR 30.1 24,132
HR 10.2 8,189
IT 27.6 22,102
CY 14.5 11,637
LV 9.9 7,940
LT 8.7 6,975
LU 34.0 27,187
HU 9.1 7,274
MT 15.6 12,523
NL 31.1 24,874
AT 32.2 25,749
PL 8.4 6,755
PT 11.7 9,366
399
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.
190
Average hourly wage for
clerks (ISCO 4), in 2022
prices
Recurrent
administrative costs
(EUR)
RO 7.3 5,849
SI 14.7 11,785
SK 11.2 8,930
FI 30.1 24,142
SE 35.9 28,761
Total 440,680
Source: Ricardo et al. (2024), Impact assessment support study
The total administrative costs at EU level for national public authorities, expected as a result of PM17,
are summarised in the tables below.
Table 182: Administrative costs for national public authorities due to PM17 in 2026, 2030, 2040 and 2050 in policy
options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
2026 2030 2040 2050
Total administrative costs 0.9 0.4 0.4 0.4
One-off administrative costs 0.5 0.0 0.0 0.0
Recurrent administrative costs 0.4 0.4 0.4 0.4
Source: Ricardo et al. (2024), Impact assessment support study
Table 183: Administrative costs for national public authorities due to PM17 in PO1a, PO2 and PO3 expressed as
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Total adjustment costs 8.4 8.4 8.4
One-off administrative costs 0.5 0.5 0.5
Recurrent administrative costs 7.9 7.9 7.9
Source: Ricardo et al. (2024), Impact assessment support study
Increased and more accessible data to authorities and inspection centres would facilitate re-
registration and RSI.
3.27. Summary of costs and costs savings by option and by measure
The summary of recurrent and one-off costs and costs savings by stakeholder group, by option and
by measure, expressed as present value over 2026-2050, and for 2026, 2030 and 2050 relative to the
baseline are provided in the tables below.
3.27.1. PTI centres
Table 184: Recurrent and one-off costs, costs savings and benefits for PTI centres in the policy options, expressed
as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 3,734.1 23,507.9 23,332.2 25,061.7
PMC1 143.6 143.6 143.6 143.6
PMC2 96.1 96.1 96.1 96.1
PMC3 697.1 697.1 697.1 697.1
PMC4 2,797.3 2,797.3 2,797.3 2,797.3
PM2 175.7
PM3 203.9
PM4 225.4
191
Difference to the baseline
PO1a PO1b PO2 PO3
PM5 647.7 647.7 647.7
PM6 17,680.8 17,680.8 17,680.8
PM7 1,300.2
PM10 1,170.6 1,170.6 1,170.6
PM12 99.0 99.0 99.0
Administrative costs 0.0 0.0 136.5 136.5
PM11 136.5 136.5
Administrative costs
savings
0.0 0.0 1,643.4 1,643.4
PM11 1,643.4 1,643.4
Benefits 860.5 39,394.2 39,100.1 39,968.0
PMC5 860.5 860.5 860.5 860.5
PM2 294.1
PM3 341.3
PM4 526.6
PM5 1,454.8 1,454.8 1,454.8
PM6 36,537.6 36,537.6 36,537.6
PM12 247.2 247.2 247.2
Net benefits -2,873.6 15,886.2 17,274.7 16,413.2
Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs.
Table 185: One-off costs for PTI centres in the policy options, expressed as present value over 2026-2050 relative
to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 2,094.7 3,221.3 3,217.4 3,708.7
PMC1 143.6 143.6 143.6 143.6
PMC2 96.1 96.1 96.1 96.1
PMC3 372.7 372.7 372.7 372.7
PMC4 1,482.3 1,482.3 1,482.3 1,482.3
PM2 3.9
PM3 4.5
PM4 1.1
PM5 20.1 20.1 20.1
PM6 1,097.9 1,097.9 1,097.9
PM7 485.6
PM10 4.7 4.7 4.7
Administrative costs 0.0 0.0 48.9 48.9
PM11 48.9 48.9
Net costs 2,094.7 3,221.3 3,266.3 3,757.6
Source: Ricardo et al. (2024), Impact assessment support study
Table 186: Recurrent and one-off costs, costs savings and benefits for PTI centres in the policy options, in 2026,
2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Adjustment
costs
2,162 115.8 91.4 4,186 1,130 1,177 4,175 1,121 1,166 4,603 1,313 1,241
PMC1 119.8 24.4 0.0 119.8 24.4 0.0 119.8 24.4 0.0 119.8 24.4 0.0
PMC2 96.1 0.0 0.0 96.1 0.0 0.0 96.1 0.0 0.0 96.1 0.0 0.0
PMC3 390.8 18.1 18.1 390.8 18.1 18.1 390.8 18.1 18.1 390.8 18.1 18.1
PMC4 1,556 73.3 73.3 1,556 73.3 73.3 1,556 73.3 73.3 1,556 73.3 73.3
192
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
PM2 11.9 8.9 11.1
PM3 13.7 10.2 13.0
PM4 12.3 11.9 13.4
PM5 69.6 49.2 4.9 69.6 49.2 4.9 69.6 49.2 4.9
PM6 1,870 886.0 995.7 1,870 886.0 995.7 1,870 886.0 995.7
PM7 402.8 170.2 48.0
PM10 63.6 61.8 73.7 63.6 61.8 73.7 63.6 61.8 73.7
PM12 8.6 8.0 0.6 8.6 8.0 0.6 8.6 8.0 0.6
Admin costs 0.0 0.0 0.0 0.0 0.0 0.0 53.8 4.9 4.9 53.8 4.9 4.9
PM11 53.8 4.9 4.9 53.8 4.9 4.9
Admin costs
savings
0.0 0.0 0.0 0.0 0.0 0.0 84.1 87.1 99.3 84.1 87.1 99.3
PM11 84.1 87.1 99.3 84.1 87.1 99.3
Benefits 44.1 45.5 52.3 2,086 2,135 2,275 2,071 2,120 2,256 2,115 2,166 2,309
PMC5 44.1 45.5 52.3 44.1 45.5 52.3 44.1 45.5 52.3 44.1 45.5 52.3
PM2 14.8 15.1 19.0
PM3 17.0 17.5 22.1
PM4 26.6 28.0 31.5
PM5 115.8 115.0 9.4 115.8 115.0 9.4 115.8 115.0 9.4
PM6 1,890 1,940 2,192 1,890 1,940 2,192 1,890 1,940 2,192
PM12 21.4 19.7 1.6 21.4 19.7 1.6 21.4 19.7 1.6
Net benefits -2,118 -70.3 -39.1 -2,100 1,006 1,097 -2,073 1,082 1,184 -2,458 934.7 1,163
Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs.
Table 187: One-off costs for PTI centres in the policy options, in 2026, 2030 and 2050, relative to the baseline, in
million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Adjustment
costs
2,071 24.4 0.0 3,111 29.4 1.7 3,107 29.3 1.7 3,479 151.6 1.7
PMC1 119.8 24.4 0.0 119.8 24.4 0.0 119.8 24.4 0.0 119.8 24.4 0.0
PMC2 96.1 0.0 0.0 96.1 0.0 0.0 96.1 0.0 0.0 96.1 0.0 0.0
PMC3 372.7 0.0 0.0 372.7 0.0 0.0 372.7 0.0 0.0 372.7 0.0 0.0
PMC4 1,482 0.0 0.0 1,482 0.0 0.0 1,482 0.0 0.0 1,482 0.0 0.0
PM2 3.3 0.02 0.04
PM3 3.8 0.02 0.06
PM4 1.0 0.02 0.00
PM5 20.1 0.0 0.0 20.1 0.0 0.0 20.1 0.0 0.0
PM6 1,012 4.9 1.7 1,012 4.9 1.7 1,012 4.9 1.7
PM7 367.0 122.2 0.0
PM10 4.7 0.0 0.0 4.7 0.0 0.0 4.7 0.0 0.0
Administrative
costs
0.0 0.0 0.0 0.0 0.0 0.0 48.9 0.0 0.0 48.9 0.0 0.0
PM11 48.9 0.0 0.0 48.9 0.0 0.0
Net costs 2,071 24.4 0.0 3,111 29.4 1.7 3,156 29.3 1.7 3,528 151.6 1.7
Source: Ricardo et al. (2024), Impact assessment support study
193
3.27.2. Garages, motor vehicle dealers, tyre and repair stations, etc.
Table 188: Recurrent and one-off costs for garages, motor vehicle dealers, tyre and repair stations, etc. in the
policy options, expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Administrative costs 460.0 460.0 460.0 460.0
PMC9 460.0 460.0 460.0 460.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 189: Recurrent and one-off costs for garages, motor vehicle dealers, tyre and repair stations, etc. in the
policy options, in 2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Administrative
costs
172.7 19.4 14.9 172.7 19.4 14.9 172.7 19.4 14.9 172.7 19.4 14.9
PMC9 172.7 19.4 14.9 172.7 19.4 14.9 172.7 19.4 14.9 172.7 19.4 14.9
Source: Ricardo et al. (2024), Impact assessment support study
Table 190: One-off costs for garages, motor vehicle dealers, tyre and repair stations, etc. in the policy options, in
2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Administrative
costs
149.2 0.0 0.0 149.2 0.0 0.0 149.2 0.0 0.0 149.2 0.0 0.0
PMC9 149.2 0.0 0.0 149.2 0.0 0.0 149.2 0.0 0.0 149.2 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
3.27.3. OEMs
Table 191: Recurrent and one-off costs for OEMs in the policy options, expressed as present value over 2026-2050
relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Administrative costs 0.0 0.0 55.9 55.9
PM11 55.9 55.9
Source: Ricardo et al. (2024), Impact assessment support study
Table 192: Recurrent and one-off costs for OEMs in the policy options, in 2026, 2030 and 2050, relative to the
baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Administrative
costs
0.0 0.0 0.0 0.0 0.0 0.0 22.0 2.0 2.0 22.0 2.0 2.0
PM11 22.0 2.0 2.0 22.0 2.0 2.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 193: One-off costs for OEMs in the policy options, in 2026, 2030 and 2050, relative to the baseline, in million
EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Administrative
costs
0.0 0.0 0.0 0.0 0.0 0.0 20.0 0.0 0.0 20.0 0.0 0.0
194
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
PM11 20.0 0.0 0.0 20.0 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
3.27.4. Other businesses (vehicle owners)
Table 194: Recurrent costs, costs savings and benefits for other businesses (vehicle owners) in the policy options,
expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Administrative costs 524.2 25,458.4 25,666.4 26,051.5
PMC5 524.2 524.2 524.2 524.2
PM4 385.1
PM5 1,454.8 1,454.8 1,454.8
PM6 23,295.9 23,295.9 23,295.9
PM12 175.0 175.0 175.0
PM13 8.5 8.5 8.5
PM14 208.0 208.0
Administrative costs
savings
0.0 1,287.3 1,287.3 1,287.3
PM12 1,287.3 1,287.3 1,287.3
Benefits 118,340.5 118,340.5 118,340.5 118,340.5
PMC9 118,340.5 118,340.5 118,340.5 118,340.5
Net benefits 117,816.3 94,169.4 93,961.3 93,576.3
Source: Ricardo et al. (2024), Impact assessment support study
Table 195: Recurrent costs, costs savings and benefits for other businesses (vehicle owners) in the policy options,
in 2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Administrative
costs
27.0 27.8 31.6 1,362 1,394 1,443 1,372 1,405 1,456 1,392 1,425 1,479
PMC5 27.0 27.8 31.6 27.0 27.8 31.6 27.0 27.8 31.6 27.0 27.8 31.6
PM4 19.3 20.4 23.1
PM5 115.8 115.0 9.4 115.8 115.0 9.4 115.8 115.0 9.4
PM6 1,204 1,237 1,400 1,204 1,237 1,400 1,204 1,237 1,400
PM12 14.8 14.0 1.2 14.8 14.0 1.2 14.8 14.0 1.2
PM13 0.4 0.4 0.5 0.4 0.4 0.5 0.4 0.4 0.5
PM14 10.5 10.9 12.9 10.5 10.9 12.9
Administrative
costs savings
0.0 0.0 0.0 109.4 102.6 10.1 109.4 102.6 10.1 109.4 102.6 10.1
PM12 109.4 102.6 10.1 109.4 102.6 10.1 109.4 102.6 10.1
Benefits 6,043 6,353 6,991 6,043 6,353 6,991 6,043 6,353 6,991 6,043 6,353 6,991
PMC9 6,043 6,353 6,991 6,043 6,353 6,991 6,043 6,353 6,991 6,043 6,353 6,991
Net benefits 6,016 6,325 6,959 4,791 5,062 5,558 4,780 5,051 5,545 4,761 5,030 5,522
Source: Ricardo et al. (2024), Impact assessment support study
195
3.27.5. Citizens (vehicle owners)
Table 196: Recurrent costs, costs savings and benefits for citizens (vehicle owners) in the policy options, expressed
as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 344.2 13,944.3 13,658.1 14,150.0
PMC5 336.3 336.3 336.3 336.3
PM1 7.9 7.9
PM2 294.1
PM3 341.3
PM4 141.5
PM6 13,241.7 13,241.7 13,241.7
PM12 72.2 72.2 72.2
PM15 16.9
Adjustment costs savings 878.2 2,144.6 2,144.6 4,289.3
PM7 4,289.3
PM8 2,144.6 2,144.6
PM9 878.2
Administrative costs savings 0.0 591.9 591.9 591.9
PM12 591.9 591.9 591.9
Benefits 65,666.9 65,666.9 65,666.9 65,666.9
PMC9 65,666.9 65,666.9 65,666.9 65,666.9
Net benefits 66,200.9 54,459.0 54,745.2 56,398.0
Source: Ricardo et al. (2024), Impact assessment support study
Table 197: Recurrent costs, costs savings and benefits for citizens (vehicle owners) in the policy options, in 2026,
2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Administrative
costs
17.5 18.1 21.1 724.9 742.0 832.3 710.6 727.3 813.8 735.3 752.8 844.9
PMC5 17.1 17.7 20.6 17.1 17.7 20.6 17.1 17.7 20.6 17.1 17.7 20.6
PM1 0.4 0.4 0.5 0.4 0.4 0.5
PM2 14.8 15.1 19.0
PM3 17.0 17.5 22.1
PM4 7.3 7.6 8.4
PM6 686.5 703.4 792.3 686.5 703.4 792.3 686.5 703.4 792.3
PM12 6.5 5.8 0.3 6.5 5.8 0.3 6.5 5.8 0.3
PM15 0.8 0.9 1.1
Adjustment
costs savings
49.0 49.0 49.0 110.7 114.1 127.4 110.7 114.1 127.4 221.5 228.2 254.8
PM7 221.5 228.2 254.8
PM8 110.7 114.1 127.4 110.7 114.1 127.4
PM9 49.0 49.0 49.0
Administrative
costs savings
0.0 0.0 0.0 53.4 48.8 2.8 53.4 48.8 2.8 53.4 48.8 2.8
PM12 53.4 48.8 2.8 53.4 48.8 2.8 53.4 48.8 2.8
Benefits 3,381 3,554 3,857 3,381 3,554 3,857 3,381 3,554 3,857 3,381 3,554 3,857
PMC9 3,381 3,554 3,857 3,381 3,554 3,857 3,381 3,554 3,857 3,381 3,554 3,857
Net benefits 3,412 3,585 3,885 2,820 2,975 3,155 2,834 2,990 3,173 2,920 3,078 3,269
Source: Ricardo et al. (2024), Impact assessment support study
196
3.27.6. National public authorities
Table 198: Recurrent and one-off costs, and costs savings for national public authorities in the policy options,
expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
Adjustment costs 7.0 198.3 207.2 208.0
PMC2 0.2 0.2 0.2 0.2
PMC3 1.3 1.3 1.3 1.3
PMC4 3.8 3.8 3.8 3.8
PM1 0.3 0.3
PM9 1.4
PM12 192.9 192.9 192.9
PM13 0.3 0.3 0.3
PM14 8.6 8.6
PM15 1.1
Administrative costs 2,233.8 2,190.4 2,387.5 2,397.9
PMC6 33.7 33.7 33.7 33.7
PMC7 15.4 15.4 15.4 15.4
PMC8 9.4 9.4 9.4 9.4
PMC9 2,122.1 2,122.1 2,122.1 2,122.1
PM1 9.1 9.1
PM11 36.3 36.3
PM13 9.8 9.8 9.8
PM14 107.5 107.5
PM15 19.5
PM16 35.8 35.8 35.8
PM17 8.4 8.4 8.4
Enforcement costs 0.0 32.9 0.0 77.4
PM2 32.9
PM3 38.1
PM4 39.2
Administrative costs savings 5,226.3 3,796.8 5,226.3 5,226.3
PMC6 3,155.0 3,155.0 3,155.0 3,155.0
PMC7 641.8 641.8 641.8 641.8
PM16 1,429.5 1,429.5 1,429.5
Net benefits 2,985.5 1,375.2 2,631.6 2,543.1
Source: Ricardo et al. (2024), Impact assessment support study
Table 199: Recurrent and one-off costs, and costs savings for national public authorities in the policy options, in
2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Adjustment
costs
4.6 0.1 0.1 36.1 9.6 9.6 39.6 9.9 9.9 39.9 9.9 9.9
PMC2 0.2 0.2 0.2 0.2
PMC3 0.7 0.03 0.03 0.7 0.03 0.03 0.7 0.03 0.03 0.7 0.03 0.03
PMC4 2.1 0.1 0.1 2.1 0.1 0.1 2.1 0.1 0.1 2.1 0.1 0.1
PM1 0.1 0.01 0.01 0.1 0.01 0.01
PM9 1.4
PM12 33.0 9.4 9.4 33.0 9.4 9.4 33.0 9.4 9.4
PM13 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03
PM14 3.4 0.3 0.3 3.4 0.3 0.3
197
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
PM15 0.45 0.04 0.04
Administrative
costs
176.9 115.3 129.7 161.9 113.7 128.0 197.1 122.8 138.3 197.6 123.3 139.0
PMC6 18.6 0.9 0.9 18.6 0.9 0.9 18.6 0.9 0.9 18.6 0.9 0.9
PMC7 8.5 0.4 0.4 8.5 0.4 0.4 8.5 0.4 0.4 8.5 0.4 0.4
PMC8 1.2 0.5 0.5 1.2 0.5 0.5 1.2 0.5 0.5 1.2 0.5 0.5
PMC9 133.1 111.4 125.6 133.1 111.4 125.6 133.1 111.4 125.6 133.1 111.4 125.6
PM1 0.5 0.5 0.6 0.5 0.5 0.6
PM11 14.3 1.3 1.3 14.3 1.3 1.3
PM13 0.5 0.5 0.6 0.5 0.5 0.6 0.5 0.5 0.6
PM14 5.4 5.6 6.7 5.4 5.6 6.7
PM15 1.0 1.0 1.3
PM16 14.1 1.3 1.3 14.1 1.3 1.3 14.1 1.3 1.3
PM17 0.9 0.4 0.4 0.9 0.4 0.4 0.9 0.4 0.4
Enforcement
costs
0.0 0.0 0.0 1.6 1.7 2.1 0.0 0.0 0.0 3.9 4.0 4.8
PM2 1.6 1.7 2.1
PM3 1.9 2.0 2.5
PM4 2.0 2.1 2.3
Administrative
costs savings
272.7 282.3 312.7 197.3 203.0 226.4 272.7 282.3 312.7 272.7 282.3 312.7
PMC6 161.5 167.3 190.6 161.5 167.3 190.6 161.5 167.3 190.6 161.5 167.3 190.6
PMC7 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8 35.8
PM16 75.4 79.3 86.3 75.4 79.3 86.3 75.4 79.3 86.3
Net benefits 91.2 166.8 182.9 -2.4 78.1 86.7 35.9 149.6 164.5 31.2 145.0 159.0
Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs.
Table 200: One-off costs for national public authorities in the policy options, in 2026, 2030 and 2050, relative to
the baseline, in million EUR (2022 prices)
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
Adjustment
costs
4.4 0.0 0.0 26.5 0.0 0.0 29.7 0.0 0.0 30.0 0.0 0.0
PMC2 0.2 0.2 0.2 0.2
PMC3 0.7 0.7 0.7 0.7
PMC4 2.0 2.0 2.0 2.0
PM1 0.1 0.1
PM9 1.4
PM12 23.6 23.6 23.6
PM13 0.03 0.03 0.03
PM14 3.1 3.1
PM15 0.4
Administrative
costs
64.9 0.0 0.0 51.6 0.0 0.0 77.9 0.0 0.0 77.9 0.0 0.0
PMC6 17.8 17.8 17.8 17.8
PMC7 8.1 8.1 8.1 8.1
PMC8 0.7 0.7 0.7 0.7
PMC9 25.0 25.0 25.0 25.0
PM11 13.0 13.0
PM16 12.8 12.8 12.8
198
Difference to the baseline
PO1a PO1b PO2 PO3
2026 2030 2050 2026 2030 2050 2026 2030 2050 2026 2030 2050
PM17 0.5 0.5 0.5
Net costs 69.3 0.0 0.0 78.1 0.0 0.0 107.6 0.0 0.0 107.9 0.0 0.0
Source: Ricardo et al. (2024), Impact assessment support study
4. IMPACTS BY POLICY MEASURE ON SAFETY, EMISSIONS AND NOISE
This section explains the inputs used for deriving the impacts of the policy options on safety,
emissions and noise.
In the first step, the impacts by policy measure have been assessed, drawing on relevant inputs. These
are explained in detail in the sections below. Only the measures with significant impact, which have
been quantified, are included in the sections below. The table below summarises the list of relevant
measures by policy option and type of impact.
Table 201: Summary of measures by type of impact
Measure Relevant options Safety Air pollutant
emissions
Noise
PMC2 PO1a, PO1b, PO2, PO3 Y
PMC3 PO1a, PO1b, PO2, PO3 Y
PMC4 PO1a, PO1b, PO2, PO3 Y
PM1 PO1a/ PO2 Y Y Y
PM2 PO1b Y Y Y
PM3 PO3 Y Y Y
PM4 PO3 Y
PM5 PO1b, PO2, PO3 Y
PM6 PO1b, PO2, PO3 Y Y
PM10 PO1b, PO2, PO3 Y
PM12 PO1b, PO2, PO3 Y Y
PM13 PO1b, PO2, PO3 Y
PM14 PO2, PO3 Y Y Y
PM15 PO3 Y Y Y
In the second step, the inputs by policy measure are aggregated into policy options and used in the
PRIMES-TREMOVE model to assess the impacts on the level of fatalities and injuries, emissions
and external costs of accidents, emissions and noise.
4.1. Impacts on road safety
4.1.1. Introduction
A number of the proposed measures are expected to have a direct impact on road safety through more
effective identification of vehicles with major and dangerous defects in the fleet and the subsequent
fix of such defects to restore the vehicles to a safe status. This can be achieved either through more
frequent tests or more effective tests, better capable of capturing defects and also covering new
technologies. The reduction in the number of unsafe vehicles should eventually lead to a reduction
of road accidents caused by technical defects and, as a result, a reduction in the number of fatalities
and injuries (i.e., serious and slight injuries).
199
In addition, a broader set of measures that are expected to increase the effectiveness of the
implementation and enforcement of overall roadworthiness legislation (such as those related to the
exchange of data among authorities) can also indirectly contribute to the reduction of unsafe vehicles.
4.1.2. Approach
Additional or more effective PTI and/or RSI inspections can help identify safety related defects and,
by mandating repair, eliminate the safety related risk. This contributes to a reduction of the number
of road accidents resulting in a reduction in the total number of fatalities and injuries compared to
the baseline.
The approach used for the assessment of the road safety impacts of individual measures is based on
the following formula:
% reduction of fatalities/injuries relative to the baseline = TD x PTI/RSI_Share x IE x RSI_EFF
Where:
• TD refers to the contribution of technical defects to accidents. A value of 6% is assumed for
motorcycles and 4% for all other vehicle categories (see below).
• PTI/RSI_Share refers to share of a specific vehicle category in the fleet that is expected to be
subject to PTI/RSI inspection on an annual basis. This is based on the scope of the measure and
determined by the vehicles average age and the test frequency400
.
• IE refers to the effectiveness of PTI/RSI inspections in identifying major and dangerous defects,
assumed to be 95%.
• RSI_EFF is relevant only in the case of measures including RSI and refers to the expected
enhanced effectiveness of targeted roadside inspections to identify vehicles with technical
defects, when compared to the PTI where there is no such targeted approach. A factor of three is
used401
. As example, if the fleet includes a 10% share of high emitters, RSI based on random
selection would identify 10 high emitters in 100 roadside inspections, while targeted RSIs are
expected to be able to identify 30 high emitters (3 x 10) in 100 roadside inspections.
The formula aims to identify the expected percentage reduction of road accidents and thus of
fatalities/injuries in relation to the baseline levels for each policy measure and vehicle category.
In the second step, in order to calculate the combined effect on safety of the policy measures included
in each option by Member State, the common residual method is applied:
CE A, B, C, … = 1−[(1-IA)x(1-IB)x(1-IC)x(1-…)]
Where:
• CE A, B, C denotes the combined effect of measures A, B, C, etc.
400
For example, in the case of an average vehicle age of 15 years and a PTI frequency of 4/2/2 (four years for the first
inspection and 2 thereafter) we can calculate a total of 6.5 inspections until the age 15 which means an annual frequency
of 0.43 (=6.5/15) inspections. For L and O vehicle types the average vehicle age is 18 years and the total number of
inspections over the lifetime of the vehicle is 8 resulting in an annual frequency of 0.44 (=8/18).
401
Based on a comparison of the share of defective vehicles found at RSI in Member States applying targeted checks
(based on risk rating for the selection of HDVs) to those that select vehicles randomly, the factor of 3 is assessed to be a
conservative estimate. For LDVs, remote sensing will help selecting vehicles to be tested at roadside.
200
• IA, IB and Ic correspond to the expected level of impact (in percentage terms) of each measure.
The resulting percentage reduction by policy option and Member State is used as input in the
PRIMES-TREMOVE model and translated into absolute levels of avoided fatalities and injuries
relative to the baseline. Based on the number of fatalities and injuries avoided, the reduction in the
external costs of accidents is calculated402
.
4.1.3. Key assumptions
The TD parameter relating to the contribution of technical defects on fatalities is a key parameter in
the assessment as it determines the maximum impact that can be possibly achieved by the removal
of unsafe vehicles from EU roads. As presented in more detail in the baseline section, there is
significant uncertainty in relation to this parameter, with estimates that range between 0.5% to up to
20% in terms of the share of road accidents caused by technical defects. It should however be noted
that methodologies vary significantly and they are often not comparable. Following a review of the
literature403
, a conservative approach has been used. A 4% contribution of technical defects to road
accidents is assumed in the case of LDVs, HDVs and trailers. For motorcycles, given the presence of
some evidence of higher levels of contribution of this vehicle type, 6% is assumed404
. Given the high
uncertainty, sensitivity analysis has been performed, considering alternatives of 1% and 7%
contribution for LDVs, HDVs and trailers and 3% and 9% for motorcycles.
The IE parameter refers to the expected effectiveness of the inspections. A value of 95% is assumed
based on the fact that inspections need to follow an extensive list, covering all vehicle aspects as
defined in the annexes of the PTI and RSI Directives (2014/45/EU and 2014/47/EU). Furthermore,
given the focus of this analysis on major or dangerous defects, it is reasonable to assume that in the
majority of cases these will be effectively identified during the inspections, by a trained inspector.
In addition, a one-to-one relationship between the impact on road accidents and fatalities and injuries
is assumed. Namely, a 1% reduction in the number of road accidents is assumed to lead to a 1%
reduction in fatalities and injuries. This is considered a reasonable assumption, even though it is
possible that the adoption of new vehicle technologies in the future may change this relationship over
time.
Another important assumption made is that unsafe vehicles inspected and repaired to pass a follow
up PTI inspection, will maintain their roadworthy status following the PTI and will not deteriorate
until the next PTI. This is an important assumption, especially when considering older vehicles where
faster deterioration is more likely. There is however no standard approach or evidence available for
assessing the impact of such deterioration over time. There are also certain limiting factors of such
an effect. This includes the possibility that some vehicle owners will repair their vehicles before the
PTI date, when a serious defect that may pose safety issues is identified. Further to that, roadside
402
The 2019 Handbook on the external costs of transport (Source: https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs. According to the Handbook,
the external cost of a fatality in 2022 prices is estimated at EUR 3.9 million and that of a serious injury at EUR 0.6
million.
403
Hudec (2021), Examination of the results of the vehicles technical inspections in relation to the average age of vehicles
in selected EU states; SAFERWHEELS (2018), Study on Powered Two-Wheeler and Bicycle Accidents in the EU, Final
Report, Brussels
404
The 4% and 6% are two percentage points lower than the levels of contribution assumed in the 2012 impact assessment
support study. Reduced rates were considered more appropriate because the estimated impact on fatalities in the 2012
impact assessment support study was significantly higher than what was actually observed on the basis of data from the
CARE database.
201
inspections can also help identify such defects, although their effectiveness is limited by the small
share of the fleet affected and the fact that they are only mandatory for HDVs.
4.1.4. PMC2 - Update PTI and RSI due to new requirements in General Safety Regulation and
checking emission reduction systems (new test items, including checks of software
status/integrity), by reading on-board diagnostics
PMC2 requires to update the PTI and RSI to new requirements in the General Safety Regulation
(including software status/integrity of safety or emission relevant systems during PTI for all vehicles
and at technical roadside inspections of commercial vehicles), resulting in safety benefits. The
enhanced testing requirements are expected to ensure detecting and resolving defects for vehicle
safety features introduced by the General Safety Regulation (GSR), thus enabling the full safety
benefit of GSR to be realised.
The impact assessment accompanying the GSR405
estimated the number of fatalities that could be
prevented by GSR across all vehicle categories during 2021-2037 for EU27 plus UK (line (a) in the
table below). These estimates were converted to EU27 (line (b) in the table below) by deducting the
UK’s fleet share, and then translated to the period 2026-2050 by first annualising them and then
multiplying by 25 years (line (c) in the table below).
Defects in ADAS would result in a reduced effectiveness of the GSR measures. This is calculated by
applying an ADAS defect rate (line (e) in the table below) to the share of fatalities that could be
avoided (line (d) in the table below). The ADAS defect rate is assumed to be the same as the defect
rate of electronic safety components, which was estimated at 17% by the initiative for Diagnosis of
Electronic Systems in Motor Vehicles for PTI406
. This provides a maximum share of total fatalities
that could be reduced by addressing ADAS defects. In the case of passenger cars this is estimated at
9.4% reduction of fatalities from the baseline levels.
Finally, a success rate of PTI inspections to capture defects (95%) is applied (line (f) in the table
below). For example, for M1 vehicles PMC2 could reduce fatalities and injuries from MS affected
by 1.5% (line (g) in the table below).
The table below presents the data for the calculation of the impact of PMC2 on safety, as outlined
above.
Table 202: Estimated impact of PMC2 on fatalities and injuries
Variable M1 N1 N2/N3 M2/M3 Explanation/source
MS affected All All All All
Share of EU fatalities
affected
100% 100% 100% 100%
Total fatalities prevented by
GSR safety measures across
all vehicle categories over
the period 2021–2037 for
EU27 plus UK (a)
21,337 1,283 1,947 227 Assumed to equal the total GSR
life-saving potential of PO3.
Source: SWD(2018)190
405
SWD(2018)190
406
SWD(2012)206
202
Variable M1 N1 N2/N3 M2/M3 Explanation/source
Total fatalities prevented by
GSR safety measures across
all vehicle categories over
the period 2021–2037 for
EU27 (b)
19,051 1,146 1,738 203 Using the share of UK fleet into
the total EU27 plus UK fleet
(12% according to Eurostat data:
Stock of vehicles by category and
NUTS 2 regions
[TRAN_R_VEHST])
Total fatalities prevented by
GSR safety measures across
all vehicle categories over
the period 2026–2050 across
EU27 (c)
28,016 1,685 2,556 298 Converted to 2026-2050 period
by annualising and multiplying by
25 years
Proportion of fatalities
prevented by GSR safety
measures across all vehicle
categories across EU27 (d)
9.4% 3.0% 3.4% 2.5% GSR fatalities prevented / total
fatalities in the baseline
Defect rate of ADAS
systems (e)
17% 17% 17% 17% Assumed to be the same as the
defect rate of ESC, which is
estimated at 17% by IDELSY
Success rate of PTI/RIS to
capture defects and address
them (f)
95% 95% 95% 95% Assumption
% reduction of
fatalities/injuries in the MS
affected (g)=(d)x(e)x(f)
1.5% 0.5% 0.5% 0.4% Decrease in fatalities relative to
the baseline
Source: Ricardo et al. (2024), Impact assessment support study
4.1.5. PM1 - RSI for heavy/powerful motorcycles (L category > 125cm3) as alternative measure,
in the Member States where they are not subject to PTI (i.e., using available opt-out)
PM1 will require that those Member States (BE, FI, IE, NL, MT, PT)407
that do not have a PTI
requirement for motorcycles introduce roadside inspections for motorcycles over 125 cc as an
alternative. The roadside inspections are expected to cover 5% of the number of motorcycles
registered every year. The motorcycle fleet of these Member States represent on average 8.6% of the
fleet over 2026-2050. Furthermore, as the measure does not cover L3-L7 motorcycles of less than
125cc, the scope of the measure is also reduced (84.2% of the total L3-L7 on average over 2026-
2050).
On the basis of the assumed effectiveness of roadside inspections (RSI) in detecting defective
vehicles when inspected (i.e., 95%=100%-5%) and the expected enhanced effectiveness of RSI to
identify defective vehicles (factor of 3), the share of defective motorcycles that is expected to be
identified on an annual basis is estimated. With 5% of the fleet inspected annually, the reduction in
407
Until the end of 2023, France had not introduced mandatory PTI for motorcycles, but the French authorities had
announced the intention to do so. For this reason, for the purposes of the analysis it was assumed that France would not
be affected by the proposed measure. Denmark does not have mandatory PTI but it has introduced roadside inspections,
and it is thus assumed to be part of the baseline. In the case of Portugal, current requirements cover only motorcycles
over 250cc.
203
the number of fatalities and injuries is estimated at 0.7% relative to the baseline for the six MS
affected.
Table 203: Estimated impact of PM1 on fatalities and injuries
Variable Values Label Calculation
Share of EU fleet affected (L3-L7) 8.6% (a)
Share of L3-L7 in measure scope 84.2% (b)
Share of fatalities/injuries of MS affected in EU
total
8% (c)
Share of accidents directly caused by motorcycle
technical defects
6% (d)
Share of motorcycles inspected in RSI 5% (e)
Parameter reflecting RSI enhanced capacity to
select defective vehicles for RSI
3.0 (f)
Failure rate of inspections in detecting defective
vehicles
5% (g)
% reduction in fatalities/injuries from affected
MS
0.7% (h) (h)=(1–(g)) x (f) x (e) x (b)
x (d)
Source: Ricardo et al. (2024), Impact assessment support study
4.1.6. PM2 - Mandatory PTI for motorcycles above 125cm3 (remove opt-out)
PM2 introduces mandatory PTI for all motorcycles over 125cm3 (removing opt-out). Besides the
Member States identified in PM1, Denmark will also need to introduce PTI for motorcycles over
125cm under PM2. Thus, the Member States affected by PM2 are BE, DK, FI, IE, MT, NL and PT.
In this case the impact will depend on the expected frequency of the PTI inspections which has been
assumed to be the minimum one provided for M1/N1 vehicles in the Directive (4/2/2), leading to an
average frequency of 0.44 inspections per year408
. Assuming 5% failure rate of PTI in detecting
defective vehicles and a 6% contribution of technical defects to road accidents, the reduction in the
number of fatalities/injuries in the MS affected is estimated at 2.2% relative to the baseline.
Table 204: Estimated impact of PM2 on fatalities and injuries
Variable Value Label Calculation
Share of EU fleet affected (L3-L7) 8.8% (a)
Share of L3-L7 in measure scope 85.9% (b)
Share of fatalities/injuries of MS affected in EU total 8.5% (c)
Share of accidents directly caused by motorcycle technical
defects
6% (d)
408
For L vehicle types the average vehicle age is 18 years and the total number of inspections over the lifetime of the
vehicle is 8 resulting in an annual frequency of 0.44 (=8/18).
204
Variable Value Label Calculation
Average share of vehicles tested in PTI per year 44% (e)
Failure rate of PTI in detecting defective vehicles 5% (f)
% reduction in fatalities/injuries for affected MS 2.2% (g) (g)=(1-(f)) x (b) x (c) x (d)
x (e)
Source: Ricardo et al. (2024), Impact assessment support study
4.1.7. PM3 - Extend PTI to all motorcycles (i.e., incl. from 50cm3 = all L3e, L4e, plus tricycles
(L5e) and heavy quadricycles (L7e)
PM3 extends the type of motorcycles covered by PTI to those from 50cm3 in the eight Member States
where such requirement is currently not in place (BE, FI, IE, NL, MT, PT, DK, CY409
).
As in the case of PM2, a 5% failure rate of PTI in detecting defective vehicles is assumed and an
average frequency of 0.44 inspections per year. The reduction in the number of fatalities/injuries for
the MS affected is estimated at 2.5% relative to the baseline.
Table 205: Estimated impact of PM3 on fatalities and injuries
Variable Value Label Calculation
Share of EU fleet affected (L3-L7) 10.2% (a)
Share of L3-L7 vehicle fleet in measure scope 100% (b)
Share of fatalities/injuries of affected MS in EU total 9% (c)
Share of accidents directly caused by motorcycle technical
defects
6% (d)
Average share of vehicles tested in PTI per year 44% (e)
Failure rate of PTI in detecting defective vehicles 5% (f)
% reduction in fatalities/injuries for affected MS 2.5% (g) (g)=(1-(f)) x (b) x (d) x (e)
Source: Ricardo et al. (2024), Impact assessment support study
4.1.8. PM4 - Mandatory PTI for light trailers (O1 and O2 categories)
PM4 requires the mandatory PTI for light trailers (O1 and O2 categories). Eleven Member States
would be affected by PM4: 7 Member States where there is currently no requirement for PTI for
either O1 or O2 (DK, EL, FI, FR, NL, IE, PT) and 4 Member States where there is currently only a
requirement for PTI for O2 (PL, SK, BE and ES).
In the case of O1 around 21.5% of the total EU fleet of O1 vehicles will be affected while in the case
of O2 around 9.3%. Due to the significant data gaps in the number of O1 and O2 vehicles in the EU,
the shares above are based on estimates linking the number of trailers with the number of passenger
409
In Cyprus motorcycles above 125cm3 are already covered.
205
cars in the fleet410
.
There is also no detailed data on the number of fatalities from O1/O2 vehicles. Data from the CARE
database concerning the fatalities and injuries of passenger cars with trailers has been used, since
passengers cars are not permitted to pull trailers over 3,500 kg. Data is available for only a small
number of Member States411
for the period 2019-2021. For the 10 Member States where data is
available, the average total number of fatalities per year is 16. Considering that these Member States
represent around 26% of the estimated number of trailers in the EU fleet, the total number of fatalities
at EU level is estimated at around 62. On the basis of CARE database, and using a similar approach,
the level of serious injuries at EU level in which O1/O2 vehicles are involved is estimated at around
324 per year and slight injuries at 1,778 per year.
Assuming a contribution of technical defects of light trailers to road accidents of 4%, an average
frequency of 0.44 inspections per year412
and a 5% failure rate of PTI detecting defective vehicles,
the percentage reduction in the number of fatalities and injuries due to PM4 is estimated at 1.7%
relative to the baseline for both O1 and O2 for the MS affected.
Table 206: Estimated impact of PM4 on fatalities and injuries
Variable O1 O2 Label Calculation
Share of EU fleet affected 21.5% 9.3% (a)
Share of MS affected fleet in measure scope 100% (b)
Share of accidents directly caused by vehicle
technical defects
4% (c)
Average share of vehicles tested in PTI per
year
44% (d)
Failure rate of PTI in detecting defective
vehicles
5% (e)
% reduction in fatalities/injuries for
affected MS
1.7% 1.7% (f) (f)=(1-(e)) x (b) x
(c) x (d)
Source: Ricardo et al. (2024), Impact assessment support study
4.1.9. PM6 - Mandatory yearly testing for vehicles that are 10-year-old or older
Currently, 11 MS do not require annual PTI testing of light-duty vehicles after 10 years of their
registration (CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT, SK). All these Member States currently
require an inspection every two years which means that the proposed measure will double the number
of inspections for vehicles over 10 years.
The share of older vehicles that contribute to accidents due to technical defects is calculated by
multiplying the share of accidents directly caused by technical defects (4%) by 1.77, to account for
410
Data from Eurostat passenger car stock (road_eqs_carage) has been used to calculate the number of O1/O2 trailers
per passenger cars for the Member States where data is available. The median was used to estimate the number of
trailers in the MS where data is missing. A 50% split of O1/O2 was used where data was not available.
411
AT, BG, DK, ES, FI, IT, LT, LV, PT and SE.
412
This is based on an average lifetime of 18 years and a frequency pattern of 4/2/2 (8 inspections within the 18 year
period). The average lifetime is estimated based on the average age of vehicles.
206
the higher rate of technical defects for older vehicles. The scaling factor (1.77) is calculated based on
the IGLAD study413
, on the distribution of vehicle accidents by age. A 5% failure rate of PTI detecting
defective vehicles is assumed.
The reduction in fatalities and injuries for the affected MS is calculated separately for M1 and N1
vehicles, as shown in the table below, and is estimated at 1.2% for M1 vehicles and 0.9% for N1
vehicles relative to the baseline.
Table 207: Estimated impact of PM6 on fatalities and injuries
Variable M1 N1 Label Calculation
MS affected by measure CY, DE, LT, CZ,
DK, FR, EL, HU,
IT, MT, SK
CY, DE, LT,
CZ, DK, FR,
EL, HU, IT,
MT, SK
(a)
Share of fatalities in MS affected in EU
total
53% 41% (b)
Share of vehicle fleet in measure scope 53% 52% (c)
Share of accidents directly caused by
technical defects
4% 4% (d)
Scale factor for increased older vehicle
accidents
1.77 1.77 (e)
Increase in the share of vehicles tested
per year
33% 26% (f)
Failure rate of PTI in detecting defective
vehicles
5% 5% (g)
% reduction in fatalities/injuries for
affected MS
1.2% 0.9% (h) (h)=(1-(g)) x (c) x
(d) x (e) x (f)
Source: Ricardo et al. (2024), Impact assessment support study
4.1.10. PM13 - Mandatory inspection of cargo securing
PM13 introduces mandatory standards in relation to cargo securing inspections. Currently 5 Member
States414
do not require either minimum training or specify test requirements relating to cargo
securing during RSI in their national transposition of Directive 2014/47/EU. For calculating the
impacts, the vehicle fleet of the affected Member States are considered. N2 and N3 vehicles in these
Member States represent around 13% of the EU-wide fleet. 14 Member States415
, covering 67% of
the N2/N3 fleet, do not specify minimum training requirements for cargo securing.
Based on MS data and available estimates416
, up to 25% of crashes involving N2/N3 vehicles are
linked to cargo securing defects. The share of fatalities attributable to cargo unsafe vehicles was
413
http://www.iglad.net/.
414
EE, FR, IE, LV and LU.
415
BE, DK, DE, EE, FR, IE, LV, LU, BG, FI, IT, NL, PL and PT.
416
https://road-safety.transport.ec.europa.eu/eu-road-safety-policy/priorities/safe-vehicles/cargo-securing-and-
abnormal-loads_en
207
assumed to be proportionate to the share of cargo-related accidents. The failure rate of cargo
inspections in detecting unsafe cargo loading (in line with the 2014 European best practise
guidelines417
) is assumed to be 5%.
To calculate the percentage reduction in fatalities due to this measure in the affected MS, the accuracy
of cargo inspections was multiplied by the share of the fleet undergoing RSI each year and the share
of fatalities attributable to unsafe cargo. The impact of introducing minimum training requirements
was weighted by 50%, to reflect its lower contribution in reducing fatalities compared to minimum
testing requirements. PM13 is estimated to reduce the number of fatalities and injuries in MS with
no testing requirements by 1.19% relative to the baseline and in MS with no training requirements
by 0.59%.
Table 208: Estimated impact of PM13 on fatalities and injuries
Variable Value Label Calculation
MS which lack testing minimum requirements
& training
EE, FR, IE, LV and
LU
(a)
MS which only lack minimum training
requirements
BE, DK, DE, EE, FR,
IE, LV, LU, BG, FI,
IT, NL, PL and PT
(b)
Weighting of fatality contribution due to the
lack of training requirements
50% (c)
Share of fatalities in MS which lack testing and
training minimum requirements in EU total
13% (d)
Share of fatalities in MS which lack training
minimum requirements in EU total
69% (e)
Share of crashes where N2/N3 cargo defects
played a role
25% (f)
Share of vehicles undergoing RSI annually 5% (g)
Failure rate of cargo inspections in detecting
unsafe cargo loading
5% (h)
% reduction in fatalities/injuries for
affected MS with no testing requirements
1.19% (i) (i)=(f) x (g) x (1-(h))
% reduction in fatalities/injuries for
affected MS with no training requirements
0.59% (j) (j)=(f) x (g) x (1-(h)) x (c)
Source: Ricardo et al. (2024), Impact assessment support study
4.1.11. PM14 - Extend the scope of application of roadside inspections to light commercial (N1)
vehicles
PM14 extends the scope of application of roadside inspections to N1 vehicles, and sets 2% as target
for the share of inspections of the N1 vehicle fleet. On the basis of the information available, few
Member States (ES, HU, SE, SK and FI) already conduct roadside inspections for N1 vehicles,
417
Cargo securing for road transport - Publications Office of the EU (europa.eu)
208
although without a certain target set and thus checking a low number of vehicles. For the purposes
of the assessment it is assumed that these five Member States will not be affected.
The inspections in the 22 Member States affected are expected to lead to the identification of
defective vehicles and thus lead to the restoration of their safe vehicle status, with positive impacts
on safety.
The failure rate of inspections in detecting defective vehicles is assumed at 5%. Further, the
effectiveness of RSI to identify defective vehicles is considered to be 3 times higher than that of PTI
tests (due to the more targeted approach adopted in selecting vehicles for the tests). Also considering
the annual target of 2% of the N1 fleet being inspected and the fact that 4% of N1 vehicle accidents
are directly caused by technical defects, the reduction in the number of fatalities and injuries for the
22 Member States affected is estimated at 0.23% relative to the baseline.
Table 209: Analysis of expected impact of PM14 on fatalities and injuries
Variable Value Label Calculation
Share of EU fleet in MS affected 77% (a)
Share of EU fatalities in MS affected in EU total 89% (b)
Share of N1 vehicle accidents directly caused by
technical defects
4% (c)
Share of N1 vehicles inspected 2% (d)
Parameter reflecting RSI enhanced capacity to
identify defective vehicles
3.0 (e)
Failure rate of inspections in detecting defective
vehicles
5% (f)
% reduction in fatalities/injuries for affected
MS
0.23% (g) (g)=(1–(f)) x (c) x (d) x
(e)
Source: Ricardo et al. (2024), Impact assessment support study
4.1.12. PM15 - Extend the scope of application of roadside inspections to 2- and 3-wheeled vehicles
(L-vehicles from L3)
PM15 extends the scope of application of roadside inspections to 2- and 3-wheeled vehicles (L-
vehicles from L3) and establishes a threshold of 1% of the vehicle fleet for roadside inspections.
Few Member States (SE, SI, AT, FI, DK, HU, RO) already perform such inspections although they
do not report the exact number of inspections of motorcycles separately and do not indicate a specific
target. In the absence of more specific data it is assumed that these Member States will not be affected
by PM15.
The failure rate of inspections in detecting defective vehicles is assumed at 5%. Further, the
effectiveness of RSI to identify defective vehicles is considered to be 3 times higher than that of PTI
tests (due to the more targeted approach adopted in selecting vehicles for the tests). Also considering
the annual target of 1% of the N1 fleet being inspected and the fact that 6% of motorcycle-related
accidents are directly caused by technical defects, the reduction in the number of fatalities and injuries
for the 20 Member States affected is estimated at 0.17% relative to the baseline.
209
Table 210: Estimated impact of PM15 on fatalities and injuries
Variable Value Label Calculation
Share of fleet in MS affected in EU total 92% (a)
Share of EU fatalities in MS affected in EU
total
91% (b)
Share of accidents directly caused by
motorcycle technical defects
6% (c)
Share of motorcycles inspected 1% (d)
Parameter reflecting RSI enhanced capacity to
select defective vehicles
3.0 ( e)
Failure rate of inspections in detecting
defective vehicles
5% (f)
% reduction in fatalities/injuries for
affected MS
0.17% (g) (1 – (f)) x (c) x (d) x (e)
Source: Ricardo et al. (2024), Impact assessment support study
4.1.13. Impact on safety by policy option
On the basis of the analysis of the impacts of each individual measure, the combined impact of the
measures for each policy option is estimated using the common residual method explained above.
The tables below summarise the expected impact on fatalities and injuries relative to the baseline (%
change from the baseline) for each policy option, by Member State and vehicle type. These are used
as inputs in the PRIMES-TREMOVE model to derive the number of fatalities and injuries avoided,
as well as the reduction in the external costs of accidents.
Table 211: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline,
for M1 vehicle category
PO1a PO1b PO2 PO3
AT 1.5% 1.5% 1.5% 1.5%
BE 1.5% 1.5% 1.5% 1.5%
BG 1.5% 1.5% 1.5% 1.5%
CY 1.5% 2.7% 2.7% 2.7%
DE 1.5% 2.7% 2.7% 2.7%
EE 1.5% 1.5% 1.5% 1.5%
FI 1.5% 1.5% 1.5% 1.5%
FR 1.5% 2.7% 2.7% 2.7%
EL 1.5% 2.7% 2.7% 2.7%
HR 1.5% 1.5% 1.5% 1.5%
HU 1.5% 2.7% 2.7% 2.7%
IE 1.5% 1.5% 1.5% 1.5%
IT 1.5% 2.7% 2.7% 2.7%
LT 1.5% 2.7% 2.7% 2.7%
LU 1.5% 1.5% 1.5% 1.5%
LV 1.5% 1.5% 1.5% 1.5%
210
PO1a PO1b PO2 PO3
MT 1.5% 2.7% 2.7% 2.7%
NL 1.5% 1.5% 1.5% 1.5%
PL 1.5% 1.5% 1.5% 1.5%
PT 1.5% 1.5% 1.5% 1.5%
RO 1.5% 1.5% 1.5% 1.5%
SE 1.5% 1.5% 1.5% 1.5%
SI 1.5% 1.5% 1.5% 1.5%
SK 1.5% 2.7% 2.7% 2.7%
ES 1.5% 1.5% 1.5% 1.5%
DK 1.5% 2.7% 2.7% 2.7%
CZ 1.5% 2.7% 2.7% 2.7%
Source: Ricardo et al. (2024), Impact assessment support study
Table 212: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline,
for N1 vehicle category
PO1a PO1b PO2 PO3
AT 0.5% 0.5% 0.7% 0.7%
BE 0.5% 0.5% 0.7% 0.7%
BG 0.5% 0.5% 0.7% 0.7%
CY 0.5% 1.4% 1.6% 1.6%
DE 0.5% 1.4% 1.6% 1.6%
EE 0.5% 0.5% 0.7% 0.7%
FI 0.5% 0.5% 0.5% 0.5%
FR 0.5% 1.4% 1.6% 1.6%
EL 0.5% 1.4% 1.6% 1.6%
HR 0.5% 0.5% 0.7% 0.7%
HU 0.5% 1.4% 1.4% 1.4%
IE 0.5% 0.5% 0.7% 0.7%
IT 0.5% 1.4% 1.6% 1.6%
LT 0.5% 1.4% 1.6% 1.6%
LU 0.5% 0.5% 0.7% 0.7%
LV 0.5% 0.5% 0.7% 0.7%
MT 0.5% 1.4% 1.6% 1.6%
NL 0.5% 0.5% 0.7% 0.7%
PL 0.5% 0.5% 0.7% 0.7%
PT 0.5% 0.5% 0.7% 0.7%
RO 0.5% 0.5% 0.7% 0.7%
SE 0.5% 0.5% 0.5% 0.5%
SI 0.5% 0.5% 0.7% 0.7%
SK 0.5% 1.4% 1.4% 1.4%
ES 0.5% 0.5% 0.5% 0.5%
DK 0.5% 1.4% 1.6% 1.6%
CZ 0.5% 1.4% 1.6% 1.6%
Source: Ricardo et al. (2024), Impact assessment support study
211
Table 213: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline,
for N2/N3 vehicle categories
PO1a PO1b PO2 PO3
AT 0.5% 0.5% 0.5% 0.5%
BE 0.5% 0.5% 0.5% 0.5%
BG 0.5% 1.1% 1.1% 1.1%
CY 0.5% 0.5% 0.5% 0.5%
DE 0.5% 0.5% 0.5% 0.5%
EE 0.5% 1.7% 1.7% 1.7%
FI 0.5% 1.1% 1.1% 1.1%
FR 0.5% 1.7% 1.7% 1.7%
EL 0.5% 0.5% 0.5% 0.5%
HR 0.5% 1.1% 1.1% 1.1%
HU 0.5% 0.5% 0.5% 0.5%
IE 0.5% 1.7% 1.7% 1.7%
IT 0.5% 1.1% 1.1% 1.1%
LT 0.5% 0.5% 0.5% 0.5%
LU 0.5% 1.7% 1.7% 1.7%
LV 0.5% 1.7% 1.7% 1.7%
MT 0.5% 0.5% 0.5% 0.5%
NL 0.5% 1.1% 1.1% 1.1%
PL 0.5% 1.1% 1.1% 1.1%
PT 0.5% 1.1% 1.1% 1.1%
RO 0.5% 0.5% 0.5% 0.5%
SE 0.5% 1.1% 1.1% 1.1%
SI 0.5% 0.5% 0.5% 0.5%
SK 0.5% 0.5% 0.5% 0.5%
ES 0.5% 1.1% 1.1% 1.1%
DK 0.5% 0.5% 0.5% 0.5%
CZ 0.5% 0.5% 0.5% 0.5%
Source: Ricardo et al. (2024), Impact assessment support study
Table 214: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline,
for M2/M3 vehicle categories
PO1a PO1b PO2 PO3
AT 0.4% 0.4% 0.4% 0.4%
BE 0.4% 0.4% 0.4% 0.4%
BG 0.4% 0.4% 0.4% 0.4%
CY 0.4% 0.4% 0.4% 0.4%
DE 0.4% 0.4% 0.4% 0.4%
EE 0.4% 0.4% 0.4% 0.4%
FI 0.4% 0.4% 0.4% 0.4%
FR 0.4% 0.4% 0.4% 0.4%
EL 0.4% 0.4% 0.4% 0.4%
HR 0.4% 0.4% 0.4% 0.4%
HU 0.4% 0.4% 0.4% 0.4%
212
PO1a PO1b PO2 PO3
IE 0.4% 0.4% 0.4% 0.4%
IT 0.4% 0.4% 0.4% 0.4%
LT 0.4% 0.4% 0.4% 0.4%
LU 0.4% 0.4% 0.4% 0.4%
LV 0.4% 0.4% 0.4% 0.4%
MT 0.4% 0.4% 0.4% 0.4%
NL 0.4% 0.4% 0.4% 0.4%
PL 0.4% 0.4% 0.4% 0.4%
PT 0.4% 0.4% 0.4% 0.4%
RO 0.4% 0.4% 0.4% 0.4%
SE 0.4% 0.4% 0.4% 0.4%
SI 0.4% 0.4% 0.4% 0.4%
SK 0.4% 0.4% 0.4% 0.4%
ES 0.4% 0.4% 0.4% 0.4%
DK 0.4% 0.4% 0.4% 0.4%
CZ 0.4% 0.4% 0.4% 0.4%
Source: Ricardo et al. (2024), Impact assessment support study
Table 215: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline,
for L3-L7 vehicle categories
PO1a PO1b PO2 PO3
AT 0.0% 0.0% 0.0% 0.0%
BE 0.7% 2.2% 0.7% 2.7%
BG 0.0% 0.0% 0.0% 0.2%
CY 0.0% 0.0% 0.0% 0.2%
DE 0.0% 0.0% 0.0% 0.2%
EE 0.0% 0.0% 0.0% 0.2%
FI 0.7% 2.2% 0.7% 2.5%
FR 0.0% 0.0% 0.0% 0.2%
EL 0.0% 0.0% 0.0% 0.2%
HR 0.0% 0.0% 0.0% 0.2%
HU 0.0% 0.0% 0.0% 0.0%
IE 0.7% 2.2% 0.7% 2.7%
IT 0.0% 0.0% 0.0% 0.2%
LT 0.0% 0.0% 0.0% 0.2%
LU 0.0% 0.0% 0.0% 0.2%
LV 0.0% 0.0% 0.0% 0.2%
MT 0.7% 2.2% 0.7% 2.7%
NL 0.7% 2.2% 0.7% 2.7%
PL 0.0% 0.0% 0.0% 0.2%
PT 0.7% 2.2% 0.7% 2.7%
RO 0.0% 0.0% 0.0% 0.0%
SE 0.0% 0.0% 0.0% 0.0%
SI 0.0% 0.0% 0.0% 0.0%
SK 0.0% 0.0% 0.0% 0.2%
213
PO1a PO1b PO2 PO3
ES 0.0% 0.0% 0.0% 0.2%
DK 0.0% 2.2% 0.0% 2.5%
CZ 0.0% 0.0% 0.0% 0.2%
Source: Ricardo et al. (2024), Impact assessment support study
Table 216: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline,
for O1 vehicle category
PO1a PO1b PO2 PO3
AT 0.0%
BE 1.7%
BG 0.0%
CY 0.0%
DE 0.0%
EE 0.0%
FI 1.7%
FR 1.7%
EL 1.7%
HR 0.0%
HU 0.0%
IE 1.7%
IT 0.0%
LT 0.0%
LU 0.0%
LV 0.0%
MT 0.0%
NL 1.7%
PL 1.7%
PT 1.7%
RO 0.0%
SE 0.0%
SI 0.0%
SK 1.7%
ES 1.7%
DK 1.7%
CZ 0.0%
Source: Ricardo et al. (2024), Impact assessment support study
Table 217: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline,
for O2 vehicle category
PO1a PO1b PO2 PO3
AT 0.0%
BE 0.0%
BG 0.0%
CY 0.0%
DE 0.0%
EE 0.0%
214
PO1a PO1b PO2 PO3
FI 1.7%
FR 1.7%
EL 1.7%
HR 0.0%
HU 0.0%
IE 1.7%
IT 0.0%
LT 0.0%
LU 0.0%
LV 0.0%
MT 0.0%
NL 1.7%
PL 0.0%
PT 1.7%
RO 0.0%
SE 0.0%
SI 0.0%
SK 0.0%
ES 0.0%
DK 1.7%
CZ 0.0%
Source: Ricardo et al. (2024), Impact assessment support study
4.2. Impacts on air pollutant emissions and noise
4.2.1. Introduction
In the case of impacts on emissions and noise, the approach adopted was to estimate the expected
contribution of each measure on the identification and removal of high emitter vehicles (whether due
to defective emissions control systems or tampering) from the fleet. It is assumed that high emitters
identified will undergo repair (whether this refers to the replacement of malfunctioning filters, sensor
or sound control system or the necessary modifications of the engine). The focus of the analysis is
on high emitters only (i.e., vehicles with emissions multiple times higher than the type-approval
limits) as these are expected to be possible to capture during PTI and RSI or with the help of remote
sensing.
It should be noted that there is no standard definition of a high emitter418
. A pragmatic approach has
been used for the analysis, making use of information/data provided in relevant studies, while
recognising that they are not always consistent in the definition applied. Furthermore, it should be
noted that high emitters may be vehicles with defective emission or noise control systems or vehicles
with tampered emissions/noise control systems. In the absence of more detailed information, a 50%
418
One possible definition would be: a vehicle whose average emissions are at least 2 standard deviations
higher than the average emissions of the sample tested (https://pure.iiasa.ac.at/id/eprint/10156/1/XO-12-019.pdf). Euro
7 on-board monitoring principle sets detecting exceedances at a level of at least 2,5 times the relevant exhaust emission
limit value.
215
share of defective and tampered vehicles is assumed in the total share of high emitters in the fleet.
There is also a need to separate the two since it can be expected that tampered vehicles will not be
effectively captured as part of a PTI. Their owners may be expected to activate the relevant control
system before the PTI and then deactivate it again. This is possibly a simplification of reality so it is
assumed that only 10% of tampered vehicles will be captured as part of the PTI.
The analysis of the impacts on emissions focuses on the two pollutants that are targeted in the
proposed measures, namely, NOx and PN/PM. Other pollutants have not been considered in detail
although it is conceivable that, by identifying high emitters for these two categories of pollutants,
there may also be benefits related to other pollutant types (e.g. CO, HC, SO2).
4.2.2. Approach
The approach used to estimate the impacts on air pollutant emissions focuses on the extent to which
additional or more effective PTI and/or RSI inspections can help identify high emitter vehicles and,
by mandating repair, align the vehicle emissions with the type-approval values. As a result, these
would contribute to the reduction of the total emissions relative to the baseline.
The approach used for the assessment of the impacts of individual measures is based on the following
formula:
Percentage reduction of high emitters share = ((PTI_Share x (DEF + TAMP x PTI_TE) +
RSI_Share (DEF + TAMP) x RSI_EFF)) x IE / HE
Where:
• PTI_Share refers to share of vehicles in the fleet that are expected to be subject to PTI on an
annual basis. This is based on the scope of the measure, and determined by the vehicles average
age and the test frequency419
. Increased scope and frequency of PTI should in principle lead to a
higher share of high emitters identified in the fleet.
• RSI_Share refers to share of vehicles in the fleet that are expected to be subject to RSI inspection
on an annual basis. This is based on the scope of the measure. Increased scope of inspections
should in principle lead to a higher share of high emitters identified in the fleet.
• DEF refers to the share of vehicles with defective emissions or noise control systems in the fleet
in the baseline, for the specific vehicle category, fuel and EURO standard. In the absence of more
detailed data these are assumed to be half of the total high emitters for the specific vehicle
category, fuel and EURO standard.
• TAMP refers to the share of vehicles with tampered emissions or noise control systems in the
fleet in the baseline. They are assumed to represent the remaining half of the total high emitters
for the specific vehicle category, fuel and EURO standard.
• PTI_TE reflects the limited capacity of PTI to capture tampered vehicles. A share of 10% is
assumed to be captured as part of the PTI420
.
419
For example, in the case of an average vehicle lifetime of 15 years and a PTI frequency of 4/2/2 (four years for the
first inspection and 2 thereafter) we can calculate a total of 6.5 inspections until the age 15 which means an annual
frequency of 0.43 (=6.5/15) inspections. For L and O vehicle types the average vehicle age is 18 years and the total
number of inspections over the lifetime of the vehicle is 8, resulting in an annual frequency of 0.44 (=8/18).
420
Giechaskiel, B., et al., (2022), Effect of tampering on on-road and off-road diesel vehicle emissions. Sustainability,
14(10), p. 6065.
216
• RSI_EFF is relevant only in the case of measures including RSI and refers to the expected
enhanced effectiveness of targeted roadside inspections to identify vehicles with technical
defects when compared to the PTI (where there is no such targeted approach). A factor of three
is used421
. As example, if the fleet includes a 10% share of high emitters, RSI based on random
selection would identify 10 high emitters in 100 roadside inspections, while targeted RSIs are
expected to be able to identify 30 high emitters (3 x 10) in 100 roadside inspections.
• IE refers to the effectiveness of the specific test method used to identify high emitting vehicles.
This varies depending on the method used and is explained under the relevant policy measures.
• HE is the total share of high emitters in the baseline, equal to TAMP + DEF.
The above formula aims to identify the expected level of reduction of high emitters in the fleet, as a
percentage of the baseline figures. Namely, a 10% reduction relative to the baseline high emitters
shares of 10% will mean a reduction by one percentage point, leading to a new level of high emitters
of 9%. This can then be translated into actual emissions reductions, on the base of the emission factors
of high emitters defined in the baseline.
Furthermore, as in the case of safety, in order to calculate the combined effect of the policy measures
included in each option, the common residual method is applied:
CE A, B, C, … = 1−[(1-IA)x(1-IB)x(1-IC)x (1-…)]
Where:
• CE A, B, C denotes the combined effect of measures A, B, C, etc.
• IA, and IB and Ic correspond to the expected level of impact (in percentage terms) of each
measure.
Similarly to the impacts on road safety, the percentage reduction of high emitters by policy option
relative to the baseline is used as input in the PRIMES-TREMOVE model to calculate the reduction
in air pollutant emissions, and in the external costs of emissions and noise422
.
4.2.3. Key assumptions
As indicated above, an assumption is made on the limited capacity of PTIs to capture tampering.
These are those vehicles which are not brought back to their original pre-tampering state in view of
the testing. A share of 10% of tampered vehicles is assumed to be captured as part of the PTI423
. An
enhanced effectiveness factor of 3 is used for RSI to reflect its targeted character424
.
An additional important assumption made in the assessment of the impacts is that following the
identification of a high emitting vehicle and its repair/correction, while emission systems may not
421
Based on a comparison of the share of defective vehicles found at RSI in Member States applying targeted checks
(based on risk rating for the selection of HDVs) to those that select vehicles randomly, the factor of 3 is assessed to be a
conservative estimate. For LDVs, remote sensing will help selecting vehicles to be tested at roadside.
422
The 2019 Handbook on the external costs of transport (Source: https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs.
423
Giechaskiel, B., et al., (2022), Effect of tampering on on-road and off-road diesel vehicle emissions. Sustainability,
14(10), p. 6065.
424
Based on a comparison of the share of defective vehicles found at RSI in Member States applying targeted checks
(based on risk rating for the selection of HDVs) to those that select vehicles randomly, the factor of 3 is assessed to be a
conservative estimate. For LDVs, remote sensing will help selecting vehicles to be tested at roadside.
217
become as good as new, it can still be expected that any deterioration will be limited and will not
lead to vehicles becoming high emitters again until the next PTI. This is considered to be a reasonable
assumption, especially in the case of older vehicles where PTI frequency is higher. Since the analysis
and estimation of impacts on emissions is based on the expected reduction in the share of high
emitters, there is no risk of overestimation of the impacts due to the ongoing durability of the repairs
following PTI. Further to that, the role of roadside inspections towards achieving continuous
compliance should be noted, even if the number of roadside inspections are relatively small and
currently only cover heavy duty vehicles. Furthermore, enhanced durability of vehicles and
components (at least partly driven by legal requirements) can also help maintain the performance of
vehicles over time. Euro 7 standards, part of the baseline, are expected to extend the durability
requirements from the current levels of 100,000 km and 5 years (that do not cover older age vehicles),
to 200,000 km425
.
4.2.4. PMC3 - Mandatory PN testing of LDVs and HDVs equipped with particle filter, at PTI, and
of HDVs at technical roadside inspections of commercial vehicles
The implementation of PN emissions testing is expected to reduce the number of defective vehicles
with PN emissions consistently over the legal value (that is, not temporarily higher than the legal
requirement because of a just regenerated diesel particulate filter). PMC3 is thus expected to have an
impact on air pollutant emissions. No impact on noise emissions is expected due to PMC3.
The capacity of identifying faulty vehicles at PTI is assumed to be 95%. Some tampered vehicles
will also be identified during PTI. These are those vehicles which are not brought back to their
original pre-tampering state in view of the testing426
. In addition, following the DIAS427
example, the
share of fleet with defective emissions control system was assumed to be equal to the share of fleet
with tampered emission control system. As explained above, it is assumed that 10% of the tampered
vehicles are identified at PTI. The proportion of high emitters identified at PTI will also depend on
the percentage of vehicles that undergo PTI checks.
To estimate the impact of implementing the new PN test at PTI, the calculation is performed by using
as multiplicative factor (line (h) in the table below), the difference between the capabilities of
identifying high emitters by the new methodology (line (g) in the table below) and the capabilities of
identifying high emitters by the currently used methods (line (f) in the table below). Therefore, the
percentage of high emitters identified in PMC3 is calculated based on the table below, as: (h) x (e) x
((c) + (i) x (d)), where the letters stand for the labels of the lines in the table.
To obtain the reduction in high emitters relative to the baseline for the MSs affected (line (j) in the
table below), the percentage of high emitters identified in PMC3 is divided by the share of high
emitters in the baseline fleet (b).
The table below summarises, as example, the steps followed to calculate the expected reduction in
high emitters in the M1 diesel Euro 5 fleet brought by implementing PMC3.
425
Related to this a recent analysis by the UK government on the possible impact of a one year extension of the initial
inspection, estimated a possible increase in PTI failure in terms of emissions at 1 to 4.6%.
426
Giechaskiel, B., et al., (2022), Effect of tampering on on-road and off-road diesel vehicle emissions. Sustainability,
14(10), p. 6065.
427
DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations.
218
Table 218: Steps followed to estimate the impact of PMC3 on the M1 diesel Euro 5 fleet by age group relative to
the baseline
Label Calculation/ Assumption
Vehicle category M1 diesel Euro 5
MS affected All MSs except for NL, DE, BE
Age group 0-4 5-9 10-14 15-19
Share of vehicle fleet in
measure scope (per age group)
65% 67% 92% 97% (a) PRIMES-TREMOVE
baseline
Share of high emitters in the
fleet in the baseline
2.5% 5.0% 7.5% 10% (b) See section on the baseline
Share of fleet with defective
emissions control systems
1.25% 2.50% 3.75% 5.00% (c) 50% x (b)
Share of fleet with tampered
emission control systems
1.25% 2.50% 3.75% 5.00% (d) 50% x (b)
% of vehicles that undergo PTI
checks per year (per age group)
24% 65% 79% 80% (e) Estimation based on the MSs
frequencies for PTIs
Accuracy of current PTI
emission test at identifying
tampered/defective emission
control systems
3.6% 3.6% 3.6% 3.6% (f) The same level of accuracy
is assumed as for the current
NOx test (Boveroux & al,
2021)
PTI capacity to identify faulty
vehicles (% of total)
95% 95% 95% 95% (g) Assumption
Change in detection accuracy
due to the introduction of PN
PTI testing
91.4% 91.4% 91.4% 91.4% (h) (h) = (g) - (f)
Share of tampered vehicles
identified at PTI
10% 10% 10% 10% (i) Assumption
% reduction in the level of
high emitters relative to the
baseline for MS affected
12% 33% 40% 40% (j) (j)= (h) x (e) x ((c) + (i) x
(d))/(b)
% reduction in the level of
high emitters - total EU fleet
8% 22% 37% 38% (k) (k) = (j) x (a)
% of high emitters in the fleet
following the implementation
of the measure
2.2% 3.4% 4.5% 6% (l) (l) = (b) - (j) x (b)
Source: Ricardo et al. (2024), Impact assessment support study
For HDVs, PMC3 envisages to use the new PN measuring methodology at RSI as well (in addition
to PTI). The table below presents first the methodology for assessing the impacts on emissions due
to PTI for HDVs, which is similar to the one for M1 vehicles explained above. The second part of
the table presents the methodology for assessing the impacts on emissions due to RSI.
Roadside inspections have the capability of identifying both defective and tampered emission
systems. Therefore, no factor is used representing the limited capacity to capture tampering (as in the
case of PTI). It is reasonable to expect that the combination of PN checks at both roadside and PTI
will also have some deterrent effect on tampering, but this is not possible to quantify.
The proportion of high emitting HDVs identified at RSI will be proportional to the percentage of
vehicles that undergo RSI checks (assumed at 5%), to the capacity of portable PN measuring devices
219
to identify faulty vehicles (assumed 95% as for measurements at PTI), and to the share of fleet with
defective/tampered emissions control systems. Furthermore, the effectiveness factor reflecting the
targeted nature of RSI is used in the calculations.
The proportion of identified high emitting HDVs at RSI due to PMC3, based on the table below, is
given by the product (k) x (l) x (m) x (b), where the letters stand for the labels of the lines in the table.
The reduction in high emitters relative to the baseline is provided in line (n) in the table below.
The combined impact of PN checks at both PTI and RSI on HDVs is estimated as the sum of the
impacts of the PTI and RIS inspections minus their product and is provided in line (o) of the table
below.
The table below summarises, as example, the steps followed to estimate the reduction in high emitters
in the HDVs Euro VI fleet due to PMC3, relative to the baseline.
Table 219: Steps followed to estimate the impact of PMC3 on HDVs Euro VI fleet by age group
Label Calculation/
Assumption
Vehicle category N2/N3/M2/M3 Euro VI
MS affected PTI checks: all MSs except NL, DE, BE
RSI checks: all MSs
Age group 0-4 5-9 10-14 15-19
Share of vehicle fleet in
measure scope (per age group)
85% 88% 95% 97% (a) PRIMES-TREMOVE
baseline
Share of high emitters in the
fleet in the baseline
7.2% 8.8% 10.4% 12.0% (b) See baseline section
Share of fleet with defective
emissions control system
3.6% 4.4% 5.2% 6.0% (c) 50% x (b)
Share of fleet with tampered
emission control system
3.6% 4.4% 5.2% 6.0% (d) 50% x (b)
% of vehicles that undergo
PTI checks per year (per age
group)
100% 100% 100% 100% (e) Estimation based on
the MSs frequencies
for PTIs
Accuracy of current PTI
emission test at identifying
tampered/defective emission
control systems
3.6% 3.6% 3.6% 3.6% (f) The same level of
accuracy is assumed
as for the current
NOx test (Boveroux
& al, 2021)
PTI capacity to identify faulty
vehicles (% of total)
95% 95% 95% 95% (g) Assumption
Change in detection accuracy
due to introduction of PN-PTI
testing
91.4% 91.4% 91.4% 91.4% (h) (h) = (g) – (f)
Share of tampered vehicles
identified at PTI
10% 10% 10% 10% (i) Assumption
% reduction in the level of
high emitters from baseline
for MS affected (PTI only)
50% 50% 50% 50% (j) (j) = (h) x (e) x ((c) +
(i) x (d))/(b)
220
Label Calculation/
Assumption
Vehicle category N2/N3/M2/M3 Euro VI
MS affected PTI checks: all MSs except NL, DE, BE
RSI checks: all MSs
Age group 0-4 5-9 10-14 15-19
% reduction in the level of
high emitters from baseline -
EU fleet (PTI only)
43% 44% 48% 49% (k) (k) = (j) x (a)
Share of fleet checked at RSI 5% 5% 5% 5% (l) Assumption
PN portable equipment
effectiveness at RSI
95% 95% 95% 95% (m) Assumption
RSI effectiveness factor 3 3 3 3 (n) Assumption
% reduction in high emitters
(RSI only)
14% 14% 14% 14% (o) (o) = (l) x (m) x (n) x
(b) / (b)
% reduction in high emitters
from baseline (RSI only) -
EU fleet
12% 13% 14% 14% (p) (p) = (o) x (a)
% reduction in level of high
emitters (combination RSI
and PTI)
57% 57% 57% 57% (q) (q) = (j) + (o) – (j) x
(o)
% reduction in the level of
high emitters in EU fleet
(combination RSI and PTI)
49% 51% 54% 56% (r) (r) = (q) x (a)
% of high emitters in the
fleet following the
implementation of the
measure
3.7% 4.3% 4.7% 5.3% (s) (s) = (b) – (r) x (b)
Source: Ricardo et al. (2024), Impact assessment support study
The tables below summarise the estimated reduction, relative to the baseline, in the share of high
emitters due to checks at PTI for LDVs and at PTI and RSI for HDVs (defined as the percentage of
high emitters identified divided by the baseline share of high emitters). The estimates are presented
for diesel vehicles only, as the PN measurement method is still under development for petrol vehicles.
Table 220: Reduction in the share of PN high emitters for M1 and N1 diesel vehicles (all Euro standards) by age
group relative to the baseline
Age group
(years)
Reduction in high emitters
relative to the baseline M1
and N1
Reduction in high emitters in
EU fleet
M1 diesel
Reduction in high emitters in
EU fleet
N1 diesel
0-4 12% 8% 9%
5-9 33% 22% 24%
10-14 40% 37% 33%
15-19 40% 38% 36%
Source: Ricardo et al. (2024), Impact assessment support study
221
Table 221: Reduction in the share of PN high emitters due to PTI only, RSI only, and their combined impact on
N2/N3/M2/M3 vehicles (all Euro standards) by age group relative to the baseline
Age
group
(years)
Reduction in
high emitters
from baseline
(PTI only)
Reduction in
high emitters
in EU fleet
(PTI only)
Reduction in
high emitters
from baseline
(RSI only)
Reduction in
high emitters
in EU fleet
(RSI only)
Reduction in
high
emitters
from
baseline
(PTI + RSI)
Reduction in
high emitters
in EU fleet
(PTI + RSI)
0-4 50% 43% 14% 12% 57% 49%
5-9 50% 44% 14% 13% 57% 51%
10-14 50% 48% 14% 14% 57% 54%
15-19 50% 49% 14% 14% 57% 56%
Source: Ricardo et al. (2024), Impact assessment support study
4.2.5. PMC4 – Mandatory NOx-testing of LDV and HDV at PTI, and HDVs at roadside
inspections
This measure is similar to PMC3 but applies NOx testing. PMC4 will introduce mandatory NOx
emission testing during PTI for LDVs and HDVs (from Euro 5b and Euro VI respectively) and at
RSIs (for HDVs from Euro VI). As a result, the number of defective LDVs and HDVs with NOx
emissions over the legal value is expected to decrease. PMC4 is thus expected to have an impact on
air pollutant emissions. No impact on noise emissions is expected due to PMC4.
The approach used to estimate the impacts is similar to that for PMC3, described in Section 4.2.4.
The assumption used for the NOx measuring devices is that the capacity of identifying faulty vehicles
is 95% for both the equipment used at PTI and at RSI. Similarly to PMC3, it is assumed that only
10% of the tampered vehicles are identified at PTI. The LDV and HDV fleets of all EU Member
States are expected to be affected by this measure, as none of the MSs are currently measuring NOx
emissions.
For RSI, similarly to PMC3, a factor of 3 is used to represent their effectiveness relative to PTI, to
take into account that the inspections are usually not random but targeted.
The tables below summarise the estimated reduction, relative to the baseline, in the share of high
emitters due to checks at PTI for LDVs and at PTI/RSI for HDVs (defined as the percentage of high
emitters identified divided by the baseline share of high emitters).
Table 222: Reduction in the share of NOx high emitters for M1 and N1 diesel and petrol vehicles (all Euro
standards) by age group relative to the baseline
Age group (years) Reduction in high emitters relative to the baseline
Petrol and diesel M1 and N1
0-4 13%
5-9 34%
10-14 41%
222
Age group (years) Reduction in high emitters relative to the baseline
Petrol and diesel M1 and N1
15-19 42%
Source: Ricardo et al. (2024), Impact assessment support study
Table 223: Reduction in the share of NOx high emitters due to PTI only, RSI only, and their combined impact on
N2/N3/M2/M3 vehicles (all Euro standards) by age group relative to the baseline
Age group
(years)
Reduction in high emitters
from baseline (PTI only)
Reduction in high emitters
from baseline (RSI only)
Reduction in high emitters
from baseline (PTI + RSI)
All age groups 52% 14% 59%
Source: Ricardo et al. (2024), Impact assessment support study
4.2.6. PM1 - RSI for heavy/powerful motorcycles (L category > 125cm3) as alternative measure,
in the Member States where they are not subject to PTI (i.e., using available opt-out)
PM1 will require that those Member States (BE, FI, IE, NL, MT, PT)428
that do not have a PTI
requirement for motorcycles introduce roadside inspections for motorcycles over 125 cc as an
alternative. The roadside inspections are expected to cover 5% of the number of motorcycles
registered every year. The motorcycle fleet of these Member States represent on average 8.6% of the
fleet over 2026-2050. Furthermore, as the measure does not cover L3-L7 motorcycles of less than
125cc, the scope of the measure is also reduced (84.2% of the total L3-L7 on average over 2026-
2050).
The share of high emitters of air pollution and noise emissions in the baseline is assumed at 8% and
30%, respectively, based on limited information from the literature and the PTI data analysis (see
baseline section).
PM1 is expected to have an impact on air pollutant emissions and noise emissions. Similar to the
approach used for assessing the impacts on road safety, the failure rate of inspections in detecting
defective vehicles is assumed at 5%. To reflect the enhanced effectiveness of RSI in targeting
defective vehicles compared to PTI, a factor of 3 is used. The proportion of motorcycle undergoing
roadside inspections (5%) and the share of motorcycles in the scope of the measure is also taken into
account in the assessment.
The share of high emitters of air pollutant emissions and noise is estimated to reduce by 12% in the
MS affected (1% at the EU level) due to PM1, relative to the baseline.
Table 224: Estimated impact of PM1 on the share of high emitters of air pollutant emissions and noise
Variable Emissions Noise Label Calculation
MS affected FI, NL, MT, PT, BE, IE
428
Until end 2023, France had not introduced mandatory PTI for motorcycles, but the French authorities had announced
the intention to do so. For this reason, for the purposes of the analysis it was assumed that France would not be affected
by the proposed measure. Denmark does not have mandatory PTI but since it has introduced roadside inspections, and it
is thus assumed to be part of the baseline. In the case of Portugal, current requirements cover only motorcycles over
250cc.
223
Variable Emissions Noise Label Calculation
Share of EU fleet affected 8.6% (a)
Share of vehicle fleet in measure scope 84.2% (b)
Share of fleet inspected in RSI 5% (c)
RSI effectiveness factor 3.0 (d)
Share of high emitters in the fleet in the
baseline (emissions/noise)
8% 30% (e)
Share of fleet with defective emissions/noise
control systems
(emissions/noise)
4% 15% (f) 50% x (e)
Share of fleet with tampered emission/noise
control systems (emissions/noise)
4% 15% (g) 50% x (e)
Failure rate of inspections in detecting
defective vehicles
5% (h)
% reduction in the share of high emitters
relative to the baseline in the Member
States affected (emissions/noise)
12% (i) (i) = (1 – (h)) x (c) x (d) x
(b)
% reduction in the share of high emitters
relative to the baseline at EU level
(emissions/noise)
1% (j) (j) = (i) x (a)
% of high emitters in the fleet following the
implementation of the measure
(emissions/noise)
7% 26% (k) (k) = (e) - (e) x (i)
Source: Ricardo et al. (2024), Impact assessment support study
4.2.7. PM2 - Mandatory PTI for motorcycles above 125cm3 (remove current opt-out)
PM2 introduces mandatory PTI for all motorcycles over 125cm3 (removing opt-out). Besides the
Member States identified in PM1, Denmark will also need to introduce PTI for motorcycles over
125cm under PM2. Thus, the Member States affected by PM2 are BE, DK, FI, IE, MT, NL and PT.
PM2 is expected to have an impact on air pollutant emissions and noise emissions. The impact of
PM2 is based on the expected effectiveness of PTI for motorcycles to identify high emitters, applying
the emission measurements and test methods already considered in PMC3 and PMC4. Considering
the MS affected by PM2, the measure is expected to have an impact on a small share of the EU fleet
(8.8%)429
. Furthermore, as it does not encompass all motorcycle categories (only L3-L7, except L3-
1a), a reduced scope is used to estimate the impacts on the total motorcycle fleet (85.9%)430
.
429
This reflects the average over 2026-2050 based on the PRIMES-TREMOVE baseline.
430
This reflects the average over 2026-2050 based on the PRIMES-TREMOVE baseline.
224
The share of high emitters of air pollution and noise emissions in the baseline is assumed at 8% and
30%, respectively, based on limited information from the literature and the PTI data analysis (see
baseline section).
Similar to the approach used for assessing the impacts of PM1, the failure rate of inspections in
detecting defective vehicles is assumed at 5%. The impact will also depend on the expected frequency
of the PTI inspections which has been assumed to be the minimum one provided for M1/N1 vehicles
in the Directive (4/2/2), leading to an average frequency of 0.44 inspections per year431
. In addition,
it is assumed that 10% of the tampered vehicles are identified at PTI. The share of motorcycles in the
scope of the measure is also taken into account in the assessment.
The share of high emitters of air pollutant emissions and noise is estimated to reduce by 20% in the
MS affected (1.7% at the EU level) due to PM2, relative to the baseline.
Table 225: Estimated impact of PM2 on the share of high emitters of air pollutant emissions and noise
Variable Emissions Noise Label Calculation
MS affected BE, DK, FI, IE, MT, NL, PT
Share of EU fleet affected 8.8% (a)
Share of vehicle fleet in measure scope 85.9% (b)
Share of high emitters in the fleet in the
baseline (emissions / noise)
8% 30% (c)
Share of fleet with defective emissions
control systems
4% 15% (d) 50% x (c)
Share of fleet with tampered emission
control systems
4% 15% (e) 50% x (c)
% of vehicles that undergo PTI per year 44% (f) 4/2/2 over 18 years (i.e., 8
inspections)
PTI capacity to identify tampering (% of
total)
10% (g)
Failure rate of inspections in detecting
defective vehicles
5% (h)
% reduction in the share of high
emitters relative to the baseline in the
Member States affected
(emissions/noise)
20% (i) (i) = (f) x ((g) x (e) + (d)) x (1
– (h)) x (b) / (c)
% reduction in the share of high
emitters relative to the baseline at EU
level (emissions/noise)
1.7% (j) (j) = (i) x (a)
431
For L vehicle types the average vehicle age is 18 years and the total number of inspections over the lifetime of the
vehicle is 8 resulting in an annual frequency of 0.44 (=8/18).
225
Variable Emissions Noise Label Calculation
% of high emitters in the fleet following
the implementation of the measure
(emissions/noise)
6.4% 24% (k) (k) = (c) - (c) x (i)
Source: Ricardo et al. (2024), Impact assessment support study
4.2.8. PM3 - Extend PTI to all motorcycles (i.e., including from 50cm3 = all L3e, L4e, plus
tricycles (L5e) and heavy quadricycles (L7e))
PM3 extends the type of motorcycles covered by PTI to those from 50cm3 in the eight Member States
where such requirement is currently not in place (BE, FI, IE, NL, MT, PT, DK, CY432
).
The approach followed for the assessment is the same as in the case of PM2. The only difference is
that the extended scope of the measure to cover vehicles over 50cm3 leads to increased share of the
fleet affected as shown in the table below.
The share of high emitters of air pollutant emissions and noise is estimated to reduce by 23.2% in the
MS affected (2.4% at the EU level) due to PM3, relative to the baseline.
Table 226: Estimated impact of PM3 on the share of high emitters of air pollutant emissions and noise
Variable Emissions Noise Label Calculation
MS affected BE, FI, IE, NL, MT, PT, DK,
CY
Share of EU fleet affected 10.2% (a)
Share of vehicle fleet in measure scope 100% (b)
Share of high emitters in the fleet in the
baseline (emissions/noise)
8% 30% (c)
Share of fleet with defective emissions
control systems (emissions/noise)
4% 15% (d) 50% x (c)
Share of fleet with tampered emission control
systems (emissions/noise)
4% 15% (e) 50% x (c)
% of vehicles that undergo PTI per year 44% (f) 4/2/2 over 18 years
(i.e., 8 inspections)
PTI capacity to identify tampering (% of
total)
10% (g)
Failure rate of inspections in detecting
defective vehicles
5% (h)
% reduction in the share of high emitters
relative to the baseline in the Member
States affected (emissions/noise)
23.2% (i) (i) = (f) x ((g) x (e) +
(d)) x (1 – (h)) x (b) /
(c)
432
In Cyprus motorcycles above 125cm3 are already covered.
226
Variable Emissions Noise Label Calculation
% reduction in the share of high emitters
relative to the baseline at EU level
(emissions/noise)
2.4% (j) (j) = (i) x (a)
% of high emitters in the fleet following the
implementation of the measure
(emissions/noise)
6.1% 23% (k) (k) = (c) - (c) x (i)
Source: Ricardo et al. (2024), Impact assessment support study
4.2.9. PM5 - Annual emission testing for light commercial vehicles (N1) instead of the currently
required 4-2-2 frequency
PM5 includes a requirement for annual emission testing for light commercial vehicles (N1) instead
of the currently required 4-2-2 frequency. It assumes additional emission testing in all Member States.
While certain Member States (e.g. LT and FR) apply yearly (emission) testing from a certain vehicle
age, this means smoke opacity test or EOBD test that are not considered effective. PM5 is expected
to have an impact on air pollutant emissions. No impact on noise emissions is expected due to PM5.
Based on the DIAS study433
, it is assumed that 50% of the high emitters are caused by tampering. As
tampering of vehicles is more difficult to detect, the emission test is assumed to only detect 10% of
the tampered vehicles. The accuracy of the new PTI emission test at identifying tampered/defective
emission control systems is assumed at 95%. Taking also into account the share of the age group in
the vehicle fleet and the percentage increase in the number of inspections, the table below provides
the calculations and impact on the share of high emitters of air pollutant emissions for the 0-4 age
group.
Table 227: Estimated impact of PM5 on the share of high emitters of air pollutant emissions for the 0-4 years age
group
Variable Value Label Calculation
Share of EU vehicle fleet in measure scope 100% (a)
Share of age group in N1 fleet 18.7% (b)
Percentage increase in inspections across
EU27
34% (c)
Percentage of high emitter vehicles which are
tampered
50% (d)
PTI capacity to identify tampering (% of
total)
10% (e)
Share of vehicles with tampered or defective
emission systems which are detected
55% (f) (f) = (d) + (b) x (e)
Accuracy of new PTI emission test at
identifying tampered/defective emission
control systems
95% (g)
433
DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations.
227
Variable Value Label Calculation
% reduction in the share of high emitters
at the EU level compared to the baseline
16.93% (h) (h) = (a) x (c) x (g) x (f)
Source: Ricardo et al. (2024), Impact assessment support study
The percentage reductions in the shares of high emitters across the EU for four age groups of the N1
vehicle category are shown in the table below. The differences between age groups are due to the
additional number of inspections relative to the baseline and the share of each age group in the N1
vehicle fleet.
Table 228: Estimated reduction of the share of high emitters of air pollutant emissions for N1 vehicles, by age
group
Variable Age group
Vehicle age group (years) 0-4 5-9 10-14 15-19
% reduction in the share of high emitters in the fleet at EU
level compared to the baseline
16.93% 16.13% 1.89% 1.88%
Source: Ricardo et al. (2024), Impact assessment support study
4.2.10. PM6 - Mandatory yearly testing for vehicles that are 10-year-old or older
Currently, 11 MS do not require annual PTI testing of light-duty vehicles after 10 years of their
registration (CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT, SK). All these Member States currently
require an inspection every two years which means that the proposed measure will double the number
of inspections for vehicles over 10 years. PM6 is expected to have an impact on air pollutant
emissions. No impact on noise emissions is expected due to PM6.
Based on the DIAS study434
, it is assumed that 50% of the high emitters are caused by tampering. As
tampering of vehicles is more difficult to detect, the emission test is assumed to only detect 10% of
the tampered vehicles. The accuracy of the new PTI emission test at identifying tampered/defective
emission control systems is assumed at 95%. The reduction in the share of high emitters in the
affected MS is calculated by also taking into account the increase in the number of inspections for
the N1 and M1 vehicle categories relative to the baseline. To calculate the percentage reduction in
the share of high emitters in the fleet at EU level compared to baseline, the share of EU fleet affected
is further taken into account.
The calculation approach for the 10-14 years age group of M1 and N1 vehicles is provided in the
table below.
Table 229: Estimated impact of PM6 on the share of M1 and N1 high emitters of air pollutant emissions for the
10-14 years age group
Variable M1 values (a) N1 values (b) Label Calculation
MS affected by measure CY, DE, LT, CZ,
DK, FR, EL, HU,
IT, MT, SK
CY, DE, LT,
CZ, DK, FR,
EL, HU, IT,
MT, SK
(a)
434
DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations.
228
Variable M1 values (a) N1 values (b) Label Calculation
Share of EU fleet affected 47% 49% (b)
% increase in the number of
inspections relative to the
baseline
33% 26% (c)
Percentage of high emitter
vehicles which are tampered
50% 50% (d)
PTI capacity to identify
tampering (% of total)
10% 10% (e)
Share of vehicles with tampered
or defective emission systems
which are detected
55% 55% (f) (f) = (d) + (b) x (e)
Accuracy of new PTI emission
test at identifying
tampered/defective emission
control systems
95% 95% (g)
% reduction in the share of
high emitters in the fleet in the
MS affected compared to
baseline
17.24% 13.59%
(h) (h) = (c) x (f) x (g)
% reduction in the share of
high emitters in the fleet at
EU level compared to baseline
8.08% 6.64%
(i) (i) = (h) x (b)
Source: Ricardo et al. (2024), Impact assessment support study
It is assumed that the vehicles older than 10 years are evenly distributed between the 10-14 years and
15-19 years age groups. This is also the case of the increase in the number of inspections relative to
the baseline. Therefore, the percentage reductions in the shares of N1 and M1 high emitters (line (f)
in the table above) are the same for the 10-14 years and 15-19 years age groups.
4.2.11. PM10 - More advanced testing of noise for motorcycles
PM10 requires that all Member States perform noise testing for motorcycles at PTI, inspired by the
procedure for pass-by noise test described in the UN Regulation no. 41. Four MSs (DE, ES, HR, SK)
currently require testing of noise for L-category vehicles at PTI. Even though the stringency and
effectiveness of current testing methods in these MS may be lower than the noise testing methods
proposed in UN Regulation 41 for pass-by noise tests, they represent a significant improvement
compared to the subjective assessment by the inspector, which is required by the PTI Directive. PM10
is expected to have an impact on noise emissions.
The measure is expected to affect 72% of the L3-7 vehicle fleet across the EU. The share of the
vehicle fleet which will be subject to the new advanced noise test each year is calculated by assuming
a standard PTI frequency for L-category vehicles of 4-2-2 and an average vehicle life of 18 years. In
addition, it is assumed that 50% of the high noise-emitting motorcycles are caused by tampering and
50% by defective noise control systems. As tampering of vehicles is more difficult to detect during
PTI, the advanced noise test is assumed to only detect 10% of tampered vehicles during PTI.
229
The introduction of advanced noise testing for motorcycles is expected to reduce the share of high
emitter L vehicles by 22% in the MS affected, relative to the baseline. The approach for calculating
the reduction in the share of high emitter vehicles is provided in the table below.
Table 230: Estimated impact of PM10 on the share of noise high-emitter L vehicles in the fleet
Variable Values Label Calculation
Share of vehicle fleet in measure scope 72% (a) All MSs except for DE, ES,
HR, SK
Share of high emitters in the fleet in the baseline 30% (b)
Percentage of high emitter vehicles which are tampered 50% (c)
Proportion of high emitter vehicles due to defective
systems
50% (d)
PTI capacity to identify tampering (% of total) 10% (e)
Share of fleet inspected annually 44% (f) Estimate based on 4-2-2 PTI
frequency
Noise test effectiveness 90% (g)
Tampered vehicles identified at PTI 0.6% (h) (h) = (b) x (c) x (e) x (f) x (g)
Defective vehicles identified at PTI 6.0% (i) (i) = (b) x (d) x (f) x (g)
% reduction in the share of high emitter vehicles in
the fleet in the MS affected
22.0% (j) (j) = ((h) + (i))/(b)
% of high emitters in the fleet following the
implementation of the measure
23.4% (k) (k) = (b) – (b) x (j)
Source: Ricardo et al. (2024), Impact assessment support study
4.2.12. PM12 – NOx, PM, and noise measurement by remote sensing in RSI of all vehicles (with
option for simplified PTI if vehicle passed recent RSI)
PM12 requires NOx and PM measurement by remote sensing in technical roadside inspections of all
vehicle types, and optional plume chasing in technical roadside inspections of commercial vehicles.
In addition, acoustic cameras would need to be added to remote sensing equipment to measure noise
at the roadside. Thus, it is expected that PM12 will decrease the number of LDVs and HDVs with
tampered/faulty emission system leading to high exhaust of NOx and particle emissions, and also
decrease the number of M1, N1 vehicles and motorcycles with tampered/faulty exhaust system
leading to high noise emissions.
NOx and PN high emitter light duty and heavy duty vehicles
The potential reduction in high emitter vehicles depends on:
• the effectiveness of remote sensing (RS), which is intrinsically penalised by the short time scale
during which a measurement takes place, and by the possible contamination of the plume by near
vehicles, is assumed at 70% (line (c) in the table below). The effectiveness of plume chasing is
assumed to be 95% as for the RSI measurements (line (h) in the table below);
230
• the proportion of false positives (that is, vehicles wrongly identified as high emitters by remote
sensing and plume chasing) is assumed at 5% (line (e) in the table below);
• the capacity of identifying NOx and PN high emitters at RSI is assumed to be 95% (line (d) in the
table below);
• the target proportion of the fleet analysed by remote sensing is assumed to be 30% (line (f) in the
table below);
• the targeted proportion of the HDVs fleet analysed by plume chasing is assumed to be 3% (line
(i) in the table below); and
• the capacity of RSI, that is, the highest proportion of the whole LDV and HDV fleets that is
feasible to check through RSI is assumed to be 0.5% (line (b) in the table below).
The table below summarises the steps followed to estimate the impact of PM12 on the share of NOx
high emitters Euro VI HDVs relative to the baseline.
Remote sensing and plume chasing are used as a filtering tool for a better targeted RSI. The high
emitters flagged as high emitters, which contain both real high emitters and false positives, are sent
either to RSI (line (m) in the table below) or, in case the number of vehicles is too high compared to
the capacity of RSI, to a testing centre (PTI station) to be double checked.
The proportion of vehicles flagged as high emitters will be proportional to the percentage of the fleet
analysed, the remote sensing and plume chasing435
effectiveness and the share of high emitters in the
fleet.
In the case of HDVs, the option of plume chasing is added: it is possible to find high emitting HDVs
(line (k)) proportionally to the share of fleet measured via plume chasing (line (i)), and the plume
chasing capacity of identifying faulty vehicles (line (h)). For LDVs this additional share of identified
high emitters by plume chasing does not exist.
All vehicles flagged as potential high emitters by remote sensing and plume chasing will be sent to
RSI up to the RSI capacity of 0.5% of the fleet (b).
The proportion of the real high emitters identified at RSI (line (n) in the table below) will be the
product of the percentage of the fleet correctly identified as high emitter by RS and the effectiveness
of the test, that is: (n) = (m) x (d).
The share of vehicles identified by remote sensing as high emitters – including possible false positives
- that are not checked via RSI due to capacity limitations are to be sent to a PTI station for further
testing (o). This is multiplied by (1-(e)) to take into account the percentage of false positives (line (p)
in the table below), that is vehicles that are flagged as high emitters by remote sensing but that at a
second check are found emitting within the legal limit.
Of these vehicles, as in PMC4 (section 4.2.5) it is expected that half (50%) will be tampered and 50%
faulty. PTI is assumed to only be able to capture 10% of tampered vehicles as a large part of them
will be set to the pre-tampering stated before the inspection, while faulty ones will be captured with
an effectiveness of 95%. The high emitting vehicles captured at the PTI (line (u) in the table below)
are the combination of the tampered vehicles identified and the faulty vehicles identified.
435
Relevant only for HDVs.
231
The total high emitters identified are the sum of those captured by RSI and at PTI stations following
their screening by remote sensing and plume chasing – in the case of HDVs only (line (v) in the table
below). The percentage reduction in the share of high emitters, defined as the percentage of total high
emitters identified divided by the baseline share of high emitters is provided in line (z) of the table
below.
Table 231: Estimated impact of PM12 on the share of high emitters Euro VI HDVs, by age group, at EU level
(relative to the baseline)
Label Calculation/ Assumption
Vehicle category N2/N3/M2/M3 Euro VI
MS affected All MSs
Age group 0-4 5-9 10-14 15-19
Share of vehicle fleet in measure
scope (per age group)
100% 100% 100% 100%
Share of high emitters in the fleet
in the baseline
7.2% 8.8% 10.4% 12.0% (a) See the baseline section
Maximum RSI capacity (% of
whole fleet)
0.5% 0.5% 0.5% 0.5% (b)
Assumption
Remote sensing (RS) capacity to
identify faulty vehicles (% of high
emitters correctly identified by RS)
70% 70% 70% 70% (c)
Assumption
% high emitters correctly
identifiable by NOx/PN RSI test
95% 95% 95% 95% (d)
Assumption
Remote sensing and plume chasing
false positives (% of the vehicles
flagged as high emitters which are
not real high emitters)
5% 5% 5% 5% (e)
Assumption
Proportion of the fleet analysed by
remote sensing
30% 30% 30% 30% (f) Assumption
Proportion of the fleet identified
as high emitter by RS 1.51% 1.85% 2.18% 2.52% (g) (g) = (f) x (c) x (a)
Plume chasing capacity to identify
faulty vehicles
95% 95% 95% 95% (h)
Assumption
Share of fleet measured via plume
chasing
3% 3% 3% 3% (i)
Assumption
Share of fleet identified as high
emitters by plume chasing
0.21% 0.25% 0.30% 0.34% (k) (k) = (h) x (i) x (a)
Total share of fleet identified as
high emitters by remote sensing
and plume chasing
1.72% 2.10% 2.48% 2.86% (l) (l) = (k) + (g)
Sent to RSI (pre-selected by RS) 0.5% 0.5% 0.5% 0.5% (m)
if (l) <= (b), (m) =(l); otherwise
(m) = (b)
Proportion of the real high
emitters identified by RSI
0.48% 0.48% 0.48% 0.48% (n) (n) = (m) x (d)
Vehicles sent to PTI stations:
vehicles flagged as high emitters
by remote sensing and plume
chasing but not inspected at RSI
1.22% 1.60% 1.98% 2.36% (o) (o) = (l) – (m)
Vehicles sent to PTI stations
which are actually high emitters
1.16% 1.52% 1.88% 2.24% (p) (p) = (o) x (1- (e))
Share of high emitters that are
tampered
50% 50% 50% 50% (q) Assumption
232
Label Calculation/ Assumption
Vehicle category N2/N3/M2/M3 Euro VI
MS affected All MSs
Age group 0-4 5-9 10-14 15-19
Vehicles sent to PTI stations
which are high emitters because
they are tampered
0.58% 0.76% 0.94% 1.12% (r) (r) = (p) x (q)
PTI capacity to identify tampered
vehicles
10% 10% 10% 10% (s) Assumption
NOx/PN -PTI test effectiveness 95% 95% 95% 95% (t) Assumption
High emitters identified at PTI
stations
0.61% 0.80% 0.99% 1.18% (u) (u) = (r) x (s)+(1-(r)) x (t)
Total high emitters identified at
PTI stations and RSI
1.08% 1.27% 1.46% 1.65% (v) (v) = (u) + (n)
% reduction in the share of high
emitters (RS + RSI) relative to
the baseline
15.03% 14.46% 14.06% 13.78% (z) (z) = (v) / (a)
Source: Ricardo et al. (2024), Impact assessment support study
Noise emissions from N1, M1, and L-vehicles
Acoustic cameras can be installed before a RSI site to optimise the detection rates of N1, M1, and L-
vehicles emitting noise over the legal limit. Coupling with a PTI is a possibility; however, this is not
expected to be particularly effective in all cases of tampered vehicles, as for motorcycles, for
example, altering some parts of the exhaust system and reinstating their original settings is relatively
easy (for instance, removing/re-installing the muffler).
The proportion of the fleet that is high emitters and is identifiable at RSI (line (e) in the table below)
is derived as the product of the share of high emitters in the fleet in the baseline (line (a) in the table
below), the remote sensing capacity of identifying faulty vehicles (line (d) in the table below), and
the RSI noise test effectiveness (line (c) in the table below). The effectiveness assumed for the
measurements at roadside is lower than the one assumed at PTI, to reflect the challenge of measuring
in a noisy environment. The acoustic camera effectiveness is considered higher than noise
measurements at roadside because it is the result of more than one measurement.
As only a portion (line (f) in the table below) of the fleet will be analysed by the acoustic cameras,
the proportion of the fleet that is high emitters and is identifiable at RSI (line (g)) is derived as: (g) =
(f) x (e), where the letters stand for the labels of the rows in the table below. However, the maximum
percentage of noise high emitters eventually identified (line (h)) is limited by the RSI capacity (line
(b)).
The table below summarises the steps and assumptions used to estimate the percentage reduction in
the share of M1, N1, and L noise high emitting vehicles.
233
Table 232: Estimated impact of PM12 on the share of noise high emitters for N1, M1 vehicles, and motorcycles
relative to the baseline
Label Calculation/ Assumption
Vehicle category N1 L3-L7 M1
MSs affected All MSs All MSs
All
MSs
Share of vehicle fleet in measure scope
100% 100% 100%
Share of high emitters in the fleet in the
baseline
4% 30% 4% (a) See the baseline section
Share of fleet selected via remote
sensing and sent to RSI (i.e., maximum
RSI capacity)
0.5% 5.0% 0.5% (b) Assumption
Noise test effectiveness
80% 80% 80% (c) Assumption
Remote sensing capacity to identify
faulty vehicles (% of total)
70% 70% 70% (d) Assumption
Proportion of the fleet that is high
emitters and is identified at RSI if 100%
inspected of the fleet is analysed via RS
and inspected at RSI
2.2% 16.8% 2.2% (e) (e) = (d) x (c) x (a)
Proportion of the fleet analysed by RS
30% 30% 30% (f) Assumption
Proportion of the fleet that is high
emitters and is identifiable at RSI
0.7% 5.0% 0.7% (g) (g =(f) x (e)
High emitters identified at RSI with
limited RSI capacity (RS+RSI)
0.5% 5.0% 0.5% (h)
If (g) <= (b) then (h) = (g);
Otherwise (h) = (b)
% reduction in the share of high
emitters (remote sensing + RSI)
12.5% 16.7% 12.5% (i) (i) = (h) / (a)
Source: Ricardo et al. (2024), Impact assessment support study
4.2.13. PM14 - Extend the scope of application of roadside inspections to light commercial (N1)
vehicles
PM14 extends the scope of application of roadside inspections to N1 vehicles, and sets 2% as target
for the share of inspections of the N1 vehicle fleet. The introduction of roadside inspections of N1
category vehicles can contribute further to the identification of vehicles with defective or tampered
emissions/noise control systems. To the extent that these roadside inspections are expected to be
targeted (as is currently the case in most Member States), this can be a particularly effective measure
in removing defective vehicles. PM14 is expected to have an impact on both air pollutant and noise
emissions.
On the basis of the information available, few Member States (ES, HU, SE, SK and FI) already
conduct roadside inspections for N1 vehicles, although without a certain target set and thus checking
a low number of vehicles. For the purposes of the assessment it is assumed that these Member States
will not be affected. The N1 vehicles fleet of the 22 Member States affected represent around 77%
of the N1 vehicles fleet in the EU.
234
Depending on the age, Euro standard and fuel type, the share of air pollutant high emitter N1 vehicles
ranges between 4% and 20% in the baseline. The share of noise high emitter N1 vehicles is estimated
at 4% in the baseline. Of these, half are assumed to be tampered and half defective.
The RSI inspections would cover 2% of the N1 vehicle fleet annually in PM14. Due to the enhanced
effectiveness as a result of the targeted nature of RSIs, the number of high emitters identified will,
on average, be three times higher than if the inspections were completely random. Similar to the
approach for assessing the impact on road safety, it is assumed that the effectiveness of roadside
inspections in detecting high emitters is 95%.
PM14 is estimated to reduce by 5.7% the share of high emitter vehicles in the Member States affected
relative to the baseline (4.4% at EU level).
Table 233: Estimated impact of PM14 on the share of high emitters of air pollutant emissions and noise
Emissions Noise Label Calculation
Share of EU fleet affected 77% (a)
Share of high emitters in the fleet in
the baseline
4%-20% depending
on age, Euro standard
and fuel type
4% (b)
Share of fleet with defective
emissions control system
2%-20% 2% (c) (c) = 50% x (b)
Share of fleet with tampered
emission control system
2%-20% 2% (d) (c) = 50% x (b)
RSI fleet target 2% (e)
Parameter reflecting RSI enhanced
capacity to identify defective
vehicles
3 (f)
Failure rate of inspections in
detecting defective vehicles
5% (g)
% reduction in the share of high
emitter vehicles (emissions/noise)
in the MS affected, relative to the
baseline
5.7% (h)
(h) = (e) x (f) x ((c) +
(d)) x (1-(g)) / (b)
% reduction in the share of high
emitter vehicles at EU level
relative to the baseline
4.4% (i) (i) = (h) x (a)
Source: Ricardo et al. (2024), Impact assessment support study
4.2.14. PM15 – Extend the scope of application of roadside inspections to 2- and 3-wheeled vehicles
(L-vehicles from L3)
PM15 extends the scope of application of roadside inspections to 2- and 3-wheeled vehicles (L-
vehicles from L3) and establishes a threshold of 1% of the vehicle fleet for roadside inspections. Few
Member States (SE, SI, AT, FI, DK, HU, RO) already perform such inspections although they do not
report the exact number of inspections of motorcycles separately and do not indicate a specific target.
In the absence of more specific data it is assumed that these Member States will not be affected by
235
PM15. The L-category vehicle fleet of the 20 Member States affected is estimated to represent on
average 92% of the L-category vehicle EU fleet over 2026-2050436
. PM15 is expected to have an
impact on air pollutant emissions and noise emissions.
The share of high emitters of air pollution and noise emissions in the baseline is assumed at 8% and
30%, respectively, based on limited information from the literature and the PTI data analysis (see
baseline section).
Similar to the approach used for assessing the impacts on road safety, the failure rate of inspections
in detecting defective vehicles is assumed at 5%. To reflect the enhanced effectiveness of RSI in
targeting defective vehicles compared to PTI, a factor of 3 is used.
PM15 is estimated to reduce by 2.9% the share of high emitter vehicles in the Member States affected
relative to the baseline (2.6% at EU level).
Table 234: Estimated impact of PM15 on the share of high emitters of air pollutant emissions and noise
Emissions Noise Label Calculation
Share of EU fleet affected 92% (a)
Share of high emitters in the fleet in
the baseline
8% 30% (b)
Share of fleet with defective
emissions control system
4% 15% (c) (c) = 50% x (b)
Share of fleet with tampered
emission control system
4% 15% (d) (c) = 50% x (b)
Share of fleet checked in RSI 1% (e)
Parameter reflecting RSI enhanced
capacity to identify defective
vehicles
3 (f)
Failure rate of inspections in
detecting defective vehicles
5% (g)
% reduction in the share of high
emitter vehicles (emissions/noise)
in the MS affected, relative to the
baseline
2.9% (h)
(h) = (e) x (f) x ((c) +
(d)) x (1-(g)) / (b)
% reduction in the share of high
emitter vehicles at EU level
relative to the baseline
2.6% (i) (i) = (h) x (a)
Source: Ricardo et al. (2024), Impact assessment support study
436
The share is calculated based on the PRIMES-TREMOVE baseline projections.
236
4.2.15. Impacts on air pollutant emissions and noise emissions by policy option
Air pollutant emissions
On the basis of the analysis of the impacts of each individual measure, the combined impact of the
measures for each policy option is estimated using the common residual method explained above.
The tables below summarise the expected reduction in the share of high emitter vehicles relative to
the baseline, by vehicle category, Euro standard and fuel type at EU level. They are provided
separately for NOx and PN high emitter vehicles. These are used as inputs in the PRIMES-
TREMOVE model to derive the reduction in the air pollution emissions and external costs of air
pollution emissions relative to the baseline.
Table 235: Reduction in the share of NOx high emitter vehicles by policy option relative to the baseline
Vehicle category Euro
standard
Fuel Age group PO1a PO1b PO2 PO3
M1 Euro 5 Diesel 0-4 12.0% 29.2% 29.2% 29.2%
M1 Euro 5 Diesel 5-9 32.1% 42.3% 42.3% 42.3%
M1 Euro 5 Diesel 10-14 42.6% 54.3% 54.3% 54.3%
M1 Euro 5 Diesel 15-19 43.0% 54.2% 54.2% 54.2%
M1 Euro 5 Petrol 0-4 12.0% 26.9% 26.9% 26.9%
M1 Euro 5 Petrol 5-9 32.1% 41.6% 41.6% 41.6%
M1 Euro 5 Petrol 10-14 42.6% 54.0% 54.0% 54.0%
M1 Euro 5 Petrol 15-19 43.0% 54.0% 54.0% 54.0%
M1 Euro 6 Diesel 0-4 12.0% 29.2% 29.2% 29.2%
M1 Euro 6 Diesel 5-9 32.1% 42.3% 42.3% 42.3%
M1 Euro 6 Diesel 10-14 42.6% 54.3% 54.3% 54.3%
M1 Euro 6 Diesel 15-19 43.0% 54.2% 54.2% 54.2%
M1 Euro 6 Petrol 0-4 12.0% 27.2% 27.2% 27.2%
M1 Euro 6 Petrol 5-9 32.1% 41.6% 41.6% 41.6%
M1 Euro 6 Petrol 10-14 42.6% 54.0% 54.0% 54.0%
M1 Euro 6 Petrol 15-19 43.0% 54.0% 54.0% 54.0%
M1 Euro 7 Diesel 0-4 12.0% 29.6% 29.6% 29.6%
M1 Euro 7 Diesel 5-9 32.1% 44.3% 44.3% 44.3%
M1 Euro 7 Diesel 10-14 42.6% 55.4% 55.4% 55.4%
M1 Euro 7 Diesel 15-19 43.0% 55.4% 55.4% 55.4%
M1 Euro 7 Petrol 0-4 12.0% 29.6% 29.6% 29.6%
M1 Euro 7 Petrol 5-9 32.1% 43.9% 43.9% 43.9%
M1 Euro 7 Petrol 10-14 42.6% 55.2% 55.2% 55.2%
M1 Euro 7 Petrol 15-19 43.0% 54.9% 54.9% 54.9%
N1 Euro 5 Diesel 0-4 12.0% 37.4% 40.3% 40.3%
N1 Euro 5 Diesel 5-9 32.1% 50.5% 52.8% 52.8%
N1 Euro 5 Diesel 10-14 42.6% 53.9% 56.1% 56.1%
N1 Euro 5 Diesel 15-19 43.0% 54.0% 56.2% 56.2%
N1 Euro 5 Petrol 0-4 12.0% 36.7% 39.7% 39.7%
N1 Euro 5 Petrol 5-9 32.1% 50.2% 52.5% 52.5%
N1 Euro 5 Petrol 10-14 42.6% 53.7% 55.9% 55.9%
N1 Euro 5 Petrol 15-19 43.0% 53.8% 56.0% 56.0%
237
Vehicle category Euro
standard
Fuel Age group PO1a PO1b PO2 PO3
N1 Euro 6 Diesel 0-4 12.0% 37.4% 40.3% 40.3%
N1 Euro 6 Diesel 5-9 32.1% 50.5% 52.8% 52.8%
N1 Euro 6 Diesel 10-14 42.6% 53.9% 56.1% 56.1%
N1 Euro 6 Diesel 15-19 43.0% 54.0% 56.2% 56.2%
N1 Euro 6 Petrol 0-4 12.0% 36.7% 39.7% 39.7%
N1 Euro 6 Petrol 5-9 32.1% 50.2% 52.5% 52.5%
N1 Euro 6 Petrol 10-14 42.6% 53.7% 55.9% 55.9%
N1 Euro 6 Petrol 15-19 43.0% 53.8% 56.0% 56.0%
N1 Euro 7 Diesel 0-4 12.0% 40.1% 42.9% 42.9%
N1 Euro 7 Diesel 5-9 32.1% 51.9% 54.2% 54.2%
N1 Euro 7 Diesel 10-14 42.6% 54.9% 57.0% 57.0%
N1 Euro 7 Diesel 15-19 43.0% 54.8% 56.9% 56.9%
N1 Euro 7 Petrol 0-4 12.0% 38.8% 41.7% 41.7%
N1 Euro 7 Petrol 5-9 32.1% 51.3% 53.6% 53.6%
N1 Euro 7 Petrol 10-14 42.6% 54.4% 56.6% 56.6%
N1 Euro 7 Petrol 15-19 43.0% 54.4% 56.6% 56.6%
N2/N3/M2/M3 Euro VI Diesel 0-4 59.1% 65.2% 65.2% 65.2%
N2/N3/M2/M3 Euro VI Diesel 5-9 59.1% 65.0% 65.0% 65.0%
N2/N3/M2/M3 Euro VI Diesel 10-14 59.1% 64.8% 64.8% 64.8%
N2/N3/M2/M3 Euro VI Diesel 15-19 59.1% 64.7% 64.7% 64.7%
N2/N3/M2/M3 Euro 7 Diesel 0-4 59.1% 66.5% 66.5% 66.5%
N2/N3/M2/M3 Euro 7 Diesel 5-9 59.1% 66.0% 66.0% 66.0%
N2/N3/M2/M3 Euro 7 Diesel 10-14 59.1% 65.7% 65.7% 65.7%
N2/N3/M2/M3 Euro 7 Diesel 15-19 59.1% 65.5% 65.5% 65.5%
L3-L7 All ages 1.0% 1.7% 1.0% 5.1%
Source: Ricardo et al. (2024), Impact assessment support study
Table 236: Reduction in the share of PN high emitter vehicles by policy option relative to the baseline
Vehicle category Euro
standard
Fuel Age group PO1a PO1b PO2 PO3
M1 Euro 5 Diesel 0-4 7.5% 25.6% 25.6% 25.6%
M1 Euro 5 Diesel 5-9 20.6% 32.5% 32.5% 32.5%
M1 Euro 5 Diesel 10-14 37.8% 50.5% 50.5% 50.5%
M1 Euro 5 Diesel 15-19 38.1% 50.4% 50.4% 50.4%
M1 Euro 5 Petrol 0-4 7.5% 23.2% 23.2% 23.2%
M1 Euro 5 Petrol 5-9 20.6% 31.7% 31.7% 31.7%
M1 Euro 5 Petrol 10-14 37.8% 50.1% 50.1% 50.1%
M1 Euro 5 Petrol 15-19 38.1% 50.1% 50.1% 50.1%
M1 Euro 6 Diesel 0-4 7.5% 25.6% 25.6% 25.6%
M1 Euro 6 Diesel 5-9 20.6% 32.5% 32.5% 32.5%
M1 Euro 6 Diesel 10-14 37.8% 50.5% 50.5% 50.5%
M1 Euro 6 Diesel 15-19 38.1% 50.4% 50.4% 50.4%
M1 Euro 6 Petrol 0-4 7.5% 23.5% 23.5% 23.5%
M1 Euro 6 Petrol 5-9 20.6% 31.7% 31.7% 31.7%
238
Vehicle category Euro
standard
Fuel Age group PO1a PO1b PO2 PO3
M1 Euro 6 Petrol 10-14 37.8% 50.1% 50.1% 50.1%
M1 Euro 6 Petrol 15-19 38.1% 50.1% 50.1% 50.1%
M1 Euro 7 Diesel 0-4 7.5% 26.0% 26.0% 26.0%
M1 Euro 7 Diesel 5-9 20.6% 34.9% 34.9% 34.9%
M1 Euro 7 Diesel 10-14 37.8% 51.7% 51.7% 51.7%
M1 Euro 7 Diesel 15-19 38.1% 51.6% 51.6% 51.6%
M1 Euro 7 Petrol 0-4 7.5% 26.0% 26.0% 26.0%
M1 Euro 7 Petrol 5-9 20.6% 34.3% 34.3% 34.3%
M1 Euro 7 Petrol 10-14 37.8% 51.4% 51.4% 51.4%
M1 Euro 7 Petrol 15-19 38.1% 51.1% 51.1% 51.1%
N1 Euro 5 Diesel 0-4 8.1% 34.6% 37.7% 37.7%
N1 Euro 5 Diesel 5-9 22.7% 43.7% 46.3% 46.3%
N1 Euro 5 Diesel 10-14 33.4% 46.5% 49.1% 49.1%
N1 Euro 5 Diesel 15-19 33.7% 46.5% 49.1% 49.1%
N1 Euro 5 Petrol 0-4 8.1% 33.9% 37.0% 37.0%
N1 Euro 5 Petrol 5-9 22.7% 43.3% 46.0% 46.0%
N1 Euro 5 Petrol 10-14 33.4% 46.3% 48.8% 48.8%
N1 Euro 5 Petrol 15-19 33.7% 46.3% 48.9% 48.9%
N1 Euro 6 Diesel 0-4 8.1% 34.6% 37.7% 37.7%
N1 Euro 6 Diesel 5-9 22.7% 43.7% 46.3% 46.3%
N1 Euro 6 Diesel 10-14 33.4% 46.5% 49.1% 49.1%
N1 Euro 6 Diesel 15-19 33.7% 46.5% 49.1% 49.1%
N1 Euro 6 Petrol 0-4 8.1% 33.9% 37.0% 37.0%
N1 Euro 6 Petrol 5-9 22.7% 43.3% 46.0% 46.0%
N1 Euro 6 Petrol 10-14 33.4% 46.3% 48.8% 48.8%
N1 Euro 6 Petrol 15-19 33.7% 46.3% 48.9% 48.9%
N1 Euro 7 Diesel 0-4 8.1% 37.4% 40.4% 40.4%
N1 Euro 7 Diesel 5-9 22.7% 45.3% 47.9% 47.9%
N1 Euro 7 Diesel 10-14 33.4% 47.7% 50.2% 50.2%
N1 Euro 7 Diesel 15-19 33.7% 47.4% 49.9% 49.9%
N1 Euro 7 Petrol 0-4 8.1% 36.1% 39.1% 39.1%
N1 Euro 7 Petrol 5-9 22.7% 44.6% 47.2% 47.2%
N1 Euro 7 Petrol 10-14 33.4% 47.2% 49.7% 49.7%
N1 Euro 7 Petrol 15-19 33.7% 47.0% 49.5% 49.5%
N2/N3/M2/M3 Euro VI Diesel 0-4 48.7% 56.4% 56.4% 56.4%
N2/N3/M2/M3 Euro VI Diesel 5-9 50.6% 57.8% 57.8% 57.8%
N2/N3/M2/M3 Euro VI Diesel 10-14 54.4% 60.8% 60.8% 60.8%
N2/N3/M2/M3 Euro VI Diesel 15-19 54.5% 60.8% 60.8% 60.8%
N2/N3/M2/M3 Euro 7 Diesel 0-4 48.7% 58.0% 58.0% 58.0%
N2/N3/M2/M3 Euro 7 Diesel 5-9 50.6% 59.0% 59.0% 59.0%
N2/N3/M2/M3 Euro 7 Diesel 10-14 54.4% 61.8% 61.8% 61.8%
N2/N3/M2/M3 Euro 7 Diesel 15-19 54.5% 61.7% 61.7% 61.7%
239
Vehicle category Euro
standard
Fuel Age group PO1a PO1b PO2 PO3
L3-L7 All ages 1.0% 1.7% 1.0% 5.1%
Source: Ricardo et al. (2024), Impact assessment support study
Table 237: Share of NOx high emitter vehicles in the baseline and policy options
Vehicle category Euro
standard
Fuel Age group Baseline
level
PO1a PO1b PO2 PO3
M1 Euro 5 Diesel 0-4 2.5% 2.2% 1.8% 1.8% 1.8%
M1 Euro 5 Diesel 5-9 5.0% 3.4% 2.9% 2.9% 2.9%
M1 Euro 5 Diesel 10-14 7.5% 4.3% 3.4% 3.4% 3.4%
M1 Euro 5 Diesel 15-19 10.0% 5.7% 4.6% 4.6% 4.6%
M1 Euro 5 Petrol 0-4 3.5% 3.1% 2.6% 2.6% 2.6%
M1 Euro 5 Petrol 5-9 6.5% 4.4% 3.8% 3.8% 3.8%
M1 Euro 5 Petrol 10-14 9.8% 5.6% 4.5% 4.5% 4.5%
M1 Euro 5 Petrol 15-19 13.0% 7.4% 6.0% 6.0% 6.0%
M1 Euro 6 Diesel 0-4 2.5% 2.2% 1.8% 1.8% 1.8%
M1 Euro 6 Diesel 5-9 5.0% 3.4% 2.9% 2.9% 2.9%
M1 Euro 6 Diesel 10-14 7.5% 4.3% 3.4% 3.4% 3.4%
M1 Euro 6 Diesel 15-19 10.0% 5.7% 4.6% 4.6% 4.6%
M1 Euro 6 Petrol 0-4 3.3% 2.9% 2.4% 2.4% 2.4%
M1 Euro 6 Petrol 5-9 6.5% 4.4% 3.8% 3.8% 3.8%
M1 Euro 6 Petrol 10-14 9.8% 5.6% 4.5% 4.5% 4.5%
M1 Euro 6 Petrol 15-19 13.0% 7.4% 6.0% 6.0% 6.0%
M1 Euro 7 Diesel 0-4 1.3% 1.1% 0.9% 0.9% 0.9%
M1 Euro 7 Diesel 5-9 3.0% 2.0% 1.7% 1.7% 1.7%
M1 Euro 7 Diesel 10-14 4.5% 2.6% 2.0% 2.0% 2.0%
M1 Euro 7 Diesel 15-19 5.0% 2.9% 2.2% 2.2% 2.2%
M1 Euro 7 Petrol 0-4 1.6% 1.4% 1.1% 1.1% 1.1%
M1 Euro 7 Petrol 5-9 3.3% 2.2% 1.8% 1.8% 1.8%
M1 Euro 7 Petrol 10-14 4.9% 2.8% 2.2% 2.2% 2.2%
M1 Euro 7 Petrol 15-19 6.5% 3.7% 2.9% 2.9% 2.9%
N1 Euro 5 Diesel 0-4 6.0% 5.3% 3.8% 3.6% 3.6%
N1 Euro 5 Diesel 5-9 9.0% 6.1% 4.5% 4.2% 4.2%
N1 Euro 5 Diesel 10-14 12.0% 6.9% 5.5% 5.3% 5.3%
N1 Euro 5 Diesel 15-19 15.0% 8.6% 6.9% 6.6% 6.6%
N1 Euro 5 Petrol 0-4 7.8% 6.9% 4.9% 4.7% 4.7%
N1 Euro 5 Petrol 5-9 11.7% 7.9% 5.8% 5.6% 5.6%
N1 Euro 5 Petrol 10-14 15.6% 9.0% 7.2% 6.9% 6.9%
N1 Euro 5 Petrol 15-19 19.5% 11.1% 9.0% 8.6% 8.6%
N1 Euro 6 Diesel 0-4 6.0% 5.3% 3.8% 3.6% 3.6%
N1 Euro 6 Diesel 5-9 9.0% 6.1% 4.5% 4.2% 4.2%
N1 Euro 6 Diesel 10-14 12.0% 6.9% 5.5% 5.3% 5.3%
N1 Euro 6 Diesel 15-19 15.0% 8.6% 6.9% 6.6% 6.6%
N1 Euro 6 Petrol 0-4 7.8% 6.9% 4.9% 4.7% 4.7%
N1 Euro 6 Petrol 5-9 11.7% 7.9% 5.8% 5.6% 5.6%
240
Vehicle category Euro
standard
Fuel Age group Baseline
level
PO1a PO1b PO2 PO3
N1 Euro 6 Petrol 10-14 15.6% 9.0% 7.2% 6.9% 6.9%
N1 Euro 6 Petrol 15-19 19.5% 11.1% 9.0% 8.6% 8.6%
N1 Euro 7 Diesel 0-4 3.0% 2.6% 1.8% 1.7% 1.7%
N1 Euro 7 Diesel 5-9 4.5% 3.1% 2.2% 2.1% 2.1%
N1 Euro 7 Diesel 10-14 6.0% 3.4% 2.7% 2.6% 2.6%
N1 Euro 7 Diesel 15-19 7.5% 4.3% 3.4% 3.2% 3.2%
N1 Euro 7 Petrol 0-4 3.6% 3.2% 2.2% 2.1% 2.1%
N1 Euro 7 Petrol 5-9 4.4% 3.0% 2.1% 2.0% 2.0%
N1 Euro 7 Petrol 10-14 5.2% 3.0% 2.4% 2.3% 2.3%
N1 Euro 7 Petrol 15-19 6.0% 3.4% 2.7% 2.6% 2.6%
N2/N3/M2/M3 Euro VI Diesel 0-4 7.2% 2.9% 2.5% 2.5% 2.5%
N2/N3/M2/M3 Euro VI Diesel 5-9 8.8% 3.6% 3.1% 3.1% 3.1%
N2/N3/M2/M3 Euro VI Diesel 10-14 10.4% 4.3% 3.7% 3.7% 3.7%
N2/N3/M2/M3 Euro VI Diesel 15-19 12.0% 4.9% 4.2% 4.2% 4.2%
N2/N3/M2/M3 Euro 7 Diesel 0-4 3.6% 1.5% 1.2% 1.2% 1.2%
N2/N3/M2/M3 Euro 7 Diesel 5-9 4.4% 1.8% 1.5% 1.5% 1.5%
N2/N3/M2/M3 Euro 7 Diesel 10-14 5.2% 2.1% 1.8% 1.8% 1.8%
N2/N3/M2/M3 Euro 7 Diesel 15-19 6.0% 2.5% 2.1% 2.1% 2.1%
L3-L7 0-4 3.5% 3.5% 3.5% 3.5% 3.3%
L3-L7 5-9 6.5% 6.4% 6.4% 6.4% 6.2%
L3-L7 10-14 9.8% 9.6% 9.6% 9.6% 9.2%
L3-L7 15-19 13.0% 12.9% 12.8% 12.9% 12.3%
Source: Ricardo et al. (2024), Impact assessment support study
Table 238: Share of PN high emitter vehicles in the baseline and policy options
Vehicle category Euro
standard
Fuel Age group Baseline
level
PO1a PO1b PO2 PO3
M1 Euro 5 Diesel 0-4 2.5% 2.3% 1.9% 1.9% 1.9%
M1 Euro 5 Diesel 5-9 5.0% 4.0% 3.4% 3.4% 3.4%
M1 Euro 5 Diesel 10-14 7.5% 4.7% 3.7% 3.7% 3.7%
M1 Euro 5 Diesel 15-19 10.0% 6.2% 5.0% 5.0% 5.0%
M1 Euro 5 Petrol 0-4 2.6% 2.4% 2.0% 2.0% 2.0%
M1 Euro 5 Petrol 5-9 5.2% 4.1% 3.6% 3.6% 3.6%
M1 Euro 5 Petrol 10-14 7.8% 4.9% 3.9% 3.9% 3.9%
M1 Euro 5 Petrol 15-19 10.4% 6.4% 5.2% 5.2% 5.2%
M1 Euro 6 Diesel 0-4 2.5% 2.3% 1.9% 1.9% 1.9%
M1 Euro 6 Diesel 5-9 5.0% 4.0% 3.4% 3.4% 3.4%
M1 Euro 6 Diesel 10-14 7.5% 4.7% 3.7% 3.7% 3.7%
M1 Euro 6 Diesel 15-19 10.0% 6.2% 5.0% 5.0% 5.0%
M1 Euro 6 Petrol 0-4 2.6% 2.4% 2.0% 2.0% 2.0%
M1 Euro 6 Petrol 5-9 5.2% 4.1% 3.6% 3.6% 3.6%
M1 Euro 6 Petrol 10-14 7.8% 4.9% 3.9% 3.9% 3.9%
M1 Euro 6 Petrol 15-19 10.4% 6.4% 5.2% 5.2% 5.2%
M1 Euro 7 Diesel 0-4 1.3% 1.2% 1.0% 1.0% 1.0%
241
Vehicle category Euro
standard
Fuel Age group Baseline
level
PO1a PO1b PO2 PO3
M1 Euro 7 Diesel 5-9 3.0% 2.4% 2.0% 2.0% 2.0%
M1 Euro 7 Diesel 10-14 4.5% 2.8% 2.2% 2.2% 2.2%
M1 Euro 7 Diesel 15-19 5.0% 3.1% 2.4% 2.4% 2.4%
M1 Euro 7 Petrol 0-4 1.3% 1.2% 1.0% 1.0% 1.0%
M1 Euro 7 Petrol 5-9 2.6% 2.1% 1.7% 1.7% 1.7%
M1 Euro 7 Petrol 10-14 3.9% 2.4% 1.9% 1.9% 1.9%
M1 Euro 7 Petrol 15-19 5.2% 3.2% 2.5% 2.5% 2.5%
N1 Euro 5 Diesel 0-4 6.0% 5.5% 3.9% 3.7% 3.7%
N1 Euro 5 Diesel 5-9 9.0% 7.0% 5.1% 4.8% 4.8%
N1 Euro 5 Diesel 10-14 12.0% 8.0% 6.4% 6.1% 6.1%
N1 Euro 5 Diesel 15-19 15.0% 9.9% 8.0% 7.6% 7.6%
N1 Euro 5 Petrol 0-4 6.2% 5.7% 4.1% 3.9% 3.9%
N1 Euro 5 Petrol 5-9 9.4% 7.2% 5.3% 5.1% 5.1%
N1 Euro 5 Petrol 10-14 12.5% 8.3% 6.7% 6.4% 6.4%
N1 Euro 5 Petrol 15-19 15.6% 10.3% 8.4% 8.0% 8.0%
N1 Euro 6 Diesel 0-4 6.0% 5.5% 3.9% 3.7% 3.7%
N1 Euro 6 Diesel 5-9 9.0% 7.0% 5.1% 4.8% 4.8%
N1 Euro 6 Diesel 10-14 12.0% 8.0% 6.4% 6.1% 6.1%
N1 Euro 6 Diesel 15-19 15.0% 9.9% 8.0% 7.6% 7.6%
N1 Euro 6 Petrol 0-4 6.2% 5.7% 4.1% 3.9% 3.9%
N1 Euro 6 Petrol 5-9 9.4% 7.2% 5.3% 5.1% 5.1%
N1 Euro 6 Petrol 10-14 12.5% 8.3% 6.7% 6.4% 6.4%
N1 Euro 6 Petrol 15-19 15.6% 10.3% 8.4% 8.0% 8.0%
N1 Euro 7 Diesel 0-4 3.0% 2.8% 1.9% 1.8% 1.8%
N1 Euro 7 Diesel 5-9 4.5% 3.5% 2.5% 2.3% 2.3%
N1 Euro 7 Diesel 10-14 6.0% 4.0% 3.1% 3.0% 3.0%
N1 Euro 7 Diesel 15-19 7.5% 5.0% 3.9% 3.8% 3.8%
N1 Euro 7 Petrol 0-4 3.1% 2.9% 2.0% 1.9% 1.9%
N1 Euro 7 Petrol 5-9 4.7% 3.6% 2.6% 2.5% 2.5%
N1 Euro 7 Petrol 10-14 6.2% 4.2% 3.3% 3.1% 3.1%
N1 Euro 7 Petrol 15-19 7.8% 5.2% 4.1% 3.9% 3.9%
N2/N3/M2/M3 Euro VI Diesel 0-4 7.2% 3.7% 3.1% 3.1% 3.1%
N2/N3/M2/M3 Euro VI Diesel 5-9 8.8% 4.3% 3.7% 3.7% 3.7%
N2/N3/M2/M3 Euro VI Diesel 10-14 10.4% 4.7% 4.1% 4.1% 4.1%
N2/N3/M2/M3 Euro VI Diesel 15-19 12.0% 5.5% 4.7% 4.7% 4.7%
N2/N3/M2/M3 Euro 7 Diesel 0-4 3.6% 1.8% 1.5% 1.5% 1.5%
N2/N3/M2/M3 Euro 7 Diesel 5-9 4.4% 2.2% 1.8% 1.8% 1.8%
N2/N3/M2/M3 Euro 7 Diesel 10-14 5.2% 2.4% 2.0% 2.0% 2.0%
N2/N3/M2/M3 Euro 7 Diesel 15-19 6.0% 2.7% 2.3% 2.3% 2.3%
L3-L7 0-4 2.6% 2.6% 2.6% 2.6% 2.5%
L3-L7 5-9 5.2% 5.1% 5.1% 5.1% 4.9%
L3-L7 10-14 7.8% 7.7% 7.7% 7.7% 7.4%
L3-L7 15-19 10.4% 10.3% 10.2% 10.3% 9.9%
Source: Ricardo et al. (2024), Impact assessment support study
242
Noise emissions
On the basis of the analysis of the impacts of each individual measure, the combined impact of the
measures for each policy option is estimated using the common residual method explained above.
The tables below summarise the expected reduction in the share of noise high emitter vehicles relative
to the baseline, by vehicle type and Member State. These are used as inputs in the PRIMES-
TREMOVE model to derive the reduction in the external costs of noise emissions relative to the
baseline.
Table 239: Reduction in the share of noise high emitter M1 vehicles by policy option relative to the baseline
PO1a PO1b PO2 PO3
AT 0.0% 12.5% 12.5% 12.5%
BE 0.0% 12.5% 12.5% 12.5%
BG 0.0% 12.5% 12.5% 12.5%
CY 0.0% 12.5% 12.5% 12.5%
DE 0.0% 12.5% 12.5% 12.5%
EE 0.0% 12.5% 12.5% 12.5%
FI 0.0% 12.5% 12.5% 12.5%
FR 0.0% 12.5% 12.5% 12.5%
EL 0.0% 12.5% 12.5% 12.5%
HR 0.0% 12.5% 12.5% 12.5%
HU 0.0% 12.5% 12.5% 12.5%
IE 0.0% 12.5% 12.5% 12.5%
IT 0.0% 12.5% 12.5% 12.5%
LT 0.0% 12.5% 12.5% 12.5%
LU 0.0% 12.5% 12.5% 12.5%
LV 0.0% 12.5% 12.5% 12.5%
MT 0.0% 12.5% 12.5% 12.5%
NL 0.0% 12.5% 12.5% 12.5%
PL 0.0% 12.5% 12.5% 12.5%
PT 0.0% 12.5% 12.5% 12.5%
RO 0.0% 12.5% 12.5% 12.5%
SE 0.0% 12.5% 12.5% 12.5%
SI 0.0% 12.5% 12.5% 12.5%
SK 0.0% 12.5% 12.5% 12.5%
ES 0.0% 12.5% 12.5% 12.5%
DK 0.0% 12.5% 12.5% 12.5%
CZ 0.0% 12.5% 12.5% 12.5%
Source: Ricardo et al. (2024), Impact assessment support study
Table 240: Share of noise high emitter M1 vehicles in the baseline and policy options
Baseline PO1a PO1b PO2 PO3
AT 4.0% 4.0% 3.5% 3.5% 3.5%
BE 4.0% 4.0% 3.5% 3.5% 3.5%
BG 4.0% 4.0% 3.5% 3.5% 3.5%
CY 4.0% 4.0% 3.5% 3.5% 3.5%
DE 4.0% 4.0% 3.5% 3.5% 3.5%
243
Baseline PO1a PO1b PO2 PO3
EE 4.0% 4.0% 3.5% 3.5% 3.5%
FI 4.0% 4.0% 3.5% 3.5% 3.5%
FR 4.0% 4.0% 3.5% 3.5% 3.5%
EL 4.0% 4.0% 3.5% 3.5% 3.5%
HR 4.0% 4.0% 3.5% 3.5% 3.5%
HU 4.0% 4.0% 3.5% 3.5% 3.5%
IE 4.0% 4.0% 3.5% 3.5% 3.5%
IT 4.0% 4.0% 3.5% 3.5% 3.5%
LT 4.0% 4.0% 3.5% 3.5% 3.5%
LU 4.0% 4.0% 3.5% 3.5% 3.5%
LV 4.0% 4.0% 3.5% 3.5% 3.5%
MT 4.0% 4.0% 3.5% 3.5% 3.5%
NL 4.0% 4.0% 3.5% 3.5% 3.5%
PL 4.0% 4.0% 3.5% 3.5% 3.5%
PT 4.0% 4.0% 3.5% 3.5% 3.5%
RO 4.0% 4.0% 3.5% 3.5% 3.5%
SE 4.0% 4.0% 3.5% 3.5% 3.5%
SI 4.0% 4.0% 3.5% 3.5% 3.5%
SK 4.0% 4.0% 3.5% 3.5% 3.5%
ES 4.0% 4.0% 3.5% 3.5% 3.5%
DK 4.0% 4.0% 3.5% 3.5% 3.5%
CZ 4.0% 4.0% 3.5% 3.5% 3.5%
Source: Ricardo et al. (2024), Impact assessment support study
Table 241: Reduction in the share of noise high emitter N1 vehicles by policy option relative to the baseline
PO1a PO1b PO2 PO3
AT 0.0% 12.5% 17.5% 17.5%
BE 0.0% 12.5% 17.5% 17.5%
BG 0.0% 12.5% 17.5% 17.5%
CY 0.0% 12.5% 17.5% 17.5%
DE 0.0% 12.5% 17.5% 17.5%
EE 0.0% 12.5% 17.5% 17.5%
FI 0.0% 12.5% 12.5% 12.5%
FR 0.0% 12.5% 17.5% 17.5%
EL 0.0% 12.5% 17.5% 17.5%
HR 0.0% 12.5% 17.5% 17.5%
HU 0.0% 12.5% 12.5% 12.5%
IE 0.0% 12.5% 17.5% 17.5%
IT 0.0% 12.5% 17.5% 17.5%
LT 0.0% 12.5% 17.5% 17.5%
LU 0.0% 12.5% 17.5% 17.5%
LV 0.0% 12.5% 17.5% 17.5%
MT 0.0% 12.5% 17.5% 17.5%
NL 0.0% 12.5% 17.5% 17.5%
PL 0.0% 12.5% 17.5% 17.5%
244
PO1a PO1b PO2 PO3
PT 0.0% 12.5% 17.5% 17.5%
RO 0.0% 12.5% 17.5% 17.5%
SE 0.0% 12.5% 12.5% 12.5%
SI 0.0% 12.5% 17.5% 17.5%
SK 0.0% 12.5% 12.5% 12.5%
ES 0.0% 12.5% 12.5% 12.5%
DK 0.0% 12.5% 17.5% 17.5%
CZ 0.0% 12.5% 17.5% 17.5%
Source: Ricardo et al. (2024), Impact assessment support study
Table 242: Share of noise high emitter N1 vehicles in the baseline and policy options
Baseline PO1a PO1b PO2 PO3
AT 4.0% 4.0% 3.5% 3.3% 3.3%
BE 4.0% 4.0% 3.5% 3.3% 3.3%
BG 4.0% 4.0% 3.5% 3.3% 3.3%
CY 4.0% 4.0% 3.5% 3.3% 3.3%
DE 4.0% 4.0% 3.5% 3.3% 3.3%
EE 4.0% 4.0% 3.5% 3.3% 3.3%
FI 4.0% 4.0% 3.5% 3.5% 3.5%
FR 4.0% 4.0% 3.5% 3.3% 3.3%
EL 4.0% 4.0% 3.5% 3.3% 3.3%
HR 4.0% 4.0% 3.5% 3.3% 3.3%
HU 4.0% 4.0% 3.5% 3.5% 3.5%
IE 4.0% 4.0% 3.5% 3.3% 3.3%
IT 4.0% 4.0% 3.5% 3.3% 3.3%
LT 4.0% 4.0% 3.5% 3.3% 3.3%
LU 4.0% 4.0% 3.5% 3.3% 3.3%
LV 4.0% 4.0% 3.5% 3.3% 3.3%
MT 4.0% 4.0% 3.5% 3.3% 3.3%
NL 4.0% 4.0% 3.5% 3.3% 3.3%
PL 4.0% 4.0% 3.5% 3.3% 3.3%
PT 4.0% 4.0% 3.5% 3.3% 3.3%
RO 4.0% 4.0% 3.5% 3.3% 3.3%
SE 4.0% 4.0% 3.5% 3.5% 3.5%
SI 4.0% 4.0% 3.5% 3.3% 3.3%
SK 4.0% 4.0% 3.5% 3.5% 3.5%
ES 4.0% 4.0% 3.5% 3.5% 3.5%
DK 4.0% 4.0% 3.5% 3.3% 3.3%
CZ 4.0% 4.0% 3.5% 3.3% 3.3%
Source: Ricardo et al. (2024), Impact assessment support study
Table 243: Reduction in the share of noise high emitter L3-L7 vehicles by policy option relative to the baseline
PO1a PO1b PO2 PO3
AT 0.0% 35.0% 35.0% 35.0%
BE 12.0% 48.0% 42.8% 51.5%
245
PO1a PO1b PO2 PO3
BG 0.0% 35.0% 35.0% 36.9%
CY 0.0% 35.0% 35.0% 36.9%
DE 0.0% 16.7% 16.7% 19.0%
EE 0.0% 35.0% 35.0% 36.9%
FI 12.0% 48.0% 42.8% 50.1%
FR 0.0% 35.0% 35.0% 36.9%
EL 0.0% 35.0% 35.0% 36.9%
HR 0.0% 16.7% 16.7% 19.0%
HU 0.0% 35.0% 35.0% 35.0%
IE 12.0% 48.0% 42.8% 51.5%
IT 0.0% 35.0% 35.0% 36.9%
LT 0.0% 35.0% 35.0% 36.9%
LU 0.0% 35.0% 35.0% 36.9%
LV 0.0% 35.0% 35.0% 36.9%
MT 12.0% 48.0% 42.8% 51.5%
NL 12.0% 48.0% 42.8% 51.5%
PL 0.0% 35.0% 35.0% 36.9%
PT 12.0% 48.0% 42.8% 51.5%
RO 0.0% 35.0% 35.0% 35.0%
SE 0.0% 35.0% 35.0% 35.0%
SI 0.0% 35.0% 35.0% 35.0%
SK 0.0% 16.7% 16.7% 19.0%
ES 0.0% 16.7% 16.7% 19.0%
DK 0.0% 48.0% 35.0% 50.1%
CZ 0.0% 35.0% 35.0% 36.9%
Source: Ricardo et al. (2024), Impact assessment support study
Table 244: Share of noise high emitter L3-L7 vehicles in the baseline and policy options
Baseline PO1a PO1b PO2 PO3
AT 30.0% 30.0% 19.5% 19.5% 19.5%
BE 30.0% 26.4% 15.6% 17.2% 14.5%
BG 30.0% 30.0% 19.5% 19.5% 18.9%
CY 30.0% 30.0% 19.5% 19.5% 18.9%
DE 30.0% 30.0% 25.0% 25.0% 24.3%
EE 30.0% 30.0% 19.5% 19.5% 18.9%
FI 30.0% 26.4% 15.6% 17.2% 15.0%
FR 30.0% 30.0% 19.5% 19.5% 18.9%
EL 30.0% 30.0% 19.5% 19.5% 18.9%
HR 30.0% 30.0% 25.0% 25.0% 24.3%
HU 30.0% 30.0% 19.5% 19.5% 19.5%
IE 30.0% 26.4% 15.6% 17.2% 14.5%
IT 30.0% 30.0% 19.5% 19.5% 18.9%
LT 30.0% 30.0% 19.5% 19.5% 18.9%
LU 30.0% 30.0% 19.5% 19.5% 18.9%
LV 30.0% 30.0% 19.5% 19.5% 18.9%
246
Baseline PO1a PO1b PO2 PO3
MT 30.0% 26.4% 15.6% 17.2% 14.5%
NL 30.0% 26.4% 15.6% 17.2% 14.5%
PL 30.0% 30.0% 19.5% 19.5% 18.9%
PT 30.0% 26.4% 15.6% 17.2% 14.5%
RO 30.0% 30.0% 19.5% 19.5% 19.5%
SE 30.0% 30.0% 19.5% 19.5% 19.5%
SI 30.0% 30.0% 19.5% 19.5% 19.5%
SK 30.0% 30.0% 25.0% 25.0% 24.3%
ES 30.0% 30.0% 25.0% 25.0% 24.3%
DK 30.0% 30.0% 15.6% 19.5% 15.0%
CZ 30.0% 30.0% 19.5% 19.5% 18.9%
Source: Ricardo et al. (2024), Impact assessment support study
5. IMPACTS BY POLICY OPTION ON SAFETY, EMISSIONS AND NOISE
5.1. Impacts on road safety
As explained in section 6.2.1 and in Annex 4 (section 4.1), given that the general objective of the
initiative is to improve road safety in the EU, several measures to achieve this objective were included
in the policy options. Direct impact on road safety is expected due to the more effective identification
of vehicles with major and dangerous defects in the fleet, which should lead to the reduction of road
crashes caused by technical defects and, as a result, to reduced fatalities and injuries (serious and
light). Policy options also include other measures contributing to road safety, which relate to better
implementation and enforcement of the roadworthiness legislation (such as the exchange of data
among Member States’ authorities).
Several assumptions were used to establish the impacts on road safety. They are explained in detail,
by policy measure, in section 4.1 of Annex 4. These inputs437
were subsequently used in the PRIMES-
TREMOVE model to derive the impacts on the number of lives saved and injuries avoided. It should
be noted that an important element in this assessment relates to the contribution of vehicle technical
defects to road crashes. As explained in section 2.1.1, various studies indicate that their share as a
contributing factor of the cause of crashes is between 3 and 19%, depending on the scope and
methodology of the study; for motorcycles, it is 5% to 12% of crashes. For this assessment, a
conservative approach was taken assuming a 4% contribution of technical defects on road crashes in
the case of light-duty vehicles, heavy-duty vehicles and trailers and 6% in the case of motorcycles.
Considering the uncertainty, a sensitivity analysis has been performed and is included in section 6 of
Annex 4.
All policy options are expected to result in lives saved and injuries avoided relative to the baseline
scenario. The table below provides the reduction in the number of fatalities and injuries relative to
the baseline in 2030 and 2050, as well as the cumulative number of lives saved and injuries avoided
relative to the baseline over the 2026-2050 horizon. Cumulatively, over the period 2026-2050, PO3
is expected to result in 7,013 lives saved, followed by PO2 (6,912 lives saved), PO1b (6,847 lives
saved) and PO1a (4,661 lives saved). The numbers of severe and slight injuries avoided follow a
similar pattern with PO3 having the highest impact, followed by PO2, PO1b, and PO1a.
437
See more details in Annex 4 (section 4.1) on the inputs by measure and their aggregation into policy options.
247
Table 245: Expected reduction in the number of fatalities and injuries in the POs relative to the baseline, in 2030
and 2050, and cumulative reduction over the period 2026-2050
Fatalities Serious injuries Slight injuries
PO1a 2030 195 1,768 9,929
2050 173 1,587 9,011
Cumulative over 2026-2050 4,661 42,272 239,803
% reduction 1.1% 1.2% 1.3%
PO1b 2030 287 2,711 15,099
2050 253 2,420 13,658
Cumulative over 2026-2050 6,847 64,640 364,155
% reduction 1.6% 1.8% 1.9%
PO2 2030 289 2,721 15,162
2050 255 2,429 13,712
Cumulative over 2026-2050 6,912 64,885 365,665
% reduction 1.6% 1.8% 1.9%
PO3 2030 293 2,753 15,274
2050 259 2,460 13,826
Cumulative over 2026-2050 7,013 65,686 368,498
% reduction 1.6% 1.8% 2.0%
Source: Ricardo et al. (2024), Impact assessment support study
It should be noted that the assessment of the impacts at option level has considered all synergies
between policy measures included in the options, by vehicle category. As such, the impact of a policy
measure may differ depending on whether it is assessed as part of a package or in isolation. While it
is quite straightforward for assessing the costs and costs savings by policy measure and policy option,
it is much more challenging to assess the impacts on the number of fatalities and injuries, and on
external costs.
To split the impacts on lives saved and injuries avoided, and the respective external costs, by policy
option and policy measure the synergies between measures need to be considered. One possibility
would be to assess various combinations of measures and look at differences between such
combinations. This would however result in a large number of policy options that is neither practical
nor proportionate for the analysis. On the other hand, considering that the PRIMES-TREMOVE
model calculates the impacts on road safety for each category of vehicle, an approximation of the
impacts by policy option and policy measure can be derived based on: the difference between policy
options where only one policy measure is related to a certain vehicle category (if relevant) and the
inputs used for estimating the impacts on road safety by policy measure and the combined effect of
measures, according to the common residual method. The table below presents the impacts on lives
saved and injuries avoided, cumulatively over the period 2026-2050, by policy option and policy
measure relative to the baseline.
Table 246: Expected cumulative reduction in the number of fatalities and injuries (over the period 2026-2050) by
policy option and policy measure relative to the baseline
Policy option Policy measure Fatalities Severe injuries Slight injuries
PO1a Total 4,661 42,272 239,803
PMC2 4,643 42,137 239,239
PM1 19 135 564
PO1b Total 6,847 64,640 364,155
PMC2 4,643 42,137 239,239
PM2 60 430 1,726
PM6 1,841 21,392 120,521
PM13 304 681 2,669
248
Policy option Policy measure Fatalities Severe injuries Slight injuries
PO2 Total 6,912 64,885 365,665
PMC2 4,643 42,137 239,239
PM1 19 135 564
PM6 1,841 21,392 120,521
PM13 304 681 2,669
PM14 105 540 2,671
PO3 Total 7,013 65,686 368,498
PMC2 4,643 42,137 239,239
PM3 71 552 2,004
PM4 4 25 137
PM6 1,841 21,392 120,521
PM13 304 681 2,669
PM14 105 540 2,671
PM15 45 359 1,257
Source: Ricardo et al. (2024), Impact assessment support study
The most significant impact on road safety is estimated to come as a result of the new testing
requirements in PTIs and roadside inspections, which will ensure that safety-related technologies to
be fitted in new vehicles as required by the General Safety Regulation (GSR) operate as expected
(PMC2). Due to inspections which will be able to detect defective ADAS systems there should be
fewer road crashes and thus fewer fatalities and injuries. This measure is included in and has an
impact on all policy options. In the case of PO1a, additional positive impacts are expected due to
roadside inspection of motorcycles over 125cc for those Member States438
where no PTI is currently
in place for such motorcycles (PM1), assuming that they will choose this option instead of PTI.
For PO1b, in addition to the impacts of new testing requirements for safety-related technologies
mandated by the GSR (PMC2), there are additional impacts expected from mandatory annual PTI
testing of vehicles over 10-year-old (PM6), mandatory PTI for motorcycles over 125cc (PM2) and
mandatory cargo securing inspections (PM13). The mandatory annual PTI testing of vehicles over
10-year-old (PM6) will lead to an increase of the PTI frequency in 11 Member States439
, and has the
second most significant impact on road safety after PMC2. PM2 is expected to help in the
identification of motorcycles over 125cc with significant safety defects during PTI inspections in
those countries that do not apply this measure yet440
. Mandatory inspections of cargo securing
(PM13) should ensure that appropriate standards are applied across all the EU, thus contributing to
the avoidance of accidents caused by cargo defects from HGVs (vehicle category N2/N3)441
. In PO2,
further positive, albeit smaller impact is expected due to the introduction of a systematic roadside
inspection of vans (PM14), which has a high effectiveness in capturing defective N1 vehicles. Finally,
PO3 goes further in road-safety related measures and besides the impact of measures PMC2, PM6,
PM13 and PM14, there is additional positive impact expected from the extended scope of PTI to all
motorcycle over 50 cc (PM3), which would mean a higher share of these vehicles subject to PTI and
438
BE, FI, IE, MT, NL, PT (DK already applies RSI for motorcycles and FR plans to introduce PTI in 2024).
439
CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT, SK
440
BE, FI, IE, MT, NL, PT (FR is expected to introduce PTI in 2024 and is thus part of the baseline).
441
This concerns only Member States (BE, BG, DK, DE, EE, FI, FR, IE, IT, LV, LU, NL, PL, PT) where there are no such
inspections or no adequate standards in place yet.
249
a higher share of detected defects. Mandatory PTI for O1 and O2 light trailers442
would affect around
21.5% of the total EU fleet of O1 trailers and around 9.3% of the O2 trailers (PM4). Extending the
scope of roadside inspections to all 2- and 3-wheeled vehicles (PM15) with a target of 1% of the fleet
is expected to bring an additional reduction of fatalities and serious injuries in comparison to baseline
levels. It will cover most of the EU Member States except those443
that indicated that they already
have RSI inspections for motorcycles in place, although with no clearly stated target.
The table below provides the reduction in the external costs of accidents relative to the baseline,
expressed as present value over the 2026-2050 period. The 2019 Handbook on the external costs of
transport444
was used to monetise the costs445
. As a result of the positive impacts on lives saved and
injuries avoided presented above, PO3 shows the highest impact in terms of reduction in the external
costs of accidents relative to the baseline (expressed as present value over the 2026-2050 period),
estimated at EUR 75.2 billion. It is followed by PO2 with EUR 74.2 billion, PO1b with EUR 73.9
billion, and PO1a with EUR 48.1 billion.
Table 247: Reduction in the external costs of accidents in the POs relative to the baseline, expressed as present
value over the 2026-2050 horizon, in 2022 prices (million EUR)
PO1a PO1b PO2 PO3
Fatalities 11,677 17,498 17,633 17,902
Serious injuries 21,348 33,235 33,299 33,821
Slight injuries 15,053 23,196 23,251 23,521
Total 48,079 73,929 74,183 75,244
Source: Ricardo et al. (2024), Impact assessment support study
The table below presents the impacts on external costs of accidents by policy option and policy
measure relative to the baseline, expressed as present value over the 2026-2050 period. The split by
policy measure considers the synergies between the measures included in the options. Considering
the caveats explained above, this should be seen as an approximation of the impacts by policy
measure.
Table 248: Reduction in the external costs of accidents by policy option and policy measure relative to the baseline,
expressed as present value over the 2026-2050 horizon, in 2022 prices (million EUR)
Policy measure PO1a PO1b PO2 PO3
PMC2 47,885 47,885 47,885 47,885
PM1 193 193
PM2 615
PM3 739
PM4 32
PM6 24,200 24,200 24,200
PM13 1,229 1,229 1,229
PM14 675 675
PM15 483
442
Eleven Member States would be affected by PM4: 7 Member States where there is currently no requirement for PTI
for either O1 or O2 (DK, EL, FI, FR, NL, IE, PT) and 4 Member States where there is currently only a requirement for
PTI for O2 (PL, SK, BE and ES).
443
SE, SI, AT, FI, DK, HU, RO
444
https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1
445
Based on the Handbook, the external cost of a fatality in 2022 prices is estimated at around EUR 3.5 million, that of a serious
injury at around EUR 0.5 million and that of a slight injury at around EUR 0.04 million. These values are multiplied by the number
of fatalities, serious and slight injuries, respectively, to monetise the external costs of accidents in the context of this impact
assessment.
250
Policy measure PO1a PO1b PO2 PO3
Total 48,079 73,929 74,183 75,244
Source: Ricardo et al. (2024), Impact assessment support study
5.2. Impacts on air pollution emissions and noise
Impacts on air pollutant emissions. As explained in section 6.3, the analysis of the impact on
emissions has focused on the two pollutants that are targeted in the proposed measures, NOx and
particulate matter (particulates). Other pollutants have not been considered although it is plausible
that by targeting high emitters for these two pollutants, there will also be benefits related to other air
pollutants (e.g. CO, HC, SO2). The measures included in the analysis having an impact on air
pollutant emissions are targeted at high emitters of NOx and particulate matter in the vehicle fleet,
which should be effectively identified and repaired.
All four policy options include the two measures aimed at NOx and particulate matter, PMC3
(mandatory PN testing) and PMC4 (NOx testing). All policy options include a combination of
measures specific for motorcycles (PM1 and PM15 for roadside inspections, and PM2 and PM3 for
PTI). In addition, all options but PO1a include more frequent emissions testing for vans (PM5),
mandatory annual PTI for cars and vans older than 10 years (PM6), and NOx and PM measurement
by remote sensing in roadside inspection of all vehicles and plume chasing in RSI of commercial
vehicles (PM12).
It is expected that the proposed new testing methods under PMC3 and PMC4 (PN measurement and
new NOx emissions testing) will be more effective in identifying high emitters than currently used
methods such as opacity tests. This, combined with an increased scope and frequency of inspection,
should in principle lead to a higher share of high emitters in the fleet identified. It is also expected
that roadside inspections of air pollutants (as provided in PM1 and PM15 for motorcycles, and in
PM14 for vans) will be very effective in identifying tampered vehicles since their owners will not be
prepared for the specific inspection and, in the majority of the cases, will not have the time to
deactivate the tampering device. In the case of measures related to PTI inspections (i.e., PM2 and
PM3 for motorcycles) it can be expected that they are less effective in identifying tampered vehicles
as the owners can remove or deactivate the tampering device before the PTI inspection and activate
it again after the inspection. Detailed tables with the expected impact of the four policy options in
terms of the expected level of reduction of high emitters in comparison to the baseline levels for each
vehicle category with reference to the total EU fleet are provided in section 4.2.15 of Annex 4.
Regarding both NOx and particle matter emissions, PO1a has the least impact among all options,
relative to the baseline, since it only includes common PTI measures PMC3 and PMC4 for PN and
NOx measurement, respectively, and PM1. PO1b, PO2 and PO3 are all expected to have a higher
impact than PO1a, in particular for light commercial vehicles (vans), as a result of the introduction
of more frequent emission testing starting from the first year for vans (PM5) and the requirement of
annual PTI for vehicles older than 10 years (PM6). Additional positive impacts of these three options
should arise from the introduction of remote sensing and plume chasing (PM12). However, more
positive impacts are expected for PO2 and PO3 due to the additional mandatory roadside inspection
for vans (PM14). Compared to PO1b, PO2 has a higher total expected impact on emissions from
PM1 due to assumed higher effectiveness of RSI inspections, especially in capturing tampered
vehicles, while PTIs are considered less effective in capturing of tampered vehicles. In the case of
PO3, the slightly higher level of impacts in comparison to PO2 comes from the broader scope of
motorcycles to be covered by PTI (>50 cc, PM3).
251
The table below presents the expected impact on the level of emissions in comparison to the baseline
for each policy option. PO2 and PO3 are expected to have the highest cumulative impact on air
pollutants reduction over 2026-2050 (3,969 kilo-tonnes of NOx in PO2 and 3,970 kilo-tonnes of NOx
in PO3, and 199 kilo-tonnes of PM in both PO2 and PO3), representing a decrease of 21% and 18.7%
for NOx and PM, respectively, relative to the baseline. PO1b shows somewhat lower levels of
emissions reductions (20.8% for NOx and 18.5% for PM). PO1a is expected to bring the least
reduction of both air pollutants over the 2026-2050 period (3,176 kilo-tonnes of NOx, representing a
16.8% reduction relative to the baseline, and 135 kilo-tonnes of PM, representing 12.7% reduction).
Table 249: Impact on air pollutant emissions (kilo tonnes of NOx and PM2.5 avoided relative to the baseline in
2030 and in 2050, and cumulative over 2026-2050; % change in cumulative air pollution emissions relative to the
baseline)
2030 2050 Cumulative
over 2026-2050
% change to
baseline
NOx (kilo tonnes of NOx avoided)
PO1a 200.5 12.1 3,176 -16.8%
PO1b 253.1 13.9 3,925 -20.8%
PO2 255.9 14.0 3,969 -21.0%
PO3 255.9 14.0 3,970 -21.0%
PM2.5 (kilo tonnes of PM avoided)
PO1a 7.8 0.6 135 -12.7%
PO1b 12.0 0.8 196 -18.5%
PO2 12.1 0.8 199 -18.7%
PO3 12.1 0.8 199 -18.7%
Source: Ricardo et al. (2024), Impact assessment support study
The external cost savings due to the reduction of air pollutant emissions (NOx and PM) were
calculated using the 2019 Handbook on the external costs of transport446
. PO2 and PO3 are expected
to lead to the highest levels of reduction in external costs, estimated at around EUR 76.1 billion,
expressed as present value over the 2026-2050 period. This is slightly higher than PO1b (EUR 75.2
billion) and much higher than PO1a (EUR 58.7 billion). Results are presented in the table below.
Table 250: Reduction in the external costs of air pollutant emissions relative to the baseline, expressed as present
value over 2026-2050, in 2022 prices (million EUR)
PO1a PO1b PO2 PO3
Reduction in external costs related to NOx emissions 46,966 58,054 58,646 58,659
Reduction in external costs related to PM emissions 11,707 17,193 17,429 17,429
Total reduction in external costs of air pollutant emissions 58,673 75,247 76,075 76,088
Source: Ricardo et al. (2023), Impact assessment support study
Impact on noise emissions. The measures which are expected to have the highest impact on noise
reduction are PM12, by the use of remote sensing with acoustic cameras, and PM10, through more
advanced testing methods for motorcycles at PTI. Positive impact on noise reduction is also expected
due to measures focusing on high emitters, such as the extension of scope of PTI to cover motorcycles
(PM3, but also PM1 and PM2), and extending the roadside inspections to cover motorcycles (PM15)
and light commercial (N1) vehicles (PM14). As in the case of exhaust gas aftertreatment systems,
PTI on its own is not expected to have a sizeable impact on identifying tampering of noise control
systems. Roadside inspections are generally expected to be a more effective tool, which was
confirmed by the stakeholders that responded on this point during the consultations. The limiting
446
https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1
252
factor in this case is the capacity of roadside inspections to cover a large share of the fleet. Detailed
explanations on the input by policy measure used to quantify the impacts are provided in section 4.2
of Annex 4.
When comparing the policy options, the impact on the reduction of high emitters and thereby on
noise is expected to be the lowest in PO1a as it does not contain any measure directly targeted at
noise (it has a small positive impact through PM1, the introduction of roadside checks for
motorcycles in six Member States where they are not fully covered by PTI447
). A higher impact is
expected in the case of PO1b and PO2, combining more advanced noise testing in PTI (PM10) and
use of remote sensing to support roadside inspections (PM12). For PO2 and PO3, additional positive
impacts can also arise from the increase in roadside inspection of vans but the highest impacts in
terms of noise reduction are expected in PO3, due to the mandatory RSI for motorcycles (PM15).
The table below presents the estimated reduction in the external costs of noise for the four policy
options, with PO3 providing the largest savings of around EUR 7.8 billion, expressed as present value
over 2026-2050 relative to the baseline. PO1b and PO2 are expected to bring similar reductions in
external noise cost (EUR 7.3 billion over the same period). The reduction under PO1a would be
significantly lower (EUR 0.2 billion). As for the costs of accidents and air pollution, the external
costs of noise were calculated using the PRIMES-TREMOVE model, based on the 2019 Handbook
on the external costs of transport.
Table 251: Reduction in the external costs of noise emissions relative to the baseline, expressed as present value
over 2026-2050, in 2022 prices (million EUR)
PO1a PO1b PO2 PO3
Reduction in external costs related to noise emissions 154 7,323 7,319 7,757
Source: Ricardo et al. (2024), Impact assessment support study
6. TRADE-OFFS IN TERMS OF COSTS AND BENEFITS OF SOME KEY POLICY MEASURES
As explained in section 5.1 of Annex 4, the assessment of the impacts at option level has considered
all synergies between policy measures included in the options, by vehicle category. As such, the
impact of a policy measure may differ depending on whether it is assessed as part of a package or in
isolation. While in this case this is quite straightforward for assessing the costs and costs savings by
policy measure and policy option, it is much more challenging to assess the impacts on external costs.
To split the impacts on lives saved, injuries avoided, the reduction in air pollution and noise emissions
and the respective external costs by policy option and policy measure, the synergies between
measures need to be considered. One possibility would be to assess various combinations of measures
and look at differences between such combinations. This would however result in a large number of
policy options that is neither practical nor proportionate for the analysis. On the other hand,
considering that the PRIMES-TREMOVE model calculates the impacts on road safety, air pollution
and noise external costs corresponding to each category of vehicle, an approximation of the external
costs savings by policy option and policy measure can be derived based on: (1) the difference between
policy options where only one policy measure is related to a certain vehicle category (if relevant), (2)
the inputs used for estimating the impacts on road safety and (3) the share of high-emitting vehicles
by policy measure and the combined effect of measures, according to the common residual method.
While keeping in mind the caveats above, the tables below illustrate the benefits, costs, and benefits
to costs ratio for policy measures related to motorcycles (see Table 252), for the policy measure
related to trailers (see Table 253) and older vehicles (see Table 254), and for the policy measure
447
BE, FI, IE, MT, NL, PL
253
related to odometer readings (see Table 255). All costs and benefits are expressed as present value
over 2026-2050, relative to the baseline.
While the cost and benefits of the measures addressing motorcycles and trailers are rather limited
(due to the relatively small number of Member States and number of vehicles affected), the impacts
of testing cars and vans older than 10 years annually is much more significant. This is even more so
for the policy measure related to odometer readings that shows the highest benefits.
Table 252: Benefits and costs for policy measures related to motorcycles, expressed as present value over 2026-
2050 (in million EUR)
Benefits and costs (present
value, in million EUR)
PM1
Benefits 350.9
External costs savings 350.9
Costs 17.4
Citizens 7.9
National public administrations 9.5
Benefits to costs ratio 20.2
PM2
Benefits 1,212.2
External costs savings 918.1
Other benefits for PTI centres (increased number of inspections) 294.1
Costs 502.7
PTI centres 175.7
Citizens 294.1
National public administrations 32.9
Benefits to costs ratio 2.4
PM3
Benefits 1,477.8
External costs savings 1,136.5
Other benefits for PTI centres (increased number of inspections) 341.3
Costs 583.4
PTI centres 203.9
Citizens 341.3
National public administrations 38.1
Benefits to costs ratio 2.5
PM15
Benefits 693.9
External costs savings 693.9
Costs 37.6
Citizens 16.9
National public administrations 20.6
Benefits to costs ratio 18.5
Source: Ricardo et al. (2024), Impact assessment support study
254
Table 253: Benefits and costs for the policy measure related to trailers, expressed as present value over 2026-2050
(in million EUR)
Benefits and costs (present
value, in million EUR)
PM4
Benefits 558.8
External costs savings 32.2
Other benefits for PTI centres (increased number of inspections) 526.6
Costs 791.3
PTI centres 225.4
Other businesses (vehicle owners) 385.1
Citizens 141.5
National public administrations 39.2
Benefits to costs ratio 0.7
Source: Ricardo et al. (2024), Impact assessment support study
For older vehicles (PM6), because of the high costs linked to additional investment in new PTI lanes
and equipment, and, most importantly, additional human resources, the benefits to costs ratio is 1.4
when considering the economic benefits to PTI centres due to the increased number of inspections.
Table 254: Benefits and costs for the policy measure related to older vehicles (cars and vans), expressed as present
value over 2026-2050 (in million EUR)
Benefits and costs (present value,
in million EUR)
PM6
Benefits 73,872.8
External costs savings 37,335.2
Other benefits for PTI centres (increased number of inspections) 36,537.6
Costs 54,218.4
PTI centres 17,680.8
Other businesses (vehicle owners) 23,295.9
Citizens 13,241.7
Benefits to costs ratio 1.4
Source: Ricardo et al. (2024), Impact assessment support study
The policy measure related to odometer readings (PMC9) is estimated to lead to the highest benefits
to costs ratio among the measures. This is due to the significant benefits expected for citizens and
businesses (vehicle owners) due to the reduction in odometer fraud. Even if the effectiveness of the
measure in reducing the number of vehicles with tampered odometers was significantly lower, the
benefits and the efficiency of the measure is still expected to remain high.
Table 255: Benefits and costs for the policy measure related to odometer readings, expressed as present value over
2026-2050 (in million EUR) relative to the baseline
Benefits and costs (present
value, in million EUR)
PMC9
Benefits 184,007.4
Other businesses (vehicle owners) 118,340.5
Citizens 65,666.9
Costs 2,638.0
Garages, motor vehicle dealers, tyre and repair stations, etc. 460.0
OEMs 55.9
255
Benefits and costs (present
value, in million EUR)
National public administrations 2,122.1
Benefits to costs ratio 69.8
Source: Ricardo et al. (2024), Impact assessment support study
7. SENSITIVITY ANALYSIS
Sensitivity analysis on contribution of technical defects to road crashes and share of high
emitting vehicles of air pollution and noise in the fleet. As indicated in section 6.2.1, there is
significant uncertainty around the contribution of technical defects to road crashes. The central
assumption used is that 4% of road crashes are caused by technical defects in the case of cars, vans,
heavy duty vehicles and trailers and 6% in the case of motorcycles. A sensitivity analysis has been
performed to understand the implications of lower or higher contribution of technical defects to road
crashes. The following cases have been assessed:
- Low case: 3% for motorcycles and 1% for all other categories;
- High case: 9% for motorcycles and 7% for all other vehicle categories.
In addition, considering the uncertainty of the share of high emitting vehicles of air pollution and
noise in the fleet, the implications of alternative shares of high and low emitters in the baseline
scenario have been assessed. More specifically, compared to the central case the following
assumptions have been used:
- Low case: shares of high emitters 25% lower than in the baseline;
- High case: shares of high emitters 25% higher than in the baseline.
Subsequently, the impacts on external costs and the efficiency of the policy options is assessed for
the low and high case, including both elements related to safety and emissions.
The table below presents the impacts on the external costs of accidents, air pollution and noise, in the
low case, central case (i.e. central estimate used in the assessment) and high case.
Table 256: External costs savings by policy option in the low case, central case and high case, expressed as present
value over 2026-2050 compared to the baseline (in million EUR, in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Total external costs savings - low
case
91,372.4 116,754.9 117,340.6 118,216.9
Reduction in external costs of air
pollution emissions
42,119.0 55,690.0 56,322.0 56,332.0
Reduction in external costs of noise
emissions
1,271.4 5,589.9 5,585.6 5,920.9
Reduction in external costs of
accidents
47,982.0 55,475.0 55,433.0 55,964.0
Total external costs savings -
central case
106,906.2 156,499.4 157,577.4 159,088.7
Reduction in external costs of air
pollution emissions
58,673.0 75,247.0 76,075.0 76,088.0
Reduction in external costs of noise
emissions
154.2 7,323.4 7,319.4 7,756.7
Reduction in external costs of
accidents
48,079.0 73,929.0 74,183.0 75,244.0
256
Difference to the Baseline
PO1a PO1b PO2 PO3
Total external costs savings - high
case
126,790.2 197,380.7 198,932.4 201,093.3
Reduction in external costs of air
pollution emissions
76,510.0 95,745.0 96,758.0 96,774.0
Reduction in external costs of noise
emissions
2,104.2 9,251.7 9,245.4 9,799.3
Reduction in external costs of
accidents
48,176.0 92,384.0 92,929.0 94,520.0
Source: Ricardo et al. (2024), Impact assessment support study
The following table presents the impacts on total benefits, net benefits and benefits to costs ratio by
policy option in the low case, central case and high case. It shows that all policy options are expected
to result in net benefits under the three cases considered. It also shows that the ranking of the policy
options is not expected to change in the low case and high case relative to the central case estimates.
Table 257: Summary of costs and benefits of the policy options in the low case, central case and high case,
expressed as present value over 2025-2050 compared to the baseline (in million EUR, in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Total costs 7,303.3 65,792.3 65,903.9 68,598.9
Total benefits
Low case 282,344.8 347,977.0 351,341.5 355,230.4
Central case 297,878.6 387,721.5 391,578.3 396,102.2
High case 317,762.6 428,602.8 432,933.3 438,106.8
Net benefits
Low case 275,041.5 282,184.7 285,437.6 286,631.5
Central case 290,575.3 321,929.3 325,674.4 327,503.3
High case 310,459.3 362,810.5 367,029.4 369,507.9
Benefits to costs ratio
Low case 38.7 5.3 5.3 5.2
Central case 40.8 5.9 5.9 5.8
High case 43.5 6.5 6.6 6.4
Source: Ricardo et al. (2024), Impact assessment support study
Sensitivity analysis on odometer fraud. As explained in sections 6.1.2.4 and 6.1.3, it should be
acknowledged that there is uncertainty regarding the economic damage caused by odometer fraud
and the number of vehicles affected. For this reason, sensitivity analysis has been performed on the
economic damage caused by odometer fraud and the number of vehicles affected.
With regard to the economic damage caused by odometer fraud, a central estimate of EUR 2,119
per vehicle has been used and it is explained in more detail in Annex 4 (section 2). The following
cases have been assessed:
- Low economic damage case: 20% lower damage costs/costs savings per vehicle (EUR 1,696
per vehicle);
- High economic damage case: 20% higher damage costs/costs savings per vehicle (EUR 2,543
per vehicle).
257
Subsequently, the impacts on the benefits due to avoided odometer fraud and the efficiency of the
policy options is assessed for the low economic damage and high economic damage case.
The table below presents the benefits due to avoided odometer fraud for national and cross-border
sales, in the low economic damage case, central case (i.e. central estimate used in the assessment)
and high economic damage case.
Table 258: Benefits due to avoided odometer fraud by policy option in the low economic damage case, central case
and high economic damage case, expressed as present value over 2026-2050 compared to the baseline (in million
EUR, in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Low economic damage case 147,205.9 147,205.9 147,205.9 147,205.9
National 52,718.5 52,718.5 52,718.5 52,718.5
Cross border 94,487.4 94,487.4 94,487.4 94,487.4
Central case 184,007.4 184,007.4 184,007.4 184,007.4
National 65,898.2 65,898.2 65,898.2 65,898.2
Cross border 118,109.2 118,109.2 118,109.2 118,109.2
High economic damage case 220,808.9 220,808.9 220,808.9 220,808.9
National 79,077.8 79,077.8 79,077.8 79,077.8
Cross border 141,731.1 141,731.1 141,731.1 141,731.1
Source: Ricardo et al. (2024), Impact assessment support study
The following table presents the impacts on total benefits, net benefits and benefits to costs ratio by
policy option in the low economic damage case, central case and high economic damage case. It
shows that all policy options are expected to result in net benefits under the three cases considered.
It also shows that the ranking of the policy options is not expected to change in the low economic
damage case and high economic damage case relative to the central case estimates.
Table 259: Summary of costs and benefits of the policy options in the low economic damage case, central case and
high economic damage case, expressed as present value over 2025-2050 compared to the baseline (in million EUR,
in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Total costs 7,303.3 65,792.3 65,903.9 68,598.9
Total benefits
Low economic damage case 261,077.0 350,920.0 354,776.4 359,300.6
Central case 297,878.5 387,721.5 391,577.8 396,102.1
High economic damage case 334,680.0 424,523.0 428,379.3 432,903.6
Net benefits
Low economic damage case 253,773.7 285,127.7 288,872.5 290,701.7
Central case 290,575.2 321,929.2 325,674.0 327,503.2
High economic damage case 327,376.7 358,730.7 362,475.4 364,304.7
Benefits to costs ratio
Low economic damage case 35.7 5.3 5.4 5.2
Central case 40.8 5.9 5.9 5.8
High economic damage case 45.8 6.5 6.5 6.3
Source: Ricardo et al. (2024), Impact assessment support study
With regard to the number of vehicles affected, the central assumptions used for the shares of
vehicles with tampered odometers are provided in Annex 4 (section 2), Table 37. The following cases
have been assessed:
- Fewer vehicles affected case: share of affected vehicles 20% lower than in the central case;
258
- More vehicles affected case: share of affected vehicles 20% higher than in the central case.
The table below presents the benefits due to avoided odometer fraud for national and cross-border
sales, in the fewer vehicles affected case, central case (i.e. central estimate used in the assessment)
and more vehicles affected case.
Table 260: Benefits due to avoided odometer fraud by policy option in the fewer vehicles affected case, central
case and more vehicles affected case, expressed as present value over 2026-2050 compared to the baseline (in
million EUR, in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Fewer vehicles affected case 147,205.9 147,205.9 147,205.9 147,205.9
National 52,718.5 52,718.5 52,718.5 52,718.5
Cross border 94,487.4 94,487.4 94,487.4 94,487.4
Central case 184,007.4 184,007.4 184,007.4 184,007.4
National 65,898.2 65,898.2 65,898.2 65,898.2
Cross border 118,109.2 118,109.2 118,109.2 118,109.2
More vehicles affected case 220,808.9 220,808.9 220,808.9 220,808.9
National 79,077.8 79,077.8 79,077.8 79,077.8
Cross border 141,731.1 141,731.1 141,731.1 141,731.1
Source: Ricardo et al. (2024), Impact assessment support study
The following table presents the impacts on total benefits, net benefits and benefits to costs ratio by
policy option in the fewer vehicles affected case, central case and more vehicles affected case. It
shows that all policy options are expected to result in net benefits under the three cases considered.
It also shows that the ranking of the policy options is not expected to change in the fewer vehicles
affected case and more vehicles affected case relative to the central case estimates.
Table 261: Summary of costs and benefits of the policy options in the fewer vehicles affected case, central case and
more vehicles affected case, expressed as present value over 2025-2050 compared to the baseline (in million EUR,
in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Total costs 7,303.3 65,792.3 65,903.9 68,598.9
Total benefits
Fewer vehicles affected case 261,077.0 350,920.0 354,776.4 359,300.6
Central case 297,878.5 387,721.5 391,577.8 396,102.1
More vehicles affected case 334,680.0 424,523.0 428,379.3 432,903.6
Net benefits
Fewer vehicles affected case 253,773.7 285,127.7 288,872.5 290,701.7
Central case 290,575.2 321,929.2 325,674.0 327,503.2
More vehicles affected case 327,376.7 358,730.7 362,475.4 364,304.7
Benefits to costs ratio
Fewer vehicles affected case 35.7 5.3 5.4 5.2
Central case 40.8 5.9 5.9 5.8
More vehicles affected case 45.8 6.5 6.5 6.3
Source: Ricardo et al. (2024), Impact assessment support study
The number of vehicles affected in 2026, 2030, 2040 and 2050 in the fewer vehicles affected case,
central case and more vehicles affected case is further provided in the table below.
Table 262: Number of vehicles affected in 2026, 2030, 2040 and 2050 in the fewer vehicles affected case, central
case and more vehicles affected case
259
Difference to the baseline
2026 2030 2040 2050
Fewer vehicles affected case
National second hand sales with
mileage fraud (million vehicles)
1.30 1.37 1.52 1.52
Cross border sales with mileage fraud
(million vehicles)
2.55 2.68 2.87 2.91
National mileage fraud avoidance
(million vehicles)
1.26 1.33 1.48 1.47
Cross border mileage fraud avoidance
(million vehicles)
2.29 2.41 2.58 2.62
Central case
National second hand sales with
mileage fraud (million vehicles)
1.63 1.71 1.90 1.90
Cross border sales with mileage fraud
(million vehicles)
3.18 3.35 3.59 3.64
National mileage fraud avoidance
(million vehicles)
1.58 1.66 1.85 1.84
Cross border mileage fraud avoidance
(million vehicles)
2.87 3.01 3.23 3.28
More vehicles affected case
National second hand sales with
mileage fraud (million vehicles)
1.96 2.06 2.28 2.28
Cross border sales with mileage fraud
(million vehicles)
3.82 4.02 4.30 4.37
National mileage fraud avoidance
(million vehicles)
1.90 1.99 2.22 2.21
Cross border mileage fraud avoidance
(million vehicles)
3.44 3.61 3.87 3.93
Source: Ricardo et al. (2024), Impact assessment support study
In addition, the combined impact of the economic damage caused by odometer fraud and vehicles
affected has been assessed as follows:
- Low economic damage and vehicles affected case: 20% lower damage costs/costs savings per
vehicle (EUR 1,696 per vehicle) and the share of affected vehicles 20% lower than in the
central case;
- High economic damage and vehicles affected case: 20% higher damage costs/costs savings
per vehicle (EUR 2,543 per vehicle) and the share of affected vehicles 20% higher than in the
central case.
Subsequently, the impacts on the benefits due to avoided odometer fraud and the efficiency of the
policy options is assessed for the low economic damage and vehicles affected case and for the high
economic damage and vehicles affected case.
The table below presents the benefits due to avoided odometer fraud for national and cross-border
sales, in the low economic damage and vehicles affected case, central case (i.e. central estimate used
in the assessment) and high economic damage and vehicles affected case.
260
Table 263: Benefits due to avoided odometer fraud by policy option in the low economic damage and vehicles
affected case, central case and high economic damage and vehicles affected case, expressed as present value over
2026-2050 compared to the baseline (in million EUR, in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Low economic damage and vehicles
affected case
117,764.7 117,764.7 117,764.7 117,764.7
National 42,174.8 42,174.8 42,174.8 42,174.8
Cross border 75,589.9 75,589.9 75,589.9 75,589.9
Central case 184,007.4 184,007.4 184,007.4 184,007.4
National 65,898.2 65,898.2 65,898.2 65,898.2
Cross border 118,109.2 118,109.2 118,109.2 118,109.2
High economic damage and vehicles
affected case
264,970.6 264,970.6 264,970.6 264,970.6
National 94,893.4 94,893.4 94,893.4 94,893.4
Cross border 170,077.3 170,077.3 170,077.3 170,077.3
Source: Ricardo et al. (2024), Impact assessment support study
The following table presents the impacts on total benefits, net benefits and benefits to costs ratio by
policy option in the low economic damage and vehicles affected case, central case and high economic
damage and vehicles affected case. It shows that all policy options are expected to result in net
benefits under the three cases considered. It also shows that the ranking of the policy options is not
expected to significantly change in the low economic damage and vehicles affected case and high
economic damage and vehicles affected case relative to the central case estimates.
Table 264: Summary of costs and benefits of the policy options in the low economic damage and vehicles affected
case, central case and high economic damage and vehicles affected case, expressed as present value over 2025-
2050 compared to the baseline (in million EUR, in 2022 prices)
Difference to the Baseline
PO1a PO1b PO2 PO3
Total costs 7,303.3 65,792.3 65,903.9 68,598.9
Total benefits
Low economic damage and vehicles
affected case
231,635.9 321,478.8 325,335.2 329,859.5
Central case 297,878.5 387,721.5 391,577.8 396,102.1
High economic damage and vehicles
affected case
378,841.8 468,684.7 472,541.1 477,065.4
Net benefits
Low economic damage and vehicles
affected case
224,332.5 255,686.6 259,431.3 261,260.6
Central case 290,575.2 321,929.2 325,674.0 327,503.2
High economic damage and vehicles
affected case
371,538.5 402,892.5 406,637.2 408,466.5
Benefits to costs ratio
Low economic damage and vehicles
affected case
31.7 4.9 4.9 4.8
Central case 40.8 5.9 5.9 5.8
High economic damage and vehicles
affected case
51.9 7.1 7.2 7.0
Source: Ricardo et al. (2024), Impact assessment support study
261
8. TESTING TECHNOLOGIES
It should be noted that most of the technologies required for more advanced testing in the policy
measures are available. However certain test methods need to be developed. This is true for electric
vehicles, advanced driver assistance systems, as well as for testing the emissions of modern vehicles.
Although electric vehicles have now been subject to PTI for some time, the PTI Directive has no
specific provision to test high-voltage systems and thus the risks associated with them. Certain
Member States have applied their own test methods but there is scope for harmonising the items to
be checked as well as the methods used. An overview of the main technologies/test methods relevant
for specific measures is provided in the table below.
Table 265: Technology/methods required by specific policy measures
Measure Technology/test procedure
required
Current status
PMC1 Visual testing and tools to
measure insulation
resistance and equipotential
bonding
This technology and equipment already exists (see for example:
https://www.hioki.com/euro-
en/learning/applications/detail/id_n1265994) – a number of stakeholders
confirmed this (e.g. TUV, ARBO, CITA, FSD) but indicated that they do
not take place in general as this is not required for roadworthiness testing.
See also: https://citainsp.org/wp-
content/uploads/2023/06/CITA_WP_BEV_REV1_15062023_FINAL.p
df
A recent proposal from FR focused on visual inspection on the basis that
this is faster/cheaper and, in FR’s view, sufficient.
PMC2 PTI scan tool Already exists and being used, though not as widely and regularly as it
could be.
PTI centres are required to have scan tools since May 2023 only and their
use is optional. As such, only a few MSs have made use of it for testing
electronic safety systems or checking the status of emission control
systems. An ISO standard describing the checks of safety-related systems
has only been developed recently.
PMC3 PN testing equipment Already exists and has been used by three Member States that have made
PN testing a requirement. Most other Member States did not indicate a
clear intention to introduce these existing test methods as requirement.
PMC4 NOx testing equipment and
standardised testing
procedure
NOx testing procedures exist but JRC is still working on a test method.
Current experience (e.g. Flanders) suggest that this is expensive but over
time and with large scale adoption costs may come down.
Cost can also be a barrier for PTI adoption given the consideration that
PTI should not be an expensive test. The intention is to combine this test
with the PN test.
PMC6 Digital technology for
electronic roadworthiness
certificate
Generally available – not barrier/issue for adoption besides investment
costs
PM7 Need to apply advanced
testing of suspension
(damping efficiency of
shock absorbers) for all
vehicles and specific
Relevant equipment and testing methods are in place and used in some
Member States (according to SE, DE authorities and CITA). Reason for
no broader adoption is mainly the cost.
262
Measure Technology/test procedure
required
Current status
braking test (extrapolation
method) for HDVs.
PM10 Advance noise testing
similar to pass-by noise test
described in the UN
Regulation no. 41
Existing technology already used in some Member States (DE, ES, HR
and SK). A barrier for broader adoption is the cost of equipment and/or
requirements for ensuring silence (according to Dutch authorities,
EGEA) that may require additional investment.
PM12 Remote sensing, plume
chasing equipment for NOx
and PM and acoustic
cameras for noise
Technologies already exist and also methodologies are in place.
Main barrier for adoption is the reliability of the methods along with
investment cost, and the fact that they are not seen by some stakeholders
as replacing PTI (e.g. TUV (DE), AECA-ITV (BE)) but as
complementary (AEEC refers to a few member states (DK, BE) that have
tried remote sensing or plume chasing). There is no clear indication of
expected broader uptake at Member State level. FI indicated that the
approach should not become mandatory and ES that they do not see this
as priority for RSI.
PM16 No specific technologies
needed – digital
technologies already in
place
Barrier for broader adoption is the cost/investment needed. Most
authorities supported the measure in principle but proposed that it should
not be mandatory (e.g. NL, DE, FI, SI, NO, SK, LV) although others
prefer it to be mandatory (ES, SE, HR).
263
ANNEX 5: COMPETITIVENESS CHECK
1. OVERVIEW OF IMPACTS ON COMPETITIVENESS
Dimensions of
Competitiveness
Impact of the initiative
(++ / + / 0 / - / -- / n.a.)
References to sub-sections of the
main report or annexes
Cost and price competitiveness 0/+ 6.1.2, 6.1.4 and Annex 4 (section 3)
International competitiveness n.a. n.a.
Capacity to innovate + 6.1.5
SME competitiveness 0/+ 6.1.6 and Annex 10
2. SYNTHETIC ASSESSMENT
Cost and price competitiveness
PTI centres and businesses that own and use light and heavy-duty vehicles are expected to face
significant costs related to additional testing requirements and data governance in PO2. Total one-
off costs for PTI centres have been estimated at EUR 3.3 billion. Recurrent costs are expected to
amount to EUR 20.2 billion for PTI centres and EUR 25.7 billion for other businesses (vehicle
owners), expressed as present value over 2026-2050 relative to the baseline. Vehicle manufacturers,
and garages will face comparatively lower costs (one-off costs: EUR 20 million for vehicle
manufacturers and EUR 149.2 million for garages; recurrent administrative costs: EUR 35.9 million
for vehicle manufacturers and EUR 310.8 million for garages).
At the same time, PTI centres will benefit from administrative cost savings (EUR 1.6 billion,
expressed as present value over 2026-2050 relative to the baseline) and, more importantly, the
expectation of new business creation and thus revenues (EUR 39.1 billion). Total net benefits for PTI
centres are estimated at EUR 17.3 billion, expressed as present value over 2026-2050 relative to the
baseline. As shown in section 6.1.2.1 (Table 11), net benefits per PTI centre would represent around
6.3% of the turnover. It is further expected that PTI centres may be able to pass on the incurred costs
related to investments in equipment to vehicle owners (businesses and citizens). This will vary from
Member State to Member State and depend on whether PTI prices are regulated or not, as well as on
the type of contract/agreement PTI providers have with the competent national authority. Thus, PO2
is expected to lead to an increase in the profitability of PTI centres.
As explained above, additional costs are expected to arise for businesses that own and use light and
heavy-duty vehicles, either because of the expected increase in the frequency and costs of PTI or the
extra time spent during roadside inspections. These will be more than counterbalanced by cost
savings and other benefits, in particular by the benefits due to avoided odometer fraud. The net
benefits for businesses that own and use light and heavy-duty vehicles are estimated at EUR 94
billion, expressed as present value over 2026-2050 relative to the baseline.
Vehicle manufacturers and garages will face comparatively lower costs, as explained above, and no
costs savings, resulting in net costs of EUR 55.9 million and EUR 460 million, respectively,
expressed as present value over 2026-2050 relative to the baseline.
264
International competitiveness
This initiative has no evident impact on the international competitiveness of EU businesses related
to the provision of PTI services that need to take place in the EU. Non-EU businesses in the specific
sector cannot be expected to benefit. Since the corresponding test requirements would be first
introduced in the EU, garage equipment and other testing equipment manufacturers could benefit
from a possible first mover advantage that can also arise for EU manufacturers. However, the
measures and requirements should apply equally to European and non-European manufacturers, to
the extent that they have equal access to the EU market on the basis of the EU standards. Finally, EU
based transport operators and other business that use vehicles on a frequent basis may experience
some extra costs as a result of the more demanding measures and time spent during roadside
inspections but would at the same time benefit significantly from the avoided odometer fraud.
Transport operators from third countries active in Europe may benefit from some reduced PTI costs
in comparison to their EU competitors although they can still be subject to roadside inspections by
authorities.
Put together, there is no evidence of a strong positive or strong negative impact on international
competitiveness. Businesses in equipment manufacturing sectors may benefit from the first mover
advantage while transport operators may face stricter PTI requirements that will not arise for their
counterparts outside Europe but active in Europe. Those non-EU hauliers will however equally be
subject to more advanced roadside inspections. These positive or negative impacts are expected to
be limited.
Capacity to innovate
As explained in section 6.1.5, positive impacts on innovation are expected from requiring more
stringent and advanced test methods that also need to be adjusted to the general requirement for a
PTI to be quick, simple and affordable. The initiative would provide garage and testing equipment
manufacturers with new opportunities, mainly on the basis of increased demand that will arise from
the implementation of the policy measures. The measures outlined will largely rely on existing
measurement and testing technologies, which are not expected to require significant innovation in
design. However, they can still be expected to require adaptations and further improvements to meet
the needs of PTI and roadside inspections, facilitating process innovation. There will also be a need
to establish and implement the accompanying standards for the widespread adoption of the
measurement and testing methods related to NOx and PN measurements, remote sensing, the use of
ePTI and noise measurement, which can further facilitate their adoption but can also provide the basis
for the development of alternative, competing, solutions. To the extent that there is eventually a
broader adoption of such technologies, a possible first mover advantage can arise for EU
manufacturers. However, in principle, it should benefit equally European and non-European
manufacturers, to the extent that they have equal access to the EU market based on the EU standards
set.
The consulted stakeholders expect a positive impact on the innovative capacity of the sectors affected
from measures related to new PTI/RSI test requirements, improved access and exchange of
information and the digitalisation of vehicle documents.
Furthermore, increased demand for new test methods and equipment can be expected to generate
further development of relevant technologies by developers of measurement equipment, a viewpoint
supported by the representatives of the sector in their contribution to the stakeholder consultation.
265
Together with that, relevant training of inspectors to the new test methods will enhance the
availability of technical skills and expertise that can have a broader positive impact. As such, most
of the common measures are expected to have some positive impact on innovation (PMC1 on the
testing of electric vehicles, PMC2 using ePTI, PMC3 and PMC4 on new emission tests, PMC6 on
digital PTI certificates, and PMC7 on more efficient exchange of vehicle data).
While in the case of PO1a the digitalisation of the registration certificates (PM16) may require further
innovation, PO1b would introduce remote sensing and plume chasing (PM12) to monitor air
pollutants and noise emitted by vehicles. Remote sensing also relies on existing technologies but
requires adaptations to scale them up to cover the desired share of the vehicle fleet. Deploying these
technologies at a larger scale than today would also necessitate process innovation. PO2 and PO3
combine the benefits of both measures.
SME competitiveness
As explained in Annex 10 and in section 6.1.6, for PTI centres, while it was not possible to split the
costs and benefits between SME and others due to the lack of data, a large part of costs and benefits
are expected to be attributed to SMEs. In PO2, net benefits for PTI centres are expected to represent
around 6.3% of the turnover.
Garage equipment manufacturers are expected to benefit from additional business opportunities
linked to higher demand for testing equipment, although such impacts were not possible to quantify.
Garages, motor vehicle dealers, tyre and repair workshops, etc., mostly SMEs, will be affected by
the requirement for Member States to set up a system to record odometer readings from the cars and
vans registered in their territory (PMC9). As explained in section 6.1.2.2, total one-off and recurrent
administrative costs would amount to EUR 460 million (EUR 706 per company), expressed as present
value over 2026-2050.
For businesses owning vehicles, as explained in section 6.1.2.4, PO2 is expected to result in net
benefits estimated at EUR 94 billion, expressed as present value over 2025-2050 relative to the
baseline. Based on the available information, it was however not possible to assess how many of the
businesses owning vehicles are SMEs. Only few of the measures in PO2 are expected to affect the
road haulage sector largely composed of SMEs (e.g., PM13 on cargo securing inspections, which
would result in minimal costs, while hauliers could also benefit from the savings of avoided emission
tests at PTI after having passed a RSI or a remote sensing check). The overall impact on the road
haulage sector is expected to be limited but rather positive, although the available data did not allow
a split of the costs and benefits between the two groups of operators (i.e., SME and others).
266
ANNEX 6: BACKGROUND ON ROADWORTHINESS LEGISLATION AND PTI
ORGANISATION IN MEMBER STATES
This annex provides background information related to:
• the evolution of the EU roadworthiness legislation;
• the way PTI is organised in Member States;
• the average prices of PTI in Member States.
1. EVOLUTION OF EU ROADWORTHINESS LEGISLATION
Figure 9: Road safety policy and PTI in the EU
Source: EUR-Lex, DEKRA presentation, CITA International Conference 2023, Rotterdam
267
2. ORGANISATION OF PTI IN MEMBER STATES
Table 266: Periodic technical inspection in Member States, passenger cars
Country Frequency
(in years)
Conducted by Country Frequency
(in years)
Conducted by
Austria 3-2-1-1- A Ireland 4-2-2-2-1-1 B
Belgium 4-1-1-1- B Italy 4-2-2-2- D
Bulgaria 3-2-1-1- Lithuania 3-2-2-2 B
Cyprus 4-2-2-2- B Luxembourg 4-2-1-1- B
Czechia 4-2-2-2- Latvia 2-2-1-1- B & C & D
Germany 3-2-2-2- B Malta 4-2-2-2- B
Denmark 4-2-2-2- The Netherlands Petrol/electric 4-2-
2-1-1 diesel/other
3-1-1-1
A
Estonia 4-2-2-2-1 B Poland 3-2-1-1- B
Greece 4-2-2-2- B & D Portugal 4-2-2-1- B
Spain 4-2-2-2-1- B & D Romania 3-2-2-2-2-1- B & D
Finland 4-2-2-2-1- B Sweden 3 years – 2 years –
14 months – 14
months – 14
months
B
France 4-2-2-2- B Slovenia 4-2-2-1- B
Croatia 2-1-1-1- B Slovakia 4-2-2-2- B
Hungary 4-2-2-2- B & D
A: Commercial garages: commercial garages that are also allowed to carry out repairs
B: Private inspection centres: privately owned vehicle inspection centres
C: Central Licencing Authority: the central licencing authority in the country
D: Public inspection centres: governmental owned vehicle inspection centres
Sources: https://road-safety.transport.ec.europa.eu/road-safety-member-states/roadworthiness-certificate-and-proof-
test_en, https://www.ereg-association.eu/publications/the-vehicle-and-driver-chain-in-europe/
268
3. OVERVIEW OF PTI CONSUMER PRICES IN EU MEMBER STATES
Table 267: PTI consumer prices by Member State
MEMBER
STATE
PTI PRICE LIGHT VEHICLES PTI PRICE HEAVY
VEHICLES
REFERENCES
Austria Vary from garage to garage:
Petrol and Diesel cars
€49.70 – 125.70 (average €82.38)
Members of ÖAMTC €49,70. Members of
ARBÖ €59,90
Electric cars
€49,70 – 131,04 (average: €84,69
Vary from deals between garage
and transport businesses
Authority interview
https://wien.arbeiterkammer.at/be
ratung/konsumentenschutz/auto/2
02305_KFZ-Pickerlkosten.pdf
Belgium 38.2€ (VAT 21% included)
+ 4.90 (spark ignition)
+ 14.60 (diesel)
68.1€ (VAT 21% included) https://www.autoveiligheid.be/sit
es/default/files/tarieven_ak_2023.
pdf
https://www.autocontrole.be/fr/tar
ifs
Bulgaria For M1 vehicles the price including VAT is 50
BGN (approx. 25,58 €)
For M2 and M3 vehicles the
price including VAT is 70 BGN
(approx. 35,81 €) https://dekra-
automotive.bg/annual-technical-
inspections
Croatia Technical inspection of a personal vehicle –
20,25 € + VAT
ECOtest DIESEL – 13,61 € + VAT
Forms and technical inspection registers 2 – €
1,24 + VAT (8,78) €Total – 43,88 €
The price of PTI for L vehicles (without VAT)
is 12,30 €
For PTI of M2 and M3 vehicles,
the price without VAT (25%) is
32,55 €
VEHICLE TECHNICAL
INSPECTION AND VEHICLE
REGISTRATION - Price
(plocice.hr)
https://narodne-
novine.nn.hr/clanci/sluzbeni/2022
_12_155_2459.html
Cyprus For M1 vehicles, the IKTEO (Private Technical
Inspection Centres for Vehicles)
fee is 35 € (incl. VAT)
For M2 vehicles, the IKTEO fee
is 65 € (incl. VAT)
For M3 vehicles, the IKTEO fee
is 85 € (incl. VAT)
The Motor Vehicles
(Roadworthiness Tests and
Technical Inspection Centres)
Law of 2007 - 1(I)/2007
(cylaw.org)
The 4 IKTEOs licensed by the
Ministry of Education.
Transport/Price List
(brief.com.cy)
Τιμοκατάλογος – M.O.T
Paralimni | Giovanis
(motgiovanis.com)
The МОТ test: governmental
vehicle inspection
(pitsasinsurances.com)
Czechia Price for regular technical inspection of M1 and
N1 vehicles: 1 200 CZK (approx. 49,09 €)
Trailers category O1 up to
750kg: 800 CZK (approx. 32,72
€)
Price list - Pronto STK s.r.o.
(stkpraha.cz)
269
MEMBER
STATE
PTI PRICE LIGHT VEHICLES PTI PRICE HEAVY
VEHICLES
REFERENCES
For category L vehicles (mopeds/motorcycles)
the price is 800 CZK (approx. 32,72 €)
Trailers category O2 from 750kg
to 3500kg: 1100 CZK (approx.
44,99 €)
Denmark Varies from garage to garage and depending on
the time of the day.
In 2016, the average price was €50.
Varies from deals between
garage and transport businesses
Authority interview
https://www.europe-
consommateurs.eu/fileadmin/Med
ia/PDF/PDF_EN/Cross_border_c
ar_purchase_2016/PDF_EN/Coun
try_fact_sheets___purchase/Coun
try_fact_sheets_purchase_FINAL
-DK.pdf
Estonia M1 vehicles - 43,95/49,95€ M2 vehicles - 53,95/59,95€
M3 vehicles - 65,95/71,95 €
Hinnakiri | Tehnoülevaatus al.
19€ | Tehnoülevaatus.ee
(tehnoulevaatus.ee)
Finland Vary from garage to garage – 25-70 EUR Authority interview
France Between 74,85 and 90 € Between 74,85 and 90 € Prix contrôle technique |
moncontroletechnique.fr
Germany Vary from garage and regions, between EUR
133,90 - 145 Euro
https://www.handelsblatt.com/un
ternehmen/tuev-kosten-2023-so-
teuer-sind-hauptuntersuchung-
und-abgasuntersuchung-aktuell-
/27005938.html
Greece Passenger cars €45-60
Motorcycles €20-35
Taxi €30-45
Trucks (up to 3.5t) €54-70
Recheck €3-6
https://www.gocar.gr/news/feed/
28822,Poso_kostizei_to_KTEO.h
tml
https://www.checkyourcar.gr/
Hungary The price for passenger car inspection is HUF
21,000-24,000 (EUR 54,68-62,49) in the case
of four-wheel drive passenger cars HUF
25,000-28,000 (EUR 65,09-72,90).
Technical examination of trucks
for 2-4 wheel drive vehicles
costs HUF 22,000-26,000 (EUR
57,28-67,7) and HUF 27,000-
30,000 (EUR 70,30-78,11)
2023 Műszaki vizsga ára (Jármű
típus szerint) – Qjob.hu
Ireland 55 EUR https://www.rsa.ie
Italy If performed by the national authority
“Motorizzazione civile”, the cost of PTI is 45 €.
If performed by private inspection centres, the
cost varies depending on the centre: the average
the price for cars in 2023 ranges between € 50
and € 80.
Example of a cost breakdown of inspection at
private centres - € 54.95 plus VAT, DMS fees
and payment commissions: 54.95 € mandatory
revision fee + 12.09 € VAT 22% on the
Same as light vehicles https://www.rattiauto.it/it-
it/blog/curiosita/revisione-auto-
2023-prezzi-e-
rimborsi#:~:text=Per%20effettuar
e%20la%20revisione%20auto,eur
o%20e%20gli%2080%20euro
https://www.revisioneauto.eu/do
mande-frequenti/revisione-auto-
normativa-costi-scadenza-
sanzioni
270
MEMBER
STATE
PTI PRICE LIGHT VEHICLES PTI PRICE HEAVY
VEHICLES
REFERENCES
compulsory audit fee + 10.20 € DMS fee + 1.76
€ DMS fee payment commission
https://assicurazioni.segugio.it/ne
ws-assicurazioni/revisione-auto-
modalita-scadenze-e-costi-per-il-
2023-
00037311.html#:~:text=In%20par
ticolare%2C%20presso%20la%2
0Motorizzazione,euro%20a%207
9%2C02%20euro.
Latvia Basic test for a vehicle of category M1 - 29,40
€
Basic test for a vehicle of
category M2- 32,97 €
Basic test for a vehicle of
category M3 - 50,19 €
Bus with a laden weight of more
than 5 tonnes (category M3) |
Payments for technical inspection
| Technical inspection | Vehicle
(csdd.lv)
Lithuania For M1 vehicles prices for technical inspections
range from 23 to 28,90 €
For motorcycles/mopeds, the price is 11,30 €
Inspection of M2 class small
buses – 26, 6 €
Inspection of M3 class buses,
trolleybuses – 37,8 €
Inspection of M3 class
connected buses, trolleybuses –
42,8 €
Compulsory roadworthiness
testing prices | TUVLITA
Luxembourg 64 EUR 77 EUR https://www.snct.lu/clients-
particuliers/tarifs-du-controle-
technique
Malta VRT testing for car now costs € 30.27, as
against the € 25.27 that used to be charged until
2022
Cost of VRT testing up €5 as from
January - The Malta Independent
Netherlands Varies from garage to garage (and depends on
age of vehicle):
e.g., €42-78.50, or €43.10-52.80
Varies from garage to garage:
e.g., €100-193 or €68.10
https://vanabeelen.nl/tarieven
https://www.km.be/autokeuring/ta
rieven
Poland The cost of periodic technical inspection is
determined by the ministry and in the case of
passenger cars it is PLN 99 (approx. € 21,33).
Owners of vehicles with LPG/CNG gas
installations pay PLN 162 (approx. 34,90 €)
Motorbikes: 62 PLN incl. VAT (approx. 13,32
€)
Passenger cars, buses designed
to carry no more than 15 people
including the driver, lorries: 98
PLN incl. VAT (approx. 21,05 €)
Buses designed to carry more
than 15 people including the
driver:199 PLN incl. VAT
(approx. 42, 75 €)
https://beesafe.pl/porady/ile-
kosztuje-przeglad-
samochodu/#:~:text=Koszt%20ok
resowego%20przegl%C4%85du
%20technicznego%20ustalany,z
%20gazem%20kosztuje%20162
%20z%C5%82ote.
https://www.infor.pl/akt-
prawny/DZU.2004.223.0002261,r
ozporzadzenie-ministra-
infrastruktury-w-sprawie-
wysokosci-oplat-zwiazanych-z-
prowadzeniem-stacji-kontroli-
pojazdow-oraz-
przeprowadzaniem-badan-
technicznych-pojazdow.html
https://isap.sejm.gov.pl/isap.nsf/D
ocDetails.xsp?id=WDU20042232
261
271
MEMBER
STATE
PTI PRICE LIGHT VEHICLES PTI PRICE HEAVY
VEHICLES
REFERENCES
Portugal Light-duty vehicles: 27.80 €
Mopeds: 14.00 €
Heavy-duty vehicles: 41,60 € Realizar as Inspeções Periódicas a
Veículos - ePortugal.gov.pt
Romania ITP fee Taxi or Driving School = 80 lei (approx.
16,09 €)
ITP fee Petrol or petrol + LPG cars = 120 lei
(approx. 24,14 €)
ITP fee Diesel cars = 150 lei (approx. 30,18 €)
ITP fee Motorcycles = 120 lei (approx. 24,14 €)
ITP fee Mopeds = 120 lei (approx. 24,14 €)
ITP fee Minibuses,
motorhomes, vans, mixed,
specialised = 150 lei (approx.
30,18 €)
ITP fee Vehicles with 4x4 all-
wheel drive = 150 lei (approx.
30,18 €)
PTI tariffs - periodic technical
inspection (itp-automoto.ro)
Slovakia PTI prices vary greatly between the eastern and
western areas. As an example, in Bratislava PTI
price for passenger cars, vans, tricycles and
quads is 45 € including VAT.
In Bratislava, the PTI price for
M2 and M3 vehicles is 70 €
https://www.dekra.sk/en/pti-
bratislava-petrzalka/
Slovenia Passenger car (weight up to 2.5 T): 36,74 €
Passenger car (weight over 2.5 T): 46,28 €
Motorcycle and quadricycle (L1 to L7) and
Moped wheel (L1 to L5): 19,09 €
Bus (M2): 84,45 €
Coach articulated (M3) and
truck and towing vehicles (N3):
96,86 €
Roadworthiness tests | AMZS
Spain 30,39€ (40,95€ with VAT) 49,73€ (64,35€ with VAT) ITVASA - Tarifas de vehículos
Sweden 64 EUR Average price across vehicle types
– CITA survey
Source: VVA (2023), Evaluation support study and own elaboration
272
ANNEX 7: DETAILED DESCRIPTION OF THE RETAINED POLICY
MEASURES
1. COMMON MEASURES INCLUDED IN THE POLICY OPTIONS
PMC1 – Adapt PTI to electric and hybrid vehicles (safety, environmental
performance, standardised data), including training of inspectors
Concerns: Directive 2014/45/EU (PTI)
The measure will introduce new items to be tested as part of PTI concerning vehicles
equipped with high-voltage systems, such as battery electric and hybrid vehicles. The
following groups of items could be included in Annex I of Directive 2014/45/EU in the
section referring to electrical equipment:
• Visual inspection of the traction battery cover and the batteries;
• Visual inspection and/or operation of the high voltage wiring harness and
connectors, including the charging cable;
• Visual inspection and operation of high voltage electrical and electronic
equipment;
• Anti-starting system: functional check by verifying that the vehicle cannot move
by itself with the charging cable plugged.
As in the case of all other test items, deficiencies would be categorised as minor, major or
dangerous, depending on the reason for failure, such as slightly/heavily deteriorated or
defective items.
PMC2 – Update PTI and RSI due to new requirements in General Safety Regulation
and checking emission reduction systems (new test items, including checks of
software status/integrity), by reading on-board diagnostics
Concerns: Directive 2014/45/EU (PTI) and Directive 2014/47/EU (RSI)
This measure will introduce new items to be tested as part of PTI and RSI using the on-
board diagnostic (OBD) scanners connected to the electronic vehicle interface (OBD port).
Since May 2023, testing centres are required to be equipped with such scan tools, however,
their use has been limited so far. The current PTI and RSI Directives do not require the
actual use of OBD scanners but refer to them as an alternative to visual inspection (of
warning devices) for the checking of certain safety systems, such as anti-lock braking
system (ABS), electronic brake system (EBS), Electronic Power Steering (EPS), the
functioning of safety belts and airbag systems and the Electronic Stability Control (ESC).
Thanks to recently developed standards448
, it is now also possible to query ePTI-relevant
system information, including software identification, software integrity, current and/or
448
ISO 20730-1:2021 and 20730-3:2021, https://www.iso.org/standard/73801.html
273
stored values, and to electronically test the safety systems required by the General Safety
Regulation, such as: automated lane keeping system (ALKS), automated braking,
intelligent speed assistance, reversing detection with camera or sensors, acoustic vehicle
alerting to prevent collisions with pedestrians or cyclists, emergency braking signal, or tyre
pressure monitoring systems.
Using ePTI will also allow checking additional safety-relevant items, like automatic
lighting, adaptative headlights, speed limiter and adaptative cruise control.
PMC3 - Mandatory PN testing of LDVs and HDVs equipped with particle filter, at
PTI, and of HDVs at technical roadside inspections of commercial vehicles
Concerns: Directive 2014/45/EU (PTI) and Directive 2014/47/EU (RSI)
The measure will require using particle number (PN) measurement for the exhaust gas
emission testing (item 8.2 in the list of items to be tested under the PTI and RSI Directive).
This would replace the currently required exhaust gas opacity test first for diesel vehicles
equipped with particle filters, at PTI, and for HDVs, at technical roadside inspections of
commercial vehicles. The focus is on these vehicles as they are subject to a solid particle
number limit at their type-approval (from Euro 5b LDVs and Euro VI HDVs), which is
used as a reference point to determine the threshold for high-emitting vehicles. In fact,
three Member States (BE, NL and DE) have already introduced such a test for Euro 5 and
Euro 6/VI vehicles and the measure is about applying harmonised measurement across the
EU. In the case of pre-Euro 5 and Euro VI vehicles equipped with DPF, Member States
would be required to indicate the result of emissions higher than the limit on the
roadworthiness certificate to draw the attention of the owner that the filter needs to be
replaced. Alternatively, e.g., where the vehicle tax is differentiated based on the presence
or not of a particle filter, Member States may allow to de-register the filter and apply higher
vehicle taxes to such vehicles.
The test requirements will be based on the procedure described in the Commission’s
Recommendation on PN measurement for the PTI of vehicles equipped with compression
ignition engines449
, which allow for a fast, simple and inexpensive test. The use of the
currently recommended pass/fail limit of 250.000/cm3
would be required.
Initially, older vehicles not equipped with DPF would continue to be checked using the
currently required opacity testing, which was adapted to the air pollutant emission limits
of earlier standards (pre-Euro 5). The Commission would have to consult the
Roadworthiness Expert Group (RWEG) to investigate the technical feasibility of using PN
measurement for those vehicles with higher thresholds, while ensuring that this does not
generate disproportionate costs, notably through the need to replace existing equipment.
Since the equipment used for PN-measurement are portable devices, the same test method
can be applied at roadside inspections, including for checks following the identification of
a high-emitting vehicle using remote sensing technology (required by PM13).
449
https://eur-lex.europa.eu/eli/reco/2023/688/oj
274
Later, once the corresponding test method is developed for testing vehicles equipped with
positive ignition engines, PN measurement should also be extended to them. As soon as
sufficient data from tailpipe emission testing at PTI and readings from the on-board
monitoring system (OBM) of Euro 7 vehicles provide confidence as regards the
equivalence of OBM with tailpipe tests, Member States may authorise the use of OBM
only.
PMC4 - Mandatory NOx-testing of LDV and HDV at PTI, and HDVs at roadside
inspections
Concerns: Directive 2014/45/EU (PTI) and Directive 2014/47/EU (RSI)
Similar to PN testing under PMC3, this measure will require the testing of NOx emissions
at PTI and RSI for light and heavy vehicles, first for diesel, focussing on the identification
of malfunctioning SCR systems. Later, once the test method is adapted to positive ignition
engines, also vehicles powered by petrol and liquefied or compressed natural gas
(LNG/CNG) could be tested. The test procedure has been developed by the Commission’s
Joint Research Centre450
with the technical and metrological requirements of the
instruments and a NOx threshold value expected to be defined by the end of 2023. The
measure would therefore likely be implemented through a delegated act amending point
8.2 in the list of items to be tested under the PTI and RSI Directives.
The test procedure is being set up in a way that it aligns with the procedure applied for PN
testing, in order to allow for simultaneous PN and NOx testing, which in the future could
also be performed using one single instrument featuring both particle and NOx analysers.
This will allow keeping the testing time as it is today and limit the additional equipment
costs.
As in the case of PN testing, as soon as sufficient data from tailpipe emission testing at PTI
and readings from the on-board monitoring system (OBM) of Euro 7 vehicles provide
confidence as regards the equivalence of OBM reading with tailpipe tests, Member States
may authorise the use of OBM only.
PMC5 - Mandatory roadworthiness testing following significant modifications of the
vehicle (e.g. change of class, propulsion system)
Concerns: Directive 2014/45/EU (PTI)
This measure will require vehicles that have undergone major technical modifications to
pass a roadworthiness test. Such modifications may include changes to the propulsion
system, retrofitting the emission control system, modifications to the chassis, wheels and
tyres and/or the engine performance of the vehicle and may thus have both safety- and
emissions-related impacts.
PMC6 – Require the roadworthiness certificate in electronic format only
450
https://www.mdpi.com/1996-1073/16/14/5520
275
Concerns: Directive 2014/45/EU (PTI)
While the current PTI Directive allows the use of “electronically produced”
roadworthiness certificates, it requires a certified printout to be handed to the person
presenting the vehicle for PTI. The measure will limit the requirement to issuing an
electronic document only, while providing a printout will be left as an option for Member
States.
The exchange of PTI-related data under PMC7 will allow enforcing authorities to check
the status of any vehicle registered in the EU in the case of a roadside check or for the
purpose of re-registration, without the need for the owner of the vehicle to present a printed
certificate.
PMC7 – Provide electronic access to relevant data, including on PTI reports stored
in national databases, to the registration authorities of other EU Member States using
a common interface
Concerns: Directive 2014/46/EU (VRD)
The current VRD Directive requires that Member States assist each other in the
implementation of the Directive and indicates that this may be done by exchanging vehicle-
related information by electronic means. However, it does not specify the means and does
not actually require such data exchange. This measure will require that Member States
provide access to other Member States requesting registration or PTI-related vehicle data
for the vehicles registered in their territory. Such exchanges already take place on bilateral
basis using EUCARIS451
, albeit this is not systematically the case for every Member State.
In order to facilitate the data exchange, the measure would require Member States to
connect their national databases (vehicle registers and related PTI databases as the case
may be) to the MOVE-HUB platform developed and run by the Commission for the
purpose of exchanging various road transport-related information among Member States.
The EUCARIS peer-to-peer network and the Commission’s hub-and-spoke network are
the connectivity layer to send messages from one Member State to another – there is no
significant difference in the development effort between the two. When implementing a
new message type, Member States have two options, they can develop their own software,
or they can use the EUCARIS module for that message type. This choice is independent
of the routing of the messages via the hub.
The methodology of the EUCARIS software sending messages via MOVE-HUB is well
known and already implemented for in similar road transport related applications like
ERRU, RSI, ProDriveNet and TACHOnet; for these solutions it is specified in the
corresponding legislation that messages must be routed via the hub. RESPER and the
ODOCAR pilot use a hybrid solution, routing messages both on the EUCARIS peer-to-
peer network and via the hub.
451
https://www.eucaris.net/
276
The Proposal for the ELV Regulation referred to in section 1 would also require that
messages between national (registration) authorities and customs are routed via MOVE-
HUB for the purpose of determining whether or not a vehicle is eligible for export, i.e.,,
roadworthy is based on the information from the Member State where it was last registered.
The use of MOVE-HUB for message routing over EUCARIS is based on the following
considerations:
• The Commission has the competence to enforce the application of EU legislation;
• MOVE-HUB can monitor the exchange for compliance with the legislation;
• The Commission can follow-up message exchange errors with Member States.
In both cases, there is no need to develop additional software to gather messaging statistics.
In addition, the fact that the hub is a single point of failure (a possible disadvantage over a
peer-to-peer network), is mitigated by relying on the Commission’s highly redundant
network layer and by having redundant servers in the application layer.
PMC8 – Harmonisation and regular update of the technical data in the vehicle
registration documents (of currently optional content)
Concerns: Directive 2014/46/EU (VRD)
Apart from a set of mandatory data elements to be included in vehicle registration
documents, the VRD Directive also provides for a series of optional elements that Member
States include or not according to their needs and preferences, taking into account the
limited space on the currently required physical registration certificate. Optional data items
include e.g. the vehicle category, the number of axles, data about the environmental
performance of the vehicle, etc. For example, item V.7 of the registration certificates refers
to CO2 emissions (in g/km for light vehicles), but it does not specify whether this should
be the emissions measures in accordance with the NEDC or the more recent WLTP testing
procedures452
.
The measure aims at harmonising the set of data included in vehicle registration documents
and provides for their update in case relevant vehicle characteristics change due to
modifications (e.g., to the engine, the chassis, or the emission control system). This
requires the harmonisation of those data items in national vehicle registers and their update
as soon as they are modified.
As indicated in the evaluation, there is also a need to align certain data elements with the
data elements record in the certificate of conformity.
PMC9 – MSs to record odometer readings in a national database and make the
records available to other MSs in the case of re-registration
Concerns: Directive 2014/45/EU (PTI) and Directive 2014/46/EU (VRD)
452
Both developed by the UNECE: https://unece.org/press/unece-adopts-more-accurate-fuel-efficiency-and-
co2-test-new-cars-wltp; see also https://www.wltpfacts.eu/
277
For the purpose of reducing odometer fraud, the PTI Directive requires the recording of
vehicle mileage at each PTI and that its manipulation be a punishable offence. However,
PTIs are only conducted every year at most (in many Member States only every two years),
with the first PTI taking place only after four years in most cases. A significant part of
odometer fraud will already have happened by that time since larger price gains can be
achieved by rolling back the odometers of relatively new vehicles.
This measure would replicate the national systems established by Belgium (Car-Pass453
)
and the Netherlands (Nationale Auto Pas, NAP)454
across all Member States. Both systems
collect odometer readings from vehicles in between PTIs and well before the first PTI and
exchange odometer history data between the national databases. The readings are provided
by various vehicle repair workshops, including tyre and windscreen repair services as well
as by manufacturers though their dealer management systems. In Belgium, manufacturers
provide odometer readings from connected cars at least four times a year. In comparison
to the Belgian Car-Pass system, PMC9 does not require the issuing of a certificate as part
of a vehicle transaction455
. In the Dutch NAP system, the delivery of the vehicle report is
free of charge.
The measure requires that Member States establish such national databases and feed them
with odometer readings in a similar way. Since the issue is of particular concern in the case
of cars and vans, those vehicles would have to be covered as a minimum. Where the
registration of a vehicle is moved to another Member States, the Member State of
registration would have to share the mileage history of that car or van with the re-
registering Member States.
Figure 10: Overview of the Car-Pass system
453
https://www.car-pass.be/en/about-car-pass
454
https://www.rdw.nl/en/buying-a-car/tips-for-buying-a-car
455
This currently costs around EUR 10 in Belgium and provides the main source of revenue to support the
operation of the system in the country.
278
2. POLICY MEASURES INCLUDED ONLY IN SOME OF THE POLICY OPTIONS
PM1 - RSI for heavy/powerful motorcycles (L category > 125cm3) as alternative
measure, in Member States where they are not subject to PTI (i.e., using the available
opt-out)
Concerns: Directive 2014/45/EU (PTI) and Directive 2014/47/EU (RSI)
The measure would apply to L-category vehicles with an engine displacement exceeding
125cm3, i.e., vehicles that are currently in the scope of the PTI Directive with a possibility
for Member States to apply alternative road safety measures instead of PTI. As such, it
would only affect the Member States that make use of the opt-out456
by requiring that the
alterative measure be roadside inspection for these vehicles. The share of the vehicle
subject to RSI every year is must be 5% of the corresponding fleet in the Member States
concerned.
PM2 – Mandatory PTI for motorcycles above 125cm3 (remove opt-out)
Concerns: Directive 2014/45/EU (PTI)
This measure would simply remove the existing possibility to apply alternative road safety
measures instead of making heavy motorcycles subject to PTI. Just like the previous
measures, this would affect a few Member States. It would however leave the choice of
the frequency of testing to Member States, as it is the case today.
PM3 – Extend PTI to all motorcycles (i.e., incl. from 50cm3 = all L3e, L4e), plus
tricycles (L5e) and heavy quadricycles (L7e)
Concerns: Directive 2014/45/EU (PTI)
This measure would extend the scope of the PTI Directive to all motorcycles, i.e., including
smaller ones from 50cm3 (all L3e, L4e), plus tricycles (L5e) and heavy quadricycles (L7e).
It would however leave the choice of the frequency of testing to Member States, as it is the
case today for heavy motorcycles.
PM4 – Mandatory PTI for light trailers (O1 and O2 categories)
Concerns: Directive 2014/45/EU (PTI)
This measure would extend the scope of the PTI Directive to all light trailers, including
O1 (with maximum mass not exceeding 750 kg) and O2 categories (maximum mass
exceeding 750 kg but not exceeding 3500 kg). It would however leave the choice of the
frequency of testing to Member States, as it is the case today for heavy motorcycles.
456
These Member States are BE (only requires a roadworthiness test before selling the vehicle or after an
accident), FI, IE, MT, NL, PT (only testing vehicles with engines > 250 cm3
). France has not introduced PTI
for motorcycles up to now, but the French authorities have announced the intention to do so in 2024. Denmark
does not have mandatory PTI but since 1 January 2022 it has introduced roadside inspections.
279
PM5 – Annual emission testing for light commercial vehicles (N1) instead of the
currently required 4-2-2- frequency
Concerns: Directive 2014/45/EU (PTI)
The measure will increase the minimum frequency of emission testing for vans and require
annual testing from the first year following the date of first registration of the vehicle.
While a few Member States apply more frequent PTI to vans that the minimum frequency
required by the PTI Directive (i.e., first test within 4 years of the date of first registration
and every 2 years thereafter), most Member States apply the minimum requirements.
As such, it will increase the number of vehicles to be tested per year, however, vehicles
that are subject only to emission testing would not have to occupy the capacity of PTI lanes
as such tests can be carried out using the portable measurement devices.
PM6 – Mandatory yearly testing for vehicles that are 10-year-old or older
Concerns: Directive 2014/45/EU (PTI)
The measure will increase the frequency of roadworthiness testing for cars and vans (M1
and N1 vehicles) and require annual PTI after 10 years following the date of first
registration of the vehicle. As indicated in Annex 6, a number of Member States457
already
apply yearly PTI to cars and vans beyond a certain age instead of the minimum frequency
of 2 years following the first PTI required by the PTI Directive. The other 11 MS apply
the minimum requirements.
PM7 – PTI certificate issued in any EU MS is recognised by the MS of registration +
further harmonisation of test methods
Concerns: Directive 2014/45/EU (PTI)
Under the current PTI rules, for the purposes of free circulation and of re-registering a
vehicle that has already been registered in another Member State, the PTI certificate issued
in that other Member State must be recognised by each Member State as if it had itself
issued that certificate, provided that the PTI certificate is still valid in terms of the
frequency intervals established for PTI by the re-registering Member State.
However, such recognition is not required for the purpose of complying with periodic
testing requirements. In fact, the PTI Directive requires that PTI is carried out by the
Member State of registration or by bodies or establishments designated and supervised by
that Member State.
The measure would require that the Member State of registration recognises PTI
certificates issued in the EU for the purpose of ensuring compliance with periodic testing
of vehicles, provided that the PTI certificate is still valid in terms of the frequency intervals
that Member State has established for PTI. In order for such a measure to be agreeable by
Member States, it is necessary to further harmonise the methods of testing (i.e. certain
457
AT, BE, BG, EE, ES, FI, HR, IE, LV, LU, NL, PL, PT, RO, SE and SI.
280
items that Member States may currently test in different ways). Examples are brake testing
for HDVs or efficiency testing of the suspension system. The measure would set specific
requirements for these items.
The reason why PTI certificate recognition is currently limited to allowing free circulation
and re-registration (and it is not allowed to undergo PTI in a Member State other than the
Member State of registration) is that the stringency of PTIs does differ among Member
States while testing a relatively stable number of vehicles per year also ensures planning
certainty for Member States, which is particularly relevant where the PTI service is subject
to longer term contracts (concessions). Full recognition could lead to PTI shopping, unless
there is almost full harmonisation of the test methods, which is considered in PM7. PM7
is only part of the most ambitious option as such level of harmonisation may affect the
structural organisation of PTI in certain Member States, e.g., advanced suspension testing
requires more space that may be available in small commercial garages that are responsible
for conducting PTIs in a number of cases. On the other hand, the recognition of PTIs via
bilateral agreements (PM9) could be a first step towards further harmonisation and
enhanced free movement.
PM8 – PTI certificate issued in any EU Member State to be recognised by the MS of
registration for a period of up to 6 months (for passenger cars only), on the condition
that the next PTI is conducted in the MS of registration
Concerns: Directive 2014/45/EU (PTI)
To further facilitate free movement and not to oblige citizens spending time in a Member
State other than the Member State of registration of the vehicle they are using to travel
abroad, PM8 would require the Member State of registration to recognise the PTI
certificate issued in another Member State where the vehicle could undergo PTI when it is
due. The validity of this certificate could be up to six months.
The measure applies to passenger cars, on condition that the next PTI is conducted in the
Member State of registration. It would complement the provision of the PTI Directive
requiring that PTI is carried out by the Member State of registration or by bodies or
establishments designated and supervised by that Member State.
PM9 – PTI in another EU MS recognised by MS of registration based on bilateral
agreement
Concerns: Directive 2014/45/EU (PTI)
PM9 would explicitly allow establishing bilateral agreements between Member States in
order to recognise each other’s PTI certificates. This measure would leave the choice of
concluding such agreements and thus recognising PTI certificates issued in other Member
States. Member States would have the freedom to apply such agreements to any vehicle
category. The measure would complement the provision of the PTI Directive requiring that
PTI is carried out by the Member State of registration or by bodies or establishments
designated and supervised by that Member State.
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PM10 – More advanced testing of noise for motorcycles
Concerns: Directive 2014/45/EU (PTI)
The current PTI Directive requires subjective evaluation of the noise suppression system,
“unless the inspector considers that the noise level may be borderline, in which case a
measurement of noise emitted by stationary vehicle using a sound level meter may be
conducted” (point 8.1 of Annex I). The same requirement is included in Annex II of the
RSI Directive applicable to HDVs, which also indicates that the item “can only be checked
to some extent without the use of equipment”.
The measure would require the use of noise measuring equipment when the inspector
considers that the noise level may be borderline. Such measurement could be inspired by
the methods described in UN Regulation 41 for pass-by noise tests458
, even though not all
the conditions of such a test applied in the case of type-approval may be fulfilled at PTI
centres (for example, there may not be sufficient space and whether conditions will not
always be favourable to fully comply with Regulation 41). Therefore, a simplified test
should be carried out. Few MSs (DE, ES, HR and SK) are already measuring L-vehicles
noise emissions at PTI.
PM11 – Data governance: further define the procedures and the means of access to
vehicle technical information by testing centres free of charge
Concerns: Directive 2014/45/EU (PTI)
Recital 17 of the PTI Directive explains the rationale behind this measure: “For the
inspection of vehicles, and especially for their electronic safety components, it is crucial
to have access to the technical specifications of each individual vehicle. Consequently,
vehicle manufacturers should provide the data needed for verification of the functionality
of safety and environment-related components. The provisions concerning access to repair
and maintenance information should likewise be applied for that purpose, allowing
inspection centres to have access to all information necessary for roadworthiness testing.
The data should include the details that allow the functionality of the vehicle safety systems
to be monitored in a way that allows such systems to be tested in a periodic technical
inspection environment. This is of crucial importance, especially in the field of
electronically controlled systems, and should cover all elements that have been installed
by the manufacturer.”
Accordingly, Article 4(3) required the Commission to adopt implementing acts to define a
set of technical information necessary for roadworthiness testing and for the use of the
recommended test methods, and detailed rules concerning the data format and the
procedures for accessing the relevant technical information. It also requires that
manufacturers make the technical information available to testing centres and competent
authorities “free of charge or at a reasonable price” and in a non-discriminatory manner.
458
Regulation No 41 of the Economic Commission for Europe of the United Nations (UN/ECE) — Uniform
provisions concerning the approval of motor cycles with regard to noise (OJ L 317 14.11.2012, p. 1, ELI:
http://data.europa.eu/eli/reg/2012/41/oj)
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In addition, it requires that the Commission examines the feasibility of establishing a single
point of access for that technical information.
As a result, Implementing Regulation 2019/621459
defines a basic set of technical
information and lays down the principles of the procedure for accessing such data and
regarding their format, however, it fails to specify them in sufficient detail, leaving a large
room for manoeuvre to manufacturers to define their own procedures and data formats.
These issues, specifically regarding in-vehicle data is being addressed by the ongoing
initiative on access to vehicle data, functions and resources460
. The proposal on access to
in-vehicle data should provide for non-discriminatory access to such data in a harmonised,
machine-readable format, which will be key for vehicle inspection. However, it is unlikely
that it will specify the means of data access specifically for the purpose of vehicle
inspection, which is the focus of this measure.
The specific requirements would be laid down in an implementing act amending
Implementing Regulation 2019/621 and would aim at establishing a single point of access
for the necessary technical information, e.g., through an independent body that would
collect the vehicle data from manufacturers and distribute it to competent authorities and
authorised PTI centres. Such a solution has notably been called for by CITA.
PM12 – NOx, PM, and noise measurement by remote sensing in RSI of all vehicles
(with option for simplified PTI if vehicle passed recent RSI)
Concerns: Directive 2014/47/EU (RSI)
PM12 requires the use of remote sensing technology for measuring NOx, PM, and noise
emissions of all vehicle types and all emission classes. This will allow the monitoring of
the emissions of a very significant part of the vehicle fleet, depending on the exact scale
of implementation in the Member States. It also includes the option for a simplified PTI if
a vehicle successfully passed a recent RSI (including by remote sensing). That is, the
Member State of registration may exempt the vehicle from the emission and/or noise
testing during the next PTI if the result of the RSI is less than 6 months old. A successful
RSI result could include not only if the vehicle is stopped and checked at the roadside but
also if it has passed a (specified number of) emission screening by remote sensing with the
results consistently showing low emissions.
The use of stationary remote sensing units may be replaced or complemented by plume
chasing, which can be a viable alternative, notably to measure NOx emissions from HDVs.
The figures below illustrate available technologies that could be used to fulfil the
requirements of PM12 as regards pollutant emissions. Monitoring noise by remote sensing
459
Commission Implementing Regulation (EU) 2019/621 of 17 April 2019 on the technical information
necessary for roadworthiness testing of the items to be tested, on the use of the recommended test methods,
and establishing detailed rules concerning the data format and the procedures for accessing the relevant
technical information, https://eur-lex.europa.eu/eli/reg_impl/2019/621/oj
460
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-
functions-and-resources_en
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allows identifying individual noisy vehicles even in dense traffic, as demonstrated by the
NEMO project461
, allowing local and national authorities to take remedial action.
The introduction of this measure will require remote sensing equipment (for NOx and PM)
and acoustic cameras (a range of microphones for noise) by national enforcing authorities.
Figure 11: Remote sensing solutions
Figure 12: Plume chasing
Source: MODALES and CARES projects, https://modales-project.eu/wp-
content/uploads/2021/10/ITSWC2021-Beyond-Eco-driving-2-CARES_HERE.pdf
PM13 – Mandatory inspection of cargo securing
Concerns: Directive 2014/47/EU (RSI)
The current RSI Directive provides for the standards applicable to cargo securing
inspections, however the inspection of cargo securing itself remains optional. As such,
Member States have only partially implemented the use of those standards. The measure
requires Member States to apply the methods described in Annex III of the Directive and
the inspectors conducting such inspections to undergo appropriate training.
461
https://nemo-cities.eu/remote-sensing-device-for-noise/
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Following the adoption of the RSI Directive in 2014, the Commission presented guidelines
for Member States and practitioners on the best practices in cargo securing462
referring to
various types of cargo. The first principle provided for in Annex III of the RSI Directive
is illustrated the figure below.
Figure 13: Forces resulting from acceleration and deceleration that cargo securing must withstand
Source: Cargo securing for road transport – 2014 European best practices guidelines
PM14 – Extend the scope of application of roadside inspections to light commercial
(N1) vehicles
Concerns: Directive 2014/47/EU (RSI)
PM14 requires that Member States apply technical roadside inspection to vans, i.e.,
commercial vehicles with a maximum permissible laden mass not exceeding 3.5 tonnes.
Since the number of these vehicles in the EU fleet is about four times the number of HGVs,
a lower target would be applied to them, e.g., 2% instead of the 5% share that Member
States are supposed to aim for in the case of RSI for HDVs.
462
European Commission (2014), Cargo securing for road transport – 2014 European best practices
guidelines, Publications Office, https://data.europa.eu/doi/10.2832/80373
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For testing vans at RSI, largely the same inspection units could be used as for HDVs. RSI
for vans could be particularly useful to detect vehicles with defective emission control
systems, including tampered ones, which may relatively easily avoid being caught at PTI.
The mere fact that a van may be subject to roadside checks is expected to play a deterrent
role.
PM15 – Extend the scope of application of roadside inspections to 2- and 3-wheeled
vehicles (L-vehicles from L3)
Concerns: Directive 2014/47/EU (RSI)
This measure requires that Member States apply technical roadside inspection to
motorcycles. Taking into account the number of these vehicles in the EU fleet a target of
1% would be applied.
RSI for motorcycles could be particularly useful to detect vehicles with defective and
tampered noise suppression systems, which may very easily avoid being caught at PTI.
Here again, the fact that motorcycles may be subject to roadside checks is expected to play
a deterrent role.
PM16 – Introduce issuing the registration certificates in digital format to gradually
replace current paper (and smart card) documents
Concerns: Directive 2014/46/EU (VRD)
The VRD Directive currently requires that registration certificates be issued either as a
paper document or as a smart card. The measure will introduce the requirement to issue
new registration certificates in a digital format. The technical details of the digital/mobile
registration certificate will be defined in an implementing act and refer to the relevant ISO
standards as in the case of the digital driving licence. Just like the mobile driving licence,
the digital registration certificate will rely on the eIDAS initiative whose legislative
proposal463
is still discussed by the co-legislators and certain technical features are not yet
consolidated in detail.
The measure applies to all vehicle categories that are subject to registration in the Member
States. For the purposes of identifying vehicles in road traffic as well as for re-registration,
Member States will have to recognise the digital version of the registration certificate. As
the physical documents, the digital vehicle registration certificate would be used to confirm
the registration of the vehicle, to check certain technical data about it (the digital version
could store more data than the paper version), and to allow verification by the authorities.
With the digital certificate enforcers can have direct access to the vehicle register, and it is
also significantly easier to update than the physical documents.
The figures below illustrate the processes involved in issuing, using, and updating the
digital certificate, and its possible appearance.
463
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021PC0281
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Figure 14: Issuing the digital registration certificate
Figure 15: Layout of a digital registration certificate
Source: Presentation by the Federal Ministry for Digital and Transport, Germany, at the meeting of the
Expert Group on Roadworthiness and Vehicle Registration Documents, September 2022
PM17 – Add new data to the vehicle register – minimum mandatory set (including
among others: country of 1st registration, registration status, PTI status, changes due
to transformation)
Concerns: Directive 2014/46/EU (VRD)
This measure will provide for a minimum set of mandatory data to be registered by member
States. New data elements could include among others:
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• Country where the vehicle was registered for the first time;
• Vehicle status (e.g. de-registered, temporarily de-registered, suspended, exported,
end-of-life, destructed) (see below)
• PTI status (passed with no or minor defects, limited validity with major defects,
failed – critical defects) and
i. validity of the roadworthiness certificate (including expiry date),
ii. status of the battery (for EVs): battery identification number; and
information if the battery has been repaired or replaced;
• Changes in documentation or transformation – any important vehicle refurbishment
to be approved and registered (process not yet harmonised);
• For a vehicle which is permanently de-registered, information on the reasons for
de-registration, based on the assessment accompanying the proposal for the
revision of the legislation on end-of-life vehicles.
i.
Based on what most Member States already record, a longer list of data items to be
recorded has been proposed by EReg464
.
464
https://www.ereg-association.eu/media/2742/final-report-topic-group-xxi-proposal-on-the-registration-
of-vehicle-data.pdf
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ANNEX 8: DISCARDED POLICY MEASURES
The possibility to adopt further recommendations or a communication from the Commission was
discarded at early stage as non-regulatory measures could not be sufficiently effective in addressing
the problems identified and would have limited effect on harmonisation. Most stakeholders, including
public authorities participating in the open public consultation, agreed that a legislative review of the
RWP would be more effective (see also Annex 2).
Out of the more than 40 policy measures discussed at five meetings with the Expert Group on
Roadworthiness and vehicle registration documents (RWEG), the following measures are among the
discarded ones:
• Extending the scope of the PTI Directive to mopeds (vehicle category L1 and L2) was discarded
due to subsidiarity and proportionality reasons. While making mopeds subject to PTI could have
significant positive impact on road safety and air pollutants reduction, these vehicles are used
locally, and the cost-benefit ratio could vary significantly depending on the specific local context
(including the electrification of the fleet465
, which will significantly reduce the negative impacts
of these vehicles on air and noise pollution over time). There would be also technical feasibility
issues with such measure since some Member States do not require registration of mopeds.
Therefore, from a subsidiarity and proportionality point of view, the testing of mopeds would best
be left for Member States to legislate.
• Extending the scope of the PTI Directive to agricultural tractors (category T with design speed
exceeding 40km/h) was discarded as there was not sufficient evidence of the road safety and
environmental/health risk posed by these vehicles, due to their limited use of public roads.
• Setting maximum mileage limit between two PTIs (e.g., 100,000 km/200,000 km) was
discarded as there are practical difficulties in monitoring mileage and calling vehicles for tests. It
could also create additional incentives for odometer tampering.
• Requiring a roadworthiness test following a crash with significant damage (affecting the main
safety components) was not retained on the grounds of the difficulty to find a commonly agreed
definition for significant damage (legal feasibility).
• New test methods - continuous technical inspection (CTI) (for autonomous vehicles) was not
retained as it was considered by the experts of the RWEG to be premature to define such methods
at this stage of autonomous mobility development.
The table below provides the full list of discarded policy measures (13) and the reason for discarding
them.
Table 268: Discarded policy measures and the reason for discarding them
Measure Reason for being discarded
Extend scope of RWP to mopeds (i.e.L1e-B and
L2e)
There are technical feasibility issues with such measure since some
Member States do not require registration of mopeds. Moreover,
these vehicles are used locally, and the cost-benefit ratio could vary
465
For example, in the Netherlands, the share of electric mopeds in the sales of mopeds increased from 3% in 2017 to
46% in 2022. The share in the EU was 34% in 2022.
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Measure Reason for being discarded
significantly depending on the specific local context (including the
electrification of the fleet, which will significantly reduce the
negative impacts of these vehicles on air pollution over time). Due
to subsidiarity and proportionality point of view, this measure was
discarded.
Extending the scope of the PTI Directive to
agricultural tractors (category T with design
speed exceeding 40km/h)
There was not sufficient evidence of the road safety and
environmental/health risk posed by these vehicles due to their
limited use of public roads.
Setting maximum mileage limit between two
PTIs (maximum limit to be determined e.g.
100,000 km/200,000 km)
There are practical difficulties in monitoring mileage and calling
vehicles for tests. It could also create additional incentives for
odometer tampering. The measure was discarded due to technical
feasibility reasons.
To make PTI mandatory before transfer of
ownership of a vehicle
The PTI Directive requires that the roadworthiness certificate be
recognised, as a matter of principle, “in the event that the
ownership of the vehicle – having a valid proof of roadworthiness
test – changes”. There are also practical questions as regards the
implementation of such a measure (length of validity of a new
certificate required before sales). Limited support among Member
States. Discarded due to unnecessary burden on vehicle owners and
lack of evidence regarding potential benefits.
PTIs mandatory for crashed vehicles with
significant damage (affecting the main safety
components)
Difficulties in defining significant damage in a consistent way and
limited support among stakeholders during the consultations.
Discarded due to legal and political feasibility reasons.
To require that PTI certificate issued in a third
country outside the EU is recognised by MS of
registration
No support among Member States authorities during the
consultations. Difficulties to monitor/ensure quality of PTI in third
countries. Discarded due to technical and political feasibility
reasons.
To require that results of on-board fuel
consumption monitoring (OBFCM required by
Regulation 2021/392) are reported on the PTI
certificate
Measure considered not directly relevant for the RWP.
Nevertheless, Member States are not prevented from reporting that
information on the PTI certificate.
Require more advanced testing of braking
(regenerative braking)
Limited support and considered as not relevant from the vehicle
roadworthiness perspective (rather a question of energy efficiency)
New test methods - continuous technical
inspection (CTI) (for autonomous vehicles)
Considered by the experts of the RWEG to be premature to define
such methods at this stage of autonomous mobility development
(technical feasibility reasons).
Extend the scope of application of roadside
inspections to motorhomes
Very limited expected impact and very limited support among
Member States authorities.
Improve administrative processes regarding
handling prohibitions/suspensions after roadside
inspection and self-cancelling prohibitions
following subsequent PTI
Limited support among experts as not considered to be a key issue
and there was not sufficient evidence about the extent of the
problem the measure would address.
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Measure Reason for being discarded
New data items necessary for the treatment of
end-of-life vehicles (ELV)
Considered outside the scope of this initiative since already
covered by the impact assessment prepared for the revision of the
legislation on ELV (but aiming at amending the Directive on
vehicle registration documents).
Improve administrative processes by requiring
that re-registration of vehicles in another MS is
conducted online (on the basis of the presence of
appropriate IT system)
Considered as going beyond what is necessary to address the
problem and is considered to be already sufficiently covered by the
SDG Regulation.
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ANNEX 9: COMPARISON OF POLICY OPTIONS IN TERMS OF MEETING THE OBJECTIVES
Strongly negative Negative No or limited impact Positive Strongly positive Unclear
Impact PO1a PO1b PO2 PO3
General objective 1: Improve road safety in the EU
% reduction in the level of
fatalities and injuries and
associated external costs
Expected reduction of fatalities by 4,661,
severe injuries by 42,272 and slight injuries
by 239,803 (cumulative over 2026-2050,
relative to the baseline).
Estimated external cost savings of EUR
48.1 billion, expressed as present value
over 2026-2050 relative to the baseline.
(++)
Expected reduction of fatalities by 6,847,
severe injuries by 64,640 and slight
injuries by 364,155 (cumulative over
2026-2050, relative to the baseline).
Estimated external cost savings of EUR
73.9 billion, expressed as present value
over 2026-2050 relative to the baseline.
(+++)
Expected reduction of fatalities by
6,912, severe injuries by 64,885 and
slight injuries by 365,665 (cumulative
over 2026-2050, relative to the
baseline).
Estimated external cost savings of
EUR 74.2 billion, expressed as present
value over 2026-2050 relative to the
baseline.
(+++)
Expected reduction of fatalities by 7,013, severe
injuries by 65,686 and slight injuries by 368,498
(cumulative over 2026-2050, relative to the
baseline).
Estimated external cost savings of EUR 75.2
billion, expressed as present value over 2026-
2050 relative to the baseline.
(+++)
General objective 2: Contribute to sustainable mobility
% reduction in the level of
pollutant emissions from road
transport and associated
external costs
Expected reduction of NOx emissions by
3,176 kt over 2026-2050 (16.8% reduction
from the baseline)
Expected reduction of PM emissions by
135 kt over 2026-2050 (12.7% reduction
from the baseline)
Estimated external cost savings of EUR
58.7 billion, expressed as present value
over 2026-2050 relative to the baseline.
(++)
Expected reduction of NOx emissions
by 3,925 kt over 2026-2050 (20.8%
reduction from the baseline)
Expected reduction of PM emissions by
196 kt over 2026-2050 (18.5% reduction
from the baseline)
Estimated external cost savings of EUR
75.2 billion, expressed as present value
over 2026-2050 relative to the baseline.
(+++)
Expected reduction of NOx emissions
by 3,969 kt over 2026-2050 (21.0%
reduction from the baseline)
Expected reduction of PM emissions
by 199 kt over 2026-2050 (18.7%
reduction from the baseline)
Estimated external cost savings of
EUR 76.1 billion, expressed as
present value over 2026-2050 relative
to the baseline.
(+++)
Expected reduction of NOx emissions by 3,970
kt over 2026-2050 (21.0% reduction from the
baseline)
Expected reduction of PM emissions by 199 kt
over 2026-2050 (18.7% reduction from the
baseline)
Estimated external cost savings of EUR 76.1
billion, expressed as present value over 2026-
2050 relative to the baseline.
(+++)
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Strongly negative Negative No or limited impact Positive Strongly positive Unclear
Impact PO1a PO1b PO2 PO3
% reduction in the level of noise
from road transport and
associated external costs
Limited impact on noise levels by a 1%
reduction of share of share of motorcycle
high emitters
Estimated external cost savings of EUR 0.2
billion, expressed as present value over
2026-2050 relative to the baseline.
(0/+)
Significant impact on noise levels by
expected reduction of high emitters by
12.5% for M1 and N1 and 31.1% for L3-
L7
Estimated external cost savings of EUR
7.3 billion, expressed as present value
over 2026-2050 relative to the baseline.
(++)
Significant impact on noise levels by
expected reduction of high emitters by
12.5% for M1, 12.5% for N1 and
30.7% for L3-L7
Estimated external cost savings of
EUR 7.3 billion, expressed as present
value over 2026-2050 relative to the
baseline.
(++)
Significant impact on noise levels by expected
reduction of high emitters by 12.5% for M1,
16.4% and N1 and 33.4% for L3-L7
Estimated external cost savings of EUR 7.8
billion, expressed as present value over 2026-
2050 relative to the baseline.
(++)
General objective 3: Facilitate the free movement of persons and goods in the EU
Removal of obstacles to re-
registration of vehicles in
another MS
Positive contribution based on enhanced
access to other MS PTI databases via the
common interface (PMC7) and the
harmonisation of the vehicle registration
documents (PMC8)
Additional positive contribution towards
removal of obstacles on the basis of the
digital vehicle registration certificate
(PM16) combined with additional data
included in the vehicle register (PM17)
(++)
Positive contribution based on enhanced
access to other MS PTI databases via the
common interface (PMC7) and the
harmonisation of the vehicle registration
documents (PMC8)
(+)
Positive contribution based on
enhanced access to other MS PTI
databases via the common interface
(PMC7) and the harmonisation of the
vehicle registration documents
(PMC8)
Additional positive contribution
towards removal of obstacles on the
basis of the digital vehicle registration
certificate (PM16) combined with
additional data included in the vehicle
register (PM17)
(++)
Positive contribution based on enhanced access to
other MS PTI databases via the common interface
(PMC7) and the harmonisation of the vehicle
registration documents (PMC8)
Additional positive contribution towards removal
of obstacles on the basis of the digital vehicle
registration certificate (PM16) combined with
additional data included in the vehicle register
(PM17)
(++)
Removal of obstacles related to
the roadworthiness testing of
vehicles (recognition of
certificates issued by other
MSs)
Positive but partial impact on the removal
of obstacles dependent on the level/number
of bilateral agreements signed that are
expected to cover only part of the EU
Member States
(+)
Positive impact on the removal of
obstacles expected due to the EU-wide
recognition of PTI certificates in another
Member State but limited only to
passenger cars and only for a period of 6
months
(++)
Positive impact on the removal of
obstacles expected due to the EU-wide
recognition of PTI certificates in
another Member State but limited only
to passenger cars and only for a period
of 6 months
(++)
Positive impact on the removal of obstacles
expected due to the EU-wide recognition of PTI
certificates in another Member State extended to
all vehicles without time limit
(+++)
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Strongly negative Negative No or limited impact Positive Strongly positive Unclear
Impact PO1a PO1b PO2 PO3
Specific objective 1: Ensure the adequacy, consistency, objectivity, and quality of roadworthiness testing of today's and tomorrow's vehicles
Use of available test methods
and procedures appropriate to
assess the roadworthiness of
vehicles, including new internal
combustion engine and electric
vehicles and their electronic
safety and emission control
systems
Use of new test methods in PTI and RSI
ensuring that ADAS and other GSR related
technologies operate as expected and
update of PTI to cover the safety of electric
vehicles
Small scope extension of RSI for
motorcycles (8.6% of the fleet covered)
(+)
Use of new test methods in PTI and RSI
ensuring that ADAS and other GSR
related technologies operate as expected
and update of PTI to cover the safety of
electric vehicles
Systematic cargo securing inspections
Significant increase in the number of
vehicles covered at PTI: M1/N1 vehicles
over 10 years old (increase by 42.1
million PTI for M1 in 2030 and 4.5
million inspections for N1). Small
extension of the number of motorcycles
tested at PTI (8.8% increase)
(+++)
Use of new test methods in PTI and
RSI ensuring that ADAS and other
GSR related technologies operate as
expected and update of PTI to cover
electric vehicles
Systematic cargo securing inspections
Significant increase in the number of
vehicles covered at PTI: M1/N1
vehicles over 10 years old (increase by
42.1 million PTI for M1 in 2030 and
4.5 million inspections for N1). Small
extension of the scope of RSI for
motorcycles covered and higher
frequency (8.6% increase)
(+++)
Use of new test methods in PTI and RSI ensuring
that ADAS and other GSR related technologies
operate as expected and update of PTI to cover
electric vehicles safety aspects
Systematic cargo securing inspections
Significant increase in the number of vehicles
covered at PTI: M1/N1 vehicles over 10 years
old (increase by 42.1 million PTI for M1 in 2030
and 4.5 million inspections for N1) and a further
extension of the scope for motorcycles (9%
increase)
(+++)
Use of available test methods
and procedures appropriate to
assess the roadworthiness of
vehicles including new internal
combustion engine and electric
vehicles and their electronic
safety and emission control
systems
Adoption of new and effective test methods
to measure NOx and PN emissions during
PTI and RSI for all vehicle categories (ICE)
Small extension of the scope of RSI for
motorcycles (8.6 % increase)
(+)
Adoption of new and effective test
methods to measure NOx and PN
emissions during PTI and RSI for all
vehicle categories (ICE), including the
use of remote sensing and plume chasing
Significant increase in the scope of
vehicles covered for N1 vehicles (annual
tests from year 1) (increase by 14.2
million emission inspection in 2030) and
for all M1/N1 vehicles over 10 years old
(increase by 42.1 million PTI for M1 in
2030 and 4.5 million inspections for N1)
and a small extension of the number of
motorcycles tested at PTI (8.8%
increase)
(+++)
Adoption of new and effective test
methods to measure NOx and PN
emissions during PTI and RSI for all
vehicle categories (ICE), including the
use of remote sensing and plume
chasing
Significant increase in the scope of
vehicles covered for N1 vehicles
(annual tests from year 1) (increase by
14.2 million emission inspection in
2030) and for all M1/N1 vehicles over
10 years old (increase by 42.1 million
PTI for M1 in 2030 and 4.5 million
inspections for N1) and a small
extension of the scope of RSI for
motorcycles (8.8% increase)
(+++)
Adoption of new and effective test methods to
measure NOx and PN emissions during PTI and
RSI for all vehicle categories (ICE), including
the use of remote sensing and plume chasing
Significant increase in the scope of vehicles
covered for N1 vehicles (annual tests from year
1) (increase by 14.2 million emission inspection
in 2030) and for all M1/N1 vehicles over 10
years old (increase by 42.1 million PTI for M1 in
2030 and 4.5 million inspections for N1) and
further extension of the scope of PTI for
motorcycles (9% increase)
(+++)
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Strongly negative Negative No or limited impact Positive Strongly positive Unclear
Impact PO1a PO1b PO2 PO3
Specific policy objective 2: Significantly reduce fraud and tampering and improve the detection of defective vehicles
Impact (% of reduction) on the
number of defective and
tampered vehicles in terms of
emission control systems
Expected reduction of vehicles with
defective and tampered emission control
systems for NOx and PN/PM (high
emitters) on the basis of advanced PTI by
up to 33% by 2030 and 42% by 2050 for
NOx and 26% by 2030 and 38% by 2050
for PN (weighted average for the whole
fleet)
(++)
Expected reduction of vehicles with
defective emission control systems for
NOx and PN/PM (high emitters) on the
basis of advanced PTI and RSI by up to
48% by 2030 and 56% by 2050 for NOx
and 43% by 2030 and 53% by 2050 for
PN (weighted average for the whole
fleet)
(+++)
Expected reduction of vehicles with
defective emission control systems for
NOx and PN/PM (high emitters) on the
basis of advanced PTI and RSI by up
to 48% by 2030 and 56% by 2050 for
NOx and 43% by 2030 and 53% by
2050 for PN (weighted average for the
whole fleet)
(+++)
Expected reduction of vehicles with defective
emission control systems for NOx and PN/PM
(high emitters) on the basis of advanced PTI and
RSI by up to 48% by 2030 and 56% by 2050 for
NOx and 43% by 2030 and 53% by 2050 for PN
(weighted average for the whole fleet)
(+++)
Impact (% reduction) on the
number of vehicles with
tampered emission/noise
control system
Very limited impact on identification of
tampered vehicles focusing on HGVs as
part of the advanced RSI inspections and
for motorcycles (for those MSs that use
RSI)
(0/+)
Positive impact on identification of
tampered vehicles covering all vehicle
categories on the basis of advanced RSI
inspection combined with the use remote
sensing and plume chasing (for HGVs) as
part of RSI
(+)
Significant impact on identification of
tampered vehicles covering all vehicle
categories on the basis of advanced
RSI inspection combined with the use
remote sensing and plume chasing (for
HGVs) as part of RSI and the
introduction of RSI for N1
(++)
Significant impact on identification of tampered
vehicles covering all vehicle categories on the
basis of advanced RSI inspection combined with
the use of remote sensing and plume chasing (for
HGVs) as part of RSI and the introduction of RSI
for N1 and motorcycles
(+++)
Impact (% reduction) on level of
odometer tampering and
associated cost savings for
consumers
Significant reduction of odometer
tampering estimated to help avoid
tampering for 4.7 million M1 and N1
vehicles in 2030 and 5.1 million in 2050,
64% of which related to cross border sales.
Benefits of EUR 118.3 billion to businesses
owners of vehicles and EUR 65.7 billion
consumers for the period 2026-2050,
expressed as present value relative to the
baseline.
(+++)
Significant reduction of odometer
tampering estimated to help avoid
tampering for 4.7 million M1 and N1
vehicles in 2030 and 5.1 million in 2050,
64% of which related to cross border
sales.
Benefits of EUR 118.3 billion to
businesses owners of vehicles and EUR
65.7 billion consumers for the period
2026-2050, expressed as present value
relative to the baseline.
(+++)
Significant reduction of odometer
tampering estimated to help avoid
tampering for 4.7 million M1 and N1
vehicles in 2030 and 5.1 million in
2050, 64% of which related to cross
border sales.
Benefits of EUR 118.3 billion to
businesses owners of vehicles and
EUR 65.7 billion consumers for the
period 2026-2050, expressed as
present value relative to the baseline.
(+++)
Significant reduction of odometer tampering
estimated to help avoid tampering for 4.7 million
M1 and N1 vehicles in 2030 and 5.1 million in
2050, 64% of which related to cross border sales.
Benefits of EUR 118.3 billion to businesses
owners of vehicles and EUR 65.7 billion
consumers for the period 2026-2050, expressed
as present value relative to the baseline
(+++)
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Strongly negative Negative No or limited impact Positive Strongly positive Unclear
Impact PO1a PO1b PO2 PO3
Specific policy objective 3: - Improve electronic storage and exchange of relevant vehicle identification and status data
Reduction of time/costs
associated with the access and
exchange of relevant vehicle
data by inspection centres and
enforcement and registration
authorities
Positive impact on costs for authorities
estimated at EUR 642 million for the period
2026-2050 on the basis of the enhanced
access to electronic data related to PTI for
authorities (PMC7) combined with
enhanced access to relevant vehicle
technical information for PTI centres
(PM16) with additional savings of up to
EUR 1.43 billion for the period 2026-2050
(+++)
Positive impact on costs for authorities
estimated at EUR 642 million for the
period 2026-2050 on the basis of the
enhanced access to electronic data
related to PTI for authorities (PMC7)
(+)
Positive impact on the basis of the
enhanced access to electronic data
related to PTI for authorities estimated
at EUR 642 million for the period
2026-2050 (PMC7) combined with
enhanced access to relevant vehicle
technical information for PTI centres
(PM16) with additional savings of up
to EUR 1.43 billion for the period
2026-2050
(+++)
Positive impact on the basis of the enhanced
access to electronic data related to PTI for
authorities estimated at EUR 642 million for the
period 2026-2050 (PMC7) combined with
enhanced access to relevant vehicle technical
information for PTI centres (PM16) with
additional savings of up to EUR 1.43 billion for
the period 2026-2050
(+++)
Source: Ricardo et al. (2023), Impact assessment support study
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ANNEX 10: SME TEST
Step (1) of SME test (identification of affected businesses).
In the road transport sector 99% of companies are SMEs (enterprises employing up to 250 people and
with a turnover of less than EUR 50 million466
). Roadside inspections under the RSI Directive have
been specifically targeted at commercial vehicle fleets, which are predominantly operated by SMEs.
The exact number of SMEs among PTI centres could not be established since there are no statistics
on the share of PTI centres that are SMEs and due to the situation where in each Member State there
are different PTI organisational models in place. In some Member States (e.g. Sweden) there are a
few big companies that provide PTI services while in others (e.g. Netherlands), there are multiple
small independent garages. In the majority of the Member States, there is a mix of a small number of
large PTI centres and a large number of small (SMEs) ones. Garages, motor vehicle dealers, tyre and
repair stations, affected by the requirement for Member States to set up a system to record odometer
readings from the cars and vans registered in their territory, are almost entirely SMEs (above 99% of
the companies are SMEs).
Step (2) of SME test (consultation of SME stakeholders).
In the OPC, looking at the responses of companies, i.e., those organisations that classified themselves
as a ‘company or business organisation’ and which are clearly a company, there were 21 separate
responses from SMEs and 16 from larger companies. In the context of the OPC and the targeted
stakeholder consultation, the responses suggested a higher sensitivity of SME respondents towards
the expected costs of some of the measures (extension of scope of PTI and RSI in the case of
motorcycles and vans, and for more demanding tests), mainly in relation to the costs for new
equipment and facilities for small PTI centres and for small transport companies.
According to the stakeholders consulted in the survey, a slightly positive impact on the SME
competitiveness would be expected from measures related to access and exchange of information,
extended scope of RSI and new RSI test methods, new PTI/RSI test requirements, vehicle registration
measures and roadworthiness certificates in electronic format. Some stakeholders also considered
there should be a positive impact for SMEs despite the additional cost on equipment. They stated that
the policy options should have a positive economic impact because vehicles, which need a mandatory
PTI also need to be maintained regularly and this is normally done by garages, tyre and repair stations,
which almost entirely SMEs. On the other hand, the survey responses showed that SMEs are
concerned by the financial burden these new testing requirements and equipment adaptations may
pose on them. These additional costs can be particularly challenging for smaller PTI centres to bear.
It was also noted that some SMEs are involved in developing these new testing methods and could
benefit from this. Regarding data access for SME technology companies, it was widely agreed that
facilitating access would enhance the competitiveness of smaller firms, levelling the playing field in
466
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their competition against larger companies. Harmonised data governance should be particularly
beneficial for SMEs.
Step (3) of SME test (assessment of the impacts on SMEs).
PTI centres are affected as described in section 6.1.2.1. The additional equipment costs for PTI
centres mean additional revenues for garage equipment manufacturers, many of which are also
SMEs. It was however not possible to quantify these revenues. Beyond the impact of the common
measures on SMEs, no additional impact on costs for PTI centres is expected for PO1a. Both PO1b
and PO2 will, in addition to the common measures, include increased costs for SMEs due to
additional emission tests for light commercial vehicles (PM5), extra tests on vehicles over 10 years
old (PM6), equipment and training of inspectors for motorcycle noise testing (PM10), and the
additional emission tests for vehicles that are found as high emitters during remote sensing or plume
chasing and are sent for emission tests in a PTI centre (PM12). PO1b will also include costs for
equipment and training of inspectors for the mandatory PTI for motorcycles above 125cm3 (PM2).
PO3 (in addition to the common measures, plus PM5, PM6, PM10 and PM12) is expected to have
an impact on SMEs through PM3, leading to motorcycle test adaptation costs. Additionally, PM4
concerning PTI for light trailers requires the acquisition of supplementary devices. PM7, which aims
to harmonise tests and procedures, is associated with increased expenses for SMEs operating testing
centres due to the need to invest in standardised equipment. These measures collectively are expected
to lead to some financial challenges for SME testing centres in adapting to the new testing
requirements, in particular in the first years of implementation, and provide new opportunities to
garage equipment manufacturers. PO1b, PO2 and PO3 are expected to have the most significant
impact on SMEs.
As shown in section 6.1.2.1, all policy options are estimated to result in adjustment costs for PTI
centres, with the highest costs arising for PO3, and under PO2 and PO3 also in some increase in the
administrative costs. The increase in costs for new equipment and facilities (estimated in the range
of EUR 20,000 to EUR 100,000 per new PTI lane depending on the specific vehicle category) can
have a greater impact on some smaller PTI centres that may find it more challenging to finance
additional investments. On the other hand, in all policy options SMEs can expect to benefit from the
additional business opportunities due to the extension of the scope and/or the frequency of PTI. The
largest benefits due to the extension of the scope and/or the frequency of PTI are expected in PO3.
Overall, as explained in section 6.1.2.1, PO2 is expected to result in the highest net benefits for PTI
centres (EUR 17.3 billion, expressed as present value over 2026-2050), followed by PO3 (EUR 16.4
billion) and PO1b (EUR 15.9 billion) while PO1a is expected to result in net costs (EUR 2.9 billion).
Net benefits in PO2 represent around 6.3% of the turnover per PTI centre, in PO3 around 6% of the
turnover, in PO1b around 5.8% of the turnover per PTI centre, while the net costs in PO1a around
1.1% of the turnover. While it was not possible to split the costs and benefits between the two groups
(i.e., SME and others), due to the lack of data, a large part of the net benefits in PO1b, PO2 and PO3
and of the net costs in PO1a are expected to be attributed to SMEs.
Garages, motor vehicle dealers, tyre and repair stations, etc., mostly SMEs, will be affected by the
requirement for Member States to set up a system to record odometer readings from the cars and vans
registered in their territory (PMC9) in all policy options. As explained in section 6.1.2.2, total one-
off and recurrent administrative costs would amount to EUR 460 million (EUR 706 per company),
expressed as present value over 2026-2050.
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Businesses owning vehicles. As explained in section 6.1.2.4, all policy options are expected to result
in net benefits for businesses owning vehicles, estimated at EUR 117.8 billion in PO1a, EUR 94.2
billion in PO1b, EUR 94 billion in PO2 and EUR 93.6 billion in PO3, expressed as present value
over 2025-2050 relative to the baseline (in 2022 prices). Based on the available information, it was
however not possible to assess how many of the businesses owning vehicles are SMEs.
Only few of the measures are expected to affect the road haulage sector largely composed of SMEs
(e.g., PM13 on cargo securing inspections in PO1b, PO2 and PO3, which would result in minimal
costs, while hauliers could also benefit from the savings of avoided emission tests at PTI after having
passed a RSI or a remote sensing check). The overall impact on the road haulage sector is expected
to be limited but rather positive, although the available data did not allow a split of the costs and
benefits between the two groups of operators (i.e., SME and others).
Step (4) of SME test (minimizing negative impacts on SMEs).
A large part of costs and benefits for PTI centres are expected to be attributed to SMEs. Depending
on the Member State, the additional costs for the SMEs due to the additional requirements per PTI
may be passed through to vehicle owners. Where Member States do not regulate prices, the PTI
centres would likely be able to recover investment costs. Where Member States regulate the level of
PTI charges, the costs may either be borne by the service provider or be recovered over a longer
period. On the other hand, the higher costs due to the increased number of inspections (i.e. due to the
extended scope) can be fully passed through to the vehicle owners and will represent benefits for the
SMEs. Likewise, garages, motor vehicle dealers, tyre and repair workshops, which are mostly SMEs,
will be affected by the requirement to set up a system to record odometer readings from the cars and
vans registered in the same Member State. The related costs could be partly offset with pass-through
of the costs to vehicle owners.
For businesses owning vehicles, it was not possible to assess how many of the businesses owning
vehicles are SMEs. Measures such as cargo securing inspections are expected to affect the road
haulage sector largely composed of SMEs, which would result in minimal costs. On the other hand,
hauliers would be able to benefit from the savings of avoided emission tests at PTI after having passed
a RSI. The overall impact on the road haulage sector is expected to be limited but rather positive,
although the available data did not allow a split of the costs and benefits between the two groups of
operators (i.e., SME and others).
A key issue highlighted by respondents in the stakeholder consultation in relation to SMEs are the
aspects related to the renewal of testing equipment: the financial implications, the timeline for
completing the investment, and the availability of support or financing options to facilitate this
transition. One possible solution could be the extension of the transitional period for SMEs to update
their equipment/facilities. A smoother transition with a longer time for adjustment could make it
easier for smaller PTI centres to prepare and minimise the negative impact.
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ANNEX 11: LINKS BETWEEN THE CONCLUSIONS OF THE EX-POST
EVALUATION AND THE IMPACT ASSESSMENT
The links between the conclusions of the ex-post evaluation and the impact assessment are
summarised in the table below.
Table 269: Links between the main conclusions of the ex-post evaluation and the impact assessment
Main ex-post evaluation conclusions Impact Assessment
Conclusions on relevance
The RWP is not adapted to the latest technologies such as advanced
driver assistance systems (e.g. ADAS) and electronic safety features,
for which the RWP currently does not provide a sufficiently
comprehensive framework. It does not contain specific testing
protocols which would ensure the compliance and maintenance of
electric, hybrid and hydrogen vehicles, including software updates.
Technical inspections would have to be updated for the efficient
acquisition of important safety-related data and the monitoring of
new sensors and functions. Regarding emissions, some of the PTI
tests and equipment must be adapted as they are no longer capable of
detecting emission failures in the most recent internal combustion
engine vehicles.
The impact assessment analyses specific
measures dedicated to addressing the
challenges posed by recent and upcoming
vehicle technology, in particular testing ADAS,
software updates and electric vehicles.
Similarly, measures aiming at improved access
to vehicle data for the purposes of vehicle
testing are assessed. As for emission testing,
measures to introduce new test methods based
on recent technical developments to replace
outdated methods are defined.
Conclusions on effectiveness
Regarding roadworthiness emission checks, the effectiveness of the
RWP is limited as the current test requirements under PTI and RSI
are not suited to testing the functioning of recent emission control
systems and must therefore be updated. Opacity testing measurement
is outdated as it cannot detect diesel vehicles with defective particle
filters or a tampered catalyst, which lead to high particle and NOx
emissions. Instead, PN and NOx measurement should be used to
verify newer diesel and petrol vehicles to detect defects and
tampering with emission control systems.
Regarding improvement of the exchange of information on testing
results between Member States, the current framework for
information exchange has not been effective. Although the legislation
mentions electronic data exchanges between Member States
authorities as a possibility, not all countries use this. Even if the
harmonisation of vehicle registration documents made it easier for
citizens to register vehicles from other Member States and EEA, there
is room for improvement of the digitalisation process, to make it even
easier. Re-registration can still be a cumbersome process and the
RWP currently prevents the mutual recognition of PTIs between
Member States, which represents a barrier to free movement.
The impact assessment analyses the impacts of
replacing outdated emission test methods for
modern vehicles, in particular exhaust gas
opacity testing required by the current PTI and
RSI Directives. It assesses the benefits of
measures introducing particle number (PN)
counting and NOx-measurement, as well as
remote sensing and/or plume chasing.
The impact assessment looks at specific
measures facilitating cross-border exchange of
vehicle data.
Similarly, it assesses the expected effects of
various alternatives of mutual recognition of
PTI certificates.
Conclusions on efficiency
Digitalisation can help in streamlining the vehicle re-registration
process: the RWP should use the benefits of digital data exchange and
more harmonisation of vehicle documents to reduce the
administrative burden and costs associated with the process. Also,
digital (mobile) vehicle registration documents could further
The impact assessment looks at specific
measures facilitating cross-border exchange of
vehicle data to address the issue of inefficient
re-registration processes, for example the
harmonisation of registered data and the
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Main ex-post evaluation conclusions Impact Assessment
facilitate the digitalisation of the vehicle registration and data-
keeping processes and reduce costs.
interlinking of national vehicle registers, as
well as the possible introduction of digital
registration documents.
Conclusions on coherence
More consistency should be ensured between the type-approval
regulation and the RWP. The coherence between the RWP and
relevant EU instruments could be improved through the
standardisation of safety-relevant vehicle data and the related
responsibilities for manufacturers during the vehicle’s lifecycle.
Defining responsibilities more clearly and mandating that relevant
information is made available for PTIs across Member States could
reduce uncertainty and time spent on searching for the relevant
information, thus improving the overall accuracy and efficiency of
inspections. The RWP should be also better aligned with the General
Safety Regulation (GSR) (EU) 2019/2144.
Roadworthiness testing relies to a large extent
on type-approval, including when it comes to
safety-relevant vehicle data. While the
initiative on access to in-vehicles data is meant
to address the need to standardise data formats,
this impact assessment considers a measure that
aims to specify the means of access to such data
for the purpose of vehicle inspection.
It also analyses the impacts of a measure
focusing on testing ADAS, mandated by the
GSR.
Conclusions on EU Added Value
The RWP sets a minimum standard for all Member States and
provides a basic framework for detecting and addressing
roadworthiness defects, ensuring that all Member States take action
to improve road safety. Further harmonisation of the minimum PTI
and RSI requirements would be useful to improve consistency of
legislation, standards and practices within the EU. There is scope to
improve mutual recognition of PTI inspections between the Member
States, which would add value to the EU internal market, while it
would also help to increase vehicle safety and environmental
protection.
One aim of the initiative is to update the RWP
to evolving technology, to maintain its added
value. It therefore includes a series of measures
aimed at further improving road safety and
environmental protection through further
harmonisation.
Measures are also defined to enhance the
mutual recognition of PTIs conducted in
another Member State.
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ANNEX 12: IMPACTS ON FUNDAMENTAL RIGHTS
This annex discusses in more detail the impacts on fundamental rights. The policy options were assessed to
determine if they have an impact on the fundamental rights and/or equal treatment of EU citizens. The
starting point of the assessment of the fundamental rights is the Charter of Fundamental Rights of the
European Union467
. All POs were assessed having regard to the relevant EU instrument and it was
concludedthattheymaintainfull respect forhumanandfundamental rights, andnonewillhaveanynegative
impact thereon.
All options containcommonmeasures (PMC3 andPMC4)tohelpreducethelevel of airpollutant emissions
from vehicles, thereby helping to improve the quality of the environment, in line with Article 37 of the
Charter. However, options PO1b, PO2, and PO3 go further than option PO1ain this regard, due to measures
PM5 (annual emission testing for light commercial vehicles), PM6 (yearly testing of vehicles that are 10-
year-old or older) and PM12 (NOx measurement in RSI by remote sensing and plume chasing).
All policy options contain a measure (PMC1) to adapt PTI methods to the testing of electric vehicles
including the training of inspectors. This will provide a safer workplace for vehicle inspectors. In addition,
PO1b, PO2, and PO3 contain a measure (PM13) to include mandatory inspection of cargo securing in RSI.
These three policy options will therefore provide a safer working environment than option PO1a for
professional drivers (Article 31).
All policy options contain a measure designed to combat odometer fraud (PMC9), thereby increasing
consumer protection (Article 38). Policy options PO3 as well as PO1b and PO2 each contain a measure
(PM7 or PM8) to provide for mutual recognition of roadworthiness certificates. Policy options PO1a, PO2
and PO3 contain a measure to digitalise registration documents (PM16). Therefore, PO2 and PO3 would
have the greatest impact on assisting freedom of movement and residence (Article 45).
All policy options contain a measure (PMC3) on PN measurement at PTI for light and heavy-duty vehicles
and at RSI for commercial vehicles. However, policy options PO1b, PO2 and PO3 also contain a roadside
inspection measure for NOx andPM measurement (remote sensing and plume chasing – PM12).Therefore,
these three options go further than PO1a in ensuring that vehicles with tampered emission control systems,
which could otherwise pass at PTI, will be caught at RSI. By ensuring that owners of non-tempered vehicles
are not placed at a disadvantage compared to tampered vehicles, these three options do the most in
promoting equality before the law (Article 3).
PO2 and PO3 contain a measure on data governance (regarding cost-free access to vehicle testing by testing
centres – PM11), which refers to technical data related to the vehicle’s specifications and current state (e.g.,
sensorvalues).Alloptions includeameasureonodometerreadings(PMC9),whichconsidersprivacyissues
when data is stored and exchanged. During the consultations, some stakeholders expressed concern over
thedataprivacyissuesincommonmeasures relatedtothepossibilityofelectronicroadworthiness electronic
certificates, and access thereto (PMC6 and PMC7). From a road safety perspective, the automatic
accessibility of certificates through a shared system holds significant advantages, particularly in facilitating
cross-border inspections and enhancing consumer convenience. However, the implementation of a digital
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roadworthiness certificate demands a careful examination of potential privacy issues and the formulation of
robust privacy protection measures.
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ANNEX 13: IMPACTS ON THE FUNCTIONING OF THE INTERNAL MARKET
AND COMPETITION
As described in section 6.1.7, the existing divergence between vehicle registration documents and
the information included and quality of the data stored in the vehicle registers creates challenges in
coordinating enforcement actions by Member States. Furthermore, the non-recognition of
roadworthiness certificates among EU Member State creates additional trade barriers for cross-border
operation or sale of vehicles, hindering the efficient functioning of the internal market, business
operations and the freedom of movement of people within the EU. All policy options are expected to
have a positive impact on the functioning of the internal market.
The combination of the measures related to improving the availability and exchange of vehicle-
related information, making the roadworthiness certificate available in electronic format,
harmonising testing methods, the frequency of testing, requirements for the improvement of the PTI
and the scope of testing, can have a positive impact on the functioning of the internal market and on
competition.
All policy options include the common measures on the harmonisation of testing methods (PMC3,
PMC4), and requirements for improving PTI (PMC1, PMC2 and PMC5) which could facilitate the
free movement of vehicles, since more harmonised testing across Member States can enhance
consumer confidence in purchasing vehicles from other countries, thereby promoting competition.
Odometer tampering concerns at the moment of purchasing a second-hand vehicle are addressed by
PMC9 in all policy options.
Harmonising vehicle registration documents across Member States (PMC8) can have a positive
contribution to internal market and competition. The standardised information helps to verify the
vehicle's characteristics, and its registration status in the country of origin. This verification process
helps to address potential obstacles to re-registration in another EU Member State, for example where
the vehicle is reported stolen, or its registration certificate is suspected of being fraudulent. By
harmonising the technical data in vehicle registration documents, the measure can simplify and
streamline cross-border trade in vehicles within the EU.
Providing electronic access to relevant data, including on PTI reports stored in national databases, to
the registration authorities in another Member State (PMC7), is also expected to have a positive
impact on the EU internal market, helping to avoid fraud and eliminate trade obstacles. An additional
positive impact on fraud avoidance is expected from the requirement to issue roadworthiness
certificates in electronic format only (PMC6).
Qualitative assessment shows that PO2 and especially PO3 are expected to have the highest positive
impact on the internal market and competition. PO2 incorporates additional measures aimed at
extending roadside inspections to light commercial vehicles, and facilitating access to vehicle data
necessary for thorough testing by PTI centres. This comprehensive approach is expected to have a
stronger impact than PO1a and PO1b due, to its emphasis on these factors. PO3 has a stronger positive
impact due to PM7, which requires that a PTI certificate issued in any Member State is recognised
by the Member State of registration, as well as further harmonisation of test methods. In addition,
PO3 introduces mandatory PTI for all motorcycles and light trailers, which are not currently tested
by all Member States. The inclusion of L-category vehicles in the scope of RSI (PM15) is expected
to reduce the number of tampered vehicles. PO3 applies more ambitious measures regarding the
304
mutual recognition of the PTI certificates, and the standardisation of tests methods than provisions
already included in the other policy options. As such, PO3 is expected to deliver the most significant
positive impact on the internal market and competition.
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ANNEX 14: COHERENCE, SUBSIDIARITY AND PROPORTIONALITY
(DETAILED ANALYSIS)
Coherence
Internal coherence assesses how various elements of the proposed options are expected to work
together to achieve the objectives. Although all four policy options address the identified specific
objectives and underlying problem drivers, they do so in different ways, and with a different level of
intervention.
The measures common to all policy options address different aspects of the problem covering test
methods and procedures for both PTI and RSI, frequency of inspections related to vehicles with
modifications, and measures related to facilitating exchange of PTI and registration data among
Member States. There are no evident contradictions and inconsistencies among these measures. In
some case there are possible synergies in terms of costs to implement them, such as the introduction
of new test methods for PN and NOx, where the goal is to eventually use one single device and one
single measurement for both tests. Importantly, the measure addressing odometer fraud, by increasing
the number of readings and the exchange of relevant data in the case of cross-border sales, will benefit
from the implementation of the measure that will facilitate the easier exchange of relevant data among
Member States.
PO1a focuses on better exchange of vehicle data and there are clear synergies between the common
measures on the frequent update of data in vehicle registration and the introduction of a digital vehicle
certificate. Digital vehicle certificate should also simplify the approach to the data to be included in
vehicle certificate dataset and facilitate re-registration of vehicles and enforcement activities.
PO1b has the focus more on testing and reducing safety- and emissions-related fraud and tampering
and improving the detection of defective vehicles. It includes additional test methods and procedures
besides those in the common measures. It aims at higher combined impact in terms of identification
of defective vehicles, for example through measures such as the annual emission testing of light
commercial vehicles. It also shows synergies with introducing mandatory PTI for motorcycles and
the use of more advanced noise testing for motorcycles. The use of remote sensing and plume chasing
for HDVs measuring NOx and particle emissions complements the new PTI and RSI methods, helps
to better target inspections and increases the share of the vehicle fleet checked between PTI
inspections. Given that it does not include any of the measures related to digital certificate or the
extension of data to be included in the registration certificate, some of the combined benefits in PO1b
are likely to be smaller.
Synergies indicated in relation to PO1a and PO1b are expected to increase in the case of PO2 and
PO3, containing more comprehensive sets of measures and even lead to extra synergies, for example
due to measures on registration certificate and more harmonised registered data. Some measures such
as introduction of RSI for vans will be complementary to the use of new testing methods (PN and
NOx testing). PO3 goes even further than PO2 by including RSI for motorcycles, complementing the
mandatory PTI for motorcycles with extended scope (>50cc), and by requiring PTI of trailers below
3.5t (O1 and O2 categories).
To summarise, all policy options ensure internal coherence. Among the four options, it can be
concluded that PO2 and PO3 are expected to benefit from a broader range of synergies that can
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contribute to a higher level of achievement of the objectives.
External coherence focuses on the compliance of the initiative with other EU instruments and
relevant EU policies, as well as national policies and international obligations. All identified policy
options show strong links to several EU instruments.
All policy options appear consistent with the objectives and priorities set in the 2020 Sustainable
and Smart Mobility Strategy (SSMS) and the EU Green Deal by ensuring that vehicles on the
roads maintain an adequate level of safety and environmental performance over time. By the expected
reduction in fatalities, all policy options are in line with the objectives set in the EU Road Safety
Policy Framework, and will contribute to the achievement of the objective of 50% reduction of
fatalities and serious injuries by 2030. Still, PO2 and even more so PO3 are the policy options with
the greatest level of contribution towards this objective. The proposed options are also expected to
have a significant contribution towards the EU’s clean air policy objectives, including those of the
Ambient Air Quality Directives and of the National Emission reduction Commitments Directive, by
better identifying and reducing the presence of high polluters that represent a very large share of total
emissions from road transport.
All policy options are also consistent with the Single Digital Gateway Regulation by facilitating
online access to vehicle-related information, relevant administrative procedures and assistance and
problem-solving services. PO1b is less coherent than the other options as it does not include the
digitalisation of vehicle registration certificates and adding further data to the vehicle registers.
Otherwise, the options are also serving the objectives of the EU’s Data Strategy for the development
of European Data spaces for public administrations that can support enforcement of legislation,
including road safety and environmental legislation. Exchange of information related to
roadworthiness and registration data will have to be aligned with relevant rules on data protection
(GDPR).
All options are consistent with the General Safety Regulation. They will ensure that any new
equipment introduced to ensure compliance with that Regulation will perform as expected and, as a
result, ensure that the benefits materialise. All policy options are coherent with the safety and
environmental requirements as set out in the Type-approval Regulations468
. These Regulations also
set out the market surveillance requirements for these vehicles. All policy options include measures
which aim at ensuring that minimum standards are maintained by owners throughout the lifetime of
the vehicle. They include alignment between PTI and RSI testing and the type-approval process,
including in relation to the use of ePTI. Remote sensing in RSI of all vehicles (part of PO1b, PO2
and PO3) is particularly relevant for the purposes of market surveillance as it allows screening a large
part of the vehicle fleet providing valuable insight into recurrent issues with specific
technologies/solutions used as part of emission control systems, vehicle models, model years etc.
Further to that, there are expected synergies with the new Euro 7 Regulation for all options,
including the use of On-Board Monitoring functions to facilitate the assessment of NOx emissions
during PTI and RSI inspections. Finally, all policy options are coherent with the requirements of the
legislation on end-of-life vehicles (ELV), through providing electronic access to data to the
registration authorities of other EU Member States and adding new, including ELV-related data to
468
i.e. Regulation (EU) 2018/858 for most passenger and freight vehicles and their trailers, Regulation (EU) 167/2013
for tractors, and Regulation (EU) 168/2013 for two- and three-wheel vehicles and quadricycles.
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the vehicle register.
In terms of external coherence, all policy options are therefore considered consistent with relevant
EU strategies and legal instruments and contribute to EU policy priorities. In relative terms, PO3 and
PO2 are expected to be the most coherent with the policy objectives in related EU legislation and
strategies, followed by PO1b and PO1a being slightly less coherent. PO2 is considered somewhat
more coherent than PO3 in relation to existing national policies and structural differences on the
ground (further explained under subsidiarity below).
Subsidiarity and proportionality
As described in sections 3.2 and 3.3, EU action is justified on the basis that Member States alone
would not be able to reach the objectives of the initiative, i.e., updating the harmonised rules on
roadworthiness testing, including coordinated exchange of vehicle-related data. What differentiates
the policy options beyond the common measures necessary to achieve the objectives at a minimum
level is their focus (between PO1a and PO1b) and the extent to which they can fulfil the objectives
(PO2 and PO3 going beyond the other two).
In terms of the relevant measures for the recognition of PTI certificate in other Member States,
measures PM8 (included in PO1b and PO2) and especially PM7 (in PO3) may be considered by
Member States as going beyond what is necessary to address the problem, while PM9 (in PO1a) –
based on bilateral agreements (essentially voluntary recognition) – leaves greater scope for Member
States to decide which PTIs to accept depending on differences between national solutions. However,
this is expected to significantly limit the benefits to a limited number of citizens and businesses, thus
also delivering less in terms of the achievement of the objectives. As regards the measures on the PTI
and RSI tests and procedures, similar measures are already in place in the Member States, based on
the current Directives. Requiring that certain standards are applied concerning the tests methods and
procedures is intended to ensure a harmonised approach across the EU and should not, in principle,
raise any subsidiarity issues.
In relation to the measures concerning the extension of the scope of PTI and/or RSI to motorcycles,
PM1 (in PO1a and PO2) aims to ensure harmonisation while giving the option for Member States to
choose whether to use PTI or RSI for motorcycles. PM2 (in PO1b) and PM3 (in PO3) requiring all
Member States to apply PTI to motorcycles would effectively harmonise the roadworthiness testing
of these vehicles, with the change affecting only seven or eight Member States. Furthermore, the fact
that motorcycles are responsible for a significant share of road crashes and environmental pollution
(air and noise), and may also take part in international traffic, appears to justify their regular testing
while leaving the specification of the frequency and contents of the inspections to Member States.
In terms of proportionality, as the level of intervention and associated costs increase from PO1a to
PO3, the level of positive impacts also increases, although not proportionally (as shown by the
efficiency ratios). In general, the scope of the options is limited to what can best be achieved at the
EU level (in terms of harmonisation of methods and scope of testing, as well as in finding common
solutions to ensure efficient sharing and access to the necessary vehicle data). For example, vehicles
that are mostly used locally, such as mopeds and tractors are not targeted by the retained measures.
At the same time, there are differences in the focus and extent to which the options aim to harmonise
the scope of vehicles and the content of testing.
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As for the choice of the instrument for Union action, amending the existing RWP Directives is
considered to be the most appropriate solution. This allows achieving the objectives through taking
the next logical step in the process of gradual harmonisation in this area, while leaving sufficient
room for manoeuvre for Member States to implement the changes in their specific national context,
by continuing to apply well-established national arrangements in roadworthiness testing. This choice,
using minimum requirements instead of a one-size-fits-all approach will also allow industry to
develop the most efficient technical solutions that this continuously evolving field requires.
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ANNEX 15: MONITORING
The following elements related to RSI are important for the monitoring:
• The biennial RSI reports drawn up by Member States cover major and dangerous deficiencies
detected during roadside inspections of heavy-duty vehicles (lorries, buses/coaches, and
tractors). As permitted by the RSI Directive, some Member States apply targeted inspections
based on the risk rating of transport undertakings, which can significantly increase the share of
vehicles found defective at the roadside. Although this increases the effectiveness of the measure,
it also means that the results reported by those Member States are not representative of the actual
share of defective vehicles that may be circulating. In addition, those reports are not comparable
to reports from other Member States that do not apply targeted checks. Their usefulness is thus
limited.
• Instead, reporting the results of PTIs, which are collected by all Member States and cover almost
the entire vehicle fleet will be a much more useful source of information, allowing better
comparability of the implementation and results achieved according to the effectiveness criteria,
e.g., in terms of the numbers of defective and tampered vehicles detected (even if not perfect due
to varying stringency of PTIs among Member States). For vehicles that are subject to PTI, this
should be the primary reference, with RSI results a possible addition. On the other hand, for
vehicles that remain outside of the scope of PTI, RSI results can be a valuable source to assess
the implementation of roadworthiness testing in the EU. The frequency of reporting (biennial) is
considered adequate.
• To gain a clearer view and to monitor the evolution the share of high-emitting vehicles, remote
sensing data should be available from all Member States. Such data would provide an overview
of the state of the vehicle fleet and help identify recurrent issues with specific technologies and
brands or models that should be subject to further investigation e.g., through market surveillance
actions and may be subject to recalls and software updates469
.
• In addition, as demonstrated by the evaluation and this impact assessment, data about the number
of PTI centres, PTI lanes and inspectors are scarce, which hinder the accurate assessment of the
effects of the policies implemented so far as well as the that of the impacts of measures still to
be adopted. It is therefore necessary that Member States regularly inform the Commission about
these basic data, which should be part of the biennial reports starting from the date of
implementation of the revised RWP.
To measure the progress and the actual effects of the initiative, the following operational objectives
and indicators have been identified:
Operational objective Indicators
469
Hooftman N., Ligterink N., Bhoraskar, A., (2020) Analysis of the 2019 Flemish remote sensing campaign.
Commissioned by the Flemish Government - Flanders Environment Agency - Team Air quality policy
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Operational objective Indicators
Apply newly available safety and emission testing
methods at PTI and RSI
Number of MSs applying test methods specific to EVs
Number of MSs applying ePTI methods
Number of MSs applying PN measurement
Number of MSs applying NOx measurement
Number of MSs applying remote sensing
- To screen pollutant emission
- To measure noise
Number of MSs applying plume chasing
Numbers of vehicles screened by remote sensing / plume
chasing
Interconnect Member States’ vehicle registers and
odometer databases through a common hub
Number of MSs having an odometer database
Number of MSs connected to the MOVE-HUB
Number of messages sent per month
Digitalise vehicle documents Number of MSs issuing digital PTI certificates
Number of MSs issuing digital registration certificates
Reduce the number of defective and tampered vehicles
on EU roads
Number of defective vehicles detected at PTI/RSI
- With safety-related defects
- With emissions-related defects
Number of vehicles stopped at RSI following remote
emission screening
Number of vehicles invited to PTI following remote
emission screening
The data for assessing these operational objectives will draw on regular reporting by Member States
as well as ad hoc data collection actions, including by data exchange systems, such as the MOVE-
HUB.
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ANNEX 16: SYNERGIES WITH OTHER POLICY INSTRUMENTS
Roadworthiness testing relies on the technical specifications of the vehicles470
that are harmonised at
EU level and beyond (UNECE471
). Vehicle registration remains a national competence, although it
relies on the Certificate of Conformity also defined in type-approval legislation472
. The most recent
and relevant safety- and emissions-related type-approval regulations are the General Safety
Regulation (GSR)473
and the Euro 7 Regulation (EU) 2024/1257474
. The GSR requires that, from
July 2022, new types of motor vehicles are equipped with advanced driver assistant systems aimed
at reducing the number of fatalities and serious injuries; these will also be used in automated
vehicles475
. The Euro 7 standards will gradually replace existing emission rules for cars and vans
(Euro 6) and lorries and buses (Euro VI), ensuring that new cars, vans, lorries and buses are cleaner
in real driving conditions and that they remain clean for longer than required by the existing
(durability) rules. However, for passenger cars and vans, the current Euro 6 test conditions and
exhaust emissions limits were maintained, as well as the current Euro VI testing conditions for buses
and lorries.
The focus of the RWP is different from the market surveillance legislation mentioned above. Whereas
market surveillance provisions aim to ensure that vehicles continue to meet their type-approval
requirements when placed on the market and for a limited period thereafter, and so are effectively
focusing on the responsibilities of the manufacturer, the RWP focuses on ensuring that minimum
standards are maintained by owners throughout the lifetime of the vehicle. Also, while market
surveillance requires testing a limited number of vehicles per model, PTI applies to almost all
registered vehicles. Thus, the RWP complements the market surveillance legislation in ensuring road
safety and the environmental performance of vehicles during their lifetime.
Since 20 May 2023, real-world fuel and/or energy consumption data are collected from light vehicles
when they undergo PTI, as required by the rules on on-board fuel consumption monitoring476
. This
is made possible since from that date, all PTI centres are required to be equipped with scan tools
capable of reading out data from the on-board diagnostics of the vehicle. The same kind of data could
also be collected from heavy-duty vehicles (HDVs) undergoing PTI as soon as the corresponding
470
Cf. the various type-approval legislation (Regulation (EU) 2018/858, Regulation (EU) 167/2013, Regulation (EU)
168/2013).
471
World Forum for Harmonization of Vehicle Regulations of the United Nations Economic Commission for Europe.
For example, a proposal has been endorsed in UNECE General Safety Provisions Working Party to introduce odometer
accuracy and anti-tampering provisions in UN Regulation No. 39, 02 series of amendment.
472
https://eur-lex.europa.eu/eli/reg/2018/858/oj
473
https://eur-lex.europa.eu/eli/reg/2019/2144/oj
474
Regulation - 2024/1257 - EN - EUR-Lex
475
For all new vehicle types from 6 July 2022 onwards and for all new vehicles from 7 July 2024, the following safety
features are mandatory: for all road vehicles (cars, vans, trucks and buses) - intelligent speed assistance, reversing
detection with camera or sensors, attention warning in case of driver drowsiness or distraction, event data recorders as
well as an emergency stop signal; for cars and vans - additional features such as lane keeping systems and automated
braking; for buses and trucks - technologies for better recognising possible blind spots, warnings to prevent collisions
with pedestrians or cyclists and tyre pressure monitoring systems.
476
Commission Implementing Regulation (EU) 2021/392 on the monitoring and reporting of data relating to CO2
emissions from passenger cars and light commercial vehicles, https://eur-lex.europa.eu/eli/reg_impl/2021/392/oj
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legislation so requires.
The Commission is also currently working on an initiative on fair and non-discriminatory access to
in-vehicle data477
, which is crucial for technical inspection centres to be able to carry out their daily
tasks. That initiative will complement the Commission’s proposal for the Data Act478
by more
specific provisions on access to functions and resources, essential for the provision of data-dependent
services in the automotive sector. It will standardise the relevant datasets and ensure effective non-
discriminatory and secure access for aftermarket and mobility services. A range of automotive service
providers, including vehicle repair and inspection companies and authorities have called for an
ambitious Commission proposal, to ensure a level-playing field and unhindered access to the relevant
in-vehicle data479
. The revision of the PTI Directive (and of its implementing act on the technical
information necessary for roadworthiness testing480
) could complement the access to in-vehicle data
proposal, through specific provisions facilitating access to the data necessary for technical
inspections.
Further EU legislation relevant for vehicle registration and roadworthiness are the Single Digital
Gateway Regulation (SDG)481
and the Directive on the treatment of end-of-life vehicles (ELV)482
.
The SDG Regulation provides for registering a motor vehicle originating from or already registered
in a Member State among the procedures to be carried fully online, where possible. The
Commission’s proposal to replace the ELV Directive with a Regulation483
aims at linking export
requirements to roadworthiness and relies on more effective and efficient exchange of vehicle
registration data among national authorities, including customs authorities, to address the problem of
missing vehicles. For that purpose, it calls for a proposal to revise the Vehicle Registration
Documents Directive. It specifically suggests that the revision of the VRD Directive should require
electronic recording of data related to the reasons for the cancellation of a registration of a vehicle,
especially if a vehicle has been treated as an end-of-life vehicle in an authorised treatment facility,
re-registered in another Member State, exported outside the Union, or stolen.
In March 2023, the Commission made three other road safety-related proposals, out of which two are
relevant for the revision of the RWP, namely the revision of the Directives on driving licences and
on facilitating cross-border exchange of information on road-safety-related traffic offences484
.
Coherence will need to be ensured between the rules on vehicle registration documents and the
possible future digitalisation of documents, as well as regards the exchange of vehicle-related
information among Member States for enforcement purposes.
EU legislation on road tolling485
also relies on the harmonised Union codes defined in the VRD
Directive, which were last (slightly) amended as part of the revision of rules on road pricing
477
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-functions-
and-resources_en
478
https://ec.europa.eu/commission/presscorner/detail/en/ip_22_1113
479
See e.g. open letter from CITA: https://citainsp.org/wp-content/uploads/2023/03/L2023-006-Data-Act.pdf
480
https://eur-lex.europa.eu/eli/reg_impl/2019/621/oj
481
https://eur-lex.europa.eu/eli/reg/2018/1724/oj
482
https://eur-lex.europa.eu/eli/dir/2000/53/oj
483
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023PC0451
484
COM(2023) 127 and COM(2023) 126 final, https://transport.ec.europa.eu/news-events/news/european-commission-
proposes-updated-requirements-driving-licences-and-better-cross-border-2023-03-01_en
485
Directive (EU) 2019/520 on the interoperability of electronic road toll systems and facilitating cross-border exchange
of information on the failure to pay road fees in the Union, https://eur-lex.europa.eu/eli/dir/2019/520/oj
313
(Eurovignette Directive)486
.
Finally, the EU Decision on the Digital Decade Policy Programme 2030487
foresees that the
European Parliament, the Council, the Commission and the Member States shall cooperate with a
view to achieving digital targets in the Union by 2030. Among those, the digitalisation of public
services, where there is 100% online accessible provision of key public services and, where relevant,
it is possible for citizens and businesses in the Union to interact online with public administrations.
486
Directive (EU) 2022/362 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520, as regards the charging
of vehicles for the use of certain infrastructures, https://eur-lex.europa.eu/eli/dir/2022/362/oj
487
Publications Office (europa.eu)
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ANNEX 17: EVALUATION REPORT (SEPARATE DOCUMENT)
Separate document: Evaluation SWD and specific annexes.