COMMISSION STAFF WORKING DOCUMENT EVALUATION acompanying the Impact assessment report of the 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, Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union, and Directive 1999/37/EC on the registration documents for vehicles

EN EN
EUROPEAN
COMMISSION
Brussels, 26.5.2025
SWD(2025) 98 final/2
CORRIGENDUM
This document replaces SWD(2025) 98 final of 24.4.2025
Insertion of the cross-reference to the COM(2025) 180 final and correction of the title
The text shall read as follows:
COMMISSION STAFF WORKING DOCUMENT
EVALUATION
acompanying 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) 96 final} -
{SWD(2025) 97 final} - {SWD(2025) 99 final} - {COM(2025) 180 final}
Offentligt
KOM (2025) 0180 - SWD-dokument
Europaudvalget 2025
Table of contents
Contents
1 INTRODUCTION ..................................................................................................................1
1.1 Context................................................................................................................ 2
1.2 Purpose and scope of the evaluation ................................................................ 4
1.3 Evaluation methodology.................................................................................... 5
2 WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? .........................5
2.1 Description of the intervention and its objectives........................................... 5
2.2 Points of comparison ....................................................................................... 10
2.2.1 Road safety points of comparison .............................................................. 11
2.2.2 Emissions and air pollutant points of comparison...................................... 12
2.2.3 Other expected impacts .............................................................................. 14
3 HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? .........14
3.1 State of play – transposition and implementation of the Roadworthiness
Package ...................................................................................................................... 14
3.2 Market developments ...................................................................................... 18
4 EVALUATION FINDINGS (ANALYTICAL PART).........................................................21
4.1 To what extent was the intervention successful and why?........................... 21
4.1.1 Effectiveness............................................................................................... 21
4.1.2 Efficiency ................................................................................................... 32
4.1.3 Coherence................................................................................................... 35
4.2 How did the EU intervention make a difference and to whom? ................. 36
4.3 Is the intervention still relevant?.................................................................... 37
5 WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ...................................41
5.1 Conclusions....................................................................................................... 41
5.1.1 Effectiveness............................................................................................... 41
5.1.2 Efficiency ................................................................................................... 42
5.1.3 Coherence................................................................................................... 42
5.1.4 EU added value........................................................................................... 43
5.1.5 Relevance ................................................................................................... 44
5.2 Lessons learned ................................................................................................ 44
5.3 Robustness of the conclusions......................................................................... 45
ANNEX I: PROCEDURAL INFORMATION...............................................................................46
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED.....................................48
ANNEX III. OVERVIEW OF BENEFITS AND COSTS..............................................................51
ANNEX IV. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT..............................53
ANNEX V. INTERVENTION LOGIC..........................................................................................75
ANNEX VI. SUMMARY OF CURRENT LEGISLATIVE FRAMEWORK................................77
ANNEX VII. THE MINIMUM REQUIREMENTS SET OUT IN THE DIRECTIVES AS
EXCEEDED BY SOME MEMBER STATES .....................................................................81
ANNEX VIII. EVALUATION MATRIX AND THE EVALUATION QUESTIONS..................82
GlossaryTerm
or acronym
Meaning or definition
ABS
Anti-lock Braking System. This is an electronic system used which operates by
preventing the wheels from locking up during braking, thereby maintaining
contact with the road surface and allowing the driver to maintain more control
over the vehicle.
ACEA
Association des Constructeurs Européens d'Automobiles (European
Automobile Manufacturers' Association)
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.
BC
Black carbon: a component of fine particulate air pollution (PM2.5). It is formed
by the incomplete combustion of wood and fossil fuels, a process which also
creates carbon dioxide (CO2), carbon monoxide (CO), and volatile organic
compounds. It lasts only days to weeks in the atmosphere but has significant
direct and indirect impacts on the climate and human health.
CARE
CARE is an EU database on road crashes resulting in death or injury. Council
Decision 93/704/EC (on the creation of a Community Database on road
accidents) obliges Member States to provide annual data on road accidents but
does not specify the content. The CARE expert group composed of national
representatives meets 1-2 times per year to discuss issues related to the database
and the variables, as well as the collection, processing and dissemination of data.
CITA
International Motor Vehicle Inspection Committee - an international non-profit
association of authorities and companies involved in vehicle compliance.
CNG Compressed Natural Gas
CO
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
A Certificate of Conformity is a statement by a vehicle manufacturer that the
vehicle conforms to EU type-approval requirements.
DPF
Diesel Particulate Filter is a device designed to remove diesel particulate matter
or soot from the exhaust gas of a diesel engine.
EEA European Environmental Agency
EGR
Exhaust Gas Recirculation (EGR) is a system for reducing automotive nitrogen
oxide (NOx) emissions in petrol, diesel and some hydrogen engines. The high-
pressure EGR loop collects part of the exhaust gases at the cylinder head outlet
and re-injects them into the engine air intake.
EPRS European Parliamentary Research Service
ESC
Electronic Stability Control is an extension of anti-lock braking technology,
which has speed sensors and independent braking for each wheel. It addresses
the problem of skidding and crashes due to loss of control of vehicles,
especially on wet or icy roads or in rollovers.
EUCARIS
European car and driving licence information system. This is an initiative of
several European countries, formalised in a multilateral treaty, and focused on
the data-exchange regarding vehicle registration, driving licences etc.
GHG Greenhouse gases
HMI
Human Machine Interface is a user interface or dashboard that connects a
person to a machine, system, or device. It includes the hardware and software
that is used to translate user input into commands, and to present results to the
user.
ISO International Organization for Standardization
NOx Nitrogen Oxides
OBD
On-board Diagnostics is a computer system in a vehicle that monitors its
performance. It collects information from the network of sensors inside the
vehicle, which the system can use to regulate car systems or alert the user to
problems. A technician can read relevant data through the OBD port to diagnose
problems.
OBFCM
An on-board Fuel Consumption Monitoring Device uses vehicle, engine, fuel
and/or electric energy parameters to determine and make available information
(such as fuel consumption, distance travelled, and speed) and stores the
lifetime values on board the vehicle.
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.
OPC Open Public Consultation
PN and PM
Particle Number measurement, a measure of air pollution, is a method of
measuring particulate emissions, typically expressed as the number of particles
per cm3
. Particulates (or particulate matter – often abbreviated to PM)
are microscopic particles of solid or liquid matter suspended in the air.
PTI Periodical technical inspection
RDE
The Real-Driving Emissions test is part of the type-approval procedure for all
new passenger cars and vans. The RDE test is an on-road emissions test meant
to complement laboratory tests to ensure vehicle emissions are similar during
normal, real-world operating conditions as they are during laboratory testing.
RSI Roadside Inspection
RWP Roadworthiness Package
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 also improves fuel economy and performance of diesel
engines.
TWC
Three-Way Catalytic converter is a device used in the exhaust system to
convert harmful gases in the engine exhaust to relatively harmless gases. It is
called a three- way catalytic converter because it can convert three types of
pollutants simultaneously.
UNECE
United Nations Economic Commission for Europe. One of 5 regional
Commissions of the United Nations, its remit includes transport (including road
safety) and vehicle regulations.
VRD Vehicle Registration Document
1
1 INTRODUCTION
This report presents the findings of the evaluation of the three Directives that together
comprise the Roadworthiness Package (hereinafter the “RWP”). These Directives are: (i)
Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their
trailers, (ii) Directive 2014/47 EU on roadside inspections of commercial vehicles, and (iii)
Directive 2014/46 EU on registration documents for vehicles.
The evaluation is performed “back-to-back” with an Impact Assessment for the possible
review of the RWP. This exercise is in line with the Commission’s Sustainable and Smart
Mobility Strategy1
adopted in 2020 which reconfirmed the Union’s commitment to pursue
improving road safety and the objective of zero road fatalities by 2050. In this context, the
Strategy stated that “Our roadworthiness legislative framework should be adjusted to
ensure the lifetime compliance of vehicles with emission and safety standards.”
Improving road safety is a prime objective of the EU's transport policy. The EU is pursuing
a policy to improve road safety with the objective of reducing fatalities, injuries and
material damage. The EU’s regulatory framework for road safety addresses the core
elements of the Safe System Approach (road use, infrastructure, vehicles and post-crash
care) and combines binding legal acts and recommendations to Member States. The EU
road safety policy also builds on national initiatives, setting targets and addressing the key
factors that play a role in road crashes, supporting public awareness and education
campaigns, helping Member States and other road safety actors share relevant experience.
Over the last 20 years, EU roads have become significantly safer. The number of road
fatalities has gone down by 60% from around 51,400 in 2001 to around 20,600 in 2022.
The 2022 figure represents 2,100 fewer fatalities (-9%) compared with the pre-COVID-19
pandemic year 2019. Nevertheless, the improvement in road safety has not been strong
enough to meet the EU’s political ambition to decrease the number of road deaths by 50%
between 2001 and 2010, and by additional 50% between 2011 and 2020 (i.e. by 75%
between 2001 and 2020). This political ambition stems from a number of strategic
documents issued by the Commission over the last two decades, such as the White Paper
on European Transport Policy for 20102
, the 2011 White Paper on a Single European
Transport Area3
or the Communication from the Commission on Towards a European road
safety area: policy orientations on road safety 2011-20204
. In its Sustainable and Smart
Mobility Strategy of 2020, the Commission committed to target zero fatalities in all modes
of transport by 2050.
In the years before 2020, there was hardly any drop in the number of road fatalities. This
slowdown, that already appeared around 2014, prompted the Transport Ministers to issue
a ministerial declaration on road safety at the informal transport Council in Valletta in
March 20175
, whereby the Member States called upon the Commission to explore the
strengthening of the Union’s road safety legal framework to reverse that stagnating trend.
Against this background, and in the context of the Safe System Approach that focuses on
safe infrastructure, safe vehicles, safe road use and better post-crash care, an important
1
COM(2020) 789 final, 9.12.2020
2
COM(2001) 370 final, 12.9.2001
3 EUR-Lex - 52011DC0144 - EN - EUR-Lex (europa.eu)
4
COM/2010/0389 final, 20.7.2010
5 Valletta Declaration on Road Safety (europa.eu)
2
element of the Union’s efforts to improve road safety is to improve the safety of the vehicle
fleet.
1.1 Context
Various measures have been introduced at EU level since 1977, as Member States had
begun developing their own national regulations regarding vehicle roadworthiness testing,
leading to a lack of harmonisation.
The 2014 Roadworthiness Package
The Roadworthiness Package was presented by the Commission in 2012 as a set of three
legislative proposals. Given their strong thematic interdependence and the alignment of
their specific objectives in the field of road safety, the package approach was considered
to be more effective than dealing and updating each legislation separately.
• Directive 2014/45/EU6
on periodic roadworthiness tests (hereinafter the
"Periodic Technical Inspection or PTI Directive") requires that road transport
vehicles are periodically tested to ensure compliance with a set of minimum
requirements and it applies to all cars, vans, trucks and buses, heavy trailers, faster
tractors as well as, since January 2022, to larger two- and three-wheel vehicles and
quadricycles.
• Directive 2014/47/EU7
on technical roadside inspections (hereinafter the
“Technical Roadside Inspection or RSI Directive) has a similar aim to PTI
Directive, although in relation to roadside inspections of heavy passenger and
freight vehicles and their trailers.
• Directive 2014/46/EU8
on the registration documents for vehicles (hereinafter
the "Vehicle Registration Documents or VRD Directive") provides for the
6
It repeals Directive 2009/40/EC; EUR-Lex - 32014L0045 - EN - EUR-Lex (europa.eu)
7
It repeals Directive 2000/30/EC; EUR-Lex - 32014L0047 - EN - EUR-Lex (europa.eu)
8
It amends Directive 1999/37/EC; EUR-Lex - 32014L0046 - EN - EUR-Lex (europa.eu)
Directive 77/143/EEC on the approximation of the laws of the Member States relating to
roadworthiness tests for motor vehicles and their trailers introduced the requirement that motor
vehicles should undergo periodic roadworthiness tests, identifying the categories of vehicles to
be tested, frequencies, and the items to be tested. This Directive was replaced by Directive
96/96/EC which established common requirements for periodic technical inspections (PTIs),
including testing frequencies, inspection methods, and standards for various vehicle categories.
Directive 2009/40/EC on roadworthiness tests for motor vehicles and their trailers was a recast
of the 1996 Directive and it allowed Member States to apply higher requirements for PTI
concerning, notably, the frequency of testing, the items to be inspected, the vehicles covered or
the minimum standards for braking efficiency.
Directive 2000/30/EC on the technical roadside inspection of the roadworthiness of commercial
vehicles complemented Directive 96/96/EC by providing the requirement to control the technical
state of commercial vehicles in between periodic inspections (roadside inspections).
Finally, Directive 1999/37/EC on the registration documents for vehicles aimed to harmonise
the form and content of the registration certificates issued by Member States and included
provisions concerning the information to be provided in the registration certificates, the process
of re-registration of a vehicle previously registered in another Member State and for exchange of
information and cooperation.
3
electronic recording of data on all vehicles registered on a Member State’s territory,
and harmonised procedures in relation to the suspension of a vehicle’s registration.
A more detailed explanation of the provisions of the RWP Directives is provided in Annex
VI.
The Roadworthiness Package was intended to act complementarily to the safety and
environmental requirements that vehicles must meet to be able to circulate on the EU roads
i.e., the respective EU type approval Regulations9
for motor vehicles. These Regulations
also set out the market surveillance requirements for motor vehicles. The focus of the RWP
is, however, different. EU market surveillance rules for motor vehicles establish
procedures to test vehicles against type-approval requirements with the aim to identify
vehicles (and vehicles components) systematic deficiencies through random checks,
creating in this way a feed-back loop for improving type-approval legislation. The RWP
legislation in force rely instead on regular vehicles checks that focus on ensuring that
minimum standards are maintained by owners throughout the lifetime of the vehicle.
The Commission Implementing Regulation (EU) 2019/62110
, adopted as part of the
roadworthiness acquis, concerns 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. Its main objective is to facilitate roadworthiness testing by
requiring manufacturers to make the relevant technical information available to testing
centres and competent authorities. Although this Implementing Regulation applies since
May 2020, it appears to have only been used to a limited extent. In fact, Member States
and vehicle inspection bodies have reported difficulties in collecting the necessary
information from each manufacturer due to cumbersome registration processes as well as
costs. As a result, some checks have not been performed as legally required.
While this Implementing Regulation does not contain any reporting obligations for
Member States, the latter have repeatedly indicated difficulties to the Commission in
effectively enforcing road safety measures in EU cross-border traffic and vehicle trade.
These mostly have their origin in difficulties for competent authorities in accessing vehicle
register data and other safety-relevant information of vehicles, notably if these are
registered in another Member State. These difficulties also, for instance, may negatively
impact upon attempts to combat odometer tampering which negatively affects road safety
and consumer welfare in the EU.
The introduction of advanced vehicle safety features (mandated by the General Safety
Regulation11
, from July 2022 onwards) and of significantly strengthened emission
legislation is challenging the methods of inspecting vehicles Therefore, changes to current
practices will be needed in future to cope with vehicles becoming technically ever more
9
https://eur-lex.europa.eu/EN/legal-content/summary/eu-approval-and-market-surveillance-measures-for-
motor-vehicles-and-their-trailers.html
10
EUR-Lex - 32019R0621 - EN - EUR-Lex (europa.eu)
11
Regulation (EU) 2019/2144 of the European Parliament and of the Council of 27 November 2019 on type-
approval requirements for motor vehicles and their trailers, and systems, components and separate technical
units intended for such vehicles, as regards their general safety and the protection of vehicle occupants and
vulnerable road users; EUR-Lex - 32019R2144 - EN - EUR-Lex (europa.eu)
4
complex and emissions standards requiring lifelong monitoring. In that context, accessing
vehicle data will become even more critical to perform roadworthiness checks.
Laboratory tests indicated that even vehicles with defective or tampered diesel particulate
filters (‘DPF’) can pass the opacity test, without the malfunctioning being noticed. An
alternative to the opacity test would be to count the particles that are emitted using optical
methods. Such an approach would be able to reliably detect a defective or tampered DPF,
but a harmonised EU measurement method was lacking. A first step towards harmonised
particle number (PN) measurement during roadworthiness testing within the EU was made
with the adoption of a specific Commission Recommendation12
. These guidelines were
adopted in March 2023 following the introduction of PN measurement by three Member
States and to achieve a minimum degree of harmonisation in PN measurement methods in
the EU. Member States can therefore integrate the requirements set in the
Recommendation into their PTI regimes. The test methods required by the PTI Directive
as regards exhaust emissions of motor vehicles, notably the opacity testing applicable to
compression ignition engines, were found not anymore adapted to more recent vehicles
equipped with particle filters.
1.2 Purpose and scope of the evaluation
The evaluation of the Roadworthiness Package aims to assess the performance of the
substantive provisions of the three Directives, to analyse if the framework is consistent
with relevant safety, environmental and internal market objectives and to determine if it is
still fit for purpose.
Both the PTI and the RSI Directives contain a reporting requirement for the Commission
on the implementation and effects of the Directives. Member States reporting obligations
are only foreseen in the RSI Directive. However, these Directives have only applied since
2018, and in order to generate data to draw meaningful conclusions, in particular their
effect in terms of improvement of road safety, it was considered that a reasonable period
of time should have elapsed. The Commission has therefore prepared reports providing an
overview of the implementation actions of the Member States based on the preliminary
findings of the transposition control13
This evaluation covers all EU Member States and is based on evidence available for the
period between 2018 and 202114
. The evaluation addresses the five evaluation criteria:
effectiveness, efficiency, coherence, relevance, and EU added value, for each of which
dedicated evaluation questions were defined. The evaluation systematically reviews and
analyses all available evidence, from a variety of sources. The evaluation was developed
with the support of an external support study15
and in line with the Better Regulation
Guidelines and Toolbox. The methodology is detailed in Annex II, while Annex III
presents the evaluation matrix which was elaborated to answer the evaluation questions.
12
Commission Recommendation (EU) 2023/688 of 20 March 2023 on particle number measurement for the
periodic technical inspection of vehicles equipped with compression ignition engines
13
COM (2020) 699 final and COM (2020) 107 final
14
Data on implementation for 2022 are not complete yet.
15
The evaluation support study was prepared in 2022-2023 by a consortium led by VVA and including TML,
TNO, VUFO and the University of Leeds. The study will be published alongside this evaluation.
5
1.3 Evaluation methodology
Against this background, the Commission has carried out the evaluation of the three
Directives. In line with the Better Regulation Guidelines, this evaluation analyses:
- Effectiveness: assesses the extent to which the three Directives triggered the actual
changes, in particular in view of original objectives of improving road safety,
contributing to the reduction of the emissions of GHG and air pollutants from road
transport, and facilitating free movement for EU citizens and the smooth
functioning of the Internal Market.
- Efficiency: assesses the actual costs relative to the actual benefits of the
implementation of the three Directives, whether there is potential for simplification
and increasing cost-efficiency.
- Coherence of the regulatory framework of the three Directives, regarding both the
internal coherence and the external coherence with other relevant EU legislation
and policies.
- Relevance: assesses whether the overall problem analysis and related objectives
are still adequate and how the policy context has evolved. It also analyses the
relevance of the Directives for current and future needs, in light of the
technological, environmental, and scientific advances.
- EU added value: assesses the value of the three Directives, for citizens and
businesses, compared to what could have been achieved by Member States at
national and/or regional and international level without these Directives.
The following sources of information were used for this evaluation:
• Information from stakeholder consultation activities which included an online
public consultation, targeted surveys, and interviews;
• A review of existing literature on the effects of technical inspections and their
correlation with the evolution of the number of road crashes, as well as on emission
control technologies and tampering practices; and
• European Commission’s CARE Database, Member States’ reports from roadside
inspections.
2 WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION?
2.1 Description of the intervention and its objectives
In 2010 the European Commission adopted policy orientations on road safety16
, where it
proposed amongst other things a two-pronged strategy for safer vehicles:
harmonisation/strengthening of EU legislation on roadworthiness tests and on technical
roadside inspections to help reaching the announced road safety target (i.e. reducing the
number of road fatalities by 50% between 2010 and 2020). The 2012 Commission proposal
built on requirements included in the previous Directives related to the roadworthiness
16
Communication from the Commission to the European Parliament, the Council, the European Economic
and Social Committee and the Committee of the Regions, Towards a European road safety area: policy
orientations on road safety 2011-2020, COM(2010) 389 final.
6
tests, roadside inspections, and rules on the registration documents of vehicles (briefly
introduced in section 1.1).
The EU regime in place before the adoption in 2014 of the RWP set minimum standards
for roadworthiness testing across the EU. Before a vehicle was allowed to be put on the
market, it had to fulfil all the relevant type or individual approval requirements
guaranteeing an optimal level of safety and environmental standards. Every Member State
had the obligation to register for the first time any vehicle that had EU type-approval on
the basis of a “Certificate of Conformity” issued by the vehicle manufacturer. Registration
of a vehicle provided administrative authorisation for a vehicle's’ entry into road traffic.
Registered vehicles had to be regularly submitted to periodic roadworthiness tests, aiming
to ensure that they remain roadworthy.
According to the impact assessment17
, the Commission's 2012 legislative proposals aimed
to tackle the problem of too many vehicles with technical defects still present on EU roads,
despite the existing legal framework. The immediate consequences of this problem were
accidents, injuries, fatalities, as well as environmental damage, in particular air pollution.
Two main underlying problem drivers were identified: (i) the scope of EU legislation was
too narrow and the level of requirements it sets were too low; and (ii) the relevant
information and data were not exchanged between the concerned actors.
In this context, the RWP aimed to contribute: (1) to increased road safety (halving fatalities
by 2030 and moving to zero fatalities by 2050) by increasing the quality and better
coordinating national PTI and roadside inspection systems and (2) to the reduction of
greenhouse gas and air pollutant emissions from road transport by detecting more
effectively and removing from circulation vehicles which are over-polluting because of
technical defects.
The impact assessment identified the following two specific objectives:
(1) Increase the scope and the level of requirements for roadworthiness testing and
roadside controls across the European Union;
(2) Create the appropriate framework for a seamless flow of information between
actors and Member States involved in the enforcement of PTI results.
While not specifically stated in the impact assessment, the revision also had the objective
of facilitating the free movement of EU citizens and the smooth functioning of the internal
market, by including explicit references to free movement in recitals 1, 3, and 8 of VRD
Directive, and in recital 24 and Article 10 of PTI Directive. With the increase in cross-
border vehicle movements within the EU, there was a need for more harmonised and
rigorous roadworthiness standards to ensure that vehicles moving across borders met the
same safety criteria. The RWP intended to create a common and harmonised framework
for roadworthiness control, including common requirements for technical checks,
equipment, knowledge and training of inspectors and cooperation between Member States.
It also aimed at reducing the administrative burden through general data exchange (based
on collaboration among national contact points (NCP) and mutual recognition of
roadworthiness certificates (RWCs).
To meet the objective to enhance the safety of vehicles on the road, the minimum EU
standards for periodic roadworthiness tests (PTI) were strengthened and mandatory
standards were introduced, together with the introduction of random roadside inspections
17
Register of Commission Documents - SWD(2012)206 (europa.eu)
7
(RSI). This was seen as essential to avoid reducing the effectiveness of roadworthiness
enforcement. To meet the objective of making the necessary data for and from
roadworthiness testing available, the PTI Directive also encourages cooperation and
information exchange among Member States including records of roadworthiness tests.
In several Member states a high number of private authorised test centres were carrying
out roadworthiness tests (and still do). To ensure a coherent approach, certain common
procedures such as frequency of testing were specified in the legislation.
In contrast to the PTI and RSI Directives, there was a limited number of changes made to
the 1999 Vehicle Registration Documents Directive in Directive 2014/46/EU, perhaps
reflecting the fact that this Directive has a relatively limited scope, given that vehicle
registration itself is a responsibility of Member States. The main changes introduced in
Directive 2014/46/EU were (i) providing for electronic recording of data on all vehicles
registered on a Member State’s territory, and (ii) harmonised procedures in relation to the
suspension of a vehicle’s registration.
The expected result from the revision of the three Directives was more detection of defects
and reduction of the number of “gross emitting” vehicles and vehicles with dangerous
defects in circulation. Also, overall consistency, objectivity, and quality of the testing
throughout the EU was expected to be improved, as well as the framework for exchange
of information between actors and Member States involved in the enforcement of testing
results.
A figure representing the intervention logic of the RWP is presented in Annex VI. It
summarises the links and causal relationships between the problems and needs. It takes
into consideration the general and specific operational objectives that the legislative
framework was designed to address and presents the expected outputs, results, and impacts.
Directive 2014/45/EU on the periodic roadworthiness tests compared to its predecessor,
Directive 2009/40/EC:
• Addressed the quality of vehicle tests by setting common minimum standards for
equipment, training of inspectors and assessment of deficiencies.
• Made electronic safety components (such as anti-lock braking system (ABS),
electronic stability control (ESC) and airbag) subject to mandatory testing.
• Introduced measures to combat odometer fraud.
• Made compulsory EU wide testing for heavy motorbikes, with a possibility for
Member States to introduce effective alternative road safety measures instead.
• Foresaw compulsory EU wide testing of high-speed tractors used for commercial
road haulage purposes;
• Provided for mutual recognition of the roadworthiness certificate during the re-
registration procedure, where the frequency of testing is the same in the Member
State of origin and in the Member State of destination.
Directive 2014/47/EU on the technical roadside inspection of commercial vehicles
compared to its predecessor, Directive 2000/30/EC:
• Addressed the quality of vehicle tests by setting common minimum standards for
equipment, training of inspectors carrying out more detailed inspections, the
assessment and follow-up of deficiencies;
• Extended the risk rating system of road transport undertakings, with information
based on the technical roadside inspection;
8
• Relied on a two-step approach for the roadside inspections by introducing the initial
and more detailed inspection;
• Introduced measures for the inspection of cargo securing;
• Added compulsory EU wide testing of high-speed tractors used for commercial
road haulage purposes.
Directive 2014/46/EU on vehicle registration documents introduced the following new
requirements compared to its predecessor, Council Directive 1999/37/EC:
• An obligation for Member States to record electronically data on all vehicles
registered on their territory;
• An obligation for Member States to record electronically the suspension of a
vehicle’s authorisation after a failed PTI, and to notify it to the vehicle registration
authority. This suspension is effective until the vehicle has passed a new
roadworthiness test. Upon successful completion of the roadworthiness test, the
competent authority has to re-authorise the use of the vehicle in road traffic without
delay, and with no need of new registration;
• An obligation for Member States to assist each other in the implementation of the
Directive, in particular to check, before any re-registration of a vehicle, the
vehicle's legal status in the Member State in which it was previously registered.
Such checking may involve the use of data from national databases to facilitate the
exchange of information.
There are some significant differences between what the Commission originally proposed
in 2012, and the measures included in the legal text of 2014 Directives. Some of the
measures originally proposed in the Commission’s 2012 proposals were not included in
the final legal texts (see Tables 1 to 3 below). It should also be noted that the Commission
originally proposed Regulations for PTI and RSI, whereas the final legal texts took the
form of Directives. In addition, the Commission’s proposals would have applied from
2015, whereas the final agreed texts applied from 2018.
9
Table 1. PTI: Comparison between COM’s proposal in 2012 and adopted directive of 2014
Table 2. RSI: Comparison between proposal of 2012 and adopted directive of 2014
Topic Vehicle Category Commission Proposal of
2012 for a Regulation
Adopted Directive of 2014
Test
intervals
M1 (passenger car) and N1 (light
truck)
Initial test after 4 years,
next after a further 2
years, then annually
Initial test after 4 years,
then every 2 years
O2 (trailer 0.75 to 3.5 tonnes) Initial test after 4 years,
next after a further 2
years, then annually
Omitted
L1e, L2e, L3e, L4e, L5e (two- and
three-wheeled vehicles, i.e.
motorcycles), L6e and L7e
(quadricycles)
Initial test after 4 years,
next after a further 2
years, then annually
L1e and L2e omitted
L6e (light quadricycles)
omitted
L3e, L4e, L5e and L7e
(motorcycles above 125cc
and heavy quadricycles) to
be included from 1 Jan 2022
with the Member States
deciding the test frequency
and with the possibility of
exemption for Member
States adopting effective
alternative measures
M2 (minibus), M3 (bus), N2
(medium truck), N3 (heavy truck),
T5 (agricultural vehicle with a
maximum design speed of more
than 40 km/h), O2 and O3 (trailers
over 3.5 tonnes)
Initial test after 1 year,
then annually
As proposed, except that
first test for T5 category to
be after 4 years with
subsequent tests every 2
years
Major
deficiencies
Retest within no more
than 6 weeks
Retest within no more than
2 months
Dangerous
deficiencies
Requirement of
withdrawal of vehicle
registration until
rectification
The Member State or the
competent authority may
decide that the vehicle in
question is not to be used
on public roads and that the
authorisation for its use in
road traffic is to be
suspended for a limited
period of time, without
requiring a new process of
registration
Topic Commission Proposal of 2012 for a Regulation Adopted Directive of 2014
Vehicle categories
included
Light commercial vehicles (category N1) and their
trailers (categories O1 and O2) to be included
No requirement to include light
vehicles and their trailers.
Only buses and coaches (categories
M2 and M3), trucks (N2 and N3) and
trailers of over 3.5 tonnes (O3 and
O4), as well as tractors used for
commercial road haulage and capable
of over 40 km/h (T5) are included.
High-risk profile Inspectors shall select as a priority vehicles operated
by undertakings with a high-risk profile
optional
10
Table 3. VRD: Differences between proposal of 2012 and adopted directive of 2014
It is reasonable to assume that if all of the Commission’s proposals had been included in
the final texts, then this would have led to fewer dangerous/defective vehicles in
circulation, and hence fewer accidents and fatalities. This can be assumed particularly in
relation to the Commission’s proposals for (i) the earlier proposed date of application of
the measures, (ii) the wider scope of vehicles to be tested at PTI and RSI, (iii) more frequent
PTI testing of older vehicles, and (iv) the greater repercussions for a vehicle failing at PTI
or RSI.
2.2 Points of comparison
Before the adoption of the Roadworthiness Package in 2014, the requirements of EU
legislation in this area were set below what was perceived as an adequate scope; moreover,
most Member States have had set national requirements for several elements of the
roadworthiness system at a level, which was higher than required by EU legislation. This
led to a heterogenous transposition of the PTI Directive 2009/40/EC (predecessor of
Directive 2014/45/EU) into national legislations. For example, because of this situation
Member States often refused to recognise the certificates for roadworthiness tests issued
by other Member States for re-registration purposes and required a new test to be
performed according to national rules.
Also, information and data vital for the effectiveness of testing and enforcement of test
results was not exchanged between concerned actors even if, during PTI and roadside
inspections, an important amount of data on the vehicle and its performance was collected.
This data could be used by the different authorities to ensure the follow up of the detection
of defects, to organise targeted checks, but also to improve the policy measures in this
domain. For PTI and roadside inspections, enforcement authorities did not have access to
information on the history of the vehicle and its technical characteristics, even if data was
available in the national registers. Lack of provisions in EU legislation about the exchange
of PTI-relevant data did not allow the effective flow of data to and from PTI centres and
enforcement authorities.
Without further intervention at EU level, the implementation of the policy measures in
Member States would have continued to diverge with a possible negative impact on
roadworthiness, and consequently road safety and environment. Overall, it was expected
that the downwards trend in fatalities would be maintained, while the share of accidents
caused by technical defects would likely rise. On the environment side, GHG emissions
were expected to reduce due to the gradual withdrawal of older vehicles. But this has been
Topic Commission Proposal of 2012 for a Regulation Adopted Directive of 2014
Registration
withdrawal in
case of
dangereous
deficiencies
The original proposal stated that: “In cases where
dangerous deficiencies have been found during a
roadworthiness test, the registration should be
withdrawn by the competent authorities until the
vehicle has passed a new roadworthiness test.”
“In cases where dangerous
deficiencies have been found
during a roadworthiness test and
the authorisation of a vehicle for
use on public roads has been
suspended, that suspension
should be recorded until the
vehicle has passed a new
roadworthiness test.” Therefore
according to the final version, full
re-registration would not be
required
11
more than compensated by increasing transport activity (and an increase in the average
mass of vehicles). However, the impact on air pollution would have become proportionally
higher. It was also expected that the number of cross-border re-registrations of vehicles in
the EU would increase up to 2050, which would increase the magnitude of the problems
related to the absence of exchange of data between the authorities and the testing centres
in different Member States.
2.2.1 Road safety points of comparison
In 2011, at the beginning of the period over which the EU aimed to halve road deaths, there
were 28,750 fatalities on the roads of the EU27. By 2022, that number was 20,640,
equivalent of a 28.2% reduction on the 2011 figure (and a 14.8% reduction on the 2013
figure of 24,230). The 2014 Roadworthiness Package was one of a series of actions at EU
level intended to help deliver the targeted reduction. The Impact Assessment for the RWP
estimated that it would lead to a yearly reduction of 38,447 in the number of accidents and
allow avoiding 1,282 fatalities per year. The measure with the greatest expected effect was
more frequent testing of older vehicles (not included in the final agreed text of the
Directive). Performance testing of electronic safety systems was expected to have the
potential to save an important number of additional lives. The monetised social benefit
arising from the reduction in accidents, saving of lives and avoided injuries was estimated
at EUR 5,122 million per year. The reduction in congestion resulting from the reduced
number of accidents translated into an additional saving of EUR 192.5 million per year.
Additional road safety benefits but which could not be quantified were identified, such as
the requirement to make targeted roadside inspections for commercial vehicles, with the
obviously badly maintained vehicles being inspected in priority. This was expected to have
a positive impact on the effectiveness of RSI in taking off the roads vehicles with defects.
Furthermore, positive impact on road safety was also expected by extending RSI to other
categories of vehicles than commercial vehicles and setting a minimum target of 10%
commercial vehicles undergoing RSI in any given year. Higher training requirements for
the inspectors involved in roadworthiness testing and additional requirements on the
supervision of PTI centres were also expected to bring positive and significant impacts in
terms of an increased rate of detection of defects during tests.
The establishment of a data exchange system was expected to bring better enforcement of
roadworthiness test results by the national authorities. For example, police forces and
roadside inspectors would have easier access to roadworthiness related data which are
needed to detect and fine non-compliant drivers. Finally, the availability of data from the
Certificate of Conformity and the PTI should have improved the functioning of the re-
registration process for vehicles originating from another Member State.
There is ample literature to support the argument that roadworthiness measures have a
positive safety impact. For example, the cost-benefit analysis conducted in the
AUTOFORE project18
calculated that defects in passenger cars would be responsible for
43,536 injury crashes across 10 Member States in 2010 and that older vehicles would be
over-represented in this problem. A recent US study19
concluded that states that have
periodic safety inspection regimes had 5.5% fewer traffic fatalities per 100,000 registered
passenger vehicles over the period from 1980 to 2015 than the US States that did not have
18
Study part-funded by the European Commission, conducted by a CITA-led consortium, to examine options
for roadworthiness enforcement, 2007, available at: https://citainsp.org/studies/autofore-2007/
19
https://ascelibrary.org/doi/10.1061/JTEPBS.TEENG-7320
12
such regimes. The study also concluded that the relationship was causal – i.e. inspection
was responsible for those reduced fatalities. It can be observed that this estimated reduction
of 5.5% is similar in size to the 4.4% reduction expected in the 2012 Impact Assessment,
even though the former is an estimation for a change from no PTI at all to PTI, whereas
the latter is a prediction for the outcome of an improvement in the operation of PTI and
RSI.
The Impact Assessment observed that those Member States with a poorer performance on
road safety also tended to be the ones with a lower level of stringency in PTI, while
Member States with a better performance in road safety tended to exceed the then
minimum standards for PTI. Thus, it concluded that a higher minimum standard would
improve overall performance in EU road safety.
Since periodic technical inspections have been in place in the EU for decades for the most
important vehicle categories, the number of recent studies comparing the before and after
(or with PTI and without PTI) situation within the EU is limited. What is available relates:
(a) to the vehicle categories that are only inspected by some of the Member States or for
which PTI has only been introduced recently (such as mopeds and trailers) (20
), or (b) to
non-EU countries, e.g. differences between US States (21
) and the evolution of the situation
in Costa Rica or Turkey (22
).
2.2.2 Emissions and air pollutant points of comparison
The positive environmental impact of the 2014 RWP was primarily expected from more
frequent testing of vehicles and extended scope of tested vehicles, which should have
allowed a higher detection level of big polluters. It was estimated that this would lead to a
decrease in the overall yearly CO2 and NOx equivalent emissions of road vehicles in the
EU by 2%. In absolute terms, this would correspond to approximately 18.2 million tons
CO2 and 6,979 tons of NOx equivalent per year. These were translated into annual
monetary savings of EUR 545 million and EUR 30.7 million respectively. However, these
estimated emission reductions did not materialise because the measures upon which these
estimates were based, principally more frequent testing of passenger cars (annually after 6
years) were not included in the final agreed text of the Directives.
In addition, the testing of emissions using on-board diagnostics (OBD) should ease the
process and therefore reduce the costs of testing for PTI centres and for the drivers, but
available evidence did not suggest that it would increase the rate of detection of defects.
There was also positive environmental impact expected in terms of reduced noise, thanks
to removing vehicles with technical defects from circulation, however this was not
quantified in the 2012 Impact Assessment.
(20
) Study on the inclusion of light trailers and two- or three-wheel vehicles in the scope of the periodic
roadworthiness testing, https://citainsp.org/wp-content/uploads/2019/02/LO.pdf
(21
) https://ascelibrary.org/doi/10.1061/JTEPBS.TEENG-7320
(22
) 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
13
Despite the increase in car transport by 18% and freight transport by 22% from 2000 to
2019 the emissions of road transport have decreased substantially23
. Emission control
technology and type-approval have been effective in reducing the overall emissions.
Hence, ensuring that emission control systems remain in a proper state has become
increasingly important. Road transport was, and is, a major contributor of nitrogen oxides
(NOx) in the air, but the continuing decrease is the result of successive and effective
European vehicle emission legislation (see Figure 1 below).
Figure 1. The continuing reduction of emissions from road transport.
*Legend: NOx =Nitrogen Oxides ; BC=Black Carbon : CO=Carbon Monoxide
Source: EEA
Therefore, as noted in the Commission’s 2012 Impact Assessment, the effect of defects
will increase in the overall context of decreasing carbon dioxide (CO2) emissions and air
pollution. However, the 1.2% to 5.7% increases in emissions estimated by the impact
assessment in the absence of the RWP, due to lower detection of technical defects, are
conservative estimates., The common understanding of acceptable deterioration of
emission control technologies, as estimated in type-approval legislation, is much larger.
Typical increases are 10% to 30% in emissions due to gradual deterioration, notably of
catalysts, over the useful life. This is the order of magnitude expected as well for the effect
of roadworthiness testing on emissions.
At the time, in 2012, it was highlighted that an unnoticed defect could lead to a twentyfold
increase in emissions on vehicles. However, the impact on the overall emissions – i.e. 1%
vehicles with a defect would increase emissions by 20% – could not be factored in
properly, as older, less clean vehicles still dominated the total emissions (although not the
fleet composition).
The new emission control technologies in vehicles developed since 2010 all have their own
strengths and weaknesses. In 2008, the first SCR (selective catalytic reduction) systems
were used on heavy-duty vehicles, and on light-duty diesel vehicles a string of after-
treatment technologies was introduced, with Euro-6 from 2014 onwards. The technical
23
https://www.eea.europa.eu/ims/emissions-of-air-pollutants-from
14
requirements for inspection, specifically relating to the functioning of the after-treatment
technologies, did not anticipate the technological advancements. Therefore, the defects of
these advanced technologies likely remained undetected during periodical technical
inspections and roadside inspection, as neither the technology, nor the possible testing was
addressed beyond the most generic formulation. In that respect, the RWP relied on the fact
that appropriate servicing of a vehicle would find defects and enforce their repair. In
practice, without incentives, vehicle owners would not consider repairs, which will not
affect the normal vehicle usage and are not legally required. The increasingly stringent
type-approval emission requirements on vehicles, both in terms of emission limits and test
protocols, had not been integrated into the roadworthiness requirements. Without
addressing the specific problems with modern technologies in the roadworthiness
legislation, there is no basis to check its functioning. The undetected defects can lead to
substantial increases in emissions, with a possibly significant impact, even with a small
fraction of undetected defects.
The 2014 RWP did not take into account the rapidly changing target, with each next
generation of vehicles achieving lower emissions. This has led to a situation where
emission tests became outdated, and the effectiveness of onboard diagnostics (OBD) is not
currently tested in PTI. The moving target has become more apparent with the scrappage
of most polluting pre-Euro-1 vehicles, for which the PTI was suitable, which have almost
completely been removed from the road since 2020, as even the most robust pre-Euro
vehicles do not last more than 30 years in normal use. Hence, although the 2012 Impact
Assessment noted the changing landscape with more complex and effective emission
control technologies, it did not identify the risk of undetected defects specific for these
technologies, and the consequent gap between type approval and roadworthiness emission
levels.
2.2.3 Other expected impacts
In addition to positive impacts on road safety and environment, the revised RWP also
introduced the requirement for PTI centres to report the odometer readings of tested
vehicles. These readings should be collected at Member State level, thereby helping to
combat more effectively the mileage fraud, which was distorting the second-hand car
market. The effects were expected to be positive and significant, but not assessed in
quantitative terms. Furthermore, the establishment of a system for data exchange was
expected to reduce the administrative costs of complying with the PTI requirement for
vehicle owners and reduce the administrative procedures for authorities and PTI test
stations. This was expected to be achieved through a replacement of manual procedures
with electronic data input and exchange.
3 HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD?
This section explains the state of play in implementing the Directive and presents what has
happened over the evaluation period in relation to the objectives of the 2014 RWP.
3.1 State of play – transposition and implementation of the Roadworthiness
Package
All three RWP Directives stipulated that Member States must transpose the measures by
20 May 2017, and that the Directives apply from 20 May 2018, though some provisions
envisaged phased application.
15
The Commission has concluded its compliance assessment of the three Directives, based
on information submitted by Member States. This compliance check indicates that no
Member State has correctly and completely transposed and communicated every provision
of all three Directives. Given that Member States had until 2017 to notify their
transpositions, it is likely that in some instances, Member States have modified their
legislation since 2017 to comply more fully with the Directives. Therefore, the
Commission is currently liaising with the Member States to seek clarification on every
item that does not appear to have been correctly transposed or communicated.
However, it should be noted that the Commission has not been made aware of any systemic
failure of any Member State to transpose the provisions of the RWP.
In relation to the PTI Directive, the information gathered during the evaluation indicated
that most Member States have adopted at least the minimum requirements for vehicle
testing frequency, with some even introducing more frequent checks, particularly for
passenger cars and light commercial vehicles. For example, the PTI Directive requires that
passenger cars are subject to a PTI test at the latest 4 years after the first year of registration,
and thereafter at least every two years (i.e., a regime of 4-2-2-2- etc.). About half the
Member States apply such a regime, while the other half have a stricter regime. For
example, Croatia and Latvia require that a PTI be conducted for passenger cars after two
years and annually thereafter; Germany and Lithuania require a PTI to be conducted 3
years after first registration and every two years thereafter, while Austria, Bulgaria and
Poland require the first PTI to be conducted after 3 years after, then after a further two
years, and annually thereafter. Table 4 presents an overview of the frequency of PTI in EU
Member States.
Table 4. Frequency of PTIs by Member State, for passenger cars (unless otherwise
indicated)
Country Frequency Conducted by Country Frequency 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- or
motorcycles: 2-2-
2-2-
B & C & D
Germany 3-2-2-2- B Malta 4-2-2-2- B
Denmark 4-2-2-2- B 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
B
16
months – 14
months
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
The content and method of these tests are generally harmonised across Member States,
adhering to a minimum list of required items. In cases where major deficiencies are found
during roadworthiness tests, most Member States stipulate a one to two-month period for
a follow-up test. All Member States have instituted minimum competence requirements
for PTI inspectors, including routine training and sometimes requalification exams with a
given frequency.
Regarding the extension of the scope by the 2014 revision, the inclusion of high-speed
tractors (with design speed over 40 km/h) and two- and three-wheel vehicles appear to
have posed a problem for some Member States. I In relation to the vehicle categories
already covered by the PTI Directive, only minor discrepancies have been found.
It seems that agricultural vehicles are in general not registered in some Member States24
,
which made the introduction of periodic testing for these vehicles challenging. The
periodic testing of two- and three- wheeled vehicles was due from 1 January 2022, though
many Member States were late with the adoption and notification of the transposing
national measures. The broad and imprecise definition of “alternative measures” in Article
2(2) of the PTI Directive, which is open to interpretation by Member States25
, was also an
issue.
Concerning the measures related to the mutual recognition of roadworthiness certificates
in the case of re-registration of a vehicle already registered in another Member State, in
the majority of the Member States the transposition has been satisfactory. Most Member
States made use of the optional measure to verify, in cases of doubt, the validity of the
roadworthiness certificate.
Regarding odometer fraud, the 2020 report on the implementation of the PTI Directive26
showed that the measures requiring Member States to ensure that the odometer data
recorded at the previous roadworthiness test was made available during the next inspection,
have been transposed without major problems. However as regards the obligation to
introduce effective and dissuasive penalties when an odometer is found to have been
manipulated, it seems that the national measures are in many cases rather generic, not
specifically aimed at odometer fraud.
24
Note: In the absence of EU legislation, it is a national competence to decide which vehicles are registered
and consequently issued a vehicle registration document and licence plate(s).
25
Some Member States take it to mean improved road infrastructure, others take it to mean roadside
inspections for motorcycles.
26
COM (2020) 699 final
17
In relation to the VRD Directive, the evaluation found that national legislation in most
Member States mandates the electronic record-keeping of all registered vehicles, including
the results of periodic roadworthiness tests and their validity periods. In all Member States,
a vehicle's suspension is automatically lifted once the identified deficiencies have been
rectified and the vehicle successfully passes a new test.
In relation to the RSI Directive, the information gathered indicates that roadside
inspections for commercial vehicles are carried out in varying numbers by Member States,
. The selection of vehicles for initial roadside inspections can be based on the risk profile
of the transport undertaking, although random selection is implemented in several
countries. The method of selection i.e., random versus targeted, naturally has a very
significanteffect on RSI failure rates. In all Member States, if a vehicle is found with major
or dangerous deficiencies during an inspection, its use is restricted. In the case of dangerous
deficiencies, which require immediate rectification, the vehicle may only be driven to the
nearest workshop for repair, provided that immediate risks to the vehicle's occupants or
other road users have been mitigated. According to the 2020 report on the implementation
of the RSI Directive27
, the inclusion of high-speed tractors was challenging for some
Member States. The report also indicated possible problems in several Member States
concerning the extension of the risk rating system with the information stemming from the
technical roadside inspections. On the other hand, the majority of the Member States have
introduced the optional measures of the Directive concerning the selection of vehicles. The
two-stage approach to inspecting, i.e., the introduction of the separate initial and more
detailed technical roadside inspections proved challenging in practice. It seems that the
clear separation of the two stages has not been introduced in some Member States, which
may raise further questions such as regarding the data collection, the reports of the more
detailed roadside inspections, or the training of inspectors. Also, the new obligation on the
collection of different sets of information after initial and more detailed inspections seems
to have been challenging for some Member States. Only a few Member States appear to
have introduced the optional measures to require the payment of a fee linked to carrying
out the inspection where defects have been found during the more detailed inspection.
During this evaluation, the Commission contacted Member States to assess the extent to
which Member States had exceeded the minimum requirements in the Directives. The
responses indicated that some Member States have exceeded the minimum requirements
set out in the Directives, including, but not limited to, the scope of vehicles to be subject
to PTI and RSI, and the frequency of PTIs (please see Annex VIII for more details).
In addition, Commission Delegated Directive 2021/171628
amended the RSI Directive as
regards modifications to the vehicle category designations stemming from amendments to
the type-approval legislation. Commission Delegated Directive 2021/171729
amended PTI
Directive as regards the updating of certain vehicle category designations and the addition
of eCall to the list of test items. For both Delegated Directives, the most common
transposition issues have been the non-communication of the transposition measures, and
the absence of a reference to the Directives in the national measures.
27
COM (2020) 676 final
28
EUR-Lex - 32021L1716 - EN - EUR-Lex (europa.eu)
29
EUR-Lex - 32021L1717 - EN - EUR-Lex (europa.eu)
18
The European implementation assessment of the European Parliamentary Research
Service (EPRS), from 202030
indicated that the transposition of the RWP at national level
has led to improved harmonisation of procedures, such as the frequency and content of
vehicle testing, and the provisions of the RWP Directives have enhanced the quality of
periodical technical inspections and roadside inspections, as well as road safety standards.
The report indicates that it is too early to analyse the effectiveness, the efficiency, the
relevance, and the EU added value of the package, but the coherence has been analysed.
The report found that the RWP measures are coherent with the general objective of
contributing to the achievement of the road safety targets in the 2011 White Paper. The
report points to a number of measures in this is regard, in particular the introduction of
common standards for testing centres, training of inspectors, as well as the provisions on
scope, frequency and the methods for vehicle testing. The report also notes that some
Member States have gone beyond the minimum requirements in relation to scope and
frequency of testing, and that this helps to reduce the number of unsafe vehicles in
circulation.
On the information exchange between Member States, the EPRS report found that 7 of the
21 Member States consulted, had issues in contacting National Contact Points to verify the
roadworthiness certificate, and 6 Member States on the time required to obtain the
document. 12 authorities reported that there is no fixed time limit to keep information in
the database. Furthermore, all the Member States notify the competent authority of the data
collected during vehicle testing, including the odometer readings.
On coherence, the Parliament report only pointed at one potential issue between Directive
2014/45 and Directive 2014/46, referring to the notification and registration of the
roadworthiness certificate. Directive 2014/45 requires the competent authority to notify
the content of the roadworthiness certificate, but Directive 2014/46 only refers to the
outcome of the test, and the validity of the roadworthiness certificate. The report also
pointed that no stakeholders interviewed have raised any internal coherence issue.
3.2 Market developments
Regarding the objective of improving road safety, one of the measures which was expected
to have the greatest effect was more frequent testing of older vehicles, which tend to have
more defects. A study from Spain31
showed that both passenger cars and light commercial
vehicles have increasing failure rates in PTI as they age, with vehicles over 10 years old
experiencing particularly high rates. This was reflected in the crash data, where older
vehicles were more prevalent, often due to issues such as defective tyres, steering, and
brakes. Consequently, addressing this group of vehicles with targeted measures under the
RWP was expected to bring greater benefits in terms of lives saved and injuries avoided.
This is relevant since the vehicle fleet in the EU has been progressively aging. The
proportion of passenger cars aged over ten years increased by 13% from 2016 to 202132
.
30
Implementation of the roadworthiness package: European implementation assessment | Think Tank |
European Parliament (europa.eu)
31
Diaz Lopez et al., 2018, https://www.aeca-itv.com/wp-content/contribucion-itv-seguridad-vial-medio-
ambiente/eng/files/assets/common/downloads/ROADWORTHINESS%20TESTING%20CONTRIBUTIO
N%20TO%20VEHICLE%20SAFETY%20AND%20ENVIRONMENT.pdf?uni=8643c3a2724634911b854
c6080952f96.
32
ACEA Annual report; Evaluation support study (VVA)
19
Increases also occurred for light commercial vehicles (7%) and for medium and heavy
commercial vehicles (11.8%). See Figure 2.
Figure 2. Proportion of registered vehicles in the EU27 aged over 10 years.
* Legend: LCV = light commercial vehicles; MHCV = medium and heavy commercial vehicles
** Note: buses were nor included as a separate category before 2018
Source: ACEA, 2023
In parallel, the average age of the vehicle fleet increased: the average age of passenger cars
in the EU was 10.7 years in 2016, and by the beginning of 2022 it had risen to 12.0 years.33
It could be expected that the problem of vehicle defects — minor, major and dangerous —
would worsen over time, since it has been established that the incidence of such defects
increases with vehicle age.34
The introduction of advanced vehicle safety features mandated by the General Safety
Regulation, (EU) 2019/2144 from July 202235
onwards and of significantly strengthened
emission legislation has led to vehicles in the EU becoming technically ever more complex.
The Regulation mandates the inclusion of safety features such as intelligent speed
assistance, driver drowsiness and attention warning systems, amongst others, in new motor
vehicles. Advanced Driver Assistance Systems (ADAS) will gradually become standard
in all vehicles and road safety will be increasingly dependent on ensuring the correct
functioning of the technologies that assist drivers in performing their driving tasks. These
electronic safety and driver assistance systems are not being tested in the current PTI.
To keep pace with this trend, adaptations in the methods of inspecting vehicles throughout
their lifetime are necessary. These may require fundamentally new approaches in the field
of vehicle testing, taking into account ongoing developments in vehicle automation. Visual
and mechanical vehicle inspections, which are still the predominant modes to date, may
33
Note that the 2016 calculation included the UK, but the 2022 one did not. The ACEA data combines the
registration years for vehicles ten years and older, so that it is not possible to calculate average vehicle age
for 2016 omitting UK registrations.
34
Hudec J., et al. (2021), Examination of the results of the vehicles technical inspections in relation to the
average age of vehicles in selected EU states,
https://www.sciencedirect.com/science/article/pii/S2352146521004695
35
The General Safety Regulation requires that, from 2022, new vehicle types are equipped with these
features, and the features will be mandatory on all new vehicles from July 2024 onwards.
0
10
20
30
40
50
60
70
2016 2017 2018 2019 2020 2021
Percent
over
10
years
old
Car LCV MHCV Bus
20
progressively need to be complemented or even replaced by inspection modes that access
vehicle status and operational data by other means.
Related to this last issue, improved vehicle technologies offer opportunities to enhance PTI
with improved and comprehensive data, but also carry a risk that current testing services
are becoming outdated. The introduction of sophisticated electronic safety and advanced
driver assistance systems have outpaced the existing standardised inspection methods at
PTI. Systems like ADAS require information from manufacturers which is necessary to
electronically access and diagnose them. However, the actual availability of data is not the
only issue. The costs due to the divergence of format of vehicle data necessary to carry out
the inspection is also a problem. The divergence of formats of data and functions across
vehicle brands poses a major obstacle to the development of improved PTI methods. The
limited access by vehicle inspection authorities and authorised entities to the functions
relevant for roadworthiness testing means that the inspection of the safety and driver
assistance systems may not be carried out properly. Hence, expected benefits to prevent
crashes could be negatively impacted. The same applies to pollutant emissions when, for
example, the software integrity of the emission control system cannot be checked in the
absence of access to relevant vehicle functions.
Member States have also repeatedly reported difficulties to the Commission in effectively
enforcing road safety measures in EU cross-border traffic and vehicle trade. These mostly
have their origin in difficulties for competent authorities in accessing vehicle register data
and other safety-relevant information of vehicles, notably if these are registered in another
Member State. These difficulties may also negatively impact upon attempts to combat the
presence on the roads of vehicles with defects or tampered components, which negatively
affects road safety, consumer welfare and environment in the EU.
One of the issues regarding the implementation of the RWP is related to the increasing
roll-out of vehicles with alternative power train technologies (e.g. hybrid and zero-
emission powertrains) which require particular testing methods for their safety- and/or
environment-relevant components. The RWP does not currently provide specific
guidelines for inspecting such vehicles during PTIs. When the current Roadworthiness
Package was adopted in 2014, only around 0.5% of the newly registered vehicles in the
EU were electric, including hybrids and range extended vehicles, whereas by 2022 battery
electric vehicles accounted for 12% of new car registrations36.
The issue may exacerbate
in view of the ambitious EU’s goal of climate neutrality by 2050 which will require having
30 million EVs on the European roads by 203037
.
While air pollutant emissions from road transport have fallen in the past decade in the EU,
in 2022 road transport remained the principal driver of the exceedances of NO2 emissions,
as reported by Member States, with 64% of all reported exceedances linked to dense road
traffic in urban centres and to the proximity to major roads38
. The road transport sector was
also the main source of reported NOx emissions, responsible for 41%, followed by the
energy supply sector at 17%. It is also important contributor to black carbon pollution
(32%), CO emissions (24%) and PM (particulate matter) emissions (20%)39
. The impact
36
Fuel types of new passenger cars in the EU - ACEA - European Automobile Manufacturers' Association
37
Sustainable and Smart Mobility Strategy, COM(2020) 789 final, 9.12.2020
38
EEA, Managing Air Quality in Europe, 2023
39
EEA, Air Pollution in Europe; 2023 reporting status
21
of road transport emissions of NO2 and PM on air quality, especially in urban areas,
remains high, because they take place close to the ground and the dilution effect is lower.
Since 2015, the development of real-driving emissions (RDE) legislation as a key policy
to address high real-world emissions of nitrogen oxides (NOx) from diesel cars led to the
application of new and more sophisticated emission control technologies and independent
verification. The change has confirmed the need to move away from reliance on the vehicle
manufacturer information for checking the actual emissions (such as reading the OBD
instead of tailpipe testing). With Euro 6, the selective catalytic reaction (SCR) technology
has become standard on light-duty diesel vehicles, passenger cars and vans, and the typical
NOx emission levels dropped under the emission limits.
At the same time, the existing EU framework for vehicle inspection (RWP) continue to
rely, to some extent, on manufacturer maintenance information, i.e., on on-board
diagnostics (OBD)), without any possibility to check independently its functioning. On the
other hand, the inspection and surveillance authorities’ tasks and responsibilities were
extended under the new type-approval and market surveillance legislation in 201840
. From
2020 Member States and type-approval authorities have the task of testing independently
and have no longer to rely on certification documents and the industry’s own quality
control systems. The market surveillance authorities received a broader mandate with more
means of enforcement. Among these tasks are the checking of the use of defeat devices in
vehicles, which can increase the emissions disproportionally in normal use, outside the
type-approval tests. The Member States are still adjusting to this new situation.
The need for comprehensive oversight and coordination of activities has been increasingly
recognised since 2018. The Member States have developed their own legislation to deal
with a variety of vehicle emission problems, with national legislation for PTI tests, anti-
tampering, software updates and dealing with car manufacturers. With Euro 4 and (later)
Euro 5 vehicles slowly leaving the vehicle fleet and the uptake of zero-emission vehicles,
it is expected that the GHG emissions as well as air pollution due to road transport will
decrease. However, the issues related to defects and tampering of EGR, particle and NOx
filters will persist, and so will the wear emissions of tyres and brakes. These emissions
would be addressed in the proposed Euro 7 Regulation41
, which is currently in the
legislative process, stimulating new vehicle and brake technologies. Nevertheless, NOx
emissions from road transport remain the main source of NOx pollution as long as vehicles
with internal combustion engines are on the road. Hence, the environmental performance
of vehicles will have to be ensured, notably through adequate roadworthiness testing.
4 EVALUATION FINDINGS (ANALYTICAL PART)
4.1 To what extent was the intervention successful and why?
4.1.1 Effectiveness
This section summarises to what extent the Directives have been successful in (a)
contributing to road safety by increasing the quality and better coordination of national PTI
and roadside inspection systems and (b) helping to reduce greenhouse gases and air
pollutant emissions from road transport through detecting more effectively and removing
40
https://eur-lex.europa.eu/EN/legal-content/summary/eu-approval-and-market-surveillance-measures-for-
motor-vehicles-and-their-trailers.html
41
COM(2022)586, https://ec.europa.eu/commission/presscorner/detail/en/ip_22_6495
22
from circulation vehicles which are over-polluting. In addition, the section also provides
insight into what extent the Directives were successful in the creation of a harmonised
framework for roadworthiness control and vehicle registration, and cooperation between
Member States in this field, which helps the free movement of EU citizens and the smooth
functioning of the internal market.
4.1.1.1 Factors contributing to the road crashes related to the technical status of a
vehicle
While not the most important cause of road crashes, defects of vehicles due to technical
malfunctions and/or inadequate maintenance have been found to be the cause for a small
share of crashes on EU roads. Deficiencies of those vehicles can compromise vehicle safety
and increase the likelihood of occurrence of road crashes and associated injuries. The 2012
Impact Assessment had identified that on average, technical defects are responsible for 6%
of all traffic collisions. In view of the expected overall increase in the number of passenger
cars in use, it was expected that in principle the risk of crash occurrence would also
increase, despite the downwards trend in fatalities. The 2012 Impact Assessment assessed
that it was probable that the share of crashes caused by technical defects would even rise
from the estimated 6%.
A 2021 study42
examined the status of temporarily roadworthy43
vehicles. There was a
significant variation observed among Member States in terms of PTI failures, which may
be due to the variation in the stringency with which testing is applied in selected countries,
and not necessarily that vehicles are less roadworthy in those countries.
Table 5: Average value of temporarily roadworthy and not roadworthy vehicles assessed
by PTI in selected European states in 2019
Countries observed in the study
% of temporarily roadworthy and not
roadworthy in 2019
Poland 2.00
Czech Republic 8.46
Austria 10.14
Slovakia 13.03
Estonia 15.06
Spain 20.66
Germany 20.77
Finland 27.00
Ireland 35.76
42
Hudec J., et al. (2021), Examination of the results of the vehicles technical inspections in relation to the
average age of vehicles in selected EU states,
https://www.sciencedirect.com/science/article/pii/S2352146521004695
43
A vehicle is considered to be “temporarily roadworthy” if the technical inspection is carried out and at
least one major defect is detected, but no dangerous defect is detected. A vehicle is considered "not
roadworthy" if at least one major or dangerous defect is detected on the vehicle. In both instances the vehicle
has failed the inspection test.
23
Latvia 39.97
Source: Ricardo, 2023, Impact assessment support study
The age of a vehicle is an important factor that contributes to the risk of roadworthiness
faults. Studies have consistently shown significantly higher failure rates among older
vehicles, specifically those exceeding 10 years of age. For example, a study from 201844
,
which used data from Spain, found that failure rates in PTI went up with age for passenger
cars and light commercial vehicles, and that failure rates were particularly high for vehicles
more than 10 years old. A similar pattern was found related to crashes, with older vehicles
featuring more frequently due to defective tyres, steering and brakes.
The analysis of the involvement rates of older vehicles in crashes in the period before the
RWP was in place supports the argument that older vehicles pose an extra safety risk: the
analysis comparing the share of involvements in fatal crashes for passenger cars aged 10
years or more with the share of vehicle registrations concluded that those vehicles have a
13% higher involvement than the average for all vehicles. Given that the literature reports
that older passenger cars have considerably lower annual mileage, compared to younger
vehicles, that over-involvement is likely to be about 50% higher when calculated on a per
km basis as opposed to a per-vehicle basis, i.e. to be around 19.5%, which suggests a
substantial extra safety risk for the use of older vehicles45
.
Regarding the role of technical defects in road safety at both EU and national levels there
are various estimations. According to the report from the EPRS in 202046
, technical vehicle
defects are deemed responsible for around 5% of accidents involving goods transport
vehicles while poor maintenance causes about 4% of accidents for road users. The most
comprehensive studies on the subject show that vehicle defects are a contributing factor in
6.5% to 12.6% of traffic crashes; for motorcycles, it is 5% to 12% of accidents47
. Technical
faults were registered as a cause or contributing factor in 3% of traffic collisions in
Norway, primarily associated with worn tires and incorrect air pressure48
. The 2012 Impact
Assessment reported varying estimations of technical defects' contribution to traffic
collisions, ranging from 3% to 19%.
There is also further evidence based on results of PTI in selected countries, showing the
link between improved technical condition of the vehicles and increased road safety. A
study49
on data from Spain attempted to assess the impact of PTI on road safety in terms
of numbers of avoided road crashes, injuries and fatalities for each vehicle category.
According to the study, thanks to the inspections carried out during 2016, at least 17,632
crashes, about 12,103 injuries and 133 deaths have been prevented, which translated into
an economic benefit of at least EUR 330 million. It should be noted that the estimated
impacts should be nevertheless treated with caution since the underlying assumptions
44
Diaz Lopez et al., 2018, https://www.aeca-itv.com/wp-content/contribucion-itv-seguridad-vial-medio-
ambiente/eng/files/assets/common/downloads/ROADWORTHINESS%20TESTING%20CONTRIBUTIO
N%20TO%20VEHICLE%20SAFETY%20AND%20ENVIRONMENT.pdf?uni=8643c3a2724634911b854
c6080952f96.
45
VVA et al. (2023), Evaluation support study
46
European Parliamentary Research Service (2020), Report on the implementation report on the road safety
aspects of the Roadworthiness Package
47
Sarkan et al. (2022), Effect of periodical technical inspections of vehicles on traffic accidents in the Slovak
Republic
48
Norwegian Public Roads Administration (2021), Special Analysis, Fatal Motorcycle Accidents 2005-2009
49
UC3M (2019), Roadworthiness testing contribution to vehicle safety and environment
24
concerning the contribution of PTI to the reduction of road accidents are not generally
accepted.
Table 6. Impact of vehicle technical inspections on road safety in Spain
Avoided Traffic
Collisions
Avoided Injuries Avoided Fatalities
Passenger cars 11,895 7,602 80
Vans 2,127 864 12
Motorbikes and mopeds 3,610 3,637 41
Total 17,632 12,103 133
Source: UC3M, 2019
In relation to vehicle age and deficiencies, the database from in-depth investigations of
road crashes IGLAD,50
containing data for Austria, Czechia, France, Greece, Italy,
Sweden, Slovakia and Spain was analysed in the evaluation support study. Figure 3 shows
a comparison of the average age of the vehicles in IGLAD selected countries compared
with the average age of the vehicles for which a defect was coded as a contributory factor.
While there is considerable year-to-year variation for the defect coding, it can still be
observed that an overall trend for the age of vehicles with defects rose faster that the age
of all the vehicles involved. This indicates a growing problem of defects for older vehicles,
perhaps related to some very old vehicles.
Figure 3. Average age of vehicles in IGLAD database compared with average age of
vehicles coded with a defect as a contributory factor.
Blue: all vehicles involved in the road crashes, Orange: vehicles with defects
Source: VVA et al. (2023), Evaluation support study
4.1.1.2 Contribution of the RWP to road safety objectives
The stakeholders surveyed emphasised that by providing a common framework for PTIs,
the RWP plays a central role in maintaining high vehicle standards, improving road safety
and reducing emissions. Some stakeholders mentioned how PTI could have an indirect
50
Initiative for the Global Harmonisation of Accident Data, http://www.iglad.net/
25
psychological effect on vehicle owners: the awareness of the obligation to undergo a PTI
can lead vehicle owners to preventively fix certain defects before the inspection itself,
thereby contributing to their safety. If the RWP had not been implemented, then they may
not have had the same incentive to do so. While most of the respondents to the survey
acknowledge the contribution of PTI and RSI Directives to improved road safety to a large
or even to a high extent, the opinions are more divided regarding the contribution of the
VRD Directive to improved safety: where vehicle registration authorities maintain a
neutral opinion while EU associations and road safety authorities stated that registration
documents lead to increased safety on the road and environmental compliance. Availability
of accurate vehicle registration data is essential for the proper functioning of the cross-
border exchange of information related to road safety offences. While the survey did not
indicate specifically the role played by the Directive on facilitating cross-border exchange
of information on road-safety-related traffic offences (Directive 2015/413/EU)51
, the inter-
institutional negotiations leading to the adoption of this Directive in 2015 confirmed the
enabling function of vehicle registration data for the purpose of enforcement and have
identified areas for further improvements.
Regarding the success of the RSI Directive to contribute to road safety, stakeholders
consulted in the survey - ministries, road safety authorities and PTI bodies - agree to a large
extent that RSI has contributed to improved road safety, although just over half of the
respondents do not have an opinion on the matter (see Figure 4). Road safety authorities
mentioned that figures on crashes in general have decreased since the Directive came into
force.
Figure 4. Stakeholder opinions regarding the effectiveness of the RWP in improving road
safety and contributing to the reduction of road fatalities and serious injuries in road
transport (n=49).
Source: VVA et al. (2023), Evaluation support study, Survey results
Stakeholders reported in the context of RSI, that the identified deficiencies have slightly
increased since the entry into force of the Directive, helping reduce the number of vehicles
in circulation with dangerous defects.
Table 7 illustrates the total number of RSIs performed in selected EU Member State,
including percentages of failed vehicles. The percentage of RSI failed vehicles for the years
2021 and 2022 ranges from 3.8% (reported for Poland) to a maximum of 58.2% (reported
for Sweden), with a total average of 9.6% of failed RSI checks.52
51 EUR-Lex - 32015L0413 - EN - EUR-Lex (europa.eu)
52 The RSI failure rates in Member States can vary for a number of reasons, including whether the RSI
checks are random or are targeted on the basis of a risk assessment, and the nature of the initial check.
26
Table 7. RSI checks by selected EU countries for the period 2021-2022
Source: VVA et al. (2023), Evaluation support study
The rules related to the training of inspectors, the detailed listing of deficiencies and the
prevention of conflicts of interest have contributed to making roads safer, but there are
several gaps that are not explicitly addressed by the RWP. For example, electronic
manipulation of engines, diesel particles exhaust emissions, ADAS suspensions and
electronic systems cannot be checked based on current PTI standards. Also, desk research
suggests that not all deficiencies can effectively be detected by applying the current
technical standards for vehicle inspections and that the protocols set in the RWP are not
sufficient to detect malfunctions and tampering, possibly leading to high emissions of key
air pollutants.
Findings from interviews with stakeholders also indicate that the likelihood of road crashes
due to technical defects increases as the PTI validity approaches its end. Some stakeholders
therefore thought that shortening the PTI interval for vehicles older than 10 years might be
a beneficial measure, as the probability for deficiencies is particularly high in older
vehicles.
Finally, the analysis carried out in the evaluation support study for the years the 2016 to
2020 examined whether the changes over the years in the share of fatal involvements by
older passenger cars could be explained by changes in the share of older vehicles in the
fleet. Data from the countries included in the CARE database analysis of passenger car
fatal involvements was used, alongside registration data for those countries. The
conclusion was that there was very little difference between the predicted evolution of fatal
Reporting Country
Total
Checked Failed Percentage failed
BE 17516 3157 18.0%
EE 16566 2593 15.7%
FI 16621 6280 37.8%
HR 16852 2272 13.5%
IT 10082 2367 23.5%
LT 9963 1371 13.8%
LV 16566 2593 15.7%
MT 6193 2638 42.6%
PL 780185 29762 3.8%
PT 335 184 54.9%
SE 67388 39201 58.2%
Total 958267 92418 9.6%
27
involvements (counterfactual situation) and the actual evolution (CARE data). Beyond the
crash data analysis, there appears to be a general scarcity of empirical data allowing to
establish a clear link between roadworthiness testing and improved road safety. Despite
this, the analysis based on an examination of the available literature on safety and the
stakeholder input combined, suggests that vehicles on the road have generally been made
safer through the introduction of common standards for roadworthiness testing, testing
centres and personnel training, as well as by the adoption of standard rules for frequency,
scope and methods for testing.
4.1.1.3 Contribution of the RWP to emissions reduction objective
Regarding the objective of the RWP to help reducing GHG emissions and air pollution,
roadworthiness emission checks have the potential to identify high-emitting vehicles that
are responsible for most of the air pollution from road transport. These high-emitting
vehicles include vehicles with technical problems, as well as vehicles with tampered
emission systems. Emission reduction technologies reduce emissions significantly. As a
consequence, when this technology is not functioning properly, a small fraction of vehicles
with malfunctioning emission technology has a major impact on the total emissions. This
phenomenon has been reported by study on remote sensing53
based on on-road emission
measurements carried out in 2019. Figure 5 presents the results of the study which
demonstrates that the few high emitters54
reported are responsible for a relative high share
of pollution.
53
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
54
The term "high emitter" is generally considered to refer to a margin over legal limits. In the Flemish remote
sensing study, they defined high emitters as emitting at least 1.5 times above the average of their vehicle
category emission class, and they looked at real driving emissions
28
Figure 5. NOx emissions per vehicle category, fuel type and Euro class.
Source: Hooftman et al., 2020
To understand the impact of the 2014 EU rules, using the number of PTI failures on
emission and the data from the various studies, the effect of PTI was estimated in the
evaluation support study as presented in Table 8.
Table 8. Estimates of the effect of PTI
Source: VVA et al. (2023), Evaluation support study
Based on these estimations, on average, emissions would increase by 10% to 13% for PM
and by 4% to 10% for NOx without the current PTI procedures. However, the number on
high emitters on the road despite the current inspection efforts also demonstrates that
further reductions in emissions are needed. Literature review has also pointed at the
problem that the current procedures are inadequate for detecting tampering, removal or
malfunction of EGR, SCR and Three-Way Catalytic converter (TWC) and DPF 55
.
55
Ligterink, N.E., Elstgeest M., Frateur T., de Ruiter J.M., Paschinger P. (2022) Approaches for detecting
high NOx emissions of aged petrol cars during the periodic technical inspection TNO report
https://publications.tno.nl/publication/34639407/wqLoW7/TNO-2022-R10659.pdf
Engine Pollutant
High emitter
share of
vehicles
High emitter
share on
emission
High emitter
share of
vehicles (no PTI
assumed)
High emitter
share on
emission (no
PTI assumed)
Factor increase
emission (no PTI
against RWP)
Petrol car,
van
PM 10.5% 78.5% 11.50% 80.17% 107.24%
Petrol car,
van
NOx 6.9% 41.1% 7.90% 44.68% 105.32%
Diesel car,
van
PM 10% 80.4% 10.50% 81.24% 103.91%
Diesel car,
van
NOx 4.6% 19.4% 5.10% 21.15% 101.69%
HDV Diesel NOx 6.14% 54.7% 6.64% 56.76% 104.21%
29
Regarding the impact of the RWP on CO2 emissions, the policy measure that targeted the
CO2 reduction was the increased frequency of the testing for “older” cars (i.e. more than
6 years old), which would have lead to better maintanence of vehicles and reduce the
presence of high-emitting vehicles on the EU roads. This measure was however not
retained in the finally agreed text of the PTI Directive. It should also be noted that
emissions depend on fuel consumption and the type of powertrain. No effect from the RWP
for CO2 emission reduction could therefore be identified in the evaluation. The only impact
could be indirect through the measures targeting the tampered vehicles, but no evidence
was found on this in the evaluation. Therefore, the effect of the RWP on CO2 emission
can be expected to be very minor.
Stakeholders’ views regarding the effectiveness of the RWP in reducing emissions were
divided: while representatives from some Member States reported having positive
experiences with dealing with stricter air pollutant limits for diesel cars and for
hydrocarbons of petrol cars, others claim that current emissions requirements are no longer
applicable and therefore need to be updated. Basic tests for diesel engines are not able to
accurately take emission measurements for Euro 5 and Euro 6 vehicles, and they do not
detect faults in newer diesel cars and older cars with missing catalysts. For example,
opacity testing measurement56
is outdated as it no longer applies to new diesel vehicles in
circulation and it does not accurately capture GHG, particle matter and NOx counts.
According to some of the stakeholders consulted, particle number (PN) measurement
should be used as the control method for newer diesel cars to detect tampering with
emission control systems, and remote sensing emission limits should be set for each type
of vehicle and Euro standard to standardise remote sensing across the EU.
Survey respondents gave varied responses to the question on the extent to which the
provisions of the RWP have contributed to reduced air pollutants from road transport since
it came into effect in 2018. The majority did not have specific views or were neutral,
whereas slightly more stakeholders who provided a reply considered that the contribution
was high or to some extent, than those who thought it was only limited or not even that
(see Figure 6).
56
Exhaust gas opacity is a result of the presence of solid particles, hydrocarbons and water vapour. An
increase in exhaust gas opacity is usually accompanied by an increase in the emission of other harmful
exhaust gas components (CO2, CO, HC, NOx). Exhaust smoke opacity measurement is conducted by using
an adsorption opacimeter.
30
Figure 6. Contribution of rules and provisions of the RWP to reduced air pollutants (n=49)
Source: VVA et.al (2023), Evaluation support study, survey results
According to the EU associations57
active in this policy area and road safety authorities
which responded to the survey 58
, the PTI Directive ensures the environmental performance
of motor vehicles by regular testing throughout their entire service life, and they considered
that the proportion of vehicles failing emission tests at PTI has declined from its start of
implementation in 2018. However, according to the EU associations, additional equipment
and testing methods, such as PM and NOx requirements for AdBlue systems, and OBD
scanning tools for commercial and non-commercial vehicles, would be needed to increase
the detection of high emitters. The same stakeholder group also agreed to some extent that
the current PTI testing is able to detect malfunctions and tampering leading to high
emissions of air pollutants, whereas national ministries and road safety authorities agreed
to a limited extent. Feedback from ministries and road safety authorities showed that
vehicles with defects that have been tampered, which are not covered by the EOBD system
or those specifically related to NOx emissions (e.g. defects in sensors required by ADAS
systems) will not necessarily be detected by the current PTI regimes. An OBD check and
complementary tailpipe measurement are perceived to be the optimal way to perform an
emissions test, and to leverage all potential PN measurements.
4.1.1.4 Contribution of the RWP to improved exchange of information and functioning
of the internal market
Regarding the improvement of the exchange of information on testing results between
actors and Member States, according to most stakeholders consulted there appears to be
significant room for improving the current framework. Although the legislation enables
data exchanges between Member States authorities, it does not mandate it (and not all
countries use this), nor does it define essential elements for the exchange of information,
especially for the compliance with the existing EU data protection standards59
and
cybersecurity aspects. Many Member States use the EUCARIS system on a voluntary basis
for import/export of vehicles and registration processes.
Some stakeholders stated that additional EU legislation might be desirable to formalise the
use of services to improve information exchange, including cross-border odometer fraud.
Several EU associations highlighted that in case more countries were connected to a
common platform, this could result in a quick win for facilitating information exchange
and making relevant vehicle mileage data available to car buyers and inspection operators
across borders. Just over a half of the survey respondents (28 out of 49) expressed no
57
The group ‘EU association’ in the survey carried out by the external contractor includes business
associations, NGOs and consumer associations.
58
VVA et al. (2023), Evaluation support study, survey results
59
Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and
on the free movement of such data (General Data Protection Regulation)
31
opinion on whether the 2014 RWP made it possible to further digitalise the re-registration
process, while only 7 out of 49 considered that it made it easier to further digitalise the re-
registration process.
From a legal point of view, the current situation brings therefore uncertainty as regards a
key enabling factor of the EU-wide cooperation between relevant authorities. Uncertainties
also exist regarding the enforcement of data protection rules applicable in the Union when
it comes to exchange of information between national authorities.
Regarding the contribution of the RWP to facilitating free movement for EU citizens and
the smooth functioning of the internal market, 20 stakeholders (EU associations, ministries,
and road safety authorities) out of 49 considered that the VRD Directive has contributed
to the free movement of citizens, while 25 had no opinion on that. EU associations
highlighted that the obligation to keep electronic record of data on all vehicles registered
in their territory and to exchange information between Member States helps improve free
movement of EU citizens, as well as the recognition of PTI certificates in EU countries.
Even if the harmonisation of vehicle registration documents was made easier for citizens
to register vehicles from other Member States and EEA, there seems to be room for further
advancing the digitalisation process to make it even easier. Moreover, although some
countries have entered bilateral agreements (such as between Sweden and Spain), there is
no mutual recognition of a PTI across Member States. Currently, PTIs must be performed
in the same country where the vehicle has been registered, which in practice limits the
effects of the EU harmonisation.
Other factors having driven or hindered the achievement of the objectives
During this evaluation, stakeholder views on the main elements currently hindering the
achievements of the objectives defined by the RWP were also collected, such as the lack
of harmonisation of PTI standards, equipment and procedures across Member States and
the inconsistencies identified between the RWP and the Type Approval Directive. Most
stakeholders, especially EU associations and Member States authorities (ministries and
road safety authorities) agreed on the importance of ensuring free access to relevant
standardised in-vehicle data and functions to authorised service providers, as well as
creating an electronic information platform to drive digitalisation and set standards for a
common document platform in the EU. Besides, some shortcomings in PTI/RSI testing
could be avoided in their views if, already at the stage of type-approval legislation,
requirements would ensure easier testable vehicles. Therefore, some of them called for
type-approval made by design to testing needs.
Some additional factors hindering the achievement of objectives have been highlighted by
stakeholders during consultations, namely:
▪ The absence of dedicated requirements for electric and hybrid vehicles such as
safe, direct measurement sample points at the high voltage system;
▪ The exclusion from the RWP of safety functions managed by electronics,
ADAS systems and new intelligent headlights;
▪ The ‘hidden’ wear and tear on cars with odometers that have been tampered
with, which negatively affects maintenance schedules and therefore road
safety;
▪ No binding cargo securing rules which would ensure this area is regulated and
would minimise accidents;
32
▪ The lack of PTI information in certification documents; and
▪ The perceived excessive costs of testing equipment and the time required by
inspections.
Regarding odometer fraud, the 2014 RWP introduced measures requiring Member States
to ensure that the odometer data recorded at the previous roadworthiness test were made
available during the next inspection. Member States have transposed this requirement, but
in many cases, there were no effective and dissuasive penalties put in place when an
odometer fraud was detected; moreover, the measures in place were in many cases rather
generic, not specifically aimed at odometer fraud. Also, the existing measure does nothing
to address the issue of odometer tampering between PTIs, or before a vehicle passes the
first PTI. Moreover, in the absence of information exchange on odometer fraud between
national authorities, cross-border odometer fraud persists. All these shortcomings point at
ineffectiveness of the RWP as regards the odometer fraud. On the other hand, the examples
of national implementing measures such as introduced by Belgium and Netherlands proved
to be effective, as they addressed the issue of regular collection of odometer readings from
vehicles, which takes place in-between PTIs (such as vehicle repair workshops, including
tyre and windscreen repair services) and well before the first PTI. In addition, these two
countries introduced an exchange of the odometer history data between the national
databases. These more targeted measures proved to be more effective in tackling the
odometer fraud and could also be replicated at the EU level.
4.1.2 Efficiency
The efficiency analysis explores the extent to which the costs associated with the RWP
have been proportionate to the overall benefits achieved.
The evaluation support study60
estimated the administrative costs for vehicle owners
(citizens and businesses) at around EUR 10 billion in 2019. They were calculated based
on the number of PTI inspections for all vehicle categories and the respective PTI charges.
Regarding the possible benefits, the evaluation support study estimated 1,300 lives saved
for 2019, and 10,600 serious injuries and 59,600 slight injuries avoided. In monetary terms,
using the Handbook on the External Costs of Transport61
, this would translate into benefits
of around EUR 12.7 billion. In addition, the reduction in the external costs of air pollutants
(NOx and PM) was estimated at EUR 0.7 billion. Thus, the total benefits are estimated at
EUR 13.4 billion and the net benefits at EUR 3.4 billion. However, while these estimates
can help understand the magnitude of costs and benefits of the PTI regime, they should be
interpreted with a significant degree of caution.
Stakeholders assessed rather positively the extent to which the benefits of the RWP in
terms of increased road safety, reduced air pollutants and improved free movement are
justified compared to the costs and effort invested in implementing the EU rules (Figure
7). Representatives of Member States’ authorities (ministries, road safety authorities) and
EU associations mostly agreed that the costs/benefits ratio of PTI, RSI and registration
documents are justified. Ministries and the road safety authorities of several EU Member
States stated that implementation of the RWP has not caused significant administrative and
60
VVA et al. (2023), Evaluation support study
61
https://op.europa.eu/fr/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1
33
adjustment costs as they already had a developed system of PTI and RSI. National
representatives noted that there is available evidence that demonstrate the contribution of
the RWP Package – and in particular PTI – to the reduction of fatalities, thus justifying the
investments. On the other hand, EU associations stated that EU legislation such as PTI can
reduce the number of illegally polluting cars on the EU's roads and reduce the human costs
of air pollution.
Figure 7. Benefits of the RWP (increased road safety, reduced air pollutants) justification
compared to the costs and efforts invested in implementing the RWP rules (n=49)
Source: VVA et al. (2023), Evaluation support study, survey results
Despite the lack of sufficient and reliable empirical data to perform a comprehensive cost-
benefit analysis for the RWP, the benefits of its implementation are likely to outweigh the
associated costs. For instance, a 2018 study on odometer manipulation in motor vehicles
in the EU62
showed that the total economic costs of odometer fraud in second-hand cars
traded cross-border in the EU can be estimated to be at least EUR 1.31 billion, with the
most probable fraud rate scenario incurring a loss of around EUR 8.77 billion.
In the stakeholder interviews63
, it was also suggested that a way to simplify the RWP and
reduce costs could be to prioritise the adaptation of PTI procedures to keep up with
technical advancements and thus strengthen the safety of vehicles. Stakeholders also
pointed out that it would be important to establish universal standards for in-vehicle data
access to facilitate inspections. To further reduce expenses, some stakeholders considered
to be made mandatory for original equipment manufacturers (OEMs) to provide
information required for carrying out the inspections to PTI operators free of charge. Along
with a unified digital format for registration documents and the definition of universal
standards for data extraction, this requirement could greatly simplify the RWP and
minimise expenses. Finally, some stakeholders suggested adjusting the scope of the
Directives to exclude weights for roller brake testers and heavy vehicle lifting testing
methods to simplify the RWP and reduce costs.
Administrative burden for authorities, businesses and citizens
The RWP has placed several administrative responsibilities on public authorities in
Member States. Interviewed stakeholders generally considered the administrative
62
EPRS study “Odometer manipulation in motor vehicles in the EU”, January 2018, available at:
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_E
N.pdf
63
VVA et al. (2023), Evaluation support study, stakeholder interviews
34
workload generated by the three Directives a necessary condition for its effective
implementation. The major administrative challenges and related costs faced by PTI
centres included training of highly qualified inspection personnel, investments in necessary
equipment and materials, analysing statistical data from technical controls, and monitoring
of inspector activities, including the supervision of testing centres and verification of
inspectors. To reduce administrative burden on national authorities, some best practices
include developing e-PTI (electronic PTI) based ISO standards, which can allow for
automatic real-time transmission of diagnostic data through the OBD port and streamline
procedures for monitoring the implementation of the RWP. The stakeholders consulted
pointed out that important vehicle data is often not accessible to inspectors: therefore, it
has been suggested that testing would be improved if information for vehicle inspections
was made available to inspection centres free of charge.
Odometer tampering causes to the buyers of tampered cars higher-than-expected
maintenance and repair costs because the cars are not inspected based on their real mileage.
Some Member States have introduced instruments to minimise odometer manipulation,
such as Car-Pass in Belgium and Nationale AutoPas (NAP) in the Netherlands; both
Member States use a database collecting odometer readings at every maintenance, service,
repair, or periodical inspection of the vehicle, without collecting any personal data, and
both have almost eradicated odometer fraud in their domains within a short timeframe64
.
Ministries, road safety authorities and vehicle registration authorities 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. The introduction
of digital information systems and structured messages exchanges was also seen as
possibly helping to improve communication among Member States and to reduce
administrative burden.
In terms of the administrative burden RWP imposed on businesses and citizens, most
stakeholders in the survey (30 out of 49) did not provide any opinion or were neutral of
whether the RWP has generated administrative burden for businesses. Similarly, more than
half of the survey respondents (32 of 49) did not have an opinion or were neutral on the
administrative burden generated by the RWP for citizens. However, it was highlighted that
certain requirements were considered burdensome for citizens, such as the requirement for
citizens to present their registration certificate when undergoing re-registration. This was
perceived as time consuming and add to the overall administrative burden faced by
citizens. Also, EU associations stated that digital (mobile) vehicle registration documents
could further facilitate the digitalisation of the vehicle registration and data-keeping
processes and reduce costs for citizens and businesses. Furthermore, a well-assessed test
methodology was also considered important to avoid false negative and false positive
outcomes during PTI and to achieve a harmonised approach to test procedures and
equipment. This would help improving the efficiency of inspections and could
consequently positively impact both citizens and businesses.
64
European Parliament resolution of 31 May 2018 with recommendations to the Commission on odometer
manipulation in motor vehicles: revision of the EU legal framework (2017/2064(INL))
35
4.1.3 Coherence
The evaluation of coherence covers both the internal coherence dimension which looks
how well various elements of the RWP operate together, and the external coherence,
meaning if and how the RWP is consistent with other related EU legislation and policies.
The evaluation found no real issues with internal coherence of the RWP. Regarding the
external coherence, the evaluation looked in the coherence with relevant EU legislation
and policies in the field of EU road safety, such as the EU Road Safety Policy Framework
2010 to 2020, and its successor, the Road Safety Action Plan 2021-2030, as well as the
Sustainable and Smart Mobility Strategy. Stakeholders overall agreed on the consistency
between the RWP Directives and the objectives of EU road safety policy. Periodic
technical inspections and roadside inspections were considered essential instruments for
achieving the European Commission’s Vision Zero approach on fatalities and serious
injuries on European roads by 2050.
However, some of the interviewed stakeholders highlighted that type-approval
requirements should enable lifelong testing by design and called therefore for better
coherence between the type-approval regulation and the RWP.
Regarding interventions at international level, EU associations also added that the UNECE
whole-lifetime compliance is at a very preliminary stage while RWP is at a more mature
stage and can be treated as state of the art legislation in the international context. Survey
replies however reflected the opinion that more coherence between the RWP and the
UNECE standards would be needed as regards the life-cycle approach.
The evaluation identified the following specific coherence issues in relation to relevant
EU legislation:
• The lack of coherence between the PTI Directive and Regulation 2018/858
on type-approval requirements for motor vehicles makes it difficult to
perform thorough inspections, and the issue is likely to grow with deployment
of automated devices, electronic sensors and safety features.
• Coherence with Regulation 2018/858 on type-approval requirements
regarding tampering: vehicles should not be allowed to be altered in a way that
diminishes the original functioning of the emission and safety controls without
further legal checks and it should be possible to monitor any deviations or
alterations during PTI or RSI. PTI does not provide an effective tool to
counteract the tampering such as removing particulate filters and emulating
SCR systems.
• In the VRT Directive, definitions of the vehicle registration
data/terminology in some instances do not correspond to those in the type-
approval legislation. This leads to confusion and potential errors in recording
and tracking vehicle information.
• Inconsistencies of definitions existing between the VRD Directive and the
End-of-Life Vehicles Directive (Directive 2000/53/EU). Terms such as
‘registration’, ‘de-registration’ ‘temporary de-registration’, ‘suspension’,
‘cancellation of the registration’ and ‘permanent cancellation of the
registration’ should be harmonised across these two Directives.
• General Safety Regulation (EU) 2019/2144 requires that all motor vehicles
will have to be equipped with safety features such as intelligent speed
36
assistance, driver drowsiness and attention warning systems; these systems
should be also covered by roadworthiness testing.
• Lack of data coherence between the RWP and relevant EU legislations due to
divergence of safety relevant vehicle data. According to interview
respondents, a common problem with the RWP is 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 daily use of reference vehicle data very difficult;
• UNECE regulations on whole-lifetime compliance set out methods for
checking electric vehicles when undergoing a technical inspection while the
PTI Directive does not specify such requirements.
4.2 How did the EU intervention make a difference and to whom?
The EU level intervention on roadworthiness testing and vehicle registration documents
brought benefits beyond those which would have been possible at national or local level
alone. The 2021 European Parliament resolution65
strongly endorsed action on
roadworthiness at EU level, pointing out that there had been improved harmonisation of
national procedures in the Member States, increased quality of PTI and better coordination
in RSI. The report suggested that these actions had improved road safety standards.
This view was widely acknowledged by relevant stakeholders consulted during this
evaluation who perceived the RWP as contributing towards the harmonisation of
roadworthiness rules among Member States. By creating a common framework for
identifying vehicle defects, the RWP ultimately benefits both EU citizens and business
entities. Crucially, according to most consulted stakeholders, the introduction of minimum
standards for periodical technical inspections and roadside inspections contributed to
preventing road crashes, thus being beneficial to vehicle owners and citizens at large.
The RWP contributed to SDG 11 through making cities and human settlements more
inclusive and sustainable, primarily by focusing on improving road safety (Target 11.2)
and by reducing the adverse impact of cities, by focusing on air quality (Target 11.6), in
particular the reduction of air pollutants such as NOx.
The interviewed stakeholders considered that had the RWP not been in place, the road
safety policy in the EU would be more fragmented and with Member States possibly taking
very different actions. The RWP set 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.
Similarly, survey respondents agreed that the implementation of the RWP created value in
terms of road safety and environmental protection compared to what could have been
achieved without EU intervention (Figure 8). According to some of the EU associations,
RWP sets a minimum standard across the EU and ensures that all Member States need to
act for road safety and environment protection, providing a basic framework and
orientation for defects with a wider scope and more detailed description. However, as
observed by some ministries and road safety authorities, several Member States had
65
Procedure File: 2019/2205(INI) | Legislative Observatory | European Parliament (europa.eu) Texts adopted
- Implementation report on the road safety aspects of the Roadworthiness Package - Tuesday, 27 April 2021
(europa.eu)
37
already implemented high-level roadworthiness test regimes before the implementation of
the RWP. Across all stakeholder categories the need to improve mutual recognition of PTI
inspections was emphasised, since this adds value to the functioning of the EU single
market, while it also helps increasing vehicle safety and environmental protection.
Figure 8. Stakeholder views on RWP added value (n=49)
Source: VVA et al. (2023), Evaluation support study, Survey results
The harmonisation of emission standards and practical implementation to test these
standards at EU level improves the level playing field for the commercial transportation
of goods and passengers in the EU, as companies in different Member States must
comply with similar technical roadworthiness requirements leading to similar cost-for-
vehicle purchases and maintenance in commercial activities. As vehicles and pollution do
not stop at the border, it is rational for EU vehicles to meet the same emission standards
and that throughout their lifetime operations. Finally, in requiring the mutual recognition
of roadworthiness certificates from other Member States for the purpose of re-registration,
the RWP provisions also facilitate free movement within the EU.
4.3 Is the intervention still relevant?
Relevance in view of road safety objectives
The Commission laid out a Road Safety Policy Framework for the decade 2020 to 203066
which sets a 50% reduction target in deaths and serious injuries over the decade on the way
to the goal of zero fatalities by 2050. The document recognises the importance of ensuring
vehicle roadworthiness: “As safety problems often appear after the placing on the market,
regular roadworthiness checks are important to ensure that consumers are protected
through the lifetime of the vehicles.” Regular roadworthiness checks play a central role in
ensuring consumer protection throughout the entire lifetime of the vehicles.
It can also be argued that the requirement as of 6 July 2022, to fit a variety of new
Advanced Driver Assistance Systems (ADAS) systems introduced by the revision of the
General Safety Regulation of 201967
increases the relevance of vehicle roadworthiness
testing. These systems are potentially subject to malfunctions, they may require software
updates to ensure intended performance and they could be the target of tampering. The
projections of road safety benefits from these systems were made on the basis that the
systems would be fully functional over the vehicle’s lifetime. Thus, the installation of these
new ADAS systems requires expanding the scope of roadworthiness testing to verifying
the operation of the mandated electronic systems. Similar findings on the importance of
66
EUR-Lex - 52018DC0293 - EN - EUR-Lex (europa.eu)
67
EUR-Lex - 32019R2144 - EN - EUR-Lex (europa.eu)
38
inclusion of the recent safety systems in vehicles come from a study published by the
Commission in 2019 on the inclusion of eCall in periodic roadworthiness testing of motor
vehicles. The study notes68
that the eCall equipment on a vehicle is subject to deterioration
and that the inclusion of this equipment in PTI would have a high benefit-to-cost return.
The average age of vehicles has been increasing in recent years. According to ACEA
data69
, the average age of passenger cars in the EU was 10.7 years in 2016, whereas by the
beginning of 2022 it had risen to 12.0 years. The average age of other vehicle categories
rose in a similar way. In this context, the International Motor Vehicle Inspection
Committee (CITA) points out70
that the average age of the vehicle fleet has increased and
will continue to rise and that serious defects are more likely to emerge as vehicles age.
The RWP is recognised by technical and institutional stakeholders as a significant
contribution towards road safety. It is generally acknowledged that the introduction of a
common EU framework for conducting PTIs and RSIs has yielded many advantages,
allowing for better detection of deficiencies in malfunctioning vehicles throughout their
lifecycle.
With regards to the relevance of the RWP for the current needs of roadworthiness, all the
objectives set out in the Directives are recognised to be relevant to a high or some extent
by a majority of consulted stakeholders. As for the relevance of the RWP to the future
needs of roadworthiness, all the objectives are also deemed very relevant by the majority
of stakeholders consulted: despite the gradual shift to e-mobility, cars with internal
combustion engines will likely still be on EU roads for decades, and the RWP has the
potential to continue to play an important role in monitoring emissions and ensuring road
safety. However, all stakeholders consulted during the evaluation highlighted the
importance of adapting the Directives to the changes in vehicle technology. They take the
view that the relevance of the RWP has been diminished by the widening gap between the
existing requirements and the new systems installed in modern vehicles. In particular
driver assistance interfaces (e.g. ADAS), Intelligent Transportation Systems (ITS), human-
machine interface (HMI) and electronic safety features were considered by stakeholders as
not sufficiently addressed by the RWP directives. On ADAS, the RWP does not seem to
provide a sufficiently comprehensive framework for evaluating the safety performance of
ADAS and automated vehicles of SAE Level 3 and higher. Another area that the RWP
does not cover is the definition of specific testing protocols to ensure the compliance and
maintenance of electric, hybrid and hydrogen vehicles, including how to handle software
updates in a safe and efficient manner. In addition, as the number of vehicle classes is
growing faster than the testing centres’ ability to diagnose their defects, parameters for
technical inspections are not sufficiently updated to allow the efficient acquisition of
important safety-related data and the monitoring of new sensors and functions.
In terms of keeping up the RWP with the technological and scientific progress, most of the
stakeholders interviewed considered that it is essential to update the Directives to include
features such as the ADAS interface, the tyre pressure monitoring system (TPMS) and
laser or LED lighting, which have been embedded in cars for around a decade but are not
tested by standard PTIs. This is consistent with the views from survey respondents,
especially ministries, road safety authorities and PTI bodies, which considered that the
current RWP and its objectives address the technological advancement in automated
68
eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=PI_COM:C(2021)4992
69
ACEA-report-vehicles-in-use-europe-2023.pdf
70
In its position paper submitted alongside its response to the public consultation on RWP
39
systems only to a limited extent. The technology used in vehicles has surpassed what the
current framework covers and new rules for inspection of new safety systems, such as
ADAS, are needed. Furthermore, since current tools like the OBD system do not fit some
cars in circulation for diagnostic purposes, the scope of the RWP would also become more
relevant should it be broadened to enable the inspection of new software and to improve
testing facilities. According to the evidence gathered, the RWP intervention is currently
not adapted to teleoperated and autonomously driving vehicles, as well as their sensors,
radar systems and cameras that act and function in network. Concrete testing of high-
voltage vehicles and their components is also currently missing.
Relevance in view of environmental objectives
The RWP’s objective to contribute to reduction of greenhouse gases and air pollutant
emissions from road transport is still relevant in the context of the EU climate objectives
and the ambitions put forward in the related key strategies, the European Green Deal71
, the
EU Zero Pollution Action Plan72
, and at international level, the Sustainable Development
Goals.
The objective of identifying gross emitters through periodical technical inspections and
roadside inspections and removing them from road traffic contributes to the emission
reduction targets established by different EU instruments, such as the newly proposed Euro
7 norms, the national emission reduction commitments for the main air pollutants set in
Directive 2016/2284, and the stricter air quality standards recently proposed by the revision
of Ambient Air Quality Directive73
.
In the stakeholder consultations, most stakeholders maintained that the three Directives are
still very relevant to the achievement of wider EU environmental policy goals, in addition
to the overall improvement of road safety.
With internal combustion engine vehicles becoming cleaner (as per the Euro norms), some
of the tests used in PTI are no longer sufficiently sensitive to detect emission failures.
Given the undetected problems for vehicles equipped with emission control systems, diesel
particulate filters (diesel Euro 5 and 6) and three-way catalysts (petrol from Euro 1),
existing evidence supports the claim that the current testing procedures are not fit to meet
the EU policy goals. Modern vehicle engines and exhaust gas systems have other critical
detection criteria that are not covered by the currently prescribed test methods, and current
PTI tools are not functional for measuring 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. While some stakeholders suggested that DPF filters
might reduce considerably particulate matter emission for Euro 5 categories or later, the
measurement of nitrogen oxide emissions or PM/PN values for new cars are still not
covered by the current RWP. Additionally, there are currently no EU provisions for testing
vehicles for NOx manipulation/defect or manipulation/defect of diesel particulate filter.
On this point, many stakeholders expressed interest in evolving the testing of engine
management and exhaust emission control systems towards updated, more sensitive
measurement procedures. According to some consulted stakeholders, consideration should
71
COM/2019/640 final
72
COM/2021/400 final
73
COM/2022/542 final
40
also be given to mandating that original equipment manufacturers (OEMs) provide type-
approval information for PTIs.
Relevance in view of other technological developments
The evidence and stakeholder views gathered suggests that there have been numerous
significant changes in vehicle technology since the RWP came into effect, making the
current RWP not adapted to new developments and less relevant.
Regarding vehicle software, the stakeholders in the survey (24 out of 49), especially among
EU associations, but also ministries, road safety authorities and PTI bodies, pointed out
that it is necessary to identify the vehicle software version in the PTI test, to ensure the
vehicle updates have been installed. Still, 16 out of 49 respondents did not have an opinion
on the matter; EU associations stated that only safety-critical and environmentally critical
software updates are relevant to PTI and RSI, whereas ministries and road safety
authorities pointed out that vehicle manufacturers should make available a database with
the latest software versions for every vehicle.
Furthermore, 26 stakeholders out of 49 in the survey, in particular EU associations and PTI
bodies, opined that on-board fuel and energy consumption meter (OBFCM) devices, OBD
(on-board diagnostics) and on-board monitoring (OBM) data should be registered centrally
during PTI checks. Ministries and road safety authorities highlighted that OBFCM data
collection during PTI is already established by the Implementing Regulation EU 2021/392.
In relation with OBM, as proposed in Euro 7, the OBM sensors could be checked/compared
with real tailpipe measuring during PTI. However, in contrast with the equipment installed
in PTI stations, the OBM sensors are not submitted to any metrological control during the
life of the vehicle. Moreover, EU associations stated that centrally registered OBFCM and
PTI data can help detect tampering with the odometer or with OBFCM/OBM data itself,
as it can allow for the easy analysis of the collected data and flagging of suspicious outliers.
Finally, even though stakeholders’ opinion on the need for standards and regulations on
mobile vehicle registration documents was divided, most EU associations consulted
considered that such standards are needed. EU associations and vehicle registration
authorities expressed the view that vehicle registration documents must be readable in all
Member States, and this is the reason why standards are very important, since documents
which are only valid at national level have only limited value (Figure 9).
Figure 9. Need for standards and regulations on mobile vehicle registration documents
(n=49)
Source: VVA et al. (2023), Evaluation support study, Survey results
41
5 WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED?
5.1 Conclusions
The evaluation’s findings lead to several conclusions regarding the overall performance of
the three Directives of the RWP, which can be grouped by evaluation criterion as follows:
5.1.1 Effectiveness
The evaluation is based on evidence available for the period between 2018 and 2021. At
the same time, it should be borne in mind that Member States had to transpose the
provisions of the RWP by May 2017. While there are gaps in the requirements for the
Member States’ reporting on RWP, the evaluation considers the available implementation
reports for the PTI and RSI Directive. While there was no sufficient quantified evidence
which would allow to establish a clear link between roadworthiness testing and improved
road safety, the evaluation analysis based on the examination of the available studies on
safety and stakeholders’ input combined, suggests that vehicles on EU roads have
generally been made safer through the introduction of common standards for
roadworthiness testing, testing centres and personnel training, as well as by the adoption
of standard rules for frequency, scope and methods for testing.
Regarding the role of technical defects in road safety at both EU and national levels various
estimations are available. The most comprehensive studies estimate that vehicle defects
are a contributing factor between 6.5% to 12.6% of road crashes. The improved technical
condition of the vehicles should hence contribute to increased road safety in terms of
numbers of avoided road crashes, injuries and fatalities, which has also been confirmed by
the results of periodic technical inspections in selected countries, showing the link between
improved technical condition of the vehicles and increased road safety. Moreover, given
that the age of a vehicle was found to be an important factor which increases the risk of
roadworthiness faults, and in the context where the average age of the EU vehicle fleet has
increased in the recent years, the contribution of RWP to road safety objectives appears
even more important. Most stakeholders consulted considered that PTIs and RSIs helped
to some extent to reduce the number of vehicles in circulation with dangerous defects.
Regarding the objective of the RWP to help reducing emissions, roadworthiness emission
checks can identify high-emitting vehicles that are responsible for most of the air pollution
from traffic. However, the effectiveness of the RWP was rather limited, especially in a
fast-evolving sector: while there were some positive experiences with adopting stricter
emission limits for diesel cars and for hydrocarbons of petrol cars, the current emissions
requirements under PTI and RSI are no longer applicable and have to be updated. Basic
tests for diesel engines are not able to accurately take emission measurements for Euro 5
and Euro 6 vehicles, and they do not detect faults in newer diesel cars and older cars with
missing catalysts. The opacity testing measurement is outdated as it no longer applies to
new diesel vehicles in circulation and it does not accurately capture GHG, particle matter
and NOx counts. Instead, PN measurement should be used as the control method for newer
diesel cars to detect tampering with emission control systems, and remote sensing emission
limits should be set for each type of vehicle and Euro standard to standardise remote
sensing across the EU. To ensure adequate levels of accuracy and efficiency in detecting
NOx emissions, it is necessary to have access to the vehicle itself and to reference values
during the approval process, which is not the case today.
42
Regarding the improvement of the exchange of information on testing results between
actors and Member States, the current framework for information exchange is not
considered as successful. Although the legislation enables data exchanges between
Member State authorities, not all countries use this possibility. Even if the harmonisation
of vehicle registration documents was made easier for citizens to register vehicles from
other Member States and EEA, there seems to be room for further improvement in the
process to make it even easier. Moreover, there is no mutual recognition of PTIs across
Member States. Currently, PTIs must be performed in the same country where the vehicle
has been registered, which in practice limits the positive effects of the RWP on the free
movement for EU citizens and the smooth functioning of the internal market.
5.1.2 Efficiency
Despite the lack of sufficient empirical data to perform a more robust cost-benefit analysis
for the RWP, it is generally accepted by the stakeholders consulted that the benefits of its
implementation outweigh the associated costs. Representatives of Member States’
authorities (ministries, road safety authorities) and EU associations mostly agreed that the
costs/benefits ratio of PTI, RSI and registration documents are justified. Ministries and the
road safety authorities of several EU Member States stated that implementation of the
RWP has not caused significant administrative and adjustment costs as they already had a
developed system of PTI and RSI. Nevertheless, opinions are divided on the level of costs
involved in certain aspects of the RWP and some practical suggestions have been identified
to reduce costs associated with its implementation.
The major administrative challenges and related costs faced by Member States included
the enforcement procedures, training of highly qualified inspection personnel, investments
in necessary equipment and materials, analysing statistical data from technical controls,
and monitoring of inspector activities, including the supervision of testing centres and
verification of inspectors. To reduce administrative burden on national authorities, some
best practices include developing e-PTI (electronic PTI) based ISO standards, which
enable automatic real-time transmission of diagnostic data through the OBD connector and
streamline procedures for monitoring the implementation of the RWP.
In terms of the administrative burden RWP imposed on businesses and citizens, there were
certain requirements which were considered burdensome for citizens, such as the
requirement for citizens to present their registration certificate when undergoing re-
registration. This can be time consuming and add to the overall administrative burden faced
by citizens. Also, digital (mobile) vehicle registration documents could furthermore
facilitate the digitalisation of the vehicle registration and data-keeping processes and
reduce costs for citizens and businesses.
5.1.3 Coherence
The evaluation finds that there is consistency between the RWP Directives and the
objectives of EU road safety policy. Periodic technical inspections and roadside
inspections are considered essential instruments in the policy toolbox for achieving the
European Commission’s Vision Zero approach on fatalities and serious injuries on
European roads by 2050.
However, it appears that more consistency should be ensured between the type-approval
regulation and the RWP. For example, in the responses to the survey, 92% (46, 25 ‘no
responses’ or ‘Don’t knows’) believed that updating the PTI to cover the safety systems
43
introduced by the General Safety Regulation (GSR) would ensure better consistency,
objectivity, and quality of roadworthiness testing. Also, the coherence between the RWP and
relevant EU policies could be improved through the standardisation of safety relevant data
regarding vehicles. In the response in relation to vehicle registration, one EU representative
organisation74
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, and the possibility for relevant authorities and bodies to access vehicle registration
data. Another stakeholder organisation75
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.
Regarding interventions at international level, the EU RWP measures should set standards
for related legislation at UNECE level, as it is currently in the case of the recommendation
on PN measurement. The RWP is also not sufficiently aligned with the General Safety
Regulation (GSR) (EU) 2019/2144 regarding 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 for free could better address
sovereign tasks and reduce procedural overlaps, thus improving the overall accuracy and
efficiency of inspections.
5.1.4 EU added value
The road transport and the automotive industry are international sectors, therefore a certain
minimum level of harmonisation in vehicle testing and exchange vehicle data between Member
States is more effective than uncoordinated national approaches. While historically, the national
practices differ, the EU level intervention on roadworthiness testing and vehicle registration
documents brought benefits beyond those which would have been posssible at national or
local level alone. The overwhelming majority of interviewed stakeholders agreed that if
the RWP had not been implemented, the road safety policy and its implementation in the
EU would be far more fragmented, with Member States taking different actions. 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.
The harmonisation of emission standards and practical implementation to test these
standards at EU level improves the level playing field for the transport of goods and
passengers in the EU, as companies across the EU must comply with similar technical
roadworthiness requirements leading to similar cost for vehicle purchases and
maintenance. Since vehicles and pollution do not stop at the border, it makes sense for EU
vehicles to meet the same emission standards throughout their lifetime operations. Further
harmonisation of the minimum level PTI and RSI requirements in the revision of the RWP
would be useful to improve consistency of laws, standards and practices within the EU.
Common rules applied to testing modern vehicle technologies (EVs, ADAS, and the most recent
emission control equipment), would on the one hand help Member States realise economies of
scale, and on the other hand the testing equipment manufacturers could operate on a more
homogenous market. There is also a scope to improve mutual recognition of PTI inspections
74
CITA Home - CITA International Motor Vehicle Inspection Committee
75
FSD German central agency for PTI
44
by the Member States, which would add value to the EU internal market, benefit the
consumers and it would also help increasing vehicle safety and environmental protection.
5.1.5 Relevance
With regards to the relevance of the RWP for the current needs, all the objectives set out
in the Directives are still recognised as relevant. With regards to the future needs, the RWP
has the potential to continue to play an important role in monitoring emissions and ensuring
road safety. However, it will be important that the Directives adapt to the changes in
vehicle technology.
The relevance of the RWP has been diminished in recent years by the widening gap
between the existing roadworthiness requirements and the new systems installed in modern
vehicles. In particular on advanced driver assistance systems (e.g. ADAS), Intelligent
Transportation Systems (ITS), human-machine interface (HMI) and electronic safety
features the three Directives do not seem to provide a sufficiently comprehensive
framework. Another area which is increasing in relevance is the roll-out of low and zero
emission vehicles; the RWP currently does not cover specific testing protocols to ensure
the compliance and maintenance of electric, hybrid and hydrogen vehicles, including
software updates, in a safe and efficient manner. Also, parameters for technical inspections
are not sufficiently updated to allow the efficient acquisition of important safety-related
data and the monitoring of new sensors and functions. Beyond, according to the evidence
gathered, the RWP intervention would not be adapted to teleoperated and autonomously
driving vehicles.
The RWP’s objective to contribute to emissions reduction from road transport is still
relevant in the context of the EU climate and environmental objectives. However, some of
the tests used in PTI are no longer sufficiently sensitive to detect emission failures in
internal combustion powered vehicles. 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 functional for measuring 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. Additionally, there are currently
no EU roadworthiness provisions for testing vehicles for NOx manipulation/defect or
manipulation/defect of diesel particulate filter. Stakeholders considered that if the
Directives are not adapted to modern driving features and safety systems, the gap between
vehicle technology and testing techniques will widen excessively.
5.2 Lessons learned
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 a high cost to society.
Defective vehicles may 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. In addition, current test methods
and procedures are not always capable of detecting defective or tampered vehicles and are
not designed to test the most recent vehicles, such as electric vehicles or vehicles with
advanced driver assistance systems. At the other end of the spectrum, older vehicles (over
10 years) are found to be defective more frequently than newer ones. This is a concern
with the gradual ageing of the EU vehicle fleet.
45
In relation to emissions, there are still many vehicles with defective or tampered emission
control systems that go undetected. There are multiple, readily available, and cheap
solutions to cheat existing emission control technologies, and the current testing (PTI and
RSI) methods are not suited to measuring the emission performance of modern vehicles.
Member States still report difficulties in effectively enforcing road safety measures in EU
cross-border traffic and vehicle trade. These difficulties can be caused by Member States
recording different sets of vehicle data, or difficulties for competent authorities in
accessing vehicle register data and other safety-relevant information of vehicles,
particularly when these are registered in another Member. These difficulties can also
negatively impact the fight against the widespread malpractice of odometer tampering.
5.3 Robustness of the conclusions
The evaluation is based on evidence available for the period between 2018 and 2021. At
the same time, it should be borne in mind that Member States had to transpose the
provisions of the RWP by May 2017. While there are gaps in the requirements for the
Member States’ reporting on RWP, the evaluation considers the available implementation
reports for the PTI and RSI Directive. In addition, it also takes into consideration results
of the implementation assessment of the European Parliamentary Research Service (EPRS)
from 2020, which established that the transposition of the RWP at national level has led to
improved harmonisation of procedures, such as the frequency and content of vehicle
testing, and the provisions of the RWP Directives have enhanced the quality of periodical
technical inspections and roadside inspections, as well as road safety standards.
Regarding the contribution of the RWP to road safety, the evaluation considered all
available evidence and in particular corroborated the findings from desk research and
various independent studies on the role of technical defects in road safety, the results of
PTI in selected EU countries showing the link between improved technical condition of
the vehicles and increased road safety, with the evidence and views provided by the
stakeholders, which confirmed that the RWP plays a central role in maintaining high
vehicle standards and improving road safety, based on their most recent practical
experience with all three Directives of the package. It should be kept in mind though that
the effectiveness of the RWP regarding road safety has to be considered in the context of
an already high level of the roadworthiness testing legal framework and implementation in
the EU, and it should also be assessed as a complementary tool to relevant road safety
regulations (such as EU type-approval Regulations for motor vehicles) and other road
safety policy measures already in place.
46
ANNEX I: PROCEDURAL INFORMATION
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.
This initiative is included in the Commission Work Programme 202376
, item 3 in Annex II
(REFIT initiatives), under headline A – A European Green Deal.
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 202177
.
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.
Consultation of the RSB
The draft impact assessment and evaluation reports were submitted to the RSB on 15
November 2023 and were discussed by the Board on 13 December 2023.
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, consumer groups, NGOs,
European Parliament etc.
• Stakeholder consultation activities (see dedicated annex IV);
76
2023 Commission work programme – key documents (europa.eu)
77
Vehicle safety – revising the EU’s roadworthiness package (europa.eu)
47
• External support studies carried out by two independent consortia (the study supporting
the evaluation was led by VVA et al. and the one supporting the impact assessment was
led by Ricardo et al.). The external support studies will be published alongside this report.
• Commission experience in monitoring and implementing the Roadworthiness Package.
48
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED
1 Process
The starting point for the evaluation was the 2012 Impact Assessment accompanying the
proposal for a revision of the three Directives included in the Roadworthiness Package.
The IA has notably been used to define the intervention logic, the points of comparison,
and the overview of costs and benefits.
Against that background, this evaluation was based on a methodology consistent with the
Better Regulation Guidelines and Toolbox, with the support of an external study. Further
to the Call for evidence, the Commission launched the process for contracting the external
support study. The terms of reference provided a draft intervention logic and draft
evaluation questions to address the five evaluation criteria: relevance, effectiveness,
efficiency, and coherence and European added value, which were further refined during
the evaluation. The support study was undertaken by a consortium led by VVA Economics
& Policy, including Transport and Mobility Leuven (TML), TNO, VUFO and the
University of Leeds.
The intervention logic diagram (see Annex V) helps capture the logic of the RWP and the
causal chain linking problems, objectives, inputs and expected results. It provides the basis
for the development of the evaluation matrix (see Annex VIII) which sets out the following
aspects for each evaluation question:
• Operational questions, breaking down the evaluation questions into smaller, measurable
aspects.
• Indicators (quantitative or qualitative), providing the measures/metrics that correspond
to each operational sub-question,
• Data sources & methods, identifying the sources of data and information used to inform
the indicators and outlining the methodology used to answer the evaluation questions and
form the conclusions.
The evaluation matrix was reviewed several times during the study, taking into account
Commission inputs as well as evidence collection activities (desk research, interview
programme, survey responses and data requests), to reflect the identification and review of
data sources, as well as updated evidence needs and gaps and the improved understanding
of the mechanisms and structures leading to better targeted questions.
2 Methodological framework
2.1 Data collection
The data collection was undertaken in the course of the whole evaluation process with a
view to collate existing quantitative and qualitative evidence. A certain degree of flexibility
was ensured to deal with unexpected issues arising throughout the data collection phase
and in particular during the data analysis phase to cover any data gaps.
Desk research
The methodology used for the gathering of data consisted of collecting information from
published sources at EU and Member States level regarding statistical and monitoring data.
These included Eurostat and ACEA for vehicle fleet data, the EU CARE database for road
crashes, complemented by two other datasets: GIDAS (which is broadly representative of
49
crashes in Germany) and IGLAD (which is an aggregation of various global databases and
was useful to extract information for Austria, Czechia, France, Greece, Italy, Sweden,
Slovakia and Spain). The existing evidence provided in published literature played an
important role in supporting the evaluation in a number of thematic areas. An updated list
of sources is provided in Annex IX of the support study.
Field research – stakeholders consultation
Important part of the data collection phase has been realised through various stakeholder
consultation activities, performed by the Commission and the external consortium. The
design of the questionnaires and the specific questions addressed to the stakeholders groups
were developed on the basis of the evaluation matrix.
The Open Public Consultation (OPC) questionnaire was accessible on “Have Your Say”
webpage from 6 July to 28 September 2022. 907 replies including 29 position papers were
received; they were carefully reviewed and valuable insights and perspective were
extracted and used during the evaluation. The factual summary report is available on the
consultation page and further details on the OPC are presented in Annex IV.
The targeted consultation consisted of tailored-made surveys and interviews and
complemented the data gathered through desk research and OPC (the latter not being
representative).
Two online surveys were launched at the beginning of the evaluation support study and
targeted the stakeholder groups impacted by the legislation: on one side the EU
associations, consumer organisations, ministries of EU Member States, road safety
authorities and vehicle registrations authorities; and on the other side the PTI bodies
(centres authorised to conduct PTIs). 49 replies were received in total: 16 from EU
associations/consumer organisations/NGOs, 17 from ministries and national road safety
authorities, 5 from vehicle registration authorities and 11 from PTI bodies.
A number of 30 in-depth interviews with selected stakeholders allowed to explore specific
questions regarding the RWP in a more profound manner thanks to their qualitative nature.
2.2 Data analysis
Safety
To analyse the reduction of road fatalities and serious injuries in road transport during the
RWP period the analysis relied on the EU CARE Database. Despite the fact that vehicle
registration year was missing for some Member States, inconsistently provided, or
incomplete which was a limitation, the complete data available and used for the analysis
is a fair representation of the EU in terms of country sizes and geographical coverage. The
CARE database does not contain information on contributory factors in crashes, so it was
not possible to look directly at the role of vehicle faults in crash involvements. Therefore,
the overall research question asked whether the RWP reduced the proportion of
involvements by older vehicles, by comparing the relative share of involvements of older
vehicles in total involvements in the period before the implementation of the RWP. Data
for the period between 2016 and 2021 (the last year with data available) was examined.
Two categories were used to define older vehicles: vehicles aged 10 to 19 years at the time
of the crash and vehicles aged 20 years or more. Involvement by vehicles in these
categories was compared with total vehicle involvements. The results indicate that over
the period analysed, vehicles aged 20 years or more are involved in a higher share of fatal
crashes.
50
Emissions
PTI aims to identify high emitters that are then taken out of circulation or repaired, in order
to reduce the air pollutants from road transport.
During the evaluation support study, data on exhaust emission in real driving conditions
detected by remote sensing technology has been analysed. It has been estimated that the
share of vehicles with malfunctioning emission technology ranges from a few percents to
10%. Nevertheless, their contribution to pollution is considerable as PM and NOx
emissions are increasing by a factor of 10 to 100 for these vehicles. High emitters can
represent up to 80% of the total emission in PM, and up to 25% of the total emissions in
NOx, for particular euro classes and vehicle categories.
Detailed data available for 3 Member States show that for the years 2019-2021, an average
of 0.7% of vehicles failed the emission test during PTI in Denmark, 0.9% for petrol engines
and 0.4% for diesel engines in Finland and 0.62% for petrol engines and 0.36% for diesel
engines in The Netherlands.
51
ANNEX III. OVERVIEW OF BENEFITS AND COSTS
Table 9: Overview of costs and benefits identified in the evaluation
Citizens/Consumers Businesses Administrations
Quantitati
ve
Comment Quantit
ative
Comment Qua
ntitat
ive
Comment
COSTS
Administrative costs
(per year relative to the
baseline)
EUR 10
billion in
2019.
This covers
both citizens
and
businesses.
Only part of
these costs
was
experienced
by citizens.
- Part of the costs
EUR 10 billion
in 2019 were
experienced by
businesses.
-
Enforcement costs:
(costs associated with
activities linked to the
implementation of an
initiative such as
monitoring, inspections
and adjudication/
litigation)
- - - - - MS administrations
faced costs related
to the enforcement
procedures, training
of highly qualified
inspection
personnel,
investments in
necessary
equipment and
materials, analysing
statistical data from
technical controls,
and monitoring of
inspector activities,
including the
supervision of
testing centres and
verification of
inspectors
BENEFITS
Direct benefits (such as
improved well being:
changes in pollution
levels, safety, health,
employment; market
efficiency)
EUR 13.4
billion in
2019, of
which
EUR 12.7
billion
external
costs
savings
The
reduction in
external
costs
savings for
accidents
and air
pollution
represent
- - - -
52
related to
accidents
and EUR
0.7
billion
external
costs
savings
related to
air
pollution
benefits for
the society
at large.
Indirect benefits (such
as wider economic
benefits,
macroeconomic
benefits, social impacts,
environmental impacts)
- - - - - -
53
ANNEX IV. STAKEHOLDERS 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 criteria of relevance, effectiveness, efficiency,
54
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.
55
• 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 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 10: 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
56
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 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.
57
• 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'
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
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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.
• 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
59
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.
• 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.
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• 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 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 10.
61
Figure 10: 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 11. 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 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.
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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’
63
Associations (FEMA) argued that 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 12. 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 13. 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
64
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 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.
65
A common argument in favour of more frequent testing for N1 vehicles, which were
mentioned in different consultation exercises, wase 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 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
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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 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
67
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 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
68
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 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
69
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 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
70
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’).
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
71
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 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
72
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 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
73
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 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.
74
75
ANNEX V. INTERVENTION LOGIC
76
General
Objectives
To contribute to
the increased
road safety, in
particular by
decreasing
fatalities in road
transport by
increasing the
quality and better
coordinating
national PTI and
roadside
inspection
systems
Specific Objectives
Increase the scope and
the level of
requirements for
roadworthiness testing
and roadside controls
across the European
Union
RESULTS
Increased detection of
defects ,and fewer vehicles
in circulation with
dangerous defects
Citizens benefit from mutual
recognition of RW
certificates when buying or
re-registering a vehicle.
Roadside testing better
targeted at vehicles/fleets
with a higher risk profile
More consistent, objective
and high quality testing
throughout the Union
Greater assurance for
citizens buying used vehicles
Reduced admin burden and
easier exchange of
information between MS
IMPACTS
Fewer heavy polluting
vehicles in circulation
Fewer road
deaths and
fatalities
Reduction of the
emissions of GHG
and air pollutants
from road
transport
Create the appropriate
framework for
seamless flow of
information between
actors and Member
States involved in the
enforcement of PTI
results
The reduction of
greenhouse
gases and air
pollutant
emissions from
road transport by
detecting more
effectively and
removing from
circulation
vehicles which
are over-
polluting because
of technical
defects
Increased scope of Periodic
and Roadside Inspections
Facilitate the free
movement of EU
citizens and the
smooth
functioning of the
Internal Market
Improved
functioning of the
Internal Market
Problem
Too many
vehicles with
technical defects
present on EU
roads, with
negative impact
on road safety
and environment
Too narrow
scope,
level of
requirements for
roadworthiness
testing and
roadside controls
too low
Problem
drivers:
The information
and data not
exchanged
between the
concerned
actorstrols too
low
Outputs
Common minimum
standards for PTI /RSI
testing, inspectors, and
Compulsory testing of high
speed tractors and PTIs for
powerful motorcycles
Electronic safety
components included in
the PTI
Measures to combat
odometer fraud
MS required to recognise
the validity of equivalent
RW certificates issued in
other MSs when a vehicle
Two-step roadside
inspection system
Risk rating system
extended to roadside
77
ANNEX VI. SUMMARY OF CURRENT LEGISLATIVE FRAMEWORK
Directive 2014/45/EU (PTI Directive)
It establishes a comprehensive framework for ensuring the safety and environmental
performance of vehicles circulating on European roads and outlines specific activities and
responsibilities for various stakeholders, including EU Member States, in order to achieve
harmonised standards and practices across the EU.
It entails regular and systematic roadworthiness testing of vehicles to identify potential
safety and environmental risks. These periodic tests are conducted at testing centres and
aim to assess the overall condition of vehicles, including their components, systems, and
emissions.
The requirements laid out in the directive apply to the following types of vehicles capable
of speeds of more than 25 km/hour:
• Passenger cars and light commercial vehicles (categories M1 and N1). To be
tested 4 years after first registration and thereafter every 2 years.
• Vehicles in category M1 used as taxis or ambulances, buses or minibuses (M2,
M3), heavy goods vehicles (N2, N3) and heavy trailers (O3, O4). To be tested 1
year after first registration and thereafter yearly.
• Wheeled tractors with a design speed above 40 km/h (T1b, T2b, T3b, T4.1b,
T4.2b and T4.3b) and used mainly public roads . To be tested 4 years after first
registration and thereafter every 2 years.
• Two- or three-wheeled vehicles (category L3e, L4e, L5e, and L7e) with a
combustion engine larger than 125 cm3
haves to be tested from 2022, unless
Member States notify to the Commission an exemption from testing for such
vehicles, and road safety statistics for the previous 5 years show that the same level
of road safety could be achieved by alternative measures.
In certain circumstances, member States or inspection authorities may require vehicles to
undergo a test before the due dates. These circumstances include:
• after an accident;
• when the holder of the registration certificate has changed;
• when the safety and environmental systems and components of the vehicle have
been altered or modified
• When the vehicle reaches a mileage of 160,000 km; and
• in cases where road safety is seriously affected.
Certain types of vehicles may be exempted from roadworthiness tests, including:
• vehicles of historic interest;
• diplomatic vehicles;
• vehicles used by the armed forces, police, customs, fire services or for agricultural
and forestry purposes only; and
• vehicles used exclusively on small islands.
78
Member States are responsible for establishing and maintaining a national system of
periodic roadworthiness testing that complies with the requirements set out in the directive.
In particular, they have to, ensure that authorised testing centres meet the required
standards, and are conducting appropriate checks to monitor their performance, ensuring.
They have to implement the required frequency of tests, where needed using the flexibility
provided by the Directive. Also, they shall set rules to further detail content and methods
of the tests, as well as the qualifications and training requirements for testers.
Additionally, they are tasked with establishing effective systems for registering and
maintaining records of the results of roadworthiness tests.
Furthermore, the directive requires ensuring the independence and impartiality of the
testing centres, preventing conflicts of interest, and to guarantee that the testing centres
operate in a fair and transparent manner. To facilitate cross-border mobility and ensure the
harmonisation of standards, the directive also encourages cooperation and information
exchange among Member States including records of roadworthiness tests,
The directive places responsibility on vehicle owners to present their vehicles for
roadworthiness testing in accordance with established requirements and timelines, and to
ensure that their vehicles are always maintained in a safe and roadworthy condition.
Defects are classified as minor, major or dangerous, with minor defects being
insufficient to fail vehicles. Where defects are dangerous, the use of the vehicle on public
roads may be suspended until the fault is rectified.
When a vehicle already registered in another Member State is re-registered, its
roadworthiness certificate must be recognised by other Member States.
To detect odometer fraud (manipulating the device used to measure distance travelled),
data from the preceding roadworthiness test is to be made available to the inspectors.
Manipulating the odometer is a punishable offence.
The directive had to be transposed into national law by 20 May 2017, and it applied from
20 May 2018.
Directive 2014/46/EU on vehicle registration documents (amending Directive
1999/37/EC - “VRD directives”)
In order to provide a comprehensive overview of the legislation on vehicle registration
documents, this summary includes the provisions of the 2014 Directive and the 1999
“mother” Directive.
The VRD Directives outline the required activities and responsibilities of the authorities in
the Member States to ensure efficient and harmonised processes for vehicle registration
and documentation. The directives aim to facilitate the free movement of vehicles within
the EU while ensuring proper identification, traceability, and compliance with legal and
administrative requirements.
79
Member States are required to keep an electronic record of data on all vehicles registered
on their territory, including the outcome of mandatory PTIs and the period of validity of
the PTI certificate
Member States shall issue a registration certificate for vehicles which are subject to
registration under their national legislation. The Directives provide that the registration
certificate issued by a Member State shall be recognised by the other Member States for
the identification of the vehicle in international traffic or for its re-registration in another
Member State.
The Member States must issue registration documents in a standardised format that contain
essential information about the vehicle, such as its identification number, technical
characteristics, and information about the holder (and optionally the owner) of the
registration certificate.
Where a Member State’s competent authority is notified that a roadworthiness test shows
the authorisation to use a particular vehicle has been suspended, this suspension must be
recorded electronically and an additional roadworthiness test carried out. The suspension
is effective until a new roadworthiness test has been passed successfully.
The directives emphasise the importance of cooperation and information exchange among
Member States, in particular so as to check, before any registration of a vehicle, the legal
status of the vehicle in the member state in which it was previously registered.
Directive 2014/47/EU (RSI Directive)
Directive 2014/47/EU on technical roadside inspections provides the legal framework for
Member States to implement technical roadside inspections of commercial vehicles. These
inspections focus on assessing the technical condition of vehicles, including their
components, systems and equipment.
The requirements set out in the directive apply to the following types of vehicles: capable
of speeds of more than 25 km/hour:
• Taxis, ambulances, buses and minibuses (M2, M3);
• heavy goods vehicles (N2, N3);
• heavy trailers (O3, O4); and
• wheeled tractors with a design speed above 40 km/h (T1b, T2b, T3b, T4.1b, T4.2b
and T4.3b) and used mainly public roads for commercial road haulage purposes.
Member States may also carry out inspections on vehicles not covered by this Directive,
such as light commercial vehicles, or carry out inspections in places other than public
roads.
Member States play a key role in implementing and enforcing the provisions of the
directive. They are responsible for establishing a system of technical roadside inspections
within their territories, including the designation of competent authorities and inspection
bodies. Member States must ensure that the designated bodies have the necessary expertise,
resources and equipment to conduct effective inspections.
80
Member States are also responsible for establishing rules regarding the content and
methods of the inspections, as well as the qualifications and training requirements for the
personnel involved in conducting them. Competent authorities are responsible for
supervising and monitoring the activities of inspection bodies to ensure their compliance
with the directive. They must carry out regular assessments of the inspection bodies'
performance and take corrective actions if deficiencies are identified.
Inspections comprise initial and, where necessary, more detailed inspections focusing
in particular on brakes, tyres, wheels and chassis, as well as nuisances (noise, exhaust
emissions, etc.). The rate of initial inspections is expected to be proportionate to the
number of vehicles registered in each EU country. The aim is for at least 5 % of all
commercial vehicles registered in the EU to be inspected (initial inspection) each year.
Inspectors must not discriminate on grounds of the nationality of the driver or of the
country of registration when selecting a vehicle for inspection. They must be free from any
conflict of interest that might compromise their impartiality, and remuneration must not be
dependent on the outcome of their inspections.
Risk-rating system - From 2019, EU countries must introduce information on deficiencies
found during RSI tests into the risk-rating system, enabling Member States to check
undertakings with a high-risk profile more closely and frequently.
The Directive includes principles for inspections and applicable standards for (optional)
testing of cargo securing,
Defects are classified as minor, major or dangerous. Any major or dangerous deficiency
revealed by an inspection must be rectified before the vehicle is further used on public
roads.
Furthermore, the directive emphasises the importance of cooperation and coordination
among Member States to ensure consistent inspection practices and to prevent non-
compliant vehicles from circulating within the EU. This includes sharing inspection
results, identifying repeat offenders and collaborating on cross-border enforcement
activities. Member States are required to designate a contact point to ensure information
exchange and assist the contact points of other Member States.
Member States are required to define the responsibilities of undertakings to maintain
vehicles in a safe and roadworthy condition.
In addition, Member States shall require undertakings and drivers to cooperate with the
inspection authorities during roadside inspections, and to provide access to the vehicle, its
parts, and all relevant vehicle documentation. Furthermore, competent authorities are
responsible for monitoring the number of roadside inceptions and reporting to the
European Commission on a biannual basis.
81
ANNEX VII. THE MINIMUM REQUIREMENTS SET OUT IN THE DIRECTIVES AS EXCEEDED
BY SOME MEMBER STATES
During the evaluation, the Commission contacted Member States to identify the matters in
which the Member States had exceeded the minimum requirements as set out in the
Directives. The responses from Member States illustrate that there are several areas in
which at least some Member States exceed the minimum requirements, as permitted by the
Directives.
PTI Directive
• On the scope, BG, BE, DE, EE, ES, FI, HR, HU, LT, LV, SE, SI and SK.
• On the frequency of tests, AT, BG, BE, DE, EE, ES, FI, HR, LV, NL, SE, SI and
SK.
• On the contents of testing:
➢ On the braking equipment, AT, BG, DE, ES, FI, HR, LV, SE and SK.
➢ On the steering, AT, BG, ES, LV, SE and SK.
➢ On the visibility, AT, BG, ES, IE, SE and SK.
➢ On the lighting equipment and parts of the electrical system, AT, BG, DE, ES, FI,
LV, SE and SK.
➢ On the axles, wheels, tyres, suspension, AT, BG, BE (partially), ES, FI, IE, LV, SE
and SK.
➢ On the chassis and chassis attachments, AT, ES, LV, SE and SK.
➢ On other equipment, AT, ES, SE and SK.
➢ On nuisance, AT, BE, DE, ES, NL, SE and SK.
➢ On supplementary tests for passenger-carrying vehicles of categories M2 and M3,
AT, BG, DE, ES and SE.
• On inspectors (competence and training), AT, BG, DE, EE, ES, FI, IE, LV and SE.
• LV has introduced specific training requirements for testing electric vehicle.
• AT, EE, ES, FI, LV, NL and SK have introduced electronic roadworthiness
certificates.
RSI Directive
AT, BE78
, EE, ES, FI, HR, HU, LV, PL, RO, SE and SK include vehicles currently outside
the scope .
VRD Directive
AT, BG, BE79
, DE, FI, HR, HU, LT, LV, NL, PL and SI regularly update vehicle data.
78
Flanders
79 Brussels and Flanders
82
ANNEX VIII. EVALUATION MATRIX AND THE EVALUATION QUESTIONS
Q1: To what extent do the scope and objectives of the intervention remain relevant for current and future
needs?
Operational sub-questions
• Is there still a need to improve road safety?
• Is there still a need to reduce the emissions GHG and air pollutants from road transport over the whole
lifetime of vehicles?
• Is there still a need to facilitate the free movement for EU citizens and smooth functioning of the internet
market?
Judgement criteria
• Road safety and environmental protection are important considerations for EU citizens.
• EU citizens consider that PTI and roadside inspections are necessary to safeguard road safety and air quality.
• There is still pollution from vehicles because of substandard repair, malfunctioning and tampering of the
emission control systems.
• There are still accidents and fatalities due to defects in vehicles.
• Stakeholders consider that the facilitation of the free movement for EU citizens and smooth functioning of
the internal market are still important
Indicators Sources
• Number of
accidents
due to
defects.
• Share of
pollution
from road
transport by
high
emitting
vehicles,
with
malfunctioni
ng emission
control
systems.
• Number of
positive
opinions on
the relevance
of each sub-
question in
the survey
• Number of
free moving
people
within the
EU
• Targeted interviews
• Survey
• Desk research
• Data analysis (databases)
Targeted
interviews
Interviews
with:
Inspection
bodies (PTI)
Market
surveillance
authorities
CITA
National
vehicle
emission
prognoses and
authorities
Agencies
responsible for
transport, road
safety, air
quality, and
law
enforcement
Survey
Relevant
stakeholders
:
Police
Urban
authorities
Inspection
bodies (PTI)
Agencies
responsible
for
transport,
road safety,
air quality,
and law
enforcement
Desk research
Academic studies
- Martín-de los Reyes LM, Effect of
Periodic Vehicle Inspection on Road
Crashes and Injuries: A Systematic
Review. Int J Environ Res Public
Health. 2021
Roadside observation reports
National PTI reports
National regulations
Vehicle safety reports
Official reports, especially at EU-
level, MS-level authorities such as:
• OECD, Road Safety – Annual
Report 2021,
• ISTAT, Road accident, Italy,
(2021) link
• Spanish Interior Ministry,
Number of fatalities by type of
vehicles, link
• INNSSE, Road accident,
Romania, (2017), link
• French Government, Road
Safety Review 2021, link
Academic and scientific literature
and articles;
Position papers, e.g. from technical
expert associations
Data analysis
(databases)
IGLAD / Initiative for
the Global
Harmonisation of
Accident Data
EU Data (CARE)
Accident databases
(GIDAS)
Remote Sensing
databases for typical
fleet average emission
performance
CONOX/CARES
database and study
data
Q2: To what extent are the 3 Directives still relevant for the wider EU policy goals, and to the objectives of the
intervention?
Operational sub-questions
83
• How are road safety, environmental protection and free movement articulated in current EU policy goals,
such as the European Green Deal, Fit-for-55, Market Surveillance, Euro 7, improving air quality and
reducing GHG emissions?
• To what extent is 2014/45/EU relevant for the EU policy goals related to road safety, air quality, and free
movement? Have these goals evolved since the adoption of the RWP, and if so, in what way?
• To what extent is directive 2014/46/EU on the registration documents for vehicles relevant for the EU policy
goal of free movement? Have these goals evolved since the adoption of the RWP, and if so, in what way?
• To what extent is 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial
vehicles circulating relevant for the EU policy goals related to road safety and air quality? Have these goals
evolved since the adoption of the RWP, and if so, in what way?
Judgement criteria
• Road safety and environmental protection are still important, relevant, and well-integrated in current EU
policy goals.
• Evidence of the importance of free movement for the EU, especially in the context of information exchange
mutual recognition of inspection certificates.
• Periodic technical inspection is relevant to the EU policy goals related to road safety and air quality
• Roadside inspection is relevant to the EU policy goals related to road safety and air quality.
Indicators Sources
• Progression towards
EU targets in terms
of road safety (Zero
casualty by 2050)
and air quality
• Statistics on the PTI
tests, high emitting
vehicles, and
vehicles registered in
the EU
• The use of cross-
border registration
documents for EU
citizens moving free
in Europe
• Targeted interviews
• Survey
• Desk research
Targeted
interviews
Interviews with:
DG MOVE
Expert Group
MEPs from
Transport
Committee
Survey
Relevant stakeholders:
Road users’ associations
Cities participating in the
Climate-Neutral and
Smart Cities Mission,
Eurocities
POLIS
Desk Research
EU policies (Fit for 55, Green Deal,
Vision 0, etc…)
Official reports, especially at EU-
level, MS-level authorities
Academic and scientific literature and
articles
Position papers, e.g. from technical
expert associations
Q3: How well adapted is the intervention to the technological, environmental, and scientific advances that have
appeared since its introduction?
Operational sub-questions
• Do the current directives sufficiently address changes in the composition of vehicle fleets due to changes in
vehicle powertrains and emission control technologies?
• Do the current directives sufficiently address technological advancement in automated and smart mobility,
such as ADAS systems and other technologies?
• Are the current directives sufficiently advanced in their approach with regard to the digital evolution of
today (the IoT, connectivity, on-board computer, etc)
Judgement criteria
• The directives of the roadworthiness package address technological, environmental, and scientific advances,
including changes in the composition of vehicle powertrains emission control technologies, and OBD.
• The European goals on the shift towards zero-emission vehicles, as laid out in the European Green Deal
and subsequent targets and frameworks like Euro-7 for cleaner vehicles.
Indicators Sources
• Data on real-world
environmental
performance of different
powertrains1
• Targeted interviews
• Survey
• Desk research
84
•
Data on the safety
concerns regarding
vehicle batteries in EVs2
•
Data on the safety
concerns regarding
misaligned and/or
defective
sensors/hardware of
safety assistance systems
and automated driving
systems3
•
Data on the impact of
defects and poor
maintenance on the
performance of ADAS
and ADS4
Targeted interviews
Targeted stakeholders:
Vehicle
manufacturers
associations
CITA
Testing equipment
providers
DG MOVE Expert
Group
UNECE Working
Groups
ETSC
Type approval
Authorities (safety
systems)
CLOVE consortium
on Euro-7
implementation
Parties participating
in development of
national PTI
improvements
Survey
Targeted stakeholders:
Vehicle manufacturers
associations
CITA
Testing equipment
providers
DG MOVE Expert
Group
UNECE Working
Group
Desk Research
Mapping of new systems and
powertrains and whether they
are covered by the directives
Available studies on the links
between defects and the
performance of ADAS and ADS
Official reports, especially at
EU-level, MS-level authorities
Academic and scientific
literature and articles
Position papers, e.g. from
technical expert associations
Q4: Have the circumstances changed in the meantime so much that the intervention has to change/adapt to
them?
Operational sub-questions
• What are the implications of knowledge about the real-world environmental performance of vehicles for
the intervention of the three Directives?
• What are the implications of new vehicle safety standards?
• What are the implications of mandatory on-road tests?
• What are the implications of ADS and ADAS in terms of PTI and maintenance? Is there a need for self-
check features on these new systems?
Judgement criteria
• There is a need to expand or modify the intervention in the light of the new challenges occurred or what
has been learned.
Indicators Sources
• Data on real-world
vehicle emissions and
effects of undetected
malfunctions and
tampering on air
quality
• Reliability of ADAS
systems
• Frequency of software
updates necessary to
ensure ADAS
performance
• Cybersecurity
requirements to
mitigate risks
• Targeted interviews
• Desk research
Targeted interviews
Targeted stakeholders:
Inspection bodies
CITA
ACEA/CLEPA
ETSC
ERMES5
T&E
Desk Research
GIDAS database
CITA SET I and CITA SET II studies
(https://citainsp.org/studies/4259-2/)
ADAS/ADS investigations by NTSB6
and NHTSA7
Road Performance Reports (OECD/International Transport
Forum, UN high-level meetings on road safety, etc.)
Official reports, especially at EU-level, MS-level
authorities
Academic and scientific literature and articles
Position papers, e.g. from technical expert associations
Effectiveness
Q5: To what extent have the three Directives been effective in improving road safety and contributing to the
reduction of road fatalities and serious injuries in road transport, in line with the EU Road safety policy
framework 2010 to 2020, as well as to its successor?
85
Operational sub-questions
• Compared to what would have happened in absence of the three Directives, in quantitative and qualitative
terms, to what extent have road fatalities and serious injuries decreased?
• To what extent did fatal and serious crashes change at the EU level in terms of absolute numbers considering
vehicle age and vehicle type variables?
• To what extent did involvements in fatal and serious crashes change at the Member States’ level in terms
of absolute numbers considering vehicle age and vehicle type variables?
Judgement criteria
• Changes in the involvement of defective vehicles after the implementation of the directives. The reduction
of defects, improved control and detection of malfunctions with environmental and safety risks (see “data
analysis” on page 18 and 19).
• Vehicle roadworthiness affects and will continue to affect road safety and environmental performance.
Indicators Sources
• Involvements of
older vehicles in
accidents of
different
severities
• Share of vehicles
found with
defects in PTI
• Share of vehicles
found with
defects in
roadside
inspections
• Proportion of
vehicles found
failing emission
test at PTI
• Accident analysis
• Desk research
• Targeted interviews
Targeted
interviews
Targeted
stakeholders:
National Police
Authorities
National Road
Safety Authorities
Accident analysis
EU Data (CARE)
GIDAS database
IGLAD / Initiative
for the Global
Harmonisation of
Accident Data
Desk Research
National reports on road safety
Roadside inspections reports
PTI reports
Official reports, especially at EU-level, MS-
level authorities
Academic and scientific literature and
articles
Position papers, e.g. from technical expert
associations
“Grey literature”, such as publications by
relevant research centres and think tanks
Q6: To what extent have the three Directives been effective in increasing the detection of defects and to reduce
the number of vehicles in circulation with dangerous defects?
Operational sub-questions
• Compared to what would have happened in absence of the three Directives, in quantitative and qualitative
terms, to what extent are PTI and roadside inspections able to detect defects and fraud?
• To what extent did the detection of defects at EU level and member state level increase?
• To what extent did the number of vehicles in circulation with dangerous defects decrease?
Judgement criteria
• Increase in the detection of vehicle defects in the PTI and the RSI after the implementation of the RWP.
Indicators Sources
• Number of periodic tests by
member states each year
• Targeted interviews
• Desk research
86
• Number of vehicle defects
detected in PTI each year
• Number of roadside
inspections each year
• Number of vehicle defects
detected in RSI each year
• Removals of vehicles with
serious defects vehicles from
operation
• Age of vehicles when put out
of circulation
Targeted interviews
Targeted stakeholders:
Inspection bodies
CITA
Desk Research
Reports by Member States
National reports on road safety
MS National Institutes of Statistics
Roadside inspections reports
PTI reports
Official reports, especially at EU-level, MS-level
authorities
Academic and scientific literature and articles
Position papers, e.g. from technical expert
associations
“Grey literature”, such as publications by relevant
research centres and think tanks
Q7: To what extent have the three Directives been effective in contributing to the reduction of the emissions of
GHG and air pollutants from road transport, and to moving towards eliminating the "gross emitting" vehicles
from the fleet?
Operational sub-questions
• Are current PTI tests able to detect malfunctions and tampering leading to high emissions of air pollutants?
• Compared to what would have happened in absence of the three Directives, to what extent have emissions
of GHG and air pollutants from road transport decreased, in particular Euro-7 and fuel consumption
monitoring?
Judgement criteria
• Evidence on detection of high-emitting vehicles
• Reduction in of the emissions of GHG and air pollutants from road transport due to the implementation of
the Directives, by detecting high emitting vehicles in the fleet as not-roadworthy.
Indicators Sources
• Rate of detection
of malfunctions
and tampering
from great
emitters during
PTI tests
• Emission share of
gross emitters in
the fleet, well
above the type-
approval limits
and EOBD
requirements.
• Sensitivity of
current tests to
relevant emission
levels
• Level of in
emissions of GHG
and air pollutants
from road
transport
• Targeted interviews
• Survey
• Desk research
• Data analysis (databases)
Targeted
interviews
Targeted
stakeholders:
Environmental
Associations/
ONG
Municipalities
National
Ministries of
Environment
Environmental
agencies
DG ENV
DG CLIMA
DG MOVE
Survey
Targeted
stakeholders:
Environmental
Associations/ ONG
Municipalities
National Ministries
of Environment
POLIS
Desk research
EEA – European
Environment
Agency reports
World Health
Organisation
OECD
Academic and
scientific literature
and articles
Position papers,
e.g. from technical
expert associations
Data analysis
(databases)
World Health
Organisation
Remote Sensing
databases for
typical fleet
average emission
performance
CONOX database
National Institutes
of Statistics
Q8: To what extent have the Directives 2014/46/EU, 2014/45/EU and 2014/47/EU improved the framework for
exchange of information between actors and Member States involved in the enforcement of testing results?
Operational sub-questions
• What information is being exchanged with respect to the mandatory parts in the directive?
87
• Are other Member States than those where vehicles are registered able to effectively enforce roadworthiness
in cross-border use?
• Is the level of exchange of information improved?
Judgement criteria
• Exchange of information – quantitative evolution of information flows and qualitative assessment of
stakeholders
• Remaining obstacles to information exchange
Indicators Sources
• Increase in
information
exchange
• Incidence of failures
to acquire desired
information
• The number of
Member States that
allows for electronic
exchange
• Targeted interviews
• Survey
• Desk research
Targeted Interviews
Targeted stakeholders:
National Authorities
Inspection bodies (PTI)
Surveys:
Targeted stakeholders:
National Authorities
Inspection bodies (PTI)
Desk Research:
European Court of Justice
decisions
EUCARIS database
Reports from member states
Q9: To what extent have the three Directives been effective in improving the consistency, objectivity, and
quality of testing throughout the Union?
Operational sub-questions
• What is the trend in test frequency?
• What is the trend in test quality?
• What is the trend in test consistency throughout the union?
Judgement criteria
• The tests are more frequent and more comprehensive (test and inspection frequency, manhours and number
of items checked during inspection)
• The number of differences between the tests among MS is limited.
Indicators Sources
• Change in frequency of tests
• Regularity of tests (1 Y, 2 Y,
etc)
• Quality of tests- number of
items checked
(thoroughness) and level of
training required for
accredited providers
• Time spent on PTI testing
the vehicle in manhours
throughout the union
• Targeted interviews
• Desk research
• Consultation with CITA
Targeted interviews
Targeted stakeholders:
National Authorities
Inspection bodies (PTI)
Agencies responsible for
transport and road safety
Desk research
Reports by member
states
Member States’ testing
protocols
Consultation with
CITA
Q10: To what extent have the three Directives been effective in facilitating free movement for EU citizens/ and
smooth functioning of the Internal Market?
88
Operational sub-questions
• Have the directives made it easier for citizens to register vehicles in another MS when they move
permanently?
• How have the directives contributed to smooth functioning of the Internal Market?
Judgement criteria
• Principles of safe movement and the Internal Market, investigating the correspondence between free
movement and the Directives
• Assessment of unfair competition from tampered vehicles
Indicators Sources
• Member States feedback
• Stakeholder feedback
• Number of cross border
registrations per year (for
the few countries where this
data is available)
• Targeted interviews
• Desk research
Targeted Interviews
Targeted stakeholders:
National inspection bodies
National Authorities
Agencies responsible for transport
and road safety
European vehicle register
implementation (EUCARIS)
Desk Research
Data on tachograph tampering
ECJ cases regarding export of
vehicles
Consultation by EC in 2021
Q11: Which factors have driven or hindered the achievement of objectives?
Operational sub-questions
• What are the driving forces behind the achievements of the roadworthiness package?
• What are the obstacles for the roadworthiness package to achieve its objectives?
Judgement criteria
• impact of the obstacles have to be significant.
• impact of the drivers have to be significant.
Indicators Sources
• Severity,
magnitude of an
obstacle
• Scale of an
obstacle
• Magnitude of a
driver
• Targeted interviews
• Survey
• Desk research
Targeted
interviews
Targeted
stakeholders:
EU
Commission
National
Authorities
Road
Associations
CITA
Survey
Targeted
stakeholders:
National
Authorities
Road Associations
CITA
Desk research
Published studies and reports on cross-border
information exchange
Consultation by EC in 2021
- European Commission, Vehicle safety –
revising the EU’s roadworthiness package,
Inception impact assessment, link
Official reports, especially at EU-level, MS-level
authorities
- European Parliament, Implementation of the
roadworthiness package, 2020, link
Academic and scientific literature and articles
Position papers, e.g. from technical expert
associations
89
“Grey literature”, such as publications by relevant
research centres and think tanks
Q12: What implementation measures have been introduced in the Member States in order to ensure the
effectiveness of the three Directives? Are there any significant differences in implementation measures and
effectiveness across the Member States? Is national transposition law sufficiently clear and enforceable to work
in practice?
Operational sub-questions
• Which implementation measures have the member states introduced?
• What is the pattern between characteristics of implementation measures and effectiveness across member
states?
• How does the member states implementation measures and transposition laws work in practice?
• What are the obstacles, if any, to implementation at national level?
Judgement criteria
• Effective implementation measures across member states
• Implementation success measure by the effectiveness of the directives.
Indicators Sources
• Relation between
effective
implementation
measures and
effectiveness
• Measures adopted in
compliance with
Directive 2014/45/EC
• Measures adopted in
compliance with
Directive 2014/46/EC
• Measures adopted in
compliance with
Directive 2014/47/EC
• Measures lacking with
respect to Directive
2014/45/EC
• Measures lacking with
respect to Directive
2014/46/EC
• Measures lacking with
respect to Directive
2014/47/EC
• Targeted interviews
• Survey
• Desk research/ member state reports
• Responses to OPC consultation by EC
Targeted
interviews
Targeted
stakeholders:
MS with varying
practices
(number of
roadside
inspections, date
of first
inspection and
frequency of
subsequent
ones,
inspections
houses vs. local
garages, etc)
Survey
Targeted
stakeholders:
MS authorities
(e.g. RDW/Dutch)
Inspection
bodies/Police
Desk research:
Member States’
relevant
legislation
Member States
reports
Commission
implementation
reports
Responses to
OPC
consultation
by EC
Efficiency
Q13: To what extent, and in respect of which specific aspects, have the three Directives generated costs and
benefits, for the relevant national authorities, citizens and businesses? To what extent have the cost associated
with the three Directives been proportionate to the overall benefits achieved?
Operational sub-questions
• What are the benefits of the implementation of the roadworthiness package for the relevant national
authorities, citizens, and businesses?
• What are the costs of the implementation of the roadworthiness package for the relevant national authorities,
citizens, and businesses?
Judgement criteria
• Estimation of costs and benefits
90
Indicators Sources
• Costs
incurred
compared to
monetised
benefits
• Targeted interviews
• Survey
• Desk research
• Data analysis (databases)
Targeted
interviews
Targeted
stakeholders:
Consumers’
groups
(BEUC)
FIA
Road
transport
companies/as
sociations
Survey
Targeted
stakeholders:
Consumers’
groups
FIA
Road
transport
companies/as
sociations
Desk research
Reports from
members states
(Academic) studies
Hidden costs
(maintenance
scrappage)
Position papers, e.g.
from technical expert
associations
IA report on the RWP
in 2012
Data analysis (databases)
Accident databases (GIDAS)
EU Data (CARE) database
IGLAD
National Institutes of Statistics
Methods of internalisation of
external costs of transport
Q14: What is the administrative burden for Member States generated by the three Directives? Is there a
potential in the Member States to simplify and reduce administrative burden without undermining the
intended objectives of the Directives?
Operational sub-questions
• What are the administrative costs, time, and red tape of the implementation of the roadworthiness package
for the relevant authorities in the member states?
• What are the identified best practices in terms of administrative burden in relation to the implementation of
the roadworthiness package?
Judgement criteria
• Additional administrative burden created by the three directives
Indicators Sources
• Efficiency in achieving
outcomes
• Administrative cost
• Manhours spent on
inspection
• Level of digitalisation of
administration
• Survey of member states
• Stakeholder views
Survey of member states
Targeted stakeholders:
National Authorities
Stakeholder discussion
Targeted stakeholders:
National Authorities
Road transport associations
Consumer Associations
Q15: What is the administrative burden for citizens and businesses generated by the three Directives? Is there
a potential to simplify and reduce administrative burden for citizens and businesses without undermining the
intended objectives of the Directives?
Operational sub-questions
• What are the administrative costs of the implementation of the roadworthiness package for citizens and
businesses?
• What are the identified best practices in terms of administrative burden in relation to the implementation of
the roadworthiness package?
Judgement criteria
• Additional administrative burden created by the three directives
Indicators Sources
91
• Efficiency in achieving
outcomes, by assessing
the costs and benefits
for citizens and
businesses
• Cost of implementation
by MS per capita over
average cost
• Time spent at inspection
by citizens
• Increase in cost for
owner by RWP
• Stakeholder discussion e.g., with organisations representing transport
companies and civil society
• Stakeholder organisations around national implementations of PTI
(e.g. SMO/Netherlands)
Stakeholder discussion
Targeted stakeholders:
ACEA
IRU
ITF
FIA
Consumer organisations such as BEUC
Coherence
Q16: To what extent are the three Directives’ objectives coherent with the objectives of relevant EU legislation
and policies in the field of EU road safety, such as the EU safety Road Policy Framework 2021-2030, and the
Sustainable and Smart Mobility Strategy?
Operational sub-questions
• What is the degree of coherence, overlap, and gaps between the three Directives’ objectives and relevant
EU legislation and policies in the field of EU road safety?
• What is the degree of coherence, overlap, and gaps between the three Directives’ objectives and relevant
EU legislation and policies in the field of environment and climate?
• What is the degree of coherence, overlap, and gaps between the three Directives’ objectives and relevant
EU legislation and policies in the field of free movement?
Judgement criteria
• Alignment of the objectives of the three directives of the roadworthiness package with current EU policy
goals and targets, including Vision 0 on road safety
Indicators Sources
• Changes in EU
policies that would
justify changing the
elements of the
package
• Targeted interviews
• Discussion with DG MOVE
• Desk research
Targeted
interviews
Targeted
stakeholders:
EURONCAP
ETSC
T&E
ACEA
Desk research
EU legislation and policies in the field of EU road safety, including
EU safety Road Policy Framework 2021-2030
Official reports, especially at EU-level, MS-level authorities
- European Parliament, Impact Assessment, 2012, link
- European Parliament, REPORT on the EU Road Safety
Policy Framework 2021-2030 – Recommendations on next
steps towards ‘Vision Zero’, link
- European Commission, Report on the application by the
Member States of Directive 2000/30/EC of the European
Parliament and of the Council of 6 June 2000 on the
technical roadside inspection of the roadworthiness of
Commercial vehicles circulating in the Community-
Reporting period 2017- 2018, 2020, link
Academic and scientific literature and articles
Position papers, e.g. from technical expert associations
- ETSC, Mid Term Review of the European Commission’s
Road Safety Policy Orientations 2011-2020, link
92
Q17: To what extent are the three Directives’ objectives coherent with the relevant EU legislation and policies
in other fields, such as the General Safety Regulation and Euro 6/VI legislation?
Operational sub-questions
• What is the degree of coherence between the three Directives’ objectives and other relevant EU legislation
and policies in other fields, including environment and climate policies?
• To what extent do the three Directives’ objectives overlap with other relevant EU legislation and policies
in other fields, including environment and climate policies?
• Are there any gap between the three Directives’ objectives and other relevant EU legislation and policies in
other fields, including environment and climate policies?
Judgement criteria
• Alignment with policies and strategies in other relevant policy areas
Indicators Sources
• Fit to other
EU policies
• Assistance to
delivery of
policy
objectives in
other policy
areas
• Targeted interviews
• Discussion with DG MOVE
• Desk research
Targeted
interviews
Targeted
stakeholders
:
DG CLIMA
DG GROW
DG ENV
Other DGs
and EU
bodies
ETSC
T&E
ACEA
National
authorities/i
mplementin
g bodies
Discussion
with DG
MOVE
Desk research
General Safety Regulation and Euro 6/VI legislation
- European Union, Regulation (EU) 2019/2144 of the
European Parliament and of the Council of 27 November
2019 on type-approval requirements for motor vehicles
and their trailers, and systems, components and separate
technical units intended for such vehicles, as regards their
general safety and the protection of vehicle occupants
and vulnerable road users, link
Official reports, especially at EU-level, MS-level authorities
Academic and scientific literature and articles
Position papers, e.g. from technical expert associations
- ACEA, Principles for potential post-Euro 6 and post-
Euro VI emission regulations, 2020, link
Q18: Are there any inconsistencies/overlaps/gaps between the Directives and other interventions at
EU/national/international level which have similar objectives?
Operational sub-questions
• What is the level of consistency, overlaps and/or gaps between the directives and the other national, EU and
international policies, such as national legislations, UNECE regulations on whole-lifetime compliance?
Judgement criteria
• Inconsistencies
• Overlaps
• Gaps
Indicators Sources
• Level
inconsistenc
ies,
overlaps,
and gaps
• Targeted interviews
• Survey
• Desk research
• Review of interventions including regulations or impending regulations from UNECE
93
Targeted interviews
Targeted stakeholders:
UNECE Working Groups
OECD/International
Transport Forum
National Authorities
(Ministries of Transport)
MEPs from the EP
Transport Committee
Survey
Targeted stakeholders:
UNECE Working Group
OECD/International
Transport Forum
National Authorities
(Ministries of Transport)
MEPs from the EP Transport
Committee
Desk
research
Regulatio
ns on
Cybersecu
rity
ADAS
Whole-
lifetime
Review of
interventions
including
regulations or
impending
regulations from
UNECE
Materials for
UNECE working
Groups under WP.29
EU Added Value
Q19: What is the additional value of the 3 Directives, for citizens and businesses, compared to what has been
or what could have been achieved by Member States at national and/or regional and international level with a
view to improving road safety and environmental protection?
Operational sub-questions
• What it the EU added value related to the implementation of the roadworthiness package in terms of road
safety?
• What it the EU added value related to the implementation of the roadworthiness package in terms of
environmental protection?
• What it the EU added value related to the implementation of the roadworthiness package in terms of free
movement of people?
Judgement criteria
• Do national differences in implementation acts and enforcement cause problems?
• Would the objectives of the directive be achieved sufficiently by Member States acting alone?
Indicators Sources
• Avoided fatalities
and injuries
• Saved emissions
• Targeted interviews
• Survey
• Desk research
• Data analysis (databases)
Targeted
interviews
Targeted
stakeholders:
MS national
authorities
Consumers Groups
MEPs
Road Safety
Associations
Environmental
Associations
Survey
Targeted
stakeholders:
MS national
authorities
Consumers Groups
MEPs
Road Safety
Associations
Environmental
Associations
Desk research
Member States’
reports on road
safety
(Academic)
studies
Data analysis
(databases)
GIDAS Database
CARE Database
IGLAD
National Institutes of
Statistics
Remote Sensing
databases for typical
fleet average emission
performance
CONOX database
Q20: To what extent would it have been possible to achieve the same results without these Directives?
Operational sub-questions
• How would the estimated road safety situation have been without the implementation of the roadworthiness
package at EU level and national level?
• How would the estimated emissions/ environmental situation have been without the implementation of the
roadworthiness package at EU level and national level?
Judgement criteria
• Difference in accident and emissions projections compared to the baseline scenario
94
Indicators Sources
• Fatalities and
injuries in
baseline
• Projected
emissions in
baseline
• Targeted interviews
• Survey
• Desk research
• Data analysis (databases)
Targeted
interviews
Targeted
stakeholders:
MS national
authorities
Consumers Groups
MEPs
Road Safety
Associations
Environmental
Associations
Survey
Targeted
stakeholders:
MS national
authorities
Consumers Groups
MEPs
Road Safety
Associations
Environmental
Associations
Desk research
Impact assessment
done for the initial
RWP (before 2016)
(Academic) studies
-
Data analysis
(databases)
GIDAS Database
CARE Database
IGLAD
National Institutes
of Statistics
Remote Sensing
databases for
typical fleet average
emission
performance
CONOX database