# IMMC.EESC-2022-03561-AC.ENG.xhtml.EESC-2022-03561-00-00-AC-TRA-EN.docx

OPINION

| OPINION |
| --- |
| European Economic and Social Committee |
| Development of post-Euro 6/VI emission standards for cars, vans, lorries and buses |
| _____________ |
| Proposal for a Regulation of the European Parliament and of the Council on type-approval of motor vehicles and engines and of systems, components and separate technical units intended for such vehicles, with respect to their emissions and battery durability (Euro 7) and repealing Regulations (EC) No 715/2007 and (EC) No 595/2009

  [COM(2022) 586 final - 2022/0365(COD)] |
| |
| CCMI/199 |
| |
| Rapporteur: Bruno CHOIX |
| Co-rapporteur: Guido NELISSEN |

European Economic and Social Committee

Development of post-Euro 6/VI emission standards for cars, vans, lorries and buses

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Proposal for a Regulation of the European Parliament and of the Council on type-approval of motor vehicles and engines and of systems, components and separate technical units intended for such vehicles, with respect to their emissions and battery durability (Euro 7) and repealing Regulations (EC) No 715/2007 and (EC) No 595/2009

  [COM(2022) 586 final - 2022/0365(COD)]

CCMI/199

Rapporteur: Bruno CHOIX

Co-rapporteur: Guido NELISSEN

EN

Referral

| Referral | European Parliament, 15/12/2022


  Council of the European Union, 21/12/2022 |
| --- | --- |
| Legal basis | Articles 114 and 304 of the Treaty on the Functioning of the European Union |
| Section responsible | Consultative Commission on Industrial Change |
| Adopted in section | 27/03/2023 |
| Adopted at plenary | 27/04/2023 |
| Plenary session No | 578 |
| Outcome of vote
  (for/against/abstentions) | 140/1/3 |

Referral

European Parliament, 15/12/2022

European Parliament, 15/12/2022

Council of the European Union, 21/12/2022

Council of the European Union, 21/12/2022

Legal basis

Legal basis

Articles 114 and 304 of the Treaty on the Functioning of the European Union

Articles 114 and 304 of the Treaty on the Functioning of the European Union

Section responsible

Section responsible

Consultative Commission on Industrial Change

Consultative Commission on Industrial Change

Adopted in section

Adopted in section

27/03/2023

27/03/2023

Adopted at plenary

Adopted at plenary

27/04/2023

27/04/2023

Plenary session No

Plenary session No

578

578

Outcome of vote
  (for/against/abstentions)

Outcome of vote
  (for/against/abstentions)

140/1/3

140/1/3

1.Conclusions and recommendations

1.

Conclusions and recommendations

1.1The automotive industry is currently engaged in the biggest transformation in its history, namely the decarbonisation and digitalisation of road transport. This new paradigm will have a profound impact on the structure of the industry and on the quantity and quality of jobs. Given the scale of the transition, the EESC calls for a comprehensive industrial policy that integrates the three dimensions of sustainable development: economic, environmental and social. The employment dimension must be addressed by increased efforts regarding vocational training, upskilling/reskilling of the workforce, regional/local programmes of economic reconversion and professional reclassification. This has to be supported by a well-established social dialogue and the ambition to ensure the preservation/creation of decent jobs in the sector.

1.1

The automotive industry is currently engaged in the biggest transformation in its history, namely the decarbonisation and digitalisation of road transport. This new paradigm will have a profound impact on the structure of the industry and on the quantity and quality of jobs. Given the scale of the transition, the EESC calls for a comprehensive industrial policy that integrates the three dimensions of sustainable development: economic, environmental and social. The employment dimension must be addressed by increased efforts regarding vocational training, upskilling/reskilling of the workforce, regional/local programmes of economic reconversion and professional reclassification. This has to be supported by a well-established social dialogue and the ambition to ensure the preservation/creation of decent jobs in the sector.

1.2The EESC supports the introduction of Euro 7 emission standards as an important element in achieving the EU's ambient air quality objectives. At the same time, this will also allow the EU to maintain its industrial leadership in clean automotive technologies.

1.2

The EESC supports the introduction of Euro 7 emission standards as an important element in achieving the EU's ambient air quality objectives. At the same time, this will also allow the EU to maintain its industrial leadership in clean automotive technologies.

1.3The Committee welcomes the many improvements contained in the proposed regulation: prevention of manipulation, use of digital technologies, reduction of complexity, and inclusion of electric vehicles and non-exhaust emissions.

1.3

The Committee welcomes the many improvements contained in the proposed regulation: prevention of manipulation, use of digital technologies, reduction of complexity, and inclusion of electric vehicles and non-exhaust emissions.

1.4For several reasons, the EESC calls for a "realistic" and "cost-effective" approach when setting new emission standards:

1.4

For several reasons, the EESC calls for a "realistic" and "cost-effective" approach when setting new emission standards:

1.4.1respect of proportionality: as internal combustion engines are likely to become an outdated technology from 2035 onwards, the budgetary resources needed to meet the new standards will no longer be available to be invested directly in clean powertrains;

1.4.1

respect of proportionality: as internal combustion engines are likely to become an outdated technology from 2035 onwards, the budgetary resources needed to meet the new standards will no longer be available to be invested directly in clean powertrains;

1.4.2individual car mobility must remain affordable in order to avoid "mobility poverty" (alternative transport options are not sufficiently available outside urban agglomerations);

1.4.2

individual car mobility must remain affordable in order to avoid "mobility poverty" (alternative transport options are not sufficiently available outside urban agglomerations);

1.4.3if Euro 7 emission standards bring about excessively high costs this is likely to be counterproductive, as consumers will postpone the replacement of their car and continue to drive their more polluting vehicle, thus limiting the potential benefits of Euro 7 emission standards in terms of health.

1.5It is therefore important that all elements of the new regulation are based on a scientific cost-benefit analysis. In this regard, all stakeholders must have the same understanding of how the costs of the new standards are calculated.

1.6The EESC believes that offering incentives to consumers would speed up the renewal of the car fleet and have significant health benefits, as replacing Euro 1-5/I-V vehicles with Euro 6/VI vehicles would lead to an 80% reduction in NOx emissions.

1.7The EESC calls for a swift adoption of the regulation and a minimum time frame of two years for cars/commercial vehicles and three years for buses and heavy goods vehicles to ensure the technical and economic viability of the proposed regulation.

2.Background to the proposal

2.1The automotive sector accounts for around 10% of the added value generated by industry in the EU and employs 13 million Europeans, equivalent to almost 7% of the EU's active population.

2.2Having grown continuously for more than a century, the automotive industry has been facing a recession and a crisis in its economic model since 2018. The ongoing crisis situations have led to the outlook for the recovery of global car production being revised down, particularly in Europe.

2.3At the same time, however, those involved in the automotive industry have to undertake the greatest transformation in vehicles since the invention of the car: electrification of the powertrain and digitalisation of the vehicle.

2.4Faced with this structural transition, the automotive industry is therefore engaged in a heavy investment phase that is putting pressure on its economic model, financed by reducing investment in conventional technologies (including internal combustion engines) and reducing production costs.

2.5In addition, the introduction of power and digital electronics opens the door to new competitors and is causing a shake-up in the sector, undermining the position of incumbent suppliers. This transition is a key factor driving employment trends.

2.6In quantitative terms, employment in this industrial sector is declining, in line with the reduction in capacity and the simplification of new traction systems. In qualitative terms, these jobs are changing significantly: needs linked to electrification and digitalisation require greater know-how in new fields of competence within the automotive sector.

2.7These employment dynamics can also be found in the automotive services sector: new traction systems reduce the need for maintenance and require a change in skills.

2.8It was in this context that the European Commission's proposal for new Euro 7 emissions standards for cars, commercial vehicles, lorries and buses was published on 10 November 2022, after repeated delays.

2.9The proposal for new Euro 7 emissions standards is part of a much wider set of EU policies to tackle transport-related air pollution. EU rules on ambient air quality, periodic roadworthiness testing, CO2 emissions, fuel quality, infrastructure for alternative fuels, clean vehicles and the Eurovignette all reflect the need to reduce transport's significant contribution to air pollution. They all come together to achieve the climate and non-pollution aim of the European Green Deal and contribute to the transition to sustainable mobility.

2.10The new Euro 7 standards will probably be the last ones for combustion engine cars as, under the 2021 Fit for 55 programme, it was decided to accelerate the decarbonisation of the automotive sector, leading to an agreement being reached on 27 October 2022 between the European Parliament and the Council to reduce CO2 emissions from cars by 55% by 2030 and to ban the sale of new combustion-powered cars (including hybrids) from 2035.

3.Content of the proposal

The main changes proposed by the regulation:

-stricter emission limits will apply to both diesel and petrol cars and lorries (although the NOx limits for cars remain at the same level);

-the test conditions for real-driving emissions will be expanded, while the conformity factors will be removed;

-greater emphasis will be placed on shorter journeys: the distance used as a basis for calculating the cold start emissions budget will be reduced from 16 km to 10 km;

-the non-exhaust emissions of brake particles and microplastics from tyres will be measured and regulated;

-durability requirements will be increased: 200 000 km or 10 years for cars/commercial vehicles and 875 000 km with no time limit for lorries/buses;

-continuous emissions control will be introduced through on-board monitoring: sensors will measure real emissions throughout the life of a vehicle;

-the longevity of batteries will be assessed by checking the change in their capacity as mileage increases;

-stricter rules will ensure that vehicles are not tampered with;

-emission limits will be set for previously unregulated pollutants: ammonia for cars, formaldehyde for lorries. For the first time, limits will regulate the emissions caused by evaporation when filling up with fuel.

4.General comments

4.1Although premature deaths in the EU-27 attributed to exposure to air pollutants decreased in 2019 by 33% from 2005, more ambitious limits are still needed. In this connection, road transport accounts for 37% of total NOx emissions and each year, and fine particulate matter and nitrogen oxides from road traffic are responsible for more than 70 000 premature deaths in the EU-27.

4.2The Commission has opted for a "realistic" approach to establishing the new rules. Cars with an internal combustion engine will remain affordable even though the tightening of rules on diesels is likely to accelerate the decline in the supply of this type of vehicle. It should also be borne in mind that the new CO2 standards will also have an impact on vehicle purchase prices.

4.3Although less ambitious than many expected when it comes to the emission values set, the Euro 7 standard is a major revision that addresses a number of weaknesses of the Euro 6 standard, such as the risk of manipulation, the complexity of rules, vehicle ageing and real-world emissions. It also takes a much broader approach by including electric vehicles and non-exhaust emissions.

4.4Regulatory pressure from successive Euro emissions standards has fostered innovation in the design of emissions control systems and powertrains and contributed to the EU's leading role in the industry. For this reason, it is important for EU standards to remain ahead of standards being developed in key markets. Being at the forefront of integrating digital and clean technologies is an important asset when it comes to accessing international markets. In this respect, more ambitious standards should also be envisaged, such as the US sustainability requirements (240 000 km or 15 years).

4.5The EESC believes that offering incentives to consumers would speed up the renewal of the car fleet, which would have a clear impact on air quality and emissions reductions. Replacing the old fleet with the latest, Euro 6 compliant vehicles, combined with ongoing electrification, would lead to a significant reduction (80%) in NOx emissions from road transport by 2035.

4.6The EESC calls for a sound and scientific cost-benefit analysis to be devoted to each of the new elements to be regulated, in order to clarify to what extent these requirements taken separately could contribute to cost-effective emission reductions. In this respect, it is important that all stakeholders have the same understanding of the analysis of the additional costs associated with the implementation of the Euro 7 standard.

4.7The EESC firmly believes that individual car mobility must remain accessible and affordable for all, especially for people who do not have access to good quality public transport (or other transport solutions). The Committee therefore calls on the automotive industry to continue to maintain the supply of low-end vehicles that are accessible to all. As car prices are rising much faster than purchasing power, and since shared mobility services do not yet provide a valid alternative, the Committee also firmly believes that it is high time to take the problem of "mobility poverty" seriously into account.

4.8In general, the EESC is of the opinion that a balance should be struck between the three dimensions of sustainable development. Investing both in the transition to electric vehicles and in the reengineering of the internal combustion engine could create competitive disadvantages for the European automotive industry compared to manufacturers producing electric vehicles only or foreign car manufacturers who are not subject to the same requirements. Moreover, it must be avoided that excessively high prices for Euro 7 compliant cars result in consumers postponing the replacement of their more polluting cars. This would significantly reduce the potential benefits of the Euro 7 standard, while at the same time causing industrial restructuring as a result of the collapse of sales.

4.9Given the scale of the transformation, the EESC is calling for a coherent industrial policy capable of meeting the triple challenge facing the automotive industry:

-environment: contributing to achievement of the Green Deal objectives and the new emission standards of the Ambient Air Quality Directive;

-economy: maintaining industrial leadership, preserving the automotive supply chain in the EU and developing a solid ecosystem for electric cars; and

-social: ensuring a just transition framework, prior information and consultation/social dialogue to anticipate and manage the transition, regional reskilling plans, retraining and maintaining quality jobs.

5.Specific comments

5.1In its draft, the Commission sets two application dates: July 2025 for light-duty vehicles and July 2027 for heavy-duty vehicles. In both cases, the date corresponds to the date on which Member States will have to refuse to register vehicles that do not comply with the Euro 7 rules.

The choice of these dates raises questions, in particular with regard to light-duty vehicles.

5.1.1The July 2025 proposal seems unrealistic. Manufacturers will have to change production several months before this deadline in order to avoid producing stocks of Euro 6 vehicles that will no longer be registered, and it usually takes over a year for the entire fleet to be approved. Approvals would therefore have to start at the beginning of 2024, i.e. immediately after the adoption of the Euro 7 Regulation, and possibly before its implementing legislation is published.

The July 2027 proposal for heavy-duty vehicles may seem more appropriate, but it is necessary to take into account the time needed to develop innovative technical solutions such as the electrically heated catalyst, which will be necessary to reach the emission limits. The EESC therefore believes that swift adoption of the regulation and a minimum time frame (after its adoption) of two years for cars/commercial vehicles and three years for buses/heavy goods vehicles are necessary to ensure the technical and economic viability of the proposed regulation.

5.2As regards light-duty vehicles, the proposed regulation provides for the different emissions limits that are applied to commercial vehicles according to their mass to be replaced by a single set of values covering all commercial vehicles, provided that the power-to-mass ratio remains below 35 kW/t. This effort to simplify things is commendable, but it is likely to have a significant impact on the activity of the light-duty commercial vehicles sector, particularly in the case of modified vehicles, especially as the application dates for light-duty and heavy-duty vehicles do not coincide. In this context, the EESC calls for derogations and flexibility when it comes to application, for example in the case of converting a category N1 light-duty commercial vehicle (mass less than 3 500 kg) to a category M2 minibus (mass less than 5 000 kg).

5.3As part of the digital aim under the Green Deal, the Commission proposes introducing an innovative system called OBM ("on board monitoring") designed to record the level of pollutant emissions on board the vehicle on an ongoing basis, in order to:

-identify situations of excess emissions not detected by the OBD;

-periodically transmit emissions values to servers to facilitate market surveillance activities, in-service conformity checks and roadworthiness testing.

While such a system can indeed help to simplify monitoring processes, developing it requires the rapid development of technical rules that will make it possible to specify the hardware needed (sensors, software, etc.). This development, which will potentially have a major impact on users, will in itself require a period of three years after the technical rules are published for the purpose of implementation.

5.4Regarding light-duty vehicles, the limit values proposed by the Commission may appear to lack ambition in that they correspond, in principle, to harmonisation based on the lowest value set out in the Euro 6 rules for petrol and diesel engines. However, it is important to note that:

-in its annexes, the draft regulation provides for a redefinition of the conditions that currently ensure that the road test is representative of normal vehicle use, which will force manufacturers to adjust the size of the after-treatment systems;

-harmonising limits on the basis of the best value increases the constraints for petrol engines (limit reduced by 50% on CO for petrol passenger cars) as well as for diesels (NOx limit reduced by 40% for heavy-duty diesel vehicles);

-contrary to the Euro 6 Regulation, the Euro 7 Regulation provides for no tolerance, the basis for which will be the road test.

5.5Given that microplastics from tyres are one of the most significant sources of ocean pollution and that no limit has yet been set due to the lack of a procedure at UN level, there is an urgent need for such a procedure to be developed as soon as possible.

5.6The Committee questions the need to introduce ammonia emission standards for cars. Given that the transport sector accounts for less than 1% of European ammonia emissions, the cost of this measure does not seem to be proportionate to the benefits. The Committee also raises questions on the appropriateness of imposing a system on vehicles to limit evaporative emissions when filling up with fuel, while Europe has already put in place a suction device for fuel pumps.

5.7For heavy-duty vehicles, the limit values proposed by the Commission signify a break with the values in the Euro 6 Regulation, with reduction targets of, respectively, -80% for NOx and particulate number and up to -95% for CO. Furthermore, in view of their impact on the greenhouse effect, the Commission proposes to regulate the thresholds for CH4 (methane) and N2O (nitrous oxide) individually, with the latter being set at a particularly low level. Of course, these changes will require significant investment, which will have to be taken into account in the upcoming discussions on the CO2 trajectory of heavy-duty vehicles
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Brussels, 27 April 2023.

Oliver Röpke

The president of the European Economic and Social Committee

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