# C_2013044EN.01012801.xml

| 15.2.2013 | EN | Official Journal of the European Union | C 44/128 |
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15.2.2013

EN

Official Journal of the European Union

C 44/128

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Opinion of the European Economic and Social Committee on the ‘Roadworthiness Package containing the following three documents: Proposal for a Regulation of the European Parliament and of the Council on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC’

COM(2012) 380 final — 2012/0184 (COD),

‘Proposal for a Directive of the European Parliament and of the Council amending Council Directive 1999/37/EC on the registration documents for vehicles’

COM(2012) 381 final — 2012/0185 (COD)

and the ‘Proposal for a Regulation of the European Parliament and of the Council on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC’

COM(2012) 382 final — 2012/0186 (COD)

2013/C 44/23

Rapporteur: Mr RANOCCHIARI

Mr RANOCCHIARI

On 7 and 10 September 2012 and 8 October, the Council, and on 11 September, the European Parliament, decided to consult the European Economic and Social Committee, under Articles 91 and 304 of the Treaty on the Functioning of the European Union (TFEU), on the

Roadworthiness package containing the following three documents: Proposal for a Regulation of the European Parliament and of the Council on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC

Roadworthiness package

Proposal for a Regulation of the European Parliament and of the Council on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC

COM(2012) 380 final — 2012/0184 (COD)

Proposal for a Directive of the European Parliament and of the Council amending Council Directive 1999/37/EC on the registration documents for vehicles

Proposal for a Directive of the European Parliament and of the Council amending Council Directive 1999/37/EC on the registration documents for vehicles

COM(2012) 381 final — 2012/0185 (COD)

Proposal for a Regulation of the European Parliament and of the Council on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC

Proposal for a Regulation of the European Parliament and of the Council on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC

COM(2012) 382 final — 2012/0186 (COD).

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 26 November 2012.

At its 485th plenary session, held on 12 and 13 December 2012 (meeting of 12 December), the European Economic and Social Committee adopted the following opinion by 130 votes to 2 with 2 abstentions.

1.   Conclusions and recommendations

Conclusions and recommendations

| 1.1 | Subject to the points made further on in the opinion, the European Economic and Social Committee (EESC) supports and endorses the Commission's proposals for at least the following three reasons:






  — | reducing accidents and their often tragic consequences is an issue that ought to assume more and more importance, not least in view of the further increase in road traffic projected in the coming years; |
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1.1

Subject to the points made further on in the opinion, the European Economic and Social Committee (EESC) supports and endorses the Commission's proposals for at least the following three reasons:

—

reducing accidents and their often tragic consequences is an issue that ought to assume more and more importance, not least in view of the further increase in road traffic projected in the coming years;

| — | pursuing the objective of reducing accidents requires a systematic and concerted effort above and beyond the remit of the individual Member States; |
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—

pursuing the objective of reducing accidents requires a systematic and concerted effort above and beyond the remit of the individual Member States;

| — | greater uniformity of rules and testing is needed to prevent such a key aspect of society – road safety – being addressed using methods and timing systems that are uneven and in some cases very divergent. |
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—

greater uniformity of rules and testing is needed to prevent such a key aspect of society – road safety – being addressed using methods and timing systems that are uneven and in some cases very divergent.

| 1.2 | However, the Committee notes that despite the underlying premise of seeking ultimate uniformity, the method adopted by the Commission in drawing up this package – a combination of regulatory requirements and soft law – leaves a significant degree of discretion to the Member States, thus complicating or at least slowing down the process of fully harmonising roadworthiness testing so that tests carried out and certificates of conformity issued in one Member State are automatically recognised in all the others. |
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1.2

However, the Committee notes that despite the underlying premise of seeking ultimate uniformity, the method adopted by the Commission in drawing up this package – a combination of regulatory requirements and soft law – leaves a significant degree of discretion to the Member States, thus complicating or at least slowing down the process of fully harmonising roadworthiness testing so that tests carried out and certificates of conformity issued in one Member State are automatically recognised in all the others.

| 1.3 | Furthermore, in the Committee's view, the harmonisation process thus initiated should naturally culminate with the creation of a European certificate of conformity to replace the current national certificates thus enabling the periodic tests to be carried out in any Member State and removing the obligation to repatriate vehicles to the Member State where they are registered. |
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1.3

Furthermore, in the Committee's view, the harmonisation process thus initiated should naturally culminate with the creation of a European certificate of conformity to replace the current national certificates thus enabling the periodic tests to be carried out in any Member State and removing the obligation to repatriate vehicles to the Member State where they are registered.

| 1.4 | The Committee welcomes both the expansion of the range of technical equipment and technology subject to testing, and the listing of tests to be carried out. The testing of equipment which has thus far remained the sole responsibility of the manufacturers, such as ABS and ESC, is to be supported. It is furthermore the right decision to differentiate vehicles also on the basis of their age and mileage, as these are aspects of particular importance to the maintenance and safety of vehicles. |
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1.4

The Committee welcomes both the expansion of the range of technical equipment and technology subject to testing, and the listing of tests to be carried out. The testing of equipment which has thus far remained the sole responsibility of the manufacturers, such as ABS and ESC, is to be supported. It is furthermore the right decision to differentiate vehicles also on the basis of their age and mileage, as these are aspects of particular importance to the maintenance and safety of vehicles.

| 1.5 | The Committee also welcomes the proposal to extend technical roadside inspections to so-called light goods vehicles (LCV, maximum permissible mass up to 3.5 tonnes). It would point out, however, that there is a huge number of such vehicles on the roads. The target of testing at least 5 % each year is frankly very ambitious. |
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1.5

The Committee also welcomes the proposal to extend technical roadside inspections to so-called light goods vehicles (LCV, maximum permissible mass up to 3.5 tonnes). It would point out, however, that there is a huge number of such vehicles on the roads. The target of testing at least 5 % each year is frankly very ambitious.

| 1.6 | In this regard, the Committee calls for a survey to be carried out at individual Member State level on the EU's mobile inspection unit stock, so that Member States can supplement their stock, as necessary, in good time. |
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1.6

In this regard, the Committee calls for a survey to be carried out at individual Member State level on the EU's mobile inspection unit stock, so that Member States can supplement their stock, as necessary, in good time.

| 1.7 | Still on the subject of widening the scope of vehicles to be tested, the Committee fully agrees on the need to include motorcycles. It believes, however, that the proposed test frequency (4-2-1) is excessive for these vehicles, which have a very low annual mileage. The Committee therefore proposes a reduced frequency (4-2-2), at least initially. |
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1.7

Still on the subject of widening the scope of vehicles to be tested, the Committee fully agrees on the need to include motorcycles. It believes, however, that the proposed test frequency (4-2-1) is excessive for these vehicles, which have a very low annual mileage. The Committee therefore proposes a reduced frequency (4-2-2), at least initially.

2.   Introduction

Introduction

| 2.1 | Roadworthiness testing of motor vehicles plays a vital role in road safety. Every day in Europe more than five people are killed in accidents caused by technical defects in vehicles. It is calculated that 6 % of car accidents and 8 % of motorcycle accidents can be attributed to such defects, at least as a contributory cause. |
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2.1

Roadworthiness testing of motor vehicles plays a vital role in road safety. Every day in Europe more than five people are killed in accidents caused by technical defects in vehicles. It is calculated that 6 % of car accidents and 8 % of motorcycle accidents can be attributed to such defects, at least as a contributory cause.

| 2.2 | European legislation in this area dates back to 1977 and has undergone only minor updates over the last decade, in the face of road traffic volumes that have tripled and major changes in vehicle technology. |
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2.2

European legislation in this area dates back to 1977 and has undergone only minor updates over the last decade, in the face of road traffic volumes that have tripled and major changes in vehicle technology.

| 2.3 | A comparative analysis by the European Commission of the systems in place in the Member States for periodic vehicle roadworthiness testing has revealed a number of shortcomings which – according to recent British and German studies – allow about 10 % of cars to circulate on the roads with technical defects that would not pass more suitable and modern tests. |
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2.3

A comparative analysis by the European Commission of the systems in place in the Member States for periodic vehicle roadworthiness testing has revealed a number of shortcomings which – according to recent British and German studies – allow about 10 % of cars to circulate on the roads with technical defects that would not pass more suitable and modern tests.

| 2.4 | It has emerged from this and other studies that:






  — | testing does not cover all of the most important devices in vehicles, such as the anti-lock braking system (ABS) and the electronic stability control (ESC); |
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2.4

It has emerged from this and other studies that:

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testing does not cover all of the most important devices in vehicles, such as the anti-lock braking system (ABS) and the electronic stability control (ESC);

| — | the definition and evaluation of defects is not being updated and harmonised throughout the European Union; |
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—

the definition and evaluation of defects is not being updated and harmonised throughout the European Union;

| — | testing equipment is not always adequate, with a lack of precise requirements on the subject, binding throughout the EU. Similarly, inspectors performing roadworthiness tests should have a level of knowledge and skills that keeps pace with technological developments, in order to ensure that their work is of an even quality across the EU; |
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—

testing equipment is not always adequate, with a lack of precise requirements on the subject, binding throughout the EU. Similarly, inspectors performing roadworthiness tests should have a level of knowledge and skills that keeps pace with technological developments, in order to ensure that their work is of an even quality across the EU;

| — | some categories of vehicle are not subject to periodic roadworthiness tests (PTI). This is the case, for example, for motorcycles in no less than eleven Member States; |
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some categories of vehicle are not subject to periodic roadworthiness tests (PTI). This is the case, for example, for motorcycles in no less than eleven Member States;

| — | the tests are not sufficiently frequent, especially for commercial vehicles, but more generally for older vehicles and those with a high mileage; |
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the tests are not sufficiently frequent, especially for commercial vehicles, but more generally for older vehicles and those with a high mileage;

| — | there is inadequate oversight of test centres by the relevant authorities; |
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there is inadequate oversight of test centres by the relevant authorities;

| — | the data and information necessary for testing on-board electronic equipment is not always available for inspectors, and neither are the results of tests always available to law enforcement authorities. |
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—

the data and information necessary for testing on-board electronic equipment is not always available for inspectors, and neither are the results of tests always available to law enforcement authorities.

| 2.5 | In the light of the foregoing, the Committee endorses and supports the Commission's initiative which, by extending and updating the scope of the roadworthiness tests, could contribute to the objective of halving road fatalities by 2020 while also reducing – by means of extended and more frequent emissions testing – the environmental impact of road traffic, particularly as regards CO2. |
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2.5

In the light of the foregoing, the Committee endorses and supports the Commission's initiative which, by extending and updating the scope of the roadworthiness tests, could contribute to the objective of halving road fatalities by 2020 while also reducing – by means of extended and more frequent emissions testing – the environmental impact of road traffic, particularly as regards CO2.

2

3.   The Commission's package of proposals

The Commission's package of proposals

The package contains the following three legislative proposals:

| — | a regulation (COM(2012) 380 final) on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC; |
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—

a regulation (COM(2012) 380 final) on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC;

| — | a second regulation (COM(2012) 382 final) on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC; and |
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—

a second regulation (COM(2012) 382 final) on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC; and

| — | a directive (COM(2012) 381 final) amending Council Directive 1999/37/EC on the registration documents for vehicles. |
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—

a directive (COM(2012) 381 final) amending Council Directive 1999/37/EC on the registration documents for vehicles.

3.1   The innovations in the proposal for a regulation on periodic roadworthiness tests (PTI, periodic technical inspections) COM(2012) 380 final

The innovations in the proposal for a regulation on periodic roadworthiness tests (PTI, periodic technical inspections) COM(2012) 380 final

| 3.1.1 | Scope. This will be extended to include two or more wheel motorcycles throughout the EU. Agricultural tractors with a design speed exceeding 40 km/h (category T5) and light trailers up to 3,5 tonnes (categories O1 and O2) will no longer be exempt. |
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3.1.1

Scope. This will be extended to include two or more wheel motorcycles throughout the EU. Agricultural tractors with a design speed exceeding 40 km/h (category T5) and light trailers up to 3,5 tonnes (categories O1 and O2) will no longer be exempt.

Scope

| 3.1.2 | Date and frequency of testing. For passenger cars (cat. M1)(Category M covers passenger vehicles with at least four wheels. They are divided into three classes based on the number of seats and their maximum mass: M1 9 seats; M2 > 9 seats and < 5 tonnes; M3 > 9 seats and > 5 tonnes. Category N vehicles are goods vehicles with at least four wheels. They are also divided into three classes on the basis of maximum masse: N1 < 3,5 tonnes; N2 < 12 tonnes; N3 > 12 tonnes. Category O refers to vehicles with trailers and T wheeled tractors.) The first PTI is to be conducted four years after registration, then after two years and thereafter annually. Cars and light commercial vehicles (N1) which at the date of first inspection have reached a mileage of more than 160 000 km are to be inspected annually thereafter (4-1-1 instead of the existing 4-2-1) and this will also apply to motorcycles. The possibility remains for Member States that already apply more frequent testing to continue to do so. It is left to Member States to decide on the frequency of tests for vehicles of historic interest, including motorcycles, all of which are not subject to the new regulation.
  For the vehicle categories M2, M3, N2, N3, O3, O4 and T5, the first test is to be conducted one year after registration. The same applies to M1 vehicles registered as taxis or ambulances. |
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3.1.2

Date and frequency of testing. For passenger cars (cat. M1)(Category M covers passenger vehicles with at least four wheels. They are divided into three classes based on the number of seats and their maximum mass: M1 9 seats; M2 > 9 seats and < 5 tonnes; M3 > 9 seats and > 5 tonnes. Category N vehicles are goods vehicles with at least four wheels. They are also divided into three classes on the basis of maximum masse: N1 < 3,5 tonnes; N2 < 12 tonnes; N3 > 12 tonnes. Category O refers to vehicles with trailers and T wheeled tractors.) The first PTI is to be conducted four years after registration, then after two years and thereafter annually. Cars and light commercial vehicles (N1) which at the date of first inspection have reached a mileage of more than 160 000 km are to be inspected annually thereafter (4-1-1 instead of the existing 4-2-1) and this will also apply to motorcycles. The possibility remains for Member States that already apply more frequent testing to continue to do so. It is left to Member States to decide on the frequency of tests for vehicles of historic interest, including motorcycles, all of which are not subject to the new regulation.

Date and frequency of testing

For the vehicle categories M2, M3, N2, N3, O3, O4 and T5, the first test is to be conducted one year after registration. The same applies to M1 vehicles registered as taxis or ambulances.

| 3.1.3 | Contents of tests, assessment of deficiencies and related penalties. Components related to safety (ABS and ESC) and the environment (emission control equipment) are to be added to the list of checks to be carried out.
  Defects found during testing are to be classified – on the basis of common parameters set out in Annex III of the proposal – as minor (no safety risk), major (may prejudice the safety of the vehicle or other road users), or dangerous (major and immediate risk entailing taking the vehicle off the road). Minor deficiencies are to be rectified but do not require a follow-up test. In the case of major deficiencies, the competent authority is to decide on the conditions under which the vehicle may be used until the defect is repaired, and another roadworthiness test is to be carried out within six weeks of the initial test. In the case of dangerous deficiencies, the vehicle's registration is to be withdrawn until the deficiencies are rectified and a new roadworthiness certificate is issued. |
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3.1.3

Contents of tests, assessment of deficiencies and related penalties. Components related to safety (ABS and ESC) and the environment (emission control equipment) are to be added to the list of checks to be carried out.

Contents of tests, assessment of deficiencies and related penalties

Defects found during testing are to be classified – on the basis of common parameters set out in Annex III of the proposal – as minor (no safety risk), major (may prejudice the safety of the vehicle or other road users), or dangerous (major and immediate risk entailing taking the vehicle off the road). Minor deficiencies are to be rectified but do not require a follow-up test. In the case of major deficiencies, the competent authority is to decide on the conditions under which the vehicle may be used until the defect is repaired, and another roadworthiness test is to be carried out within six weeks of the initial test. In the case of dangerous deficiencies, the vehicle's registration is to be withdrawn until the deficiencies are rectified and a new roadworthiness certificate is issued.

minor

major

dangerous

| 3.1.4 | Testing facilities and equipment. Testing centres are to have a period of five years from the date of application of the regulation to bring their testing facilities and equipment into line with the minimum requirements of this regulation. |
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3.1.4

Testing facilities and equipment. Testing centres are to have a period of five years from the date of application of the regulation to bring their testing facilities and equipment into line with the minimum requirements of this regulation.

Testing facilities and equipment

| 3.1.5 | Cooperation between Member States. No later than three years after the entry into force of this regulation, the testing centres are to communicate, by electronic means only, the results of their activities or certificates of compliance to the competent authority of their Member State, which shall designate a national contact point responsible for the exchange of information with the other Member States and the Commission with regard to the application of this regulation. Proof that a vehicle has passed a test in one Member State will be recognised also by the others. |
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3.1.5

Cooperation between Member States. No later than three years after the entry into force of this regulation, the testing centres are to communicate, by electronic means only, the results of their activities or certificates of compliance to the competent authority of their Member State, which shall designate a national contact point responsible for the exchange of information with the other Member States and the Commission with regard to the application of this regulation. Proof that a vehicle has passed a test in one Member State will be recognised also by the others.

Cooperation between Member States

3.2   The innovations in the proposal for a regulation on the technical roadside inspection of the roadworthiness of commercial vehicles – COM(2012) 382 final

The innovations in the proposal for a regulation on the technical roadside inspection of the roadworthiness of commercial vehicles – COM(2012) 382 final

| 3.2.1 | This proposal intends to expand the scope of the existing directive, while targeting high-risk companies and reducing the inspection of operators that maintain their vehicles properly. Risk profiling (Annex I to the proposal) is to be based on the results of previous test-centre roadworthiness tests and roadside inspections, taking account of the deficiencies detected. |
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3.2.1

This proposal intends to expand the scope of the existing directive, while targeting high-risk companies and reducing the inspection of operators that maintain their vehicles properly. Risk profiling (Annex I to the proposal) is to be based on the results of previous test-centre roadworthiness tests and roadside inspections, taking account of the deficiencies detected.

| 3.2.2 | Currently, technical roadside inspections apply to commercial vehicles of more than 3.5 tonnes. The proposal extends these inspections to light commercial vehicles (N1) and their trailers (O1 e O2). |
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3.2.2

Currently, technical roadside inspections apply to commercial vehicles of more than 3.5 tonnes. The proposal extends these inspections to light commercial vehicles (N1) and their trailers (O1 e O2).

| 3.2.3 | Each Member State is to carry out roadside inspections on at least 5 % of the vehicles registered in its territory, in every calendar year. |
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3.2.3

Each Member State is to carry out roadside inspections on at least 5 % of the vehicles registered in its territory, in every calendar year.

| 3.2.4 | As indicated above, at national level, a risk profile (low, medium or high) based on previous tests is to be attributed to each operator. This profile will be communicated to the operator concerned, in the knowledge that high-risk companies will be prioritised in roadside inspections. |
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3.2.4

As indicated above, at national level, a risk profile (low, medium or high) based on previous tests is to be attributed to each operator. This profile will be communicated to the operator concerned, in the knowledge that high-risk companies will be prioritised in roadside inspections.

| 3.2.5 | The tests will be carried out in stages. Initial inspections are to involve a visual assessment of the condition of the vehicle and its documentation, and following this more detailed inspections, where necessary, may be carried out using mobile inspection units or the nearest testing centre. |
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3.2.5

The tests will be carried out in stages. Initial inspections are to involve a visual assessment of the condition of the vehicle and its documentation, and following this more detailed inspections, where necessary, may be carried out using mobile inspection units or the nearest testing centre.

| 3.2.6 | A further innovation is including the securing of cargo in inspections (Annex IV) which, according to the Commission, accounts for a quarter of incidents involving commercial vehicles. |
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3.2.6

A further innovation is including the securing of cargo in inspections (Annex IV) which, according to the Commission, accounts for a quarter of incidents involving commercial vehicles.

| 3.2.7 | The results of roadside inspections are to be passed on by the competent authority to the Member State in which the vehicle is registered. |
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3.2.7

The results of roadside inspections are to be passed on by the competent authority to the Member State in which the vehicle is registered.

3.3   The innovations in the proposal for a directive amending Council Directive 1999/37/EC on the registration documents for vehicles – COM(2012) 381 final

The innovations in the proposal for a directive amending Council Directive 1999/37/EC on the registration documents for vehicles – COM(2012) 381 final

| 3.3.1 | Information on registered vehicles is to be kept in national electronic registers, which will include the results of the periodic roadworthiness tests. |
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3.3.1

Information on registered vehicles is to be kept in national electronic registers, which will include the results of the periodic roadworthiness tests.

| 3.3.2 | The technical data that enabled type-approval of the vehicle and that is not included on the registration documentation is to be made available to inspectors for the purposes of roadworthiness testing. |
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3.3.2

The technical data that enabled type-approval of the vehicle and that is not included on the registration documentation is to be made available to inspectors for the purposes of roadworthiness testing.

| 3.3.3 | In the interests of road safety, the proposal contains more precise provisions on the withdrawal and cancellation of registrations and the re-registration and destruction of vehicles. |
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3.3.3

In the interests of road safety, the proposal contains more precise provisions on the withdrawal and cancellation of registrations and the re-registration and destruction of vehicles.

4.   General comments

General comments

| 4.1 | It often happens that goods transport operators are penalised following roadside inspections carried out abroad for defects that would not be subject to penalties in the country in which they are registered. It thus seems that the Commission has taken the right direction with this package of proposals, which is also intended to pave the way for harmonisation of testing at EU level. The process thus launched should be completed, in a second phase, with the mutual recognition by all Member States of the respective certificates of conformity, followed by the creation of a European certificate to replace the national ones. |
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4.1

It often happens that goods transport operators are penalised following roadside inspections carried out abroad for defects that would not be subject to penalties in the country in which they are registered. It thus seems that the Commission has taken the right direction with this package of proposals, which is also intended to pave the way for harmonisation of testing at EU level. The process thus launched should be completed, in a second phase, with the mutual recognition by all Member States of the respective certificates of conformity, followed by the creation of a European certificate to replace the national ones.

| 4.2 | Indeed, the obligation to repatriate vehicles – both cars and commercial vehicles – to the Member State where they are registered in order to obtain the certificate continues to be a major burden. Mutual recognition should make it possible for testing to be carried out in any Member State. |
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4.2

Indeed, the obligation to repatriate vehicles – both cars and commercial vehicles – to the Member State where they are registered in order to obtain the certificate continues to be a major burden. Mutual recognition should make it possible for testing to be carried out in any Member State.

| 4.3 | More generally, the Committee notes that the approach chosen by the Commission in drawing up this package – a combination of regulatory measures and soft law – risks leaving a significant degree of discretion to the Member States, thus complicating or at least slowing down the process of fully harmonising and standardising roadworthiness testing so that tests carried out and certificates of conformity issued in one Member State are automatically recognised in all the others. |
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4.3

More generally, the Committee notes that the approach chosen by the Commission in drawing up this package – a combination of regulatory measures and soft law – risks leaving a significant degree of discretion to the Member States, thus complicating or at least slowing down the process of fully harmonising and standardising roadworthiness testing so that tests carried out and certificates of conformity issued in one Member State are automatically recognised in all the others.

| 4.4 | An example of continuing and considerable divergences is the provision that the Member States can maintain a shorter interval between tests (point 3.1.2). It is understandable that the Commission does not want to impose downward revisions on countries that have had more frequent testing in place for some time. However, it is also true that the acceptance of very different situations is not conducive to the uniformity of rules that should be the objective of these proposals: a PTI that is the same throughout the EU. |
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4.4

An example of continuing and considerable divergences is the provision that the Member States can maintain a shorter interval between tests (point 3.1.2). It is understandable that the Commission does not want to impose downward revisions on countries that have had more frequent testing in place for some time. However, it is also true that the acceptance of very different situations is not conducive to the uniformity of rules that should be the objective of these proposals: a PTI that is the same throughout the EU.

| 4.5 | In the light of the above, the Committee hopes that the Member States, while remaining free to opt for more frequent tests, will undertake to recognise the validity of the tests carried out in another Member State that adheres to the timing and minimum requirements set out in the regulation. |
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4.5

In the light of the above, the Committee hopes that the Member States, while remaining free to opt for more frequent tests, will undertake to recognise the validity of the tests carried out in another Member State that adheres to the timing and minimum requirements set out in the regulation.

| 4.6 | Again in terms of test frequency, the Committee wonders whether it is appropriate to provide for the same system of timing to apply to L-category vehicles (mopeds, motorcycles, three-wheel vehicles and quadricycles) as for automobiles. |
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4.6

Again in terms of test frequency, the Committee wonders whether it is appropriate to provide for the same system of timing to apply to L-category vehicles (mopeds, motorcycles, three-wheel vehicles and quadricycles) as for automobiles.

| 4.6.1 | It is right that L-category vehicles be subject to periodic tests, to overcome the anomaly in many Member States where there has been no provision for testing “L” vehicles. |
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4.6.1

It is right that L-category vehicles be subject to periodic tests, to overcome the anomaly in many Member States where there has been no provision for testing “L” vehicles.

| 4.6.2 | However, for these vehicles, which are often inexpensive and mostly used in cities, the changes should be kept simple so as to limit the required investment in test equipment, and their test frequency should be set at 4-2-2 instead of 4-2-1, given their much lower average annual mileage. The mileage of “L” vehicles is between 2 800 and 5 300 km per year, as against 15 000 km for cars. |
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4.6.2

However, for these vehicles, which are often inexpensive and mostly used in cities, the changes should be kept simple so as to limit the required investment in test equipment, and their test frequency should be set at 4-2-2 instead of 4-2-1, given their much lower average annual mileage. The mileage of “L” vehicles is between 2 800 and 5 300 km per year, as against 15 000 km for cars.

| 4.6.3 | This frequency could be reassessed in the future taking account of the data (finally with European coverage) collected during the periodic tests, with due regard here too to Member States' freedom to continue to carry out additional and/or more frequent tests. |
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4.6.3

This frequency could be reassessed in the future taking account of the data (finally with European coverage) collected during the periodic tests, with due regard here too to Member States' freedom to continue to carry out additional and/or more frequent tests.

| 4.7 | Finally, the EESC hopes that, in tandem with achieving standardised, more thorough testing, a plan could be launched, working on the basis of the existence of the new rules, designed to raise public awareness, especially among young people, of the need for more careful and responsible use of motor vehicles, warning in particular against making any technical modifications that may alter safety features, particularly on motorcycles. |
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4.7

Finally, the EESC hopes that, in tandem with achieving standardised, more thorough testing, a plan could be launched, working on the basis of the existence of the new rules, designed to raise public awareness, especially among young people, of the need for more careful and responsible use of motor vehicles, warning in particular against making any technical modifications that may alter safety features, particularly on motorcycles.

5.   Specific comments

Specific comments

| 5.1 | While welcoming the Commission's decision to include tractors with a design speed exceeding 40 km/h (T5) in the PTI system, the Committee wonders why these tractors are not subject to possible roadside inspections. |
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5.1

While welcoming the Commission's decision to include tractors with a design speed exceeding 40 km/h (T5) in the PTI system, the Committee wonders why these tractors are not subject to possible roadside inspections.

| 5.2 | The technical annexes of the proposal on testing set out the minimum requirements to be met by test centres, but it is unclear to what extent these requirements also apply to mobile inspection units. |
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5.2

The technical annexes of the proposal on testing set out the minimum requirements to be met by test centres, but it is unclear to what extent these requirements also apply to mobile inspection units.

| 5.3 | The target of 5 % of total vehicles on the roads to be subject to roadside inspection (point 3.2.3) seems ambitious given the high number of light commercial vehicles (LCV) in circulation that are to be added to the medium- and heavy-duty ones already subject to inspection. By way of illustration, in the years 2010-2011 alone more than three million LCV were registered as against around 450 000 medium- and heavy-duty vehicles, and LCV account for over 80 % of the commercial fleet in circulation.
  In this regard, the Committee feels that a survey should be carried out of the EU's mobile inspection unit stock so that Member States can supplement their stock, as necessary, in good time. |
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5.3

The target of 5 % of total vehicles on the roads to be subject to roadside inspection (point 3.2.3) seems ambitious given the high number of light commercial vehicles (LCV) in circulation that are to be added to the medium- and heavy-duty ones already subject to inspection. By way of illustration, in the years 2010-2011 alone more than three million LCV were registered as against around 450 000 medium- and heavy-duty vehicles, and LCV account for over 80 % of the commercial fleet in circulation.

In this regard, the Committee feels that a survey should be carried out of the EU's mobile inspection unit stock so that Member States can supplement their stock, as necessary, in good time.

Brussels, 12 December 2012.

The President of the European Economic and Social Committee

Staffan NILSSON

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