EN    EN EN 
EN    EN  EUROPEAN COMMISSION 
Brussels, 13.1.2011 
SEC(2011) 43 final 
  
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the  
Proposal for a 
DIRECTIVE OF THE EUROPEAN PA RLIAMENT AND OF THE COUNCIL 
amending Directive 2000/25/EC as regards the application of emi ssion stages to narrow-track 
tractors 
Impact Assessment 
SEC(2011) 44 final 
COM(2011) 1 final 
This report commits only the Commission's servic es involved in its preparation and does not 
prejudge the final form of any deci sion to be taken by the Commission 
 
EN 2   EN TABLE OF CONTENTS 
1. Procedural issues and positions from consultation of interested parties .............. 4 
1.1. Introduction .............................................................................................................. .... 4 
1.2. Organisation of the impact assessment ........................................................................ 4 1.3. Impact Assessment Board ............................................................................................ 5 1.4. Relevant scientific studies............................................................................................ 6 1.5. Consultation of stakeholders ........................................................................................ 6 
2. Background, problem defini tion and subsidiarity .................................................. 7 
2.1. Policy Context............................................................................................................ .. 7 
2.2. Economic context......................................................................................................... 9  
2.3. Market overview .......................................................................................................... 9  
2.4. Emissions from Narro w-track Tractors...................................................................... 11 
2.5. Problem definition...................................................................................................... 11  
2.6. Affected parties .......................................................................................................... 14 
2.7. Subsidiarity and proportionality................................................................................. 14 
3. Objectives.................................................................................................................. 15 
3.1. Definition of objectives.............................................................................................. 15 
3.2. Consistency with other horizontal ob jectives of the European Union ....................... 15 
4. Policy Options........................................................................................................... 17 
4.1. Options identified....................................................................................................... 1 7 
4.2. Options discarded at an early stage............................................................................ 18 
5. Analysis of impacts................................................................................................... 19 
5.1. Impacts of Option 1 (no new action).......................................................................... 19 
5.2. Impacts of Option 2 (Allowing 3 extra years)............................................................ 24 5.3. Impacts of Option 3 (Allowing 5 extra years)............................................................ 26 5.4. Impacts of Option 4 (Exemption)............................................................................... 27 
6. Comparison of the options....................................................................................... 28 
7. Monitoring and evaluation ...................................................................................... 30 
7.1. Indicators of progress towards meeting the objectives .............................................. 30 
7.2. Ongoing dialogue with stakeholders.......................................................................... 30 
EN 3   EN Annex I – Glossary & Definitions............................................................................................ 32 
Annex II - Reference Documents............................................................................................. 34 Annex III – Emission limit sta ndards relevant for NTTs......................................................... 35 
Annex IV - Implementation dates ............................................................................................ 36 Annex V – Examples of Narrow Track Tractors...................................................................... 39 
Annex VI - Typical NTT Engine an d Vehicle Development Process...................................... 40 
Annex VII –Stakeholders' opinions at Working Group for Agricultural Tractors meeting..... 41 
Annex VIII – Relevant parts of the JRC report 2008............................................................... 46 Annex IX – Relevant sections  of the ARCADIS report 2009.................................................. 59 
Annex X – Relevant sections of the ARCADIS SME Test report 2010.................................. 68 
Annex XI - Fleet and annua l sales of tractors .......................................................................... 81 
Annex XII – Estimation of environmental impacts.................................................................. 82 
EN 4   EN  
1. PROCEDURAL ISSUES AND POSITIONS FROM CONSULTATION OF INTERESTED 
PARTIES  
1.1. Introduction 
This report provides an assessment of the im pact of pollutant emission requirements on a 
specific type of agricultural tractor, ge nerally called the narrow-track tractor (NTT)1. 
NTTs exist in three cate gories: T2, C2 and T4.12, as defined in the Framework Directive 
on the type-approval of tractors3. These tractors are specially designed to meet the specific 
terrain and layout characteristics of vineya rds and orchards in Europe and, as a 
consequence, are almost solely produced and us ed in Europe. Their specific design - which 
makes them suitable for use in narrow rows in  vineyards and orchards  - creates particular 
engineering constraints, mainly dimensi onal, for integrating new technology while 
meeting customer requirements.  
Pollutant emissions, such as carbon monoxide (CO)4, hydrocarbons (HC), nitrogen oxides 
(NOx) and particulate matter (PM) from tractors, including NTTs, are regulated by 
Directive 2000/25/EC5. This Directive was amended by Directive 2005/13/EC6 that 
introduced the currently applicable level of  emission limits, called Stage IIIA. It also 
defined the more stringent Stage IIIB and St age IV limits that w ill enter into force 
progressively, depending on the engine power category.7 
Article 4.8 of the amended Dire ctive points to the particular needs of narrow -track tractors 
and tasks the Commission with reviewing and potentially revising the foreseen emission 
limits requirements in accordance with these need s. The current impact assessment (IA) is 
part of the implementation by the Comm ission of this legal requirement.  
It is considered that this IA concerns a ‘n arrow’ legislative action, as defined in Section 
3.3.1 of the European Commission Impact A ssessment Guidelines of 15 January 20098.  
1.2. Organisation of the impact assessment 
The current initiative is mentioned in the Commission's Work Programme under the 
reference 2010/ENTR/011. Directive 2000/25 /EC on tractor emissions, including its 
revisions, makes extensive reference to Dire ctive 97/68/EC on emissions of non-road 
mobile machinery (NRMM). Due to the signif icant overlap between the two legislative 
                                                 
1 See Annex V for examples of narrow tractors.  
2 T4.1 tractors strictly speaking are not narrow-track tractors but high-clearance tractors, riding above the vines during work; 
they have the same constructional limitati ons and problems as th e other 2 categories.  
3 Directive 2003/37/EC  
4 Additional information on abbreviations used is available in the Glossary in Annex I.  
5 OJ L 173, 12.7.2000, p.1.  
6 OJ L 55, 1.3.2005, p.35.  
7 See Annex III, for a detailed table  
8 http://ec.europa.eu/governance/impact/c ommission_guidelines/docs/iag_2009_en.pdf  
EN 5   EN acts, the technical review (s ee supporting studies in secti on 1.4 below) on both legislative 
acts was carried out jointly. The review iden tified a need for acti on in three areas: 
– the need for additional flexibilities for NRMM; 
– the need for additional flexibilities for tractors; 
– the particular difficulties for NTTs to meet the emission requirements. 
The first two areas have already been subjec t to an Impact Assessment and legislative 
proposals are currently in preparation. This report concerns the third area. 
The present Impact Assessment was led by DG Enterprise and Industry and carried out 
between 21 January 2010 and 21 September 2010. Fo r the purposes of th is IA, an Impact 
Assessment Steering Group (IASG) was created involving the Secretariat-General (SG), 
the Legal Service, DG Environment (ENV), DG Mobility and Transport (MOVE), DG 
Economic and Financial Affairs (ECFIN ), DG Employment, DG Trade and DG 
Agriculture. The IASG met twice on 22 July 2010 and 21 September 2010. The SG, 
MOVE, ENV and ECFIN contributed to the IA  either through part icipation in these 
meetings or via written contributions. As signi ficant analysis of the issue had already been 
performed in previous studies (see section 1.4 below), two IASG meetings were deemed 
sufficient.  The suggestions of the IASG group ha ve been incorporated in the IA. 
1.3. Impact Assessment Board 
A draft Impact Assessment Report was pres ented on 20 October 2010 to the Impact 
Assessment Board. Further to that meeti ng, the following improvements have been 
integrated to the report as request ed in the opinion of the Board:  
– the reasons for unavailability of compliant  NTTs were clarified (in Chapter 2) 
– further explanations on the flexibility scheme have been added (in Chapter 2) 
– the technological issues have been ela borated in more detail (in Chapter 2) 
– the baseline scenario and assessment of imp acts have been clarified (in Chapter 5) 
– more detailed treatment of health impacts and the transition to Stage IV have been 
added (in Chapter 5). 
In addition, several other minor improvement s were made, based on technical comments 
received from the Board. 
EN 6   EN 1.4. Relevant scientific studies 
The impact assessment is based on a number of scientific studies9. These were carried out 
to investigate many different t opics, covering NRMM and all ty pes of tractors, as well as 
the specific needs of NTTs . The three studies are: 
– A Technical Review10 by the Joint Research Cent re (JRC), September 2008, which 
includes, inter alia, a specific evaluation on NTTs. For NTTs, the study confirmed the 
severe technical difficulties of meeting St age IIIB and IV requirements. Hence, the 
impacts of exempting NTTs and delaying both stages by 5 years were analysed. 
– An Impact Assessment study11 by ARCADIS, January 2009, to assess the impacts of 
the policy options as defined in the Techni cal Review of JRC. For NTTs, the study 
analysed the impacts of three policy options : no change policy option, a 5-year delay in 
implementation and an exemption from the emission requirements. The 5-year delay 
came out clearly as the preferred option. 
– An additional SME Test study12, March 2010. For NTTs, detailed information was 
obtained for the professional users of N TTs in the agricultural sector and for 
manufacturers of a specific type of N TTs (high-clearance tractors). The study 
confirmed the substantial difficulties these businesses would face if the emission requirements would not be changed, includi ng details on the length of homologation 
procedures. 
1.5. Consultation of stakeholders 
For the assessment of some of the requirements of the tractors and NRMM emissions 
Directives, the Commission’s services carried  out between May and June 2009 an in depth 
consultation with Member States’ author ities and other stak eholders (industry, 
environmental organisations, workers associations)
13. In addition to two meetings of the 
Working Group on Agricultural Tractors (WGA T), composed of representatives of 
Member States and other stakeholders advising the Commission on tractors-related 
issues14, additional meetings were organised with the Committee for European 
Construction Equipment (CECE) and the Co mmittee for European Agricultural machinery 
                                                 
9 All studies can be found on the Europa website: http:// ec.europa.eu/enterprise/sector s/mechanical/non-road-mobile-
machinery/publications-studies/index_en.htm  
10 The final report of the Technical Review is available on the NRMM web page at the Europa website 
http://ec.europa.eu/enterprise/sect ors/mechanical/files/nrmm/final_report_nrmm_review_part_ii_en.
pdf. 
11 The final report is available on the Europa website: 
http://ec.europa.eu/enterprise/s ectors/mechanical/files/nrmm/ia_study_on_nrmm-_final_report_-
_arcadis_en.pdf. The parts of the study relevant for this IA have been included in Annex IX. 
12 The final report is available on the Europa website: 
http://ec.europa.eu/enterprise/sect ors/mechanical/files/nrmm/final_r eport_sme_test_nrmm_2010_03_29_en.pdf . The parts 
of the study relevant for this IA have been included in Annex X. 
13 Summarised information on the contributions of th e public consultation on this proposal may be 
found in Annex V 
14 See Annex VII. 
EN 7   EN Manufacturers (CEMA). On 17 July 2009 a consu ltation was held with the Expert Group 
on Emissions of NRMM.  
An additional meeting with industry repres entatives was organised on 2 September 2010 
with a view to obtaining additional inform ation on the state of preparedness of the 
industrial actors to meet  Stage IIIB and Stage IV emission requirements. 
The positions of different stakeholders  can be briefly described as follows: 
– manufacturers of narrow tractor s have clearly stated sin ce 2005 that there are severe 
technical difficulties for NTTs in meeting the emission requirements. They initially 
called for an exemption and later for a 5-year delay of Stages IIIB and IV.  
– manufacturers of engines and after-treatment  devices have only recently presented new 
technological concepts that could be developed into solutions for NTTs.  
– also, several Member States (Italy, Austri a, France, Spain, Greece, Finland Sweden, the 
Netherlands) have recognised the problem and asked the Commission to take the 
necessary action in order to avoid severe  negative consequences for the sector. 
Also consumer organisation BE UC, representatives of agricu ltural and rural contractors, 
the association of clean fuels (IANGV) and that  of catalysts manufacturers (AECC) were 
invited. No reaction from environm ental organisations was received. 
A summary of the positions expressed by the va rious stakeholders in  those meetings can 
be found in Annex V . 
2. BACKGROUND , PROBLEM DEFINITION AND SUBSIDIARITY  
2.1. Policy Context 
The tractors emissions Directive 2000/25/EC15 was adopted by the Eu ropean Parliament 
and the Council in 2000 and amended in 2005 by  Directive 2005/13/EC. Both acts defined 
the pollutant emission limits and their mandatory introduction dates based on the scientific knowledge available at that time.  
The Directive covers all categories of agricultura l and forestry tractors (hereafter: tractors), 
including the NTTs described above. The required emissi on limits are based upon those 
contained in Directive 97/68/EC, wh ich covers emission limits for non-road mobile 
machinery  (NRMM) because engines used for thes e two applications are of a similar 
technical nature, and it is lo gical that their emission requi rements should be aligned to 
allow interchangeability between engine designs used for NRRM and tractor applications. 
For all types of tractors, the Directive stip ulates the maximum permitted engine exhaust 
emissions as a function of the power of th e installed engine. Moreover, the Directive 
includes a series of emission limit stages of increasing stringenc y with corresponding 
                                                
 
15 OJ L 173, 12.7.2000, p.1. 
EN 8   EN compliance dates16. Tractor manufacturers must ensure that new engines used in their 
tractors comply with these limits when placi ng them on the market. The reductions in PM 
and NO x emissions resulting from stricter emission limits are significant and come in 
addition to those obtained with the previous  Stages. For PM, a reduction by 88 to 94 % is 
required for the transition from Stage IIIA to Stage IIIB; for NO x similar reductions are 
required for the transition from Stage IIIB to St age IV (as can be seen in the last table of  
Annex III ). 
Stage IIIA emission requirements have been ap plicable to NTTs si nce 1 January 2008. The 
implementation dates currently defined concer ning the placing on the market of NTTs for 
the relevant engine categories are as set out in the table below. New type-approvals of NTTs need to comply with the new stages one year ahead of these dates. 
Engine power Implementation date 
(Stage IIIB) Implementation date 
(Stage IV) 
56-75 kW 1 January 2012 1 October 2014 
37-56 kW 1 January 2013 - 
As the Stage IIIB limits are much stricter th an the currently applicable Stage IIIA, current 
engines will need to be modified  or re-designed to ensure that the limits can be respected. 
Engine manufacturers  must develop and apply the tec hnology needed: engines must be 
fitted with electronic control systems and high pressure injection systems that deliver the 
fuel at the right time and in the right qua ntity for a cleaner bur ning in the combustion 
chamber. In addition, exhaust gas recircula tion (EGR) and possibly sophisticated after-
treatment systems are necessar y. Several of these technologie s require additional cooling 
capacity.  
The further transition from Stage IIIB to Stage IV is likely to require the fitting of a NOx 
after-treatment system (or making an existing system more efficient) and/or the installation 
of a Diesel Particulate Filter (DPF). In on-ro ad applications, devel opment work is ongoing 
on combining these after treatment systems into a single device that reduces the space requirement when fitted on the vehicle. 
These redesigns affect tractor manufacturers  who have to adapt the design of their 
tractors to accommodate the modified engine s. This is a time- and resource-consuming 
procedure, the timing of which depends h eavily on the development programmes of the 
engine manufacturers to design engines appr opriate for NTT applications. Considerable 
R&D investment is required for these processes. 
                                                
 
16 The emission limits and implementation dates can be found in Annexes III and IV  
EN 9   EN 2.2. Economic context 
From autumn 2008 onwards most of the EU-based production of machinery has been 
unexpectedly and severely hit by the global financial and economic crisis. Steep falls in sales caused a large decrease in income and available capital to finance the necessary 
technology research and development (R&D) for machinery with Stage IIIB compliant 
engines. Firms prioritise their R&D expenditu re to cover firstly those products with high 
existing and potential sales' volumes. These sa les then provide the business with revenues 
that can be used for R&D in order to develop technical solutions for smaller niche markets.  
For agricultural tractors as a w hole the decline started in most  European countries in early 
2009. For the sector of NTT the crisis seems to have little effect on the sales to date, but 
there will be some indirect effects from other product line s ('normal' tractors) if the 
company produces those too. 
Moreover, the global crisis affecting the Eu ropean economy, particularly the reduced 
availability of credit, has de finitely made R&D and other investments for new products 
harder also for NTT manufacturers. However, this was not considered to be the main 
reason for this action which is firs t of all based on technical grounds. 
2.3. Market overview 
Narrow tractors are a product manufactured excl usively in Europe and sold almost entirely 
on the European market. In other regions of th e world, such as the US A or South America, 
available field space is much bigger (JRC, 2007) and therefore norma l types of tractors 
with specific dedicated equipment can be used for the cultivat ion of vineyards and 
orchards.  
The European Committee of associations of  manufacturers of Agricultural Machinery 
(CEMA) estimates that around 26 000 units of NTTs are sold per year in the EU, and 
2 500 outside the EU
17. NTTs represent around 16% of the total EU market for new 
tractors, which is about 160.000 units annually. The average price of a narrow tractor is 
€ 30 000 with a minimum of € 17 000 and a maximum of € 58 000, corresponding to an 
estimated turnover of € 843 million. However, fo r very specific products (types) the prices 
can be as high as € 100 000. These prices are 15- 20% higher than for a 'normal' tractor of 
comparable engine power and even up to 50% higher for sophisticated versions due to the need to design as small as possible NTTs with  specific technical features to be able to 
manoeuvre in narrow vineyard and orchard rows. 
NTT use engines of the power categories be low 75 kW. Around 75% of the NTTs sold are 
in the 37-75 kW engine categories and are the focus of this report. The NTTs which fall in 
the lower engine categories (below 25 kW ) are not subject to Stage IIIB and IV 
requirements. NTT manufacturers do not produ ce their own engines, but purchase them 
directly from specialised e ngine manufacturers. The latt er supply also engines for 
machinery and other types of tractors. New e ngine designs are usually developed in the 
first place for applications in different types of machinery. The engine designs are then 
                                                
 
17 See Annex XI for more details.  
EN 10   EN adapted, either by the engine supplier or the tractor manufacturer, for tractors. Special 
tractors, such as NTTs, require further technical development of the engine and 
surrounding systems (see Annex VI for typical  industrial development steps and their 
timeline). Since NTTs constitute only a mi nor market for the engine suppliers, the 
development work of an engine specifically for an NTT may not repr esent a high priority 
for an engine manufacturer compared to othe r engine categories. Delays in developing 
engines appropriate for NTT applications may impact on NTT manufacturers as NTT 
vehicle re-engineering can only occur on ce the basic engine design is known.  
The development and production of NTTs is to  a very large extent done by specialised 
companies of a limited size and capital. This can  be illustrated by the fact that some major 
tractor manufacturers have NTTs in their offe r, but instead of produc ing them themselves, 
they rely on the supply from sm aller manufacturers dedicated completely to producing this 
type of product. An SME Test study was pe rformed and investigat ed, among other things, 
the specific situation of small businesses producing or using NTTs18.  
In terms of market structure, for tractors belonging to the categories T2 and C2 , the 4 
largest companies in the EU hold a market shar e of 55%; the remainder of the market is in 
the hands of SMEs. All producers are based in  Italy or Germany, and the SMEs are all 
Italian. Altogether, these producers empl oy 1 800 people directly, and 1 200 people 
indirectly. The SME test study (see Section 1.4. above) was not able to provide much 
specific data on T2 and C2 ma nufacturers, as the companie s contacted did not match the 
official definition of SME ( i.e. having a maximum of 250 empl oyees). In fact, the larger 
companies in this segment typically empl oy 300-400 persons and ther efore can still be 
considered as small industrial enterprise s, although strictly speaking not SMEs.  
According to the same study, high-clearance tractors (T4.1) are typically produced in 
France. The total production is 500-600 uni ts per year, with 95% coming from 2 
manufacturers (one SME, one is part of a larger group); 5% comes from 3 very small 
specialists. 90% of the production is sold in France. Sales dropped 12% in 2007-2008 and 
another 12 to 15% in 2009, largely as a resu lt of the economic recession. The study 
observed that for two out of the three companies interviewed the length of the homologation procedure was a major concern a nd that the implications of future emission 
requirements were not well understood. However,  these two companies were very small 
businesses, representing a very limited part  of the market. These observations cannot be 
generalised for the high -clearance segment, neither to the NTT sector as a whole, and 
should be considered of marginal importance.  Further details on these manufacturers can 
be found in the SME Test study. 
End-users of NTTs are typically SMEs, a nd mostly micro-firms including farmers and 
contract workers. NTTs are used mainly in th e mountains and hills in  Southern Europe in 
the regions where high quality  wines are produced. Further de tails on these companies can 
be found in the SME Test study. 
                                                
 
18 See Annex X: "SME Test study and IA on possible options for reviewing the Directive 97/68/EC 
relating to NRMM", ARCADIS, 30-03-2010. This  includes a chapter specifically on NTT. 
EN 11   EN 2.4. Emissions from Narrow-track Tractors 
The key air polluters from tr actors are particulate matter (PM) and nitrogen oxide (NO x) 
emissions19. Although carbon monoxide (CO) and hydrocarbons (HC) emissions from 
tractors are also regulated, emission requi rements only change marginally for these 
pollutants. Therefore, the analysis will fo cus on PM and NOx. According to the latest 
report of the European Environment Agen cy (EEA) on the EU's emissions of air 
pollutants20 the total PM1021 emissions in the EU27 in 2008 amounted to 2.126 kt. For 
NOx the total emissions were 10.397 kt in 2008. The report also attributes around 4% of 
PM10 emissions and 5% of NOx emissions to off-road vehicles used in agriculture, 
forestry and fishing. For the sake of comparis on, road transport is deemed responsible for 
14 % of PM10 emissions and 37% of NOx emissions. 
Using figures from the Arcadis study (secti on 3.6.1) as a basis for calculation, the annual 
emissions from NTTs can be estimated at 4.8 kt  of PM and 51 kt of NOx. This represents 
0.2% of the total annual emissions of PM in  the EU and 0.5% for those of NOx. These 
emissions are generated by the current NTT fleet, which, taking into account that the 
average lifetime of an NTT is nine years,  includes only a small proportion of NTTs 
complying with Stage IIIA. This contributio n from NTTs to air pollution in the EU 
provides the rationale for increasing the effort s to reduce pollutant em issions in the coming 
years. Any proposal should therefore caref ully consider the policy objective to 
progressively reduce overall air pollutant emissi ons from road transport, including tractors.  
2.5. Problem definition  
The problem under examination concerns the f easibility of meeting the currently enacted 
emission requirements for NTTs. As things curre ntly stand, this issue is composed of two 
elements: regulatory failure and lack  of technological feasibility.  
2.5.1.  Regulatory failure 
When the emission limits for NTTs were introduced by the legislator there was a limited 
amount of information available on the techno logy needed to meet those values. The 2004 
amendment for NRMM, Directive 2004/26/EC wa s based on the need for alignment with 
USA exhaust emission legislation. At that tim e, the envisaged measure was much broader 
and the specific impact on NTTs was probably underestimated. However, the Directive did 
provide for a technical revi ew clause which, among others , requires the Commission to 
“consider the available technology , including the cost/benefits, with a view to confirming 
                                                 
19 Definitions of the gaseous and particulate pollutants are the same as in Directive 97/68/EC Annex I, 
as amended, and include:  '2.2. gaseous pollutants shall mean carbon monoxide, hydrocarbons (assuming a ratio of C1: H1.85 
and oxides of nitrogen, the last named being expressed in nitrogen dioxide (NO2 equivalent; 2.3. 
particulate pollutants shall mean any material co llected on a specified filter medium after diluting 
C.I. engine exhaust gas with clean filtered air so that the temperature does not exceed 325 K 
(52 oC)' 
20 http://www.eea.europa.eu/publications/e uropean-union-emission-inventory-report  
21 Particulate matter below 10 µm diameter 
EN 12   EN Stage IIIB and IV limit values and evaluating the possible need for additional flexibilities, 
exemptions or later introduction dates for cer tain types of equipment or engines and 
taking into account engines installed in non-road mobile machinery used in seasonal 
applications ”. The 2005 amendment of the tractors Directive was adopted in the 
comitology procedure simply aligning the requirements for all tractors with those 
applicable to NRMM engines. The potential  existence of difficulties for NTTs was 
acknowledged and article 4 (8) was introduced requiring a further study of the feasibility 
of the foreseen emission limits for NTTs. 
Over time, it was confirmed that NTTs would have serious difficulties meeting the 
emission requirements. This is because contra ry to normal –larger- tractors, NTTs have 
only a limited space available for the fitment of  new engine and pollutant after-treatment 
technologies, which are needed to meet th e next stages of emission limits. These new 
technologies require more space, which is gene rally not available on NTTs, or could result 
in an increase in the vehicl e size leading to a loss in ma noeuvrability. This would make 
these tractors unsuitable to use in the cu ltivations for which they are designed.  
Further research and technologica l development is required in order to ensure that narrow-
track tractors complying with the Stage IIIB and later the Stage IV emission limits can be placed on the market.  
2.5.2.  Lack of technical feasibility  
The emission requirements of Stage IIIB and IV would not be problematic for NTTs if 
satisfactory technological solutions were available in the appropriate timeframe. An important part of the current analysis has been concentrating on an assessment of recent 
technological developments for engines used in NTTs. The state of the art of technology 
has a large influence on the outcome of this im pact assessment and therefore it is explored 
in detail in this section.  
In 2008, the technical feasibility for NTTs of  meeting the emission requirements of stage 
IIIB was assessed in detail in the report of DG JRC (see Annex VIII), which considered a 
5-year necessary to allow the development of  IIIB-compliant NTTs. Subsequently, some 
new technical developments have taken place, which are taken into account as well. These 
have lead to a downward adjustment of the extent of required technical development. 
Development for engine technologies to meet  Stage IIIB and IV is still ongoing. If the 
implementation dates are mainta ined, engine adaptation and in tegration in the vehicles 
needs to start on current state-of -the-art technology. In that ca se, there seems to be general 
agreement among the relevant e xperts on the following points: 
– Stage IIIB will require electronically co ntrolled engines with high-pressure fuel 
injection systems; 
– For some engine power categories exhaust ga s after treatment may not be required to 
comply with the Stage IIIB limits whilst for others one of the following may be needed:  
• either the fitment of cooled exhaus t gas recirculation (EGR) and diesel 
particulate filters (DPF) or  
EN 13   EN • selective catalytic redu ction (SCR) technology.  
– The first technology is the most lik ely to be implemented for NTTs. 
– Stage IV will need the simultaneous adopti on of both the above mentioned technologies 
which may however be combined into  a single after treatment system. 
The installation implications can be summarised as: 
– Increased cooling capacity of the engine due  to the cooled EGR estimated between 15 
and 25% of present requirements and equiva lent increase of the cooling radiator 
volume; 
– Installing a DPF with a ca. 20 dm3 volume; 
– Installing an SCR system with a ca. 25 dm3 volume. 
As described in detail in the JRC report, these implications are incompatible with the space 
constraints created by the user requirements to operate in vineyards and orchards. The 
severity of these constraints can be illustrate d by the fact that alre ady today several NTTs, 
in addition to the main fuel tank, are equi pped with small secondary fuel tanks, fitted 
wherever space is available under the hood. Also, larger engine compartments may require 
farmers to replace their implements (tools  mountable on the engine and tractor for 
performing specific agricu ltural operations) and/or damage the fruits by exposing them to 
heated surfaces. 
NTTs operate as mobile power sources for a wide range of implements, which are tools 
mounted on the engine of the tr actor necessary to perform diff erent operations in vineyards 
and orchards. As mentioned before, these ar e often located in mountainous areas, which 
also pose a certain demand on engine power. Over time the power demand increased to 
achieve an indicative upper limit of 75 kW. The chosen engine power of a NTT is essential 
to meet its customer requirements. Therefor e, replacement of higher power NTTs by those 
with an engine of a lower power category, wh ich are not subject to the next emission 
stages, would not be a acceptable solution for NTT users. 
In the course of 2010, new technical developm ents have been communicated by the engine 
and after-treatment supplying i ndustry. A few engine concepts have been presented that 
are capable of meeting stage II IB requirements without the us e of a DPF. However, these 
engines were designed primarily for the use in machinery and the adaptation to tractors, 
particularly to NTTs, remains to be prove n. Without DPF, the space implications for 
integrating the new engine concept in the current engine compartments are mitigated. Also, after-treatment technology has recently de monstrated a progress: specific concepts 
have been developed that offer better potenti al for integrating this  technology within the 
space constraints of NTTs. It has to be stressed, however, that neither of these technologies 
is sufficiently developed at the time of the present assessment to en able NTTs meeting the 
Stage IIIB limits within the current legal timeframe. 
For Stage IV-compliant technology, which w ould be compatible with NTT-needs, no 
technical solution is for the moment demonstrat ed, even as a R&D concept. Even if Stage 
IV technology is likely to rely on the use of both sophisticated engine measures, such as 
EN 14   EN high-pressure fuel injection and cooled EGR, as well as both DPF and SCR after-treatment 
technology (potentially combined) as explaine d above, engine and after-treatment system 
manufacturers will have to de velop the technology further to  propose a system that meets 
the limit values. With regard to the instal lation in NTTs, Stage IV compliant engines 
would face even bigger challenges, given the need for large after-treatment systems.  
In conclusion, the current state of technologica l development of engine and after-treatment 
technologies is considered such that stag e IIIB-compliant technology could be available 
for NTTs once the recent prototypes for other applications have been adapted to fit NTT-
needs, integrated and tested in the vehicle. Th is process, according to standard industrial 
leadtimes (see Annex VI), will take between 3 and 6 years. Although the industry stated 
that significant R&D investment s have been made in the past years, the probability that 
some manufacturers may be ready before 3 years is considered low. For Stage IV-
compliant technology, the fitment of after-treatment systems w ill be needed and NTTs are 
likely to face difficulties integrating this eq uipment. If technical solutions are found, it is 
very likely that it will take  a full development cycle of 6 to 10 years before acceptable 
Stage IV-compliant NTTs can be put on the market. 
2.6. Affected parties 
The things as they currently stand affect both the European manufacturers of NTTs and 
farmers who rely on the use of NTTs. While the former are left with neither sufficient time 
nor sufficient technological development to adapt their products to the new emission 
limits, the latter are left with no modern m echanisation tools needed in the European 
specialized agriculture.  
2.7. Subsidiarity and proportionality 
The legal basis of this initiative is the sa me as for the tractors emissions Directive 
2000/25/EC, namely Article 114 of the TFEU on the approximation of laws. 
The Directive already harmonises the laws of  the Member States relating to emission 
limits and the type-approval pr ocedure for engines to be installed in tractors. Any 
modifications to the Directive can only be done at EU level.  Therefore EU action is 
justified and provides added va lue in maintaining the internal market for tractors. 
In terms of proportionality, a close review of th e impacts of legislation is important in this 
case. There is a rather small and geographi cally concentrated market for NTTs, which 
potentially has to cope with prohibitive comp liance burden or severe  technical challenges 
to adapt to new legal limits.  
EN 15   EN 3. OBJECTIVES  
3.1. Definition of objectives 
The objectives are mainly twofold: competitiveness and environment related. The general, 
specific and operational objectives ar e set out in the table below. 
GENERAL SPECIFIC OPERATIONAL 
1. To safeguard 
the competitiveness and viability of the tractor industry. 1. To enable industry to 
continue investing in R&D so that technology becomes available for all NTTs to meet Stage IIIB and Stage IV. 1. To introduce a cost effective and 
timely measure that allows engine and tractor producers to  continue selling 
new NTTs. 
2. To allow industry to finance 
expenditure on R&D in the short term to develop innovative tractors by allowing them to continue to generate revenues from sales. 
2. To maintain a high level of environmental protection. 1. To limit the overall 
emissions of the NTT tractor fleet by enabling fleet renewal. 1. To enable the replacing of older, 
more polluting and fuel consuming engines and tractors by cleaner ones by setting emission requirements in such a way that demand for new tractors can be met by the cleanest available models.  
2. To send a clear signal to industry 
that further emission reductions are required and that th e current path of 
reducing emissions is maintained. 
3.2. Consistency with other horizontal objectives of the European Union 
3.2.1.  The European Economic Recovery Plan 
The present proposal is in line with the objectives of the EU 2020 Strategy22 and 
complements the European Economic Recovery Plan (EERP)23. Adopted in November 
2008, the EERP addresses the difficulties of  the wider economy brought about by the 
global financial crisis. The Plan  outlines a series of measures  to cope with the squeeze on 
credit, declining sales and revenues. It refers in ter alia to the need for a swift stimulation of 
demand and consumer confidence as well as m easures to lessen the human cost of the 
                                                 
22 COM(2010) 2020  
23 COM (2008) 800 
EN 16   EN economic downturn and its impact on jobs. Th e EERP highlights the need to ensure full 
coherence between immediate actions and the EU’s medium- and longer term objectives.  
Such immediate action needs to focus on improving business conditions through 
maintaining the competitive industrial base  and through promoting a knowledge based and 
low carbon economy as set out in the EU2020 Strategy. 
3.2.2.  Environmental Policies 
The tractors emissions Directive, which provides an important contribution to a 
progressive reduction of air polluti on, is also in line with the EU environmental policies, in 
particular with the Sixth European Envi ronment Action Programme and one of its 
initiatives – the Clean Air For Europe (CAFE) strategy. The initiative sets out an integrated and long term strategy for reducin g the adverse impact of air pollution on 
human health and environment. These obj ectives are implemented through Directive 
2008/50/EC
24 on ambient air quality and cleaner air for Europe which establishes a system 
for the assessment of ambient air quality and provides thre sholds for each pollutant. 
Member States have to assess and manage the ambient air quality. Besides this instrument 
it remains important to combat emissions of  pollutants at source and to implement the 
most effective emission reduction measures. 
Today, a large number of Member States are in non-compliance with the air quality limit 
values for PM 10 which entered into force in 2005 but where extra time has been granted for 
some air quality management zones until June 2011. Many Member States are also expected not to comply with the air quality lim it values for nitrogen dioxide when official 
monitoring data is reported in  2011. One of the reasons most frequently cited by Member 
States for their non-compliance with PM
10 air quality limits is the substantial contribution 
made to observed levels from transboundary air pollution. In this respec t, it is important to 
note that more than 10 Member States are expected not to comply with their national 
emission ceilings for NOx (under the Direc tive 2001/81/EC) that ar e binding from 2010 
onwards based on their emissions forecasts so far submitted to the Commission25. 
It is broadly recognised that these problems, as far as they are related to vehicles, are 
largely caused by the emissions from the exis ting fleets, which are still composed of many 
old vehicles. Current actions therefore focus on measures stimulating fleet renewal and 
retrofitting. 
                                                 
24 Directive 2008/50/EC of the European Par liament and of the Council of 21 May 2008 on ambient air quality and cleaner air 
for Europe (AAQD) entered into force on 11 June 2008. It merg es existing legislation into a single directive with no change 
to existing air quality objectives for PM 10 and NO x contained in Directive 1999/30/EC; maintains two limit values for NO x 
based on hourly and annual average concentra tions; sets (new) air quality objectives for PM 2.5 including the limit value and 
exposure related objectives – exposure con centration obligation and exposure reducti on target; creates the possibility for time  
extensions for compliance up until June 2011 for PM 10 (where the limit values entered into force on 1 January 2005) or up 
until 31 December 2014 for NO 2 and benzene) based on conditions and the a ssessment by the European Commission. Single 
most important condition is that the notifi cation must include an air quality plan that delivers compliance by the extended 
deadline for compliance.  
25 http://www.eea.europa.eu/publications /nec-directive-status-report-2008  
EN 17   EN 4. POLICY OPTIONS  
4.1. Options identified 
Six policy options have been identified as pos sible means of meeting the policy objectives 
described in the previ ous section. These are: 
• Option 1- No new action = Baseline scenario.  
The current implementation dates for NTTs , to achieve compliance with the new 
Stage IIIB and Stage IV limits remain unchanged, meaning that Stage IIIB would be required for new NTTs starting from  1 January 2012 and Stage IV from 1 
October 2014.  
• Option 2 – Allowing 3 extra years for impl ementation of Stages IIIB and IV for 
NTTs. 
The implementation dates for NTTs for m eeting Stage IIIB and Stage IV emission 
requirements would be delayed by 3 years. Stage IIIB would be required for new NTTs starting from 1 January 2015 and Stage IV from 1 October 2017. 
• Option 3 – Allowing 5 extra years for impl ementation of Stages IIIB and IV for 
NTTs. 
The implementation dates for NTTs for m eeting Stage IIIB and Stage IV emission 
requirements would be delayed by 5 years. Stage IIIB would be required for new NTTs starting from 1 January 2017 and Stage IV from 1 October 2019. 
• Option 4 – Exempting NTTs
 from Stages IIIB and IV for NTTs.  
Given the specific design constraints of  NTTs and their limited market share 
compared to the entire tractor market, an  additional option coul d be to completely 
exempt NTTs from Stages IIIB and IV requirements. This would maintain the 
current Stage IIIA requirements for these special tractors for an unlimited period of time.  
• Option 5 – Skipping Stage IIIB and introduci ng Stage IV at th e dates originally 
foreseen 
This option foresees skipping Stage IIIB and introducing Stage IV emission limits 
at the dates originally foreseen in the tr actors emissions legisl ation i.e. as of 1 
October 2014. 
• Option 6 – Extending the flexibility provisions for NTTs  
This option foresees a further extension of the flexibility provisions in the Tractor 
Emissions Directive for NTTs, so as to allow them to sell an additional number of non-compliant tractors without changing the emission requirements as such. 
EN 18   EN 4.2. Options discarded at an early stage 
• Option 5:  
Some companies may find it beneficial to focu s directly on solutions capable of meeting 
Stage IV and would therefore avoid investi ng resources in developing an intermediate 
solution. However, as shown in  Annex III, Stage IV will not  apply to the power category 
between 37 and 56kW. This option would ther efore only be applicable to the power 
category between 56 and 75 kW.  
Furthermore, the JRC study highlighted that th e technical solution to meet Stage IV would 
imply an improved engine and extensive after-treatment systems to reduce both PM and 
NOx emissions. Stage IV solutions will largely build on Stage IIIB compliant-technologies, and therefore the two stages are mutually complementary. In terms of 
technical feasibility, manufactur ers will face the same design and installation problems as 
encountered with Stage IIIB. The state of the art of technology, as discussed in section 
2.5.1, is in such a premature stage that the po ssibility for NTTs to meet Stage IV in 2014 
can be excluded with near certainty. Even if  this option would avoi d the negative impacts 
on the sector and the environment between 2012 and 2014, damages of a similar nature 
(impossibility to sell compliant NTTs, loss of  revenues, continued us e of old tractors) can 
be expected as of 2014, probably in an even la rger extent. This is because vehicle design 
(as demonstrated in Annex VI) will take mu ch longer than the time  available until the 
mandatory introduction of Stage IV foreseen by the legislation and after-treatment seems 
unavoidable, creating particular difficulties for integration in to NTTs. Moreover, it would 
mean a waste of resources for the companies th at have invested in technical solutions for 
Stage IIIB (see Annex VII). Ther efore, this option has been discarded, since it will not 
deliver on the define d policy objectives. 
• Option 6:  
The current Tractor Emissions Directive in cludes flexibility provisions which allow a 
number of new tractors non-complying with the new emission stage to be sold in the year 
following the introduction of this stage. Current ly this is limited to 20% of the number of 
sales in the previous year. The Commissi on adopted a proposal on 27 October 2010
26 to 
increase the flexibility provisions to 50%. In  both cases, these provisions would provide 
only limited relief to manufacturers, allowing th em to continue sales for a period of a few 
months, which are far from sufficient to allow technical solutions to be developed in time (see section 2.5.2).  
In order to bring the flexibility for NTTs more in line with th e leadtime needed for 
developing compliant NTTs, one could imagin e a further extension of the flexibility 
provisions, specifically for NTTs. In that case,  the flexibility provisions would need to be 
around 300%. In practice, such an option w ould represent a delay of 3 years in the 
application of the new emissions Stages, very similar to Option 2. However, the administrative burden for manufacturers and ad ministrations to implement the flexibility 
scheme would be significantly higher. Fo r that reason, this option was discarded. 
                                                
 
26 COM(2010) 607 final  
EN 19   EN 5. ANALYSIS OF IMPACTS  
As this IA concerns a 'narrow' legislative action, it will assess the options essentially in a 
qualitative way with quantifications for those impacts for which sufficient data was available. The options will be  analysed with respect to the economic, environmental and 
social aspects. The economic impacts consider ed include the direct impact of sales and 
revenues on industry, including many  SMEs, the indirect impact on users of increased cost 
and price, or unavailability of NTTs and th e impact on R&D investments, their expected 
returns and innovation. The environmental imp acts considered include the emissions of 
PM and NOx and the correspondi ng cost estimates. The social impacts considered include 
employment and the safety of wo rkers related to the use of di fferent types of tractors. For 
the latter, it is important to not e that all new tractors entere d into service after July 2009 
are legally required to be e quipped, among other safety-related measures, with roll-over 
protection, which is particular ly relevant for the safety  of workers using NTTs.  
The assessment is based on the data available from different sources, including the JRC 
and Arcadis studies and the indus try itself (in particular engi ne, after-treatment and tractor 
manufacturers), who delivered information on R&D results a nd the state of the art of 
technology related to the introdu ction of the new stages for NTTs. Additional information 
on the R&D budget for the sector was obtained from EUROSTAT. Some of the factors, 
which are impossible to quantify due to lack of  detailed information from the industry, and 
therefore are not taken into account in the an alysis include: increased learning & training 
costs; reduced availability of manpower; in creased stock piling; reduced availability of 
low volume products; standstill state of the art; increased peak load for certification 
bodies; increased warranty cost due to rush released tractors  and the health impacts of 
workers using NTTs due to the direct exposur e to pollutants. Noneth eless, the magnitude 
of these factors is not likely to affect  the overall conclusions of the assessment. 
5.1. Impacts of Option 1 (no new action)  
Option 1 can evolve in two directions for whic h two different scenarios can be foreseen:  
– Scenario 1a: adapting compliant NTTs to current customer requirements 
Emission requirements remain unchanged, N TT manufacturers are not able to offer 
compliant NTTs once the new limits are requi red (beyond limited flexibility provisions). 
The surviving companies will re-enter the market once a technical solution is found 
permitting NTTs to be used in existing vineyards and orchards. 
– Scenario 1b: Redesigning vineyards and or chards to fit NTTs of a bigger size 
Emission requirements remain unchanged, compliant NTTs could become available 
although of different sizes than those currently  used by the agricultural sector. As a form 
of self-help, the agricultural  sector redesigns the existing vineyards and orchards to fit 
wider or longer tractors. 
Scenario 1b has been investigated in the Arcadis Report (in section 3.6.4.2) and the JRC 
report (in section 5.3.2) and was co nsidered not plausible, due to  the associated high costs 
EN 20   EN that would need to be incurr ed by the agricultural sector  and for other reasons stated 
below: 
Vineyards and orchards were already restru ctured some 10-15 years ago following the 
adoption of the Council Regulation No 1493/1999 on the common organization of the wine market
27. As a consequence, the row width increased from narrow row widths of 
about 1m to larger row widths  of about 2m. One reason was the possibility to switch from 
manual cultivation to techniques assisted by spec ial tractors. Substant ial EU-resources (the 
SME Test report mentions 400-465 M€ annuall y over a period of seve n years) from the 
Common Agricultural Policy were spent for this  purpose, in addition to private and other 
expenses. This shows the extent of the necessa ry investments and, given the fact that the 
average life cycle of a vineyard is forty years, it would eviden tly be an enormous waste of 
resources if farmers would have  to replant vineyards again. 
Further, the JRC report has estimated that re designed vineyards (either by increasing the 
row width or reducing the row length so that larger tractors can turn) would result in a 
20% loss of cultivable grounds . This would obviously be a heavy blow to the relevant 
economic actors and to the competitiveness of th e EU wine sector; espe cially to the part 
producing high quality wines that alrea dy faces strong space limitations and makes 
widespread use of NTTs.  
As scenario 1b is highly unlikely, the analysis of option 1 is based on scenario 1a. This has 
been investigated in detail in the Arcadis study (see Annex IX) and th e analysis below is 
largely based on the conclusions of this study. 
5.1.1.  Economic impact of Option 1 
As explained in the section 2.5.2, the tec hnological development of  engine and after-
treatment technology is not likely  to deliver a cceptable solutions in time for NTTs to meet 
the Stage IIIB and Stage IV limits by the date s currently prescribed by the Directive.  
In that case, NTT manufacturers would not be  able to comply with existing deadlines, 
would continue to struggle with technical problems and would not ha ve tractors ready, 
neither for Stage IIIB nor for Stage IV, un til a technical solution is found. At the same 
time, since the sale of NTTs not complying with Stage IIIB will not be allowed as of 
January 2012, industry would not be able to place products on the market beyond the 
limited volumes offered with the sell off and flexibility provisionsSeveral firms – in 
particular SMEs which are specialised in N TTs and can hardly benefit from revenues in 
other tractor segments, run a si gnificant risk of going out of  business. Following standard 
economic theory, a reduced number of firms will also lead to less competition, lower 
product diversity and probably higher pr ices, thus lower consumer welfare. 
                                                 
27 Under the Council Regulation (EC) No 1493/1999 on the common organisation of the market in 
wine, Member States can obtain annual payments for restructuring and conversion of a set number 
of hectares of vineyards. The objective of this system is the adaptation of production to market 
demand. It covers the following measures: varietal conversion, relocation of vineyards and improvements to vineyard management techniqu es. The system does not cover the normal renewal 
of vineyards which have come to the end of their natural life. As consequence of the restructuring of 
vineyards, the row width has changed from about 1 meter to 1,6 - 2,2 meter. NTT are designed to work in this situation. For more de tail see the JRC report in Annex VIII. 
EN 21   EN Clients of tractor manufacturers will be faced with a disruption of a satisfactory product 
offer. Wider or longer NTTs compliant with Stage IIIB may be offered, but would in the 
best case only be bought by a small number of farmers (for example those who can accept 
a lower yield of their cultivable land). The large majority of users, if not all, will maintain 
existing tractors (for which the purchase cost s have already been amortised) in operation 
until a technical solution is found. That would m ean that they will not be able to purchase 
newer, safer, less fuel-consuming tractors that  can work more efficiently, even though this 
decision brings higher operating co sts. These are estimated at 1339 M€28. 
In terms of R&D investment and innovation, this  option has some benefit. It could indeed 
reward the companies that are the quickest to offer Stage IIIB-compliant NTTs with a 
quasi-monopoly, according to the 'winner takes it a ll' principle. It remains very doubtful 
whether this would avoid an  interruption of NTT supply. It would certa inly create 
casualties as several smaller firms will not have the capital resources to engage in such an 
excessive innovation race, in the absence of revenue  from sales, and are likely to risk their 
business. In the long term, a reduced number of firms and product diversity would have a 
negative impact on innovation. 
The impacts for applying Stage IV without any delay as of October 2014 would be of a 
similar nature as for Stage IIIB  (impossibility to sell comp liant NTTs, loss of revenues, 
continued use of old tractors). However, given the lack of demonstrat ed technical solutions 
and the certainty that they will require after-treatment, the problems for the sector can be expected to be even larger than for Stage IIIB. Also in terms of innovation, impacts would 
be similar, leading to an excessive innovati on race, with a small number of winners and 
many casualties. Based on information currently available, it is considered highly unlikely that any company would be capable of deve loping Stage IV compliant NTTs in time. 
5.1.2.  Environmental impact of Option 1  
Due to unavailability of compliant NTTs, at l east for a number of years after the emission 
limits will enter into force, i.e 2012, the emissions of pollutants cannot achieve the 
reductions that could have been expected from the Tractor Emissions Directive. The 
expected reductions from strict er limits form therefore a hypothetical scenario, which has 
nevertheless been chosen as the benchmark for quantifying and comparing the emissions 
under different scenarios in the JRC and Arcadis studies. It will be referred to as 'hypothetical scenario' in the graphs in this  report. The environmen tal impacts have been 
determined based on external costs of calculated emissions. Emissions have been 
calculated taking into account tr actor/engine stocks, averag e use and the lifetime of 
tractors.  
The Arcadis study estimates that, under Opti on 1, PM emissions and NOx emission would 
be substantially higher than the hypothetical scen ario (blue curve). This is illustrated in the 
two graphs below. The increase in emissions (y ellow curve) is due to the continued use of 
the oldest tractors, whose emi ssions were not regulated at th e time of entry into force or 
complied with the first sets of emission limits.  
                                                
 
28 See SME Test Study, section 8.2.2 
EN 22   EN Figure 1: PM emissions of NTTs (time span 2005-2050) 
 
Source: Arcadis report 
Figure 2: NOx emissions of NTTs (time span 2005-2050) 
 
Source: Arcadis report 
The estimated increase29 in emissions compared to th e hypothetical scen ario amounts to 
4,3 kt for PM and 62 kt for NOx for th e period until 2050. The monetized emission 
impacts for the increased PM emissions are estimated at 60 M€ and those for NOx emissions at 134 M€ over the 2012-2030 timefra me. As this option reflects the baseline 
scenario, the above figures are taken as the reference and the environmental impacts 
indicated for the other policy opti ons are relative to the baseline. 
It should however be noted that the overa ll impact of emissions is not expected to 
significantly affect the Member States obl igations under the Dir ective on Ambient Air 
Quality and Cleaner Air for Europe, which requires MS to meet certain ceilings for 
ambient air quality in defined geographical areas
30. Moreover, the emissions of NTTs are 
normally not generated near those geographical areas in the EU that experience the most 
problems with meeting the air quality targets and associated implications for human 
                                                 
29 See Annex XII for more details  
30 Directive 2008/50/EC L 152 11.6.2008 p1, Annex III Hypothetical scenario 
 Option 1 (baseline)  
Option 3 (5 year delay) 
Hypothetical scenario 
 Option 1 (baseline)  
Option 3 (5 year delay) 

EN 23   EN health. Figure 3 illustrates the geographical distribution of health impacts associated with 
PM emissions in Europe. One exception may be  Northern Italy, wh ere vineyards and air 
quality problems coincide.  
Figure 3: Loss in life expectancy attributable to anthropogenic PM2.5 in 200031 
 
5.1.3.  Social impact of Option 1 
As mentioned in the Arcadis study, the prolonge d disruption (of severa l years) of revenue 
represents a serious risk for all NTT manufac turers, many of which are SMEs or other 
small businesses. The estimated number of jobs32 that could be lost would correspond to 
3000 for around three years. The application of Stage IV (for NTT corresponding to the larger engine power category) would perpetuate  the majority of these losses. The expected 
job losses would be concentrated in Germany,  France and Italy. The larger companies may 
be able to survive thanks to their activities in other (tractor) markets and could re-enter the 
NTT market (for the lower engine power category, not subject to Stage IV) when 
satisfactory technical solu tions have been found, presumably after 3 years. 
As was already explained above, the non-ava ilability of new NTTs will lead to the 
continued use of old tractors, which are not equipped with mode rn safety devices such as 
roll-over protection. This risk should not be underestimated as  the NTTs, due to their high 
centre of gravity and th e fact that they are employed fr equently in mountainous regions, 
are prone to these types of accidents. It can be estimated that  around 80.000 workers, 
active in agricultural cultivation, will be exposed to higher safety risks, at least for the 3 
coming years. 
Option 1 (no new EU action) represents a s erious risk of disrupt ing the NTT industry 
and market, as industry would not have comp liant tractors ready for Stage IIIB, nor 
for Stage IV. Users will not be able to rep lace old polluting tractors with modern 
equipment and are likely to continue to us e old tractors with high pollution and 
deteriorated worker safety. Some compliant tractors (in the lower engine category) 
may come some years later to the market, but the prolonged loss of revenue from 
                                                
 
31 Impact Assessment of the Thematic Strategy on Air Pollution, SEC(2005)1133, 21.09.2005, p. 32  
32 See Arcadis study, section 3.6.4.2  
EN 24   EN NTT could lead several manufacturers to cl ose business, resulting in a significant 
proportion of jobs lost in the sector. St akeholders (mainly from industry) have for 
many years criticised this option and warned against its negative consequences. 
5.2. Impacts of Option 2 (Allowing 3 extra years)  
Unlike Option 3, this Option was not investigated  in detail in the Arcadis study. Therefore, 
the analysis of the present option had to be  performed by adapting th e analysis of Option 
333. Option 2 foresees a Stage IIIB implement ation delay for NTTs shorter by 2 years 
compared to Option 3. The shorter delay takes into account technol ogical solutions that 
have been developed over the past years.  
5.2.1.  Economic impact of Option 2 
As already recalled above, at this moment the available engine and after-treatment 
technology is not mature enough to allow industry to build this into  NTTs and comply 
with Stage IIIB requirements. The specificities of these ve hicles (very narrow design, all 
hot components under the engine hood, short tu rning circles required, inherent risk of 
instability) asks for furthe r development of technology: smaller components, smaller 
engines still suitable for this purpose. The addi tional 3 years can be expected to help all 
related industries (vehicle, e ngine and after- treatment manufacturers) to solve these 
issues. 
The compliance costs for tractor manufacturers to cope with the new emission limits are 
nevertheless significant. Thes e costs include for example: costs for research and 
development, equipment redesign, after trea tment devices, investment, documentation and 
labelling, etc. In order to recover those i nvestments, the price of NTTs will have to 
increase. This is particularly challenging for NTTs in the engine pow er range of 56-75 kW 
as they only have less than three years before  Stage IIIB tractors have to be replaced by 
Stage IV. The increase in price is estimated at 15% (according to industry sources). Above 
the normal expenses projected for NTT replac ement, this would amount to additional 
equipment expenses for the users of NTTs of  117 M€ per year, starting in 2015. It can be 
expected that these costs will decrease over time thanks to learning effects, economies of 
scale and product optimisation. Moreover, and c ontrary to the situa tion for manufacturers 
of other categories of tractors and all other aspects being equa l, for NTT the cost increases 
are less of a problem compared to the availabili ty of viable technologie s, as these tractors 
already adopted sophisticated and expensiv e solutions and are priced well above the 
equivalent conventional tractor. 
Manufacturers estimate that they  would have to increase th eir R&D spending from 3% to 
more than 6% of turnover over the coming 4 y ears in order to meet Stage IIIB as of 2015. 
Total R&D investment from NTT manufacturers is therefore expected to be around 50 M€. 
These costs include the homologation, which is perceived as time consuming and 
                                                 
33 The estimation was obtained by assuming a proportionate relationship between the calcu lated emissions and the length of the 
delay. A similar approach was used  for the monetized emission impacts.  
EN 25   EN particularly burdensome for small companies (s ee the SME test report in Annex X). They 
do not include the necessary investments by en gine manufacturers and system suppliers. 
This option seems to foster innovation in a healthy way. It w ould provide sufficient 
leadtime to those companies that have invested early in R&D to be able to develop Stage IIIB-compliant solutions in time and get a fair return on investment, compared to competitors that have invested later.  
Also for Stage IV, the delay can be expected to provide sufficient time to develop 
compliant NTTs, if technical solutions can be demonstrated in the near future. It would 
provide an immediate boost for R&D investments as prototype solutions need to be found 
rapidly in order to be able to put complia nt NTTs on the market by the new deadline. 
5.2.2.  Environmental impact of Option 2  
Before Stage IIIB would be applied, industry woul d in the meantime st ill be allowed to 
place on the market Stage IIIA compliant tractor s that would in turn replace older, more 
polluting ones still in use. Simulations of emissions under this option were unfortunately 
not performed in the Arcadis and JRC studies, but can be estimated by adapting the results 
provided for Option 3. In the Figure 1 and Fi gure 2 on PM and NOx emissions (on pages 
21-22), under option 2 the curve would follow the one for option 3 until 2015 when it would tend towards the line for the hypothetical  scenario. Emissions compared to the 
baseline scenario are estimated by adapting the JRC results for Option 3 (see Annex XII). 
They would amount to a reduction in emissions  of 2.2 kt (-5.2%) and 42kt (4.1%) for PM 
and NOx respectively until 2050. 
The monetized emission impacts for the reduced  PM emissions can again be estimated by 
adapting the results for Option 3 from the Arcad is study. This would re sult in a benefit of 
31 M€ and would set those for NOx emissions at 91 M€. The total environmental benefits 
can thus be estimated at 122 M€ comp ared to the baseline scenario.  
5.2.3.  Social impact of Option 2 
It is expected that, with the three additional years, the majority of manufacturers can adapt 
their NTTs to meet Stage IIIB while satisfying the essential user requirements. Therefore, 
the social impacts of this option on the indus try are not very signif icant. It cannot be 
excluded that a small number of firms are not capable of adapting to the new more 
advanced technology, leading to some job losses. It is likel y, however, that these losses 
will be compensated by additional jobs wi th stronger competitors. Compared to the 
baseline scenario, there woul d be a significant improveme nt in worker safety. As 
mentioned before, customers will be able, dur ing the 3 year delay, to replace old NTTs 
with new (Stage IIIA-compliant) tractors. As there is no difference in safety requirements 
for NTTs complying with Stage IIIA and Stag e IIIB, the improvement of worker safety 
will be safeguarded under this option. 
Option 2, by allowing NTTs three extra year s to comply, would be very effective in 
mitigating the economic impacts on the industry to challenging but feasible 
proportion, without serious social drawba cks. Also, the environmental impacts are 
EN 26   EN improved due to the fact that, while Stage  IIIB NTTs are not available, new Stage 
IIIA NTTs will be able to reduce pollutant em issions, compared to the old NTTs that 
they will replace. Industry would, however,  remain under continuous pressure to find 
technical solutions to meet the new emissi on limits introduced by the Directive, so 
innovation is fostered. Some industrial compan ies have indicated that this might be 
feasible, while others think it is not. 
5.3. Impacts of Option 3 (Allowing 5 extra years)  
5.3.1.  Economic impacts of Option 3 
This Option has been investigat ed in detail in the Arcadis study (see Annex IX) and this 
analysis is largely based on it s conclusions. The analysis is similar to the one for Option 2. 
Therefore, the remarks here will focus on the differences compared to Option 2. 
With an additional period of 5 years, all re levant industrial actors should have sufficient 
time to develop technical solutions for NTTs  to meet Stage IIIB emission requirements. 
The additional two years compared to Option 2 may be needed if the initial technical 
developments for machinery engines discusse d in Section 2.5.2 do not  progress as quickly 
as expected into suitable solutions for NTTs.  
The compliance costs can be expected to be somewhat lower than under option 2, as the 
technology has more time to improve and progress along the 'learning curve'. Price 
increases for customers could amount to ar ound 13% initially, l eading to additional 
expenses of around 100 M€ per year initially. Again, these costs are likely to be reduced 
over time. 
In terms of innovation, there may be a drawback for this option. The industrial actors that 
invested to develop Stage IIIB solutions as quickly as possible may be able to offer NTTs 
complying with Stage IIIB even  before the implementation dates. In the absence of fiscal 
incentives, these products would be put at a competitive disadvantage due to the higher 
price compared to IIIA-compliant NTTs . Forward looking business decisions and 
investments in innovation may therefore not be  rewarded. In terms of legal certainty, it 
could also be considered a pe rverse incentive if economic acto rs that did not prepare for 
meeting Stage IIIB in the past years, will now benefit from an opportunity to catch up with 
competitors. 
Also for Stage IV, the 5-year delay gives mo re leeway to industry to develop compliant 
NTTs, even if technical solutions are not demons trated in the near future. It would provide 
only a moderate boost for R&D investments as more time is available for finding 
prototype solutions to be able to put comp liant NTTs on the market by the new deadline. 
Some investments could in fact be delayed. 
5.3.2.  Environmental impact of Option 3 
Before Stage IIIB would be applied, industry woul d in the meantime st ill be allowed to 
place on the market Stage IIIA compliant tractor s that would in turn replace older, more 
polluting ones still in use. Simulations of em issions under this option were performed in 
the Arcadis and JRC studies, The pink curv e in the figures 1 and 2 on PM and NOx 
EN 27   EN emissions (p. 21-22) shows the estimated emi ssion under this option. Emissions reductions 
compared to the baseline scenario (yellow cu rve) are estimated (see Annex XII), based on 
the results of the JRC study, at 0.8 kt (-1.9%) and 29kt (-2.9% ) for PM and NOx 
respectively until 2050. 
The monetized emission impacts for the reduced PM emissions are estimated at a benefit 
of 12 M€ and those for NOx emissions at 62 M €. The total real environmental benefits can 
thus be estimated at 74 M€. These results incl ude the effects of both Stage IIIB and Stage 
IV. 
5.3.3.  Social impact of Option 3 
Compared to option 2, a difference is that co mpanies that did not make early investments 
would have time to catch up with their competitors before the new limits become mandatory. Therefore, the risk that a small nu mber of companies will not be capable of 
transforming to adapt to the new market situa tion is even lower, as is the risk for job 
losses. 
As for option 2, there is an improvement in worker safety, brought about by the renewal of 
old NTT by newer models. 
Option 3, allowing NTTs five extra years to comply, would be very effective in 
avoiding job losses in the sector. However, there will be some drawback for environment as the new Stages IIIB requireme nts will not be effe ctive for 5 years. 
According to calculations this will neverthe less be better than option 1, where the old 
tractors (instead of new and Stage IIIA co mpliant ones) will continue to be used. 
Industry would remain under pressure to fi nd technical solutions to meet the 
Directive. It may, however, question somewhat the credibility of legi slation, if it is 
perceived that the industry did not try to meet the limits in time. This option 
corresponds to the current requests from NTT manufacturers. 
5.4. Impacts of Option 4 (Exemption)  
This Option has been investigated to some extent in the JRC study (see Annex VIII) and 
this analysis is largel y based on its conclusions. 
5.4.1.  Economic impact of Option 4  
Under this option, the industry could continue  to produce NTTs at the present Stage IIIA 
level of requirements, as is already the case fo r tractors with small engines (up to 37 kW). 
There would be no specific threat nor pressure  for businesses to seek  innovative solutions. 
Many companies will have done superfluous prep aratory work on techni cal solutions that 
will not be required anymore.  
Customers would benefit as th ey can continue to replace old polluting tractors by 
relatively clean new tractors meeting Stage II IA, but without having to pay the additional 
costs for Stage IIIB and IV. In terms of i nnovation, past investments made by economic 
EN 28   EN actors for meeting Stage IIIB would effectivel y be lost. There would also be no incentive 
to develop new emission-reducing technologies  in the future for meeting Stage IV 
requirements, so environmental innovation in this  sector would come to  a halt. In addition, 
it could again be considered a pe rverse incentive to 'reward' operators that did not prepare 
for meeting Stage IIIB and St age IV in the past years.  
5.4.2.  Environmental impact of Option 4 
The JRC study estimated that emissions of PM per year would in the long term be 0.7 kt 
higher than under the reference level. That would amount to  a total increase in PM 
emissions of around 22.7 kt until 2050, compared  to the baseline scenario (see Annex XII 
for details). Similarly, NOx emissions per year  would be increased by 6 kt per year. Until 
2050, this would give rise to a total of 168 kt of NOx emissions by NTTs. 
The monetization of the environmental impacts under this option was not  carried out in the 
Arcadis report. They would logically be more  or less proportionate to the increase in 
emissions and can be estimated at an increase in environmental cost of 313 M€ for PM and 
361 M€ for NOx, compared to th e baseline scenario. These re sults include the effects of 
exempting both Stage IIIB and Stage IV. 
5.4.3.  Social impact of Option 4 
There would be no risk that companies ar e pushed out of business due to emissions 
requirements, as they would effectively stay as they are today. However, a small number 
of jobs related to R&D in the tractor manu facturer and exhaust af ter-treatment supplier 
sector may be lost. As for options 2 and 3, there is an improvement in worker safety, 
brought about by the renewal of old NTT by newer models. 
A permanent exemption does effectively mi tigate the negative impacts for industry 
but does not give any certainty that pollutant  emissions are reduced in the long term, 
as it is far from certain th at NTTs meeting Stage IIIB or IV would be developed. As 
other sources of PM and NOx are expected  to reduce their emissions over time, the 
relative share of NTTs in those emissions will therefore increase. In the short term, 
however, it would be positi ve for environment as at least new Stage IIIA tractors 
would be available to replace older, more polluting ones. An exemption would also 
largely remove any incentive to invest in R&D and innovation in environmental 
technologies for NTTs. Initially, this wa s the solution requested by (industrial) 
stakeholders. More recently, th ey requested a 5-year delay. 
6. COMPARISON OF THE OPTIONS  
The detailed assessment of economical, environm ental and social impacts of the previous 
chapter are summarised in the following table34 for each of the policy options.  
                                                 
34 The impact of the baseline scenario has for methodological r easons been set to zero. The symbols for the other options 
indicate the impact relative to the ba seline scenario, ranging from very unfavourable (--) to very favourable (++)  
EN 29   EN  Option 1 - 
Baseline Option 2 – 3 year 
delay Option 3 – 5 year 
delay Option 4 - 
exemption 
Direct economic impact 
(on industry) 0 
No NTTs sold until 
technical solution is 
found, loss of revenue, 
serious risk of 
bankruptcies + 
Most actors can stay in 
business, sales 
continue, sunk 
investments not lost  + 
All actors can stay in 
business and sales 
continue, sunk 
investment not lost  + 
No need to invest 
more, sales continue, 
loss of sunk 
investments  
Indirect economic 
impact (on consumers) 0  
Cannot renew tools, 
higher maintenance 
costs + 
Additional equipment 
cost of 117 M€ initially 
per year + 
Additional equipment 
cost of +/- 100M€ 
initially per year  ++ 
No particular cost 
increases  
Impact on R&D 0 
Wild race among some 
to innovate, without 
revenue to finance it  ++ 
R&D investment 
continued, allowing 
most to participate  + 
Early R&D investment 
not rewarded, allowing 
all to participate  -- 
No incentive to 
innovate  
PM emissions35 0 
Use of old, polluting 
tractors is prolonged  ++ 
Fleet renewal 
continued, reduction of 
2.2 kt, 31 M€ benefit+ 
Fleet renewal 
continued, reduction of 
0.8 kt, 12 M€ benefit  -- 
Long-term higher 
emissions of 22.7 kt, 
313 M€ cost  
NOx emissions 0 
Use of old, polluting 
tractors is prolonged  ++ 
Fleet renewal 
continued, reduction of 
42 kt, 91 M€ benefit  + 
Fleet renewal 
continued, reduction of 
29 kt, 62 M€ benefit  -- 
Long-term higher 
emissions of 168 kt, 
361 M€ cost  
Impact on employment 0 
Serious risk for job 
losses, up to 3000 over 
3 years + 
Job losses limited, not 
structural, some 
additional jobs at 
suppliers  + 
Job losses further 
limited, not structural, 
some additional jobs at 
suppliers  + 
No risk of significant 
job losses, no 
additional jobs at 
suppliers  
Impact on worker safety 0 
Unsafe tractors are 
used longer, ca. 80.000 
workers exposed  + 
Improvement of safety 
through fleet renewal+ 
Improvement of safety 
through fleet renewal  + 
Improvement of safety 
through fleet renewal
As a result of the above anal ysis, it is concluded that pos tponing the implementation dates 
for NTT with 3 years (Option 2) is the most appropriate measure to ensure that the policy 
objectives of ensuring a competitive industry an d a better protecting the environment are 
met.  
                                                 
35 The estimated pollutant emissions and m onetized impacts are relative to the base line scenario. The emissions correspond to 
the timeframe until 2050, the monetized environmental impacts to the 2012-2030 timeframe.  
EN 30   EN The 3-year delay would allow most of the manufacturers to transform the recent 
technological progress into NTTs complying with Stage IIIB limits and simultaneously 
meeting the essential customer requirements  for their use in vineyards and orchards. 
Thereby, significant job losses of Option 1 are avoi ded and the environmental and worker 
safety impacts continue to be positive due to the continued renewal of the EU fleet. 
Compared to Option 3, the delay would be in line with the necessary technological 
development and continue to foster innovati on. With a limited delay, the environmental 
benefits that were expected fr om the original legislation will therefore be realised, unlike 
Option 4. 
7. MONITORING AND EVALUATION  
7.1. Indicators of progress towards meeting the objectives 
Since the implementation of the preferred option entails postponing the deadline for 
complying with Stage IIIB and Stage IV, it is  important to monitor over time the technical 
advancement in the industry, in order to trac k progress towards the transition towards these 
limits. Accordingly, one of the key indicators to be take n into account for evaluating the 
performance of the proposed ac tion is the level of R&D investment in the sector, with 
specific reference to R&D aimed at the develo pment of engines complying with Stage IIIB 
and Stage IV.  
At the same time, the level of sales and prof itability of firms (in particular, SMEs) active 
in the sector will have to be monitored to ensure that the new option contributed to the 
competitiveness of this sector and enables the replacement of old tractors with Stage IIIa- 
compliant and, later Stage IIIB-compliant trac tors. Alternatively, since the key mechanism 
by which the proposed Regulation will take eff ect is the tractor type-approval process, a 
core indicator of progress will be the numb er of NTTs which are successfully type-
approved to the Stage IIIB and IV limit values over time. 
As an additional indicator, where possible, the monitori ng of NOx and PM emissions 
attributed to NTT will reveal whether the c hosen option has positively contributed to the 
environmental objectives related to this policy initiative.  
The monitoring of these indicators can be ca rried out through regul ar contacts with the 
sector’s trade associations and is therefore not expected to lead to significant costs. 
7.2. Ongoing dialogue with stakeholders 
The main reason for this proposed directive is  that the technical a dvancement of the NTT 
industry does not allow for a smooth transition towards Stage IIIB as originally envisaged: this poses both a problem of regulatory failure ( i.e. too ambitious dead lines) and a problem 
of industry competitiveness. The proposed 3-y ear extension is thus a viable solution 
insofar as the industry will be able to invest  in R&D to develop technical solutions that 
comply with the set objectives at EU level for the NTT sector.  
Accordingly, constant dialogue with the industr y, aimed at tracking of R&D investment by 
large and small firms in the sector and monito ring the competitiveness of the sector and its 
EN 31   EN ability to develop suitable te chnological solutions within th e next few years will be of 
utmost importance. In view of the future implementation of the rules at hand, it will be 
essential to monitor the NTT market and the development of  technologies, including the 
appearance of potential solutions for the transition to Stage IV. 
One suitable way of achieving this constant di alogue is to rely on the Working Group for 
Agricultural Tractors (WGAT). 
EN 32   EN ANNEX I – GLOSSARY & DEFINITIONS  
1 - Glossary 
Adsorption: the accumulation of atoms or molecu les on the surface of a material.  
Engine family:  a manufacturer's grouping of engi nes which, through their design, are 
expected to have similar exhaust emission characteristics and which comply with the requirements of Directive 2000/25/EC 
CECE: Committee for European Construction Equipment 
CEMA:  Committee for European Agricultural Tractor Manufacturers 
C.I.:  An engine that works under the compressi on-ignition principle, e.g. diesel engine 
CO: Carbon monoxide  
DPF:  Diesel Particulate Filter 
EGR:  Exhaust Gas Recirculation 
Engine manufacturer:  the person or body who is responsib le to the approval authority for 
all aspects of the type-approva l process and for ensuring conf ormity of production of the 
engines.  
HC: Hydrocarbons 
NO
x: Nitrogen oxides 
NRMM : non-road mobile machinery (e missions directive 97/68/EC) 
NTT: narrow-track tractors (categ ories defined in Directive 2003/37/EC as T2, C2 and 
T4.1, the width of which is less than 1,15 m)  
Original equipment manufacturer (tractor manufacturer ): a manufacturer of a type of 
tractor (final product). 
PM:  Particulate Matter 
UNECE: United Nations Economic Commi ssion for Europe (Geneva) 
2 – Definitions of tractor categories 
Directive 2003/37/EC classifies tractors  by describing the specifications of  
• T2: Narrow wheeled tractors (vineyard and orchard),  
• C2: narrow tracked tractors (vineyard and orchard),  
EN 33   EN • T4.1: High clearance tractors  
as follows: 
Definition of vehicle cate gories and vehicle types  
A. The vehicle categories are defined as follows:  
(1) Category T: Wheeled tractors  
(a) Category T2: wheeled tractors with a maximum design speed of not 
more than 40 km/h, with a mini mum track width of less than 1 150 
mm, with an unladen mass, in running order, of more than 600 kg and with a ground clearance of not mo re than 600 mm. However, where 
the height of the centre of gravity of the tractor (measured in relation 
to the ground) divided by the average minimum track for each axle exceeds 0,90, the maximum design speed  is restricted to 30 km/h.  
(b) Category T4: special purpose wh eeled tractors with a maximum 
design speed of not more than 40 km/h (as defined in Appendix 1).  
- T4.1 High-clearance tractors: trac tors designed for working with 
high-growing crops, such as vines. They feature a raised chassis or section of chassis, enabling th em to advance in parallel with 
the crop with left and right wheels on either side of one or more 
rows of the crop. They are intended for carrying or operating tools which may be fitted at the front, between the axles, at the rear or on a platform. When the tractor is in working position the ground clearance perpendicula r to the crop rows exceeds 1 
000 mm. Where the height of the ce ntre of gravity of the tractor 
(measured in relation to the ground, using the tyres normally fitted) divided by the average minimum track of all of the axles exceeds 0,90, the maximum design speed must not exceed 30 km/h.  
(2) Category C: Track-laying tractors  
Track-laying tractors that are propelled and steered by endless tracks and whose categories 
C1 to C5 are defined by analogy with categories T1 to T5.  
EN 34   EN Annex II - Reference Documents 
Final Report Technical Review - DG JRC- 28 November 2008 
Administrative arrangement for a Tec hnical Review of Directive 97/68/EC, 
carried out by DG JRC, on behalf of  DG ENTR, September 2006 - September 
2008. 
http://ec.europa.eu/enterprise/newsroom/cf/docum ent.cfm?action=display&doc_id=5015&userser
vice_id=1&request.id=0  
Final Report of the IA study - ARCADIS - January 2009 
External specific contract, under LOT5 framework contract, for an Impact 
Assessment study of options presented in  the Technical Review of Directive 
97/68/EC, carried out be ARCADI S N.V., April 2008 - January 2009. 
http://ec.europa.eu/enterprise/newsroom/cf/docum ent.cfm?action=display&doc_id=5028&userser
vice_id=1&request.id=0  
Additional Report on narrow-trac k tractors - DG JRC- June 2008 
Final Report of the SME Test Study a nd IA on possible options for reviewing 
of the Directive 97/68/EC relat ing to NRMM - ARCADIS - March 2010 
Additional external specif ic contract, under LOT5 framework contract, for an 
SME Test study, carried out be  ARCADIS N.V., 2009 - March 2010.  
See Annexes VIII, IX and X for the sectio ns relevant for this impact assessment 
report . 
EN 35   EN Annex III – Emission limit standards relevant for NTTs 
Date of application of the subs equent emission limit standards 
Power Year 
(kW)   2009 2010 2011 2012 2013 2014 2015 2016 
56 - 75 CO: 5,0; HC+NOx: 4,7; PM: 0,4 CO: 5,0; HC: 0,19;  
NOx: 3,3; PM: 0,025 CO: 5,0; HC: 0,19; NOx: 
0,4; PM: 0,025 
                        
37 - 56 CO: 5,0; HC+NOx: 4,7; PM: 0,4 CO: 5,0; HC+NOx: 4,7; PM: 0,025 
                        
19 - 37 CO: 5,5; HC+NOx: 7,5; PM: 0,6 
                        
            
 Stage 
IIIA  Stage 
IIIB  Stage 
IV      
 limit values: gr/kWh         
CO = carbon monoxide; HC = hydrocarbons; NO x = nitrogen oxides; PM = particulate matter; 
Percentage reductions in pollutant emission lim its of subsequent emission limit standards 
 NO x: IIIA Æ IIIB NO x: IIIB Æ IV PM: IIIA Æ IIIB PM: IIIB Æ IV 
56 – 75 kW HC+NOx=4,7 Æ 
HC+NOx=3,49; 27 %  3,3 Æ 0,4 = 86 % 0,4 Æ 0,025 = 94 % 0,025 Æ 0,025 = 0 % 
37 – 56 kW HC+NOx=4,7 Æ no 
change No Stage IV 0,4 Æ 0,025 = 94 %  No Stage IV 
EN 36   EN Annex IV - Implementation dates 
Current Directives 2000/25/EC – 2005/13/EC  36: 
Article 4 - Timetable 
1. Member States may not after 30 September 2000: 
– refuse to grant EC type-approval or national type -approval in respect of an engine type or 
family, or 
– prohibit the sale, entry into serv ice or use of a new engine, or 
– refuse to grant EC type-approval or nati onal type-approval of tr actor types, or  
– prohibit the use, the sale, the initial entry into service of tractor types, 
on grounds relating to air pollution if the pollutants emitted by those engines or the engines fitted to 
those tractors meet the requirements of this Directive. 
2. Member States may no longer grant EC type-approv al or national type-approval for a type or family 
of engines or a tractor type where the pollutants em itted by the engine do not meet the requirements of 
this Directive: 
(a) in stage I 
…. 
(c) in stage III A 
– after 31 December 2005 for engines of categories H, I and K , 
– after 31 December 2006 for engines of category J; 
(d) in stage III B 
– after 31 December 2009 for engines of category L, 
– after 31 December 2010 for engines of categories M and  N, 
– after 31 December 2011 for engines of category P; 
(e) in stage IV 
– after 31 December 2012 for engines of category Q, 
– after 30 September 2013 for engines of category R . 
3. Member States shall prohibit the initial entry into service of engines and tractors where the 
pollutants emitted by the engines do not meet the requirements of the Directive: 
                                                 
36 For engine categories / power classes: see end of this annex 
EN 37   EN – after 30 June 2001 for engines of categories A, B, and C, 
– after 31 December 2001 for engi nes of categories D and E, 
– after 31 December 2002 for engines of category F, 
– after 31 December 2003 for engines of category G, 
– after 31 December 2005 for engines of category H, 
– after 31 December 2006 for engines of categories I, 
– after 31 December 2006 for engines of categories K, 
– after 31 December 2007 for engines of category J, 
– after 31 December 2010 for engines of category L, 
– after 31 December 2011 for engines of categories M 
– after 31 December 2011 for engines of categories N, 
– after 31 December 2012 for engines of category P, 
– after 31 December 2013 for engines of category Q, 
– after 30 September 2014 for engines of category R. 
However, for tractors fitted with category E or F engines, the above da tes shall be postponed 
for six months. 
4. The requirements of paragraph 3 do not apply to  engines intended to be installed in tractor 
types for export to third countri es and the replacement of engi nes for tractors in service. 
5. For engines of categories A to G Member States may postpone th e dates laid down in 
paragraph 3 for two years with respect to engines with a prod uction date prior to the said date. 
They may grant other exceptions under the cond itions laid down in Ar ticle 10 of Directive 
97/68/EC. 
6. For engines of categories H to R, the dates laid down in paragraph 3 shall be postponed for 
two years with respect to engines with a production date prior to the said date. 
7. For engine types or engine families meeting the limit values set out in the table in section 
4.1.2.4, 4.1.2.5 and 4.1.2.6 of Annex I to  Directive 97/68/EC before  the dates la id down in 
paragraph 3 of this Article, Memb er States shall allow special labelling and marking to show 
that the equipment concerned meets the require d limit values before the dates laid down. 
8. In accordance with the procedure referred to in Article 20(2) of Directive 2003/37/EC, the 
Commission shall align the limit values and dates of stages IIIB and IV with the limit values and dates decided following the revision procedur e provided for in Article 2(b) of Directive 
2004/26/EC, with a view to the needs of agricultu ral or forestry tractors and, in particular, 
tractors of categories T2, T4.1 and C2. 
EN 38   EN Power classes for engines (as defined in Directive 97/68/EC)  
NB: narrow-track tractors are in the power range of 37 to 75 kW; classes P, N and R. 
Stage I: ENGINE CATEGORIES: A, B, C — A: 130 kW ≤ P ≤ 560 kW, 
— B: 75 kW ≤ P < 130 kW, 
— C: 37 kW ≤ P < 75 kW, 
STAGE II: ENGINE CATEGORIES: D, E, F, G — D: 18 kW ≤ P < 37 kW, 
— E: 130 kW ≤ P ≤ 560 kW, 
— F: 75 kW ≤ P < 130 kW, 
— G: 37 kW ≤ P < 75 kW, 
Stage IIIA: ENGINE CATEGORIES H, I, J and K — H: 130 kW ≤ P ≤ 560 kW, 
— I: 75 kW ≤ P < 130 kW, 
— J: 37 kW ≤ P < 75 kW, 
— K: 19 kW ≤ P < 37 kW, 
STAGE III B: ENGINE CATEGORIES L, M, N and P — L: 130 kW ≤ P ≤ 560 kW, 
— M: 75 kW ≤ P < 130 kW, 
— N: 56 kW ≤ P < 75 kW, 
— P: 37 kW ≤ P < 56 kW, 
STAGE IV: ENGINE CATEGORIES Q and R — Q: 130 kW ≤ P ≤ 560 kW, 
— R: 56 kW ≤ P < 130 kW. 
EN 39   EN Annex V – Examples of Narrow Track Tractors 
 
 
 
EN 40   EN  
Annex VI - Typical NTT Engi ne and Vehicle Development 
Process 
PROJECT PHASE WHO
Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10
BEST CASE
WORST CASENew Vehicle Start of Production (SoP) T2 Tractor OEMVehicle & Engine Field Test T2 Tractor OEM
New Vehicle Industrialization (Tooling) T2 Tractor OEMFirst Sample Engine to T2 Tractor OEM Engine Manufact.
New T2 Tractor Vehicle Dev. T2 Tractor OEMCustomized Engines for T2 Tractors Dev. Engine Manufact.First Base Engine Functional Samples Engine Manufact.Engine Sub-System Integration Engine Manufact.
Base Engine Durability & Reliability Dev. Engine Manufact.TIME
New Technology Concept Demonstration Research Centers
Engine Sub-System Dev. (FIS,VVT, EAS) Tier 1 Suppliers
 
Source: CEMA 
EN 41   EN Annex VII –Stakeholders' opinions at Working Group for 
Agricultural Tractors meeting 
(Extracts from the minutes of the Worki ng Group for Agricultural Tractors - WGAT) 
1 - Positions of stakeholders regarding a possible exemption from emission 
limits, based on an agenda item  presented by the Commission  
22-6-2009 TA authority, 
Austria TA authority Fully support the consideration to amend the 
current legislation 
22-6-2009 Ministry, France  Welc omes the proposal to amend  
22-6-2009 Ministry, Spain  Welcomes the proposal to amend  
22-6-2009 Ministry, Italy  Strongly supports the proposal to amend 
20-1-2009 CEMA European tractor 
manufacturers Fully support the proposal, although they 
prefer a complete exemption, not just 5 years 
exemption 
22-6-2009 UNACOMA Italian tractor 
manufacturers Fully support the proposal to amend 
01-07-2009 EUROMOT The European 
Association of Internal Combustion 
Engine 
Manufacturers Fully support the amendment to amend 
10-07-2009 SMMT The Society of Motor 
Manufacturers and 
Traders (UK) off Highway Engine & 
Equipment Group  Strongly endorses the proposal to amend  
13-07-2009 AGORIA Belgium Employers 
Organisation Fully support the proposal to amend. 
14-07-2009 AECC Association for 
Emissions Control by 
Catalyst Supports additional measures acting as 
incentives for Stage IIIB engines to be placed 
on the market but not the proposed measure. 
Justifications include impacts on environment, EU competiveness in the global 
market. 
 
2 - Extract from minutes of WGAT 
85th WGAT, 22 June 2009  
EN 42   EN 4. Narrow-track tractors – exemp tion from emission requirements 
The expert for CEMA/EUROMOT stated that in 2004, as soon as Stages IIIB and IV were 
decided in the frame of the amendment to Di rective 97/68/EC, the specialised tractors 
manufacturers addressed their concerns to the Commission in view of the adaptation of the 
tractors directive. In time the proposal to exempt NTT received the support of Vice-President 
Verheugen, was successfully submitted to th e technical inquiry by DG JRC, the impact 
assessment of Arcadis and the legal scrutiny. 
He insisted that ENTR F1 pres ented last November a draft propos al that represents a realistic 
compromise between environmental expectations  and technical reality and pointed to the 
urgency of the matter. He asked whether it shoul d be recorded that the efforts of industry, the 
Commission services and independe nt consultants were not able  to deliver a solution in 5 
years? 
The Italian expert expressed his surprise that after all the discussion the issue is not solved 
yet. Possibly his ministry would not wait for a European solution, as it is a very urgent 
regional problem. He also referred to request s for higher ‘flexibility’ percentages in the 
NRMM Directive. 
The Austrian expert agreed, sta ting that in these special tracto rs not enough space is available 
for the extra emission equipment need ed. The Spanish expert agreed too. 
86th WGAT, 18 December 2009 
5.2. Narrow-track tractors 
The chairman explained that the Commission is we ll aware of the urgency of this issue, and 
that there seems to be a wide support from Member-States and industr y to solve the matter. 
The original approach of a comitology amendm ent had proved to be unacceptable. A second 
ISC procedure for the co-decis ion proposal that has been prepared now had not had a 
promising outcome; the Unit needs to prepare an  IA Report. Some discussion followed on the 
type of additional and detailed information needed for such report. 
The Italian expert was struck by this statement.  He said that many companies will have to 
close down with tragic numbers of lay-offs as a result. The Commission should take the 
economic situation into account.  
A representative from CEMA gave a clear Power Point presentation to show why it’s 
impossible now to adapt NTTs to emissions Stage IIIB and IV, on technical grounds: no space under the bonnet, unacceptable reduction of steerability or ground clearance, etc. 
Another representative for CEMA, representing a specific company, explained that she would 
have to close down her company (400 staff) if there would be no exemption for Stages IIIB 
and IV. Still the users, mainly in the mountains and hills in Southern Eu rope, need these NTT. 
The emission stage IIIA already required huge investments by the manufacturers; 1 in 10 
tractors of the existing EU fleet are IIIA comp liant now, and the presentation highlighted that 
to stop the replacement of old tractors wi th new models will present a damage for both 
environment and the safety (old tractors still don’t have ROPS, safety belts etc). 
EN 43   EN The Austrian expert, supporting the need for an exemption, stated that tractors in agriculture 
use only about 1% of the fuel, so have little impact on the environment.  Stage IIIB would be 
technically ‘impossible’ in a NTT. 
The Greek expert stated that this is a technical issue; if there is no technical solution then we 
need an administrative solution. She supports the proposal. 
The French expert had the same view as the It alian and CEMA colleagues; there is a crisis 
now in this sector (minus 50% in 2 years). 
Experts from Finland, Sweden and the Ne therlands also supported the exemption. 
The representative of EUROMOT stated that six months after his last intervention at a similar 
meeting, the situation had not advanced. He felt that this is unacceptable, but what is even 
more unacceptable is that the existence of the specialised tractors is questioned only on 
bureaucratic grounds. All the evid ence of independent studies for the Commission (ref. JRC, 
ARCADIS) confirms the justification of the exem ption of these tractors from Stages IIIB and 
IV due to the impossibility to meet those requirements. All the requested data are available 
already from those studies (mainly Arcadis) or were supplied later. What makes the situation 
even more surreal is that yet another impact a ssessment study is asked wh ere in reality we are 
trying to correct a mistake in a piece of legislation not based on Sound scientific knowledge 
and economic assessments, reliable and up to- date data and information and the use of 
indicators (Sixth enviro nmental Action Programme) , but is only the result of a ‘cut and paste 
exercise’ from US legislation. Th e co-legislators had left an open door to verification of the 
technical feasibility and soundness of their de cisions, but now bureaucracy is closing this 
door. What seems worrying, from EUROMOT perspec tive, is that there are no signs that the 
system is able to correct its own mistakes in a reasonable time and that it ignores scientific 
evidence and puts at risk jobs in industry and agricultures and the active and productive economy of the Community. 
Meeting with industry on Impact Assessment emissions NTT, 2-9-2010. 
Participants: representatives from CEMA and EUROMOT and DG ENTR 
Purpose: to obtain information for the IA of a propos al to solve problems for the introduction 
of new Stage IIIB and IV requirements for the special tractors of categories T2, C2 and T4.1 
for use in vineyards and orchards, as indi cated in Directive 20 05/13 – article 1.4(d). 
Background: when stages IIIB and IV were disc ussed in 2004 / 2005, industry warned for 
the problems for these NTT; this resulted in article 1.4(d)  of 2005/13, stating in the new 
paragraph 8 that the Commission shall act '… w ith a view to the need s of agricultural or 
forestry tractors and, in particular, tractors of categories T2, T4.1 and C2'. 
These new stages, aiming at reduction of envi ronmental problems in Europe, were adopted 
without IA, fully based on alignment with USA lim its and tests (Tier IV-interim and IV). In 
2008 the study by JRC showed that an exemption was needed; in 2009 ARCADIS studied the IA consequences, first in the overall report on amendments to Directives 97/68 (Machinery) 
and 2000/25 (tractors) and afterwards  in the additional SME Test study. 
Two power bands as defined in 2000/25 are used for NTT: 37-56 and 56-75 kW. Most 
engines are in the higher class, close to 75 kW  (with the new tendency to go to 80 kW, as 
farmers need more power for additional equipm ent). The 56 limit comes from US legislation 
EN 44   EN and is not specific for EU. In general the ove rall dimensions of the NTT are the same, 
regardless of whether the engine used bel ongs in the lower or higher power class.  
IASG : on 22 July a first meeting was held, in whic h questions were raised (SG, ENV). This 
led ENTR to send a list of questions to CE MA (tractors and machin ery manufacturers) and 
EUROMOT (engine manufacturers), which were discussed in the 2/9 meeting. The resulting 
info is presented below; in addition industry pr omised to collect and submit further data in 2 
weeks time. 
Industry stated that for NTT the functionality is es sential, more than costs; if the user is not 
satisfied about functionality (esp. dimensions and fit of additional equipment) he will not buy 
a new tractor. 
Questions and answers 
Q1: are engines for NTT and other tractors the same? 
Answer: yes and no. No engine is specifically desi gned for NTT; base engine is for use in 'all' 
types of tractors, but they must  be adapted for use in NTT (di fferent placing of turbo, EGR, 
cooling, hoses etc). 
Engines for use in tractors have specific requ irements (strength of sump, shape/dimensions, 
passage of transmission axle to front axle 'through' sump), which makes that some IIIB 
approved engines for machines cannot be used here. For this reason some recently presented engines (JCB engine presented in July in th e AECC symposium; Cummins) are not suitable. 
Q2: when can IIIB engines be available for NTT? 
Answer: industry does not see IIIB becoming available until more is finished, maybe a 
prototype in one year. Tractor manufacturers started requesting engine manufacturers in 2006 
to produce IIIB engines in time. Only recently  specially adapted (shaped) filters became 
available for engines below 56 kW, not yet fo r the larger ones. EUROMOT presented in 
WGAT (Dec 2009) a graph showing the example of a timeline for the development of the 
engine and then the tractor, taking 6 -10 y ears (best – worst case) from the moment of 
demonstration of the concept of new technology. 
From the moment that a first functional sample of  a new base engine is available it would take 
3-4 years to adapt them for use in NTT.  
Costs: as this is a limited market, for comp etitiveness reasons industry cannot readily give 
figures. CEMA proposed to use a different a pproach which should allow to come with 
relevant generalised figu res in the near future. 
On the issue of Stage IV , industry stated that there are no
 solutions in sight; at present they do 
not see a date when NTT could meet those re quirements ('totally in the dark'). As a 
consequence there are no cost  figures to be indicated. 
Q3: is it a useful option to skip Stage IIIB and go to Stage IV at the defined deadline? 
Answer: industry stated that with the presen t state of knowledge it is impossible to make a 
Stage IV compliant NTT. Engines are not rea dy; SCR and DPF seem necessary but require 
too much space. On the other hand, for engi nes below 56 kW, no Stage IV is required. 
On the other hand, industry invest ed heavily already in developi ng for Stage IIIB; this money 
would be lost if IIIB would be lost. 
EN 45   EN Q4: Is 50% flexibility  a solution for NTT? 
Answer: this is not the proper solution for this  problem, as it basically allows only for some 
more weeks of leadtime, for products which are not ready by the deadline of the directive. 
EN 46   EN Annex VIII – Relevant part s of the JRC report 2008 
  
Land Based Compression Ignited Engines  
The problem arising from the application of Stage IIIB and Stage IV emission limits for 
special small tractors  was discussed and analysed in larg e detail. In conclusion, the special 
narrow track tractors used in vineyards and or chards should be exempted from the emission 
Stage IIIB and Stage IV.  
5.3 Application of Stage IIIB and Stage IV emission limits to special agricultural 
tractors used in vineyards and orchards  
Under the Council Regulation (EC) No  1493/1999 from 14.07.1999 (OJ L179, Chapter III, 
Articles 11 and 13) on the common  organisation of the market  in wine from 1999, Member 
States can obtain annual payments for rest ructuring and conversion of a set number of 
hectares of vineyards. The objective of this sy stem is the adaptation of production to market 
demand. It covers the following measures:  
– varietal conversion,  
– relocation of vineyards and  
– improvements to vineyard management techniques.  
The system does not cover the normal renewal of  vineyards which have come to the end of 
their natural life.  
As consequence of the restructuring of vineya rds, according to a German wine producer, the 
row width has changed from narrow row width of about 1 meter to larger row widths of 1,6 - 
2,2 meters. One reason was the possibility to swit ch from manual cultivat ion techniques to the 
use of special agricultural tractors and machin ery. As reason for the upper row width limit the 
micro-climatic control was mentioned: larg er row width would dr y out the grounds and 
increase ventilation and cooling between the plan ts. In general it was stated that the new row 
width gives the best results in terms of quantity at the desired high quality level.  
Similar to vineyards also the orchards are set up with row widths of about 2 meters, allowing 
for automation of cultivation of ground, plant/ fruit treatment and harvesting by using special 
agricultural tractors and machinery.  
5.3.1 Classification according to Directive 2003/37/EC  
[See Annex I] 
EN 47   EN 5.3.2 Problems reported by manufacturers a nd user regarding the installation of 
additional after-treatment equipmen t on special purpose tractors  
The report is based on a pres entation prepared by UNACOMA and material provided by 
manufacturers during visits to their production sites. The foll owing list gives a summary of 
the reasons for which the additional (necessary) equipment required to fulfil Stages IIIB and 
IV can currently not be installed in the special small tractors.  
General technical development and construction  
– Introduction of Stage IIIB and St age IV would need introduction of after-treatment systems 
for PM and NOx  
– PM after-treatment is likely to be accomplis hed by a closed particle trap requiring 
sometimes also an additive tank for regeneration  
– Typical volume for such a PM system is 2 - 2.5 times the engine displacement  
– PM traps need high temperatures for regene ration and consequently  a position near the 
engine out valve  
– NOx after-treatment is most probably accomplished by a SCR system requiring a catalyst, 
a urea injection system and a urea tank. The catalyst should be placed near the engine out valves  
– Typical volume for such a de-NOx system  is 2 times the engine displacement  
– De-NOx system requires operation temperat ures above 280 C and consequently a place 
near the engine out valves (a s does already the PM system)  
– Engine temperatures during tract or operation are high. This cr eates already now difficulties 
because of the lack of space for additional cooling systems  
– Under specific working conditions tractor is operated at low load with high oil 
consumption and high ash formation and low temperature which is difficult for running a 
PM filter  
– When operated at high load the problems will ar ise from the increase in counter pressure 
due to construction limits; all connections between e ngine and exhaust after-treatment need 
to be bended and their cross section must be reduced.  
Special purpose tractors and their specific problems  
– The total number of T2 tractor sales in Eu rope is about 16.000 units, and the T2 engine 
power goes up to 75 kW. The T2 tractors are pa rt of the about 85.000 tr actors sold in year 
2005 in the 19-75 kW power range (see NRMM inventory).  
– Special machinery to be operated with the T2 -tractors can’t be used any longer when the 
general shape of the tractors  needs to be modified  
– Average life of T2 tractor in profes sional environment is about 8-10 years  
EN 48   EN – Price of T2 tractors is much higher than  for an equivalent “normal” tractor  
– T2-tractors are sometimes used for commun ity work, cleaning roads from snow, cutting 
trees or similar work. A T2-tractor would not be suitable to replace a “normal” tractor due 
to its higher price and its uncomfortable design with narrow driver cabin and high centre of gravity. The latter one results in frequent overturn of the tr actors in steep vineyards.  
– T2 tractors need to turn in a very limite d area. To reduce the ra dius for turning, some 
models have shaped the tractors body to avoi d that the tyres touch the tractor body. Others, 
the articulated tractors, have introduced add itional front parts to be  turned. The latter 
models are special flat tractors in which th e driver is lying rather than sitting  
– The engine is packed in the T2  tractor, and has elements that  with a special shape to fit 
under the bonnet, which is giving the physical boundary for construction. The fuel tank is 
often made up of several smaller can isters put in different places.  
Boundary conditions for field operatio n of a special purpose tractor  
– T2 tractors are built for special purpose, they n eed to operate at high efficiency in narrow 
vineyards and orchards.  
– They should have a maximum engine height of about 1.2 meters, a width of down to 1 
meter and cabins/outside pieces that can be bended for not touching fruits during operation 
in field. Hot and sharp surfaces are not allowed outside the tractors, otherwise the grapes or 
fruits will be damaged.  
– The T2-tractors are highly specialized tractors  which can be operated simultaneously with 
different cultivation machines to reduce numbe r of treatment steps (and consequently as 
by-product also the emissions per treatment).  
– Limiting factors for construction and engineering freedom are the space between rows, the 
height of fruits above the tractors body and th e space at the end of rows for turning into the 
“next” row.  
European market and wine production  
– T2 tractors are a special European product, wine  producers in US have no need because the 
available field space there is much bigger al lowing for different cultivation methods.  
– European space for vineyards is limited and expensive. It needs to bring high quality 
products instead of mass production. 
– European space for vineyards is in almost all cases difficult terrain, either in mountains or 
on hills, where normal tractors can’t operate. 
– Vineyard row width has been changed some 10-15 years ago, funded by European 
commission, in order to increase compe titiveness of European wine producers (see 
introduction).  
– The change from manual to machinery treatmen t and fruit/grapes colle ction is based on the 
enlarged row width, increasing from about 1m to about 2m width. 
EN 49   EN – Turning with the tractor into each 2nd 
row is possible today without loosing too much space 
at both ends of the vineyard for turning the tractor. This would not be any longer possible 
when tractors become longer.  
– Cultivation cycles are about 20-30 years: ch anging row width would not be immediately 
possible without financial losses. Cutting plan ts away at both field ends to allow for 
turning with longer tractors w ould reduce the field or vineyard  yield substantially because 
European fields are already now short in length. Cutting away a dditional plants would 
result in an estimated 20% loss of cultivable grounds.  
5.3.3 Environmental impact of the exemption  
Further to the estimates on the environmental imp act of an exemption of special narrow track 
tractors (categories T2, C2, T4.1)  from the emission limits set in Stage IIIB and Stage IV, a 
more detailed emissions inventory was made. Th e assumptions used for the calculations and 
the final results are reported herein after.  
(i) Basic elements and assumptions  
Engine survival rate  
The engine survival rate follows a normal distribution (mean = average life; σ = 0.25)  
Numbers for average life of 8, 10, 12, 16 years are given in the table belo w and are illustrated 
in the graph.  
Annual operating hours  
The annual operation hours’ curves follow a suggestion from Euromo t, CECE, CEMA, but 
includes a linear decrease until the end of engi ne life, instead of a constant 50% rate.  
EN 50   EN 
 
EN 51   EN 
 

EN 52   EN 
 
EN 53   EN 
 
First year operation hours  
The first year operating hours within the differe nt power categories relevant to specialised 
tractors are given in the table below, together  with the average total operation hours over the 
full life of an engine. The selected conditions  for the special tractors and normal tractors 
inventory are:  
– power band 19-37 kW: 8 years average life; 400 hours operation in 1st 
year for normal 
tractors; 250 hours operation in 1st 
year for special tractors  
– power band 37-56 kW: 12 years aver age life; 500 hours operation in 1st 
year for normal 
tractors; 300 hours operation in 1st 
year for special tractors  
– power band 56-75 kW: 16 years average life; 700 hours operation in 1st 
year for special 
tractors; 350 hours operation in 1st 
year for special tractors  
Emissions from large (normal) tractors in the power band above 75 kW were also calculated 
for having a complete picture of all agricultura l tractors’ emissions. Th e selected conditions 
for the large tractors inventory are:  
– power band 75-135 kW: 16 years averag e life; 700 hours operation in 1st 
year  
– power band 135-560 kW: 16 years averag e life; 750 hours operation in 1st 
year  

EN 54   EN 
 
It can be questioned if the 12 and 16 years aver age life selected for normal tractors is also 
appropriate for the narrow track tractors. In the in ventory it would have an impact on the fleet 
renewal, thus a reduced life of narrow track  tractors would reduce the impact time when 
calculating a delay in th e introduction date of an emission li mit stage. But there would be no 
effect on the emission level of  the stabilised projection.  
Annual sales  
Annual sales numbers for all tractors in the different power categories were taken from 
information given by Euromot/CECE/CEMA. The sp ecial tractors’ sales numbers (named T2 
sales in the table) were presented to JRC by the manufacturers during a visit to their production sites. Although these numbers we re confirmed by industry in private 
communications, and not questioned when presen ted during GEME meetings, there remains a 
high level of uncertainty because one source q uoted a total of 14.000 special tractors sold in 
2004. Furthermore the total sales of  special tractors with abou t 30.000 units per ye ar are quite 
large. This has to be compared with the total sales of all tractors in the power range 19-75 kW, summing up to about 85.000 units, and with the overall tractor sales of about 150.000 
units over the full power range. The share of sp ecialised tractors in these two cases becomes 
35% and 20% respectively.  
However, the sales numbers used for this invent ory, and shown in the table below, refer to the 
base year 2005. They are estimates for the sa les in the EU15. For th e projection a stable 
market was assumed (no increase/decrease in sales over the years).  
 

EN 55   EN Emission limits and introduction date  
PM and NOx emissions from tractors were examin ed, being today the most  relevant ones for 
diesel fuelled engines. Emission factors for th e inventory were derived from the relevant 
emission limits as given in the NRMM Directives.  
These values were multiplied with a “correct ion factor” of 0.7 for PM and 0.8 for NOx, to 
account for that the expected average emi ssions are lower than the limit values.  
The real world operation and actual in-use engi ne power has been taken in consideration by 
another multiplicative “load factor” which has been set to 0.5 for all engines.  
Emission limits and introduction dates shown in  the table 5.10 below are those given in 
Directive 2000/25/EC an d Directive 2005/13/EC.  
Table 5.10: PM and NOx emission limits for en gines used in agricultural tractors and  
their introduction dates for the relevant engine power classes (all new engines).  
 
Emission factors for old engines (“unregulated”) were estimated from different values found 
in the literature. The overall impact of these en gines is small in the period of interest where 
the exemptions for small specialised tractors might become effective.  
(ii) Scenarios  
Calculations were made for emissions from all tractors and separately for special tractors in 
the different power bands between 19 kW a nd 560 kW. Annual emissions, always given in 
kilo tonnes, are calculated until year 2050.  
A first scenario estimates the annual emissi on pattern for all tracto rs under the assumption 
that all follow the current legislation, i.e. no exemption for special tractors.  
For PM emissions additional ca lculations were made under the assumption that special 
tractors are exempted from St age IIIB, and under the assumption that the introduction date is 
postponed by 5 years.  

EN 56   EN For NOx emissions additional calculations were made under the assumption that special 
tractors are exempted from Stage IIIB only, exempted from Stage IIIB and Stage IV, and 
under the assumption that the intr oduction date for Stage IIIB and Stage IV is postponed by 5 
years.  
(iii) Results  
The tables and graphs below are summarising the results obtained for the different scenarios. 
The short discussion below is made separate ly for PM emissions and NOx emissions . 
PM emissions:  
Following the current legislation, all tractors in the full power range 19-560 kW would reach 
by the year 2050 a total annual emission of 1.1 kt . Taking only the power range 19-75 kW, in 
which the special tractors are included, the tota l annual emissions reach 0.3 kt in year 2050.  
Exempting special tractors from Stage IIIB, th e annual emissions of al l tractors in the full 
power range 19-560 kW would reach about 1.8 kt in year 2050, from which a total of about 1 
kt can be attributed to tractor s in the power range 19-75 kW, in which the special tractors are 
included.  
In other words: the exemption of small tr actors would increase on the long term the PM 
emission by about 0.7 kt per year.  
Postponing the introduction would result in year 2050 in the sa me total annual emission as 
calculated for the “current legislation”. The de lay would result over a period of about 34 years 
a total additional emission of 3.5 kt in addition to the estimated 38 kt PM emissions of all 
tractors in the pow er range 19-75 kW over the same period. This equals an ove rall increase by 
9%.  
 
Figure 5.3: Annual PM emissions as calculated for the different scenarios until the year 2050.  

EN 57   EN Note: the graph shows the annual PM emission patte rn for all tractors in the power band 19-
560 kW, but the differences for different scenar ios only for the tractor power band in which 
narrow track tractors are found (19-75 kW).  
NOx emissions:  
Following the current legislation, all tractors in the full power range 19-560 kW would reach 
by the year 2050 a total annual em ission of 29 kt. Taking only th e power range 19-75 kW, in 
which the special tractors are included, the total annual emissions reach 15 kt in year 2050.  
Exempting special tractors from Stage IIIB a nd Stage IV, the annual em issions of all tractors 
in the full power range 19-560 kW would reach about 35 kt in year 2050, from which a total of about 21 kt can be attributed to tractors in  the power range 19-75 kW, in which the special 
tractors are included.  
In other words: the exemption of small tractors from Stage IIIB and Stage IV would increase 
on the long term the NOx emissions by about 6 kt per year.  
Exempting special tractors from Stage IV only, the annual emissions  of all tractors in the full 
power range 19-560 kW would reach about 33 kt in  year 2050, from which a total of about 19 
kt can be attributed to tractor s in the power range 19-75 kW, in which the special tractors are 
included.  
In other words: the exemption of small tracto rs from Stage IV only would increase on the 
long term the NOx emissions by about 4 kt per year.  
Postponing the introduction of both St ages IIIB and IV would resu lt in year 2050 in the same 
total annual emission as calculated for the “curr ent legislation”. The delay would result over a 
period of 36 years a total additional emission of 33 kt in addition to the estimated 965 kt NOx 
emissions of all tractors in the power range 19-75 kW over the same period. This equals an 
overall increase by about 3.5%.  
 

EN 58   EN Figure 5.4: Annual NOx emissions as calculated for th e different scenarios until the year 
2050.  
Note: the graph shows the annual NOx emission patt ern for all tractors in the power band 19-
560 kW, but the differences for different scenar ios only for the tractor power band in which 
narrow track tractors are found (19-75 kW).  
5.3.4 Summary  
No sufficient free space is availa ble in the current structures of  T2 tractors for installation of 
secondary after-treatment devi ces. To install such emission reduction technologies, the shape 
of T2 tractors would need to be changed: they should be made either longer or wider. Making 
them higher is probably no option because of the already today’s high instability of the 
tractors resulting from th e high centre of gravity.  
As consequence of the re-shaped design the us er requirements will no longer be fulfilled: the 
tractors would touch and destroy fruits and grapes with a wider shape, or would need to be 
turned in time consuming and ground co mpacting manoeuvres. The existing special 
machinery could not be used any longer and would need to be replaced  
To overcome these problems the vi neyards and orchards need to be  restructured to fit to the 
new shaped tractors. This would be an a dditional financial burden, mainly for small 
producers, especially caused by the reduced productivity of a field with larger row width 
and/or shorter row length.  
On the other side the user claim that they woul d utilise the current trac tor models longer than 
the normal 8-10 years to avoid the additional co sts of buying a new tractor not serving their 
need, the new machinery to be operated wi th the new models an d the necessary field 
restructuring. The new models would not find cu stomers on the market, and some T2 tractor 
manufacturers stated that they  would then give up this low profit market segment.  
Possible actions to be taken  
Option 0: No action  
Option 1: Exempt special purpose tractors for a limited time from the emission Stages IIIB 
and Stage IV.  
EN 59   EN Annex IX – Relevant sections of the ARCADIS report 2009 
IMPACT ASSESSMENT STUDY – Reviewing Directive 97/68/ECEmissions from non-
road mobile machinery 
Specific Contract n° SI2.AC PROCE018014400; ENTR/04/093 Lot 5 
FINAL REPORT for EC DG Enterpri se and Industry - 30 January 2009 
3.6 LAND BASED COMPRESSION ENGI NES: SPECIAL AGRICULTURAL 
TRACTORS USED IN VI NEYARDS AND ORCHARDS 
3.6.1 Background 
The current structures of special agricultural trac tors used in vineyards and orchards (T2, T4.1 
and C2 tractors) have no sufficient free space fo r the installation of secondary after-treatment 
devices. To install such emissi on reduction technologies, the shape of these tractors needs to 
be changed: they should be made either l onger or wider, which could result in higher 
instability of the tractors.  
The eventual reshaped tractors will no longer fu lfil the user requirement s. They will touch and 
destroy fruits and grapes unless users restructure their vineyards at relatively high costs. Even 
if stage IIIB and stage IV compliant tractors become available, users could use the actual 
models longer to avoid this field restructuri ng and the additional cost s of buying a new tractor 
not serving their needs. (JRC, 2007 and stakeholders input)  
T2: narrow wheeled tractors 
T4.1 high clearance tractors C2: narrow tracked tractors  
Emissions of special purpose tractors are r oughly estimated at 8.5 % of all CI NRMM for 
NOx and 4.8 % of all CI NRMM for PM. (JRC,  2007 and own calculations) With a reduction 
of emissions of other CI engines, the rela tive emissions of these engines will grow in 
importance. 
3.6.2 Options to investigate 
– option 0: do nothing or keep stage IIIB and stage IV for special purpose tractors 
Risks are that new tractors are not bought in the short term and that producers pull out of the 
market 
– option 1: exempt special purpose tracto rs form stage IIIB and stage IV 
This option will cause some extra emissions. It will make life of users easier. An exemption 
of 5 years seems to be reasonable from a technical point of view (Mr Krasenbrink) 
Remark:  – for the smallest segment 19-37 kW ther e is no stage IIIB and thus no problem 
EN 60   EN – for the 37-57 kW there is a stage IIIB but not a stage IV 
– for the 57-75 kW there is a stage IIIB and a stage IV foreseen  
Emission standards 
Table 1 Relevant emission standards for special purpose tractors 
emission standards g/kwh
start date start date start date
Nox PM Nox PM Nox PM
stage IIIA 7.5 (HC incl) 0.6 31/12/2006 4.7 (HC incl) 0.4 31/12/2007 4.7 (HC incl) 0.4 31/12/2007
stage IIIB 4.7 (HC incl) 0.025 31/12/2012 3.3 0.025 31/12/2011reduction compared to IIIA 94% 27% 94%
stage IV 0.4 0.025 30/09/2014
reduction compared to IIIB 88% 0%19-37 kw
no stage IV emission standard no stage IV emission standard37-56 kw
no stage IIIB emission standardstandard standard standard56-75 kw
 
3.6.3 Sector description 
Special agricultural tractors are a purely Eur opean product –in the US, available field space is 
much bigger (JRC, 2007). According to the JRC, about 28 000 tractors ar e sold in the EU 1537 
– this corresponds 5.8% of all sold NRMM CI engines. 
CEMA estimates that 25 600 units are sold per year in the EU, and 2 500 outside the EU. The 
price is € 30 000 with a minimum of € 17 000 and a maximum of € 58 000, corresponding to 
an estimated turnover of € 843 million.  
The 4 largest companies in the EU hold a market  share of 55% - the remainder of the market 
is in hands of SMEs. All pr oducers are based in Italy or Germany, and the SME”s are all 
Italian. These producers employ 1 800 people directly, and 1 200 pe ople indirectly.  
3.6.4 Main impacts of the options 
3.6.4.1 Compliance costs Building small vineyard and orchard tractors se ems to be unfeasible for the industry. Those 
small tractors have to operate at high effici ency in narrow vineyards and orchards. Maximum 
weight and width, end of row turn, are strictly  limited due to these elements. The width is a 
decisive factor in the decision to buy a specialized tractor.  
Fitting after-treatment on the small tractors without modifying their specific characteristics is 
with current technol ogies unfeasible.  
A diesel particulate filter could be added at th e side of the tractor, under the tractor or on top 
of the engine. All solutions modify one or more of the specific small tractor characteristics to 
wit and cause therefore ot her potential problems: 
• Impossibility to overcome real life ramp angles 
• Insufficient visibility 
• Impossibility to use mid mounted implements 
• Impossibility to steer 
                                                
 
37 Personal communication from Mr Krasenbrink, updating the estimate in the JRC report, p. 89.  
EN 61   EN • Impossibility to perform operations with side mounted implements 
• Impossibility to perform operations with front loaders….. 
3.6.4.2 Socio economic impacts 
For an evaluation of the socio-economic impact s, we will assume that option 0 is indeed 
technologically not feasible.  
In this case, the following solutions  would be open for the end users: 
• Redesign existing vineyards and orch ards to fit compliant tractors 
• Maintain old tractors until a technical solution has been found for new tractors 
The first solution has been clearly exclud ed by the vineyard sector. The European 
Confederation of Independent Wi negrowers (CEVI) has not been ab le to quantify its financial 
implications, but has pointed out that a grubb ed-up and replanted vineyard does not give 
grapes before three years. The average life cycl e of a vineyard is forty years. However, as 
explained in section 0, the JRC has estimated that  5 additional years would be sufficient to 
develop of solution for special tractors! 
Moreover, according to the CEVI, the planting de nsity is determined by the specifications of 
the designation of origin. An enlargement of ro ws would then run coun ter to EC support for 
replanting with a higher density. In some slope or terrace zones, CEVI also claims that it 
would not be possible to widen the rows.  
The JRC report has also pointed out that 20% of  cultivable land will be lost when vineyards 
are adapted to new tractors while European space for vineyard is limited and expensive. 
Therefore, we think we can safely assume  that the first solution is excluded.  
Therefore, the more realistic assumption is th at end users will simply not buy new tractors, 
but maintain their old ones until a new tec hnical solution is found. In this case, the 
environmental benefits of the Directive would be lost.  
As the smaller producers of special tractors  are niche players, discontinuation of the 
production of this type of tractors would put them  out of business. Employment at the larger 
manufacturers would be reduced proportionally, at leas t until a solution ha s been developed. 
Due to a lack of more specific information, we  can only conclude that this would correspond 
to a maximum of 3,000 job losses for a period of up to 5 years.  
3.6.4.3 Environmental impacts  
Emission results 
The graphs below show the main environmenta l impacts of the options  under investigation: 
Figure 3 for PM and Figure 4 for NOx. 
The graph for the compliant solution (option 0) is rather hypothetical, as it is unfeasible to 
comply with stage IIIB and st age IV. Two sub options are poss ible in the case 0 option: 
EN 62   EN • Option 0A: No new machinery is available and vineyards have to close down (not 
shown on graph)  
• Option 0B: No new machinery is available and older tractors continue to work. 
Machinery is repaired instead of replaced.  
In the hypothetical situation that all engines are able to meet th e emission limits at the date as 
originally planned (option 0), the decrease in em issions is larger than if special tractors are 
exempted from Stage IIIB emission limits for 5 years (option 1). 
However, if Stage IIIB emission limits are impos ed and no new machinery is able to meet the 
limits, causing old machines to remain in servi ce (option 0B), emissions are higher than for 
option 1. 
These general conclusions are similar for PM emissions and NOx emissions. However, there 
is one notable difference between PM and NOx : the difference between option 0 and option 1 
is larger for PM than for NOx.  
As a result, option 1 emissions are closer to  option 0B emissions for PM than for NOx. 
As it is assumed that Stage IIIB  (and Stage IV in the case of  56-75kW engines) emissions can 
eventually be met, emissions of all options converge after the complete stock has been 
renewed around the year 2030. Eventual yearly emissions are estimated at 0.171 kt for PM 
and 4.41 kt for NOx. 
Special tractors
00.20.40.60.811.21.4
2005 2010 2015 2020 2025 2030 2035 2040 2045 2050
yearPM emissions [kt]OPTION0
OPTION0B
OPTION1
 
Figure 3 PM emissions of Special agric ulture tractors (tim e series 2005-2050) 
EN 63   EN . 
Special tractors
02468101214161820
2005 2010 2015 2020 2025 2030 2035 2040 2045 2050
yearNOx emissions [kt]OPTION0
OPTION0B
OPTION1
 
Figure 4 NOx emissions of Special agricul ture tractors (time series 2005-2050) 
Methodology emission calculation 
In the annex a small emission model for CI engines is described.  This model is also used to assess the impact on emissions for the different options for special 
agricultural tractors. 
From the 7x7 matrix in the emission model, th e cells for the category “agricultural tractors” 
for engine power classes 19-37 kW, 37-57 kW a nd 57-75 kW are used in this calculation. 
The input for the emission model is adapted fo r special agricultural tr actors, based on info 
from the JRC report and base d on input from CECE/CEMA. 
• Annual sales 
Annual sales are estimated at 26 000 per year for EU15. These sales are assumed to remain 
constant (stable market conditions).  
Special agricultural tractors have a power range between 19 and 75 kW. 
Due to lack of better data, the shares of th e three power classes be tween 19 and 75 kW are 
assumed to be equal, see Table 2. 
EN 64   EN Table 2 Estimated annual sales spec ial agricultural tractors (EU15) 
19-37 kW 37-56 kW 56-75 kW
Share 33% 33% 33%Agricultural Tractors 8666 8666 8666
 
• Useful machine life 
In the JRC report, useful machine life was report ed to be between 8 to 10 years. Therefore, 
the average useful machine life is assumed to be 9 years. 
• Emission factors 
The only difference between the different options, is the set of emission factors that is used 
for each option. The options under investig ation are described in section 0. 
There are three engine size classes for special  agricultural tractors. The option 0 emission 
factors for 19-37 kW are indicated in Error! Reference source not found. , those for 37-56 
kW engines are indicated in Ta ble 4, and Table 5 contains th e emission factors for 56-75 kW 
engines. The pre-Stage I emi ssion factors are based on (Van Zeebroeck, 2005). The Stage I, 
Stage II and Stage IIIA emission factors are calculated as the emission limit multiplied by a 
reduction factor, as an estimate for typical em issions. The reduction factors are based on those 
provided by Euromot/CECE/CEMA, see Table 6. 
To calculate emissions for option 1, Stage IIIB  emission factors are delayed 5 years. For 56-
75 kW engines, the Stage IV emission factors are also delayed 5 years.  
Table 3 Emission factors for 19- 37kW CI engines (option 0) 
From To NOx PM Comments
0 1980 16.20 1.60 Based on [Van Zeebroeck, 2005]
1981 1990 16.20 1.50 Based on [Van Zeebroeck, 2005]
1991 2000 9.80 1.26 Based on [Van Zeebroeck, 2005]
2001 2006 5.76 0.45 Stage II * red_factor_typical_em issions; PM adapted for alignment with JRC
2007 2050 4.55 0.34 Stage IIIA * red_factor_typical_emissions  
Table 4 Emission factors for 37- 56kW CI engines (option 0) 
From To NOx PM Comments
0 1980 11.500 1.800 Based on [Van Zeebroeck, 2005]
1981 1990 8.600 1.200 Based on [Van Zeebroeck, 2005]
1991 1998 7.700 0.720 Based on [Van Zeebroeck, 2005]
1999 2003 7.360 0.476 Stage I * red_factor_typical_emissions
2004 2007 5.600 0.224 Stage II * red_factor_typical_emissions2008 2012 3.171 0.224 Stage IIIA  * red_factor_typical_emissions
2013 2050 3.171 0.025 mininimum of (Stage IIIB, ef_factor previous years)
          
EN 65   EN Table 5 Emission factors for 56-75 kW CI engines (option 0) 
From To NOx PM Comments
0 1980 11.500 1.800 Based on [Van Zeebroeck, 2005]
1981 1990 9.460 1.200 Based on [Van Zeebroeck, 2005]1991 1998 8.470 0.800 Based on [Van Zeebroeck, 2005]
1999 2003 8.096 0.536 Stage I * red_factor_typical_emissions
2004 2007 6.160 0.252 Stage II * red_factor_typical_emissions2008 2011 3.480 0.252 Stage IIIA  * red_factor_typical_emissions
2012 2013 3.300 0.025 mininimum of (Stage IIIB, ef_factor previous years)
2014 2050 0.400 0.025 mininimum of (Stage IV, ef_factor previous years)
 
Table 6 Reduction factors for typical emission s for pre-Stage IIIB em ission limits for 19 
to 75 kW CI engines 
red_factor_typical_emissions
NOx PM Comments
original 0.8 0.7 Source: CECE-CEMA-EUROMOT, 2006
19-37kW 0.72 0.56 adapted to align with JRC calculation
37-56kW 0.8 0.56 adapted to align with JRC calculation
56-75kW 0.88 0.63 adapted to align with JRC calculation 
Monetized estimate of environmental impacts of options for small tractors 
Based on the above calculated emissions in tons  and the external costs for NOx and PM we 
calculate the monetized values of the differenc es in emissions between the reference option 
and option 1-exemption and opti on 0b-old tractors remaining. We considered the 2012-2030 
period and discounted monetized em issions to 2008 at a discount rate of 4%. The table below 
illustrates the results.  
Table 7 Monetized emission impacts for opti on 1 and option 0b for small tractors 
(million EUR) 
 
The figures in the table show ne gative values as these are real  environmental costs. Each of 
the options increase the emission compared to the theoretical (unrealistic) reference option. 
Exempting special tractors for 5 years costs € 120 million more in emissions than having small tractors complying from the foreseen date s. Keeping the emission standard as foreseen, 
but not having compliant tractors ready will howev er cost € 193 million due to the old tractors 
that are kept in service. 

EN 66   EN 3.6.4.4 Multi criteria analysis 
There are no technical compliance costs as co mpliance is technically unfeasible. We analyse 
therefore not the efficiency of the options. We  give however for the different options an 
overview of the different options. 
Other elements 
Category Option 0 Option 1 
Functioning of 
the internal market No specific issues identified No specific issues identified 
Competitiveness, 
trade and investment flows Could lead to decreased competitiveness 
of European orchards or vineyards 
compared to foreign competitors 
As T2 tractors are a specific European 
product (see JRC report, p 90), trade is not 
an issue for this equipment type Would solve issues of competitiveness 
Operating costs 
and costs of business Would lead to increased operation 
costs for orchards and vineyards due to longer maintenance of special tractors  Would solve issues of cost 
increases 
Administrative burden to companies/SME’s Most vineyards and orchards are 
SMEs producing special tractors would disappear from the market Would solve issues 
Property rights No changes expected No changes expected 
Innovation and 
technological development Could lead to more R&D for 
compliance at the expense of customer-oriented R&D; no information provided by industry Could lead to more R&D for compliance 
at the expense of customer-oriented R&D but less so than under option 0; no information provided by industry 
Consumer and 
households Will lead to increased wine price, but no 
information available that would allow to quantify this impact Would solve issues 
Specific regions, 
sectors or workers Will have negative impact in rural 
areas and in the sector involved in the production of special tractors Would solve issues 
EN 67   EN Third countries 
and international relations No specific issues identified No specific issues identified 
Impact on public 
authorities, including administrative costs No specific issues identified No specific issues identified 
Impact on 
macroeconomic 
environment With EU27 GDP estimated at 
12,870,560 million EUR 
(EUROSTAT), estimated compliance costs and employment effects do not have a significant macroeconomic impact Would solve issues 
Employment and 
labour markets Localised and temporary job losses 
of a few thousand units Would solve issues 
Standards and 
rights related to job quality No specific issues identified No specific issues identified 
Social inclusion 
and protection of particular groups No specific issues identified No specific issues identified 
Public health and 
safety Loss of 193 million EUR compared 
to theoretical option 0 loss of 121 million EUR compared 
to theoretical option 0 
 
EN 68   EN Annex X – Relevant sections of  the ARCADIS SME Test report 
2010 
"SME Test Study and IA on possible opti ons for reviewing the Directive 97/68/EC 
relating to NRMM – Reviewing Directive 97/ 68/ECEmissions from non-road mobile 
machinery" 
EXTENDED EXECUTIVE SUMMARY 
The aim of this study was to complement th e existing Impact Assessment study related to 
Directive 97/68/EC (as amended) with a deta iled assessment of the impacts the identified 
policy options may have on SMEs. 
We have focused our research on the following categories of stakeholders: 
– the manufacturers of engines, equipment and components 
– professional end users of the equipment. 
Based upon the results of the IA study, there wa s no indication that other SMEs are affected 
significantly by this Dir ective. Therefore, in our proposal, we had proposed that the focus of 
the study would be on these categories. The most  striking conclusion of this study is that, 
despite the very important efforts undertaken  by the project team, less than 10 individual 
tractor manufacturers (abstracting from the shi pbuilders) have been id entified unequivocally 
as SMEs and have contributed actively to the study. 
The number of SMEs identified amongst professi onal end users was much higher, but really 
new information was only provided by the fo llowing sectors: independent winegrowers, 
cableway and ski lift operators, and by the inland waterways sectors. 
There are several possible explanations to the large difference with previous estimates of the 
number of SMEs: 
– The discrepancy between the Commission’s de finition of SMEs and the public perception 
of what an SME is. 
– SMEs feel that their specific interests ar e not always well represented by the sector 
federations. Therefore, we have also used al ternative communication channels but this has 
resulted in very limited response rates as well. 
– For SMEs, the burden of re sponding actively to the ques tionnaire is often too high 
compared to the (perceived) benefits of doing so. This is certainly the case for professional 
end users. 
However, if a less restrictive definition of SMEs  would be used in future work, this would 
ignore two essential problems of SMEs that ar e solved with mergers and acquisitions (high 
fixed costs and difficult access to capital). Moreove r, a change of the scope of the definition 
could lead to confusion on the side of the industry. 
EN 69   EN Allowing longer response times c ould lead to a sligh tly higher response rate, but, in this 
study, the extension of the contract has not had a significant impact on the actual response rate. Drafting a questionnaire in several languages (or allowing SMEs to answer in their mother tongue), would have huge implications in terms of translati on budget and in execution 
time. Finally, there are limits to how far we can go in simplifying the questionnaires without 
missing the whole point of the study. 
The most important policy conclusions are: … – Virtually all tractor manufacturers that have been interviewed in th e course of the study 
have expressed concerns with respect to th e rapid succession of emission stages (rather 
than the absolute values of the imposed emission limits). This affects their business negatively through the following ch annels: (a) shorter production runs to cover fixed costs 
(b) the costs linked to teethi ng problems of new equipment. 
– The most important concern raised by producers of agricultural machinery was not the next 
stage in the Directive, but the homologation pro cess, and more specifically: the length of 
this process, the lack of international standa rdisation and the fact th at even minor changes 
require rerunning a complete homologation process. 
– Regarding the impact of the Directive on trac tors used in orchards, no information has 
been obtained from the relevant professiona l organisation of end users. Regarding the 
impact on tractors used in vineyards, the Eur opean sector federation has confirmed that all 
independent winegrowers are SMEs, and the va st majority are micro-enterprises. Our 
calculations indicate that: 
– the cost for redesigning vineyards to accommodate stage IIIB and IV compliant 
tractors would be several orders of magn itude larger than the environmental cost 
of not exempting the special tractors  from stage IIIB and IV; 
– the increased maintenance cost following fr om keeping old tractors in use would 
be an order of magnitude larger than the environmental cost of not exempting the 
special tractors from stage IIIB and IV. 
This study has considered the two following generic mitigating measures: …. – An extension of the duration of the flexib ility scheme would allow small equipment 
manufacturers to overcome the long time lag between the development of a new engine 
and the full integration of this new engine in the equipment (including homologation for 
use on the road); 
Most tractor manufacturers that we have interv iewed are aware of the flexibility scheme, but 
not all seem keen on using it. One manufacturer ha s raised the specific concern that the engine 
options for reviewing the Directive 97/68/EC re lating to NRMM suppliers may not always be 
able to supply engines complying with the previous stage of the Directive. 
… 
EN 70   EN 3.4 Consultation with the identified target group 
The questionnaires have been sent out afte r the inception meeting with the Commission 
services. However, as our expe rience with the IA study had show n that few stakeholders have 
the resources to provide comprehensive answers to  this type of questionnaire, the project team 
has proposed to concentrate on two groups of selected stakeholders: 
– First, we have contacted the European indus try associations that have been consulted 
during the IA study: AECC, CCNR, CECE, CEMA, CER, EBU, EGMF, ESO, ISMA, 
ORGALIME, UITP, UNIFE, VDMA and EUROMOT. 
– Second, we had proposed to single out a represen tative group of SMEs that is willing and 
able to cooperate on this study. The selection of this group would take place in consultation 
with the European industry a ssociations and with UEAPME. 
We aimed at 2 SMEs per main NRMM sector used in the IA study. Our intention was to organise round table disc ussions with those selected stakeholders. 
Experience with the IA study had shown that th is is the most effective means to elicit a 
maximum of information. We proposed to orga nise six half-day r ound table discussions, 
focussing on the most relevant sectors. Relevant  sector are those where many SMEs are active 
as a manufacturer or as a profe ssional user of the equipment. 
We also proposed to approach the SMEs via in-depth telephone interviews and mail 
exchange, as it is difficult to organise meet ings with them in Brussels. A round table 
discussion has been asked with UEAPME. 
3.5 General development of the consultation process 
Table 1 gives an overview of all the contacts  that have been made with stakeholders. 
Although the questionnaires have been sent out immediately after the signa ture of the 
contract, and although there ha s been a steady follow up, the ge neral response rate has been 
very low. We will discuss the specific reasons chap ter per chapter, but the main reason is that, 
for most sectors covered by the NRMM Directive,  there are very few (if any) SMEs. One of 
the reasons why the relative importance of  the number of SMEs might have been 
overestimated in the past is that the criterion of autonomy in the definition is often 
overlooked: companies that fulfil all other criter ia (headcount and turnover or balance sheet 
total) can still not be considered SMEs if they are part of a larger group that does not meet the 
criteria. Moreover, the sector  of internal combustion engi nes has recently gone through a 
consolidation phase, and the fu ll extent of the reorganisati on of the sector is now only 
becoming clear. 
Effects on SMEs are therefore generally limited to the professional end users, who are much 
less familiar with the NRMM Directive. 
Upstream in the product chain, the manufacturers of exhaust em issions control equipment are 
an important actor. The sector federation AECC does not count any SMEs amongst its 
members, but has referred us to  some individual companies th at are not members of AECC. 
Amongst these, one SME has been identified, which has been contacted individually. However, this contact has not led to the identific ation of information that could be useful for 
EN 71   EN the purposes of the current study. CLEPA, the European Association of Automotive 
Suppliers, has informed us that this subject was of no interest to them. 
Therefore, our invitation to organise round table meetings has met a very low positive 
response rates. We have been able to hold seve ral telephone interviews who turned out to be 
very informative, but also less than we had hoped for.  
As explained above, in parallel with the sector organisations, in order to reach SMEs that are 
not affiliated to sectoral associations, we had taken several steps in parallel: 
– We have contacted UEAPME, the European Association of Craft, Small and Medium-
sized Enterprises. UEAPME has sent out the questionnaires, but has pointed out that it 
does not work directly with SMEs, but with  its members, which are national horizontal 
SME organisations. This means that 1) UEAP ME cannot send the questionnaires directly 
to SMEs or invite them directly to attend meetings in Brussels 2) UEAPME does not know 
whether or not its members have  national branch organisations  specialised in the sectors 
concerned by the NRMM and the Noise Directives. Therefore, UEAPME cannot target these SMEs specifically. Because the NRMM and the Noise Directives are very specific, it 
is not possible for UEAPME to speak in the name of its members on this issue. UEAPME has also expressed concerns with respect to the representativeness of any response because 
of (1) the language barrier some SMEs face (2) the short deadline. This channel has not led to any specific response. 
– Thanks to the kind cooperati on of Mr Berck and Németh of  DG ENTR, we have launched 
the questionnaires through the Ente rprise Europe Network on 03 June. 
This channel has not led to  any specific response. 
– Taking into account that many e quipment types that are cove red by the Noise Directive 
contain engines that are covered by the NRMM Di rective, we have taken a sample of more 
than 80 companies out of the noise database that the Commission is managing according to 
Article 16(4) of Directive 2000/14/EC. This samp le has led to the identification of just 2 
SMEs. As already pointed out above, many “small” companies do not fall under the 
definition of SMEs because they fail to  satisfy the criterion of autonomy. 
– We have also contacted associations of local  authorities (Eurocitie s and CEMR), who are 
important end users of some machine types covered by the Directive. On 22 July, the 
CEMR has informed us that they would not be able to provide input on this issue. 
On 28 May, the Commission services have sent us a list of Italian SMEs that they had 
received from an Italian stakeholder. All thes e enterprises have been contacted immediately, 
and some individual responses were receive d. On 29-30 June, reminders (per e-mail and 
phone) were sent to all individual co mpanies that had not yet responded. 
On 30 June, CECE has handed over a list of indus try directories that could be useful in 
identifying individual SMEs: www.intermat.f r ; http://www.bauma.de/ ; www.smopyc.es ; 
www.lectura.de ; ANMOPYC ; www.khl-group.com . 
These directories contain several thousands of co mpanies. We have taken a targeted sample of 
170 companies in order to identify SMEs that are not members of the sector associations. 
Based upon publicly available information, we have  concluded that 71 of  these companies do 
EN 72   EN not fall within the EC definition of SMEs. All other companies have been contacted 
individually. 
PNEUROP has informed us that, to the best of their knowledge, none of their members is 
actually an SME. However, they have provided us with a (short) list of manufacturers that 
they think may be SMEs but that are not me mbers of PNEUROP. Thes e manufacturers have 
been contacted individually. On 15 Septembe r, CECE has also handed over a list of 
companies that produce drill rigs. They have al l been contacted indivi dually. In some cases, 
individual respondents to the questionnaires have also indicated that some  of their competitors 
may well fall within the EC definition of SMEs. These companies have been contacted individually. Reminders have been sent. 
On 12 October 2009, the contract was formally amended, allowing an extension until the end 
of March 2010. We have used this extensio n to send reminders, both to professional 
organisations and to the companies that had b een contacted on an indi vidual basis. This has 
unfortunately not led to  a significant increase  in the response rate. 
EN 73   EN 8 Landbased compression engines: Special agri cultural tractors used in vineyards and 
orchards 
8.1 Impact on producers 
The IA study had concluded th at 45% of the tractor market is in hands of SMEs. 
Discontinuation of the production of this type of tractors would put them out of business. 
T2 (narrow wheeled) tractors and C2 (narrow tracked) tractors are produced in Italy and 
Germany only. After thorough inve stigation, the 3 manufacturers th at were indicated as SMEs 
turned out to have a workforce between 250 and 300 people38. Therefore, they do not qualify 
as medium enterprises according to the EC definition. We will therefore no longer pursue the 
issue of the T2 and C2 tractors in this section. 
The T4.1 (high clearance) tractors are a typicall y French product. 95% of the market is held 
by Bobard and Tecnoma. Bobard is an SME, wh ile Tecnoma is part of the Exel group. The 
remaining 5% is held by very small producers, w ho sell at most 10 to 20 tractors per year. The 
market has gone through a consolidation phase in the 1990s, which is  indicative of the 
existence of economies to scale. According to Bobard, this market is a small one. Industry 
sales amount to 500-600 units per year. 90% of these are sold in France while the remainder is exported to Switzerland or to Centra l and Eastern European countries. 
Sales (in units) at the industry level have decreased by 12% in 2007-2008 and by 12-15% in 
2009. This decrease is largely due to the on- going economic recession, a nd not to structural 
factors. 
On the contrary, due to an ongoing consolidation of the viticulture sector, the average surface 
area of individual enterprises is increasing. Clie nts are requesting product s of ever increasing 
precision. Thus, while the number of tractors sold is decreasing, the unit pr ice of tractors is 
increasing.  
Actually, demand can be expected to increase in the future. In France, the Grenelle de 
l'Environnement has requested a decrease of pesticide use in agriculture with 50%
39, which 
should lead to increased mechanical weeding (and thus to an increase in demand for high 
clearance tractors). 
Besides Bobard, we have identifi ed 3 other producers of high cl earance tractors. One of them 
declined to allow an interview due to time constraints. This leaves us with three case studies based on telephone interviews. 
8.1.1 Case study 1 
Bobard produces only high cleara nce tractors (T4.1) which are used in narrow vineyards. 
According to Bobard, horses are the only techni cal alternative to this type of tractors. 
Currently, Bobard sells about 250 tractors per y ear, in 5 different models. With an average 
                                                
 
38 Personal communication by Dr Billi (24 November 2009). 
39 see: http://www.legrenelle-environnement.fr/ grenelle-environnement/IMG/pdf/Fiche_6.pdf 
EN 74   EN lifetime of 3 years, this means that fixed develo pment costs have to be amortized over a series 
of 150 tractors. 
The large number of models is explained by the diversity of terrain conditions (relief, 
plantation width) on which vineyards are built. 
The relative share of fixed costs is increasi ng through time. The development costs linked to 
the integration of an engine complying with a new stage of emission standards correspond to 
one full time project engineer during one year (to which one has to add the homologation 
costs, which vary from 12 000 to 15 000 EU R, depending on the tractor type). These 
resources are then unavailable to meet new tec hnical requirements from the clients. Bobard 
can manage the development of 3 new projects per year. Each new tractor type requires 23 
months as a prototype. 
The typical sales price of a T 4.1 tractor sold by Bobard li es in the range 70 000 to 85 000 
EUR. 
The typical economic lifetime (in use) a T4.1 tract or is 7 to 10 years. If a tractor is used 
beyond this period, annual maintenance cost s can be expected to increase from 
(approximately) 1500-2000 EUR per y ear to 3000-4000 EUR per year. 
Bobard has suggested to have a longer time in terval between subsequent stages. Bobard does 
not take advantage of the flexibility scheme. Their main motivation for not doing so is that 
they are uncertain whether their engine suppliers will be able to supply engines that comply 
with the previous stages of the Directive, whil st they have already started the production of 
engines complying with the next stage. With  a longer time interval between subsequent 
stages, the product cycles of engine a nd tractor producers would be synchronised. 
Bobard estimates that the homologation of a ne w tractor for use on the road requires 7 to 8 
weeks of internal work, and between 15 and 23 weeks before approval of the DRIRE is obtained. 
8.1.2 Case study 2 
VSP Construction is a family business in the category “micro enterprises”. 90% of their 
turnover (1 200 000 EUR) originates from the sa le of T4.1 tractors. This corresponds to 10-15 
tractors per year. Occasionally, th ey also sell tracked tractors. 
6 employees (out of a total of 17) are direc tly involved in the production of T4.1 tractors. 
The production of the frame is subcontracted  to their sister company C2MH – this 
corresponds to 2 indirect jobs. 
The vast majority of their sale s take place in France; although th ey also occasionally sell on 
the Belgian market. 
Their principal activity consists in the productio n of customized high clearance tractors. This 
is not limited to applications in vineyards; th eir clientele consists of firms who do not find 
suitable solutions in the mass ma rket. Non-vineyard applications  include tractors for picking 
up algae under the water level or for picking up boulders from fields. However, vineyard 
applications still constitute 90% of their turnover. Another competitive advantage is a shorter delivery time than some of their compe titors. A disadvantage compared to larger 
manufacturers is that the share of developmen t costs is relatively high (one sixth of the 
EN 75   EN payroll). However, their activity is not capital intensive and depreciation of physical capital is 
not an important cost category40. 
On average, this company sells its tracto rs at a unit price of 100 000 EUR, which is 
significantly higher than the prices quoted by Bo bard. This confirms that this producer does 
not compete on price. 
Their main concern is related to the homologa tion costs. All tractors using public roads (even 
for very short trips) have to be homologated41. Every time a new engine is installed, the 
producers need to go through the whole homologa tion procedure, even if the tractors are 
otherwise identical. The development of a new tr actor requires on average 3 to 4 months. The 
test (pollution, brakes…) are undertaken under the surveillance of UTAC , who prepare the 
homologation dossier for the DRIRE. This  requires approximately 10 working days. 
Although, in theory, the homologation file should be processed within 45 days, this can take 
up to 1 year in practice. 
As it is allowed to sell non-homologated tractors as long as they do not use public roads, some 
vineyards use trucks to move the tractors on the public roads. However, this solution requires 
the winegrower to obtain a driving licence for tr ucks. Moreover, it is fa r from obvious to load 
and unload tractors. Therefore, for short di stances, users prefer to take the road. 
VSP’s engines suppliers are already capable of  supplying stage IV compliant engines, at a 
price that is 50% higher than  engines that meet the current emission limits. As already 
reported in the JRC report and the IA study, thes e engines take much more place and limit the 
manoeuvrability of tracto rs in the vineyards. 
As a supplier of customized products, VSP feel  that they cannot adap t their designs pro- 
actively, as they cannot anticipate the specific cl ient needs that will arise in the future. VSP 
has no specific comments on the NRMM Directive in itself – for them, the priority should be 
a simplification of the homologation procedure (w hich falls outside the scope of this study). 
They point out that, as end users sometimes adapt the tractors themselves, without being 
subject to the slightest control, these heavy a nd costly procedures ar e circumvented anyway. 
8.1.3 Case study 3 
FREMA is a small company with 12 employees (2 of which are working on development). 
They have a turnover of 5 m illion EUR, which is uniquely composed of high clearance 
tractors. Their annual production corresponds to 50 tractors, which are sold at a price that 
varies between 50 000 and 100 000 EUR, depending on the model. 
Their main competitive advantages compared to larger producers are their higher flexibility 
and proximity to the clients. They sometimes produce tailor made tractors, but most of their 
production is made in series. 
Homologation of new machines is a major c oncern. The tests by UTAC cost 2 500 EUR. The 
subsequent approval of the file by the DRIR E can take between 6 months and a year. As 
already pointed out above, it is legally possible to  sell tractors that have not been homologated 
if they do not circulate on the roads. Howeve r, in FREMA’s experience, clients do not accept 
this possibility. An important problem is that the French homologation for the road is not recognized in the countries to which they expor t (such as Germany and Austria). This is due 
                                                
 
40 No concrete figure has been given. 
41 By the DRIRE, the Directions Régionales de l'Industrie, de la Recherche et de l'Environnement. 
EN 76   EN to different standards (for inst ance, with respect to the brakes ). Every time a new engine is 
installed in a tractor, the whole homologati on procedure has to st art all over again. 
FREMA has confirmed the usefulness of the flexibility mechanism. The high clearance tractors for vineyards are sold  uniquely in France. FR EMA also sells high 
clearance tractors for cereals (seed corn, sunflowers, tobacco ). These are also exported, 
mainly to Europe, but also to Latin Ameri ca (where no regulations on emissions exist). 
Exports outside the EU correspond to 4-5 tractors per year (sales of 300 000 EUR). This firm 
is thus heavily dependent on the EU market. 
8.2 Impacts on professional users 
For the impact on end users in the agricultural and vineyard sector, we  have contacted COPA-
COCEGA. A meeting to discuss th e approach for the consultation has taken place on 14 July. 
As no response had been received from COPA-COGECA by the end of September, 
ARCADIS has submitted a thoroughly simplified questionnaire to CO PA- COGECA with a 
renewed request to forward this  questionnaire to the members. No answer has been provided 
to date. 
Concerning the impact on vineyards, we have c onsulted with the Europe an Confederation of 
Independent Winegrowers (CEVI). CEVI represen ts European independent winegrowers. In 
the case of independent winegrowers, the whole process (vine growing, harvesting, 
winemaking and wine selling) is fully vertic ally integrated. CEVI represents 9000 members. 
The total number of independent winegrowers in Europe is estimated to be, in total, from 
180,000 to 200,000. A large number of these wine growers produce only for household 
consumption, but no reliable estimate exists of  the number of winegrowers who sell their 
products. 
The large majority of independent winegrower s are micro-enterprises, generally family 
owned. Only a very small minority are small enterprises. In France, the “very big estates” of 
independent winegrowers account  for 2.5 % of all the independe nt winegrowers’ estates, 
where “very big” refers to estates of 10 employees on average and a surface of 84.4 ha
42. 
CEVI reckons that the pr oportion is roughly the same in the other countries. 
None of these enterprises are medium. As pointed out in the IA study, in the absence of stage IIIB and IV tractors, the end users have 
two options: 
– Redesign existing vineyards to fit compliant tractors 
– Maintain the old tractors until a technical solution has been found for new tractors 
Let us discuss the economic implications of both in turn. 
8.2.1 Redesign of existing vineyards 
In the case of vineyards, it is useful to first consider the possibilities for public support that 
exist for restructuring existing vineyards: 
Since the entry into force of Regulation (EC) N°1493/1999, recently amended by Regulation 
(EC) N° 479/2008, the common organisation of th e market in wine has provided for the 
                                                
 
42 The average independent winegrower ’s estate in France is 12.3 ha 
EN 77   EN possibility for Member States to give s upport for the restructuring and conversion of 
vineyards. 
Chapter 1 of the Regulation lays down the rules governing the attr ibution of Community 
funds to Member States and the use of thos e funds by Member States through national support 
programmes (hereinafter referred to as s upport programmes) to fi nance specific support 
measures to assist the wine sector. 
According to Article 4, Member States shall be responsible for the support programmes. 
According to Article 11 of Regulation (EC)  N° 479/2008, the objective of measures relating 
to the restructuring and conversion of vineyard s shall be to increase the competitiveness of 
wine producers. 
Support for restructuring and conversion of vi neyards may only cover one or more of the 
following activities: 
(a) varietal conversion, incl uding by means of grafting-on; 
(b) relocation of vineyards; (c) improvements to vineyard management techniques. The normal renewal of vineyards which have come to the end of their natural life shall not be 
supported. 
Support for restructuring and conversion of vi neyards may only take the following forms: 
(a) compensation of producers for the loss of  revenue due to the implementation of the 
measure; 
(b) contribution to the costs of  restructuring and conversion. 
Compensation of producers for the loss of reve nue may cover up to 100 % of the relevant 
loss. The Community contribution to the actua l costs of restructuring and conversion of 
vineyards shall not exceed 50 %. In regions cl assified as convergence regions, the Community 
contribution to the costs of restructur ing and conversion shall not exceed 75 %. 
Summarising the text above, Member States coul d thus decide to provide financial support for 
the adaptation of the row width of vineyard s in order to allow the use of tractors
43. 
However, it is not clear whether financial compensation would be enough to compensate 
winegrowers for the other drawbacks of redesi gning the vineyards. I ndeed, CEVI has argued 
that in vine growing, a higher planting density guarantees a bett er quality of the grapes, and 
that this explains why the European Community supports re planting with a higher density44. 
Redesigning the vineyards to better accommodate special tractors would run counter to this 
objective. However, the relation between planti ng density and grape quality is controversial45. 
We do not think it would be worthwhile to further deepen this issue here, as it is of relatively 
minor importance compared to the financial imp lications of adapting the row widths one more 
time. Indeed, in the first seven years of a pplication of the sche me, 400 to 465 million EUR 
were allocated annually to restructuring and conversion measures46. 
                                                 
43 Personal communication from DG AGRI. 
44 However, in the text of the Regulation (EC) N° 479/2008, no explicit reference to density is made. 
45 Cesare Intrieri and Ilaria Filippetti. Proceedings of  the ASEV 50th Annual Meeting, Seattle, WA, June  
 19-23, 2000, pp 296-308 
46 http://ec.europa.eu/agriculture/markets/wine/prod/depens.pdf 
EN 78   EN The IA study had shown a total environmental cost of 120 million EUR in case the special 
purpose tractors would be exempted from stag e IIIB and stage IV. This figure is obviously 
very low compared to the financial implicat ions of a redesign of existing vineyards and 
orchards. Of course, not all existing vineyard s would need to be redesigned. However, the 
figure above does suggest that the cost of adap ting the row width can be significantly higher 
than the environmental cost of exempting the sp ecial purpose tractors fr om stage IIIB and IV. 
Moreover, adapting the row width in itself would lead to the re lease of carbon, which is also 
an environmental cost. CEVI admits that no i ndependent estimate of these releases exists. 
8.2.2 Maintenance of old tractors 
In Section 8.1 we had reported that if a hi gh clearance tractor is used beyond its economic 
lifetime, annual maintenance costs can be ex pected to increase from 1 500- 2 000 EUR per 
year to 3 000 – 4 000 EUR per year. 
For illustrative purposes, we assume that the cost  increase is 2 500 EUR per year per tractor, 
and that all special tractors face the same increase in maintena nce costs as the high clearance 
tractors. To remain consistent with the IA st udy, we assume that a technical solution can be 
found 5 years after the planned in troduction date of the next emi ssion stage, that a total of 
25 600 units are sold per year in the EU a nd that a discount rate  of 4% applies. 
For the T4.1 tractors, based upon the response received during the consultation, we assume 
that 400 units are sold per year. 
To the best of our knowledge, no data on the sales of C2 tractors are publicly available47. 
Thus, in total we assume that 26 000 special trac tors are sold per year. We assume that all 
sales correspond to replacement sales and th at, once the technical solution has been 
developed, old tractors are replaced at  a rate of 26 000 units per year. 
The table below gives then, for each year afte r the planned introduction of stage IIIB until all 
“old” tractors have been replaced by stage IIIB compliant tractors, the increase in the number 
of tractors that are kept in use beyond th eir economic lifetime and the implied extra 
maintenance costs at the EU level. 
Table 5: Extra maintenance costs for speci al tractors used beyond economic lifetime 
Year Number of tractors kept in use  Extra cost per year 
1 26 000 65.000.000 2 52 000 130.000.000 3 78 000 195.000.000 4 104 000 260.000.000 5 130 000 325.000.000 6 104 000 260.000.000 7 78 000 195.000.000 
                                                
 
47 This has been confirmed in a personal communication by Dr Krasenbrink of the JRC 
EN 79   EN 8 52 000 130.000.000 
9 26 000 65.000.000 
The net present value of these costs (discounte d to the planned introduction of stage IIIB) is 
1 339 million EUR. This is an order of magnit ude higher than the environmental benefits 
linked to not postponing stage IIIB  with 5 years (120 million EUR). 
Thus, even if actual higher maintenance cost would be significantly lower than suggested by 
the manufacturers, the costs of not postponing st age IIIB would still be much higher than the 
benefits. 
8.3 Conclusion 
On the producers’ side, no SMEs are involved  in the production of special agricultural 
tractors, except in the niche of high clearance tractors. This market  represents less than 2% of 
the total market for special tractors in Europe. The following points are noteworthy: 
- Although the tractor manufacturers we have interviewed know that the machines they 
produce are regulated by the NRMM  Directive, some of them did not appear to understand 
fully the implications of th e next stage in the Directive . Some of the smaller companies are 
not affiliated to professional associations, a nd were not aware of the on-going legislative 
process until the phone interview. It was th erefore sometimes difficult to keep the phone 
interview focused on the subject at hand. 
- Maybe because of this lack of information, the most important concern raised was not the 
next stage in the Directive, but the homologation process . The points raised by the producers 
of special tractors were almost identical to those discussed in Chapter 7: the length of the 
process, the lack of international standardisatio n and the fact that even minor changes require 
rerunning a complete homologation process. The possibility to sell non-homologated tractors 
and to use trucks to move them on the road was rejected as unrealistic. One manufacturer has 
pointed out that the homologation procedures are sometimes circumvented by the end 
users , who adapt tractors to their own n eeds without any external control. 
- Most manufacturers that we have  interviewed are aware of the flexibility scheme, but not all 
seem keen on using it. One manufacturer has raised the specific concern that the engine 
suppliers may not always be able  to supply engines complying w ith the previous  stage of the 
Directive48. 
- This very small market is further divided in subniches determined by the diversity of 
terrain conditions on which vineya rds are built. This implies that producers have to amortize 
fixed development costs (including homologa tion costs) over very small series. The rapid 
succession of stages in the Direct ive exacerbates these problems . At least one producer has 
suggested introducing longer time intervals be tween successive stages of the Directive. 
Regarding the impact on orchards, no information (even indicative) has been obtained from 
the relevant professional organisation. 
Regarding the impact on vineyards, the Europ ean sector federation has confirmed that all 
independent winegrowers are SMEs, and the va st majority are micro-enterprises. Using 
                                                 
48 In other applications, engine manufacturers keep on producing engines complying only with previous  
stages of the Directive, but these en gines are exported to unregulated regions of the world. We have to  
keep in mind that this chapter treats a niche market, where this outlet does not necessarily exist. 
EN 80   EN figures on existing public support schemes, we have argued that the cost for redesigning 
vineyards to accommodate stage IIIB a nd IV compliant tractors would be several orders of 
magnitude larger than the environmental cost of not exempting the special tractors from 
stage IIIB and IV . Moreover, such a policy would run counter to the existing policy to 
stimulate a higher plating density. 
The alternative option would be  for vineyards to keep old tractors in use beyond their 
economic lifetime. Our calcu lations suggest that the increased maintenance cost following 
from this option would be an order of magnitude larger than the environmental cost of not 
exempting the special tractors from stage IIIB and IV . As another way to put these 
compliance costs in perspective, one could note that they are of  the same order of magnitude 
as the compliance costs linked to the Euro mot proposal for inland waterway engines. 
EN 81   EN Annex XI - Fleet and a nnual sales of tractors 
Annual sales estimates per tractor category and power class (year 2005, 
EU15) 
 Power
(kW) 
Total Nr49 19-37 37-56 56-75 
Agricultural 
tractors 163 000 3 260 32 600 48 900 
T2 24 439 5 004 7 690 10 338 
C2 1 128 10 711 407 
T4.1 550    
Total number of tractors in use per tractor category and power class (year 
2005, EU15) 
Total engines 
in use Total Nr 19-37 37-56 56-75 
Agricultural 
tractors 2 500 420 32 600 521 600 782 400 
Percentage  1,3 20,9 31,3 
 
Source: JRC / CEMA 
                                                 
49 The total number includes also tractors of engine power categories above 75 kW. 
EN 82   EN Annex XII – Estimation of environmental impacts 
This Annex presents the way the environmenta l impacts mentioned in the current Impact 
Assessment report have been estimated, based on the results of the JRC and Arcadis reports. 
The latter two reports contain several figures on the environmental impacts of some of the 
options. These impacts are give n relative to the hypothetical scenario, whereby compliant 
NTTs would be placed on the market by the dates foreseen in the current Regulation. In this 
IA report, other options have been investigated and the refe rence chosen was option 1 (the 
baseline scenario), where no compliant NTTs ca n be put on the market and the use of older 
NTTs is prolonged.  
The following steps have been carried out: 
• JRC report mentions for Op tion 3 additional emissions of 3,5 kt PM and 33 kt 
NOx 
• The Arcadis report mentions for Option 3 environmental costs of 48 M€ for PM, 
72 M€ for NOx 
• This report also mentions  for Option 1 environmental costs of 60 M€ for PM, 134 
M€ for NOx 
• The cost factors used can therefore be calculated, based on th e above figures for 
Option 3 
• These cost factors can be applied to calcu late the additional emissions of Option 1 
• The additional emissions of Option 2 were estimated by taking a proportionate 
share of those of Option 3 
• Environmental costs of Option 2 can be estimated by multiplying the emissions by 
the cost factors 
• The JRC report mentions, for option 4, year ly additional emissions of 0,7 kt PM 
and 6 kt for NOx 
• The total additional emissions are estimated by multiplying by 38 (for 2012-2050) 
• Environmental costs of Option 4 can be estimated by multiplying the emissions by 
the cost factors 
The results are presented in the following table: 
 hypothetical 
scenario option 1 
(baseline) option 2  
(3 yr delay)option 3  
(5 yr delay) option 4 
(exemption)
Change in PM 
emissions (kt) 0 4,3 2,1 3,5 27 
Change in NOx 
emissions (kt) 0 62 20 33 230 
Change in PM costs 
(M€) 0 60 29 48 373 
EN 83   EN Change in NOx 
costs (M€) 0 134 43 72 495 
The environmental impacts for options 2, 3 and 4 mentioned in this report, represent the 
variations relative to the ones of option 1 (baseline scenario).