29. 12. 86 Official Journal of the European Communities No C 333/7 
The Community competition policy will be a success if are the true challenges of our time, 
it accommodates these two forces for change, which 
Done at Brussels, 23 October 1986. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
Opinion on the proposal for a Council Directive amending Directive 77/143/EEC on the 
approximation of the laws of the Member States relating to roadworthiness tests for motor 
vehicles and their trailers 
(86/C 333/02) 
On 20 May 1986 the Council decided to consult the Economic and Social Committee, 
under Article 75 of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Section for Transport and Communications, which was responsible for preparing the 
Committee's work on the subject, adopted its opinion on 10 September 1986, in the light of 
the oral report by Mr Corell Ayora. 
At its 240th plenary session (meeting of 23 October 1986) (rapporteur-general: Mr Corell 
Ayora, Article 18 of RP) the Economic and Social Committee adopted the following opinion 
unanimously. 
1. General comments 
1.1. The Committee welcomes the objectives of the 
proposed Directive, which is aimed primarily at increas­
ing road safety and could also have an impact on: 
— the protection of the environment by limiting noise 
and reducing CO, HC and NOx emissions from 
exhausts, 
— fuel savings, new jobs, improved vehicle availability, 
and the provision of better information for vehicle 
owners and manufacturers. 
1.2. By approximating legislation, the proposal will 
also help to eliminate differences between Member 
States and eventually to bring the Community together 
in such a sensitive area as road safety. 1.3. It must be pointed out in this context that some 
Member States have considerable ground to make up 
and gaps to fill in their vehicle testing legislation: this 
has serious consequences on road safety. The sharp rise 
in the number of vehicles on the roads in recent years 
has further aggravated the situation. In this respect 
the Committee regrets that the Community institutions 
and, first and foremost, the Council have been very 
slow to do anything about introducing Community 
legislation for the testing of light vehicles. 
1.4. However, it must not be forgotten that the 
extension of roadworthiness testing to private cars and 
vans concerns only one aspect of road safety. Only if 
measures are taken as soon as possible in other fields 
—as the Committee has already suggested in its opinion 
on European Road Safety Year (1986) (2)—will a con­
siderable improvement in road safety be possible. The 
Commission's proposals on these matters are eagerly 
awaited. 
(J) OJ No C 133, 31. 5. 1986, p. 3. (2) OJ No C 101, 28. 4. 1986, p. 8. 
No C 333/8 Official Journal of the European Communities 29. 12. 86 
1.5. The Committee also points out that it has on 
several occasions in the past stressed the need for 
mandatory roadworthiness tests on vehicles travelling 
on the Community's roads, e.g. in its opinions on 
the roadworthiness testing of heavy vehicles and other 
categories of vehicles, the Directives on the lead content 
of petrol and motor vehicle emissions and European 
Road Safety Year(!). 
1.6. While accepting the Commission's proposal in 
principle, the Committee thinks that its application 
will pose problems and that some aspects should be 
improved. Accordingly, it would make the following 
comments. 
2. Specific comments 
2.1. The Committee deduces from the explanatory 
memorandum to the Commission proposal that 
adequate data were available to justify an extension of 
Directive 77/143/EEC to the categories of vehicle in 
question (cf. point 1.4.). In order to better assess the 
full implications of the proposal the Committee would, 
however, have liked to have detailed information on 
the following: 
— the tests currently carried out on private cars and 
light goods vehicles in Member States (e.g. test 
procedures and content, advantages and disadvan­
tages), 
— the special circumstances in each country, e.g. the 
number of vehicles on the roads, their classification 
according to category and age, existence of test 
centres and spare parts, 
— the application to date in the Member States of 
Directive 77/143/EEC, i.e. whether and to what 
extent the Directive has been applied and with what 
results. 
In this connection the Committee urges the Commission 
to take account of these points in the studies and 
research which it intends to promote in the field of 
road safety, including the creation of a Community 
data bank for road safety to which all the Member 
States would have access. Furthermore, the Committee 
considers that it would be useful to have reliable docu­
mented data on the costs and benefits of the proposed 
measures. (The experiences gained with the testing of 
private cars in some countries are a valuable asset here.) 
Conclusions can be drawn about whether such 
(') OJ No C 60, 26. 7. 1986, p. 1; OJ No C 25, 28. 1. 1985, p. 
46; OJ No C 101, 28. 4. 1986, p. 8. measures ought to be applied once the costs and benefits 
are compared. On the cost side a distinction must be 
drawn between (a) the direct cost of building and 
maintaining test centres and verifying that the measures 
have been applied and (b) the indirect cost for vehicle 
owners. 
2.2. It must not be concluded from the foregoing, 
however, that the reduction of the number of road 
deaths and injuries is a 'negotiable' social objective. 
2.3. The Committee regrets that the Directive does 
not cover motorcycles, and that there are no special 
provisions for other categories of vehicles (cf. 2.7.). It 
also wonders how the roadworthiness of agricultural 
machinery and tractors could be ensured. This should 
not, however, hinder the rapid adoption of the Directive 
by the Council. 
2.4. The list of items to be tested (Annex III) is, on 
the whole, adequate and sensible. Of course, certain 
items might still have to be reconsidered, or elucidated 
(e.g. nuisance of old vehicles, steering). Furthermore, 
the Committee thinks that the content of the list must 
be reviewed from time to time to make allowance for 
changes in vehicle design and equipment (e.g. introduc­
tion of microelectronics in recent years). 
2.5. It is also vital that most of the tests are carried 
out on the basis of objective criteria. Subjective tests 
(e.g. checking the suspension's or the steering's wear 
and tear), an obvious source of controversy, should be 
reduced to a minimum. 
2.6. On the subject of testing procedures and the 
content and frequency of tests, it should be considered 
whether a distinction ought to be made between tests 
relating to the mechanical condition of the vehicle (and 
hence linked directly to road safety) and environment­
ally-related tests. Such distinctions are already made 
within the Community. 
2.7. Furthermore, the Committee would like to see 
consideration given to a special roadworthiness test in 
the following cases: 
— private, commercial and hired vehicles (e.g. more 
frequent tests for the latter), 
29. 12. 86 Official Journal of the European Communities No C 333/9 
— vehicles not type-approved prior to registration, 
vehicles undergoing a periodic test and vehicles under­
going a special test following a change of owner or an 
accident. 
2.8. The Committee further considers that appli­
cation of the Directive by the Member States is in itself 
not enough: it must also be applied uniformly. This 
applies particularly to the content of the tests. A vehicle 
which passes the test in one Member State should also 
pass the test in any other Member State. 
2.9. The Committee thinks that the roadworthiness 
tests are the responsibility of the authorities. It is also 
up to the Member State authorities to lay down the 
procedures and to verify the application of the road­
worthiness test. However, the Committee agrees with 
the Commission (Article 1 (3) of the proposal) that the 
tests could be delegated to approved workshops which 
have the necessary equipment, as is the case in some 
countries. These workshops should come under perma­
nent State supervision. 
2.10. There are no provisions in the proposal about 
vehicles which fail roadworthiness tests. The Commit^ 
Done at Brussels, 23 October 1986. tee thinks that the repair or demolition of such vehicles 
should be made mandatory. For this purpose there 
ought to be 'automatic checks', as there are in some 
countries where a roadworthiness certificate is required 
to obtain the documents necessary for putting a vehicle 
on the road. 
2.11. As far as the implementation of the Directive 
is concerned (Article 2), the Committee thinks that 
the Commission and the Council should review the 
timetable of derogations in Article 2 (3) of the proposal 
which, in its view, lays down overly short deadlines for 
those Member States which do not have adequate test­
ing facilities at the moment. 
2.12. Finally, the Committee considers that the infor­
mation to be supplied to the Commission by the Mem­
ber States with regard to the adopted measures (Article 
2 (2) of the proposal) must be supplied annually on the 
basis of documents common to all Member States. This 
will make it possible to improve the accuracy, clarity 
and regularity of the information given and check the 
application of the measures more effectively. The Com­
mission, in turn, should publish periodic reports on the 
information supplied by the Member States with regard 
to the Directive's application, and should submit these 
reports to the Committee. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT