10. 9. 90 Official Journal of the European Communities No C 225/7 
Opinion on the proposal for a Council Directive amending Directive 70/220/EEC on the 
approximation of the laws of the Member States relating to measures to be taken against air 
pollution by emissions from motor vehicles (*) 
(90/C 225/04) 
On 16 February 1990, the Council decided, in accordance with Article 100a of the Treaty 
establishing the European Economic Community, to consult the Economic and Social Committee 
on the abovementioned proposal. 
The Section for Industry, Commerce, Crafts and Services was instructed to prepare the work on 
this topic and adopted its opinion on 6 June 1990. Rapporteur: Mr Pearson. 
The Economic and Social Committee, at its 278th plenary session, meeting on 5 July 1990, 
adopted, by a majority and three abstentions, the following opinion. 
INTRODUCTION 
The Committee recognizes that the Commission proposals 
are a further step towards reducing the pollution caused by 
the use of motor vehicles and that this should help the 
environment. Mobility of Community citizens is seen as an 
important element of personal freedom, thus public 
transport and private transport have their parts to play: in 
the peripheral regional areas, where public transport is 
usually infrequent, the private passenger vehicle is 
absolutely necessary and without it regional economic well 
being and development cannot take place. 
In approving the proposals the Committee however would 
encourage the Council of Ministers to consider the 
following matter when finalizing its Decision. 
1. General comments 
1.1. The Committee notes that the Commission, 
conforming to the Council request, considers the proposals 
submitted for the exhaust emission levels as severe as those 
present standards in the United States of America and that 
they will assure adequate protection as regards public 
health and environment. Owing to the social and 
environmental dimension of this topic the Committee 
believes that the Community should continue to work with 
the automobile, oil, other interested industries and all 
groups with environmental or consumer interests, in order 
that progress towards further reduction of harmful exhaust 
emissions can be achieved. 
The Committee believes that, regardless of European 
standardization work, it is necessary to prevent the 
uncontrolled proliferation of international limit values and 
test procedures. In addition to the efforts made by the 
Community, it is therefore necessary to work — in a 
second-stage operation — towards a unified, worldwide 
plan for the phased increasing of the severity of these 
emission standards. 
1.2. The availability to the European Community 
automobile industry of the three-way catalytic converter 
with closed loop control is such that it is possible to provide for the whole of the passenger car production, thus all 
passenger cars will be subject to the same emission controls 
as those adopted for small passenger cars by Directive 89/ 
458/EEC (2). 
1.3. The Directive under review will require all car 
categories to be subject to an improved, stricter and more 
sophisticated test procedure. This is a significant advance. 
1.4. The extension of testing to involve 'an extra-urban 
cycle characterized by a synthetized driving pattern' is 
innovative: it is variable as to power/mass (weight) ratios 
and maximum speeds. Essential is that the new proposal 
produces a format which must be carried out without 
separation and the measured masses of pollutants are 
compared to a set of limit values referring to the test as a 
whole. 
1.5. As a result of an invitation by the Council in 1985, 
the Commission has proposed to introduce further 
requirements concerning the durability standards of vehicle 
components concerned with the control of exhaust 
emission from passenger cars. In the setting of such levels 
the Commission should bear in mind European require­
ments due to geographic and climatic factors. Durability 
and adequate care of whole propulsion system are vital 
elements to the success of a system so heavily dependent on 
catalytic converters and there is concern that Member 
States have not made sufficient effort to ensure that 
appropriate levels of maintenance are introduced and 
applied. 
1.6.1. Yet another new area covered in this amending 
Directive is a set of measures to control the evaporative 
emissions from the fuel system of petrol engined cars. This 
will involve the so called SHED (Sealed House Evaporation 
Determination) to control permissable levels of fuel 
evaporation from cars parked after use and it will require 
the fitting of a charcoal filter. 
1.6.2. The Committee understands that the Commis­
sion is preparing a Directive concerning fuel distribution 
and evaporation levels and the necessity of the inclusion of 
(!) OJ No C 81, 30. 3. 1990, p. 1. (2) OJ No L 226, 3. 8. 1989, p. 1. 
No C 225/8 Official Journal of the European Communities 10. 9. 90 
all elements of the matter, from the refinery to the car in 
use, is stressed — a complete reliable coordinated chain of 
safeguards is what is required between the two Directives. 
1.6.3. The quality of fuels is extremely important and is 
one of the key factors for controlling pollution caused by 
vehicle emissions. The Committee recognizes the need 
expressed by the automobile industry for more precise 
gasoline specifications. The volatility of fuels is of great 
importance. Fuels of adequate quality and corresponding 
to the pertinent European Community specifications, 
should be available throughout the Community: con­
sequently the specifications of reference fuels should be 
reviewed with the cooperation of the automobile and oil 
industries. Consumer choice should be as wide as possible. 
1.7. The Committee endorses the statement expressed in 
the conclusions of the explanatory memorandum, wherein 
a period of at least five years is granted as regards the 
proposed European standards to ensure the stability of the 
legal framework in order to enable the relevant industries 
to amortize the necessary investments. This would not pre­
empt any manufacturer from producing a vehicle which 
emits exhaust gases below the legal limits. Future technical 
progress may put into question the duration of this 
projected time span, meaning that a revision of the 
Directive might be feasible in a shorter time. 
2. Specific comments 
2.1. With respect to diesel engined cars (!), the Commit­
tee, in recognition of the large and growing percentage of 
such cars in the Community, agrees that the level set for the 
emissions of diesel particulate pollutants at 0,19 g/km is 
currently acceptable but would encourage the European 
institutions together with the motor manufacturers to be 
involved in lowering these maximum levels as a matter of 
urgency. 
Also, there is a need for a more up-to-date diesel fuel 
specification. 
2.2. Evident throughout the document is the influence of 
the availability of the United States of America experience 
with catalytic converters and testing procedures. Despite 
the variance of views the Commission has agreed to the 
permitted emission levels and deadlines and its proposals 
are acceptable, being seen as an equitable assessment of the 
needs to meet the requirements of the European conditions. 
2.3. It is evident, that at the present time noxious 
emissions from car engines are intended to be controlled 
through the exhaust system of the vehicle. The Committee would emphasize the importance of a continuing high 
priority for the development of the lean burn engine, 
anticipating more ambitious exhaust emission control 
levels. The fourth environment action programme set a 
deadline of 1992/1993, or even earlier, which now seems 
unlikely to be met with a lean burn engine, and it is 
necessary that engine development with low pollutant 
levels is fully encouraged. 
The research and development of an electrically powered 
car should not be overlooked, or any other non-pollutant 
energy. 
2.4. Greater dependence on catalytic converters will 
make regular inspection increasingly important. This form 
of exhaust control system has an operating limit in perfect 
conditions but the elements of durability, accident factors 
and climatic conditions may all cause the equipment to be 
inoperative before that time. If the aim of this Directive is to 
be achieved then firm control of the operation is required 
and national legislation enacted (where necessary) and 
enforced. 
The Committee again draws attention to its previous 
opinions [86/C 333/06 (2) and 88/C 208/04 (3)] in which 
the recommendation for regular Ministry of Transport 
safety tests in all Member States is seen as an essential 
element in the proper monitoring of emission levels for 
motor vehicles. 
2.5. The Committee has also called attention to the fact 
that even 'conventional modern engines are becoming so 
complicated that servicing costs are reaching a level at 
which less than a proper minimum maintenance is being 
carried out by the owners'. Whilst the checking of 
catalyzer-converter with closed loop control exhaust 
systems will increase the charge to car owners, the 
Committee, nevertheless, considers it a necessity. 
2.6. As this Directive applies only to type-approval the 
Committee believes that the Commission should table a 
further Directive dealing with the proper and regular 
compulsory inspection of all motor cars, to ensure that 
exhaust emissions are within the limits laid down by the 
Community. 
Further research should be undertaken towards the 
production of simple form(s) of indicator(s) which might 
be attached to each car and which would indicate whether 
the emission limit level(s) were being exceeded. 
2.7. The Committee shares the Commission's view that 
the proposed standards linked with the new European text 
procedures, both for petrol and for diesel engines, should 
make use of the best available technology. The Committee 
is aware of the following issues being under discussion: 
(]) OJ No C 333, 29. 12. 1986, p. 17. (2) OJ No C 333, 29. 12. 1986, p. 17. 
(3) OJ No C 208, 8. 8. 1988, p. 7. 
10 9 90 Official Journal of the European communities ^oC22^9 
— a separate ^C^ limit value to be added to the combined 
limit value for IdC^l^^, 
— the introduction of additional limit values for C^C^ and 
IdCin the urban cycle. This action is intended to ensure 
that even in unfavourable operatingconditions (e.g^ 
mnercity traffic or when starting in cold weather) the 
exhaust treatment system (catalyzer) worlds efficiently, 
— the driving sequence tobeapphedtounderDpowered 
vehicles in accordance with their typical mode of 
operation. 
^ Arucles 
^.1. Ar^^ 2 ^ — The Committee approves the 
obligation of Aiember States to prohibit the importation 
into the Commumtyof motor cars from third countries 
which do not meet the exhaust emission or other 
Community regulations. All member States should be 
required to adopt appropriate national legislation without 
delay. 
Arr^A^ — This Article permits the Council todecideona 
future date to set requirements to reduce CC^ emissions in 
1. Introduction 
PL The three draft Uirectives are intended to replace 
similar proposals whichthe Commission drafted several 
years ago (in 1972 in the case of glaring, and 197^ in the 
caseoftheothertwo subjects).Theorigmal proposals were 
not well received by certain member States which wanted 
to retain some control over the admission of nonD 
(^Ol^DC^,!^ t^,DD^DtOl light of the progress gained in the research on the 
greenhouse effect.The committee feels that such an open 
ended proposal is unacceptable and suggests that the 
Council setalimitbyl]anuaryl991,which may later be 
amended, or at leastadefmite date. 
The Committee furthernotesthatthe Commission plans to 
preparealOirective concerning light commercial vehicles 
by the end of 1990. It is important that this plan is 
implemented. 
Arr^^ — Itwould seem thatljanuary 1991 may well be 
too soon to bring the new proposals into force in the 
member States and the Section would suggest ^within Sm 
months of the acceptance of the proposed lOirective by the 
Council of ^imisters. 
Uoneat8russels,4]ulyl990 
Community vehicles to their national territory, thereby 
precluding the adoptionofaCommumtytypeapproval 
scheme. 
1.2. The completion of these three tOirectives and their 
application in conmnction with those already in force will 
ensure that any vehicle marketed in the Community, 
regardless of its origin, satisfiesaset of coherent conditions 
guaranteeing a high degree of operating safety. The 
Committeealso hopes that the current attempts to lay Opinion on the^ 
— proposal foraC^ouncil directive on safety glazing and glazingmaterials on motorvehicles and 
their tracers 
— proposal foraC^ouncilfOirective on the masses and dimensions of motor vehicles of category 
^vil 
— proposal foraC^ouncillOirective on pneumatic tyres for motor vehicles and their trailers (^) 
(90BC22^0^) 
C^n21Eebruary 1990, the Council decided to consult the Economic and Social Committee, under 
Article 100a of the Treaty establishing the European Economic Community, on the 
abovementioned proposals. 
The Section for lndustry,Commerce, Crafts and Services, which was responsible forprepanng the 
Committees worl^onthis subject, adopted its opimonon^June 1990.Therapporteur was 
^ir^ernn^elletier. 
At its 278th plenary session (meeting of^July 1990),the Economicand Social Committeeadopted 
the following opinion with no dissenting votes and one abstention.