EN    EN EN 
 
EN    EN  EUROPEAN COMMISSION 
Brussels, 23.7.2010 
SEC(2010) 933 final 
  
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
 
Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
concerning Type-approval requirement s for agricultural vehicles  
  
Impact Assessment 
 
{COM(2010) 395 final} 
{SEC(2010) 934 final} 
 
EN 2   EN Table of contents 
Background ..................................................................................................................... ........... 4 
Section 1: Procedural issues and c onsultation of interested parties ........................................... 6 
1.1. Organisation and timing............................................................................................... 6 1.2. Public consultation....................................................................................................... 6 
1.3. External expertise........................................................................................................ .7  
Section 2: Policy context, problem  definition and right to act................................................... 8 
2.1. Policy context............................................................................................................ ... 8 
2.2. Problem definition........................................................................................................ 9 
2.2.1. A Lack of Legal and Regulatory cl arity and burdensome management...................... 9 
2.2.2. Resource-intensive transposition without adding value............................................... 9 2.2.3. Functioning of the internal market............................................................................. 10 2.3. Community competence and subsidiarity .................................................................. 11 Section 3: Objectives.......................................................................................................... ...... 11 
3.1. Overall objective ........................................................................................................ 1 1 
3.2. Objective 1: Simplification of existing acquis (by repeal of existing directives)...... 12 
3.3. Objective 2: Improved regulatory capacity  for future acquis (by new split-level 
regulatory approach with use of refere nces to international standards)..................... 12 
3.4. Objective 3: Completion of the single market ........................................................... 12 Section 4: Policy options...................................................................................................... .... 13 
4.1. Simplification I: Simplification of existing acquis (by repeal of existing directives. 13 
4.2. Simplification II: Improved regulatory capac ity for future acquis (by new split-level 
regulatory approach with use of refere nces to international standards)..................... 13 
4.3. Completion of the single market................................................................................ 14 Section 5: Analysis of impacts................................................................................................. 16 
5.1. Simplification I: Simplification of existing acquis (by repeal of existing directives) 16 
5.2. Simplification II: Improved regulatory capac ity for future acquis (by new split-level 
regulatory approach with use of refere nces to international standards)..................... 18 
5.3. Completion of the single market................................................................................ 21 Section 6: Options comparison and conclusions...................................................................... 27 Section 7: Monitoring and evaluation ...................................................................................... 31 ANNEX 1  Public consultation on outline propo sals for a Framework Regulation of the 
European Parliament and of the Council for Agricultural Vehicles .......................... 32 
1. Context ..................................................................................................................... .. 32 
2. Overview of respondents............................................................................................ 32 3. Summary of responses ............................................................................................... 32 
 
EN 3   EN 3.1 Choice of the legislative format ................................................................................. 32 
3.2 References to international regulations and standards............................................... 32 
3.3 The type-approval system as legislative approach..................................................... 33 
3.4 Completion and mandatory nature of the type-approval system ............................... 33 
3.5 Aspects to be covered................................................................................................. 33 3.6 Need for exemptions .................................................................................................. 33 ANNEX 2........................................................................................................................ ......... 34 
Description of the tasks requested to the external consultant  and methodology used ............ 34 
ANNEX 3........................................................................................................................ ......... 36 
Definition of vehicle categor ies and vehicle types .................................................................. 36 
and background to the ty pe-approval system........................................................................... 36 
A. The vehicle categories are defined as follows:.................................................................... 36 1. Category T: Wheeled tractors .............................................................................................. 36  
2. Category C: Track-laying tractors........................................................................................ 36 3. Category R: Trailers........................................................................................................ ..... 36 
4. Category S: Interchangeab le towed machinery.................................................................... 37 
B. Definition of vehicle types ................................................................................................. . 37 
1. Wheeled tractors:........................................................................................................... ....... 37 
2. Track-laying tractors: id em wheeled tractors....................................................................... 38 
3. Trailers: ................................................................................................................... ............. 38 
C. Background to the type-approval system ............................................................................ 38 ANNEX 4........................................................................................................................ ......... 40 
Market of agricultural vehicles ................................................................................................ 40 
ANNEX 5........................................................................................................................ ......... 44 
Stakeholders position on th e objectives and options................................................................ 44 
ANNEX 6........................................................................................................................ ......... 48 
List of separate directives, relation with UNECE and OECD ................................................. 48 
ANNEX 7........................................................................................................................ ......... 51 
Cost / Benefit comparison table ............................................................................................... 5 1 
 
 
EN 4   EN BACKGROUND  
Type-approval requirements for agricultural and forestry tractors, their trailers and towed 
machinery (vehicles from categories T, C, R and S1, hereafter referred to as agricultural 
vehicles) are currently contained w ithin the Framework Directive 2003/37/EC2 ( the 
“Framework Directive”). In addition to this, a series of Directives referenced in the 
Framework Directive contain deta iled technical requirements rela ting to agricultural vehicles. 
The Framework Directive became mandatory on the 1 July 2005 for new types of tractors 
from categories T1, T2, and T3, and is mandatory for all new T1, T2 and T3 tractors as of 1 
July 2009. For all the remaining vehicle types (categories T4, T5, C,  R and S) approval 
requirements are currently optional or not yet av ailable (Annex 3 includes detailed definitions 
of all tractor categories and in part C give s some information on how the type-approval 
system functions). To be noted that during cr eation and development of the complete type-
approval system, for some time directives usually  are of an ‘optional’  nature in order to 
facilitate those manufacturers that want to  (and are able to) use the advantages of 
harmonisation while not creating undue burden to  others. For authori ties it allowed at the 
same time to adapt. 
Type approval is legislation th at has been addressed in the political initiative named “CARS 
21”3. This initiative was set up in 2005 to carry  out an automotive-related regulatory and 
policy review to advise the Commission on fu ture policy options. One of the reasons for 
setting up CARS 21 was the concern expre ssed by automotive stak eholders that the 
cumulative cost of regulation had a negative e ffect on competitiveness, and made vehicles 
unnecessarily expensive. The CARS 21 Final Report4 concluded that while most of the 
legislation in force should be maintained  for the protection of consumers and the 
environment, a simplification exercise should be undertaken so as to rationalise the regulatory 
framework and move towards interna tional harmonisation of requirements. 
Concerning the braking  requirements currently provided for in Directive 76/432/EEC for 
tractors it has been made evid ent that the directive needs to be updated and extended to the 
other categories covered by the Framework Di rective. Draft amendments have been 
extensively discussed and should be concluded in the near fu ture. These amendments will 
thus be integrated into the implementing legi slation following the split-level approach which 
is explained in more detail below. As it may have serious implications the Commission will prepare a separate impact a ssessment report on this project 
Information on the market  of agricultural vehicles (more details are presented in Annex 4): 
a. For the tractor categories of T1-T2-T3, the EU type-approval (TA) is mandatory on the 
basis of Directive 2003/37/EC. Based on available figures 137,000 products were sold in 
2005. 
b. The other categories defined in Directive 20 03/37 can obtain – on an optional basis as an 
alternative to national type-approval - EC type-approval for specific aspects, based on 
separate directives. Sales p.a. in 2005: T4: 15,000; T5: 13,000; C: 5,000 R: 125,000 and S: 
500,000. 
                                                
 
1  Categories: T = wheeled tractors; C = crawle r tractors; R = trailers; S = towed machinery 
2 OJ L 171, 9.7.2003 
3 http://ec.europa.eu/enterprise/automotive/ pagesbackground/compe titiveness/cars21.htm 
4 http://ec.europa.eu/enterprise/automotive/pagesb ackground/competitiveness/ cars21finalreport.pdf 
 
EN 5   EN c. Tractors are to a large extent produced by large manufacturers with multinational 
operations, while only a few are SMEs (with the exception of e.g. T4.1 (high-clearance 
tractors), which are produced virtually all by SMEs). In the category of  trailers (R) and to 
some extent also towed equipment (S) there are many SMEs. No figures on SMEs are available (see annex 2). Some categories are mos tly used in specific regions/areas: crawlers 
(C) especially in ES, IT, EL, FR; low-clearanc e tractors (T4.3) in mount ains (AT, CH, IT).  
d. Users: 1. farmers, with or without  personnel – most or all are SMEs.  
2. a large sector of contractor s: companies working for farm ers to provide for specific 
services, on each farm usually a limited num ber of days p.a. They are mostly using 
specialized (larger) equipm ent, like harvesters and fast tract ors (T5). Contractors generally are 
SMEs (typically about 10 staff on average). 
 This simplification exercise has been planned in the “Commission seco nd progress report on 
the strategy for simplifying th e regulatory environment”
5. 
                                                 
5 COM(2008) 33 final, 30.1.2008, proposal n°47, p. 31. 
 
EN 6   EN SECTION 1: PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. Organisation and timing 
Apart from its planning in th e simplification strategy, this proposal forms part of the 2009 
Commission Legislativ e and Work Program6 and is scheduled in the Commission’s Agenda 
Planning under the reference 2009/ENTR/001. 
A Roadmap has been established for this propos al, including an impact assessment, and has 
been inserted in the Agenda Planning. An Im pact Assessment Steering Group, consisting of 
interested Directorate-Generals was set up and met on 26 March 2009.  
The impact assessment was presented to the Commission’s Impact Assessment Board (IAB) 
on 13 May 2009. This version of the impact asse ssment has been amende d to respond to the 
comments of the IAB. In particular, implications  of the preferred options have been further 
detailed, as well as the positions of stakeholders; information on the markets for agricultural vehicles has been added; criteria for comp arison have been amended; consequences for 
health, safety and environment have been spel led out; some editorial errors were corrected. 
TRL Ltd. was contracted as exte rnal consultant in order to deliver an extended Impact 
Assessment study, while a public consultation took place to gath er stakeholders’ opinions. 
1.2. Public consultation 
An open public consultation was run from 3 July 2008 to 12 September 2008 with the specific 
purpose of seeking stakeholder opinions on key as pects of the simplification of the provisions 
relating to type-approval of agri cultural vehicles. In particular, stakeholder views were sought 
regarding the choice and format of the co ming legislation, on the completion and the 
mandatory nature of the type-approval system, and on its scope and coverage.  
The public consultation was: targ eted at those groups that w ould be most affected by the 
proposals, including type-approval authorities in Member States, manufacturers, suppliers and 
consumers; published on a specific website created for the purposes of the consultation
7; and 
published in English, French and German. The consultation document was also announced on 
“Your Voice in Europe” and sent directly to parties known to be interested in the policy.  
The Commission has acknowledged the receipt of all stakeholder responses to the 
consultation, and these have been made publically available. 8  
The Commission has analysed the comments made during the consultation and a full 
summary of these can be found on the DG Enterprise and Industry website.9 Further details 
regarding the consultation can also be found in Annex 1.  
The written consultation was discussed in 2008  in a meeting of the Commission's Working 
Group on Agricultural Tractors (WGAT) to which al l relevant stakeholde rs were invited, and 
supplemented by an impact assessment study (see section 1.3). The general attitude was 
positive, but with differing opinions on specific i ssues (i.a. on whether type-approval should 
be mandatory for all categories). 
The public consultation met with the Commi ssion’s minimum standards for consultation. 
                                                 
6 COM(2008) 712 final, Commission Legislative and Work Programme 2009. Acting now for a better 
Europe , 5.11.2008, p. 17. 
7 http://ec.europa.eu/enterprise/automotive/consultation/agricultural_vehicles/call.htm 
8  http://ec.europa.eu/enterprise/automotive/cons ultation/agricultural_vehicles/contributions.htm 
9  http://ec.europa.eu/enterprise/automotive/co nsultation/agricultural_vehicles/summary.pdf 
 
EN 7   EN 1.3. External expertise 
An impact assessment study ran from Sept ember 2008 to March 2009 with the aim of 
evaluating the economic, social and environm ental impacts of the proposals relating to 
agricultural vehicles. In part icular, the study focused on the simplification of the existing 
type-approval system and the de velopment of type-approval legi slation where it does not exist 
for certain vehicle categories. 
 
The following statement by the contractor is  to be noted: “The confidence in the 
estimates could be improved if additional responses and data were available from 
stakeholders. The lack of data has meant that some of the es timates made in this impact 
assessment have relied heavily on assumption s made by TRL or on anecdotal evidence 
from stakeholders.”   
 
Annex 2 gives a description of the tasks (t o be) performed and the methodology used by the 
contractor. 
 
EN 8   EN SECTION 2: POLICY CONTEXT , PROBLEM DEFINITION AND RIGHT TO ACT  
2.1. Policy context 
Type-approval of agricultural vehicles has su bstantially evolved over the past thirty-five 
years: its nature has moved from being a system designed to allow free trade between 
Member States to a system based on compulso ry whole-vehicle type-approval (WVTA) for 
most categories of vehicle. This system now aims  to provide a high level of health, safety and 
environmental protection. Initially, after the adoption of Council Dir ective 74/150/EEC, the 
type-approval of agricultural vehicles was applied only to agricultural tractors fitted with pneumatic tyres having a design speed of less than 25 km/h. Since that time agricultural 
tractors, trailers and towed equipment have typi cally increased in size, weight, and technical 
complexity. In addition, many are now capable of much greater speeds, the distance they 
travel on public roads has increas ed, and differing agricu ltural traditi ons in different countries 
has led to greater diversity in designs. 
Directive 74/150/EEC has been replaced  in 2003 by the new Framework Directive 
2003/37/EC, inter alia exte nding the scope to include  trailers and towed e quipment. In parallel 
a set of requirements has been developed fo r Non-Road Mobile Machinery, with Directive 
2006/42/EC covering safety aspects. This di rective will enter into force on 29 December 
2009. In principle the two directives deal with  different products (agricultural vehicles 
respectively non-road mobile mach inery) but in practice some c ould be classified in both. 
When the machinery directive was adopted it wa s agreed that, for the time being, agricultural 
and forestry tractors would fall under this dir ective too for those risks not covered at that 
moment by the type-approval system. The Co mmission then committed to prepare the 
necessary proposals to eliminate the overlap between the systems thus created, to be adopted 
in Comitology in 2009. 
Some of the separate technical Directives fo reseen by the Framework Directive have not yet 
been fully adapted to this important technical progress: in those directives, requirements for 
some vehicles remain optional and therefore,  no EC whole vehicle t ype approval can be 
issued for these vehicles and the internal ma rket for these vehicles is therefore still 
incomplete. In the absence of uniform Eur opean standards being, Member States have 
imposed their own mandatory requirements and these often differ widely from one Member 
State to another. 
Moreover, where no common standards exist at EU -level, cultural and traditional differences 
between farmers in different Member States may lead to different user  preferences. Any of 
these factors can result in a fragmentation of the internal market for industry, i.e. manufacturers having to adapt part icular types of vehicles to pr ovide different specifications 
for the sale in different Member States, thus  potentially increasing complexity and cost. For 
example, some Member States require ABS (a nti-lock braking) on fast tractors (T5 – 
maximum speed over 40 and up to 80 or more km/h);  one requires the front axle of a tractor to 
be connected for the purpose of braking in cer tain conditions, others do not; requirements on 
marking plates differ;  anothe r has no type-approval system at  all for agricultural vehicles 
other than T1-T3; maximum axle loads are di fferent between countries; a Member State  
notified various requirements for T4.1, T4.2, T4.3, C1, C2 and C3 tractors (requirements on 
stability, roll-over protection, driv er seat, noise etc.); in some Member States braking systems 
are hydraulic, in others pneumatic. 
 
EN 9   EN 2.2. Problem definition 
The Commission has identified thre e key problems associated with the current provisions for 
the type-approval of agricultural vehicles: 
2.2.1. A Lack of Legal and Regulatory clarity and burdensome management 
It has been pointed out to the Commission that the existing system for agricultural vehicles is 
too complex and that there is therefore scope for simplification and international harmonisation. At the same time, the completion of the internal market for agricultural 
vehicles could be done, by proposing to define the requirements which are currently lacking 
for some categories, despite that the Framewor k Directive in principl e provides for EC whole 
vehicle type-approval for these categories. It is understood that this proposal does not suggest 
to increase the stringency of any existing technical requirements; where requirements are 
introduced for non-regulated categories / aspects,  these should be at a level comparable to 
existing ones, suitably adapted to the cate gory. The specific case of new requirements for 
braking of all vehicle categories will be  dealt with in a separate IA study. 
Agricultural vehicles currently have to comp ly with a series of requirements found in a 
number of separate Directives. The Framework Directive is linke d to 23 technically detailed 
Directives, which have themselves been amende d by 36 amending Directives, so as to ensure 
that they accurately reflect t echnical progress (for example, by applying stri ngent noise and 
exhaust gas requirements, higher maximum speeds and improved ro ll-over protection 
systems). For formal reasons all these separate  publications stand on their own and must be 
applied individually. 
In addition to this, many directives contain references to international regulations and 
standards, such as those from the UNECE, wh ich are subject to amendments. Ultimately, the 
disparate nature of regulations relating to type-approval of agricu ltural vehicles leads to a lack 
of legal and regulatory clarity. Industry and regulators must be familiar with some 60 
directives, and ensure that they are aware of  and apply any amendmen ts to international 
standards. This can be a burdensome process and resu lts in additional costs for 
administrations and industry. Fo r industry, it has been  indicated that the compliance cost for 
type-approval has increased due to this regulat ory complexity and uncertainty. This situation 
is particularly a problem for SMEs which operate on this market. 
The type-approval system is generally recognised  as an effective framework to tackle various 
aspects (road and occupational safety, environmen t). However, national authorities in charge 
of the correct applica tion of the Framework Directive ar e facing unnecessary additional costs 
in their attempts to operate in this complex regulatory fram ework. Many stakeholders have 
called upon the Commission to simplify the regulat ory framework in order to obtain a less 
burdensome and less time consuming approach to type-approval. 
2.2.2. Resource-intensive transposition without adding value 
The Framework Directive and its separate Directiv es provide for the technical requirements to 
be complied with when granting EC type-approval . Both the enacting terms of the directives 
and their annexes are highly detailed and leave practically no room fo r discretion of Member 
States when transposing them. Thus, some Member States simply make direct reference to those Directives, while others develop a completely new legislative text that is meant to 
correctly transpose those requirements.  
Nevertheless, amending Directives have to be transposed by Member States, and this has led 
to difficulties for EU manufacturer s, as national transpositions may slightly differ for example 
concerning dates of publication and entry into force and even (mis-) interpretations with 
 
EN 10   EN regard to the substantive requirements, leading to unclarity between t ype-approval authorities. 
This problem is inherent in any EU legislation adopted in the fo rm of a Directive, but it is 
particularly prominent in this case where the re quirements are highly technical, very detailed, 
and likely to be very frequently  amended due to frequent adap tations to technical progress. 
Transpositions are then using resources in na tional administrations without adding any value 
in terms of safety or environment protect ion. Additional administrative resources are 
consequently required to solve such problem s of interpretation, which happen on a regular 
basis in the so-called Type-Approval Authoriti es Meeting (TAAM) where representatives of 
Member States and the Co mmission services meet.  
2.2.3. Functioning of the internal market 
Requirements under the Framework Directive ar e mandatory since 1 July 2005 for all new 
types of tractors in categories  T1, T2 and T3, and are mandatory  for all new tractors in these 
categories from 1 July 2009 onwards. For the remaining categories of vehicles (T4, T5, C, R and S) EC whole vehicle type-approval is not ye t mandatory; today it is optional for certain 
categories; the manufacturers may choose. For ot hers, not all special requirements have been 
harmonized at EU-level yet, thus, EC whole ve hicle type-approval is not yet available. The 
Framework Directive provides in Annex II Chapte r B a table listing the requirements that are 
to be specified in the separate Directives, and will be necessary for obtaining EC type-
approval for the different  vehicle categories. In most cases , existing directives for categories 
T1-T3 cannot be directly applie d to the remaining categories. This is because the test 
procedure is not adequate (e.g. caterpillar or “crawler” tractors ordinarily have no steering 
wheel but two handles, used to accelerate, stee r and brake and there is no adequate test 
procedure for such a system under the present di rective), or different limit values must be 
defined for those categories. 
Consequently an EC whole vehi cle type-approval cannot presently be granted to these other 
categories. A regulatory framewor k harmonised at the European le vel is thus lacking for these 
categories, preventing the realisation of the in ternal market until each of these technical 
requirements have been harmonized for the vehi cle categories for which this has not been 
done so far. As such a process would be par ticularly resources and time consuming for both 
EU and national administrations, the question is raised whether the completion of the 
mandatory EC whole vehicle type-approval is n eeded for these categories, and whether it can 
be done in a simplification exercise.  
The absence of (some) EU harmonized technica l requirements can be explained as follows:  
in 1970 the EC started with its regulatory work, with priority  for automobiles and production 
in large series, completed in 1992 with the re vision of the relevant Framework Directive 
70/156/EEC: the package became mandatory for passenger cars. In 1974 a similar system was set up for (wheeled) tractors: Directive 74/150/ EEC. This was partially completed with the 
new Framework Directive replacing Dir ective 74/150/EEC and making Type-Approval 
possible (and mandatory) for the main categories of  tractors: T1, T2 and T3 (80% of tractors 
market). As of today, the full series of related specific directives is not completed due mainly to lack of capacity in combina tion with the lack of priority and urgency (for stakeholders), 
even if the most complex and high priority issues like exhaust ga s emissions have been 
covered and updated by the legislation for all categories, while others, like braking, are 
currently being addressed for completion and updating. Braki ng proposals should be covered 
in implementing legislation, updating existing re quirements and adding such for categories 
not covered in the old directive. A separate  IA is planned for this subject in 2009/2010. 
 
Directive 2003/37/EC provides for mandatory  EC whole vehicle type-approval  in article 23 
 
EN 11   EN 1 for all categories, some time after completion of  all the necessary separate directives: 3 years 
for new types, 6 years for all new vehicles. 
 
Annex 6 gives the overview of the specific directives needed according to 2003/37.  
A further consideration to be taken into account  when choosing between different alternatives 
is whether completion of the EC whole vehicle type approval system wo uld be too costly for 
SMEs like trailer manufacturers and end-users, if it would be on a mandatory  basis. One 
alternative could be to complete the set of requirements but leave w hole vehicle type-approval 
optional  (the choice being for the manufacturer) fo r those categories, thus allowing full EC 
whole vehicle type-approval (or component type-approval) for t hose -larger- industries who 
can benefit.  
A drawback is that Member States may need to maintain a set of national rules and 
requirements, in parallel to the EC Regula tion now being proposed. It should also be 
considered whether mandatory EC whole vehicl e type-approval is desi rable for reasons of 
safety or environmental protection (the more so, since exhaust gas requirements are already 
mandatory for all tractors). 
 
2.3. Community competence and subsidiarity 
Prior to the establishment of an EC type-appro val for agricultural vehicles, regulations were 
established at Member State level. This legi slation set by Member States often differed and 
manufacturers selling on several markets were then obliged to vary their production according 
to the Member States for which their products we re intended and had their vehicles tested in 
every Member State, which was time consum ing and costly. Different national rules 
consequently hindered trade, and had a negati ve effect on the estab lishment and functioning 
of the internal market. 
It was, therefore, necessary to establish stan dards at the EU level. The Framework Directive 
2003/37/EC, based on Article 95 of the EC Treaty, was designe d to do this and aims at 
establishing an internal market while ensuri ng a high level of protec tion concerning health, 
safety and environment. Such a rationale is s till valid today as Communi ty action is necessary 
to avoid fragmentation of the internal market  and to ensure a high and equal level of 
protection across Europe. Any change to this regulatory framework will be assessed in its compliance with the principle of subsidiarity as  established in Article  5 of the EC Treaty. 
S
ECTION 3: OBJECTIVES  
3.1. Overall objective 
One overall objective is the exercise of simplif ication which is a response to the commitment 
of the Commission to act in accordance with th e principles of Better Regulation. This overall 
objective can be subdivided as described in 3.2. and 3.3. hereafte r. Simplifying the regulatory 
framework of the type-approval of  vehicles is furthermore in line with the recommendations 
of CARS 21, which gathered expectations of various stakeholders. Applying now this process 
to agricultural vehicles aims at addressing the problems identified by the Commission on the 
basis of the stakeholder consultation. The si mplification exercise has thus as general 
objectives the reduction of the legal unclarity, the dele tion of resource-intensive 
transpositions, and a move towards a better covera ge of these agricultural vehicles by the EU 
type-approval system. 
 
EN 12   EN A second overall objective is to make the free  movement of goods in the internal market 
possible by completing the type-approval system fo r all categories of agricultural ad forestry 
vehicles. 
3.2. Objective 1: Simplification of existing  acquis (by repeal of existing directives) 
The simplification exercise aims at addre ssing the complexity of using a Framework 
Directive, 23 detailed technical Directives , 36 amending directives and a whole corresponding 
set of transpositions into national legislations and assessing which regulatory approach could allow less time-consuming and less burdensome ad aptations to technica l progress. A clearer, 
better structured and coherent legislation would also be in line with the Better Regulation 
commitment, which is an important objective for the Commission. 
3.3. Objective 2: Improved regulatory capaci ty for future acquis (by new split-level 
regulatory approach with use of referen ces to international standards) 
Another part of the simplification exercise is the elimination of technical specifications in EC 
Directives by replacing them by references  to standards set by  other international 
organisations such as the UNECE, OECD, CEN/CENELEC and ISO
10, which are widely 
accepted inside and outside the EU. Direct referen ces to them are already used in the existing 
type-approval legislation, often as alternatives. Those standard s are not made mandatory, but 
the manufacturer may opt for compliance with t hose standards instead of the requirements set 
by the EC directly. 
Through these references, duplication of techni cal requirements is created in the EU 
legislation and among regulations  and standards of these inte rnational organisations. The 
second objective of simplification is thus to see how these duplications can be reduced in 
order for stakeholders to not be confronted wi th several sets of requirements addressing the 
same aspects.  
It must be emphasized that this is an exerci se of simplification only, and that no change in 
technical requirements should be introduced by us ing references to inte rnational standards. 
Such references would in principle only be us ed if the level of safety or environmental 
protection of those international standards is the same as the one  of the EC Directives, and no 
loss in safety or environment protection levels is foreseen. 
3.4. Objective 3: Completion of the single market 
The EC whole vehicle type-approval system unde r the Framework Directive is not mandatory 
for categories T4, T5, C, R and S, but according to the text of the di rective manufacturers can 
voluntarily apply for EC (whole vehicle) type -approval for vehicles of these categories. 
However, technical requirements for thes e categories have not been established11 yet for many 
of the aspects and the option to obtain an EC whole-vehicle type-appr oval remains therefore 
theoretical, despite what is provided in the di rective: vehicles of th ese categories can only 
obtain a whole vehicle type-appro val under national legislation. It follows that in order to 
obtain access to the different national markets,  the same vehicle may need a whole-vehicle 
type-approval from several Member States. The simplification exercise is an opportunity to 
complete the EU regulatory framework for these categories of vehicles , so that they can 
benefit from a single EU system which gi ves access to the whole European market. 
                                                 
10  United Nations Economic Commission for Europe; Organisation for Economic Cooperation and 
Development; CEN, the European Committee for Standardisation, and CENELEC, the European 
Committee for Electrotechnical Standardisation; International Standardisation Organisation. 
11  Chapter B Part I of Annex II of 2003/37/EC provides with the list of requirements under the specific 
directives, and requirements which still have to be defined are marked with the symbol “(X)”. 
 
EN 13   EN SECTION 4: POLICY OPTIONS  
For these objectives the follo wing options were evaluated. 
4.1. Simplification I: Simplification of existing acquis (by repeal of existing 
directives 
a) Option 1: No policy change 
No change would be made to the current re gulatory framework: the Framework Directive 
would still define the EC type-approval system, while technical requirements would still be established under separate Directives, which re quire transposition into national legislations. 
Amending directives would also require transposition through national acts. The Commission will have to continue to  monitor transposition. 
b) Option 2: Replace the current framework by two regulations The Framework Directive, the 23 technical Di rectives and their 36 amendments would be 
repealed. A new Mother Regula tion adopted by co-decision w ould contain the fundamental 
requirements of the EC type-approval system, while all detailed techni cal requirements would 
be gathered into a single implementing regulat ion, to be adopted and more easily updated in 
the future through the comitology procedure. 
c) Option 3: Replace the current framework by a limited number of thematic 
regulations 
Same as option 2, but the detailed technical requirements would be gathered into e.g. three 
thematic implementing regulations adopted by comitology procedure. Requirements could be 
grouped by coherent blocks und er environmental aspects, road safety aspects, and 
occupational safety aspects
12. 
For both Option 2 and Option 3, beyond the im plementing regulations mentioned before, 
further implementing acts would be  needed in order to  establish or modify  certain annexes of 
the mother regulation containing detailed requirements for a pplication forms, information 
folders, numbering systems, templates for ap proval certificates and other technical and 
administrative details which should not be adopted by the co-legislator, but by the 
Commission, using the comitology procedure.13 In practical terms this means that these acts 
could after all be integrated in the main Regulation.  
 
4.2. Simplification II: Improved regulatory ca pacity for future acquis (by new split-
level regulatory approach with use of references to internat ional standards) 
a) Option 1: No policy change 
No change would be made to the current fram ework, requirements and test procedures having 
to be followed as required unde r the 23 separate Directives. 
b) Option 2: Use when possible re ferences to UNECE Regulations 
Similar to what has been introduced for moto r vehicles in the General Safety Regulation 
(GSR), if equivalent technical standards have  been defined by UNECE, the provisions of EC 
                                                 
12  At this stage, the exact number of implementation Regulations has not been fixed yet. 
13  Cf. Regulation 1060/2008, replacing certain annexes of the framework directive (2007/46/EC) for 
motor vehicles; OJ L 292 of 31.10.2008. 
 
EN 14   EN Directives should be repealed a nd replaced by a reference to these international standards. 
This option could take different fo rms which have to be assessed: 
- Full references, where the text is fully copied and published by EU  
- Simple fixed (static) references, wher e the EC legislation links to a dated 
international regulation 
- General (dynamic) references, where the EC legislation links to a regulation of an 
international standardisati on body, but without da ting it: this woul d allow opening 
up  to updates of these technical requirements. 
From a point of view of legal certainty and control over EU le gislation the latter 
possibility (dynamic reference) seems unaccep table; stakeholders agree on this. As a 
consequence this is not further analysed. It is intended to maintain the existing 
reference to motor vehicle directives, as far as  they will continue to exist in the light of 
developments under the General Safety  Regulation for those vehicles.  
c) Option 3: Use references to al l relevant international standards 
Similar to option b), but now reference to OECD, CEN/CENELEC and ISO can be applied. 
OECD has introduced so called Codes for Ro ll-over Protection Systems, which are not 
available from UNECE; for othe r issues only standards from CEN/CENELEC or ISO exist.  
In the table in annex 6 a preliminary indication is given of the international standards that 
could be used. This needs verification during the development of implementing legislation. 
 
4.3. Completion of the single market 
a) Option 1: No policy change 
No change would be made to the scope of th e Framework Directive, the EC whole vehicle 
type-approval remaining optional,  but de facto not available14 for categories T4, T5, C, R and 
S. Without any adaptation to technical requi rements, the different  national type-approval 
requirements will have to be complied with in  order to obtain national type-approvals and 
have market access in different Member States of the EU. 
b) Option 2: Complete  the EC type-approval requireme nts and make EC type-approval 
mandatory  for all categories of vehicles 
The EC type-approval legislation will be comp leted for the categories not (fully) covered 
today. The missing technical compliance requirements for certain elements would be filled in. EC whole vehicle type-approval would be made mandatory  for all categories presently 
covered by the Framework Directive, which mean s that vehicles from categories T4, T5, C, R 
and S would no longer have to pass national type-approval pro cedures: they should only fulfil 
requirements of EC type-approval and then gain access to all markets. 
c) Option 3: Complete  the EC type-approval requiremen ts and leave EC whole vehicle 
type-approval optional  for certain categories  (T4, T5, C, R and/or S) 
Like in option 2, the EC legislation would be  completed, but the EC whole vehicle type-
approval would remain optional for those catego ries. This would allo w a manufacturer the 
choice between a national approval per Member St ate or an EU whole vehicle type-approval, 
the latter at probably higher cost s but with the benefit of dire ct accessibility to the whole 
                                                
 
14  Cf. the explanation given under point 2.2.3. above. 
 
EN 15   EN internal market. The manufacturer would have an incentive to choose th e profit maximising 
solution. 
An alternative would be, as suggested by many stakeholders, to make certain requirements 
mandatory within this option. Some subjects mentioned are: braking, lighting and markings. 
This would harmonise those aspe cts within Europe and bring im portant road safety aspects up 
to a shared certain acceptable (minimum) level. For all tractors this already is the case for 
exhaust gas emissions requirements. 
 
EN 16   EN SECTION 5: ANALYSIS OF IMPACTS  
5.1. Simplification I: Simplification of existing acquis (by repeal of existing 
directives) 
a) Option 1: No policy change 
Considering the positive side of no change in policy, it can be stated first that avoiding to 
change the whole regulatory fram ework will save the administrati ve cost necessary in national 
administrations to establish the new Regulatio n and repeal the current  national legislation 
transposing the Directives. The extended imp act assessment report presents the saving of 
€ 909.225 (average of values given by resp ondents; range from € 18.225 to € 3.653.100, 
caused by differences in legal systems in Member States; see TRL report paragraph 4.1.2) for this change in the 27 MS. This co st would be avoided if option 1 is chosen. If a look is taken 
at medium and long-term effects, this positiv e aspect is neverthele ss weakened, because the 
annual cost of managing the current regulator y framework in the 27 MS is estimated at 
€ 533.993 (range: € 29.160 to € 2.435.400; TRL repor t paragraph 4.2.1.1), while it would be 
at € 128.912 with a new Mother Regulation and an implementing Regulation. This situation 
can be explained by the different manageme nt requirements used by Member States 
administrations between the two legislative format s: an annual average cost per Member State 
of € 19.778 in order to reflect th e changes to Directives in th eir national legislation can be 
compared to an annual average of € 11.858 for changes to implementing Regulations. Due to this difference, it can be calculated that the initial cost would turn to be beneficial from a cost/benefit point of vi ew after a foreseen period of 3 years. 
Apart from this budgetary point of view, the simplification process and replacement of the 
current framework Directive by a Regulation has not been oppos ed by stakeholders during the 
public consultation. Stakeholders welcome the simplification exer cise and consider that the 
choice of a Regulation is a proper step on this wa y. But several actors, in  particular industry, 
stress the need to deal firstly with ot her matters, considered to be more urgent
15, before using 
time to tune the legal format of the regulat ory framework. These actors underline that the 
simplification exercise should not delay such urge nt dossiers. The shift to a Regulation is thus 
not opposed by stakeholders, but not deeply suppor ted because of this scepticism on timing. 
This can be considered as a positive point for option 1, but it assumes that delays will indeed be introduced for dealing with current matters. The Commission services intend to tackle both aspects in parallel, using the comitology proce dure (CATP-AT) to tackle urgent issues, in 
order for this negative input of  the regulatory modification to be  limited as much as possible. 
This impact can thus be considered as limited.  
b) Option 2: Replace the current framework by two regulations Replacing the Framework Directive and its set of 23 technical Directives (and 36 amending 
Directives) by one co-decision Regulation and one Regulation by comitology is proposed as 
an exercise of simplification. The proposal to apply simplification to agricultural vehicles 
responds to a clear demand coming from stakeholde rs in the public consultation, but also from 
the European Parliament, where several Member s have expressed criticisms on the pointless 
complexity of the format of the current le gislative framework, and asked the Commission to 
take measures to tackle this situation. 
                                                
 
15  One of these issues is to take agricultural tr actors out of the scope of  the Machinery Directive 
2006/42/EC. 
 
EN 17   EN As mentioned above, replies from stakehol ders during the public consultation have 
highlighted that a shift to a Regulation was welcomed as a simplification exercise. This 
proposal has also received th e support of Member States representatives during the 83rd 
meeting of the Working Group on Agricultural Tractors, held on 21 November 2008. It must 
be stressed that in both cases the support is dependent on the format of the Regulation, which 
has to be of a split-level nature . Both Member States and industry insisted on the necessity of 
this approach: the functioning of the type-a pproval system, its scop e and its fundamental 
requirements have to be included in the Mother Regulation decided by co-decision, while detailed technical requirements have to be contained in implementi ng legislation adopted 
through comitology procedure. Such a split-lev el approach allows a quick process of 
adaptation to technical evolution in the future. Commission servic es are aware of this demand 
and therefore intend to use this approach. The support for this format is  thus a positive point 
for this option. 
As far as administrative costs are concerned, th e choice of such a format can be considered 
positive as well, because transpositions in natio nal legislations will no longer be needed, and 
the Commission will also no longer be responsib le for a time consuming scrutiny of these 
transpositions. Both national and EU administrati ons will thus benefit from this new format. 
As explained with figures in op tion 1, the cost of replacing the regulatory framework is quite 
high (estimated at € 909.225), and this cost  is a clear negative point for option 2.  But taking a 
medium and long-term view (more than 3 years), the shift appears to be beneficial, and is then 
a positive point, which is well in line with the objective of simplifi cation and reduction of 
administrative burden. 
c) Option 3: Replace the current Directives by four Regulations 
The cost/benefit analysis did not  show significant differences between cost to implement and 
operate one or three implementing Regulati on(s); this reflects the view taken above
16 that the 
difference between options 2 and 3 is small.  
Actually, the exact number of implementing Regulations, setting tech nical requirements via 
comitology procedure, is not yet fixed. It is proposed to group these provisions by themes, 
like road safety, occupational (work) safe ty, and environmental protection aspects. 
Nevertheless, additional categorie s could be added, for example one  for braking requirements.  
This proposal should be seen as a generalisatio n for the simplification exercise, in order for 
technical experts in comitology to deal with sets of coherent gr oups of issues. This division is 
thus purely practical, intended to plan the adopt ion of the requirements, but will not indeed 
affect the requirements themselves. Such an approach using several sets of implementing 
Regulations is also seeking to increase th e clarity of the regulatory framework for 
manufacturers which have to comply with it to obtain type-approval. It would be particularly 
the case if it is foreseen to choose the option of mandatory EC type-approval for vehicles in 
categories R and S, covering only aspects relating to  road safety. This clarity for industry is an 
important benefit of the simplification exercise , considering in partic ular SMEs which have 
limited administrative resources to deal with complex regulatory requirements needed to obtain type-approval. This op tion for providing a clear and logical structure has been 
supported by industry representatives, for example during the stakeholders workshop 
organised by TRL on the 21 November 2008. 
A negative aspect of using one  implementing Regulation can be  the length of  processing: 
agreeing on one text including all requirements would indeed take a lot of time for the 
                                                
 
16  Cf. point 4.3.  
 
EN 18   EN committee, which may need to involve differe nt experts depending on  the aspects covered. 
The positive side of grouping th e requirements is the facilita tion and rationalisation effects 
provided, by allowing expe rts to deal more coherently with aspects related to similar, limited 
objectives. And the timing issue can be minimised as implementing measures will be prepared 
in parallel to the co-decision process, allowi ng them to be adopted in a short term. The 
decision to go for one or a particular number of implementing Regulations should be agreed 
with the comitology committees. 
It must be kept in mind that two issues have  to be distinguished: one is the number of 
regulations to be adopted, the other one is the number of regulations fi nally obtained. What is 
intended to become one (Mother) Regulation co uld be adopted in several stages, with one 
original (basic) regulation which is later on  amended by other regulations. Thus, while the 
legislative process could be split up for practical reasons, the number of legal instruments obtained in the end could still be very small. This might well be the most suitable answer to the different pros and cons deliber ated in the preceding paragraph. 
While the difference between Option 2 and Opti on 3 is rather small, the difference from 
Option 1 is major. By moving from directives to the legislative inst rument of regulations, 
options 2 and 3 would do away w ith the need for transposition on the side of Member States 
and the need for transposition control on the side of the Commission, and all discrepancies 
between national transposition acts  would be avoided. With the in troduction of th e split-level 
approach, the co-legislator could concentrate on issues which must be decided by Council and 
Parliament, while delegating t echnical and administrative deta ils to the Commission without 
losing control (the regulatory procedure with scrutiny would be  the applicable comitology 
procedure, which ensures final control of the co-legislator also  for comitology acts). 
 Position of stakeholders Member States: some expressed preference for Re gulations for faster a nd clearer legislation 
(DE, FR, FI, UK), none were against. NL: could accept, but fears additional administrative costs. Only one ministry was in favour of New Approach directives. Some  expressed that this 
project should not dela y prioritary work on sp ecific other proposals. 
Industry: CEMA agreed with a regulation; scop e should be clear and ag reed in co-decision. 
No opinion was expressed on the number of Regulations to be used.  
5.2. Simplification II: Improved regulatory ca pacity for future acquis (by new split-
level regulatory approach with use of references to internat ional standards) 
a) Option 1: No policy change 
Regulations of the UNECE, under the 1958 Agreem ent, are widely rec ognized in countries 
inside and outside the EU, and the EU has itsel f acceded to a lot of them. A similar situation 
takes place with standards produced by other international institut ions, such as OECD, 
CEN/CENELEC and ISO. Many provisi ons of EU Directives relate to these standards, and as 
a result manufacturers whose types of vehicles  comply with their requirements can gain 
access to EU and various other markets using these same requirements. In practice, a 
manufacturer usually selects among those organisations the si ngle most appropriate approval 
standard in order to get approval for a component  or a type of vehicle. This promotion of 
international standards is thus supported by indus try. But in the current situation, provisions 
are often duplicated in the Eur opean legislation, or are simila r in technical requirements but 
 
EN 19   EN differ in formal details. An example is the date  of entry into force of an amendment to a 
Directive, which usually is differe nt as a result of (lengthy) pr ocedures to update the Directive 
after e.g. UNECE introduced an amendment in  its Regulation on the same subject. This 
causes unclarity and unnecessa ry administrative burden. 
The positive point in ”no policy ch ange” is that no risk of loss in quality of requirements 
would be introduced by replaci ng provisions of EU Directives by references to international 
standards. Indeed, many respondents to the pub lic consultation have expressed their worries 
that the referencing exercise could introduce loss in safety or environmental protection. But 
the negative side of option 1 is that the uncla rity for manufacturers a nd administrations will 
remain, which is not in line with the Better Re gulation objective, in particular because the 
duplication is considered as useless in terms of safety or environment. Continuing this 
approach would thus only add additional admini strative burden on stakeholders. To reply to 
the worries about a weakening of requirements, it is stated clearly in the objectives that 
references will be proposed only in cases where the international standards are at least equal to the relevant EU Directives. This argument fo r the support of option 1 can thus be assumed 
to be non-applicable. 
 
b) Option 2: Use where possible references to UNECE Regulations
17 
This option, also applied in the General Safety Regulation fo r motor vehicles, is widely 
supported by stakeholders, as expressed in replies to the public consultation. The main 
positive point is that the legislation will be simplified by suppressing useless duplications. 
This will benefit all actors dea ling with this legislation, being national authorities responsible 
for type-approval, or manuf acturers whose vehicle types ha ve to comply with these 
requirements. This will in particular benefit the SMEs which have limited resources to be 
attributed to regulatory affairs. The extended impact assessment done by the contractor has 
tried to quantify the changes implied by the refe rences, offering a cost/benefit analysis of the 
different aspects of this shift. 
Considering the cost of type-approvals for manuf acturers, it has been estimated from previous 
studies and stakeholders’ feedback that it  would be approximately € 15.000 per type on 
average. The cost of one w hole vehicle type-approval taken individually can be above 
€ 100.000, but practically most manufacturers use a family approach, using results from one 
type to approve other types of vehicle. For example, a cab structure approved for the roll-over protective structure (ROPS) test can be used several times for different vehicle types using 
various engines and devices: the costly ROPS test  would not need to be  done again and again. 
This situation allows manufacturers to re duce costs and administrative burden. Using 
references to international st andards and repealing EC Directives dupli cating them is not 
likely to change this functioning. Manufacturers will continue to select the approval tests needed among UNECE and remaining EC standards. There will be no additional administrative or type-approval co sts. Requirements of repealed Directives will be replaced 
by equivalent requirements. There is  therefore no cost, but no direct benefit either in terms of 
cost reduction for manufacturers. The foreseen  benefit will be the simplification and the 
clarification of the regulatory framework, but this is particul arly hard to be quantified. 
Considering the cost of attendance to meeti ngs of EU, UNECE, OECD, ISO and CEN, it has 
been estimated that the average annual co st for all particip ants is € 1.135.085 (range: 
                                                
 
17  Presently 8 Regulations specific for tractors and some 12 for motor vehicles which can applied to this 
sector too. 
 
EN 20   EN € 310.536 to € 2.608.200; TRL report paragraph 4.2.1. 2). This cost is high and the 
simplification exercise could help to reduce it.  Nevertheless, Member States representatives 
indicated that the proposed changes to the current type-approval framework will not put into question the necessity for them to attend meet ings of these internat ional organisations. A 
simplified regulatory framework could thus  not claim to reduce costs for national 
administrations to this respect. Member States  which mentioned a reduction stated it as being 
very limited, and difficult to quantify. As fa r as industry represen tatives are concerned, 
stakeholder feedback suggested also that the im pact on attendance to m eetings might be very 
limited. However, even if difficult to assess, there will be a reduction. For example, if all lighting requirements were based on UNECE Regulations, with only references in EC 
Regulations, there would still be a need to atte nd meetings of both orga nisations, but the work 
in EC working groups would be reduced, because it would only be nece ssary to agree on the 
updated version of the UNECE Regulation and to change the reference in the EC Regulation. 
As a result of this situation, a reduction of up to 10 % on annual meeting costs is assumed to 
take place, which means an annual benef it of € 56.574 (average; TRL report paragraph 
4.2.2.2). This benefit will compensate the initi al cost of introducing a new Framework 
Regulation with references and repealing the cu rrent Directives (estim ated at € 533.993) after 
a few years. 
Another aspect of the quantified cost/benefit as sessment of using references to international 
standards is the reducti on of translation costs.  The annual cost for tr anslations under the 
current regulatory system is estimated at  € 55.688 (average), because amendments to a 
Directive need to be translated into all langu ages. This cost should no longer be required if 
references to international standards are used. Nevertheless this benefit would exist only if the option of fixed references is used, with only the mention of the code of the international 
standard, and not a full reference with the text of the standard fully transferred or separately 
published by EC. However, even in the case of simp le static references - which seem to be the 
most likely option - the Commission can commit to  translate the texts of these international 
standards. It is already the case for UNECE, and it has been requested for OECD Codes. 
To summarize, quantified benefits of using re ferences are limited, but costs are also very 
limited. The global assessment is that this change has a very low impact for both manufacturers and EC and MS in terms of administrative or type-approval costs. The 
cost/benefit assessment is thus slightly but gl obally in favour of thes e references. The main 
argument for this option is therefore the simp lification: a regulatory framework with more 
clarity will benefit both manufacturers seeki ng type-approval and administrations updating 
regulations to technical progre ss in an international envir onment. In addition, today the 
Commission services work on their own documents  and on those from UN ECE, OECD, etc. It 
would be much easier and more cost-effectiv e for the Commission services and for the 
representatives of Member States  in the working groups if the technical details were no longer 
duplicated in different set of legislations. 
c) Option 3: Use references to al l relevant international standards 
Similar to option b), but now reference to OECD, CEN/CENELEC and ISO can be applied. 
A certain number of subjects is dealt with in other internationa l organisations than UNECE. In 
relevant cases the EU may wish to reference those other standards, for example the OECD 
Codes on roll-over protection systems. In othe r cases we can refer to  CEN/CENELEC or ISO 
standards. 
A further difference may be caused by the infl uence of the parties involved in decision 
making; in UNECE the EU has full voting right s, which is not the case in the other 
 
EN 21   EN organisations. Also, standards from CEN/CEN ELEC and ISO are mostly about definitions 
and test procedures, but do not contain limit values for approval or rejection. 
Stakeholders from industry clearly expressed a preference to refer to ISO standards above 
UNECE and OECD. Furthermore there is an ongoing process to harmonise requirements 
between OECD and ISO, producing one single st andard for both organisations for certain 
subjects.  
In all cases of reference to in ternational standards the Regula tion should provide  that the EU 
can act independently to introduce differing amendments if necessary. 
Position of stakeholders Member States: DE, FI, FR, NL , UK favourable to the use of  international standards, 
especially UNECE and OECD, with some conditi ons (static reference; CoP requirements). 
None was negative. 
Industry: General support, with preference for ISO standards; OECD and UNECE as 
alternative. 
The idea of legislation based on New Approach  was supported by one ministry (DK); others 
were against and insisted on stic king to the existing type-appr oval system (with either a Reg. 
or a Dir.). 
 
5.3. Completion of the single market 
The baseline  (no change in policy) ha s been considered  the co mpletion of requirements on a 
mandatory basis as described in th e current Framework Directive. The preferred option (3)  
considers the  completion of all requirements, on a mandatory basis, for all tractors (for 
reasons of road and occupational safety and environment), while on an optional basis for 
trailers and towed equipment with the exception of the main road safety aspects that shall  be 
made mandatory too. It has been considered that  the  baseline will not be achieved for a long 
time and will represent a problem in particular  for SMEs it would be a problem. 
a) Option 1: No policy change Basically Directive 2003/37/EC provides for mandatory EU t ype-approval for all categories 
of agricultural and forestry vehicles (as soon as all relevant separate  Directives would be 
available). At the moment of writing this report , vehicles from categories T4, T5, C, R and S 
should in principle be able to apply for EC type-approval on a voluntary basis. In the present 
situation technical requirements for many subjects still have to be adapted for this to be 
possible. In this situation, safety objectives set at the European level are not reached, and 
these vehicles have only to comply with provi sions of national type-approval systems (as far 
as they exist). The free move ment of these goods across the European market is thus not 
possible, as a same vehicle has to be approve d in each country where a manufacturer wants to 
sell it or a user wants to use it.  For some manufacturers and some  types of product it is little or 
no problem (SME; small series for local/regiona l markets only). Larger manufacturers may 
produce larger series for many markets a nd wish to obtain EU type-approvals. 
This option requires that Member States conti nue to implement future EU Directives and 
COM shall monitor this. To agree on the applicab le technical requirements for categories T4, 
T5, C, R and S and producing such detailed Di rectives is a time consuming  and sometimes 
cumbersome procedure. 
 
EN 22   EN b) Option 2: Complete  the EC type-approval requireme nts and make EC type-approval 
mandatory  for all categories of vehicles, as intended in the present Framework 
Directive 
The expected main benefit of this option is considered to be that for society thanks to road 
casualties reduction (TRL: up to € 51 million; pa ragraph 4.3.2.8), but the statistical basis for 
this assumption is very limited.  
Going for mandatory EC type-approval for thes e categories T4, T5, C, R and S would help 
manufacturers saving costs of approving their ve hicles in the different national type-approval 
systems. Vehicles are sold on average in be tween 4 and 14 Member States, which would 
indicate much less administrative costs for ma nufacturers if only one EC type-approval would 
be needed. This would allow the development of the internal mark et of this sector, and help 
manufacturers to develop by accessing various Eur opean markets. It may be an interesting 
option when considering that mo st manufacturers of vehicles in  categories R and S are SMEs: 
these manufacturers would benefit from access to  a wider market for less administrative 
burden and costs. But it must be highlighted that this option would introduce new European 
standards replacing national ones, and that this shift could imply important costs for 
manufacturers in order for their vehicles to co mply with these new safety and environmental 
requirements. This is particularly a problem when considering that additional costs will be 
passed on to users and consumers of these vehicles, which are often SMEs: farmers, 
contractors and forestry enterprises. Establis hing new mandatory requirements at EU-level 
has thus to be well assessed, in order to be co st/beneficial and not to add unnecessary costs on 
manufacturers. During the public consultation, the wide majority of stak eholders have replied 
that a completion under certain conditions is very welcome, and option 1 is thus not 
supported, but both administrations and manufactu rers have expressed demands on how this 
completion should be made, with distinctions among types of requirements. 
As stressed by stakeholders during the public  consultation, a comple tion of the internal 
market is welcomed for these categories, and the EC type-approval system is supported as a 
good instrument for this purpose. But the mandatory  version of option 2 is  very unlikely to be 
applied: cost/benefit calculations must be done for each category, and the various aspects of 
the type-approval must be distinguished. As far as vehicles in categories C, T4, and T5 are 
concerned, stakeholders have ag reed that, considering their use on the road and their higher 
speed capabilities, they should co mply with common road safety requirements, and thus have 
mandatory EC type-approval for these aspects.  Where these vehicles are used by larger 
companies or contracting firms, the additional cost of new requirements would be borne by 
large manufacturers and is not likely to add more  costs on SMEs. For the larger manufacturers 
of these vehicles, the benefit would be less administrative co sts for type-approval, and an 
easier access to markets. 
Concerning the T4.1  category (high-clearance tractors , used in vineyards), industry 
representatives have hi ghlighted that these types of vehi cles are currently covered by the 
exemption for small series existing in pres ent the Framework Directive. The Commission 
services do not foresee modification of this ex emption. If T4.1 category is to be included in 
the mandatory EC type-approval system, those t ypes of vehicles can t hus continue to be 
approved under the small series exemption. There will be therefore no cost for this enclosure. However, opting for the mandatory EC w hole vehicle type-approval would cause 
manufacturers and administrations to pr epare the ground for common road safety 
requirements for such vehicles, in case their ma rket grows and is consolidated across Europe, 
which will impede the use of the small series exemption. 
 
EN 23   EN Concerning the T4.2  category (very large tractors), th e feedback from manufacturers 
suggested that the current situat ion offers a large variety of situations among Member States 
in terms of technical requirements and road safe ty provisions. In the meantime, these types of 
vehicles are sold across the EU (typically in  about 10 MS) which means that there is no 
common market for them and that manufacturer s and users suffer from administrative and 
design/production costs due to the different national technical  requirements. Mandatory EC 
type-approval could lead to a redu ction of the cost of design, a nd finally to a reduction of the 
final cost of the vehicle. This would be an additional benefit, together with the benefits of having a common market established for these goods. The impact on the final price has been 
assessed in order to indentify the cost/benefit analysis on users, which include SMEs. It has 
been estimated that a reduction of 2% coul d occur, which means a benefit of € 2.000 to 
€ 3.000 on vehicles of € 100.000 to € 150.000. As a bout 9.000 vehicles of this category are 
registered each year across Europe, an av erage of € 22.500.000 could be saved by users (TRL 
report paragraph 4.3.2.2). Nevertheless,  technical requirements will have to be ad apted to this 
category, because the cost of compliance would ot herwise cause an increase of price superior 
to the decrease permitted by the harmonisation.  
Concerning the T4.3  category (alpine tractors ), these vehicles fall totally under the exemption 
for small series, which Commissi on services intend to maintain. To include this category in 
the mandatory EC whole vehicle type-approval  framework will thus not add any cost for 
manufacturers or users. This exemption allows  vehicles to be type -approved by a national 
type-approval system under its specific provisi ons, and the Member State then sends to the 
Commission and to other MS the list of its approvals; other Member States decide then 
individually to accept it or not if a manufact urer wants to sell the product in such other 
Member State. 
Concerning the T5 category (maximum speed more than 40 km/h), diverging technical 
requirements are currently used across the EU, which prevent these types of vehicles from benefitting of the internal ma rket. To ask these vehicles to  meet mandatory type-approval 
requirements is likely to increase their fina l price, but this depe nds on the requirements 
selected. TRL calculated that if the requireme nts currently used by the German type-approval 
system were used for the mandatory EC whol e vehicle type-approval,  an increase of 2,5% 
(average) could be expected, which would lead to an increase in pri ce per vehicle of € 2.000 
to 4.500 on a vehicle costing typically € 100.000 to 150.000 now (TRL report paragraph 
4.3.2.4). Considering that some 13.000 vehicles of this type are registered each year in 
Europe, such requirements would cost from € 26 to 59 million to manufacturers due to higher prices. If other requirements were selected, such as mandatory fitting of ABS (as is currently required in the United Kingdom), the increase in  price would be much higher, and so would 
be the global cost on users. Commission services  consider that the EC  whole vehicle type-
approval is nevertheless a good option for the T5  category, because those vehicles can reach 
high speeds (designed for > 40km/ h, typically intended also for use on main public roads) and 
road safety is a real concern. The various provis ions in force in Member States prove that all 
Member States agree that road safety require ments are indeed needed here, and to ask for 
common requirements at the European  level is thus an opportunity to reach the benefits of the 
common market while ensuring a high level of road safety. 
Concerning the C category, these vehicles are produced  in low volumes for very specific 
markets, and therefore they all fall under th e small series exemption that the Commission 
services propose to maintain, in accordance with what both nationa l administrations and 
manufacturers have asked during the public consu ltation. In this situat ion, there will be no 
additional cost to include these types of vehi cles in the mandatory EC whole vehicle type-
approval framework. 
 
EN 24   EN As far as vehicles from categories R (trailers) and S (towed machinery) are concerned, a 
different assessment must be used. These vehicl es are produced and bought  directly mainly by 
SMEs, which would bear the costs of new requi rements. Stakeholders are divided about the 
necessity to make the EC w hole vehicle type-approval manda tory for these categories. 
Nevertheless, these vehicles are being used on public roads, and are sold across the EU in 
very high numbers (estimation of 625.000 vehicl es for EU-25 in 2005). To require European 
road safety provisions for them is thus a policy option supported by the majority of 
stakeholders during the public consultation, be ing associations of users or governmental 
organisations. Commission servic es consider that mandatory EC whole vehicle type-approval 
for these categories could thus be introduced, but that this would be don e only for road safety 
aspects.  
This approach respects opinions expressed by stakeholders. Other aspects such as work safety 
are considered as sufficiently well covered by  other European legislations, such as the 
Machinery Directive. Moreover, the majority of  replies from national administrations state 
that for other aspects than road safety these vehicles are produced for specific regional needs which would be very difficult to cover with ha rmonised requirements at the European level. 
To choose a regulatory action would therefore not be  in line with the subsidiarity principle. In 
addition, Commission services agr ee with the various stakeholde rs who expressed the opinion 
that exemptions such as included in the current legislation should be maintained. Small series 
and individual approvals will t hus remain type-approved at the national level. Exemptions 
stated currently under Art. 2.2 of the Framework Directiv e will also be maintained, as 
demanded by stakeholders. 
Concerning the R category, for which common technical requirements are currently missing, 
it covers a wide variety of trailers, ranging from large sta ndardised productions to very 
specific vehicles used for particular works. So me of the specific produ ctions would fall under 
the small series exemptions, defined in Annex V Section A of the Framework Directive, but 
the number authorised is smaller: 75 units inst ead of 150 units for the T categories. (This limit 
is set as the number of vehicles registered, offered for sale or put into service each year in 
each Member State.).  
It has been estimated that common requirements for road safety (signs, lighting, braking etc.) 
would allow a harmonisation of design for a ll markets, which would lead to a better 
integration of these road safety devices on the vehicles, but also to a reduction of their final 
price. This reduction is estimated at 2 to 3 %, which means a decr ease of € 200 to 900 on a 
vehicle of between € 5.000 and 30.000 (TRL report paragraph 4.3.2.6). Over a number of 125.000 units registered per year in the EU, there will be a benefit of € 68.750.000 (average) 
for buyers of these vehicles, which are ofte n SMEs. Manufacturers w ill also gain from 
common requirements, which will prevent them to ad apt the safety devices of their vehicles in 
a badly integrated way, only in order to comply w ith the variety of national rules. It will thus 
simplify their design and produc tion, as well as the functioning of their stocks and their 
logistics. Finally, asking for mandatory applic ation of common road safety requirements will 
benefit to all citizens, as thos e vehicles are sold in high vo lumes and do circulate on public 
roads. To complete the internal market by setting common European road safety requirements is thus an option foreseen by Commission services , and it has been supported by a majority of 
stakeholders during the public consultation. 
The current technical requirement s are nevertheless not adapted to  the category R. It has been 
estimated by a stakeholder that to comply w ith all current requirements of the EC type-
approval framework would lead to  an increase of € 3.000 of the pr ice per vehicle. This cost 
would be borne by buyers of these vehicles, am ong which there are many SMEs (farmers and 
 
EN 25   EN small forestry enterprises). As stated by national administrations during the public 
consultation, many of these vehicles are adapted for specific needs to perform jobs related to 
special agricultural of forestry work which are different across Europe. To standardise all safety and environmental requirements in such a situation would be very difficult, and would 
put into question the use of particular vehicles in certain regions. In respect of this situation, 
the Commission services could set new requireme nts for road safety only, and not make the 
EC type-approval system for other aspects mandatory. 
Concerning the S category, types of vehicl es are even more diverse than in the R category. 
Interchangeable towed machinery covers a wide variety of vehicles bu ilt to perform very 
specific tasks and with many regional specialisati ons across the regions of  Europe. Given this 
situation, a high proportion of these types of vehicles (estimated as between 25 and 50 %) 
would fall under the small series  exemption. Nevertheless, consid ering the low limit of this 
exemption for this category (set as 50 units registered per year in each MS), a majority of 
these types will have to comply with the re quirements of the EC type-approval if it was 
decided to make it mandatory. The same appro ach as for category R has been followed to 
assess the cost/benefit of this choice (TRL report paragraph 4.3.2.7). An average reduction of 
€ 1.625 of the price per vehicle (2.5% of € 65.000)  could be gained due to harmonisation of 
road safety requirements and production harmon isation allowed by it. As some vehicles of 
category S are sold in a high numbers, it would mean a benefit of € 812.500.000 (average 
reduction of € 1.625 on 500.000 vehicles registered per year). This will be a benefit to buyers, 
which are often SMEs, as well as to manuf acturers which will have simplified design and 
production stages.  
Nevertheless, the technical requirements are not yet adapted, and in the current situation, if 
vehicles from category S had to comply with all requirements of the separate Directives 
specified in the EC type-approval Framework Directive, the cost of all the additional 
requirements would be much higher than the bene fits from the standardisation (approximately 
twice as much, estimated as € 3.000 per vehi cle). This means that a cost of € 687.500.000 
would be implied. In this situation, asking for mandatory EC type-approval for this category 
is not a good cost/benefit option, pa rticularly if considering that  the increase in the cost per 
vehicle would be borne by a large number of SMEs. And as stated above, it cannot be 
assumed that the small series exemption will cover sufficiently the ve ry specific types of 
vehicles, in order for th em not to see their price increase dr astically; they might even not be 
allowed on the market anymore, not meeting the EU requirements. 
With such an assessment, it is clear for Commis sion services that technical requirements will 
have to be adapted and defined precisely in or der to allow vehicles to  comply with the new 
common requirements at a minimum cost. At the same time and in the present market 
conditions it seems undesirable to introduce mandatory new requirements because of rising costs.  
c) Option 3: Complete  the EC type-approval requiremen ts and leave EC whole vehicle 
type-approval optional  for certain categories  (T4, T5, C, R and S) 
This option is similar to b) above, but in this  case the EU requireme nts (to be completed) 
would not be mandatory but it will be left to th e choice of the manufacturer whether to apply 
for EC whole vehicle type-approval or  for national type-approval or not. 
The advantages and disadvantages are similar to the option above, but the manufacturer can 
decide whether his choice is bene ficial for him and his product.  
An additional disadvantage is, however, that Memb er States will have to maintain a national 
homologation system in parallel. In additi on, an optional system requires that for each 
 
EN 26   EN separate substantive requirement  set at EU-level, the legislation specifies whether this 
requirement is mandatory, including in the co ntext of national type-a pproval, or optional. 
Also, if certain requirements are left optional,  various MS may choose a different level of 
protection. This may be appropriate for the lo cal / national conditions, but it may hinder trade 
if the vehicle is to be used elsewhere later on.  
Presently the Commission services are of the opinion that there are no supporting data in 
accident statistics, nor in trade aspects, that w ould justify a mandatory system. In 7 to 10 years 
it could be useful to reassess  this situation. 
The preferred option would be option 3, but with addition that certain road safety 
requirements would be mandatory in order to guarantee road safety (e.g. braking, lighting, 
marking). From the point of view of proportional ity this seems the most appropriate choice; in 
numbers the categories T1, T2 and T3 are about 80% of the tractors market, so ‘completion’ 
would be for 20% only and these vehicles ar e very seldom used on the roads – with the 
specific exemption of T5 (fast tractors) that  will need special attention in implementing 
legislation. For environmental ap sects it should be noted that the requirements of Directive 
2000/25/EC are already mandatory for all tractor s and the intention is that this will not 
change, so the present proj ect of introducing a Mother Regulation should not lessen 
environmental protection levels. 
 Position of stakeholders Member States:  
Austria: should be optional Finland: mandatory for all tracto rs; partly optio nal for others. 
France: completion on mandatory basis, as soon as possible. 
Germany: mandatory for all, but with  some possibilities for exemptions. 
Netherlands: the use of “small series ex emptions” causes a need for national 
legislation, which is contrary to the idea of a Regulation. TA only for large series, 
should be limited to tractors. 
United Kingdom: mixed, depending on cost/b enefit. Mandatory for all tractors, maybe 
optional for T5. 
Industry:  
CEMA favours mandatory legislation fo r T1, T2 and T3 tractors only; the 
requirements for all other categories should be optional and for R and S be limited to 
road safety aspects. For some industrie s (SME) full EU type-approval would be too 
costly and they fear that it might prove impossible to build in enough flexibility in 
requirements to fit the needs for all different types of ve hicle (e.g. the various higher 
masses and dimensions for special large tractors and machines). Requirements to be adjustable to regional needs. 
Some delegations have indicated that “self-pr opelled machinery” (or e quipment) should be 
included in this Regulation on an optional basi s (ES, NL, CEMA), for road safety issues.
 
EN 27   EN SECTION 6: OPTIONS COMPARISON AND CONCLUSIONS  
Summary of impacts of differen t options for all objectives 
 
 
                                                 
18 Explanation:  0 means ‘neutral’ (no change) 
  + means ‘better’ Criteria Objective Policy options effectiveness efficiency coherence Conclusion
18 
1 - No policy change 0 0 0 0 
initial cost _ 
 
slight risk of delaying urgent 
matters _ 
cost reduction on the long term + 2 - Replace current 
framework by two regulations simplification of the 
regulatory 
framework + 
a quick process of adaptation to 
technical evolution in  the future + better than baseline + + 
initial cost _ 
 
slight risk of delaying urgent 
matters _ even more positive 
(increased clarity for 
industry) + 
easier processing + 
cost reduction on the long term + 1 -  Simplification of existing acquis  
(by repeal of existing directives) 3 - Replace the current 
framework by limited number of thematic 
regulations simplification of the 
regulatory 
framework + 
implementing measures will be 
adopted in a short term + facilitation and 
rationalisation effects: more 
coherence for experts + ++ 
 
EN 28   EN  Criteria  
Objective  Policy options  
effectiveness  efficiency  coherence  Con-
clusion  
1- No policy 
change 0 0 0 0 
simplification + slight reduction of costs and administrative 
burden + 
improved management of procedures + 
UNECE texts also need to be translated and 
published, like EC legislation 0 2- Use references 
to UNECE Regulations reduction of 
duplications + 
potential risk of weakening requirements _ increase clarity 
for industry and 
administrations + + 
simplification ++ OECD texts also need to be translated and 
published, 
like EC legislation and UNECE 0 
reduction of costs and administrative burden + 
improved management of procedures + 2 – Simplification: Improved regulatory capacity for future acquis 
(new split-level regulatory approach with use of international 
standards) 
3- Use references 
to all relevant international standards reduction of 
duplications ++ 
potential risk of weakening requirements - same as in 2.2 ++ 
 
EN 29   EN Criteria  
Objective  Policy options  
effectiveness  efficiency  coherence  Con-
clusion  
1- No policy change 0 0 0 0 
high costs of new requirements for 
T4.2, T5, R and S _ 
access to a wider market with less 
administrative burden + 
new specific technical requirements 
needed - 
increase in road safety + 2- Complete the EC TA 
requirements and make EC type-approval mandatory for 
all categories of vehicles completion of 
internal market 
(mandatory) + 
gains from harmonised designs +  0 
allows open market with cheapest 
option + 
new specific technical requirements 
needed - 
increase in road safety + 3 - Completion of the single market 3- Complete the EC TA 
requirements;  leave EC 
WVTA optional for certain 
categories (T4, T5, C, R 
and/or S)  completion of the 
internal market 
(optional) + 
gains from harmonised designs +  + 
 
EN 30   EN In conclusion, the prefe rred options would be to simplify th e legislation by introducing a co-
decision Regulation with a limited number of implementing Regulations through Comitology, 
using as much as possible the standards availa ble from UNECE, OECD, ISO and CEN/CENELEC. 
some of the road safety related prescriptions sh ould be made mandatory (like already the case for 
emission requirements for all tractors). 
Furthermore, the preferred option for completion w ould be to maintain th e ‘mandatory’ approach 
for tractor categories T1, T2 and T3, to require mandatory applica tion of road safety requirements 
(at least braking, lighting, marking) for T4, T5, C, R and S vehicles and make the additional 
requirements (as listed in annex 3) optional at th e choice of the manufacturer. Most stakeholders 
agree with the need for mandatory road safety  requirements. CEMA would wish to maintain 
‘optional’ for all except T1-T2-T 3. Optionality means the need to  keep national legislation, but 
‘mandatory’ would be too expensive. 
 
It can be noted that for all ‘automotive sector s’ (motor vehicles, two- and three wheelers an 
agricultural vehicles) the following applies:  
a. Self-regulation / voluntary codes:  since 1970 many actors, incl uding Member States national 
authorities have indicated that  in Europe thes e are not acceptable approaches for road safety, 
occupational safety and environmental pr otection, hence the ex isting (framework) 
Directives. Member States do not accept a ch ange and prefer type -approval. A typical 
example for this approach is provi ded by the reasons for regulating CO 2 emissions from 
passenger cars; another example is the situation relating to ‘pedestrian protection’ (bumpers 
of cars).  
b. An additional option to make use of all inte rnational standards combined with ‘no EU 
action’: in this case EU would maintain th e system of Directives but amend them 
progressively by replacing the te chnical content by a reference to  such standards; this would 
be a viable option, but less de sirable than when combined  with a new Regulation. As 
explained the Directives are a relatively cu mbersome, time-consuming and costly system, 
lacking some legal clarit y, for all parties involved. 
Impact on health, safety and environmental protec tion: the ‘Mother Regulation’ should not have a 
major impact on health, safety and environmental protection as the Commi ssion does not intend to 
change the technical requirements; as indicated before the proposal involves first of all a system 
change. For health and environmental protec tion there should be no impact at all (same 
requirements as today, no new categor ies); for road safety a slight  improvement may be expected 
as categories R and S would fall under harmoni sed requirements. Later, in implementing 
legislation, positive effects should come from impr oved requirements for braking, to be applied to 
categories not covered today. On the other hand, th e external study was not able to quantify these 
effects due to lack of deta iled information (see annex 2). 
Ensuring existing level of protectio n: when agreeing a reference to UNECE, OECD or other, there 
should be agreement with the expe rts that equivalence is shown;  of course the Commission is 
obliged under the Treaty to strive for a high level of protection when it  proposes legislation, so a 
step back would not be acceptable. Not for th e Commission, nor for the MS. A positive change 
may occur, also in the case wher e a MS did not have requirements until now and will have to apply 
 
EN 31   EN the new rules. This approach is similar to what has been accepted for the ‘General Safety 
Regulation’ for motor vehicles recently. 
SECTION 7: MONITORING AND EVALUATION  
No specific system is fores een but the Commission’s Worki ng Group on Agricultural Tractors 
(WGAT) will be used for the follow-up with the implementing measure
 
EN 32   EN ANNEX  1 
 
PUBLIC CONSULTATION ON OUTLINE PROPOSALS FOR A FRAMEWORK 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL FOR 
AGRICULTURAL VEHICLES  
 
Summary of Responses   
 
1. C ONTEXT  
The Commission launched an open public  consultation seeking to gather views of interested parties on 
its outline proposals for new legislation for agricult ural vehicles. A consultation document has been 
published to provide background and ask for opini ons on this new framework, which should replace 
the Framework Directive and 23 separate directives and their many amending directives. These 
outline proposals are thus embedded in the EU st rategy to improve the regulatory environment 
towards simplification. In particular, comments of in terested parties have been asked over three main 
aspects: concerning the choice and format of the le gislation; on the completion and the mandatory 
nature of the type-approval system ; and over its scope  and coverage.  
2. O VERVIEW OF RESPONDENTS  
The consultation was launched on 03 July 2008, with  12 September as deadline for submission. The 
Commission services received 19 responses, among wh ich 9 contributions have been provided by 
Member States governmental organisations, and 10  by industrial organisations. Business responses 
came from European federations of producers and u sers, national associations of producers and users, 
and single manufacturers of vehicles and components.  
3. S UMMARY OF RESPONSES  
3.1 Choice of the legislative format 
There is a general support for the use of the Regula tion format, which should help in the simplification 
process. Only one (governmental) organisation highli ghted the usefulness of a New Approach system. 
The majority of stakeholders have stressed th e necessity of the split-level approach, where 
fundamental requirements are include d in a Mother Regulation decided by co-decision, while detailed 
technical requirements are contained and updated in  implementing regulations, using the comitology 
procedure. Business actors consider this approach as very needed in order to grant in the future the 
quick adaptation to new requirements.  
3.2 References to international regulations and standards 
Comments from both governmental and business r esponses are highly positive about increasing 
references to international regulations and sta ndards, being Regulations from the United Nations 
Economic Commission for Europe (UNECE), or st andards developed by OECD, CEN/CENELEC or 
ISO. This approach is supported because of its welcomed simplification effect, provided that 
references should be done on a case by case basis, and only when standards are at least equal to 
existing parallel EU legislation, i.e. supporting the achievement of an equal le vel of safety. Moreover, 
many stakeholders stressed that static references should be used.  
 
EN 33   EN 3.3 The type-approval system as legislative approach 
The broad majority of stakeholders, both public an d private, consider the use of the type-approval 
system as efficient and support it as a legislative a pproach, even if it could be improved in order to 
become less time-consuming for the process of updating to technical progress.  
3.4 Completion and mandatory nature of the type-approval system 
Both public and private stakeholders broadly (but not unanimously) support a mandatory type-
approval system at the European level for all agricult ural and forestry tractors (defined as categories T 
and C in the Framework Directive). Some want li mitations if a cost/benefit analysis support it. 
Concerning trailers and interchangeable towed mach inery (categories R and S), half of governments 
consider that mandatory type-approval at the Eu ropean level could be applied, provided that 
exemptions should be maintained for small series a nd very specific needs. The other administrations 
would rather see the type-approval of these vehicl es at the European level as optional, or only 
mandatory for road safety aspects. They are b acked in this position by most manufacturers 
representatives, who also ask for a voluntary harm onisation only. National (type)-approval systems are 
in their opinion still necessary considering regiona l specific uses across Europe. Still concerning 
trailers and interchangeable towed machinery (cat egories R and S), most governmental and business 
organisations are asking for a distinction between ro ad safety aspects, which should be covered by the 
type-approval system, and other aspects such as occupa tional safety, which are already covered by the 
requirements of Directive 2006/42/EC on machinery.  
3.5 Aspects to be covered 
All stakeholders but one agree on the fact that ro ad safety aspects have to be covered in the type-
approval system. Concerning occupatio nal safety of vehicles from cat egories T and C, respondents ask 
for an inclusion of the risks falling currently unde r the Machinery Directive, so tractors would no 
longer fall under the requirements of Directive 2006/ 42/EC. As mentioned above, occupational safety 
aspects in vehicles of categories R and S are cons idered as sufficiently covered by the Machinery 
Directive. Additionally, some stakeholders have shown interest for new requirements concerning 
aspects such as anti-lock braking (ABS).  
3.6 Need for exemptions 
Both governmental and business actors consider that  exempting full classes from type-approval is not 
the right option. Stakeholders are neverthel ess divided concerning specific exemptions. Some 
responses only ask for exemptions contained in the Framework Directive, such as vehicles produced 
in small series or on individual basis, to be main tained in the new Regulation. Others would like to 
see new specific exemptions introduced, for example for vehicles adapted for special forestry needs, 
or about small vehicles from categories R and S wh ich do not contain a braking system. Moreover, 
several manufacturers representatives ask for exem ptions from particular requirements, such as 
vehicles from category C out of noise specifications, or  vehicles from categories T2 and T4.1 out of 
updated exhaust emissions requirements. 
 
EN 34   EN ANNEX  2 
DESCRIPTION OF THE TASKS REQUESTED TO THE EXTERNAL CONSULTANT  
AND METHODOLOGY USED  
Tasks  
A. General assessment:  identification and estimation of  likely economic, safety, social 
and environmental effects for each policy objectives proposed. 
This implies firstly to provide a general overv iew of the relevant market, with a special 
emphasis on vehicle categories for which EC type -approval is not mandatory yet, and also 
with a particular interest for SMEs. Moreover,  the contractor has been asked to include 
wherever possible the 27 Member States. And it has also been asked to  provide market data 
on the share between vehicles produc ed inside and outside Europe. 
Secondly, always for each policy option, data  have been requested on both positive and 
negative impacts on road and work safety, on the environment, and on costs for manufacturers as well as for national admini strations. The necessity to integrate these 
different aspects has been stre ssed, and it has been asked to  consider impacts in short, 
medium and long-term. Moreover, the contract or should study the possible improvement of 
the competitiveness of the relevant industry on the global market. And as costs are concerned, 
an integrated approach should be adopted with measurements to be done at the various stages 
from manufacture, assembly, and testing to the final type-approval of vehicles. 
B. Simplification of the legislation (Part I):
 assessment of a simplification exercise 
where the current legislative framework consisting of 24 Directives would be 
replaced by a single Regulation adopted by co-decision and a li mited number of 
implementing regulations adopted by comitology procedure. 
This simplification is deemed to enable the co-legislator to focus on the main political issues, 
whereas technical issues will be dealt at the level of experts. Advantages foreseen are a quicker adaptation and moreover and prevention of burdensome transpositions by Member 
States, as well as the related scrutiny of  these transpositions by the Commission. The 
contractor has been requested to assess, if possi ble in monetary terms, the impacts of such a 
simplification for the different stakeholders. Th ree scenarios have been established: the “no-
policy change”, the introduction of one co -decision Regulation with one implementing 
comitology regulation covering all aspects,  and the introduction of one co-decision 
Regulation together with several implementing regulations covering di fferent aspects (road 
safety, work safety and environment). 
C. Simplification of the legislation (Part II):
 assessment of the replacement of existing 
detailed technical provisions in current separate Directives by references to relevant 
international or European standard s (UNECE, OECD, CEN/CENELEC and ISO 19). 
The study should analyse three scenarios: the “ no-policy change”, refere ncing in a single co-
decision Regulation, and referencing in one “mot her” Regulation and in a limited number of 
specific implementing measures (divided betwee n road safety, work safety and environment 
                                                 
19 United Nations Economic Commission for Europe; Organisation for Economic Cooperation and 
Development; CEN, the European Committee for Stan dardisation, and CENELEC, the European Committee 
for Electrotechnical Standardisation; International Standardisation Organisation 
 
 
EN 35   EN aspects). Cost/benefit calculations have to be assessed for direct references and for full 
publication, where translations would then be needed considering that OECD documents are 
only available in FR and EN while EU Regulati ons need to be made available in all 23 
official languages. (For UNECE, the Commi ssion is already publis hing all relevant 
Regulations.) 
D. Completion for categories T4, T5, C, R and S:  assessment of the cost/benefit and the 
feasibility of a completion towards mandatory type-approval for these categories, for which requirements are sometimes specified and sometimes still to be determined 
depending on the different Directives. 
 Methodology
 
A literature review was performed, including the CARS 21 initiative, the present set of 
Directives for the sector a nd the public consultation done by the Commission services in 
2008. An enquiry form was sent to all relevant st akeholders: representati ves of ministries in 
all Member States and industry organisations. Tw enty-two replies were received, of which 12 
contained useful information; 10 from Memb er States and 2 from industry. Consultation 
meetings were planned in October and Novemb er, but due to unavailability only the one on 
21 November was held, with representatives  of one Member Stat e and of industry. A 
reminding letter was sent by the Commission serv ices, which caused 4 more replies (included 
in the numbers given above) with some useful information.  
On this basis the contractor drafted a report,  which was then presen ted in the Working Group 
on Agricultural Tractors (WGAT) on 20 February 2009. 
The following statement by the contractor is to be noted: “The confidence in the estimates 
could be improved if additional responses and data were available from stakeholders. The lack of data has meant that some of the estimates made in this impact assessment have relied heavily on assumptions made by TRL or on an ecdotal evidence from stakeholders.”  
Although the Commission has to accept the report prepared by the contractor because of the 
limitations  for the study there is uncertainty a bout the figures used; that is why ranges of 
values have been indicated. Also the figures gi ven by some of the stakeholders might not be 
fully comparable because of a different (but unknown) breakdown of the costs involved. 
The contractor has used a figure of 3.5% for the discount rate in stead of 4% given in the IA 
Guidelines, but it is considered that this should not have a rele vant impact on the outcome of 
the study. 
The report by TRL can be f ound at the following website: 
http://ec.europa.eu/enterprise/a utomotive/projects/index.htm  
 
EN 36   EN ANNEX  3 
DEFINITION OF VEHICLE CATEGORIES AND VEHICLE TYPES 20 
AND BACKGROUND TO THE TYPE -APPROVAL SYSTEM  
A. The vehicle categories are defined as follows: 
1. Category T: Wheeled tractors 
– Category T1: wheeled tractors with a maximum d esign speed of not more than 40 km/h, with the 
closest axle to the driver21 having a minimum track width of not less than 1 150 mm, with an 
unladen mass, in running order, of more than 600 kg, and with a ground clearance of not more than 
1 000 mm. 
– Category T2: wheeled tractors with a maximum de sign speed of not more than 40 km/h, with a 
minimum 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 more th an 600 mm. However, where the height of the 
centre of gravity of the tractor22 (measured in relation to the ground) divided by the average 
minimum track for each axle exceeds 0,90, the maxi mum design speed is restricted to 30 km/h. 
– Category T3: wheeled tractors with a maximum d esign speed of not more than 40 km/h, and with 
an unladen mass, in running order, of not more than 600 kg. 
– Category T4: special purpose wheeled tractors with  a maximum design speed of not more than 
40 km/h (as defined in Appendix 1). 
– Category T5: wheeled tractors with a maxi mum design speed of more than 40 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. 
3. Category R: Trailers 
– Category R1: trailers, the sum of the technically permissible masses per axle of which does not 
exceed 1 500 kg. 
– Category R2: trailers, the sum of the technically permissible masses per axle of which exceeds 
1 500 kg but does not exceed 3 500 kg. 
– Category R3: trailers, the sum of the technically permissible masses per axle of which exceeds 
3 500 kg but does not exceed 21 000 kg. 
– Category R4: trailers, the sum of the technically permissible masses per axle of which exceeds 
21 000 kg. 
Each trailer category also includes an «a» or «b» index, according to its design speed: 
– «a» for trailers with a maximum desi gn speed below or equal to 40 km/h, 
– «b» for trailers with a maximum design speed above 40 km/h. 
                                                 
20  Directive 2003/37/EC and proposal for Regulation 
21 For reversible driver's position tractors (reversible seat and steering wheel), the closest axle to the 
driver to be considered must be the on e fitted with the biggest diameter tyres. 
22 In accordance with st andard ISO 789-6: 1982. 
 
EN 37   EN Example: Rb3 is a category of trailers for which the sum of the technically permissible masses per 
axle exceeds 3 500 kg but does not  exceed 21 000 kg, and which ar e designed to be towed by a 
tractor in category T5. 
4. Category S: Interchangeable towed machinery 
– Category S1: Interchangeable towed machinery intend ed for agricultural or forestry use, the sum 
of the technically permissible masses per axle of which does not exceed 3 500 kg. 
– Category S2: Interchangeable towed machinery intend ed for agricultural or forestry use, the sum 
of the technically permissible mass es per axle of which exceeds 3 500 kg. 
Each category of interchangeable towed machinery al so includes an «a» or «b» index, according to its 
design speed: 
– «a» for interchangeable towed machinery with  a maximum design speed below or equal to 
40 km/h, 
– «b» for interchangeable towed machinery wi th a maximum design speed above 40 km/h. 
Example : Sb2 is a category of interchangeable towed m achinery for which the sum of the technically 
permissible masses per axle exceeds 3 500 kg, and wh ich is designed to be towed by a tractor in 
category T5. 
B. Definition of vehicle types 
1. Wheeled tractors: 
For the purposes of this Directive: 
«type» means tractors of the same category that do not differ in respect of at least the following 
essential aspects: 
– manufacturer; 
– manufacturer's type designation; 
– essential construction and design characteristics: 
– backbone chassis/chassis with side members/ar ticulated chassis (obvious and fundamental 
differences), 
– engine (internal combustion/electric/hybrid), 
– axles (number); 
«variant» means tractors of the same type which do not differ in respect of at least the following 
aspects: 
– engine: 
– operating principle, 
– number and arrangement of cylinders, 
– power difference of no more than 30 % (the highest  power being no more than 1,3 times the lowest 
power), 
– cylinder capacity difference of no more than 20 % (t he highest figure being no more than 1,2 times 
the lowest figure); 
– powered axles (number, position, interconnection); 
– steered axles (number and position); 
– maximum laden mass differing by no more than 10 %; 
– transmission (type); 
 
EN 38   EN – rollover protection structure; 
– braked axles (number); 
«version» of a variant means tractors which cons ist of a combination of items shown in the 
information package in accordance with Annex I. 
2. Track-laying tractors: idem wheeled tractors. 
3. Trailers : 
«Type» means trailers of the same category that do not differ in respect of at least the following 
essential aspects: 
– manufacturer; 
– manufacturer's type designation; 
– essential construction and design characteristics; 
– backbone chassis/chassis with side members/ar ticulated chassis (obvious and fundamental 
differences); 
– axles (number); 
«variant» means trailers of the same type which do  not differ in respect of at least the following 
aspects: 
– steering axles (number, position, interconnection); 
– maximum laden mass differing by no more than 10 %; 
– braked axles (number). 
4. Interchangeable towed machinery:  idem trailers. 
 
C. BACKGROUND TO THE TYPE -APPROVAL SYSTEM  
How the system works 
Before the EU developed the type -approval system most Member States used to have their own, 
differing national requirements for new vehicles to be  allowed on the market. The directives for motor 
vehicles (under 70/156/EEC)  and for tractors (74/150/EEC) were set up to counter the problems for industry created by these differences and separate approval procedures by harmonising the minimum requirements to be fulfilled. Execution of testing and approval activities was left to the MS. In the 
directives it is stated that other MS have to accep t approvals given in one MS (mutual recognition, 
based on EU requirements; an approach of mu tual recognition based on –differing- national 
requirements has been discussed in the past but has never been accepted by Member States).  
Costs: the system has inherent costs: the direc tives have to be develope d (meetings of experts, 
drafting by Commission services and experts from MS; procedural costs related to getting the draft approved by the co-legislators; cost of implem enting directives in national legislation and its 
verification by the Commission; costs for manufactur ers to get their product tested (including 
provision of products for testing) and approved; fo llow-up costs if product needs to be adapted and 
again approved. Available figures are in this report and the supporting external report.  
Every Member State appoints a ‘Type-approval authority’ (TAA; under 2003/37 – agricultural 
vehicles as well as under 70/156 – motor vehicles and 2002/24 – two and three wheelers). This TAA must be notified to the Commissi on and other MS to perform the n ecessary tests or other institutes 
(testhouses) can be notified for this purpose. 
 
EN 39   EN A manufacturer who proposes a new vehicle or component (e.g. headlamp) contacts the TAA and the 
testhouse, submits the prescribed completed inform ation document, makes the vehicle or component 
available for testing and pays the fees. 
It may prove that the test is not passed; in such  case the product can be adapted and resubmitted for 
testing.  
If all is well the manufacturer obtains the test report(s) and approval form(s). These forms are defined 
in the SDs. Then the manufacturer is able to se ll his product everywhere in the EU, provided he puts 
the prescribed marking on the product and, for vehicles, provides a CoC (Certificate of Conformity) with every vehicle delivered. 
In case of a vehicle, the manufacturer can obtain TA in one step (all testing etc in one go), or step-by-
step (separate approvals for every component / syst em; in the end, for the vehicle as a whole, he 
submits the approvals given before. In the latter cas e, which is must usual, many part-approvals may 
have been obtained by other (component) manuf acturers. Another option foreseen is that one 
manufacturer builds a basic but incomplete vehicl e and the next finishes it by e.g. building the 
bodywork on it, or modifying it for a specific purpose: multi-stage approval. 
A manufacturer can submit a product for TA only in one MS, to one TAA (no ‘shopping’). The TAA must inform the other authorities about TA’s given, denied or withdrawn. The latter 
because the TAA is responsible towards the others  in case it is found that products are marketed 
which are not in line with the TA given. 
As long as the EU system allows “optionality”, this means that he may choose to apply for an EU TA 
for the vehicle or component. EU requirements are of ten somewhat stricter than national requirements 
and thus the product may have to be somewhat more expensive; on the other hand if his markets are in 
more MS he can choose his best option. 
The approval procedure for a vehicle may be time-c onsuming, often starting in the first year of 
development, lasting 3 to 4 years. It’s important for the manufacturer not to have to repeat this a 
number of times in different countries. 
 
EN 40   EN ANNEX  4 
MARKET OF AGRICULTURAL VEHICLES  
1. Number of tractors and trailers sold in  2005 (EU-25; source: TRL final report, 2009) 
Vehicle type Number 
sold Price Turnover 
T1 120,000  
T2 15,000  
T3 1,650  
T4 15,000  
T4.1   
T4.2  100,000 -150,000 
T4.3   
T5 13,000 100,000 -150,000 1,300,000 - 2,000,000
Sub total 164,650  
C 5,000  
Total 169,650  
   
R 125,000 5,000 – 30,000 625,000, 000 – 3,750,000,000
S 500,000 65,000 * 32,500,000,000
   
* indication of average 
 
------------- CEMA information for the years 2001 and 20 04 – tractor market, turnover etc. 
- Turnover tractors: 2001 - € 6,180 million for 154,000 units (12 member countries); 
average price  € 40,130 / unit. For 2004: € 7,300 million for 156,200 units, € 46,700 / 
unit. 
- In Europe 5 manufacturing groups are active, with more than 20 brand names, most 
from the EU.  
 
---------------- 
 
EN 41   EN 2. Tractors - new registrations per MS, 2006 – 2008 (source: TRL final report 
2009). 
Registrations 2006 2007 2008 
Austria 7,152 6,792 7,737
Belgium 2,748 2,680Bulgaria  Cyprus  Czech Republic 2,225 2,730Denmark 3,110 3,479Estonia  437Finland 4,172 4,245France 27,388 29,129Germany 29,009 28,469Greece 3,518 4,170Hungary 1,045 2,045Ireland 4,221 Italy 29,752 26,837Latvia  Lithuania  Luxembourg  Malta  Netherlands 3,823 4,054Poland  Portugal 5,415 6,122Romania  1,077Slovakia  1,450Slovenia 1,853 2,084Spain 16,605 17,241Sweden 4,233 4,465United Kingdom 13,829 14,941
Total 160,098 159,483 10,701
 
(for empty boxes: no information was received)
 
EN 42   EN 3. Import/export of new agricu ltural tractors, 2007, EU27 ( Comext database, Eurostat ) 23 
 Track-laying tractors   Wheeled agricultural tractors 
 Import  
Import Export  
Export  Import Import Export  
Export
 Value Units Value Units  Value Units Value Units 
Belarus      95.038.622 7.378 12.964.865 95
Canada 200.412 9    2.677.990 295 62.964.860 2.328Chile   137.999 7    11.756.464 706
China 130.670 25 114.480 5  25.851.834 8.488 10.044.776 283
Croatia   96.146 4  450.727 13 34.752.302 1.160
Iceland   40.539 8    15.522.714 422
Iran        17.239.503 514Israel 32.256 2    15.063 4 11.423.125 505
Japan 439.696 206    147.060.521 25.068 45.213.966 1.183
Malaysia        6.269.559 455Mexico      213.457 28 9.413.104 454
Morocco   198.088 21    28.016.583 1.747
New Zealand   16.205 1  8.135 1 61.428.357 1.874Norway 438.338 29 599.060 60  1.626.906 93 154.734.409 5.354
Russia 287.813 8 6.981.647 170  151.558 20 72.359.710 1.370
Serbia 17.439 1 151.341 4  511.653 38 17.239.770 413South Africa   3.463.20 4 34  166.840 41 71.097.548 2.829
South Korea      20.661.795 2.248 36.586.678 1.200
Switzerland 580.763 28 416.682 1 6  7.732.927 210 93.881.975 2.921
Tunisia        9.230.970 585
Turkey 4.482.968 1.467 246.126 2  9.754.638 621 67.533.886 3.060
                                                 
23 Values in Euros and units 
 
 
EN 43   EN Ukraine   3.181.355 26  469.873 52 25.702.010 358
United States 37.641.319 368 2.082.49 0 188  476.626.178 42.049 742.673.712 25.882
Venezuela 8.000 1 336.321 12    7.440.827 280
Total 44.259.674 2.144 18.061.683 558  789.018.717 86.647 1.625.491.673 55.978
 
 
EN 44   EN ANNEX  5  
STAKEHOLDERS POSITION ON THE OBJECTIVES AND OPTIONS  
(information from public consultation and WGAT) 
 Objective 1 – Simplification: Directive or 
Regulation Objective 2 – Simplification: 
international standards Objective 1 – Completion Comments 
 Option 1: 
no policy 
change Option 2:  
2 Regulations Option 3:  
4 Regulations Option 1: 
no policy 
change Option 2: 
reference 
to UNECE 
Regs  Option 3: 
reference 
to more 
standards Option 1:  
no policy 
change Option 2: 
complete & 
mandatory 
for all cat’s Option 
3: 
complet
e but partial 
optional  
Stakeholders - MS     
Austria Change from Dir. to Reg., with basically 
the same contents, seems possible. Not of 
vital importance how this is done.    
Bulgaria Approach of 2007/46/EC must be 
followed: one framework Directive with 
TA requirements + separate reg's with technical req's, or references to UN/ECE 
reg's where applicable separate reg's with technical 
requirements, or references to 
UN/ECE reg's where applicable   
Denmark (Working 
Environment Auth.) Should be New Approach; if not, 
possibility of risks not covered.     
 
EN 45   EN Finland Reg. would save costs for governments.  
 Positive about reference to internat. 
documents, but updating could be a challenge; reference always to latest 
version.  Emissions: Dir 
97/68 sufficient => should cover 
tractors.  
France agree with Reg; no preference for 2 or 3; 
no priority issue; should not delay some 
other issues Favourable (also i.r.t. OECD), but 
(static) references to dated standards 
require update of regulation; New Approach possible to avoid that, but 
then need "guaranties” from 
CEN/ISO; codification should be stopped. option 2, ASAP  
Germany Agree with the replacement of dir by a 
Reg    
Netherlands Regulation accepted, but fear additional 
administrative burden. Like the 2007/46/EC system with 
direct reference to UNECE Regs. Can 
do that in a Reg   
     
United Kingdom Support for simplification, but concern 
about transition, self-certification and 
COP.    
     
 
EN 46   EN  
Stakeholders – industry    
CEMA Agrees in principle with Reg. but new 
items or change in scope must be under 
Co-Decision. Scope must be considered carefully.    
SYGMA (Fr) Not against Reg, but priority for 
adaptation to techn. Progress; MD 
distinction issue; New items in the Reg. 
and scope modifications under Co-Decision.    
VDMA (DE) Reg. or Dir. not important; positive on 
bringing several Dir's together in one Reg, 
Be careful with loss of clarity.    
CEETTAR Positive on Reg., because it promotes 
harmonisation.    
ETRMA Welcome the CARS21 approach on better 
regulation.Favours Impact Ass. prior to 
drafting. Welcome the CARS21 approach on 
reference to international docs 
(UNECE Reg. 106 on tractor tyres).    
TLN (NL) No different from road vehicles by using ECE Reg's, new EU reg's 
can be sooner   
AECC Agree with Reg.    
 
EN 47   EN J.C.Bamford Against Reg with systematic co-decision; 
Comitology is needed (split-level)    
Knorr Bremse Little benefit is expected for industry 
(compared with existing consolidated dir's). So not demanding, particularly 
considering updates might be more 
difficult    
ACAP (PT) Reg. is very positive and necessary    
 
EN 48   EN ANNEX  6   
 LIST OF SEPARATE DIRECTIVES , RELATION WITH UNECE  AND OECD 
Directive 2003/37/EC, Annex II [similar tabl e for special tractors:T4.1 – T4.3] 
Note: the relation between directives and UNECE Re gulations / OECD Codes is indicative only and 
needs confirmation during preparation of implem enting legislation. For CEN/CENELEC and ISO 
no suitable information is available.  
Applicability 
(for T4 and C4 see Appendix 1) No Subject Equivalency 
with UNECE 
(R) and 
OECD (C) Base Directives 
and Annexes 
T1 T2 T3 T5 C R S 
1.1. Maximum laden mass  74/151/EEC I X X X X (X) (X) (X) 
1.2. Registration plate  74/151/EEC II X X X X I (X) (X) 
1.3. Fuel tank  74/151/EEC III X X X X I — — 
1.4. Ballast masses  74/151/EEC IV X X  (X) I — — 
1.5. Audible warning device R28 74/151/EEC V X X X X I — — 
1.6. Sound level (external) R51 74/151/EEC VI X X X (X) I — — 
2.1. Maximum speed  74/152/EEC 
Annex, para 1 X X X (X) I — — 
2.2. Load platforms  74/152/EEC 
Annex, para 2 X X X (X) I — — 
3.1. Rear-view mirrors  74/346/EEC X X  (X) I — — 
4.1. Field of vision and 
windscreen wipers R71 74/347/EEC X X X (X) I — — 
5.1. Steering R79 75/321/EEC X X X (X) (X) — — 
6.1. Electromagnetic 
compatibility R10 75/322/EEC X X X X I — — 
 76/432/EEC X X X — (X) (X) (X) 7.1. Braking devices 
R13 71/320/EEC — — — X — — — 
8.1. Passenger seats  76/763/EEC X — X (X) I — — 
9.1. Sound levels (internal)  77/311/EEC X X X (X) I — — 
10.1. ROPS C3 77/536/EEC X — — (X) (X) — — 
12.1. Driving seat  78/764/EEC X X X (X) (X) — — 
 
EN 49   EN 13.1. Lighting installation R86 78/933/EEC X X X (X) I (X) (X) 
14.1. Lighting and 
lightsignalling devices R1, 3, 4, 6, 7, 
8, 19, 20, 23, 
38, 98  79/532/EEC X X X X X (X) (X) 
15.1. Coupling and reversing 
devices  79/533/EEC X X X (X) I — — 
16.1. ROPS (static testing) C4 79/622/EEC X — — (X) I — — 
17.1. Operating space, access 
to the driving position  80/720/EEC X — X (X) I — — 
18.1. Power take-offs  86/297/EEC X X X (X) I — — 
19.1. Rear-mounted ROPS 
(narrow-track tractors) C7 86/298/EEC — X — (X) I — — 
20.1. Installation of the 
controls  86/415/EEC X X X (X) I — — 
21.1. Front-mounted ROPS 
(narrow-track tractors) C6 87/402/EEC — X — (X) I — — 
22.1. Dimensions and trailer 
mass  89/173/EEC I X X X (X) I (X) (X) 
 89/173/EEC III X X X — I — — 22.2. Glazing 
R43 92/22/EEC — — — X — — — 
22.3. Speed governor  89/173/EEC II, 
1 X X X (X) I — — 
22.4. Protection of drive 
components  89/173/EEC II, 
2 X X X (X) I — — 
22.5. Mechanical couplings  89/173/EEC IV X X X (X) I (X) (X) 
22.6. Statutory plate  89/173/EEC V X X X (X) I (X) (X) 
22.7. Trailer-brake coupling  89/173/EEC VI X X X (X) I (X) (X) 
23.1. Pollutant emissions R49, 96 2000/25/EC X X X X X — — 
24.1. Tyres24 R106 […./../EC] X X X X — (X) (X) 
25.1. Stability2  […./../EC] — — — SD — — — 
26.1. Seat-belt attachment 
points C3, 4, 6, 7, 8  76/115/EEC X X X X X — — 
27.1. Safety belts  77/ 541/EEC — — — X — — — 
                                                 
24 Pending the adoption of directives on tyres, stability a nd rear protective structures, the absence of a separate 
directive on this does not prevent the gr anting of the whole vehicle type-approval. 
 
EN 50   EN 28.1. Reverse and 
speedometer  75/443/EEC — — — X — — — 
29.1. Spray-suppression 
systems  91/226/EEC — — — X — (X) — 
30.1. Speed limitation devices  92/24/EEC — — — X — — — 
31.1. Rear protective 
structures2  [../../EC] — — — — — SD — 
32.1. Lateral protection  89/297/EEC — — — X — (X) — 
 
Legend: 
X = applicable as is 
(X) = applicable in amended form 
SD = separate directive 
— = not applicable 
I = same as T according to the category 
 
 
EN 51   EN ANNEX  7 
COST / BENEFIT COMPARISON TABLE  
 
 Objective 1 : Simplification of the regulato ry framework through a split-level approach 
 
Option 1 Option 2 Option 3 Indicators 
No policy change  Replace current 
framework by 2 
regulations  Replace current 
framework by [4] 
regulations  
Costs 
Annual cost to  
EU-27  € 29,160 to € 2,435, 400 
average € 533,993 € 7,560 to € 1,217,700 
average € 320,153 
Initial investment cost 
 € 18,225 to € 3,653,100 
average € 909,225 
 
Benefits 
Year Lower 
limit Average  Upper Limit  
1 € 3,375 - € 695,385  - € 2,435,400
5 € 86,690 € 129,430  € 2,261,461Cumulative benefit 
(Costs include an 
uplift of 2 % per 
annum and a discount 
rate of 3,5 %)  
10 € 184,219 € 1,094,970  € 7,759,675
Objective 2: Simplification throug h use if international standards 
Option 1 Option 2  Option 3  Indicators 
No policy change  Use when possible 
references to UNECE 
Regulations  Use references to all 
relevant international 
standards  
Costs 
Type approval costs Approximate costs per type (component) on average: € 15,000 
The cost of one whole vehicle-type approval can be above   € 100,000  
Translation costs  
 
EN 52   EN  
  
 
    Annual staff cost for 
attending meetings  Estimated average annual cost to 
attend EC,UNECE,OECD, ISO 
& CEN meetings € 1,135,085 (range: € 310,536 to 
€ 2,608,200)
  Estimated average annual 
cost to attend meetings 
with reference to existing standards  € 1,078,331 
(range: € 279,482 to 
€ 2,608,200)  
Investment cost for 
EU-27  
  € 909,225 (range: 
€ 18,225 to € 3,653,100)  
Benefits 
Annual saving from 
Type approval costs    0 
Annual average 
savings from attending meetings   € 31,054 (range: € 0 to 
 € 56,754)  
Translations   0 
 
EN 53   EN Objective 3 : Completion of the regulatory framework 
 
Option 1 Option 2 Option 3 Indicators 
No policy change  Complete the EC type-approval 
requirements and make EC type-
approval mandatory for all 
categories of vehicles Complete the EC type-approval 
requirements and leave EC 
whole  type-approval optional 
for certain  categories of 
vehicles (T4,T5,C,R and S)  
Costs 
T4.1 € 0 
T4.2 € 112,500,000 
T4.3 € 0 
T5 € 40,625,000  
C € 0  
R € 200,195,313  Estimated average cost 
per vehicle category (1)   
S € 257,812,500  similar to option 2  
Estimated average 
annual administrative 
costs (2)  
€ 36,190,000  
Total cost (1+2)  € 647,322,813 (range: € 364,440,000 to € 996,565,000)  
Average investment 
cost25 for EU-27   € 32,980,000*  (range: € 3,860,000 to € 62,100,000)  
Benefits 
Estimated casualty 
savings   € 50,750,409  
Estimated average 
cumulative benefits 
(Costs include an uplift 
of 2 % per annum and a discount of 3,5 %)  Year 1: - € 629,552,403 
Year 5: - € 3,057,835,295 
Year 10: - € 5,900,418,586  
Benefits from 
standardisation (saved by 
buyers)  T4.2 Category: benefit of € 22,500, 000 (average) 
 on 9,000 vehicles registered p.a. 
R Category:  benefit of € 68,750,000 (average) 
 on 125,000 vehicles registered p.a. 
S Category: benefit of € 812,500,000 (average)  
on 500,000 vehicles registered p.a. 
 
EN 54   EN