EN    EN EN 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 28.10.2009 
SEC(2009) 1454 
  
COMMISSION STAFF WORKING DOCUMENT 
  
IMPACT ASSESSMENT  
Accompanying document to the 
 
Proposal for a 
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
Setting emission performance standards for ne w light commercial vehicles as part of the 
Community's integrated approach to reduce CO 2 emissions from light-duty vehicles 
   
{COM(2009) 593 final} 
{SEC(2009) 1455} 
EN 2   EN TABLE OF CONTENTS 
1. Procedural issues and consulta tion of interested parties .............................................. 5 
1.1. Background in the development of the proposal.......................................................... 5 1.2. Consultation and expertise ........................................................................................... 6 1.3. Results of the consultation of the Impact Assessment Board ...................................... 7 2. Context and Problem definition ................................................................................... 8 2.1. The context of the initiative ......................................................................................... 8 2.2. Legal basis............................................................................................................... ..... 9 
2.3. Problem definition........................................................................................................ 9 
2.4. What are the underlying drivers of the problem?....................................................... 10 2.4.1. Vehicle stock of LCVs is increasing.......................................................................... 10 2.4.2. LCV driving pattern and mileages ............................................................................. 12 2.4.3. Potential regulatory gap linked to type  approval and registration procedures........... 12 
2.5. Stakeholders affected ................................................................................................. 14 2.6. Current economic situation ........................................................................................ 15 2.7. Baseline scenario........................................................................................................ 1 7 
2.8. Does the Union have the right to act? ........................................................................ 19 3. Objective ................................................................................................................... . 19 
3.1. Policy objectives ........................................................................................................ 1 9 
3.2. Consistency with horizontal object ives of the European Union ................................ 20 
3.2.1. Lisbon Strategy ......................................................................................................... . 20 
3.2.2. Sustainable Development Strategy............................................................................. 20 3.2.3. EU commitments to reduce GHG emissions.............................................................. 21 4. Policy options............................................................................................................. 2 1 
4.1. Introduction .............................................................................................................. .. 21 
4.2. Design parameters ...................................................................................................... 22 4.2.1. Scope of the legislation .............................................................................................. 22  
4.2.2. Effort sharing between manufacturers ....................................................................... 23 4.2.3. Target level............................................................................................................ ..... 24 
4.2.4. Target year............................................................................................................. ..... 24 
EN 3   EN 4.2.5. Utility curve slope ..................................................................................................... . 24 
4.2.6. Choice of average utility value in the definition of the limit value curve.................. 25 
4.2.7. Flexibility mechanisms .............................................................................................. 26 4.2.8. Compliance mechanism ............................................................................................. 27 4.2.9. Long-term target........................................................................................................ . 27 
4.2.10. Multi-stage vehicles ................................................................................................... 28 
4.3. Policy options considered in the further assessment.................................................. 29 5. Analysis of impacts .................................................................................................... 30 5.1. Description of the methodology................................................................................. 30 5.2. Economic impacts ...................................................................................................... 30 5.2.1. Distributional effect  on manufacturers....................................................................... 30 
5.2.1.1. Distributional impacts of mass- based limit function (2012 to 2015)......................... 31 
5.2.1.2. Distributional impacts of pan area- based limit function (2012 to 2015) ................... 31 
5.2.1.3. Summary of distributional analysis............................................................................ 32 5.2.1.4. Impact on small and medium enterprises (SMEs) ..................................................... 33 5.2.2. Innovation and competitiveness ................................................................................. 33 5.2.3. Sensitivity analysis.................................................................................................... . 35 
5.2.4. Impact on society and cost effectiveness ................................................................... 36 5.2.4.1. Impact on vehicle buyers and users............................................................................ 36 5.2.5. Impact on energy consumption .................................................................................. 37 5.2.6. Impacts of the long-term target .................................................................................. 37 5.2.7. Impacts of pooling...................................................................................................... 38 
5.2.8. Compatibility with the revised strategy on LDVs...................................................... 39 5.3. Social impacts ............................................................................................................ 40 
5.3.1. Employment aspect .................................................................................................... 40 5.4. Environmental Impacts .............................................................................................. 41 
5.4.1. Overall impacts in terms of emissions ....................................................................... 41 
5.4.2. Impact of the compliance mechanism........................................................................ 42 5.5. Additional costs to businesses and Member States.................................................... 42 5.6. Comparison of options ............................................................................................... 43 
EN 4   EN 5.6.1. Long-term target........................................................................................................ . 45 
6. Monitoring and evaluation ......................................................................................... 45 6.1. Core indicators of progress towards meeting the objectives...................................... 45 6.2. Monitoring arrangements ........................................................................................... 46 7. Reference Documents ................................................................................................ 46 
ANNEX I: GLOSSARY........................................................................................................... 48 ANNEX II: SUMMARY OF STAKEHOL DER CONSULTATION 02 SEPTEMBER 
2008 ........................................................................................................................... ............... 49 
ANNEX III: SUMMARY
 OF SECOND  STAKEHOLDER  CONSULTATION  09 
MARCH  2009........................................................................................................................... 53 
ANNEX IV: DISTRIBUTIONAL EFFECTS ON MANUFACTURERS............................... 59 ANNEX V DESCRIPTION OF THE METHODOLOGY ...................................................... 69 ANNEX VI: ECONOMIC IMPACTS ..................................................................................... 72 ANNEX VII: SOCIAL EQUI TY AND DISTRIBUTIONAL  EFFECTS WITHIN THE 
FLEET .......................................................................................................................... ............ 79 
ANNEX VIII: ENVIRONMENTAL IMPACTS ..................................................................... 80 
EN 5   EN 1. PROCEDURAL ISSUES AND CONSULTA TION OF INTERESTED PARTIES  
1.1. Background in the development of the proposal  
The proposal for the regulation on reduction of CO 2 emissions from light commercial 
vehicles (LCVs) is a continuation of the Co mmission's regulatory pr ocess to address the 
climate change impacts of road vehicles. This policy initiative started with the 
publication in February 2007 of two Comm unications: a Communication on the revised 
CO 2 and cars strategy1 and a Communication on a Comp etitive Automotive Regulatory 
Framework for the 21st Century CARS 212 (referred to as " the earlier Communications " 
in this document). On the basis of thes e Communications, the Commission proposed an 
integrated approach to achie ve the EU objective of 120 gCO 2/km from new passenger 
cars by 2012. Under this approach, legisla tive proposals would focus on mandatory 
reductions of CO 2 emissions to reach an average objective of 130 gCO 2/km for new 
passenger cars by means of improvements in vehicle motor technology. A further 
reduction equivalent to 10 gCO 2/km would be achieved by other technological 
improvements and increased use of bio-fuels. These include3: 
– setting minimum efficiency require ments for air-conditioning systems; 
– the compulsory fitting of accurate tyre pressure monitoring systems; 
– setting maximum tyre rolling resistance limits; 
– use of gear shift indicators;  
– fuel efficiency progress in light commerc ial vehicles (vans and minibuses) with 
the objective of reaching 175 g CO 2/km in 2012 and 160 gCO 2/km by 2015. 
In 2007 the Commission adopted a proposal for a Regulation4 setting emission 
performance standards for new passenger cars with the aim of limiting CO 2 emissions 
from new passenger cars to an average of 130 gCO 2/km. The proposal was accompanied 
by an extensive impact assessment5 (referred to as the 'impact assessment on CO 2 and 
cars'  in this document) that included a deta iled analysis of the economic, social and 
environmental impact of the regulation. The Council adopted the legi slative text agreed 
in co-decision in April 20096, further referred to as regulation on CO 2 and cars. 
                                                 
1 COM(2007) 19, 07.02.2007 
2 COM(2007) 22, 07.02.2007 
3 Several of these measures are estimated to have a negative cost so their ab sence in the market has 
to be considered as a market failure, possibly linked to the level of return that they provide. 
4 COM(2007) 856 final. Proposal for a regulation of the European Parliament and of the Council 
setting emission performance standards for new passenger cars as part of the Community's 
integrated approach to reduce CO 2 emissions from light-duty vehicles 
5 Accompanying document to the Pr oposal from the Commission to the European Parliament and 
Council for a regulation to reduce CO 2 emissions from passenger cars (SEC(2007)1723). 
6 Regulation of the European Parliament and of the Council setting emission performance standards 
for new passenger cars as part of the Community's integrated approach to reduce CO 2 emissions 
from light-duty vehicles (EC) no 443/2009 
EN 6   EN Light commercial vehicles were no t included in the regulation on CO 2 and cars due to the 
necessity to gather more data on LCVs. Th e current legislative proposal on the reduction 
of CO 2 emissions from light commercial vehicl es therefore supplements the regulation on 
CO 2 and cars and supports achievement of  the overall EU objective to cut CO 2 emissions 
from the new light duty vehicle fleet, by putting in place measures to reduce CO 2 
emissions from light commercial vehicles. Light commercial vehicles make up around 
12% of the light duty vehicle fleet. 
For the purposes of better regulation and administrative simplicity, the proposal on CO 2 
and light commercial vehicles should, where possible, be aligned with the legislation 
setting emission performance standards for car s. Therefore similar policy options will be 
reviewed to regulate CO 2 emissions from the light co mmercial vehicles fleet.  
Correspondingly, this impact assessment is si milar to the impact assessment developed 
for passenger cars. The policy options applicable for passenger cars and the resulting impacts were discussed in depth in the impact assessment on CO
2 and cars. In order to 
avoid repetition, this impact assessment will incl ude cross-references to that assessment.  
1.2. Consultation and expertise 
For the preparation of this legislation an inter-service group was set up and a meeting 
was organised on 23 July 2008 and 18 March 2009 in order to collect the views of 
various services. The servi ces involved in this group in cluded: DG Environment, the 
Secretariat General, DG Enterprise a nd Industry, DG Transport and Energy, DG 
Economic and Financial Affairs and Joint Re search Centre. The timing of the proposal 
development and the key aspects of the proposed  legislation were disc ussed in this inter-
service consultation. 
Stakeholder consultation process include d a public internet consultation and two 
stakeholders meetings. 
• Between May and July 2007, an internet publ ic consultation was carried out, aimed at 
gathering the views of all stakeholders  and members of the public on the 
implementation of the revised CO 2 and cars strategy. This included measures to 
reduce emissions from light commercial ve hicles. The majority of consultation 
responses are available at: http://ec.europa.eu/reducing_co2_e missions_from_cars/index_en.htm. 
The results of the consultation were presen ted in Annex III of the Impact assessment 
on CO
2 and cars therefore it will not be repeated here. 
• To complement the internet consultation, tw o stakeholder meetings were organised by 
the Commission on 02 September 2008 a nd 09 March 2009. This provided the 
stakeholders directly concerned by the upcoming legislation (a utomotive industry, 
suppliers, environmental NGOs, social partners  and Member States) the opportunity to 
present their positions. The summaries of bot h meetings are attach ed in Annex I and 
Annex II. 
In addition an external study investigating possible regulat ory approaches to reducing 
CO 2 from light-duty vehicles was carried out  and a study consis ting of two reports: 
EN 7   EN 'Assessment of options fo r the legislation on CO 2 emissions from light commercial 
vehicles'7and 'Assessment with respect to long term CO 2 emission targets for passenger 
cars and vans'8, has been developed. This study was part of a project 'Impacts of 
regulatory options to reduce CO 2 emissions from cars, in part icular on car manufacturers' 
under the framework contract ENV. C.5/FRA/2006/0071 (Service request ENV 
C5/GK/ak/D(2007)17850). Analysis of alternat ive policy options is based on findings of 
the two reports, further referred to as 'the supporting study on light commercial vehicles 
(LCVs)' .  
Input from stakeholders has been taken in to account in assessing the different possible 
options to regulate CO 2 emissions from light commercia l vehicles, particularly with 
regard to the design of the legislation, possi ble unwanted effects, and implications for 
competition on automotive markets, global indus trial competitiveness and environmental 
outcome. External expertise was used to asse ss the various options available, including 
aspects raised during the consultation process (t he external contractor  attended the public 
hearings). 
1.3. Results of the consultation of  the Impact Assessment Board  
A draft version of the impact assessment re port was submitted to the Impact Assessment 
Board on 25 March 2009 which issued it s opinion on the document on 28 April 2009. 
The final opinion stated that the impact as sessment should assess potential effects of 
pooling the CO 2 reduction targets for cars (Ml) and light commercial vehicles (LCVs) in 
more depth, including impacts on the curren t market structure and on administrative 
burden. The Board also requested that the imp lications of the changes introduced by the 
Legislator to the regulation on cars, which were not assess ed in the corresponding IA, 
should be discussed more explicitly. Finally, further analysis of th e potential impact on 
the external competitiveness of EU car manufacturers was demanded.  
These comments have been taken into account in the final impact assessment as follows: 
- Impacts of pooling between cars and LC Vs on the level of excess emissions 
premium as well as on manu facturers producing cars an d vans, or only vehicles 
of one category, were cl arified in section 5.2.7. 
– The link of this proposal to  the overall Strategy, incl uding other measures of the 
integrated approach (incl. CO 2 from cars proposal), has b een clarified in section 
5.2.8.  
– More attention has been given to the analysis of potential impacts of the 
legislation on the competitiveness of th e EU industry in th e third countries 
(section 5.2.2).  
                                                 
7 This report is available on Europa website under the following link: 
http://ec.europa.eu/environment/air/transport/co2/co2_studies.htm 
8 This report is available on Europa website under the following link: 
http://ec.europa.eu/environment/air/transport/co2/co2_studies.htm 
EN 8   EN – In addition, the aspects related to the t ype approval and monitoring of passenger 
cars and LCVs, and the impact of the sc heme on administrative burden, have 
been described in more detail in sections 2.4.3 and 5.5. 
2. CONTEXT AND PROBLEM DEFINITION  
2.1. The context of the initiative 
The overall rationale for the revised CO 2 and cars strategy, based on an integrated 
approach, and implemented through a legisla tive framework, has been analysed in detail 
in the earlier Communications and the impact assessment on CO 2 and cars. Key aspects 
are summarised here: 
• All sectors must contribute to the fight against climate change:  The EU has made a 
commitment to achieve at least a 20% re duction of GHG emissions by 2020 compared 
to 1990 levels, increasing to 30% as part of a comprehens ive international agreement. 
To avoid distortions, and for the sake of ec onomic and social fairness, all sectors must 
contribute to the reduction effort, including transport. While there is no binding EU 
target for transport sector, transport covers major part of the emissions under the Effort Sharing Decision
9 which requires a 10% reduction from 1990 levels by 2020; 
• The CO 2 performance of new vehicles s hould improve at a faster rate:  While the 
EU27 as whole has reduced its em issions of greenhouse gases (GHG10) by 5.2% over 
the 1990-2006 period, the GHG emissions from  transport have increased by 35.8% 
and in particular from road transpor t, GHG emissions have  increased by 29.3%11. This 
trend is partly linked to the limited progr ess in real world improvements in fuel 
efficiency (the average reduction of em issions over 2002-2007 for light commercial 
vehicles amounted to 0.4-0.5% per year), and pa rtly linked to the increase in transport 
activity. Existing policies to reduce CO 2 emissions and improve the fuel efficiency of 
new cars sold in the EU have not been able  to deliver the progress needed for reaching 
the long-standing EU objective to reduce th e average emissions of the new passenger 
car fleet to 120 g/km.; 
• Road transport needs to use less oil:  There is a direct link between improved fuel 
efficiency and lower CO 2 emissions. Road transport relies heavily on oil for which the 
EU's import dependency is higher than 80%. This has a significant impact on the EU's 
security of energy supply and makes th e EU economies more susceptible to oil 
shocks. In 2006, road transport accounted fo r 25.8% of the final energy consumption 
in the EU27; 
• Further reductions in CO 2 emissions must be achieve d cost-effectively without 
undermining sustainable mobility and the car industry's competitiveness:  Light duty 
vehicles are an important part of the ever yday lives of a large number of Europeans. 
Vehicles provide mobility, which is essent ial to European society and economy. In 
                                                 
9 Decision 2009/406/EC 
10 In road transport, CO 2 emissions account for 98% of  all GHG in this sector. 
11 Source: EC, DG for Energy and Transport, EU energy and transport in figures: Statistical 
pocketbook 2009. Figures are including International Bunkers but excluding LULUCF. 
EN 9   EN 2005, road transport accounted for around 86 % of passenger transp ort activity and 
approximately 70% of freight  transport activity in Europe. Europe is the world’s 
largest producer of passenger cars and light  commercial vehicles with around 30% of 
these vehicle types produced in Europe. The European automotive industry is a major component of Europe's manufacturing base . The vehicle industr y accounts for about 
20% of Europe’s manufacturing R&D inve stment (over €20 billion), contributed 
about €60 billion to Europe’s trade balance a nd contributes more than €350 billion in 
fiscal revenues, which represents about 8%  of the European Union's total general 
government revenues. Legislation to reduce the GHG emissions of light duty vehicles 
should not undermine the competitiveness of the automotive industry in Europe. 
2.2. Legal basis 
The proposal on light commercial vehicles  is similar to the Regulation on CO
2 emissions 
from passenger cars. The legal basis of that Regulation is Article 175 EC. The first recital 
of the Regulation states " The objective of this Regulation is to set emission performance 
standards for new passenger cars registered in  the Community which delivers part of the 
Community's integrated approach to reducing CO 2 emissions from li ght-duty vehicles 
while ensuring the proper functioning of the internal market ". The same applies to the 
current proposal on light commercial vehicles . Therefore the legal basis for the proposal 
is Article 175. 
2.3. Problem definition 
The main problem, concerning CO 2 emissions from all light duty vehicles was described 
in the impact assessment on CO 2 and cars. It states that:  
'The overarching problem  as identified in the earl ier Communications is that 
existing policies to reduce CO 2 emissions and improve the fu el efficiency of new cars 
sold in the EU have not been able to de liver the progress needed for reaching the 
long-standing EU objective of an av erage new light duty vehicles fleet CO 2 emission 
of 120 g/km.' 
The regulation on CO 2 and cars addresses CO 2 emissions from passenger cars as the 
main part of the implementation of the integr ated approach. At present light commercial 
vehicles, which make up around 12% of the li ght duty vehicles fleet, are not covered by 
the Community policies to reduce CO 2 emissions. However, the revised strategy 
COM(2007)19 identified fuel effici ency progress in light-commerc ial vehicles as part of 
the integrated approach to achieving th e Community objective of reducing emissions 
from new passenger cars to 120 g/km.  
A consultants report12 revealed that the number of light commercial vehicles (LCV) has 
been slowly increasing in European transpor t fleet (now making up 12% of the total road 
transport fleet13), and consequently that the share of CO 2 emissions from LCV is rising. 
Therefore, in order to reduce CO 2 emissions from the transpor t sector, it is necessary to 
introduce fuel efficiency measures for light co mmercial vehicles. Further, in the absence 
                                                 
12 TNO Automotive, Measuring and preparing redu ction measures for CO2 emissions from N1 
vehicles. Final report. (contract no. 04.OR.VM.050.1/DE)  
13 See Figure 3 
EN 10   EN of a regulation for light-commercial vehicles, there is a risk of a regulatory gap which 
could undermine the effectiveness of the regul ation on passenger cars (explained in more 
detail in section 2.4.3). 
The specific problem  therefore is to design a legislativ e instrument to limit emissions of 
CO 2 from light commercial vehicles. 
2.4. What are the underlying drivers of the problem? 
As far as overall CO 2 emissions from road transport are concerned, a wide range of 
factors influence the observed  and predicted growth in CO 2 emissions from passenger 
cars and light commercial vehicles. 
2.4.1.  Vehicle stock of LCVs is increasing 
According to the FLEETS14 report, the number of light duty vehicles has been increasing 
in Europe since 1995 (with the exception of gasoline vehicles in EU-15). The development of the stock is presented in Figure 1. 
Figure 1 Development of the LDV stock in Europe  (Source: FLEETS 2008) 
 
Note: GLDV = Gasoline LDV; DLDV = Diesel LDV 
Sales of light commercial vehicles accordin g to Global Insight have  been growing since 
2002. Figure 2 shows that in total sales of lig ht commercial vehicles increased by 24% 
during the period 2000-2007. 
                                                 
14 European Database of Vehicle Stock for the Ca lculation and Forecast of Pollutant and Greenhouse 
Gases Emissions with TREMOVE and COPERT (Contract No 070501/2006/451259/MAR/C5); Final report, 2008 
EN 11   EN Figure 2  Development of number of sales of light commercial vehicles in EU-27 
(source: Global Insight) 
0500.0001.000.0001.500.0002.000.0002.500.000
2000 2001 2002 2003 2004 2005 2006 2007 
This trend is also clearly visible in both, EU-15 and the new Member States (Figure 3) 
with share of diesel powered vehicles growi ng at the expense of petrol engines in both 
groups of countries. 
Table 1 N1 registrations in EU-15 and EU-12  (source: FLEETS report, 
http://lat.eng.auth.gr/copert/data.php ) 
 EU15 N1 registrations EU12 N1 registrations 
 1995 2000 2005 1995 2000 2004 
Stock ('000): 16 323 20 050 23 506 1 611 2 293 3 093 
 Diesel 10 950 15 357 19 854 781 1 047 1 255 
 Gasoline 5 342 4 657 3 596 830 1 245 1 836 
 LPG 31 35 55    
New registrations ('000): 1 241 1 739 2 076 386 211 301 
 Diesel 1 073 1 575 1 958 186 127 220 
 Gasoline 165 162 106 200 84 81 
 LPG 4 2 12    
The share of N1 vehicles (vans) in the total registrations of light- duty vehicles has been 
increasing at a steady rate from 1995 to 2005. This phenomenon can also be explained to 
some extent by growing number of large passen ger cars (e.g. SUVs) being registered as 
light commercial vehicles, mainly for tax pur poses (see sectio n 2.4.3). This trend is likely 
to be reinforced when the regulation on CO 2 from passenger cars st arts applying and no 
similar legislation on light-comme rcial vehicles is in place. 
EN 12   EN Figure 3 Registrations of vans (N1) and pa ssenger cars (M1) in EU27 (1995-2005)  
(source: EC) 
05 000 00010 000 00015 000 00020 000 000
1995 2000 2005M1
Passenger CarsN1N1
10%11%12%
 
2.4.2.  LCV driving pattern and mileages 
The driving patterns for LCVs are slightly di fferent than for cars. FLEETS study analysis 
shows that vans are mostly used in urban conditions (shorter distances, lower speeds, 
many restarts and periods of idling) which results in higher fuel consumption and 
therefore generates more CO 2 emissions than extra-urban, motorway driving. However, 
the EU average annual mileage of the whole fleet (old and new vehicles) has been found 
to be very close for LCVs and passenge r cars (M1), i.e. 13 971 km and 13 303 km 
respectively. This is also the case for new fleet whereby EU average annual mileage for passenger cars amounts to 17 113 km whereas for light commercial vehicles it is around 
20 000 km.
15 
2.4.3.  Potential regulatory gap linked to type  approval and registration procedures 
According to the Directive 70/156/EEC (ame nded), the light commercial vehicle (N1) 
category contains vehicles w ith maximum mass not exceedin g 3,5 tonnes which are used 
for the transport of goods. However, in pract ice many vehicles that  are homologated as 
passenger cars (category M1) are registered as  N1, often to take advantage of reduced 
taxation or other fiscal incentives. The de cision under which catego ry the vehicle is 
registered may be made independently from the homologation. Cars can also be easily 
adapted by distributors in order to allow the users to register these vehicles as LCVs. 
Therefore, the exact mix of N1 vehicles in total vehicle fleet is not entirely certain.16 
The 2008 report "European Database of Vehicl e Stock for the Calculation and Forecast 
of Pollutant and Greenhouse Gases Emissi ons with TREMOVE and COPERT" (FLEETS 
report) concluded that in EU15 passenger cars make up 4-58 % of N1 registrations. Data 
                                                 
15 TREMOVE baseline scenario 2005 
16 The database used in the supporting study was corrected in view of eliminating M1 vehicles 
registered as N1 from the dataset.  
EN 13   EN show that these are SUVs but also other l uxury and smaller vehicles, which are mainly 
used for the transport of passengers. Based on the FLEETS report analysis , it is clear that 
the number of N1-registered vehicles which ar e primarily used for the transport of people 
and not goods is quite significant. 
Table 2 EU15 sales and actual registra tions of N1 vehicles in 2005  (source: FLEETS 
report) 
EU15 Total sales of N1 models Total N1 M1 models  share in 
AT 32 285  8 004 28 878 4 597  16% 
BE 74 879  24 374 62 672 12 167  19% 
DE 322 801  129 019 202 335 8 553  4% 
DK 29 730  5 249 58 079 33 598  58% 
ES 240 213  3 051 387 203 150 041  39% 
FI 17 609  2 230 16 211  832  5% 
FR 347 898  77 583 420 065 149 750  36% 
IT 163 391  26 059 218 514 81 182  37% 
LU 4 387  1 621 3 064  298  10% 
NL 68 978  7 794 66 236 5 052  8% 
PT 33 518  1 260 66 774 34 516  52% 
SE 34 106  4 438 35 095 5 427  15% 
UK 291 475  17 975 330 436 56 936  17% 
In addition, there are no constraints on dr ivers consequent on the type approval of a 
passenger car as N1 because the same drivi ng licence is required and insurance premiums 
are not significantly higher.  
The scope of the legislation on passenger ca rs, and also of the proposed legislation on 
light commercial vehicles, is linked to the t ype of vehicle (M1 or N1) as homologated 
under Directive 2007/46/EC. Therefore, the re gistration practice in the Member States 
regarding M1 versus N1, as described above, does not affect the scope of the legislation. 
This means that even vehicles type approve d as passenger cars but registered as LCVs 
will fall under the scope of the regulation on CO 2 and cars. However, the presence of a 
certain degree of overlap between the re gistrations for passe nger cars and light 
commercial vehicles suggests that there is a risk of market respons es if one category of 
vehicles is subject to legislation on CO 2 emissions whereas the other is not, leading to the 
risk of an unintended regulatory gap. The ab sence of regulation for LCVs could create 
incentives for manufacturers to type approve  large passenger cars as light commercial 
vehicles in order to avoid the mandatory CO 2 standards for passenger cars. 
EN 14   EN For this reason, the legislation for M1 categ ory and N1 category s hould preferably enter 
into force in the same time – the longer th e gap between the legi slation, the bigger the 
incentive for inappropriate type approval. 
2.5. Stakeholders affected 
The proposed regulation will have an impact on a number of stakeholder groups, 
however the scale of the effect should not be  as large as in the case of passenger cars. 
The share of light commercial vehicles pr oduced by the automobile manufacturers in 
Europe is much smaller than the share of cars. According to ACEA statistics, light 
commercial vehicles (below <3.5 t) amount to  10% of total motor vehicle production in 
the EU.  
Major stakeholder groups affected include the general population, vehicle consumers, car 
manufactures, automotive component suppliers and fuel suppliers: 
• The population of the European Union is increasingly affected by climate change 
through the increased climate variability and more freque nt extreme weather events, 
and their related impacts. 
• The buyers of vehicles are a ffected by possible increases in  the price of new vehicles 
and reductions in their running costs, due to stricter requirements on CO 2 emissions 
and the related improvements in fuel  consumption. The regulation on light 
commercial vehicles (LCVs) however will have a less important impact on private consumers than the regulation on CO
2 and cars, because there are fewer LCVs 
purchased for individual use. On the othe r hand, users with spec ific applications 
(police and security organisations, postal and parcel delivery services; 
telecommunications and other infrastructure  services suppliers) will be affected. 
• The manufacturers of LCVs will be affected  by the obligation to comply with the new 
regulatory scheme to reduce CO 2 emissions. Manufacturers will have to introduce 
technical CO 2 reduction measures. In the short-term, this is likely to result in 
increased production costs and could affect th e structure of their product portfolios. 
However, given that demand for low carbon vehi cles is likely to increase throughout 
the world as climate change policies conti nue to develop, manufacturers have an 
opportunity to gain first mover advantage, providing them with a possibility to export 
advanced low carbon vehicles to other markets. 
• Component suppliers will also be affect ed by increasing demand for advanced 
technologies. They are likely to benef it from the higher demand for low carbon 
technologies. As with the automotive manufacturers they may also benefit from the 
possibility to export these advanced technol ogies to other markets around the world.  
• Fuel suppliers will also be affected. They ar e likely to see lower demand for transport 
fuels as a result of  the legislation. 
• Small and medium enterprises (SMEs), us ing light commercial vehicles will be 
affected by possible increases in the price of new vehicles and will benefit from 
reductions in their running costs that will result from the legislation.  
EN 15   EN 2.6. Current economic situation 
The financial crisis that be gan in the second half of 2008 has had profound impacts on 
the economy, including the automotive sect or. In February 2009, the Commission 
adopted a Communication on "Responding to th e crisis in the European automotive 
industry" (COM(2009)104). Th e Communication notes three major reasons for the 
difficulties being experienced by the European automotive industry: 
1. A sharp and uniform drop in demand for passenger and commercial vehicles 
both in the EU and worldwide. In the la st quarter of 2008 new car registrations 
in Europe declined by an average of  20%. New passenger car sales fell by 1.2 
million in 2008. In January 2009, the European passenger car market was 27% lower than a year before. 
2. Parts of the automotive industry are re porting problems with access to credit 
financing and fears of liquid ity shortages. In addition,  suppliers are expressing 
an additional concern about money not moving down the supply chain.  
3. The industry suffers from longer-term stru ctural problems pre-dating the crisis 
including a very competitive business environment, high fixed costs, structural overcapacity and intensive price competition. The average overcapacity in Europe is estimated to be at least 20%.  Globally, vehicle production capacity is 
currently at ca. 94 million per year at a time when demand for 2009 is estimated at ca. 55 million. 
The accumulative figures of new car registrations in Europe (EU-27 and EFTA) in the 
period from January to August 2009 showed an 8.2% drop as compared to the same 
period in 2008.
17 This trend is even more severe  for light commercial vehicles. The 
number of registrations of new light commercial vehicles18 in the same period in 2009 
was 37.4% lower than in the previous year19. A reduction in demand is likely to lead to 
continued production decreases, following estimat es of reductions by 25 % in the first two 
quarters of 2009 alone. This exceeds a forecast made in autumn of 2008 although the 
downturn expected is of a comparable magn itude (see Figure 4 below). This figure also 
illustrates that if the downturn turns out to be  as anticipated, it will be comparable to 
earlier such events although on a higher overall sales level. 
                                                 
17 ACEA 
18 In ACEA's statistics vans are defined as LCVs up to 3.5t. 
19 ACEA 
EN 16   EN Figure 4 Trend level of car sales on the western European market (1960 – 2012)  
[Source: Global Insight] 
 
On a more positive note, the Communication al so points out that the long term global 
outlook for the automotive industry is promisin g as world-wide demand for vehicles is 
projected to double or even tr iple in the next 20 years, and that the imperative of a 
"greener" car fleet will bring new op portunities for innova tive technology.  
Building on the re-launched Lisbon partne rship for growth and jobs in 2005, the 
European Economic Recovery Plan20 identified the automotive sector as requiring a 
strong policy response. As noted  in the Communication, a key priority for the automotive 
industry in this context will be to master th e triple challenge of technological leadership 
with an environmental and safety pe rformance that is world class.  
In the Communication the Commission undertook to weigh up the costs and benefits of 
any new legislative initiative and seek, as fa r as possible, to avoid creating new economic 
burdens. It also announced that, together wi th the European Investment Bank and the 
Member States, which are increasingly undert aking measures to s upport the automotive 
industry (e.g. scrapping schemes), it would s upport industry in their efforts to maintain 
investments into future tec hnologies (particularly  green technologies  such as fuel 
efficiency and alternative propulsion) thr oughout the economic dow nturn. This support 
will be provided primarily through the Europ ean Investment Bank as well as through the 
7th Research Framework Programme. 
On 5 March 2009, the Competitiveness Council adopted conclusions on the automotive 
industry in which it stressed that “ the main principles of the  [CARS-21] mid-term review 
should remain the guiding forc es for the future decision- making process, while applying 
thoroughly the better regulatio n principles, namely through im pact assessments, in order 
to guarantee predictability and lega l certainty for the businesses ”. In this respect, the 
Council invited the Commission to “ thoroughly assess any po ssible new legislative 
                                                 
20 Communication from the Commission to the European Council of 26.11.2008, "A European 
Economic Recovery Plan" - COM(2008) 800. 
EN 17   EN initiative in line with these principles and avoid unnecessary administrative burdens on 
businesses ”. 
In the context of the considerations outlined above, the arguments for making a proposal 
now or at a later stage have to be weighed up against each other.  
On the one hand, it can be argued that in a time of economic crisis the focus of action 
should be on addressing the short-term issu es and that, given the difficulties being 
experienced by the industry to access fina nce, new action should be postponed.  
However, there are a number of arguments in support of making a proposal now. First, 
there is a need for pla nning certainty in the indus try. The need to reduce CO 2 emissions 
from all sources including road transport is undisputed and has not changed as a result of the economic crisis. It is therefore clear th at emissions will have to come down, and the 
industry needs to know as soon as possible what is required.  Given that demand for low 
carbon vehicles is likely to increase throughou t the world as climat e change policies 
continue to develop, there could be some first mover advantage for European based 
manufacturers, providing them  with ability to export adva nced low carbon vehicles to 
other markets. 
Second, the Decision on Effort Sharing
21 that has been agreed as part of the package on 
energy and climate in December 2008 puts an obligation on Member States to reduce their greenhouse gas emissions from the sectors not include d in the Emissions Trading 
Scheme. Failure to address one source of emissi ons implies more effort in other parts of 
the non-ETS sector, which are probably a ffected by current crisis as well.  
Third, the regulation of emissions from li ght commercial vehicles is an outstanding 
element in the implementation of the Commi ssion's Integrated Approach to reducing CO
2 
emissions from light-duty vehicles.22 As the boundary between cars and light commercial 
vehicles is not fully clear-cut, there is a ri sk of creating a loophole in the legislation on 
CO 2 and cars unless light commercial vehicles ar e also subject to similar legislation (see 
section 2.4.3).  
2.7. Baseline scenario 
The existing historical data on the development of CO 2 emissions from light commercial 
vehicles is very limited. This provides ch allenges for projecting the trends of the 
emissions development in the future.  
The supporting study on light commercial vehicl es revealed that the new fleet average 
emissions in 2007 amounted to about 203 g CO 2/km whereas the average of emission 
level of the whole fleet was 230 g/km23. To develop baseline scenario going forward, 
estimations of the development of CO 2 emissions in light commercial vehicles between 
2002 and 2007 were made. The same study suggested that manufacturers applied efficiency improvements to passenger cars in the context of the voluntary agreements. As these agreements do not apply to light commercial  vehicles, it is likel y that the amount of 
                                                
 
21 Decision 2009/406/EC 
22 COM(2007)19 
23 Source: TREMOVE 
EN 18   EN CO 2 reduction measures applied in vans and mi nibuses is lower. According to the TNO 
2006 study the baseline value for 2012 in the absence of a policy aimed at efficiency improvements in light commer cial vehicles, based on the 2002 average of 201 g/km, is 
expected to be around 190 g/km for newly registered ve hicles. This estimate is based on 
assumed autonomous efficiency improve ments stemming partly from technology 
improvements diffusing into light vans from eq uivalent passenger cars. This corresponds 
to a decrease of the average CO
2 emissions by about 0.5-0.4% per year, or 1 gram per 
year. However, the analysis of the 2007 data in the supporting study shows that the average CO
2 emissions for light commercial ve hicles increased to 203 g/km and 
concluded that the majority of vans and minibuses are diesel ve hicles. It is expected that 
implementation of additional efficiency improvements for diesel vehicles will generally be more costly to manufacturers than improv ements to petrol vehicles. Therefore, it 
should be assumed that it is unlikely that  many improvements will occur in the absence 
of regulatory incentives to manufacturers.  
Further, it is possible that an inverse tr end could develop in the absence of legal 
constraints, potentially resulti ng in an increase in average CO
2 emissions. This would 
occur if the benefits of impr oved engine technology were offs et by an increas e in engine 
power and vehicle mass. However, measures developed by Member States to address 
transport emissions, including fiscal measures , rising prices of fuel and technological 
improvement in passenger cars resulting from the adopted CO 2 and cars legislation 
(likely to be also applied to smaller car-deriv ed vans) could be expected to trigger a more 
rational approach to fuel efficiency of LCVs.  
To understand the baseline scenario in terms of total CO 2 emissions from light 
commercial vehicles, it is necessary to take  into account the dema nd for these vehicles. 
The FLEETS report suggests that the number of light commercial vehicles has been 
increasing in Europe for the last ten years a nd this trend is confirmed by the data from 
Global Insight (see Figure 2) on th e increase of sales of LCVs. 
Figure 5: TREMOVE baseline scenario for CO 2 emissions from N1 (source: 
TREMOVE)  
CO2 emissions from vans (N1)
TREMOVE baseline scenario
0102030405060708090
1995 2000 2005 2010 2015 2020 2025 2030Mt CO2 (exhaust)
 
EN 19   EN As a result, the overall CO 2 emissions from light commercial  vehicles will also increase 
in a business as usual scenario. These resu lts are confirmed in the TREMOVE baseline 
scenario (see Annex V for de tails on TREMOVE) on Figure 5.  
2.8. Does the Union have the right to act? 
Similarly to the Regulation setting CO 2 emissions standards for passenger cars, the 
subsidiarity principle is respected by this proposal, as the policy objectives cannot be 
sufficiently achieved by actions of the Member States and can be met more efficiently at 
the Community level. EU action is necessary in  order to avoid the emergence of barriers 
to the single market in the automotive sector and because of the transnational nature of 
climate change. The absence of action at the Eu ropean level risks resulting in a series of 
national schemes to reduce CO 2 emissions of light commerci al vehicles. This would be 
of particular disadvantage to vehicle ma nufacturers as differing ambition levels and 
design parameters would require a wide range of technology options and vehicle 
configurations. Such market fragmentation would also affect consumers who would not 
benefit from lower costs and economies of scale that an EU  wide policy would deliver. 
3. OBJECTIVE  
3.1. Policy objectives  
The general policy objectives applicable for the legislative proposal on light commercial 
vehicles are similar to those develope d for the cars proposal. These are:  
• Providing for a high level of environmenta l protection in the European Union and 
contributing to reaching the EU's  climate change targets; and 
• Reducing oil consumption and thus improvi ng the security of energy supply in the 
EU. 
The specific objective is: 
• To reduce the climate change impacts and improve the fuel efficiency of light 
commercial vehicles by means of a specified  emission reduction for new vehicles in 
line with the revised strategy COM(2007)19. 
The operational objectives include: 
• Designing a legislative proposal that effi ciently implements the fleet average 
emissions target for new LCVs and pr events any regulatory gap which could 
undermine the effectiveness of the regulation on CO 2 and cars; 
• Making the legislation compatib le with the regulation on CO 2 and cars for reasons of 
simplification; and 
• Providing a regulatory framework that avoids any unjustified distortion of competition 
between automobile manufacturers.  
EN 20   EN 3.2. Consistency with horizontal objectives of the European Union 
Consistency of the legi slative proposal on CO 2 and passenger cars with horizontal 
objectives of European Union was extensively documented in that impact assessment. As this proposal is similar, most  of the same considerations apply. These are summarised in 
the following sections. 
3.2.1.  Lisbon Strategy 
The policy objectives of the revised strate gy, which includes both, passenger cars and 
light commercial vehicles, are in line with the three pillars of the European Union’s 
Lisbon strategy, namely " making Europe a more attrac tive place to invest and work ", 
"knowledge and innovation for growth " and " creating more and better jobs ". 
• The policy objectives promote innovation a nd technological development, because 
tighter requirements on CO
2 emissions and fuel efficiency  for light duty vehicles will 
encourage the development and applic ation of new vehi cle technologies; 
• In the longer term, it is expected to lead to increased competitiveness in the 
automotive sector. Technological innovation that  is required to ach ieve the objectives 
is one of the main prerequisite for long-term competitiveness.  
• It will increase a demand for highly qualifie d jobs in Europe. Development of the 
technologies needed to achieve emission reductions requires high skilled human 
resources to generate high value added solutions.  
• The policy objectives are also consistent with the approach taken in the European 
Economic Recovery Programme to support the industry by encouraging it towards 
'tomorrow's markets'. 
3.2.2.  Sustainable Development Strategy  
The overall objective of the Renewed Sustaina ble Development Strate gy (RSDS) of the 
European Union24, regarding sustainable transport is " to ensure that our transport 
systems meet society’s economic, social and environmental needs whilst minimising their 
undesirable impacts on the economy, society and the environment ". The related 
operational objective is to achieve sustainable levels of transport energy use and reduce 
transport greenhouse gas emissions. 
• The policy objectives of the proposed regula tion on light commercial  vehicles are in 
line with the RSDS. The requ irements of the proposed re gulation will contribute to 
more sustainable mobility. Cleaner light commercial vehicles will bring economic, 
social and environmental benefits through reduced CO 2 emissions and fuel 
consumption.  
• The proposed regulation is consistent with the operational object ive of the Strategy: 
'promoting sustainable consumption and production by addressing social and 
economic development within the carryi ng capacity of ecosystems and decoupling 
                                                 
24 European Council, June 2006 
EN 21   EN economic growth from environmental degrad ation'. Improving the fu el efficiency of 
vehicles will support the decoupling of economic growth from environmental 
degradation through reduced greenhouse gas emissions.  
3.2.3.  EU commitments to reduce GHG emissions 
In December 2008 the Council and the Parliament reached an  agreement on the climate 
and energy package of legisla tion to implement the EU's climate change commitments to 
be met by 2020, namely to reduce greenhouse ga s emissions by at least 20%, to ensure 
that 20% of final energy consumption is met wi th renewable sources, and to raise energy 
efficiency by 20%. The package also contains a clear offer to go further and commit to a 30% cut in the event of a satisf actory international agreement. 
• The proposed Regulation to reduce CO
2 emissions from light commercial vehicles 
will make an important contribution to the reduction of GHG emissions in the non-
ETS sector of the economy which includes tran sport, buildings, agri culture and waste, 
representing some 60% of total GHG emissions in the EU. By 2020, emissions from these areas are to be reduced by an aver age of 10% compared to 2005, shared out 
between Member States. Section 5.4.1 inte r alia concludes that reductions of 
emissions resulting from the proposed regulation on CO
2 emissions from light 
commercial vehicles will by year 2020 co rrespond roughly to 5% of the total EU 
reduction effort. 
4. POLICY OPTIONS  
4.1. Introduction 
An extensive discussion on the appropriate policy instruments that should be used to 
improve fuel efficiency and performance in terms of CO 2 emissions in lig ht duty vehicles 
took place in the context of the Commissi on's Communications a nd the proposal for a 
Regulation CO 2 and cars. The conclusion of this discussion was that voluntary 
agreements with industry did not bring the expected outco me and that a regulatory 
approach was the best solution to tackle the problem of rising CO 2 emissions from light-
duty vehicles. 
In view of growing demand for LCVs (see s ection 2.7) and the EU target to reduce CO 2 
emissions by 2020 by 20% (or by 30% if a co mprehensive international agreement is 
reached), it is clear that all sectors have to contribute to the re duction effort. Emissions 
from LCVs represent ar ound 1.5% of EU total CO 2 emissions and it is imperative that 
growing emissions from LCVs do not undermine the efforts to reduce emissions in other 
transport modes and sectors of the EU economy.  Moreover, there is a strong rationale for 
regulating other sectors of ro ad transport in order to avoid creating a regulatory gap 
which could undermine the effectiv eness of the regulation on CO 2 and cars by enabling 
larger and highly emitting passenger cars to av oid the target (see section 2.4.3). For these 
reasons, the business as usual option has been discarded from further analysis. 
The intention of the proposed regulation on CO 2 from light commercial vehicles is to 
ensure that all light duty vehi cles are covered by similar legi slation to that agreed in 
December 2008 for passenger cars. There ar e no obvious reasons for a significantly 
different policy mechanism for LCVs than that  agreed upon for cars. Therefore, there is a 
EN 22   EN strong degree of guidance for many of the design parameters and policy options to be 
discussed in this impact assessment.  
The legislation for LCVs needs to take into  account the differences between the markets 
for passenger cars and for light-commercial vehi cles and some stake holders argue that a 
different approach is therefore needed. Although a substantial part of LCV sector is very 
similar to cars and uses the same technol ogy (car-derived vans, mostly found in mass 
class I and II), heavier LCVs are less like cars and the heaviest vehicles are more akin to lighter heavy-duty vehicles. Further the market  in passenger cars is highly heterogeneous. 
However, despite these differences, the legisl ation on the emission of air pollutants from 
road vehicles deals with LCVs of all mass classes in the same manner as cars.
25 Indeed, 
the concept of mass classes I, II and III is laid down in that legislation and only used 
there. It is necessary to find a balance between consistency with existing legislation and adaptation to the specificities of the sector. The approach ch osen for the current proposal 
is to design the legislation on LCVs to be as  similar as possible to the one on cars except 
where there are justifications for taking a di fferent approach for LCVs (such as limit 
value and slope of the utility curve). 
4.2. Design parameters  
The main design aspects to be discussed in  this section are effort sharing between 
manufacturers, possible flexibility mechanisms and the compliance mechanism.  
4.2.1.  Scope of the legislation 
In order to ensure that the obj ectives of the current proposal are met, it is important that 
the scope of the legislation does not create a ny additional regulatory gaps. Therefore, it is 
important that vehicles whic h directly compete with N1 but are not covered by other CO
2 
emissions standards are also included into the scope of the regulation. This is the case of 
lighter N2 and M2 vehicles which are derived from N1 category but due to certain 
features, i.e. higher mass or higher number of seats are categorised as N2 or M2 vehicles. 
In the absence of CO 2 standards for lighter N2 and M2 th ere is a risk of creating perverse 
incentives for manufacturers to further incr ease mass of heavier N1 and type-approve 
them as N2 to avoid CO 2 standards. In one specific example of a widely used van, the N2 
version of the vehicle is only 190 kg heavier than its N1 counterpart. 
The scope of Regulation (EC) 715/2007 on type approval of motor vehicles with respect 
to emissions from light passenger and commerci al vehicles (Euro 5 and Euro 6) and on 
access to vehicle repair and maintenance inform ation includes vehicles of the N2 and M2 
categories with a reference mass not exceeding 2610 kg or to which type-approval has been extended in accordance with Art. 2(2)  of the above Regulation (with a mass up to 
2840 kg). It would seem advisable to make us e of the same scope for the purposes of 
regulating the CO
2 emissions of LCVs. 
This would ensure that vehicl es of similar physical characte ristics that compete directly 
in the same markets are covered by the same legislation, while leaving the heavier vehicles in the M2 and N2 classes out of the scope (N2 vehicles can reach a maximum 
mass of up to 12 tonnes). 
                                                
 
25 Regulation(EC) 715/2007 
EN 23   EN 4.2.2.  Effort sharing between manufacturers 
The key approaches to share regulatory effo rt between manufacturers are as follows: 
• Utility based targets : in this approach, the CO 2 obligation is defined as a function of a 
so-called "utility" parameter reflecting the ut ility of vehicles perceived by customers.  
• Percentage reduction based targets : in this approach, the CO 2 obligation is defined as a 
function of a percentage emission reduc tion compared to earlier emissions 
performance.  
Under the utility based target option  approach, a utility curv e would be developed to 
reflect the fact that different vehicles have different utilities and emit different levels of 
CO 2. The average reduction target would be di stributed between vehi cles of different 
sizes according to their utility  (i.e. recognising that a large van capable of carrying a large 
load emits more than a small van with a much  lower load carrying capability). As regards 
developing the utility function,  a linear approach c ould be used in dist ributing the target 
amongst different vehicles and manufacturers.  
In earlier studies on light commercial vehi cles, a range of utility parameters was 
discussed including maximum payload, gross vehicle mass, loading volume, footprint 
and pan area. The supporting study concluded that  in view of the available data and for 
reasons of practicality, only  functions based on vehicle mass  and on vehicle pan area  
could be analysed. 
Figure 6 presents distribution of CO 2 emissions in relation to mass and pan area. A sales 
weighted regression line also demonstrates that either of these parameters is suitable as they show a reasonable correlation to CO
2 emissions. There are a number of outlying 
models on both graphs. However, the scatter for pan area is wider meaning that more 
models are further from the limit value curve. 
Figure 6 Sales-weighted correlation (least squares) between CO 2 emissions and two 
principal utility parameters for petrol  and diesel models- 2007 LCV database  
(source: supporting study on LCVs) 
 
The option of a percentage based CO 2 reduction  will also be considered as an alternative 
option to the utility based target. The percenta ge based reduction target would mean that 
EN 24   EN a proportionate emissions reduction would be re quired relative to the existing base level. 
This would be an alternative way to di stribute the burden among manufacturers. In 
practical terms it means that producers of vehicles emitting higher amount of CO 2 would 
have to deliver higher absolu te reduction of emissions. Ho wever, it does not recognise 
the efforts of those manufacturers who ha ve already taken early action to reduce 
emissions of their products. 
4.2.3.  Target level 
The supporting study on light commercial vehicles  analysed the target levels set in the 
revised Strategy on CO 2 emissions from light duty vehicl es, that is: 175 g/km target in 
2012 and 160 g/km target in 2015. Since the revised Strate gy was published in January 
2007, there have been major developments such as the improvement of the available dataset and the agreemen t of the Regulation on CO
2 and cars which create a need for 
reconsideration of the target dates. 
• The target of 175 gCO 2/km by 2012 set in the revised strategy is found in the 
supporting study to be demanding given the pr oximity of the target date of 2012. It 
appears desirable to also cons ider an option to postpone the introduction of this target 
to a later date (2013- 15). In further analysis  the level of 175 gCO 2/km will be tested 
with different utility parameters and slopes. 
• The target of 160 g/km in 2015 set in the revised strate gy does not appear to be 
realistic in this timeline according to the supporting study. Therefore, it is discarded 
from further analysis. However, a second step is considered as part of the discussion 
of the long term target (section 4.2.9). 
4.2.4.  Target year 
The revised Strategy on CO 2 from light-duty vehicles set the CO 2 emission target for 
passenger cars of 130g/km and set the CO 2 emission target for light-commercial vehicles 
of 175 g/km for 2012. This is the date for which targets will begin to apply for passenger cars (phased-in with full implementation in 2015). Given the time needed for the 
agreement of the legislation in the co-decision procedure, to allow su fficient lead-in time 
for the industry and to take into consid eration the current economic situation (in 
particular more difficult acce ss to finance (see section 2.6)  additional target years from 
the range 2013 – 2015 will be considered. 
The timeframe for LCVs should be consistent  with that for cars where the limit value 
becomes binding in the year 2012. The proposal  for a Regulation on passenger cars was 
made in December 2007, it was agreed in co-decision in December 2008 and formally adopted in June 2009. A similar tim etable would indicate entry into force of the standard 
for light commercial vehicles by mid-2013.  
4.2.5.  Utility curve slope 
The choice of the slope of the utility curve and utility parameter determine the 
distribution of reduction effort between vehicles and as a consequence between 
manufacturers. The impact assessment on cars included an analysis of a wide range of 
EN 25   EN utility curve slopes26, starting from 0% slope to 120% slope. For passen ger cars a 60% 
slope was selected. In order to rationalise th e impact assessment on vans and minibuses a 
number of options short-listed for fu rther thorough analysis is reduced. 
Utility curves with lower slopes i.e. 0% to  40% seem less suitable for LCVs than for 
passenger cars where perverse incentives of  increasing mass in order to gain a less 
stringent target are of greater concern. Light  commercial vehicles are used to transport 
goods therefore there are fewer incentives to ma ke them heavier. A mass increase is done 
at the expense of payload or performance which then needs to be compensated by 
increased engine power leading to higher ve hicle cost. Also market shifts on the LCV 
market are usually not driven by such incentives as luxury or increased comfort, which 
could also increase the mass of a vehicle, but  rather are driven by business needs (with 
the exceptions of LCVs also being used for private purposes). The supporting study on LCVs explains different gaming options in ch apter 7 and considers th at the likelihood of 
mass increase being used by manufacture rs as a means to reduce required CO
2 reduction 
effort is considered less significant for LCVs than for passenger cars. Thus, only the 
upper range of utility curve slopes: 60%, 80%, 100% and 120% will be analysed in 
detail in this impact assessment. However, re duction effort for lower slopes will still be 
presented for completeness. 
4.2.6.  Choice of average utility value in the definition of the limit value curve 
The formula for a limit value based on a utility parameter, M, can be written as follows 
(for the case of a target value of 175g/km, and assuming mass as th e utility parameter): 
CO 2 level = 175g/km + a × (M – M 0), 
where a is the slope of the limit value curve and M0 is the average mass of the fleet. This 
formula only delivers the desired CO 2 fleet average if the real, physical average mass of 
the fleet coincide s with the value M0 assumed in the formula. If the figure M0 is too low, 
the limit value curve will be too far to the left and the fleet average delivered by the 
legislation will be higher than desired. Conversely, if the figure M0 is too high, the limit 
value curve will be too far to the right and th e fleet average delivered by the legislation 
will be lower than expected. In practice, th e real average vehicle mass is not known in 
advance. It has been observed to rise over time both for cars and for LCVs. This phenomenon is known as "Autonomous Mass Increase" (AMI) and has been discussed at length in the context of the Impact Asse ssment for passenger cars and its underlying 
study. 
Further to the analysis conducte d in the impact assessment on CO
2 from passenger cars, 
an account of possible future developments of the market for light-commercial vehicles 
is taken. An autonomous mass increase can happ en as a result of ad ditional applications 
to improve safety, comfort or performance with in a vehicle class, or due to the overall 
average mass increase resulting from increasing sales of vehicles from higher classes. In 
general this phenomenon is less true for LCVs as explained above. In addition, a shift towards larger vehicles may also mean that CO
2 performance in terms of emissions per 
tonne kilometre may be improved. 
                                                 
26 See Glossary in Annex I 
EN 26   EN The analysis conducted by the consultant was done on the basis of different autonomous 
mass increase (AMI) scenarios: 0%, 0,82% an d 1,5%. Contrary to the study for cars, an 
extreme scenario of AMI equal to 2,5% wa s excluded as an unlikely trend for LCVs. 
Further analysis will focus on two options 0% and 1,5%. The effects on costs and the 
distributional impacts for AMI=0,82% will not be presented explicitly in chapter 5 
however, the expected results would be roughly halfway between the two remaining 
scenarios. 
Two approaches can be used to handle AMI in practice. First, a plausible value of AMI 
can be used to make a projection into the futu re and thus to determine an expected value 
of M0 in advance. Second, an  ex-post adjustment of M0 can be done every few years, thus 
enhancing planning certainty for the industry while ensuring th at the actual value of the 
average mass is never too far away from the chosen value of M0. This second approach is 
applied in the Regulation on CO 2 from cars and it appears sensible to take the same 
approach in the case of LCVs.  
4.2.7.  Flexibility mechanisms  
To increase a level of flexibility for manufact urers to comply with the regulation, it is 
important that appropriate mechanisms are introduced. Mechanisms to be considered include options of fleet averaging, pooling, and derogations for small volume independent manufacturers: 
• Fleet averaging
: manufacturers could average their CO 2 emissions over their fleet 
(rather than having to respect a target for each car they sell). The model assumes that 
manufacturers would choose to deliver the chea pest reductions first. This approach is 
consistent with the one in the CO 2/cars legislation. 
• Pooling between manufacturers:  manufacturers could do the same fleet averaging 
amongst companies belonging to the same gr oup; similarly differe nt manufacturers 
could be allowed to create a pool on their own initiative and trade the credits they need, should this he lp to optimise the cost of delivering CO
2 reductions needed. This 
solution is also permitted in the CO 2/cars regulation. 
• Pooling of the targets for cars (M1) and LCVs  would mean that manufacturers can 
compensate underachievement in terms of CO 2 g/km in one category by an equivalent 
overachievement in the other category. This flexibility would allow manufacturers to 
minimise their abatement cost by choosing to reduce more in a category where it is 
cheaper. According to the supporting study this  would be the case fo r the majority of 
manufacturers producing both passenger ca rs and LCVs. Pooling between cars and 
LCVs would lead to a net cost reduction compared to the situation in which both 
targets have to be met separately but would introduce competitive advantage for manufacturers producin g both cars and vans. 
• Specialist derogation for small volume independent manufacturers:
 some specialised 
independent manufacturers who make small num bers of vehicles may not be able to 
take advantage of the types of flexibility  identified above (e.g. through a lack of 
pooling partners) and therefore may need a dditional flexibility. A limited number of 
derogations are included in the CO 2/cars legislation. 
EN 27   EN 4.2.8.  Compliance mechanism 
Following the approach taken in the impact assessment for regulation on CO 2 and cars 
the excess emissions premium has been iden tified as being the most suitable way of 
enforcing the regulation. The level of pr emium is of crucial importance for the 
effectiveness of the scheme as well as co mpetitiveness of the automotive industry. Under 
the regulation on CO 2 and cars, the premium is calculated at the manufacturer level after 
fleet averaging (which would allow low emittin g vehicles to offset vehicles above the 
limit). The premium is calculated as the produc t of the distance to target (in grams per 
kilometre) multiplied by the premium level (€ per gram per kilometre) and by the number 
of vehicles registered for which the manu facturer under consideration is responsible. 
The impact of selected levels of excess em issions premium (EEP) is evaluated in terms 
of deterrent effect against non-compliance and competitiveness.  
The premium must be set at a level whic h deters non-compliance whilst taking into 
account the effect on global competitiveness an d the automotive value chain's ability to 
continue contributing to the Growth and Jobs agenda . The level of the EEP under the 
Regulation on CO 2 and cars was set by reference to the marginal CO 2 abatement cost 
through vehicle technology. This rationale also applies to the setting of the EEP for light-
commercial vehicles. Together with the co mpetitiveness dimension, it should also be 
taken into account that manu facturers do not have full control over the average of their 
sales in a given year and the ta rget is defined as the average of all the vehicles placed on 
the market. This creates a margin for erro r. Manufacturers can re duce the risk through 
putting in place continuous sales monitoring or through introducing a safety margin for 
uncertainties. The Regulation on CO 2 and cars addresses this situation by allowing a 
lower premium level for the first few grams pe r kilometre above the target (the so-called 
corridor approach). This corridor of reduced  premium levels extends until the year 2018 
and subsequently ceases to apply. It can be  assumed that by that time the manufacturers 
have gained sufficient experi ence with the regula tory system and the response of the 
market so the corridor is no longer needed. The co rridor is therefore a risk management 
tool that reduces the financial exposure of a manufacturer in case of accidental, 
unintended non-compliance during an introducto ry period. A similar approach could be 
taken in the case of light commercial vehicles . In addition, in the l onger term it would be 
desirable to consider linking the excess emi ssions premium to the consumer price index 
in order to avoid that its level, once chos en, erodes over time and thereby diminishes the 
intended deterrent function. 
4.2.9.  Long-term target 
The regulation on CO 2 and cars includes a long-term ta rget of 95 g/km in 2020 which 
was introduced by the European Parliament and the Council during the co-decision. This long-term vision allows for more planning certa inty for the industry and counter balances 
the effects of less stringent design paramete rs (i.e. phase-in of fu ll compliance and fines 
as well as additional derogations). 
The revised Strategy introduced a two step approach to CO
2 emissions reductions from 
light-commercial vehicles (in 2012 and 2015). In or der to be consistent with the approach 
in the Regulation on CO 2 and cars, there is a case for replacing the 2015 target for LCVs 
referred to in the revised St rategy with a long-term target  for 2020 and new information 
EN 28   EN gathered in the meantime. However, in view  of a longer than originally proposed break 
between the two, the target for 2020 should be more ambitious than 160 g/km. The stringency of the 2020 target for passenger cars may provide guidance in this respect. 
Further to the analysis in the supporting study, the following emissions levels have been 
identified as potential targets for year  2020, i.e. 160, 150 g/km, 140 g/km, 135 g/km and 
125 g/km. According to the supporting study the average level of 125 g/km is the 
maximum technically feasible option according to current knowledge, and thus the most 
expensive effort. The methodology applied in this assessment was based on the learning 
curve theory. This approach takes into account  that costs of a product generally decrease 
over time as a function of economies of scale,  learning effects and innovations in product 
and production methods. Learning curve theory  summarises the effects of these in a 
learning curve that specifies the development of costs as function of the cumulative production. The consultant identified two vari ants with similar reduction potential but 
different costs: full hybridisation  and extra strong downsizing  (of the engine). 
Following the methodology described above with in these two variants three possible 
scenarios were explored:  
1. No learning (each grade in the reduction potential is achieved using new technology 
replacing the previous one);  
2. Learning and slow penetra tion (technologies once introdu ced and having attained its 
maximum penetration remains in full production , the rate of penetration is low and takes 
about 10 years);  
3. Learning and fast penetration (as above but it takes about 3 years to fully penetrate the 
market).  
It is important to note that these calculations  were done at level of  total sales, without 
assessment of efforts by individual manuf acturers and the costs do not depend on the 
utility parameter and limit function slope th at is assumed. Costs and impacts of the 
identified options for the long-term target  are further analysed  in section 5.2.6. In 
addition several scenarios linking short-term and long-term targets were selected for 
further analysis of the economic, social and environmental impacts of the proposed 
legislation.  
4.2.10.  Multi-stage vehicles 
Multi-stage vehicles are LCVs that are sold  as chassis-cabin combinations only and are 
completed with a dedicated build-up after the vehicles are sold by manufacturers to final 
users or third companies installing these build -ups. These structures are often constructed 
to buyers' specifications. Sales of these vehicl es are estimated to represent 8% of the 
market. It is expected that many multi-stage vehicles in th e 2007 database will not have 
information on CO
2 emissions. Directive 2004/3/EC extended the measurement of CO 2 
emissions to N1 vehicles and established a timetable for th e reporting of these emissions 
which stretches from 1 January  2006 for complete vehicles of class I to 1 January 2009 
for incomplete vehicles of classes II and II I. Thus, the regulatory mechanism to provide 
the CO 2 levels for completed multi-stage vehicles is in principle in place. Any provisions 
specific to multi-stage vehicles in the Regulation on CO 2 from LCV would therefore 
have the character of transitional measures  until the provisions of Directive 2004/3/EC 
are fully operational.  
EN 29   EN For the time being it appears feasible to adopt a pragmatic approach based on the 
observation that the superstructures built by third-party vehicle body manufacturers are 
unlikely to perform better in terms of air re sistance and mass than those provided by the 
original equipment manufacturer  (OEM). The range of variants  and versions of complete 
vehicles of the same type offered by a manufact urer can be considered  as an i ndication of 
the variety that is present in this segment of  the market for light commercial vehicles.  
One possibility is to use, for incomplete ve hicles of each manufacturer and vehicle type, 
the emission level of the variant and version of the same type of vehicle marketed in that 
year with the second--highest specific emissions of CO 2 (this approach would be similar 
to the choice of tyres at the type approval test).  
Alternatively, a conservative approach would be to consider, for each manufacturer and 
vehicle type, the average CO 2 emission level of all complete vehicles registered in the 
EU in that year, and to use that value as  representative for the incomplete vehicles, 
recognising that an OEM has no control over the ai r resistance and mass of a vehicle that 
is being completed by a third party. In this cas e the true emissions of the vehicles as they 
finally enter the market are very likely to be underestimated. This approach would 
require safeguards such as ensuring that multi-stage vehicles that are completed by an enterprise that is connected to a manu facturer are not given unduly advantageous 
treatment, as well as monitoring the share of vehicles that are registered as multi-stage vehicles and adapting the legislation in case the provision is being abused. 
4.3. Policy options considered in the further assessment 
The key policy options short- listed for further assessment are summarised in Table 3 
below. These options are used for the purpose of distributional anal ysis and do not yet 
include the long-term target. Further analysis  of the long-term target is conducted at a 
later stage (section 5.2.6). The options diffe r according to target year and utility 
parameter. In options 2, 4, and 5 the target  year is set beyond 2012 and is defined as a 
range of possible dates up to 2015 considered fo r the first step of th e emissions standards. 
Within each option there are variants with different slopes of the utility curves and two variants of the autonomous mass increase (AMI). 
Table 3 Policy options  
Target Slope Year Parameter AMI 
Option 1 
60% mass 
80% mass 
100% mass 175 g/km 
120% 2012 
mass 0% 
1.5% 
Option 2 
60% mass 
80% mass 
100% mass 175 g/km 
120% 2013-2015 
mass 0% 
1.5% 
Option 3 
175 g/km 60% 2012 pan area 0% 
EN 30   EN 80%; pan area 
100%; pan area 
120% pan area 1.5% 
Option 4 
60% pan area 
80%; pan area 
100%; pan area 175 g/km 
120% 2013-2015 
pan area 0% 
1.5% 
Option 5 
2012/ mass/pan area % reduction 
2013-2015 mass/pan area 0% 
1.5% 
In addition to the main policy options setting th e main orientation of the approach of this 
legislation, the design parameters such as flexibility and compliance mechanisms will be 
assessed and chosen independently from these op tions because this choice is not affected 
by the conclusions on main policy options. This is also true for the long-term target because at this stage the detailed modalities of reaching this target are not being defined. 
The recommended policy option will thus be accompanied by chosen design parameters. 
5. A
NALYSIS OF IMPACTS  
The impacts of the short-listed policy options will be analysed according to the criteria 
set in the Communication from the Co mmission on the revised strategy on CO 2 
emissions from light duty vehicles, namely ne utrality to competitiveness, social equity, 
and sustainability. More speci fically, the economic, social and environmental impacts of 
selected options will be analysed. 
5.1. Description of the methodology  
The methodology followed in the analysis of th e impacts of identified policy options is 
based on the impact assessment on cars and a supporting study on light commercial vehicles. In addition, the cont ributions provided during the st akeholder consultation will 
be taken into account. To reflect the overall  socio-economic impacts, the modelling time 
horizon is 2020 and 2030. For furthe r details refer to Annex V. 
5.2. Economic impacts  
5.2.1.  Distributional effect on manufacturers 
The impacts on manufacturers (i.e. cost of compliance with the targets) of different 
options selected for further analysis are analys ed in terms of estimated changes in retail 
prices and relative emissions reduc tion required by each manufacturer.
27 
                                                 
27 The analysis is based on the assumption of full cost pass-through from manufacturers to buyers. 
EN 31   EN 5.2.1.1.  Distributional impacts of mass- based limit function (2012 to 2015) 
Figure 7 - Figure 12 (all figures provided in the Annex) pres ent the distributional impacts 
of options 1 and 2 for the achievement of the 175 g/km target with mass-based utility 
parameter, as well as option 5, expressed in te rms of absolute and re lative price increase.  
This analysis shows clearly that the costs per manufacturer are more sensitive to the 
slope of the limit function than was the case fo r passenger cars. This is  also true for the 
difference in levels of costs across the manufact urers. In general, it can be concluded that 
the higher the slope of the mass-based limit func tion the more even is  the distri bution of 
costs between the manufacturers. Lower slope s (below 60%) increase  the difficulty of 
meeting the targets on the limit value curve for manufacturers of larger LCVs. 
If AMI is set at the level of 0% the average costs of meeting the targ et are independent of 
the target year and therefore are presented in the same figur e (Figure 7 and Figure 8). On 
average the costs would be lower the higher the slope, with the best result for option 5 
(percentage reduction target). An assumpti on of AMI = 1.5% and target date of 2012 
(Figure 9 and Figure 10) leads to higher costs of meeting the target than in case of zero 
autonomous mass increase. When these are compar ed to the results for a later target date 
(Figure 11 and Figure 12) one can see that the costs of meeting the target go up when the 
target year is shifted. This is due to higher mass increase between 2007 and the target year leading to proportional higher CO
2 emissions. This mass increase needs to be 
compensated with additional more expensive measures from the upper end of the cost 
curve. This leads to an overall co st increase of meeting the target. 
5.2.1.2.  Distributional impacts of pan area- based limit function (2012 to 2015) 
Figure 13 and Figure 14 (all figures provided in the Annex) represent absolute and 
relative price increase of reaching the targ et of 175 g/km in 2012, when pan area is 
selected as utility parameter (option 3) a nd AMI = 0%. Following the previous section, 
the results for option 5 are also included for comparison. 
The average costs of option 3  and 4 (if AMI is set at the level of 0% the average costs of 
meeting the target are independent of the ta rget year) are quite similar to the average 
costs for the mass-based limit functions (op tion 1 and 2 with AMI=0%). However, the 
distributional impact is much more divers e and uneven for pan-ar ea and therefore more 
manufacturers would have difficu lty to meet their specific targets and one is reaching the 
maximum of its reduction potential (i.e. price in crease is the same for different slopes of 
utility curves). Similarly to the results fo r mass-based parameter the average costs are 
lower with higher slopes of the curve and are the lowest for percentage reduction (option 
5). This becomes even more vi sible if AMI of 1,5% is appl ied (Figure 15 and Figure 16) 
with the average relative co sts being closer to 10%. 
Shifting the introduction of the target beyond 2012 (Figure 17 and Figure 18) results in 
the average costs rising above 10% for most  of the options. Only the manufacturer 
reaching the maximum of its reduc tion potential in 2012 benefits from slight decrease in 
the cost of reaching the target. 
EN 32   EN 5.2.1.3.  Summary of distributional analysis 
Comparing the different slopes for the limit functions of all options shows that the sales-
weighted average retail price increase per ve hicle is lower when the slope is higher, 
although these variations are not very signifi cant. The retail price increases for a mass-
based curve by 5.8% (sales-wei ghted average) at 60% slop e and by 5.4% at 100% slope 
for option 1 . For option 3  these values amount to 6.3% to 6% respectively. The 
differences are similarly small for options with AMI = 1.5%, equalling to 9.9% to 9.5% 
for mass-based limit functions and 10.5% to  10.2% for pan area-based limit functions 
respectively. For option 2  and 4 with AMI = 1.5% the differe nces of cost increase are 
also less than 0.5%.  
While the average cost is not subject to significant variations, the differences at the level 
of single manufacturers are much more importa nt, especially with a lower slope of the 
curve. The most even distribution of retail  price increase is observed between 100% and 
120% slopes. However, even though the risk of perverse incentives of increasing the 
mass of vehicles to receive less stringent target s in LCVs is expected to be lower than in 
the case of passenger cars, the slope of 120% is more likely to pr ovoke these adjustments 
than the 100% slope. Therefore, it seem s that a slope of 100% would be most 
appropriate. 
Delaying the introductory date of the 175 g/km  target from 2012 to a later date (with 
AMI = 0%) is of advantage for the industry du e to the later introduction of the target 
allowing for more time to implement the neces sary technological measures to comply 
with the legislation. A cert ain delay beyond 2012 appears to be a necessity on practical 
grounds to take into account the time n eeded for the co-decision procedure. 
The autonomous mass increase set at the leve l greater than 0% increases the cost of 
meeting the average target in the case of a mass-based limit function, and makes 
compliance more difficult for certain manufact urers which may find themselves at the 
maximum of their cost curves. As explai ned in section 4.2.5, the risk of perverse 
incentives to make LCVs heav ier appears less pronounced than  for cars because their size 
is mostly determined by the task for which they are designed, and mass increases would reduce available payload. In or der to ensure that perverse incentives to increase the mass 
of vehicles in order to benefit from a le ss stringent target are avoided, an ex-post 
adjustment of the average mass would have to  be embedded in the legislation, following 
the approach in the agreed Regulation on CO
2 and cars. Setting a zero autonomous mass 
increase may therefore be considered su itable for the proposed legislation on LCVs. 
The choice of utility parameter (mass or pan area) has more important impacts on the 
average retail price increase and the dist ribution of burden am ong manufacturers. The 
main tendency is that the estimated retail pr ice increase is slightly higher when pan area 
is used as a utility parameter (with AMI = 0%). A serious drawback of this parameter is that the distributional impacts are more unevenly spread than in case of a mass-based 
utility parameter. The individual targets for some manufacturers b ecome more stringent 
for pan area as compared to mass.  
Option 5 (percentage reduction) is the most attrac tive in terms of the average costs of 
compliance which are lower than in other optio ns. The average increase of retail price in 
this option for 2012/15 scenario equals 5.1%, rising to 7.8% with AMI=1.5% in 2012 and 
EN 33   EN 9.3% with AMI=1.5% and the target date in 2015. The distributi on of costs among 
manufacturers is also the most  equal. However the drawback of this option is that past 
efforts to reduce CO 2 emissions are penalised. In addition, it would be difficult to define 
the targets for new market entrants. Finally, the legislation would be  defined on the basis 
of the current market situation, and no t on the basis of an  objective criterion. 
Following the results of the distributional anal ysis, options 3 and 4 (pan area-based utility 
parameter) and option 5 have been discarded from further considerations. Also lower 
slopes of the curve (below 60%) as well as the slope of 120% will not be analysed 
further. 
5.2.1.4.  Impact on small and medium enterprises (SMEs) 
LCVs are mostly produced by la rge manufacturers. Where SMEs are currently present on 
the market they evidently compete in today' s circumstances. As l ong as the legislation 
does not introduce distortions that  impact disproportionately on the vehicles produced by 
SMEs, distortions at the expense of  these SMEs should be avoidable. 
SMEs play a rather bigger ro le as customers of LCVs. Fo r them, as for all buyers and 
users of these vehicles, the key impact is th e change in the total cost of ownership. As 
demonstrated in section 5.2.4, this change is expected to be a negative cost and thus 
beneficial. Hence SMEs, along with all other users of LCVs, stand to gain from the 
proposal. While upfront financing may be an issue, by the time the legislation enters into 
force, the effects of the economic crisis on credit availability  should have abated. 
5.2.2.  Innovation and competitiveness 
The impact of the regulation on CO 2 and cars on research and development was analysed 
in the impact assessment on cars and th e following conclusions were drawn: 
• the 130 gCO 2/km target for passenger cars will pr omote further technological advance 
in fuel efficiency measures and accelerat e the market penetration of advanced 
combustion and powertrain technologies ; 
• the legislation will to some extent  limit possible vehicle upsizing; 
• it is expected that the diesel penetration rate  will continue increas ing in the short term. 
It is likely that the legal proposal on light  commercial vehicles will have similar impacts 
on research and development. The proposed 175  g/km will require a significant increase 
in the efficiency of light commercial vehicl es. To a significant extent, manufacturers of 
light commercial vehicles are expected to ta ke an advantage of l earning effects obtained 
from reducing the CO 2 emissions of passenger cars, espe cially for car-derived smaller 
vans. 
Further dieselisation of the fleet is not e xpected in view of significant domination of 
diesel LCVs already. 
EN 34   EN The impact assessment on cars, suggested that  the above mentioned trends should have 
positive impacts on the competitiveness of European manufacturers28:  
'In the global perspective, research and innova tion are seen as strengths of the European 
market and it is not likely that the above trends will have a damaging effect on the 
competitive position of EU manufacturers. As  regards mature non-EU markets where EU 
manufacturers are already present (e.g. US, Canada) there is a general trend towards 
the reinforcement of fuel  efficiency/greenhouse gas emission standards. Because 
requirements on these markets are so far le ss ambitious than those in the EU, the 
proposed EU legislation will allow European carmakers to provide vehicles that are 
competitive and meet the reinforced standards to come into force in the coming years. ' 
This conclusion can also be a pplied to light commer cial vehicles. First of all, vehicles 
that meet strict CO 2 emissions requirements in the EU will be globally competitive and 
compliant with the climate change policies being implemented in third countries (especially where fuel economy standards exis t and are about to be tightened, notably 
Japan, China, and USA, as well as India which is likely to follow). The reduction of CO
2 
emissions is now a global phenomenon and involves all means of transport.  
Currently European LCV manufacturers are amongst the most technologically advanced 
in the world. Vans, trucks and buses produ ced in Europe are highly valued on the non-
EU markets. Moreover, more fuel efficient vehicles will be attractive to vehicle users 
allowing to lower costs of r unning a vehicle which is especi ally important for business 
users. New vehicles equipped with even more  advanced fuel saving technologies should 
remain competitive, especially with oil prices  expected to rise. This is also true for 
countries with lower fuel taxation which tend to  be more sensitive to price fluctuations of 
oil. 
To assess the impact of the proposed regula tion on light commercial vehicles on trade, 
current trade patterns need to be understood. According to the impact assessment on cars, 
the automotive industry contributes nearly €60 billion to the European  trade balance, so 
is one of the most important sectors. The share of light commercial vehicles in imports and exports of the EU automobile sector is presented in Table 4. 
Table 4 EU25 automobile trade (in million EUR)  Source: www.acea.be
  
 2004 2005 
Vehicle category Imports Exports Trade 
BalanceImports Exports Trade 
Balance
Passenger cars 24972 56315 31342 25208 60820 35612 
Light commercial vehicles 3005 1836 -1169 3257 2155 -1102 
The data suggests that trade flows of light commercial vehi cles are significantly lower 
than passenger car imports and trade balance is negati ve. The analysis of the 
                                                 
28 SEC(2007)1724 
EN 35   EN distributional impacts of the policy on manuf acturers (section 5.2.1), suggests that to the 
extent that importing manufacturers produce  vehicles with higher emissions and 
therefore will need to make more effort to reach the target than domestic manufacturers, 
the proposal could have a positive impact on the EU's trade balance. 
In terms of impacts on competitiveness, th e proposal will apply to  all manufacturers29, 
irrespective of where they  are located (i.e. EU or third c ountries). It will therefore affect 
all manufacturers in a relatively consiste nt manner. The legislation will be most 
beneficial to those manufacturers with acces s to the most advanced technology as 
compliance will require lower carbon powertrai n technology to be introduced. However, 
much advanced technology is developed by the automotive component suppliers and should be available to all manuf acturers willing to purchase it. 
5.2.3.  Sensitivity analysis 
Sensitivity to fuel prices-
 in order to assess the impact of fuel prices (exp eriencing high 
volatility over the past year) an additional analysis including oil prices was carried out. 
The fuel prices used to perform these runs (TREMOVE) model are co untry specific and 
for all countries are expressed in Euro in  the year 2000. Three price levels were 
investigated: base case, as well as half a nd double of the fuel price which is a common 
approach in econometric modelling of  scenarios with high uncertainty. 
Restrictions on reduction potential-  the supporting study on light  commercial vehicles 
assumes that due to much lower share of pe trol vans on the market, a large part of 
technical measures will be introduced in di esel vehicles. To avoi d unrealistic high costs 
for petrol vehicles in the model (due to th eir small share and much flatter cost curves 
than for diesels) a cap on the available re duction potential for petrol vehicles was 
introduced. This is modelled as a percenta ge of the maximum achievable reduction 
according to the cost curves. The following alternative situations with 50% cap were modelled: 175 g/km – 2012 – 60% and 175 g/km – 2012 – 100%. 
Fuel price sensitivity runs (Table 12 in the Annex) show that if the fuel prices decrease 
(as happened currently, see se ction 2.6), the GHG abatement cost s will be positive as the 
higher purchase costs will not be fully offset  by the fuel savings. However, they are 
within the range of the EU ETS price and also in the levels comparable to the abatement costs under the Regulation on CO
2 and cars as presented in the CO 2 and cars impact 
assessment. Note that the fuel price is assumed constant over the modelling period in each fuel price scenario considered. It can be thus concluded that based on the results of 
the TREMOVE model the contribution of the tran sport sector is either cost benefiting for 
the society as whole or of a comparable cost  effort to other sectors with Community-wide 
measures.
30 
                                                 
29 The manufacturer is defined in the legislation as the entity responsible for the type-approval of 
vehicle. 
30 Sensitivity runs were not performed for the long-term options because of the favourable results of 
analysis for the short-term targets which show a net benefit or in – the worst case – a rather 
limited cost. The introduction of the long-term target is expected to provide clear benefits to the society and lower compliance costs. 
EN 36   EN 5.2.4.  Impact on society and cost effectiveness  
As mentioned at the beginning of section 5, the economic impacts of the proposal on 
light commercial vehicles have been analysed  in terms of distri butional effects among 
manufacturers and of overall cost-effectivenes s. The results of the cost effectiveness 
analysis are provided in this section and th e figures and tables are presented in the 
Annex.  
The associated CO 2 abatement costs reflect costs to  society per unit of achieved CO 2 
emission reduction. In the supportive st udy on light commercial vehicles, CO 2 abatement 
costs were estimated for mass-based utility  curve slopes 60% and 100%, the autonomous 
mass increase was assumed to be zero. The CO 2 abatement costs decrease with the 
increase of fuel prices due to higher savings from increased fuel efficiency. Abatement 
costs for a 60% slope are depicted in Figur e 21 and for a 100% slope are depicted in 
Figure 22. For the autonomous mass increase of 0%, a CO 2 emissions reduction target of 
175 g/km for light commercial vehicles is cost effective to society (because the 
abatement costs are negative or equal to zero ) at both, 60% and 100% slope in case of oil 
price above 54 €/bbl an d 50 €/bbl respectively. 
The economic impact on society of options 1 and 2 (mass-based utility parameter, 
AMI=0%) was also assessed in TREMOVE m odel (see Table 17 in  the Annex). The 
abatement costs to society are expressed by the net present value of purchase and fuel costs incurred to the consumers over the pe riod 2010-2020 as compared to the base case. 
The difference between the options 1 and 2 is ne gligible in terms of costs to society and 
CO
2 abatement costs, because the target is actually the same and the same technology 
improvement measures have to be implement ed in both options. The overall amount of 
CO 2 saved is slightly lower in the options with  a later start date b ecause of the delay in 
implementing the target.  
The combined scenarios (options 1 or 2 combin ed with different leve ls of the long-term 
targets) offer negative cumulative GHG abatem ent costs in the rang e of - €38.9 to - €32.6 
up to 2020, and - €20.6 to - €34.9 up to 2030 (see Table 17). 
5.2.4.1.  Impact on vehicle buyers and users 
From the end-user perspective the proposed regulation is cost beneficial according to 
TREMOVE simulations (Table 10 and Table 11 in the Annex). Additional costs are 
calculated as a difference between end-user  purchase, repair and insurance costs 
inclusive of all taxes and end-user fuel cost s inclusive of all taxes. Negative costs mean 
savings for end users. It should be noted that TREMOVE assumes repair and insurance 
costs increasing according to the increase in ve hicle prices, which might not be fully in 
line with the actual observed technological and market development. Thus as a 
consequence, costs shown in the table might be overestimated which consequently would 
mean higher savings. 
Simulations in TREMOVE model indicate, in li ne with the initial expectation, that the 
effect of the legislation on vehicle sales shou ld be very small (see Table 9 in the Annex). 
In fact, the decrease in vehicl e sales in N1 segment for some of the options has an effect 
only on lowering the expected growth of this  market. The expected growth in sales 
(+18.7% by 2020 and +19.2% by 2030)  is reduced by approximately 1%. This effect is 
also very small for different combinations of the short-term and long-term targets and 
EN 37   EN ranges from 0.38% decrease to 0.7% increase in 2020 and a pproximately from 2.7% to 
0.4% decrease in 2030.31 
Further impacts on end-users are listed in section 5.2.6. 
5.2.5.  Impact on energy consumption 
In 2006, 564 Mt of crude oil was imported into the European Union and final oil 
consumption was 496 Mtoe. Based on the results of TREMOVE simulations, the 
proposed CO 2 in LCVs regulation (combined scen arios, 50% cap) will deliver fuel 
savings in the range of 3.18-4.54 Mt by 2020 depending on the case, which means 
decrease of fuel consumption of road tran sport by 1.57-2.52% (Table 7). The decrease of 
total fuel consumption by this range represen ts a sizeable cut in fuel used by light 
commercial vehicles, which account for 12% shar e in the LDV fleet and use 6-7% off all 
road fuel, and means a comparable reduction effort to the one required from passenger cars. The LDV fleet (passenger cars and LCVs) is in total responsible fo r two thirds of all 
road emissions, and thus fuel use. This means LCVs thereby make an adequate contribution to energy security and reducing oil import dependence. 
Delay of the start date for the first step of reduction (175 g/km) to after 2012 will deliver 
slightly lower savings. However, an additional stricter long-term target from the range of 
125 to 160 g CO
2/km in 2020 will more than compensa te for this (see section 5.2.6.). 
5.2.6.  Impacts of the long-term target 
Figure 19 and Table 5 present relative retail pr ice increases for both variants of the long-
term target: full hybridisation and extra str ong downsizing, as well as three scenarios 
within each option (no learni ng, learning with slow penetrat ion and learning with fast 
penetration). The technology options of extra strong downsizing and of strong 
hybridisation are consider ed as mutually exclusive for tech nical reasons. It is clear that 
the option of hybridisation is much more e xpensive than extra dow nsizing however the 
differences between costs of scenarios within  each variant do not differ significantly. 
Therefore, a preferred option for further analys is is a more cost effective scenario of 
extra strong downsizing  with variant of learning and slow penetration  which also 
seems to be the most realistic option. 
According to the analysis performed by the contractor the level of 125 g/km is the 
maximum feasible reduction in the timescale and the costs of reach ing this target are 
high, amounting to €4193 for the shortlisted va riant (see Figure 19) in addition to the 
effort that needs to be born for the first st ep of emission reductions. The effort that would 
be required from LCVs in 2020 would in this case be more than asked from passenger cars. According to the supporting study, the 2020 target of 95 g/km for passenger cars is 
expected to result in 15 to 22% retail pri ce increase from 2006, whereas the target of 125 
g/km for LCVs would result in  a 20% retail price increase as compared to 2007 baseline. 
                                                
 
31 The TREMOVE model has not been designed to describe the effects of situations such as the 
current economic crisis. Th is analysis therefore concerns the im pact of the vehicle purchase price 
on the demand in the absence of other considera tions like access to financing, economic situation 
etc.  
EN 38   EN A target of 135g/km would be consistent with the stringency of the 2020 target for cars 
leading to a 15 to 26% retail price increase. 
Further analysis in TREMOVE uses 150 g/km as  a potential target level for 2020 as well 
as 125 g/km which represents maximum feasib ility. In addition, target levels of 160, 140 
and 135 g/km are analysed in a simplified way based on the modelling results for 150 and 125g/km. A long-term target set within the range of 160-125 g CO
2/km is expected 
to deliver: 
- net benefit for the vehicle owner at all inve stigated levels of the 2020 target in the 
cheaper of the two approaches (extra strong downsizing) and at  a discount rate of 4% as 
usually employed from a public policy persp ective (see in Annex IV). A target of 
150g/km, for example, would on average lead  to savings between €2 110 and €2 331, a 
target of 140 g/km would on average lead to  savings of €2 028 to €2 297, and a target of 
135 g/km would lead to savings of €1 987 to  €2 279. Even choosing a discount rate as 
high as 10% – which is closer to a commerci al perspective – would still lead to a net 
benefit for most of the options  in the approach of extra st rong downsizing apart from the 
target of 125 g/km which would impose a net co st of €88 in the 'no learning' scenario and 
allow for net savings ranging from  €121 to €252 for other scenarios. 
- net benefits to end-users in all combined scenarios (different short-term and long-term 
targets) as depicted in Table 10. The scenar io with a 2013 start da te and 135 g/km target 
for 2020 offers the highest savings of €4 831 and results in sa vings of €1.45 per €1 
invested. Less challenging scen arios, e.g. 2015 as a start da te and 160 as a long-term 
target, offer lower savings of €4 097, but require lower investment due to later 
introductory date and less ambitious 2020 target  and thus yield higher return (€1.55 per 
euro invested). All scenarios offer savings also in the period up to 2030 (Table 11).  
- negative cumulative GHG abatement costs as presented in section 5.2.4 and Table 17. 
- benefits from savings due to reduction in the consumption of fuel of €11.6 - €15.6 
billion by 2020, and €42.4 – €60.7 billion by 2030 (see Table 8 in the Annex). 
5.2.7.  Impacts of pooling 
Flexibility mechanisms provide manufacturers with a broader range of options to meet 
their emission targets and therefore faci litate the achievement of targets.  
The impact assessment on cars argued that ap plying the target to manufacturers’ fleet 
average  rather than individual vehicles w ould allow manufacturers to decide for 
themselves how and in which segments to reduce their emissions. Reduction of average 
emissions may be achieved by reducing the emissions of the models where such 
reductions cost the least. The approximate di fference in cost increase for cars for fleet 
average/individual car was f ound to be 2% lower when th e target applied to the 
manufacturer fleet average. In  case of LCVs some manufact urers may find it difficult to 
meet the individual target if the vehicle-based emission limit is introduced therefore there is an even stronger case to apply the av erage target to the producer's fleet.  
The positive effect of pooling between two or several manufacturers
 was emphasised in 
the impact assessment on cars. It is very likely that pooling of manufacturers producing 
EN 39   EN vans and minibuses will have similar eff ect. A summary of the arguments are provided 
below: 
- Pooling between manufacturers has similar effects to fleet averaging. As different 
vehicles are subject to different abatement co sts, different manufact urers are also faced 
with varying costs of abatement. By allowi ng pooling, the abatement costs of different 
manufacturers could theoretically move towa rds average costs, which would result in 
increased cost-effectiveness.  
- Pooling would allow for niche producers to  combine their portfo lios with mainstream 
producers hence helping to address the problem of outliers within the overall system. 
- The precise impact of pooling on cost-effectiveness will depend on the extent to which 
manufacturers use this possibility and the na ture of the agreements they reach between 
one another, it is likely that  it will take place in prac tice and has been supported by 
representatives of the au tomotive industry during th e consultation process. 
Pooling between cars and LCVs.  Bringing both categories of  vehicles under the same 
limit function is not a realistic option, as conclude d in the supporting study on LCVs, 
because it would require a majo rity of vans and minibuses manufacturers to apply 100% 
of their technically feasible  emissions reduction potential.32 Allowing pooling of the 
efforts under separate targets (resulting fr om different limit functions) for LCVs and 
passenger cars however is a possible option. Pool ing of the targets for passenger cars and 
light commercial vehicles would mean  that manufacturers can compensate 
underachievement in one categor y (expressed in average g/km  above target times total 
sales in that category) by an  equivalent overachievement in  the other category (expressed 
in average g/km below target times total sales in that category).  
According to the supporting study on light commercial vehicles, for the majority of 
manufacturers the marginal costs for meeti ng their manufacturer-specific target values 
(resulting from the overall target s and slope) are expected to  be somewhat higher for 
LCVs than the marginal costs for meeting th e proposed passenger car target. This means 
that, when pooling of targets is allowed, th e manufacturers for which the difference is 
more important may limit their CO 2 reduction efforts in LCV cat egory and to compensate 
this by applying more CO 2 reduction measures in the M 1 category of vehi cles (see Table 
13 in the Annex). 
A manufacturer that produces only light commercial vehicles could still have a 
possibility to pool with another manufacturer of cars and/or vans33. However, this could 
potentially put such a company at a certain di sadvantage compared to a manufacturer or a 
group of connected manufacturers that  produce both types of vehicles. 
5.2.8.  Compatibility with the revised strategy on LDVs 
As explained in section 1.1, th e proposal for a regulation on LCVs is a continuation of 
the Commission's regulatory process to addr ess the climate change  impacts of road 
vehicles resulting from the revised strategy on CO 2 from light-duty vehicles. The strategy 
                                                 
32 See section 5.3 of the supporting study on LCVs. 
33 Similarly to pooling allowed under article 7 of the CO 2/cars regulation 
EN 40   EN announced that CO 2 reduction from LCVs should be a part of the measures of the 
integrated approach to deliver reduction of additional 10 g CO 2/km complementing the 
target of 130 g/km set for passenger cars, which in total would result in an average of 120 g/km from light-duty vehicles by 2012. Howeve r, during the co-decision process to adopt 
the regulation on CO
2 emissions standards for passenger cars, the time schedule of the 
strategy and the overall ambition have been amended by the European Parliament and the 
Council by introducing the long-term perspect ive of 2020 target. In addition, a phase-in 
period of full compliance with the target fo r cars introduced to the scheme changed the 
timeframe of the short-term reductions. It is therefore difficult to directly compare the level of CO
2 reductions anticipated in the impact assessment accompanying the strategy 
(aiming at 2012 as a target date) with the es timates of this proposal which takes into 
account the new framework. Likewise, a more pr ecise estimate of the long-term target 
will be possible only when the modalities of re aching it are defined at the review in 2013. 
The impact assessment of the revised strategy (SEC(2007)60) estimated the CO 2 
reduction due to mandatory reduction requirements from LCVs as 44.5 Mt of GHG 
(expressed as well-to-wheel CO 2 equivalent) over the peri od 2010-2020. As specified in 
Table 16 the anticipated reduction level of  the analysed option 1 and 2 (assuming 
AMI=0%) in the period 2010-20 should amount  to at least 60 Mt of GHG in CO 2 
equivalent with a start date  from the range 2013 to 201534. This amount of CO 2 reduction 
which is higher than anticipated in the strate gy is the result of the more extensive data 
collection and investigation for this indivi dual proposal compared to a necessarily less 
accurate approach for the overall strategy.35 It was announced in  the strategy that "in 
2010, the Commission will review the status of implementation and the potential for 
further measures to move bey ond the stated EU objective."  This will be an occasion for 
taking stock of all EU measur es undertaken to implement CO 2 reduction from light-duty 
vehicles as part of the integr ated approach, and for potentia lly revising the strategy in 
view of the findings made. 
5.3. Social impacts  
5.3.1.  Employment aspect 
The industries that manufacture cars and light  commercial vehicles are very similar – 
indeed almost all manufacturer s of LCVs also make passenge r cars. Therefore, many of 
the key aspects in this section are rather similar in the two sectors and the discussion in 
the impact assessment36 of the proposal for the regulation on CO 2 and cars largely applies 
in the present case as well, bearing in  mind that the size of the market under 
consideration here is about 1/10 of that for passenger cars.  
                                                 
34 The value would be 63Mt for a 100% slope of the limit value curve in 2015, based on a simplified 
calculation on the basis of results from TREMOVE 
35 The impact assessment of the Strategy SEC(2007)60 used the baseline of 200.9 g/km in 2002 and 
assumed that the baseline value (without policy aime d at efficiency improv ement in N1s) for 2012 
would be around 190 g/km based on autonomous efficiency improvements stemming in part at 
least from technology improvements diffusing into light vans from equivalent passenger cars. 
However, the most recent analysis shows that the average emissions in 2007 amounted to 203 
g/km which explains higher savings resulting from the proposal than initially expected in the 
Strategy. 
36 SEC(2007)1723, section 5.3. See 
http://ec.europa.eu/environment/air/transport/co2/pdf/sec_2007_1723.pdf 
EN 41   EN The impact assessment on cars discussed the balance of tw o opposing tendencies linked 
to more ambitious environmental performan ce of vehicles. On the one hand, the higher 
added value on the vehicle is likely to lead  to more employment along the value chain; 
on the other hand adverse impacts on the sale s of new vehicles have the opposite effect. 
The impact assessment on cars concludes that the direct impact on employment through 
decreased sales levels caused by the legislation seems likely to be relatively marginal, while the upstream (suppliers) and downstr eam (servicing) impacts as well as the 
requirements for higher added value at the manufacturers themselves holds out positive 
prospects for employment.  
In the case of LCVs, an assessment of the alte rnative options shows that the retail price 
increase per vehicle may range from 5.4% to 5.8% at the first stag e of the legislation, 
depending on the slope of the utility curv e and assuming full cost pass-through, and 7.1-
20.9% for the long-term target (range of 160  – 125 g/km level; extra strong downsizing 
option). This relative price increase for li ght commercial vehicles is similar to the 
estimated 6% retail price increase for passe nger cars for the short-term target, whereas 
the 2020 target is estimated to result in 15-20% increase.  
In addition, the TREMOVE model forecasts only insignificant decr eases of light duty 
vehicles sales (0.31 – 0.42% in 2020) due to lo wer price elasticity of demand for LCVs 
as compared to demand for passenger cars. Thus , it is expected that a marginal decrease 
of LCV sales (see Table 9 in the Annex) re sulting from the regulation should not have 
important implications on employment in the vehicle manufacturing sector. 
5.4. Environmental Impacts  
5.4.1.  Overall impacts in terms of emissions  
The overall CO
2 abatement in two alternatives is pr esented in Table 15  and Table 16 (in 
the Annex). The estimated emi ssion reduction for the 2010-2020 in option 1  amounts to 
67-77 million tonnes (100% slope). However, the variation in savings between the 
different slopes is not very large, it may o ccur because of slight shift in vehicle sales.  
The CO 2 abatement in option 2 is at least 60 million tonnes.  The difference between the 
options is caused by the fact that the target of 175 g/km will be achieved at the most 3 years later that in option 1 . 
According to TREMOVE modelling
37: 
• The reduction in the GHG emissions in pe riod from 2010 to 2020 (Table 15 in the 
Annex) corresponds roughly to 10% of th e reductions calculated in the impact 
assessment for CO 2 in cars, which is in line with the proportion of the vehicle fleet 
sizes of the vehicle fleet in the covered ca tegories (the number of newly registered 
LCVs in 2005 was 12% of the number of passenger cars).  
                                                 
37 Note: "Abatement costs" are calculated for year 2009 with the recommended discount factor 4% 
and expressed in Euros of year 2000 – which is the base year in the TREMOVE model. "WtW" (Well-to-Wheel) GHG abatement also includes GHG emissions reduced by fuel producers. 
EN 42   EN • The reduction in the GHG emissions from LDVs in year 2020 for targets from 2012 to 
2015 targets corresponds roughly to 5% of the total reduction effort (Table 15 in the 
Annex) under the decisions of European Parl iament and of the Council on the effort of 
Member States to reduce of their greenhous e gas emissions to meet the Community’s 
greenhouse gas emission reduction commit ments up to 2020 (Decision 2009/406/EC). 
This can be partly offset by the increase in the road transport emissions due to increase of transport activity. However, the contribution of CO
2 reductions from 
LDVs to the total effort does not take into account the offset of additional growth of GHG emissions from 2005 level.
 
• The introduction of the long-term target is estimated to result in the cumulative GHG 
savings (CO 2 equivalent) of 61.7 to 81.6 Mt by 2020 (Table 16). These levels of CO 2 
abatement will help achieve 4.7 to 6.0% of the reduction effort of the non-ETS 
contribution to 20% reduction in EU GHG emissions by 2020 (see Table 15 and 
section 3.2.3). The cumulative GHG savings resulting from the combined scenarios increase to 267 to 342 Mt in 2030 (see Table 16).  
• The impact of the legal proposal on CO
2 emissions from light commercial vehicles in 
principle has an insignificant impact on th e overall emissions of other pollutants, as 
indicated in Table 18 (in the A nnex). LCVs sold in the EU will be subject to pollutant 
emissions standards (Euro 5 and Euro 6)  in any event and the proposal for CO 2 
standards will not impact on these limit values. The share of diesel vehicles is already near 100% and no shift in the pe trol/diesel share is expected. 
• The production of more efficien t vehicles under the present le gislation is not expected 
to generate substantially more CO
2 emissions than current processes. Moreover, 
production is to a certain extent already covered by the EU Emissions Trading 
Scheme (cost of electricity as well as parts of the production of raw materials and 
components). At present the CO 2 emissions resulting from the production of vehicles 
are estimated to be responsible for about 15% of their lifecycle CO 2 emissions. 
5.4.2.  Impact of the compliance mechanism 
In order to ensure that manuf acturers have incentives to comply with the legislation, the 
excess emissions premium should be set at the level of the marginal cost of compliance. 
On the basis of the purely technical cost of  compliance as obtained from the supporting 
study, compliance with the target of 175 g/km in the timeframe 2012-2015 with mass-
based parameter and zero AMI, and within  a margin of 0,1g/km, would require a 
premium level of around €120 per gram per kilome tre (Figure 23). This is higher than the 
level of €95 per gram agreed for passenger cars  and results from higher marginal cost of 
CO 2 abatement for light commercial vehicles. 
Setting the same premium levels for the two types of vehicle would be important if 
pooling between passenger cars and LCVs is permitted to avoid gaming. 
5.5. Additional costs to busin esses and Member States 
The proposal for a regulation to reduce CO 2 emissions from LCVs will not put any 
additional reporting burden on manufacturers.  Car producers are obliged to report the 
data necessary to check compliance with this legislation already now at the type approval 
EN 43   EN and in the certificate of conformity of each vehicles. This also includes any parameters 
needed for a future review of the utility pa rameter. This is required from both, passenger 
cars and LCVs (the latter as of 2007 pursuant Directive 2004/3).  
The regulation will however require that produ cers put more effort in monitoring and 
forecasting of progress of sales in order to ma nage the compliance of their fleet with the 
target, and handle the monitoring reports pr epared by the Commi ssion each year. This 
will be already required by the regulation on CO 2 and cars which enters into force in 
2012 and therefore a large major ity of manufacturers will have these procedures in place 
in any case. 
The Member States are obliged to monitor a nd report the data provi ded by manufacturers 
for passenger cars already now (Decision 1753/2000/EC). Furthe r to the adoption of the 
regulation on CO 2 and cars regulation, the national authorities will  have to adapt the 
monitoring schemes to the requirements of the Regulation (i.e. gather data on the 
footprint). The Commission is also working with the Member  States to improve national 
monitoring schemes which also includes mon itoring of the registration of passenger cars 
as LCVs and the opposite.  
Inclusion of the obligation to monitor data concerning LCVs will put only negligible 
additional costs on national authorities. The monitoring scheme required for this purpose 
will be the same as used for passenger cars  and the only difference will relate to the 
obligation to process more data. The share of  LCVs in the whole light-duty fleet is only 
around 12% of the light-duty vehicles fleet and this additional effort is estimated to be 
very limited. 
5.6. Comparison of options 
As a starting point, five alternative policy opt ions were identified. However, the analysis 
of distributional impacts of op tions discarded pan area-based utility (options  3 and 4) and 
percentage reduction (option 5)  from further analysis (see  section 5.2.1.3). Pan area was 
discarded because the distribution of re duction efforts was more uneven between 
different manufacturers than in case of a mass-based utility parameter. This means that 
the individual targets for some manufactur ers were more stringent for pan area as 
compared to mass. The general tendency was that the estimated retail price increases 
were also higher for pan area. 
The short-listed options 1 and 2 were further analysed in terms of social equity, 
competitive neutrality, cost-effectiveness and the environmental outcome. Within these options low slopes of the utility curve (bel ow 60%) were discarded and the slope of 
120% was rejected on the basis of a risk of perverse incentives to  increase mass. In 
option 2 the target year was defined as a range of possible dates (beyond 2012 up to 
2015) considered for the first step of emissions reductions. 
In principle the two options are alike in terms of costs, if assumed autonomous mass 
increase is set to zero. If the autonomous ma ss of vehicles increases over 3 years, the 
manufacturers will be in less favourable pos ition in 2015, because they will be required 
to introduce more reduction measures ne eded to compensate the increased CO
2 
emissions. However, AMI of 1.5% is unlikely for light commercial vehicles because of 
their use in transporting goods. The additiona l mass would come at the expense of the 
payload and performance.  
EN 44   EN The most even distribution of retail pri ce increases between manufacturers is observed 
between 100% and 120% slopes. In addition, even though the ri sk of perverse incentives 
of increasing the mass of vehicles to receive less stringent targets in LCVs is expected to be lower than in the case of passenger cars, the slope of 120% is more likely to provoke 
these adjustments than the 100% slope. Theref ore, the latter seems the most suitable. 
 Option 1 
Mass-based utility 
Target year – 2012 
Slope: 60% - 100% Option 2 
Mass-based utility 
Target year – 2013-2015 
Slope: 60% - 100% 
Environmental impacts (i.e. CO
2 
reductions) ☺ 
67 to 77 Mt CO 2 eq. until 2020 . 
At least around 60 Mt CO 2 until 
2020 
5.4%- 5.8% price increase per vehicle 
The cost of meeting this target for both start dates is similar if zero AMI 
increase is assumed  Average compliance costs (expressed as relative retail price increase for 60%-100% slope) 7.9% - 8.3% price increase per 
vehicle 
Higher cost results from the need 
to compensate for the autonomous 
mass increase of 1.5% 
(AMI=1.5%) 9.5% - 9.9% price increase per 
vehicle 
Higher cost results from the need 
to compensate for the autonomous 
mass increase of 1.5% 
(AMI=1.5%) 
Cost-effectiveness to society (cumulative GHG abatement cost 2012-2020) ☺ 
-13.5 to -10.2 €/ton CO 2 eq. ☺ 
Around -13.5 €/ton CO 2 eq. 
Other economic 
impacts (incl. competitive neutrality) . 
The slope of 60% makes it very 
challenging for some manufacturers producing larger vehicles (class III) to meet their respective targets. The slope of 100% gives a more even distribution of co sts over different 
manufacturers and on average a lower cost of compliance for the industry.  The start date of 2012 is very challenging and does not leave enough lead time for manufacturers to adjust their production cycles. ./☺ 
Concerning slope and costs this 
option has similar characteristics as option 1. However, it provides manufacturers with more time to respond to the requirements of the legislation (i.e. longer lead time ). 
 
Other economic impacts - impact on businesses including SMEs ☺ 
Light Commercial Vehicles are 
mostly used by commercial 
enterprises including SMEs. At 
both slopes there are net benefits to 
the vehicle operator. ☺ 
At both slopes there are net 
benefits to the vehicle operator. 
Option 2 also offers net benefits 
per vehicle to the vehicle operator 
in the same order as option 1.  
EN 45   EN  Option 1 
Mass-based utility 
Target year – 2012 
Slope: 60% - 100% Option 2 
Mass-based utility 
Target year – 2013-2015 
Slope: 60% - 100% 
Social impacts (employment) ☺ 
The higher added value on the 
vehicle is likely to lead to more 
employment along the value chain 
(similarly to effects of CO 2/cars 
regulation).  
The adverse impacts on the sales 
of new vehicles are estimated to be 
very small: -0.69% to – 1.33%  ☺ 
The higher added value on the 
vehicle is likely to lead to more 
employment along the value chain 
(similarly to effects of CO 2/cars 
regulation).  
The adverse impacts on the sales 
of new vehicles are estimated to be 
very small, around -1%.  
 
5.6.1.  Long-term target38 
2020 target 160 g/km 150 g/km 140 g/km 135 g/km 125 g/km 
2020 59.1 61.7 71.7-64.3 65.6-81.6 68.2 Environmental 
impacts [cum. 
GHG savings in 
Mt] 2030 
237 267 297-311 312-342 342 
2020 3.18 3.49 3.80-4.07 4.21 4.51 Fuel savings [in 
Mt] 2030 5.99 7.02 8.06-8.19 8.57-8.85 9.60 
Fuel savings at 4% 
discount rate [€/vehicle] 3477 4286 5094 5499 6307 
Retail price increase 
[€/vehicle] (extra strong 
downsizing; slow 
penetration scenario)  1499 2049 2907 3335 4193 
2020 -38.9 -36.9 -34.7 to -
35.1 -33.4 to -
34.2 -32.6 Cost-
effectiveness to 
society 
[€/tCO 2] 2030 -34.9 -29.6 -25.4 to -
25.5 -23.7 to -
23.9 -20.6 
6. MONITORING AND EVALUATION  
6.1. Core indicators of progress towards meeting the objectives 
The core indicators of progres s are linked to the evolution of the average new fleet of 
light commercial vehicles over the year s, and they cover data relating to:  
                                                 
38 Only for combined scenarios with 50% cap 
EN 46   EN • specific CO 2 emissions as measured under the EU  test procedure, to assess the 
performance of the automotive industry towards the respect of the mandatory targets,  
• utility (mass or footprint), to provide an analysis of the evolution of the EU LCV 
market e.g. in case a shift in utility would require an adaptation of the utility curve in 
the future. Further utility parameters su ch as maximum payload or maximum load 
volume have been proposed by stakeholders and could become part of a mandatory 
monitoring regime in order to assess the appropriateness of su ch parameters at a future 
review. 
6.2. Monitoring arrangements 
The necessary data have to be provided by manufacturers of light commercial vehicles 
already now at type approval (Directive 2004/3). The arrangements on monitoring of 
compliance with the legislation will be simila r to the ones for passenger cars. Further to 
the adoption of the regulation on CO 2 and cars, the national aut horities already now need 
to adopt the monitoring schemes to new require ments, e.g. by gatheri ng data on footprint. 
The Commission is currently working with the Member States to improve national 
monitoring schemes which also includes mon itoring of the registration of passenger cars 
as LCVs and the opposite. The revised mon itoring arrangements will allow using the 
similar scheme for both categorie s of vehicles, cars and vans. 
7. REFERENCE DOCUMENTS  
SUPPORTING STUDY  
1. AEA 2008 
Assessment of policy options for the regulation on CO 2 emission reduction for light-
commercial vehicles carried out by A SPEN, TNO, CE DELFT, OKO INSTITUT, 
Framework contract No. ENV/C.5/FRA/2006/0071, December 2008 
2. AEA 2009 
Assessment with respect to long term CO 2 emission targets for passenger cars and vans 
carried out by ASPEN, TNO, CE DELFT,  OKO INSTITUT, Fram ework contract No. 
ENV/C.5/FRA/2006/0071, July 2009 
FLEETS  2008 
European Database of Vehicle Stock for th e Calculation and Forecast of Pollutant and 
Greenhouse Gases Emissions with TR EMOVE and COPERT, Contract No 
070501/2006/451259/MAR/C5, Final report, 2008 
TNO  2004 
Service Contract on the Policies for reducing CO 2 emissions from light commercial 
vehicles, carried out by TNO, IEEP and LA T on behalf of the European Commission 
(DG Environment) in 2003-2004 
TNO  2006 
EN 47   EN Review and analysis of the reduction poten tial and costs of t echnological and other 
measures to reduce CO 2-emissions from passenger cars, study for DG Enterprise carried 
out by TNO, IEEP and LAT/AUTh, Contract nr. SI2.408212, October2006 
EN 48   EN ANNEX I: GLOSSARY  
Light-duty vehicles (LDVs)  - passenger cars and li ght commercial vehicles 
Light Commercial vehicles (LCVs) – the definition applied for the purpose of this 
document aligns the scope of LCVs with that of the Euro 5/6 legislation and covers N1, 
N2 and M2 vehicles with a reference mass not exceeding 2610 kg. This is further 
extended to those vehicles with reference mass up to 2840 kg to which type-approval is 
extended in accordance with Article 2(2) of Regulation (EC) No 715/2007. 
N1 vehicles - definitions of N1 vehicles and N1 vehicle classes are given in Directive 
2007/46 Annex II; these are motor vehicles w ith at least four wheels designed and 
constructed for the carriage of goods a nd having a maximum mass not exceeding 3.5 
tonnes. Classes of N1 vehicles are define d on the basis of refe rence mass: class I ( ≤ 
1305kg), class II (1305 kg < reference mass ≤ 1760 kg), class III (> 1760 kg).  
N2 vehicles  – according to Directive 2007/46 Annex II N2 vehicles are designed and 
constructed for the carriage of goods and having a maximum mass exceeding 3,5 tonnes 
but not exceeding 12 tonnes. 
M2 vehicles -  according to Directive 2007/46 Annex II M2 vehicles designed and 
constructed for the carriage of passengers, co mprising more than ei ght seats in addition 
to the driver's seat, and having a maximum mass not exceeding 5 tonnes. 
Autonomous mass increase (AMI) – is an indicator of an average increase of mass of 
the fleet resulting from such factor s as additional safety measures.  
Limit value curve  - in the utility based ap proach the obligation of CO 2 reduction is 
defined as a linear function of a so-called "u tility" parameter reflecting the utility of 
vehicles. The line is such that the average ne w LCV fleet respects the average target (e.g. 
175 g/km). A 100% curve is based on the observe d trend in a base year, scaled down to 
reach the desired limit value. Furthermore, one can rotate the curve around the point of 
average utility and the targeted CO 2 level, which means that even though the slope 
changes the average target remains the same. The rotation can make the curve flatter 
(below 100%) in which case vehicles with hi gher utility would have to reduce more in 
order to meet the target, or steeper (above  100%) for which smaller vehicles would be 
asked to make more effort. 
Utility parameter  – a parameter meant to distingu ish vehicles by their utility as 
perceived by buyers or users. The utility parameter can for example be chosen to be vehicle's mass, pan area or foot print, or its carrying capacity. 
EN 49   EN ANNEX II: SUMMARY OF STAKEHOLDER CONSULTATION 
02 SEPTEMBER 2008  
Stakeholder meeting on th e Proposal to reduce CO 2 emissions from light 
commercial vehicles, 02.09.2008 
Chairman: Philip Good, DG Environment 
The chair from the Clean Air and Transport unit in DG Environment opened the meeting 
and outlined the context for the stakeholde r consultation. The re vised strategy on CO 2 
emissions from light duty vehicles announ ced that the Commission would propose 
legislation to reduce CO 2 emissions from light commercial vehicles. The aim of this 
workshop was to give industry and NGO stak eholders to express their views on the 
proposed legislation and in particular the issue paper circulated  by the Commission.  
Introduction  
The chair gave an introductory presentati on, highlighting the main aspects of the 
proposed regulation on light commercial vehicles. These included following:  
• Proposed regulation on CO 2 from light commercial vehicl es should follow in general 
the structure of the proposal on passenger cars; 
• To be consistent with the sc ope of Euro 5 and Euro 6 standards (Regulation (EC) No. 
715/2007) the proposed regulation should cover vehicles of categories N 1, N2 and M 2;  
• The Communication from the Commission sets two targets for light commercial 
vehicles: 175 g/km target in 2012 and 160 g/km target in 2015. The proposed legislation should incl ude these targets; 
• With regard to long term targets it is possible to proceed in two ways, i.e. to set 
separate targets for passenger cars and light  commercial vehicles, or to set a single 
long term target; 
• It is considered appropriate to apply a utility curve based target in the proposed 
regulation. Utility parameters under consid eration are vehicle pan area and vehicle 
mass; 
• For manufacturers producing both M and N t ype of vehicles it is possible to allow 
pooling between cars and vans targets. Possibility for poo ling between manufacturers 
is also being considered; 
• It is considered to have a similar compliance mechanism to that for cars; 
• The possibility of including a derogation for small scale manufacturers will be 
considered. 
The Commission aims to make a proposal be fore the end of 2008. The full consultation 
paper is available at:  
http://ec.europa.eu/environment/air /transport/co2/co2_cars_regulation.htm
. 
EN 50   EN ACEA Presentation 
Mr. Rolf Stromberger from ACEA provided th eir opinion on some of the key questions 
in the issue paper. He highlighted that: 
• LCVs have a wide range of different designs  and are more varied in terms of vehicle 
configuration and body styles than passenger cars.  Functionality is one of the key 
purchase considerations for LCVs.  
• ACEA considered that CO 2 savings potential for LCVs were limited, as the vast 
majority of the light commercial vehicles  fleet is already equipped with diesel 
engines.  
• ACEA considered that there was a lack of CO 2 emissions data for light commercial 
vehicles, making it difficult to set targets.  
With regard to the specific questions posed by the Commission he noted that: 
• They do not consider that an immediate merger of the proposals on CO 2 emissions 
from passenger cars and that for light  commercial vehicles  is appropriate. 
• They do not support a common target for passenger cars and light commercial 
vehicles.  
• They agree that an increase in fuel pr ice makes technologies more cost-effective. 
• They consider that retail price increase would require the first owner to keep the 
vehicle longer to get the investment back. Small and medium enterprises may 
postpone investments in new vehicles.  
• ACEA supports a utility based approach, but  it raised a question whether a single 
utility parameter is sufficient to cover th e range of segments of vehicles. They 
emphasised that bigger vans carry significantly  more load that smaller vans and that 
this should be taken into consideration. 
• ACEA is supportive to the pooli ng between manufacturers,  
• They did not support pooling within a manu facturer between the targets for cars and 
vans due to competition concerns. 
• They support the possibility to grant de rogations to small scale producers.  
• They stated that the level of excess emissi ons premium should be similar those in the 
EU Emissions trading scheme.  
Summary of discussion  
ACEA was asked to clarify the statement that  retail price increase will cause a slowdown 
of fleet renewal. It was quite possible that any increase in price of the vehicle would be 
offset by the reduced fuel cost, so it could have little or no overall effect. ACEA thought 
EN 51   EN that in order to get back the extra purchase cost, users will drive the same vehicle for 
longer.  
ACEA proposed to exclude  vehicles of category M 2 from the scope of legislation, 
arguing that this segment of vehicles is specia lised, and that increased retail price of the 
vehicle may cause the increase in costs of  transportation of passengers so was not 
socially desirable. Other stakeholders thought that the rationale for this exclusion was not 
at all clear as these vehicles are based on N 1, and that it would not be correct to exclude 
one particular segment of vehicles.  
Industry representatives were concerned about  a long product cycle of 10 years, due to 
which manufacturers will have  difficulties in reaching the target in 2012. They also 
stressed that all new tec hnologies being developed now have to undergo long testing 
procedures before implementing them in th e vehicles. The assertion that it was not 
possible improve vehicle fuel efficiency in  a shorter time period was disputed, as for 
example emissions requirements tended  to change every 4- 5 years. 
Industry representatives stated that it ma y not be enough to a pply a single utility 
parameter, due to the large segmentation of  light commercial vehicles. However, no 
preference was expressed for a specific  utility parameter at this stage. 
The issue of multi-stage vehicles was also raise d. It was noted that these vehicles are sold 
incomplete, so there is an issue of who s hould be responsible for emissions from these 
vehicles. ACEA was asked to provide informa tion on what is the share of sales of these 
vehicles and the type approval arrangements for vehicles which have been completed by a coachbuilder.  
There were questions as to why ACEA opposed  pooling between the cars target and the 
vans target. Their opposition was because of competition concerns between different manufacturers. JAMA and KAMA did not have a common position regarding the pooling yet.  
Other questions and comments: 
• A comment was made that a maximum ma ss limit can cause loopholes and perverse 
incentive to produce heavier vehicles that will be outside of the scope of this regulation. 
• A question was asked about the strategy if there will be a fleet wide non-compliance 
with the target due to sh ift to heavier vehicles. 
• A comment was made that all derogations in the legislation should not be permanent 
and need to be regularly reviewed. 
• A comment was made that di fferent policies between M
1 and N 1 classes could cause a 
distortion in the M 1 and N 1 markets. 
At the end of the meeting stakeholders were  informed that the presentations of DG 
Environment and ACEA will be circulated via e-mail. Stakeholders were asked to 
provide their additional co mments by 30 September 2008.  
EN 52   EN In addition DG Environment received some wr itten responses to the consultation which 
can be accessed on:  http://ec.europa.eu/environment/air /transport/co2/co2_cars_regulation.htm
 
EN 53   EN ANNEX III: SUMMARY  OF SECOND  STAKEHOLDER  CONSULTATION  09 
MARCH  2009  
Chairman: Stefan Moser, Günter Hörmandinger, DG Environment 
The chair from the Clean Air and Transport unit in DG Environment opened the meeting 
and outlined the context for the stakeholder c onsultation. The aim of this meeting was to 
inform all interested parties about the progress with regard to the development of the legislative proposal on li ght commercial vehicles  and to provide an opportunity to share 
views on the proposal. 
Introduction
 
Representative of the contractor39 Richard Smokers gave an in troductory presentation on 
the main elements and findings of the re port on the Assessment of options for the 
legislation of CO 2 emissions from light commercial vehicles. The main conclusions of 
the report were: 
• 175 g/km target can be reached in 2012/15 
– at around 10% retail price increase 
• 160 g/km target not feasible for 2015 
– based on static cost curves for 2012-15 period with conservative safety 
margin for assessing total reduction potential for combined measures 
– assessment of a long-term ta rget for 2020 still on-going 
– analysis will include additional technological options and cost 
reduction as function of cumula tive production due to learning 
effects  
• mass-based limit function with slope ≥ 80% preferred due to: 
– lowest average costs per vehicle for meeting target  
– most equal distribution of efforts among manufacturers 
– limited chance of perverse effects compared to M1 
• non-zero AMI has strong impacts on costs 
impacts on CO 2 corrected by adjusting the limit curve 
                                                 
39 Consortium of AEA, CE Delft and TNO; analysis performed under the f ramework contract DG 
ENV/C.5/FRA/2006/0071  
EN 54   EN ACEA presentation 
Mr Rolf Stromberger from ACEA (Associ ation of European Car Manufacturers) 
provided joint position of association’s me mbers on some of the key issues in the 
proposal and the report. Th e main highlights are:  
• it is a business-to-business market and ther e is a high diversity in customer needs 
• there is no need for a regulation on light commercial vehicles, because:  
– 85% of road vehicles are already covered by CO 2 cars legislation 
– LCVs are responsible for 1,7% of man-made CO 2 emissions in the EU 
– LCVs are not 'emotional products' and are not driven by fashion, they need 
to fulfil a work function; 
• ACEA considers that dir ect application of the same design used for CO 2 and cars 
regulation is not appropriate because of differences between passenger cars and LCVs, 
for instance: dedicated business needs;  higher diversity of LCVs; limited CO 2 
reduction potentials; etc.  
• Impact assessment should sufficiently cons ider the wide range of LCVs and other 
aspects as lead-time. According to ACEA  inadequate impact assessment may put 
additional burden on industry and customer s and is incompatible with CARS 21 
principles. 
• ACEA noted that LCV's development a nd product cycles are longer than for 
passenger cars. In addition, due  to cash shortage and econo mic situation the current 
development time for LCVs will be even longer. Therefore, ACEA believes that 
proposed CO 2 target in 2012 does not consider lead-time needs; 
• According to ACEA, CO 2 saving potential for LCVs is limited as compared to cars 
because diesel engine penetration is  above 90%; load volume determines 
aerodynamics and design of vehicle; some t echnologies for cars are not applicable or 
have lower CO 2 reduction potential (e.g. engine down- sizing). Due to this the vehicle 
price and CO 2 abatement costs will increase significantly.  
• ACEA considers that the data used by the c onsultant is weak because it contains many 
assumptions; 
• ACEA considers that cost increase for LCVs  will not be recoverable because of the 
following aspects:  
– CO 2 fleet average is not representative 
– When proposing targets in the revised Strategy on CO 2/LDVs it was not 
considered that CO 2 reduction for LCVs is more costly than for passenger 
cars; 
EN 55   EN – For proposed Community target of 175g/ km average retail price increase 
would be €1,650–€2,000 (excl. tax); 
– Tougher long term target will require further cost increase and it is not 
technically feasible. 
• ACEA considers that consultants st udy does not justify the proposed CO 2 target for 
LCVs; 
• The current economic situation of the automotive industry: LCV sales dropped by 
35.6% in January 2009; forecasts show that vehicles production in the world will 
further decrease in 2009. The goal of the industry is to  get through the recession 
without long-term damage to competitiven ess and minimisation of the closure of 
production sites.  
• ACEA considers that proposed legisl ation needs a robust database and a 
comprehensive impact assessment and it proposes a following way forward:  
– Joint work of the Commission and the industry on the vehicles database; 
– Setting more realistic targets than  currently proposed and allowing 
sufficient lead-time; and avoiding additional economic burden; 
– Consideration of the cumula tive costs of regulation. 
FIA European Bureau presentation 
Mr Wilfried Klanner from FIA (Fédérati on International d’Automobiles) European 
Bureau presented results of their own analysis conducted on the ADAC data to 
demonstrate the influence of differ ent target line concepts on the CO 2 emission reduction 
potential based on the strategy to reduce CO 2 from LDVs, and on the achievability of 
these targets by future N1 fl eet. The objective of this an alysis was to find the most 
promising concept. The analysis looked at three policy options: utility curve based on 
kerb weight, utility curve based on gross mass,  and similar scheme as the one used in 
regulation on CO 2 from passenger cars. 
Based on this analysis of the data, FI A presented the following conclusions: 
i. The constant CO 2 reduction target line concep t, based on vehicle kerb 
weight respectively on vehicle refe rence mass, is likely to be a good 
compromise between CO 2 reduction potential and achievability.  
ii. Using the M1 target line for the N1 car fleet as well is  not a satisfactory 
solution, due to low achiev ability and due to the fact  that, in contrast to 
M1 cars, heavier N1 vehicles norm ally also transport higher loads. 
Therefore heavier N1 should not  be punished by more demanding 
thresholds, as it is the case for the M1 target line. 
iii. Based on this concept the target lines to fulfil the CO 2 emission targets for 
2012 and 2015 are developed and discussed. 
EN 56   EN iv. The outcomes of this analysis s how good compliance with the findings of 
the AEA study.  
v. FIA proposal for 2012- 175 g/km average- a constant CO 2 reduction target 
line based on vehicle kerb mass. 
vi. The target line of 2012 would mean  13,79% reduction line (203 g/km to 
175 g/km)- already today a lot of ve hicles are meeting this target. 
Contribution by Axel Friedrich 
Axel Friedrich presented a short statemen t on behalf of German environmental NGOs . 
An importance of reducing CO 2 emissions from all sources (also small emitters) and 
energy security (i.e. lowering relian ce on imports of oil) was stressed .  
Mr Friedrich referred to the estimation of cost s in the contractor’s report saying that they 
are much too high. In addition, a longer life time of light commercial vehicles, and thus 
longer impact on emissions, should be taken in to account in the estimations of efficiency 
of CO 2 reductions. In UBA the costs of optimised technological packages were estimated 
proving that these reductions can be done at much lower costs,  e.g. optimisation of tyres 
can provide savings of 5%, e ngine friction 3-5% with virt ually no cost, improvement of 
air resistance of vehicles can also contribu te to fuel efficiency. Taking this into 
consideration when analysing data in the repor t leads to conclusions that the target of 
175g/km can be reached with no additional costs.  
In addition, Mr Friedrich claimed that nearly all light commercial vehi cles in class I are 
derived from passenger cars which means that CO 2 reduction in the former could be done 
using the same solutions as in M1. According to the speaker half of LCVs in class II 
could also benefit from invest ments in efficiency in passenger cars (example of the 
retrofitting programme in Germany). The stat ement that some of the targets cannot be 
made was also opposed and benefits to societ y being three times higher than costs were 
highlighted. In addition, an example of hybr id LCVs being used in Japan and USA and 
offering 50-60% of reduction in fuel consumption was given. 
Mr Friedrich also referred to an agreement on phasing out of cooling agent for air 
conditioners 134a and possible plan s of manufacturers to delay coming into effect of this 
agreement until 2017. The speaker claimed that  this should be penalised by adding 8-10g 
of CO 2 to the emissions figure of vehicles. 
Finally, a mass-based utility parameter wa s questioned, and volume/or area based 
standard was proposed instead as more suitable for LCVs. 
Contribution by JAMA (Hiroki Ota) 
The representative of Association of Ja panese Automobile Manufacturers (JAMA) 
highlighted that the recommendations of CA RS 21 should be respected while preparing 
this proposal and that unnecessary costs for the industry should be avoided. Mr Ota 
called for a comprehensive impact assessment of the proposal, especially because the costs of compliance are higher than for passenger cars. A need for more precise and accurate database was reiterated and JAMA offered support to the Commission in this 
EN 57   EN respect. The speaker reminded that manufactur ers of LCVs need more lead time due to 
longer product cycles, especially the target  date of 2012 is too short to achieve it. 
Summary of discussion  
- Timing of the proposal 
The representative of the European Shi ppers Council expressed its concern on the 
timeline highlighting that their members will not be left with much choice if heavier vans 
go out of the market and that it will cause serious problems of efficiency. Timing of 
2012/15 was therefore assume d to be not realistic. 
The official from the Ministry of Envir onment of the Netherlands asked whether the 
long-term target (mentioned by the contractor ) would also be incl uded in the proposal. 
- Slope of the utility line and utility parameter 
The representative of the European Shippers  Council questioned whether it would be fair 
if all categories had the same burden (100% slope). A possibility  of relative ta rgets, i.e. 
same relative reduction effort for large and sm all vans was suggested  as a better option. 
Jos Dings from Transport and Environment said that mass-based parameter was an 
unfortunate consequence of copying M1 proposal. T&E study on feasibility of footprint 
parameter concluded that costs are likely to be lower in this approach. The speaker said 
that it is possible to use this parameter becau se the data is available and in addition the 
light weighting options pay off fully. Jos Dings also reminded that the regulation on 
LCVs has been in place in the USA for 30 ye ars thus, in reality the diversity of the 
market is not an obstacle to regulation. 
Axel Friedrich highlighted that any parameter that is based on the area, i.e. pan area or 
footprint, is better because of  the utility of LCVs (to tr ansport goods) and because it 
prevents a misuse. The data on pan area is available whereas foot print, although more 
complicated, can be estimated ba sed on data from manufacturers. 
Wilfried Klanner referred to AEA study and comparison of the outcomes of different 
policies (incl. different utility parameters) a nd asked for keeping the same approach as in 
M1 regulation. Pan area does not bring many benefits because of the wider scatter. 
- Pooling 
The representative of Toyota expressed a conc ern that some of the manufacturers do not 
produce passenger cars and therefore would not have an opportunity to use the flexibility 
of pooling. 
An official from Department for Transport (UK) also questioned the practicality of this 
flexibility even though it sounds reasonabl e from the theoretical point of view. 
- Derogations 
EN 58   EN The representative of Jaguar Land Rover hi ghlighted that Land Rover products would 
need a derogation for small volume manuf acturers due to very high costs of CO 2 
reductions and a specific use of  vehicles (i.e. off-road). 
The participant from the UK Society of Mo tor Manufacturers and Traders (SMMT) also 
mentioned that the diversity of the mark et should be preserved and the case for 
derogations (also based on other parameters than volume) should be made. The concern 
over impacts of abatement costs on small vol ume manufacturers was also expressed by 
the official from Department fo r Transport (UK) and a need to  include these actors to the 
analysis was highlighted. 
T&E stressed that any derogation has a tendenc y to grow into a regulatory gap which can 
be abused. In addition, a need for speed  limiters for LCVs should be seriously 
considered. LCVs are often overloaded and raise safety concerns . This was backed 
strongly by a representative of German NG Os. The official from the Ministry of 
Environment (NL) agreed that  this issue should be anal ysed. ACEA mentioned some 
concerns on the grounds of safety. The Europ ean Shippers Council highlighted that speed 
limiters should be able to adapt to traffic situation. 
In addition, a demand for inclusion of superc redits for low emitting vehicles (similar to 
the ones introduced in the CO 2/cars regulation) was made.  
Finally, ACEA and Ford called for the current economic situation to be taken into 
account, especially in vi ew of current difficulties in gett ing financing. It was highlighted 
that in order to meet the targets in 2012/15 investment should take place now. In 
addition, ACEA representative proposed to co ntribute to improvement of the database 
used in the analysis. 
The Chairman concluded the meeting and invi ted participants to send their written 
contributions in the coming weeks. 
EN 59   EN ANNEX IV: DISTRIBUTIONAL EFFECTS ON MANUFACTURERS  
Part A – Mass-based utility parameter (options 1, 2 and 5)40 
Figure 7 Estimate of absolute price increase fo r options 1, 2 and 5 with AMI = 0.0% 
p.a. (Source: Supporting study on li ght commercial vehicles)   
175 g/km - per manufacturer - utility - m / 
AMI = 0% / b1
010002000300040005000600070008000
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageAbsolute retail price increase [€]per manuf. - utility - m - slope 0%
per manuf. - utility - m - slope 20%
per manuf. - utility - m - slope 40%
per manuf. - utility - m - slope 60%
per manuf. - utility - m - slope 80%
per manuf. - utility - m - slope 100%
per manuf. - utility - m - slope 120%
per manuf. - percentage red.2012/15
 
                                                 
40 Mazda (and to a lesser extent Hyundai for pan area) appears to be an outlier in this analysis. This 
is due to inclusion of pick-up SUVs with relatively high CO 2 emissions as N-type vehicles in the 
JATO database. These vehicles are also included in  the sales figures of other, mainly Japanese and 
Korean, manufacturers. 
EN 60   EN Figure 8 Estimate of relative price increase for options 1, 2 and 5 with AMI = 0.0% 
p.a. (Source: Supporting study on li ght commercial vehicles)  
175 g/km - per manufacturer - utility - m / 
AMI = 0% / b1
0%5%10%15%20%25%30%35%40%
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageRelative retail price [%]per manuf. - utility - m - slope 0%
per manuf. - utility - m - slope 20%
per manuf. - utility - m - slope 40%
per manuf. - utility - m - slope 60%
per manuf. - utility - m - slope 80%
per manuf. - utility - m - slope 100%
per manuf. - utility - m - slope 120%
per manuf. - percentage red.2012/15
 
Figure 9  Estimate of absolute price increase for options 1 and 5 with AMI = 1,5% 
p.a. (Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - m / 
AMI = 1.5% / b1
010002000300040005000600070008000
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageAbsolute retail price increase [€]per manuf. - utility - m - slope 0%
per manuf. - utility - m - slope 20%
per manuf. - utility - m - slope 40%
per manuf. - utility - m - slope 60%
per manuf. - utility - m - slope 80%
per manuf. - utility - m - slope 100%
per manuf. - utility - m - slope 120%
per manuf. - percentage red.2012
 
EN 61   EN Figure 10 Estimate of relative price increase for options 1 and 5 with AMI = 1,5% 
p.a. (Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - m / 
AMI = 1.5% / b1
0%5%10%15%20%25%30%35%40%
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageRelative retail price [%]per manuf. - utility - m - slope 0%
per manuf. - utility - m - slope 20%
per manuf. - utility - m - slope 40%
per manuf. - utility - m - slope 60%
per manuf. - utility - m - slope 80%
per manuf. - utility - m - slope 100%
per manuf. - utility - m - slope 120%
per manuf. - percentage red.2012
 
Figure 11 Estimate of absolute price increase  for option 2 with AMI = 1,5% p.a . 
(Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - m / 
AMI = 1.5% / b1
010002000300040005000600070008000
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageAbsolute retail price increase [€]per manuf. - utility - m - slope 0%
per manuf. - utility - m - slope 20%
per manuf. - utility - m - slope 40%
per manuf. - utility - m - slope 60%
per manuf. - utility - m - slope 80%
per manuf. - utility - m - slope 100%
per manuf. - utility - m - slope 120%
per manuf. - percentage red.2015
 
EN 62   EN Figure 12 Estimate of relative price increase for option 2 with AMI = 1,5% p.a.  
(Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - m / 
AMI = 1.5% / b1
0%5%10%15%20%25%30%35%40%
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageRelative retail price [%]per manuf. - utility - m - slope 0%
per manuf. - utility - m - slope 20%
per manuf. - utility - m - slope 40%
per manuf. - utility - m - slope 60%
per manuf. - utility - m - slope 80%
per manuf. - utility - m - slope 100%
per manuf. - utility - m - slope 120%
per manuf. - percentage red.2015
 
Part B- pan area-based utility parameter (options 3, 4 and 5)  
Figure 13  Estimate of absolute price increase  for option 3 with AMI = 0.0% p.a. 
(Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - l x w / 
AMI = 0% / b1
010002000300040005000600070008000
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageAbsolute retail price increase [€]per manuf. - utility - lxw - slope 0%
per manuf. - utility - lxw - slope 20%
per manuf. - utility - lxw - slope 40%
per manuf. - utility - lxw - slope 60%
per manuf. - utility - lxw - slope 80%
per manuf. - utility - lxw - slope 100%
per manuf. - utility - lxw - slope 120%
per manuf. - percentage red.2012/15
 
EN 63   EN Figure 14 Estimate of relative price increase for option 3 with AMI = 0.0% p.a.  
(Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - l x w / 
AMI = 0% / b1
0%5%10%15%20%25%30%35%40%
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageRelative retail price [%]per manuf. - utility - lxw - slope 0%
per manuf. - utility - lxw - slope 20%
per manuf. - utility - lxw - slope 40%
per manuf. - utility - lxw - slope 60%
per manuf. - utility - lxw - slope 80%
per manuf. - utility - lxw - slope 100%
per manuf. - utility - lxw - slope 120%
per manuf. - percentage red.2012/15
 
Figure 15  Estimate of absolute price increase for option 3 with AMI = 1,5% (Source: 
Supporting study on light commercial vehicles) 
175 g/km - per manufacturer - utility - l x w / 
AMI = 1.5% / b1
010002000300040005000600070008000
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageAbsolute retail price increase [€]per manuf. - utility - lxw - slope 0%
per manuf. - utility - lxw - slope 20%
per manuf. - utility - lxw - slope 40%
per manuf. - utility - lxw - slope 60%
per manuf. - utility - lxw - slope 80%
per manuf. - utility - lxw - slope 100%
per manuf. - utility - lxw - slope 120%
per manuf. - percentage red.2012
 
EN 64   EN Figure 16 Estimate of relative price increase for option 3 with AMI = 1,5% p.a.  
(Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - l x w / 
AMI = 1.5% / b1
0%5%10%15%20%25%30%35%40%
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageRelative retail price [%]per manuf. - utility - lxw - slope 0%
per manuf. - utility - lxw - slope 20%
per manuf. - utility - lxw - slope 40%
per manuf. - utility - lxw - slope 60%
per manuf. - utility - lxw - slope 80%
per manuf. - utility - lxw - slope 100%
per manuf. - utility - lxw - slope 120%
per manuf. - percentage red.2012
 
Figure 17 Estimate of absolute price increase  for option 4 with AMI = 1,5% p.a.  
(Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - l x w / 
AMI = 1.5% / b1
010002000300040005000600070008000
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageAbsolute retail price increase [€]per manuf. - utility - lxw - slope 0%
per manuf. - utility - lxw - slope 20%
per manuf. - utility - lxw - slope 40%
per manuf. - utility - lxw - slope 60%
per manuf. - utility - lxw - slope 80%
per manuf. - utility - lxw - slope 100%
per manuf. - utility - lxw - slope 120%
per manuf. - percentage red.2015
 
EN 65   EN Figure 18  Estimate of relative price increase  for option 4 with AMI = 1,5% p.a . 
(Source: Supporting study on li ght commercial vehicles) 
175 g/km - per manufacturer - utility - l x w / 
AMI = 1.5% / b1
0%5%10%15%20%25%30%35%40%
PSA
GM
Renault
Fiat
Ford
Volkswagen
Toyota
Hyundai
LDV
Isuzu
Mitsubishi
Nissan
Daimler
Mazda
AverageRelative retail price [%]per manuf. - utility - lxw - slope 0%
per manuf. - utility - lxw - slope 20%
per manuf. - utility - lxw - slope 40%
per manuf. - utility - lxw - slope 60%
per manuf. - utility - lxw - slope 80%
per manuf. - utility - lxw - slope 100%
per manuf. - utility - lxw - slope 120%
per manuf. - percentage red.2015
 
EN 66   EN Figure 19 Relative retail price increase – scenarios for the long-term target (Source: 
Supporting study on light commercial vehicles) 
Relative retail price increase 
0,0%5,0%10,0%15,0%20,0%25,0%30,0%35,0%
100 120 140 160 180 200
Target [g/km]Price increase [€/vehicle]No learning
Learning: slow penetration
Learning: fast penetration
No learning
Learning: slow penetration
Learning: fast penetration
 Hybrid 
Extra strong 
downsizing 
EN 67   EN Table 5 Summary of the average costs for reachin g the different 2020 target levels in 
the 6 different scenario var iants - all relative to 2007  (Source: calculations based on 
supporting study) 
 Absolute retail price increase relative to 2007 [€/vehicle] 
 Extra strong downsizing Hybrid options 
Target No 
learning Learning: 
slow 
penetrationLearning: 
fast 
penetrationNo 
learning Learning: 
slow 
penetration Learning: 
fast 
penetration
160(a) 1599 1499 1420 2155 2004 1899 
150 2175 2049 1954 3030 2840 2703 
140(a) 3066 2907 2797 4584 4354 4179 
135(a) 3512 3335 3219 5360 5111 4917 
125 4403 4193 4062 6914 6625 6393 
 
(a) Values are obtained by linear interpolat ion which causes a certain overestimate.  Relative retail pri ce increase relative to 2007 [€/vehicle] 
 Extra strong downsizing Hybrid options 
Target No 
learning Learning: 
slow 
penetrationLearning: 
fast 
penetrationNo 
learning Learning: 
slow 
penetration Learning: 
fast 
penetration
160(a) 7,6% 7,1% 6,8% 10,2% 9,5% 9,0% 
150 10.3% 9.7% 9.3% 14.4% 13.5% 12.8% 
140(a) 14,5% 13,8% 13,3% 21,8% 20,7% 19,8% 
135(a) 16,7% 15,8% 15,3% 25,5% 24,3% 23,4% 
125 20.9% 19.9% 19.3% 32.9% 31.5% 30.4% 
EN 68   EN Table 6 (1) Summary of fuel savings and net co sts/benefits for the different 2020 
target levels(b) at 4% discount rate (Source: calculations ba sed on supporting study) 
  Total user costs and benefits (discount rate of 4%) [€/vehicle]  
  Extra strong downsizing Hybrid options 
Target Discounted 
fuel saving No 
learning Learning: 
slow 
penetrationLearning: 
fast 
penetrationNo 
learningLearning: 
slow 
penetration Learning: 
fast 
penetration
160(a) 3477 -1878 -1978 -2057 -1322 -1473 -1578
150 4286 -2110 -2237 -2331 -1256 -1445 -1583
140(a) 5094 -2028 -2188 -2297 -511 -740 -915
135(a) 5499 -1987 -2163 -2279 -138 -387 -582
125 6307 -1904 -2114 -2245 607 318 86
(b) Taking into account purchase price increase and fuel savings; assuming a fuel price of 
€1 per litre including taxes and a mileage of  300 000km over a 15 year lifetime. Negative 
numbers are savings. 
(2) Summary of fuel savings and net cost s/benefits for the different 2020 target 
levels(b) at 10% discount rate (Source: calculations based on supporting study) 
  Total user costs and benefits (discount rate of 12%) [€/vehicle] 
  Extra strong downsizing Hybrid options 
Target Discounted 
fuel saving No 
learning Learning: 
slow 
penetrationLearning: 
fast 
penetrationNo 
learningLearning: 
slow 
penetration Learning: 
fast 
penetration
160(a) 2379 -779 -880 -958 -224 -375 -479
150 2932 -757 -883 -977 98 -92 -229
140(a) 3485 -419 -578 -687 1099 869 694
135(a) 3762 -250 -426 -542 1599 1350 1155
125 4315 88 -121 -252 2599 2311 2079
(b) Taking into account purchase price increase and fuel savings; assuming a fuel price of 
€1 per litre including taxes and a mileage of  300 000km over a 15 year lifetime. Negative 
numbers are savings. 
EN 69   EN ANNEX V DESCRIPTION OF THE METHODOLOGY  
• Estimates of costs and distributional impacts for vehicle manufacturers 
An ex-ante model developed by consultants an alysed the distributional effects and costs 
among manufacturers. The cost model used in  this supporting study was based on cost 
curves representing different combinations  of powertrain technol ogies. The methodology 
for defining cost curves was based on info rmation collected from the industry on the 
relative CO 2 reduction potential (% reduction) and a dditional costs (€) for a large number 
of technological CO 2 reduction options41 that can be applied to baseline N1 vehicles. For 
each vehicle segment (defined by vehicle class and fuel) a number of technology packages was assembled, containing a comb ination of various technology options for 
which overall reduction potential and cost s were estimated. The overall relative CO
2 
reductions were then applied to the average CO 2 emission per segment of the 2002 
baseline vehicles. This methodology was al so used in the supporting study on LCVs 
however, the cost curves were updated to mirror more recent reference data.42  
The starting point for the determina tion of cost curves were the 2002 reference vehicles, 
however the database used in the suppor tive study on LCVs provided information for 
2007 only. To obtain 2002 reference data that would be consistent with the 2007 
averages determined from the database , assumptions on the development of CO 2 
emissions in LCVs between 2002 and 2007 were made. Previous studies (see Annex I) 
have suggested that in the period from  2002 to 2006 manufacturers have applied CO 2 
reduction technologies to vehicles. In a ddition manufacturers have applied some 
efficiency improvements to M 1 vehicles in the context of the voluntary agreements 
covering these vehicles. As these agreements  do not apply to LCVs it has been assumed 
that the amount of CO 2 reduction measures applied in LCVs is smaller than in cars. The 
total reduction was set at 3.5% for petrol vehi cles and 2.5% for diesel vehicles over the 
complete 2002-2007 period. 
In order to properly determine the maximum reduction potential available in the various 
LCV segments, the number of technology packages  used to construct the cost curves has 
been extended from 4 to 5, as compared w ith the previous analysis. The updated cost 
curves are provided in the figure 1. 
It is important to note that the analysis for the range of dates considered for the first step 
of emission reductions is based on the static cost curves. Possible effects of developments in technology, le arning effects and costs are i gnored for this short term 
horizon. The only dynamic element in this shor t-term analysis is the autonomous mass 
increase (AMI). 
• For certain scenarios for the long-term targ et a linear approximation was performed. 
This is methodologically justif ied because the targets for wh ich the intra/extrapolation 
was done are sufficiently close to the basis points (i.e. the target of 140 g/km in 2020 
                                                
 
41 The methodology was developed in the Supportive study carried out in 2006 [TNO 2006] 
Technological CO 2 reduction options were presented in the Tables 8.2 and 8.3 of this study. 
42 For more information see the study: Assessment of options for CO 2 legislation for LCVs, Chapter 
4 
  
EN 70   EN was estimated on the basis of modelled s cenarios for targets of 150 g/km and 125 
g/km, whereas 160 g/km on the basis of 175 g/km and 150 g/km). In addition, 13 
scenario runs in total were performed fo r short and long-term targets which allowed 
for a sufficient understanding of characteristics of the model. 
Figure 20  Estimated cost curves for emission s reductions from light commercial 
vehicles  (Source: Supporting study on light commercial vehicles) 
 
N1 petrol - cost curves based on 5 packages
0100020003000400050006000700080009000
0 20 40 60 80 100 120 140
CO2 reduction [g/km]Costs [Euro]Class I
Class II
Class III
 
 
N1 diesel - cost curves based on 5 packages
0100020003000400050006000700080009000
0 1 02 03 04 05 06 07 08 09 0 1 0 0
CO2 reduction [g/km]Costs [Euro]Class I
Class II
Class III
 
In the ex-ante assessment, no significant variation to overall segmentation of the car 
market is expected. 
• Dynamic modelling of economic and environmental impacts 
EN 71   EN In addition to the modelling of cost im pacts at manufacturer and consumer level, 
TREMOVE runs have been carried out. TREMOVE is a transport and emissions simulation model developed for the European Commission. It is desi gned to study the 
effects of different transport and environmen t policies on the emissions of the transport 
sector. The model estimates the changes in transport demand, modal split, vehicle fleets, 
welfare level and emissions of air pollutants of different policy scenarios. The scenarios 
for the present IA report have been mode lled using the latest version of the model 
TREMOVE 2.7, which covers all EU-27 Member  States over the period 1995-2030 with 
yearly intervals. 
The details on the model structur e and the baseline can be fo und in the final report of the 
service contract for the developm ent of the model on the website 
http://www.tremove.org/
. For the present report a varian t of the 2.7 baseline scenario has 
been used. New fuel prices for the EU countries, as they are known in 2008 were 
incorporated in this case. Also fuel taxes we re updated according to the situation in 2008. 
This mainly involved updating values for non Eu ro-zone countries as their exchange rate 
to Euro have changed and thus TREMOVE va lues which are in Eu ros of year 2000 had 
to be updated. 
EN 72   EN ANNEX VI: ECONOMIC IMPACTS  
Figure 21 CO 2 abatement costs for N-type vehicles  (for AMI = 0.0% p.a.) as function 
of the target level and the oil price for a mass-based limit function with slope 60%  
(Source: supporting study)  
CO2 abatement costs 
-250-200-150-100-50050100
25 50 75 100 125 150
oil price [€/bbl]abatement costs [€/ton]190
185
180
175
170
165
160
M1 - 130 g/km
discount rate = 4%
lifetime = 15 years
annual mileage = 20.000 kmmass-based limitslope 60%
AMI = 0.0% p.a.
 
Figure 22  CO 2 abatement costs for N1 vehicles (for  AMI = 0.0% p.a.) as function of the 
target level and the oil price for a mass- based limit function with slope 100% (Source: 
supporting study)  
CO2 abatement costs 
-300-250-200-150-100-50050100150
25 50 75 100 125 150
oil price [€/bbl]abatement costs [€/ton]190
185
180
175
170
165
160
M1 - 130 g/km
discount rate = 4%
lifetime = 15 yearsannual mileage = 20.000 kmmass-based limitslope 100%
AMI = 0.0% p.a.
 
EN 73   EN Table 7  Fuel savings for options 1,2 a nd long-term targets in 2020 and 2030  (Source: 
TREMOVE) 
scenario Fuel savings Fuel savings 
share in total road 
transport fuel 
consumption 
short-term target 
and start date 2020 
target slope cap fuel 
price43 
2020 
[Mt] 2030 
[Mt] slope cap 
60% no basecase 3.15 4.66 0.92% 1.22% 
100% no basecase 3.28 4.89 0.96% 1.28% 
60% 50% basecase 2. 85 4.15 0.83% 1.09% 175 g/km ( 2012 ) n/a 
100% 50% basecase 2. 85 4.15 0.83% 1.09% 
175 g/km ( 2015 ) n/a 60% no basecase 2 .86 4.55 0.84% 1.19% 
60% no half 3.24 4.84 0.95% 1.26% 
100% no half 3.38 5.07 0.99% 1.32% 
60% no double 2.98 4.36 0.87% 1.15% 175 g/km ( 2012 ) n/a 
100% no double 3.11 4.59 0.91% 1.21% 
175g/km ( 2013 ) 135g/km  100% 50% basecase 4. 54 8.85 1.33% 2.32% 
175g/km ( 2014 ) 140g/km 100% 50% basecase 4 .07 8.19 1.19% 2.15% 
175g/km ( 2015 ) 160g/km  100% 50% basecase 3. 18 5.99 0.93% 1.57% 
175g/km ( 2015 ) 150g/km 100% 50% basecase 3 .49 7.02 1.02% 1.84% 
175g/km ( 2015 ) 140g/km 100% 50% basecase 3.80 8.06 1.11% 2.11% 
175g/km ( 2015 ) 135g/km 100% 50% basecase 3.96 8.57 1.16% 2.25% 
175g/km ( 2015 ) 125g/km 100% 50% basecase 4 .27 9.60 1.25% 2.52% 
175g/km ( 2013 ) 135g/km 100% no basecase 4.62 8.91 1.35% 2.34% 
175g/km ( 2014)  140g/km 100% no basecase 4 .15 8.23 1.22% 2.16% 
175g/km ( 2015 ) 160g/km 100% no basecase 3 .26 6.02 0.95% 1.58% 
175g/km ( 2015 ) 150g/km 100% no basecase 3 .57 7.05 1.04% 1.85% 
175g/km ( 2015 ) 140g/km 100% no basecase 3.88 8.09 1.14% 2.12% 
175g/km ( 2015 ) 135g/km 100% no basecase 4.04 8.61 1.18% 2.26% 
175g/km ( 2015 ) 125g/km 100% no basecase 4 .35 9.64 1.27% 2.53% 
Note: Shaded scenarios are estimated us ing linear interpolation/extrapolation. 
                                                 
43 Fuel prices used in TREMOVE model are countr y specific and for all countries are expressed in 
Euro of year 2000. As an example of a baselin e, in Germany the assume d fuel price increases 
between 2000 and 2020 are as follows: pure biodiesel +27%, diesel +26%, ethanol +16%, gasoline +12%, CNG +4% and LPG +17%. 
EN 74   EN Table 8  Savings on fuel spending by end-us ers (incl. all taxes) in 2010-2020 and 
2010-2030  (Source: TREMOVE) 
 scenario savings in M€ 2000 
short-term target 2020 
target slope cap fuel 
price44 2010 to 2020 2010 to 2030 
60% no basecase -15 677 -41 952 
100% no basecase -16 436 -44 071 
60% 50% basecase -14 122 -37 535 175 g/km ( 2012 ) n/a 
100% 50% basecase -14 155 -37 611 
175 g/km ( 2015 ) n/a 60% no basecase -12 243 -37 228 
60% no half -13 337 -33 419 
100% no half -14 014 -35 265 
60% no double -20 086 -58 020 175 g/km ( 2012 ) n/a 
100% no double -21 005 -60 673 
175g/km ( 2013 ) 135g/km 100% 50% basecase -15 656 -60 721 
175g/km ( 2014 ) 140g/km 100% 50% basecase -13 891 -55 294 
175g/km ( 2015 ) 160g/km  100% 50% basecase -11 613 -42 452 
175g/km ( 2015 ) 150g/km 100% 50% basecase -11 953 -47 392 
175g/km ( 2015 ) 140g/km 100% 50% basecase -12 294 -52 331 
175g/km ( 2015 ) 135g/km 100% 50% basecase -12 464 -54 801 
175g/km ( 2015 ) 125g/km 100% 50% basecase -12 804 -59 741 
175g/km( 2013 ) 135g/km 100% no basecase -16 250 -61 748 
175g/km ( 2014)  140g/km 100% no basecase -14 459 -56 286 
175g/km ( 2015 ) 160g/km 100% no basecase -12 155 -43 395 
175g/km ( 2015 ) 150g/km 100% no basecase -12 496 -48 345 
175g/km ( 2015 ) 140g/km 100% no basecase -12 837 -53 295 
175g/km ( 2015 ) 135g/km 100% no basecase -13 007 -55 770 
175g/km ( 2015 ) 125g/km 100% no basecase -13 349 -60 721 
Note: Negative number denotes savings, positive additi onal costs. Saving (costs) in this table are 
discounted (4% rate) and are expres sed in Euros of year 2000. 
EN 75   EN Table 9  Effect on new LCV sales in 2020 and 2030  for options 1, 2 and long-term 
targets (Source: TREMOVE) 
scenario Total N1 market 
change [%] from 
2005 levels Change in 
vehicle sales 
short-term 
target 2020 
target slope cap fuel 
price44 
in 2020 in 2030 in 2020 in 2030 
baseline scenario +18.7% +19.2%   
60% no basecase +17.4% + 17.6% -1.16% -1.34% 
100% no basecase +17.2% + 17.3% -1.33% -1.59% 
60% 50% basecase +17.8% + 18.1% -0.83% -0.87% 175g/km ( 2012 ) n/a 
100% 50% basecase +17.9% + 18.3% -0.69% -0.75% 
175g/km ( 2015 ) n/a 60% no basecase +17.6% +17.6% -0.98% -1.34% 
175g/km ( 2013 ) 135g/km  100% 50% basecase +18.4% +16.9% -0.25% -1.88% 
175g/km ( 2014 ) 140g/km 100% 50% basecase +18.8% +17.3% +0.01% -1.58% 
175g/km ( 2015 ) 160g/km 100% 50% basecase +19.6% +18.9% +0.71% -0.23% 
175g/km ( 2015 ) 150g/km 100% 50% basecase +19.2% +18.1% +0.42% -0.92% 
175g/km ( 2015 ) 140g/km 100% 50% basecase +18.9% +17.2% +0.13% -1.62% 
175g/km ( 2015 ) 135g/km 100% 50% basecase +18.7% +16.8% -0.01% -1.97% 
175g/km ( 2015 ) 125g/km 100% 50% basecase +18.4% +16.0% -0.31% -2.66% 
175g/km ( 2013)  135g/km 100% no basecase +19.6% +18.7% +0.70% -0.37% 
175g/km ( 2014)  140g/km 100% no basecase +19.3% +18.2% +0.48% -0.78% 
175g/km ( 2015 ) 160g/km 100% no basecase +19.6% +19.0% +0.74% -0.11% 
175g/km ( 2015 ) 150g/km 100% no basecase +19.2% +18.2% +0.42% -0.84% 
175g/km ( 2015 ) 140g/km 100% no basecase +18.9% +17.3% +0.10% -1.57% 
175g/km ( 2015 ) 135g/km 100% no basecase +18.7% +16.9% -0.06% -1.93% 
175g/km ( 2015 ) 125g/km 100% no basecase +18.3% +16.0% -0.38% -2.66% 
Note: Shaded scenarios are estimated us ing linear interpolation/extrapolation 
EN 76   EN Table 10  Costs to end-users(a) in period 2010-2020  (Source: TREMOVE) 
scenario 
short-term 
target 2020 
target slope cap fuel 
price44 Additional 
costs 
[M€ 2000] Savings per 
1 € invested 
[€2000] 
175g/km ( 2013 ) 135g/km 100% 50% basecase -4 831 1.45 
175g/km ( 2014 ) 140g/km 100% 50% basecase -4 438 1.47 
175g/km ( 2015 ) 160g/km 100% 50% basecase -4 097 1.55 
175g/km ( 2015 ) 150g/km 100% 50% basecase -4 061 1.51 
175g/km ( 2015 ) 140g/km 100% 50% basecase -4 025 1.49 
175g/km ( 2015 ) 135g/km 100% 50% basecase -4 007 1.47 
175g/km ( 2015 ) 125g/km 100% 50% basecase -3 971 1.45 
175g/km( 2013 ) 135g/km 100% no basecase -4 658 1.40 
175g/km ( 2014)  140g/km 100% no basecase -4 291 1.42 
175g/km ( 2015 ) 160g/km 100% no basecase -3 987 1.49 
175g/km ( 2015 ) 150g/km 100% no basecase -3 943 1.46 
175g/km ( 2015 ) 140g/km 100% no basecase -3 900 1.44 
175g/km ( 2015 ) 135g/km 100% no basecase -3 878 1.42 
175g/km ( 2015 ) 125g/km 100% no basecase -3 834 1.40 
 (a) Costs in this table are discounted (4% ra te) and are expressed in Euros of year 2000 
EN 77   EN Note: Negative number denotes savings, positive additiona l costs. Saving (costs) in this table are 
discounted (4% rate) and are expressed in Euros of year 2000 
Table 11 Costs to end-users(a) in period 2010-2030  (Source: TREMOVE) 
scenario 
short-term target 2020 
target slope cap fuel 
price44 Additional 
costs [M€ 2000] Savings per
1 € invested 
[€2000] 
175g/km ( 2013 ) 135g/km 100% 50% basecase -10 442 1.21 
175g/km ( 2014 ) 140g/km 100% 50% basecase -10 519 1.23 
175g/km ( 2015 ) 160g/km 100% 50% basecase -12 232 1.40 
175g/km ( 2015 ) 150g/km 100% 50% basecase -11 138 1.31 
175g/km ( 2015 ) 140g/km 100% 50% basecase -10 044 1.24 
175g/km ( 2015 ) 135g/km 100% 50% basecase -9 497 1.21 
175g/km ( 2015 ) 125g/km 100% 50% basecase -8 403 1.16 
175g/km( 2013 ) 135g/km 100% no basecase -9 699 1.19 
175g/km ( 2014)  140g/km 100% no basecase -10 037 1.22 
175g/km ( 2015 ) 160g/km 100% no basecase -12 199 1.39 
175g/km ( 2015 ) 150g/km 100% no basecase -10 978 1.29 
175g/km ( 2015 ) 140g/km 100% no basecase -9 758 1.22 
175g/km ( 2015 ) 135g/km 100% no basecase -9 148 1.20 
175g/km ( 2015 ) 125g/km 100% no basecase -7 927 1.15 
(a) Costs in this table are discounted (4% ra te) and are expressed in Euros of year 2000 
Note: Negative number denotes savings, positive additiona l costs. Saving (costs) in this table are 
discounted (4% rate) and are expressed in Euros of year 2000 
Table 12  Results of price sensitivity runs  
175 gCO 2/km (no cap) WtW GHG abatement 
2010 >> 2020 [Mt CO 2 eq.] Abatement costs 
[€/t CO 2 eq.] 
60% slope base case 73 -12.5 
100% slope base case 77 -9.4 
60% slope half 75 12.9 
100% slope half 78 15.7 
60% slope double 71 -62.9 2012 
100% slope double 74 -59.6 
EN 78   EN  
Table 13 Comparison of marginal costs per ma nufacturer for a 175 g/km target in 
2012 / 2015 with different slope values for N-type vehicles (assumed AMI = 0.0% 
p.a.) with the marginal costs per manuf acturer for meeting the 130 g/km target 
based on a 60% slope in M1 category. (Source: supporting study on LCVs) 
 
EN 79   EN ANNEX VII: SOCIAL EQ UITY AND DISTRIBUTIONAL EFFECTS WITHIN 
THE FLEET  
Table 14 Relative retail price increase (%) per segment for alternative policy options  
(Source: Supporting study on light  commercial vehicles)  
 Diesel class I Diesel class II Diesel class III Sales-weighted average
Options 1 & 2 : 175 target in 2012/2015; utility parameter – mass; AMI = 0 
Slope 60% 3.6% 5.0% 6.3% 5.8% 
Slope 80% 4.4% 5.1% 5.8% 5.5% 
Slope 100% 5.2% 5.2% 5.4% 5.4% 
Option 1: 175 target in 2012; utility parameter – mass; AMI = 1.5% 
Slope 60% 5.2% 7.4% 8.9% 8.3% 
Slope 80% 6.2% 7.5% 8.3% 8.0% 
Slope 100% 7.3% 7.7% 7.9% 7.9% 
Option 2: 175 target in 2015; utility parameter – mass; AMI = 1.5 % 
Slope 60% 6.2% 9.0% 10.7% 9.9% 
Slope 80% 7.3% 9.2% 10.0% 9.6% 
Slope 100% 8.6% 9.4% 9.5% 9.5% 
Options 3 & 4 : 175 target in 2012/2015; utility parameter – pan area; AMI = 0 
Slope 60% 3.0% 5.0% 7.2% 6.3% 
Slope 80% 3.4% 5.0% 6.9% 6.1% 
Slope 100% 3.9% 5.0% 6.6% 6.0% 
Option 3: 175 target in 2012; utility parameter – pan area; AMI = 1.5% 
Slope 60% 4.3% 7.3% 9.9% 8.8% 
Slope 80% 4.8% 7.4% 9.6% 8.7% 
Slope 100% 5.5% 7.4% 9.3% 8.5% 
Option 4: 175 target in 2015; utility parameter – pan area; AMI = 1.5 % 
Slope 60% 5.1% 8.7% 11.8% 10.5% 
Slope 80% 5.8% 8.8% 11.4% 10.3% 
Slope 100% 6.5% 8.9% 11.1% 10.2% 
EN 80   EN ANNEX VIII: ENVIRONMENTAL IMPACTS  
Table 15 Well-to-wheel GHG reductions in year 2020 and 2030 for options 1, 2 and long-
term targets  (Source: TREMOVE) 
scenario GHG 
abatement 
[Mt CO2 
eq.] Contribution to 
the Effort 
Sharing 
Decision GHG 
abatement 
[Mt CO2 
eq.] 
short-term target 
and start date 2020 
target slope cap fuel 
price44 
2020 2030 
60% no basecase 11.4 4.2% 16.9 
100% no basecase 11.9 4.4% 17.7 
60% 50% basecase 10.3 3.8% 15.0 175 g/km ( 2012 ) n/a 
100% 50% basecase 10.3 3.8% 15.0 
175 g/km ( 2015 ) n/a 60% no basecas e 10.4 3.9% 16.5 
60% no half 11.7 4.4% 17.5 
100% no half 12.2 4.6% 18.3 
60% no double 10.8 4.0% 15.8 175 g/km ( 2012 ) n/a 
100% no double 11.2 4.2% 16.6 
175g/km ( 2013 ) 135g/km  100% 50% basecase 16.2 6.0% 32.1 
175g/km ( 2014 ) 140g/km 100% 50% basec ase 14.7 5.5% 29.6 
175g/km ( 2015 ) 160g/km 100% 50% basec ase 11.5 4.3% 21.7 
175g/km ( 2015 ) 150g/km 100% 50% basec ase 12.6 4.7% 25.4 
175g/km ( 2015 ) 140g/km 100% 50% basecase 13.8 5.1% 29.1 
175g/km ( 2015 ) 135g/km 100% 50% basecase 14.3 5.3% 31.0 
175g/km ( 2015 ) 125g/km 100% 50% basec ase 15.4 5.8% 34.8 
175g/km ( 2013 ) 135g/km 100% no basecase 16.5 6.1% 32.2 
175g/km ( 2014)  140g/km 100% no basecas e 15.0 5.6% 29.8 
175g/km ( 2015 ) 160g/km 100% no basecas e 11.8 4.4% 21.8 
175g/km ( 2015 ) 150g/km 100% no basecas e 12.9 4.8% 25.5 
175g/km ( 2015 ) 140g/km 100% no basecase 14.1 5.2% 29.3 
175g/km ( 2015 ) 135g/km 100% no basecase 14.6 5.4% 31.1 
175g/km ( 2015 ) 125g/km 100% no basecas e 15.7 5.9% 34.9 
Note: Shaded scenarios are estimated us ing linear interpolation/extrapolation 
EN 81   EN Table 16 Well-to-wheel cumulative  GHG reductions in the period from 2010 to 2020 and 
2010 to 2030 for options 1,2 and long-term targets  (Source: TREMOVE) 
scenario GHG 
abatement [Mt 
CO 2 eq.] GHG 
abatement [Mt 
CO 2 eq.] 
short-term target 
and start date 2020 
target slope cap fuel price44 
2010 >> 2020 2010 >> 2030 
60% no basecase 73 221 
100% no basecase 77 231 
60% 50% basecase 67 199 175 g/km ( 2012 ) n/a 
100% 50% basecase 67 199 
175 g/km ( 2015 ) n/a 60% no basecase 60 201 
60% no half 75 228 
100% no half 78 238 
60% no double 71 209 175 g/km ( 2012 ) n/a 
100% no double 74 219 
175g/km ( 2013 ) 135g/km  100% 50% basecase 81.6 342 
175g/km ( 2014 ) 140g/km 100% 50% basecase 71.7 311 
175g/km ( 2015 ) 160g/km 100% 50% basecase 59.1 237 
175g/km ( 2015 ) 150g/km 100% 50% basecase 61.7 267 
175g/km ( 2015 ) 140g/km 100% 50% basecase 64.3 297 
175g/km ( 2015 ) 135g/km 100% 50% basecase 65.6 312 
175g/km ( 2015 ) 125g/km 100% 50% basecase 68.2 342 
175g/km ( 2013 ) 135g/km 100% no basecase 84.1 347 
175g/km ( 2014)  140g/km 100% no basecase 74.1 316 
175g/km ( 2015 ) 160g/km 100% no basecase 61.4 241 
175g/km ( 2015 ) 150g/km 100% no basecase 64.0 271 
175g/km ( 2015 ) 140g/km 100% no basecase 66.6 302 
175g/km ( 2015 ) 135g/km 100% no basecase 67.9 317 
175g/km ( 2015 ) 125g/km 100% no basecase 70.5 347 
Note: Shaded scenarios are estimated us ing linear interpolation/extrapolation 
Table 17 Cumulative GHG abatement costs in  2010 to 2020 and 2010 to 2030 for options 
1, 2 and long-term targets  (Source: TREMOVE) 
scenario GHG abatement costs 
€/tCO 2 in €2000 
short-term 
target and start 
date 2020 
target slope cap fuel 
price44 
2010 >> 2020 2010 >> 2030 
60% no basecase -13.5 -9.3 
175 g/km( 2012 ) n/a 100% no basecase -10.2 -5.4 
EN 82   EN 60% 50% basecase -20.2 -17.2 
100% 50% basecase -23.2 -19.9 
175 g/km( 2015 ) n/a 60% no basecase -13.5 -9.8 
60% no half 13.9 24.2 
100% no half 17.0 27.8 
60% no double -68.1 -78.1 175 g/km( 2012 ) n/a 
100% no double -64.4 -73.2 
175g/km ( 2013 ) 135g/km  100% 50% basecase -33.4 -23.9 
175g/km ( 2014 ) 140g/km 100% 50% basec ase -34.7 -25.5 
175g/km ( 2015 ) 160g/km 100% 50% basec ase -38.9 -34.9 
175g/km ( 2015 ) 150g/km 100% 50% basec ase -36.9 -29.6 
175g/km ( 2015 ) 140g/km 100% 50% basecase -35.1 -25.4 
175g/km ( 2015 ) 135g/km 100% 50% basecase -34.2 -23.7 
175g/km ( 2015 ) 125g/km 100% 50% basec ase -32.6 -20.6 
175g/km ( 2013 ) 135g/km 100% no basecase -31.3 -22.4 
175g/km ( 2014)  140g/km 100% no basecase -32.4 -24.4 
175g/km ( 2015 ) 160g/km 100% no basecase -36.3 -34.2 
175g/km ( 2015 ) 150g/km 100% no basecase -34.4 -28.9 
175g/km ( 2015 ) 140g/km 100% no basecase -32.7 -24.6 
175g/km ( 2015 ) 135g/km 100% no basecase -31.9 -22.8 
175g/km ( 2015 ) 125g/km 100% no basecase -30.4 -19.6 
Note: Shaded scenarios are estimated us ing linear interpolation/extrapolation. 
EN 83   EN Table 18 Reduction of emission s of other pollutants for modelled scenarios  (Source 
TREMOVE) 
scenario well-to-wheel changes from the baseline scenario 
in year  2020  
short-term 
target and 
start date 2020 
target slope cap fuel 
price44 
PM SO 2 VOC  NO X TOFP 
175g ( 2014 ) 140g/k
m 100
% 50% basecase -0.63% -1.13% -0.47% -0.36% -0.35% 
175g ( 2015 ) 150g/k
m  100
% 50% basecase -0.54% -0.97% -0.41% -0.31% -0.30% 
175g ( 2015 ) 125g/k
m  100
% 50% basecase -0.66% -1.19% -0.50% -0.38% -0.37% 
175g ( 2014)  140g/k
m 100
% no basecase -0.65% -1.16% -0.49% -0.37% -0.36% 
175g ( 2015 ) 150g/k
m 100
% no basecase -0.56% -1.00% -0.42% -0.31% -0.31% 
175g ( 2015 ) 125g/k
m 100
% no basecase -0.68% -1.22% -0.51% -0.38% -0.37% 
 
scenario well-to-wheel changes from the baseline scenario 
in year 2030  
short-term 
target and 
start date 2020 
target slope cap fuel 
price44 
PM SO 2 VOC  NO X TOFP 
175g ( 2014 ) 140g/k
m 100
% 50% basecase -1.33% -2.07% -1.16% -0.82% -0.83% 
175g ( 2015 ) 150g/k
m  100
% 50% basecase -1.13% -1.78% -0.99% -0.70% -0.70% 
175g ( 2015 ) 125g/k
m  100
% 50% basecase -1.57% -2.43% -1.38% -0.97% -0.98% 
175g ( 2014)  140g/k
m 100
% no basecase -1.34% -2.09% -1.17% -0.82% -0.83% 
175g ( 2015 ) 150g/k
m 100
% no basecase -1.14% -1.80% -1.00% -0.70% -0.71% 
175g ( 2015 ) 125g/k
m 100
% no basecase -1.57% -2.44% -1.38% -0.97% -0.99% 
 
Figure 23  Influence of the excess emis sions premium on the average CO 2 from LCVs 
(Source: technical compliance costs from suppo rting study; own calculations assuming that 
emission improvement stops when the marginal abatement cost is equal to the premium) 
EN 84   EN Influence of the excess emissions premium 
on the average CO2 level
175g/km, mass, AMI=0
175176177
80 90 100 110 120 130 140 150 160
Excess emissions premium [€/(g/km)]Fleet CO2 average [g./km]