Opinion of the Economic and Social Committee on the "Proposal for a Directive of the European Parliament and of the Council amending Directive 97/24/EC of the European Parliament and of the Council on certain components and characteristics of two or three-wheel motor vehicles"

(2001/C 123/03)

On 20 July 2000 the Council decided to consult the Economic and Social Committee, under Article 95 of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for the Single Market, Production and Consumption, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 8 December 2000. The rapporteur was Mr Barros Vale.

At its 378nd plenary session of 24 and 25 January 2001 (meeting of 25 January), the Economic and Social Committee adopted the following opinion by 48 votes to 15 with four abstentions.

1. Introduction

1.1. The present opinion concerns a proposal to amend the Directive on certain components and characteristics of two or three-wheel motor vehicles.

1.2. The Commission's proposal is prompted by Article 5 of Directive 97/24/EC, which obliges the Commission to put forward proposals for a new motorcycle emission limit within two years of the adoption of the Directive, on the basis of research into the emission reduction potential of technology and an assessment of the costs and benefits of applying stricter limit values.

1.3. The proposal's primary aim is to improve air quality by defining maximum limit values for gaseous emissions from this type of vehicle.

1.4. This aim will be achieved by incorporating technology such as the oxidation catalyst (with or without secondary air injection), the closed loop three-way catalyst and direct petrol injection systems.

2. General comments

2.1. The Commission admits that electronic fuel injection and engine management systems have only just begun to find their way into the market. While these technologies are already feasible in four-stroke engines, the situation of two-stroke engines is quite different; various two-stroke engine manufacturers are currently developing this technology or already have a model on the market. The Committee considers that the mandatory introduction of new "green" technologies must be conditional on their effective dissemination on the market and on producers having generalised access to them. The Committee hopes that such access can be achieved as swiftly as possible.

2.2. Two and three-wheeled vehicles are manufactured in small series and this, together with the vehicles' prices, is the reason why manufacturers' ability to write off R& D investment differs appreciably. Also, costs are higher for changes that have to be made in a short space of time due to a particular legislative measure entering into force, than for a change that can be incorporated into a model change that is already planned.

2.3. After listing the technological solutions that could be applied and the different results in two- and four-stroke engine emissions respectively, the Commission concludes that the proposed technological solutions for the first stage create the opportunity to establish one set of limit values applicable for all motorcycles, irrespective of the type of engine.

3. Specific comments

3.1. Because of the time-lag between (state of the art) technologies becoming known and the industrial feasibility and dissemination of the technological solutions mentioned for two- and four-stroke engines, precautions should be introduced concerning the dates when the proposed emission values become mandatory, in particular for the application of those technological solutions that still do not have industrially viable versions.

3.2. This concern stems primarily from the fact that while some attempts have previously been made to apply these technologies (e.g. direct injection) in small high-revolution engines, the products needed were not available on the specialised components market. This was due to technical difficulties and to the fact that, in quantitative terms, such products were of little interest to component specialists, given the high development costs but relatively small potential market.

3.3. Consideration must be given to the differing impact on the final cost of categories of vehicle equipped with two- or four-stroke engines, as this affects the competitiveness of prices on the market.

3.4. It would seem necessary to introduce mechanisms for correcting or amending the target values or dates in order to cater for cases where industrially viable versions cannot be found.

3.5. The issue of introducing fiscal incentives also needs to be clarified in order to protect the principle of competition, both between States and between different types of vehicle and companies in the sector. In particular, the Committee stresses that small and medium-sized manufacturers would have difficulty in meeting the optional limit values mentioned in Article 3(1)(b), as they do not have sufficient resources for R& D. These manufacturers may also face added difficulties on the market, as they do not have access to tax incentives, unlike their larger competitors with greater technical and/or financial capacity.

4. Final considerations

4.1. While the principle of environmental concern that underpins the proposal is welcomed, account must be taken of the likely technical and industrial difficulties. This is vital if the Directive is not to become unworkable for certain types of vehicle or if certain sectors with a long tradition in this type of vehicle (in particular, users of small two-stroke engines) are not to be excluded from the market from the outset.

4.2. The proposal must reflect the following:

4.2.1. In the case of technologies which are industrially feasible and available on the components market, and which are accessible to all engine and vehicle manufacturers (e.g. oxidation catalysts (OC) and closed loop three-way catalysts (TWC) for two-stroke and four-stroke engines, and secondary air injection (SAI) for four-stroke engines), the emission limits and deadlines mentioned in the proposal can be made binding.

4.2.2. The emission limits and deadlines which depend on technologies that are still in the R& D stage, and decisions which depend on tests whose details and reliability are not yet established, must be subject to an interim deadline to check their viability, as after 2003 they will be regulated in accordance with the state of the art at that time.

4.2.3. Here the Committee would draw the Commission's attention to the work being carried out by the UN-ECE Group on Pollution and Energy in Geneva on a new specific test cycle for motorcycles. It therefore does not seem advisable at present to establish optional limit values for the granting of tax incentives.

4.2.4. The Committee considers that the deadline mentioned in Article 2(3), regarding the validity of certificates of conformity which accompany new vehicles pursuant to Directive 92/61/EEC, should be changed to 1 January 2005.

4.2.5. The Committee also thinks that a one-year derogation should be provided regarding the application of the Directive to "trial" bikes, so that manufacturers can explore solutions for this specific type of vehicle and adjust to the new requirements.

Brussels, 25 January 2001.

The President

of the Economic and Social Committee

Göke Frerichs