Opinion of the Economic and Social Committee on the "Proposal for a Directive of the European Parliament and of the Council amending Council Directives 70/156/EEC and 80/1268/EEC as regards the measurement of carbon dioxide emissions and fuel consumption of N1 vehicles"

(COM(2001) 543 final - 2001/0255 (COD))

(2002/C 125/02)

On 27 November 2001 the Council decided, under Article 95 of the Treaty establishing the European Community, to consult the European Economic and Social Committee on the above-mentioned proposal.

The Section for the Internal Market, Production and Consumption, which was responsible for drawing up the Committee's opinion on the subject, adopted its opinion on 1 March 2002. The rapporteur was Mr Colombo.

At its 389th Plenary Session (meeting of 20 March 2002) the European Economic and Social Committee adopted the following opinion by 55 votes to 0, with 5 abstentions.

1. Aim of the proposal

1.1. The aim of the proposal in question is to extend the harmonised standards on CO2 emissions and fuel consumption already laid down for M1 class vehicles (cars) by Directive 1999/100/EEC amending the original Directives 70/156/EEC and 80/1268/EEC to cover also N1 vehicles (light commercial vehicles).

1.2. It is clear that the main objective of the proposal is that of preparing specific measures designed to reduce CO2 emissions and fuel consumption to protect the environment where transport is concerned.

2. Scope of the proposal

2.1. The present proposal covers light commercial vehicles (N1 vehicles) having a maximum mass not exceeding 3,5 tonnes: this definition includes a wide range of vehicles (e.g. smaller car-derived transport vehicles, sport utility vehicles and multi-purpose vehicles, pick-ups and larger vans). Each base model usually has a relatively large number of different versions.

2.2. The size of this market segment is considerable: in the year 2000, about 1,8 million of such vehicles were sold in the EU, as compared with about 14 million passenger cars. Light commercial vehicles account for about 10 % of total road transport CO2 emissions. The synoptic table below, drawn up by the Commission, gives a clear picture of the situation.

- total EU CO2 emissions (1995): 3227 Mton CO2 eq;

- total EU CO2 emissions road transport sector (1995): 655,7 Mton CO2 eq (= 20 % of total CO2 emissions);

- EU CO2 emissions other sectors (1995)

other transport sources: 195,7 Mton CO2 eq

combustion (energy sector): 1041 Mton CO2 eq

combustion (non industrial): 654,9 Mton CO2 eq;

- CO2 emissions of N1 vehicles are estimated at approximately 10 % of total road transport CO2 emissions (+- 65 Mton CO2 eq);

- the division of the fleet between class 1, 2, and 3 is estimated at approximately:

- class 1: 25 %

- class 2: 50 %

- class 3: 25 %;

- CO2 emissions for the different classes are probably in the same order of magnitude with somewhat higher value for class 3 (higher fuel consumption, higher mileage);

- the total number of different versions for class 2 and 3 is estimated at 3000 different versions. However, this does not mean 3000 type approvals would be required, as there is a significant degree of flexibility to the manufacturers to group different versions into one type approval;

- the exemption for small volume manufacturers is really to ensure that type approval cost would not be excessive with respect to the number of vehicles to which the approval applies. The CO2 contribution of these vehicles is negligible.

2.3. This figure is likely to rise since a gradual increase has been noted in this market share. No Community initiative has been taken on this so far in order to monitor and then improve fuel economy and CO2 emissions for this category of vehicles.

3. General comments

3.1. The Committee supports planned Commission initiatives to introduce measures to reduce CO2 emissions and optimise fuel consumption: these initiatives are important for achieving the Community's ambitious environmental protection plans in the transport sector.

3.2. Achieving the CO2 reduction objectives laid down at Kyoto must be regarded as a priority strategic aim with a view to "lasting and sustainable development". It seems fundamental that the transport sector should play a part in achieving these objectives, and the Committee has supported this argument in earlier opinions.

3.3. However, in the Committee's view, while the Commission proposal is a step in the right direction it does raise some doubts: it may fail to achieve the desired results because of the additional costs arising from either duplication of the planned tests or the funds needed for the new tests. These factors will inevitably have an impact on the product's final price. These costs double whenever production takes place in different establishments and countries. An initial examination of the costs confirms this assessment and has led the Commission to provide for firms which produce fewer than 2000 units per year to be exempted from this testing method.

3.4. There is in fact a lack of differentiation as to the composition of the N1 category which Directive 98/69/EEC divides into three sub-categories on the basis of the reference mass (tare): the first sub-category up to 1305 kg, the second from 1305 kg to 1760 kg and the third above 1760 kg.

3.5. As regards the criterion for measuring the vehicles, which is done solely unloaded, the Committee takes note of the Commission's comments on the difficulties involved in increasing the tests and therefore the costs. However, it stresses the fact - and calls upon the Commission to take account of it - that consumption clearly varies with the rated load and type of fittings of the vehicle.

3.6. The Committee also wishes to point out the lack of a reference to a cost-benefit analysis, which would seem to be necessary for a more careful assessment of the results which can be achieved under this proposal. For the two sub-categories II and III in particular, the cost of funding the necessary infrastructure and manpower does not seem to be commensurate with the expected results.

4. Specific comments

4.1. Using the breakdown of category N1 given in detail in point 3.4 above, the Committee believes that for the first sub-category there are no special problems, since such vehicles are derived directly from cars, and it is well-known that they are already subject to roller bench tests. This means in effect that there are no problems of implementation.

4.2. The situation is different with regard to the second sub-category, and more particularly the third sub-category: both involve considerable problems of implementation.

4.3. These vehicles are produced in factories which build heavy vehicles, the motors of which are subject to different tests (Directive 88/77/EEC and subsequent amendments). Extending the rules now covering cars, as envisaged in the present proposal, would therefore lead to a system with two types of test.

4.4. The proposed directive provides for the exclusion of the pay-load from the test methodology, although the Explanatory Memorandum of the same proposal states in point E.2 that "the pay-load has a significant impact on the actual fuel consumption and CO2 emissions." This exclusion seems to arise from the existence of a large number of different versions, which would "result in a substantial amount of additional testing and associated costs" (see point 3.4 above).

4.5. It also provides for exemption of small manufacturers (see point 3.3). It is understandable and proper for the Commission to concern itself with the effects on SMEs. However, it is necessary to avoid this exemption being used to reduce the effectiveness of the standard laid down in the proposed directive.

4.6. The ESC favours this solution, which forms part of the broader approach of support for small and medium European enterprises, and suggests that for those who produce only slightly more than 2000 units per year the public bodies responsible for type-approval checks could make available the technical type-approval equipment (dynamometer bench) at a reasonable cost.

5. Conclusions

5.1. For the reasons set out above, the Committee, while endorsing the application of this provision to the first sub-category, would ask the Commission to provide further justification for the application of the draft directive's provisions to vehicles in the second and third sub-categories; it seems more realistic for such vehicles to be excluded from its scope. It would also seem desirable to extend the deadlines for new type-approvals as well from 1 July 2003 to 1 October 2005. That would enable the present draft directive to come into force at the same time as the more restrictive emission standards known as EURO 4.

Brussels, 20 March 2002.

The President

of the Economic and Social Committee

Göke Frerichs