EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 23/5/2008 
SEC(2008) 1909 
COMMISSION STAFF WORKING DOCUMENT 
 
Accompanying the  
Proposal for a 
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
concerning type-approval requirements for the general safety of motor vehicles 
  
Summary of the Impact Assessment  
{COM(2008) 316} 
{SEC(2008) 1908} 
 
EN 2   EN COMMISSION STAFF WORKING DOCUMENT 
 
Accompanying the  
Proposal for a 
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
concerning type-approval requirements for the general safety of motor vehicles 
  
EXECUTIVE SUMMARY 
In order to meet the European Union's safe ty and environmental objectives, there is a 
continual need to update the various regulatio ns that apply to new vehicle construction. 
However, there is an equal ne ed to limit the regulatory bur den on industry, and to simplify 
existing legislation wherever possible. Ne w technologies are now available which can 
dramatically improve vehicle safety (such as  vehicle stability control) or reduce CO
2 
emissions (such as low rolling-resistance tyres) a nd research has indicated that there would be 
significant benefits if such technologies we re introduced as standard on new cars, and 
possibly other vehicles as well.  
However, before considering amending or expa nding the current type-a pproval Directives to 
mandate, or at least set standards for, these ne w technologies, it is ne cessary to review the 
current system of safety-related type-appr oval Directives. In 2005 the CARS 21 report 
recommended the simplification of the current  regime, replacing many of the current 
Directives with equivalent  regulations developed by the United Nations Economic 
Commission for Europe (UNECE).  Further simplification could be achieved by replacing the 
current 50 base Directives (and 100 related amending Directives) with one Council and 
Parliament Regulation. An advantage of such an  approach would be that such a Regulation, 
and its subsequent amendments, would not n eed to be transposed by Member States. 
The proposal which is the subject of this imp act assessment will be to  simplify the current 
systems for vehicle safety but also introduce ne w requirements, where technically feasible and 
economically justifiable, to improve the sa fety and environmental performance of new 
vehicles. 
This Impact Assessment analyses possible chan ges to the current safety requirements under 
three themes; Simplification, Advanced Safety Systems  and Tyres . 
With regard to  simplification , the following options were considered: 
(a) Do nothing (maintain all existing safety –related Directives). 
(b) Do nothing as part of the current exerci se, but review each Directive as and 
when they are due to be modified, and decide whether replacement is 
appropriate. 
 
EN 3   EN (c) Replace all existing Directives through the proposed Regulation. 
Option (c) was considered most viable since it  represents the quickest way of simplifying the 
current regime and is in line with the CARS 21 recommendations.  
With regard to advanced safety systems , three types of syst ems were considered; electronic 
stability control, advanced emergency braking  and lane departure warning . For each of 
these systems, the following options were examined: 
Option a)  Do nothing and allow the mark et to take the initiative. 
Option b)  Establish technical standards for su ch systems (where fitted) and allow 
manufacturers to f it them optionally. 
Option c)  Establish technical standards a nd mandatory fitting requirements. 
In all cases, the analysis concluded that re lying on market forces alone was unlikely to 
achieve full fleet penetration, a nd that there was justification for mandatory action. However, 
in the cases of advanced emergency braking  and lane departure warning systems, the 
emphasis should be on mandatory installation on  heavy duty vehicles as a first stage. 
Regarding tyres, there are four areas, some of them inter-related, where action has been 
proposed. These concern tyre/road noise, rolling resistance, tyre pressure monitoring 
systems and tyre wet grip performance .  
With regard to  tyre noise the following options were considered: 
Option a)  Follow the recommendations of a report by the Federation of European Highway 
Research Laboratories (FEHRL ) and propose tyre noise limit reductions of around 4dB(A), 
with the actual values depending on which of  five width categories the tyre falls into. 
Option b)  Similar to Option a) but allowing a longer two-phase introduction. 
Option c)  Follow the recommendations of a report by TRL which proposes similar noise 
reductions to FEHRL but effectively reduces the number of width categories to two. This 
makes compliance with the requirements propor tionately more difficult for wider tyres.  
As the FEHRL report has indicated that a larg e proportion of existing ty res can already meet 
the proposed requirements of option a) there a ppears to be no justification in delaying the 
implementation (as proposed in option b)). Ther e may be some feasibil ity concerns over the 
ability of some tyres to meet the option c) re quirements, so option a) with minor adjustments 
following consultations with stakeholders, is  the preferred option. 
With regard to tyre rolling resistance , the following options were considered: 
Option a) Rely on a grading and labelling scheme to encourage the increased use of low 
rolling resistance tyres. For tyres supplied as  original equipment, rely on the vehicle 
manufacturers' incentive to produce cars with low fuel consumption, and to produce cars with 
a low CO 2 rating in order to meet future CO 2 emission targets. 
Option b) Introduce a grading and labelling scheme as in Option 1 but make at least the 
minimum standard mandatory for vehi cle and component type approval. 
 
EN 4   EN Option c) Same as Option b) but would also apply to after-market tyres.  
It was considered that Option c) should be c hosen since the benefits would apply to existing 
vehicles and would thus be realised over a shorter timescale. However, only the mandatory 
limit values would be included in the main Re gulation. Details of a grading and labelling 
scheme would be agreed at a later date.  
With Regard to Tyre Pressure Monitoring Systems , the following options were considered;  
Option a)  Do nothing and allow the mark et to take the initiative. 
Option b)  Establish technical standards for su ch systems (where fitted) and allow 
manufacturers to f it them optionally. 
Option c)  Establish technical standards a nd mandatory fitting requirements. 
It was considered that, in order to be effective in maintaining an optimum pressure to 
minimise fuel consumption and CO 2 emissions, a higher degree of accuracy was required than 
is available with current systems. In additi on, there was justificati on for mandatory fitment 
since reliance on market forces alone was unlikely to achieve full fleet penetration.  
With regard to tyre wet grip , it was considered th at voluntary options were not appropriate 
since wet grip was an important safety issue and the 'no action' option could lead to a reduction in wet grip standards due to the pre ssure on manufacturers to meet noise and rolling 
resistance requirements. Therefore compulsory wet grip approval was c onsidered as the best 
option. 
In general, the impact assessment shows that it is possible to improve the safety and 
environmental performance of new vehicles in a cost-effective manner, while simplifying the 
legislative framework covering vehicle safety.