EN    EN EN 
D5 95728 
Executive Summary  
 
EN    EN  EUROPEAN COMMISSION 
Brussels, 13.1.2011 
SEC(2011) 44 final 
  
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the  
Proposal for a 
DIRECTIVE OF THE EUROPEAN PA RLIAMENT AND OF THE COUNCIL 
amending Directive 2000/25/EC as regards the application of emi ssion stages to narrow-track 
tractors 
EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 
SEC(2011) 43 final 
COM(2011) 1 final 
 
 
EN    EN Disclaimer:  This executive summary commits only the Commission's services involved in its 
preparation and does not prejudge the final fo rm of any decision to be taken by the 
Commission. 
 
EN 3   EN 1. PROBLEM DEFINITION  
The problem to be assessed is the feasibility of meeting the currently enacted legislative 
pollutant emission requirements for the so-calle d narrow-track tractors (NTTs). With annual 
sales of around 26.000 units, they re present 16% of the EU market for new tractors. They are 
specially designed to meet the specific terrain  and layout characteris tics of vineyards and 
orchards in Europe, such as narrow vineyard ro ws. As a consequence, NTTs are almost solely 
produced and used in Europe. The problem is tw o-fold: the adequacy of the regulatory limits 
and the lack of technol ogical feasibility.  
When the new emission limits for tractors were introduced by the legislator in 2005, there was 
a limited amount of information av ailable on the technology needed  to meet thos e standards. 
In addition to the currently applicable Stage II IA, also Stage IIIB and Stage IV were defined, 
requiring strong reductions in the emissions of  particulate matter (PM) and nitrogen-oxides 
(NO x). The implementation dates currently define d concerning the placing on the market of 
NTTs for the relevant engine categories (covering 75%  of the market of new NTTs) are as 
follows: 
Engine power Implementation date 
(Stage IIIB) Implementation date 
(Stage IV) 
56-75 kW 1 January 2012 1 October 2014 
37-56 kW 1 January 2013 - 
The potential existence of diff iculties for NTTs was acknowledged in the Tractor Emissions 
Directive 2000/25/EC and article 4 (8) was introduced requiring a further study of the 
feasibility of the foreseen emission limits for NTTs. Over time, it was confirmed that NTTs would have serious difficulties meeting the next  stages of emission requirements. This is 
because contrary to normal/larger tractors, NTTs have only a limited space available for the 
fitment of the required new engine and pollutant  after-treatment technologies. An increase in 
the vehicle size would compromise the essential user requirements, caused by a loss in manoeuvrability, loss in cu ltivable grounds and a general diffi culty to operate in the current 
environment for which they are designed.  
The emission requirements of Stage IIIB and IV  would not be problematic if satisfactory 
technological solutions for N TTs were available in the appropriate timeframe. However, 
current market information shows that development of engine and after-treatment technologies to meet Stage IIIB has only recentl y delivered the first prototype solutions. For 
Stage IV, R&D on engine concepts is sti ll ongoing. Further, additional efforts will be 
necessary to adapt these technologies for app lication in NTTs and integrate them in the 
limited available space. This process for Stage IIIB, according to standard industrial lead 
times, is expected to take between 3 and 6 years.  For Stage IV, if a feasible technical concept 
can be demonstrated, the development of comp liant NTTs may still require between 6 and 10 
years. 
The most affected parties are engine and tr actor manufacturers, their workforce and the 
agricultural sector. First, new engines must be developed by engine manufacturers that can 
 
EN 4   EN meet the new limits and are suitable for use in NTTs. Secondly ther e is the technological 
challenge for NTT manufacturers to install the next generation of engines in their specific 
products and to maintain their ability to operate  in narrow vineyard rows. The agricultural 
sector would be affected by the absence of ne w NTTs that would be compatible with the 
current row-width of vineyards and orchards an d with their existing equipment/tools used for 
cultivation. The employees of these tractor manufacturers would be affected by possible 
factory downtimes due to the inability to meet the demand for new products. 
This impact assessment sets out polic y options to address this problem.  
2. ANALYSIS OF SUBSIDIARITY  
The Tractors Emissions Directive harmonises the laws of Member States relating to emission 
limits and the type-approval procedure for e ngines to be installed in tractors. Any 
modifications to the Directive can only be done at EU level.  There is, however, a risk that if 
no action is taken, Member States  might resort to national meas ures to address the problem 
that would lead to a fragmentation of the inte rnal market and unlevel  playing field between 
different Member States. Therefore EU action is justified and provides added value in 
maintaining the internal market for tractors. 
3. OBJECTIVES  
The policy objectives are related to competitiveness and environmental issues. The general 
objectives are to safegu ard the competitiveness and viabi lity of the tractor industry while 
maintaining a high level of environmental prot ection with reduced pollutant emissions from 
tractors when addressing  the identified problem. 
Faced with the impossibility of putting on the market compliant products as of 2012, NTT 
manufacturers are likely to suffer a large loss of  revenue. This would represent a serious risk 
for the R&D investments needed to develop the technical solutions required to re-enter the 
market. This risk may jeopardise the existence of many of these specialised companies, which are generally industrial compan ies of a limited size and capital , including several SMEs.  
In terms of environmental protection, the renewa l of the tractor fleet is key to delivering 
reductions of PM and NOx emissions. If new N TTs are not offered on the market, due to the 
technical difficulty in meeting regulatory requ irements, users are expected to adapt by 
extending the use of the old NTTs and more  polluting beyond their normal lifetime. In 
addition, an incentive to industry is required to continue the de velopment of cleaner NTTs and 
deliver in the medium to long term the nece ssary reductions. The emissions of the current 
NTT fleet represent 0.2 and 0.5% of the to tal emissions in the EU of PM and NOx 
respectively. 
4. P
OLICY OPTIONS  
Six policy options have been identified as pos sible means of meeting the policy objectives. 
These are: 
 
EN 5   EN • Option 1- No new action = Baseline scenario.  
The current implementation dates for NTTs  to achieve compliance with the new 
Stage IIIB and Stage IV limits remain unc hanged, meaning that Stage IIIB would be 
required for new NTTs starting from 1 Ja nuary 2012 and Stage IV from 1 October 
2014.  
• Option 2 – Allowing 3 extra years for implementation of Stages IIIB and IV for NTTs. 
The implementation dates for NTTs for mee ting Stage IIIB and Stage IV emission 
requirements would be delayed by 3 years.  Stage IIIB would be required for new 
NTTs starting from 1 January 2015 and Stage IV from 1 October 2017. 
• Option 3 – Allowing 5 extra years for implementation of Stages IIIB and IV for NTTs. 
The implementation dates for NTTs for mee ting Stage IIIB and Stage IV emission 
requirements would be delayed by 5 years.  Stage IIIB would be required for new 
NTTs starting from 1 January 2017 and Stage IV from 1 October 2019. 
• Option 4 – Exempting from Stages IIIB and IV for NTTs.  
Given the specific design constraints of  NTTs and their limited market share 
compared to the entire tractor market, an additional option could be to completely 
exempt NTTs from Stages IIIB and IV requirements. This would maintain the 
current Stage IIIA requirements for these special tractors for an unlimited period of 
time.  
• Option 5 – Skipping Stage IIIB and introducing Stage IV at the dates originally foreseen 
This option foresees skipping Stage IIIB a nd introducing Stage IV emission limits at 
the dates originally foreseen in the tractors emissions legislation i.e. as of 1 October 2014. 
• Option 6 – Extending the flexibility provisions for NTTs  
This option foresees a further extension of  the flexibility provisions in the Tractor 
Emissions Directive for NTTs, so as to a llow the manufacturers of NTTs to sell an 
additional number of non-compliant tr actors without changing the emission 
requirements as such. 
Option 5 has been discarded at an early stage because vehicle design co mplying with Stage IV 
will take much longer than the time availabl e until the mandatory introduction of the limits 
foreseen by the legislation. Strong negative imp acts (impossibility to sell compliant NTTs, 
loss of revenues, continued use of old tractors) can be expect ed as of 2014, probably in an 
even larger extent than under Option 1. Moreover, it would mean a waste of resources for the 
companies that have invested in technical solutions for Stage IIIB.  
Also Option 6 has been discarded. The flexibil ity provisions for tractor s allow manufacturers 
to continue sales of non-compliant tractor s beyond the date of im plementation of new 
emissions stages. Current provisions give a relie f for a period of only a few months. In order 
 
EN 6   EN to bring these provisions more in line with  the leadtime needed for developing compliant 
NTTs, one could imagine a further extension of the flexibility provisions for NTTs. In that case, the flexibility provisions would need to  be around 300%. In practice, such an option 
would represent a delay of 3 year s in the application of the new emissions stages, very similar 
to Option 2. However, the administrative burde n for manufacturers an d administrations to 
implement the flexibility scheme would be significantly higher.  
5. A
SSESSMENT OF IMPACTS  
As this Impact Assessment concerns a 'narrow'  legislative action, it will assess the options 
essentially in a qualitative way with quantificati ons for those impacts for which sufficient data 
was available. The analysis is based on the data available from different sources, including the 
supporting studies by JRC and Arcadis and the i ndustry itself (in partic ular engine, after-
treatment and tractor manufact urers), who delivered information on R&D results and the 
state-of-the-art technology related to the introduction of  the new stages for NTTs. 
• Option 1- No new action = Baseline scenario.  
This policy option represents a serious risk of disrupting the NTT industry and 
market, as industry would not have compliant  tractors ready in time for Stage IIIB or 
for Stage IV. Users will not be able to re place old polluting tractors with modern 
equipment and are likely to continue to use old tractors with high pollution and 
deteriorated worker safety. Some compliant  tractors (in the lower engine category) 
may come some years later to the market, but the prolonged loss of revenue from 
NTT could lead several manufacturers to cl ose business, resulting in a significant 
proportion of jobs lost, which is estimated to amount to 3000 over a period of three years. Further, due to the lack of replacem ent of the existing fleet, it can be estimated 
that around 80.000 workers using NTTs will be exposed to higher safety risks, at 
least for a period of 3 coming years. In fact recent legislation improved safety 
requirements for new tractors, particularly against rollover accidents, and renewal of 
the fleet is essential to improve worker safety.  
The overall emissions of PM and NOx under this option are highe r than originally 
expected from the new emission limits. This is due to the continued use of old tractors, caused by the inavailabi lity of compliant new NTTs.  
Stakeholders (mainly from i ndustry) have for many years criticised this option and 
warned against its negative consequences. 
• Option 2 – Allow 3 extra years for implementation of Stages IIIB and IV for NTTs. 
This policy option, by allowing NTTs three extra years to comp ly, would be very 
effective in mitigating the economic imp acts on the industry to challenging but 
feasible proportions, without serious soci al drawbacks. Industry would remain under 
continuous pressure to find technical solu tions to meet the new emission limits 
introduced by the Directive, so innovation is fostered. It is estimated that manufacturers would have to increase their R&D spending fr om 3% to more than 6% 
of turnover over the coming 4 years in orde r to meet Stage IIIB as of 2015. Total 
R&D investment from NTT ma nufacturers is expected to be around €50m. Worker 
 
EN 7   EN safety will improve as expected, due to the replacement of older NTTs with new, 
safer ones.  
Compared to the baseline scenario (option 1) the environmental impacts are positive. 
This is due to the fact that, while Stag e IIIB NTTs are not available, new NTTs 
complying with Stage IIIA will be able to enter the market and reduce pollutant 
emissions, through the replacement of old and polluting NTTs. The overall 
environmental benefits of this option ar e estimated at €122m (lower PM emissions 
are monetized at €31m, NOx emissions at €91m).  
Some industrial companies have indicated th at this might be feasible, while others 
think it is not. 
• Option 3 – Allow 5 extra years for implementation of Stages IIIB and IV for NTTs. 
This option, allowing NTTs five extra year s to comply, would be  very effective in 
avoiding job losses in the sector. Industry would still remain under pressure to find 
technical solutions to meet the Directive, although all re levant industrial actors 
should have sufficient time to develop tec hnical solutions for NTTs. The credibility 
of legislation may, however, be somewhat questionable, if it is perceived that the 
industry did not try to meet the limits in time. This option corresponds to the current 
requests from NTT manufacturers. Worker sa fety will improve as expected, due to 
the replacement of older NTTs with new, safer ones.  
Again, there will be an improvement for th e environment compared to the baseline 
scenario due to the replacement of old N TTs by cleaner ones, complying with Stage 
IIIA. The overall environmental benefits of this option are estimated at €74m (lower 
PM emissions are monetized at €12m, NOx emissions at 62 M€). These values are somewhat lower than those for option 2, as Stage IIIB will be applicable 2 years later.  
This option corresponds to the current  requests from NTT manufacturers.  
• Option 4 – Exemption from Stages IIIB and IV for NTTs.  
A permanent exemption does effectively mitigate the negative economic impacts for 
industry but does not give any certainty that pollutant em issions are reduced in the 
long term, as it is far from certain that NTTs meeting Stage IIIB or IV would be 
developed. As other sources of PM and NOx are expected  to reduce their emissions 
over time, the relative share of NTTs in t hose emissions will therefore increase. The 
overall environmental costs of this op tion are estimated at €674m (higher PM 
emissions are monetized at €313m, NOx emissions at €361m). In the short term, however, it would be positive for the envir onment as at least new Stage IIIA tractors 
would be available to replace  older, more polluting ones.  An exemption would also 
largely remove any incentive to invest in R&D and innovation in environmental 
technologies for NTTs. Again, worker safety  will improve as expected, due to the 
replacement of older NTTs with new, safer ones.  
There would be no risk that companies ar e pushed out of business due to emissions 
requirements, as they would effectively st ay as they are today. However, a small 
 
EN 8   EN number of jobs related to R&D in the tractor manufacturer and exhaust after-
treatment supplier sector may be lost. 
Initially, this was the solution requested by (industrial) stakeholders. More recently, 
they requested a 5-year delay. 
6. COMPARISON OF OPTIONS  
As a result of the above analysis, it is conc luded that postponing the implementation dates for 
NTT with 3 years (Option 2) is the most a ppropriate measure to ensure that the policy 
objectives of ensuring a competitive industry and a better protecting the environment are met. 
As summarised in the table below, this opti on delivers the most favourable overall impacts 
with regard to the economic, envi ronmental and social implications. 
 Option 1 - 
Baseline Option 2 – 3 year 
delay Option 3 – 5 year 
delay Option 4 - 
exemption 
Direct economic impact 
(on industry) 0 
No NTTs sold until 
technical solution is 
found, loss of revenue, 
serious risk of 
bankruptcies + 
Most actors can stay in 
business, sales 
continue, sunk 
investments not lost  + 
All actors can stay in 
business and sales 
continue, sunk 
investment not lost  + 
No need to invest 
more, sales continue, 
loss of sunk 
investments  
Indirect economic 
impact (on consumers) 0  
Cannot renew tools, 
higher maintenance 
costs + 
Additional equipment 
cost of 117 M€ initially 
per year + 
Additional equipment 
cost of +/- 100M€ 
initially per year  ++ 
No particular cost 
increases  
Impact on R&D 0 
Wild race among some 
to innovate, without 
revenue to finance it  ++ 
R&D investment 
continued, allowing 
most to participate  + 
Early R&D investment 
not rewarded, allowing 
all to participate  -- 
No incentive to 
innovate  
PM emissions1 0 
Use of old, polluting 
tractors is prolonged  ++ 
Fleet renewal 
continued, reduction of 
2.2 kt, €31m benefit  + 
Fleet renewal 
continued, reduction of 
0.8 kt, €12m benefit  -- 
Long-term higher 
emissions of 22.7 kt, 
€313m cost  
NOx emissions 0 
Use of old, polluting 
tractors is prolonged  ++ 
Fleet renewal 
continued, reduction of 
42 kt, €91m benefit  + 
Fleet renewal 
continued, reduction of 
29 kt, €62m benefit  -- 
Long-term higher 
emissions of 168 kt, 
€361m cost  
Impact on employment 0 + + + 
                                                 
1 The estimated pollutant emissions and monetized impacts are re lative to the baseline scenario. The emissions correspond to the 
timeframe until 2050, the monetized environm ental impacts to the 2012-2030 timeframe.  
 
EN 9   EN Serious risk for job 
losses, up to 3000 over 
3 years Job losses limited, not 
structural, some 
additional jobs at 
suppliers  Job losses further 
limited, not structural, 
some additional jobs at 
suppliers  No risk of significant 
job losses, no 
additional jobs at 
suppliers  
Impact on worker safety0 
Unsafe tractors are 
used longer, ca. 80.000 
workers exposed  + 
Improvement of safety 
through fleet renewal+ 
Improvement of safety 
through fleet renewal  + 
Improvement of safety 
through fleet renewal
The 3-year delay would allow most of the manu facturers to transform the recent technological 
progress into NTTs complying with Stage IIIB limits and simultaneously meeting the essential customer requirements for their use in  vineyards and orchards . Thereby, significant 
job losses of Option 1 are avoided and the envi ronmental and worker safety impacts continue 
to be positive due to the con tinued renewal of the EU fleet. Compared to Option 3, the delay 
would be in line with the necessary technol ogical development and continue to foster 
innovation. With a limited delay, the environmenta l benefits that were  expected from the 
original legislation will theref ore be realised, unlike Option 4. 
7. M
ONITORING AND EVALUATION  
It will be important to monitor over time the t echnical advancement in the industry, in order to 
track progress towards the transition towards St age IIIB and Stage IV limits. Key indicators 
are the level of R&D investment in the sector, the level of sale s and profitability of firms (in 
particular, SMEs) active in the sector and the number of NTTs which are successfully type-
approved to the Stage IIIB a nd IV limit values over time. Also the monitoring of NOx and 
PM emissions attributed to NTT will be relevant.  
Accordingly, constant dialogue with the indus try, aimed at tracking of R&D investment by 
large and small firms in the sector and monitoring the competitiveness of the sector and its ability to develop suitable technol ogical solutions within  the next few years, will be of utmost 
importance. In view of the future implementatio n of the rules at hand, it will be essential to 
monitor the NTT market and the development of technologies, including the appearance of 
potential solutions for the transition to Stage IV. One suitable way of achieving this constant 
dialogue is to rely on the Working Gr oup for Agricultural Tractors (WGAT).