EUROPEAN COMMISSION Brussels, 31.5.2017 SWD(2017) 188 final COMMISSION STAFF WORKING DOCUMENT



IMPACT ASSESSMENT

Impact Assessment Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the monitoring and reporting of CO2 emissions from and fuel consumption of new heavy-duty vehicles {COM(2017) 279 final}

{SWD(2017) 189 final}



TABLE OF CONTENTS Acronyms and definitions 1. Problem definition 1.1 Context 1.2 What is the problem? 1.3 Why is it a problem? What are the main drivers? 1.3.1 Where are we now in addressing the problem? 1.4 Who is affected by the problem, in what ways, and to what extent? Whose behaviour would have to change to improve the situation? 1.5 What is the EU dimension of the problem? 1.6 How would the problem evolve, all things being equal? 1.7 Has any fitness check/retrospective evaluation been carried out of the existing policy framework? 2. The right of the EU to act 2.1 Legal basis 2.2 Analysis of subsidiarity and added value of EU action 2.3 Proportionality check 3. Objectives 4. Options 4.1 Common elements of the options considered 4.1.1 Scope of monitoring and reporting

4.1.2 Statistical analysis 4.1.3 Role of the European Environment Agency (EEA) 4.1.4 Publication of Monitoring Data 4.2 Baseline option "No action at EU level" 4.3 Options assessed on how to monitor and report 4.3.1 Option 1: Reporting by national authorities 4.3.2 Option 2: Reporting by manufacturers 4.3.3 Option 3: Mixed reporting by national authorities and manufacturers 4.4 Discarded options 4.5 Are Small and Medium sized Enterprises targeted by the different options? 5. What are the impacts of the different policy options and who will be affected? 5.1 Economic impacts 5.1.1 General economic impacts 5.1.2 Cost of options (administrative burden for main stakeholders concerned) 5.2 Social impacts 5.3 Environmental impacts 5.3.1 CO2 emissions 5.3.2 Other emissions 5.4 Impact on competitiveness and innovation 5.5 Impacts on third countries and on EU international trade

5.6 Impact on SMEs 6. How do the options compare? 6.1 Effectiveness 6.2 Efficiency 6.3 Proportionality 6.4 Subsidiarity 6.5 Coherence with other mainstream EU policies 6.6 Stakeholders' views 6.7 Conclusions 7. How would actual impacts be monitored and evaluated? Annex 1 - Procedural information Annex 2 - Stakeholder consultation Annex 3 - Who is affected by the initiative and how Annex 4 - Development of a new simulation tool, VECTO, for the determination of CO2 emissions from Heavy-Duty Vehicles Annex 5 - Draft certification methodology for the determination of the co2 emissions from heavy-duty vehicles Annex 7 - HDV Sector Statistics Annex 8 - Monitoring of CO2 emissions from vans Annex 9 - International experiences with HDV fuel efficiency Annex 10 - Assessment of administrative costs of monitoring and reporting





Acronyms and definitions CO2 Carbon dioxide ETS Emissions Trading Scheme. The EU emissions trading scheme (carbon market on which allowances for tons of CO2 are being traded among participating entities) does not currently include road, waterways and maritime transport emissions (aviation emissions have been included as of 1.1.2012) Euro VI The latest HDV exhaust gas emission standards for gaseous pollutants and particulate matter as set out in Regulation (EC) 595/2009. GHG Greenhouse gases: gases that have a global warming effect HDV Heavy-Duty Vehicles, i.e. lorries, buses and coaches (vehicles of more than 3.5 tons) LDV Light-Duty Vehicles, i.e. cars and vans NOx Nitrogen oxides (nitric oxide (NO) and nitrogen dioxide (NO2)) OEM Original Equipment Manufacturer: the main truck and bus manufacturers of complete vehicles, tractors and chassis/cabin unfinished vehicles PM Particulate matter Tailpipe emissions TTW emissions (see below) TTW emissions "Tank-to-wheel" –or tailpipe- emissions: emissions that occur throughtout the drive cycle of vehicles. This only includes dowstream emissions, excluding upstream emissions (see below WTW emissions) VECTO Vehicle Energy Consumption calculation TOol WTW emissions "Well-to-wheel" emissions = TTW + upstream "well-to-tank" emissions attached to the fuel production and transport



1.Problem definition 1.1Context This Commission's primary political objectives are to create jobs, growth and investment, and in this context to make the transition to clean energy for all Europeans. This is underpinned by an investment plan aimed at reindustrialising Europe based on new business models and cutting-edge technologies. The medium- to long-term aim is to achieve, a circular low carbon economy. In the context of transport, particularly with respect to lorries, buses and coaches, i.e. heavy-duty vehicles (HDVs), the Commission’s vision is to ensure that European citizens and business have access to fair, sustainable and competitive mobility:

·In 2014, the Commission adopted a Communication on a Strategy for Reducing Heavy-Duty Vehicles' fuel consumption and CO2 emissions (referred to hereafter as "the HDV Strategy"), announcing firstly an implementing measure setting out the procedure for the certification of carbon-dioxide (CO2) emissions from new HDVs, calculated by the VECTO simulation tool, and secondly upon its adoption to propose legislation to monitor and report them for all new vehicles placed on the EU market. ·In July 2016, the Commission's European Strategy for low-emission mobility set the ambition for the transport sector to reduce greenhouse gas (GHG) emissions by at least 60% in 2050 compared to 1990 levels and of drastically reducing the emission of air pollutants. The strategy includes an action plan to improve fuel efficiency and to reduce emissions from HDVs. So far, only pollutant emissions from these vehicles are regulated under the so-called Euro VI Regulation . The Strategy confirmed the earlier 2014 work and also announced that the Commission will speed up analytical work on design options for HDV CO2 emission standards to prepare a legislative proposal during the mandate of this Commission. ·In October 2015, the EU ratified the Paris Agreement which then entered into force 30 days thereafter. The EU committed to an at least 40% domestic emission reduction by 2030 compared to 1990. As part of the implementation, the Commission proposed in July 2016 the Effort Sharing Regulation on binding annual GHG emission reductions by Member States for the period 2021 to 2030. Central policy scenarios used inter alia for the low-emission mobility strategy and for the impact assessment underpinning the Effort Sharing Regulation show that for reaching the EU’s ambitious 2030 target emission reductions for transport would have to be around 18 to 19% by 2030 compared to 2005 levels. ·In December 2016, the Commission also proposed a revision of the Energy Efficiency Directive setting a binding headline target at EU level of 30% for improving energy efficiency in 2030 compared to business as usual. Total primary energy consumption should come down to 1 321 Mtoe by 2030. In 2015, total primary energy consumption was 1529.6 Mtoe. This impact assessment (IA) accompanies a Commission proposal for a Regulation on the monitoring and reporting of CO2 emissions and fuel consumption from HDVs, which is part of the Clean, Connected and Competitive Mobility Package and constitutes an additional step to address HDV CO2 emissions, as announced in the abovementioned strategies. The scope of this IA therefore covers specifically the monitoring and reporting of CO2 emissions and fuel consumption of new vehicles. It also takes into account the first two steps which have already been decided and are therefore not subject to this IA: 1) the VECTO simulation tool, developed to calculate new HDVs CO2 emissions and fuel consumption, and 2) the certification procedure for calculating these emissions with VECTO through a draft Commission Regulation under the type approval legislation. This constitutes the first block of EU measures in relation to CO2 emissions from HDVs. This measure will close the knowledge gap on EU HDV CO2 emissions identified in the 2014 HDV Strategy. At the same time, it provides the key enforcement tool for the future CO2 emission standards for these vehicles, which will be proposed before the end of this Commission mandate and will be subject to another dedicated IA. This Regulation will also help with the establishment of a methodology for the differentiation of infrastructure use charges for new HDVs according to CO2 emissions, supporting the implementation of the review of the "Eurovignette" Directive.



1.2What is the problem? 1. Missed opportunities to design policies to reduce the fuel bill for transport operators Freight transport operators can experience fuel costs greater than a quarter of their operational costs and rank fuel efficiency as their top purchase criterion. While the fuel efficiency of heavy-duty vehicles has improved over past decades, many of the more than half a million transport companies, which are to a large extent SMEs, do not have access yet to standardised information to evaluate fuel efficiency technologies, compare lorries in order to make the best informed purchasing decisions and reduce their fuel costs. This is also made more difficult by the absence of a commonly agreed methodology to measure fuel consumption. A study assessed market barriers to increased efficiency in the European freight sector and concluded that the lack of information and comparability between vehicles' CO2 emissions and fuel consumption was one of the main market barriers to the uptake of fuel saving innovation. Despite being aware of a number of fuel saving technologies, transport operators were not able to make informed choices and purchase the most energy efficient vehicles as they could not compare the different brands and models at the stage of vehicle purchase. Over time, these missed fuel savings cumulatively increase the EU's dependency on fossil fuel imports and represent a missed opportunity to reduce fuel imports. 2. Increasing competitiveness challenges for vehicle manufacturers In 2015, according to industry data, the exports of lorries generated a trade balance surplus of € 5.1 billion. This sector is part of an automotive industry which generates 12.1 million direct and indirect jobs in Europe (5.6% of total EU employment). EU HDV manufacturers face increasing global competitive pressures. Significant markets such as the United States, Canada, Japan and China have in recent years implemented certification and fuel efficiency measures in the form of fuel consumption and/or emission standards in order to stimulate innovation and rapidly improve vehicle efficiency. A summary of the experiences for the other main HDV markets in the world is provided in Annex 9. The city buses market sees also an increasing competition in the field of electric vehicles, in particular from Chinese manufacturers. The EU HDV manufacturing sector will need to keep up with the technological improvements in these markets to preserve its current market position.

The lack of market transparency translates into lesser pressure for EU HDV manufacturers to make further efforts to improve vehicle efficiency and invest in innovation in such competitive global market. This creates risks for the EU manufacturing sector to lose its current leading role in vehicle fuel efficiency. Transparency on the fuel and CO2 emission performance of the vehicles would also stimulate competition inside the EU market, where in 2016 the Commission revealed a cartel among a number of manufacturers of lorries that operated between 1997 and 2011. 3. Barrier for setting policies to address the GHG emissions challenges for the heavy duty vehicles sector The HDV sector is a significant source of GHG emissions. In 2014, GHG emissions from HDVs represented 5% of total EU emissions, a fifth of all transport emissions and about a quarter of road transport emissions. During the period 1990-2014, overall GHG transport emissions have increased by 20% and HDV emissions by 14% as illustrated in Figure 1. Figure 1. Road transport GHG emissions 1990-2014 Note: 1.A.3. b.ii / Light duty trucks includes light-duty vehicles < 3.5 t Source: GHG Inventory data 2016 As shown in Figure 2, without further action, HDV CO2 emissions are set to increase by up to 10% between 2010 and 2030. Given action already taken to curb emissions from cars and vans, HDV CO2 emissions are bound –particularly as regards emissions from lorries – to represent an increasing share of road transport emissions, from around 25% in 2015 to around 30% in 2050.



Source: EU Reference scenario 2016, PRIMES-TREMOVE Transport Model (ICCS-E3MLab) At the same time, the EU has set ambitious targets for GHG reduction in 2030 to which the transport sector must contribute. The EU has an overall domestic emissions reduction target for 2030 of at least 40% below 1990 levels which has been divided in a cost-effective manner into reductions by 2030 compared to 2005 of 43% for the emissions from the EU ETS sectors and of 30% for the non-ETS sectors, to which transport belongs. Member States’ transport emissions range from 21% to 69% of total national emissions in the not-ETS sectors covered by the Effort Sharing Regulation. While no sector-specific targets have been set for 2030, transport will need to contribute its share to the achievement of the non-ETS emission reduction target in the context of the Effort Sharing Regulation, together with buildings, agriculture, and waste. The above mentioned lack of information is, however, hampering action at national or EU level to reduce HDV CO2 emissions. For instance, at national level the lack of availability of data on fuel consumption and CO2 emissions prevents Member States to provide further incentives for the uptake of efficient HDVs, and design for example appropriate taxation or incentive schemes including road charging and public procurement to promote emission reductions. At EU level, the absence of robust and comparable data prevents the implementation and enforcement of future harmonised CO2 emission standards across the EU market. 1.3Why is it a problem? What are the main drivers? The main driver for the identified knowledge gap is a market failure, i.e. the absence of monitoring and reporting of objective, standardised and comparable CO2 emissions from HDVs. Figure 3 illustrates the problem tree.



Figure 3. Problem tree

CO2 emissions from new heavy-duty vehicles placed on the EU market have so far not been monitored and reported in an objective and comparable manner, implying that no reliable data are available regarding their magnitude at fleet and vehicle level. This is also true for fuel consumption of these vehicles, which is directly correlated to the CO2 emissions, as well as the real benefits of fuel efficiency technologies. The only EU HDV fleet data available at the moment with regards to CO2 emissions come from the greenhouse gas emission inventories, for which emissions of the whole HDV sector are estimated by each Member States based on fuel sales. Such data does not provide information on CO2 emissions of each specific vehicle, and therefore cannot be used to define policies aimed at increasing fuel efficiency and reducing CO2 emissions at vehicle level. At vehicle level, and until certification becomes mandatory, the information available to buyers of new HDVs concerning their fuel consumption is based on different testing and simulation methodologies depending on each HDV manufacturer, and are therefore not directly comparable. Buyers have also no broader information on the development of competition with respect to fuel efficiency in the EU-wide market for transport services The EU HDV market is therefore lacking transparency as regards fuel consumption and CO2 emissions of new vehicles preventing well informed purchasing and policy decisions promoting the most fuel efficient vehicles. 1.3.1Where are we now in addressing the problem? Against this background and in application of the 2014 HDVs Strategy, the Commission has taken action to address this knowledge gap, based on the following three-step approach illustrated in Figure 4.



Figure 4. Identified three-step solution Subject of this impact assessment Developed for lorries above 7.5 tonnes Developed and ready to simulate CO2 emissions and fuel consumption of lorries above 7.5 tonnes Step 1: Development of a simulation software - the Vehicle Energy Consumption calculation TOol (VECTO) - in order to calculate fuel consumption and CO2 emissions of new vehicles The first measure has been to develop an IT simulation tool, so-called VECTO, to calculate HDV CO2 emissions and fuel consumption in a comparable manner among different heavy-duty vehicles across all manufacturers. The decision to develop this tool was made after considering other options for test procedures, including engine test beds, chassis dynamometer and on-board tests in real traffic with Portable Emission Measurement Systems (PEMS). The key reasons to opt for simulation rather than any of the other testing procedures were: 1)Comparability: test results for different types of HDVs are directly comparable; 2)Cost efficiency because of high costs of testing facilities compared to simulation; 3)Capability to deal with high variability: HDV series of production are very small since vehicles are to a large extent customized to end-users' prescriptions; 4)Repeatability: simulation offers the highest scores for reproducibility of the tests; 5)Accuracy: small savings from single component optimisations can be detected; 6)Comprehensiveness: simulation can be used to optimise the total vehicle configuration in order to achieve lower fuel consumption, since it includes all components (i.e. cabin, tyres, engine, transmission, etc.). This approach was confirmed in the 2014 HDV Strategy and its accompanying IA.

Other major countries have also opted for using simulation tools. For instance, the US EPA has developed a similar simulation software, the Greenhouse Gas Emissions Model (GEM) to calculate CO2 emissions and fuel consumption from HDVs (see Annex 9). The Commission in close cooperation with stakeholders have developed VECTO. The current version is ready to support CO2 certification for lorries above 7.5 tonnes. Simulation module for buses and coaches is still under development. Simulation results have been compared to real driving, and the VECTO simulations have shown a high level of accuracy of around +/- 3%. Further details on VECTO are provided in Annex 4. Step 2: New Commission Regulation on the determination of new heavy-duty vehicles' CO2 emissions (so-called "certification" Regulation) The development of VECTO has laid the ground for a certification methodology for CO2 emissions and fuel consumption of new heavy-duty vehicles before being placed on the EU market. It will be possible to calculate VECTO values in a comparable and certifiable way under the existing type approval legislation. According to the upcoming Commission Regulation on certification each heavy-duty vehicle of the categories identified, which is going to be placed on the EU market, will need to be simulated in terms of CO2 emissions and fuel consumption with VECTO. Vehicle manufacturers themselves will perform the simulation on the basis of certified input data of all different vehicle components and of a certified process of sourcing, managing and applying such input data. Further details on the draft certification methodology are provided in Annex 5. The certification methodology has been developed in 2015-2017 based on extensive stakeholder consultation and input. The Technical Committee on Motor Vehicles provided a positive opinion on 11 May 2017 on the draft Commission Regulation on certification proposed by the Commission. It covers the main categories of lorries above 7.5 tonnes, to be followed by amendments to cover smaller lorries (above 3.5 tonnes) as well as buses and coaches. The Regulation is not accompanied by a specific impact assessment beyond the IA on the 2014 HDV Strategy. Nonetheless studies on the costs of its implementation have been carried out. Relevant cost information is illustrated in Annex 5. Once the certification regulation enters into force in 2019, HDVs manufactures will be required to calculate with VECTO fuel consumption and CO2 emissions of every single HDV produced and placed on the EU market. Certification, however, would only close the knowledge gap partially, since information on the performance of the vehicles will only be available to each individual purchaser and to the national authorities where the vehicle is registered. In order to close the knowledge gap and create full market transparency, this information should be made available to all stakeholders, so that: ·Transport operators can have an understanding of the performance of lorries from different brands with similar characteristics, to be able to make better informed purchasing decisions. ·Vehicle manufacturers can compare their vehicles' performances with those of other brands, and have increased incentives for innovation. ·Public authorities can have access to comprehensive data for designing and implementing policies to promote more fuel efficient lorries, for instance through taxation, road user charging, etc. This would not otherwise be possible as Member States have access only to VECTO data from the vehicles registered in their territory. ·Non-governmental organisations can make analysis of the data, e.g. assessing the penetration level of certain technologies, etc. Step 3: Monitoring and reporting certified CO2 emissions from new heavy-duty vehicles Through this third step, all relevant data calculated by manufacturers according to the certification methodology would be monitored, reported and published at EU level. In this way the data would be available to all stakeholders. Whether and how such monitoring and reporting system should be designed is the subject of this IA. Since emission data will become available from the first year of the entry into force of certification in 2019, it will be paramount to set up the system in order to have such data reported and published the year after. This is a necessary step also in the process to prepare the implementation and enforcement of future CO2 emission standards for HDVs. A monitoring and reporting system is necessary in particular for assessing the compliance of such future standards, as it is the case for cars and vans. A system already in place by the time future HDV CO2 emission standards will enter into force will allow for the actors involved, especially vehicle manufacturers, to become familiar with the obligation to monitor and report, and for the system to be tested, and implementation guidance developed if need be. Stakeholders' view

All stakeholders, who replied to the online public consultation, agreed that monitoring HDV fuel consumption and CO2 emissions in the EU is needed in order to gather the necessary data to close the identified knowledge gap. 1.4Who is affected by the problem, in what ways, and to what extent? Whose behaviour would have to change to improve the situation? The lack of information on fuel efficiency directly affects freight transport operators as well as logistics companies, i.e. the buyers and users of HDVs. This lack of information and possibility to compare prevents them from choosing the most efficient vehicles and to benefit from the corresponding potential fuel savings. These could be significant considering that fuel represents a large share of vehicle operating costs . It has therefore impacts on intermediate transport costs and potentially on the costs of goods and services for consumers and companies. HDV manufacturers and automotive component suppliers in the absence of such transparency have only limited incentives from the market to invest in innovation and deployment of energy efficient technologies to improve their vehicles and hence their competitiveness. Member States are also affected. At the moment few Member States have set up voluntary schemes to promote HDV CO2 emissions reductions and fuel efficiency. In France, under the initiative Objectif CO2, transport companies can sign a charter of commitments, pledging to work towards an overall CO2 emission reduction goal over a period of three years. In Ireland, the Sustainable Energy Authority recognises best practice in energy performance, management and design through the annual Sustainable Energy Awards, for the individuals and groups who demonstrate a commitment to include energy management as part of their overall management structure, including transport companies. However, the lack of availability of data on fuel consumption and CO2 emissions from HDVs prevents Member States to regulate effectively on that basis, and design for example appropriate taxation schemes, including road user charging, which can currently only be based for HDVs on the EURO air pollutants emission classes. It would also provide information to design incentives schemes, for instance embedded in public procurement, to promote fuel efficient and low emission HDVs. Moreover it would make existing fuel taxation more effective. In addition, lower fuel consumption would reduce the necessity for imports of fossil fuels into the EU and contribute to overall energy security and trade balance. 1.5What is the EU dimension of the problem? Markets for new HDVs and transport services are both operating EU-wide and are integral parts of the Single Market. The lack of transparency concerning fuel consumption and CO2 emissions from new vehicles is not yet addressed in any of the Member States and concerns the EU as a whole. Moreover, HDV CO2 emissions are covered under the EU’s greenhouse gas emission reduction target. The development of the vehicle emissions simulation tool VECTO has been carried out cost efficiently by the Commission in close cooperation with experts from Member States and stakeholders. The certification of HDV fuel consumption and CO2 emissions is set out in a Commission Regulation, under the EU type-approval framework which covers HDVs. For cars and vans a mandatory EU-wide system to monitor and report CO2 emissions is already in place. 1.6How would the problem evolve, all things being equal? In the absence of an EU-wide monitoring and reporting legislation, national authorities may adopt different monitoring and reporting approaches leading to a fragmented and inconsistent collection of such data across the EU. This would lead to high administrative burden for HDV manufacturers who would have to keep different reporting systems. However, this risk is unlikely as illustrated by the public consultation indicating that national authorities would rather not act at all. In case HDV certification is put in place without monitoring and reporting CO2 emission and fuel consumption data at EU level, information on the level of penetration and actual diffusion of advanced fuel efficient technologies will not become fully available to manufacturers, HDV buyers and policy makers. One would not be able to compare the performance of vehicles across the whole fleet, assess the wider effective demand for fuel efficient vehicles and evaluate national policy incentives for fuel efficient lorries. With certification alone, only the direct buyer of a vehicle would receive the information at the moment of purchasing and Member States would have access to the information only for the vehicles registered in their territory. As a result, technological progress in terms of fuel efficiency and CO2 emissions would stay at business as usual. Freight operators would lose in terms of fuel costs, transport costs would be higher than necessary, EU manufacturers risk falling gradually behind their competitors outside Europe, and the share of emissions from heavy-duty vehicles would increase in the coming decades. Furthermore, it would not enable the implementation and enforcement of future CO2 emission standards and would also hamper action at Member States level to reduce emissions from this sector. For example, road user charging schemes could not be effectively designed to address CO2 emissions as Member States do not have access to the full database on CO2 emissions from HDVs that could operate on their territory. 1.7Has any fitness check/retrospective evaluation been carried out of the existing policy framework?

HDV CO2 emissions are currently not subject to specific EU legislation. Consequently, no evaluation could be carried out. 2.The right of the EU to act 2.1Legal basis Climate change is a trans-boundary problem and at the same time is a competence shared between the EU and Member States. Coordination of climate action at European level is therefore necessary and EU action is justified on grounds of subsidiarity. Articles 191 to 193 of the Treaty on the Functioning of the European Union confirm and further specify EU competencies in the area of climate change. In particular, the TFEU provides the legal basis for acting on HDV fuel consumption and CO2 emissions. The EU has already acted in the area of vehicle emissions, adopting Regulations (EC) 443/2009 and (EU) 510/2011 which set limits for CO2 emissions from cars and vans, and with implementing legislation on monitoring and reporting of data on registration and CO2 emissions of new light commercial vehicles ((EU) No 410/2014 and 2012/293). These Regulations were based upon the Environment chapter of the Treaty and namely on Article 192 TFEU. In addition, there is a need to maintain a functioning Single Market for HDV manufacturers and to preserve a level playing field for all transport operators in the EU. 2.2Analysis of subsidiarity and added value of EU action EU action is justified in view of both the cross-border impact of climate change and the need to safeguard single markets in fuel, vehicles and transport services. The EU-28 share of international transport in total road freight transport in 2015 was 40%, in some Member States reaching above 80%, see figure 5 below. Moreover, new HDVs registered in a given Member States are often produced by a manufacturer in another Member State. Monitoring at national level instead of EU level would thus require extensive cooperation among Member States, including the adoption of various pieces of national legislation. Even if such monitoring at national level were to materialize, comparable and homogeneous monitoring data would not be guaranteed due to differences between Member States' legislation and policy practices, for instance in the field of taxation or organization of the transport network. Comparability and completeness of data would be difficult to achieve, triggering EU market fragmentation and loss of market transparency. Another difficulty related to the proliferation of monitoring schemes at national level would be the lack of a common database containing all Member States' monitoring data. This would, in particular, hamper the utility and use of the data by the purchasers of vehicles and by policy makers at EU level. A common monitoring scheme at EU level appears to be the most straightforward and simple approach. This would reap the benefits of the adoption of the certification procedure on HDV fuel consumption and CO2 emissions. For similar reasons, this is the approach followed for cars and vans through EU level action. Figure 5. Share of international transport in total road freight transport, 2011 and 2015 (% in tonne-kilometres) Source: Eurostat, 2016 (road_go_ta_tott) 2.3Proportionality check HDV emissions are significant representing about 5% of EU CO2 emissions and 20% of transport emissions. In view of their scale and their long-term increasing trend, it appears proportionate to collect and report HDV CO2 emissions and fuel consumption data for new vehicles, thereby improving market transparency. Conclusions on proportionality (section 6) will further take into consideration how the options meet effectiveness requirements, notably with regards to its costs and benefits.

3.Objectives General policy objectives: 1)Facilitate a reduction in fuel costs for transport operators, many of which are SMEs 2)Contribute to the improvement of the competitiveness of HDV manufacturers 3)Contribute to the achievement of the EU's climate and energy target and objectives Specific objectives: ·Enable informed purchasing decisions and deployment of more fuel efficient vehicles ·Foster innovation and development of fuel efficiency technologies ·Promote cost-effective reductions of CO2 emissions and reduce overall fuel consumption from HDVs ·Enable the development of rational policies promoting the uptake of advanced fuel efficient and low emission HDVs Operational objective: Monitor and report in a cost efficient manner: ·CO2 emissions and fuel saved over time per vehicle group, manufacturer and Member State ·uptake levels of more fuel efficient vehicles and rate of annual efficiency improvement in each vehicle group ·technology development and penetration levels in the fleet



4.Options With the entry into force of the certification obligation, CO2 and fuel consumption of all new lorries above 7.5 tonnes placed on the EU market and falling under the scope of the new Commission Regulation will have to be simulated using VECTO. Options will be considered in this impact assessment on whether and how these data should be reported and monitored at EU level to close the knowledge gap on CO2 emissions from heavy-duty vehicles. 4.1Common elements of the options considered

4.1.1Scope of monitoring and reporting The options considered relate to the monitoring and reporting of CO2 emissions from all new HDVs placed on the EU market, which will be subject to the certification process under the type approval framework. The monitoring system will only cover CO2 emissions, resulting from the certification procedure. Emission pollutants, such as particulate matter (PM), nitrogen oxides (NOx), un-burnt hydrocarbons (HC) and carbon monoxide (CO), as well as methane (CH4) emissions from CNG fuelled engines, are already covered by the EURO VI engine standards. Fluorinated greenhouse gases due to leakages from refrigeration systems in the case of refrigerated trucks and from the air conditioning systems of HDVs are covered by the so-called F-gas Regulation. The monitoring system will only cover new vehicles, since vehicles in use cannot technically be subject to certification. The input data needed to run the VECTO simulation tool are not available for vehicles already sold and in operation. Moreover, fuel efficiency technologies can generally not be (cost-effectively) retrofitted to existing vehicles. Furthermore, the first purchasing decisions are crucial for the diffusion in the fleet of more fuel efficient vehicles. It is thus essential to provide the right set of information to influence them. Considering the average lifetime of a lorry of around ten years, it can be assumed that in ten-year time the whole (or most) of the EU fleet will be covered by the monitoring scheme. Manufacturers will generate the digitised monitoring data at the time of production. This will contain a subset of around 80 parameters coming out of the certification process under type approval (see Figure 6 below for an illustration of the link between VECTO, certification and monitoring and reporting). The parameters in the monitoring data file have been chosen from the VECTO output data file following a technical analysis, which took into account the relevance of these parameters for the objective of closing the knowledge gap on HDV CO2 emissions and future policy action, in particular having in mind the enforcement needs for future HDV CO2 emission standards. The key parameters are fuel consumption and CO2 emission values and other parameters relevant for the determination of such values coming from the certification process. Table 1 below provides a list of the main elements of the monitoring data which will have to be reported. Table 1. Main elements of the data to be monitored and reported General (mission profile independent) vehicle information Component identification Vehicle classification Vehicle and chassis specification Main engine specifications Aerodynamics Main transmission specifications Main axle specifications Angle drive Main tyre specifications Main auxiliary specifications Technologies to reduce CO2 emissions, e.g. advanced driver assistance systems Mission profile and loading dependent values Vehicle mass Vehicle driving performance and information for simulation quality check Fuel and CO2 results VECTO version Manufacturers' reported monitoring data will not include information on where the vehicle was registered. National authorities will need to complement manufacturer’s information with vehicle registration data on the basis of the Vehicle Identification Numbers (VIN, described in Annex 6). This will allow calculating average values for CO2 and fuel efficiency across the fleet of new heavy-duty vehicles registered in certain Member States for each calendar year.



Figure 6. Links between VECTO, certification and monitoring and reporting 4.1.2Statistical analysis Taking into account future regulatory use of the monitoring data, it is necessary to provide effective safeguards ensuring the objectivity and precision of the data. It is therefore appropriate to foresee an empowerment for the Commission to develop a methodology for carrying out statistical data analysis for detecting and taking into account possible unjustified divergences found in the reported data, e.g. lorries of the same model reported with very different CO2 emissions. This could trigger for example further targeted verification according to future provisions of the certification Regulation, thereafter improving market surveillance. 4.1.3Role of the European Environment Agency (EEA) The European Environment Agency (EEA) is the most appropriate body at European level to act on behalf of the Commission in order to collate data, build a new database, analyse and perform quality checks of the reported monitoring data from heavy-duty vehicles. This was also confirmed by comments received through the public consultation, which underlined the need of an independent agency to perform the monitoring at EU level. The EEA already carries out these tasks for different monitoring and reporting schemes, including for CO2 emissions from cars and vans (see Annex 8 for more information). Impacts on EEA's resources are assessed in section 5. 4.1.4Publication of Monitoring Data

The annual monitoring process would be completed with the publication by the Commission/EEA at the end of year n of monitoring data for year n-1 per vehicle, manufacturer and Member State. Stakeholders expressed different views concerning the publication of the full set of monitoring data reported per vehicle. On the one hand, civil society organisations consider that all monitoring parameters should be published per individual vehicle in order to ensure full transparency. On the other hand, HDV and some component manufacturers have expressed concerns about the commercial confidentiality of some of the parameters like the coefficients of the rolling resistance of the tyres and of the aerodynamic drag. In duly justified cases, such as where it is clearly demonstrated that a public disclosure of the data would seriously undermine commercial interests, the transparency objective may nevertheless be achieved by e.g. the publication of ranges of values instead of the specific values or the parameter may not be made public if absolutely critical. In the latter case, the data would be kept only for Commission internal use. The Commission has also considered the risks that publication of data for each new HDV registered in the EU would entail in terms of market reactions. The risk of market collusion in a market with a very limited number of players, such as the EU HDV market, is considered to be limited as a result of the publication of the monitoring data. The availability of such data is expected rather to enhance competition in the market, given the information available on the performance of each player's vehicles. 4.2Baseline option "No action at EU level" This option does not entail any action at EU level on setting up a monitoring and reporting system for the CO2 emission and fuel consumption data from new heavy-duty vehicles resulting from the certification process. The certification legislation would be adopted under the type-approval framework, but no instrument would be proposed to gather such data at EU level in a common database. The other options below are assessed against this baseline. 4.3Options assessed on how to monitor and report The options relate to how to monitor and report CO2 emissions and fuel consumption from new HDVs. Three main options are considered as illustrated in Figure 7.



Figure 7. Overview of option 1, 2 and 3 Source: EC/CE Delft, 2016 4.3.1Option 1: Reporting by national authorities Under this option, national authorities report the monitoring data and the registration data of the vehicles concerned via the EEA to the Commission. As is the case for monitoring and reporting CO2 emissions from vans, Member States will designate a competent authority for the collection and forwarding of the monitoring information, which would be the registration authorities in most cases. They will gather the monitoring data as part of the vehicle registration process. The activities required for monitoring and reporting of HDV CO2 emissions under this option include the following: -adaptation of the national vehicle register, if needed; -gathering of the monitoring data from the national vehicle register; -submission of data to EC/EEA; -combining national data sets and processing of data by EEA;

-eventually fixing of mismatches of data upon comparison of national data and manufacturers' data. Under the assumption that all VECTO data is available due to the vehicle certification, the role of manufacturers would be to submit monitoring data to national authorities or intermediary persons (such as importers or dealers), during the registration procedure. In addition, manufacturers would review the data set compiled by EEA. Implementation of this option will require extra investments, for example concerning training staff in all Member States. The amount of additional costs will depend on the existing expertise and technical system already available in the specific Member State. Full digitisation of monitoring and reporting may not be easily feasible under this option as the majority of national registration authorities still process paper files to register HDVs (see Table 2 in section 5.1.2), therefore adaptation to fully digitised flows of monitoring data may be challenging and costly, this will be further assessed in section 5.1.2. Figure 8. Actors and related role for option 1 Stakeholders' view Option 1 was deemed the most appropriate option for monitoring and reporting HDV CO2 emissions and fuel consumption by 31% of the 121 respondents to the online public consultation (see Annex 2). The stakeholders most in favour of this option belong mainly to professional organisations, e.g. dealing with transport and logistics, private enterprises like component manufacturers, business, industry, and trade associations, some civil society organisations and some public authorities. 4.3.2Option 2: Reporting by manufacturers This option would alternatively put HDV manufacturers in charge of reporting the monitoring data for each new vehicle via the EEA to the Commission. In such a case the monitoring data would be annual sales-based data in the possession of vehicle manufacturers and no registration data would be reported (i.e. no information would be available on where the vehicle was registered). Under this option manufacturers would thus annually collect and report the required monitoring data of their produced vehicles to the EC/EEA, including sales numbers on EU territory. The country of registration is not necessarily the country where vehicle and documents are sent to from the manufacturer. Dealers may register it elsewhere and, consequently, the manufacturers have no reliable information on where vehicles are registered. Under this option, only manufacturers, the EEA and the Commission would have specific obligations with respect to monitoring and reporting of HDVs CO2 emissions and fuel consumption, whereas Member States would play no role, as illustrated in Figure 9.



Figure 9. Actors and related role for option 2 Full digitisation of monitoring and reporting appears feasible under this option since manufacturers deal with digital files (e.g. they already own the digital VECTO input and output data) and could efficiently transfer them. Stakeholders' view Option 2 was considered the most appropriate option by 12% of the respondents to the online public consultation, mainly by professional organisations (e.g. representing shippers). 4.3.3Option 3: Mixed reporting by national authorities and manufacturers

This third option is an intermediate option between 1 and 2. Designated national authorities –most of which are expected to be the national registration authorities– would annually report via the EEA to the Commission registration data (VIN numbers) of new registered vehicles. Vehicle manufacturers would submit via the EEA to the Commission the corresponding monitoring data. On the basis of the VIN numbers the two datasets are combined in order to obtain monitoring data at a Member State level. Figure 10. Actors and related role for option 3 Under this option, full digitalisation of the flow of data is ensured, since manufacturers are in charge of reporting the monitoring data. Stakeholders' view Option 3 was considered as the most appropriate option by the highest number of respondents (42%) to the online public consultation, belonging to civil society organisations, the automotive industry, sector/trade/employers' associations, private and public companies, not for profit organisation, professional organisations (mainly linked to the automotive industry), private enterprises (e.g. from the energy sector), public authorities, individuals and international organisations. 4.4Discarded options Voluntary cooperation Voluntary cooperation among national authorities and/or vehicle manufacturers could provide a monitoring of fuel consumption and CO2 emissions of new vehicles in the EU. However: ­Harmonised checks and controls of these data would not be possible and the quality of the reporting may be affected. ­Cooperation cannot be taken for granted. In the absence of full cooperation of all players EU-wide monitoring/reporting would not be possible. ­The absence of such voluntary monitoring so far points to the difficulty of such approaches. In view of the latter this option was discarded. It has not been supported by any stakeholder. Collection of real-world fuel consumption data Some stakeholders suggested that the emission data reported by manufacturers should be supplemented with “on-road/actual operations” data. Real-world fuel consumption data could be collected directly from on-board units fitted on the vehicles or requesting the operators to retrieve and report such data from their fleet management systems. This would require in particular on-board fuel flow meters to be made compulsory. This option goes beyond the scope of this Impact Assessment which focuses on the monitoring data generated by VECTO through the certification process. It has therefore been discarded. It should, however, be noted that the relationship between the HDV CO2 emissions calculated ex-ante with VECTO and the real world emissions has been subject to thorough reflection in the preparation of the first block of HDV CO2 emission legislation. In particular, the Commission has considered the following elements: ·Firstly, the high accuracy of the VECTO simulation tool. The simulation tool has been designed and calibrated in such a way to ensure a high accuracy, in the order of +/-3 % according to tests carried out by DG JRC. This measures the ability of VECTO to accurately calculate the emissions and fuel consumption of a specific vehicle on a specific route.

·Secondly, it will be important to set up periodic verification on VECTO and its use by manufacturers to ensure that this accuracy remains high and that manufacturers use the VECTO simulation tool in a correct manner. This safeguard will consist of periodic verification of the results of the certification procedure and of the accuracy of the simulation tool. Discussions have started in view of the introduction of this requirement in the certification Regulation as soon as a robust verification testing procedure is agreed (see Annex 5). ·Thirdly, from the side of the monitoring and reporting legislation, an additional safeguard will be foreseen to detect possible unjustified divergences found in the reported data through statistical analysis of the reported data (see above section 4.1.2). ·Fourthly, the Commission aims to monitor the gap between the future VECTO data and real-world data. This gap should be as small as possible but cannot be entirely closed in view of the large variability in the use of the vehicles in real-world. A quantified analysis is not yet possible as VECTO is not in place and on-board fuel meters are not mandatory under the type approval. Further work will be needed in this respect and goes beyond the scope of this IA. VECTO as an open tool A non-governmental organisation and other stakeholders submitted a joint memorandum to the Commission requesting VECTO to be made available to third parties such as transport operators or suppliers. This should enable third parties to independently consult and compare vehicle combinations, their energy performance and CO2 emissions. The design of VECTO largely accommodates this request since it has been established as an open source software under EU Public License. It can be run under so-called 'declaration' mode for certification purposes and under 'engineering' mode with various possible assumptions to assess vehicles' energy performance and emissions in a customized way (see Annex 4 for more details). However, the confidentiality of some of the input data, e.g. fuel and engine maps, does not allow the access of VECTO 'declaration' mode to third parties. Furthermore, this concerns the regulation on certification. It was therefore discarded in this IA. Coverage of Well-to-Wheel emissions Some stakeholders proposed that the monitoring and reporting should have a broader approach providing information not only of HDV tailpipe CO2 emissions but also of the GHG emissions from the whole fuel production process. This option has been discarded in the present IA for several reasons: ·Certification only provides tank to wheel CO2 emission data. ·Furthermore, this could lead to double regulation. Today, upstream "well-to-tank" GHG emissions are subject to other EU legislation through the inclusion of the oil industry and energy production sector into the EU Emission Trading System and by the Fuel Quality Directive. ·Creation of legal ambiguity as the responsibility for the fuel production process lies with the fuel producers, and the final choice of fuels is left to the truck operator. ·A tank to wheel approach has also been taken in the case of cars and vans. 4.5Are Small and Medium sized Enterprises targeted by the different options? HDV manufacturers responsible for the monitoring and reporting are all very large international companies, namely Daimler, Volvo Trucks (which is also the owner of Renault Trucks), MAN and Scania which are part of the VW group, Iveco (CNH Industrial Group) and DAF (Paccar Group)(see Annex 7). Body and trailer manufacturers are to a large extent SMEs: the trailer and body-builder sector is highly diverse with thousands of enterprises most of which operate only in local markets. The sector is, however, not impacted as body and trailer manufacturers are not involved in the first stage of implementation of the certification regulation. VECTO simulations will use generic default values on body and trailer characteristics to calculate entire vehicle emissions. 5.What are the impacts of the different policy options and who will be affected? 5.1Economic impacts 5.1.1General economic impacts Depending on consumer choices, rates of technological progress in manufacturing more efficient vehicles, and the actual downstream use of the monitoring and reporting data by policy makers, the potential benefits could be sizeable. The impact assessment that underpinned the 2014 HDV Strategy has shown that a more transparent HDV market would stimulate competition among HDV manufacturers and transport operators. This should foster innovation to produce more energy efficient vehicles in the EU market (see paragraph 5.6). For instance this could trigger new design of the driving cabin to improve aerodynamic according to the directive on weights and dimensions. Such redesign was quantified in the related impact assessment as yielding up to 8.9% of fuel savings.

The effects of more energy efficient freight and passenger road transport are expected to, at least partially, pass-through and spread to most sectors of the EU economy: lower fuel operating costs of transport will under the current competitive environment of transport trigger lower transport prices, and thereby reduce other sectors' costs for intermediate and consumer goods, eventually benefitting EU consumers. However, transport costs are generally a small share of overall product costs: the elasticity of output prices to increases in road transport prices has been assessed in the context of past legislation and varies significantly across sectors. Options 1 and 3 are considered not to have different economic impacts. However, the second option provides much less detailed information for policy makers and therefore benefits should be expected to be smaller. In the absence of knowledge on how exactly the gathered information will be used over time, it is difficult to assess the exact vehicle percentage efficiency gains that monitoring and reporting alone could trigger on top of business as usual, which is assumed by manufacturers at around 1.3% per year during the period 2005-2020. However, a simple marker of the potential economic benefits that could be reaped from such efficiency gains is illustrated in Box 1. It shows, under the assumptions made, that an incremental 1% improvement of the energy efficiency of the fleet could lead to savings of fuel costs for transport operators of about € 725 million per year. Potential benefits of monitoring HDV fuel efficiency and CO2 The HDV fleet in the EU in 2014 consisted of around 5.6 million trucks and 0.6 million buses, emitting some 214 MT of CO2. Assuming over time that the full fleet is purchased in light of more transparent information benefiting from such monitoring, each 1% efficiency gain on the HDV fleet would translate annually into 2.1 MT emission savings and fuel savings of 790 M litres, i.e. a gain of some € 725 M for transport operators at current automotive gas oil prices or 4.9 M barrels of oil. As this is mostly imported, i.e. a non-refined oil value of some € 250 M annually based on an oil price (brent) of USD 54.15 i.e. € 50.9 it would reduce Member States' oil imports. Stakeholders' view The majority of stakeholders which replied to the online public consultation (see Annex 2) share the opinion that the economic impacts of monitoring and reporting HDV CO2 emissions and fuel consumption are expected to be positive even though limited. 5.1.2 Cost of options (administrative burden for main stakeholders concerned) Monitoring costs have been estimated in an external study (see Annex 10) for each of the three options considered and of the actors involved (Member States, OEMs, EEA/EC). Monitoring costs are estimated between € 1 (Option 3) and € 5 (Option 1) per heavy-duty vehicle registered in the EU. These costs are additional to the costs for certification (available in Table 1 and 2 in Annex 5). Two cost components have been assessed: ­transition costs: implementation costs and database development/IT investments; ­annual costs: technical maintenance and IT costs, VECTO data transfer costs, reporting costs, and costs for making checks and answering questions. These cost components have been described in more details and indicated for each option and respective actor in Table 2 below. Transition costs have been annualised with a discount rate of 4%, in accordance with the Better Regulation Toolbox, and a 10 year depreciation period. Labour costs have been estimated based on an hourly rate of 30€/hour (60.000€ for one working year), and the figure includes also social charges and costs for pension (25%). Table 2. Cost components Cost component Sub-component description Description Relevant for actor under option 1, 2 or 3 MS OEM EEA Transition costs Implementation costs The implementation costs are defined as non-technical costs for organising the process, making arrangements between actors (between MS and OEM on registration procedure, between EEA and MS/OEM on reporting format). These costs are non-recurring costs. 1,3 1,2,3 1,2,3 Database development/

IT investments The technical implementation costs refer to investments in the development of needed databases and additional IT requirements. OEMs database costs are defined as certification costs and therefore not taken into account. These costs are non-recurring costs. 1 1,2,3 Annual costs Technical maintenance &

IT costs Data management costs concern the technical maintenance costs for IT systems and databases. These only apply when IT systems are in use for the sole purpose of HDV monitoring. OEMs database costs are defined as certification costs and therefore not taken into account. The data management costs are estimated at 10% of the technical investments. 1,3 1,2,3 VECTO data transfer costs VECTO data transfer costs apply only to monitoring option 1. In this option, not all Member States use a fully digitalised registration system, and additional costs will occur when registration procedure is extended for the sole purpose of HDV monitoring. This is the case for all registrations for the OEM and only for non-digitalised registrations for Member States. 1 1 Reporting costs Reporting costs are defined as costs of transfer of data to EEA and management by EEA. These costs refer to the effort made by the responsible entity (MS in Option 1, OEM in Option 2 and both in Option 3) to perform the annual reporting. In case of EEA, this cost components represents the processing of the received datasets. 1,3 1,2,3 1,2,3 Costs for making checks, answering questions EEA and EC will perform several quality checks in order to evaluate the accuracy and the quality of the datasets. On the basis of the checks and the feedbacks from the responsible entity(ies) a preliminary database is published. Depending on the quality control system in each monitoring option, various actors will be able to give feedback on the datasets and notify the Commission of any errors in the data. The feedback is assessed and, when justified, taken into account for the final database. 1,3 1,2,3 1,2,3 1)Costs of Option 1

Monitoring costs under option 1 vary greatly among Member States in function of the number of registrations and the degree of digitalisation of the registration systems (for example a number of Member States still uses mainly paper work, see Table 3). Table 3. Rate of digitalised registrations and registration methods allowed in various countries Country MS uses CoC on paper for registration (WVTA) MS uses CoC XML file for registration (WVTA) MS uses other (than) XML file for registration Rate of total number of registrations on the basis of transferred digital files (from interviews) Austria Yes Yes Yes, adapted Croatia Yes Yes No Moderate Czech Republic Yes Yes No Denmark No Yes Not decided yet, system DMR Moderate Finland Yes No No Low France Yes No Yes (OTC file) High Germany Yes Yes Yes adapted None Greece Yes No No None Hungary Yes No No Italy Yes + local declaration paper Yes No High Lithuania Yes No No Netherlands Only for incomplete HDV Yes IVI standard designed by EReg High Romania Yes No No Slovakia Yes No No Slovenia Yes Yes No Spain No Yes Yes High Sweden No Yes No Low United Kingdom Only for complete vehicles, other vehicles via national IVA No No Low Decisive cost categories are thus the development and operation of the needed IT systems by Member States in order to process large monitoring data files and the transfer of individual data files per vehicle. Total one-off transition costs for all Member States are estimated to be around €2 million and the annual costs for all EU Member States around €500.000 per year. When transition costs are annualised, the total costs are estimated to about € 800.000 per year in average for each Member State. Transition costs for all manufacturers have been estimated in the range of €125.000-250.000 and annual costs between €75.000-180.000 per year, plus €20.000 for data checking. 2)Costs of Option 2 This option entails no additional costs for Member States. Transition costs per manufacturer are estimated to be around €16.500 and annual costs around €7.000 for reporting plus €6.750 for checking data. 3)Costs of Option 3 This option does not involve transition costs for Member States and in total annual costs are estimated in average at around €100.000 for all Member States (around €3.500 per Member State) per year. Costs for manufacturers are similar as for option 2. All three options require transition costs of around €250.000 for the EEA/EC and around €175.000 of annual costs. Total annualised costs for the EEA/EC are estimated to be around €205.000. Entity Cost component Option 1

national authorities reporting to EC/EEA Option 2

manufacturers reporting to EC/EEA Option 3

Mixed : national authorities/manufacturers reporting to EC/EEA HDV Manufacturers Transition costs k€ 1.313 k€ 116 k€ 116 Annual costs k€ 901 k€ 96 k€ 96 Total annualised(*) k€ 1.062 k€ 110 k€ 110 Member States Transition costs k€ 2.242 0 0 Annual costs k€ 534 0 k€ 98 Total annualised (*) k€ 811 0 k€ 98 EC/EEA Transition costs k€ 250 k€ 250 k€ 250 Annual costs k€ 175 k€ 175 k€ 175 Total annualised(*) k€ 206 k€ 206 k€ 206 Total annualised Total annualised (*) k€ 2.079 k€ 316 k€ 414 (*) Transition costs were annualised using a discount rate of 4% and a period of 10 years Source: CE Delft (2016) Stakeholders' view These results of the cost assessment carried out by CE Delft were presented at the stakeholders' meeting on 17 October 2016 and have not been challenged. 5.2Social impacts There is no expected appreciable impact on employment from either option in the short term. The possible short term impact on employment could be the few jobs related to the monitoring and reporting function in national authorities (options 1 and 3), vehicle manufacturers (option 2 and 3). In all three options, two additional full time employees will be required in the EEA and 0.5 in the EC. In the medium to long-term, positive social impacts are expected through the stimulation of competitiveness and innovation for manufacturers and transport operators. No quantification is however possible at this stage.

Stakeholders' view The majority of stakeholders which replied to the online public consultation agree that social impacts will not be material for any of the options. 5.3Environmental impacts 5.3.1CO2 emissions As indicated in the impact assessment that underpinned the 2014 HDV Strategy, certification, monitoring and reporting of HDV CO2 emissions in curbing HDV fuel consumption and CO2 emissions is expected to be effective. This action would establish a reliable track record of whole HDV emissions, independent from each manufacturer's measurement, providing reliability and transparency to the market as to real vehicle performances. This would be expected to increase awareness among fleet operators on the most cost effective vehicles to operate, and influence decision making in purchasing new HDVs. A second dynamic impact related to increased transparency in the HDV market, is expected to be the creation of an incentive for HDV manufacturers to innovate and to the uptake of fuel efficiency technologies, which in the long term will contribute to an increasing share of more energy efficient heavy-duty vehicles in the fleet. A precise quantification of the impacts of monitoring and reporting over time on HDV CO2 emissions in the EU could not be carried out due to the lack of reliable methodology for such an assessment. However, the simple marker illustrated in Box 1 above provides an indicative benchmark. Assuming over time that the full fleet is purchased in light of more transparent information benefitting from such monitoring, an incremental 1% efficiency improvement in the EU fleet would translate into around 2.1 Mt CO2 emission reductions. Impacts are therefore expected to be favourable. CO2 emissions reductions would be relevant for new vehicles and progressively for the whole HDV fleet. The three options are not expected to have different impacts on CO2 emissions. Stakeholders' view The large majority of stakeholders, who replied to the online public consultation, agree that HDV monitoring and reporting will increase awareness among fleet operators on the most effective vehicles to operate and consequently influence their purchasing decisions. They also agree that its effect on reducing HDV fuel consumption and CO2 emissions will be real but limited. 5.3.2 Other emissions Other environmental impacts considered relate to emissions of air pollutants (particulate matter, nitrogen oxides, un-burnt hydrocarbons and carbon monoxide), which are already regulated under the Euro VI Regulation. As underlined in the impact assessment attached to the 2014 HDV Strategy, favourable but only negligible impacts can be expected. Given that HDV engines are already subject to not-to-exceed limits according to the EURO VI standard for such pollutant emissions, favourable impacts on the overall pollutant emissions from the vehicle can only be expected from efficiency measures outside the engine, e.g. aerodynamic improvements of the cabin. Quantitative estimates cannot be provided at this stage. The three options are not expected to have any differentiated environmental impacts. Stakeholders' view The majority of stakeholders, who replied to the online public consultation, shared the opinion that the increased fuel efficiency of vehicles would lead to some reduction of other non-CO2 emissions. 5.4Impact on competitiveness and innovation Within the EU market, positive impacts on competitiveness and innovation are expected in the medium / long-term, irrespective of the options. Such impacts would be differentiated by sector. 1)Automotive manufacturing industry. As anticipated in the 2014 HDV Strategy impact assessment, no material impacts are expected, even though, to some extent, comparability between manufacturers' vehicles energy efficiency may foster innovation and the industry's competitiveness on the EU internal market. Innovation would be fostered both at the level of component and vehicle manufacturers.

2)Transport operators. The combined cost of vehicle purchase and operation would be expected to be reduced by improved comparability of the HDVs' energy performance, leading to improved performance of transport operators expected to be at least partly passed through to their customers through lower prices, as this is a very competitive industry. 3)Other sectors of the economy. Lower transport costs may (marginally) lead to lower prices of intermediate goods, and thereby to increases in competitiveness of many other segments of the economy. In relative terms on the EU market this would only affect the competitiveness of companies operating in the same market if they have very different shares of transport costs in their product costs. Stakeholders' view The large majority of stakeholders responding to the online public consultation agreed that increased transparency in the HDV sector would improve competition among HDV manufacturers and transport operators. Stakeholders also agreed that marginal positive impacts can be expected in terms of improved competitiveness. 5.5Impacts on third countries and on EU international trade There is not likely to be any direct impact on third countries. Switzerland has in the past largely replicated EU car and light commercial vehicle Regulations and might continue to do so in the future. It is possible that other countries might take inspiration from the EU approach in this field. However, most of the large countries such as the US, China and Japan, have already put in place a system of certification, monitoring and reporting of HDVs emissions. Impacts on EU international trade and investment are expected to be positive in the medium / long-term and differentiated among sectors of the economy: ·Automotive manufacturing industry. As indicated in the competitiveness assessment (annex 10) of the 2013 impact assessment underpinning the 2014 HDV Strategy, the EU HDV industry is highly competitive, has a positive trade surplus and specialisation index in HDV production and trade. Expected improvements in innovation uptakes and the industry's competitiveness would benefit the EU HDV industry's international competitiveness and its global market penetration both through trade or Foreign Direct Investment (FDI) and overseas production. It should also be noted that the other major HDV markets in the world (US, China and Japan) have already enacted HDV CO2 emissions, setting emission standards, leading manufacturers from these other markets to enhance the efficiency of their fleet to comply with the standards. ·Transport operators. While benefitting from improved competitiveness in the EU market, the industry of transport services would not be expected to significantly improve its international position (outside the EU) as differences in labour costs would not be affected. More energy efficient vehicles would also be expected to be available to competitors in neighbouring countries. ·Other sectors of the economy. The above mentioned competitiveness assessment took the view that the implementation of legislative measures to reduce HDV fuel consumption and CO2 emissions may change the costs of intermediate products and hence also the costs of final products through changes in transport costs. For products offered on a global market, the change in transport costs due to measures aimed at reducing HDV CO2 emissions may also affect the global competitive position of European companies. For both situations, however, transport costs are generally a small share of overall product costs. Direct or indirect impacts on EU international trade through changes in the cost price of intermediate and final products will therefore most likely be negligible. Options are not expected to differ with respect to these impacts. Stakeholders' view Most of the stakeholders, respondents to the online public consultation, agree that, if the assumptions above mentioned are fulfilled, the EU HDV industry's international competitiveness and EU exports could marginally benefit. 5.6Impact on SMEs 1)Manufacturing industry In the case of HDV manufacturers, there is no expected impact on SMEs as the main HDV manufacturers are all very large international companies, in particular 6 large manufacturing companies dominate the EU HDV market (see Annex 7). Body and trailer manufacturers are mostly SMEs but no impacts are expected since they are not involved in the monitoring and reporting. In the first stage of certification, trailers and body will be included in the VECTO simulation using default values. 2)Transport operators Transport companies, most of which are SMEs (see Annex 7) operating only a few trucks or buses, would benefit from the monitoring of emissions as this would provide more transparency on the fuel consumption performance of HDVs. The transport companies will be able to take this information into consideration in their purchasing decisions, thereby realising fuel savings and reducing their operating costs.

The economic impact for transport operators is subject to the evolution of fuel prices. An assessment of mid-2015 (i.e. when oil prices were around 60 USD/barrel) estimated fuel to represent between 26% and 36% of transport operators costs, with variations to the category of vehicle and cycle. Another assessment by the French Fédération Nationale du Transport Routier suggests lower fuel relative costs in 2016 between 14.3 and 20.7% of operating costs (see Annex 8) as a result of the recent fall in oil prices. The Freight Transport Association (FTA) in the UK estimated in July 2016 that fuel costs represented a percentage ranging between 17 and 32% of total annual vehicle operating costs, depending on mileage and gross vehicle weight. The Comité National Routier (CNR) estimated the share of fuel costs of total operating costs for a heavy-duty vehicle of 40tonnes to be 21.1% for regional delivery and 23.1% for long haul in December 2016. While these operating costs follow fuel price developments, this points to fuel operating costs that represent a very significant share of transporters' overall costs. Depending on the penetration of fuel efficient HDVs, the impact may be significant on transport prices as well, given the highly competitive situation in the transport industry. This suggests that with high penetration the fuel cost saving is expected to be passed through to transport end-users. Options are not expected to have differentiated impacts in this respect. Stakeholders' view The vast majority of stakeholders, respondents to the online public consultation, agree that transport companies, most of which are small SMEs, are expected to benefit from the monitoring of fuel consumption and CO2 emissions from HDVs.



6.How do the options compare? 6.1Effectiveness Against the general policy objectives: 1) Facilitate a reduction in fuel costs for transport operators All options would make available to transport operators data on fuel consumption and CO2 emissions from new HDVs placed on the EU market, through the publication of a database where vehicle efficiency could be compared. Regardless of the option chosen, transport operators will benefit from the information available, which will influence their purchasing decision towards the vehicles that would allow the highest fuel savings for their specific operations. 2) Contribute to the improvement of the competitiveness of HDV manufacturers Providing information on fuel consumption and CO2 emissions will create an additional incentive for HDV manufacturers to invest in innovation in order to put on the market more fuel efficient technologies and vehicles, improving their competitiveness worldwide. This is the case for all of the options. 3) Contribute to the achievement of the EU's climate and energy targets and objectives All options would make available data on fuel consumption and CO2 emissions to policy makers, providing a baseline for policy action to reduce HDV emissions and also a tool for implementation and enforcement of future CO2 emission standards. Against the specific objectives: ·Enable informed purchasing decisions and deployment of more fuel efficient vehicles ·Foster innovation and development of fuel efficiency technologies ·Promote cost-effective reductions of CO2 emissions and reduce overall fuel consumption from HDVs

·Enable the development of rational policies promoting the uptake of advanced fuel efficient and low emission HDVs All options would provide for information on fuel consumption and CO2 emissions per vehicle and would allow comparing the performance of new vehicles placed on the EU market from various manufacturers by market segment. However, option 2 is considered to meet the specific objectives only partly, as it will not provide information at the level of each Member State. The HDV monitoring data reported by manufacturers would be based on the vehicles sold. Registration information held by national authorities would not be provided under this option. As a result, the reported emissions data could not be allocated to a particular Member State. This would make it more difficult for Member States to design effective national policies to increase the uptake of more efficient HDVs. Option 2 is in this respect less effective than options 1 and 3, under which Member States' HDV emissions would be satisfactorily covered through the registration data provided to the EC/EEA by their national authorities. Options 1 and 3 are equally effective in meeting all specific objectives, since they would equally contribute to market transparency, overcoming the main market barrier identified i.e. the lack of information on the most efficient vehicles. Option 1 is less effective than option 3 in meeting the last specific objective of enabling the development of rational policies promoting the uptake of advanced fuel efficient and low emission HDVs. This is due to the risks concerning the quality of the data. Under option 1, the digital flow of information may be interrupted if national registration authorities operate in a non- or partly digitalised mode. This may cause errors in reporting the monitoring data to the EEA. This risk does not materialise under option 3 as the data flow will be fully digitalised. Under option 3, the possible risks of errors identified relate to the EEA matching each vehicle's registration data provided by Member States with the corresponding monitoring data reported by manufacturers. These risks will be mitigated through the implementation of a quality assurance and quality check (QA/QC) process by the EEA, for example performing checks on: ­the completeness of the data; ­the variability; ­the plausibility, in order to identify outliers (e.g. vehicles with similar characteristics and very different emissions). Similar mitigation measures have been put in place successfully by the EEA for the monitoring and reporting of CO2 emissions from vans (see Annex 8). In light of the above, option 3 is considered the most effective option in meeting the specific objectives. 6.2Efficiency The main efficiency criterion that is being considered is the administrative costs. This costing exercise exhibits a quite significant difference between option 1, which turns out to be the most costly, and the two others, that have modest cost implications. The main reason for this lies in the current state of play, in which registration is in most countries not a digitalised process. The cost assessment has assumed that digitalisation would be required. Significant costs are therefore anticipated for establishing the necessary digitalised IT procedures and database systems, mainly for Member States, and more limited costs for manufacturers to adapt to possible shortcomings in the transmission chain of digital data. While overall relatively moderate in view of the size of the EU economy, option 1 costs are high for Member States considering the available resources of the relevant authorities. In the case of options 2 and 3, costs would be minimal for Member States. Authorities in the Member States are not involved for option 2, and only have to submit one monitoring parameter, i.e. the Vehicle Identification Number (VIN) for option 3. Manufacturers would not face high costs either, as they will have to set up the necessary databases to implement the certification obligations. The main costs lie with the EC/EEA, which is in charge of processing the data, publishing them and reporting. 6.3Proportionality In view of its necessity and potential magnitude of the economic benefits, EU monitoring envisaged in the three options would meet proportionality requirements: at the EU scale, efforts needed are rather limited and costs reported above almost negligible compared with potential benefits. In addition, the costs estimated per vehicle for the options rank between €1 for option 3 and €5 for option 1, which compared to the cost of a vehicle (in the order of hundred thousand euros) and to the annual fuel cost (in average estimated above €20.000 per vehicle) can be considered as negligible. Saving 1 litre of fuel from around 30.000 litres consumed in average per year by a vehicle would be enough to cover the total administrative costs related to the monitoring of this vehicle.

6.4Subsidiarity In all cases, EU-level action is deemed superior to fragmented national initiatives to monitor HDV fuel consumption and CO2 emission. 6.5Coherence with other mainstream EU policies Options 1 and 3 are expected to rank equally in addressing the identified knowledge gap and in providing accurate and complete information on CO2 emissions from HDVs in the EU to serve as baseline for future policy action. Option 2 would instead be expected to provide a less complete baseline, lacking the geographical distribution of emissions. Option 2 would therefore risk a lower level of coherence with the main EU policies concerning GHG emissions from transport as it would not provide data at the Member States level. This could lead to inconsistencies and inefficiencies when implementing key EU policies: the European Strategy for low-emission mobility , the review of the "Eurovignette" Directive and the Effort Sharing Regulation setting 2030 national targets for GHG emissions in non-ETS sectors, including transport. 6.6Stakeholders' views The majority of stakeholders agree that manufacturers of heavy-duty vehicles and public authorities should share the administrative burden of monitoring HDV fuel consumption and CO2 emissions. Most of the stakeholders, across all categories, expressed a preference for option 3, pointing out that the administrative burden of monitoring and reporting is shared between manufacturers and Member States' authorities and that the digital flow of data is ensured. 6.7Conclusions Table 5 provides an illustration on how the options compare and rank based on the explanations given in the previous paragraphs.



Option 1

national authorities reporting to EC/EEA Option 2

manufacturers reporting to EC/EEA Option 3

Mixed: national authorities/manufacturers reporting to EC/EEA Effectiveness

in meeting objectives + Objectives are expected to be met under this option, however there are risks for the integrity of the monitoring data due to the possible interruption of the digital flow of information during the reporting - Objectives are expected to be partly met with an important caveat: manufacturer's monitoring data would be sales-based and would not include national registration data. This option would hence not provide full set of information at EU level nor at Member State level ++ Objectives are expected to be met under this option Efficiency (proportionality of effort, in particular costs, needed to reach objectives) =

This option is the most costly, but its overall cost remains moderate (to keep the continuous flow of digital monitoring data national authorities would need to make significant investments as a large number of them currently process data with paper) ++

This option has a zero cost for national authorities, and a moderate one for manufacturers as well as the EC/EEA ++ This option has only a marginal cost for national authorities, and a moderate one for manufacturers as well as the EC/EEA Stakeholders views + Option considered as possible by around 30% of the stakeholders. However not favored by many of them in view of its costs, the interruption of the digital flow of information and hence its low efficiency - Option considered as possible but not favored by most stakeholders given its burden falling exclusively on HDV manufacturers and the lack of MS data coverage ++

Option favored by most of stakeholders (above 40%) in view of its good efficiency and effectiveness Subsidiarity ++ EU scheme superior to aggregation of national ones + EU scheme superior to aggregation of national ones, however limited information hampers development of national policies ++ EU scheme superior to aggregation of national ones Coherence with other mainstream EU policies ++ Option expected to contribute to the broader EU objectives and mainstream policies - Option expected to contribute in a less effective way to the broader EU objectives and mainstream policies ++ Option expected to contribute to the broader EU objectives and mainstream policies Ranking 2 3 1 In view of this assessment, Option 3 is the preferred option for the following key reasons: 1)Its administrative cost is modest compared to the more costly option (option 1) and comparable to the cost of option 2. 2)It is more effective than options 1 and 2 as it ensures the digital flow of information and provides for the expected degree of reliability of national data. 3)This option meets subsidiarity requirements. Given the latter three criteria findings, it is the option that is the most proportionate in view of effort needed compared with effectiveness in meeting objectives. In the stakeholders' consultation it appeared as the most favoured option by the majority of stakeholders, from all categories. On other criteria, namely the economic and social impacts, environmental impacts, addressing market barriers, and possible effects for SMEs this option appears as effective as options 1 and 2. The option 3 also meets all the general, specific and operational objectives.

It should thus be concluded from the present Impact Assessment that this option should be the one retained in the upcoming regulation on monitoring and reporting HDV CO2 emissions and fuel consumption. A fully-fledged new legislative basis, under the ordinary (co-decision) legislative approval procedure will be required to establish such monitoring and reporting. 7.How would actual impacts be monitored and evaluated? In order to monitor and evaluate the progress made towards the operational objectives of this monitoring and reporting initiative, the following four indicators are proposed: 1)Average annual CO2 emissions and fuel consumption per vehicle group, manufacturer and Member State from new HDVs registered in the EU within the scope of the certification legislation. This indicator should be calculated each year by the European Environment Agency based on the reported data for the retained option. Over time, it will give an indication on the amount of fuels saved and the reduced costs for operators. 2)Comparison of average annual CO2 emissions and fuel consumption of the same group of vehicles across different years. This indicator should be calculated every year by the European Environment Agency based on the reported data for the retained option. Over the time it would help monitor and evaluate progress towards the three general policy objectives, indicating the uptake of more fuel efficient vehicles, and in particular showing each year the rate of annual efficiency improvement in each vehicle group, i.e. whether new vehicles in the same group have an increased fuel efficiency and lower CO2 emissions. It would also demonstrate the level of innovativeness of the manufacturing industry and the acceptance by transport operators. 3)Annual overview of fuel efficiency technologies fitted in the new vehicles and their penetration level. This indicator should be calculated each year by the European Environment Agency based on the reported data for the retained option. The results of this monitoring will enable better design of emission reduction measures, and especially the further development of CO2 emission standards, providing knowledge about technology development and penetration level in the fleet and therefore allowing a more accurate estimation of the level of ambition for such measures. It would also be an indicator of overall innovation in the manufacturing industry. 4)Exports and imports of HDVs This indicator would give an indication on the competitive position of EU HDV manufacturers, based on data being collected via EUROSTAT.



Annex 1 - Procedural information 1.Organisation and Timing The Directorate-General (DG) for Climate Action was leading the preparation of this initiative and the work on the impact assessment in the European Commission. An inter-service steering group (ISG), chaired by DG Climate Action and the Secretariat-General, was established in December 2015 on CO2 emissions from road vehicles and was tasked of preparing this initiative. The ISG met four times in the period from December 2015 to February 2017. The following Directorates-General (DGs) participated in the work of the group: Secretariat-General (SG), Legal Service (SJ), DG GROW, DG MOVE, DG ECFIN, DG ENER, DG ENV, DG JUST, DG RTD, JRC, DG TAXUD, DG CNECT, DG COMP. The EEA was also consulted. An indicative roadmap was adopted in July 2016. An online public consultation took place from 20 July to 28 October 2016 (see Annex 2). A stakeholder consultation meeting took place on 17 October 2016. 2.Consultation of the Regulatory Scrutiny Board

The Regulatory Scrutiny Board received the draft version of the present impact assessment report on 24 February 2017 and following the Board meeting on 22 March 2017 issued a positive opinion on 24 March 2017. The Board made recommendations. Those were addressed in the revised IA report as follows: RSB recommendations Modification of the IA report 1) The introduction is not sufficiently clear on the context and scope of the impact assessment. Explanation of interlinked prior and future decisions on emission reporting and certification regulation is inadequate. Explanations have been added in the first section to clarify what decisions had already been taken in the past, concerning the development of a simulation tool and a certification procedure for CO2 emissions and fuel consumption from new HDVs, and how future decisions, in particular on CO2 emission standards for HDVs, are linked with this initiative on monitoring and reporting HDV CO2 emissions. 2) Data sensitivity and the potential market-disruptive risks relating to the monitoring and data collecting system lack assessment. Section 4.1.4 has been expanded to provide considerations on the risks related to the publication of monitoring data for the EU HDV market. 3) The differences in digitalisation costs between options lack specificity. Sections 4.3 and 5.1.2 have been further elaborated to provide more details about the costs of each option. 3.Evidence and external expertise used The cost assessment of the different monitoring and reporting options was carried out by CE Delft. The CE Delft study is largely based on interviews to national registration authorities and HDV manufacturers, in order to collect their opinion about various monitoring options and receive targeted input with regard to the costs for their organisation, taking into account the current procedures and required adaptations. Moreover, the IA relies on the previous Impact Assessment from 2014 accompanying the Strategy for Reducing Heavy-Duty Vehicles Fuel Consumption and CO2 Emissions, in relation to the assessment of the other impacts.



Annex 2 - Stakeholder consultation 1.Process and quantitative results of the public consultation The European Commission organised a public online consultation from 20 July to 28 October 2016, i.e. 12 weeks, on the preparation of legislation on monitoring and reporting of Heavy-Duty Vehicle fuel consumption and CO2 emissions . The Part A of the consultation sought input on how to monitor and report fuel consumption and CO2 emissions from heavy-duty vehicles, with questions concerning the need of action, the objectives, the options and their anticipated impacts. Part B of the consultation focused on requesting general feedback on the need and design of CO2 emissions and fuel efficiency standards. The public consultation was carried out using the “General principles and minimum standards for consultation of interested parties by the Commission”. The consultation received responses among others from professional organisations, private enterprises, civil society organisations, public authorities, international organisations, individuals/private persons and 'others'. This analysis will only focus on the replies to Part A of the online consultation as directly linked to the initiative on monitoring and reporting HDV CO2 emissions and fuel consumption that this impact assessment aims to underpin. Replies to Part B of the online consultation will be analysed in the frame of the future impact assessment on HDV CO2 emission standards. Part A of the public consultation consisted of a questionnaire in English with twelve main questions, ten multiple choices (in some cases articulated) and two spaces limited to 2 000 characters for additional comments. This report follows the structure of the questions in the consultation questionnaire. The individual stakeholder submissions can be downloaded on the consultation website for those stakeholders that gave their consent to publication (either under the given name or anonymously), whereas 6 submissions are not available either because missing publication consent or because received in a modified format. Main conclusions from the consultation replies can be summarised as follows: ­general agreement with the need of action at EU level to monitor vehicle efficiency to close the identified knowledge gap; ­broad support of the objectives put forward, especially reducing HDV fuel consumption and CO2 emissions, improving market transparency in the HDV sector and ensuring competitiveness of the European HDV manufacturing sector; ­option 3, i.e. mixed reporting by national authorities and HDV manufacturers, is considered as the most appropriate option by most stakeholders, followed by option1, i.e. national authorities reporting; ­broad agreement with the expectation of a positive although limited economic impact; ­increased transparency in the HDV market is expected to contribute to an improved level playing field among HDV manufacturers and the available comparability is likely to foster innovation; ­a marginal increased competitiveness of the transport sector is expected by the majority of stakeholders, as a result of lower transport costs due to more fuel efficient vehicles placed in the market; ­fleet operators, and in particular SMEs, are anticipated to benefit from the monitoring, since they will be able to take more informed purchasing decisions concerning the fuel efficiency of the vehicles;

­the administrative burden of monitoring and reporting HDV CO2 emissions and fuel consumption should be shared between national authorities and HDV manufacturers, according to the majority of respondents; ­real but limited effects on reducing CO2 emissions are expected from the initiative, as well as limited reductions in non-CO2 emissions. 2.Stakeholders' participation in the public consultation The Commission received 121 formal replies from a broad spectrum of stakeholders as shown in Table 1, three of which were received by email and not through the EU Voice website. Stakeholder category Number of responses % of responses Professional organisation 32 26% Private enterprise 21 17% Civil society organisation 20 16.5% Other 20 16.5% Public authority 12 10% International organisation 9 7% As an individual / private person 6 5% Academic / Research institution 1 1% Grand Total 121 100% Notes: Other includes: one employers' association, 2 trade associations, 5 automotive/and body builders industries, one association for manufactures, one industry association, 3 business organisations, one sector association, one alliance of private companies operating in the logistics industry, one public company, one company, 2 non-governmental organisations and one non-profit organisation. A number of coordinated responses were received, indicating that respondents followed a common answer, although with different degrees of variations. Since respondents were free to adapt the answers to correspond with their own views all responses have been analysed individually in the following sections. Responses were received from organisations based in, or respondents residing in, 19 EU Member States (Austria, Belgium, Czech Republic, Denmark, Finland, France, Germany, Hungary, Ireland, Italy, Latvia, Netherlands, Poland, Portugal, Romania, Slovenia, Spain, Sweden and the United Kingdom), while few responses were also received from other non-EU locations such as Norway and the United States. The highest number of responses came from organisations residing in Belgium, followed by respondents from Germany, France and the United Kingdom, as shown in Table 2.



Country of residence/establishment Number of responses Belgium 29 Germany 13 France 10 United Kingdom 8 Austria 7 Netherlands 7 Sweden 7 Hungary 6 3.Responses to the individual questions Need of action All stakeholders, but one that gave no answer, agreed that monitoring vehicle efficiency (both in terms of fuel consumption and CO2 emissions) in the EU is important in order to gather the necessary data to close the identified knowledge gap, with 70% of the respondents considering it as very important. The majority of respondents (56%) were of the opinion that if no action is taken at EU level, monitoring of HDV CO2 emissions would likely not take place. Only 25% of the respondents were of opposite views, with 18% being neutral. 44% of the respondents believed that Member States would separately take the necessary measures to monitor and report HDV CO2 emissions in case of no action at EU level, whereas 27% saw this as unlikely, in particular most of the public authorities, and 26% were neutral. Objectives All stakeholders, but one that gave no answer, agreed that objective 1 'reducing fuel consumption and HDV CO2 emissions' is important, with 86% of the respondents considering it as very important.

Most of the stakeholders considered objective 2 'Improving market transparency in the HDV sector' as important, however with a lower number of respondents considering it as very important (58%). Stakeholders' opinions are more mixed regarding objective 3 'Improving road transport competitiveness', with the vast majority recognising it as important, but 12% of stakeholders belonging to different categories indicated it as not important. Almost all stakeholders agreed that objective 4 'Ensuring competitiveness of the European HDV manufacturing sector' is important, with 47% of the respondents considering it as very important. Options Option 1 is deemed the most appropriate option for monitoring and reporting HDV CO2 emissions and fuel consumption by 31% of the respondents, belonging mostly to professional organisations (10 respondents, among which organisations dealing with transport and logistics), private enterprises (7 respondents, including component manufacturers), 'other' (business/ industry/ trade associations, 6 respondents), civil society organisations (6 respondents) and public authorities (5 respondents). Option 2 is the most appropriate option according to 12% of the respondents, mainly from professional organisations (8 respondents, mainly representing shippers), 2 private enterprises, 2 international organisations, 2 'other' (non-governmental organisations) and 1 public authority. Option 3 is considered as the most appropriate by the highest