EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 
SEC(2008) 1908 
COMMISSION STAFF WORKING DOCUMENT 
 
Accompanying the  
Proposal for a 
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
concerning type-approval requirements for the general safety of motor vehicles 
  
Impact Assessment  
{COM(2008) 316} 
{SEC(2008) 1909} 
 
EN 2   EN Table of contents 
 
1. PROBLEM DEFINITION ........................................................................................... 5 1.1. Simplification............................................................................................................ ... 5 
1.2. Advanced Safety Features............................................................................................ 6 1.2.1. Electronic Stability Control.......................................................................................... 7 1.2.2. Advanced Emergency Braking Systems (AEBS) ........................................................ 7 1.2.3. Lane Departure Warning Systems (LDW)................................................................... 8 1.3. Tyres..................................................................................................................... ........ 8 
1.3.1. Rolling Noise Emissions. ............................................................................................. 9 1.3.2. Tyre Rolling Resistance ............................................................................................. 11 1.3.3. Tyre Pressure Monitoring Systems ............................................................................ 12 1.3.4. Wet Grip Performance ............................................................................................... 13 2. objectives.................................................................................................................. .. 14 
3. 3. Policy Options........................................................................................................ 15 3.1. Simplification aspects ................................................................................................ 15 3.2. Advanced Vehicle Technologies................................................................................ 15 
3.3. Tyres and Tyre Systems ............................................................................................. 16 
3.4. Subsidiarity and Proportionality................................................................................. 19 4. Analysis.................................................................................................................... .. 20 
4.1. Simplification............................................................................................................ . 20 
4.2. Advanced safety features ........................................................................................... 22 4.2.1. Electronic Stability Control........................................................................................ 22 4.2.1.1. Light Vehicles ........................................................................................................ .... 22 
4.2.1.1.1 Benefits............................................................................................................. ......... 22 
4.2.1.1.2 Costs ................................................................................................................ .......... 24 
4.2.1.2. Heavy Vehicles ........................................................................................................ .. 24 
4.2.1.2.1 Benefits............................................................................................................. ......... 24 
4.2.1.2.2 Costs ................................................................................................................ .......... 25 
4.2.1.3. Options for the Introduction of ESC .......................................................................... 25 
 
EN 3   EN 4.2.2. Advanced Emergency Braking Systems (AEBS) ...................................................... 25 
4.2.2.1. Benefits.............................................................................................................. ......... 25 
4.2.2.2. Costs................................................................................................................. .......... 26 
4.2.2.3. Options for the Introduction of AEBS ....................................................................... 27 4.2.3. Lane Departure Warning Systems.............................................................................. 28 4.2.3.1. Benefits.............................................................................................................. ......... 28 
4.2.3.2. Costs................................................................................................................. .......... 28 
4.2.3.3. Options for Lane Departure Warning Systems. ......................................................... 28 4.3. Tyres and Tyre Systems ............................................................................................. 29 4.3.1. Tyre Noise.............................................................................................................. .... 29 
4.3.1.1. Benefits from Reduced Tyre Noise............................................................................ 30 4.3.1.2. Valuation of benefits from new noise limits for C1 tyres .......................................... 31 4.3.1.3. Costs of Tyre Noise Reductions................................................................................. 32 4.3.1.4. Options for Reducing Tyre Noise .............................................................................. 35 4.3.1.4.1 C1 (car) tyres ....................................................................................................... ...... 35 
4.3.1.4.2 Commercial Vehicle Tyres (C2 and C3)................................................................... 38 4.3.1.4.3. Additional Options .................................................................................................. . 41 
4.3.2. Tyre Rolling Resistance ............................................................................................. 42 
4.3.2.1. Calculation of Benefits at the Vehicle Level ............................................................. 42 
4.3.2.2. Calculation of Costs at  the Vehicle Level.................................................................. 43 
4.3.2.3. Options for Introducing Tyre Ro lling Resistance Requirements ............................... 43 
4.3.2.3.1 Car Tyres ............................................................................................................ ....... 43 
4.3.2.3.2 Commercial vehicle tyres.......................................................................................... 45 4.3.2.3.3. Labelling........................................................................................................... ........ 45 
4.3.3. Tyre Pressure Monitoring Systems ............................................................................ 46 4.3.3.1. Benefits.............................................................................................................. ......... 46 
4.3.3.1.1. Safety Benefits ..................................................................................................... .... 46 
4.3.1.1.2. CO2/ fuel saving benefits. ........................................................................................ 46  
4.3.3.2. Costs................................................................................................................. .......... 46 
4.3.3.3. Options for introducing Tyre Pr essure Monitoring Systems ..................................... 46 
 
EN 4   EN 4.3.4 Wet Grip Requirements  
4.3.4.1. Benefits.............................................................................................................. ......... 47 
4.3.4.2. Costs................................................................................................................. .......... 47 
4.3.4.3. Options for Introducing Wet Grip Requirements....................................................... 48 5. Monitoring and evaluation ......................................................................................... 48 6. procedural issues and consulta tion of interested parties ............................................ 48 
6.1. Internet Consultation.................................................................................................. 48 6.2. Opinion of the Impact Assessment Board.................................................................. 51 ANNEX I Potential casualty savings achie vable through various technologies...................... 52 
ANNEX II SUMMARY OF COSTS AND BENEFITS PER VEHICLE ............................... 53 ANNEX III ...................................................................................................................... ......... 57 
Consideration of the production, employment a nd affordability effects of the proposalS 
CoVered by this impact assessment ........................................................................... 57 
 
EN 5   EN 1. PROBLEM  DEFINITION 
In order to meet the European Union's safety and environmental objectives, there is a 
continual need to update the various regulatio ns that apply to ne w vehicle construction. 
However, there is an equal need to lim it the regulatory burden on industry, and to 
simplify existing legislation wherever possi ble. New technologies  are now available 
which can dramatically improve  vehicle safety (such as vehicle stability control) or 
reduce CO2 emissions (such as low rolling-resistance tyres) 
European Community Directives concerni ng the type-approval of motor vehicle 
components and systems have been progr essively introduced since 1970, under the 
framework of Community Direc tive 70/156/EEC. Over the last 35 years, the nature of the 
regime has evolved from being a system designed to allow free trade of vehicle components between Member States, to a sy stem based on compulsory whole-vehicle 
type-approval (WVTA) for most categories of vehicle. WVTA requires a series of 
approvals to the component or system Dir ectives, or equivalent standards which are 
produced by the United Nations Economic  Commission for Europe (UNECE). These 
Directives and Regulations have been upda ted over the years to  reflect technical 
progress, so that there are now around 50 base Direc tives and over 100 amending 
Directives covering this subject area. Th is duality of EC Directives and UNECE 
Regulations is confusing, unnecessary  and wasteful of resources.  
Advances in vehicle technology in the areas of braking, vehi cle stability, sensing systems 
and tyre technology offer the potential for significant pr ogress in these areas. Some 
advanced systems, such as vehicle stability control and tyre pressure monitoring systems, are already being offered by ve hicle manufacturers. One ar ea of particular importance 
concerns vehicle tyres. Tyres ar e critical to the safety performance of a vehicle since they 
represent the only contact between the vehicle and the road. They are also partially responsible for the level of traffic noise, and they can have a considerable impact on the 
fuel consumption of a ve hicle, and hence its CO
2 emissions. 
The purpose of this Impact Assessment is to  examine the various issues concerning the 
current type-approval regime for vehicle sa fety, particularly the areas that can be 
simplified and the areas where additional measur es may be appropriate  in order to meet 
safety and environmental objectives. 
Hence the Impact Assessment is structured so that the three main elements of the 
proposal are considered separately, i.e. 
1) Simplification aspects 2) Advanced Safety Systems 3) Tyres  
1.1. Simplification 
The original vehicle type-approval fram ework Directive, 70/156/EEC has now been 
recast as 2007/46/EC to reflect the evolution of the vehicle type-approval procedure in 
 
EN 6   EN recent years. In addition, the requirements c overing vehicle emissions have been updated 
and consolidated into new Council and Parl iament Regulations which are directly 
applicable in Member States. However, many of the original safety-related Directives are around 35 years old, and although some have been  updated a number of times, the result 
is that there are many unconsolidated amendments which are complicated to interpret and, due to the effort involved in produci ng amendments, do not always represent the 
most recent state of technology. It  is likely that in the future  this situation will worsen. 
In 2006 the CARS 21 group
1 recommended that 38 EC Direct ives should be replaced by 
equivalent UNECE Regulations in order to simplify the regulatory regime. UNECE 
Regulations are widely accepted in countries inside and outside the EU, and the EU is 
itself a contracting party to many of these Re gulations. Therefore there is little point in 
the EU retaining and constantly updating its own Directives, unless there are particular 
aspects which are not covered, or are in sufficiently covered, by UNECE Regulations. 
Therefore it is proposed that the requirements set out in these direct ives will be carried 
over by this Regulation and its implementing measures to this Regulation and will be replaced, where appropriate, with referenc es to the corresponding regulations of the 
United Nations Economic Commission for Europe 
The proposal will affect vehi cle and component manufacturer s, national administrations 
and test authorities. All should benefit to va rying extents from the greater clarity of the 
legislation, and national administrations will benefit from reduced workload transposing 
Directives into national regulations.  
1.2. Advanced Safety Features 
Advances in vehicle design, including the provision of seat belts and airbags and 
improvements in crashworthiness, have led to considerable casualty reductions in recent 
years. However, future increases in road tr affic will make it difficult to meet future 
casualty reduction targets unless more advan ced accident avoidance technologies can be 
introduced. Although market forces are alre ady encouraging the introduction of new 
technologies in some vehicles, it is possible th at legislation will be required to speed their 
introduction. In general, advanced features are initially introduced as options on high-
specification cars, and eventually  filter down to cars at th e low-budget end of the market. 
However, the situation varies considerably between one Member St ate and another, and 
it is possible that, due to cost reasons and the fact that some  buyers do not consider safety 
as a high priority when making a purchasin g decision, some 'entry-level' models will 
never be equipped with a feature unless it is compulsory. There may therefore be 
justification to introduce manda tory requirements for advanced  vehicle safety systems, 
where such requirements are technically and eco nomically feasible and can be justified in 
terms of projected casualty savings. Annex I shows the potential savings in deaths and 
serious injuries that can be obtained by vari ous safety technologies. As can be seen, a 
high proportion of these savings  can be achieved by means of the measures envisaged in 
this document, and discussed in the followi ng sections. The measures in Annex I not 
specifically covered by this proposal ar e either covered under other framework 
legislation or covered unde r this proposal via UNECE legislation. For example, 
Pedestrian Protection is covered by a se parate proposal which was adopted by the 
                                                
 
1 Competitive Automotive Regulatory System for the 21st Century. 
 
EN 7   EN Commission in 2007. ABS braking on motorcycle s would be covered under the separate 
motorcycle framework Directive. Daytime r unning lights, conspicuity markings and seat 
belt reminder systems are being covered by amendments to the relevant UNECE 
Regulations which would be referenced und er implementing regul ations under this 
proposal. 
Where possible, the detailed technical specificat ions of advanced safe ty systems will be 
based on UNECE Regulations or other internati onal standards. The first systems likely to 
be covered are Electronic Stability Control (ESC), Advanced Emergency Braking (AEB) 
and Lane Departure Warning systems (LDW) described in 1.2.1 to 1.2.3. Tyre Pressure 
Monitoring Systems can also be described as  advanced safety systems but they are 
discussed under the tyres secti on (1.3.3). Other systems might be included at a later date. 
The beneficiaries would be the road users in general. The costs would fall initially to 
vehicle manufacturers, but would be lik ely to be passed on to vehicle buyers. 
1.2.1.  Electronic Stability Control  
Electronic stability control (ESC) systems act on the braking or power systems of a 
vehicle to assist the driver in maintaining c ontrol of the vehicle in a critical situation 
(caused, for example, by poor road conditions  or excessive speed during cornering). ESC 
usually acts by sensing wheel slip in indi vidual wheels and reducing power or applying 
braking to one or more wheels to regain st ability. ESC can reduce accidents by more than 
20 percent in normal conditions and more than 30 percent in wet or icy conditions. It has 
been available on some cars for around 10 year s, and costs have been reducing due to 
improved technology and increased volumes. Th e market penetration of ESC in cars 
varies greatly between Member States. Recent figures2 suggest that, on average, 43 
percent of cars in the 'supermini' class ar e offered with ESC as standard in Denmark 
compared with only 3 percent in Malta. In th e case of small family cars, 83 percent are 
offered with ESC as standard in Denmark compared with only 35 percent in Ireland. 
For heavy commercial vehicles, there is less customer demand, possibly for cost reasons 
and possibly because drivers of heavy vehicles are considered to be less vulnerable in an 
accident and less likely to benefit from ESC (although some of the main beneficiaries 
may be the occupants of smaller vehicles w ho are less likely to be struck by a large 
vehicle equipped with ESC). T hus in these cases the market  mechanism alone may not be 
sufficient to bring about improvements in safety. 
Separate technical standards for light and heavy vehicle ESC have been under 
development within the UNECE. Decisions need  to be made on how these new standards 
will be applied in the European Union. 
1.2.2.  Advanced Emergency Braking Systems (AEBS) 
Some vehicles are already fitted with sy stems which employ sensors to monitor the 
proximity of the vehicle in front and det ect situations where the relative speed and 
distance between the two vehi cles suggest that a collisi on is imminent. In such a 
situation, emergency braking can be automatical ly applied and the eff ects of the collision 
                                                 
2 Figures from the 'choose ESC website 
http://www.chooseesc.eu/download/press/Eu roNCAP%208_May%20ESC%20Brochure.pdf 
 
EN 8   EN are either mitigated or avoided altogether . The capability of such systems could be 
expanded in the future to cover other types of  accident (for example, pedestrian accidents 
or even head-on collisions). Preliminary studies suggest that such systems could ultimately save around 5000 fatalities and 50,000 se rious injuries per year across the EU. 
It is likely that due to the technical challenges involved, these systems will only be ready for installation on the whole range  of new vehicles in a few years time. However, it is 
already possible to provide estimates of the likely costs and benefits of such systems. 
1.2.3.  Lane Departure Warning Systems (LDW)  
Lane Departure Warning (LDW) Systems assist  drivers in keeping their lanes by warning 
drivers when their vehicle is in  danger of leaving the lane unintentionally (mainly due to 
lack of driver attention). Current systems use either an audible beep  or a "rumble strips" 
noise, which mimics the sound made when the ty re runs over a lane divider or road edge 
marking. 
A supplement to the LDW system is the lane change assistant (LCA) system. This assists 
drivers intending to change lanes. The lane change assistant monitors the adjacent lanes and warns the driver if another vehicle is like ly to come within colliding distance during 
the lane change. This occurs for example, if the other vehicle is located in the LCA 
equipped vehicle's blind spot. Presently the system would warn the driver of such a 
problem with e.g. a red flashing side mirror.  Later on, a system with feedback in the 
steering wheel could be introduced . The lane change assistant needs predictive sensors to 
scan the surrounding vehicles. The sensors might  possibly be integrated with the sensors 
used on a AEBS system.  
1.3. Tyres 
The current type-approval Directive on vehicl e tyres (92/23/EEC) covers specifications 
relating to the approval of new tyres as com ponents, and requirements for the equipment 
of new vehicles with suitable tyres. The requirements are mostly related to tyre safety, but the Directive was amended in 2001 (2001/ 43/EEC) to cover additional requirements 
to limit tyre rolling noise emissions. The in itial noise limit values  agreed in 2001 were 
subject to a review, to assess whether it was possible to introduce tighter noise emission 
values without compromising other essential aspects of tyre design. This review has now 
been completed, and new noise limit values have been recommended. 
In addition, as part of the Commission's CO
2 reduction strategy, tyres have been 
identified as potential sources for improve ments in vehicle fuel economy (and hence 
reductions in CO 2 emissions). In particular, the us e of low rolling-resistance tyres can 
significantly reduce fuel consumption, and the use of tyre pressure monitoring systems 
(TPMS) can ensure that tyres remain inflated  to the optimum pressu re to maximise fuel 
economy. TPMS can also offer safety benefits by providing the driver with a warning of 
any significant deflation in one or more of the vehicle tyres. 
Studies have shown that it is possible to improve the noise and fuel economy 
performance of tyres without necessarily affecting their sa fety. However, safety is 
paramount and it is essential that existing sa fety standards are not compromised. Since it 
is recognised that it could be possible for manufactures to meet, say, more stringent 
rolling resistance requirements by designing a tyre which has poor grip performance 
 
EN 9   EN (particularly in the wet), it is considered that new car tyres should also be subject to wet 
grip performance requirements to ensure that this aspect is not overlooked in the pursuit 
of more energy-efficient, quiet er tyres. Consequently ther e are four areas where it is 
considered necessary to introduce new performance requirements for tyres: 
- tighter noise emission requirements, -new rolling resistance requirements, -the introduction of TPMS to vehicles, and  - new wet-grip requirements. It is intended to treat the above measures as a package, since they are inter-related. 
However, since it is possible that different regulatory solutions may be appropriate for 
different elements of the package, the different  elements are considered separately within 
this Impact Assessment.  
Further details of the four elements  of the package are given below. 
1.3.1.  Rolling Noise Emissions. 
Road-traffic is perceived by the population to  be the biggest source of noise pollution. 
Above a vehicle speed of 40 to 50 km/h, rolling noise is the dominant component of road traffic noise. It is already widely recognized that the noise exposure is a serious limiting 
factor for people’s quality of life, but recent research has highlighted the harmful effects 
noise exposure may have on people’s health. In  addition, impaired sleep may also have 
effects on work efficiency a nd learning efficiency at sch ools. Reducing the level of 
tyre/road noise thus represents an effectiv e approach for protecting the population from 
noise. An integrated approach, involving the use of low-noise road surfaces and low-noise tyres is seen as being best means of achieving this. The Direct orate General for the 
Environment has been involved, together with other stakeholders, in work to investigate 
the use of low-noise road surfaces. The Dire ctorate General for Enterprise and Industry 
has the responsibility for tyre performance st andards. This section concentrates on the 
contribution of the vehicle tyre to lowering tyre-road noise emissions.  
The currently applicable limit values la id down in Directive 2001/43/EC (amending 
Council Directive 92/23/EEC  relating to tyres for motor vehicles and their trailers and to 
their fitting) are given in table 1(a)-(c) below. The limit values are based on various 
categories and widths of tyre. Class C1 ty res are generally used for cars, class C2 
generally for light commercial vehicles and C3 generally fo r heavy commercial vehicles. 
Within class C1, there are several width categories. Since wider tyres will normally produce more noise than narrow tyres, the 2001  Directive allows higher noise limits for 
the wider categories of tyre. As can be seen, some of the future va lues are dependant on 
studies to be carried out to ensure that these more stringent noise values do not 
compromise tyre performance in other area s. This study (by FEHRL, the Forum of 
 
EN 10   EN European National Highway Research Au thorities) has now been completed3 and will be 
referred to in this document as the FEHRL report. 
The specific proposals set out in the FEHRL report to amend the above limit values are 
discussed in section 3. However, one of the main conclusions of th e FEHRL study is that 
many tyres currently on the market could eas ily meet tighter limit values than currently 
exist (without any obvious trade-offs in othe r areas). This may be partly because tyre 
manufacturers are anticipating the lower lim it values (as foreseen by the 'indicative' 
values in columns B and C of table 1). Hence ev en if there is no change to the Directive, 
the situation will probably continue to improve. However, if limit values remain at the pre-2007 levels, there will be little incentive to improve tyre noise performance and 
design optimisation in other areas (for exam ple, wet grip) may actually lead to tyre 
designs that barely meet the current require ments. This, in conj unction with increasing 
overall traffic levels, and the increased use of wider, noisier , tyres, could lead to an 
increase in the traffic noise problem if no action is taken. 
The beneficiaries from additional action to improve tyre/road noise standards would be 
the general public, particularly those living ne ar busy roads. The costs required to meet 
tighter noise standards would in itially fall to tyre and ve hicle manufacturers, but would 
ultimately fall to vehicle users. There is a si gnificant externality problem here, i.e., the 
people who buy tyres are not necessarily the pe ople who benefit from lower traffic noise. 
Even in the case where buyers of tyres w ould benefit from lower traffic noise, a 
particular buyer would proba bly consider that his/her own purchasing decision would 
have little effect on his/her quality of life (unlike the situation concerning tyre safety, 
where the purchaser is likely to be a direct beneficiary). 
                                                
 
3 FEHRL Study S12.408210 on tyre/road noise (see 
http://ec.europa.eu/enterprise/automotive/ projects/report_tyre_road_noise1.pdf ). 
 
EN 11   EN Table 1a Noise limit values prescrib ed in 2001/43/EC (C1 car tyres)  
 
Note: Additional allowances are given for rein forced tyres (1 dB(A)) and special tyres (2 
dB (A))  
Table 1b. Noise limit values prescribed in 2001/43/EC (C2 light commercial tyres)  
 
Table 1c. Noise limit values prescribed in 2001/43/EC (C3 heavy commercial tyres)  
 
1.3.2.  Tyre Rolling Resistance 
Rolling resistance is the resistance to motion that occurs when an object (e.g. a wheel or 
tyre) rolls. It is caused mainly by the deforma tion of the wheel or tyre or the deformation 
of the contact surface (e.g., the road) and thus  it depends very much on the material of 
 
EN 12   EN the wheel or tyre and the type of road surface. For example, rubber will give a higher 
rolling friction than steel and sand will give much higher rolling fric tion than concrete. In 
the case of rubber vehicle tyres, rubber acts as  a visco-elastic materi al that deforms and 
returns to its original shape periodically. Th e term 'hysteresis loss' is often used in 
literature to describe the energy lost as heat  during the repeated de formation of a tyre.  
Rolling resistance has a dir ect impact on the vehicle CO 2 emissions and fuel 
consumption. A study by TNO 4 (referred to throughout this  document as the TNO study) 
estimates that use of low rolling resistan ce tyres (LRRT) could re duce fuel consumption 
by 3% for a given vehicle a nd thus save on average 0.09 t onnes of CO2 per year and 
vehicle.  
There has been a gradual reduction in roll ing resistance for tyres of comparable 
dimensions over recent years. This has par tly been driven by the desire of car 
manufacturers to reduce the overall fuel  consumption of new cars. However, 
development and use of LRRT needs to be encouraged and accelerated if they are to make a significant contribution to the CO
2 reduction strategy.  
Apart from the global benefits made possible from the gradual replacement of traditional 
tyres by LRRT, the individual vehicle users can  also benefit from lower fuel bills. 
However, there is likely to be a higher in itial cost, largely refl ecting the development 
costs incurred by the tyre manufact urer. Also, due to the fact that tyres with high speed 
ratings tend to have a higher rolling resistance than standard tyres, it is possible that more 
demanding rolling resistance requirements will restrict the choice of higher-performance 
tyres available on the market.  
The use of customer information (for exampl e, tyre labelling or information campaigns) 
may encourage the increased market penetrat ion of LRRT. However, the tyre purchasing 
decision is likely to be base d on a number of factors othe r than fuel economy; and in 
particular the purchase price is likely to be a significant factor particularly with an older 
car. Also, the purchaser may have little real choice if a particular car has a limited number of tyre types suitable for it, or if a pa rticular tyre dealer or fitter only offers a 
limited range of products. Thus, although the mark et mechanism may have a role to play 
in encouraging LRRT, it may not be sufficient in itself.  
1.3.3.  Tyre Pressure Monitoring Systems  
Maintaining proper tyre inflation is essential for both fuel efficiency and better tyre 
performance. Deflated tyres can cause up to  4% increase in fuel consumption while 
reducing tyre lifespan by 45% . Tyres can lose  3-6% of pressure pe r month, and this may 
not be noticed by the driver. Deflated tyres are also an important factor causing road 
accidents resulting in numerous fatalities and in juries throughout Europe. Despite the fact 
that tyre pressure is important for the opera tion of the vehicle car owners are not careful 
with the condition of their tyres. The TNO study quotes research which shows that 50% 
of all cars are driven on under-inflated tyres, and US estimates which indicate that under-
inflation causes an increase  in the average rolling resistance of about 8%. 
                                                
 
4 Review and analysis of the reduction potential and costs of technological and other measures to 
reduce CO 2-emissions from passenger cars Final Report- TNO Contract nr. SI2.408212 , see 
http://ec.europa.eu/enterprise/automo tive/projects/report_co2_reduction.pdf 
 
EN 13   EN A potential solution to this problem is th e use of Tyre Pressure Monitoring Systems 
(TPMS). TPMS are systems that monitor tyre pr essure and warn the driver in case a tyre 
has to be inflated. In certai n cases TPMS also warn for ty re failures for safety reasons. 
Two different TPMS types are distinguished , indirect TPMS and direct TPMS. The 
indirect TPMS uses the antilock brake system (ABS) wheel speed sensor to measure the speed of the wheel. Pressure drops are detect ed by the increase in the ABS wheel speed 
that is caused by the reduction of the rolling wheel diameter. Direct TPMS have calibrated internal sensors that measure actual tyre pressure and transmit data to receivers.  
Use of TPMS is relatively low in Europe. In the USA it is higher due to the TREAD Act 
which effectively mandates the use of TPMS on  new cars. It is envisaged that similar 
legislation will be necessary in Europe in orde r to reap the full benefits of such a system. 
However, it could be argued that TPMS sy stems meeting the US standard may not be 
sufficiently accurate to detect the degree of  under-inflation that can make a significant 
difference to fuel consumption and hence CO
2 emissions. This is discussed further in 
section 3. 
Apart from the global benefits made possibl e by the increased use of TPMS systems, 
individual vehicle users could benefit from reduced fuel cons umption, increased tyre life 
and greater safety. The additional cost will fa ll to the purchasers of new cars. There are 
no plans to require TPMS to be retro-fitted to existing vehicles. This would not be a 
practical proposition since the cost of adding such a system would outweigh the benefits on a car with a limited remaining life. Also, a TPMS system is largely integrated with the 
car (in the case of an indi rect system, through the ABS brake system) and cannot be 
installed simply by replacing one tyre with another.  
1.3.4.  Wet Grip Performance  
Wet grip performance, in other words, th e skid resistance of tyres under wet road 
conditions, is a significant safety feature. There is no evidence to suggest that current 
new tyres, even tyres which have been design ed for low noise or low rolling resistance, 
are substandard in this area. However, it is  acknowledged that if additional requirements 
are introduced with regard to noi se or rolling resistance, it is possible that some (cheaper) 
solutions to achieve better noise or rolling resistance could be detrimental to wet grip 
performance. This was recognised by the United Nations Econom ic Commission for 
Europe (UNECE) working group which developed standards for wet grip as part of the 
same regulation (UNECE Regulation 117) whic h specifies tyre/road noise limits along 
the same lines as Directive 2001/43/EC. It is  proposed that the Regulation 117 wet grip 
test is introduced for all new car tyres, to ensure that safety standards are not compromised by other new requirements. 
The benchmark for the Regulation 117 wet grip test is based on existing tyre types, so 
there will be no increased safety benefit fr om the introduction of this requirement. There 
will be a small additional cost for the regulato ry approval (see section 4) but this will be 
negligible when spread over  the entire tyre production. 
 
EN 14   EN 2. OBJECTIVES  
The Commission has high-level objectives rela ting to road safety, the environment and 
the competitiveness of its industries: 
• Road Safety  The White Paper on European Trans port Policy, which was adopted by 
the Commission in 2001 provides an umbrella  for the European Road Safety Action 
Programme, which sets out the Community’s  goal of reducing the number of road 
fatalities to less than 25,000 by the year 2010. 
• Environment . A key target in the Commissions envi ronmental strategy is the target of 
reducing emissions to 120 g/km for the average new car fleet.  
• Competitiveness . The CARS 21 report identified a number of objectives relating to 
the competitiveness of the Eur opean motor industry, including: 
– ensuring an open and competitive Single Market, including 
competition 
– knowledge, such as researc h, innovation, and skills 
– better regulation 
– ensuring synergies between competitiveness, energy and 
environmental policies 
– ensuring full and fair participation in global markets 
– facilitating social and economic cohesion 
The main objectives of the package of propos als covered by this Impact Assessment are 
as follows: 
-to contribute to road safety objectives  by reducing casualties by the introduction of 
requirements for advanced safety systems such as vehicle stability co ntrol, lane departure 
warning and advanced emergency braking 
-to contribute to environmen tal objectives by reducing the amount of road noise and 
vehicle CO2 emissions through improvements to tyre performance, while at least 
maintaining and possibly improving the level of tyre safety 
- to contribute to competitiveness objectives  by simplify the existing vehicle safety type-
approval legislation to improve transpar ency and ease administrative burden.  
A full analysis of the current situation c oncerning the European Automotive industry, 
plus a discussion about the possible impact of the proposals discu ssed in this Impact 
Assessment on retail prices and affordability is given in Annex III. 
 
EN 15   EN 3. POLICY OPTIONS  
Because this proposal includes a number of se parate elements, the policy options for each 
separate element are examined below. 
3.1. Simplification aspects  
The options identified are as follows: 
a) Do nothing (maintain all existi ng safety –related Directives)  
b) Do nothing as part of the current exer cise, but review each Directive as and 
when they are due to be modified, and decide whether replacement is 
appropriate 
c) Replace all existing Directives through the proposed Regulation  
Option a) would mean continuing with the ex isting Directive struct ure and adding to it, 
as additional amendments to Directives b ecame necessary. This Directive structure 
would continue to operate in parallel with  the existing UNECE Regulatory structure with 
the technical requirements usually (but not alwa ys) being equivalent. This is currently the 
cause of much confusion for stakeholders who ar e not closely involved with the type-
approval system, and leads to a situation of a regulatory system that is less than fully 
transparent. The CARS 21 group (and the following  Communication) strongly 
recommended that the current situation should be simplified, Option b) would effectively 
be a piecemeal replacement of  current Directives which w ould probably take place over a 
number of years. Option c) would represent a 'clean sheet of paper' and would therefore 
maximise the advantages of simplificati on. However, in most cases the technical 
requirements would be the same as the existing requirements, and in such cases the new regulation would allow existing vehicle ty pes to remain subject to the existing 
requirements. Any requirements that represen ted a technical advan ce would only apply to 
new vehicle types. 
A further analysis is included in section 4.1 . 
3.2. Advanced Vehicle Technologies 
The options identified are as follows: 
a) Do nothing and allow the market to take the initiative. b) Establish technical standards for such systems (where fitted) and allow 
manufacturers to f it them optionally. 
c) Establish technical standards a nd mandatory fitting requirements. 
Features such as ESC are already appearing on an increasing numb er of cars in some 
markets (In Germany, over 70% of new cars ar e fitted with ESC) so it could be argued 
that option a) is sufficient. However, on ve hicles such as heavy trucks and tourist 
coaches, where the benefit of ES C may be even greater than for cars, there is often not 
the market incentive to fit ESC voluntarily (since, unlike the case with cars, the 
 
EN 16   EN purchasers are not normally the beneficiar ies). So if there is a good cost-benefit 
justification for fitting ESC, then option c) should be preferred. If the cost–benefit case does not justify mandatory fitment, then optio n b) should be considered since it would 
require common standards for such systems a nd would therefore offer protection for the 
consumer by ensuring that inferior systems were not allowed on the market. It could be 
argued that standardisation is not necessary, and that it should be left to the consumer to 
decide whether to pay more for a superior syst em or less for an inferior system. However, 
the quality of a stability control system is a difficult concept to put across to a non-technical consumer. It is easy for a consumer to compare car s on the basis of, say, engine 
size, and to decide whether it is worth paying more money for a car with a larger engine. 
However, vehicle stability control systems cannot be measured in the same way, and 
while manufacturers can use a wide vocabul ary of technical terms to describe the 
capabilities of their particular system, this is  not always objective, and it could thus be 
argued that a consumer needs the protection of  a unified standard for vehicle stability 
control.  
Other advanced systems such as AEBS a nd LDW are only now starting to appear on 
some higher specification vehicles, and it is difficult to predict the extent to which the 
market will encourage these systems to be fitte d as standard. However, it is likely that 
these systems will follow the same pattern as ESC, i.e, a high take-up on higher-specification vehicles in the more affluent  Member States, but a much lower take-up 
elsewhere. Also, it is unlikely that market forces alone will encourage 100% fitment on 
the vehicles where such systems are likely to yield the greatest benefits, such as heavy trucks. Because of the sophisticat ion of these systems, and the fact that they may be seen 
to take over some functions which are normally the responsibility of the driver, it is especially important that sufficient performa nce requirements are introduced to ensure 
that the systems do not introduce additional risk s. Thus option b) should be preferred to 
the non-regulatory option a). The decision on wh ether option b) or option c) is chosen 
may differ for various categories of vehi cle, depending on the particular costs and 
benefits which apply to those particular vehicle categories. This is explored in more 
detail in Section 4.2. 
3.3. Tyres and Tyre Systems 
As indicated above, the tyre proposals include four different elements: noise, rolling 
resistance, wet grip and Tyre Pressure Monitoring Systems (TPMS). This leads to 
various options and combinations of options in relation to the choice of voluntary or 
mandatory application, or the level of technical difficulty that should be demanded. Table 
2 examines possible combinations of options , and eliminates those which are thought not 
to be practical. The more practical options are examined in greater  detail in Section 4.3. 
 
EN 17   EN Table 2 - Potential policy options for tyres  
Potential Policy Option  
Tyre feature  Do nothing Voluntary/market solu tion Mandatory solution (lower 
technical difficulty) Mandatory solution 
(higher technical difficulty) 
Noise X. Studies show that some 
reduction in tyre/road noise is both feasible and necessary. As explained in section 1.3.1, without any action, the tyre noise 
problem is likely to increase in future years.  X Unlikely that  tyre buyers 
will consider low-noise as a major priority. However, a labelling scheme could be considered in addition to mandatory requirements.    9 (examined further in 
section 4.3) 9(examined further in 
section 4.3) 
Rolling Resistance X It is essential that the use 
of low rolling resistance tyres is at least encouraged in order to meet CO2 reduction targets   9 Buyers will see a benefit 
in fuel consumption when buying LRRT, so use of the market mechanism is a possibility.  9(examined further in 
section 4.3) 9(examined further in 
section 4.3) 
Wet grip  X If proposals on noise or 
rolling resistance are adopted, then it is essential to have a wet grip requirement in order to ensure tyre design is not optimised at the expense of X If proposals on noise or 
rolling resistance are adopted, then it is essential to have a wet grip requirement in order to ensure tyre design is not optimised at the expense of 9(examined further in 
section 4.3) X (There is no identified 
need for a standard higher than the existing Regulation 117 standard. However, if manufacturers wish to introduce a 'premium wet grip' standard, they are free 
 
EN 18   EN wet grip safety.  wet grip safety, and existing 
levels of safety should be mandatory, not optional. to do so. 
TPMS X The benefits of low 
rolling resistance tyres will only be realised if tyres are maintained at their optimum pressure   9 Buyers will see a benefit 
in fuel consumption and safety when buying a vehicle equipped with TPMS, so use of the market mechanism is a possibility. X Current generation TPMS 
systems are considered not to be sufficiently accurate to ensure optimum tyre pressures are maintained .  9(examined further in 
section 4.3) 
 9 Possible option. (Examined in greater detail in section 4) X Not a viable option, for reasons given 
 
EN 19   EN 3.4. Subsidiarity and Proportionality 
For high-volume manufacture, type-approval standards are al ready harmonised across the 
European Union for passenger cars and are becoming harmonised for other types of vehicle. This offers advantages of economies of scale and free access to all EU markets. 
However, in the case of low volume manuf acture, the Framework Directive allows 
special provisions which can be used to ex empt vehicles produced in low volumes from 
certain requirements where the burden on th e manufacturer may be  disproportionately 
high due to the need to spr ead development and approval costs over a smaller number of 
vehicles. There is also the option of Nationa l Type-approval for small-series vehicles, 
which allows Member States to lay down alte rnative technical require ments if the full EC 
type-approval requirements are considered over- burdensome or inappropriate. This is in 
line with the principle of subsidiarity.  
 
EN 20   EN 4. ANALYSIS  
An analysis of the three main elements of  the package is given in sections 4.1-4.3. In 
general the impacts fall into three categories as follows 
Economic Impacts . The simplification proposals outlined in 4.1 will aid the 
competitiveness of the automotive industry by reducing the duplication of Regulation. In 
addition, the accident reduction measures outlined in 4.2 will reduce the costs due to the congestion arising from road accidents. Fina lly, it can be shown that the use of low 
rolling resistance tyres and tyre pressure m onitoring systems can reduce costs for vehicle 
owners or operators in the long term. Annex III discusses the economic aspects in more 
detail.  
Social Impacts . Road casualties have an immense so cial impact, and th eir effect cannot 
be described purely in economic terms. Also, the effect of traffic noise (to which tyre 
noise makes a significant contribution)  has a considerable social impact. 
Environmental Impacts.  The proposed tyre measures are intended to reduce the 
environmental effects of noise and CO
2 emissions. The proposals in this document 
relating to low rolling resistance tyres and tyre  pressure monitoring systems are expected 
to make a contribution to the complementary measures aimed at achieving a target of 120 
g/km. On the basis of the TNO estimated fuel  saving of potential of LRRT and TPMS in 
passenger cars of 3% and 2.5% respectively, for new cars with expected engine test cycle 
performance of 130 g CO 2/km this would mean additional reductions of 3.9 (LRRT) and 
3.25 (TPMS) g CO 2/km. The TREMOVE modelling of the real on-road performance 
of passenger cars shows that in 2020 the EU-27 average savings could be 2.5 g CO 2/km 
for LRRT and 3.0 g CO 2/km for TPMS. In addition, there will be benefits for fitting 
LRRT (and eventually TPMS) for commercial ve hicles but these have not been included 
in this calculation.  
As well as the effect on CO 2 emissions, reducing fuel consumption through more 
efficient tyres has other environmental be nefits, for example in the reductions in 
consumption of raw material resources used for making producing fuels, and the 
environmental effects of processing and dist ributing those fuels. These effects are not 
easily quantified, but are lik ely to be significant.  
In addition, road noise is considered as a significant environmental nuisance, and a 
possible concern for health. The tyre rolling noise proposals discusse d in this document, 
in conjunction with infrastructure measures , are aimed at addressing this situation. 
4.1. Simplification 
Currently, a vehicle undergoing type-approva l has to meet around 50 (depending on the 
category of vehicle) separate safety–related  Directives. In many cases, the manufacturer 
has the option of meeting th e requirement of an 'equivalent' UNECE Regulation which 
 
EN 21   EN has been developed under the 1958 agreement5 The EU is a signatory to the 1958 
agreement and many of the Regulations  adopted under that Agreement. 
The relationship between EU and UNECE le gislation is an important one. UNECE 
Regulations are essentially trading agreem ents between Contracting Parties which 
originally consisted mostly of European  Countries, concerning various vehicle 
components. The ECE system pre-dated the EEC/EU Type Approval system, and when 
the latter system was set up in the early 1970's, most of the EEC Directives on vehicle 
parts were largely copies of the corre sponding UNECE Regulations (although in some 
cases, the reverse was true). As technology has progressed, the EEC/EU Directives have 
been modified in line with UNECE Regulatio ns although there are periods when, due to 
administrative procedures, the corresponding in struments may be out of line with each 
other. Since the introduction of European W hole Vehicle Type Appr oval in the 1990's, 
vehicle manufacturers seeking approval for their components or systems have had the choice of meeting either the relevant Dire ctive or the corresponding UNECE Regulation, 
where available. As a result, manufacturers have shown an increasing tendency to choose 
an approval to the UNECE Regulation rather than the Directive since approval through 
the UNECE system allows access to markets out side the EU (such as Russia, South Africa or Japan). Hence the i ndividual components Directives are becoming increasingly 
redundant where there is  a suitable UNECE alternative available. The current duplication 
of regulation also increases the complexity  of the regulatory framework, and involves 
much administrative effort from all stakehol ders in keeping the regulations up to date, 
and keeping up to date with the regulations. Un der Option a) (the 'do nothing' option) the 
situation would gradually worsen  with the continual updating of legislation adding to the 
already extensive list of Directives. 
Under Options b) and c) the existing Directives  would be replaced as far as possible with 
references to UNECE Regulations, rem oving most of the existing duplication. 
For many manufacturers who already use UN ECE Regulations in preference to EU 
Directives, these changes would make little  difference. However, by eliminating around 
50 base Directives and over 100 amending Di rectives, the clarity of the vehicle 
regulatory system is improved, with definite (b ut not easily quantifia ble) benefits for all 
stakeholders. UNECE Regulations are increas ingly being aligned w ith Global Technical 
Regulations, which allow vehicles to be test ed to a harmonised standard and sold across 
the world to all countries which are signatori es to that particular Regulation. Therefore 
the increased use of the UNECE system will help manufactures reduce costs by avoiding duplication of tests and avoidi ng the design costs associated with meeting different sets 
of regulations. This will help  increase the competit iveness of European products in world 
markets.  
In addition, by using a direct-acting Regula tion instead of a Directive, much of the 
administrative effort required by Member Stat es to transpose Directives into national 
legislation will be avoided. Assuming that on e full-time official per Member State is 
required to transpose these Directives (inc luding any necessary consultation process) 
                                                
 
5 'Agreement concerning the adop tion of uniform technical prescriptions for wheeled vehicles, 
equipment and parts which can be fitted and/or be used on wheeled vehicles and the conditions for reciprocal recognition of approvals granted on th e basis of these prescriptions' UN Geneva 1958. 
 
EN 22   EN then elimination of this task could re present a saving of around € 50,000 per Member 
State (€ 1.35m) 
There will, obviously, be some administrative effort involved in the introduction of this 
new regulation (and the implementing legislat ion) but, unlike the existing system, this 
will not recur. There will be additional costs to manufacturers to meet the new technical areas mentioned in sections 4.2 and 4.3. Howeve r, in relation to th e existing technical 
requirements, there will be no additional bur den on manufacturers since approvals to the 
old Directives will still be accepted until technical change renders these requirements obsolete.  
The difference between Option b) and Option c)  is that that Option b) would change 
Directives to Regulations as and when the re levant Directives required, while Option c) 
would introduce the new regime straight  away under a single new Regulation. Since 
some Directives may remain unchanged for many years to come, Option b) would probably not be fully implemented for se veral years, and would have no obvious 
advantages. Therefore Option c) is preferred.  
4.2. Advanced safety features 
4.2.1.  Electronic Stability Control  
Electronic stability control systems for light a nd heavy vehicles are tr eated separately in 
this section due to the different accident patt erns between these vehicles and the different 
technical specifications propose d. Technical requirements for heavy vehicles have been 
developed by an UNECE working group a nd have been introduced in UNECE 
Regulation 13 which covers braking requiremen ts on heavy vehicles , since ESC systems 
generally act on the br aking system. Requirements for light  vehicles are being developed 
through a Global Technical Regulation whic h is largely base d on proposed US 
requirements. This is likely to be impleme nted in Europe (and many countries outside 
Europe) through UNECE Regulation 13H whic h covers braking on light vehicles.  
4.2.1.1.  Light Vehicles 
4.2.1.1.1 Benefits 
A report for DG TREN
6 by COWI looked at the costs and benefits of various new 
technologies, and in particular ESC for passe nger cars. It reviewed a number of existing 
studies on the effectiveness of ESC and conclu ded that the potential savings per year for 
a fleet fully equipped with ESC could reduce accidents by around 15-20%. The report 
analysed the injury savings for the 20 year period leadin g up to full implementation, 
assuming that, even without legislation, 50% of cars would be fitte d with ESC. The study 
then applied the valuations in table 3 to each category on injury, based on an average of values used throughout the EU25, adjusted  to account for property damage and 
congestion costs.  
                                                
 
6 Cost-benefit assessment and prioritisation of  vehicle safety technologies (COWI 2006) 
http://ec.europa.eu/transport/roads afety_library/publications/vehicle_safety_technologies_final_re
port.pdf 
 
EN 23   EN Using the COWI methodology, but adjusting the values to take into account the EU 
enlargement and more recent registration statis tics, the estimated annual casualty savings 
in the EU27 due to mandatory fitment would be around 2250 fatalities, 23,000 serious injuries and 226,000 slight injuries. This gi ves a total annual saving of 10,803 million 
Euros. 
 
EN 24   EN Table 3. Casualty valuations  
Cost per casualty (Euros)  Type of 
casualty 
Direct cost  Property 
damage Congestion Total 
Fatalities  1,000,000 5,200 13,000 1,018,200 
Severe Injury  135,000 4,400 3,700 143,100 
Slight Injury 15,000 4,400 3,700 23,100 
 
Assuming an average number of cars regist ered per year the EU  27 to be around 13 
million, with an average 13 year lifespan, this means that the total st ock of cars is around 
170 million. The additional 50% of cars that would be fitted  with ESC due to mandatory 
legislation would represent a total of 85 million cars (the other 85 million would have 
ESC fitted already). The average saving per car per year would be around 127 Euros.  
4.2.1.1.2 Costs  The COWI report assumed an increased cost per vehicle of €250 wh ich, using a discount 
rate of 4%, gave a be nefit/cost ratio of 3.8. This is similar to the figure of 3.9 given in the 
summary in Annex 2 which uses the slightly  different vehicle registration assumptions 
outlined above. However, work carried out by the US Regulatory body NHTSA in preparation of the proposal for a Global T echnical Regulation on ESC suggested a cost 
per car of 111 US dollars (around €76) assumi ng the vehicle was already fitted with ABS 
braking, which would almost certainly be th e case in Europe. Therefore the 3.8 benefit 
/cost ratio cited by COWI can probably  be considered as conservative.  
4.2.1.2.  Heavy Vehicles 
The cost and benefit information in this s ection was obtained mainly from the working 
papers of the informal UNECE group
7 which developed the technical requirements for 
Regulation 13.  
4.2.1.2.1 Benefits Based on German accident studies, it is estimated that around 500 fatalities and 2500 
serious injuries per year coul d be saved in the EU27 if h eavy goods vehicles and tourist 
coaches were fitted with ESC. Applying the casualty valuations in Table 3, this gives an 
annual saving of around €867million.  
                                                
 
7 See http://www.unece.org/trans/main/wp29/wp29wg s/wp29grrf/grrf-infevsc8.html working group 
papers on the development of electronic vehicle stability control systems for heavy vehicles. 
 
EN 25   EN 4.2.1.2.2 Costs 
This proposal covers a large range of vehicle types and cost estimates for the addition of 
ESC vary from 400 to 1500 Euro per vehicle. This cost is likely to fall as these systems become standard equipment. For a vehicle already fitted with ABS braking (which would be the case with almost all vehicles in this category) then there is unlikely to be any increased maintenance cost. Therefore the €400-1500 figure represents the increased cost 
for a vehicle over its lifespan. In the EU there are approximately 425,000 goods vehicles 
over 3.5 tonnes and around 25, 000 buses of the type likely to be affected by the ESC 
requirement registered every year. Assuming a vehicle lifespan of 13 years, the average 
additional annual cost per ve hicle would be would be in the range €30-€115, which 
would equate to €180-€675 million for the whol e fleet.. Even using the higher of these 
figures, this still compares favourably with  the estimated annual saving of €867 million. 
A summary of costs and benefits is given in Annex II, table 1.  
4.2.1.3.  Options for the Introduction of ESC 
Section 3.2 identified the following options: 
a) Do nothing and allow the market to take the initiative. b) Establish technical standards for such sy stems (where fitted) and allow manufacturers 
to fit them optionally. 
c) Establish technical standards a nd mandatory fitting requirements. 
Since it is clear that for both light and heavy vehicles there is a positive cost-benefit case 
for these systems, it appears that the mandatory option, opti on c), is justified. However, 
there may be certain cases on some specialised  vehicles (such as low-volume sports cars) 
where the cost of developing an ESC system  would be disproporti onately high since it 
would be spread over a small production run of vehicles; say, 50 compared with 500,000 
for a volume production car. However, these limited cases can be dealt with under the 
small series exemptions of  the Framework Directive.
8 Consultation with stakeholders has 
indicated that 2012 is a realistic date for in troduction of mandatory ESC for new vehicle 
types. Longer lead times may be appr opriate for some specialist vehicles. 
4.2.2.  Advanced Emergency Braking Systems (AEBS) 
4.2.2.1.  Benefits 
Work carried out for DG Enterprise by TR L has indicated that there are significant 
casualty savings to be obtain ed by equipping vehicle with th ese systems. The level of 
casualties saved depends on the t ype of vehicle and the level of capability of the system. 
Current systems do not always avoid collisions , but they ensure that the collision takes 
place at a slower speed thus mitigating injuri es. Future systems should be able to avoid 
collisions altogether, including may collisions  with pedestrians. The TRL work indicates 
that the highest benefit to cost ratios are likely to be achieved through fitting these 
                                                 
8 See Articles 22, 23 and 24 of Community Directive 2007/46/EC. 
 
EN 26   EN systems to heavy vehicles due to the increas ed severity of front to rear collisions 
involving these vehicles.  
Table 4 Range of annual benefits for AEBS  for various classes of vehicle (TRL 
study)9  
 
In table 4. “Current” systems can be defined as systems that are effective in front to rear 
shunt collisions with other vehi cles with four or more whee ls and collisions with rigid 
fixed objects on the carriageway. “Near future” systems may be expect ed to add function 
in collisions with rigid fixed objects off th e carriageway and with pedestrians. “Longer 
term future developments” may be expected to add functionality in head on collisions and front to side collisions at junctions. 
The 'break even cost' is the maximum the system could cost while still remaining cost-
effective in terms of casualty reduction potential. Most current systems are not 
considered effective at preventing collisions ; only in mitigating them. Therefore for a 
heavy truck, the system would possibly need to cost under € 314 to have a positive 
benefit. However, future systems with a wider capability are seen as having a far greater casualty prevention potential, and this would co nsiderably raise the amount that could be 
spent on installing such a system (around €136 -966 for a passenger car and €1700-12000 for an M2 or M3 vehicle (bus or coach).  
4.2.2.2.  Costs 
These systems combine advanced braking syst ems with sensing technologies using radar 
or laser. According to industry sources cu rrent systems cost over €1,000 per vehicle, but 
the technology cost is reduci ng rapidly, and will reduce further as volume increases. A 
recent estimate
10 suggests that once standard fitmen t has been achieved in main-stream 
models at 1 million units a year, a laser-based  system can be installed for around €200 to 
                                                 
9 Automated Emergency Brake Systems: Techni cal requirements, Costs and Benefits, see 
http://ec.europa.eu/enterprise/automotive/projects/index.htm  
10 Automotive News Europe, June 11 2007. 
 
EN 27   EN €250 per car for hardware, software and inst allation. Thus, these will be highly cost-
efficient, as their cost will be considerably  below the break-even cost presented in Table 
4. above. Also, once a vehicle has been fitted with ESC the additional hardware cost for an AEBS system is relatively low, and is unlikely to be very de pendant on the category 
of vehicle. In Annex II, table 1, a mid-ra nge assumption of €1,000 for a system cost is 
used (assuming the vehicle is already equipped with ESC). At this cost, the benefit/cost 
ratio is less than 1 for cars, but more than 2 for heavy vehicles. As these systems become 
more widely available, costs are likely to decrease significantly. 
4.2.2.3.  Options for the Introduction of AEBS 
As with ESC, the options identified are as follows: 
a) Do nothing and allow the market to take the initiative. b) Establish technical standards for such systems (where fitted) and allow 
manufacturers to f it them optionally. 
c) Establish technical standards a nd mandatory fitting requirements. 
As such systems are rapidly becoming cost-eff ective, particularly on vehicles already 
equipped with ESC, Option c) is the right appr oach provided that the legislation foresees 
a transitory period of several years and that the systems are initially fitted only to heavy 
goods vehicles and buses. Unlike ESC, the cost–benefit balance for AEBS is more 
favourable for heavy vehicles than for light ve hicles. This apparent contradiction is due 
to the fact that ESC tends to be quite expe nsive for heavy vehicles (due to the large 
number of axles and the relatively low pr oduction volumes). However, the additional 
cost of equipping a heavy vehicle with AEBS, once ESC has already been fitted, is relatively low since the sensors can be produced  in high volumes and at a similar cost to 
the sensors used for cars. Thus the cost of fitting AEBS, as a percentage of the whole vehicle cost, is relatively low for larger vehicles.  
Based on the feedback from system supplie rs following the internet consultation, a 
realistic implementation date for these cat egories of vehicles may be around 2013. At a 
later stage it should be assessed whether ma ndatory installation of  these technologies 
should be extended to light-duty vehicles and passenger cars. 
 
EN 28   EN 4.2.3.  Lane Departure Warning Systems. 
4.2.3.1.  Benefits. 
The COWI report referenced in 4.2.1.1.1 also examined the costs and benefits of LDW 
systems using the same methodology as for ESC systems. The accident prevention 
potential of combined LDW and LCA systems,  has been estimated at 25% for head on 
collisions, 25% for left roadway accidents and 60% for side collisions. An accident 
mitigation effect is also expected, in that  the severity of accidents is shifted down a 
severity class - i.e. from fatality to severe injury and from severe to slight injury. The 
mitigation effect is 25% for head on collisions, 15% for left roadway accidents and 10% for side collisions. If all vehicles were fitted with LDW and LCA this could result in annual EU-wide savings of 5500 deaths, 30,800 serious injuries and 208,500 slight 
injuries, equivalent to an annual cost saving of 14,824 million Euro.  
4.2.3.2.  Costs 
The COWI report assumed an increased co st per vehicle of €600 to include the 
installation of both LDW and LCA systems. Using the above benefit data, this would 
suggest a benefit/cost ratio of 1.7. Using more recent EU registration data (see Annex II) 
suggests a slightly lower figure of 1.1. However, a lot of the hardware could probably be 
shared with other systems (such as AEBS ) which could significan tly reduce the cost. 
Therefore this figure is probably conservative.  
4.2.3.3.  Options for Lane Departure Warning Systems. 
As with ESC and AEBS, the following options are identified: 
a) Do nothing and allow the market to take the initiative. b) Establish technical standards for such systems (where fitted) and allow 
manufacturers to f it them optionally. 
c) Establish technical standards a nd mandatory fitting requirements. 
The benefit/cost balance is not as favourable as  for ESC, and it is lik ely that such systems 
will be more cost beneficial on heavy trucks than on cars (due to the lower cost of the 
system as a proportion of the vehicle cost, th e greater problem of blind spots on larger 
vehicles, their greater distance travelled a nd the more serious consequences of an 
accident concerning large vehicles). Furt her work is being carried out for the 
Commission which will examine the costs and be nefits in more detail in relation to 
different vehicle classes. Even on the current  evidence, there appears to be a case for 
introducing mandatory LDW/LCA at least on heavy goods vehicles and buses, since the 
COWI report indicates that introduction of  such systems through market mechanisms 
alone is likely to be very slow. Since these systems may use similar sensing hardware to 
AEBS system, it would seem logical to introduce them on a similar timescale.  
 
EN 29   EN 4.3. Tyres and Tyre Systems  
4.3.1.  Tyre Noise 
The FEHRL report mentioned in section 1.3.1 cons idered the costs and benefits involved 
in tightening the tyre noise limits. A major part of this  study involved analysis of the 
noise performance of existing tyres on the mark et, to assess the feas ibility of tightening 
the noise limits in the future. Table 5 shows the percentage of tyres tested which were 
able to meet the existing levels with margins of 3dB(A) and 5 dB(A). 
Table 5. Performance of current tyres in  relation to existing limit values 
Category Percentage ≥ 3 dB(A) 
below  Percentage ≥ 5 dB(A) 
below 
C1b 68 10 
C1c 45 5 
C1d 66 19 C1e 57 16 C2 50 13 C3 75 53 
On the basis of the above re sults, and further comparisons  which indicated no significant 
relationship between noise, wet grip or rolling resistance on the tyres tested, FEHRL concluded that it was feasible to introduce ne w limits in the order of 5dB(A) lower than 
the existing limits. Taking in to account the normal product cycle of tyres, it was 
suggested that a date of 2012 was feasible for the introduc tion of the new noise limits, 
with a possible interim step in 2008. The FEHR L report also suggested  a number of other 
changes, including: 
• A realignment of the width 'bands' to recognise the increased average width 
of modern car tyres  
• A change in the method of 'rounding' th e raw measurement data to give the 
final approval figure 
• Recommendations to introduce testing of wet grip and rolling resistance to 
ensure that future tyre designs to not s acrifice these qualities in the pursuit of 
lower noise levels 
• Recommendations on changes to the te st surface and measuring procedures 
• Increased consumer awareness through a labelling scheme 
Options concerning the introduction of new limits, the realignment of width bands, 
changes to the rounding proced ure and a possible labelling sc heme are discussed later in 
 
EN 30   EN this section. Requirements concerning wet grip  and rolling resistance are covered in other 
sections. Changes to the test procedure and the test surface will be discussed in the context of possible changes to UNECE Re gulation 117, since the proposed Regulation 
would refer to the Regula tion 117 test procedure. 
4.3.1.1.  Benefits from Reduced Tyre Noise 
The benefits of tyre/road noise reductions we re calculated using a valuation that was 
established by the EU Working group on Heal th and Socio–Economic Aspects in 2003. 
This put a value of noise reduction to house holds of 25 Euro per dB per household per 
year. This figure is lower than figures used in some national studies in the wealthier Member States, and therefore could be cons idered to be conservative. However, the 
figure was reached by a wide consensus of academics for use across the EU with input 
from national governments and industry. The FEHRL report adjusted this 25 Euro figure 
to 27 Euro to reflect th e growth in per capita GDP  between 2003 and 2006. The 
estimated number of households in the EU  27 is around 215 million. Therefore the total 
benefit across the EU 27 would be  
27 X 215 million = 5805 million Euro per dB per year. (say 5.8 billion Euro)  As indicated in the previous section, FE HRL considered that proposed noise limit 
reductions per tyre of around 5 dB(A) were feas ible so this figure formed the basis of 
calculations to determine the effect on the general public. A noise reduction of 5 dB (A) 
per tyre does not mean that the noise reducti on perceived by a person (for example, at the 
roadside or in a nearby building) would be 5 dB(A). This is due to a number of factors: 
• Even if the noise limit is reduced by 5 dB(A) this does not mean the average 
noise value per tyre is reduced by th e same amount. This is because some 
tyres already meet the proposed limits as it would be technically difficult (or 
impossible) for them to improve by anot her 5 dB(A). The likely result is that 
the distribution of tyre noise values  will become narrower, on average around 
3 dB(A) below current values. 
• Due to the variations between test road  surfaces and actual road surfaces, the 
reductions in tyre noise values may not always be reflecte d in reductions in 
actual tyre road/noise values.  
• The other sources of noise from the ve hicles also need to be taken into 
account. 
These factors are discussed in detail in se ction 5.3 of the FEHRL report, which also 
describes two mathematical noise models whic h have been develope d for use in traffic 
noise calculations and noise mapping in Eu ropean towns and cities; HARMONOISE and 
TraNECam. Both these models were used to predict the noise benefits achieved for the 
population as a result of the proposed tyre noise  limits. Predictions were made for a range 
of scenarios from motorways to congested ur ban conditions. It was concluded that there 
was considerable agreement between model pred ictions, leading to greater confidence in 
the predictions made. However, there were some relatively small differences between the noise level reductions predic ted by HARMONOISE and TraN ECam, so the results of 
both models were considered as conservati ve and optimistic assumptions respectively. 
 
EN 31   EN Based on the two models, FEHR L assumed a lower value of 0.9 dB(A)  and an upper 
value of 2.3 dB(A)  for the overall average traffic noise  reduction resulting from the tyre 
noise limits for C1 tyres only . There would be greater benef its than this if the proposal 
covered C1, C2 and C3 tyres. 
4.3.1.2.  Valuation of benefits from new noise limits for C1 tyres 
The valuation of 5.8 Billion Euro/dB/annum  from section 4.3.1.1 needs to be multiplied 
by the actual noise reduction in dB(A) that woul d occur in real traffic. This then provides 
the annual benefit to the pub lic across the EU27 of the proposed new noise limits, in 
2006 Euro values. 
(i) Using the 0.9 dB(A) estimate:   
Annual benefit = 
 5.8 billion Euro/dB/annum x 0.9 dB(A) 
Annual benefit to EU27 of proposed new 
noise limits using 0.9 dB(A) estimate = 
  
5.22 billion Euro/annum 
(ii) Using the 2.3 dB(A) estimate: 
  
Annual benefit = 
 5.8 billion Euro/dB/annum x 2.3 dB(A) 
Annual benefit to EU27 of proposed new 
noise limits using 2.3 dB(A) estimate =  
13.34 billion Euro/annum 
 
Taking (i) and (ii) together:  
Estimate of the annual benefit of the 
proposed new noise limits =  
5.22 -13.34 billion Euro/annum 
 
This is a simplified analysis of the benefits achievable from a reduction in the limit 
values of 5dB per tyre. A more detailed analys is of the benefits over time is provided in 
section 7.5.2 of the FEHRL report. This pred icts a total benefit of 48-123 billion Euros 
for the EU25 over the period of 2010 to 2022. Adjusting this figure to the EU27 gives a 
 
EN 32   EN total benefit of around 50-129 bil lion Euros. The summary table in Annex II gives values 
for the benefit per car, based on a mid-ra nge annual benefit of 9bn Euro/annum. 
4.3.1.3.  Costs of Tyre Noise Reductions 
Any costs for compliance with the proposed ch anges to the Directive are assumed to be 
borne by the following stakeholders: 
Any increased costs for the original tyre, due to extra material or labour costs, or extra 
research and development, would initially be  borne by the tyre manufacturer, but would 
be passed on to the consumer either directly (in the case of after market tyres) or via the 
vehicle manufacturer (in the case of original equipment tyres) 
Any increase in running costs (s uch as increases in fuel c onsumption or increased wear) 
would be borne directly by the consumer. 
The FEHRL report concluded that 35% of C1 tyres on sale in 2000-2005 already met 
noise limits around 4.5-5 dB(A) below the current level, that is to say, the noise level 
reductions assumed when calculating the benefi ts described in the previous paragraph. 
This would indicate that the research and de velopment to meet the new noise limits has 
already been carried out by the manufacturers,  and tyres achieving the new noise limits 
are apparently being mass produced without difficulty, and are price competitive with non-compliant tyres.  
Other requirements of tyres, su ch as safety and visual appe al, must already have achieved 
levels that are satisfactory both to sellers and buyers. There was also no evidence from 
any available literature that tyres meeting the lower noise level suffered significantly from any reduced durability or increased rolling resistance. Therefore it could be 
concluded that there are unlik ely to be any increased runni ng costs for the consumer.  
FEHRL concluded that the only major cost to  manufacturers would lie in discontinuing 
production of any tyre lines that  did not meet the proposed no ise limits. The tyre industry 
has indicated that there are around 6,000 tyre li nes on sale at any one time. Therefore we 
consider that there is unlik ely to be an undersupply of  the market due to such 
discontinuation, though there is a danger th at customer choice  could be reduced, 
particularly in some 'niche' markets. There w ould of course be tooling costs for replacing 
tyre moulds, but given that the time-span for introduction of these requirements is likely 
to be around 8 years, this should fit in  with the normal product replacement cycle 
(bearing in mind that not all tyre va riants will need to be replaced). 
Although it could be claimed that  the R&D effort has already been spent, since there are 
tyres in production that already meet the new limits, it is accepted that the limits will be more difficult to meet with respect to some types of tyre than with others. Also, the 
normal tyre design cycle may have to be accelerated in order to meet the proposed deadlines, requiring extra resear ch and development resources. This is discussed in detail 
in section 7.6 of the FEHRL report, which quot es a tyre industry es timate of 2 billion 
Euro per annum to achieve this. It is difficult to provide an independe nt validation of this 
figure, and FEHRL considers it to be an over-estimate. FEHRL calculated that, on the basis of industry–supplied figures stating th at research and development expenditure was 
around 3.5-5% of sales in the EU, amounting to around 400million Euros, if the industry 
 
EN 33   EN were to increase their entire research and development over the transitional period by 
50%, this would represent an extra 200million Euro per annum. If it was assumed that 
this research was concentrated on developi ng original equipment tyres for new cars and 
this cost was spread across the entire EU  sales of new cars (around 13 million per 
annum) this would represent about 15 Euro per car. Alternatively, using the assumption 
that 33% of cars already meet the limit va lues, the extra costs may only fall on the 67% 
of tyres that do not, which would lead to a increase in cost per car of 22.5 Euros. 
 
EN 34   EN Table 6 Proposal for noise limits for C1 (car) tyres  
Possible intermediate values Final values Old tyre class 
(width in mm) Old 
value 
(dB(A)) Proposed class  
(width in mm) Proposed 
value 
(dB(A)) Reductions 
compared with current values  'Real'
* 
reductions) Proposed 
value 
(dB(A)) Reductions 
compared with current values  'Real'
* 
reductions)  
≤ 145 (c1a) 72 -1.0 0.5 1.0 2.5 
> 145 ≤ 165 (c1b) 73 0 1.5 2.0 3.5 
> 165 ≤ 185 ( c1c) 74  
≤ 185 ( C1A)  
73  
1.0 2.5  
71  
3.0 4.5 
> 185 ≤ 215 ( c1d) 75  > 185 ≤ 215 ( 
C1B) 74  1.0 2.5 72  3.0 4.5 
> 215 ≤ 245 ( C1C) 74  2.0 3.5 72  4.0 5.5 
> 245 ≤ 275 ( C1D) 75  1.0 2.5 73  3.0 4.5  
> 215 (c1e)  
76 
> 275 (C1E) 77  -1.0 0.5 75  1.0 2.5 
                                                 
* Currently, the 'raw' measur ements are rounded down to  the nearest whole number, then 1dB is subtracted to give the final appr oval value. The FEHRL proposal was to take the 
raw measurement and round it up or down to the nearest whole number to give the approval value. The effect of this would be to increase the difference between the old and 
new targets by, on average, 1.5 dB 
 
EN 35   EN 4.3.1.4.  Options for Reducing Tyre Noise 
As indicated in table 2, the options of doi ng nothing or relying on market forces to 
reduce tyre noise have been eliminated. Other measures, such as improving road 
surfaces, can be considered as part of an 'int egrated approach' to reducing tyre noise, but 
such measures should be complementary to, an d not replace, direct measures to reduce 
the tyre's contribution to the pr oblem. The main issue to decide  is the level of ambition of 
the proposed tyre noise levels and the associated timescale. 
4.3.1.4.1 C1 (car) tyres Table 6 proposes two sets of proposed values  for C1 (car) tyres, together with their 
reductions from the current values required by the 2001/43 Directive. The 'final' values in 
the right hand columns represen t the '2012' proposals includ ed in the FEHRL document. 
The 'intermediate' values in the middle co lumns represent the '2008' proposals included 
in the FEHRL report. These were included to allow a phasing-in of the requirements. It 
would not be practical to implement these re quirements by 2008 as originally suggested, 
but a possible option would be to ease the burden on industry by introducing the 
intermediate requirements i n, say, 2012 with the final re quirements following in, say 
2016.  
It should be noted that part of  the proposal included in table 6 is the realignment of tyre 
width categories to represent more accurately  the distribution of tyres on the current 
market. It is more difficult for wider tyre s to meet low-noise requirements and the 
existing and proposed limits reflect this. Howe ver, it has been ar gued that allowing 
higher limits for wider tyres encourages ve hicle manufacturers to specify wider tyres 
than are necessary for a particular vehicle. Clearly, a wider tyre in creases the amount of 
road contact surface, and therefore offers a potential safety advantage. However, in many cases it could be argued that this safety a dvantage is only relevant  beyond the limits of 
performance that the vehicle is designed for.  
Research carried out by the Tran sport Research Laboratory (TRL)
11 in the UK proposed 
a different set of future noise limits, summa rised in Table 7. This proposal would require 
the same limits for all widths of C1 tyre under the existing classifi cation, but would allow 
an extra 2dB(A) for a new class of tyre wider than 245mm.  
The effect of this proposal would be partic ularly severe on tyre s just under the 245mm 
threshold, and it might be necessary to adjust some of the limits or thresholds. However, 
the general principle of reduci ng the number of width categorie s from five to two may be 
worthy of further consideration.  
                                                 
11 Tyre/road noise –Assessment of existing and proposed tyre noise limits : report for UK 
Department for Transport Watts et al, TRL May 2006,  http://www.dft.gov.uk/pgr/roads/environment/r esearch/cqvcf/tyrenoise/tyreroadnoisereport 
 
EN 36   EN Table 7 . TRL proposal for C1 noise limits 
Limit values (dB(A) Tyre Class Width (mm) 
Current limit  Proposed limit  Reduction  'Real' reduction (see 
table 5 footnote)  
C1a ≤ 145  72 71 1.0 2.5 
C1b > 145 ≤ 165  73 71 2.0 3.5 
C1c > 165 ≤ 185  74 71 3.0 4.5 
C1d > 185 ≤ 215 75 71 4.0 5.5 
C1e > 215 ≤ 245 76 71 5.0 6.5 
C1f > 245 76 73 3.0 4.5 
 
 
EN 37   EN Table 8. Summary of Options for C1 Tyres 
Actual reduction in limit values (dB(A))  Tyre width class 
Option a 
(FEHRL 
recommended limits)  Option b  
(FEHRL recommended limits - 2 
phase) Option c  
(TRL 
recommended limits) 
Possible implementation date (new tyre types) 2012 2010 2014 2012 
≤ 145  2.5 0.5 2.5 2.5 
> 145 ≤ 165  3.5 1.5 3.5 3.5 
> 165 ≤ 185  4.5 2.5 4.5 4.5 
> 185 ≤ 215  4.5 2.5 4.5 5.5 
> 215 ≤ 245  5.5 3.5 5.5 6.5 
> 245 ≤ 275  4.5 2.5 4.5 4.5 
> 275  2.5 0.5 2.5 4.5 

 
EN 38   EN Ultimately, bearing in mind the scientific  evidence that a limit reduction of around 
5dB(A) is feasible, and the increasing evidence on the adverse health effects of environmental noise pollution, it would be difficult to justify a smaller reduction than 
this. However, there remain questions on ti mescale (and whether to go for a two-phase 
approach) and to what extent wider tyres s hould benefit from an additional allowance. 
Table 8 summarises the three options, base d on the above discu ssion. The costs and 
benefits of Option a are generally as described in 4.3.1.2 and 4.3.1.3. Option b would, in 
effect, be a delay of two years which would me an that two years of benefits arising from 
the implementation of the full limits woul d be lost. On the other hand, the longer 
introduction period would allow the industry time  to integrate the new requirements with 
its normal tyre replacement programme and thus reduce the costs due to accelerated replacement. It could be argued that the ''int ermediate' limit will have little actual effect, 
since, according to FEHRL, 76% of tyres me et this limit already and most new tyres 
which are introduced around 2010 will be designed to meet the 2
nd stage limits in order to 
enable a full design life of about 8 years to be  achieved. Option c) is, in general, slightly 
more severe than Option a) so the costs a nd benefits would be slightly greater.  
4.3.1.4.2 Commercial Vehicle Tyres (C2 and C3) 
The FEHRL recommendations for noise limits fo r commercial vehicle tyres are given in 
Table 9A As with C1 tyres, two levels are proposed , shown on the ta ble as 'intermediate' 
and 'final' thus allowing the po ssibility of a 2 phase introduction. 
Options for implementation for C2 and C3 ar e shown in Table 9B. As there are no width 
categories within these classes and therefore no opportunity to adjust these categories, 
only two options are presented. As with the C1 category the two-stage option (option b) 
is likely to provide lower costs and lower benefits. It would seem  reasonable to follow 
the FEHRL proposed timetable for the introduc tion of the new requirements for new tyre 
types (2012). However, due to the large number of ty re lines in existe nce, it would be 
necessary to allow a longer-than-normal trans ition period to allow existing tyre types to 
continue to be sold (say four years). 
 
EN 39   EN Table 9A FERHL recommendations for light commercial (C2) and heavy 
commercial (C3) tyres.  
Limit values in dB(A)  
 
Intermediate requirements Full requirements Tyre 
class Category 
of use 
Current  
Limit Nominal 
Reduction Actual* 
reduction Limit Nominal 
reduction  Actual* 
reduction
Normal  75 73 2.0 3.5 71 4.0 5.5 
 Snow (M+S) 77 74 3.0 4.5 72 5.0 6.5 C2 
 Special 78 76 2.0 3.5 74 4.0 5.5 
Normal  76 73 3.0 4.5 71 5.0 6.5 
Snow 
(M+S) 78 75 3.0 4.5 73 5.0 6.5 C3 
Special  79 77 2.0 3.5 75 4.0 5.5 
                                                 
* Currently, the 'raw' m easurements are rounded down to the nearest whole number, then 1dB is 
subtracted to give the final approval valu e. The FEHRL proposal was to take the raw 
measurement and round it up or down to the nearest whole number to give the approval value. 
The effect of this is would be  to increase the difference betwee n the old and new targets by, on 
average, 1.5 dB. 
 
EN 40   EN Table 9B – Options for C2 and C3 tyres 
Actual limit reduction (dB(A) )  
Option a) Option b) 
Possible 
introduction date 2012 2010 2014 
Normal  5.5 3.5 5.5 
 Snow 
(M+S) 6.5 4.5 6.5 C2 
 
Special 5.5 3.5 5.5 
Normal  6.5 4.5 6.5 
Snow 
(M+S) 6.5 4.5 6.5 C3 
Special  5.5 3.5 5.5 
 
EN 41   EN 4.3.1.4.3. Additional Options 
The possibility of noise labelling to inform  consumers of the noise characteristics of 
particular tyres has been rais ed. Although it is not considered that this could be a viable 
alternative to legislation, since there is li ttle customer incentive to buy low-noise tyres, 
there is a possibility that noise values, togeth er with wet grip values, could be added to 
the CO 2 label discussed in Section 4.3.2 to give the consumer a full range of information. 
In addition, it has been suggested that re treaded tyres should also meet the noise 
requirements. Currently this would only affect  after-market tyres sinc e retreaded tyres are 
currently not allowed on new cars within the sc ope of type-approval. Also, there has been 
no study on the feasibility of applying th e proposed limits on retreaded tyres. The 
FEHRL study indicates that for retreaded tyres on heavy vehicles (the vehicles for which 
they are most often used) the values for retreaded tyres are 2-4 dB(A) noisier than new tyres so there may be problems with the feasibility of meet ing the proposed standards. 
Further investigation may be  required in this area.  
4.3.1.5.  Further Analysis of Pr actical Noise Limits. 
Following the initial consultation, a study by SP Technical Research Institute of 
Sweden
12, sponsored by the Swedish Government, examined the rolling noise of 
currently available tyres in the C1, C2 and C3  categories. In the C2 and C3 categories; 
for which the FEHRL study had offered considerab ly less data than fo r C1 tyres, the SP 
data suggested that the 5.5-6.5 db(A) reduc tions proposed by the FEHRL study might be 
over-ambitious. In addition, for C3 tyres, it wa s suggested that there was a considerable 
difference between the noise emitted from tyres uses on the drive axle(s) and those used on the steering axles. Tyres used on the drive ax les, often termed 'traction tyres' also tend 
to be approved as mud and snow (M+S) tyres.  To allow continued us e of these tyres, it 
would seem appropriate to allow an additio nal 2db(A) for traction tyres compared with 
standard tyres.  
Furthermore, there are certain tyres which used for heavy-duty off-road applications 
categories which would have difficulty mee ting either the noise or rolling resistance 
limits. It would seem reasonable to exempt th ese tyres (termed as 'professional off-road 
tyres') from the noise and ro lling resistance requirements provi ded these were for genuine 
off-road applications and not for normal road-going vehicles. For this reason, it is 
suggested that such exemptions are limited to  tyres with a speed capability of no more 
than 100km/hr. 
Taking the above factors into account, the complete table of proposed limit values is 
given in Table 10. Column 1 gives the proposed values measured in the same way as in 
the current Directive (rounding do wn to the nearest whole nu mber value and subtracting 
a tolerance of 1db(A)). Column  2 gives the proposed values using the rounding method 
proposed by FEHRL (rounding up or down to  the nearest whole number with no 
additional tolerance). 
                                                
 
12 Jonasson, Hans (2007): "Rolling Noise Emission of Tyres – A Market Survey". SP Report: 
2007:70, SP Technical Research Ins titute of Sweden, Borås, Sweden. 
 
EN 42   EN Table 10 – Summary of Proposed Limit Values  
Limit value (db(A) Tyre Class 
1. Using current Directive 
Method 2. Using FEHRL proposed 
method 
C1A (≤ 185mm)  70 71 
C1B ( > 185 ≤ 215mm)  71 72 
C1C ( > 215 ≤ 245mm)  71 72 
C1D ( > 245 ≤ 275mm)  72 73 
C1E ( > 275mm)  74 75 
C2 71 72 
C2 M+S 72 73 
C3 72 73 
C3 M+S 74 75 
 
'Professional off-road tyres' meeting certain  criteria would be exempt from these 
requirements. 
4.3.2.  Tyre Rolling Resistance 
The following sections analys e the costs and benefits of introducing low rolling 
resistance tyres across the vehicle fleet. The analysis is based on the results of the TNO study which concentrated on passenger cars. Passe nger cars are seen as  the first priority 
with respect to CO
2 emission targets. However the use of  low rolling resistance tyres on 
commercial vehicles is also di scussed later in this section. 
There is currently no formal definition of  a 'Low Rolling Resistance Tyre' (LRRT). 
However, a draft international standard for a rolling resistance measuring procedure (ISO 
28580) is currently under preparation.  
4.3.2.1.  Calculation of Benefits  at the Vehicle Level 
The TNO study indicated that low rolling re sistance tyres could reduce a car's fuel 
consumption by between 1% and 5% . As outlined in section 4.3.2.3 , one option is to designate tyres into rolling resistance 'bands' so that, say, a band A tyre gives the 
maximum rolling resistance reduction (corre sponding to, say, a 5% fuel consumption 
reduction) and a band D tyre gives the minimum permissible improvement 
(corresponding to, say, a 1% fuel consumption reduction) Thus, an average rolling vehicle fuel consumption reducti on of 3% is assumed for the purposes of this analysis.  
 
EN 43   EN Full details of the TNO analysis are given in section 5.3 of the TNO report. However, the 
main conclusions are that, based on an a nnual distance of 16,000 km, a car using LRRT 
would on average save 0.09 tonnes of CO 2 per year (well to wheel).  In the longer term , a 
TREMOVE13 analysis has predicted th at the mandatory fitting of original-equipment and 
replacement LRRT, phased in from 2012, w ould result in a total reduction of CO2 
emissions from passenger cars of 1.45% in 2020. In addition, there would be fuel cost savings for the vehicle owner, depending the cost  of fuel at the time. For a fuel cost of 
0.21€/l (excluding tax) the annu al saving would be €7. For a fuel cost of 0.60 €/l, the 
annual saving would be €19. The actual fuel co st to the motorist will include tax, which 
would significantly increase the cost advantages of LRRT.  
4.3.2.2.  Calculation of Costs at  the Vehicle Level  
The TNO study estimated the additional cost to the consumer of fitting a set of LRRT to 
a vehicle would be €60. Assuming a typical tyre  life of 3 years this  would lead to an 
additional annual cost of €20. There was no evid ence of any durability or safety penalty 
in purchasing LRRT, so the €24 would represent the total annu al additional cost. For the 
tyre manufacturers, many of the same argu ments apply as for tyre noise. LRRT are 
already proven to be feasible  but if a deadline is applied which prohibits the sale of non-
compliant tyres, there may be additional cost s to the manufacturer in accelerating the 
replacement of such tyre types. 
4.3.2.3.  Options for Introducing Tyre Ro lling Resistance Requirements 
4.3.2.3.1 Car Tyres 
As indicated in Table 4, it is possible to us e the market mechanism as well as regulation 
to promote the use of LRRT. The TNO report s uggests that 50% of ne w tyres already fall 
within the category of LRRT, which suggest s that the market mechanism is already 
working to some extent. This is largely due to  the fact that vehicle manufacturers like to 
achieve low fuel consumption figures for thei r products, and therefor e have an incentive 
to provide energy–saving tyres. For the after-m arket, there is unlikely to be such an 
incentive since other factors (such as purchase cost) are more likely to play a major role 
particularly with the oldest cars. Howeve r, the development of a tyre grading and 
labelling system to give consumers more info rmation on the fuel consumption benefits of 
LRRT may be beneficial .  
An outline proposal on a banding system for L RRT is given in Table 11A below. (The 
number of bands and the associated thre shold levels may be subject to further 
modification). The table includes indicative figures from the tyre industry on the 
percentage market share over time of tyres in  the various grades. (Band A represents the 
best performance level)  
Table 11A – Possible Grading System  for Rolling Resistance (C1 tyres)  
 Band Band Band Band 
                                                 
13 For background on TREMOVE see http://www.tremove.org/  
 
EN 44   EN A B C D 
Maximum rolling 
resistance coefficient per band (kg/tonne)  9.0 10.5 12.0 13.5 
2004 1.7 14.8 40.5 33.8 
2012 (est)  10.0 25.0 35.0 30.0 % Market 
share 
2015(est) 20.0 26.7 26.7 26.7 
 
Although it is a reasonable assump tion that market forces will tend to push tyres to the 
higher band categories, as indicated above, ma rkets are difficult to predict and it may be 
necessary to include a legislative option to ensure that at least the worst performing tyres are removed from the market. Hence three options are proposed. 
Option a) Rely on a grading and labelling scheme to encourage the increased use of 
low rolling resistance tyres. For tyres supplie d as original equipmen t, rely on the vehicle 
manufacturers' incentive to produce cars with low fuel consumption, and to produce cars 
with a low CO
2 rating in order to meet future CO 2 emission targets. 
Option b) Introduce a grading and labelling scheme as in Option a) but make at least 
the minimum (band D) standard mandatory for vehicle and component type approval. 
Option c) Same as Option b) but would also apply to after-market tyres.  
The costs and benefits for Opti ons a and b are likely to be as indicated in sections 4.3.2.1 
and 4.3.2.2 above. Option c may incur additional costs for manufacturers (likely to be 
passed on to consumers) if the level of difficu lty is such that a large number of tyre 
designs have to be replaced over a short times cale. However, it is the option that provides 
the greatest degree of certa inty. It is also the only option that lives up to the 
Commission's commitment made  in the Commission's comm unications of 7 February 
200714 to ensure that a reduction of a further 10g CO 2 /kg is achieved, over and above the 
130g to be achieved by vehicle technology m eans. Savings due to tyres supplied as 
original equipment are already accounted for in the vehicle's CO 2 rating. So it is only the 
tyres for the after-market that  can contribute to the 10 g CO 2 /kg target. Since these tyres 
will be fitted to all vehicles of the existing fleet, they have a potential for reducing CO 2 
which is up to ten times higher than tyre s for new vehicles. Thus, Option c) is the 
preferred option.  
                                                 
14 See http://eur-lex.europa.eu/LexUriServ/site/en/com/2007/com2007_0019en01.pdf 
 
EN 45   EN 4.3.2.3.2 Commercial vehicle tyres. 
The options for C2 and C3 tyres are generally th e same as for C1 tyres. However, there is 
limited data on the current rolli ng resistance performance of C3 tyres. Therefore a single 
limit rather than a grading system is proposed for this category of tyre. 
4.3.2.3.3. Labelling In order for options a and b in section 4.2.3.2.1 to work effec tively it would be necessary 
to introduce a clear understandable labelling sy stem to advise the end-user on the best 
choice of replacement tyres with regard to fuel consumption (and hence CO
2 emissions). 
Labelling has been used  with respect to passe nger cars (see section 11 of the TNO report) 
and there is a strong argument  for using a similar system for tyres, possibly using the 
same seven-band format as used on other consumer products. The addition of 3 more bands would not seem to increase the costs of the labelling scheme. In fact, it is likely to 
present an incentive for manufacturers to move  to the higher bands. Thus the market 
share of band G tyres (see ta ble 11B below) is likely to decrease somewhat faster over 
time than it otherwise would. Initial requi rements could be introduced from 2012. At a 
later stage (say 2 years) it is envisaged th at approvals to the lowest band would cease.  
Table 11B –Modified Grading System  
Maximum rolling resistance coeffi cient per band (kg/tonne) 
Tyre 
Category 
Band 
A Band 
B Band 
C Band 
D Band 
E Band 
F Band 
G 
C1 4.5 6.0 7.5 9.0 10.5 12.0 13.5 
C2 4.5 5.5 6.5 7.5 9.0 10.5 12.0 
It is estimated th at the 3.3 g/km CO 2 reduction figure quoted  by TNO would correspond 
to a tyre falling between categor ies E and F in the above table. 
Further analysis of any labelling system w ould be needed. Therefore this proposal would 
be limited to setting minimum requirements for type approval. Actual requirements for 
labelling will be introduced through other regulatory acts. 
The 2007 consultation proposed limit values of  13.5 for C1 and 12.0 for C2 (equivalent 
to Band G in the table above) However, further research pr esented at the International 
Transport Forum15 suggested that lower values were achievable in the short term. Thus a 
first phase implementation of mandatory limits  based on Band F would seem reasonable, 
followed by a minimum requirement of Band E as a second stage.  
                                                 
15 See http://www.internationaltransportforum.org/docs/SPnordwijk07.pdf 
 
EN 46   EN 4.3.3.  Tyre Pressure Monitoring Systems 
4.3.3.1.  Benefits 
Tyre Pressure Monitoring Systems offer be nefits in terms of both casualty and CO 2 
reduction.  
4.3.3.1.1. Safety Benefits The study referred to in 4.3.1.1.1 indi cated that if all cars were fitted with effective tyre 
pressure monitoring systems, then annual savings of around 29 fatalities, 340 serious 
injuries and 3350 slight injuries could be fore seen. Applying the values  in table 3 leads to 
annual casualty savings of € 155million. Ba sed on a vehicle stock of 220 Million, the 
saving comes to around € 0.7 per vehicle per year. 
4.3.3.1.2. CO2/ fuel saving benefits. The potential fuel saving benefits arising fr om the use of a TPMS system depends on the 
degree of under-inflation of ty res in current use, and the degree to which TPMS systems 
can address this. There are a number of studies  ongoing in this area, which indicate that 
the under-inflation problem varies consider ably between Member States. The TNO study 
(section 5.3) looked at the CO2 benefits of  TPMS using a similar methodology to their 
analysis of LRRT. It estimated that an accura te TPMS system could generate fuel savings 
of 2.5%. Using an average car usage of 16,000 km the annual savings per car could come 
to between 6€ (assuming a fuel price of 0.21€ /litre) and 16 € (assuming 0.6€ /litre). In 
line with normal cost-benefit methodology the above fuel costs do not include indirect 
taxes. However, in reality the fuel cost to the motorist will include such taxes, thus the annual fuel cost saving due to the use of  TPMS will be considerably greater than 
indicated above.  
The associated saving on CO
2 would be 0.09 tonnes per year (well to wheel). In the 
longer term, a TREMOVE analysis has predic ted that the mandatory fitting of TPMS 
systems meeting the above specifications, pha sed in from 2012, woul d result in a total 
reduction of CO2 emissions from passenge r cars of 1.6% in 2020 and 2.3% in 2030.  
4.3.3.2.  Costs 
The TNO study assumed that the additional cost of fitting a TPMS tyre system to a car 
would be € 50. However TNO suggests this cost might rise by around 25% bearing in 
mind that the accuracy of TPMS systems woul d have to improve over current levels in 
order to be effective at improving fuel consumption (although the present level of 
accuracy will still yield the safety benef its) . More recent information received via 
suppliers suggests that the current cost  of a system which exceeds the current 
requirements is around € 30, Assuming a ve hicle life of 13 years and no additional 
maintenance costs this works out at € 2.3 per vehicle per year. Allowing for a 25% 
increase to ensure that future requirements ar e met, this still comes to just under €3 per 
vehicle per year.  
4.3.3.3.  Options for introducing Tyre Pressure Monitoring Systems 
The options identified from table 2 were as follows: 
 
EN 47   EN a) Do nothing and allow the market to take the initiative. 
b) Establish technical standards for such sy stems (where fitted) and allow manufacturers 
to fit them optionally. 
c) Establish technical standards a nd mandatory fitting requirements. 
In the case of LRRT there wa s the additional manufacturer incentive to supply new cars 
with LRRT in order to reduce that  vehicle's fuel consumption or CO 2 emission rating and 
thus comply with the Commission's future ta rget. However, this would not apply with 
TPMS since TPMS does not affect the fuel consumption or CO 2 rating of a new car 
(since a car will be tested for its fuel cons umption with its tyres correctly inflated). 
However, TPMS can affect the fuel consum ption of a car in 'real world' driving 
conditions.  
Option a) would allow the continued use of TPMS systems to current standards, which 
may yield the safety benefits described in section 4.3.3.1.1 but are unlikely to be sufficiently accurate to yield the CO
2 and fuel saving benefits  described in section 
4.3.3.1.2. Thus a cheaper system costing €2.5 pe r vehicle per year would only provide 
the safety benefits of €0.7 per vehicle per ye ar. Following the market approach (option a) 
would encourage cheaper systems which woul d give little or no fuel consumption 
benefits and could in fact make things worse since a driver might be tempted to allow his 
tyre pressures to fall until the TPMS alert was activated, which could be considerably 
below the normal tyre pressure. However, a more expensive system costing €3 per 
vehicle per year would yield the full be nefits of between €6.7 and €16.7 per year 
depending on fuel prices. Thus setting a higher standard (as in option b) would result in a 
net benefit to the driver in the range of between €3-13 even before considering the environmental benefits. To maximise the bene fits, and to ensure the maximum likelihood 
of reaching the CO
2 reduction targets, option c) would be preferred. 
Subject to the agreement of satisfactory tec hnical standards, it is envisaged that TPMS 
requirements could apply from 2012 to passenger cars. TPMS for other vehicle 
categories could be added at a later date, subject to technical feasibility and the 
development of appropriate standards. 
4.3.4.  Wet Grip Requirements 
4.3.4.1.  Benefits 
Generally, it is considered that current tyre designs offer a good degree of wet grip 
performance and there has been no identified need  to increase this level of performance. 
Indeed, the wet grip procedure developed for car tyres in UNECE Regulation 117 (and 
which is proposed for this regulation) does not require a significan tly greater wet grip 
performance than current tyres. The main purpose is to ensure that there is no 
deterioration of wet grip perf ormance as a result of designi ng tyres to meet low noise 
and/or rolling resist ance requirements.  
4.3.4.2.  Costs 
As current tyre designs are considered to meet the proposed requirements, there is 
unlikely to be any additional development or production cost involved in meeting the wet 
 
EN 48   EN grip requirements. There may be costs i nvolved in meeting the noise and rolling 
resistance requirements without compromising the wet grip requireme nts but these costs 
would be attributed to the noise/rolling resistance development costs covered under sections 4.3.1.3 and 4.3.2.2. The only additional cost to the manufacturer is likely to be 
the cost of approval testing, which is estimated at €1,000 per tyre type. Even assuming a 
modest production run of 100,000 tyres per type, the resulting cost pe r tyre is €0.01, so 
the cost can be considered as negligible. 
Therefore it can be concluded that there are no additional cost or benefits of introducing 
wet grip requirements, and the main purpos e of introducing such requirements is to 
maintain the 'status quo'. 
4.3.4.3.  Options for Introducing Wet Grip Requirements 
As indicated in table 2, it is considered th at only the option of a mandatory requirement 
for wet grip for car tyres (on the basis of  UNECE Regulation 117) should be considered, 
otherwise there is a risk that  some design solutions to ach ieve lower noise or rolling 
resistance could result in a reduction in safety. There is no evidence of the need for a tighter wet-grip standard than the Regulati on 117 standard. It is possible that the tyre 
labelling proposed for rolling resistance (and possibly noise) could indicate if the wet 
grip performance exceeded the minimum re quirement. This additional performance 
would be at the manufacturer's discretion, therefore there woul d be no additional 
regulatory cost if this option were take n. Thus, as far as the minimum regulatory 
requirements are concerned, the preferred option is  to require all car tyres to meet at least 
the wet grip requirements of UNECE Regula tion 117. Since most car tyres would already 
meet this requirement, it could be introduced  with the minimum lead time (say 2 years 
from adoption of any Regulation). Work is und er way to develop a standard for wet grip 
for C2 and C3 tyres which is likely to be in corporated into Regulation 117 in the future.  
5. M
ONITORING AND EVALUATION  
The proposed Regulation will take effect through the vehicle type-approval process. 
Vehicle manufacturers will need to demonstrat e that vehicles comply with – amongst 
other things – the test requirements specifi ed in order to rece ive a type-approval 
certificate. 
Monitoring of the effect of the Regulation is effectively undertaken by type-approval 
authorities who oversee in-use compliance processes to ensure that the requirements of 
the Regulation are met. More generally, m onitoring data, which are required on those 
tests specified for monitoring purposes only, wi ll provide the necessary basis for further 
development of requirements, while also giving  an indication of the wider success of the 
policy. 
6. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
6.1. Internet Consultation. 
An internet consultation covering outline proposals on all the aspects covered by this 
Impact Assessment was carried out between August and October 2007. Around 80 
 
EN 49   EN responses were received. Thes e are available on the website 
http://ec.europa.eu/enterpri se/automotive/index_en.htm  In summary, the breakdown of 
responses was as follows: 
Twelve responses were from Member States , four were from non-MS governments, four 
from other (mostly regional ) government or ganisations, 29 were from industry/business 
organisations, 27 from NGOs, professional orga nisations and research  groups and 5 from 
private individuals. There wa s general support for most of the measures proposed. 
However, some of the main comments, and our responses, are give n in table 12 below. 
 
EN 50   EN Table 12 – Summary of Internet Consul tation Responses on Main Issues  
Comment Respondent (s)  DG ENTR Response 
Simplification issues   
New regulation not 
necessary. Simplification would be achieved by referring directly to UNECE Regulations within Type-approval Framework Directive  ACEA and some member 
vehicle manufacturers Direct reference would 
remove the EU's power to improve safety or environmental requirements if the relevant UNECE Regulation was inadequate or could not be improved.  
Advanced Safety Issues   
Additional safety features 
should be mandated such as ISOfix, seat belt reminders, alcohol locks, Intelligent Speed Adaptation, Advanced lighting systems Various Features such as ISOfix and 
seat belt reminders will be mandated by reference UNECE Regulations. Other features could be mandated under the proposed Regulation at a late date, subject to further cost/benefit analysis. 
Too early to mandate systems such as AEBS Vehicle manufacturers 
AEBS possible for new 
types of heavy vehicle by 2010, light commercial vehicles by 2012, cars by 2014. CLEPA (vehicle 
system/component manufacturers). Accept need to set realistic 
timescale and to limit the scope of applica tion, at least 
initially, to heavy goods vehicles and buses. 
Tyre issues   
Proposed noise standards 
unfeasible  Vehicle and tyre 
manufacturers 
Proposed noise standards not sufficiently ambitious  Various environmental 
organisations. FEHRL report, supported 
by TRL and M+P reports, suggest proposal is feasible. However, we accept the need for adequate lead times to allow manufacturers to comply. 
Rolling resistance banding unambitious (will not drive market forward)  Various Accept that banding will 
need to be refined, using a seven band system. However, this may be implemented through a 
 
EN 51   EN separate regulatory Act 
TPMS (various estimates of 
required level of accuracy, ranging from 10-25%) Various Required technical 
specifications for TPMS will be discussed at Working Group level. 
 
6.2. Opinion of the Impact Assessment Board 
 
A draft version of the present impact a ssessment report was examined by the Impact 
Assessment Board (IAB). The opinion of  the IAB formulated a number of 
recommendations on the draft impact assessment. These recommendations have been taken into account in the final document in the following way: 
 
Recommendation 1. Paragraph 1.2 has been expanded to explain how the safety 
measures not specifically covered under th is Regulation are covered by other EU or 
UNECE legislation. Annex I has also been clarified in this respect.  
 
Recommendation 2. Paragraph 4.1 has been expanded to clarify how the move towards 
UNECE-based Regulations will aid simplification and competitiveness.  
 
Recommendation 3. A new Annex II has been added to provide a summary of the costs 
and benefits of the various features un der discussion. In addition, a new Annex III 
provides a full analysis of the current s ituation concerning the European Automotive 
industry, plus a discussion a bout the possible impact of th e proposals discussed in this 
Impact Assessment on retail prices and affordability.   
 
Recommendation 4. Paragraph 4 has been amended in each section to give approximate 
implementations times and, where appropriate , to explain why the market-mechanism is 
insufficient to achieve the desired safety and environmental object ives. In addition, the 
table in Annex II gives estimates of the per centage of new vehicles which are already 
fitted with the feature under discussion. 
 
Recommendation 5. Various references to research stud ies have been have been updated 
and expanded where appropriate  
 
EN 52   EN ANNEX  I 
POTENTIAL CASUALTY SAVINGS ACHIEVABLE THROUGH VARIOUS 
TECHNOLOGIES . 
0100020003000400050006000700080009000
Advanced Emergency BrakeLane Departure Warning
ESC on Cars
ESC on Trucks
TPMS
Seat Belt Reminders
ABS on Motorbikes II Pedestrian Protection
Conspicuity Marking 
e-call Pan-European
DRL05000100001500020000250003000035000400004500050000Fatalities Severe InjuriesAvoidable
Severe InjuriesAvoidable Fatalities
Measures covered by this 
documentMeasures covered by other existing or future proposals 
 
 
EN 53   EN ANNEX II COMPARISON OF COSTS AND BENEFITS FOR VARIOUS 
TECHNOLOGIES  
Table 1. Advanced Safety Features  
Note: The following table gives an indicative comparison between the costs and benefits 
of various technologies. Due to the different source data used, some of the assumptions 
used (for example, on vehicle fleet sizes an d casualty costs) may differ, so comparisons 
should be treated with caution).  
Electronic Stability Control Advanced Emergency 
Braking  
Light 
vehicles  Heavy 
vehicles  Light 
vehicles  Heavy 
vehicles  Lane 
Departure 
Warning  
(all vehicles)  
Increase in 
vehicle cost € 250 1000 1000 1000 600 
 Fatalities 
saved (per annum)_  2250 
500 7000 1020 5500 
Serious 
injuries saved 
(per annum)  23000 2,500 17000 4280 30800 
Slight injuries 
saved (per 
annum) 260000 0 -15000 -1800 208500 
Value of 
casualty 
savings per 
annum (Million €) 10, 802  
867 9,213 1608.9 14, 824 
Total per 
vehicle per 
year € 127 148 54.5 275 84.7 
Total value of 
casualties 
saved though 
13 year vehicle life € 1651 
1926 708.5 3575 1101 
Present value 
€ 991 1155 425 2147 661 
Benefit /Cost 
Ratio 3.97 1.16 0.43 2.15 1.1 
 
 
EN 54   EN Table 2 ;Summary of Tyre Measures (light vehicles only)  
 Tyre noise 
proposal Rolling 
resistance proposal  Wet grip 
proposal TPMS 
Increased technology 
cost per vehicle 
(average) € 15 60 0 40 
Value of noise 
reduction (per car per 
annum) €  53.2 - - - 
Value of CO 2 
reduction.(tonnes/year)- 0.09  - 0.09  
Fuel savings per car 
per annum - 13** - 11** 
Casualty savings per 
car per annum € - - - 0.7 
Savings over tyre 
lifetime (car lifetime for TPMS) 159.6 39 - 152.1 
Present value (at 4% 
discount)  142 34.6 - 91.3 
Benefit /cost ratio 9.46 0.53 1*** 2.28 
 
                                                 
** Average estimate. This value is sensitive to fuel cost. See section 4.3.2.1. 
*** No technology cost. Approval cost can be disregarded when spread over entire tyre production. 
Possible slight casualty reduction but this can not be quantified. 
 
EN 55   EN Table 3 – Effect on Initial Vehicle Cost  
Light vehicles € Heavy vehicles €  
 Cost of 
technology Percentage 
of vehicles currently fitted Average 
increased cost per vehicle (where mandatory)  Cost of 
technology Percentage 
of vehicles currently fitted Average 
increased cost per vehicle (where mandatory) 
Advanced safety systems   
ESC 250 50 125 1000 10 900 
AEBS 1000 0 optional 1000 0 1000 
LDW 600 0 optional 600 10 540 
Total advanced 
safety  1850  125 2600  2440 
Tyres    
noise  15 50 7.50 30 50 15 
LRRT 60 50 30 120 50 60 
wet grip  0 95 0 N/A N/A N/A 
TPMS 40 0* 
 40 N/A N/A N/A 
Total tyres 115  77.50 150 100 75 
Total/vehicle 1965  202.50 2750  2515 
 
                                                 
* Some TPMS systems are fitted, but do not meet the proposed standards.  
 
EN 56   EN Assumptions used in tables 1-3 
1) Annual cars registered in the EU = 13 million . 
2) Number of heavy duty vehi cles subject to ESC requirements registered per year 
= 450,000 
3) Lifetime of a vehicle = 13 years. 4) Lifetime of a tyre = 3 years  5) Fuel costs used do not include taxes 6) Some slight injuries will increase, due to  serious or fatal injuries being mitigated 
to slight injuries. 
 
EN 57   EN ANNEX  III 
CONSIDERATION OF THE PRODUCTION , EMPLOYMENT AND AFFORDABILITY EFFECTS OF 
THE PROPOSALS COVERED BY THIS IMPACT ASSESSMENT  
This Annex is structured into two parts:  the first provides quantitative data and a 
summary discussion of the main indicators for the automotive indus try while the second 
engages in a discussion about the possible im pact of the proposal on retail prices and 
affordability. 
1. Overview of the main production, sales, trade and employment indicators 
1.1. Production and sales of vehicl es in the European Union  
Together with North America and Asia, Europe  is one of the larg est vehicle production 
locations globally as well as one of the main automotive markets in the world. The 
graphs below present the number of vehicles  produced and sold in the European Union 
since 2004 together with a forecas t for the 2012 and 2017 timeframe. 
Graph 1: Production of vehicles in the European Union16 
16,500,00017,000,00017,500,00018,000,00018,500,00019,000,00019,500,00020,000,00020,500,00021,000,00021,500,00022,000,000
2004 2005 2006 2007 2012 2017Number of units
 
Source: Global Insight 
                                                 
16 Data covers: Austria, Belgium, Bulgaria, Czech  Republic, Finland, Fran ce, Germany, Hungary, 
Italy, Lithuania, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom. 
 
EN 58   EN Graph 2 Sales of vehicles in European Union 
16,000,00016,500,00017,000,00017,500,00018,000,00018,500,00019,000,00019,500,000
2004 2005 2006 2007 2012 2017Number of units
 
Source: Global Insight 
As can be seen from the above, both vehicle production and sales in the European Union 
are expected to increase in the medium te rm perspective and the Commission does not 
foresee that the current proposal will have an impact  on this trend, wh ich is impacted by 
a host of factors which are entir ely independent of EU regulati ons in the field of vehicle 
safety (e.g. product planning, future market outlook, previous capital  expenditure, labour 
costs, future marketing strategies of differe nt vehicle manufacturers, agreements reached 
between company managements and employee representatives etc.). Production figures 
in 2012 and 2017 respectively are expected to  be 8.7% and 10.2% higher than in 2007. 
Although most European countries are involv ed in the automotive value chain, its 
relative role in the economic structures of  different EU Member States can vary 
significantly. Given that the as sessment of the potential economic and social impacts of 
legislative proposals should provide an indi cation of possible distributional effects 
between different European regions, the ta bles below show the break-down of vehicle 
production and sales by different  Member States (includi ng a forecast for the 2012 and 
2017 perspective). 
Table 1: Production of vehicles in the Eu ropean Union by selected member states 
 2004 2005 2006 2007 2012 2017
Austria 222,634 230,794 252,948 237,353 125,778 100,627
Belgium 525,156 538,362 560,215 530,744 702,950 678,739
Bulgaria 0 0 0 0 231 257
Czech Republic 446,320 602,288 851,988 901,519 1,184,760 1,267,183
Finland 10,510 21,644 32,746 24,184 30,757 32,894
France 3,652,427 3,535,162 3,153,186 2,977,140 3,190,728 3,196,215
 
EN 59   EN Germany 5,559,861 5,751,353 5,811,062 6,197,594 6,582,612 6,521,372
Hungary 117,184 148,371 187,770 295,279 334,960 369,523
Italy 1,140,226 1,036,907 1,209,978 1,334,243 1,428,590 1,316,604
Lithuania 649 1,256 1,529 1,970 2,869 2,922
Netherlands 223,342 156,584 131,834 110,574 146,934 130,586
Poland 590,476 616,713 718,504 791,816 977,560 969,641
Portugal 224,392 219,455 222,603 174,194 166,118 175,035
Romania 122,185 194,802 213,589 218,801 555,526 534,922
Slovakia 181,498 177,511 267,088 520,430 699,354 719,988
Slovenia 131,761 177,945 153,126 200,350 119,389 157,919
Spain 2,945,162 2,676,659 2,703,515 2,870,131 2,766,660 2,934,843
Sweden 504,572 498,931 493,826 513,070 494,348 507,613
United Kingdom 1,854,873 1,801,618 1,648,522 1,709,331 1,750,036 1,936,583
Source: Global Insight 
Table 2: Sales of vehicles in the Eur opean Union by selected member states 
 2004 2005 2006 2007 2012 2017 
Austria 349,850 344,934 346,554 338,386 346,911 351,295
Belgium 599,930 600,345 645,536 649,962 609,621 588,626
Bulgaria 25,785 34,478 45,422 56,413 76,370 88,727
Czech Republic 167,423 171,990 178,928 196,136 253,163 289,775
Denmark 170,557 208,689 225,630 228,430 237,928 225,368
Estonia 19,461 23,433 30,741 39,644 45,426 47,859
Finland 164,102 167,710 166,225 152,664 169,966 172,958
France 2,468,173 2,542,135 2,493,250 2,531,835 2,667,363 2,674,008
Germany 3,537,744 3,603,968 3,760,299 3,477,743 3,777,892 3,851,811
Greece 311,719 293,186 291,441 305,445 340,102 354,286
Hungary 235,629 225,479 206,345 203,940 252,084 279,202
 
EN 60   EN Ireland 187,520 212,171 222,894 235,849 228,787 217,754
Italy 2,522,000 2,489,233 2,590,332 2,743,041 2,562,713 2,539,906
Latvia 13,707 19,750 30,337 42,677 52,583 58,721
Lithuania 13,509 16,025 21,472 30,937 38,702 44,163
Netherlands 583,989 544,481 567,647 595,506 606,602 590,250
Poland 366,892 282,585 295,008 365,807 522,705 595,808
Portugal 273,871 277,743 264,586 266,842 375,392 401,052
Romania 180,567 255,912 294,649 353,294 418,759 482,057
Slovakia 70,318 74,642 82,902 90,482 106,716 116,546
Slovenia 71,115 68,949 68,078 78,730 86,792 92,997
Spain 1,887,816 1,956,031 1,949,165   1,924,662 1,890,246
Sweden 299,959 314,951 328,687 347,896 343,655 338,146
United Kingdom 2,953,401 2,821,500 2,727,607 2,774,841 2,810,868 2,842,804
Source: Global Insight 
Finally, the current vehicle produc tion situation in Europe is presented in Figure 1 below, 
which indicates the main automotive production sites in Europe.
 
EN 61   EN Figure1 - Automotive production loca tions on the European continent 
 
Source: European Automobile Manufacturers Association (ACEA) 
The main conclusion to be drawn from the above is that most of the EU countries 
currently hosting automotive i ndustry production facil ities are forecast to see production 
remain stable or increase in terms of output units. Biggest grow th in output is expected to 
occur in the new Member States (particula rly Romania, Slovakia, the Czech Republic 
and Poland) while vehicle producti on is expected to see a sli ght decline in Austria, Italy, 
Sweden and, surprisingly, Slovenia. 
1.2. Trade performance  
Trade in automotive products makes a significant contribution (ca. € 60 billion) to the 
European Union’s trade balance. This is de monstrated by graphs 3and 4 below, which 
show Europe’s trade performance in vehicles, accessories and parts by both unit and monetary values.
 
EN 62   EN Graph 3: Imports and export EU-27 – extra EU-27 for motor vehicles, tractors, 
accessories and parts expressed in number of units traded 
050,000,000100,000,000150,000,000200,000,000250,000,000
2004 2005 2006Number of units
Import Export
 
Source: Eurostat 
Graph 4: Imports and export EU-27 – extra EU-27 for motor vehicles, tractors, 
accessories and parts expressed in value in Euros 
020,000,000,00040,000,000,00060,000,000,00080,000,000,000100,000,000,000120,000,000,000140,000,000,000
2004 2005 2006Value in euros
Import Export 
Source: Eurostat 
Generally, the most profitable part of the European automotive industry is the 
manufacture of larger, premium vehicles whic h accounts for ca. € 9 billion of the approx. 
€ 15 billion total profits made by the European automotive industry. This trend is also reflected in trade statistics where an ove rwhelming proportion of trade revenues from 
cars is earned from the export of petrol vehi cles with an engine sizes of between 1,500 
and 3,000 cm
3 and petrol vehicles with engine capacities over 3,000 cm3. Trade data for 
different vehicle segments as de fined by engine type and size is presented in graphs 5 and 
6 below. 
 
EN 63   EN Graph 5: Imports and export EU-27 – extra EU -27 by engine type and size (units) 
0500,0001,000,0001,500,0002,000,0002,500,000
Imports 2004 Exports 2004 Imports 2005 Exports 2005 Imports 2006 Exports 2006Number of units
Petrol <= 1.000 CM³
Petrol  > 1.000 CM³ BUT <= 1.500 CM³
Petrol > 1.500 CM³ BUT <= 3.000 CM³
Petrol > 3.000 CM³
Diesel <= 1.500 CM³
Diesel > 1.500 CM³ BUT <= 2.500 CM³
Diesel > 2.500 CM³ 
Source: Eurostat 
Graph 6: Imports and export EU-27 – extra EU -27 by engine type and size (value) 
05,000,000,00010,000,000,00015,000,000,00020,000,000,00025,000,000,00030,000,000,00035,000,000,000
Imports 2004 Exports 2004 Imports 2005 Exports 2005 Imports 2006 Exports 2006Value in euros
Petrol <= 1.000 CM³
Petrol  > 1.000 CM³ BUT <= 1.500 CM³
Petrol > 1.500 CM³ BUT <= 3.000 CM³
Petrol > 3.000 CM³
Diesel <= 1.500 CM³
Diesel > 1.500 CM³ BUT <= 2.500 CM³
Diesel > 2.500 CM³ 
Source: Eurostat 
The fact that Europe primarily exports medium  and large petrol vehicles is related not 
only to the quality of Europ ean-produced and branded vehicles in those segments but 
also to the fact that for high quantity mass market vehicles manufacturers tend to produce 
on, or close to the markets in which their sa les take place. Conse quently, it is unlikely 
that any cost increases resulting from th is proposal will have a major impact on the 
 
EN 64   EN ability of European producers to conti nue successfully exporting in the premium 
segments because in many cases the technologies covered have already been implemented in these segments (or are available as optional extras). 
It should also be noted the current demand structure in emerging markets suggests that 
exporters of new premium vehicles generally have a customer base, which is relatively 
price insensitive while the buyers of “mass market” vehicles tend to be very price-
conscious, which suggests that added cost to mass-produced ve hicles is unlikely to give 
European producers a competitive advantage in those segments. However, given that mass market products are mo re likely to be produced  in situ  using production facilities 
which do not correspond to those used for the Eu ropean market, it is likely that the scope 
of any disadvantage would be reduced. On the other hand, it should also be noted that the 
competitive advantage which safer and more fuel efficient vehicles could provide is likely to become more relevant in emergi ng markets with the passage of time and the 
creation of a larger middle-class customer base . Market experience in the mature markets 
(such as Europe) has shown that  with increasing prosperity, consumers are willing to pay 
more vehicles with an enhanced safety performance.  
1.3. Employment
 
Table 3 below presents the data for employment in the vehicle manufacturing and parts 
sector broken down by diffe rent Member States. 
Table 3: Number of persons employed in  the- manufacture of motor vehicles  
and the manufacture of parts & accessories for motor vehicles  
 MOTOR VEHICLES PARTS AND ACCESSORIES 
 2003 2004 2005 2003 2004 2005 
Belgium 31,774 29,336 28, 890 10,770 11,353 11,323
Bulgaria 142 207 c 2,151 2,070 2,675
Czech Republic c c c 57,072 62,788 :
Denmark c c c c c 3,904
Germany 526,057 526,934 516,639 300,991 304,748 309,401
Estonia 99 103 136 1,283 1,310 1,297
Ireland 247 291 299 2,572 2,500 2,627
Greece : 1,467 1, 081 : 949 815
Spain 77,327 75,100 74,551 72,629 73,160 70,591
France 172,121 168,200 167,536 86,589 82,752 79,587
Italy 59,462 66,533 67, 599 87,934 84,395 83,355
 
EN 65   EN Cyprus 0 0 0 227 151 128
Latvia 172 0 20 168 236 362
Lithuania 66 147 159 387 208 269
Hungary 9,977 10,338 9,575 27,989 28,669 30,735
Netherlands 10,589 10,471 9,789 6,080 4,620 4,631
Austria 15,484 16,999 16,758 10,990 13,142 13,344
Poland 24,253 26,696 28, 405 55,926 68,928 73,207
Portugal 8,046 6,740 6,682 11,521 12,376 13,018
Romania c c 16,262 39,828 46,619 42,110
Slovenia 2,410 c 2,997 3,359 c 3,870
Slovakia c c c 9,954 10,636 11,060
Finland 2,871 2,110 2,194 800 757 784
Sweden 45,247 48,273 50, 114 26,246 27,345 26,247
United Kingdom 95,054 89,278 85,898 95,012 88,471 80,982
Total 1,081,398 1,079,223 1,085,584 910,478 928,183 866,322
Source: Eurostat 
It should be noted, however, that the data a bove does not present the full picture of the 
automotive value chain a graphical expression of which has been presented in Figure 2 
below.  
Figure 2: The automotive value chain  
 
 
             Raw materials 
provision (e.g. 
steel, rubber 
etc. 3rd tier 
suppliers 
(parts and 
components) 2nd tier 
suppliers 
(system 
specialist) 1st tier suppliers 
(system 
integrator, 
module supplier  
OEMs 
(Final Product) 
Aftermarket
(parts) Energy Servicing Finance 
 
EN 66   EN Given that a number of automotive production re lated activities are no t reflected in the 
statistical classification as presented in the above table (e.g. electrical equipment for 
engines and vehicles, steel and aluminium produ ction, paints, tyres, synthetic and textile 
products, servicing and repair etc.) one can safely assume  that the whole automotive 
value chain provides employment for signi ficantly larger number of people.  
It should also be noted that automotive suppl iers account for circa 2/ 3 of the final product 
and over 50% of research in this sector. Eff ective supply chain management is one of the 
key competitive advantages of the European  industry while production of advanced 
components is an important strength of the European supply industry. As suppliers play 
an increasing role in the value chain over time , increased vehicle value is often viewed as 
a key avenue for future growth  in the supplier industry, partic ularly given that Europe is 
well represented with specialist suppliers. Given that the proposal is expected to further 
increase the value of vehicle components included in the fina l product, it is likely that the 
proposal could lead to a rise in direct employment depe nding on what shar e of extra costs 
were to go into extra labour. 
It should be borne in mind that the additiona l features proposed by th is legislation do not 
require the development and introduction of revolutionary new technologies but relate 
rather to the further proliferation of alrea dy available technologies  throughout the entire 
vehicle fleet. Consequently, it is not expected that this pr oposal will create a dramatic 
technological shift but will rather pose the que stion of how available technologies are to 
be introduced into the lower segments of the market.  
There is currently a substant ial consolidation process under way in the supplier industry 
despite the fact that the s uppliers’ volume of production has more than doubled over the 
last 10 years (due to continued outsourcing of manufacturing and services by end-product 
manufacturers and an increasing number of vehicle fittings many of which are also 
purchased externally). There are a number of  reasons for this process which, among other 
things, reflect the heterogeneity  of the suppliers (small-and medium sized suppliers have 
experienced difficulties in accessing capit al, there has been significant downward 
pressure on prices initiated by manufactur ers seeking to cut costs, passing higher 
commodity prices on to consumers has at times  been difficult for a number of component 
manufacturers, competition between suppliers ha s intensified etc.) but the overall effect 
has been increased pressure to rationalise the market and promote mergers17.  
2. Affordability and impa ct on retail prices 
The main issue regarding the impact of new legislation on affordability usually concerns 
smaller vehicle categories. This is the case because it is assumed that larger, premium 
vehicles will already contain many of the ne w features introduced by legislation and will 
hence be less effected than lower sections of the market. Additional concerns are raised because the larger profit margin s of larger vehicles should enab le for an easier absorption 
of additional costs while purchasers of bigger and more expensive cars are also better positioned to pay increased retail prices should costs be directly passed on to the 
                                                
 
17 A study by Mercer Management Consulting and Fr aunhofer Gesellschaft foresees that despite the 
expected substantial expansion in production and added value in the industry, the number of 
independent component manufacturers worldwide w ill decrease from 5,600 in 2000 to 2,800 in 
2015. 
 
EN 67   EN consumers. Finally, discussions about afford ability stress the higher proportional impact 
on the total price of the car in smaller (and cheaper) vehicle segments as well as raising 
the issue of purchasing power where it is assumed that hous eholds with smaller incomes 
tend to buy smaller new cars. This section will gi ve some consideration to these issues in 
the light of the proposed legislation. 
2.1. Different vehicle segments  
Some of the options discussed in section 4 of the Impact Assessmen t would make several 
features which are currently optional, mandato ry. This would, first and foremost, impact 
smaller vehicles as well as having a differe nt impact on different Member States where 
different technologies have penetrated the market to varying degrees. Table 4 below 
provides a summary of the assumed additional cost to new vehicles assuming that the 
options for mandatory fitting were chosen. 
Table 4: Ex-ante additional cost  assumptions of the proposal  
Electronic Stability Control €12518 
Advanced Emergency 
Breaking €25019 
Lane Departure Warning €60020 
Low Rolling Resistance 
Tyres/noise/wet grip €60 Advanced Vehicle Safety 
Features and Tyres 
Tyre Pressure Monitoring 
Systems €30 
From an affordability perspective the effect  on different vehicl e segments is highly 
relevant because profitability cushions to  absorb additional compliance costs vary 
substantially between segments while the cost  of complying with regulatory requirements 
will also vary for vehicles in different secti ons of the market. Table 5 below presents the 
profit estimates per vehicle segment. 
SEGMENT ESTIMATED PROFIT PER 
VEHICLE 
Small  (e.g. Renault Clio, Peugeot 107)  €150 - €400 
Compact  (e.g. Audi A3, Citroen C4)  €650 - €900 
Medium (e.g. BMW 3 series, Skoda €900-€1500 
                                                 
18 Average cost across the car fleet assuming that 50% of new cars are already equipped with ESC 
and that all cars are fitted with an ti-lock breaking systems (ABS). 
19 Assumes that new cars are already equipped with ABS and Brake Assist. 
20 Assumes that new cars are already equipped with Advanced Emergency Braking Systems and that 
some sensors can be shared between the systems. 
 
EN 68   EN Octavia)  
Large (e.g. Mercedes E-Class, BMW 5 
series)  €2600-€2700 
Source: A.T. Kearney 
There is hence little doubt that premium se gment vehicles are better positioned to pass 
additional costs on to consumers.  
2.2. Additional considerations rega rding retail price developments  
From an affordability perspective therefore, the primary question relates to the 
development of costs over time and the extent to which companies will choose to pass costs on to their customers. Three main c onsiderations should be borne in mind: 
• Economies of scale: the building up of production capacities and volumes for 
different products is an important part of the automotive industry’s modus operandi  
because this represents one of  the most effective means of cost reduction. The cost of 
diesel particulate f ilters which have under gone a significant decrease with increased 
market penetration and production volumes of fers a good example. Mu ch of the actual 
future price impact will depend on the speed with which such economies of scale are achieved. This consideration is very releva nt to this legislativ e proposal given that 
most the technologies covered by the propos al are already on the market and have 
been of production for some time. Furtherm ore, the automotive industry has for long 
been aware that legislation will be proposed with regard to the issues covered given 
that the proposed technologies were di scussed in the CARS 21 High Level Group.  
• Initial investment retrieval interval: cost pass-through to consumers is not static. In 
addition to developing economies of scale, there can be a tendency for manufacturers 
to attempt the recuperation of product deve lopment costs in the early stages of 
marketing (in the automotive sector this c ould be ca. 3-5 years) . After this initial 
period, product prices can fall relatively quickly.  
• Competitive- and market environm ent in the automotive sector: some segments of 
the automotive market are characterised by increased competitive pressure and strong 
price competition. This is particularly th e case in the small and medium segments, 
which raise most of the affordability concerns. This has led to an increase in the share of earnings, which manufacturers attempt to de rive from post-sale activities (e.g. spare 
parts, financing etc.) as these offer higher profit margins than traditional 
manufacturing activity. However, strong sales of the core product (i.e. the car itself) 
are a pre-requisite for accessing such a dditional earnings. The combination of 
competitive pressure and future earnings potential can lead to a situation where 
margins are lowered, which can in turn be reflected in the retail price.  
2.3. Historical retail price developments
 
Given the number of factors which influen ce the pricing strategy of companies in the 
automotive sector, it is very difficult to pred ict the future monetary impact of individual 
elements proposed by legislation. However, gi ven that the automotive industry has a long 
 
EN 69   EN history of responding to regulat ory requirements it is worthwhile looking at empirical 
evidence of car price developments in or der to assess possible future impacts.  
Historical price developments in the automotiv e sector indicate that  the EU price index 
for cars (reflecting actual prices paid by  consumers, including VAT and registration 
taxes) has for some time been increasing at  a substantially lower rate than headline 
inflation. Graph 7 below presents the comp arison between the two from 2003 onwards. 
Graph 7: Comparison between headline inflation and car price developments 
00,511,522,53
May 2003-May 2004 May 2004-May 2005 May 2005-May 2006 May 2006-May 2007%EU price index for cars
Headline inflation
 
Source: DG Competition 
In real terms, car prices have been declining.  
2.4. Additional consideration on affordability  
It is often assumed that vehicle size provide s a good proxy for assessi ng social equity: the 
implication being that buyers of new smaller vehicles are households  with proportionally 
lower purchasing power. It is important to point out that while this may hold true 
partially, car size cannot be considered to  be a perfect proxy insofar as it does not 
account for the ability of households to purchas e vehicles on the second-hand market as 
well as the practical needs of individual fa milies (e.g. a family consisting of 4 members 
may not find that purchasing a new “small”  vehicle would best serve their needs).