EN    EN EN 
558340 DT Two- or Three-wheel vehicles and Quadricycles 
Impact Assessment 
 
EN    EN  EUROPEAN COMMISSION 
 
Brussels, 4.10.2010 
SEC(2010) 1152 
  
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the  
 
Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
on the approval and market surveillance of tw o- or three-wheel vehicles and quadricycles 
 
 
Impact Assessment 
This report commits only the Commission departm ents involved in its preparation and does not 
prejudge the final form of any decision to be taken by the Commission. 
Lead DG: DG Enterprise and Industry Commission Work Programme 2010 
Commission’s Agenda Planning: 2010/ENTR/02 
{COM(2010) 542 final} 
 {SEC(2010) 1151} 
 
EN 2   EN TABLE OF CONTENTS 
 Background information and policy context..................................................................................... ............................. 6 
1. Procedural issues and consul tation of interested parties .................................................................... ......................... 7 
1.1. Organisation and timing................................................................................................... ............................................. 7 
1.2. Public consultation....................................................................................................... ................................................. 7 
1.3. External expertise........................................................................................................ ................................................. 8 
1.4. Industry self obligation and proposal ..................................................................................... ....................................... 8 
2. Problem definition and right to act ......................................................................................... ....................................... 8 
2.1. Problem definition........................................................................................................ ................................................. 8 
2.1.1. Complexity of the current legal framework ............................................................................... .................................... 8 
2.1.2. High level of emissions................................................................................................. ................................................ 9 
2.1.3. High number of fatalities in road accidents and safety risks............................................................ ........................... 13 
2.1.4. Lack of a legal fram ework for new technologies.......................................................................... ............................... 14 
2.2. Community competence and subsidiary....................................................................................... .............................. 15 
3. Objectives.................................................................................................................. ................................................. 15 
3.1. General objectives........................................................................................................ .............................................. 15 
3.1.1. Specific objectives: simplific ation of existing EU legislation .......................................................... ............................. 15 
3.1.2. Environmental specific objectives....................................................................................... ........................................ 15 
3.1.3. Safety specific objectives.............................................................................................. .............................................. 16 
3.1.4. Specific objectives: realign legal  requirements and technology developments............................................. ............. 16 
4. Policy options.............................................................................................................. ................................................ 16 
4.1. Simplification of ex isting EU legislation ................................................................................. ..................................... 16 
4.2. Vehicle type approval environmental measures.............................................................................. ........................... 16 
4.2.1. New or revised environmental measur es for the type approval of new vehicles............................................. ........... 17 
4.2.1.1. Revised lowe r emissions  limits........................................................................................ ........................................... 17 
4.2.1.2. Use of a revised World-wide Motorcycle emissi ons Testing Cycle (WMTC) for all L-category vehicle  
 cla sses....................................................................................................................... ................................................. 18 
4.2.1.3. Type-approval requirements for CO 2 measurement and fuel consumpt ion determination and reporting................... 18 
4.2.1.4. Evaporative emissions test and limit.................................................................................. ......................................... 19 
4.2.1.5. Durability requirements............................................................................................... ................................................ 19 
4.2.2. New measures to control v ehicle emissions ov er vehicle life............................................................. ........................ 20 
4.2.2.1. In-Use Conformity (IUC) testing and limits ............................................................................ ..................................... 20 
4.2.2.2. On Board Diagnostic (OBD) systems and access to repair information.................................................... ................. 20 
4.3. New vehicle type approval safety measures ................................................................................. ............................. 20 
4.3.1. Obligatory fitting of  Advanced Brake Systems............................................................................ ................................ 21 
4.3.2. Anti-tampering measures................................................................................................. ........................................... 21 
4.3.3. 74kW power limitation for motorcycles ................................................................................... .................................... 21 
4.4. Improved categorisati on of L-category vehicles ............................................................................ ............................. 21 
4.4.1. Electrical cycles (current ly outside scope of Framework Direct ive), Tricycles (L5e) and quadricycles 
 (categories L6e and L7e)...................................................................................................... ...................................... 21 
4.4.2. Specific requirements for category L7e vehicles ......................................................................... ............................... 22 
4.4.3. Dedicated requirements for gaseous alter native fuels and other non- traditional propulsions.............................. ...... 22 
5. Analysis of impact.......................................................................................................... ............................................. 22 
5.1. Simplification of the legislation......................................................................................... ........................................... 22 
5.2. Vehicle type approval environmental measures.............................................................................. ........................... 25 
5.2.1. New or revised environmental measur es for the type approval of new vehicles............................................. ........... 25 
5.2.1.1. Revised lowe r emissions limits........................................................................................ ........................................... 25 
5.2.1.2. Use of a revised World-wide Motorcycle emi ssions Testing Cycle (WMTC) for all L-category vehicle 
 classes....................................................................................................................... ................................................. 25 
5.2.1.3. Type-approval requirements for CO 2 measurement and fuel consumpt ion determination and reporting and 
 reporting..................................................................................................................... ................................................. 26 
5.2.1.4. Evaporative emissions test and limit.................................................................................. ......................................... 26 
5.2.1.5. Durability requirements............................................................................................... ................................................ 27 
5.2.2. New measures to contro l emissions duri ng vehicle life. .................................................................. ........................... 28 
5.2.2.1. In-Use Conformity (IUC) testing and limits. ........................................................................... ..................................... 28 
5.2.2.2. On Board Diagnostic (OBD) systems and access to repair information.................................................... ................. 28 
5.3. New vehicle type approval safety measures ................................................................................. ............................. 28 
5.3.1. Obligatory fitting of  Advanced brake systems............................................................................ ................................. 28 
5.3.2. Anti-tampering measures................................................................................................. ........................................... 30 
5.3.3. 74kW power limitation for motorcycles ................................................................................... .................................... 30 
5.4. Improved categorisati on of L-category vehicles ............................................................................ ............................. 30 
5.4.1. Re-categorising electric  assisted cycles (currently outside the scope of  legal framework), tricycles (category L5e)  
 and quadricycles (Categories L6e and L7e)..................................................................................... .......................... 30 
5.4.2. Specific requirements for category L7e vehicles ......................................................................... ............................... 31 
5.4.3. Dedicated requirements for gaseous alter native fuels and other non- traditional propulsions.............................. ...... 32 
5.4.4. Proposal to combine the results of the preferred op tions for improved categorisat ion of L-category vehicles........... 32  
6. Options comparison and conclusions.......................................................................................... ............................... 32 
6.1. Simplification of the legislation......................................................................................... ........................................... 32 
6.2. Vehicle type approval environmental measures.............................................................................. ........................... 32 
6.2.1. New or revised environmental measur es for the type approval of new vehicles............................................. ........... 32 
6.2.1.1. Revised lowe r emissions limits........................................................................................ ...............................................  
6.2.1.2. Use of a revised World-wide Motorcycle emissi ons Testing Cycle (WMTC) for all L-category vehicle  
 classes....................................................................................................................... ................................................. 33 
 
EN 3   EN 6.2.1.3. Type-approval requirements for CO 2 measurement and fuel consumpt ion determination and reporting and  
 reporting ..................................................................................................................... .................................................33 
6.2.1.4. Evaporative emissions test and limit .................................................................................. .........................................33 
6.2.1.5. Durability testing of anti-pollution devices and aged v ehicles to obtain new vehicle type-approval certificate ........ ...34 
6.2.2. New measures to control vehicl e emissions over v ehicles in use.......................................................... ......................... 
6.2.2.1. In-Use Conformity (IUC) testing and limits. ........................................................................... ......................................34 
6.2.2.2. On Board Diagnostic (OBD) systems and access to repair information.................................................... ..................34 
6.3. New vehicle type approval safety measures ................................................................................. ..............................34 
6.3.1. Obligatory fitting of  Advanced Brake Systems ............................................................................ ................................34 
6.3.2. Anti-tampering measures ................................................................................................. ...........................................37 
6.3.3. 74 kW power limitation for motorcycles.................................................................................. .....................................37 
6.4. Improved categorisati on of L-category vehicles ............................................................................ ..............................37 
6.4.1. Re-categorising electric  assisted cycles (currently outside scope of  legal framework), Tricycles (L5e) and  
 quadricycles (categories L6e and L7e) ......................................................................................... ..............................37 
6.4.2. Specific requirements for category L7e vehicles......................................................................... ................................38 
6.4.3. Dedicated requirements for gaseous alter native fuels and other non- traditional propulsions.............................. .......38 
6.5. Overview preferred options, the detailed analysis and comparison with the other options................................... ......39 
7. Monitoring and evaluation ................................................................................................... ........................................40 
7.1. Simplification ............................................................................................................ ...................................................40 
7.2. Vehicle type approval environmental measures.............................................................................. ............................40 
7.2.1. New or revised environmental measur es for the type approval of new vehicles............................................. ............40 
7.2.1.1. Revised lowe r emissions limits........................................................................................ ................................................ 
7.2.1.2. Use of a revised World-wide Motorcycle emi ssions Testing Cycle (WMTC) for all L-category vehicle 
 classes....................................................................................................................... ..................................................41 
7.2.1.3. Type-approval requirements for CO 2 measurement and fuel consumpt ion determination and reporting and  
 reporting ..................................................................................................................... .................................................41 
7.2.1.4. Evaporative emissions test and limit .................................................................................. .........................................41 
7.2.1.5. Durability testing of ant i-pollution devices  and aged vehicles ........................................................ .............................41 
7.2.2. New measures to control vehicl e emissions over v ehicles in use.......................................................... ......................... 
7.2.2.1. In-Use Conformity (IUC) testing and limits ............................................................................ ......................................41 
7.2.2.2. On Board Diagnostic (OBD) systems and access to repair information.................................................... ..................41 
7.3. New vehicle type approval safety measures ................................................................................. ..............................42 
7.3.1. Obligatory fitting of  Advanced Brake Systems ............................................................................ ................................42 
7.3.2. Anti-tampering measures ................................................................................................. ...........................................42 
7.3.3. 74kW power limitation for motorcycles................................................................................... .....................................42 
7.4. Improved categorisati on of L-category vehicles ............................................................................ ..............................42 
7.4.1. Electrical cycles (current ly outside scope of Framework Directive), Tricycles and Quadricycles .......................... .....42 
7.4.2. 6.4.2. Specific require ments for category L7e vehicles)................................................................. .............................42 
7.4.3. Dedicated requirements for gaseous alter native fuels and other non- traditional propulsions.............................. .......42 
ANNEX I: L-category vehicle definitions ........................................................................................ ..............................................43 
ANNEX II: Public consultation on outline proposals for a Regulation of the European Parliament and of the  
 Council for L-category vehicl es — Summary of Responses ........................................................................ ...............45 
1. Context ..................................................................................................................... ...................................................45 
2. Overview of respondents and analysis method................................................................................. ..........................45 
3. Summary of  responses ........................................................................................................ .......................................45 
ANNEX III: Description of the tasks requested to the ex ternal consultant TRL and methodology used — Policy 
 Assessment report regarding possible safety measures.......................................................................... ...................48 
1. Detailed description of the task to be performed............................................................................ .............................48 
2. Methodology................................................................................................................. ...............................................48 
ANNEX IV: Description of the tasks requested to the ex ternal consultant LAT a nd methodology used — Policy 
 assessment report regarding possible safety measures .......................................................................... ...................49 
1. Subject of the service request .............................................................................................. .......................................49 
1.1. Detailed description of the tasks to be performed ......................................................................... ..............................49 
1.2. Methodology............................................................................................................... .................................................50 
ANNEX V: Self obligation European moto rcycle industry association (ACEM) ....................................................... .....................51 
ANNEX VI: Self obligation European motorcycle indus try association (ACEM) Environmental Aspects................................ .......55 
ANNEX VII: Self obligation European motorcycle industry association (ACEM) Envir onmental aspects — Revised 
 emission limits ............................................................................................................... ..............................................58 
ANNEX VIII:Background to the type-approval system .............................................................................. .....................................59 
ANNEX IX: The Market for L- category vehicl e in the EU .......................................................................... .....................................60 
1. The structure of the EU market .............................................................................................. .....................................60 
2. Electrical Cycles ........................................................................................................... ...............................................60 
2.1. Sales of Electric Cycles.................................................................................................. .............................................60 
3. Powered-two wheelers (PTW).................................................................................................. ...................................62 
3.1. EuroStat data............................................................................................................. ..................................................62 
3.2. Type Approval data ........................................................................................................ .............................................62 
3.3. Import and export of motorcycles and motorcycle parts..................................................................... .........................63 
3.4. The impact of the new m easures on international trade ..................................................................... ........................64 
3.5. Production of PTWs ........................................................................................................ ............................................64 
3.6. PTW Price development over time........................................................................................... ...................................68 
3.7. Sales of PTWs............................................................................................................. ................................................68 
7.4.4. Motorcycles ............................................................................................................. ....................................................69 
7.4.5. Mopeds.................................................................................................................. ......................................................69 
3.8. Upstream-Suppliers........................................................................................................ .............................................69 
3.9. Downstream- sale, maintenance and repair.................................................................................. ..............................69 
3.10. Employment PTW industry.................................................................................................. ........................................70 
 
EN 4   EN 4. All Terrain Vehicles (ATVs)................................................................................................. ........................................ 71 
4.1. All Terrain Vehicle (ATV) sales in Europe ................................................................................. ................................. 72 
4.2. Employment ATV industry ................................................................................................... ....................................... 73 
5. Mini-cars ................................................................................................................... .................................................. 73 
Annex X: Details chapter 5 — Impact analys is — Simplification of legislation ................................................... ....................... 74 
ANNEX XI: Details chapter 5 — Impact analysis v ehicle Type Approval En vironmental measures ..................................... ........ 75 
1. New or revised environmental measures  for the type approval of new vehicles................................................. ....... 75 
1.1. Revised lower emissions limits, detailed analys is of proposed limit by comparison with light duty 
 M1 emissi on limits ............................................................................................................ .......................................... 75 
1.2. Qualitative analysis of the policy options to revise the emission limits.................................................. ..................... 90 
1.3. Revised lower emissions limits, summary of t he cost effectiveness of t he proposed emission limit  
 options ....................................................................................................................... ................................................. 94 
1.4. Use of a revised World-wide Mo torcycle emissions Testing Cycle (W MTC) for all L-category vehicle...................... 95 
1.5. Type-approval requirements for CO 2 measurement and fuel consumpt ion determination and reporting and 
 reporting..................................................................................................................... ................................................. 96 
1.6. Evaporative emissions test and limit...................................................................................... ..................................... 97 
1.7. Durability requirements................................................................................................... ............................................ 98 
2. New measures to control emissions during vehicle life. ...................................................................... ....................... 99 
2.1. In-Use Conformity (IUC) testing and limits. ............................................................................... ................................. 99 
2.2. On Board Diagnostic (OBD) systems and access to repair information........................................................ ........... 100 
ANNEX XII: Details chapter 5 — Impact analysis new vehicle Type Approv al safety measures....................................... .......... 103 
1. Obligatory fitting of Advanced Brake systems ................................................................................ .......................... 103 
1.1. No change ................................................................................................................. ............................................... 103 
1.2. Anti-lock Brake Systems on a ll Powered Two Wheelers (PTW)................................................................. .............. 104 
1.3. Anti-lock Brake Systems on PTWs with cylinder capacity > 125 cm3 and Advanced Brake Systems (Combined 
 Brake System (CBS) or Anti-lock Brake Systems(ABS)) on motorcycles   with 50cm
3 < cylinder capacity ≤ 125cm3.................................................................................................................. 105 
1.4. To make mandatory the fitting of Advanced Brake Sy stems (Combined Brake System (CBS) and/or Anti-lock  
 Braking Systems) on those motorcycles which conform to  the performance criteria defined by the A2 driving 
 licence . Obligatory fitting of Anti-lock Brake Systems on all other L3e class motorcycles; ................................... .. 106 
1.5. Industry self obligation.................................................................................................. ............................................ 107 
2. Anti-tampering measures..................................................................................................... ..................................... 108 
2.1. No change; ................................................................................................................ ............................................... 108 
2.2. Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures; ..................................... 1 09 
2.3. New measures on anti-tampering............................................................................................ ................................. 110 
3. 74 kW power limitation for motorcycles ...................................................................................... .............................. 111 
ANNEX XIII:Details chapter 5 — Impact analysis Im proved categorisation of  L-category vehicles .................................. .......... 112 
1. Electrical Cycles (outside scope of framework directive currently), Tricycles (L5e) and Quadricycles  
 (Category L6e and L7e)........................................................................................................ .................................... 112 
2. Specific requirements fo r Category L7e vehicles ............................................................................. ........................ 113 
3. Dedicated requirements for gaseous alternat ive fuels and other non-tr aditional propulsions.................................. 114 
ANNEX XIV:Details chapter 6 — options comparison and conclusions Simplificati on of the legislation............................. ........ 115 
ANNEX XV:Details chapter 6 — Options comparison and conclu sions Vehicle Type Approval Environmental measures ........ 117 
1. New or revised environmental measures  for the type approval of new vehicles................................................. ..... 117 
1.1. Revised lower emissions limits............................................................................................ ..................................... 117 
1.2. Use of a revised World-wide Motorcycle emissi ons Testing Cycle (WMTC) for all L-category vehicle 
 cla sses....................................................................................................................... ............................................... 119 
1.3. Type-approval requirements for CO 2 measurement and fuel consumpt ion determination and reporting and 
 reporting..................................................................................................................... ............................................... 120 
1.4. Evaporative emissions test and limit...................................................................................... ................................... 121 
1.5. Durability requirements................................................................................................... .......................................... 122 
2. New measures to control emissions during vehicle life. ...................................................................... ..................... 123 
2.1. In-Use Conformity (IUC) testing and limits. ............................................................................... ............................... 123 
2.2. On Board Diagnostic (OBD) systems and access to repair information........................................................ ........... 124 
3. Proposal for revised emission limits ........................................................................................ ................................. 125 
3.1. Proposal to revise emission limits for short and medium term .............................................................. ................... 125 
3.2. Proposal to revise em ission limits for long term .......................................................................... ............................. 127 
ANNEX XVI:Details chapter 6 — options  comparison and conclusions-Analysis Ne w Vehicle Type Approval Safety  
 measures ...................................................................................................................... ............................................ 128 
1. fitting of Advanced Brake systems........................................................................................... ................................. 130 
1.1. No change ................................................................................................................. ............................................... 130 
1.2. Anti-lock Brake Systems on a ll Powered Two Wheelers (PTW)................................................................. .............. 130 
1.3. Anti-lock Brake Systems on PTWs with cylinder capacity > 125 cm3 and Advanced Brake Systems (Combined 
 Brake System (CBS) or Anti-lock Brake Systems(ABS)) on motorcycles   with 50 cm
3 < cylinder capacity ≤ 125 cm3 .............................................................................................................................. .......................................................131 
1.4. Obligatory fitting of Advanced Brake Sy stems (Combined Brake System (CBS) and/or  
 Anti-lock Brake Systems (ABS)) on motorcycles fulfilli ng the maximum performance criteria related to the A2 
 driving licence. Obligatory fitting of Anti-lock Brake Systems on all other L3e class motorcycles............................ 1 32 
1.5. Industry self obligation.................................................................................................. ............................................ 133 
1.6. Impact Assessment of Anti-lock Brake System tec hnology fitted on vehicles, manufactured and type approved  
 by SMEs ....................................................................................................................... ............................................ 134 
1.6.1. Introduction ............................................................................................................ ................................................... 134 
1.6.2. Regulatory Impacts on SMEs .............................................................................................. ..................................... 134 
1.6.3. Economic Advantages..................................................................................................... ......................................... 134 
1.6.4. Possible Disadvantages .................................................................................................. ......................................... 135 
1.6.5. Potential Opportunities ................................................................................................. ............................................ 135 
 
EN 5   EN 1.6.6. Pot ential Risks......................................................................................................... ..................................................135 
2. Anti-tampering measures ..................................................................................................... .....................................136 
2.1. No change; ................................................................................................................ ................................................136 
2.2. Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures;...................................... 136 
2.3. New measures on anti-tampering. ........................................................................................... .................................137 
3. 74 kW power limitation for motorcycle....................................................................................... ................................138 
ANNEX XVII:Details chapter 6 — Options comparison and conclusions — Improved cat egorisation of L-category vehicles.....139 
1. re-categorisation Electrical Cycl es (outside scope of framework directive currently), Tricycles (L5e) and 
 Quadricycles (Categories L6e and L7e)......................................................................................... ...........................139 
2. Specific requirements fo r category L7e vehicles............................................................................. ..........................140 
3. Dedicated requirements for gaseous alternat ive fuels and other non-tr aditional propulsions.................................. .140 
4. Proposal to re-categoris e L-category vehicles ............................................................................... ...........................141 
ANNEX XVIII:Details chapter 7 — – Monitoring & Evaluation Analysis New Vehicle Type Ap proval Simplification and  
 Safety measures............................................................................................................... .........................................142 
1. Simplification .............................................................................................................. ...............................................142 
2. Obligatory fitting of Advanced Brake systems................................................................................ ...........................142 
3. Anti-tampering measures ..................................................................................................... .....................................142 
4. 74kW power limitation for motorcycles....................................................................................... ...............................142 
ANNEX XIX:Details chapter 7 — Monitoring & Evaluati on Improved categorisation of L-category vehicles ........................... ....143 
1. Re-categorisation electric assisted CYCLES (outside sc ope of legal framework currently), Tricycles (L5e) and  
 quadricycles (Categories L6e and L7e)......................................................................................... ............................143 
2. Specific requirements for Off-road  quads (All Terrain Vehicles, ATVs) ....................................................... .............143 
3. Specific requirements for gaseous alternat ive fuels and other non-traditional propulsions. .................................. ...143 
ANNEX XX:Abbreviation List and Glossary........................................................................................ ..........................................144 
 
EN 6   EN BACKGROUND INFORMATION AND POLICY CONTEXT  
Please refer to Annex XX  at the back of this report for a list of abbreviations and a glossary of terminology. 
‘L-category vehicles’ is a term covering a wide range of different vehicle types with two or three or four 
wheels, e.g. two- or three-wheel mopeds, two- or th ree-wheel motorcycles and motorcycles with side-cars. 
Examples of four-wheel vehicles, also known as quadri cycles or quads, which also belong to the L-category 
vehicle family, are quads used on public roads, all-te rrain vehicles (ATVs), which are quads designed to be 
used off-road, and mini-cars. Annex I  provides more details of the current categorisation criteria for L-
category vehicles. 
Type-approval requirements for new vehicles in the L category are currently set out in Directive 2002/24/EC1 
(the ‘Framework Directive’). In additi on, a series of directives referred to  in the Framework Directive contain 
detailed technical requirements relating to L-category  vehicles. The Framework Directive became mandatory 
on 9 November 2003 for new types of vehicles. 
Type-approval legislation wa s addressed in the political initiative ‘CARS 21’2. This initiative was launched in 
2005 to carry out a regulatory and policy review of the automotive sector to advise the Commission on future 
policy options. One of the reasons for launching CA RS 21 was the concern expressed by automotive 
stakeholders that the cumulative cost  of regulation had a negative effe ct on competitiveness, and made 
vehicles unnecessarily expens ive. The CARS 21 Final Report3 concluded that while most of the legislation in 
force should be maintained for the protection of c onsumers and the environment, a simplification exercise 
should be undertaken so as to rationalise the regulatory framework and move towards international 
harmonisation. This simplification exercise was planned in the ‘Commission second progress report on the 
strategy for simplifying the regulatory environment’4. Any possible initiative should be aligned with this 
strategy.  
In line with the European strategy on air quality5, the EU has constantly strengthened emission standards for 
motor vehicles, in particular for hydrocarbons, carbon  monoxide, nitrogen oxides and particulate matter. The 
contribution of L-category vehicles  to the overall reduction sought in greenhouse gases is another 
environmental aspect that is covered in this Impact Assessment. 
The new initiative should be aligned with the European Road Safety Action Plan 2011-2020 and the 
European Road Safety Charter (ERSC)6, 2000-2010. The ERSC aimed to halve the number of road fatalities 
by 2010, but this challenging target will unfortunately  not be met. Unfortunately, L-category vehicle riders 
belong to a vulnerable road user group with the high est fatality and injury rates among all road users.  
Annex IX  provides detailed information on the market for L-category vehicles, as registered by EuroStat. 
Where data were not available from EuroStat, the indus try associations were reque sted to provide relevant 
information. The market is broadly composed of two s ub-markets, the first comprising motorcycles and the 
second for scooters and mopeds. The motorcycle market  is dominated by Japanese imports from companies 
such as Honda, Yamaha, Kawasaki and Suzuki. In a gl obalised world it is not any longer appropriate to refer 
only to traditional European companies with their main development and production footprint based in 
Europe. These large companies with their head offices in Japan also produce and develop models in 
Europe; they employ many European citizens and accoun t for approximately 50 per cent of sales in the EU 
market. Large traditional EU-based motorcycle producers,  also with their head offices in Europe are Piaggio, 
Peugeot, BMW, and a number of mid-sized companies like KTM and Ducati, which account for 
approximately 17  % of the market between them. In recent year s there has been a significant increase in 
imports from China. The United States is the la rgest export market for motorcycles from the EU. 
The second sub-market is the market for mopeds and sco oters. This market is much more fragmented than 
the motorcycle market. Piaggio, Peugeot and Derbi ar e the main traditional European producers. Asian 
manufacturers are again strongly represented in this s egment, including manufacturers from China, Thailand 
and India, but they have less market share than in the motorcycle segment.  
                                                 
1 Directive 2002/24/EC of the European Parliament and of the Council of 18 March 2002 relating to the type-approval of two or 
three-wheel motor vehicles and repealing C ouncil Directive 92/61/EEC, OJ L 124, 9.5.2002, p. 1. For further information on 
the background to the type-approval system refer to Annex VIII. 
2 http://ec.europa.eu/enterprise/automotive/pagesbackground/competitiveness/cars21.htm . 
3 http://ec.europa.eu/enterprise/automotive/pagesba ckground/competitiveness/cars21finalreport.pdf . 
4 COM(2008) 33 final, 30.1.2008, proposal No 49, p. 32. 
5 http://ec.europa.eu/environment/archives/cafe/general/keydocs.htm . 
6 http://www.erscharter.eu/ . 
 
EN 7   EN In all, the number of vehicles currently in circulat ion in the EU is estimated at over 30 million. The EU 
produces over 1.1 million vehicles an nually, but this is a relatively lo w number in comparison with China, 
which produces over 20 million vehicles per year, I ndia, which produces 8 million, and Taiwan, which 
produces 1.5 million vehicles. However, European vehi cles are considered to provide greater added value 
and higher quality. 
It is estimated that there are approximately 100 manufac turers of motorcycles or mopeds in the EU, about 
half of which are owned by European companies. The estimate was based on different data sources 
including EuroStat, data from the type-approval authorit ies and a study by the Univ ersity of Bologna, which 
was commissioned by industry. The number of SME produc ers operating in both the motorcycle and scooter 
markets is small, although the scooter market ha s more SMEs. The combined market segments have a 
turnover of approximately €  4.1 billion. 
While approximately 60  000 people are employed in the manufacture of motorcycles and cycles, the total 
number of persons employed by the industry as a whole is estimated at approximately 165  000, when all 
aspects of the market are taken in to consideration, including the up stream and downstream sectors. As 
regards employment, the main countries are Italy , Spain, France, Germany and the United Kingdom.  
A third, downstream sub-market is t he sale, maintenance and repair of motorcycles. This market is extremely 
significant and, in 2006, generated €  3. 4 billion in value added from a turnover of over €  24.8 billion in the 
EU-27 (EuroStat estimate). 105  000 persons were employed by the 37  000 enterprises in the motorcycle 
distribution sector It is estimated that 72  % of the total industry’s turnover  is generated in this sector. 
The Impact Assessment Board (IAB) of the EU Commi ssion issued an opinion on the present report after its 
meeting on 16 December 2009. The Board’s recommen dations were used to revise and improve the 
presentation of the analysis and the overall quality of t he report. The references to the annexes to chapters 
5, 6 and 7 were made into links so that all the qualit ative and quantitative elements of every policy option are 
readily accessible in the main report. The ‘industry self-regulation’ option for advanced brake systems was 
elaborated on in chapter 6.3.1 and additional informat ion on the industry proposal for new emission limits 
was added in chapter 6.2.1.1 to meet the IAB recommendat ion to make it clearer whether self-regulation is a 
feasible option or not. The desirable use of internati onal standards, like UNECE regulations, was explained 
in more detail in chapters 4.1, 4.2.11,  5.1 and 6.1. The global impacts of the measures on international trade 
were explained in Annex VIII, chapt ers 3.3 and 3.4. The Commission’s leve l of ambition regarding suggested 
standards for pollutant emissions was also added to chapt er 3.1.2. A summary table of preferred options with 
associated references to the detailed analysis and comp arison in the main text was added to chapter 6.5. 
Chapters 5.2.1.3 and 6.2.1.3 were  further developed regarding CO 2 emissions and fuel consumption 
determination and reporting at type appro val to pave the ground for future introduction of energy efficiency 
labelling. Finally, the references to monitoring and eval uation arrangements were improved in chapter 7 by 
inserting active links to this t opic in Annexes XVIII and XIX. In addi tion, it was explained who would be 
responsible for collecting data for monitoring and ev aluation and when a study was to be conducted to 
evaluate and compare the regulator’s target with t he actual situation at a future point in time.  
1. P ROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. Organisation and timing 
This proposal is an item in the Commission’s Wo rk Programme 2010 and is scheduled in its Agenda 
Planning under the reference 2010/ENTR/02. 
A roadmap has been established for this proposal, including an impact assessment, and has been included 
in the Agenda Planning for 2010. An Impact Assessment  Steering Group, consisting of members of the 
Commission services concerned (DG ENV, DG MOVE  and DG ECFIN), was set up and met on 14 August, 5 
November and 16 November 2009 
1.2. Public consultation 
A public consultation7 was held from 22 December 2008 to 27 February 2009 to seek the opinions of 
associations, companies and public authorities on key as pects of potential measures  for the type-approval of 
L-category vehicles. In particular, stakeholder vi ews were sought on the simplification of the current 
legislation, on the environmental and safety aspects of L-category vehicles and on the possible need to align 
legal measures with technical developments. Opini ons were sought especially  on items perceived to be 
controversial, e.g.: 
                                                 
7 http://ec.europa.eu/enterprise/automotive/c onsultation/2_3_wheeler s/contributions.htm . 
 
EN 8   EN – Obligatory fitting of advanced brake systems8 on powered two-wheelers. On this point, 29  % of all 
respondents were against, 24  % were neutral or had no opinion and 49  % were favourable or 
relatively favourable. 
– Environmental measures, e.g. introduction of revise d, lower emission limit values. In response to 
the question ‘Do you support the introduction of ne w emission limits for motorcycles equivalent to 
the Euro 5 limits for petrol cars?’, 17  % were against, 32  % had no comments and 52  % were 
favourable or relatively favourable. 
Please see Annex II  for the executive summary of the consultation report9, summarising the results of this 
public consultation. The present report explains how the opinions of stakeholders were taken into account in 
weighing up the different pros and cons of the policy options considered. 
In addition to the public consultation over the internet, some 20 bilateral meetings were held with 
stakeholders in 2009. From 2002 on wards, two working groups, the Motor Cycle Working Group10 (MCWG) 
and the Motor Vehicle Emission Group (MVEG), met on a number of occasions11 to discuss L-category 
vehicle legislation. At these meetings, Member Stat e experts, associations re presenting the L-category 
vehicle industry and vehicle users,  and non-governmental organisations ex pressed their views on what the 
new regulation was supposed to achieve and on the envisaged policy options. The most recent MCWG 
meetings were held in February and June 2009. A third MCWG meeting was held on 14 December 2009. 
1.3. External expertise 
Two studies were carried out in the course of 2008 and 2009 with the aim of evaluating the economic, social 
and environmental impacts of proposals fo r L-category vehicle type-approval. 
TRL Ltd was brought in as an external  consultant to study potential safety  measures for L-category vehicles 
and also to investigate the impact of simplification on ex isting L-category vehicle legislation. A report (‘the 
TRL report12’) was issued and published on the Commission’s websit e. A consortium of institutes comprising 
TNO (lead institute), the Universi ty of Thessaloniki (LAT), BAST, EMPA and TÜV Nord produced a study 
report on potential environmental measures for L-category vehicles13 (‘the LAT report’). These two policy 
reports provided the main inputs to the impact assessmen t. The quantitative cost and benefit estimates in the 
present report are based on both policy reports. Annex III  and Annex IV  provide a brief overview of the 
methodology used by both contractors. 
1.4. Industry self-regulation and legislative proposals 
ACEM, the European motorcycle industry association, proposed self-regulation on ce rtain safety aspects of 
L-category vehicles, e.g. fitting of advanced brake sy stems on powered two-wheelers.  They also proposed a 
package of environmental measures to be included in the new L-category vehicl e regulation in order to 
proactively address various environmental and safety co ncerns identified and described in the TRL and LAT 
reports. The commitments proposed by ACEM can be found in Annexes V , VI, and VII. 
2. P ROBLEM DEFINITION AND RIGHT TO ACT  
2.1. Problem definition 
The Commission has identified a number of key concerns associated with the current  provisions for the type-
approval of L-category vehicles:  
2.1.1. Complexity of the current legal framework 
It has been pointed out to the Commission that the existi ng system for L-category vehicles is too complex 
and that there is therefore scope for simplif ication and international harmonisation.  
The type-approval system is generally recognised as  an effective framework for tackling various aspects 
(functional and occupational safety, environment). Howeve r, the national authorities in charge of applying the 
Framework Directive are facing unnecessary additional co sts in their attempts to operate in this complex 
regulatory framework. Many stak eholders have called upon the Commission to simplify the regulatory 
                                                 
8 Refer to the glossary at the end of this report fo r a technical explanation of anti-lock brake systems. 
9 http://ec.europa.eu/enterprise/automotive/c onsultation/2_3_wheelers/results_report.pdf . 
10 http://ec.europa.eu/enterprise/automotive/mcwg_meetings/index.htm . 
11 http://ec.europa.eu/enterprise/automotive/mveg_meetings/index.htm . 
12 http://ec.europa.eu/enterprise/automotive/pr ojects/report_new_m easures_l_category.pdf . 
13 http://ec.europa.eu/enterprise/automotive/proj ects/report_measures_motorcycle_emissions.pdf . 
 
EN 9   EN framework in order to ensure a less burdensome and less time-consuming approach to type-approval. This 
objective has thus been included in the Simplification Rolling Plan. 
L-category vehicles have to comply with a series of  requirements found in a number of separate directives. 
The Framework Directive is linked to 13 detailed tech nical directives, which themselves have been amended 
by 21 amending directives so as to ensure that they ac curately reflect technical progress (for example, by 
allowing the use of an alternative world-standard dr iving cycle with associat ed EU-defined exhaust gas 
limits). For formal reasons, all these separa te directives must be applied individually. 
The Framework Directive lays down the legal type-approv al requirements for light two-, three- and four-wheel 
vehicles such as mopeds, motorcycles, tricycles and quadricycles. Both the enacting terms of the technical 
directives and their annexes are highl y detailed and leave Member States practically no room for discretion 
when transposing them. Thus, some Member States simp ly make direct reference to those directives, while 
others opt to develop a completely new legislat ive text to transpose those requirements. 
In addition, many directives contain references to regulations and standards applied worldwide, such as 
those adopted by UNECE14, which are subject to amendments. Ultimately, the disparate nature of 
regulations governing the type-approval of L-category vehi cles leads to a lack of legal and regulatory clarity. 
Industry and regulators need to be familiar with 37 EU directives and in parallel 34 UNECE regulations, 
which may be equivalent. To consistently update t hese can be a burdensome process and results in 
additional costs for administrations and industry. For industry, this regulatory complexity and uncertainty 
leads to unnecessary compliance costs for the type-appr oval of new vehicles. Other  concerns expressed in 
the public consultation were the weakening of existi ng EU requirements and less transparency owing to the 
decision-making process taking place in a ‘remote’  international institution such as UNECE. 
Nevertheless, amending directives have to be transposed by Member States, and this has led to difficulties 
for EU manufacturers, as national transpositions ma y differ slightly, for example concerning dates of 
publication and entry into force and even (mis-)interpretat ions with regard to the substantive requirements, 
leading to misunderstanding between type-approval aut horities. This problem is inherent in any EU 
legislation adopted in the form of a directive, but it is  particularly acute in this case, where the requirements 
are highly technical, very detailed, and likely to be often amended owing to frequent adaptations to technical 
progress. Transposition then makes demands on the re sources of national administrations without adding 
any value in terms of safety or environmental protection. Additional administrative resources are 
consequently required to solve the resulting problems of  interpretation, which crop up on a regular basis in 
the Type-Approval Authorities Meeting (TAAM), bringi ng together representatives of Member States and 
Commission departments. 
Regulations adopted by UNECE, under the 1958 Agreement, are widely recognised in countries inside and 
outside the EU, and the EU has acceded to many of t hese. The promotion of international standards is 
supported by industry. But in the current situation, prov isions are often duplicated in European legislation, or 
are similar in terms of technical requirements but differ in formal details. An example is the date of entry into 
force of an amendment to a directive, which is usually different as a result of (lengthy) procedures to update 
the directive after e.g. UNECE has introduced an am endment in its regulation on the same subject. This 
gives rise to concerns of non-transparen cy and unnecessary administrative burden.  
The administrative burden in this ‘no change’ scenario is significant. Based on the cost estimates of six 
Member States, the cumulative cost to the EU27 Me mber States between 2009 and 2020 was estimated by 
the consultant to be €  3.1 million in total, despite the fact t hat the scenario is called ‘no change’. 
This high cost will remain a nd is likely to increase if no simplification exercise is carried out to delete obsolete 
measures and to reduce complexity. 
2.1.2. High level of emissions 
The internal combustion engines of L-category vehicles , which convert chemical energy (fuel) into movement 
and heat, emit toxic air pollutants and greenhouse gases as undesirable by-products. Evaporative emissions, 
mainly hydrocarbons from positive-i gnition (PI) fuel storage and supply systems are also considered to be 
toxic. Toxic air pollutants, e.g. certain hydrocarbons , are known or suspected to  cause cancer or other 
serious health effects, such as reproductive or bi rth defects, or may cause other adverse environmental 
effects. 
                                                 
14 http://www.unece.org/trans/main/wp29/wp29wgs/wp29gen/wp29pub/wp29pub2002e.pdf . 
 
EN 10   EN Two pollutants, fine particulate matter and ground-level ozone, are generally recognised as the most 
significant in terms of health impacts. Long-term and pea k exposures can lead to a variety of health effects, 
ranging from minor effects on the respiratory system to premature mortality. Since 1997, up to 45  % of 
Europe’s urban population may have been exposed to ambient concentrations of particulate matter above 
the EU limit set to protect human health; and up to 61  % may have been exposed to levels of ozone that 
exceed the EU target value. It has been estimated t hat PM2.5 (fine particulate matter) in air has reduced 
statistical life expectancy in t he EU by more than eight months15. Common pollutants16 that are currently 
regulated for L-category vehicles are hydrocarbons, carbon monoxide and nitrogen oxides. Particulate matter 
emissions are not regulated17. 
The introduction of the Euro 5 & 6 passenger car em ission standards and the Euro VI heavy-duty emission 
standards means that the c ontribution of L-category v ehicles will become increasi ngly important in the years 
to come. For example, it is estimated (in the LAT report ) that total hydrocarbons (THC) emitted by L-category 
vehicles will increase from a share of 38  % to 62 % of the total hydrocarbon em issions (sum of evaporative 
and exhaust emissions) of the entire road transport sector  by 2020, if no additional measures are taken. This 
is mainly due to the significant reductions in hydr ocarbon emissions from other road transport categories. 
Mopeds are already today one of the most signific ant contributors to hydr ocarbon emissions, and are 
expected to account for 36 % of total road transport emissions by 2020. 
 
0.0E+002.0E+054.0E+056.0E+058.0E+051.0E+061.2E+061.4E+061.6E+06
2007
2008
2009
2010201120122013
2014201520162017201820192020HC [tn]
0%5%10%15%20%25%30%35%40%Evaporation
TriQuad Gasoline
TriQuad Diesel
Motorcycles
Mopeds
All other vehicles
 
Figure 1: For L-category vehicles, trend over time in absolute and relative shares of hydrocarbon emissions, assuming no 
change in policy18 
CO emissions are high and are expected to rise from a share of about 20  % to around 36 % of total road 
transport emissions in 2020. 
0.0E+002.0E+064.0E+066.0E+068.0E+061.0E+071.2E+07
2007
20082009
20102011
2012
20132014
201520162017
20182019
2020CO [tn]
0%5%10%15%20%25%30%35% TriQuad Gasoline
TriQuad Diesel
Motorcycles
Mopeds
All other vehicles
 
                                                 
15 Quote from EEA: http://www.eea.europa.eu/themes/air/about-air-pollution . 
16 Health effects of common pollutants: http://www.eea.europa.eu/publications/2599XXX/page008.html . 
17 http://pubs.healtheffects.org/view.php?id=282 . 
18 NB. ‘All other vehicles’ includes passenger cars, delivery v ans, trucks and buses. Source: LAT report. Primary Y-axis (left): 
HC = hydrocarbon emissions; 2.0E+05 = 200  000, 1.0E+06 = 1  000  000, 1 tn = 1000 kg. Secondary Y-axis (right): L-category 
vehicle hydrocarbon (HC) emission share as % of all road transport HC emissions L-category vehicle 
hydrocarbon (HC) 
emission share  
[% of all road transport 
hydrocarbon emissions] 
L-category vehicle carbon 
monoxide (CO) emission 
share  
[% of all road transport 
carbon monoxide 
emissions] 
 
EN 11   EN Figure 2: For L-category vehicles, trend over time in, absolute and relative share of carbon monoxide emissions, assuming no 
change in policy19. 
In a number of southern European cities, powered two wh eelers are banned from city traffic in the event of a 
fine dust alarm on hot summer days to prevent excessive particulate emissions. EU legislation for trucks and 
cars is proving successful in sharply reducing overall emitted pollutant levels throughout Europe, going by 
the most recent emission levels measured. L-catego ry vehicles need to contribute proportionately to this 
success story, especially gi ven that they will produce significantly more total hydrocarbons (from exhaust and 
evaporative emissions) than passenger cars and trucks  together in 2020. At the same time, they are 
responsible for only 3  % of total road transport mileage. The source of the emission problems are the 
polluting vehicles currently in circulation. As powered two-wheelers have on average a longer life20 than e.g. 
passenger cars, it takes a long time before ne w emission limits take effect on air quality.  
The present legal framework for L-category vehicles  emissions was adopted in 2002. Since then technology 
has evolved rapidly. Given the wide diversity of vehi cle construction, design and propulsion technology now 
on the market, the current legal framework is no longer up to date in environmental terms. 
Another concern is the proliferat ion of laboratory testing cycles21 currently used to test the emissions of the 
different L-category vehicles. The results of an emissi on test carried out under laboratory conditions should 
reflect the vehicle’s real-world emission performance . In order to be able to compare different means of 
transport in terms of environmental  performance and fuel consumption, there should ideally be only one 
single testing cycle, regardless of whether a truck, a passenger car, a mo tor cycle or a quadricycle is being 
tested. For historical and certain physical reasons, this has not been the case, which means that there are 
currently four different testing cycles for the seven su bcategories of L-category vehicles. For L3e motorcycles 
alone there are two optional testing cycles, altho ugh manufacturers only seem to use the World-wide 
Motorcycle emissions Testing Cycle WMTC) to type- approve a vehicle. The traditional European Driving 
Cycle (EDC) with associated limits and testing procedur es may therefore have become obsolete. In addition, 
consumers are complaining that the fuel consumption measured in the laboratory test cycle does not match 
real-world fuel consumption, so the fuel bill for co nsumers can be higher than expected if the published fuel 
consumption is based only on the figure m easured in a non-represent ative test cycle. 
UNECE WP29 is eagerly waiting for the EU to publish new emission limits that match the WMTC test cycle22 
and help address global pollutant emission concerns. The WP29 contracting parties are considering 
incorporating the new Euro limit values into global23 technical regulation No. 2. This will be the first time in 
WP29 history that contracting partie s adopt emission performance limits in  a global emission test cycle, as 
historically only test conditions have been regulated and each contracting party has had its own proprietary 
testing cycle and emission pollutant lim its for type-approval or self-certi fication. Consequently, the speed with 
which possible Euro limits enter into forc e in the EU is a possible global concern. 
The non-toxic greenhouse gases (GHGs) emitted by PTWs, e.g. CO 2, represent overall a very small share of 
total road transport emissions. 
 
0.0E+001.0E+082.0E+083.0E+084.0E+085.0E+086.0E+087.0E+088.0E+089.0E+081.0E+09
20072008200920102011201220132014201520162017201820192020CO2 [tn]
0.0%0.2%0.4%0.6%0.8%1.0%1.2%
TriQuad Gasoline
TriQuad Diesel
Motorcycles
Mopeds
All other vehicles
 
                                                 
19 NB. ‘All other vehicles’ includes passenger cars, delivery vans , trucks and busses. Source: LAT report. Primary Y-axis (left):  
CO = carbon monoxide emissions; 2.0E+06 = 2  000  000; 1.0E+07 = 10  000  000, 1 tn = 1000 kg. Secondary Y-axis (right): L-
category vehicle carbon monoxide (CO) emission s hare as % of all road transport CO emissions. 
20 The LAT report, chapter 2.2. 
21 In the LAT report, chapter 2.3.1, pp.37 – 39, the three different test cycles are described in more detail. 
22 http://www.unece.org/trans/doc/2009/wp29/ECE-TRANS-WP29-2009-132e.pdf . 
23 http://www.unece.org/trans/main/wp29/wp29wgs/wp29gen/wp29registry/gtr2.html . L-category vehicle carbon 
dioxide emissions (CO 2) 
share 
[% of all road transport 
CO 2 emissions] 
 
EN 12   EN Figure 3: For L-category vehicles, trend over time in absolute and relative share of CO 2 emissions, assuming no change in 
policy 24. 
However, it is not obvious to the average consumer if a vehicle is fuel-efficient and what level of CO 2 it emits, 
as there are currently no labelling requirements (unl ike for passenger cars). The L-category vehicle 
manufacturer is not obliged to officially declare the CO 2 emissions of an L-category v ehicle, nor must the fuel 
consumption be determined and officially declared to obtai n type-approval for a new vehicle. Given the much 
lower CO 2 emissions of PTWs per passenger, compared to passenger cars, an increase in trips made using 
PTWs instead of passenger cars will actually have a positive effect in reducing overall CO 2 emissions by 
road transport. To inform the consumer in a clear,  concise and harmonised way, objective measurement 
data are needed, e.g. measurements of CO 2 emissions and fuel consumption in type-approval demonstration 
testing. For passenger cars, for example, such objec tive measurement data are officially reported and used 
as a basis for a labelling scheme, which is currently not the case  for L-category vehicles. This is therefore a 
concern from the perspective of consumer information. 
At the 9th meeting of the MVEG on 20 October 2008, the exhaust  after-treatment indust ry association, AECC, 
presented a study25 on durability testing. For one of the five te sted motorcycles CO emissions reached the 
Euro 3 limit after only a mileage of 2000 km and NOx ty pe-approval limits were already exceeded after 5 000 
km. Mileage accumulation was stopped after 20  000 km, as NOx had reached the stop criterion for the test, 
set at 200  % of the Euro 3 NOx limit. This vehicle was analysed and no obvious failure was found, leading to 
the conclusion that the exhaust a fter-treatment system had aged rapi dly and had lost its ability to reduce 
emissions. This means in practice that older vehicles  in use may emit more than twice the limits after only 
20 000 km. The deterioration in emission performance over vehicle life is not a specific problem of L-
category vehicles. For other road vehicles with com bustion engines (cars, trucks ) equipped with exhaust 
after-treatment systems, this conc ern was already raised several decade s ago. L-category vehicles are 
currently the only type approved vehicle types not subjec t to any legal durability requirements in the EU. 
Other countries (USA, India, China, Thailand, Taiw an and Singapore) have durability requirements for such 
vehicles too. 
An integral approach involving periodical technical inspection (PTI)26, road-side inspection (RSI)27 and in-use 
conformity (IUC) testing and limits may be required for vehicles already in use in order to identify possible 
environmental and/or safety concerns with such vehicles . In practice, only a proper balance in testing effort 
and frequency employing a mix of PTI, RSI and IUC testi ng will ensure that the emissions of mass-produced 
vehicles remain under the type-approval limits, as ther e is a certain overlap between these types of tests. 
Applying only one of these three test  types has proven with passenger cars  to be insufficient to guarantee 
effective and efficient monitoring of  vehicle emissions and safety over  vehicle life. It is therefore not 
conducive to effective and efficient repair and maintenan ce over vehicle life if only one of these tests is 
regularly carried out. Environmental or safety probl ems may be caused by a component suddenly breaking 
down or by degradation or reduced e fficiency of vehicle components and systems over vehicle life, due 
possibly to bad vehicle maintenance, bad quality of r eplacement components, etc. PTI and RSI legislation 
fall outside the scope of this new Regulation for the type- approval of new vehicles. This means that only the 
impact of IUC testing is considered in the present Repo rt. The main problem is that none of the three tests 
are currently harmonised or covered in the EU legal fr amework. This means that once a limited number of 
representative new vehicles have pass ed type-approval demonstration testin g there is no further harmonised 
monitoring or market surveillance mechanism to check whether mass-produced vehicles continue to comply 
with emission and safety regulations while ageing and accumulating mileage. 
Finally, a clean vehicle may turn into a high polluter if an emission-relevant comp onent or system fails or 
excessively degrades. In order to effectively and efficient ly repair such failures, any independent repair shop 
needs: 
- Standardised diagnostic information on possible ma lfunctions leading to environmental and/or safety 
problems. The on-board diagnostic system on a vehicle sh ould make this information available to a generic 
scan tool (not just a proprietary OE M scan tool obtainable only by contract  repairers). Such information is 
critical to understanding what the actual problem is with the vehicle and what needs to be done to effectively 
and efficiently repair the vehicle. 
                                                 
24 NB. ‘All other vehicles’ includes passenger cars, delivery v ans, trucks and buses. Source: LAT report. Primary Y-axis (left): 
CO 2 = carbon dioxide emissions; 1.0E+08 = 100  000  000; 1.0E+09 = 1  000  000  000,; 1 tn = 1000 kg. Secondary Y-axis (right): 
L-category vehicle carbon dioxide (CO 2) emission share as % of all road transport CO 2 emissions 
25 http://ec.europa.eu/enterprise/automotive/mveg_meetings/motos/aecc.pdf . 
26 http://en.wikipedia.org/ wiki/Vehicle_inspection . 
27 http://ec.europa.eu/transport/road_safety/ vehicles/roadworthi ness/roadside_en.htm . 
 
EN 13   EN - Access to repair and maintenance information developed by  the manufacturer of the vehicle. Unfortunately, 
this is currently possible only for contract repair shops, not for independent dealers, which is not only a 
competition problem but also has high pollutant emissions as a negative side-effect. 
2.1.3. High road fatalities and safety risks 
L-category drivers face a much higher risk of fatal or  serious accidents than other drivers. The fatality rate 
per million kilometres travelled is, on average, 18 times greater than for passenger cars. In 2006, powered two wheelers accounted for 2
 % of the distance travelled but 16  % of road deaths in the EU-25 (ETSC, 2007). 
Furthermore, while other vehicle types have seen significant decreases in fa talities and serious injuries over 
time, the figures for powered two wheelers have fallen much more slowly or remained static. 
In 2008, 5  520 PTW riders died in road accidents. In addition the number of serious injuries is estimated to 
be 5.5 to 13 times higher than the number of fatalities (30  000 – 72  000). The number of slight injuries, which 
is even more difficult to estimate, might be between 12 to 28 times higher (66  000 – 155  000 riders) in the 
EU-27. 
Evolution of fatalities
in EU road accidents
69,147
64,908
60,125
58,308
47,801
44,536
41,861
39,458
36,92452,65054,11155,268
54,720
33,11149,010
37,54558,7776,225
5,708
5,069
4,7994,6374,9575,4065,1975,778
5,593
5,3945,3155,309 5,304
4,8345,520
010,00020,00030,00040,00050,00060,00070,000
1991
1992
1993
1994
19951996
1997
1998
1999
20002001
2002
2003
2004
2005
2006
2007
2008
Source: CARE (EU road accidents database)
Other categories road accident 
fatalities
01,0002,0003,0004,0005,0006,0007,000
Motorcycle fatalities
Other categories road accident fatalities M otorcycles only
 
Figure 4: Road fatalities among powered two wheeler riders in the EU over time 
.
  
Figure 5: Probability of fatal injury depending on relative speed upon collision. 
Source: OECD presentation, International Transport Forum and Vulnerable Road User workshop (DG TREN, 15 July 2009) 
The human body’s tolerance to physical force is limi ted. According to the World Health Organisation, 
pedestrians incur a risk of around 80  % of being killed at an im pact speed of 50 km/h. However, this risk is 
reduced to only 10  % at 30 km/h. There is no difference between  a slow-moving pedestrian hit by a fast-
moving car or a PTW rider colliding with a fixed object at 50 km/h. It is the difference in speed upon collision 
that leads to fatalities and heavy injuries in road accidents. 
 
EN 14   EN In general, on a competitive market aiming to satisfy co nsumer preferences,  vehicle manufacturers will try to 
find the best compromise between driveability and perfor mance (torque and power) on the one hand and fuel 
consumption and fulfilling legal emission requirements on the other. This delicate balance achieved by the 
manufacturer during development may be significantly dist urbed through after-sales tampering with the type-
approved settings by or on behalf of the consum er. Tampering may improve driveability and engine 
performance but at the cost of significantly higher emi ssions and fuel consumption. At the same time, higher 
engine performance increases the maximum vehicle speed beyond that for which the other vehicle 
components are designed, leading e.g. to under-per forming brakes, power train components not able to 
withstand forces acting upon them, etc. All this can easily lead to an unsafe vehicle for both rider and 
environment. For this reason, anti-ta mpering measures are included in t he current Framework Directive for 
mopeds and low-displacement motorcycles. However, due to the shift from mechanical to electronic engine 
control or the use of other types of propulsion (e.g. el ectrical or hybrid engines), the current measures may 
no longer be effective or may even be obsolete. 
Mini-cars are defined as four-wheel vehicles with limited performance and mass. These are typically used in 
rural areas by older people who have never obtained a driving licence. Other users in urban areas may be 
younger drivers starting to learn to drive or drivers with court convicti ons who have been banned from driving 
a car. Some Member States even today have no drivi ng licence requirements for this vehicle type. The 
problem with these vehicles is that drivers may assume  the same level of active and passive safety as in 
passenger cars. However, their design concept, lowe r maximum speeds and less strict type-approval 
requirements means that this assumption is not necessa rily correct. The lower safety of mini cars in 
comparison with passenger cars has therefore been identified as a concern. 
Another area of concern for safety is that certain quadricycles, quads designed to be used off-road (all-
terrain vehicles or ATVs) are frequently driven on pub lic roads. As their name s uggests, these vehicles are 
mainly intended to be used off-road. Often, non-certifi ed versions of an ATV, for use only off-road, are also 
sold in the same shop. Using ATVs on the road may rais e safety issues because of their high acceleration 
capability and their high centre of gr avity, which can result in the vehicle rolling while  cornering. The absence 
of a differential on the driven axle(s), which is advant ageous in terrain, causes the vehicle to drift through 
bends on asphalt. Every other type of three- or four-w heel vehicle driven predominantly on asphalt is 
equipped with a differential28 or a similar device, as this is a basi c safety feature of such vehicles. The 
absence of a differential can be compared with a pa ssenger car equipped without windscreen wipers during 
rainfall. The vehicle will drive and the driver may adapt it s speed to move through traffic, but it is far from 
being safe, both for drivers and their environment. In a number of EU cities, the use of such vehicles is prohibited. In 2003, the total fleet was estimated to be only 95
 000 vehicles. Four years later in 2007, 
158 000 vehicles of this type were sold and the fleet size was estimated at 800 000 vehicles on EU roads. 
Gaseous fuels, for example CNG, LPG and hydrogen, ar e perceived by consumers as dangerous and as a 
potential safety risk, although they may provide signi ficant environmental benefit s. Safety concerns may 
include e.g. unsafe fuel storage desi gn or the possibility of fuel tubing connectors becoming loose due to 
engine vibrations, etc. At the time of analysis in th e impact assessment hydrogen technology for L-category 
vehicles was considered to be not mature. Other alternative propulsion technology may be mature for mass 
vehicle production, but may at the time of the impact assessment be not statistically relevant for the accident 
and safety statistics yet.  
2.1.4. Lack of a legal framework for new technologies 
L-category vehicle technology ha s evolved very fast over the la st decade. The development of the 
associated legislation has been much slower, with the resu lt that certain vehicles can no longer be allocated 
to the right L-vehicle category and a number of curr ent measures under the Framework Directive are no 
longer appropriate. For example, the current measur es do not apply to L-category vehicles with purely 
electric propulsion. For a moped with a small combustion engine, anti-tampering measures should mainly 
address mechanical manipulation, wh ereas measures to prevent engine management tuning may be more 
appropriate for both electric vehicles and vehicles equipped with a traditional combustion engine. For hybrid 
vehicles, both types of measures may be required. Ca tegorisation is therefore an issue affecting many 
aspects of the concerns raised above: complexity of  the legal framework, safety and environmental issues. 
                                                 
28 When cornering, the inner wheel needs to travel a sh orter distance than the outer wheel, so with no  
differential, the result is the inner wheel spinning and/or th e outer wheel dragging, resulting in difficult and unpredictable 
handling, damage to tires and roads, and strain on (or possible failure of) the entire drive train. 
http://en.wikipedia.org/wiki/Di fferential_(mechanical device) . 
 
EN 15   EN For example, on-road quads, off-road quads and mini-cars currently all fall within the same subcategory, 
L7e, and are all subject to the same requirements. Howe ver, quads and mini-cars are inherently so different 
in design that they each require specific legal requirements to be safe and comply with appropriate environmental standards. Low-power el ectric cycles (less than 250 W, up  to 25 km/h) currently fall outside 
the legal framework. In addition, more powerful cycles of up to 1
 000 W are also becoming very popular29 
throughout the EU. At the moment, these more powerful cycles are classified as mopeds. These cycles must 
hence comply with the type-approval requirements fo r vehicles with combustion engines, which are not 
appropriate for a purely electric vehicle. 
2.2. EU competence and subsidiarity 
Prior to the introduction of EU (then EU) type-approval for L-category vehicles, regulations were established 
at Member State level. The legislation adopted by Me mber States often differed and manufacturers selling 
on several markets were obliged to vary their producti on for each market and have their vehicles tested in 
each Member State in question, which was time-consumi ng and costly. Different national rules consequently 
hindered trade, and had a negative effect on the internal market. 
It was therefore necessary to establish standards at EU level, especially to tackle EU-wide concerns 
regarding safety and the adverse health and environmental  effects of air pollution. High emissions in local 
urban settings may be controlled by measures taken by individual Member States, but global emissions do 
not stop at borders. This Europe-wide concern ca n only be addressed by harmonised, EU-wide measures. 
Framework Directive 2002/24/EC was designed to do this and aimed to establish an internal market while 
ensuring a high level of protection of health, safety a nd the environment. Such a rationale is still valid today 
as EU action is needed to avoid fragmentation of the in ternal market and to ensure a high and equal level of 
protection across Europe.  
A further added value of EU legislation is that harmoni sed legal requirements allow industry to profit from 
economies of scale: for instance, products can be made for the whole European market, instead of being 
customised to obtain national type-appr oval for every single Member State. Consumers will benefit from 
lower product prices, which are constantly under pressure owing to EU-wide competition. 
3. O BJECTIVES  
3.1. General objectives 
The general objectives of the initiative are to simplify of  the current legal framework, to contribute to a lower, 
more proportionate share of overall road transport emis sions, and to increase functional safety for new 
vehicles entering the market. 
3.1.1. Specific objectives: simplific ation of existing EU legislation  
The specific simplification30 objective is to develop a less complex regulatory approach that ensures greater 
efficiency, less time loss and less burdensome adaptation to technical progress. Replacing existing 
provisions in the Framework Directiv e by references to equivalent or more appropriate UNECE regulations 
has a high priority for the Commission in order to  pursue the high-level goals set out in CARS 21. 
Another specific objective is to see how duplication of international standards can be reduced so that 
stakeholders are not confr onted with several sets of require ments addressing the same aspects. 
3.1.2. Specific environmental objectives 
A specific objective for environmental measures is to ke ep the share of L-category vehicle emissions in total 
road transport emissions at least constant compared to current levels, or preferably to reduce them in 
proportion to actual use/total mileage compared to ot her road vehicle categories. In addition, evaporative 
emissions must be addressed to help achieve the specific pollutant emi ssion reductions targeted by the 
Commission. The long-term aim (2020 – 2021) is to reduce the share of L-category vehicle emissions in total 
road transport emissions by at least 16  % for CO, 15  % for HC, 37  % for PM and 27  % for NOx (in tonnes) 
compared to the ‘no change’ scenario.  
In the long run, the Commission also  wants transparency in the choi ce between alternative modes of 
transport in terms of environmental performance, and is considering using only one emission laboratory 
testing cycle (WMTC) instead of t he four testing cycles used today. 
                                                 
29 See the economic market overview of L-category v ehicles in this report, el ectric cycles, Annex IX. 
30 http://europa.eu/scadplus/glossary/l egislation_simplification_en.htm . 
 
EN 16   EN 3.1.3. Safety specific objectives 
The specific objectives are to help achieve the same hi gh reductions in road accident fatalities and casualties 
as for other means of road transport, with the falling trend in passenger car fatalities since 2000 as the 
benchmark, to maximise accident mitigation to prevent serious and minor injuries as much as possible, and 
to help close the gap between actual road accident fa talities and casualties and the medium- to long-term 
road safety targets. 
3.1.4. Specific objectives for legal requirements and technology developments 
A number of technology developments should be reflected in  legal requirements at EU level in order to allow 
the industry to type-approve a produc t only once and then to market and se ll certified products not only in the 
EU internal market but also in countries that opt to  apply UNECE regulations. With clearer criteria for the 
various subcategories of L-category vehicles, this  can be achieved more effectively and efficiently. 
4. P OLICY OPTIONS  
A number of options have been analysed for each of the ar eas addressed by the objectives. As analysis has 
shown that there are no significant tr ade-offs between the different area s, the options will be presented as 
separate sets. 
4.1. Simplification of existing EU legislation 
The assessed policy options were the following: 
(1) No policy change 
No change would be made to the current regulatory framework. The Framework Directive would still lay 
down the EU type-approval system, while technical r equirements would still be established under separate 
directives, which require transposition into national legislation. Amending direct ives would also require 
transposition. The Commission would have to continue m onitoring transposition into the national legislation 
of 27 Member States. 
(2) Repeal current directives and replac e with a minimum number of regulations 
The Framework Directive, the 13 te chnical directives and their 21 amendments would be repealed. A new 
Regulation adopted through the ordina ry legislative procedure would c ontain the fundamental requirements 
of the EU type-approval system, while all detailed technical requirements would be gathered into a small 
number of implementing regulations, to be adopted and more easily updated in future through the committee 
procedure (‘comitology’). 
Similar to what has been introduced for motor vehicles in the General Safety Regulation (GSR), if equivalent 
technical standards have been adopted by UNECE, the provisions of EU directives could be repealed and 
replaced by a reference to these international st andards. This option could take different forms: 
- Full references, where the text is copied in full and published by the EU; 
- Simple fixed (static) references, where the EU l egislation links to a dated international regulation; 
- General (dynamic) references, where the EU legislation links to a regulation of an international standardisation body, but without dating it: this would allow automatic adjustment in line with updates of 
these technical requirements. 
From the point of view of legal certainty and control over EU legislation, the latter possibility (dynamic 
references) seems unacceptable. In consequence, this  is not further analysed. The same split-level 
approach could be followed as when legislation was in troduced for other EU vehicl e categories, e.g. light- 
and heavy-duty vehicles. 
(3) Recast the current Framework Directive 2002/24/EC  
The current Framework Directive would be revised an d re-enter into force from a given date. Some 
measures in the Framework Direct ive would be amended in order to update them and align them with 
technical progress. References to UNECE Regulations would be used consistently. The same process would 
apply to the 13 implementing directives and thei r 21 amendments. These would be codified and their 
provisions as much as possible replaced by refe rences to global UNECE regulations. The split-level 
approach is assumed for this option as well. 
4.2. Environmental measures 
For obtaining a type-approval certificate for a new vehi cle design, the manufacturer must demonstrate to the 
type-approval authorities that a new vehicle type complie s with the set of rules defined by the regulatory 
framework and more specifically with the detailed techni cal provisions in associated  legal acts. In order to 
demonstrate to the type-approval authorities that a mass-p roduced series of vehicles complies with all these 
legal requirements, demonstration tests must be perform ed in the presence of the type-approval authorities 
 
EN 17   EN well before the start of mass production, during the development of a new vehicle design. In these 
demonstration tests, performed with a limited number  of representative vehicles, vehicle emissions are 
tested in a certified emission laboratory equipped with  an engine dynamometer, on which the vehicles are 
tested following mandatory test procedures.  
The emission laboratory is equipped with certified measur ing equipment that collects the exhaust gas flow in 
bags while the vehicle is tested on the engine dynamome ter using e.g. the World-wide Motorcycle emissions 
Testing Cycle (WMTC). The contents of the bags are analysed at t he end of the test and the test results 
must be below the legal emission limits. The test cycle simulates a representative real-world driving profile 
and the test results are supposed to reflect the real-world  emission performance of the tested vehicle, which 
in turn is supposed to be representative of the emissi on performance of the mass-produced vehicles that the 
manufacturer intends to market after obtaining type-approval.  
Possible policy options for requirements prior to the star t of production to obtain type-approval are listed in 
chapter 4.2.1. Policy options to control vehicle emissions after start of mass production and after type-
approval are listed in chapter 4.2.2. If the latter type of options is included in the new legal framework, the 
vehicle manufacturer must ensure that these requirements continue to  be met to retain type-approval. 
In order to reduce and/or control the emissions from L-ca tegory vehicles over vehicle life, a number of policy 
options are considered as a package applicable bef ore and after type-approval of a new vehicle. 
4.2.1. New or revised environmental measures for the type-approval of new vehicles 
4.2.1.1. Revised lower emissions limits. 
Different options have been developed and analysed wi th regard to new emission limits for different 
pollutants: 
(1) No action; 
(2) Use of the traditional R47 test cycle but including cold start and a 30  % weighting factor for cold 
start in this emission laboratory test cycle are proposed. In this option the emission limits remain 
unchanged for mopeds and all other L-category vehicles.  
 
Figure 6: R47, driving cycle for mopeds (Euro 1 and Euro 2); 
Pollutant sampling is conducted from sub-cycle 5 to 8 for Euro 2 mopeds. In option 2, which is a 
possible Euro 3 measure for mopeds, cycles 1 to 4 will also be sampled, but only weighted for 30  % 
of the total pollutant emissions sampled over the whole test. The reason for a lower weighting 
factor in the phase where the engine  is cold and warming up (sub-cycle 1 to 4) is that under real-
world conditions the engine will operate for a higher percentage of time when it is warm. Hence, in 
line with the assumptions behind the R47 test sa mpling definition for Euro 2 mopeds, the moped 
will, under real-world c onditions, be started two to four ti mes a day with a cold engine and then 
warmed up. The moped engine is thus assumed to be warm for most of its operating time. In option 
2, this is represented by a (100  % — 30  % =) 70  % weighting factor for the warm engine phase 
(cycles 5 to 8). For Euro 2 mopeds it does not matter how much the moped engine emits in sub-
cycles 1 to 4, which means that the manufacture r must only optimise the emissions of the warm 
engine (represented by cycles 5 to 8), which have a weighting factor of 100  % in a Euro 2 test. 
In option 2, consequently, the m oped manufacturer must ensure t hat moped emissions in the cold 
phase are controlled by an exhaust after-treatme nt system that also operates under cold engine 
conditions (lower light-off or operating temperature)  and/or by optimising engine calibration (tuning) 
to take account of cold-start conditions and warming-up of the moped engine. As cold-start 
emissions are also includ ed in the test result in  option 2, total measured pollutant emissions will be 
 
EN 18   EN higher, which will make it more challenging for the manufacturer to meet the same emission limits if 
option 2 were retained as a Euro 3 measure. 
(3) This option reflects the motorcycle industry proposal31. Among many other scenarios (17 for 
categories L1e to L7e in total), the manufacturers propose a -25  % reduction for L3e motorcycles 
compared to Euro 3 levels when the new regulation enters into force (2013) and a second 
reduction 3 years late r of approximately -50  % compared to Euro3 levels. This general reduction is 
not applicable to the other L-cate gory vehicles (L1e, L2e, L5e, L6e and L7e), for which individual 
reductions are proposed by the motorcycle industry association, ACEM. 
(4) New measures based on the best available techno logy applied to L-category vehicles sold today in 
the market. 
(5) New limits for all L-category vehicles equivalent in absolute terms to the Euro 5 stage for 
passenger cars. 
The five different options for the possible revision  of emission limits and the associated analysis are 
summarised in detail in Annex XI  and Annex XIV. 
4.2.1.2. Use of a revised World- wide Motorcycle emissions Testing Cycle (WMTC) for all L-category 
vehicles32. 
 
Figure 7: R40 European Driving Cycle for Euro3 L3e motorcycles. WMTC alternative driving cycle for the type-
approval of Euro3 L3e motorcycles 
Under the umbrella of UNECE, a Worldwide Harmonis ed Motorcycle Test Cycle (WMTC), stage one, was 
developed, which manufacturers in the EU have been able to use since 2006 to type-approve a new L3e 
motorcycle. Manufacturers may contin ue to use the traditional European Drive Cycle (R40 cycle) for type-
approval testing. Mopeds and light quad ricycles are currently type-approved using the R47 test cycle (distinct 
from the Motorcycle EDC R47 and the WMTC). 
Stage 2 of the WMTC includes a number of technica l revisions to widen the scope of use and improve 
WMTC stage one. Specific type-approval emission limits were developed for WMTC stage one. In this 
impact assessment, the pros and cons of using onl y WMTC stage two, completely abandoning the EDC 
cycle, are assessed for motorcycles.  For other L-category vehicles (mopeds, quadricycles) the impacts of 
using a revised WMTC and replacing the currently used R4 7 and R40 test cycles are assessed as well, with 
a view to harmonising the testing cycle acro ss the L-category. The assessed options: 
(1) No change; (2) Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category 
vehicles. 
4.2.1.3. Type-approval r equirements to measure CO
2 emissions and to determine fuel consumption 
CO 2 emissions from L-category vehicles repres ent overall a very small share of total CO 2 emissions from 
road transport. Initially, therefore, obligatory CO 2 emission measurement and f uel consumption determination 
and reporting at type-approval to pave the ground fo r the introduction of an energy efficiency labelling 
                                                 
31 Explained in detail in Annexes VI and VII of the IA report. In t he LAT report cf. chapter 3.2.2. At the MCWG of 29 June 09, th is 
was summarised in: 
http://circa.europa.eu/Public/irc/enterprise/automotive/lib rary?l=/mcwg_motorcycle/meet ing_june_2009/emisia_report_v2pdf/_
EN_1.0_&a=d . 
32 http://ec.europa.eu/enterprise/automotive/proj ects/report_measures_motorcycle_emissions.pdf  (ch. 2.3.1). 
 
EN 19   EN scheme at a later stage was not included in the public  consultation. An energy efficiency labelling scheme as 
such is not within the scope of this impact assessme nt but the data to be provi ded by the manufacturers as 
input for labelling is analysed. This item which obliges the manufacturer to measure CO 2 emissions and to 
determine fuel consumption at type- approval was addressed during an extended stakeholder consultation 
conducted in parallel to the impact assessment pr ocess in order to obtain additional information and 
stakeholder views on topics that em erged during the impact analysis.  
The market seems to be split into two regarding the lowering of CO 2 emissions and fuel consumption. Riders 
who buy a PTW or any other L-catego ry vehicle purely for leisure purposes and sports use may be relatively 
indifferent to fuel consumption and CO 2 emissions. This may still continue to be the case in future as L-
category vehicles are often perceived as emotiona l products and not as just an alternative means of 
transport. On the other hand, riders who use their v ehicles to commute back and forth to work and for 
professional purposes may be very interested in cont inuous improvements in fuel consumption and lower 
CO 2 emissions.  
Lightweight PTWs with relatively small engines fr equently have much better performance than passenger 
cars, but in many cases unfortunately have the same fuel consumption and CO 2 emissions as heavier 
passenger cars equipped with much bigger engines. Cons umer information is one of the most obvious and 
effective ways to address this issue.  In addition, the effectiveness of a future labelling scheme may be further 
strengthened by fiscal incentives  (e.g. vehicle tax linked to CO 2 emissions). This has been the case for 
passenger cars, and it is likely that such schemes will  evolve to include other categories of vehicles. If 
consumers are better informed and compare products not only on engine performance (power and torque) 
but also on CO 2 emissions and fuel consumption when buying a new motorcycle, the incentives for 
manufacturers to provide buyers with more fuel-efficient  vehicles will also increas e, regardless of whether 
these vehicles are used purely for leisure or for commuting to work and other professional reasons. 
Policy options assessed: 
(1) No change; 
(2) Type-approval requirements for CO 2 measurement and fuel consumption determination and 
reporting. 
4.2.1.4. Evaporative em issions test and limit 
In addition to exhaust gas emissions, emissions may occu r through evaporation of fuel from the fuel tank 
filler opening or from the fuelling system, especially  under hot ambient conditions. As in the case of 
passenger cars, a limit on such evapor ative emissions needs to be assess ed. There would be a requirement 
to perform a SHED test for type-approval and to comply  with a limit for hydrocarbons similar to what has 
been compulsory for gasoline passenger cars since 2000. Policy options assessed: 
(1) No change; 
(2) Replacement of all new carburetted models with f uel-injected models. Due to the closed circuit, fuel 
injection engines produce much lower evaporat ion emissions than carburetted engines; 
(3) Evaporative emissions test and lim it ensuring evaporative emission control for L-category vehicles. 
4.2.1.5. Durability requirements 
Vehicle emissions should preferably deteriorate very little over vehicle life, so it may prove to be necessary to 
limit the acceptable deterioration over vehicle mil eage in emissions, which are obviously very much 
influenced by the quality and functionality of exhaust after-treatment components and systems like catalytic 
converters and lambda sensors. Also, an increase in ra w engine-out emissions over  vehicle life due e.g. to 
engine wear will lead to higher emissions, even if t he exhaust after-treatment sy stems deteriorate only very 
little. Consequently, durability requirements should apply not just to exhaust after-treatment systems, but to 
the whole vehicle. Assessed policy options: 
(1) No change; (2) Deterioration reduced to 10
 % over useful vehicle life and linear extrapolation for higher mileages. 
This means that the manufacturer must guarantee  that well-maintained, aged vehicles with a 
defined useful vehicle life, e.g. 50  000 km for L3e motorcycles, do not exceed the type-approval 
pollutant limits. 
(3) Useful life increased by 60  %, i.e. similar trend comparable with the increase for passenger cars on 
the move from Euro 3 (80  000 km) to Euro 5 (160  000 km) stages. This means that, over and above 
option 2, useful life would be defined as 1. 6 x 50 000 km for L3e motorcycles, i.e. 80  000 km 
instead of 50  000 km. 
 
EN 20   EN 4.2.2. New measures to control vehicle emissions over vehicle life. 
4.2.2.1. In-use conformity (IUC) testing and limits 
IUC exhaust and/or evaporative emissions could be test ed and analysed on in-use vehicles. For this purpose 
a representative number of vehicles should be selected to perform IUC test ing. This representative sample 
would then be tested under vehicle-emission laboratory conditions and employing testing methods similar to 
the accurate and advanced methods used to test new vehicles in type-approval demonstration testing. 
Ultimately, if a high number of vehicles in the sample  failed to comply with the exhaust and/or evaporative 
emission limits, the vehicle manufacture r could be obliged to recall the vehicles in the field to correct the root 
cause of the failure. The burden of conducting this ty pe of test would be borne mainly by the vehicle 
manufacturers and the national authorities. Using IUC te sting as instrument to ke ep vehicle emissions under 
type-approval limits would be scrutinised. This policy opt ion could be part of the integral approach towards 
environmental measures to guarantee that the emissi on performance of a vehicle degrades over vehicle life 
only up to the defined levels. The following policy options regarding IUC testing are assessed: 
(1) No change (IUC not applicable to any L-category vehicle); 
(2) IUC procedure mandatory for all Euro 3 motorcycles.  
4.2.2.2. On-board diagnostic (OBD) sy stems and access to repair information 
If an emission-relevant component or system were to  fail suddenly or slowly degrades beyond acceptable 
levels, a clean vehicle may turn into a highly polluting vehi cle. In such cases, the driver will ideally need to be 
informed quickly, to take the vehicle to the garage at the next opportunity  and have it repaired. 
The OBD system is the vehicle’s se lf-diagnostic and reporting capabilit y. OBD systems give the vehicle 
owner, a repair technician or a PTI (periodical technical inspection) officer access to state-of-health 
information for various vehicle sub-systems and/or co mponents. For passenger-car  PTI testing, Directive 
2009/40/EC33 allows OBD information to be used instead of gaseo us (CO) testing, but this is not the case for 
L-category vehicles.  
Failing environmental and/or safety -relevant components or systems need to be rapidly diagnosed and 
indicated to riders, so that they can go to the gara ge to have the failure quickly repaired. This may mitigate 
adverse environmental and/or safety effects of such failures.  
During the repair cycle (diagnosis and analysis of problem /failure, repair of smallest identifiable component 
or ordering of replacement part and replacement of sma llest exchangeable unit), access to repair information 
is critical and directly relies on obtaining standardised diagnostic info rmation from the OBD system with a 
generic scan tool.  
Therefore, all these aspects of these integral requirements for the effectiv e and efficient repair of a vehicle 
were assessed as one combined measure. Assessed policy options: 
(1) No change (no introduction of OBD systems and access to repair and maintenance information); 
(2) OBD systems using a similar technology as for passenger cars (European OBD), including catalyst 
efficiency and misfire monitoring for all L-catego ry vehicles. Provision for access to repair and 
maintenance information, similar as for passenger cars; 
(3) Use of best available OBD technology: minor malf unction monitoring (e.g. circuit integrity check) 
(OBD stage 1) for all L-category vehicles, no catalyst  efficiency monitoring. Provision for access to 
repair and maintenance information, similar as for passenger cars. 
4.3. Safety measures 
With the aim of improving safety for vulnerable road users, the Commission intends to focus on a number of 
critical policy areas. However, these do not all fall under  the scope of this impact assessment, which is only 
limited to type-approval measures for new vehicles. Ex amples of measures not falling in the scope include 
the planning, design and operation of road networks, comp liance with key road safety rules, helmet design 
and use, protective clothing, licensing, testing and training, periodical technical inspections and road-side 
inspections. However, other possible  policy instruments for achieving road safety objectives involve new or 
amended measures related to the type-approval of new ve hicles, e.g. use of passive and/or active safety 
systems such as the fitting of advanced brake system s and a number of other functional safety-related 
vehicle features listed under the policy options. Thes e do fall within the scope of this impact assessment. 
A number of the safety measures assessed below may be left optional, made mandatory or left up to 
voluntary manufacturer initiatives. It may be necess ary to combine all the measures, to apply them 
                                                 
33 http://eur-lex.europa.eu/LexUriServ/LexUr iServ.do?uri=OJ:L:2009:141:0012:0028:EN:PDF , Annex II, Ch. 8.2.1.b, 4(iii). 
 
EN 21   EN individually, or to mandate them as different gr oups of measures, depending on the outcome of cost-
effectiveness calculations. 
Main possible measures assessed: 
4.3.1. Obligatory fitting of  advanced brake systems 
(1) No change; in this case the fitting of advanced  brake systems on PTWs would be entirely left to the 
market, i.e. depending on supply and demand. 
(2) Anti-lock brake systems34 on all powered two-wheelers (PTWs); 
(3) Anti-lock brake systems on PTWs with cylinder capacity35 > 125 cm3 and advanced brake systems 
(combined brake systems (CBS) and/or anti-lock brake systems (ABS)) on motorcycles with  
50 cm3 < cylinder capacity ≤ 125 cm3; 
(4) Obligatory fitting of advanced brake systems (combined brake systems and/ or anti-lock braking 
systems) on motorcycles conforming to the per formance criteria for the A2 driving licence36. 
Obligatory fitting of anti-lock brake systems on all other L3e class motorcycles; 
(5) Industry self-regulation, Annex V  
4.3.2. Anti-tampering measures  
In addition to chapter 4 of the TRL report, a separate report37 on anti-tampering was published on the 
Commission’s website explaining all the issues related to tampering in 2003. Many of its elements are still 
valid today, but technology developed fast in the last decade, which means that the report should be updated 
before finalising any detailed technical provision if opting for option 3. Assessed policy options 
(1) No change; 
(2) Repeal Chapter 7 of Directive 97/24/EEC (c urrently obsolete anti-tampering measures); 
(3) New measures on anti-tampering. 
4.3.3. 74kW power limitation for motorcycles 
The initial intention to limit motorcyc le power to 74 kW was to increase safety by inherently limiting maximum 
acceleration and vehicle speed. This concept is reasse ssed in this impact assessment for the following 
options: (1) No change; 
(2) Repeal the option given to Member States to limit power to 74kW; 
(3) Set a harmonised limit of 74kW; (4) Use an alternative limitati on, e.g. power-to-mass ratio. 
4.4. Improved categorisation of L-category vehicles 
4.4.1. Electrical cycles (current ly outside the scope of the Framewor k Directive), tricycles (L5e) and 
quadricycles (categories L6e and L7e) 
(1) No change; 
(2) Exclude quadricycles and electrical cycles and tricycles from the new Regulation; (3) Return to the original spirit of the legislation for mini-cars, reintroducing small external dimensions 
and the original vehicle weight classification criteria (400 kg / 550 kg); 
(4) Improve the legislation by adding new require ments for mini-cars based on car requirements; 
(5) Refine the vehicle categories by introducing new sub-categories in L1e, L5e, L6e, and L7e. Add 
new/revised requirements fo r these sub-categories. 
                                                 
34 Definition from TRL report: Anti-lock br aking systems (ABS) monitor the speed at which the wheels are rotating and rapidly 
modulate the brake pressure when imminent wheel lock is detec ted in order to increase effective braking and prevent 
deceleration being dictated by the sliding friction between tyre and road. ABS is the only technical solution  that directly 
monitors and prevents wheel locking and has been shown in test condi tions to result in generally higher braking deceleration 
by maintaining the wheel slip such that friction is above the level provided by locked wheels. Preventing wheel lock under 
emergency braking gives the rider greater confidence to apply higher brake forces, leads to shorter stopping distances and 
prevents the rider from falling. 
35 The figure of 125 cm3 corresponds to the thresholds in Directive 2006/126/EC  (recast Driving Licence Directive) for class A1: 
motorcycles with a cylinder capacity not exceeding 125 cm3, power not exceeding 11kW and a power/weight ratio not 
exceeding 0.1 kW/kg. 
36 Thresholds obtained from Directive 2006/126/EC  (recast Driving Licence Directive) fo r class A2: 1) power not exceeding 35 
kW, 2) a power/weight ratio not exceeding 0.2 kW/kg, and 3) not derived from a vehi cle of more than double the power. These 
are EU-wide criteria for distinguishing le ss powerful PTWs that beginners are allowed to ride within the first two years of 
getting their driving licence from powerful motorcycles that  may only driven by more experienced motorcycle riders. 
37 http://ec.europa.eu/enterprise/automotive/ projects/report_anti_ tampering_devices.pdf . 
 
EN 22   EN 4.4.2. Specific requirement s for category L7e vehicles 
(1) No change; 
(2) Exclude off-road quads (ATVs) from the new Regulation and add new requirements on safety and 
emissions for on-road quadricycles (on-road quads and mini-cars); 
(3) Keep the existing L7e category and add new r equirements on safety for all quadricycles; 
(4) Create new categories in L7e with specific  requirements for off-and on-road quadricycles. 
4.4.3. Specific requirements for gaseous altern ative fuels and other non-traditional propulsions 
The same technology trends can be observed as in light-duty vehicle technology. Different and new types of 
gaseous fuels and/or alternative prop ulsion technologies are being in troduced for L-category vehicles 
alongside or in addition to conventional gasoline or di esel fuels. Blends with ethanol, LPG, and CNG or even 
hydrogen may be used in future to propel vehicles. The first requests to ty pe-approve hydrogen-propelled 
motorcycles have already been received by the type-appr oval authorities of at least two Member States. 
Hybrid and purely electric technologies may also be adopted by manufacturers. All these different technology 
choices and mixes of technologies are only partly covered by the current legal framework or not at all. The 
policy options assessed in the impact assessment: (1) No change (legislation at national level); 
(2) Legislation at European Union level through a more refined vehicle categorisation with specific 
measures for different vehicles and propulsion technologies. 
5. A
NALYSIS OF IMPACTS  
5.1. Simplification of legislation 
 
Annex X  Full analysis, including all available quantitative  and qualitative aspects, of the 3 policy options 
for simplification: 
Option 1:  No policy change; 
Option 2:  Repeal current directives and replace with a minimum number of regulations; 
Option 3 : Recast the current Framework Directive 2002/24/EC. 
Table 1: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3 
Summary:  
Option 1: No policy change The main disadvantage of option 1 is that the problems described in chapter 2.2.1.of this impact assessment 
report will not be resolved. This is not in line with the Commission’s better regula tion objective, in particular 
as there will be no improvement in terms of safety or  environmental impacts. Continuing this approach would 
thus only place additional administrative burden on stakeholders. 
A positive point is that requirements will not be "diluted" by replacing provisions of EU Directives with 
references to international standards like those of UNECE. Indeed, some respondents to the public 
consultation have expressed concern that such re ferencing could reduce safety and environmental 
protection. Some even fear a loss of transparency and loss of complete European control over international 
regulation by EU regulatory instituti ons. Another positive aspect of opti on 1 could be that specialists who are 
already familiar with the current legal text need not spend costly time reviewing a completely new legislative 
text. However, these benefits cannot be expressed in  monetary terms and can therefore only be taken into 
account in the qualitative analysis. 
Option 2: Replace the current set of dire ctives by a small number of regulations 
The exact number of implementing regulations, setting technical requirements via the comitology procedure, 
would still need to be determined. These provisions c ould be grouped by themes, like road safety or 
environmental protection. The advantage of referri ng as much as possible to UNECE international 
regulations is explained under the discussion of option 3. 
This option would have the advantage of allowing technical experts to deal with coherent sets of issues via 
comitology. It is thus purely a prac tical approach, intended to facilitate adopt ion of the requirements, but will 
not affect the requirements themselves. Such an approa ch, using several sets of delegated acts containing 
the technical details, also aims to increase the clarity of the regulato ry framework for manufacturers who 
have to comply with it to obtain type-approval. This clarity for industry is an important benefit of the 
simplification exercise, in particular for SMEs, whic h have limited administrative resources to deal with the 
complex regulatory requirements for obtaining type- approval. The aim of providing a clear and logical 
structure is supported by industry representatives. 
As far as costs for administrations are concerned, t hese would be lower because there would no longer be 
any need to transpose directives into national law, leading to reduced costs for the Member States. The 
Commission would no longer be responsible for the time-consuming scrutiny of transposition. Both national and EU administrations would thus benefit from the new format. Grouping the regulations into sets will allow 
 
EN 23   EN experts to deal more coherently with aspects of simila r, limited objectives. The decision to opt for one or 
more implementing regulations should be agreed with t he comitology committees. In the assessment, it was 
not possible to quantify the benefits of si mplification in terms of lower cost  to industry or for consumers. 
A negative aspect of using a small number of implementi ng regulations can be the lengthy process involved: 
agreeing on one text including all requirements may take a lot of time for the committee and will involve 
different experts depending on the aspects covered. Another perceived disadvantage of this option may be 
the shift of control and scrutiny from national par liaments to the EU institutions. Basically, the EU 
Commission proposes a legal text for the new Regulati on and this text is scrutinised and voted on by the co-
legislators, the EU Parliament and Council. As so on as the Regulation is adopted and published in the EU 
Official Journal38, it will enter into force in all the 27 Members States simultaneously on the specified dates, 
without the extra step of having to be transposed into national law. 
From the cost perspective39, an average cost of €  2 .4 million may be incurred from 2009 until 2020, within a 
range of €  58 400 to €  8 .8 million. The annual cost of making amendments to the legal text would be slightly 
lower owing to the fact that technical progress can alr eady partly be anticipated w hen the new legislation is 
developed and adopted, which means that further amendm ents to adapt to technical progress can already 
be partly included. This effect cannot  be quantified. For the timeframe 2009 to 2020, an average cumulative 
benefit of €  421  000, within a range of €  78 000  to €  786  000, was calculated for this option. The cost-benefit 
ratio was on average 1.2, within a range between 1.1 and 2.5. The break-even point is estimated to be 
reached between the years 2017 and 2019. 
Table 8, p. 17, of the TRL report40 provides an overview of the qua ntitative and qualitative impacts for 
simplification options 1 and 2. 
Option 3: Recast the current Framew ork Directive 2002/24/EC, simplify by referring to UNECE regulations, 
and maintain the implementing measures. 
An alternative to option 2 could be to recast41 the current Framework Direct ive 2002/24/EC, referring as 
much as possible to UNECE regulations. This will benefit  all actors dealing with this legislation, whether 
national authorities responsible for ty pe-approval or manufacturers whose vehicle types have to comply with 
these requirements. In particular SMEs will benefit, as  they have limited resources to devote to reviewing 
regulatory matters. To respond to concerns as to a we akening of requirements, it  should be stated clearly 
that references will be proposed only in cases where the international standards are at least equal to the relevant EU directives. 
The disadvantage mentioned under option 2, regarding a shi ft from national control and scrutiny to control by 
EU institutions, is not applicable in option 3. As t he Framework Directive and its implementing measures will 
not be turned into a Regulat ion, the recast Directives will nee d to be transposed
42 into national legislation. 
On the other hand, the additional cost of this transposition remains. 
Manufacturers will continue to select the approv al tests needed among the UNECE and remaining EU 
standards. There will be no additional administrative or type-approval costs compared with those under 
option 2. The requirements of repealed directives will be replaced by equivalent requirements. There is 
therefore no additional cost, but also no direct benefit in terms of cost reductions for manufacturers. The 
envisaged benefit will be simplification and clarification of the regulatory fr amework, but this is particularly 
hard to quantify. 
The cost of this option is estimated to be in the same range as option 2, except th at the cost of transposition 
needs be added. Although the precise differences bet ween option 2 and 3 cannot be quantified, it is 
assumed that the cost-benefit ratio of  option 3 is lower (higher cost owing to transposition, more or less the 
same benefits). This also means that the brea k-even point will be reached later than the 2017 – 2019 
timeframe. Again, it was not possible to exactly quantify these financial indicators. 
The societal impacts of option 3 are similar to those of option 2, but as it involves  recasting directives, option 
3 does not eliminate transposition and implementation co sts for the administrations in the Member States. It 
is again likely to yield a low cost-benefit ratio and result  in the break-even point bei ng reached at a later date. 
                                                 
38 http://eur-lex.europa.eu/JOIndex.do?ihmlang=en . 
39 http://ec.europa.eu/enterprise/automotive/pr ojects/report_new_m easures_l_category.pdf . 
40 TRL report, http://ec.europa.eu/enterprise/automotive/pr ojects/report_new_measures_l_category.pdf , chapter 2. 
41 http://europa.eu/scadplus/glossa ry/legislation_recasting_en.htm . 
42 EU directives are transpos ed into local legislation. 
 
EN 24   EN Unfortunately, this hypothesis for option 3 cannot be su pported with data. This scenario was not included in 
the extended policy report and, owing to  timing constraints on collecting data after this report was published, 
only an estimate can be made, based on previous exper ience with the recasting of  the Framework Directive 
for Euro 5 & 6 passenger cars. The option to refer to global standards, also used in the General Safety 
Regulation for motor vehicles, is widely supported by st akeholders, as expressed in their replies to the public 
consultation. 
 
EN 25   EN 5.2. Environmental measures 
5.2.1. New or revised environmental measures for the type-approval of new vehicles 5.2.1.1. Revised lower emissions limits 
Annex XI  
Annex XI Ch. 1.1  
Annex XI Ch. 1.2  
 
Annex XI Ch. 1.2 Opt. 1  
Annex XI Ch. 1.2 Opt. 2  
 
 Annex XI Ch. 1.2 Opt. 3
 
Annex XI Ch. 1.2 Opt. 4  
 Annex XI Ch. 1.2 Opt. 5
 
 
Annex XI Ch. 1.3  
 Revised lower emissions limits, detailed analysis  of proposed limits for L-category vehicles, 
subcategories L1e to L7e, by comparison with light-duty M1 emission limits; Qualitative analysis of the 5 policy opt ions to revise the emission limits. 
 
Option 1:  No policy change; 
Option 2:  New emission limits for L1e mopeds: a cold-start R47 test cycle and a 30
 % weighting factor 
for cold start are proposed (scenario 1 from LAT report). No change in limits for other L-category 
vehicles; Option 3 : Motorcycle industry proposal (scenario 2 from LAT report); 
Option 4:  New measures based on best ava ilable technology for L-category vehicles sold today in the 
market (scenario 3 from LAT report); Option 5 : New limits for all L-category vehicles equivalent in absolute terms to Euro5 M1 light-duty 
vehicles (scenario 4 from LAT report); 
Quantitative analysis: policy options for new emission limits, summary of the cost-effectiveness of the 
proposed emission limit options. 
Table 2: Click on ‘Annex’ links to display the full, detailed analysis of policy options 1 to 5 
Summary:  
Chapter 1.1 of Annex XI lists the cu rrent emission limits and the proposed new limits as a percentage of the 
Euro 5 passenger car limits. At the MCWG35 of 29 June 09 (agenda item 6a) it was explained why L-category 
vehicle emission limits and those for passenger cars ar e directly comparable in order of magnitude. Looking 
at the high limits for THC and CO it bec omes obvious why the shares of these emissions from the L-category 
vehicle fleet compared to all ot her means of transport ar e currently a concern, and will grow to a 
disproportionate 62  % for HC and 35  % for CO by 2020 if the emission lim its are not revised. Chapter 1.2 
provides a quantitative analysis of the pros and cons of every option and,  finally, chapter 1.3 discusses the 
cost-effectiveness of each. 
Option 2 only covers one critical category, mopeds, and only one single aspect: cold-start weighting in the 
emission test. Therefore this option can be regarded as a technical sensitivity study to show that the impact 
of a cheap, simple measure on the overall exhaust emissions of one vehicle cl ass can have a slightly 
positive effect. One positive impact is its relatively high cost-effectiveness. A negativ e impact is that mopeds 
may be among the highest emitting road vehicles, but only a minimum reduction will be obtained in 
comparison with the benchmark passenger cars. Another negative impact is that all other high-emitting 
vehicles in the L-category are not subject to revised emission limits. Th erefore, the overa ll reduction will be 
only 7  % for HC and 2  % for CO. 
For option 3, the industry proposal for emission redu ctions in two steps, a technical sensitivity study 
presented at the MCWG35 of 29 June 2009 showed that t he level of the limit has only a limited effect on total 
L-category vehicle emissions for the assessed timeframe until 2020. The effe ct will be more significant if the 
models were able to predict overall emissions until 2030.  However; this is technically not feasible for the 
moment, so the comparison base is 2009–2020. The rapi d introduction of the limits is the most important 
factor in reducing L-category vehicl e emissions on the short to medium term. Option 3 can in principle be 
introduced quickly, is still reasonably cost-effe ctive and is su pported by the industry (minimal implementation 
time anticipated). The negative impact is that HC a nd CO emissions will remain disproportionately high 
compared to all other means of transport up to 2020 and beyond. 
This latter disadvantage also applies to option 4 and even option 5, where the limits are assumed to be 
equivalent in absolute terms to EURO 5 for passenger ca rs. A further negative impact of option 4 is its low 
potential to reduce HC (only 2  % by 2020). A negative impact of option 5 is its high cost for industry in the 
short to medium term. A positive aspect of option 5 is that it is the best performing option in terms of 
emission reduction: it is expec ted to yield reductions of 19  % in CO, 28  % in HC, 40  % in PM and 37  % in 
NOx. 
5.2.1.2. Use of a revised World- wide Motorcycle emissions Testing Cycle (WMTC) for all L-category 
vehicles  
Annex XI, Ch. 1.4  Option 1:  No policy change; 
Option 2:  Use of a revised World-wide Motorcycle emi ssions Testing Cycle (WMTC) for all L-category 
vehicles. 
Table 3: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 and 2 
Summary:  
The disadvantage of option 1 is that  the benefits from common improvements to the test cycle as adopted by 
the UNECE cannot be completely leveraged for L3e motorcycles type-approved for the use in the EU 
market. Another disadvantage is that the proliferation of testing cycles for L-category vehicles will remain, 
 
EN 26   EN which makes it difficult to compare the emission perf ormance of the various vehicle subcategories. In 
addition, it will continue to be impossible for consumer s to compare alternative vehicle types within the L-
category in terms of CO 2 emissions and fuel efficiency. A positive aspect is the minimised compliance costs 
for manufacturers. 
Option 2 has a number of advantages in economic, envir onmental and societal terms. Owing to the higher 
share of ‘transient manoeuvres’, it is generally accept ed that the WMTC reflects real-world conditions better 
than the currently used R40 and R47 test cycles. Opting for stage-two as against stage-one WMTC is also 
assumed to be emission- and cost-neutral. If, however, t he R47 test cycle for mopeds is repl aced by a future 
revised WMTC-based test cycle, there may initially be  increased compliance costs, although the measure is 
estimated to be cost-neutral in the medium to long term . A replacement for the R47 test cycle currently does 
not exist, but it is feasible to define such a test cycle, based on WMTC, in collaboration with the global 
community represented in UNECE WP29. It is expect ed that fewer test cycles worldwide will be 
advantageous for L-category vehicle producers in the EU  owing to reduced global compliance costs for type-
approving vehicles and more transparency for consumer s purchasing vehicles in the EU in terms of toxic 
emission reduction performance, green house gas emissions and fuel consum ption. This may also stimulate 
L-category vehicle use as an alter native to other means of transport. A compulsory labelling scheme for CO 2 
and fuel consumption is expected to be useful to suppor t consumers in their purchasing decisions in order to 
obtain best value for money. 
5.2.1.3. Type-approval requirements for CO 2 measurement and fuel consumption determination and 
reporting 
Annex XI, Ch. 1.5  Option 1:  No policy change; 
Option 2:  Type-approval requirements for CO 2 measurement and fuel c onsumption determination and 
reporting 
Table 4: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 and 2 
Summary:  
Option 1, no change, has the disadvan tage that type-approval demonstration testing does not provide a full 
environmental picture of the vehicl e: only the emissions of pollut ants are measured and compared to the 
type-approval limits, whereas CO 2 and fuel consumption need not even be measured or reported, although 
the measurement of this data comes at zero cost for the manufacturer. A further disadvantage of option 1 is 
that consumers do not consistently get fuel efficiency  information to allow them to choose the most fuel-
efficient form of road transport. This is a pity, as L- category vehicles are light and therefore have an inherent 
advantage in comparison to passenger cars. The advantage of option 1 is that the cost of introducing a 
product labelling system for manufacturers, importers and de alers is minimised, and it is  left to the initiative 
of industry to fully inform its customers. 
Option 2 calls for CO 2 measurement and fuel consumption determi nation and reporting at type-approval and 
to be indicated on the type-approval certificate and on t he certificate of conformity . This data can then be 
used in a next step as a basis for a class A — G labe lling system (as for other energy-consuming products), 
similar to that proposed for passenger cars with Di rective 1999/94/EC. The disadv antage of option 2 is the 
additional cost and effort of labelling vehicles for the manufacturer and, further downstream, for the dealer. 
As a fuel efficiency labelling scheme as such did not  fall under the scope of this impact assessment It was 
not possible to quantify the total cost to manufac turers and how much would be passed on to the end-
customer. It was assumed that the cost of measurement for manufactu rers would be insignificant, as CO 2 
must be measured anyway for type-approving pollut ant emissions (to provide a base for pollutant 
measurement correction). Fuel cons umption is calculated based on CO 2, CO and HC emission 
measurements. The market will decide whether this low cost is passed on to the co nsumer or absorbed by 
industry. Another advantage of this option is that mo torcycles in future may no longer compete on only 
engine performance (power and torque), but also on t heir ability to perform well with minimised fuel 
consumption. A further possible future advantage of option 2 is an EU-wide CO 2 and fuel consumption 
labelling system, if introduced, avoiding the need for nat ional labelling systems that may be costly to industry 
and confusing to consumers if they co mpare vehicles in different Member States. Therefore, making labelling 
mandatory just at national level may be ineffective and  may have little added value for consumers. Again the 
labelling system as such was not the topic of this assessment, but obligatory measurement and 
determination of its input  data at type approval. 
5.2.1.4. Evaporative em issions test and limit. 
Annex XI, Ch. 1.6  Option 1:  No policy change; 
Option 2:  Replacement of all new carburetted m odels with fuel-injected models (scenario; 
Option 3:  Evaporative emissions test and limit ensuring evapor ative emission control fo r L-category vehicles 
Table 5: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3 
 
EN 27   EN Summary:  
The major disadvantage of option 1 is that it does not address the disproportionately high HC emissions. 
However, no hardware or software changes are required, nor  must a special test facility be rented or bought 
by manufacturers, so this option has the advantage of  no extra costs for manufacturers and consumers.  
Option 2 has advantages, but the high cost of fitting electr onic fuel injection (EFI) to every L-category vehicle 
just to reduce the high share of evaporative HC emissi ons makes it seem largely academic. As the stricter 
emission limits under option 3 may lead to substantially more vehicle categories being equipped with EFI, the 
advantages of this option will automatically apply owing to organic growth in the share of vehicles with EFI. 
The basic reason for introducing EFI is better control of  fuelling, which allows exhaust gas emissions to be 
minimised and more flexibility for the manufacturer to optimise vehicl e drive-ability. The reduction of 
evaporative emissions is just an adv antageous and desirable side-effect. 
The disadvantage of option 3 is additional vehicle comp lexity and thus cost for the manufacturer, which will 
be passed on to the consumer, hence increasing vehicle pr ices. The advantage is that this is one of the more 
cost-effective policy options, as identified in the curren t and previous versions of the LAT report (2004 and 
2008). This means that the dispropo rtionately high HC emissions can be r educed by a relatively simple and 
cost-effective method. 
5.2.1.5. Durability requirements 
Annex XI, Ch. 1.7  Option 1: No policy change; 
Option 2: (Scenario 2 from the LAT report): deterioration reduced to 10  % over useful life with linear 
extrapolation for higher mileages; 
Option 3 : (Scenario 2 from the LAT report): useful life increased by 60  %, i.e. equivalent to the increase for 
passenger cars upon the move from Euro 3 (80k km) to Euro 5 (160k km). 
Table 6: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3  
Summary:  
Option 1, no change, basically means that the policy options for new emission limits, as summarised in 
chapters 5.2.1.1 and 5.2.1.4, will be ineffective. If there is no need for a manufacturer to guarantee that 
emissions, as measured in demonstrati on testing for type-approval with a single new vehicle, remain within 
acceptable limits during vehicle life (e.g . over an accumulated mileage of e.g. 12  000 km for mopeds or 
50 000 km for motorcycles, tricycles and on-road quads),  the emission limit met by this new vehicle, as 
demonstrated to the type-approval authorities before the start of mass production and before introduction on 
the market, may be largely irrelevant. There is a high ri sk that once vehicles start to accumulate mileage 
under real-world conditions their tailpipe emissions will deteriorate, as described in the durability test report 
published by the AECC (see chapter 2.1.2,  problem definition, footnote). The same may hold for evaporative 
emissions. If an aged carbon canister, used to store HC until it can be fed back into the engine for 
combustion, is not tested prior to the start of produ ction as part of the demonstration testing programme43, 
the type-approval authorities will be unable to determine if this part of the emis sion abatement system will do 
what it is designed to: to significantly reduc e evaporative emissions over vehicle life. 
The advantage of options 2 and 3 is t hat these concerns will be addressed. As IUC testing was discarded for 
reasons explained in the next chapter, there is no direct  market surveillance mechanism within the EU to 
monitor and feed back to the legislator if and to what ex tent these concerns actually materialise. In PTI and 
RWT testing, which are only employed at national level in some Member States, it is not possible to verify 
what the exact level of degradation of  the vehicle fleet is in terms of exhaust and evaporativ e emissions over 
vehicle life. This can only be verified in an emissi on laboratory with measurement equipment as used for 
type-approval demonstration testing. Therefore, durabilit y requirements as defined in options 2 and 3 are the 
only way to ensure upfront of market introduction that  vehicles may be still accept ably close to the type-
approval emission test results when accumulating mileage under real-world conditions. The disadvantage of 
options 2 and 3 is that the manufacturer carries the full burden of guaranteeing that the vehicles fulfil the 
durability requirements, whic h means increased compliance costs an d longer development programmes, so 
the time-to-market for new products may also increase . An additional disadvantage of option 3 is that moving 
from no durability requirements at present to high mil eages may lead to initially uncompetitive products, as 
extending the mileage in durability testing is costly a nd time-consuming. This may result in manufacturers 
requiring more time to bring new products to the ma rket, and the additional cost may be transferred to the 
consumer. It is necessary to monitor and evaluate the em ission performance of the vehicle fleet some time 
after a durability measure is introduced to determine if a higher vehicle mileage should be set for useful life at 
a later stage. Annex XI, Ch. 1.7 , contains a proposal for the initially assumed useful life of the different L-
category vehicles subject to type-approval emission limits. 
                                                 
43 Introducing a SHED test limit value of e.g. 2 g for a new/degreened canister. 
 
EN 28   EN 5.2.2. New measures to control emissions from vehicles in use 
5.2.2.1. In-use conformity (IUC) testing and limits 
Annex XI, Ch. 2.1  Option 1:  No policy change; 
Option 2: (Scenario 1 from LAT report): IUC procedure mandatory for all Euro 3 motorcycles. 
Table 7: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 and 2  
Summary:  
Owing to the many disadvantages, e. g. the low likelihood of finding appropr iate, representative vehicles on 
the market for an IUC test sample and its low cost-e fficiency, option 2 was discarded. Although option 2 only 
assessed motorcycles, the same arguments apply to ot her L-category vehicles such as mopeds, ATVs and 
mini-cars. 
5.2.2.2. On-board diagnostic (OBD) sy stems and access to repair information 
Annex XI, Ch. 2.2  Option 1:  No policy change; 
Option 2: (Scenario 1 in LAT report): application of OBD systems using a similar technology as for passenger 
cars (EOBD), including catalyst efficiency monito ring for all L-category vehicles. Provision for 
access to repair and maintenance information, as for passenger cars; 
Option 3:  (Scenario 2 in LAT report): use of best ava ilable technology (BAT): mi nor malfunction monitoring 
(e.g. circuit integrity check) (OBD stage 1) fo r all L-category vehicles, no catalyst efficiency 
monitoring. Provision for access to repair and maintenance information, as for passenger cars. 
Table 8: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3 
Summary:  
Option 1, no change, does not require an on-board diagnostic system for L-category vehicles. The 
disadvantage of this approach is that  that there will be no standardised diagnostic socket to connect a 
cheap, generic scan tool used by independent repairers or riders that wi sh to repair vehicles themselves, 
there will be no standardised communication protocol for the engine control module to `talk´ to a generic 
scan tool, no diagnostic information, such as diagnosti c trouble codes (DTCs) or freeze-frame information, 
will be available to a generic scan tool, and independent repairers will be unable to effectively or efficiently 
diagnose simple failures that may lead to high emissions or unsafe situations. In addition, will there be no 
obligatory standardised malfunction indicator light to indica te to the rider that there is a serious problem with 
the engine or vehicle which ought to be repaired in orde r to prevent environmental damage or a safety risk. 
The disadvantages associated with opti on 1 are addressed by options 2 or 3, which is an advantage of both 
options. The disadvantage of option 2 is that it ma y need some additional development for motorcycles in 
order to find cost-effective solutions to detect misf ire at high engine speeds (maximum engine speeds may 
be up to twice that of typical passenger car engines). In  addition, robust catalyst diagnostics may be for the 
moment still problematic, and the additional hardware and software development needed to support full EOBD, as in passenger cars, is considered to be rather  expensive for the industry over the short term. 
Option 3, however, calls for introducing the simplest  form of OBD, termed OBD stage I, combined with 
access to repair information for independent repairers an d riders who wish to repair their own vehicles, as 
already applicable today in the passenger car industry. All vehicles equipped with electronic control units 
(fewer mopeds, but all other new vehicles in the L-cate gory) already have this proprietary functionality on-
board. Therefore, the cost of introducing this opti on is expected to be low — vehicles need to be have a 
standardised diagnostic connector, two wires in the wiri ng harness from the connector to the ECU, and a 
standardised communication protocol(CAN), possibly a CAN interface in the ECU. In addition, minimum 
software development is required since 95
 % can be copied from passenger car applications and can be re-
used over the next decade on new models. A very small ca libration, verification and validation effort is also 
needed, but can be re-used to a great extent for other types and variants or successor models. So, option 3 requires a one-off moderate investment by the manufa cturer but can then be carried over and re-used to a 
great extent over a long period. Acco rdingly, the high costs of OBD stag e I implementation as identified in 
the LAT report were found to be too high by the Commi ssion, at least over the medium to long term, and 
hence were rejected. Even for vehicles mass-produced on just a fraction of the sc ale compared to passenger 
cars, as in the case of L-category vehicles (lower ec onomy of scale), the total cost for the manufacturer is 
estimated to be 25
 % to 50  % of the cost estimated in the LAT report, which obviously leads to significantly 
better cost-effectiveness and hence represents an advantage for this option. The disadvantage for the 
manufacturer, apart from the one-off investment, is sli ghtly increased compliance costs. However, as many 
contract dealers may be independent repairers for other  brands, harmonised OBD information will also be 
advantageous to this sector. Moreov er, riders who are technically interested and opt to repair their own 
vehicles will benefit from standardised,  basic diagnostic information, as generic scan tools can be purchased 
on the market. 
5.3. Safety measures 
5.3.1. Obligatory fitting of  advanced brake systems 
Annex XII  
Annex XII Ch.1   
Qualitative and quantitative analysis of policy optio ns for obligatory fitting of advanced brake systems  
 
EN 29   EN Annex XII Ch. 1.1  
Annex XII Ch. 1.2  
Annex XII Ch. 1.3  
 
 Annex XII Ch. 1.4
 
 
 Annex XII Ch. 1.5
 Option 1:  No policy change; 
Option 2:  Anti-lock brake systems on all powered two-wheelers (PTWs); 
Option 3:  Anti-lock brake systems on PTWs with cylinder capacity >125 cm3 and advanced brake systems 
(combined brake system and/or anti-lock brake systems) on motorcycles with 50 cm3 < cylinder 
capacity ≤ 125 cm3 (NB: 125 cm3 relates to vehicle performance criteria for the A1 driving licence); 
Option 4:  Obligatory fitting of advanced brake systems (c ombined brake systems and/or anti-lock braking 
systems) on motorcycles conforming to the perfo rmance criteria for the A2 driving licence. 
Obligatory fitting of anti-lock brake systems on all other L3e motorcycles; 
Option 5:  Industry self-regulation. 
Table 9: Click on the ‘Annex’ links to display the full, detailed analysis of policy options 1 to 5  
Summary:  
Option 1, no change, does nothing about the unacceptable fact that every year many PTW riders die in road 
accidents, e.g. 5  520 PTW riders in 2008, and even many more of them get seriously injured or even 
disabled for the rest of their lives. 
Option 2, obligatory fitting of anti-lock brake systems on all PTWs (two-wheel mopeds and motorcycles), was 
found to be technically very advantageous as it is best way of preventing critical wheel lock. Wheel lock often 
leads to a longer stopping distance and may also cause the rider to fall because the vehicle becomes 
uncontrollable. Also, riders will have c onfidence that wheel lock will not occur with anti-lock brakes fitted so 
that they actually dare to brake.  A number of studies have reported t hat no traces are often found on the 
road after accidents, indicating that the rider did not attempt to brake at all. However, this option has a 
number of disadvantages, mainly economic. Cost-effectivene ss is controversial and difficult to estimate, as it 
is dependent on a large number of fact ors. Overall, the literat ure points to a solid pos itive cost-effectiveness, 
and the high cost–benefit ratios (around 3 as the best av erage) noted in the TRL report seem to confirm this 
assumption. 
Options 3 and 4 are basically attempts to decrease t he cost for industry without compromising too much the 
safety benefits offered by anti-lock brake systems. The major advantages of option 3 are the high estimated 
fatality and injury reductions. Additionally, the high cost–benefit ratios are very attractive. Major negative impacts of this option are the possi ble price increases for consumers a nd possible non-availability of anti-
lock brake system technology to SME manufacturers. The latter is because an SME might not be able to 
take on the minimum volumes demanded by bigger autom otive suppliers or alternatively could be confronted 
with high development costs, as suppliers might not be able to justify investment  in tooling to produce ABS 
components owing to the SME’s small series production.  The major advantage of option 4 is that it employs 
the same categorisation of low- and high-performance motorcycles as used in the Driving Licence Directive 
(matching vehicle type-approval and driving licence cr iteria, hence ensuring coherence). This makes a clear 
distinction between non-powerful and powerful PTWs, thus indicating which type of vehicle must to be fitted 
with an anti-lock brake system and which can be fitt ed with either an anti-lock brake system, a combined 
brake system or both, depending on what manufacturers deem to be cost-effective and to offer the best level 
of safety for their customers. On the other hand, t he technical effectiveness of  both options 3 and 4 is 
expected to be lower than for option 2, as the Commission considers that combined brake systems can only help to reduce critical wheel lock up to a certain le vel, not eliminate it altogether, resulting in a smaller 
reduction in fatalities and injuries. The economic impa ct of option 3 and 4 is estimated as being in the same 
order of magnitude. For option 4, no co st-benefit estimate was in fact calc ulated by the consultant as this 
scenario was added at a late stage. Owing to the simila rity with option 3, the same cost range and benefit 
data were assumed for both options, based on the calculations for option 3. 
Option 5 was unfortunately referred to in the policy option assessment report as ‘no change’ (option A). It is 
obvious and appreciated by the Commi ssion that the industry is seriously attempting to address the high 
level of fatalities and serious injuries by voluntarily  offering self-regulation. Consequently, the industry is 
committed to offering , by 2015, 75
 % of street motorcycle models with an advanced braking system as an 
option or fitted as standard. One question remains: doe s this option go far enough to meet the objective of 
significantly reducing fatalities and casualties among PTW riders involved in road accidents ? 
Despite the commitment by manufacturers since 2004 to  introduce advanced brake systems as an option on 
powered two-wheelers, the road fatality statistics have not fallen, but remain more or less the same or have 
even slightly increased (up to 2008). T he TRL report estimates that only 23  % of the fleet will be equipped 
with anti-lock and/or combined brake systems by 2020 under the current self -regulation. However, this would 
nonetheless save 1436 lives with a corresponding saving of €  1. 2 billion and reduce injuri es with savings in 
the order of €  1.1 billion as best estimates. 
According to the TRL report (Table 12, p. 26), actual  take-up by customers of antilock brake systems, 
combined brake systems or both will grow from 20  % in 2011 to 41  % by 2020. Effectively, this means that 
9 % of the PTW fleet in 2011 will be equipped with su ch systems. This will grow to an estimated 23  % of the 
vehicle fleet by 2020. The advantages of industry self-regulation are signi ficantly lower burdens to industry 
 
EN 30   EN and less complex and prescriptive legislation. On the ot her hand, a major negative impact is a significantly 
lower reduction in fatalities and injuries. Although vol untary self-regulation has already applied since 2004 
and is on schedule (35  % of all PTWs offered have advanced brake systems), the fatality statistics have so 
far not significantly decreased and remain st atic or are even slightly increasing.  
5.3.2. Anti-tampering measures  
Annex XII, Ch. 2  Option 1:  No policy change; 
Option 2:  Repeal Chapter 7 of Directive 97/24/EEC, curr ently partly obsolete anti-tampering measures; 
Option 3:  New measures on anti-tampering. 
Table 10: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3  
Summary:  
Option 1 suffers from an extensive list of disadvantag es, as the baseline safety and environmental concerns 
would not be addressed. One might c onsider a benefit to be the technica l know-how that amateur vehicle 
tuners can acquire from "cr eative" engine tuning activities, which is the starting point and motivation for many 
engineering careers. Another controversial benefit is the fact that the tuning indust ry could continue to make 
revenue and employ people. However, these benefits may not go at the co st of safety and/or environmental 
protection. 
Option 2 has the same extensive list of disadvantages, but in this case  the effects are several orders of 
magnitude worse. One additional advantage for vehicl e manufacturers is a lower burden, as one type-
approval less would be required to obtain whole-vehicle type-approval. 
Finally, while option 3 would not completely eliminat e the disadvantages of opt ions 1 and 2, it would 
eliminate costly obsolete measures  and align measures with the su bstantial progress in technology 
development. Only a qualitative assessment was carried out  owing to a lack of economic information. All 
vehicles with electronic engine management system s, for which the current anti-tampering measures 
enforced are ineffective, will be co vered by the new Regulation in a ddition to the mopeds and light 
motorcycles currently included. 
5.3.3. 74kW power limitation for motorcycles 
Annex XII, Ch. 3  Option 1:  No policy change; 
Option 2: Repeal the option given to Member States to limit power to 74kW; 
Option 3:  Set a harmonised limit of 74kW; 
Option 4:  Use alternative limitation criteria. 
Table 11: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3  
Summary:  
In the literature, no clear evidence was found to suggest that limiting the power of a motorcycle to 74kW has 
a positive impact on the number of road accidents involv ing motorcycles. Other factors such as rider attitude, 
experience and the issues listed under the previous  chapters have a greater in fluence on accident risk. 
Option 1 suffers from the major disadvantage that manufac turers have to develop special products to meet 
the power limitation requirement, currently imposed by  only one Member State. These products have to be 
separately distributed as well, so development and distribution costs are estimated to be higher. 
Option 2 offers the optimum economic benefits to manufacturers as compliance costs would be reduced and 
the concerns associated with option 1 would be avoided. The cost-effectiven ess of option 3 is doubtful, as 
already indicated. The advantage of option 4 is that alternative, more cost-e ffective limitation criteria could be 
used. The drawback, however, is that no data are current ly available to determine possible alternative criteria 
such as power-to-mass ratio. 
5.4. Improved categorisation of L-category vehicles 
5.4.1. Recategorise electrically assisted cycles (c urrently outside the scope of the legal framework), 
tricycles (category L5e) and quadricycles (categories L6e and L7e) 
Annex XIII, Ch. 1  Option 1:  No policy change; 
Option 2: Exclude quadricycles and electrical cycles from the Regulation;  
Option 3:  Return to the original spirit of the legislation for mini-cars; 
Option 4:  Improve the legislation by adding new require ments for mini-cars based on car requirements; 
Option 5:  Refine vehicle categories by introducing ne w subcategories in L1e, L5e, L6e and L7e. Add new / 
revised requirements for these subcategories. 
Table 12: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 to 5  
Summary:  
The disadvantage of option 1 is the volume of the curr ent legal text, which has proliferated over the years 
and contains inappropriate or obsolete measures or no measures at all (e.g. obligatory fitting of an 
elementary safety feature such as a differential on a four-wheel powered vehicle), where such measures are 
 
EN 31   EN considered essential for environmental protection and safety. One of the root causes of this problem is 
inappropriate or non-existent classification criteria. 
The disadvantage of option 2 is even greater confus ion among stakeholders owing to the absence of 
appropriate rules and the need for L1e, L5e L6e and L7e vehi cle manufacturers to have their vehicles type-
approved at national level. Noise, emission and fuel co nsumption levels may also increase. To a lesser 
extent, these negative impacts are also applicable to option 3.  
As Option 4 would drive up costs for mini-car producers to very high levels, this industry, which is completely 
composed of SMEs (the market leader with the hi ghest sales volume employs about 200 people), would not 
be able to survive if subjected to such a high burden on the short to mid term. 
Option 5 deals with the concerns but has the major di sadvantage of potentially signi ficant compliance costs. 
Unfortunately, no economic data are available for any of these options, although the results of the 
quantitative analysis, weighing the pros and cons, point to option 5 as the optimum solution. In particular, the 
better coherence within L-category legislation and also wi th the legislation applicable to other means of road 
transport is a clear advantage. Other positive impacts are increased clarity for industry and stakeholders and 
the possibility for the legislator to be able to develop more effective measures in terms of environmental 
protection and safety. 
5.4.2. Specific requirement s for category L7e vehicles 
Annex XIII, Ch. 2  Option 1:  No policy change; 
Option 2 : Exclude off-road quads (ATVs) from the Regulation and add new requirements on safety and 
emissions for on-road quadricycles  (on-road quads and mini-cars); 
Option 3:  Keep the existing L7e category and add new requirements on safety for all quadricycles; 
Option 4:  Create new subcategories within L7e with specific  requirements for off- and on-road quadricycles. 
Table 13: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 to 4 
Summary:  
Option 1 is disadvantageous from the safety, environm ental, economic and societal perspectives, as three 
completely different vehicle types (mini-cars, on-road quads and off-road quads), are allocated to the same 
category L7e even though their only common characteristic is  that they have four whee ls. It is not considered 
possible to address the individual concerns associated wi th each specific vehicle type with appropriate and 
cost-effective measures. No positive impacts could be determined for this scenario.  
Option 2 offers the advantage that the environmental and safety concerns of on-road quads and mini-cars 
can be effectively addressed by specif ic measures. In addition, if ATVs are excluded, they will fall 
automatically under the Machinery Directive with regard to safety and under the Non-Road Mobile Machinery 
Directive as regards environmental re quirements. This is already partly the case today, so for ATVs this 
would be the most cost-effective option. As the requirem ents for ATVs are similar to those for other ‘non-road 
mobile machinery’, manufacturers would benefit from lo wer compliance costs and could pass this on in the 
form of lower consumer prices. In particular, SMEs in  the agricultural and forestry sector, which purchase 
ATVs as a cheap alternative to tractors, could benefit from such lower prices. 
Option 3 is advantageous in that it offers the possibili ty to revise or develop more appropriate environmental 
and safety measures for all quadricycles, which may addr ess the concerns identified in this field. The 
disadvantage is that three different vehicle sub-types would still be assi gned to a single subcategory, which 
makes it difficult to develop specific measures for a sp ecific vehicle type, e.g. to  separate off-road, on-road 
quads and mini-cars. 
Finally, option 4 offers the highest flexibility to reca tegorise the three vehicle types. It also provides the 
possibility to further split up quads into subcategorie s for on-road quads and mini-cars. Both the latter types 
again might need different measures as they are designed for different uses. On-road quads would need to 
offer the same level of safety and environmental performance as other road transport vehicles. 
A special subcategory for ‘on-road quads’ would increas e clarity for stakeholders as to which requirements 
must be met for this vehicle to be considered safe and environmentally acceptable for use on public, paved 
roads. The disadvantages of option 4 could be that consumer prices fo r ‘on-road’ quads might increase and 
manufacturers might have to meet more requirement s before such vehicles could be type-approved and 
allowed to travel on public roads. Further analysis of this scenario indicates that it is unfeasible to find 
enough characteristic design criteria to separate on -road quads sufficiently well from off-road quads. For 
example, on-road quads could at first be type-approved as off-road quads and then retrofitted with a kit to 
make them roadworthy, but not necessarily compliant with EU safety and emission standards. Such vehicles 
would benefit from the advantages of  a virtual off-road quad subcategory,  but would circumvent the safety 
and environmental measures developed specifically fo r on-road quads. In addition, only on-road vehicles 
traditionally fall under the scope of type-approval legislat ion, but this concern could possibly be addressed as 
 
EN 32   EN for agricultural vehicles, which are also designed pred ominantly for off-road use, but which are still type-
approved. 
5.4.3. Specific requirements for gaseous altern ative fuels and other non-traditional propulsions 
Annex XIII, Ch. 3  Option 1:  No policy change; 
Option 2 : Legislation at EU level through a more refined vehicl e categorisation with specific measures for the 
different vehicles and propulsion technologies. 
Table 14: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 and 2  
Summary:  
Option 1 suffers from the common disadvantages for manufac turers that want to market their products EU-
wide: potentially different national app roval requirements that need to be me t. There is a risk that divergent 
requirements may lead to trade barriers. There may be inappropriate environmental and safety measures, or 
no measures at all, reducing the envir onmental benefit inherently offered by these types of propulsions in 
comparison to using ‘conventional’ diesel and gasoline fuels. 
Option 2 provides the flexibility to develop measures  to address fuel-specific environmental and safety 
concerns, which is an advantage. The level of innovat ion in safety and environmental technology may be 
stimulated by introducing specific measures for gaseous alternative fuels and other non-traditional 
propulsions. The disadvantages are th at the cost of compliance for manufacturers may be higher initially and 
that in general consumers perceive gaseous fuels to be dangerous and difficult to handle. There could be an 
economic benefit for manufacturers if the measures  were designed carefully, international standards 
(UNECE) were used as much as possible, and this type of technology were to be subsidised at Member 
State level, in other words to pr ovide incentives to manufacturers and consumers to make alternative 
propulsion concepts more attractive. This could allow manufacturers to produce vehicles for the whole EU 
market and subsequently for global mark ets, which could cut the cost of these technologies in the long run 
owing to economies of scale. Once it is demonstrat ed to consumers that the advantages of alternative 
propulsions significantly outwe igh the disadvantages, demand for such products may rise. 
5.4.4. Proposal to combine the results of the prefe rred options for improved categorisation of L-category 
vehicles 
Annex XVII, Ch. 4   Revise the categorisation for L-category vehicles by comb ining the preferred options of sections 5.4.1 to 5.4.3.  
Table 15: Click on ‘Annex’ to see the detailed proposal to recategorise L-category vehicles 
6. C OMPARISON OF OPTIONS AND CONCLUSIONS  
6.1. Simplification of legislation 
Annex XIV  Option 1:  No policy change; 
Option 2:  Repeal current directives and replace with a minimum number of regulations; 
Option 3 : Recast the current Framework Directive 2002/24/EC. 
Table 16: Click on ‘Annex’ for the full, detailed comparison of policy options 1, 2 and 3  
Summary:  
In terms of efficiency, options 2 and 3 perform equally well, especially because both call for the current legal 
text to be replaced by technical equivalent or more appropriate UNECE regulations as far as possible, which 
should simplify the Regulation and in particular the associated technical implementing measures. For the new Regulation on approval and market surveillance of L- category vehicles, only the intention to use UNECE 
regulations can be indicated. The subsequent delegated acts containing technical details, to be developed 
after adoption of the Regulation, will cl arify which specific text of the r epealed implementing directives can be 
replaced with UNECE regulations. 
Regarding efficiency, option 2 is better in terms of tran sposition and implementation costs and is expected to 
reduce the risk of delay in dealing with urgent matt ers or changes. As a result, the benefits of any new 
measures can be obtained more rapidly.  Option 2 is therefore preferred. 
6.2. Environmental measures 
6.2.1. New or revised environmental measures for the type-approval of new vehicles 
6.2.1.1. Revised lower emissions limits 
Annex XV, Ch. 1.1  Option 1:  No policy change; 
Option 2:  New emission limits for L1e mopeds: a cold-start R47 test cycle and a 30  % weighting factor for cold 
start are proposed (scenario 1 from LAT report). No change in limits for other L-category vehicles; 
Option 3 : Motorcycle industry proposal (scenario 2 from LAT report); 
Option 4:  New measures based on best availabl e technology for L-category vehicl es sold today in the market 
(scenario 3 from LAT report); 
Option 5 : New limits for all L-category vehicles equivalent in  absolute terms to Euro5 M1 light-duty vehicles 
(scenario 4 from LAT report). 
Table 17: Click on ‘Annex’ to display a detailed comparison of policy options 1 to 5  
 
EN 33   EN Summary:  
The main criteria for comparing between the 5 different options over the short to medium term are 
implementation time and cost-effectiveness. Option 3 sc ores best for these aspects. However, over the long 
term, the disproportionately high HC, CO and PM emissions must be addressed, and this can only be 
achieved with option 5. Even option 5 will not be sufficient to bring emis sions into line with the very low total 
vehicle mileage accumulated with  L-category vehicles (2 – 3  % of total road vehicle mileage), but it is 
considered to be the most that can be done by the L-cate gory vehicle industry to ensure clean vehicles over 
the long term. Therefore, the optimum solution will be a combination of a slightly modified option 3 (separate 
limits, which means no combined HC & NOx limits for all L-category vehicles) over the short to medium term (2013 – 2016 timeframe) and option 5 for the long term (2019–2020) depending on the results of an 
additional environmental effect study to be carried out by  2016. This strategy should provide industry with a 
longer lead-time and therefore help to mitigate the burden and the long-term effects of the current financial 
crisis on the industry. While option 3 is based on the self -regulation proposal put fo rward by the industry, the 
legal instrument used would be the new Regulation on approval and market surveillance of L-category 
vehicles, which will make these lim its obligatory for type-approval. 
Although PM will not be limited, the expectation is that the THC limit will automatically lead to a reduction in 
VOC, especially taking into account the particular composition and volatility of the particulates emitted by L-
category vehicles in comparison to e.g.  those emitted by diesel passenger cars. 
6.2.1.2. Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicles  
Annex XV, Ch. 1.2  Option 1:  No policy change; 
Option 2:  Use of a revised World-wide harmonised Motorcyc le emissions Testing Cycle (WMTC) for all L-
category vehicles. 
Table 18: Click on ‘Annex’ to display the detailed comparison of policy options 1 and 2  
Summary:  
The advantages of using the stage-two WMTC only fo r L3e category vehicles over the short term and a 
revised WMTC other L-category vehicles over the medi um to long term outweigh the disadvantages by far. 
Therefore, option 2 is the pr eferred solution for the long term. In order to provide industry with sufficient lead-
time a transition towards the use of WMTC for all L-category vehicles is proposed as summarised in Annex 
XV, Ch. 1.2, Table  2. Certain L-category vehicles (L1B, L2e,  L5e, L6e, and L7e) do not yet come under 
UNECE global technical regulation 2 (WMTC). The Co mmission will need to launch an initiative within 
UNECE to include these subcategories in the long term (2020). 
6.2.1.3. Type-approval requirements for CO 2 measurement and fuel consumption determination and 
reporting 
Annex XV, Ch. 1.3  Option 1:  No policy change; 
Option 2:  Type-approval requirements for CO 2 measurement and fuel c onsumption determination and 
reporting 
Table 19: Click on ‘Annex’ to display the detailed comparison of policy options 1 and 2 
Summary:  
The ratings for effectiveness, efficiency and coherence are overall positive to highly positive for option 2. 
Consumers need to have additional information presented in a standardised form for them to be able to compare the fuel efficiency of different vehicles wi thin the L-category and to be able to compare with 
alternative means of ro ad transport. This will allow them to purchase the most fuel-efficient vehicle or to 
choose the optimum transport alternat ive in terms of fuel cost and will make them aware of the green house 
gas emissions per kilometre travelled. The motorcycle riders’ association, FEMA, for example welcomes the 
introduction of a compulsory labellin g scheme, for which the data obtai ned through option 2 will be used as 
input. The preferred solution is therefor e option 2. As L-category vehicles only contribute little to the overall 
CO
2 emissions of road transport as a whole, an explicit limit value was not deemed necessary. In fact, if the 
pollutant concerns of PTWs were ad dressed (currently thei r emissions are dispropor tionately high compared 
to all road transport based on mileage travelled), it would be advantageous if heavy, big passenger cars 
were to be substituted by light, flex ible L-category vehicles. This may help to bring down the overall high fuel 
consumption of road vehicles and significantly redu ce emissions of green house gas emissions like CO 2. 
6.2.1.4. Evaporative em issions test and limit 
Annex XV, Ch. 1.4  Option 1:  No policy change; 
Option 2:  Replacement of all new carburetted models with fuel-injected models; 
Option 3:  Evaporative emissions test and limit ensuring evapor ative emission control fo r L-category vehicles; 
Table 20: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3  
Summary:  
 
EN 34   EN As the high hydrocarbon emissions of L-category vehicl es can only be influenced to a relatively small extent 
by type-approval measures addressing evaporative emis sions, an effective low-co st measure that can be 
implemented quickly is preferable. The advantages of option 2 will become automatically available if more 
stringent emission thresholds will need to be fulfille d and the highest part of the financial burden to the 
manufacturers will already be amortised by the nece ssary hardware changes under this policy option to 
introduce revised tailpipe emission limits. Option 3 is es timated to be the only cost-effective way of reducing 
evaporative emissions from L-ca tegory vehicles and is therefore the preferred option. 
6.2.1.5. Durability requirements 
Annex XV, Ch. 1.5  Option 1:  No policy change; 
Option 2:  (Scenario 2 from the LAT report): deterioration reduced to 10  % over useful life with linear 
extrapolation for higher mileages; 
Option 3 : (Scenario 2 from the LAT report): useful life increased by 60  %, i.e. equivalent to the increase for 
passenger cars upon moving from Euro 3 (80k km) to Euro 5 (160k km). 
Table 21: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3 
Summary:  
Option 1 was discarded as this makes the introduction of revised emission limits ineffective. Option 3 is 
regarded as very expensive and may inhibit manufacturers from introducing new products on the market. The introduction of durability requirements for L-category  vehicles in option 2 alr eady addresses the majority 
of the concerns identified at an acceptable cost to  industry, so is therefore the preferred solution. 
6.2.2. New measures to control vehicle emissions over vehicle life 
6.2.2.1. In-use conformity  (IUC) testing and limits. 
Annex XV, Ch. 2.1  Option 1:  No policy change; 
Option 2: (Scenario 1 from LAT report): IUC procedure mandatory for all Euro 3 motorcycles. 
Table 22: Click on ‘Annex’ to display the detailed comparison of policy options 1 and 2  
Summary:  
Owing to the many disadvantages, including impractic ability and only moderate cost-effectiveness, IUC was 
discarded. However, this is one of the assumptions wh ich will be re-examined in the environmental effect 
study referred to in chapter 6.2.1.1. 
6.2.2.2. On-board diagnostic (OBD) sy stems and access to repair information 
Annex XV, Ch. 2.2  Option 1:  No policy change; 
Option 2:  (Scenario 1 in LAT report) application of OBD sy stems using a similar technology as for passenger 
cars (EOBD), including catalyst efficiency and mi sfire monitoring for all L-category vehicles. 
Provision for access to repair and maint enance information, as for passenger cars; 
Option 3:  (Scenario 2 in LAT report) use of best avail able technology (BAT): mi nor malfunction monitoring 
(e.g. circuit integrity check) (OBD stage 1) fo r all L-category vehicles, no catalyst efficiency 
monitoring. Provision for access to repair and maintenance information as for passenger cars. 
Table 23: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3  
Summary:  
A distortion of competition arises in the internal EU market, as independent repairers are not able to retrieve 
standardised diagnostic on-board information from vehicles and are therefore not able to repair failures as 
effectively and efficiently as contra ct dealers and repairers. In the repair cycle (diagnosis and analysis of 
problem, repair of smallest identifiable component or ordering of replacement parts and replacement of 
smallest exchangeable unit) the avail ability of harmonised diagnostic info rmation from the OBD system is 
essential for an independent dealer or even for a vehicle ow ner, to effectively and efficiently repair a vehicle. 
As option 3 is estimated to have a much better cost-effe ctiveness than option 2, this is the preferred option 
for the short term (2017). In addition, option 3 paves the way for a possible introduction of option 2 in the 
long term (2019), if proven cost effective in the environ mental effect study referre d to in chapter 6.2.1.1. 
6.3. Safety measures 
6.3.1. Obligatory fitting of  advanced brake systems 
Annex XVI, Ch. 1  
 
Annex XVI Ch. 1.1  
Annex XVI Ch. 1.2  
Annex XVI Ch. 1.3  
 
 Annex XVI Ch. 1.4
 
 
 Annex XVI Ch. 1.5
 Qualitative and quantitative analysis of policy optio ns for obligatory fitting of advanced brake systems 
Option 1:  No policy change; 
Option 2:  Anti-lock brake systems on all powered two-wheelers (PTWs); 
Option 3:  Anti-lock brake systems on PTWs with cylinder capacity >125cm3 and advanced brake systems 
(combined brake systems and/or anti-lock br ake systems) on motorcycles with 50 cm3 < cylinder 
capacity ≤ 125 cm3 (NB 125 cm3 relates to the vehicle performance criteria for the A1 driving 
licence); 
Option 4:  Obligatory fitting of advanced brake systems (c ombined brake systems and/or anti-lock braking 
systems) on motorcycles conforming to the perfo rmance criteria for the A2 driving licence. 
Obligatory fitting of anti-lock brake systems on all other L3e motorcycles; 
Option 5:  Industry self-regulation. 
Table 24: Click on ‘Annex’ to display the detailed comparison of policy options 1 to 5  
 
EN 35   EN See also Annex XVI, Ch. 1.6  for an impact assessment of anti-lock brake system technology fitted to 
vehicles manufactured and type-approved by SMEs. 
 
EN 36   EN Summary:  
Recently, three retrospective studies44 were published, which were not in cluded in the literature study for the 
TRL report. The value of these studies is that the resu lts were based on an analysis of actual accident data, 
unlike in the majority of the liter ature assessed, which was predominan tly forward-looking. The Spanish 
study provided relevant statistics on motorcycle accident  fatalities, indicating that motorcycles with a higher 
engine displacement are overrepresented in fatal accide nts. The Swedish and US st udies confirmed the high 
cost-effectiveness of anti-lock brake systems, with estimates even higher than for most of the studies 
summarised in the TRL report. The estimates ranged from 11 to 17  % in the Swedish study. On the other 
hand, the 38  % cost-effectiveness found in the US study was not statistically relevant, although the results 
indicated that ‘there is considerable confidence that  anti-lock brake systems prevent fatal crashes among 
motorcyclists’. 
In terms of reducing fatalities and injuries, options 2, 3 and 4 are superior to options 1 and 5, which are 
therefore considered insufficient. In terms of cost-benefit  ratios, options 3 and 4 are considered to be similar, 
and are under the given assumptions slightly worse than option 2. Option 5 lags significantly behind options 
2, 3 and 4 in terms of saved lives and casualty preven tion. The fact that the fatality statistics have remained 
more or less the same in recent years, despite the self-regulation already ‘in force’ since 2004, seems to 
indicate that the number of vehicles equipped with advanc ed brake systems in the EU market is not yet high 
enough to result in the significant road fatality reduc tions necessary to meet the safety objectives.  
A concern with industry self-regulation is that offeri ng vehicles with advanced brake systems as an option 
does not automatically mean that the vehicles sold are actually equipped with these systems. The industry 
depends on the demand from customers and their actual purchase decisions. If customers choose to save 
money and do not opt for advanced brak e systems, even more in current ti mes of economic difficult times, 
only a small part of the fleet will actually be equipped wi th these systems. If the cu rrent trend continues, only 
23 % from the vehicle fleet are estimated to be equipped with anti-lock brake systems by 2020, as estimated 
in the TRL report, which is not regarded as su fficient to meet the safety objectives.  
It should also be pointed out that ACEM’s members are responsible for 90  % of the production of powered 
two-wheelers (PTWs) in Europe and up to 95  % of the market. This means that the remaining 10  % of 
vehicles produced by the 5  % of manufacturers not affiliated to AC EM are likely to continue producing 
vehicles not equipped with advanced brake systems, in or der to sell products as cheap as possible. A further 
problem for the EU is that some vehicles on the mark et do not seem to meet any  type-approval requirements 
relating to safety and the environment. This can only be addressed by better market surveillance, which is 
another priority for the European Commission, which will be addressed with this Regulation. The Commission appreciates the effort and good-will of the mo torcycle industry to offer PTWs with advanced 
braking systems, but consi ders, for the above reasons and in view of other aspects listed in the detailed 
analysis, that self-regulation as not sufficiently effective to achieve its ambitious safety goals. 
It is acknowledged that estimates of the cost of  advanced brake systems are controversial, as no 
independent information is available from e.g. EuroStat, which is why best estimated values for options 2, 3 
and 4 vary so widely. Chapter 3.5.1 in the TRL report (Table 11) gives best estimates of the price of 
advanced brake systems for option 5 at the poi nt of sale (anti-lock brake system: €
 539; combined brake 
system: €  150). In Table 14 of chapter 3.5.1, the best esti mated price for both anti-lock brake systems and 
combined brake systems was €  150 for option 2. Despite of the controversy of this assumption it is assumed 
that the high demand from manufacturers to their su ppliers for anti-lock brake systems and combined brake 
systems if they are made obligatory will result in si milar economies of scale for options 3 and 4 and hence 
lower prices than for the other options.  
Given the difference in complexity between anti-lock brake systems and combined brake systems, it seems 
obvious that the best estimated co st for combined brake systems will be lower than for anti-lock brake 
systems. It is therefore assumed that it is cheaper fo r a manufacturer to equip a PTW with a combined brake 
system than with an anti-lock brake system. For cheape r, less powerful PTWs in particular, the consumer 
price may be significantly increased if a more expensive anti-lock brake system is fitted instead of a cheaper 
combined brake system. Therefore, from a purely cost  perspective, options 3 and 4 offer more advantages 
for the manufacturer and consumer than option 2. T he best estimated price for combined brake systems 
(€ 150) is considered to be on the conservative side. 
                                                 
44 1) Swedish Road Administration: The effectiveness of anti- lock brake systems on motorcycle s reducing real-life crashes and 
injuries — 29 June 2009. 2) pp. 41 – 43: 
http://www.dgt.es/portal/es/seguridad_vial/est udios_informes/estudios_informes084.htm.  3) US Insurance Institute for 
Highway Safety: Effectiveness of Antilock Braking Systems in Reducing Fatal Motorcycle Crashes — October 2008. 
 
EN 37   EN Option 3 and to a lesser degree option 4 seem to offer the best compromise between significant fatality and 
injury reductions, on the one hand and an estimated mode rate increase in cost to the end-consumer in the 
low-price PTW segment (mopeds and light motorcycles) on the other. In particular, linking the driving licence 
classification criteria to the type-appro val criteria will also improve the co herence of EU legislation. For this 
reason, the preferred options are 3 or 4. 
6.3.2. Anti-tampering measures  
Annex XVI, Ch. 2  Option 1:  No policy change; 
Option 2:  Repeal Chapter 7 of Directive 97/24/EEC, currently obsolete anti-tampering measures; 
Option 3:  New measures on anti-tampering. 
Table 25: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3  
Summary:  
Although no explicit cost information wa s available, option 1 is considered  the no-cost option. On the other 
hand, no identified concern would be addressed. Option 2 is even worse and is considered to be a step back in time (before 1996). It would lead to a lot of undesira ble amateur tuning, resulti ng in high vehicle speeds 
and unsafe and environmentally unfriendly vehicles. Opti on 3 is probably the most expensive of the threes, 
but has the potential to partly address the adverse effects of tampering and associated safety and 
environmental concerns. The prefer red option is therefore option 3. 
6.3.3. 74 kW power limitation for motorcycles 
Annex XVI, Ch. 3  Option 1:  No policy change; 
Option 2: Repeal the option given to Member States to limit power to 74kW; 
Option 3:  Set a harmonised limit of 74kW; 
Option 4 : Use alternative limitation criteria. 
Table 26: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3  
Summary:  
The anticipated societal impact of all the options is neut ral. Option 2 is expected to have a positive economic 
impact. Both options 3 and 4 are likely to have a negati ve economic impact, but option 4 has the potential for 
a larger positive environmental impact. However, the magnitude of the environmental impacts is currently 
uncertain. Owing to the lower cost for manufacturers an d the availability of more effective safety measures, 
such as the introduction of anti-lock brake systems, option 2 is the preferred option. 
6.4. Improved categorisation of L-category vehicles 
6.4.1. Recategorise electrically assisted cycles (c urrently outside the scope of the legal framework), 
tricycles (L5e) and quadricycles (categories L6e and L7e) 
Annex XVII, Ch. 1  Option 1:  No policy change; 
Option 2: Exclude quadricycles and electrical cycles  and tricycles from the Regulation;  
Option 3:  Return to the original spirit of the legislation for mini-cars; 
Option 4:  Improve the legislation by adding new requirem ents for mini cars based on car requirements; 
Option 5:  Refine vehicle categories by introducing new subcategories in L1e, L5e, L6e and L7e. Add new / 
revised requirements for these subcategories. 
Table 27: Click on ‘Annex’ to display the detailed comparison of policy options 1 to 5  
Summary:  
Options 1 to 3 do not address the root  problems. Option 4 can resolve these concerns for mini-cars, but still 
leaves a confusing set of rules for the L1e, L5e and L7e subcategories. The best solution for effective 
environmental protection and safety is correct classification, as propose d in option 5. Its disadvantage may 
be higher compliance costs for indu stry initially, but this would depend on how carefully the current 
classification is overhauled. New measures may emer ge once appropriate subcat egories are defined, e.g. 
there are currently no specific measures for the electric al safety of electric vehi cles. UNECE regulation No. 
100 on the safety of electrical vehicles could apply to such vehicles in future, but should not cover traditional 
vehicles equipped solely with internal combustion engi nes. The preferred solution after weighing the pros 
and cons is therefore option 5. 
 
EN 38   EN 6.4.2. Specific requirement s for category L7e vehicles 
Annex XVII, Ch. 2  Option 1:  No policy change; 
Option 2 : Exclude off-road quads (ATVs) from the Regulation and add new requirements on safety and 
emissions for on-road quadricycles  (on-road quads and mini-cars); 
Option 3:  Keep the existing L7e category and add new requirements on safety for all quadricycles; 
Option 4:  Create new subcategories within L7e with specific  requirements for off-and on-road quadricycles. 
Table 28: Click on ‘Annex’ to display the detailed analysis of policy options 1 to 4  
Summary:  
In analysing the pros and cons of the four different  policy options, the advantage of flexibility to develop 
specific requirements addressing the specific concerns of different vehicle types became obvious. Initially, 
therefore, this led to a high preference for option 4,  with a subcategory L7Be for ATVs, a subcategory L7Ce 
for mini-cars and a subcategory L7Ae for all other quadric ycles classified as ‘on-road’ quads. The initial plan 
was also not to register off-road quads (ATVs) or equi p these vehicles with a special registration plate and 
put a note in its vehicle papers that this vehicle type may only travel a s hort distance on public, hard-surfaced 
roads. This would have helped the enforcement authorities,  as such vehicles could then be easily identified 
as not permitted in cities and far away from off-road areas. 
On the other hand, not registering ATVs would have  lead to identification concerns for enforcement 
authorities if a vehicle could not be stopped. Special registration plate requirements are solely individual 
Member State business and can therefore not be propos ed by the Commission as EU wide legislation.  
Unfortunately option 4 had to be discarded owing to the fa ct that off-road vehicles do not legally fall under 
the scope of the type-approval legisl ation for L-category vehicles. This legislation is only supposed to cover 
the type-approval of vehicles used on public roads. In addition, it was not possible to identify a sufficient 
number of critical vehicle characteristics able to di stinguish sufficiently well between an off-road quad (ATV) 
and an on-road quad, as between e.g. a passenger car and a class G (off-road) vehicle. The design criteria 
initially selected could too easily be circumvented by  retrofitting a cheap kit to adapt the original type-
approved off-road vehicle to make it fit to drive on public roads. This would not  have meant that such a 
retrofitted vehicle would then also comply with the specific safety and environmental measures specially 
designed for subcategory L7A. So, from a practical poin t of view as well, this concept had to be abandoned. 
With options 1 and 3, either the problems identified are not addressed or the manufacturer of one vehicle 
type must comply with requirements developed to addre ss concerns with the other vehicle types. Given this 
complex set of advantages and disadvantages, opt ion 2 was chosen as the only feasible option. 
Furthermore, it still provides the be st way to address the environmental and safety  concerns of on-road 
quads and mini-cars in particular. ATVs will conseq uently no longer come under the L-category vehicle 
legislation and will be covered by the Machinery Dire ctive 2006/42/EC with regard to safety aspects. ATVs 
will also need to comply with the Non-Road Mobile Machinery Directive 97/68/EC as amended by Directive 
2002/88/EC as regards environmental requirements. T he coherence of option 2 was considered to be better 
than for options 1, 3 and 4, as e.g. off-road motorc ycles are also not covered by the L-category vehicle 
legislation and are therefore also classified as machines. Circumventing the stricter on-road quad 
requirements for retrofitted ATVs cannot unfortunate ly be completely prevented with option 2 at European 
level, so additional national rules will be needed to prevent this. 
6.4.3. Specific requirements for gaseous altern ative fuels and other non-traditional propulsions 
Annex XVII, Ch. 3  Option 1:  No policy change; 
Option 2 : Legislation at EU level through a more refined vehicl e categorisation with specific measures for the 
different vehicles and propulsion technologies. 
Table 29: Click on ‘Annex’ to display the detailed comparison of policy options 1 and 2  
Summary:  
Gaseous fuels are in general perceived to be dangerous by consumers. To use thes e types of fuels on small 
vehicles such as PTWs, with very limited space avail able to e.g. incorporate a fuel tank, may sound exotic, 
but a small number of such vehicles are already nati onally approved, so it is physically possible. It may 
become more attractive to manufacturers to develop an d market these vehicles on a larger scale if such 
vehicles can be type-approved and sold on the whole EU market. By complying with appropriate, uniform 
international safety requirements, th ese vehicles will be as safe as or safer than vehicles propelled with 
conventional fuels. This will hopefully  contribute to an improved safety  perception among consumers, and 
demand for these vehicles may grow, especially because e.g. LPG, CNG or electricity are rather cheap in 
comparison to conventional fuels. 
Providing the possibility to type-approve  a vehicle propelled by alternativ e gaseous fuels or  any other shape 
of form of alternative propulsions may make it attracti ve for consumers in the Member States to drive such 
vehicles and may encourage manufacturers to spend more on environmental technology development, thus 
 
EN 39   EN increasing the pace of innovation in environmental technol ogy. In particular, SMEs would benefit from this 
increased focus on niche market technologies. These ar e the reasons why option 2 is the preferred option. 
Despite this preference for including gaseous fuels wi thin the new Regulation, hydrogen would for the time 
being remain excluded. There are many development s in hydrogen technology fo r light-duty vehicles 
(passenger cars), and EU legislation is being developed fo r four-wheel vehicles. In order to learn and benefit 
from this legislative development, more time is ne eded before drafting generic legal requirements for L-
category vehicles propelled with hy drogen. Rather technologi cal developments of this type of propulsion and 
associated requests to type-approv e vehicles propelled with hydrogen will be handled on a case-by-case 
basis. 
6.5. Overview of preferred options, detailed analysis and comparison with other options 
Objective Preferred policy option(s) Link to detailed 
analysis of preferred 
policy option  Link to detailed 
comparison of 
policy options  
Simplification 
of existing EU legislation Option  (2) Repeal current directiv es and replace with a 
minimum number of regulations  Annex X
 Annex XIV  
Revised lower emissions limits : 
Option (3 ) motorcycle industry (ACEM) proposal for the 
short to mid-term and Option (5) Equivalent Euro 5 
passenger car limits for the long term  Annex XI Ch. 1.2 Opt. 3  
AND 
Annex XI Ch. 1.2 Opt. 5  
 Annex XV, Ch. 1.1  
Emission laboratory test cycle:  
Option (2) Use of a revised World-wide Motorcycle 
emissions Testing Cycle (WMTC) for all L-category vehicles  Annex XI, Ch. 1.4  Annex XV, Ch. 1.2  Environmental 
measures: 
new or 
revised 
measures for 
the type-
approval of 
new vehicles Type-approval requirement for CO 2 measurement and 
fuel consumption determination and reporting: Option 2:  Actual introduction of type-approval requirements 
for CO
2 measurement and fuel consumption determination 
and reporting. Annex XI, Ch. 1.5  Annex XV, Ch. 1.3  
Evaporative emissions test and limit:  
Option (3) Evaporative emissions test and limit ensuring 
evaporative emission control for L-category vehicles.  Annex XI, Ch. 1.6  Annex XV, Ch. 1.4  
Durability requirements:  
Option (2) Deterioration reduced to 10  % over useful life and 
linear extrapolation for higher mileages  Annex XI, Ch. 1.7  Annex XV, Ch. 1.5  
In-use conformity (IUC) testing and limits:  
Option (1) No change  Annex XI, Ch. 2.1  Annex XV, Ch. 2.1  Environmental 
measures: 
New 
measures to 
control vehicle 
emissions 
over vehicle 
life. On-board diagnostic (OBD) systems and access to 
repair information:  
Option (3) Use of best available te chnology (BAT): minor 
malfunction monitoring (e.g. circ uit integrity check) (OBD 
stage 1) for all L-category vehicles, no catalyst efficiency of 
misfire monitoring. Provision of access to repair and maintenance information, as for passenger cars.  Annex XI, Ch. 2.2 Opt. 3
 Annex XV, Ch. 2.2  
Obligatory fitting of advanced brake systems:  
Option (3) Anti-lock brake systems on PTWs with cylinder 
capacity >125 cm3 and advanced brake systems (combined 
brake systems and/or anti-lock brake systems) on motorcycles with 50 cm
3 < cylinder capacity ≤ 125 cm3; (NB 
125 cm3 relates to the performance criteria of PTWs that can 
be driven with an A1 driving licence) 
OR 
Option (4) Obligatory fitting of advanced brake systems 
(combined brake systems and/or anti-lock braking systems) 
on motorcycles that conform to the performance criteria for the A2 driving licence. Obligat ory fitting of anti-lock brake 
systems on all other L3e motorcycles;  Annex XII Ch. 1.3
 
OR 
Annex XII Ch. 1.4  
 Annex XVI Ch. 1.3  
OR 
Annex XVI Ch. 1.4  
 
Anti-tampering measures:   
Option (3)  New measures on anti-tampering.  Annex XII, Ch. 2.2 Opt.3  Annex XVI, Ch. 2  Safety 
measures  
74kW power limitation for motorcycles:  
Option (2) Repeal the option given to Member States to limit 
power to 74kW;  Annex XII, Ch. 3  Annex XVI, Ch. 3  
 
EN 40   EN  
Recategorise vehicle types such as electric cycles, 
motorcycles (L3e), tricycles (L5e) and quadricycles (categories L6e and L7e):  
Option (5) Refine vehicle categories by introducing new sub-
categories in L1e, L3e, L5e, L6e, and L7e. Add new/revised requirements for these sub-categories. 
 Annex XIII, Ch. 1
 Annex XVII, Ch. 1  
Specific requirements for category L7e vehicles:  
Option (2) Exclude off-road quads (ATVs) from the 
Regulation and add new requirements on safety and emissions for on-road quadricy cles (on-road quads and mini-
cars);  Annex XIII, Ch. 2
 Annex XVII, Ch. 2  Improved 
categorisation 
of L-category 
vehicles 
Specific requirements for gaseous alternative fuels and 
other non-traditional propulsions:  
Option (2) Legislation at EU level through a more refined 
vehicle categorisation with specif ic measures for the different 
vehicles and propul sion technologies.  Annex XIII, Ch. 3  Annex XVII, Ch. 3  
 
Table 30: Summary table of preferred policy options with links to the detailed analysis, including all available quantitative a nd 
qualitative elements, and the detailed comparison with other policy options in terms of effectiveness, efficiency and 
coherence 
7. M ONITORING AND EVALUATION  
7.1. Simplification 
See Annex XVIII  for the complete list of recommended monito ring and evaluation parameters. These mainly 
concern the number of amendments and the require d time and cost of implementing these changes. 
7.2. Environmental measures 7.2.1. New or revised environmental measures for the type-approval of new vehicles 
7.2.1.1. Revised lower emissions limits 
Four years after first application, the new legal fr amework should be reviewed to determine whether the 
assumptions and modelled emissions conform to reality at that point in time. An increase in the number of mass-produced hybrid and electrical vehicles may have a positive impact on local pollutant reduction. In 
2016 – 2017 timeframe, the Commission should assess whether the additional pr omotion of electrified 
vehicles would effectively address t he disproportionately high emissions from L-category vehicles equipped 
with combustion engines. In addition, it should assess t he need to include off-cycle emission provisions in 
2020 for vehicles equipped with traditional propulsion technology. The long-term preferred option 5 will 
initially be between braces, and further monitoring and evaluation by both the Member States and the 
Commission will be required in the period up to 20 16, during which option 3 will be in force. 
 
EN 41   EN  
7.2.1.2. Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicle 
categories 
No specific monitoring and evaluation are deemed necessa ry, other than a comparison of actual pollutant 
emissions vs. predicted average emis sions based on test cycle measurements. The same applies to real-
world fuel consumption and the value determined in t he test cycle. For mopeds , a WMTC-based test cycle 
does not yet exist. A study will be star ted in 2011 and an initiative will be launched by the Co mmission within 
UNECE in the informal group for WMTC development in order to extend the scope of the WMTC to mopeds, 
so that the type-approval emission test bette r reflects real-world driving conditions. 
 
Figure 8: WMTC-based moped test cycle proposal (bottom) to replace the conventional R47 moped test cycle (top) 
7.2.1.3. Type-approval requirements for CO 2 measurement and fuel consumption determination and 
reporting 
For this policy option as well, real-world fuel consumption and CO 2 emissions should be monitored by both 
the Member States and the Commission and should be compared to the modelled results, which are based 
on the measurements obtained in the test cycle. For exam ple, three years after the introduction of a future 
energy efficiency labelling system co nsumers should be asked if this additional, standardised information has 
substantially influenced their purchasing decis ions towards more fuel-efficient vehicles. 
7.2.1.4. Evaporative em issions test and limit 
Actual and modelled HC emissions must be compared by  the Member States and the Commission, e.g. in 
2016 – 2017 timeframe, in order to judge if cost-eff ectiveness is as good as anticipated. Manufacturers 
should be asked to present the actual costs compared wi th the anticipated costs as presented in the various 
Motor Cycle Working Group meetings. 
7.2.1.5. Durability testing of ant i-pollution devices and aged vehicles 
The Member States and the Commission should run a stand-alone durability test programme and have a 
statistically relevant sample of aged vehicles from th e field, with a known maint enance history, by 2016. The 
actual test results of these vehi cles should be compared with aged emi ssion results from type-approval 
demonstration testing. This will indicate if the acce lerated-ageing methods used to demonstrate aged vehicle 
emissions are effective and if there is a need to increa se the durability mileage requirement as suggested by 
option 3. 
7.2.2. New measures to control vehicle emissions over vehicle life 
7.2.2.1. In-use conformity (IUC) testing and limits In the 2016 – 2017 timeframe, this policy option sh ould be reassessed by Member States and the 
Commission in the environmental assessment study to s ee if it should remain discarded or if the conditions 
or assumptions have changed to allow it to be recons idered. Experience gained with e.g. passenger-car IUC 
may provide a better evidence base than available today. 
7.2.2.2. On-board diagnostic (OBD) sy stems and access to repair information 
In the 2016 – 2017 timeframe an environmental impact st udy should be conducted by the Commission with 
input from the Member States to as sess the success of this option. T he environmental advantages should be 
more accurately quantified and independent repairer s should be asked if t heir current competitive 
disadvantage has changed for the better. 
 
EN 42   EN 7.3. Safety measures 
7.3.1. Obligatory fitting of  advanced brake systems 
See Annex XIX, Ch. 1 , for the complete list of recommended monitoring and evaluation parameters. These 
mainly relate to the number of powered two wheel rider casualties, non-fatal casualty data and the 
equipment fitted. Crucial data such as Anti-lock brake system or combined brake system costs and the effect 
of the large-scale fitment of systems on market pric e were lacking and should continue to be sought after 
one of the recommended policy options has been adopted. These should be used as input for a study to be 
conducted by the Commission four years after first application of the new Regulation (2017). 
7.3.2. Anti-tampering measures  
See Annex XIX, Ch. 2 , for the complete list of recommended monitoring and evaluation parameters. 
Recommendation from TUEV Nord report: spot checks on  two- and three-wheeled vehicles regi stered before 
and after 17 June 1999, reported in 2003; EU-wide accid ent research including the state of the vehicles 
involved; where carried out, inclusion of unauthorised m anipulations in periodical technical inspections; 
observing the market in electronic tuning devices; and pr actical research into the effect of electronic tuning 
on emissions, noise and maximum speed. There has si nce been significant technical progress with new 
power-train developments (electrical vehicles, hybrids), which could not be covered in the study at that time. 
The Commission should therefore have the study u pdated in 2011 to include the latest technology. 
7.3.3. 74kW power limitation for motorcycles 
See Annex XIX, Ch. 3 , for the complete list of recommended monitoring and evaluation parameters. Baseline 
data need to be determined, including: sales data with  respect to engine power/acceleration potential or 
whatever limitation measure is used; accident rates wi th respect to engine power/acceleration potential or 
whatever limitation measure is used; and emissions/ noise data with respect to engine power/acceleration 
potential or whatever limitation meas ure is used. These data must be moni tored by the Member States in 
relation to any other changes that could influence a ccident numbers, emissions or noise, for example anti-
tampering measures, etc. 
7.4. Improved categorisation of L-category vehicles 
7.4.1. Electrical cycles (currently outside the sc ope of the Framework Directive), tricycles and 
quadricycles 
See Annex XX, Ch. 1 , for the complete list of recommended monitoring and evaluation parameters. 
Significant uncertainties remain regarding key costs in the approvals process and in the casualty and 
environmental impacts of the proposed options. These should be monitored by the Member States and used 
as input for an evaluation conducted by the Commi ssion in 2016. Further data obtained to refine the 
assessments of potential impacts should be collected by the Member States. More detailed accident data are 
required to provide information on the safety of tricyc les and quadricycles and to allow the impact of any 
measures to be assessed. A more specific categorisati on of tricycles and quadricycles would allow the safety 
impact of future measures to be monitored. 
7.4.2. Specific requirement s for category L7e vehicles 
See Annex XX, Ch. 2 , for the complete list of recommended monitoring and evaluation parameters. Data on 
the costs of the proposed options could be gathered for evaluation purposes by monitoring type-approval 
costs prior to 2012 (the earliest proposed implementati on of any change) and further investigating the costs 
of national approval, to be carried out by the Member States and the Co mmission. This would allow the costs 
of approval processes to be more accurately quantif ied for all proposed options. For all options, it is 
important that a means of collecting European accident  data for quadricycles is implemented and that these 
accident data are disaggregated for different tricycle  and quadricycle types and accident locations (on-road 
and off-road). This would enable a clearer assessment of  the societal benefits of future safety improvement 
measures. 
7.4.3. Specific requirements for gaseous alternat ive fuels and other non-traditional propulsions  
See Annex XX, Ch. 3 , for the complete list of recommended monitoring and evaluation parameters. It has not 
been possible in this report or in the TRL report to conduct a cost-benefit analysis of the options for gaseous 
fuel-powered or other alternative propulsion equipped ca tegory L vehicles due to insufficient information on: 
the shares of current environmental impacts from road tr ansport that are due to each category of vehicle; the 
rate at which gaseous fuel-powered and other non-tradi tional propulsions for category L vehicles will be 
introduced in the EU27; the costs of these non-traditi onal propulsion category L vehicles (design, fitment, 
etc.); the costs of type- approval; and a full energy cycle assess ment. More statistical data should be 
collected by the Member States and used as input for a study by the Commission in the 2016 – 2017 
timeframe. 
 
EN 43   EN ANNEX  I: L-CATEGORY VEHICLE DEFINITIONS  
Definitions of L-category vehicles according to Fr amework Directive 2002/24/EC, chapter 1, article 1.2: 
Category Vehicle Name Vehicle characteristics 
L1e Moped Two wheels  and maximum designed vehicle speed of not more 
than 45 km/h  and characterised by: 
• cylinder capacity does not exceed 50 cm3 in the case of the 
internal combustion type, or 
• maximum continuous rated power  is no more than 4 kW  in 
the case of an electric motor ; 
L2e Three-wheel 
Moped Three wheels  and maximum designed vehicle speed of not 
more than 45 km/h  and characterised by: 
• cylinder capacity does not exceed 50 cm3 if of the spark 
(positive) ignition  type, or 
• maximum net power  output does not exceed 4 kW  in the 
case of other internal combustion engines , or 
• maximum continuous rated power  does not exceed 4 kW  in 
the case of an electric motor ; 
L3e Motorcycles Two-wheels , without a sidecar fitted with an engine having a 
cylinder capacity of more than 50 cm3 of the internal 
combustion type and/or having a maximum designed vehicle 
speed of more than 45 km/h , 
L4e Motorcycle & 
Sidecar Two-wheels , with a sidecar  fitted with an engine having a 
cylinder capacity of more than 50 cm3 if of the internal 
combustion type and/or having a maximum designed vehicle 
speed of more than 45 km/h , 
L5e Tricycles Three  symmetrically arranged wheels  fitted with an engine 
having a cylinder capacity of more than 50 cm3 if of the 
internal combustion type and/or a maximum design speed 
of more than 45 km/h.  
L6e Light Quadricycles Four wheels , unladen mass is not more than 350 kg  not 
including the mass of the batteries in case of electric vehicles, 
whose maximum design vehicle speed is not more than  45 
km/h , and 
• whose engine cylinder capacity does not exceed 50 cm3 for 
spark (positive) ignition engines, or 
• whose maximum net power  output does not exceed 4 kW  in 
the case of other internal combustion engines , or 
• whose maximum continuous rated power does not exceed 4 
kW in the case of an electric motor . 
These vehicles shall fulfil the technical requirements 
applicable to three-wheel mopeds of category L2e  unless 
specified differently in any of the separate directives; 
L7e Heavy 
Quadricycles Four wheels , other than those referred to in ca 
theory L6e whose unladen mass is not more than 400 kg  (550 kg  for vehicles 
intended for carrying goods ), not including the mass of 
batteries in the case of electric vehicles, and whose maximum net engine power  does not exceed 15 kW . These vehicles 
shall be considered to be moto r tricycles and shall fulfil the 
technical requirements applicable to motor tricycles of category 
L5e unless specified differently  in any of the separate 
Directives. 
Table 31: overview table with design criteria for L-category vehicles, according to Framework Directive 2002/24/EC, Chapter 1, 
Article 1.2 
 
EN 44   EN   
Figure 9: examples of vehicles in the scope of the current Framework Directive 2002/24/EC 
 
Please note that no differentiation is currently made in  the classes L6e and L7e between Quads for public 
road use, all terrain vehicles (ATVs) and mini cars. As long as the minimum design criteria of Framework 
Directive 2002/24/EC, Chapter 1, Article 1.2 are fulfill ed all three types of vehicles may be associated to L-
vehicle, class L6e, respectively L7e.  
 
 
Figure 10: examples of vehicles not  in the scope of the current Framework Directive 2002/24/EC 
 
Besides the classification as defined in Framework Di rective 2002/24/EC, Chapter 1, Article 1.2 there are 
also other classifications used to refer to sub-ca tegories of L-category vehi cles. Examples of other 
categorisation within the L- category vehi cle families: 
– Mopeds, besides the traditional widely known one-track vehicles th ere are also e.g. electrical 
cycles with a power higher than 250 W (0.25 kW), which are considered to be a Moped and must 
therefore be type approved as such a vehicle. 
– Powered Two Wheelers (abbreviated PTWs): this is a summary expression for one-track (2-wheel) 
vehicles combining L-category vehicles L1e and L3e. 
– Trikes or Motor Tricycles, this is a wide variet y of different two-track vehicle types, some with 2 
wheels in the front and one in the rear, others with  a configuration of 2 wheels at the rear and one 
in the front. The greater shares of these vehicles are equipped with gasoline engines, but there are 
also a number of vehicles, which are equipped with a Diesel engine.  
– Quadricycles: two-track 4-wheel vehicles like quad s used on public roads, all terrain vehicles used 
mainly off-road and mini cars. Quads used on public roads are predominantly powered by gasoline 
engines, mini cars are in general equipped with small industrial diesel engines. 

 
EN 45   EN ANNEX  II: PUBLIC CONSULTATION ON OUTLINE PROPOSALS FOR A REGULATION OF THE EUROPEAN PARLIAMENT 
AND OF THE COUNCIL FOR L-CATEGORY VEHICLES — SUMMARY OF RESPONSES  
1. C ONTEXT  
The Commission launched an open public consultation s eeking to gather views of interested parties on its 
outline proposals for new legislation for L-category vehicles. A consultation document has been published45 
to provide background and ask for opinions on this new framework, which should replace the Framework 
Directive and 13 separate directives and their many  amending directives. These outline proposals are thus 
embedded in the EU strategy to impr ove the regulatory environment to wards simplification, safety and 
environmental aspects. 
The public consultation was targeted at those groups t hat would be most affected by the proposals, including 
type-approval authorities in Member States, manufac turers, suppliers and consumers; published on a 
specific website created for the purposes of the consul tation; and published in English, French and German.  
The Commission has acknowledged the receipt of all stakeholder responses to the consultation, and these 
have been made publically available. 46 . The results of the public consultation were published in a report.47 
The written consultation was discussed on 29 June 2009 in a meeting of the Commission’s Working Group 
on Motorcycles48 (MCWG) to which all relevant stakeholders were invited. The preliminary impact 
assessment study results w ill be presented in the MCWG planned to  take place on 26 November 2009. The 
public consultation met with the Commission’ s minimum standards for consultation.  
2. O VERVIEW OF RESPONDENTS AND ANALYSIS METHOD  
In total fifty-seven respondents completed the survey and sent back their replies to the functional mailbox of 
the Commission services. Forty-one respondents replied on  behalf of an association, a company or a public 
authority, while sixteen replies were received from individual citizens.  
The unfiltered responses from all respondents can be ac cessed directly on the Commission’s website. In 
order to obtain a balanced, the responses from as sociations, companies and public authorities were 
combined.  
Although 16 individual citizens participated to the public consultation, in many cases the questions were left 
uncommented. The citizen replies that were applic able and which could be associated with the various 
questions have been summarised in a separate chapter.  Individuals’ e-mail and postal addresses have been 
removed in line with the pre-questionnaire privacy statement. 
The next step was to classify the replies in an overview  table per question. The final results were interpreted 
and summarised in the summary report. 
3. S UMMARY OF RESPONSES  
L-category vehicles refer to a classification of a wide r ange of 2-, 3- and 4 wheel vehicles like e.g. 2- & 3-
wheel Mopeds, 2- and 3-wheel Motorcycles, Tricycle s, All Terrain Vehicles/Quads and other quadricycles 
like mini-cars. All these different  types of vehicles are currentl y type approved under the scope of EU 
framework directive 2002/24/EC and its four teen associated implementing directives. 
                                                 
45 http://ec.europa.eu/enterprise/automotiv e/consultation/2_3_wheelers/index.htm . 
46 http://ec.europa.eu/enterprise/automotive/c onsultation/2_3_wheeler s/contributions.htm . 
47 http://ec.europa.eu/enterprise/automotive/c onsultation/2_3_wheelers/results_report.pdf . 
48 http://ec.europa.eu/enterprise/automotive/mcwg_meetings/29_06_2009/index.htm . 
 
EN 46   EN A number of potential policy options were developed in or der to meet the overall objectives. Subsequently a 
public consultation paper was published on the Internet at the end of 2008. This questionnaire, including a 
brief explanation on every potential policy option a nd 20 associated open questions, was published on the 
Commission’s website with a request to reply from Asso ciations, Public Authorities and individual citizens. 
The replies to this consultation paper were collected, classified, analyzed and again published on the 
Commission’s website. In total fifty-seven replies were  received, as summarised in attachments #2 to this 
report. 
Questions 1, 2 and 3 were related to simplification. The majority of the respondents were in favour, but some 
respondents doubted whether this proposal was actually going to deliver the promised simplification or not. 
More transparency, better harmonisation, and redu ction of unnecessary administrative costs were 
anticipated by some respondents as justification to simplify the current legal requirements. Also using 
equivalent international UNECE regulations to replace current EU directive requirements was perceived as 
positive by the majority of the respondents. A small number  of critical voices feared that increasing the use of 
references to UNECE regulations would create a co stly bureaucratic burden and generate a democratic gap 
from transferring future regula tory work from the EU proces s to this United Nations body. 
Questions 4 and 5 were dedicated to questions regardi ng emission measures. About half of the total number 
of survey respondents repres enting associations, companies and public authorities (a total of forty-one), 
were supportive on the introduction of new emission lim its equivalent to Euro 5 limits for petrol cars. An 
additional fifteen percent from the total number of this  group of respondents were conditionally in favour, 
summarised as ‘Relatively Favourable’. The conditions were mainly comprised of a sufficiently long lead time 
or a multi step approach for Indust ry to develop technology. Four respon dents of this group of forty-one and 
the majority of the sixteen individual citizens were ab solutely against the proposal fearing that more severe 
emission requirements would lead to a significant higher  customer price. The majority of the respondents 
were also in favour of additional related emission m easures like e.g. durability  requirements, evaporative 
emission limits and CO 2 and fuel consumption measurements. 
Questions 6 to 17 were related to safety measures. Q uestion number 6 requested for the survey participant’s 
view on mandatory fitting of Anti-lock Brake System s (ABS) on Powered Two Wheelers (PTW) and potential 
alternative solutions. Explicitly being in favour or against mandatory fitting of ABS were approximately 30  % 
each of the forty one respondents from the mix of asso ciations, companies and public authorities. However, 
an additional seventeen percent of this group of respo ndents were conditionally in favour of mandatory fitting 
of ABS, referred to as ‘Relatively Fa vourable’. Examples of these conditio ns were: mandatory fitting of ABS 
only for bigger PTWs, optional / voluntary fitting for small versions or other conditions like ‘a robust Impact Assessment analysis should first demonstrate a positive  cost-benefit ratio’. Question number 7 required the 
respondents view on other or supplementary solutions be tter suited for certain categories (i.e. coupled brake 
systems, stability control systems, et c.) that would produce the same/better effect than ABS at better (lower) 
cost. The top two of suggestions by the respond ents: ‘alternative advance d brake systems’ (20
 %) and ‘no 
alternative solution but ABS’ (10  %).  
Questions 8 and 9 requested feedback on potential anti-t ampering measures and asked for suggestions for 
alternative measures with respect to tampering prev ention. A wide majority of  survey participants (29  %) that 
responded (52  % of the 41 respondents) is opposed to additional anti-tampering measures. Frequently 
expressed opinion among the survey partic ipants, including the ones from the individual citizens, is that there 
is a need for anti-tampering measures with respect to Mopeds (L1e, L2e), but that additional anti-tampering 
measures for motorcycles (L3e, L4e, L5e) would be ‘adver se to users’ rights to make modifications to their 
motorcycles, providing these do not compromise their safety and impact on the environment.’. The top two 
responses to question number 9 if other solutions woul d be preferable: a shared first place for ‘No additional 
solutions’ and ‘Periodical technical Inspections’ (both 7  % from the 41 survey partici pants from associations, 
companies and public authorities) and on number two ‘M easures covering the electronic devices controlling 
the vehicle’s maximum speed, the in ter-changeability of components, the CVT components, the exhaust 
silencing system and marking (5  % of total). 
A high response rate (66  % of total) was noted on questions 10 and 11 regarding power limitation and its 
alternatives. The absolute majority (51  % of total 41 respondents from associations, companies and public 
authorities) were absolutely against power limitation, s upported by nearly all individual citizens, owing to the 
opinion that a correlation between v ehicle power and accident frequency wa s not scientifically proven. The 
top two of alternatives suggested by the respondent s; a shared first place through education/training and 
 
EN 47   EN power/mass ratio limitation (with each 12  % of total), the second place for regular safety inspections with 5  % 
of total. 
Questions 12 and 13 were related to mini-cars (categories L6e and L7e). 32  % of the respondents were of 
the opinion that that EU legislation on these vehicles is justified, 7  % was relatively favourable and 12  % was 
not agreeing to this statement. The adversaries of this  statement predominantly t hought that these types of 
vehicles should be regulated under national legislat ion of the Member States. Regarding the question 
whether these vehicles should have designated safety  requirements or comply with the same safety 
standards as passenger cars only 12  % of the respondents were in favour for passenger car safety measures 
compliance. The majority would like to see measures that are specifically designated to these types of 
vehicles. 
Questions 14 to 16 were related to quads. The majority of respondents is favourable (39  % if the share 
‘relatively favourable’ is included) to the question if  these vehicles should be in  the scope of type approval 
whereas they are not designed to be used on the road.  Not a single respondent agreed with the statement 
that at present the category in which these vehicles  are type approved is adapted to the design of such 
vehicles. The majority of the respondents would like to see new specific requirements be added to improve 
the safety of such vehicles. 
The last question related to L-category vehicle safety, number 17, was related to the need if in the scope of 
the EU legislation hydrogen vehicles  should be included. There was a slight majority in favour of EU 
legislative requirements regarding L-ca tegory vehicles fuelled with Hydro gen. Most of the stakeholders that 
are against this policy option argue that the technology is still in its early stage of development and that 
legislation may hinder innovation. The Motorcycle Industry  and individual citizens were of the opinion that EU 
legislation on hydrogen Powered Two Wheelers is not needed for the very next future. Prototypes could be 
individually type-approved at national level or to be subject to an exemption of the current framework 
directive.  
Questions 18 to 20 were related to the overall impac t of new L-category vehicle legislation on the 
competitiveness of the EU industry. Only one third of the survey partici pants decided to reply to these 
questions. Question 18 requested for the view of the par ticipants on the impact of measures related to the 
competitiveness of the EU industry, and in particular on the Small and Medium Enterprises (SMEs)? The 
reply of 22  % of the respondents was positive, 10  % anticipated a negative impa ct on the Industry. Question 
19 asked for the view on the impact of employment within the EU, which 15  % of the respondents thought 
this will be influenced negatively. Only 7  % considered a positive effect and was optimistic for the future of 
e.g. suppliers owing to the development of new tech nologies and increased production of components and 
systems owing to higher demand from  their customers. Finally on questi on 20 asking for the potential impact 
from new legislative requirements on the final customer price, the survey participants that responded were all 
of the same opinion, 34  % of total thought there would be a negative impact of new measures on the end 
customer price. 
 
EN 48   EN ANNEX  III: DESCRIPTION OF THE TASKS REQUESTED  TO THE EXTERNAL CONSULTANT TRL  AND METHODOLOGY 
USED — POLICY ASSESSMENT REPORT REGARDING POSSIBLE SAFETY MEASURES  
1. D ETAILED DESCRIPTION OF THE TASK TO BE PERFORMED  
In general terms, the impact assessment shall include an identification and estimation of the likely economic, 
safety and social effects of the following policy options, compared to the ‘no policy change’ baseline 
scenario. The baseline for the impact  assessment will be the state of play of the legislation today. 
The study will provide overview of t he state of the art of safety as well as the trend in terms of market and 
technology development. For the European market, the share between vehicles produced in Europe and 
vehicles produced outside Europe will also have to be provided. Then, for each policy option, both positive 
and negative impacts at EU level on road safety and cost s for the manufacturer should be considered as well 
as the time at which they are likely to occur (short, medium or long-term). In each of the mentioned cases the 
cost of the measures to be introduced will include manufacture, assembly, testing and final type approval of 
vehicles. In assessing the costs of the possible measur es, the contractor should seek to collect cost data 
from the different stakeholders (manufacturers, suppliers, etc) and take into account the reduction in costs 
when a technology is produced in high volumes followi ng new regulatory requirements. The Contractor will 
therefore asses and highlight the unc ertainties in costs and benefits. 
Overall, the time and effort put down in assessing the va rious impacts should be proportionate to their likely 
significance. Therefore, more focus should be put on the assessment of impacts which are likely to be 
important (e.g. potentially the economic and safety ones) than on those that are potentially less important 
(e.g. potentially the social ones but understanding that in this case, measur es applied to two and three-wheel 
motor vehicles may have a higher social cost on user s than similar measures applied to passenger cars). 
The contractor shall include wher ever possible the EU 27 Member States. The measures would be 
introduced in 2011 at the earliest. The follo wing possible options had to be assessed: 
– ABS/coupling braking dev ices for motorcycles 
– Anti-tampering for mopeds, motorcycles, tricycles and quadricycles 
– 74 kW power limit for motorcycles – Quadricycles (L6e and L7e) 
– Off-road quads  
– Safety of hydrogen powered L category vehicles. – Simplification of the legislation  
2. M
ETHODOLOGY  
The contractor will provide a comprehensive analysis  covering the above mentioned issues and will present 
a series of recommendations indicating the respective  advantages and disadvantages of the different policy 
options, clearly outlining and taking into account:  
The positive and negative impacts of the options sele cted, particularly in terms of quantified economic, 
social, safety and envir onmental consequences. 
Other additional effects. Description in qualit ative terms and quantified as far as possible.  
Impacts over time (time scale 10 years). Spread of impacts on social groups or economic sectors. 
The reports from the contractor will be structured in accordance with the Commission document SEC 
(2005)791 ‘Impact Assessment Guidelines’, updated in March 2006. The contractor’s methodology will be 
based on the Impact Assessment Guidelines and its Annexes.  
The contractor will perform the above analyses on the basis of: existing legislative measures in place for two- a nd three-wheel vehicles in other world markets; 
the published literature; 
experimental data in the hands of the contra ctor or available in the public domain; 
the information circulated in the Commission’s motorcycles working group; 
and any additional data the contractor will provide for the benefit of the study. 
 
EN 49   EN ANNEX  IV: DESCRIPTION OF THE TASKS REQUESTED TO THE EXTERNAL CONSULTANT LAT  AND METHODOLOGY 
USED — POLICY ASSESSMENT REPORT REGARDING POSSIBLE SAFETY MEASURES  
1. S UBJECT OF THE SERVICE REQUEST  
The subject of the service request is an assessment study of possible measures on motorcycles emissions, 
which will be based on the study conducted by the Un iversity of Thessaloniki (LAT) in 2004.  
 
1.1. Detailed description of the tasks to be performed 
The study will identify and evaluate the likely economic, environmental and social im pact of four different 
policy options , taking into account the foreseen legislation for light duty vehicles (Euro 5-6) and heavy duty 
engines (Euro VI): 
No policy change : This policy option corresponds to the situation where no additional measures to those 
defined in the Directives 2002/51/EC and 2006/72/EC w ill be taken for the control of the motorcycle 
emissions. 
Initial Commission proposal : This policy option reflects the proposal prepared by the European Commission 
on the basis of the agreed measures in the MVEG-motor group as well as the results of the LAT study, with a 
possible amendment of the equivalent Euro 3 limit va lues for the WMTC to account for the recent 
modifications of the test cycle and new experiment al data on the emission performance of Euro 3 
motorcycles. Euro 5 passenger cars equivalent limits : This policy option differs from the ‘Commission proposal scenario’ 
only in the introduction of more stringent emission limits for motorcycles that would be equivalent to the Euro 
5 limits for cars. 
Best available technology : This policy option will consid er the introduction of a range  of measures that will 
reflect the application of what is assumed to be toda y the ‘best available technology’ for two and three-wheel 
motor vehicles. 
The technical measures to be considered in the formulation of the above policy options will include: 
A procedure to check the durabilit y of emission control systems. 
A procedure to check the in-use conformity of the motorcycles. 
The technical provisions for the type-approval with respect to CO
2 emissions and fuel consumption. 
The new set of pollutant emission limit values for tr icycles and quadricycles discussed in the MVEG group. 
The introduction of OBD systems on two and three-wheel motor vehicles. 
The control of evaporative emissions fr om two and three-wheel motor vehicles. 
The introduction of the WMTC as the only test cycle for EU type-approval. A possible introduction of the ‘family concept’ in the type approval procedure. 
The new set of pollutant emission limit values for mopeds discussed in MVEG, on the basis of the policy 
options. The tasks that will be performed in t he framework of this study are: 
 Task 1. Information collection and analysis  
Task 1.1. Overview of the technical legislation on emissions from two and three wheelers and quadricycles 
used in the main markets of the world including developing countries (US, Japan, India and China).  
Task 1.2. Overview of the technology currently us ed in the main markets and the latest technological 
developments.  
Task 1.3. Revision of the equivalent Euro 3 limits for WMTC Task 1.4. Clarification of the policy options.  Task 2. Evaluation of the environmental, economic  and social impact of the different policy 
measures. 
Task 2.1. Estimation of the financial effects associated wi th the introduction of the different policy options.  
Task 2.2. Estimation of the envir onmental benefits associated with the introduction of the different policy 
measures.  Task 2.3. Identification and characte risation of any social impact asso ciated with the introduction of the 
different policy measures.  
Task 2.4. Cost effectiveness of  the different policy measures 
 
EN 50   EN 1.2. Methodology 
A methodological approach similar to the one followed in  the LAT study will be applied, with proper revisions 
and enhancements where necessary. The study team will provide a comprehensive analysis covering the 
above mentioned issues and will present a series of re commendations indicating the respective advantages 
and disadvantages of the different policy options , clearly outlying and taking into account: 
The positive and negative impacts of the options select ed, particularly in terms of economic, social and 
environmental consequences. 
Other additional effects. Description in qualit ative terms and quantified as far as possible. 
Impacts over time at short medium and long-te rm. The evaluation time will span over 10 years. 
Spread of possible impacts on social groups other or ec onomic sectors, with special reference to SME’s. 
Following the guidelines outlined in the Commissi on document SEC (2005)791 ‘Impact Assessment 
Guidelines’, the method to be used comprise: Step 1: Information collection and analysis 
Step 2: Formulation of the different policy options 
Step 3: Simulation Step 4: Impact assessment/cost-effectiveness 
 
EN 51   EN ANNEX  V: SELF OBLIGATION EUROPEAN MOTORCYCLE INDUSTRY ASSOCIATION (ACEM) 
Advanced Braking Systems  
ACEM Commitment on Advanced Brake Systems offer depl oyment on Powered Two-W heeler vehicles in the 
framework of a road safety agreement bet ween the European Commission and ACEM 
ACEM, the Motorcycle Industry in Europe, is the prof essional body representing the interests and combined 
skills of 12 manufacturers, responsible for a total of 25 motorcycle, scooter and moped brands. The members of ACEM account for 90% of the Europ ean production and powered two-wheeler market. 
Background Information 
1. Brake/tyre combinations on today’s powered tw o-wheelers have very high performance capabilities 
in a very wide variety of traffic and road conditi ons. In some emergency situations, when the rider 
has to make decisions in a split second, human ‘decision failures’ and faulty collision avoidance 
manoeuvres sometimes lead to loss of control, tyre lo ck up, rear tyre slide out, etc. In other cases, 
the accident happens without sufficient warn ing for the rider to take any action. 
2. In 2004, in an effort to provide simpler-to-use  Braking systems to riders and especially novice 
riders in emergency as well as in all other braking situations, ACEM manufacturers have jointly committed to the European Road Sa fety Charter to progressively supply powered two-wheelers 
with advanced braking systems, taking into account their distinctive characteristics. 
3. As a result of this commitment, 35% of the motorcycles sold by the ACEM manufacturers and 
registered in Europe in 2008 were equipped with advanced braking systems. 
4. Demand and market acceptance are crucial to the development of advanced braking systems on 
powered two-wheelers, and largely depend on the appropriateness of the solutions offered, 
technically and in terms of cost, to the specific market segment and model. 
5. ACEM believes that it would be impractical and nearl y impossible to try to translate into legislation 
the rich variety of systems and combinations of  systems and their adaptation to the variety of 
motorcycles and uses. A legislative approach (that, by definition, would need to be simple, clear 
and rigid) would lose the benefits of this di versity and would be detrimental to technology 
innovation. 
Introduction and Principles 
(1) This new Commitment is part of the ACEM road sa fety strategy that is based on the three following 
main pillars 
• Improving the knowledge about motorcycling safety, 
• Developing an integrated approach, and act on: 
 The human factor, 
 The vehicle, 
 The infrastructure, 
• Cooperating with institutions and stakeholders. 
(2) This commitment has the support of all ACEM powered two-wheeler manufacturing companies 
including their respective affiliated companies and commercial brands: 
 
EN 52   EN • Bayerische Motoren We rke AG (BMW Motorrad) as well as  its affiliated company Husqvarna 
Motorcyles S.r.l., 
• BRP European Distribution s.a • Ducati Motor Holding S.p.A., 
• Harley-Davidson Europe Ltd. as well as its affiliated company Buell, MV Agusta and its 
commercial brand Cagiva, 
• Kawasaki Motors Europe N.V., 
• KTM-Sport motorcycle AG, 
• Honda Motor Europe Ltd., as well as its affiliated company Montesa, • Peugeot Motorcycles, 
• Piaggio & C. S.p.A. as well as its affiliat ed company Derbi, and its commercial brands 
Vespa, Gilera, Aprilia, Scarabeo and Moto Guzzi 
• Suzuki International Europe GmbH, 
• Triumph Motorcycles Ltd., 
• Yamaha Motor Europe n.v. , as well as its affiliated company MBK Industries. 
These companies have agreed to make every endeavou r to contribute to ACEM's road safety goals to 
reducing accidents by funding research, financing and participating to road safety projects and acting 
towards the common objective of improving the road sa fety of powered two-whee ler users through “shared 
responsibility” initiatives. 
(3) This Commitment is in line with the European Union's undertakings under the European Road Safety 
Action Programme and in particular with the European Road Safety Charter, whose principles were 
adopted by ACEM and its members after ACEM became one of the first signatories at the Dublin 
Charter event in April 2004. 
(4) At the same time this commitment aims at pres erving the diversity of the product offerings of the 
manufacturers, reflecting the diversity of motorcyc le use, encouraging the development of innovative 
solutions especially in the domai n of brake systems. This commit ment also seeks to not negatively 
influence competitiveness, as well as the financ ial performance and employment of the European 
powered two-wheeler industry. 
(5) ACEM is assuming that this Commitment provid es complete and sufficient substitute for all new 
regulatory measures to mandate any advanced br aking systems on power ed two-wheelers of any 
category, as long as it is being honoured and produ ces satisfactory results in terms of market 
penetration. 
(6) The European powered two-wheeler industry's brak ing commitment is very ambitious in the light of 
present and future technologies, an d the industry is w illing and prepared to commit substantial 
development efforts to implement it. 
(7) Together with the European Commission, ACEM will ensure that the Commitment is implemented in 
a manner that is in line with applicable competition rules. 
ACEM Commitment (8) This new ACEM Commitment is based on the ex perience and expected results from the ACEM 
braking commitment agreed among powered two-wheel er manufacturers under the umbrella of the 
European Road Safety Charter in 2004. 
 
EN 53   EN (9) The motorcycle industry in Europe commits to progressively supply more motorcycles (powered two-
wheelers above 50 cm3) equipped with advanced braking systems to the market of the European 
Union.  
(10) As before, this new commitment will take ac count of the main purposes of motorcycles, their 
distinctive characteristics and spec ificities, e.g. balance, weight, dynamics, and general capacities, 
and the cost-effectiveness of the technical solutions. 
(11) As a result of this commitment 75% of street motorcycle models offered on the market in 2016 will be 
available with an advanced braking system as an option or as standard fitment. 
(12) To assess compliance and results with this commitment, there will be a joint ACEM/Commission 
monitoring of the relevant factors with regard to this commitment i.e.  % of manufacturers’ offering of 
motorcycle and market penetration. The Commissio n could decide to follow up the commitment and 
its results through an independent auditor. 
Definitions and Scope 
(13) An Advanced Braking System is a braking system  in which either an antilock brake system and/or a 
combined brake system is present. An Antilock Br ake System is a system for sensing and controlling 
the amount of relative slip velocity between t he tyre and road surface during braking. A Combined 
Brake System / CBS is a type of PTW braking syst em in which each brake manipulator (i.e., either 
lever and/or pedal) actuates a brake on the front w heel and a brake on the rear wheel. Definitions 
and performance and construction requirements for each of these brake systems are as laid down in 
ECE 78 or GTR3. 
(14) Both braking systems (ABS and CBS) can be co mbined and complemented with additional features 
e.g. rear lift off protection, automatic brake forc e distribution, powered braking system, braking-by-
wire system etc. Any other brake system with a function and braking performance equivalent to ABS 
or CBS, or better, is consid ered as Advanced Brake System. 
(15) Any innovative architecture of moto rcycles (powered two-wheeler above 50 cm3) with a brake 
system, whose function and brakin g performance are equivalent to ABS or CBS, or better, will be 
consolidated in the above mentioned monitori ng of Advanced Brake System deployment. 
(16) The commitment covers street motorcycles. T he commitment does not cover certain categories of 
vehicle known as enduro and trial motorcycles. En duro and trial motorcycles are primarily designed 
for off-road use and are therefore incompatible with ABS and indeed coupling braking devices: being 
able to intentionally lock the wheels is essentia l in certain off-road conditions. The industry 
commitment therefore excludes those vehicles co rresponding to the following characteristics: 
Enduro Motorcycles  
– Minimum seat height: 900 mm and 
– Minimum ground clearance: 310 mm and – Minimum overall gear ratio in the highest gear (primary  ratio x gear ratio x final drive ratio) of 6, 0; 
Trial Motorcycles 
– Maximum seat height: 700 mm and – Minimum ground clearance: 280 mm and 
– Maximum fuel tank capacity: 4 l and 
– Minimum overall gear ratio in the highest gear (primary  ratio x gear ratio x final drive ratio) of 7, 5. 
 
EN 54   EN (17) The Industry commitment also excludes vehicles  intended for production in small series of up to a 
maximum of 200 units a year per type of vehicl e, per system, per component or per separate 
technical unit. 
Accompanying Provisions 
1. Promotion of advanced br aking system technologies 
This commitment is based on the assumption of an unhampered distribution of motorcycles fitted with 
advanced braking systems into the market via com petition amongst ACEM members and other market 
participants which is expected to result in market mix changes. Therefore it is fundamental that any 
measures which might ham per the distribution process will be taken into consideration in the monitoring 
procedure. 
2. Acceptance of innovations 
The acceptance by the Commission, th at innovative concept of vehicles/f eatures offering better performance 
than conventional braking system s comply with the Commitment. 
Monitoring 
The Motorcycle Industry in Europe will regularly co mmunicate a status report on the progress of advanced 
braking systems available on the market. The joint ACEM / Commission monitoring procedure should cover: 
(18) The development of the manufacturers’ offering  of motorcycles available with advanced braking 
systems. 
(19) The development of the market penetration of registered motorcycles fitted with advanced braking 
systems. 
(20) The assessment of new technologies and vehicle ar chitectures that can be agreed to be in the spirit 
of this Commitment.  
(21) The percentage offered with an advanced brake system shall be measur ed by calculating the 
number of types offered with an Advanced Brake System variant or version versus the total number 
of types offered (type, variant and version as defined in framework directive 2002/24/EC). 
To allow manufacturers to collect all data on new model lin e ups, the actual calculatio ns of the status of the 
commitment will happen at the end of a year (first time end of 2015). 
The Commission's official reports on the monitoring results may refer to individual companies' achievements. 
ACEM is willing to provide the necessary data to  achieve the objectives of the monitoring.  
 
ACEM and the Commission will review the situation on the basis of the monitori ng reports and  make any 
necessary adjustments in good faith, in particular also  if the impacts of this Commitment on the European 
motorcycle industry and market, the employment si tuation and the global competitive environment, would 
appear to be detrimental. 
 
EN 55   EN ANNEX  VI: SELF OBLIGATION EUROPEAN MOTORCYCLE INDUSTRY ASSOCIATION (ACEM)  ENVIRONMENTAL 
ASPECTS  
 
 
EN 56   EN 
 
 
EN 57   EN 

 
EN 58   EN ANNEX  VII: SELF OBLIGATION EUROPEAN MOTORCYCLE INDUSTRY ASSOCIATION (ACEM)  ENVIRONMENTAL 
ASPECTS — REVISED EMISSION LIMITS  
Vehicle Type Category Scenario THC 
(mg/km)THC & 
NOx
(mg/km)CO
(mg/km)NOx
(mg/km)PM
(mg/km)Approx. Type 
Approval entryClassification 
criteriaTest 
Cycle
2W Mopeds, EU3, Prop. 
ACEM , cold wei ghtingL1 3 1200 1000 [01/01/2012] PI & <50ccECE R47 
& cold
2W Mopeds, EU4, Prop. 
ACEM, cold weightingL1 3 800 1000 [01/01/2015] PI & <50ccECE R47 
& cold
3W Mopeds, EU3, Prop. 
ACEM, cold weightingL2 3 1200 3500 [01/01/2012] PI & <50ccECE R47 
& cold
3W Mopeds, EU4, Prop. 
ACEM, cold weightingL2 3 900 1900 [01/01/2015] PI & <50ccECE R47 
& cold
2W 2-Stroke Motorcycles, 
EU 4 Prop. ACEM 2012           < 130 km/hL3 & L4 3 _ 691 1965 _ - [01/01/2012]PI & (-25%*EU3 
WMTC)WMTC, 
ph2
2W 4-Stroke Motorcycles, 
EU 4 Prop. ACEM 2012           < 130 km/hL3 & L4 3 563 - 1965 128 - [01/01/2012]PI & (-25%*EU3 
WMTC)WMTC, 
ph2
2W 2-Stroke Motorcycles, 
EU 4 Prop. ACEM 2012           
≥ 130 km/hL3 & L4 3 - 413 1965 - - [01/01/2012]PI & (-25%*EU3 
WMTC)WMTC, 
ph2
2W 4-Stroke Motorcycles, 
EU 4 Prop. ACEM 2012           
≥ 130 km/hL3 & L4 3 248 - 1965 165 - [01/01/2012]PI & (-25%*EU3 
WMTC)WMTC, 
ph2
2W 2-Stroke Motorcycles, 
Euro 5, Prop. ACEM 2015       
< 130 km/hL3 & L4 3 - 443 570 - - [01/01/2015]WMTC corr.:          
THC=1.10, CO=1.31, 
NOx=1.47
PC EU5/EU3 fact.: THC=0.50, CO=0.435, WMTC, 
ph2
2W 4-Stroke Motorcycles, 
Euro 5, Prop. ACEM 2015       < 130 km/hL3 & L4 3 375 - 1140 68 - [01/01/2015]WMTC corr.:          
THC=1.10, CO=1.31, 
NOx=1.47
PC EU5/EU3 fact.: THC=0.50, CO=0.435, WMTC, 
ph2
2W 2-Stroke Motorcycles, 
Euro 5, Prop. ACEM 2015       
≥ 130 km/hL3 & L4 3 - 253 1140 - - [01/01/2015]WMTC corr.:          
THC=1.10, CO=1.31, 
NOx=1.47
PC EU5/EU3 fact.: THC=0.50, CO=0.435, WMTC, 
ph2
2W 4-Stroke Motorcycles, 
Euro 5, Prop. ACEM 2015       ≥ 130 km/hL3 & L4 3 165 - 1140 88 - [01/01/2015]WMTC  corr.:          
THC=1.10, CO=1.31, 
NOx=1.47
PC EU5/EU3 fact.: 
THC=0.50, CO=0.435, 
NOx=0.40WMTC, 
ph2
3W Motorcycles PI,      Euro 
3, Prop ACEM
EDCL5 3 1000 - 4000 250 - [01/01/2012] PI ECE R40
3W Motorcycles, PI,       
Euro 4, Prop ACEM
EDCL5 3 550 - 2000 250 - [01/01/2015] PI ECE R40
3W Motorcycle CI,      Euro 
3, Prop ACEM
EDCL5 3 150 - 1000 650 100 [01/01/2012] PI ECE R40
3W Motorcycles CI,      Euro 
4,Prop ACEM 
EDCL5 3 100 - 600 550 80 01/01/2015 CI ECE R40
4W, Light Quadricycle, EU2 L6 0 - 1200 3500 - - 01/01/2003 PI & <50cc ECE R47
4W, Light Quadricycle, Euro 
3,Prop. ACEML6 3 1200 3500 - - [01/01/2012] PI & <50ccECE R47 
& cold
4W, Light Quadricycle, Euro 
4, Prop. ACEML6 3 900 1900 - - [01/01/2015] PI & <50ccECE R47 
& cold
4W, Heavy Quadricycle, 
Euro 3, Prop. ACEML7 3 1000 - 4000 250 [01/01/2012] PI ECE R40
4W, Heavy Quadricycle, 
Euro 3, Prop. ACEML7 3 150 - 1000 650 100 [01/01/2012] CI ECE R40
4W, Heavy Quadricycle, 
Euro 4, Prop. ACEML7 3 550 - 2000 250 [01/01/2015] PI ECE R40
4W, Heavy Quadricycle, 
Euro 4, Prop. ACEML7 3 100 - 600 550 80 [01/01/2015] CI ECE R40
NB scenario # Reference to emission study LAT & ACEM proposals for introduction into the upcoming EU legislation 
3 Proposal ACEM, categories L1 to L7 (for L3 the 2-step approach and the calculated multiplication factor vs EU3) Emission thresholds overview (mg / km)
 
Table 32: Proposed L-category vehicle emission limits by European motorcycle industry association ACEM 
 
EN 59   EN ANNEX  VIII:  BACKGROUND TO THE TYPE -APPROVAL SYSTEM  
How the system works Before the EU developed the type-approval system most Member States (MS) used to have their own, 
differing national requirements for new vehicles to be allowed on the market. The directives for L-Category 
vehicles (2002/24/EC) were set up to counter the pr oblems for industry created by these differences and 
separate approval procedures by harmonising the mini mum requirements to be fulfilled. Execution of testing 
and approval activities was left to the MS. In the directiv es it is stated that other MS have to accept approvals 
given in one MS (mutual recognition, based on EU r equirements; an approach of mutual recognition based 
on –differing- national requirements has been discuss ed in the past but has never been accepted by 
Member States).  
Costs: the system has inherent costs: the directives have to be developed (meetings of experts, drafting by 
Commission services and experts from MS; procedural co sts related to getting the draft approved by the co-
legislators; cost of implementing di rectives in national legislation and its verification by the Commission; 
costs for manufacturers to get their product tested (inc luding provision of products for testing) and approved; 
follow-up costs if product needs to be adapted and again appr oved. Available figures are in this report and 
the supporting external report.  
Every Member State appoints a ‘Type-approval authorit y’. This TAA must be notified to the Commission and 
other MS to perform the necessary tests or other inst itutes (test houses) can be notified for this purpose. 
A manufacturer, who proposes a new vehicle or com ponent (e.g. headlamp) contacts the TAA and the test 
house, submits the prescribed completed information document, makes the vehicle or component available 
for testing and pays the fees. 
It may prove that the test is not passed; in such case  the product can be adapted and resubmitted for testing.  
If all is well the manufacturer obtains the test report(s) and approval form(s). These forms are defined in the 
Separate Directives (SDs). Then the manufacturer is able to sell his product everywhere in the EU, provided 
she / he puts the prescribed marking on the product and, for vehicles, provides a Certificate of Conformity 
(CoC) with every vehicle delivered. 
In case of a vehicle, the manufacturer can obtain TA in one step (all testing etc in one go), or step-by-step 
(separate approvals for every component / system; in t he end, for the vehicle as a whole, she / he submits 
the approvals given before. In the latter case, whic h is must usual, many part-approvals may have been 
obtained by other (component) manufact urers. Another option foreseen is that one manufacturer builds a 
basic but incomplete vehicle and the next finishes it by e.g. building the bodywork on it, or modifying it for a 
specific purpose: multi-stage approval. 
A manufacturer can submit a product for TA only in one MS, to one TAA (no ‘shopping’). 
The TAA must inform the other authorities about TA’s  given, denied or withdrawn. The latter because the 
TAA is responsible towards the others in case it is found that products are marketed which are not in line 
with the TA given. 
As long as the EU system allows options, this means that the manufacturer may choose to apply for an EU 
TA for the vehicle or component. EU requirements are often somewhat stricter than national requirements 
and thus the product may have to be somewhat more expensive; on the other hand if his markets are in 
more MS she / he can choose his best option. 
The approval procedure for a vehicle may be time-consumi ng, often starting in the first year of development, 
lasting 3 to 4 years. It’s important for the manufacturer not to have to repeat this number of times in different 
countries. 
 
EN 60   EN ANNEX  IX: THE MARKET FOR L-CATEGORY VEHICLE IN THE EU 
1. T HE STRUCTURE OF THE EU MARKET  
The powered two-wheeler (PTW) segment of the L-cat egory market is the most important in terms of 
manufacturing, turnover and employment. However, in or der to keep the analysis in line with the structure of 
other sections of the impact assessment, the analysis is carried out in the following order: 
(1) Electrical cycles 
(2) Powered Two Wheelers: Mopeds and motorcycles. This also includes motorcycles with side car. 
(3) Off-road Quads; also called All Terrain Vehicles (ATVs) 
(4) Mini-cars 
2. E LECTRICAL CYCLES  
Currently electrical cycles fall out of the scope of L- category vehicles (less than 0.25 kW, maximum vehicle 
speed of 25 km/h). More powerful electric cycles are categorised as mopeds and fall in the scope of type 
approval legislation. 
The market is still very young and very  fragmented. Most of the electric bike manufacturers who entered the 
market first, originally produced conventional bikes and gradually added the production of electric bikes to 
their activities. The number of vehicles produced is ei ther not available or still very low. Only 6 companies 
produce relevant numbers, in 2009 ranging from an estimated 6  000 to 50  000 cycles. They have accordingly 
relevant revenues ranging from €350  000 to €2.7 million in 2009.  
The electric cycle industry is a very international bu siness, with companies located in Europe, America and 
the Far East. The overall majority of the companies are very small, often even micro companies. Quite a 
number of them have no prior history in the cycle business. All large companies are companies that are 
adding electric cycle activities to their original acti vities in the field of conventional cycles. The overall 
majority of the companies are active in various elec tric vehicle categories. T he production of the overall 
majority of the companies is still in a very early stage.  As a result production volume and revenues are low, 
whereas R&D costs are relatively high. 
2.1. Sales of Electric Cycles 
The European Commission has received the following data from professional organisations (ETRA) and the 
data has not been verified independently. 
France: 
Sales in 2008 were at 15  800 units, which is a 50  % improvement of the 2007 result.  
Germany: 
In 2008, an estimated 100  000 electric cycles were sold, which is 2.5  % of total sales volume. Growth is 
considerable: +62.5  % in 2007, +54  % in 2008 and a forecasted +20  % in 2009. 
Italy: 
Sales in 2008 are estimated at 10  000, whereas for 2009 they are expected to increase to 30  000. Sales may 
well be further encouraged as a result of the renewe d cycling incentive scheme. The Italian government has 
allocated another €7.6 million euro to spur consumers to purchase (electric) cycles. In a first phase, the 
Italian government has already granted  €11.4 million euro as incentives fo r buying (electric) bikes. The 
incentive was extremely successful.  
The Netherlands: 
In 2008, almost 140  000 electric bikes were sold at an average retail price of €1  900. Thus electric cycles 
have generated 1/3 of the total revenue from sales of new bikes in The Netherlands. 
UK: 
Sales in 2008 are estimated at 15  000, whereas for 2009 a 50  % increase is forecasted. Sales are reported to 
be mainly to commuters who are replacing car or public  transport journeys by electric bike journeys. Sales 
have been bolstered by tax breaks on cycle purchases. 
Belgium: 
 
EN 61   EN There are no statistics available but th e most important suppliers all confirm the success of the electric cycle. 
Since 2007, Sparta, which is one of the most popular brands in Belgium reports growth of 10 to 15  % a year, 
with a +15  % prognosis for this year. With that, sales of electric bikes are reported to increase more than 
other types of bikes.  
 
Year 2007 2008 2009 2010 2011
China 21,000,000 21,000,000 21,000,000 25,000,000 30,000,000
India 85,000 120,000 300,000 500,000 700,000
Japan 300,000 317,000 325,000 325,000 350,000
European 
Union250,000 550,000 800,000 1,200,000 2,500,000
Taiwan 10,000 10,000 11,000 12,000 14,000
SE Asia 200,000 800,000 1,000,000 2,000,000 5,000,000
USA 120,000 170,000 220,000 350,000 500,000
Total 21,965,000 22,967,000 23,656,000 29,387,000 39,064,000Worldwide Electric Bike Sales as Estimated in the Electric Bikes* Worldwide Reports 
2008
 
Table 33: Worldwide Electric cycle sales and sales forecasts 
 
EN 62   EN 3. P OWERED TWO -WHEELERS (PTW) 
This is the largest and most important sector of the in dustry and includes motorcycles, including those with a 
side car, mopeds and scooters. PTW market statistics 
3.1. EuroStat data 
The manufacturing of motorcycles is classified under the NACE activity classi fications of 35.4 and 35.5. 
However, this particular classification does not di saggregate the manufacture of motor-cycles from the 
manufacture of cycles. In addition, the classification is so broad that a manufacturer which contributes in any 
way to the manufacture of a vehicle is included. Using this classification, EuroStat  estimates that there are 
2.300 companies manufacturing motorcycles and cycles. This would seem to be an over-estimate of the 
reality of the market-place. A study by  the University of Bologna estimate s that that stripping out the cycle 
manufacturing companies would yield an estimated 870 companies which manufacture motorcycles. 
However, in order to get a more accurate estimate  of the number of manufacturing companies, data has 
been gathered from the ‘type approval’ authorities and analysed to produce a more accurate picture of the 
number of manufactures in the EU. The resu lts are discussed below in chapter 3.2. 
EuroStat also provides data for Prodcom classificati ons, which indicates the number of units produced and 
the production value for certain classifications of m anufacturing activities. Motor-cycles and scooters are 
classified under subsectors 35.4 and 35.5, classified by  cylinder displacement. The most recent full year data 
is for 2007. 
The data indicates that for 2007, the EU produced 1.136 m illion L-category vehicles. Overall, the statistics 
indicate that the value of production of  motorcycles and scooters in the EU was €  4.1 billion in 2007. The 
most important segment in terms of value is the lar ge motor-cycle segment, where the engine size is greater 
than 800cc; the production value is €  1 billion for this segment. In terms of number of vehicles , more scooters 
are produced than motorcycles, but their ov erall value is less and was valued at €  840 million in 2007.  
The production of ‘parts and accessories’ is also an important segment, with a production value of €  1.6 
billion. 
Powered Two Wheelers sub categories1000's of 
units € million
Motorcycles, and cycles fitted with an auxiliary motor, 
with an engine capacity <= 50cc493 631
Scooters with an engine capacity > 50cc but ≤ 250cc 360 840
Motorcycles with an engine capacity > 50cc but ≤  
250cc (excludin g scooters )120 250
Motorcycles with an engine capacity > 250cc but ≤ 
500cc158 587
Motorcycles with an engine capacity > 500cc but ≤  
800 cc109 692
Motorcycles with an engine capacity > 800 cc 180 1,000
Motorcycle side-cars 40 127
Total 1,136 4,127 
Table 34: Production volume Powered Two Wheelers 2007, EuroStat data 
3.2. Type Approval data 
The data generated by type-approval authorities are a more market based source of information and can be 
particularly useful to assess the structure of the ma rket because the type approval data indicates which 
manufacturers had a vehicle type-approved in order to place it on the market. Initially a sample of type-
approval data from March 2008 to 2009 was analysed. Fo llowing on from that analysis, a large sample from 
January 4th 2005 to March 2009 was analysed to ensure t hat the results are consistent. This later sample 
involved over 15.000 type- approvals for vehicles. 
 
EN 63   EN The analysis of the type-approval data indicates a far smaller cohort of active companies who manufacture 
L-category vehicles and place them  on the market, than that indicated by the EuroStat data. Having 
analysed in detail the type approval data from March 2008 to  2009, the analysis results indicated that 42 EU 
companies applied for type approval for an L-category vehicle. Of the 42 companies, 18 are Italian, 10 are 
German, 5 are French, 2 are Spanish, 2 Swedish and one each from UK (Triumph), Poland, Greece, Austria 
and Switzerland. However, further investigations yield the information that companies which are based in the 
EU sought type-approval for vehicles which they did not actually manufacture themselves, but they imported 
the vehicles from China and then marketed and sold the vehicles in Europe.  
Finally, of the 42 companies, we estimate that 17 are SME’s. The remaining 25 of the 42 companies are 
owned by large companies or large corporations. T he analysis of the type-approval data is reasonably 
consistent with data recently received  from industry (ACEM). ACEM have indi cated that their estimate is that 
106 companies manufacture motorcycles. This figure of 106 includes non-EU companies from Japan, China, Thailand and the United States.  
Having analysed the data for one year above, a lar ger sample was analysed covering the timeframe January 
4th 2005 to March 2009. Since 2005, approximately 280 EU companies sought type approval to place a 
vehicle on the market. This results in an average of  56 companies per year. Cons equently it was estimated 
that there are between 42 and 56 Eur opean companies manufacturing motorcycles in the EU. However, over 
the same time period, 398 non-EU companies applied fo r type-approval to place vehicles on the market. 
Among the non-EU, by far the most significant group  were Chinese companies seeking type-approval.  
3.3. Import and export of motorcycles and motorcycle parts 
The following import into the EU and export from th e EU data were obtained from EuroStat and extracted 
using the COMEX database from 1999 to 2008. The mo st significant trend is high and sustained imports 
from Japan from 1999 to 2008, from companies such as Honda, Suzuki, Kawasaki and Yamaha, as shown in the sales data below. Following from Japan, the main imports are from China, USA and Taiwan. As 
mentioned above, the imports from China are often rebranded and marketed under a European name such 
as Hartford (UK) and Geo polis (Greek company). The value of imports from China and Taiwan has increased 
dramatically from 178.1 million Euros in 1999 up to 646.5 million Euros in 2008.  
As regards exports, the largest export market for motorc ycles manufactured in the EU is the USA, increasing 
from 220.5 million Euros in 1999 to 359.4 million Euros in 2008. After the USA, the largest markets are Australia and Switzerland. There is no signifi cant export yet from the EU to China and 
Taiwan.
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008
IMPORTS [x 1,000 €]
Extra European 2,840,946 3,091,244 2,710,645 2,390,600 2, 531,612 2,798,560 3,019,010 3,181,156 3,206,480 2,881,422
Japan 2,305,627 2,489,032 2,141,665 1,909,956 1,879,365 1,964,394 1,918,938 2,119,349 2,075,018 1,690,580China 11,198 19,958 31,865 51,329 100,606 176,613 371,894 391,425 447,815 496,554USA 218,584 260,033 295,635 204,668 307,167 333,784 378,525 348,575 344,392 351,517
Taiwan 166,931 209,501 136,778 132,891 150,587 176,416 186,226 181,024 178,059 149,960
Thailand 606 357 1,835 5,903 18,356 39,011 49,546 28,106 49,459 109,466
EXPORTS [x 1000 €]
Extra European 510,394 700,753 775,878 831,399 775,699 764,477 832,953 970,691 1,014,522 1,063,138
USA 220,552 331,803 341,230 337,489 335,957 301,612 314,640 397,172 374,727 359,402
Australia 29,666 42,337 49,129 53,253 52,745 72,880 79,165 90,990 91,115 115,410
Switzerland 75,865 87,554 86,165 81,468 100,109 92,231 87,805 86,216 99,586 94,178Japan 55,153 76,280 95,741 92,309 80,287 71,225 69,961 66,497 70,798 793,353
Vietnam 103 208 2,192 4,769 18,586 24,096 35,721 61,144 62,355PTW
 
Table 35: Import in the EU and Export from the EU of motorcycles, 1999 – 2008 
 
EN 64   EN Similar trends as for complete motorcycles can also be  observed for motorcycle par ts. The majority of motor-
cycle parts come from Japan, Taiwan and China, again with the greatest amounts of imports from Japan. 
The value of imports of parts is almost twice that of exports. The ratio of imports to exports for motorcycle 
parts with Japan has declined from 11.4 in 1999 to 9. 0 in 2008, however the value remains substantive. 
Imports have continued to increase from China and Taiwan from 52.3 million Euros in 1999 up to 226.7 
million Euros in 2008, which is 4.3 times more than in  1999. As regards exports of motorcycle parts from 
Europe, the main exports are to the USA where exports increased from €  43.3 million in 1999 to €  135.7 
million in 2008. After the USA, the next most important markets are t hose of Brazil and Switzerland.  
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008
IMPORTS [x 1,000 €]
Extra European 340,746 489,969 481,118 447,030 494,501 562,346 591,841 629,977 689,039 690,406
Japan 200,540 294,890 277,034 271,174 276,935 291,195 278,790 268,689 274,978 247,848Taiwan 48,998 78,010 70,336 57,876 60,712 75,159 87,571 104,765 111,178 118,887China 2,313 8,263 14,455 26,724 42,642 58,332 67,996 80,467 96,809 107,805
USA 66,255 78,362 83,304 46,045 61,177 60,869 67,426 67,958 74,795 75,137
Thailand 7,533 13,246 15,621 20,158 25,195 40,417 45,426 51,903 57,160 65,493
EXPORTS [x 1000 €]
Extra European 144,458 182,408 201,897 248,520 244,119 240,791 251,697 291,352 312,061 338,389
USA 43,262 62,321 66,578 101,538 108,164 110,844 104,006 133,776 136,938 135,733
Brazil 4,595 4,982 7,640 5,979 3,988 4,235 8,297 8,049 10,115 29,152
Switzerland 13,778 17,838 21,436 18,569 17,178 21,295 23,649 24,969 28,002 28,245Japan 17,550 24,188 25,074 27,817 32,508 28,962 30,869 29,250 27,404 27,407
Australia 7,022 6,237 7,072 7,601 9,676 10,024 12,659 14,685 16,707 16,997Motorcycle parts
 
Table 36: Import in the EU and Export from the EU of motorcycle parts, 1999 – 2008 
3.4. The impact of the new measures on international trade 
The EU imported €2.8 billion worth of motor-cycles fr om outside the EU in 2008, with the main import 
countries being Japan €1.7 billion and China € 0.5 billion. Chinese imports have grown from €  11 million to € 
0.5 billion since 1999. Imports from Thailand ha ve also increased significantly from €  606.000 to €  109 million 
in the same time period. The EU exported €  1.06 billion, the main markets being the United States and 
Switzerland. The trend for international trade is to  see increased imports from China and other Asian 
countries into the EU. Given the patterns that have  emerged from the analysis of the type-appr ovals over 
recent years, the indication is that this will continue.  
The safety aspects of the new regulation will be cr ucial to prevent unsafe vehicles being placed on the 
European market and to protect the consumer from purcha sing unsafe products. In conjunction with this, it is 
necessary to put in place increased market surveillance to prevent such vehicles being placed on the EU 
markets. The labelling of vehicles with information regarding carbon dioxide emissions will assist the 
consumer to choose the most energy efficient vehicles irrespective of country of origin of the vehicle and 
ensure a level-playing field for all manufacturers. The pric e of motorcycles in the EU may increase if the cost 
of the improved safety features and meeting lo wer pollutant emission targets and other necessary 
environmental measures is passed on to customers.  
3.5. Production of PTWs 
The activity of the manufacture of motorcycles is grouped under NACE code 35.41 by EuroStat. According to 
the 2009 EuroStat Facts and Figure, the EU-27’s motorcycles and cycles manufacturing subsector consisted 
of 2  300 enterprises which created €  2.4 billion of value added in 2006. The sector employed 55  900 persons. 
Italy was the largest producer of motorcyc les and cycles in the EU-27, with a 40  % share of EU-27 value 
added and a 35% share of the workforce. Italy and Li thuania were the most specialised producers of 
motorcycles and cycles within the EU-27 in terms of the sector’s contribution to non-financial business 
economy value added. In 2007 motorcycles and cycles ma nufacturing output in the EU-27 grew by 2.2%, 
following 1.8% growth in 2006. 
In 2006 the EU-27’s motorcycles and cycles manuf acturing subsectors combined an apparent labour 
productivity of €  42 600 per person employed with average personnel costs of €  30 900 per employee to leave 
a wage adjusted labour productivity ra tio of 138% which is very high. In most Member States value added 
per person employed exceeded personnel costs per empl oyee, the exceptions being Slovenia and France 
where the wage adjusted labour productivity ratio was below 100%, and in Ireland where negative value 
added resulted in a large, negative wage adjusted labour productivity ratio. 
 
EN 65   EN Production 
ValueVolume sold Production Value Volume sold 
( €million) ( 1000 units) ( €million) ( 1000 units)
Parts and accessories 
for motorcycles, 
mopeds and scooters 
(excluding saddles)35.41.20.90 1,720 1,452
Scooters with an engine 
capacity > 50 cm3 but ≤ 
250 cm335.41.12.13 1,255 622 840 360
Motorcycles, and cycles 
fitted with an auxiliary 
motor, with an engine 
capacity ≤ 50 cm335.41.11.00 678 530 706 530
Motorcycles with an 
engine capacity >250 
cm3 but less than 500 
cm335.41.12.30 368 77
Motorcycles with an 
engine capacity > 500 
cm3 but ≤ 800 cm335.41.12.50 983 172 693 109
Motorcycles with an 
engine capacity > 800 
cm335.41.12.70 1,000 180Description PRODCOM code
2006 2007
 
Table 37: Production PTWs for 2006 and 2007- Source EuroStat 
Table 7 gives a snap-shop of data for the production of PTWs using PRODCOM data for 2006 and 2007 for 
the various categories of motorcycles, scooters and par ts. The figures reveal that in 2007, the value of 
motorcycle production of vehicles over 800cc was the most lucrative and was valued at €1 billion, producing 
180  000 vehicles. The second high est value was for scooters at  840 million producing 360  000 scooters. This 
was followed by 530  000 motorcycles with capacity of less than 50 cm3 worth €706 million. A total of 109  000 
vehicles were produced in the EU with engine displacements between 500 and 800cc at a value of €693 
million. 
 
EN 66   EN QUANTITY [thousand 
units] VALUE IN Million €
 EU15 TOTALS
Jan.-Dec. 2000 1,324 1,451      Jan.-Dec. 2001 927 994
      Jan.-Dec. 2002 900 900
      Jan.-Dec. 2003 720 900
      Jan.-Dec. 2004 600 900
      Jan.-Dec. 2005 600 400
EU27 TOTALS
      Jan.-Dec. 2003 796 1,000
      Jan.-Dec. 2004 600 880
      Jan.-Dec. 2005 600 400      Jan.-Dec. 2006 510 657
      Jan.-Dec. 2007 530 706
      Jan.-Dec. 2008 493 631
 EU15 TOTALS
      Jan.-Dec. 2000 565 1,155
      Jan.-Dec. 2001 477 944
      Jan.-Dec. 2002 452 886
      Jan.-Dec. 2003 335 711
      Jan.-Dec. 2004 368 783
      Jan.-Dec. 2005 586 1,179
 EU27 TOTALS
      Jan.-Dec. 2003 335 711
      Jan.-Dec. 2004 368 783
      Jan.-Dec. 2005 586 1,179
      Jan.-Dec. 2006 376 799
      Jan.-Dec. 2007 360 840      Jan.-Dec. 2008
Motorcycles with an engine capacity > 50 cm but <= 250 cm (excluding scooters)
EU15 TOTALS      Jan.-Dec. 2000 100 261      Jan.-Dec. 2001 90 240      Jan.-Dec. 2002 120 320      Jan.-Dec. 2003 60 250
      Jan.-Dec. 2004 80 210
      Jan.-Dec. 2005 150 280
EU27 TOTALS      Jan.-Dec. 2003 60 250
      Jan.-Dec. 2004 80 210
      Jan.-Dec. 2005 150 280
      Jan.-Dec. 2006 120 360
      Jan.-Dec. 2007 120 250
      Jan.-Dec. 2008   
 EU15 TOTALS
      Jan.-Dec. 2000 49 192
      Jan.-Dec. 2001 41 160
      Jan.-Dec. 2002 44 187
      Jan.-Dec. 2003 78 334
      Jan.-Dec. 2004 60 400
      Jan.-Dec. 2005 87 363EU27 TOTALS
      Jan.-Dec. 2003 80 337
      Jan.-Dec. 2004 83 400
      Jan.-Dec. 2005 89 365
      Jan.-Dec. 2006 77 369
      Jan.-Dec. 2007 158 587
      Jan.-Dec. 2008Scooters with an engine capacity > 50 cm but <= 250 cm
Motorcycles with an engine capacity > 250 cm but <= 500 cmMotorcycles, and cycles fitted with an auxiliary motor, with an engine capacity <= 50 cmQUANTITY and VALUE of L-Category Vehicles By ENGINE CAPACITY
 
Table 38: Quantity and value of L-Category Vehicles by engine capacity, part 1 
 
EN 67   EN QUANTITY [thousand 
units] VALUE IN Million €
EU15 TOTALS
      Jan.-Dec. 2000 126 560
      Jan.-Dec. 2001 91 477      Jan.-Dec. 2002 96 539      Jan.-Dec. 2003 108 659
      Jan.-Dec. 2004 145 826
      Jan.-Dec. 2005 165 851
EU27 TOTALS
      Jan.-Dec. 2003 108 659
      Jan.-Dec. 2004 146 826
      Jan.-Dec. 2005 165 851      Jan.-Dec. 2006 128 767      Jan.-Dec. 2007 109 693
EU15 TOTALS
      Jan.-Dec. 2000 125 898
      Jan.-Dec. 2001 140 1,201
      Jan.-Dec. 2002 180 1,400
      Jan.-Dec. 2003 120 1,135
      Jan.-Dec. 2004 100 1,075
      Jan.-Dec. 2005 150 1,205
EU27 TOTALS 0 0      Jan.-Dec. 2003 120 1,137
      Jan.-Dec. 2004 100 1,077
      Jan.-Dec. 2005 150 1,207
      Jan.-Dec. 2006 126 1,173
      Jan.-Dec. 2007 180 1,000      Jan.-Dec. 2008  
 EU15 TOTALS
      Jan.-Dec. 2000 3 16
      Jan.-Dec. 2001 4 20
      Jan.-Dec. 2002 4 23
      Jan.-Dec. 2003 3 17      Jan.-Dec. 2004 1 2      Jan.-Dec. 2005 2 17
EU27 TOTALS
      Jan.-Dec. 2003 3 17      Jan.-Dec. 2004 2 3      Jan.-Dec. 2005 2 17
      Jan.-Dec. 2006 6 28
      Jan.-Dec. 2007 3 16
      Jan.-Dec. 2008 40 128QUANTITY and VALUE of L-Category Vehicles By ENGINE CAPACITY
Motorcycles with an engine capacity > 500 cm but <= 800 cm
Motorcycles with an engine capacity > 800 cm
Motorcycle side-cars
 
units] VALUE IN Million €
EU15 TOTALS
      Jan.-Dec. 2000 3,500.00 45.00      Jan.-Dec. 2001 2,000.00 35.00
      Jan.-Dec. 2002 2,800.00 28.00
      Jan.-Dec. 2003 1,800.00 20.00      Jan.-Dec. 2004 1,500.00 27.00
      Jan.-Dec. 2005 2,400.00 60.00
EU27 TOTALS      Jan.-Dec. 2003 1,800.00 20.00      Jan.-Dec. 2004 1,500.00 27.00
      Jan.-Dec. 2005 2,400.00 60.00
      Jan.-Dec. 2006 1,600.00 28.00      Jan.-Dec. 2007 2,400.00 40.00
      Jan.-Dec. 2008 1,200.00 28.00
Parts and accessories for motorcycles, mopeds and scooters (excluding saddles) EU15 TOTALS
      Jan.-Dec. 2000  1,225
      Jan.-Dec. 2001  1,263      Jan.-Dec. 2002  1,320      Jan.-Dec. 2003  1,467
      Jan.-Dec. 2004  1,497
      Jan.-Dec. 2005  1,535EU27 TOTALS 0
      Jan.-Dec. 2003  1,479
      Jan.-Dec. 2004  1,514      Jan.-Dec. 2005  1,578      Jan.-Dec. 2006  1,444
      Jan.-Dec. 2007  1,450
      Jan.-Dec. 2008 1,604Saddles for motorcycles, mopeds, and scootersQUANTITY and VALUE of L-Category Vehicles By ENGINE CAPACITY
 
Table 39: Quantity and value of L-Category Vehicles by engine capacity, part 3 
 
EN 68   EN Tables 8 & 9 give a more extended and detailed picture of the market from 2001 to 2008. This tables yield 
the Prodcom data for the value of pr oduction and quantity of goods produced  since 2001, for EU 15 and then 
for EU 27. The production is broken down in detail motorcycles and scooters by engine capacity. 
3.6. PTW Price development over time 
The consumer price indices from EuroStat have data for all EU 27 c ountries in a category ‘Motor cycles, 
cycles and animal drawn vehicles’. The following table illustrates prices on an annual base from 2000 to 
2008. 
  2000 2001 2002 2003 2004 2005 2006 2007 2008 
EU 27 98.0 99.5 98.4 99.1 100. 2 100.0 100.0 101.1 102.9 
Table 40: consumer price indices in category ‘Motor cycles, cycles and animal drawn vehicles’ in EU 
27 countries 
As a practical example of how prices have changed over time, an OEM has provided an example of price 
development over time for a popular 1200 cm3 motorcycle with standard fittings. The prices include VAT. The 
company name is with-held for reasons of confidentiality. 
Month Year Price 
January 2004 €  11 500 
January 2005 €  11 700 
January 2006 €  12 050 
January 2007 €  12 360 
January 2008 €  12 500 
January 2009 €  12 650 
May 2009 €  12 800 
Table 41: Example of price development over time for a popular 1200 cm3 motorcycle (Source: 
anonymous motorcycle manufacturer) 
3.7. Sales of PTWs 
In line with the automotive industry, the PTW industry was affected by the economic crisis in the final quarter 
of 2008 and also again in 2009. The market in 2008 decreased by 7.4  % on a year by year basis over 2007. 
In the first quarter of 2009, PTW sales were down 37  % on the same period in 2008.  
Few countries have taken demand measures to stimulat e the sales of new vehicles, Italy being the main 
exception. Italy has put a scrappi ng scheme in place: vehicles with low cylinder capacity benefited from a 
€ 500 contribution for scrapping obsolete vehicles. This ha d a positive effect on the market. However, sales 
still decreased by 20  %. Spain has adopted a motorcycle scrapping scheme in July 2008 but this has not 
been implemented. Between January and August 2009 in Spain Moped sales were down by 52  % and PTW 
sales were down by 43  % on the same period in 2008 . 
 
EN 69   EN Ranking Brand SalesMarket 
share Ranking Brand SalesMarket 
share
1 HONDA 235,906 17.2% 1 YAMAHA 34,687 9.1%
2 YAMAHA 213,661 15.6% 2 PIAGGIO 26,639 7.0%
3 SUZUKI 149,090 10.9% 3 PEUGEOT 25,027 6.6%
4 PIAGGIO 130,065 9.5% 4 DERBI 23,680 6.2%5 KAWASAKI 82,624 6.0% 5 KYMCO 21,991 5.8%6 BMW 67,448 4.9% 6 BAOTIAN 16,620 4.4%
7 KYMCO 55,673 4.1% 7 KEEWAY 15,016 3.9%
8 APRILIA 41,921 3.1% 8 APRILIA 12,008 3.2%9 HARLEY 39,935 2.9% 9 RIEJU 9,804 2.6%
10 KTM 32,137 2.4% 10 SYM 8,345 2.2%
11 TRIUMPH 27,966 2.0% 11 CPI 5,531 1.5%12 DUCATI 25,497 1.9% 12 BETA 4,626 1.2%13 SYM 24,238 1.8% 13 MBK 4,374 1.2%
14 PEUGEOT 19,240 1.4% 14 TGB 3,805 1.0%
15 DAELIM 11,906 0.9% 15 GILERA 3,477 0.9%16 HYOSUNG 8,631 0.6% 16 HONDA 3,123 0.8%
17 MALAGUTI 8,480 0.6% 17 DAELIM 1,874 0.5%
18 DERBI 6,642 0.5% 18 SKYTEAM 1,473 0.4%19 GILERA 6,234 0.5% 19 SAMADA 1,329 0.4%20 HUSQVARNA 6,208 0.5% 20 MALAGUTI 1,291 0.3%
OTHERS 89,855 6.6% OTHERS 133,887 35.1%MOTORCYCLES MOPEDS
 
Table 42: Sales data and market share for 2008- (Source ACEM) 
7.4.4. Motorcycles 
The first four left hand columns relate to refers to sa les of motorcycles in the EU during 2008. Japanese 
companies have captured 50  % of the market for motor-cycles in the EU. The most successful European 
company is Piaggio with a market share of 9.5  %, followed by BMW with a share of 4.9  %. Large companies 
are dominant in the market for motorcycles. 
7.4.5. Mopeds 
The moped market is more fragmented than the market for motorcycles and the total supplied ‘by others’ is 
35 % of the market. Industry sources indicate that the overall market share for Chinese companies for 
motorcycles and mopeds combined is 20  % and anecdotal evidence suggests  that the EU moped market is 
most under threat from cheap imports from the Far East (with the exception of Japan). 
3.8. Upstream-Suppliers 
The number of suppliers to the industry is estimat ed at around 500. These suppliers have traditionally been 
European concentrated in Italy, Spain, France, the Un ited Kingdom, Germany and the Netherlands. In recent 
years competition from Asian suppliers has increas ed. In response to this competition some European 
suppliers have in turn moved part of their activities  to Asia. However, European component suppliers rely 
exclusively on orders from European producers. There are an estimated 20  000 jobs in the components 
sector, located mainly in Italy, Spain, France, t he United Kingdom, Germany, the Netherlands and Hungary. 
These activities are included in  the NACE 35.41 classification. 
3.9. Downstream- sale, maintenance and repair  
The downstream activities of the sale, maintenance  and repair of motorcycles are gathered under NACE 
50.4. This distribution sector generated €  3.4 billion of value added in the EU-27 million in 2006 from a 
turnover of over €25 billion. 105  000 persons were employed by the 37  000 enterprises in the motorcycles 
distribution sector. It is estimated that 72  % of the total industry’s turnover is generated in this sector. 
 
EN 70   EN The distribution and assistance network works in proxim ity to its users which is specific to motorcycles 
(especially as regards mopeds and scooters): in the EU there are around 37  000 active points of sale and 
after-sales assistance, often run by family businesse s. Italy, France, the United Kingdom, Germany, Spain, 
the Netherlands, Greece and Sweden account for 91  % of turnover in the distribution and assistance sector; 
this figure rose by 5  % between 2004 and 2006. 
3.10. Employment PTW industry 
The total number of persons employed for the motorcyc le and cycle industry as a whole is estimated at 
approximately 184  000, between manufacturers, upstream and downstream sectors. As mentioned above 
the NACE class DM3541 for ‘the manufacture of motorcyc les and cycles’ does not disaggregate motorcycles 
from cycles, so both are included in the values below. Given that caveat, in 2004 the most recent EuroStat 
data show that 59  000 people were employed in the manufacturing sector. From the NACE class 50.4 which 
analyses the sale, maintenance and repair of motorcycles below, it can be derived that 105  000 persons 
were employed in this sub-category. Finally suppli er’s organisations estimate the numbers of persons 
employed in supplier industry is 20  000 persons. 
Employment in this market is concentrated in Italy, Spain, France, Germany and the United Kingdom. 
However, in terms of specialisation, Italy and Latvia ar e the most specialised, in terms of the importance of 
the industry to their own economy. The seasonal nature  of the motorcycle market which is busier in the 
spring and summer months causes production peaks at certain times of year, during which manufacturers 
take on seasonal workers. 
Amount of 
employees 1-9 10 - 19 20-49 50-250 >250 Total
Member State
BE 7 7
BG 89 3 3 95
CZ 33 4 14 12 2 65
DK 734 1 4
DE
ES 68 19 14 9 4 114
FR 161 16 17 9 3 206
IT 560 116 63 42 12 793
CY
LV
LT 21 3
LU 11
HU 25 3 5 33
MT
NL 70 10 10 10 100
AT 92 1 11 1 4
PL 75 4 6 10 3 98
PT 29 11 11 8 59
RO 52 2 3 1 2
SI 14 2 16
SK 11 4 15
FI 11 1 1 13
SE 82 6 6 9 103
UK 163 17 180
Totals 1,412 225 156 122 26 1,941 
Table 43: Number of SME’s manufacturing motorcycles and cycles for 2006-NACE code DM3541 
 
EN 71   EN Table 14 analyses the size of companies involved with the manufacture of motorcycles and cycles. There are 
two caveats with the statistics. The first is that the EuroStat statistics do not disaggregate motorcycles from 
cycles; therefore the statistics may be skewed. The second caveat is that  the statistics do not include the 
numbers for Germany which are unavail able for reasons of confidentiality. 
It is estimated that there are approximately 100 manufac turers of either motorcycles or mopeds in the EU, 
about half of which are owned by European companies. The number of SME’s operating in both motorcycle 
and scooter markets is very small. 
4. All Terrain Vehicles (ATVs) 
There are no statistics gathered by EuroStat and t he Impact Assessment must rely on data and statistics 
presented by the professional organisations. The indu stry for On-road quads is not represented by a 
professional organisation. However, Off-road quad s (ATVs) are represented by ATVEA. According to 
ATVEA, this sector of the industry  employs directly or indirectly 12.000 people and have a turn-over of €  2 
billion. 
 
EN 72   EN 4.1. All Terrain Vehicle (ATV) sales in Europe 
TOTAL ECONOMIC VALUE 2008 2,011,818,750                      EUR
TAX CONTRIBUTION 395,949,664                         EUR
ESTIMATED TOTAL FLEET 730,000    units
NEW UNIT SALES
DESCRIPTION VALUE TOTAL MARKET VALUE NOTE
2008 new unit sales 155,000           units
Average CIF T1 costs 3,000               EUR/unit 465,000,000                                                                
Import Duties 7% 32,550,000                                                                  
Avg Cost + import duties 3,210               EUR
Transport 100                  EUR/unit
Distribution Margin 890                  EUR
Average Wholesales 4,200               EUR
Average Dealer Margin 800                  EUR
Average Retail (excl. VAT) 5,000               EUR 775,000,000                                                                
VAT 19% 147,250,000                                                                
TOTAL TAX 179,800,000                                                                
TOTAL UNIT SALES (INCL. TAX) 922,250,000                                                                
ACCESSORIES + GEAR
DESCRIPTION VALUE TOTAL MARKET VALUE NOTE
Average (new units only) 175                  EUR/unit
VAT 19%
Average (new units only) incl. VAT 208                  
TOTAL TAX 5,153,750                                                                    
TOTAL UNIT SALES (INCL. TAX) 32,278,750                                                                  
USED UNIT SALES
DESCRIPTION VALUE TOTAL MARKET VALUE NOTE
ratio against new units 70% % of units compared to new unit sales
used units 108,500           units
average cost 2750 EUR/unit
average sales 3500 EUR/unit
margin 750 EUR/unitVAT 19%TOTAL TAX 15,461,250                                                                  
TOTAL UNIT SALES (INCL. TAX) 379,750,000                                                                
REGISTRATION
DESCRIPTION VALUE TOTAL MARKET VALUE NOTE
Local registration ratio 50% % of unitsLocal registration costs 500 EUR/unit
Margin 300 EUR/unit
Local registration sales 800 EUR/unitVAT 19% 32,395,000                                                                  
Local registration sales (INCL. TAX) 952 EUR/unit 147,560,000                                                                
TOTAL TAX 32,395,000                                                                  
TOTAL UNIT SALES (INCL. TAX) 147,560,000                                                                
PETROL
DESCRIPTION VALUE TOTAL MARKET VALUE NOTE
Average milage 2000 km/unit/year
Consumption 10 liter/100 km
Average liter 200 liter/unit/yearFuel cost 0.50                 EUR/liter 73,000,000                                                                  
Fuel tax 0.60                 EUR/liter 87,600,000                                                                  
VAT 19% 13,870,000                                                                  
Fuel (retail) 1.20                 EUR/liter
TOTAL TAX 101,470,000                                                                
TOTAL SALES (INCL. TAX) 174,470,000                                                                
RENTAL
DESCRIPTION VALUE TOTAL MARKET VALUE NOTE
units in operation at rental companies 2% % of totalunits in operation at rental companies 14,600             units
rental fee 42                    EUR/hr
VAT 19%rental fee (incl. VAT) 50                    
billed hours per day 3                      hours/day
billed days per year 120                  days/year
total rental income per unit / year 18,000             EUR 262,800,000                                                                
TOTAL TAX 41,959,664                                                                  
TOTAL SALES (INCL. TAX) 262,800,000                                                                
INSURANCE
DESCRIPTION VALUE TOTAL MARKET VALUE NOTE
insurance fee 100 EUR/unit/yearinsurance tax 8%
VAT 19%
insurance (retail) 127 EUR/unit/yearTOTAL TAX 19,710,000                                                                  
TOTAL SALES (INCL. TAX) 92,710,000                                                                  
 
Table 44: All Terrain Vehicle (ATV) sales in Europe (source: ATVEA) 
 
EN 73   EN 4.2. Employment ATV industry 
TOTAL EMPLOYMENT 2008 12,454   
NEW + USED UNIT SALES
2008 new + used unit sales 263,500          units / staff
dealer staff (sales, service) 8,783              30                    
distributors 527                 500                  
headquarters 176                 1,500               
others (incl. logistics, accounting, finance etc) 176                 1,500               
TOTAL EMPLOYMENT 9,662                  
ACCESSORIES + GEAR
turnover 32,278,750     to / staff
dealer staff 646                 50,000             
distributors 40                   800,000           
European headquarters 22                   1,500,000        
others (incl. logistics, accounting, finance etc) 10                   
TOTAL EMPLOYMENT 717                     
REGISTRATION
number of variants put on the market in 2008 300                 
homologation officials 0.1 empl oyment per variant per year
homologation development 0.1 employment per variant per yeartotal homologation employment 60TOTAL EMPLOYMENT 60                       
PETROL
liters of fuel consumed per year 146,000,000   
liters of fuel per employee 1,000,000       assumption 1M liter of fuel require 1 FTE
total staff required to sell and distribute fuel 146                 
TOTAL EMPLOYMENT 146                     
RENTAL
units in rental operation 14,600            lifetime is 1 year
average fleet / rental company 12                   
number of rental companies 1,217              
staff per rental company 2                     
TOTAL STAFF 1,825                  
INSURANCE
number of total ATVs 730000
total manhours required 60,833            5 minutes total jobtime per ATV
hours per staff per year 1400 average workhours per year per staffinsurance staff required 43                   
TOTAL STAFF 43                       
 
Table 45: Employment ATV industry (source: ATVEA) 
5. M INI-CARS  
The market is comprised of mini cars which are co nstructed for the primary purpose of on-road transport. 
These vehicles are exclusively built by specialised European SMEs. EuroStat do not compile statistics on 
mini-cars and hence the European Commission are depe ndent on professional organisations to provide 
statistics. The European fleet of mini-cars manufactur ed by member companies of EQUAL, the mini car 
industry association, totals about 340  000 vehicles. Mini-cars represent 1.1  % of the L-category fleet and are 
vehicles meeting a specific need. The market is more ma ture in France, Spain, and Italy. The global sales for 
2007 were 35  000 vehicles, more than 90  % were equipped with very small, industrial, compression ignition 
engines, manufactured by industrial  suppliers (Lombardini, Kubota, Yanmar) who do not develop a specific 
automotive product. The average annual mileage is estimated to be between 5  000 to 7  000 kilometres. 
At present there are 11 manufacturers, without except ion SMEs, of mini-cars in Europe who are established 
in various Member States. The global market leader as  producer for this vehicle type, employed 200 people 
in 2008, and produced 13  500 vehicles per year of which 1  500 electrical vehicles (200 – 300 utility vehicles).  
- In France: Aixam, Automobiles Ligier, Bellier, Chatenet, JDM-Simpa, Microcar, 
- In Italy: Casalini ; Grecav, Piaggio, Tasso, - In Germany: ATW. 
These manufacturers are often est ablished in regions lacking a developed industrial network (in France: 
Savoie, Vendée, in Italy: Abruzzi). On a larger scale, the mini-cars industry entertains a complex network of 
partners, on which depend 20000 jobs in Europe. 
 
EN 74   EN ANNEX X: DETAILS CHAPTER 5 — IMPACT ANALYSIS — SIMPLIFICATION OF LEGISLATION  
In summary: 
Economical
EnvironmentalSafet
y
SocietalType of impact:
 
 
Remarks
Low Mean High Low Mean High
0 € 0 € 0 € € 160,000 € 3,100,000 € 10,500,000 cumulative EU27 2009 - 2020
€ 22,000 € 25,000 € 28,000 Annual  estimated translation cost
Same argument as mentioned for transparency applicable for 
bureaucratic burden
Same argument as mentioned for transparency applicable for 
democratic gap
Technical standards meeting effort reduced for Industry/EU-27: not 
quantified; magnitude of change uncertain
Economies of scale: not quantified; will only lead to savings for OEMs if standard design can be sold in more countries
More rapid accrued benefits: not quantified; potential large 
safety/environmental benefit depending on the performance of proposed change and how much quicker it can be implemented 
compared with current situationMore transparent regulatory system: not quantified; benefits difficult 
to quantify
Reduced travelling: not quantified; benefits uncertain
Low Mean High Low Mean High
€ 78,000 € 420,000 € 786,000 € 58,000 € 2,400,000 € 8,800,000cumulative 2009 - 2020. The benefit must be offset to the cost e.g. 
net mean cost: € 1,980,000.
€ 22,000 € 25,000 € 28,000 Saved annual estimated translation cost
Low Mean High
1.1 1.2 2.5
Same argument as mentioned for transparency applicable for 
bureaucratic burden
Same argument as mentioned for transparency applicable for 
democratic gap
Technical standards meeting effort reduced for Industry/EU-27: not 
quantified; magnitude of change uncertain
Economies of scale: not quantified; will only lead to savings for 
OEMs if standard design can be sold in more countriesOption 1: No policy change
Option 2: Repeal current directives and replace with a minimum number of regulations
Lack of Transparency was an issue for a minority of respondents to 
the public consultation, therefore was transparency rated neutral to 
Costs of regulatory system to implement 
and maintain EU Directives
Solution is not sustainable. Current 
problems like complexity, time-consuming 
implementation task, obsolete or non-
aligned measures with technology, lack of 
legal and regulatory clarity, increased 
proliferation of text etc. may only be 
resolved for the short to medium timeframe 
. For the mid to long term the same 
concerns as with option 1 may partly 
reappear.Benefit to cost ratio
Democratic gap
Will final result of simplification of the 
current legal text and at the same 
time adding new measures to align 
with technical progress as end result 
truly simplify ?Option 3: Recast the current framework Directive 2002/24/EC Benefit Cost Other indicators
Translation cost eliminated if direct reference 
to technical standard
Technical standards meeting effort reduced 
for Industry/EU-27
Standardisation of component and vehicle 
design leading to economies of scaleImproved global harmonization, better and 
clearer structure of legal textLength of processing: agreeing on one text 
including all requirementsTransparency
Bureaucratic burdenPositive Negative Neutral  / No agreement in public Break-even  in year 2017 - 2019After initial investment, reduced annual costs 
of regulatory systemLength of processing: agreeing on one text 
including all requirements
Translation cost eliminated if direct reference 
to technical standard
Technical standards meeting effort reduced 
for Industry/EU-27Improved global harmonization, better and 
clearer structure of legal text
Time taken for implementation of regulatory 
change deceased so benefits can be accrued 
more rapidlyWill final result of simplification of the 
current legal text and at the same 
time adding new measures to align with technical progress as end result 
truly simplify ?Standardisation of component and vehicle 
design leading to economies of scale
Benefit Cost Remarks / Other indicatorsMore transparent regulatory system. 
Intangible benefits to all stakeholders; All 
Industry; potentially larger benefits for SMEs 
and new entrants
Emissions resulting from travel to/from 
technical standards meetings reduced for Industry/EU-27Positive Negative
Neutral  / No agreement in public 
consultation
Loss in safety and environmental 
protectionDemocratic gapBureaucratic burdenTransparencyNo risk of loss or gain in quality of current 
requirements
Lack of Transparency was an issue for a m inority of respon dents to 
the public consultation, therefore was transparency rated neutral to 
positive, hence, listed in both columnsPositive NegativeNeutral  / No agreement in public 
consultation
Minimal impact Current problems like complexity, time-
consuming implementation task, obsolete or 
non-aligned measures with technology, lack 
of legal and regulatory clarity, increased 
proliferation of text etc. will not be resolved.
 
Table 46: Analysis table policy options simplification 
 
EN 75   EN ANNEX  XI: DETAILS CHAPTER 5 — IMPACT ANALYSIS VEHICLE TYPE APPROVAL ENVIRONMENTAL MEASURES  
1. N EW OR REVISED ENVIRONMENTAL MEASURES FOR THE TYPE APPROVAL OF NEW VEHICLES  
1.1. Revised lower emissions limits, detailed analysis of pr oposed limit by comparison with  light duty M1 emission limits 
In the LAT report an overview of current European and global L-ca tegory vehicle emission limits were given. In the tables and g raphs on the next pages the current 
emission limits and the different considered emission scenarios we re summarised. The current and proposed limits were expressed  as a percentage of Euro5 M1 
passenger cars (mainly gasoline (PI) cars, but if appropriate for e.g. 3- and 4 wheel vehicles also diesel (CI) cars. 
Emission thresholds overview (ALL in mg / km or in %)
#Emission 
Scenario #Label graphs Vehicle Type CategoryNumber of 
wheelsEngine Type / 
Combustion 
CycleEuro 
level
THC THC 
(% of M1 
Euro5) THC & NOxTHC & NOx
(% of M1 
Euro5 veh.) COCO
(% of M1 
Euro5 
veh.) NOxNOx
(% of M1 
EU4 veh.)NOx
(% of M1 
Euro5 / 
EU6 veh.) PMPM (% of 
Euro5 
veh.)Approx. Type 
Approval entryClassification criteria 
&
Comments Test Cycle
1 01) 2W Mopeds, Euro2, 
Option 1Moped L1 2 PI  / 4S 2 - - 1200 750% 1000 100% - - - - - 17/06/2002 PI & <50cc ECE R47
2 12) 2W Mopeds, Euro3, 
cold weighting, 2010, 
Option 2Moped L1 2 PI  / 4S [3] - - 1200 750% 1000 100% - - - - - 01/01/2010 PI & <50ccECE R47 & 
cold weighting
3 23) 2W Mopeds, Euro3, 
cold weighting, 2012, 
Option 3Moped L1 2 PI  / 4S [3] - - 1200 750% 1000 100% - - - - - [01/01/2012] PI & <50ccECE R47 & 
cold weighting
4 24) 2W Mopeds, Euro4, 
cold weighting, 2015, 
Option 3Moped L1 2 PI  / 4S [4] - - 800 500% 1000 100% - - - - - [01/01/2015] PI & <50ccECE R47 & 
cold weighting
8 48) 2W&3W Mopeds, 
Euro3, cold weighting, 
2013, Option 5 Two & Three-
wheel MopedL1 & L2 2 & 3 PI  / 4S [3] 165 165% - - 1140 114% 88 110% 147% - - 01/01/2013 PI & <50ccECE R47 & 
cold weighting
9 49) 2W&3W Mopeds, 
Euro4, cold weighting, 
2016 , Option 5 Two & Three-
wheel MopedL1 & L2 2 & 3 PI  / 4S [4] 100 100% - - 1000 100% 60 75% 100% - - 01/01/2016 PI & <50ccWMTC, 
adapted
Ref.Reference PI   Passenger 
Car, M1, PI, Euro5Passenger Car M1 4 PI  / 4S 5 100 100% 160 100% 1000 100% 60 75% 100% 5 100% 01/09/2011 PI NEDC
5 05) 3W Mopeds, Euro2, 
Option 1Moped L2 3 PI  / 4S 2 - - 1200 750% 3500 350% - - - - - 17/06/2002 PI & <50cc ECE R47
6 26) 3W Mopeds, Euro3, 
cold weighting, 2012, 
Option 3Three-wheel 
MopedL2 3 PI  / 4S 3 - - 1200 750% 3500 350% - - - - - [01/01/2012] PI & <50ccECE R47 & 
cold weighting
7 27) 3W Mopeds, Euro4, 
cold weighting, 2015, 
Option 3 Three-wheel 
MopedL2 3 PI  / 4S [4] - - 900 563% 1900 190% - - - - - [01/01/2015] PI & <50ccECE R47 & 
cold weighting
8 48) 2W&3W Mopeds, 
Euro3, cold weighting, 
2013, Option 5 Two & Three-
wheel MopedL1 & L2 2 & 3 PI  / 4S [3] 165 165% - - 1140 114% 88 110% 147% - - 01/01/2013 PI & <50ccECE R47 & 
cold weighting
9 49) 2W&3W Mopeds, 
Euro4, cold weighting, 
2016 , Option 5 Two & Three-
wheel MopedL1 & L2 2 & 3 PI  / 4S [4] 100 100% - - 1000 100% 60 75% 100% - - 01/01/2016 PI & <50ccWMTC, 
adapted
Ref.Reference PI   Passenger 
Car, M1, PI, Euro5Passenger Car M1 4 PI  / 4S 5 100 100% 160 100% 1000 100% 60 75% 100% 5 100% 01/09/2011 PI NEDC 
Table 47: Overview current, proposed and bench mark emission limits for 2 & 3 wheel Mopeds (classes L1e & L2e) 
 
EN 76   EN Class L1, 2-wheel Moped, overview current and proposed limits
 [% of Euro5  M1 PI Passenger Car threshold]750%
750%750%100%
100%100%
100%
114%
100%100%100%
100%
100%165%
100%100%500%
(100%)147%
0%100%200%300%400%500%600%700%800%900%1000%
1) 2W Mopeds, Euro2,
Option 1
2) 2W Mopeds, Euro3,
cold weighting, 2010,
Option 2
3) 2W Mopeds, Euro3,
cold weighting, 2012,
Option 3
4) 2W Mopeds, Euro4,
cold weighting, 2015,
Option 3
8) 2W&3W Mopeds,
Euro3, cold weighting,
2013, Option 5 
9) 2W&3W Mopeds,
Euro4, cold weighting,
2016, Option 5 
Reference PI  
Passenger Car, M1, PI,
Euro5 [% of Euro5  M1 PI Passenger Car threshold]
THC THC & NOx CO NOx PM (% of Euro5 veh.)
 
Figure 11: Overview current, proposed and bench mark emission limits for 2 wheel Mopeds (classes L1e) 
 
EN 77   EN Class L2, 3-wheel Moped, overview current and proposed limits
 [% of Euro5  M1 PI Passenger Car threshold]750%
750%350%
350%
190%
114%
100%
100%
100%100%100%165%563%
100%147%
100%
100%
0%100%200%300%400%500%600%700%800%900%1000%
5) 3W Mopeds, Euro2,
Option 1
6) 3W Mopeds, Euro3,
cold weighting, 2012,
Option 3
7) 3W Mopeds, Euro4,
cold weighting, 2015,
Option 3 
8) 2W&3W Mopeds,
Euro3, cold weighting,
2013, Option 5 
9) 2W&3W Mopeds,
Euro4, cold weighting,
2016, Option 5 
Reference PI  
Passenger Car, M1, PI,
Euro5 [% of Euro5  M1 PI Passenger Car threshold]
THC THC & NOx CO NOx PM (% of Euro5 veh.)
 
Figure 12: Overview current, proposed and bench mark emission limits for 3 wheel Mopeds (classes L2e) 
 
EN 78   EN Emission thresholds overview (ALL in mg / km or in %)
#Emission 
Scenario #Label graphs Vehicle Type CategoryNumber of 
wheelsEngine Type / 
Combustion 
CycleEuro 
level
THC THC 
(% of M1 
Euro5) THC & NOxTHC & NOx
(% of M1 
Euro5 veh.) COCO
(% of M1 
Euro5 
veh.) NOxNOx
(% of M1 
EU4 veh.)NOx
(% of M1 
Euro5 / 
EU6 veh.) PMPM (% of 
Euro5 
veh.)Approx. Type 
Approval entryClassification criteria 
&
Comments Test Cycle
10 010) 2W Motorcycle, < 
150cc, Euro3, EDC, 
Option 1Motorcycle L3 & L4 2 (3) PI  / 4S 3 800 800% - - 2000 200% 150 188% 250% - - 01/01/2006 PI & < 150cc ECE R40
11 011) 2W Motorcycle, L3& 
L4 ≥ 150cc Euro3, EDC, 
Option 1Motorcycle L3 & L4 2 (3) PI  / 4S 3 300 300% - - 2000 200% 150 188% 250% - - 01/01/2007 PI & ≥ 150ccECE R40 + 
EUDC (120 
km/h)
12 012) 2W Motorcycle, vmax, 
< 130 km/h, Euro3, 
WMTC, Option 1Motorcycle L3 & L4 2 (3) PI  / 4S 3 750 750% - - 2620 262% 170 213% 283% - - 01/01/2007 PI, < 130 km/h WMTC, ph1
13 013) 2W Motorcycles, 
vmax, ≥ 130 km/h, Euro3, 
WMTC, Option 1Motorcycle L3 & L4 2 (3) PI  / 4S 3 330 330% - - 2620 262% 220 275% 367% - - 01/01/2007 PI, ≥ 130 km/h WMTC, ph1
14 314) 2W Motorcycles, < 
130 km/h, Euro3, WMTC, 
2010, Option 4Motorcycle L3 & L4 2 (3) PI  / 4S [4] 630 630% - - 1570 157% 94 118% 157% - - 01/01/2010 PI, < 130 km/h WMTC, ph2
15 315) 2W Motorcycles, 
vmax, ≥ 130 km/h, Euro3, 
WMTC, 2010, Option 4Motorcycle L3 & L4 2 (3) PI  / 4S [4] 228 228% - - 1380 138% 110 138% 183% - - 01/01/2010 PI, 150-750 cc WMTC, ph2
16 216) 2W 2S Motorcycles, 
Euro4, 2012, < 130 km/h, 
Option 3Motorcycle L3 & L4 2 (3) PI  / 2S [4] - - 691 432% 1965 197% - - - - - [01/01/2012] PI, 2S, < 130 km/h WMTC, ph2
17 217) 2W 4S Motorcycles, 
Euro4, 2012, < 130 km/h, 
Option 3Motorcycle L3 & L4 2 (3) PI  / 4S [4] 563 563% - - 1965 197% 128 160% 213% - - [01/01/2012] PI, 4S, < 130 km/h WMTC, ph2
18 218) 2W 2S Motorcycles, 
Euro4, 2012,  ≥ 130 km/h, 
Option 3Motorcycle L3 & L4 2 (3) PI  / 2S [4] - - 413 258% 1965 197% - - - - - [01/01/2012] PI, 2S, ≥ 130 km/h WMTC, ph2
19 219) 2W 4S Motorcycles, 
Euro4, 2012,  ≥ 130 km/h, 
Option 3Motorcycle L3 & L4 2 (3) PI  / 4S [4] 248 248% - - 1965 197% 165 206% 275% - - [01/01/2012] PI, 4S, ≥ 130 km/h WMTC, ph2
20 220) 2W 2S Motorcycles, 
Euro 5, 2015, < 130 km/h, 
Option 3Motorcycle L3 & L4 2 (3) PI  / 2S [5] - - 443 277% 570 57% - - - - - [01/01/2015] PI, 2S, < 130 km/h WMTC, ph2
21 221) 2W 4S Motorcycles, 
Euro 5, 2015, < 130 km/h, 
Option 3Motorcycle L3 & L4 2 (3) PI  / 4S [5] 375 375% - - 1139.7 114% 68 85% 113% - - [01/01/2015] PI, 4S, < 130 km/h WMTC, ph2
22 222) 2W 2S Motorcycles, 
Euro 5, 2015, ≥ 130 km/h, 
Option 3Motorcycle L3 & L4 2 (3) PI  / 2S [5] - - 253 158% 1140 114% - - - - - [01/01/2015] PI, 2S, ≥ 130 km/h WMTC, ph2
23 223) 2W 4S Motorcycles, 
Euro 5, 2015, ≥ 130 km/h, 
Option 3Motorcycle L3 & L4 2 (3) PI  / 4S [5] 165 165% - - 1140 114% 88 110% 147% - - [01/01/2015] PI, 4S, ≥ 130 km/h WMTC, ph2
24 424) 2W & 3W 
Motorcycles, Euro4, 2013, 
WMTC, Option 5 Motorcycle & 
TricycleL3 & L4 & 
L52 (3) PI & CI  / 4S [4] 165 165% - - 1140 114% 88 110% 147% 25 500% 01/01/2013 PI & CI, PM for CI only WMTC, ph2
25 425) 2W & 3W 
Motorcycles, Euro5, 2016, 
WMTC, Option 5 Motorcycle & 
TricycleL3 & L4 & 
L52 (3) PI & CI / 4S [5] 100 100% - - 1000 100% 60 75% 100% 5 100% 01/01/2016 PI & CI, PM for CI only WMTC, ph2
Ref.Reference PI   Passenger 
Car, M1, PI, Euro5Passenger Car M1 4 PI  / 4S 5 100 100% 160 100% 1000 100% 60 75% 100% 5 100% 01/09/2011 PI NEDC
 
Table 48: Overview current, proposed and bench mark emission limits for 2 wheel motorcycles (classes L3e & L4e) 
 
EN 79   EN Class L3&L4, 2-wheel Motorcycle (with and without sidecar), overview current and proposed limits 
[% of Euro5  M1 PI Passenger Car threshold]
165%
100%
100%200%
200%
262%
262%
157%
138%
197%
197%
197%
197%
57%
114%
114%
114%114%
100%
100%183%
113%
147%
100%
100%100%165%563%
375%248%228%630%330%750%300%800%
277%432%
158%258%
147%275%213%367%250%
250%
283%
157%
500%
0%100%200%300%400%500%600%700%800%900%1000%
10) 2W Motorcycle, <
150cc, Euro3, EDC,
Option 1
11) 2W Motorcycle, L3&
L4 ≥ 150cc Euro3, EDC,
Option 1
12) 2W Motorcycle, vmax,
< 130 km/h, Euro3,
WMTC, Option 1
13) 2W Motorcycles,
vmax, ≥ 130 km/h, Euro3,
WMTC, Option 1
14) 2W Motorcycles, <
130 km/h, Euro3, WMTC,
2010, Option 4
15) 2W Motorcycles,
vmax, ≥ 130 km/h, Euro3,
WMTC, 2010, Option 4
16) 2W 2S Motorcycles,
Euro4, 2012, < 130 km/h,
Option 3
17) 2W 4S Motorcycles,
Euro4, 2012, < 130 km/h,
Option 3
18) 2W 2S Motorcycles,
Euro4, 2012,  ≥ 130 km/h,
Option 3
19) 2W 4S Motorcycles,
Euro4, 2012,  ≥ 130 km/h,
Option 3
20) 2W 2S Motorcycles,
Euro 5, 2015, < 130 km/h,
Option 3
21) 2W 4S Motorcycles,
Euro 5, 2015, < 130 km/h,
Option 3
22) 2W 2S Motorcycles,
Euro 5, 2015, ≥ 130 km/h,
Option 3
23) 2W 4S Motorcycles,
Euro 5, 2015, ≥ 130 km/h,
Option 3
24) 2W & 3W
Motorcycles, Euro4, 2013,
WMTC, Option 5 
25) 2W & 3W
Motorcycles, Euro5, 2016,
WMTC, Option 5 
Reference PI   Passenger
Car, M1, PI, Euro5 [% of Euro5  M1 PI Passenger Car threshold]
THC THC & NOx CO NOx PM (% of Euro5 veh.)
 
Figure 13: Overview current, proposed and bench mark emission limits for 2 wheel motorcycles (class L3e) and motorcycles with s idecar (class L4e) 
 
EN 80   EN Emission thresholds overview (ALL in mg / km or in %)
#Emission 
Scenario #Label graphs Vehicle Type CategoryNumber of 
wheelsEngine Type / 
Combustion 
CycleEuro 
level
THC THC 
(% of M1 
Euro5) THC & NOxTHC & NOx
(% of M1 
Euro5 veh.) COCO
(% of M1 
Euro5 
veh.) NOxNOx
(% of M1 
EU4 veh.)NOx
(% of M1 
Euro5 / 
EU6 veh.) PMPM (% of 
Euro5 
veh.)Approx. Type 
Approval entryClassification criteria 
&
Comments Test Cycle
26 026) 3W Motorcycles, PI, 
Euro2, EDC, Option 1Tricycle L5 3 PI  / 4S 2 1500 1500% - - 7000 700% 400 500% 667% - 01/01/2003 PI ECE R40
28 228) 3W Motorcycles PI, 
Euro 3, 2012, EDC, 
Option 3Tricycle L5 3 PI  / 4S [3] 1000 1000% - - 4000 400% 250 313% 417% - [01/01/2012] PI ECE R40
29 229) 3W Motorcycles, PI, 
Euro 4, 2015, EDC, 
Option 3Tricycle L5 3 PI  / 4S [4] 550 550% - - 2000 200% 250 313% 417% - [01/01/2015] PI ECE R40
24 424) 2W & 3W 
Motorcycles, Euro4, 2013, 
WMTC, Option 5 Motorcycle & 
TricycleL3 & L4 & 
L52 (3) PI & CI  / 4S [4] 165 165% - - 1140 114% 88 110% 147% 25 500% 01/01/2013 PI & CI, PM for CI only WMTC, ph2
25 425) 2W & 3W 
Motorcycles, Euro5, 2016, 
WMTC, Option 5 Motorcycle & 
TricycleL3 & L4 & 
L52 (3) PI & CI / 4S [5] 100 100% - - 1000 100% 60 75% 100% 5 100% 01/01/2016 PI & CI, PM for CI only WMTC, ph2
Ref.Reference PI   Passenger 
Car, M1, PI, Euro5Passenger Car M1 4 PI  / 4S 5 100 100% 160 100% 1000 100% 60 75% 100% 5 100% 01/09/2011 PI NEDC
27 027) 3W Motorcycles, CI, 
Euro2, EDC, Option 1Tricycle L5 3 CI  / 4S 2 1000 2000% - - 2000 400% 650 361% 361% - 01/01/2003 CI ECE R40
30 230) 3W Motorcycle CI, 
Euro 3, 2012, EDC, 
Option 3Tricycle L5 3 CI  / 4S [3] 150 300% - - 1000 200% 650 361% 361% 100 2000% [01/01/2012] CI ECE R40
31 231) 3W Motorcycles CI, 
Euro 4, 2015, EDC, 
Option 3Tricycle L5 3 CI  / 4S [4] 100 200% - - 600 120% 550 306% 306% 80 1600% 01/01/2015 CI ECE R40
24 424) 2W & 3W 
Motorcycles, Euro4, 2013, 
WMTC, Option 5 Motorcycle & 
TricycleL3 & L4 & 
L52 (3) PI & CI  / 4S [4] 165 165% - - 1140 114% 88 110% 147% 25 500% 01/01/2013 PI & CI, PM for CI only WMTC, ph2
25 425) 2W & 3W 
Motorcycles, Euro5, 2016, 
WMTC, Option 5 Motorcycle & 
TricycleL3 & L4 & 
L52 (3) PI & CI / 4S [5] 100 100% - - 1000 100% 60 75% 100% 5 100% 01/01/2016 PI & CI, PM for CI only WMTC, ph2
Ref.Reference CI   Passenger 
Car, M1, CI, Euro5Passenger Car M1 4 CI  / 4S 5 50 100% 230 100% 500 100% 180 100% 100% 5 100% 01/09/2011 CI NEDC
 
Table 49: Overview current, proposed and bench mark emission limits for 3 wheel motorcycles (Tricycles, class L5e) 
 
EN 81   EN Class L5, 3-wheel Motorcycle (Tricycle), overview current and proposed limits
 [% of EU5  M1 PI / CI Passenger Car threshold]
300%
200%
100%700%
400%
200%
114%
100%
100%
400%
200%
120%
114%
100%
100%100%
361%
361%
306%
147%
100%
100%500%
100%
100%100%100%165%100%100%165%550%1000%
147%667%
417%
417%
100%500%
100%
100%
0%100%200%300%400%500%600%700%800%900%1000%
26) 3W Motorcycles, PI,
Euro2, EDC, Option 1
28) 3W Motorcycles PI,
Euro 3, 2012, EDC,
Option 3
29) 3W Motorcycles, PI,
Euro 4, 2015, EDC,
Option 3
24) 2W & 3W
Motorcycles, Euro4,
2013, WMTC, Option 5 
25) 2W & 3W
Motorcycles, Euro5,
2016, WMTC, Option 5 
Reference PI  
Passenger Car, M1, PI,
Euro5
27) 3W Motorcycles, CI,
Euro2, EDC, Option 1
30) 3W Motorcycle CI,
Euro 3, 2012, EDC,
Option 3
31) 3W Motorcycles CI,
Euro 4, 2015, EDC,
Option 3
24) 2W & 3W
Motorcycles, Euro4,
2013, WMTC, Option 5 
25) 2W & 3W
Motorcycles, Euro5,
2016, WMTC, Option 5 
Reference CI  
Passenger Car, M1, CI,
Euro5 [% of EU5  M1 PI / CI Passenger Car threshold]
THC THC & NOx CO NOx PM (% of Euro5 veh.)1500
2000%
1600%
1600%
 
Figure 14: Overview current, proposed and bench mark emission limits for 3 wheel motorcycles (Tricycles, class L5e) 
 
EN 82   EN Emission thresholds overview (ALL in mg / km or in %)
#Emission 
Scenario #Label graphs Vehicle Type CategoryNumber of 
wheelsEngine Type / 
Combustion 
CycleEuro 
level
THC THC 
(% of M1 
Euro5) THC & NOxTHC & NOx
(% of M1 
Euro5 veh.) COCO
(% of M1 
Euro5 
veh.) NOxNOx
(% of M1 
EU4 veh.)NOx
(% of M1 
Euro5 / 
EU6 veh.) PMPM (% of 
Euro5 
veh.)Approx. Type 
Approval entryClassification criteria 
&
Comments Test Cycle
32 032) 4W, Light 
Quadricycle, Euro2, 
Option 1Light Quadricycle L6 4 PI  / 4S 2 - - 1200 750% 3500 350% - - - - - 01/01/2003 PI & <50cc ECE R47
33 233) 4W, Light 
Quadricycle, Euro 3, 
2012, Option 3 Light Quadricycle L6 4 PI  / 4S [3] - - 1200 750% 3500 350% - - - - - [01/01/2012] PI & <50ccECE R47 & 
cold
34 234) 4W, Light 
Quadricycle, Euro 4, 
2015, Option 3 Light Quadricycle L6 4 PI  / 4S [4] - - 900 563% 1900 190% - - - - - [01/01/2015] PI & <50ccECE R47 & 
cold
35 435) 4W, Light 
Quadricycle, Euro3, PI, 
2013, Option 5Light Quadricycle L6 4 PI & CI  / 4S [3] 165 165% - - 1140 114% 88 110% 147% - - 01/01/2013 PI & <50ccECE R47 & 
cold
36 436) 4W, Light 
Quadricycle, Euro4, PI, 
2016, Option 5Light Quadricycle L6 4 PI & CI  / 4S [4] 100 100% - - 1000 100% 60 75% 100% - - 01/01/2016 PI & <50ccWMTC, 
adapted
Ref.Reference PI   Passenger 
Car, M1, PI, Euro5Passenger Car M1 4 PI  / 4S 5 100 100% 160 100% 1000 100% 60 75% 100% 5 100% 01/09/2011 PI NEDC
37 037) 4W, Heavy 
Quadricycle, Euro2, PI, 
Option 1Heavy 
QuadricycleL7 4 PI  / 4S 2 1500 1500% - - 7000 700% 400 500% 667% - - 01/01/2003 PI ECE R40
39 239) 4W, Heavy 
Quadricycle, Euro 3, PI, 
2012, Option 3Heavy 
QuadricycleL7 4 PI  / 4S [3] 1000 1000% - - 4000 400% 250 313% 417% - - [01/01/2012] PI ECE R40
41 241) 4W, Heavy 
Quadricycle, Euro 4, PI, 
2015, Option 3Heavy 
QuadricycleL7 4 PI  / 4S [4] 550 550% - - 2000 200% 250 313% 417% - - [01/01/2015] PI ECE R40
43 443) 4W, Heavy 
Quadricycle, Euro3, PI, 
2013, Option 5Heavy 
QuadricycleL7 4 PI / 4S [3] 165 165% - - 1140 114% 88 110% 147% - - 01/01/2013 PI WMTC ph2
44 444) 4W, Heavy 
Quadricycle, Euro4, PI, 
2016, Option 5Heavy 
QuadricycleL7 4 PI & CI / 4S [4] 100 100% - - 1000 100% 60 75% 100% - - 01/01/2016 PI WMTC ph2
Ref.Reference PI   Passenger 
Car, M1, PI, Euro5Passenger Car M1 4 PI  / 4S 5 100 100% 160 100% 1000 100% 60 75% 100% 5 100% 01/09/2011 PI NEDC
38 038) 4W, Heavy 
Quadricycle, Euro2, CI, 
Option 1Heavy 
QuadricycleL7 4 CI  / 4S 2 1000 2000% - - 2000 400% 650 361% 361% - - 01/01/2003 CI ECE R40
40 240) 4W, Heavy 
Quadricycle, Euro 3, 
Option 3 , CI, 2012, 
Option 3Heavy 
QuadricycleL7 4 CI  / 4S [3] 150 300% - - 1000 200% 650 361% 361% 100 2000% [01/01/2012] CI ECE R40
42 242) 4W, Heavy 
Quadricycle, Euro 4, CI, 
2015, Option 3Heavy 
QuadricycleL7 4 CI  / 4S [4] 100 200% - - 600 120% 550 306% 306% 80 1600% [01/01/2015] CI ECE R40
45 445) 4W, Heavy 
Quadricycle, Euro3, CI, 
2013, Option 5Heavy 
QuadricycleL7 4 CI  / 4S [3] - - 300 130% 1000 200% 250 139% 139% 25 500% 01/01/2013 CI WMTC ph2
46 446) 4W, Heavy 
Quadricycle, Euro4, CI, 
2016, Option 5Heavy 
QuadricycleL7 4 CI  / 4S [4] - - 230 100% 500 100% 180 100% 100% 5 100% 01/01/2016 CI WMTC ph2
Ref.Reference CI   Passenger 
Car, M1, CI, Euro5Passenger Car M1 4 CI  / 4S 5 50 100% 230 100% 500 100% 180 100% 100% 5 100% 01/09/2011 CI NEDC 
Table 50: Overview current, proposed and bench mark emission limits for Light quadricycles (class L6e) and heavy Quadricycles ( class L7e) 
 
EN 83   EN Class L6, Light Quadricycle, overview current and proposed limits
 [% of Euro5  M1 PI  Passenger Car threshold]750%
750%350%
350%
190%
114%
100%
100%100%100%165%563%
100%100%
100%
0%100%200%300%400%500%600%700%800%900%1000%
32) 4W, Light
Quadricycle, Euro2,
Option 1
33) 4W, Light
Quadricycle, Euro 3,
2012, Option 3 
34) 4W, Light
Quadricycle, Euro 4,
2015, Option 3 
35) 4W, Light
Quadricycle, Euro3, PI,
2013, Option 5
36) 4W, Light
Quadricycle, Euro4, PI,
2016, Option 5
Reference PI  
Passenger Car, M1, PI,
Euro5 [% of Euro5  M1 PI Passenger Car threshold]
THC THC & NOx CO NOx PM (% of Euro5 veh.)
 
Figure 15: Overview current, proposed and bench mark emission limits for Light quadricycles (class L6e) 
 
EN 84   EN L7, Heavy Quadricycle, overview current and proposed thresholds
300%
130%
100%
100%700%
400%
200%
114%
100%
100%
400%
200%
120%
200%
100%
100%361%
306%1000%
550%
165%
100%
100%
100%(100%)667%
361%100%100%147%417%417%
139%
100%
100%500%100%
0%100%200%300%400%500%600%700%800%900%1000%
37) 4W, Heavy
Quadricycle, Euro2, PI,
Option 1
39) 4W, Heavy
Quadricycle, Euro 3, PI,
2012, Option 3
41) 4W, Heavy
Quadricycle, Euro 4, PI,
2015, Option 3
43) 4W, Heavy
Quadricycle, Euro3, PI,
2013, Option 5
44) 4W, Heavy
Quadricycle, Euro4, PI,
2016, Option 5
Reference PI  
Passenger Car, M1, PI,
Euro5
38) 4W, Heavy
Quadricycle, Euro2, CI,
Option 1
40) 4W, Heavy
Quadri cycle, Euro 3,
Option 3 , CI, 2012,
Option 3
42) 4W, Heavy
Quadricycle, Euro 4, CI,
2015, Option 3
45) 4W, Heavy
Quadricycle, Euro3, CI,
2013, Option 5
46) 4W, Heavy
Quadricycle, Euro4, CI,
2016, Option 5
Reference CI  
Passenger Car, M1, CI,
Euro5[mg/km]
THC THC & NOx CO NOx PM (% of Euro5 veh.)1500
2000%
2000%
1600%
 
Figure 16: Overview current, proposed and bench mark emission limits for Heavy quadricycles (class L7e) 
For comparison reasons the following graphs show the Total HydroC arbons (THC), Carbon Monoxide (CO), NOx (Nitrogen Oxides) and Particulate Matter (PM) 
emissions across all L-category v ehicle emissions as a percentage of  Euro5 passenger car limits (100  %). The next graphs contain current, proposed and 
benchmark M1 passenger car limits for all L-category vehicle categories. 
 
EN 85   EN Total HydroCarbons (THC) thresholds [% of Euro5 M1 PI / CI Passenger Car threshold]
165%
100%
800%
300%
750%
330%
630%
228%
165%
100%
1500%
2000%
1000%
100%
1500%
2000%
1000%
300%
550%
100%
100%
100%
100%
100%
180%165%165%375%248%
165%200%200%300%550%563%
0%200%400%600%800%1000%1200%1400%1600%1800%2000%
1) 2W Mopeds, Euro2, Option 1
2) 2W Mopeds, Euro3, cold weighting, 2010, Option 23) 2W Mopeds, Euro3, cold weighting, 2012, Option 34) 2W Mopeds, Euro4, cold weighting, 2015, Option 3
5) 3W Mopeds, Euro2, Option 1
6) 3W Mopeds, Euro3, cold weighting, 2012, Option 3
7) 3W Mopeds, Euro4, cold weighting, 2015, Option 3 
8) 2W&3W Mopeds, Euro3, cold weighting, 2013, Option 5 9) 2W&3W Mopeds, Euro4, cold weighting, 2016, Option 5 
10) 2W Motorcycle, < 150cc, Euro3, EDC, Option 1
11) 2W Motorcycle, L3& L4 ≥ 150cc Euro3, EDC, Option 1
12) 2W Motorcycle, vmax, < 130 km/h, Euro3, WMTC, Option
113) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3, WMTC, Option
114) 2W Motorcycles, < 130 km/h, Euro3, WMTC, 2010, Option
415) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3, WMTC, 2010,
Option 4
16) 2W 2S Motorcycles, Euro4, 2012, < 130 km/h, Option 3
17) 2W 4S Motorcycles, Euro4, 2012, < 130 km/h, Option 3
18) 2W 2S Motorcycles, Euro4, 2012,  ≥ 130 km/h, Option 3
19) 2W 4S Motorcycles, Euro4, 2012,  ≥ 130 km/h, Option 3
20) 2W 2S Motorcycles, Euro 5, 2015, < 130 km/h, Option 321) 2W 4S Motorcycles, Euro 5, 2015, < 130 km/h, Option 3
22) 2W 2S Motorcycles, Euro 5, 2015, ≥ 130 km/h, Option 3
23) 2W 4S Motorcycles, Euro 5, 2015, ≥ 130 km/h, Option 3
24) 2W & 3W Motorcycles, Euro4, 2013, WMTC, Option 5 
25) 2W & 3W Motorcycles, Euro5, 2016, WMTC, Option 5 
26) 3W Motorcycles, PI, Euro2, EDC, Option 1
27) 3W Motorcycles, CI, Euro2, EDC, Option 1
28) 3W Motorcycles PI, Euro 3, 2012, EDC, Option 3
29) 3W Motorcycles, PI, Euro 4, 2015, EDC, Option 3
30) 3W Motorcycle CI, Euro 3, 2012, EDC, Option 3
31) 3W Motorcycles CI, Euro 4, 2015, EDC, Option 3
32) 4W, Light Quadricycle, Euro2, Option 1
33) 4W, Light Quadricycle, Euro 3, 2012, Option 3 34) 4W, Light Quadricycle, Euro 4, 2015, Option 3 
35) 4W, Light Quadricycle, Euro3, PI, 2013, Option 536) 4W, Light Quadricycle, Euro4, PI, 2016, Option 5
37) 4W, Heavy Quadricycle, Euro2, PI, Option 1
38) 4W, Heavy Quadricycle, Euro2, CI, Option 1
39) 4W, Heavy Quadricycle, Euro 3, PI, 2012, Option 3
40) 4W, Heavy Quadricycle, Euro 3, Option 3 , CI, 2012,
Option 3
41) 4W, Heavy Quadricycle, Euro 4, PI, 2015, Option 3
42) 4W, Heavy Quadricycle, Euro 4, CI, 2015, Option 3
43) 4W, Heavy Quadricycle, Euro3, PI, 2013, Option 5
44) 4W, Heavy Quadricycle, Euro4, PI, 2016, Option 5
45) 4W, Heavy Quadricycle, Euro3, CI, 2013, Option 546) 4W, Heavy Quadricycle, Euro4, CI, 2016, Option 5
Passenger Car, M1, PI, Euro4
Reference PI   Passenger Car, M1, PI, Euro5
Passenger Car, M1, PI, Euro6
Passenger Car, M1, CI, Euro4
Reference CI   Passenger Car, M1, CI, Euro5
Passenger Car, M1, CI, Euro6THC thresholds [% of Euro5 M1 PI / CI Passenger Car threshold]
 
Figure 17: Overview current, proposed emission limits for all L-category vehicle categories vs. passenger car M1 benchmark limi ts: Total HydroCarbons (THC 
 
EN 86   EN THC & Nox thresholds  [% of Euro5 M1 PI Passenger Car 'Threshold']
(Reference based on calculated, non legislated threshold of PI engine, composed by sum of THC + NOx)750%
750%
750%
100%
113%
100%100%
100%
100%
74%500%
750%750%
563%
432%
258%
277%
158%
750%
750%
563%
130%
0%100%200%300%400%500%600%700%800%900%1000%
1) 2W Mopeds, Euro2, Option 1
2) 2W Mopeds, Euro3, cold weighting, 2010, Option 23) 2W Mopeds, Euro3, cold weighting, 2012, Option 34) 2W Mopeds, Euro4, cold weighting, 2015, Option 3
5) 3W Mopeds, Euro2, Option 1
6) 3W Mopeds, Euro3, cold weighting, 2012, Option 3
7) 3W Mopeds, Euro4, cold weighting, 2015, Option 3 
8) 2W&3W Mopeds, Euro3, cold weighting, 2013,9) 2W&3W Mopeds, Euro4, cold weighting, 2016,
10) 2W Motorcycle, < 150cc, Euro3, EDC, Option 1
11) 2W Motorcycle, L3& L4 ≥ 150cc Euro3, EDC,
12) 2W Motorcycle, vmax, < 130 km/h, Euro3, WMTC,
13) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3,
14) 2W Motorcycles, < 130 km/h, Euro3, WMTC,
15) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3,
16) 2W 2S Motorcycles, Euro4, 2012, < 130 km/h,
17) 2W 4S Motorcycles, Euro4, 2012, < 130 km/h,
18) 2W 2S Motorcycles, Euro4, 2012,  ≥ 130 km/h,
19) 2W 4S Motorcycles, Euro4, 2012,  ≥ 130 km/h,
20) 2W 2S Motorcycles, Euro 5, 2015, < 130 km/h,
21) 2W 4S Motorcycles, Euro 5, 2015, < 130 km/h,
22) 2W 2S Motorcycles, Euro 5, 2015, ≥ 130 km/h,
23) 2W 4S Motorcycles, Euro 5, 2015, ≥ 130 km/h,
24) 2W & 3W Motorcycles, Euro4, 2013, WMTC,
25) 2W & 3W Motorcycles, Euro5, 2016, WMTC,
26) 3W Motorcycles, PI, Euro2, EDC, Option 1
27) 3W Motorcycles, CI, Euro2, EDC, Option 1
28) 3W Motorcycles PI, Euro 3, 2012, EDC, Option 3
29) 3W Motorcycles, PI, Euro 4, 2015, EDC, Option 3
30) 3W Motorcycle CI, Euro 3, 2012, EDC, Option 3
31) 3W Motorcycles CI, Euro 4, 2015, EDC, Option 3
32) 4W, Light Quadricycle, Euro2, Option 1
33) 4W, Light Quadricycle, Euro 3, 2012, Option 3 
34) 4W, Light Quadricycle, Euro 4, 2015, Option 3 
35) 4W, Light Quadri cycle, Euro3, PI, 2013, Option 5
36) 4W, Light Quadri cycle, Euro4, PI, 2016, Option 5
37) 4W, Heavy Quadricycle, Euro2, PI, Option 1
38) 4W, Heavy Quadricycle, Euro2, CI, Option 1
39) 4W, Heavy Quadricycle, Euro 3, PI, 2012, Option 3
40) 4W, Heavy Quadricycle, Euro 3, Option 3 , CI,
41) 4W, Heavy Quadricycle, Euro 4, PI, 2015, Option 3
42) 4W, Heavy Quadricycle, Euro 4, CI, 2015, Option 3
43) 4W, Heavy Quadricycle, Euro3, PI, 2013, Option 544) 4W, Heavy Quadricycle, Euro4, PI, 2016, Option 5
45) 4W, Heavy Quadricycle, Euro3, CI, 2013, Option 5
46) 4W, Heavy Quadricycle, Euro4, CI, 2016, Option 5
Passenger Car, M1, PI, Euro4
Reference PI   Passenger Car, M1, PI, Euro5
Passenger Car, M1, PI, Euro6
Passenger Car, M1, CI, Euro4
Reference CI   Passenger Car, M1, CI, Euro5
Passenger Car, M1, CI, Euro6THC & NOx [% of  Euro5 M1 PI / CI Passenger Car threshold]
 
Figure 18: Overview current, proposed emission limits for all L-category vehicle categories vs. passenger car M1 benchmark limi ts: Total HydroCarbons (THC) 
NB. The euro5 reference value for PI engines were arithmetically  determined by adding up the separate THC and NOx limits. This was only done to show the order 
of magnitude and should not be interpreted as absolute limit com parison, unlike the euro5 Diesel passenger car M1 limits, which  actually consists of a combined 
THC&NOx limit and a separate NOx limit. 
 
EN 87   EN CO thresholds  [% of Euro5 M1 PI / CI Passenger Car threshold]100%
100%
100%
100%
350%
350%
190%
114%
100%
200%
200%
262%
262%
157%
138%
197%
197%
197%
57%
114%
114%114%
114%
100%
400%
400%
200%
200%
120%
350%
350%
190%
114%
100%
400%
400%
200%
200%
120%
114%
100%
200%
100%
100%
100%
100%100%
100%
100%197%
0%100%200%300%400%
1) 2W Mopeds, Euro2, Option 1
2) 2W Mopeds, Euro3, cold weighting,3) 2W Mopeds, Euro3, cold weighting,
4) 2W Mopeds, Euro4, cold weighting,
5) 3W Mopeds, Euro2, Option 1
6) 3W Mopeds, Euro3, cold weighting,
7) 3W Mopeds, Euro4, cold weighting,
8) 2W&3W Mopeds, Euro3, cold
9) 2W&3W Mopeds, Euro4, cold
10) 2W Motorcycle, < 150cc, Euro3,
11) 2W Motorcycle, L3& L4 ≥ 150cc
12) 2W Motorcycle, vmax, < 130 km/h,
13) 2W Motorcycles, vmax, ≥ 130
14) 2W Motorcycles, < 130 km/h,
15) 2W Motorcycles, vmax, ≥ 130
16) 2W 2S Motorcycles, Euro4, 2012, <
17) 2W 4S Motorcycles, Euro4, 2012, <
18) 2W 2S Motorcycles, Euro4, 2012, 19) 2W 4S Motorcycles, Euro4, 2012, 
20) 2W 2S Motorcycles, Euro 5, 2015,
21) 2W 4S Motorcycles, Euro 5, 2015,22) 2W 2S Motorcycles, Euro 5, 2015,
23) 2W 4S Motorcycles, Euro 5, 2015,
24) 2W & 3W Motorcycles, Euro4,
25) 2W & 3W Motorcycles, Euro5,
26) 3W Motorcycles, PI, Euro2, EDC,
27) 3W Motorcycles, CI, Euro2, EDC,
28) 3W Motorcycles PI, Euro 3, 2012,
29) 3W Motorcycles, PI, Euro 4, 2015,
30) 3W Motorcycle CI, Euro 3, 2012,
31) 3W Motorcycles CI, Euro 4, 2015,
32) 4W, Light Quadricycle, Euro2,
33) 4W, Light Quadricycle, Euro 3,
34) 4W, Light Quadricycle, Euro 4,
35) 4W, Light Quadricycle, Euro3, PI,36) 4W, Light Quadricycle, Euro4, PI,
37) 4W, Heavy Quadricycle, Euro2, PI,
38) 4W, Heavy Quadricycle, Euro2, CI,
39) 4W, Heavy Quadricycle, Euro 3,
40) 4W, Heavy Quadricycle, Euro 3,
41) 4W, Heavy Quadricycle, Euro 4,
42) 4W, Heavy Quadricycle, Euro 4,
43) 4W, Heavy Quadricycle, Euro3, PI,
44) 4W, Heavy Quadricycle, Euro4, PI,
45) 4W, Heavy Quadricycle, Euro3, CI,
46) 4W, Heavy Quadricycle, Euro4, CI,
Passenger Car, M1, PI, Euro4
Reference PI   Passenger Car, M1, PI,
Passenger Car, M1, PI, Euro6
Passenger Car, M1, CI, Euro4
Reference CI   Passenger Car, M1, CI,
Passenger Car, M1, CI, Euro6CO  [% of Euro5 M1 PI / CI Passenger Car threshold]
700%700%
 
Figure 19: Overview current, proposed emission limits for all L-category vehicle categories vs. passenger car M1 benchmark limi ts: Carbon Monoxide (CO)  
 
EN 88   EN NOx thresholds   [% of Euro5  M1 PI / CI Passenger Car threshold]147%
100%
250%
250%
283%
183%
147%
100%
667%
361%
417%
100%
667%
361%
417%
361%
417%
306%
147%
100%
139%
100%
133%
100%
100%
100%
44%147%147%113%275%213%
100%306%361%417%157%367%
0%100%200%300%400%500%600%700%
1) 2W Mopeds, Euro2, Option 1
2) 2W Mopeds, Euro3, cold weighting, 2010, Option 23) 2W Mopeds, Euro3, cold weighting, 2012, Option 3
4) 2W Mopeds, Euro4, cold weighting, 2015, Option 3
5) 3W Mopeds, Euro2, Option 1
6) 3W Mopeds, Euro3, cold weighting, 2012, Option 3
7) 3W Mopeds, Euro4, cold weighting, 2015, Option 3 
8) 2W&3W Mopeds, Euro3, cold weighting, 2013,
9) 2W&3W Mopeds, Euro4, cold weighting, 2016,
10) 2W Motorcycle, < 150cc, Euro3, EDC, Option 1
11) 2W Motorcycle, L3& L4 ≥ 150cc Euro3, EDC,
12) 2W Motorcycle, vmax, < 130 km/h, Euro3, WMTC,
13) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3, WMTC,
14) 2W Motorcycles, < 130 km/h, Euro3, WMTC, 2010,
15) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3, WMTC,
16) 2W 2S Motorcycles, Euro4, 2012, < 130 km/h,
17) 2W 4S Motorcycles, Euro4, 2012, < 130 km/h,
18) 2W 2S Motorcycles, Euro4, 2012,  ≥ 130 km/h,
19) 2W 4S Motorcycles, Euro4, 2012,  ≥ 130 km/h,
20) 2W 2S Motorcycles, Euro 5, 2015, < 130 km/h,
21) 2W 4S Motorcycles, Euro 5, 2015, < 130 km/h,
22) 2W 2S Motorcycles, Euro 5, 2015, ≥ 130 km/h,
23) 2W 4S Motorcycles, Euro 5, 2015, ≥ 130 km/h,
24) 2W & 3W Motorcycles, Euro4, 2013, WMTC,
25) 2W & 3W Motorcycles, Euro5, 2016, WMTC,
26) 3W Motorcycles, PI, Euro2, EDC, Option 1
27) 3W Motorcycles, CI, Euro2, EDC, Option 1
28) 3W Motorcycles PI, Euro 3, 2012, EDC, Option 3
29) 3W Motorcycles, PI, Euro 4, 2015, EDC, Option 3
30) 3W Motorcycle CI, Euro 3, 2012, EDC, Option 3
31) 3W Motorcycles CI, Euro 4, 2015, EDC, Option 3
32) 4W, Light Quadricycle, Euro2, Option 1
33) 4W, Light Quadricycle, Euro 3, 2012, Option 3 
34) 4W, Light Quadricycle, Euro 4, 2015, Option 3 
35) 4W, Light Quadricycle, Euro3, PI, 2013, Option 536) 4W, Light Quadricycle, Euro4, PI, 2016, Option 5
37) 4W, Heavy Quadricycle, Euro2, PI, Option 1
38) 4W, Heavy Quadri cycle, Euro2, CI, Option 1
39) 4W, Heavy Quadri cycle, Euro 3, PI, 2012, Option 3
40) 4W, Heavy Quadri cycle, Euro 3, Option 3 , CI,
41) 4W, Heavy Quadri cycle, Euro 4, PI, 2015, Option 3
42) 4W, Heavy Quadricycle, Euro 4, CI, 2015, Option 3
43) 4W, Heavy Quadricycle, Euro3, PI, 2013, Option 5
44) 4W, Heavy Quadricycle, Euro4, PI, 2016, Option 5
45) 4W, Heavy Quadri cycle, Euro3, CI, 2013, Option 5
46) 4W, Heavy Quadri cycle, Euro4, CI, 2016, Option 5
Passenger Car, M1, PI, Euro4
Reference PI   Passenger Car, M1, PI, Euro5
Passenger Car, M1, PI, Euro6
Passenger Car, M1, CI, Euro4
Reference CI   Passenger Car, M1, CI, Euro5
Passenger Car, M1, CI, Euro6NOx Thresholds  [% of Euro5 M1 PI  / CI Passenger Car threshold]
 
Figure 20: Overview current, proposed emission limits for all L-category vehicle categories vs. passenger car M1 benchmark limi ts: Nitrogen Oxides (NOx)  
 
EN 89   EN PM thresholds [% of Euro5 M1 PI  / CI Passenger Car threshold]
500%
100%
500%
100%
100%
100%
100%
100%
012345678910
1) 2W Mopeds, Euro2, Option 1
2) 2W Mopeds, Euro3, cold weighting, 2010, Option
3) 2W Mopeds, Euro3, cold weighting, 2012, Option
4) 2W Mopeds, Euro4, cold weighting, 2015, Option
5) 3W Mopeds, Euro2, Option 1
6) 3W Mopeds, Euro3, cold weighting, 2012, Option7) 3W Mopeds, Euro4, cold weighting, 2015, Option
8) 2W&3W Mopeds, Euro3, cold weighting, 2013,
9) 2W&3W Mopeds, Euro4, cold weighting, 2016,
10) 2W Motorcycle, < 150cc, Euro3, EDC, Option 1
11) 2W Motorcycle, L3& L4 ≥ 150cc Euro3, EDC,
12) 2W Motorcycle, vmax, < 130 km/h, Euro3,
13) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3,
14) 2W Motorcycles, < 130 km/h, Euro3, WMTC,
15) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3,
16) 2W 2S Motorcycles, Euro4, 2012, < 130 km/h,
17) 2W 4S Motorcycles, Euro4, 2012, < 130 km/h,
18) 2W 2S Motorcycles, Euro4, 2012,  ≥ 130 km/h,
19) 2W 4S Motorcycles, Euro4, 2012,  ≥ 130 km/h,
20) 2W 2S Motorcycles, Euro 5, 2015, < 130 km/h,
21) 2W 4S Motorcycles, Euro 5, 2015, < 130 km/h,
22) 2W 2S Motorcycles, Euro 5, 2015, ≥ 130 km/h,
23) 2W 4S Motorcycles, Euro 5, 2015, ≥ 130 km/h,
24) 2W & 3W Motorcycles, Euro4, 2013, WMTC,
25) 2W & 3W Motorcycles, Euro5, 2016, WMTC,
26) 3W Motorcycles, PI, Euro2, EDC, Option 1
27) 3W Motorcycles, CI, Euro2, EDC, Option 1
28) 3W Motorcycles PI, Euro 3, 2012, EDC, Option 3
29) 3W Motorcycles, PI, Euro 4, 2015, EDC, Option
30) 3W Motorcycle CI, Euro 3, 2012, EDC, Option 3
31) 3W Motorcycles CI, Euro 4, 2015, EDC, Option 3
32) 4W, Light Quadri cycle, Euro2, Option 1
33) 4W, Light Quadricycle, Euro 3, 2 012, Option 3 
34) 4W, Light Quadricycle, Euro 4, 2 015, Option 3 
35) 4W, Light Quadricycle, Euro3, PI, 2013, Option 5
36) 4W, Light Quadricycle, Euro4, PI, 2016, Option 5
37) 4W, Heavy Quadri cycle, Euro2, PI, Option 1
38) 4W, Heavy Quadri cycle, Euro2, CI, Option 1
39) 4W, Heavy Quadri cycle, Euro 3, PI, 2012, Option
40) 4W, Heavy Quadricycle, Euro 3, Option 3 , CI,
41) 4W, Heavy Quadri cycle, Euro 4, PI, 2015, Option
42) 4W, Heavy Quadricycle, Euro 4, CI, 2015, Option
43) 4W, Heavy Quadricycle, Euro3, PI, 2013, Option
44) 4W, Heavy Quadricycle, Euro4, PI, 2016, Option
45) 4W, Heavy Quadri cycle, Euro3, CI, 2013, Option
46) 4W, Heavy Quadri cycle, Euro4, CI, 2016, Option
Passenger Car, M1, PI, Euro4
Reference PI   Passenger Car, M1, PI, Euro5
Passenger Car, M1, PI, Euro6
Passenger Car, M1, CI, Euro4
Reference CI   Passenger Car, M1, CI, Euro5
Passenger Car, M1, CI, Euro6PM [% of Euro5 M1 PI  / CI Passenger Car threshold]
2000%
1600%
2000%
1600%
1000%
 
Figure 21: Overview current, proposed emission limits for all L-category vehicle categories vs. passenger car M1 benchmark limi ts: Particulate Matter (PM) 
 
EN 90   EN 1.2. Qualitative analysis of the policy options to revise the emission limits 
Economical
EnvironmentalSafet
y
SocietalType of impact:
 
Emission reduction mandated for other means of road 
transport beyond 2020 will become marginal, if Mopeds 
and all other L-category vehicle type emissions not 
further reduced.Compliance cost of manufacturersOption 1: No change
Positive Negative Neutral  / Remarks
Extreme high share of hydrocarbons (HC) emitted by L-
category vehicles (rising to 62% of total in 2020 if no new 
measures applied) compared to other means of road 
transport. Same for CO (rising to over 30% of total in 
2020). High share of urban PM emissions. L-category 
vehicles only responsible for 3% of total vehicle mileage, 
therefore level of emissions not proportional to level of 
use.
 
Table 51: Analysis table policy options new emission limits, option 1 
 
Low cost scenario. With regard to HC and PM option 2 
appears as most cost-effective, but only 6,5% HC reduction 
achievable in 2020 leading to 60% of THC emission from all 
road transport in comparison to option 1, which would lead 
to 62% of total HC emissions from road transport. Minimised weaknesses and threads of the introduction of 
new emission limit values for L-category vehicles as 
identified in LAT report, ch. 3.3 (again listed under option 
3)All other categories of L-category vehicles which produce 
significant high emissions are not affected by the need to 
comply with lower limits. Current high overall pollution 
level for new L-category vehicles maintained. Adverse 
health and environmental effects by air pollution cannot 
be efficiently and effectively addressed. 
Scenario 1 achieves 2%, 7%, and 27% reduction in CO, 
HC, and PM respectively. NOx marginally increases.
Sensitivity study presented in MCWG of 29 June 09 
(EMISIA SA Report No: 09.RE.005.V2, Scenarios on the 
future regulation of Power Two Wheelers) showed that the 
threshold level has relatively little effect on total L-category 
vehicle emissions for the assessed timeframe until 2020. 
The speed of threshold introduction is the most important 
factor to reduce emissions on the mid to long term. Option 2 
can be fast introduced and is supported by the industry. If it 
would have been possible to extend the assessed 
timeframe up to 2030, this positive impact may have been a 
negative impactEmission reduction mandated for other means of road transport in 2020 will become marginal, if Mopeds and all 
other L-category vehicle type emissions not further 
reduced.Option 2: : New emission limits for L1 mopeds: a cold-start r47 test cycle and a 30% weighing factor for the cold start are pro posed to be applied. (Scenario 1 
from LAT report). No change in limits for other L-category vehicles.
Effect of Type Approval threshold reduction on the 
overall level of pollutants is marginal in comparison 
to the highly polluting L-category vehicle fleet. The 
average vehicle replacement timeframe is much 
longer as for e.g. passenger cars. It takes much 
longer before the effect of new vehicles, which 
pollute less, becomes effective. The other road 
transport vehicles had to comply already 10 years 
ago with relatively severe type approval thresholds. 
The benefit of this early adoption becomes obvious 
owing to the significant overall pollutant reduction of 
all other vehicles (refer to figure 3.1 to 3.5 of the 
LAT report, p59 - 61With minor modifications to the test cycle result analysis a 
fractional share of HC emissions can be reduced. Positive Negative
Only slight compliance cost increase for Moped 
manufacturers. For all other manufacturers no change in 
compliance cost compared to option 1.Neutral  / Remarks
 
Table 52: Analysis table policy options new emission limits, option 2 
 
EN 91   EN Positive Negative
Using the strength of new emission limit values for L-
category vehicles as identified in the LAT report (ch. 3.3):
- reduction of harmful atmospheric substances  (HC, NOx, 
CO, PM) that directly affect a large fraction of the population
- reduction of harmful species that contribute to the 
formation of photochemical pollution (HC, NOx)
- minor reduction of greenhouse-gas (mainly CO2) emissions
- reduction of visible smoke
The weaknesses of introducing new emissions as 
identified in the LAT report (ch. 3.3):
- costly measures with the cost transferred to the 
customers- generally, cost increases with increasing stringency of 
emission standards
- the emission threshold should have appeared earlier to 
maximize benefitPossible using the opportunities as identified in the LAT 
report ch. 3.3: 
- good environmental performance is a marketing asset for 
all products sold today. Improving emissions will also have a 
positive impact on PTWs’ image
- low CO2 vehicles are promoted and are increasingly 
desirable. Clean and efficient motorcycles are a very good 
candidate- emission standards from other vehicle categories become 
more stringent; this provides the ground to reduce 
emissions from PTWs as wellEmission reduction mandated for other means of road 
transport beyond 2020 may become marginal, if Mopeds 
and all other L-category vehicle type emissions not 
further reduced.
Additional possible impacts from SWOT analysis from LAT 
report (ch 3.3)
- products (motorcycles, mopeds, three and four wheelers) 
of superior quality withstanding global competition.
- possible generation of new jobs in suppliers of emission 
control systemsThe threads as identified in the LAT report (ch. 3.3): 
- small motorcycles and mini-cars are mostly sold due to 
their low price, while large motorcycles and ATVs are 
mainly used as recreational and not prime transport 
vehicles; hence PTWs market is inherently more 
sensitive to price increases; large price increases may 
lead to loss of jobs including SMEs (
- increasing cost may shift buyers to other vehicle 
classes (i.e. small cars); shift of the market to cars will 
increase congestion and greenhouse gas emissions. 
Shift to (small) diesel cars may also increase pollutant 
emissions
- increasing cost may also lead to less frequent PTWs 
replacement, hence degrading the rate of reducing 
emissions
- stringent emission standards may lead to loss of 
performance which is a marketing asset for motorcycles; 
hence increasing tampering practicesCurrent high overall pollution level for new L-category vehicles maintained as this can only be very little 
influenced by type approval compliance with low 
thresholds. Adverse health and environmental effects by 
air pollution cannot be efficiently and effectively 
addressed. 
Option 3 leads to 16%, 15%, 37% and 27% reductions in 
CO, HC, PM, and NOx, respectively. Effect of Type Approval threshold reduction on the 
overall level of pollutants is marginal in comparison 
to the highly polluting L-category vehicle fleet. The 
average vehicle replacement timeframe is much 
longer as for e.g. passenger cars. It takes much 
longer before the effect of new vehicles, which 
pollute less, becomes effective. The other road transport vehicles had to comply already 10 years 
ago with relatively severe type approval thresholds. 
The benefit of this early adoption becomes obvious 
owing to the significant overall pollutant reduction of 
all other vehicles (refer to figure 3.1 to 3.5 of the 
LAT report, p59 - 61Neutral  / RemarksOption 3: Motorcycle industry proposal (Scenario 2 from LAT report)
Sensitivity study presented in MCWG of 29 June 09 
(EMISIA SA Report No: 09.RE.005.V2, Scenarios on the 
future regulation of Power Two Wheelers) showed that the 
threshold level has relatively little effect on total L-category vehicle emissions for the assessed timeframe until 2020. 
The speed of threshold introduction is the most important 
factor to reduce emissions. Option 3 can be fast introduced 
and is supported by the industry (minimised implementation 
time anticipated).
 
Table 53: Analysis table policy options new emission limits, option 3 
 
EN 92   EN Option 4: New measures based on the Best Available Technology applied on L-category vehicles sold today in the market (Scenario  3 from LAT report)
Positive Negative Neutral  / Remarks
Using the strength of new emission limit values for L-
category vehicles as identified in the LAT report (ch. 3.3):
- reduction of harmful atmospheric substances  (HC, NOx, 
CO, PM) that directly affect a large fraction of the population
- reduction of harmful species that contribute to the 
formation of photochemical pollution (HC, NOx)
- minor reduction of greenhouse-gas (mainly CO2) 
emissions
- reduction of visible smoke.Current high overall pollution level for new L-category 
vehicles maintained as this can only be very little 
influenced by type approval compliance with low 
thresholds. Adverse health and environmental effects by 
air pollution cannot be efficiently and effectively 
addressed. 
Option 4 achieves reductions of 15%, 2% and 22% for 
CO, HC and NOx, respectively. No PM reduction could 
be assessed based on the available experimental data. Effect of Type Approval threshold reduction on the 
overall level of pollutants is marginal in comparison 
to the highly polluting L-category vehicle fleet. The 
average vehicle replacement timeframe is much 
longer as for e.g. passenger cars. It takes much 
longer before the effect of new vehicles, which 
pollute less, becomes effective. The other road 
transport vehicles had to comply already 10 years 
ago with relatively severe type approval thresholds. 
The benefit of this early adoption becomes obvious 
owing to the significant overall pollutant reduction of 
all other vehicles (refer to figure 3.1 to 3.5 of the 
LAT report, p59 - 61
Possible using the opportunities as identified in the LAT 
report ch. 3.3: 
- good environmental performance is a marketing asset for 
all products sold today. Improving emissions will also have a 
positive impact on PTWs’ image
- low CO2 vehicles are promoted and are increasingly 
desirable. Clean and efficient motorcycles are a very good 
candidate
- emission standards from other vehicle categories become 
more stringent; this provides the ground to reduce 
emissions from PTWs as wellEmission reduction mandated for other means of road 
transport beyond 2020 may become marginal, if Mopeds 
and all other L-category vehicle type emissions not 
further reduced.
Additional possible impacts from SWOT analysis from LAT 
report (ch 3.3)
- products (motorcycles, mopeds, three and four wheelers) 
of superior quality withstanding global competition.
- possible generation of new jobs in suppliers of emission 
control systemsPossible economy of scales expected for industrialised level 
of technology already applied today. Should theoretically 
result in only low vehicle price increase to consumer.
Sensitivity study presented in MCWG of 29 June 09 
(EMISIA SA Report No: 09.RE.005.V2, Scenarios on the 
future regulation of Power Two Wheelers) showed that 
the threshold level has relatively little effect on total L-
category vehicle emissions for the assessed timeframe 
until 2020. The speed of threshold introduction is the 
most important factor to reduce emissions. Option 4 is 
not supported by the industry (longer time anticipated to 
reach compromise, therefore negative effect on speed of 
implementation of new thresholds (speed of 
implementation is most critical factor)).The weaknesses of introducing new emissions as 
identified in the LAT report (ch. 3.3):
- costly measures with the cost transferred to the 
customers
- generally, cost increases with increasing stringency of 
emission standards
- the emission threshold should have appeared earlier to 
maximize benefit
The threads as identified in the LAT report (ch. 3.3): 
- small motorcycles and mini-cars are mostly sold due to 
their low price, while large motorcycles and ATVs are 
mainly used as recreational and not prime transport 
vehicles; hence PTWs market is inherently more 
sensitive to price increases; large price increases may 
lead to loss of jobs including SMEs (
- increasing cost may shift buyers to other vehicle 
classes (i.e. small cars); shift of the market to cars will 
increase congestion and greenhouse gas emissions. 
Shift to (small) diesel cars may also increase pollutant 
emissions
- increasing cost may also lead to less frequent PTWs 
replacement, hence degrading the rate of reducing 
emissions
- stringent emission standards may lead to loss of 
performance which is a marketing asset for motorcycles; 
hence increasing tampering practices
 
Table 54: Analysis table policy options new emission limits, option 4 
 
EN 93   EN Option 5: New limits for all L-category vehicles equivalent in absolute terms to Euro5 M1 passenger cars (4th scenario from LAT  report)
Positive Negative Neutral  / Remarks
Using the strength of new emission limit values for L-
category vehicles as identified in the LAT report (ch. 3.3):
- reduction of harmful atmospheric substances  (HC, NOx, 
CO, PM) that directly affect a large fraction of the population
- reduction of harmful species that contribute to the 
formation of photochemical pollution (HC, NOx)
- minor reduction of greenhouse-gas (mainly CO2) 
emissions
- reduction of visible smoke
- products (motorcycles, mopeds, three and four wheelers) 
of superior quality withstanding global competition.
- possible generation of new jobs in suppliers of emission 
control systemsCurrent high overall pollution level for new L-category 
vehicles maintained as this can only be very little 
influenced by type approval compliance with low 
thresholds. Adverse health and environmental effects by 
air pollution cannot be efficiently and effectively 
addressed.Effect of Type Approval threshold reduction on the 
overall level of pollutants is marginal in comparison 
to the highly polluting L-category vehicle fleet. The 
average vehicle replacement timeframe is much 
longer as for e.g. passenger cars. It takes much 
longer before the effect of new vehicles, which 
pollute less, becomes effective. The other road 
transport vehicles had to comply already 10 years 
ago with relatively severe type approval thresholds. 
The benefit of this early adoption becomes obvious 
owing to the significant overall pollutant reduction of 
all other vehicles (refer to figure 3.1 to 3.5 of the 
LAT report, p59 - 61
Possible using the opportunities as identified in the LAT 
report ch. 3.3: 
- good environmental performance is a marketing asset for 
all products sold today. Improving emissions will also have a 
positive impact on PTWs’ image
- low CO2 vehicles are promoted and are increasingly 
desirable. Clean and efficient motorcycles are a very good 
candidate
- emission standards from other vehicle categories become 
more stringent; this provides the ground to reduce 
emissions from PTWs as wellEmission reduction mandated for other means of road 
transport beyond 2020 may become marginal, if Mopeds 
and all other L-category vehicle type emissions not 
further reduced.
Possible economy of scales expected for industrialised level 
of technology already applied today. Should theoretically 
result in only low vehicle price increase to consumer.The weaknesses of introducing new emissions as 
identified in the LAT report (ch. 3.3):
- costly measures with the cost transferred to the 
customers
- generally, cost increases with increasing stringency of 
emission standards
- the emission threshold should have appeared earlier to 
maximize benefit
Best performing option in terms of emission reduction: 
achieves 19%, 28%, 40% and 37% reductions in CO, HC, 
PM and NOx, respectively.The threads as identified in the LAT report (ch. 3.3): 
- small motorcycles and mini-cars are mostly sold due to 
their low price, while large motorcycles and ATVs are 
mainly used as recreational and not prime transport 
vehicles; hence PTWs market is inherently more 
sensitive to price increases; large price increases may 
lead to loss of jobs including SMEs (
- increasing cost may shift buyers to other vehicle 
classes (i.e. small cars); shift of the market to cars will 
increase congestion and greenhouse gas emissions. 
Shift to (small) diesel cars may also increase pollutant 
emissions
- increasing cost may also lead to less frequent PTWs 
replacement, hence degrading the rate of reducing 
emissions
- stringent emission standards may lead to loss of 
performance which is a marketing asset for motorcycles; 
hence increasing tampering practicesAdditional possible impacts from SWOT analysis from LAT report (ch 3.3)
- products (motorcycles, mopeds, three and four wheelers) 
of superior quality withstanding global competition.
- possible generation of new jobs in suppliers of emission 
control systemsSensitivity study presented in MCWG of 29 June 09 
(EMISIA SA Report No: 09.RE.005.V2, Scenarios on the 
future regulation of Power Two Wheelers) showed that 
the threshold level has relatively little effect on total L-
category vehicle emissions for the assessed timeframe 
until 2020. The speed of threshold introduction is the 
most important factor to reduce emissions. Option 4 is 
not supported by the industry (longer time anticipated to 
reach compromise, therefore negative effect on speed of 
implementation of new thresholds (speed of 
implementation is most critical factor)).
Worst in cost effectiveness and absolute cost to industry. 
A possible explanation is that the full benefits of this 
option cannot be obtained in the assessed timeframe, 
but a longer period (e.g. 2012 - 2030) should have been 
assessed. Unfortunately this was not feasible owing to 
timing, resources and simulation tool capability.
 
Table 55: Analysis table policy options new emission limits, option 5 
 
EN 94   EN 1.3. Revised lower emissions limits, summary of the co st effectiveness of the proposed emission limit options 
Pollutant ScenarioTotal [tn] (2007 -
2020) 2009 [tn] 2020 [tn]Percentage reduction 
over baseline in 2020Percentage of total road 
transport in 2020Low Estimate
Best Estimate High Estimate
option 1 (no change) 18.400.000 1.630.000 1.010.000 35% - - -
option 2 (scenario 1) 18.400.000 1.630.000 995.000 1% 35% - - -
option 3 (scenario 2) 17.800.000 1.630.000 845.000 16% 31% - - -
option 4 (scenario 3) 17.600.000 1.630.000 859.000 15% 32% - - -
option 5 (scenario 4) 17.700.000 1.630.000 823.000 19% 31% - - -
Other road transport 56.600.000 6.070.000 1.870.000 - - -
option 1 (no change) 4.910.000 429.000 262.000 61% - - -
option 2 (scenario 1) 4.810.000 429.000 245.000 6% 60% 36.2 42.3 48.4
option 3 (scenario 2) 4.740.000 429.000 222.000 15% 57% 50.4 62.8 75.3
option 4 (scenario 3) 4.870.000 429.000 256.000 2% 61% 86.6 109.7 132.8
option 5 (scenario 4) 4.600.000 429.000 188.000 28% 53% 50.1 65.5 80.9
Other road transport 5.370.000 614.000 166.000 - - -
option 1 (no change) 480.000 29.200 42.000 3% - - -
option 2 (scenario 1) 481.000 29.200 42.100 0% 3% - - -
option 3 (scenario 2) 436.000 29.200 30.700 27% 3% 8.0 10.0 12.0
option 4 (scenario 3) 426.000 29.200 32.800 22% 3% 3.8 4.8 5.8
option 5 (scenario 4) 417.000 29.200 26.600 37% 2% 10.5 13.7 17.0
Other road transport 32.500.000 3.220.000 1.190.000 - - -
option 1 (no change) 37.600 3.450 1.970 6% - - -
option 2 (scenario 1) 34.100 3.450 1.430 28% 5% 93.9 109.8 125.6
option 3 (scenario 2) 34.100 3.450 1.240 37% 4% 171.6 214.0 256.4
option 4 (scenario 3) 37.600 3.450 1.970 0% 6% - - -
option 5 (scenario 4) 34.100 3.450 1.180 40% 4% 323.4 423.0 522.6
Other road transport 933.000 101.000 28.800
Worst performing scenario in terms of pollutant reduction
Best performing scenario in terms of pollutant reduction
Low Best High
Estimate Estimate Estimate
Baseline 0 0 0
Scenario 1 4 996 5 838 6 681
Scenario 2 9 283 11 578 13 874
Scenario 3 6 023 7 626 9 229
Scenario 41 17 358 22 705 28 051
Worst performing scenario in terms of cost
Best performing scenario in terms of costSummary of the effectiveness of the emission limits scenarios proposedCost–effectiveness of different L-category vehicle emission standards 
[Euro/kg] or [Million Euro / kton]
Total cost (NPV) for the introduction of different 
emission thresholds 
[Million Euro]Worst performing scenario in terms of cost 
Best performing scenario in terms of cost 
1 Cost calculations are based on very rough estimates, with cost items expressed as 
multiplicands of the cost of technology required to meet the emission standards in Scenario 2. Details are given in section 3.2.4. of the LAT reportNO
x
PMCO
HC
Scenario
 
Table 56: Summary of the cost effectiveness of the proposed emission limits options 
 
EN 95   EN 1.4. Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category 
vehicle categories 
Economical
EnvironmentalSafet
y
SocietalType of impact:
 
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate HighMinimised compliance cost for manufacturers Mopeds (R47 test cycle),  Tricycles (R40 test cycle) and 
Light and Heavy Quadricycles (R40 test cycle) cannot be 
type approved with WMTC global harmonised test cycle. WMTC introduction in 2006 for 2-wheel motorcycle very successful.
R47 and R40 test cycle not representative to simulate 
modern real-world traffic and driving conditions in which 
L-category vehicles participate, mainly owing to the 
absence of representative transient manœuvres in EDC 
and R47 cycle and non-representative low vehicle speed & low engine load collective in EDC test cycle.
Possible CO
2 / fuel consumption measurement is not 
representative for real world emission / performance. 
Especially fuel consumption measurement result may be a purchase criterion for a consumer, who will not be happy if tested fuel consumption and real-world fuel consumption largely differ. This deprives customer to compare different vehicles and to choose for the most fuel efficient and least polluting vehicle.
Not possible to quantify, no data available Not possible to quantify, no data available Not possible to quantify, no data availab leBenefit Cost Other indicatorsBetter simulation of real world driving conditionsEconomy of scales for manufacturers selling L-category 
vehicles globally. Possibly less cost transferred to 
consumers resulting in lower vehicle price.No extra cost to manufacturer if WMTC phase replaced 
with phase 2 for L3&L4 vehicles. No emission impacts 
anticipated.R40 & R47 test cycles easy to replicate with modern 
Engine Management Systems, induces engine tuning 
optimised for the specific emission cycle to obtain type approval. Real-world / off-cycle emission performance of vehicle may be compromised by the search for optimum drive-ability and engine performance (power & torque).
Option 2: Use of the phase 2 World Motorcycle Testing Cycle (WMTC) for all L-category vehicle categories
Initial additional compliance cost, cost neutral on the mid 
to long term.
Less easy (more expensive) to replicate test cycle 
conditions in ECU, more degrees of liberty to prevent "cycle 
beating", make this less attractiveAll L-category vehicles could be type approved by using a 
World Harmonised test cycle (WMTC), which could open 
external markets, especially for countries that are acceded to the UN ECE agreements. PositiveOption 1: No change
Positive Negative Neutral  / Remarks
More transparency for consumer to compare different 
vehicle types in terms of fuel consumption, CO2 emission 
and pollutant emissions. Also comparison with other vehicles than the ones from the L-category may be possible (pending large scale correlation exercises, as previously executed by JRC to establish correlation factors between EDC and WMTC)Benefit
NegativeCost Other indicators
Not possible to quantify, no data available Not possible to quantify, no data available Not possible to quantify, no data availab le
Neutral  / Remarks
 
Table 57: Analysis table policy options Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-
category vehicle categories 
 
EN 96   EN 1.5. Type Approval requirements for CO 2 measurement and fuel consumption determination and 
reporting 
Economical
EnvironmentalSafet
y
SocietalType of impact:
 
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate HighNot possible to quantify, no data available Not possible to quantify, no data available
NegativeOption 2: Type Approval requirements for CO2 measurement and fuel consumption determination and reportingNot possible to quantify, no data available
Uniform EU-wide indication preventing confusion among 
stakeholders.Option 1: No change
Positive Negative Neutral  / Remarks
Cost Other indicators Benefit
Not possible to quantify, no data availableType approval CO 2 and fuel consumption 
measurement and demonstration cost compliance 
are cost neutral, as these are measured simultaneously during pollutant control emission Type Approval testing.Neutral  / Remarks
Benefit Cost Other indicatorsAdditional cost for manufacturer and further downstream 
at the dealer to label vehiclesAt a later stage when also a labelling scheme is introruced, 
direct comparison of fuel consumption with a passenger car 
may provide some good arguments in shifting some potential car buyers to the two-wheelers market. However, this requires common test cycles, or at least test cycles that correlate in terms of emissions, but also in terms of CO
2 
emissions and fuel consumption.Positive
Within different categories and sub-categories of L-category 
vehicles, consumer has additional information to his/her 
disposal to allow selection and purchase of the most energy efficient vehicle.No uniform indication in EU for customer of L-category 
vehicles with respect to their energy consumption. This 
deprives consumer to compare different vehicles and to choose for the most fuel efficient vehicle.
Risk is that Member States will develop and impose own 
labelling system based on the internal structure market. 
This increases the risk of adding confusion to the customers and the manufacturers with respect to evaluation of their different products. A vehicle model could be differently scored in different countries. This is confusing and does not assist in the boundary-free market integration within EU.
Not possible to quantify, no data available Not possible to quantify, no data available
 
Table 58: Analysis table policy options Type-approval requirements for CO 2 measurement and fuel consumption determination 
and reporting 
 
EN 97   EN 1.6. Evaporative emissions test and limit 
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
792 1,189 1,585 Low Best estimate High
171 257 342
Low Best estimate High Low Best estimate High
171 513 855 Low Best estimate High
94 7 2 8Both exhaust and evaporation emissions seem to drop until 
2016. The reason for the drop in evaporation emissions is 
the gradual replacement of carburetted with fuel injection vehicles, also in the baseline scenario. No additional compliance cost for the industry Evaporative emissions are volatile HC emissions due to:
• Breathing losses (directly from the fuel tank or through 
an activated carbon canister or through the open bowl of a carburettor)• Fuel permeation and/or leakage through the fuel lines and circuitAs there is a generic concern with lowering L-category vehicle's share of HC from all road transport HC emissions, this source of HC should also be tackled.
HC emissions from fuel evaporation via tank vents and 
engine openings may become a significant contributor of 
total HC emissions as exhaust concentrations decrease
Not possible to quantify, no data availableCost effectiveness 
[Euro/kg] or [Million Euro / kton]
NB assumption that investment in EFI will only be done 
to reduce evaporative emission is a theoretical 
assumption, therefore are the assumed cost and cost 
efficiency of this option estimated too high. No data 
available to quantify the level of magnitude of this too Increased revenue to supplier industry, including SMEs, 
potentially leading to higher employmentAvailability of independent testing facilities (SHED 
chamber) for authorities, for manufacturers and in 
particular accessibility to these testing facilities for SMEs
Benefit Cost (million Euro) Other indicatorsNB the quantitive data below was only available for category L3e vehiclesSubstantial investments required from industry to e.g. 
equip Mopeds with EFI, but this investment is to a high 
extend justified by possibly complying with revised exhaust emission limits. Only part of the investment can be attributed to better control of evaporative emissions, therefore is option 2 a purely academic assumption.Inherent advantage of EFI to lower evaporative emissions. 
Principle justification of moving from carburettor to EFI is 
more accurate fuel control, leading to better exhaust gas emissions, drive-ability and performance. Better performance of evaporative emission control is a welcome secondary effect. PositiveOption 2: Replacement of all new carburetted models with fuel injected ones. Due to the closed circuit, fuel injection engines result in much lower evaporation 
emissions than carburetted ones
This option in which all the cost of the shift to move 
to electronic fuel injection (EFI) will be incurred only 
owing to improve evaporative emission control is a pure theoretic assumption. In practice the very first reason to equip a vehicle with EFI is to improve fuel metering accuracy to improve exhaust emissions. A secondary effect of moving from carburettor to EFI is the assumption under this option. The cost effectiveness of this option becomes much better if only part of the investment to move to EFI is attributed to evaporative emission control, but this can unfortunately not be quantified. Neutral  / RemarksOther indicatorsOption 1: No change
Positive Negative Neutral  / Remarks
Benefit Cost
Negative
Option 3: Evaporative emissions test and limit enforcing evaporative emission control for all L-category vehicles
Positive Negative Neutral  / Remarks
Substantial investments required from industry to e.g. 
equip vehicles with evaporative emission control, but this 
investment should more be attributed to the case of new exhaust emission limits. Only part of the investment can be attributed to better control of evaporative emissions.Active evaporative emission control can only be 
effective if vehicle is equipped with EFI.
Increased revenue to supplier industry, including SMEs, 
potentially leading to higher employmentAvailability of independent testing facilities (SHED 
chamber) for authorities, but also for SMEs
Benefit Cost (million Euro) Other indicatorsNo guarantee that evaporative emissions remain 
controlled under different ambient conditions (hot 
climate, stop and go traffic) and/or over vehicle life. Type approved once when vehicle is new, no IUC or PTI testing foreseen to check compliance over vehicle life of vehicle fleetMost cost effective solution found in LAT report, to address 
HC emissions from L-category vehicles
NB the quantitive data below was only available for category L3e vehiclesInherent advantage of EFI to lower evaporative emissions. 
Principle justification of moving from carburettor to EFI is 
more accurate fuel control, leading to better exhaust gas emissions, drive-ability and performance. Better performance of evaporative emission control is a welcome secondary effect. 
Not possible to quantify, no data availableNo guarantee that evaporative emissions remain 
controlled under different ambient conditions (hot 
climate, stop and go traffic) and/or over vehicle life. Type approved once when vehicle is new, no IUC or PTI testing foreseen to check compliance over vehicle life of vehicle fleetSignificant additional decrease in evaporative HC 
emissions, approximately 600 ton until 2020 (refer to graph 
3-29 in ch. 3.3.5.3 of the LAT report)
Significant additional decrease in evaporative HC 
emissions, approximately 2800 ton until 2020 (refer to graph 
3-29 in ch. 3.3.5.3 of the LAT report)
Cost effectiveness 
[Euro/kg] or [Million Euro / kton]
 
Table 59: Analysis table policy options evaporative emissions test and limit 
 
EN 98   EN 1.7. Durability requirements. 
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
Not possible to quantify, no data available Not possible to quantify, no data available Not possible to quantify, no data availab leReduced risk for customers to fail PTI tests in the Member 
States where this applies. Prevent early on exchange of 
expensive exhaust after treatment components.
Benefit Cost Other indicatorsOnce a durability regulation has been decided, the 
actual useful life is not a critical parameter. 
Increase of the durability by 60% led to additional reductions in emission levels in the order of 4 ktn of HC, 30 ktn of CO and 1.1 ktn of NOx. This corresponds to 1.6%, 3.0%, and 2.6% per pollutant respectively, of total PTW emissions in 2020
It is absolutely critical that a durability regulation is 
introduced for L-category vehicles, otherwise significant 
departures from the emission standard may occur at rather 
ht d i tOption 1: (Scenario "Baseline" from the LAT report): This scenario assumes that there will be no further legislative step beyon d 2006/72/EC i.e. no durability 
requirements for PTWs will be imposed. In this way, an arbitrary deterioration over the useful life is set to 20%.
Positive Negative Neutral  / Remarks
Increased compliance cost for manufacturers possibly 
transferred into high consumer priceEstimated emission benefit in EU15 (EU27 unknown) until 
2020 owing to introduction of option 2:
- HC: 12,500 tn- CO: 75,500 tn- NOx: 3,400 tnPositive Negative
Once a durability regulation has been decided, the 
actual useful life is not a critical parameter. 
Increase of the durability by 60% led to additional reductions in emission levels in the order of 4 ktn of HC, 30 ktn of CO and 1.1 ktn of NOx. This corresponds to 1.6%, 3.0%, and 2.6% per pollutant respectively, of total PTW emissions in 2020Neutral  / Remarks
Reduced risk for customers to fail PTI tests in the Member 
States where this applies. Prevent early on exchange of 
expensive exhaust after treatment components.Option 2 (Scenario 2 from the LAT report): Deterioration reduced to 10% for the useful life and application of linear extrapola tion for higher mileageBenefit Cost Other indicators
Not possible to quantify, no data available Not possible to quantify, no data available Not possible to quantify, no data availab le
It is absolutely critical that a durability regulation is 
introduced for L-category vehicles, otherwise significant 
departures from the emission standard may occur at rather 
ht d i tIncreased quality and guarantee for customer that 
investment in cleaner vehicle gives better  value for money 
over vehicle life in terms of steady environmental 
f
Other indicators
Increased quality and guarantee for customer that 
investment in cleaner vehicle gives better  value for money 
over vehicle life in terms of steady environmental 
fOption 3 (Scenario 2 from the LAT report): useful life increased by 60%, i.e. equivalent to the increase incurred to passenger cars when shifting from Euro 3 
(80k km) to Euro 5 (160k km)
Positive Negative Neutral  / Remarks
Estimated emission benefit in EU15 (EU27 unknown) until 
2020 owing to introduction of option 3:
- HC: 17,500 tn- CO: 105,000 tn- NOx: 4,600 tnIncreased compliance cost for manufacturers possibly 
transferred into high consumer priceNew Type Approval limits go hand-in-hand with 
durability requirements. Introduction of lower Type 
Approval limits is practically useless if the exhaust after treatment components and other emission relevant components do not have the quality and/or proper design to withstand thermal ageing and poisoning over vehicle life. One method to check this quality is to perform durability testing before start of production by e.g. letting development vehicles run a durability distance of X km (e.g. 50,000 km) and to test the emission performance of the vehicle every Y km (e.g. 10,000 km. After X km the emission performance must still be below the respective emission limits. Also accelerated durability tests exist.Low compliance cost for manufacturer Uncontrolled degradation of exhaust emissions relevant 
engine components and systems is never verified on 
fleet vehicles, as there are no PTI, RSI or IUC tests. Once a type approval test conducted with a brand new vehicle, meeting the type approval limits does not guarantee that the emission performance over vehicle life in the real world remains within the acceptable boundary (e.g. maximum 10 - 15% emission performance deterioration after X km of mileage accumulation).
Not possible to quantify, no data available Not possible to quantify, no data available Not possible to quantify, no data availab leBenefit Cost
 
Table 60: Analysis table policy options durability requirements 
 
EN 99   EN 2. N EW MEASURES TO CONTROL EMISSIONS DURING VEHICLE LIFE . 
2.1. In-Use Conformity (IUC) testing and limits.  
Under the scope of this policy option only IUC is regar ded for the reasons as indicated in chapter 2.1, 
problem definition (not PTI, nor RSI, which will be subj ects to a separate Impac t Assessment executed by 
DG TREN on the revision of Di rectives 96/69/EC and 2000/40/EC). 
Economical
EnvironmentalSafet
y
SocietalType of impact:
  
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
6 7 8 Low Best estimate High
3.6 4.2 4.8
Low Best estimate High
0.3 0.3 0.4Cost effectiveness HC
[Euro/kg] or [Million Euro / kton]In-Use compliance (IUC) regulations are 
established to make sure that the emission levels 
of a vehicle type in the real-world complies with its type-approval limits. IUC is a manufacturer's responsibility. IUC requires that a small sample of fleet vehicles is randomly selected and is tested according to the certification test conditions to check whether the vehicles comply with their corresponding emission standards.Low compliance cost for manufacturer Uncontrolled degradation of exhaust emissions relevant 
engine components and systems is never verified on 
fleet vehicles, as there are no PTI, RSI or IUC tests. Once a type approval test conducted with a brand new vehicle, meeting the type approval limits does not guarantee that the emission performance over vehicle life in the real world remains within the acceptable boundary (e.g. maximum 10 - 15% emission performance deterioration after X km of mileage 
accumulation
).
Benefit Cost [Million Euro] Other indicatorsReduced risk for customers to fail PTI tests in the Member 
States where this applies. Prevent early on exchange of 
expensive exhaust after treatment components.Difficult to select representative vehicles to testEstimated emission benefit in EU15 (EU27 unknown) until  
2020 owing to introduction of option 2:
- HC: 180 tn- CO: 1600 tn- NOx: 100 tnPartial overlap with RSI, PTI and durability testing, low 
cost effectiveness of IUC compared to other related 
measures
Increased quality and guarantee for customer that 
investment in cleaner vehicle gives better  value for money 
over vehicle life in terms of steady environmental Increased administrative and financial burden to national 
authoritiesDepending on the results of the IUC procedure, the 
manufacturer may be forced to remedy the situation, if the 
vehicles selected do not comply with the emission standards. This should be considered as a direct environmental benefit of an IUC requirement. As an indirect benefit, the manufacturer takes all necessary steps to ensure that the long-term emission behaviour does not differentiate (at least much) from the type approval limits. It is obvious that it is not possible to simulate the indirect 
effect of IUC.PositiveNot possible to quantify, no data available Not possible to quantify, no data available
Option 2: (Scenario 1 from LAT report): IUC procedure mandatory to for all Euro 3 motorcycles. The IUC is considered to identif y all not attainments which are 
consecutively corrected. Not possible to quantify, no data available
main structural components of any IUC procedure
• Manufacturers responsibility for durable and 
functioning emission controls in use, for a certain driving distance (durability period).• Test procedure: type-approval emission laboratory test or, for surveillance, some other in-use emission test data supplied by manufacturers or an authority.• Procedure for selection, procurement, and maintenance of vehicles to the test sample (audit 
procedure).
• Procedure to examine test data and information, emission failure and technical faults.• Recall/remedial actions, how to perform and report, labels, etcNeutral  / RemarksOther indicatorsOption 1: No change
Positive Negative Neutral  / Remarks
Benefit Cost
Cost effectiveness NOx
[Euro/kg] or [Million Euro / kton]Negative
Increased compliance cost for manufacturers possibly 
transferred into high consumer price
No additional cost for end-customer as burden carried by 
manufacturer and national authorities
 
Table 61: Analysis table policy options In-Use Conformity (IUC) testing and limits 
 
EN 100   EN 2.2. On Board Diagnostic (OBD) syst ems and access to repair information 
Economical
EnvironmentalSafet
y
SocietalType of impact:
 
Low Best estimate High Low Best estimate High
Not possible to quantify, no data available Not possible to quantify, no data availableOption 1: No change (No introduction of OBD systems)
Positive Negative Neutral  / Remarks
Benefit Cost Other indicators
Not possible to quantify, no data availableNo additional compliance cost for manufacturer. Effect of malfunctions on emissions
Inefficient malfunction analysis with subsequent 
ineffective repair. (Independent) workshop is dependent 
on availability of proprietary manufacturer, non-standardised malfunction information. 
Driver not directly informed if a capital system failure 
exists, that leads to high emissions 
In Member States in which L-category vehicles are 
subject to PTI testing, gaseous testing cannot be 
replaced by reading out OBD information as there is no standardised diagnostic information made available to a generic scan tool. This forces to maintain the worse cost efficient gaseous (CO) testing.Ineffective repair leads to high repair cost for customer 
and leads to customer dissatisfaction, high cost for repair 
shop and possibly high warranty cost for manufacturers. 
Driver not directly informed if a capital system failure 
exists, that leads to a possible engine failure, leading to high subsequent repair cost for consumer.Driver not directly informed if a capital system failure 
exists, that leads to a possible safety impact.
 
Table 62: Analysis table policy options On Board Diagnostic (OBD) systems and access to repair information, option 1 
 
EN 101   EN Low Best estimate High Low Best estimate High
1227 1588 1949 Low Best estimate High
HC 22.5 29.1 35.8
NOx 1.5 2.4 1.9NegativeOption 2 (scenario 1 in LAT report): Application of OBD systems of similar technology to passenger cars (EOBD), including catal yst efficiency monitoring to 
all L-category vehicles. Introduction of free access to repair and maintenance provisions, similar as for passenger cars.
Engine component, sub system and complete system 
degradation monitoring. Fuel system drift, Misfire, Catalyst 
efficiency diagnostic, Front and Rear O2 sensor response diagnostic, EGR flow diagnostic, comprehensive components monitoring diagnostic among others guarantee 
that the most emission relevant components are monitored 
on their efficiency. In case of low efficiency leading to exceeding the OBD emission thresholds, the MIL will be illuminated and the driver will be notified so he/she is aware that a repair must be executed. The engine management system may trigger default actions in order to protect the engine and/or the catalytic converter. In Use Performance Ratio monitoring will increase the confidence level that all this monitoring will also happen under real world conditions and not only for demonstration purposes in the type approval test.Positive
Risk of ignoring the Malfunction Indicator Light by the 
driver.Neutral  / Remarks
Driver directly informed if a capital system failure exists, that 
leads to possible engine failure. Support to prevent high 
subsequent repair cost for consumer.Increased complexity of legislationStandardised (ISO) malfunction information available to 
independent repairers, leading to less cost and time to 
diagnose malfunctions
Access to technology by SME's (analogy to aspects as 
referred to under chapter on Antilock  Brake systems).It is essential to find the optimum balance between 
correct, fast detection of failure and prevention of 
false detection. False detection will lead to loss of confidence of consumer and repairers and increased non value added cost to all stakeholders.If notified driver may visit repair shop soon and have 
malfunctions causing high emissions quickly repaired, 
leading to significant less negative environmental impact of malfunctions.Substantial investments of the industry in technology 
(hard-ware and software). High compliance cost.
Driver directly informed if a capital system failure exists, that 
leads to a possible safety impact.Special provisions required to accommodate retrofitting. 
Possible negative financial consequences for aftermarket 
Other indicators
Standardised  (ISO)  malfunction  and other  diagnostic  
information is indispensible for independent repairers to 
efficiently and effectively repair a failure. The introduction of OBD and free access to repair and maintenance information to address the competition concern in the EU internal market must be assessed as one combined policy option. For this reason are the cost and cost-effectiveness calculations only indicative and too estimated very conservatively
Cost effectiveness 
[Euro/kg] or [Million Euro / kton]Additional employment and revenue for Type Approval 
Authorities and testing laboratories to help manufacturers 
develop the OBD system and increased revenue related to additional engine hardware and software to be able to comply with OBD measures.
Increased innovation in other areas of development than 
only in engine performance (power / torque) increase
Not possible to quantify, no data availableAdditional employment and revenue for automotive 
suppliers to help manufacturers develop the OBD system 
and increased revenue related to additional engine hardware and software to be able to comply with OBD measures.
Use OBD as alternative to gaseous test in PTI, similar as on 
passenger cars. Enhanced efficient method to check 
whether engine is in acceptable condition. Reduced cost and PTI for customer.Missing enforcement in Periodical Technical Inspection / 
Road Side Inspection. No consequences if MIL on, 
voluntary decision of driver to continue driving with malfunction or to have vehicle repaired. In case of systematic malfunction owing to bad quality / design of 
components / systems there is no authority checking 
whether manufacturer should recall vehicles and improve vehicle.
Benefit Cost (NPV in Million Euro)Less attractive (more complicated, more expensive) to 
tamper with manufacturer optimum found settings in order 
to just increase engine power / torque at the cost of the environmental / safety performance of the vehicle.
 
Table 63: Analysis table policy options On Board Diagnostic (OBD) systems and access to repair information, option 2 
 
EN 102   EN Low Best estimate High Low Best estimate HighIf notified driver may visit repair shop soon and have 
malfunctions causing high emissions quickly repaired, 
leading to significant less negative environmental impact of malfunctions.Low investments of the industry in technology (hardware 
and software) as OBD phase one features are industry 
wide available, only as manufacturer proprietary systems (not standardised) and hardly not available on request of generic scan tool. Low estimated compliance cost. OBD phase 1 is ´commodity product´ of automotive suppliers and a ´no brainer´ to manufacturers.It is essential to find the optimum balance between 
correct, fast detection of failure and prevention of 
false detection. False detection will lead to loss of confidence of consumer and repairers and increased non value added cost to all stakeholders.
Standardised (ISO) malfunction information available to 
independent repairers, leading to less cost and time to 
diagnose malfunctionsRisk of ignoring the Malfunction Indicator Light by the 
driver.
Driver directly informed if a capital system failure exists, that 
leads to a possible safety impact.Special provisions required to accommodate retrofitting. 
Possible negative financial consequences for aftermarket 
industry.
Driver directly informed if a capital system failure exists, that 
leads to possible engine failure. Support to prevent high 
subsequent repair cost for consumer.Increased complexity of legislation
Degradation of components / systems not included. Only 
fast developing failures detected, slow over time developing 
failures will not be detected. Missing enforcement in Periodical Technical Inspection / 
Road Side Inspection. No consequences if MIL on, 
voluntary decision of driver to continue driving with malfunction or to have vehicle repaired. In case of systematic malfunction owing to bad quality / design of components / systems there is no authority checking whether manufacturer should recall vehicles and improve vehicle.
Less attractive (more complicated, more expensive) to 
tamper with manufacturer optimum found settings in order 
to just increase engine power / torque at the cost of the environmental / safety performance of the vehicle.
Additional employment and revenue for automotive 
suppliers to help manufacturers develop the OBD system 
and increased revenue related to additional engine hardware and software to be able to comply with OBD 
measuresAdditional employment and revenue for Type Approval 
Authorities and testing laboratories to help manufacturers 
develop the OBD system and increased revenue related to additional engine hardware and software to be able to comply with OBD measures.
Standardised (ISO) malfunction and other diagnostic 
information is indispensible for independent repairers to 
efficiently and effectively repair a failure. The introduction of OBD and free access to repair and maintenance information to address the competition concern in the EU internal market must be assessed as one combined policy option.This was an additional reason to discard the cost and cost-effectiveness calculations provided by the consultant's report as this was aspect was not included in the initial assumptions.Increased innovation in other areas of development than 
only in engine performance (power / torque) increase.
Use OBD as alternative to gaseous test in PTI, similar as on 
passenger cars. Enhanced efficient method to check 
whether engine is in acceptable condition. Reduced cost and PTI for customer.
One time investment for OEM  can be we ll amort ised, owing 
to high level of re-use of hardware and software functionality 
for current and future generations of Engine Control Modules.
Benefit Cost (NPV in Million Euro) Other indicators
Cost effectiveness 
Not possible to quantify, no data availableThe numbers from the LAT report were considered much 
too high and were therefore discarded by the 
Commission Services.The numbers from the LAT report were considered 
much too high and were therefore discarded by the 
Commission Services.Option 3 (scenario 2 in LAT report): use of Best Available Technology (BAT): minor malfunction monitoring (e.g. circuit integri ty check) (OBD phase 1) to all L-
category vehicles, no catalyst efficiency monitoring. Introduction of free access to repair and maintenance provisions, similar  as for passenger cars.
Positive Negative Neutral  / Remarks
 
Table 64: Analysis table policy options On Board Diagnostic (OBD) systems and access to repair information, option 3 
 
EN 103   EN ANNEX  XII: DETAILS CHAPTER 5 — IMPACT ANALYSIS NEW VEHICLE TYPE APPROVAL SAFETY MEASURES  
1. O BLIGATORY FITTING OF ADVANCED BRAKE SYSTEMS  
In the discussions about this topic there is a lot of confusion about the expression  ‘Advanced’ Brake Systems 
and ‘ Anti-lock’  Brake Systems49, generally abbreviated as ABS. Howe ver, Advanced Brake Systems are 
also abbreviated as ABS. In this Impact Assessment  report ABS means Anti-lock  Brake System exclusively. 
Advanced Brake Systems in this report is defined as: Anti-lock  Brake System and/or Combined Brake 
Systems50. 
Controversial in the discussions is  the technical effectiveness of Anti-lock  Brake Systems to prevent 
accidents or mitigation of injuries and associated cost-benef it ratios, especially for the scenarios in which this 
system would be assumed to be mandatory. One of the mo st critical variables in the discussion is the best 
estimated cost price of Anti-lock  Brake System and the impact this pot entially has on vehicle sales and the 
estimations of the cost benefit ratios. For every scen ario the assumed best estimate, including low and high 
range prices will be listed. In the policy report the short, mid- and long-term economic impacts were 
assessed. In the Impact Assessment  report only the long term effects will be used as final comparison 
criteria, as the objectives for the measures in the new regulation are also defined as long term goals. In case of any short term side-effect of a measur e, this will be specifically reported. 
1.1. No change 
Economical
EnvironmentalSafet
y
SocietalType of impact:
 
Low Best estimate High Low Best estimate HighPotential customers not purchasing PTWs owing to 
being victim of road accidentLevel of cost to society owing to cost of health care, lost 
working days etc.
High insurance cost for consumerOption 1: No change
Positive Negative Neutral  / Remarks
Benefit (million Euro), 2011 - 2021 Cost (million Euro), 2011 - 2021 Other indicatorsLow consumer price of PTW Unchanged level of fatalities and injured riders in PTW 
involved road accidents.
Grief of family, friends, colleagues.
 
Table 65: Analysis table policy options obligatory fitting of advanced brake systems, option 1 
                                                 
49 Definition from TRL report: Anti-lock  braking systems (ABS) monitor the speed at  which the wheels are rotating and rapidly 
modulate the brake pressure when imminent wheel lock is detect ed in order to increase effective braking and prevent the 
deceleration being dictated by the sliding friction between tyre and road. ABS is the only technical solution  which directly 
monitors and prevents wheel locking and has been shown in test condi tions to result in generally higher braking decelerations 
by maintaining the wheel slip such that friction is above the level provided by locked wheels. Preventing wheel lock under 
emergency braking provides the rider with incr eased confidence to appl y higher brake forces. 
50 Definition from TRL report: Combined braking systems (CBS) are used to ensure that the co rrect braking distribution is 
applied regardless of which brake is activated; currently the rider must use two separate mechanisms to operate the front and 
rear brakes. The use of CBS allows one mechanism to operate bo th brakes (in a similar way to that of a passenger car). The 
primary aim of this system is to appropriately distribute the braking effort between the front and rear wheels. Compared with 
rider-controlled distribution of braking between the front and th e rear, CBS reduces the chances of wheel lock and instability 
occurring at less than the maximum level of deceleration. For ex ample, if a rider applied the rear brake very hard, without 
using the front brake, the rear wheel c ould lock and cause instability at a level of  deceleration considerably less than half t he 
maximum achievable. CBS can prevent such  a situation but cannot prevent wheel lo ck when the rider applies the single brake 
control harder than required to produce maximum deceleration. 
 
EN 104   EN 1.2. Anti-lock Brake Systems on all Powered Two Wheelers (PTW) 
2,799 5,999 11,997
Low Best estimate High Low Best estimate High
€ 2,553 € 5,107 € 10,214 € 1,732 € 3,463 € 2,597
€ 792 €1,583 - €3,677 € 7,354
€ 102 €204  - €460 € 919
accident avoidance 
2011 - 20211.3 2.7 – 3.6 7.1
casualty mitigation 
2011 - 20211.1 2.3 – 3.0 5.9Long term societal and economic benefits owing to casualty 
mitigation . There are estimated to be between 5.5 and 13 
times (approximately between 30,000 and 72,000 riders) 
more heavily injured people than fatalities per year in the 
EU. Slight motorcycle casualties are lying within a range of 
12 and 28 times the numbers of fatalities (approximately 
between 66,000 and 155,000 riders) per annum in the EU. 
Based on the current available data it is not possible to forecast the level of mitigation in case of mandatory use of 
advanced brake system.
In some Member States, discount on rider's insurance. Less 
cost insurance com
panies.
Level of market penetration: 91% of PTWs estimated to be 
equipped with a Anti-lock  Brake System in 2021Legislation not technology neutral, mandating a specific 
technology. Normally legislation just defines the 
performance criteria.  
Level of technical complexity of vehicleAnti-lock  Brake System is the only technical solution 
which directly monitors and prevents wheel locking.
With Anti-lock  Brake System higher braking decelerations 
achieved (resulting in less braking distance) than with 
conventional brakes only. Potential reduction in impact speed in case of collisionRider training is required in order to achieve the 
maximum advantages of Anti-lock  brake system
Innovation in Anti-lock  Brake System and braking 
technology
Preventing wheel lock under emergency braking provides 
the rider with increased confidence to apply higher brake 
forces. More efficient braking with Anti-lock  brake system, 
rider brakes earlier during brake manœuvre
Additional rules for design of brake system to industry 
making legislation more complex.Anti-lock brake systems prevents dangerous downfalls 
whilst braking. In case of critical wheel-lock of front wheel 
PTW rider falls and slides uncontrolled over the road
Cost effectiveness obligatory Anti-lock  brake system. 
Majority of in total 11 predictive and retrospective literature 
st ud
y results are positive.
Chance of increased level of accident result mitigation in 
case of  Anti-lock  brake systemRisk of short - mid term price increase owing to 
manufacturers forced to buy systems and components 
from suppliers.
Benefit (million Euro), 2011 - 2021 Cost (million Euro), 2011 - 2021 Remarks / Other indicators
Benefit: fatality avoidance
Benefit: mitigation heavy injuries
Benefit: mitigation slight injuriesOption 2: Anti-lock  Brake Systems on all Powered Two Wheelers (PTW)
Positive Negative Neutral  / Remarks
Inexperienced riders on PTW with Anti-lock  Brake System 
able to achieve decelerations closer to that of experienced 
riders, after relatively short training / adaptation time
Vehicles fitted with Anti-lock  Brake System are able to 
make use of the adhesion available when on low and high friction surfaces. (e.g. changing conditions from dry to wet 
road)Rider becoming "over" confident if PTW equipped with 
advanced brake system, trusts too much on technology. 
Higher speed
Perception that CBS is full alternative to Anti-lock brake 
system, technical equivalence
Possible bad braking performance (adverse effects off-
road) if Anti-lock  Brake System fitted on off-road PTW
Manufacturing and development cost of PTWs equipped 
with Anti-lock  Brake Systems, possibly passed on to 
consumer (possible price increase)
Availability o f Anti-lock Brake System technology to 
SME's (not meeting entrance criteria to be supplied by 
bigger automotive suppliers or confronted with high 
development cost as supplier cannot amortise investments owing to low series production)
Economy of scales for Anti-lock Braking System production, 
mid to long term drop of development and production cost 
Revenue and employment supplier industry
FATALITY REDUCTION 
Long term life saving (2011-2021)
Min.           Best Estimate                Max.
Benefit to cost ratio, 2011 - 2021
Low        Best estimate          High
 
Table 66: Analysis table policy options obligatory fitting of advanced brake systems, option 2 
 
EN 105   EN 1.3. A NTI-LOCK BRAKE SYSTEMS ON PTW S WITH CYLINDER CAPACITY51 > 125  CM3 AND ADVANCED BRAKE 
SYSTEMS (COMBINED BRAKE SYSTEM (CBS)  OR ANTI-LOCK BRAKE SYSTEMS (ABS))  ON MOTORCYCLES 
WITH 50 CM3 < CYLINDER CAPACITY51 ≤ 125  CM3 
2,799 5,332 11,331
Low Best estimate High Low Best estimate High
€ 2,383 € 4,539 € 9,646 € 1,602 € 3,463 € 2,597
€ 739 €1,407 - €3,268 € 6,945
€ 95 €182 - €409 € 868
accident avoidance 
2011 - 2021 1.2 2.4 – 3.2 6.7
casualty mitigation 
2011 - 2021 1.1 2.0 – 2.6 5.6Performance criteria of option 3 aligned with vehicle 
performance criteria as defined in the new driving licence Directive 2006/126/EC for category A2. Benefit: type 
approval and driving licence vehicle classification criteria harmonised (coherence)
Sensible definition of performance thresholds to differentiate 
between a low and a high performing motorcycle. To 
improve the match between the performance (acceleration 
and braking) criteria used for type approval and for driving 
licence (category A2). Rationale: the higher the power and torque characteristics of a motorcycle, leading to a high 
max. vehicle speed and fast acceleration respectively, the 
better the braking performance must be. Especially the Power to mass criteria defined in Directive 2006/126/EC 
provide an international accepted limitation for this criterion.Option 3: Anti-lock Brake Systems on PTWs with cylinder capacity > 125 cm
3 and Advanced Brake Systems (Combined Brake System (CBS)             
               and/or Anti-lock Brake S ystems (Anti-lock Brake S ystem )) on motorc ycles with c ylinder ca pacity >50cm3and <= 125cm3 
Positive Negative Neutral  / Remarks
Benefit to cost ratio, 2011 - 2021
Low        Best estimate          HighBenefit (million Euro), 2011 - 2021 Cost (million Euro), 2011 - 2021 Remarks / Other indicatorsAnti-lock  Brake System is the only technical solution 
which directly monitors and prevents wheel locking.
With Anti-lock  Brake System higher braking decelerations 
achieved (resulting in less braking distance) than with 
conventional brakes only. Potential reduction in impact 
speed in case of collision
Preventing wheel lock under emergency braking provides 
the rider with increased confidence to apply higher brake 
forces. More efficient braking with Anti-lock  brake system, 
rider brakes earlier during brake manœuvre
Inexperienced riders on PTW with Anti-lock  Brake System 
able to achieve decelerations closer to that of experienced riders, after relatively short training / adaptation time
Vehicles fitted with Anti-lock  Brake System are able to 
make use of the adhesion available when on low and high friction surfaces. (e.g. changing conditions from dry to wet 
road)
Anti-lock  brake systems prevents dangerous downfalls 
whilst braking. In case of critical wheel-lock of front wheel PTW rider falls and slides uncontrolled over the road
Cost effectiveness obligatory Anti-lock  brake system. 
Majority of in total 11 predictive and retrospective literature 
study results are positive.
Chance of increased level of accident result mitigation in 
case of  Anti-lock  brake system
In some Member States, discount on rider's insurance. Less 
cost insurance companies.Long term societal and economic benefits.
Level of market penetration: 64% of PTWs estimated to be 
equipped with a Anti-lock  Brake System in 2021, 27% with Economy of scales for Anti-lock Braking System production, 
mid to long term drop of development and production cost 
Revenue and employment supplier industryRider becoming "over" confident if PTW equipped with 
advanced brake system, trusts too much on technology. 
Perception that CBS is full alternative to Anti-lock brake 
system, technical equivalence
Possible bad braking performance (adverse effects off-
road) if Anti-lock  Brake System fitted on Off-road PTW
Manufacturing and development cost of PTWs equipped 
with Anti-lock  Brake Systems, possibly passed on to 
consumer (possible price increase)
Availability o f Anti-lock Brake System technology to 
SME's (not meeting entrance criteria to be supplied by bigger automotive suppliers or confronted with high 
development cost as supplier cannot amortise investments owing to low series production)
Risk of short term price increase owing to manufacturers 
forced to buy systems and components from suppliers.
Additional rules for design of brake system to industry 
making legislation more complex.
Legislation not technology neutral, mandating a specific 
technology. Normally legislation just defines the 
performance criteria.  
Level of technical complexity of vehicleRider training is required in order to achieve the 
maximum advantages of Anti-lock  brake system
Innovation in Anti-lock  Brake System and braking 
technology
Benefit: fatality avoidance
Benefit: mitigation heavy injuries
Benefit: mitigation slight injuriesFATALITY REDUCTION 
Long term life saving (2011-2021)
Min.           Best Estimate                Max.Long term societal and economic benefits owing to casualty 
mitigation . There are estimated to be between 5.5 and 13 
times (approximately between 30,000 and 72,000 riders) more heavily injured people than fatalities per year in the 
EU. Slight motorcycle casualties are lying within a range of 
12 and 28 times the numbers of fatalities (approximately between 66,000 and 155,000 riders) per annum in the EU. 
Based on the current available data it is difficult to forecast 
the level of mitigation in case of mandatory use of advanced 
brake system
 
Table 67: Analysis table policy options obligatory fitting of advanced brake systems, option 3 
                                                 
51 The 125 cm3 takes reference to the thresholds in Directive 2006/126/EC  (recasted driving licence di rective) related to class 
A1: motorcycles with a cylinder capacity not exceeding 125 cm3, of a power not exceeding 11kW and with a power/weight 
ratio not exceeding 0.1 kW/kg. 
 
EN 106   EN 1.4. To make mandatory the fitting of Advanced  Brake Systems (Combi ned Brake System (CBS) 
and/or Anti-lock Braking Systems) on those motorcycles which conform to the performance 
criteria defined by the A2 driving licence. Obligatory fitting of Anti-lock Brake Systems on 
all other L3e class motorcycles; 
754 - 2799
mean: 17771437 - 5332
mean:33853054 - 11331
mean:7193
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
€ 2,383 € 4,539 € 9,646 € 1,602 € 3,463 € 2,597
€ 739 €1,407 - €3,268 € 6,945
€ 95 €182 - €409 € 868
accident avoidance 
2011 - 2021 1.2 2.4 – 3.2 6.7
casualty mitigation 
2011 - 2021 1.1 2.0 – 2.6 5.6Remarks / Other indicatorsApproximated Benefit (million Euro), 2011 - 2021 Approximated Cost (million Euro), 2011 - 2021 Remarks / Other indicatorsPositive Negative Neutral  / RemarksOption 4: To make mandatory the fitting of Advanced Brake Systems (Combined Brake System (CBS) and/or Anti-lock Braking Systems ) on those motorcycles 
which conform to the performance criteria defined by the A2 driving licence . Obligatory fitting of Anti-lock Brake Systems on all other L3 class motorcycles;
Performance criteria of option 4 aligned with vehicle 
performance criteria as defined in the new driving licence Directive 2006/126/EC for category A2. Benefit: type 
approval and driving licence vehicle classification criteria 
harmonised (coherence)
Sensible definition of performance thresholds to differentiate 
between a low and a high performing motorcycle. To 
improve the match between the performance (acceleration 
and braking) criteria used for type approval and for driving 
licence (category A2). Rationale: the higher the power and 
torque characteristics of a motorcycle, leading to a high 
max. vehicle speed and fast acceleration respectively, the 
better the braking performance must be. Especially the 
Power to mass criteria defined in Directive 2006/126/EC 
provide an international accepted limitation for this criterion.Anti-lock  Brake System is the only
 technical solution 
which directly monitors and prevents wheel locking.
With Anti-lock  Brake System higher braking decelerations 
(resulting in less braking distance) than with conventional 
brakes only. Potential reduction in impact speed in case of 
collision
Preventing wheel lock under emergency braking provides 
the rider with increased confidence to apply higher brake 
forces. More efficient braking with Anti-lock  brake system, 
rider brakes earlier during brake manœuvre
Inexperienced riders on PTW with Anti-lock  Brake System 
able to achieve decelerations closer to that of experienced 
riders, after relatively short training / adaptation time
Economy of scales for Anti-lock Braking System production, 
mid to long term drop of development and production cost In some Member States, discount on rider's insurance. Less 
cost insurance companies.
Higher fleet penetration rate of Anti-lock  Brake System 
than if left to marketRevenue and employment supplier industryPossible bad braking performance (adverse effects off-
road) if Anti-lock  Brake System fitted on Off-road PTW
Manufacturing and development cost of PTWs equipped 
with Anti-lock  Brake Systems, possibly passed on to 
consumer (possible price increase)
Anti-lock  brake systems prevents dangerous downfalls 
whilst braking. In case of critical wheel-lock of front wheel PTW rider falls and slides uncontrolled over the road
Cost effectiveness obligatory Anti-lock  brake system. 
Majority of in total 11 predictive and retrospective literature study results are positive.Rider training is required in order to achieve the 
maximum advantages of Anti-lock  brake system
Innovation in Anti-lock  Brake System and braking 
technology
Availability o f Anti-lock Brake System technology to 
SME's (not meeting entrance criteria to be supplied by 
bigger automotive suppliers or confronted with high 
development cost as supplier cannot amortise 
investments owing to low series production)
Risk of short term price increase owing to manufacturers 
forced to buy systems and components from suppliers.
Significant higher level of uncertainty regarding the 
benefit to cost ratio as scenario did not make part of the 
TRL report. The financial data were copied from option 3. 
The assumption is that the cost to the manufacturer is 
significantly lower, but the benefit as well, resulting in 
lower benefit to cost ratios.Legislation not technology neutral, mandating a specific 
technology. Normally legislation just defines the 
performance criteria.  
Less vehicles in the scope of mandatory equipping 
vehicles with an Anti-lock  Brake System from the 
braking performance perspectiveLevel of technical complexity of vehicleChance of increased level of accident result mitigation in 
case of  Anti-lock  brake system
Benefit: fatality avoidance
Benefit: mitigation heavy injuriesFATALITY REDUCTION 
Long term life saving (2011-2021)
Min.           Best Estimate                Max.Long term societal and economic benefits owing to casualty 
mitigation . There are estimated to be between 5.5 and 13 times (approximately between 30,000 and 72,000 riders) 
more heavily injured people than fatalities per year in the 
EU. Slight motorcycle casualties are lying within a range of 
12 and 28 times the numbers of fatalities (approximately 
between 66,000 and 155,000 riders) per annum in the EU. 
Based on the current available data it is difficult to forecast 
the level of mitigation in case of mandatory use of advanced 
brake systemAdditional rules for design of brake system to industry 
making legislation more complex.Vehicles fitted with Anti-lock  Brake System are able to 
make use of the adhesion available when on low and high 
friction surfaces. (e.g. changing conditions from dry to wet 
road)Rider becoming "over" confident if PTW equipped with 
advanced brake system, trusts too much on technology. 
Perception that CBS is full alternative to Anti-lock brake 
system, technical equivalence
Benefit (million Euro), 2011 - 2021 Cost (million Euro), 2011 - 2021
Benefit: mitigation slight injuries
Benefit to cost ratio, 2011 - 2021
Low        Best estimate          High
 
Table 68: Analysis table policy options obligatory fitting of advanced brake systems, option 4
 
EN 107   EN  
1.5. Industry self obligation 
754 1,437 3,054
Low Best estimate High Low Best estimate High
€ 648 € 1,234 € 2,621 € 404 € 1,338 € 2,203
€ 201 €382 - €888 € 1,887
€ 26 €49 - €111 € 236
accident avoidance 
2011 - 2021 0.7 1.2 - 1.7 3.5
casualty mitigation 
2011 - 2021 0.6 1.1 - 1.4 3.0Benefit: fatality avoidance
Benefit: mitigation heavy injuriesBenefit (million Euro), 2011 - 2021 Cost (million Euro), 2011 - 2021 Remarks / Other indicatorsAdvanced brake system type chosen by consumer
Less complex legislation, remains technology neutral to the 
full extend by just defining brake performance criteriaPositive
Estimated Percentage of fleet fitted with Anti-lock Brake 
System only estimated 16%, CBS: 7% in 2021
Consumer opting for Anti-lock  Brake System and/or 
CBS can only partly benefit from pressure on advanced 
brake system price (lower level of economy of scales for 
manufacturer)
Level of technical complexity of vehicleAnti-lock  Brake System is the only technical 
solution which directly monitors and prevents wheel 
locking.
With Anti-lock  Brake System higher braking 
decelerations achieved in the majority of cases 
(resulting in less braking distance) than with 
conventional brakes only.
Despite of voluntary self-regulation already applicable 
since 2004 and on schedule (35% of all PTWs equipped 
with advanced brake systems) the fatality statistics have 
not significantly decreased and remain to be static or 
slightly increasing.Rider becoming "over" confident if PTW equipped with 
advanced brake system, trusts too much on technology. 
Higher speeds
Cost effectiveness obligatory Anti-lock  brake system. 
Possible bad braking performance (adverse effects off-
road) if Anti-lock  Brake System fitted on Off-road PTW
SME's under "normal" market pressure to equip 
produced vehicles with advanced brake systems. 
Concern related to access to technology  postponed / 
only mitigated, not eliminatedInexperienced riders on PTW with Anti-lock Brake 
System able to achieve decelerations closer to that 
of experienced riders, after relatively short training / 
adaptation time
Anti-lock  brake systems prevents dangerous 
downfalls in many cases whilst braking (panic 
stop).
Rider training is required in order to achieve the 
maximum advantages of Anti-lock  brake system
Chance of increased level of accident result 
mitigation in case of  Anti-lock  brake system
Economy of scales for Anti-lock  Braking System 
production, mid to long term drop of development 
and production cost 
Revenue and employment supplier industry
Innovation in Anti-lock  Brake System and braking 
technology
FATALITY REDUCTION 
Long term life saving (2011-2021)
Min.           Best Estimate                Max.Long term societal and economic benefits owing to casualty 
mitigation . There are estimated to be between 5.5 and 13 
times (approximately between 30,000 and 72,000 riders) 
more heavily injured people than fatalities per year in the 
EU. Slight motorcycle casualties are lying within a range of 
12 and 28 times the numbers of fatalities (approximately 
between 66,000 and 155,000 riders) per annum in the EU. 
Based on the current available data it is not possible to 
forecast the level of mitigation in case of mandatory use of 
advanced brake system.Cost effectiveness Advanced Brake Systems according to 
industry self-obligation scheme (either Anti-lock  Brake 
System and/or CBS)Preventing wheel lock under emergency braking provides 
the rider with increased confidence to apply higher brake 
forces. More efficient braking with  Advanced Brake System, 
rider brakes earlier during brake manœuvre
In some Member States, discount on rider's insurance in 
case consumer opted for advanced brake system. Less cost
insurance companies for these cases.
Higher fleet penetration rate of Anti-lock  Brake System 
than if completely left to market demand
Benefit to cost ratio, 2011 - 2021
Low        Best estimate          HighBenefit: mitigation slight injuriesNegative
Conventional consumer price development owing to supply 
and demand. No guarantee in the self regulation is provided 
that the cost of advanced brake systems will not be 
transferred to the end customer. Anti-lock Brake System 
might be available as an option only.Neutral  / Remarks
CBS is full alternative to Anti-lock  brake system, technical 
equivalence assumed between both systems from the 
perspective of accident avoidance.
Less burden (impact of legislation on vehicle design) in 
industry (mainly for big players, small manufacturers may 
still struggle to fulfil self regulation quota if above small 
series threshold)Option 5: Industry self-obligation
 
Table 69: Analysis table policy options obligatory fitting of advanced brake systems, option 5 
 
EN 108   EN 2. A NTI-TAMPERING MEASURES  
Economical
EnvironmentalSafet
y
SocietalType of impact:
 
2.1. No change; 
Low Best estimate High Low Best estimate HighEnforcement: vehicle compliance with chapter 7 not 
checked with the same intensity and frequency in all the 
EU27 Member StatesGeneral interest in customising and modification, good for 
technical education
Emission of noise, exhaust emission levels, fuel 
consumption and CO2. In some cases application of after -
market components that do not increase power or 
maximum speed but do increase the noise levels 
substantially.
Higher maximum vehicle speed for e.g. Mopeds, which 
are designed for max. only 45 km/h.Theft of vehicles Saving on insurance premium
Vehicles move more towards electronic manipulation, 
there is likely to be a negative safety impact as the 
existing anti-tampering measures become less effective 
(not possible to quantify) or become obsolete
Vehicles that have been tampered with are more likely to 
become involved in an accident.
Most frequent tampering of original exhaust system, 
which possible contains exhaust after treatment 
technology to reduce emissions. Possible other 
tampering candidate: Engine Management System
Not possible to quantify, no data availableOther indicatorsNo additional manufacturer cost added if current 
anti-tampering measures for Mopeds and Light 
Motorcycles would be maintained.
Level of innovationEffectiveness of chapter 7, ten years after introduction 
largely unknownEffectiveness of chapter 7, seven years after introduction 
largely unknown
Adverse economic impact on the suppliers of the parts 
which are no longer required (information stickers, 
frangible bolts etc.). Some may be SMEs.
Likely to have a negative effect on safety and would 
represent a backwards step from the current situation 
(MAIDS study indicated in 1999-2000, before introduction 
of chapter 7, 12.3% of mopeds had some form of engine 
or driveline tampering, which may be a very conservative 
estimate)
Enforcement: vehicle compliance with chapter 7 not 
checked with the same intensity and frequency in all the 
EU27 Member States (spot checks in Road Side 
Inspection or reoccurring in Periodical Technical 
Inspection)Tampering only limited to Mopeds and lower 
displacement motorcycles ? What will be effect of 
possible lower emission limits which may effect 
maximum performance on motorcycles with higher 
displacement ?By-passing driver licensing restrictions 
Large after-market industry that supplies 
equipment/services for the modification of vehicles. Some of
these modifications can be used to by-pass the existing anti-
tampering measures, therefore repealing these measures 
could have an economic impact on this market, which is 
likely to contain a number of SMEs. (not possible to quantify 
this impact)Saving on road tax 
By-passing recurring technical inspections for special 
categories of vehicle
Not possible to quantify, no data available Not possible to quantify, no data availableBenefit CostOption 1: No change
Positive Negative Neutral  / Remarks
 
Table 70: Analysis table policy options anti tampering measures, option 1 
 
EN 109   EN 2.2. Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures; 
Low Best estimate High Low Best estimate HighLikely to have a negative effect on safety and would 
represent a backwards step from the current situation 
(MAIDS study indicated in 1999-2000, before introduction 
of chapter 7, 12.3% of mopeds had some form of engine 
or driveline tampering, which may be a very conservative 
estimate)
Theft of vehiclesLevel of innovationEnforcement: vehicle compliance with chapter 7 not 
checked with the same intensity and frequency in all the 
EU27 Member States (spot checks in Road Side 
Inspection or reoccurring in Periodical Technical 
Inspection)
Most frequent tampering of original exhaust system, 
which possible contains exhaust after treatment 
technology to reduce emissions. Possible other 
tampering candidate: Engine Management SystemGeneral interest in customising and modification, good for 
technical educationBy-passing driver licensing restrictions 
Effectiveness of chapter 7, ten years after introduction 
largely unknownSaving on road tax 
Savin g on insurance premiumOption 2: Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures
Enforcement: vehicle compliance with chapter 7 not 
checked with the same intensity and frequency in all the 
EU27 Member States
Effectiveness of chapter 7, seven years after introduction 
largely unknownEmission of noise, exhaust emission levels, fuel 
consumption and CO 2. In some cases application of after -
market components that do not increase power or 
maximum speed but do increase the noise levels 
substantially.
Higher maximum vehicle speed for e.g. Mopeds, which 
are designed for max. only 45 km/h.
Vehicles move more towards electronic manipulation, 
there is likely to be a negative safety impact as the 
existing anti-tampering measures become less effective 
(not possible to quantify) or obsolete
Vehicles that have been tampered with are more likely to 
become involved in an accident.Slightly less burden on OEM because one less approval to 
be obtained.Tampering only limited to Mopeds and lower 
displacement motorcycles ? What will be effect of possible lower emission limits which may effect 
maximum performance on motorcycles with higher 
displacement ?
Adverse economic impact on the suppliers of the parts 
which are no longer required (information stickers, 
frangible bolts etc.). Some may be SMEs.
Large after-market industry that supplies 
equipment/services for the modification of vehicles. 
Some of these modifications can be used to by-pass the 
existing anti-tampering measures, therefore repealing 
these measures could have an economic impact on this 
market, which is likely to contain a number of SMEs. (not 
possible to quantify this impact)Positive Negative Neutral  / Remarks
Not possible to quantify, no data available Not possible to quantify, no data availableOther indicatorsBy-passing recurring technical inspections for special 
Not possible to quantify, no data availableBenefit Cost
 
Table 71: Analysis table policy options anti tampering measures, option 2 
 
EN 110   EN 2.3. New measures on anti-tampering 
Low Best estimate High Low Best estimate High
Not possible to quantify, no data availableBenefit Cost Other indicatorsBy-passing driver licensing restrictions 
Saving on road tax 
Saving on insurance premium
By-passing recurring technical inspections for special 
categories of vehicleMinimum economic impact on manufacturers if the 
new measures can be designed into the vehicles in 
a similar way to the current measures
Additional cost owing to design/development of new 
parts that are not currently used for the existing 
measures, especially for SMEs. Positive impact on 
other suppliers (which could also be SMEs), who develop and sell solutions to cope with new 
requirements.
Economic impact on the after-market vehicle 
Tampering only limited to Mopeds and lower 
displacement motorcycles ? What will be effect of 
possible lower emission limits which may effect 
maximum performance on motorcycles with higher 
displacement ?
Adverse economic impact on the suppliers of the parts 
which are no longer required or modified (information 
stickers, frangible bolts etc.). Some may be SMEs.
Enforcement: better vehicle compliance checking 
indications
Number of additional products for large after-market 
industry that supplies equipment/services for the 
modification of vehicles. Modifying / adding measures could 
have a positive economic impact on this market.Improvements in emission of noise, exhaust emission 
levels, fuel consumption and CO
2 owing to tampering 
prevention.Level of innovation
More difficult (expensive) to obtain a maximum vehicle 
speed for e.g. Mopeds over the legal limit of 45 km/h.
More appropriate anti-tampering measures, matching with 
technology, prevention of obsolete measures.
(more expensive) to tamper with become less involved in a 
road accident.
Not possible to quantify, no data available Not possible to quantify, no data availableOption 3 New measures on anti-tampering
Positive Negative Neutral  / Remarks
General interest in customising and modification, good for 
technical education
Updated legal requirements to align with progress in 
technology
Theft of vehicles
 
Table 72: Analysis table policy options anti tampering measures, option 3 
 
EN 111   EN 3. 74  KW POWER LIMITATION FOR MOTORCYCLES  
Economical
EnvironmentalSafet
y
SocietalType of impact:
 
 
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate HighBenefit Cost Other indicatorsNeutral  / RemarksOption 1: No change
Positive Negative Neutral  / Remarks
No clear evidence to suggest that limiting the power 
of a motorcycle to 74kW has a positive impact on 
the number of road accidents involving 
motorcycles. Other factors such as rider attitude 
and experience have a greater influence on 
accident risk
Effect on the noise generation, emissions and fuel 
consumptionOption 3: Set a harmonized limit of 74kW. 
Positive
Potential significant revenue loss to industry owing to 
some customers loosing interest in motorcyclesImpact on some specialist manufacturers that 
concentrate on the production of high powered 
motorcycles, where maximum power is essential for their 
brandNegativeEffect on the noise generation, emissions and fuel 
consumption
Not possible to quantify, no data availableBenefit Cost
Not possible to quantify, no data availableOther indicatorsNumber of Member States that apply the 74kW 
power limit through national legislation could 
increaseCost to the manufacturers to produce the restricted 
motorcycles
No clear evidence to suggest that limiting the power 
of a motorcycle to 74kW has a positive impact on 
the number of road accidents involving 
motorcycles. Other factors such as rider attitude 
and experience have a greater influence on 
accident riskPotential that, in the future, the number of Member 
States that apply the 74kW power limit through 
national legislation could increase
Sales within the markets affected that are currently 
not restricted ? Will there be an increase or 
decrease in sales ?
Option 2: Repeal the option given to Member States to limit the power to 74kW.
Positive Negative Neutral  / RemarksOther indicators Benefit Cost
If e.g. power to mass ratio would be considered as limitation 
criterion this may be more effective. No data available to 
substantiate assumption.Neutral  / Remarks
Economic impact of this option will be dependent 
on the method of limitation that is selectedRisk of impact on the sales of new motorcycles if the 
new method of limitation is inconsistent with the 
requirements of the target marketNo clear evidence to suggest that limiting the power 
of a motorcycle to 74kW has a positive impact on 
the number of road accidents involving 
motorcycles. Other factors such as rider attitude 
and experience have a greater influence on 
accident riskNegative
Potential significant revenue loss to industry owing to 
some customers loosing interest in motorcyclesEffect on the noise generation neutral, impact on 
emissions and fuel consumption may be negative
OEMs will not be required to add specific measures to 
vehicles for specific markets therefore this should result in a 
positive economic impact for the OEMs with respect to 
reduced technical and administrative costsNo clear evidence to suggest that limiting the power 
of a motorcycle to 74kW has a positive impact on 
the number of road accidents involving 
motorcycles. Other factors such as rider attitude 
and experience have a greater influence on 
accident riskAny motorcycle that has a European approval can be 
registered in any Member State.Minimum Economic impact
Benefit CostMember States that currently apply the 74kW power limit 
(currently thought to be only France) may rescind the 
National Legislation. This is likely to have a moderate 
positive economic impact
Positive
Effect on the noise generation, emissions and fuel 
consumptionOther indicators
Option 4: Use an alternative limitation.Not possible to quantify, no data available Not possible to quantify, no data available
 
Table 73: Analysis table policy options 74 kW limitation, options 1 to 4 
 
EN 112   EN ANNEX  XIII:  DETAILS CHAPTER 5 — IMPACT ANALYSIS IMPROVED CATEGORISATION OF L-CATEGORY VEHICLES  
1. E LECTRICAL CYCLES (OUTSIDE SCOPE OF FRAMEWORK DIRECTIVE CURRENTLY ), TRICYCLES (L5E) AND 
QUADRICYCLES (CATEGORY L6E  AND L7E) 
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate HighOther indicators
Option 4: Improving the legislation by adding new requirements based on car requirements for mini cars.Not possible to quantify, no data available Not possible to quantify, no data available
Positive
Transparency regulatory systemBenefit CostTransparency regulatory systemOther indicators Benefit
In the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars, but 2,500,000 electric bicycles anticipated to be on the market by 2011
Technical standards meeting effort; current costs 
unchangedSignificant cost increase if technical requirements vary 
between countries. Cost impact particularly high for 
SMEs
Neutral  / Remarks
Align requirements as far as possible with M1 
requirements. Increase in scope for testing to match 
passenger cars would impose very significant additional 
cost on industryIn the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger carsNegativeCost
Option 2: Exclude quadricycles and electrical bi- and tri-cycles from the Framework Regulation; 
Positive Negative Neutral  / RemarksIn the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars, but 2,500,000 electric bicycles 
anticipated to be on the market by 2011Regulatory system costs unchanged, not possible to 
quantify more as the general statement that type 
approval cost per application is €10,000;
Not possible to quantify, no data availableOther indicators
Neutral  / Remarks
Transparency regulatory system In the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars, but 2,500,000 electric bicycles 
anticipated to be on the market by 2011
Regulatory system costsOption 3: Return to the original spirit of the legislation for mini cars;
Positive
Noise, emissions and fuel consumption; low negative 
impact. Not quantified; no dataLevel of safetyOption 1: No change
Positive Negative Neutral  / Remarks
Technical standards meeting effort; current costs 
unchanged
Level of safety
Not possible to quantify, no data availableBenefit Cost
Not possible to quantify, no data available Not possible to quantify, no data availableBenefit Cost Other indicatorsPossible additional compliance cost to manufacturer with 
revised criteria to re-categorise L-category vehiclesTechnical standards meeting effort unchangedLevel of safety
Noise, emissions and fuel consumption; low negative 
im
pact. Not quantified ; no data
Negative
Noise, emissions and fuel consumption; Not quantified; no 
dataTechnical standards meeting effort unchanged Technical requirements improved to M1 passenger car 
equivalent; improved safety
Option 5: Improving the proliferation of vehicle categories by the introduction of dedicated sub categories in L1e, L5e, L6e an d L7e. Add new / revised 
appropriate dedicated requirements for these sub categories.
Positive Negative Neutral  / Remarks
Level of safetyPossible additional compliance cost to manufacturer with 
revised criteria to re-categorise L-category vehiclesIn the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars
Technical standards meeting effort unchangedTransparency regulatory systemNoise, emissions and fuel consumption; low negative 
impact. Not quantified; no data
 
Table 74: Analysis table policy options re-categorisation L1e, L5e, L6E & L7e, options 1 to 5. 
 
EN 113   EN 2. Specific requirements for category L7e vehicles 
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate HighReduced compliance cost for manufacturers, better cost 
effectiveness of measures, lower consumer prices.Inappropriate / non-present safety measures
Appropriate environmental measures. Possibility to incl ude 
international standards (CEN / ISO / UN ECE)Emissions resulting from travel to/from technical 
standards meetings
Appropriate safety measures. Possibility to include 
international standards (CEN / ISO / UN ECE)
Appropriate environmental measures. Possibility to incl ude 
international standards (CEN / ISO / UN ECE)No clear separation between on-road and off-road quad 
classification possible, based on design criteria only . 
High risk of easy circumnavigating strict safety and 
environmental type-approval requirements for on-road 
quads by simple and inexpensive modification of off-road 
quadsAdd new Quadricycle category and specific r equirements. 
Not quantified; effect on casualties not clear. Targeted 
measures may be more effective at reducing casualties 
than Option C.Inappropriate / non-present environmental measures
Negative Neutral  / Remarks
Appropriate safety measures. Possibility to include 
international standards (CEN / ISO / UN ECE)
Not possible to quantify, no data available Not possible to quantify, no data availableBenefit Cost Other indicatorsOption 1: No change
Positive Negative Neutral  / Remarks
Cost
Option 2: Exclude off-road quads from the Framework Directive.
Not possible to quantify, no data availableBenefitType approval costs unchanged
Casualty rates remain unchanged; current casualty rates 
appear high in relation to cars and PTWs. Not quantified; 
data insufficient to draw robust conclusions
Neutral  / RemarksNot possible to quantify, no data available Not possible to quantify, no data available
PositiveCost
Add new requirements for all quadricycles. Not 
quantified ; effect on casualties not clear
Option 4: Create a new category for off-road quadricycles with specific requirements.Positive Negative Neutral  / Remarks
Option 3: Keep the existing category and add new requirements on safety for all quads.
Positive
Still complex, difficult to interpret and to differentiate 
between different vehicle t ypesAdd new requirements for all quadricycles (Quads and 
mini cars) in terms of cost. Risk that requirements for 
one vehicle type are not applicable for the other and vice 
versa. Not quantified; insufficient data but cost increase if 
additional tests added. Likely to also result in increased 
cost to consumersApproved as machines or other alternative. Not 
quantified; effect on casualties not clearATVs approved at national level. Increase in cost to 
manufacturers over current situation, potentially requiring 
€10,000 per vehicle for approval in each member state
Other indicatorsNot possible to quantify, no data availableOther indicators
Benefit CostDifferent national approval requirements. Not quantified; 
risk of divergent requirements leading to trade barriersOther indicators Benefit
Simplification. Clearer, more appropriate measures. 
Reduction of obsolete or redundant requirementsInappropriate / non-present environmental measuresInappropriate / non-present safety measures
Emissions resulting from travel to/from technical 
standards meetingsAdd new Quadricycle category and specific 
requirements. Not quantified; cost increase over 
current situation if additional to current 
requirements but reduction possible if specific 
requirements mean reduced costNegative
 
Table 75: Analysis table policy options specific requirements for Category L7e vehicles, options 1 to 4. 
 
EN 114   EN 3. Dedicated requirements for gaseous alternat ive fuels and other non-traditional propulsions. 
Low Best estimate High Low Best estimate High
Low Best estimate High Low Best estimate HighLevel of innovation in safety and environmental technology 
may increase, with potential opportunities for SMEs.In appropriate / non present environmental measures
Cost Other indicators
Other indicatorsOption 2: Legislation at European Union level through a tighter grid of vehicle type categorisation with dedicated measures for  the different vehicles and 
propulsion technologies.
Appropriate environmental measures. Possibility to incl ude 
international standards (CEN / ISO / UN ECE)Not sufficient technical experience with and impacts of 
e.g. large scale industrial hydrogen L-category vehicle 
technology. Benefit
Appropriate safety measures. Possibility to include 
international standards (CEN / ISO / UN ECE)Positive Negative Neutral  / Remarks
Global Technical Regulation on Hydrogen 
technology is being developed. L-category vehicles 
propelled on hydrogen are excluded as the 
technology is not considered mature yet.Type approval costs unchanged or estimated higher. 
Also conflicting stakeholder responses that would a) 
promote investment through a clearer market or b) inhibit 
innovation by more test and cost requirements
Not possible to quantify, no data availableBenefitSimplification. Clearer, more appropriate measures. 
Reduction of obsolete or redundant requirements
Cost
Not possible to quantify, no data availableOption 1: No change (legislation at National level)
Positive Negative Neutral  / Remarks
Type approval costs unchanged. Potentially high costs 
for approval in multiple countries and this may be 
inhibiting investment in market. Not quantified; no 
available data
Add new fuel specific requirements. Not quantified; effect on 
casualties not clear. Targeted measures may be more 
effective at reducing casualties than option 1.Different national approval requirements. Not quantified; 
risk of divergent requirements leading to trade barriers
Environmental benefit: lower particulate matter emissions, 
lower non-methane hydrocarbon emissions, lower CO 
emissions, similar NOx emissions. In case of CNG / Biogas: 
significant lower CO 2 emissions.In appropriate / non present safety measures
 
Table 76: Analysis table policy options dedicated requirements for gaseous alternative fuels and other non-traditional 
propulsions. 
 
EN 115   EN ANNEX  XIV:  DETAILS CHAPTER 6 — OPTIONS COMPARISON AND CONCLUSIONS SIMPLIFICATION OF THE 
LEGISLATION  
 
The positive point in option 1,’no policy change’ is t hat no risk of loss in quality of requirements would be 
introduced by replacing provisions of EU Directives by references to international standards. A negative side 
of option 1 is that the concerns for manufacturers and administrations will re main, which is not in line with the 
Better Regulation objective. Continuing this approach would thus add unnecessary administrative burden on 
stakeholders. To reply to the concerns  about a weakening of requirements, it  is intended that references will 
only be proposed in cases where the international standards  are at least equal to the relevant EU Directives. 
By moving from directives to the legislative instrument  of regulations, option 2 would do away with the need 
for transposition on the side of Member States and t he need for transposition control on the side of the 
Commission, as this continues to be the case for opt ions 1 and 3. Hence, all discrepancies between national 
transposition acts would be avoided. In addition, today the Commission services work on their own 
documents and on those from UNECE, etc. It would be mu ch more efficient and more cost-effective for the 
representatives of Member States and also for the Commission services if the technical details were no 
longer duplicated in different set of legislations. 
With the introduction of the split-level approach, the Council and Parliament can concentrate on the most 
important and perhaps controversial issues that require political debate and agreement, while delegating technical and administrative details to the Commission without losing control. The regulatory procedure with 
scrutiny would be the applicable comitology procedure, wh ich ensures final control of the co-legislators also 
for comitology acts. Additional advantages of options 2 and 3 compared to option 1 are that the legislation 
will be simplified by suppressing useless duplications and that the fast developments in technical progress, 
possible new or revised environmental and safety meas ures can be smoothly integrated, while executing the 
simplification exercise. In terms of co st benefit is option 2 superior to option 3, as the cost for national 
transposition and surveillance of compliance cost will not apply. 
In conclusion the advantages of option 2 outweigh by far its disadvantages and are more beneficial than 
choosing for options 1 or 3. Therefore the preferred opt ion would be to simplify the legislation by introducing 
a co-decision Regulation with a limited number of im plementing Regulations through Comitology, using as 
much as possible the standards availabl e from UNECE, CEN/CENELEC and ISO.  
 
EN 116   EN __ __ much worse
__worse
0 neutral (no change)
+ better
++ much betterExplanation:
 
 
Conclusion 
00 0 0
simplification of the 
regulatory framework ++initial cost
__better coherence than option 1, 
in the long run also better than option 3++
Improved global 
harmonization++reduced annual implementation cost of 
regulatory system +increased clarity for industry 
and other stakeholders++
better and clearer structure 
of legal text++translation cost eliminated+
technical standards meeting 
effort reduced for Industry  & EU-270risk of delaying urgent matters
0
emissions resulting from 
travel to/from technical standards meetings reduced 
for Industry/EU-270cost reduction on the long term
++
loss in safety and 
environmental 
protection0quick process of adaptation to technical 
evolution in the future0
benefits of new measures can be 
accrued more ra pidly+
transparent regulatory system / 
democratic gap0
length of processing: agreeing on one 
text including all requirements__
simplification of the 
regulatory framework ++initial cost
__better coherence than option 1, 
in the long run also better than 
option 3++
Improved global 
harmonization++reduced annual implementation cost of 
regulatory system 0increased clarity for industry 
and other stakeholders++
better and clearer structure 
of legal text++translation cost eliminated if direct 
reference to technical standard0
technical standards meeting 
effort reduced for Industry  & 
EU-270risk of delaying urgent matters
__
emissions resulting from 
travel to/from technical standards meetings reduced 
for Industr
y/EU-270cost reduction on the long term
+
loss in safety and 
environmental protection0quick process of adaptation to technical 
evolution in the future_
benefits of new measures can be 
accrued more rapidly0
transparent regulatory system / 
democratic gap0
length of processing: agreeing on one 
text including all requirements__+2: Repeal current directives and 
replace with a minimum number 
of regulations                 1: No policy change
3: Repeal current directives and 
replace with a minimum number 
of regulationsSimplification
Option 3: Repeal current directives and replace with a minimum number of regulations
Objective Policy options CriteriaOption 1: No policy change
Objective Policy options Criteria
Effectiveness Efficiency Coherence
CoherenceOption 2: Repeal current directives and replace with a minimum number of regulations
++Conclusion 
Conclusion Effectiveness Efficienc y CoherenceSimplificationObjective Policy options Criteria
Effectiveness Efficienc y
 
Table 77: option comparison and conclusion table — simplification 
 
EN 117   EN ANNEX  XV:  DETAILS CHAPTER 6 — OPTIONS COMPARISON AND CONCLUSIONS VEHICLE TYPE APPROVAL 
ENVIRONMENTAL MEASURES  
1. New or revised environmental measures for the type approval of new vehicles 1.1. Revised lower emissions limits. 
__ __ much worse
__worse
0 neutral (no change)
+ better
++ much betterExplanation:
 
Conclusion 
Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate Matter emissions as share of total road transport emissions.0Estimated speed of implementation 
(short implementation time)
0Better coherence than options 2,3,4,5 ?
0
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport0Compliance cost
0Increased clarity for industry and other 
stakeholders0
Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for part or all of L-category vehicle industry0Risk of cost transferred to consumer
0Appropriate environmental measures 
for complete different vehicles0
Products of superior quality withstanding global 
competition.0Level of simplification0
Possible generation of new jobs in suppliers of 
emission control systems 0Transparency with emission 
performance of other, alternative 
means of road transport0
Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs0
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective0
Increasing tampering practices 0Environmental objective: reduce air pollution from 
operation and reduce evaporative emissions until L-
category emissions proportionate to their actual use (3% of 
total road mileage)
0Option 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y Coherence
 
Table 78: option comparison and conclusion table, revised emission limits, option 1  
 
Conclusion 
Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate Matter emissions as share of total road transport emissions.__Estimated speed of implementation 
(short implementation time)
++Better coherence than options 2,3,4,5 ?
__ __
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport__ __Compliance cost
0Increased clarity for industry and other 
stakeholders__ __
Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for part or all of L-category vehicle industry__ __Risk of cost transferred to consumer
0Appropriate environmental measures 
for complete different vehicles__ __
Products of superior quality withstanding global 
competition.__ Level of simplification__ __
Possible generation of new jobs in suppliers of 
emission control systems __Transparency with emission 
performance of other, alternative 
means of road transport__ __
Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs0
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective0
Increasing tampering practices 0Environmental objective: reduce air pollution from operation 
and reduce evaporative emissions until L-category emissions 
proportionate to their actual use (3% of total road mileage)__Option 2: : New emission limits for L1 mopeds: a cold-start r47 test cycle and a 30% weighing factor for the cold start are pro posed to be applied. (Scenario 1 from LAT report). No change in limits for 
other L-category vehicles.
Objective Policy options Criteria
Effectiveness Efficienc y Coherence
 
Table 79: option comparison and conclusion table, revised emission limits, option 2  
 
EN 118   EN Conclusion 
Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate Matter emissions as share of total road transport emissions.+Estimated speed of implementation 
(short implementation time)
++Better coherence than options 1,2,4,5 ?
__ __
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport0Compliance cost
0Increased clarity for industry and other 
stakeholders+
Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for part or all of L-category vehicle industry++Risk of cost transferred to consumer
0Appropriate environmental measures 
for complete different vehicles+
Products of superior quality withstanding global 
competition.+Level of simplification0
Possible generation of new jobs in suppliers of 
emission control systems +Transparency with emission 
performance of other, alternative 
means of road transport__
Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs0
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective0
Increasing tampering practices0Option 3: Motorcycle industry proposal (Scenario 2 from LAT report)
Objective Policy options Criteria
++Effectiveness Efficienc y CoherenceEnvironmental objective: reduce air pollution from operation 
and reduce evaporative emissions until L-category emissions 
proportionate to their actual use (3% of total road mileage)
 
Table 80: option comparison and conclusion table, revised emission limits, option 3  
Conclusion 
Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate Matter emissions as share of total road transport emissions.+Estimated speed of implementation 
(short implementation time)
__ __Better coherence than options 1,2, 3 
and 5 ?
__
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport0Compliance cost
__Increased clarity for industry and other 
stakeholders+
Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for part or all of L-category vehicle industry++Risk of cost transferred to consumer
__Appropriate environmental measures 
for complete different vehicles+
Products of superior quality withstanding global 
competition.+Level of simplification0
Possible generation of new jobs in suppliers of 
emission control systems +Transparency with emission 
performance of other, alternative 
means of road transport__
Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs0
Risk of less frequent vehicle replacement, 
leading to longer time before new measures become effective0
Increasing tampering practices 0Efficienc
y CoherenceEnvironmental objective: reduce air pollution from operation 
and reduce evaporative emissions until L-category emissions 
proportionate to their actual use (3% of total road mileage)Option 4: New measures based on th e Best Available Technology appl ied on L-category vehicles sold today in the market (Scenario  3 from LAT report)
Objective Policy options Criteria
Effectiveness
+
 
Table 81: comparison and conclusion table, revised emission limits, option 4  
 
Conclusion 
Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate Matter emissions as share of total road transport emissions.++Estimated speed of implementation 
(short implementation time)
__ __Better coherence than options 1,2, 3 
and 5 ?
+
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport+Compliance cost
__Increased clarity for industry and other 
stakeholders+
Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for part or all of L-category vehicle industry++Risk of cost transferred to consumer
__ __Appropriate environmental measures 
for complete different vehicles++
Products of superior quality withstanding global 
competition.++Level of simplification+
Possible generation of new jobs in suppliers of 
emission control systems ++Transparency with emission 
performance of other, alternative 
means of road transport+
Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs__
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective__
Increasing tampering practices
__Efficienc
y CoherenceEnvironmental objective: reduce air pollution from operation and 
reduce evaporative emissions until L-category emissions 
proportionate to their actual use (3% of total road mileage)++Option 5: New limits for all L-category vehicles equivalent in absolute terms to Euro5 M1 light-duty vehicles (4th scenario fro m LAT report)
Objective Policy options Criteria
Effectiveness
 
Table 82: comparison and conclusion table, revised emission limits, option 5 
 
EN 119   EN 1.2. Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category 
vehicle categories. 
__ __ much worse
__worse
0 neutral (no change)
+ better
++ much betterExplanation:
 
Conclusion 
Representation of off-cycle, real world 
emissions and fuel consumption 0Compliance cost short term
0Amount of test cycles developed from 
historic reasons that may obsolete 0
Increase cost of tampering / "cycle beating", 
therefore make it less attractive0Compliance cost mid to long term
0Transparency of vehicle emission 
performance and fuel economy 
between the different vehicles of the L-category.0
Economy of scale for manufacturers 
that globally market L-category vehicles
0Transparency of vehicle emission 
performance and fuel economy 
between  L-category vehicle and 
alternative means of transport (e.g. 
passenger cars or other).0
Conclusion 
Representation of off-cycle, real world 
emissions and fuel consumption +Compliance cost short term
__Amount of test cycles developed from 
historic reasons that may obsolete +
Increase cost of tampering / "cycle beating", 
therefore make it less attractive+Compliance cost mid to long term
0Transparency of vehicle emission 
performance and fuel economy 
between the different vehicles of the L-category.++
Economy of scale for manufacturers 
that globally market L-category vehicles
+Transparency of vehicle emission 
performance and fuel economy 
between  L-category vehicle and alternative means of transport (e.g. passenger cars or other).+
Transparent change (cost and/or 
emission impact) if phase 2 WMTC 
would replace phase 1++Effectiveness Efficienc
y CoherenceOption 2: Use of the phase 2 World Motorcycle Testing Cycle (WMTC) for all L-category vehicle classesOption 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y CoherenceEnvironmental objective: reduce air 
pollution from operation and reduce 
evaporative emissions until L-
category emissions proportionate to 
their actual use (3% of total road 
mileage)
++Environmental objective: 
reduce air pollution from 
operation and reduce 
evaporative emissions until L-
category emissions 
proportionate to their actual 
use (3% of total road mileage)0
Objective Policy options Criteria
 
Table 83: comparison and conclusion table Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-
category vehicle categories 
L-category 
vehicle typeEmission 
step Test cycleL-category 
vehicle typeEmission 
stepTest 
cycleEmission 
stepTest 
cycle Remark
L1AN.A. N.A.N.A. is not applicable, full 
electrical vehicles only
L1B Euro 3 & 4 R47 Euro 5 WMTC To be developped in UN ECE
L2 Euro 2 R47 L2 Euro 3 & 4 R47 Euro 5 WMTC Same as for L1B
L3 Euro 3 EDC / WMTC L3 Euro 4 & 5 WMTC Euro 6 WMTC
L4 Euro 3 EDC / WMTC L4 Euro 4 & 5 WMTC Euro 6 WMTC
L5A Euro 3 & 4 WMTC Euro 5 WMTC
L5B Euro 3 & 4 R40 Euro 5 WMTC
L6A Euro 3 & 4 R47 Euro 5 WMTC Same as for L1B
L6B Euro 3 & 4 R47 Euro 5 WMTC Same as for L1B
L7A Euro 3 & 4 WMTC Euro 5 WMTC
L7B Euro 3 & 4 R40 Euro 5 WMTCEuro 2 R40Current test cycle Proposal for future test cycles
L1 Euro 2 R47
R40
R47L5
L6Euro 2
Euro 2
L7
 
Table 84: Summary table containing proposal to transition to preferred option 2 (use of WMTC for all L-category vehicles) 
NB Also please notes that for cert ain L-category vehicles (L1e, L2e, L6E and L7e) the scope of the WMTC 
under UNECE Global Technical Regulation 2 must be widened. 
 
Figure 22: Example of how the existing Moped test cycle R47 can be replaced by a WMTC based test cycle. 
 
EN 120   EN 1.3. Type-approval requirements for CO 2 measurement and fuel consumption determination and 
reporting 
Conclusion 
Paving the ground for the introduction of an 
energy efficiency labelling schem. Allowing then 
the consumer to select optimum fuel efficient vehicle:- between different alternative L-category vehicles- between L-category vehicles and alternative means of road transport0Cost of development to Member State 
to develop proprietary labelling system, 
if not EU wide available
0Uniform EU-wide indication of CO2 
emission and fuel consumption
0
Compliance cost of manufacturers and 
further downstream0Stakeholders less confused, level of 
awareness0
Conclusion 
Paving the ground for the introduction of an 
energy efficiency labelling schem. Allowing then 
the consumer to select optimum fuel efficient vehicle:- between different alternative L-category vehicles- between L-category vehicles and alternative means of road transport++Cost of development to Member State 
to develop proprietary labelling system, 
if not EU wide available
+Uniform EU-wide indication of CO2 
emission and fuel consumption
++
Compliance cost of manufacturers and 
further downstream__Stakeholders less confused, level of 
awareness++Environmental objective: reduce air 
pollution from operation and reduce 
evaporative emissions until L-
category emissions proportionate to 
their actual use (3% of total road 
mileage)
++Environmental objective: reduce 
air pollution from operation and 
reduce evaporative emissions 
until L-category emissions 
proportionate to their actual use 
(3% of total road mileage)0
Objective Policy options CriteriaOption 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y Coherence
Effectiveness Efficienc y CoherenceOption 2: Type Approval for CO 2 and fuel consumption, vehicle labelling
 
Table 85: comparison and conclusion table Type-approval requirements for CO 2 measurement and fuel consumption 
determination and reporting 
 
EN 121   EN 1.4. Evaporative emissions test and limit 
Conclusion 
Evaporative hydrocarbon emission level0Additional compliance cost0Better coherence than options 2 and 3 
?0
Reducing exhaust and evaporative emissions
0Investment in evaporative emission 
control technology development of 
hardware and software. Additional cost may be passed on to customers0Increased clarity for industry and other 
stakeholders0
Level of cost effectiveness compared to other 
methods to reduce hydrocarbon emissions 0Revenue to supplier industry, including 
SMEs, potentially leading to effects on 
employment0Appropriate environmental measures 
for complete different vehicles 0
Availability of independent testing facilities 
(SHED chamber) for authorities, but also for 
SME0Level of simplification
0
Evaporative emissions controlled under different 
ambient conditions (hot climate, stop and go 
traffic) and/or over vehicle life.0Transparency with emission 
performance of other, alternative 
means of road transport0
Conclusion 
Evaporative hydrocarbon emission level+Additional compliance cost__Better coherence than options 2 and 3 
?+
Reducing exhaust and evaporative emissions
++Investment in evaporative emission 
control technology development of 
hardware and software. Additional cost may be passed on to customers__Increased clarity for industry and other 
stakeholders+
Level of cost effectiveness compared to other 
methods to reduce hydrocarbon emissions. 
NB assumption that investment in EFI will only be done to reduce evaporative emission is a theoretical assumption, therefore are the assumed cost and cost efficiency of this option estimated too high. No data available to quantify the level of magnitude of this too high estimate.0Revenue to supplier industry, including 
SMEs, potentially leading to effects on 
employment
++Appropriate environmental measures 
for complete different vehicles
++
Availability of independent testing facilities 
(SHED chamber) for authorities, but also for 
SMEs__Level of simplification
__
Evaporative emissions controlled under different 
ambient conditions (hot climate, stop and go 
traffic) and/or over vehicle life.__Transparency with emission 
performance of other, alternative 
means of road transport+
Conclusion 
Evaporative hydrocarbon emission level++Additional compliance cost__Better coherence than options 1 and 2 
?+
Reducing exhaust and evaporative emissions
0Investment in evaporative emission 
control technology development of 
hardware and software. Additional cost may be passed on to customers__Increased clarity for industry and other 
stakeholders+
Level of cost effectiveness compared to other 
methods to reduce hydrocarbon emissions. 
NB assumption that investment in EFI will only be done to reduce evaporative emission is a 
theoretical assumption, therefore are the 
assumed cost and cost efficiency of this option estimated too high. No data available to quantify the level of magnitude of this too high estimate.++Revenue to supplier industry, including 
SMEs, potentially leading to effects on 
employment
++Appropriate environmental measures 
for complete different vehicles
++
Availability of independent testing facilities 
(SHED chamber) for authorities, but also for __Level of simplification__
Evaporative emissions controlled under different 
ambient conditions (hot climate, stop and go 
traffic) and/or over vehicle life.__Transparency with emission 
performance of other, alternative 
means of road transport+Environmental objective: reduce air pollution from 
operation and reduce evaporative emissions until L-
category emissions proportionate to their actual use 
(3% of total road mileage)
+Environmental objective: reduce air pollution from 
operation and reduce evaporative emissions until L -
category emissions proportionate to their actual 
use (3% of total road mileage)++Option 3: Evaporative emissions test and limit enforcing evaporative emission control for all L-category vehicles
Objective Policy options Criteria
Effectiveness Efficienc y CoherenceEffectiveness Efficienc y CoherenceOption 2: Replacement of all new carburetted models with fuel injected ones. Due to the closed circuit, fuel injection engines result in much lower evaporation emissions than carburetted ones
Objective Policy options CriteriaOption 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y CoherenceEnvironmental objective: reduce air 
pollution from operation and reduce 
evaporative emissions until L-
category emissions proportionate to 
their actual use (3% of total road 
mileage)
0
 
Table 86: comparison and conclusion table evaporative emissions test and limit 
 
EN 122   EN 1.5. Durability requirements 
Conclusion 
Controlled degradation of exhaust emissions 
relevant engine components and systems 0Compliance cost for manufacturers 
possibly transferred into high consumer 
price0Better coherence than options 2 and 3 
? 0
Effect of actual defined vehicle mileage once 
opted to introduce durability requirements
0Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money over vehicle life in terms of steady environmental performance over vehicle life.0Increased clarity for industry and other 
stakeholders
0
Combined measure together with revised Type 
Approval emission limits
0Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of expensive exhaust after treatment components.0Appropriate environmental measures 
for complete different vehicles
0
Possible emission reduction level
0Level of simplification
0
Transparency with emission 
performance of other, alternative 
means of road transport0
Conclusion 
Controlled degradation of exhaust emissions 
relevant engine components and systems ++Compliance cost for manufacturers 
possibly transferred into high consumer 
price__Better coherence than options 1 and 2 
? 0
Effect of actual defined vehicle mileage once 
opted to introduce durability requirements
0Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money over vehicle life in terms of steady environmental performance over vehicle life.++Increased clarity for industry and other 
stakeholders
+
Combined measure together with revised Type 
Approval emission limits
++Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of expensive exhaust after treatment components.+Appropriate environmental measures 
for complete different vehicles
+
Possible emission reduction level+Level of simplification__
Transparency with emission 
performance of other, alternative 
means of road transport+
Conclusion 
Controlled degradation of exhaust emissions 
relevant engine components and systems ++Compliance cost for manufacturers 
possibly transferred into high consumer 
price__ __Better coherence than options 1 and 2 
? 0
Effect of actual defined vehicle mileage once 
opted to introduce durability requirements
0Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money over vehicle life in terms of steady environmental performance over vehicle life.++Increased clarity for industry and other 
stakeholders
+
Combined measure together with revised Type 
Approval emission limits
++Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of expensive exhaust after treatment components.+Appropriate environmental measures 
for complete different vehicles
+
Possible emission reduction level++Level of simplification__
Transparency with emission 
performance of other, alternative 
means of road transport++Environmental objective: reduce air pollution 
from operation and reduce evaporative 
emissions until L-category emissions 
proportionate to their actual use (3% of total 
road mileage)
++Environmental objective: reduce air pollution 
from operation and reduce evaporative emissions 
until L-category emissions proportionate to their 
actual use (3% of total road mileage)0
Objective Policy options CriteriaOption 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y Coherence
Effectiveness Efficienc y CoherenceOption 2 (Scenario 2 from the LAT report): Deterioration reduced to 10% for the useful life and application of linear extrapola tion for higher mileage
Option 3 (Scenario 2 from the LAT report): useful life increased by 60%, i.e. equivalent to the increase incurred to passenger cars when shifting from Euro 3 (80k km) to Euro 5 (160k km)
Objective Policy options Criteria
Effectiveness Efficienc y CoherenceEnvironmental objective: reduce air pollution 
from operation and reduce evaporative 
emissions until L-category emissions 
proportionate to their actual use (3% of total 
road mileage)
+
 
Table 87: comparison and conclusion table durability requirements 
 
EN 123   EN 2. N EW MEASURES TO CONTROL EMISSIONS DURING VEHICLE LIFE . 
2.1. In-Use Conformity (IUC) testing and limits. 
Conclusion 
Controlled degradation of exhaust emissions 
relevant engine components and systems 0Compliance cost for manufacturers 
possibly transferred into high consumer 
price0Better coherence than option 1 ?
0
Combined measure together with revised Type 
Approval emission limits
0Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money over vehicle life in terms of steady environmental performance over vehicle life.0Increased clarity for industry and other 
stakeholders
0
Possible emission reduction level
0Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of expensive exhaust after treatment components.0Appropriate environmental measures 
for complete different vehicles
0
Cost effectiveness 0 Level of simplification 0
Transparency with emission 
performance of other, alternative 
means of road transport0
Conclusion 
Controlled degradation of exhaust emissions 
relevant engine components and systems +Compliance cost for manufacturers 
possibly transferred into high consumer 
price__ __Better coherence than option 0 ?
0
Combined measure together with PTI and RSI, 
overlap
__Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money over vehicle life in terms of steady environmental performance over vehicle life.+Increased clarity for industry and other 
stakeholders
0
Possible emission reduction level
__ __Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of expensive exhaust after treatment components.0Appropriate environmental measures 
for complete different vehicles
+
Cost effectiveness__Level of simplification__
Selection of representative vehicles
__ __Transparency with emission 
performance of other, alternative 
means of road transport+Effectiveness Efficienc
y CoherenceOption 2: (Scenario 1 from LAT report): IUC procedure mandatory to for all Euro 3 motorcycles. The IUC is considered to identif y all not attainments which are consecutively corrected. Option 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y CoherenceEnvironmental objective: reduce air pollution 
from operation and reduce evaporative 
emissions until L-category emissions 
proportionate to their actual use (3% of total 
road mileage)
__Environmental objective: reduce air pollution 
from operation and reduce evaporative 
emissions until L-category emissions 
proportionate to their actual use (3% of total 
road mileage)
0
Objective Policy options Criteria
 
Table 88: comparison and conclusion table possible introduction of In-Use Conformity (IUC) testing and limits 
 
EN 124   EN 2.2. On Board Diagnostic (OBD) syst ems and access to repair information 
Conclusion 
Environmental impact 0 Compliance cost manufacturers 0 Better coherence than options 2 and 3 
?0
Ignoring Malfunction Indicator Light by customer 0 Employment at manufacturers 0 Increased clarity for industry and other 
stakeholders0
Functional safety impact 0 Initial investment cost for manufacturer 0 Appropriate environmental measures 
for complete different vehicles0
Standardised diagnostic information, available 
on request of generic scan tool0 Effectiveness of repair (perspective 
independent repairer)0 Level of simplification 0
Anti-tampering measure 0 Repair cost for customer (if repaired by 
independent repairer)0 Transparency with emission 
performance of other, alternative 
means of road transport0
Level of innovation in engine technology other 
than  to increase engine performance (power 
dt )0 Employment and revenue suppliers, 
type approval authorities, test 
lb t i0
Complexity of legislation 0 Cost of PTI in Member States that 
conduct this for L-category vehicles0
Enforcement (recall) 0
Access to technology by SME's 0
Paramount for the repair cycle (diagnose, 
access to repair and maintenance information, 0
Level of re-use of technology by manufacturer 0
Conclusion 
Environmental impact++Compliance cost manufacturers__ __Better coherence than options 1 and 3 
?0
Ignoring Malfunction Indicator Light by customer__Employment at manufacturers++Increased clarity for industry and other 
stakeholders+
Functional safety impact+Initial investment cost for manufacturer__ __Appropriate environmental measures 
for complete different vehicles++
Standardised diagnostic information, available 
on request of generic scan tool ++Effectiveness of repair (perspective 
independent repairer) ++Level of simplification
__ 
Anti-tampering measure
++Repair cost for customer (if repaired by 
independent repairer) +Transparency with emission 
performance of other, alternative 
means of road transport++
Level of innovation in engine technology other 
than  to increase engine performance (power 
and torque)++Employment and revenue suppliers, 
type approval authorities, test 
laboratories++
Complexity of legislation
__ __Cost of PTI in Member States that 
conduct this for L-category vehicles +
Enforcement (recall)0
Access to technology by SME's__
Paramount for the repair cycle (diagnose, 
access to repair and maintenance information, 
repair). Importance to free access to repair and maintenance information policy option to repair competition failure in internal market.+
Level of re-use of technology by manufacturer+
Conclusion 
Environmental impact+Compliance cost manufacturers__Better coherence than options 1 and 2 
?0
Ignoring Malfunction Indicator Light by customer__Employment at manufacturers++Increased clarity for industry and other 
stakeholders+
Functional safety impact+Initial investment cost for manufacturer__Appropriate environmental measures 
for complete different vehicles+
Standardised diagnostic information, available 
on request of generic scan tool++Effectiveness of repair (perspective 
independent repairer)+Level of simplification
__ 
Anti-tampering measure
+Repair cost for customer (if repaired by 
independent repairer) +Transparency with emission 
performance of other, alternative 
means of road transport++
Level of innovation in engine technology other 
than  to increase engine performance (power 
and torque)0Employment and revenue suppliers, 
type approval authorities, test 
laboratories+
Complexity of legislation__Cost of PTI in Member States that 
conduct this for L-category vehicles+
Enforcement (recall ) 0
Access to technology by SME's+
Paramount for the repair cycle (diagnose, 
access to repair and maintenance information, 
repair). Importance to free access to repair and maintenance information policy option to repair competition failure in internal market.++
Level of re-use of technology by manufacturer++Environmental objective: reduce air pollution from operation and reduce 
evaporative emissions until L-category emissions proportionate to their 
actual use (3% of total road mileage)+Environmental objective: reduce air pollution from operation and 
reduce evaporative emissions until L-category emissions 
proportionate to their actual use (3% of total road mileage)0
Objective Policy options CriteriaOption 1: No change (No introduction of OBD systems)
Objective Policy options Criteria
Effectiveness Efficienc y Coherence
Effectiveness Efficienc y CoherenceOption 2 (scenario 1 in LAT report): Application of OBD systems of similar technology to passenger cars (EOBD), including catal yst efficiency monitoring to all L-category vehicles. Introduction of free 
access to repair and maintenance provisions, similar as for passenger cars.
Environmental objective: reduce air pollution from operation and 
reduce evaporative emissions until L-category emissions 
proportionate to their actual use (3% of total road mileage)++Option 3 (scenario 1 in LAT report): Application of OBD systems of similar technology to passenger cars (EOBD), including catal yst efficiency monitoring to all L-category vehicles. Introduction of free 
access to repair and maintenance provisions, similar as for passenger cars.
Objective Policy options Criteria
Effectiveness Efficienc y Coherence
 
Table 89: comparison and conclusion table possible introduction On Board Diagnostic (OBD) systems and access to repair 
information
 
EN 125   EN 3. P ROPOSAL FOR REVISED EMISSION LIMITS  
3.1. Proposal to revise tailpipe emi ssion limits for the short term (2014) 
Vehicle 
category Vehicle 
category name Propulsion 
class Euro 
level Mass of 
carbon 
monoxide 
(CO) Mass of total 
hydrocarbons 
(THC) Mass of 
oxides 
of nitrogen 
(NOx) Mass of 
particulate 
Matter (PM) Sum mass of total 
hydrocarbons and oxides 
of nitrogen (THC + NOx) Test 
cycle 
    L1 (mg / L2 (mg / km)  L 3 (mg / km)  L 4 (mg / km)  L 5 (mg / km)  
L1Ae Powered cycle PI / Hybrid Euro 3  560 100 130 - -  UNECE regulation No 47 
L1Be Two-wheel moped PI / Hybrid Euro 3  1000 - - - 1200 UNECE regulation No 47 
L2e Three-wheel moped PI /Hybrid Euro 3  3500 - - - 1200 UNECE regulation No 47 
PI, v max < 
130 km/h Euro 4  1970 560 130 - - Revised WMTC, phase 2 
PI, v max ≥ 
130 km/h Euro 4  1970  250 170 - - Revised WMTC, phase 2 L3e 
L4e 
L5Ae 
L7Ae -Two-wheel motorcycle 
with and without side-
car 
- Tricycle 
- Heavy on-road quad 
 
 CI / Hybrid Euro 4  1000  100 570 10052 - Revised WMTC, phase 2 
PI Euro 3  4000 1000 250 - - UNECE regulation No 40 
L5Be Commercial 
tricycle 
CI / Hybrid Euro 3  1000 150 650 100 - UNECE regulation No 40 
L6Ae Light on-road quad PI / Hybrid Euro 3 3500    1200 UNECE regulation No 47 
PI Euro 3 3500    1200 UNECE regulation No 47 
L6Be Light mini-car 
CI / Hybrid Euro 3 1000 150 650 100  UNECE regulation No 47 
PI Euro 3  4000 1000 250 - - UNECE regulation No 40 
L7Be Heavy mini-car 
CI / Hybrid Euro 3 1000 150 650 100  UNECE regulation No 40 
 
Table 90: Proposed revised tailpipe emission limits53, Euro 3   
                                                 
52 CI only, also if e.g. a hybrid concept includes a CI engine. 
53 Category L3e vehicles: Euro 4 
 
EN 126   EN 3.2. Proposal to revise tailpipe emi ssion limits for the mid term (2017) 
Vehicle 
category Vehicle 
category name Propulsion  
class Euro 
level Mass of 
carbon 
monoxide 
(CO) Mass of total 
hydrocarbons 
(THC) Mass of 
oxides 
of nitrogen 
(NOx) Mass of 
particulate 
matter 
(PM) Test 
cycle 
  L1 (mg / km) L2 (mg / km)  L 3 (mg / km)  L 4 (mg / km)  
L1Ae Powered cycle PI / Hybrid Euro 4 560 100 70  UNECE regulation No 47 
L1Be Two-wheel moped PI / Hybrid Euro 4  1000 640 170 - UNECE regulation No 47 
L2e Three-wheel moped PI /Hybrid Euro 4  1900 740 170 - UNECE regulation No 47 
PI, v max < 
130 km/h Euro 5  1140 380 70 - Revised WMTC, phase 2 
PI, v max ≥ 130 
km/h Euro 5  1140  170 90 - Revised WMTC, phase 2 L3e 
L4eError! 
Bookmark 
not defined. 
L5Ae 
L7Ae -Two-wheel 
motorcycles with and 
without side-car 
- Tricycle 
- Heavy on-road quad CI / Hybrid Euro 5  1000  100 300 8052 Revised WMTC, phase 2 
PI Euro 4  2000 550 250 - UNECE regulation No 40 
L5Be Commercial 
tricycle CI / Hybrid Euro 4  1000 100 550 8052 UNECE regulation No 40 
L6Ae Light on-road quad PI / Hybrid Euro 4  1900 740  170 - UNECE regulation No 47 
PI Euro 4  1900 740  170  UNECE regulation No 47 
L6Be Light mini-car 
CI / Hybrid Euro 4  1000 100 550 8052 UNECE regulation No 47 
PI Euro 4  2000 550 250 - UNECE regulation No 40 
L7Be Heavy mini-car CI / Hybrid Euro 4 1000 100 550 8052 UNECE regulation No 40 
Table 91: Proposed revised tailpipe emission limits54, Euro 4  
                                                 
54 Category L3e vehicles: Euro 5. 
 
EN 127   EN 3.3. Proposal55 to revise tailpipe emission limits for the long term (2020) 
Vehicle 
category Vehicle 
category name Propulsion  
class Euro 
level Mass of 
carbon 
monoxide 
(CO) Mass of total 
hydrocarbons 
(THC) Mass of Non 
methane 
hydrocarbons 
(NMHC) Mass of 
oxides 
of nitrogen 
(NOx) Mass of 
particulate 
matter 
(PM) Test cycle 
  L1 (mg / km) L2A (mg / km)  L 2B (mg / km)  L 3 (mg / km)  L 4 (mg / km)  
L1Ae Powered cycle PI / Hybrid Euro 5  {500} {100} {68} {60} {4.5} {Revised WMTC} 
PI {1000} {100} {68} {60} {4.5} {Revised WMTC} 
L1Be — 
L7e All other L-category 
vehicles 
CI / Hybrid Euro 5  
{500} {100} {68}56 {90} {4.5}  {Revised WMTC} 
Table 92: Proposed revised tailpipe emission limits57, Euro 5  
                                                 
55 The braces around the limit values indicate that these have to be finally confirmed by an environmental effect study conducted  for the Commission. 
56 NMHC limit only applicable to a hybrid  vehicle equipped with a PI engine. 
57 Category L3e vehicles: Euro 6. 
 
EN 128   EN 3.4. Proposal for the introduction of On-board diagno stics emission thresholds for the mid term (2017) 
Vehicle 
category Vehicle 
category 
name Propulsion 
class Euro 
level Mass of 
carbon 
monoxide 
(CO) Mass of total 
hydrocarbons 
(THC) Mass of 
oxides 
of nitrogen 
(NOx) Test 
cycle 
    OT 1 (mg / 
km) OT 2 (mg / km)  OT 3 (mg / 
km)  
L1Be 
 
L2e 
 
L6Ae - Two-wheel 
moped 
- Three-wheel 
moped 
-On-road 
light quad PI or 
Hybrid Euro 4  3610 2720 850 UNECE regulation No 47  
PI 
vmax < 130 
km/h 3740 2060 650 Revised WMTC, phase 2 
PI 
vmax ≥ 130 
km/h 3740 920 850 Revised WMTC, phase 2 L3e 
L4eError! 
Bookmark not 
defined. 
 
L5Ae 
 
L7Ae -Two-wheel 
motorcycle 
with and 
without side-
car 
- Tricycle 
- Heavy on-
road quad CI or 
Hybrid Euro 4  
1900 640 1710 Revised WMTC, phase 2 
Table 93: Proposed Euro 4 OBD emission thresholds54, OBD stage I 
3.5. Proposal55 to revise the On-board diagnostics emission thresholds for the long term (2020) 
Vehicle 
category Vehicle 
category 
name Propulsion  
class Euro 
level Mass of 
carbon 
monoxide 
(CO) Mass of Non 
methane 
hydrocarbons 
(NMHC) Mass of 
oxides 
of nitrogen 
(NOx) Mass of 
particulate 
matter 
(PM) Test 
cycle 
    OT 1 (mg / 
km) OT 2 (mg / km)  OT 3 (mg / 
km) OT 4 (mg / 
km)  
PI Euro 5  {1900} {250} {300} {50} {Revised 
WMTC} {L1Be — 
L7e} All L 
category 
vehicles 
except 
category CI or 
Hybrid Euro 5  {1900} {320} {375} {50} {Revised 
WMTC} 
Table 94: Proposed Euro 5 OBD emission thresholds57 {OBD stage I, and OBD stage II}55 
 
EN 129   EN 3.6 Proposal for the introduction of evaporative emission threshold (2017)  
Vehicle 
category Vehicle 
category name Propulsion  
class Euro 
level Mass of total hydrocarbons 
(THC) (mg / test)  Test cycle 
L3e 
L4e Two-wheel motorcycle 
with and without side-car PI58 
vmax ≥ 130 km/h  Euro 5 
L6A Light on-road quad PI Euro 4 
L7Ae Heavy on-road quad PI Euro 4  2000 SHED 
Table 95: Proposed revised evaporative emission limit, Euro 454 
3.7 Proposal55 to revise the evaporative emission threshold (2020) 
Vehicle 
Class Vehicle 
class name Propulsion 
Class Euro 
level Mass of total hydrocarbons 
(THC) (mg / test)  Test 
cycle 
{L1Ae} {Powered cycle} {Euro 5} 
{L1B} {Two-wheel moped} {Euro 5} 
{L2} {Three-wheel moped} {Euro 5} 
L3e 
L4 Two-wheel motorcycle 
with and without side-car Euro 6 
{L5A} {Tricycle} {Euro 5}  
{L5B} {Commercial tricycle} {Euro 5} 
L6A Light on-road quad Euro 5 
{L6B} {Light mini-car} {Euro 5} 
L7A Heavy on-road quad Euro 5  
{L7B} {Heavy mini-car} PI 
{Euro 5} {2000} / {TBD} SHED /  
{SHED} or {Fuel Tank and Fuel 
tubing permeation test}59 
Table 96: Proposed revised evaporative emission limit, Euro 557 
                                                 
58 PI engines running on gasoline,  gasoline blends or ethanol. 
59 The cost-effectiveness of evaporative emission control will among others be assessed in the environmental effect study to be c arried out for the Commission. Other cost-effective evaporative 
testing methods like fuel tank and fuel s upply permeation testing will be assessed in this study as an alternative to the SHED test for vehicle categories other than L3e, L6Ae and L7Ae. 
 
EN 130   EN ANNEX  XVI:  DETAILS CHAPTER 6 — OPTIONS COMPARISON AND CONCLUSIONS — ANALYSIS NEW VEHICLE TYPE 
APPROVAL SAFETY MEASURES  
1. FITTING OF ADVANCED BRAKE SYSTEMS  
__ __ much worse
__worse
0 neutral (no change)
+ better
++ much betterExplanation:
 
1.1. No change 
Conclusion 
00 0 01: No policy changeOption 1: No change
Objective Policy options Criteria
Effectiveness Efficiency Coherence
 
Table 97: option comparison and conclusion table — fitting of Advanced Brake systems — option 1 
1.2. Anti-lock Brake Systems on all Powered Two Wheelers (PTW) 
Level of fatalities and injured riders in PTW 
involved road accidents++Low consumer price of PTW__ __better coherence than options 3,4 and 
50
Anti-lock  Brake System is the only technical 
solution which directly monitors and prevents 
wheel lockin g.++Level of cost to society owing to cost of 
health care, lost working days etc ++increased clarity for industry and other 
stakeholders +
With Anti-lock  Brake System higher braking 
decelerations achieved (resulting in less braking distance) than with conventional brakes only. 
Potential reduction in impact speed in case of 
collision++Insurance cost for consumer
+
Preventing wheel lock under emergency braking 
provides the rider with increased confidence to 
apply higher brake forces. More efficient braking 
with Anti-lock  brake system, rider brakes 
earlier during brake manœuvre++Potential customers not purchasing 
PTWs owing to being victim of road 
accident +
Inexperienced riders on PTW with Anti-lock 
Brake System able to achieve decelerations 
closer to that of experienced riders, after 
relativel
y short trainin g / ada ptation time++Cost effectiveness obligatory Anti-lock 
brake system. Majority of in total 11 
predictive and retrospective literature 
study results are positive.++
Vehicles fitted with  Anti-lock  Brake System are 
able to make use of the adhesion available 
when on low and high friction surfaces. (e.g. 
changing conditions from dry to wet road)++Economy of scales for Anti-lock 
Braking System production, mid to long 
term drop of development and 
production cost ++
Anti-lock  brake systems prevents dangerous 
downfalls whilst braking. In case of critical wheel -
lock of front wheel PTW rider falls and slides uncontrolled over the road++Revenue and employment supplier 
industry++
Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system 
fitted. Long term societal and economic benefits++Market penetration of Anti-lock brake 
system++
Estimated fatality and heavily injured rider 
reduction++Manufacturing and development cost of 
PTWs equipped with Anti-lock  Brake 
Systems, possibly passed on to 
consumer 
(possible price increase )__ __
Risk of rider becoming "over" confident if PTW 
equipped with advanced brake system, trusts 
too much on technology. Higher speed_Risk of unavailability of Anti-lock Brake 
System technology to SME's (not 
meeting entrance criteria to be supplied 
by bigger automotive suppliers or 
confronted with high development cost 
as supplier cannot amortise investments owing to low series production)__ __
Possible bad braking performance (adverse 
effects off-road) if Anti-lock Brake System fitted 
on Off-road PTW_Risk of short term price increase owing 
to manufacturers forced to buy systems 
and components from suppliers._
Additional rules for design of brake system to 
industry making legislation more complex._Level of legislation complexity_
Legislation not technology neutral, mandating a 
specific technology. Normally legislation just defines the performance criteria.  __ __
Level of technical complexity of vehicle 0
Level of brake technology innovation 0
Riding training required for system to be 
effectively0Option 2: Anti-lock Brake S
ystems on all Powered Two Wheelers (PTW )
Objective Policy options CriteriaConclusion Effectiveness Efficienc y CoherenceIncreased SafetyAnti-lock Brake 
Systems on all 
Powered Two 
Wheelers (PTW)+
 
Table 98: option comparison and conclusion table — fitting of Advanced Brake systems — option 2 
 
EN 131   EN 1.3. Anti-lock Brake Systems on PTWs with cylinder capacity60 > 125 cm3 and Advanced Brake 
Systems (Combined Brake System (CBS) or An ti-lock Brake Systems (ABS) on motorcycles 
with 50 cm3 < cylinder capacity61 ≤ 125 cm3 
Level of fatalities and injured riders in PTW 
involved road accidents++Low consumer price of PTW__ __better coherence than options 3,4 and 
50
Anti-lock  Brake System is the only technical 
solution which directly monitors and prevents 
wheel locking.++Level of cost to society owing to cost of 
health care, lost working days etc ++increased clarity for industry and other 
stakeholders +
With Anti-lock  Brake System higher braking 
decelerations achieved (resulting in less braking 
distance) than with conventional brakes only. 
Potential reduction in impact speed in case of 
collision++Insurance cost for consumer
+
Preventing wheel lock under emergency braking 
provides the rider with increased confidence to apply higher brake forces. More efficient braking 
with Anti-lock  brake system, rider brakes 
earlier during brake manœuvre++Potential customers not purchasing 
PTWs owing to being victim of road accident +
Inexperienced riders on PTW with Anti-lock 
Brake System able to achieve decelerations 
closer to that of experienced riders, after 
relatively short training / adaptation time++Cost effectiveness obligatory Anti-lock 
brake system. Majority of in total 11 
predictive and retrospective literature 
study results are positive.++
Vehicles fitted with  Anti-lock  Brake System are 
able to make use of the adhesion available when on low and high friction surfaces. (e.g. 
changing conditions from dry to wet road)++Economy of scales for Anti-lock 
Braking System production, mid to long 
term drop of development and 
production cost ++
Anti-lock  brake systems prevents dangerous 
downfalls whilst braking. In case of critical wheel
-
lock of front wheel PTW rider falls and slides 
uncontrolled over the road++Revenue and employment supplier 
industry++
Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system 
fitted. Long term societal and economic benefits+Market penetration of Anti-lock  brake 
system++
Estimated fatality and heavily injured rider 
reduction+Manufacturing and development cost of 
PTWs equipped with Anti-lock  Brake 
Systems, possibly passed on to 
consumer (possible price increase )__ __
Risk of rider becoming "over" confident if PTW 
equipped with advanced brake system, trusts 
too much on technology. Higher speed
_Risk of unavailability of Anti-lock Brake 
System technology to SME's (not 
meeting entrance criteria to be supplied 
by bigger automotive suppliers or 
confronted with high development cost as supplier cannot amortise investments 
owing to low series production)__ __
Possible bad braking performance (adverse 
effects off-road) if Anti-lock Brake System fitted 
on Off-road PTW_Risk of short term price increase owing 
to manufacturers forced to buy systems 
and components from suppliers._
Additional rules for design of brake system to 
industry making legislation more complex._Level of legislation complexity_
Legislation not technology neutral, mandating a 
specific technology. Normally legislation just defines the performance criteria.  __ __
Level of technical com
plexity of vehicle 0
Freedom of choice regarding product and 
product characteristics0
Level of brake technology innovation 0Option 3: Anti-lock Brake Systems on PTWs with cylinder capacity >125cm3 and Advanced Brake Systems (Combined Brake System 
               (CBS) and/or Anti-lock Brake S ystems (ABS )) on motorc ycles with 50cm3 < c ylinder ca pacity  <= 125cm3 
Effectiveness Efficienc y CoherenceObjective Policy options CriteriaConclusion Increased SafetyAnti-lock Brake 
Systems on PTWs 
with cylinder capacity 
>125cm3 and 
Advanced Brake 
Systems (Combined 
Brake System 
               (CBS) 
and/or Anti-lock 
Brake Systems 
(ABS)) on 
motorcycles with 
50cm3 < cylinder 
capacity  <= 125cm3++
 
Table 99: option comparison and conclusion table — fitting of Advanced Brake systems -option 3 
                                                 
60 The 125 cm3 takes reference to the thresholds in Directive 2006/126/EC  (recasted driving licence di rective) related to class 
A1: motorcycles with a cylinder capacity not exceeding 125 cm3, of a power not exceeding 11kW and with a power/weight 
ratio not exceeding 0.1 kW/kg. 
61 The 125 cm3 takes reference to the thresholds in Directive 2006/126/EC  (recasted driving licence di rective) related to class 
A1: motorcycles with a cylinder capacity not exceeding 125 cm3, of a power not exceeding 11kW and with a power/weight 
ratio not exceeding 0.1 kW/kg. 
 
EN 132   EN 1.4. Obligatory fitting of Advanced Brake Syst ems (Combined Brake System  (CBS) and/or Anti-
lock Brake Systems (ABS)) on  motorcycles fulfilling the m aximum performance criteria 
related to the A2 driving licence62. Obligatory fitting of Anti-lock Brake Systems on all other 
L3e class motorcycles. 
Level of fatalities and injured riders in PTW 
involved road accidents+Low consumer price of PTW better coherence than options 3,4 and 
5
Anti-lock  Brake System is the only technical 
solution which directly monitors and prevents wheel locking.++Level of cost to society owing to cost of 
health care, lost working days etcincreased clarity for industry and other 
stakeholders
With Anti-lock  Brake System higher braking 
decelerations achieved (resulting in less braking 
distance) than with conventional brakes only. 
Potential reduction in impact speed in case of 
collision++Insurance cost for consumer
Preventing wheel lock under emergency braking 
provides the rider with increased confidence to apply higher brake forces. More efficient braking 
with Anti-lock  brake system, rider brakes 
earlier during brake manœuvre++Potential customers not purchasing 
PTWs owing to being victim of road accident
Inexperienced riders on PTW with Anti-lock 
Brake System able to achieve decelerations 
closer to that of experienced riders, after 
relativel
y short trainin g / ada ptation time++Cost effectiveness obligatory Anti-lock 
brake system. Majority of in total 11 
predictive and retrospective literature 
study results are positive.
Vehicles fitted with  Anti-lock  Brake System are 
able to make use of the adhesion available 
when on low and high friction surfaces. (e.g. 
changing conditions from dry to wet road)++Economy of scales for Anti-lock 
Braking System production, mid to long 
term drop of development and 
production cost 
Anti-lock  brake systems prevents dangerous 
downfalls whilst braking. In case of critical wheel -
lock of front wheel PTW rider falls and slides 
uncontrolled over the road++Revenue and employment supplier 
industry
Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system 
fitted. Long term societal and economic benefits++Market penetration of Anti-lock  brake 
system
Estimated fatality and heavily injured rider 
reduction+Manufacturing and development cost of 
PTWs equipped with Anti-lock Brake 
Systems, possibly passed on to 
consumer (possible price increase)
Risk of rider becoming "over" confident if PTW 
equipped with advanced brake system, trusts 
too much on technology. Higher speed
_Risk of unavailability of Anti-lock Brake 
System technology to SME's (not 
meeting entrance criteria to be supplied 
by bigger automotive suppliers or 
confronted with high development cost 
as supplier cannot amortise investments 
owing to low series production)
Possible bad braking performance (adverse 
effects off-road) if  Anti-lock  Brake System 
fitted on Off-road PTW_Risk of short term price increase owing 
to manufacturers forced to buy systems 
and components from suppliers.
Additional rules for design of brake system to 
industry making legislation more complex._Level of legislation complexity
Legislation not technology neutral, mandating a 
specific technology. Normally legislation just defines the performance criteria.  __ __
Level of technical complexity of vehicle 0
Freedom of choice regarding product and 
product characteristics0
Level of brake technolo
gy innovation 0
Horizontal harmonisation of vehicle performance criteria between type approval and 
drivin
g licence le gislation (simplification )+Coherence Efficienc y
++Option 4: To make mandatory the fitting of Advanced Brake Systems (Combined Brake System (CBS) and/or Anti-lock Braking Systems ) on those motorcycles which conform to the 
performance criteria defined by the A2 driving licence . Obligatory fitting of Anti-lock Brake Systems on all other L3 class mo torcycles
Objective Policy options CriteriaConclusion EffectivenessIncreased SafetyTo make mandatory 
the fitting of 
Advanced Brake 
Systems (Combined 
Brake System (CBS) 
and/or Anti-lock 
Braking Systems) on 
those motorcycles 
which conform to the 
performance criteria 
defined by the A2 
driving licence . 
Obligatory fitting of 
Anti-lock Brake 
Systems on all other 
L3 class motorcycles
 
Table 100: option comparison and conclusion table — fitting of Advanced Brake systems — option 4 
                                                 
62 Thresholds obtained from Directive 2006/126/ EC (recasted driving licence directive) class A2: 1) power not exceeding 35 kW, 
with 2) a power/weight ratio not exceeding 0.2 kW/kg, and 3) not derived from a vehicle of more than double its power. These 
are EU wide accepted criteria to separate less powerful PT Ws that beginning riders only ma y ride during the two subsequent 
years of getting their driving licence on one hand from powerf ul motorcycles that may only driven by more experienced 
motorcycle riders on the other hand. 
 
EN 133   EN 1.5. Industry self obligation 
Level of fatalities and injured riders in PTW 
involved road accidents _Low consumer price of PTW
+better coherence than options 3,4 and 
5 0
CBS is full alternative to Anti-lock  brake 
system, technical equivalence assumed 
between both s ystems 0Level of cost to society owing to cost of 
health care, lost working days etc 0increased clarity for industry and other 
stakeholders +
With Anti-lock  Brake System higher braking 
decelerations achieved (resulting in less braking distance) than with conventional brakes only. 
Potential reduction in impact speed in case of collision+Insurance cost for consumer
++
Preventing wheel lock under emergency braking 
provides the rider with increased confidence to 
apply higher brake forces. More efficient braking with Advanced Brake System, rider brakes earlier during brake manœuvre+Potential customers not purchasing 
PTWs owing to being victim of road 
accident +
Inexperienced riders on PTW with Anti-lock 
Brake System able to achieve decelerations closer to that of experienced riders, after relatively short training / adaptation time+Cost effectiveness Advanced Brake 
Systems according to industry self-
obligation scheme (either Anti-lock Brake System and/or CBS)+
Vehicles fitted with  Anti-lock  Brake System are 
able to make use of the adhesion available 
when on low and high friction surfaces. (e.g. changing conditions from dry to wet road)+Economy of scales for Advanced 
Braking System production, mid to long 
term drop of development and 
production cost +
Anti-lock  brake systems prevents dangerous 
downfalls whilst braking. In case of critical wheel
-
lock of front wheel PTW rider falls and slides 
uncontrolled over the road0Revenue and employment supplier 
industry__
Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system 
fitted. Long term societal and economic benefits+Market penetration of Anti-lock  brake 
system__
Estimated fatality and heavily injured rider 
reduction__Manufacturing and development cost of 
PTWs equipped with Anti-lock Brake Systems, possibly passed on to 
consumer (possible price increase)+
Risk of rider becoming "over" confident if PTW 
equipped with advanced brake system, trusts 
too much on technology. Higher speed
__ __Risk of unavailability of Anti-lock Brake 
System technology to SME's (not 
meeting entrance criteria to be supplied by bigger automotive suppliers or 
confronted with high development cost 
as supplier cannot amortise investments owing to low series production)+
Possible bad braking performance (adverse 
effects off-road) if Anti-lock  Brake System 
fitted on Off-road PTW__ __Risk of short term price increase owing 
to manufacturers forced to buy systems 
and components from suppliers.+
Additional rules for design of brake system to 
industry making legislation more complex.
__ __Less burden (impact of legislation on 
vehicle design) in industry (mainly for big players, small manufacturers may 
still struggle to fulfil self regulation quota if above small series threshold)+
Legislation not technology neutral, mandating a 
specific technology. Normally legislation just defines the performance criteria.  0Level of intervention: Conventional 
consumer price development owing to supply and demand0
Level of technical complexit
y of vehicle 0 Level of le gislation complexit y 0
Freedom of choice regarding product and 
product characteristics
++SME's under normal market pressure to 
equip produced vehicles with advanced 
brake systems. Concern related to access to technology  postponed / only mitigated, not eliminated__
Level of brake technology innovation
0Consumer price of Advanced Brake 
System determined by normal market 
mechanism of supply and demand. 
Consumer opting for Anti-lock  Brake 
System and/or CBS can only partly benefit from pressure on advanced 
brake system price (lower level of 
econom
y of scales for manufacturer )__Efficienc y CoherenceIncreased SafetyOption 5: Industry 
self regulation 
proposal__Option 5: Industry self regulation proposal
Objective Policy options CriteriaConclusion Effectiveness
 
Table 101: option comparison and conclusion table — fitting of Advanced Brake systems -option 5 
 
EN 134   EN 1.6. Impact Assessment of Anti -lock Brake System technology fitted on vehicles, manufactured 
and type approved by SMEs 
1.6.1. Introduction 
As part of the impact assessment of the proposed Regulation for the type approval of L-category vehicles, an 
analysis of possible effects on SMEs in the relevant bu siness sectors must be conducted. In accordance with 
the definitions laid down in Recommendation 2003/361/E C, a medium sized enterprise employs between 50-
249 workers. A small enterprise has 10-49 employees whereas micro enterprises employ up to nine persons. 
It is important to keep these distinctions in mind giv en that precise employment numbers in SMEs in the 
PTW industry are difficult to obtain, but recent data colle cted by EuroStat suggests that within the EU micro 
companies account for the biggest share of SMEs manufacturing cycles as well as motorcycles. 
Unfortunately the data for each type of manufacturer cannot be disaggregated. In addition this data should 
be referenced with caution owing to 2 constraints. 
For the sake of clarity and completeness, it is important  to point out that the data provided by EuroStat can 
only be used to gain a generic picture of the Cycle and L-category vehicle market since it lacks precision in 
two important ways. First, the data incl udes the manufacture of cycles which is problematic in the sense that 
the cycle market strongly varies from the PTWs ma rket. The cycle market is very diversified and 
heterogeneous in terms of producers which often constitu te of micro companies. This strongly contrasts with 
the motorcycle market which is far more concen trated. Second, the data does not specify the term 
‘manufacturer’ which is paramount for the underlyin g assessment since the proposed Regulation will only 
cover OEMs that market their products complying with requirements for Whol e Vehicle Type Approval 
(WVTA). Accordingly, all SMEs that might fall under t he definition of manufacturer in the EuroStat database 
but which are only active in the business of vehicle modi fications are not of primary concern in this impact 
assessment since their end products may be subject to national type approvals. 
1.6.2. Regulatory Impacts on SMEs 
In respect of the assessment of regulatory impacts on SMEs, there are some general points worth to be kept 
in mind. Hence, the introduction of new regulatio ns can be a disproportionately bigger burden for SME 
manufacturers because of scarcer resources. Any additional costs caused by a new regulatory framework 
can have a substantial negative impact on the commerci al viability of SME OEMs because of compliance 
costs and a lack of information or expertise which in many cases has to be bought from specialists outside 
the company. Furthermore, SME ma nufacturers have only a limited sco pe for benefiting from economies of 
scale and face severe constraints in passing on increases  in costs to their customers because they generally 
act as price takers on the market. Moreover, especially in  the context of the current crisis it is important to 
remember that the access to capital is restricted for SMEs which makes major investments difficult if often 
not impossible. On the other hand, SMEs are characteri sed by their high flexibility and their ability to adapt to 
new market conditions quickly. As such they are ther efore quicker to meet new market demands than their 
larger counterparts. There may also be component s and systems (hardw are) and software required by 
manufacturers to be able to comply with new or revised legal requirements. This demand for certain niche 
products, not interesting to be mass produced by t he major automotive suppliers, or highly specialised 
products or software solutions may be the high added value that specialised SME suppliers can provide. 
1.6.3. Economic Advantages 
There are a number of economic advantage s in case of introduction of mandatory Anti-lock  Brake Systems 
on PTWs. Hence, positive impact on society as a whole by  fatality prevention and possible injury mitigation in 
road accidents of PTW riders positively  correlate with the industry’s economic interests since it will retain 
first-line potential clients. Related to this is the increase in consumer confidence. This argument has 
essentially two aspects. First, on a more general level ma king the use of motorcycles safer will remove some 
of the safety concerns which are beneficial for acqui ring new customers as well as for winning back old 
customers. Given some customers’ tendency to be up to date with the newest technological developments, 
the legislative proposal could hav e a positive impact on sale number s since it encourages customers to 
upgrade their vehicle. Second, it will improve the individual brand image of motorcycle producers since they 
do not have an interest in being perceived as marketi ng second-class quality products. There is clearly no 
interest in being considered as lagging behind in terms of  safety standards in an industry where safety issues 
play an increasingly greater role. Thus, due to the technological advancement brought by Anti-lock  Brake 
System the product becomes more attractive. In additi on, the attractiveness could also be raised by lower 
 
EN 135   EN insurance premiums offered for PTWs with Anti-lock  Brake Systems. With r egard to new distribution 
channels, the downstream market that practically cons ists of SMEs could also profit from the measure 
envisaged. Hence, requiring the fitting of Anti-lock  Brake System could encourage the emergence of a new 
niche distribution channel, e.g. outlets spec ialising in the safest motorbikes only.  
1.6.4. Possible Disadvantages 
As regards the disadvantages of the mandatory fitting of Anti-lock  Brake System, it is obv ious that there is a 
probability that the additional costs of fitting this braki ng system will be added up to the market price of the 
vehicle with an adverse effect on the vehicle’s compet itiveness. However, it needs to be remembered that 
safer motorcycles could attract additional customers and, furthermore, economy of scales and market 
pressure may soon lead to a new equilibrium. In this  context, it remains to be seen in how far SMEs 
manufacturing motorcycles in relatively low volumes will be able to cope with the competitive pressure to 
lower prices given that they do not profit from large ec onomies of scale. In this context, however, it needs to 
be remembered that thro ugh an appropriate mark eting strategy, SMEs could also  have the possibility to get 
an extra margin on their products sinc e new advancements in safety matters  could justify higher prices. From 
the perspective of the Anti-lock  Brake System supplier, it is worthwhile  to state that in the short term the 
prices for Anti-lock  Brake System systems could rise given the sudden increase in demand which could 
translate into higher vehicle prices.  
1.6.5. Potential Opportunities 
Despite the potential disadvantages, the mandatory fitting of Anti-lock  Brake System also brings 
opportunities for SMEs. Alongside the advantages ment ioned above, SME suppliers would have the chance 
to specialise in the production of Anti-lock  Brake System braking systems since the demand for this system 
will significantly increase. In this co ntext, there is even the possibility of the development of certain synergy 
effects between two SMEs where one focuses on the produc tion of motorbikes whereas the other specialises 
on the supply of corresponding braking systems that are tailor-made for a sp ecific brand. In this sense, both 
could profit from the conclusion of exclusive supply agreements and an improved brand image.  
1.6.6. Potential Risks  
In respect of potential risks of the compulsory fitting of Anti-lock  Brake System, there is a danger that certain 
SMEs manufacturing PTWs will not have access to Anti-lock  Brake System technology. There are two 
reasons for this observation. First, the R&D expenses for this technology are prohibitive and, thus, only the 
SME manufacturers producing high end PTWs may inve st to develop the technolog y on its own. That is 
particularly true for SME manufacturers with low produ ction volumes where economies of scale are very 
small. Second, in order to get the required tec hnology, SME OEMs will have to rely on automotive 
technology suppliers and buy the technology from them. The problem with this scenario is that their purchase 
order might be too small and, hence, suppliers may refuse  to deal with them since the profit margins are not 
high enough or the supplier may not even reach its break even point with these customised Anti-lock  Brake 
System. In the worst case scenario a SME OEM might not find a supplier willing to supply Anti-lock  Brake 
System technology which would basically amount to  an inability to sell its products if the fitting of Anti-lock  
Brake System was to be made mandatory. With the purpose to address this problem, various solutions may be considered. One solution could be to set a sale number threshold for a product below which a SME 
producer does not have to comply with the Anti-lock  Brake System requirement (small series requirements). 
Another possibility is to en sure that every SME manufac turer will get access to 
Anti-lock  Brake System 
technology at an affordable price. In this regard , the idea of a voluntary commitment on the part of Anti-lock  
Brake System suppliers to supply SMEs could be a nother possibility to ease t he fears expressed above. 
 
EN 136   EN 2. Anti-tampering measures  
__ __ much worse
__worse
0 neutral (no change)
+ better
++ much betterExplanation:
 
2.1. No change; 
Conclusion 
General interest in customising and 
modification, good for technical education0Road tax contribution0better coherence than options 2, & 3 ?0
Driver licensing restrictions 
0Insurance premium
0increased clarity for industry and other 
stakeholders 0
By-passing recurring technical inspections
0Economic impact on the suppliers of the 
parts which are no longer required 
(information stickers, frangible bolts 
t)0
Emission of noise, exhaust emission levels, fuel 
consum ption and CO2.0Economic effect on tampering industry0
Prevent to exceed maximum vehicle speed for e
0
Electronic manipulation: effectiveness of 
existing anti-tampering measures 0
Risk to be involved in accident0
Enforcement results successful ?0
Level of innovation0
Effectiveness of chapter 7, ten years after 
introduction largely unknown0
Level of obsolete measures0
Theft of vehicles
00 1: No policy changeOption 1: No change
Objective Policy options Criteria
Effectiveness Efficiency Coherence
 
Table 102: option comparison and conclusion table, anti-tampering measures, option 1 
2.2. Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures; 
General interest in customising and 
modification, good for technical education++Road tax contribution__ __better coherence than options 1, & 3 ?__ __
Driver licensing restrictions __ __Insurance premium__ __increased clarity for industry and other 
stakeholders__ __
By-passing recurring technical inspections
__ __Economic impact on the suppliers of the 
parts which are no longer required 
(information stickers, frangible bolts 
etc.)__ __
Emission of noise, exhaust emission levels, fuel 
consum ption and CO2.__ __Economic effect on tampering industry__ __
Prevent to exceed maximum vehicle speed for e
__ __
Electronic manipulation: effectiveness of 
existing anti-tampering measures__ __
Risk to be involved in accident__ __
Enforcement results successful ?__ __
Level of innovation__
Effectiveness of chapter 7, ten years after 
introduction largely unknown0
Level of obsolete measures__ __
Theft of vehicles
__ ____ __Objective Policy options Criteria Conclusion 
Effectiveness Efficienc y CoherenceIncreased SafetyOption 2: Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tamperin g measures
 
Table 103: option comparison and conclusion table, anti-tampering measures, option 2 
 
EN 137   EN 2.3. New measures on anti-tampering. 
General interest in customising and 
modification, good for technical education++Road tax contribution0better coherence than options 1, & 2 ?+
Driver licensing restrictions 0Insurance premium+increased clarity for industry and other 
stakeholders+
By-passing recurring technical inspections
0Economic impact on the suppliers of the 
parts which are no longer required 
(information stickers, frangible bolts 
etc.)__
Emission of noise, exhaust emission levels, fuel 
consum ption and CO2.++Economic effect on tampering industry0
Prevent to exceed maximum vehicle speed for 
e.g. Mopeds+
Electronic manipulation: effectiveness of 
existing anti-tampering measures++
Risk to be involved in accident+
Enforcement results successful ? +
Level of innovation+
Effectiveness of chapter 7, ten years after 
introduction largely unknown0
Level of obsolete measures +
Theft of vehicles ++Increased SafetyEffectiveness Efficienc y CoherenceObjective Policy options Criteria Conclusion Option 3 New  measures on anti-tamperin g
 
Table 104: option comparison and conclusion table, anti-tampering measures, option 3 
 
EN 138   EN 3. 74 kW power limitation for motorcycle 
__ __ much worse
__worse
0 neutral (no change)
+ better
++ much betterExplanation:
 
Conclusion 
Number of Member States that apply the 74kW 
power limit through national legislation could 
increase0Minimum Economic impact
0better coherence than options 2,3,4 ?
0
No clear evidence to suggest that limiting the 
power of a motorcycle to 74kW has a positive 
impact on the number of road accidents 
involving motorcycles. Other factors such as 
rider attitude and experience have a greater 
influence on accident risk0Cost to the manufacturers to produce 
the restricted motorcycles
0increased clarity for industry and other 
stakeholders
0
Effect on the noise generation, emissions and 
fuel consumption
0Impact on some specialist (SME) 
manufacturer's revenue and cost that 
concentrate on the production of high 
powered motorcycles0
Member State may save cost by 
rescinding National Legislation0
Internal market with less barriers, 
reduced technical and administration burden on manufacturers. Lower 
price 0
Number of Member States that apply the 74kW 
power limit through national legislation could 
increase0Minimum Economic impact
+better coherence than options 3 &4 ?
+
No clear evidence to suggest that limiting the 
power of a motorcycle to 74kW has a positive impact on the number of road accidents 
involving motorcycles. Other factors such as 
rider attitude and experience have a greater 
influence on accident risk+Cost to the manufacturers to produce 
the restricted motorcycles
++increased clarity for industry and other 
stakeholders
+
Effect on the noise generation, emissions and 
fuel consumption0Impact on some specialist (SME) 
manufacturer's revenue and cost that 
concentrate on the production of high 
powered motorcycles+
Member State may save cost by 
rescinding National Legislation+
Internal market with less barriers, 
reduced technical and administration 
burden on manufacturers. Lower price 
to consumer++
Number of Member States that apply the 74kW 
power limit through national legislation could 
increase0Minimum Economic impact
__ __better coherence than options 2&4 ?
+
No clear evidence to suggest that limiting the 
power of a motorcycle to 74kW has a positive 
impact on the number of road accidents 
involving motorcycles. Other factors such as 
rider attitude and experience have a greater 
influence on accident risk+Cost to the manufacturers to produce 
the restricted motorcycles
__increased clarity for industry and other 
stakeholders
+
Effect on the noise generation, emissions and 
fuel consumption
0Impact on some specialist (SME) 
manufacturer's revenue and cost that concentrate on the production of high 
powered motorcycles__ __
Member State may save cost by 
rescinding National Legislation+
Internal market with less barriers, 
reduced technical and administration 
burden on manufacturers. Lower price 
to consumer+Option 2: Repeal the option given to Member States to limit the power to 74kW.Option 1: No change
Objective Policy options Criteria
Effectiveness Efficiency Coherence
+
Option 3: Set a harmonized limit of 74kW. Objective Policy options Criteria Conclusion 
Effectiveness Efficienc y Coherence
Objective Policy options Criteria Conclusion Increased Safety
0
__Increased SafetyEffectiveness Efficienc y CoherenceIncreased Safety
 
Table 105: option comparison and conclusion table, 74 kW power limitations for motorcycles, options 1 to 4 
 
EN 139   EN ANNEX  XVII:  DETAILS CHAPTER 6 — OPTIONS COMPARISON AND CONCLUSIONS — IMPROVED CATEGORISATION OF 
L-CATEGORY VEHICLES  
__ __ much worse
__worse
0 neutral (no change)
+ better
++ much betterExplanation:
 
1. RECATEGORISATION ELECTRICAL CYCLES (OUTSIDE SCOPE OF FRAMEWORK DIRECTIVE CURRENTLY ), 
TRICYCLES (L5E) AND QUADRICYCLES (CATEGORIES L6E  AND L7E) 
Conclusion 
Technical standards meeting effort0Compliance costs0Better coherence than options 2,3,4,5 ?0
Noise, emissions and fuel consumption0Increased clarity for industry and other 
stakeholders0
Level and appropriateness of current safety 
measures0
Technical standards meeting effort
0Compliance costs
+Better coherence than options 3,4,5 ?
__ __
Noise, emissions and fuel consumption__ __Increased clarity for industry and other 
stakeholders__ __
Level and appropriateness of current safety 
measures__ __
Technical standards meeting effort0Compliance costs0Better coherence than options 2,4,5 ?__ __
Noise, emissions and fuel consumption__ __Increased clarity for industry and other 
stakeholders__ __
Level and appropriateness of current safety 
measures__ __
Technical standards meeting effort
0Compliance costs
__ __Better coherence than options 2, 3, 5 ?
__ __
Noise, emissions and fuel consumption__ __Increased clarity for industry and other 
stakeholders__ __
Level and appropriateness of current safety 
measures__ __
Technical standards meeting effort
0Compliance costs
__Better coherence than options 2, 3, 5 ?
++
Noise, emissions and fuel consumption+Increased clarity for industry and other 
stakeholders++
Level and appropriateness of current safety 
measures+Improved 
categorisation 
of L-category 
vehicles 0
__Improved 
categorisatio
n of L-
category 
vehiclesEffectiveness Efficienc y CoherenceImproved 
categorisation of 
L-category 
vehicles
Objective Policy options Criteria Conclusion __ __
Option 3: Return to the ori ginal spirit of the le gislation for mini cars;Objective Policy options Criteria Conclusion 
Effectiveness Efficienc y CoherenceOption 2: Exclude quadric ycles and electrical bi- and tri-c ycles from the Framework Re gulation; Option 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y Coherence
Option 4: Improvin g the le gislation b y addin g new requirements based on car requirements for mini cars.
Objective Policy options Criteria Conclusion 
Effectiveness Efficiency
CoherenceCoherenceImproved 
categorisation of 
L-category 
vehicles0Improved 
categorisation 
of L-category 
vehicles +Option 5: Improving the proliferation of vehicle categories by the introduction of dedicated sub categories inL1 and L6&L7. Add  new / revised appropriate dedicated requirements for these 
sub categories.
Objective Policy options Criteria Conclusion 
Effectiveness Efficienc y
 
Table 106: option comparison and conclusion table, re-categorisation, options 1 to 5 
 
EN 140   EN 2. S PECIFIC REQUIREMENTS FOR CATEGORY L7E VEHICLES  
Conclusion 
Casualty rates0Type approval costs0Appropriate safety measures for 
complete different vehicles0
Trade barriers owing to divergent requirements 
when type approved (national or EU)0Appropriate environmental measures 
for complete different vehicles0
Separation on-road and off-road quads based 
on design criteria in order to develop designated 
safety and environmental measures 0Level of simplification
0
Casualty rates0Type approval costs+Appropriate safety measures for 
complete different vehicles__
Trade barriers owing to divergent requirements 
when type approving off-road quads (national or __Appropriate environmental measures 
for complete different vehicles__
Separation on-road and off-road quads based 
on design criteria in order to develop designated 
safety and environmental measures +Level of simplification
+
Casualty rates+Type approval costs__Appropriate safety measures for 
complete different vehicles+
Trade barriers owing to divergent requirements 
when type approved (national or EU) 0Appropriate environmental measures 
for complete different vehicles +
Separation on-road and off-road quads based 
on design criteria in order to develop designated 
safety and environmental measures __Level of simplification
__
Casualty rates +Type approval costs 0Appropriate safety measures for 
ff+
Trade barriers owing to divergent requirements 
when type approved (national or EU)0Appropriate environmental measures 
for complete different vehicles+
Separation on-road and off-road quads based 
on design criteria in order to develop designated 
safety and environmental measures __Level of simplification
__ __Improved 
categorisation of 
L-category 
vehicles+Option 4: Create a new cate gory for off-road quads with specific requirements.
Objective Policy options Criteria Conclusion 
Effectiveness Efficiency CoherenceOption 2: Exclude off-road quads from the Framework Directive.Option 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y Coherence
+
Option 3: Keep the existin g cate gory and add new requirements for all quads.Objective Policy options Criteria Conclusion 
Effectiveness Efficienc y Coherence
Objective Policy options Criteria Conclusion Improved 
categorisation of 
L-category 
vehicles0
+Improved 
categorisation of L-
category vehiclesEffectiveness Efficienc y CoherenceImproved 
categorisation of 
L-category 
vehicles
 
Table 107: option comparison and conclusion table specific requirements Category L7e vehicles 
3. S PECIFIC REQUIREMENTS FOR GASEOUS ALTERNATIVE FUELS AND OTHER NON -TRADITIONAL 
PROPULSIONS . 
Conclusion 
Casualty reduction0Type Approval Cost0Appropriate safety measures for 
complete different vehicles0
Environmental performance
0Appropriate environmental measures 
for complete different vehicles 0
Level of innovation in environmental and safety 
technology0Level of simplification
0
Casualty reduction+Type Approval Cost (initially higher, on 
the long run neutral)__Appropriate safety measures for 
complete different vehicles++
Environmental performance++Appropriate environmental measures 
for complete different vehicles++
Level of innovation in environmental and safety 
technology++Level of simplification0Objective Policy options Criteria Conclusion 
Effectiveness Efficienc y CoherenceOption 1: No change
Objective Policy options Criteria
Effectiveness Efficienc y CoherenceImproved 
categorisation of L -
category vehicles0
+Improved 
categorisation 
of L-category 
vehiclesOption 2: Legislation at European Union level through a tighter grid of vehicle type categorisation with dedicated measures for  the different vehicles and propulsion technologies.
 
Table 108: option comparison and conclusion table: dedicated requirements for gaseous alternative fuels and other non-
traditional propulsions 
 
EN 141   EN 4. P ROPOSAL TO RE -CATEGORISE L-CATEGORY VEHICLES  
Category & 
Category NameSub category 
& Sub 
category 
nameExampleNumber 
of wheelsMax. 
vehicle 
SpeedInternal 
Combustion 
Engine (ICE) 
max. displ. (cm3)ICE Max. 
Power 
(kW)Hybrid 
Max. 
Power 
(kW)Electric 
Motor 
Max. 
Power 
(kW)Max mass 
(kg)
Hybrid 
EngineElectric
Engine
Gasoline & 
Gasoline 
blendsDiesel & 
Diesel 
blendsGaseous 
(CNG / 
LPG)
L1Ae powered 
cycles2 x x x x x 25 50 (PI)
L1Be Moped 2 x x x x x 45 50 (PI)
L2e Three-
wheel moped3 x x x x x 45 50 (PI)
L3e,
motorcycle-2 x x x x x
L4e,
motorcycle with 
side car-3 x x x x x
L5Ae 
Tricycles3x x x x x
L5Be 
Commercial 
tricycles3x x x x x
L6Ae
Light quad4 x x x x x 45 50 (PI) 350
L6Be
Light mini car4 x x x x x 45 50 (PI) 350
L7Ae
On-road quad4x x x x x 400
L7Be
Heavy mini 
car4x x x x x400 
(passengers) 
550 (goods)
PI: Positive I gnition en gineL6e,
Light quadricycle
L7e,
Heavy 
quadricycleL5e,
tricycles
max.15 kWmax. 4
max. 4
max. 6
max.15 kWPropulsion
Internal Combustion Engine (ICE)
L1e,
light two-wheel 
vehiclemax. 1
max. 4
 
Table 109: Proposal to re-categorise L-category vehicles 
 
EN 142   EN ANNEX  XVIII:  DETAILS CHAPTER 7 — – MONITORING & EVALUATION ANALYSIS NEW VEHICLE TYPE APPROVAL 
SIMPLIFICATION AND SAFETY MEASURES  
The following recommendations to monitor and control safety measures were obtained from the TRL report: 
1. S IMPLIFICATION  
The following issues were proposed by TRL to be monitored and evaluated in order to ensure the 
effectiveness of the proposed change: - Monitor the key cost parameters used as a basis for the analysis; 
- Number of amendments required to relevant Directives per annum 
- Ongoing costs to member states of implementing current system 
- Monitor numbers of type approvals per annum 
- Time taken for implementation of regulatory changes 
- Monitoring and standardisation of vehicle design - Number of technical standard group meetings, travel mode, distance and number of attendees 
- Evaluation of the proposed change should also moni tor key costs to allow the accuracy of the cost 
saving (benefit) estimate of  option 2 to be assessed. 
2. O
BLIGATORY FITTING OF ADVANCED BRAKE SYSTEMS  
In order to monitor the effect of any change in legislat ion, the number of motorcycle casualties should be 
monitored, preferably in relation to the engine capacity  of the motorcycle, the equipment fitted and in which 
driving licence category the rider can be attributed to. The quality of this impact assessment was influenced 
by a lack of reliable non-fatal casualty data, requiring some broad assumptions to be made. 
Collection/reporting of reliable non -fatal data would enable these assumptions to be verified and would a 
more accurate evaluation of the effe ct of any changes. There was mini mal information available regarding 
the costs and effectiveness of comb ined Brake systems. Data from research studies similar to those 
identified for Anti-lock  Brake System would enable a higher confidenc e in the estimated societal impact for 
casualty prevention. Minimal information was also available regarding future Anti-lock  Brake System costs 
and the effect of large scale fitment of systems on the market price. In particular, information on CBS costs 
was lacking and these were estimated. 
3. A NTI-TAMPERING MEASURES  
In order to monitor the effect of the selected option it is recommended that the following actions be taken: 
Identify baseline data, especially relating to the curren t levels of tampering, and the magnitude of the effect 
that the tampering has on noise, tailpipe emissions and the involvement of relevant vehicle types in 
accidents. Monitor the in-use cond ition of vehicles, undertaking a survey at a representative sample of 
periodic/roadside inspections. 
It was recommended to provide more definitive guidance on the effect of future policy options, the impact of 
tampering on safety and the environment should be review ed in order that the effects can be quantified. If 
effects are identified which cause concern, then a surv ey should be conducted to monitor the current rates 
and types of tampering present in the current fleet. This  could be carried out at periodic inspections, or by 
roadside checks, as used by previous studies. 
4. 74 KW POWER LIMITATION FOR MOTORCYCLES  
Determine baseline data, including: 
• Sales data with respect to engine power/accelerati on potential or whatever m easure is used as the 
limitation. 
• Accident rates with respect to engine power/accelera tion potential or whatever measure is used as the 
limitation. 
• Emissions/noise data with respect to engine power/acce leration potential or whatever measure is used as 
the limitation. Monitor these data in relation to any  other changes that could influence the number of 
accidents, emissions or noise, for example anti- tampering measures, approval of hydrogen powered 
vehicles etc. 
These actions should allow the effect of the proposal to be identified after implementation, or before if the 
implementation is delayed to quantify the possible impacts further. 
 
EN 143   EN  
ANNEX  XIX:  DETAILS CHAPTER 7 — MONITORING & EVALUATION IMPROVED CATEGORISATION OF L-CATEGORY 
VEHICLES  
1. R E-CATEGORISATION ELECTRIC ASSISTED CYCLES  (OUTSIDE SCOPE OF LEGAL FRAMEWORK 
CURRENTLY ), TRICYCLES (L5E) AND QUADRICYCLES (CATEGORIES L6E  AND L7E) 
The following recommendations are relevant for the re-categorisation of L1e, L6E & L7e vehicles: 
Significant uncertainties remain regarding key costs in the approvals process and in the casualty and 
environmental impacts of the proposed options. Thes e should be monitored and further data obtained to 
refine the assessments of potential impa cts. More detailed accident data is required to provide information 
on the safety of quadricycles and to allow the impact of any measures to be assessed. A more specific 
categorisation of L1e, L6E & L7e vehicles would allow t he safety impact of future measures to be monitored. 
2. S PECIFIC REQUIREMENTS FOR OFF-ROAD QUADS (ALL TERRAIN VEHICLES , ATV S) 
Data required to perform a full cost benefit analysis for these options was not obtained from the consultation 
process. Evaluation of the costs of the proposed options could be gathered by monitoring type approval 
costs prior to 2011 (the proposed earliest implementati on of any change) and further investigation of costs 
for national approval. This would allow costs involved with  the approval processes of all proposed options to 
be more accurately quantified. For all options it is important that a means of collecting European accident 
data for quadricycles is implemented and that this a ccident data is disaggregated for different quadricycle 
types and accident locations (on-road and off-road). Th is would allow clearer assessment of the societal 
benefits of future safety improvement measures. Moni toring of accident data would allow future safety 
related changes to be identified and evaluated. 
3. D EDICATED REQUIREMENTS FOR GASEOUS ALTERNATIVE FUELS AND OTHER NON -TRADITIONAL 
ALTERNATIVE PROPULSIONS . 
The following should be monitored and evaluated: Some hydrogen-powered category L vehicles are likely to 
be produced in very low numbers only. For these vehi cles, it might be acceptable to pursue a policy that 
results in individual vehicle approval schemes at Me mber State level. Possible uncertainties include: the 
proportion of road miles likely to be driven by each  category of hydrogen-powered, other gaseous fuel-
powered or non-traditionally propelled category L vehicl es; the environmental effects of new petrol and diesel 
engines; the effects of any Government incentives.  
 
EN 144   EN ANNEX  XX:  ABBREVIATION LIST AND GLOSSARY  
2S Two Stroke engine 
4S Four Stroke engine 
ABS Anti-lock  Brake System. The Antilock Brake Syst em is a closed loop controlled brake 
system which prevents the wheels from locking while braking. The purpose of this is on the 
one hand to avoid a possible fall of the motorcycle rider and on the other hand to shorten 
braking distances. A more detailed technical explanation can be found on: 
http://en.wikipedia.org/wiki/Anti-lock_braking_system#Motorcycles  
ABS Advanced  Braking Systems.  
NB  
1) In the TRL report this is a summary expression of Combined Brake System (CBS) or 
Anti-lock  Brake Systems (ABS). 
2) ACEM considers under Advanced  Brake System: a brake system in which either an 
Antilock Brake  System and/or  a Combined Brake System is present. 
ACEM  Association des Constructeurs Eu ropéens de Motocycles www.acembike.org 
AECC Association for Emissions Cont rol by Catalyst www.aecc.eu  
AFQUAD Association européenne des fabr icants et importateurs de quadricycles 
ATV All Terrain Vehicle 
ATVEA All Terrain Vehicle Industry Eu ropean Association www.atvea.org  
BASt Federal Highway Resear ch Institute (Germany) 
BAT Best Available Technology 
CAN Controller Area Network, referred to as communication protocol (language) between ECU 
and generic scan tool 
CARS 21 Competitive Automotive Regul atory System for the 21st century 
CB Carburettor 
CBS Combined Brake System 
Ch. Chapter 
CLEPA European Association of Automo tive Suppliers www.clepa.com  
CLWP Commission Legislative and Work Programme 
CNG Compressed Natural Gas (mainly methane) 
CO Carbon monoxide 
CO 2 Carbon dioxide 
CoC Certificate of Conformity 
COM The European Commission 
CoP Conformity of Production 
COP Conformity of Production 
DeNOx NOx emission control devices 
DI Direct Injection 
 
EN 145   EN DPF Diesel Particle Filter 
DTC Diagnostic Trouble Code 
EBD Electronic Brake Distribution 
EU European Union 
ECE-R40 United Nations Economic Commissi on for Europe Regulation 40 driving cycle 
ECE-R47 United Nations Economic Commissi on for Europe Regulation 47 driving cycle 
ECU Engine Control Unit 
EDC European Driving Cycle for L-category vehicles (6 super cycles & EUDC) 
EEA European Environmental Agency 
EEA EU Legal provisions will also apply to Iceland, Norway, and Liechtenstein. 
EFI Electronic Fuel Injection 
EMPA Federal Laboratories for Materials Testing and Research (Switzerland) 
EOBD European On Board Diagnostics 
EoS End-of-Series (vehicle) 
EUDC Extra Urban Driving Cycle (high vehicl e speed part of the laboratory test cycle) 
Euro 3, Euro 
4, Euro 5 , Emission standards for air pollutants HC, CO, NOx and PM 
EuroStat European Institute to gather, process and publish statistical data  
FC Fuel Consumption [l./100 km] 
FE Fuel Economy [km per litre] 
FEM A Federation of Euro pean Motorc yclists’ Associations
FF Freeze Frame information. These are generic engine parameters listed on the moment 
while a failure was detected and a DTC was stored in the Engine Control Unit memory. 
This information helps a service technician to  diagnose and pinpoint a failure of the system. 
Best case it helps to determine finding the smallest exchangeable / repairable unit in the 
system
FI Fuel Injection 
GDi Gasoline Direct Injection 
GHG GreenHouse Gas 
GSR General Safety Regulation  
HC HydroCarbons 
IA Impact Assessment 
IASG Impact Assessment Steering Group 
ICE Internal Combustion Engine 
IES Institute for Environment and Sustainability (European Commission) 
IMMA International Motorcycle Manufacturers Association 
IUC In-Use Compliance / In-Use Conformity testing 
IUPR In Use Performance Ratio 
 
EN 146   EN JRC Joint Research Centre (European Commission) 
LAT Laboratory of Applied Thermodynamics (Arist otle University, Gree ce). Institute that 
assessed the environmental policy options.  
L-category Light vehicles e.g. 2& 3 wheel Mopeds, 2& 3 wheel motorcycles, quads, all terrain vehicles 
and mini cars. All these different vehicle ty pes are categorised in 7 different classes 
currently. Refer to Annex I X for the details on the classification. 
LPG Liquefied Petroleum Gas (mix of propane and butane) 
M.V.E.G. Motor Vehicle Emissions Group 
M.V.W.G. Motor Vehicles Working Group 
MC Motorcycle 
MCWG Motor Cycle Working Group 
MIL Malfunction Indicator Lamp 
MY Model Year 
NEDC New European Driving Cycle 
NG Natural Gas (mainly methane) 
NOx Nitrogen Oxides 
NPV Net Present Value 
OBD On-Board Diagnostics 
OCE Off Cycle Emissions 
OEM Original Equipment Manufacturer 
OxiCat Oxidation Catalyst 
PM Particulate Matter 
PTI Periodical Technical Inspection 
PTW Powered Two Wheelers 
R40 test cycle Moped test cycle as specified in UNECE regulation 40 (4 ECE super cycles) 
R47 test cycle  Moped test cycle as specified in UNECE regulation 47 
R&D  Research and Development 
RESS 1) Replacement Exhaust Silencer System 
2) Rechargeable Energy Storage System 
RLP Rear wheel Lift-off Protection 
RMI Retail Motor Industry Federation www.rmif.co.uk  
RSI Road Side Inspection 
RSI Road Side Inspection 
RW Road Worthiness 
SD Separate Directives in relation to fr amework directive or mother regulation. 
SHED Sealed Housing Evaporative Determination 
 
EN 147   EN SME Small Medium Enterprise 
TA Type-Approval 
TAAM Type-Approval Authorities Meetings 
TAR Type-Approval Regulation 
TCMV Technical Committee Motor Vehicles 
THC Total HydroCarbons measured in the appropriat e emission laboratory test cycle or if it is 
used in the context of air quality: all hy drocarbon emissions when adding up evaporative 
and tail pipe emissions from vehicles 
TNO Netherlands Organisation for Applied Scientific Research 
TRL Transport Research Laboratory. Institut e that assessed the safety policy options. 
TÜV Technical Inspection Agency (Germany) 
TWC Three Way Catalyst 
UDC Urban driving Cycle 
UNECE  United Nations Economic Committee for Europe — World Forum for Harmonisation of 
Vehicle Regulations (WP.29)63 
VOC Volatile Or ganic Compound 
VOC Volatile organic compounds 
WMTC World-wide Motorcycle emissions Test Cycle 
WP29 Working Party of the UNECE, which is  the World Forum for Harmonisation of 
Vehicle Regulations 
Table 110: Abbreviation List and Glossary 
                                                 
63 www.unece.org/trans/main/welcwp29.htm