Opinion of the Economic and Social Committee on the 'Proposal for a European Parliament and Council Directive amending Council Directive 78/548/EEC on the approximation of the laws of the Member States relating to heating systems for the passenger compartment of motor vehicles'
Date: 1999-01-27
Institutions: European Economic and Social Committee
Subjects: ESC opinion, approximation of laws, heating, motor vehicle

12.4.1999

EN

Official Journal of the European Communities

C 101/15

Opinion of the Economic and Social Committee on the ‘Proposal for a European Parliament
and Council Directive amending Council Directive 78/548/EEC on the approximation of the
laws of the Member States relating to heating systems for the passenger compartment of
motor vehicles’

(1999/C 101/04)

On 23 October 1998 the Council decided to consult the Economic and Social Committee,
under Article 100a of the Treaty establishing the European Community, on the above-mentioned
proposal.

The Section for the Single Market, Production and Consumption, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 9 December 1998. The
rapporteur was Mr Bagliano.

At its 360th plenary session (meeting of 27 January 1999) the Economic and Social Committee
adopted the following opinion by 114 votes to three with two abstentions.

1.

Introduction

Directive 78/548/EEC of 12 June 1978 concerns
1.1.
heating systems for the passenger compartments of
motor vehicles (category M1), particularly systems using
the heat from exhaust gases or engine cooling air.

1.2.
The aim of the directive was to protect vehicle
occupants from two hazards of these systems: firstly,
the possibility of coming into contact with parts which
could cause burns, and secondly, the entry into the
passenger compartment of air more polluted than the
outside air.

2.3.
The Commission proposal lays down technical
prescriptions for the production and fitting of these
heating systems which are specific to each of the five
classes referred to in point 2.2 above, with the aim of
ensuring that:

— while the vehicle is in use, occupants may not come
into contact with parts of the vehicle or heated air
liable to cause burns;

— the heated air is no more polluted than that outside

the vehicle; and

— the exhaust emissions from combustion heaters are

kept within acceptable limits.

Independent combustion heaters, usually fuelled
1.3.
by diesel, petrol or liquefied petroleum gas (LPG) are
now used in some types of vehicle.

2.4.
The Commission specifies the data which vehicle
and combustion heater manufacturers must provide
on the information document and the EC approval
document.

These devices could give rise to the same prob-
1.4.
lems as those mentioned in point 1.2 above. The purpose
of the Commission’s draft directive is to introduce
specifications for these devices and their attachment to
vehicles, in order to protect consumers.

2. Summary of the proposal

reference

framework Directive
to
2.1. With
70/156/EEC on the approximation of the laws of the
Member States concerning vehicles systems, components
and separate technical units, and the successive amend-
ments to it, the Commission proposes to extend the
scope of Directive 78/548/EEC to all motor vehicles to
which the framework directive applies. This would
extend it beyond cars to apply to buses, motor caravans
and light and heavy commercial vehicles and their
trailers.

2.2.
It goes on to divide vehicles into five classes
according to whether water, oil or air is used as the
transfer medium for engine waste heat, or whether a
liquid or gaseous fuel heater is used.

From 1 October 2000 all new vehicle types must
2.5.
be approved with regard to their internal heating
systems, in accordance with the prescriptions of the
draft directive. From 1 October 2001 this obligation will
apply to all vehicles and combustion heaters placed on
the market.

3. Comments

3.1.
The Commission proposal alters the scope of
Directive 78/548/EEC: it is therefore appropriate that it
be submitted for approval by the European Parliament
and Council, although the issues involved are essentially
technical and procedural.

3.2.
The Committee notes the increasing use of
devices to enhance the comfort of vehicle users, both
passengers and drivers, and agrees with the Commission
on the need to harmonize legislation, taking account of
the different types of vehicle to which such devices are
fitted. Heating systems are in fact used for applications
ranging from the passenger compartments of cars, buses
and trucks, to the sleeping compartments of trucks and

C 101/16

EN

Official Journal of the European Communities

12.4.1999

motor caravans, and the load areas of trucks and trailers
used for carrying goods sensitive to excessive falls in
temperature.

3.3.
The Committee would recall, concerning load
areas of trucks and trailers, that precise prescriptions
exist for the transport of perishable goods and animals
based on the international ATP agreement (1) and
therefore proposes that the draft directive make appro-
priate reference to them.

3.4.
The Committee emphasizes the importance of
heating systems to the well-being and comfort of
passengers, and consequently proposes that the follow-
ing be added to the end of the third recital:

‘... whereas these requirements should be designed
to increase the well-being of vehicle occupants
and to ensure optimum driving conditions, thereby
enhancing safety.’

3.5.
In the Committee’s view, Annex II ‘Scope’ and
‘Definitions’ should become Annex I, coming before all

(1) Agreement on the International Carriage of Perishable
Foodstuffs and on the Special Equipment to be used for
such Carriage (Geneva, 1.9.1970).

Brussels, 27 January 1999.

the other annexes: this would make the directive easier
to read and understand.

3.6.
Instructions on how to use, operate and maintain
heating devices should also be available to users in
clear and readily comprehensible form. The Committee
therefore proposes the following modifications to Annex
VII:

— point 1.1

‘Clear, straightforward and readily understood
operating and maintenance instructions, which must
remain legible, shall be supplied with every heater...’

— point 2.1.4 (new)

‘Clear, straightforward and readily understood
instructions for the use, operation and maintenance
of combustion heaters shall be supplied with all
vehicles fitted with such heaters.’

The Committee would have preferred the Com-
3.7.
mission to have kept the approval procedures and
prescriptions for heating devices clearly separate from
those for the fitting of such devices to vehicles. This
would have made the proposal clearer and more precise.

The President

of the Economic and Social Committee

Beatrice RANGONI MACHIAVELLI