Opinion of the European Economic and Social Committee on the Communication from the Commission to the Council and the European Parliament — Results of the review of the Community Strategy to reduce CO 2 emissions from passenger cars and light-commercial vehicles COM(2007) 19 final
Date: 2007-10-24
Institutions: European Economic and Social Committee
Subjects: EU environmental policy, environmental standard, motor vehicle pollution, reduction of gas emissions, road transport

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Official Journal of the European Union

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Opinion of the European Economic and Social Committee on the ‘Communication from the
the
Commission to the Council and the European Parliament — Results of

the review of

Community Strategy to reduce CO2 emissions from passenger cars and light-commercial vehicles’

COM(2007) 19 final

(2008/C 44/11)

On 7 February 2007 the Commission decided to consult the European Economic and Social Committee,
under Article 175 of the Treaty establishing the European Community, on the abovementioned proposal.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 5 October 2007. The rapporteur
was Mr Ranocchiari.

At its 439th plenary session, held on 24 and 25 October 2007 (meeting of 24 October), the European
Economic and Social Committee adopted the following opinion by 142 votes to one with two abstentions.

1. Summary and recommendations

1.1
The EESC supports the European Commission's initiative
aimed at reviewing the Community strategy for reducing CO2
emissions from road traffic.

urban areas (1)) and guiding demand by means of
taxation
targeting CO2 emissions. The EESC also feels that among future
low
measures, consideration should be given to the use of
rolling resistance tyres which, according to industry data, can
reduce consumption by 3-4 %. The Commission's suggestion to
introduce tyre pressure monitoring systems is a step in the same
direction.

1.2
The Commission's proposal, which the Council plans to
is to cut CO2 emissions from passenger cars to
confirm,
130 g/km by 2012, by means of technological improvements to
motor vehicles. A further reduction of 10 g/km should be
achieved, if technically possible, thanks to alternative technolo-
gies and greater use of biofuels, to reach the overall objective of
120 g/km by 2012.

1.6
the
An intelligent and considered combination of all
measures available might enable the CO2 reduction targets to be
reached, without putting a brake on the renewal of the car fleet,
by containing and sharing out the financial burden and avoiding
penalising potential buyers of new cars.

The EESC believes that this ambitious initiative will only
1.3
succeed if it is conducted using diverse, balanced measures, and
a timeframe that takes into account the need for manufacturers
the models they
to adapt
the chosen technologies to all
produce, a complex operation with varying costs.
In other
words, when it comes to CO2 emissions,
improvements in
passenger car performance must be reconciled with the manu-
facturers' capacity to apply them both economically and techno-
logically and with the spending capacity of potential buyers.

1.7
The EESC also hopes that the impact of the legislative
instrument chosen will be as neutral as possible when it comes
to competition between manufacturers, not imposing binding
limits on the models they can put on the market, but rather
guiding consumer demand towards lower emission models. The
CO2 reduction targets must correlate with the existing differ-
ences within the product ranges, using those parameters judged
to be most informative and proportionate to their CO2 emis-
sions.

1.4
In the light of these factors, while underlining the need
to urge car manufacturers to make more rapid progress towards
further reductions in consumption and emissions, the EESC also
points to the need to press ahead with efforts to introduce the
most socially, economically and environmentally effective legis-
lative framework possible.

1.8
It is extremely important that the parameters chosen act
as an instrument to guide consumers towards types of vehicle
that respond to their real needs, avoiding consumption and
emission levels that go beyond their everyday needs.

1.5
The EESC therefore recommends commissioning a full
and detailed impact assessment, to establish the costs/benefits of
the various options, ranging from work on vehicle technology
to other possible instruments: adjustments to infrastructure,
alternative fuels,
information through various
forms of education for eco-driving (needed most of all in large

tax incentives,

1.9
In this respect, the EESC is concerned at the Commis-
sion's plan to introduce legislation for light commercial vehicles.
The consumption, and thus CO2
these vehicles,
designed for professional use, are examined carefully by poten-
tial buyers as they have a significant impact on business costs.

levels, of

(1) See opinion OJ C 168, 20.7.2007, Transport in urban and metropolitan

areas.

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As a result, the vehicles currently on the market are already
adopting the most efficient solutions — the almost exclusive
use of diesel engines. In any case, before a decision is taken, the
EESC recommends that the Commission conduct an impact
assessment based on an up-to-date survey of light commercial
vehicle emissions, something that is not currently available.

1.10
Lastly, the EESC believes that the Member States should
develop activities in a wider range of areas than in the past
(roads, intelligent traffic lights, etc.), not least by buying environ-
mentally-sound vehicles for their own public transport fleets
and committing themselves to both building infrastructure
networks that can give access to the distribution of fuels of a
lower environmental impact, such as natural gas, and facilitating
the purchase of vehicles using natural gas or LPG, a matter on
which the EESC has already expressed its view in previous
opinions (2).

2. Introduction

In 1995, a Community strategy to reduce CO2 emissions
including measures addressing supply from

2.1
was introduced,
vehicle manufacturers and demand from consumers.

2.2 More specifically on the supply side, European manufac-
turers entered into a voluntary agreement aimed at reducing
average CO2 emissions from cars to 140 g/km by 2008. Japa-
nese and Korean manufacturers made the same commitment the
following year, to be achieved by 2009.

On the demand side,

2.3
the European Commission's
strategy simultaneously provided for consumer information on
CO2 emissions,
together with
to help them choose wisely,
targeted use of car taxes.

2.4
In practice, significant improvements have been achieved
on the supply side, although they are not by themselves enough
to meet the objective set, as the contribution of the other two
instruments — information/guidance and tax — has been
lacking. The Commission acknowledges this, admitting in its
communication that ‘… improvements in car technology have
delivered the bulk of the reductions’ in CO2 emissions.

the fleet placed on the market in 2004 had emissions of less
than 140 g/km.

2.6
On the other hand, during the same period consumer
preference has shifted towards larger, heavier, more powerful
cars, on account of both the perception that they are safer and
the considerable population movement away from urban
centres.
information labelling has had little
impact on consumer choices.

In consequence,

2.7
The other instrument for shaping demand, targeted taxa-
tion to reduce CO2 emissions, does not yet possess a European
dimension (3), being restricted to national initiatives in less than
half the Member States. In some cases, the measures taken have
had a paradoxically negative impact on reducing emissions. One
such example is the increased tax on diesel, which has slowed
the shift to diesel that has taken place over recent years in many
Member States having larger numbers of diesel vehicles.

2.8
In conclusion, due to both external factors hindering the
reduction process launched with the review of car technologies
in the wake of the voluntary agreements, and the failure to
make use of the other planned instruments, the objectives set
for 2008/2009 do not seem to be feasible. The Commission has
therefore decided to review the strategy and has published the
communication under examination by the EESC, laying down
guidelines to be followed by a specific legislative proposal by
the end of the first half of 2008.

3. The Communication from the European Commission

In the communication,

3.1
the Commission proposes to
reach the EU objective of 120 g/km by 2012. This is to be
achieved through a combination of EU and Member State
action.

To this end, the Commission will propose a legislative
3.2
framework by mid-2008, focusing on mandatory reductions in
CO2 emissions to achieve the average new car fleet objective of
130 g/km by means of improvements in vehicle motor tech-
nology.

3.3
A further reduction of 10 g/km, or equivalent if techni-
cally possible, is to be achieved by other technological improve-
ments and by increased use of biofuels, specifically:

2.5
Average CO2 emissions fell approximately 13 % from
186 g/km to 161 g/km between 1995 and 2004, and 30 % of

a) setting minimum efficiency requirements for air-conditioning

systems;

(2) Opinion of the European Economic and Social Committee on The devel-
opment and promotion of alternative fuels for road transport in the European
Union, OJ C 195, 18.8.2006, p. 75.

(3) The draft directive on car-related tax in the EU, COM(2005) 261, which
provided for a restructuring of car-related tax based wholly or partially
on CO2 emissions, was not approved.

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b) compulsory fitting of accurate tyre pressure monitoring

systems;

car marketing and advertising, aimed at promoting sustainable
consumption patterns.

c) setting maximum tyre rolling resistance limits in the EU for
tyres fitted on passenger cars and light commercial vehicles;

d) use of gear shift indicators, taking into account the extent to
which such devices are used by consumers in real driving
conditions;

e) fuel efficiency progress in light commercial vehicles (vans)
with the objective of reaching 175 g/km CO2 by 2012 and
160 g/km CO2 by 2015;

f) increased use of biofuels maximising environmental perfor-

mance.

4. General comments

4.1
The EESC fully agrees that there is a need to review the
Community strategy to reduce CO2 emissions generated by road
traffic, which account for some 20 % of overall emissions.

The EESC would also point to the complexity of this
4.2
review, which should aim to achieve further CO2 emission
reductions without undermining the competitiveness of
the
vehicle sector, which is operating on an extremely competitive
world market.

3.4
The Commission agrees that the legislative framework
implementing the average new car fleet target will need to be
designed so as to ensure competitively neutral and socially equi-
table and sustainable reduction targets which reflect the diversity
of European car manufacturers and avoid any unjustified distor-
tion of competition between automobile manufacturers.

4.3
It should be borne in mind that in Europe alone, the car
industry employs 2 million people directly and another
10 million indirectly. The industry accounts for 3,5 % of
European GDP, with net exports worth EUR 33,5 billion and —
last but not least — the Member States receive EUR 365 billion
annually in car taxes.

In this regard,

3.5
the Commission encourages Member
States to adapt their car taxation policies so as to promote the
purchase of
the EU and help
manufacturers comply with the upcoming fuel efficiency frame-
work.

fuel-efficient cars throughout

3.6
The Commission also suggests the introduction of taxes
differentiated over the whole range of cars on the market, so as
to gradually induce a switch towards relatively less emitting cars,
as an efficient way to reduce compliance costs for manufac-
turers.

Indeed, in its CARS 21 (4) communication, the Commis-
4.4
sion has sought to outline industrial policy in the automotive
sector, which ‘plays a substantial role in the European economy’.

The CARS 21 communication is the Commission's response to
the final report and recommendations drawn up in December
2005 by the CARS 21 High Level Group, which comprised
representatives of industry and the main components of civil
society, as well as of the Commission. The document highlights
that attaining ambitious objectives in complex areas, such as the
reduction of CO2 emissions while not damaging industrial
an integrated
competitiveness or
approach aimed at drawing together the contributions of all
stakeholders to pursue a single objective of general interest.

employment,

demands

The role of fiscal incentives is mentioned as a powerful
3.7
way of encouraging people to buy the cleanest light-duty vehicle
classes on the market; similar emphasis is placed on the need to
improve the effectiveness of information for potential buyers on
vehicle consumption (the Commission is to adopt a proposal to
amend Directive 1999/94/EC on labelling in 2007).

4.5
The EESC shares the concerns voiced regarding the
potentially excessive impact on industrial costs of decisions that
might directly or indirectly jeopardise employment levels in the
industry by encouraging strategic choices entailing the possibi-
lity of industrial relocation outside the EU.

Lastly,

the Commission points to the need for

the
3.8
Member States to promote eco-driving through training and/or
awareness campaigns with the aim of reducing emissions.

3.9 Manufacturers
also invited to sign up before
mid-2007 to a voluntary agreement on good practice regarding

are

4.6
In the light of these considerations, the EESC agrees that
car manufacturers should be urged to make more rapid progress
towards further reductions in consumption and emissions, but
also points to the need to press ahead with efforts to introduce
the most socially, economically and environmentally effective
legislative framework possible for reducing CO2 emissions.

(4) A Competitive Automotive Regulatory

the
21st Century, COM(2007) 22 final, 7 February 2007. The EESC has
drafted an opinion on this subject (rapporteur: Mr Davoust).

Framework

for

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4.6.1
The EESC would make the following recommendations
with a view to securing the best results from future Community
legislation on reducing CO2 emissions from road traffic:

As it takes Europe 12 years on average to replace its
4.6.4
car fleet, as noted by the Commission,
it is clear that price
increases on that scale would further slow the car replacement
cycle. It also is clear that such increases would have a social
impact, making it even harder for the more disadvantaged
sectors of society to buy a car.

— Infrastructure and tyres: upgrading of road infrastructure
is justified, since better road surfaces reduce friction and
noise pollution, and increase road practicability. In addition,
the introduction of advanced electronic traffic management
(ETM) systems to reduce congestion and redundant stops at
traffic lights can make a significant contribution to reducing
CO2 emissions. With the same aim, the use of low rolling
resistance
reducing
consumption by some 3-4 %; the Commission's suggestion
to introduce tyre pressure monitoring systems is a move in
the same direction.

produces

benefits,

proven

tyres

and

social

— Alternative fuels: principally biofuels, also mentioned in
the CARS 21 final report. Once the technical feasibility and
first-generation
environmental
biofuels (5) have been checked (pending the introduction of
second-generation,
they could,
together with other alternative fuels coming into use in
Europe (natural gas, in the medium term, biogas, and hope-
fully in the long term, hydrogen), become a decisive factor
for reducing CO2 emissions.

impact, biofuels),

impact

lower

of

— Training, information and guidance: training initiatives for
the entire motor vehicle commercial and distribution chain
should be promoted and supported, in order to steer buyers'
choices towards lower CO2 emission options, with full
understanding of the facts. Direct means should also be used
to influence buyers through taxation tied to CO2 emissions
and incentives for eco-driving.

4.6.2
All these measures would also have the effect of not
undermining the process of renewing the current car fleet, by
spreading the financial burden of reducing the level of CO2
emissions. The EESC would point out in passing that according
to the ECCP (6), the potential reduction of CO2 emissions from
eco-driving could amount to 50 million tonnes in Europe by
2010 (2006-2010), and a joint TNO/IEEP (7) study claims that
eco-driving is not only feasible, but is both effective and measur-
able.

On the other hand, the average sale price of a car
4.6.3
would rise by approximately EUR 3 600 if the 120 g/km target
were to be reached through car technology alone. Additionally,
the same sources (8) indicate that in order to reach 130 g/km,
the additional cost to purchasers would in any case be substan-
tial, around the EUR 2 500 mark.

(5) Opinion TEN/286 Progress in the use of biofuels, under discussion.
(6) European Climate Change Programme. As part of the ECCP, the
Commission's consultant, TNO, has estimated the costs and CO2 emis-
sions reduction potential of the various possible measures.

(7) IEEP: Institute for European Environmental Policy — TNO Consul-

tancy.

(8) See footnote 6.

4.7
Lastly, the EESC disagrees with the Commission's posi-
tion that complementary technologies would bring about a
reduction in CO2 emissions of 10 g/km, since the ability of
biofuels to penetrate the market is still uncertain, and it cannot
be assumed that they will contribute the expected 5 g/km. In
the EESC's view, it is essential to introduce a raft of measures
that can be monitored with certainty, as is the case, for example,
with eco-driving and infrastructure.

5. Specific comments

5.1
In keeping with the general comments above, and also in
the light of the current parliamentary debate, the EESC hopes
that the future legislative instrument will not compromise the
ability of consumers to buy new cars, in order to ensure that
the car fleet is renewed, and also that it will succeed in strongly
directing demand towards lower emission models.

5.2
In the absence of a full and detailed impact assessment
to highlight the costs/benefits of the various options, the EESC
reserves the right to draw up an opinion at a later stage on
appropriate and feasible limits in terms of reduction of CO2
emissions, but recommends at this juncture that the planned
legislative instrument should take account of the fact that the
car production cycle is famously complex, requiring a lead
time (9) of anything up to seven years.

In view of the time needed to prepare legislation in the
5.3
co-decision process, the EESC reckons that the final text laying
down the requirements to be met will not be ready before
2009. Given the earlier comments regarding the sector's typical
industrial cycles, the first practicable date would be 2015, to
coincide with the entry into force of the EURO 6 regulation on
the reduction of pollutants that, as in the case of CO2, require
structural modifications to cars.

5.4
There is a danger that the 2012 target date is technically
impracticable and could have distinctly negative effects on the
competitiveness of the European car industry and its contribu-
tion to employment.

(9) The time needed for the industry to implement any new requirement

involving changes to vehicle structures.

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5.5
The EESC is, as of now, in favour of a legislative instru-
ment which is neutral in terms of competition between manu-
facturers, meaning not imposing binding limits on the models
they can put on the market, but rather guiding consumer
demand towards lower emission models; the CO2 reductions
called for must match the existing differences within the
product range, using those parameters judged to be most infor-
mative and proportionate to their CO2 emissions.

5.6
In this regard, it is felt that the parameter to be selected
must ensure that contributions in emissions reduction terms
from the various segments and the inevitable ensuing vehicle
cost increases should not be such as to erode affordability, so
that customers can buy a new vehicle in keeping with their own
spending power.

In view of the ambitious objectives, there is no realistic prospect
of sufficient volumes of allowances for exchange being built up
to ensure that the system would work.

In contrast, the EESC considers the application of an
5.7.1
‘open’ emissions trading system (i.e. permitting trading with
other sectors) to be possible, offering the advantage of guaran-
teeing an overall reduction in CO2 emissions with an appro-
priate degree of
flexibility, while setting limits on possible
purchases for vehicle manufacturers. The EESC therefore advo-
cates an open system, the economic implications of which will
have to be defined and identified in the light of changes within
the emissions market between now and 2015, underlining the
need to prevent such economic implications putting the afford-
ability for final customers at risk.

One possible parameter would be vehicle weight (as
5.6.1
suggested by ACEA, the European Automobile Manufactures'
Association), as this directly affects the level of CO2 emissions.
The EESC recalls that vehicle weight rose by 32 kg between
1996 and 2005, reflected in a relative increase in CO2 emissions
of 6,6 g/km. Weight is to be used as a benchmark in Japan's
CO2 emissions strategy. In 2006, the country set a target of
138 g/km to be achieved by 2015. ACEA supports this para-
meter, as it represents a step towards harmonisation of CO2
policies across the world.

Turning to the communication's call for a code of good
5.8
practice regarding car marketing and advertising,
the EESC
points out that almost all the Member States already have —
usually very stringent — agreements on how to define rules in
this area. In general terms, however, the EESC favours harmo-
nising these rules and consequently is not opposed to drawing
up a European code of good practice as suggested to vehicle
manufacturers by the Commission.

It should also be pointed out

5.6.2
that discussions are
currently taking place on other parameters that could be used
to identify and differentiate product ranges. Of particular note is
the proposal by EP rapporteur, MEP Chris Davies, which refers
to the vehicle's ‘footprint’ (the area occupied by the car, calcu-
lated using wheelbase and track width (10)).

The EESC, meanwhile, considers that adopting,

5.6.3
for
example, box volume (vehicle length × width × height) as a
parameter could be useful and appropriate, as a possible tool for
guiding consumers towards vehicle types meeting their real
needs and without redundant CO2 emissions caused by a prac-
tical need/vehicle size mismatch.
In other words, a person
that can carry more
needing an SUV (sport utility vehicle)
passengers and more weight will be willing to pay more because
a vehicle of
this type is really necessary, whereas a person
without these requirements will be more attracted to a lower
segment.

The same European Parliament rapporteur, MEP Chris
5.7
Davies, has proposed establishing a ‘Carbon Allowance Reduc-
tion System’ (CARS) setting penalties and credits for exceeding
or coming below the limits set. The EESC believes that intro-
ducing a CO2 allowance-swapping system is not practicable in a
market restricted to the automobile sector.

(10) WHEELBASE: distance between front and rear axles; TRACK WIDTH:

distance between tyres.

The EESC also notes that

5.9
the
Commission also states its intention to prepare a legislative
to reduce CO2 emissions from light commercial
instrument
vehicles.

in its communication,

5.9.1
It seems to the EESC that light commercial vehicles
(category N1 and related passenger transport vehicles) do not
require an intervention of this kind, since they are designed for
commercial purposes and, consequently, consumption and CO2
emissions are already a deciding factor for buyers, as they have a
major
the vehicles
currently on the market are already adopting the most efficient
solutions — the almost exclusive use of diesel engines.

impact on business costs. As a result,

5.9.2
In any case, before a decision is taken, the EESC recom-
the Commission conduct an impact assessment
mends that
based on an up-to-date survey of light commercial vehicle emis-
sions, something that is not currently available.

5.9.3
Applying g/km targets on commercial vehicles, without
precise knowledge of the relevant data, also brings the risk of
reducing the carrying capacity of individual vehicles, with the
ensuing inefficiency requiring either a greater number of vehi-
cles to transport the same loads, or larger, higher category vehi-
cles, thereby increasing overall emissions.

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5.10
The EESC also believes that the subject of CO2 emis-
sions from cars and light duty vehicles should be assessed
comprehensively, taking into account the entire life cycle of
vehicles, from production processes to use and disposal. In the
light of the above, the EESC would also stress the need to coor-
dinate and secure coherence between legislative and regulatory
initiatives relating to the motor vehicle industry with an impact
on CO2 emissions so as to preclude contradictions causing
delays in their implementation.

The EESC believes

5.11
future research framework
that
programmes must give priority as a matter of urgency to
projects aimed at finding technically feasible and economically
sustainable ways of reducing global CO2 emissions (not only in
relation to transport), taking into account the real impact of the
entire life cycles of various sources of emissions. The EESC is

convinced that research projects should work across a broad
spectrum with a view to identifying short-, medium- and
long-term solutions with affordability — for both manufacturers
and final customers — as a constant objective, in order to facili-
tate the renewal of the vehicle fleet in the interests of sustain-
able mobility.

Lastly, the EESC believes that the Member States should
5.12
develop activities in a wider range of areas than in the past
(roads, intelligent traffic lights, etc.), not least by buying environ-
mentally-sound vehicles for their own public transport fleets
and committing themselves to both building infrastructure
networks that can give access to the distribution of fuels of a
lower environmental impact, such as natural gas, and facilitating
the purchase of vehicles using natural gas or LPG.

Brussels, 24 October 2007.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

Opinion of the European Economic and Social Committee on the ‘Proposal for a directive of the
European Parliament and of the Council amending Directive 2003/54/EC as regards the application
of certain provisions to Estonia’

COM(2007) 411 final — 2007/0141 (COD)

(2008/C 44/12)

On 17 September 2007 the Council decided to consult the European Economic and Social Committee,
under Articles 47(2), 55 and 95 of the Treaty establishing the European Community, on the abovemen-
tioned proposal.

Since the Committee unreservedly endorses the proposal and feels that it requires no comment on its part,
it decided, at its 439th plenary session of 24 and 25 October 2007 (meeting of 24 October 2007) by
150 votes to 2 and 8 abstentions, to issue an opinion endorsing the proposed text.

Brussels, 24 October 2007.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS