Commission staff working document - Annex to the Proposal for a Regulation of the European Parliament and of the Council on the approximation of the laws of the Member States with respect to emissions from on-road heavy duty vehicles and on access to vehicle repair information - Impact assessment {COM(2007) 851 final} {SEC(2007) 1720}
Date: 2007-12-21
Institutions: European Commission
Subjects: access to information, commercial vehicle, engine, general mechanical engineering, impact study, motor vehicle, motor vehicle pollution, pollution control measures, reduction of gas emissions

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 21.12.2007 
SEC(2007) 1718 

COMMISSION STAFF WORKING DOCUMENT 

Annex to the 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on the approximation of the laws of the Member States with respect to emissions 
from on-road heavy duty vehicles and on access to vehicle repair information,  

Impact Assessment 

{COM(2007) 851 final} 
{SEC(2007) 1720} 

 
 
 
 
 
 
 
 
 
 
TABLE OF CONTENTS 

EXECUTIVE SUMMARY ................................................................................................. 3 

1.  PROCEDURAL  ISSUES  AND  CONSULTATION  OF  INTERESTED 

PARTIES..................................................................................................................... 5 

1.1.  Organisation and timing .................................................................................... 5 

1.2.  Consultation and expertise ................................................................................ 5 

1.3.  Opinion of the Impact Assessment Board ......................................................... 6 

2.  PROBLEM DEFINITION........................................................................................... 6 

2.1.  Nature of the issue or problem that requires action........................................... 6 

2.2.  Underlying drivers of the problem .................................................................... 7 

2.3.  Stakeholders affected......................................................................................... 9 

2.4.  Consequences of no change in policy ............................................................... 9 

2.5.  Treaty base and subsidiarity principle............................................................. 10 

3.  OBJECTIVES ........................................................................................................... 11 

3.1.  Policy objectives.............................................................................................. 11 

3.2.  Consistency with horizontal objectives of the European Union ..................... 11 

4.  POLICY OPTIONS................................................................................................... 13 

4.1.  Options Identified............................................................................................ 13 

4.2.  Options discarded at an early stage ................................................................. 13 

5.  ANALYSIS OF IMPACTS....................................................................................... 16 

5.1. 

Impacts of the policy options .......................................................................... 16 

5.2.  Conclusion....................................................................................................... 18 

6. 

IDENTIFICATION  OF  THE  BEST  SUB-OPTION  UNDER  THE 
REGULATORY OPTION ........................................................................................ 20 

6.1.  Data Collection and Modelling of the Impacts ............................................... 20 

6.2.  Sub-options of the Regulatory approach ......................................................... 20 

6.3. 

Impact of other measures................................................................................. 39 

6.4.  Preferred Option .............................................................................................. 45 

6.5. 

Indicators of progress towards meeting the objectives ................................... 47 

6.6.  Monitoring and evaluation .............................................................................. 47 

Annex 1: Issues raised during the public consultation.............................................. 48 

 
 
 
EXECUTIVE SUMMARY 

Air  quality  has  improved  over  the  past  decade  but  there  are  still  significant  air  quality 
problems  throughout  the  European  Union,  especially  in  urban  areas  and  in  densely 
populated regions.  

By  2020  the  EU  will  still  be  a  long  way  from  achieving  the  objectives  of  the  6th 
Environmental  Action  Programme.  Significant  negative  health  and  environmental 
impacts will continue to persist even with effective implementation of current legislation. 

In order to solve these problems, further measures have been considered, and in doing so 
the following options have been assessed: 

- No policy change 
- Regulatory approach at the European level 
- Regulation in Member States 
- Fiscal incentives by Member States 
- Non-regulatory approach 

The  impact  assessment  has  demonstrated  that  further  reduction  of  emission  limits  for 
heavy duty vehicles (Euro VI) is necessary to improve air quality while at the same time 
retaining the functioning of the internal market. 

Particulate  matter  (PM)  pollution  is  of  increasing  scientific  concern  and  harmonised 
emission  limits  at  European  Union  level  are  necessary  to  prevent  barriers  to  the 
distribution and circulation of heavy duty vehicles and to achieve substantial reductions 
in particulate emissions from those vehicles across the EU. A 66% reduction in the limit 
value  for  particulate  matter  is  proposed  with  an  emission  limit  of  0.01  g/kWh,  which, 
given current technology, will require particulate filters to be fitted to all diesel vehicles.  

Additional  action  on  nitrogen  oxide  (NOx)  and  hydrocarbon  (HC)1  emissions  is  also 
justified, given the fact that many Member States will otherwise be unable to fulfil the 
requirements  of  the  National  Emissions  Ceilings  Directive  (2001/81/EC)  and  the 
proposal for revision of the air quality directives (COM(2005) 447)2. An 80% reduction 
in  NOx  to  an  emission  limit  of  0.4  g/kWh  is  proposed.  Increased  use  of  engine 
technology  and  after-treatment  technology  shall  be  needed  to  fulfil  the  required  NOx 
emission limits.  

A  series  of  amendments  to  the  existing  legislation  are  discussed  in  this  impact 
assessment. The general effect of these is to further tighten emission limits from vehicles, 
in  that  they  reduce  the  risk  of  vehicles  producing  unnecessary  levels  of  pollution  by 
providing  more  robust  and  comprehensive  regulatory  requirements  without  imposing 
excessive  costs.  In  addition,  they  ensure  standardised  access  to  vehicle  repair 
information. 

1   Hydrocarbons  (HC)  and  Volatile  Organic  Compounds  (VOC)  are  used  in  this  document 

interchangeably. 

2   This proposal for an Ambient Air Quality Directive would amend existing air quality legislation, i.e. 
Directives  96/62/EC  (“Framework  Directive"),  OJ  L  296,  21.11.1996,  p.55,  and  three  “daughter 
directives” 1999/30/EC, 2000/69/EC 2002/3/EC and Council Decision 97/101/EC. 

  3

 
 
 
 
 
                                                 
The impact assessment concludes that it is appropriate to align our future emission values 
with  those  of  the  US.  Most  stakeholders  –  including  industry  –  support  the  alignment 
with the US limit values, and our impact assessment shows that it is cost-efficient. 

The  result  will  be  a  considerable  improvement  in  air  quality  while,  at  the  same  time 
reducing  the  cost  of  engine  development  and  testing.  In  fact,  the  proposal  will  enable 
manufacturers  to  produce  highly  environmentally  friendly  engines  for  both  the  US  and 
the European markets. 

It will also enable Member States to fulfil the requirements of the Air Quality Directive. 

  4

1.  PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1.  Organisation and timing 

A  proposal  relating  to  the  pollutant  emissions  from  heavy  duty  vehicles  has  been 
included  in  the  2007  Commission  Legislative  and  Work  Programme.  The  proposal  has 
been 
the  Roadmap  reference  number 
2007/ENTR/009. The latter has been published as part of the Work Programme. 

identified  as  a  Priority  Initiative  under 

1.2.  Consultation and expertise 

In  developing  the  proposal  the  Commission  services  have  both  consulted  stakeholders 
and drawn on external expertise in a number of ways: 

•  A questionnaire was sent to stakeholders in 2004 on possible scenarios of new Euro 
VI  emission  limit  values  for  heavy-duty  vehicles.  The  questionnaire  aimed  at 
gathering views of stakeholders as to the required technology and associated costs of 
meeting  various  limit  value  scenarios.  The  Commission  services  consulted  a  wide 
spectrum  of  interested  organisations  through  the  questionnaire:  national  authorities, 
industry  associations  and  non-
vehicle  manufacturers,  component  suppliers, 
governmental organisations. 

•  A  panel  of  experts,  external  to  the  Commission,  was  engaged  to  assess  stakeholder 
responses to the questionnaire sent out by the Commission on new Euro VI emission 
limit  values  for  heavy-duty  vehicles.  The  panel  was  composed  of  three  independent 
professionals,  whose  task  was  to  assess  and  validate  the  stakeholder  responses  on 
various  emission  reduction  scenarios  and  on  costs  of  necessary  technology.  The 
results of the work of the expert panel were reported to the Commission services3. The 
panel subsequently reported on its interpretation of the stakeholder responses in terms 
of the technologies required and the costs involved. This report is further referenced in 
the impact assessment as TNO Report. 

•  To understand more fully the results of the questionnaire, the expert panel organised a 
number  of  targeted  stakeholder  meetings  to  generate  additional  data  on  technology 
performance and related costs. The panel produced a technology map and a cost range 
of meeting the various emission reduction scenarios. 

•  Modelling of environmental and economic impacts was undertaken to understand the 
cost-effectiveness  of  different  emission  limit  scenarios  using  the  analytical  tools 
developed  under  the  CAFE  Programme  in  order  to  model  the  impacts  of  different 
emission limit levels. This work was reported by an external consultant contracted by 
the  Commission  in  a  study  that  is  referenced  as  LAT  study  throughout  this  Impact 
Assessment4.  LAT  performed  additional  calculations  to  assess  the  impacts  of  the 

3    TNO: Panel Report on Euro VI technologies and costs – The expert panel’s summary of stakeholder 

responses; 06.OR.PT.034.2/NG; September 12 2006 
http://ec.europa.eu/enterprise/automotive/pagesbackground/pollutant_emission/tno_report_euro_vi.pd
f  

4   LAT - TREMOVE model scenario runs related to the impact assessment of EURO VI emission limit 
values  for  Heavy  Duty  Vehicles  –  Draft  final  report  –  February  2007  [link  will  be  introduced  once 
final report is published] 

  5

                                                 
emission limit value scenarios in 2030 which was carried out with version 2.52 of the 
TREMOVE model. This work was also reported in a study that is referenced as LAT 
study No. 2 throughout this Impact Assessment5   

•  A number of scenarios for Euro VI (see section 6.2.1) were put to public consultation 
in  July-September  2007.  The  Commission  services  aimed  to  gather  the  views  of  all 
interested  parties  on  future  limit  values  and  to  take  into  consideration  all  relevant 
comments of stakeholders in its proposal. The opinion of the stakeholders on whether 
the introduction of the Euro VI should be introduced in a single step or in two steps, 
was  also  requested  in  the  public  consultation.  Comments  and  issues  raised  by 
stakeholders are summarised in Annex 1. 

The Commission’s standards for consultation of interested parties6 were met throughout 
the consultation procedure. 

1.3.  Impact Assessment Board 

The  Board  has  examined  a  draft  of  this  Impact  Assessment  and  has  made  a  number  of 
recommendations.  These  concern  on  the  one  hand the presentation of  the options. This 
aspect  has  been  taken  into  account  throughout  the  report.  On  substance,  the  Board 
suggested that the choice of the scenarios should be better justified. This has been done 
in  section  6.1.  The  Board  has  also  asked  for  a  better  evaluation  of  the  accompanying 
measures.  This  has  been  done  in  section  6.3.  Finally,  the  Board  has  asked  for 
clarification why sub-option A has been chosen despite the fact that this does not seem to 
be the most cost-efficient option. This aspect has been dealt with in section 6.4.1. 

2.  PROBLEM DEFINITION 

2.1.  Nature of the issue or problem that requires action 

The  proper  functioning  of  the  single  market  in  the  European  Union  requires  common 
standards limiting the emission of atmospheric pollutants from motor vehicles. Action at 
Community  level  prevents  varying  product  standards  emerging  across  Member  States 
which  results  in  fragmentation  of  the  internal  market  and  imposition  of  unnecessary 
barriers  to  intra-Community  trade.  Also  through  harmonised  standards  it  is  possible  to 
reap  the  economies  of  scale  as  production  series  can  be  made  for  the  whole  European 
market. 

Harmonized  vehicle  emission  standards  have  long  been  a  feature  of  EU  policy.  Given 
developments  in  automotive  technology,  increased  demand  for  road  transport  and 
continuing air quality problems, there has been a need to keep standards under review. 

5   LAT - TREMOVE model scenario runs related to the impact assessment of EURO VI emission limit 
values for Heavy Duty Vehicles – Draft final report – October 2007 [link will be introduced once final 
report is published] 

6   COM(2002) 704 final, 11.12.2002 

  6

  
                                                 
2.2.  Underlying drivers of the problem 

All Member States and their citizens are concerned about the significant risk to human 
health and environment that results from air pollution. Although air quality has improved 
over  the  past  decade,  there  are  still  significant  air  quality  problems  throughout  the 
European Union, especially in urban areas and in densely populated regions.  

The 6th Environmental Action Programme (EAP)7 establishes the objective of achieving 
levels of air quality that do not give rise to significant negative impacts on and risks to 
human  health  and  the  environment.  Following  its  communication  on  the  Clean  Air  For 
Europe programme (CAFE)8, the Commission has examined whether current legislation 
is sufficient to achieve the 6th EAP objectives by 2020. 

The  Commission’s  Communication  on  the  Thematic  Strategy  on  Air  Pollution9  has 
identified that by 2020 the EU will still be a long way from achieving the objectives of 
the 6th Environmental Action Programme. Significant negative health and environmental 
impacts will continue to persist even with effective implementation of current legislation. 
Thus,  the  strategy  established  objectives  for  air  pollution  in  the  EU  and  proposed 
appropriate  measures  to  achieve  them.  To  that end, it has been identified  that  a further 
review of the emission limits for heavy duty vehicles beyond the current Euro standards 
(Euro  IV  and  V)  is  needed  to  meet  the  air  quality  targets  for  202010.  Furthermore,  the 
Council  Conclusions  on  the  Thematic  Strategy  emphasised  "that  achievement  of 
ambitious  objectives  depends  on  the  timely  adoption  and  implementation  of  further 
Community  measures,  therefore  urged  the  Commission  to  come  forward  as  soon  as 
possible  with  appropriate  proposals  inter  alia  on  emissions  from  engines  in  heavy-duty 
vehicles (EURO VI)"11 

The  Thematic  Strategy  on  Air  Pollution  has  identified  that  the  pollutants  from  road 
transport of most concern for human health are airborne particulates and ozone. Ozone is 
formed by reaction between HC and NOX, both of which are emitted by road transport. 
The road transport sector is a significant source of pollution; it was responsible for 41% 
of  total  NOX  emission  and  22%  of  total  non-methane  volatile  organic  compounds 
(NMVOCs) emissions in 2004.12 The transport sector (including road transport, shipping, 
aviation  and  rail)  accounted  for  29%  of  total  PM2.5  emissions  in  the  year  2000.13  Road 
transport  contributed  15  %  to  the  total  emissions  (i.e.  from  all  sectors)  of  acidifying 
substances  in  2001  for  EEA-31  (25  EU  Members  States,  Bulgaria,  Romania,  Turkey, 
Iceland,  Lichtenstein  and  Norway).  Road  transport  is  the  dominant  source  of  ozone 

7   Decision 1600/2002/EC - OJ L242, 10.9.2002 

8   COM(2001) 245 final, 04.05.2001 

9   Thematic Strategy on Air Pollution, COM(2005)446 final, 21.09.2005. 
10   Impact Assessment of the Thematic Strategy on Air Pollution, SEC(2005)1133, 21.09.2005, p. 22 

11   Council of the European Union: Thematic Strategy on Air Pollution − Council conclusions 7329/06 

http://ec.europa.eu/environment/air/cafe/pdf/council_concl_them_strategy.pdf 

12   Source: Eurostat – Environment and energy statistical data: 

http://epp.eurostat.cec.eu.int/portal/page?_pageid=0,1136239,0_45571447&_dad=portal&_schema=P
ORTAL. 

13   Impact Assessment of the Thematic Strategy on Air Pollution, SEC(2005)1133, 21.09.2005, p. 9, 26, 

31. 

  7

 
                                                 
 
precursors and contributed 36 % of total ozone precursor emissions in 2001 in EEA-3114. 
These pollutants are associated with damage to health and have detrimental impacts on 
ecosystems  through:  ozone  formation;  particulate  matter  formation;  acidification  and 
eutrophication.  Since  the  emissions  of  these  pollutants  from  motor  vehicles  are 
harmonised  at  EU  level,  the  Community  needs  to  address  these  issues,  as  it  carries 
responsibilities for the internal market for vehicles, public health and the environment. 

14   EEA factsheet of air pollutants from transport: 

http://themes.eea.eu.int/Sectors_and_activities/transport/indicators/consequences/TERM03%2C2003.
09/TERM2003_03_EEA31_Transport_emissions_of_air_pollutants_by_mode_final.pdf 

  8

                                                 
2.3.  Stakeholders affected 

A wide range of different groups are affected by the problem: 

•  The  population  of  the  European  Union  is  affected  by  poor  air  quality  through  the 
impacts  on  health  and  welfare  of  society.  In  the  year  2000,  exposure  to  particulate 
matter  was  estimated  to  reduce  average  statistical  life  expectancy  by  approximately 
eight months in the EU-25. This equates to approximately 3.6 million life years lost or 
348,000 premature mortalities per annum. In addition, it has been estimated that there 
were some 21,000 cases of hastened death due to ozone15. 

•  Consumers  of  motor  vehicles  are  affected  by  changes  in  the  price  of  new  vehicles, 

which may alter as a result of stricter vehicle emission limits. 

•  Stricter  emission  limits  affect  vehicle  manufacturers  by  requiring  improvements  to 

new vehicles through the development and introduction of better technologies. 

•  Component suppliers will be affected by increasing demand for advanced engine and 

exhaust gas after-treatment technologies. 

2.4.  Consequences of no change in policy 

With no change in the policy of reducing emission levels for motor vehicles, there is a 
high risk that the functioning of the internal market would be impaired. Poor air quality 
will  remain  an  issue  in  the  European  Union  as  atmospheric  pollution  will  continue  to 
have a detrimental impact on human health.  

With  no  additional  action  on  motor  vehicle  pollution,  it  is  likely  that  Member  States 
would  question  whether  EU  legislation  still  provides  a  high  level  of  environmental 
protection in the sense of Article 95 (3) of the Treaty. It is foreseeable that they would try 
to  promote  vehicles  that  fulfil  stricter  emission  limit  values.  There  is  a  risk  that  this 
would result in disruption to the single market if varying standards for vehicles emerge 
from  different  Member  States.  If  air  quality  remains  a  problem,  the  use  of  other 
measures,  such  as  bans  on  certain  types  of  vehicle  entering  cities  or  creation  of  low 
emission zones would also become even more widespread, restricting the free movement 
of goods and people. 

The  Thematic  Strategy  on  Air  Pollution  has  forecast  the  likely  levels  of  air  pollution 
given present policies for the period 2000-2020. Despite the improvements in pollutant 
emissions,  health  impacts  from  air  pollution  across  the  EU  are  still  projected  to  be 
considerable in 202016 . 

•  For  particulate  matter,  the  average  loss  in  statistical  life  expectancy  will  be  five 
months  in  2020.  Correspondingly,  in  2020  it  is  estimated  that  some  2.5  million  life 
years will be lost in the EU-25. This is equivalent to about 272,000 premature deaths. 

•  No significant decrease is estimated in the health impacts of ozone with 20,000 cases 

of hastened death in the year 2020. 

15   Thematic Strategy on Air Pollution, COM(2005) 446 final, 21.09.2005, p. 3 
16   Impact Assessment of the Thematic Strategy on Air Pollution, SEC(2005)1133, 21.09.2005, p. 11, 37, 

39 

  9

                                                 
The  total  annual  damage  costs  to  human  health  associated  with  particulate  matter  and 
ozone  pollution  in  2020  are  estimated  at  between  €189  billion  and  €609  billion.  This 
excludes an estimate of damage on ecosystems and cultural heritage which are difficult 
to value. 

It  has  to  be  noted  however  that  the  baseline  of  the  Thematic  Strategy  on  Air  Pollution 
included only the policy measures existing in 2000 and estimated the impacts of these in 
the year 2020. Therefore, the baseline of the Thematic Strategy on Air Pollution  did not 
include  the  measures  adopted  since  then,  such  as  the  Euro  5  and  6  emission  limits  for 
light-duty  vehicles  that  significantly  contribute  to  the  reduction  of  the  above  health 
impacts.  However,  the  Impact  Assessment  on  the  Thematic  Strategy  on  Air  Pollution 
assesses that, when considering the level of stringency in the three air quality scenarios 
foreseen for 2020, it had been assumed that lower emission limit values would be applied 
from October 2005 (Euro IV) and from October 2008 (Euro V) for heavy duty vehicles. 
Furthermore,  it  is  stated  that  "for  new  heavy  duty  vehicles,  the  assumption  was  that 
tightened emission limit values would take effect from 2013 in all Member States"17  

2.5.  Treaty base and subsidiarity principle 

Since  the  objective  of  the  Euro  VI  proposal  is  to  lay  down  harmonised  rules  on  the 
construction of motor vehicles with regard to their emissions with a view to ensuring the 
functioning of the internal market, the proposed Regulation is based on Article 95 of the 
EC Treaty.  

Atmospheric modelling shows that the pollution emitted in one Member State contributes 
to  pollution  in  other  Member  States  so,  in  order  to  solve  the  problem  of  air  pollution, 
concerted action at the EU scale is required. 

The subsidiarity principle is respected, since the policy objectives cannot be sufficiently 
achieved  by  actions  of  the  Member  States  and  can  be  better  achieved  at  Community 
level. European Union action is necessary because of the need to avoid the emergence of 
barriers  to  the  single  market  and  because  of  the  trans-boundary  implications  of  air 
pollution. 

17   Impact Assessment of  the Thematic Strategy on Air Pollution, SEC(2005)1133, 21.09.2005, p. 67 

  10

                                                 
3.  OBJECTIVES 

3.1.  Policy objectives 

The proposal pursues the following general policy objectives: 

•  Ensuring proper functioning of the internal market; and 
•  Providing for a high level of environmental protection in the European Union. 

The specific objectives cover: 

•  Setting harmonised rules on the construction of motor vehicles; and 
•  Improving air quality by reducing pollutants emitted by the road transport sector. 

3.2.  Consistency with horizontal objectives of the European Union 

3.2.1. Lisbon strategy 

The  policy  objectives  of  Euro  VI  are  in  line  with  the  aims  of  the  European  Union’s 
Lisbon strategy, which has three pillars, namely:  

•  Making Europe a more attractive place to invest and work 

The objectives of Euro VI are supporting the integrity of the single market, providing for 
uniform  standards  for  new  vehicles  sold  throughout  the  European  Union.  It  means  that 
the automotive industry in Europe is required to meet uniform regulations throughout the 
Internal  Market  of  the  EU.  This  will  ensure  that  the  European  heavy  duty  vehicle 
industry  remains  competitive  and  an  attractive  industry  to  invest  in.  The  proposal  will 
also contribute to enhancing its competitiveness on world export markets. 

The  CAFE  Programme  has  shown  that  air  pollution  has  significant  effects  on 
productivity.18 For example, the CAFE Cost-Benefit Analysis19 assessed the effects of air 
pollution  on  activities  of  the  population,  namely  by  estimating  the  Restricted  Activity 
Days  (RADs)  and  the  Work  Loss  Days  (WLDs)  for  each  Member  State  that  are 
attributable to air pollution. By seeking to reduce air pollution, the policy objectives of 
Euro VI contribute to increasing productivity in the European Union. 

•  Knowledge and innovation for growth 

New emission limits for vehicles encourage the development and implementation of new 
environmental  technologies.  The  policy  objectives  therefore  promote  innovation  and 
technological  development,  enabling  the  EU  to  keep  pace  with  the  technology 
development  of  the  automotive  industry  in  the  United  States  and  in  Japan.  The  vast 
majority of heavy-duty trucks and buses are using diesel technology in which Europe is 
world  leader.  Policies  which  support  the  development  of  cleaner  diesel  open  up  the 
potential for greater export of European technology to other parts of the world.  

18   Methodology for the Cost-Benefit analysis for CAFE, Volume 2: Health Impact Assessment, AEA 

Technology Environment, February 2005, p. 85 

19   CAFE Cost Benefit Analysis: Baseline Analysis 2000 to 2020, AEA Technology Environment, April 

2005, p.18, p. 60 

  11

                                                 
•  Creating more and better jobs 

In the Impact Assessment of the Thematic Strategy on Air Pollution (SEC (2005) 1133) 
it was demonstrated that reducing air pollution in the EU would have a negligible impact 
on employment. As Euro VI would be one of the measures considered in the Thematic 
Strategy, the overall employment impact of this proposal is also negligible.  One of the 
main  employment  impacts  is  likely  to  be  created  by  the  demand  for  new  vehicle 
components.  Given that more advanced technology would be required, the employment 
impact will be a mixture between high value added research and development activities 
and also manufacturing opportunities. 

3.2.2. Sustainable Development strategy  

the  core  of 

the  European  Union’s  Sustainable  Development  strategy,  as 
At 
communicated  by  the  Commission  to  the  European  Council  at  Göteborg  in  200120  and 
supported  by  the  European  Council,  is  that  “economic  growth,  social  cohesion  and 
environmental protection must go hand in hand”. The policy objectives of Euro VI are in 
line  with  the  strategy  by  ensuring  that  the  automotive  industry  grows  in  a  more 
sustainable  way  through  production  of  more  environmentally  friendly  vehicles.  Such 
vehicles bring social benefits through reducing the impacts on human health. 

3.2.3. Simplification of the regulatory framework 

The  proposal  provides  for  simplification  of  administrative  procedures  for  public 
authorities  (EU  or  national).  The  proposal  is  included  in  the  Commission's  rolling 
programme  for  up-date  and  simplification  of  the  acquis  communautaire  and  its 
Legislative Work Programme under the reference 2007/ENTR/009.  

Simplification  is  introduced  through  the  repeal  of  the  current  existing  Directives  in  the 
field of emissions from heavy duty vehicles and the integration of the test requirements 
for measuring diesel smoke, which were previously contained in Directive 72/306/EEC21 
into  this  proposal.  This  Directive  has  been  repealed  by  Euro  5  and  6  Regulation22. 
Council  Directive  80/1269/EEC23,  and  its  amendments,  relating  to  the  engine  power  of 
motor vehicles will also be repealed and its technical requirements have been included in 
this proposal. 

20   COM(2001)264 final. 
21  Council  Directive  72/306/EEC  of  2  August  1972  on  the  approximation  of  the  laws  of  the  Member 
States relating to the measures to be taken against the emission of pollutants from diesel engines for 
use in vehicles (OJ L 190, 20.8.1972, p. 1). 

22  Regulation  (EC)  No  715/2007  of  the  European  Parliament  and  of  the  Council  on  type  approval  of 
motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and 
Euro  6)  and  on  access  to  vehicle  repair  and  maintenance  information,  amending  Council  Directive 
70/156/EEC and Directive 2005/55/EC 

23   Council  Directive  80/1269/EEC  of  16  December  1980  on  the  approximation  of  the  laws  of  the 

Member States relating to the engine power of motor vehicles (OJ L 375, 31.12.1980, p. 46) 

  12

                                                 
4. 

 POLICY OPTIONS 

4.1.  Options Identified 

Four  policy  options  have  been  identified  as  possible  means  of  meeting  the  policy 
objectives identified in the previous section. These are: 

(1) 

No policy change, maintaining the Euro V emission limit values 

(2) 

(3) 

(4) 

(5) 

Regulatory approach at the European level: revising the existing Euro IV and 
V  legislation  through  setting  new  Euro  VI  emission  limit  values  at  European 
Union level. 

Regulation  in  Member  States:  Member  States  develop  their  own  emissions 
standards  and/or 
temporary  driving 
impose  other  policy  measures  (e.g. 
restrictions on vehicles not complying with more ambitious standards). 

Fiscal  incentives  by  Member  States:  Member  States  introduce  on  a  voluntary 
basis (or on the basis of a potential EU legislation) fiscal incentives for vehicles 
that fulfil stricter emission limit values than Euro V.  

Non-regulatory approach: self-regulation through negotiated commitments with 
the automotive industry to reduce the emissions from new vehicles.  

4.2.  Options discarded at an early stage 

Discussions  with  stakeholders  have  shown  that  there  is  little  interest  in  a  fundamental 
change in the regulatory system. Moreover, the ‘softer’ options such as self-regulation or 
voluntary  fiscal  incentives  may  not  deliver  on  the  environmental  side  or  would  not  be 
workable.  For example, the option may not be feasible due to the unanimity requirement 
in the Council with respect to a fiscal regime, or because it creates significant distortions 
in the working of the internal market. Therefore, four options were discarded at an early 
stage, these are: 

(1) 

No  policy  change,  maintaining  the  Euro  V  emission  limit  values:  As  stated  in 
section  2.4  with  no  change  in  the  policy  of  reducing  emission  levels  for  motor 
vehicles, there is a high risk that the functioning of the internal market would be 
impaired.  Poor  air  quality  will  remain  an  issue  in  the  European  Union  as 
atmospheric  pollution  will  continue  to  have  a  detrimental  impact  on  human 
health.  

(2) 

Regulation  in  Member  States:  Member  States  develop  their  own  emissions 
temporary  driving 
impose  other  policy  measures  (e.g. 
standards  and/or 

restrictions  

on vehicles not complying with more ambitious standards). 

This policy option was rejected because of its detrimental effects on the functioning of 
the  internal  market,  for  example  regarding  the  market of commercial vehicles,  but also 
the free movement of goods transported by these vehicles.  

(3) 

Fiscal  incentives  by  Member  States:  Member  States  introduce  on  a  voluntary 
basis (or on the basis of a potential EU legislation) fiscal incentives for vehicles 
that fulfil stricter emission limit values than Euro V. 

  13

 
The policy option of using fiscal incentives as a mechanism to introduce lower emission 
limits was rejected for the following reasons:   

•  Due to the unanimity requirement at the Council it is likely that legislation on support 

schemes would be very difficult to ever finalise. 

•  At present only a small number of Member States have a history of introducing fiscal 
measures  encouraging  the  introduction  of  cleaner  vehicles  in  advance  of  new  Euro 
standards,  so  uptake  of  the  measure  could  be  limited.  This  would  clearly  lead  to  a 
fragmented  internal  market,  since  only  a  limited  number  of  Member  States  would 
introduce incentives and manufacturers would have to construct vehicles according to 
different specifications. 

•  With a purchase tax regime, a key issue is their sustainability over a period of time.  
They could involve significant financial commitment by Member States so there is no 
guarantee that they would be in place for the long term. Therefore the resultant policy 
could lead to considerable uncertainty for manufacturers as to the demand for cleaner 
vehicles.  Fiscal incentives could be designed such that they are revenue neutral with 
charges on the sale of polluting trucks and buses subsidising the purchase of cleaner 
ones.  Such a tax would only be revenue neutral as long as sales of polluting vehicles 
continue to take place.  If the instrument becomes too successful and the market shifts 
to  cleaner  vehicles,  the  tax  base  will  diminish.    The  incentive  mechanism  will  then 
become  a  net  cost  to  the  Member  State.   If  the  incentive  scheme  were  to  finish,  the 
market risks shifting back to cheaper, less clean vehicles. 

•  In  order  to  make  such  an  approach  revenue  neutral  such  an  option  could  only  work 
through  differentiation  of  circulation  taxes.    For  example,  vehicles  fulfilling  a  more 
ambitious  but  indicative  new  norm  would  benefit  from  reduced  taxes  (or  a  direct 
subsidy),  whilst  vehicles  fulfilling  the  norms  in  place  when  the  vehicles  were 
registered for the first time would come with higher circulation taxes. The higher the 
penetration  rate  of  new  vehicles,  the  higher  the  tax  ‘penalty’  for  older  ones  would 
have  become  for  revenue  neutrality  to  continue.  This  could  lead  to  undesired 
distortions  of 
the  market  and  unacceptable  negative  economic  and  social 
consequences for the owners of vehicles already on the market. 

•  If uncoordinated, different types of incentive regimes in neighbouring countries could 
result  in  unpredictable  cross  border  effects,  both  in  terms  of  vehicle  purchasing 
patterns  and  air  pollution  impacts.  The  continued  existence  of  the  single  market  for 
vehicles  could  therefore  be  put  in  danger.    A  Commission  Communication  giving 
some guidance to Member States could perhaps help at an early stage.  However, such 
a Communication would also have to develop indicative vehicle emission limit values 
so as to give some guidance on an adequate tax differentiation.  Thus, if effective this 
would eventually come close to a regulatory approach without delivering the planning 
security  for  vehicle  manufacturers  and  the  greater  environmental  certainty  that  a 
regulation would bring about. 

In conclusion, such a policy option does not ensure that the stated policy objectives are 
attained and could even have a negative impact on the functioning of the internal market 
through reducing the certainty as to the demand for specific types of vehicles.  However, 
fiscal incentives could be used by Member States (preferably in a budget neutral way) as 
an accompanying measure to a European regulation so as to accelerate the penetration of 
new  vehicles  fulfilling  more  ambitious  standards.  Furthermore,  the  use  of  fiscal 
incentives  to  accelerate  the  penetration  of  new  –  more  environmentally  friendly  – 
  14

vehicles is already a feature of applicable emissions legislation both for light and heavy 
duty  vehicles.  This  approach  ensures  that  fiscal incentives are only used for an interim 
period in advance of the application of the new emission standards. 

(4) 

Non-regulatory approach: self-regulation through negotiated commitments with 
the automotive industry to reduce the emissions from new vehicles. 

The policy option of self-regulation was discarded due to the following reasons:  

•  Self-regulation  would  imply  a  significant  departure  from  an  approach  that  is  well 
established all over the world and has proven its effectiveness and proportionality in 
the past. 

•  A large number of other countries around the world base their emissions regulation on 
EU  practice.    A  radical  change  in  approach  to  a  non-regulatory  approach  risks 
reducing the EU’s leadership in this area.  The use of EU regulation by other countries 
also  offers  competitiveness  benefits  to  the  EU  automotive  industry  which  could  be 
affected by a change of approach. 

•  It is not clear that a self commitment provides an adequate guarantee that a specific 
emission level will be reached or that there will be appropriate sanctions available if 
the self-commitment were to be breached.  

•  As  the  issue  of  emission  control  has  repercussions  on  the  protection  of  the 
environment  and  public  health,  it  is  questionable  whether  a  self-commitment  can  be 
justified. 

•  A self-regulation approach could take too much time to be negotiated and to deliver 
the hoped-for effects. Due to the problem of several Member States to meet existing 
air  quality  targets,  there  is  a  certain  urgency  to  introduce  action  that  has  more 
immediate effects. 

In  addition,  it  is  not  apparent  that  the  use  of  a  voluntary  approach  would  offer  any 
additional benefits to the industry, governments or the general public. It is likely that a 
similar  compliance  process  would  be  used  as  currently  exists  in  the  type  approval 
system,  however  there  would  be  additional  transaction  costs  in  establishing  an 
appropriate  monitoring  and  compliance  mechanism.    A  regulatory  approach  instead 
would provide industry with a stable and predictable framework in which investment in 
better technology solutions would be stimulated. 

  15

5.  ANALYSIS OF IMPACTS 

5.1.  Impacts of the policy options 

This  section  analyses  the  impacts  of  the  Regulatory  approach  (policy  option  2  – 
introducing  new  Euro  VI  limit  values)  relative  to  the  No  policy  change  option  (policy 
option  1  –  maintaining  Euro  V  emission  limit  values).  The  potential  economic, 
environmental and social impacts have been examined. 

5.1.1. Option 1 - No policy change 

As discussed in Section 2.4 and 4.2, the option of no policy change (maintaining Euro V 
emission limit values) is not considered a viable way forward due to the significance of 
the air pollution problems that the EU faces.  However for the purpose of this chapter this 
option  provides  a  baseline  to  consider  the  impact  of  the  Regulatory  approach.    The 
impacts related to the baseline have been based on the forecasts made under the CAFE 
Programme. Any potential limitations with the forecasts have already been considered in 
the development of the CAFE Programme, so it is not necessary to consider these issues 
in the present impact assessment. 

5.1.2. Option 2 - Regulatory approach  

Considerable emphasis was given to gathering data from stakeholders to understand the 
costs  of  varying  emission  limits.  There  is  substantial  information  asymmetry  as  those 
with the best information on these costs do not necessarily have clear incentives to make 
it  public.  Another  key  issue  with  cost  data  relates  to  understanding  the  effect  of  mass 
production on new technology. A more detailed explanation of this process is provided in 
section 6. 

5.1.2.1.  Economic impacts 

The  fulfilment  of  stricter  emission  limit  values  would  require  the  increased  use  or  the 
development  and  introduction  of  new  technologies  to  reduce  emissions  of  pollutants. 
There are a number of economic impacts that result from the further regulation of vehicle 
emissions: 

•  Single market 

Harmonised emission limit values throughout the European Union would have a positive 
impact on the competition in the internal market by sustaining a ‘level playing field’ for 
all automotive businesses. 

•  Competitiveness 

This policy option may have neutral direct impacts overall on the competitiveness of the 
automotive industry of the European Union. The option may increase the operating costs 
of  businesses  in  the  automotive  industry  through  the  additional  cost  of  additional 
components  and  also  research  and  development  expenditure.  However,  the  competitive 
position  of  the  manufacturers  within  the  EU  would  not  be  influenced  by  the  policy 
option. Moreover, costs and economic impacts could be expected to diminish over time, 
once a new technology becomes established and production costs fall. 

  16

 
The policy option would have some indirect impacts as well in terms of competitiveness. 
The automotive industry could become more competitive in markets outside the EU with 
strict  environmental  regulation  in  force,  through  being  able  to  produce  vehicles  and 
engines  equipped  with  advanced  environmental  technologies.  Moreover,  it  should  be 
noted that at present, the EU is the world leader in clean diesel technology. Encouraging 
the development of cleaner diesel vehicle technology will have a positive impact on the 
international  competitiveness  of  EU  industry  through  expanding  the  size  of  the  global 
clean diesel market. 

Further  development  of  EU  emissions  standards  ensures  their  continued  use  in  other 
markets  around  the  world.    At  present  there  are  three  main  systems  used  around  the 
world for setting vehicle emission limits, these are those from the EU, the United States 
and Japan. Currently there is widespread use of EU standards in OECD countries such as 
Australia  and  emerging  markets  around  the  world,  including  in  China  and  India.    As 
many  of  these  markets  have  significant  air  quality  problems  and  are  experiencing  high 
growth in the use of heavy duty vehicles, there is continued demand for better standards.  
Current high levels of oil prices and concerns over security of supply, is increasing the 
level  of  interest  in  diesel  technology  in  a  number  of  markets,  where  petrol  engines  are 
still used in heavy duty vehicles.  So driving forward the development of cleaner diesel 
technology  is  an  important  need  which  could  provide  competitiveness  benefits.  
Therefore  further  evolution  of  EU  policy  in  this  area,  will  sustain  the  use  of  the  Euro 
system so be in the interests of both EU based manufacturers and equipment suppliers. 

Finally,  a  policy  that  makes  it  necessary  to  develop  and  introduce  new  environmental 
technologies  would  benefit  indirectly  the  component  suppliers  in  the  automotive 
industry, who would benefit from increasing revenues. 

•  Affordability of vehicles 

The  necessary  technological  developments  will  result  in  an  increase  in  prices  of  new 
vehicles,  which  might  to  a  certain  extent  negatively  affect  road  hauliers  and  bus 
operators  in  the  European  Union.  However,  these  would  also  benefit  from  the  proper 
functioning  of  the  internal  market  indirectly  through  greater  competition  between 
manufacturers  and  the  reduction  in  barriers  to  cross-border  vehicle  purchases.  At  any 
rate,  the  price  increase  will  be  small  compared  to  the  cost  of  a  new  truck  or  bus. 
Moreover,  road  hauliers  and  bus  operators  are  generally  able  to  pass  on  any  increased 
costs towards their customers so that the price increase that the end consumer of goods 
and services will have to bear will be minimal.  

5.1.2.2.  Environmental impacts 

•  Air quality 

As  explained  in  Section  2.2,  the  Thematic  Strategy  on  Air  Pollution  identified  that  a 
further  review  of  the  emission  limits  for  heavy  duty  vehicles  beyond  the  current  Euro 
standards (Euro IV and V) is needed to meet the air quality targets for 2020.24 

This policy option would result in improvement in air quality through reducing the levels 
of pollution produced by road transport, in particular by heavy-duty vehicles, and would 
therefore be an essential part of the regulatory measures necessary to meet the air quality 

24   Impact Assessment of the Thematic Strategy on Air Pollution, SEC(2005)1133, 21.09.2005, p. 22 

  17

                                                 
objectives  for  2020.  A  decrease  in  the  areas  under  threat  of  ozone  and  eutrophication 
would be a result of reduced air pollution from vehicles. Furthermore, cleaner air in cities 
would also reduce damage to buildings and cultural heritage. 

•  Biodiversity  

The  regulatory  option  would  have  reduced  impact  on  biodiversity  compared  to  the 
baseline scenario through reducing the emission of pollutants from vehicles. The threats 
of ozone and eutrophication on biodiversity would be reduced. 

•  Climate 

Tighter emission limits could have both direct and indirect effects on fuel consumption 
and  greenhouse  gas  emissions.  The  direct  impact  is  due  to  some  forms  of  engine 
technology and after-treatment resulting in slightly higher CO2 emissions in comparison 
with  the  Euro  V  stage,  therefore,  the  policy  option  might  cause  the  emission  of 
greenhouse gases to increase. Given the nature of emission limits being considered, and 
the likely technologies used to reach these limits a small direct negative impact on CO2 
could be expected.  

However,  there  might  be  some  positive  impacts  indirectly.  Because  of  the  strong 
competition  in  the  transport  industry  and  the  resulting  cost  pressure  in  the  sector, 
operators  tend  to  choose  the  vehicles  with  the  lowest  fuel  consumption.  Therefore, 
greenhouse  gas  emissions  may  be  decreased  since  vehicle  manufacturers  will  try  to 
diminish the fuel consumption through technological measures in order to achieve high 
sales volumes of their vehicles. Then fuel consumption could be maintained close to the 
level in Euro V in the long term.  

5.1.2.3.     Social impacts 

•  Public health 

Better  air  quality  would  improve  public  health  by  decreasing  morbidity  rates  and 
increasing life expectancy of the population, which in turn results in lower mortality. The 
impacts will grow in proportion to the penetration of newer low emission vehicles onto 
the market while older more polluting vehicles are retired. 

•  Employment 

The proposal has no perceptive impact on employment (see Section 3.2.1). 

5.2.  Conclusion 

In conclusion, in comparison with the no policy change option, the regulatory option will 
have  the  clear  benefits  of  ensuring  the  proper  functioning  of  the  internal  market  and 
improving  air  quality.  This,  in  turn,  will  improve  public  health  and,  thus,  will  enable 
Governments to generate savings. 

As  far  as  the  competitiveness  of  industry  is  concerned,  the  indirect  impacts  of  the 
regulatory option might be positive as the international competitiveness of EU industry, 
especially in markets with strict environmental regulation in force, might be improved. 

  18

On the other hand, the introduction of new technologies will bring additional costs and 
result in an increase in consumer prices of new vehicles. 

It is therefore essential to ensure a right balance between higher environmental standards 
and the increase of vehicle cost. To this effect, in the next section different sub-options 
under the regulatory option are compared. 

  19

6. 

IDENTIFICATION OF THE BEST SUB-OPTION UNDER THE REGULATORY OPTION 

In  this  section,  different  sub-options  under  the  regulatory  option  are  compared,  where 
possible, based on a quantification of their impacts.  

6.1.  Data Collection and Modelling of the Impacts 

The  Euro  VI  proposal  was  developed  in  the  context  of  the  Commission’s  Thematic 
Strategy  on  Air  Pollution.  Stakeholders  were  actively engaged in the discussion of this 
programme. 

In the preparation for a new set of limit values for heavy-duty vehicles, the Commission 
services  sent  out  a  questionnaire  to  stakeholders  that  requested  information  on  the 
technologies needed and the associated costs for meeting a number of different scenarios 
for possible Euro VI limit values. Those scenarios represented a reduction of 50 to 90% 
in NOx and 33 to 66% in PM in relation to the already defined Euro V stage for the years 
2008-2009. One of the scenarios was considered as equivalent to the one to be introduced 
in US in the period 2007-2010.  

 The questionnaire was sent in the autumn of 2004 to the stakeholders participating in the 
Motor  Vehicle  Emission  Group  (MVEG)  and  contained  specific  questions  about 
technologies,  cost,  durability  and  additional  requirements  to  fulfil  11  emission  limit 
scenarios  (6  for  compression  ignition  engines  and  5  for  positive  ignition  engines). 
Official  responses  to  the  EC's  request  for  information  were  submitted  by  the  European 
Association of Vehicle Manufacturers (ACEA), the European Association of Control by 
Catalyst  (AECC),  the  European  Natural  Gas  Vehicle  Association  (ENGVA)  and  the 
German Agency for the Environment (UBA).   

The  responses  received  from  the  stakeholders  were  then  provided  to  a  panel  of  three 
independent experts for validation. Some further discussion was held between the panel 
and  the  stakeholders  in  order  to  clarify  outstanding  issues  and  to  generate  additional 
information. The results of the work of the expert panel were reported to the Commission 
services in the study referred to as TNO Report. 

The data summarised by the panel was used as input for the modelling of the impacts of 
different scenarios. The analysis was carried out by using the TREMOVE model, which 
was  developed  in  the  context  of  the  CAFE  Programme.  TREMOVE  is  a  policy 
assessment model designed to study the effects of different policies on the emissions of 
the  transport  sector.  More  details  on  this  model  can  be  found  in  Section  6.2.5.  The 
modelling work was reported in two reports referred to as LAT study and LAT study No. 
2. 

6.2.  Scenarios (Sub-options) of the Regulatory approach 

A  number  of  scenarios,  hereafter  named  as  sub-options,  combining  different  levels  of 
particulate  matter  (PM),  nitrogen  oxides  (NOx)  and  hydrocarbon  (HC)  emission  limit 
values  for  compression  ignition  engines  (CI)  and  positive  ignition  engines  (PI)  fuelled 
with natural gas (NG) and liquefied petroleum gas (LPG) have been developed for policy 
option 2 (Regulatory approach), including one with limit values equivalent to those to be 
applicable in US from 2010. Those sub-options were included in the questionnaire sent 
to stakeholders (see section 1.2) and are described in Table 2.  

  20

6.2.1. Baseline 

For the purpose of the evaluation of the impacts of possible Euro VI emission limit value 
sub-options and to assess the costs and benefit of each sub-option, Euro V has been taken 
as baseline, which approach corresponds to the 'no policy change' option. In line with this 
approach, the baseline of TREMOVE 2.43b – which version was used for the modelling 
exercise – includes EURO V as final heavy-duty vehicle emission reduction step.25 

As an example, for compression ignition engines, the Euro V limit values are included in 
Table 1. 

Table 1: Euro V emission standards (Operation Cycle: ETC)  
for compression ignition engines considered in the baseline sub-option 

Pollutant 

g/kWh (ETC) 

CO 

THC 

NOx 

PM 

4.0 

0.55 

2.0 

0.03 
Source: Directive 2005/55/EC 

6.2.2. Euro VI emission limit value sub-options 

The  emission  limit  value  sub-options  that  have  been  developed  and  considered  for  the 
Euro VI stage of heavy-duty vehicles are shown in Table 2. 

Table 2: Euro VI emission limit value sub-options 

Sub-option 

A 

B 

C 

D 

Engine 

CI 

PI 

CI 

PI 

CI 

PI 

CI 

PI 

PM 

0.01 

0.01 

0.02 

0.02 

0.015 

0.02 

0.015 

0.01 

NOx 

0.4 

0.4 

0.2 

2.0 

1.0 

2.0 

0.5 

1.0 

THC 

0.16 

0.66 

0.55 

1.05 

0.55 

1.05 

0.55 

1.05 

t
i

m

i
l
n
o
i
s
s
i

m
E

)
h
W
k
/
g
(

s
e
u
l
a
v

The  percentage  reductions  for  the  various  compression  ignition  engine  Euro  VI  sub-
options over the Euro V baseline are shown in Table 3. 

25   LAT study, p. 6 

  21

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 3: Reductions of emission limit values of Euro VI sub-options  
over EURO V for compression ignition engines (%) 

Pollutant 

Sub-option A 

Sub-option B 

Sub-option C 

Sub-option D 

PM 

NOx 

THC 

66 

80 

70 

33 

90 

- 

50 

50 

- 

50 

75 

- 

The limit value for CO remains unchanged compared to Euro V. 

6.2.3. Evaluation of sub-options  

The  cost  implications  for  the  various  sub-options  examined  as  part  of  this  proposal, 
taking into account the possible technology options, are set out in  

Table 4. This summarises the average cost per vehicle for each sub-option, expressed in 
2012 Euros. The figures are based on the replies from stakeholders to the questionnaire 
sent  by  the  Commission  as  reported  by  the  panel of  independent experts.  According to 
the panel report, due to the unpredictability of the precious metal price towards 2012, the 
price level used has been taken constant at the level of summer 2004 but, in order to take 
into  account  that  the  actual  precious  metal  loading  of  the  catalyst  to  achieve  certain 
emission  reduction  efficiencies  is  likely  to  decrease  over  time  (thrifting  effect)  a 
correction of 30% has been applied.26 In addition, due to uncertain production volumes 
of  certain  components  in  2012,  especially  NOx  after-treatment  systems  and  diesel 
particulate  filters,  the  cost  figures  could  be  lower  than  those  expressed  by  the 
stakeholders  in  the  questionnaire.  Furthermore,  no  reduction  in  costs  is  made  to  take 
account  of  mass  production  economies  of  scale.  Therefore, cost data should be seen  as 
worst case.  

The  highest  cost  sub-options  relate  to  those  with  the  most  significant  PM  and  NOx 
reduction.  

26   TNO Report, p. 45 

  22

 
 
 
 
 
 
                                                 
Table 4: Sub-optionss of Euro VI emission limit values and sales weighted average 
cost per heavy-duty vehicle (2012 prices) 

Sub-option 

A 

B 

C 

D 

Engine 

CI 

PI 

CI 

PI 

CI 

PI 

CI 

PI 

PM 

0.01 

0.01 

0.02 

0.02 

0.015 

0.02 

0.015 

0.01 

NOx 

0.4 

0.4 

0.2 

2.0 

1.0 

2.0 

0.5 

1.0 

THC 

0.16 

0.66 

0.55 

1.05 

0.55 

1.05 

0.55 

1.05 

Average cost per vehicle (€) 

6 l 

9 l 

2539 

--- (1) 

2838 

--- 

1027 

--- 

1227 

--- 

3226 

1825 (2) 
4025 (3) 

3575 

1000 (2)
1825 (3) 

1333 

1000 (2) 
1825 (3) 

1583 

1000 (2)
3825 (3) 

12 l 

4009 

--- 

4423 

--- 

1741 

--- 

1991 

--- 

Baseline 

Euro 
V 

Euro V 

Euro 
V 

Euro V 

Euro V 

Euro 
V 

Euro 
V 

Euro V 

t
i

m

i
l
n
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i
s
s
i

m
E

)
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k
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g
(

s
e
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e
n
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g
n
E

t
n
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m
e
c
a
l
p
s
i
d

Source: TNO report 
(1) For positive ignition engines (PI), the representative engine displacement is considered to be 9 litres. 
(2) Stoichiometric engines; (3) Lean burn engines.  

It  is  to  be  noted  that  directives  currently  applicable  to  the  limitation  of  pollutant 
emissions  from  heavy  duty  engines  and  vehicles  (Euro  IV  and  V  stages)27  have 
introduced  the  concept  of  “Enhanced  Environment-friendly  vehicle”  (EEV)  as  those 
vehicles  propelled  by  an  engine  which  complies  with  permissive  limit  values  more 
stringent than those for Euro V. At this stage, vehicles fulfilling those requirements are 
provided with positive-ignition engines and, therefore, taking the EEV as the reference, 
the cost for a representative engine would be:  

27   Directive 2005/55/EC of the European Parliament and of the  Council, of 28 September 2005, on the 
approximation  of  the  laws  of  the  Member  States  relating  to  the  measures  to  be  taken  against  the 
emission of gaseous and particulate pollutants from compression-ignition engines for use in vehicles, 
and  the  emission  of  gaseous  pollutants  from  positive-ignition  engines  fuelled  with  natural  gas  or 
liquefied petroleum gas for use in vehicles. O.J. L 275, 20.10.2005, p.1, and subsequent amendments 

  23

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 5: Sales weighted average cost per positive ignition engined vehicles with 
reference to EEV (€ in 2012 prices) 

e
n
i
g
n
E

t
n
e
m
e
c
a
l
p
s
i
d

CI  

PI  

CI  

PI  

CI  

PI  

CI  

PI  

9 l 

825 (2) 
2200 (3) 

Baseline  

EEV 

0 (2) 
0 (3) 

EEV  

0 (2) 
0 (3) 

EEV  

0 (2) 
2000 (3) 

EEV  

(2) Stoichiometric engines; (3) Lean burn engines.  

The  9  litre  engine  is  considered  fully  representative  of  the  current  fleet  of  positive 
ignition engines.  

6.2.4.  Possible emission reduction technologies for different sub-options 

Taking into account that gas vehicles represent less than 1% of the whole fleet of heavy 
duty vehicles, this section focuses on vehicles fuelled with diesel. 

To  achieve  the  sub-option  A  NOx  limit  value,  both  cooled  EGR  and  SCR  might  be 
necessary.  Together  with  an  advanced  development  of  the  combustion  system,  fuel 
injection  and  turbo-charging  technology,  it  seems  feasible  to  meet  the  PM  limit  with 
either an open-flow DPF or a wall-flow DPF.  

Limit  values  in  this  sub-option  are  considered  to  be  equivalent  to  the  most  stringent 
standards  that  will  be  introduced  in  the  US  from  2010.  Those  US  standards  were 
introduced  following  a  public  consultation  and  impact  assessment28.  This  impact 
assessment has shown that the US standards will result in substantial benefits to public 
health  and  welfare  and  the  environment  through  significant  reductions  in  emissions  of 
NOx,  PM  and  other  pollutants.  It  is  assessed  that  by  2030,  the  total  net  benefit  of  the 
introduction of new standards in 2010 will result in a benefit of $70.3 billion in the US. 

Nevertheless,  some  considerations  should  be  taken  when  comparing  the  European  and 
US legislative framework: 

- The US legislation includes a programme on Averaging, Banking and Trading (ABT) in 
which  manufacturers  are  allowed  to  certify  their  engine  families  with  various  family 
emission limits (FELs), provided that in each model year the average of the FELs does 
not exceed the emission standard when weighted by the numbers of engines produced in 
each family for that model year. 

- Emission credits are generated by engine families that are certified below the applicable 
standard. 

- The credits can be used to offset the production of engine families that are certified to 
have emissions in excess of the applicable standard. 

28   Federal Register / Vol. 66, No. 12 / Thursday, January 18, 2001 / rules and Regulations 

  24

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
-  Manufacturers  are  allowed  to  bank  these  credits  for  later  use  or  trade  them  to  other 
manufacturers. 

The  system  of  Averaging,  Banking  and  Trading  (ABT)  included  in  the  certification 
procedure in the  US is  substantially different from the one of type-approval in Europe. 
The ABT means that it is sufficient that a family of vehicles reaches a limit value of 0.7 
g/kWh  NOx,  which  is  substantially  higher  than  the  value  proposed  with  sub-option  A. 
This would mean that some vehicles would be allowed to emit more than others. This is 
particularly problematic if those vehicles are operated in urban areas. 

This  approach  is  not  likely  to  bring  about  any benefit and would imply the  set up of a 
costly  and  complicated  monitoring  and  compliance  mechanism,  whereby  the  emission 
performance  of  a  manufacturer's  products  are  reported,  verified  and  approved. 
Furthermore, an emissions trading mechanism between manufacturers would have to be 
set up. This can only be done with the help of an agency that would have to be created. 
The introduction of Euro VI would certainly be delayed by several years. 

Therefore, this issue has not been considered in the impact assessment. 

Due to the fact that there are no standards for CO2 emissions and fuel consumption, the 
evaluation of these impacts of the various sub-options was based on a comparison to the 
current Euro IV stage. 

In  sub-option  A,  fuel  consumption  and  therefore  CO2  emissions  are  likely  to  increase 
slightly compared to the Euro IV baseline, especially in the case of a wall-flow DPF.29 
This increase is estimated to be in the order of 2-3%, however, as explained in section 
5.1.2.2,  may  decrease  in  the  long  term.  In  this  context, the US legislation foresees  that 
after  some  years  after  the  introduction  of  measures  (by  2010)  the  increase  in  fuel 
consumption  can  be  regained  through  the  optimisation  of  the  engine  and  the  after-
treatment systems so that, at the end, no fuel economy penalty results.30 

To achieve the sub-option B NOx limit, both cooled EGR and SCR might be necessary.  
At  this  NOx  level,  a  wall-flow  DPF  will  be  needed  to  meet  the  PM  limit  value.  Fuel 
consumption  and  therefore  CO2  emissions  are  likely  to  increase  significantly  (in  the 
order of 5-6%) compared with the Euro IV baseline.31 

Sub-option C  could  be  achieved  either with EGR or SCR technology. The use of EGR 
will imply rates over 25% with larger radiators and heat exchangers, which will tend to 
increase the fuel consumption. For manufacturers using SCR technology already for the 
Euro V stage, the engine will be kept without major changes but the urea dosing strategy 
will be revised. For this sub-option, a wall-flow DPF may be needed.32  

29   TNO report, p. 32 

30   Federal Register / Vol. 66, No. 12 / Thursday, January 18, 2001 / rules and Regulations (pages 5061 to 

5063) 

31   TNO report, p. 32, p.39 

32   TNO report, p. 32, p.39 

  25

 
 
 
 
                                                 
It seems unlikely that the NOx level in sub-option D can be achieved with cooled EGR 
only,  but  if  so,  fuel  consumption  and  therefore,  CO2  emission  will  increase  due  to  the 
high  level  of  EGR  required.  The  alternative  strategy  to  use  SCR  appears  to  be  more 
feasible,  although  some  cooled  EGR  will  be  needed  to  achieve  the  NOx  target.33  This 
latter  solution  could  be  considered  as  having  neutral  impact  on  fuel  consumption  and 
CO2 emissions. For this sub-option, a wall-flow DPF may be needed. 

6.2.5. Impacts of Euro VI emission limit value sub-options 

The  impacts  of  each  of  the  above  mentioned  sub-options  have  been  evaluated  with  the 
TREMOVE  model.34  TREMOVE  is  a  policy  assessment  model  designed  to  study  the 
effects of different transport and environment policies on the emissions of the transport 
sector.  It  covers  economic,  environmental  and  technical  aspects  of  transport  and  it  is 
therefore usable for the evaluation of the impacts of different sub-options. 

It  contains,  inter  alia,  information  on  the  mileage  travelled  by  vehicles  in  the  different 
transport  modes,  the  vehicle  stock  and  its  specific  emissions,  as  well  as  on  the  cost  of 
transport  and  technologies.  It  covers  the  major  part  of  Member  States  of  the  EU, 
Switzerland and Norway. 

It  has  to  be  noted  that  the  impact  of  more  stringent  limit  values  for  positive  ignition 
engines  have not  been  included in the TREMOVE model runs, due to the fact  that gas 
engines  in  heavy  duty  vehicles  represent  less  than  0.2%  of  the  total  number  of  those 
vehicles.35  The  model  runs  have  been  developed  under  the  assumption  that  70%  of 
compression ignition Euro V vehicles are using SCR technology and 30% are using EGR 
technology. Therefore, the cost of urea has been included in the calculations.36 

On the basis of the calculations performed with the TREMOVE model, it is possible to 
assess the monetary impacts of the identified emission limit value sub-options within the 
regulatory policy option. This assessment includes the estimation of the total economic 
cost of sub-options and the associated pollution benefits. A more detailed explanation of 
the concepts used in TREMOVE is provided in Box 1.  

33   TNO report, p. 32, p.39 

34   www.tremove.org  

35   LAT study, p. 7 

36   LAT  study 

  26

 
 
 
 
                                                 
Box 1: TREMOVE model 

The TREMOVE model is designed to analyse welfare differences between the basecase sub-option and 
alternative  policy's  sub-options.  The  welfare  differences  calculated  by  TREMOVE  are  composed  of 
four components: 

•  Changes in aggregated utility level of households; 

•  Changes is aggregated production costs of firms; 

•  Welfare changes stemming from changes in government tax revenues; 

•  Changes in external environmental costs. 

Households 

A decrease in utility then can stem from an increase in consumption and/or a substitution of low utility 
goods by high utility goods. Both could be the results, of, amongst others, changes in price structures 
or changes in infrastructures. 

Production 

Next to the calculation of the impact of policy sub-options on aggregate household utility, TREMOVE 
also calculates the impacts on the overall production costs of firms and service sectors. As TREMOVE 
is a partial equilibrium model, it assumes that the overall production level of goods and services is not 
affected by the policy sub-options. 

Public funds 

To evaluate the welfare effect of these increases in tax revenues, an assumption has to be taken on the 
way in which the government will make us of the additional tax revenues from the transport sector. As 
the government balances its revenues and expenses, changes in revenues from the transport sector will 
be compensated in one or another way. 

External costs 

In TREMOVE, country values for external costs per ton of pollutant are derived from the cost-benefit 
analysis research in the Clean Air for Europe Programme. 

Furthermore, it has to be noted that the results of the TREMOVE model runs involve uncertainty, given 
that  it  is  based  on  the  current  knowledge  regarding  vehicle  mileage,  vehicle  stock  and  specific 
emissions.  Any  future  change  in  these  variables  can  introduce  some  variation  in  the  final  impacts  of 
any of the Euro VI sub-options. 

TREMOVE  version  2.43b  covers  the  period  up  to  2020.  The  results  of  the  model  runs 
performed with this version of the model are provided in Section 6.2.5.1.  

Given  that  in  2030  a  higher  proportion  of  heavy  duty  vehicles  on  EU  roads  will  have 
been type approved according to Euro VI than in 2020, it is considered also appropriate 
to  evaluate  the  cost  and  benefits  of  the  different  sub-options    in  that  year.  TREMOVE 
version  2.52  covers  the  period  until  2030  and  uses  different  emission  factors  and 
assumptions than version 2.43b. This version of the model became available during the 

  27

 
 
 
 
 
impact assessment process. The results of the model runs performed with this version of 
the model are provided in Section 6.2.5.2. 

 The main differences between the two versions are the following: 

•  v2.52 covers EU31, while v2.43b covers EU21. This results in a total number of vkm 
in  v2.52  37.7%  higher  than  v2.43b,  which  is  directly  reflected  on  the  calculated 
emission reduction; 

•  The NOx emission factors in v2.52 are much higher than in v2.43b, up to 3.4 times. 
This originates from the shift from COPERT III to COPERT IV methodology and the 
assumptions  made  for  the  aggregation  of  emissions  into  TREMOVE  heavy  duty 
vehicle categories.  

•  The PM emission factors between the two versions are not much different, except for 

buses. However, all values are consistent with the COPERT IV emission factors. 

•  COPERT  IV  emission  factors  for  HDV  have  a  more  detailed  vehicle  type 

categorization (19 classes), while COPERT III included 6 classes.  

•  v2.52 does not distinguish between Buses and Coaches as V2.43b did. V2.52 has only 

one category: “Buses”.  

The  impacts  of  the  emission  limit  value  sub-options  have  been  calculated  also  with 
version 2.52 of the model. The results are provided in Section 6.2.5.2. 

It should be noted that the codes used for sub-options in the TREMOVE model runs are 
different from those used in this impact assessment. 

6.2.5.1.  Evaluation of sub-options with TREMOVE 2.43b 

The sum of the PM and NOx pollution abated and the detailed cost and benefit analysis 
for each sub-option are the following: 

Sub-option A 

Table 6: Total NOx and PM emissions -  
difference between baseline and sub-option A in 2020 

Total NOx 
Total PM 

tons 
226929 
3290 

percent 
37 
22 
Source: LAT study, p. 46 

Figure 1: Total NOx emissions – 2012-2020 – Sub-option A (in tons/annum) 

  28

 
 
 
 
 
 
 
 
NOx

BaseCase
Scenario A1/G5

1.20E+06

1.00E+06

8.00E+05

a
/
t

6.00E+05

4.00E+05

2.00E+05

0.00E+00

2012

2014

2016

2018

2019

2020

Source: LAT study, p. 46 

Figure 2: Total PM emissions – 2012-2020 – Sub-option A (in tons/annum) 

PM

BaseCase
Scenario A1/G5

4.00E+04

3.50E+04

3.00E+04

2.50E+04

a
/
t

2.00E+04

1.50E+04

1.00E+04

5.00E+03

0.00E+00

2012

2014

2016

2018

2019

2020

Source: LAT study, p. 46 

Table 7: Monetary impact of sub-option A in 2020 (million Euros) 

Sum of utility of households 
Sum of production costs 
Sum of cost of public funds (general) 
Total welfare effect w/o pollution benefits (general) 

Sum of external cost CO 
Sum of external cost CO2 
Sum of external cost N2O 
Sum of external cost NOx 
Sum of external cost PM 
Sum of external cost SO2 
Sum of external cost VOC 
Pollution benefits 
Sum of welfare (general) 

43.7 
827.3 
82.9 
953.9 

0.0 
12.7 
0.4 
3,455.9 
270.9 
16.3 
224.4 
3,980.6 
3,026.7 

Source: LAT study, p. 45 

Sub-option B 

  29

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 8: Total NOx and PM emissions -  
difference between baseline and sub-option B in 2020 

Total NOx  
Total PM  

tons 
255177 
1628 

percent 
41 
11 
Source: LAT study, p. 48 

Figure 3: Total NOx emissions – 2012-2020 – Sub-option B (in tons/annum) 

NOx

BaseCase
Scenario B1/G6

1.20E+06

1.00E+06

8.00E+05

a
/
t

6.00E+05

4.00E+05

2.00E+05

0.00E+00

2012

2014

2016

2018

2019

2020

Source: LAT study, p. 48 

Figure 4: Total PM emissions – 2012-2020 – Sub-option B (in tons/annum) 

PM

BaseCase
Scenario B1/G6

4.00E+04

3.50E+04

3.00E+04

2.50E+04

a
/
t

2.00E+04

1.50E+04

1.00E+04

5.00E+03

0.00E+00

2012

2014

2016

2018

2019

2020

Source: LAT study, p. 48 

Table 9: Monetary impact of sub-option B in 2020 (million Euros) 

Sum of utility of households 
Sum of production costs 
Sum of cost of public funds (general) 
Total welfare effect w/o pollution benefits (general) 

46.6 
893.0 
90.0 
1,029.7 

  30

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Sum of external cost CO 
Sum of external cost CO2 
Sum of external cost N2O 
Sum of external cost NOx 
Sum of external cost PM 
Sum of external cost SO2 
Sum of external cost VOC 
Pollution benefits 
Sum of welfare (general) 

0.0 
13.7 
0.5 
3,885.9 
136.6 
17.6 
2.8 
4,057.1 
3,027.4 

Source: LAT study, p. 47 

Sub-option C 

Table 10: Total NOx and PM emissions -  
difference between baseline and sub-option C in 2020 

Total NOx  
Total PM 

tons 
142030 
2459 

percent 
23 
17 

Source: LAT study, p. 50 

Figure 5: Total NOx emissions – 2012-2020 – Sub-option C (in tons/annum) 

NOx

BaseCase
Scenario C1/G7

1.20E+06

1.00E+06

8.00E+05

a
/
t

6.00E+05

4.00E+05

2.00E+05

0.00E+00

2012

2014

2016

2018

2019

2020

Source: LAT study, p. 50 

Figure 6: Total PM emissions – 2012-2020 – Sub-option C (in tons/annum) 

PM

BaseCase
Scenario C1/G7

4.00E+04

3.50E+04

3.00E+04

2.50E+04

a
/
t

2.00E+04

1.50E+04

1.00E+04

5.00E+03

0.00E+00

2012

2014

2016

  31

2018

2019

2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Source: LAT study, p. 50 

Table 11: Monetary impact of sub-option C in 2020 (million Euros) 

Sum of utility of households 
Sum of production costs 
Sum of cost of public funds (general) 
Total welfare effect w/o pollution benefits (general) 

Sum of external cost CO 
Sum of external cost CO2 
Sum of external cost N2O 
Sum of external cost NOx 
Sum of external cost PM 
Sum of external cost SO2 
Sum of external cost VOC 
Pollution benefits 
Sum of welfare (general) 

27.4 
480.0 
46.1 
553.5 

0.0 
7.2 
0.2 
2,162.2 
201.7 
9.2 
1.4 
2,381.9 
1,828.4 

Source: LAT study, p. 49 

Sub-option D 

Table 12: Total NOx and PM emissions -  
difference between baseline and sub-option D in 2020 

Total NOx  
Total PM 

tons 
212806 
2459 

percent 
35 
17 

Source: LAT study, p. 52 

Figure 7: Total NOx emissions – 2012-2020 – Sub-option D (in tons/annum) 

NOx

BaseCase
Scenario D1/G8

1.20E+06

1.00E+06

8.00E+05

a
/
t

6.00E+05

4.00E+05

2.00E+05

0.00E+00

2012

2014

2016

2018

2019

2020

Source: LAT study, p. 52 

Figure 8: Total PM emissions – 2012-2020 – Sub-option D (in tons/annum) 

  32

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PM

BaseCase
Scenario D1/G8

4.00E+04

3.50E+04

3.00E+04

2.50E+04

a
/
t

2.00E+04

1.50E+04

1.00E+04

5.00E+03

0.00E+00

2012

2014

2016

2018

2019

2020

Source: LAT study, p. 52 

Table 13: Monetary impact of sub-option D in 2020 (million Euros) 

Sum of utility of households 
Sum of production costs 
Sum of cost of public funds (general) 
Total welfare effect w/o pollution benefits (general) 

Sum of external cost CO 
Sum of external cost CO2 
Sum of external cost N2O 
Sum of external cost NOx 
Sum of external cost PM 
Sum of external cost SO2 
Sum of external cost VOC 
Pollution benefits 
Sum of welfare (general) 

29.0 
525.6 
51.2 
605.9 

0.0 
7.9 
0.3 
3,238.4 
201.9 
10.1 
1.6 
3,460.2 
2,854.3 

Source: LAT study, p. 51 

On the basis of the performed TREMOVE model runs as described in Section 6.2.5.1, a 
summary of the monetary impacts in the year 2020 is provided in Table 14. 

  33

 
 
 
 
 
 
 
 
 
 
 
 
 
Table 14: Monetary impacts of Euro VI emission limit value sub-options in 2020 (in 
million Euros) 

Sub-option A  Sub-option B  Sub-optio C 

Sub-option D 

NOx limit value (g/kWh) 
PM limit value (g/kWh) 

0,4
0,01

0,2
0,02

1,0 
0,015 

0,5
0,015

Total cost  

953,9

1.029,7

553,5 

605,9

Pollution benefit (decrease in 
external costs) 

3.980,6

4.057,1

2.381,9 

3.460,2

Net benefit (general) 

3.026,7

3.027,4

1.828,4 

2.854,3

Source: LAT study (TREMOVE model sub-option runs, pages 16 to 18) 

In the year 2020, sub-option A and B provide the highest value of net benefit. However, 
sub-option  B  appears  to  be  more  costly  than  sub-option  A  and  would  not  result  in 
substantially  higher  pollution  benefits.  Furthermore,  as  explained  above,  sub-option  A 
represents  limit  values  that  correspond  to  the  US  2010  values.  Therefore,  from  the 
perspective of global harmonisation and the cost-benefit analysis, sub-option A should be 
preferred. 

6.2.5.2.  Evaluation of sub-options with TREMOVE 2.52 

The  sum  of  the  PM  and  NOx  pollution  abated  and  the  monetary  impact  for  each  sub-
option are the following: 

Sub-option A 

Table 15: Total NOx and PM emissions -  
difference between baseline and sub-option A in 2030 

Total NOx 
Total PM 

tons 
964437 
8341 

percent 
69 
55 
Source: TREMOVE 2.52 

Figure 9: Total NOx emissions – 2012-2030 – Sub-option A (in tons/annum) 

  34

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
2.50E+06

NOx

Basecase
G5

2.00E+06

1.50E+06

a
/
t

1.00E+06

5.00E+05

0.00E+00

2010

2015

2020

Year

2025

2030

Source: TREMOVE 2.52 

Figure 10: Total PM emissions – 2012-2030 – Sub-option A (in tons/annum) 

PM

Basecase
G5

a
/
t

4.50E+04

4.00E+04

3.50E+04

3.00E+04

2.50E+04

2.00E+04

1.50E+04

1.00E+04

5.00E+03

0.00E+00

2010

2015

2020

Year

2025

2030

Source: TREMOVE 2.52 

Sub-option B 

Total NOx  
Total PM  

Table 16: Total NOx and PM emissions -  
difference between baseline and sub-option B in 2030 

percent 
78 
27 
Source: TREMOVE 2.52 

tons 
1084084 
4145 

  35

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 11: Total NOx emissions – 2012-2030 – Sub-option B (in tons/annum) 

Basecase
G6

2.50E+06

NOx

2.00E+06

1.50E+06

a
/
t

1.00E+06

5.00E+05

0.00E+00

2010

2015

2020

Year

2025

2030

Source: TREMOVE 2.52 

Figure 12: Total PM emissions – 2012-2030 – Sub-option B (in tons/annum) 

PM

Basecase
G6

a
/
t

4.50E+04

4.00E+04

3.50E+04

3.00E+04

2.50E+04

2.00E+04

1.50E+04

1.00E+04

5.00E+03

0.00E+00

2010

2015

2020

Year

2025

2030

Source: TREMOVE 2.52 

Sub-option C 

Total NOx  
Total PM 

Table 17: Total NOx and PM emissions -  
difference between baseline and sub-option C in 2030 

tons 
604031 
6228 

  36

percent 
43 
41 

Source: TREMOVE 2.52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 13: Total NOx emissions – 2012-2030 – Sub-option C (in tons/annum) 

2.50E+06

NOx

Basecase
G3

2.00E+06

1.50E+06

a
/
t

1.00E+06

5.00E+05

0.00E+00

2010

2015

2020

Year

2025

2030

Source: TREMOVE 2.52 

Figure 14: Total PM emissions – 2012-2030 – Sub-option C (in tons/annum) 

PM

Basecase
G3

a
/
t

4.50E+04

4.00E+04

3.50E+04

3.00E+04

2.50E+04

2.00E+04

1.50E+04

1.00E+04

5.00E+03

0.00E+00

2010

2015

2020

Year

2025

2030

Source: TREMOVE 2.52 

Sub-option D 

Total NOx  
Total PM 

Table 18: Total NOx and PM emissions -  
difference between baseline and sub-option D in 2030 

tons 
903984 
6230 

  37

percent 
65 
41 

Source: TREMOVE 2.52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 15: Total NOx emissions – 2012-2030 – Sub-option D (in tons/annum) 

2.50E+06

NOx

Basecase
G8

2.00E+06

1.50E+06

a
/
t

1.00E+06

5.00E+05

0.00E+00

2010

2015

2020

Year

2025

2030

Source: TREMOVE 2.52 

Figure 16: Total PM emissions – 2012-2030 – Sub-option D (in tons/annum) 

PM

Basecase
G8

a

/
t

4.50E+04

4.00E+04

3.50E+04

3.00E+04

2.50E+04

2.00E+04

1.50E+04

1.00E+04

5.00E+03

0.00E+00

2010

2015

2020

Year

2025

2030

Source: TREMOVE 2.52 

Table 19: Monetary impacts of Euro VI emission limit value sub-options in 2030 (in 
million Euros) 

  38

 
 
 
 
 
 
 
 
 
Sub-option A  Sub-option B  Sub-option C  Sub-option D 

NOx limit value (g/kWh) 
PM limit value (g/kWh) 

0,4
0,01

0,2
0,02

1,0 
0,015 

0,5
0,015

Total cost  

2.615,6

2.823,6

1.511,6 

1.654,4

Pollution benefit (decrease in 
external costs) 

5.689,7

6.221,9

3.587,4 

5.250,3

Net benefit (general) 

3.074,1

3.398,4

2.075,9 

3.595,8

Source: LAT study No. 2, p. 24 

It  can  be  observed  that  in  the  year  2030,  the  net  benefit  of  sub-option  A  is  somewhat 
lower than the corresponding value for sub-option D or B. However, the pollution benefit 
of  sub-option  A  is  substantially  higher  than  the  corresponding  value  of  sub-option  D. 
With regard to sub-option B, it needs to be taken into account that it has the highest cost 
of  all  sub-options.  In  addition,  its  relatively  high  benefits  come  at  the  cost  of  a  CO2 
penalty of 5 to 6% (see section 6.2.4. above).The cost of the CO2 penalty has not been 
monetised but it is clear that it considerably reduces the environmental benefit of option 
B.  

On  the  basis  of  the    above  considerations  and  taking  into  account  the  aspect  of  global 
harmonisation, sub-option A is seen as the most appropriate for the introduction of 
the Euro VI stage of limit values. 

Furthermore,  the  LAT  study  has  concluded  that  the  costs  associated  with  the  different 
technologies  required  for  meeting  the  different  sets  of  emission  limit  values  do  not 
influence  the  transport  demand,  i.e.  the  application  of  even  the  most  stringent  set  of 
limits would have no impact on road transport demand.37 

6.3.  Impact of other measures 

In addition to the options for reducing emission limits there are a number of additional 
aspects that have been considered as part of the proposal. These measures contribute to 
the policy objectives of the proposal, i.e. ensuring the proper functioning of the internal 
market while providing for a high level of environmental protection. 

The TREMOVE model is not designed to evaluate the impacts of measures, such as the 
extension  of  durability  requirements  and  the  introduction  of  requirements  relating  to 
'access  to  vehicle  repair  information'.  Therefore,  the  analysis  has  to  be  restricted  to  a 
qualitative evaluation. 

37   LAT study, p. 24 

  39

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
                                                 
These  measures  are  essential  to  achieve  better  control  of  emissions  from  heavy-duty 
vehicles and to ensure that the limit values are respected during their whole useful life. 
They  will  also  contribute  to  improve  the  functioning  of  the  internal  market.  This  is 
shown by the fact that the majority of these measures have already been introduced with 
the latest stage of light-duty vehicle emission standards (Euro 5 and 6).  

No re-distributional and employment impacts are foreseen due to the introduction of the 
measures mentioned below. 

6.3.1. Particulate emission limits for gas (positive ignition) engines 

The  proposal  includes  the  introduction  of  a  particulate  matter  emission  limit  for  gas 
engines. Particulates from gas engines are currently unregulated in the EU, although for 
the  consideration  of  environmentally  enhanced  friendly  vehicles  (EEV)  a  PM  limit  of 
0.02 g/kWh has been introduced. It is considered that the PM emissions from gas fuelled 
engines should be regulated. 

In any case, the influence of the PM emitted by those engines, with respect to the total 
amount  of  PM  coming  from  heavy  duty  vehicles,  will  be  quite  small  since  as  stated 
above, gas engines in heavy duty vehicles represent less than 0.2% of the total number of 
those vehicles.38 

However, results from the stakeholder consultation have suggested that the strictest limit 
values described in the above mentioned sub-options could be achieved without the use 
of any after-treatment technology.39 Therefore, the introduction of such a limit value will 
not imply additional costs for manufacturers.  

6.3.2. Regulating the number of particulates emitted  

The  proposal  indicates  that  as  soon  as  the  results  of  the  UN/ECE  Particulate 
Measurement Programme for heavy-duty vehicles are going to be available, a particulate 
number  standard  will  be  introduced.  The  standards  would  be  set  so  that  they  broadly 
correlate with the mass standards of the current proposal.  

The existing regulation focuses on the total mass of particulate that is emitted. However 
there  is  serious  concern  about  the  health  effects  of  ultra  fine  particulates  (of  very  low 
mass). The main issues with ultra fine particles are summarised in Box 2. 

Box 2: The importance of controlling emissions of ultra fine particles 

Discussion  on  particulate  pollution  frequently  focuses  on  impacts  from  two  different  size 
thresholds, these are all particles below 10µm (PM 10) and a subset of those which are smaller 
than 2.5µm (PM 2.5). Most diesel exhaust particles are considerably smaller than 2.5µm and thus 
contribute  to  both  statistics.  In  addition,  concerns  have  been  raised  about  the  health  impact  of 
ultra fine particles (commonly defined as those below 0.1µm). For example: 

38   LAT study, p. 7 

39   TNO Report, p. 34-35 

  40

 
 
 
                                                 
-  Wichmann  (2003)  reports  that  the  limited  numbers of available studies suggest that ultra fine 
particles do have health impacts beyond those of fine particles.  

 - The study on Health Effects of Air Pollution on Susceptible Subpopulations (HEAPSS) study 
reported  that  particle  number  concentration  and  CO,  both  originating  from  traffic  and  other 
combustion  processes,  were  the  pollutants  most  strongly  associated  with  all  the  health  effects 
considered (HEAPSS 2004). 

In  addition  to  effects  on  the  function  of  the  lungs  and  blood  circulation,  more  recent  evidence 
also  points  to  a  penetration  of  ultra  fine particles into nerve tissue including the brain (see e.g. 
Oberdörster et al. 2005). 

The  Scientific  Committee  on  Health  and  Environmental  Risks  (SCHER)  of  DG  Health  and 
Consumer  Protection  of  the  European  Commission  has  stated  in  its  opinion40  that  there  is 
increasing  epidemiological  evidence  that  PM  2.5  may  be  related  to  adverse  health  effects 
especially in susceptible populations and vulnerable groups. An unambiguous threshold for PM 
2.5  dose  has  not  yet  been  established  and  it  appears  to  depend  on  the  health  effect  endpoint, 
populations and vulnerability. 

The  scientific  evidence  suggests  that  limiting  emissions  of  ultra  fine  particles  is 
especially important to health. 

The much reduced particulate emission limits which the Euro VI proposal is considering 
will  most  likely  be  met  by  the  use  of  diesel  particulate  filters.  Current  technological 
solutions use wall flow (or ‘closed’) filters which are effective at reducing emissions of 
all  types  of  particles  including  the  ultra-fine.  Other  filter  technology  also  exists  that 
operates on ‘open’ principles. These filters are effective at removing most of the mass of 
particulates  from  the  exhaust  stream,  but  may  not  result  in  significant  reduction  in  the 
ultra-fine particulates. As development of filters continues it is possible that greater use 
will  be  made  of  open  filters  to  reduce  the  mass  of  particulates.  This  would  lead  to  a 
situation where high emission levels of ultra-fine particles continue to be created.  

The use of a particle number standard is a means to ensure that emissions of ultra fine 
particles are controlled and that developments in filter technology continue to focus on 
the  removal  of  ultra  fine  particles.  Present  test  procedures  set  down  in  European 
legislation  do  not  include  a  method  for  measuring  particle  number.  Therefore  a  new 
procedure  would  be  required  to  be  adopted  if  such  an  emission  standard  were  to  be 
introduced.  Work  on  developing  and  testing  a  new  measurement  protocol  for  both 
particulate mass and number is taking place at the United Nations Economic Commission 
for Europe (UN-ECE) under the World Forum for Harmonisation of Vehicle Regulations 
(WP  29)  in  Geneva.  This  work  is  at  a  very  advanced  stage  for  light-duty  vehicles  and 
particulate number standards will be introduced with the implementing measures of the 
Euro 5 and 6 Regulation41. The programme for heavy-duty vehicles has just been started. 
Once  this  work  is  complete,  the  new  standard  shall  be  implemented  into  European 
legislation.  

40   Scientific Committee on Health and Environmental Risks (SCHER): Opinion on “New evidence of air 

pollution effects on human health and the environment”, 18 March 2005, 
http://europa.eu.int/comm/health/ph_risk/committees/04_scher/docs/scher_o_009.pdf 

41   Regulation (EC) No 715/2007 of the European Parliament and of the Council of 20 June 2007 on type 
approval  of  motor  vehicles  with  respect  to  emissions  from  light  passenger  and  commercial  vehicles 
(Euro 5 and Euro 6) and on access to vehicle repair and maintenance information, OJ L171, 29 June 
2007 

  41

                                                 
Introducing  a  new  test  procedure  introduces  costs  to  industry  and  testing  facilities  in 
adapting  their  practices.  However,  given  that  the  procedure  will  have  already  been 
implemented for light-duty vehicles and as a number of laboratories are involved in the 
work piloting the procedures, some of the costs have already been incurred.  

 Furthermore, the development of a more accurate variation of the current test procedure 
for measuring particulate mass is considered in order to provide repeatable results at low 
emission  limits.  Therefore  there  are  good  reasons  for  introduction  of  most  of  the 
measurement  methodology  to  improve  the  accuracy  of  particulate  mass  measurement, 
irrespective of whether the number measurement component is used. 

Consequently,  measuring  the  number  of  particulates  instead  of  their  mass  could  be 
considered as a more effective means of regulation in the future.  

6.3.3. Durability requirements 

For the time being, existing legislation requires manufacturers to confirm the durability 
of  pollution  control  devices  in  heavy  duty  vehicles  depending  on  the  category  they 
belong  to.  The  new  proposal  includes  the  extension  of  this  durability  period  from 
100,000  km  to  160,000  km  for  vehicles  of  category  M1,  N2  and  M2,  in  line  with  the 
requirements  of  the  Regulation  on  light  duty  vehicles  (Euro  5&6).  The  period  would 
more realistically reflect the actual life of vehicles of the above mentioned categories and 
ensure  that  emission  control  systems  continue  to  function  throughout  the  life  of  the 
vehicle. 

The current durability requirements for other vehicle categories would be reviewed when 
adopting  the  implementing  measures  of  the  regulation.  Extending  the  durability 
requirements  would  therefore  be  in  line  with  the  principle  of  ensuring  that  a  vehicle 
continues to produce low emissions for its entire lifetime.  

At  present,  there  are  two  ways  in  which  manufacturers  demonstrate  the  durability 
requirement: 

•  Manufacturers  can  test  for  durability  using  either  operation  on  track,  road,  or  on  a 

chassis dynamometer using a defined test protocol; or  

•  A  manufacturer  may  choose  to  apply  standardised  deterioration  factors  to  the 
measured emissions limit. The factors vary for CI and PI angines and for the different 
pollutants. They reflect the general changes in performance that can be expected over 
time of standard emission control technologies.  

The vast majority of manufacturers make use of the second approach as this avoids the 
need  for  extensive  testing.  Thus,  changing  the  durability  requirements  will  not  impose 
any  significant  testing  costs  on  manufacturers  as  they  would  apply  an  amended  set  of 
deterioration factors. It does not appear that this requirement as such imposes significant 
costs  on  manufacturers,  as  aftertreatment  devices  are  designed  to  function  for  such 
distances without the need for replacement.  

6.3.4. Access to vehicle repair information 

The  proposal  requires  the  provision  of  vehicle  repair  information  through  websites  in 
accordance  with  the  specifications  developed through the OASIS Technical Committee 
which  the  Commission  chaired,  in  order  to  ensure  access  to  this  information  for  all 

  42

service  and  repair  operators,  whether  independent  or  within  the  supplier’s  distribution 
system. 

The obligation to provide this information already existed; the provisions in this proposal 
constitute  the  details  necessary  for  that  obligation  to  be  implemented  in  practice.    The 
Block  Exemption  Regulation  imposed  as  a  general  requirement  that  motor  vehicle 
suppliers provide all operators, whether independent or within the supplier’s distribution 
system,  access  to  the  necessary  information  for  repair  and  service  of  vehicles,  but 
without  further  details  of  the  method  through  which  this  obligation  would  be 
implemented.  Directive  2005/55/EC  regarding  Euro  IV  and  V,  as  amended,  noted  the 
need for unrestricted and standardised access to repair information, in particular related 
to on-board diagnostic systems and the diagnosing, service and repair of vehicles.   

A standardised format for making such information available through websites has been 
developed by a technical committee of stakeholders under the framework of the OASIS 
consortium. Other attempts at developing international standards in this area have been 
unsuccessful.  Access  to  this  information,  which  forms  a  vital  part  of  testing  and 
monitoring  emissions  performance,  has  proved  highly  variable  across  the  internal 
market.42  Indeed, it is likely that access to this information will only prove more difficult 
and more variable due to the increasing complexity of electronic systems incorporated in 
vehicles,  which  creates  the  knock-on  effects  of  requiring  more  specialised  tools  and 
further specialised knowledge in order to perform repairs and maintenance which might 
previously have been non-existent or routine.  

The principle of non-discriminatory access to this information for both authorised dealers 
and  those  outside  the  supplier’s  distribution  chain  was  already  established  in  the 
legislation mentioned above, so no additional burden on manufacturers is being created.  
The provisions in this proposal do not require manufacturers to create new webpages nor 
do they require the creation of repair information in a new format for existing vehicles 
(i.e., there is no retrospective obligation).  The effect of the proposed measures is only to 
require  manufacturers  to  provide  the  information  on  their  web  pages    Similar 
requirements to those proposed here have already been in operation in the United States, 
where fees appear to be reasonable and vary with the length of time for which access is 
required.      The  impact  of  this  measure  on  manufacturers  is  likely  to  be  cost-neutral  as 
they  will  be  able  to  charge  reasonable  and  proportionate  fees  for  access  to  the 
information. 

The  benefits  of  the  proposal  are  manifest.    The  proper  flow  of  this  information  should 
create  beneficial  competition  in  the  sector  which  will  give  consumers  greater  and  freer 
choice  of  when  and  where  to  repair  their  vehicles.    Access  to  this  information  in  a 
reasonable  and  non-discriminatory  manner  is  not  only  useful  for  routine  maintenance, 
but can be crucial for motorists in more isolated or remote areas where there may be no 
choice  of  repairer,  or  when  travelling  from  an  area  where  one  mark  of  vehicle  may  be 
common to an area where that is not the case.   

Access on reasonable terms to this information for small and medium-sized enterprises in 
the  sector  is  vital  as  they  cannot  afford  the  myriad  specialised  tools  and  dedicated 

42  See  study  COMP/F-2/2003/26/S12.371920  performed  by  the  Institut  für  Kraftfahrwesen  Aachen, 
October  2004,  which  examined  access  to  repair  information  for  nine  major  car  manufacturers  and 
seven major truck manufacturers across eight Member States. 

  43

                                                 
information services available to a distributor.  Roadside assistance organisations, which 
need access to repair information in order to perform even simple tasks such as helping 
motorists  with  battery  replacement,  will  benefit  and  in  turn  will  be  able  to  provide  the 
service expected of them by motorists in difficulties.  Expected benefits of the proposal 
will therefore exceed any incurred costs for manufacturers to make any changes required 
and they will be able to recoup those costs through charges for the information. 

In the public consultation, the Association of independent repairers (AFCAR) requested 
that similar aftermarket provisions to those ones currently included in the Euro 5 and 6 
Regulation be included in the new Euro VI Regulation. 

6.3.5. Monitoring of carbon dioxide (CO2) emissions  

The Commission is considering the introduction of a standardised method of measuring 
fuel  consumption  and  carbon  dioxide  emissions  of  heavy  duty  vehicles  in  order  to 
monitor  the  contribution  of  this  sector  to  the  global  emissions  of  greenhouse  gases 
(GHG). 

Carbon dioxide is not considered as a pollutant but its effect in the global warming of the 
earth makes it necessary to control it. 

The  introduction  of  this  measurement  will  not  impose  any  cost  in  the  type  approval 
process  since  the  necessary  equipment  for  the  evaluation  and  calculation  of  CO2 
emissions are already present in the testing facilities. 

6.3.6. Introduction of global harmonised requirements 

Regulations  governing  the  exhaust-emissions  from  heavy  duty  vehicles  have  been  in 
existence for many years but the methods of measurement vary in the different regions of 
the world.  To ensure the maximum benefit to the environment as well as economies of 
scale regarding engine design, it is desirable that as many countries as possible use the 
same high standards of emission control.  

As  manufacturers  of  heavy-duty  vehicles  are  already  operating  in  a  world  market,  it  is 
economically  inefficient  for  them  to  have  to  prepare  different  models  in  order  to  meet 
different  emission  regulations  which  are,  in  principle,  aimed  at  achieving  the  same 
objective.  In order to enable manufacturers to develop new models in the most effective 
way,  the  Commission  intends  to  include  in  the  Euro  VI  proposal  the  technical 
requirements  developed  in  the  framework  of  the  World  Forum  for  Harmonisation  of 
Vehicle Regulations (WP.29) of the United Nations Economic Commission for Europe.   

Those  requirements  are  based  on  research  into  the  world-wide  pattern  of  real  heavy 
commercial  vehicle  use.    From  the  collected  data,  two  representative  test  cycles,  one 
transient test cycle (WHTC) and one steady state test cycle (WHSC), have been created 
covering typical driving conditions in the European Union, the United States of America 
and  Japan.    Based  on  real  life  data  a  model  was  developed  for  translating  the  vehicle 
cycle into an engine cycle.  The general laboratory conditions for the emission test and 
the engine family concept have been brought up to date by expert committees in ISO and 
reflect the latest technologies.  

  44

 
The  WHTC  and  WHSC  test  procedures  reflect  world-wide  on-road  heavy-duty  engine 
operation  and  provide  a  marked  improvement  in  the  test  procedure  for  measuring  the 
emission performance of existing and future heavy-duty engines. 

Global  harmonised  provisions  will  also  imply  the  introduction  of  requirements  on  on-
board diagnostic (OBD) systems and on the verification of off-cycle emissions (OCE) 

Since  the  above  mentioned  methodology  will  replace  the  currently  existing  one,  it  will 
not add any cost to vehicle manufacturers but for those manufacturers that are active in 
the global market, these measures will bring substantial benefits. 

6.3.7.  New methodology for in-service conformity. 

Current legislation includes provisions regarding the conformity of vehicles and engines 
with the emission limits during the useful life of the engine installed in a vehicle under 
normal  conditions  when  properly  maintained  and  used.  To  verify  that,  the  vehicle 
manufacturer has to provide to the type approval authority data on the performance of a 
range  of  representative  vehicles  or  engines  of  which  the  manufacturer  holds  the  type 
approval. 

Considering that obtaining test data from the engine test bench, as required in the current 
legislation, is quite costly and time consuming (i.e. it requires the removal of the engine 
from  the  vehicle),  the  Commission  is  developing  a  new  procedure,  in  cooperation  with 
engine and measuring equipment manufacturers, type approval authorities and accredited 
technical  services,  to  introduce  in-service  conformity  provisions  based  on  the  use  of 
portable emission measuring systems (PEMS).  

When  implemented,  this  procedure  will  reduce  the  burden  of  emission  legislation  for 
manufacturers. 

6.4.  Preferred Option 

The preferred policy option is the ‘Regulatory approach’, which means further regulation 
of  vehicle  emission  limits.  This  is  seen  as  an  essential  means  of  sustaining  a  single 
market for vehicles and providing for better air quality in Europe, while safeguarding the 
affordability of vehicles at the same time. Taking into account the need for striking the 
balance between higher environmental standards and the continued affordability of heavy 
duty  vehicles  for  the  operators,  the  following  emission  limit  values  are  proposed  for 
compression-ignition and positive-ignition engines, which result in a significant overall 
reduction of pollutants. 

6.4.1. Emission limits for compression-ignition and positive-ignition engines 

A- 0.01 g/kWh for PM. It implies: 

- Significant reduction 66% in particulate matter emitted 

-  It  would  imply  the  introduction  of  particulate  filters  for  compression-
ignition engines 

- No additional filter for positive-ignition engines 

  45

  
 
 
 
 
- It is in line with the US standard and future global harmonisation. 

B- 0.4 g/kWh for NOX. It implies: 

- Significant reduction 80% in the emission of NOx 

- Contribution to the objectives of the National Emissions Ceiling (NEC) 
Directive   

- Reasonable balance between NOx and CO2 emissions 

- It is in line with the US standard and future global harmonisation. 

These values, that correspond to sub-option A, have been chosen as the most appropriate 
set of emission limit values, since they provide a high amount of environmental benefit at 
a reasonable cost. Further, their impacts on fuel consumption and thus, CO2 emission are 
estimated to be negligible. 

As  explained  in  the  previous  sections,  sub-option  A  provides  an  environmental  benefit 
close to that of sub-option B and this at a lower cost. Sub-option B is the most costly and 
would  result  in  a  fuel  consumption  and  CO2  emission  increase  of  5-6%.  This  penalty 
could  not  be  included  in  the  monetised  impacts.  If  it  had  been,  it  would  decrease  the 
benefits of scenario B considerably. At the same time, sub-option A would not result in a 
significant  increase  of  CO2  emissions,  a  fact  that  has  been  confirmed  by  the  public 
consultation responses. 

Furthermore, sub-option B would introduce a limit value for particulate matter which is 
double  the  value  for  sub-option  A  and  the  highest  amongst  all  sub-options.  The  health 
concerns  relating  to  particulate  matter  are  significant  and  can  be  linked  to  reduced  life 
expectancy.  This  higher  PM  limit  value  for  sub-option  B  is  not  likely  to  ensure  that 
diesel  particulate  filters  (DPFs)  are  fitted  on  all  heavy-duty  vehicles.  To  current 
technology, DPFs need to be fitted to ensure effective removal of particulates from the 
exhaust. 

In addition, the aspect of global harmonisation can not be included in the calculations of 
TREMOVE,  but  it  is  very  important  to  be  considered.  As  previously  explained,  sub-
option A corresponds to the US 2010 values. With the introduction of a Euro VI standard 
that is equivalent to that in the US, engine and vehicle manufacturers would benefit from 
economies  of  scale  linked  to  higher  production  volumes.  Furthermore,  considering  that 
the daily cost for the use of an engine test bench is in the order of 2 500 € it can be seen 
that the benefit of global harmonisation for the industry is really important. This also has 
been confirmed by the public consultation. 

6.4.2. Additional requirements 

The additional aspects of the proposal ensure that the overall emission of road transport 
is reduced. For instance, the extension of the durability requirements provides for a stable 
environmental  performance  of  the  vehicles  throughout  a  much  longer  period  of  their 

  46

 
 
 
 
 
 
 
 
actual life without imposing a significant cost on manufacturers. With the use of PEMS,  
manufacturers  and  type  approval  authorities  will  have  a  useful  tool  to  ensure  that  the 
vehicles do not exceed the specified limit values during their lifespan. Furthermore, the 
introduction  of  a  particulate  number  standard  will  reduce  the  risk  that  open  filters  are 
specified in the future as engine and filter technology develops. With global harmonised 
requirements  the  general  objectives  of  air  quality  will  be  fulfilled  at  a  lower  cost  for 
manufacturers. 

6.5.  Indicators of progress towards meeting the objectives 

The  key  mechanism  by  which  the  proposed  Regulation  will  take  effect  is  through  the 
vehicle  type-approval  process.  Vehicle  manufacturers  will  need  to  demonstrate  that 
vehicles comply with – amongst other things – the emission limit requirements in order 
to  receive  a  type-approval  certificate.  The  core  indicators  of  progress  will  therefore  be 
the  number  of  vehicles  which  are  successfully type-approved according to the  Euro  VI 
standard. 

6.6. 

 Monitoring and evaluation 

Monitoring  of  the  effect  of  the  Regulation  is  effectively  undertaken  by  type  approval 
authorities  who  oversee  in-service  conformity  processes  to  ensure  that  requirements  of 
the  Regulation  are  met.  More  generally,  monitoring  data  on  air  pollution  levels  and 
epidemiology on health impacts will point to the wider success of the policy. 

  47

Annex 1: Issues raised during the public consultation  

At  the  date  of  closing  the  public  (internet)  consultation,  a  total  of  55  replies  were 
received to the request for comments. Of these the breakdown by source is as follows: 

•  Governmental organisations………………………………. 9 replies 

•  Regional and Local official Organisations………………….4 replies 

•  Industry and business organisations……………………..   24 replies 

•  NGOs, consumer and professional groups………………. 13 replies 

•  Individuals………………………………….…………….   5 replies 

During  the  consultation,  a  number  of  issues  were  raised  by  stakeholders.  This  section 
summarises  the  substantive  issues  raised  and  discusses  how  they  have  been  taken  into 
consideration. 

Almost  all  replies  welcome  the  introduction  of  stringent  limit  values  for  the  pollutant 
emissions from heavy duty vehicles. Very few replies state that the current limit values 
are still valid for the future and that energy efficiency, in terms of fuel consumption and 
CO2 emission reduction should be the main priority. 

The vast majority of stakeholders support a single step with limit values close to those in 
US2010 (sub-options A or D).  

Just  eight  replies,  and  within  them  only  two  industrial  organisations (AGU-CEFIC and 
CLEPA) are supporting the two step approach. Those organisations are in favour of the 
less stringent sub-options (sub-option C for Euro VI and sub-option D for Euro VII). 

In  general  terms  transport  operators  and  some  national  administrations  (IT  and  SW) 
support a fuel neutral sub-option (i.e. sub-option D; NOx=0.5 g/kWh). 

The motor industry (ACEA) and some other national administrations (among which CH, 
DE, FR and NL) and non governmental organisations support the introduction of a more 
stringent  set  of  limit  values  (i.e.  sub-option  A;  NOx=0.4  g/kWh).  Additional 
requirements  on  on-board  diagnostic  (OBD),  off-cycle  emissions  (OCE)  and  in  service 
conformity are also requested. In some replies it is stated that the foreseen fuel penalty 
associated to this sub-option would be reduced by technical improvements by the date of 
entry into force of the Regulation. 

A  vast  majority  of  replies  (including  ACEA)  express  support  for  the  global 
harmonisation  of  testing  procedures  and  driving  cycles  (i.e.  introduction  of  WHDC  – 
world-wide  harmonised  driving  cycle)  as  a  means  of  reaching  future  global  standards 
while reducing the testing cost for the vehicle manufacturers. 

In some replies, including national Administrations such as NL, DK and CH, the Greater 
London Authority and other non-governmental organisations, the introduction of a limit 
value for particle number is requested.  

 
 
 
 
Monitoring of CO2 is supported in some replies. 

Other issues can be summarised as follows: 

- An independent research centre is proposing a change in the testing methodology 
and  the  use  of  different  driving  cycles  according  to  the  vehicle  application  but  it 
should  be  reminded  that  the  current  test  procedure  (test  of  the  engine  by  using  an 
engine test bench) is the standard one accepted in US, Europe and Japan.   

- In one reply the sender asks about the reason to allow higher NOx emissions, in 
some  sub-options,  to  gas  (PI)  vehicles.  On  this  issue,  it  should  be  noted  that  the 
possibility of considering one sub-option for CI engines and another for PI engines 
was open, as expressed in another reply in which sub-option D is supported for CI 
engines together with sub-option A for PI engines. 

Taking the above comments into account, it seems reasonable to propose the following: 

- Introduction of the limit values included in sub-option A, based on the currently 
applicable  ETC  (European  Transient  Cycle)  in  a  single  stage  for  both 
compression-ignition (CI) and positive ignition (PI) engines. It is to be noted that, 
in line with the current applicable legislation for natural gas fuelled engines, the 
limit value for hydrocarbons will be split in non-methane hydrocarbons (NMHC) 
and methane (CH4) with values of 0.16 g/kWh and 0.50 g/kWh respectively. This 
cap for CH4 was already considered in the questionnaire sent by the Commission 
and does not introduce any additional burden to natural gas fuelled vehicles since 
emissions from such vehicles are currently far below that cap.    

- Introduction in a further step, through comitology, of equivalent limit values to 
those  mentioned  in  the  paragraph  above  but  referred  to  WHDC  as  described  in 
UNECE Regulation 49. 

-  Introduction  of  provisions  regarding  on-board  diagnostic  (OBD)  and  off-cycle 
emissions (OCE) as developed in the framework of UNECE WP29 (World Forum 
for the Harmonisation of Motor Vehicle Regulations). 

- Introduction of provisions regarding durability of after-treatment systems. 

-  Introduction  of  requirements  on  in-service  conformity  of  vehicles  during  their 
useful  life  with  the  application  of  portable  emissions  measurement  systems 
(PEMS). 

-  Consideration  of  technologically  neutral  standards  in  relation  to  compression-
ignition  and  positive-ignition  engines  except  for  the  limitation  of  un-burnt 
hydrocarbons (HC) as in sub-option A. 

-  Introduction,  through  comitology,  of  the  limitation  of  particle  number  taking 
into account the result of the  particle measurement programme (PMP) developed 
under the auspices of the UNECE  

- Monitoring of CO2 emissions in order to obtain data about the contribution of 
heavy duty vehicles to the Green House Effect.  

- Timing: 

  49

 
 
- 1 October 2013 for the approval of new vehicle and engine types 

- 1 October 2014 for the registration of new vehicles 

- Regarding simplification, the new Regulation will repeal four EC directives. 

… 

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