Commission staff working document - Accompanying the Proposal for a Regulation of the European Parliament and of the Council concerning type-approval requirements for the general safety of motor vehicles - Summary of the impact assessment {COM(2008) 316} {SEC(2008) 1908}
Date: 2008-05-23
Institutions: European Commission
Subjects: approval, approximation of laws, impact study, motor vehicle, safety standard, technical standard

EN 

EN 

   EN 

 
 
COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 23/5/2008 
SEC(2008) 1909 

COMMISSION STAFF WORKING DOCUMENT 

Accompanying the 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

concerning type-approval requirements for the general safety of motor vehicles 

Summary of the Impact Assessment 

{COM(2008) 316} 
{SEC(2008) 1908} 

EN 

   EN 

 
 
 
 
 
 
 
 
COMMISSION STAFF WORKING DOCUMENT 

Accompanying the 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

concerning type-approval requirements for the general safety of motor vehicles 

EXECUTIVE SUMMARY 

In  order  to  meet  the  European  Union's  safety  and  environmental  objectives,  there  is  a 
continual  need  to  update  the  various  regulations  that  apply  to  new  vehicle  construction. 
However,  there  is  an  equal  need  to  limit  the  regulatory  burden  on  industry,  and  to  simplify 
existing  legislation  wherever  possible.  New  technologies  are  now  available  which  can 
dramatically  improve  vehicle  safety  (such  as  vehicle  stability  control)  or  reduce  CO2 
emissions (such as low rolling-resistance tyres) and research has indicated that there would be 
significant  benefits  if  such  technologies  were  introduced  as  standard  on  new  cars,  and 
possibly other vehicles as well.  

However, before considering amending or expanding the current type-approval Directives to 
mandate,  or  at  least  set  standards  for,  these  new  technologies,  it  is  necessary  to  review  the 
current  system  of  safety-related  type-approval  Directives.  In  2005  the  CARS  21  report 
recommended  the  simplification  of  the  current  regime,  replacing  many  of  the  current 
Directives  with  equivalent  regulations  developed  by  the  United  Nations  Economic 
Commission for Europe (UNECE). Further simplification could be achieved by replacing the 
current  50  base  Directives  (and  100  related  amending  Directives)  with  one  Council  and 
Parliament Regulation. An advantage of such an approach would be that such a Regulation, 
and its subsequent amendments, would not need to be transposed by Member States. 

The  proposal  which  is  the  subject  of  this  impact  assessment  will  be  to  simplify  the  current 
systems for vehicle safety but also introduce new requirements, where technically feasible and 
economically  justifiable,  to  improve  the  safety  and  environmental  performance  of  new 
vehicles. 

This  Impact  Assessment  analyses  possible  changes  to  the  current  safety  requirements  under 
three themes; Simplification, Advanced Safety Systems and Tyres. 

With regard to simplification, the following options were considered: 

(a) 

(b) 

Do nothing (maintain all existing safety –related Directives). 

Do  nothing  as  part  of  the  current  exercise,  but  review  each  Directive  as  and 
when  they  are  due  to  be  modified,  and  decide  whether  replacement  is 
appropriate. 

EN 

2 

   EN 

 
 
 
 
 
 
(c) 

Replace all existing Directives through the proposed Regulation. 

Option (c) was considered most viable since it represents the quickest way of simplifying the 
current regime and is in line with the CARS 21 recommendations.  

With regard to advanced safety systems, three types of systems were considered; electronic 
stability control, advanced emergency braking and lane departure warning. For each of 
these systems, the following options were examined: 

Option a) Do nothing and allow the market to take the initiative. 

Option  b)  Establish  technical  standards  for  such  systems  (where  fitted)  and  allow 
manufacturers to fit them optionally. 

Option c) Establish technical standards and mandatory fitting requirements. 

In  all  cases,  the  analysis  concluded  that  relying  on  market  forces  alone  was  unlikely  to 
achieve full fleet penetration, and that there was justification for mandatory action. However, 
in  the  cases  of  advanced  emergency  braking  and  lane  departure  warning  systems,  the 
emphasis should be on mandatory installation on heavy duty vehicles as a first stage. 

Regarding  tyres,  there  are  four  areas,  some  of  them  inter-related,  where  action  has  been 
proposed.  These  concern  tyre/road  noise,  rolling  resistance,  tyre  pressure  monitoring 
systems and tyre wet grip performance.  

With regard to tyre noise the following options were considered: 

Option a) Follow the recommendations of a report by the Federation of European Highway 
Research  Laboratories  (FEHRL)  and  propose  tyre  noise  limit  reductions  of  around  4dB(A), 
with the actual values depending on which of five width categories the tyre falls into. 

Option b) Similar to Option a) but allowing a longer two-phase introduction. 

Option  c)  Follow  the  recommendations  of  a  report  by  TRL  which  proposes  similar  noise 
reductions  to  FEHRL  but  effectively  reduces  the  number  of  width  categories  to  two.  This 
makes compliance with the requirements proportionately more difficult for wider tyres.  

As the FEHRL report has indicated that a large proportion of existing tyres can already meet 
the  proposed  requirements  of  option  a)  there  appears  to  be  no  justification  in  delaying  the 
implementation (as proposed in option b)). There may be some feasibility concerns over the 
ability of some tyres to meet the option c) requirements, so option a) with minor adjustments 
following consultations with stakeholders, is the preferred option. 

With regard to tyre rolling resistance, the following options were considered: 

Option a) 
Rely on a grading and labelling scheme to encourage the increased use of low 
rolling  resistance  tyres.  For  tyres  supplied  as  original  equipment,  rely  on  the  vehicle 
manufacturers' incentive to produce cars with low fuel consumption, and to produce cars with 
a low CO2 rating in order to meet future CO2 emission targets. 

Option b) 
minimum standard mandatory for vehicle and component type approval. 

Introduce a grading and labelling scheme as in Option 1 but make at least the 

EN 

3 

   EN 

 
Option c) 

Same as Option b) but would also apply to after-market tyres.  

It was considered that Option c) should be chosen since the benefits would apply to existing 
vehicles  and  would  thus  be  realised  over  a  shorter  timescale.  However,  only  the  mandatory 
limit  values  would  be  included  in  the  main  Regulation.  Details  of  a  grading  and  labelling 
scheme would be agreed at a later date.  

With Regard to Tyre Pressure Monitoring Systems, the following options were considered;  

Option a) Do nothing and allow the market to take the initiative. 

Option  b)  Establish  technical  standards  for  such  systems  (where  fitted)  and  allow 
manufacturers to fit them optionally. 

Option c) Establish technical standards and mandatory fitting requirements. 

It  was  considered  that,  in  order  to  be  effective  in  maintaining  an  optimum  pressure  to 
minimise fuel consumption and CO2 emissions, a higher degree of accuracy was required than 
is  available  with  current  systems.  In  addition,  there  was  justification  for  mandatory  fitment 
since reliance on market forces alone was unlikely to achieve full fleet penetration.  

With regard to tyre wet grip, it was considered that voluntary options were not appropriate 
since  wet  grip  was  an  important  safety  issue  and  the  'no  action'  option  could  lead  to  a 
reduction in wet grip standards due to the pressure on manufacturers to meet noise and rolling 
resistance requirements. Therefore compulsory wet grip approval was considered as the best 
option. 

In  general,  the  impact  assessment  shows  that  it  is  possible  to  improve  the  safety  and 
environmental performance of new vehicles in a cost-effective manner, while simplifying the 
legislative framework covering vehicle safety. 

EN 

4 

   EN