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 - Impact assessment {COM(2008) 316} {SEC(2008) 1909}
Date: 2008-05-23
Institutions: European Commission
Subjects: approval, approximation of laws, impact study, motor vehicle, safety standard, technical standard

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 
SEC(2008) 1908 

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 

Impact Assessment 

{COM(2008) 316} 
{SEC(2008) 1909} 

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Table of contents 

1. 

1.1. 

1.2. 

PROBLEM DEFINITION ........................................................................................... 5 

Simplification ............................................................................................................... 5 

Advanced Safety Features............................................................................................ 6 

1.2.1.  Electronic Stability Control.......................................................................................... 7 

1.2.2.  Advanced Emergency Braking Systems (AEBS) ........................................................ 7 

1.2.3.  Lane Departure Warning Systems (LDW)................................................................... 8 

1.3. 

Tyres............................................................................................................................. 8 

1.3.1.  Rolling Noise Emissions. ............................................................................................. 9 

1.3.2.  Tyre Rolling Resistance ............................................................................................. 11 

1.3.3.  Tyre Pressure Monitoring Systems ............................................................................ 12 

1.3.4.  Wet Grip Performance ............................................................................................... 13 

2. 

3. 

3.1. 

3.2. 

3.3. 

3.4. 

4. 

4.1. 

4.2. 

objectives.................................................................................................................... 14 

3. Policy Options ........................................................................................................ 15 

Simplification aspects ................................................................................................ 15 

Advanced Vehicle Technologies................................................................................ 15 

Tyres and Tyre Systems ............................................................................................. 16 

Subsidiarity and Proportionality................................................................................. 19 

Analysis...................................................................................................................... 20 

Simplification ............................................................................................................. 20 

Advanced safety features ........................................................................................... 22 

4.2.1.  Electronic Stability Control........................................................................................ 22 

4.2.1.1.  Light Vehicles ............................................................................................................ 22 

4.2.1.1.1 Benefits...................................................................................................................... 22 

4.2.1.1.2 Costs .......................................................................................................................... 24 

4.2.1.2.  Heavy Vehicles .......................................................................................................... 24 

4.2.1.2.1 Benefits...................................................................................................................... 24 

4.2.1.2.2 Costs .......................................................................................................................... 25 

4.2.1.3.  Options for the Introduction of ESC .......................................................................... 25 

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4.2.2.  Advanced Emergency Braking Systems (AEBS) ...................................................... 25 

4.2.2.1.  Benefits....................................................................................................................... 25 

4.2.2.2.  Costs ........................................................................................................................... 26 

4.2.2.3.  Options for the Introduction of AEBS ....................................................................... 27 

4.2.3.  Lane Departure Warning Systems.............................................................................. 28 

4.2.3.1.  Benefits....................................................................................................................... 28 

4.2.3.2.  Costs ........................................................................................................................... 28 

4.2.3.3.  Options for Lane Departure Warning Systems. ......................................................... 28 

4.3. 

Tyres and Tyre Systems ............................................................................................. 29 

4.3.1.  Tyre Noise .................................................................................................................. 29 

4.3.1.1.  Benefits from Reduced Tyre Noise............................................................................ 30 

4.3.1.2.  Valuation of benefits from new noise limits for C1 tyres .......................................... 31 

4.3.1.3.  Costs of Tyre Noise Reductions................................................................................. 32 

4.3.1.4.  Options for Reducing Tyre Noise .............................................................................. 35 

4.3.1.4.1 C1 (car) tyres ............................................................................................................. 35 

4.3.1.4.2 Commercial Vehicle Tyres (C2 and C3) ................................................................... 38 

4.3.1.4.3. Additional Options ................................................................................................... 41 

4.3.2.  Tyre Rolling Resistance ............................................................................................. 42 

4.3.2.1.  Calculation of Benefits at the Vehicle Level ............................................................. 42 

4.3.2.2.  Calculation of Costs at the Vehicle Level.................................................................. 43 

4.3.2.3.  Options for Introducing Tyre Rolling Resistance Requirements ............................... 43 

4.3.2.3.1 Car Tyres ................................................................................................................... 43 

4.3.2.3.2 Commercial vehicle tyres. ......................................................................................... 45 

4.3.2.3.3. Labelling................................................................................................................... 45 

4.3.3.  Tyre Pressure Monitoring Systems ............................................................................ 46 

4.3.3.1.  Benefits....................................................................................................................... 46 

4.3.3.1.1. Safety Benefits ......................................................................................................... 46 

4.3.1.1.2. CO2/ fuel saving benefits. ........................................................................................ 46 

4.3.3.2.  Costs. .......................................................................................................................... 46 

4.3.3.3.  Options for introducing Tyre Pressure Monitoring Systems ..................................... 46 

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4.3.4  Wet Grip Requirements 

4.3.4.1.  Benefits....................................................................................................................... 47 

4.3.4.2.  Costs ........................................................................................................................... 47 

4.3.4.3.  Options for Introducing Wet Grip Requirements....................................................... 48 

5. 

6. 

6.1. 

6.2. 

Monitoring and evaluation ......................................................................................... 48 

procedural issues and consultation of interested parties ............................................ 48 

Internet Consultation. ................................................................................................. 48 

Opinion of the Impact Assessment Board.................................................................. 51 

ANNEX I Potential casualty savings achievable through various technologies...................... 52 

ANNEX II SUMMARY OF COSTS AND BENEFITS PER VEHICLE ............................... 53 

ANNEX III ............................................................................................................................... 57 

Consideration of the production, employment and affordability effects of the proposalS 

CoVered by this impact assessment ........................................................................... 57 

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1. 

PROBLEM DEFINITION 

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) 

European  Community  Directives  concerning  the  type-approval  of  motor  vehicle 
components  and  systems  have  been  progressively  introduced  since  1970,  under  the 
framework of Community Directive 70/156/EEC. Over the last 35 years, the nature of the 
regime  has  evolved  from  being  a  system  designed  to  allow  free  trade  of  vehicle 
components  between  Member  States,  to  a  system  based  on  compulsory  whole-vehicle 
type-approval  (WVTA)  for  most  categories  of  vehicle.  WVTA  requires  a  series  of 
approvals  to  the  component  or  system  Directives,  or  equivalent  standards  which  are 
produced  by  the  United  Nations  Economic  Commission  for  Europe  (UNECE).  These 
Directives  and  Regulations  have  been  updated  over  the  years  to  reflect  technical 
progress,  so  that  there  are  now  around  50  base  Directives  and  over  100  amending 
Directives  covering  this  subject  area.  This  duality  of  EC  Directives  and  UNECE 
Regulations is confusing, unnecessary and wasteful of resources.  

Advances in vehicle technology in the areas of braking, vehicle stability, sensing systems 
and  tyre  technology  offer  the  potential  for  significant  progress  in  these  areas.  Some 
advanced systems, such as vehicle stability control and tyre pressure monitoring systems, 
are  already  being  offered  by  vehicle  manufacturers.  One  area  of  particular  importance 
concerns vehicle tyres. Tyres are critical to the safety performance of a vehicle since they 
represent  the  only  contact  between  the  vehicle  and  the  road.  They  are  also  partially 
responsible for the level of traffic noise, and they can have a considerable impact on the 
fuel consumption of a vehicle, and hence its CO2 emissions. 

The purpose of this Impact Assessment is to examine the various issues concerning the 
current  type-approval  regime  for  vehicle  safety,  particularly  the  areas  that  can  be 
simplified and the areas where additional measures may be appropriate in order to meet 
safety and environmental objectives. 

Hence  the  Impact  Assessment  is  structured  so  that  the  three  main  elements  of  the 
proposal are considered separately, i.e. 

1) Simplification aspects 

2) Advanced Safety Systems 

3) Tyres  

1.1. 

Simplification 

The  original  vehicle  type-approval  framework  Directive,  70/156/EEC  has  now  been 
recast  as  2007/46/EC  to  reflect  the  evolution  of  the  vehicle  type-approval  procedure  in 

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recent years. In addition, the requirements covering vehicle emissions have been updated 
and  consolidated  into  new  Council  and  Parliament  Regulations  which  are  directly 
applicable in Member States. However, many of the original safety-related Directives are 
around 35 years old, and although some have been updated a number of times, the result 
is  that  there  are  many  unconsolidated  amendments  which  are  complicated  to  interpret 
and,  due  to  the  effort  involved  in  producing  amendments,  do  not  always  represent  the 
most recent state of technology. It is likely that in the future this situation will worsen. 

In 2006 the CARS 21 group1 recommended that 38 EC Directives should be replaced by 
equivalent  UNECE  Regulations  in  order  to  simplify  the  regulatory  regime.  UNECE 
Regulations  are  widely  accepted  in  countries  inside  and  outside  the  EU,  and  the  EU  is 
itself a contracting party to many of these Regulations. Therefore there is little point in 
the EU retaining and constantly updating its own Directives, unless there are particular 
aspects  which  are  not  covered,  or  are  insufficiently  covered,  by  UNECE  Regulations. 
Therefore it is proposed that the requirements set out in these directives will be carried 
over  by  this  Regulation  and  its  implementing  measures  to  this  Regulation  and  will  be 
replaced,  where  appropriate,  with  references  to  the  corresponding  regulations  of  the 
United Nations Economic Commission for Europe 

The proposal will affect vehicle and component manufacturers, national administrations 
and test authorities. All should benefit to varying extents from the greater clarity of the 
legislation, and national administrations will benefit from reduced workload transposing 
Directives into national regulations.  

1.2. 

Advanced Safety Features 

Advances  in  vehicle  design,  including  the  provision  of  seat  belts  and  airbags  and 
improvements in crashworthiness, have led to considerable casualty reductions in recent 
years.  However,  future  increases  in  road  traffic  will  make  it  difficult  to  meet  future 
casualty reduction targets unless more advanced accident avoidance technologies can be 
introduced.  Although  market  forces  are  already  encouraging  the  introduction  of  new 
technologies in some vehicles, it is possible that legislation will be required to speed their 
introduction.  In  general,  advanced  features  are  initially  introduced  as  options  on  high-
specification cars, and eventually filter down to cars at the low-budget end of the market. 
However, the situation varies considerably between one Member State and another, and 
it is possible that, due to cost reasons and the fact that some buyers do not consider safety 
as  a  high  priority  when  making  a  purchasing  decision,  some  'entry-level'  models  will 
never  be  equipped  with  a  feature  unless  it  is  compulsory.  There  may  therefore  be 
justification  to  introduce  mandatory  requirements  for  advanced  vehicle  safety  systems, 
where such requirements are technically and economically feasible and can be justified in 
terms  of  projected  casualty  savings.  Annex  I  shows  the  potential  savings  in  deaths  and 
serious  injuries  that  can  be  obtained  by  various  safety  technologies.  As  can  be  seen,  a 
high proportion of these savings can be achieved by means of the measures envisaged in 
this  document,  and  discussed  in  the  following  sections.  The  measures  in  Annex  I  not 
specifically  covered  by  this  proposal  are  either  covered  under  other  framework 
legislation  or  covered  under  this  proposal  via  UNECE  legislation.  For  example, 
Pedestrian  Protection  is  covered  by  a  separate  proposal  which  was  adopted  by  the 

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Competitive Automotive Regulatory System for the 21st Century. 

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Commission in 2007. ABS braking on motorcycles would be covered under the separate 
motorcycle framework Directive. Daytime running lights, conspicuity markings and seat 
belt  reminder  systems  are  being  covered  by  amendments  to  the  relevant  UNECE 
Regulations  which  would  be  referenced  under  implementing  regulations  under  this 
proposal. 

Where possible, the detailed technical specifications of advanced safety systems will be 
based on UNECE Regulations or other international standards. The first systems likely to 
be covered are Electronic Stability Control (ESC), Advanced Emergency Braking (AEB) 
and Lane Departure Warning systems (LDW) described in 1.2.1 to 1.2.3. Tyre Pressure 
Monitoring  Systems  can  also  be  described  as  advanced  safety  systems  but  they  are 
discussed under the tyres section (1.3.3). Other systems might be included at a later date. 
The  beneficiaries  would  be  the  road  users  in  general.  The  costs  would  fall  initially  to 
vehicle manufacturers, but would be likely to be passed on to vehicle buyers. 

1.2.1.  Electronic Stability Control  

Electronic  stability  control  (ESC)  systems  act  on  the  braking  or  power  systems  of  a 
vehicle  to  assist  the  driver  in  maintaining  control  of  the  vehicle  in  a  critical  situation 
(caused, for example, by poor road conditions or excessive speed during cornering). ESC 
usually acts by sensing wheel slip in individual wheels and reducing power or applying 
braking to one or more wheels to regain stability. ESC can reduce accidents by more than 
20 percent in normal conditions and more than 30 percent in wet or icy conditions. It has 
been  available  on  some  cars  for  around  10  years,  and  costs  have  been  reducing  due  to 
improved  technology  and  increased  volumes.  The  market  penetration  of  ESC  in  cars 
varies  greatly  between  Member  States.  Recent  figures2  suggest  that,  on  average,  43 
percent  of  cars  in  the  'supermini'  class  are  offered  with  ESC  as  standard  in  Denmark 
compared with only 3 percent in Malta. In the case of small family cars, 83 percent are 
offered with ESC as standard in Denmark compared with only 35 percent in Ireland. 

For heavy commercial vehicles, there is less customer demand, possibly for cost reasons 
and possibly because drivers of heavy vehicles are considered to be less vulnerable in an 
accident  and  less  likely  to  benefit  from  ESC  (although  some  of  the  main  beneficiaries 
may  be  the  occupants  of  smaller  vehicles  who  are  less  likely  to  be  struck  by  a  large 
vehicle equipped with ESC). Thus in these cases the market mechanism alone may not be 
sufficient to bring about improvements in safety. 

Separate  technical  standards  for  light  and  heavy  vehicle  ESC  have  been  under 
development within the UNECE. Decisions need to be made on how these new standards 
will be applied in the European Union. 

1.2.2.  Advanced Emergency Braking Systems (AEBS) 

Some  vehicles  are  already  fitted  with  systems  which  employ  sensors  to  monitor  the 
proximity  of  the  vehicle  in  front  and  detect  situations  where  the  relative  speed  and 
distance  between  the  two  vehicles  suggest  that  a  collision  is  imminent.  In  such  a 
situation, emergency braking can be automatically applied and the effects of the collision 

2 

Figures from the 'choose ESC website 
http://www.chooseesc.eu/download/press/EuroNCAP%208_May%20ESC%20Brochure.pdf 

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are  either  mitigated  or  avoided  altogether.  The  capability  of  such  systems  could  be 
expanded in the future to cover other types of accident (for example, pedestrian accidents 
or  even  head-on  collisions).  Preliminary  studies  suggest  that  such  systems  could 
ultimately save around 5000 fatalities and 50,000 serious injuries per year across the EU. 
It is likely that due to the technical challenges involved, these systems will only be ready 
for  installation  on  the  whole  range  of  new  vehicles  in  a  few  years  time.  However,  it  is 
already possible to provide estimates of the likely costs and benefits of such systems. 

1.2.3.  Lane Departure Warning Systems (LDW)  

Lane Departure Warning (LDW) Systems assist drivers in keeping their lanes by warning 
drivers when their vehicle is in danger of leaving the lane unintentionally (mainly due to 
lack of driver attention). Current systems use either an audible beep or a "rumble strips" 
noise, which mimics the sound made when the tyre runs over a lane divider or road edge 
marking. 

A supplement to the LDW system is the lane change assistant (LCA) system. This assists 
drivers intending to change lanes. The lane change assistant monitors the adjacent lanes 
and warns the driver if another vehicle is likely to come within colliding distance during 
the  lane  change.  This  occurs  for  example,  if  the  other  vehicle  is  located  in  the  LCA 
equipped  vehicle's  blind  spot.  Presently  the  system  would  warn  the  driver  of  such  a 
problem  with  e.g.  a  red  flashing  side  mirror.  Later  on,  a  system  with  feedback  in  the 
steering wheel could be introduced. The lane change assistant needs predictive sensors to 
scan the surrounding vehicles. The sensors might possibly be integrated with the sensors 
used on a AEBS system.  

1.3. 

Tyres 

The  current  type-approval  Directive  on  vehicle  tyres  (92/23/EEC)  covers  specifications 
relating to the approval of new tyres as components, and requirements for the equipment 
of  new  vehicles  with  suitable  tyres.  The  requirements  are  mostly  related  to  tyre  safety, 
but the Directive was amended in 2001 (2001/43/EEC) to cover additional requirements 
to limit tyre rolling noise  emissions. The initial noise limit values agreed in 2001 were 
subject to a review, to assess whether it was possible to introduce tighter noise emission 
values without compromising other essential aspects of tyre design. This review has now 
been completed, and new noise limit values have been recommended. 

In  addition,  as  part  of  the  Commission's  CO2  reduction  strategy,  tyres  have  been 
identified  as  potential  sources  for  improvements  in  vehicle  fuel  economy  (and  hence 
reductions  in  CO2  emissions).  In  particular,  the  use  of  low  rolling-resistance  tyres  can 
significantly  reduce  fuel  consumption,  and  the  use  of  tyre  pressure  monitoring  systems 
(TPMS) can ensure that tyres remain inflated to the optimum pressure to maximise fuel 
economy. TPMS can also offer safety benefits by providing the driver with a warning of 
any significant deflation in one or more of the vehicle tyres. 

Studies  have  shown  that  it  is  possible  to  improve  the  noise  and  fuel  economy 
performance  of  tyres  without  necessarily  affecting  their  safety.  However,  safety  is 
paramount and it is essential that existing safety standards are not compromised. Since it 
is  recognised  that  it  could  be  possible  for  manufactures  to  meet,  say,  more  stringent 
rolling  resistance  requirements  by  designing  a  tyre  which  has  poor  grip  performance 

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(particularly in the wet), it is considered that new car tyres should also be subject to wet 
grip performance requirements to ensure that this aspect is not overlooked in the pursuit 
of  more  energy-efficient,  quieter  tyres.  Consequently  there  are  four  areas  where  it  is 
considered necessary to introduce new performance requirements for tyres: 

- tighter noise emission requirements, 

-new rolling resistance requirements, 

-the introduction of TPMS to vehicles, and  

- new wet-grip requirements. 

It  is  intended  to  treat  the  above  measures  as  a  package,  since  they  are  inter-related. 
However,  since  it  is  possible  that  different  regulatory  solutions  may  be  appropriate  for 
different elements of the package, the different elements are considered separately within 
this Impact Assessment.  

Further details of the four elements of the package are given below. 

1.3.1.  Rolling Noise Emissions. 

Road-traffic  is  perceived  by  the  population  to  be  the  biggest  source  of  noise  pollution. 
Above a vehicle speed of 40 to 50 km/h, rolling noise is the dominant component of road 
traffic noise. It is already widely recognized that the noise exposure is a serious limiting 
factor for people’s quality of life, but recent research has highlighted the harmful effects 
noise exposure may have on people’s health. In addition, impaired sleep may also have 
effects  on  work  efficiency  and  learning  efficiency  at  schools.  Reducing  the  level  of 
tyre/road noise thus represents an effective approach for protecting the population from 
noise.  An  integrated  approach,  involving  the  use  of  low-noise  road  surfaces  and  low-
noise tyres is seen as being best means of achieving this. The Directorate General for the 
Environment has been involved, together with other stakeholders, in work to investigate 
the use of low-noise road surfaces. The Directorate General for Enterprise and Industry 
has  the  responsibility  for  tyre  performance  standards.  This  section  concentrates  on  the 
contribution of the vehicle tyre to lowering tyre-road noise emissions.  

The  currently  applicable  limit  values  laid  down  in  Directive  2001/43/EC  (amending 
Council Directive 92/23/EEC relating to tyres for motor vehicles and their trailers and to 
their  fitting)  are  given  in  table  1(a)-(c)  below.  The  limit  values  are  based  on  various 
categories  and  widths  of  tyre.  Class  C1  tyres  are  generally  used  for  cars,  class  C2 
generally for light commercial vehicles and C3 generally for heavy commercial vehicles. 
Within  class  C1,  there  are  several  width  categories.  Since  wider  tyres  will  normally 
produce more noise than narrow tyres, the 2001 Directive allows higher noise limits for 
the wider categories of tyre. As can be seen, some of the future values are dependant on 
studies  to  be  carried  out  to  ensure  that  these  more  stringent  noise  values  do  not 
compromise  tyre  performance  in  other  areas.  This  study  (by  FEHRL,  the  Forum  of 

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European National Highway Research Authorities) has now been completed3 and will be 
referred to in this document as the FEHRL report. 

The specific proposals set out in the FEHRL report to amend the above limit values are 
discussed in section 3. However, one of the main conclusions of the FEHRL study is that 
many tyres currently on the market could easily meet tighter limit values than currently 
exist  (without  any  obvious  trade-offs  in  other  areas).  This  may  be  partly  because  tyre 
manufacturers  are  anticipating  the  lower  limit  values  (as  foreseen  by  the  'indicative' 
values in columns B and C of table 1). Hence even if there is no change to the Directive, 
the  situation  will  probably  continue  to  improve.  However,  if  limit  values  remain  at  the 
pre-2007  levels,  there  will  be  little  incentive  to  improve  tyre  noise  performance  and 
design  optimisation  in  other  areas  (for  example,  wet  grip)  may  actually  lead  to  tyre 
designs  that  barely  meet  the  current  requirements.  This,  in  conjunction  with  increasing 
overall  traffic  levels,  and  the  increased  use  of  wider,  noisier,  tyres,  could  lead  to  an 
increase in the traffic noise problem if no action is taken. 

The beneficiaries from additional action to improve tyre/road noise standards would be 
the general public, particularly those living near busy roads. The costs required to meet 
tighter noise standards would initially fall to tyre and vehicle manufacturers, but would 
ultimately  fall  to  vehicle  users.  There  is  a  significant  externality  problem  here,  i.e.,  the 
people who buy tyres are not necessarily the people who benefit from lower traffic noise. 
Even  in  the  case  where  buyers  of  tyres  would  benefit  from  lower  traffic  noise,  a 
particular  buyer  would  probably  consider  that  his/her  own  purchasing  decision  would 
have  little  effect  on  his/her  quality  of  life  (unlike  the  situation  concerning  tyre  safety, 
where the purchaser is likely to be a direct beneficiary). 

3 

FEHRL Study S12.408210 on tyre/road noise (see 
http://ec.europa.eu/enterprise/automotive/projects/report_tyre_road_noise1.pdf ). 

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Table 1a Noise limit values prescribed in 2001/43/EC (C1 car tyres)  

Note: Additional allowances are given for reinforced tyres (1 dB(A)) and special tyres (2 
dB (A))  

Table 1b. Noise limit values prescribed in 2001/43/EC (C2 light commercial tyres)  

Table 1c. Noise limit values prescribed in 2001/43/EC (C3 heavy commercial tyres)  

1.3.2.  Tyre Rolling Resistance 

Rolling resistance is the resistance to motion that occurs when an object (e.g. a wheel or 
tyre) rolls. It is caused mainly by the deformation of the wheel or tyre or the deformation 
of the contact surface (e.g., the road) and thus it depends very much on the material of 

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the  wheel  or  tyre  and  the  type  of  road  surface.  For  example,  rubber  will  give  a  higher 
rolling friction than steel and sand will give much higher rolling friction than concrete. In 
the case of rubber vehicle tyres, rubber acts as a visco-elastic material that deforms and 
returns  to  its  original  shape  periodically.  The  term  'hysteresis  loss'  is  often  used  in 
literature to describe the energy lost as heat during the repeated deformation of a tyre.  

Rolling  resistance  has  a  direct  impact  on  the  vehicle  CO2  emissions  and  fuel 
consumption. A study by TNO 4 (referred to throughout this document as the TNO study) 
estimates that use of low rolling resistance tyres (LRRT) could reduce fuel consumption 
by  3%  for  a  given  vehicle  and  thus  save  on  average  0.09  tonnes  of  CO2  per  year  and 
vehicle.  

There  has  been  a  gradual  reduction  in  rolling  resistance  for  tyres  of  comparable 
dimensions  over  recent  years.  This  has  partly  been  driven  by  the  desire  of  car 
manufacturers  to  reduce  the  overall  fuel  consumption  of  new  cars.  However, 
development  and  use  of  LRRT  needs  to  be  encouraged  and  accelerated  if  they  are  to 
make a significant contribution to the CO2 reduction strategy.  

Apart from the global benefits made possible from the gradual replacement of traditional 
tyres  by  LRRT,  the  individual  vehicle  users  can  also  benefit  from  lower  fuel  bills. 
However,  there  is  likely  to  be  a  higher  initial  cost,  largely  reflecting  the  development 
costs incurred by the tyre manufacturer. Also, due to the fact that tyres with high speed 
ratings tend to have a higher rolling resistance than standard tyres, it is possible that more 
demanding rolling resistance requirements will restrict the choice of higher-performance 
tyres available on the market.  

The use of customer information (for example, tyre labelling or information campaigns) 
may encourage the increased market penetration of LRRT. However, the tyre purchasing 
decision  is  likely  to  be  based  on  a  number  of  factors  other  than  fuel  economy;  and  in 
particular the purchase price is likely to be a significant factor particularly with an older 
car.  Also,  the  purchaser  may  have  little  real  choice  if  a  particular  car  has  a  limited 
number  of  tyre  types  suitable  for  it,  or  if  a  particular  tyre  dealer  or  fitter  only  offers  a 
limited range of products. Thus, although the market mechanism may have a role to play 
in encouraging LRRT, it may not be sufficient in itself.  

1.3.3.  Tyre Pressure Monitoring Systems  

Maintaining  proper  tyre  inflation  is  essential  for  both  fuel  efficiency  and  better  tyre 
performance.  Deflated  tyres  can  cause  up  to  4%  increase  in  fuel  consumption  while 
reducing tyre lifespan by 45% . Tyres can lose 3-6% of pressure per month, and this may 
not  be  noticed  by  the  driver.  Deflated  tyres  are  also  an  important  factor  causing  road 
accidents resulting in numerous fatalities and injuries throughout Europe. Despite the fact 
that tyre pressure is important for the operation of the vehicle car owners are not careful 
with the condition of their tyres. The TNO study quotes research which shows that 50% 
of all cars are driven on under-inflated tyres, and US estimates which indicate that under-
inflation causes an increase in the average rolling resistance of about 8%. 

4 

Review and analysis of the reduction potential and costs of technological and other measures to 
reduce  CO2-emissions  from  passenger  cars  Final  Report-  TNO  Contract  nr.  SI2.408212  ,  see 
http://ec.europa.eu/enterprise/automotive/projects/report_co2_reduction.pdf 

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A  potential  solution  to  this  problem  is  the  use  of  Tyre  Pressure  Monitoring  Systems 
(TPMS). TPMS are systems that monitor tyre pressure and warn the driver in case a tyre 
has to be inflated. In certain cases TPMS also warn for tyre failures for safety reasons. 
Two  different  TPMS  types  are  distinguished,  indirect  TPMS  and  direct  TPMS.  The 
indirect TPMS uses the antilock brake system (ABS) wheel speed sensor to measure the 
speed of the wheel. Pressure drops are detected by the increase in the ABS wheel speed 
that  is  caused  by  the  reduction  of  the  rolling  wheel  diameter.  Direct  TPMS  have 
calibrated  internal  sensors  that  measure  actual  tyre  pressure  and  transmit  data  to 
receivers.  

Use of TPMS is relatively low in Europe. In the USA it is higher due to the TREAD Act 
which  effectively  mandates  the  use  of  TPMS  on  new  cars.  It  is  envisaged  that  similar 
legislation will be necessary in Europe in order to reap the full benefits of such a system. 
However,  it  could  be  argued  that  TPMS  systems  meeting  the  US  standard  may  not  be 
sufficiently  accurate  to  detect  the  degree  of  under-inflation  that  can  make  a  significant 
difference  to  fuel  consumption  and  hence  CO2  emissions.  This  is  discussed  further  in 
section 3. 

Apart  from  the  global  benefits  made  possible  by  the  increased  use  of  TPMS  systems, 
individual vehicle users could benefit from reduced fuel consumption, increased tyre life 
and greater safety. The additional cost will fall to the purchasers of new cars. There are 
no  plans  to  require  TPMS  to  be  retro-fitted  to  existing  vehicles.  This  would  not  be  a 
practical proposition since the cost of adding such a system would outweigh the benefits 
on a car with a limited remaining life. Also, a TPMS system is largely integrated with the 
car  (in  the  case  of  an  indirect  system,  through  the  ABS  brake  system)  and  cannot  be 
installed simply by replacing one tyre with another.  

1.3.4.  Wet Grip Performance  

Wet  grip  performance,  in  other  words,  the  skid  resistance  of  tyres  under  wet  road 
conditions,  is  a  significant  safety  feature.  There  is  no  evidence  to  suggest  that  current 
new tyres, even tyres which have been designed for low noise or low rolling resistance, 
are substandard in this area. However, it is acknowledged that if additional requirements 
are introduced with regard to noise or rolling resistance, it is possible that some (cheaper) 
solutions  to  achieve  better  noise  or  rolling  resistance  could  be  detrimental  to  wet  grip 
performance.  This  was  recognised  by  the  United  Nations  Economic  Commission  for 
Europe (UNECE) working group which developed standards for wet grip as part of the 
same  regulation  (UNECE  Regulation  117)  which  specifies  tyre/road  noise  limits  along 
the same lines as Directive 2001/43/EC. It is proposed that the Regulation 117 wet grip 
test  is  introduced  for  all  new  car  tyres,  to  ensure  that  safety  standards  are  not 
compromised by other new requirements. 

The benchmark for the Regulation 117 wet grip test is based on existing tyre types, so 
there will be no increased safety benefit from the introduction of this requirement. There 
will be a small additional cost for the regulatory approval (see section 4) but this will be 
negligible when spread over the entire tyre production. 

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2. 

OBJECTIVES 

The  Commission  has  high-level  objectives  relating  to  road  safety,  the  environment  and 
the competitiveness of its industries: 

•  Road Safety The White Paper on European Transport Policy, which was adopted by 
the Commission in 2001 provides an umbrella for the European Road Safety Action 
Programme,  which  sets  out  the  Community’s  goal  of  reducing  the  number  of  road 
fatalities to less than 25,000 by the year 2010. 

•  Environment. A key target in the Commissions environmental strategy is the target of 

reducing emissions to 120 g/km for the average new car fleet.  

•  Competitiveness.  The  CARS  21  report  identified  a  number  of  objectives  relating  to 

the competitiveness of the European motor industry, including: 

– 

– 

– 

– 

– 

– 

ensuring  an  open  and  competitive  Single  Market,  including 
competition 

knowledge, such as research, innovation, and skills 

better regulation 

ensuring 
environmental policies 

synergies  between  competitiveness,  energy  and 

ensuring full and fair participation in global markets 

facilitating social and economic cohesion 

The main objectives of the package of proposals covered by this Impact Assessment are 
as follows: 

-to  contribute  to  road  safety  objectives  by  reducing  casualties  by  the  introduction  of 
requirements for advanced safety systems such as vehicle stability control, lane departure 
warning and advanced emergency braking 

-to  contribute  to  environmental  objectives  by  reducing  the  amount  of  road  noise  and 
vehicle  CO2  emissions  through  improvements  to  tyre  performance,  while  at  least 
maintaining and possibly improving the level of tyre safety 

- to contribute to competitiveness objectives by simplify the existing vehicle safety type-
approval legislation to improve transparency and ease administrative burden.  

A  full  analysis  of  the  current  situation  concerning  the  European  Automotive  industry, 
plus  a  discussion  about  the  possible  impact  of  the  proposals  discussed  in  this  Impact 
Assessment on retail prices and affordability is given in Annex III. 

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3. 

POLICY OPTIONS  

Because this proposal includes a number of separate elements, the policy options for each 
separate element are examined below. 

3.1. 

Simplification aspects  

The options identified are as follows: 

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 

c) 

Replace all existing Directives through the proposed Regulation  

Option a) would mean continuing with the existing Directive structure and adding to it, 
as  additional  amendments  to  Directives  became  necessary.  This  Directive  structure 
would continue to operate in parallel with the existing UNECE Regulatory structure with 
the technical requirements usually (but not always) being equivalent. This is currently the 
cause  of  much  confusion  for  stakeholders  who  are  not  closely  involved  with  the  type-
approval  system,  and  leads  to  a  situation  of  a  regulatory  system  that  is  less  than  fully 
transparent.  The  CARS  21  group  (and  the  following  Communication)  strongly 
recommended that the current situation should be simplified, Option b) would effectively 
be a piecemeal replacement of current Directives which would probably take place over a 
number of years. Option c) would represent a 'clean sheet of paper' and would therefore 
maximise  the  advantages  of  simplification.  However,  in  most  cases  the  technical 
requirements would be the same as the existing requirements, and in such cases the new 
regulation  would  allow  existing  vehicle  types  to  remain  subject  to  the  existing 
requirements. Any requirements that represented a technical advance would only apply to 
new vehicle types. 

A further analysis is included in section 4.1 . 

3.2. 

Advanced Vehicle Technologies 

The options identified are as follows: 

a) 

b) 

Do nothing and allow the market to take the initiative. 

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

c) 

Establish technical standards and mandatory fitting requirements. 

Features  such  as  ESC  are  already  appearing  on  an  increasing  number  of  cars  in  some 
markets (In Germany, over 70% of new cars are fitted with ESC) so it could be argued 
that  option  a)  is  sufficient.  However,  on  vehicles  such  as  heavy  trucks  and  tourist 
coaches, where the benefit of ESC may be even greater than for cars, there is often not 
the  market  incentive  to  fit  ESC  voluntarily  (since,  unlike  the  case  with  cars,  the 

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purchasers  are  not  normally  the  beneficiaries).  So  if  there  is  a  good  cost-benefit 
justification for fitting ESC, then option c) should be preferred. If the cost–benefit case 
does  not  justify  mandatory  fitment,  then  option  b)  should  be  considered  since  it  would 
require common standards for such systems and would therefore offer protection for the 
consumer by ensuring that inferior systems were not allowed on the market. It could be 
argued that standardisation is not necessary, and that it should be left to the consumer to 
decide whether to pay more for a superior system or less for an inferior system. However, 
the  quality  of  a  stability  control  system  is  a  difficult  concept  to  put  across  to  a  non-
technical consumer. It is easy for a consumer to compare cars on the basis of, say, engine 
size, and to decide whether it is worth paying more money for a car with a larger engine. 
However,  vehicle  stability  control  systems  cannot  be  measured  in  the  same  way,  and 
while  manufacturers  can  use  a  wide  vocabulary  of  technical  terms  to  describe  the 
capabilities of their particular system, this is not always  objective, and it  could  thus be 
argued  that  a  consumer  needs  the  protection  of  a  unified  standard  for  vehicle  stability 
control.  

Other  advanced  systems  such  as  AEBS  and  LDW  are  only  now  starting  to  appear  on 
some  higher  specification  vehicles,  and  it  is  difficult  to  predict  the  extent  to  which  the 
market  will  encourage  these  systems  to  be  fitted  as  standard.  However,  it  is  likely  that 
these  systems  will  follow  the  same  pattern  as  ESC,  i.e,  a  high  take-up  on  higher-
specification  vehicles  in  the  more  affluent  Member  States,  but  a  much  lower  take-up 
elsewhere. Also, it is unlikely that market forces alone will encourage 100% fitment on 
the vehicles where  such  systems are likely to yield the greatest benefits, such  as heavy 
trucks. Because of the sophistication of these systems, and the fact that they may be seen 
to  take  over  some  functions  which  are  normally  the  responsibility  of  the  driver,  it  is 
especially  important  that  sufficient  performance  requirements  are  introduced  to  ensure 
that the systems do not introduce additional risks. Thus option b) should be preferred to 
the  non-regulatory  option  a).  The  decision  on  whether  option  b)  or  option  c)  is  chosen 
may  differ  for  various  categories  of  vehicle,  depending  on  the  particular  costs  and 
benefits  which  apply  to  those  particular  vehicle  categories.  This  is  explored  in  more 
detail in Section 4.2. 

3.3. 

Tyres and Tyre Systems 

As  indicated  above,  the  tyre  proposals  include  four  different  elements:  noise,  rolling 
resistance,  wet  grip  and  Tyre  Pressure  Monitoring  Systems  (TPMS).  This  leads  to 
various  options  and  combinations  of  options  in  relation  to  the  choice  of  voluntary  or 
mandatory application, or the level of technical difficulty that should be demanded. Table 
2 examines possible combinations of options, and eliminates those which are thought not 
to be practical. The more practical options are examined in greater detail in Section 4.3. 

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Table 2 - Potential policy options for tyres  

Potential Policy Option 

Tyre feature  

Do nothing 

Voluntary/market solution  Mandatory solution (lower 

Noise 

Rolling Resistance 

Wet grip  

technical difficulty) 

(examined 

 (cid:57) 
section 4.3) 

further 

in 

X  Unlikely  that  tyre  buyers 
will  consider  low-noise  as  a 
major  priority.  However,  a 
labelling  scheme  could  be 
considered 
to 
in  addition 
mandatory requirements.  

both 

feasible 

X.  Studies  show  that  some 
reduction  in  tyre/road  noise 
and 
is 
necessary.  As  explained  in 
section  1.3.1,  without  any 
action, 
noise 
problem is likely to increase 
in future years.  

tyre 

the 

Mandatory 
(higher 
difficulty) 

(cid:57)(examined 
section 4.3) 

solution 
technical 

further 

in 

X  It is  essential that the  use 
low  rolling  resistance 
of 
tyres  is  at  least  encouraged 
in  order 
to  meet  CO2 
reduction targets  

(cid:57)  Buyers  will  see  a  benefit 
in  fuel  consumption  when 
buying LRRT, so  use of the 
market  mechanism 
is  a 
possibility.  

(cid:57)(examined 
section 4.3) 

further 

in 

(cid:57)(examined 
section 4.3) 

further 

in 

resistance 

X  If  proposals  on  noise  or 
rolling 
are 
adopted,  then  it  is  essential 
grip 
to 
requirement 
to 
ensure  tyre  design  is  not 
optimised  at  the  expense  of 

a  wet 
in  order 

have 

resistance 

X  If  proposals  on  noise  or 
rolling 
are 
adopted,  then  it  is  essential 
grip 
to 
requirement 
to 
ensure  tyre  design  is  not 
optimised  at  the  expense  of 

a  wet 
in  order 

have 

(cid:57)(examined 
section 4.3) 

further 

in 

X  (There  is  no  identified 
need  for  a  standard  higher 
than  the  existing  Regulation 
117  standard.  However,  if 
manufacturers  wish 
to 
introduce  a  'premium  wet 
grip'  standard,  they  are  free 

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TPMS 

wet grip safety. 

X  The  benefits  of 
low 
rolling  resistance  tyres  will 
only  be  realised  if  tyres  are 
maintained at their optimum 
pressure  

wet grip safety, and existing 
levels  of  safety  should  be 
mandatory, not optional. 

(cid:57)  Buyers  will  see  a  benefit 
in  fuel  consumption  and 
buying 
safety  when 
a 
equipped  with 
vehicle 
TPMS, so use of the market 
mechanism is a possibility. 

to do so. 

X Current generation TPMS 
systems  are  considered  not 
to be sufficiently accurate to 
tyre 
ensure 
pressures are maintained.  

optimum 

(cid:57)(examined 
section 4.3) 

further 

in 

 (cid:57) 

Possible option. (Examined in greater detail in section 4) X Not a viable option, for reasons given 

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3.4. 

Subsidiarity and Proportionality 

For high-volume manufacture, type-approval standards are already harmonised across the 
European  Union  for  passenger  cars  and  are  becoming  harmonised  for  other  types  of 
vehicle. This offers advantages of economies of scale and free access to all EU markets. 
However,  in  the  case  of  low  volume  manufacture,  the  Framework  Directive  allows 
special provisions which can be used to exempt vehicles produced in low volumes from 
certain  requirements  where  the  burden  on  the  manufacturer  may  be  disproportionately 
high due to the need to spread development and approval costs over a smaller number of 
vehicles.  There  is  also  the  option  of  National  Type-approval  for  small-series  vehicles, 
which allows Member States to lay down alternative technical requirements if the full EC 
type-approval requirements are considered over-burdensome or inappropriate. This is in 
line with the principle of subsidiarity. 

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4. 

ANALYSIS 

An  analysis  of  the  three  main  elements  of  the  package  is  given  in  sections  4.1-4.3.  In 
general the impacts fall into three categories as follows 

Economic  Impacts.  The  simplification  proposals  outlined  in  4.1  will  aid  the 
competitiveness of the automotive industry by reducing the duplication of Regulation. In 
addition, the accident reduction measures outlined in 4.2 will reduce the costs due to the 
congestion  arising  from  road  accidents.  Finally,  it  can  be  shown  that  the  use  of  low 
rolling resistance tyres and tyre pressure monitoring systems can reduce costs for vehicle 
owners or operators in the long term. Annex III discusses the economic aspects in more 
detail.  

Social Impacts. Road casualties have an immense social impact, and their effect cannot 
be  described  purely  in  economic  terms.  Also,  the  effect  of  traffic  noise  (to  which  tyre 
noise makes a significant contribution) has a considerable social impact. 

Environmental  Impacts.  The  proposed  tyre  measures  are  intended  to  reduce  the 
environmental  effects  of  noise  and  CO2  emissions.  The  proposals  in  this  document 
relating to low rolling resistance tyres and tyre pressure monitoring systems are expected 
to make a contribution to the complementary measures aimed at achieving a target of 120 
g/km. On the basis of the TNO estimated fuel saving of potential of LRRT and TPMS in 
passenger cars of 3% and 2.5% respectively, for new cars with expected engine test cycle 
performance of 130 g CO2/km this would mean additional reductions of 3.9 (LRRT) and 
3.25  (TPMS)  g  CO2/km.  The  TREMOVE  modelling  of  the real  on-road  performance 
of passenger cars shows that in 2020 the EU-27 average savings could be 2.5 g CO2/km 
for  LRRT  and  3.0  g  CO2/km  for  TPMS.  In  addition,  there  will  be  benefits  for  fitting 
LRRT (and eventually TPMS) for commercial vehicles but these have not been included 
in this calculation.  

As  well  as  the  effect  on  CO2  emissions,  reducing  fuel  consumption  through  more 
efficient  tyres  has  other  environmental  benefits,  for  example  in  the  reductions  in 
consumption  of  raw  material  resources  used  for  making  producing  fuels,  and  the 
environmental  effects  of  processing  and  distributing  those  fuels.  These  effects  are  not 
easily quantified, but are likely to be significant.  

In  addition,  road  noise  is  considered  as  a  significant  environmental  nuisance,  and  a 
possible concern for health. The tyre rolling noise proposals discussed in this document, 
in conjunction with infrastructure measures, are aimed at addressing this situation. 

4.1. 

Simplification 

Currently, a vehicle undergoing type-approval has to meet around 50 (depending on the 
category of vehicle) separate safety–related Directives. In many cases, the manufacturer 
has  the  option  of  meeting  the requirement of an 'equivalent'  UNECE Regulation which 

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has  been  developed  under  the  1958  agreement5  The  EU  is  a  signatory  to  the  1958 
agreement and many of the Regulations adopted under that Agreement. 

The  relationship  between  EU  and  UNECE  legislation  is  an  important  one.  UNECE 
Regulations  are  essentially  trading  agreements  between  Contracting  Parties  which 
originally  consisted  mostly  of  European  Countries,  concerning  various  vehicle 
components. The ECE system pre-dated the EEC/EU Type Approval system, and when 
the latter system was set up in the early 1970's, most of the EEC Directives on vehicle 
parts  were  largely  copies  of  the  corresponding  UNECE  Regulations  (although  in  some 
cases, the reverse was true). As technology has progressed, the EEC/EU Directives have 
been modified in line with UNECE Regulations although there are periods when, due to 
administrative  procedures,  the  corresponding  instruments  may  be  out  of  line  with  each 
other. Since the introduction of European Whole Vehicle  Type Approval in the 1990's, 
vehicle  manufacturers  seeking  approval  for  their  components  or  systems  have  had  the 
choice of meeting either the relevant Directive or the corresponding UNECE Regulation, 
where available. As a result, manufacturers have shown an increasing tendency to choose 
an approval to the UNECE Regulation rather than the Directive since approval through 
the  UNECE  system  allows  access  to  markets  out  side  the  EU  (such  as  Russia,  South 
Africa or Japan). Hence the individual components Directives are becoming increasingly 
redundant where there is a suitable UNECE alternative available. The current duplication 
of  regulation  also  increases  the  complexity  of  the  regulatory  framework,  and  involves 
much  administrative  effort  from  all  stakeholders  in  keeping  the  regulations  up  to  date, 
and keeping up to date with the regulations. Under Option a) (the 'do nothing' option) the 
situation would gradually worsen with the continual updating of legislation adding to the 
already extensive list of Directives. 

Under Options b) and c) the existing Directives would be replaced as far as possible with 
references to UNECE Regulations, removing most of the existing duplication. 

For  many  manufacturers  who  already  use  UNECE  Regulations  in  preference  to  EU 
Directives, these changes would make little difference. However, by eliminating around 
50  base  Directives  and  over  100  amending  Directives,  the  clarity  of  the  vehicle 
regulatory system is improved, with definite (but not easily quantifiable) benefits for all 
stakeholders. UNECE Regulations are increasingly being aligned with Global Technical 
Regulations, which allow vehicles to be tested to a harmonised standard and sold across 
the world to all countries  which are signatories to that particular Regulation. Therefore 
the increased use of the UNECE system will help manufactures reduce costs by avoiding 
duplication of tests and avoiding the design costs associated with meeting different sets 
of regulations. This will help increase the competitiveness of European products in world 
markets.  

In  addition,  by  using  a  direct-acting  Regulation  instead  of  a  Directive,  much  of  the 
administrative  effort  required  by  Member  States  to  transpose  Directives  into  national 
legislation  will  be  avoided.  Assuming  that  one  full-time  official  per  Member  State  is 
required  to  transpose  these  Directives  (including  any  necessary  consultation  process) 

5 

'Agreement  concerning  the  adoption  of  uniform  technical  prescriptions  for  wheeled  vehicles, 
equipment and parts which can be fitted and/or be used on wheeled vehicles and the conditions for 
reciprocal recognition of approvals granted on the basis of these prescriptions' UN Geneva 1958. 

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then  elimination  of  this  task  could  represent  a  saving  of  around  €  50,000  per  Member 
State (€ 1.35m) 

There will, obviously, be some administrative effort involved in the introduction of this 
new  regulation  (and  the  implementing  legislation)  but,  unlike  the  existing  system,  this 
will not recur. There will be additional costs to manufacturers to meet the new technical 
areas  mentioned  in  sections  4.2  and  4.3.  However,  in  relation  to  the  existing  technical 
requirements, there will be no additional burden on manufacturers since approvals to the 
old  Directives  will  still  be  accepted  until  technical  change  renders  these  requirements 
obsolete.  

The  difference  between  Option  b)  and  Option  c)  is  that  that  Option  b)  would  change 
Directives to Regulations as and when the relevant Directives required, while Option c) 
would  introduce  the  new  regime  straight  away  under  a  single  new  Regulation.  Since 
some  Directives  may  remain  unchanged  for  many  years  to  come,  Option  b)  would 
probably  not  be  fully  implemented  for  several  years,  and  would  have  no  obvious 
advantages. Therefore Option c) is preferred.  

4.2. 

Advanced safety features 

4.2.1.  Electronic Stability Control  

Electronic stability control systems for light and heavy vehicles are treated separately in 
this section due to the different accident patterns between these vehicles and the different 
technical specifications proposed. Technical requirements for heavy vehicles have been 
developed  by  an  UNECE  working  group  and  have  been  introduced  in  UNECE 
Regulation 13 which covers braking requirements on heavy vehicles, since ESC systems 
generally act on the braking system. Requirements for light vehicles are being developed 
through  a  Global  Technical  Regulation  which  is  largely  based  on  proposed  US 
requirements.  This  is  likely  to  be  implemented  in  Europe  (and  many  countries  outside 
Europe) through UNECE Regulation 13H which covers braking on light vehicles.  

4.2.1.1.  Light Vehicles 

4.2.1.1.1 Benefits 

A  report  for  DG  TREN6  by  COWI  looked  at  the  costs  and  benefits  of  various  new 
technologies, and in particular ESC for passenger cars. It reviewed a number of existing 
studies on the effectiveness of ESC and concluded that the potential savings per year for 
a  fleet  fully  equipped  with  ESC  could  reduce  accidents  by  around  15-20%.  The  report 
analysed  the  injury  savings  for  the  20  year  period  leading  up  to  full  implementation, 
assuming that, even without legislation, 50% of cars would be fitted with ESC. The study 
then applied the valuations in table 3 to each category on injury, based on an average of 
values  used  throughout  the  EU25,  adjusted  to  account  for  property  damage  and 
congestion costs.  

6 

Cost-benefit  assessment  and  prioritisation  of  vehicle  safety  technologies  (COWI  2006) 
http://ec.europa.eu/transport/roadsafety_library/publications/vehicle_safety_technologies_final_re
port.pdf 

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Using  the  COWI  methodology,  but  adjusting  the  values  to  take  into  account  the  EU 
enlargement and more recent registration statistics, the estimated annual casualty savings 
in  the  EU27  due  to  mandatory  fitment  would  be  around  2250  fatalities,  23,000  serious 
injuries  and  226,000  slight  injuries.  This  gives  a  total  annual  saving  of  10,803  million 
Euros. 

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Table 3. Casualty valuations  

Type 
casualty 

of 

Cost per casualty (Euros)  

Direct cost  

Property 
damage 

Congestion 

Total 

Fatalities  

1,000,000 

Severe Injury   135,000 

Slight Injury 

15,000 

5,200 

4,400 

4,400 

13,000 

1,018,200 

3,700 

3,700 

143,100 

23,100 

Assuming  an  average  number  of  cars  registered  per  year  the  EU  27  to  be  around  13 
million, with an average 13 year lifespan, this means that the total stock of cars is around 
170 million. The additional 50% of cars that would be fitted with ESC due to mandatory 
legislation  would  represent  a  total  of  85  million  cars  (the  other  85  million  would  have 
ESC fitted already). The average saving per car per year would be around 127 Euros.  

4.2.1.1.2 Costs  

The COWI report assumed an increased cost per vehicle of €250 which, using a discount 
rate of 4%, gave a benefit/cost ratio of 3.8. This is similar to the figure of 3.9 given in the 
summary  in  Annex  2  which  uses  the  slightly  different  vehicle  registration  assumptions 
outlined  above.  However,  work  carried  out  by  the  US  Regulatory  body  NHTSA  in 
preparation of the proposal for a Global Technical Regulation on ESC suggested a cost 
per car of 111 US dollars (around €76) assuming the vehicle was already fitted with ABS 
braking, which would almost certainly be the case in Europe. Therefore the 3.8 benefit 
/cost ratio cited by COWI can probably be considered as conservative.  

4.2.1.2.  Heavy Vehicles 

The cost and benefit information in this section was obtained mainly from the working 
papers  of  the  informal  UNECE  group7  which  developed  the  technical  requirements  for 
Regulation 13.  

4.2.1.2.1 Benefits 

Based  on  German  accident  studies,  it  is  estimated  that  around  500  fatalities  and  2500 
serious injuries per year could be saved in the EU27 if heavy goods vehicles and tourist 
coaches were fitted with ESC. Applying the casualty valuations in Table 3, this gives an 
annual saving of around €867million.  

7 

See http://www.unece.org/trans/main/wp29/wp29wgs/wp29grrf/grrf-infevsc8.html working group 
papers on the development of electronic vehicle stability control systems for heavy vehicles. 

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4.2.1.2.2 Costs 

This proposal covers a large range of vehicle types and cost estimates for the addition of 
ESC vary from 400 to 1500 Euro per vehicle. This cost is likely to fall as these systems 
become standard equipment. For a vehicle already fitted with ABS braking (which would 
be  the  case  with  almost  all  vehicles  in  this  category)  then  there  is  unlikely  to  be  any 
increased maintenance cost. Therefore the €400-1500 figure represents the increased cost 
for a vehicle over its lifespan. In the EU there are approximately 425,000 goods vehicles 
over  3.5  tonnes  and  around  25,  000  buses  of  the type  likely  to  be  affected  by  the  ESC 
requirement registered every year. Assuming a vehicle lifespan of 13 years, the average 
additional  annual  cost  per  vehicle  would  be  would  be  in  the  range  €30-€115,  which 
would equate to €180-€675 million for the whole fleet.. Even using the higher of these 
figures, this still compares favourably with the estimated annual saving of €867 million. 
A summary of costs and benefits is given in Annex II, table 1.  

4.2.1.3.  Options for the Introduction of ESC 

Section 3.2 identified the following options: 

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

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

c) Establish technical standards and mandatory fitting requirements. 

Since it is clear that for both light and heavy vehicles there is a positive cost-benefit case 
for these systems, it appears that the mandatory option, option c), is justified. However, 
there may be certain cases on some specialised vehicles (such as low-volume sports cars) 
where  the  cost  of  developing  an  ESC  system  would  be  disproportionately  high  since  it 
would be spread over a small production run of vehicles; say, 50 compared with 500,000 
for  a  volume  production  car.  However,  these limited  cases  can  be  dealt  with  under  the 
small series exemptions of the Framework Directive.8 Consultation with stakeholders has 
indicated that 2012 is a realistic date for introduction of mandatory ESC for new vehicle 
types. Longer lead times may be appropriate for some specialist vehicles. 

4.2.2.  Advanced Emergency Braking Systems (AEBS) 

4.2.2.1.  Benefits 

Work  carried  out  for  DG  Enterprise  by  TRL  has  indicated  that  there  are  significant 
casualty  savings  to  be  obtained  by  equipping  vehicle  with  these  systems.  The  level  of 
casualties saved depends on the type of vehicle and the level of capability of the system. 
Current systems do not always avoid collisions, but they ensure that the collision takes 
place at a slower speed thus mitigating injuries. Future systems should be able to avoid 
collisions altogether, including may collisions with pedestrians. The TRL work indicates 
that  the  highest  benefit  to  cost  ratios  are  likely  to  be  achieved  through  fitting  these 

8 

See Articles 22, 23 and 24 of Community Directive 2007/46/EC. 

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systems  to  heavy  vehicles  due  to  the  increased  severity  of  front  to  rear  collisions 
involving these vehicles.  

Table  4  Range  of  annual  benefits  for  AEBS  for  various  classes  of  vehicle  (TRL 
study)9  

In table 4. “Current” systems can be defined as systems that are effective in front to rear 
shunt  collisions  with  other  vehicles  with  four  or  more  wheels  and  collisions  with  rigid 
fixed objects on the carriageway. “Near future” systems may be expected to add function 
in collisions with rigid fixed objects off the carriageway and with pedestrians. “Longer 
term  future  developments”  may  be  expected  to  add  functionality  in  head  on  collisions 
and front to side collisions at junctions. 

The 'break even cost' is the maximum the system could cost while still remaining cost-
effective  in  terms  of  casualty  reduction  potential.  Most  current  systems  are  not 
considered  effective  at  preventing  collisions;  only  in  mitigating  them.  Therefore  for  a 
heavy  truck,  the  system  would  possibly  need  to  cost  under  €  314  to  have  a  positive 
benefit. However, future systems with a wider capability are seen as having a far greater 
casualty prevention potential, and this would considerably raise the amount that could be 
spent on installing such a system (around €136 -966 for a passenger car and €1700-12000 
for an M2 or M3 vehicle (bus or coach).  

4.2.2.2.  Costs 

These systems combine advanced braking systems with sensing technologies using radar 
or laser. According to industry sources current systems cost over €1,000 per vehicle, but 
the technology cost is reducing  rapidly, and  will reduce  further as  volume  increases.  A 
recent estimate10 suggests  that  once standard fitment  has  been  achieved  in  main-stream 
models at 1 million units a year, a laser-based system can be installed for around €200 to 

9 

10 

Automated  Emergency  Brake  Systems:  Technical  requirements,  Costs  and  Benefits,  see 
http://ec.europa.eu/enterprise/automotive/projects/index.htm  
Automotive News Europe, June 11 2007. 

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€250  per  car  for  hardware,  software  and  installation.  Thus,  these  will  be  highly  cost-
efficient, as their cost will be considerably below the break-even cost presented in Table 
4. above. Also, once a vehicle has been fitted with ESC the additional hardware cost for 
an AEBS system is relatively low, and is unlikely to be very dependant on the category 
of vehicle. In Annex II, table 1, a mid-range assumption of €1,000 for a system cost is 
used (assuming the vehicle is already equipped with ESC). At this cost, the benefit/cost 
ratio is less than 1 for cars, but more than 2 for heavy vehicles. As these systems become 
more widely available, costs are likely to decrease significantly. 

4.2.2.3.  Options for the Introduction of AEBS 

As with ESC, the options identified are as follows: 

a) 

b) 

Do nothing and allow the market to take the initiative. 

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

c) 

Establish technical standards and mandatory fitting requirements. 

As  such  systems  are  rapidly  becoming  cost-effective,  particularly  on  vehicles  already 
equipped with ESC, Option c) is the right approach provided that the legislation foresees 
a transitory period of several years and that the systems are initially fitted only to heavy 
goods  vehicles  and  buses.  Unlike  ESC,  the  cost–benefit  balance  for  AEBS  is  more 
favourable for heavy vehicles than for light vehicles. This apparent contradiction is due 
to  the  fact  that  ESC  tends  to  be  quite  expensive  for  heavy  vehicles  (due  to  the  large 
number  of  axles  and  the  relatively  low  production  volumes).  However,  the  additional 
cost  of  equipping  a  heavy  vehicle  with  AEBS,  once  ESC  has  already  been  fitted,  is 
relatively low since the sensors can be produced in high volumes and at a similar cost to 
the  sensors  used  for  cars.  Thus  the  cost  of  fitting  AEBS,  as  a  percentage  of  the  whole 
vehicle cost, is relatively low for larger vehicles.  

Based  on  the  feedback  from  system  suppliers  following  the  internet  consultation,  a 
realistic implementation date for these categories of vehicles may be around 2013. At a 
later  stage  it  should  be  assessed  whether  mandatory  installation  of  these  technologies 
should be extended to light-duty vehicles and passenger cars. 

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4.2.3.  Lane Departure Warning Systems. 

4.2.3.1.  Benefits. 

The COWI report referenced in 4.2.1.1.1 also examined the costs and benefits of LDW 
systems  using  the  same  methodology  as  for  ESC  systems.  The  accident  prevention 
potential of combined LDW and LCA systems, has been estimated at 25% for head on 
collisions,  25%  for  left  roadway  accidents  and  60%  for  side  collisions.  An  accident 
mitigation  effect  is  also  expected,  in  that  the  severity  of  accidents  is  shifted  down  a 
severity  class  -  i.e.  from  fatality  to  severe  injury  and  from  severe  to  slight  injury.  The 
mitigation effect is 25% for head on collisions, 15% for left roadway accidents and 10% 
for  side  collisions.  If  all  vehicles  were  fitted  with  LDW  and  LCA  this  could  result  in 
annual  EU-wide  savings  of  5500  deaths,  30,800  serious  injuries  and  208,500  slight 
injuries, equivalent to an annual cost saving of 14,824 million Euro.  

4.2.3.2.  Costs 

The  COWI  report  assumed  an  increased  cost  per  vehicle  of  €600  to  include  the 
installation  of  both  LDW  and  LCA  systems.  Using  the  above  benefit  data,  this  would 
suggest a benefit/cost ratio of 1.7. Using more recent EU registration data (see Annex II) 
suggests a slightly lower figure of 1.1. However, a lot of the hardware could probably be 
shared  with  other  systems  (such  as  AEBS)  which  could  significantly  reduce  the  cost. 
Therefore this figure is probably conservative.  

4.2.3.3.  Options for Lane Departure Warning Systems. 

As with ESC and AEBS, the following options are identified: 

a) 

b) 

Do nothing and allow the market to take the initiative. 

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

c) 

Establish technical standards and mandatory fitting requirements. 

The benefit/cost balance is not as favourable as for ESC, and it is likely that such systems 
will be more  cost  beneficial on  heavy trucks than on cars (due to the lower  cost of  the 
system as a proportion of the vehicle cost, the greater problem of blind spots on larger 
vehicles,  their  greater  distance  travelled  and  the  more  serious  consequences  of  an 
accident  concerning  large  vehicles).  Further  work  is  being  carried  out  for  the 
Commission  which  will  examine  the  costs  and  benefits  in  more  detail  in  relation  to 
different  vehicle  classes.  Even  on  the  current  evidence,  there  appears  to  be  a  case  for 
introducing mandatory LDW/LCA at least on heavy goods vehicles and buses, since the 
COWI  report  indicates  that  introduction  of  such  systems  through  market  mechanisms 
alone is likely to be very slow. Since these systems may use similar sensing hardware to 
AEBS system, it would seem logical to introduce them on a similar timescale.  

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4.3. 

Tyres and Tyre Systems  

4.3.1.  Tyre Noise 

The FEHRL report mentioned in section 1.3.1 considered the costs and benefits involved 
in  tightening  the  tyre  noise  limits.  A  major  part  of  this  study  involved  analysis  of  the 
noise performance of existing tyres on the market, to assess the feasibility of tightening 
the  noise  limits  in  the  future.  Table  5  shows  the  percentage  of  tyres  tested  which  were 
able to meet the existing levels with margins of 3dB(A) and 5 dB(A). 

Table 5. Performance of current tyres in relation to existing limit values 

Category 

Percentage  ≥  3  dB(A) 
below  

Percentage  ≥  5  dB(A) 
below 

C1b 

C1c 

C1d 

C1e 

C2 

C3 

68 

45 

66 

57 

50 

75 

10 

5 

19 

16 

13 

53 

On the basis of the above results, and further comparisons which indicated no significant 
relationship  between  noise,  wet  grip  or  rolling  resistance  on  the  tyres  tested,  FEHRL 
concluded that it was feasible to introduce new limits in the order of 5dB(A) lower than 
the  existing  limits.  Taking  into  account  the  normal  product  cycle  of  tyres,  it  was 
suggested that a date of 2012 was feasible  for the introduction of the new noise limits, 
with a possible interim step in 2008. The FEHRL report also suggested a number of other 
changes, including: 

•  A realignment of the width 'bands' to recognise the increased average width 

of modern car tyres  

•  A change in the method of 'rounding' the raw measurement data to give the 

final approval figure 

•  Recommendations  to  introduce  testing  of  wet  grip  and  rolling  resistance  to 
ensure that future tyre designs to not sacrifice these qualities in the pursuit of 
lower noise levels 

•  Recommendations on changes to the test surface and measuring procedures 

•  Increased consumer awareness through a labelling scheme 

Options  concerning  the  introduction  of  new  limits,  the  realignment  of  width  bands, 
changes to the rounding procedure and a possible labelling scheme are discussed later in 

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this section. Requirements concerning wet grip and rolling resistance are covered in other 
sections.  Changes  to  the  test  procedure  and  the  test  surface  will  be  discussed  in  the 
context  of  possible  changes  to  UNECE  Regulation  117,  since  the  proposed  Regulation 
would refer to the Regulation 117 test procedure. 

4.3.1.1.  Benefits from Reduced Tyre Noise 

The  benefits  of  tyre/road  noise  reductions  were  calculated  using  a  valuation  that  was 
established by the EU Working group on Health and Socio–Economic Aspects in 2003. 
This put a value of noise reduction to households of 25 Euro per dB per household per 
year.  This  figure  is  lower  than  figures  used  in  some  national  studies  in  the  wealthier 
Member  States,  and  therefore  could  be  considered  to  be  conservative.  However,  the 
figure was reached by a wide consensus of academics for use across the EU with input 
from national governments and industry. The FEHRL report adjusted this 25 Euro figure 
to  27  Euro  to  reflect  the  growth  in  per  capita  GDP  between  2003  and  2006.  The 
estimated number of households in the EU 27 is around 215 million. Therefore the total 
benefit across the EU 27 would be  

27 X 215 million = 5805 million Euro per dB per year. (say 5.8 billion Euro)  

As  indicated  in  the  previous  section,  FEHRL  considered  that  proposed  noise  limit 
reductions  per  tyre  of  around  5  dB(A)  were  feasible  so  this  figure  formed  the  basis  of 
calculations to determine the effect on the general public. A noise reduction of 5 dB (A) 
per tyre does not mean that the noise reduction perceived by a person (for example, at the 
roadside or in a nearby building) would be 5 dB(A). This is due to a number of factors: 

•  Even if the noise limit is reduced by 5 dB(A) this does not mean the average 
noise  value  per  tyre  is  reduced  by  the  same  amount.  This  is  because  some 
tyres already meet the proposed limits as it would be technically difficult (or 
impossible) for them to improve by another 5 dB(A). The likely result is that 
the distribution of tyre noise values will become narrower, on average around 
3 dB(A) below current values. 

•  Due to the variations between test road surfaces and actual road surfaces, the 
reductions in tyre noise values may not always be reflected in reductions in 
actual tyre road/noise values.  

•  The  other  sources  of  noise  from  the  vehicles  also  need  to  be  taken  into 

account. 

These  factors  are  discussed  in  detail  in  section  5.3  of  the  FEHRL  report,  which  also 
describes  two  mathematical  noise  models  which  have  been  developed  for  use  in  traffic 
noise calculations and noise mapping in European towns and cities; HARMONOISE and 
TraNECam. Both these models were used to predict the noise benefits achieved for the 
population as a result of the proposed tyre noise limits. Predictions were made for a range 
of scenarios from motorways to congested urban conditions. It was concluded that there 
was considerable agreement between model predictions, leading to greater confidence in 
the predictions made. However, there were some relatively small differences between the 
noise  level  reductions  predicted  by  HARMONOISE  and  TraNECam,  so  the  results  of 
both models were considered as conservative and optimistic assumptions respectively. 

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Based  on  the  two  models,  FEHRL  assumed  a  lower  value  of  0.9  dB(A)  and  an  upper 
value of 2.3 dB(A) for the overall average traffic noise reduction resulting from the tyre 
noise limits for C1 tyres only. There would be greater benefits than this if the proposal 
covered C1, C2 and C3 tyres. 

4.3.1.2.  Valuation of benefits from new noise limits for C1 tyres 

The valuation of 5.8 Billion Euro/dB/annum from section 4.3.1.1 needs to be multiplied 
by the actual noise reduction in dB(A) that would occur in real traffic. This then provides 
the  annual  benefit  to  the  public  across  the  EU27  of  the  proposed  new  noise  limits,  in 
2006 Euro values. 

(i) Using the 0.9 dB(A) estimate: 

Annual benefit = 

5.8 billion Euro/dB/annum x 0.9 dB(A) 

Annual  benefit  to  EU27  of  proposed  new 
noise limits using 0.9 dB(A) estimate = 

5.22 billion Euro/annum 

(ii) Using the 2.3 dB(A) estimate: 

Annual benefit = 

5.8 billion Euro/dB/annum x 2.3 dB(A) 

Annual  benefit  to  EU27  of  proposed  new 
noise limits using 2.3 dB(A) estimate = 

13.34 billion Euro/annum 

Taking (i) and (ii) together:  

Estimate  of  the  annual  benefit  of  the 
proposed new noise limits = 

5.22 -13.34 billion Euro/annum 

This  is  a  simplified  analysis  of  the  benefits  achievable  from  a  reduction  in  the  limit 
values of 5dB per tyre. A more detailed analysis of the benefits over time is provided in 
section 7.5.2 of the FEHRL report. This predicts a total benefit of 48-123 billion Euros 
for the EU25 over the period of 2010 to 2022. Adjusting this figure to the EU27 gives a 

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total benefit of around 50-129 billion Euros. The summary table in Annex II gives values 
for the benefit per car, based on a mid-range annual benefit of 9bn Euro/annum. 

4.3.1.3.  Costs of Tyre Noise Reductions 

Any costs for compliance with the proposed changes to the Directive are assumed to be 
borne by the following stakeholders: 

Any increased costs for the original tyre, due to extra material or labour costs, or extra 
research and development, would initially be borne by the tyre manufacturer, but would 
be passed on to the consumer either directly (in the case of after market tyres) or via the 
vehicle manufacturer (in the case of original equipment tyres) 

Any increase in running costs (such as increases in fuel consumption or increased wear) 
would be borne directly by the consumer. 

The  FEHRL  report  concluded  that  35%  of  C1  tyres  on  sale  in  2000-2005  already  met 
noise  limits  around  4.5-5  dB(A)  below  the  current  level,  that  is  to  say,  the  noise  level 
reductions  assumed  when  calculating  the  benefits  described  in  the  previous  paragraph. 
This would indicate that the research and development to meet the new noise limits has 
already been carried out by the manufacturers, and tyres achieving the new noise limits 
are  apparently  being  mass  produced  without  difficulty,  and  are  price  competitive  with 
non-compliant tyres.  

Other requirements of tyres, such as safety and visual appeal, must already have achieved 
levels that are satisfactory both to sellers and buyers. There was also no evidence from 
any  available  literature  that  tyres  meeting  the  lower  noise  level  suffered  significantly 
from  any  reduced  durability  or  increased  rolling  resistance.  Therefore  it  could  be 
concluded that there are unlikely to be any increased running costs for the consumer.  

FEHRL concluded that the only major cost to manufacturers would lie in discontinuing 
production of any tyre lines that did not meet the proposed noise limits. The tyre industry 
has indicated that there are around 6,000 tyre lines on sale at any one time. Therefore we 
consider  that  there  is  unlikely  to  be  an  undersupply  of  the  market  due  to  such 
discontinuation,  though  there  is  a  danger  that  customer  choice  could  be  reduced, 
particularly in some 'niche' markets. There would of course be tooling costs for replacing 
tyre moulds, but given that the time-span for introduction of these requirements is likely 
to  be  around  8  years,  this  should  fit  in  with  the  normal  product  replacement  cycle 
(bearing in mind that not all tyre variants will need to be replaced). 

Although it could be claimed that the R&D effort has already been spent, since there are 
tyres in production that already meet the new limits, it is accepted that the limits will be 
more  difficult  to  meet  with  respect  to  some  types  of  tyre  than  with  others.  Also,  the 
normal  tyre  design  cycle  may  have  to  be  accelerated  in  order  to  meet  the  proposed 
deadlines, requiring extra research and development resources. This is discussed in detail 
in  section  7.6  of  the  FEHRL  report,  which  quotes  a  tyre  industry  estimate  of  2  billion 
Euro per annum to achieve this. It is difficult to provide an independent validation of this 
figure,  and  FEHRL  considers  it  to  be  an  over-estimate.  FEHRL  calculated  that,  on  the 
basis of industry–supplied figures stating that research and development expenditure was 
around 3.5-5% of sales in the EU, amounting to around 400million Euros, if the industry 

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were  to  increase  their  entire  research  and  development  over  the  transitional  period  by 
50%,  this  would  represent  an  extra  200million Euro  per  annum.  If  it  was  assumed  that 
this research was concentrated on developing original equipment tyres for new cars and 
this  cost  was  spread  across  the  entire  EU  sales  of  new  cars  (around  13  million  per 
annum) this would represent about 15 Euro per car. Alternatively, using the assumption 
that 33% of cars already meet the limit values, the extra costs may only fall on the 67% 
of tyres that do not, which would lead to a increase in cost per car of 22.5 Euros. 

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Table 6 Proposal for noise limits for C1 (car) tyres  

tyre 

Old 
(width in mm) 

class 

Old 
value 

(dB(A)) 

Proposed class  

Possible intermediate values 

Final values 

(width in mm) 

'Real'* 
reductions) 

Proposed 
value 

(dB(A)) 

Reductions 
compared 
with 
current 
values  

Proposed 
value 

(dB(A)) 

Reductions 
compared 
with 
current 
values  

'Real'* 
reductions)  

≤ 145 (c1a) 

72 

> 145 ≤ 165 (c1b) 

73 

≤ 185 ( C1A) 

73  

> 165 ≤ 185 ( c1c) 

74 

> 185 ≤ 215 ( c1d) 

75 

 >  185  ≤  215  ( 
C1B) 

74  

> 215 ≤ 245 ( C1C)  74  

> 215 (c1e) 

76 

> 245 ≤ 275 ( C1D)  75  

> 275 (C1E) 

77  

-1.0 

0 

1.0 

1.0 

2.0 

1.0 

-1.0 

0.5 

1.5 

2.5 

2.5 

3.5 

2.5 

0.5 

1.0 

2.0 

3.0 

3.0 

4.0 

3.0 

1.0 

71  

72  

72  

73  

75  

2.5 

3.5 

4.5 

4.5 

5.5 

4.5 

2.5 

* 

Currently, the 'raw' measurements are rounded down to the nearest whole number, then 1dB is subtracted to give the final approval value. The FEHRL proposal was to take the 
raw measurement and round it up or down to the nearest whole number to give the approval value. The effect of this would be to increase the difference between the old and 
new targets by, on average, 1.5 dB 

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4.3.1.4.  Options for Reducing Tyre Noise 

As  indicated  in  table  2,  the  options  of  doing  nothing  or  relying  on  market  forces  to 
reduce  tyre  noise  have  been  eliminated.  Other  measures,  such  as  improving  road 
surfaces, can be considered as part of an 'integrated approach' to reducing tyre noise, but 
such measures should be complementary to, and not replace, direct measures to reduce 
the tyre's contribution to the problem. The main issue to decide is the level of ambition of 
the proposed tyre noise levels and the associated timescale. 

4.3.1.4.1 C1 (car) tyres 

Table  6  proposes  two  sets  of  proposed  values  for  C1  (car)  tyres,  together  with  their 
reductions from the current values required by the 2001/43 Directive. The 'final' values in 
the right hand columns represent the '2012' proposals included in the FEHRL document. 
The 'intermediate' values in the middle columns represent the '2008' proposals included 
in the FEHRL report. These were included to allow a phasing-in of the requirements. It 
would not be practical to implement these requirements by 2008 as originally suggested, 
but  a  possible  option  would  be  to  ease  the  burden  on  industry  by  introducing  the 
intermediate  requirements  in,  say,  2012  with  the  final  requirements  following  in,  say 
2016.  

It should be noted that part of the proposal included in table 6 is the realignment of tyre 
width  categories  to  represent  more  accurately  the  distribution  of  tyres  on  the  current 
market.  It  is  more  difficult  for  wider  tyres  to  meet  low-noise  requirements  and  the 
existing  and  proposed  limits  reflect  this.  However,  it  has  been  argued  that  allowing 
higher  limits  for  wider  tyres  encourages  vehicle  manufacturers  to  specify  wider  tyres 
than are necessary for a particular vehicle. Clearly, a wider tyre increases the amount of 
road contact surface, and therefore offers a potential safety advantage. However, in many 
cases it could be argued that this safety advantage is only relevant beyond the limits of 
performance that the vehicle is designed for.  

Research carried out by the Transport Research Laboratory (TRL)11 in the UK proposed 
a different set of future noise limits, summarised in Table 7. This proposal would require 
the same limits for all widths of C1 tyre under the existing classification, but would allow 
an extra 2dB(A) for a new class of tyre wider than 245mm.  

The effect of this proposal would be particularly severe on tyres just under the 245mm 
threshold, and it might be necessary to adjust some of the limits or thresholds. However, 
the general principle of reducing the number of width categories from five to two may be 
worthy of further consideration.  

11 

Tyre/road  noise  –Assessment  of  existing  and  proposed  tyre  noise  limits  :  report  for  UK 
Department for Transport Watts et al, TRL May 2006, 
http://www.dft.gov.uk/pgr/roads/environment/research/cqvcf/tyrenoise/tyreroadnoisereport 

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Table 7 . TRL proposal for C1 noise limits 

Tyre Class  Width (mm) 

Limit values (dB(A) 

Current limit  

Proposed limit  

Reduction  

'Real' 
reduction 
table 5 footnote)  

(see 

C1a 

C1b 

C1c 

C1d 

C1e 

C1f 

≤ 145  

> 145 ≤ 165  

> 165 ≤ 185  

> 185 ≤ 215 

> 215 ≤ 245 

> 245 

72 

73 

74 

75 

76 

76 

71 

71 

71 

71 

71 

73 

1.0 

2.0 

3.0 

4.0 

5.0 

3.0 

2.5 

3.5 

4.5 

5.5 

6.5 

4.5 

EN 

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Table 8. Summary of Options for C1 Tyres 

Tyre width class 

Actual reduction in limit values (dB(A))  

Option a 

Option b  

(FEHRL 
recommended 
limits)  

(FEHRL  recommended  limits  -  2 
phase) 

Option c  

(TRL 
recommended 
limits) 

2012 

2010 

2014 

2012 

Possible 
implementation  date 
(new tyre types) 

≤ 145  

> 145 ≤ 165  

> 165 ≤ 185  

> 185 ≤ 215  

> 215 ≤ 245  

> 245 ≤ 275  

> 275  

2.5 

3.5 

4.5 

4.5 

5.5 

4.5 

2.5 

0.5 

1.5 

2.5 

2.5 

3.5 

2.5 

0.5 

2.5 

3.5 

4.5 

5.5 

6.5 

4.5 

4.5 

2.5 

3.5 

4.5 

4.5 

5.5 

4.5 

2.5 

37 

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EN 

 
  
Ultimately,  bearing  in  mind  the  scientific  evidence  that  a  limit  reduction  of  around 
5dB(A)  is  feasible,  and  the  increasing  evidence  on  the  adverse  health  effects  of 
environmental  noise  pollution,  it  would  be  difficult  to  justify  a  smaller  reduction  than 
this. However, there remain questions on timescale (and whether to go for a two-phase 
approach)  and  to  what  extent  wider  tyres  should  benefit  from  an  additional  allowance. 
Table  8  summarises  the  three  options,  based  on  the  above  discussion.  The  costs  and 
benefits of Option a are generally as described in 4.3.1.2 and 4.3.1.3. Option b would, in 
effect, be a delay of two years which would mean that two years of benefits arising from 
the  implementation  of  the  full  limits  would  be  lost.  On  the  other  hand,  the  longer 
introduction period would allow the industry time to integrate the new requirements with 
its  normal  tyre  replacement  programme  and  thus  reduce  the  costs  due  to  accelerated 
replacement. It could be argued that the ''intermediate' limit will have little actual effect, 
since,  according  to  FEHRL,  76%  of  tyres  meet  this  limit  already  and  most  new  tyres 
which are introduced around 2010 will be designed to meet the 2nd stage limits in order to 
enable a full design life of about 8 years to be achieved. Option c) is, in general, slightly 
more severe than Option a) so the costs and benefits would be slightly greater.  

4.3.1.4.2 Commercial Vehicle Tyres (C2 and C3) 

The FEHRL recommendations for noise limits for commercial vehicle tyres are given in 
Table 9A As with C1 tyres, two levels are proposed , shown on the table as 'intermediate' 
and 'final' thus allowing the possibility of a 2 phase introduction. 

Options for implementation for C2 and C3 are shown in Table 9B. As there are no width 
categories  within  these  classes  and  therefore  no  opportunity  to  adjust  these  categories, 
only two options are presented. As with the C1 category the two-stage option (option b) 
is likely to provide lower costs and lower benefits. It would  seem reasonable to follow 
the FEHRL proposed timetable for the introduction of the new requirements for new tyre 
types  (2012).  However,  due  to  the  large  number  of  tyre  lines  in  existence,  it  would  be 
necessary to allow a longer-than-normal transition period to allow existing tyre types to 
continue to be sold (say four years). 

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Table  9A  FERHL  recommendations  for  light  commercial  (C2)  and  heavy 
commercial (C3) tyres.  

Tyre 
class 

Category 
of use 

Limit values in dB(A)  

Current  

Intermediate requirements 

Full requirements 

Limit  Nominal 

Reduction 

Actual* 
reduction 

Limit  Nominal 

reduction  

Actual* 
reduction

C2 

Normal  

75 

 Snow 
(M+S) 

77 

 Special 

78 

C3 

Normal  

76 

Snow 
(M+S) 

78 

73 

74 

76 

73 

75 

2.0 

3.0 

2.0 

3.0 

3.0 

3.5 

4.5 

3.5 

4.5 

4.5 

71 

72 

74 

71 

73 

4.0 

5.0 

4.0 

5.0 

5.0 

5.5 

6.5 

5.5 

6.5 

6.5 

Special  

79 

77 

2.0 

3.5 

75 

4.0 

5.5 

* 

Currently,  the  'raw'  measurements  are  rounded  down  to  the  nearest  whole  number,  then  1dB  is 
subtracted  to  give  the  final  approval  value.  The  FEHRL  proposal  was  to  take  the  raw 
measurement  and  round  it  up  or  down  to  the  nearest  whole  number  to  give  the  approval  value. 
The effect of this is would be to increase the difference between the old and new targets by, on 
average, 1.5 dB. 

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Table 9B – Options for C2 and C3 tyres 

Actual limit reduction (dB(A) ) 

Option a) 

Option b) 

2012 

Possible 
introduction 
date 

C2 

Normal   5.5 

 Snow 
(M+S) 

Special 

6.5 

5.5 

C3 

Normal   6.5 

Snow 
(M+S) 

6.5 

Special   5.5 

2010 

2014 

3.5 

4.5 

3.5 

4.5 

4.5 

3.5 

5.5 

6.5 

5.5 

6.5 

6.5 

5.5 

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4.3.1.4.3. Additional Options 

The  possibility  of  noise  labelling  to  inform  consumers  of  the  noise  characteristics  of 
particular tyres has been raised. Although it is not considered that this could be a viable 
alternative to legislation, since there is little  customer incentive to buy low-noise tyres, 
there is a possibility that noise values, together with wet grip values, could be added to 
the CO2 label discussed in Section 4.3.2 to give the consumer a full range of information. 

In  addition,  it  has  been  suggested  that  retreaded  tyres  should  also  meet  the  noise 
requirements. Currently this would only affect after-market tyres since retreaded tyres are 
currently not allowed on new cars within the scope of type-approval. Also, there has been 
no  study  on  the  feasibility  of  applying  the  proposed  limits  on  retreaded  tyres.  The 
FEHRL study indicates that for retreaded tyres on heavy vehicles (the vehicles for which 
they are most often used) the values for retreaded tyres are 2-4 dB(A) noisier than new 
tyres  so  there  may  be  problems  with  the  feasibility  of  meeting  the  proposed  standards. 
Further investigation may be required in this area.  

4.3.1.5.  Further Analysis of Practical Noise Limits. 

Following  the  initial  consultation,  a  study  by  SP  Technical  Research  Institute  of 
Sweden12,  sponsored  by  the  Swedish  Government,  examined  the  rolling  noise  of 
currently available tyres in the C1, C2 and C3 categories. In the C2 and C3 categories; 
for which the FEHRL study had offered considerably less data than for C1 tyres, the SP 
data suggested that the 5.5-6.5 db(A) reductions proposed by the FEHRL study might be 
over-ambitious. In addition, for C3 tyres, it was suggested that there was a considerable 
difference between the noise emitted from tyres uses on the drive axle(s) and those used 
on the steering axles. Tyres used on the drive axles, often termed 'traction tyres' also tend 
to be approved as mud and snow (M+S) tyres. To allow continued use of these tyres, it 
would seem appropriate to allow an additional 2db(A) for traction tyres compared with 
standard tyres.  

Furthermore,  there  are  certain  tyres  which  used  for  heavy-duty  off-road  applications 
categories  which  would  have  difficulty  meeting  either  the  noise  or  rolling  resistance 
limits. It would seem reasonable to exempt these tyres (termed as 'professional off-road 
tyres') from the noise and rolling resistance requirements provided these were for genuine 
off-road  applications  and  not  for  normal  road-going  vehicles.  For  this  reason,  it  is 
suggested that such  exemptions  are  limited to tyres with a speed capability  of  no  more 
than 100km/hr. 

Taking  the  above  factors  into  account,  the  complete  table  of  proposed  limit  values  is 
given in Table 10. Column 1 gives the proposed values measured in the same way as in 
the current Directive (rounding down to the nearest whole number value and subtracting 
a tolerance of 1db(A)). Column 2 gives the proposed values using the rounding method 
proposed  by  FEHRL  (rounding  up  or  down  to  the  nearest  whole  number  with  no 
additional tolerance). 

12 

Jonasson,  Hans  (2007):  "Rolling  Noise  Emission  of  Tyres  –  A  Market  Survey".  SP  Report: 
2007:70, SP Technical Research Institute of Sweden, Borås, Sweden. 

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Table 10 – Summary of Proposed Limit Values  

Tyre Class 

Limit value (db(A) 

1.  Using  current  Directive 
Method 

2. Using FEHRL proposed 
method 

C1A (≤ 185mm) 

C1B (> 185 ≤ 215mm) 

C1C (> 215 ≤ 245mm) 

C1D (> 245 ≤ 275mm) 

C1E (> 275mm) 

C2 

C2 M+S 

C3 

C3 M+S 

70 

71 

71 

72 

74 

71 

72 

72 

74 

71 

72 

72 

73 

75 

72 

73 

73 

75 

'Professional  off-road  tyres'  meeting  certain  criteria  would  be  exempt  from  these 
requirements. 

4.3.2.  Tyre Rolling Resistance 

The  following  sections  analyse  the  costs  and  benefits  of  introducing  low  rolling 
resistance tyres across the vehicle fleet. The analysis is based on the results of the TNO 
study which concentrated on passenger cars. Passenger cars are seen as the first priority 
with respect to CO2 emission targets. However the use of low rolling resistance tyres on 
commercial vehicles is also discussed later in this section. 

There  is  currently  no  formal  definition  of  a  'Low  Rolling  Resistance  Tyre'  (LRRT). 
However, a draft international standard for a rolling resistance measuring procedure (ISO 
28580) is currently under preparation.  

4.3.2.1.  Calculation of Benefits at the Vehicle Level 

The  TNO  study  indicated  that  low  rolling  resistance  tyres  could  reduce  a  car's  fuel 
consumption by  between 1% and 5%  . As outlined in section 4.3.2.3 , one option is  to 
designate  tyres  into  rolling  resistance  'bands'  so  that,  say,  a  band  A  tyre  gives  the 
maximum  rolling  resistance  reduction  (corresponding  to,  say,  a  5%  fuel  consumption 
reduction)  and  a  band  D 
improvement 
(corresponding  to,  say,  a  1%  fuel  consumption  reduction)  Thus,  an  average  rolling 
vehicle fuel consumption reduction of 3% is assumed for the purposes of this analysis.  

the  minimum  permissible 

tyre  gives 

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42 

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Full details of the TNO analysis are given in section 5.3 of the TNO report. However, the 
main conclusions are that, based on an annual distance of 16,000 km, a car using LRRT 
would on average save 0.09 tonnes of CO2 per year (well to wheel). In the longer term , a 
TREMOVE13 analysis has predicted that the mandatory fitting of original-equipment and 
replacement  LRRT,  phased  in  from  2012,  would  result  in  a  total  reduction  of  CO2 
emissions  from  passenger  cars  of  1.45%  in  2020.  In  addition,  there  would  be  fuel  cost 
savings for the vehicle owner, depending the cost of fuel at the time. For a fuel cost of 
0.21€/l  (excluding  tax)  the  annual  saving  would  be  €7.  For  a  fuel  cost  of  0.60  €/l,  the 
annual saving would be €19. The actual fuel cost to the motorist will include tax, which 
would significantly increase the cost advantages of LRRT.  

4.3.2.2.  Calculation of Costs at the Vehicle Level  

The TNO study estimated the additional cost to the consumer of fitting a set of LRRT to 
a  vehicle  would  be  €60.  Assuming  a  typical  tyre  life  of  3  years  this  would  lead  to  an 
additional annual cost of €20. There was no evidence of any durability or safety penalty 
in purchasing LRRT, so the €24 would represent the total annual additional cost. For the 
tyre  manufacturers,  many  of  the  same  arguments  apply  as  for  tyre  noise.  LRRT  are 
already proven to be feasible but if a deadline is applied which prohibits the sale of non-
compliant  tyres,  there  may  be  additional  costs  to  the  manufacturer  in  accelerating  the 
replacement of such tyre types. 

4.3.2.3.  Options for Introducing Tyre Rolling Resistance Requirements 

4.3.2.3.1 Car Tyres 

As indicated in Table 4, it is possible to use the market mechanism as well as regulation 
to promote the use of LRRT. The TNO report suggests that 50% of new tyres already fall 
within  the  category  of  LRRT,  which  suggests  that  the  market  mechanism  is  already 
working to some extent. This is largely due to the fact that vehicle manufacturers like to 
achieve low fuel consumption figures for their products, and therefore have an incentive 
to  provide  energy–saving  tyres.  For  the  after-market,  there  is  unlikely  to  be  such  an 
incentive since other factors (such as purchase cost) are more likely to play a major role 
particularly  with  the  oldest  cars.  However,  the  development  of  a  tyre  grading  and 
labelling system to give consumers more information on the fuel consumption benefits of 
LRRT may be beneficial.  

An outline proposal on a banding system for LRRT is given in Table 11A below. (The 
number  of  bands  and  the  associated  threshold  levels  may  be  subject  to  further 
modification).  The  table  includes  indicative  figures  from  the  tyre  industry  on  the 
percentage market share over time of tyres in the various grades. (Band A represents the 
best performance level)  

Table 11A – Possible Grading System for Rolling Resistance (C1 tyres)  

Band 

Band 

Band 

Band 

13 

For background on TREMOVE see http://www.tremove.org/  

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A 

9.0 

Maximum 
resistance 
per band (kg/tonne)  

rolling 
coefficient 

%  Market 
share 

2004 

1.7 

2012 (est)   10.0 

2015(est) 

20.0 

B 

10.5 

14.8 

25.0 

26.7 

C 

12.0 

40.5 

35.0 

26.7 

D 

13.5 

33.8 

30.0 

26.7 

Although it is a reasonable assumption that market forces will tend to push tyres to the 
higher band categories, as indicated above, markets are difficult to predict and it may be 
necessary to include a legislative option to ensure that at least the worst performing tyres 
are removed from the market. Hence three options are proposed. 

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) 
the minimum (band D) standard mandatory for vehicle and component type approval. 

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

Option c) 

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

The costs and benefits for Options a and b are likely to be as indicated in sections 4.3.2.1 
and  4.3.2.2  above.  Option  c  may  incur  additional  costs  for  manufacturers  (likely  to  be 
passed  on  to  consumers)  if  the  level  of  difficulty  is  such  that  a  large  number  of  tyre 
designs have to be replaced over a short timescale. However, it is the option that provides 
the  greatest  degree  of  certainty.  It  is  also  the  only  option  that  lives  up  to  the 
Commission's  commitment  made  in  the  Commission's  communications  of  7  February 
200714 to ensure that a reduction of a further 10g CO2 /kg is achieved, over and above the 
130g  to  be  achieved  by  vehicle  technology  means.  Savings  due  to  tyres  supplied  as 
original equipment are already accounted for in the vehicle's CO2 rating. So it is only the 
tyres for the after-market that can contribute to the 10 g CO2 /kg target. Since these tyres 
will be fitted to all vehicles of the existing fleet, they have a potential for reducing CO2 
which  is  up  to  ten  times  higher  than  tyres  for  new  vehicles.  Thus,  Option  c)  is  the 
preferred option.  

14 

See http://eur-lex.europa.eu/LexUriServ/site/en/com/2007/com2007_0019en01.pdf 

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4.3.2.3.2 Commercial vehicle tyres. 

The options for C2 and C3 tyres are generally the same as for C1 tyres. However, there is 
limited data on the current rolling resistance performance of C3 tyres. Therefore a single 
limit rather than a grading system is proposed for this category of tyre. 

4.3.2.3.3. Labelling 

In order for options a and b in section 4.2.3.2.1 to work effectively it would be necessary 
to  introduce  a  clear  understandable  labelling  system  to  advise  the  end-user  on  the  best 
choice of replacement tyres with regard to fuel consumption (and hence CO2 emissions). 
Labelling has been used with respect to passenger cars (see section 11 of the TNO report) 
and  there  is  a  strong  argument  for  using  a  similar  system  for  tyres,  possibly  using  the 
same  seven-band  format  as  used  on  other  consumer  products.  The  addition  of  3  more 
bands would not seem to increase the costs of the labelling scheme. In fact, it is likely to 
present  an  incentive  for  manufacturers  to  move  to  the  higher  bands.  Thus  the  market 
share of band G tyres (see table 11B below) is likely to decrease somewhat faster over 
time than it otherwise would. Initial requirements could be introduced from 2012. At a 
later stage (say 2 years) it is envisaged that approvals to the lowest band would cease.  

Table 11B –Modified Grading System  

Tyre 
Category 

Maximum rolling resistance coefficient per band (kg/tonne) 

Band 

Band 

Band 

Band 

Band 

Band 

Band 

A 

4.5 

4.5 

B 

6.0 

5.5 

C 

7.5 

6.5 

D 

9.0 

7.5 

E 

10.5 

9.0 

F 

12.0 

10.5 

G 

13.5 

12.0 

C1 

C2 

It is estimated that the 3.3 g/km CO2 reduction figure quoted by TNO would correspond 
to a tyre falling between categories E and F in the above table. 

Further analysis of any labelling system would be needed. Therefore this proposal would 
be  limited  to  setting  minimum  requirements  for  type  approval.  Actual  requirements  for 
labelling will be introduced through other regulatory acts. 

The 2007 consultation proposed limit values of 13.5 for C1 and 12.0 for C2 (equivalent 
to  Band  G  in  the  table  above)  However,  further  research  presented  at  the  International 
Transport Forum15 suggested that lower values were achievable in the short term. Thus a 
first phase implementation of mandatory limits based on Band F would seem reasonable, 
followed by a minimum requirement of Band E as a second stage.  

15 

See http://www.internationaltransportforum.org/docs/SPnordwijk07.pdf 

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4.3.3.  Tyre Pressure Monitoring Systems 

4.3.3.1.  Benefits 

Tyre  Pressure  Monitoring  Systems  offer  benefits  in  terms  of  both  casualty  and  CO2 
reduction.  

4.3.3.1.1. Safety Benefits 

The study referred to in 4.3.1.1.1 indicated that if all cars were fitted with effective tyre 
pressure  monitoring  systems,  then  annual  savings  of  around  29  fatalities,  340  serious 
injuries and 3350 slight injuries could be foreseen. Applying the values in table 3 leads to 
annual  casualty  savings  of  €  155million.  Based  on  a  vehicle  stock  of  220  Million,  the 
saving comes to around € 0.7 per vehicle per year. 

4.3.3.1.2. CO2/ fuel saving benefits. 

The potential fuel saving benefits arising from the use of a TPMS system depends on the 
degree of under-inflation of tyres in current use, and the degree to which TPMS systems 
can address this. There are a number of studies ongoing in this area, which indicate that 
the under-inflation problem varies considerably between Member States. The TNO study 
(section 5.3) looked at the CO2 benefits of TPMS using a similar methodology to their 
analysis of LRRT. It estimated that an accurate TPMS system could generate fuel savings 
of 2.5%. Using an average car usage of 16,000 km the annual savings per car could come 
to between 6€ (assuming a fuel price of 0.21€ /litre) and 16 € (assuming 0.6€ /litre). In 
line  with  normal  cost-benefit  methodology  the  above  fuel  costs  do  not  include  indirect 
taxes. However, in reality the fuel cost to the motorist will include such taxes, thus the 
annual  fuel  cost  saving  due  to  the  use  of  TPMS  will  be  considerably  greater  than 
indicated above.  

The  associated  saving  on  CO2  would  be  0.09  tonnes  per  year  (well  to  wheel).  In  the 
longer  term,  a  TREMOVE  analysis  has  predicted  that  the  mandatory  fitting  of  TPMS 
systems  meeting  the  above  specifications,  phased  in  from  2012,  would  result  in  a  total 
reduction of CO2 emissions from passenger cars of 1.6% in 2020 and 2.3% in 2030.  

4.3.3.2.  Costs 

The TNO study assumed that the additional cost of fitting a TPMS tyre system to a car 
would  be  €  50.  However  TNO  suggests  this  cost  might  rise  by  around  25%  bearing  in 
mind that the accuracy of TPMS systems would have to improve over current levels in 
order  to  be  effective  at  improving  fuel  consumption  (although  the  present  level  of 
accuracy  will  still  yield  the  safety  benefits)  .  More  recent  information  received  via 
suppliers  suggests  that  the  current  cost  of  a  system  which  exceeds  the  current 
requirements  is  around  €  30,  Assuming  a  vehicle  life  of  13  years  and  no  additional 
maintenance  costs  this  works  out  at  €  2.3  per  vehicle  per  year.  Allowing  for  a  25% 
increase to ensure that future requirements are met, this still comes to just under €3 per 
vehicle per year.  

4.3.3.3.  Options for introducing Tyre Pressure Monitoring Systems 

The options identified from table 2 were as follows: 

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46 

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

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

c) Establish technical standards and mandatory fitting requirements. 

In the case of LRRT there was the additional manufacturer incentive to supply new cars 
with LRRT in order to reduce that vehicle's fuel consumption or CO2 emission rating and 
thus  comply  with  the  Commission's  future  target.  However,  this  would  not  apply  with 
TPMS  since  TPMS  does  not  affect  the  fuel  consumption  or  CO2  rating  of  a  new  car 
(since  a  car  will  be  tested  for  its  fuel  consumption  with  its  tyres  correctly  inflated). 
However,  TPMS  can  affect  the  fuel  consumption  of  a  car  in  'real  world'  driving 
conditions.  

Option a) would allow the continued use of TPMS systems to current standards, which 
may  yield  the  safety  benefits  described  in  section  4.3.3.1.1  but  are  unlikely  to  be 
sufficiently  accurate  to  yield  the  CO2  and  fuel  saving  benefits  described  in  section 
4.3.3.1.2.  Thus  a  cheaper  system  costing  €2.5  per  vehicle  per  year  would  only  provide 
the safety benefits of €0.7 per vehicle per year. Following the market approach (option a) 
would  encourage  cheaper  systems  which  would  give  little  or  no  fuel  consumption 
benefits and could in fact make things worse since a driver might be tempted to allow his 
tyre  pressures  to  fall  until  the  TPMS  alert  was  activated,  which  could  be  considerably 
below  the  normal  tyre  pressure.  However,  a  more  expensive  system  costing  €3  per 
vehicle  per  year  would  yield  the  full  benefits  of  between  €6.7  and  €16.7  per  year 
depending on fuel prices. Thus setting a higher standard (as in option b) would result in a 
net  benefit  to  the  driver  in  the  range  of  between  €3-13  even  before  considering  the 
environmental benefits. To maximise the benefits, and to ensure the maximum likelihood 
of reaching the CO2 reduction targets, option c) would be preferred. 

Subject  to  the  agreement  of  satisfactory  technical  standards,  it  is  envisaged  that  TPMS 
requirements  could  apply  from  2012  to  passenger  cars.  TPMS  for  other  vehicle 
categories  could  be  added  at  a  later  date,  subject  to  technical  feasibility  and  the 
development of appropriate standards. 

4.3.4.  Wet Grip Requirements 

4.3.4.1.  Benefits 

Generally,  it  is  considered  that  current  tyre  designs  offer  a  good  degree  of  wet  grip 
performance and there has been no identified need to increase this level of performance. 
Indeed, the wet grip procedure developed for car tyres in UNECE Regulation 117 (and 
which  is  proposed  for  this  regulation)  does  not  require  a  significantly  greater  wet  grip 
performance  than  current  tyres.  The  main  purpose  is  to  ensure  that  there  is  no 
deterioration  of  wet  grip  performance  as  a  result  of  designing  tyres  to  meet  low  noise 
and/or rolling resistance requirements.  

4.3.4.2.  Costs 

As  current  tyre  designs  are  considered  to  meet  the  proposed  requirements,  there  is 
unlikely to be any additional development or production cost involved in meeting the wet 

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grip  requirements.  There  may  be  costs  involved  in  meeting  the  noise  and  rolling 
resistance requirements without compromising the wet grip requirements but these costs 
would  be  attributed  to  the  noise/rolling  resistance  development  costs  covered  under 
sections 4.3.1.3 and 4.3.2.2. The only additional cost to the manufacturer is likely to be 
the cost of approval testing, which is estimated at €1,000 per tyre type. Even assuming a 
modest production run of 100,000 tyres per type, the resulting cost per tyre is €0.01, so 
the cost can be considered as negligible. 

Therefore it can be concluded that there are no additional cost or benefits of introducing 
wet  grip  requirements,  and  the  main  purpose  of  introducing  such  requirements  is  to 
maintain the 'status quo'. 

4.3.4.3.  Options for Introducing Wet Grip Requirements 

As indicated in table 2, it is considered that only the option of a mandatory requirement 
for wet grip for car tyres (on the basis of UNECE Regulation 117) should be considered, 
otherwise  there  is  a  risk  that  some  design  solutions  to  achieve  lower  noise  or  rolling 
resistance  could  result  in  a  reduction  in  safety.  There  is  no  evidence  of  the  need  for  a 
tighter  wet-grip  standard  than  the  Regulation  117  standard.  It  is  possible  that  the  tyre 
labelling  proposed  for  rolling  resistance  (and  possibly  noise)  could  indicate  if  the  wet 
grip  performance  exceeded  the  minimum  requirement.  This  additional  performance 
would  be  at  the  manufacturer's  discretion,  therefore  there  would  be  no  additional 
regulatory  cost  if  this  option  were  taken.  Thus,  as  far  as  the  minimum  regulatory 
requirements are concerned, the preferred option is to require all car tyres to meet at least 
the wet grip requirements of UNECE Regulation 117. Since most car tyres would already 
meet this requirement, it could be introduced with the minimum lead time (say 2 years 
from adoption of any Regulation). Work is under way to develop a standard for wet grip 
for C2 and C3 tyres which is likely to be incorporated into Regulation 117 in the future.  

5. 

MONITORING AND EVALUATION 

The  proposed  Regulation  will  take  effect  through  the  vehicle  type-approval  process. 
Vehicle  manufacturers  will  need  to  demonstrate  that  vehicles  comply  with  –  amongst 
other  things  –  the  test  requirements  specified  in  order  to  receive  a  type-approval 
certificate. 

Monitoring  of  the  effect  of  the  Regulation  is  effectively  undertaken  by  type-approval 
authorities who oversee in-use compliance  processes to ensure that the requirements of 
the  Regulation  are  met.  More  generally,  monitoring  data,  which  are  required  on  those 
tests specified for monitoring purposes only, will provide the necessary basis for further 
development of requirements, while also giving an indication of the wider success of the 
policy. 

6. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

6.1. 

Internet Consultation. 

An  internet  consultation  covering  outline  proposals  on  all  the  aspects  covered  by  this 
Impact  Assessment  was  carried  out  between  August  and  October  2007.  Around  80 

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were 

responses 
website 
http://ec.europa.eu/enterprise/automotive/index_en.htm  In  summary,  the  breakdown  of 
responses was as follows: 

received. 

available 

These 

the 

are 

on 

Twelve responses were from Member States, four were from non-MS governments, four 
from other (mostly regional ) government organisations, 29 were from industry/business 
organisations, 27 from NGOs, professional organisations and research groups and 5 from 
private  individuals.  There  was  general  support  for  most  of  the  measures  proposed. 
However, some of the main comments, and our responses, are given in table 12 below. 

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Table 12 – Summary of Internet Consultation Responses on Main Issues  

Comment 

Respondent (s)  

DG ENTR Response 

Simplification issues 

ACEA  and  some  member 
vehicle manufacturers 

regulation 

not 
New 
necessary. 
Simplification 
would  be  achieved  by 
referring 
to 
UNECE Regulations within 
Type-approval  Framework 
Directive  

directly 

Advanced Safety Issues 

Additional  safety  features 
should be mandated such as 
ISOfix,  seat  belt  reminders, 
Intelligent 
alcohol 
Speed 
Adaptation, 
Advanced lighting systems 

locks, 

Various 

Vehicle manufacturers 

CLEPA 
system/component 
manufacturers). 

(vehicle 

early 

Too 
systems such as AEBS 

to  mandate 

AEBS  possible  for  new 
types  of  heavy  vehicle  by 
2010, 
commercial 
vehicles  by  2012,  cars  by 
2014. 

light 

Tyre issues 

Proposed  noise  standards 
unfeasible  

Vehicle 
manufacturers 

and 

tyre 

Proposed  noise  standards 
not sufficiently ambitious  

Various 
organisations. 

environmental 

Rolling  resistance  banding 
unambitious  (will  not  drive 
market forward)  

Various 

safety 

Direct 
reference  would 
remove  the  EU's  power  to 
or 
improve 
environmental  requirements 
if 
relevant  UNECE 
Regulation  was  inadequate 
or could not be improved.  

the 

Features such as ISOfix and 
seat  belt  reminders  will  be 
mandated 
reference 
by 
UNECE  Regulations.  Other 
features  could  be  mandated 
under 
proposed 
Regulation  at  a  late  date, 
further 
to 
subject 
cost/benefit analysis. 

the 

Accept  need  to  set  realistic 
timescale  and  to  limit  the 
scope of application, at least 
initially, 
to  heavy  goods 
vehicles and buses. 

FEHRL  report,  supported 
by  TRL  and  M+P  reports, 
suggest proposal is feasible. 
the 
However,  we  accept 
lead 
need 
times 
allow 
manufacturers to comply. 

for  adequate 
to 

Accept  that  banding  will 
need  to  be  refined,  using  a 
seven 
system. 
band 
this  may  be 
However, 
a 
through 
implemented 

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50 

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TPMS (various estimates of 
required  level  of  accuracy, 
ranging from 10-25%) 

Various 

separate regulatory Act 

Required 
specifications 
will 
discussed 
Working Group level. 

technical 
for  TPMS 
at 

be 

6.2. 

Opinion of the Impact Assessment Board 

A draft version of the present impact assessment report was examined by the Impact 
Assessment Board (IAB). The opinion of the IAB formulated a number of 
recommendations on the draft impact assessment. These recommendations have been 
taken into account in the final document in the following way: 

Recommendation 1. Paragraph 1.2 has been expanded to explain how the safety 
measures not specifically covered under this Regulation are covered by other EU or 
UNECE legislation. Annex I has also been clarified in this respect.  

Recommendation 2. Paragraph 4.1 has been expanded to clarify how the move towards 
UNECE-based Regulations will aid simplification and competitiveness.  

Recommendation 3. A new Annex II has been added to provide a summary of the costs 
and benefits of the various features under discussion. In addition, a new Annex III 
provides a full analysis of the current situation concerning the European Automotive 
industry, plus a discussion about the possible impact of the proposals discussed in this 
Impact Assessment on retail prices and affordability.  

Recommendation 4. Paragraph 4 has been amended in each section to give approximate 
implementations times and, where appropriate, to explain why the market-mechanism is 
insufficient to achieve the desired safety and environmental objectives. In addition, the 
table in Annex II gives estimates of the percentage of new vehicles which are already 
fitted with the feature under discussion. 

Recommendation 5. Various references to research studies have been have been updated 
and expanded where appropriate 

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ANNEX I 

POTENTIAL CASUALTY SAVINGS ACHIEVABLE THROUGH VARIOUS 
TECHNOLOGIES. 

Avoidable Fatalities

Fatalities

Severe Injuries

Avoidable
Severe Injuries

Measures covered by this 
document

Measures covered by other 
existing or future proposals 

9000

8000

7000

6000

5000

4000

3000

2000

1000

0

Lane Departure Warning
Advanced Emergency Brake
ESC on Trucks
ESC on Cars

TPMS

Conspicuity Marking 
e-call Pan-European
Pedestrian Protection
ABS on Motorbikes II
Seat Belt Reminders

50000

45000

40000

35000

30000

25000

20000

15000

10000

5000

0

DRL

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ANNEX 
TECHNOLOGIES  

II  COMPARISON  OF  COSTS  AND  BENEFITS  FOR  VARIOUS 

Table 1. Advanced Safety Features 

Note: The following table gives an indicative comparison between the costs and benefits 
of various technologies. Due to the different source data used, some of the assumptions 
used (for example, on vehicle fleet sizes and casualty costs) may differ, so comparisons 
should be treated with caution). 

Electronic Stability Control  Advanced 

Emergency 

Braking 

Light 
vehicles  

Heavy 
vehicles  

Light 
vehicles  

Heavy 
vehicles  

Lane 
Departure 
Warning  

(all vehicles) 

Increase 
vehicle cost € 

in 

250 

1000 

1000 

1000 

600 

 Fatalities 
saved 
annum)_  

(per 

Serious 
injuries  saved 
(per annum)  

Slight  injuries 
saved 
(per 
annum) 

2250 

500 

7000 

1020 

5500 

23000 

2,500 

17000 

4280 

30800 

260000 

0 

-15000 

-1800 

208500 

Value 
casualty 
savings 
annum 
(Million €) 

Total 
vehicle 
year € 

of 

10, 802  

867 

9,213 

1608.9 

14, 824 

per 

127 

per 
per 

148 

54.5 

275 

84.7 

1651 

1926 

708.5 

3575 

1101 

Total  value  of 
casualties 
saved  though 
13 
year 
vehicle life € 

Present  value 
€ 

991 

Benefit 
Ratio 

/Cost 

3.97 

1155 

1.16 

425 

2147 

661 

0.43 

2.15 

1.1 

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Table 2 ;Summary of Tyre Measures (light vehicles only)  

Tyre 
proposal 

noise 

Rolling 
resistance 
proposal  

Wet 
proposal 

grip 

TPMS 

Increased 
cost 
(average) €

per 

technology 
vehicle 

15 

noise 
of 
Value 
reduction  (per  car  per 
annum) €

53.2 

CO2 
of 
Value 
reduction.(tonnes/year)

Fuel  savings  per  car 
per annum 

Casualty  savings  per 
car per annum €

- 

- 

- 

over 

tyre 
Savings 
lifetime (car lifetime for 
TPMS) 

159.6 

Present  value  (at  4% 
discount)  

142 

Benefit /cost ratio 

9.46 

60 

- 

0.09  

13** 

- 

39 

34.6 

0.53 

0 

- 

- 

- 

- 

- 

- 

1*** 

40 

- 

0.09  

11** 

0.7 

152.1 

91.3 

2.28 

** 
*** 

Average estimate. This value is sensitive to fuel cost. See section 4.3.2.1. 
No  technology  cost.  Approval  cost  can  be disregarded  when  spread  over  entire  tyre  production. 
Possible slight casualty reduction but this can not be quantified. 

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Table 3 – Effect on Initial Vehicle Cost  

Light vehicles € 

Heavy vehicles € 

Cost 
of 
technology 

Percentage 
of  vehicles 
currently 
fitted 

Cost 
of 
technology 

Percentage 
of  vehicles 
currently 
fitted 

Average 
increased 
cost 
vehicle 
(where 
mandatory)  

per 

Average 
increased 
cost 
vehicle 
(where 
mandatory) 

per 

Advanced  safety 
systems 

ESC 

AEBS 

LDW 

Total  advanced 
safety  

Tyres  

noise  

LRRT 

wet grip  

TPMS 

250 

1000 

600 

1850 

15 

60 

0 

40 

50 

0 

0 

50 

50 

95 

0* 

125 

1000 

optional 

1000 

optional 

600 

125 

2600 

7.50 

30 

0 

40 

30 

120 

N/A 

N/A 

10 

0 

10 

50 

50 

N/A 

N/A 

Total tyres 

115 

77.50 

150 

100 

Total/vehicle 

1965 

202.50 

2750 

900 

1000 

540 

2440 

15 

60 

N/A 

N/A 

75 

2515 

* 

Some TPMS systems are fitted, but do not meet the proposed standards.  

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Assumptions used in tables 1-3 

1) 

2) 

3) 

4) 

5) 

6) 

Annual cars registered in the EU = 13 million . 

Number of heavy duty vehicles subject to ESC requirements registered per year 
= 450,000 

Lifetime of a vehicle = 13 years. 

Lifetime of a tyre = 3 years  

Fuel costs used do not include taxes 

Some slight injuries will increase, due to serious or fatal injuries being mitigated 
to slight injuries. 

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ANNEX III 

CONSIDERATION OF THE PRODUCTION, EMPLOYMENT AND AFFORDABILITY EFFECTS OF 

THE PROPOSALS COVERED BY THIS IMPACT ASSESSMENT 

This  Annex  is  structured  into  two  parts:  the  first  provides  quantitative  data  and  a 
summary discussion of the main indicators for the automotive industry while the second 
engages  in  a  discussion  about  the  possible  impact  of  the  proposal  on  retail  prices  and 
affordability. 

1. 

Overview of the main production, sales, trade and employment indicators 

1.1. 

Production and sales of vehicles in the European Union 

Together with North America and Asia, Europe is one of the largest vehicle production 
locations  globally  as  well  as  one  of  the  main  automotive  markets  in  the  world.  The 
graphs below present the number of vehicles produced and sold in the European Union 
since 2004 together with a forecast for the 2012 and 2017 timeframe. 

Graph 1: Production of vehicles in the European Union16 

Numb e r  o f u n its

22,000,000

21,500,000

21,000,000

20,500,000

20,000,000

19,500,000

19,000,000

18,500,000

18,000,000

17,500,000

17,000,000

16,500,000

Source: Global Insight 

2004

2005

2006

2007

2012

2017

16 

Data  covers:  Austria,  Belgium,  Bulgaria,  Czech  Republic,  Finland,  France,  Germany,  Hungary, 
Italy,  Lithuania,  Netherlands,  Poland,  Portugal,  Romania,  Slovakia,  Slovenia,  Spain,  Sweden, 
United Kingdom. 

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Graph 2 Sales of vehicles in European Union 

Numb e r  o f u n its

19,500,000

19,000,000

18,500,000

18,000,000

17,500,000

17,000,000

16,500,000

16,000,000

Source: Global Insight 

2004

2005

2006

2007

2012

2017

As can be seen from the above, both vehicle production and sales in the European Union 
are  expected  to  increase  in  the  medium  term  perspective  and  the  Commission  does  not 
foresee that the current proposal will have an impact on this trend, which is impacted by 
a host of factors which are entirely independent of EU regulations in the field of vehicle 
safety (e.g. product planning, future market outlook, previous capital expenditure, labour 
costs, future marketing strategies of different vehicle manufacturers, agreements reached 
between  company  managements  and  employee  representatives  etc.).  Production  figures 
in 2012 and 2017 respectively are expected to be 8.7% and 10.2% higher than in 2007. 

Although  most  European  countries  are  involved  in  the  automotive  value  chain,  its 
relative  role  in  the  economic  structures  of  different  EU  Member  States  can  vary 
significantly. Given that the assessment of the potential economic and social impacts of 
legislative  proposals  should  provide  an  indication  of  possible  distributional  effects 
between  different  European  regions,  the  tables  below  show  the  break-down  of  vehicle 
production and sales by different Member States (including a forecast for the 2012 and 
2017 perspective). 

Table 1: Production of vehicles in the European Union by selected member states 

Austria 

Belgium 

Bulgaria 

2004 

2005 

2006 

2007 

2012 

2017

222,634 

230,794 

252,948 

237,353 

125,778 

100,627

525,156 

538,362 

560,215 

530,744 

702,950 

678,739

0 

0 

0 

0 

231 

257

Czech Republic 

446,320 

602,288 

851,988 

901,519  1,184,760  1,267,183

Finland 

France 

10,510 

21,644 

32,746 

24,184 

30,757 

32,894

3,652,427  3,535,162  3,153,186  2,977,140  3,190,728  3,196,215

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Germany 

Hungary 

Italy 

Lithuania 

5,559,861  5,751,353  5,811,062  6,197,594  6,582,612  6,521,372

117,184 

148,371 

187,770 

295,279 

334,960 

369,523

1,140,226  1,036,907  1,209,978  1,334,243  1,428,590  1,316,604

649 

1,256 

1,529 

1,970 

2,869 

2,922

Netherlands 

223,342 

156,584 

131,834 

110,574 

146,934 

130,586

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

590,476 

616,713 

718,504 

791,816 

977,560 

969,641

224,392 

219,455 

222,603 

174,194 

166,118 

175,035

122,185 

194,802 

213,589 

218,801 

555,526 

534,922

181,498 

177,511 

267,088 

520,430 

699,354 

719,988

131,761 

177,945 

153,126 

200,350 

119,389 

157,919

2,945,162  2,676,659  2,703,515  2,870,131  2,766,660  2,934,843

504,572 

498,931 

493,826 

513,070 

494,348 

507,613

United Kingdom 

1,854,873  1,801,618  1,648,522  1,709,331  1,750,036  1,936,583

Source: Global Insight 

Table 2: Sales of vehicles in the European Union by selected member states 

Austria 

Belgium 

Bulgaria 

2004 

2005 

2006 

2007 

2012 

2017 

349,850 

344,934 

346,554 

338,386 

346,911 

351,295

599,930 

600,345 

645,536 

649,962 

609,621 

588,626

25,785 

34,478 

45,422 

56,413 

76,370 

88,727

Czech Republic 

167,423 

171,990 

178,928 

196,136 

253,163 

289,775

Denmark 

170,557 

208,689 

225,630 

228,430 

237,928 

225,368

Estonia 

Finland 

France 

19,461 

23,433 

30,741 

39,644 

45,426 

47,859

164,102 

167,710 

166,225 

152,664 

169,966 

172,958

2,468,173  2,542,135  2,493,250  2,531,835  2,667,363 

2,674,008

Germany 

3,537,744  3,603,968  3,760,299  3,477,743  3,777,892 

3,851,811

Greece 

Hungary 

311,719 

293,186 

291,441 

305,445 

340,102 

354,286

235,629 

225,479 

206,345 

203,940 

252,084 

279,202

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Ireland 

Italy 

Latvia 

187,520 

212,171 

222,894 

235,849 

228,787 

217,754

2,522,000  2,489,233  2,590,332  2,743,041  2,562,713 

2,539,906

13,707 

19,750 

30,337 

42,677 

52,583 

58,721

Lithuania 

13,509 

16,025 

21,472 

30,937 

38,702 

44,163

Netherlands 

583,989 

544,481 

567,647 

595,506 

606,602 

590,250

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

366,892 

282,585 

295,008 

365,807 

522,705 

595,808

273,871 

277,743 

264,586 

266,842 

375,392 

401,052

180,567 

255,912 

294,649 

353,294 

418,759 

482,057

70,318 

74,642 

82,902 

90,482 

106,716 

116,546

71,115 

68,949 

68,078 

78,730 

86,792 

92,997

1,887,816  1,956,031  1,949,165 

1,924,662 

1,890,246

299,959 

314,951 

328,687 

347,896 

343,655 

338,146

United Kingdom 

2,953,401  2,821,500  2,727,607  2,774,841  2,810,868 

2,842,804

Source: Global Insight 

Finally, the current vehicle production situation in Europe is presented in Figure 1 below, 
Europe.
automotive 
which 

the  main 

production 

indicates 

sites 

in 

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Figure1 - Automotive production locations on the European continent 

Source: European Automobile Manufacturers Association (ACEA) 

The  main  conclusion  to  be  drawn  from  the  above  is  that  most  of  the  EU  countries 
currently hosting automotive industry production facilities are forecast to see production 
remain stable or increase in terms of output units. Biggest growth in output is expected to 
occur  in  the  new  Member  States  (particularly  Romania,  Slovakia,  the  Czech  Republic 
and Poland) while vehicle production is expected to see a slight decline in Austria, Italy, 
Sweden and, surprisingly, Slovenia. 

1.2. 

Trade performance 

Trade  in  automotive  products  makes  a  significant  contribution  (ca.  €  60  billion)  to  the 
European  Union’s  trade  balance.  This  is  demonstrated  by  graphs  3and  4  below,  which 
show  Europe’s  trade  performance  in  vehicles,  accessories  and  parts  by  both  unit  and 
values.
monetary 

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Graph  3:  Imports  and  export  EU-27  –  extra  EU-27  for  motor  vehicles,  tractors, 
accessories and parts expressed in number of units traded 

Num be r of units

250,000,000

200,000,000

150,000,000

100,000,000

50,000,000

0

Source: Eurostat 

2004

2005

2006

Im p o rt

Exp o rt

Graph  4:  Imports  and  export  EU-27  –  extra  EU-27  for  motor  vehicles,  tractors, 
accessories and parts expressed in value in Euros 

V a lue  in e uros

140,000,000,000

120,000,000,000

100,000,000,000

80,000,000,000

60,000,000,000

40,000,000,000

20,000,000,000

0

Source: Eurostat 

2004

2005

2006

Im port

E x port

Generally,  the  most  profitable  part  of  the  European  automotive  industry  is  the 
manufacture of larger, premium vehicles which accounts for ca. € 9 billion of the approx. 
€  15  billion  total  profits  made  by  the  European  automotive  industry.  This  trend  is  also 
reflected  in  trade  statistics  where  an  overwhelming  proportion  of  trade  revenues  from 
cars is earned from the export of petrol vehicles with an engine sizes of between 1,500 
and 3,000 cm3 and petrol vehicles with engine capacities over 3,000 cm3. Trade data for 
different vehicle segments as defined by engine type and size is presented in graphs 5 and 
6 below. 

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Graph 5: Imports and export EU-27 – extra EU-27 by engine type and size (units) 

Numbe r of units

2,500,000

2,000,000

1,500,000

1,000,000

500,000

0

Im ports  20 04

Exports  200 4

Im po rts  2 005

Exports  200 5

Im po rts  2 006

Exports  20 06

P etrol < =  1.000 CM³

P etrol  >  1.000 CM³ B UT < =  1.500 CM³

P etrol >  1.500 CM³ B UT < =  3.000 CM³

P etrol >  3.000 CM³

Dies el < =  1.500 CM³

Dies el >  1.500 CM³ BUT < =  2.500 CM³

Dies el >  2.500 CM³

Source: Eurostat 

Graph 6: Imports and export EU-27 – extra EU-27 by engine type and size (value) 

Value  in e uros

35,000,000,000

30,000,000,000

25,000,000,000

20,000,000,000

15,000,000,000

10,000,000,000

5,000,000,000

0

Imports  2004

Ex ports  2004

Imports  2005

Ex ports  2005

Imports  2006

Ex ports  2006

Petrol <= 1.000 CM³

Petrol  > 1.000 CM³ BU T <= 1.500 CM³

Petrol > 1.500 CM³ BU T <= 3.000 CM³

Petrol > 3.000 CM³

D ies el <= 1.500 CM³

D ies el > 1.500 CM³ BU T <= 2.500 CM³

D ies el > 2.500 CM³

Source: Eurostat 

The  fact  that  Europe  primarily  exports  medium  and  large  petrol  vehicles  is  related  not 
only  to  the  quality  of  European-produced  and  branded  vehicles  in  those  segments  but 
also to the fact that for high quantity mass market vehicles manufacturers tend to produce 
on,  or  close  to  the  markets  in  which  their  sales  take  place.  Consequently,  it  is  unlikely 
that  any  cost  increases  resulting  from  this  proposal  will  have  a  major  impact  on  the 

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ability  of  European  producers  to  continue  successfully  exporting  in  the  premium 
segments  because  in  many  cases  the  technologies  covered  have  already  been 
implemented in these segments (or are available as optional extras). 

It should also  be  noted  the  current  demand structure in emerging markets suggests that 
exporters of new  premium vehicles  generally have a customer base,  which is relatively 
price  insensitive  while  the  buyers  of  “mass  market”  vehicles  tend  to  be  very  price-
conscious, which suggests that added cost to mass-produced vehicles is unlikely to give 
European  producers  a  competitive  advantage  in  those  segments.  However,  given  that 
mass market products  are  more  likely to be produced in situ using  production facilities 
which do not correspond to those used for the European market, it is likely that the scope 
of any disadvantage would be reduced. On the other hand, it should also be noted that the 
competitive  advantage  which  safer  and  more  fuel  efficient  vehicles  could  provide  is 
likely  to  become  more  relevant  in  emerging  markets  with  the  passage  of  time  and  the 
creation of a larger middle-class customer base. Market experience in the mature markets 
(such as Europe) has shown that with increasing prosperity, consumers are willing to pay 
more vehicles with an enhanced safety performance. 

1.3. 

Employment 

Table 3 below presents the data for employment in the vehicle manufacturing and parts 
sector broken down by different Member States. 

Table  3:  Number  of  persons  employed  in  the-  manufacture  of  motor  vehicles  
and the manufacture of parts & accessories for motor vehicles 

MOTOR VEHICLES 

PARTS AND ACCESSORIES 

2003 

2004 

2005 

2003 

2004 

2005 

31,774 

29,336 

28,890 

10,770 

11,353 

11,323

142 

207 

c 

c 

c 

c 

c 

c 

c 

2,151 

2,070 

2,675

57,072 

62,788 

:

c 

c 

3,904

526,057 

526,934 

516,639 

300,991 

304,748 

309,401

99 

247 

103 

291 

136 

1,283 

1,310 

299 

2,572 

2,500 

: 

1,467 

1,081 

: 

949 

1,297

2,627

815

77,327 

75,100 

74,551 

72,629 

73,160 

70,591

172,121 

168,200 

167,536 

86,589 

82,752 

79,587

59,462 

66,533 

67,599 

87,934 

84,395 

83,355

Belgium 

Bulgaria 

Czech Republic 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Italy 

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Cyprus 

Latvia 

Lithuania 

Hungary 

0 

172 

66 

0 

0 

0 

20 

147 

159 

227 

168 

387 

151 

236 

208 

128

362

269

9,977 

10,338 

9,575 

27,989 

28,669 

30,735

Netherlands 

10,589 

10,471 

9,789 

6,080 

4,620 

4,631

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

15,484 

16,999 

16,758 

10,990 

13,142 

13,344

24,253 

26,696 

28,405 

55,926 

68,928 

73,207

8,046 

6,740 

6,682 

11,521 

12,376 

13,018

c 

2,410 

c 

c 

c 

c 

16,262 

39,828 

46,619 

42,110

2,997 

3,359 

c 

3,870

c 

9,954 

10,636 

11,060

2,871 

2,110 

2,194 

800 

757 

784

45,247 

48,273 

50,114 

26,246 

27,345 

26,247

United Kingdom 

95,054 

89,278 

85,898 

95,012 

88,471 

80,982

Total 

1,081,398 

1,079,223 

1,085,584 

910,478 

928,183 

866,322

Source: Eurostat 

It should be noted, however, that the data above does not present the full picture of the 
automotive value chain a graphical expression of which has been presented in Figure 2 
below.  

Figure 2: The automotive value chain  

Raw materials 
provision (e.g. 
steel, rubber 
etc. 

3rd tier 
suppliers 
(parts and 
components) 

2nd tier 
suppliers 
(system 
specialist) 

1st tier suppliers 
(system 
integrator, 
module supplier 

OEMs 

(Final Product) 

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Finance 

Servicing 

Energy 

Aftermarket
(parts) 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Given that a number of automotive production related activities are not reflected in the 
statistical  classification  as  presented  in  the  above  table  (e.g.  electrical  equipment  for 
engines and vehicles, steel and aluminium production, paints, tyres, synthetic and textile 
products,  servicing  and  repair  etc.)  one  can  safely  assume  that  the  whole  automotive 
value chain provides employment for significantly larger number of people.  

It should also be noted that automotive suppliers account for circa 2/3 of the final product 
and over 50% of research in this sector. Effective supply chain management is one of the 
key  competitive  advantages  of  the  European  industry  while  production  of  advanced 
components is an important strength of the European supply industry. As suppliers play 
an increasing role in the value chain over time, increased vehicle value is often viewed as 
a key avenue for future growth in the supplier industry, particularly given that Europe is 
well represented with specialist suppliers. Given that the proposal is expected to further 
increase the value of vehicle components included in the final product, it is likely that the 
proposal could lead to a rise in direct employment depending on what share of extra costs 
were to go into extra labour. 

It should be borne in mind that the additional features proposed by this legislation do not 
require  the  development  and  introduction  of  revolutionary  new  technologies  but  relate 
rather to the further proliferation of already available technologies throughout the entire 
vehicle  fleet.  Consequently,  it  is  not  expected  that  this  proposal  will  create  a  dramatic 
technological shift but will rather pose the question of how available technologies are to 
be introduced into the lower segments of the market.  

There is currently a substantial consolidation process under way in the supplier industry 
despite the fact that the suppliers’ volume of production has more than doubled over the 
last 10 years (due to continued outsourcing of manufacturing and services by end-product 
manufacturers  and  an  increasing  number  of  vehicle  fittings  many  of  which  are  also 
purchased externally). There are a number of reasons for this process which, among other 
things, reflect the heterogeneity of the suppliers (small-and medium sized suppliers have 
experienced  difficulties  in  accessing  capital,  there  has  been  significant  downward 
pressure  on  prices  initiated  by  manufacturers  seeking  to  cut  costs,  passing  higher 
commodity prices on to consumers has at times been difficult for a number of component 
manufacturers, competition between suppliers has intensified etc.) but the overall effect 
has been increased pressure to rationalise the market and promote mergers17.  

2. 

Affordability and impact on retail prices 

The main issue regarding the impact of new legislation on affordability usually concerns 
smaller  vehicle  categories.  This  is  the  case  because  it  is  assumed  that  larger,  premium 
vehicles will already contain many of the new features introduced by legislation and will 
hence be less effected than lower sections of the market. Additional concerns are raised 
because the larger profit margins of larger vehicles should enable for an easier absorption 
of  additional  costs  while  purchasers  of  bigger  and  more  expensive  cars  are  also  better 
positioned  to  pay  increased  retail  prices  should  costs  be  directly  passed  on  to  the 

17 

A study by Mercer Management Consulting and Fraunhofer Gesellschaft foresees that despite the 
expected  substantial  expansion  in  production  and  added  value  in  the  industry,  the  number  of 
independent  component  manufacturers  worldwide  will  decrease  from  5,600  in  2000  to  2,800  in 
2015. 

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consumers. Finally, discussions about affordability stress the higher proportional impact 
on the total price of the car in smaller (and cheaper) vehicle segments as well as raising 
the issue of purchasing power where it is assumed that households with smaller incomes 
tend to buy smaller new cars. This section will give some consideration to these issues in 
the light of the proposed legislation. 

2.1.  Different vehicle segments 

Some of the options discussed in section 4 of the Impact Assessment would make several 
features which are currently optional, mandatory. This would, first and foremost, impact 
smaller vehicles as well as having a different impact on different Member States where 
different  technologies  have  penetrated  the  market  to  varying  degrees.  Table  4  below 
provides  a  summary  of  the  assumed  additional  cost  to  new  vehicles  assuming  that  the 
options for mandatory fitting were chosen. 

Table 4: Ex-ante additional cost assumptions of the proposal 

Advanced  Vehicle  Safety 
Features and Tyres 

Electronic Stability Control 

€12518 

Advanced 
Breaking 

Emergency 

€25019 

Lane Departure Warning 

€60020 

Low  Rolling  Resistance 
Tyres/noise/wet grip 

€60 

Tyre  Pressure  Monitoring 
Systems 

€30 

From  an  affordability  perspective  the  effect  on  different  vehicle  segments  is  highly 
relevant  because  profitability  cushions  to  absorb  additional  compliance  costs  vary 
substantially between segments while the cost of complying with regulatory requirements 
will also vary for vehicles in different sections of the market. Table 5 below presents the 
profit estimates per vehicle segment. 

SEGMENT 

ESTIMATED PROFIT PER 
VEHICLE 

Small (e.g. Renault Clio, Peugeot 107) 

Compact (e.g. Audi A3, Citroen C4) 

Medium 

(e.g.  BMW  3  series,  Skoda 

€150 - €400 

€650 - €900 

€900-€1500 

18 

19 
20 

Average cost across the car fleet assuming that 50% of new cars are already equipped with ESC 
and that all cars are fitted with anti-lock breaking systems (ABS). 
Assumes that new cars are already equipped with ABS and Brake Assist. 
Assumes that new cars are already equipped with Advanced Emergency Braking Systems and that 
some sensors can be shared between the systems. 

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Octavia) 

Large  (e.g.  Mercedes  E-Class,  BMW  5 
series) 

€2600-€2700 

Source: A.T. Kearney 

There  is  hence  little  doubt  that  premium  segment  vehicles  are  better  positioned  to  pass 
additional costs on to consumers.  

2.2.  Additional considerations regarding retail price developments 

From  an  affordability  perspective  therefore,  the  primary  question  relates  to  the 
development  of  costs  over time  and the  extent to  which  companies will  choose to pass 
costs on to their customers. Three main considerations should be borne in mind: 

•  Economies  of  scale:  the  building  up  of  production  capacities  and  volumes  for 
different  products  is  an  important  part  of  the  automotive  industry’s  modus  operandi 
because this represents one of the most effective means of cost reduction. The cost of 
diesel  particulate  filters  which  have  undergone  a  significant  decrease  with  increased 
market penetration and production volumes offers a good example. Much of the actual 
future price impact will depend on the speed with which such economies of scale are 
achieved.  This  consideration  is  very  relevant  to  this  legislative  proposal  given  that 
most  the  technologies  covered  by  the  proposal  are  already  on  the  market  and  have 
been of production for some time. Furthermore, the automotive industry has for long 
been aware that legislation will be proposed with regard to the issues covered given 
that the proposed technologies were discussed in the CARS 21 High Level Group. 

•  Initial investment retrieval interval: cost pass-through to consumers is not static. In 
addition to developing economies of scale, there can be a tendency for manufacturers 
to  attempt  the  recuperation  of  product  development  costs  in  the  early  stages  of 
marketing  (in  the  automotive  sector  this  could  be  ca.  3-5  years).  After  this  initial 
period, product prices can fall relatively quickly. 

•  Competitive- and market environment in the automotive sector: some segments of 
the automotive market are characterised by increased competitive pressure and strong 
price  competition.  This  is  particularly  the  case  in  the  small  and  medium  segments, 
which raise most of the affordability concerns. This has led to an increase in the share 
of earnings, which manufacturers attempt to derive from post-sale activities (e.g. spare 
parts,  financing  etc.)  as 
traditional 
manufacturing activity. However, strong sales of the core product (i.e. the car itself) 
are  a  pre-requisite  for  accessing  such  additional  earnings.  The  combination  of 
competitive  pressure  and  future  earnings  potential  can  lead  to  a  situation  where 
margins are lowered, which can in turn be reflected in the retail price. 

these  offer  higher  profit  margins 

than 

2.3.  Historical retail price developments 

Given  the  number  of  factors  which  influence  the  pricing  strategy  of  companies  in  the 
automotive sector, it is very difficult to predict the future monetary impact of individual 
elements proposed by legislation. However, given that the automotive industry has a long 

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history  of  responding  to  regulatory  requirements  it  is  worthwhile  looking  at  empirical 
evidence of car price developments in order to assess possible future impacts.  

Historical price developments in the automotive sector indicate that the EU price index 
for  cars  (reflecting  actual  prices  paid  by  consumers,  including  VAT  and  registration 
taxes)  has  for  some  time  been  increasing  at  a  substantially  lower  rate  than  headline 
inflation. Graph 7 below presents the comparison between the two from 2003 onwards. 

Graph 7: Comparison between headline inflation and car price developments 

3

2,5

2

%

1,5

1

0,5

0

EU price index for cars

Headline inflation

May 2003-May 2004

May 2004-May 2005

May 2005-May 2006

May 2006-May 2007

Source: DG Competition 

In real terms, car prices have been declining. 

2.4.  Additional consideration on affordability 

It is often assumed that vehicle size provides a good proxy for assessing social equity: the 
implication being that buyers of new smaller vehicles are households with proportionally 
lower  purchasing  power.  It  is  important  to  point  out  that  while  this  may  hold  true 
partially,  car  size  cannot  be  considered  to  be  a  perfect  proxy  insofar  as  it  does  not 
account for the ability of households to purchase vehicles on the second-hand market as 
well as the practical needs of individual families (e.g. a family consisting of 4 members 
may not find that purchasing a new “small” vehicle would best serve their needs). 

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