Opinion of the European Economic and Social Committee on the Proposal for a Regulation of the European Parliament and of the Council setting emission performance standards for new passenger cars as part of the Community's integrated approach to reduce CO 2 emissions from light-duty vehicles COM(2007) 856 final — 2007/0297 (COD)
Date: 2008-09-17
Institutions: European Economic and Social Committee
Subjects: ESC opinion, energy saving, motor car, motor vehicle, non-polluting vehicle, pollution control measures, reduction of gas emissions

31.3.2009

EN

Official Journal of the European Union

C 77/1

III

(Preparatory Acts)

EUROPEAN ECONOMIC AND SOCIAL COMMITTEE

447th PLENARY SESSION HELD ON 17 AND 18 SEPTEMBER 2008

Opinion of the European Economic and Social Committee on the ‘Proposal for a Regulation of the
European Parliament and of the Council setting emission performance standards for new passenger
cars as part of the Community's integrated approach to reduce CO2 emissions from light-duty
vehicles’

COM(2007) 856 final — 2007/0297 (COD)

(2009/C 77/01)

On 22 February 2008 the Council decided to consult the European Economic and Social Committee, under
Article 95 of the Treaty establishing the European Community, on the

Proposal for a Regulation of the European Parliament and of the Council setting emission performance standards for
new passenger cars as part of the Community's integrated approach to reduce CO2 emissions from light-duty vehicles.

The Section for the Single Market, Production and Consumption, which was responsible for preparing the
Committee's work on the subject, adopted its opinion on 15 July 2008. The rapporteur was Mr Iozia.

At its 447th plenary session, held on 17 and 18 September 2008 (meeting of 17 September), the European
Economic and Social Committee adopted the following opinion by 140 votes to four.

1. Conclusions and recommendations

1.1
In its various opinions on the subject of cutting CO2
emissions, the Committee has always strongly supported the
Commission's legislative initiatives aimed at reaching specific
visible targets on cutting greenhouse gas emissions as a key
contribution to the fight against climate change.

the proposed Directive on passenger-car

Specifically, the Committee calls for the speedy adoption
1.4
of
related taxes
(COM(2005) 261 final) and the enhancement of Directive
1999/94/EEC on CO2-emissions labelling. It also calls on the
Commission to propose and coordinate initiatives on motor
vehicle advertising and marketing aimed at promoting more
fuel-efficient vehicles.

1.2
the
The Committee agrees with the objectives of
proposed regulation, which is aimed at steadily reducing CO2
emissions so as to meet the proposed target of 130 g/km by
2012, by means of improvements in vehicle motor technology.

Specific legislation for the car industry seems warranted,
1.5
given the need to move on from the phase of voluntary industry
commitments, which, although beneficial in terms of the impor-
tant progress made on passenger car emissions performance,
have proved insufficient to achieve the targets set.

1.3 Moreover, the Committee calls for the commitment of all
stakeholders to meeting the target of 120 g/km by 2012,
through an integrated approach, as set out in the Commission
communication of 7 February 2007, and calls on the Council
and European Parliament to swiftly adopt all pending legislation
aimed at curbing climate change.

1.3.1
The Committee recommends that the Commission set
long-term targets, as advocated by the European Parliament:
bolder solutions will need to be found for 2020.

1.6 While endorsing the strategy and proposed approach, the
Committee would call for measures that are genuinely feasible,
insofar as they strike the right balance between achieving crucial
environmental progress on the one hand, and, on the other, the
need to safeguard jobs in an industry that employs 13 million
workers and to fully maintain the competitiveness of European
manufacturers in an undoubtedly strategic sector for the EU's
economy.

C 77/2

EN

Official Journal of the European Union

31.3.2009

1.7
The Committee agrees that a regulation is the appro-
priate legal instrument as it will ensure immediate compliance
and thus prevent any distortions of competition. The timeframes
and specific details of the proposed measures must be carefully
thought out in a more consensual manner, so as to maintain
and strengthen the competitiveness of EU manufacturers in a
global market and to prevent the emergence of artificial advan-
tages amongst the various segments within the sector.

1.8
To this end, the Committee proposes that the Commis-
sion consider the possibility of replacing the current system of
defining emission limit values solely based on vehicle mass (as
used in Japan), and giving more consideration to other para-
meters such as vehicle footprint (wheelbase by track width),
which is already used as the basis for goods vehicles in the USA.

1.9
the
The Committee calls for further consideration of
linear function inclination (i.e. the % slope), given its direct
influence on the way in which the burden is shared amongst
manufacturers. The Commission itself, in its Executive summary
of the impact assessment [SEC(2007) 1724] says that ‘The appli-
cation of these criteria would, on the basis of initial analysis, suggest
that in order to strike a balance between them, a range between 50 %
and 80 % should be considered further at this stage’, thus implicitly
acknowledging the need for a much better impact assessment
on such a sensitive issue. Opting for a 60 % slope leaves
problems unresolved and could provoke a dispute with manu-
facturers that consider the decision unfair and imbalanced. The
Committee recommends that the impact of the final decision,
following all necessary further consideration, be neither benefi-
cial nor detrimental.

Another aspect that requires careful consideration is the
1.10
the regulation.
introduction of penalties, under Article 7 of
While the Committee agrees with this dissuasive approach, it
believes that their highly progressive nature will not allow EU
manufacturers to adapt their production chains to the new
limits within the planned timescale. The measures seem out of
kilter with those envisaged for other sectors, while creating an
inherent
and
medium-sized vehicles and those of
large vehicles, having a
much greater impact on the former.

imbalance between manufacturers of

small

1.11
The Committee thinks that these are hefty, spiralling
penalties and that they may be passed on into consumer prices,
placing the burden on the purchaser and possibly distorting
competition, while slowing the pace of vehicle fleet replace-
ment.
It calls on the Commission to ensure that any funds
deriving from this measure remain within the car industry,
providing incentives for the trade-in of more polluting cars and
campaigns to increase awareness of CO2 emissions as a factor
when purchasing, as well as contributing to the huge resources
needed for research and development.

1.12
The Committee considers that scientific research is
crucial to the degree of progress that can be achieved by the

industry. While results can be achieved in the initial phase using
existing technologies,
it is a reasonable assumption that the
future will require ‘a technological break from the present’
through the introduction of more advanced technology.

In the Committee's view,

1.13
taking the research route
requires huge resources and firm commitment, beginning with
the need to ensure coordination of ongoing initiatives in the
Member States, universities and technological centres of excel-
lence at all levels, while encouraging the direct participation of
manufacturers.

1.14
To this end, the Committee thinks that establishing a
dedicated Joint Technological Initiative (JTI) for the car industry
could help mobilise the scientific community.

The Committee thinks that the impact assessment does
1.15
not go far enough, as highlighted by the Impact Assessment
Board itself. In document SEC(2007) 1725 the Board calls for
clarification of the possible effects on attaining the targets, and
for an explanation of any differences between results from
TREMOVE and ex-ante analysis. It adds that further analysis is
needed of certain sensitive variables such as fuel prices and
increase (AWI). There should also be
autonomous weight
further assessment of
impact, particularly on
the regional
employment, the automotive supplier industry and competitive-
ness on external markets.

In the Committee's view, if such a far-reaching strategy
1.16
is to succeed, suitable measures are needed to support and
protect the industrial structure that exists in Europe, with a view
to safeguarding or indeed raising the current level of competi-
tiveness, while maintaining quality jobs in the industry. The
Committee advocates a phasing-in approach that would require
at least 80 % of the final target to be reached by 2012, the ulti-
mate target then being reached incrementally by 2015.

1.17
A key factor in reaching the environmental targets and
safeguarding competitiveness is applying the emissions limits
stringently to all non-EU-manufactured vehicles sold in Europe.
These limits will apply to imported vehicles.

1.18
Considering that this proposal is only the beginning of
a process aimed at tackling environmental problems across the
whole transport sector, the Committee calls on the Commission
to quickly draw up new legislation to limit CO2 emissions from
light goods vehicles, heavy-duty and two-wheel vehicles,
collating all the relevant data on their emissions.

1.19
The Committee believes that while sectoral policy for
the car industry is of real importance, it does not represent the
sum total of our wider commitment to general transport policy.
Nevertheless,
that commitment,
helping to guide the entire industry towards the environmental
targets already being pursued by other sectors of EU industry.

it is an important token of

31.3.2009

EN

Official Journal of the European Union

C 77/3

1.20
The Committee hopes that the proposed sector-specific
measures will be flanked by action focusing on transport
demand. It is vital to pursue a rigorous policy aimed at an ever
greater shift of transport from the roads onto other means
generating fewer greenhouse gas emissions such as rail, inland
waterway
(very-low-emitting, where
possible).

and public

transport

1.21
The Committee does not agree with the temporary
derogation under Article 9 of the Regulation as currently being
proposed, given that this clearly means unequal treatment of
manufacturers. In the Committee's view it is crucial to avoid
enshrining
distort
competition.

regulatory

advantage

could

that

any

The Committee recommends devising a model

1.22
for
calculating CO2 that factors in all emissions deriving from car
manufacturing. The carbon footprint should be taken into
account with regard to the entire lifecycle of vehicles.

1.23
To achieve this aim, we need to launch a debate on life-
styles — an issue on which the Committee has recently drawn
up specific opinions. It is a widely-held belief that if the number
and size of private vehicles continue to grow, and if goods vehi-
cles that generate high levels of greenhouse gas emissions and
NOx continue to receive preference, the goal of cutting CO2 by
20 % will not be achieved. This cannot and must not be
accepted.

2. Introduction: background to the proposal

2.1
The United Nations Framework Convention on Climate
Change, which was approved on behalf of the European Com-
munity by Council Decision 94/69/EC of 15 December 1993,
requires all parties to formulate and implement programmes to
mitigate climate change.

2.2
The Commission responded by gradually developing a
series of legislative measures which culminated in January 2007
in the EU proposing in the context of international negotiations
a 30 % reduction in greenhouse gas emissions by developed
countries (compared to 1990 levels) and a 20 % reduction by
2020. These targets were subsequently endorsed by the Council
and the European Parliament.

action is urgently needed on passenger cars, given that they
account for 12 % of overall EU emissions of carbon dioxide
(CO2), the main greenhouse gas.

Although significant

2.5
technological progress has been
made in the car industry, leading to a 12.4 % cut in CO2 emis-
sions between 1995 and 2004 by increasing fuel efficiency, the
steady growth in demand for transport and constant increase in
vehicle size have completely offset this saving, and indeed led to
an increase in overall emissions of greenhouse gases by the
transport sector.

2.6
The result is that, without specific initiatives, the EU is
highly unlikely to be able to meet its target of average emissions
from the new car fleet of 120 g CO2/km.

3. Landmarks in the Commission's strategy

The Community strategy for reducing CO2 emissions

3.1
began to take shape in 1995. It was based on three elements:

— voluntary commitments

from the car

industry to cut

emissions;

— improvements in consumer information;

— the promotion of fuel-efficient cars via fiscal measures.

3.2
In 1998, the European Automobile Manufacturers Asso-
ciation (ACEA) adopted a commitment to reduce average emis-
sions from new cars to 140g CO2/km by 2008, and the
Japanese and Korean Automobile Manufacturers Associations
(JAMA and KAMA) adopted a similar commitment to reduce
average emissions by 2009.

The Commission recognised these commitments by
3.3
issuing Recommendation 1999/125/EC (on the ACEA voluntary
agreement), Recommendation 2000/303/EC (on the KAMA
voluntary agreement) and Recommendation 2000/304/EC (on
the JAMA voluntary agreement). On the subject of monitoring
emissions the EU adopted Decision 1753/2000/EC of
the
European Parliament and of the Council establishing a scheme
to monitor average emissions of CO2 from new passenger cars.

On 7 February 2007,

3.4
parallel communications for the automobile sector:

the Commission adopted two

An analysis of

2.3
individual sectors shows that, while
overall emissions of greenhouse gases fell by approximately 5 %
in the period 1990-2004, CO2 emissions from the road trans-
port sector increased in the same period by 26 %.

— Results of the review of the Community Strategy to reduce
CO2 emissions from passenger cars and light-commercial
vehicles, COM(2007) 19 final
(EESC Opinion TEN/301,
rapporteur Mr Ranocchiari).

2.4
In view of this, there is a need for specific legislation to
bring the road transport sector back in line with the overall
downward trend in greenhouse gas emissions. More particularly,

— A Competitive Automotive Regulatory Framework for the
(EESC

21st Century — CARS 21, COM(2007) 22 final
Opinion INT/351, rapporteur Mr Davoust).

C 77/4

EN

Official Journal of the European Union

31.3.2009

These

communications

3.5
towards
meeting the target of 140 g CO2/km by 2008-2009, but
concluded that without other measures it would be impossible
to meet the target of 120 g CO2/km for the new car fleet.

reported

progress

Both communications called for an integrated approach

3.6
along two lines:

— compulsory reduction in CO2 emissions by improving
vehicle technology in order to achieve the average target of
130 g/km;

— the remaining 10 g/km reduction to be achieved by comple-
mentary measures consisting of the installation of new tech-
nological devices in vehicles (gear change indicators, tyre
low rolling-resistance tyres, high-effi-
pressure indicators,
ciency air conditioning systems, etc.) and increased use of
biofuels.

reduction in order to meet the Community's final objective of
120 g CO2/km as set out in COM(2007) 19 final.

4.3 When setting the levels of CO2 emissions, the regulation
takes into account:

— the

implications

for markets

and manufacturers'

competitiveness;

— stimulating innovation;

— reducing energy consumption.

4.4

The proposed Regulation also seeks to:

— encourage

the automobile

industry to invest

in new

technologies;

3.7
The Commission stated in these communications that
the average target for the new car fleet should take the following
factors into account:

— actively promote eco-innovation;

— it should be competitively neutral;

— the choices should be socially equitable and sustainable;

— take account of future technological developments;

— enhance the competitiveness of European industry;

— any unjustified distortion of competition between automo-

bile manufacturers should be avoided;

— create high-quality jobs.

— it should be fully compatible with the Kyoto targets.

The framework proposed and endorsed by both the
3.8
Competitiveness Council and the Transport Council relies on all
car manufacturers stepping up their efforts to produce more
ecological cars, while at the same time pursuing maximum cost
efficiency.

3.9
This means that the reduction in CO2 emissions has to
be achieved through an integrated approach that involves all
parties. A legislative proposal is thus needed that will meet the
targets while maintaining the global competitiveness of
the
automobile industry.

4. The Commission proposal

4.5
The Commission states that the regulation is consistent
with the EU's other objectives and policies and is the result of
extensive consultation and input from a working group specially
set up under the European Climate Change Programme (the
CARS 21 group) with the direct involvement of all stakeholders.

4.6
Legal basis. Article 95 of the EC Treaty is regarded as
the appropriate legal basis to ensure a level playing field for all
economic actors and provide a high level of protection of health
and the environment.

The

and

Subsidiarity

proportionality.

proposal
4.7
complies with the principles of subsidiarity and proportionality
in that, even though it does not fall under the exclusive compe-
tence of the Community, it prevents the emergence of barriers
to the single market, and the adoption of legislative measures at
Community level simplifies action to achieve a harmonised
reduction in the climate change impact of passenger cars.

The aim of the proposed Regulation (COM(2007) 856) is
4.1
to ‘reduce CO2 emissions from light-duty vehicles’ and to take
steps to achieve the target of 130 g/km by 2012. It applies to
motor vehicles of category M1 as defined in Annex II to Direc-
is
tive 2007/46/EC and to vehicles to which type-approval
extended in accordance with Article 2(2) of Regulation (EC)
No 715/2007 which are registered in the Community for the
first time and which have not previously been registered outside
the Community.

The proposal

4.2
is part of an integrated approach to be
rounded off by measures delivering an additional 10g CO2/km

Choice of legislative instrument. In the Commission's
4.8
view a regulation is the most appropriate instrument to ensure
immediate compliance with the provisions adopted, avoiding
distortions of competition which could have repercussions for
the internal market.

Information on emissions of

4.9 Monitoring.
carbon
dioxide from new passenger cars, measured on a harmonised
basis according to the methodology laid down in Regulation
(EC) No 715/2007, must be collected by the individual Member
States and reported to the Commission under the procedure laid
down in Article 6.

31.3.2009

EN

Official Journal of the European Union

C 77/5

4.10
Certificate of conformity. Manufacturers are required
under Directive 2007/46/EC to issue a certificate of conformity
which must accompany each new passenger car. Member States
will permit the registration and entry into service of a new
passenger car only on presentation of such a certificate (with
the exception of the derogations provided for in Article 9 of the
Regulation).

efforts.
It also calls on the institutions to undertake a swift
improvement on Directive 1999/94/EC on CO2-emissions label-
ling and for initiatives to be proposed and coordinated on
motor vehicle advertising and marketing. These should include
measures to promote more fuel-efficient vehicles and to ban the
advertising of the most polluting vehicles.

4.11
Excess emissions premium. Under Article 7 of the
proposed regulation, an excess emissions premium will be
imposed from 2012 on manufacturers or, in the case of a pool,
pool managers, whose emissions exceed the specific target. The
amount of the premium will increase significantly in the years
after 2012 and the sums collected will be considered as revenue
for the EU budget.

5. Strategic proposal of the European Parliament

5.1
the
In its resolution adopted on 24 October 2007,
European Parliament welcomed the Commission's strategy but
proposed that emission targets be implemented from 2011
onwards in order to reach 125 g CO2/km in 2015 by technical
improvements to vehicles alone. The Parliament laid stress on
the second step to be taken in view of the longer-term target:
reaching 95 g CO2/km by 2020 and possibly 70 g CO2/km
by 2025, subject to a confirmation or review no later than
2016.

6. Importance of consumer behaviour

is of particular

Consumer behaviour

6.1
importance in
successfully cutting CO2 emissions from cars. The Commission
has
thus begun preparatory work on amending Directive
1999/94/EC on consumer information regarding the conformity
of new vehicles to the emissions targets and their fuel economy,
aimed at increasing the contribution of car users to achieving
the objectives set.

7. General comments

7.1
As in previous opinions regarding Commission proposals
on cutting CO2 emissions, the Committee reaffirms its support
for all EU initiatives aimed at reaching specific targets on cutting
greenhouse gas emissions, as a key aspect of the fight against
climate change.

7.2
this
The Committee concurs with the objectives of
proposed regulation subject to the comments set out below. It
calls on the Council and European Parliament to swiftly adopt
all pending legislation aimed at curbing climate change.

The Committee calls for the speedy adoption by the EU
7.3
institutions of Directive COM(2005) 261 on passenger-car
related taxes, which would help accelerate the process of
reaching the target, encouraging companies to make greater

7.4
The Committee supports the choice of Article 95 of the
EC Treaty as the legal basis for the proposed regulation, as this
is well-suited to ensuring a level playing field for all actors and a
high level of protection of health and the environment.

7.5
The Committee agrees that a regulation is the appro-
priate legal instrument as it will ensure immediate compliance
and prevent any distortions of competition. This choice seems
necessary as voluntary commitments entered into by the
industry, although beneficial in terms of the results achieved on
passenger car emissions performance, have proved insufficient
to achieve the targets set.

The Committee approves the proposal to limit emissions
7.6
to 130 g CO2/km by means of improvements in vehicle motor
technology, though regretting that it appears no longer to be
practicable to aim for the tighter target of 120 g CO2/km origin-
ally envisaged for 2012. It recognises that the Commission now
proposes to achieve the 120 g/km in a different way through an
integrated approach,
including improved standards for tyres,
promotion of consumer awareness, incentives for eco-driving (1)
and particularly through greater use of biofuels. But given the
growing doubts about
the
target for use of biofuels in the transport sector, the Committee
does not regard this as a satisfactory alternative.

the feasibility and desirability of

The Committee therefore recommends that the Commis-
7.7
sion should set out now further targets for the car industry to
improve the carbon performance of vehicles in subsequent
years. We believe that establishing now a sequence of progres-
sively tighter targets for future years would give a clear signal of
the standards that will apply in those years, enabling European
industry to adjust its production plans accordingly.

thinks

The Committee

7.8
target
would represent an important contribution by the motor
industry to the fight against greenhouse gas emissions from the
transport sector, as over
in a
400-million-tonne cut in CO2 emissions.

that period it would result

achieving

that

this

The Committee believes that a key factor in achieving
7.9
both the current and longer-term objectives is significant invest-
ment in research and development. This must be designed to tie
in and coordinate with ongoing initiatives in the individual
Member States, universities and all industry-related technological
centres of excellence and involve the direct participation of
manufacturers.

(1) EESC opinion: OJ C 44, 16.2.2008 (rapporteur: Mr Ranocchiari).

C 77/6

EN

Official Journal of the European Union

31.3.2009

The Committee would draw the attention of

7.9.1
the
Commission and the Member States to the need for income
support measures to be introduced — inter alia via tax incen-
tives — for large families obliged to use large vehicles. Consid-
eration should also be given to the situation in Eastern
European markets where the average fleet lifespan is very high
and where more highly polluting second and third-hand cars are
sold. Ways should be found of incentivising trade-ins in these
countries, by means of specific provisions. Clearly, countries
with lower per capita income will not be able to benefit from a
general cut in emissions, as people there will be unable to
purchase the new, more efficient vehicles, which will most likely
be more expensive.

7.10
It seems clear that while over the next few years reason-
able results can be achieved using existing technologies, there
will be a need in future to consider ‘a technological break from
the present’ by introducing more advanced technology.

7.11
To this end, the Committee thinks that establishing a
Joint Technological Initiative (JTI) could help mobilise the scien-
tific community. This could be co-funded by a sizeable EU
budget allocation, matched by funding from the manufacturers,
as recently proposed in important sectors such as hydrogen and
fuel cells, aeronautics and air transport, innovative medicines, IT
systems and nanoelectronics.

7.12
The Committee supports the introduction of penalties
from 2012 for failure to meet the targets, as laid down under
the regulation, agreeing with this dissuasive
Article 7 of
approach, but thinks that these penalties should be earmarked
for motor industry-related measures, such as:

— bolstering all research and development initiatives;

— investing in vocational training;

— funding incentives

for

trading-in older, more-polluting

vehicles;

— carrying out information campaigns to encourage consu-
mers to factor in emissions as a criterion when purchasing a
vehicle; and

— supporting local public transport.

The Committee believes that these measures and their
7.13
highly progressive nature may not be compatible with the capa-
city of EU manufacturers to adapt their production chains to the
new limits. The penalties, which most likely will be passed on
into consumer prices, seem particularly high, and could distort
competition and effectively penalise the sector in relation to
other industries. A solution will need to be found that harmo-
nises the burden, taking account of the average cost borne by
the other sectors of industry involved in curbing CO2 emissions.

7.14
The Committee proposes that the Commission consider
the possibility of replacing the current system of defining emis-
sion limit values based on vehicle mass, with one based on
other parameters, such as vehicle footprint (a car's footprint is
calculated by multiplying its wheelbase by its track width).

7.15
The inclination of the linear function (i.e. % slope) will
influence the way in which the burden is shared amongst manu-
facturers and the certainty of the environmental outcome. The
nearer the slope is to 100, the lighter the burden to be borne
by heavier-car manufacturers. Conversely, the nearer the slope is
to zero the heavier the burden imposed to meet the targets (an
80 % slope allows a 6 g emission surplus, a 20 % slope allows
only a 1.5 g emission surplus). The Commission has indicated a
60 % slope (4.6 g surplus). The Committee calls on the
Commission to reflect further on this proposal, to make abso-
lutely sure that the regulation cannot benefit or disadvantage
any EU business.

If

7.16
the Commission does decide to retain this mass-
based approach, it would not make much sense to review the
slope in 2010, while the mass increase should be considered
from 2013.

7.17
The Committee calls on the Commission to quickly
draw up new legislation to limit CO2 emissions from light
goods vehicles, heavy-duty and two-wheel vehicles, for which
reliable verified data on actual emissions are needed.

Besides the crucial

7.18
issue of environmental protection,
the Committee calls on the Commission to give due considera-
tion to the potential effects of this complex process on the
the motor
13 million workers currently employed across
industry. With rising oil prices and consumer demand for fuel
economy, European car manufacturers could gain a competitive
advantage by producing more efficient vehicles, which could
favour employment in the EU.

7.19
In the Committee's view, suitable and practical measures
for research into new, innovative and efficient technologies are
needed, in order to maintain or indeed increase the European
car industry's competitiveness and the quality of the jobs it
provides.

7.20
The Committee believes that an important element in
this process is applying the emissions limits, fully and strin-
gently,
to all non-EU-manufactured vehicles sold in Europe.
These limits will be calculated on the basis of imports.

The Committee thinks that the progress report to be
7.21
drawn up in 2010 represents a key opportunity to assess the
entire strategy. It therefore asks to be involved in these periodic
assessments and thus for an opportunity to give its opinion.

31.3.2009

EN

Official Journal of the European Union

C 77/7

7.22
The Committee thinks that the impact assessment does
not go far enough. The Impact Assessment Board's opinion
called for certain crucial points to be clarified, given the impor-
tance of this issue.

The Board's recommendations, set out

7.23
in document
SEC(2007) 1725, are as follows: to clarify the impact on fleet
composition and the effect this may have on attaining the
targets, and explain possible differences between results from
TREMOVE (2) and ex-ante analysis; to undertake a sensitivity
analysis of certain variables such as fuel prices or autonomous
weight increase (AWI); to assess the regional impact, particularly
regarding employment; and to consider the effects on the auto-
motive supplier industry, and on competitiveness on external
markets. The Committee agrees with these suggestions and
hopes that the impact analysis will be broadened accordingly.

Alongside the proposed measures,

7.24
the Committee
stresses the need to step up policies aimed at reducing transport
demand, through an ever greater shift of transport from the
roads onto other means generating fewer greenhouse gas emis-
sions, such as rail, inland waterway, or public transport.

The Committee disagrees with the proposed temporary
7.25
the Regulation. As currently
derogation under Article 9 of
worded,
treating companies
it goes against
equally, effectively distorting competition in this particular
market segment as regards similar products with similar charac-
teristics. The Committee considers that the derogation should be

the principle of

Brussels, 17 September 2008.

granted to all manufacturers (regardless of whether or not they
are connected to another manufacturer) competing in the same
market segment, which in any case is just 0.2 %.

7.26
The Committee recommends that the Commission set
long-term targets, as advocated by the European Parliament:
bolder solutions will need to be found for 2020, with particular
emphasis on their feasibility. It is crucial to continue cutting
emissions, giving a clear signal of our intent to persevere along
this road.

The Committee recommends devising a model

7.27
for
calculating CO2 that factors in all emissions deriving from car
manufacturing. In certain countries, for example, many car parts
are brought in from very far afield, thus increasing the total
emissions per car manufactured, before the cars even hit the
road. The carbon footprint should be taken into account with
regard to the entire lifecycle of vehicles,
including the CO2
needed for scrapping.

7.28
In several recent opinions, the Committee has urged the
Commission to launch a debate on lifestyles. While agreeing
with the proposed targets, the Committee points out that if
current levels of growth continue in the number of private vehi-
cles, road transport vehicles and other modes of transport that
generate high levels of greenhouse gas emissions and NOx, and
if the Commission's growth projections are borne out, it will be
impossible to achieve the goal of cutting CO2 by 20 %, as set
out in recent Commission proposals.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

(2) TREMOVE is a policy assessment model for analysing the cost-effective-
ness of technical and non-technical measures aimed at reducing emis-
sions from the entire transport sector and at improving air quality, for
21 countries: EU-15, Switzerland, Norway, Czech Republic, Hungary,
Poland and Slovenia (the four new Member States have been selected
on the basis of data availability).