COMMISSION STAFF WORKING DOCUMENT Accompanying document to the  Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL concerning Type-approval requirements for agricultural vehicles    Executive summary of the Impact Assessment
Date: 2010-07-23
Institutions: European Commission
Subjects: agricultural equipment, agricultural implement, approval, commercial vehicle, tractor

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EUROPEAN COMMISSION 

Brussels, 23.7.2010 
SEC(2010) 934 final 

COMMISSION STAFF WORKING DOCUMENT 

Accompanying document to the 

Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
concerning Type-approval requirements for agricultural vehicles  

Executive summary of the Impact Assessment 

{COM(2010) 395} 
{SEC(2010) 933} 

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EXECUTIVE SUMMARY 

Over  the  last  35  years  a  type-approval  system  for  agricultural  vehicles  has  been  developed  from  a  basic 
document for harmonisation (Directive 74/150/EEC) to a system securing proper limits for road safety and 
environment protection. Now it needs modernising, rationalisation, simplification and completion.  

1. 

PROBLEM DEFINITION 

The  Commission  has  identified  three  key  problems  associated  with  the  current  provisions  for  the  type-
approval of agricultural vehicles: 

1.1. 

Lack of Legal and Regulatory clarity and burdensome management 

The  existing  system  for  agricultural  vehicles  is  considered  to  be  too  complex  and  that  there  is  therefore 
scope for simplification and international harmonisation. It is understood that in principle this proposal does 
not suggest increasing the stringency of existing technical requirements. 

Type-approval of agricultural vehicles has substantially evolved over the past thirty-five years: its nature has 
moved  from  being  a  system,  based  on  existing  national  requirements  and  designed  to  allow  free  trade 
between  Member  States  to  a  system  based  on  compulsory  whole-vehicle  type-approval  (WVTA)  for  most 
categories of vehicle, aiming to provide a high level of protection for health, safety and environment. 

In  addition  to  this,  many  directives  contain  references  to  international  regulations  and  standards,  such  as 
those  from  the  UNECE,  which  are  subject  to  amendments.  Ultimately,  the  disparate  nature  of  regulations 
relating to type-approval of agricultural vehicles leads to a lack of legal and regulatory clarity. Industry and 
regulators  must  be  familiar  with  some  60  directives,  and  ensure  that  they  are  aware  of  and  apply  any 
amendments to international standards. This can be a burdensome process and results in additional costs 
for  administrations  and  industry.  This  situation  is  particularly  a  problem  for  SMEs  which  operate  on  this 
market. 

As a general framework, the type-approval system is recognised as an effective approach to tackle various 
aspects (road and occupational safety, environment). Many stakeholders have called upon the Commission 
to  simplify  the  regulatory  framework  in  order  to  obtain  a  less  burdensome  and  less  time  consuming 
approach to type-approval. 

1.2. 

Resource-intensive transposition without adding value 

The Framework Directive and its separate Directives provide for the technical requirements to be complied 
with  when  granting  EC  type-approval.  The  enacting  terms  of  the  directives  and  their  annexes  are  highly 
detailed and leave practically no room for discretion of Member States when transposing them. Thus, some 
Member  States  simply  make  direct  reference  to  those  Directives,  but  others  develop  a  completely  new 
legislative text that is meant to correctly transpose those requirements.  

Transpositions  are  then  using  resources  in  national  administrations  without  adding  any  value  in  terms  of 
safety or environment protection.  

1.3. 

Functioning of the internal market 

Requirements under the Framework Directive are mandatory since 1 July 2005 for all new types of tractor in 
categories T1, T2 and T3, and will be mandatory for all new tractors in these categories from 1 July 2009 
onwards. For the remaining categories of vehicles (T4, T5, C, R and S) EC whole vehicle type-approval is 
not  yet  mandatory.  For  certain  categories,  it  is  optional,  i.e.  up  to  the  choice  of  the  manufacturers.  For 
others,  not  all  special  requirements  have  been  harmonised  at  EU-level  yet,  thus,  EC  whole  vehicle  type-
approval is not yet available. 

A  further  consideration  to  be  taken  into  account  when  choosing  between  different  alternatives  is  whether 
completion  would  be  too costly  for  SMEs  such  as  trailer  manufacturers  and  end-users  if  it  would  be  on a 
mandatory basis. One alternative could be to complete the set of requirements but leave whole vehicle type-
approval  optional  (at  the  manufacturer’s  choice)  for  those  categories,  thus  allowing  full  EC  whole  vehicle 
type-approval (or component type-approval) for those -larger- industries that can benefit. A drawback may 
be that Member States may need to maintain a set of national rules and requirements, in parallel to the EC 
Regulation  now  being  proposed.  It  should  also  be considered whether  mandatory  EC  whole  vehicle  type-
approval  is  desirable  for  reasons  of  safety  or  environmental  protection  (the  more  so,  since  exhaust  gas 
requirements are already mandatory for all tractors). 

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2. 

ANALYSIS OF SUBSIDIARITY 

Prior to the establishment of an EU type-approval for agricultural vehicles, regulations were established at 
Member  State  level.  The  regulations  set  by  Member  States  often  differed  and  manufacturers  selling  on 
several markets were then obliged to vary their production according to the Member States for which their 
products  were  intended  and  had  their  vehicles  tested  in  every  Member  State,  which  was  time  consuming 
and  costly.  Different  national  rules  consequently  hindered  trade  (different  design,  production,  distribution, 
after-sales in every country), and had a negative effect on the establishment and functioning of the internal 
market. 

It  was,  therefore,  necessary  to  establish  standards  at  the  EU  level  for  certain  areas  (for  example,  road 
safety, occupational safety, and environment protection). The Framework Directive 2003/37/EC, based on 
Article  95  of  the  EC  Treaty,  was  designed  to  do  this  and  aims  at  establishing  an  internal  market  while 
ensuring a high level of protection concerning health, safety and environment. Such a rationale is still valid 
today as Community action is necessary to avoid fragmentation of the internal market and to ensure a high 
and equal level of protection across Europe. Any change to this regulatory framework will be assessed in its 
compliance with the principle of subsidiarity as established in Article 5 of the EC Treaty. 

3. OBJECTIVES OF EU INITIATIVE 

3.1. 

Overall objective 

The  exercise  of  simplification  replies  to  the  commitment  of  the  Commission  to  act  in  accordance  with  the 
principles  of  Better  Regulation.  Simplifying  the  regulatory  framework  of  the  type-approval  of  vehicles  is 
furthermore  in  line  with  the  recommendations  of  CARS  211,  which  gathered  expectations  of  various 
stakeholders. Applying now this process to agricultural vehicles aims at addressing the problems identified 
by  the  Commission  on  the  basis  of  the  stakeholder  consultation.  The  simplification  exercise  has  thus  as 
general objectives the reduction of the legal unclarity, the deletion of resource-intensive transpositions, and 
a move towards a better coverage of these agricultural vehicles by the EU type-approval system. 

3.2. 

Objective 1: Simplification of existing acquis (by repeal of existing directives). 

The current regulatory architecture is very fragmented, using a Framework Directive, 23 detailed technical 
Directives,  36  amending  directives  and  a  whole  corresponding  set  of  transpositions  into  national 
legislations. The simplification exercise aims at addressing this complexity and assessing which regulatory 
approach could allow less time-consuming and less burdensome adaptations to technical progress. A more 
clear,  structured  and  coherent  legislation  would  also  be  in  line  with  the  Better  Regulation  commitment, 
which is an important objective for the Commission. 

3.3. 

Objective  2:  Improved  regulatory  capacity  for  future  acquis  (by  new  split-level  regulatory 
approach with use of references to international standards) 

Another part of the simplification exercise is the elimination of technical details in EC Directives by replacing 
them  by  references  to  standards  set  by  other  international  organisations  such  as  the  UNECE,  OECD, 
CEN/CENELEC  and  ISO,  which  are  widely  accepted  inside  and  outside  the  EU.  A  condition  is  that  such 
standards must be equivalent to the protection level provided by the present Directives. 

3.4. 

Objective 3: Completion of the single market 

The  EC  whole  vehicle  type-approval  system  under  the  Framework  Directive,  even  though  in  principle 
foreseen,  is  not  mandatory  for  categories  T4,  T5,  C,  R  and  S,  but  according  to  the  text  of  the  Directive 
manufacturers  can  voluntarily  apply  for EC  (whole  vehicle)  type-approval  for  vehicles  of  these categories. 
However,  technical  requirements  for  these  categories  have  not  been  established  yet  for  many  of  the 
aspects and the option to obtain an EC whole-vehicle type-approval remains therefore theoretical, despite 
what is provided in the Directive: vehicles of these categories can only obtain a whole vehicle type-approval 
under national legislation. It follows that in order to obtain access to the different national markets, the same 
vehicle may need a whole-vehicle type-approval from several Member States. The simplification exercise is 
an opportunity to complete the EU regulatory framework for these categories of vehicles, so that they can 
benefit from a single EU system which gives access to the whole European market. 

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Competitive Automotive Regulatory System for the 21st century 
http://ec.europa.eu/enterprise/automotive/pagesbackground/competitiveness/cars21.htm 

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4. POLICY OPTIONS 

For these objectives the following options were evaluated: 

Simplification I: Simplification of existing acquis (by repeal of existing directives) 

Option 1: No policy change 

4.1. 

a) 

No change would be made to the current regulatory framework: the Framework Directive would still define 
the  EC  type-approval  system,  while  technical  requirements  would  still  be  established  under  separate 
Directives,  which  require  transposition  into  national  legislations.  Amending  directives  would  also  require 
transposition through national acts. 

b) 

Option 2: Replace the current framework by two regulations 

The present Directives would be repealed. A new Mother Regulation adopted by co-decision would contain 
the  fundamental  requirements  of  the  EC  type-approval  system,  while  all  detailed  technical  requirements 
would  be  gathered  into  a  single  implementing  regulation,  to  be  adopted  and  more  easily  updated  in  the 
future through the comitology procedure. 

c) 

Option 3: Replace the current framework by a limited number of thematic regulations 

Same  as  option  2,  but  the  detailed  technical  requirements  would  be  gathered  into  for  example  three 
thematic  implementing  regulations  adopted  by  comitology  procedure.  Requirements  could  be  grouped  by 
coherent blocks under environmental aspects, road safety aspects, and occupational safety aspects2. 

While the difference between Option 2 and Option 3 is rather small, the difference from Option 1 is major. 
By moving from directives to the legislative instrument of regulations, options 2 and 3 would do away with 
the need for transposition on the side of Member States and the need for transposition control on the side of 
the  Commission,  and  all  discrepancies  between  national  transposition  acts  would  be  avoided.  With  the 
introduction of the split-level approach, the co-legislator could concentrate on issues which must be decided 
by Council and Parliament, while delegating technical and administrative details to the Commission without 
losing control (the regulatory procedure with scrutiny would be the applicable comitology procedure, which 
ensures final control by the co-legislator also for comitology acts). 

4.2. 

Simplification  II:  Improved  regulatory  capacity  for  future  acquis  (by  new  split-level 
regulatory approach with use of references to international standards) 

a) 

Option 1: No policy change 

No  change  would  be  made  to  the  current  framework,  requirements  and  test  procedures  having  to  be 
followed as required under the 24 separate Directives. 

b) 

Option 2: Use when possible references to UNECE Regulations 

Similar  to  what  has  been  introduced  for  motor  vehicles  in  the  General  Safety  Regulation  (GSR),  where 
equivalent  technical  standards  have  been  defined  by  UNECE,  the  provisions  of  EC  Directives  should  be 
repealed and replaced by a reference to these international standards. This option could take different forms 
which have to be assessed: 

– 

– 

– 

– 

Full references, where the text is fully copied and published by EU 

Simple  fixed  (static)  references,  where  the  EC  legislation  links  to  a  dated  international 
regulation 

General  (dynamic)  references,  where  the  EC  legislation  links  to  a  regulation  of  an 
international standardisation body, but without dating it (open to update). 

From a  point  of  view  of  legal  certainty and control  over  EU  legislation  the  latter  possibility 
(dynamic reference) seems unacceptable; it was not further analysed. 

c) 

Option 3: Use references to all relevant international standards 

Similar  to  option  b),  but  now  reference  to  OECD,  CEN/CENELEC  and  ISO  can  be  applied.  OECD  has 
introduced so called Codes for Roll-over Protection Systems, which are not available from UNECE; for other 
issues only standards from CEN/CENELEC or ISO exist. .  

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At this stage, the exact number of implementation Regulations has not been fixed yet. 

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4.3. 

a) 

Completion of the single market 

Option 1: No policy change 

No  change  would  be  made  to  the  scope  of  the  Framework  Directive,  the  EC  whole  vehicle  type-approval 
remaining optional, but de facto not available for categories T4, T5, C, R and S. Without any adaptation to 
technical  requirements,  the  different  national  type-approval  requirements  will  have  to  be  complied  with  in 
order to obtain national type-approvals and have market access in different Member States of the EU. 

b) 

Option 2: Complete the EC type-approval requirements and make EC type-approval mandatory 
for all categories of vehicles 

The EC type-approval legislation will be completed for the categories not (fully) covered today. The missing 
technical compliance requirements for certain elements would be filled in. EC whole vehicle type-approval 
would be made mandatory for all categories presently covered by the Framework Directive, which means 
that  vehicles  from  categories  T4,  T5,  C,  R  and  S  would  no  longer  have  to  pass  national  type-approval 
procedures: they should only fulfil requirements of EC type-approval and then gain access to all markets. 

c) 

Option 3: Complete the EC type-approval requirements and leave EC whole vehicle type-approval 
optional for certain categories (T4, T5, C, R and/or S) 

As  with  option  2,  the  EC  legislation  would  be  completed,  but  the  EC  whole  vehicle  type-approval 
would remain optional for those categories. This would allow a manufacturer the choice between a national 
approval  per  Member  State  or  an  EU  whole  vehicle  type-approval,  the  latter  at  probably  higher  costs  but 
with  the  benefit  of  direct  accessibility  of  the  whole  internal  market.  The  manufacturer  would  have  an 
incentive to choose the profit maximising solution. 

An  alternative  would  be,  as  suggested  by  many  stakeholders,  to  make  certain  requirements  mandatory 
within  this  option.  Some  subjects  mentioned  are:  braking,  lighting  and  markings.  This  would  harmonise 
those aspects within Europe and bring important road safety aspects at a certain acceptable minimum level. 
For all tractors this already is the case for exhaust gas emissions requirements. 

5. ANALYSIS OF IMPACTS 

5.1. 

Simplification I: Simplification of existing acquis (by repeal of existing directives) 

The  proposal  to  change  to  Regulations  is  brought  about  by  Parliament  and  stakeholders;  several  have 
expressed criticisms on the useless complexity of the format of the current legislative framework, and asked 
the Commission to take measures to tackle this situation.  

The type-approval system receives full support, but needs updating. 

Changing from Directives to regulations in split-level approach is shown to be clearly cost-effective, after 3 
to 4 years because of investment costs for the change. 

The simplification exercise is welcomed by the stakeholders, even though some insisted that there are other 
issues on the agenda that should have priority (e.g. exclusion of tractors from the Machinery Directive). 

The  choice  between  two  and  more  Regulations  is  not  evident  on  the  basis  of  cost/benefit  considerations, 
but should be made on practical grounds.  

5.2. 

Simplification  II:  Improved  regulatory  capacity  for  future  acquis  (by  new  split-level 
regulatory approach with use of references to international standards) 

A move to use “worldwide” recognised standards, also applied in the General Safety Regulation for motor 
vehicles, widely supported by stakeholders as expressed in replies to the public consultation, is a benefit to 
industry as their approved products can be marketed as widely as possible.  

The main positive point is that the legislation will be simplified by suppressing useless duplications. This will 
benefit to all actors dealing with this legislation, being national authorities responsible for type-approval, or 
manufacturers whose vehicle types have to comply with these requirements. It will in particular benefit the 
SMEs which have limited resources to be attributed to regulatory affairs. 

In  relation  with  translations  the  study  shows  that  large  benefits  should  not  be  expected  as  legal  security 
requires that such documents need to be available in all official community languages. UNECE and OECD 
produce  only  French  and  English  versions,  so  the  EC  must  take  care  of  the  others  (a  reduction  of  1 
language compared with the present situation where one original version needs to be translated in all other 
languages). 

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Some cost reduction can be obtained by a limited reduction in participation in international meetings. 

A  reduction  in  costs  of  type-approval  seems  possible,  but  limited.  Today  some  components  (like 
headlamps)  have  more  than  one  approval  (set  of  documents  and  marking)  which  brings  about  some 
additional  costs.  At  the  same  time  such  a  limitation  in  international  legislation  by  suppressing  useless 
duplications is also an advantage for national authorities which have to apply them.  

In  all  cases  of  reference  to  international  standards  the  Regulation  should  provide  that  the  EU  can  act 
independently to introduce differing amendments if necessary. 

A special case is the existing Directive on exhaust gas requirements for tractors. As the technical content is 
already  aligned  with  Directive  97/68/EC  for  Non-Road  Mobile  Machinery,  it  is  considered  to  be  a 
simplification  to  repeal  the  tractors  Directive  and  fully  refer  to  97/68/EC,  without  affecting  the  technical 
content. 

In conclusion the evaluation is slightly in favour of this reference to international standards. 

5.3. 

Completion of the single market 

The present incomplete status of Directives means that additional national legislation is necessary. 
Completing the EC system and making it mandatory could change this and bring long-term advantages. 
Completion as such is seen as beneficial, but it is shown that making it mandatory would bring serious and 
undesirable costs for industry, especially for the many SMEs. This may vary with vehicle categories, 
depending on the facilities for “small-series type-approval”. Such arrangement, already available in the 
present Framework Directive, allows manufacturers and national authorities to use easier and cheaper 
approval procedures, while the vehicle is supposed to attain the same level of protection. 

When the system would remain optional for certain categories the level of protection provided in a certain 
market might be lower than in others. At the same time Member States will have to maintain national 
legislation. For manufacturers it will be the cheapest solution, if they sell only in limited numbers of 
countries. This would be important for SMEs, especially in the sector of trailers and towed machinery.

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6. OPTIONS COMPARISON AND CONCLUSIONS 

Summary of impacts of different options for all objectives 

Objective 

Policy options 

effectiveness 

1 - No policy change 

0 

Criteria 

efficiency 

0 

initial cost 

2 - Replace current 
framework by two 
regulations 

simplification of the 
regulatory 
framework 

slight risk of delaying urgent matters

+ 

cost reduction on the long term 

a quick process of adaptation to 
technical evolution in the future 

initial cost 

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b
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3 - Replace the 
current framework by 
limited number of 
thematic regulations 

simplification of the 
regulatory 
framework 

+ 

slight risk of delaying urgent matters

_ 

easier processing 

cost reduction on the long term 

implementing measures will be 
adopted in a short term 

+ 

+ 

+ 

facilitation and rationalisation 
effects: more coherence for 
experts 

coherence 

 

Conclusion
3 

0 

_ 

_ 

+ 

+ 

_ 

better than baseline 

+ 

even more positive 
(increased clarity for 
industry) 

 

 

+ 

+ 

3 

Explanation: 
+ means ‘better’ 

0 means ‘neutral’ (no change) 

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
Policy options 

Objective 

effectiveness 

Criteria 

efficiency 

coherence 

Con-
clusion 

1- No policy 
change 

2- Use references 

to UNECE 
Regulations 

3- Use references 
to all relevant 
international 
standards 

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0 

0 

0 

0 

simplification 

+ 

slight reduction of costs and administrative 
burden 

improved management of procedures 

reduction of 
duplications 

+ 

UNECE texts also need to be translated and 
published, like EC legislation 

simplification 

++ 

potential risk of weakening requirements 

OECD texts also need to be translated and 
published, 
like EC legislation and UNECE 

reduction of costs and administrative burden 

reduction of 
duplications 

++ 

improved management of procedures 

potential risk of weakening requirements 

+ 

+ 

0 

_ 

0 

+ 

+ 

- 

increase clarity 
for industry and 
administrations 

+ 

 

same as in 2.2 

 

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
Objective 

Policy options 

effectiveness 

Criteria 

efficiency 

coherence 

Con-
clusion 

1- No policy change 

0 

0 

0 

t

e
k
r
a
m
e
g
n
s
e
h

l

i

t

f

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p
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o
C

-
3

2- Complete the EC TA 
requirements and make EC 
type-approval mandatory for 
all categories of vehicles 

completion of 
internal market 
(mandatory) 

+ 

3- Complete the EC TA 
requirements; leave EC 
WVTA optional for certain 
categories (T4, T5, C, R 
and/or S) 

completion of the 
internal market 
(optional) 

high costs of new requirements for 
T4.2, T5, R and S 

access to a wider market with less 
administrative burden 
new specific technical requirements 
needed 
increase in road safety 
gains from harmonised designs 

allows open market with cheapest 
option 

+ 

new specific technical requirements 
needed 

increase in road safety 
gains from harmonised designs 

_ 

+ 

- 

+ 
+ 

+ 

- 

+ 
+ 

0 

0 

 

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In conclusion, the preferred options would be to simplify the legislation by introducing a co-decision 
Regulation with a limited number of implementing Regulations through Comitology, using available 
standards  from  UNECE,  OECD,  ISO  and  CEN/CENELEC  as  much  as  possible;  the  technical 
provisions should be completed as already foreseen in the Framework Directive; some of the road 
safety  related  prescriptions  should  be  made  mandatory  (as  is  already  the  case  for  emission 
requirements for all tractors). 

7. MONITORING AND EVALUATION 

No specific system is foreseen but the Commission’s Working Group on Agricultural Tractors will 
be used for the follow-up with the implementing measures.  

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ANNEX 

Objective 1 : Simplification of the regulatory framework through a split-level approach 

Indicators 

Option 1 

Option 2 

Option 3 

No policy change 

Replace current 
framework by 2 
regulations 

Replace current 
framework by [4] 
regulations 

Costs 

Annual cost to  

€ 29,160 to € 2,435, 400 

€ 7,560 to € 1,217,700 

EU-27  

average € 533,993 

average € 320,153 

Initial investment cost 

Benefits 

Cumulative benefit 
(Costs include an 
uplift of 2 % per 
annum and a discount 
rate of 3,5 %) 

€ 18,225 to € 3,653,100 

average € 909,225 

Year 

Lower 
limit 

Average 

Upper Limit 

1 

5 

€ 3,375

- € 695,385  

- € 2,435,400

€ 86,690

€ 129,430  

€ 2,261,461

10 

€ 184,219

€ 1,094,970  

€ 7,759,675

COST / BENEFIT COMPARISON TABLE 

Objective 2: Simplification through use if international standards 

Indicators 

Option 1 

Option 2 

Option 3 

No policy change 

Use when possible 
references to UNECE 
Regulations 

Use references to all 
relevant international 
standards 

Costs 

Type approval costs 

Approximate costs per type (component) on average: € 15,000 

The cost of one whole vehicle-type approval can be above € 100,000  

Translation costs 

Annual staff cost for 

Estimated average annual cost to 
attend  EC,UNECE,OECD,  ISO 

Estimated  average  annual 
cost  to  attend  meetings 

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attending meetings  

&  CEN  meetings  € 1,135,085 
to 
€ 
(range: 
€ 2,608,200)  

310,536 

with  reference  to  existing 
€  1,078,331 
standards 
(range: 
to 
€ 2,608,200)  

€  279,482 

Investment cost for 
EU-27 

Benefits 

Annual saving from 
Type approval costs 

Annual average 
savings from attending 
meetings 

Translations 

909,225 

€ 
€ 18,225 to € 3,653,100)

(range: 

0 

€ 31,054 (range: € 0 to 
€ 56,754)  

0 

EN 

12 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
Objective 3 : Completion of the regulatory framework 

Indicators 

Option 1 

Option 2 

Option 3 

No policy change 

Complete the EC type-approval 
requirements and make EC type-
approval mandatory for all 
categories of vehicles 

Complete the EC type-approval 
requirements and leave EC 
whole type-approval optional 
for certain categories of 
vehicles (T4,T5,C,R and S) 

Costs 

Estimated average cost 
per vehicle category (1) 

Estimated average 
annual administrative 
costs (2) 

Total cost (1+2) 

Average investment cost4 
for EU-27  

Benefits 

Estimated casualty 
savings  

Estimated average 
cumulative benefits 
(Costs include an uplift 
of 2 % per annum and a 
discount of 3,5 %) 

Benefits from 
standardisation (saved by 
buyers) 

T4.1 

T4.2 

T4.3 

T5 

C 

R 

S 

€ 0  

€ 112,500,000 

€ 0  

€ 40,625,000  

similar to option 2 

€ 0  

€ 200,195,313  

€ 257,812,500  

€ 36,190,000  

€ 647,322,813 (range: € 364,440,000 to € 996,565,000)

€ 32,980,000* (range: € 3,860,000 to € 62,100,000)

€ 50,750,409  

Year 1: - € 629,552,403 

Year 5: - € 3,057,835,295 

Year 10: - € 5,900,418,586  

T4.2 Category: benefit of € 22,500, 000 (average) 

on 9,000 vehicles registered p.a. 

R Category: benefit of € 68,750,000 (average) 

on 125,000 vehicles registered p.a. 

S Category: benefit of € 812,500,000 (average)  

on 500,000 vehicles registered p.a. 

EN 

13 

   EN 

 
 
 
 
 
 
 
 
 
 
 
EN 

14 

   EN