COMMISSION STAFF WORKING DOCUMENT Accompanying document to the  Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the approval and market surveillance of two- or three-wheel vehicles and quadricycles   Impact Assessment
Date: 2010-10-04
Institutions: European Commission
Subjects: Community certification, approval, environmental protection, harmonisation of standards, marketing standard, motor vehicle, two-wheeled vehicle, vehicle parts

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558340 DT Two- or Three-wheel vehicles and Quadricycles 
Impact Assessment 

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EUROPEAN COMMISSION 

Brussels, 4.10.2010 
SEC(2010) 1152 

COMMISSION STAFF WORKING DOCUMENT 

Accompanying document to the 

Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
on the approval and market surveillance of two- or three-wheel vehicles and quadricycles 

Impact Assessment 

This  report  commits  only  the  Commission  departments  involved  in  its  preparation  and  does  not 
prejudge the final form of any decision to be taken by the Commission. 

Lead DG: DG Enterprise and Industry 

Commission Work Programme 2010 

Commission’s Agenda Planning: 2010/ENTR/02 

{COM(2010) 542 final} 
 {SEC(2010) 1151} 

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TABLE OF CONTENTS 

Background information and policy context .................................................................................................................. 6 
Procedural issues and consultation of interested parties ............................................................................................. 7 
Organisation and timing................................................................................................................................................ 7 
Public consultation........................................................................................................................................................ 7 
External expertise ......................................................................................................................................................... 8 
Industry self obligation and proposal ............................................................................................................................ 8 
Problem definition and right to act ................................................................................................................................ 8 
Problem definition ......................................................................................................................................................... 8 
Complexity of the current legal framework ................................................................................................................... 8 
High level of emissions ................................................................................................................................................. 9 
High number of fatalities in road accidents and safety risks....................................................................................... 13 
Lack of a legal framework for new technologies......................................................................................................... 14 
Community competence and subsidiary..................................................................................................................... 15 
Objectives ................................................................................................................................................................... 15 
General objectives ...................................................................................................................................................... 15 
Specific objectives: simplification of existing EU legislation ....................................................................................... 15 
Environmental specific objectives............................................................................................................................... 15 
Safety specific objectives............................................................................................................................................ 16 
Specific objectives: realign legal requirements and technology developments .......................................................... 16 
Policy options.............................................................................................................................................................. 16 
Simplification of existing EU legislation ...................................................................................................................... 16 
Vehicle type approval environmental measures ......................................................................................................... 16 
New or revised environmental measures for the type approval of new vehicles ........................................................ 17 
Revised lower emissions limits. .................................................................................................................................. 17 
Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicle  
classes........................................................................................................................................................................ 18 
Type-approval requirements for CO2 measurement and fuel consumption determination and reporting................... 18 
Evaporative emissions test and limit........................................................................................................................... 19 
Durability requirements............................................................................................................................................... 19 
New measures to control vehicle emissions over vehicle life. .................................................................................... 20 
In-Use Conformity (IUC) testing and limits ................................................................................................................. 20 
On Board Diagnostic (OBD) systems and access to repair information. .................................................................... 20 
New vehicle type approval safety measures .............................................................................................................. 20 
Obligatory fitting of Advanced Brake Systems............................................................................................................ 21 
Anti-tampering measures............................................................................................................................................ 21 
74kW power limitation for motorcycles ....................................................................................................................... 21 
Improved categorisation of L-category vehicles ......................................................................................................... 21 
Electrical cycles (currently outside scope of Framework Directive), Tricycles (L5e) and quadricycles 
(categories L6e and L7e)............................................................................................................................................ 21 
Specific requirements for category L7e vehicles ........................................................................................................ 22 
Dedicated requirements for gaseous alternative fuels and other non-traditional propulsions .................................... 22 
Analysis of impact....................................................................................................................................................... 22 
Simplification of the legislation.................................................................................................................................... 22 
Vehicle type approval environmental measures ......................................................................................................... 25 
New or revised environmental measures for the type approval of new vehicles ........................................................ 25 
Revised lower emissions limits ................................................................................................................................... 25 
Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicle 
classes........................................................................................................................................................................ 25 
Type-approval requirements for CO2 measurement and fuel consumption determination and reporting and 
reporting...................................................................................................................................................................... 26 
Evaporative emissions test and limit........................................................................................................................... 26 
Durability requirements............................................................................................................................................... 27 
New measures to control emissions during vehicle life. ............................................................................................. 28 
In-Use Conformity (IUC) testing and limits. ................................................................................................................ 28 
On Board Diagnostic (OBD) systems and access to repair information ..................................................................... 28 
New vehicle type approval safety measures .............................................................................................................. 28 
Obligatory fitting of Advanced brake systems............................................................................................................. 28 
Anti-tampering measures............................................................................................................................................ 30 
74kW power limitation for motorcycles ....................................................................................................................... 30 
Improved categorisation of L-category vehicles ......................................................................................................... 30 
Re-categorising electric assisted cycles (currently outside the scope of legal framework), tricycles (category L5e)  
and quadricycles (Categories L6e and L7e) ............................................................................................................... 30 
Specific requirements for category L7e vehicles ........................................................................................................ 31 
Dedicated requirements for gaseous alternative fuels and other non-traditional propulsions .................................... 32 
Proposal to combine the results of the preferred options for improved categorisation of L-category vehicles........... 32 
Options comparison and conclusions ......................................................................................................................... 32 
Simplification of the legislation.................................................................................................................................... 32 
Vehicle type approval environmental measures ......................................................................................................... 32 
New or revised environmental measures for the type approval of new vehicles ........................................................ 32 
Revised lower emissions limits .......................................................................................................................................  
Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicle  
classes........................................................................................................................................................................ 33 

1. 
1.1. 
1.2. 
1.3. 
1.4. 
2. 
2.1. 
2.1.1. 
2.1.2. 
2.1.3. 
2.1.4. 
2.2. 
3. 
3.1. 
3.1.1. 
3.1.2. 
3.1.3. 
3.1.4. 
4. 
4.1. 
4.2. 
4.2.1. 
4.2.1.1. 
4.2.1.2. 

4.2.1.3. 
4.2.1.4. 
4.2.1.5. 
4.2.2. 
4.2.2.1. 
4.2.2.2. 
4.3. 
4.3.1. 
4.3.2. 
4.3.3. 
4.4. 
4.4.1. 

4.4.2. 
4.4.3. 
5. 
5.1. 
5.2. 
5.2.1. 
5.2.1.1. 
5.2.1.2. 

5.2.1.3. 

5.2.1.4. 
5.2.1.5. 
5.2.2. 
5.2.2.1. 
5.2.2.2. 
5.3. 
5.3.1. 
5.3.2. 
5.3.3. 
5.4. 
5.4.1. 

5.4.2. 
5.4.3. 
5.4.4. 
6. 
6.1. 
6.2. 
6.2.1. 
6.2.1.1. 
6.2.1.2. 

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6.2.1.3. 

6.4.2. 
6.4.3. 
6.5. 
7. 
7.1. 
7.2. 
7.2.1. 
7.2.1.1. 
7.2.1.2. 

6.2.1.4. 
6.2.1.5. 
6.2.2. 
6.2.2.1. 
6.2.2.2. 
6.3. 
6.3.1. 
6.3.2. 
6.3.3. 
6.4. 
6.4.1. 

Type-approval requirements for CO2 measurement and fuel consumption determination and reporting and  
reporting ......................................................................................................................................................................33 
Evaporative emissions test and limit ...........................................................................................................................33 
Durability testing of anti-pollution devices and aged vehicles to obtain new vehicle type-approval certificate ...........34 
New measures to control vehicle emissions over vehicles in use................................................................................... 
In-Use Conformity (IUC) testing and limits. .................................................................................................................34 
On Board Diagnostic (OBD) systems and access to repair information......................................................................34 
New vehicle type approval safety measures ...............................................................................................................34 
Obligatory fitting of Advanced Brake Systems ............................................................................................................34 
Anti-tampering measures ............................................................................................................................................37 
74 kW power limitation for motorcycles .......................................................................................................................37 
Improved categorisation of L-category vehicles ..........................................................................................................37 
Re-categorising electric assisted cycles (currently outside scope of legal framework), Tricycles (L5e) and  
quadricycles (categories L6e and L7e) .......................................................................................................................37 
Specific requirements for category L7e vehicles.........................................................................................................38 
Dedicated requirements for gaseous alternative fuels and other non-traditional propulsions.....................................38 
Overview preferred options, the detailed analysis and comparison with the other options.........................................39 
Monitoring and evaluation ...........................................................................................................................................40 
Simplification ...............................................................................................................................................................40 
Vehicle type approval environmental measures..........................................................................................................40 
New or revised environmental measures for the type approval of new vehicles.........................................................40 
Revised lower emissions limits........................................................................................................................................ 
Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicle 
classes.........................................................................................................................................................................41 
Type-approval requirements for CO2 measurement and fuel consumption determination and reporting and  
reporting ......................................................................................................................................................................41 
Evaporative emissions test and limit ...........................................................................................................................41 
7.2.1.4. 
Durability testing of anti-pollution devices and aged vehicles .....................................................................................41 
7.2.1.5. 
New measures to control vehicle emissions over vehicles in use................................................................................... 
7.2.2. 
In-Use Conformity (IUC) testing and limits ..................................................................................................................41 
7.2.2.1. 
On Board Diagnostic (OBD) systems and access to repair information......................................................................41 
7.2.2.2. 
New vehicle type approval safety measures ...............................................................................................................42 
7.3. 
Obligatory fitting of Advanced Brake Systems ............................................................................................................42 
7.3.1. 
Anti-tampering measures ............................................................................................................................................42 
7.3.2. 
74kW power limitation for motorcycles........................................................................................................................42 
7.3.3. 
Improved categorisation of L-category vehicles ..........................................................................................................42 
7.4. 
Electrical cycles (currently outside scope of Framework Directive), Tricycles and Quadricycles ...............................42 
7.4.1. 
6.4.2. Specific requirements for category L7e vehicles)..............................................................................................42 
7.4.2. 
7.4.3. 
Dedicated requirements for gaseous alternative fuels and other non-traditional propulsions.....................................42 
ANNEX I:  L-category vehicle definitions ......................................................................................................................................43 
ANNEX II:  Public consultation on outline proposals for a Regulation of the European Parliament and of the  

7.2.1.3. 

Council for L-category vehicles — Summary of Responses .......................................................................................45 
Context ........................................................................................................................................................................45 
Overview of respondents and analysis method...........................................................................................................45 
Summary of responses ...............................................................................................................................................45 

1. 
2. 
3. 
ANNEX III:  Description of the tasks requested to the external consultant TRL and methodology used — Policy 

Assessment report regarding possible safety measures.............................................................................................48 
Detailed description of the task to be performed.........................................................................................................48 
Methodology ................................................................................................................................................................48 

1. 
2. 
ANNEX IV: Description of the tasks requested to the external consultant LAT and methodology used — Policy 

assessment report regarding possible safety measures .............................................................................................49 
Subject of the service request .....................................................................................................................................49 
1. 
Detailed description of the tasks to be performed .......................................................................................................49 
1.1. 
1.2. 
Methodology ................................................................................................................................................................50 
ANNEX V:  Self obligation European motorcycle industry association (ACEM) ............................................................................51 
ANNEX VI: Self obligation European motorcycle industry association (ACEM) Environmental Aspects.......................................55 
ANNEX VII: Self obligation European motorcycle industry association (ACEM) Environmental aspects — Revised 

emission limits .............................................................................................................................................................58 
ANNEX VIII:Background to the type-approval system ...................................................................................................................59 
ANNEX IX: The Market for L-category vehicle in the EU ...............................................................................................................60 
The structure of the EU market ...................................................................................................................................60 
1. 
Electrical Cycles ..........................................................................................................................................................60 
2. 
Sales of Electric Cycles ...............................................................................................................................................60 
2.1. 
Powered-two wheelers (PTW).....................................................................................................................................62 
3. 
EuroStat data...............................................................................................................................................................62 
3.1. 
Type Approval data .....................................................................................................................................................62 
3.2. 
Import and export of motorcycles and motorcycle parts..............................................................................................63 
3.3. 
The impact of the new measures on international trade .............................................................................................64 
3.4. 
Production of PTWs ....................................................................................................................................................64 
3.5. 
PTW Price development over time..............................................................................................................................68 
3.6. 
Sales of PTWs.............................................................................................................................................................68 
3.7. 
Motorcycles .................................................................................................................................................................69 
7.4.4. 
Mopeds........................................................................................................................................................................69 
7.4.5. 
Upstream-Suppliers.....................................................................................................................................................69 
3.8. 
Downstream- sale, maintenance and repair................................................................................................................69 
3.9. 
Employment PTW industry ..........................................................................................................................................70 
3.10. 

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1.4. 

1.4. 
1.5. 

1.2. 
1.3. 

All Terrain Vehicles (ATVs)......................................................................................................................................... 71 
4. 
All Terrain Vehicle (ATV) sales in Europe .................................................................................................................. 72 
4.1. 
Employment ATV industry .......................................................................................................................................... 73 
4.2. 
5. 
Mini-cars ..................................................................................................................................................................... 73 
Annex X:  Details chapter 5 — Impact analysis — Simplification of legislation .......................................................................... 74 
ANNEX XI: Details chapter 5 — Impact analysis vehicle Type Approval Environmental measures ............................................. 75 
New or revised environmental measures for the type approval of new vehicles ........................................................ 75 
1. 
Revised lower emissions limits, detailed analysis of proposed limit by comparison with light duty 
1.1. 
M1 emission limits ...................................................................................................................................................... 75 
Qualitative analysis of the policy options to revise the emission limits ....................................................................... 90 
Revised lower emissions limits, summary of the cost effectiveness of the proposed emission limit  
options ........................................................................................................................................................................ 94 
Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicle...................... 95 
Type-approval requirements for CO2 measurement and fuel consumption determination and reporting and 
reporting...................................................................................................................................................................... 96 
Evaporative emissions test and limit........................................................................................................................... 97 
1.6. 
Durability requirements............................................................................................................................................... 98 
1.7. 
New measures to control emissions during vehicle life. ............................................................................................. 99 
2. 
In-Use Conformity (IUC) testing and limits. ................................................................................................................ 99 
2.1. 
2.2. 
On Board Diagnostic (OBD) systems and access to repair information ................................................................... 100 
ANNEX XII: Details chapter 5 — Impact analysis new vehicle Type Approval safety measures ................................................. 103 
Obligatory fitting of Advanced Brake systems .......................................................................................................... 103 
1. 
No change ................................................................................................................................................................ 103 
1.1. 
Anti-lock Brake Systems on all Powered Two Wheelers (PTW)............................................................................... 104 
1.2. 
Anti-lock Brake Systems on PTWs with cylinder capacity > 125 cm3 and Advanced Brake Systems (Combined 
1.3. 
Brake System (CBS) or Anti-lock Brake Systems(ABS)) on motorcycles  
with 50cm3 < cylinder capacity ≤ 125cm3.................................................................................................................. 105 
To make mandatory the fitting of Advanced Brake Systems (Combined Brake System (CBS) and/or Anti-lock  
Braking Systems) on those motorcycles which conform to the performance criteria defined by the A2 driving 
licence . Obligatory fitting of Anti-lock Brake Systems on all other L3e class motorcycles; ..................................... 106 
Industry self obligation .............................................................................................................................................. 107 
1.5. 
Anti-tampering measures.......................................................................................................................................... 108 
2. 
No change; ............................................................................................................................................................... 108 
2.1. 
Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures; ..................................... 109 
2.2. 
New measures on anti-tampering............................................................................................................................. 110 
2.3. 
3. 
74 kW power limitation for motorcycles .................................................................................................................... 111 
ANNEX XIII:Details chapter 5 — Impact analysis Improved categorisation of L-category vehicles ............................................ 112 
1. 

Electrical Cycles (outside scope of framework directive currently), Tricycles (L5e) and Quadricycles  
(Category L6e and L7e)............................................................................................................................................ 112 
2. 
Specific requirements for Category L7e vehicles ..................................................................................................... 113 
Dedicated requirements for gaseous alternative fuels and other non-traditional propulsions. ................................. 114 
3. 
ANNEX XIV:Details chapter 6 — options comparison and conclusions Simplification of the legislation..................................... 115 
ANNEX XV:Details chapter 6 — Options comparison and conclusions Vehicle Type Approval Environmental measures ........ 117 
New or revised environmental measures for the type approval of new vehicles ...................................................... 117 
1. 
Revised lower emissions limits. ................................................................................................................................ 117 
1.1. 
Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicle 
1.2. 
classes...................................................................................................................................................................... 119 
Type-approval requirements for CO2 measurement and fuel consumption determination and reporting and 
reporting.................................................................................................................................................................... 120 
Evaporative emissions test and limit......................................................................................................................... 121 
Durability requirements............................................................................................................................................. 122 
New measures to control emissions during vehicle life. ........................................................................................... 123 
In-Use Conformity (IUC) testing and limits. .............................................................................................................. 123 
On Board Diagnostic (OBD) systems and access to repair information ................................................................... 124 
Proposal for revised emission limits ......................................................................................................................... 125 
Proposal to revise emission limits for short and medium term ................................................................................. 125 
Proposal to revise emission limits for long term ....................................................................................................... 127 

1.4. 
1.5. 
2. 
2.1. 
2.2. 
3. 
3.1. 
3.2. 
ANNEX XVI:Details chapter 6 — options comparison and conclusions-Analysis New Vehicle Type Approval Safety  

1.3. 

1. 
1.1. 
1.2. 
1.3. 

1.4. 

1.5. 
1.6. 

1.6.1. 
1.6.2. 
1.6.3. 
1.6.4. 
1.6.5. 

measures .................................................................................................................................................................. 128 
fitting of Advanced Brake systems............................................................................................................................ 130 
No change ................................................................................................................................................................ 130 
Anti-lock Brake Systems on all Powered Two Wheelers (PTW)............................................................................... 130 
Anti-lock Brake Systems on PTWs with cylinder capacity > 125 cm3 and Advanced Brake Systems (Combined 
Brake System (CBS) or Anti-lock Brake Systems(ABS)) on motorcycles  
with 50 cm3 < cylinder capacity ≤ 125 cm3 .....................................................................................................................................................................................131 
Obligatory fitting of Advanced Brake Systems (Combined Brake System (CBS) and/or  
Anti-lock Brake Systems (ABS)) on motorcycles fulfilling the maximum performance criteria related to the A2 
driving licence. Obligatory fitting of Anti-lock Brake Systems on all other L3e class motorcycles............................ 132 
Industry self obligation .............................................................................................................................................. 133 
Impact Assessment of Anti-lock Brake System technology fitted on vehicles, manufactured and type approved  
by SMEs ................................................................................................................................................................... 134 
Introduction ............................................................................................................................................................... 134 
Regulatory Impacts on SMEs ................................................................................................................................... 134 
Economic Advantages .............................................................................................................................................. 134 
Possible Disadvantages ........................................................................................................................................... 135 
Potential Opportunities ............................................................................................................................................. 135 

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Potential Risks...........................................................................................................................................................135 
1.6.6. 
Anti-tampering measures ..........................................................................................................................................136 
2. 
No change; ................................................................................................................................................................136 
2.1. 
Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures; ......................................136 
2.2. 
New measures on anti-tampering. ............................................................................................................................137 
2.3. 
3. 
74 kW power limitation for motorcycle.......................................................................................................................138 
ANNEX XVII:Details chapter 6 — Options comparison and conclusions — Improved categorisation of L-category vehicles.....139 
re-categorisation Electrical Cycles (outside scope of framework directive currently), Tricycles (L5e) and 
1. 
Quadricycles (Categories L6e and L7e) ....................................................................................................................139 
Specific requirements for category L7e vehicles.......................................................................................................140 
Dedicated requirements for gaseous alternative fuels and other non-traditional propulsions...................................140 
Proposal to re-categorise L-category vehicles ..........................................................................................................141 

2. 
3. 
4. 
ANNEX XVIII:Details chapter 7 — – Monitoring & Evaluation Analysis New Vehicle Type Approval Simplification and  

Safety measures........................................................................................................................................................142 
Simplification .............................................................................................................................................................142 
1. 
Obligatory fitting of Advanced Brake systems ...........................................................................................................142 
2. 
Anti-tampering measures ..........................................................................................................................................142 
3. 
4. 
74kW power limitation for motorcycles......................................................................................................................142 
ANNEX XIX:Details chapter 7 — Monitoring & Evaluation Improved categorisation of L-category vehicles ...............................143 
1. 

Re-categorisation electric assisted CYCLES (outside scope of legal framework currently), Tricycles (L5e) and  
quadricycles (Categories L6e and L7e).....................................................................................................................143 
Specific requirements for Off-road quads (All Terrain Vehicles, ATVs) ....................................................................143 
2. 
3. 
Specific requirements for gaseous alternative fuels and other non-traditional propulsions. .....................................143 
ANNEX XX:Abbreviation List and Glossary..................................................................................................................................144 

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BACKGROUND INFORMATION AND POLICY CONTEXT 

Please refer to Annex XX at the back of this report for a list of abbreviations and a glossary of terminology. 

‘L-category  vehicles’  is  a  term  covering  a  wide  range  of  different  vehicle  types  with  two  or  three  or  four 
wheels, e.g. two- or three-wheel mopeds, two- or three-wheel motorcycles and motorcycles with side-cars. 
Examples of four-wheel vehicles, also known as quadricycles or quads, which also belong to the L-category 
vehicle family, are quads used on public roads, all-terrain vehicles (ATVs), which are quads designed to be 
used  off-road,  and  mini-cars.  Annex  I  provides  more  details  of  the  current  categorisation  criteria  for  L-
category vehicles. 
Type-approval requirements for new vehicles in the L category are currently set out in Directive 2002/24/EC1 
(the ‘Framework Directive’). In addition, a series of directives referred to in the Framework Directive contain 
detailed technical requirements relating to L-category vehicles. The Framework Directive became mandatory 
on 9 November 2003 for new types of vehicles. 
Type-approval legislation was addressed in the political initiative ‘CARS 21’2. This initiative was launched in 
2005 to carry out a regulatory and policy review of the automotive sector to advise the Commission on future 
policy  options.  One  of  the  reasons  for  launching  CARS  21  was  the  concern  expressed  by  automotive 
stakeholders  that  the  cumulative  cost  of  regulation  had  a  negative  effect  on  competitiveness,  and  made 
vehicles unnecessarily expensive. The CARS 21 Final Report3 concluded that while most of the legislation in 
force  should  be  maintained  for  the  protection  of  consumers  and  the  environment,  a  simplification  exercise 
should  be  undertaken  so  as  to  rationalise  the  regulatory  framework  and  move  towards  international 
harmonisation. This simplification exercise was planned in the ‘Commission second progress report on the 
strategy  for  simplifying  the  regulatory  environment’4.  Any  possible  initiative  should  be  aligned  with  this 
strategy.  
In line with the European strategy on air quality5, the EU has constantly strengthened emission standards for 
motor vehicles, in particular for hydrocarbons, carbon monoxide, nitrogen oxides and particulate matter. The 
contribution  of  L-category  vehicles  to  the  overall  reduction  sought  in  greenhouse  gases  is  another 
environmental aspect that is covered in this Impact Assessment. 

The  new  initiative  should  be  aligned  with  the  European  Road  Safety  Action  Plan  2011-2020  and  the 
European Road Safety Charter (ERSC)6, 2000-2010. The ERSC aimed to halve the number of road fatalities 
by  2010,  but  this  challenging  target  will  unfortunately  not  be  met.  Unfortunately,  L-category  vehicle  riders 
belong to a vulnerable road user group with the highest fatality and injury rates among all road users.  

Annex  IX  provides  detailed  information  on  the  market  for  L-category  vehicles,  as  registered  by  EuroStat. 
Where data were not available from EuroStat, the industry associations were requested to provide relevant 
information. The market is broadly composed of two sub-markets, the first comprising motorcycles and the 
second for scooters and mopeds. The motorcycle market is dominated by Japanese imports from companies 
such as Honda, Yamaha, Kawasaki and Suzuki. In a globalised world it is not any longer appropriate to refer 
only  to  traditional  European  companies  with  their  main  development  and  production  footprint  based  in 
Europe.  These  large  companies  with  their  head  offices  in  Japan  also  produce  and  develop  models  in 
Europe; they employ many European citizens and account for approximately 50 per cent of sales in the EU 
market. Large traditional EU-based motorcycle producers, also with their head offices in Europe are Piaggio, 
Peugeot,  BMW,  and  a  number  of  mid-sized  companies  like  KTM  and  Ducati,  which  account  for 
approximately  17 %  of  the  market  between  them.  In  recent  years  there  has  been  a  significant  increase  in 
imports from China. The United States is the largest export market for motorcycles from the EU. 

The second sub-market is the market for mopeds and scooters. This market is much more fragmented than 
the  motorcycle  market.  Piaggio,  Peugeot  and  Derbi  are  the  main  traditional  European  producers.  Asian 
manufacturers are again strongly represented in this segment, including manufacturers from China, Thailand 
and India, but they have less market share than in the motorcycle segment.  

1

2

3

4

5

6

Directive 2002/24/EC of the European Parliament and of the Council of 18 March 2002 relating to the type-approval of two or 
three-wheel motor vehicles and repealing Council Directive 92/61/EEC, OJ L 124, 9.5.2002, p. 1. For further information on 
the background to the type-approval system refer to Annex VIII. 
http://ec.europa.eu/enterprise/automotive/pagesbackground/competitiveness/cars21.htm. 
http://ec.europa.eu/enterprise/automotive/pagesbackground/competitiveness/cars21finalreport.pdf. 
COM(2008) 33 final, 30.1.2008, proposal No 49, p. 32. 
http://ec.europa.eu/environment/archives/cafe/general/keydocs.htm. 
http://www.erscharter.eu/. 

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In  all,  the  number  of  vehicles  currently  in  circulation  in  the  EU  is  estimated  at  over  30  million.  The  EU 
produces  over  1.1  million  vehicles  annually,  but  this  is  a  relatively  low  number  in  comparison  with  China, 
which  produces  over  20  million  vehicles  per  year,  India,  which  produces  8  million,  and  Taiwan,  which 
produces 1.5  million  vehicles.  However,  European  vehicles  are considered  to provide greater  added  value 
and higher quality. 

It is estimated that there are approximately 100 manufacturers of motorcycles or mopeds in the EU, about 
half  of  which  are  owned  by  European  companies.  The  estimate  was  based  on  different  data  sources 
including EuroStat, data from the type-approval authorities and a study by the University of Bologna, which 
was commissioned by industry. The number of SME producers operating in both the motorcycle and scooter 
markets  is  small,  although  the  scooter  market  has  more  SMEs.  The  combined  market  segments  have  a 
turnover of approximately € 4.1 billion. 

While  approximately  60 000  people  are  employed  in  the  manufacture  of  motorcycles  and  cycles,  the  total 
number  of  persons  employed  by  the  industry  as  a  whole  is  estimated  at  approximately  165 000,  when  all 
aspects  of  the  market  are  taken  into  consideration,  including  the  upstream  and  downstream  sectors.  As 
regards employment, the main countries are Italy, Spain, France, Germany and the United Kingdom.  

A third, downstream sub-market is the sale, maintenance and repair of motorcycles. This market is extremely 
significant  and,  in  2006,  generated  € 3. 4  billion  in  value  added  from  a  turnover  of  over  € 24.8  billion  in  the 
EU-27  (EuroStat  estimate).  105 000  persons  were  employed  by  the  37 000  enterprises  in  the  motorcycle 
distribution sector It is estimated that 72 % of the total industry’s turnover is generated in this sector. 

The Impact Assessment Board (IAB) of the EU Commission issued an opinion on the present report after its 
meeting  on  16  December  2009.  The  Board’s  recommendations  were  used  to  revise  and  improve  the 
presentation of the analysis and the overall quality of the report. The references to the annexes to chapters 
5, 6 and 7 were made into links so that all the qualitative and quantitative elements of every policy option are 
readily accessible in the main report. The ‘industry self-regulation’ option for advanced brake systems was 
elaborated  on  in  chapter  6.3.1  and  additional  information  on  the  industry  proposal  for  new  emission  limits 
was added in chapter 6.2.1.1 to meet the IAB recommendation to make it clearer whether self-regulation is a 
feasible option or not. The desirable use of international standards, like UNECE regulations, was explained 
in more detail in chapters 4.1, 4.2.11, 5.1 and 6.1. The global impacts of the measures on international trade 
were explained in Annex VIII, chapters 3.3 and 3.4. The Commission’s level of ambition regarding suggested 
standards for pollutant emissions was also added to chapter 3.1.2. A summary table of preferred options with 
associated  references  to  the  detailed  analysis  and comparison  in  the  main  text  was  added to  chapter  6.5. 
Chapters  5.2.1.3  and  6.2.1.3  were  further  developed  regarding  CO2  emissions  and  fuel  consumption 
determination and reporting at type approval to pave the ground for future introduction of energy efficiency 
labelling. Finally, the references to monitoring and evaluation arrangements were improved in chapter 7 by 
inserting  active  links  to  this  topic  in  Annexes  XVIII  and  XIX.  In  addition,  it  was  explained  who  would  be 
responsible  for  collecting  data  for  monitoring  and  evaluation  and  when  a  study  was  to  be  conducted  to 
evaluate and compare the regulator’s target with the actual situation at a future point in time.  

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 
Organisation and timing 

1. 
1.1. 
This  proposal  is  an  item  in  the  Commission’s  Work  Programme  2010  and  is  scheduled  in  its  Agenda 
Planning under the reference 2010/ENTR/02. 
A roadmap has been established for this proposal, including an impact assessment, and has been included 
in  the  Agenda  Planning  for  2010.  An  Impact  Assessment  Steering  Group,  consisting  of  members  of  the 
Commission services concerned (DG ENV, DG MOVE and DG ECFIN), was set up and met on 14 August, 5 
November and 16 November 2009 

Public consultation 

1.2. 
A  public  consultation7  was  held  from  22  December  2008  to  27  February  2009  to  seek  the  opinions  of 
associations, companies and public authorities on key aspects of potential measures for the type-approval of 
L-category  vehicles.  In  particular,  stakeholder  views  were  sought  on  the  simplification  of  the  current 
legislation, on the environmental and safety aspects of L-category vehicles and on the possible need to align 
legal  measures  with  technical  developments.  Opinions  were  sought  especially  on  items  perceived  to  be 
controversial, e.g.: 

7

http://ec.europa.eu/enterprise/automotive/consultation/2_3_wheelers/contributions.htm. 

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7 

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– 

– 

Obligatory fitting of advanced brake systems8 on powered two-wheelers. On this point, 29 % of all 
respondents  were  against,  24 %  were  neutral  or  had  no  opinion  and  49 %  were  favourable  or 
relatively favourable. 

Environmental  measures,  e.g.  introduction  of  revised,  lower  emission  limit  values.  In  response  to 
the question ‘Do you support the introduction of new emission limits for motorcycles equivalent to 
the  Euro  5  limits  for  petrol  cars?’,  17 %  were  against,  32 %  had  no  comments  and  52 %  were 
favourable or relatively favourable. 

Please see Annex II for the executive summary of the consultation report9, summarising the results of this 
public consultation. The present report explains how the opinions of stakeholders were taken into account in 
weighing up the different pros and cons of the policy options considered. 

In  addition  to  the  public  consultation  over  the  internet,  some  20  bilateral  meetings  were  held  with 
stakeholders in 2009. From 2002 onwards, two working groups, the Motor Cycle Working Group10 (MCWG) 
and  the  Motor  Vehicle  Emission  Group  (MVEG),  met  on  a  number  of  occasions11  to  discuss  L-category 
vehicle  legislation.  At  these  meetings,  Member  State  experts,  associations  representing  the  L-category 
vehicle industry and vehicle users, and non-governmental organisations expressed their views on what the 
new  regulation  was  supposed  to  achieve  and  on  the  envisaged  policy  options.  The  most  recent  MCWG 
meetings were held in February and June 2009. A third MCWG meeting was held on 14 December 2009. 

External expertise 

1.3. 
Two studies were carried out in the course of 2008 and 2009 with the aim of evaluating the economic, social 
and environmental impacts of proposals for L-category vehicle type-approval. 

TRL Ltd was brought in as an external consultant to study potential safety measures for L-category vehicles 
and  also  to  investigate  the  impact  of  simplification  on  existing  L-category  vehicle  legislation.  A  report  (‘the 
TRL report12’) was issued and published on the Commission’s website. A consortium of institutes comprising 
TNO  (lead  institute),  the  University  of  Thessaloniki  (LAT),  BAST,  EMPA  and  TÜV  Nord  produced  a  study 
report  on  potential  environmental  measures  for  L-category  vehicles13  (‘the  LAT  report’).  These  two  policy 
reports provided the main inputs to the impact assessment. The quantitative cost and benefit estimates in the 
present  report  are  based  on  both  policy  reports.  Annex  III  and  Annex  IV  provide  a  brief  overview  of  the 
methodology used by both contractors. 

Industry self-regulation and legislative proposals 

1.4. 
ACEM, the European motorcycle industry association, proposed self-regulation on certain safety aspects of 
L-category vehicles, e.g. fitting of advanced brake systems on powered two-wheelers. They also proposed a 
package  of  environmental  measures  to  be  included  in  the  new  L-category  vehicle  regulation  in  order  to 
proactively address various environmental and safety concerns identified and described in the TRL and LAT 
reports. The commitments proposed by ACEM can be found in Annexes V, VI, and VII. 

2. 

PROBLEM DEFINITION AND RIGHT TO ACT 

Problem definition 

2.1. 
The Commission has identified a number of key concerns associated with the current provisions for the type-
approval of L-category vehicles:  

Complexity of the current legal framework 

2.1.1. 
It has been pointed out to the Commission that the existing system for L-category vehicles is too complex 
and that there is therefore scope for simplification and international harmonisation.  

The  type-approval  system  is  generally  recognised  as  an  effective  framework  for  tackling  various  aspects 
(functional and occupational safety, environment). However, the national authorities in charge of applying the 
Framework  Directive  are  facing  unnecessary  additional  costs  in  their  attempts  to  operate  in  this  complex 
regulatory  framework.  Many  stakeholders  have  called  upon  the  Commission  to  simplify  the  regulatory 

8

9

10

11

12

13

Refer to the glossary at the end of this report for a technical explanation of anti-lock brake systems. 
http://ec.europa.eu/enterprise/automotive/consultation/2_3_wheelers/results_report.pdf. 
http://ec.europa.eu/enterprise/automotive/mcwg_meetings/index.htm. 
http://ec.europa.eu/enterprise/automotive/mveg_meetings/index.htm. 
http://ec.europa.eu/enterprise/automotive/projects/report_new_measures_l_category.pdf. 
http://ec.europa.eu/enterprise/automotive/projects/report_measures_motorcycle_emissions.pdf. 

EN 

8 

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framework in order to ensure a less burdensome and less time-consuming approach to type-approval. This 
objective has thus been included in the Simplification Rolling Plan. 

L-category vehicles have to comply with a series of requirements found in a number of separate directives. 
The Framework Directive is linked to 13 detailed technical directives, which themselves have been amended 
by  21  amending  directives  so  as  to  ensure  that  they  accurately  reflect  technical  progress (for  example, by 
allowing  the  use  of  an  alternative  world-standard  driving  cycle  with  associated  EU-defined  exhaust  gas 
limits). For formal reasons, all these separate directives must be applied individually. 

The Framework Directive lays down the legal type-approval requirements for light two-, three- and four-wheel 
vehicles such as mopeds, motorcycles, tricycles and quadricycles. Both the enacting terms of the technical 
directives and their annexes are highly detailed and leave Member States practically no room for discretion 
when transposing them. Thus, some Member States simply make direct reference to those directives, while 
others opt to develop a completely new legislative text to transpose those requirements. 

In  addition,  many  directives  contain  references  to  regulations  and  standards  applied  worldwide,  such  as 
those  adopted  by  UNECE14,  which  are  subject  to  amendments.  Ultimately,  the  disparate  nature  of 
regulations governing the type-approval of L-category vehicles leads to a lack of legal and regulatory clarity. 
Industry  and  regulators  need  to  be  familiar  with  37  EU  directives  and  in  parallel  34  UNECE  regulations, 
which  may  be  equivalent.  To  consistently  update  these  can  be  a  burdensome  process  and  results  in 
additional  costs  for  administrations  and  industry.  For  industry,  this  regulatory  complexity  and  uncertainty 
leads to unnecessary compliance costs for the type-approval of new vehicles. Other concerns expressed in 
the public consultation were the weakening of existing EU requirements and less transparency owing to the 
decision-making process taking place in a ‘remote’ international institution such as UNECE. 

Nevertheless, amending directives have to be transposed by Member States, and this has led to difficulties 
for  EU  manufacturers,  as  national  transpositions  may  differ  slightly,  for  example  concerning  dates  of 
publication and entry into force and even (mis-)interpretations with regard to the substantive requirements, 
leading  to  misunderstanding  between  type-approval  authorities.  This  problem  is  inherent  in  any  EU 
legislation adopted in the form of a directive, but it is particularly acute in this case, where the requirements 
are highly technical, very detailed, and likely to be often amended owing to frequent adaptations to technical 
progress.  Transposition  then  makes  demands  on  the  resources  of  national  administrations  without  adding 
any  value  in  terms  of  safety  or  environmental  protection.  Additional  administrative  resources  are 
consequently required to solve the resulting problems of interpretation, which crop up on a regular basis in 
the  Type-Approval  Authorities  Meeting  (TAAM),  bringing  together  representatives  of  Member  States  and 
Commission departments. 

Regulations adopted by UNECE, under the 1958 Agreement, are widely recognised in countries inside and 
outside  the  EU,  and  the  EU  has  acceded  to  many  of  these.  The  promotion  of  international  standards  is 
supported by industry. But in the current situation, provisions are often duplicated in European legislation, or 
are similar in terms of technical requirements but differ in formal details. An example is the date of entry into 
force of an amendment to a directive, which is usually different as a result of (lengthy) procedures to update 
the  directive  after  e.g.  UNECE  has  introduced  an  amendment  in  its  regulation  on  the  same  subject.  This 
gives rise to concerns of non-transparency and unnecessary administrative burden.  

The  administrative  burden  in  this  ‘no  change’  scenario  is  significant.  Based  on  the  cost  estimates  of  six 
Member States, the cumulative cost to the EU27 Member States between 2009 and 2020 was estimated by 
the consultant to be € 3.1 million in total, despite the fact that the scenario is called ‘no change’. 

This high cost will remain and is likely to increase if no simplification exercise is carried out to delete obsolete 
measures and to reduce complexity. 

High level of emissions 

2.1.2. 
The internal combustion engines of L-category vehicles, which convert chemical energy (fuel) into movement 
and heat, emit toxic air pollutants and greenhouse gases as undesirable by-products. Evaporative emissions, 
mainly  hydrocarbons  from  positive-ignition  (PI)  fuel  storage  and  supply  systems  are  also  considered  to  be 
toxic.  Toxic  air  pollutants,  e.g.  certain  hydrocarbons,  are  known  or  suspected  to  cause  cancer  or  other 
serious  health  effects,  such  as  reproductive  or  birth  defects,  or  may  cause  other  adverse  environmental 
effects. 

14

http://www.unece.org/trans/main/wp29/wp29wgs/wp29gen/wp29pub/wp29pub2002e.pdf. 

EN 

9 

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Two  pollutants,  fine  particulate  matter  and  ground-level  ozone,  are  generally  recognised  as  the  most 
significant in terms of health impacts. Long-term and peak exposures can lead to a variety of health effects, 
ranging  from  minor  effects  on  the  respiratory  system  to  premature  mortality.  Since  1997,  up  to  45 %  of 
Europe’s  urban  population  may  have  been  exposed  to  ambient  concentrations  of  particulate  matter  above 
the  EU  limit  set  to  protect  human  health;  and  up  to  61 %  may  have  been  exposed  to  levels  of  ozone  that 
exceed  the  EU  target  value.  It  has  been  estimated  that  PM2.5  (fine  particulate  matter)  in  air  has  reduced 
statistical  life  expectancy  in  the  EU  by  more  than  eight  months15.  Common  pollutants16  that  are  currently 
regulated for L-category vehicles are hydrocarbons, carbon monoxide and nitrogen oxides. Particulate matter 
emissions are not regulated17. 

The introduction of the Euro 5 & 6 passenger car emission standards and the Euro VI heavy-duty emission 
standards means that the contribution of L-category vehicles will become increasingly important in the years 
to come. For example, it is estimated (in the LAT report) that total hydrocarbons (THC) emitted by L-category 
vehicles will increase from a share of 38 % to 62 % of the total hydrocarbon emissions (sum of evaporative 
and exhaust emissions) of the entire road transport sector by 2020, if no additional measures are taken. This 
is  mainly  due  to  the  significant  reductions  in  hydrocarbon  emissions  from  other  road  transport  categories. 
Mopeds  are  already  today  one  of  the  most  significant  contributors  to  hydrocarbon  emissions,  and  are 
expected to account for 36 % of total road transport emissions by 2020. 

]
n
t
[

C
H

1.6E+06

1.4E+06

1.2E+06

1.0E+06

8.0E+05

6.0E+05

4.0E+05

2.0E+05

0.0E+00

Evapo ration
TriQua d Gasoline
TriQua d Diesel
Motorcycles
Mopeds
All o ther ve hicles

40%

35%

30%

25%

20%

15%

10%

5%

0%

L-category vehicle 
hydrocarbon (HC) 
emission share  

[% of all road transport 
hydrocarbon emissions] 

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

Figure  1:  For  L-category  vehicles,  trend  over  time  in  absolute  and  relative  shares  of  hydrocarbon  emissions,  assuming  no 
change in policy18 

CO  emissions  are  high  and  are  expected  to  rise  from  a  share  of  about  20 %  to  around  36 %  of  total  road 
transport emissions in 2020. 

TriQuad Gasoline
TriQuad Diesel
Motorcycles
Mopeds
All other vehicles

]
n
t
[

O
C

1.2E+07

1.0E+07

8.0E+06

6.0E+06

4.0E+06

2.0E+06

0.0E+00

35%

30%

25%

20%

15%

10%

5%

0%

L-category vehicle carbon 
monoxide (CO) emission 
share  

[% of all road transport 
carbon monoxide 
emissions] 

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

15

16

17

18

Quote from EEA: http://www.eea.europa.eu/themes/air/about-air-pollution. 
Health effects of common pollutants: http://www.eea.europa.eu/publications/2599XXX/page008.html. 
http://pubs.healtheffects.org/view.php?id=282. 
NB. ‘All other vehicles’ includes passenger cars, delivery vans, trucks and buses. Source: LAT report. Primary  Y-axis (left): 
HC = hydrocarbon emissions; 2.0E+05 = 200 000, 1.0E+06 = 1 000 000, 1 tn = 1000 kg. Secondary Y-axis (right): L-category 
vehicle hydrocarbon (HC) emission share as % of all road transport HC emissions 

EN 

10 

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Figure 2: For L-category vehicles, trend over time in, absolute and relative share of carbon monoxide emissions, assuming no 
change in policy19. 
In a number of southern European cities, powered two wheelers are banned from city traffic in the event of a 
fine dust alarm on hot summer days to prevent excessive particulate emissions. EU legislation for trucks and 
cars  is  proving  successful  in  sharply  reducing  overall  emitted  pollutant  levels  throughout  Europe,  going  by 
the  most  recent  emission  levels  measured.  L-category  vehicles  need  to  contribute  proportionately  to  this 
success story, especially given that they will produce significantly more total hydrocarbons (from exhaust and 
evaporative  emissions)  than  passenger  cars  and  trucks  together  in  2020.  At  the  same  time,  they  are 
responsible  for  only  3 %  of  total  road  transport  mileage.  The  source  of  the  emission  problems  are  the 
polluting vehicles currently in circulation. As powered two-wheelers have on average a longer life20 than e.g. 
passenger cars, it takes a long time before new emission limits take effect on air quality. 

The present legal framework for L-category vehicles emissions was adopted in 2002. Since then technology 
has evolved rapidly. Given the wide diversity of vehicle construction, design and propulsion technology now 
on the market, the current legal framework is no longer up to date in environmental terms. 
Another concern is the proliferation of laboratory testing cycles21 currently used to test the emissions of the 
different L-category vehicles. The results of an emission test carried out under laboratory conditions should 
reflect  the  vehicle’s  real-world  emission  performance.  In  order  to  be  able  to  compare  different  means  of 
transport  in  terms  of  environmental  performance  and  fuel  consumption,  there  should  ideally  be  only  one 
single testing cycle, regardless of whether a truck, a passenger car, a motor cycle or a quadricycle is being 
tested. For historical and certain physical reasons, this has not been the case, which means that there are 
currently four different testing cycles for the seven subcategories of L-category vehicles. For L3e motorcycles 
alone  there  are  two  optional  testing  cycles,  although  manufacturers  only  seem  to  use  the  World-wide 
Motorcycle  emissions  Testing  Cycle  WMTC)  to  type-approve  a  vehicle.  The  traditional  European  Driving 
Cycle (EDC) with associated limits and testing procedures may therefore have become obsolete. In addition, 
consumers are complaining that the fuel consumption measured in the laboratory test cycle does not match 
real-world fuel consumption, so the fuel bill for consumers can be higher than expected if the published fuel 
consumption is based only on the figure measured in a non-representative test cycle. 
UNECE WP29 is eagerly waiting for the EU to publish new emission limits that match the WMTC test cycle22 
and  help  address  global  pollutant  emission  concerns.  The  WP29  contracting  parties  are  considering 
incorporating the new Euro limit values into global23 technical regulation No. 2. This will be the first time in 
WP29 history that contracting parties adopt emission performance limits in a global emission test cycle, as 
historically only test conditions have been regulated and each contracting party has had its own proprietary 
testing cycle and emission pollutant limits for type-approval or self-certification. Consequently, the speed with 
which possible Euro limits enter into force in the EU is a possible global concern. 

The non-toxic greenhouse gases (GHGs) emitted by PTWs, e.g. CO2, represent overall a very small share of 
total road transport emissions. 

]
n
t
[
2
O
C

1.0E+09

9.0E+08

8.0E+08

7.0E+08

6.0E+08

5.0E+08

4.0E+08

3.0E+08

2.0E+08

1.0E+08

0.0E+00

TriQuad Gasoline
TriQuad Diesel
Motorcycles
Mopeds
All other vehicles

1.2%

1.0%

0.8%

0.6%

0.4%

0.2%

0.0%

L-category vehicle carbon 
dioxide emissions (CO2) 
share 

[% of all road transport 
CO2 emissions] 

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

19

20

21

22

23

NB. ‘All other vehicles’ includes passenger cars, delivery vans, trucks and busses. Source: LAT report. Primary Y-axis (left): 
CO = carbon monoxide emissions; 2.0E+06 = 2 000 000; 1.0E+07 = 10 000 000, 1 tn = 1000 kg. Secondary Y-axis (right): L-
category vehicle carbon monoxide (CO) emission share as % of all road transport CO emissions. 
The LAT report, chapter 2.2. 
In the LAT report, chapter 2.3.1, pp.37 – 39, the three different test cycles are described in more detail. 
http://www.unece.org/trans/doc/2009/wp29/ECE-TRANS-WP29-2009-132e.pdf. 
http://www.unece.org/trans/main/wp29/wp29wgs/wp29gen/wp29registry/gtr2.html. 

EN 

11 

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Figure  3:  For  L-category  vehicles,  trend  over  time  in  absolute  and  relative  share  of  CO2  emissions,  assuming  no  change  in 
policy 24. 
However, it is not obvious to the average consumer if a vehicle is fuel-efficient and what level of CO2 it emits, 
as  there  are  currently  no  labelling  requirements  (unlike  for  passenger  cars).  The  L-category  vehicle 
manufacturer is not obliged to officially declare the CO2 emissions of an L-category vehicle, nor must the fuel 
consumption be determined and officially declared to obtain type-approval for a new vehicle. Given the much 
lower CO2 emissions of PTWs per passenger, compared to passenger cars, an increase in trips made using 
PTWs  instead  of  passenger  cars  will  actually  have  a  positive  effect  in  reducing  overall  CO2  emissions  by 
road  transport.  To  inform  the  consumer  in  a  clear,  concise  and  harmonised  way,  objective  measurement 
data are needed, e.g. measurements of CO2 emissions and fuel consumption in type-approval demonstration 
testing. For passenger cars, for example, such objective measurement data are officially reported and used 
as a basis for a labelling scheme, which is currently not the case for L-category vehicles. This is therefore a 
concern from the perspective of consumer information. 
At the 9th meeting of the MVEG on 20 October 2008, the exhaust after-treatment industry association, AECC, 
presented a study25 on durability testing. For one of the five tested motorcycles CO emissions reached the 
Euro 3 limit after only a mileage of 2000 km and NOx type-approval limits were already exceeded after 5 000 
km. Mileage accumulation was stopped after 20 000 km, as NOx had reached the stop criterion for the test, 
set at 200 % of the Euro 3 NOx limit. This vehicle was analysed and no obvious failure was found, leading to 
the  conclusion  that  the  exhaust  after-treatment  system  had  aged  rapidly  and  had  lost  its  ability  to  reduce 
emissions. This means in practice that older vehicles in use may emit more than twice the limits after only 
20 000  km.  The  deterioration  in  emission  performance  over  vehicle  life  is  not  a  specific  problem  of  L-
category  vehicles.  For  other  road  vehicles  with  combustion  engines  (cars,  trucks)  equipped  with  exhaust 
after-treatment  systems,  this  concern  was  already  raised  several  decades  ago.  L-category  vehicles  are 
currently  the  only  type  approved  vehicle  types  not  subject  to  any  legal  durability  requirements  in  the  EU. 
Other countries (USA, India, China, Thailand, Taiwan and Singapore) have durability requirements for such 
vehicles too. 
An integral approach involving periodical technical inspection (PTI)26, road-side inspection (RSI)27 and in-use 
conformity (IUC) testing and limits may be required for vehicles already in use in order to identify possible 
environmental and/or safety concerns with such vehicles. In practice, only a proper balance in testing effort 
and frequency employing a mix of PTI, RSI and IUC testing will ensure that the emissions of mass-produced 
vehicles  remain  under  the  type-approval  limits,  as  there  is  a  certain  overlap  between  these  types  of  tests. 
Applying only one of these three test types has proven with passenger cars to be insufficient to guarantee 
effective  and  efficient  monitoring  of  vehicle  emissions  and  safety  over  vehicle  life.  It  is  therefore  not 
conducive  to  effective  and  efficient  repair  and  maintenance  over  vehicle  life  if  only  one  of  these  tests  is 
regularly carried out. Environmental or safety problems may be caused by a component suddenly breaking 
down  or  by  degradation  or  reduced  efficiency  of  vehicle  components  and  systems  over  vehicle  life,  due 
possibly  to  bad  vehicle  maintenance,  bad  quality  of  replacement components, etc.  PTI  and RSI  legislation 
fall outside the scope of this new Regulation for the type-approval of new vehicles. This means that only the 
impact of IUC testing is considered in the present Report. The main problem is that none of the three tests 
are currently harmonised or covered in the EU legal framework. This means that once a limited number of 
representative new vehicles have passed type-approval demonstration testing there is no further harmonised 
monitoring or market surveillance mechanism to check whether mass-produced vehicles continue to comply 
with emission and safety regulations while ageing and accumulating mileage. 

Finally,  a  clean  vehicle  may  turn  into  a  high  polluter  if  an  emission-relevant  component  or  system  fails  or 
excessively degrades. In order to effectively and efficiently repair such failures, any independent repair shop 
needs: 

-  Standardised  diagnostic  information  on  possible  malfunctions  leading  to  environmental  and/or  safety 
problems. The on-board diagnostic system on a vehicle should make this information available to a generic 
scan  tool  (not  just  a  proprietary  OEM  scan  tool  obtainable  only  by  contract  repairers).  Such  information  is 
critical to understanding what the actual problem is with the vehicle and what needs to be done to effectively 
and efficiently repair the vehicle. 

24

25

26

27

NB. ‘All other vehicles’ includes passenger cars, delivery vans, trucks and buses. Source: LAT report. Primary  Y-axis (left): 
CO2 = carbon dioxide emissions; 1.0E+08 = 100 000 000; 1.0E+09 = 1 000 000 000,; 1 tn = 1000 kg. Secondary Y-axis (right): 
L-category vehicle carbon dioxide (CO2) emission share as % of all road transport CO2 emissions 
http://ec.europa.eu/enterprise/automotive/mveg_meetings/motos/aecc.pdf. 
http://en.wikipedia.org/wiki/Vehicle_inspection. 
http://ec.europa.eu/transport/road_safety/vehicles/roadworthiness/roadside_en.htm. 

EN 

12 

   EN 

 
                                                 
 
 
 
 
- Access to repair and maintenance information developed by the manufacturer of the vehicle. Unfortunately, 
this  is  currently  possible  only  for  contract  repair  shops,  not  for  independent  dealers,  which  is  not  only  a 
competition problem but also has high pollutant emissions as a negative side-effect. 

High road fatalities and safety risks 

2.1.3. 
L-category drivers face a much higher risk of fatal or serious accidents than other drivers. The fatality rate 
per million kilometres travelled is, on average, 18 times greater than for passenger cars. In 2006, powered 
two wheelers accounted for 2 % of the distance travelled but 16 % of road deaths in the EU-25 (ETSC, 2007). 
Furthermore, while other vehicle types have seen significant decreases in fatalities and serious injuries over 
time, the figures for powered two wheelers have fallen much more slowly or remained static. 

In 2008, 5 520 PTW riders died in road accidents. In addition the number of serious injuries is estimated to 
be 5.5 to 13 times higher than the number of fatalities (30 000 – 72 000). The number of slight injuries, which 
is even more difficult to estimate, might be between 12 to 28 times higher (66 000 – 155 000 riders) in the 
EU-27. 

Evolution of fatalities
in EU road accidents

t
n
e
d
i
c
c
a

d
a
o
r

s
e
i
r
o
g
e
t
a
c

r
e
h
t
O

70,000

60,000

50,000

s
e
i
t
i
l
a
t
a
f

40,000

30,000

20,000

10,000

0

69,147

6,225

64,908

60,125

58,777

58,308

5,708

5,197

5,069

55,268

54,111

52,650

5,304

5,309

5,315

5,593

5,406

5,394

54,720

4,799

4,637

4,957

4,834

49,010

47,801

44,536

41,861

39,458

37,545

36,924

33,111

7,000

5,778

6,000

5,520

5,000

s
e
i
t
i
l
a
t
a
f
e
l
c
y
c
r
o
t
o
M

4,000

3,000

2,000

1,000

0

1
9
9
1

2
9
9
1

3
9
9
1

4
9
9
1

5
9
9
1

6
9
9
1

7
9
9
1

8
9
9
1

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

So ur ce: C A R E  ( EU   r o ad   acci d ent s  d at ab ase)

Other categories road accident fatalities

Motorcycles only

Figure 4: Road fatalities among powered two wheeler riders in the EU over time 

.

Figure 5: Probability of fatal injury depending on relative speed upon collision. 
Source: OECD presentation, International Transport Forum and Vulnerable Road User workshop (DG TREN, 15 July 2009) 

The  human  body’s  tolerance  to  physical  force  is  limited.  According  to  the  World  Health  Organisation, 
pedestrians incur a risk of around 80 % of being killed at an impact speed of 50 km/h. However, this risk is 
reduced  to  only  10 %  at  30  km/h.  There  is  no  difference  between  a  slow-moving  pedestrian  hit  by  a  fast-
moving car or a PTW rider colliding with a fixed object at 50 km/h. It is the difference in speed upon collision 
that leads to fatalities and heavy injuries in road accidents. 

EN 

13 

   EN 

 
 
 
 
 
 
 
 
In general, on a competitive market aiming to satisfy consumer preferences, vehicle manufacturers will try to 
find the best compromise between driveability and performance (torque and power) on the one hand and fuel 
consumption and fulfilling legal emission requirements on the other. This delicate balance achieved by the 
manufacturer during development may be significantly disturbed through after-sales tampering with the type-
approved  settings  by  or  on  behalf  of  the  consumer.  Tampering  may  improve  driveability  and  engine 
performance but at the cost of significantly higher emissions and fuel consumption. At the same time, higher 
engine  performance  increases  the  maximum  vehicle  speed  beyond  that  for  which  the  other  vehicle 
components  are  designed,  leading  e.g.  to  under-performing  brakes,  power  train  components  not  able  to 
withstand  forces  acting  upon  them,  etc.  All  this  can  easily  lead  to  an  unsafe  vehicle  for  both  rider  and 
environment. For this reason, anti-tampering measures are included in the current Framework Directive for 
mopeds and low-displacement motorcycles. However, due to the shift from mechanical to electronic engine 
control or the use of other types of propulsion (e.g. electrical or hybrid engines), the current measures may 
no longer be effective or may even be obsolete. 

Mini-cars are defined as four-wheel vehicles with limited performance and mass. These are typically used in 
rural areas by older people who have never obtained a driving licence. Other users in urban areas may be 
younger drivers starting to learn to drive or drivers with court convictions who have been banned from driving 
a  car.  Some  Member  States  even  today  have  no  driving  licence  requirements  for  this  vehicle  type.  The 
problem  with  these  vehicles  is  that  drivers  may  assume  the  same  level  of  active  and  passive  safety  as  in 
passenger  cars.  However,  their  design  concept,  lower  maximum  speeds  and  less  strict  type-approval 
requirements  means  that  this  assumption  is  not  necessarily  correct.  The  lower  safety  of  mini  cars  in 
comparison with passenger cars has therefore been identified as a concern. 

Another  area  of  concern  for  safety  is  that  certain  quadricycles,  quads  designed  to  be  used  off-road  (all-
terrain vehicles or ATVs) are frequently driven on public roads. As their name suggests, these vehicles are 
mainly intended to be used off-road. Often, non-certified versions of an ATV, for use only off-road, are also 
sold in the same shop. Using ATVs on the road may raise safety issues because of their high acceleration 
capability and their high centre of gravity, which can result in the vehicle rolling while cornering. The absence 
of  a  differential  on  the  driven  axle(s),  which  is  advantageous  in  terrain,  causes  the  vehicle  to  drift  through 
bends  on  asphalt.  Every  other  type  of  three-  or  four-wheel  vehicle  driven  predominantly  on  asphalt  is 
equipped  with  a  differential28  or  a  similar  device,  as  this  is  a  basic  safety  feature  of  such  vehicles.  The 
absence of a differential can be compared with a passenger car equipped without windscreen wipers during 
rainfall.  The vehicle  will  drive  and  the  driver  may  adapt  its  speed  to  move  through  traffic,  but  it  is  far  from 
being  safe,  both  for  drivers  and  their  environment.  In  a  number  of  EU  cities,  the  use  of  such  vehicles  is 
prohibited.  In  2003,  the  total  fleet  was  estimated  to  be  only  95 000  vehicles.  Four  years  later  in  2007, 
158 000 vehicles of this type were sold and the fleet size was estimated at 800 000 vehicles on EU roads. 

Gaseous fuels, for example CNG, LPG and hydrogen, are perceived by consumers as dangerous and as a 
potential  safety  risk,  although  they  may  provide  significant  environmental  benefits.  Safety  concerns  may 
include  e.g.  unsafe  fuel  storage  design  or  the  possibility  of  fuel  tubing  connectors  becoming  loose  due  to 
engine vibrations, etc. At the time of analysis in the impact assessment hydrogen technology for L-category 
vehicles was considered to be not mature. Other alternative propulsion technology may be mature for mass 
vehicle production, but may at the time of the impact assessment be not statistically relevant for the accident 
and safety statistics yet.  

Lack of a legal framework for new technologies 

2.1.4. 
L-category  vehicle  technology  has  evolved  very  fast  over  the  last  decade.  The  development  of  the 
associated legislation has been much slower, with the result that certain vehicles can no longer be allocated 
to  the  right  L-vehicle  category  and  a  number  of  current  measures  under  the  Framework  Directive  are  no 
longer  appropriate.  For  example,  the  current  measures  do  not  apply  to  L-category  vehicles  with  purely 
electric  propulsion.  For  a  moped  with  a  small  combustion  engine,  anti-tampering  measures  should  mainly 
address mechanical manipulation, whereas measures to prevent engine management tuning may be more 
appropriate for both electric vehicles and vehicles equipped with a traditional combustion engine. For hybrid 
vehicles,  both  types  of  measures  may  be  required.  Categorisation  is  therefore  an  issue  affecting  many 
aspects of the concerns raised above: complexity of the legal framework, safety and environmental issues. 

28

EN 

the 

the  outer  wheel,  so  with  no  
When  cornering, 
differential,  the  result  is  the  inner  wheel  spinning  and/or  the  outer  wheel  dragging,  resulting  in  difficult  and  unpredictable 
handling,  damage 
train. 
http://en.wikipedia.org/wiki/Differential_(mechanical device). 

travel  a  shorter  distance 

roads,  and  strain  on 

inner  wheel  needs 

the  entire  drive 

(or  possible 

failure  of) 

tires  and 

than 

to 

to 

14 

   EN 

 
                                                 
 
For  example,  on-road  quads,  off-road  quads  and  mini-cars  currently  all  fall  within  the  same  subcategory, 
L7e, and are all subject to the same requirements. However, quads and mini-cars are inherently so different 
in  design  that  they  each  require  specific  legal  requirements  to  be  safe  and  comply  with  appropriate 
environmental standards. Low-power electric cycles (less than 250 W, up to 25 km/h) currently fall outside 
the  legal  framework.  In  addition,  more  powerful  cycles  of  up  to  1 000  W  are  also  becoming  very  popular29 
throughout the EU. At the moment, these more powerful cycles are classified as mopeds. These cycles must 
hence  comply  with  the  type-approval  requirements  for  vehicles  with  combustion  engines,  which  are  not 
appropriate for a purely electric vehicle. 

EU competence and subsidiarity 

2.2. 
Prior to the introduction of EU (then EU) type-approval for L-category vehicles, regulations were established 
at Member State level. The legislation adopted by Member States often differed and manufacturers selling 
on several markets were obliged to vary their production for each market and have their vehicles tested in 
each Member State in question, which was time-consuming and costly. Different national rules consequently 
hindered trade, and had a negative effect on the internal market. 
It  was  therefore  necessary  to  establish  standards  at  EU  level,  especially  to  tackle  EU-wide  concerns 
regarding  safety  and  the  adverse  health  and  environmental  effects  of  air  pollution.  High  emissions  in  local 
urban settings may be controlled by measures taken by individual Member States, but global emissions do 
not stop at borders. This Europe-wide concern can only be addressed by harmonised, EU-wide measures. 
Framework  Directive  2002/24/EC  was  designed  to  do  this  and  aimed  to  establish  an  internal  market  while 
ensuring a high level of protection of health, safety and the environment. Such a rationale is still valid today 
as EU action is needed to avoid fragmentation of the internal market and to ensure a high and equal level of 
protection across Europe.  

A  further  added  value  of  EU  legislation  is  that  harmonised  legal  requirements  allow  industry  to  profit  from 
economies  of  scale:  for  instance,  products  can  be  made  for  the  whole  European  market,  instead  of  being 
customised  to  obtain  national  type-approval  for  every  single  Member  State.  Consumers  will  benefit  from 
lower product prices, which are constantly under pressure owing to EU-wide competition. 

3. 

OBJECTIVES 

General objectives 

3.1. 
The general objectives of the initiative are to simplify of the current legal framework, to contribute to a lower, 
more  proportionate  share  of  overall  road  transport  emissions,  and  to  increase  functional  safety  for  new 
vehicles entering the market. 

Specific objectives: simplification of existing EU legislation  

3.1.1. 
The specific simplification30 objective is to develop a less complex regulatory approach that ensures greater 
efficiency,  less  time  loss  and  less  burdensome  adaptation  to  technical  progress.  Replacing  existing 
provisions in the Framework Directive by references to equivalent or more appropriate UNECE regulations 
has a high priority for the Commission in order to pursue the high-level goals set out in CARS 21. 

Another  specific  objective  is  to  see  how  duplication  of  international  standards  can  be  reduced  so  that 
stakeholders are not confronted with several sets of requirements addressing the same aspects. 

Specific environmental objectives 

3.1.2. 
A specific objective for environmental measures is to keep the share of L-category vehicle emissions in total 
road  transport  emissions  at  least  constant  compared  to  current  levels,  or  preferably  to  reduce  them  in 
proportion  to  actual  use/total  mileage  compared  to  other  road  vehicle  categories.  In  addition,  evaporative 
emissions  must  be  addressed  to  help  achieve  the  specific  pollutant  emission  reductions  targeted  by  the 
Commission. The long-term aim (2020 – 2021) is to reduce the share of L-category vehicle emissions in total 
road transport emissions by at least 16 % for CO, 15 % for HC, 37 % for PM and 27 % for NOx (in tonnes) 
compared to the ‘no change’ scenario.  

In  the  long  run,  the  Commission  also  wants  transparency  in  the  choice  between  alternative  modes  of 
transport  in  terms  of  environmental  performance,  and  is  considering  using  only  one  emission  laboratory 
testing cycle (WMTC) instead of the four testing cycles used today. 

29

30

See the economic market overview of L-category vehicles in this report, electric cycles, Annex IX. 
http://europa.eu/scadplus/glossary/legislation_simplification_en.htm. 

EN 

15 

   EN 

 
                                                 
 
 
Safety specific objectives 

3.1.3. 
The specific objectives are to help achieve the same high reductions in road accident fatalities and casualties 
as  for  other  means  of  road  transport,  with  the  falling  trend  in  passenger  car  fatalities  since  2000  as  the 
benchmark, to maximise accident mitigation to prevent serious and minor injuries as much as possible, and 
to  help  close  the  gap between  actual road  accident  fatalities and  casualties  and  the  medium-  to  long-term 
road safety targets. 

Specific objectives for legal requirements and technology developments 

3.1.4. 
A number of technology developments should be reflected in legal requirements at EU level in order to allow 
the industry to type-approve a product only once and then to market and sell certified products not only in the 
EU  internal  market  but  also  in  countries  that  opt  to  apply  UNECE  regulations.  With  clearer  criteria  for  the 
various subcategories of L-category vehicles, this can be achieved more effectively and efficiently. 

POLICY OPTIONS 

4. 
A number of options have been analysed for each of the areas addressed by the objectives. As analysis has 
shown that there are no significant trade-offs between the different areas, the options will be presented as 
separate sets. 

4.1. 

Simplification of existing EU legislation 

The assessed policy options were the following: 

(1) No policy change 
No  change  would  be  made  to  the  current  regulatory  framework.  The  Framework  Directive  would  still  lay 
down the EU type-approval system, while technical requirements would still be established under separate 
directives,  which  require  transposition  into  national  legislation.  Amending  directives  would  also  require 
transposition. The Commission would have to continue monitoring transposition into the national legislation 
of 27 Member States. 

(2) Repeal current directives and replace with a minimum number of regulations 
The  Framework  Directive,  the  13  technical directives  and  their  21  amendments would  be  repealed.  A new 
Regulation adopted through the ordinary legislative procedure would contain the fundamental requirements 
of  the  EU  type-approval  system,  while  all  detailed  technical  requirements  would  be  gathered  into  a  small 
number of implementing regulations, to be adopted and more easily updated in future through the committee 
procedure (‘comitology’). 

Similar to what has been introduced for motor vehicles in the General Safety Regulation (GSR), if equivalent 
technical standards have been adopted by UNECE, the provisions of EU directives could be repealed and 
replaced by a reference to these international standards. This option could take different forms: 
- Full references, where the text is copied in full and published by the EU; 
- Simple fixed (static) references, where the EU legislation links to a dated international regulation; 
- General (dynamic) references, where the EU legislation links to a regulation of an international 
standardisation body, but without dating it: this would allow automatic adjustment in line with updates of 
these technical requirements. 

From  the  point  of  view  of  legal  certainty  and  control  over  EU  legislation,  the  latter  possibility  (dynamic 
references)  seems  unacceptable.  In  consequence,  this  is  not  further  analysed.  The  same  split-level 
approach  could  be  followed  as  when  legislation  was  introduced  for  other  EU  vehicle  categories,  e.g.  light- 
and heavy-duty vehicles. 

(3) Recast the current Framework Directive 2002/24/EC  
The  current  Framework  Directive  would  be  revised  and  re-enter  into  force  from  a  given  date.  Some 
measures  in  the  Framework  Directive  would  be  amended  in  order  to  update  them  and  align  them  with 
technical progress. References to UNECE Regulations would be used consistently. The same process would 
apply  to  the  13  implementing  directives  and  their  21  amendments.  These  would  be  codified  and  their 
provisions  as  much  as  possible  replaced  by  references  to  global  UNECE  regulations.  The  split-level 
approach is assumed for this option as well. 

Environmental measures 

4.2. 
For obtaining a type-approval certificate for a new vehicle design, the manufacturer must demonstrate to the 
type-approval  authorities  that  a  new  vehicle  type  complies  with  the  set  of  rules  defined  by  the  regulatory 
framework  and  more  specifically  with  the  detailed  technical  provisions  in  associated  legal  acts.  In  order  to 
demonstrate to the type-approval authorities that a mass-produced series of vehicles complies with all these 
legal requirements, demonstration tests must be performed in the presence of the type-approval authorities 

EN 

16 

   EN 

 
well  before  the  start  of  mass  production,  during  the  development  of  a  new  vehicle  design.  In  these 
demonstration  tests,  performed  with  a  limited  number  of  representative  vehicles,  vehicle  emissions  are 
tested  in  a  certified  emission  laboratory  equipped  with  an engine  dynamometer,  on which the  vehicles are 
tested following mandatory test procedures.  

The emission laboratory is equipped with certified measuring equipment that collects the exhaust gas flow in 
bags while the vehicle is tested on the engine dynamometer using e.g. the World-wide Motorcycle emissions 
Testing  Cycle  (WMTC).  The  contents  of  the  bags  are  analysed  at  the  end  of  the  test  and  the  test  results 
must be below the legal emission limits. The test cycle simulates a representative real-world driving profile 
and the test results are supposed to reflect the real-world emission performance of the tested vehicle, which 
in turn is supposed to be representative of the emission performance of the mass-produced vehicles that the 
manufacturer intends to market after obtaining type-approval.  

Possible policy options for requirements prior to the start of production to obtain type-approval are listed in 
chapter  4.2.1.  Policy  options  to  control  vehicle  emissions  after  start  of  mass  production  and  after  type-
approval are listed in chapter 4.2.2. If the latter type of options is included in the new legal framework, the 
vehicle manufacturer must ensure that these requirements continue to be met to retain type-approval. 

In order to reduce and/or control the emissions from L-category vehicles over vehicle life, a number of policy 
options are considered as a package applicable before and after type-approval of a new vehicle. 

4.2.1. 

New or revised environmental measures for the type-approval of new vehicles 

4.2.1.1.  Revised lower emissions limits. 
Different  options  have  been  developed  and  analysed  with  regard  to  new  emission  limits  for  different 
pollutants: 
(1) 
(2) 

No action; 
Use  of  the  traditional  R47  test  cycle  but  including  cold  start  and  a  30 %  weighting  factor  for  cold 
start in this emission laboratory test cycle are  proposed. In this option the emission limits remain 
unchanged for mopeds and all other L-category vehicles. 

Figure 6: R47, driving cycle for mopeds (Euro 1 and Euro 2); 

Pollutant sampling is conducted from sub-cycle 5 to 8 for Euro 2 mopeds. In option 2, which is a 
possible Euro 3 measure for mopeds, cycles 1 to 4 will also be sampled, but only weighted for 30 % 
of  the  total  pollutant  emissions  sampled  over  the  whole  test.  The  reason  for  a  lower  weighting 
factor in the phase where the engine is cold and warming up (sub-cycle 1 to 4) is that under real-
world conditions the engine will operate for a higher percentage of time when it is warm. Hence, in 
line  with  the assumptions behind  the R47  test sampling  definition  for  Euro 2  mopeds,  the  moped 
will,  under  real-world  conditions,  be  started  two  to  four  times  a  day  with  a  cold  engine  and  then 
warmed up. The moped engine is thus assumed to be warm for most of its operating time. In option 
2,  this  is  represented  by  a  (100 %  —  30 %  =)  70 %  weighting  factor  for  the  warm  engine  phase 
(cycles 5 to 8). For Euro 2 mopeds it does not matter how much the moped engine emits in sub-
cycles  1  to  4,  which  means  that  the  manufacturer  must  only  optimise  the  emissions  of  the  warm 
engine (represented by cycles 5 to 8), which have a weighting factor of 100 % in a Euro 2 test. 

In option 2, consequently, the moped manufacturer must ensure that moped emissions in the cold 
phase  are  controlled  by  an  exhaust  after-treatment  system  that  also  operates  under  cold  engine 
conditions (lower light-off or operating temperature) and/or by optimising engine calibration (tuning) 
to  take  account  of  cold-start  conditions  and  warming-up  of  the  moped  engine.  As  cold-start 
emissions are also included in the test result in option 2, total measured pollutant emissions will be 

EN 

17 

   EN 

 
 
higher, which will make it more challenging for the manufacturer to meet the same emission limits if 
option 2 were retained as a Euro 3 measure. 
This  option  reflects  the  motorcycle  industry  proposal31.  Among  many  other  scenarios  (17  for 
categories L1e to L7e in total), the manufacturers propose a -25 % reduction for L3e motorcycles 
compared  to  Euro 3  levels  when  the  new  regulation  enters  into  force  (2013)  and  a  second 
reduction 3 years later of approximately -50 % compared to Euro3 levels. This general reduction is 
not applicable to the other L-category vehicles (L1e, L2e, L5e, L6e and L7e), for which individual 
reductions are proposed by the motorcycle industry association, ACEM. 

New measures based on the best available technology applied to L-category vehicles sold today in 
the market. 
New  limits  for  all  L-category  vehicles  equivalent  in  absolute  terms  to  the  Euro 5  stage  for 
passenger cars. 

(3) 

(4) 

(5) 

The  five  different  options  for  the  possible  revision  of  emission  limits  and  the  associated  analysis  are 
summarised in detail in Annex XI and Annex XIV. 

4.2.1.2.  Use  of  a  revised  World-wide  Motorcycle  emissions  Testing  Cycle  (WMTC)  for  all  L-category 

vehicles32. 

Figure 7: R40 European Driving Cycle for Euro3 L3e motorcycles. 
approval of Euro3 L3e motorcycles 

WMTC  alternative  driving  cycle 

for 

the 

type-

Under  the  umbrella  of  UNECE,  a  Worldwide  Harmonised  Motorcycle  Test  Cycle  (WMTC),  stage  one,  was 
developed,  which  manufacturers  in  the  EU  have  been  able  to  use  since  2006  to  type-approve  a  new  L3e 
motorcycle.  Manufacturers  may  continue  to  use  the  traditional  European  Drive  Cycle  (R40  cycle)  for  type-
approval testing. Mopeds and light quadricycles are currently type-approved using the R47 test cycle (distinct 
from the Motorcycle EDC R47 and the WMTC). 

Stage  2  of  the  WMTC  includes  a  number  of  technical  revisions  to  widen  the  scope  of  use  and  improve 
WMTC  stage  one.  Specific  type-approval  emission  limits  were  developed  for  WMTC  stage  one.  In  this 
impact  assessment,  the  pros  and  cons  of  using  only  WMTC  stage  two,  completely  abandoning  the  EDC 
cycle,  are  assessed  for  motorcycles.  For  other  L-category  vehicles  (mopeds,  quadricycles)  the  impacts  of 
using a revised WMTC and replacing the currently used R47 and R40 test cycles are assessed as well, with 
a view to harmonising the testing cycle across the L-category. The assessed options: 
(1) 
(2) 

No change; 
Use  of  a  revised  World-wide  Motorcycle  emissions  Testing  Cycle  (WMTC)  for  all  L-category 
vehicles. 

4.2.1.3.  Type-approval requirements to measure CO2 emissions and to determine fuel consumption 

CO2  emissions  from  L-category  vehicles  represent  overall  a  very  small  share  of  total  CO2  emissions  from 
road transport. Initially, therefore, obligatory CO2 emission measurement and fuel consumption determination 
and  reporting  at  type-approval  to  pave  the  ground  for  the  introduction  of  an  energy  efficiency  labelling 

31

32

Explained in detail in Annexes VI and VII of the IA report. In the LAT report cf. chapter 3.2.2. At the MCWG of 29 June 09, this 
was summarised in: 
http://circa.europa.eu/Public/irc/enterprise/automotive/library?l=/mcwg_motorcycle/meeting_june_2009/emisia_report_v2pdf/_
EN_1.0_&a=d. 
http://ec.europa.eu/enterprise/automotive/projects/report_measures_motorcycle_emissions.pdf (ch. 2.3.1). 

EN 

18 

   EN 

 
 
                                                 
 
 
scheme at a later stage was not included in the public consultation. An energy efficiency labelling scheme as 
such is not within the scope of this impact assessment but the data to be provided by the manufacturers as 
input for labelling is analysed. This item which obliges the manufacturer to measure CO2 emissions and to 
determine  fuel  consumption  at  type-approval  was  addressed  during  an  extended  stakeholder  consultation 
conducted  in  parallel  to  the  impact  assessment  process  in  order  to  obtain  additional  information  and 
stakeholder views on topics that emerged during the impact analysis.  

The market seems to be split into two regarding the lowering of CO2 emissions and fuel consumption. Riders 
who buy a PTW or any other L-category vehicle purely for leisure purposes and sports use may be relatively 
indifferent  to  fuel  consumption  and  CO2  emissions.  This  may  still  continue  to  be  the  case  in  future  as  L-
category  vehicles  are  often  perceived  as  emotional  products  and  not  as  just  an  alternative  means  of 
transport.  On  the  other  hand,  riders  who  use  their  vehicles  to  commute  back  and  forth  to  work  and  for 
professional  purposes  may  be  very  interested  in  continuous  improvements  in  fuel  consumption  and  lower 
CO2 emissions.  

Lightweight  PTWs  with  relatively  small  engines  frequently  have  much  better  performance  than  passenger 
cars,  but  in  many  cases  unfortunately  have  the  same  fuel  consumption  and  CO2  emissions  as  heavier 
passenger cars equipped with much bigger engines. Consumer information is one of the most obvious and 
effective ways to address this issue. In addition, the effectiveness of a future labelling scheme may be further 
strengthened  by  fiscal  incentives  (e.g.  vehicle  tax  linked  to  CO2  emissions).  This  has  been  the  case  for 
passenger  cars,  and  it  is  likely  that  such  schemes  will  evolve  to  include  other  categories  of  vehicles.  If 
consumers are better informed and compare products not only on engine performance (power and torque) 
but  also  on  CO2  emissions  and  fuel  consumption  when  buying  a  new  motorcycle,  the  incentives  for 
manufacturers  to  provide  buyers  with  more  fuel-efficient  vehicles  will  also  increase,  regardless  of  whether 
these vehicles are used purely for leisure or for commuting to work and other professional reasons. 

Policy options assessed: 
(1) 
(2) 

No change; 
Type-approval  requirements  for  CO2  measurement  and  fuel  consumption  determination  and 
reporting. 

4.2.1.4.  Evaporative emissions test and limit 
In  addition  to  exhaust  gas  emissions,  emissions  may  occur  through  evaporation  of  fuel  from  the  fuel  tank 
filler  opening  or  from  the  fuelling  system,  especially  under  hot  ambient  conditions.  As  in  the  case  of 
passenger cars, a limit on such evaporative emissions needs to be assessed. There would be a requirement 
to  perform  a  SHED  test  for  type-approval  and  to  comply  with  a  limit  for  hydrocarbons  similar  to  what  has 
been compulsory for gasoline passenger cars since 2000. Policy options assessed: 
(1) 
(2) 

No change; 
Replacement of all new carburetted models with fuel-injected models. Due to the closed circuit, fuel 
injection engines produce much lower evaporation emissions than carburetted engines; 
Evaporative emissions test and limit ensuring evaporative emission control for L-category vehicles. 

(3) 

4.2.1.5.  Durability requirements 
Vehicle emissions should preferably deteriorate very little over vehicle life, so it may prove to be necessary to 
limit  the  acceptable  deterioration  over  vehicle  mileage  in  emissions,  which  are  obviously  very  much 
influenced by the quality and functionality of exhaust after-treatment components and systems like catalytic 
converters and lambda sensors. Also, an increase in raw engine-out emissions over vehicle life due e.g. to 
engine wear will lead to higher emissions, even if the exhaust after-treatment systems deteriorate only very 
little. Consequently, durability requirements should apply not just to exhaust after-treatment systems, but to 
the whole vehicle. Assessed policy options: 
(1) 
(2) 

No change; 
Deterioration reduced to 10 % over useful vehicle life and linear extrapolation for higher mileages. 
This  means  that  the  manufacturer  must  guarantee  that  well-maintained,  aged  vehicles  with  a 
defined  useful  vehicle  life,  e.g.  50 000  km  for  L3e  motorcycles,  do  not  exceed  the  type-approval 
pollutant limits. 
Useful life increased by 60 %, i.e. similar trend comparable with the increase for passenger cars on 
the move from Euro 3 (80 000 km) to Euro 5 (160 000 km) stages. This means that, over and above 
option  2,  useful  life  would  be  defined  as  1.6  x  50  000  km  for  L3e  motorcycles,  i.e.  80 000  km 
instead of 50 000 km. 

(3) 

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4.2.2. 

New measures to control vehicle emissions over vehicle life. 

In-use conformity (IUC) testing and limits 

4.2.2.1. 
IUC exhaust and/or evaporative emissions could be tested and analysed on in-use vehicles. For this purpose 
a representative number of vehicles should be selected to perform IUC testing. This representative sample 
would then be tested under vehicle-emission laboratory conditions and employing testing methods similar to 
the accurate and advanced methods used to test new vehicles in type-approval demonstration testing. 

Ultimately, if a high number of vehicles in the sample failed to comply with the exhaust and/or evaporative 
emission limits, the vehicle manufacturer could be obliged to recall the vehicles in the field to correct the root 
cause  of  the  failure.  The  burden  of  conducting  this  type  of  test  would  be  borne  mainly  by  the  vehicle 
manufacturers and the national authorities. Using IUC testing as instrument to keep vehicle emissions under 
type-approval limits would be scrutinised. This policy option could be part of the integral approach towards 
environmental measures to guarantee that the emission performance of a vehicle degrades over vehicle life 
only up to the defined levels. The following policy options regarding IUC testing are assessed: 
(1) 
(2) 

No change (IUC not applicable to any L-category vehicle); 
IUC procedure mandatory for all Euro 3 motorcycles.  

4.2.2.2.  On-board diagnostic (OBD) systems and access to repair information 
If  an  emission-relevant  component  or  system  were  to  fail  suddenly  or  slowly  degrades  beyond  acceptable 
levels, a clean vehicle may turn into a highly polluting vehicle. In such cases, the driver will ideally need to be 
informed quickly, to take the vehicle to the garage at the next opportunity and have it repaired. 

The  OBD  system  is  the  vehicle’s  self-diagnostic  and  reporting  capability.  OBD  systems  give  the  vehicle 
owner,  a  repair  technician  or  a  PTI  (periodical  technical  inspection)  officer  access  to  state-of-health 
information  for  various  vehicle  sub-systems  and/or  components.  For  passenger-car  PTI  testing,  Directive 
2009/40/EC33 allows OBD information to be used instead of gaseous (CO) testing, but this is not the case for 
L-category vehicles.  

Failing  environmental  and/or  safety-relevant  components  or  systems  need  to  be  rapidly  diagnosed  and 
indicated to riders, so that they can go to the garage to have the failure quickly repaired. This may mitigate 
adverse environmental and/or safety effects of such failures.  

During the repair cycle (diagnosis and analysis of problem/failure, repair of smallest identifiable component 
or ordering of replacement part and replacement of smallest exchangeable unit), access to repair information 
is  critical  and  directly  relies  on  obtaining  standardised  diagnostic  information  from  the  OBD  system  with  a 
generic scan tool.  

Therefore, all these aspects of these integral requirements for the effective and efficient repair of a vehicle 
were assessed as one combined measure. Assessed policy options: 
(1) 
(2) 

No change (no introduction of OBD systems and access to repair and maintenance information); 
OBD systems using a similar technology as for passenger cars (European OBD), including catalyst 
efficiency  and  misfire  monitoring  for  all  L-category  vehicles.  Provision  for  access  to  repair  and 
maintenance information, similar as for passenger cars; 
Use  of  best  available  OBD  technology:  minor  malfunction  monitoring  (e.g.  circuit  integrity  check) 
(OBD stage 1) for all L-category vehicles, no catalyst efficiency monitoring. Provision for access to 
repair and maintenance information, similar as for passenger cars. 

(3) 

Safety measures 

4.3. 
With the aim of improving safety for vulnerable road users, the Commission intends to focus on a number of 
critical policy areas. However, these do not all fall under the scope of this impact assessment, which is only 
limited to type-approval measures for new vehicles. Examples of measures not falling in the scope include 
the planning, design and operation of road networks, compliance with key road safety rules, helmet design 
and  use,  protective  clothing,  licensing,  testing  and  training,  periodical  technical  inspections  and  road-side 
inspections. However, other possible policy instruments for achieving road safety objectives involve new or 
amended  measures  related  to  the  type-approval  of  new  vehicles,  e.g.  use  of  passive  and/or  active  safety 
systems  such  as  the  fitting  of  advanced  brake  systems  and  a  number  of  other  functional  safety-related 
vehicle features listed under the policy options. These do fall within the scope of this impact assessment. 

A  number  of  the  safety  measures  assessed  below  may  be  left  optional,  made  mandatory  or  left  up  to 
voluntary  manufacturer  initiatives.  It  may  be  necessary  to  combine  all  the  measures,  to  apply  them 

33

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:141:0012:0028:EN:PDF, Annex II, Ch. 8.2.1.b, 4(iii). 

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individually,  or  to  mandate  them  as  different  groups  of  measures,  depending  on  the  outcome  of  cost-
effectiveness calculations. 

Main possible measures assessed: 

4.3.1.  Obligatory fitting of advanced brake systems 
(1) 

No change; in this case the fitting of advanced brake systems on PTWs would be entirely left to the 
market, i.e. depending on supply and demand. 
Anti-lock brake systems34 on all powered two-wheelers (PTWs); 
Anti-lock brake systems on PTWs with cylinder capacity35 > 125 cm3 and advanced brake systems 
(combined  brake  systems  (CBS)  and/or  anti-lock  brake  systems  (ABS))  on  motorcycles  with  
50 cm3 < cylinder capacity ≤ 125 cm3; 
Obligatory  fitting  of  advanced  brake  systems  (combined  brake  systems  and/or  anti-lock  braking 
systems)  on  motorcycles  conforming  to  the  performance  criteria  for  the  A2  driving  licence36. 
Obligatory fitting of anti-lock brake systems on all other L3e class motorcycles; 
Industry self-regulation, Annex V 

(2) 
(3) 

(4) 

(5) 

Anti-tampering measures  

4.3.2. 
In  addition  to  chapter  4  of  the  TRL  report,  a  separate  report37  on  anti-tampering  was  published  on  the 
Commission’s website explaining all the issues related to tampering in 2003. Many of its elements are still 
valid today, but technology developed fast in the last decade, which means that the report should be updated 
before finalising any detailed technical provision if opting for option 3. Assessed policy options 
(1) 
(2) 
(3) 

No change; 
Repeal Chapter 7 of Directive 97/24/EEC (currently obsolete anti-tampering measures); 
New measures on anti-tampering. 

74kW power limitation for motorcycles 

4.3.3. 
The initial intention to limit motorcycle power to 74 kW was to increase safety by inherently limiting maximum 
acceleration  and  vehicle  speed.  This  concept  is  reassessed  in  this  impact  assessment  for  the  following 
options: 
(1) 
(2) 
(3) 
(4) 

No change; 
Repeal the option given to Member States to limit power to 74kW; 
Set a harmonised limit of 74kW; 
Use an alternative limitation, e.g. power-to-mass ratio. 

4.4. 

Improved categorisation of L-category vehicles 

4.4.1. 

(1) 
(2) 
(3) 

(4) 
(5) 

Electrical  cycles  (currently  outside  the  scope  of  the  Framework  Directive),  tricycles  (L5e)  and 
quadricycles (categories L6e and L7e) 
No change; 
Exclude quadricycles and electrical cycles and tricycles from the new Regulation; 
Return to the original spirit of the legislation for mini-cars, reintroducing small external dimensions 
and the original vehicle weight classification criteria (400 kg / 550 kg); 
Improve the legislation by adding new requirements for mini-cars based on car requirements; 
Refine  the  vehicle  categories  by  introducing  new  sub-categories  in  L1e,  L5e,  L6e,  and  L7e.  Add 
new/revised requirements for these sub-categories. 

34

35

36

37

Definition from TRL report: Anti-lock braking systems (ABS) monitor the speed at which the wheels are rotating and rapidly 
modulate  the  brake  pressure  when  imminent  wheel  lock  is  detected  in  order  to  increase  effective  braking  and  prevent 
deceleration  being  dictated  by  the  sliding  friction  between  tyre  and  road.  ABS  is  the  only  technical  solution  that  directly 
monitors and prevents wheel locking and has been shown in test conditions to result in generally higher braking deceleration 
by  maintaining  the  wheel  slip  such  that  friction  is  above  the  level  provided  by  locked  wheels.  Preventing  wheel  lock  under 
emergency braking gives the rider greater confidence to apply  higher brake forces, leads to shorter stopping distances and 
prevents the rider from falling. 
The figure of 125 cm3 corresponds to the thresholds in Directive 2006/126/EC (recast Driving Licence Directive) for class A1: 
motorcycles  with  a  cylinder  capacity  not  exceeding  125  cm3,  power  not  exceeding  11kW  and  a  power/weight  ratio  not 
exceeding 0.1 kW/kg. 
Thresholds obtained from Directive 2006/126/EC (recast Driving Licence Directive) for class A2: 1) power not exceeding 35 
kW, 2) a power/weight ratio not exceeding 0.2 kW/kg, and 3) not derived from a vehicle of more than double the power. These 
are  EU-wide  criteria  for  distinguishing  less  powerful  PTWs  that  beginners  are  allowed  to  ride  within  the  first  two  years  of 
getting their driving licence from powerful motorcycles that may only driven by more experienced motorcycle riders. 
http://ec.europa.eu/enterprise/automotive/projects/report_anti_tampering_devices.pdf. 

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4.4.2. 
(1) 
(2) 

(3) 
(4) 

Specific requirements for category L7e vehicles 
No change; 
Exclude off-road quads (ATVs) from the new Regulation and add new requirements on safety and 
emissions for on-road quadricycles (on-road quads and mini-cars); 
Keep the existing L7e category and add new requirements on safety for all quadricycles; 
Create new categories in L7e with specific requirements for off-and on-road quadricycles. 

4.4.3. 
Specific requirements for gaseous alternative fuels and other non-traditional propulsions 
The same technology trends can be observed as in light-duty vehicle technology. Different and new types of 
gaseous  fuels  and/or  alternative  propulsion  technologies  are  being  introduced  for  L-category  vehicles 
alongside or in addition to conventional gasoline or diesel fuels. Blends with ethanol, LPG, and CNG or even 
hydrogen  may  be  used  in  future  to  propel  vehicles.  The  first  requests  to  type-approve  hydrogen-propelled 
motorcycles  have  already  been  received  by  the  type-approval  authorities  of  at  least  two  Member  States. 
Hybrid and purely electric technologies may also be adopted by manufacturers. All these different technology 
choices and mixes of technologies are only partly covered by the current legal framework or not at all. The 
policy options assessed in the impact assessment: 
No change (legislation at national level); 
(1) 
Legislation  at  European  Union  level  through  a  more  refined  vehicle  categorisation  with  specific 
(2) 
measures for different vehicles and propulsion technologies. 

5. 
5.1. 

ANALYSIS OF IMPACTS 
Simplification of legislation 

Annex X 

Full analysis, including all available quantitative and qualitative aspects, of the 3 policy options 
for simplification: 
Option 1: No policy change; 
Option 2: Repeal current directives and replace with a minimum number of regulations; 
Option 3: Recast the current Framework Directive 2002/24/EC. 
Table 1: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3 

Summary: 
Option 1: No policy change 
The main disadvantage of option 1 is that the problems described in chapter 2.2.1.of this impact assessment 
report will not be resolved. This is not in line with the Commission’s better regulation objective, in particular 
as there will be no improvement in terms of safety or environmental impacts. Continuing this approach would 
thus only place additional administrative burden on stakeholders. 

A  positive  point  is  that  requirements  will  not  be  "diluted"  by  replacing  provisions  of  EU  Directives  with 
references  to  international  standards  like  those  of  UNECE.  Indeed,  some  respondents  to  the  public 
consultation  have  expressed  concern  that  such  referencing  could  reduce  safety  and  environmental 
protection. Some even fear a loss of transparency and loss of complete European control over international 
regulation by EU regulatory institutions. Another positive aspect of option 1 could be that specialists who are 
already familiar with the current legal text need not spend costly time reviewing a completely new legislative 
text. However, these benefits cannot be expressed in monetary terms and can therefore only be taken into 
account in the qualitative analysis. 

Option 2: Replace the current set of directives by a small number of regulations 
The exact number of implementing regulations, setting technical requirements via the comitology procedure, 
would  still  need  to  be  determined.  These  provisions  could  be  grouped  by  themes,  like  road  safety  or 
environmental  protection.  The  advantage  of  referring  as  much  as  possible  to  UNECE  international 
regulations is explained under the discussion of option 3. 

This option would have the advantage of allowing technical experts to deal with coherent sets of issues via 
comitology. It is thus purely a practical approach, intended to facilitate adoption of the requirements, but will 
not affect the requirements themselves. Such an approach, using several sets of delegated acts containing 
the  technical  details,  also  aims  to  increase  the  clarity  of  the  regulatory  framework  for  manufacturers  who 
have  to  comply  with  it  to  obtain  type-approval.  This  clarity  for  industry  is  an  important  benefit  of  the 
simplification exercise,  in  particular  for SMEs,  which  have  limited  administrative  resources  to  deal  with  the 
complex  regulatory  requirements  for  obtaining  type-approval.  The  aim  of  providing  a  clear  and  logical 
structure is supported by industry representatives. 

As far as costs for administrations are concerned, these would be lower because there would no longer be 
any  need  to  transpose  directives  into  national  law,  leading  to  reduced  costs  for  the  Member  States.  The 
Commission would no longer be responsible for the time-consuming scrutiny of transposition. Both national 
and EU administrations would thus benefit from the new format. Grouping the regulations into sets will allow 

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experts  to  deal  more  coherently  with  aspects  of  similar,  limited  objectives.  The  decision  to  opt  for  one  or 
more implementing regulations should be agreed with the comitology committees. In the assessment, it was 
not possible to quantify the benefits of simplification in terms of lower cost to industry or for consumers. 

A negative aspect of using a small number of implementing regulations can be the lengthy process involved: 
agreeing  on  one  text  including  all  requirements  may  take  a  lot  of  time  for  the  committee  and  will  involve 
different experts depending on the aspects covered. Another perceived disadvantage of this option may be 
the  shift  of  control  and  scrutiny  from  national  parliaments  to  the  EU  institutions.  Basically,  the  EU 
Commission proposes a legal text for the new Regulation and this text is scrutinised and voted on by the co-
legislators, the EU Parliament and Council. As soon as the Regulation is adopted and published in the EU 
Official Journal38, it will enter into force in all the 27 Members States simultaneously on the specified dates, 
without the extra step of having to be transposed into national law. 
From the cost perspective39, an average cost of € 2 .4 million may be incurred from 2009 until 2020, within a 
range of € 58 400 to € 8 .8 million. The annual cost of making amendments to the legal text would be slightly 
lower owing to the fact that technical progress can already partly be anticipated when the new legislation is 
developed and adopted, which means that further amendments to adapt to technical progress can already 
be partly included. This effect cannot be quantified. For the timeframe 2009 to 2020, an average cumulative 
benefit of € 421 000, within a range of € 78 000 to € 786 000, was calculated for this option. The cost-benefit 
ratio  was  on  average  1.2,  within  a  range  between  1.1  and  2.5.  The  break-even  point  is  estimated  to  be 
reached between the years 2017 and 2019. 
Table  8,  p.  17,  of  the  TRL  report40  provides  an  overview  of  the  quantitative  and  qualitative  impacts  for 
simplification options 1 and 2. 

Option 3: Recast the current Framework Directive 2002/24/EC, simplify by referring to UNECE regulations, 
and maintain the implementing measures. 
An  alternative  to  option  2  could  be  to  recast41  the  current  Framework  Directive  2002/24/EC,  referring  as 
much  as  possible  to  UNECE  regulations.  This  will  benefit  all  actors  dealing  with  this  legislation,  whether 
national authorities responsible for type-approval or manufacturers whose vehicle types have to comply with 
these  requirements.  In  particular  SMEs  will  benefit,  as  they  have  limited  resources  to  devote  to  reviewing 
regulatory  matters.  To  respond  to concerns  as  to  a weakening of  requirements,  it  should  be  stated clearly 
that  references  will  be  proposed  only  in  cases  where  the  international  standards  are  at  least  equal  to  the 
relevant EU directives. 

The disadvantage mentioned under option 2, regarding a shift from national control and scrutiny to control by 
EU institutions, is not applicable in option 3. As the Framework Directive and its implementing measures will 
not be turned into a Regulation, the recast Directives will need to be transposed42 into national legislation. 
On the other hand, the additional cost of this transposition remains. 

Manufacturers  will  continue  to  select  the  approval  tests  needed  among  the  UNECE  and  remaining  EU 
standards.  There  will  be  no  additional  administrative  or  type-approval  costs  compared  with  those  under 
option  2.  The  requirements  of  repealed  directives  will  be  replaced  by  equivalent  requirements.  There  is 
therefore  no  additional  cost,  but  also  no  direct  benefit  in  terms  of  cost  reductions  for  manufacturers.  The 
envisaged  benefit  will  be  simplification  and  clarification  of  the  regulatory  framework,  but  this  is  particularly 
hard to quantify. 

The cost of this option is estimated to be in the same range as option 2, except that the cost of transposition 
needs  be  added.  Although  the  precise  differences  between  option  2  and  3  cannot  be  quantified,  it  is 
assumed that the cost-benefit ratio of option 3 is lower (higher cost owing to transposition, more or less the 
same  benefits).  This  also  means  that  the  break-even  point  will  be  reached  later  than  the  2017  –  2019 
timeframe. Again, it was not possible to exactly quantify these financial indicators. 

The societal impacts of option 3 are similar to those of option 2, but as it involves recasting directives, option 
3 does not eliminate transposition and implementation costs for the administrations in the Member States. It 
is again likely to yield a low cost-benefit ratio and result in the break-even point being reached at a later date. 

38

39

40

41

42

http://eur-lex.europa.eu/JOIndex.do?ihmlang=en. 
http://ec.europa.eu/enterprise/automotive/projects/report_new_measures_l_category.pdf. 
TRL report, http://ec.europa.eu/enterprise/automotive/projects/report_new_measures_l_category.pdf, chapter 2. 
http://europa.eu/scadplus/glossary/legislation_recasting_en.htm. 
EU directives are transposed into local legislation. 

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Unfortunately, this hypothesis for option 3 cannot be supported with data. This scenario was not included in 
the extended policy report and, owing to timing constraints on collecting data after this report was published, 
only an estimate can be made, based on previous experience with the recasting of the Framework Directive 
for  Euro  5  &  6  passenger  cars.  The  option  to  refer  to  global  standards,  also  used  in  the  General  Safety 
Regulation for motor vehicles, is widely supported by stakeholders, as expressed in their replies to the public 
consultation. 

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5.2. 
5.2.1. 
5.2.1.1.  Revised lower emissions limits 

Environmental measures 
New or revised environmental measures for the type-approval of new vehicles 

Annex XI 
Annex XI Ch. 1.1 
Annex XI Ch. 1.2 

Annex XI Ch. 1.2 Opt. 1 
Annex XI Ch. 1.2 Opt. 2 

Annex XI Ch. 1.2 Opt. 3 
Annex XI Ch. 1.2 Opt. 4 

Annex XI Ch. 1.2 Opt. 5 

Annex XI Ch. 1.3 

lower  emissions 

Revised 
subcategories L1e to L7e, by comparison with light-duty M1 emission limits; 
Qualitative analysis of the 5 policy options to revise the emission limits. 

limits,  detailed  analysis  of  proposed 

limits 

for  L-category  vehicles, 

Option 1: No policy change; 
Option 2: New emission limits for L1e mopeds: a cold-start R47 test cycle and a 30 % weighting factor 
for  cold  start  are  proposed  (scenario  1  from  LAT  report).  No  change  in  limits  for  other  L-category 
vehicles; 
Option 3: Motorcycle industry proposal (scenario 2 from LAT report); 
Option  4:  New  measures  based  on  best  available  technology  for  L-category  vehicles sold  today  in  the 
market (scenario 3 from LAT report); 
Option  5:  New  limits  for  all  L-category  vehicles  equivalent  in  absolute  terms  to  Euro5  M1  light-duty 
vehicles (scenario 4 from LAT report); 
Quantitative  analysis:  policy  options  for  new  emission  limits,  summary  of  the  cost-effectiveness  of  the 
proposed emission limit options. 

Table 2: Click on ‘Annex’ links to display the full, detailed analysis of policy options 1 to 5 

Summary: 
Chapter 1.1 of Annex XI lists the current emission limits and the proposed new limits as a percentage of the 
Euro 5 passenger car limits. At the MCWG35 of 29 June 09 (agenda item 6a) it was explained why L-category 
vehicle emission limits and those for passenger cars are directly comparable in order of magnitude. Looking 
at the high limits for THC and CO it becomes obvious why the shares of these emissions from the L-category 
vehicle  fleet  compared  to  all  other  means  of  transport  are  currently  a  concern,  and  will  grow  to  a 
disproportionate  62 %  for  HC  and  35 %  for  CO  by  2020  if  the  emission  limits  are  not  revised.  Chapter  1.2 
provides a quantitative analysis of the pros and cons of every option and, finally, chapter 1.3 discusses the 
cost-effectiveness of each. 

Option 2 only covers one critical category, mopeds, and only one single aspect: cold-start weighting in the 
emission test. Therefore this option can be regarded as a technical sensitivity study to show that the impact 
of  a  cheap,  simple  measure  on  the  overall  exhaust  emissions  of  one  vehicle  class  can  have  a  slightly 
positive effect. One positive impact is its relatively high cost-effectiveness. A negative impact is that mopeds 
may  be  among  the  highest  emitting  road  vehicles,  but  only  a  minimum  reduction  will  be  obtained  in 
comparison  with  the  benchmark  passenger  cars.  Another  negative  impact  is  that  all  other  high-emitting 
vehicles in the L-category are not subject to revised emission limits. Therefore, the overall reduction will be 
only 7 % for HC and 2 % for CO. 

For  option  3,  the  industry  proposal  for  emission  reductions  in  two  steps,  a  technical  sensitivity  study 
presented at the MCWG35 of 29 June 2009 showed that the level of the limit has only a limited effect on total 
L-category vehicle emissions for the assessed timeframe until 2020. The effect will be more significant if the 
models  were  able  to  predict  overall  emissions  until  2030.  However;  this  is  technically  not  feasible  for  the 
moment,  so  the  comparison  base  is  2009–2020.  The  rapid  introduction  of  the  limits  is  the  most  important 
factor  in  reducing  L-category  vehicle  emissions  on  the  short  to  medium  term.  Option  3  can  in  principle  be 
introduced quickly, is still reasonably cost-effective and is supported by the industry (minimal implementation 
time  anticipated).  The  negative  impact  is  that  HC  and  CO  emissions  will  remain  disproportionately  high 
compared to all other means of transport up to 2020 and beyond. 

This  latter  disadvantage  also  applies  to  option  4  and  even  option  5,  where  the  limits  are  assumed  to  be 
equivalent in absolute terms to EURO 5 for passenger cars. A further negative impact of option 4 is its low 
potential to reduce HC (only 2 % by 2020). A negative impact of option 5 is its high cost for industry in the 
short  to  medium  term.  A  positive  aspect  of  option  5  is  that  it  is  the  best  performing  option  in  terms  of 
emission  reduction:  it  is  expected  to  yield  reductions  of  19 %  in  CO,  28 %  in  HC,  40 %  in  PM  and  37 %  in 
NOx. 

5.2.1.2.  Use  of  a  revised  World-wide  Motorcycle  emissions  Testing  Cycle  (WMTC)  for  all  L-category 

vehicles  

Annex XI, Ch. 1.4 

Option 1: No policy change; 
Option  2:  Use  of  a  revised  World-wide  Motorcycle  emissions  Testing  Cycle  (WMTC)  for  all  L-category 
vehicles. 

Table 3: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 and 2 

Summary: 
The disadvantage of option 1 is that the benefits from common improvements to the test cycle as adopted by 
the  UNECE  cannot  be  completely  leveraged  for  L3e  motorcycles  type-approved  for  the  use  in  the  EU 
market.  Another  disadvantage  is  that  the  proliferation  of  testing  cycles  for  L-category  vehicles  will  remain, 

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which  makes  it  difficult  to  compare  the  emission  performance  of  the  various  vehicle  subcategories.  In 
addition,  it  will  continue  to  be  impossible  for  consumers  to  compare  alternative  vehicle  types  within  the  L-
category in terms of CO2 emissions and fuel efficiency. A positive aspect is the minimised compliance costs 
for manufacturers. 

Option 2 has a number of advantages in economic, environmental and societal terms. Owing to the higher 
share of ‘transient manoeuvres’, it is generally accepted that the WMTC reflects real-world conditions better 
than the currently used R40 and R47 test cycles. Opting for stage-two as against stage-one WMTC is also 
assumed to be emission- and cost-neutral. If, however, the R47 test cycle for mopeds is replaced by a future 
revised WMTC-based test cycle, there may initially be increased compliance costs, although the measure is 
estimated to be cost-neutral in the medium to long term. A replacement for the R47 test cycle currently does 
not  exist,  but  it  is  feasible  to  define  such  a  test  cycle,  based  on  WMTC,  in  collaboration  with  the  global 
community  represented  in  UNECE  WP29.  It  is  expected  that  fewer  test  cycles  worldwide  will  be 
advantageous for L-category vehicle producers in the EU owing to reduced global compliance costs for type-
approving  vehicles  and  more  transparency  for  consumers  purchasing  vehicles  in  the  EU  in  terms  of  toxic 
emission reduction performance, green house gas emissions and fuel consumption. This may also stimulate 
L-category vehicle use as an alternative to other means of transport. A compulsory labelling scheme for CO2 
and fuel consumption is expected to be useful to support consumers in their purchasing decisions in order to 
obtain best value for money. 

5.2.1.3.  Type-approval  requirements  for  CO2  measurement  and  fuel  consumption  determination  and 

reporting 

Annex XI, Ch. 1.5 

Option 1: No policy change; 
Option  2:  Type-approval  requirements  for  CO2  measurement  and  fuel  consumption  determination  and 
reporting 

Table 4: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 and 2 

Summary: 
Option 1, no change, has the disadvantage that type-approval demonstration testing does not provide a full 
environmental  picture  of  the  vehicle:  only  the  emissions  of  pollutants  are  measured  and  compared  to  the 
type-approval limits, whereas CO2 and fuel consumption need not even be measured or reported, although 
the measurement of this data comes at zero cost for the manufacturer. A further disadvantage of option 1 is 
that  consumers  do  not  consistently  get  fuel  efficiency  information  to  allow  them  to  choose  the  most  fuel-
efficient form of road transport. This is a pity, as L-category vehicles are light and therefore have an inherent 
advantage  in  comparison  to  passenger  cars.  The  advantage  of  option  1  is  that  the  cost  of  introducing  a 
product labelling system for manufacturers, importers and dealers is minimised, and it is left to the initiative 
of industry to fully inform its customers. 

Option 2 calls for CO2 measurement and fuel consumption determination and reporting at type-approval and 
to be indicated on the type-approval certificate and on the certificate of conformity . This data can then be 
used in a next step as a basis for a class A — G labelling system (as for other energy-consuming products), 
similar to that proposed for passenger cars with Directive 1999/94/EC. The disadvantage of option 2 is the 
additional cost and effort of labelling vehicles for the manufacturer and, further downstream, for the dealer. 
As a fuel efficiency labelling scheme as such did not fall under the scope of this impact assessment It was 
not  possible  to  quantify  the  total  cost  to  manufacturers  and  how  much  would  be  passed  on  to  the  end-
customer.  It  was  assumed  that  the  cost  of  measurement  for  manufacturers  would  be  insignificant,  as  CO2 
must  be  measured  anyway  for  type-approving  pollutant  emissions  (to  provide  a  base  for  pollutant 
measurement  correction).  Fuel  consumption  is  calculated  based  on  CO2,  CO  and  HC  emission 
measurements. The market will decide whether this low cost is passed on to the consumer or absorbed by 
industry.  Another  advantage  of  this  option  is  that  motorcycles  in  future  may  no  longer  compete  on  only 
engine  performance  (power  and  torque),  but  also  on  their  ability  to  perform  well  with  minimised  fuel 
consumption.  A  further  possible  future  advantage  of  option  2  is  an  EU-wide  CO2  and  fuel  consumption 
labelling system, if introduced, avoiding the need for national labelling systems that may be costly to industry 
and confusing to consumers if they compare vehicles in different Member States. Therefore, making labelling 
mandatory just at national level may be ineffective and may have little added value for consumers. Again the 
labelling  system  as  such  was  not  the  topic  of  this  assessment,  but  obligatory  measurement  and 
determination of its input data at type approval. 

5.2.1.4.  Evaporative emissions test and limit. 

Annex XI, Ch. 1.6 

Option 1: No policy change; 
Option 2: Replacement of all new carburetted models with fuel-injected models (scenario; 
Option 3: Evaporative emissions test and limit ensuring evaporative emission control for L-category vehicles 

Table 5: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3 

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Summary: 
The  major  disadvantage  of  option  1  is  that  it  does  not  address  the  disproportionately  high  HC  emissions. 
However, no hardware or software changes are required, nor must a special test facility be rented or bought 
by manufacturers, so this option has the advantage of no extra costs for manufacturers and consumers.  

Option 2 has advantages, but the high cost of fitting electronic fuel injection (EFI) to every L-category vehicle 
just to reduce the high share of evaporative HC emissions makes it seem largely academic. As the stricter 
emission limits under option 3 may lead to substantially more vehicle categories being equipped with EFI, the 
advantages of this option will automatically apply owing to organic growth in the share of vehicles with EFI. 
The basic reason for introducing EFI is better control of fuelling, which allows exhaust gas emissions to be 
minimised  and  more  flexibility  for  the  manufacturer  to  optimise  vehicle  drive-ability.  The  reduction  of 
evaporative emissions is just an advantageous and desirable side-effect. 

The disadvantage of option 3 is additional vehicle complexity and thus cost for the manufacturer, which will 
be passed on to the consumer, hence increasing vehicle prices. The advantage is that this is one of the more 
cost-effective policy options, as identified in the current and previous versions of the LAT report (2004 and 
2008). This means that the disproportionately high HC emissions can be reduced by a relatively simple and 
cost-effective method. 

5.2.1.5.  Durability requirements 
Annex XI, Ch. 1.7 

Option 1: No policy change; 
Option  2:  (Scenario  2  from  the  LAT  report):  deterioration  reduced  to  10 %  over  useful  life  with  linear 

extrapolation for higher mileages; 

Option  3:  (Scenario  2  from  the  LAT  report):  useful  life  increased  by  60 %,  i.e.  equivalent  to  the  increase  for 

passenger cars upon the move from Euro 3 (80k km) to Euro 5 (160k km). 
Table 6: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3  

Summary: 
Option  1,  no  change,  basically  means  that  the  policy  options  for  new  emission  limits,  as  summarised  in 
chapters  5.2.1.1  and  5.2.1.4,  will  be  ineffective.  If  there  is  no  need  for  a  manufacturer  to  guarantee  that 
emissions, as measured in demonstration testing for type-approval with a single new vehicle, remain within 
acceptable  limits  during  vehicle  life  (e.g.  over  an  accumulated  mileage  of  e.g.  12 000  km  for  mopeds  or 
50 000  km  for  motorcycles,  tricycles  and  on-road  quads),  the  emission  limit  met  by  this  new  vehicle,  as 
demonstrated to the type-approval authorities before the start of mass production and before introduction on 
the  market,  may  be  largely  irrelevant.  There  is  a  high  risk  that  once  vehicles  start  to  accumulate  mileage 
under real-world conditions their tailpipe emissions will deteriorate, as described in the durability test report 
published by the AECC (see chapter 2.1.2, problem definition, footnote). The same may hold for evaporative 
emissions.  If  an  aged  carbon  canister,  used  to  store  HC  until  it  can  be  fed  back  into  the  engine  for 
combustion, is not tested prior to the start of production as part of the demonstration testing programme43, 
the type-approval authorities will be unable to determine if this part of the emission abatement system will do 
what it is designed to: to significantly reduce evaporative emissions over vehicle life. 

The advantage of options 2 and 3 is that these concerns will be addressed. As IUC testing was discarded for 
reasons  explained  in  the  next  chapter,  there  is  no  direct  market  surveillance  mechanism  within  the  EU  to 
monitor and feed back to the legislator if and to what extent these concerns actually materialise. In PTI and 
RWT testing, which are only employed at national level in some Member States, it is not possible to verify 
what the exact level of degradation of the vehicle fleet is in terms of exhaust and evaporative emissions over 
vehicle  life.  This  can  only  be  verified  in  an  emission  laboratory  with  measurement  equipment  as  used  for 
type-approval demonstration testing. Therefore, durability requirements as defined in options 2 and 3 are the 
only  way  to  ensure  upfront  of  market  introduction  that  vehicles  may  be  still  acceptably  close  to  the  type-
approval emission test results when accumulating mileage under real-world conditions. The disadvantage of 
options  2  and  3  is  that  the  manufacturer  carries  the  full  burden  of  guaranteeing  that  the  vehicles  fulfil  the 
durability requirements, which means increased compliance costs and longer development programmes, so 
the time-to-market for new products may also increase. An additional disadvantage of option 3 is that moving 
from no durability requirements at present to high mileages may lead to initially uncompetitive products, as 
extending  the  mileage  in  durability  testing  is  costly  and  time-consuming.  This  may  result  in  manufacturers 
requiring more time to bring new products to the market, and the additional cost may be transferred to the 
consumer. It is necessary to monitor and evaluate the emission performance of the vehicle fleet some time 
after a durability measure is introduced to determine if a higher vehicle mileage should be set for useful life at 
a  later stage.  Annex  XI,  Ch.  1.7,  contains  a  proposal  for  the  initially  assumed useful  life of the  different  L-
category vehicles subject to type-approval emission limits. 

43

Introducing a SHED test limit value of e.g. 2 g for a new/degreened canister. 

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5.2.2. 
5.2.2.1. 

Annex XI, Ch. 2.1 

New measures to control emissions from vehicles in use 
In-use conformity (IUC) testing and limits 
Option 1: No policy change; 
Option 2: (Scenario 1 from LAT report): IUC procedure mandatory for all Euro 3 motorcycles. 

Table 7: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 and 2  

Summary: 
Owing to the many disadvantages, e.g. the low likelihood of finding appropriate, representative vehicles on 
the market for an IUC test sample and its low cost-efficiency, option 2 was discarded. Although option 2 only 
assessed motorcycles, the same arguments apply to other L-category vehicles such as mopeds, ATVs and 
mini-cars. 

5.2.2.2.  On-board diagnostic (OBD) systems and access to repair information 

Annex XI, Ch. 2.2 

Option 1: No policy change; 
Option 2: (Scenario 1 in LAT report): application of OBD systems using a similar technology as for passenger 

cars (EOBD), including catalyst efficiency monitoring for all L-category vehicles. Provision for 
access to repair and maintenance information, as for passenger cars; 

Option 3: (Scenario 2 in LAT report): use of best available technology (BAT): minor malfunction monitoring 

(e.g. circuit integrity check) (OBD stage 1) for all L-category vehicles, no catalyst efficiency 
monitoring. Provision for access to repair and maintenance information, as for passenger cars. 

Table 8: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3 

Summary: 
Option  1,  no  change,  does  not  require  an  on-board  diagnostic  system  for  L-category  vehicles.  The 
disadvantage  of  this  approach  is  that  that  there  will  be  no  standardised  diagnostic  socket  to  connect  a 
cheap,  generic  scan  tool  used  by  independent  repairers  or  riders  that  wish  to  repair  vehicles  themselves, 
there  will  be  no  standardised  communication  protocol  for  the  engine  control  module  to  `talk´  to  a  generic 
scan tool, no diagnostic information, such as diagnostic trouble codes (DTCs) or freeze-frame information, 
will be available to a generic scan tool, and independent repairers will be unable to effectively or efficiently 
diagnose  simple  failures  that  may  lead  to  high  emissions  or unsafe  situations.  In  addition, will  there be no 
obligatory standardised malfunction indicator light to indicate to the rider that there is a serious problem with 
the engine or vehicle which ought to be repaired in order to prevent environmental damage or a safety risk. 

The disadvantages associated with option 1 are addressed by options 2 or 3, which is an advantage of both 
options.  The disadvantage  of  option  2  is  that  it  may  need some additional  development  for  motorcycles  in 
order to find cost-effective solutions to detect misfire at high engine speeds (maximum engine speeds may 
be up to twice that of typical passenger car engines). In addition, robust catalyst diagnostics may be for the 
moment  still  problematic,  and  the  additional  hardware  and  software  development  needed  to  support  full 
EOBD, as in passenger cars, is considered to be rather expensive for the industry over the short term. 

Option  3,  however,  calls  for  introducing  the  simplest  form  of  OBD,  termed  OBD  stage  I,  combined  with 
access to repair information for independent repairers and riders who wish to repair their own vehicles, as 
already  applicable  today  in  the  passenger  car  industry.  All  vehicles  equipped  with  electronic  control  units 
(fewer  mopeds,  but  all other new  vehicles  in  the L-category)  already  have  this  proprietary  functionality on-
board.  Therefore,  the  cost  of  introducing  this  option  is  expected  to  be  low  —  vehicles  need  to  be  have  a 
standardised  diagnostic  connector,  two  wires  in  the  wiring  harness  from  the  connector  to  the  ECU,  and  a 
standardised  communication  protocol(CAN),  possibly  a  CAN  interface  in  the  ECU.  In  addition,  minimum 
software development is required since 95 % can be copied from passenger car applications and can be re-
used over the next decade on new models. A very small calibration, verification and validation effort is also 
needed, but can be re-used to a great extent for other types and variants or successor models. So, option 3 
requires a one-off moderate investment by the manufacturer but can then be carried over and re-used to a 
great extent over a long period. Accordingly, the high costs of OBD stage I implementation as identified in 
the  LAT  report  were  found  to  be  too  high  by  the  Commission,  at  least  over  the  medium  to  long  term,  and 
hence were rejected. Even for vehicles mass-produced on just a fraction of the scale compared to passenger 
cars, as in the case of L-category vehicles (lower economy of scale), the total cost for the manufacturer is 
estimated to be 25 % to 50 % of the cost estimated in the LAT report, which obviously leads to significantly 
better  cost-effectiveness  and  hence  represents  an  advantage  for  this  option.  The  disadvantage  for  the 
manufacturer, apart from the one-off investment, is slightly increased compliance costs. However, as many 
contract  dealers  may  be  independent  repairers  for  other  brands,  harmonised  OBD  information  will  also  be 
advantageous  to  this  sector.  Moreover,  riders  who  are  technically  interested  and  opt  to  repair  their  own 
vehicles will benefit from standardised, basic diagnostic information, as generic scan tools can be purchased 
on the market. 

Safety measures 

5.3. 
5.3.1.  Obligatory fitting of advanced brake systems 
Annex XII 
Annex XII Ch.1 

Qualitative and quantitative analysis of policy options for obligatory fitting of advanced brake systems 

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Annex XII Ch. 1.1 
Annex XII Ch. 1.2 
Annex XII Ch. 1.3 

Option 1: No policy change; 
Option 2: Anti-lock brake systems on all powered two-wheelers (PTWs); 
Option 3: Anti-lock brake systems on PTWs with cylinder capacity >125 cm3 and advanced brake systems 
(combined brake system and/or anti-lock brake systems) on motorcycles with 50 cm3 < cylinder 
capacity ≤ 125 cm3 (NB: 125 cm3 relates to vehicle performance criteria for the A1 driving licence); 

Annex XII Ch. 1.4 

Option 4: Obligatory fitting of advanced brake systems (combined brake systems and/or anti-lock braking 

systems) on motorcycles conforming to the performance criteria for the A2 driving licence. 
Obligatory fitting of anti-lock brake systems on all other L3e motorcycles; 

Annex XII Ch. 1.5 

Option 5: Industry self-regulation. 

Table 9: Click on the ‘Annex’ links to display the full, detailed analysis of policy options 1 to 5  

Summary: 
Option 1, no change, does nothing about the unacceptable fact that every year many PTW riders die in road 
accidents,  e.g.  5 520  PTW  riders  in  2008,  and  even  many  more  of  them  get  seriously  injured  or  even 
disabled for the rest of their lives. 
Option 2, obligatory fitting of anti-lock brake systems on all PTWs (two-wheel mopeds and motorcycles), was 
found to be technically very advantageous as it is best way of preventing critical wheel lock. Wheel lock often 
leads  to  a  longer  stopping  distance  and  may  also  cause  the  rider  to  fall  because  the  vehicle  becomes 
uncontrollable. Also, riders will have confidence that wheel lock will not occur with anti-lock brakes fitted so 
that  they  actually  dare  to  brake.  A  number  of  studies  have  reported  that  no  traces  are  often  found  on  the 
road  after  accidents,  indicating  that  the  rider  did  not  attempt  to  brake  at  all.  However,  this  option  has  a 
number of disadvantages, mainly economic. Cost-effectiveness is controversial and difficult to estimate, as it 
is dependent on a large number of factors. Overall, the literature points to a solid positive cost-effectiveness, 
and the high cost–benefit ratios (around 3 as the best average) noted in the TRL report seem to confirm this 
assumption. 

Options 3 and 4 are basically attempts to decrease the cost for industry without compromising too much the 
safety benefits offered by anti-lock brake systems. The major advantages of option 3 are the high estimated 
fatality  and  injury  reductions.  Additionally,  the  high  cost–benefit  ratios  are  very  attractive.  Major  negative 
impacts  of  this  option  are  the  possible  price  increases  for  consumers  and  possible  non-availability  of  anti-
lock  brake  system  technology  to  SME  manufacturers.  The  latter  is  because  an  SME  might  not  be  able  to 
take on the minimum volumes demanded by bigger automotive suppliers or alternatively could be confronted 
with high development costs, as suppliers might not be able to justify investment in tooling to produce ABS 
components owing to the SME’s small series production. The major advantage of option 4 is that it employs 
the same categorisation of low- and high-performance motorcycles as used in the Driving Licence Directive 
(matching vehicle type-approval and driving licence criteria, hence ensuring coherence). This makes a clear 
distinction between non-powerful and powerful PTWs, thus indicating which type of vehicle must to be fitted 
with  an  anti-lock  brake  system  and  which  can  be  fitted  with  either  an  anti-lock  brake  system,  a  combined 
brake system or both, depending on what manufacturers deem to be cost-effective and to offer the best level 
of  safety  for  their  customers.  On  the  other  hand,  the  technical  effectiveness  of  both  options  3  and  4  is 
expected to be lower than for option 2, as the Commission considers that combined brake systems can only 
help  to  reduce  critical  wheel  lock  up  to  a  certain  level,  not  eliminate  it  altogether,  resulting  in  a  smaller 
reduction in fatalities and injuries. The economic impact of option 3 and 4 is estimated as being in the same 
order  of  magnitude.  For  option  4,  no  cost-benefit  estimate  was  in  fact  calculated  by  the  consultant  as  this 
scenario was added at a late stage. Owing to the similarity with option 3, the same cost range and benefit 
data were assumed for both options, based on the calculations for option 3. 

Option 5 was unfortunately referred to in the policy option assessment report as ‘no change’ (option A). It is 
obvious  and  appreciated  by  the  Commission  that  the  industry  is  seriously  attempting  to  address  the  high 
level  of  fatalities  and  serious  injuries  by  voluntarily  offering  self-regulation.  Consequently,  the  industry  is 
committed  to  offering,  by  2015,  75 %  of  street  motorcycle  models  with  an  advanced  braking  system  as  an 
option or fitted as standard. One question remains: does this option go far enough to meet the objective of 
significantly reducing fatalities and casualties among PTW riders involved in road accidents ? 

Despite the commitment by manufacturers since 2004 to introduce advanced brake systems as an option on 
powered two-wheelers, the road fatality statistics have not fallen, but remain more or less the same or have 
even slightly increased (up to 2008). The TRL report estimates that only 23 % of the fleet will be equipped 
with anti-lock and/or combined brake systems by 2020 under the current self-regulation. However, this would 
nonetheless save 1436 lives with a corresponding saving of € 1. 2 billion and reduce injuries with savings in 
the order of € 1.1 billion as best estimates. 

According  to  the  TRL  report  (Table  12,  p.  26),  actual  take-up  by  customers  of  antilock  brake  systems, 
combined brake systems or both will grow from 20 % in 2011 to 41 % by 2020. Effectively, this means that 
9 % of the PTW fleet in 2011 will be equipped with such systems. This will grow to an estimated 23 % of the 
vehicle fleet by 2020. The advantages of industry self-regulation are significantly lower burdens to industry 

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and less complex and prescriptive legislation. On the other hand, a major negative impact is a significantly 
lower  reduction  in  fatalities  and  injuries.  Although  voluntary  self-regulation  has  already  applied  since  2004 
and is on schedule (35 % of all PTWs offered have advanced brake systems), the fatality statistics have so 
far not significantly decreased and remain static or are even slightly increasing.  

5.3.2. 

Anti-tampering measures  

Annex XII, Ch. 2  Option 1: No policy change; 

Option 2: Repeal Chapter 7 of Directive 97/24/EEC, currently partly obsolete anti-tampering measures; 
Option 3: New measures on anti-tampering. 

Table 10: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3  

Summary: 
Option 1 suffers from an extensive list of disadvantages, as the baseline safety and environmental concerns 
would  not  be  addressed.  One  might  consider  a  benefit  to  be  the  technical  know-how  that  amateur  vehicle 
tuners can acquire from "creative" engine tuning activities, which is the starting point and motivation for many 
engineering careers. Another controversial benefit is the fact that the tuning industry could continue to make 
revenue and employ people. However, these benefits may not go at the cost of safety and/or environmental 
protection. 

Option  2  has  the  same  extensive  list  of  disadvantages,  but  in  this  case  the  effects  are  several  orders  of 
magnitude  worse.  One  additional  advantage  for  vehicle  manufacturers  is  a  lower  burden,  as  one  type-
approval less would be required to obtain whole-vehicle type-approval. 

Finally,  while  option  3  would  not  completely  eliminate  the  disadvantages  of  options  1  and  2,  it  would 
eliminate  costly  obsolete  measures  and  align  measures  with  the  substantial  progress  in  technology 
development.  Only  a  qualitative  assessment  was  carried  out  owing  to  a  lack  of  economic  information.  All 
vehicles  with  electronic  engine  management  systems,  for  which  the  current  anti-tampering  measures 
enforced  are  ineffective,  will  be  covered  by  the  new  Regulation  in  addition  to  the  mopeds  and  light 
motorcycles currently included. 

5.3.3. 

74kW power limitation for motorcycles 

Annex XII, Ch. 3  Option 1: No policy change; 

Option 2: Repeal the option given to Member States to limit power to 74kW; 
Option 3: Set a harmonised limit of 74kW; 
Option 4: Use alternative limitation criteria. 

Table 11: Click on ‘Annex’ to display the full, detailed analysis of policy options 1, 2 and 3  

Summary: 
In the literature, no clear evidence was found to suggest that limiting the power of a motorcycle to 74kW has 
a positive impact on the number of road accidents involving motorcycles. Other factors such as rider attitude, 
experience and the issues listed under the previous chapters have a greater influence on accident risk. 

Option 1 suffers from the major disadvantage that manufacturers have to develop special products to meet 
the power limitation requirement, currently imposed by only one Member State. These products have to be 
separately distributed as well, so development and distribution costs are estimated to be higher. 

Option 2 offers the optimum economic benefits to manufacturers as compliance costs would be reduced and 
the concerns associated with option 1 would be avoided. The cost-effectiveness of option 3 is doubtful, as 
already indicated. The advantage of option 4 is that alternative, more cost-effective limitation criteria could be 
used. The drawback, however, is that no data are currently available to determine possible alternative criteria 
such as power-to-mass ratio. 

5.4. 
5.4.1. 

Improved categorisation of L-category vehicles 
Recategorise  electrically  assisted  cycles  (currently  outside  the  scope  of  the  legal  framework), 
tricycles (category L5e) and quadricycles (categories L6e and L7e) 

Annex XIII, Ch. 1  Option 1: No policy change; 

Option 2: Exclude quadricycles and electrical cycles from the Regulation; 
Option 3: Return to the original spirit of the legislation for mini-cars; 
Option 4: Improve the legislation by adding new requirements for mini-cars based on car requirements; 
Option  5:  Refine  vehicle  categories  by  introducing  new  subcategories  in  L1e,  L5e,  L6e  and  L7e.  Add  new  / 

revised requirements for these subcategories. 

Table 12: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 to 5  

Summary: 
The disadvantage of option 1 is the volume of the current legal text, which has proliferated over the years 
and  contains  inappropriate  or  obsolete  measures  or  no  measures  at  all  (e.g.  obligatory  fitting  of  an 
elementary safety feature such as a differential on a four-wheel powered vehicle), where such measures are 

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considered  essential  for  environmental  protection  and  safety.  One  of  the  root  causes  of  this  problem  is 
inappropriate or non-existent classification criteria. 

The  disadvantage  of  option  2  is  even  greater  confusion  among  stakeholders  owing  to  the  absence  of 
appropriate rules and the need for L1e, L5e L6e and L7e vehicle manufacturers to have their vehicles type-
approved  at  national  level.  Noise,  emission  and  fuel  consumption  levels  may  also  increase.  To  a  lesser 
extent, these negative impacts are also applicable to option 3.  

As Option 4 would drive up costs for mini-car producers to very high levels, this industry, which is completely 
composed of SMEs (the market leader with the highest sales volume employs about 200 people), would not 
be able to survive if subjected to such a high burden on the short to mid term. 

Option 5 deals with the concerns but has the major disadvantage of potentially significant compliance costs. 
Unfortunately,  no  economic  data  are  available  for  any  of  these  options,  although  the  results  of  the 
quantitative analysis, weighing the pros and cons, point to option 5 as the optimum solution. In particular, the 
better coherence within L-category legislation and also with the legislation applicable to other means of road 
transport is a clear advantage. Other positive impacts are increased clarity for industry and stakeholders and 
the  possibility  for  the  legislator  to  be  able  to  develop  more  effective  measures  in  terms  of  environmental 
protection and safety. 

5.4.2. 

Specific requirements for category L7e vehicles 

Annex XIII, Ch. 2  Option 1: No policy change; 

Option 2: Exclude off-road quads (ATVs) from the Regulation and add new requirements on safety and 

emissions for on-road quadricycles (on-road quads and mini-cars); 

Option 3: Keep the existing L7e category and add new requirements on safety for all quadricycles; 
Option 4: Create new subcategories within L7e with specific requirements for off- and on-road quadricycles. 
Table 13: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 to 4 

Summary: 
Option 1 is disadvantageous from the safety, environmental, economic and societal perspectives, as three 
completely different vehicle types (mini-cars, on-road quads and off-road quads), are allocated to the same 
category L7e even though their only common characteristic is that they have four wheels. It is not considered 
possible to address the individual concerns associated with each specific vehicle type with appropriate and 
cost-effective measures. No positive impacts could be determined for this scenario.  

Option 2 offers the advantage that the environmental and safety concerns of on-road quads and mini-cars 
can  be  effectively  addressed  by  specific  measures.  In  addition,  if  ATVs  are  excluded,  they  will  fall 
automatically under the Machinery Directive with regard to safety and under the Non-Road Mobile Machinery 
Directive  as  regards  environmental  requirements.  This  is  already  partly  the  case  today,  so  for  ATVs  this 
would be the most cost-effective option. As the requirements for ATVs are similar to those for other ‘non-road 
mobile machinery’, manufacturers would benefit from lower compliance costs and could pass this on in the 
form  of  lower  consumer  prices.  In  particular,  SMEs  in  the  agricultural  and  forestry  sector,  which  purchase 
ATVs as a cheap alternative to tractors, could benefit from such lower prices. 

Option 3 is advantageous in that it offers the possibility to revise or develop more appropriate environmental 
and  safety  measures  for  all  quadricycles,  which  may  address  the  concerns  identified  in  this  field.  The 
disadvantage is that three different vehicle sub-types would still be assigned to a single subcategory, which 
makes it difficult to develop specific measures for a specific vehicle type, e.g. to separate off-road, on-road 
quads and mini-cars. 

Finally,  option  4  offers  the  highest  flexibility  to  recategorise  the  three  vehicle  types.  It  also  provides  the 
possibility to further split up quads into subcategories for on-road quads and mini-cars. Both the latter types 
again might need different measures as they are designed for different uses. On-road quads would need to 
offer the same level of safety and environmental performance as other road transport vehicles. 

A special subcategory for ‘on-road quads’ would increase clarity for stakeholders as to which requirements 
must be met for this vehicle to be considered safe and environmentally acceptable for use on public, paved 
roads. The disadvantages of option 4 could be that consumer prices for ‘on-road’ quads might increase and 
manufacturers  might  have  to  meet  more  requirements  before  such  vehicles  could  be  type-approved  and 
allowed  to  travel  on  public  roads.  Further  analysis  of  this  scenario  indicates  that  it  is  unfeasible  to  find 
enough  characteristic  design  criteria  to  separate  on-road  quads  sufficiently  well  from  off-road  quads.  For 
example, on-road quads could at first be type-approved  as off-road quads and then retrofitted with a kit to 
make them roadworthy, but not necessarily compliant with EU safety and emission standards. Such vehicles 
would benefit from the advantages of a virtual off-road quad subcategory, but would circumvent the safety 
and  environmental  measures  developed  specifically  for  on-road  quads.  In  addition,  only  on-road  vehicles 
traditionally fall under the scope of type-approval legislation, but this concern could possibly be addressed as 

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for  agricultural  vehicles,  which  are  also  designed  predominantly  for  off-road  use,  but  which  are  still  type-
approved. 

5.4.3. 

Specific requirements for gaseous alternative fuels and other non-traditional propulsions 

Annex XIII, Ch. 3  Option 1: No policy change; 

Option 2: Legislation at EU level through a more refined vehicle categorisation with specific measures for the 

different vehicles and propulsion technologies. 

Table 14: Click on ‘Annex’ to display the full, detailed analysis of policy options 1 and 2  

Summary: 
Option 1 suffers from the common disadvantages for manufacturers that want to market their products EU-
wide: potentially different national approval requirements that need to be met. There is a risk that divergent 
requirements may lead to trade barriers. There may be inappropriate environmental and safety measures, or 
no  measures  at  all,  reducing  the  environmental  benefit  inherently  offered  by  these  types  of  propulsions  in 
comparison to using ‘conventional’ diesel and gasoline fuels. 

Option  2  provides  the  flexibility  to  develop  measures  to  address  fuel-specific  environmental  and  safety 
concerns,  which  is  an  advantage.  The  level  of  innovation  in  safety  and  environmental  technology  may  be 
stimulated  by  introducing  specific  measures  for  gaseous  alternative  fuels  and  other  non-traditional 
propulsions. The disadvantages are that the cost of compliance for manufacturers may be higher initially and 
that in general consumers perceive gaseous fuels to be dangerous and difficult to handle. There could be an 
economic  benefit  for  manufacturers  if  the  measures  were  designed  carefully,  international  standards 
(UNECE)  were  used  as  much  as  possible,  and  this  type  of  technology  were  to  be  subsidised  at  Member 
State  level,  in  other  words  to  provide  incentives  to  manufacturers  and  consumers  to  make  alternative 
propulsion  concepts  more attractive.  This  could  allow  manufacturers  to  produce  vehicles  for the  whole  EU 
market and subsequently for global markets, which could cut the cost of these technologies in the long run 
owing  to  economies  of  scale.  Once  it  is  demonstrated  to  consumers  that  the  advantages  of  alternative 
propulsions significantly outweigh the disadvantages, demand for such products may rise. 

5.4.4. 

Proposal to combine the results of the preferred options for improved categorisation of L-category 
vehicles 

Annex XVII, Ch. 4   Revise the categorisation for L-category vehicles by combining the preferred options of sections 5.4.1 to 5.4.3.  

Table 15: Click on ‘Annex’ to see the detailed proposal to recategorise L-category vehicles 

6. 
6.1. 

COMPARISON OF OPTIONS AND CONCLUSIONS 
Simplification of legislation 

Annex XIV 

Option 1: No policy change; 
Option 2: Repeal current directives and replace with a minimum number of regulations; 
Option 3: Recast the current Framework Directive 2002/24/EC. 
Table 16: Click on ‘Annex’ for the full, detailed comparison of policy options 1, 2 and 3  

Summary: 
In terms of efficiency, options 2 and 3 perform equally well, especially because both call for the current legal 
text to be replaced by technical equivalent or more appropriate UNECE regulations as far as possible, which 
should  simplify  the  Regulation  and  in  particular  the  associated  technical  implementing  measures.  For  the 
new Regulation on approval and market surveillance of L-category vehicles, only the intention to use UNECE 
regulations can be indicated. The subsequent delegated acts containing technical details, to be developed 
after adoption of the Regulation, will clarify which specific text of the repealed implementing directives can be 
replaced with UNECE regulations. 

Regarding efficiency, option 2 is better in terms of transposition and implementation costs and is expected to 
reduce  the  risk  of  delay  in  dealing  with  urgent  matters  or  changes.  As  a  result,  the  benefits  of  any  new 
measures can be obtained more rapidly. Option 2 is therefore preferred. 

6.2. 
6.2.1. 
6.2.1.1.  Revised lower emissions limits 

Environmental measures 
New or revised environmental measures for the type-approval of new vehicles 

Annex XV, Ch. 1.1  Option 1: No policy change; 

Option 2: New emission limits for L1e mopeds: a cold-start R47 test cycle and a 30 % weighting factor for cold 
start are proposed (scenario 1 from LAT report). No change in limits for other L-category vehicles; 

Option 3: Motorcycle industry proposal (scenario 2 from LAT report); 
Option 4: New measures based on best available technology for L-category vehicles sold today in the market 

(scenario 3 from LAT report); 

Option 5: New limits for all L-category vehicles equivalent in absolute terms to Euro5 M1 light-duty vehicles 

(scenario 4 from LAT report). 

Table 17: Click on ‘Annex’ to display a detailed comparison of policy options 1 to 5  

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Summary: 
The  main  criteria  for  comparing  between  the  5  different  options  over  the  short  to  medium  term  are 
implementation time and cost-effectiveness. Option 3 scores best for these aspects. However, over the long 
term,  the  disproportionately  high  HC,  CO  and  PM  emissions  must  be  addressed,  and  this  can  only  be 
achieved with option 5. Even option 5 will not be sufficient to bring emissions into line with the very low total 
vehicle  mileage  accumulated  with  L-category  vehicles  (2  –  3 %  of  total  road  vehicle  mileage),  but  it  is 
considered to be the most that can be done by the L-category vehicle industry to ensure clean vehicles over 
the long term. Therefore, the optimum solution will be a combination of a slightly modified option 3 (separate 
limits, which means no combined HC & NOx limits for all L-category vehicles) over the short to medium term 
(2013  –  2016  timeframe)  and  option  5  for  the  long  term  (2019–2020)  depending  on  the  results  of  an 
additional environmental effect study to be carried out by 2016. This strategy should provide industry with a 
longer lead-time and therefore help to mitigate the burden and the long-term effects of the current financial 
crisis on the industry. While option 3 is based on the self-regulation proposal put forward by the industry, the 
legal  instrument  used  would  be  the  new  Regulation  on  approval  and  market  surveillance  of  L-category 
vehicles, which will make these limits obligatory for type-approval. 

Although PM will not be limited, the expectation is that the THC limit will automatically lead to a reduction in 
VOC, especially taking into account the particular composition and volatility of the particulates emitted by L-
category vehicles in comparison to e.g. those emitted by diesel passenger cars. 

6.2.1.2. Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicles  

Annex XV, Ch. 1.2  Option 1: No policy change; 

Option  2:  Use  of  a  revised  World-wide  harmonised  Motorcycle  emissions  Testing  Cycle  (WMTC)  for  all  L-
category vehicles. 

Table 18: Click on ‘Annex’ to display the detailed comparison of policy options 1 and 2  

Summary: 

The  advantages  of  using  the  stage-two  WMTC  only  for  L3e  category  vehicles  over  the  short  term  and  a 
revised WMTC other L-category vehicles over the medium to long term outweigh the disadvantages by far. 
Therefore, option 2 is the preferred solution for the long term. In order to provide industry with sufficient lead-
time a transition towards the use of WMTC for all L-category vehicles is proposed as summarised in Annex 
XV,  Ch.  1.2,  Table  2.  Certain  L-category  vehicles  (L1B,  L2e,  L5e,  L6e,  and  L7e)  do  not  yet  come  under 
UNECE  global  technical  regulation  2  (WMTC).  The  Commission  will  need  to  launch  an  initiative  within 
UNECE to include these subcategories in the long term (2020). 

6.2.1.3.  Type-approval  requirements  for  CO2  measurement  and  fuel  consumption  determination  and 

reporting 

Annex XV, Ch. 1.3  Option 1: No policy change; 

Option  2:  Type-approval  requirements  for  CO2  measurement  and  fuel  consumption  determination  and 
reporting 

Table 19: Click on ‘Annex’ to display the detailed comparison of policy options 1 and 2 

Summary: 
The  ratings  for  effectiveness,  efficiency  and  coherence  are  overall  positive  to  highly  positive  for  option  2. 
Consumers  need  to  have  additional  information  presented  in  a  standardised  form  for  them  to  be  able  to 
compare  the  fuel  efficiency  of  different  vehicles  within  the  L-category  and  to  be  able  to  compare  with 
alternative  means  of  road  transport.  This  will  allow  them  to  purchase  the  most  fuel-efficient  vehicle  or  to 
choose the optimum transport alternative in terms of fuel cost and will make them aware of the green house 
gas emissions per kilometre travelled. The motorcycle riders’ association, FEMA, for example welcomes the 
introduction of a compulsory labelling scheme, for which the data obtained through option 2 will be used as 
input. The preferred solution is therefore option 2. As L-category vehicles only contribute little to the overall 
CO2 emissions of road transport as a whole, an explicit limit value was not deemed necessary. In fact, if the 
pollutant concerns of PTWs were addressed (currently their emissions are disproportionately high compared 
to  all  road  transport  based  on  mileage  travelled),  it  would  be  advantageous  if  heavy,  big  passenger  cars 
were to be substituted by light, flexible L-category vehicles. This may help to bring down the overall high fuel 
consumption of road vehicles and significantly reduce emissions of green house gas emissions like CO2. 

6.2.1.4.  Evaporative emissions test and limit 

Annex XV, Ch. 1.4  Option 1: No policy change; 

Option 2: Replacement of all new carburetted models with fuel-injected models; 
Option 3: Evaporative emissions test and limit ensuring evaporative emission control for L-category vehicles; 

Table 20: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3  

Summary: 

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As the high hydrocarbon emissions of L-category vehicles can only be influenced to a relatively small extent 
by  type-approval  measures  addressing  evaporative  emissions,  an  effective  low-cost  measure  that  can  be 
implemented quickly  is  preferable.  The advantages  of  option  2  will  become  automatically  available  if  more 
stringent  emission  thresholds  will  need  to  be  fulfilled  and  the  highest  part  of  the  financial  burden  to  the 
manufacturers  will  already  be  amortised  by  the  necessary  hardware  changes  under  this  policy  option  to 
introduce revised tailpipe emission limits. Option 3 is estimated to be the only cost-effective way of reducing 
evaporative emissions from L-category vehicles and is therefore the preferred option. 

6.2.1.5.  Durability requirements 
Annex XV, Ch. 1.5  Option 1: No policy change; 

Option  2:  (Scenario  2  from  the  LAT  report):  deterioration  reduced  to  10 %  over  useful  life  with  linear 

extrapolation for higher mileages; 

Option  3:  (Scenario  2  from  the  LAT  report):  useful  life  increased  by  60 %,  i.e.  equivalent  to  the  increase  for 

passenger cars upon moving from Euro 3 (80k km) to Euro 5 (160k km). 
Table 21: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3 

Summary: 
Option  1  was  discarded  as  this  makes  the  introduction  of  revised  emission  limits  ineffective.  Option  3  is 
regarded  as  very  expensive  and  may  inhibit  manufacturers  from  introducing  new  products  on  the  market. 
The introduction of durability requirements for L-category vehicles in option 2 already addresses the majority 
of the concerns identified at an acceptable cost to industry, so is therefore the preferred solution. 

6.2.2. 
6.2.2.1. 

New measures to control vehicle emissions over vehicle life 
In-use conformity (IUC) testing and limits. 

Annex XV, Ch. 2.1  Option 1: No policy change; 

Option 2: (Scenario 1 from LAT report): IUC procedure mandatory for all Euro 3 motorcycles. 

Table 22: Click on ‘Annex’ to display the detailed comparison of policy options 1 and 2  

Summary: 
Owing to the many disadvantages, including impracticability and only moderate cost-effectiveness, IUC was 
discarded.  However,  this  is  one  of  the  assumptions  which  will  be  re-examined  in  the  environmental  effect 
study referred to in chapter 6.2.1.1. 

6.2.2.2.  On-board diagnostic (OBD) systems and access to repair information 

Annex XV, Ch. 2.2  Option 1: No policy change; 

Option 2: (Scenario 1 in LAT report) application of OBD systems using a similar technology as for passenger 

cars (EOBD), including catalyst efficiency and misfire monitoring for all L-category vehicles. 
Provision for access to repair and maintenance information, as for passenger cars; 

Option 3: (Scenario 2 in LAT report) use of best available technology (BAT): minor malfunction monitoring 

(e.g. circuit integrity check) (OBD stage 1) for all L-category vehicles, no catalyst efficiency 
monitoring. Provision for access to repair and maintenance information as for passenger cars. 

Table 23: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3  

Summary: 
A distortion of competition arises in the internal EU market, as independent repairers are not able to retrieve 
standardised diagnostic  on-board  information  from  vehicles and  are  therefore not  able  to repair  failures as 
effectively  and  efficiently  as  contract  dealers  and  repairers.  In  the  repair  cycle  (diagnosis  and  analysis  of 
problem,  repair  of  smallest  identifiable  component  or  ordering  of  replacement  parts  and  replacement  of 
smallest  exchangeable  unit)  the  availability  of  harmonised  diagnostic  information  from  the  OBD  system  is 
essential for an independent dealer or even for a vehicle owner, to effectively and efficiently repair a vehicle. 
As option 3 is estimated to have a much better cost-effectiveness than option 2, this is the preferred option 
for  the short term  (2017). In  addition,  option  3  paves  the way  for  a  possible  introduction  of  option  2  in the 
long term (2019), if proven cost effective in the environmental effect study referred to in chapter 6.2.1.1. 

Safety measures 

6.3. 
6.3.1.  Obligatory fitting of advanced brake systems 
Annex XVI, Ch. 1 

Annex XVI Ch. 1.1 
Annex XVI Ch. 1.2 
Annex XVI Ch. 1.3 

Qualitative and quantitative analysis of policy options for obligatory fitting of advanced brake systems 
Option 1: No policy change; 
Option 2: Anti-lock brake systems on all powered two-wheelers (PTWs); 
Option 3: Anti-lock brake systems on PTWs with cylinder capacity >125cm3 and advanced brake systems 
(combined brake systems and/or anti-lock brake systems) on motorcycles with 50 cm3 < cylinder 
capacity ≤ 125 cm3 (NB 125 cm3 relates to the vehicle performance criteria for the A1 driving 
licence); 

Annex XVI Ch. 1.4 

Option 4: Obligatory fitting of advanced brake systems (combined brake systems and/or anti-lock braking 

systems) on motorcycles conforming to the performance criteria for the A2 driving licence. 
Obligatory fitting of anti-lock brake systems on all other L3e motorcycles; 

Annex XVI Ch. 1.5 

Option 5: Industry self-regulation. 
Table 24: Click on ‘Annex’ to display the detailed comparison of policy options 1 to 5  

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See  also  Annex  XVI,  Ch.  1.6  for  an  impact  assessment  of  anti-lock  brake  system  technology  fitted  to 
vehicles manufactured and type-approved by SMEs. 

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Summary: 
Recently, three retrospective studies44 were published, which were not included in the literature study for the 
TRL report. The value of these studies is that the results were based on an analysis of actual accident data, 
unlike  in  the  majority  of  the  literature  assessed,  which  was  predominantly  forward-looking.  The  Spanish 
study provided relevant statistics on motorcycle accident fatalities, indicating that motorcycles with a higher 
engine displacement are overrepresented in fatal accidents. The Swedish and US studies confirmed the high 
cost-effectiveness  of  anti-lock  brake  systems,  with  estimates  even  higher  than  for  most  of  the  studies 
summarised  in  the  TRL  report.  The  estimates  ranged  from  11  to  17 %  in  the  Swedish  study.  On  the  other 
hand, the 38 % cost-effectiveness found in the US study was not statistically relevant, although the results 
indicated  that  ‘there  is  considerable  confidence  that  anti-lock  brake  systems  prevent  fatal  crashes  among 
motorcyclists’. 

In  terms  of  reducing  fatalities  and  injuries,  options  2,  3  and  4  are  superior  to  options  1  and  5,  which  are 
therefore considered insufficient. In terms of cost-benefit ratios, options 3 and 4 are considered to be similar, 
and are under the given assumptions slightly worse than option 2. Option 5 lags significantly behind options 
2, 3 and 4 in terms of saved lives and casualty prevention. The fact that the fatality statistics have remained 
more  or  less  the  same  in  recent  years,  despite  the  self-regulation  already  ‘in  force’  since  2004,  seems  to 
indicate that the number of vehicles equipped with advanced brake systems in the EU market is not yet high 
enough to result in the significant road fatality reductions necessary to meet the safety objectives.  

A  concern  with  industry  self-regulation  is  that  offering  vehicles  with  advanced  brake  systems  as  an  option 
does not automatically mean that the vehicles sold are actually equipped with these systems. The industry 
depends on the demand from customers and their actual purchase decisions. If customers choose to save 
money and do not opt for advanced brake systems, even more in current times of economic difficult times, 
only a small part of the fleet will actually be equipped with these systems. If the current trend continues, only 
23 % from the vehicle fleet are estimated to be equipped with anti-lock brake systems by 2020, as estimated 
in the TRL report, which is not regarded as sufficient to meet the safety objectives.  

It should also be pointed out that ACEM’s members are responsible for 90 % of the production of powered 
two-wheelers  (PTWs)  in  Europe  and  up  to  95 %  of  the  market.  This  means  that  the  remaining  10 %  of 
vehicles  produced  by  the  5 %  of  manufacturers  not  affiliated  to  ACEM  are  likely  to  continue  producing 
vehicles not equipped with advanced brake systems, in order to sell products as cheap as possible. A further 
problem for the EU is that some vehicles on the market do not seem to meet any type-approval requirements 
relating to safety and the environment. This can only be addressed by better market surveillance, which is 
another  priority  for  the  European  Commission,  which  will  be  addressed  with  this  Regulation.  The 
Commission  appreciates  the  effort  and  good-will  of  the  motorcycle  industry  to  offer  PTWs  with  advanced 
braking  systems,  but  considers,  for  the  above  reasons  and  in  view  of  other  aspects  listed  in  the  detailed 
analysis, that self-regulation as not sufficiently effective to achieve its ambitious safety goals. 

It  is  acknowledged  that  estimates  of  the  cost  of  advanced  brake  systems  are  controversial,  as  no 
independent information is available from e.g. EuroStat, which is why best estimated values for options 2, 3 
and  4  vary  so  widely.  Chapter  3.5.1  in  the  TRL  report  (Table  11)  gives  best  estimates  of  the  price  of 
advanced  brake  systems  for  option  5  at  the  point  of  sale  (anti-lock  brake  system:  € 539;  combined  brake 
system: € 150). In Table 14 of chapter 3.5.1, the best estimated price for both anti-lock brake systems and 
combined brake systems was € 150 for option 2. Despite of the controversy of this assumption it is assumed 
that the high demand from manufacturers to their suppliers for anti-lock brake systems and combined brake 
systems if they are made obligatory will result in similar economies of scale for options 3 and 4 and hence 
lower prices than for the other options.  

Given the difference in complexity between anti-lock brake systems and combined brake systems, it seems 
obvious  that  the  best  estimated  cost  for  combined  brake  systems  will  be  lower  than  for  anti-lock  brake 
systems. It is therefore assumed that it is cheaper for a manufacturer to equip a PTW with a combined brake 
system  than  with  an  anti-lock  brake  system.  For  cheaper,  less  powerful  PTWs  in  particular,  the  consumer 
price may be significantly increased if a more expensive anti-lock brake system is fitted instead of a cheaper 
combined brake system. Therefore, from a purely cost perspective, options 3 and 4 offer more advantages 
for  the  manufacturer  and  consumer  than  option  2.  The  best  estimated  price  for  combined  brake  systems 
(€ 150) is considered to be on the conservative side. 

44

1) Swedish Road Administration: The effectiveness of anti-lock brake systems on motorcycles reducing real-life crashes and 
injuries — 29 June 2009. 2)  pp. 41 – 43: 
http://www.dgt.es/portal/es/seguridad_vial/estudios_informes/estudios_informes084.htm. 3) US Insurance Institute for 
Highway Safety: Effectiveness of Antilock Braking Systems in Reducing Fatal Motorcycle Crashes — October 2008. 

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Option 3 and to a lesser degree option 4 seem to offer the best compromise between significant fatality and 
injury reductions, on the one hand and an estimated moderate increase in cost to the end-consumer in the 
low-price PTW segment (mopeds and light motorcycles) on the other. In particular, linking the driving licence 
classification criteria to the type-approval criteria will also improve the coherence of EU legislation. For this 
reason, the preferred options are 3 or 4. 

6.3.2. 

Anti-tampering measures  

Annex XVI, Ch. 2 

Option 1: No policy change; 
Option 2: Repeal Chapter 7 of Directive 97/24/EEC, currently obsolete anti-tampering measures; 
Option 3: New measures on anti-tampering. 

Table 25: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3  

Summary: 
Although no explicit cost information was available, option 1 is considered the no-cost option. On the other 
hand, no identified concern would be addressed. Option 2 is even worse and is considered to be a step back 
in time (before 1996). It would lead to a lot of undesirable amateur tuning, resulting in high vehicle speeds 
and unsafe and environmentally unfriendly vehicles. Option 3 is probably the most expensive of the threes, 
but  has  the  potential  to  partly  address  the  adverse  effects  of  tampering  and  associated  safety  and 
environmental concerns. The preferred option is therefore option 3. 

6.3.3. 

74 kW power limitation for motorcycles 

Annex XVI, Ch. 3 

Option 1: No policy change; 
Option 2: Repeal the option given to Member States to limit power to 74kW; 
Option 3: Set a harmonised limit of 74kW; 
Option 4: Use alternative limitation criteria. 

Table 26: Click on ‘Annex’ to display the detailed comparison of policy options 1, 2 and 3  

Summary: 
The anticipated societal impact of all the options is neutral. Option 2 is expected to have a positive economic 
impact. Both options 3 and 4 are likely to have a negative economic impact, but option 4 has the potential for 
a  larger  positive  environmental  impact.  However,  the  magnitude  of  the  environmental  impacts  is  currently 
uncertain. Owing to the lower cost for manufacturers and the availability of more effective safety measures, 
such as the introduction of anti-lock brake systems, option 2 is the preferred option. 

6.4. 
6.4.1. 

Improved categorisation of L-category vehicles 
Recategorise  electrically  assisted  cycles  (currently  outside  the  scope  of  the  legal  framework), 
tricycles (L5e) and quadricycles (categories L6e and L7e) 

Annex XVII, Ch. 1  Option 1: No policy change; 

Option 2: Exclude quadricycles and electrical cycles and tricycles from the Regulation; 
Option 3: Return to the original spirit of the legislation for mini-cars; 
Option 4: Improve the legislation by adding new requirements for mini cars based on car requirements; 
Option 5: Refine vehicle categories by introducing new subcategories in L1e, L5e, L6e and L7e. Add new / 

revised requirements for these subcategories. 

Table 27: Click on ‘Annex’ to display the detailed comparison of policy options 1 to 5  

Summary: 
Options 1 to 3 do not address the root problems. Option 4 can resolve these concerns for mini-cars, but still 
leaves  a  confusing  set  of  rules  for  the  L1e,  L5e  and  L7e  subcategories.  The  best  solution  for  effective 
environmental protection and safety is correct classification, as proposed in option 5. Its disadvantage may 
be  higher  compliance  costs  for  industry  initially,  but  this  would  depend  on  how  carefully  the  current 
classification  is  overhauled.  New  measures  may  emerge  once  appropriate  subcategories  are  defined,  e.g. 
there are currently no specific measures for the electrical safety of electric vehicles. UNECE regulation No. 
100 on the safety of electrical vehicles could apply to such vehicles in future, but should not cover traditional 
vehicles  equipped  solely  with  internal  combustion  engines.  The  preferred  solution  after  weighing  the  pros 
and cons is therefore option 5. 

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6.4.2. 

Specific requirements for category L7e vehicles 

Annex XVII, Ch. 2  Option 1: No policy change; 

Option 2: Exclude off-road quads (ATVs) from the Regulation and add new requirements on safety and 

emissions for on-road quadricycles (on-road quads and mini-cars); 

Option 3: Keep the existing L7e category and add new requirements on safety for all quadricycles; 
Option 4: Create new subcategories within L7e with specific requirements for off-and on-road quadricycles. 

Table 28: Click on ‘Annex’ to display the detailed analysis of policy options 1 to 4  

Summary: 
In  analysing  the  pros  and  cons  of  the  four  different  policy  options,  the  advantage  of  flexibility  to  develop 
specific  requirements  addressing  the  specific  concerns  of  different  vehicle  types  became  obvious.  Initially, 
therefore, this led to a high preference for option 4, with a subcategory L7Be for ATVs, a subcategory L7Ce 
for mini-cars and a subcategory L7Ae for all other quadricycles classified as ‘on-road’ quads. The initial plan 
was also not to register off-road quads (ATVs) or equip these vehicles with a special registration plate and 
put a note in its vehicle papers that this vehicle type may only travel a short distance on public, hard-surfaced 
roads. This would have helped the enforcement authorities, as such vehicles could then be easily identified 
as not permitted in cities and far away from off-road areas. 

On  the  other  hand,  not  registering  ATVs  would  have  lead  to  identification  concerns  for  enforcement 
authorities  if  a  vehicle  could  not  be  stopped.  Special  registration  plate  requirements  are  solely  individual 
Member State business and can therefore not be proposed by the Commission as EU wide legislation.  

Unfortunately option 4 had to be discarded owing to the fact that off-road vehicles do not legally fall under 
the scope of the type-approval legislation for L-category vehicles. This legislation is only supposed to cover 
the  type-approval  of  vehicles  used  on  public  roads.  In  addition,  it  was  not  possible  to  identify  a  sufficient 
number of critical vehicle characteristics able to distinguish sufficiently well between an off-road quad (ATV) 
and an on-road quad, as between e.g. a passenger car and a class G (off-road) vehicle. The design criteria 
initially  selected  could  too  easily  be  circumvented  by  retrofitting  a  cheap  kit  to  adapt  the  original  type-
approved  off-road  vehicle  to  make  it  fit  to  drive  on  public  roads.  This  would  not  have  meant  that  such  a 
retrofitted  vehicle  would  then  also  comply  with  the  specific  safety  and  environmental  measures  specially 
designed for subcategory L7A. So, from a practical point of view as well, this concept had to be abandoned. 

With  options  1  and  3,  either  the  problems  identified  are  not  addressed  or  the  manufacturer  of  one  vehicle 
type must comply with requirements developed to address concerns with the other vehicle types. Given this 
complex  set  of  advantages  and  disadvantages,  option  2  was  chosen  as  the  only  feasible  option. 
Furthermore,  it  still  provides  the  best  way  to  address  the  environmental  and  safety  concerns  of  on-road 
quads  and  mini-cars  in  particular.  ATVs  will  consequently  no  longer  come  under  the  L-category  vehicle 
legislation and will be covered by the Machinery Directive 2006/42/EC with regard to safety aspects. ATVs 
will also need to comply with the Non-Road Mobile Machinery Directive 97/68/EC as amended by Directive 
2002/88/EC as regards environmental requirements. The coherence of option 2 was considered to be better 
than  for  options  1,  3  and  4,  as  e.g.  off-road  motorcycles  are  also  not  covered  by  the  L-category  vehicle 
legislation  and  are  therefore  also  classified  as  machines.  Circumventing  the  stricter  on-road  quad 
requirements  for  retrofitted  ATVs  cannot  unfortunately  be  completely  prevented  with  option  2  at  European 
level, so additional national rules will be needed to prevent this. 

6.4.3. 

Specific requirements for gaseous alternative fuels and other non-traditional propulsions 

Annex XVII, Ch. 3  Option 1: No policy change; 

Option 2: Legislation at EU level through a more refined vehicle categorisation with specific measures for the 

Table 29: Click on ‘Annex’ to display the detailed comparison of policy options 1 and 2  

different vehicles and propulsion technologies. 

Summary: 
Gaseous fuels are in general perceived to be dangerous by consumers. To use these types of fuels on small 
vehicles such as PTWs, with very limited space available to e.g. incorporate a fuel tank, may sound exotic, 
but  a  small  number  of  such  vehicles  are  already  nationally  approved,  so  it  is  physically  possible.  It  may 
become  more  attractive  to  manufacturers  to  develop  and  market  these  vehicles  on  a  larger  scale  if  such 
vehicles  can  be  type-approved  and  sold  on  the  whole  EU  market.  By  complying  with  appropriate,  uniform 
international  safety  requirements,  these  vehicles  will  be  as  safe  as  or  safer  than  vehicles  propelled  with 
conventional  fuels.  This  will  hopefully  contribute  to  an  improved  safety  perception  among  consumers,  and 
demand for these vehicles may grow, especially because e.g. LPG, CNG or electricity are rather cheap in 
comparison to conventional fuels. 

Providing the possibility to type-approve a vehicle propelled by alternative gaseous fuels or any other shape 
of form of alternative propulsions may make it attractive for consumers in the Member States to drive such 
vehicles and may encourage manufacturers to spend more on environmental technology development, thus 

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increasing  the  pace  of  innovation  in  environmental  technology.  In  particular,  SMEs  would  benefit  from  this 
increased focus on niche market technologies. These are the reasons why option 2 is the preferred option. 
Despite this preference for including gaseous fuels within the new Regulation, hydrogen would for the time 
being  remain  excluded.  There  are  many  developments  in  hydrogen  technology  for  light-duty  vehicles 
(passenger cars), and EU legislation is being developed for four-wheel vehicles. In order to learn and benefit 
from  this  legislative  development,  more  time  is  needed  before  drafting  generic  legal  requirements  for  L-
category vehicles propelled with hydrogen. Rather technological developments of this type of propulsion and 
associated  requests  to  type-approve  vehicles  propelled  with  hydrogen  will  be  handled  on  a  case-by-case 
basis. 

6.5. 

Overview of preferred options, detailed analysis and comparison with other options 

Objective 

Preferred policy option(s) 

Simplification 
of  existing  EU 
legislation 

Environmental 
measures: 
new or 
revised 
measures for 
the type-
approval of 
new vehicles 

Environmental 
measures: 
New 
measures to 
control 
vehicle 
emissions 
over vehicle 
life. 

Safety 
measures 

Option (2) Repeal current directives and replace with a 
minimum number of regulations  

Revised lower emissions limits: 
Option (3) motorcycle industry (ACEM) proposal for the 
short to mid-term and Option (5) Equivalent Euro 5 
passenger car limits for the long term 
Emission laboratory test cycle:  
Option (2) Use of a revised World-wide Motorcycle 
emissions Testing Cycle (WMTC) for all L-category vehicles  
Type-approval requirement for CO2 measurement and 
fuel consumption determination and reporting: 
Option 2: Actual introduction of type-approval requirements 
for CO2 measurement and fuel consumption determination 
and reporting. 
Evaporative emissions test and limit:  
Option (3) Evaporative emissions test and limit ensuring 
evaporative emission control for L-category vehicles. 
Durability requirements:  
Option (2) Deterioration reduced to 10 % over useful life and 
linear extrapolation for higher mileages 
In-use conformity (IUC) testing and limits:  
Option (1) No change 
On-board diagnostic (OBD) systems and access to 
repair information:  
Option (3) Use of best available technology (BAT): minor 
malfunction monitoring (e.g. circuit integrity check) (OBD 
stage 1) for all L-category vehicles, no catalyst efficiency of 
misfire monitoring. Provision of access to repair and 
maintenance information, as for passenger cars. 
Obligatory fitting of advanced brake systems:  
Option (3) Anti-lock brake systems on PTWs with cylinder 
capacity >125 cm3 and advanced brake systems (combined 
brake systems and/or anti-lock brake systems) on 
motorcycles with 50 cm3 < cylinder capacity ≤ 125 cm3; (NB 
125 cm3 relates to the performance criteria of PTWs that can 
be driven with an A1 driving licence) 
OR 
Option (4) Obligatory fitting of advanced brake systems 
(combined brake systems and/or anti-lock braking systems) 
on motorcycles that conform to the performance criteria for 
the A2 driving licence. Obligatory fitting of anti-lock brake 
systems on all other L3e motorcycles; 
Anti-tampering measures:  
Option (3) New measures on anti-tampering. 
74kW power limitation for motorcycles:  
Option (2) Repeal the option given to Member States to limit 
power to 74kW; 

Link to detailed 
analysis of preferred 
policy option 

Link to detailed 
comparison of 
policy options 

Annex X 

Annex XIV 

Annex XI Ch. 1.2 Opt. 3 
AND 
Annex XI Ch. 1.2 Opt. 5 

Annex XV, Ch. 1.1 

Annex XI, Ch. 1.4 

Annex XV, Ch. 1.2 

Annex XI, Ch. 1.5 

Annex XV, Ch. 1.3 

Annex XI, Ch. 1.6 

Annex XV, Ch. 1.4 

Annex XI, Ch. 1.7 

Annex XV, Ch. 1.5 

Annex XI, Ch. 2.1 

Annex XV, Ch. 2.1 

Annex XI, Ch. 2.2 Opt. 3  Annex XV, Ch. 2.2 

Annex XII Ch. 1.3 
OR 
Annex XII Ch. 1.4 

Annex XVI Ch. 1.3 
OR 
Annex XVI Ch. 1.4 

Annex XII, Ch. 2.2 Opt.3 

Annex XVI, Ch. 2 

Annex XII, Ch. 3 

Annex XVI, Ch. 3 

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Improved 
categorisation 
of L-category 
vehicles 

Recategorise vehicle types such as electric cycles, 
motorcycles (L3e), tricycles (L5e) and quadricycles 
(categories L6e and L7e):  
Option (5) Refine vehicle categories by introducing new sub-
categories in L1e, L3e, L5e, L6e, and L7e. Add new/revised 
requirements for these sub-categories. 

Specific requirements for category L7e vehicles:  
Option (2) Exclude off-road quads (ATVs) from the 
Regulation and add new requirements on safety and 
emissions for on-road quadricycles (on-road quads and mini-
cars); 
Specific requirements for gaseous alternative fuels and 
other non-traditional propulsions:  
Option (2) Legislation at EU level through a more refined 
vehicle categorisation with specific measures for the different 
vehicles and propulsion technologies. 

Annex XIII, Ch. 1 

Annex XVII, Ch. 1 

Annex XIII, Ch. 2 

Annex XVII, Ch. 2 

Annex XIII, Ch. 3 

Annex XVII, Ch. 3 

Table 30: Summary table of preferred policy options with links to the detailed analysis, including all available quantitative and 
qualitative elements, and the detailed comparison with other policy options in terms of effectiveness, efficiency and 
coherence 

7. 

MONITORING AND EVALUATION 

Simplification 

7.1. 
See Annex XVIII for the complete list of recommended monitoring and evaluation parameters. These mainly 
concern the number of amendments and the required time and cost of implementing these changes. 

7.2. 

Environmental measures 

7.2.1. 

New or revised environmental measures for the type-approval of new vehicles 

7.2.1.1.  Revised lower emissions limits 
Four  years  after  first  application,  the  new  legal  framework  should  be  reviewed  to  determine  whether  the 
assumptions and modelled emissions conform to reality at that point in time. An increase in the number of 
mass-produced  hybrid  and  electrical  vehicles  may  have  a  positive  impact  on  local  pollutant  reduction.  In 
2016  –  2017  timeframe,  the  Commission  should  assess  whether  the  additional  promotion  of  electrified 
vehicles would effectively address the disproportionately high emissions from L-category vehicles equipped 
with  combustion  engines.  In  addition,  it  should  assess  the need  to  include  off-cycle  emission  provisions  in 
2020  for  vehicles  equipped  with  traditional  propulsion  technology.  The  long-term  preferred  option  5  will 
initially  be  between  braces,  and  further  monitoring  and  evaluation  by  both  the  Member  States  and  the 
Commission will be required in the period up to 2016, during which option 3 will be in force. 

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7.2.1.2.  Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category vehicle 

categories 

No  specific  monitoring  and  evaluation  are  deemed  necessary,  other  than  a  comparison  of  actual  pollutant 
emissions  vs.  predicted  average  emissions  based  on  test  cycle  measurements.  The  same  applies  to  real-
world fuel consumption and the value determined in the test cycle. For mopeds, a WMTC-based test cycle 
does not yet exist. A study will be started in 2011 and an initiative will be launched by the Commission within 
UNECE in the informal group for WMTC development in order to extend the scope of the WMTC to mopeds, 
so that the type-approval emission test better reflects real-world driving conditions. 

Figure 8: WMTC-based moped test cycle proposal (bottom) to replace the conventional R47 moped test cycle (top) 

7.2.1.3.  Type-approval  requirements  for  CO2  measurement  and  fuel  consumption  determination  and 

reporting 

For this policy option as well, real-world fuel consumption and CO2 emissions should be monitored by both 
the Member States and the Commission and should be compared to the modelled results, which are based 
on the measurements obtained in the test cycle. For example, three years after the introduction of a future 
energy efficiency labelling system consumers should be asked if this additional, standardised information has 
substantially influenced their purchasing decisions towards more fuel-efficient vehicles. 

7.2.1.4.  Evaporative emissions test and limit 
Actual and modelled HC emissions must be compared by the Member States and the Commission, e.g. in 
2016  –  2017  timeframe,  in  order  to  judge  if  cost-effectiveness  is  as  good  as  anticipated.  Manufacturers 
should be asked to present the actual costs compared with the anticipated costs as presented in the various 
Motor Cycle Working Group meetings. 

7.2.1.5.  Durability testing of anti-pollution devices and aged vehicles 
The  Member  States  and  the  Commission  should  run  a  stand-alone  durability  test  programme  and  have  a 
statistically relevant sample of aged vehicles from the field, with a known maintenance history, by 2016. The 
actual  test  results  of  these  vehicles  should  be  compared  with  aged  emission  results  from  type-approval 
demonstration testing. This will indicate if the accelerated-ageing methods used to demonstrate aged vehicle 
emissions are effective and if there is a need to increase the durability mileage requirement as suggested by 
option 3. 

7.2.2. 

New measures to control vehicle emissions over vehicle life 

7.2.2.1. 

In-use conformity (IUC) testing and limits 

In  the  2016  –  2017  timeframe,  this  policy  option  should  be  reassessed  by  Member  States  and  the 
Commission in the environmental assessment study to see if it should remain discarded or if the conditions 
or assumptions have changed to allow it to be reconsidered. Experience gained with e.g. passenger-car IUC 
may provide a better evidence base than available today. 

7.2.2.2.  On-board diagnostic (OBD) systems and access to repair information 
In the 2016 – 2017 timeframe an environmental impact study should be conducted by the Commission with 
input from the Member States to assess the success of this option. The environmental advantages should be 
more  accurately  quantified  and  independent  repairers  should  be  asked  if  their  current  competitive 
disadvantage has changed for the better. 

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Safety measures 

7.3. 
7.3.1.  Obligatory fitting of advanced brake systems 
See Annex XIX, Ch. 1, for the complete list of recommended monitoring and evaluation parameters. These 
mainly  relate  to  the  number  of  powered  two  wheel  rider  casualties,  non-fatal  casualty  data  and  the 
equipment fitted. Crucial data such as Anti-lock brake system or combined brake system costs and the effect 
of  the  large-scale  fitment  of  systems  on  market  price  were  lacking  and  should  continue  to  be  sought  after 
one of the recommended policy options has been adopted. These should be used as input for a study to be 
conducted by the Commission four years after first application of the new Regulation (2017). 

Anti-tampering measures  

7.3.2. 
See  Annex  XIX,  Ch.  2,  for  the  complete  list  of  recommended  monitoring  and  evaluation  parameters. 
Recommendation from TUEV Nord report: spot checks on two- and three-wheeled vehicles registered before 
and  after  17  June  1999,  reported  in  2003;  EU-wide  accident  research  including  the  state  of  the  vehicles 
involved;  where  carried  out,  inclusion  of  unauthorised  manipulations  in  periodical  technical  inspections; 
observing the market in electronic tuning devices; and practical research into the effect of electronic tuning 
on  emissions,  noise  and  maximum  speed.  There  has  since  been  significant  technical  progress  with  new 
power-train developments (electrical vehicles, hybrids), which could not be covered in the study at that time. 
The Commission should therefore have the study updated in 2011 to include the latest technology. 

74kW power limitation for motorcycles 

7.3.3. 
See Annex XIX, Ch. 3, for the complete list of recommended monitoring and evaluation parameters. Baseline 
data  need  to  be  determined,  including:  sales  data  with  respect  to  engine  power/acceleration  potential  or 
whatever  limitation  measure  is  used;  accident  rates  with  respect  to  engine  power/acceleration  potential  or 
whatever  limitation  measure  is  used;  and  emissions/noise  data  with  respect  to  engine  power/acceleration 
potential  or  whatever  limitation  measure  is  used.  These  data  must  be  monitored  by  the  Member  States  in 
relation to any other changes that could influence accident numbers, emissions or noise, for example anti-
tampering measures, etc. 

7.4. 
7.4.1. 

Improved categorisation of L-category vehicles 
Electrical  cycles  (currently  outside  the  scope  of  the  Framework  Directive),  tricycles  and 
quadricycles 

See  Annex  XX,  Ch.  1,  for  the  complete  list  of  recommended  monitoring  and  evaluation  parameters. 
Significant  uncertainties  remain  regarding  key  costs  in  the  approvals  process  and  in  the  casualty  and 
environmental impacts of the proposed options. These should be monitored by the Member States and used 
as  input  for  an  evaluation  conducted  by  the  Commission  in  2016.  Further  data  obtained  to  refine  the 
assessments of potential impacts should be collected by the Member States. More detailed accident data are 
required  to  provide  information  on  the  safety  of  tricycles  and  quadricycles  and  to  allow  the  impact  of  any 
measures to be assessed. A more specific categorisation of tricycles and quadricycles would allow the safety 
impact of future measures to be monitored. 

Specific requirements for category L7e vehicles 

7.4.2. 
See Annex XX, Ch. 2, for the complete list of recommended monitoring and evaluation parameters. Data on 
the  costs  of  the  proposed  options  could  be  gathered  for  evaluation  purposes  by  monitoring  type-approval 
costs prior to 2012 (the earliest proposed implementation of any change) and further investigating the costs 
of national approval, to be carried out by the Member States and the Commission. This would allow the costs 
of  approval  processes  to  be  more  accurately  quantified  for  all  proposed  options.  For  all  options,  it  is 
important that a means of collecting European accident data for quadricycles is implemented and that these 
accident data are disaggregated for different tricycle and quadricycle types and accident locations (on-road 
and off-road). This would enable a clearer assessment of the societal benefits of future safety improvement 
measures. 

Specific requirements for gaseous alternative fuels and other non-traditional propulsions 
7.4.3. 
See Annex XX, Ch. 3, for the complete list of recommended monitoring and evaluation parameters. It has not 
been possible in this report or in the TRL report to conduct a cost-benefit analysis of the options for gaseous 
fuel-powered or other alternative propulsion equipped category L vehicles due to insufficient information on: 
the shares of current environmental impacts from road transport that are due to each category of vehicle; the 
rate  at  which  gaseous  fuel-powered  and  other  non-traditional  propulsions  for  category  L  vehicles  will  be 
introduced  in  the  EU27;  the  costs  of  these  non-traditional  propulsion  category  L  vehicles  (design,  fitment, 
etc.);  the  costs  of  type-approval;  and  a  full  energy  cycle  assessment.  More  statistical  data  should  be 
collected  by  the  Member  States  and  used  as  input  for  a  study  by  the  Commission  in  the  2016  –  2017 
timeframe. 

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ANNEX I: L-CATEGORY VEHICLE DEFINITIONS 

Definitions of L-category vehicles according to Framework Directive 2002/24/EC, chapter 1, article 1.2: 

Category 

Vehicle Name 

Vehicle characteristics 

L1e 

Moped 

L2e 

Three-wheel 
Moped 

L3e 

Motorcycles 

L4e 

Motorcycle & 
Sidecar 

L5e 

Tricycles 

L6e 

Light Quadricycles 

Two wheels and maximum designed vehicle speed of not more 
than 45 km/h and characterised by: 
•  cylinder capacity does not exceed 50 cm3 in the case of the 

internal combustion type, or 

•  maximum continuous rated power is no more than 4 kW in 

the case of an electric motor; 

Three  wheels  and  maximum  designed  vehicle  speed  of  not 
more than 45 km/h and characterised by: 
•  cylinder  capacity  does  not  exceed  50  cm3  if  of  the  spark 

(positive) ignition type, or 

•  maximum  net  power  output  does  not  exceed  4  kW  in  the 

case of other internal combustion engines, or 

•  maximum continuous rated power does not exceed 4 kW in 

the case of an electric motor; 

Two-wheels,  without  a  sidecar  fitted  with  an  engine  having  a 
cylinder  capacity  of  more  than  50  cm3  of 
internal 
combustion  type  and/or  having  a  maximum  designed  vehicle 
speed of more than 45 km/h, 

the 

Two-wheels,  with  a  sidecar  fitted  with  an  engine  having  a 
cylinder  capacity  of  more  than  50  cm3  if  of  the  internal 
combustion  type  and/or  having  a  maximum  designed  vehicle 
speed of more than 45 km/h, 

Three symmetrically arranged wheels fitted with an engine 
having a cylinder capacity of more than 50 cm3 if of the 
internal combustion type and/or a maximum design speed 
of more than 45 km/h. 
Four  wheels,  unladen  mass  is  not  more  than  350  kg  not 
including  the  mass  of  the  batteries  in  case  of  electric  vehicles, 
whose  maximum  design  vehicle  speed  is  not  more  than  45 
km/h, and 
•  whose engine cylinder capacity does not exceed 50 cm3 for 

spark (positive) ignition engines, or 

•  whose maximum net power output does not exceed 4 kW in 

the case of other internal combustion engines, or 

•  whose maximum continuous rated power does not exceed 4 

kW in the case of an electric motor. 

L7e 

Heavy 
Quadricycles 

the 

fulfil 

technical  requirements 
These  vehicles  shall 
applicable  to  three-wheel  mopeds  of  category  L2e  unless 
specified differently in any of the separate directives; 
Four wheels, other than those referred to in ca 
theory L6e whose 
unladen  mass  is  not  more  than  400  kg  (550  kg  for  vehicles 
intended  for  carrying  goods),  not  including  the  mass  of 
batteries  in  the  case  of  electric  vehicles,  and  whose  maximum 
net  engine  power  does  not  exceed  15  kW.  These  vehicles 
shall  be  considered  to  be  motor  tricycles  and  shall  fulfil  the 
technical requirements applicable to motor tricycles of category 
L5e  unless  specified  differently 
the  separate 
Directives. 

in  any  of 

Table 31: overview table with design criteria for L-category vehicles, according to Framework Directive 2002/24/EC, Chapter 1, 
Article 1.2 

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Figure 9: examples of vehicles in the scope of the current Framework Directive 2002/24/EC 

Please note that no differentiation is currently made in the classes L6e and L7e between Quads for public 
road  use,  all  terrain  vehicles  (ATVs)  and  mini  cars.  As  long  as  the  minimum  design  criteria  of  Framework 
Directive 2002/24/EC, Chapter 1, Article 1.2 are fulfilled all three types of vehicles may be associated to L-
vehicle, class L6e, respectively L7e. 

Figure 10: examples of vehicles not in the scope of the current Framework Directive 2002/24/EC 

Besides  the  classification  as  defined  in  Framework  Directive  2002/24/EC,  Chapter  1,  Article  1.2  there  are 
also  other  classifications  used  to  refer  to  sub-categories  of  L-category  vehicles.  Examples  of  other 
categorisation within the L-category vehicle families: 

– 

– 

– 

– 

Mopeds,  besides  the  traditional  widely  known  one-track  vehicles  there  are  also  e.g.  electrical 
cycles with a power higher than 250 W (0.25 kW), which are considered to be a Moped and must 
therefore be type approved as such a vehicle. 

Powered Two Wheelers (abbreviated PTWs): this is a summary expression for one-track (2-wheel) 
vehicles combining L-category vehicles L1e and L3e. 

Trikes  or  Motor  Tricycles,  this  is  a  wide  variety  of  different  two-track  vehicle  types,  some  with  2 
wheels in the front and one in the rear, others with a configuration of 2 wheels at the rear and one 
in the front. The greater shares of these vehicles are equipped with gasoline engines, but there are 
also a number of vehicles, which are equipped with a Diesel engine.  

Quadricycles: two-track 4-wheel vehicles like quads used on public roads, all terrain vehicles used 
mainly off-road and mini cars. Quads used on public roads are predominantly powered by gasoline 
engines, mini cars are in general equipped with small industrial diesel engines. 

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ANNEX II: PUBLIC  CONSULTATION  ON  OUTLINE  PROPOSALS  FOR  A REGULATION  OF  THE EUROPEAN PARLIAMENT 

AND OF THE COUNCIL FOR L-CATEGORY VEHICLES — SUMMARY OF RESPONSES 

1. 

CONTEXT 

The  Commission  launched  an  open  public  consultation  seeking  to  gather  views  of  interested  parties  on  its 
outline proposals for new legislation for L-category vehicles. A consultation document has been published45 
to  provide  background  and  ask  for  opinions  on  this  new  framework,  which  should  replace  the  Framework 
Directive and 13 separate directives and their many amending directives. These outline proposals are thus 
embedded  in  the  EU  strategy  to  improve  the  regulatory  environment  towards  simplification,  safety  and 
environmental aspects. 

The public consultation was targeted at those groups that would be most affected by the proposals, including 
type-approval  authorities  in  Member  States,  manufacturers,  suppliers  and  consumers;  published  on  a 
specific website created for the purposes of the consultation; and published in English, French and German.  

The Commission has acknowledged the receipt of all stakeholder responses to the consultation, and these 
have been made publically available. 46 . The results of the public consultation were published in a report.47 

The written consultation was discussed on 29 June 2009 in a meeting of the Commission’s Working Group 
on  Motorcycles48  (MCWG)  to  which  all  relevant  stakeholders  were  invited.  The  preliminary  impact 
assessment study results will be presented in the MCWG planned to take place on 26 November 2009. The 
public consultation met with the Commission’s minimum standards for consultation. 

2. 

OVERVIEW OF RESPONDENTS AND ANALYSIS METHOD 

In total fifty-seven respondents completed the survey and sent back their replies to the functional mailbox of 
the Commission services. Forty-one respondents replied on behalf of an association, a company or a public 
authority, while sixteen replies were received from individual citizens.  

The  unfiltered  responses  from  all  respondents  can  be  accessed  directly  on  the  Commission’s  website.  In 
order  to  obtain  a  balanced,  the  responses  from  associations,  companies  and  public  authorities  were 
combined.  

Although 16 individual citizens participated to the public consultation, in many cases the questions were left 
uncommented.  The  citizen  replies  that  were  applicable  and  which  could  be  associated  with  the  various 
questions have been summarised in a separate chapter. Individuals’ e-mail and postal addresses have been 
removed in line with the pre-questionnaire privacy statement. 

The next step was to classify the replies in an overview table per question. The final results were interpreted 
and summarised in the summary report. 

3. 

SUMMARY OF RESPONSES 

L-category vehicles refer to a classification of a wide range of 2-, 3- and 4 wheel vehicles like e.g. 2- & 3-
wheel  Mopeds,  2-  and  3-wheel  Motorcycles,  Tricycles,  All  Terrain  Vehicles/Quads  and  other  quadricycles 
like  mini-cars.  All  these  different  types  of  vehicles  are  currently  type  approved  under  the  scope  of  EU 
framework directive 2002/24/EC and its fourteen associated implementing directives. 

45

46

47

48

http://ec.europa.eu/enterprise/automotive/consultation/2_3_wheelers/index.htm. 
http://ec.europa.eu/enterprise/automotive/consultation/2_3_wheelers/contributions.htm. 
http://ec.europa.eu/enterprise/automotive/consultation/2_3_wheelers/results_report.pdf. 
http://ec.europa.eu/enterprise/automotive/mcwg_meetings/29_06_2009/index.htm. 

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A number of potential policy options were developed in order to meet the overall objectives. Subsequently a 
public consultation paper was published on the Internet at the end of 2008. This questionnaire, including a 
brief explanation on every potential policy option and 20 associated open questions, was published on the 
Commission’s  website  with  a  request  to  reply  from  Associations,  Public  Authorities  and  individual  citizens. 
The  replies  to  this  consultation  paper  were  collected,  classified,  analyzed  and  again  published  on  the 
Commission’s  website.  In  total  fifty-seven  replies  were  received,  as  summarised  in  attachments  #2  to  this 
report. 

Questions 1, 2 and 3 were related to simplification. The majority of the respondents were in favour, but some 
respondents doubted whether this proposal was actually going to deliver the promised simplification or not. 
More  transparency,  better  harmonisation,  and  reduction  of  unnecessary  administrative  costs  were 
anticipated  by  some  respondents  as  justification  to  simplify  the  current  legal  requirements.  Also  using 
equivalent international UNECE regulations to replace current EU directive requirements was perceived as 
positive by the majority of the respondents. A small number of critical voices feared that increasing the use of 
references to UNECE regulations would create a costly bureaucratic burden and generate a democratic gap 
from transferring future regulatory work from the EU process to this United Nations body. 

Questions 4 and 5 were dedicated to questions regarding emission measures. About half of the total number 
of  survey  respondents  representing  associations,  companies  and  public  authorities  (a  total  of  forty-one), 
were  supportive  on  the  introduction  of  new  emission  limits  equivalent  to  Euro  5  limits  for  petrol  cars.  An 
additional  fifteen  percent  from  the  total  number  of  this  group  of  respondents  were  conditionally  in  favour, 
summarised as ‘Relatively Favourable’. The conditions were mainly comprised of a sufficiently long lead time 
or a multi step approach for Industry to develop technology. Four respondents of this group of forty-one and 
the majority of the sixteen individual citizens were absolutely against the proposal fearing that more severe 
emission  requirements  would  lead  to  a  significant  higher  customer  price.  The  majority  of  the  respondents 
were  also  in  favour  of  additional  related  emission  measures  like  e.g.  durability  requirements,  evaporative 
emission limits and CO2 and fuel consumption measurements. 

Questions 6 to 17 were related to safety measures. Question number 6 requested for the survey participant’s 
view on mandatory fitting of Anti-lock Brake Systems (ABS) on Powered Two Wheelers (PTW) and potential 
alternative solutions. Explicitly being in favour or against mandatory fitting of ABS were approximately 30 % 
each of the forty one respondents from the mix of associations, companies and public authorities. However, 
an additional seventeen percent of this group of respondents were conditionally in favour of mandatory fitting 
of ABS, referred to as ‘Relatively Favourable’. Examples of these conditions were: mandatory fitting of ABS 
only for bigger PTWs, optional / voluntary fitting for small versions or other conditions like ‘a robust Impact 
Assessment analysis should first demonstrate a positive cost-benefit ratio’. Question number 7 required the 
respondents view on other or supplementary solutions better suited for certain categories (i.e. coupled brake 
systems, stability control systems, etc.) that would produce the same/better effect than ABS at better (lower) 
cost. The top two of suggestions by the respondents: ‘alternative advanced brake systems’ (20 %) and ‘no 
alternative solution but ABS’ (10 %). 

Questions 8 and 9 requested feedback on potential anti-tampering measures and asked for suggestions for 
alternative measures with respect to tampering prevention. A wide majority of survey participants (29 %) that 
responded  (52 %  of  the  41  respondents)  is  opposed  to  additional  anti-tampering  measures.  Frequently 
expressed opinion among the survey participants, including the ones from the individual citizens, is that there 
is a need for anti-tampering measures with respect to Mopeds (L1e, L2e), but that additional anti-tampering 
measures for motorcycles (L3e, L4e, L5e) would be ‘adverse to users’ rights to make modifications to their 
motorcycles, providing these do not compromise their safety and impact on the environment.’. The top two 
responses to question number 9 if other solutions would be preferable: a shared first place for ‘No additional 
solutions’ and ‘Periodical technical Inspections’ (both 7 % from the 41 survey participants from associations, 
companies and public authorities) and on number two ‘Measures covering the electronic devices controlling 
the  vehicle’s  maximum  speed,  the  inter-changeability  of  components,  the  CVT  components,  the  exhaust 
silencing system and marking (5 % of total). 

A  high  response  rate  (66 %  of  total)  was  noted  on  questions  10  and  11  regarding  power  limitation  and  its 
alternatives.  The  absolute  majority  (51 %  of  total  41  respondents  from  associations,  companies  and  public 
authorities) were absolutely against power limitation, supported by nearly all individual citizens, owing to the 
opinion that a correlation between vehicle power and accident frequency was not scientifically proven. The 
top  two  of  alternatives  suggested  by  the  respondents;  a  shared  first  place  through  education/training  and 

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power/mass ratio limitation (with each 12 % of total), the second place for regular safety inspections with 5 % 
of total. 

Questions 12 and 13 were related to mini-cars (categories L6e and L7e). 32 % of the respondents were of 
the opinion that that EU legislation on these vehicles is justified, 7 % was relatively favourable and 12 % was 
not agreeing to this statement. The adversaries of this statement predominantly thought that these types of 
vehicles  should  be  regulated  under  national  legislation  of  the  Member  States.  Regarding  the  question 
whether  these  vehicles  should  have  designated  safety  requirements  or  comply  with  the  same  safety 
standards as passenger cars only 12 % of the respondents were in favour for passenger car safety measures 
compliance.  The  majority  would  like  to  see  measures  that  are  specifically  designated  to  these  types  of 
vehicles. 

Questions  14  to  16  were  related  to  quads.  The  majority  of  respondents  is  favourable  (39 %  if  the  share 
‘relatively favourable’ is included) to the question if these vehicles should be in the scope of type approval 
whereas they are not designed to be used on the road. Not a single respondent agreed with the statement 
that  at  present  the  category  in  which  these  vehicles  are  type  approved  is  adapted  to  the  design  of  such 
vehicles. The majority of the respondents would like to see new specific requirements be added to improve 
the safety of such vehicles. 

The last question related to L-category vehicle safety, number 17, was related to the need if in the scope of 
the  EU  legislation  hydrogen  vehicles  should  be  included.  There  was  a  slight  majority  in  favour  of  EU 
legislative requirements regarding L-category vehicles fuelled with Hydrogen. Most of the stakeholders that 
are  against  this  policy  option  argue  that  the  technology  is  still  in  its  early  stage  of  development  and  that 
legislation may hinder innovation. The Motorcycle Industry and individual citizens were of the opinion that EU 
legislation on hydrogen Powered Two Wheelers is not needed for the very next future. Prototypes could be 
individually  type-approved  at  national  level  or  to  be  subject  to  an  exemption  of  the  current  framework 
directive.  

Questions  18  to  20  were  related  to  the  overall  impact  of  new  L-category  vehicle  legislation  on  the 
competitiveness  of  the  EU  industry.  Only  one  third  of  the  survey  participants  decided  to  reply  to  these 
questions. Question 18 requested for the view of the participants on the impact of measures related to the 
competitiveness  of  the  EU  industry,  and  in  particular  on  the  Small  and  Medium  Enterprises  (SMEs)?  The 
reply of 22 % of the respondents was positive, 10 % anticipated a negative impact on the Industry. Question 
19 asked for the view on the impact of employment within the EU, which 15 % of the respondents thought 
this will be influenced negatively. Only 7 % considered a positive effect and was optimistic for the future of 
e.g. suppliers owing to the development of new technologies and increased production of components and 
systems owing to higher demand from their customers. Finally on question 20 asking for the potential impact 
from new legislative requirements on the final customer price, the survey participants that responded were all 
of  the  same opinion,  34 %  of  total  thought  there would  be  a negative  impact of  new  measures  on  the end 
customer price. 

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ANNEX III: DESCRIPTION OF THE TASKS REQUESTED TO THE EXTERNAL CONSULTANT TRL AND METHODOLOGY 

USED — POLICY ASSESSMENT REPORT REGARDING POSSIBLE SAFETY MEASURES 

1. 

DETAILED DESCRIPTION OF THE TASK TO BE PERFORMED 

In general terms, the impact assessment shall include an identification and estimation of the likely economic, 
safety  and  social  effects  of  the  following  policy  options,  compared  to  the  ‘no  policy  change’  baseline 
scenario. The baseline for the impact assessment will be the state of play of the legislation today. 

The study will provide overview of the state of the art of safety as well as the trend in terms of market and 
technology  development.  For  the  European  market,  the  share  between  vehicles  produced  in  Europe  and 
vehicles produced outside Europe will also have to be provided. Then, for each policy option, both positive 
and negative impacts at EU level on road safety and costs for the manufacturer should be considered as well 
as the time at which they are likely to occur (short, medium or long-term). In each of the mentioned cases the 
cost of the measures to be introduced will include manufacture, assembly, testing and final type approval of 
vehicles.  In  assessing  the  costs  of  the  possible  measures,  the  contractor  should  seek  to  collect  cost  data 
from the different stakeholders (manufacturers, suppliers, etc) and take into account the reduction in costs 
when a technology is produced in high volumes following new regulatory requirements. The Contractor will 
therefore asses and highlight the uncertainties in costs and benefits. 

Overall, the time and effort put down in assessing the various impacts should be proportionate to their likely 
significance.  Therefore,  more  focus  should  be  put  on  the  assessment  of  impacts  which  are  likely  to  be 
important  (e.g.  potentially  the  economic  and  safety  ones)  than  on  those  that  are  potentially  less  important 
(e.g. potentially the social ones but understanding that in this case, measures applied to two and three-wheel 
motor vehicles may have a higher social cost on users than similar measures applied to passenger cars). 

The  contractor  shall  include  wherever  possible  the  EU  27  Member  States.  The  measures  would  be 
introduced in 2011 at the earliest. The following possible options had to be assessed: 
– 
– 
– 
– 
– 
– 
– 

ABS/coupling braking devices for motorcycles 
Anti-tampering for mopeds, motorcycles, tricycles and quadricycles 
74 kW power limit for motorcycles 
Quadricycles (L6e and L7e) 
Off-road quads  
Safety of hydrogen powered L category vehicles. 
Simplification of the legislation  

2. 

METHODOLOGY 

The contractor will provide a comprehensive analysis covering the above mentioned issues and will present 
a series of recommendations indicating the respective advantages and disadvantages of the different policy 
options, clearly outlining and taking into account:  
The  positive  and  negative  impacts  of  the  options  selected,  particularly  in  terms  of  quantified  economic, 
social, safety and environmental consequences. 
Other additional effects. Description in qualitative terms and quantified as far as possible.  
Impacts over time (time scale 10 years). 
Spread of impacts on social groups or economic sectors. 
The  reports  from  the  contractor  will  be  structured  in  accordance  with  the  Commission  document  SEC 
(2005)791  ‘Impact  Assessment  Guidelines’,  updated  in  March  2006.  The  contractor’s  methodology  will  be 
based on the Impact Assessment Guidelines and its Annexes.  
The contractor will perform the above analyses on the basis of: 
existing legislative measures in place for two- and three-wheel vehicles in other world markets; 
the published literature; 
experimental data in the hands of the contractor or available in the public domain; 
the information circulated in the Commission’s motorcycles working group; 
and any additional data the contractor will provide for the benefit of the study. 

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ANNEX  IV:  DESCRIPTION  OF  THE  TASKS  REQUESTED  TO  THE  EXTERNAL  CONSULTANT  LAT  AND  METHODOLOGY 

USED — POLICY ASSESSMENT REPORT REGARDING POSSIBLE SAFETY MEASURES 

1. 

SUBJECT OF THE SERVICE REQUEST 

The subject of the service request is an assessment study of possible measures on motorcycles emissions, 
which will be based on the study conducted by the University of Thessaloniki (LAT) in 2004. 

1.1. 

Detailed description of the tasks to be performed 

The  study  will  identify  and  evaluate  the  likely  economic,  environmental  and  social  impact  of  four  different 
policy options, taking into account the foreseen legislation for light duty vehicles (Euro 5-6) and heavy duty 
engines (Euro VI): 
No  policy  change:  This  policy  option  corresponds  to  the  situation  where  no  additional  measures  to  those 
defined  in  the  Directives  2002/51/EC  and  2006/72/EC  will  be  taken  for  the  control  of  the  motorcycle 
emissions. 
Initial Commission proposal: This policy option reflects the proposal prepared by the European Commission 
on the basis of the agreed measures in the MVEG-motor group as well as the results of the LAT study, with a 
possible  amendment  of  the  equivalent  Euro  3  limit  values  for  the  WMTC  to  account  for  the  recent 
modifications  of  the  test  cycle  and  new  experimental  data  on  the  emission  performance  of  Euro  3 
motorcycles. 
Euro 5 passenger cars equivalent limits: This policy option differs from the ‘Commission proposal scenario’ 
only in the introduction of more stringent emission limits for motorcycles that would be equivalent to the Euro 
5 limits for cars. 
Best available technology: This policy option will consider the introduction of a range of measures that will 
reflect the application of what is assumed to be today the ‘best available technology’ for two and three-wheel 
motor vehicles. 
The technical measures to be considered in the formulation of the above policy options will include: 
A procedure to check the durability of emission control systems. 
A procedure to check the in-use conformity of the motorcycles. 
The technical provisions for the type-approval with respect to CO2 emissions and fuel consumption. 
The new set of pollutant emission limit values for tricycles and quadricycles discussed in the MVEG group. 
The introduction of OBD systems on two and three-wheel motor vehicles. 
The control of evaporative emissions from two and three-wheel motor vehicles. 
The introduction of the WMTC as the only test cycle for EU type-approval. 
A possible introduction of the ‘family concept’ in the type approval procedure. 
The  new  set  of  pollutant  emission  limit  values  for  mopeds  discussed  in  MVEG,  on  the  basis  of  the  policy 
options. 
The tasks that will be performed in the framework of this study are: 

Task 1. Information collection and analysis 
Task 1.1. Overview of the technical legislation on emissions from two and three wheelers and quadricycles 
used in the main markets of the world including developing countries (US, Japan, India and China).  
Task  1.2.  Overview  of  the  technology  currently  used  in  the  main  markets  and  the  latest  technological 
developments.  
Task 1.3. Revision of the equivalent Euro 3 limits for WMTC 
Task 1.4. Clarification of the policy options.  
Task  2.  Evaluation  of  the  environmental,  economic  and  social  impact  of  the  different  policy 
measures. 
Task 2.1. Estimation of the financial effects associated with the introduction of the different policy options.  
Task  2.2.  Estimation  of  the  environmental  benefits  associated  with  the  introduction  of  the  different  policy 
measures.  
Task  2.3.  Identification  and  characterisation  of  any  social  impact  associated  with  the  introduction  of  the 
different policy measures.  
Task 2.4. Cost effectiveness of the different policy measures 

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1.2. 

Methodology 

A methodological approach similar to the one followed in the LAT study will be applied, with proper revisions 
and  enhancements  where  necessary.  The  study  team  will  provide  a  comprehensive  analysis  covering  the 
above mentioned issues and will present a series of recommendations indicating the respective advantages 
and disadvantages of the different policy options, clearly outlying and taking into account: 
The  positive  and  negative  impacts  of  the  options  selected,  particularly  in  terms  of  economic,  social  and 
environmental consequences. 
Other additional effects. Description in qualitative terms and quantified as far as possible. 
Impacts over time at short medium and long-term. The evaluation time will span over 10 years. 
Spread of possible impacts on social groups other or economic sectors, with special reference to SME’s. 
Following  the  guidelines  outlined  in  the  Commission  document  SEC  (2005)791  ‘Impact  Assessment 
Guidelines’, the method to be used comprise: 
Step 1: Information collection and analysis 
Step 2: Formulation of the different policy options 
Step 3: Simulation 
Step 4: Impact assessment/cost-effectiveness 

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ANNEX V: SELF OBLIGATION EUROPEAN MOTORCYCLE INDUSTRY ASSOCIATION (ACEM) 

Advanced Braking Systems 

ACEM Commitment on Advanced Brake Systems offer deployment on Powered Two-Wheeler vehicles in the 
framework of a road safety agreement between the European Commission and ACEM 

ACEM, the Motorcycle Industry in Europe, is the professional body representing the interests and combined 
skills  of  12  manufacturers,  responsible  for  a  total  of  25  motorcycle,  scooter  and  moped  brands.  The 
members of ACEM account for 90% of the European production and powered two-wheeler market. 

Background Information 

1. 

2. 

3. 

4. 

5. 

Brake/tyre combinations on today’s powered two-wheelers have very high performance capabilities 
in a very wide variety of traffic and road conditions. In some emergency situations, when the rider 
has  to  make  decisions  in  a  split  second,  human  ‘decision  failures’  and  faulty  collision  avoidance 
manoeuvres sometimes lead to loss of control, tyre lock up, rear tyre slide out, etc. In other cases, 
the accident happens without sufficient warning for the rider to take any action. 

In  2004,  in  an  effort  to  provide  simpler-to-use  Braking  systems  to  riders  and  especially  novice 
riders  in  emergency  as  well  as  in  all  other  braking  situations,  ACEM  manufacturers  have  jointly 
committed  to  the  European  Road  Safety  Charter  to  progressively  supply  powered  two-wheelers 
with advanced braking systems, taking into account their distinctive characteristics. 

As  a  result  of  this  commitment,  35%  of  the  motorcycles  sold  by  the  ACEM  manufacturers  and 
registered in Europe in 2008 were equipped with advanced braking systems. 

Demand and market acceptance are crucial to the development of advanced braking systems on 
powered  two-wheelers,  and  largely  depend  on  the  appropriateness  of  the  solutions  offered, 
technically and in terms of cost, to the specific market segment and model. 

ACEM believes that it would be impractical and nearly impossible to try to translate into legislation 
the  rich  variety  of  systems  and  combinations  of  systems  and  their  adaptation  to  the  variety  of 
motorcycles  and  uses.  A  legislative  approach  (that,  by  definition,  would  need  to  be  simple,  clear 
and  rigid)  would  lose  the  benefits  of  this  diversity  and  would  be  detrimental  to  technology 
innovation. 

Introduction and Principles 

(1) 

This new Commitment is part of the ACEM road safety strategy that is based on the three following 
main pillars 

• 

• 

Improving the knowledge about motorcycling safety, 

Developing an integrated approach, and act on: 

 

 

 

The human factor, 

The vehicle, 

The infrastructure, 

• 

Cooperating with institutions and stakeholders. 

(2) 

This  commitment  has  the  support  of  all  ACEM  powered  two-wheeler  manufacturing  companies 
including their respective affiliated companies and commercial brands: 

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• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Bayerische Motoren Werke AG (BMW Motorrad) as well as its affiliated company Husqvarna 
Motorcyles S.r.l., 

BRP European Distribution s.a 

Ducati Motor Holding S.p.A., 

Harley-Davidson  Europe  Ltd.  as  well  as  its  affiliated  company  Buell,  MV  Agusta  and  its 
commercial brand Cagiva, 

Kawasaki Motors Europe N.V., 

KTM-Sport motorcycle AG, 

Honda Motor Europe Ltd., as well as its affiliated company Montesa, 

Peugeot Motorcycles, 

Piaggio  &  C.  S.p.A.  as  well  as  its  affiliated  company  Derbi,  and  its  commercial  brands 
Vespa, Gilera, Aprilia, Scarabeo and Moto Guzzi 

Suzuki International Europe GmbH, 

Triumph Motorcycles Ltd., 

Yamaha Motor Europe n.v. , as well as its affiliated company MBK Industries. 

These  companies  have  agreed  to  make  every  endeavour  to  contribute  to  ACEM's  road  safety  goals  to 
reducing  accidents  by  funding  research,  financing  and  participating  to  road  safety  projects  and  acting 
towards the common objective of improving the road safety of powered two-wheeler users through “shared 
responsibility” initiatives. 

(3) 

(4) 

(5) 

(6) 

(7) 

This Commitment is in line with the European Union's undertakings under the European Road Safety 
Action Programme and in particular with the European Road Safety Charter, whose principles were 
adopted  by  ACEM  and  its  members  after  ACEM  became  one  of  the  first  signatories  at  the  Dublin 
Charter event in April 2004. 

At  the  same  time  this  commitment  aims  at  preserving  the  diversity  of  the  product  offerings  of  the 
manufacturers, reflecting the diversity of motorcycle use, encouraging the development of innovative 
solutions especially in the domain of brake systems. This commitment also seeks to not negatively 
influence  competitiveness,  as  well  as  the  financial  performance  and  employment  of  the  European 
powered two-wheeler industry. 

ACEM  is  assuming  that  this  Commitment  provides  complete  and  sufficient  substitute  for  all  new 
regulatory  measures  to  mandate  any  advanced  braking  systems  on  powered  two-wheelers  of  any 
category,  as  long  as  it  is  being  honoured  and  produces  satisfactory  results  in  terms  of  market 
penetration. 

The European powered two-wheeler industry's braking commitment is very ambitious in the light of 
present  and  future  technologies,  and  the  industry  is  willing  and  prepared  to  commit  substantial 
development efforts to implement it. 

Together with the European Commission, ACEM will ensure that the Commitment is implemented in 
a manner that is in line with applicable competition rules. 

ACEM Commitment 

(8) 

This  new  ACEM  Commitment  is  based  on  the  experience  and  expected  results  from  the  ACEM 
braking commitment agreed among powered two-wheeler manufacturers under the umbrella of the 
European Road Safety Charter in 2004. 

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(9) 

(10) 

(11) 

(12) 

The motorcycle industry in Europe commits to progressively supply more motorcycles (powered two-
wheelers  above  50  cm3)  equipped  with  advanced  braking  systems  to  the  market  of  the  European 
Union.  

As  before,  this  new  commitment  will  take  account  of  the  main  purposes  of  motorcycles,  their 
distinctive  characteristics  and  specificities,  e.g.  balance,  weight,  dynamics,  and  general  capacities, 
and the cost-effectiveness of the technical solutions. 

As a result of this commitment 75% of street motorcycle models offered on the market in 2016 will be 
available with an advanced braking system as an option or as standard fitment. 

To  assess  compliance  and  results  with  this  commitment,  there  will  be  a  joint  ACEM/Commission 
monitoring of the relevant factors with regard to this commitment i.e. % of manufacturers’ offering of 
motorcycle and market penetration. The Commission could decide to follow up the commitment and 
its results through an independent auditor. 

Definitions and Scope 

(13) 

(14) 

(15) 

(16) 

An Advanced Braking System is a braking system in which either an antilock brake system and/or a 
combined brake system is present. An Antilock Brake System is a system for sensing and controlling 
the amount of relative slip velocity between the tyre and road surface during braking. A Combined 
Brake System / CBS is a type of PTW braking system in which each brake manipulator (i.e., either 
lever and/or pedal) actuates a brake on the front wheel and a brake on the rear wheel. Definitions 
and performance and construction requirements for each of these brake systems are as laid down in 
ECE 78 or GTR3. 

Both braking systems (ABS and CBS) can be combined and complemented with additional features 
e.g.  rear  lift  off  protection,  automatic  brake  force  distribution,  powered  braking  system,  braking-by-
wire system etc. Any other brake system with a function and braking performance equivalent to ABS 
or CBS, or better, is considered as Advanced Brake System. 

Any  innovative  architecture  of  motorcycles  (powered  two-wheeler  above  50  cm3)  with  a  brake 
system,  whose  function  and  braking  performance  are  equivalent  to  ABS  or  CBS,  or  better,  will  be 
consolidated in the above mentioned monitoring of Advanced Brake System deployment. 

The  commitment  covers  street  motorcycles.  The  commitment  does  not  cover  certain  categories  of 
vehicle known as enduro and trial motorcycles. Enduro and trial motorcycles are primarily designed 
for off-road use and are therefore incompatible with ABS and indeed coupling braking devices: being 
able  to  intentionally  lock  the  wheels  is  essential  in  certain  off-road  conditions.  The  industry 
commitment therefore excludes those vehicles corresponding to the following characteristics: 

Enduro Motorcycles  

– 

– 

– 

Minimum seat height: 900 mm and 

Minimum ground clearance: 310 mm and 

Minimum overall gear ratio in the highest gear (primary ratio x gear ratio x final drive ratio) of 6, 0; 

Trial Motorcycles 

– 

– 

– 

– 

Maximum seat height: 700 mm and 

Minimum ground clearance: 280 mm and 

Maximum fuel tank capacity: 4 l and 

Minimum overall gear ratio in the highest gear (primary ratio x gear ratio x final drive ratio) of 7, 5. 

EN 

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(17) 

The  Industry  commitment also excludes  vehicles  intended  for  production  in  small  series of  up  to a 
maximum  of  200  units  a  year  per  type  of  vehicle,  per  system,  per  component  or  per  separate 
technical unit. 

Accompanying Provisions 

1. 

Promotion of advanced braking system technologies 

This  commitment  is  based  on  the  assumption  of  an  unhampered  distribution  of  motorcycles  fitted  with 
advanced  braking  systems  into  the  market  via  competition  amongst  ACEM  members  and  other  market 
participants  which  is  expected  to  result  in  market  mix  changes.  Therefore  it  is  fundamental  that  any 
measures  which  might  hamper  the  distribution  process  will  be  taken  into  consideration  in  the  monitoring 
procedure. 

2. 

Acceptance of innovations 

The acceptance by the Commission, that innovative concept of vehicles/features offering better performance 
than conventional braking systems comply with the Commitment. 

Monitoring 

The Motorcycle Industry in Europe will regularly communicate a status report on the progress of advanced 
braking systems available on the market. The joint ACEM / Commission monitoring procedure should cover: 

(18) 

(19) 

(20) 

(21) 

The  development  of  the  manufacturers’  offering  of  motorcycles  available  with  advanced  braking 
systems. 

The  development  of  the  market  penetration  of  registered  motorcycles  fitted  with  advanced  braking 
systems. 

The assessment of new technologies and vehicle architectures that can be agreed to be in the spirit 
of this Commitment.  

The  percentage  offered  with  an  advanced  brake  system  shall  be  measured  by  calculating  the 
number of types offered with an Advanced Brake System variant or version versus the total number 
of types offered (type, variant and version as defined in framework directive 2002/24/EC). 

To allow manufacturers to collect all data on new model line ups, the actual calculations of the status of the 
commitment will happen at the end of a year (first time end of 2015). 

The Commission's official reports on the monitoring results may refer to individual companies' achievements. 
ACEM is willing to provide the necessary data to achieve the objectives of the monitoring. 

ACEM  and  the  Commission  will  review  the  situation  on  the  basis  of  the  monitoring  reports  and  make  any 
necessary  adjustments  in good  faith,  in  particular  also  if  the  impacts  of  this Commitment  on  the  European 
motorcycle  industry  and  market,  the  employment  situation  and  the  global  competitive  environment,  would 
appear to be detrimental. 

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ANNEX  VI:  SELF  OBLIGATION  EUROPEAN  MOTORCYCLE  INDUSTRY  ASSOCIATION  (ACEM)  ENVIRONMENTAL 

ASPECTS 

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EN 

56 

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EN 

57 

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ANNEX  VII:  SELF  OBLIGATION  EUROPEAN  MOTORCYCLE  INDUSTRY  ASSOCIATION  (ACEM)  ENVIRONMENTAL 

ASPECTS — REVISED EMISSION LIMITS 

Vehicle Type

Category

Scenario

Emission thresholds overview (mg / km)

THC 
(mg/km)

THC & 
NOx
(mg/km)

CO
(mg/km)

NOx
(mg/km)

PM
(mg/km)

Approx. Type 
Approval entry

Classification 
criteria

2W Mopeds, EU3, Prop. 
ACEM, cold weighting
2W Mopeds, EU4, Prop. 
ACEM, cold weighting

3W Mopeds, EU3, Prop. 
ACEM, cold weighting

3W Mopeds, EU4, Prop. 
ACEM, cold weighting

2W 2-Stroke Motorcycles, 
EU 4 Prop. ACEM 2012           
< 130 km/h

2W 4-Stroke Motorcycles, 
EU 4 Prop. ACEM 2012           
< 130 km/h
2W 2-Stroke Motorcycles, 
EU 4 Prop. ACEM 2012           
≥ 130 km/h
2W 4-Stroke Motorcycles, 
EU 4 Prop. ACEM 2012           
≥ 130 km/h
2W 2-Stroke Motorcycles, 
Euro 5, Prop. ACEM 2015       
< 130 km/h
2W 4-Stroke Motorcycles, 
Euro 5, Prop. ACEM 2015       
< 130 km/h
2W 2-Stroke Motorcycles, 
Euro 5, Prop. ACEM 2015       
≥ 130 km/h

2W 4-Stroke Motorcycles, 
Euro 5, Prop. ACEM 2015       
≥ 130 km/h

3W Motorcycles PI,      Euro 
3, Prop ACEM
EDC
3W Motorcycles, PI,       
Euro 4, Prop ACEM
EDC
3W Motorcycle CI,      Euro 
3, Prop ACEM
EDC
3W Motorcycles CI,      Euro 
4,Prop ACEM 
EDC

4W, Light Quadricycle, EU2

4W, Light Quadricycle, Euro 
3,Prop. ACEM

4W, Light Quadricycle, Euro 
4, Prop. ACEM

4W, Heavy Quadricycle, 
Euro 3, Prop. ACEM
4W, Heavy Quadricycle, 
Euro 3, Prop. ACEM
4W, Heavy Quadricycle, 
Euro 4, Prop. ACEM
4W, Heavy Quadricycle, 
Euro 4, Prop. ACEM

L1 

L1 

L2

L2

L3 & L4

L3 & L4

L3 & L4

L3 & L4

L3 & L4

L3 & L4

L3 & L4

L3 & L4

L5

L5

L5

L5

L6

L6

L6

L7

L7

L7

L7

3

3

3

3

3

3

3

3

3

3

3

3

3

3

3

3

0

3

3

3

3

3

3

1200

1000

800

1000

[01/01/2012]

PI & <50cc

[01/01/2015]

PI & <50cc

1200

3500

[01/01/2012]

PI & <50cc

900

1900

[01/01/2015]

PI & <50cc

Test 
Cycle
ECE R47 
& cold
ECE R47 
& cold

ECE R47 
& cold

ECE R47 
& cold

_

691

1965

_

563

-

1965

128

-

413

1965

-

248

-

1965

165

-

443

570

-

375

-

1140

68

-

253

1140

-

1140

88

4000

250

2000

250

165

1000

550

150

100

-

-

-

-

-

-

1200

3500

1200

3500

900

1900

-

-

-

-

4000

1000

2000

600

1000

150

550

100

-

-

-

250

650

250

550

-

-

-

-

-

-

-

-

-

-

-

-

-

[01/01/2012]

PI & (-25%*EU3 
WMTC)

WMTC, 
ph2

[01/01/2012]

PI & (-25%*EU3 
WMTC)

WMTC, 
ph2

[01/01/2012]

PI & (-25%*EU3 
WMTC)

WMTC, 
ph2

[01/01/2012]

PI & (-25%*EU3 
WMTC)

WMTC, 
ph2

[01/01/2015]

[01/01/2015]

[01/01/2015]

[01/01/2015]

[01/01/2012]

[01/01/2015]

WMTC corr.:          
THC=1.10, CO=1.31, 
NOx=1.47
PC EU5/EU3 fact.: 
THC=0.50, CO=0.435, 
WMTC corr.:          
THC=1.10, CO=1.31, 
NOx=1.47
PC EU5/EU3 fact.: 
THC=0.50, CO=0.435, 
WMTC corr.:          
THC=1.10, CO=1.31, 
NOx=1.47
PC EU5/EU3 fact.: 
THC=0.50, CO=0.435, 
WMTC corr.:          
THC=1.10, CO=1.31, 
NOx=1.47
PC EU5/EU3 fact.: 
THC=0.50, CO=0.435, 
NOx=0.40

PI

PI

PI

CI

WMTC, 
ph2

WMTC, 
ph2

WMTC, 
ph2

WMTC, 
ph2

ECE R40

ECE R40

ECE R40

ECE R40

01/01/2003

PI & <50cc

ECE R47

[01/01/2012]

PI & <50cc

[01/01/2015]

PI & <50cc

ECE R47 
& cold

ECE R47 
& cold

ECE R40

ECE R40

ECE R40

ECE R40

[01/01/2012]

100

[01/01/2012]

[01/01/2015]

80

[01/01/2015]

PI

CI

PI

CI

1000

650

100

[01/01/2012]

600

550

80

01/01/2015

NB scenario #
3

Reference to emission study LAT & ACEM proposals for introduction into the upcoming EU legislation 
Proposal ACEM, categories L1 to L7 (for L3 the 2-step approach and the calculated multiplication factor vs EU3) 

Table 32: Proposed L-category vehicle emission limits by European motorcycle industry association ACEM 

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ANNEX VIII: BACKGROUND TO THE TYPE-APPROVAL SYSTEM 

How the system works 

Before  the  EU  developed  the  type-approval  system  most  Member  States  (MS)  used  to  have  their  own, 
differing national requirements for new vehicles to be allowed on the market. The directives for L-Category 
vehicles  (2002/24/EC)  were  set  up  to  counter  the  problems  for  industry  created  by  these  differences  and 
separate approval procedures by harmonising the minimum requirements to be fulfilled. Execution of testing 
and approval activities was left to the MS. In the directives it is stated that other MS have to accept approvals 
given in one MS (mutual recognition, based on EU requirements; an approach of mutual recognition based 
on  –differing-  national  requirements  has  been  discussed  in  the  past  but  has  never  been  accepted  by 
Member States).  

Costs: the system has inherent costs: the directives have to be developed (meetings of experts, drafting by 
Commission services and experts from MS; procedural costs related to getting the draft approved by the co-
legislators;  cost  of  implementing  directives  in  national  legislation  and  its  verification  by  the  Commission; 
costs for manufacturers to get their product tested (including provision of products for testing) and approved; 
follow-up costs if product needs to be adapted and again approved. Available figures are in this report and 
the supporting external report.  

Every Member State appoints a ‘Type-approval authority’. This TAA must be notified to the Commission and 
other MS to perform the necessary tests or other institutes (test houses) can be notified for this purpose. 

A manufacturer, who proposes a new vehicle or component (e.g. headlamp) contacts the TAA and the test 
house, submits the prescribed completed information document, makes the vehicle or component available 
for testing and pays the fees. 

It may prove that the test is not passed; in such case the product can be adapted and resubmitted for testing.  

If all is well the manufacturer obtains the test report(s) and approval form(s). These forms are defined in the 
Separate Directives (SDs). Then the manufacturer is able to sell his product everywhere in the EU, provided 
she / he puts the prescribed marking on the product and, for vehicles, provides a Certificate of Conformity 
(CoC) with every vehicle delivered. 

In case of a vehicle, the manufacturer can obtain TA in one step (all testing etc in one go), or step-by-step 
(separate approvals for every component / system; in the end, for the vehicle as a whole, she / he submits 
the  approvals  given  before.  In  the  latter  case,  which  is  must  usual,  many  part-approvals  may  have  been 
obtained  by  other  (component)  manufacturers.  Another  option  foreseen  is  that  one  manufacturer  builds  a 
basic but incomplete vehicle and the next finishes it by e.g. building the bodywork on it, or modifying it for a 
specific purpose: multi-stage approval. 

A manufacturer can submit a product for TA only in one MS, to one TAA (no ‘shopping’). 

The  TAA  must  inform  the  other  authorities  about  TA’s  given,  denied  or  withdrawn.  The  latter  because  the 
TAA  is  responsible  towards  the others  in  case  it  is found  that  products  are  marketed which are not  in  line 
with the TA given. 

As long as the EU system allows options, this means that the manufacturer may choose to apply for an EU 
TA  for  the  vehicle  or  component.  EU  requirements are  often somewhat  stricter  than  national  requirements 
and  thus  the  product  may  have  to  be  somewhat  more  expensive;  on  the  other  hand  if  his  markets  are  in 
more MS she / he can choose his best option. 

The approval procedure for a vehicle may be time-consuming, often starting in the first year of development, 
lasting 3 to 4 years. It’s important for the manufacturer not to have to repeat this number of times in different 
countries. 

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ANNEX IX: THE MARKET FOR L-CATEGORY VEHICLE IN THE EU 

1. 

THE STRUCTURE OF THE EU MARKET 

The  powered  two-wheeler  (PTW)  segment  of  the  L-category  market  is  the  most  important  in  terms  of 
manufacturing, turnover and employment. However, in order to keep the analysis in line with the structure of 
other sections of the impact assessment, the analysis is carried out in the following order: 

(1) 
(2) 
(3) 
(4) 

Electrical cycles 
Powered Two Wheelers: Mopeds and motorcycles. This also includes motorcycles with side car. 
Off-road Quads; also called All Terrain Vehicles (ATVs) 
Mini-cars 

2. 

ELECTRICAL CYCLES 

Currently electrical cycles fall out of the scope of L-category vehicles (less than 0.25 kW, maximum vehicle 
speed  of  25  km/h).  More  powerful  electric  cycles  are  categorised  as  mopeds  and  fall  in  the  scope  of  type 
approval legislation. 

The market is still very young and very fragmented. Most of the electric bike manufacturers who entered the 
market  first,  originally  produced  conventional  bikes  and  gradually  added  the  production  of  electric  bikes  to 
their activities. The number of vehicles produced is either not available or still very low. Only 6 companies 
produce relevant numbers, in 2009 ranging from an estimated 6 000 to 50 000 cycles. They have accordingly 
relevant revenues ranging from €350 000 to €2.7 million in 2009.  

The electric cycle industry is a very international business, with companies located in Europe, America and 
the  Far  East.  The  overall  majority  of  the  companies  are  very  small,  often  even  micro  companies.  Quite  a 
number  of  them  have  no  prior  history  in  the  cycle  business.  All  large  companies  are  companies  that  are 
adding  electric  cycle  activities  to  their  original  activities  in  the  field  of  conventional  cycles.  The  overall 
majority  of  the  companies  are  active  in  various  electric  vehicle  categories.  The  production  of  the  overall 
majority of the companies is still in a very early stage. As a result production volume and revenues are low, 
whereas R&D costs are relatively high. 

2.1. 

Sales of Electric Cycles 

The European Commission has received the following data from professional organisations (ETRA) and the 
data has not been verified independently. 

France: 
Sales in 2008 were at 15 800 units, which is a 50 % improvement of the 2007 result.  

Germany: 
In  2008,  an  estimated  100 000  electric  cycles  were  sold,  which  is  2.5 %  of  total  sales  volume.  Growth  is 
considerable: +62.5 % in 2007, +54 % in 2008 and a forecasted +20 % in 2009. 
Italy: 
Sales in 2008 are estimated at 10 000, whereas for 2009 they are expected to increase to 30 000. Sales may 
well be further encouraged as a result of the renewed cycling incentive scheme. The Italian government has 
allocated  another  €7.6  million  euro  to  spur  consumers  to  purchase  (electric)  cycles.  In  a  first  phase,  the 
Italian  government  has  already  granted  €11.4  million  euro  as  incentives  for  buying  (electric)  bikes.  The 
incentive was extremely successful.  

The Netherlands: 
In  2008,  almost  140 000  electric  bikes  were  sold  at  an  average  retail  price  of  €1 900.  Thus  electric  cycles 
have generated 1/3 of the total revenue from sales of new bikes in The Netherlands. 

UK: 
Sales in 2008 are estimated at 15 000, whereas for 2009 a 50 % increase is forecasted. Sales are reported to 
be mainly to commuters who are replacing car or public transport journeys by electric bike journeys. Sales 
have been bolstered by tax breaks on cycle purchases. 

Belgium: 

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There are no statistics available but the most important suppliers all confirm the success of the electric cycle. 
Since 2007, Sparta, which is one of the most popular brands in Belgium reports growth of 10 to 15 % a year, 
with  a  +15 %  prognosis  for  this  year.  With  that,  sales  of  electric  bikes  are  reported  to  increase  more  than 
other types of bikes. 

Worldwide Electric Bike Sales as Estimated in the Electric Bikes* Worldwide Reports 
2008

Year

China
India
Japan
European 
Union
Taiwan
SE Asia
USA
Total

2007
21,000,000
85,000
300,000
250,000

2008

21,000,000
120,000
317,000
550,000

10,000
200,000
120,000
21,965,000

10,000
800,000
170,000
22,967,000

2009

21,000,000
300,000
325,000
800,000

11,000
1,000,000
220,000
23,656,000

2010

25,000,000
500,000
325,000
1,200,000

12,000
2,000,000
350,000
29,387,000

2011
30,000,000
700,000
350,000
2,500,000

14,000
5,000,000
500,000
39,064,000

Table 33: Worldwide Electric cycle sales and sales forecasts 

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3. 

POWERED TWO-WHEELERS (PTW) 

This is the largest and most important sector of the industry and includes motorcycles, including those with a 
side car, mopeds and scooters. PTW market statistics 

3.1. 

EuroStat data 

The  manufacturing  of  motorcycles  is  classified  under  the  NACE  activity  classifications  of  35.4  and  35.5. 
However,  this  particular  classification  does  not  disaggregate  the  manufacture  of  motor-cycles  from  the 
manufacture of cycles. In addition, the classification is so broad that a manufacturer which contributes in any 
way to the manufacture of a vehicle is included. Using this classification, EuroStat estimates that there are 
2.300  companies  manufacturing  motorcycles  and  cycles.  This  would  seem  to  be  an  over-estimate  of  the 
reality of the market-place. A study by the University of Bologna estimates that that stripping out the cycle 
manufacturing  companies  would  yield  an  estimated  870  companies  which  manufacture  motorcycles. 
However,  in  order  to  get  a  more  accurate  estimate  of  the  number  of  manufacturing  companies,  data  has 
been gathered from the ‘type approval’ authorities and analysed to produce a more accurate picture of the 
number of manufactures in the EU. The results are discussed below in chapter 3.2. 

EuroStat also provides data for Prodcom classifications, which indicates the number of units produced and 
the  production  value  for  certain  classifications  of  manufacturing  activities.  Motor-cycles  and  scooters  are 
classified under subsectors 35.4 and 35.5, classified by cylinder displacement. The most recent full year data 
is for 2007. 

The data indicates that for 2007, the EU produced 1.136 million L-category vehicles.  Overall, the statistics 
indicate  that  the  value  of  production  of  motorcycles  and  scooters  in  the  EU  was  € 4.1  billion  in  2007.  The 
most important segment in terms of value is the large motor-cycle segment, where the engine size is greater 
than 800cc; the production value is € 1 billion for this segment. In terms of number of vehicles, more scooters 
are produced than motorcycles, but their overall value is less and was valued at € 840 million in 2007.  

The  production  of  ‘parts  and  accessories’  is  also  an  important  segment,  with  a  production  value  of  € 1.6 
billion. 

Powered Two Wheelers sub categories

Motorcycles, and cycles fitted with an auxiliary motor, 
with an engine capacity <= 50cc

Scooters with an engine capacity > 50cc but ≤ 250cc

Motorcycles with an engine capacity > 50cc but ≤  
250cc (excluding scooters)
Motorcycles with an engine capacity > 250cc but ≤ 
500cc
Motorcycles with an engine capacity > 500cc but ≤  
800 cc
Motorcycles with an engine capacity > 800 cc
Motorcycle side-cars
Total

1000's of 
units

€ million

493

360

120

158

109

180
40
1,136

631

840

250

587

692

1,000
127
4,127

Table 34: Production volume Powered Two Wheelers 2007, EuroStat data 

3.2. 

Type Approval data 

The data generated by type-approval authorities are a more market based source of information and can be 
particularly  useful  to  assess  the  structure  of  the  market  because  the  type  approval  data  indicates  which 
manufacturers  had  a  vehicle  type-approved  in  order  to  place  it  on  the  market.  Initially  a  sample  of  type-
approval data from March 2008 to 2009 was analysed. Following on from that analysis, a large sample from 
January 4th 2005 to March 2009 was analysed to ensure that the results are consistent. This later sample 
involved over 15.000 type-approvals for vehicles. 

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The analysis of the type-approval data indicates a far smaller cohort of active companies who manufacture 
L-category  vehicles  and  place  them  on  the  market,  than  that  indicated  by  the  EuroStat  data.  Having 
analysed in detail the type approval data from March 2008 to 2009, the analysis results indicated that 42 EU 
companies applied for type approval for an L-category vehicle. Of the 42 companies, 18 are Italian, 10 are 
German, 5 are French, 2 are Spanish, 2 Swedish and one each from UK (Triumph), Poland, Greece, Austria 
and Switzerland. However, further investigations yield the information that companies which are based in the 
EU sought type-approval for vehicles which they did not actually manufacture themselves, but they imported 
the vehicles from China and then marketed and sold the vehicles in Europe.  

Finally,  of  the  42  companies,  we  estimate  that  17  are  SME’s.  The  remaining  25  of  the  42  companies  are 
owned  by  large  companies  or  large  corporations.  The  analysis  of  the  type-approval  data  is  reasonably 
consistent with data recently received from industry (ACEM). ACEM have indicated that their estimate is that 
106 companies manufacture motorcycles. This figure of 106 includes non-EU companies from Japan, China, 
Thailand and the United States.  

Having analysed the data for one year above, a larger sample was analysed covering the timeframe January 
4th  2005  to  March  2009.  Since  2005,  approximately  280  EU  companies  sought  type  approval  to  place  a 
vehicle on the market. This results in an average of 56 companies per year. Consequently it was estimated 
that there are between 42 and 56 European companies manufacturing motorcycles in the EU. However, over 
the  same  time  period,  398  non-EU  companies  applied  for  type-approval  to  place  vehicles  on  the  market. 
Among the non-EU, by far the most significant group were Chinese companies seeking type-approval.  

3.3. 

Import and export of motorcycles and motorcycle parts 

The  following  import  into  the  EU  and  export  from  the  EU  data  were  obtained from  EuroStat  and  extracted 
using  the  COMEX  database  from  1999  to  2008.  The  most  significant  trend  is  high  and  sustained  imports 
from Japan from 1999 to 2008, from companies such as Honda, Suzuki, Kawasaki and Yamaha, as shown in 
the  sales  data  below.  Following  from  Japan,  the  main  imports  are  from  China,  USA  and  Taiwan.  As 
mentioned above, the imports from China are often rebranded and marketed under a European name such 
as Hartford (UK) and Geopolis (Greek company). The value of imports from China and Taiwan has increased 
dramatically from 178.1 million Euros in 1999 up to 646.5 million Euros in 2008.  

As regards exports, the largest export market for motorcycles manufactured in the EU is the USA, increasing 
from  220.5  million  Euros  in  1999  to  359.4  million  Euros  in  2008.  After  the  USA,  the  largest  markets  are 
Australia  and  Switzerland.  There 
to  China  and 
Taiwan.

is  no  significant  export  yet 

the  EU 

from 

PTW
IMPORTS [x 1,000 €]
Extra European
Japan
China
USA
Taiwan
Thailand
EXPORTS [x 1000 €]
Extra European
USA
Australia
Switzerland
Japan
Vietnam

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2,840,946 3,091,244
2,305,627 2,489,032
19,958
260,033
209,501
357

11,198
218,584
166,931
606

510,394
220,552
29,666
75,865
55,153

700,753
331,803
42,337
87,554
76,280
103

2,710,645 2,390,600 2,531,612 2,798,560 3,019,010 3,181,156 3,206,480 2,881,422
2,141,665 1,909,956 1,879,365 1,964,394 1,918,938 2,119,349 2,075,018 1,690,580
496,554
351,517
149,960
109,466

391,425
348,575
181,024
28,106

447,815
344,392
178,059
49,459

31,865
295,635
136,778
1,835

371,894
378,525
186,226
49,546

176,613
333,784
176,416
39,011

51,329
204,668
132,891
5,903

100,606
307,167
150,587
18,356

775,878
341,230
49,129
86,165
95,741
208

831,399
337,489
53,253
81,468
92,309
2,192

775,699
335,957
52,745
100,109
80,287
4,769

764,477
301,612
72,880
92,231
71,225
18,586

832,953
314,640
79,165
87,805
69,961
24,096

970,691 1,014,522 1,063,138
359,402
374,727
397,172
115,410
91,115
90,990
94,178
99,586
86,216
793,353
70,798
66,497
62,355
61,144
35,721

Table 35: Import in the EU and Export from the EU of motorcycles, 1999 – 2008 

EN 

63 

   EN 

 
 
Similar trends as for complete motorcycles can also be observed for motorcycle parts. The majority of motor-
cycle  parts  come  from  Japan,  Taiwan  and  China,  again  with  the  greatest  amounts  of  imports  from  Japan. 
The value of imports of parts is almost twice that of exports. The ratio of imports to exports for motorcycle 
parts  with  Japan  has  declined  from  11.4  in  1999  to  9.0  in  2008,  however  the  value  remains  substantive. 
Imports  have  continued  to  increase  from  China  and  Taiwan  from  52.3  million  Euros  in  1999  up  to  226.7 
million  Euros  in  2008,  which  is  4.3  times  more  than  in  1999.  As  regards  exports  of  motorcycle  parts  from 
Europe,  the  main  exports  are  to  the  USA  where  exports  increased  from  € 43.3  million  in  1999  to  € 135.7 
million in 2008. After the USA, the next most important markets are those of Brazil and Switzerland.  

Motorcycle parts
IMPORTS [x 1,000 €]
Extra European
Japan
Taiwan
China
USA
Thailand
EXPORTS [x 1000 €]
Extra European
USA
Brazil
Switzerland
Japan
Australia

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

340,746
200,540
48,998
2,313
66,255
7,533

144,458
43,262
4,595
13,778
17,550
7,022

489,969
294,890
78,010
8,263
78,362
13,246

182,408
62,321
4,982
17,838
24,188
6,237

481,118
277,034
70,336
14,455
83,304
15,621

201,897
66,578
7,640
21,436
25,074
7,072

447,030
271,174
57,876
26,724
46,045
20,158

248,520
101,538
5,979
18,569
27,817
7,601

494,501
276,935
60,712
42,642
61,177
25,195

244,119
108,164
3,988
17,178
32,508
9,676

562,346
291,195
75,159
58,332
60,869
40,417

240,791
110,844
4,235
21,295
28,962
10,024

591,841
278,790
87,571
67,996
67,426
45,426

251,697
104,006
8,297
23,649
30,869
12,659

629,977
268,689
104,765
80,467
67,958
51,903

291,352
133,776
8,049
24,969
29,250
14,685

689,039
274,978
111,178
96,809
74,795
57,160

312,061
136,938
10,115
28,002
27,404
16,707

690,406
247,848
118,887
107,805
75,137
65,493

338,389
135,733
29,152
28,245
27,407
16,997

Table 36: Import in the EU and Export from the EU of motorcycle parts, 1999 – 2008 

3.4. 

The impact of the new measures on international trade 

The  EU  imported  €2.8  billion  worth  of  motor-cycles  from  outside  the  EU  in  2008,  with  the  main  import 
countries being Japan €1.7 billion and China € 0.5 billion. Chinese imports have grown from € 11 million to € 
0.5 billion since 1999. Imports from Thailand have also increased significantly from € 606.000 to € 109 million 
in  the  same  time  period.  The  EU  exported  € 1.06  billion,  the  main  markets  being  the  United  States  and 
Switzerland.  The  trend  for  international  trade  is  to  see  increased  imports  from  China  and  other  Asian 
countries  into  the  EU.  Given  the  patterns  that  have  emerged  from  the  analysis  of  the  type-approvals  over 
recent years, the indication is that this will continue.  

The  safety  aspects  of  the  new  regulation  will  be  crucial  to  prevent  unsafe  vehicles  being  placed  on  the 
European market and to protect the consumer from purchasing unsafe products. In conjunction with this, it is 
necessary  to  put  in  place  increased  market  surveillance  to  prevent  such  vehicles  being  placed  on  the  EU 
markets.  The  labelling  of  vehicles  with  information  regarding  carbon  dioxide  emissions  will  assist  the 
consumer  to  choose  the  most  energy  efficient  vehicles  irrespective  of  country  of  origin  of  the  vehicle  and 
ensure a level-playing field for all manufacturers. The price of motorcycles in the EU may increase if the cost 
of  the  improved  safety  features  and  meeting  lower  pollutant  emission  targets  and  other  necessary 
environmental measures is passed on to customers.  

3.5. 

Production of PTWs 

The activity of the manufacture of motorcycles is grouped under NACE code 35.41 by EuroStat. According to 
the 2009 EuroStat Facts and Figure, the EU-27’s motorcycles and cycles manufacturing subsector consisted 
of 2 300 enterprises which created € 2.4 billion of value added in 2006. The sector employed 55 900 persons. 
Italy  was  the  largest  producer  of  motorcycles  and  cycles  in  the  EU-27,  with  a  40 %  share  of  EU-27  value 
added  and  a  35%  share  of  the  workforce.  Italy  and  Lithuania  were  the  most  specialised  producers  of 
motorcycles  and  cycles  within  the  EU-27  in  terms  of  the  sector’s  contribution  to  non-financial  business 
economy  value  added.  In  2007  motorcycles  and  cycles  manufacturing  output  in  the  EU-27  grew  by  2.2%, 
following 1.8% growth in 2006. 

In  2006  the  EU-27’s  motorcycles  and  cycles  manufacturing  subsectors  combined  an  apparent  labour 
productivity of € 42 600 per person employed with average personnel costs of € 30 900 per employee to leave 
a wage adjusted labour productivity ratio of 138% which is very high. In most Member States value added 
per  person employed  exceeded  personnel  costs  per  employee,  the  exceptions  being  Slovenia  and  France 
where  the  wage  adjusted  labour  productivity  ratio  was  below  100%,  and  in  Ireland  where  negative  value 
added resulted in a large, negative wage adjusted labour productivity ratio. 

EN 

64 

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Description

PRODCOM code

Production 
Value
( €million)

Volume sold  Production Value

Volume sold 

( 1000 units)

( €million)

( 1000 units)

2006

2007

Parts and accessories 
for motorcycles, 
mopeds and scooters 
(excluding saddles)
Scooters with an engine 
capacity > 50 cm3 but ≤ 
250 cm3
Motorcycles, and cycles 
fitted with an auxiliary 
motor, with an engine 
capacity ≤ 50 cm3

35.41.20.90

1,720

1,452

35.41.12.13

1,255

622

840

35.41.11.00

678

530

706

368

35.41.12.30

Motorcycles with an 
engine capacity >250 
cm3 but less than 500 
cm3
Motorcycles with an 
engine capacity > 500 
cm3 but ≤ 800 cm3
Motorcycles with an 
engine capacity > 800 
cm3
Table 37: Production PTWs for 2006 and 2007- Source EuroStat 

35.41.12.70

35.41.12.50

983

77

172

693

1,000

360

530

109

180

Table 7 gives a snap-shop of data for the production of PTWs using PRODCOM data for 2006 and 2007 for 
the  various  categories  of  motorcycles,  scooters  and  parts.  The  figures  reveal  that  in  2007,  the  value  of 
motorcycle production of vehicles over 800cc was the most lucrative and was valued at €1 billion, producing 
180 000 vehicles. The second highest value was for scooters at 840 million producing 360 000 scooters. This 
was followed by 530 000 motorcycles with capacity of less than 50 cm3 worth €706 million. A total of 109 000 
vehicles  were  produced  in  the  EU  with  engine  displacements  between  500  and  800cc  at  a  value  of  €693 
million. 

EN 

65 

   EN 

 
 
QUANTITY and VALUE of L-Category Vehicles By ENGINE CAPACITY

QUANTITY [thousand 
units]

VALUE IN Million €

Motorcycles, and cycles fitted with an auxiliary motor, with an engine capacity <= 50 cm

 EU15 TOTALS

Jan.-Dec. 2000

      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
EU27 TOTALS
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
      Jan.-Dec. 2006
      Jan.-Dec. 2007
      Jan.-Dec. 2008

1,324

927
900
720
600
600

796
600
600
510
530
493

Scooters with an engine capacity > 50 cm but <= 250 cm
 EU15 TOTALS
      Jan.-Dec. 2000
      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
 EU27 TOTALS
      Jan.-Dec. 2003

565
477
452
335
368
586

335

      Jan.-Dec. 2004
      Jan.-Dec. 2005
      Jan.-Dec. 2006
      Jan.-Dec. 2007
      Jan.-Dec. 2008

368
586
376
360

1,451

994
900
900
900
400

1,000
880
400
657
706
631

1,155
944
886
711
783
1,179

711

783
1,179
799
840

Motorcycles with an engine capacity > 50 cm but <= 250 cm (excluding scooters)
EU15 TOTALS
      Jan.-Dec. 2000
      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003

261
240
320
250

100
90
120
60

80
150

60
80
150
120
120

      Jan.-Dec. 2004
      Jan.-Dec. 2005
EU27 TOTALS
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
      Jan.-Dec. 2006
      Jan.-Dec. 2007
      Jan.-Dec. 2008
Motorcycles with an engine capacity > 250 cm but <= 500 cm
 EU15 TOTALS
      Jan.-Dec. 2000
      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
EU27 TOTALS
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
      Jan.-Dec. 2006
      Jan.-Dec. 2007
      Jan.-Dec. 2008

80
83
89
77
158

49
41
44
78
60
87

210
280

250
210
280
360
250

192
160
187
334
400
363

337
400
365
369
587

Table 38: Quantity and value of L-Category Vehicles by engine capacity, part 1 

EN 

66 

   EN 

 
 
 
 
QUANTITY and VALUE of L-Category Vehicles By ENGINE CAPACITY

QUANTITY [thousand 
units]

VALUE IN Million €

108
146
165
128
109

126
91
96
108
145
165

Motorcycles with an engine capacity > 500 cm but <= 800 cm
EU15 TOTALS
      Jan.-Dec. 2000
      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
EU27 TOTALS
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
      Jan.-Dec. 2006
      Jan.-Dec. 2007
Motorcycles with an engine capacity > 800 cm
EU15 TOTALS
      Jan.-Dec. 2000
      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
EU27 TOTALS
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
      Jan.-Dec. 2006
      Jan.-Dec. 2007
      Jan.-Dec. 2008
Motorcycle side-cars
 EU15 TOTALS
      Jan.-Dec. 2000
      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
EU27 TOTALS
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
      Jan.-Dec. 2006
      Jan.-Dec. 2007
      Jan.-Dec. 2008

125
140
180
120
100
150
0
120
100
150
126
180

3
4
4
3
1
2

17
3
17
28
16
128
QUANTITY and VALUE of L-Category Vehicles By ENGINE CAPACITY

3
2
2
6
3
40

560
477
539
659
826
851

659
826
851
767
693

898
1,201
1,400
1,135
1,075
1,205
0
1,137
1,077
1,207
1,173
1,000

16
20
23
17
2
17

units]

VALUE IN Million €

45.00
35.00
28.00
20.00
27.00
60.00

3,500.00
2,000.00
2,800.00
1,800.00
1,500.00
2,400.00

1,800.00
1,500.00
2,400.00
1,600.00
2,400.00
1,200.00

Saddles for motorcycles, mopeds, and scooters
EU15 TOTALS
      Jan.-Dec. 2000
      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
EU27 TOTALS
20.00
      Jan.-Dec. 2003
27.00
      Jan.-Dec. 2004
60.00
      Jan.-Dec. 2005
28.00
      Jan.-Dec. 2006
40.00
      Jan.-Dec. 2007
      Jan.-Dec. 2008
28.00
Parts and accessories for motorcycles, mopeds and scooters (excluding saddles)
 EU15 TOTALS
      Jan.-Dec. 2000
      Jan.-Dec. 2001
      Jan.-Dec. 2002
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
EU27 TOTALS
      Jan.-Dec. 2003
      Jan.-Dec. 2004
      Jan.-Dec. 2005
      Jan.-Dec. 2006
      Jan.-Dec. 2007
      Jan.-Dec. 2008
Table 39: Quantity and value of L-Category Vehicles by engine capacity, part 3 

1,225
1,263
1,320
1,467
1,497
1,535
0
1,479
1,514
1,578
1,444
1,450
1,604

EN 

67 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Tables 8 & 9 give a more extended and detailed picture of the market from 2001 to 2008. This tables yield 
the Prodcom data for the value of production and quantity of goods produced since 2001, for EU 15 and then 
for EU 27. The production is broken down in detail motorcycles and scooters by engine capacity. 

3.6. 

PTW Price development over time 

The consumer price indices from EuroStat have data for all EU 27 countries in a category ‘Motor cycles, 
cycles  and  animal  drawn  vehicles’.  The  following  table  illustrates  prices  on  an  annual  base  from  2000  to 
2008. 

2000 

2001 

2002 

2003 

2004 

2005 

2006 

2007 

2008 

EU 27  98.0 

99.5 

98.4 

99.1 

100.2 

100.0 

100.0 

101.1 

102.9 

Table 40: consumer price indices in category ‘Motor cycles, cycles and animal drawn vehicles’ in EU 
27 countries 

As a practical example of how prices have changed over time, an OEM has provided an example of price 
development over time for a popular 1200 cm3 motorcycle with standard fittings. The prices include VAT. The 
company name is with-held for reasons of confidentiality. 

Month 
January 
January 
January 
January 
January 
January 
May 

Year 
2004 
2005 
2006 
2007 
2008 
2009 
2009 

Price 
€ 11 500 
€ 11 700 
€ 12 050 
€ 12 360 
€ 12 500 
€ 12 650 
€ 12 800 

Table 41: Example of price development over time for a popular 1200 cm3 motorcycle (Source: 
anonymous motorcycle manufacturer) 

3.7. 

Sales of PTWs 

In line with the automotive industry, the PTW industry was affected by the economic crisis in the final quarter 
of 2008 and also again in 2009. The market in 2008 decreased by 7.4 % on a year by year basis over 2007. 
In the first quarter of 2009, PTW sales were down 37 % on the same period in 2008.  

Few  countries  have  taken  demand  measures  to  stimulate  the  sales  of  new  vehicles,  Italy  being  the  main 
exception.  Italy  has  put  a  scrapping  scheme  in  place:  vehicles  with  low  cylinder  capacity  benefited  from  a 
€ 500 contribution for scrapping obsolete vehicles. This had a positive effect on the market. However, sales 
still  decreased  by  20 %.  Spain  has  adopted  a  motorcycle  scrapping  scheme  in  July  2008  but  this  has  not 
been implemented. Between January and August 2009 in Spain Moped sales were down by 52 % and PTW 
sales were down by 43 % on the same period in 2008 . 

EN 

68 

   EN 

 
  
MOTORCYCLES

MOPEDS

Ranking
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

Brand
HONDA
YAMAHA
SUZUKI
PIAGGIO
KAWASAKI
BMW
KYMCO
APRILIA
HARLEY
KTM
TRIUMPH
DUCATI
SYM
PEUGEOT
DAELIM
HYOSUNG
MALAGUTI 
DERBI
GILERA
HUSQVARNA
OTHERS

Sales
235,906
213,661
149,090
130,065
82,624
67,448
55,673
41,921
39,935
32,137
27,966
25,497
24,238
19,240
11,906
8,631
8,480
6,642
6,234
6,208
89,855

Market 
share
17.2%
15.6%
10.9%
9.5%
6.0%
4.9%
4.1%
3.1%
2.9%
2.4%
2.0%
1.9%
1.8%
1.4%
0.9%
0.6%
0.6%
0.5%
0.5%
0.5%
6.6%

Ranking
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

Brand
YAMAHA
PIAGGIO
PEUGEOT
DERBI
KYMCO 
BAOTIAN
KEEWAY
APRILIA
RIEJU
SYM
CPI
BETA
MBK 
TGB
GILERA
HONDA
DAELIM
SKYTEAM
SAMADA
MALAGUTI
OTHERS

Sales
34,687
26,639
25,027
23,680
21,991
16,620
15,016
12,008
9,804
8,345
5,531
4,626
4,374
3,805
3,477
3,123
1,874
1,473
1,329
1,291
133,887

Market 
share
9.1%
7.0%
6.6%
6.2%
5.8%
4.4%
3.9%
3.2%
2.6%
2.2%
1.5%
1.2%
1.2%
1.0%
0.9%
0.8%
0.5%
0.4%
0.4%
0.3%
35.1%

7.4.4.  Motorcycles 

Table 42: Sales data and market share for 2008- (Source ACEM) 

The  first  four  left  hand  columns  relate  to  refers  to  sales  of  motorcycles  in  the  EU  during  2008.  Japanese 
companies  have  captured  50 %  of  the  market  for  motor-cycles  in  the  EU.  The  most  successful  European 
company is Piaggio with a market share of 9.5 %, followed by BMW with a share of 4.9 %. Large companies 
are dominant in the market for motorcycles. 

7.4.5.  Mopeds 

The moped market is more fragmented than the market for motorcycles and the total supplied ‘by others’ is 
35 %  of  the  market.  Industry  sources  indicate  that  the  overall  market  share  for  Chinese  companies  for 
motorcycles and mopeds combined is 20 % and anecdotal evidence suggests that the EU moped market is 
most under threat from cheap imports from the Far East (with the exception of Japan). 

3.8. 

Upstream-Suppliers 

The number of suppliers to the industry is estimated at around 500. These suppliers have traditionally been 
European concentrated in Italy, Spain, France, the United Kingdom, Germany and the Netherlands. In recent 
years  competition  from  Asian  suppliers  has  increased.  In  response  to  this  competition  some  European 
suppliers  have  in  turn  moved  part  of  their  activities  to  Asia.  However,  European  component  suppliers  rely 
exclusively  on  orders  from  European  producers.  There  are  an  estimated  20 000  jobs  in  the  components 
sector, located mainly in Italy, Spain, France, the United Kingdom, Germany, the Netherlands and Hungary. 
These activities are included in the NACE 35.41 classification. 

3.9. 

Downstream- sale, maintenance and repair  

The  downstream  activities  of  the  sale,  maintenance  and  repair  of  motorcycles  are  gathered  under  NACE 
50.4.  This  distribution  sector  generated  € 3.4  billion  of  value  added  in  the  EU-27  million  in  2006  from  a 
turnover  of  over  €25  billion.  105 000  persons  were  employed  by  the  37 000  enterprises  in  the  motorcycles 
distribution sector. It is estimated that 72 % of the total industry’s turnover is generated in this sector. 

EN 

69 

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The  distribution  and  assistance  network  works  in  proximity  to  its  users  which  is  specific  to  motorcycles 
(especially as regards mopeds and scooters): in the EU there are around 37 000 active points of sale and 
after-sales assistance, often run by family businesses. Italy, France, the United Kingdom, Germany, Spain, 
the Netherlands, Greece and Sweden account for 91 % of turnover in the distribution and assistance sector; 
this figure rose by 5 % between 2004 and 2006. 

3.10. 

Employment PTW industry 

The  total  number  of  persons  employed  for  the  motorcycle  and  cycle  industry  as  a  whole  is  estimated  at 
approximately  184 000,  between  manufacturers,  upstream  and  downstream  sectors.  As  mentioned  above 
the NACE class DM3541 for ‘the manufacture of motorcycles and cycles’ does not disaggregate motorcycles 
from cycles, so both are included in the values below. Given that caveat, in 2004 the most recent EuroStat 
data show that 59 000 people were employed in the manufacturing sector. From the NACE class 50.4 which 
analyses  the  sale,  maintenance  and  repair  of  motorcycles  below,  it  can  be  derived  that  105 000  persons 
were  employed  in  this  sub-category.  Finally  supplier’s  organisations  estimate  the  numbers  of  persons 
employed in supplier industry is 20 000 persons. 

Employment  in  this  market  is  concentrated  in  Italy,  Spain,  France,  Germany  and  the  United  Kingdom. 
However, in terms of specialisation, Italy and Latvia are the most specialised, in terms of the importance of 
the  industry  to  their  own  economy.  The  seasonal  nature  of  the  motorcycle  market  which  is  busier  in  the 
spring  and  summer  months  causes  production  peaks  at certain  times  of  year,  during which  manufacturers 
take on seasonal workers. 

Amount of 
employees

Member State
BE

BG

CZ

DK

DE

ES
FR
IT
CY
LV
LT
LU
HU
MT
NL
AT
PL

PT
RO
SI
SK
FI
SE
UK
Totals

1-9

10 - 19

20-49

50-250

>250

Total

7

89

33

68
161
560

25

70
9
75

29
5
14
11
11
82
163
1,412

3

4

7

19
16
116

3

10
2
4

11
2

4
1
6
17
225

3

14

3

14
17
63

1
5

10
1
6

11
2

6

156

2

4
3
12

1

1
3

12

4

9
9
42

2

10
1
10

8
3
2

1
9

122

26

7

95

65

14

114
206
793

3
1
33

100
14
98

59
12
16
15
13
103
180
1,941

Table 43: Number of SME’s manufacturing motorcycles and cycles for 2006-NACE code DM3541 

EN 

70 

   EN 

 
 
Table 14 analyses the size of companies involved with the manufacture of motorcycles and cycles. There are 
two caveats with the statistics. The first is that the EuroStat statistics do not disaggregate motorcycles from 
cycles;  therefore  the  statistics  may  be  skewed.  The  second  caveat  is  that  the  statistics  do  not  include  the 
numbers for Germany which are unavailable for reasons of confidentiality. 

It is estimated that there are approximately 100 manufacturers of either motorcycles or mopeds in the EU, 
about half of which are owned by European companies. The number of SME’s operating in both motorcycle 
and scooter markets is very small. 

4. 

All Terrain Vehicles (ATVs) 

There  are  no  statistics  gathered  by  EuroStat  and  the  Impact  Assessment  must  rely  on  data  and  statistics 
presented  by  the  professional  organisations.  The  industry  for  On-road  quads  is  not  represented  by  a 
professional  organisation.  However,  Off-road  quads  (ATVs)  are  represented  by  ATVEA.  According  to 
ATVEA, this sector of the industry employs directly or indirectly 12.000 people and have a turn-over of € 2 
billion. 

EN 

71 

   EN 

 
4.1. 

All Terrain Vehicle (ATV) sales in Europe 

units

units
EUR/unit

EUR
EUR/unit
EUR
EUR
EUR
EUR

EUR/unit

units
EUR/unit
EUR/unit
EUR/unit

VALUE
175
19%
208

VALUE
70%
108,500
2750
3500
750
19%

VALUE
155,000
3,000
7%
3,210
100
890
4,200
800
5,000
19%

730,000

TOTAL ECONOMIC VALUE 2008
TAX CONTRIBUTION
ESTIMATED TOTAL FLEET
NEW UNIT SALES
DESCRIPTION
2008 new unit sales
Average CIF T1 costs
Import Duties
Avg Cost + import duties
Transport
Distribution Margin
Average Wholesales
Average Dealer Margin
Average Retail (excl. VAT)
VAT
TOTAL TAX
TOTAL UNIT SALES (INCL. TAX)
ACCESSORIES + GEAR
DESCRIPTION
Average (new units only)
VAT
Average (new units only) incl. VAT
TOTAL TAX
TOTAL UNIT SALES (INCL. TAX)
USED UNIT SALES
DESCRIPTION
ratio against new units
used units
average cost
average sales
margin
VAT
TOTAL TAX
TOTAL UNIT SALES (INCL. TAX)
REGISTRATION
DESCRIPTION
Local registration ratio
Local registration costs
Margin
Local registration sales
VAT
Local registration sales (INCL. TAX)
TOTAL TAX
TOTAL UNIT SALES (INCL. TAX)
PETROL
DESCRIPTION
Average milage
Consumption
Average liter
Fuel cost
Fuel tax
VAT
Fuel (retail)
TOTAL TAX
TOTAL SALES (INCL. TAX)
RENTAL
DESCRIPTION
units in operation at rental companies
units in operation at rental companies
rental fee
VAT
rental fee (incl. VAT)
billed hours per day
billed days per year
total rental income per unit / year
TOTAL TAX
TOTAL SALES (INCL. TAX)
INSURANCE
DESCRIPTION
insurance fee
insurance tax
VAT
insurance (retail)
TOTAL TAX
TOTAL SALES (INCL. TAX)

VALUE

14,600
42
19%
50
3
120
18,000

0.50
0.60
19%
1.20

VALUE

VALUE

VALUE

50% % of units
EUR/unit
500
EUR/unit
300
800
EUR/unit
19%
952

EUR/unit

2000 km/unit/year
liter/100 km
200 liter/unit/year

10

2% % of total

units
EUR/hr

hours/day
days/year
EUR

100 EUR/unit/year
8%
19%
127 EUR/unit/year

2,011,818,750
395,949,664

EUR
EUR

TOTAL MARKET VALUE

NOTE

465,000,000
32,550,000

775,000,000
147,250,000
179,800,000
922,250,000

TOTAL MARKET VALUE

NOTE

5,153,750
32,278,750

TOTAL MARKET VALUE

NOTE

% of units compared to new unit sales

15,461,250
379,750,000

TOTAL MARKET VALUE

NOTE

32,395,000
147,560,000
32,395,000
147,560,000

TOTAL MARKET VALUE

NOTE

EUR/liter
EUR/liter

EUR/liter

73,000,000
87,600,000
13,870,000

101,470,000
174,470,000

TOTAL MARKET VALUE

NOTE

262,800,000
41,959,664
262,800,000

TOTAL MARKET VALUE

NOTE

19,710,000
92,710,000

Table 44: All Terrain Vehicle (ATV) sales in Europe (source: ATVEA) 

EN 

72 

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4.2. 

Employment ATV industry 

TOTAL EMPLOYMENT 2008

12,454

NEW + USED UNIT SALES
2008 new + used unit sales
dealer staff (sales, service)
distributors
headquarters
others (incl. logistics, accounting, finance etc)
TOTAL EMPLOYMENT
ACCESSORIES + GEAR
turnover
dealer staff
distributors
European headquarters
others (incl. logistics, accounting, finance etc)
TOTAL EMPLOYMENT
REGISTRATION
number of variants put on the market in 2008
homologation officials
homologation development
total homologation employment
TOTAL EMPLOYMENT
PETROL
liters of fuel consumed per year
liters of fuel per employee
total staff required to sell and distribute fuel
TOTAL EMPLOYMENT
RENTAL
units in rental operation
average fleet / rental company
number of rental companies
staff per rental company
TOTAL STAFF
INSURANCE
number of total ATVs
total manhours required
hours per staff per year
insurance staff required
TOTAL STAFF

263,500
8,783
527
176
176

units / staff

30
500
1,500
1,500

32,278,750
646
40
22
10

to / staff

50,000
800,000
1,500,000

9,662

717

300

0.1 employment per variant per year
0.1 employment per variant per year
60

60

146,000,000
1,000,000
146

14,600
12
1,217
2

assumption 1M liter of fuel require 1 FTE

lifetime is 1 year

146

1,825

730000
60,833

5 minutes total jobtime per ATV
1400 average workhours per year per staff

43

43

Table 45: Employment ATV industry (source: ATVEA) 

5. 

MINI-CARS 

The  market  is  comprised  of  mini  cars  which  are  constructed  for  the  primary  purpose  of  on-road  transport. 
These  vehicles  are  exclusively  built  by  specialised  European  SMEs.  EuroStat  do  not  compile  statistics  on 
mini-cars  and  hence  the  European  Commission  are  dependent  on  professional  organisations  to  provide 
statistics.  The  European  fleet  of  mini-cars  manufactured  by  member  companies  of  EQUAL,  the  mini  car 
industry association, totals about 340 000 vehicles. Mini-cars represent 1.1 % of the L-category fleet and are 
vehicles meeting a specific need. The market is more mature in France, Spain, and Italy. The global sales for 
2007 were 35 000 vehicles, more than 90 % were equipped with very small, industrial, compression ignition 
engines, manufactured by industrial suppliers (Lombardini, Kubota, Yanmar) who do not develop a specific 
automotive product. The average annual mileage is estimated to be between 5 000 to 7 000 kilometres. 

At present there are 11 manufacturers, without exception SMEs, of mini-cars in Europe who are established 
in various Member States. The global market leader as producer for this vehicle type, employed 200 people 
in 2008, and produced 13 500 vehicles per year of which 1 500 electrical vehicles (200 – 300 utility vehicles).  

- In France: Aixam, Automobiles Ligier, Bellier, Chatenet, JDM-Simpa, Microcar, 
- In Italy: Casalini ; Grecav, Piaggio, Tasso, 
- In Germany: ATW. 

These  manufacturers  are  often  established  in  regions  lacking  a  developed  industrial  network  (in  France: 
Savoie, Vendée, in Italy: Abruzzi). On a larger scale, the mini-cars industry entertains a complex network of 
partners, on which depend 20000 jobs in Europe. 

EN 

73 

   EN 

 
  
         
             
                   
                
                 
                
              
                
              
                 
    
                
            
                  
          
                  
       
                  
                    
                
                      
  
      
                
                    
           
                  
             
                    
                 
           
                  
                      
 
ANNEX X: DETAILS CHAPTER 5 — IMPACT ANALYSIS — SIMPLIFICATION OF LEGISLATION 

In summary: 

Type of impact:

Economical
Environmental
Safety

Societal

Option 1: No policy change

Positive

Negative

No risk of loss or gain in quality of current 
requirements

Current problems like complexity, time-
consuming implementation task, obsolete or 
non-aligned measures with technology, lack 
of legal and regulatory clarity, increased 
proliferation of text etc. will not be resolved.

Neutral  / No agreement in public 
consultation

Remarks

Minimal impact

Low
0 €

Benefit
Mean
0 €

High
0 €

Low
€ 160,000

Cost
Mean

High

€ 3,100,000 € 10,500,000

Other indicators

cumulative EU27 2009 - 2020

€ 22,000

€ 25,000

€ 28,000

Annual estimated translation cost

Option 2: Repeal current directives and replace with a minimum number of regulations

Positive

Negative

Neutral  / No agreement in public 
consultation

Improved global harmonization, better and 
clearer structure of legal text

Length of processing: agreeing on one text 
including all requirements

Transparency

After initial investment, reduced annual costs 
of regulatory system
Translation cost eliminated if direct reference 
to technical standard
Technical standards meeting effort reduced 
for Industry/EU-27
Standardisation of component and vehicle 
design leading to economies of scale
Time taken for implementation of regulatory 
change deceased so benefits can be accrued 
more rapidly

More transparent regulatory system. 
Intangible benefits to all stakeholders; All 
Industry; potentially larger benefits for SMEs 
and new entrants
Emissions resulting from travel to/from 
technical standards meetings reduced for 
Industry/EU-27

Bureaucratic burden

Democratic gap

Loss in safety and environmental 
protection
Will final result of simplification of the 
current legal text and at the same 
time adding new measures to align 
with technical progress as end result 
truly simplify ?

Lack of Transparency was an issue for a minority of respondents to 
the public consultation, therefore was transparency rated neutral to 
positive, hence, listed in both columns
Same argument as mentioned for transparency applicable for 
bureaucratic burden
Same argument as mentioned for transparency applicable for 
democratic gap
Technical standards meeting effort reduced for Industry/EU-27: not 
quantified; magnitude of change uncertain
Economies of scale: not quantified; will only lead to savings for 
OEMs if standard design can be sold in more countries
More rapid accrued benefits: not quantified; potential large 
safety/environmental benefit depending on the performance of 
proposed change and how much quicker it can be implemented 
compared with current situation
More transparent regulatory system: not quantified; benefits difficult 
to quantify

Reduced travelling: not quantified; benefits uncertain

Benefit

Cost

Remarks / Other indicators

Low

Mean

High

Low

Mean

High

€ 78,000
€ 22,000

€ 420,000
€ 25,000

€ 786,000
€ 28,000

€ 58,000

€ 2,400,000

€ 8,800,000

cumulative 2009 - 2020. The benefit must be offset to the cost e.g. 
net mean cost: € 1,980,000.
Saved annual estimated translation cost

Benefit to cost ratio

Low
1.1
Break-even in year 2017 - 2019

Mean
1.2

High
2.5

Option 3: Recast the current framework Directive 2002/24/EC 

Positive

Improved global harmonization, better and 
clearer structure of legal text

Translation cost eliminated if direct reference 
to technical standard
Technical standards meeting effort reduced 
for Industry/EU-27

Standardisation of component and vehicle 
design leading to economies of scale

Negative
Length of processing: agreeing on one text 
including all requirements
Costs of regulatory system to implement 
and maintain EU Directives
Solution is not sustainable. Current 
problems like complexity, time-consuming 
implementation task, obsolete or non-
aligned measures with technology, lack of 
legal and regulatory clarity, increased 
proliferation of text etc. may only be 
resolved for the short to medium timeframe 
. For the mid to long term the same 
concerns as with option 1 may partly 
reappear.

Neutral  / No agreement in public 

Transparency

Bureaucratic burden

Democratic gap

Will final result of simplification of the 
current legal text and at the same 
time adding new measures to align 
with technical progress as end result 
truly simplify ?

Table 46: Analysis table policy options simplification 

Lack of Transparency was an issue for a minority of respondents to 
the public consultation, therefore was transparency rated neutral to 
Same argument as mentioned for transparency applicable for 
bureaucratic burden
Same argument as mentioned for transparency applicable for 
democratic gap
Technical standards meeting effort reduced for Industry/EU-27: not 
quantified; magnitude of change uncertain

Economies of scale: not quantified; will only lead to savings for 
OEMs if standard design can be sold in more countries

EN 

74 

   EN 

 
 
 
 
ANNEX XI: DETAILS CHAPTER 5 — IMPACT ANALYSIS VEHICLE TYPE APPROVAL ENVIRONMENTAL MEASURES 

1. 

NEW OR REVISED ENVIRONMENTAL MEASURES FOR THE TYPE APPROVAL OF NEW VEHICLES 

1.1. 

Revised lower emissions limits, detailed analysis of proposed limit by comparison with light duty M1 emission limits 

In the LAT report an overview of current European and global L-category vehicle emission limits were given. In the tables and graphs on the next pages the current 
emission limits and the different considered emission scenarios were summarised. The current and proposed limits were expressed as a percentage of Euro5 M1 
passenger cars (mainly gasoline (PI) cars, but if appropriate for e.g. 3- and 4 wheel vehicles also diesel (CI) cars. 

Emission thresholds overview (ALL in mg / km or in %)

Emission 
Scenario #

Label graphs

Vehicle Type Category

Number of 
wheels

Engine Type / 
Combustion 
Cycle

Euro 
level

THC 
(% of M1 
Euro5)

THC 

THC & NOx

THC & NOx
(% of M1 
Euro5 veh.)

CO

CO
(% of M1 
Euro5 
veh.)

NOx

NOx
(% of M1 
EU4 veh.)

NOx
(% of M1 
Euro5 / 
EU6 veh.)

PM (% of 
Euro5 
veh.)

PM

Approx. Type 
Approval entry

Classification criteria 
&
Comments

Test Cycle

0

1

2

2

4

4

1) 2W Mopeds, Euro2, 
Option 1

2) 2W Mopeds, Euro3, 
cold weighting, 2010, 
Option 2

3) 2W Mopeds, Euro3, 
cold weighting, 2012, 
Option 3

4) 2W Mopeds, Euro4, 
cold weighting, 2015, 
Option 3

Moped

Moped

L1

L1 

Moped

L1 

Moped

L1 

2

2

2

2

PI  / 4S

2

PI  / 4S

[3]

PI  / 4S

[3]

PI  / 4S

[4]

-

-

-

-

-

-

-

-

1200

750%

1000

100%

1200

750%

1000

100%

1200

750%

1000

100%

800

500%

1000

100%

-

-

-

-

-

-

-

-

-

-

-

-

8) 2W&3W Mopeds, 
Euro3, cold weighting, 
2013, Option 5 

9) 2W&3W Mopeds, 
Euro4, cold weighting, 
2016, Option 5 

Two & Three-
wheel Moped

Two & Three-
wheel Moped

L1 & L2

2 & 3

PI  / 4S

[3]

165

165%

L1 & L2

2 & 3

PI  / 4S

[4]

100

100%

-

-

-

-

1140

114%

88

110%

147%

1000

100%

75%

100%

-

-

-

-

-

-

-

-

-

-

-

-

17/06/2002

PI & <50cc

ECE R47

01/01/2010

PI & <50cc

[01/01/2012]

PI & <50cc

[01/01/2015]

PI & <50cc

01/01/2013

PI & <50cc

01/01/2016

PI & <50cc

ECE R47 & 
cold weighting

ECE R47 & 
cold weighting

ECE R47 & 
cold weighting

ECE R47 & 
cold weighting

WMTC, 
adapted

75%

100%

5

100%

01/09/2011

PI

NEDC

Ref.

Reference PI   Passenger 
Car, M1, PI, Euro5

Passenger Car

M1

0

2

2

4

4

5) 3W Mopeds, Euro2, 
Option 1

Moped

6) 3W Mopeds, Euro3, 
cold weighting, 2012, 
Option 3

Three-wheel 
Moped

7) 3W Mopeds, Euro4, 
cold weighting, 2015, 
Option 3 

Three-wheel 
Moped

8) 2W&3W Mopeds, 
Euro3, cold weighting, 
2013, Option 5 

9) 2W&3W Mopeds, 
Euro4, cold weighting, 
2016, Option 5 

Two & Three-
wheel Moped

Two & Three-
wheel Moped

4

3

3

3

PI  / 4S

PI  / 4S

PI  / 4S

5

2

3

PI  / 4S

[4]

100

100%

160

100%

1000

100%

-

-

-

-

-

-

1200

750%

3500

350%

1200

750%

3500

350%

900

563%

1900

190%

L2

L2

L2

-

-

-

-

-

-

L1 & L2

2 & 3

PI  / 4S

[3]

165

165%

L1 & L2

2 & 3

PI  / 4S

[4]

100

100%

-

-

-

-

1140

114%

88

110%

147%

1000

100%

75%

100%

-

-

-

-

-

-

-

-

-

-

17/06/2002

PI & <50cc

ECE R47

[01/01/2012]

PI & <50cc

[01/01/2015]

PI & <50cc

01/01/2013

PI & <50cc

01/01/2016

PI & <50cc

ECE R47 & 
cold weighting

ECE R47 & 
cold weighting

ECE R47 & 
cold weighting

WMTC, 
adapted

60

60

-

-

-

60

60

Ref.

Reference PI   Passenger 
Car, M1, PI, Euro5

Passenger Car

M1

4

PI  / 4S

5

100

100%

160

100%

1000

100%

Table 47: Overview current, proposed and bench mark emission limits for 2 & 3 wheel Mopeds (classes L1e & L2e) 

75%

100%

5

100%

01/09/2011

PI

NEDC

#

1

2

3

4

8

9

5

6

7

8

9

EN 

75 

EN 

 
  
 
i

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 [% of Euro5  M1 PI Passenger Car threshold]

1
0
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2
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3
0
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4
0
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5
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1
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1) 2W Mopeds, Euro2,
Option 1

100%

2) 2W Mopeds, Euro3,
cold weighting, 2010,
Option 2

100%

T
H
C

T
H
C
&
N
O
x

3) 2W Mopeds, Euro3,
cold weighting, 2012,
Option 3

C
O

100%

750%

750%

750%

4) 2W Mopeds, Euro4,
cold weighting, 2015,
Option 3

100%

500%

8) 2W&3W Mopeds,
Euro3, cold weighting,
2013, Option 5 

9) 2W&3W Mopeds,
Euro4, cold weighting,
2016, Option 5 

Reference PI  
Passenger Car, M1, PI,
Euro5

165%

114%

147%

100%

100%

100%

100%

(100%)

100%

100%

100%

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 [% of Euro5  M1 PI Passenger Car threshold]

1
0
0
%

2
0
0
%

3
0
0
%

4
0
0
%

5
0
0
%

6
0
0
%

7
0
0
%

8
0
0
%

9
0
0
%

0
%

1
0
0
0
%

5) 3W Mopeds, Euro2,
Option 1

6) 3W Mopeds, Euro3,
cold weighting, 2012,
Option 3

350%

350%

750%

750%

7) 3W Mopeds, Euro4,
cold weighting, 2015,
Option 3 

190%

5
6
3
%

8) 2W&3W Mopeds,
Euro3, cold weighting,
2013, Option 5 

165%

114%

147%

9) 2W&3W Mopeds,
Euro4, cold weighting,
2016, Option 5 

Reference PI  
Passenger Car, M1, PI,
Euro5

100%

100%

100%

100%

100%

100%

100%

100%

[

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E
N

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Emission thresholds overview (ALL in mg / km or in %)

Emission 
Scenario #

Label graphs

Vehicle Type Category

Number of 
wheels

Engine Type / 
Combustion 
Cycle

Euro 
level

THC 
(% of M1 
Euro5)

THC 

THC & NOx

THC & NOx
(% of M1 
Euro5 veh.)

CO

CO
(% of M1 
Euro5 
veh.)

NOx

NOx
(% of M1 
EU4 veh.)

NOx
(% of M1 
Euro5 / 
EU6 veh.)

PM (% of 
Euro5 
veh.)

PM

Approx. Type 
Approval entry

Classification criteria 
&
Comments

Test Cycle

Motorcycle

L3 & L4

2 (3)

PI  / 4S

Motorcycle

L3 & L4

2 (3)

PI  / 4S

Motorcycle

L3 & L4

2 (3)

PI  / 4S

Motorcycle

L3 & L4

2 (3)

PI  / 4S

3

3

3

3

800

800%

300

300%

750

750%

330

330%

Motorcycle

L3 & L4

2 (3)

PI  / 4S

[4]

630

630%

Motorcycle

L3 & L4

2 (3)

PI  / 4S

[4]

228

228%

-

-

-

-

-

-

-

-

-

-

-

-

2000

200%

150

188%

250%

2000

200%

150

188%

250%

2620

262%

170

213%

283%

2620

262%

220

275%

367%

1570

157%

94

118%

157%

1380

138%

110

138%

183%

Motorcycle

L3 & L4

2 (3)

PI  / 2S

[4]

-

-

691

432%

1965

197%

-

-

-

Motorcycle

L3 & L4

2 (3)

PI  / 4S

[4]

563

563%

-

-

1965

197%

128

160%

213%

Motorcycle

L3 & L4

2 (3)

PI  / 2S

[4]

-

-

413

258%

1965

197%

-

-

-

Motorcycle

L3 & L4

2 (3)

PI  / 4S

[4]

248

248%

-

-

1965

197%

165

206%

275%

Motorcycle

L3 & L4

2 (3)

PI  / 2S

[5]

-

-

443

277%

570

57%

-

-

-

Motorcycle

L3 & L4

2 (3)

PI  / 4S

[5]

375

375%

-

-

1139.7

114%

68

85%

113%

Motorcycle

L3 & L4

2 (3)

PI  / 2S

[5]

-

-

253

158%

1140

114%

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

01/01/2006

PI & < 150cc

ECE R40

01/01/2007

PI & ≥ 150cc

ECE R40 + 
EUDC (120 
km/h)

01/01/2007

PI, < 130 km/h

WMTC, ph1

01/01/2007

PI, ≥ 130 km/h

WMTC, ph1

01/01/2010

PI, < 130 km/h

WMTC, ph2

01/01/2010

PI, 150-750 cc

WMTC, ph2

[01/01/2012]

PI, 2S, < 130 km/h

WMTC, ph2

[01/01/2012]

PI, 4S, < 130 km/h

WMTC, ph2

[01/01/2012]

PI, 2S, ≥ 130 km/h

WMTC, ph2

[01/01/2012]

PI, 4S, ≥ 130 km/h

WMTC, ph2

[01/01/2015]

PI, 2S, < 130 km/h

WMTC, ph2

[01/01/2015]

PI, 4S, < 130 km/h

WMTC, ph2

[01/01/2015]

PI, 2S, ≥ 130 km/h

WMTC, ph2

[01/01/2015]

PI, 4S, ≥ 130 km/h

WMTC, ph2

#

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10) 2W Motorcycle, < 
150cc, Euro3, EDC, 
Option 1

11) 2W Motorcycle, L3& 
L4 ≥ 150cc Euro3, EDC, 
Option 1

12) 2W Motorcycle, vmax, 
< 130 km/h, Euro3, 
WMTC, Option 1

13) 2W Motorcycles, 
vmax, ≥ 130 km/h, Euro3, 
WMTC, Option 1

14) 2W Motorcycles, < 
130 km/h, Euro3, WMTC, 
2010, Option 4

15) 2W Motorcycles, 
vmax, ≥ 130 km/h, Euro3, 
WMTC, 2010, Option 4

16) 2W 2S Motorcycles, 
Euro4, 2012, < 130 km/h, 
Option 3

17) 2W 4S Motorcycles, 
Euro4, 2012, < 130 km/h, 
Option 3

18) 2W 2S Motorcycles, 
Euro4, 2012,  ≥ 130 km/h, 
Option 3

19) 2W 4S Motorcycles, 
Euro4, 2012,  ≥ 130 km/h, 
Option 3

20) 2W 2S Motorcycles, 
Euro 5, 2015, < 130 km/h, 
Option 3

21) 2W 4S Motorcycles, 
Euro 5, 2015, < 130 km/h, 
Option 3

22) 2W 2S Motorcycles, 
Euro 5, 2015, ≥ 130 km/h, 
Option 3

23) 2W 4S Motorcycles, 
Euro 5, 2015, ≥ 130 km/h, 
Option 3

0

0

0

0

3

3

2

2

2

2

2

2

2

2

4

4

Motorcycle

L3 & L4

2 (3)

PI  / 4S

[5]

165

165%

1140

114%

88

110%

147%

24) 2W & 3W 
Motorcycles, Euro4, 2013, 
WMTC, Option 5 

Motorcycle & 
Tricycle

L3 & L4 & 
L5

25) 2W & 3W 
Motorcycles, Euro5, 2016, 
WMTC, Option 5 

Motorcycle & 
Tricycle

L3 & L4 & 
L5

2 (3)

PI & CI  / 4S

[4]

165

165%

2 (3)

PI & CI / 4S

[5]

100

100%

-

-

-

-

-

-

1140

114%

88

110%

147%

25

500%

01/01/2013

PI & CI, PM for CI only WMTC, ph2

1000

100%

60

75%

100%

5

5

100%

01/01/2016

PI & CI, PM for CI only WMTC, ph2

100%

01/09/2011

PI

NEDC

Table 48: Overview current, proposed and bench mark emission limits for 2 wheel motorcycles (classes L3e & L4e) 

Ref.

Reference PI   Passenger 
Car, M1, PI, Euro5

Passenger Car

M1

4

PI  / 4S

5

100

100%

160

100%

1000

100%

60

75%

100%

EN 

78 

EN 

 
  
 
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,

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o
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2
w
h
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m
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y
c
l
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s
(
c
l
a
s
s
L
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e
)

a
n
d
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o
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c
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c
l
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s
w

i
t
h
s
i
d
e
c
a
r

(
c

l

a
s
s
L
4
e
)

 [% of Euro5  M1 PI Passenger Car threshold]

1
0
0
%

2
0
0
%

3
0
0
%

4
0
0
%

5
0
0
%

6
0
0
%

7
0
0
%

8
0
0
%

9
0
0
%

0
%

1
0
0
0
%

10) 2W Motorcycle, <
150cc, Euro3, EDC,
Option 1

11) 2W Motorcycle, L3&
L4 ≥ 150cc Euro3, EDC,
Option 1

12) 2W Motorcycle, vmax,
< 130 km/h, Euro3,
WMTC, Option 1

13) 2W Motorcycles,
vmax, ≥ 130 km/h, Euro3,
WMTC, Option 1

14) 2W Motorcycles, <
130 km/h, Euro3, WMTC,
2010, Option 4

15) 2W Motorcycles,
vmax, ≥ 130 km/h, Euro3,
WMTC, 2010, Option 4

16) 2W 2S Motorcycles,
Euro4, 2012, < 130 km/h,
Option 3

17) 2W 4S Motorcycles,
Euro4, 2012, < 130 km/h,
Option 3

18) 2W 2S Motorcycles,
Euro4, 2012,  ≥ 130 km/h,
Option 3

19) 2W 4S Motorcycles,
Euro4, 2012,  ≥ 130 km/h,
Option 3

20) 2W 2S Motorcycles,
Euro 5, 2015, < 130 km/h,
Option 3

21) 2W 4S Motorcycles,
Euro 5, 2015, < 130 km/h,
Option 3

22) 2W 2S Motorcycles,
Euro 5, 2015, ≥ 130 km/h,
Option 3

23) 2W 4S Motorcycles,
Euro 5, 2015, ≥ 130 km/h,
Option 3

24) 2W & 3W
Motorcycles, Euro4, 2013,
WMTC, Option 5 

25) 2W & 3W
Motorcycles, Euro5, 2016,
WMTC, Option 5 

Reference PI   Passenger
Car, M1, PI, Euro5

T
H
C

T
H
C
&
N
O
x

C
O

N
O
x

P
M

(

%
o
f

E
u
r
o
5

v
e
h
.
)

800%

750%

200%

250%

300%

200%

250%

262%

283%

330%

262%

367%

630%

432%

563%

157%
157%

228%

138%

183%

197%

197%

213%

258%

197%

248%

197%

275%

57%

277%

375%

114%
113%

158%

114%

165%

114%

147%

165%

114%

147%

100%
100%
100%

100%
100%
100%
100%

500%

[

%
o
f

E
u
r
o
5

M
1
P

I

P
a
s
s
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C
a
r

t
h
r
e
s
h
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]

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a
s
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3
&
L
4
,

2
-
w
h
e
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o
t
o
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c
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c
l
e

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w

i
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a
n
d
w

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o
u
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c
a
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)
,

o
v
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v
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w
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n
t

a
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p
r
o
p
o
s
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d

l
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m

i
t
s

E
N

7
9

E
N

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
#

26

28

29

24

25

27

30

31

24

25

Emission thresholds overview (ALL in mg / km or in %)

Emission 
Scenario #

Label graphs

Vehicle Type Category

Number of 
wheels

Engine Type / 
Combustion 
Cycle

Euro 
level

THC 
(% of M1 
Euro5)

THC 

THC & NOx

THC & NOx
(% of M1 
Euro5 veh.)

CO

CO
(% of M1 
Euro5 
veh.)

NOx

NOx
(% of M1 
EU4 veh.)

NOx
(% of M1 
Euro5 / 
EU6 veh.)

PM (% of 
Euro5 
veh.)

PM

Approx. Type 
Approval entry

Classification criteria 
&
Comments

0

2

2

4

4

26) 3W Motorcycles, PI, 
Euro2, EDC, Option 1

Tricycle

L5

28) 3W Motorcycles PI, 
Euro 3, 2012, EDC, 
Option 3

29) 3W Motorcycles, PI, 
Euro 4, 2015, EDC, 
Option 3

Tricycle

L5

Tricycle

L5

3

3

3

PI  / 4S

2

1500

1500%

PI  / 4S

[3]

1000

1000%

PI  / 4S

[4]

550

550%

24) 2W & 3W 
Motorcycles, Euro4, 2013, 
WMTC, Option 5 

Motorcycle & 
Tricycle

L3 & L4 & 
L5

25) 2W & 3W 
Motorcycles, Euro5, 2016, 
WMTC, Option 5 

Motorcycle & 
Tricycle

L3 & L4 & 
L5

2 (3)

PI & CI  / 4S

[4]

165

165%

2 (3)

PI & CI / 4S

[5]

100

100%

-

-

-

-

-

-

-

-

-

-

7000

700%

400

500%

667%

4000

400%

250

313%

417%

2000

200%

250

313%

417%

-

-

-

01/01/2003

[01/01/2012]

[01/01/2015]

PI

PI

PI

Test Cycle

ECE R40

ECE R40

ECE R40

1140

114%

88

110%

147%

25

500%

01/01/2013

PI & CI, PM for CI only WMTC, ph2

1000

100%

60

75%

100%

100%

01/01/2016

PI & CI, PM for CI only WMTC, ph2

PI  / 4S

CI  / 4S

5

2

100

100%

160

100%

1000

100%

60

75%

100%

1000

2000%

2000

400%

650

361%

361%

5

5

-

100%

01/09/2011

01/01/2003

CI  / 4S

[3]

150

300%

CI  / 4S

[4]

100

200%

1000

200%

650

361%

361%

100

2000%

[01/01/2012]

600

120%

550

306%

306%

80

1600%

01/01/2015

PI

CI

CI

CI

NEDC

ECE R40

ECE R40

ECE R40

4

3

3

3

Ref.

Reference PI   Passenger 
Car, M1, PI, Euro5

Passenger Car

M1

0

2

2

4

4

27) 3W Motorcycles, CI, 
Euro2, EDC, Option 1

Tricycle

L5

30) 3W Motorcycle CI, 
Euro 3, 2012, EDC, 
Option 3

31) 3W Motorcycles CI, 
Euro 4, 2015, EDC, 
Option 3

Tricycle

L5

Tricycle

L5

24) 2W & 3W 
Motorcycles, Euro4, 2013, 
WMTC, Option 5 

Motorcycle & 
Tricycle

L3 & L4 & 
L5

25) 2W & 3W 
Motorcycles, Euro5, 2016, 
WMTC, Option 5 

Motorcycle & 
Tricycle

L3 & L4 & 
L5

2 (3)

PI & CI  / 4S

[4]

165

165%

2 (3)

PI & CI / 4S

[5]

100

100%

1140

114%

88

110%

147%

25

500%

01/01/2013

PI & CI, PM for CI only WMTC, ph2

1000

100%

60

75%

100%

5

5

100%

01/01/2016

PI & CI, PM for CI only WMTC, ph2

100%

01/09/2011

CI

NEDC

Ref.

Reference CI   Passenger 
Car, M1, CI, Euro5

Passenger Car

M1

4

CI  / 4S

5

50

100%

230

100%

500

100%

180

100%

100%

Table 49: Overview current, proposed and bench mark emission limits for 3 wheel motorcycles (Tricycles, class L5e) 

-

-

-

-

-

-

-

-

-

-

EN 

80 

EN 

 
  
 
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.
)

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N

8
1

E
N

 [% of EU5  M1 PI / CI Passenger Car threshold]

1
0
0
%

2
0
0
%

3
0
0
%

4
0
0
%

5
0
0
%

6
0
0
%

7
0
0
%

8
0
0
%

9
0
0
%

0
%

700%

667%

400%

417%

550%

200%

417%

26) 3W Motorcycles, PI,
Euro2, EDC, Option 1

28) 3W Motorcycles PI,
Euro 3, 2012, EDC,
Option 3

29) 3W Motorcycles, PI,
Euro 4, 2015, EDC,
Option 3

24) 2W & 3W
Motorcycles, Euro4,
2013, WMTC, Option 5 

25) 2W & 3W
Motorcycles, Euro5,
2016, WMTC, Option 5 

Reference PI  
Passenger Car, M1, PI,
Euro5

27) 3W Motorcycles, CI,
Euro2, EDC, Option 1

30) 3W Motorcycle CI,
Euro 3, 2012, EDC,
Option 3

165%

114%

147%

100%

100%
100%
100%

100%

100%
100%
100%

400%

361%

300%

361%

200%

200%

500%

500%

31) 3W Motorcycles CI,
Euro 4, 2015, EDC,
Option 3

120%

306%

24) 2W & 3W
Motorcycles, Euro4,
2013, WMTC, Option 5 

25) 2W & 3W
Motorcycles, Euro5,
2016, WMTC, Option 5 

Reference CI  
Passenger Car, M1, CI,
Euro5

165%

114%

147%

100%

100%
100%
100%

100%
100%
100%
100%
100%

1
0
0
0
%

1500

1000%

[

%
o
f

E
U
5

M
1
P

I

/

C

I

P
a
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C
a
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5
,

3
-
w
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l

M
o
t
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(
T
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)
,

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l
i

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i
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s

2000%

1600%

1600%

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Emission thresholds overview (ALL in mg / km or in %)

Emission 
Scenario #

Label graphs

Vehicle Type Category

Number of 
wheels

Engine Type / 
Combustion 
Cycle

Euro 
level

THC 
(% of M1 
Euro5)

THC 

THC & NOx

THC & NOx
(% of M1 
Euro5 veh.)

CO

CO
(% of M1 
Euro5 
veh.)

NOx

NOx
(% of M1 
EU4 veh.)

NOx
(% of M1 
Euro5 / 
EU6 veh.)

PM (% of 
Euro5 
veh.)

PM

Approx. Type 
Approval entry

Classification criteria 
&
Comments

Test Cycle

#

32

33

34

35

36

37

39

41

43

44

38

40

42

45

46

0

2

2

4

4

32) 4W, Light 
Quadricycle, Euro2, 
Option 1

33) 4W, Light 
Quadricycle, Euro 3, 
2012, Option 3 

34) 4W, Light 
Quadricycle, Euro 4, 
2015, Option 3 

35) 4W, Light 
Quadricycle, Euro3, PI, 
2013, Option 5

36) 4W, Light 
Quadricycle, Euro4, PI, 
2016, Option 5

Light Quadricycle

L6

Light Quadricycle

L6

Light Quadricycle

L6

Light Quadricycle

L6

Light Quadricycle

L6

Ref.

Reference PI   Passenger 
Car, M1, PI, Euro5

Passenger Car

M1

0

2

2

4

4

37) 4W, Heavy 
Quadricycle, Euro2, PI, 
Option 1

Heavy 
Quadricycle

39) 4W, Heavy 
Quadricycle, Euro 3, PI, 
2012, Option 3

Heavy 
Quadricycle

41) 4W, Heavy 
Quadricycle, Euro 4, PI, 
2015, Option 3

Heavy 
Quadricycle

43) 4W, Heavy 
Quadricycle, Euro3, PI, 
2013, Option 5

Heavy 
Quadricycle

44) 4W, Heavy 
Quadricycle, Euro4, PI, 
2016, Option 5

Heavy 
Quadricycle

L7

L7

L7

L7

L7

Ref.

Reference PI   Passenger 
Car, M1, PI, Euro5

Passenger Car

M1

0

2

2

4

4

38) 4W, Heavy 
Quadricycle, Euro2, CI, 
Option 1

Heavy 
Quadricycle

40) 4W, Heavy 
Quadricycle, Euro 3, 
Option 3 , CI, 2012, 
Option 3

Heavy 
Quadricycle

42) 4W, Heavy 
Quadricycle, Euro 4, CI, 
2015, Option 3

Heavy 
Quadricycle

45) 4W, Heavy 
Quadricycle, Euro3, CI, 
2013, Option 5

Heavy 
Quadricycle

46) 4W, Heavy 
Quadricycle, Euro4, CI, 
2016, Option 5

Heavy 
Quadricycle

L7

L7

L7

L7

L7

Ref.

Reference CI   Passenger 
Car, M1, CI, Euro5

Passenger Car

M1

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

PI  / 4S

2

PI  / 4S

[3]

PI  / 4S

[4]

-

-

-

-

-

-

1200

750%

3500

350%

1200

750%

3500

350%

900

563%

1900

190%

-

-

-

-

-

-

-

-

-

PI & CI  / 4S

[3]

165

165%

PI & CI  / 4S

[4]

100

100%

-

-

-

-

1140

114%

88

110%

147%

1000

100%

60

75%

100%

-

-

-

-

-

-

-

-

-

-

[01/01/2012]

PI & <50cc

[01/01/2015]

PI & <50cc

01/01/2013

PI & <50cc

01/01/2016

PI & <50cc

01/01/2003

PI & <50cc

ECE R47

100

100%

160

100%

1000

100%

60

75%

100%

5

100%

01/09/2011

PI  / 4S

PI  / 4S

5

2

1500

1500%

PI  / 4S

[3]

1000

1000%

PI  / 4S

[4]

550

550%

PI / 4S

[3]

165

165%

PI & CI / 4S

[4]

100

100%

PI  / 4S

CI  / 4S

5

2

CI  / 4S

[3]

150

300%

CI  / 4S

[4]

100

200%

CI  / 4S

[3]

CI  / 4S

[4]

-

-

-

-

-

-

-

-

-

-

-

-

-

-

7000

700%

400

500%

667%

4000

400%

250

313%

417%

2000

200%

250

313%

417%

1140

114%

88

110%

147%

1000

100%

60

75%

100%

-

-

-

-

-

5

-

-

-

-

-

-

01/01/2003

[01/01/2012]

[01/01/2015]

01/01/2013

01/01/2016

100%

01/09/2011

-

01/01/2003

100

100%

160

100%

1000

100%

60

75%

100%

1000

2000%

2000

400%

650

361%

361%

-

-

-

-

-

-

1000

200%

650

361%

361%

100

2000%

[01/01/2012]

600

120%

550

306%

306%

80

1600%

[01/01/2015]

300

130%

1000

200%

250

139%

139%

25

500%

01/01/2013

CI  / 4S

5

50

100%

230

100%

500

100%

180

100%

100%

230

100%

500

100%

180

100%

100%

5

5

100%

01/01/2016

100%

01/09/2011

PI

PI

PI

PI

PI

PI

PI

CI

CI

CI

CI

CI

CI

ECE R47 & 
cold

ECE R47 & 
cold

ECE R47 & 
cold

WMTC, 
adapted

NEDC

ECE R40

ECE R40

ECE R40

WMTC ph2

WMTC ph2

NEDC

ECE R40

ECE R40

ECE R40

WMTC ph2

WMTC ph2

NEDC

Table 50: Overview current, proposed and bench mark emission limits for Light quadricycles (class L6e) and heavy Quadricycles (class L7e) 

EN 

82 

EN 

 
  
 
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 [% of Euro5  M1 PI Passenger Car threshold]

1
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2
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3
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4
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6
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32) 4W, Light
Quadricycle, Euro2,
Option 1

33) 4W, Light
Quadricycle, Euro 3,
2012, Option 3 

750%

750%

350%

350%

34) 4W, Light
Quadricycle, Euro 4,
2015, Option 3 

190%

563%

165%

114%

35) 4W, Light
Quadricycle, Euro3, PI,
2013, Option 5

36) 4W, Light
Quadricycle, Euro4, PI,
2016, Option 5

Reference PI  
Passenger Car, M1, PI,
Euro5

100%

100%

100%

100%

100%

100%

100%

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[mg/km]

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2
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3
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4
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5
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37) 4W, Heavy
Quadricycle, Euro2, PI,
Option 1

39) 4W, Heavy
Quadricycle, Euro 3, PI,
2012, Option 3

41) 4W, Heavy
Quadricycle, Euro 4, PI,
2015, Option 3

43) 4W, Heavy
Quadricycle, Euro3, PI,
2013, Option 5

C
O

44) 4W, Heavy
Quadricycle, Euro4, PI,
2016, Option 5

Reference PI  
Passenger Car, M1, PI,
Euro5

N
O
x

38) 4W, Heavy
Quadricycle, Euro2, CI,
Option 1

40) 4W, Heavy
Quadricycle, Euro 3,
Option 3 , CI, 2012,
Option 3

700%

667%

400%

417%

550%

200%

417%

165%

114%

147%

100%

100%
100%

100%
(100%)
100%
100%
100%

400%

361%

300%

200%

361%

N
O
x

42) 4W, Heavy
Quadricycle, Euro 4, CI,
2015, Option 3

120%

306%

45) 4W, Heavy
Quadricycle, Euro3, CI,
2013, Option 5

130%

200%

139%

500%

46) 4W, Heavy
Quadricycle, Euro4, CI,
2016, Option 5

Reference CI  
Passenger Car, M1, CI,
Euro5

100%
100%
100%

100%
100%
100%
100%

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THC thresholds [% of Euro5 M1 PI / CI Passenger Car threshold]

2
0
0
%

4
0
0
%

6
0
0
%

8
0
0
%

0
%

1
0
0
0
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1
2
0
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1
4
0
0
%

1
6
0
0
%

1
8
0
0
%

2
0
0
0
%

1) 2W Mopeds, Euro2, Option 1

2) 2W Mopeds, Euro3, cold weighting, 2010, Option 2

3) 2W Mopeds, Euro3, cold weighting, 2012, Option 3

4) 2W Mopeds, Euro4, cold weighting, 2015, Option 3

5) 3W Mopeds, Euro2, Option 1

6) 3W Mopeds, Euro3, cold weighting, 2012, Option 3

7) 3W Mopeds, Euro4, cold weighting, 2015, Option 3 

8) 2W&3W Mopeds, Euro3, cold weighting, 2013, Option 5 

9) 2W&3W Mopeds, Euro4, cold weighting, 2016, Option 5 

165%

100%

10) 2W Motorcycle, < 150cc, Euro3, EDC, Option 1

11) 2W Motorcycle, L3& L4 ≥ 150cc Euro3, EDC, Option 1
12) 2W Motorcycle, vmax, < 130 km/h, Euro3, WMTC, Option
1
13) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3, WMTC, Option
1
14) 2W Motorcycles, < 130 km/h, Euro3, WMTC, 2010, Option
4
15) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3, WMTC, 2010,
Option 4

16) 2W 2S Motorcycles, Euro4, 2012, < 130 km/h, Option 3

800%

750%

630%

300%

330%

228%

17) 2W 4S Motorcycles, Euro4, 2012, < 130 km/h, Option 3

563%

18) 2W 2S Motorcycles, Euro4, 2012,  ≥ 130 km/h, Option 3

19) 2W 4S Motorcycles, Euro4, 2012,  ≥ 130 km/h, Option 3

248%

20) 2W 2S Motorcycles, Euro 5, 2015, < 130 km/h, Option 3

21) 2W 4S Motorcycles, Euro 5, 2015, < 130 km/h, Option 3

375%

22) 2W 2S Motorcycles, Euro 5, 2015, ≥ 130 km/h, Option 3

23) 2W 4S Motorcycles, Euro 5, 2015, ≥ 130 km/h, Option 3

24) 2W & 3W Motorcycles, Euro4, 2013, WMTC, Option 5 

25) 2W & 3W Motorcycles, Euro5, 2016, WMTC, Option 5 

165%

165%

100%

26) 3W Motorcycles, PI, Euro2, EDC, Option 1

27) 3W Motorcycles, CI, Euro2, EDC, Option 1

1500%

2000%

28) 3W Motorcycles PI, Euro 3, 2012, EDC, Option 3

1000%

29) 3W Motorcycles, PI, Euro 4, 2015, EDC, Option 3

550%

30) 3W Motorcycle CI, Euro 3, 2012, EDC, Option 3

31) 3W Motorcycles CI, Euro 4, 2015, EDC, Option 3

300%

200%

32) 4W, Light Quadricycle, Euro2, Option 1

33) 4W, Light Quadricycle, Euro 3, 2012, Option 3 

34) 4W, Light Quadricycle, Euro 4, 2015, Option 3 

35) 4W, Light Quadricycle, Euro3, PI, 2013, Option 5

36) 4W, Light Quadricycle, Euro4, PI, 2016, Option 5

165%

100%

37) 4W, Heavy Quadricycle, Euro2, PI, Option 1

38) 4W, Heavy Quadricycle, Euro2, CI, Option 1

39) 4W, Heavy Quadricycle, Euro 3, PI, 2012, Option 3
40) 4W, Heavy Quadricycle, Euro 3, Option 3 , CI, 2012,
Option 3
41) 4W, Heavy Quadricycle, Euro 4, PI, 2015, Option 3

1000%

300%

550%

1500%

2000%

42) 4W, Heavy Quadricycle, Euro 4, CI, 2015, Option 3

43) 4W, Heavy Quadricycle, Euro3, PI, 2013, Option 5

200%

165%

44) 4W, Heavy Quadricycle, Euro4, PI, 2016, Option 5

100%

45) 4W, Heavy Quadricycle, Euro3, CI, 2013, Option 5

46) 4W, Heavy Quadricycle, Euro4, CI, 2016, Option 5

Passenger Car, M1, PI, Euro4

Reference PI   Passenger Car, M1, PI, Euro5

Passenger Car, M1, PI, Euro6

Passenger Car, M1, CI, Euro4

Reference CI   Passenger Car, M1, CI, Euro5

100%

100%

100%

100%

Passenger Car, M1, CI, Euro6

180%

T
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5

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THC & NOx [% of  Euro5 M1 PI / CI Passenger Car threshold]

1
0
0
%

2
0
0
%

3
0
0
%

4
0
0
%

5
0
0
%

6
0
0
%

7
0
0
%

8
0
0
%

9
0
0
%

0
%

1
0
0
0
%

1) 2W Mopeds, Euro2, Option 1

2) 2W Mopeds, Euro3, cold weighting, 2010, Option 2

3) 2W Mopeds, Euro3, cold weighting, 2012, Option 3

4) 2W Mopeds, Euro4, cold weighting, 2015, Option 3

5) 3W Mopeds, Euro2, Option 1

6) 3W Mopeds, Euro3, cold weighting, 2012, Option 3

7) 3W Mopeds, Euro4, cold weighting, 2015, Option 3 

8) 2W&3W Mopeds, Euro3, cold weighting, 2013,

9) 2W&3W Mopeds, Euro4, cold weighting, 2016,

10) 2W Motorcycle, < 150cc, Euro3, EDC, Option 1

11) 2W Motorcycle, L3& L4 ≥ 150cc Euro3, EDC,

12) 2W Motorcycle, vmax, < 130 km/h, Euro3, WMTC,

13) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3,

14) 2W Motorcycles, < 130 km/h, Euro3, WMTC,

15) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3,

16) 2W 2S Motorcycles, Euro4, 2012, < 130 km/h,

17) 2W 4S Motorcycles, Euro4, 2012, < 130 km/h,

18) 2W 2S Motorcycles, Euro4, 2012,  ≥ 130 km/h,

19) 2W 4S Motorcycles, Euro4, 2012,  ≥ 130 km/h,

20) 2W 2S Motorcycles, Euro 5, 2015, < 130 km/h,

21) 2W 4S Motorcycles, Euro 5, 2015, < 130 km/h,

750%

750%

750%

750%

750%

500%

563%

432%

258%

277%

750%
750%

563%

22) 2W 2S Motorcycles, Euro 5, 2015, ≥ 130 km/h,

158%

23) 2W 4S Motorcycles, Euro 5, 2015, ≥ 130 km/h,

24) 2W & 3W Motorcycles, Euro4, 2013, WMTC,

25) 2W & 3W Motorcycles, Euro5, 2016, WMTC,

26) 3W Motorcycles, PI, Euro2, EDC, Option 1

27) 3W Motorcycles, CI, Euro2, EDC, Option 1

28) 3W Motorcycles PI, Euro 3, 2012, EDC, Option 3

29) 3W Motorcycles, PI, Euro 4, 2015, EDC, Option 3

30) 3W Motorcycle CI, Euro 3, 2012, EDC, Option 3

31) 3W Motorcycles CI, Euro 4, 2015, EDC, Option 3

32) 4W, Light Quadricycle, Euro2, Option 1

33) 4W, Light Quadricycle, Euro 3, 2012, Option 3 

34) 4W, Light Quadricycle, Euro 4, 2015, Option 3 

35) 4W, Light Quadricycle, Euro3, PI, 2013, Option 5

36) 4W, Light Quadricycle, Euro4, PI, 2016, Option 5

37) 4W, Heavy Quadricycle, Euro2, PI, Option 1

38) 4W, Heavy Quadricycle, Euro2, CI, Option 1

39) 4W, Heavy Quadricycle, Euro 3, PI, 2012, Option 3

40) 4W, Heavy Quadricycle, Euro 3, Option 3 , CI,

41) 4W, Heavy Quadricycle, Euro 4, PI, 2015, Option 3

42) 4W, Heavy Quadricycle, Euro 4, CI, 2015, Option 3

43) 4W, Heavy Quadricycle, Euro3, PI, 2013, Option 5

44) 4W, Heavy Quadricycle, Euro4, PI, 2016, Option 5

45) 4W, Heavy Quadricycle, Euro3, CI, 2013, Option 5

130%

46) 4W, Heavy Quadricycle, Euro4, CI, 2016, Option 5

Passenger Car, M1, PI, Euro4

Reference PI   Passenger Car, M1, PI, Euro5

Passenger Car, M1, PI, Euro6

Passenger Car, M1, CI, Euro4

Reference CI   Passenger Car, M1, CI, Euro5

100%

113%

100%

100%

100%

100%

Passenger Car, M1, CI, Euro6

74%

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3
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1) 2W Mopeds, Euro2, Option 1
2) 2W Mopeds, Euro3, cold weighting,
3) 2W Mopeds, Euro3, cold weighting,
4) 2W Mopeds, Euro4, cold weighting,
5) 3W Mopeds, Euro2, Option 1
6) 3W Mopeds, Euro3, cold weighting,
7) 3W Mopeds, Euro4, cold weighting,
8) 2W&3W Mopeds, Euro3, cold
9) 2W&3W Mopeds, Euro4, cold
10) 2W Motorcycle, < 150cc, Euro3,
11) 2W Motorcycle, L3& L4 ≥ 150cc
12) 2W Motorcycle, vmax, < 130 km/h,
13) 2W Motorcycles, vmax, ≥ 130
14) 2W Motorcycles, < 130 km/h,
15) 2W Motorcycles, vmax, ≥ 130
16) 2W 2S Motorcycles, Euro4, 2012, <
17) 2W 4S Motorcycles, Euro4, 2012, <
18) 2W 2S Motorcycles, Euro4, 2012, 
19) 2W 4S Motorcycles, Euro4, 2012, 
20) 2W 2S Motorcycles, Euro 5, 2015,
21) 2W 4S Motorcycles, Euro 5, 2015,
22) 2W 2S Motorcycles, Euro 5, 2015,
23) 2W 4S Motorcycles, Euro 5, 2015,
24) 2W & 3W Motorcycles, Euro4,
25) 2W & 3W Motorcycles, Euro5,
26) 3W Motorcycles, PI, Euro2, EDC,
27) 3W Motorcycles, CI, Euro2, EDC,
28) 3W Motorcycles PI, Euro 3, 2012,
29) 3W Motorcycles, PI, Euro 4, 2015,
30) 3W Motorcycle CI, Euro 3, 2012,
31) 3W Motorcycles CI, Euro 4, 2015,
32) 4W, Light Quadricycle, Euro2,
33) 4W, Light Quadricycle, Euro 3,
34) 4W, Light Quadricycle, Euro 4,
35) 4W, Light Quadricycle, Euro3, PI,
36) 4W, Light Quadricycle, Euro4, PI,
37) 4W, Heavy Quadricycle, Euro2, PI,
38) 4W, Heavy Quadricycle, Euro2, CI,
39) 4W, Heavy Quadricycle, Euro 3,
40) 4W, Heavy Quadricycle, Euro 3,
41) 4W, Heavy Quadricycle, Euro 4,
42) 4W, Heavy Quadricycle, Euro 4,
43) 4W, Heavy Quadricycle, Euro3, PI,
44) 4W, Heavy Quadricycle, Euro4, PI,
45) 4W, Heavy Quadricycle, Euro3, CI,
46) 4W, Heavy Quadricycle, Euro4, CI,
Passenger Car, M1, PI, Euro4
Reference PI   Passenger Car, M1, PI,
Passenger Car, M1, PI, Euro6
Passenger Car, M1, CI, Euro4
Reference CI   Passenger Car, M1, CI,
Passenger Car, M1, CI, Euro6

100%

100%

100%

100%

114%

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350%

350%

190%

200%

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262%

262%

157%

138%

197%

197%

197%

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114%

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1) 2W Mopeds, Euro2, Option 1

2) 2W Mopeds, Euro3, cold weighting, 2010, Option 2

3) 2W Mopeds, Euro3, cold weighting, 2012, Option 3

4) 2W Mopeds, Euro4, cold weighting, 2015, Option 3

5) 3W Mopeds, Euro2, Option 1

6) 3W Mopeds, Euro3, cold weighting, 2012, Option 3

7) 3W Mopeds, Euro4, cold weighting, 2015, Option 3 

8) 2W&3W Mopeds, Euro3, cold weighting, 2013,

147%

9) 2W&3W Mopeds, Euro4, cold weighting, 2016,

100%

10) 2W Motorcycle, < 150cc, Euro3, EDC, Option 1

11) 2W Motorcycle, L3& L4 ≥ 150cc Euro3, EDC,

12) 2W Motorcycle, vmax, < 130 km/h, Euro3, WMTC,

250%

250%

283%

13) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3, WMTC,

367%

14) 2W Motorcycles, < 130 km/h, Euro3, WMTC, 2010,

15) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3, WMTC,

157%

183%

16) 2W 2S Motorcycles, Euro4, 2012, < 130 km/h,

17) 2W 4S Motorcycles, Euro4, 2012, < 130 km/h,

18) 2W 2S Motorcycles, Euro4, 2012,  ≥ 130 km/h,

19) 2W 4S Motorcycles, Euro4, 2012,  ≥ 130 km/h,

20) 2W 2S Motorcycles, Euro 5, 2015, < 130 km/h,

213%

275%

21) 2W 4S Motorcycles, Euro 5, 2015, < 130 km/h,

113%

22) 2W 2S Motorcycles, Euro 5, 2015, ≥ 130 km/h,

23) 2W 4S Motorcycles, Euro 5, 2015, ≥ 130 km/h,

24) 2W & 3W Motorcycles, Euro4, 2013, WMTC,

147%
147%

25) 2W & 3W Motorcycles, Euro5, 2016, WMTC,

100%

26) 3W Motorcycles, PI, Euro2, EDC, Option 1

27) 3W Motorcycles, CI, Euro2, EDC, Option 1

28) 3W Motorcycles PI, Euro 3, 2012, EDC, Option 3

29) 3W Motorcycles, PI, Euro 4, 2015, EDC, Option 3

30) 3W Motorcycle CI, Euro 3, 2012, EDC, Option 3

31) 3W Motorcycles CI, Euro 4, 2015, EDC, Option 3

32) 4W, Light Quadricycle, Euro2, Option 1

33) 4W, Light Quadricycle, Euro 3, 2012, Option 3 

34) 4W, Light Quadricycle, Euro 4, 2015, Option 3 

35) 4W, Light Quadricycle, Euro3, PI, 2013, Option 5

147%

36) 4W, Light Quadricycle, Euro4, PI, 2016, Option 5

100%

37) 4W, Heavy Quadricycle, Euro2, PI, Option 1

38) 4W, Heavy Quadricycle, Euro2, CI, Option 1

39) 4W, Heavy Quadricycle, Euro 3, PI, 2012, Option 3

40) 4W, Heavy Quadricycle, Euro 3, Option 3 , CI,

41) 4W, Heavy Quadricycle, Euro 4, PI, 2015, Option 3

361%

417%
417%

361%

306%

361%

417%

361%

417%

42) 4W, Heavy Quadricycle, Euro 4, CI, 2015, Option 3

306%

43) 4W, Heavy Quadricycle, Euro3, PI, 2013, Option 5

44) 4W, Heavy Quadricycle, Euro4, PI, 2016, Option 5

45) 4W, Heavy Quadricycle, Euro3, CI, 2013, Option 5

46) 4W, Heavy Quadricycle, Euro4, CI, 2016, Option 5

Passenger Car, M1, PI, Euro4

Reference PI   Passenger Car, M1, PI, Euro5

Passenger Car, M1, PI, Euro6

Passenger Car, M1, CI, Euro4

Reference CI   Passenger Car, M1, CI, Euro5

147%

100%

139%

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1) 2W Mopeds, Euro2, Option 1

2) 2W Mopeds, Euro3, cold weighting, 2010, Option

3) 2W Mopeds, Euro3, cold weighting, 2012, Option

4) 2W Mopeds, Euro4, cold weighting, 2015, Option

5) 3W Mopeds, Euro2, Option 1

6) 3W Mopeds, Euro3, cold weighting, 2012, Option

7) 3W Mopeds, Euro4, cold weighting, 2015, Option

8) 2W&3W Mopeds, Euro3, cold weighting, 2013,

9) 2W&3W Mopeds, Euro4, cold weighting, 2016,

10) 2W Motorcycle, < 150cc, Euro3, EDC, Option 1

11) 2W Motorcycle, L3& L4 ≥ 150cc Euro3, EDC,

12) 2W Motorcycle, vmax, < 130 km/h, Euro3,

13) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3,

14) 2W Motorcycles, < 130 km/h, Euro3, WMTC,

15) 2W Motorcycles, vmax, ≥ 130 km/h, Euro3,

16) 2W 2S Motorcycles, Euro4, 2012, < 130 km/h,

17) 2W 4S Motorcycles, Euro4, 2012, < 130 km/h,

18) 2W 2S Motorcycles, Euro4, 2012,  ≥ 130 km/h,

19) 2W 4S Motorcycles, Euro4, 2012,  ≥ 130 km/h,

20) 2W 2S Motorcycles, Euro 5, 2015, < 130 km/h,

21) 2W 4S Motorcycles, Euro 5, 2015, < 130 km/h,

22) 2W 2S Motorcycles, Euro 5, 2015, ≥ 130 km/h,

23) 2W 4S Motorcycles, Euro 5, 2015, ≥ 130 km/h,

24) 2W & 3W Motorcycles, Euro4, 2013, WMTC,

500%

25) 2W & 3W Motorcycles, Euro5, 2016, WMTC,

100%

26) 3W Motorcycles, PI, Euro2, EDC, Option 1

27) 3W Motorcycles, CI, Euro2, EDC, Option 1

28) 3W Motorcycles PI, Euro 3, 2012, EDC, Option 3

29) 3W Motorcycles, PI, Euro 4, 2015, EDC, Option

30) 3W Motorcycle CI, Euro 3, 2012, EDC, Option 3

31) 3W Motorcycles CI, Euro 4, 2015, EDC, Option 3

32) 4W, Light Quadricycle, Euro2, Option 1

33) 4W, Light Quadricycle, Euro 3, 2012, Option 3 

34) 4W, Light Quadricycle, Euro 4, 2015, Option 3 

35) 4W, Light Quadricycle, Euro3, PI, 2013, Option 5

36) 4W, Light Quadricycle, Euro4, PI, 2016, Option 5

37) 4W, Heavy Quadricycle, Euro2, PI, Option 1

38) 4W, Heavy Quadricycle, Euro2, CI, Option 1

39) 4W, Heavy Quadricycle, Euro 3, PI, 2012, Option

40) 4W, Heavy Quadricycle, Euro 3, Option 3 , CI,

41) 4W, Heavy Quadricycle, Euro 4, PI, 2015, Option

42) 4W, Heavy Quadricycle, Euro 4, CI, 2015, Option

43) 4W, Heavy Quadricycle, Euro3, PI, 2013, Option

44) 4W, Heavy Quadricycle, Euro4, PI, 2016, Option

45) 4W, Heavy Quadricycle, Euro3, CI, 2013, Option

500%

46) 4W, Heavy Quadricycle, Euro4, CI, 2016, Option

100%

Passenger Car, M1, PI, Euro4

Reference PI   Passenger Car, M1, PI, Euro5

Passenger Car, M1, PI, Euro6

Passenger Car, M1, CI, Euro4

Reference CI   Passenger Car, M1, CI, Euro5

Passenger Car, M1, CI, Euro6

100%

100%

100%

100%

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2000%

1600%

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1.2. 

Qualitative analysis of the policy options to revise the emission limits 

Type of impact:

Economical
Environmental
Safety

Societal

Option 1: No change

Positive

Neutral  / Remarks

Compliance cost of manufacturers

Negative
Extreme high share of hydrocarbons (HC) emitted by L-
category vehicles (rising to 62% of total in 2020 if no new 
measures applied) compared to other means of road 
transport. Same for CO (rising to over 30% of total in 
2020). High share of urban PM emissions. L-category 
vehicles only responsible for 3% of total vehicle mileage, 
therefore level of emissions not proportional to level of 
use.

Emission reduction mandated for other means of road 
transport beyond 2020 will become marginal, if Mopeds 
and all other L-category vehicle type emissions not 
further reduced.

Table 51: Analysis table policy options new emission limits, option 1 

Option 2: : New emission limits for L1 mopeds: a cold-start r47 test cycle and a 30% weighing factor for the cold start are proposed to be applied. (Scenario 1 
from LAT report). No change in limits for other L-category vehicles.

Negative
All other categories of L-category vehicles which produce 
significant high emissions are not affected by the need to 
comply with lower limits. Current high overall pollution 
level for new L-category vehicles maintained. Adverse 
health and environmental effects by air pollution cannot 
be efficiently and effectively addressed. 

Scenario 1 achieves 2%, 7%, and 27% reduction in CO, 
HC, and PM respectively. NOx marginally increases.

Neutral  / Remarks
Effect of Type Approval threshold reduction on the 
overall level of pollutants is marginal in comparison 
to the highly polluting L-category vehicle fleet. The 
average vehicle replacement timeframe is much 
longer as for e.g. passenger cars. It takes much 
longer before the effect of new vehicles, which 
pollute less, becomes effective. The other road 
transport vehicles had to comply already 10 years 
ago with relatively severe type approval thresholds. 
The benefit of this early adoption becomes obvious 
owing to the significant overall pollutant reduction of 
all other vehicles (refer to figure 3.1 to 3.5 of the 
LAT report, p59 - 61

Emission reduction mandated for other means of road 
transport in 2020 will become marginal, if Mopeds and all 
other L-category vehicle type emissions not further 
reduced.

Minimised weaknesses and threads of the introduction of 
new emission limit values for L-category vehicles as 
identified in LAT report, ch. 3.3 (again listed under option 
3)

Positive
With minor modifications to the test cycle result analysis a 
fractional share of HC emissions can be reduced. 

Sensitivity study presented in MCWG of 29 June 09 
(EMISIA SA Report No: 09.RE.005.V2, Scenarios on the 
future regulation of Power Two Wheelers) showed that the 
threshold level has relatively little effect on total L-category 
vehicle emissions for the assessed timeframe until 2020. 
The speed of threshold introduction is the most important 
factor to reduce emissions on the mid to long term. Option 2 
can be fast introduced and is supported by the industry. If it 
would have been possible to extend the assessed 
timeframe up to 2030, this positive impact may have been a 
negative impact
Low cost scenario. With regard to HC and PM option 2 
appears as most cost-effective, but only 6,5% HC reduction 
achievable in 2020 leading to 60% of THC emission from all 
road transport in comparison to option 1, which would lead 
to 62% of total HC emissions from road transport. 

Only slight compliance cost increase for Moped 
manufacturers. For all other manufacturers no change in 
compliance cost compared to option 1.

Table 52: Analysis table policy options new emission limits, option 2 

EN 

90 

   EN 

 
 
 
 
 
Option 3: Motorcycle industry proposal (Scenario 2 from LAT report)

Positive

Negative

Using the strength of new emission limit values for L-
category vehicles as identified in the LAT report (ch. 3.3):
- reduction of harmful atmospheric substances  (HC, NOx, 
CO, PM) that directly affect a large fraction of the population
- reduction of harmful species that contribute to the 
formation of photochemical pollution (HC, NOx)
- minor reduction of greenhouse-gas (mainly CO2) 
emissions
- reduction of visible smoke

Current high overall pollution level for new L-category 
vehicles maintained as this can only be very little 
influenced by type approval compliance with low 
thresholds. Adverse health and environmental effects by 
air pollution cannot be efficiently and effectively 
addressed. 

Option 3 leads to 16%, 15%, 37% and 27% reductions in 
CO, HC, PM, and NOx, respectively. 

Neutral  / Remarks
Effect of Type Approval threshold reduction on the 
overall level of pollutants is marginal in comparison 
to the highly polluting L-category vehicle fleet. The 
average vehicle replacement timeframe is much 
longer as for e.g. passenger cars. It takes much 
longer before the effect of new vehicles, which 
pollute less, becomes effective. The other road 
transport vehicles had to comply already 10 years 
ago with relatively severe type approval thresholds. 
The benefit of this early adoption becomes obvious 
owing to the significant overall pollutant reduction of 
all other vehicles (refer to figure 3.1 to 3.5 of the 
LAT report, p59 - 61

Possible using the opportunities as identified in the LAT 
report ch. 3.3: 
- good environmental performance is a marketing asset for 
all products sold today. Improving emissions will also have a 
positive impact on PTWs’ image
- low CO2 vehicles are promoted and are increasingly 
desirable. Clean and efficient motorcycles are a very good 
candidate
- emission standards from other vehicle categories become 
more stringent; this provides the ground to reduce 
emissions from PTWs as well

Sensitivity study presented in MCWG of 29 June 09 
(EMISIA SA Report No: 09.RE.005.V2, Scenarios on the 
future regulation of Power Two Wheelers) showed that the 
threshold level has relatively little effect on total L-category 
vehicle emissions for the assessed timeframe until 2020. 
The speed of threshold introduction is the most important 
factor to reduce emissions. Option 3 can be fast introduced 
and is supported by the industry (minimised implementation 
time anticipated).

Additional possible impacts from SWOT analysis from LAT 
report (ch 3.3)
- products (motorcycles, mopeds, three and four wheelers) 
of superior quality withstanding global competition.
- possible generation of new jobs in suppliers of emission 
control systems

Emission reduction mandated for other means of road 
transport beyond 2020 may become marginal, if Mopeds 
and all other L-category vehicle type emissions not 
further reduced.

The weaknesses of introducing new emissions as 
identified in the LAT report (ch. 3.3):
- costly measures with the cost transferred to the 
customers
- generally, cost increases with increasing stringency of 
emission standards
- the emission threshold should have appeared earlier to 
maximize benefit

The threads as identified in the LAT report (ch. 3.3): 
- small motorcycles and mini-cars are mostly sold due to 
their low price, while large motorcycles and ATVs are 
mainly used as recreational and not prime transport 
vehicles; hence PTWs market is inherently more 
sensitive to price increases; large price increases may 
lead to loss of jobs including SMEs (
- increasing cost may shift buyers to other vehicle 
classes (i.e. small cars); shift of the market to cars will 
increase congestion and greenhouse gas emissions. 
Shift to (small) diesel cars may also increase pollutant 
emissions
- increasing cost may also lead to less frequent PTWs 
replacement, hence degrading the rate of reducing 
emissions
- stringent emission standards may lead to loss of 
performance which is a marketing asset for motorcycles; 
hence increasing tampering practices

Table 53: Analysis table policy options new emission limits, option 3 

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Option 4: New measures based on the Best Available Technology applied on L-category vehicles sold today in the market (Scenario 3 from LAT report)

Positive

Negative

Using the strength of new emission limit values for L-
category vehicles as identified in the LAT report (ch. 3.3):
- reduction of harmful atmospheric substances  (HC, NOx, 
CO, PM) that directly affect a large fraction of the population
- reduction of harmful species that contribute to the 
formation of photochemical pollution (HC, NOx)
- minor reduction of greenhouse-gas (mainly CO2) 
emissions
- reduction of visible smoke.

Current high overall pollution level for new L-category 
vehicles maintained as this can only be very little 
influenced by type approval compliance with low 
thresholds. Adverse health and environmental effects by 
air pollution cannot be efficiently and effectively 
addressed. 

Option 4 achieves reductions of 15%, 2% and 22% for 
CO, HC and NOx, respectively. No PM reduction could 
be assessed based on the available experimental data. 

Neutral  / Remarks
Effect of Type Approval threshold reduction on the 
overall level of pollutants is marginal in comparison 
to the highly polluting L-category vehicle fleet. The 
average vehicle replacement timeframe is much 
longer as for e.g. passenger cars. It takes much 
longer before the effect of new vehicles, which 
pollute less, becomes effective. The other road 
transport vehicles had to comply already 10 years 
ago with relatively severe type approval thresholds. 
The benefit of this early adoption becomes obvious 
owing to the significant overall pollutant reduction of 
all other vehicles (refer to figure 3.1 to 3.5 of the 
LAT report, p59 - 61

Possible using the opportunities as identified in the LAT 
report ch. 3.3: 
- good environmental performance is a marketing asset for 
all products sold today. Improving emissions will also have a 
positive impact on PTWs’ image
- low CO2 vehicles are promoted and are increasingly 
desirable. Clean and efficient motorcycles are a very good 
candidate
- emission standards from other vehicle categories become 
more stringent; this provides the ground to reduce 
emissions from PTWs as well

Possible economy of scales expected for industrialised level 
of technology already applied today. Should theoretically 
result in only low vehicle price increase to consumer.

Additional possible impacts from SWOT analysis from LAT 
report (ch 3.3)
- products (motorcycles, mopeds, three and four wheelers) 
of superior quality withstanding global competition.
- possible generation of new jobs in suppliers of emission 
control systems

Emission reduction mandated for other means of road 
transport beyond 2020 may become marginal, if Mopeds 
and all other L-category vehicle type emissions not 
further reduced.

The weaknesses of introducing new emissions as 
identified in the LAT report (ch. 3.3):
- costly measures with the cost transferred to the 
customers
- generally, cost increases with increasing stringency of 
emission standards
- the emission threshold should have appeared earlier to 
maximize benefit

The threads as identified in the LAT report (ch. 3.3): 
- small motorcycles and mini-cars are mostly sold due to 
their low price, while large motorcycles and ATVs are 
mainly used as recreational and not prime transport 
vehicles; hence PTWs market is inherently more 
sensitive to price increases; large price increases may 
lead to loss of jobs including SMEs (
- increasing cost may shift buyers to other vehicle 
classes (i.e. small cars); shift of the market to cars will 
increase congestion and greenhouse gas emissions. 
Shift to (small) diesel cars may also increase pollutant 
emissions
- increasing cost may also lead to less frequent PTWs 
replacement, hence degrading the rate of reducing 
emissions
- stringent emission standards may lead to loss of 
performance which is a marketing asset for motorcycles; 
hence increasing tampering practices
Sensitivity study presented in MCWG of 29 June 09 
(EMISIA SA Report No: 09.RE.005.V2, Scenarios on the 
future regulation of Power Two Wheelers) showed that 
the threshold level has relatively little effect on total L-
category vehicle emissions for the assessed timeframe 
until 2020. The speed of threshold introduction is the 
most important factor to reduce emissions. Option 4 is 
not supported by the industry (longer time anticipated to 
reach compromise, therefore negative effect on speed of 
implementation of new thresholds (speed of 
implementation is most critical factor)).

Table 54: Analysis table policy options new emission limits, option 4 

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Option 5: New limits for all L-category vehicles equivalent in absolute terms to Euro5 M1 passenger cars (4th scenario from LAT report)

Neutral  / Remarks
Effect of Type Approval threshold reduction on the 
overall level of pollutants is marginal in comparison 
to the highly polluting L-category vehicle fleet. The 
average vehicle replacement timeframe is much 
longer as for e.g. passenger cars. It takes much 
longer before the effect of new vehicles, which 
pollute less, becomes effective. The other road 
transport vehicles had to comply already 10 years 
ago with relatively severe type approval thresholds. 
The benefit of this early adoption becomes obvious 
owing to the significant overall pollutant reduction of 
all other vehicles (refer to figure 3.1 to 3.5 of the 
LAT report, p59 - 61

Positive

Negative

Using the strength of new emission limit values for L-
category vehicles as identified in the LAT report (ch. 3.3):
- reduction of harmful atmospheric substances  (HC, NOx, 
CO, PM) that directly affect a large fraction of the population
- reduction of harmful species that contribute to the 
formation of photochemical pollution (HC, NOx)
- minor reduction of greenhouse-gas (mainly CO2) 
emissions
- reduction of visible smoke
- products (motorcycles, mopeds, three and four wheelers) 
of superior quality withstanding global competition.
- possible generation of new jobs in suppliers of emission 
control systems

Possible using the opportunities as identified in the LAT 
report ch. 3.3: 
- good environmental performance is a marketing asset for 
all products sold today. Improving emissions will also have a 
positive impact on PTWs’ image
- low CO2 vehicles are promoted and are increasingly 
desirable. Clean and efficient motorcycles are a very good 
candidate
- emission standards from other vehicle categories become 
more stringent; this provides the ground to reduce 
emissions from PTWs as well

Possible economy of scales expected for industrialised level 
of technology already applied today. Should theoretically 
result in only low vehicle price increase to consumer.

Best performing option in terms of emission reduction: 
achieves 19%, 28%, 40% and 37% reductions in CO, HC, 
PM and NOx, respectively.

Additional possible impacts from SWOT analysis from LAT 
report (ch 3.3)
- products (motorcycles, mopeds, three and four wheelers) 
of superior quality withstanding global competition.
- possible generation of new jobs in suppliers of emission 
control systems

Current high overall pollution level for new L-category 
vehicles maintained as this can only be very little 
influenced by type approval compliance with low 
thresholds. Adverse health and environmental effects by 
air pollution cannot be efficiently and effectively 
addressed.

Emission reduction mandated for other means of road 
transport beyond 2020 may become marginal, if Mopeds 
and all other L-category vehicle type emissions not 
further reduced.

The weaknesses of introducing new emissions as 
identified in the LAT report (ch. 3.3):
- costly measures with the cost transferred to the 
customers
- generally, cost increases with increasing stringency of 
emission standards
- the emission threshold should have appeared earlier to 
maximize benefit

The threads as identified in the LAT report (ch. 3.3): 
- small motorcycles and mini-cars are mostly sold due to 
their low price, while large motorcycles and ATVs are 
mainly used as recreational and not prime transport 
vehicles; hence PTWs market is inherently more 
sensitive to price increases; large price increases may 
lead to loss of jobs including SMEs (
- increasing cost may shift buyers to other vehicle 
classes (i.e. small cars); shift of the market to cars will 
increase congestion and greenhouse gas emissions. 
Shift to (small) diesel cars may also increase pollutant 
emissions
- increasing cost may also lead to less frequent PTWs 
replacement, hence degrading the rate of reducing 
emissions
- stringent emission standards may lead to loss of 
performance which is a marketing asset for motorcycles; 
hence increasing tampering practices
Sensitivity study presented in MCWG of 29 June 09 
(EMISIA SA Report No: 09.RE.005.V2, Scenarios on the 
future regulation of Power Two Wheelers) showed that 
the threshold level has relatively little effect on total L-
category vehicle emissions for the assessed timeframe 
until 2020. The speed of threshold introduction is the 
most important factor to reduce emissions. Option 4 is 
not supported by the industry (longer time anticipated to 
reach compromise, therefore negative effect on speed of 
implementation of new thresholds (speed of 
implementation is most critical factor)).

Worst in cost effectiveness and absolute cost to industry. 
A possible explanation is that the full benefits of this 
option cannot be obtained in the assessed timeframe, 
but a longer period (e.g. 2012 - 2030) should have been 
assessed. Unfortunately this was not feasible owing to 
timing, resources and simulation tool capability.

Table 55: Analysis table policy options new emission limits, option 5 

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1.3. 

Revised lower emissions limits, summary of the cost effectiveness of the proposed emission limit options 

Summary of the effectiveness of the emission limits scenarios proposed

Cost–effectiveness of different L-category vehicle emission standards 
[Euro/kg] or [Million Euro / kton]

Pollutant

CO

HC

NOx

PM

Scenario
option 1 (no change)
option 2 (scenario 1)
option 3 (scenario 2)
option 4 (scenario 3)
option 5 (scenario 4)
Other road transport
option 1 (no change)
option 2 (scenario 1)
option 3 (scenario 2)
option 4 (scenario 3)
option 5 (scenario 4)
Other road transport
option 1 (no change)
option 2 (scenario 1)
option 3 (scenario 2)
option 4 (scenario 3)
option 5 (scenario 4)
Other road transport
option 1 (no change)
option 2 (scenario 1)
option 3 (scenario 2)
option 4 (scenario 3)
option 5 (scenario 4)
Other road transport

Total [tn] (2007-
2020)

2009 [tn]

2020 [tn]

Percentage reduction 
over baseline in 2020

Percentage of total road 
transport in 2020

Low Estimate

18.400.000
18.400.000
17.800.000
17.600.000
17.700.000
56.600.000
4.910.000
4.810.000
4.740.000
4.870.000
4.600.000
5.370.000
480.000
481.000
436.000
426.000
417.000
32.500.000
37.600
34.100
34.100
37.600
34.100
933.000

1.630.000
1.630.000
1.630.000
1.630.000
1.630.000
6.070.000
429.000
429.000
429.000
429.000
429.000
614.000
29.200
29.200
29.200
29.200
29.200
3.220.000
3.450
3.450
3.450
3.450
3.450
101.000

1.010.000
995.000
845.000
859.000
823.000
1.870.000
262.000
245.000
222.000
256.000
188.000
166.000
42.000
42.100
30.700
32.800
26.600
1.190.000
1.970
1.430
1.240
1.970
1.180
28.800

1%
16%
15%
19%

6%
15%
2%
28%

0%
27%
22%
37%

28%
37%
0%
40%

35%
35%
31%
32%
31%

61%
60%
57%
61%
53%

3%
3%
3%
3%
2%

6%
5%
4%
6%
4%

-
-
-
-
-
-
-
36.2
50.4
86.6
50.1
-
-
-
8.0
3.8
10.5
-
-
93.9
171.6
-
323.4

Best Estimate
-
-
-
-
-
-
-
42.3
62.8
109.7
65.5
-
-
-
10.0
4.8
13.7
-
-
109.8
214.0
-
423.0

High Estimate

-
-
-
-
-
-
-
48.4
75.3
132.8
80.9
-
-
-
12.0
5.8
17.0
-
-
125.6
256.4
-
522.6

Worst performing scenario in terms of pollutant reduction
Best performing scenario in terms of pollutant reduction

Worst performing scenario in terms of cost 
Best performing scenario in terms of cost 

Scenario

Total cost (NPV) for the introduction of different 
emission thresholds 
[Million Euro]

Baseline
Scenario 1 
Scenario 2 
Scenario 3 
Scenario 41 

Low
Estimate
0
4 996
9 283
6 023
17 358

Best
Estimate
0
5 838
11 578
7 626
22 705

High
Estimate
0
6 681
13 874
9 229
28 051

Worst performing scenario in terms of cost
Best performing scenario in terms of cost

1 Cost calculations are based on very rough estimates, with cost items expressed as 
multiplicands of the cost of technology required to meet the emission standards in 
Scenario 2. Details are given in section 3.2.4. of the LAT report

Table 56: Summary of the cost effectiveness of the proposed emission limits options 

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1.4. 

Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category 
vehicle categories 

Type of impact:

Economical
Environmental
Safety

Societal

Option 1: No change

Positive

Minimised compliance cost for manufacturers

Neutral  / Remarks

Negative
Mopeds (R47 test cycle),  Tricycles (R40 test cycle) and 
Light and Heavy Quadricycles (R40 test cycle) cannot be 
type approved with WMTC global harmonised test cycle. 
WMTC introduction in 2006 for 2-wheel motorcycle very 
successful.
R47 and R40 test cycle not representative to simulate 
modern real-world traffic and driving conditions in which 
L-category vehicles participate, mainly owing to the 
absence of representative transient manœuvres in EDC 
and R47 cycle and non-representative low vehicle speed 
& low engine load collective in EDC test cycle.

Possible CO2 / fuel consumption measurement is not 
representative for real world emission / performance. 
Especially fuel consumption measurement result may be 
a purchase criterion for a consumer, who will not be 
happy if tested fuel consumption and real-world fuel 
consumption largely differ. This deprives customer to 
compare different vehicles and to choose for the most 
fuel efficient and least polluting vehicle.

R40 & R47 test cycles easy to replicate with modern 
Engine Management Systems, induces engine tuning 
optimised for the specific emission cycle to obtain type 
approval. Real-world / off-cycle emission performance of 
vehicle may be compromised by the search for optimum 
drive-ability and engine performance (power & torque).

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Option 2: Use of the phase 2 World Motorcycle Testing Cycle (WMTC) for all L-category vehicle categories

Positive

All L-category vehicles could be type approved by using a 
World Harmonised test cycle (WMTC), which could open 
external markets, especially for countries that are acceded 
to the UN ECE agreements. 
Economy of scales for manufacturers selling L-category 
vehicles globally. Possibly less cost transferred to 
consumers resulting in lower vehicle price.
More transparency for consumer to compare different 
vehicle types in terms of fuel consumption, CO2 emission 
and pollutant emissions. Also comparison with other 
vehicles than the ones from the L-category may be possible 
(pending large scale correlation exercises, as previously 
executed by JRC to establish correlation factors between 
EDC and WMTC)

Negative
Initial additional compliance cost, cost neutral on the mid 
to long term.

Neutral  / Remarks

No extra cost to manufacturer if WMTC phase replaced 
with phase 2 for L3&L4 vehicles. No emission impacts 
anticipated.

Better simulation of real world driving conditions
Less easy (more expensive) to replicate test cycle 
conditions in ECU, more degrees of liberty to prevent "cycle 
beating", make this less attractive
Benefit
Best estimate

High
Not possible to quantify, no data available

Low

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Table  57:  Analysis  table  policy  options  Use  of  a  revised  World-wide  Motorcycle  emissions  Testing  Cycle  (WMTC)  for  all  L-
category vehicle categories 

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1.5. 

Type Approval requirements for CO2 measurement and fuel consumption determination and 
reporting 

Type of impact:

Economical
Environmental
Safety

Societal

Option 1: No change

Positive

Neutral  / Remarks

Negative
No uniform indication in EU for customer of L-category 
vehicles with respect to their energy consumption. This 
deprives consumer to compare different vehicles and to 
choose for the most fuel efficient vehicle.

Risk is that Member States will develop and impose own 
labelling system based on the internal structure market. 
This increases the risk of adding confusion to the 
customers and the manufacturers with respect to 
evaluation of their different products. A vehicle model 
could be differently scored in different countries. This is 
confusing and does not assist in the boundary-free 
market integration within EU.

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Option 2: Type Approval requirements for CO2 measurement and fuel consumption determination and reporting

Negative
Additional cost for manufacturer and further downstream 
at the dealer to label vehicles

Neutral  / Remarks

Type approval CO2 and fuel consumption 
measurement and demonstration cost compliance 
are cost neutral, as these are measured 
simultaneously during pollutant control emission 
Type Approval testing.

Positive
At a later stage when also a labelling scheme is introruced, 
direct comparison of fuel consumption with a passenger car 
may provide some good arguments in shifting some 
potential car buyers to the two-wheelers market. However, 
this requires common test cycles, or at least test cycles that 
correlate in terms of emissions, but also in terms of CO2 
emissions and fuel consumption.

Within different categories and sub-categories of L-category 
vehicles, consumer has additional information to his/her 
disposal to allow selection and purchase of the most energy 
efficient vehicle.
Uniform EU-wide indication preventing confusion among 
stakeholders.

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Table 58: Analysis table policy options Type-approval requirements for CO2 measurement and fuel consumption determination 
and reporting 

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1.6. 

Evaporative emissions test and limit 

Option 1: No change

Positive

No additional compliance cost for the industry

Both exhaust and evaporation emissions seem to drop until 
2016. The reason for the drop in evaporation emissions is 
the gradual replacement of carburetted with fuel injection 
vehicles, also in the baseline scenario. 

Neutral  / Remarks

Negative
Evaporative emissions are volatile HC emissions due to:
• Breathing losses (directly from the fuel tank or through 
an activated carbon canister or through the open bowl of 
a carburettor)
• Fuel permeation and/or leakage through the fuel lines 
and circuit
As there is a generic concern with lowering L-category 
vehicle's share of HC from all road transport HC 
emissions, this source of HC should also be tackled.

HC emissions from fuel evaporation via tank vents and 
engine openings may become a significant contributor of 
total HC emissions as exhaust concentrations decrease

Low

Benefit
Best estimate

High

Low

Cost
Best estimate

High

Other indicators

Option 2: Replacement of all new carburetted models with fuel injected ones. Due to the closed circuit, fuel injection engines result in much lower evaporation 
emissions than carburetted ones
Positive
Inherent advantage of EFI to lower evaporative emissions. 
Principle justification of moving from carburettor to EFI is 
more accurate fuel control, leading to better exhaust gas 
emissions, drive-ability and performance. Better 
performance of evaporative emission control is a welcome 
secondary effect. 

Substantial investments required from industry to e.g. 
equip Mopeds with EFI, but this investment is to a high 
extend justified by possibly complying with revised 
exhaust emission limits. Only part of the investment can 
be attributed to better control of evaporative emissions, 
therefore is option 2 a purely academic assumption.

Negative

Neutral  / Remarks
This option in which all the cost of the shift to move 
to electronic fuel injection (EFI) will be incurred only 
owing to improve evaporative emission control is a 
pure theoretic assumption. In practice the very first 
reason to equip a vehicle with EFI is to improve fuel 
metering accuracy to improve exhaust emissions. A 
secondary effect of moving from carburettor to EFI 
is the assumption under this option. The cost 
effectiveness of this option becomes much better if 
only part of the investment to move to EFI is 
attributed to evaporative emission control, but this 
can unfortunately not be quantified. 

Increased revenue to supplier industry, including SMEs, 
potentially leading to higher employment

Significant additional decrease in evaporative HC 
emissions, approximately 600 ton until 2020 (refer to graph 
3-29 in ch. 3.3.5.3 of the LAT report)

Availability of independent testing facilities (SHED 
chamber) for authorities, for manufacturers and in 
particular accessibility to these testing facilities for SMEs

No guarantee that evaporative emissions remain 
controlled under different ambient conditions (hot 
climate, stop and go traffic) and/or over vehicle life. Type 
approved once when vehicle is new, no IUC or PTI 
testing foreseen to check compliance over vehicle life of 
vehicle fleet

NB the quantitive data below was only available for category L3e vehicles

Benefit

Cost (million Euro)

Low

Best estimate

High

Not possible to quantify, no data available

Low
792

Best estimate
1,189

High
1,585

NB assumption that investment in EFI will only be done 
to reduce evaporative emission is a theoretical 
assumption, therefore are the assumed cost and cost 
efficiency of this option estimated too high. No data 
available to quantify the level of magnitude of this too 

Other indicators
Cost effectiveness 
[Euro/kg] or [Million Euro / kton]

Low

Best estimate

High

171

257

342

Option 3: Evaporative emissions test and limit enforcing evaporative emission control for all L-category vehicles

Positive
Inherent advantage of EFI to lower evaporative emissions. 
Principle justification of moving from carburettor to EFI is 
more accurate fuel control, leading to better exhaust gas 
emissions, drive-ability and performance. Better 
performance of evaporative emission control is a welcome 
secondary effect. 

Negative

Neutral  / Remarks

Substantial investments required from industry to e.g. 
equip vehicles with evaporative emission control, but this 
investment should more be attributed to the case of new 
exhaust emission limits. Only part of the investment can 
be attributed to better control of evaporative emissions.

Active evaporative emission control can only be 
effective if vehicle is equipped with EFI.

Increased revenue to supplier industry, including SMEs, 
potentially leading to higher employment

Availability of independent testing facilities (SHED 
chamber) for authorities, but also for SMEs

Most cost effective solution found in LAT report, to address 
HC emissions from L-category vehicles

No guarantee that evaporative emissions remain 
controlled under different ambient conditions (hot 
climate, stop and go traffic) and/or over vehicle life. Type 
approved once when vehicle is new, no IUC or PTI 
testing foreseen to check compliance over vehicle life of 
vehicle fleet

Significant additional decrease in evaporative HC 
emissions, approximately 2800 ton until 2020 (refer to graph 
3-29 in ch. 3.3.5.3 of the LAT report)

NB the quantitive data below was only available for category L3e vehicles

Benefit

Cost (million Euro)

Low

Best estimate

High

Not possible to quantify, no data available

Low
171

Best estimate
513

High
855

Other indicators
Cost effectiveness 
[Euro/kg] or [Million Euro / kton]

Low
9

Best estimate
47

High
28

Table 59: Analysis table policy options evaporative emissions test and limit 

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1.7. 

Durability requirements. 

Option 1: (Scenario "Baseline" from the LAT report): This scenario assumes that there will be no further legislative step beyond 2006/72/EC i.e. no durability 
requirements for PTWs will be imposed. In this way, an arbitrary deterioration over the useful life is set to 20%.

Low compliance cost for manufacturer

Positive

Negative
Uncontrolled degradation of exhaust emissions relevant 
engine components and systems is never verified on 
fleet vehicles, as there are no PTI, RSI or IUC tests. 
Once a type approval test conducted with a brand new 
vehicle, meeting the type approval limits does not 
guarantee that the emission performance over vehicle 
life in the real world remains within the acceptable 
boundary (e.g. maximum 10 - 15% emission 
performance deterioration after X km of mileage 
accumulation).

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Neutral  / Remarks

New Type Approval limits go hand-in-hand with 
durability requirements. Introduction of lower Type 
Approval limits is practically useless if the exhaust 
after treatment components and other emission 
relevant components do not have the quality and/or 
proper design to withstand thermal ageing and 
poisoning over vehicle life. One method to check 
this quality is to perform durability testing before 
start of production by e.g. letting development 
vehicles run a durability distance of X km (e.g. 
50,000 km) and to test the emission performance 
of the vehicle every Y km (e.g. 10,000 km. After X 
km the emission performance must still be below 
the respective emission limits. Also accelerated 
durability tests exist.

Other indicators

Not possible to quantify, no data available

Option 2 (Scenario 2 from the LAT report): Deterioration reduced to 10% for the useful life and application of linear extrapolation for higher mileage

Negative

Increased compliance cost for manufacturers possibly 
transferred into high consumer price

Neutral  / Remarks
Once a durability regulation has been decided, the 
actual useful life is not a critical parameter. 
Increase of the durability by 60% led to additional 
reductions in emission levels in the order of 4 ktn of 
HC, 30 ktn of CO and 1.1 ktn of NOx. This 
corresponds to 1.6%, 3.0%, and 2.6% per pollutant 
respectively, of total PTW emissions in 2020

Positive
Estimated emission benefit in EU15 (EU27 unknown) until 
2020 owing to introduction of option 2:
- HC: 12,500 tn
- CO: 75,500 tn
- NOx: 3,400 tn

It is absolutely critical that a durability regulation is 
introduced for L-category vehicles, otherwise significant 
departures from the emission standard may occur at rather 

h t di t

Increased quality and guarantee for customer that 
investment in cleaner vehicle gives better  value for money 
over vehicle life in terms of steady environmental 

f

Reduced risk for customers to fail PTI tests in the Member 
States where this applies. Prevent early on exchange of 
expensive exhaust after treatment components.

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Option 3 (Scenario 2 from the LAT report): useful life increased by 60%, i.e. equivalent to the increase incurred to passenger cars when shifting from Euro 3 
(80k km) to Euro 5 (160k km)

Negative

Increased compliance cost for manufacturers possibly 
transferred into high consumer price

Neutral  / Remarks
Once a durability regulation has been decided, the 
actual useful life is not a critical parameter. 
Increase of the durability by 60% led to additional 
reductions in emission levels in the order of 4 ktn of 
HC, 30 ktn of CO and 1.1 ktn of NOx. This 
corresponds to 1.6%, 3.0%, and 2.6% per pollutant 
respectively, of total PTW emissions in 2020

Positive
Estimated emission benefit in EU15 (EU27 unknown) until 
2020 owing to introduction of option 3:
- HC: 17,500 tn
- CO: 105,000 tn
- NOx: 4,600 tn

It is absolutely critical that a durability regulation is 
introduced for L-category vehicles, otherwise significant 
departures from the emission standard may occur at rather 

h t di t

Increased quality and guarantee for customer that 
investment in cleaner vehicle gives better  value for money 
over vehicle life in terms of steady environmental 

f

Reduced risk for customers to fail PTI tests in the Member 
States where this applies. Prevent early on exchange of 
expensive exhaust after treatment components.

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Table 60: Analysis table policy options durability requirements 

EN 

98 

   EN 

 
 
2. 

NEW MEASURES TO CONTROL EMISSIONS DURING VEHICLE LIFE. 

2.1. 

In-Use Conformity (IUC) testing and limits.  

Under  the  scope  of  this  policy  option  only  IUC  is  regarded  for  the  reasons  as  indicated  in  chapter  2.1, 
problem definition (not PTI, nor RSI, which will be subjects to a separate Impact Assessment executed by 
DG TREN on the revision of Directives 96/69/EC and 2000/40/EC). 

Type of impact:

Economical
Environmental
Safety

Societal

Option 1: No change

Low compliance cost for manufacturer

Positive

Negative
Uncontrolled degradation of exhaust emissions relevant 
engine components and systems is never verified on 
fleet vehicles, as there are no PTI, RSI or IUC tests. 
Once a type approval test conducted with a brand new 
vehicle, meeting the type approval limits does not 
guarantee that the emission performance over vehicle 
life in the real world remains within the acceptable 
boundary (e.g. maximum 10 - 15% emission 
performance deterioration after X km of mileage 
accumulation).

Neutral  / Remarks

In-Use compliance (IUC) regulations are 
established to make sure that the emission levels 
of a vehicle type in the real-world complies with its 
type-approval limits. IUC is a manufacturer's 
responsibility. IUC requires that a small sample of 
fleet vehicles is randomly selected and is tested 
according to the certification test conditions to 
check whether the vehicles comply with their 
corresponding emission standards.

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Option 2: (Scenario 1 from LAT report): IUC procedure mandatory to for all Euro 3 motorcycles. The IUC is considered to identify all not attainments which are 
consecutively corrected. 

Positive

Negative

Increased compliance cost for manufacturers possibly 
transferred into high consumer price

Depending on the results of the IUC procedure, the 
manufacturer may be forced to remedy the situation, if the 
vehicles selected do not comply with the emission 
standards. This should be considered as a direct 
environmental benefit of an IUC requirement. As an indirect 
benefit, the manufacturer takes all necessary steps to 
ensure that the long-term emission behaviour does not 
differentiate (at least much) from the type approval limits. It 
is obvious that it is not possible to simulate the indirect 
effect of IUC.

Neutral  / Remarks
main structural components of any IUC procedure
• Manufacturers responsibility for durable and 
functioning emission controls in use, for a certain 
driving distance (durability period).
• Test procedure: type-approval emission laboratory 
test or, for surveillance, some other in-use emission 
test data supplied by manufacturers or an authority.
• Procedure for selection, procurement, and 
maintenance of vehicles to the test sample (audit 
procedure).
• Procedure to examine test data and information, 
emission failure and technical faults.
• Recall/remedial actions, how to perform and 
report, labels, etc

Estimated emission benefit in EU15 (EU27 unknown) until  
2020 owing to introduction of option 2:
- HC: 180 tn
- CO: 1600 tn
- NOx: 100 tn

Increased quality and guarantee for customer that 
investment in cleaner vehicle gives better  value for money 
over vehicle life in terms of steady environmental 
Reduced risk for customers to fail PTI tests in the Member 
States where this applies. Prevent early on exchange of 
expensive exhaust after treatment components.

No additional cost for end-customer as burden carried by 
manufacturer and national authorities

Partial overlap with RSI, PTI and durability testing, low 
cost effectiveness of IUC compared to other related 
measures

Increased administrative and financial burden to national 
authorities

Difficult to select representative vehicles to test

Benefit

Cost [Million Euro]

Low

Best estimate

High

Low
6

Best estimate
7

High
8

Table 61: Analysis table policy options In-Use Conformity (IUC) testing and limits 

Other indicators
Cost effectiveness HC
[Euro/kg] or [Million Euro / kton]

Low
3.6

Best estimate
4.2

High
4.8

Cost effectiveness NOx
[Euro/kg] or [Million Euro / kton]

Low
0.3

Best estimate
0.3

High
0.4

EN 

99 

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2.2. 

On Board Diagnostic (OBD) systems and access to repair information 

Type of impact:

Economical
Environmental
Safety

Societal

Option 1: No change (No introduction of OBD systems)
Positive

No additional compliance cost for manufacturer.

Negative

Neutral  / Remarks

Effect of malfunctions on emissions
Inefficient malfunction analysis with subsequent 
ineffective repair. (Independent) workshop is dependent 
on availability of proprietary manufacturer, non-
standardised malfunction information. 
Ineffective repair leads to high repair cost for customer 
and leads to customer dissatisfaction, high cost for repair 
shop and possibly high warranty cost for manufacturers. 
Driver not directly informed if a capital system failure 
exists, that leads to high emissions 
Driver not directly informed if a capital system failure 
exists, that leads to a possible safety impact.

Driver not directly informed if a capital system failure 
exists, that leads to a possible engine failure, leading to 
high subsequent repair cost for consumer.
In Member States in which L-category vehicles are 
subject to PTI testing, gaseous testing cannot be 
replaced by reading out OBD information as there is no 
standardised diagnostic information made available to a 
generic scan tool. This forces to maintain the worse cost 
efficient gaseous (CO) testing.

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Table 62: Analysis table policy options On Board Diagnostic (OBD) systems and access to repair information, option 1 

EN 

100 

   EN 

 
 
 
Option 2 (scenario 1 in LAT report): Application of OBD systems of similar technology to passenger cars (EOBD), including catalyst efficiency monitoring to 
all L-category vehicles. Introduction of free access to repair and maintenance provisions, similar as for passenger cars.

Neutral  / Remarks
It is essential to find the optimum balance between 
correct, fast detection of failure and prevention of 
false detection. False detection will lead to loss of 
confidence of consumer and repairers and 
increased non value added cost to all stakeholders.

Positive

Negative

Substantial investments of the industry in technology 
(hard-ware and software). High compliance cost.

Risk of ignoring the Malfunction Indicator Light by the 
driver.

Special provisions required to accommodate retrofitting. 
Possible negative financial consequences for aftermarket 
Increased complexity of legislation

Missing enforcement in Periodical Technical Inspection / 
Road Side Inspection. No consequences if MIL on, 
voluntary decision of driver to continue driving with 
malfunction or to have vehicle repaired. In case of 
systematic malfunction owing to bad quality / design of 
components / systems there is no authority checking 
whether manufacturer should recall vehicles and improve 
vehicle.

Access to technology by SME's (analogy to aspects as 
referred to under chapter on Antilock  Brake systems).

If notified driver may visit repair shop soon and have 
malfunctions causing high emissions quickly repaired, 
leading to significant less negative environmental impact of 
malfunctions.

Standardised (ISO) malfunction information available to 
independent repairers, leading to less cost and time to 
diagnose malfunctions

Driver directly informed if a capital system failure exists, that 
leads to a possible safety impact.
Driver directly informed if a capital system failure exists, that 
leads to possible engine failure. Support to prevent high 
subsequent repair cost for consumer.

Engine component, sub system and complete system 
degradation monitoring. Fuel system drift, Misfire, Catalyst 
efficiency diagnostic, Front and Rear O2 sensor response 
diagnostic, EGR flow diagnostic, comprehensive 
components monitoring diagnostic among others guarantee 
that the most emission relevant components are monitored 
on their efficiency. In case of low efficiency leading to 
exceeding the OBD emission thresholds, the MIL will be 
illuminated and the driver will be notified so he/she is aware 
that a repair must be executed. The engine management 
system may trigger default actions in order to protect the 
engine and/or the catalytic converter. In Use Performance 
Ratio monitoring will increase the confidence level that all 
this monitoring will also happen under real world conditions 
and not only for demonstration purposes in the type 
approval test.
Less attractive (more complicated, more expensive) to 
tamper with manufacturer optimum found settings in order 
to just increase engine power / torque at the cost of the 
environmental / safety performance of the vehicle.

Additional employment and revenue for automotive 
suppliers to help manufacturers develop the OBD system 
and increased revenue related to additional engine 
hardware and software to be able to comply with OBD 
measures.

Additional employment and revenue for Type Approval 
Authorities and testing laboratories to help manufacturers 
develop the OBD system and increased revenue related to 
additional engine hardware and software to be able to 
comply with OBD measures.
Increased innovation in other areas of development than 
only in engine performance (power / torque) increase

Use OBD as alternative to gaseous test in PTI, similar as on 
passenger cars. Enhanced efficient method to check 
whether engine is in acceptable condition. Reduced cost 
and PTI for customer.
Standardised (ISO) malfunction and other diagnostic 
information is indispensible for independent repairers to 
efficiently and effectively repair a failure. The introduction of 
OBD and free access to repair and maintenance information 
to address the competition concern in the EU internal 
market must be assessed as one combined policy option. 
For this reason are the cost and cost-effectiveness 
calculations only indicative and too estimated very 
conservatively

Benefit

Cost (NPV in Million Euro)

Other indicators

Low

High
Not possible to quantify, no data available

Best estimate

Low
1227

Best estimate
1588

High
1949

Cost effectiveness 
[Euro/kg] or [Million Euro / kton]

HC
NOx

Low
22.5
1.5

Best estimate
29.1
2.4

High
35.8
1.9

Table 63: Analysis table policy options On Board Diagnostic (OBD) systems and access to repair information, option 2 

EN 

101 

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Option 3 (scenario 2 in LAT report): use of Best Available Technology (BAT): minor malfunction monitoring (e.g. circuit integrity check) (OBD phase 1) to all L-
category vehicles, no catalyst efficiency monitoring. Introduction of free access to repair and maintenance provisions, similar as for passenger cars.

Neutral  / Remarks
It is essential to find the optimum balance between 
correct, fast detection of failure and prevention of 
false detection. False detection will lead to loss of 
confidence of consumer and repairers and 
increased non value added cost to all stakeholders.

Positive

If notified driver may visit repair shop soon and have 
malfunctions causing high emissions quickly repaired, 
leading to significant less negative environmental impact of 
malfunctions.

Standardised (ISO) malfunction information available to 
independent repairers, leading to less cost and time to 
diagnose malfunctions

Driver directly informed if a capital system failure exists, that 
leads to a possible safety impact.

Driver directly informed if a capital system failure exists, that 
leads to possible engine failure. Support to prevent high 
subsequent repair cost for consumer.

Degradation of components / systems not included. Only 
fast developing failures detected, slow over time developing 
failures will not be detected. 

Negative
Low investments of the industry in technology (hardware 
and software) as OBD phase one features are industry 
wide available, only as manufacturer proprietary systems 
(not standardised) and hardly not available on request of 
generic scan tool. Low estimated compliance cost. OBD 
phase 1 is ´commodity product´ of automotive suppliers 
and a ´no brainer´ to manufacturers.

Risk of ignoring the Malfunction Indicator Light by the 
driver.

Special provisions required to accommodate retrofitting. 
Possible negative financial consequences for aftermarket 
industry.
Increased complexity of legislation

Missing enforcement in Periodical Technical Inspection / 
Road Side Inspection. No consequences if MIL on, 
voluntary decision of driver to continue driving with 
malfunction or to have vehicle repaired. In case of 
systematic malfunction owing to bad quality / design of 
components / systems there is no authority checking 
whether manufacturer should recall vehicles and improve 
vehicle.

Less attractive (more complicated, more expensive) to 
tamper with manufacturer optimum found settings in order 
to just increase engine power / torque at the cost of the 
environmental / safety performance of the vehicle.
Additional employment and revenue for automotive 
suppliers to help manufacturers develop the OBD system 
and increased revenue related to additional engine 
hardware and software to be able to comply with OBD 
measures
Additional employment and revenue for Type Approval 
Authorities and testing laboratories to help manufacturers 
develop the OBD system and increased revenue related to 
additional engine hardware and software to be able to 
comply with OBD measures.

Increased innovation in other areas of development than 
only in engine performance (power / torque) increase.
Use OBD as alternative to gaseous test in PTI, similar as on 
passenger cars. Enhanced efficient method to check 
whether engine is in acceptable condition. Reduced cost 
and PTI for customer.
One time investment for OEM can be well amortised, owing 
to high level of re-use of hardware and software functionality 
for current and future generations of Engine Control 
Modules.

Standardised (ISO) malfunction and other diagnostic 
information is indispensible for independent repairers to 
efficiently and effectively repair a failure. The introduction of 
OBD and free access to repair and maintenance information 
to address the competition concern in the EU internal 
market must be assessed as one combined policy 
option.This was an additional reason to discard the cost and 
cost-effectiveness calculations provided by the consultant's 
report as this was aspect was not included in the initial 
assumptions.

Low

Benefit
Best estimate

High

Low

Best estimate

High

Cost (NPV in Million Euro)

Not possible to quantify, no data available

The numbers from the LAT report were considered much 
too high and were therefore discarded by the 
Commission Services.

Other indicators
Cost effectiveness 
The numbers from the LAT report were considered 
much too high and were therefore discarded by the 
Commission Services.

Table 64: Analysis table policy options On Board Diagnostic (OBD) systems and access to repair information, option 3 

EN 

102 

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ANNEX XII: DETAILS CHAPTER 5 — IMPACT ANALYSIS NEW VEHICLE TYPE APPROVAL SAFETY MEASURES 

1. 

OBLIGATORY FITTING OF ADVANCED BRAKE SYSTEMS 

In the discussions about this topic there is a lot of confusion about the expression ‘Advanced’ Brake Systems 
and  ‘Anti-lock’  Brake  Systems49,  generally  abbreviated  as  ABS.  However,  Advanced  Brake  Systems  are 
also abbreviated as ABS. In this Impact Assessment report ABS means Anti-lock Brake System exclusively. 
Advanced  Brake  Systems  in  this  report  is  defined  as:  Anti-lock  Brake  System  and/or  Combined  Brake 
Systems50. 

Controversial  in  the  discussions  is  the  technical  effectiveness  of  Anti-lock  Brake  Systems  to  prevent 
accidents or mitigation of injuries and associated cost-benefit ratios, especially for the scenarios in which this 
system would be assumed to be mandatory. One of the most critical variables in the discussion is the best 
estimated cost price of Anti-lock Brake System and the impact this potentially has on vehicle sales and the 
estimations of the cost benefit ratios. For every scenario the assumed best estimate, including low and high 
range  prices  will  be  listed.  In  the  policy  report  the  short,  mid-  and  long-term  economic  impacts  were 
assessed.  In  the  Impact  Assessment  report  only  the  long  term  effects  will  be  used  as  final  comparison 
criteria, as the objectives for the measures in the new regulation are also defined as long term goals. In case 
of any short term side-effect of a measure, this will be specifically reported. 

1.1. 

No change 

Type of impact:

Economical
Environmental
Safety

Societal

Option 1: No change

Low consumer price of PTW

Positive

Negative
Unchanged level of fatalities and injured riders in PTW 
involved road accidents.
Level of cost to society owing to cost of health care, lost 
working days etc.
High insurance cost for consumer
Potential customers not purchasing PTWs owing to 
being victim of road accident
Grief of family, friends, colleagues.

Neutral  / Remarks

Benefit (million Euro), 2011 - 2021

Cost (million Euro), 2011 - 2021

Other indicators

Low

Best estimate

High

Low

Best estimate

High

Table 65: Analysis table policy options obligatory fitting of advanced brake systems, option 1 

49

50

Definition from TRL report: Anti-lock braking systems (ABS) monitor the speed at which the wheels are rotating and rapidly 
modulate  the  brake  pressure  when  imminent  wheel  lock  is  detected  in  order  to  increase  effective  braking  and  prevent  the 
deceleration being dictated by the sliding friction between tyre and road. ABS is the only technical solution which directly 
monitors and prevents wheel locking and has been shown in test conditions to result in generally higher braking decelerations 
by  maintaining  the  wheel  slip  such  that  friction  is  above  the  level  provided  by  locked  wheels.  Preventing  wheel  lock  under 
emergency braking provides the rider with increased confidence to apply higher brake forces. 
Definition  from  TRL  report:  Combined  braking  systems  (CBS)  are  used  to  ensure  that  the  correct  braking  distribution  is 
applied regardless of which brake is activated; currently the rider must use two separate mechanisms to operate the front and 
rear brakes. The use of CBS allows one mechanism to operate both brakes (in a similar way to that of a passenger car). The 
primary aim of this system is to appropriately distribute the braking effort between the front and rear wheels. Compared with 
rider-controlled distribution of braking between the front and the rear, CBS reduces the chances of wheel lock and instability 
occurring  at  less  than  the  maximum  level  of  deceleration.  For  example,  if  a  rider  applied  the  rear  brake  very  hard,  without 
using the front brake, the rear wheel could lock and cause instability at a level of deceleration considerably less than half the 
maximum achievable. CBS can prevent such a situation but cannot prevent wheel lock when the rider applies the single brake 
control harder than required to produce maximum deceleration. 

EN 

103 

   EN 

 
 
 
                                                 
 
 
1.2. 

Anti-lock Brake Systems on all Powered Two Wheelers (PTW) 

Option 2: Anti-lock  Brake Systems on all Powered Two Wheelers (PTW)

Positive

Negative

Neutral  / Remarks

Anti-lock  Brake System is the only technical solution 
which directly monitors and prevents wheel locking.

With Anti-lock  Brake System higher braking decelerations 
achieved (resulting in less braking distance) than with 
conventional brakes only. Potential reduction in impact 
speed in case of collision
Preventing wheel lock under emergency braking provides 
the rider with increased confidence to apply higher brake 
forces. More efficient braking with Anti-lock  brake system, 
rider brakes earlier during brake manœuvre

Rider becoming "over" confident if PTW equipped with 
advanced brake system, trusts too much on technology. 
Higher speed
Perception that CBS is full alternative to Anti-lock brake 
system, technical equivalence

Rider training is required in order to achieve the 
maximum advantages of Anti-lock  brake system

Innovation in Anti-lock  Brake System and braking 
technology

Possible bad braking performance (adverse effects off-
road) if Anti-lock  Brake System fitted on off-road PTW

Inexperienced riders on PTW with Anti-lock  Brake System 
able to achieve decelerations closer to that of experienced 
riders, after relatively short training / adaptation time

Manufacturing and development cost of PTWs equipped 
with Anti-lock  Brake Systems, possibly passed on to 
consumer (possible price increase)

Availability of  Anti-lock  Brake System technology to 
SME's (not meeting entrance criteria to be supplied by 
bigger automotive suppliers or confronted with high 
development cost as supplier cannot amortise 
investments owing to low series production)
Risk of short - mid term price increase owing to 
manufacturers forced to buy systems and components 
from suppliers.

Additional rules for design of brake system to industry 
making legislation more complex.

Legislation not technology neutral, mandating a specific 
technology. Normally legislation just defines the 
performance criteria.  
Level of technical complexity of vehicle

Vehicles fitted with Anti-lock  Brake System are able to 
make use of the adhesion available when on low and high 
friction surfaces. (e.g. changing conditions from dry to wet 
road)

Anti-lock brake systems prevents dangerous downfalls 
whilst braking. In case of critical wheel-lock of front wheel 
PTW rider falls and slides uncontrolled over the road
Cost effectiveness obligatory Anti-lock  brake system. 
Majority of in total 11 predictive and retrospective literature 
study results are positive.
Chance of increased level of accident result mitigation in 
case of Anti-lock  brake system

Long term societal and economic benefits owing to casualty 
mitigation . There are estimated to be between 5.5 and 13 
times (approximately between 30,000 and 72,000 riders) 
more heavily injured people than fatalities per year in the 
EU. Slight motorcycle casualties are lying within a range of 
12 and 28 times the numbers of fatalities (approximately 
between 66,000 and 155,000 riders) per annum in the EU. 
Based on the current available data it is not possible to 
forecast the level of mitigation in case of mandatory use of 
advanced brake system.

In some Member States, discount on rider's insurance. Less 
cost insurance companies.
Economy of scales for Anti-lock Braking System production, 
mid to long term drop of development and production cost 

Revenue and employment supplier industry

Level of market penetration: 91% of PTWs estimated to be 
equipped with a Anti-lock  Brake System in 2021

FATALITY REDUCTION 
Long term life saving (2011-2021)
Min.           Best Estimate                Max.

2,799

5,999

11,997

Benefit (million Euro), 2011 - 2021

Cost (million Euro), 2011 - 2021

Remarks / Other indicators

Low

Best estimate

High

Low

Best estimate

High

€ 2,553
€ 792
€ 102

€ 5,107
€1,583 - €3,677
€204 - €460

€ 10,214
€ 7,354
€ 919

€ 1,732

€ 3,463

€ 2,597

accident avoidance 
2011 - 2021
casualty mitigation 
2011 - 2021

Benefit: fatality avoidance
Benefit: mitigation heavy injuries
Benefit: mitigation slight injuries

Benefit to cost ratio, 2011 - 2021
Low        Best estimate          High

1.3

1.1

2.7 – 3.6

2.3 – 3.0

7.1

5.9

Table 66: Analysis table policy options obligatory fitting of advanced brake systems, option 2 

EN 

104 

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1.3. 

3
  AND  ADVANCED  BRAKE 
ANTI-LOCK  BRAKE  SYSTEMS  ON  PTWS  WITH  CYLINDER  CAPACITY
SYSTEMS (COMBINED BRAKE SYSTEM (CBS) OR ANTI-LOCK BRAKE SYSTEMS (ABS)) ON MOTORCYCLES 
WITH 50 CM

3
 < CYLINDER CAPACITY

  >  125  CM

 ≤ 125 CM

51

51

3 

Option 3: Anti-lock Brake Systems on PTWs with cylinder capacity > 125 cm3 and Advanced Brake Systems (Combined Brake System (CBS)             
               and/or Anti-lock Brake Systems (Anti-lock Brake System)) on motorcycles with cylinder capacity >50cm3 and <= 125cm3 

Positive

Negative

Neutral  / Remarks

Anti-lock  Brake System is the only technical solution 
which directly monitors and prevents wheel locking.
With Anti-lock  Brake System higher braking decelerations 
achieved (resulting in less braking distance) than with 
conventional brakes only. Potential reduction in impact 
speed in case of collision
Preventing wheel lock under emergency braking provides 
the rider with increased confidence to apply higher brake 
forces. More efficient braking with Anti-lock  brake system, 
rider brakes earlier during brake manœuvre

Rider becoming "over" confident if PTW equipped with 
advanced brake system, trusts too much on technology. 
Perception that CBS is full alternative to Anti-lock brake 
system, technical equivalence

Rider training is required in order to achieve the 
maximum advantages of Anti-lock  brake system
Innovation in Anti-lock  Brake System and braking 
technology

Possible bad braking performance (adverse effects off-
road) if Anti-lock  Brake System fitted on Off-road PTW

Inexperienced riders on PTW with Anti-lock  Brake System 
able to achieve decelerations closer to that of experienced 
riders, after relatively short training / adaptation time

Manufacturing and development cost of PTWs equipped 
with Anti-lock  Brake Systems, possibly passed on to 
consumer (possible price increase)

Availability of Anti-lock  Brake System technology to 
SME's (not meeting entrance criteria to be supplied by 
bigger automotive suppliers or confronted with high 
development cost as supplier cannot amortise 
investments owing to low series production)
Risk of short term price increase owing to manufacturers 
forced to buy systems and components from suppliers.

Additional rules for design of brake system to industry 
making legislation more complex.

Legislation not technology neutral, mandating a specific 
technology. Normally legislation just defines the 
performance criteria.  
Level of technical complexity of vehicle

Vehicles fitted with Anti-lock  Brake System are able to 
make use of the adhesion available when on low and high 
friction surfaces. (e.g. changing conditions from dry to wet 
road)

Anti-lock  brake systems prevents dangerous downfalls 
whilst braking. In case of critical wheel-lock of front wheel 
PTW rider falls and slides uncontrolled over the road
Cost effectiveness obligatory Anti-lock  brake system. 
Majority of in total 11 predictive and retrospective literature 
study results are positive.
Chance of increased level of accident result mitigation in 
case of Anti-lock  brake system

Long term societal and economic benefits.
In some Member States, discount on rider's insurance. Less 
cost insurance companies.
Economy of scales for Anti-lock Braking System production, 
mid to long term drop of development and production cost 

Revenue and employment supplier industry

Level of market penetration: 64% of PTWs estimated to be 
equipped with a Anti-lock  Brake System in 2021, 27% with 
Long term societal and economic benefits owing to casualty 
mitigation . There are estimated to be between 5.5 and 13 
times (approximately between 30,000 and 72,000 riders) 
more heavily injured people than fatalities per year in the 
EU. Slight motorcycle casualties are lying within a range of 
12 and 28 times the numbers of fatalities (approximately 
between 66,000 and 155,000 riders) per annum in the EU. 
Based on the current available data it is difficult to forecast 
the level of mitigation in case of mandatory use of advanced 
brake system
Performance criteria of option 3 aligned with vehicle 
performance criteria as defined in the new driving licence 
Directive 2006/126/EC for category A2. Benefit: type 
approval and driving licence vehicle classification criteria 
harmonised (coherence)

Sensible definition of performance thresholds to differentiate 
between a low and a high performing motorcycle. To 
improve the match between the performance (acceleration 
and braking) criteria used for type approval and for driving 
licence (category A2). Rationale: the higher the power and 
torque characteristics of a motorcycle, leading to a high 
max. vehicle speed and fast acceleration respectively, the 
better the braking performance must be. Especially the 
Power to mass criteria defined in Directive 2006/126/EC 
provide an international accepted limitation for this criterion.

FATALITY REDUCTION 
Long term life saving (2011-2021)
Min.           Best Estimate                Max.

2,799

5,332

11,331

Benefit (million Euro), 2011 - 2021

Cost (million Euro), 2011 - 2021

Remarks / Other indicators

Low

Best estimate

High

Low

Best estimate

High

€ 2,383
€ 739
€ 95

€ 4,539
€1,407 - €3,268
€182 - €409

€ 9,646
€ 6,945
€ 868

€ 1,602

€ 3,463

€ 2,597

accident avoidance 
2011 - 2021
casualty mitigation 
2011 - 2021

Benefit: fatality avoidance
Benefit: mitigation heavy injuries
Benefit: mitigation slight injuries

Benefit to cost ratio, 2011 - 2021
Low        Best estimate          High

1.2

1.1

2.4 – 3.2

2.0 – 2.6

6.7

5.6

Table 67: Analysis table policy options obligatory fitting of advanced brake systems, option 3 

51

The 125 cm3 takes reference to the thresholds in Directive 2006/126/EC (recasted driving licence directive) related to class 
A1:  motorcycles  with  a  cylinder  capacity  not  exceeding  125  cm3,  of  a  power  not  exceeding  11kW  and  with  a  power/weight 
ratio not exceeding 0.1 kW/kg. 

EN 

105 

   EN 

 
 
                                                 
 
1.4. 

To make mandatory the fitting of Advanced Brake Systems (Combined Brake System (CBS) 
and/or Anti-lock Braking Systems) on those motorcycles which conform to the performance 
criteria  defined  by  the  A2  driving  licence.  Obligatory  fitting  of  Anti-lock  Brake  Systems  on 
all other L3e class motorcycles; 

Option 4: To make mandatory the fitting of Advanced Brake Systems (Combined Brake System (CBS) and/or Anti-lock Braking Systems) on those motorcycles 
which conform to the performance criteria defined by the A2 driving licence . Obligatory fitting of Anti-lock Brake Systems on all other L3 class motorcycles;

Positive

Negative

Neutral  / Remarks

Anti-lock  Brake System is the only technical solution 
which directly monitors and prevents wheel locking.
With Anti-lock  Brake System higher braking decelerations 
(resulting in less braking distance) than with conventional 
brakes only. Potential reduction in impact speed in case of 
collision
Preventing wheel lock under emergency braking provides 
the rider with increased confidence to apply higher brake 
forces. More efficient braking with Anti-lock  brake system, 
rider brakes earlier during brake manœuvre

Rider becoming "over" confident if PTW equipped with 
advanced brake system, trusts too much on technology. 
Perception that CBS is full alternative to Anti-lock brake 
system, technical equivalence

Rider training is required in order to achieve the 
maximum advantages of Anti-lock  brake system
Innovation in Anti-lock  Brake System and braking 
technology

Possible bad braking performance (adverse effects off-
road) if Anti-lock  Brake System fitted on Off-road PTW

Inexperienced riders on PTW with Anti-lock  Brake System 
able to achieve decelerations closer to that of experienced 
riders, after relatively short training / adaptation time

Manufacturing and development cost of PTWs equipped 
with Anti-lock  Brake Systems, possibly passed on to 
consumer (possible price increase)

Vehicles fitted with Anti-lock  Brake System are able to 
make use of the adhesion available when on low and high 
friction surfaces. (e.g. changing conditions from dry to wet 
road)

Anti-lock  brake systems prevents dangerous downfalls 
whilst braking. In case of critical wheel-lock of front wheel 
PTW rider falls and slides uncontrolled over the road
Cost effectiveness obligatory Anti-lock  brake system. 
Majority of in total 11 predictive and retrospective literature 
study results are positive.
Chance of increased level of accident result mitigation in 
case of Anti-lock  brake system

In some Member States, discount on rider's insurance. Less 
cost insurance companies.
Economy of scales for Anti-lock Braking System production, 
mid to long term drop of development and production cost 

Revenue and employment supplier industry

Availability of Anti-lock  Brake System technology to 
SME's (not meeting entrance criteria to be supplied by 
bigger automotive suppliers or confronted with high 
development cost as supplier cannot amortise 
investments owing to low series production)

Risk of short term price increase owing to manufacturers 
forced to buy systems and components from suppliers.

Additional rules for design of brake system to industry 
making legislation more complex.

Legislation not technology neutral, mandating a specific 
technology. Normally legislation just defines the 
performance criteria.  
Level of technical complexity of vehicle

Less vehicles in the scope of mandatory equipping 
vehicles with an Anti-lock  Brake System from the 
braking performance perspective
Significant higher level of uncertainty regarding the 
benefit to cost ratio as scenario did not make part of the 
TRL report. The financial data were copied from option 3. 
The assumption is that the cost to the manufacturer is 
significantly lower, but the benefit as well, resulting in 
lower benefit to cost ratios.

Higher fleet penetration rate of Anti-lock  Brake System 
than if left to market
Long term societal and economic benefits owing to casualty 
mitigation . There are estimated to be between 5.5 and 13 
times (approximately between 30,000 and 72,000 riders) 
more heavily injured people than fatalities per year in the 
EU. Slight motorcycle casualties are lying within a range of 
12 and 28 times the numbers of fatalities (approximately 
between 66,000 and 155,000 riders) per annum in the EU. 
Based on the current available data it is difficult to forecast 
the level of mitigation in case of mandatory use of advanced 
brake system
Performance criteria of option 4 aligned with vehicle 
performance criteria as defined in the new driving licence 
Directive 2006/126/EC for category A2. Benefit: type 
approval and driving licence vehicle classification criteria 
harmonised (coherence)

Sensible definition of performance thresholds to differentiate 
between a low and a high performing motorcycle. To 
improve the match between the performance (acceleration 
and braking) criteria used for type approval and for driving 
licence (category A2). Rationale: the higher the power and 
torque characteristics of a motorcycle, leading to a high 
max. vehicle speed and fast acceleration respectively, the 
better the braking performance must be. Especially the 
Power to mass criteria defined in Directive 2006/126/EC 
provide an international accepted limitation for this criterion.

FATALITY REDUCTION 
Long term life saving (2011-2021)
Min.           Best Estimate                Max.

754 - 2799
mean: 1777

1437 - 5332
mean:3385

3054 - 11331
mean:7193

Approximated Benefit (million Euro), 2011 - 2021

Best estimate

High

Low

Low

Benefit (million Euro), 2011 - 2021

Cost (million Euro), 2011 - 2021

Remarks / Other indicators

Best estimate

High

Low

Best estimate

High

Approximated Cost (million Euro), 2011 - 2021
Low

Best estimate

High

Remarks / Other indicators

€ 2,383
€ 739
€ 95

€ 4,539
€1,407 - €3,268
€182 - €409

€ 9,646
€ 6,945
€ 868

€ 1,602

€ 3,463

€ 2,597

accident avoidance 
2011 - 2021
casualty mitigation 
2011 - 2021

Benefit: fatality avoidance
Benefit: mitigation heavy injuries
Benefit: mitigation slight injuries

Benefit to cost ratio, 2011 - 2021
Low        Best estimate          High

1.2

1.1

2.4 – 3.2

2.0 – 2.6

6.7

5.6

Table 68: Analysis table policy options obligatory fitting of advanced brake systems, option 4

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1.5. 

Industry self obligation 

Option 5: Industry self-obligation
Positive

Preventing wheel lock under emergency braking provides 
the rider with increased confidence to apply higher brake 
forces. More efficient braking with Advanced Brake System, 
rider brakes earlier during brake manœuvre

Cost effectiveness Advanced Brake Systems according to 
industry self-obligation scheme (either Anti-lock  Brake 
System and/or CBS)

Negative

Neutral  / Remarks

Rider becoming "over" confident if PTW equipped with 
advanced brake system, trusts too much on technology. 
Higher speeds

Anti-lock  Brake System is the only technical 
solution which directly monitors and prevents wheel 
locking.

Cost effectiveness obligatory Anti-lock  brake system. 

With Anti-lock  Brake System higher braking 
decelerations achieved in the majority of cases 
(resulting in less braking distance) than with 
conventional brakes only.

Inexperienced riders on PTW with Anti-lock Brake 
System able to achieve decelerations closer to that 
of experienced riders, after relatively short training / 
adaptation time

Anti-lock  brake systems prevents dangerous 
downfalls in many cases whilst braking (panic 
stop).

Rider training is required in order to achieve the 
maximum advantages of Anti-lock  brake system

Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system

Economy of scales for Anti-lock  Braking System 
production, mid to long term drop of development 
and production cost 
Revenue and employment supplier industry

Innovation in Anti-lock  Brake System and braking 
technology

CBS is full alternative to Anti-lock  brake system, technical 
equivalence assumed between both systems from the 
perspective of accident avoidance.

Possible bad braking performance (adverse effects off-
road) if Anti-lock  Brake System fitted on Off-road PTW

Less burden (impact of legislation on vehicle design) in 
industry (mainly for big players, small manufacturers may 
still struggle to fulfil self regulation quota if above small 
series threshold)

In some Member States, discount on rider's insurance in 
case consumer opted for advanced brake system. Less cost
insurance companies for these cases.

Conventional consumer price development owing to supply 
and demand. No guarantee in the self regulation is provided 
that the cost of advanced brake systems will not be 
transferred to the end customer. Anti-lock Brake System 
might be available as an option only.

SME's under "normal" market pressure to equip 
produced vehicles with advanced brake systems. 
Concern related to access to technology  postponed / 
only mitigated, not eliminated
Estimated Percentage of fleet fitted with Anti-lock Brake 
System only estimated 16%, CBS: 7% in 2021

Consumer opting for Anti-lock  Brake System and/or 
CBS can only partly benefit from pressure on advanced 
brake system price (lower level of economy of scales for 
manufacturer)

Advanced brake system type chosen by consumer

Level of technical complexity of vehicle

Less complex legislation, remains technology neutral to the 
full extend by just defining brake performance criteria

Despite of voluntary self-regulation already applicable 
since 2004 and on schedule (35% of all PTWs equipped 
with advanced brake systems) the fatality statistics have 
not significantly decreased and remain to be static or 
slightly increasing.

Higher fleet penetration rate of Anti-lock  Brake System 
than if completely left to market demand
Long term societal and economic benefits owing to casualty 
mitigation . There are estimated to be between 5.5 and 13 
times (approximately between 30,000 and 72,000 riders) 
more heavily injured people than fatalities per year in the 
EU. Slight motorcycle casualties are lying within a range of 
12 and 28 times the numbers of fatalities (approximately 
between 66,000 and 155,000 riders) per annum in the EU. 
Based on the current available data it is not possible to 
forecast the level of mitigation in case of mandatory use of 
advanced brake system.

FATALITY REDUCTION 
Long term life saving (2011-2021)
Min.           Best Estimate                Max.
3,054

1,437

754

Benefit (million Euro), 2011 - 2021

Cost (million Euro), 2011 - 2021

Remarks / Other indicators

Low

Best estimate

High

Low

Best estimate

High

€ 648
€ 201
€ 26

€ 1,234
€382 - €888
€49 - €111

€ 2,621
€ 1,887
€ 236

€ 404

€ 1,338

€ 2,203

accident avoidance 
2011 - 2021
casualty mitigation 
2011 - 2021

Benefit: fatality avoidance
Benefit: mitigation heavy injuries
Benefit: mitigation slight injuries

Benefit to cost ratio, 2011 - 2021
Low        Best estimate          High

0.7

0.6

1.2 - 1.7

1.1 - 1.4

3.5

3.0

Table 69: Analysis table policy options obligatory fitting of advanced brake systems, option 5 

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2. 

ANTI-TAMPERING MEASURES  

Type of impact:

Economical
Environmental
Safety

Societal

2.1. 

No change; 

Option 1: No change

Positive
General interest in customising and modification, good for 
technical education

By-passing driver licensing restrictions 

Negative

Neutral  / Remarks

Large after-market industry that supplies 
equipment/services for the modification of vehicles. Some of
these modifications can be used to by-pass the existing anti-
tampering measures, therefore repealing these measures 
could have an economic impact on this market, which is 
likely to contain a number of SMEs. (not possible to quantify 
this impact)

Saving on road tax 

Saving on insurance premium
By-passing recurring technical inspections for special 
categories of vehicle
Emission of noise, exhaust emission levels, fuel 
consumption and CO2. In some cases application of after-
market components that do not increase power or 
maximum speed but do increase the noise levels 
substantially.
Higher maximum vehicle speed for e.g. Mopeds, which 
are designed for max. only 45 km/h.
Vehicles move more towards electronic manipulation, 
there is likely to be a negative safety impact as the 
existing anti-tampering measures become less effective 
(not possible to quantify) or become obsolete
Vehicles that have been tampered with are more likely to 
become involved in an accident.
Enforcement: vehicle compliance with chapter 7 not 
checked with the same intensity and frequency in all the 
EU27 Member States
Effectiveness of chapter 7, seven years after introduction 
largely unknown
Adverse economic impact on the suppliers of the parts 
which are no longer required (information stickers, 
frangible bolts etc.). Some may be SMEs.

Likely to have a negative effect on safety and would 
represent a backwards step from the current situation 
(MAIDS study indicated in 1999-2000, before introduction 
of chapter 7, 12.3% of mopeds had some form of engine 
or driveline tampering, which may be a very conservative 
estimate)
Enforcement: vehicle compliance with chapter 7 not 
checked with the same intensity and frequency in all the 
EU27 Member States (spot checks in Road Side 
Inspection or reoccurring in Periodical Technical 
Inspection)

Effectiveness of chapter 7, ten years after introduction 
largely unknown
Level of innovation
Most frequent tampering of original exhaust system, 
which possible contains exhaust after treatment 
technology to reduce emissions. Possible other 
tampering candidate: Engine Management System

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Tampering only limited to Mopeds and lower 
displacement motorcycles ? What will be effect of 
possible lower emission limits which may effect 
maximum performance on motorcycles with higher 
displacement ?
No additional manufacturer cost added if current 
anti-tampering measures for Mopeds and Light 
Motorcycles would be maintained.

Theft of vehicles

Other indicators

Not possible to quantify, no data available

Table 70: Analysis table policy options anti tampering measures, option 1 

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2.2. 

Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures; 

Option 2: Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures

Positive
General interest in customising and modification, good for 
technical education

Negative

Neutral  / Remarks

By-passing driver licensing restrictions 

Tampering only limited to Mopeds and lower 
displacement motorcycles ? What will be effect of 
possible lower emission limits which may effect 
maximum performance on motorcycles with higher 
displacement ?

Slightly less burden on OEM because one less approval to 
be obtained.

Saving on road tax 

Saving on insurance premium
By-passing recurring technical inspections for special 
Emission of noise, exhaust emission levels, fuel 
consumption and CO2. In some cases application of after-
market components that do not increase power or 
maximum speed but do increase the noise levels 
substantially.
Higher maximum vehicle speed for e.g. Mopeds, which 
are designed for max. only 45 km/h.
Vehicles move more towards electronic manipulation, 
there is likely to be a negative safety impact as the 
existing anti-tampering measures become less effective 
(not possible to quantify) or obsolete
Vehicles that have been tampered with are more likely to 
become involved in an accident.
Enforcement: vehicle compliance with chapter 7 not 
checked with the same intensity and frequency in all the 
EU27 Member States
Effectiveness of chapter 7, seven years after introduction 
largely unknown
Adverse economic impact on the suppliers of the parts 
which are no longer required (information stickers, 
frangible bolts etc.). Some may be SMEs.
Large after-market industry that supplies 
equipment/services for the modification of vehicles. 
Some of these modifications can be used to by-pass the 
existing anti-tampering measures, therefore repealing 
these measures could have an economic impact on this 
market, which is likely to contain a number of SMEs. (not 
possible to quantify this impact)
Likely to have a negative effect on safety and would 
represent a backwards step from the current situation 
(MAIDS study indicated in 1999-2000, before introduction 
of chapter 7, 12.3% of mopeds had some form of engine 
or driveline tampering, which may be a very conservative 
estimate)

Enforcement: vehicle compliance with chapter 7 not 
checked with the same intensity and frequency in all the 
EU27 Member States (spot checks in Road Side 
Inspection or reoccurring in Periodical Technical 
Inspection)
Effectiveness of chapter 7, ten years after introduction 
largely unknown

Most frequent tampering of original exhaust system, 
which possible contains exhaust after treatment 
technology to reduce emissions. Possible other 
tampering candidate: Engine Management System
Level of innovation
Theft of vehicles

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Not possible to quantify, no data available

Table 71: Analysis table policy options anti tampering measures, option 2 

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2.3. 

New measures on anti-tampering 

Option 3 New measures on anti-tampering

Positive
General interest in customising and modification, good for 
technical education

By-passing driver licensing restrictions 

Negative

Updated legal requirements to align with progress in 
technology

Saving on road tax 

Theft of vehicles
Level of innovation

Saving on insurance premium
By-passing recurring technical inspections for special 
categories of vehicle

Adverse economic impact on the suppliers of the parts 
which are no longer required or modified (information 
stickers, frangible bolts etc.). Some may be SMEs.

Improvements in emission of noise, exhaust emission 
levels, fuel consumption and CO2 owing to tampering 
prevention.
More difficult (expensive) to obtain a maximum vehicle 
speed for e.g. Mopeds over the legal limit of 45 km/h.
More appropriate anti-tampering measures, matching with 
technology, prevention of obsolete measures.

(more expensive) to tamper with become less involved in a 
road accident.
Enforcement: better vehicle compliance checking 
indications
Number of additional products for large after-market 
industry that supplies equipment/services for the 
modification of vehicles. Modifying / adding measures could 
have a positive economic impact on this market.

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Neutral  / Remarks
Minimum economic impact on manufacturers if the 
new measures can be designed into the vehicles in 
a similar way to the current measures

Additional cost owing to design/development of new 
parts that are not currently used for the existing 
measures, especially for SMEs. Positive impact on 
other suppliers (which could also be SMEs), who 
develop and sell solutions to cope with new 
requirements.

Economic impact on the after-market vehicle 
Tampering only limited to Mopeds and lower 
displacement motorcycles ? What will be effect of 
possible lower emission limits which may effect 
maximum performance on motorcycles with higher 
displacement ?

Other indicators

Not possible to quantify, no data available

Table 72: Analysis table policy options anti tampering measures, option 3 

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3. 

74 KW POWER LIMITATION FOR MOTORCYCLES 

Type of impact:

Economical
Environmental
Safety

Societal

Option 1: No change

Minimum Economic impact

Positive

Negative

Neutral  / Remarks

Cost to the manufacturers to produce the restricted 
motorcycles

Number of Member States that apply the 74kW 
power limit through national legislation could 
increase
Potential that, in the future, the number of Member 
States that apply the 74kW power limit through 
national legislation could increase
Sales within the markets affected that are currently 
not restricted ? Will there be an increase or 
decrease in sales ?
No clear evidence to suggest that limiting the power 
of a motorcycle to 74kW has a positive impact on 
the number of road accidents involving 
motorcycles. Other factors such as rider attitude 
and experience have a greater influence on 
accident risk
Effect on the noise generation, emissions and fuel 
consumption

Low

Benefit
Best estimate

High

Low

Cost
Best estimate

High

Other indicators

Option 2: Repeal the option given to Member States to limit the power to 74kW.

Positive

Negative

Any motorcycle that has a European approval can be 
registered in any Member State.
Member States that currently apply the 74kW power limit 
(currently thought to be only France) may rescind the 
National Legislation. This is likely to have a moderate 
positive economic impact

OEMs will not be required to add specific measures to 
vehicles for specific markets therefore this should result in a 
positive economic impact for the OEMs with respect to 
reduced technical and administrative costs

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Option 3: Set a harmonized limit of 74kW. 

Positive

Negative

Impact on some specialist manufacturers that 
concentrate on the production of high powered 
motorcycles, where maximum power is essential for their 
brand

Potential significant revenue loss to industry owing to 
some customers loosing interest in motorcycles

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Option 4: Use an alternative limitation.

Positive
If e.g. power to mass ratio would be considered as limitation 
criterion this may be more effective. No data available to 
substantiate assumption.

Negative

Risk of impact on the sales of new motorcycles if the 
new method of limitation is inconsistent with the 
requirements of the target market

Potential significant revenue loss to industry owing to 
some customers loosing interest in motorcycles

Cost
Best estimate
Table 73: Analysis table policy options 74 kW limitation, options 1 to 4 

Benefit
Best estimate

High

Low

Low

High

Neutral  / Remarks
Effect on the noise generation neutral, impact on 
emissions and fuel consumption may be negative
No clear evidence to suggest that limiting the power 
of a motorcycle to 74kW has a positive impact on 
the number of road accidents involving 
motorcycles. Other factors such as rider attitude 
and experience have a greater influence on 
accident risk

Other indicators

Neutral  / Remarks
No clear evidence to suggest that limiting the power 
of a motorcycle to 74kW has a positive impact on 
the number of road accidents involving 
motorcycles. Other factors such as rider attitude 
and experience have a greater influence on 
accident risk
Effect on the noise generation, emissions and fuel 
consumption

Other indicators

Neutral  / Remarks
No clear evidence to suggest that limiting the power 
of a motorcycle to 74kW has a positive impact on 
the number of road accidents involving 
motorcycles. Other factors such as rider attitude 
and experience have a greater influence on 
accident risk
Economic impact of this option will be dependent 
on the method of limitation that is selected
Effect on the noise generation, emissions and fuel 
consumption

Other indicators

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ANNEX XIII: DETAILS CHAPTER 5 — IMPACT ANALYSIS IMPROVED CATEGORISATION OF L-CATEGORY VEHICLES 

1. 

ELECTRICAL  CYCLES  (OUTSIDE  SCOPE  OF  FRAMEWORK  DIRECTIVE  CURRENTLY),  TRICYCLES  (L5E)  AND 
QUADRICYCLES (CATEGORY L6E AND L7E) 

Option 1: No change

Positive

Negative

Regulatory system costs unchanged, not possible to 
quantify more as the general statement that type 
approval cost per application is €10,000;

Technical standards meeting effort; current costs 
unchanged
Level of safety
Noise, emissions and fuel consumption; low negative 
impact. Not quantified; no data

Neutral  / Remarks
In the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars, but 2,500,000 electric bicycles 
anticipated to be on the market by 2011

Low

Benefit
Best estimate

High

Low

Cost
Best estimate

High

Other indicators

Option 2: Exclude quadricycles and electrical bi- and tri-cycles from the Framework Regulation; 

Positive

Negative

Significant cost increase if technical requirements vary 
between countries. Cost impact particularly high for 
SMEs

Transparency regulatory system

Level of safety

Noise, emissions and fuel consumption; low negative 
impact. Not quantified; no data

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Option 3: Return to the original spirit of the legislation for mini cars;

Transparency regulatory system

Level of safety

Positive

Negative

Noise, emissions and fuel consumption; low negative 
impact. Not quantified; no data
Possible additional compliance cost to manufacturer with 
revised criteria to re-categorise L-category vehicles

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Neutral  / Remarks
In the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars, but 2,500,000 electric bicycles 
anticipated to be on the market by 2011
Technical standards meeting effort; current costs 
unchanged

Other indicators

Neutral  / Remarks
In the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars, but 2,500,000 electric bicycles 
anticipated to be on the market by 2011

Regulatory system costs

Technical standards meeting effort unchanged

Other indicators

Option 4: Improving the legislation by adding new requirements based on car requirements for mini cars.

Transparency regulatory system

Positive

Technical requirements improved to M1 passenger car 
equivalent; improved safety
Noise, emissions and fuel consumption; Not quantified; no 
data

Negative

Align requirements as far as possible with M1 
requirements. Increase in scope for testing to match 
passenger cars would impose very significant additional 
cost on industry

Neutral  / Remarks
In the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars
Technical standards meeting effort unchanged

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Option 5: Improving the proliferation of vehicle categories by the introduction of dedicated sub categories in L1e, L5e, L6e and L7e. Add new / revised 
appropriate dedicated requirements for these sub categories.

Transparency regulatory system

Positive

Negative
Possible additional compliance cost to manufacturer with 
revised criteria to re-categorise L-category vehicles

Level of safety

Neutral  / Remarks
In the EU approximately 320.000 minicars, 800.000 
ATVs (in 2007, sales 158.000 vehicles per year), 
relatively small fleet in comparison to motorcycles 
or passenger cars
Technical standards meeting effort unchanged

Table 74: Analysis table policy options re-categorisation L1e, L5e, L6E & L7e, options 1 to 5. 

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2. 

Specific requirements for category L7e vehicles 

Option 1: No change

Positive

Negative

Neutral  / Remarks

Type approval costs unchanged
Casualty rates remain unchanged; current casualty rates 
appear high in relation to cars and PTWs. Not quantified; 
data insufficient to draw robust conclusions
Inappropriate / non-present safety measures
Inappropriate / non-present environmental measures

Low

Benefit
Best estimate

High

Low

Cost
Best estimate

High

Other indicators

Option 2: Exclude off-road quads from the Framework Directive.

Positive

Negative

Neutral  / Remarks

ATVs approved at national level. Increase in cost to 
manufacturers over current situation, potentially requiring 
€10,000 per vehicle for approval in each member state

Different national approval requirements. Not quantified; 
risk of divergent requirements leading to trade barriers

Approved as machines or other alternative. Not 
quantified; effect on casualties not clear
Inappropriate / non-present safety measures
Inappropriate / non-present environmental measures

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Option 3: Keep the existing category and add new requirements on safety for all quads.
Negative

Positive

Appropriate safety measures. Possibility to include 
international standards (CEN / ISO / UN ECE)

Appropriate environmental measures. Possibility to include 
international standards (CEN / ISO / UN ECE)

Add new requirements for all quadricycles (Quads and 
mini cars) in terms of cost. Risk that requirements for 
one vehicle type are not applicable for the other and vice 
versa. Not quantified; insufficient data but cost increase if 
additional tests added. Likely to also result in increased 
cost to consumers
Emissions resulting from travel to/from technical 
standards meetings

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Still complex, difficult to interpret and to differentiate 
between different vehicle types
Cost
Best estimate

High
Not possible to quantify, no data available

Low

Other indicators

Neutral  / Remarks

Add new requirements for all quadricycles. Not 
quantified ; effect on casualties not clear

Other indicators

Option 4: Create a new category for off-road quadricycles with specific requirements.

Positive

Negative

Neutral  / Remarks

Simplification. Clearer, more appropriate measures. 
Reduction of obsolete or redundant requirements

Emissions resulting from travel to/from technical 
standards meetings

Add new Quadricycle category and specific 
requirements. Not quantified; cost increase over 
current situation if additional to current 
requirements but reduction possible if specific 
requirements mean reduced cost

Add new Quadricycle category and specific requirements. 
Not quantified; effect on casualties not clear. Targeted 
measures may be more effective at reducing casualties 
than Option C.

Reduced compliance cost for manufacturers, better cost 
effectiveness of measures, lower consumer prices.
Appropriate safety measures. Possibility to include 
international standards (CEN / ISO / UN ECE)
Appropriate environmental measures. Possibility to include 
international standards (CEN / ISO / UN ECE)

No clear separation between on-road and off-road quad 
classification possible, based on design criteria only . 
High risk of easy circumnavigating strict safety and 
environmental type-approval requirements for on-road 
quads by simple and inexpensive modification of off-road 
quads

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Table 75: Analysis table policy options specific requirements for Category L7e vehicles, options 1 to 4. 

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3. 

Dedicated requirements for gaseous alternative fuels and other non-traditional propulsions. 

Option 1: No change (legislation at National level)

Positive

Negative

Neutral  / Remarks

Type approval costs unchanged. Potentially high costs 
for approval in multiple countries and this may be 
inhibiting investment in market. Not quantified; no 
available data
Different national approval requirements. Not quantified; 
risk of divergent requirements leading to trade barriers
In appropriate / non present safety measures
In appropriate / non present environmental measures

Low

Benefit
Best estimate

High

Low

Cost
Best estimate

High

Other indicators

Option 2: Legislation at European Union level through a tighter grid of vehicle type categorisation with dedicated measures for the different vehicles and 
propulsion technologies.

Positive

Negative

Neutral  / Remarks

Type approval costs unchanged or estimated higher. 
Also conflicting stakeholder responses that would a) 
promote investment through a clearer market or b) inhibit 
innovation by more test and cost requirements
Not sufficient technical experience with and impacts of 
e.g. large scale industrial hydrogen L-category vehicle 
technology. 

Global Technical Regulation on Hydrogen 
technology is being developed. L-category vehicles 
propelled on hydrogen are excluded as the 
technology is not considered mature yet.

Appropriate safety measures. Possibility to include 
international standards (CEN / ISO / UN ECE)

Appropriate environmental measures. Possibility to include 
international standards (CEN / ISO / UN ECE)

Environmental benefit: lower particulate matter emissions, 
lower non-methane hydrocarbon emissions, lower CO 
emissions, similar NOx emissions. In case of CNG / Biogas: 
significant lower CO2 emissions.
Simplification. Clearer, more appropriate measures. 
Reduction of obsolete or redundant requirements
Add new fuel specific requirements. Not quantified; effect on 
casualties not clear. Targeted measures may be more 
effective at reducing casualties than option 1.
Level of innovation in safety and environmental technology 
may increase, with potential opportunities for SMEs.

Benefit
Best estimate

Low

High
Not possible to quantify, no data available

Cost
Best estimate

Low

High
Not possible to quantify, no data available

Other indicators

Table  76:  Analysis  table  policy  options  dedicated  requirements  for  gaseous  alternative  fuels  and  other  non-traditional 
propulsions. 

EN 

114 

   EN 

 
 
ANNEX  XIV:  DETAILS  CHAPTER  6  —  OPTIONS  COMPARISON  AND  CONCLUSIONS  SIMPLIFICATION  OF  THE 

LEGISLATION 

The  positive  point  in  option  1,’no  policy  change’  is  that  no  risk  of  loss  in  quality  of  requirements  would  be 
introduced by replacing provisions of EU Directives by references to international standards. A negative side 
of option 1 is that the concerns for manufacturers and administrations will remain, which is not in line with the 
Better Regulation objective. Continuing this approach would thus add unnecessary administrative burden on 
stakeholders. To reply to the concerns about a weakening of requirements, it is intended that references will 
only be proposed in cases where the international standards are at least equal to the relevant EU Directives. 

By moving from directives to the legislative instrument of regulations, option 2 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, as this continues to be the case for options 1 and 3. Hence, all discrepancies between national 
transposition  acts  would  be  avoided.  In  addition,  today  the  Commission  services  work  on  their  own 
documents and on those from UNECE, etc. It would be much more efficient and more cost-effective for the 
representatives  of  Member  States  and  also  for  the  Commission  services  if  the  technical  details  were  no 
longer duplicated in different set of legislations. 

With  the  introduction  of  the  split-level  approach,  the  Council  and  Parliament  can  concentrate  on  the  most 
important  and  perhaps  controversial  issues  that  require  political  debate  and  agreement,  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 of the co-legislators also 
for comitology acts. Additional advantages of options 2 and 3 compared to option 1 are that the legislation 
will be simplified by suppressing useless duplications and that the fast developments in technical progress, 
possible new or revised environmental and safety measures can be smoothly integrated, while executing the 
simplification  exercise.  In  terms  of  cost  benefit  is  option  2  superior  to  option  3,  as  the  cost  for  national 
transposition and surveillance of compliance cost will not apply. 

In  conclusion  the  advantages  of  option  2  outweigh  by  far  its  disadvantages  and  are  more  beneficial  than 
choosing for options 1 or 3. Therefore the preferred option would be to simplify the legislation by introducing 
a  co-decision  Regulation with  a  limited  number  of  implementing Regulations  through Comitology,  using as 
much as possible the standards available from UNECE, CEN/CENELEC and ISO.  

EN 

115 

   EN 

 
 
Explanation:

__ __  much worse
__
worse
neutral (no change)
better
much better

0
+
++

Option 1: No policy change

Objective

Policy options

1: No policy change

Effectiveness

0

Option 2: Repeal current directives and replace with a minimum number of regulations

Objective

Policy options

Effectiveness

simplification of the 
regulatory framework

Improved global 
harmonization
better and clearer structure 
of legal text
technical standards meeting 
effort reduced for Industry  & 
EU-27
emissions resulting from 
travel to/from technical 
standards meetings reduced 
for Industry/EU-27
loss in safety and 
environmental protection

++

++

++

0

0

0

n
o
i
t
a
c
i
f
i
l

p
m
S

i

2: Repeal current directives and 
replace with a minimum number 
of regulations                 

Option 3: Repeal current directives and replace with a minimum number of regulations

Objective

Policy options

Effectiveness

simplification of the 
regulatory framework

Improved global 
harmonization
better and clearer structure 
of legal text
technical standards meeting 
effort reduced for Industry  & 
EU-27
emissions resulting from 
travel to/from technical 
standards meetings reduced 
for Industry/EU-27
loss in safety and 
environmental protection

++

++

++

0

0

0

n
o
i
t
a
c
i
f
i
l

p
m
S

i

3: Repeal current directives and 
replace with a minimum number 
of regulations

Criteria
Efficiency

Criteria
Efficiency

initial cost

reduced annual implementation cost of 
regulatory system 
translation cost eliminated

risk of delaying urgent matters

cost reduction on the long term

quick process of adaptation to technical 
evolution in the future
benefits of new measures can be 
accrued more rapidly
transparent regulatory system / 
democratic gap
length of processing: agreeing on one 
text including all requirements

Criteria
Efficiency

initial cost

reduced annual implementation cost of 
regulatory system 
translation cost eliminated if direct 
reference to technical standard
risk of delaying urgent matters

cost reduction on the long term

quick process of adaptation to technical 
evolution in the future
benefits of new measures can be 
accrued more rapidly
transparent regulatory system / 
democratic gap
length of processing: agreeing on one 
text including all requirements

0

__

+

+

0

++

0

+

0

__

__

0

0

__

+

_

0

0

__

Table 77: option comparison and conclusion table — simplification 

Coherence

Conclusion 

0

0

Conclusion 

Coherence

better coherence than option 1, 
in the long run also better than 
option 3
increased clarity for industry 
and other stakeholders

++

++

++

Conclusion 

Coherence

better coherence than option 1, 
in the long run also better than 
option 3
increased clarity for industry 
and other stakeholders

++

++

+

EN 

116 

   EN 

 
 
 
 
ANNEX  XV:  DETAILS  CHAPTER  6  —  OPTIONS  COMPARISON  AND  CONCLUSIONS  VEHICLE  TYPE  APPROVAL 

ENVIRONMENTAL MEASURES 

1. 

New or revised environmental measures for the type approval of new vehicles 

1.1. 

Revised lower emissions limits. 

Explanation:

__ __  much worse
__
worse
neutral (no change)
better
much better

0
+
++

Option 1: No change

Objective

Policy options

)
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:
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j
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l
a
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m
n
o
r
i
v
n
E

-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e

e
v
i
t
a
r
o
p
a
v
e
e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o

f
o
%
3
(

e
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l
a
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c
a
r
i
e
h
t
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t

e
t
a
n
o
i
t
r
o
p
o
r
p
s
n
o
i
s
s
i
m
e

y
r
o
g
e
t
a
c

Effectiveness

Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate 
Matter emissions as share of total road 
transport emissions.
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport

Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for 
part or all of L-category vehicle industry
Products of superior quality withstanding global 
competition.
Possible generation of new jobs in suppliers of 
emission control systems

Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective
Increasing tampering practices

0

0

0

0

0

0

0

0

Criteria

Efficiency

Estimated speed of implementation 
(short implementation time)

Compliance cost

Risk of cost transferred to consumer

0

0

0

Coherence

Conclusion 

Better coherence than options 2,3,4,5 ?

Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

0

0

0

0

0

0

Table 78: option comparison and conclusion table, revised emission limits, option 1  

Option 2: : New emission limits for L1 mopeds: a cold-start r47 test cycle and a 30% weighing factor for the cold start are proposed to be applied. (Scenario 1 from LAT report). No change in limits for 
other L-category vehicles.
Objective

Policy options

Criteria

)
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g
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l
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m
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l
a
t
o
t

f
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%
3
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p
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n
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p
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m
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f
n
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l
l

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p
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a

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c
u
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e
r

:
e
v
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c
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j
b
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l
a
t
n
e
m
n
o
r
i
v
n
E

s
n
o
i
s
s
i
m
e

y
r
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g
e
t
a
c
-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e
e
v
i
t
a
r
o
p
a
v
e

e
c
u
d
e
r
d
n
a

Effectiveness

Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate 
Matter emissions as share of total road 
transport emissions.
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport

Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for 
part or all of L-category vehicle industry
Products of superior quality withstanding global 
competition.
Possible generation of new jobs in suppliers of 
emission control systems

Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective
Increasing tampering practices

__

__ __

__ __

__ 

__

0

0

0

Efficiency

Estimated speed of implementation 
(short implementation time)

Coherence

Conclusion 

Better coherence than options 2,3,4,5 ?

Compliance cost

Risk of cost transferred to consumer

++

0

0

Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

__ __

__ __

__ __

__ __

__ __

__

Table 79: option comparison and conclusion table, revised emission limits, option 2  

EN 

117 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Option 3: Motorcycle industry proposal (Scenario 2 from LAT report)

Objective

Policy options

)
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g
a
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l
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m
d
a
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l
a
t
o
t

f
o
%
3
(

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a
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p
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p

n
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p
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m
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f
n
o
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l
l

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p
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c
u
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e
r

:
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j
b
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l
a
t
n
e
m
n
o
r
i
v
n
E

s
n
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s
s
i
m
e

y
r
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g
e
t
a
c
-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e

e
v
i
t
a
r
o
p
a
v
e

e
c
u
d
e
r
d
n
a

Effectiveness

Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate 
Matter emissions as share of total road 
transport emissions.
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport

Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for 
part or all of L-category vehicle industry
Products of superior quality withstanding global 
competition.
Possible generation of new jobs in suppliers of 
emission control systems

Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective
Increasing tampering practices

+

0

++

+

+

0

0

0

Criteria

Efficiency

Estimated speed of implementation 
(short implementation time)

Compliance cost

Risk of cost transferred to consumer

++

0

0

Coherence

Conclusion 

Better coherence than options 1,2,4,5 ?

Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

__ __

+

+

0

__

++

Table 80: option comparison and conclusion table, revised emission limits, option 3  

Option 4: New measures based on the Best Available Technology applied on L-category vehicles sold today in the market (Scenario 3 from LAT report)

Objective

Policy options

)
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g
a
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l
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m
d
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l
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t

f
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%
3
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n
E

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v
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t
a
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p
a
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e
r
d
n
a

Effectiveness

Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate 
Matter emissions as share of total road 
transport emissions.
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport

Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for 
part or all of L-category vehicle industry
Products of superior quality withstanding global 
competition.
Possible generation of new jobs in suppliers of 
emission control systems

Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective
Increasing tampering practices

+

0

++

+

+

0

0

0

Criteria

Efficiency

Coherence

Conclusion 

Estimated speed of implementation 
(short implementation time)

Better coherence than options 1,2, 3 
and 5 ?

Compliance cost

Risk of cost transferred to consumer

__ __

__

__

Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

__

+

+

0

__

+

Table 81: comparison and conclusion table, revised emission limits, option 4 

Option 5: New limits for all L-category vehicles equivalent in absolute terms to Euro5 M1 light-duty vehicles (4th scenario from LAT report)

Objective

Policy options

s
n
o
i
s
s
i
m
e

y
r
o
g
e
t
a
c
-
L

l
i
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e

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p
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d
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l
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f
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%
3
(

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r
i
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h
t
o
t

e
t
a
n
o
i
t
r
o
p
o
r
p

Effectiveness

Level of reduction of all air pollutants emitted by 
L-category vehicles but in particular: 
Hydrocarbon, Carbon Monoxide and Particulate 
Matter emissions as share of total road 
transport emissions.
Impact of L-category vehicle high level of 
emissions on capability of reducing emissions 
from other means of road transport

Only one or limited amount of L-category 
vehicles comply with revised thresholds, so 
distribution of burden to reduce emissions for 
part or all of L-category vehicle industry
Products of superior quality withstanding global 
competition.
Possible generation of new jobs in suppliers of 
emission control systems

Risk of large price increases might lead to loss 
of jobs in manufacturing including SMEs
Risk of less frequent vehicle replacement, 
leading to longer time before new measures 
become effective
Increasing tampering practices

++

+

++

++

++

__

__

__

d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f
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r

:
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v

i
t
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e
b
o

j

l

a
t
n
e
m
n
o
r
i

v
n
E

Criteria

Efficiency

Coherence

Conclusion 

Estimated speed of implementation 
(short implementation time)

Better coherence than options 1,2, 3 
and 5 ?

Compliance cost

Risk of cost transferred to consumer

__ __

__

__ __

Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

+

+

++

+

+

++

Table 82: comparison and conclusion table, revised emission limits, option 5 

EN 

118 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.2. 

Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-category 
vehicle categories. 

Explanation:

__ __  much worse
__
worse
neutral (no change)
better
much better

0
+
++

Option 1: No change

Objective

Policy options

e
c
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d
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r
d
n
a
n
o
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t
a
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p
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t

f
o
%
3
(
e
s
u

Effectiveness

Representation of off-cycle, real world 
emissions and fuel consumption

Increase cost of tampering / "cycle beating", 
therefore make it less attractive

0

0

Criteria

Efficiency

Compliance cost short term

Compliance cost mid to long term

Economy of scale for manufacturers 
that globally market L-category vehicles

Option 2: Use of the phase 2 World Motorcycle Testing Cycle (WMTC) for all L-category vehicle classes

Effectiveness

Representation of off-cycle, real world 
emissions and fuel consumption

Increase cost of tampering / "cycle beating", 
therefore make it less attractive

+

+

Criteria

Efficiency

Compliance cost short term

Compliance cost mid to long term

Economy of scale for manufacturers 
that globally market L-category vehicles

Objective

Policy options

)
e
g
a
e
l
i

m

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L

l
i
t
n
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s
n
o
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s
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p
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f
n
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p

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%
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r
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e
t
a
c

Coherence

Conclusion 

0

0

0

Amount of test cycles developed from 
historic reasons that may obsolete

Transparency of vehicle emission 
performance and fuel economy 
between the different vehicles of the L-
category.
Transparency of vehicle emission 
performance and fuel economy 
between  L-category vehicle and 
alternative means of transport (e.g. 
passenger cars or other).

0

0

0

0

Coherence

Conclusion 

Amount of test cycles developed from 
historic reasons that may obsolete

__

0

+

Transparency of vehicle emission 
performance and fuel economy 
between the different vehicles of the L-
category.
Transparency of vehicle emission 
performance and fuel economy 
between  L-category vehicle and 
alternative means of transport (e.g. 
passenger cars or other).
Transparent change (cost and/or 
emission impact) if phase 2 WMTC 
would replace phase 1

+

++

+

++

++

Table 83: comparison and conclusion table Use of a revised World-wide Motorcycle emissions Testing Cycle (WMTC) for all L-
category vehicle categories 
Current test cycle

L-category 
vehicle type

Emission 
step

Test cycle

L-category 
vehicle type

Emission 
step

Proposal for future test cycles
Emission 
step

Test 
cycle

Test 
cycle

L1A

L1

R47

Euro 2

L5

R47

Euro 2

L2
L3
L4

N.A.
R47
R47

Euro 2
Euro 3 EDC / WMTC
Euro 3 EDC / WMTC

N.A.
Euro 3 & 4
Euro 3 & 4
Euro 4 & 5 WMTC
Euro 4 & 5 WMTC
Euro 3 & 4 WMTC
Euro 3 & 4
Euro 3 & 4
Euro 3 & 4
Euro 3 & 4 WMTC
Euro 3 & 4
Table 84: Summary table containing proposal to transition to preferred option 2 (use of WMTC for all L-category vehicles) 
NB Also please notes that for certain L-category vehicles (L1e, L2e, L6E and L7e) the scope of the WMTC 
under UNECE Global Technical Regulation 2 must be widened. 

Euro 5 WMTC To be developped in UN ECE
Euro 5 WMTC
Euro 6 WMTC
Euro 6 WMTC
Euro 5 WMTC
Euro 5 WMTC
Euro 5 WMTC
Euro 5 WMTC
Euro 5 WMTC
Euro 5 WMTC

L1B
L2
L3
L4
L5A
L5B
L6A
L6B
L7A
L7B

Same as for L1B
Same as for L1B

Same as for L1B

R40
R47
R47

Euro 2

Euro 2

R40

R40

R47

R40

L6

L7

Remark
N.A. is not applicable, full 
electrical vehicles only

Figure 22: Example of how the existing Moped test cycle R47 can be replaced by a WMTC based test cycle. 

EN 

119 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.3. 

Type-approval requirements for CO2 measurement and fuel consumption determination and 
reporting 

Option 1: No change

Objective

Policy options

)
e
g
a
e
l
i

m
d
a
o
r

l
a
t
o
t

f
o
%
3
(

s
n
o
i
s
s
i
m
e

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v
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t
a
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p
a
v
e
e
c
u
d
e
r

e
c
u
d
e
r

:
e
v
i
t
c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f
n
o
i
t
u

l
l

o
p
r
i
a

s
n
o
i
s
s
i
m
e

y
r
o
g
e
t
a
c
-
L

l
i
t
n
u

e
s
u

l
a
u
t
c
a
r
i
e
h
t
o
t

e
t
a
n
o
i
t
r
o
p
o
r
p

Effectiveness

Paving the ground for the introduction of an 
energy efficiency labelling schem. Allowing then 
the consumer to select optimum fuel efficient 
vehicle:
- between different alternative L-category 
vehicles
- between L-category vehicles and alternative 
means of road transport

0

Option 2: Type Approval for CO2 and fuel consumption, vehicle labelling
Policy options

Objective

Effectiveness

Paving the ground for the introduction of an 
energy efficiency labelling schem. Allowing then 
the consumer to select optimum fuel efficient 
vehicle:
- between different alternative L-category 
vehicles
- between L-category vehicles and alternative 
means of road transport

++

)
e
g
a
e
l
i

m

-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e
e
v
i
t
a
r
o
p
a
v
e

r
i
a

e
c
u
d
e
r

:
e
v
i
t
c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f
n
o
i
t
u

l
l

o
p

d
a
o
r

l
a
t
o
t

f
o
%
3
(

e
s
u

l
a
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t
c
a
r
i
e
h
t

o
t

e
t
a
n
o
i
t
r
o
p
o
r
p
s
n
o
i
s
s
i
m
e
y
r
o
g
e
t
a
c

Criteria

Efficiency

Cost of development to Member State 
to develop proprietary labelling system, 
if not EU wide available

Coherence

Conclusion 

Uniform EU-wide indication of CO2 
emission and fuel consumption

Compliance cost of manufacturers and 
further downstream

Criteria

Efficiency

Cost of development to Member State 
to develop proprietary labelling system, 
if not EU wide available

0

0

+

Stakeholders less confused, level of 
awareness

0

0

0

Coherence

Conclusion 

Uniform EU-wide indication of CO2 
emission and fuel consumption

Compliance cost of manufacturers and 
further downstream

__

Stakeholders less confused, level of 
awareness

++

++

++

Table  85:  comparison  and  conclusion  table  Type-approval  requirements  for  CO2  measurement  and  fuel  consumption 
determination and reporting 

EN 

120 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.4. 

Evaporative emissions test and limit 

Option 1: No change

Objective

Policy options

)
e
g
a
e
l
i

m

-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
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e
v
i
t
a
r
o
p
a
v
e

r
i
a

e
c
u
d
e
r

:
e
v
i
t
c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f
n
o
i
t
u

l
l

o
p

d
a
o
r

l
a
t
o
t

f
o
%
3
(
e
s
u

l
a
u
t
c
a
r
i
e
h
t

o
t

e
t
a
n
o
i
t
r
o
p
o
r
p
s
n
o
i
s
s
i
m
e

y
r
o
g
e
t
a
c

Evaporative hydrocarbon emission level

Effectiveness

Reducing exhaust and evaporative emissions

Level of cost effectiveness compared to other 
methods to reduce hydrocarbon emissions

Availability of independent testing facilities 
(SHED chamber) for authorities, but also for 
SME
Evaporative emissions controlled under different 
ambient conditions (hot climate, stop and go 
traffic) and/or over vehicle life.

0

0

0

0

0

Criteria

Efficiency

Additional compliance cost

Investment in evaporative emission 
control technology development of 
hardware and software. Additional cost 
may be passed on to customers
Revenue to supplier industry, including 
SMEs, potentially leading to effects on 
employment

0

0

0

Coherence

Conclusion 

Better coherence than options 2 and 3 
?
Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

0

0

0

0

0

0

Option 2: Replacement of all new carburetted models with fuel injected ones. Due to the closed circuit, fuel injection engines result in much lower evaporation emissions than carburetted ones

Objective

Policy options

)
e
g
a
e
l
i

m
d
a
o
r

l
a
t
o
t

f
o
%
3
(

m
o
r
f
n
o
i
t
u

l
l

o
p
r
i
a

e
c
u
d
e
r

:
e
v
i
t
c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e

e
v
i
t
a
r
o
p
a
v
e

e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o

e
s
u

l
a
u
t
c
a
r
i
e
h
t
o
t

e
t
a
n
o
i
t
r
o
p
o
r
p
s
n
o
i
s
s
i
m
e

y
r
o
g
e
t
a
c

Criteria

Efficiency

Additional compliance cost

Investment in evaporative emission 
control technology development of 
hardware and software. Additional cost 
may be passed on to customers
Revenue to supplier industry, including 
SMEs, potentially leading to effects on 
employment

Evaporative hydrocarbon emission level

Effectiveness

Reducing exhaust and evaporative emissions

Level of cost effectiveness compared to other 
methods to reduce hydrocarbon emissions. 
NB assumption that investment in EFI will only 
be done to reduce evaporative emission is a 
theoretical assumption, therefore are the 
assumed cost and cost efficiency of this option 
estimated too high. No data available to quantify 
the level of magnitude of this too high estimate.

Availability of independent testing facilities 
(SHED chamber) for authorities, but also for 
SMEs

Evaporative emissions controlled under different 
ambient conditions (hot climate, stop and go 
traffic) and/or over vehicle life.

+

++

0

__

__

Option 3: Evaporative emissions test and limit enforcing evaporative emission control for all L-category vehicles

Objective

Policy options

)
e
g
a
e
l
i

m
d
a
o
r

l
a
t
o
t

f
o
%
3
(
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s
u

l
a
u
t
c
a
r
i
e
h
t
o
t

e
t
a
n
o
i
t
r
o
p
o
r
p
s
n
o
i
s
s
i
m
e

y
r
o
g
e
t
a
c

m
o
r
f
n
o
i
t
u

l
l

o
p
r
i
a

e
c
u
d
e
r

:
e
v
i
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c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e

e
v
i
t
a
r
o
p
a
v
e
e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o

Criteria

Efficiency

Additional compliance cost

Investment in evaporative emission 
control technology development of 
hardware and software. Additional cost 
may be passed on to customers
Revenue to supplier industry, including 
SMEs, potentially leading to effects on 
employment

Evaporative hydrocarbon emission level

Effectiveness

Reducing exhaust and evaporative emissions

Level of cost effectiveness compared to other 
methods to reduce hydrocarbon emissions. 
NB assumption that investment in EFI will only 
be done to reduce evaporative emission is a 
theoretical assumption, therefore are the 
assumed cost and cost efficiency of this option 
estimated too high. No data available to quantify 
the level of magnitude of this too high estimate.

Availability of independent testing facilities 
(SHED chamber) for authorities, but also for 
Evaporative emissions controlled under different 
ambient conditions (hot climate, stop and go 
traffic) and/or over vehicle life.

++

0

++

__

__

Table 86: comparison and conclusion table evaporative emissions test and limit 

__

__

++

__

__

++

Coherence

Conclusion 

Better coherence than options 2 and 3 
?
Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

+

+

++

__

+

+

Coherence

Conclusion 

Better coherence than options 1 and 2 
?
Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

+

+

++

__

+

++

EN 

121 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Coherence

Conclusion 

1.5. 

Durability requirements 

Option 1: No change

Objective

Policy options

Effectiveness

Controlled degradation of exhaust emissions 
relevant engine components and systems

Effect of actual defined vehicle mileage once 
opted to introduce durability requirements

Combined measure together with revised Type 
Approval emission limits

Possible emission reduction level

)
e
g
a
e
l
i

m
d
a
o
r

l
a
t
o
t

f
o
%
3
(
e
s
u

l
a
u
t
c
a

n
o
i
t
u

l
l

o
p
r
i
a

e
c
u
d
e
r

:
e
v
i
t
c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

r
i
e
h
t
o
t

e
t
a
n
o
i
t
r
o
p
o
r
p
s
n
o
i
s
s
i
m
e
y
r
o
g
e
t
a
c
-
L

l
i
t
n
u

s
n
o
i
s
s
i
m
e
e
v
i
t
a
r
o
p
a
v
e

e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f

Criteria

Efficiency

Compliance cost for manufacturers 
possibly transferred into high consumer 
price
Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money 
over vehicle life in terms of steady 
environmental performance over vehicle 
life.
Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of 
expensive exhaust after treatment 
components.

0

0

0

0

0

0

0

Better coherence than options 2 and 3 
?

Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

Option 2 (Scenario 2 from the LAT report): Deterioration reduced to 10% for the useful life and application of linear extrapolation for higher mileage

Objective

Policy options

)
e
g
a
e
l
i

m
d
a
o
r

s
n
o
i
s
s
i
m
e
y
r
o
g
e
t
a
c
-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e

e
v
i
t
a
r
o
p
a
v
e
e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f

l
a
t
o
t

f
o
%
3
(

e
s
u

l
a
u
t
c
a
r
i
e
h
t
o
t
e
t
a
n
o
i
t
r
o
p
o
r
p

n
o
i
t
u

l
l

o
p
r
i
a

e
c
u
d
e
r

:
e
v
i
t
c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

Effectiveness

Controlled degradation of exhaust emissions 
relevant engine components and systems

Effect of actual defined vehicle mileage once 
opted to introduce durability requirements

Combined measure together with revised Type 
Approval emission limits

Possible emission reduction level

Criteria

Efficiency

Compliance cost for manufacturers 
possibly transferred into high consumer 
price
Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money 
over vehicle life in terms of steady 
environmental performance over vehicle 
life.
Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of 
expensive exhaust after treatment 
components.

++

0

++

+

Coherence

Better coherence than options 1 and 2 
?

__

Increased clarity for industry and other 
stakeholders

++

+

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

0

0

0

0

0

0

+

+

__

+

0

Conclusion 

++

Option 3 (Scenario 2 from the LAT report): useful life increased by 60%, i.e. equivalent to the increase incurred to passenger cars when shifting from Euro 3 (80k km) to Euro 5 (160k km)

Objective

Policy options

)
e
g
a
e
l
i

m
d
a
o
r

s
n
o
i
s
s
i
m
e
y
r
o
g
e
t
a
c
-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e

e
v
i
t
a
r
o
p
a
v
e

e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f

l
a
t
o
t

f
o
%
3
(
e
s
u

l
a
u
t
c
a
r
i
e
h
t
o
t

e
t
a
n
o
i
t
r
o
p
o
r
p

n
o
i
t
u

l
l

o
p
r
i
a

e
c
u
d
e
r

:
e
v
i
t
c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

Effectiveness

Controlled degradation of exhaust emissions 
relevant engine components and systems

Effect of actual defined vehicle mileage once 
opted to introduce durability requirements

Combined measure together with revised Type 
Approval emission limits

Possible emission reduction level

Criteria

Efficiency

Compliance cost for manufacturers 
possibly transferred into high consumer 
price
Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money 
over vehicle life in terms of steady 
environmental performance over vehicle 
life.
Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of 
expensive exhaust after treatment 
components.

++

0

++

++

Coherence

Conclusion 

Better coherence than options 1 and 2 
?

__ __

Increased clarity for industry and other 
stakeholders

++

+

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

0

+

+

__

++

+

Table 87: comparison and conclusion table durability requirements 

EN 

122 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2. 

NEW MEASURES TO CONTROL EMISSIONS DURING VEHICLE LIFE. 

2.1. 

In-Use Conformity (IUC) testing and limits. 

Option 1: No change

Objective

Policy options

)
e
g
a
e
l
i

m
d
a
o
r

s
n
o
i
s
s
i
m
e

y
r
o
g
e
t
a
c
-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e

e
v
i
t
a
r
o
p
a
v
e

e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f

l
a
t
o
t

f
o
%
3
(
e
s
u

l
a
u
t
c
a
r
i
e
h
t
o
t

e
t
a
n
o
i
t
r
o
p
o
r
p

n
o
i
t
u

l
l

o
p
r
i
a

e
c
u
d
e
r

:
e
v
i
t
c
e
j
b
o

l
a
t
n
e
m
n
o
r
i
v
n
E

Effectiveness

Controlled degradation of exhaust emissions 
relevant engine components and systems

Combined measure together with revised Type 
Approval emission limits

Possible emission reduction level

Cost effectiveness

Criteria

Efficiency

Compliance cost for manufacturers 
possibly transferred into high consumer 
price
Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money 
over vehicle life in terms of steady 
environmental performance over vehicle 
life.
Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of 
expensive exhaust after treatment 
components.

0

0

0

0

0

0

0

Option 2: (Scenario 1 from LAT report): IUC procedure mandatory to for all Euro 3 motorcycles. The IUC is considered to identify all not attainments which are consecutively corrected. 

Objective

Policy options

)
e
g
a
e
l
i

m
d
a
o
r

s
n
o
i
s
s
i
m
e
y
r
o
g
e
t
a
c
-
L

l
i
t
n
u
s
n
o
i
s
s
i
m
e

e
v
i
t
a
r
o
p
a
v
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e
c
u
d
e
r
d
n
a
n
o
i
t
a
r
e
p
o
m
o
r
f

l
a
t
o
t

f
o
%
3
(

e
s
u

l
a
u
t
c
a
r
i
e
h
t
o
t
e
t
a
n
o
i
t
r
o
p
o
r
p

n
o
i
t
u

l
l

o
p
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r

:
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j
b
o

l
a
t
n
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m
n
o
r
i
v
n
E

Effectiveness

Controlled degradation of exhaust emissions 
relevant engine components and systems

Combined measure together with PTI and RSI, 
overlap

Possible emission reduction level

Cost effectiveness

Selection of representative vehicles

Criteria

Efficiency

Compliance cost for manufacturers 
possibly transferred into high consumer 
price
Increased quality and guarantee for 
customer that investment in cleaner 
vehicle gives better  value for money 
over vehicle life in terms of steady 
environmental performance over vehicle 
life.
Reduced risk for customers to fail PTI 
tests in the Member States where this 
applies. Prevent early on exchange of 
expensive exhaust after treatment 
components.

+

__

__ __

__

__ __

Coherence

Better coherence than option 0 ?

__ __

Increased clarity for industry and other 
stakeholders

+

0

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

Table 88: comparison and conclusion table possible introduction of In-Use Conformity (IUC) testing and limits 

Coherence

Conclusion 

Better coherence than option 1 ?

Increased clarity for industry and other 
stakeholders

Appropriate environmental measures 
for complete different vehicles

Level of simplification
Transparency with emission 
performance of other, alternative 
means of road transport

0

0

0

0

0

0

0

+

__

+

0

Conclusion 

__

EN 

123 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.2. 

On Board Diagnostic (OBD) systems and access to repair information 

Option 1: No change (No introduction of OBD systems)

Objective

Policy options

Effectiveness

Criteria

Efficiency

Coherence

Conclusion 

s
n
o
i
s
s
i
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e
y
r
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g
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t
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m
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o
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v
n
E

Environmental impact

0 Compliance cost manufacturers

Ignoring Malfunction Indicator Light by customer

Functional safety impact

Standardised diagnostic information, available 
on request of generic scan tool
Anti-tampering measure

0

0

0

Employment at manufacturers

Initial investment cost for manufacturer

Effectiveness of repair (perspective 
independent repairer)

0 Repair cost for customer (if repaired by 

independent repairer)

Employment and revenue suppliers, 
type approval authorities, test 
l b

0 Cost of PTI in Member States that 
conduct this for L-category vehicles

t

i

Level of innovation in engine technology other 
than  to increase engine performance (power 

0

d t

)
Complexity of legislation

Enforcement (recall)

Access to technology by SME's

Paramount for the repair cycle (diagnose, 
access to repair and maintenance information, 
Level of re-use of technology by manufacturer

0

0

0

0

Better coherence than options 2 and 3 
?
Increased clarity for industry and other 
stakeholders
Appropriate environmental measures 
for complete different vehicles
Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

0

0

0

0

0

0

0

0

0

0

0

0

0

Option 2 (scenario 1 in LAT report): Application of OBD systems of similar technology to passenger cars (EOBD), including catalyst efficiency monitoring to all L-category vehicles. Introduction of free 
access to repair and maintenance provisions, similar as for passenger cars.
Policy options

Objective

Criteria

Compliance cost manufacturers

Efficiency

Employment at manufacturers

Initial investment cost for manufacturer

Effectiveness of repair (perspective 
independent repairer)

Repair cost for customer (if repaired by 
independent repairer)

Employment and revenue suppliers, 
type approval authorities, test 
laboratories
Cost of PTI in Member States that 
conduct this for L-category vehicles

Coherence

Conclusion 

__ __

++

Better coherence than options 1 and 3 
?
Increased clarity for industry and other 
stakeholders

__ __

Appropriate environmental measures 
for complete different vehicles

Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

++

+

++

+

0

+

++

__ 

++

+

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u
s
n
o
i
s
s
i
m
e
e
v
i
t
a
r
o
p
a
v
e

Environmental impact

Effectiveness

Ignoring Malfunction Indicator Light by customer

Functional safety impact

Standardised diagnostic information, available 
on request of generic scan tool

Anti-tampering measure

Level of innovation in engine technology other 
than  to increase engine performance (power 
and torque)
Complexity of legislation

Enforcement (recall)

Access to technology by SME's

Paramount for the repair cycle (diagnose, 
access to repair and maintenance information, 
repair). Importance to free access to repair and 
maintenance information policy option to repair 
competition failure in internal market.
Level of re-use of technology by manufacturer

++

__

+

++

++

++

__ __

0

__

+

+

Option 3 (scenario 1 in LAT report): Application of OBD systems of similar technology to passenger cars (EOBD), including catalyst efficiency monitoring to all L-category vehicles. Introduction of free 
access to repair and maintenance provisions, similar as for passenger cars.

Objective

Policy options

s
n
o
i
s
s
i
m
e

y
r
o
g
e
t
a
c
-
L

l
i
t
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u
s
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c
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b
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j

l

a
t
n
e
m
n
o
r
i
v
n
E

Environmental impact

Effectiveness

Ignoring Malfunction Indicator Light by customer

Functional safety impact

Standardised diagnostic information, available 
on request of generic scan tool
Anti-tampering measure

Level of innovation in engine technology other 
than  to increase engine performance (power 
and torque)
Complexity of legislation

Enforcement (recall)
Access to technology by SME's

Paramount for the repair cycle (diagnose, 
access to repair and maintenance information, 
repair). Importance to free access to repair and 
maintenance information policy option to repair 
competition failure in internal market.

Level of re-use of technology by manufacturer

+

__

+

++

+

0

__

0

+

++

++

Criteria

Efficiency

Compliance cost manufacturers

Employment at manufacturers

Initial investment cost for manufacturer

Effectiveness of repair (perspective 
independent repairer)
Repair cost for customer (if repaired by 
independent repairer)

Employment and revenue suppliers, 
type approval authorities, test 
laboratories
Cost of PTI in Member States that 
conduct this for L-category vehicles

__

++

__

+

+

+

+

Coherence

Conclusion 

Better coherence than options 1 and 2 
?
Increased clarity for industry and other 
stakeholders
Appropriate environmental measures 
for complete different vehicles
Level of simplification

Transparency with emission 
performance of other, alternative 
means of road transport

0

+

+

__ 

++

++

Table  89:  comparison  and  conclusion  table  possible  introduction  On  Board  Diagnostic  (OBD)  systems  and  access  to  repair 
information

EN 

124 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3. 
3.1. 

PROPOSAL FOR REVISED EMISSION LIMITS 
Proposal to revise tailpipe emission limits for the short term (2014) 

Vehicle 
category 

Vehicle 
category name 

Propulsion 
class 

Euro 
level 

Mass of 
carbon 
monoxide 
(CO) 
L1 (mg / 

Mass of total 
hydrocarbons 
(THC) 

L2 (mg / km) 

Mass of 
oxides 
of nitrogen 
(NOx) 
L3 (mg / km) 

Mass of 
particulate 
Matter (PM) 

Sum mass of total 
hydrocarbons and oxides 
of nitrogen (THC + NOx) 

L4 (mg / km) 

L5 (mg / km) 

Test 
cycle 

L1Ae 

L1Be 

L2e 

L3e 
L4e 
L5Ae 
L7Ae 

L5Be 

Powered cycle 

PI / Hybrid 

Euro 3 

Two-wheel moped 

PI / Hybrid 

Euro 3 

Three-wheel moped 

PI /Hybrid 

Euro 3 

560 

1000 

3500 

PI, vmax < 
130 km/h 

Euro 4 

1970 

-Two-wheel motorcycle 
with and without side-
car 
- Tricycle 
- Heavy on-road quad 

Commercial 
tricycle 

PI, vmax ≥ 
130 km/h 
CI / Hybrid 

Euro 4 

Euro 4 

PI 

Euro 3 

CI / Hybrid 

Euro 3 

100 

- 

- 

560 

250 

100 

1000 

150 

150 

1000 

150 

130 

- 

- 

130 

170 

570 

250 

650 

650 

250 

650 

- 

- 

- 

- 

- 

10052 

- 

100 

100 

- 

100 

- 

1200 

1200 

- 

- 

- 

- 

- 

1200 

1200 

- 

UNECE regulation No 47 

UNECE regulation No 47 

UNECE regulation No 47 

Revised WMTC, phase 2 

Revised WMTC, phase 2 

Revised WMTC, phase 2 

UNECE regulation No 40 

UNECE regulation No 40 

UNECE regulation No 47 

UNECE regulation No 47 

UNECE regulation No 47 

UNECE regulation No 40 

UNECE regulation No 40 

1970 

1000 

4000 

1000 

3500 

3500 

1000 

4000 

1000 

L6Ae 

Light on-road quad 

PI / Hybrid 

Euro 3 

L6Be 

Light mini-car 

L7Be 

Heavy mini-car 

PI 

Euro 3 

CI / Hybrid 

Euro 3 

PI 

Euro 3 

CI / Hybrid 

Euro 3 

Table 90: Proposed revised tailpipe emission limits

53

, Euro 3  

52

53

CI only, also if e.g. a hybrid concept includes a CI engine. 
Category L3e vehicles: Euro 4 

EN 

125 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
 
 
3.2. 

Proposal to revise tailpipe emission limits for the mid term (2017) 

Vehicle 
category 

Vehicle 
category name 

Propulsion  
class 

Euro 
level 

Mass of 
carbon 
monoxide 
(CO) 

Mass of total 
hydrocarbons 
(THC) 

Mass of 
oxides 
of nitrogen 
(NOx) 

Mass of 
particulate 
matter 
(PM) 

L1 (mg / km) 

L2 (mg / km) 

L3 (mg / km) 

L4 (mg / km) 

L1Ae 

Powered cycle 

PI / Hybrid 

PI / Hybrid 

PI /Hybrid 

PI, vmax < 
130 km/h 

PI, vmax ≥ 130 
km/h 

L1Be 

Two-wheel moped 

L2e 

Three-wheel moped 

-Two-wheel 
motorcycles with and 
without side-car 
- Tricycle 
- Heavy on-road quad 

L3e 
L4eError! 
Bookmark 
not defined. 
L5Ae 
L7Ae 

L5Be 

Commercial 
tricycle 

PI 

CI / Hybrid 

L6Ae 

Light on-road quad 

PI / Hybrid 

L6Be 

Light mini-car 

L7Be 

Heavy mini-car 

PI 

CI / Hybrid 

PI 

CI / Hybrid 

Euro 4 

Euro 4 

Euro 4 

Euro 5 

Euro 5 

Euro 4 

Euro 4 

Euro 4 

Euro 4 

Euro 4 

Euro 4 
Euro 4 

CI / Hybrid 

Euro 5 

Table 91: Proposed revised tailpipe emission limits

54

, Euro 4 

54

Category L3e vehicles: Euro 5. 

EN 

70 

170 

170 

70 

90 

300 

250 

550 

170 

170 

550 

250 
550 

- 

- 

- 

- 

8052 

- 

8052 

- 

8052 

- 
8052 

560 

1000 

1900 

1140 

1140 

1000 

2000 

1000 

1900 

1900 

1000 

2000 
1000 

100 

640 

740 

380 

170 

100 

550 

100 

740 

740 

100 

550 
100 

126 

Test 
cycle 

UNECE regulation No 47 

UNECE regulation No 47 

UNECE regulation No 47 

Revised WMTC, phase 2 

Revised WMTC, phase 2 

Revised WMTC, phase 2 

UNECE regulation No 40 

UNECE regulation No 40 

UNECE regulation No 47 

UNECE regulation No 47 

UNECE regulation No 47 

UNECE regulation No 40 

UNECE regulation No 40 

EN 

 
  
 
 
 
 
                                                 
 
3.3. 

Proposal55 to revise tailpipe emission limits for the long term (2020) 

Vehicle 
category 

Vehicle 
category name 

Propulsion  
class 

Euro 
level 

Mass of 
carbon 
monoxide 
(CO) 

Mass of total 
hydrocarbons 
(THC) 

Mass of Non 
methane 
hydrocarbons 
(NMHC) 

Mass of 
oxides 
of nitrogen 
(NOx) 

Mass of 
particulate 
matter 
(PM) 

L1 (mg / km) 

L2A (mg / km) 

L2B (mg / km) 

L3 (mg / km) 

L4 (mg / km) 

Test cycle 

L1Ae 

Powered cycle 

PI / Hybrid 

Euro 5 

{500} 

{100} 

{68} 

{60} 

{4.5} 

{Revised WMTC} 

L1Be — 
L7e 

All other L-category 
vehicles 

Euro 5 

CI / Hybrid 

{500} 

{100} 

{68}56 

{90} 

{4.5} 

{Revised WMTC} 

PI 

{1000} 

{100} 

{68} 

{60} 

{4.5} 

{Revised WMTC} 

Table 92: Proposed revised tailpipe emission limits

57

, Euro 5 

55

56

57

EN 

The braces around the limit values indicate that these have to be finally confirmed by an environmental effect study conducted for the Commission. 
NMHC limit only applicable to a hybrid vehicle equipped with a PI engine. 
Category L3e vehicles: Euro 6. 

127 

EN 

 
  
 
 
                                                 
 
 
 
3.4. 

Proposal for the introduction of On-board diagnostics emission thresholds for the mid term (2017) 

Vehicle 
category 

Vehicle 
category 
name 

Propulsion 
class 

Euro 
level 

Mass of 
carbon 
monoxide 
(CO) 

OT1 (mg / 
km) 

Mass of total 
hydrocarbons 
(THC) 

OT2 (mg / km) 

Mass of 
oxides 
of nitrogen 
(NOx) 

OT3 (mg / 
km) 

Test 
cycle 

L1Be 

L2e 

L6Ae 

L3e 
L4eError! 
Bookmark not 
defined. 

L5Ae 

L7Ae 

- Two-wheel 
moped 
- Three-wheel 
moped 
-On-road 
light quad 

-Two-wheel 
motorcycle 
with and 
without side-
car 
- Tricycle 
- Heavy on-
road quad 

PI or 
Hybrid 

PI 
vmax < 130 
km/h 
PI 
vmax ≥ 130 
km/h 
CI or 
Hybrid 

Euro 4 

3610 

2720 

850 

UNECE regulation No 47 

3740 

2060 

650 

Revised WMTC, phase 2 

Euro 4 

3740 

1900 

920 

640 

850 

Revised WMTC, phase 2 

1710 

Revised WMTC, phase 2 

Table 93: Proposed Euro 4 OBD emission thresholds54, OBD stage I 

3.5. 

Proposal55 to revise the On-board diagnostics emission thresholds for the long term (2020) 

Vehicle 
category 

Vehicle 
category 
name 

Propulsion  
class 

Euro 
level 

Mass of 
carbon 
monoxide 
(CO) 

OT1 (mg / 
km) 

Mass of Non 
methane 
hydrocarbons 
(NMHC) 

OT2 (mg / km) 

Mass of 
oxides 
of nitrogen 
(NOx) 

OT3 (mg / 
km) 

Mass of 
particulate 
matter 
(PM) 

OT4 (mg / 
km) 

{L1Be — 
L7e} 

All L 
category 
vehicles 
except 
category 

PI 

Euro 5 

{1900} 

{250} 

{300} 

{50} 

CI or 
Hybrid 

Euro 5 

{1900} 

{320} 

{375} 

{50} 

Test 
cycle 

{Revised 
WMTC} 

{Revised 
WMTC} 

Table 94: Proposed Euro 5 OBD emission thresholds57 {OBD stage I, and OBD stage II}55 

EN 

128 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.6 

Proposal for the introduction of evaporative emission threshold (2017)  

Vehicle 
category 

Vehicle 
category name 

Propulsion  
class 

Euro 
level 

Mass of total hydrocarbons 
(THC) (mg / test) 

Test cycle 

L3e 
L4e 

L6A 

Two-wheel motorcycle 
with and without side-car 

PI58 
vmax ≥ 130 km/h 

Light on-road quad 

Euro 5 

Euro 4 

Euro 4 

2000 

SHED 

PI 

PI 

Table 95: Proposed revised evaporative emission limit, Euro 454

L7Ae 

Heavy on-road quad 

3.7 

Proposal55 to revise the evaporative emission threshold (2020) 

Vehicle 
Class 

Vehicle 
class name 

Propulsion 
Class 

Euro 
level 

Mass of total hydrocarbons 
(THC) (mg / test) 

Test 
cycle 

{L1Ae} 

{Powered cycle} 

{Euro 5} 

{L1B} 

{Two-wheel moped} 

{L2} 

L3e 
L4 

{L5A} 

{L5B} 

L6A 

{L6B} 

L7A 

{L7B} 

{Three-wheel moped} 

Two-wheel motorcycle 
with and without side-car 

{Tricycle} 

PI 

{Commercial tricycle} 

Light on-road quad 

{Light mini-car} 

Heavy on-road quad 

{Heavy mini-car} 

{Euro 5} 

{Euro 5} 

Euro 6 

{Euro 5} 

{Euro 5} 

Euro 5 

{Euro 5} 

Euro 5 

{Euro 5} 

Table 96: Proposed revised evaporative emission limit, Euro 557

{2000} / {TBD} 

SHED /  
{SHED} or {Fuel Tank and Fuel 
tubing permeation test}59 

58

59

EN 

PI engines running on gasoline, gasoline blends or ethanol. 
The  cost-effectiveness  of  evaporative  emission  control  will  among  others  be  assessed  in  the  environmental  effect  study  to  be  carried  out  for  the  Commission.  Other  cost-effective  evaporative 
testing methods like fuel tank and fuel supply permeation testing will be assessed in this study as an alternative to the SHED test for vehicle categories other than L3e, L6Ae and L7Ae. 

129 

EN 

 
  
 
 
                                                 
 
 
ANNEX XVI: DETAILS CHAPTER 6 — OPTIONS COMPARISON AND CONCLUSIONS — ANALYSIS NEW VEHICLE TYPE 

APPROVAL SAFETY MEASURES 

1. 

FITTING OF ADVANCED BRAKE SYSTEMS 

Explanation:
__ __ much worse
__ worse
0 neutral (no change)
+ better
++ much better

1.1. 

No change 

Option 1: No change
Objective

Policy options

1: No policy change

Effectiveness

Criteria

Efficiency

Coherence

Conclusion 

0

0

0

0

Table 97: option comparison and conclusion table — fitting of Advanced Brake systems — option 1 

1.2. 

Anti-lock Brake Systems on all Powered Two Wheelers (PTW) 

Option 2: Anti-lock Brake Systems on all Powered Two Wheelers (PTW)
Objective

Policy options

y
t
e
f
a
S
d
e
s
a
e
r
c
n

I

Anti-lock Brake 
Systems on all 
Powered Two 
Wheelers (PTW)

Effectiveness

Level of fatalities and injured riders in PTW 
involved road accidents
Anti-lock  Brake System is the only technical 
solution which directly monitors and prevents 
wheel locking.
With Anti-lock  Brake System higher braking 
decelerations achieved (resulting in less braking 
distance) than with conventional brakes only. 
Potential reduction in impact speed in case of 
collision

Preventing wheel lock under emergency braking 
provides the rider with increased confidence to 
apply higher brake forces. More efficient braking 
with Anti-lock  brake system, rider brakes 
earlier during brake manœuvre

Inexperienced riders on PTW with Anti-lock 
Brake System able to achieve decelerations 
closer to that of experienced riders, after 
relatively short training / adaptation time
Vehicles fitted with Anti-lock  Brake System are 
able to make use of the adhesion available 
when on low and high friction surfaces. (e.g. 
changing conditions from dry to wet road)
Anti-lock  brake systems prevents dangerous 
downfalls whilst braking. In case of critical wheel-
lock of front wheel PTW rider falls and slides 
uncontrolled over the road
Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system 
fitted. Long term societal and economic benefits

Estimated fatality and heavily injured rider 
reduction

Risk of rider becoming "over" confident if PTW 
equipped with advanced brake system, trusts 
too much on technology. Higher speed
Possible bad braking performance (adverse 
effects off-road) if Anti-lock Brake System fitted 
on Off-road PTW

Additional rules for design of brake system to 
industry making legislation more complex.
Legislation not technology neutral, mandating a 
specific technology. Normally legislation just 
defines the performance criteria.  
Level of technical complexity of vehicle
Level of brake technology innovation
Riding training required for system to be 
effectively

++

++

++

++

++

++

++

++

++

_

_

_

__ __

0
0

0

Criteria

Efficiency
Low consumer price of PTW

__ __

Level of cost to society owing to cost of 
health care, lost working days etc

++

Insurance cost for consumer

Coherence

better coherence than options 3,4 and 
5
increased clarity for industry and other 
stakeholders

0

+

Conclusion 

Potential customers not purchasing 
PTWs owing to being victim of road 
accident

Cost effectiveness obligatory Anti-lock 
brake system. Majority of in total 11 
predictive and retrospective literature 
study results are positive.
Economy of scales for Anti-lock 
Braking System production, mid to long 
term drop of development and 
production cost 
Revenue and employment supplier 
industry

Market penetration of Anti-lock brake 
system

+

+

++

++

++

++

Manufacturing and development cost of 
PTWs equipped with Anti-lock  Brake 
Systems, possibly passed on to 
consumer (possible price increase)
Risk of unavailability of Anti-lock Brake 
System technology to SME's (not 
meeting entrance criteria to be supplied 
by bigger automotive suppliers or 
confronted with high development cost 
as supplier cannot amortise investments 
owing to low series production)

__ __

__ __

Risk of short term price increase owing 
to manufacturers forced to buy systems 
and components from suppliers.

Level of legislation complexity

_

_

+

Table 98: option comparison and conclusion table — fitting of Advanced Brake systems — option 2 

EN 

130 

   EN 

 
 
 
 
 
1.3. 

Anti-lock Brake Systems on PTWs with cylinder capacity60 > 125 cm3 and Advanced Brake 
Systems (Combined Brake System (CBS) or Anti-lock Brake Systems (ABS) on motorcycles 
with 50 cm3 < cylinder capacity61 ≤ 125 cm3 

Conclusion 

++

Option 3: Anti-lock Brake Systems on PTWs with cylinder capacity >125cm3 and Advanced Brake Systems (Combined Brake System 
               (CBS) and/or Anti-lock Brake Systems (ABS)) on motorcycles with 50cm3 < cylinder capacity  <= 125cm3 
Objective

Policy options

Criteria

y
t
e
f
a
S
d
e
s
a
e
r
c
n

I

Anti-lock Brake 
Systems on PTWs 
with cylinder capacity 
>125cm3 and 
Advanced Brake 
Systems (Combined 
Brake System 
               (CBS) 
and/or Anti-lock 
Brake Systems 
(ABS)) on 
motorcycles with 
50cm3 < cylinder 
capacity  <= 125cm3

Effectiveness

Level of fatalities and injured riders in PTW 
involved road accidents
Anti-lock  Brake System is the only technical 
solution which directly monitors and prevents 
wheel locking.
With Anti-lock  Brake System higher braking 
decelerations achieved (resulting in less braking 
distance) than with conventional brakes only. 
Potential reduction in impact speed in case of 
collision
Preventing wheel lock under emergency braking 
provides the rider with increased confidence to 
apply higher brake forces. More efficient braking 
with Anti-lock  brake system, rider brakes 
earlier during brake manœuvre
Inexperienced riders on PTW with Anti-lock 
Brake System able to achieve decelerations 
closer to that of experienced riders, after 
relatively short training / adaptation time
Vehicles fitted with Anti-lock  Brake System are 
able to make use of the adhesion available 
when on low and high friction surfaces. (e.g. 
changing conditions from dry to wet road)
Anti-lock  brake systems prevents dangerous 
downfalls whilst braking. In case of critical wheel-
lock of front wheel PTW rider falls and slides 
uncontrolled over the road
Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system 
fitted. Long term societal and economic benefits

Estimated fatality and heavily injured rider 
reduction

Risk of rider becoming "over" confident if PTW 
equipped with advanced brake system, trusts 
too much on technology. Higher speed

Possible bad braking performance (adverse 
effects off-road) if Anti-lock Brake System fitted 
on Off-road PTW

Additional rules for design of brake system to 
industry making legislation more complex.
Legislation not technology neutral, mandating a 
specific technology. Normally legislation just 
defines the performance criteria.  
Level of technical complexity of vehicle
Freedom of choice regarding product and 
product characteristics
Level of brake technology innovation

++

++

++

++

++

++

++

+

+

_

_

_

__ __

0

0

0

Efficiency
Low consumer price of PTW

__ __

Level of cost to society owing to cost of 
health care, lost working days etc

++

Coherence

better coherence than options 3,4 and 
5
increased clarity for industry and other 
stakeholders

0

+

Insurance cost for consumer

Potential customers not purchasing 
PTWs owing to being victim of road 
accident

Cost effectiveness obligatory Anti-lock 
brake system. Majority of in total 11 
predictive and retrospective literature 
study results are positive.
Economy of scales for Anti-lock 
Braking System production, mid to long 
term drop of development and 
production cost 
Revenue and employment supplier 
industry

Market penetration of Anti-lock  brake 
system

+

+

++

++

++

++

Manufacturing and development cost of 
PTWs equipped with Anti-lock  Brake 
Systems, possibly passed on to 
consumer (possible price increase)
Risk of unavailability of Anti-lock Brake 
System technology to SME's (not 
meeting entrance criteria to be supplied 
by bigger automotive suppliers or 
confronted with high development cost 
as supplier cannot amortise investments 
owing to low series production)

Risk of short term price increase owing 
to manufacturers forced to buy systems 
and components from suppliers.

Level of legislation complexity

__ __

__ __

_

_

Table 99: option comparison and conclusion table — fitting of Advanced Brake systems -option 3 

60

61

The 125 cm3 takes reference to the thresholds in Directive 2006/126/EC (recasted driving licence directive) related to class 
A1:  motorcycles  with  a  cylinder  capacity  not  exceeding  125  cm3,  of  a  power  not  exceeding  11kW  and  with  a  power/weight 
ratio not exceeding 0.1 kW/kg. 
The 125 cm3 takes reference to the thresholds in Directive 2006/126/EC (recasted driving licence directive) related to class 
A1:  motorcycles  with  a  cylinder  capacity  not  exceeding  125  cm3,  of  a  power  not  exceeding  11kW  and  with  a  power/weight 
ratio not exceeding 0.1 kW/kg. 

EN 

131 

   EN 

 
 
 
                                                 
 
 
1.4. 

Obligatory fitting of Advanced Brake Systems (Combined Brake System (CBS) and/or Anti-
lock  Brake  Systems  (ABS))  on  motorcycles  fulfilling  the  maximum  performance  criteria 
related to the A2 driving licence62. Obligatory fitting of Anti-lock Brake Systems on all other 
L3e class motorcycles. 

Option 4: To make mandatory the fitting of Advanced Brake Systems (Combined Brake System (CBS) and/or Anti-lock Braking Systems) on those motorcycles which conform to the 
performance criteria defined by the A2 driving licence . Obligatory fitting of Anti-lock Brake Systems on all other L3 class motorcycles

Coherence

better coherence than options 3,4 and 
5
increased clarity for industry and other 
stakeholders

Conclusion 

++

Objective

Policy options

y
t
e
f
a
S
d
e
s
a
e
r
c
n

I

To make mandatory 
the fitting of 
Advanced Brake 
Systems (Combined 
Brake System (CBS) 
and/or Anti-lock 
Braking Systems) on 
those motorcycles 
which conform to the 
performance criteria 
defined by the A2 
driving licence . 
Obligatory fitting of 
Anti-lock Brake 
Systems on all other 
L3 class motorcycles

Effectiveness

Level of fatalities and injured riders in PTW 
involved road accidents
Anti-lock  Brake System is the only technical 
solution which directly monitors and prevents 
wheel locking.
With Anti-lock  Brake System higher braking 
decelerations achieved (resulting in less braking 
distance) than with conventional brakes only. 
Potential reduction in impact speed in case of 
collision
Preventing wheel lock under emergency braking 
provides the rider with increased confidence to 
apply higher brake forces. More efficient braking 
with Anti-lock  brake system, rider brakes 
earlier during brake manœuvre

Inexperienced riders on PTW with Anti-lock 
Brake System able to achieve decelerations 
closer to that of experienced riders, after 
relatively short training / adaptation time
Vehicles fitted with Anti-lock  Brake System are 
able to make use of the adhesion available 
when on low and high friction surfaces. (e.g. 
changing conditions from dry to wet road)

Anti-lock  brake systems prevents dangerous 
downfalls whilst braking. In case of critical wheel-
lock of front wheel PTW rider falls and slides 
uncontrolled over the road
Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system 
fitted. Long term societal and economic benefits

Estimated fatality and heavily injured rider 
reduction

Risk of rider becoming "over" confident if PTW 
equipped with advanced brake system, trusts 
too much on technology. Higher speed

Possible bad braking performance (adverse 
effects off-road) if Anti-lock  Brake System 
fitted on Off-road PTW

Additional rules for design of brake system to 
industry making legislation more complex.
Legislation not technology neutral, mandating a 
specific technology. Normally legislation just 
defines the performance criteria.  

Criteria

Efficiency
Low consumer price of PTW

Level of cost to society owing to cost of 
health care, lost working days etc

Insurance cost for consumer

Potential customers not purchasing 
PTWs owing to being victim of road 
accident

Cost effectiveness obligatory Anti-lock 
brake system. Majority of in total 11 
predictive and retrospective literature 
study results are positive.
Economy of scales for Anti-lock 
Braking System production, mid to long 
term drop of development and 
production cost 

Revenue and employment supplier 
industry

Market penetration of Anti-lock  brake 
system

Manufacturing and development cost of 
PTWs equipped with Anti-lock Brake 
Systems, possibly passed on to 
consumer (possible price increase)
Risk of unavailability of Anti-lock Brake 
System technology to SME's (not 
meeting entrance criteria to be supplied 
by bigger automotive suppliers or 
confronted with high development cost 
as supplier cannot amortise investments 
owing to low series production)

Risk of short term price increase owing 
to manufacturers forced to buy systems 
and components from suppliers.

Level of legislation complexity

+

++

++

++

++

++

++

++

+

_

_

_

__ __

Level of technical complexity of vehicle
Freedom of choice regarding product and 
product characteristics
Level of brake technology innovation
Horizontal harmonisation of vehicle 
performance criteria between type approval and 
driving licence legislation (simplification)

0

0

0

+

Table 100: option comparison and conclusion table — fitting of Advanced Brake systems — option 4 

62

Thresholds obtained from Directive 2006/126/EC (recasted driving licence directive) class A2: 1) power not exceeding 35 kW, 
with 2) a power/weight ratio not exceeding 0.2 kW/kg, and 3) not derived from a vehicle of more than double its power. These 
are EU wide accepted criteria to separate less powerful PTWs that beginning riders only may ride during the two subsequent 
years  of  getting  their  driving  licence  on  one  hand  from  powerful  motorcycles  that  may  only  driven  by  more  experienced 
motorcycle riders on the other hand. 

EN 

132 

   EN 

 
 
 
                                                 
 
Conclusion 

Coherence

better coherence than options 3,4 and 
5

increased clarity for industry and other 
stakeholders

0

+

__

1.5. 

Industry self obligation 

Option 5: Industry self regulation proposal

Objective

Policy options

Effectiveness

Level of fatalities and injured riders in PTW 
involved road accidents

CBS is full alternative to Anti-lock  brake 
system, technical equivalence assumed 
between both systems 
With Anti-lock  Brake System higher braking 
decelerations achieved (resulting in less braking 
distance) than with conventional brakes only. 
Potential reduction in impact speed in case of 
collision
Preventing wheel lock under emergency braking 
provides the rider with increased confidence to 
apply higher brake forces. More efficient braking 
with Advanced Brake System, rider brakes 
earlier during brake manœuvre
Inexperienced riders on PTW with Anti-lock 
Brake System able to achieve decelerations 
closer to that of experienced riders, after 
relatively short training / adaptation time

Vehicles fitted with Anti-lock  Brake System are 
able to make use of the adhesion available 
when on low and high friction surfaces. (e.g. 
changing conditions from dry to wet road)

Anti-lock  brake systems prevents dangerous 
downfalls whilst braking. In case of critical wheel-
lock of front wheel PTW rider falls and slides 
uncontrolled over the road
Chance of increased level of accident result 
mitigation in case of Anti-lock  brake system 
fitted. Long term societal and economic benefits

Estimated fatality and heavily injured rider 
reduction

Risk of rider becoming "over" confident if PTW 
equipped with advanced brake system, trusts 
too much on technology. Higher speed

y
t
e
f
a
S
d
e
s
a
e
r
c
n

I

Option 5: Industry 
self regulation 
proposal

Criteria

Efficiency
Low consumer price of PTW

Level of cost to society owing to cost of 
health care, lost working days etc

Insurance cost for consumer

Potential customers not purchasing 
PTWs owing to being victim of road 
accident

Cost effectiveness Advanced Brake 
Systems according to industry self-
obligation scheme (either Anti-lock 
Brake System and/or CBS)

Economy of scales for Advanced 
Braking System production, mid to long 
term drop of development and 
production cost 

Revenue and employment supplier 
industry

Market penetration of Anti-lock  brake 
system

_

0

+

+

+

+

0

+

__

__ __

Manufacturing and development cost of 
PTWs equipped with Anti-lock Brake 
Systems, possibly passed on to 
consumer (possible price increase)
Risk of unavailability of Anti-lock Brake 
System technology to SME's (not 
meeting entrance criteria to be supplied 
by bigger automotive suppliers or 
confronted with high development cost 
as supplier cannot amortise investments 
owing to low series production)

Possible bad braking performance (adverse 
effects off-road) if Anti-lock  Brake System 
fitted on Off-road PTW

Risk of short term price increase owing 
to manufacturers forced to buy systems 
and components from suppliers.

__ __

Additional rules for design of brake system to 
industry making legislation more complex.

Legislation not technology neutral, mandating a 
specific technology. Normally legislation just 
defines the performance criteria.  
Level of technical complexity of vehicle
Freedom of choice regarding product and 
product characteristics

Level of brake technology innovation

__ __

0

0

++

0

Less burden (impact of legislation on 
vehicle design) in industry (mainly for 
big players, small manufacturers may 
still struggle to fulfil self regulation quota 
if above small series threshold)
Level of intervention: Conventional 
consumer price development owing to 
supply and demand
Level of legislation complexity
SME's under normal market pressure to 
equip produced vehicles with advanced 
brake systems. Concern related to 
access to technology  postponed / only 
mitigated, not eliminated

Consumer price of Advanced Brake 
System determined by normal market 
mechanism of supply and demand. 
Consumer opting for Anti-lock  Brake 
System and/or CBS can only partly 
benefit from pressure on advanced 
brake system price (lower level of 
economy of scales for manufacturer)

+

0

++

+

+

+

__

__

+

+

+

+

0

0

__

__

Table 101: option comparison and conclusion table — fitting of Advanced Brake systems -option 5 

EN 

133 

   EN 

 
 
 
1.6. 

Impact Assessment of Anti-lock Brake System technology fitted on vehicles, manufactured 
and type approved by SMEs 

1.6.1. 

Introduction 

As part of the impact assessment of the proposed Regulation for the type approval of L-category vehicles, an 
analysis of possible effects on SMEs in the relevant business sectors must be conducted. In accordance with 
the definitions laid down in Recommendation 2003/361/EC, a medium sized enterprise employs between 50-
249 workers. A small enterprise has 10-49 employees whereas micro enterprises employ up to nine persons. 
It  is  important  to  keep  these  distinctions  in  mind  given  that  precise  employment  numbers  in  SMEs  in  the 
PTW industry are difficult to obtain, but recent data collected by EuroStat suggests that within the EU micro 
companies  account  for  the  biggest  share  of  SMEs  manufacturing  cycles  as  well  as  motorcycles. 
Unfortunately the data for each type of manufacturer cannot be disaggregated. In addition this data should 
be referenced with caution owing to 2 constraints. 

For the sake of clarity and completeness, it is important to point out that the data provided by EuroStat can 
only be used to gain a generic picture of the Cycle and L-category vehicle market since it lacks precision in 
two important ways. First, the data includes the manufacture of cycles which is problematic in the sense that 
the  cycle  market  strongly  varies  from  the  PTWs  market.  The  cycle  market  is  very  diversified  and 
heterogeneous in terms of producers which often constitute of micro companies. This strongly contrasts with 
the  motorcycle  market  which  is  far  more  concentrated.  Second,  the  data  does  not  specify  the  term 
‘manufacturer’  which  is  paramount  for  the  underlying  assessment  since  the  proposed  Regulation  will  only 
cover  OEMs  that  market  their  products  complying  with  requirements  for  Whole  Vehicle  Type  Approval 
(WVTA). Accordingly, all SMEs that might fall under the definition of manufacturer in the EuroStat database 
but which are only active in the business of vehicle modifications are not of primary concern in this impact 
assessment since their end products may be subject to national type approvals. 

1.6.2. 

Regulatory Impacts on SMEs 

In respect of the assessment of regulatory impacts on SMEs, there are some general points worth to be kept 
in  mind.  Hence,  the  introduction  of  new  regulations  can  be  a  disproportionately  bigger  burden  for  SME 
manufacturers  because  of  scarcer  resources.  Any  additional  costs  caused  by  a  new  regulatory  framework 
can  have  a  substantial  negative  impact  on  the  commercial  viability  of  SME  OEMs  because  of  compliance 
costs and a lack of information or expertise which in many cases has to be bought from specialists outside 
the company. Furthermore, SME manufacturers have only a limited scope for benefiting from economies of 
scale and face severe constraints in passing on increases in costs to their customers because they generally 
act as price takers on the market. Moreover, especially in the context of the current crisis it is important to 
remember that the access to capital is restricted for SMEs which makes major investments difficult if often 
not impossible. On the other hand, SMEs are characterised by their high flexibility and their ability to adapt to 
new market conditions quickly. As such they are therefore quicker to meet new market demands than their 
larger  counterparts.  There  may  also  be  components  and  systems  (hardware)  and  software  required  by 
manufacturers to be able to comply with new or revised legal requirements. This demand for certain niche 
products,  not  interesting  to  be  mass  produced  by  the  major  automotive  suppliers,  or  highly  specialised 
products or software solutions may be the high added value that specialised SME suppliers can provide. 

1.6.3. 

Economic Advantages 

There are a number of economic advantages in case of introduction of mandatory Anti-lock Brake Systems 
on PTWs. Hence, positive impact on society as a whole by fatality prevention and possible injury mitigation in 
road  accidents  of  PTW  riders  positively  correlate  with  the  industry’s  economic  interests  since  it  will  retain 
first-line  potential  clients.  Related  to  this  is  the  increase  in  consumer  confidence.  This  argument  has 
essentially two aspects. First, on a more general level making the use of motorcycles safer will remove some 
of  the  safety  concerns  which  are  beneficial  for  acquiring  new  customers  as  well  as  for  winning  back  old 
customers. Given some customers’ tendency to be up to date with the newest technological developments, 
the  legislative  proposal  could  have  a  positive  impact  on  sale  numbers  since  it  encourages  customers  to 
upgrade their vehicle. Second, it will improve the individual brand image of motorcycle producers since they 
do not have an interest in being perceived as marketing second-class quality products. There is clearly no 
interest in being considered as lagging behind in terms of safety standards in an industry where safety issues 
play an increasingly greater role. Thus, due to the technological advancement brought by Anti-lock Brake 
System  the  product  becomes  more  attractive.  In  addition,  the  attractiveness could  also  be raised  by  lower 

EN 

134 

   EN 

 
insurance  premiums  offered  for  PTWs  with  Anti-lock  Brake  Systems.  With  regard  to  new  distribution 
channels,  the  downstream  market  that  practically  consists  of  SMEs  could  also  profit  from  the  measure 
envisaged. Hence, requiring the fitting of Anti-lock Brake System could encourage the emergence of a new 
niche distribution channel, e.g. outlets specialising in the safest motorbikes only.  

1.6.4. 

Possible Disadvantages 

As regards the disadvantages of the mandatory fitting of Anti-lock Brake System, it is obvious that there is a 
probability that the additional costs of fitting this braking system will be added up to the market price of the 
vehicle with an adverse effect on the vehicle’s competitiveness. However, it needs to be remembered that 
safer  motorcycles  could  attract  additional  customers  and,  furthermore,  economy  of  scales  and  market 
pressure  may  soon  lead  to  a  new  equilibrium.  In  this  context,  it  remains  to  be  seen  in  how  far  SMEs 
manufacturing  motorcycles  in  relatively  low  volumes  will  be  able  to  cope  with  the  competitive  pressure  to 
lower prices given that they do not profit from large economies of scale. In this context, however, it needs to 
be remembered that through an appropriate marketing strategy, SMEs could also have the possibility to get 
an extra margin on their products since new advancements in safety matters could justify higher prices. From 
the  perspective  of  the  Anti-lock  Brake  System  supplier,  it  is  worthwhile  to  state  that  in  the  short  term  the 
prices  for  Anti-lock  Brake  System  systems  could  rise  given  the  sudden  increase  in  demand  which  could 
translate into higher vehicle prices.  

1.6.5. 

Potential Opportunities 

Despite  the  potential  disadvantages,  the  mandatory  fitting  of  Anti-lock  Brake  System  also  brings 
opportunities for SMEs. Alongside the advantages mentioned above, SME suppliers would have the chance 
to specialise in the production of Anti-lock Brake System braking systems since the demand for this system 
will significantly increase. In this context, there is even the possibility of the development of certain synergy 
effects between two SMEs where one focuses on the production of motorbikes whereas the other specialises 
on the supply of corresponding braking systems that are tailor-made for a specific brand. In this sense, both 
could profit from the conclusion of exclusive supply agreements and an improved brand image.  

1.6.6. 

Potential Risks  

In respect of potential risks of the compulsory fitting of Anti-lock Brake System, there is a danger that certain 
SMEs  manufacturing  PTWs  will  not  have  access  to  Anti-lock  Brake  System  technology.  There  are  two 
reasons for this observation. First, the R&D expenses for this technology are prohibitive and, thus, only the 
SME  manufacturers  producing  high  end  PTWs  may  invest  to  develop  the  technology  on  its  own.  That  is 
particularly  true  for  SME  manufacturers  with  low  production  volumes  where  economies  of  scale  are  very 
small.  Second,  in  order  to  get  the  required  technology,  SME  OEMs  will  have  to  rely  on  automotive 
technology suppliers and buy the technology from them. The problem with this scenario is that their purchase 
order might be too small and, hence, suppliers may refuse to deal with them since the profit margins are not 
high enough or the supplier may not even reach its break even point with these customised Anti-lock Brake 
System. In the worst case scenario a SME OEM might not find a supplier willing to supply Anti-lock Brake 
System technology which would basically amount to an inability to sell its products if the fitting of Anti-lock 
Brake System was to be made mandatory. With the purpose to address this problem, various solutions may 
be  considered.  One  solution  could  be  to  set  a  sale  number  threshold  for  a  product  below  which  a  SME 
producer does not have to comply with the Anti-lock Brake System requirement (small series requirements). 
Another  possibility  is  to  ensure  that  every  SME  manufacturer  will  get  access  to  Anti-lock  Brake  System 
technology at an affordable price. In this regard, the idea of a voluntary commitment on the part of Anti-lock 
Brake System suppliers to supply SMEs could be another possibility to ease the fears expressed above. 

EN 

135 

   EN 

 
2. 

Anti-tampering measures  

Explanation:
__ __ much worse
__ worse
0 neutral (no change)
+ better
++ much better

2.1. 

No change; 

Option 1: No change
Objective

Policy options

Effectiveness

General interest in customising and 
modification, good for technical education
Driver licensing restrictions 

By-passing recurring technical inspections

Emission of noise, exhaust emission levels, fuel 
consumption and CO2.
Prevent to exceed maximum vehicle speed for e

Electronic manipulation: effectiveness of 
existing anti-tampering measures

Risk to be involved in accident

Enforcement results successful ?

Level of innovation

Effectiveness of chapter 7, ten years after 
introduction largely unknown
Level of obsolete measures

Theft of vehicles

0

0

0

0

0

0

0

0

0

0

0

0

1: No policy change

Criteria

Efficiency

Road tax contribution

Insurance premium

Economic impact on the suppliers of the 
parts which are no longer required 
(information stickers, frangible bolts 

t

)

Economic effect on tampering industry

Coherence

Conclusion 

better coherence than options 2, & 3 ?

increased clarity for industry and other 
stakeholders

0

0

0

0

0

0

0

Table 102: option comparison and conclusion table, anti-tampering measures, option 1 

2.2. 

Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures; 

Option 2: Repeal Chapter 7 of Directive 97/24/EEC, current superseded anti-tampering measures
Objective

Policy options

Criteria

Efficiency

Road tax contribution

Insurance premium

Economic impact on the suppliers of the 
parts which are no longer required 
(information stickers, frangible bolts 
etc.)
Economic effect on tampering industry

__ __

__ __

__ __

__ __

Conclusion 

better coherence than options 1, & 3 ?

Coherence

increased clarity for industry and other 
stakeholders

__ __

__ __

__ __

Effectiveness
General interest in customising and 
modification, good for technical education
Driver licensing restrictions 

By-passing recurring technical inspections

Emission of noise, exhaust emission levels, fuel 
consumption and CO2.
Prevent to exceed maximum vehicle speed for e

Electronic manipulation: effectiveness of 
existing anti-tampering measures

Risk to be involved in accident

Enforcement results successful ?

Level of innovation

Effectiveness of chapter 7, ten years after 
introduction largely unknown
Level of obsolete measures

Theft of vehicles

++

__ __

__ __

__ __

__ __

__ __

__ __

__ __

__

0

__ __

__ __

y
t
e
f
a
S
d
e
s
a
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c
n

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Table 103: option comparison and conclusion table, anti-tampering measures, option 2 

EN 

136 

   EN 

 
 
 
 
 
2.3. 

New measures on anti-tampering. 

Option 3 New measures on anti-tampering
Objective
Policy options

y
t
e
f
a
S
d
e
s
a
e
r
c
n

I

Effectiveness
General interest in customising and 
modification, good for technical education
Driver licensing restrictions 

By-passing recurring technical inspections

Emission of noise, exhaust emission levels, fuel 
consumption and CO2.
Prevent to exceed maximum vehicle speed for 
e.g. Mopeds

Electronic manipulation: effectiveness of 
existing anti-tampering measures
Risk to be involved in accident

Enforcement results successful ?

Level of innovation

Effectiveness of chapter 7, ten years after 
introduction largely unknown
Level of obsolete measures
Theft of vehicles

++

0

0

++

+

++

+

+

+

0

+
+

Criteria

Efficiency

Road tax contribution

Insurance premium

Economic impact on the suppliers of the 
parts which are no longer required 
(information stickers, frangible bolts 
etc.)
Economic effect on tampering industry

0

+

__

0

Conclusion 

better coherence than options 1, & 2 ?

Coherence

increased clarity for industry and other 
stakeholders

+

+

+

Table 104: option comparison and conclusion table, anti-tampering measures, option 3 

EN 

137 

   EN 

 
 
 
3. 

74 kW power limitation for motorcycle 

Explanation:
__ __ much worse
__ worse
0 neutral (no change)
+ better
++ much better

Option 1: No change
Objective

Policy options

y
t
e
f
a
S
d
e
s
a
e
r
c
n

I

Effectiveness

Number of Member States that apply the 74kW 
power limit through national legislation could 
increase
No clear evidence to suggest that limiting the 
power of a motorcycle to 74kW has a positive 
impact on the number of road accidents 
involving motorcycles. Other factors such as 
rider attitude and experience have a greater 
influence on accident risk

Effect on the noise generation, emissions and 
fuel consumption

Option 2: Repeal the option given to Member States to limit the power to 74kW.
Objective

Policy options

Effectiveness

Number of Member States that apply the 74kW 
power limit through national legislation could 
increase
No clear evidence to suggest that limiting the 
power of a motorcycle to 74kW has a positive 
impact on the number of road accidents 
involving motorcycles. Other factors such as 
rider attitude and experience have a greater 
influence on accident risk
Effect on the noise generation, emissions and 
fuel consumption

y
t
e
f
a
S
d
e
s
a
e
r
c
n

I

Option 3: Set a harmonized limit of 74kW. 
Policy options
Objective

Effectiveness

Number of Member States that apply the 74kW 
power limit through national legislation could 
increase

No clear evidence to suggest that limiting the 
power of a motorcycle to 74kW has a positive 
impact on the number of road accidents 
involving motorcycles. Other factors such as 
rider attitude and experience have a greater 
influence on accident risk
Effect on the noise generation, emissions and 
fuel consumption

y
t
e
f
a
S
d
e
s
a
e
r
c
n

I

Criteria

Efficiency

Coherence

Conclusion 

Minimum Economic impact

better coherence than options 2,3,4 ?

0

0

0

0

+

0

0

+

0

Cost to the manufacturers to produce 
the restricted motorcycles

Impact on some specialist (SME) 
manufacturer's revenue and cost that 
concentrate on the production of high 
powered motorcycles

Member State may save cost by 
rescinding National Legislation
Internal market with less barriers, 
reduced technical and administration 
burden on manufacturers. Lower price 

Criteria

Efficiency

Minimum Economic impact

0

0

0

0

0

+

increased clarity for industry and other 
stakeholders

better coherence than options 3 &4 ?

Coherence

Cost to the manufacturers to produce 
the restricted motorcycles

increased clarity for industry and other 
stakeholders

Impact on some specialist (SME) 
manufacturer's revenue and cost that 
concentrate on the production of high 
powered motorcycles
Member State may save cost by 
rescinding National Legislation
Internal market with less barriers, 
reduced technical and administration 
burden on manufacturers. Lower price 
to consumer

++

+

+

++

Criteria

Efficiency

Coherence

Minimum Economic impact

better coherence than options 2&4 ?

__ __

Cost to the manufacturers to produce 
the restricted motorcycles

increased clarity for industry and other 
stakeholders

__

__ __

+

+

Impact on some specialist (SME) 
manufacturer's revenue and cost that 
concentrate on the production of high 
powered motorcycles

Member State may save cost by 
rescinding National Legislation

Internal market with less barriers, 
reduced technical and administration 
burden on manufacturers. Lower price 
to consumer

0

0

+

+

+

+

0

Conclusion 

+

Conclusion 

__

Table 105: option comparison and conclusion table, 74 kW power limitations for motorcycles, options 1 to 4 

EN 

138 

   EN 

 
 
 
 
 
 
ANNEX XVII: DETAILS CHAPTER 6 — OPTIONS COMPARISON AND CONCLUSIONS — IMPROVED CATEGORISATION OF 

L-CATEGORY VEHICLES 

Explanation:
__ __ much worse
__ worse
0 neutral (no change)
+ better
++ much better

1. 

RECATEGORISATION  ELECTRICAL  CYCLES  (OUTSIDE  SCOPE  OF  FRAMEWORK  DIRECTIVE  CURRENTLY), 
TRICYCLES (L5E) AND QUADRICYCLES (CATEGORIES L6E AND L7E) 

Option 1: No change

Objective

Policy options

s
e
l
c
i
h
e
v

d
e
v
o
r
p
m

I

y
r
o
g
e
t
a
c
-
L
f
o

n
o
i
t
a
s
i
r
o
g
e
t
a
c

Effectiveness
Technical standards meeting effort

Noise, emissions and fuel consumption

Level and appropriateness of current safety 
measures

0

0

0

Criteria

Efficiency

Compliance costs

Option 2: Exclude quadricycles and electrical bi- and tri-cycles from the Framework Regulation; 

Objective

Policy options

s
e
l
c
i
h
e
v

y
r
o
g
e
t
a
c
-
L

d
e
v
o
r
p
m

I

f
o
n
o
i
t
a
s
i
r
o
g
e
t
a
c

Effectiveness
Technical standards meeting effort

Criteria

Efficiency

Compliance costs

Noise, emissions and fuel consumption

Level and appropriateness of current safety 
measures

0

__ __

__ __

Option 3: Return to the original spirit of the legislation for mini cars;

Objective

Policy options

l

s
e
c
h
e
v

i

-
L
f
o
n

y
r
o
g
e
t
a
c

d
e
v
o
r
p
m

I

o
i
t
a
s
i
r
o
g
e
t
a
c

Effectiveness
Technical standards meeting effort

Noise, emissions and fuel consumption

Level and appropriateness of current safety 
measures

Criteria

Efficiency

0 Compliance costs

__ __

__ __

0

+

0

Coherence

Conclusion 

Better coherence than options 2,3,4,5 ?

Increased clarity for industry and other 
stakeholders

0

0

0

Conclusion 

Coherence

Better coherence than options 3,4,5 ?

__ __

Increased clarity for industry and other 
stakeholders

__ __

__ __

Conclusion 

Coherence

Better coherence than options 2,4,5 ?

Increased clarity for industry and other 
stakeholders

__ __

__ __

__

Option 4: Improving the legislation by adding new requirements based on car requirements for mini cars.

Objective

Policy options

s
e

l

i

c
h
e
v

y
r
o
g
e
t
a
c
-
L

d
e
v
o
r
p
m

I

f
o
n
o
i
t
a
s
i
r
o
g
e
t
a
c

Effectiveness
Technical standards meeting effort

Noise, emissions and fuel consumption

Level and appropriateness of current safety 
measures

0

__ __

__ __

Criteria

Efficiency

Compliance costs

Coherence

Better coherence than options 2, 3, 5 ?

__ __

__ __

Conclusion 

Increased clarity for industry and other 
stakeholders

__ __

0

Option 5: Improving the proliferation of vehicle categories by the introduction of dedicated sub categories inL1 and L6&L7. Add new / revised appropriate dedicated requirements for these 
sub categories.
Objective

Policy options

Criteria

Conclusion 

s
e

l

i

c
h
e
v

d
e
v
o
r
p
m

I

y
r
o
g
e
t
a
c
-
L
f
o

n
o
i
t
a
s
i
r
o
g
e
t
a
c

Effectiveness
Technical standards meeting effort

Noise, emissions and fuel consumption

Level and appropriateness of current safety 
measures

0

+

+

Compliance costs

Efficiency

Coherence

Better coherence than options 2, 3, 5 ?

__

Increased clarity for industry and other 
stakeholders

++

++

+

Table 106: option comparison and conclusion table, re-categorisation, options 1 to 5 

EN 

139 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2. 

SPECIFIC REQUIREMENTS FOR CATEGORY L7E VEHICLES 

Option 1: No change

Objective

Policy options

s
e
l
c
i
h
e
v

y
r
o
g
e
t
a
c
-
L

d
e
v
o
r
p
m

I

f
o
n
o
i
t
a
s
i
r
o
g
e
t
a
c

Casualty rates

Effectiveness

Trade barriers owing to divergent requirements 
when type approved (national or EU)
Separation on-road and off-road quads based 
on design criteria in order to develop designated 
safety and environmental measures 

Option 2: Exclude off-road quads from the Framework Directive.

Objective

Policy options

s
e
l
c
i
h
e
v

y
r
o
g
e
t
a
c
-
L

d
e
v
o
r
p
m

I

f
o
n
o
i
t
a
s
i
r
o
g
e
t
a
c

Casualty rates

Effectiveness

Trade barriers owing to divergent requirements 
when type approving off-road quads (national or 
Separation on-road and off-road quads based 
on design criteria in order to develop designated 
safety and environmental measures 

Option 3: Keep the existing category and add new requirements for all quads.

Objective

Policy options

d
e
v
o
r
p
m

I

s
e
l
c
i
h
e
v
y
r
o
g
e
t
a
c

-
L
f
o
n
o
i
t
a
s
i
r
o
g
e
t
a
c

Casualty rates

Effectiveness

Trade barriers owing to divergent requirements 
when type approved (national or EU)

Separation on-road and off-road quads based 
on design criteria in order to develop designated 
safety and environmental measures 

Option 4: Create a new category for off-road quads with specific requirements.

Objective

Policy options

s
e

l

i

c
h
e
v

y
r
o
g
e
t
a
c
-
L

d
e
v
o
r
p
m

I

f
o
n
o
i
t
a
s
i
r
o
g
e
t
a
c

Effectiveness

Casualty rates

Trade barriers owing to divergent requirements 
when type approved (national or EU)

Separation on-road and off-road quads based 
on design criteria in order to develop designated 
safety and environmental measures 

0

0

0

0

__

+

+

0

__

+

0

__

Criteria

Efficiency

Type approval costs

Criteria

Efficiency

Type approval costs

Criteria

Efficiency

Type approval costs

Criteria

Efficiency

Type approval costs

Coherence

Conclusion 

0

+

Appropriate safety measures for 
complete different vehicles
Appropriate environmental measures 
for complete different vehicles
Level of simplification

Coherence

Appropriate safety measures for 
complete different vehicles
Appropriate environmental measures 
for complete different vehicles
Level of simplification

Coherence

__

Appropriate safety measures for 
complete different vehicles
Appropriate environmental measures 
for complete different vehicles

Level of simplification

0

0

0

__

__

+

+

+

__

0

Conclusion 

+

Conclusion 

+

Conclusion 

Coherence

0

Appropriate safety measures for 

ff

Appropriate environmental measures 
for complete different vehicles

+

+

Level of simplification

+

__ __

Table 107: option comparison and conclusion table specific requirements Category L7e vehicles 

3. 

SPECIFIC  REQUIREMENTS  FOR  GASEOUS  ALTERNATIVE  FUELS  AND  OTHER  NON-TRADITIONAL 
PROPULSIONS. 

Option 1: No change

Objective

Policy options

d
e
v
o
r
p
m

I

-
L
f
o
n
o
i
t
a
s
i
r
o
g
e
t
a
c

s
e

l

i

c
h
e
v

y
r
o
g
e
t
a
c

Casualty reduction

Effectiveness

Environmental performance

Level of innovation in environmental and safety 
technology

0

0

0

Criteria

Efficiency

Type Approval Cost

Coherence

Conclusion 

0

Appropriate safety measures for 
complete different vehicles
Appropriate environmental measures 
for complete different vehicles

Level of simplification

0

0

0

0

Option 2: Legislation at European Union level through a tighter grid of vehicle type categorisation with dedicated measures for the different vehicles and propulsion technologies.

Objective

Policy options

s
e

l

i

c
h
e
v

d
e
v
o
r
p
m

I

y
r
o
g
e
t
a
c
-
L
f
o

n
o
i
t
a
s
i
r
o
g
e
t
a
c

Casualty reduction

Effectiveness

Environmental performance

Level of innovation in environmental and safety 
technology

+

++

++

Criteria

Efficiency

Type Approval Cost (initially higher, on 
the long run neutral)

__

Coherence

Appropriate safety measures for 
complete different vehicles
Appropriate environmental measures 
for complete different vehicles
Level of simplification

Conclusion 

++

++

0

+

Table  108:  option  comparison  and  conclusion  table:  dedicated  requirements  for  gaseous  alternative  fuels  and  other  non-
traditional propulsions 

EN 

140 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4. 

PROPOSAL TO RE-CATEGORISE L-CATEGORY VEHICLES 

Category & 
Category Name

Sub category 
& Sub 
category 
name

Example

Number 
of wheels

Propulsion

Max. 
vehicle 
Speed

Internal 
Combustion 
Engine (ICE) 
max. displ. (cm3)

ICE Max. 
Power 
(kW)

Hybrid 
Max. 
Power 
(kW)

Electric 
Motor 
Max. 
Power 
(kW)

Max mass 
(kg)

Internal Combustion Engine (ICE)

Hybrid 
Engine

Electric
Engine

Gasoline & 
Gasoline 
blends

Diesel & 
Diesel 
blends

Gaseous 
(CNG / 
LPG)

2

2

3

2

3

3

3

4

4

4

4

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

L1e,
light two-wheel 
vehicle

L1Ae powered 
cycles

L1Be Moped

L2e Three-
wheel moped

L3e,
motorcycle

L4e,
motorcycle with 
side car

-

-

L5e,
tricycles

L6e,
Light quadricycle

L7e,
Heavy 
quadricycle

L5Ae 
Tricycles

L5Be 
Commercial 
tricycles

L6Ae
Light quad

L6Be
Light mini car

L7Ae
On-road quad

L7Be
Heavy mini 
car

PI: Positive Ignition engine
Table 109: Proposal to re-categorise L-category vehicles 

25

50 (PI)

max. 1

45

50 (PI)

max. 4

45

50 (PI)

max. 4

45

50 (PI)

max. 4

45

50 (PI)

max. 6

max.15 kW

max.15 kW

350

350

400

400 
(passengers) 
550 (goods)

EN 

141 

   EN 

 
 
ANNEX  XVIII:  DETAILS  CHAPTER  7  —  –  MONITORING  &  EVALUATION  ANALYSIS  NEW  VEHICLE  TYPE  APPROVAL 

SIMPLIFICATION AND SAFETY MEASURES 

The following recommendations to monitor and control safety measures were obtained from the TRL report: 

1. 

SIMPLIFICATION 

The  following  issues  were  proposed  by  TRL  to  be  monitored  and  evaluated  in  order  to  ensure  the 
effectiveness of the proposed change: 
- Monitor the key cost parameters used as a basis for the analysis; 
- Number of amendments required to relevant Directives per annum 
- Ongoing costs to member states of implementing current system 
- Monitor numbers of type approvals per annum 
- Time taken for implementation of regulatory changes 
- Monitoring and standardisation of vehicle design 
- Number of technical standard group meetings, travel mode, distance and number of attendees 
- Evaluation of the proposed change should also monitor key costs to allow the accuracy of the cost 
saving (benefit) estimate of option 2 to be assessed. 

2. 

OBLIGATORY FITTING OF ADVANCED BRAKE SYSTEMS 

lack  of  reliable  non-fatal  casualty  data,  requiring  some  broad  assumptions 

In  order  to  monitor  the  effect  of  any  change  in  legislation,  the  number  of  motorcycle  casualties  should  be 
monitored, preferably in relation to the engine capacity of the motorcycle, the equipment fitted and in which 
driving licence category the rider can be attributed to. The quality of this impact assessment was influenced 
by  a 
to  be  made. 
Collection/reporting  of  reliable  non-fatal  data  would  enable  these  assumptions  to  be  verified  and  would  a 
more  accurate  evaluation of  the  effect  of  any  changes.  There was  minimal  information  available  regarding 
the  costs  and  effectiveness  of  combined  Brake  systems.  Data  from  research  studies  similar  to  those 
identified for Anti-lock Brake System would enable a higher confidence in the estimated societal impact for 
casualty prevention. Minimal information was also available regarding future Anti-lock Brake System costs 
and the effect of large scale fitment of systems on the market price. In particular, information on CBS costs 
was lacking and these were estimated. 

3. 

ANTI-TAMPERING MEASURES 

In order to monitor the effect of the selected option it is recommended that the following actions be taken: 
Identify baseline data, especially relating to the current levels of tampering, and the magnitude of the effect 
that  the  tampering  has  on  noise,  tailpipe  emissions  and  the  involvement  of  relevant  vehicle  types  in 
accidents.  Monitor  the  in-use  condition  of  vehicles,  undertaking  a  survey  at  a  representative  sample  of 
periodic/roadside inspections. 

It was recommended to provide more definitive guidance on the effect of future policy options, the impact of 
tampering on safety and the environment should be reviewed in order that the effects can be quantified. If 
effects are identified which cause concern, then a survey should be conducted to monitor the current rates 
and types of tampering present in the current fleet. This could be carried out at periodic inspections, or by 
roadside checks, as used by previous studies. 

74KW POWER LIMITATION FOR MOTORCYCLES 

4. 
Determine baseline data, including: 
•  Sales  data  with  respect  to  engine  power/acceleration  potential  or  whatever  measure  is  used  as  the 

limitation. 

•  Accident  rates  with  respect  to  engine  power/acceleration  potential  or  whatever  measure  is  used  as  the 

limitation. 

•  Emissions/noise data with respect to engine power/acceleration potential or whatever measure is used as 
the  limitation.  Monitor  these  data  in  relation  to  any  other  changes  that  could  influence  the  number  of 
accidents,  emissions  or  noise,  for  example  anti-tampering  measures,  approval  of  hydrogen  powered 
vehicles etc. 

These  actions should  allow  the effect of  the  proposal to  be  identified  after  implementation,  or before  if  the 
implementation is delayed to quantify the possible impacts further. 

EN 

142 

   EN 

 
ANNEX  XIX:  DETAILS  CHAPTER  7  —  MONITORING  &  EVALUATION  IMPROVED  CATEGORISATION  OF  L-CATEGORY 

VEHICLES 

1. 

RE-CATEGORISATION  ELECTRIC  ASSISTED  CYCLES 
CURRENTLY), TRICYCLES (L5E) AND QUADRICYCLES (CATEGORIES L6E AND L7E) 

(OUTSIDE  SCOPE  OF  LEGAL  FRAMEWORK 

The following recommendations are relevant for the re-categorisation of L1e, L6E & L7e vehicles: 
Significant  uncertainties  remain  regarding  key  costs  in  the  approvals  process  and  in  the  casualty  and 
environmental  impacts  of  the  proposed  options.  These  should  be  monitored  and  further  data  obtained  to 
refine the assessments of potential impacts. More detailed accident data is required to provide information 
on  the  safety  of  quadricycles  and  to  allow  the  impact  of  any  measures  to  be  assessed.  A  more  specific 
categorisation of L1e, L6E & L7e vehicles would allow the safety impact of future measures to be monitored. 

2. 

SPECIFIC REQUIREMENTS FOR OFF-ROAD QUADS (ALL TERRAIN VEHICLES, ATVS) 

Data required to perform a full cost benefit analysis for these options was not obtained from the consultation 
process.  Evaluation  of  the  costs  of  the  proposed  options  could  be  gathered  by  monitoring  type  approval 
costs prior to 2011 (the proposed earliest implementation of any change) and further investigation of costs 
for national approval. This would allow costs involved with the approval processes of all proposed options to 
be  more  accurately  quantified.  For  all  options  it  is  important  that  a  means  of  collecting  European  accident 
data  for  quadricycles  is  implemented  and  that  this  accident  data  is  disaggregated  for  different  quadricycle 
types  and  accident  locations  (on-road  and  off-road).  This  would  allow  clearer  assessment  of  the  societal 
benefits  of  future  safety  improvement  measures.  Monitoring  of  accident  data  would  allow  future  safety 
related changes to be identified and evaluated. 

3. 

DEDICATED  REQUIREMENTS  FOR  GASEOUS  ALTERNATIVE  FUELS  AND  OTHER  NON-TRADITIONAL 
ALTERNATIVE PROPULSIONS. 

The following should be monitored and evaluated: Some hydrogen-powered category L vehicles are likely to 
be  produced  in  very  low  numbers  only.  For  these  vehicles,  it  might  be  acceptable  to  pursue  a  policy  that 
results  in  individual  vehicle  approval  schemes  at  Member  State  level.  Possible  uncertainties  include:  the 
proportion  of  road  miles  likely  to  be  driven  by  each  category  of  hydrogen-powered,  other  gaseous  fuel-
powered or non-traditionally propelled category L vehicles; the environmental effects of new petrol and diesel 
engines; the effects of any Government incentives. 

EN 

143 

   EN 

 
 
 
ANNEX XX: ABBREVIATION LIST AND GLOSSARY 

2S 

4S 

ABS 

ABS 

ACEM  

AECC 

Two Stroke engine 

Four Stroke engine 

Anti-lock  Brake  System.  The  Antilock  Brake  System  is  a  closed  loop  controlled  brake 
system which prevents the wheels from locking while braking. The purpose of this is on the 
one hand to avoid a possible fall of the motorcycle rider and on the other hand to shorten 
found  on: 
braking  distances.  A  more  detailed 
http://en.wikipedia.org/wiki/Anti-lock_braking_system#Motorcycles 

technical  explanation  can  be 

Advanced Braking Systems.  
NB  
1) In the TRL report this is a summary expression of Combined Brake System (CBS) or 
Anti-lock Brake Systems (ABS). 
2)  ACEM  considers  under  Advanced  Brake  System:  a  brake  system  in  which  either  an 
Antilock Brake System and/or a Combined Brake System is present. 

Association des Constructeurs Européens de Motocycles www.acembike.org 

Association for Emissions Control by Catalyst www.aecc.eu  

AFQUAD 

Association 

européenne 

des 

fabricants 

et 

importateurs 

de 

quadricycles 

ATV 

All Terrain Vehicle 

ATVEA 

All Terrain Vehicle Industry European Association www.atvea.org  

BASt 

BAT 

CAN 

Federal Highway Research Institute (Germany) 

Best Available Technology 

Controller Area Network, referred to as communication protocol (language) between ECU 
and generic scan tool 

CARS 21 

Competitive Automotive Regulatory System for the 21st century 

CB 

CBS 

Ch. 

CLEPA 

CLWP 

CNG 

CO 

CO2 

CoC 

COM 

CoP 

COP 

Carburettor 

Combined Brake System 

Chapter 

European Association of Automotive Suppliers www.clepa.com  

Commission Legislative and Work Programme 

Compressed Natural Gas (mainly methane) 

Carbon monoxide 

Carbon dioxide 

Certificate of Conformity 

The European Commission 

Conformity of Production 

Conformity of Production 

DeNOx 

NOx emission control devices 

DI 

Direct Injection 

EN 

144 

   EN 

 
DPF 

DTC 

EBD 

EU 

Diesel Particle Filter 

Diagnostic Trouble Code 

Electronic Brake Distribution 

European Union 

ECE-R40 

United Nations Economic Commission for Europe Regulation 40 driving cycle 

ECE-R47 

United Nations Economic Commission for Europe Regulation 47 driving cycle 

ECU 

EDC 

EEA 

EEA 

EFI 

EMPA 

EOBD 

EoS 

EUDC 

Engine Control Unit 

European Driving Cycle for L-category vehicles (6 super cycles & EUDC) 

European Environmental Agency 

EU Legal provisions will also apply to Iceland, Norway, and Liechtenstein. 

Electronic Fuel Injection 

Federal Laboratories for Materials Testing and Research (Switzerland) 

European On Board Diagnostics 

End-of-Series (vehicle) 

Extra Urban Driving Cycle (high vehicle speed part of the laboratory test cycle) 

Euro 3, Euro 
4, Euro 5, 

Emission standards for air pollutants HC, CO, NOx and PM 

EuroStat 

European Institute to gather, process and publish statistical data  

FC 

FE 

FEMA 

FF 

FI 

GDi 

GHG 

GSR 

HC 

IA 

IASG 

ICE 

IES 

IMMA 

IUC 

IUPR 

Fuel Consumption [l./100 km] 

Fuel Economy [km per litre] 

Federation of European Motorcyclists’ Associations

Freeze  Frame  information.  These  are  generic  engine  parameters  listed  on  the  moment 
while  a  failure  was  detected  and  a  DTC  was  stored  in  the  Engine  Control  Unit  memory. 
This information helps a service technician to diagnose and pinpoint a failure of the system. 
Best  case  it  helps  to  determine  finding  the  smallest  exchangeable  /  repairable  unit  in  the 
system
Fuel Injection 

Gasoline Direct Injection 

GreenHouse Gas 

General Safety Regulation  

HydroCarbons 

Impact Assessment 

Impact Assessment Steering Group 

Internal Combustion Engine 

Institute for Environment and Sustainability (European Commission) 

International Motorcycle Manufacturers Association 

In-Use Compliance / In-Use Conformity testing 

In Use Performance Ratio 

EN 

145 

   EN 

 
JRC 

LAT 

Joint Research Centre (European Commission) 

Laboratory  of  Applied  Thermodynamics  (Aristotle  University,  Greece).  Institute  that 
assessed the environmental policy options.  

L-category 

Light vehicles e.g. 2&3 wheel Mopeds, 2& 3 wheel motorcycles, quads, all terrain vehicles 
and  mini  cars.  All  these  different  vehicle  types  are  categorised  in  7  different  classes 
currently. Refer to Annex I X for the details on the classification. 

LPG 

Liquefied Petroleum Gas (mix of propane and butane) 

M.V.E.G. 

Motor Vehicle Emissions Group 

M.V.W.G. 

Motor Vehicles Working Group 

MC 

Motorcycle 

MCWG 

Motor Cycle Working Group 

MIL 

MY 

Malfunction Indicator Lamp 

Model Year 

NEDC 

New European Driving Cycle 

NG 

NOx 

NPV 

OBD 

OCE 

OEM 

Natural Gas (mainly methane) 

Nitrogen Oxides 

Net Present Value 

On-Board Diagnostics 

Off Cycle Emissions 

Original Equipment Manufacturer 

OxiCat 

Oxidation Catalyst 

PM 

PTI 

PTW 

Particulate Matter 

Periodical Technical Inspection 

Powered Two Wheelers 

R40 test cycle  Moped test cycle as specified in UNECE regulation 40 (4 ECE super cycles) 

R47 test cycle   Moped test cycle as specified in UNECE regulation 47 

R&D  

Research and Development 

RESS 

RLP 

RMI 

RSI 

RSI 

RW 

SD 

1) Replacement Exhaust Silencer System 
2) Rechargeable Energy Storage System 

Rear wheel Lift-off Protection 

Retail Motor Industry Federation www.rmif.co.uk  

Road Side Inspection 

Road Side Inspection 

Road Worthiness 

Separate Directives in relation to framework directive or mother regulation. 

SHED 

Sealed Housing Evaporative Determination 

EN 

146 

   EN 

 
SME 

TA 

TAAM 

TAR 

TCMV 

THC 

TNO 

TRL 

TÜV 

TWC 

UDC 

Small Medium Enterprise 

Type-Approval 

Type-Approval Authorities Meetings 

Type-Approval Regulation 

Technical Committee Motor Vehicles 

Total  HydroCarbons  measured  in  the  appropriate  emission  laboratory  test  cycle  or  if  it  is 
used  in  the  context  of  air  quality:  all  hydrocarbon  emissions  when  adding  up  evaporative 
and tail pipe emissions from vehicles 

Netherlands Organisation for Applied Scientific Research 

Transport Research Laboratory. Institute that assessed the safety policy options. 

Technical Inspection Agency (Germany) 

Three Way Catalyst 

Urban driving Cycle 

UNECE  

United  Nations  Economic  Committee  for  Europe  —  World  Forum  for  Harmonisation  of 
Vehicle Regulations (WP.29)63 

VOC 

VOC 

WMTC 
WP29 

Volatile Organic Compound 

Volatile organic compounds 

World-wide Motorcycle emissions Test Cycle 
Working Party of the UNECE, which is the World Forum for Harmonisation of 
Vehicle Regulations 

Table 110: Abbreviation List and Glossary 

63

www.unece.org/trans/main/welcwp29.htm 

EN 

147 

   EN