COMMISSION STAFF WORKING DOCUMENT Accompanying document to the
Date: 2011-01-13
Institutions: European Commission
Subjects: air quality, approximation of laws, motor vehicle, pollution control measures, technical regulations, tractor

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EUROPEAN COMMISSION 

Brussels, 13.1.2011 
SEC(2011) 43 final 

COMMISSION STAFF WORKING DOCUMENT 

Accompanying document to the  

Proposal for a 

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

amending Directive 2000/25/EC as regards the application of emission stages to narrow-track 
tractors 

Impact Assessment 

SEC(2011) 44 final 
COM(2011) 1 final 

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

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TABLE OF CONTENTS 

Procedural issues and positions from consultation of interested parties .............. 4 

Introduction .................................................................................................................. 4 

Organisation of the impact assessment ........................................................................ 4 

Impact Assessment Board ............................................................................................ 5 

Relevant scientific studies............................................................................................ 6 

Consultation of stakeholders ........................................................................................ 6 

Background, problem definition and subsidiarity .................................................. 7 

Policy Context .............................................................................................................. 7 

Economic context......................................................................................................... 9 

Market overview .......................................................................................................... 9 

Emissions from Narrow-track Tractors...................................................................... 11 

Problem definition...................................................................................................... 11 

Affected parties .......................................................................................................... 14 

Subsidiarity and proportionality................................................................................. 14 

Objectives.................................................................................................................. 15 

Definition of objectives.............................................................................................. 15 

Consistency with other horizontal objectives of the European Union ....................... 15 

Policy Options........................................................................................................... 17 

Options identified....................................................................................................... 17 

Options discarded at an early stage ............................................................................ 18 

Analysis of impacts................................................................................................... 19 

Impacts of Option 1 (no new action).......................................................................... 19 

Impacts of Option 2 (Allowing 3 extra years)............................................................ 24 

Impacts of Option 3 (Allowing 5 extra years)............................................................ 26 

Impacts of Option 4 (Exemption)............................................................................... 27 

Comparison of the options....................................................................................... 28 

Monitoring and evaluation ...................................................................................... 30 

Indicators of progress towards meeting the objectives .............................................. 30 

Ongoing dialogue with stakeholders .......................................................................... 30 

1. 

1.1. 

1.2. 

1.3. 

1.4. 

1.5. 

2. 

2.1. 

2.2. 

2.3. 

2.4. 

2.5. 

2.6. 

2.7. 

3. 

3.1. 

3.2. 

4. 

4.1. 

4.2. 

5. 

5.1. 

5.2. 

5.3. 

5.4. 

6. 

7. 

7.1. 

7.2. 

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Annex I – Glossary & Definitions............................................................................................ 32 

Annex II - Reference Documents ............................................................................................. 34 

Annex III – Emission limit standards relevant for NTTs ......................................................... 35 

Annex IV - Implementation dates ............................................................................................ 36 

Annex V – Examples of Narrow Track Tractors...................................................................... 39 

Annex VI - Typical NTT Engine and Vehicle Development Process...................................... 40 

Annex VII –Stakeholders' opinions at Working Group for Agricultural Tractors meeting..... 41 

Annex VIII – Relevant parts of the JRC report 2008............................................................... 46 

Annex IX – Relevant sections of the ARCADIS report 2009.................................................. 59 

Annex X – Relevant sections of the ARCADIS SME Test report 2010 .................................. 68 

Annex XI - Fleet and annual sales of tractors .......................................................................... 81 

Annex XII – Estimation of environmental impacts.................................................................. 82 

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1. 

PROCEDURAL  ISSUES  AND  POSITIONS  FROM  CONSULTATION  OF  INTERESTED 
PARTIES 

1.1. 

Introduction 

This report provides an assessment of the impact of pollutant emission requirements on a 
specific  type  of  agricultural  tractor,  generally  called  the  narrow-track  tractor  (NTT)1. 
NTTs exist in three categories: T2, C2 and T4.12, as defined in the Framework Directive 
on the type-approval of tractors3. These tractors are specially designed to meet the specific 
terrain  and  layout  characteristics  of  vineyards  and  orchards  in  Europe  and,  as  a 
consequence, are almost solely produced and used in Europe. Their specific design - which 
makes them suitable for use in narrow rows in vineyards and orchards - creates particular 
engineering  constraints,  mainly  dimensional,  for  integrating  new  technology  while 
meeting customer requirements.  

Pollutant emissions, such as carbon monoxide (CO)4, hydrocarbons (HC), nitrogen oxides 
(NOx)  and  particulate  matter  (PM)  from  tractors,  including  NTTs,  are  regulated  by 
Directive  2000/25/EC5.  This  Directive  was  amended  by  Directive  2005/13/EC6  that 
introduced  the  currently  applicable  level  of  emission  limits,  called  Stage  IIIA.  It  also 
defined  the  more  stringent  Stage  IIIB  and  Stage  IV  limits  that  will  enter  into  force 
progressively, depending on the engine power category.7 

Article 4.8 of the amended Directive points to the particular needs of narrow-track tractors 
and  tasks  the  Commission  with  reviewing  and  potentially  revising  the  foreseen  emission 
limits requirements in accordance with these needs. The current impact assessment (IA) is 
part of the implementation by the Commission of this legal requirement.  

It  is  considered  that  this  IA  concerns  a  ‘narrow’  legislative  action,  as  defined  in  Section 
3.3.1 of the European Commission Impact Assessment Guidelines of 15 January 20098.  

1.2. 

Organisation of the impact assessment 

The  current  initiative  is  mentioned  in  the  Commission's  Work  Programme  under  the 
reference  2010/ENTR/011.  Directive  2000/25/EC  on  tractor  emissions,  including  its 
revisions,  makes  extensive  reference  to  Directive  97/68/EC  on  emissions  of  non-road 
mobile  machinery  (NRMM).  Due  to  the  significant  overlap  between  the  two  legislative 

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See Annex V for examples of narrow tractors. 
T4.1 tractors strictly speaking are not narrow-track tractors but high-clearance tractors, riding above the vines during work; 
they have the same constructional limitations and problems as the other 2 categories.  
Directive 2003/37/EC 
Additional information on abbreviations used is available in the Glossary in Annex I. 
OJ L 173, 12.7.2000, p.1. 
OJ L 55, 1.3.2005, p.35. 
See Annex III, for a detailed table 
http://ec.europa.eu/governance/impact/commission_guidelines/docs/iag_2009_en.pdf  

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acts, the technical review (see supporting studies in section 1.4 below) on both legislative 
acts was carried out jointly. The review identified a need for action in three areas: 

–  the need for additional flexibilities for NRMM; 

–  the need for additional flexibilities for tractors; 

–  the particular difficulties for NTTs to meet the emission requirements. 

The  first  two  areas  have  already  been  subject  to  an  Impact  Assessment  and  legislative 
proposals are currently in preparation. This report concerns the third area. 

The  present  Impact  Assessment  was  led  by  DG  Enterprise  and  Industry  and  carried  out 
between 21 January 2010 and 21 September 2010. For the purposes of this IA, an Impact 
Assessment  Steering  Group  (IASG)  was  created  involving  the  Secretariat-General  (SG), 
the  Legal  Service,  DG  Environment  (ENV),  DG  Mobility  and  Transport  (MOVE),  DG 
Economic  and  Financial  Affairs  (ECFIN),  DG  Employment,  DG  Trade  and  DG 
Agriculture.  The  IASG  met  twice  on  22  July  2010  and  21  September  2010.  The  SG, 
MOVE,  ENV  and  ECFIN  contributed  to  the  IA  either  through  participation  in  these 
meetings or via written contributions. As significant analysis of the issue had already been 
performed in previous studies (see section 1.4 below), two IASG meetings were deemed 
sufficient. The suggestions of the IASG group have been incorporated in the IA. 

1.3. 

Impact Assessment Board 

A  draft  Impact  Assessment  Report  was  presented  on  20  October  2010  to  the  Impact 
Assessment  Board.  Further  to  that  meeting,  the  following  improvements  have  been 
integrated to the report as requested in the opinion of the Board:  

–  the reasons for unavailability of compliant NTTs were clarified (in Chapter 2) 

–  further explanations on the flexibility scheme have been added (in Chapter 2) 

–  the technological issues have been elaborated in more detail (in Chapter 2) 

–  the baseline scenario and assessment of impacts have been clarified (in Chapter 5) 

–  more  detailed  treatment  of  health  impacts  and  the  transition  to  Stage  IV  have  been 

added (in Chapter 5). 

In addition, several other minor improvements were made, based on technical comments 
received from the Board. 

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1.4. 

Relevant scientific studies 

The impact assessment is based on a number of scientific studies9. These were carried out 
to investigate many different topics, covering NRMM and all types of tractors, as well as 
the specific needs of NTTs. The three studies are: 

–  A  Technical  Review10  by  the  Joint  Research  Centre  (JRC),  September  2008,  which 
includes, inter alia, a specific evaluation on NTTs. For NTTs, the study confirmed the 
severe  technical  difficulties  of  meeting  Stage  IIIB  and  IV  requirements.  Hence,  the 
impacts of exempting NTTs and delaying both stages by 5 years were analysed. 

–  An  Impact  Assessment  study11  by  ARCADIS,  January  2009,  to  assess  the  impacts  of 
the  policy  options  as  defined  in  the  Technical  Review  of  JRC.  For  NTTs,  the  study 
analysed the impacts of three policy options: no change policy option, a 5-year delay in 
implementation  and  an  exemption  from  the  emission  requirements.  The  5-year  delay 
came out clearly as the preferred option. 

–  An  additional  SME  Test  study12,  March  2010.  For  NTTs,  detailed  information  was 
obtained  for  the  professional  users  of  NTTs  in  the  agricultural  sector  and  for 
manufacturers  of  a  specific  type  of  NTTs  (high-clearance  tractors).  The  study 
confirmed  the  substantial  difficulties  these  businesses  would  face  if  the  emission 
requirements  would  not  be  changed,  including  details  on  the  length  of  homologation 
procedures. 

1.5. 

Consultation of stakeholders 

For  the  assessment  of  some  of  the  requirements  of  the  tractors  and  NRMM  emissions 
Directives, the Commission’s services carried out between May and June 2009 an in depth 
consultation  with  Member  States’  authorities  and  other  stakeholders  (industry, 
environmental  organisations,  workers  associations)13.  In  addition  to  two  meetings  of  the 
Working  Group  on  Agricultural  Tractors  (WGAT),  composed  of  representatives  of 
Member  States  and  other  stakeholders  advising  the  Commission  on  tractors-related 
issues14,  additional  meetings  were  organised  with 
the  Committee  for  European 
Construction Equipment (CECE) and the Committee for European Agricultural machinery 

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12 

13 

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final 

report 

All  studies  can  be  found  on  the  Europa  website:  http://ec.europa.eu/enterprise/sectors/mechanical/non-road-mobile-
machinery/publications-studies/index_en.htm
The final report of the Technical Review is available on the NRMM web page at the Europa website 
http://ec.europa.eu/enterprise/sectors/mechanical/files/nrmm/final_report_nrmm_review_part_ii_en.
pdf. 
The 
available 
http://ec.europa.eu/enterprise/sectors/mechanical/files/nrmm/ia_study_on_nrmm-_final_report_-
_arcadis_en.pdf. The parts of the study relevant for this IA have been included in Annex IX. 
website: 
The 
http://ec.europa.eu/enterprise/sectors/mechanical/files/nrmm/final_report_sme_test_nrmm_2010_03_29_en.pdf.  The  parts 
of the study relevant for this IA have been included in Annex X. 
Summarised  information  on  the  contributions  of  the  public  consultation  on  this  proposal  may  be 
found in Annex V 
See Annex VII. 

available 

website: 

Europa 

Europa 

report 

final 

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Manufacturers (CEMA). On 17 July 2009 a consultation was held with the Expert Group 
on Emissions of NRMM.  

An additional meeting with industry representatives was organised on 2 September 2010 
with  a  view  to  obtaining  additional  information  on  the  state  of  preparedness  of  the 
industrial actors to meet Stage IIIB and Stage IV emission requirements. 

The positions of different stakeholders can be briefly described as follows: 

–  manufacturers  of  narrow  tractors  have  clearly  stated  since  2005  that  there  are  severe 
technical  difficulties  for  NTTs  in  meeting  the  emission  requirements.  They  initially 
called for an exemption and later for a 5-year delay of Stages IIIB and IV.  

–  manufacturers of engines and after-treatment devices have only recently presented new 

technological concepts that could be developed into solutions for NTTs.  

–  also, several Member States (Italy, Austria, France, Spain, Greece, Finland Sweden, the 
Netherlands)  have  recognised  the  problem  and  asked  the  Commission  to  take  the 
necessary action in order to avoid severe negative consequences for the sector. 

Also  consumer  organisation  BEUC,  representatives  of  agricultural  and  rural  contractors, 
the association of clean fuels (IANGV) and that of catalysts manufacturers (AECC) were 
invited. No reaction from environmental organisations was received. 

A summary of the positions expressed by the various stakeholders in those meetings can 
be found in Annex V. 

2. 

BACKGROUND, PROBLEM DEFINITION AND SUBSIDIARITY 

2.1. 

Policy Context 

The  tractors  emissions  Directive  2000/25/EC15  was  adopted  by  the  European  Parliament 
and the Council in 2000 and amended in 2005 by Directive 2005/13/EC. Both acts defined 
the pollutant emission limits and their mandatory introduction dates based on the scientific 
knowledge available at that time.  

The Directive covers all categories of agricultural and forestry tractors (hereafter: tractors), 
including  the  NTTs  described  above.  The  required  emission  limits  are  based  upon  those 
contained  in  Directive  97/68/EC,  which  covers  emission  limits  for  non-road  mobile 
machinery  (NRMM)  because  engines  used  for  these  two  applications  are  of  a  similar 
technical  nature,  and  it  is  logical  that  their  emission  requirements  should  be  aligned  to 
allow interchangeability between engine designs used for NRRM and tractor applications. 

For  all  types  of  tractors,  the  Directive  stipulates  the  maximum  permitted  engine  exhaust 
emissions  as  a  function  of  the  power  of  the  installed  engine.  Moreover,  the  Directive 
includes  a  series  of  emission  limit  stages  of  increasing  stringency  with  corresponding 

15 

OJ L 173, 12.7.2000, p.1. 

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compliance  dates16.  Tractor  manufacturers  must  ensure  that  new  engines  used  in  their 
tractors comply with these limits when placing them on the market. The reductions in PM 
and  NOx  emissions  resulting  from  stricter  emission  limits  are  significant  and  come  in 
addition to those obtained with the previous Stages. For PM, a reduction by 88 to 94 % is 
required  for  the  transition  from  Stage  IIIA  to  Stage  IIIB;  for  NOx  similar  reductions  are 
required for the transition from Stage IIIB to Stage IV (as can be seen in the last table of 
Annex III). 

Stage IIIA emission requirements have been applicable to NTTs since 1 January 2008. The 
implementation dates currently defined concerning the placing on the market of NTTs for 
the  relevant  engine  categories  are  as  set  out  in  the  table  below.  New  type-approvals  of 
NTTs need to comply with the new stages one year ahead of these dates. 

Engine power 

Implementation date 

Implementation date 

56-75 kW 

37-56 kW 

(Stage IIIB) 

(Stage IV) 

1 January 2012 

1 October 2014 

1 January 2013 

- 

As the Stage IIIB limits are much stricter than the currently applicable Stage IIIA, current 
engines will need to be modified or re-designed to ensure that the limits can be respected. 
Engine  manufacturers  must  develop  and  apply  the  technology  needed:  engines  must  be 
fitted with electronic control systems and high pressure injection systems that deliver the 
fuel  at  the  right  time  and  in  the  right  quantity  for  a  cleaner  burning  in  the  combustion 
chamber.  In  addition,  exhaust  gas  recirculation  (EGR)  and  possibly  sophisticated  after-
treatment systems are necessary. Several of these technologies require additional cooling 
capacity.  

The further transition from Stage IIIB to Stage IV is likely to require the fitting of a NOx 
after-treatment system (or making an existing system more efficient) and/or the installation 
of a Diesel Particulate Filter (DPF). In on-road applications, development work is ongoing 
on  combining  these  after  treatment  systems  into  a  single  device  that  reduces  the  space 
requirement when fitted on the vehicle. 

These  redesigns  affect  tractor  manufacturers  who  have  to  adapt  the  design  of  their 
tractors  to  accommodate  the  modified  engines.  This  is  a  time-  and  resource-consuming 
procedure,  the  timing  of  which  depends  heavily  on  the  development  programmes  of  the 
engine  manufacturers  to  design  engines  appropriate  for  NTT  applications.  Considerable 
R&D investment is required for these processes. 

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The emission limits and implementation dates can be found in Annexes III and IV  

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2.2. 

Economic context 

From  autumn  2008  onwards  most  of  the  EU-based  production  of  machinery  has  been 
unexpectedly  and  severely  hit  by  the  global  financial  and  economic  crisis.  Steep  falls  in 
sales  caused  a  large  decrease  in  income  and  available  capital  to  finance  the  necessary 
technology  research  and  development  (R&D)  for  machinery  with  Stage  IIIB  compliant 
engines. Firms prioritise their R&D expenditure to cover firstly those products with high 
existing and potential sales' volumes. These sales then provide the business with revenues 
that can be used for R&D in order to develop technical solutions for smaller niche markets.  

For agricultural tractors as a whole the decline started in most European countries in early 
2009. For the sector of NTT the crisis seems to have little effect on the sales to date, but 
there  will  be  some  indirect  effects  from  other  product  lines  ('normal'  tractors)  if  the 
company produces those too. 

Moreover,  the  global  crisis  affecting  the  European  economy,  particularly  the  reduced 
availability  of  credit,  has  definitely  made  R&D  and  other  investments  for  new  products 
harder  also  for  NTT  manufacturers.  However,  this  was  not  considered  to  be  the  main 
reason for this action which is first of all based on technical grounds. 

2.3.  Market overview 

Narrow tractors are a product manufactured exclusively in Europe and sold almost entirely 
on the European market. In other regions of the world, such as the USA or South America, 
available  field  space  is  much  bigger  (JRC,  2007)  and  therefore  normal  types  of  tractors 
with  specific  dedicated  equipment  can  be  used  for  the  cultivation  of  vineyards  and 
orchards.  

The  European  Committee  of  associations  of  manufacturers  of  Agricultural  Machinery 
(CEMA)  estimates  that  around  26  000  units  of  NTTs  are  sold  per  year  in  the  EU,  and 
2 500  outside  the  EU17.  NTTs  represent  around  16%  of  the  total  EU  market  for  new 
tractors,  which  is  about  160.000  units  annually.  The  average  price  of  a  narrow  tractor  is 
€ 30 000  with  a  minimum  of  € 17 000  and  a  maximum  of  € 58 000,  corresponding  to  an 
estimated turnover of € 843 million. However, for very specific products (types) the prices 
can be as high as € 100 000. These prices are 15-20% higher than for a 'normal' tractor of 
comparable engine power and even up to 50% higher for sophisticated versions due to the 
need  to  design  as  small  as  possible  NTTs  with  specific  technical  features  to  be  able  to 
manoeuvre in narrow vineyard and orchard rows. 

NTT use engines of the power categories below 75 kW. Around 75% of the NTTs sold are 
in the 37-75 kW engine categories and are the focus of this report. The NTTs which fall in 
the  lower  engine  categories  (below  25  kW)  are  not  subject  to  Stage  IIIB  and  IV 
requirements.  NTT  manufacturers  do  not  produce  their  own  engines,  but  purchase  them 
directly  from  specialised  engine  manufacturers.  The  latter  supply  also  engines  for 
machinery  and  other  types  of  tractors.  New  engine  designs  are  usually  developed  in  the 
first  place  for  applications  in  different  types  of  machinery.  The  engine  designs  are  then 

17 

See Annex XI for more details. 

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adapted,  either  by  the  engine  supplier  or  the  tractor  manufacturer,  for  tractors.  Special 
tractors,  such  as  NTTs,  require  further  technical  development  of  the  engine  and 
surrounding  systems  (see  Annex  VI  for  typical  industrial  development  steps  and  their 
timeline).  Since  NTTs  constitute  only  a  minor  market  for  the  engine  suppliers,  the 
development work of an engine specifically for an NTT may not represent a high priority 
for  an  engine  manufacturer  compared  to  other  engine  categories.  Delays  in  developing 
engines  appropriate  for  NTT  applications  may  impact  on  NTT  manufacturers  as  NTT 
vehicle re-engineering can only occur once the basic engine design is known.  

The  development  and  production  of  NTTs  is  to  a  very  large  extent  done  by  specialised 
companies of a limited size and capital. This can be illustrated by the fact that some major 
tractor manufacturers have NTTs in their offer, but instead of producing them themselves, 
they rely on the supply from smaller manufacturers dedicated completely to producing this 
type of product. An SME Test study was performed and investigated, among other things, 
the specific situation of small businesses producing or using NTTs18.  

In  terms  of  market  structure,  for  tractors  belonging  to  the  categories  T2  and  C2,  the  4 
largest companies in the EU hold a market share of 55%; the remainder of the market is in 
the  hands  of  SMEs.  All  producers  are  based  in  Italy  or  Germany,  and  the  SMEs  are  all 
Italian.  Altogether,  these  producers  employ  1 800  people  directly,  and  1 200  people 
indirectly.  The  SME  test  study  (see  Section  1.4.  above)  was  not  able  to  provide  much 
specific data on T2 and C2 manufacturers, as the companies contacted did not match the 
official definition of SME (i.e. having a maximum of 250 employees). In fact, the larger 
companies  in  this  segment  typically  employ  300-400  persons  and  therefore  can  still  be 
considered as small industrial enterprises, although strictly speaking not SMEs.  

According  to  the  same  study,  high-clearance  tractors  (T4.1)  are  typically  produced  in 
France.  The  total  production  is  500-600  units  per  year,  with  95%  coming  from  2 
manufacturers  (one  SME,  one  is  part  of  a  larger  group);  5%  comes  from  3  very  small 
specialists. 90% of the production is sold in France. Sales dropped 12% in 2007-2008 and 
another  12  to  15%  in  2009,  largely  as  a  result  of  the  economic  recession.  The  study 
observed  that  for  two  out  of  the  three  companies  interviewed  the  length  of  the 
homologation procedure was a major concern and that the implications of future emission 
requirements  were  not  well  understood.  However,  these  two  companies  were  very  small 
businesses,  representing  a  very  limited  part  of  the  market.  These  observations  cannot  be 
generalised  for  the  high-clearance  segment,  neither  to  the  NTT  sector  as  a  whole,  and 
should be considered of marginal importance. Further details on these manufacturers can 
be found in the SME Test study. 

End-users  of  NTTs  are  typically  SMEs,  and  mostly  micro-firms  including  farmers  and 
contract workers. NTTs are used mainly in the mountains and hills in Southern Europe in 
the regions where high quality wines are produced. Further details on these companies can 
be found in the SME Test study. 

18 

See Annex X: "SME Test study and IA on possible options for reviewing the Directive 97/68/EC 
relating to NRMM", ARCADIS, 30-03-2010. This includes a chapter specifically on NTT. 

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2.4. 

Emissions from Narrow-track Tractors 

The key air polluters from tractors are particulate matter (PM) and nitrogen oxide (NOx) 
emissions19.  Although  carbon  monoxide  (CO)  and  hydrocarbons  (HC)  emissions  from 
tractors  are  also  regulated,  emission  requirements  only  change  marginally  for  these 
pollutants.  Therefore,  the  analysis  will  focus  on  PM  and  NOx.  According  to  the  latest 
report  of  the  European  Environment  Agency  (EEA)  on  the  EU's  emissions  of  air 
pollutants20  the  total  PM1021  emissions  in  the  EU27  in  2008  amounted  to  2.126  kt.  For 
NOx the total emissions were 10.397 kt in 2008. The report also attributes around 4% of 
PM10  emissions  and  5%  of  NOx  emissions  to  off-road  vehicles  used  in  agriculture, 
forestry and fishing. For the sake of comparison, road transport is deemed responsible for 
14 % of PM10 emissions and 37% of NOx emissions. 

Using figures from the Arcadis study (section 3.6.1) as a basis for calculation, the annual 
emissions from NTTs can be estimated at 4.8 kt of PM and 51 kt of NOx. This represents 
0.2%  of  the  total  annual  emissions  of  PM  in  the  EU  and  0.5%  for  those  of  NOx.  These 
emissions  are  generated  by  the  current  NTT  fleet,  which,  taking  into  account  that  the 
average  lifetime  of  an  NTT  is  nine  years,  includes  only  a  small  proportion  of  NTTs 
complying  with  Stage  IIIA.  This  contribution  from  NTTs  to  air  pollution  in  the  EU 
provides the rationale for increasing the efforts to reduce pollutant emissions in the coming 
years.  Any  proposal  should  therefore  carefully  consider  the  policy  objective  to 
progressively reduce overall air pollutant emissions from road transport, including tractors.  

2.5. 

Problem definition  

The problem under examination concerns the feasibility of meeting the currently enacted 
emission requirements for NTTs. As things currently stand, this issue is composed of two 
elements: regulatory failure and lack of technological feasibility.  

2.5.1.  Regulatory failure 

When the emission limits for NTTs were introduced by the legislator there was a limited 
amount of information available on the technology needed to meet those values. The 2004 
amendment for NRMM, Directive 2004/26/EC was based on the need for alignment with 
USA exhaust emission legislation. At that time, the envisaged measure was much broader 
and the specific impact on NTTs was probably underestimated. However, the Directive did 
provide  for  a  technical  review  clause  which,  among  others,  requires  the  Commission  to 
“consider the available technology, including the cost/benefits, with a view to confirming 

19 

20 
21 

amended, 

Definitions of the gaseous and particulate pollutants are the same as in Directive 97/68/EC Annex I, 
as 
include: 
 '2.2. gaseous pollutants shall mean carbon monoxide, hydrocarbons (assuming a ratio of C1: H1.85 
and oxides of nitrogen,  the  last  named  being  expressed  in  nitrogen dioxide  (NO2  equivalent;  2.3. 
particulate pollutants shall mean any material collected on a specified filter medium after diluting 
C.I.  engine  exhaust  gas  with  clean  filtered  air  so  that  the  temperature  does  not  exceed  325  K 
(52 oC)' 
http://www.eea.europa.eu/publications/european-union-emission-inventory-report  
Particulate matter below 10 µm diameter 

and 

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Stage IIIB and IV limit values and evaluating the possible need for additional flexibilities, 
exemptions  or  later  introduction  dates  for  certain  types  of  equipment  or  engines  and 
taking  into  account  engines  installed  in  non-road  mobile  machinery  used  in  seasonal 
applications”.  The  2005  amendment  of  the  tractors  Directive  was  adopted  in  the 
comitology  procedure  simply  aligning  the  requirements  for  all  tractors  with  those 
applicable  to  NRMM  engines.  The  potential  existence  of  difficulties  for  NTTs  was 
acknowledged and article 4 (8) was introduced requiring a further study of the feasibility 
of the foreseen emission limits for NTTs. 

Over  time,  it  was  confirmed  that  NTTs  would  have  serious  difficulties  meeting  the 
emission  requirements.  This  is  because  contrary  to  normal  –larger-  tractors,  NTTs  have 
only a limited space available for the fitment of new engine and pollutant after-treatment 
technologies,  which  are  needed  to  meet  the  next  stages  of  emission  limits.  These  new 
technologies require more space, which is generally not available on NTTs, or could result 
in  an  increase  in  the  vehicle  size  leading  to  a  loss  in  manoeuvrability.  This  would  make 
these tractors unsuitable to use in the cultivations for which they are designed.  

Further research and technological development is required in order to ensure that narrow-
track tractors complying with the Stage IIIB and later the Stage IV emission limits can be 
placed on the market.  

2.5.2.  Lack of technical feasibility  

The  emission  requirements  of  Stage  IIIB  and  IV  would  not  be  problematic  for  NTTs  if 
satisfactory  technological  solutions  were  available  in  the  appropriate  timeframe.  An 
important  part  of  the  current  analysis  has  been  concentrating  on  an  assessment  of  recent 
technological developments for engines used in NTTs. The state of the art of technology 
has a large influence on the outcome of this impact assessment and therefore it is explored 
in detail in this section.  

In 2008, the technical feasibility for NTTs of meeting the emission requirements of stage 
IIIB was assessed in detail in the report of DG JRC (see Annex VIII), which considered a 
5-year necessary to  allow  the  development of IIIB-compliant NTTs. Subsequently, some 
new technical developments have taken place, which are taken into account as well. These 
have lead to a downward adjustment of the extent of required technical development. 

Development  for  engine  technologies  to  meet  Stage  IIIB  and  IV  is  still  ongoing.  If  the 
implementation  dates  are  maintained,  engine  adaptation  and  integration  in  the  vehicles 
needs to start on current state-of-the-art technology. In that case, there seems to be general 
agreement among the relevant experts on the following points: 

–  Stage  IIIB  will  require  electronically  controlled  engines  with  high-pressure  fuel 

injection systems; 

–  For some engine power categories exhaust gas after treatment may not be required to 
comply with the Stage IIIB limits whilst for others one of the following may be needed:  

•  either  the  fitment  of  cooled  exhaust  gas  recirculation  (EGR)  and  diesel 

particulate filters (DPF) or  

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•  selective catalytic reduction (SCR) technology.  

–  The first technology is the most likely to be implemented for NTTs. 

–  Stage IV will need the simultaneous adoption of both the above mentioned technologies 

which may however be combined into a single after treatment system. 

The installation implications can be summarised as: 

–  Increased cooling capacity of the engine due to the cooled EGR estimated between 15 
and  25%  of  present  requirements  and  equivalent  increase  of  the  cooling  radiator 
volume; 

–  Installing a DPF with a ca. 20 dm3 volume; 

–  Installing an SCR system with a ca. 25 dm3 volume. 

As described in detail in the JRC report, these implications are incompatible with the space 
constraints  created  by  the  user  requirements  to  operate  in  vineyards  and  orchards.  The 
severity of these constraints can be illustrated by the fact that already today several NTTs, 
in  addition  to  the  main  fuel  tank,  are  equipped  with  small  secondary  fuel  tanks,  fitted 
wherever space is available under the hood. Also, larger engine compartments may require 
farmers  to  replace  their  implements  (tools  mountable  on  the  engine  and  tractor  for 
performing specific agricultural operations) and/or damage the fruits by exposing them to 
heated surfaces. 

NTTs  operate  as  mobile  power  sources  for  a  wide  range  of  implements,  which  are  tools 
mounted on the engine of the tractor necessary to perform different operations in vineyards 
and  orchards.  As  mentioned  before,  these  are  often  located  in  mountainous  areas,  which 
also  pose  a  certain  demand  on  engine  power.  Over  time  the  power  demand  increased  to 
achieve an indicative upper limit of 75 kW. The chosen engine power of a NTT is essential 
to meet its customer requirements. Therefore, replacement of higher power NTTs by those 
with  an  engine  of  a  lower  power  category,  which  are  not  subject  to  the  next  emission 
stages, would not be a acceptable solution for NTT users. 

In the course of 2010, new technical developments have been communicated by the engine 
and  after-treatment  supplying  industry.  A  few  engine  concepts  have  been  presented  that 
are capable of meeting stage IIIB requirements without the use of a DPF. However, these 
engines  were  designed  primarily  for  the  use  in  machinery  and  the  adaptation  to  tractors, 
particularly  to  NTTs,  remains  to  be  proven.  Without  DPF,  the  space  implications  for 
integrating  the  new  engine  concept  in  the  current  engine  compartments  are  mitigated. 
Also,  after-treatment  technology  has  recently  demonstrated  a  progress:  specific  concepts 
have  been  developed  that  offer  better  potential  for  integrating  this  technology  within  the 
space constraints of NTTs. It has to be stressed, however, that neither of these technologies 
is sufficiently developed at the time of the present assessment to enable NTTs meeting the 
Stage IIIB limits within the current legal timeframe. 

For  Stage  IV-compliant  technology,  which  would  be  compatible  with  NTT-needs,  no 
technical solution is for the moment demonstrated, even as a R&D concept. Even if Stage 
IV technology is likely to rely on the use of both sophisticated engine measures, such as 

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high-pressure fuel injection and cooled EGR, as well as both DPF and SCR after-treatment 
technology (potentially combined) as explained above, engine and after-treatment system 
manufacturers will have to develop the technology further to propose a system that meets 
the  limit  values.  With  regard  to  the  installation  in  NTTs,  Stage  IV  compliant  engines 
would face even bigger challenges, given the need for large after-treatment systems.  

In conclusion, the current state of technological development of engine and after-treatment 
technologies  is  considered  such  that  stage  IIIB-compliant  technology  could  be  available 
for NTTs once the recent prototypes for other applications have been adapted to fit NTT-
needs, integrated and tested in the vehicle. This process, according to standard industrial 
leadtimes (see Annex VI), will take between 3 and 6 years. Although the industry stated 
that  significant  R&D  investments  have  been  made  in  the  past  years,  the  probability  that 
some  manufacturers  may  be  ready  before  3  years  is  considered  low.  For  Stage  IV-
compliant technology, the fitment of after-treatment systems will be needed and NTTs are 
likely to face difficulties integrating this equipment. If technical solutions are found, it is 
very  likely  that  it  will  take  a  full  development  cycle  of  6  to  10  years  before  acceptable 
Stage IV-compliant NTTs can be put on the market. 

2.6. 

Affected parties 

The  things  as  they  currently  stand  affect  both  the  European  manufacturers  of  NTTs  and 
farmers who rely on the use of NTTs. While the former are left with neither sufficient time 
nor  sufficient  technological  development  to  adapt  their  products  to  the  new  emission 
limits,  the  latter  are  left  with  no  modern  mechanisation  tools  needed  in  the  European 
specialized agriculture.  

2.7. 

Subsidiarity and proportionality 

The  legal  basis  of  this  initiative  is  the  same  as  for  the  tractors  emissions  Directive 
2000/25/EC, namely Article 114 of the TFEU on the approximation of laws. 

The  Directive  already  harmonises  the  laws  of  the  Member  States  relating  to  emission 
limits  and  the  type-approval  procedure  for  engines  to  be  installed  in  tractors.  Any 
modifications  to  the  Directive  can  only  be  done  at  EU  level.  Therefore  EU  action  is 
justified and provides added value in maintaining the internal market for tractors. 

In terms of proportionality, a close review of the impacts of legislation is important in this 
case.  There  is  a  rather  small  and  geographically  concentrated  market  for  NTTs,  which 
potentially has to cope with prohibitive compliance burden or severe technical challenges 
to adapt to new legal limits.  

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3.  OBJECTIVES 

3.1. 

Definition of objectives 

The objectives are mainly twofold: competitiveness and environment related. The general, 
specific and operational objectives are set out in the table below. 

GENERAL 

SPECIFIC 

OPERATIONAL 

1. To safeguard 
the 
competitiveness 
and viability of 
the tractor 
industry. 

1. To enable industry to 
continue investing in R&D so 
that technology becomes 
available for all NTTs to meet 
Stage IIIB and Stage IV. 

2. To maintain a 
high level of 
environmental 
protection. 

1. To limit the overall 
emissions of the NTT tractor 
fleet by enabling fleet 
renewal. 

1. To introduce a cost effective and 
timely measure that allows engine and 
tractor producers to continue selling 
new NTTs. 

2. To allow industry to finance 
expenditure on R&D in the short term 
to develop innovative tractors by 
allowing them to continue to generate 
revenues from sales. 

1.  To  enable  the  replacing  of  older, 
more  polluting  and  fuel  consuming 
engines  and  tractors  by  cleaner  ones 
by  setting  emission  requirements  in 
such  a  way  that  demand  for  new 
tractors  can  be  met  by  the  cleanest 
available models.  

2.  To  send  a  clear  signal  to  industry 
that  further  emission  reductions  are 
required  and  that  the  current  path  of 
reducing emissions is maintained. 

3.2. 

Consistency with other horizontal objectives of the European Union 

3.2.1.  The European Economic Recovery Plan 

The  present  proposal  is  in  line  with  the  objectives  of  the  EU  2020  Strategy22  and 
complements  the  European  Economic  Recovery  Plan  (EERP)23.  Adopted  in  November 
2008,  the  EERP  addresses  the  difficulties  of  the  wider  economy  brought  about  by  the 
global financial crisis. The Plan outlines a series of measures to cope with the squeeze on 
credit, declining sales and revenues. It refers inter alia to the need for a swift stimulation of 
demand  and  consumer  confidence  as  well  as  measures  to  lessen  the  human  cost  of  the 

22 
23 

COM(2010) 2020 
COM (2008) 800 

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economic  downturn and its impact  on jobs. The EERP highlights the need to ensure full 
coherence between immediate actions and the EU’s medium- and longer term objectives.  

Such  immediate  action  needs  to  focus  on  improving  business  conditions  through 
maintaining the competitive industrial base and through promoting a knowledge based and 
low carbon economy as set out in the EU2020 Strategy. 

3.2.2.  Environmental Policies 

The  tractors  emissions  Directive,  which  provides  an  important  contribution  to  a 
progressive reduction of air pollution, is also in line with the EU environmental policies, in 
particular  with  the  Sixth  European  Environment  Action  Programme  and  one  of  its 
initiatives  –  the  Clean  Air  For  Europe  (CAFE)  strategy.  The  initiative  sets  out  an 
integrated  and  long  term  strategy  for  reducing  the  adverse  impact  of  air  pollution  on 
human  health  and  environment.  These  objectives  are  implemented  through  Directive 
2008/50/EC24 on ambient air quality and cleaner air for Europe which establishes a system 
for  the  assessment  of  ambient  air  quality  and  provides  thresholds  for  each  pollutant. 
Member States have to assess and manage the ambient air quality. Besides this instrument 
it  remains  important  to  combat  emissions  of  pollutants  at  source  and  to  implement  the 
most effective emission reduction measures. 

Today, a large number of Member States are in non-compliance with the air quality limit 
values for PM10 which entered into force in 2005 but where extra time has been granted for 
some  air  quality  management  zones  until  June  2011.  Many  Member  States  are  also 
expected not to comply with the air quality limit values for nitrogen dioxide when official 
monitoring data is reported in 2011. One of the reasons most frequently cited by Member 
States for their non-compliance with PM10 air quality limits is the substantial contribution 
made to observed levels from transboundary air pollution. In this respect, it is important to 
note  that  more  than  10  Member  States  are  expected  not  to  comply  with  their  national 
emission  ceilings  for  NOx  (under  the  Directive  2001/81/EC)  that  are  binding  from  2010 
onwards based on their emissions forecasts so far submitted to the Commission25. 

It  is  broadly  recognised  that  these  problems,  as  far  as  they  are  related  to  vehicles,  are 
largely caused by the emissions from the existing fleets, which are still composed of many 
old  vehicles.  Current  actions  therefore  focus  on  measures  stimulating  fleet  renewal  and 
retrofitting. 

24 

25 

Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and cleaner air 
for Europe (AAQD) entered into force on 11 June 2008. It merges existing legislation into a single directive with no change 
to existing air quality objectives for PM10 and NOx contained in Directive 1999/30/EC; maintains two limit values for NOx 
based on hourly and annual average concentrations; sets (new) air quality objectives for PM2.5 including the limit value and 
exposure related objectives – exposure concentration obligation and exposure reduction target; creates the possibility for time 
extensions for compliance up until June 2011 for PM10 (where the limit values entered into force on 1 January 2005) or up 
until 31 December 2014 for NO2 and benzene) based on conditions and the assessment by the European Commission. Single 
most important condition is that the notification  must include an air quality plan that delivers compliance by the extended 
deadline for compliance. 
http://www.eea.europa.eu/publications/nec-directive-status-report-2008  

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4.  POLICY OPTIONS 

4.1. 

Options identified 

Six policy options have been identified as possible means of meeting the policy objectives 
described in the previous section. These are: 

•  Option 1- No new action = Baseline scenario.  

The current implementation dates for NTTs, to achieve compliance with the new 
Stage IIIB and Stage IV limits remain unchanged, meaning that Stage IIIB would 
be  required  for  new  NTTs  starting  from  1  January  2012  and  Stage  IV  from  1 
October 2014.  

•  Option  2  –  Allowing  3  extra  years  for  implementation  of  Stages  IIIB  and  IV  for 

NTTs. 

The implementation dates for NTTs for meeting Stage IIIB and Stage IV emission 
requirements would be delayed by 3 years. Stage IIIB would be required for new 
NTTs starting from 1 January 2015 and Stage IV from 1 October 2017. 

•  Option  3  –  Allowing  5  extra  years  for  implementation  of  Stages  IIIB  and  IV  for 

NTTs. 

The implementation dates for NTTs for meeting Stage IIIB and Stage IV emission 
requirements would be delayed by 5 years. Stage IIIB would be required for new 
NTTs starting from 1 January 2017 and Stage IV from 1 October 2019. 

•  Option 4 – Exempting NTTs from Stages IIIB and IV for NTTs.  

Given  the  specific  design  constraints  of  NTTs  and  their  limited  market  share 
compared to the entire tractor market, an additional option could be to completely 
exempt  NTTs  from  Stages  IIIB  and  IV  requirements.  This  would  maintain  the 
current Stage IIIA requirements for these special tractors for an unlimited period 
of time.  

•  Option  5  –  Skipping  Stage  IIIB  and  introducing  Stage  IV  at  the  dates  originally 

foreseen 

This option foresees skipping Stage IIIB and introducing Stage IV emission limits 
at  the  dates  originally  foreseen  in  the  tractors  emissions  legislation  i.e.  as  of  1 
October 2014. 

•  Option 6 – Extending the flexibility provisions for NTTs  

This option foresees a further extension of the flexibility provisions in the Tractor 
Emissions Directive for NTTs, so as to allow them to sell an additional number of 
non-compliant tractors without changing the emission requirements as such. 

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4.2. 

Options discarded at an early stage 

•  Option 5:  

Some companies may find it beneficial to focus directly on solutions capable of meeting 
Stage  IV  and  would  therefore  avoid  investing  resources  in  developing  an  intermediate 
solution. However, as shown in Annex III, Stage IV will not apply to the power category 
between  37  and  56kW.  This  option  would  therefore  only  be  applicable  to  the  power 
category between 56 and 75 kW.  

Furthermore, the JRC study highlighted that the technical solution to meet Stage IV would 
imply  an  improved  engine  and  extensive  after-treatment  systems  to  reduce  both  PM  and 
NOx  emissions.  Stage  IV  solutions  will  largely  build  on  Stage  IIIB  compliant-
technologies,  and  therefore  the  two  stages  are  mutually  complementary.  In  terms  of 
technical feasibility, manufacturers will face the same design and installation problems as 
encountered  with  Stage  IIIB.  The  state  of  the  art  of  technology,  as  discussed  in  section 
2.5.1, is in such a premature stage that the possibility for NTTs to meet Stage IV in 2014 
can be excluded with near certainty. Even if this option would avoid the negative impacts 
on  the  sector  and  the  environment  between  2012  and  2014,  damages  of  a  similar  nature 
(impossibility to sell compliant NTTs, loss of revenues, continued use of old tractors) can 
be expected as of 2014, probably in an even larger extent. This is because vehicle design 
(as  demonstrated  in  Annex  VI)  will  take  much  longer  than  the  time  available  until  the 
mandatory introduction of Stage IV foreseen by the legislation and after-treatment seems 
unavoidable, creating particular difficulties for integration into NTTs. Moreover, it would 
mean a waste of resources for the companies that have invested in technical solutions for 
Stage  IIIB  (see  Annex  VII).  Therefore,  this  option  has  been  discarded,  since  it  will  not 
deliver on the defined policy objectives. 

•  Option 6:  

The  current  Tractor  Emissions  Directive  includes  flexibility  provisions  which  allow  a 
number of new tractors non-complying with the new emission stage to be sold in the year 
following the introduction of this stage. Currently this is limited to 20% of the number of 
sales in the previous year. The Commission adopted a proposal on 27 October 201026 to 
increase  the  flexibility  provisions  to  50%.  In  both  cases,  these  provisions  would  provide 
only limited relief to manufacturers, allowing them to continue sales for a period of a few 
months, which are far from sufficient to allow technical solutions to be developed in time 
(see section 2.5.2). 

In  order  to  bring  the  flexibility  for  NTTs  more  in  line  with  the  leadtime  needed  for 
developing  compliant  NTTs,  one  could  imagine  a  further  extension  of  the  flexibility 
provisions, specifically for NTTs. In that case, the flexibility provisions would need to be 
around  300%.  In  practice,  such  an  option  would  represent  a  delay  of  3  years  in  the 
application  of  the  new  emissions  Stages,  very  similar  to  Option  2.  However,  the 
administrative  burden  for  manufacturers  and  administrations  to  implement  the  flexibility 
scheme would be significantly higher. For that reason, this option was discarded. 

26 

COM(2010) 607 final 

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5.  ANALYSIS OF IMPACTS 

As this IA concerns a 'narrow' legislative action, it will assess the options essentially in a 
qualitative  way  with  quantifications  for  those  impacts  for  which  sufficient  data  was 
available. The options will be analysed with respect to the economic, environmental and 
social  aspects.  The  economic  impacts  considered  include  the  direct  impact  of  sales  and 
revenues on industry, including many SMEs, the indirect impact on users of increased cost 
and price, or unavailability of NTTs and the impact on R&D investments, their expected 
returns  and  innovation.  The  environmental  impacts  considered  include  the  emissions  of 
PM and NOx and the corresponding cost estimates. The social impacts considered include 
employment and the safety of workers related to the use of different types of tractors. For 
the latter, it is important to note that all new tractors entered into service after July 2009 
are  legally  required  to  be  equipped,  among  other  safety-related  measures,  with  roll-over 
protection, which is particularly relevant for the safety of workers using NTTs.  

The  assessment  is  based  on  the  data  available  from  different  sources,  including  the  JRC 
and Arcadis studies and the industry itself (in particular engine, after-treatment and tractor 
manufacturers),  who  delivered  information  on  R&D  results  and  the  state  of  the  art  of 
technology related to the introduction of the new stages for NTTs. Additional information 
on the R&D budget for the sector was obtained from EUROSTAT.  Some of  the  factors, 
which are impossible to quantify due to lack of detailed information from the industry, and 
therefore are not taken into account in the analysis include: increased learning & training 
costs;  reduced  availability  of  manpower;  increased  stock  piling;  reduced  availability  of 
low  volume  products;  standstill  state  of  the  art;  increased  peak  load  for  certification 
bodies;  increased  warranty  cost  due  to  rush  released  tractors  and  the  health  impacts  of 
workers using NTTs due to the direct exposure to pollutants. Nonetheless, the magnitude 
of these factors is not likely to affect the overall conclusions of the assessment. 

5.1. 

Impacts of Option 1 (no new action)  

Option 1 can evolve in two directions for which two different scenarios can be foreseen:  

–  Scenario 1a: adapting compliant NTTs to current customer requirements 

Emission  requirements  remain  unchanged,  NTT  manufacturers  are  not  able  to  offer 
compliant NTTs once the new limits are required (beyond limited flexibility provisions). 
The  surviving  companies  will  re-enter  the  market  once  a  technical  solution  is  found 
permitting NTTs to be used in existing vineyards and orchards. 

–  Scenario 1b: Redesigning vineyards and orchards to fit NTTs of a bigger size 

Emission  requirements  remain  unchanged,  compliant  NTTs  could  become  available 
although of different sizes than those currently used by the agricultural sector. As a form 
of  self-help,  the  agricultural  sector  redesigns  the  existing  vineyards  and  orchards  to  fit 
wider or longer tractors. 

Scenario 1b has been investigated in the Arcadis Report (in section 3.6.4.2) and the JRC 
report (in section 5.3.2) and was considered not plausible, due to the associated high costs 

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that  would  need  to  be  incurred  by  the  agricultural  sector  and  for  other  reasons  stated 
below: 

Vineyards  and  orchards  were  already  restructured  some  10-15  years  ago  following  the 
adoption  of  the  Council  Regulation  No  1493/1999  on  the  common  organization  of  the 
wine  market27.  As  a  consequence,  the  row  width  increased  from  narrow  row  widths  of 
about 1m to larger row widths of about 2m. One reason was the possibility to switch from 
manual cultivation to techniques assisted by special tractors. Substantial EU-resources (the 
SME  Test  report  mentions  400-465  M€  annually  over  a  period  of  seven  years)  from  the 
Common Agricultural Policy were spent for this purpose, in addition to private and other 
expenses. This shows the extent of the necessary investments and, given the fact that the 
average life cycle of a vineyard is forty years, it would evidently be an enormous waste of 
resources if farmers would have to replant vineyards again. 

Further, the JRC report has estimated that redesigned vineyards (either by increasing the 
row  width  or  reducing  the  row  length  so  that  larger  tractors  can  turn)  would  result  in  a 
20%  loss  of  cultivable  grounds.  This  would  obviously  be  a  heavy  blow  to  the  relevant 
economic actors and to the competitiveness of the EU wine sector; especially to the part 
producing  high  quality  wines  that  already  faces  strong  space  limitations  and  makes 
widespread use of NTTs.  

As scenario 1b is highly unlikely, the analysis of option 1 is based on scenario 1a. This has 
been investigated in detail in the Arcadis study (see Annex IX) and the analysis below is 
largely based on the conclusions of this study. 

5.1.1.  Economic impact of Option 1 

As  explained  in  the  section  2.5.2,  the  technological  development  of  engine  and  after-
treatment technology is not likely to deliver acceptable solutions in time for NTTs to meet 
the Stage IIIB and Stage IV limits by the dates currently prescribed by the Directive.  

In  that  case,  NTT  manufacturers  would  not  be  able  to  comply  with  existing  deadlines, 
would  continue  to  struggle  with  technical  problems  and  would  not  have  tractors  ready, 
neither  for  Stage  IIIB  nor  for  Stage  IV,  until  a  technical  solution  is  found.  At  the  same 
time,  since  the  sale  of  NTTs  not  complying  with  Stage  IIIB  will  not  be  allowed  as  of 
January  2012,  industry  would  not  be  able  to  place  products  on  the  market  beyond  the 
limited  volumes  offered  with  the  sell  off  and  flexibility  provisionsSeveral  firms  –  in 
particular  SMEs  which  are  specialised  in  NTTs  and  can  hardly  benefit  from  revenues  in 
other tractor segments, run a significant risk of going out of business. Following standard 
economic  theory,  a  reduced  number  of  firms  will  also  lead  to  less  competition,  lower 
product diversity and probably higher prices, thus lower consumer welfare. 

27 

Under  the  Council  Regulation  (EC)  No  1493/1999  on  the  common  organisation  of  the  market  in 
wine, Member States can obtain annual payments for restructuring and conversion of a set number 
of  hectares  of  vineyards.  The  objective  of  this  system  is  the  adaptation  of  production  to  market 
demand.  It  covers  the  following  measures:  varietal  conversion,  relocation  of  vineyards  and 
improvements to vineyard management techniques. The system does not cover the normal renewal 
of vineyards which have come to the end of their natural life. As consequence of the restructuring of 
vineyards, the row width has changed from about 1 meter to 1,6 - 2,2 meter. NTT are designed to 
work in this situation. For more detail see the JRC report in Annex VIII. 

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Clients  of  tractor  manufacturers  will  be  faced with  a  disruption  of  a  satisfactory  product 
offer. Wider or longer NTTs compliant with Stage IIIB may be offered, but would in the 
best case only be bought by a small number of farmers (for example those who can accept 
a lower yield of their cultivable land). The large majority of users, if not all, will maintain 
existing tractors (for which the purchase costs have already been amortised) in operation 
until a technical solution is found. That would mean that they will not be able to purchase 
newer, safer, less fuel-consuming tractors that can work more efficiently, even though this 
decision brings higher operating costs. These are estimated at 1339 M€28. 

In terms of R&D investment and innovation, this option has some benefit. It could indeed 
reward  the  companies  that  are  the  quickest  to  offer  Stage  IIIB-compliant  NTTs  with  a 
quasi-monopoly,  according  to  the  'winner  takes  it  all'  principle.  It  remains  very  doubtful 
whether  this  would  avoid  an  interruption  of  NTT  supply.  It  would  certainly  create 
casualties as several smaller firms will not have the capital resources to engage in such an 
excessive innovation race, in the absence of revenue from sales, and are likely to risk their 
business. In the long term, a reduced number of firms and product diversity would have a 
negative impact on innovation. 

The impacts for applying Stage IV without any delay as of October 2014 would be of a 
similar  nature  as  for  Stage  IIIB  (impossibility  to  sell  compliant  NTTs,  loss  of  revenues, 
continued use of old tractors). However, given the lack of demonstrated technical solutions 
and the certainty that they will require after-treatment, the problems for the sector can be 
expected to be even larger than for Stage IIIB. Also in terms of innovation, impacts would 
be  similar,  leading  to  an  excessive  innovation  race,  with  a  small  number  of  winners  and 
many casualties. Based on information currently available, it is considered highly unlikely 
that any company would be capable of developing Stage IV compliant NTTs in time. 

5.1.2.  Environmental impact of Option 1  

Due to unavailability of compliant NTTs, at least for a number of years after the emission 
limits  will  enter  into  force,  i.e  2012,  the  emissions  of  pollutants  cannot  achieve  the 
reductions  that  could  have  been  expected  from  the  Tractor  Emissions  Directive.  The 
expected reductions from stricter limits form therefore a hypothetical scenario, which has 
nevertheless been chosen as the benchmark for quantifying and comparing the emissions 
under  different  scenarios  in  the  JRC  and  Arcadis  studies.  It  will  be  referred  to  as 
'hypothetical scenario' in the graphs in this report. The environmental impacts have been 
determined  based  on  external  costs  of  calculated  emissions.  Emissions  have  been 
calculated  taking  into  account  tractor/engine  stocks,  average  use  and  the  lifetime  of 
tractors.  

The Arcadis study estimates that, under Option 1, PM emissions and NOx emission would 
be substantially higher than the hypothetical scenario (blue curve). This is illustrated in the 
two graphs below. The increase in emissions (yellow curve) is due to the continued use of 
the oldest tractors, whose emissions were not regulated at the time of entry into force or 
complied with the first sets of emission limits.  

28 

See SME Test Study, section 8.2.2 

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Figure 1: PM emissions of NTTs (time span 2005-2050) 

Source: Arcadis report 

Figure 2: NOx emissions of NTTs (time span 2005-2050) 

Hypothetical scenario 

Option 1 (baseline) 

Option 3 (5 year delay) 

Hypothetical scenario 

Option 1 (baseline) 

Option 3 (5 year delay) 

Source: Arcadis report 

The  estimated  increase29  in  emissions  compared  to  the  hypothetical  scenario  amounts  to 
4,3  kt  for  PM  and  62  kt  for  NOx  for  the  period  until  2050.  The  monetized  emission 
impacts  for  the  increased  PM  emissions  are  estimated  at  60  M€  and  those  for  NOx 
emissions  at  134  M€  over  the  2012-2030  timeframe.  As  this  option  reflects  the  baseline 
scenario,  the  above  figures  are  taken  as  the  reference  and  the  environmental  impacts 
indicated for the other policy options are relative to the baseline. 

It  should  however  be  noted  that  the  overall  impact  of  emissions  is  not  expected  to 
significantly  affect  the  Member  States  obligations  under  the  Directive  on  Ambient  Air 
Quality  and  Cleaner  Air  for  Europe,  which  requires  MS  to  meet  certain  ceilings  for 
ambient air quality in defined geographical areas30. Moreover, the emissions of NTTs are 
normally not generated near those geographical areas in the EU that experience the most 
problems  with  meeting  the  air  quality  targets  and  associated  implications  for  human 

29
30 

See Annex XII for more details 
Directive 2008/50/EC L 152 11.6.2008 p1, Annex III 

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health. Figure 3 illustrates the geographical distribution of health impacts associated with 
PM emissions in Europe. One exception may be Northern Italy, where vineyards and air 
quality problems coincide.  

Figure 3: Loss in life expectancy attributable to anthropogenic PM2.5 in 200031 

5.1.3. 

Social impact of Option 1 

As mentioned in the Arcadis study, the prolonged disruption (of several years) of revenue 
represents  a  serious  risk  for  all  NTT  manufacturers,  many  of  which  are  SMEs  or  other 
small businesses. The estimated number of jobs32 that could be lost would correspond to 
3000 for around  three  years.  The  application of Stage IV (for NTT corresponding  to the 
larger engine power category) would perpetuate the majority of these losses. The expected 
job losses would be concentrated in Germany, France and Italy. The larger companies may 
be able to survive thanks to their activities in other (tractor) markets and could re-enter the 
NTT  market  (for  the  lower  engine  power  category,  not  subject  to  Stage  IV)  when 
satisfactory technical solutions have been found, presumably after 3 years. 

As  was  already  explained  above,  the  non-availability  of  new  NTTs  will  lead  to  the 
continued use of old tractors, which are not equipped with modern safety devices such as 
roll-over protection. This risk should not be underestimated as the NTTs, due to their high 
centre  of  gravity  and  the  fact  that  they  are  employed  frequently  in  mountainous  regions, 
are  prone  to  these  types  of  accidents.  It  can  be  estimated  that  around  80.000  workers, 
active in agricultural cultivation, will be exposed to higher safety risks, at least for the 3 
coming years. 

Option 1 (no new EU action) represents a serious risk of disrupting the NTT industry 
and market, as industry would not have compliant tractors ready for Stage IIIB, nor 
for  Stage  IV.  Users  will  not  be  able  to  replace  old  polluting  tractors  with  modern 
equipment  and  are  likely  to  continue  to  use  old  tractors  with  high  pollution  and 
deteriorated  worker  safety.  Some  compliant  tractors  (in  the  lower  engine  category) 
may  come  some  years  later  to  the  market,  but  the  prolonged  loss  of  revenue  from 

31 
32 

Impact Assessment of the Thematic Strategy on Air Pollution, SEC(2005)1133, 21.09.2005, p. 32 
See Arcadis study, section 3.6.4.2 

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NTT  could  lead  several  manufacturers  to  close  business,  resulting  in  a  significant 
proportion  of  jobs  lost  in  the  sector.  Stakeholders  (mainly  from  industry)  have  for 
many years criticised this option and warned against its negative consequences. 

5.2. 

Impacts of Option 2 (Allowing 3 extra years)  

Unlike Option 3, this Option was not investigated in detail in the Arcadis study. Therefore, 
the analysis of the present option had to be performed by adapting the analysis of Option 
333.  Option  2  foresees  a  Stage  IIIB  implementation  delay  for  NTTs  shorter  by  2  years 
compared  to  Option  3.  The  shorter  delay  takes  into  account  technological  solutions  that 
have been developed over the past years.  

5.2.1.  Economic impact of Option 2 

As  already  recalled  above,  at  this  moment  the  available  engine  and  after-treatment 
technology  is  not  mature  enough  to  allow  industry  to  build  this  into  NTTs  and  comply 
with Stage IIIB requirements. The specificities of these vehicles (very narrow design, all 
hot  components  under  the  engine  hood,  short  turning  circles  required,  inherent  risk  of 
instability)  asks  for  further  development  of  technology:  smaller  components,  smaller 
engines still  suitable  for this purpose. The additional 3  years can be expected  to help  all 
related  industries  (vehicle,  engine  and  after-  treatment  manufacturers)  to  solve  these 
issues. 

The compliance costs for tractor manufacturers to cope with the new emission limits are 
nevertheless  significant.  These  costs  include  for  example:  costs  for  research  and 
development, equipment redesign, after treatment devices, investment, documentation and 
labelling,  etc.  In  order  to  recover  those  investments,  the  price  of  NTTs  will  have  to 
increase. This is particularly challenging for NTTs in the engine power range of 56-75 kW 
as they only have less than three years before Stage IIIB tractors have to be replaced by 
Stage IV. The increase in price is estimated at 15% (according to industry sources). Above 
the  normal  expenses  projected  for  NTT  replacement,  this  would  amount  to  additional 
equipment expenses for the users of NTTs of 117 M€ per year, starting in 2015. It can be 
expected that these costs will decrease over time thanks to learning effects, economies of 
scale and product optimisation. Moreover, and contrary to the situation for manufacturers 
of other categories of tractors and all other aspects being equal, for NTT the cost increases 
are less of a problem compared to the availability of viable technologies, as these tractors 
already  adopted  sophisticated  and  expensive  solutions  and  are  priced  well  above  the 
equivalent conventional tractor. 

Manufacturers estimate that they would have to increase their R&D spending from 3% to 
more than 6% of turnover over the coming 4 years in order to meet Stage IIIB as of 2015. 
Total R&D investment from NTT manufacturers is therefore expected to be around 50 M€. 
These  costs  include  the  homologation,  which  is  perceived  as  time  consuming  and 

33 

The estimation was obtained by assuming a proportionate relationship between the calculated emissions and the length of the 
delay. A similar approach was used for the monetized emission impacts. 

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24 

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particularly burdensome for small companies (see the SME test report in Annex X). They 
do not include the necessary investments by engine manufacturers and system suppliers. 

This  option  seems  to  foster  innovation  in  a  healthy  way.  It  would  provide  sufficient 
leadtime to those companies that have invested early in R&D to be able to develop Stage 
IIIB-compliant  solutions  in  time  and  get  a  fair  return  on  investment,  compared  to 
competitors that have invested later.  

Also  for  Stage  IV,  the  delay  can  be  expected  to  provide  sufficient  time  to  develop 
compliant  NTTs,  if  technical  solutions  can  be  demonstrated  in  the  near  future.  It  would 
provide an immediate boost for R&D investments as prototype solutions need to be found 
rapidly in order to be able to put compliant NTTs on the market by the new deadline. 

5.2.2.  Environmental impact of Option 2  

Before  Stage  IIIB  would  be  applied,  industry  would  in  the  meantime  still  be  allowed  to 
place on the market Stage IIIA compliant tractors that would in turn replace older, more 
polluting ones still in use. Simulations of emissions under this option were unfortunately 
not performed in the Arcadis and JRC studies, but can be estimated by adapting the results 
provided for Option 3. In the Figure 1 and Figure 2 on PM and NOx emissions (on pages 
21-22),  under  option  2  the  curve  would  follow  the  one  for  option  3  until  2015  when  it 
would  tend  towards  the  line  for  the  hypothetical  scenario.  Emissions  compared  to  the 
baseline scenario are estimated by adapting the JRC results for Option 3 (see Annex XII). 
They would amount to a reduction in emissions of 2.2 kt (-5.2%) and 42kt (4.1%) for PM 
and NOx respectively until 2050. 

The monetized emission impacts for the reduced PM emissions can again be estimated by 
adapting the results for Option 3 from the Arcadis study. This would result in a benefit of 
31 M€ and would set those for NOx emissions at 91 M€. The total environmental benefits 
can thus be estimated at 122 M€ compared to the baseline scenario.  

5.2.3. 

Social impact of Option 2 

It is expected that, with the three additional years, the majority of manufacturers can adapt 
their NTTs to meet Stage IIIB while satisfying the essential user requirements. Therefore, 
the  social  impacts  of  this  option  on  the  industry  are  not  very  significant.  It  cannot  be 
excluded  that  a  small  number  of  firms  are  not  capable  of  adapting  to  the  new  more 
advanced  technology,  leading  to  some  job  losses.  It  is  likely,  however,  that  these  losses 
will  be  compensated  by  additional  jobs  with  stronger  competitors.  Compared  to  the 
baseline  scenario,  there  would  be  a  significant  improvement  in  worker  safety.  As 
mentioned  before,  customers  will  be  able,  during  the  3  year  delay,  to  replace  old  NTTs 
with new (Stage IIIA-compliant) tractors. As there is no difference in safety requirements 
for  NTTs  complying  with  Stage  IIIA  and  Stage  IIIB,  the  improvement  of  worker  safety 
will be safeguarded under this option. 

Option 2, by allowing NTTs three extra years to comply, would be very effective in 
mitigating  the  economic  impacts  on  the  industry  to  challenging  but  feasible 
proportion,  without  serious  social  drawbacks.  Also,  the  environmental  impacts  are 

EN 

25 

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improved  due  to  the  fact  that,  while  Stage  IIIB  NTTs  are  not  available,  new  Stage 
IIIA NTTs will be able to reduce pollutant emissions, compared to the old NTTs that 
they will replace. Industry would, however, remain under continuous pressure to find 
technical  solutions  to  meet  the  new  emission  limits  introduced  by  the  Directive,  so 
innovation is fostered. Some industrial companies have indicated  that  this might  be 
feasible, while others think it is not. 

5.3. 

Impacts of Option 3 (Allowing 5 extra years)  

5.3.1.  Economic impacts of Option 3 

This Option has been investigated in detail in the Arcadis study (see Annex IX) and this 
analysis is largely based on its conclusions. The analysis is similar to the one for Option 2. 
Therefore, the remarks here will focus on the differences compared to Option 2. 

With  an  additional  period  of  5  years,  all  relevant  industrial  actors  should  have  sufficient 
time  to  develop  technical  solutions  for  NTTs  to  meet  Stage  IIIB  emission  requirements. 
The  additional  two  years  compared  to  Option  2  may  be  needed  if  the  initial  technical 
developments for machinery engines discussed in Section 2.5.2 do not progress as quickly 
as expected into suitable solutions for NTTs.  

The compliance costs can be expected to be somewhat lower than under option 2, as the 
technology  has  more  time  to  improve  and  progress  along  the  'learning  curve'.  Price 
increases  for  customers  could  amount  to  around  13%  initially,  leading  to  additional 
expenses of around 100 M€ per year initially. Again, these costs are likely to be reduced 
over time. 

In terms of innovation, there may be a drawback for this option. The industrial actors that 
invested to develop Stage IIIB solutions as quickly as possible may be able to offer NTTs 
complying with Stage IIIB even before the implementation dates. In the absence of fiscal 
incentives,  these  products  would  be  put  at  a  competitive  disadvantage  due  to  the  higher 
price  compared  to  IIIA-compliant  NTTs.  Forward  looking  business  decisions  and 
investments  in  innovation  may  therefore  not  be  rewarded.  In  terms  of  legal  certainty,  it 
could also be considered a perverse incentive if economic actors that did not prepare for 
meeting Stage IIIB in the past years, will now benefit from an opportunity to catch up with 
competitors. 

Also  for  Stage  IV,  the  5-year  delay  gives  more  leeway  to  industry  to  develop  compliant 
NTTs, even if technical solutions are not demonstrated in the near future. It would provide 
only  a  moderate  boost  for  R&D  investments  as  more  time  is  available  for  finding 
prototype solutions to be able to put compliant NTTs on the market by the new deadline. 
Some investments could in fact be delayed. 

5.3.2.  Environmental impact of Option 3 

Before  Stage  IIIB  would  be  applied,  industry  would  in  the  meantime  still  be  allowed  to 
place on the market Stage IIIA compliant tractors that would in turn replace older, more 
polluting ones still in use. Simulations of emissions under this option were performed in 
the  Arcadis  and  JRC  studies,  The  pink  curve  in  the  figures  1  and  2  on  PM  and  NOx 

EN 

26 

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emissions (p. 21-22) shows the estimated emission under this option. Emissions reductions 
compared to the baseline scenario (yellow curve) are estimated (see Annex XII), based on 
the  results  of  the  JRC  study,  at  0.8  kt  (-1.9%)  and  29kt  (-2.9%)  for  PM  and  NOx 
respectively until 2050. 

The monetized emission impacts for the reduced PM emissions are estimated at a benefit 
of 12 M€ and those for NOx emissions at 62 M€. The total real environmental benefits can 
thus be estimated at 74 M€. These results include the effects of both Stage IIIB and Stage 
IV. 

5.3.3. 

Social impact of Option 3 

Compared to option 2, a difference is that companies that did not make early investments 
would  have  time  to  catch  up  with  their  competitors  before  the  new  limits  become 
mandatory.  Therefore,  the  risk  that  a  small  number  of  companies  will  not  be  capable  of 
transforming  to  adapt  to  the  new  market  situation  is  even  lower,  as  is  the  risk  for  job 
losses. 

As for option 2, there is an improvement in worker safety, brought about by the renewal of 
old NTT by newer models. 

Option  3,  allowing  NTTs  five  extra  years  to  comply,  would  be  very  effective  in 
avoiding  job  losses  in  the  sector.  However,  there  will  be  some  drawback  for 
environment  as  the  new  Stages  IIIB  requirements  will  not  be  effective  for  5  years. 
According to calculations this will nevertheless be better than option 1, where the old 
tractors  (instead  of  new  and  Stage  IIIA  compliant  ones)  will  continue  to  be  used. 
Industry  would  remain  under  pressure  to  find  technical  solutions  to  meet  the 
Directive.  It  may,  however,  question  somewhat  the  credibility  of  legislation,  if  it  is 
perceived  that  the  industry  did  not  try  to  meet  the  limits  in  time.  This  option 
corresponds to the current requests from NTT manufacturers. 

5.4. 

Impacts of Option 4 (Exemption)  

This Option has been investigated to some extent in the JRC study (see Annex VIII) and 
this analysis is largely based on its conclusions. 

5.4.1.  Economic impact of Option 4  

Under this option, the industry could continue to produce NTTs at the present Stage IIIA 
level of requirements, as is already the case for tractors with small engines (up to 37 kW). 
There would be no specific threat nor pressure for businesses to seek innovative solutions. 
Many companies will have done superfluous preparatory work on technical solutions that 
will not be required anymore.  

Customers  would  benefit  as  they  can  continue  to  replace  old  polluting  tractors  by 
relatively clean new tractors meeting Stage IIIA, but without having to pay the additional 
costs for Stage IIIB and IV. In terms of innovation, past investments made by economic 

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actors for meeting Stage IIIB would effectively be lost. There would also be no incentive 
to  develop  new  emission-reducing  technologies  in  the  future  for  meeting  Stage  IV 
requirements, so environmental innovation in this sector would come to a halt. In addition, 
it could again be considered a perverse incentive to 'reward' operators that did not prepare 
for meeting Stage IIIB and Stage IV in the past years. 

5.4.2.  Environmental impact of Option 4 

The JRC study estimated that emissions of PM per year would in the long term be 0.7 kt 
higher  than  under  the  reference  level.  That  would  amount  to  a  total  increase  in  PM 
emissions of around 22.7 kt until 2050, compared to the baseline scenario (see Annex XII 
for details). Similarly, NOx emissions per year would be increased by 6 kt per year. Until 
2050, this would give rise to a total of 168 kt of NOx emissions by NTTs. 

The monetization of the environmental impacts under this option was not carried out in the 
Arcadis  report.  They  would  logically  be  more  or  less  proportionate  to  the  increase  in 
emissions and can be estimated at an increase in environmental cost of 313 M€ for PM and 
361 M€ for NOx, compared to the baseline scenario. These results include the effects of 
exempting both Stage IIIB and Stage IV. 

5.4.3. 

Social impact of Option 4 

There  would  be  no  risk  that  companies  are  pushed  out  of  business  due  to  emissions 
requirements, as they would effectively stay as they are today. However, a small number 
of  jobs  related  to  R&D  in  the  tractor  manufacturer  and  exhaust  after-treatment  supplier 
sector  may  be  lost.  As  for  options  2  and  3,  there  is  an  improvement  in  worker  safety, 
brought about by the renewal of old NTT by newer models. 

A  permanent  exemption  does  effectively  mitigate  the  negative  impacts  for  industry 
but does not give any certainty that pollutant emissions are reduced in the long term, 
as it is far from certain that NTTs meeting Stage IIIB or IV would be developed. As 
other sources of PM and NOx are expected to reduce their emissions over time, the 
relative share of NTTs in those emissions will therefore increase. In the short term, 
however,  it  would  be  positive  for  environment  as  at  least  new  Stage  IIIA  tractors 
would  be  available  to  replace  older,  more  polluting  ones.  An  exemption  would  also 
largely  remove  any  incentive  to  invest  in  R&D  and  innovation  in  environmental 
technologies  for  NTTs.  Initially,  this  was  the  solution  requested  by  (industrial) 
stakeholders. More recently, they requested a 5-year delay. 

6.  COMPARISON OF THE OPTIONS 

The detailed assessment of economical, environmental and social impacts of the previous 
chapter are summarised in the following table34 for each of the policy options.  

34 

The  impact  of  the  baseline  scenario  has  for  methodological  reasons  been  set  to  zero.  The  symbols  for  the  other  options 
indicate the impact relative to the baseline scenario, ranging from very unfavourable (--) to very favourable (++) 

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Option 1 - 
Baseline 

Option 2 – 3 year 
delay 

Option 3 – 5 year 
delay 

Option 4 - 
exemption 

0 

+ 

+ 

+ 

Direct economic impact 
(on industry) 

No NTTs sold until 
technical solution is 
found, loss of revenue, 
serious risk of 
bankruptcies 

Most actors can stay in 
business, sales 
continue, sunk 
investments not lost 

All actors can stay in 
business and sales 
continue, sunk 
investment not lost 

No need to invest 
more, sales continue, 
loss of sunk 
investments 

Indirect economic 
impact (on consumers) 

0  

+ 

+ 

++ 

Cannot renew tools, 
higher maintenance 
costs 

Additional equipment 
cost of 117 M€ initially 
per year 

Additional equipment 
cost of +/- 100M€ 
initially per year 

No particular cost 
increases 

0 

++ 

+ 

-- 

Impact on R&D 

Wild race among some 
to innovate, without 
revenue to finance it 

R&D investment 
continued, allowing 
most to participate 

Early R&D investment 
not rewarded, allowing 
all to participate 

No incentive to 
innovate 

PM emissions35 

NOx emissions 

0 

++ 

+ 

-- 

Use of old, polluting 
tractors is prolonged 

Fleet renewal 
continued, reduction of 
2.2 kt, 31 M€ benefit

Fleet renewal 
continued, reduction of 
0.8 kt, 12 M€ benefit 

Long-term higher 
emissions of 22.7 kt, 
313 M€ cost 

0 

++ 

+ 

-- 

Use of old, polluting 
tractors is prolonged 

Fleet renewal 
continued, reduction of 
42 kt, 91 M€ benefit 

Fleet renewal 
continued, reduction of 
29 kt, 62 M€ benefit 

Long-term higher 
emissions of 168 kt, 
361 M€ cost 

0 

+ 

+ 

+ 

Impact on employment 

Serious risk for job 
losses, up to 3000 over 
3 years 

Job losses limited, not 
structural, some 
additional jobs at 
suppliers 

Job losses further 
limited, not structural, 
some additional jobs at 
suppliers 

No risk of significant 
job losses, no 
additional jobs at 
suppliers 

Impact on worker safety 

0 

Unsafe tractors are 
used longer, ca. 80.000 
workers exposed  

+ 
Improvement of safety 
through fleet renewal

+ 
Improvement of safety 
through fleet renewal 

+ 
Improvement of safety 
through fleet renewal

As a result of the above analysis, it is concluded that postponing the implementation dates 
for NTT with 3 years (Option 2) is the most appropriate measure to ensure that the policy 
objectives of ensuring a competitive industry and a better protecting the environment are 
met.  

35 

The estimated pollutant emissions and monetized impacts are relative to the baseline scenario. The emissions correspond to 
the timeframe until 2050, the monetized environmental impacts to the 2012-2030 timeframe. 

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29 

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The  3-year  delay  would  allow  most  of  the  manufacturers  to  transform  the  recent 
technological  progress  into  NTTs  complying  with  Stage  IIIB  limits  and  simultaneously 
meeting  the  essential  customer  requirements  for  their  use  in  vineyards  and  orchards. 
Thereby, significant job losses of Option 1 are avoided and the environmental and worker 
safety  impacts  continue  to  be  positive  due  to  the  continued  renewal  of  the  EU  fleet. 
Compared  to  Option  3,  the  delay  would  be  in  line  with  the  necessary  technological 
development  and  continue  to  foster  innovation.  With  a  limited  delay,  the  environmental 
benefits that were expected from the original legislation will therefore be realised, unlike 
Option 4. 

7.  MONITORING AND EVALUATION 

7.1. 

Indicators of progress towards meeting the objectives 

Since  the  implementation  of  the  preferred  option  entails  postponing  the  deadline  for 
complying with Stage IIIB and Stage IV, it is important to monitor over time the technical 
advancement in the industry, in order to track progress towards the transition towards these 
limits. Accordingly, one of the key indicators to be taken into account for evaluating the 
performance  of  the  proposed  action  is  the  level  of  R&D  investment  in  the  sector,  with 
specific reference to R&D aimed at the development of engines complying with Stage IIIB 
and Stage IV.  

At the same time, the level of sales and profitability of firms (in particular, SMEs) active 
in  the  sector  will  have  to  be  monitored  to  ensure  that  the  new  option  contributed  to  the 
competitiveness of this sector and enables the replacement of old tractors with Stage IIIa- 
compliant and, later Stage IIIB-compliant tractors. Alternatively, since the key mechanism 
by which the proposed Regulation will take effect is the tractor type-approval process, a 
core  indicator  of  progress  will  be  the  number  of  NTTs  which  are  successfully  type-
approved to the Stage IIIB and IV limit values over time. 

As  an  additional  indicator,  where  possible,  the  monitoring  of  NOx  and  PM  emissions 
attributed to NTT will reveal whether the chosen option has positively contributed to the 
environmental objectives related to this policy initiative.  

The  monitoring  of  these  indicators  can  be  carried  out  through  regular  contacts  with  the 
sector’s trade associations and is therefore not expected to lead to significant costs. 

7.2. 

Ongoing dialogue with stakeholders 

The main reason for this proposed directive is that the technical advancement of the NTT 
industry does not allow for a smooth transition towards Stage IIIB as originally envisaged: 
this poses both a problem of regulatory failure (i.e. too ambitious deadlines) and a problem 
of  industry  competitiveness.  The  proposed  3-year  extension  is  thus  a  viable  solution 
insofar  as  the  industry  will  be  able  to  invest  in  R&D  to  develop  technical  solutions  that 
comply with the set objectives at EU level for the NTT sector.  

Accordingly, constant dialogue with the industry, aimed at tracking of R&D investment by 
large and small firms in the sector and monitoring the competitiveness of the sector and its 

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ability  to  develop  suitable  technological  solutions  within  the  next  few  years  will  be  of 
utmost  importance.  In  view  of  the  future  implementation  of  the  rules  at  hand,  it  will  be 
essential to monitor the NTT  market and  the development of technologies, including  the 
appearance of potential solutions for the transition to Stage IV. 

One suitable way of achieving this constant dialogue is to rely on the Working Group for 
Agricultural Tractors (WGAT). 

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ANNEX I – GLOSSARY & DEFINITIONS 

1 - Glossary 

Adsorption: the accumulation of atoms or molecules on the surface of a material.  

Engine  family:  a  manufacturer's  grouping  of  engines  which,  through  their  design,  are 
expected  to  have  similar  exhaust  emission  characteristics  and  which  comply  with  the 
requirements of Directive 2000/25/EC 

CECE: Committee for European Construction Equipment 

CEMA: Committee for European Agricultural Tractor Manufacturers 

C.I.: An engine that works under the compression-ignition principle, e.g. diesel engine 

CO: Carbon monoxide  

DPF: Diesel Particulate Filter 

EGR: Exhaust Gas Recirculation 

Engine manufacturer: the person or body who is responsible to the approval authority for 
all aspects of the type-approval process and for ensuring conformity of production of the 
engines.  

HC: Hydrocarbons 

NOx: Nitrogen oxides 

NRMM: non-road mobile machinery (emissions directive 97/68/EC) 

NTT:  narrow-track  tractors  (categories  defined  in  Directive  2003/37/EC  as  T2,  C2  and 
T4.1, the width of which is less than 1,15 m) 

Original equipment manufacturer (tractor manufacturer): a manufacturer of a type of 
tractor (final product). 

PM: Particulate Matter 

UNECE: United Nations Economic Commission for Europe (Geneva) 

2 – Definitions of tractor categories 

Directive 2003/37/EC classifies tractors by describing the specifications of  

•  T2: Narrow wheeled tractors (vineyard and orchard),  

•  C2: narrow tracked tractors (vineyard and orchard),  

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•  T4.1: High clearance tractors  

as follows: 

Definition of vehicle categories and vehicle types  

A. The vehicle categories are defined as follows:  

(1)  Category T: Wheeled tractors  

(a)  Category  T2:  wheeled  tractors  with  a  maximum  design  speed  of  not 
more  than  40  km/h,  with  a  minimum  track  width  of  less  than  1  150 
mm, with an unladen mass, in running order, of more than 600 kg and 
with  a  ground  clearance  of  not  more than 600 mm.  However, where 
the height of the centre of gravity of the tractor (measured in relation 
to  the  ground)  divided  by  the  average  minimum  track  for  each  axle 
exceeds 0,90, the maximum design speed is restricted to 30 km/h.  

(b)  Category  T4:  special  purpose  wheeled  tractors  with  a  maximum 

design speed of not more than 40 km/h (as defined in Appendix 1).  

- 

T4.1 High-clearance tractors: tractors designed for working with 
high-growing crops, such as vines. They feature a raised chassis 
or section of chassis, enabling them to advance in parallel with 
the crop with left and right wheels on either side of one or more 
rows  of  the  crop.  They  are  intended  for  carrying  or  operating 
tools which may be fitted at the front, between the axles, at the 
rear  or  on  a  platform.  When  the  tractor  is  in  working  position 
the ground clearance perpendicular to the crop rows exceeds 1 
000 mm. Where the height of the centre of gravity of the tractor 
(measured  in  relation  to  the  ground,  using  the  tyres  normally 
fitted) divided by the average minimum track of all of the axles 
exceeds  0,90,  the  maximum  design  speed  must  not  exceed  30 
km/h.  

(2)  Category C: Track-laying tractors  

Track-laying tractors that are propelled and steered by endless tracks and whose categories 
C1 to C5 are defined by analogy with categories T1 to T5.  

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Annex II - Reference Documents 

Final Report Technical Review - DG JRC- 28 November 2008 

Administrative  arrangement  for  a  Technical  Review  of  Directive  97/68/EC, 
carried  out  by  DG  JRC,  on  behalf  of  DG  ENTR,  September  2006  -  September 
2008. 

http://ec.europa.eu/enterprise/newsroom/cf/document.cfm?action=display&doc_id=5015&userser
vice_id=1&request.id=0 

Final Report of the IA study - ARCADIS - January 2009 

External  specific  contract,  under  LOT5  framework  contract,  for  an  Impact 
Assessment  study  of  options  presented  in  the  Technical  Review  of  Directive 
97/68/EC, carried out be ARCADIS N.V., April 2008 - January 2009. 

http://ec.europa.eu/enterprise/newsroom/cf/document.cfm?action=display&doc_id=5028&userser
vice_id=1&request.id=0 

Additional Report on narrow-track tractors - DG JRC- June 2008 

Final Report of the SME Test Study and IA on possible options for reviewing 
of the Directive 97/68/EC relating to NRMM - ARCADIS - March 2010 

Additional  external  specific  contract,  under  LOT5  framework  contract,  for  an 
SME Test study, carried out be ARCADIS N.V., 2009 - March 2010. 

See  Annexes  VIII,  IX  and  X  for  the  sections  relevant  for  this  impact  assessment 
report. 

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Annex III – Emission limit standards relevant for NTTs 

Date of application of the subsequent emission limit standards 

Power 

(kW) 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

Year 

56 - 75 

CO: 5,0; HC+NOx: 4,7; PM: 0,4 

CO: 5,0; HC: 0,19;  

NOx: 3,3; PM: 0,025 

CO: 5,0; HC: 0,19; NOx: 
0,4; PM: 0,025 

37 - 56 

CO: 5,0; HC+NOx: 4,7; PM: 0,4 

CO: 5,0; HC+NOx: 4,7; PM: 0,025 

19 - 37 

CO: 5,5; HC+NOx: 7,5; PM: 0,6 

Stage 
IIIA 

Stage 
IIIB 

limit values: gr/kWh 

Stage 

IV 

CO = carbon monoxide; HC = hydrocarbons; NOx = nitrogen oxides; PM = particulate matter; 

Percentage reductions in pollutant emission limits of subsequent emission limit standards 

NOx: IIIA (cid:198) IIIB 

NOx: IIIB (cid:198) IV 

PM: IIIA (cid:198) IIIB 

PM: IIIB (cid:198) IV 

56 – 75 kW 

HC+NOx=4,7 
HC+NOx=3,49; 27 % 

(cid:198) 

3,3 (cid:198) 0,4 = 86 % 

0,4 (cid:198) 0,025 = 94 % 

0,025 (cid:198) 0,025 = 0 % 

37 – 56 kW 

HC+NOx=4,7  (cid:198) 
change 

no 

No Stage IV 

0,4 (cid:198) 0,025 = 94 %  

No Stage IV 

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Annex IV - Implementation dates 

Current Directives 2000/25/EC – 2005/13/EC 36: 

Article 4 - Timetable 

1. Member States may not after 30 September 2000: 

–  refuse to grant EC type-approval or national type-approval in respect of an engine type or 

family, or 

–  prohibit the sale, entry into service or use of a new engine, or 

–  refuse to grant EC type-approval or national type-approval of tractor types, or  

–  prohibit the use, the sale, the initial entry into service of tractor types, 

on grounds relating to air pollution if the pollutants emitted by those engines or the engines fitted to 
those tractors meet the requirements of this Directive. 

2. Member States may no longer grant EC type-approval or national type-approval for a type or family 
of engines or a tractor type where the pollutants emitted by the engine do not meet the requirements of 
this Directive: 

(a) in stage I 

…. 

(c) in stage III A 

–  after 31 December 2005 for engines of categories H, I and K , 

–  after 31 December 2006 for engines of category J; 

(d) in stage III B 

–  after 31 December 2009 for engines of category L, 

–  after 31 December 2010 for engines of categories M and N, 

–  after 31 December 2011 for engines of category P; 

(e) in stage IV 

–  after 31 December 2012 for engines of category Q, 

–  after 30 September 2013 for engines of category R. 

3.  Member  States  shall  prohibit  the  initial  entry  into  service  of  engines  and  tractors  where  the 
pollutants emitted by the engines do not meet the requirements of the Directive: 

36 

For engine categories / power classes: see end of this annex 

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–  after 30 June 2001 for engines of categories A, B, and C, 

–  after 31 December 2001 for engines of categories D and E, 

–  after 31 December 2002 for engines of category F, 

–  after 31 December 2003 for engines of category G, 

–  after 31 December 2005 for engines of category H, 

–  after 31 December 2006 for engines of categories I, 

–  after 31 December 2006 for engines of categories K, 

–  after 31 December 2007 for engines of category J, 

–  after 31 December 2010 for engines of category L, 

–  after 31 December 2011 for engines of categories M 

–  after 31 December 2011 for engines of categories N, 

–  after 31 December 2012 for engines of category P, 

–  after 31 December 2013 for engines of category Q, 

–  after 30 September 2014 for engines of category R. 

However, for tractors fitted with category E or F engines, the above dates shall be postponed 
for six months. 

4. The requirements of paragraph 3 do not apply to engines intended to be installed in tractor 
types for export to third countries and the replacement of engines for tractors in service. 

5.  For  engines  of  categories  A  to  G  Member  States  may  postpone  the  dates  laid  down  in 
paragraph 3 for two years with respect to engines with a production date prior to the said date. 
They  may  grant  other  exceptions  under  the  conditions  laid  down  in  Article  10  of  Directive 
97/68/EC. 

6. For engines of categories H to R, the dates laid down in paragraph 3 shall be postponed for 
two years with respect to engines with a production date prior to the said date. 

7. For engine types or engine families meeting the limit values set out in the table in section 
4.1.2.4,  4.1.2.5  and  4.1.2.6  of  Annex  I  to  Directive  97/68/EC  before  the  dates  laid  down  in 
paragraph 3 of this Article, Member States shall allow special labelling and marking to show 
that the equipment concerned meets the required limit values before the dates laid down. 

8. In accordance with the procedure referred to in Article 20(2) of Directive 2003/37/EC, the 
Commission shall align the limit values and dates of stages IIIB and IV with the limit values 
and dates decided following the revision procedure provided for in Article 2(b) of Directive 
2004/26/EC,  with  a  view  to  the  needs  of  agricultural  or  forestry  tractors  and,  in  particular, 
tractors of categories T2, T4.1 and C2. 

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Power classes for engines (as defined in Directive 97/68/EC) 

NB: narrow-track tractors are in the power range of 37 to 75 kW; classes P, N and R. 

Stage I: ENGINE CATEGORIES: A, B, C 

— A:  130 kW  ≤ P ≤  560 kW, 

— B:  75 kW  ≤ P <  130 kW, 

— C:  37 kW  ≤ P <  75 kW, 

STAGE II: ENGINE CATEGORIES: D, E, F, G 

— D:  18 kW  ≤ P <  37 kW, 

— E:  130 kW  ≤ P ≤  560 kW, 

— F:  75 kW  ≤ P <  130 kW, 

— G:  37 kW  ≤ P <  75 kW, 

Stage IIIA: ENGINE CATEGORIES H, I, J and K 

— H:  130 kW  ≤ P ≤  560 kW, 

— I:  75 kW  ≤ P <  130 kW, 

— J:  37 kW  ≤ P <  75 kW, 

— K:  19 kW  ≤ P <  37 kW, 

STAGE III B: ENGINE CATEGORIES L, M, N and P 

— L:  130 kW  ≤ P ≤  560 kW, 

— M:  75 kW  ≤ P <  130 kW, 

— N:  56 kW  ≤ P <  75 kW, 

— P:  37 kW  ≤ P <  56 kW, 

STAGE IV: ENGINE CATEGORIES Q and R 

— Q:  130 kW  ≤ P ≤  560 kW, 

— R:  56 kW  ≤ P <  130 kW. 

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Annex V – Examples of Narrow Track Tractors 

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Annex VI - Typical NTT Engine and Vehicle Development 
Process 

PROJECT PHASE

WHO

TIME

Year 1

Year 2

Year 3

Year 4

Year 5

Year 6

Year 7

Year 8

Year 9

Year 10

New Technology Concept Demonstration

Research Centers

Engine Sub-System Dev. (FIS,VVT, EAS)

Tier 1 Suppliers

Engine Sub-System Integration

Engine Manufact.

First Base Engine Functional Samples

Engine Manufact.

Base Engine Durability & Reliability Dev.

Engine Manufact.

Customized Engines for T2 Tractors Dev.

Engine Manufact.

First Sample Engine to T2 Tractor OEM

Engine Manufact.

New T2 Tractor Vehicle Dev.

T2 Tractor OEM

Vehicle & Engine Field Test

T2 Tractor OEM

New Vehicle Industrialization (Tooling)

T2 Tractor OEM

New Vehicle Start of Production (SoP)

T2 Tractor OEM

Source: CEMA 

BEST CASE

WORST CASE

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Annex VII –Stakeholders' opinions at Working Group for 
Agricultural Tractors meeting 

(Extracts from the minutes of the Working Group for Agricultural Tractors - WGAT) 

1 - Positions of stakeholders regarding a possible exemption from emission 
limits, based on an agenda item presented by the Commission  

22-6-2009 

authority, 

TA 
Austria 

TA authority 

Fully support the consideration to amend the 
current legislation 

22-6-2009 

Ministry, France 

Welcomes the proposal to amend  

22-6-2009 

Ministry, Spain 

Welcomes the proposal to amend  

22-6-2009 

Ministry, Italy 

Strongly supports the proposal to amend 

20-1-2009 

CEMA 

European 
manufacturers 

tractor 

Fully  support  the  proposal,  although  they 
prefer a complete exemption, not just 5 years 
exemption 

22-6-2009 

UNACOMA 

Italian 
manufacturers 

tractor 

Fully support the proposal to amend 

01-07-2009 

EUROMOT 

10-07-2009 

SMMT 

13-07-2009 

AGORIA 

14-07-2009 

AECC 

European 
The 
Association 
of 
Internal  Combustion 
Engine 
Manufacturers 

The Society of Motor 
and 
Manufacturers 
off 
Traders 
Highway  Engine  & 
Equipment Group  

(UK) 

Belgium  Employers 
Organisation 

Association 
for 
Emissions Control by 
Catalyst 

Fully support the amendment to amend 

Strongly endorses the proposal to amend  

Fully support the proposal to amend. 

Supports  additional  measures  acting  as 
incentives for Stage IIIB engines to be placed 
on the market but not the proposed measure. 
Justifications 
on 
include 
environment, EU competiveness in the global 
market. 

impacts 

2 - Extract from minutes of WGAT 

85th WGAT, 22 June 2009 

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4. Narrow-track tractors – exemption from emission requirements 

The  expert  for  CEMA/EUROMOT  stated  that  in  2004,  as  soon  as  Stages  IIIB  and  IV  were 
decided  in  the  frame  of  the  amendment  to  Directive  97/68/EC,  the  specialised  tractors 
manufacturers  addressed  their  concerns  to  the  Commission  in  view  of  the  adaptation  of  the 
tractors directive. In time the proposal to exempt NTT received the support of Vice-President 
Verheugen,  was  successfully  submitted  to  the  technical  inquiry  by  DG  JRC,  the  impact 
assessment of Arcadis and the legal scrutiny. 

He insisted that ENTR F1 presented last November a draft proposal that represents a realistic 
compromise  between  environmental  expectations  and  technical  reality  and  pointed  to  the 
urgency of the matter. He asked whether it should be recorded that the efforts of industry, the 
Commission  services  and  independent  consultants  were  not  able  to  deliver  a  solution  in  5 
years? 

The  Italian  expert  expressed  his  surprise  that  after  all  the  discussion  the  issue  is  not  solved 
yet.  Possibly  his  ministry  would  not  wait  for  a  European  solution,  as  it  is  a  very  urgent 
regional  problem.  He  also  referred  to  requests  for  higher  ‘flexibility’  percentages  in  the 
NRMM Directive. 

The Austrian expert agreed, stating that in these special tractors not enough space is available 
for the extra emission equipment needed. The Spanish expert agreed too. 

86th WGAT, 18 December 2009 

5.2. Narrow-track tractors 

The chairman explained that the Commission is well aware of the urgency of this issue, and 
that there seems to be a wide support from Member-States and industry to solve the matter. 
The original approach of a comitology amendment had proved to be unacceptable. A second 
ISC  procedure  for  the  co-decision  proposal  that  has  been  prepared  now  had  not  had  a 
promising outcome; the Unit needs to prepare an IA Report. Some discussion followed on the 
type of additional and detailed information needed for such report. 

The  Italian  expert  was  struck  by  this  statement.  He  said  that  many  companies  will  have  to 
close  down  with  tragic  numbers  of  lay-offs  as  a  result.  The  Commission  should  take  the 
economic situation into account.  

A  representative  from  CEMA  gave  a  clear  Power  Point  presentation  to  show  why  it’s 
impossible now to adapt NTTs to emissions Stage IIIB and IV, on technical grounds: no space 
under the bonnet, unacceptable reduction of steerability or ground clearance, etc. 

Another representative for CEMA, representing a specific company, explained that she would 
have to close down her company (400 staff) if there would be no exemption for Stages IIIB 
and IV. Still the users, mainly in the mountains and hills in Southern Europe, need these NTT. 
The  emission  stage  IIIA  already  required  huge  investments  by  the  manufacturers;  1  in  10 
tractors of the existing EU fleet are IIIA compliant now, and the presentation highlighted that 
to  stop  the  replacement  of  old  tractors  with  new  models  will  present  a  damage  for  both 
environment and the safety (old tractors still don’t have ROPS, safety belts etc). 

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The Austrian expert, supporting the need for an exemption, stated that tractors in agriculture 
use only about 1% of the fuel, so have little impact on the environment. Stage IIIB would be 
technically ‘impossible’ in a NTT. 

The Greek expert stated that this is a technical issue; if there is no technical solution then we 
need an administrative solution. She supports the proposal. 

The  French  expert  had  the  same  view  as  the  Italian  and  CEMA  colleagues;  there  is  a  crisis 
now in this sector (minus 50% in 2 years). 

Experts from Finland, Sweden and the Netherlands also supported the exemption. 

The representative of EUROMOT stated that six months after his last intervention at a similar 
meeting,  the  situation  had  not  advanced.  He  felt  that  this  is  unacceptable,  but  what  is  even 
more  unacceptable  is  that  the  existence  of  the  specialised  tractors  is  questioned  only  on 
bureaucratic grounds. All the evidence of independent studies for the Commission (ref. JRC, 
ARCADIS) confirms the justification of the exemption of these tractors from Stages IIIB and 
IV  due  to  the  impossibility  to  meet  those  requirements.  All  the  requested  data  are  available 
already from those studies (mainly Arcadis) or were supplied later. What makes the situation 
even more surreal is that yet another impact assessment study is asked where in reality we are 
trying to correct a mistake in a piece of legislation not based on Sound scientific knowledge 
and  economic  assessments,  reliable  and  up  to-date  data  and  information  and  the  use  of 
indicators (Sixth environmental Action Programme), but is only the result of a ‘cut and paste 
exercise’ from US legislation. The co-legislators had left an open door to verification of the 
technical  feasibility  and  soundness  of  their  decisions,  but  now  bureaucracy  is  closing  this 
door. What seems worrying, from EUROMOT perspective, is that there are no signs that the 
system is able to correct its own mistakes in a reasonable time and that it ignores scientific 
evidence  and  puts  at  risk  jobs  in  industry  and  agricultures  and  the  active  and  productive 
economy of the Community. 

Meeting with industry on Impact Assessment emissions NTT, 2-9-2010. 

Participants: representatives from CEMA and EUROMOT and DG ENTR 
Purpose: to obtain information for the IA of a proposal to solve problems for the introduction 
of new Stage IIIB and IV requirements for the special tractors of categories T2, C2 and T4.1 
for use in vineyards and orchards, as indicated in Directive 2005/13 – article 1.4(d). 

Background: when stages IIIB and IV were discussed in 2004 / 2005, industry warned for 
the problems for these NTT; this resulted in article 1.4(d) of 2005/13, stating in the new 
paragraph 8 that the Commission shall act '… with a view to the needs of agricultural or 
forestry tractors and, in particular, tractors of categories T2, T4.1 and C2'. 

These new stages, aiming at reduction of environmental problems in Europe, were adopted 
without IA, fully based on alignment with USA limits and tests (Tier IV-interim and IV). In 
2008 the study by JRC showed that an exemption was needed; in 2009 ARCADIS studied the 
IA consequences, first in the overall report on amendments to Directives 97/68 (Machinery) 
and 2000/25 (tractors) and afterwards in the additional SME Test study. 

Two power bands as defined in 2000/25 are used for NTT: 37-56 and 56-75 kW. Most 
engines are in the higher class, close to 75 kW (with the new tendency to go to 80 kW, as 
farmers need more power for additional equipment). The 56 limit comes from US legislation 

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and is not specific for EU. In general the overall dimensions of the NTT are the same, 
regardless of whether the engine used belongs in the lower or higher power class.  

IASG: on 22 July a first meeting was held, in which questions were raised (SG, ENV). This 
led ENTR to send a list of questions to CEMA (tractors and machinery manufacturers) and 
EUROMOT (engine manufacturers), which were discussed in the 2/9 meeting. The resulting 
info is presented below; in addition industry promised to collect and submit further data in 2 
weeks time. 

Industry stated that for NTT the functionality is essential, more than costs; if the user is not 
satisfied about functionality (esp. dimensions and fit of additional equipment) he will not buy 
a new tractor. 

Questions and answers 

Q1: are engines for NTT and other tractors the same? 
Answer: yes and no. No engine is specifically designed for NTT; base engine is for use in 'all' 
types of tractors, but they must be adapted for use in NTT (different placing of turbo, EGR, 
cooling, hoses etc). 

Engines for use in tractors have specific requirements (strength of sump, shape/dimensions, 
passage of transmission axle to front axle 'through' sump), which makes that some IIIB 
approved engines for machines cannot be used here. For this reason some recently presented 
engines (JCB engine presented in July in the AECC symposium; Cummins) are not suitable. 

Q2: when can IIIB engines be available for NTT? 
Answer: industry does not see IIIB becoming available until more is finished, maybe a 
prototype in one year. Tractor manufacturers started requesting engine manufacturers in 2006 
to produce IIIB engines in time. Only recently specially adapted (shaped) filters became 
available for engines below 56 kW, not yet for the larger ones. EUROMOT presented in 
WGAT (Dec 2009) a graph showing the example of a timeline for the development of the 
engine and then the tractor, taking 6 -10 years (best – worst case) from the moment of 
demonstration of the concept of new technology. 

From the moment that a first functional sample of a new base engine is available it would take 
3-4 years to adapt them for use in NTT.  

Costs: as this is a limited market, for competitiveness reasons industry cannot readily give 
figures. CEMA proposed to use a different approach which should allow to come with 
relevant generalised figures in the near future. 

On the issue of Stage IV, industry stated that there are no solutions in sight; at present they do 
not see a date when NTT could meet those requirements ('totally in the dark'). As a 
consequence there are no cost figures to be indicated. 

Q3: is it a useful option to skip Stage IIIB and go to Stage IV at the defined deadline? 
Answer: industry stated that with the present state of knowledge it is impossible to make a 
Stage IV compliant NTT. Engines are not ready; SCR and DPF seem necessary but require 
too much space. On the other hand, for engines below 56 kW, no Stage IV is required. 
On the other hand, industry invested heavily already in developing for Stage IIIB; this money 
would be lost if IIIB would be lost. 

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Q4: Is 50% flexibility a solution for NTT? 
Answer: this is not the proper solution for this problem, as it basically allows only for some 
more weeks of leadtime, for products which are not ready by the deadline of the directive. 

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Annex VIII – Relevant parts of the JRC report 2008 

Land Based Compression Ignited Engines  

The  problem  arising  from  the  application  of  Stage  IIIB  and  Stage  IV  emission  limits  for 
special  small  tractors  was  discussed  and  analysed  in  large  detail.  In  conclusion,  the  special 
narrow track tractors used in vineyards and orchards should be exempted from the emission 
Stage IIIB and Stage IV.  

5.3  Application  of  Stage  IIIB  and  Stage  IV  emission  limits  to  special  agricultural 
tractors used in vineyards and orchards  

Under  the  Council  Regulation  (EC)  No  1493/1999  from  14.07.1999  (OJ  L179,  Chapter  III, 
Articles 11 and 13) on the common organisation of the market in wine from 1999, Member 
States  can  obtain  annual  payments  for  restructuring  and  conversion  of  a  set  number  of 
hectares of vineyards. The objective of this system is the adaptation of production to market 
demand. It covers the following measures:  

–  varietal conversion,  

–  relocation of vineyards and  

–  improvements to vineyard management techniques.  

The system does not cover the normal renewal of vineyards which have come to the end of 
their natural life.  

As consequence of the restructuring of vineyards, according to a German wine producer, the 
row width has changed from narrow row width of about 1 meter to larger row widths of 1,6 - 
2,2 meters. One reason was the possibility to switch from manual cultivation techniques to the 
use of special agricultural tractors and machinery. As reason for the upper row width limit the 
micro-climatic  control  was  mentioned:  larger  row  width  would  dry  out  the  grounds  and 
increase ventilation and cooling between the plants. In general it was stated that the new row 
width gives the best results in terms of quantity at the desired high quality level.  

Similar to vineyards also the orchards are set up with row widths of about 2 meters, allowing 
for automation of cultivation of ground, plant/fruit treatment and harvesting by using special 
agricultural tractors and machinery.  

5.3.1 Classification according to Directive 2003/37/EC  

[See Annex I] 

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5.3.2  Problems  reported  by  manufacturers  and  user  regarding  the  installation  of 
additional after-treatment equipment on special purpose tractors  

The  report  is  based  on  a  presentation  prepared  by  UNACOMA  and  material  provided  by 
manufacturers  during  visits  to  their  production  sites.  The  following  list  gives  a  summary  of 
the reasons for which the additional (necessary) equipment required to fulfil Stages IIIB and 
IV can currently not be installed in the special small tractors.  

General technical development and construction  

–  Introduction of Stage IIIB and Stage IV would need introduction of after-treatment systems 

for PM and NOx  

–  PM  after-treatment  is  likely  to  be  accomplished  by  a  closed  particle  trap  requiring 

sometimes also an additive tank for regeneration  

–  Typical volume for such a PM system is 2 - 2.5 times the engine displacement  

–  PM  traps  need  high  temperatures  for  regeneration  and  consequently  a  position  near  the 

engine out valve  

–  NOx after-treatment is most probably accomplished by a SCR system requiring a catalyst, 
a urea injection system and a urea tank. The catalyst should be placed near the engine out 
valves  

–  Typical volume for such a de-NOx system is 2 times the engine displacement  

–  De-NOx  system  requires  operation  temperatures  above  280  C  and  consequently  a  place 

near the engine out valves (as does already the PM system)  

–  Engine temperatures during tractor operation are high. This creates already now difficulties 

because of the lack of space for additional cooling systems  

–  Under  specific  working  conditions  tractor  is  operated  at  low  load  with  high  oil 
consumption and high ash formation and low temperature which is difficult for running a 
PM filter  

–  When operated at high load the problems will arise from the increase in counter pressure 
due to construction limits; all connections between engine and exhaust after-treatment need 
to be bended and their cross section must be reduced.  

Special purpose tractors and their specific problems  

–  The  total  number  of  T2  tractor  sales  in  Europe  is  about  16.000  units,  and  the  T2  engine 
power goes up to 75 kW. The T2 tractors are part of the about 85.000 tractors sold in year 
2005 in the 19-75 kW power range (see NRMM inventory).  

–  Special machinery to be operated with the T2-tractors can’t be used any longer when the 

general shape of the tractors needs to be modified  

–  Average life of T2 tractor in professional environment is about 8-10 years  

EN 

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–  Price of T2 tractors is much higher than for an equivalent “normal” tractor  

–  T2-tractors  are  sometimes  used  for  community  work,  cleaning  roads  from  snow,  cutting 
trees or similar work. A T2-tractor would not be suitable to replace a “normal” tractor due 
to its higher price and its uncomfortable design with narrow driver cabin and high centre of 
gravity. The latter one results in frequent overturn of the tractors in steep vineyards.  

–  T2  tractors  need  to  turn  in  a  very  limited  area.  To  reduce  the  radius  for  turning,  some 
models have shaped the tractors body to avoid that the tyres touch the tractor body. Others, 
the  articulated  tractors,  have  introduced  additional  front  parts  to  be  turned.  The  latter 
models are special flat tractors in which the driver is lying rather than sitting  

–  The  engine  is  packed  in  the  T2  tractor,  and  has  elements  that  with  a  special  shape  to  fit 
under the bonnet, which is giving the physical boundary for construction. The fuel tank is 
often made up of several smaller canisters put in different places.  

Boundary conditions for field operation of a special purpose tractor  

–  T2 tractors are built for special purpose, they need to operate at high efficiency in narrow 

vineyards and orchards.  

–  They  should  have  a  maximum  engine  height  of  about  1.2  meters,  a  width  of  down  to  1 
meter and cabins/outside pieces that can be bended for not touching fruits during operation 
in field. Hot and sharp surfaces are not allowed outside the tractors, otherwise the grapes or 
fruits will be damaged.  

–  The T2-tractors are highly specialized tractors which can be operated simultaneously with 
different  cultivation  machines  to  reduce  number  of  treatment  steps  (and  consequently  as 
by-product also the emissions per treatment).  

–  Limiting factors for construction and engineering freedom are the space between rows, the 
height of fruits above the tractors body and the space at the end of rows for turning into the 
“next” row.  

European market and wine production  

–  T2 tractors are a special European product, wine producers in US have no need because the 

available field space there is much bigger allowing for different cultivation methods.  

–  European  space  for  vineyards  is  limited  and  expensive.  It  needs  to  bring  high  quality 

products instead of mass production. 

–  European space for vineyards is in almost all cases difficult terrain, either in mountains or 

on hills, where normal tractors can’t operate. 

–  Vineyard  row  width  has  been  changed  some  10-15  years  ago,  funded  by  European 
commission,  in  order  to  increase  competitiveness  of  European  wine  producers  (see 
introduction).  

–  The change from manual to machinery treatment and fruit/grapes collection is based on the 

enlarged row width, increasing from about 1m to about 2m width. 

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–  Turning with the tractor into each 2

row is possible today without loosing too much space 
at both ends of the vineyard for turning the tractor. This would not be any longer possible 
when tractors become longer.  

nd 

–  Cultivation  cycles  are  about  20-30  years:  changing  row  width  would  not  be  immediately 
possible  without  financial  losses.  Cutting  plants  away  at  both  field  ends  to  allow  for 
turning with longer tractors would reduce the field or vineyard yield substantially because 
European  fields  are  already  now  short  in  length.  Cutting  away  additional  plants  would 
result in an estimated 20% loss of cultivable grounds.  

5.3.3 Environmental impact of the exemption  

Further to the estimates on the environmental impact of an exemption of special narrow track 
tractors (categories T2, C2, T4.1) from the emission limits set in Stage IIIB and Stage IV, a 
more detailed emissions inventory was made. The assumptions used for the calculations and 
the final results are reported herein after.  

(i) Basic elements and assumptions  

Engine survival rate  

The engine survival rate follows a normal distribution (mean = average life; σ = 0.25)  

Numbers for average life of 8, 10, 12, 16 years are given in the table below and are illustrated 
in the graph.  

Annual operating hours  

The  annual  operation  hours’  curves  follow  a  suggestion  from  Euromot,  CECE,  CEMA,  but 
includes a linear decrease until the end of engine life, instead of a constant 50% rate.  

EN 

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EN 

50 

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EN 

51 

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EN 

52 

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First year operation hours  

The  first  year  operating  hours  within  the  different  power  categories  relevant  to  specialised 
tractors are given in the table below, together with the average total operation hours over the 
full  life  of  an  engine.  The  selected  conditions  for  the  special  tractors  and  normal  tractors 
inventory are:  

–  power  band  19-37  kW:  8  years  average  life;  400  hours  operation  in  1
st 

tractors; 250 hours operation in 1

year for special tractors  

st 

year  for  normal 

–  power  band  37-56  kW:  12  years  average  life;  500  hours  operation  in  1

st 

year  for  normal 

tractors; 300 hours operation in 1

year for special tractors  

–  power  band  56-75  kW:  16  years  average  life;  700  hours  operation  in  1

year  for  special 

tractors; 350 hours operation in 1

year for special tractors  

st 

st 

Emissions from large (normal) tractors in the power band above 75 kW were also calculated 
for having a complete picture of all agricultural tractors’ emissions. The selected conditions 
for the large tractors inventory are:  

–  power band 75-135 kW: 16 years average life; 700 hours operation in 1

–  power band 135-560 kW: 16 years average life; 750 hours operation in 1

year  

st 

st 

year  
st 

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It  can  be  questioned  if  the  12  and  16  years  average  life  selected  for  normal  tractors  is  also 
appropriate for the narrow track tractors. In the inventory it would have an impact on the fleet 
renewal,  thus  a  reduced  life  of  narrow  track  tractors  would  reduce  the  impact  time  when 
calculating a delay in the introduction date of an emission limit stage. But there would be no 
effect on the emission level of the stabilised projection.  

Annual sales  

these  numbers  were  confirmed  by 

Annual  sales  numbers  for  all  tractors  in  the  different  power  categories  were  taken  from 
information given by Euromot/CECE/CEMA. The special tractors’ sales numbers (named T2 
sales  in  the  table)  were  presented  to  JRC  by  the  manufacturers  during  a  visit  to  their 
production  sites.  Although 
in  private 
communications, and not questioned when presented during GEME meetings, there remains a 
high level of uncertainty because one source quoted a total of 14.000 special tractors sold in 
2004. Furthermore the total sales of special tractors with about 30.000 units per year are quite 
large.  This  has  to  be  compared  with  the  total  sales  of  all  tractors  in  the  power  range  19-75 
kW,  summing  up  to  about  85.000  units,  and  with  the  overall  tractor  sales  of  about  150.000 
units over the full power range. The share of specialised tractors in these two cases becomes 
35% and 20% respectively.  

industry 

However, the sales numbers used for this inventory, and shown in the table below, refer to the 
base  year  2005.  They  are  estimates  for  the  sales  in  the  EU15.  For  the  projection  a  stable 
market was assumed (no increase/decrease in sales over the years).  

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Emission limits and introduction date  

PM and NOx emissions from tractors were examined, being today the most relevant ones for 
diesel  fuelled  engines.  Emission  factors  for  the  inventory  were  derived  from  the  relevant 
emission limits as given in the NRMM Directives.  

These  values  were  multiplied  with  a  “correction  factor”  of  0.7  for  PM  and  0.8  for  NOx,  to 
account for that the expected average emissions are lower than the limit values.  

The real world operation and actual in-use engine power has been taken in consideration by 
another multiplicative “load factor” which has been set to 0.5 for all engines.  

Emission  limits  and  introduction  dates  shown  in  the  table  5.10  below  are  those  given  in 
Directive 2000/25/EC and Directive 2005/13/EC.  

Table 5.10: PM and NOx emission limits for engines used in agricultural tractors and  
their introduction dates for the relevant engine power classes (all new engines).  

Emission factors for old engines (“unregulated”) were estimated from different values found 
in the literature. The overall impact of these engines is small in the period of interest where 
the exemptions for small specialised tractors might become effective.  

(ii) Scenarios  

Calculations were made for emissions from all tractors and separately for special tractors in 
the  different  power  bands  between  19  kW  and  560  kW.  Annual  emissions,  always  given  in 
kilo tonnes, are calculated until year 2050.  

A  first  scenario  estimates  the  annual  emission  pattern  for  all  tractors  under  the  assumption 
that all follow the current legislation, i.e. no exemption for special tractors.  

For  PM  emissions  additional  calculations  were  made  under  the  assumption  that  special 
tractors are exempted from Stage IIIB, and under the assumption that the introduction date is 
postponed by 5 years.  

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55 

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For  NOx  emissions  additional  calculations  were  made  under  the  assumption  that  special 
tractors  are  exempted  from  Stage  IIIB  only,  exempted  from  Stage  IIIB  and  Stage  IV,  and 
under the assumption that the introduction date for Stage IIIB and Stage IV is postponed by 5 
years.  

(iii) Results  

The tables and graphs below are summarising the results obtained for the different scenarios. 
The short discussion below is made separately for PM emissions and NOx emissions . 

PM emissions:  

Following the current legislation, all tractors in the full power range 19-560 kW would reach 
by the year 2050 a total annual emission of 1.1 kt. Taking only the power range 19-75 kW, in 
which the special tractors are included, the total annual emissions reach 0.3 kt in year 2050.  

Exempting  special  tractors  from  Stage  IIIB,  the  annual  emissions  of  all  tractors  in  the  full 
power range 19-560 kW would reach about 1.8 kt in year 2050, from which a total of about 1 
kt can be attributed to tractors in the power range 19-75 kW, in which the special tractors are 
included.  

In  other  words:  the  exemption  of  small  tractors  would  increase  on  the  long  term  the  PM 
emission by about 0.7 kt per year.  

Postponing  the  introduction  would  result  in  year  2050  in  the  same  total  annual  emission  as 
calculated for the “current legislation”. The delay would result over a period of about 34 years 
a  total  additional  emission  of  3.5  kt  in  addition  to  the  estimated  38  kt  PM  emissions  of  all 
tractors in the power range 19-75 kW over the same period. This equals an overall increase by 
9%.  

Figure 5.3: Annual PM emissions as calculated for the different scenarios until the year 2050.  

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Note: the graph shows the annual PM emission pattern for all tractors in the power band 19-
560 kW, but the differences for different scenarios only for the tractor power band in which 
narrow track tractors are found (19-75 kW).  

NOx emissions:  

Following the current legislation, all tractors in the full power range 19-560 kW would reach 
by the year 2050 a total annual emission of 29 kt. Taking only the power range 19-75 kW, in 
which the special tractors are included, the total annual emissions reach 15 kt in year 2050.  

Exempting special tractors from Stage IIIB and Stage IV, the annual emissions of all tractors 
in the full power range 19-560 kW would reach about 35 kt in year 2050, from which a total 
of about 21 kt can be attributed to tractors in the power range 19-75 kW, in which the special 
tractors are included.  

In other words: the exemption of small tractors from Stage IIIB and Stage IV would increase 
on the long term the NOx emissions by about 6 kt per year.  

Exempting special tractors from Stage IV only, the annual emissions of all tractors in the full 
power range 19-560 kW would reach about 33 kt in year 2050, from which a total of about 19 
kt can be attributed to tractors in the power range 19-75 kW, in which the special tractors are 
included.  

In  other  words:  the  exemption  of  small  tractors  from  Stage  IV  only  would  increase  on  the 
long term the NOx emissions by about 4 kt per year.  

Postponing the introduction of both Stages IIIB and IV would result in year 2050 in the same 
total annual emission as calculated for the “current legislation”. The delay would result over a 
period of 36 years a total additional emission of 33 kt in addition to the estimated 965 kt NOx 
emissions of all tractors in the power range 19-75 kW over the same period. This equals an 
overall increase by about 3.5%.  

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Figure  5.4:  Annual  NOx  emissions  as  calculated  for  the  different  scenarios  until  the  year 
2050.  

Note: the graph shows the annual NOx emission pattern for all tractors in the power band 19-
560 kW, but the differences for different scenarios only for the tractor power band in which 
narrow track tractors are found (19-75 kW).  

5.3.4 Summary  

No sufficient free space is available in the current structures of T2 tractors for installation of 
secondary after-treatment devices. To install such emission reduction technologies, the shape 
of T2 tractors would need to be changed: they should be made either longer or wider. Making 
them  higher  is  probably  no  option  because  of  the  already  today’s  high  instability  of  the 
tractors resulting from the high centre of gravity.  

As consequence of the re-shaped design the user requirements will no longer be fulfilled: the 
tractors would  touch  and  destroy fruits and grapes with a wider shape, or would need to be 
turned  in  time  consuming  and  ground  compacting  manoeuvres.  The  existing  special 
machinery could not be used any longer and would need to be replaced  

To overcome these problems the vineyards and orchards need to be restructured to fit to the 
new  shaped  tractors.  This  would  be  an  additional  financial  burden,  mainly  for  small 
producers,  especially  caused  by  the  reduced  productivity  of  a  field  with  larger  row  width 
and/or shorter row length.  

On the other side the user claim that they would utilise the current tractor models longer than 
the normal 8-10 years to avoid the additional costs of buying a new tractor not serving their 
need,  the  new  machinery  to  be  operated  with  the  new  models  and  the  necessary  field 
restructuring. The new models would not find customers on the market, and some T2 tractor 
manufacturers stated that they would then give up this low profit market segment.  

Possible actions to be taken  

Option 0: No action  

Option  1:  Exempt  special  purpose  tractors  for  a  limited  time  from  the  emission  Stages  IIIB 
and Stage IV.  

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Annex IX – Relevant sections of the ARCADIS report 2009 

IMPACT ASSESSMENT STUDY – Reviewing Directive 97/68/ECEmissions from non-
road mobile machinery 

Specific Contract n° SI2.ACPROCE018014400; ENTR/04/093 Lot 5 

FINAL REPORT for EC DG Enterprise and Industry - 30 January 2009 

3.6  LAND  BASED  COMPRESSION  ENGINES:  SPECIAL  AGRICULTURAL 
TRACTORS USED IN VINEYARDS AND ORCHARDS 

3.6.1 Background 

The current structures of special agricultural tractors used in vineyards and orchards (T2, T4.1 
and C2 tractors) have no sufficient free space for the installation of secondary after-treatment 
devices. To install such emission reduction technologies, the shape of these tractors needs to 
be  changed:  they  should  be  made  either  longer  or  wider,  which  could  result  in  higher 
instability of the tractors.  

The eventual reshaped tractors will no longer fulfil the user requirements. They will touch and 
destroy fruits and grapes unless users restructure their vineyards at relatively high costs. Even 
if  stage  IIIB  and  stage  IV  compliant  tractors  become  available,  users  could  use  the  actual 
models longer to avoid this field restructuring and the additional costs of buying a new tractor 
not serving their needs. (JRC, 2007 and stakeholders input)  

T2: 

narrow wheeled tractors 

T4.1  high clearance tractors 

C2: 

narrow tracked tractors  

Emissions  of  special  purpose  tractors  are  roughly  estimated  at  8.5  %  of  all  CI  NRMM  for 
NOx and 4.8 % of all CI NRMM for PM. (JRC, 2007 and own calculations) With a reduction 
of  emissions  of  other  CI  engines,  the  relative  emissions  of  these  engines  will  grow  in 
importance. 

3.6.2 Options to investigate 

–  option 0: do nothing or keep stage IIIB and stage IV for special purpose tractors 

Risks are that new tractors are not bought in the short term and that producers pull out of the 
market 

–  option 1: exempt special purpose tractors form stage IIIB and stage IV 

This option will cause some extra emissions. It will make life of users easier. An exemption 
of 5 years seems to be reasonable from a technical point of view (Mr Krasenbrink) 

Remark:  

–  for the smallest segment 19-37 kW there is no stage IIIB and thus no problem 

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–  for the 37-57 kW there is a stage IIIB but not a stage IV 

–  for the 57-75 kW there is a stage IIIB and a stage IV foreseen  

Emission standards 

Table 1 Relevant emission standards for special purpose tractors 

emission standards g/kwh

19-37 kw

37-56 kw

56-75 kw

stage IIIA
stage IIIB
reduction compared to IIIA
stage IV
reduction compared to IIIB

standard
PM

start date

Nox

standard
PM

start date

standard
PM

Nox

start date

Nox
7.5 (HC incl)
no stage IIIB emission standard

0.6 31/12/2006 4.7 (HC incl)
4.7 (HC incl)

0.4 31/12/2007 4.7 (HC incl)

0.025 31/12/2012
94%

3.3
27%
0.4
88%

0.4 31/12/2007
0.025 31/12/2011
94%
0.025 30/09/2014

0%

no stage IV emission standard

no stage IV emission standard

3.6.3 Sector description 

Special agricultural tractors are a purely European product –in the US, available field space is 
much bigger (JRC, 2007). According to the JRC, about 28 000 tractors are sold in the EU 1537 
– this corresponds 5.8% of all sold NRMM CI engines. 

CEMA estimates that 25 600 units are sold per year in the EU, and 2 500 outside the EU. The 
price is € 30 000 with a minimum of € 17 000 and a maximum of € 58 000, corresponding to 
an estimated turnover of € 843 million.  

The 4 largest companies in the EU hold a market share of 55% - the remainder of the market 
is  in  hands  of  SMEs.  All  producers  are  based  in  Italy  or  Germany,  and  the  SME”s  are  all 
Italian. These producers employ 1 800 people directly, and 1 200 people indirectly.  

3.6.4 Main impacts of the options 

3.6.4.1 Compliance costs 

Building small vineyard and orchard tractors seems to be unfeasible for the industry. Those 
small tractors have to operate at high efficiency in narrow vineyards and orchards. Maximum 
weight and width, end of row turn, are strictly limited due to these elements. The width is a 
decisive factor in the decision to buy a specialized tractor.  

Fitting after-treatment on the small tractors without modifying their specific characteristics is 
with current technologies unfeasible.  

A diesel particulate filter could be added at the side of the tractor, under the tractor or on top 
of the engine. All solutions modify one or more of the specific small tractor characteristics to 
wit and cause therefore other potential problems: 

•  Impossibility to overcome real life ramp angles 

•  Insufficient visibility 

•  Impossibility to use mid mounted implements 

•  Impossibility to steer 

37 

Personal communication from Mr Krasenbrink, updating the estimate in the JRC report, p. 89.  

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•  Impossibility to perform operations with side mounted implements 

•  Impossibility to perform operations with front loaders….. 

3.6.4.2 Socio economic impacts 

For  an  evaluation  of  the  socio-economic  impacts,  we  will  assume  that  option  0  is  indeed 
technologically not feasible.  

In this case, the following solutions would be open for the end users: 

•  Redesign existing vineyards and orchards to fit compliant tractors 

•  Maintain old tractors until a technical solution has been found for new tractors 

The  first  solution  has  been  clearly  excluded  by  the  vineyard  sector.  The  European 
Confederation of Independent Winegrowers (CEVI) has not been able to quantify its financial 
implications,  but  has  pointed  out  that  a  grubbed-up  and  replanted  vineyard  does  not  give 
grapes  before  three  years.  The  average  life  cycle  of  a  vineyard  is  forty  years.  However,  as 
explained  in  section  0,  the  JRC  has  estimated  that  5  additional  years  would  be  sufficient  to 
develop of solution for special tractors! 

Moreover, according to the CEVI, the planting density is determined by the specifications of 
the designation of origin. An enlargement of rows would then run counter to EC support for 
replanting  with  a  higher  density.  In  some  slope  or  terrace  zones,  CEVI  also  claims  that  it 
would not be possible to widen the rows.  

The JRC report has also pointed out that 20% of cultivable land will be lost when vineyards 
are adapted to new tractors while European space for vineyard is limited and expensive. 

Therefore, we think we can safely assume that the first solution is excluded.  

Therefore,  the  more  realistic  assumption  is  that  end  users  will  simply  not  buy  new  tractors, 
but  maintain  their  old  ones  until  a  new  technical  solution  is  found.  In  this  case,  the 
environmental benefits of the Directive would be lost.  

As  the  smaller  producers  of  special  tractors  are  niche  players,  discontinuation  of  the 
production of this type of tractors would put them out of business. Employment at the larger 
manufacturers would be reduced proportionally, at least until a solution has been developed. 
Due to a lack of more specific information, we can only conclude that this would correspond 
to a maximum of 3,000 job losses for a period of up to 5 years.  

3.6.4.3 Environmental impacts  

Emission results 

The graphs below show the main environmental impacts of the options under investigation: 
Figure 3 for PM and Figure 4 for NOx. 

The  graph  for  the  compliant  solution  (option  0)  is  rather  hypothetical,  as  it  is  unfeasible  to 
comply with stage IIIB and stage IV. Two sub options are possible in the case 0 option: 

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•  Option 0A: No new machinery is available and vineyards have to close down (not 

shown on graph)  

•  Option  0B:  No  new  machinery  is  available  and  older  tractors  continue  to  work. 

Machinery is repaired instead of replaced.  

In the hypothetical situation that all engines are able to meet the emission limits at the date as 
originally  planned  (option  0),  the  decrease  in  emissions  is  larger  than  if  special  tractors  are 
exempted from Stage IIIB emission limits for 5 years (option 1). 

However, if Stage IIIB emission limits are imposed and no new machinery is able to meet the 
limits, causing old machines to remain in service (option 0B), emissions are higher than for 
option 1. 

These general conclusions are similar for PM emissions and NOx emissions. However, there 
is one notable difference between PM and NOx: the difference between option 0 and option 1 
is larger for PM than for NOx.  

As a result, option 1 emissions are closer to option 0B emissions for PM than for NOx. 

As it is assumed that Stage IIIB (and Stage IV in the case of 56-75kW engines) emissions can 
eventually  be  met,  emissions  of  all  options  converge  after  the  complete  stock  has  been 
renewed  around  the  year  2030.  Eventual  yearly  emissions  are  estimated  at  0.171  kt  for  PM 
and 4.41 kt for NOx. 

Special tractors

1.4

1.2

1

0.8

0.6

0.4

0.2

]
t
k
[
s
n
o
i
s
s
i
m
e
M
P

0
2005

OPTION0
OPTION0B
OPTION1

2010

2015

2020

2025

2030

2035

2040

2045

2050

year

Figure 3 PM emissions of Special agriculture tractors (time series 2005-2050) 

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. 

20

18

16

14

12

10

8

6

4

2

]
t
k
[

s
n
o
i
s
s
i
m
e

x
O
N

0
2005

Special tractors

OPTION0
OPTION0B
OPTION1

2010

2015

2020

2025

2030

2035

2040

2045

2050

year

Figure 4 NOx emissions of Special agriculture tractors (time series 2005-2050) 

Methodology emission calculation 

In the annex a small emission model for CI engines is described.  

This model is also used to assess the impact on emissions for the different options for special 
agricultural tractors. 

From the 7x7 matrix in the emission model, the cells for the category “agricultural tractors” 
for engine power classes 19-37 kW, 37-57 kW and 57-75 kW are used in this calculation. 

The  input  for  the  emission  model  is  adapted  for  special  agricultural  tractors,  based  on  info 
from the JRC report and based on input from CECE/CEMA. 

•  Annual sales 

Annual sales are estimated at 26 000 per year for EU15. These sales are assumed to remain 
constant (stable market conditions).  

Special agricultural tractors have a power range between 19 and 75 kW. 

Due to lack of better data, the shares of the three power classes between 19 and 75 kW are 
assumed to be equal, see Table 2. 

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Table 2 Estimated annual sales special agricultural tractors (EU15) 

Share
Agricultural Tractors

19-37 kW 37-56 kW 56-75 kW
33%
8666  

33%
8666

33%
8666

•  Useful machine life 

In the JRC report, useful machine life was reported to be between 8 to 10 years. Therefore, 
the average useful machine life is assumed to be 9 years. 

•  Emission factors 

The only difference between the different options, is the set of emission factors that is used 
for each option. The options under investigation are described in section 0. 

There  are  three  engine  size  classes  for  special  agricultural  tractors.  The  option  0  emission 
factors for 19-37 kW are indicated in Error! Reference source not found., those for 37-56 
kW engines are indicated in Table 4, and Table 5 contains the emission factors for 56-75 kW 
engines. The pre-Stage I emission factors are based on (Van Zeebroeck, 2005). The Stage I, 
Stage II and Stage IIIA emission factors are calculated as the emission limit multiplied by a 
reduction factor, as an estimate for typical emissions. The reduction factors are based on those 
provided by Euromot/CECE/CEMA, see Table 6. 

To calculate emissions for option 1, Stage IIIB emission factors are delayed 5 years. For 56-
75 kW engines, the Stage IV emission factors are also delayed 5 years.  

Table 3 Emission factors for 19-37kW CI engines (option 0) 

From
0
1981
1991
2001
2007

To
1980
1990
2000
2006
2050

NOx
16.20
16.20
9.80
5.76
4.55

PM Comments
1.60 Based on [Van Zeebroeck, 2005]
1.50 Based on [Van Zeebroeck, 2005]
1.26 Based on [Van Zeebroeck, 2005]
0.45 Stage II * red_factor_typical_emissions; PM adapted for alignment with JRC
0.34 Stage IIIA * red_factor_typical_emissions

Table 4 Emission factors for 37-56kW CI engines (option 0) 

From
0
1981
1991
1999
2004
2008
2013

To
1980
1990
1998
2003
2007
2012
2050

NOx
11.500
8.600
7.700
7.360
5.600
3.171
3.171

PM Comments

1.800 Based on [Van Zeebroeck, 2005]
1.200 Based on [Van Zeebroeck, 2005]
0.720 Based on [Van Zeebroeck, 2005]
0.476 Stage I * red_factor_typical_emissions
0.224 Stage II * red_factor_typical_emissions
0.224 Stage IIIA  * red_factor_typical_emissions
0.025 mininimum of (Stage IIIB, ef_factor previous years)

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Table 5 Emission factors for 56-75 kW CI engines (option 0) 

From
0
1981
1991
1999
2004
2008
2012
2014

To
1980
1990
1998
2003
2007
2011
2013
2050

NOx
11.500
9.460
8.470
8.096
6.160
3.480
3.300
0.400

PM Comments

1.800 Based on [Van Zeebroeck, 2005]
1.200 Based on [Van Zeebroeck, 2005]
0.800 Based on [Van Zeebroeck, 2005]
0.536 Stage I * red_factor_typical_emissions
0.252 Stage II * red_factor_typical_emissions
0.252 Stage IIIA  * red_factor_typical_emissions
0.025 mininimum of (Stage IIIB, ef_factor previous years)
0.025 mininimum of (Stage IV, ef_factor previous years)

Table 6 Reduction factors for typical emissions for pre-Stage IIIB emission limits for 19 
to 75 kW CI engines 

red_factor_typical_emissions

original
19-37kW
37-56kW
56-75kW

NOx

0.8
0.72
0.8
0.88

PM Comments

0.7 Source: CECE-CEMA-EUROMOT, 2006
0.56 adapted to align with JRC calculation
0.56 adapted to align with JRC calculation
0.63 adapted to align with JRC calculation

Monetized estimate of environmental impacts of options for small tractors 

Based on the above calculated emissions in tons and the external costs for NOx and PM we 
calculate  the  monetized  values  of  the  differences  in  emissions  between  the  reference  option 
and option 1-exemption and option 0b-old tractors remaining. We considered the 2012-2030 
period and discounted monetized emissions to 2008 at a discount rate of 4%. The table below 
illustrates the results.  

Table  7  Monetized  emission  impacts  for  option  1  and  option  0b  for  small  tractors 
(million EUR) 

The figures in the table show negative values as these are real environmental costs. Each of 
the  options  increase  the  emission  compared  to  the  theoretical  (unrealistic)  reference  option. 
Exempting  special  tractors  for  5  years  costs  € 120  million  more  in  emissions  than  having 
small tractors complying from the foreseen dates. Keeping the emission standard as foreseen, 
but not having compliant tractors ready will however cost € 193 million due to the old tractors 
that are kept in service. 

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3.6.4.4 Multi criteria analysis 

There are no technical compliance costs as compliance is technically unfeasible. We analyse 
therefore  not  the  efficiency  of  the  options.  We  give  however  for  the  different  options  an 
overview of the different options. 

Category 

Option 0 

Option 1 

Other elements 

Functioning 
the 
market 

of 
internal 

No specific issues identified 

No specific issues identified 

Competitiveness, 
and 
trade 
investment flows 

Could  lead  to  decreased  competitiveness 
of  European  orchards  or  vineyards 
compared to foreign competitors 

Would solve issues of competitiveness 

As  T2  tractors  are  a  specific  European 
product (see JRC report, p 90), trade is not 
an issue for this equipment type 

Operating 
and 
business 

costs 

costs 
of 

Would  lead  to  increased  operation 
costs  for  orchards  and  vineyards 
due 
longer  maintenance  of 
to 
special tractors  

Would 
increases 

solve 

issues  of 

cost 

Administrative 
burden 
to 
companies/SME’s 

Most  vineyards  and  orchards  are 
SMEs  producing  special  tractors 
would disappear from the market 

Would solve issues 

Property rights 

No changes expected 

No changes expected 

and 

Innovation 
technological 
development 

lead 

Could 
compliance  at 
customer-oriented 
information provided by industry 

to  more  R&D  for 
the  expense  of 
no 
R&D; 

Could  lead  to  more  R&D  for  compliance 
at  the  expense  of  customer-oriented  R&D 
but  less  so  than  under  option  0;  no 
information provided by industry 

Consumer 
households 

and 

Will  lead  to  increased  wine  price,  but  no 
information  available  that  would  allow  to 
quantify this impact 

Would solve issues 

Specific  regions, 
sectors or workers 

Will  have  negative  impact  in  rural 
areas  and  in  the  sector  involved  in 
the production of special tractors 

Would solve issues 

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countries 
international 

Third 
and 
relations 

Impact  on  public 
authorities, 
including 
administrative 
costs 

on 

Impact 
macroeconomic 
environment 

No specific issues identified 

No specific issues identified 

No specific issues identified 

No specific issues identified 

Would solve issues 

million 

With  EU27  GDP  estimated  at 
12,870,560 
EUR 
(EUROSTAT), 
estimated 
compliance  costs  and  employment 
effects  do  not  have  a  significant 
macroeconomic impact 

Employment  and 
labour markets 

Localised and temporary job losses 
of a few thousand units 

Would solve issues 

Standards 
and 
rights  related  to 
job quality 

Social 
inclusion 
and  protection  of 
particular groups 

No specific issues identified 

No specific issues identified 

No specific issues identified 

No specific issues identified 

Public  health  and 
safety 

Loss of 193 million EUR compared 
to theoretical option 0 

loss of 121 million EUR compared 
to theoretical option 0 

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Annex X – Relevant sections of the ARCADIS SME Test report 
2010 

"SME  Test  Study  and  IA  on  possible  options  for  reviewing  the  Directive  97/68/EC 
relating  to  NRMM  –  Reviewing  Directive  97/68/ECEmissions  from  non-road  mobile 
machinery" 

EXTENDED EXECUTIVE SUMMARY 

The  aim  of  this  study  was  to  complement  the  existing  Impact  Assessment  study  related  to 
Directive  97/68/EC  (as  amended)  with  a  detailed  assessment  of  the  impacts  the  identified 
policy options may have on SMEs. 

We have focused our research on the following categories of stakeholders: 

–  the manufacturers of engines, equipment and components 

–  professional end users of the equipment. 

Based upon the results of the IA study, there was no indication that other SMEs are affected 
significantly by this Directive. Therefore, in our proposal, we had proposed that the focus of 
the  study  would  be  on  these  categories.  The  most  striking  conclusion  of  this  study  is  that, 
despite  the  very  important  efforts  undertaken  by  the  project  team,  less  than  10  individual 
tractor manufacturers (abstracting from the shipbuilders) have been identified unequivocally 
as SMEs and have contributed actively to the study. 

The number of SMEs identified amongst professional end users was much higher, but really 
new  information  was  only  provided  by  the  following  sectors:  independent  winegrowers, 
cableway and ski lift operators, and by the inland waterways sectors. 

There are several possible explanations to the large difference with previous estimates of the 
number of SMEs: 

–  The discrepancy between the Commission’s definition of SMEs and the public perception 

of what an SME is. 

–  SMEs  feel  that  their  specific  interests  are  not  always  well  represented  by  the  sector 
federations. Therefore, we have also used alternative communication channels but this has 
resulted in very limited response rates as well. 

–  For  SMEs,  the  burden  of  responding  actively  to  the  questionnaire  is  often  too  high 
compared to the (perceived) benefits of doing so. This is certainly the case for professional 
end users. 

However,  if  a  less  restrictive  definition  of  SMEs  would  be  used  in  future  work,  this  would 
ignore  two  essential  problems  of  SMEs  that  are  solved  with  mergers  and  acquisitions  (high 
fixed costs and difficult access to capital). Moreover, a change of the scope of the definition 
could lead to confusion on the side of the industry. 

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Allowing  longer  response  times  could  lead  to  a  slightly  higher  response  rate,  but,  in  this 
study,  the  extension  of  the  contract  has  not  had  a  significant  impact  on  the  actual  response 
rate.  Drafting  a  questionnaire  in  several  languages  (or  allowing  SMEs  to  answer  in  their 
mother tongue), would have huge implications in terms of translation budget and in execution 
time. Finally, there are limits to how far we can go in simplifying the questionnaires without 
missing the whole point of the study. 

The most important policy conclusions are: 

… 

–  Virtually  all  tractor  manufacturers  that  have  been  interviewed  in  the  course  of  the  study 
have  expressed  concerns  with  respect  to  the  rapid  succession  of  emission  stages  (rather 
than  the  absolute  values  of  the  imposed  emission  limits).  This  affects  their  business 
negatively through the following channels: (a) shorter production runs to cover fixed costs 
(b) the costs linked to teething problems of new equipment. 

–  The most important concern raised by producers of agricultural machinery was not the next 
stage in the Directive, but the homologation process, and more specifically: the length of 
this process, the lack of international standardisation and the fact that even minor changes 
require rerunning a complete homologation process. 

–  Regarding  the  impact  of  the  Directive  on  tractors  used  in  orchards,  no  information  has 
been  obtained  from  the  relevant  professional  organisation  of  end  users.  Regarding  the 
impact on tractors used in vineyards, the European sector federation has confirmed that all 
independent  winegrowers  are  SMEs,  and  the  vast  majority  are  micro-enterprises.  Our 
calculations indicate that: 

–  the  cost  for  redesigning  vineyards  to  accommodate  stage  IIIB  and  IV  compliant 
tractors would be several orders of magnitude larger than the environmental cost 
of not exempting the special tractors from stage IIIB and IV; 

–  the increased maintenance cost following from keeping old tractors in use would 
be an order of magnitude larger than the environmental cost of not exempting the 
special tractors from stage IIIB and IV. 

This study has considered the two following generic mitigating measures: 

…. 

–  An  extension  of  the  duration  of  the  flexibility  scheme  would  allow  small  equipment 
manufacturers  to  overcome  the  long  time  lag  between  the  development  of  a  new  engine 
and  the  full  integration  of  this  new  engine in the equipment  (including  homologation for 
use on the road); 

Most tractor manufacturers that we have interviewed are aware of the flexibility scheme, but 
not all seem keen on using it. One manufacturer has raised the specific concern that the engine 
options for reviewing the Directive 97/68/EC relating to NRMM suppliers may not always be 
able to supply engines complying with the previous stage of the Directive. 

… 

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3.4 Consultation with the identified target group 

The  questionnaires  have  been  sent  out  after  the  inception  meeting  with  the  Commission 
services. However, as our experience with the IA study had shown that few stakeholders have 
the resources to provide comprehensive answers to this type of questionnaire, the project team 
has proposed to concentrate on two groups of selected stakeholders: 

–  First,  we  have  contacted  the  European  industry  associations  that  have  been  consulted 
during  the  IA  study:  AECC,  CCNR,  CECE,  CEMA,  CER,  EBU,  EGMF,  ESO,  ISMA, 
ORGALIME, UITP, UNIFE, VDMA and EUROMOT. 

–  Second, we had proposed to single out a representative group of SMEs that is willing and 
able to cooperate on this study. The selection of this group would take place in consultation 
with the European industry associations and with UEAPME. 

We aimed at 2 SMEs per main NRMM sector used in the IA study. 

Our  intention  was  to  organise  round  table  discussions  with  those  selected  stakeholders. 
Experience  with  the  IA  study  had  shown  that  this  is  the  most  effective  means  to  elicit  a 
maximum  of  information.  We  proposed  to  organise  six  half-day  round  table  discussions, 
focussing on the most relevant sectors. Relevant sector are those where many SMEs are active 
as a manufacturer or as a professional user of the equipment. 

We  also  proposed  to  approach  the  SMEs  via  in-depth  telephone  interviews  and  mail 
exchange,  as  it  is  difficult  to  organise  meetings  with  them  in  Brussels.  A  round  table 
discussion has been asked with UEAPME. 

3.5 General development of the consultation process 

Table  1  gives  an  overview  of  all  the  contacts  that  have  been  made  with  stakeholders. 
Although  the  questionnaires  have  been  sent  out  immediately  after  the  signature  of  the 
contract, and although there has been a steady follow up, the general response rate has been 
very low. We will discuss the specific reasons chapter per chapter, but the main reason is that, 
for most sectors covered by the NRMM Directive, there are very few (if any) SMEs. One of 
the  reasons  why  the  relative  importance  of  the  number  of  SMEs  might  have  been 
overestimated  in  the  past  is  that  the  criterion  of  autonomy  in  the  definition  is  often 
overlooked: companies that fulfil all other criteria (headcount and turnover or balance sheet 
total) can still not be considered SMEs if they are part of a larger group that does not meet the 
criteria.  Moreover,  the  sector  of  internal  combustion  engines  has  recently  gone  through  a 
consolidation  phase,  and  the  full  extent  of  the  reorganisation  of  the  sector  is  now  only 
becoming clear. 

Effects on SMEs are therefore generally limited to the professional end users, who are much 
less familiar with the NRMM Directive. 

Upstream in the product chain, the manufacturers of exhaust emissions control equipment are 
an  important  actor.  The  sector  federation  AECC  does  not  count  any  SMEs  amongst  its 
members, but has referred us to some individual companies that are not members of AECC. 
Amongst  these,  one  SME  has  been  identified,  which  has  been  contacted  individually. 
However, this contact has not led to the identification of information that could be useful for 

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the  purposes  of  the  current  study.  CLEPA,  the  European  Association  of  Automotive 
Suppliers, has informed us that this subject was of no interest to them. 

Therefore,  our  invitation  to  organise  round  table  meetings  has  met  a  very  low  positive 
response rates. We have been able to hold several telephone interviews who turned out to be 
very informative, but also less than we had hoped for.  

As explained above, in parallel with the sector organisations, in order to reach SMEs that are 
not affiliated to sectoral associations, we had taken several steps in parallel: 

–  We  have  contacted  UEAPME,  the  European  Association  of  Craft,  Small  and  Medium-
sized  Enterprises.  UEAPME  has  sent  out  the  questionnaires,  but  has  pointed  out  that  it 
does  not  work  directly  with  SMEs,  but  with  its  members,  which  are  national  horizontal 
SME organisations. This means that 1) UEAPME cannot send the questionnaires directly 
to SMEs or invite them directly to attend meetings in Brussels 2) UEAPME does not know 
whether  or  not  its  members  have  national  branch  organisations  specialised  in  the  sectors 
concerned  by  the  NRMM  and  the  Noise  Directives.  Therefore,  UEAPME  cannot  target 
these SMEs specifically. Because the NRMM and the Noise Directives are very specific, it 
is not possible for UEAPME to speak in the name of its members on this issue. UEAPME 
has also expressed concerns with respect to the representativeness of any response because 
of (1) the language barrier some SMEs face (2) the short deadline. This channel has not led 
to any specific response. 

–  Thanks to the kind cooperation of Mr Berck and Németh of DG ENTR, we have launched 

the questionnaires through the Enterprise Europe Network on 03 June. 

This channel has not led to any specific response. 

–  Taking  into  account  that  many  equipment  types  that  are  covered  by  the  Noise  Directive 
contain engines that are covered by the NRMM Directive, we have taken a sample of more 
than 80 companies out of the noise database that the Commission is managing according to 
Article 16(4) of Directive 2000/14/EC. This sample has led to the identification of just 2 
SMEs.  As  already  pointed  out  above,  many  “small”  companies  do  not  fall  under  the 
definition of SMEs because they fail to satisfy the criterion of autonomy. 

–  We have also contacted associations of local authorities (Eurocities and CEMR), who are 
important  end  users  of  some  machine  types  covered  by  the  Directive.  On  22  July,  the 
CEMR has informed us that they would not be able to provide input on this issue. 

On  28  May,  the  Commission  services  have  sent  us  a  list  of  Italian  SMEs  that  they  had 
received from an Italian stakeholder. All these enterprises have been contacted immediately, 
and  some  individual  responses  were  received.  On  29-30  June,  reminders  (per  e-mail  and 
phone) were sent to all individual companies that had not yet responded. 

On  30  June,  CECE  has  handed  over  a  list  of  industry  directories  that  could  be  useful  in 
identifying  individual  SMEs:  www.intermat.fr  ;  http://www.bauma.de/  ;  www.smopyc.es  ; 
www.lectura.de ; ANMOPYC ; www.khl-group.com . 

These directories contain several thousands of companies. We have taken a targeted sample of 
170  companies  in  order  to  identify  SMEs  that  are  not  members  of  the  sector  associations. 
Based upon publicly available information, we have concluded that 71 of these companies do 

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not  fall  within  the  EC  definition  of  SMEs.  All  other  companies  have  been  contacted 
individually. 

PNEUROP  has  informed  us  that,  to  the  best  of  their  knowledge,  none  of  their  members  is 
actually  an  SME.  However,  they  have  provided  us  with  a  (short)  list  of  manufacturers  that 
they think may be SMEs but that are not members of PNEUROP. These manufacturers have 
been  contacted  individually.  On  15  September,  CECE  has  also  handed  over  a  list  of 
companies that produce drill rigs. They have all been contacted individually. In some cases, 
individual respondents to the questionnaires have also indicated that some of their competitors 
may  well  fall  within  the  EC  definition  of  SMEs.  These  companies  have  been  contacted 
individually. Reminders have been sent. 

On 12 October 2009, the contract was formally amended, allowing an extension until the end 
of  March  2010.  We  have  used  this  extension  to  send  reminders,  both  to  professional 
organisations and to the companies that had been contacted on an individual basis. This has 
unfortunately not led to a significant increase in the response rate. 

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8  Landbased  compression  engines:  Special  agricultural  tractors  used  in  vineyards  and 
orchards 

8.1 Impact on producers 

The IA study had concluded that 45% of the tractor market is in hands of SMEs. 

Discontinuation of the production of this type of tractors would put them out of business. 

T2  (narrow  wheeled)  tractors  and  C2  (narrow  tracked)  tractors  are  produced  in  Italy  and 
Germany only. After thorough investigation, the 3 manufacturers that were indicated as SMEs 
turned out to have a workforce between 250 and 300 people38. Therefore, they do not qualify 
as medium enterprises according to the EC definition. We will therefore no longer pursue the 
issue of the T2 and C2 tractors in this section. 

The T4.1 (high clearance) tractors are a typically French product. 95% of the market is held 
by Bobard and Tecnoma. Bobard is an SME, while Tecnoma is part of the Exel group. The 
remaining 5% is held by very small producers, who sell at most 10 to 20 tractors per year. The 
market  has  gone  through  a  consolidation  phase  in  the  1990s,  which  is  indicative  of  the 
existence  of  economies  to  scale.  According  to  Bobard,  this  market  is  a  small  one.  Industry 
sales amount to 500-600 units per year. 90% of these are sold in France while the remainder is 
exported to Switzerland or to Central and Eastern European countries. 

Sales (in units) at the industry level have decreased by 12% in 2007-2008 and by 12-15% in 
2009. This decrease is largely due to the on-going economic recession, and not to structural 
factors. 

On the contrary, due to an ongoing consolidation of the viticulture sector, the average surface 
area of individual enterprises is increasing. Clients are requesting products of ever increasing 
precision. Thus, while the number of tractors sold is decreasing, the unit price of tractors is 
increasing.  

Actually,  demand  can  be  expected  to  increase  in  the  future.  In  France,  the  Grenelle  de 
l'Environnement  has  requested  a  decrease  of  pesticide  use  in  agriculture  with  50%39,  which 
should  lead  to  increased  mechanical  weeding  (and  thus  to  an  increase  in  demand  for  high 
clearance tractors). 

Besides Bobard, we have identified 3 other producers of high clearance tractors. One of them 
declined to allow an interview due to time constraints. This leaves us with three case studies 
based on telephone interviews. 

8.1.1 Case study 1 

Bobard produces only high clearance tractors (T4.1) which are used in narrow vineyards. 

According  to  Bobard,  horses  are  the  only  technical  alternative  to  this  type  of  tractors. 
Currently,  Bobard  sells  about  250  tractors  per  year,  in  5  different  models.  With  an  average 

38 
39 

Personal communication by Dr Billi (24 November 2009). 
see: http://www.legrenelle-environnement.fr/grenelle-environnement/IMG/pdf/Fiche_6.pdf 

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lifetime of 3 years, this means that fixed development costs have to be amortized over a series 
of 150 tractors. 

The  large  number  of  models  is  explained  by  the  diversity  of  terrain  conditions  (relief, 
plantation width) on which vineyards are built. 

The relative share of fixed costs is increasing through time. The development costs linked to 
the integration of an engine complying with a new stage of emission standards correspond to 
one  full  time  project  engineer  during  one  year  (to  which  one  has  to  add  the  homologation 
costs,  which  vary  from  12  000  to  15  000  EUR,  depending  on  the  tractor  type).  These 
resources  are  then  unavailable  to  meet  new  technical  requirements  from  the  clients.  Bobard 
can  manage  the  development  of  3  new  projects  per  year.  Each  new  tractor  type  requires  23 
months as a prototype. 

The  typical  sales  price  of  a  T4.1  tractor  sold  by  Bobard  lies  in  the  range  70  000  to  85  000 
EUR. 

The  typical  economic  lifetime  (in  use)  a  T4.1  tractor  is  7  to  10  years.  If  a  tractor  is  used 
beyond 
increase  from 
(approximately) 1500-2000 EUR per year to 3000-4000 EUR per year. 

this  period,  annual  maintenance  costs  can  be  expected 

to 

Bobard has suggested to have a longer time interval between subsequent stages. Bobard does 
not take advantage of the flexibility scheme. Their  main  motivation  for  not  doing  so  is  that 
they are uncertain whether their engine suppliers will be able to supply engines that comply 
with the previous stages of the Directive, whilst they have already started the production of 
engines  complying  with  the  next  stage.  With  a  longer  time  interval  between  subsequent 
stages, the product cycles of engine and tractor producers would be synchronised. 

Bobard estimates that the homologation of a new tractor for use on the road requires 7 to 8 
weeks  of  internal  work,  and  between  15  and  23  weeks  before  approval  of  the  DRIRE  is 
obtained. 

8.1.2 Case study 2 

VSP  Construction  is  a  family  business  in  the  category  “micro  enterprises”.  90%  of  their 
turnover (1 200 000 EUR) originates from the sale of T4.1 tractors. This corresponds to 10-15 
tractors per year. Occasionally, they also sell tracked tractors. 

6 employees (out of a total of 17) are directly involved in the production of T4.1 tractors. 

The  production  of  the  frame  is  subcontracted  to  their  sister  company  C2MH  –  this 
corresponds to 2 indirect jobs. 

The vast majority of their sales take place in France; although they also occasionally sell on 
the Belgian market. 

Their principal activity consists in the production of customized high clearance tractors. This 
is  not  limited  to  applications  in  vineyards;  their  clientele  consists  of  firms  who  do  not  find 
suitable solutions in the mass market. Non-vineyard applications include tractors for picking 
up  algae  under  the  water  level  or  for  picking  up  boulders  from  fields.  However,  vineyard 
applications still constitute 90% of their turnover. Another competitive advantage is a shorter 
delivery  time  than  some  of  their  competitors.  A  disadvantage  compared  to  larger 
manufacturers  is  that  the  share  of  development  costs  is  relatively  high  (one  sixth  of  the 

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payroll). However, their activity is not capital intensive and depreciation of physical capital is 
not an important cost category40. 

On  average,  this  company  sells  its  tractors  at  a  unit  price  of  100  000  EUR,  which  is 
significantly higher than the prices quoted by Bobard. This confirms that this producer does 
not compete on price. 

Their main concern is related to the homologation costs. All tractors using public roads (even 
for  very  short  trips)  have  to  be  homologated41.  Every  time  a  new  engine  is  installed,  the 
producers  need  to  go  through  the  whole  homologation  procedure,  even  if  the  tractors  are 
otherwise identical. The development of a new tractor requires on average 3 to 4 months. The 
test  (pollution,  brakes…)  are  undertaken  under  the  surveillance  of  UTAC,  who  prepare  the 
homologation  dossier  for  the  DRIRE.  This  requires  approximately  10  working  days. 
Although, in theory, the homologation file should be processed within 45 days, this can take 
up to 1 year in practice. 

As it is allowed to sell non-homologated tractors as long as they do not use public roads, some 
vineyards use trucks to move the tractors on the public roads. However, this solution requires 
the winegrower to obtain a driving licence for trucks. Moreover, it is far from obvious to load 
and unload tractors. Therefore, for short distances, users prefer to take the road. 

VSP’s  engines  suppliers  are  already  capable  of  supplying  stage  IV  compliant  engines,  at  a 
price  that  is  50%  higher  than  engines  that  meet  the  current  emission  limits.  As  already 
reported in the JRC report and the IA study, these engines take much more place and limit the 
manoeuvrability of tractors in the vineyards. 

As  a  supplier  of  customized  products,  VSP  feel  that  they  cannot  adapt  their  designs  pro- 
actively, as they cannot anticipate the specific client needs that will arise in the future. VSP 
has no specific comments on the NRMM Directive in itself – for them, the priority should be 
a simplification of the homologation procedure (which falls outside the scope of this study). 
They  point  out  that,  as  end  users  sometimes  adapt  the  tractors  themselves,  without  being 
subject to the slightest control, these heavy and costly procedures are circumvented anyway. 

8.1.3 Case study 3 

FREMA is a small company with 12 employees (2 of which are working on development). 

They  have  a  turnover  of  5  million  EUR,  which  is  uniquely  composed  of  high  clearance 
tractors.  Their  annual  production  corresponds  to  50  tractors,  which  are  sold  at  a  price  that 
varies between 50 000 and 100 000 EUR, depending on the model. 

Their  main  competitive  advantages  compared  to larger  producers  are  their  higher  flexibility 
and proximity to the clients. They sometimes produce tailor made tractors, but most of their 
production is made in series. 

Homologation of new machines is a major concern. The tests by UTAC cost 2 500 EUR. The 
subsequent  approval  of  the  file  by  the  DRIRE  can  take  between  6  months  and  a  year.  As 
already pointed out above, it is legally possible to sell tractors that have not been homologated 
if they do not circulate on the roads. However, in FREMA’s experience, clients do not accept 
this  possibility.  An  important  problem  is  that  the  French  homologation  for  the  road  is  not 
recognized in the countries to which they export (such as Germany and Austria). This is due 

40 
41 

No concrete figure has been given. 
By the DRIRE, the Directions Régionales de l'Industrie, de la Recherche et de l'Environnement. 

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to  different  standards  (for  instance,  with  respect  to  the  brakes).  Every  time  a  new  engine  is 
installed in a tractor, the whole homologation procedure has to start all over again. 

FREMA has confirmed the usefulness of the flexibility mechanism. 

The high clearance tractors for vineyards are sold uniquely in France. FREMA also sells high 
clearance  tractors  for  cereals  (seed  corn,  sunflowers,  tobacco).  These  are  also  exported, 
mainly  to  Europe,  but  also  to  Latin  America  (where  no  regulations  on  emissions  exist). 
Exports outside the EU correspond to 4-5 tractors per year (sales of 300 000 EUR). This firm 
is thus heavily dependent on the EU market. 

8.2 Impacts on professional users 

For the impact on end users in the agricultural and vineyard sector, we have contacted COPA-
COCEGA. A meeting to discuss the approach for the consultation has taken place on 14 July. 
As  no  response  had  been  received  from  COPA-COGECA  by  the  end  of  September, 
ARCADIS has submitted a thoroughly simplified questionnaire to COPA- COGECA with a 
renewed request to forward this questionnaire to the members. No answer has been provided 
to date. 

Concerning the impact on vineyards, we have consulted with the European Confederation of 
Independent  Winegrowers  (CEVI).  CEVI  represents  European  independent  winegrowers.  In 
the  case  of  independent  winegrowers,  the  whole  process  (vine  growing,  harvesting, 
winemaking and wine selling) is fully vertically integrated. CEVI represents 9000 members. 
The  total  number  of  independent  winegrowers  in  Europe  is  estimated  to  be,  in  total,  from 
180,000  to  200,000.  A  large  number  of  these  winegrowers  produce  only  for  household 
consumption,  but  no  reliable  estimate  exists  of  the  number  of  winegrowers  who  sell  their 
products. 

The  large  majority  of  independent  winegrowers  are  micro-enterprises,  generally  family 
owned. Only a very small minority are small enterprises. In France, the “very big estates” of 
independent  winegrowers  account  for  2.5  %  of  all  the  independent  winegrowers’  estates, 
where  “very  big”  refers  to  estates  of  10  employees  on  average  and  a  surface  of  84.4  ha42. 
CEVI reckons that the proportion is roughly the same in the other countries. 

None of these enterprises are medium. 

As pointed out in the IA study, in the absence of stage IIIB and IV tractors, the end users have 
two options: 

–  Redesign existing vineyards to fit compliant tractors 

–  Maintain the old tractors until a technical solution has been found for new tractors 

Let us discuss the economic implications of both in turn. 

8.2.1 Redesign of existing vineyards 

In the case of vineyards, it is useful to first consider the possibilities for public support that 
exist for restructuring existing vineyards: 

Since the entry into force of Regulation (EC) N°1493/1999, recently amended by Regulation 
(EC)  N°  479/2008,  the  common  organisation  of  the  market  in  wine  has  provided  for  the 

42 

The average independent winegrower’s estate in France is 12.3 ha 

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possibility  for  Member  States  to  give  support  for  the  restructuring  and  conversion  of 
vineyards. 

Chapter  1  of  the  Regulation  lays  down  the  rules  governing  the  attribution  of  Community 
funds to Member States and the use of those funds by Member States through national support 
programmes  (hereinafter  referred  to  as  support  programmes)  to  finance  specific  support 
measures to assist the wine sector. 

According to Article 4, Member States shall be responsible for the support programmes. 

According to Article 11 of Regulation (EC) N° 479/2008, the objective of measures relating 
to  the  restructuring  and  conversion  of  vineyards  shall  be  to  increase  the  competitiveness  of 
wine producers. 

Support  for  restructuring  and  conversion  of  vineyards  may  only  cover  one  or  more  of  the 
following activities: 

(a) varietal conversion, including by means of grafting-on; 

(b) relocation of vineyards; 

(c) improvements to vineyard management techniques. 

The normal renewal of vineyards which have come to the end of their natural life shall not be 
supported. 

Support for restructuring and conversion of vineyards may only take the following forms: 

(a)  compensation  of  producers  for  the  loss  of  revenue  due  to  the  implementation  of  the 
measure; 

(b) contribution to the costs of restructuring and conversion. 

Compensation  of  producers  for  the  loss  of  revenue  may  cover  up  to  100  %  of  the  relevant 
loss.  The  Community  contribution  to  the  actual  costs  of  restructuring  and  conversion  of 
vineyards shall not exceed 50 %. In regions classified as convergence regions, the Community 
contribution to the costs of restructuring and conversion shall not exceed 75 %. 

Summarising the text above, Member States could thus decide to provide financial support for 
the adaptation of the row width of vineyards in order to allow the use of tractors43. 

However,  it  is  not  clear  whether  financial  compensation  would  be  enough  to  compensate 
winegrowers for the other drawbacks of redesigning the vineyards. Indeed, CEVI has argued 
that in vine growing, a higher planting density guarantees a better quality of the grapes, and 
that this explains why the European Community supports replanting with a higher density44. 
Redesigning  the  vineyards  to  better  accommodate  special  tractors  would  run  counter  to  this 
objective. However, the relation between planting density and grape quality is controversial45. 

We do not think it would be worthwhile to further deepen this issue here, as it is of relatively 
minor importance compared to the financial implications of adapting the row widths one more 
time. Indeed, in the first seven years of application of the scheme, 400 to  465 million EUR 
were allocated annually to restructuring and conversion measures46. 

43 
44 
45 

46 

Personal communication from DG AGRI. 
However, in the text of the Regulation (EC) N° 479/2008, no explicit reference to density is made. 
Cesare Intrieri and Ilaria Filippetti. Proceedings of the ASEV 50th Annual Meeting, Seattle, WA, June  
19-23, 2000, pp 296-308 
http://ec.europa.eu/agriculture/markets/wine/prod/depens.pdf 

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The IA study had shown a total environmental cost of 120 million EUR in case the special 
purpose  tractors  would  be  exempted  from  stage  IIIB  and  stage  IV.  This  figure  is  obviously 
very  low  compared  to  the  financial  implications  of  a  redesign  of  existing  vineyards  and 
orchards.  Of  course,  not  all  existing  vineyards  would  need  to  be  redesigned.  However,  the 
figure above does suggest that the cost of adapting the row width can be significantly higher 
than the environmental cost of exempting the special purpose tractors from stage IIIB and IV. 

Moreover, adapting the row width in itself would lead to the release of carbon, which is also 
an environmental cost. CEVI admits that no independent estimate of these releases exists. 

8.2.2 Maintenance of old tractors 

In  Section  8.1  we  had  reported  that  if  a  high  clearance  tractor  is  used  beyond  its  economic 
lifetime,  annual  maintenance  costs  can  be  expected  to  increase  from  1 500-  2 000  EUR  per 
year to 3 000 – 4 000 EUR per year. 

For illustrative purposes, we assume that the cost increase is 2 500 EUR per year per tractor, 
and that all special tractors face the same increase in maintenance costs as the high clearance 
tractors. To remain consistent with the IA study, we assume that a technical solution can be 
found  5  years  after  the  planned  introduction  date  of  the  next  emission  stage,  that  a  total  of 
25 600 units are sold per year in the EU and that a discount rate of 4% applies. 

For  the  T4.1  tractors,  based  upon  the  response  received  during  the  consultation,  we  assume 
that 400 units are sold per year. 
To  the  best  of  our  knowledge,  no  data  on  the  sales  of  C2  tractors  are  publicly  available47. 
Thus,  in  total  we  assume  that  26  000  special  tractors  are  sold  per  year.  We  assume  that  all 
sales  correspond  to  replacement  sales  and  that,  once  the  technical  solution  has  been 
developed, old tractors are replaced at a rate of 26 000 units per year. 

The table below gives then, for each year after the planned introduction of stage IIIB until all 
“old” tractors have been replaced by stage IIIB compliant tractors, the increase in the number 
of  tractors  that  are  kept  in  use  beyond  their  economic  lifetime  and  the  implied  extra 
maintenance costs at the EU level. 

Table 5: Extra maintenance costs for special tractors used beyond economic lifetime 

Year 

Number of tractors kept in use   Extra cost per year 

1 

2 

3 

4 

5 

6 

7 

26 000 

52 000 

78 000 

104 000 

130 000 

104 000 

78 000 

65.000.000 

130.000.000 

195.000.000 

260.000.000 

325.000.000 

260.000.000 

195.000.000 

47 

This has been confirmed in a personal communication by Dr Krasenbrink of the JRC 

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8 

9 

52 000 

26 000 

130.000.000 

65.000.000 

The net present value of these costs (discounted to the planned introduction of stage IIIB) is 
1 339  million  EUR.  This  is  an  order  of  magnitude  higher  than  the  environmental  benefits 
linked to not postponing stage IIIB with 5 years (120 million EUR). 

Thus, even if actual higher maintenance cost would be significantly lower than suggested by 
the manufacturers, the costs of not postponing stage IIIB would still be much higher than the 
benefits. 

8.3 Conclusion 

On  the  producers’  side,  no  SMEs  are  involved  in  the  production  of  special  agricultural 
tractors, except in the niche of high clearance tractors. This market represents less than 2% of 
the total market for special tractors in Europe. The following points are noteworthy: 

-  Although  the  tractor  manufacturers  we  have  interviewed  know  that  the  machines  they 
produce are regulated by the NRMM Directive, some of them did not appear to understand 
fully the implications of the next stage in the Directive. Some of the smaller companies are 
not  affiliated  to  professional  associations,  and  were  not  aware  of  the  on-going  legislative 
process  until  the  phone  interview.  It  was  therefore  sometimes  difficult  to  keep  the  phone 
interview focused on the subject at hand. 

- Maybe because of this lack of information, the most important concern raised was not the 
next stage in the Directive, but the homologation process. The points raised by the producers 
of  special  tractors  were  almost  identical  to  those  discussed  in  Chapter  7:  the  length  of  the 
process, the lack of international standardisation and the fact that even minor changes require 
rerunning a complete homologation process. The possibility to sell non-homologated tractors 
and to use trucks to move them on the road was rejected as unrealistic. One manufacturer has 
pointed  out  that  the  homologation  procedures  are  sometimes  circumvented  by  the  end 
users, who adapt tractors to their own needs without any external control. 

- Most manufacturers that we have interviewed are aware of the flexibility scheme, but not all 
seem  keen  on  using  it.  One  manufacturer  has  raised  the  specific  concern  that  the  engine 
suppliers may not always be able to supply engines complying with the previous stage of the 
Directive48. 

-  This  very  small  market  is  further  divided  in  subniches  determined  by  the  diversity  of 
terrain conditions on which vineyards are built. This implies that producers have to amortize 
fixed  development  costs  (including  homologation  costs)  over  very  small  series.  The  rapid 
succession of stages in the Directive exacerbates these problems. At least one producer has 
suggested introducing longer time intervals between successive stages of the Directive. 

Regarding the impact on orchards, no information (even indicative) has been obtained from 
the relevant professional organisation. 

Regarding  the  impact  on  vineyards,  the  European  sector  federation  has  confirmed  that  all 
independent  winegrowers  are  SMEs,  and  the  vast  majority  are  micro-enterprises.  Using 

In other applications, engine manufacturers keep on producing engines complying only with previous  

48 
stages of the Directive, but these engines are exported to unregulated regions of the world. We have to  
keep in mind that this chapter treats a niche market, where this outlet does not necessarily exist. 

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figures  on  existing  public  support  schemes,  we  have  argued  that  the  cost  for  redesigning 
vineyards to accommodate stage IIIB and IV compliant tractors would be several orders of 
magnitude larger than the environmental cost of not exempting the special tractors from 
stage  IIIB  and  IV.  Moreover,  such  a  policy  would  run  counter  to  the  existing  policy  to 
stimulate a higher plating density. 

The  alternative  option  would  be  for  vineyards  to  keep  old  tractors  in  use  beyond  their 
economic lifetime. Our calculations suggest that the increased maintenance cost following 
from this option would be an order of magnitude larger than the environmental cost of not 
exempting  the  special  tractors  from  stage  IIIB  and  IV.  As  another  way  to  put  these 
compliance costs in perspective, one could note that they are of the same order of magnitude 
as the compliance costs linked to the Euromot proposal for inland waterway engines. 

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Annex XI - Fleet and annual sales of tractors 

Annual  sales  estimates  per  tractor  category  and  power  class  (year  2005, 
EU15) 

19-37 

37-56 

56-75 

Power
(kW) 

Total Nr49 

Agricultural 
tractors 

163 000 

3 260 

32 600 

48 900 

T2 

C2 

24 439 

5 004 

7 690 

10 338 

1 128 

10 

711 

407 

T4.1 

550 

Total number of tractors in use per tractor category and power class (year 
2005, EU15) 

Total  engines 
in use 

Agricultural 
tractors 

Total Nr 

19-37 

37-56 

56-75 

2 500 420 

32 600 

521 600 

782 400 

Percentage 

1,3 

20,9 

31,3 

Source: JRC / CEMA 

49 

The total number includes also tractors of engine power categories above 75 kW. 

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Annex XII – Estimation of environmental impacts 

This  Annex  presents  the  way  the  environmental  impacts  mentioned  in  the  current  Impact 
Assessment report have been estimated, based on the results of the JRC and Arcadis reports. 
The  latter  two  reports  contain  several  figures  on  the  environmental  impacts  of  some  of  the 
options.  These  impacts  are  given  relative  to  the  hypothetical  scenario,  whereby  compliant 
NTTs would be placed on the market by the dates foreseen in the current Regulation. In this 
IA  report,  other  options  have  been  investigated  and  the  reference  chosen  was  option  1  (the 
baseline scenario), where no compliant NTTs can be put on the market and the use of older 
NTTs is prolonged.  

The following steps have been carried out: 

•  JRC  report  mentions  for  Option  3  additional  emissions  of  3,5  kt  PM  and  33  kt 

NOx 

•  The Arcadis report mentions for Option 3 environmental costs of 48 M€ for PM, 

72 M€ for NOx 

•  This report also mentions for Option 1 environmental costs of 60 M€ for PM, 134 

M€ for NOx 

•  The cost factors used can therefore be calculated, based on the above figures for 

Option 3 

•  These cost factors can be applied to calculate the additional emissions of Option 1 

•  The  additional  emissions  of  Option  2  were  estimated  by  taking  a  proportionate 

share of those of Option 3 

•  Environmental costs of Option 2 can be estimated by multiplying the emissions by 

the cost factors 

•  The JRC report mentions, for option 4, yearly additional emissions of 0,7 kt PM 

and 6 kt for NOx 

•  The total additional emissions are estimated by multiplying by 38 (for 2012-2050) 

•  Environmental costs of Option 4 can be estimated by multiplying the emissions by 

the cost factors 

The results are presented in the following table: 

hypothetical 
scenario 

option 1 
(baseline) 

option 2  
(3 yr delay)

option 3  
(5 yr delay) 

option 4 
(exemption)

Change in PM 
emissions (kt) 

Change in NOx 
emissions (kt) 

Change in PM costs 
(M€) 

0 

0 

0 

4,3 

62 

60 

2,1 

20 

29 

3,5 

33 

48 

27 

230 

373 

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Change in NOx 
costs (M€) 

0 

134 

43 

72 

495 

The  environmental  impacts  for  options  2,  3  and  4  mentioned  in  this  report,  represent  the 
variations relative to the ones of option 1 (baseline scenario). 

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