COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document& Proposal for a Regulation of the European Parliament and of the Council on simplifying the transfer of motor vehicles registered in another Member State within the Single Market
Date: 2012-04-04
Institutions: European Commission
Subjects: EU Member State, administrative formalities, exchange of information, motor vehicle, single market, vehicle registration

EUROPEAN COMMISSION 

Brussels, 4.4.2012  
SWD(2012) 81 final 

COMMISSION STAFF WORKING DOCUMENT 

IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Regulation of the European Parliament and of the Council on simplifying 
the transfer of motor vehicles registered in another Member State within the Single 
Market 

{COM(2012) 164 final} 
{SWD(2012) 82 final} 

 
 
 
 
  
 
COMMISSION STAFF WORKING DOCUMENT 

IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Regulation of the European Parliament and of the Council on simplifying 
the transfer of motor vehicles registered in another Member State within the Single 
Market 

This report only commits 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 

COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT....................... 2 

1. 

1.1. 

1.2. 

1.3. 

1.4. 

2. 

2.1. 

2.2. 

Procedural issues and consultation of interested parties .............................................. 8 

Identification ................................................................................................................ 8 

Organisation and timing............................................................................................... 8 

Consultation and expertise ........................................................................................... 8 

Scrutiny by the Commission Impact Assessment Board ............................................. 8 

Policy context – Problem definition............................................................................. 9 

Policy context............................................................................................................... 9 

Problem definition...................................................................................................... 10 

2.2.1. 

In which Member State should the motor vehicle be registered? .............................. 10 

2.2.2.  The administrative burden of re-registration.............................................................. 11 

2.3. 

2.4. 

2.5. 

The objectives of motor vehicle registration - Underlying causes of the problem .... 15 

Action taken by the Commission (baseline scenario) ................................................ 16 

The size of the problem: who is affected, in what ways and to what extent?............ 16 

2.5.1.  Summary .................................................................................................................... 19 

2.5.2.  Figures about the size of the problem ........................................................................ 19 

2.5.3.  Estimation of the costs of the current system (baseline scenario) ............................. 20 

2.5.3.1.  Administrative costs................................................................................................... 20 

2.5.3.2.  Other impacts: Profit loss........................................................................................... 21 

2.5.3.3.  Additional costs for car rental companies.................................................................. 21 

2.5.3.4.  Other costs.................................................................................................................. 21 

2.6. 

2.7. 

3. 

3.1. 

3.2. 

3.3. 

4. 

Foreseen evolution of the problem............................................................................. 22 

EU right to act ............................................................................................................ 23 

Objectives................................................................................................................... 24 

General policy objectives........................................................................................... 24 

Specific policy objectives .......................................................................................... 24 

Operational policy objectives..................................................................................... 24 

Policy options............................................................................................................. 24 

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4.1. 

4.2. 

5. 

5.1. 

5.2. 

Assumptions............................................................................................................... 24 

Description of policy options ..................................................................................... 25 

Analysis of impacts .................................................................................................... 29 

Base-line option ......................................................................................................... 29 

Option 1: Single registration for the entire life of the motor vehicle (“single 
registration) ................................................................................................................ 29 

5.2.1.  Qualitative assessment ............................................................................................... 29 

5.2.2.  Reduction of administrative costs .............................................................................. 31 

5.3. 

Option 2: No re-registration in the Member State of destination if the holder remains 
the same person .......................................................................................................... 32 

5.3.1.1.  Qualitative assessment ............................................................................................... 32 

5.3.1.2.  Reduction of administrative costs .............................................................................. 36 

5.4. 

Option 3: registration in the Member State of the holder of the vehicle and simplified 
re-registration ............................................................................................................. 37 

5.4.1.1.  Qualitative assessment ............................................................................................... 37 

5.4.1.2.  Reduction of administrative costs .............................................................................. 39 

5.5. 

Option 4: Registration in the Member State where the motor vehicle is primarily used 
and simplified re-registration ..................................................................................... 40 

5.5.1.  Qualitative assessment ............................................................................................... 40 

5.5.2.  Reduction of administrative costs .............................................................................. 42 

5.6. 

Option 5: Optimising the electronic exchange of information among national 
registration authorities................................................................................................ 42 

5.6.1.  Reduction of administrative costs .............................................................................. 43 

6. 

6.1. 

6.2. 

6.3. 

6.4. 

6.5. 

6.6. 

7. 

8. 

Comparing the options ............................................................................................... 44 

Public consultation ..................................................................................................... 44 

Administrative burden................................................................................................ 44 

Comparison of the qualitative impacts....................................................................... 45 

Comparison of all impacts ......................................................................................... 45 

Sensitivity analysis..................................................................................................... 46 

Form of the legislative instrument ............................................................................. 47 

Monitoring and evaluation ......................................................................................... 47 

Annexes...................................................................................................................... 49 

8.1. 

Annex 1: Public consultation and surveys ................................................................. 49 

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8.1.1.  Results of the public consultation .............................................................................. 49 

8.1.1.1.  General overview ....................................................................................................... 49 

8.1.1.2.  Results ........................................................................................................................ 51 

8.1.1.3.  Conclusion and subsequent steps ............................................................................... 63 

8.1.2.  Survey of national registration authorities ................................................................. 64 

8.1.3.  Understanding Citizens’ and Businesses’ Concerns with the Single Market: A View 

from the Assistance Services ..................................................................................... 67 

8.2. 

Annex 2: legal context of car registration in the internal market............................... 73 

8.2.1.  Type-approval of new motor vehicles........................................................................ 73 

8.2.1.1.  New motor vehicles and their trailers ........................................................................ 73 

8.2.1.2.  New two or three-wheeled motor vehicles................................................................. 73 

8.2.1.3.  Agricultural or forestry tractors ................................................................................. 74 

8.2.2.  Registration of motor vehicles ................................................................................... 74 

8.2.3.  The role of registration in the field of transport......................................................... 75 

8.2.3.1.  Hiring of vehicles for the carriage of goods............................................................... 75 

8.2.3.2.  Periodic roadworthiness tests..................................................................................... 76 

8.2.3.3.  Recommendation 2010/378/EU (Periodic inspections of vehicles)........................... 77 

8.2.3.4.  Technical roadside inspection of the roadworthiness of commercial vehicles .......... 80 

8.2.3.5.  Recommendation 2010/379/EU (Roadside checks)................................................... 80 

8.2.4.  Motor insurance ......................................................................................................... 81 

8.2.5.  Cross-border car crime............................................................................................... 81 

8.2.6.  End-of life vehicles .................................................................................................... 82 

8.2.7. 

Jurisprudence of the Court of Justice on car registration since 2000......................... 84 

8.3. 

Annex 3: Summary of national rules and practices with respect to motor vehicle 
registration.................................................................................................................. 90 

8.3.1.  Belgium ...................................................................................................................... 90 

8.3.2.  Bulgaria ...................................................................................................................... 91 

8.3.3.  Czech Republic .......................................................................................................... 92 

8.3.4.  Denmark..................................................................................................................... 92 

8.3.5.  Germany..................................................................................................................... 93 

8.3.6.  Estonia........................................................................................................................ 95 

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8.3.7. 

Ireland ........................................................................................................................ 96 

8.3.8.  Greece ........................................................................................................................ 97 

8.3.9.  Spain........................................................................................................................... 98 

8.3.10.  France......................................................................................................................... 99 

8.3.11.  Italy .......................................................................................................................... 100 

8.3.12.  Cyprus ...................................................................................................................... 102 

8.3.13.  Latvia........................................................................................................................ 103 

8.3.14.  Lithuania .................................................................................................................. 103 

8.3.15.  Luxembourg ............................................................................................................. 105 

8.3.16.  Hungary.................................................................................................................... 106 

8.3.17.  Malta ........................................................................................................................ 108 

8.3.18.  Netherlands .............................................................................................................. 111 

8.3.19.  Austria ...................................................................................................................... 112 

8.3.20.  Poland....................................................................................................................... 114 

8.3.21.  Portugal .................................................................................................................... 115 

8.3.22.  Romania ................................................................................................................... 116 

8.3.23.  Slovenia.................................................................................................................... 118 

8.3.24.  Slovakia.................................................................................................................... 119 

8.3.25.  Finland...................................................................................................................... 120 

8.3.26.  Sweden ..................................................................................................................... 122 

8.3.27.  United Kingdom....................................................................................................... 123 

8.3.28.  Transferring motor vehicles to another Member States - Temporary and professional 
(or ‘commercial’) registration schemes in the EU ................................................... 127 

8.3.28.1. The seller drives the motor vehicle with his own registration plates....................... 127 

8.3.28.2. The buyer seeks registration of the motor vehicle in his own Member State:......... 127 

8.3.28.3. The buyer seeks temporary registration of the motor vehicle:................................. 127 

8.3.28.4. The professional seller drives the motor vehicle with his professional number plates:

.................................................................................................................................. 133 

8.4. 

Annex 4: figures and statistics ................................................................................. 138 

8.4.1.  Affected groups........................................................................................................ 138 

8.4.2.  Background statistics ............................................................................................... 142 

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8.4.2.1.  Methodological remarks........................................................................................... 142 

8.4.2.2.  Car registrations in the EU....................................................................................... 144 

8.4.2.3.  Car-rental and leasing sector.................................................................................... 150 

8.4.3.  Economic Impacts.................................................................................................... 153 

8.4.3.1.  Methodology and assumptions................................................................................. 153 

8.4.3.2.  Impact on administrative costs................................................................................. 153 

8.4.3.3.  Other economic impact: loss of profits .................................................................... 156 

8.4.3.4.  Other economic impacts on the car-rental sector..................................................... 158 

8.4.3.5.  Other economic impacts: the 2nd hand vehicle market ........................................... 160 

8.4.3.6.  Sensitivity analysis................................................................................................... 161 

8.5. 

Annex 5: European Vehicle and Driving Licence Information System (EUCARIS)
.................................................................................................................................. 162 

8.5.1.  Treaty concerning a European Vehicle and Driving Licence Information System 

(EUCARIS) .............................................................................................................. 162 

8.5.2.  Bilateral exchange of information............................................................................ 162 

8.5.3.  The exchange of vehicle registration data through EUCARIS in EU law............... 163 

8.5.4.  The functioning of the electronic exchange of vehicle registration data through 

EUCARIS................................................................................................................. 164 

8.5.5.  Financial aspects ...................................................................................................... 165 

8.5.6.  Technical aspects ..................................................................................................... 167 

8.5.6.1.  Introduction .............................................................................................................. 167 

8.5.6.2.  National Registries ................................................................................................... 167 

8.5.6.3.  An EUCARIS application in each Member State .................................................... 167 

8.5.6.4.  Presentation .............................................................................................................. 168 

8.5.6.5.  Applications ............................................................................................................. 168 

8.5.6.6.  Communication ........................................................................................................ 172 

8.5.6.7.  Technical infrastructure ........................................................................................... 172 

8.5.6.8.  Security .................................................................................................................... 173 

8.5.6.9.  Operational system management ............................................................................. 175 

8.6. 

8.7. 

Annex 6: Discarded option....................................................................................... 178 

Annex 7: SME Test.................................................................................................. 180 

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1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1. 

Identification 

Lead DG: DG ENTR - Agenda Planning/WP Reference: 2011/ENTR/010. 

1.2. 

Organisation and timing 

Work  on  the  Impact  Assessment  started  in  the  second  half  of  2010.  An  Impact 
Assessment  Steering  Group  chaired  by  DG  ENTR  was  set  up  and  met  5  times,  on 
7 December 2010, 27 May, 22 September, and 11 and 20 October 2011. SG, SJ, DG 
ECFIN, COMP, EMPL, MOVE, ENV, MARKT, TAXUD, SANCO and JUST were 
invited  to  the  meetings,  at  which  representatives  of  SG,  DG  MOVE,  TAXUD  and 
MARKT  attended  and  contributed  to  the  discussions.  DG  JUST  and  DG  COMP 
provided written comments. 

1.3. 

Consultation and expertise 

External  expertise  was  used  for  mainly  gathering  data  about  the  magnitude  of  the 
current  problems  and  the  extent  to  which  a  simplification  of  the  registration 
procedure for motor vehicles previously registered in another Member State can be 
enhanced. Different surveys were organised, the results of which are summarised in 
Annex 1. 

From March to May 2011, a public consultation of stakeholders, consisting of tailor 
made  questionnaires  for  citizens,  economic  operators  and  public  authorities,  was 
carried  out  through  I.P.M.  (Your  Voice  in  Europe).  A  summary  of  the  public 
consultation results is enclosed in annex 1 and is also available on the Europa web 
site1. The Commission’s minimum standards have all been met. 

A  conference  was  organised  on  21  June  2011  to  present  preliminary  results  of  the 
public consultation, and to provide an additional forum for debate and exchange of 
information between different stakeholders, and in particular for public authorities in 
charge of registration in the Member States2. 

1.4. 

Scrutiny by the Commission Impact Assessment Board 

The Impact Assessment Board of the European Commission assessed a draft version 
of the present impact assessment and issued its opinion on 16 December 2011. The 
Impact  Assessment  Board  made  several  recommendations  and,  in  the  light  of  the 
latter, the final impact assessment report firstly strengthens the evidence base of the 
problem definition, for instance by giving clearer references to the jurisprudence of 
the ECJ. Secondly, it provides a more detailed explanation of the content and impacts 

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HTTP://EC.EUROPA.EU/ENTERPRISE/POLICIES/SINGLE-MARKET-GOODS/FREE-MOVEMENT-NON-
HARMONISED-SECTORS/CAR-REGISTRATION/VIEW_CONTRIBUTIONS_EN.HTM 
http://ec.europa.eu/enterprise/policies/single-market-goods/free-movement-non-harmonised-sectors/car-
registration/conference_documents_en.htm 

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of the options, in particular for the package of preferred options. Thirdly, the report 
gives a better supported comparison of options by presenting an integrated overview 
of  all  relevant  costs  and  benefits.  Finally,  it  presents  the  future  monitoring 
arrangements more clearly, and indicates how the Directive will be evaluated. 

2. 

POLICY CONTEXT – PROBLEM DEFINITION 

2.1. 

Policy context 

The free movement of goods is one of the cornerstones of the European Union. This 
principle constitutes an important pillar of the single market and allows citizens and 
enterprises to purchase or sell products in another Member State. Unfortunately, the 
single market still comprises considerable barriers.  

The obligation to register, in the receiving Member State, a motor vehicle previously 
registered in the Member State of origin has been a source of complaints and court 
cases  for  decades.  Notwithstanding  the  further  integration  of  the  single  market,  car 
registration  problems  remain  a  frequent  barrier  for  citizens  and  businesses. 
Europeans  moving  to  another  Member  State  often  experience  difficulties  when 
taking their car along with them. They can face complex and burdensome registration 
procedures, demands for paperwork in the host country which was not delivered in 
the  home  country,  and  they  may  have  to  pay  additional  taxes  and  duties.  Citizens 
purchasing  a  car  in  another  country  and  taking  it  back  with  them  to  the  country 
where they live face the same problems regarding registration procedures.  

The  Europe2020  Strategy  for  smart,  sustainable  and  inclusive  growth3  already 
pointed  out  that  businesses  and  citizens  are  faced  every  day  with  the  reality  that 
bottlenecks  to  cross-border  activity  remain  despite  the  legal  existence  of  the  single 
market.  Motor  vehicle  registration  problems  are  a  typical  example  of  these 
bottlenecks and were identified in the first EU Citizenship Report4 as one of the main 
obstacles faced by citizens when exercising their rights under EU law in their daily 
lives. Moreover, they were also highlighted as one of the 20 main concerns with the 
Single Market as it stands now, in a list compiled by the Commission5. In its opinion 
of  11  March  2011,  the  High  Level  Group  of  Independent  Stakeholders  on 
Administrative  Burdens  supported  a  possible  Commission  initiative  to  simplify 
registration  conditions  and  formalities.  In  addition,  the  Group  called  upon  the 
national authorities to strive for improved registration processes as soon as possible, 
in  particular  concerning  mutual  recognition of the necessary documentation, and to 
refrain from burdensome requests for supplementary documentation6. 

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COM(2010)2020 of 3.3.2010. 
COM(2010)603 of 27.10.2010. 
This  list  represents  a  snapshot  of  difficulties  encountered  by  people  (understood  in  a  wide  sense: 
citizens,  businesses,  consumers,  workers,  students,  pensioners)  when  attempting  to  exercise  their  EU 
rights. See http://ec.europa.eu/internal_market/strategy/docs/20concerns/publication_en.pdf.  
HTTP://EC.EUROPA.EU/ENTERPRISE/POLICIES/SMART-REGULATION/ADMINISTRATIVE-BURDENS/HIGH-
LEVEL-GROUP/FILES/HLG_100311_AMSTERDAM_OFFLINE_OPINION_EN.PDF, point 21. 

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2.2. 

Problem definition 

All Member States have a vehicle registration system of motor vehicles. It constitutes 
the administrative authorisation for their entry into service in road traffic, involving 
their  identification  and  the  issuing  of  a  registration  number.  At  the  end  of  the 
registration procedure, Member States issue a registration certificate which certifies 
that  the  vehicle  is  registered  in  a  Member  State.  The  registration  certificate  also 
contains  the  name  and  address  of  the  person  in  whose  name  a  vehicle  is  registered 
(the  ‘holder’  of  the  registration  certificate  who  is  not  necessarily  the  owner  of  the 
motor vehicle7).  

The  registration  of  a  new  motor  vehicle8  is  a  very  simple  administrative  formality 
which most Member States have organised very efficiently. 

Yet, when the motor vehicle is registered in one Member State and frequently used in 
another, the question of which Member States the motor vehicle should be registered 
in arises. If it needs to be re-registered in another Member State, the administrative 
formalities  to  obtain  the  registration  in  the  receiving  Member  State  are  often 
burdensome and cause delays. The two problems are obviously interlinked: a person 
or a business is only confronted with the formalities of re-registration when they are 
forced  to  re-register  a  motor  vehicle  that  is  already  registered  in  another  Member 
State9.  

2.2.1. 

In which Member State should the motor vehicle be registered?  

Citizens  who  move  to  another  Member  State,  cross-border  workers,  car-rental 
companies  and  people  leasing  a  motor  vehicle  in  another  Member  State  are  often 
obliged  to  register  it  on  the  territory  where  they  live  or  where  the  motor  vehicle  is 
used, although it is already registered in another Member State. This is for example 
the  case  when  certificate  holders  change  their  residence  and  move  permanently  to 
another Member State with their motor vehicle. However, it is a tedious problem for 
citizens that live part of the year in one Member State and the other part in another, 
as well as for cross-border commuters who use, in their own Member State, a motor 
vehicle registered by their employer in another Member State. In this case, the motor 
vehicle is registered in one of the Member States but the holder is often asked by the 
other Member State to register it there10.  

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The registration certificate may contain, on an optional basis, information about the ownership of the 
motor vehicle. Where the particulars about the ownership are not included in the registration certificate, 
it will contain a reference to the fact that the holder of the registration certificate is the vehicle owner, or 
is not the vehicle owner, or is not identified by the registration certificate as being the vehicle owner.  
Member States are obliged to register new motor vehicles on the basis of the certificate of conformity, 
pursuant  to  Article  26  of  Directive  2007/46/EC  of  the  European  Parliament  and  of  the  Council  of  5 
September 2007 establishing a framework for the approval of motor vehicles and their trailers, and of 
systems, components and separate technical units intended for such vehicles. Since new motor vehicles 
face  no  barriers  for  their  first  registration  in  the  EU,  they  fall  outside  the  scope  of  this  impact 
assessment. For further details, see Annex 2. 
This impact assessment does not relate to re-registrations of motor vehicles previously registered in the 
same Member State or in a third country. 
Annex 2 contains an overview of the jurisprudence of the Court of Justice on these cases.  

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Example:  Cross-frontier  workers  residing  in  Finland  and  employed  in  another 
Member State were not allowed to use company vehicles which were made available 
by their employers established in another Member State and registered in the latter 
State,  unless  these  motor  vehicles  were  registered  in  Finland.  The  Court  of  Justice 
ruled  that  this  was  incompatible  with  the  Treaty  (judgement  of  23  February  2006, 
Commission v. Finland, Case C-232/03). 

Traders of second-hand motor vehicles, which are usually SMEs, are confronted with 
the same problem when they purchase a motor vehicle in another Member State. For 
them,  the  problem  is  often  aggravated  by  the  difficulty  of  transferring  individual 
motor  vehicles  bought  in  another  Member  State  to  their  home  country  since 
temporary  registrations  tend  to  be  fairly  restrictive  and  so-called  ‘professional 
registrations’ for motor vehicles are often not recognised in other Member States. A 
similar  problem  as  regards  pinpointing  the  Member  State  where  the  motor  vehicle 
needs to be registered occurs for people wishing to lease a motor vehicle from, and 
registered by, a leasing company established in another Member State. Finally, it is 
also  a  problem  for  car-rental  companies  that  wish  to  move  a  part  of  their  fleet  to 
another Member State to meet seasonal demands.  

Example: A Belgian national, residing in Belgium but working in Luxembourg, was 
stopped in Belgium for a roadside control, when he was driving a vehicle registered 
in  Luxembourg.  He  was  charged  with  having,  while  residing  in  Belgium,  failed  to 
register  a  vehicle  that  he  intended  to  put  into  circulation  in  Belgium,  even  though 
that vehicle was already registered abroad (judgement of the Court of Justice of 15 
December 2005, Case C-152/04).  

2.2.2.  The administrative burden of re-registration 

In  practice,  when  Member  States  do  not  accept  that  people  living  on  their  territory 
use a motor vehicle registered in another Member State, they oblige the holder of the 
motor  vehicle  to  re-register  it  on  their  territory.  However,  formalities  of  re-
registration for a motor vehicle being transferred from one Member State to another 
are  often  very  burdensome  and  lengthy.  Transferring  a  motor  vehicle  for  a  longer 
period  to  another  Member  State  leads  to  new  paperwork  in  the  receiving  Member 
State and, usually, also the paperwork to cease the registration of the vehicle in the 
Member State of origin.  

The  additional  burden  is  principally  caused  by  the  fact  that  the  registration 
authorities  of  the  receiving  Member  State  have  little  or  no  information  about  the 
motor  vehicle,  except  the  information  that  they  can  find  on  the  registration 
certificate.  If  the  vehicle  were  to  be  re-registered  in  the  same  Member  State, 
registration authorities could rely on the information in their national databases. 

Example: The Polish legislation required imported second-hand vehicles to undergo 
roadworthiness  test  prior  to  their  registration,  whereas  domestic  vehicles  with  the 
same  characteristics  were  not  subject  to  such  a  requirement.  The  Court  of  Justice 
ruled that this rule breached the principle of free movement of goods. According to 
the Court, the same objective could be attained through the recognition of the proof 
issued in another Member State showing that a vehicle registered in the territory of 
that  State  has  passed  a  roadworthiness  test,  together  with  cooperation  by  the 

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registration  authorities  with  their  counterparts  in  other  Member  States  concerning 
any  data  that  may  be  missing  (judgement  of  5  June  2008,  Commission  v.  Poland, 
Case C-170/07). 

The amount of paperwork in the receiving Member State and its burdensome effect 
are to a large extent determined by the modalities of the registration process which 
vary widely between Member States11. The first step is the formal de-registration of 
the  motor  vehicle.  These  formalities  usually  consist  of  collecting  the  required 
documents  which  vary  from  country  to  country,  visiting  the  competent  office, 
submitting personal data and motor vehicle data (e.g. proof of ownership, registration 
document,  chassis  number).  The  insurance  company  must  also  be  informed.  In  the 
case that the motor vehicle is driven on public roads after de-registration towards the 
destination country, one must usually apply for a temporary number plate, submit all 
necessary data about the vehicle and its owner, and arrange for insurance coverage. 
The next administrative phase of transferring a vehicle to another Member States is 
the heaviest: re-registration in the receiving Member State. It involves a number of 
administrative steps and, more importantly, various new controls and checks, such as 
the submission of a certificate of conformity and national roadworthiness tests: 

• 

individual  approval.  For  new  motor  vehicles, 

Type-approval  or 
the 
manufacturer, in his capacity as the holder of the EC type-approval, issues an 
EC  certificate  of  conformity  which  shows  that  the  vehicle  has  been 
manufactured in conformity with the approved vehicle type. The EC certificate 
of conformity must accompany each new EC type-approved vehicle. However, 
EU  legislation  does  not  require  that  the  certificate  of  conformity  remain  with 
the  vehicle  after  registration.  In  most  Member  States  the  EC  certificate  of 
conformity  is  kept  by  the  authorities  once  the  vehicle  is  registered. 
Nevertheless, several Member States oblige applicants to submit a copy of the 
certificate of conformity which is usually only required for the first registration 
of the vehicle. This constitutes a serious problem for many citizens who have 
to  contact  the  manufacturer  for  a  copy  of  the  certificate,  and  pay  a  fee  to 
receive it. In addition, this process usually takes a few weeks.  

Example:  Austria  required  that,  for  the  purposes  of  their  first  registration  in 
Austria,  motor  vehicles  previously  registered  in  other  Member  States  and 
which have not undergone, because of their age, a Community  type-approval 
procedure, had comply with limit values in respect of pollutant emissions and 
noise which are stricter than those they initially had to comply with as set out 
in EU law. However, motor vehicles with the same characteristics and which 
were  already  authorised  to  use  the  roads  in  Austria  were  not  subject  to  that 
requirement in cases of their re-registration in that Member State. Therefore, 
the  Court  of  Justice  considered  that  this  requirement  constituted  a  breach  of 
the  principle  of  free  movement  of  goods  (judgement  of  11  December  2008, 
Commission v. Austria, Case C-524/07). 

• 

Roadworthiness tests. Several Member States oblige the person seeking the re-
to  undergo  a 
registration  of  a  vehicle  from  another  Member  State 

11 

Annex  3  contains  a  succinct  overview  of  the  different  formalities  and  requirements  relating  to  motor 
vehicle registration in the Member States. 

EN 

12 

   EN 

 
                                                 
roadworthiness test prior to the registration procedure, despite the fact that the 
person  is  already  in  possession  of  valid  documents  delivered  by  another 
Member State. This test is either similar to the regular (annual) test that applies 
to  national  vehicles  or  can  be  even  more  demanding  and,  consequently,  also 
more  expensive.  At  the  moment  many  Member  States  do  not  recognise  the 
content of the roadworthiness certificate issued by another Member State or, if 
they need information about the vehicle, they do not demand the necessary data 
from their counterparts in other Member States. 

Example:  The  Court  of  Justice  indicated  that,  by  requiring  motor  vehicles 
previously  registered  in  another  Member  State  to  undergo  a  test  as  to  their 
general  condition  prior  to  registration  and  without  taking  any  account 
whatsoever of tests that may have already been carried out by those Member 
States,  some  persons  concerned  may  be  deterred  from  registering  vehicles 
previously registered in other Member States. The Court argued that a similar 
result could be achieved by less restrictive measures, such as recognition of the 
proof issued in another Member State showing that a vehicle registered in the 
territory  of  that  State  has  passed  a  roadworthiness  test,  together  with 
cooperation  by  the  registration  authorities  with  their  counterparts  in  other 
Member  States  concerning  any  data  that  may  be  missing  (Judgement  of  20 
September 2007, Commission v. the Netherlands, Case C-297/05). 

Lack of administrative cooperation: National registration authorities complain 
about  the  difficulties  that  they  are  facing  to  contact  their  colleagues  in  other 
Member States. Almost 60% of the public authorities which participated in the 
public consultation are dissatisfied with the current system for the exchange of 
information  between  registration  authorities12.  The  practical  difficulties  to 
obtaining  missing  data  could  lead  to  additional  delays  for  re-registration. 
Directive  1999/37/EC  allows  Member  States  to  ‘exchange  information  at 
bilateral  or  multilateral  level  in  particular  so  as  to  check,  before  any 
registration  of  a  vehicle,  the  latter's  legal  status,  where  necessary  in  the 
Member  State  in  which  it  was  previously  registered.  Such  checking  may  in 
particular  involve  the  use  of  an  electronic  network.’  However,  no  specific 
network was created for the implementation of this provision of the Directive. 
Yet,  according  to  the  case-law  of  the  Court  of  Justice,  the  objectives  of  road 
safety  and  the  protection  of  the  environment  can  be  attained  through  the 
recognition of the proof issued in another Member State showing that a vehicle 
registered  in  the  territory  of  that  State  has  passed  a  roadworthiness  test, 
together with cooperation by the competent authorities with their counterparts 
in other Member States concerning any data that may be missing13.  

• 

The 651 citizens and 151 businesses responding to the public consultation mentioned 
the following problems: 

Problem 

Business 

12 
13 

See the results of the public consultation and the survey of national registration authorities in Annex 1.  
Judgment  of  20  September  2007,  Commission  of  the  European  Communities  v  Kingdom  of  the 
Netherlands, Case C-297/05 ; Judgment of 5 June 2008, Commission of the European Communities v 
Republic of Poland, Case C-170/07. 

EN 

13 

   EN 

 
  
                                                 
The vehicle reg. authorities required additional technical 
checks or certificates  

Long and complicated procedures 
The registering country required a new roadworthiness test, 
even though the vehicle had passed one in another EU 
country 

1 

2 

3 

4  Differences in registration requirements between countries 

5 

6 

7 

8 

9 

Required to supply technical information you did not have 
The authorities did not recognise some of the technical 
documentation submitted 
The authorities refused requests to have the vehicle 
registered there 
The vehicle was not EU type-approved (new type approval 
requested) 
Unable to temporarily transfer a vehicle from one EU 
country to another 

10  Other 

A valid EU type-approval certificate was not recognised by 
reg. authorities in the receiving country 

11 

12  Required to submit an EU type-approval certificate 

Problem 

1 

2 

3 

Long and complicated procedures 
The vehicle reg. authorities required additional technical 
checks or certificates 
The registering country required a new roadworthiness test, 
even though the vehicle had passed one in another EU 
country 

4  Differences in registration requirements between countries 

5  Required to supply technical information you did not have 

6  Other 

7  Required to submit an EU type-approval certificate 

The vehicle was not EU type-approved (new type approval 
requested) 
A valid EU type-approval certificate was not recognised by 
reg. authorities in the receiving country 
The authorities did not recognise some of the technical 
documentation submitted 
Unable to temporarily transfer a vehicle from one EU 
country to another 
The authorities refused requests to have the vehicle 
registered there 

8 

9 

10 

11 

12 

69.5 % 

67.8 % 

50.8 % 

37.3 % 

32.2 % 

30.5 % 

27.1 % 

20.3 % 

18.6 % 

18.6 % 

13.6 % 

11.9 % 

Citizens 

81.6 % 

67.9 % 

54.3 % 

44.7 % 

26.7 % 

25.4 % 

20.7 % 

18.2 % 

17.3 % 

15.2 % 

12.4 % 

8.8 % 

• 

The  modalities  of  the  re-registration  process  constitute  not  only  a  general 
problem  for  citizens  and  enterprises,  but  equally  for  national  registration 
authorities. In the public consultation, 95% of national registration authorities 
reported procedural problems with cross-border re-registration procedures.  

EN 

14 

   EN 

 
 
 
80,0%

70,0%

60,0%

50,0%

40,0%

30,0%

20,0%

10,0%

0,0%

66,7%

75,0%

37,5%

45,8%

Certificates submitted with the application do
not contain information needed to determine
whether vehicle complies with technical rules
(66.7%)
Difficulties in identifying the vehicle with
precision (37.5%)

Differences in registration requirements
between EU countries (75.0%)

Problems by public authorities

Other (45.8%)

2.3. 

The objectives of motor vehicle registration - Underlying causes of the problem 

The  principle  of  national  registration  of  motor  vehicles  is  very  old  and  was 
consolidated by the Convention on Road Traffic, signed in Vienna on 8 November 
196814.  The  main  objective  of  national  motor  vehicle  registration 
the 
administrative  authorisation  for  the  entry  into  service  in  road  traffic  of  a  motor 
vehicle. This procedure is used for three purposes:  

is 

– 

– 

– 

Vehicle identification in traffic. The motor vehicles registration number allows 
identifying the owner or user of the registration number, for law enforcement 
and road safety purposes. 

The registration data are used for the taxation of motor vehicles15. There exists 
a close link between the obligation to register a motor vehicle and the payment 
of motor vehicle taxes.  

The  registration  data  are  also  used  for  the  organisation  of  the  roadworthiness 
tests. 

Consequently,  the  main  causes  of  the  problem  are  the  concerns  of  national 
administrations to obtain the national registration of motor vehicles in order to ensure 
road  safety,  to  prosecute  traffic  offences  and  to  levy  national  registration  and/or 
circulation taxes. 

In addition, the problem will also be influenced by two interrelated gaps:  

14 

15 

24  Member  States  are  Contracting  Parties  to  the  Convention.  The  full  text  of  the  Convention  can  be 
consulted 
on 
http://www.unece.org.unecedev.colo.iway.ch/fileadmin/DAM/trans/conventn/Conv_road_traffic_EN.pd
f.  
Judgment  of  the  Court  of  Justice  of  21  March  2002,  Cura  Anlagen  GmbH  v  Auto  Service  Leasing 
GmbH (ASL), Case C-451/99. The Court of Justice also pointed out that, save for the specific situation 
of vehicles which are imported into the EU temporarily and motor vehicles intended exclusively for the 
road transport of goods with an authorised load of 12 tonnes or more, ‘the taxation of motor vehicles 
has not been harmonised and differs considerably from one Member State to another. Member States 
are therefore free to exercise their powers of taxation in that area, provided they do so in compliance 
with EU law. It is lawful for them to allocate those powers of taxation amongst themselves on the basis 
of criteria such as the territory in which a vehicle is actually used or the residence of the driver, which 
are various components of the territoriality principle, and to conclude agreements amongst themselves 
to ensure that a vehicle is subject to indirect taxation in only one of the signatory States.’ 

EN 

15 

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– 

– 

An information gap: Citizens and businesses often do not sufficiently know or 
understand their rights and do not know where to look for information or help 
on the registration of a motor vehicle previously registered in another Member 
State. Likewise, registration authorities fail to sufficiently understand the rules 
and how to apply them;  

An  implementation  gap:  In  several  areas,  a  gap  can  be  noted  between  the 
application of the principles set out in the jurisprudence of the Court of Justice 
and  the  way  it  is  implemented  and  applied  in  practice.  For  motor  vehicle 
registration  issues,  there  is  still  a  lack  of  co-operation  amongst  relevant 
administrations  operating  in  a  cross-border  context  and  to  difficulties  in 
resolving problems and obtaining redress where things go wrong. 

2.4. 

Action taken by the Commission (baseline scenario) 

Besides  starting  infringement  procedures,  the  Commission  published  interpretative 
communications  summarising  EU  law  on  the  subject16.  However,  EU  law  and  the 
jurisprudence  of  the  Court  of  Justice  on  the  subject  keep  evolving  so  that  most 
interpretative  communications  on  car  registration  are  quite  quickly  outdated, 
including the one published in 2007. Moreover, an interpretative Communication is 
non-binding,  and  so  far  has  not  acted  as  effective  guidance  or  a  constraint  on 
Member States.  

these  different 
the  Commission  has  already 
Furthermore,  although 
interpretative  communications,  it  cannot  be  claimed  that  they  have  considerably 
reduced  the  number  of  problems.  National  registration  authorities  are  aware  –  or 
should  be  aware  –  of  the  existence  of  the  latest  interpretative  communication  but 
usually  apply  national  law  in  the  case  of  conflict  between  national  rules  and  the 
interpretative communication.  

issued 

There are no indications that citizens and enterprises would be aware of the existence 
of  the  communication,  and  it  seems  unrealistic  to  expect  that  the  communication  – 
which  outlines  the  main  elements  of  EU  law  and  the  jurisprudence  of  the  Court  of 
Justice – would be very helpful for them in case of a conflict.  

2.5. 

The size of the problem: who is affected, in what ways and to what extent? 

There  are  around  300  million  registered  motor  vehicles17  in  the  EU  (which  consist 
mainly  of  M1  passenger  vehicles  and  N1  light  duty  motor  vehicles)18.  Around  13 
million  new  vehicles  were  registered  in  2010.  The  number  of  car-title  transfers  is 

16 

17 

18 

The  latest  ‘Commission  interpretative  communication  on  procedures  for  the  registration  of  motor 
vehicles originating in another Member State’ [SEC(2007)169 of 14.2.2007] was published in OJ C68 
of  24.3.2007,  p.  15.  This  communication  replaced  in  its  entirety  the  previous  Commission 
Communication on the same subject [96/C 143/04], published in OJ C143, 15.5.1996, p. 4.  
Motor  vehicles  with  at  least  four  wheels  are  subdivided  into  category  M  (i.e.  vehicles  used  for  the 
carriage  of  passengers  whereby  category  M1  covers  motor  vehicles  with  no  more  than  eight  seats  in 
addition to the driver’s seat and categories M2 and M3 cover motor vehicles with more than eight seats 
in addition to the driver’s seat), category N (motor vehicles used for the carriage of goods), category O 
(trailers,  including  semi-trailers),  off-road  vehicles  (symbol  G)  and  ‘special  purpose  vehicles’  (i.e. 
vehicles intended to perform a function which requires special body arrangements and/or equipment). 
Ereg, The vehicle chain 2010/2011 

EN 

16 

   EN 

 
                                                 
about three times as high as first registrations, with an average number of 40 million 
vehicles  that  are  transferred  to  a  new  holder19.  Around  8%  of  these  (3.5  million) 
correspond to vehicles transferred between Member States20. De- and re-registration 
are unevenly distributed across Member States. The main “net exporter” of cars to be 
re-registered in another Member State is by far Germany (1,697,000: almost 50%). It 
is  followed  by  Italy  (423,000:  12%),  Netherlands  (309,000:  9%)  and  France 
(271,585:  8%).  Concerning  “net  importers”,  the  highest  number  by  far  of  re-
registration  of  cars  coming  from  another  Member  State  takes  place  in  Poland, 
(1,123,583:  30%  of  all  re-registrations).  It  is  followed  by  Greece  (404,000:  11%), 
Lithuania  (253,000:  6.5%),  Romania  (225,000:  6.5%)  and  the  Czech  Republic 
(207,000: 6%).  

Citizens are in the first to be affected by re-registration problems. As EU integration 
proceeds,  more  people  may  wish  to  move  from  one  country  to  another;  or  to  have 
holiday homes in other Member States, leaving their cars there. More than 3 million 
people  arrived  for  a  permanent  stay  in  Member  States  in  2007,  with  more  than  2 
million arriving in Spain, Germany and the United Kingdom combined21.  

Persons  living  in  one  Member  State  and  using  a  motor  vehicle  registered  by  their 
employer in another Member State are also affected by the problem. In total, about 
780,000  people  in  the  EU  (including  EEA/EFTA)  were  cross-border  commuters  in 
the year 2006/2007 (including commuters using other means of transport)22.  

Citizens are also the main group of customers for the intra–EU second-hand market 
of  motor  vehicles.  While  the  new-car  market  is  increasingly  being  shaped  by 
commercial customers, more and more private customers are tapping into the used-
car market. Overall, used cars are newer and have better technology today than they 
did in the 1980s. In terms of quality, “young used cars,” which once belonged to car-
rental  agencies  or  served  as  company  cars  or  demonstration  vehicles,  are  very 
difficult to distinguish from new cars. But they can be purchased at just a fraction of 
the  original  price23.  The  assumption  in  this  impact  assessment  is  that  second-hand 
traders, which are mostly SMEs, are directly affected by the problems identified in 
this document. Although one can assume that these traders will not register the motor 
vehicles purchased in another Member State and that the registration will be done by 
the  customer,  a  professional  second-hand  trader  will  be  in  a  position  to  provide  its 
(potential)  clients  with  all  the  paperwork,  including  roadworthiness  certificates  and 
inspection results. Moreover, these firms face the problem of transferring individual 
motor vehicles since temporary registration tend to be fairly restrictive and so-called 
‘professional  registrations’  for  motor  vehicles  are  often  not  recognised  in  other 
Member States. However, a fairly recent phenomenon on the second-hand market of 
motor  vehicles  is  the  so-called  ‘car  supermarkets’  which  undertake  practically  no 

19 

20 
21 
22 
23 

CARFAX  Europe  GmbH,  Musiol  Munzinger  Sasserath  Gesellschaft  für  umsetzungsorientierte 
Markenberatung  und  Markenentwicklung  mbH,  F.A.Z.-Institut  für  Management-,  Markt-  und 
Medieninformationen GmbH, „Used Cars: from Outsider to Market Driver”, August 2009. 
ACEA and Oko institute e.V. Transport and Mobility COWI 2001. 
See Annex 4 for more detailed figures.  
See Annex 4 for more detailed figures.  
CARFAX  Europe  GmbH,  Musiol  Munzinger  Sasserath  Gesellschaft  für  umsetzungsorientierte 
Markenberatung  und  Markenentwicklung  mbH,  F.A.Z.-Institut  für  Management-,  Markt-  und 
Medieninformationen GmbH, „Used Cars: from Outsider to Market Driver”, August 2009. 

EN 

17 

   EN 

 
                                                 
sales of new cars but mainly of pre-registered cars. Pre-registered cars are often “like 
new”  cars  except  that,  through  the  mechanism  of  pre-registration,  the  dealer  or 
vehicle manufacturer can sell at a lower price without having to lower the price of all 
its inventory. Sales in this form do not enter the statistics as sales of new cars and it 
is  therefore  difficult  to  assess  their  magnitude.  It  is  common  that  car  supermarkets 
selling new cars source these cars from abroad. This often implies some variation in 
specifications. For more flexible buyers, car supermarkets can be a good way to get a 
new car quickly and cheaply. Car supermarkets engaged in selling imported new cars 
have  so  far  benefited  from  large  price  differences  between  Member  States  and  are 
thus  an  established  part  of  the  distribution  landscape  in  many  countries,  including 
Belgium and the Netherlands, Italy and the UK. Future trends may be favourable to 
this  new  retail  format.  According  to  a  survey  by  UK  trade  magazine  Auto  Trader, 
one in five UK owners have bought from a car supermarket, and one in three would 
consider buying from one in the future24.  

In theory, leasing companies could face registration problems, at least if they are the 
holder of the registration certificate and the vehicle is used by a person established in 
another  Member  State.  Leasing  firms  retain  the  ownership  of  the  leased  motor 
vehicles  throughout  the  life  of  the  contract  whereby  they  convey  to  the  lessee,  in 
return for a payment or series of payments, the right to use the motor vehicle for an 
agreed period of time25. Leasing firms usually also offer long term automotive rental 
contracts.  This  is  a  specific  kind  of  leasing,  whereby  businesses  outsource  their 
vehicle  fleet  needs  to  a  leasing  company  which  provides  the  necessary  passenger 
cars, vans or trucks to the client, along with any required related services, including 
maintenance,  insurance,  fuel  management  and/or  tyre  replacements.  Automotive 
assets, i.e. passenger cars and commercial vehicles, accounted for about 55% (€124.1 
billion)  of  total  new  leasing  contracts  agreed  in  2010,  remaining  the  largest 
individual  asset  segment  of  the  European  leasing  market.  It  is  estimated  that 
European  leasing  companies  financed  some  5.8  million  passenger  cars  in  201026. 
There are indications that employers increasingly rely on leasing arrangements rather 
than ownership when providing cars to their employees. In practice, however, many 
leasing  companies  seem  to  prefer  that  the  client  appears,  in  the  national  motor 
vehicle register and on the registration certificate, as the holder of the vehicle while 
the leasing company appears as the legal owner. By not being the formal holder of 
the  vehicle,  a  leasing  company  can  avoid  any  liability  for  the  settlement  of  traffic 
offences or for the payment of road taxes. 

Car-rental  companies  are  equally  affected  by  the  problem  but  in  a  very  different 
manner.  These  companies  rent  out  motor  vehicles  to  private  or  professional  clients 
for a relatively short period of time in order to meet their respective transport needs. 

24 
25 

26 

http://ec.europa.eu/competition/sectors/motor_vehicles/documents/block_exemption_final.pdf.  
According to IAS 17.4, a lease is classified as a finance lease if it transfers substantially all the risks and 
rewards incident to ownership. All other leases are classified as operating leases. Classification is made 
at  the  inception  of  the  lease.  Whether  a  lease  is  a finance  lease  or  an  operating  lease  depends  on  the 
substance of the transaction rather than the form. Situations that would normally lead to a lease being 
classified  as  a  finance  lease  are,  for  example,  when  the  lease  transfers  ownership  of  the  asset  to  the 
lessee by the end of the lease term, or when the lessee has the option to purchase the asset at a price 
which  is  expected  to  be  sufficiently  lower  than  fair  value  at  the  date  the  option  becomes  exercisable 
that, at the inception of the lease, it is reasonably certain that the option will be exercised [IAS 17.10].  
See Annex 4 for more detailed figures.  

EN 

18 

   EN 

 
                                                 
Besides the traditional car-rental services (as a means of transport to complete a train 
or plane journey or as a replacement vehicle), truck rental is a growing sector. The 
EU fleet for short-term rental is estimated at 1.4 million vehicles, split into about 1 
million cars and 400,000 light commercial vehicles. Car-rental fleets are usually very 
new,  in  particular  for  large  cross-border  companies,  as  vehicles  remain  in  the  fleet 
for about 6-9 months, and are subsequently bought back by manufacturers.  

Registration  authorities  are  very  much  affected  by  the  problem.  During  the  public 
consultation, public authorities highlighted that the main problems for them relate to 
differences between Member States in registration procedures and to the exchange of 
information  required  for  re-registering  motor  vehicles.  In  addition,  not  all  Member 
States  de-register  motor  vehicles  automatically  after  receiving  notification,  and  this 
leads  to  even  longer  and  more  complicated  re-registration  procedures  for  all 
concerned. Furthermore, the re-registration of a motor vehicle previously registered 
in another Member State is sometimes used for legalising stolen vehicles or vehicle 
documents.  Stolen  vehicles  are  often  sold  with  their  identity  changed,  for  example 
through  ‘cloning’  (i.e.  a  practice  whereby  a  vehicle  is  stolen  and  then  its  genuine 
identity markings removed and changed to reflect the identity of a legitimate vehicle 
that is currently in use on the road, so that the stolen vehicle assumes the identity of 
the  legitimate  vehicle  and  two  vehicles  are  now  being  used  with  the  same  vehicle 
registration number) or ‘ringing’ (i.e. the practice where a stolen vehicle’s identity is 
swapped  with  that  of  a  salvaged  vehicle).  This  can  only  be  prevented  by  a  close 
cooperation between registration authorities27. 

2.5.1. 

Summary 

Who is affected? 

Affected by the 
problem in which 
Member State 
should the vehicle 
be registered 

Affected by the 
modalities of the 
registration 

Citizens  purchasing  a  second-hand  motor  vehicle 
in another Member State  
Citizens  moving  permanently  to  another  Member 
State with their vehicle  
Citizens living part of the year in another Member 
State 
Citizens  working  across  borders  with  a  company 
car 
Intra–EU second-hand market of motor vehicles 
Leasing and car-rental enterprises 
National registration authorities 

No 

No 

Yes 

Yes 

No 
Yes 
Yes 

2.5.2.  Figures about the size of the problem 

Yes 

Yes 

Yes 

Yes 

Yes 
Yes 
No 

Precise  statistics  about  the  exact  number  of  difficulties  encountered  during  the  re-
registration process do not yet exist. The current statistics only relate to the number 
registrations that were granted and do not provide any information on the length of 
the  procedure,  the  number  of  persons  that  have  given  up  during  the  procedure,  the 

27 

Council  Decisions  2004/919/EC,  2008/615/JHA  and  2008/616/JHA  aim  at  combating  cross-border 
vehicle crime. More information about these Decisions can be found in Annex 2.  

EN 

19 

   EN 

 
                                                 
number of persons who are the subject of conflicting registration rules or the number 
of  persons  that  avoided  the  re-registration  by  keeping  their  original  registration 
number,  for  example  to  avoid  or  evade  taxes  or  the  payment  of  penalties  for  local 
traffic violations. Most of the difficulties encountered by persons who wish and fail 
to re-register their vehicle in another Member States are not or incidentally reported 
to national authorities, consumer organisations or the Commission. Difficulties faced 
by persons who still have a legally valid vehicle registration in another Member State 
but who are obliged to register their vehicle in the Member State where they work or 
live, are equally not reported. 

Nevertheless,  in  the  period  2000-2011,  the  Commission  handled  114  official 
complaints  about  car  registration  problems  while  the  Court  of  Justice  delivered  17 
judgments  and  orders  about  car  registration  (see  Annex  2).  The  SOLVIT  annual 
report  for  2010  indicates  that  cases  concerning  driving  licences  and  vehicle 
registrations cumulatively account for 6% of the overall case load, with an increase 
of 5% compared to 200928. An analysis of questions and problems handled by Your 
Europe  Advice  (YEA,  former  Citizens  Signpost  Service)  and  SOLVIT  in  2009 
shows the following results: 

Database 

Category level 1 

Category level 2 

SOLVIT 
YEA 

Motor vehicle registration 
Motor-vehicles 

Import 
and registration 

type-approval 

Nbr of cases in 
database 

128
714

Several  National  Registration  Authorities  have  also  acknowledged  in  the  public 
consultation  that  they  receive  a  substantial  share  of  complaints  on  re-registration 
from  national  SOLVIT  centres.  With  respect  to  vehicle  registration,  a  substantial 
share  of  cases  concerned  the  importation  into  the  Member  State  of  motor  vehicles 
purchased  in  another  Member  State.  Another  large  share  involved  enterprises  that 
want to use their vehicles in a Member State different from that of first registration.  

2.5.3.  Estimation of the costs of the current system (baseline scenario) 

The  duration  of  the  process  of  de-registration  is  estimated  to  take  an  average  of  1 
week.  For  re-registration  in  another  Member  State,  the  process  lasts  on  average  4 
weeks. The total duration of the process is around 5 weeks. This has been estimated 
on  the  basis  of  data  received  in  the  public  consultation  and  from  interviews  with 
Member  States.  For  calculation  purposes,  the  basic  assumption  is  that  3.5  million 
vehicles are transferred to another Member State per year. 

2.5.3.1.  Administrative costs  

The  unit  cost  of  de-registration  and  re-registration  procedures  is  estimated  at  €400 
for  citizens  and  for  businesses  and  €29  for  public  authorities  (this  reflects  the 

28 

European Commission, Internal Market and Services, SOLVIT - 2010 Report, 2011. In total, there were 
75  vehicle  registration  and  11  driving  licence  cases  in  2010,  according  to  this  report.  For  a  more 
detailed  description  of  the  of  questions  and  problems  handled  by  the  EU  information  and  assistance 
services  (i.e.  Europe  Direct  Contact  Centres  (EDCC),  Your  Europe  Advice  (YEA,  former  Citizens 
Signpost  Service),  European  Consumer  Centres  (ECC),  Enterprise  Europe  Network  and  SOLVIT)  in 
2009, see section 8.1.3 of Annex I. 

EN 

20 

   EN 

 
 
                                                 
effective time  devoted to this  procedure  as  well  as  the fees  paid).  The  total  current 
annual administrative costs are estimated (on the basis of the Standard Costs model) 
at around EUR 1400 million for citizens and for businesses and EUR 100 million for 
public authorities, which totals around EUR 1500 million euro.  

Estimated annual costs EUR million 

Citizens and companies 
Public authorities  
Total administrative costs 

2.5.3.2.  Other impacts: Profit loss  

1,400 
100
1,500

Other  economic  impacts  for  companies  derive  from  not  being  able  to  use  the  car 
while the de-registration/re-registration procedure is on going. This loss of profits is 
estimated at around 336 million. 

Profit loss 

Estimated annual costs (EUR million) 

336

2.5.3.3.  Additional costs for car rental companies 

Additionally,  there  are  specific  impacts  for  car  rental  companies  resulting  from  the 
nature of their business. One impact is the high costs of one-way rental associated to 
the costs of repatriation of the car. In most cases, companies decide not to re register 
the car in the country of destination because of excessive costs. Either they rent it to 
a client with the same nationality of the number plate of the vehicle or they drive it 
back. This cost is passed on to the final consumer through higher prices. The overall 
cost  of  this  amounts  to  EUR  418  million  annually.  There  is  also  a  loss  of  profits 
derived  from  lower  demand  due  to  the  very  high  price  of  this  service.  This  is 
estimated  at  EUR  202  million.  Finally,  companies  face  the  constraint  of  not  being 
able  to  meet  peak  seasonal  demand  due  to  the  impossibility  of  easily  moving  fleet 
from one Member State to another. As a result, they suffer a loss of profits of around 
EUR 16 million annually. 

Estimated annual costs (EUR million) 

One-way rentals costs 
Loss of demand 
Peak seasonal demand loss 
Additional costs for car rental companies 

418
202
16
636

The  current  procedures  generate  significant  administrative  and  other  costs  for 
citizens,  businesses  and  public  authorities  that  amount  to  EUR  2472  million 
annually. 

2.5.3.4.  Other costs 

Other possible costs for private citizens (having to resort to other transport solutions 
or reduce their mobility) and for businesses (such as cost of having a larger fleet than 
otherwise needed in a given country or the depreciation of the vehicle) have not been 
quantitatively  estimated.  The  number  of  vehicles  is  also  a  conservative  estimation. 
Therefore, real costs could be higher. 

EN 

21 

   EN 

 
 
 
 
 
 
2.6. 

Foreseen evolution of the problem 

• 

The  percentage  of  citizens  working  in  a  different  Member  State  than  their 
Member  State  of  origin  has  shown  an  increasing  trend  in  the  last  few  years 
amounting  to  around  6  million  in  2010,  which  represents  around  3%  of  total 
workers  in  the  EU.  The  number  of  cross-border  workers  has  increased  30% 
since  2005,  reaching  around  1  million  in  2010.  One  can  expect  this  trend  to 
continue in coming years. 

Intra-EU movement of workers

)
0
0
0
(

r
e
b
m
u
N

7000

6000

5000

4000

3000

2000

1000

0

Permanently
employed in
different MS

Cross-border
workers

Permanently employed in
different MS

Cross-border workers

2005

2006

2007

2008

2009

2010

4237

4825

5300

5717

5792

5983

774

876

988

1010

965

1020

Year

Source: EUROSTAT

• 

Cross-border  exchange  of  information  on  road  safety  related  traffic  offences 
will  improve  profoundly.  Directive  2011/82/EU  facilitating  the  cross-border 
exchange of information on road safety related traffic offences29 will have to be 
transposed  by  Member  States  (except  Denmark)  by  7  November  201330.  The 
objective of the Directive is to improve road safety by establishing a system of 
information  exchange  between  the  State  of  the  offence  and  the  State  of 
registration on the most serious road safety infringements. It serves to identify 
the vehicle owner who has committed an offence in a Member State other than 
the one where his vehicle is registered. The Member State of the offence would 
then be in a position to prosecute and sanction him. The offences covered by 
the  Directive  include  speeding,  non-use  of  a  seat-belt,  failing  to  stop  at  a  red 
traffic  light  and  drink-driving.  The  Directive  also  sets  out  the  exchange 
procedures (data, responsible authorities and network) and the establishment of 
an EU network for this exchange of information. 

• 

Obtaining  information  about  the  payment  of  road  and  circulation  taxes  will 
become much easier. The new Council Directive 2011/16/EU on administrative 

29 

30 

Directive 2011/82/EU of the European Parliament and of the Council of 25 October 2011 facilitating 
the cross-border exchange of information on road safety related traffic offences, JO L288 of 5.11.2011, 
p. 1. 
Subject  to  the  outcome  of  the  proceedings  at  the  Court  of  Justice,  following  the  action  taken  by  the 
Commission [Decision C(2012)438 of 25.1.2012]. 

EN 

22 

   EN 

 
 
 
 
                                                 
cooperation in the field of taxation31 lays down the rules and procedures under 
which  the  Member  States  must  cooperate  with  each  other  to  exchange 
information that is foreseeably relevant to the administration and enforcement 
of  the  domestic  laws  of  the  Member  States  concerning,  inter  alia,  road  and 
circulation  taxes.  The  Directive  also  contains  provisions  for  the  electronic 
exchange of information and will be applied from 1 January 2013 onwards. In 
addition,  Council  Directive  2010/24/EU  concerning  mutual  assistance  for  the 
recovery of claims relating to taxes, duties and other measures32 lays down the 
rules under which the Member States must provide assistance for the recovery 
in  a  Member  State  of  any  claims  which  arise  in  another  Member  State  with 
respect to, inter alia, road and circulation taxes. This Directive is applied from 
1 January 2012. 

2.7. 

EU right to act 

The  cross-border  aspects  of  car  registration  continue  causing  problems  within  the 
internal market. For example, there were 17 judgements and orders of the Court of 
Justice  on  the  obstacles,  caused  by  car  registration  related  matters,  to  the  free 
movement of goods, services and persons33.  

Current problems and differences in administrative rules at national level as regards 
the  re-registration  of  motor  vehicles  previously  registered  in  another  Member  State 
impede the free movement of these vehicles within the EU. The EU has therefore the 
right  to  act  on  the  basis  of  Article  114  TFEU,  in  order  to  ensure  the  proper 
functioning  of  the  single  market  for  second-hand  motor  vehicles  purchased  in 
another  member  state,  for  citizens  transferring  a  motor  vehicle  to  another  Member 
State of residence, for citizens using a motor vehicle registered in the Member State 
of employment, as well as for car-rental firms (and to a lesser extent leasing firms) 
which,  due  to  registration  requirements  for  themselves  or  their  client,  encounter 
barriers for the cross-border use of these vehicles.  

In order to comply with the subsidiarity principle, the initiative should however not 
consider  options  concerning  the  re-registrations  within  the  same  Member  State,  or 
the transfer of a motor vehicle within the same Member State. The proportionality of 
the remaining policy options will be subsequently assessed in this report. 

During  the  public  consultation,  a  signification  majority  in  each  category  of 
stakeholders  considered  that  action  should  be  taken  at  EU  level  to  improve  the 
current  situation.  All  public  authorities  that  contributed  to  the  consultation  are  in 
favour of action being taken at EU level. 

31 

32 

33 

Council  Directive  2011/16/EU  of  15  February  2011  on  administrative  cooperation  in  the  field  of 
taxation and repealing Directive 77/799/EEC, OJ L64 of 11.3.2011, p. 1. 
Council  Directive  2010/24/EU  of  16 March  2010  concerning  mutual  assistance  for  the  recovery  of 
claims relating to taxes, duties and other measures, OJ L84 of 31.3.2010, p. 1. 
See Annex 2. 

EN 

23 

   EN 

 
                                                 
100,00%

80,00%

60,00%

40,00%

20,00%

0,00%

92,30%

7,70%

57,30%

42,70%

100%

0%

Yes

No

Citizens

Business

Public authority

3. 

OBJECTIVES  

3.1. 

General policy objectives 

The  general  objective  of  this  initiative  is  to  improve  the  functioning  of  the  single 
market through the elimination of administrative barriers related to the re-registration 
procedure of motor vehicles, which currently hinder the free movement of goods. 

3.2. 

Specific policy objectives 

The specific objectives of this initiative are: 

• 

• 

To  harmonise,  streamline,  and  simplify  the  procedures  for  re-registration  of 
motor  vehicles  previously  registered  in  another  Member  State,  for  citizens, 
employees,  employers,  car  rental  and  leasing  companies,  and  registration 
authorities; 

To  consequently  reduce  the  administrative  burdens  of  all  actors  involved 
without hindering road safety or the prevention of crimes and fraud;  

3.3. 

Operational policy objectives 

The operational objectives to be accomplished by this initiative are the following: 

– 

– 

– 

To  determine  in  which  Member  State  a  motor  vehicle  transferred  between 
Member States should be registered; 

To reduce the time of de- and re-registration procedures;  

To  reduce  the  administrative  burden  on  citizens  and  undertakings  by  limiting 
the  number  of  documents  necessary  to  carry  out  the  re-registration  procedure 
and by facilitating data exchange between national registration authorities. 

4. 

POLICY OPTIONS  

4.1. 

Assumptions 

The policy options were developed on the basis of the following assumptions: 

EN 

24 

   EN 

 
 
 
• 

The first registration of a new motor vehicle in the EU usually takes place in 
the  Member  State  of  residence/establishment  of  the  applicant  (i.e.  the  future 
holder  of  the  registration  certificate)  although  new  motor  vehicles  are 
sometimes  registered  by  a  car  dealer  in  one  Member  State  and  subsequently 
purchased by a customer residing in another Member State.  

•  Member States remain free to exercise their power of taxation with respect to 
motor  vehicles  on  the  basis  of  the  territory  on  which  the  vehicle  is  actually 
used, or the residence of the driver. For example, circulation taxes are levied by 
the Member State in which the motor vehicle is registered or the Member State 
where the vehicle is essentially used.  

• 

None of the options concern the re-registrations within the same Member State, 
or the transfer of a motor vehicle within the same Member State.  

4.2. 

Description of policy options 

One  policy  option  was  discarded  at  an  early  stage,  as  set  out  in  Annex  6  of  this 
impact assessment. The policy options to be assessed would be the following:  

• 

• 

• 

• 

• 

Baseline  option:  infringement  proceedings  and  interpretative  communications 
published by the Commission. 

Option  1:  Single  registration  for  the  entire  life-cycle  of  the  motor  vehicle 
(“Single Registration”): The motor vehicle is registered once in the EU for its 
entire life-cycle. Motor vehicles keep their original registration until they reach 
the  end-of-life  status.  When  the  vehicle  is  transferred  to  a  new  holder,  the 
original registration is maintained. 

Option 2: the holder keeps his/her registration throughout the EU but a transfer 
of the vehicle to a new holder requires a new registration: Every holder (i.e. the 
holder  of  the  registration  certificate)  keeps  his/her  own  registration  until  the 
vehicle is transferred to another holder. In other words, motor vehicles should 
not  be  re-registered  when  the  holder  changes  his/her  residence  to  another 
Member  State.  In  that  case,  however,  he/she  should  inform  the  authorities  of 
their new Member State which in turn should inform their counterparts in the 
Member  State  of  registration.  A  transfer  of  the  vehicle  to  another  holder, 
however, would require re-registration. 

Option  3:  registration  in  the  Member  State  of  the  holder  of  the  vehicle  and 
simplified re-registration. When the holder moves his/her residence to another 
Member  State  or  when  the  vehicle  is  transferred  to  another  holder  in  another 
Member  State,  the  motor  vehicle  would  have  to  be  re-registered  but  a 
simplified  registration  procedure  would  apply.  This  simplified  procedure 
would limit the paperwork and the number of controls, through a detailed list 
of documents which may or may not be requested, and an explicit prohibition 
to request supplementary documents.  

Option 4: registration in the Member State where the motor vehicle is primarily 
used  and simplified re-registration. The motor vehicle should be registered in 
the Member State of primary use of the motor vehicle, even when the holder of 

EN 

25 

   EN 

 
the  registration  certificate  resides  permanently  or  is  established  in  another 
Member State. Thus, the motor vehicle must be registered in the Member State 
where  the  motor  vehicle  is  primarily  used.  The  registration  procedure, 
however, would be simplified as under option 3. 

• 

Option  5:  optimising  the  electronic  exchange  of  information  among  national 
registration authorities. The technical information about the motor vehicle and 
the latest registration details in the Member State where the motor vehicle was 
registered would be electronically gathered by the registration authorities in the 
Member State of destination, through the EUCARIS system34.  

34 

A detailed description of the electronic exchange of vehicle registration data is set out in Annex 5. 

EN 

26 

   EN 

 
                                                 
PROBLEMS  

CAUSES  

OBJECTIVES 

OPTIONS 

It  is  not  clear  where  and 
when  a  motor  vehicle 
registered  in  a  Member 
State  has  to  be  registered 
in another Member State 

-  Each  Member  State  has  its  own  registration 
system  with  different 
requirements:  not 
recognition of registration documents delivered 
information  and/or 
or 
undergo technical inspections 

request  of 

further 

-  There  is  the obligation  to  register  the vehicle 
permanently  used  in  the  territory  of  a  MS 
despite the fact the vehicle is already registered 
in another MS. However it is not clear what it is 
understood by “permanently used” 

to  proceed  when 

-Legal  uncertainty:  Cross-border  workers  and 
citizens  in  general  do  not  know  their  right  and 
how 
facing  conflicting 
registration  requirements  from  two  Member 
States 
-  market 
failure).  

information 

(Imperfect 

Improve  the  functioning  of  the  single 
market  

Option 1: single registration in the 
Member State of first registration 

a)  remove  the  legal  uncertainty  by 
clarifying registration procedure 

b) clarify the rights and obligations of 
actors 
the  registration 
in 
procedure 

involved 

in 

registration 

the 
Option  2: 
Member  State  of 
residence/ 
establishment  at  the  moment  of 
re-registration 
registration.  No 
to 
when  change  of  residence 
another Member State. 

registration 

Option  3: 
the 
Member State of the holder of the 
vehicle 
re-
registration 

simplified 

and 

in 

registration 

Option  4: 
the 
country  of  use  and  simplified  re-
registration 

in 

Re-registration  procedures 
are  very  burdensome  and 
lengthy 

-There  is  hardly  any  exchange  of  information 
between  registration  authorities  so  that  the 
Member State of destination has no information 
on  the  motor  vehicle  previously  registered  in 
another  Member  State.  Registration  authorities 
can  only  rely  on  the  information  present  on 
their 
(Imperfect 
databases 
information - market failure).  

national 

Improve  the  functioning  of  the  single 
market: 

a) Harmonise, streamline and simplify 
the 
re-registration 
of 
procedure 

procedure 

b)  reduce  the  lead-time  of  de-  and  re- 
registration procedures 

Option 1: no re-registration 

establishment 

Option  2:  no  re-registration  if  the 
holder  moves  his/her residence  or 
its 
another 
Member  State.  Re-registration 
when  the  vehicle  is  transferred  to 
a new holder. 

to 

-  Procedural  problems  with  cross-border  re-
registration procedures: citizens and businesses 
often  do  not  sufficiently  know  or  understand 
their rights and do not know where to look for 
information  or  help  on  the  registration  of  a 
motor  vehicle  previously  registered  in  another 
registration 
Member 
authorities  fail  to  sufficiently  understand  the 

Likewise, 

State. 

c)  reduce  the  administrative  burden 
the 
the  burden  of  proof  on 
and 
applicant  

d)  facilitate  data  exchange  between 
national 
to 
eliminate the lack of trust  

registration  authorities 

e)  mutual  recognition  of  documents 

3: 

simplified 

re-
Option 
registration  in  the  Member  State 
to which the holder moved his/her 
residence  or  its  establishment,  or 
in  the  Member  State  of  the  new 
holder. 

EN 

27 

EN 

 
  
 
rules  for  cross-border  cases  and  how  to  apply 
them 
information-  market 
failure).  

(Imperfect 

-  Procedures  and  information  requirements  are 
defined  too  broadly  in  the  existing  European 
legislation. 
legal 
framework –regulatory failure) 

(Inadequately  defined 

-  lack  of  trust  among  national  registration 
authorities 

-  Burden  of  proof  is  put  on  the  applicant  who 
has  to  provide  documents  and  information  not 
always at his disposal 

delivered 
registration authorities. 

by 

another  European 

4: 

simplified 

re-
Option 
registration  in  the  Member  State 
where  the  vehicle  is  primarily 
used. 

option 5: optimising the exchange 
of 
information  among  national 
registration authorities 

EN 

28 

EN 

 
  
 
 
 
5. 

ANALYSIS OF IMPACTS 

5.1. 

Base-line option 

As  described  above.  It  serves  as  a  reference  against  which  the  other  options  are 
assessed. 

5.2. 

Option  1:  Single  registration  for  the  entire  life  of  the  motor  vehicle  (“single 
registration)  

5.2.1.  Qualitative assessment 

• 

This option would have vast negative impacts on road safety (roadworthiness 
tests),  traffic  enforcement  and  car  crime,  motor  insurance,  the  second-hand 
market  and  the  levying  of  registration  and  circulation  taxes.  Without 
complementary  measures,  this  option  would  cut  the  link  between  the 
registration  and  the  owner  or  user  of  the  car  thus  making  it  impossible  to 
identify  them  through  the  motor  vehicle  register.  In  fact,  one  of  the  current 
objectives  of  motor  vehicle  registration  is  to  identify  the  holder  of  the  motor 
vehicle. The negative consequences would be the following: 

– 

– 

– 

This  option  would  impede  the  effective  organisation  of  roadworthiness 
testing since it would be difficult to find the owner or user of the car. In 
addition,  since  roadworthiness  tests  must  be  performed  in  the  Member 
State of registration, the holders of the vehicles would have to drive back, 
at regular intervals, to the Member of registration for these tests.  

As  it  would  be  possible  to  freely  transfer  a  motor  vehicle  within  the 
European Union on a permanent basis without any further requirements, 
it  would  be  very  difficult  to  track  the  actual  holder  in  case  of  traffic 
offences  or  car  crime.  It  would  also  be  difficult  to  know  where  traffic 
fines and/or notifications should be sent. Another difficulty would be the 
tracking of stolen vehicles as the requirement to re-register the vehicle or 
to  inform  the  Member  State  of  its  existence  on  their  territory  would  be 
removed. 

Specific  problems  would  also  arise  in  cases  of  repeated  offences  by  a 
vehicle  belonging  to  a  non-resident.  According  to  current  European 
legislation  such  situations  must  be  reported  to  the  authorities  in  the  EU 
country  where  the  vehicle  is  registered.  The  country  in  which  the 
offences have been committed may then request that their counterpart in 
the Member State where the vehicle is registered take action against the 
offender.  Under  this  option  this  would  no  longer  be  possible  or  at  least 
would be very difficult as the country where the car is first registered is 
not necessarily the country where the offender has his residence. 

– 

Through  a  single  registration,  registration  taxes  would  be  paid,  where 
applicable, only once in the whole life of the motor vehicle. This would 
suppose an important loss of revenues for Member States.  

EN 

29 

   EN 

 
– 

– 

– 

– 

There  are  comparable  problems  for  circulation  taxes  which  are  usually 
paid  in  the  Member  State  where  the  vehicle  is  registered  or  in  the 
Member State where the vehicle is essentially used. As a consequence, it 
could  be  possible  that  the  holder  would  be  requested  to  pay  circulation 
taxes  in  two  Member  States  when  the  vehicle  is  transferred  to  another 
Member State. It would be difficult to prevent this double taxation.  

For the same reasons, it would complicate the effective functioning of the 
compulsory  insurance  against  civil  liability  for  motor  vehicles  (“motor 
insurance”).  Under  this  option  it  would  be  very  difficult  for  insurance 
companies to know in which Member State the motor vehicle would be 
primarily used. As a consequence insurance companies would not be able 
to  apply  the  localisation  of  risk  principle  that  is  used  to  calculate  their 
premiums. A not notified change of residence would not only affect the 
calculation of the premium but could also undermine the validity of the 
insurance  contract.  The  insurer  may  not  be  authorised  to  provide  its 
services in the Member State of destination or may not willing to do so 
(due,  inter  alia,  to  their  difficulties  to  calculate  the  risk  in  another 
Member State).  

This  option  might  have  negative  consequences  for  the  functioning  of 
Council  Decision  2004/919/EC  on  tackling  vehicle  crime  with  cross-
border implications. This Decision implicitly uses the registration process 
as  a  tool  for  tracking  stolen  vehicles  so  that  this  option  would  most 
probably  require  new  actions  to  tackle  vehicle  crime  with  cross-border 
implications. 

Finally,  since  the  first  holder  of  the  motor  vehicle  would  be  the  only 
person known to the registration authorities, this option would discourage 
them  from  transferring  the  motor  vehicle  to  another  person  since  the 
latter would remain unknown to registration authorities and so that only 
the  former  would  be  contacted  for  any  difficulties  caused  by  the  new 
holder (e.g. non-payment of taxes, road offences etc). 

• 

Positive impacts: 

– 

Citizens bringing their vehicle into  the country of residence: Under this 
option,  citizens  would  be  able  to  move  permanently  with  their  vehicles 
from  one  Member  State  to  another  without  any  further  administrative 
obligation as regards their vehicles. This would suppose the elimination 
of  re-registration  and  de-registration  procedures  for  motor  vehicles 
already  registered  elsewhere  in  the  EU.  Thus,  citizens  would  save 
significant  time  and  money.  As  a  consequence  there  would  be  no 
differences  between  driving  the  vehicle  permanently  in  one  Member 
State or in several. Furthermore, by linking the registration to the vehicle, 
citizens would further avoid the re-registration if the holder of the motor 
vehicle changes.  

– 

Cross-border  workers.  Although  Directive  83/182/EC  and  2009/55/EC 
provide guidance for taxation purposes, it is currently not clear where the 
vehicle  has  to  be  registered  when  the  cross-border  worker  has  both 

EN 

30 

   EN 

 
– 

– 

– 

– 

personal  and  occupational  interests  in  two  Member  States,  or  when  a 
cross-border  worker  lives  in  one  Member  State  but  uses  a  company 
motor vehicle registered by the employer in another Member State. This 
option  would  immediately  solve  all  uncertainty  with  regard  to  which 
Member  State  should  register  the  motor  vehicle  and  would  have  a 
positive effect on cross-border workers. 

Leasing  companies:  The  positive  aspect  of  this  option  is  that  it  would 
facilitate  cross-border  leasing  since  the  residence  of  the  holder  of  the 
certificate would determine where the vehicle should be first registered. 
Yet, the negative aspects outlined above would have an important impact 
on  leasing  companies  who  are  the  formal  holders  of  the  registration 
certificate and that would be responsible for transferring the ownership of 
the vehicle. 

Car-rental  companies:  This  option  would  allow  car  rental  companies  to 
meet  seasonal  demand  as  they  would  be  able  to  move  their  fleet  freely 
across the European Union thus removing an important barrier to cross-
borders  rentals.  As  a  direct  consequence  of  the  removal  of  the  current 
barriers  to  the  free  movement  of  services,  one  could  expect  more 
competition and lower prices for consumers. Car rental companies would 
have  fewer  costs  as  they  would  not  have  to  repatriate  the  vehicles  in 
trucks to the Member State of registration. From an environmental point 
of view, this option would contribute to the reduction of CO2 emissions 
generated  by  the  current  repatriation  system.  One  could  also  envisage 
that  this  option  would  provide  indirect  positive  impacts  on  European 
tourism. However, the negative impacts set out above would start taking 
effect when the car-rental companies decide to remove the vehicle from 
their stock (e.g. by selling it or by returning it to the manufacturer). 

Intra-EU trade of second-hand vehicles: this option would eliminate the 
administrative barrier of registration and would therefore have a positive 
impact on EU market of second-hand vehicles. 

Registration  authorities.  In  theory,  this  option  would  remove  the  legal 
uncertainty  and  potential  contradiction  of  different  national  registration 
requirements.  There  would  be  no  difficulties  for  national  registration 
authorities  since  they  would  only  register  new  motor  vehicles  and  they 
would  remain  registered  until  their  scrapping.  In  practice,  however,  the 
negative 
traffic 
enforcement, motor insurance and the levying of circulation taxes would 
heavily complicate the functioning of the registration authorities. 

(roadworthiness 

road  safety 

impacts  on 

tests), 

5.2.2.  Reduction of administrative costs 

The elimination of the need for de-registration and re-registration would remove the 
administrative costs for businesses and citizens as well as for public authorities that 
exist  in  the  baseline  scenario.  This  would  deliver  savings  of  EUR  1,500  million 
annually. The profit loss would also be eliminated, because the vehicle could now be 
used  without  interruption.  This  would  allow  savings  of  around  EUR  336  million 
annually. The specific costs for car rental companies would also disappear with this 

EN 

31 

   EN 

 
policy option (EUR 636 million) as they would be able to transfer cars across borders 
without constraints. 

OPTION 1: SINGLE REGISTRATION 

Citizens and businesses 
Public authorities 
Total administrative costs ( A) 
Profit loss (B) 
Savings on one-way rentals costs 
Savings on loss of demand 
Peak seasonal demand  
Total additional savings car rental companies (C)  
TOTAL ( A+B+C) 

Estimated annual 
savings compared to 
the baseline option 
(EUR million) 

1400 
100
1,500
336
418
202
16
636
2,472

This  option  would  allow  savings  (administrative  costs)  estimated  at  EUR  2,472 
million annually. 

5.3. 

Option  2:  No  re-registration  in  the  Member  State  of  destination  if  the  holder 
remains the same person 

5.3.1.1.  Qualitative assessment 

During the public consultation, 54.9 % of businesses, 69.7 % of citizens and 41.7 % 
of  public  authorities  replied  that  the  current  situation  could  be  improved  by  a  new 
EU system that recognises vehicles already registered in another Member State. For 
23.4% of businesses, 15.4% of citizens and 16.7% of public authorities this measure 
alone would not completely solve the current problems, and should be accompanied 
by additional measures.  

• 

– 

Positive impacts: 

In order to assess the impacts on citizens moving to another Member State, one 
should distinguish three sub-options: 

(a)  Sub-option 2a: Under this sub-option, citizens moving their residence to 
another Member State would be able to move with their vehicles without 
any  further  administrative  obligation  as  regards  their  vehicles.  This 
would  suppose  that  re-registration  and  de-registration  would  only  take 
place  when  there  would  be  a  new  holder  or  on  a  voluntary  basis.  The 
abolition  of  all  administrative  formalities  would  have  a  very  positive 
impact on this group of citizens if they could move residence. 

(b)  Sub-option 2b: citizens moving to another Member State could keep their 
original  vehicle  registration  but  would  have  to  inform  their  own 
registration  authorities  about  their  new  residence.  The  de-registration 
process  is  replaced  by  an  information  obligation  which  is  still  less 
burdensome  and  much  lighter  than  a  formal  de-  and  re-registration 
procedure. 

EN 

32 

   EN 

 
 
(c)  Sub-option 2c: citizens moving to another Member State could keep their 
original  vehicle  registration  but  would  have  to  inform  the  registration 
authorities  of  their  new  Member  State  about  their  new  residence.  This 
would  also  be  less  burdensome  and  much  lighter  than  a  formal 
registration procedure, although there might be a minor language barrier. 

Cross-border  workers:  this  option  would  solve  the  problem  of  cross-border 
workers  since  it  would  determine  in  which  Member  State  the  motor  vehicle 
must be registered so that the second Member State could not claim registration 
on its territory.  

Leasing  companies:  this  option  would  also  be  favourable  for  them  since  it 
would determine in which Member State the motor vehicle must be registered. 

Car-rental  companies:  This  option  would  allow  car  rental  companies  to  meet 
seasonal  demand  as  they  would  be  able  to  move  their  fleet  freely  across  the 
European  Union.  There  would  be  no  differences  between  national  and  cross-
borders rentals. Furthermore and as a direct consequence of the removal of the 
current  barriers  to  the  free  movement  of  services,  one  could  expect  more 
competition  and  lower  prices  for  consumers  since  car-rental  companies  could 
stop  repatriating  their  vehicles  in  trucks  to  the  Member  State  of  registration. 
This  option  would  also  contribute  to  a  reduction  of  the  CO2  emissions 
generated by the current repatriation system. One could also envisage that this 
option would have an indirect positive impact on European tourism.  

Registration  authorities.  Sub-option  2a  (no  formalities)  would  significantly 
reduce  the  workload  that  national  authorities  currently  have  as  regards  re-
registration procedures for motor vehicles arriving from another Member State. 
Sub-options 2b (the holder should inform the Member State of registration) and 
2c (the holder should inform the Member State to which he/she moves his/her 
residence)  would  slightly  reduce  the  administrative  burden  for  the  Member 
State  since  the  information  transmitted  by  the  citizens  would  to  have  to  be 
handled. 

Negative impacts: 

safety 

tests)  and 

(roadworthiness 

traffic  enforcement.  Since 
Road 
roadworthiness  tests  must  be  performed  in  the  Member  State  of  registration, 
the holders of the vehicles would have to drive back, at regular intervals, to the 
Member  of  registration  for  these  tests.  The  impact  on  the  effectiveness  of 
traffic enforcement would be neutral in all situations, except in the case where 
people change their residence to another Member State: 

– 

– 

– 

– 

• 

– 

(a)  Sub-option 2a (no formalities): In cases like these, it would be very 
difficult, sometimes impossible, to find the residence details within 
another  Member  State,  for  invitations  to  roadworthiness  tests  and 
for the prosecution of road offences.  

(b)  Sub-option  2b  (the  holder  should  inform  the  Member  State  of 
registration):  The  objective  of  the  information  obligation  is  to 
ensure  that  it  would  be  possible  to  find  the  address  of  the  new 

EN 

33 

   EN 

 
residence  within  another  Member  State,  for  the  sending  of 
invitations  to  roadworthiness  tests  and  for  the  prosecution  of  road 
offences. 

(c)  Sub-option  2c  (the  holder  should  inform  the  Member  State  to 
which he/she moves his/her residence): same impact as sub-option 
2b. 

– 

Car  taxation.  The  right  of  Member  States  to  levy  registration  tax  and 
circulation tax is generally based on the registration of the car in the Member 
State where the owner is resident or where the vehicle is permanently used.  

(a)  Sub-option  2a  (no  formalities):  If  the  holder  of  the  registration 
certificate  moves  from  one  Member  State  to  another,  the  levy  of 
taxes  related  to  vehicles  will  also  in  practice  become  difficult. 
Another aspect is that it would be very difficult to levy circulation 
taxes  on  these  transferred  cars.  The  consequences  for  taxation  of 
transferring  leasing  companies  and  short  term  rental  companies' 
cars are not foreseeable. 

(b)  Sub-options  2b  (the  holder  should  inform  the  Member  State  of 
registration) and 2c (the holder should inform the Member State to 
which  he/she  moves  his/her  residence):  The  exchange  of 
information  between  authorities  might  mitigate  the  risk  that  the 
“taxable  event”  (i.e.  the  event  or  transaction  that  results  in  a  tax 
consequence for the party who executes the event) for the levy of 
registration  tax  (and  circulation  tax)  remains  unknown  for  the 
receiving  Member  State.  However,  this  depends  on  the  efficiency 
of the administrative systems and collaboration of the owner of the 
vehicle. 

– 

This  option  has  a  negative  impact  on  motor  insurance  where  people  change 
their residence to another Member State. As there would be no need, under this 
option,  to  re-register  the  vehicle,  it  would  be  very  difficult  for  insurance 
companies  to  apply  the  localisation  of  risk  principle  that  is  used  to  calculate 
their premiums.  

(a)  Sub-option 2a (no formalities): A not notified change of residence 
would  not  only  affect  the  calculation  of  premiums  but  could  also 
undermine  the  validity  of  the  insurance  contract.  The  insurer  may 
not  be  authorised  to  provide  its  services  in  the  Member  State  of 
destination or may not be willing to do so (due, inter alia, to their 
difficulties  to  calculate  the  risk  in  another  Member  State).  As  a 
consequence  the  insurance  contract  may  be  considered  invalid  by 
the insurer, and in case of accident, the victims' damages would be 
covered  by  the  guarantee  fund  which  is  funded  by  the  motor 
insurers  providing  their  services  in  that  particular  Member  State. 
Increased  uninsured  driving  increases  motor  insurance  premiums 
for law-abiding motorists.  

EN 

34 

   EN 

 
his/her 

he/she  moves 

residence):  Without 

(b)  Sub-options  2b  (the  holder  should  inform  the  Member  State  of 
registration) and 2c (the holder should inform the Member State to 
which 
any 
complementary  measure,  this  option  has  a  negative  impact  on 
motor  insurance.  The  simple  notification  of  change  of  residence 
without any further requirements (i.e. new registration plate) would 
not allow insurance companies to easily identify their vehicles, nor 
to  calculate  the  insurance  premiums  as  they  can  not  apply  the 
localisation  of  risk  principle.  The  EU  insurance  system  mainly 
relies  on  this  so-called localisation of  risk principle which is used 
by  insurers  to  calculate  their  premiums.  According  to  the  current 
European legislation on motor insurance35 the motor vehicle may - 
provided  it  is  compliant  with  the  national  registration  rules  -  be 
insured  by  an  insurer  established  in  the  Member  State  of 
registration or by an insurer established in any other Member State. 
Under this option there is a risk that insurers may not be informed 
by  the  insured  of  the  change  of  residence.  However  a  change  of 
residence  would  not  only  affect  the  calculation  of  the  insurance 
premium, but also and more importantly, the coverage of insurance 
services. The insurer may not be authorised to provide its services 
in the Member State of destination or may not be willing to do so. 
A failure of notification of the change of residence would suppose 
that  the  insurance  contract  may  be  considered  invalid  by  the 
insurer. Moreover, decoupling the Member State of registration and 
the  Member  State  where  the  vehicle  habitually  circulates  may  be 
burdensome  or  even  impossible  to  the  functioning  of  the  claims 
handling  system  which  guarantees  the  protection  of  road  traffic 
accident victims, which is one of the main objectives of the Motor 
Insurance  Directive.  The  reason  for  this  is  that  the  bodies 
responsible for compensating those victims of accidents caused by 
uninsured or 'foreign' vehicles may no longer be able to determine 
which insurer or compensation body is responsible for covering the 
damages caused. This might cause financial damage to those bodies 
in Member States with much transit traffic for example.  

• 

Neutral impact  

–  Market  of  second-hand  motor  vehicles.  This  option  would  not  eliminate  the 
current  registration  barriers  that  new  holders  often  are  confronted  with  when 
there  is  a  change  of  holder.  Under  this  option,  vehicles  would  still  be 
deregistered in the Member State of the previous holder and would have to go 
through the registration process of the Member State of the new holder. For the 
second-hand market, this option would be identical to the baseline option. 

– 

Vehicle crime: This option would probably not have any consequences on the 
functioning  of  Council  Decision  2004/919/EC  on  tackling  vehicle  crime  with 

35 

Directive 2009/103/EC of the European parliament and of the Council of 16 September 2009 relating to 
insurance  against  civil  liability  in  respect  of  the  use  of  motor  vehicles,  and  the  enforcement  of  the 
obligation to insure against such liability 

EN 

35 

   EN 

 
                                                 
cross-border  implications  so  that  this  option  would  not,  as  an  immediate 
consequence,  require  new  actions  to  tackle  vehicle  crime  with  cross-border 
implications. 

5.3.1.2.  Reduction of administrative costs 

• 

• 

• 

Sub-option  2a  (no  formalities):  The  simplifications  of 
the  procedure 
eliminating the need for de-registration and re-registration would eliminate the 
administrative costs for businesses and citizens as well as for public authorities 
that  exist  in  the  baseline  scenario.  This  would  deliver  savings  of  EUR  1,500 
million  annually.  The  loss  of  profits  would  also  be  eliminated,  because  the 
vehicle could in theory be used without interruption. This would allow savings 
of  around  EUR  336  million  annually.  The  specific  costs  for  car  rental 
companies would also disappear with this policy option (EUR 636 million) as 
they would be able to move cars across borders without constraints. 

Sub-option 2b (the holder should inform the Member State of registration): the 
effective  time  necessary  for  the  procedure  would  be  significantly  reduced 
compared  to  the  baseline  scenario,  because  the  procedure  is  limited  to  an 
information  mechanism  of  the  Member  State  of  origin36.  This  would 
significantly reduce the administrative costs resulting from the process. In this 
case  the  unit  cost  would  be  €12  for  citizens  and businesses  and  €6  for  public 
authorities.  The  administrative  costs  for  citizens  and  businesses  would  be 
reduced to around EUR 41 million and EUR 22 million for public authorities. 
Therefore, savings would be EUR 1,359 million for citizens and businesses and 
EUR  78  million  for  public  authorities,  totalling  around  EUR  1,437  million 
annually.  Loss  of  profits  would  also  be  eliminated  (savings  around  EUR  336 
million) because the vehicle could in theory be used without interruption. Car 
rental companies would not incur costs presented in the baseline scenario (only 
in a minimal cost of informing the authorities). The costs derived from the 1-
way rental expenditure would be almost completely eliminated allowing saving 
of  EUR  408  million  annually.  An  increase  in  demand  could  be  expected  that 
would  generate  an  additional  annual  profit  of  EUR  188  million.  They  would 
also  be  able  to  move  their  fleet  freely,  which  would  imply  a  profit  of  around 
EUR 15 million annually. 

Sub-option  2c  (the  holder  should  inform  the  Member  State  to  which  he/she 
moves  his/her  residence):  the  time  necessary  for  the  procedure  would  be 
significantly  reduced  because  the  procedure  is  limited  to  an  information 
mechanism of the Member State of destination. This option would significantly 
reduce  the  administrative  costs  resulting  from  the  process  for  the  different 
actors.  It  is  assumed  that  the  time  (and  derived  costs)  used  to  inform  the 
authorities  would  be  a  bit  longer  than  in  the  previous  option,  because  the 
operator will be dealing with an administration that is different from its own37. 

36 

37 

For  the  calculations,  the  assumption  is  a  reduction  of  the  effective  time  of  the  re-registration  for 
companies and citizens of 94% and of 60% for authorities. The additional assumption is that there are 
no fees to be paid. 
For  the  calculations,  the  assumption  is  a  reduction  of  the  effective  time  of  the  re-registration  for 
companies and citizens of 90% and of 45% for authorities. The additional assumption is that there are 
no fees to be paid. 

EN 

36 

   EN 

 
                                                 
The  time  spent  by  public  authorities  on  the  procedure  would  also  be  reduced 
compared  to  the  baseline  scenario.  Administrative  costs  for  citizens  and  for 
businesses  would  be  EUR  40  million  and  for  public  authorities  EUR  44 
million. Therefore the savings in terms of reduction of administrative costs for 
citizens  and  for  businesses  would  be  EUR  1,360  million  and  for  public 
authorities EUR 56 million, which totals EUR 1,416 million annually. The loss 
of profits would also be eliminated because the vehicle could in theory be used 
without interruption (savings around EUR 336 million). Car rental companies 
would not incur costs presented in the baseline scenario (only in a minimal cost 
of  informing  the  authorities).  The  costs  derived  from  the  1-way  rental 
expenditure  would  be  strongly  reduced  allowing  savings  of  EUR  407  million 
annually.  An  increase  in  demand  could  be  expected  that  would  generate  an 
additional annual profit of EUR 169 million. They would also be able to move 
their  fleet  freely,  which  would  imply  a  profit  of  around  EUR  15  million 
annually. 

OPTION 2: THE HOLDER KEEPS HIS/HER REGISTRATION BUT THE 
TRANSFER TO A NEW HOLDER REQUIRES A NEW REGISTRATION 

Citizens and businesses 
Public authorities 
Total administrative costs (A) 
Profit loss (B) 
Savings on one-way rentals costs 
Savings on loss of demand 
Peak seasonal demand  
Total  additional  savings  car 
rental companies (C) 
TOTAL ( A+B+C) 

Estimated annual savings compared to the baseline 
option (EUR million) 
Sub-option 2b 
1,359 
78 
1,437 
336 
409 
188 
15 
612 

Sub-option 2a 
1,400
100
1,500
336
418
202
16
636

Sub-option 2c 
1,360
56
1,416
336
407
169
15
591

2,472

2,385 

2,343

The  estimated  savings  vary  between  from  EUR  2,472  million  annually  (sub-option 
2a) and EUR 2,385 million annually (sub-option 2b) to EUR 2,343 million annually. 

5.4. 

Option  3:  registration  in  the  Member  State  of  the  holder  of  the  vehicle  and 
simplified re-registration 

5.4.1.1.  Qualitative assessment 

This  option  is  as  a  consequence  of  the  public  consultation,  during  which  54.9 %  of 
businesses, 69.7 % of citizens and 41.7 % of public authorities replied that the current 
situation  could  be  improved  by  a  new  EU  system  that  recognises  vehicles  already 
registered  in  another  Member  State  (option  2).  However,  for  23.4%  of  businesses, 
15.4%  of  citizens  and  16.7%  of  public  authorities  this  measure  alone  would  not 
completely  solve  the  current  problems,  and  should  be  accompanied  by  additional 
measures. Therefore, option 3 was elaborated in order to organise mutual recognition 
in the context of the re-registration procedure. 

• 

– 

Positive impacts 

Citizens bringing their vehicle into the country of residence: Under this option 
citizens  would  still  have  to  re-register  their  motor  vehicles  when  transferring 

EN 

37 

   EN 

 
 
 
them  on  a  permanent  basis  to  another  Member  State.  However  the  re-
registration procedure would be significantly simplified at European level. This 
would  bring  about  an  important  reduction  of  time  wasting  for  citizens.  The 
legal uncertainty about where the motor vehicle has to be registered would also 
be eliminated. Furthermore clarification will be ensured of when it is required 
to register a vehicle in another Member State and of all the detailed documents 
that national registration authorities may request for that purpose. By setting up 
a  European  level  re-registration  procedure,  clarifying  the  role  of  each  actor, 
and  harmonising  the  documents  that  could  be  requested  during  such  a 
procedure,  most  of  the  problems  that  citizens  are  currently  facing  when  re-
registering their motor vehicles would be solved. Thus the burden of proof on 
the applicant would also be automatically removed. This option would have a 
positive impact on citizens as it would decrease the administrative burden. 

– 

Cross-border  workers:  This  option  would  solve  the  current  problem  of  cross-
border workers as it would entirely eliminate the uncertainty of which Member 
State the motor vehicle has to be registered in. 

–  Market of second-hand motor vehicles: this option would imply a reduction of 
time and costs for second-hand motor vehicle traders. The simplification of the 
registration  procedure  would  suppose  that  less  time  would  be  needed  to 
complete  it.  As  a  consequence  important  savings  as  regards  the  baseline 
scenario would be expected. 

– 

– 

– 

Leasing  companies  and  on  car-rental  companies:  this  option  would  imply  a 
reduction  of  time  and  costs  for  European  companies.  By  simplifying  the 
procedure we can assume that less time  would be needed to complete it. The 
time  that  the  fleet  would  be  non-operational  would  then  be  considerably 
reduced. Therefore important savings as regard the baseline scenario could be 
expected. If the re-registration procedure is considerably shortened that would 
solve  the  current  problem  of  car-rental.  Thus  car  rental  companies  would  be 
able  to  temporarily  move  their  fleet  across  Europe  to  reply  to  peak  seasonal 
demand.  

Registration  authorities:  This  option  would  have  a  positive  impact  on 
registration authorities. During the public consultation, registration authorities 
highlighted  the  problems  caused  by  the  many  differences  between  the 
registration  procedures  of  the  Member  States.  Under  this  option  these 
differences  and  discrepancies  would  be  automatically  removed.  The  detailed 
list  of  registration  documents  would  be  harmonised  at  European  level.  This 
would  automatically  imply  a  mutual  recognition  of  documents  and  an 
improvement  of  mutual  trust  among  registration  authorities.  In  administrative 
terms,  we  could  assume  that  there  would  be  an  increase  of  efficiency  and  an 
important simplification of the re-registration procedure. 

Vehicle crime: This option would have a very positive effect on the functioning 
of Council Decision 2004/919/EC on tackling vehicle crime with cross-border 
implications  since 
imply  direct  contact  between  registration 
authorities  so  that  it  would  become  extremely  difficult  to  register  a  motor 
vehicle that was stolen in another Member State. 

it  would 

EN 

38 

   EN 

 
• 

• 

– 

– 

– 

Negative impacts could not be identified. 

Neutral impacts: 

Taxation: this option does not seem to have an impact on tax revenue from the 
point  of  view  of  the  loss  of  tax  revenue  or  from  that  of  the  practical 
applications of tax rules of Member States. However, as de-registration would 
no  longer  be  required,  there  is  a  risk  that  the  application  of  the  refund 
mechanism for registration taxes would be rendered more difficult. 

Traffic  enforcement:  This  option  would  not  have  any  impacts  on  traffic 
enforcement. 

Road  safety  and  motor  vehicle  insurance:  This  option  would  not  have  an 
impact on road safety or on motor vehicle insurance. 

5.4.1.2.  Reduction of administrative costs 

The administrative costs would be reduced because this option would eliminate the 
need  for  de-registration  and  would  reduce  the  time  and  costs  needed  for  re-
registration.  In  the  short  term  public  authorities  would  still  have  to  do  the  de-
registration procedures38.  

The  cost  per  vehicle  would  be  €145  for  citizens  and  businesses  and  €13  for  public 
authorities.  The  administrative  costs  for  citizens  would  be  EUR  510  million  for 
citizens  and  businesses  and  EUR  47  million  for  public  authorities,  which  makes  a 
total of EUR 557 million annually. Therefore, this option would result in savings of 
EUR 943 million annually. One can assume that the whole duration of the procedure 
would be shorter (up to 2 weeks instead of 5 weeks). Therefore, the time the car is 
unused will also be shorter. Profit loss would be EUR 112 million. This would imply 
savings of EUR 224 million annually. If the procedure is simple enough it might help 
car rental companies to solve the problems they face with peak demands. This would 
imply  profits  of  EUR  4  million.  The  other  costs  from  the  baseline  scenario  would 
remain. 

OPTION 3: REGISTRATION IN THE MEMBER STATE OF THE HOLDER AND 
SIMPLIFIED RE-REGISTRATION 

Citizens and Businesses 
Public authorities 
Total administrative costs (A) 
Profit loss (B) 
Savings on one-way rentals costs 
Savings on loss of demand 
Peak seasonal demand  
Total additional savings car rental companies (C) 

Estimated annual savings 
compared to the baseline 
option (EUR million) 

890
53
943
224
0
0
4
4

38 

We  assume  that  the  effective  time  for  re  registration  would  be  reduced  by  50%  for  citizens  and 
companies. We assume that fees linked to de-registration would also disappear and those related to re-
registration would remain the same. Time for public authorities would also be reduced 60%. 

EN 

39 

   EN 

 
 
                                                 
TOTAL ( A+B+C) 

1,171

This option would allow savings estimated at EUR 1171 million annually. 

5.5. 

Option  4:  Registration  in  the  Member  State  where  the  motor  vehicle  is 
primarily used and simplified re-registration 

5.5.1.  Qualitative assessment 

The rationale behind this option is that the motor vehicle would be registered in the 
Member State where the vehicle primarily uses the road infrastructure. This option is 
a  variant  of  option  3  which  was  developed  as  a  consequence  of  the  public 
consultation  during  which  23.4%  of  businesses,  15.4%  of  citizens  and  16.7%  of 
public authorities  suggested  additional measures to organise  the mutual recognition 
of registration certificates. The difference between options 3 and 4 is that the former 
is inspired by the case-law of the Court of Justice on free movement of goods while 
the  latter  is  very  much  inspired  by  the  case-law  on  free  movement  of  persons  and 
services.  According  to  this  case-law,  a  Member  State  may  impose  an  obligation  to 
register  a  motor  vehicle  leased  by  a  worker  living  in  that  Member  State  from  a 
company  established  in  another  Member  State  where  that  vehicle  is  intended  to  be 
used essentially in the first Member State on a permanent basis or where it is, in fact, 
used in that manner. However, the concepts of ‘essential use on a permanent basis’ 
or  ‘actual  use  on  a  permanent  basis’  are  not  elaborated  in  the  jurisprudence  and 
depend mainly on a case-by-case assessment.  

• 

– 

– 

• 

– 

Positive impacts: 

Car-rental  companies:  The  impacts  of  this  option  would  be  positive  for  car-
rental  companies  which  operate  a  cross-border  fleet  management,  since  they 
could  move  a  part  of  their  fleet  to  another  Member  State  without  de-  and  re-
registration.  In  their  case,  the  notion  of  ‘essential  use  on  a  permanent  basis’ 
could be connected to the place from which the vehicles are rented. 

 Traffic  enforcement:  This  option  would  have  positive  impacts  on  traffic 
enforcement. The registration of the motor vehicle in the Member State where 
that  vehicle  is  intended  to  be  used  essentially  on  a  permanent  basis  would 
facilitate the recording and processing of traffic violations and make drivers or 
vehicle holders accountable for the violations. 

Negative impacts: The main difficulty of this option is its vagueness and the 
difficulties  that  it  may  cause  in  practice,  especially  for  persons  or  businesses 
that would use vehicles in different Member States. The concepts of ‘essential 
use  on  a  permanent  basis’  or  ‘actual  use  on  a  permanent  basis’  would  need 
further clarification and a very precise definition.  

 Citizens:  This  option  is  fairly  easy  to  apply  to  citizens  bringing  their  vehicle 
into  the  country  of  residence  which,  in  most  cases,  will  also  be  the  Member 
State where that vehicle is intended to be used essentially on a permanent basis. 
Yet,  this  option  has  no  positive  or  negative  impacts  on  them  since  it 
corresponds  to  the  current  situation.  However,  it  would  cause  severe 
difficulties for citizens who live a part of the year in one Member State and the 
other part in another Member State. Both Member States could then argue that 

EN 

40 

   EN 

 
– 

– 

– 

– 

• 

– 

the motor vehicle is essentially or actually used on a permanent basis on their 
territory and requires registration by them. 

 Cross-border  workers:  The  vagueness  and  the  practical  difficulties,  and  the 
corresponding administrative burden, would cause a negative impact on them. 
They could argue that the essential use is situated in the Member State where 
they work or in the Member State where they live, as they see fit. Obviously, 
both  Member  States  directly  concerned  could  argue  differently.  One  would 
have  to  assess,  in  each  individual  case,  if  a  car  is  mainly  used  for  private  or 
professional  purposes,  and  if  home-office  commutes  count  as  professional  or 
private use. This assessment would already be very challenging for people who 
work full-time in another Member State than the one where they live, but could 
become  extremely  complicated  in  other  cases,  in  particular  for  people 
employed  in  another  Member  State  in  work  which  is  not  their  principal 
employment and who use for business or private purposes a company vehicle 
registered  in  the  other  Member  State  where  their  employer’s  undertaking  is 
established.  

Employers:  This  option  would  have  a  similar  negative  impact  on  employers 
established  in  another  Member  State  than  their  employee  and  who  provided 
them with a company car registered in the country of the employer; the latter 
would face the same problems in their Member State. 

Leasing  companies:  Likewise,  this  option  would  have  a  negative  impact  on 
leasing  firms  which  would  be  obliged  to  register  the  motor  vehicle  in  the 
Member State of the client or, where the client is an employer providing a car 
to a cross-border worker, in one of both Member States. 

 Car  taxation:  The  number  of  de-  and  re-registrations  would  diminish  thus 
leading to a reduction of registration taxes. It is impossible to assess the impact 
on circulation taxes. 

Neutral impacts: 

Registration  authorities:  This  option  would  have  a  neutral  impact  on 
registration  authorities  who,  on  the  one  hand  would  see  a  decrease  of  their 
workload, and on the other hand, would be faced with an increasing number of 
information requests from cross-border workers, employers wishing to provide 
a company car to employees living in another Member State, and leasing firms. 

– 

 This option would have no impact on vehicle crime or motor vehicle insurance.  

EN 

41 

   EN 

 
5.5.2.  Reduction of administrative costs 

The quantitative impacts would be identical to those of option 3: 

OPTION 4: REGISTRATION IN THE MEMBER STATE WHERE THE VEHICLE 
IS PRIMARILY USED AND SIMPLIFIED RE-REGISTRATION PROCEDURE 

Citizens and Businesses 
Public authorities 
Total administrative costs (A) 
Profit loss (B) 
Savings on one-way rentals costs 
Savings on loss of demand 
Peak seasonal demand  
Total additional savings car rental companies (C) 
TOTAL ( A+B+C) 

Estimated annual savings 
compared to the baseline 
option (EUR million) 

890
53
943
224
0
0
4
4
1,171

This option would allow savings estimated at EUR 1,171 million annually. 

5.6. 

Option  5:  Optimising  the  electronic  exchange  of  information  among  national 
registration authorities 

This option does not envisage the establishment of a new electronic network but the 
use  of  an  updated  version  of  EUCARIS39  which  provides  a  direct  point-to-point 
architectural  model  to  exchange  information  on  license  plates  and  registered  cars. 
This  option  only  concerns  the  exchange  of  information  for  the  purpose  of  re-
registration in another Member State. 

During  the  public  consultation,  95.8%  of  public  authorities  supported  a  shared 
system,  linking  the  different  registration  authorities  in  every  Member  State,  which 
would  ensure  effective  exchange  of  vehicle  data  and  technical  registration 
information. However, some concerns were expressed as to the timing and costs of 
introducing  such  a  system.  For  80%  of  citizens  and  51%  of  businesses  improving 
communication  and  information  sharing  between  national  registration  authorities 
would properly address the current problems, though not all consider that this alone 
would solve the problems. It is worth noting that over 40% of the businesses did not 
answer the question. The Council invited the Member States already to accede to the 
EUCARIS  Treaty  ‘in  order  to  be  able  to  detect  stolen  vehicles  with  forged 
identification numbers by making use of non-existent vehicle identification numbers 
or the identification papers of seriously damaged vehicles.’40 

• 

– 

Positive impacts:  

Citizens bringing their vehicle into the country of residence: This option would 
have  a  positive  impact  on  this  group  since  it  would  certainly  decrease  the 

39 
40 

A detailed description of the electronic exchange of vehicle registration data is set out in Annex 5. 
Council  Conclusions  on  improving  the  detection  of  stolen  vehicles  in  the  Member  States  to  tackle 
illegal cross-border trafficking, 3051st Justice and Home Affairs Council Meeting of 2 and 3 December 
2010 

EN 

42 

   EN 

 
 
                                                 
– 

– 

administrative  burden  for  citizens,  since  the  registration  authorities  would  be 
able to find the missing vehicle data in the system. They would therefore not 
have to request this data from the person seeking the re-registration. 

Registration  authorities:  This  option  would  certainly  have  a  very  positive 
impact  on  registration  authorities  since  it  would  increase  the  efficiency  and 
effectiveness  of  their  operations  while  providing  them  with  sufficient 
guarantees  about  the  reliability  of  the  data.  During  the  public  consultation, 
95.8%  of  public  authorities  indicated  that  they  encountered  problems  when 
contacting their colleagues in other Member States. This option would have no 
additional budgetary impact as one of the existing systems would be used. 

Vehicle  crime:  This  option  would  have  a  very  positive  effect  on  tackling 
vehicle  crime  with  cross-border  implications  since  registration  authorities 
would be immediately informed about the theft, in another Member State, of a 
motor vehicle that is presented to them for registration. Consequently, it would 
become  extremely  difficult  to  register  a  motor  vehicle  that  was  stolen  in 
another Member State. 

–  Market of second-hand motor vehicles: this option would imply a reduction of 
time and costs for second-hand motor vehicle traders. The simplification of the 
registration  procedure  would  a  major  step  forward  since  many  controls  and 
inspections would be abolished. As a consequence important savings as regards 
the baseline scenario would be expected. 

• 

• 

Negative impacts could not be identified. 

Neutral  impacts  on  cross-border  workers,  leasing  companies  and  car-rental 
companies, car taxation, traffic enforcement and motor vehicle insurance. 

5.6.1.  Reduction of administrative costs 

The  administrative  costs  would  be  slightly  reduced  because  we  assume  that  there 
would  be  a  small  reduction  in  the  effective  time41  for  re-registration  for  citizens, 
businesses and authorities. The administrative costs would be of EUR 1,267 million 
for citizens and businesses and EUR 71 million for public authorities, which makes a 
total of EUR 1338 million annually. This would result in a reduction of around EUR 
162 million annually in administrative costs. The assumption is that the duration of 
the  re-registration  procedure  would  be  shorter  (up  3  weeks  instead  of  5  weeks). 
Therefore the time the car is unused will also be shorter. This would imply savings of 
EUR 112 million. The same costs currently incurred in the baseline scenario would 
remain. 

OPTION 5: IMPROVING THE EXCHANGE OF INFORMATION 

Citizens and Businesses 

Estimated annual savings 
compared to the baseline 
option (EUR million) 

133

41 

For our calculations we assume a reduction of 40% in the effective time for re-registration for citizens 
and companies and 55% for authorities. The time for de-registration would remain the same. 

EN 

43 

   EN 

 
 
                                                 
Public authorities 
Total administrative costs (A) 
Profit loss (B) 
Savings on one-way rentals costs 
Savings on loss of demand 
Peak seasonal demand savings 
Total additional savings car rental companies (C) 
TOTAL ( A+B+C) 

29
162
112
0
0
0
0
274

This option would allow savings estimated at EUR 274 million. 

Member  States  would  have  to  pay  a  financial  contribution  for  improving  the 
exchange  of  information  system.  As  a  reference  of  a  system  for  exchange  of 
information already functioning, the current annual budget of the EUCARIS financed 
by contributions from Member States amounts is slightly more than €600,000. This 
includes  all  costs,  operating  costs  and  software  development  costs42.  At  present 
different countries are using different modules of the system. Currently there are 30 
connections  to  EUCARIS:  14  countries  in  the  EUCARIS  Vehicle  and  Driving 
Licence information user group, 27 countries in the Prüm user group, 5 countries in 
the Vehicle Holder information user group and 2 countries in the Mileage user group. 
Therefore,  if  all  EU  Member  States  used  a  similar  system  to  exchange  information 
under option 5, the total necessary budget could be estimated at around €1,000.000 
per year for all Member States together. 

6. 

COMPARING THE OPTIONS  

6.1. 

Public consultation 

During  the  public  consultation,  stakeholders  were  invited  to  rank  the  proposals  in 
order  of  preference.  While  public  authorities  and  businesses  give  preference  to 
improving  communication  and  information  sharing  between  authorities  (option  5), 
the first choice for the majority of citizens is an EU system for mutual recognition of 
registration (option 2).  

Citizens 

Business 

Public 
authorities 

Option  1  (European  document  containing  all 
the necessary information) 

Option 2 (EU system for mutual recognition of 
registration 

Option  5  (Improving  communication  and 
information sharing between authorities) 

34.6 % 

25.6 % 

33.3 % 

54.7 % 

15.9 % 

29.2 % 

10.7 % 

58.5 % 

37.5 % 

6.2. 

Administrative burden 

The impacts of the various options on the reduction of the administrative burden can 
be summarised as follows: 

42 

For further details, see Annex 5. 

EN 

44 

   EN 

 
 
                                                 
Options 
Citizens and Businesses 
Public authorities 
Total administrative costs (A) 
Profit loss (B) 
Savings on one-way rentals costs 
Savings on loss of demand 
Peak seasonal demand savings 
Total  additional  savings  car  rental 
companies (C) 
TOTAL ( A+B+C) 

2a 
1400
100

1 
1400
100

2b 
1359
78

2c 
1360 
56 
1,500 1,500 1,437 1,416 
336 
407 
169 
15 
591 

336
418
202
16
636

336
418
202
16
636

336
409
188
15
612

3 
890 
776 
943 
224 
0 
0 
4 
4 

4 
5 
890 133
53
29
943 162
224 112
0
0
0
0

0
0
4
4

2,472 2,472 2,385 2,343  1,171  1,171 274

The  baseline  scenario  generates  significant  administrative  costs  and  other  costs  for 
citizens,  companies  and  public  authorities.  From  this  perspective  all  options  would 
lead to a significant improvement of the situation and a reduction of costs (especially 
administrative burden) for all involved actors in a different degree.  

6.3. 

Comparison of the qualitative impacts 

The  qualitative  impacts  of  the  options  can  be  summarised  as  follows  in  this 
qualitative comparison table43: 

Options 
Target groups 
Citizens transferring 
residence 
Second-hand market 
Cross-border workers 
Leasing firms 
Car-rental firms 
Registration authorities 
Other impacts 
Roadworthiness checks 
Traffic enforcement 
Motor insurance 
Taxation issues 
Vehicle crime 
+ = positive impact 
- = negative impact 
0 = neutral impact 

1 

+ 

+ 
+ 
+ 
+ 
+ 

- 
- 
- 
- 
- 

2a 

2b 

2c 

+ 

0 
+ 
+ 
+ 
+ 

- 
- 
- 
- 
0 

+ 

0 
+ 
+ 
+ 
+ 

0 
0 
- 
- 
0 

+ 

0 
+ 
+ 
+ 
+ 

0 
0 
- 
- 
0 

3 

+ 

+ 
+ 
+ 
+ 
+ 

0 
0 
0 
0 
+ 

4 

0 

0 
- 
- 
+ 
0 

0 
+ 
0 
0 
0 

5 

+ 

+ 
0 
0 
0 
+ 

0 
0 
0 
0 
+ 

The table shows that none of the options addresses all problems.  

6.4. 

Comparison of all impacts 

A  comparison  of  the  quantifiable  and  the  non-quantifiable  impacts  leads  to  the 
following results, compared to the baseline option: 

Comparison of all impacts 

43 

These various positive and negative impacts are of different nature and intensity. One positive impact 
does  not  necessarily  outweigh  one  negative  impact.  Adding  them  to  compare  the  total  number  of 
positive and negative impacts for each option would therefore be misleading.  

EN 

45 

   EN 

 
 
 
                                                 
Options 

1 

2a 

2b 

2c 

3 

4 

5 

Savings (millions €) 

2,472

2,472

2,385

2,343

1,171 

1,171 

274

This leads to the preliminary finding that all options lead to considerable savings but 
also that, notwithstanding those savings, options 1, 2a, 2b and 4 show very important 
negative impacts, especially as regards motor insurance and car taxation.  

Therefore,  it  is  recommended  to  select  only  the  policy  options  that  present  only 
positive and neutral impacts, namely: 

• 

• 

Option  3:  registration  in  the  Member  State  of  the  holder  of  the  vehicle  and 
simplified re-registration.  

Option  5:  Optimising  the  electronic  exchange  of  information  among  national 
registration authorities. 

The combination of options 3 and 5 would create relatively high savings of at least 
EUR 1.445 billion and would at the same time have a positive or neutral impact on 
all target groups. 

6.5. 

Sensitivity analysis 

This  impact  assessment  contains  several  assumptions.  In  some  cases,  assumptions 
and extrapolations were needed to complete data series with missing data points. In 
other  cases,  assumptions  were  needed  to  run  the  quantitative  analysis  of  policy 
options.  To  verify  whether  results  are  robust  to  changes  in  the  assumptions,  a 
sensitivity analysis has been carried out. For the most important assumed variables ( 
number  of  de-  and  re-registrations,  leasing  rate,  one-way  cross  border  transactions 
and elasticity of demand of cross-border rentals), calculation of total net savings has 
been re-run based on lower and higher values.  

The number of de- and re-registrations is considered as a very conservative estimate 
(3.5 million). This is due to reporting thresholds under which the economic operators 
do  not  have  to  report.  Additionally,  there  are  cars  that  cross  EU  borders  without 
complying  with  the  registration  formalities.  However,  it  is  a  fact  that  part  of  the 
vehicles  transferred  to  another  Member  State  would  be  sold  immediately  in  the 
country of destination (second hand car trade). These cars would not benefit from the 
savings  derived  from  option  2  because  they  would  need  to  be  re-registered  in  any 
case  due  to  the  fact  that  the  ownership  changes.  However,  there  are  no  available 
statistics  showing  the  percentage  that  these  vehicles  represent  in  the  total  picture. 
Therefore,  to  take  this  into  account  the  savings  values  have  been  recalculated  with 
lower  and  higher  figures  of  vehicles  re-registered  (see  detailed  figures  in  annex  4 
point  8.4.2.6).  Leasing  rate  is  used  as  a  proxy  for  the  opportunity  cost  of  capital. 
Savings  have  been  recalculated  assuming  lower  and  higher  values.  The  number  of 
one-way cross border transactions is estimated by the car sector in 837,000 per year. 
Saving  values  have  been  recalculated  assuming  lower  and  higher  values.  The 
demand for cross border rental is considered inelastic assuming an elasticity of 0.50. 
Savings have been recalculated assuming lower and higher values. 

EN 

46 

   EN 

 
In any case, the ranking of the combination of options remains the same under each 
variation, although absolute values of savings vary. 

6.6. 

Form of the legislative instrument 

A  regulation,  being  directly  applicable  upon  Member  States,  would  achieve  a  very 
high degree of harmonisation of the rules on the registration of motor vehicles that 
were already registered in another Member State, without the need for transposition 
into different national laws. It would also eliminate the need for defining criteria for 
the applicable law in cross-border situations in which the question arises where the 
motor  vehicle  should  be  registered,  as  the  regulation  would  be  the  applicable  law 
across  Member  States.  Since  the  legislative  instrument  would  only  apply  to  cross-
border  situations  within  the  EU,  a  regulation  would  ensure  legal  certainty  and 
simplification  within  the  internal  market.  Considering  that  the  current  cost  of  legal 
fragmentation,  only  in  terms  of  administrative  burden,  is  incurred  by  citizens  and 
economic  operators  operating  across  borders,  a  regulation  would  have  the  effect  of 
cutting  such  costs  and  drastically  simplifying 
the  regulatory  environment. 
Furthermore, a regulation is a more effective instrument for organising the electronic 
exchange of information among national registration authorities. 

A very detailed Directive, further harmonising the applicable rules and reducing the 
room  for  manoeuvre  left  to  Member  States, could  also  help  substantially  in  cutting 
the  costs  and  administrative  burden  in  the  baseline  scenario  due  to  fragmentation. 
However, this would not eliminate the need for transposition by Member States and 
the differences in national transposition laws that this might entail. Moreover, there 
would always be the risk for "gold-plating" from Member States. 

7. 

MONITORING AND EVALUATION  

The  different  problems  outlined  in  this  impact  assessment  are  not  yet  subject  to 
secondary EU law. Therefore, they are governed by the provisions of the TFEU. The 
different national systems and the problems encountered by citizens and businesses 
are very different, especially for vehicles that were previously registered in another 
Member State. Considering these wide differences and the abundant jurisprudence of 
the Court of Justice, a specific evaluation of all existing vehicle registration systems 
for motor vehicles previously registered in another Member State was not made.  

Therefore,  it  is  important  to  put  in  place  a  coherent  monitoring  and  evaluation 
scheme  without,  however, creating an additional administrative burden for citizens, 
businesses  and  national  registration  authorities.  In  addition,  there  are  hardly  any 
precise statistics about certain target groups directly affected by the current problems 
on motor vehicle registration, especially on citizens transferring their vehicles across 
borders  or  about  the  second-hand  market.  There  are  also  no  precise  statistics  about 
the  number  of  problems  encountered  by  people  who  encountered  problems  when 
they used a motor vehicle registered in another Member State, and about the amount 
of  difficulties  and  the  time  required  for  re-registration  in  another  Member  State. 
However, the ‘EUCARIS’ software application delivers statistics that could be used 
as indicators.  

EN 

47 

   EN 

 
It is suggested to use the following indicators and monitoring methods in view of an 
evaluation of the legislative instrument, within four years following the deadline for 
its implementation: 

Who was affected by the problems? 
Citizens purchasing a second-hand motor 
vehicle in another Member State  
Citizens moving to another Member State 
with their vehicle  
Citizens living part of the year in another 
Member State 
Citizens  working  across  borders  with  a 
company car 
Leasing and car-rental enterprises 

National registration authorities 

All target groups 

Indicators/ method for monitoring 

- Number of complaints; 
- Number of SOLVIT cases; 
- Number of court cases; 
- Number of requests to the European 
Consumers Centres; 
- Number of re- and de-registrations; 
-Public consultation in particular on 
administrative burdens 
Survey specifically addressed to this 
sector 
Survey specifically addressed to national 
registration authorities 
EUCARIS statistics. 

EN 

48 

   EN 

 
8. 

ANNEXES  

8.1. 

Annex 1: Public consultation and surveys 

8.1.1.  Results of the public consultation 

8.1.1.1.  General overview 

The  public  consultation  on  a  future  initiative  concerning  the  registration  of  motor 
vehicles  previously  registered  in  another  Member  State  was  held  between  3  March 
and  26  May  2011  by  DG  Enterprise  and  Industry  (DG  ENTR)44.  An  online 
questionnaire,  hosted  on  the  European  Union’s  website,  was  open  to  various 
categories  of  stakeholders.  Tailor-made  questionnaires  for  different  categories  of 
stakeholders — citizens, businesses and public authorities — were available in all 22 
EU  official  languages.  Information  on  the  public  consultation  was  published  on 
several  websites45  and  promoted  through  business  networks,  e.g.  Enterprise  Europe 
Network; E-Reg network, Industrie- und Handelskammer Frankfurt am Main (IHK), 
Leaseurope  network  and  G+europe,  with  a  view  to  reaching  as  many  interested 
parties as possible. 

There were 828 respondents to the public consultation. The vast majority of replies 
came  from  citizens  (78 %),  followed  by  business  organisations  (19 %)  and  public 
authorities (3 %) (see Figure 1). 

19,0%

3,0%

Citizens 78%

Business 19%

Public authorities 3%

78,0%

Figure 1: Contributions by category of stakeholders 

Of the 651 replies received from citizens, most were from Poland (16.4 %), Slovakia 
(15.9 %), France (11.4 %), Finland (9.6 %), Belgium (8.6 %) and Germany (5.9 %). 

Of the 151 replies received from businesses (143 replies via the public questionnaire 
and  8  submitted  as  separate  contributions),  the  majority  were  submitted  by 
businesses  selling  second-hand  vehicles  (49.0%),  followed  by  leasing  companies 
(2.1 %),  car  rental  companies  (0.7 %),  and  other  types  of  businesses  (35.0 %).  No 
contributions  were  received  from  businesses  in  9  Member  States.  As  regards 

44 
45 

http://ec.europa.eu/yourvoice/ipm/forms/dispatch?form=CARREGISTRATION. 
EUROPA website, E-Reg website, IHK website, Enterprise Europe Network bulletin. 

EN 

49 

   EN 

 
 
 
                                                 
geographical distribution, most replies were from Austria (61), France (15), Poland 
(16), Slovakia (14), Netherlands (10) and Germany (9). 

Only 26 replies (3 % of the total) were submitted by public authorities, namely 14 
central  public  authorities  and  12  local  or  regional  public  authorities  (23  replies  via 
the  public  questionnaire  and  3  replies  via  e-mail).  The  largest  proportion  of 
contributions was from regional public authorities in Germany (12). 

Citizens

Business

Public authority

UK

SE

ES

SL

SK

RO

PT

PL

NL

MT

LU

LT

LV

IT

IE

HU

EE

DE

FR

FI

ET

DK

CZ

CY

BG

BE

AT

0

20

40

60

80

100

120

Figure 2: Contributions by category of stakeholder and Member State of origin 

the  public 
in  all  stakeholder  categories  generally  welcomed 
Respondents 
consultation.  A  large  majority  supported  a  possible  future  initiative  by  the 

EN 

50 

   EN 

 
 
Commission to simplify and facilitate formalities and conditions for the registration 
of motor vehicles previously registered in another Member State. 

8.1.1.2.  Results 

30,0%

25,0%

20,0%

15,0%

10,0%

5,0%

0,0%

35,0%

30,0%

25,0%

20,0%

15,0%

10,0%

5,0%

0,0%

26,1%

17,4%

17,4%

8,7%

8,7%

8,70%8,70%

4,3%

Few e r than 5000 (8.7%)

5000-24000 (17.4%)

25000-49000 (4.3%)

50000-74000 (26.1%)

75000-124000 (8.7%)

125000-249000 (17.4%)

250000-499000 (8.7%)

500000-1 m illion (8.7%)

Figure 3: Number of applications to register new vehicles received in the past 12 months 

Public  authorities  were  invited  to  provide  both  the  number  of  applications  for  the 
registration  of  new  vehicles  and  the  number  of  applications  for  re-registering 
previously registered vehicles. 

Figures indicate that the public authorities in the Member States deal each year with 
a considerable number of applications for the registration of both new vehicles and 
vehicles previously registered in another Member State. 

30,4%

30,4%

8,7%8,7%

8,7%

8,7%

4,3%

Fewer than 80 (0.0%)

80-150 (0.0%)

150-500 (8.7%)

500-1000 (8.7%)

1000-5000 (30.4%)

5000-10000 (8.7%)

10000-20000 (0.0%)

20000-50000 (30.4%)

50000-100000 (8.7%)

100000-200000 (4.3%)

200000-450000 (0.0%)

450000-500000 (0.0%)

Over 500000 (0.0%)

Figure 4: Number of applications to register vehicles that were previously registered in another Member State 
received in the past 12 months 

EN 

51 

   EN 

 
 
 
 
 
Question  1:  Have  you  had  (procedural)  problems  when  registering  vehicles  that 
were previously registered in another Member State? 

Re-registration of a vehicle posed problems for a significant majority of citizens, but 
also for many businesses. The variation in the case of the latter is most probably due 
to a large number of identical answers from Austria. 

The  figure  for  public  authorities  (95.8 %)  indicates  that  almost  all  faced  several 
procedural  problems  when  requested  to  register  a  vehicle  previously  registered  in 
another Member State. 

100%

80%

60%

40%

20%

0%

72%

28%

59%

41%

95,80%

4,20%

Yes 

No 

Citize ns 

Business

Public authorities

Question 2: What problems did you have46? 

Citizens and businesses were requested to specify the types of problems encountered. 
The  figures  in  the  table  below  are  comparable  for  both  categories  of  stakeholders, 
thus indicating recurrent problems. 

Apart  from  the  listed  problems,  high  registration  taxes  (Denmark),  additional 
recycling fees (Poland), and problems with proving the identity of historic vehicles 
(Belgium, the Netherlands) were also mentioned. 

Problem 

Citizens 

Business 

The vehicle reg. authorities required 
additional technical checks or certificates 

The registering country required a new 
roadworthiness test, even though the 
vehicle had passed one in another EU 
country 

Long and complicated procedures 

Differences in registration requirements 
between countries 

A valid EU type-approval certificate was 
not recognised by reg. authorities in the 
receiving country 

1 

2 

3 

4 

5 

67.9 %

69.5 %

54.3 %

81.6 %

44.7 %

50.8 %

67.8 %

37.3 %

17.3 %

13.6 %

46 

Multiple choice reply. 

EN 

52 

   EN 

 
 
 
  
                                                 
The vehicle was not EU type-approved 
(new type approval requested) 

Required to submit an EU type-approval 
certificate 

Unable to temporarily transfer a vehicle 
from one EU country to another 

Required to supply technical information 
you did not have 

The authorities did not recognise some 
of the technical documentation submitted

The authorities refused requests to have 
the vehicle registered there 

Other 

6 

7 

8 

9 

10 

11 

12 

18.2 %

20.7 %

12.4 %

26.7 %

15.2 %

8.8 %

25.4 %

20.3 %

11.9 %

18.6 %

32.2 %

30.5 %

27.1 %

18.6 %

For  public  authorities,  the  main  problems  relate  to  differences  between  Member 
States in registration procedures and to the exchange of information required for re-
registering  motor  vehicles.  In  addition,  not  all  Member  States  de-register  motor 
vehicles automatically after receiving notification, and this leads to even longer and 
more  complicated 
for  all  concerned.  Therefore, 
standardisation of the information exchanged could constitute part of the solution.  

re-registration  procedures 

66,7%

75,0%

45,8%

37,5%

80,0%
70,0%
60,0%
50,0%
40,0%
30,0%
20,0%
10,0%
0,0%

Certificates subm itted w ith the application
do not contain inform ation needed to
determ ine w hether vehicle com plies w ith
technical rules (66.7%)
Difficulties in identifying the vehicle w ith
precision (37.5%)

Differences in registration requirem ents
betw een EU countries (75.0%)

Problem s by public authorities

Other (45.8%)

Question 3: What is the effect of these problems47? 

Registration  problems  have  a  negative  impact  on  citizens  and  businesses.  Long 
procedures  (for  77.8 %  of  citizens  and  83.1 %  of  businesses)  and  extra  costs  (for 
86.5 % of citizens and 81.4 % of businesses) are identified as the main effects, with 
50.8 %  of  businesses  being  discouraged  from  transferring  cars  from  one  Member 
State  to  another.  For  55.9 %  of  the  businesses  consulted,  the  problems  identified 
under  question  2  above  seriously  affect  productivity.  For  64.4 %,  they  also  affect 
growth. Finally, 23.7 % of citizens and 28.8 % of businesses stated that, in the end, 
they could not register a vehicle in the Member State concerned. 

Effects of the problems 

Citizens 

47 

Multiple choice reply. 

EN 

53 

   EN 

 
 
 
 
                                                 
It creates extra costs 

The procedure takes too long 

In the end, you can not register 
vehicle 

It discourages you from 
transferringyour car in the EU 

It affects the productivity of your 
business 

It affects the growth of your 
business 

Other 

As regards businesses: 

Effects of the problems 

The procedure takes too long 

It creates extra costs 

It affects the growth of your 
business 

It affects the productivity of your 
business 

It discourages you from 
transferringyour car in the EU 

In the end, you can not register 
vehicle 

Other 

86.5% 

77.8% 

 23.7% 

- 

- 

- 

- 

Business 

83.1% 

81.4 % 

64.4 % 

55.9 % 

50.8% 

28.8 % 

13.6 % 

Question 4: What causes these additional costs48? 

According  to  the  contributions  received,  most  additional  costs  are  generated  by 
requests  to  undergo  additional  checks  and  tests  (83.2 %  of  citizens,  81.2 %  of 
businesses), to translate documents (52.1 % of citizens, 50.0 % of businesses) and to 
contact  the  manufacturer  for  additional  technical  information  (41.5 %  of  citizens, 
41.7 % of businesses). 

Citizens  and  businesses  estimated  the  additional  costs  as  ranging  from  EUR 200  – 
400 in some Member States (France, Poland, Germany) to as much as EUR 10 000 in 
the Scandinavian countries. 

48 

Multiple choice reply. 

EN 

54 

   EN 

 
 
                                                 
100%

83%

81%

80%

60%

40%

20%

0%

52%

41%

50%

41%

Additional checks and tests

Contacts with manufacturer to
get more technical information

Getting documents translated

Citizens

Business

Question  5:  Are  problems  with  vehicle  registration  creating  obstacles  to  your 
commercial choices and /or everyday life? 

Two out of three citizens consider that problems encountered when transferring a car 
from one Member State to another result in obstacles to choice. 

67%

70%

60%

50%

40%

30%

20%

10%

0%

27,80%

14% 11%

9%

Obstacles for citizens

Yes (66.7%)

No (13.9%)

Do not know (10.9%)

Do not understand (8.5%)

N/A (27.8%)

Question 6: When one of the problems listed in the previous questions arises, do you 
contact  the  registration  authorities  in  the  EU  country  where  the  car  was  previously 
registered to get more information? 

Three quarters of the public authorities say they contact the registration authorities in 
the Member State where the motor vehicle was previously registered in order to get 
information needed for re-registration. 

However, only one quarter of the public authorities always contact their counterparts 
in another Member State in such cases. 

EN 

55 

   EN 

 
 
 
 
 
29,2

25

25

20,8

30

25

20

15

10

5

0

Do you contact the registration authorities in
another Member State?

Yes, always (25.0%)

Yes, sometimes (29.2%)

Yes, but rarely (20.8%)

No, newer (25.0%)

Question 7: Do you have problems when contacting registration authorities in other 
EU countries? 

Most  public  authorities  frequently  face  problems  when  contacting  registration 
authorities  in  other  Member  State.  95.8 %  of  public  authorities  state  they  have 
encountered problems. 

60%

50%

40%

30%

20%

10%

0%

53%

42%

Yes, always (42.1%)

Yes, sometimes (52.6%)

Yes, occasionally (5.3%)

No, never 0%

5%

0%

Problems when contacting registration authorities

Question 8: What are these problems49? 

The  main  problems  mentioned  by  public  authorities  are  identification  of  the 
competent public authority in the other Member State (27.1 %), not being given the 
required  information  (25.0 %),  late  reply  from  the  counterpart  (25.0 %),  their 
counterparts did not have the information requested (12.5 %) .  

10% of the public authorities pointed at other problems.  

Types of problems 

49 

Multiple choice reply. 

EN 

56 

   EN 

 
 
 
 
 
                                                 
30,0%

25,0%

20,0%

15,0%

10,0%

5,0%

0,0%

27,1%

25,0%

25,0%

12,5%

10,0%

It is not easy to find out w ho is responsible
in other EU countries (27.1%)

The inform ation requested w as not
provided (25.0%)

The authority in the other country did not
have the inform ation requested (12.5%)

The authority in the other country did not
reply in tim e (25.0%)

Other (10.4%)

Question  9:  In  your  view,  is  the  current  system  for  sharing  information  between 
registration 
very 
good/good/average/unsatisfactory/very unsatisfactory? 

authorities 

countries 

different 

in 

Almost  60 %  of  the  public  authorities  consider  the  current  system  for  exchanging 
information to be unsatisfactory. This figure indicates the importance of tackling the 
issue  of  exchanging  and  sharing  information  between  registration  authorities  in  the 
EU,  in  order  to  facilitate  the  overall  re-registration  procedure  by  decreasing  its 
duration and cost. 

In separate written contributions, public authorities from the Netherlands, Ireland and 
Germany  specifically  identified  EUCARIS  (the  European  Car  and  Driving  Licence 
Information  System)  as  a  useful  and  practical  tool  to  improve  communication  and 
information exchange between registration authorities. 

4,2%

4,2%

4,2%

29,2%

29,2%

29,2%

Very good (4.2%)

Good (4.2%)

Average (29.2%)

Unsatisfactory (29.2%)

Very unsatisfactory (29.2%)

Don't know  (4.2%)

Question 10: Are you aware of the existence of any centralised or local databases? 

In general, most public authorities (70.8 %) are aware of the existence of centralised 
or local databases. However, it should be noted that almost one third do not know of 
such  databases,  which  is  bound  to  affect  the  duration  of  the  overall  re-registration 
procedure and its effectiveness. 

Question  11:  If  so,  have  you  ever  used  the  database(s)  when  dealing  with  an 
application to register a vehicle previously registered in another EU country? 

EN 

57 

   EN 

 
 
 
 
 
58.3 % of the public authorities aware of the existence of databases stated that they 
make  use  of  them,  but  the  overall  figure  is  not  encouraging  and  reflects  a  need  to 
improve communication and information exchange. Moreover, the respondents also 
admit there is still room for improving their effective use (see also question 12). 

29,20%

12,5%

Yes (58.3%)

No (12.5%)

N/A (29.2%)

58,3%

Question 12: Do you think this method is effective? 

The majority of public authorities that use the databases available consider them to 
be  a  very  effective  tool,  significantly  facilitating  their  work.  It  is  worth  noting, 
however, that 41.7 % of public authorities did not reply to this question. 

41,7%

8,3%

8,3%

8,3%

Alw ays effective (8.3%)

Usually effective - in around
75% cases (33.3%)
Effective - in around 50% of
cases (8.3%)

Occasionally effective in
around 25% of cases (8.3%)
N/A (41.7%)

33,3%

Question 13: How long did the registration procedure take in the receiving country? 

Replies  from  citizens  and  businesses  illustrate  a  large  variation  in  the  duration  of 
registration procedures. Thus, almost half of the consulted citizens said registration 
took more than 1 month. The figure for businesses is similar (for 27.1 %, registration 
took over 1 month and for 13.6 % more than 2 months). It is worth noting that almost 
60% of businesses and 30% of citizens did not reply to this question. 

EN 

58 

   EN 

 
 
 
 
 
60

50

40

30

20

10

0

58,7

37

31,4

27,8

18,4

9,8

3,4

25,427,127,1

13,6

6,8

Citizens 

Business

several hours

less than 1 w eek

1 w eek- 3 w eeks

1 m onth- 2 m onths

over 2 m onths

N/A

The respondents were given the opportunity to express their view on a possible EU 
action  to  improve  the  current  situation,  as  well  as  their  preference  on  different 
proposals. 

Question 14: Should action be taken at EU level to improve the situation? 

As shown in the table below, for all categories of stakeholders, a significant majority 
believe that action should be taken at EU level to improve the current situation. Most 
importantly, all public authorities that contributed to the consultation are in favour of 
action been taken at EU level. 

100,00%

80,00%

60,00%

40,00%

20,00%

0,00%

92,30%

7,70%

57,30%

42,70%

100%

0%

Yes

No

Citizens

Business

Public authority

Question 15: Could the situation be improved by a new EU system that recognises 
vehicles already registered in another EU country?  

54.9 % of businesses, 69.7 % of citizens and 41.7 % of public authorities replied that 
the current situation could be improved by a new EU system that recognises vehicles 
already registered in another Member State. 

For  23.4%  of  businesses,  15.4%  of  citizens  and  16.7%  of  public  authorities  this 
measure  alone  would  not  completely  solve  the  current  problems,  and  should  be 
accompanied  by  additional  measures.  In  the  case  of  Austria,  the  majority  of 
stakeholders (70 %) considered that this issue should preferably be addressed through 
national legislation. 

Yes, definitely 

Citizens 

69.7 % 

Business 

54.9 % 

Public 
authorities 

41.7 % 

EN 

59 

   EN 

 
 
 
 
 
 
Yes, it could help 
although the problem 
would not be totally 
solved 

Yes, but only if combined 
with other measures 
No, it would not improve 
things 

No, it could create 
administrative problems 
between different 
countries 

No, it could create 
conflicts with national 
registration requirements 

Do not know 

N/A 

12.0 % 

13.4 % 

16.7 % 

15.4 % 

0.4 % 

23.2 % 

2.4 % 

16.7 % 

8.3 % 

0.2 % 

1.2 % 

0.0 % 

0.3 % 

1.8 % 

7.7 % 

1.2 % 

3.7 % 

42.7 % 

4.2 % 

12.5 % 

0.0 % 

Question  16:  Would  it  be  useful  to  introduce  an  EU  registration  certificate,  which 
would not need to be replaced when a vehicle is transferred from one Member State 
to another? 

A  significant  majority  of  stakeholders  would  like  to  see  an  EU  registration 
certificate: 87.7 % of citizens, 52.4 % of businesses and 79.2 % of public authorities.  

Moreover, they welcome the idea that this new certificate would not need replacing 
when  a  vehicle  is  transferred  between  Member  States  and  would  contain  all  the 
necessary  technical  and  personal  information  in  a  unique  format,  recognised  in  all 
Member States. 

100%

87%

79%

80%

60%

40%

20%

0%

52%

43%

5%

8%

5%

21%

0%

Citizens

Business

Public authority

Yes

No/Do not know

No answ er

Question  17:  Would  the  situation  be  improved  by  a  shared  system  linking  the 
different registration authorities in every EU country and enabling them to exchange 
vehicle data and technical registration information? 

EN 

60 

   EN 

 
 
 
 
A vast majority of public authorities supported a shared system, linking the different 
registration  authorities  in  every  Member  State,  which  would  ensure  effective 
exchange  of  vehicle  data  and  technical  registration  information.  However,  some 
concerns were expressed as to the timing and costs of introducing such a system. 

4,2%

95,8%

Yes 95.8%

No 4.2%

Question  18:  Could  problems  be  solved  by  improving  communication  and 
information sharing between national registration authorities? 

For  80%  of  citizens  and  51%  of  businesses  improving  communication  and 
information sharing between national registration authorities would properly address 
the  current  problems,  though  not  all  consider  that  this  alone  would  solve  the 
problems.  It  is  worth  noting  that  over  40%  of  the  businesses  did  not  answer  the 
question. 

50%

40%

30%

20%

10%

0%

45%

35%

42,70%

Yes

29%

22%

9%

7,70%

3,10%

4%

2,10%

Citizens

Business

Could improve the situation,
but not solve the problem

No

Don't know/don't understand

N/A

Question 19: Would it help your business if we introduced a temporary authorisation 
for transferring vehicles already registered in one EU country, provided they are used 
for commercial purposes (e.g. car rental, leasing)? 

40.2 %  of  businesses  would  welcome  the  introduction  of  temporary  registration  for 
businesses  at  EU  level,  given  that  registration  procedures  vary  from  one  Member 
State to another, resulting in legal uncertainty. However, for a significant number of 
businesses  (30.5%)  a  temporary  authorisation  for  transferring  vehicles  would  be  of 
no help. 

EN 

61 

   EN 

 
 
 
 
 
29,30%

30,5%

40,2%

Yes 40.2%
No 30.5%
Do not know 29.3%

Please estimate by how much: 

36.4 % of businesses in favour of temporary registration for businesses at EU level50 
expect this to help their business in 50 % or more of cases and for 6.1% of them only 
in up to 45% of cases. 

40,0%
35,0%
30,0%

25,0%
20,0%
15,0%
10,0%
5,0%
0,0%

33,3%

24,2% 

36,40%

0-15% cases 

15-30% cases

30-45% cases

50% or above
cases

6,10%

Question 20: Please rank the following proposals in order of preference  

Following on from questions 14-16, stakeholders were invited to rank the proposals 
in  order  of  preference.  While  public  authorities  and  businesses  give  preference  to 
improving  communication  and  information  sharing  between  authorities,  for  the 
majority  of  citizens  the  first  choice  is  an  EU  system  for  mutual  recognition  of 
registration.  

Worth  observing  is  that,  while  the  preferences  of  public  authorities  are  evenly 
balanced  between  the  three  proposals,  for  citizens  and  businesses  the  preference  is 
strong for their respective first options. 

Citizens 

Business 

Public 
authorities 

50 

See above, Question 19.  

EN 

62 

   EN 

 
 
 
 
 
 
                                                 
Improving communication and 
information sharing between authorities 

10.7 % 

58.5 % 

37.5 % 

European document containing all the 
necessary information 

34.6 % 

25.6 % 

33.3 % 

EU system for mutual recognition of 
registration 

54.7 % 

15.9 % 

29.2 % 

Some  public  authorities  included  additional  comments  when  answering  the 
questionnaire. An important point relates to the need to improve the system for the 
detection  of  stolen  vehicles  in  the  EU  to  tackle  illegal  cross-border  vehicle 
trafficking, considering the magnitude of the phenomenon (approx. 800 000 vehicles 
a  year  are  stolen  in  the  EU).  Furthermore,  problems  could  arise  with  registering 
motor  vehicles  built  and  designed  in  series  for  third  country  markets  where 
requirements  are  less  strict  than  in  the  EU  (e.g.  lower  safety  and  environment 
performance). 

8.1.1.3.  Conclusion and subsequent steps 

A  conference  on  the  re-registration  of  vehicles  previously  registered  in  another 
Member  State  was  held  on  21  June  2011  in  Brussels.  The  conference  was  well 
attended  by  stakeholders  (including  businesses  and  the  European  association  of 
national registration authorities) from 22 Member States. One of the objectives of the 
conference  was  to  present  the  preliminary  results  of  the  public  consultation  on  car 
registration.  It  also  provided  a  forum  for  debate  and  exchange  of  information 
between  the  different  stakeholders.  The  Commission  presented  the  preliminary 
results  of  the  public  consultation  and  the  conclusions  of  the  impact  assessment 
preceding adoption of a future instrument by the European Commission. 

The  main  issues  raised  by  participants  from  Member  States  concerned:  the  need  to 
improve  and  standardise  the  exchange  of  information  between  national  authorities; 
the  importance  of  a  traceable  legal  status  for  vehicles  (including  for  stolen  and 
scrapped vehicles); the proper use of existing databases (e.g. EUCARIS); the need to 
improve Commission supervision and enforcement of existing EU legal instruments; 
the importance of harmonised certificates for vehicles, from placing on the market to 
end of life; the need to harmonise the registration procedure at EU level in order to 
resolve certain problems that create obstacles. 

Businesses mainly called for facilitating the temporary transfer of vehicles in order to 
meet  seasonal  demands  and  to  ensure  the  genuine  free  movement  of  goods  and 
services. 

According  to  the  contributions  received  during  the  public  consultation  and  the 
conference,  consideration  should  be  given  to  simplification  of  the  formalities  and 
facilitation of the requirements for the registration of motor vehicles in the EU and 
action should be taken at EU level. 

EN 

63 

   EN 

 
8.1.2. 

Survey of national registration authorities 

During the first semester of 2011, national registration authorities were consulted by 
an external contractor on the following policy options to simplify the formalities and 
conditions for the registration of motor vehicles previously registered in another EU 
Member State: 

– 

– 

– 

– 

– 

Option 1: no policy change; 

Option  2:  an  improvement  of  the  implementation  of  the  existing  EU  law 
through  additional  guidance  and  enhanced  administrative  cooperation  (for 
example through increased efforts to establish common IT solutions); 

Option  3:  self  and  co-regulation  by  the  registration  authorities  in  view  of  an 
agreement  on  common registration principles facilitating the permanent intra-
EU transfers of motor vehicles; 

Option 4: an amendment of Council Directive 1999/37/EC on the registration 
documents  for  vehicles  and/or  Council  Regulation  (EC)  No  2411/98  on  the 
recognition in intra-EU traffic of the distinguishing sign of the Member State in 
which motor vehicles and their trailers are registered, in view of an automatic 
recognition,  throughout  the  EU,  of  the  registration  issued  in  another  Member 
State; 

Option 5: a new legislative instrument on motor vehicle registration in the EU, 
setting  out  the  conditions  for  the  national  registrations  of  motor  vehicles  and 
the  subsequent  rights  and  obligations  of  drivers  and  national  authorities, 
including  the  establishment  of  a  European  registration  certificate,  issued  by 
national licensing authorities. 

The national authorities were asked which of the abovementioned policy options they 
preferred. The results were the following: 

Member 
State 

Austria 
Belgium 
Bulgaria 

Czech 
Republic 
Germany 
Denmark 

Estonia 

Finland 

Hungary 

Reason why 

Expected benefits 

Preferred 
policy 
option(s) 
1 

2, 4 and 5  Harmonisation of European rules 

5 

2 

Reduction of disparities in 
registration of motor vehicles in the 
EU and creation of facilities re-
registrations 
Harmonise the process to EU 
standards 

Time and cost savings 
Ease of activities national authority 
and time reductions for citizens and 
businesses 

Reduce the administrative burdens 
for "both sides of the counter". 

5 
political 
issue 
2 

2 

1 

Security and speed 

Client services take less time and 
improve their convenience 
Requires more thorough analysis and 
more information 

Existing solutions can be used 
(EUCARIS), which is the quickest 
and safest solution 
Cannot support options 4 and 5 because of the importance of registration 
tax. 

EN 

64 

   EN 

 
New initiatives distract national 
authorities and expose them to 
unnecessary expenses and may not 
address the issues they have. 

Reduction of the number of re-
registrations, time saving for national 
authorities and also for citizens and 
businesses 
Reduce administrative work for the 
national authority. 

Simplifications and costs savings 

Ireland 

every policy 
option has 
its pro's and 
cons. 

Italy 

5 

It is important to note that much 
work is done by EReg, for example 
the development of EUCARIS. This 
work has to be supported. As for the 
other options they require extensive 
consultation and close cooperation 
and unanimous agreement. 
Reduction of the number of re-
registrations, time saving for national 
authorities and also for citizens and 
businesses 

Lithuania 

2 and 3  Would simplify motor vehicle re-

registration procedures in other 
Member States. 

Luxembourg  2, 3, 4 and 5  Could be used with pragmatism, 
progressively and with common 
sense to keep control of the 
responsibilities involved in car 
registrations 
Current administrative system is 
sufficient enough. Plus involvement 
of all EU Member States in the 
EUCARIS system 
Agrees with this policy option 

Latvia 

2 

Malta 
Netherlands 

5 

2 

Changes improve the combat of all 
kinds of fraud including stolen 
vehicle registered in other Member 
States. 
- 
When the decision is taken to use 
EUCARIS, the use of this system has 
to become an obligation. Such a 
system only has advantages/benefits 
for all stakeholders. 
Depends on final solutions taken in 
European and national laws, at this 
moment in time difficult to evaluate 
the costs. 

2 and 3  To reduce the administrative burdens 
of citizens and businesses. 
Connection to the existing system 
(EUCARIS) is quick and would be 
relatively cheap.  
To improve the current situation, 
simplification. Consequences: 
change to EU and national laws, 
leads to burdens for administrations, 
but can give benefits for citizens and 
businesses. 
To make the registration certificates 
and procedures in the EU Member 
States uniform. 
The current system in Sweden is a 
good one, but it is good to do more at 
EU level to harmonise the rules and 
administrative cooperation. It is also 
necessary to remember that it is 
important to fight fraud and 
criminality. 
Harmonise the procedures in the EU  Less burdens for citizens when 

Benefits: better public services and 
time saving. Disadvantages: 
probably some IT investments. 
- 

5 

5 and until 
adoption 
option 2 
1 

Poland 

Romania 

Sweden 

Slovenia 

Slovakia 

2 

United 
Kingdom 

1 

Want to stress the existing relatively 
high requirement referring to re-
registration as we want to avoid 
becoming a target country for old 
technically underperforming vehicles 
that can cause problems. 
Current procedures are satisfactory 
and changes could mean unwanted 
costs for the taxpayer and for vehicle 
manufacturers. 

selling vehicles to other Member 
States 
- 

Implementation of any policy 
changes would result in increased 
administrative and expensive IT 
systems development costs as well as 
potentially placing a greater burden 

EN 

65 

   EN 

 
on customers and business. 

Two national authorities did not know exactly which policy option they preferred at 
that  moment.  According  to  the  Danish  authority,  it  is  a  political  issue  to  make  this 
kind of decisions. The Irish authority mentioned different pros and cons of all policy 
options.  Furthermore,  four  authorities  preferred  no  further  action,  because  they 
thought that  their current procedures  were sufficiently addressing  the  problem.  The 
implementation  of  the  other  options  could  mean  unwanted  costs  and  more 
administrative burdens on citizens and businesses.  

Eleven out the twenty National Registration Authorities mentioned policy option 2 as 
the  preferred  one.  Some  of  them  would  like  to  implement  it  in  combination  with 
other options. The reason why these national authorities preferred option 2 was the 
possibility  to  use  existing  solutions,  such  as  EUCARIS.  Mandating  the  use  of 
EUCARIS  is  deemed  the  cheapest,  safest  and  quickest  way  to  reduce  the 
administrative burden on citizens and businesses. 

Policy  options  3  and  4  were  mentioned  by  respectively  three  and  two  National 
Registration Authorities and always in combination with other options.  

Seven  National  Registration  Authorities  mentioned  policy  option  5.  The  most 
important  reason  for  that  was  to  achieve  harmonisation  of  European  rules,  i.e.  a 
reduction  of  existing  disparities  in  the  registration  procedures.  National  authorities 
that were in favour of this option expected benefits to their citizens and businesses as 
result  of  better  public  services  and  time  savings.  They  argued  that  the  initial  phase 
could bring some costs for National Registration Authorities, because norms had to 
be amended and IT systems set up. 

EN 

66 

   EN 

 
8.1.3.  Understanding Citizens’ and Businesses’ Concerns with the Single Market: A View 

from the Assistance Services 

The Commission requested Ramboll Management Consulting to conduct an analysis 
of questions and problems handled by five EU information and assistance services: 
Europe Direct Contact Centres (EDCC), Your Europe Advice (YEA, former Citizens 
Signpost  Service),  European  Consumer  Centres  (ECC),  Enterprise  Europe  Network 
and SOLVIT in 2009. The objectives of this study51 were to give feedback to policy 
officials on the practical functioning of the single market, as seen by information and 
assistance  services,  and  to  act  as  a  feasibility  study  for  further  in-depth  analysis  of 
the Internal Market policies based on the queries and complaints (also referred to as 
“cases”) received by such services.  

The following section is an extract from chapter 12 of this study, about vehicles (p. 
188-193): 

‘Summary of findings 

The main findings from this section on issues that potentially hamper the functioning 
of the Internal Market are as follows: 

• 

• 

Procedures for registering a vehicle or seeking recognition of driving licences 
in  another  Member  State  involve  different  administrative  procedures  with 
different  authorities.  The  large  majority  of  enquiries  relevant  to  the  vehicle 
section  are  comprised  of  information  and  clarification  requests,  reflecting 
difficulties  in  understanding  the  legislation  and  in  accessing  appropriate 
information,  rather  than  misapplication  of  EU  law  and/or  structural  legal 
problems.  As  a  result,  a  number  of  citizens  still  avoid  buying  a  vehicle  in 
another  Member  State  as  they  fear  facing  unreasonable  paper  work  and  extra 
costs in their home country. Moreover, the transfer of motor vehicles to another 
Member State is also a source of complaint in some cases, in particular due to 
burdensome  type-approval  and  registration  procedures.  This  issue  presents  a 
significant obstacle to the free movement of goods and to the functioning of the 
Internal Market.  

The  complexity  of  the  coordination  system  combined  with  the  low  level  of 
harmonisation,  especially  in  the  areas  of  vehicle  registration  and  vehicle 
taxation,  often  results  in  administrative  difficulties  caused  by  competent 
authorities.  This  can  lead  to  administrative  mistakes  or  impose  unnecessary 
administrative  burdens  on  citizens.  Further  difficulties  encountered  by  the 
citizens  are  in  many  cases  due  to  a  lack  of  cooperation  from  and  among 
competent authorities of the Member States. This in turn leads to unnecessary 
delays  and  financial  losses.  Reviewed  cases  also  revealed  that  police  and 
customs  officers  are  often  not  aware  of  the  EU  legislation  and  hence  might 
infringe  the  law  by  requiring  fines  and  unnecessary  documents  from  the 
citizens. 

51 

EN 

report 

The 
be 
http://ec.europa.eu/internal_market/strategy/docs/20concerns/feedback_report_en.pdf 

in  May 

delivered 

2011 

was 

and 

can 

67 

found 

on 

   EN 

 
                                                 
• 

• 

The  low  level  of  harmonisation  often  comes  as  a  surprise  to  many  citizens. 
This  transpires  from  the  enquiries  of  the  citizens,  but  also  from  the  large 
number  of  unjustified  complaints  about  violations  of  EU  law  which  are 
seemingly  rooted  in  a  misunderstanding  of  the  rules.  The  reviewed  cases 
detected many unjustified complaints where citizens are surprised that there is 
no  EU  legislation  regulating  their  matter  or  that  their  issue  is  subject  to  the 
legislation  of  the  particular  Member  State.  Consequently,  citizens  fail  to 
comply with national laws of the individual Member States. Thus, they have to 
pay  vehicle  taxes  twice  or  have  their  vehicles  confiscated  by  police  officers 
because they fail to register it within the required deadline. This complexity is 
also  reflected  in  cases  submitted  to  the  support  services,  where  citizens  often 
fail to provide the necessary information to determine whether the law has been 
breached. All this suggests a serious burden on the free movement of goods as 
well as on the functioning of the Internal Market. 

The  issue  of  discrimination  on  the  basis  of  nationality  also  constitutes  an 
obstacle  to  the  functioning  of  the  Internal  Market.  The  discrimination  is 
primarily  due  to  private  parties’  illegal  practices.  Such  cases  include  driving 
schools  refusing  access  to  driving  education  to  non-nationals  by  posing 
unreasonable  requirements,  or  insurance  companies  suddenly  terminating 
insurance of vehicles that had been previously imported from another Member 
State. […] 

• 

Sources 

Table 13 Overview of sources 

Database 

Category level 1 

Category level 2 

ECC 
SOLVIT 
SOLVIT 
YEA 
YEA 

Transport services 
Driving licence 
Motor vehicle registration 
Motor-vehicles 
Motor-vehicles 

YEA 
YEA 

Motor-vehicles 
Motor-vehicles 

12.1  Registration of vehicles 

Car-rental 

Driving licences 
Import type-approval 
and registration 
Insurance 
Taxes 

Nbr of cases 
in database 
376
41
128
324
714

95
220

Most relevant cases under this section usually refer to the following legislation: 

• 

• 

Council Directive 1999/37/EC on the registration documents for vehicles52. 

Council Directive 96/96/EC on the approximation of the laws of the Member 
States relating to roadworthiness tests for motor vehicles and their trailers53. 

52 

53 

Council Directive 1999/37/EC of 29 April 1999 on the registration documents for vehicles (OJ L 138, 
1.6.1999, p. 57); 
Council  Directive  96/96/EC  of  20  December  1996  on  the  approximation  of  the  laws  of  the  Member 
States relating to roadworthiness tests for motor vehicles and their trailers (OJ L 46, 17.2.1997, p. 1); 

EN 

68 

   EN 

 
 
 
                                                 
• 

• 

Directive  2007/46/EC  of  the  European  Parliament  and  of  the  Council 
establishing a framework for the approval of motor vehicles and their trailers, 
and  of  systems,  components  and  separate  technical  units  intended  for  such 
vehicles54.  

Articles  34  and  36  TFEU,  which  ensure  operational  cooperation  between  the 
competent authorities, including the police, customs and other specialised law 
enforcement services of the Member States. 

12.1.1 

Most common problems encountered 

It should also be mentioned that a large number of requests are simple information 
requests about the relevant authorities for car registration and the correct formalities 
and  procedure  for  registering  or  moving  a  vehicle  to  another  Member  State.  More 
specific information requests also concern the technical inspection of vehicles in the 
host Member State and the formalities and procedures for selling or buying a vehicle 
abroad. 

Apart  from  information  requests,  the  most  common  problems  encountered  in  this 
section concern: 

• 

• 

Lack of awareness  and misunderstanding of the rules on the registration 
of vehicles due to the predominant role of the national level: Beyond simple 
information requests, cases reveal a lack of awareness and misunderstanding of 
the  predominant  role  of  the  national  level  in  regulating  vehicles  registration. 
Citizens  would  expect  more  harmonisation  or  coordination  between  the 
national administrations, and the procedures they have to comply with come as 
a  surprise.  Also,  the  procedures  citizens  have  to  comply  with  appear  to  be 
complex.  A  consequence  of  this  is  the  frequent  unjustified  complaints  about 
violation of the law which are seemingly rooted in a misunderstanding of the 
rules.  Also,  complaints  usually  lack  important  information  which  prevent  the 
EU information and support services from providing a clear answer. 

Flawed  administrative  practices  and  unreasonable  requirements: 
Recurring  YEA  and  SOLVIT  cases  reveal  that  the  competent  authorities 
violate the EU law by refusing registration or provision of certain documents. 
On  several  occasions,  authorities  impose  unreasonable  administrative  or 
technical  burdens  on  citizens  without  any  specific  reason.  It  is  however 
difficult  to  say  whether  these  are  systematic  practices  or  administrative 
mistakes due to a lack of awareness in the national administrations.  

12.1.2 

Application of EU law on the ground 

Member States applying the law incorrectly 

As the registration of motor vehicles is not entirely harmonised on the EU level, the 
registration  to  a  great  extent  remains  subject  to  relevant  national  legislation  and 

54 

Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007 establishing 
a  framework  for  the  approval  of  motor  vehicles  and  their  trailers,  and  of  systems,  components  and 
separate technical units intended for such vehicles (OJ L 263, 09.10.2007, p. 1); 

EN 

69 

   EN 

 
                                                 
formalities. So most complaints from citizens against misapplication of the EU law 
fall under one of the following situations: 

– 

– 

– 

In  many  situations,  it  is  not  possible  to  identify  any  EU  law  that  applies  to 
cases, and thus they fall under national law. 

In  other  cases,  EU  law  applies  but  citizens  often  do  not  provide  sufficient 
information in order to determine whether the law has been infringed or not55. 

Finally,  there  are  cases  that  reveal  a  possible  breach  of  EU  law.  These  cases 
include: 

• 

Unreasonable  administrative  requirements  for  the  registration  of 
vehicles  already  registered  in  another  Member  State:  Alleged 
misapplication of Directive 1999/37/EC occurs when the Member States 
require  unreasonable  documents  for  registering  vehicles  or  refuse 
registration  of  a  vehicle  that  was  already  approved  and  registered  in 
another  Member  State  for  invalid  reasons.  Citizens  also  complain  that 
technical  controls  made  in  one  Member  State  are  not  recognized  in 
another.  The  issue  of  resistant  vehicle  approval  and  registration  is  most 
recurring in France and Italy where a large number of citizens complain 
about unreasonable administrative burdens when registering their cars. In 
particular, citizens importing motor vehicles from non-EU countries and 
from  the  United  Kingdom  to  France  face  difficulties  from  the 
administration. The issue is demonstrated by a SOLVIT case: 

A Danish citizen attempted to register his car, manufactured in the UK, 
in  France.  The  vehicle  was  previously  registered  and  approved  in 
Denmark.  The  citizen  was  requested  to  provide  several  documents 
including  British  type  approval  from  the  manufacturer.  However,  these 
documents  were  refused  by  the  relevant  French  authority  and  his  car 
could  not  be  registered  in  France.  The  citizen  was  advised  by  SOLVIT 
that  the  British  type  approval  was  sufficient  for  the  registration  and  he 
was signposted to contact the French authority. 

• 

Lack  of  cooperation  between  competent  approval  bodies:  Flawed 
cooperation  between  competent  authorities  and  administrative  mistakes 
sometimes  results  in  a  failure  to  deregister  the  vehicle  in  one  Member 
State while it has already been registered in another Member State. Thus, 
the vehicle is registered in two Member States at the same time, which is 
against Article 5 of Directive 1999/37/EC. 

A  SOLVIT  case  related  to  a  Belgian  citizen  who  registered  his  Belgian 
car  in  Slovenia  and  at  the  same  time  asked  the  competent  Belgian 
authority  to  deregister  his  car  there.  However,  the  authority  failed  to 
remove  his  registration  from  its  database  and  thus  the  citizens’  vehicle 

55 

For this reason, the number of cases that were analysed as infringement of the EU law results from a 
very  conservative  approach  and  may  constitute  an  underestimation  of  the  number  of  cases  involving 
infringement of EU law. Unclear cases have been coded as uncertain infringement of EU law and are 
mentioned bellow in other barriers to the exercise of single market rights. 

EN 

70 

   EN 

 
                                                 
was  registered  in  two  Member  States  simultaneously.  The  case  was 
resolved after SOLVIT intervention. 

• 

Administrative mistakes: According to SOLVIT, such flawed practices 
by the administration lead to delays and possibly breach of the EU law.  

This issue is exemplified by a Romanian citizen who wanted to register a 
vehicle in Romania that was previously registered in Belgium. The citizen 
had  all  of  the  necessary  documents;  however  the  Belgian  original 
registration  certificate  was  lost  in  the  process  of  vehicle  deregistration 
by  the  competent  Belgian  authority.  Consequently,  the  process  was 
prolonged and the requested document was sent to the citizen only after 
SOLVIT intervention. 

Other  mistakes  relate  to  citizens  who  are  prevented  from  driving  their 
vehicle with a temporary number plate in order to move it to the Member 
State of origin. This issue is illustrated by a YEA case: 

A French citizen bought a vehicle in Germany that he intended to import 
to  France.  For  this  purpose,  he  acquired  transit  number  plates  marked 
with  a  yellow  stripe  in  Germany  that  were  valid  for  five  days.  When 
driving  with  these  number  plates  in  France  the  citizen  was  pulled  over 
and subsequently arrested by French police officers who claimed that the 
plates were not valid in France. 

• 

Difficulties  in  being  granted  access  to  the  national  markets  for 
modified  cars:  Cases  also  refer  to  a  small  extent  to  companies  that 
specialize in modifying cars. They report that they have restricted access 
to  markets  of  some  Member  States,  although  their  vehicles  are  in 
conformity  with  EU  legislation.  This  is  mainly  due  to  administrative 
burdens imposed on the companies by the relevant authorities. 

12.1.3 

Other barriers to the exercise of single market rights 

• 

• 

Lack of awareness  and misunderstanding of the rules on the registration 
of  vehicles.  A  large  number  of  citizens  enquire  about  the  formalities  of 
registration  procedures.  Beyond  numerous  simple  information  requests,  many 
cases  reveal  that  the  citizens  are  unaware  of  the  fact  that  registration  of  their 
vehicle  is  subject  to  the  Member  State  of  their  residence  and  thus  they  are 
obliged  to  register  their  vehicle  when  they  move  permanently  to  another 
Member  State.  Quite  frequently,  it  is  by  chance  that  they  are  informed  about 
the  necessity  to  register  their  car  in  their  country  of  residence,  for  instance 
during a police control. 

Perceived  gap  in  Directive  1999/37/EC  in  the  case  of  cross-border  or 
posted  workers.  Due  to  a  low  level  of  harmonisation  on  registration  of 
vehicles in the EU combined with the complexity of this procedure, cases tend 
to  indicate  a  gap  in  Directive  1999/37/EC.  Although  the  EU  law  limits  the 
registration  period  when  importing  a  vehicle  to  another  Member  State  to  six 
months, individual Member States may impose their own registration deadlines 
on imported vehicles. Consequently, citizens who move to another country fail 

EN 

71 

   EN 

 
to  comply  with  national  laws  of  these  Member  States,  which  require 
registration of vehicles within a certain period of time. This is in some Member 
States much shorter than the six month period required by the EU. Citizens are 
often unaware of the low level of harmonisation and as a result their vehicles 
and  registration  documents  are  often  confiscated  by  the  national  authorities. 
This  issue  is  particularly  related  to  posted  workers  who  do  not  register  their 
vehicles in the host Member State because they do not intend to stay in the host 
Member  State  for  more  than  six  months.  Also,  frontier  and  non-resident 
workers reported cases where they have been asked to re-register their vehicles 
when they are stopped and checked by police officers in the Member State of 
employment.  

• 

• 

Difficulty  in  accessing  information  on  the  competent  national  authorities 
and the formalities for the registration of vehicles: Citizens often end up in 
difficult situations because relevant authorities of both Member States refuse to 
register their vehicle. This often occurs when citizens, while living in another 
country,  lose  their  registration  documents  that  were  issued  by  the  Member 
State of origin. When seeking replacement of the lost documents, citizens often 
do  not  know  where  to  apply.  Also,  some  cases  describe  situations  where  the 
citizens  have  difficulties  identifying  the  relevant  authority  for  approval,  and 
obtaining  clear  information  on  the  required  documents  and  the  procedures  to 
comply  with  when  registering  their  vehicles  in  another  Member  State.  Such 
situations can be rooted in contradictory information from different authorities. 

Cases  where  violation  of  the  EU  law  was  not  explicit  were  analysed  as 
uncertain  violation  of  EU  law.  In  such  cases,  citizens  often  do  not  provide 
sufficient information about why their vehicles are not approved or registered 
in another Member State. Cases falling into this category include: 

– 

– 

– 

– 

– 

administrative  burden  and  unreasonable  technical  tests  sometimes  far 
away from the place of possible registration when registering a vehicle in 
France 

confiscated cars due to failure to register in another Member State 

uncertainty of citizens about vehicle registration in another Member State 
when the vehicle belongs to a relative or a friend 

misinterpretation of country of residence (in case of posted workers) 

very high registration fees 

Nevertheless,  the  large  number  of  complaints  filed  by  the  citizens  indicates  a 
high burden when registering or buying a car abroad.’  

[…]

EN 

72 

   EN 

 
8.2. 

Annex 2: legal context of car registration in the internal market 

8.2.1.  Type-approval of new motor vehicles 

8.2.1.1.  New motor vehicles and their trailers 

Directive  2007/46/EC56  establishes  a  harmonised  framework  containing 
the 
administrative provisions and general technical requirements for approval of all new 
vehicles within its scope and of the systems, components and separate technical units 
intended  for  those  vehicles,  with  a  view  to  facilitating  their  registration,  sale  and 
entry into service within the EU. 

The  requirement  for  EC  type-approval  applies  to  all  categories  of  motor  vehicles 
designed and constructed in one or more stages for use on the road and also to the 
systems, components and separate technical units designed and constructed for such 
vehicles.  More  precisely,  the  Directive  is  aimed  at  commercial  vehicles  (vans, 
lorries, semi-trailers, trailers), buses and coaches. 

The EC type-approval system is based on the principle that manufacturers must issue 
a certificate of conformity for each vehicle manufactured, attesting that it conforms 
to the  approved type.  EC  type-approval procedures  are compulsory and replace the 
national procedures with which they have co-existed up until now.  

It  is  enough  for  one  Member  State  to  type-approve  a  vehicle  in  order  for  all  new 
vehicles of that type to be registered throughout the EU solely on the basis of their 
certificate of conformity. 

The  Directive  obliges  Member  States  to  register,  and  permit  the  sale  or  entry  into 
service of, vehicles only if they are accompanied by a valid certificate of conformity. 

8.2.1.2.  New two or three-wheeled motor vehicles 

Directive  2002/24/EC57  applies  to  two  or  three-wheeled  motor  vehicles,  whether 
twin-wheeled or otherwise (each wheel fitted with a separate tyre), intended to travel 
on the road, and to the components or separate technical units of such vehicles.  

This Directive establishes a similar type-approval system for the EU. After the type-
approval,  the  certificate  of  conformity  is  completed  by  the  manufacturer  or  his 
authorised representative for each vehicle produced in conformity with the approved 
type  and  for  each  non-original  technical  entity  or  component  manufactured  in 
conformity with the type that has been component type-approved. 

56 

57 

Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007 establishing 
a  framework  for  the  approval  of  motor  vehicles  and  their  trailers  and  of  systems,  components  and 
separate technical units intended for such vehicles. 
Directive 2002/24/EC of the European Parliament and of the Council of 18 March 2002 relating to the 
type-approval of two or three-wheeled motor vehicles and repealing Council Directive 92/61/EEC.  

EN 

73 

   EN 

 
 
                                                 
Type-approval  is  a  requirement  for  registration  since  Member  States  may  not 
prohibit the registration of new vehicles complying with the Directive. Only vehicles 
complying with the Directive may be presented for initial registration. 

8.2.1.3.  Agricultural or forestry tractors 

Directive 2003/37/EC58 applies to tractors with a maximum design speed of not more 
than  40  km/h,  any  trailer  and  any  interchangeable  towed  machinery,  whether 
incomplete or completed, which is intended to be used in agriculture or forestry. 

The  EC  type-approval  procedure  guarantees  permanent  monitoring  that  vehicles 
comply  with  EU  technical  requirements.  In  the  first  instance,  a  Member  State 
certifies  that  a  type  of  vehicle,  system,  component  or  separate  technical  unit 
presented  by  a  manufacturer  conforms  to  the  technical  prescriptions  imposed  by 
Directive  2003/37/EC.  It  then  issues  an  EC  type-approval  certificate  to  the 
manufacturer.  The manufacturer then ensures that each vehicle,  system, component 
or  separate  technical  unit  built  is  accompanied  by  a  certificate  of  conformity,  thus 
proving that it is manufactured in conformity with the approved vehicle type. 

The Directive also obliges Member States to register a new type-approved vehicle on 
grounds relating to their construction and functioning only if they are accompanied 
by  a  valid  certificate  of  conformity.  Each  Member  State  must  permit  the  sale  of 
incomplete  vehicles  but  may  refuse  their  permanent  registration  and  entry  into 
service until such time as they are completed. 

8.2.2.  Registration of motor vehicles 

Directive 1999/37/EC59 applies to the documents issued by the Member States at the 
time  of  registration  of  vehicles.  It  does  not  prevent  Member  States  to  use,  for  the 
temporary registration of vehicles, documents which may not meet the requirements 
of the Directive in every respect. 

The Directive applies to motor vehicles which are subject to Directives 2007/46/EC 
and 2002/24/EC, and not to agricultural or forestry tractors. 

It  obliges  Member  States  to  issue  a  registration  certificate  for  vehicles  that  are 
subject to registration under their national legislation. The certificate must consist of 
either  a  single  part  in  accordance  with  Annex  I  of  the  Directive  or  two  parts  in 
accordance  with  Annexes  I  and  II.  The  data  given  in  the  registration  certificate,  in 
accordance with Annexes I and II, must be represented by the harmonised EU codes 
shown in those Annexes. 

The Directive specifies that a registration certificate issued by a Member State must 
be  recognised  by  the  other  Member  States  for  the  identification  of  the  vehicle  in 
international  traffic  or  for  its  re-registration  in  another  Member  State.  For  the 

58 

59 

Directive 2003/37/EC of the European Parliament and of the Council of 26 May 2003 on type-approval 
of  agricultural  or  forestry  tractors,  their  trailers  and  interchangeable  towed  machinery,  together  with 
their systems, components and separate technical units and repealing Directive 74/150/EEC.  
Council Directive 1999/37/EC of 29 April 1999 on the registration documents for vehicles.  

EN 

74 

   EN 

 
                                                 
identification of a vehicle in road traffic, Member States may require that the driver 
carry Part I of the registration certificate. 

The harmonised registration certificate should facilitate the re-registration. When the 
re-registration is sought for a motor vehicle previously registered in another Member 
State, the following steps have to be followed: 

• 

• 

The  competent  authorities  in  the  receiving  Member  State  have  to  require  the 
submission  of  Part  I  of  the  previous  registration  certificate  in  every  case  and 
the submission of Part II if it was issued.  

The competent authorities in the receiving Member State have to withdraw the 
part(s)  of  the  previous  registration  certificate  submitted  and  keep  it  for  a 
minimum of six months. 

•  Within  two  months,  they  must  inform  the  authorities  of  the  Member  State 
which  delivered  the  certificate  of  its  withdrawal.  They  have  to  return  the 
certificate  which  they  have  withdrawn  to  the  authorities  of  the  Member  State 
which  delivered  the  certificate  if  they  request  so  within  six  months  of  its 
withdrawal. 

Where the registration certificate consists of Parts I and II, and Part II is missing, the 
competent  authorities  in  the  Member  State  where  the  new  registration  has  been 
requested may decide, in exceptional cases, to re-register the vehicle, but only after 
having obtained confirmation, in writing or by electronic means, from the competent 
authorities in the Member State where the vehicle was previously registered, that the 
applicant is entitled to re-register the vehicle in another Member State.  

According to the Directive, Member States may exchange information at bilateral or 
multilateral level in particular so as to check, before any registration of a vehicle, the 
latter's legal status, where necessary in the Member State in which it was previously 
registered. The Directive provides for the possibility of using an electronic network. 

The  Court  of  Justice  confirmed  that  the  harmonisation  effected  by  Directive 
1999/37/EC  was  not  exhaustive.  The  Court  refers,  in  that  regard,  to  Point  II.7  in 
Annex I to that directive, according to which Member States may include, in Part I of 
the registration document, information in addition to that which it is compulsory to 
include  pursuant  to  Annex  I.  Therefore,  the  Court  of  Justice  concluded  that,  in 
accordance  with  Point  II.7,  Directive  1999/37/EC  does  not  preclude  national 
provisions  which  include,  in  Part  I  of  the  registration  document,  information  in 
addition to that which it is compulsory to include, provided that they do not infringe 
the provisions of the TFEU, including Articles 34 TFEU and 36 TFEU (Judgment of 
the  Court  of  6  October  2011,  Philippe  Bonnarde  v  Agence  de  Services  et  de 
Paiement, Case C-443/10). 

8.2.3.  The role of registration in the field of transport 

8.2.3.1.  Hiring of vehicles for the carriage of goods 

In  the  EU  legislation  on  the  internal  market  for  the  transport  of  goods,  the 
registration of the vehicle is sometimes a relevant factor, for example for the hiring 

EN 

75 

   EN 

 
of vehicles for the carriage of goods. Each Member State must allow the use within 
its territory of vehicles (i.e. motor vehicles, trailers, semi-trailers, or a combination of 
vehicles  intended  exclusively  for  the  carriage  of  goods)  hired  by  undertakings 
established  on  the  territory  of  another  Member  State  provided,  inter  alia,  that  the 
vehicle is registered or put into circulation in compliance with the laws in the latter 
Member State60.  

8.2.3.2.  Periodic roadworthiness tests 

Directive  2009/40/EC61  specifies  that,  in  each  Member  State,  motor  vehicles 
registered  in  that  State  and  their  trailers  and  semi-trailers  must  undergo  periodic 
roadworthiness  tests  in  accordance  with  the  Directive.  Annexes  I  and  II  of  the 
Directive  set  out  the  categories  of  vehicles  to  be  examined,  the  frequency  of  these 
checks and the parts to be tested.  

The  minimum  testing  frequency  for  the  different  categories  of  motor  vehicles  and 
their trailers is: 

– 

– 

One  year  after  the  date  on  which  the  vehicle  was  first  used,  and  thereafter 
annually for motor vehicles used for the carriage of passengers and with more 
than  eight  seats,  excluding  the  driver’s  seat,  motor  vehicles  used  for  the 
carriage  of  goods  and  having  a  maximum  permissible  mass  exceeding  3,500 
kg,  trailers  and  semi-trailers  with  a  maximum  permissible  mass  exceeding 
3,500 kg, taxis and ambulances;  

Four  years  after  the  date  on  which  the  vehicle  was  first  used,  and  thereafter 
every two years for motor vehicles having at least four wheels, normally used 
for  the  road  carriage  of  goods  and  with  a  maximum  permissible  mass  not 
exceeding 3,500 kg, excluding agricultural tractors and machinery, and motor 
vehicles  having  at  least  four  wheels,  used  for  the  carriage  of  passengers  and 
with not more than eight seats excluding the driver’s seat.  

The tests covered by Annex II should be undertaken using techniques and equipment 
available without the use of tools to disassemble or remove any part of the vehicle. 
Where the motor vehicle is found to be defective with regard to a specific list of test 
items,  the  competent  authority  must  set  specific  conditions  under  which  the 
particular vehicle may be used before passing another roadworthiness test. The test 
must  cover  the  items  listed  in  the  annex,  provided  that  these  are  related  to  the 
equipment of the vehicle being tested in the EU country concerned.  

The vehicle operator or driver must be informed in writing of any defects, the result 
of the test and the legal consequences. All Member States have to mutually recognise 
the proof issued in another EU country showing that a vehicle registered in that other 
EU country, together with its trailer or semi-trailer, has passed a roadworthiness test 
in compliance with the provisions of this Directive.  

60 

61 

Directive 2006/1/EC of the European Parliament and of the Council of 18 January 2006 on the use of 
vehicles hired without drivers for the carriage of goods by road. 
Directive 2009/40/EC of the European Parliament and of the Council of 6 May 2009 on roadworthiness 
tests for motor vehicles and their trailers.  

EN 

76 

   EN 

 
                                                 
However,  Member  States  are  allowed  to  bring  forward  the  date  for  the  first 
compulsory  roadworthiness  test  and,  where  appropriate,  require  the  vehicle  to  be 
submitted  for  test  prior  to  registration.  They  may  also  shorten  the  interval  between 
two successive compulsory tests, make the testing of optional equipment compulsory 
and increase the number of items to be tested. In addition, Member States can extend 
the  periodic  test  requirement  to  other  categories  of  vehicles,  prescribe  special 
additional  tests  and  require  vehicles  registered  on  their  territory  to  have  higher 
minimum standards for braking efficiency under certain circumstances. 

8.2.3.3.  Recommendation 2010/378/EU (Periodic inspections of vehicles) 

Commission Recommendation of 5 July 2010 addresses certain issues regarding the 
assessment  of  defects  during  roadworthiness  testing  in  accordance  with  Directive 
2009/40/EC.  The  Recommendation  provides  a  guideline  on  standards  and  testing 
methods referred to in 2009/40/EC for inspectors conducting vehicle tests in order to 
ensure  a  harmonised  assessment  of  the  failures  listed  in  Annex  II  of  the  Directive. 
The  Recommendation  is  seen  as  a  step  towards  a  uniform  assessment  of  the 
deficiencies identified during roadworthiness testing within the EU. 

Three  categories  of  failure  are  introduced,  to  reflect  the  seriousness  of  the  defect, 
with the consequences for the use of the vehicle in that condition given as shown in 
the following table. 

Type 
defect 

Minor 

Major 

of 

Definition 

Action 

Technical  defects  that  have  no 
significant effect on the safety of 
the vehicle and other minor non-
compliances. 

The  vehicle  does  not  necessarily  have  to  be 
re-examined as it can reasonably be expected 
that  the  detected  defects  will  be  rectified 
without delay. 

Defects  that  may  prejudice  the 
safety of the vehicle or put other 
road users at risk and other more 
significant non-compliances. 

Further use of the vehicle on the road without 
repair  of  the  detected  defects  is  subject  to 
conditions.  The  competent  authorities  in  the 
Member  States  must  adopt  a  procedure  for 
setting the conditions under which the vehicle 
may  be  used  before  passing  another 
roadworthiness test. 

Dangerous  Defects  that  constitute  a  direct 
and immediate risk to road safety. 

The  vehicle  should  not  be  used  on  the  road 
under any circumstances. 

Note: A vehicle having defects falling into more than one defect group is classified according to 
the most serious defect. A vehicle showing several defects of the same group can be classified in 
the next more serious group if their combined effect makes the vehicle more dangerous. 

EN 

77 

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Current frequencies of period roadworthiness tests (Table 1) 

Private cars 

Goods vehicles 
< 3,500 kg 

Goods vehicles 
> 3,500 kg 

Passenger 
vehicles < 8 
passengers 

Passenger 
vehicles > 8 
passengers 

4/1/1 

3/2/1/1 

4/2/2 

4/2/2 

3/2/2 

3/2/2/2/1 

4/2/2 

n/a 

6m/6m/6m 

6m/6m/6m 

6m/6m/6m 

3m/3m/3m 

- 

4/2/2 

4/1/1 

2/2/2 

1/1/1 

4/2/2 

n/a 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

n/a 

- 

4/2/2 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

n/a 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

n/a 

n/a 

4/2/2/1 

2(x3)/1(x4)/6m

1(x10)/6m 

2/1/1/1/6m 

1(x5)/6m 

4/2/2 

4/2/2 

4/2/2 

2/2/2 

3/2/2 

3.5/1/1 

4/3/2/2 

1/1/1 

4/2/2/1 

3/2/1 

3/2/1 

4/2/2/1 

2/2/2 

3/2/2 

3/1/1 

3/2/1 

3/2/1 

4/2/2 

4/2/2 

- 

1/1/1 

- 

1/1/1 

2/2/1/1 

- 

3/1/1 

1/1/1 

3/2/1 

2/1/1 

- 

3/1/1 

- 

3/1/1 

1/1/1 

3/1/1 

1/1/1 

1/1/1 

1/1/1 

4/2/2 

4/2/2 

- 

6m/6m/6m 

6m/6m/6m 

- 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

6m/6m/6m 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

- 

3.5/1/1 

3/3/2/2 

- 

1/1/1 

1/1/1 

1/1/1 

1(x7)/6m 

1(x7)/6m 

- 

3/1/1 

- 

1/1/1 

1/1/1 

3/1/1 
1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

6m/6m/6m 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1(x7)/6m 

1/6m/6m 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

Belgium 

Bulgaria 

Czech Republic 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

United Kingdom 

3/1/1 

Source: AUTOFORE Study on the Future Options for Roadworthiness in the European Union: WP540 –
Analysis  of  pass/fail  rates  and  accidents  for  different  vehicle  types  in  relation  to  PTI  –  frequency  and 
vehicle age; DEKR 

EN 

78 

   EN 

 
 
 
Current frequencies of period roadworthiness tests (Table 2) 

Trailers < 3,500 kg  Trailers > 3,500 kg

Agricultural 
tractors 

Motorcycles 

Belgium 

Bulgaria 

Czech Republic 

Denmark 

1/1/1 

- 

4/2/2 

n/a 

3/2/2 (<750kg) 
2/2/2 (>750kg) 

3/2/2/2/1 

1/1/1 

n/a 

6m/6m/6m 

6m/6m/6m 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

n/a 

n/a 

- 

4/4/4 

n/a 

2/2/2 
1/1/1 

2/1/1/1 

n/a 

n/a 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

United Kingdom 

2(x3)/1(x4)/6m 

1(x10)/6m 

1(x10)/6m 

- 

1/1/1 

- 

1/1/1 

- 

3.5/1/1 

2/2/1/1 

- 

- 

3/2/1 

3/2/1 

n/a 

- 

3/1/1 

- 

2/2/2 

4/2/2 

n/a 

- 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

6m/6m/6m 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

- 

- 

- 

n/a 

- 

3.5/1/1 

3/3/2/2 

- 

- 

3/2/1 

3/2/2 

1(x7)/6m 

1(x7)/6m 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

1/1/1 

- 

3/1/1 

- 

n/a 

n/a 

n/a 

n/a 

- 

4/2/2 

n/a 

2/2/2 

3/2/2/2/1 

n/a 

n/a 

5/2/2 

- 

4/2/2 

- 

1/1/1 

- 

3.5/1/1 

3/3/2/2 

- 

- 

1/1/1 

3/2/1 

n/a 

- 

3/1/1 

- 

n/a 

4/2/2 

3/1/1 

Source: AUTOFORE Study on the Future Options for Roadworthiness in the European Union: WP540 –
Analysis  of  pass/fail  rates  and  accidents  for  different  vehicle  types  in  relation  to  PTI  –  frequency  and 
vehicle age; DEKR 

EN 

79 

   EN 

 
 
 
8.2.3.4.  Technical roadside inspection of the roadworthiness of commercial vehicles 

For commercial vehicles, Directive 2000/30/EC62 organises roadside roadworthiness 
checks  on  commercial  vehicles  that  are  intended  to  carry  passengers  or  goods.  It 
supplements Directive 2009/40/EC. These roadside checks are unannounced checks 
on a commercial vehicle travelling within a European Union (EU) country. They are 
carried  out  by  the  authorities  on  roads,  in  ports,  or  anywhere  else  considered 
appropriate. 

A  technical  roadside  inspection  may  comprise  a  visual  check  on  the  state  of 
maintenance of the vehicle running on the road network, a check on the documents 
relating to the compliance of the vehicle with a technical roadside inspection and if 
the driver presents it a recent roadside technical inspection report, and/or a check to 
uncover  poor  maintenance  (smooth  tyres,  faulty  braking  system,  etc.).  In  this 
instance,  the  inspector  should  take  the  most  recent  documents  and  any  other  safety 
certificate into consideration.  

Appropriate roadside checks have to be carried out without discrimination as to the 
driver’s  nationality  or  vehicle  registration.  They  should  cover  a  significant, 
representative cross-section of commercial vehicles of all categories. 

If the results of a roadside check show that a commercial vehicle does not meet the 
standards  set  out  in  the  Directive,  or  if  it  is  not  shown  to  comply  with  Directive 
2009/40/EC  during  a  subsequent  roadworthiness  test  at  an  approved  testing  centre 
and if it therefore constitutes a major risk to its occupants or other road users, the use 
of that vehicle on the public highway will immediately be banned.  

Serious  or  repeated  offences  by  a  vehicle  belonging  to  a  non-resident  must  be 
reported  to  the  authorities  in  the  EU  country  where  the  vehicle  or  company  is 
registered. The country in which the offence has been repeated may then request that 
action  be  taken  against  the  offender.  Where  such  action  is  taken,  the  country  of 
vehicle or company registration has to inform the country in which the offences have 
been noted of the action taken against the carrier or company concerned. 

8.2.3.5.  Recommendation 2010/379/EU (Roadside checks) 

Commission Recommendation of 5 July 2010 deals with certain issues, regarding the 
risk  assessment  of  deficiencies  detected  during  technical  roadside  inspections  (of 
commercial vehicles) in accordance with Directive 2000/30/EC. 

The Recommendation provides a guideline on standards and testing methods for the 
assessment of deficiencies listed in Annex II of Directive 2000/30/EC for inspectors 
conducting  technical  roadside  inspections,  in  order  to  achieve  a  more  harmonised 
roadside  testing  system  and  to  avoid  unequal  treatment  at  technical  roadside 
inspections. 

62 

Directive 2000/30/EC of the European Parliament and of the Council of 6 June 2000 on the technical 
roadside inspection of the roadworthiness of commercial vehicles circulating in the Community. 

EN 

80 

   EN 

 
                                                 
8.2.4.  Motor insurance 

The EU Motor Insurance Directive 2009/103/EC63 obliges all motor vehicles in the 
EU to be covered by compulsory third party insurance and ensures the abolition of 
border checks on insurance so that vehicles can be driven as easily between Member 
States as within one country.  

All  compulsory  motor  insurance  policies  should  cover,  on  the  basis  of  a  single 
premium and during the whole term of the contract, the entire territory of the Union, 
including for any period in which the vehicle remains in other Member States during 
the term of the contract.  

In  addition,  the  EU  Motor  Insurance  Directive  provides  for  a  mechanism  to 
compensate the local victims of accidents caused by vehicles from another Member 
State.  The  Directive  builds  in  this  respect  upon  the  private  sector  network  of 
‘national  insurers’  bureau’  and  the  Green  Card  System  set  up  by  insurers  which 
handle the victims’ claims. The Directive also establishes an efficient mechanism for 
the  quick  settlement  of  claims  where  the  accident  takes  place  outside  the  victim’s 
Member State of residence (the so-called ‘visiting victims’). 

Motor vehicles may – provided that they are in a regular situation with respect to the 
national registration rules – be insured by an insurer established in the Member State 
of  registration  or  by  an  insurer  established  in  any  other  Member  State.  Insurers 
willing  to  provide  cross-border  insurance  services  must  fulfil  certain  formalities 
following on from the relevant EU insurance legislation. They also need to be willing 
to  offer  a  contract  (according  to  the  fundamental  EU  principle  of  commercial 
freedom,  neither  an  insurer  nor  a  consumer  can  be  forced  to  enter  into  a  business 
relationship). 

8.2.5.  Cross-border car crime 

• 

Council  Decision  2008/615/JHA64  provides  for  the  possibility  of  information 
exchange  between  Member  States  for  the  prevention  and  investigation  of 
criminal  offences  and  in  dealing  with  other  offences  coming  within  the 
jurisdiction  of  the  courts  or  the  public  prosecution  service  in  the  searching 
Member State, as well as in maintaining public security. Member States have 
to allow other Member States’ national contact points access to certain national 
vehicle  registration  data,  with  the  power  to  conduct  automated  searches  in 
individual cases, namely data relating to holders or operators and data relating 
to  vehicles.  Searches  may  be  conducted  only  with  a  full  chassis  number  or  a 
full registration number. Searches may be conducted only in compliance with 
the searching Member State’s  national law. The exchange of information and 
the supply of data take place between the national contact points designated by 
the Member States. 

63 

64 

Directive 2009/103/EC of the European Parliament and of the Council of 16 September 2009 relating to 
insurance  against  civil  liability  in  respect  of  the  use  of  motor  vehicles,  and  the  enforcement  of  the 
obligation to insure against such liability. 
Council  Decision  2008/615/JHA  of  23  June  2008  on  the  stepping  up  of  cross-border  cooperation, 
particularly in combating terrorism and cross-border crime. 

EN 

81 

   EN 

 
                                                 
• 

• 

The  details  of  technical  arrangements  for  the  procedure  are  laid  down  in 
Council  Decision  2008/616/JHA65.  For  automated  searching  of  vehicle 
registration  data,  Member  States  use  the  European  Vehicle  and  Driving 
Licence  Information  System  (EUCARIS)  software  application  especially 
designed  for  the  purposes  of  Article  12  of  Decision  2008/615/JHA,  and 
amended  versions  of  this  software.  The  information  exchanged  via  the 
EUCARIS  system  is  transmitted  in  encrypted  form.  The  data  elements  of  the 
vehicle  registration  data  that  are  exchanged  are  set  out  in  Chapter  3  of  the 
Annex to this Decision. Each Member State has to bear the costs arising from 
the administration, use and maintenance of the EUCARIS software application. 

The  objective  of  Council  Decision  2004/919/EC  of  22  December  2004  on 
tackling  vehicle  crime  with  cross-border  implications  is  to  achieve  improved 
cooperation  within  the  European  Union  with  the  aim  of  preventing  and 
combating cross-border vehicle crime, whereby particular attention is given to 
the  relationship  between  vehicle  theft  and  the  illegal  car  trade.  The  Decision 
obliges  each  Member  State  to  ensure  that  its  competent  authorities  take  the 
necessary  steps  to  prevent  abuse  and  theft  of  vehicle  registration  documents. 
The Decision obliges national vehicle registration authorities to be informed by 
law enforcement authorities of whether a vehicle that is in the process of being 
registered is known to have been stolen. The Decision also aims at preventing 
the  abuse  of  vehicle  registration  certificates:  each  Member  State  must  ensure 
that  its  competent  authorities  take  the  necessary  steps  to  recover  a  vehicle 
owner’s  or  vehicle  holder’s  registration  certificate  if  the  vehicle  has  been 
seriously  damaged  in  an  accident  (total  loss).  A  registration  certificate  must 
also be recovered where, during a check by the law enforcement agency, it is 
suspected that there has been an infringement concerning the vehicle’s identity 
markings,  such  as  the  vehicle  identification  number.  Regulation  (EC)  No 
1160/200566  authorises  the  services  responsible  for  issuing  registration 
certificates  for  vehicles  to  consult  the  ‘Schengen  Information  System’  (SIS) 
before  registering  a  vehicle.  As  the  SIS  contains,  in  particular,  information 
about  stolen,  hijacked  or  lost  motor  vehicles,  this  should  reinforce  the  fight 
against vehicle theft.  

8.2.6.  End-of life vehicles 

Directive  2000/53/EC67 obliges the Member States, inter alia, to take the necessary 
measures to ensure that all end-of life vehicles are transferred to authorised treatment 
facilities. 

65 

66 

67 

Council Decision 2008/616/JHA of 23 June 2008 on the implementation of Decision 2008/615/JHA on 
the stepping up of cross-border cooperation, particularly in combating terrorism and cross-border crime.  
Regulation (EC) No 1160/2005 of the European Parliament and of the Council of 6 July 2005 amending 
the  Convention  implementing  the  Schengen  Agreement  of  14  June  1985  on  the  gradual  abolition  of 
checks at common borders, as regards access to the Schengen Information System by the services in the 
Member  States  responsible  for  issuing  registration  certificates  for  vehicles  authorises  the  services 
responsible for issuing registration certificates for vehicles. 
Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of 
life vehicles.  

EN 

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According to the Directive, Member States must set up a system according to which 
the presentation of a certificate of destruction is a condition for deregistration of the 
end-of  life  vehicle.  This  certificate  is  issued  to  the  holder  and/or  owner  when  the 
end-of life vehicle is transferred to a treatment facility. Treatment facilities that have 
a permit may issue certificates of destruction.  

Member  States  may  permit  producers,  dealers  and  collectors  on  behalf  of  an 
authorised  treatment  facility  to  issue  certificates  of  destruction  provided  that  they 
guarantee that the end-of life vehicle is transferred to an authorised treatment facility 
and provided that they are registered with public authorities. 

EN 

83 

   EN 

 
8.2.7. 

Jurisprudence of the Court of Justice on car registration since 2000 

The  following  overview  does  not  include  judgements  with  respect  to  the  fiscal 
treatment  of  car  registration  (i.e.  jurisprudence  concerning  the  interpretation  of 
Articles  30  and  110  TFEU,  and  Directives  83/182/EEC,  2009/55/EC,  1999/62/EC 
and 2006/112/EC) which falls outside the scope of this impact assessment: 

Case 

Judgment of 12 
October 2000 

Snellers Auto’s BV 
v Algemeen 
Directeur van de 
Dienst Wegverkeer 

Case C-314/98 

Judgment of 21 
March 2002 

Cura Anlagen 
GmbH v Auto 
Service Leasing 
GmbH (ASL).  

Case C-451/99 

Summary 

National rules which provide that the date on which an imported vehicle 
was first authorised for use on the public highway is to be fixed at the 
date  on  which  its  registration  certificate  was  issued  only  where  the 
vehicle  has  not  been  registered  for  more  than  two  days  in  another 
Member  State  constitute  a  measure  having  an  effect  equivalent  to  a 
quantitative  restriction  on  imports  for  the  purposes  of  Article  28  EC 
(now Article 34 TFEU).  

Such national rules may, in spite of their restrictive effects on the free 
movement  of  goods,  be  justified  by  imperative  requirements  such  as 
road safety and/or protection of the environment if it can be shown that 
the  resulting  restriction  is  necessary  to  ensure  road  safety  and/or 
protection  of 
is  not 
disproportionate  to  those  objectives,  particularly  in  the  sense  that  no 
other, less restrictive, measures are available.  

the  environment  and 

the  restriction 

that 

The provisions of the EC Treaty on the freedom to provide services (Articles 49 EC to 55 EC – 
now  Articles  56  and  62  TFEU)  preclude  legislation  of  a  Member 
State,  such  as  that  at  issue  in  the  main  proceedings,  requiring  an 
undertaking established in that Member State which takes a lease of a 
vehicle registered in another Member State to register it  in  the first 
Member State in order to be able to use it there beyond a period that 
is  so  short,  in  this  case  three  days,  that  it  makes  it  impossible  or 
excessively difficult to comply with the requirements imposed. The 
same provisions of the Treaty preclude legislation of a Member State, 
such  as  that  at  issue  in  the  main  proceedings,  requiring  an 
undertaking established in that Member State which takes a lease of a 
vehicle registered in another Member State to register it  in  the first 
Member  State  and  imposing  on  it  one  or  more  of  the  following 
conditions: 

-  a  requirement  that  the  person  in  whose  name  the  vehicle  is 
registered  in  the  Member  State  of  use  reside  or  has  a  place  of 
business there, in so far as it obliges a leasing undertaking either to 
have a principal place of business in that Member State or to accept 
registration  of  the  vehicle  in  the  name  of  the  lessee  and  the 
consequent limitation of its rights over the vehicle;  

- a requirement to insure the vehicle with an authorised insurer in the 
Member State of use, if that requirement implies that the insurer must 
have its principal place of business in that Member State, as the home 
State  within  the  meaning  of  the  non-life  insurance  Directives,  and 

EN 

84 

   EN 

 
have official authorisation there;  

- a requirement of a roadworthiness test when the vehicle has already 
undergone  such  testing  in  the  Member  State  where  the  leasing 
company  is  established,  save  where  that  requirement  is  aimed  at 
verifying that the vehicle satisfies the conditions imposed on vehicles 
registered in the Member State of use that are not covered by the tests 
carried  out  in  the  Member  State  where  the  leasing  company  is 
established and/or, if the vehicle has in the meantime been used on 
the public highway, that its condition has not deteriorated since it was 
tested in that latter Member State, provided similar testing is imposed 
where  a  vehicle  previously  tested  in  the  Member  State  of  use  is 
presented for registration in that State;  

-  payment,  in  the  Member  State  of  use,  of  a  consumption  tax  the 
amount of which is not proportionate to the duration of the registration 
of the vehicle in that State.  

Article  39  EC  (now Article  45  TFEU)  precludes  national  rules  of  a 
Member  State,  such  as  those  in  the  present  case,  which  prohibit  a 
worker  who  is  domiciled  in  that  Member  State  from  using  on  its 
territory  a  vehicle  registered  in  another  neighbouring  Member  State, 
belonging  to  a  leasing  company  established  in  that  second  Member 
State, and made available to the worker by his employer who is also 
established in the second Member State. 

Article 29 EC (now Article 35 TFEU) precludes the rules of a Member 
State  which  prohibit  a  national  of  another  Member  State,  on  pain  of 
criminal  penalties  such  as  imprisonment  or  a  fine,  from  taking  to  that 
other  State  a  vehicle  purchased  in  the  first  Member  State  bearing  a 
temporary  number  plate  issued,  for  the  purpose  of  the  export  of  the 
vehicle to that other Member State, by the competent authorities of the 
latter State, if those rules are of such a kind as to restrict export patterns, 
create a difference in treatment between a State’s domestic trade and its 
external  trade  and  give  rise  to  an  advantage  for  national  trade  at  the 
expense of another Member State, provided that those rules cannot be 
justified  under  Article  30  EC  (now  Article  36  TFEU).  It  is  for  the 
national court to ascertain whether that is so in the main proceedings. If 
the  rules  at  issue  in  the  main  proceedings  are  held  to  be  contrary  to 
Article  29  EC  (now  Article  35  TFEU),  the  penalties  for  which  they 
make provision are inapplicable. 

Judgment of 2 
October 2003.  

Criminal 
proceedings against 
Hans van Lent  

Case C-232/01 

Judgment of 2 
October 2003.  

Criminal 
proceedings against 
Marco Grilli.  

Case C-12/02 

Judgment of 15 
September 2005.  

Commission of the 
European 
Communities v 
Kingdom of 
Denmark 

In so far as  

-  its  legislation  and  administrative  practice  do  not  allow  workers 
resident in Denmark and employed in another Member State in work 
which is not their principal employment to use for business or private 
purposes  a  company  vehicle  registered  in  that  other  Member  State 
where the undertaking of their employer is established, and  

- its legislation and administrative practice allow employees resident in 

EN 

85 

   EN 

 
Case C-464/02 

Judgment of 15 
December 2005.  

Criminal 
proceedings against 
Claude Nadin, 
Nadin-Lux SA (C-
151/04) and Jean-
Pascal Durré (C-
152/04).  

Judgment of 23 
February 2006.  

Commission of the 
European 
Communities v 
Republic of 
Finland 

Case C-232/03 

Denmark and employed in another Member State to use for business 
purposes  or  business  and  private  purposes  a  company  vehicle 
registered in that other Member State in which their employer has its 
registered  office  or  principal  establishment,  the  vehicle  neither  being 
intended to be essentially used in Denmark on a permanent basis nor 
being  actually  so  used,  only  subject  to  the  condition  that  the 
employment with that employer is their main employment and that a 
tax is paid for that purpose,  

the  Kingdom  of  Denmark  has  failed  to  fulfil  its  obligations  under 
Article 39 EC (now Article 45 TFEU).  

It is contrary to Article 43 EC (now Article 49 TFEU) for the domestic 
legislation of one Member State, such as the legislation at issue in the 
cases  in  the  main  proceedings,  to  require  a  self-employed  worker 
residing in that Member State to register there a company vehicle made 
available  to  him  by  the  company  for  which  he  works,  established  in 
another Member State, when it is not intended that that vehicle should 
be used essentially in the first Member State on a permanent basis and 
it is not, in fact, used in that manner. 

By preventing cross-frontier workers residing in Finland and employed 
in  another  Member  State  from  benefiting  from  the  use  of  company 
vehicles  which  are  made  available  by  their  employers  established  in 
another  Member  State  and  registered  in  the  latter  State  on  the  sole 
ground  that  the  cross-frontier  workers  concerned  reside  on  Finnish 
territory,  into  which  the  vehicles  belonging  to  their  employers  have 
been imported;  

and 

by  preventing  the  cross-frontier  workers  concerned  from  benefiting, 
for  professional  and  private  purposes,  from  the  use  of  company 
vehicles  which  are  made  available  by  their  employers  established  in 
another  Member  State  and  registered  in  the  latter  State,  while  those 
vehicles  are  neither  intended  to  be  used  mainly  in  Finland  on  a 
permanent basis nor, in fact, used in that way, on the sole ground that 
those  workers  reside  on  Finnish  territory,  into  which  the  vehicles 
belonging to their employers have been imported,  

the Republic of Finland has failed to fulfil its obligations under Article 
39 EC(now Article 45 TFEU).  

Order of the Court 
of 2 May 2006.  

Criminal 
proceedings against 
Henri Léon 

Article 43 EC (now Article 49 TFEU) precludes national legislation of 
one  Member  State,  such  as  the  legislation  at  issue  in  the  main 
proceedings,  which  obliges  a  self-employed  person  residing  in  that 
Member  State  to  register  a  company  vehicle  provided  to  him  by  the 
company  which  employs  him  and  which  is  established  in  another 
Member State, when the company vehicle is neither actually intended 

EN 

86 

   EN 

 
to be used permanently in the first Member State nor is in fact used in 
that way.  

Articles 49 EC to 55 EC (now Articles 56 to 62 TFEU) do not preclude 
the domestic legislation of a Member State, such as that at issue in the 
main proceedings, from prohibiting a person who resides and works in 
that State from using, in that State, a vehicle which he has rented from 
a  leasing  company  established  in  another  Member  State,  when  that 
vehicle has not been registered in the first State and it is intended that it 
should  be  used  there  essentially  on  a  permanent  basis  or  is,  in  fact, 
used in that manner. 

Articles  49  EC  to  55  EC  (now  Articles  56  to  62  TFEU)  preclude 
national legislation of a Member State, such as that at issue in the main 
proceedings,  which  requires  a  natural  person  established  in  that 
Member State who leases a vehicle registered in another Member State 
to  pay  the  full  amount  of  a  registration  tax  when  the  vehicle  is  first 
used on the highway in the first Member State, without taking account 
of  the  duration of the  use of that highway and without the person in 
question  having  any  right  to  an  exemption  or  a  refund,  where  the 
vehicle is neither intended to be used essentially in the first Member 
State on a permanent basis nor in fact used in that way. 

By  requiring  a  transfer  licence  for  the  putting  into  circulation  of 
vehicles  lawfully  registered and used in another Member State, […], 
the Republic of Finland has failed to fulfil its obligations under Articles 
28 EC and 30 EC (now Articles 34 and 36 TFEU).  

Schmitz 

Case C-291/04 

Order of 30 May 
2006.  

Criminal 
proceedings against 
Sébastien Victor 
Leroy.  

Case C-435/04 

Order of 27 June 
2006.  

G. M. van de 
Coevering v Hoofd 
van het District 
Douane Roermond 
van de 
rijksbelastingdienst.  

Case C-242/05 

Judgment of 15 
March 2007.  

Commission of the 
European 
Communities v 
Republic of 
Finland 

Case C-54/05 

Judgment of 20 
September 2007.  

Intra-EU trade is not capable of being hindered, directly or indirectly, 
actually or potentially, by national legislation which:  

Commission of the 
European 
Communities v 
Kingdom of the 
Netherlands.  

Case C-297/05 

- requires a vehicle to be identified before it is registered;  

-  requires,  pursuant  to Articles  2(b)  and  4  of  Directive  1999/37,  that 
such identification be carried out, where a vehicle previously registered 
in  another  Member  State  is  imported,  by  means  of  the  registration 
certificate issued by that other Member State; and 

-  includes  the  obligation  to  present  the  vehicle  to  a  control  body, 
thereby  allowing  verification  as  to  whether  the  vehicle  is  actually 
present  in  the  territory  of  the  Member  State  of  importation  and 
corresponds to the data in the registration certificate issued by the other 
Member State. Since that is a simple administrative formality, which 

EN 

87 

   EN 

 
does  not  introduce  any  additional  check,  but  which  is  integral  to  the 
actual processing of the registration application and also to the conduct 
of the associated procedure, the manner in which the tests are carried 
out  is  not  capable  of  having  any  deterrent  effect  whatsoever  on  the 
import  of  a  vehicle  into  that  Member  State  or  of  making  such 
importation less attractive.  

2.  A  Member  State  which,  generally  and  systematically,  submits  all 
vehicles which are more than three years old and have previously been 
registered  in  other  Member  States  for  testing  as  to  their  physical 
condition prior to registration in that State, without taking any account 
whatsoever  of  tests  that  may  have  already  been  carried  out  in  other 
Member States, fails to fulfil its obligations under Articles 28 EC and 
30  EC  (now  Articles  34  and  36  TFEU).  Such  a  control  procedure, 
which  may  deter  some  persons  concerned  from  importing  into  the 
Member State in question vehicles which are more than three years old 
and  which  have  previously  been  registered  in  other  Member  States, 
cannot be justified on the ground that it safeguards road safety and the 
protection  of  the  environment  where  the  Member  State  in  question 
does not specifically show that the restriction on the free movement of 
goods at issue is proportionate to the objective pursued.  

By requiring, in accordance with the practice in issue, for the purposes 
of  the  registration  of  vehicles  in  Luxembourg,  the  submission  of  an 
excerpt  from  the  commercial  register  or  a  comparable  document 
proving that the seller of the vehicle is registered as a dealer, except for 
dealers on the register of the Société Nationale de Contrôle Technique, 
the  Grand  Duchy  of  Luxembourg  has  failed  to  fulfil  its  obligations 
under Article 28 EC (now Article 34 TFEU). 

By subjecting imported second-hand vehicles previously registered in 
other Member States to a roadworthiness test prior to their registration 
in  Poland,  the  Republic  of  Poland  has  failed  to  fulfil  its  obligations 
under Article 28 EC (now Article 34 TFEU). 

Articles 43 EC and 49 EC (now Articles 49 and 56 TFEU) are to be 
interpreted  as  precluding  national  legislation  of  one  Member  State, 
such as that in question in the main proceedings, under which a self-
employed person residing in that Member State is required to register 
there a vehicle leased from a company established in another Member 
State,  when  it  is  not  intended  that  that  vehicle  should  be  used 
essentially in the first Member State on a permanent basis and it is not, 
in fact, used in that manner. 

Judgment of 24 
April 2008.  

Commission of the 
European 
Communities v 
Grand Duchy of 
Luxemburg.  

Case C-286/07 

Judgment of 5 June 
2008.  

Commission of the 
European 
Communities v 
Republic of Poland.  

Case C-170/07 

Order of 24 
October 2008.  

Marc Vandermeir v 
Belgian State - SPF 
Finances.  

Case C-364/08 

EN 

88 

   EN 

 
By requiring, for the purposes of their first registration in Austria, that 
motor  vehicles  previously  registered  in  other  Member  States  which 
have  not  undergone,  because  of  their  age,  a  EU  type-approval 
procedure, comply with limit values in respect of pollutant emissions 
and  noise  which  are  stricter  than  those  they  initially  had  to  comply 
with,  in  particular,  the  values  laid  down  in  Council  Directive 
93/59/EEC  of  28  June  1993  amending  Directive  70/220/EEC  on  the 
approximation of the laws of the Member States relating to measures 
to be taken against air pollution by emissions from motor vehicles and 
Council  Directive  92/97/EEC  of  10 November  1992  amending 
Directive  70/157/EEC  on  the  approximation  of  the  laws  of  the 
Member States relating to the permissible sound level and the exhaust 
system  of  motor  vehicles,  although  vehicles  having  the  same 
characteristics  and  which  are  already  authorised  to  use  the  roads  in 
Austria  are  not  subject  to  that  requirement  in  cases  of  their  re-
registration in that Member State, the Republic of Austria has failed to 
fulfil its obligations under Article 28 EC (now Article 34 TFEU). 

Articles 34 and 36 TFEU preclude legislation of a Member State from 
requiring, for the award of the subsidy known as the ‘bonus écologique 
–  Grenelle  de  l’environnement’  to  imported  demonstration  motor 
vehicles at the time of registration in that Member State, that the first 
registration document of those vehicles bear the words ‘demonstration 
vehicle’. 

Judgment of 11 
December 2008.  

Commission of the 
European 
Communities v 
Republic of 
Austria.  

Case C-524/07 

Judgment of 6 
October 2011.  

Philippe Bonnarde 
v. Agence de 
Services et de 
Paiement. 

Case C-443/10 

EN 

89 

   EN 

 
 
8.3. 

Annex 3: Summary of national rules and practices with respect to motor vehicle 
registration68 

8.3.1.  Belgium 

Registration system 

Motor vehicles are registered by the DIV which is part of the General Directorate for 
Mobility and Road safety within the Federal Public Service (FPS) for Mobility and 
Transport.  

Belgium has a person-based registration system. This means that a person may keep 
the  same  registration  plate  for  life  and  that  he  or  she  may  take  it  from  vehicle  to 
vehicle. When the vehicle is registered, the new holder declares whether or not he or 
she has an available registration plate. If not, a new number is allocated to the person 
and a stamped rear registration plate is delivered. 

The  register  contains  information  on  both  the  vehicle  and  the  holder.  Details  of 
stolen vehicles are not part of the vehicle registration; these are registered separately 
by the Police. The vehicle register keeps a record of the relevant police files, which 
are  consulted  during  transfers.  Personal  details  (name,  address  etc)  are  kept  up-to-
date  through  a  subscription  to  the  National  Register  or  to  the  "Crossroad  bank  of 
enterprises". 

Procedures 

New  vehicles  are  supplied  by  the  importer  to  the  dealer  with  all  technical  data 
printed  on  the  application  form.  The  technical  data  has  previously  been  passed  on 
electronically  to  the  DIV.  In  the  case  of  an  individual  import,  the  importer  must 
obtain a 705 Customs sticker. 

When  a  vehicle  is  first  registered,  the  technical  information  is  printed  on  the 
application form. The dealer also provides a VAT sticker and a stamp confirming the 
technical  data.  The  applicant  completes  the  personal  details,  indicates  whether  he 
wants  a  new  number  and  provides  an  insurance  sticker.  The  applicant  brings  the 
application  form  to  the  DIV.  Registration  certificates  and/or  registration  plates  are 
sent by B-post (postal service). 

The  DIV  has  an  interactive  "on-line"  computer  system  allowing  it  to  issue 
registration  certificates  and  registration  plates  immediately.  In  order  to  speed  the 
process, the DIV has decided to enable online registration on the Internet. Since May 
2002, some insurance and leasing companies are registering their customers’ vehicles 
by means of WebDIV.  

68 

The information in this section is partly an extract of ‘The Vehicle Chain in Europe 2011’ published by 
Ereg, the Association of European Vehicle and Driver Registration authorities, and partly a summary of 
information that was found on various websites in September 2011. The objective of this section is to 
give  a  succinct  overview.  It  does  not  contain  a  detailed  or  exhaustive  description  of  national  motor 
vehicle registration systems. 

EN 

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   EN 

 
                                                 
A  registered  vehicle  must  pass  a  technical control  before  a  new  registration  can  be 
issued.  The  control  results  in  a  test  sticker,  valid  for  two  months,  stuck  onto  the 
application  form.  An  insurance  sticker  is  also  included.  As  part  of  the  registration 
process, the registration number of the previous holder is blacked out. The previous 
holder is expected to remove the plates, because he will need them for his next car. 

Documents 

An application form available at the DIV, car dealers, technical control centres and 
insurance  companies  must  be  completed  by  the  applicant  with  all  the  necessary 
details and stickers. 

The  registration  certificate  and  (if  needed)  the  registration  plate  is/are  delivered  by 
Bpost (postal service).  

The  registration  certificate  new  model  A4,  delivered  since  16  November  is  in  one 
part.  It  is  prepared  centrally  by  the  DIV  and  issued  by  Bpost.  It  includes  details 
concerning  the  vehicle  and  the  applicant.  The  registration  certificate  has  to  be 
presented by the driver at any request and has to be kept with the vehicle till the end 
of its life. 

No  decision  has  been  taken  until  now  about  the  introduction  of  the  smartcard 
registration document. 

8.3.2.  Bulgaria 

Registration system 

In Bulgaria the licensing activities are performed by the Traffic Police. The Traffic 
police are part of the Ministry of Interior and function under the chief directorate for 
Public Order and Security Police. 

Bulgaria  has  a  vehicle-based  licensing  system.  All  vehicles  must  be  presented 
regularly  for 
traffic 
infringements  are  also  checked.  Stickers  are  also  used  to  check  the  insurance  and 
periodical technical inspections ('PTI') obligations. 

insurance  and  outstanding 

inspection  where 

technical 

It is possible to suspend a vehicle in Bulgaria, however vehicle taxes have to be paid. 

Documents and procedures 

The two part vehicle registration certificate is issued by the Traffic police. The first 
part  contains  the  technical  vehicle  data.  The  second  part  contains  the  ownership 
details.  In  case  of  vehicle  modifications  or  re-registration  of  the  vehicle  a  new 
registration certificate is issued. The registration document is issued by the regional 
offices of the Traffic police (formally known as KAT).  

When the registration document is issued, the personal details of the person claiming 
to  be  the  owner  are  included  in  part  two  of  the  registration.  During  the  process  of 
registration  the  Traffic  police  makes  checks  on  the  Schengen  Information  System 
and  with  Interpol  (ASF).  Additionally  checks  are  made  by  examining  the  contract 

EN 

91 

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made between the seller and the buyer to verify that this person is the actual owner. 
For vehicles that are already registered, the contract has to be signed by a notary. 

If  the  certificate  of  conformity  ('COC')  is  missing  or  not  available,  the  customer  is 
sent to a Technical Service like Dekra. There a technical admittance test is performed 
mainly based on permanent PTI requirements. The report is sent to KAT.  

After obligations like insurance, PTI, tax, payment of inspection costs are checked a 
vehicle license plate is issued and directly mounted (in a safe way) to the vehicle by 
a mechanic from the licence plate manufactures. 

8.3.3.  Czech Republic 

Persons who will stay in the Czech Republic for more than one year have to register 
their car there. According to Czech law, one can only register cars that are less than 5 
or 8 years old, depending on the type of the car. 

Prior to the registration of a motor vehicle that was brought into the Czech Republic, 
the vehicle must be inspected by the Technical Inspection Unit (STK). The certificate 
issued by this Unit remains valid for three months for the purpose of registration. 

When importing five or less vehicles of the same type per year, individual inspection 
is required for each vehicle based on the request of the individual importer (usually a 
person).  If  more  than  five  vehicles  are  imported  in  one  year,  the  inspection  of  the 
respective  type  of  vehicle  is  executed  at  the  request  of  the  producer  or  importer 
(usually a legal entity) and no further inspections are necessary for other imports of 
the same type that has been already approved. 

If  the  vehicle  meets  the  requirements  set  out  in  Regulation  No.  102/1995  Coll.,  it 
may then be registered by the Transport Inspectorate of the Czech Police. The basic 
requirements for the registration of a motor vehicle in the Czech Republic include a 
low emission rate (a catalytic converter is not mandatory), the technical specification 
of the vehicle and the vehicle operating manual. 

Various  special  requirements  apply  for  vehicle  registration  in  the  Czech  Republic, 
for example mirrors on both sides of vehicles, a gasoline tank with a lock, a steering 
wheel  on  the  left  side  only,  etc.  The  registration  of  a  vehicle  is  not  valid  until  its 
technical conditions meet all these requirements.  

8.3.4.  Denmark 

The registration of motor vehicles is managed by SKAT, the Danish Tax authority. 

Persons  bringing  a  vehicle  to  Denmark  and  taking  up  residence  in  Denmark,  must 
register  their  motor  vehicles  in  Denmark  within  14  days  of  arrival,  and  pay 
registration tax. Persons residing in Denmark are not allowed to use motor vehicles 
registered  in  another  country,  with  the  exception  of  students  or  persons  residing  in 
another  Member  State  but  working  in  Denmark  if  they  obtain  a  permit  for  using  a 
motor vehicle registered in another country. 

Before  the  vehicle  can  be  registered  in  Denmark,  the  Danish  authorities  require  an 
ordinary  technical  inspection  and  a  customs  inspection  by  the  vehicle  inspection 

EN 

92 

   EN 

 
authority to determine the identity, the number  of  kilometres  on  the  clock,  features 
and general condition of the vehicle. When the vehicle has passed the inspection, the 
applicant  must  visit  the  nearest  tax  centre  and  submit  a  file  containing  the  vehicle 
inspection  form  and  the  customs  inspection  form  issued  by  the  vehicle  inspection 
authority, the registration certificate issued in the Member State of origin, cash to pay 
the registration tax and the registration form (form no. 21.016).  

SKAT  will  then  calculate  the  registration  tax  based  on  the  vehicle's  market  price 
inclusive  of  registration  tax  if  sold  to  a  person  in  Denmark.  This  price  will  be 
compared to the vehicle's original cost and loss in value. The decision concerning the 
valuation of the vehicle is then sent to the applicant (form no. 21.043). 

When the registration tax is paid, the number plate desk at the tax centre will issue 
Danish  number  plates  provided  that  the  following  documents  are  submitted:  the 
vehicle inspection form, the registration certificate issued by the other Member State, 
the  insurance  certificate,  the  decision  concerning  valuation,  the  receipt  for  the 
payment of the registration tax and cash to pay for number plates69. 

8.3.5.  Germany 

Registration system 

In  Germany,  the  federal  16  states  carry  out  the  actual  vehicle  registration.  In 
comparison  with  similar  organisations  in  other  countries,  the  central  German 
registration  organisation,  the  Kraftfahrt-Bundesamt  (KBA),  has  a  relatively  small 
range of tasks. It is the type approval authority for motor vehicles in Germany, and it 
maintains and operates the four federal registers, one of which relates to the vehicle 
chain. There are 420 vehicle licensing offices in Germany. 

The licensing system is vehicle and district based. The 420 licensing offices across 
the  federal  states  are  authorized  to  issue  licence  numbers.  These  offices  maintain 
their own registers of all vehicles for which they have issued licence numbers. The 
KBA  also  records  all  vehicles  with  their  technical  data  and  their  holder  data  in  a 
central vehicle register, called ZFZR (Zentrales Fahrzeugregister). 

Vehicles  (and  their  trailers)  which  on  the  basis  of  their  construction  can  reach  a 
speed of more than 6 kilometres per hour may be used on the public roads if they are 
licensed and registered. These vehicles must have a national approval or an EU type 
approval  and  a  compulsory  third-party  insurance.  Passenger  vehicles,  commercial 
vehicles  and  lorries,  motorcycles,  mopeds,  agricultural  tractors,  road-construction 
and maintenance machines and trailers are licensed and registered. 

Procedures 

When a vehicle is sold, the buyer or dealer has to show the Part II document to the 
licensing office. Additionally the existence of third-party insurance has to be proved. 
This is done electronically by the licensing office who make an online request to a 
database  containing  proof  of  insurance  operated  by  the  association  of  insurance 
companies (see also section 2.4). If all preconditions for registration are fulfilled the 

69 

HTTP://WWW.SKAT.DK  

EN 

93 

   EN 

 
                                                 
license  authority  allocates  a  licence  number  to  the  vehicle.  The  holder  then  has  to 
buy  the  number  plates.  A  supplier  is  usually  located  near  the  licensing  office.  The 
holder  then  takes  the  number  plates  to  the  licensing  office.  In  the  meantime,  the 
holder  and  vehicle  details  have  been  recorded  in  the  district  register.  For  mass-
produced  vehicles,  the  registration  relies  on  a  register  with  type  data  information 
(technical data of a vehicle type). The KBA updates this type data register daily. 

The registration  certificate Part II includes the holder's details. The licensing office 
prepares a registration certificate Part I and attaches a sticker on the number plates. 
The  licensing  office  then  informs  the  KBA,  for  registration  in  the  ZFZR  central 
vehicle register, the tax office and the insurance company. 

Motor vehicles registered in another Member State must be inspected by the TÜV or 
another similar body. The owner then takes the approval declaration to the licensing 
office. This ascertains whether the applicant has the right to have the vehicle, on the 
basis,  for  instance,  of  a  purchase  contract.  The  vehicle  licensing  office  checks,  via 
the KBA, that the vehicle does not already have a registration certificate Part II and 
that it has not been stolen. The vehicle licensing office also consults the EUCARIS 
system  and  the  Schengen  Information  System  (SIS)  via  the  KBA.  If  the  vehicle 
proves  to  be  stolen,  the  vehicle  licensing  office  or  the  KBA  calls  in  the  police  and 
informs  the  applicant  accordingly.  If  everything  is  in  order,  the  licensing  office 
prepares a registration certificate Part II. 

Documents 

The  registration  certificate  consists  of  two  parts:  the  Registration  Certificate  Part  I 
and the Registration Certificate Part II. The first part has the function of the former 
vehicle certificate (in German called “Fahrzeugschein”) and the second part has the 
function  of  the  former  vehicle  letter  (in  German  called  “Fahrzeugbrief”).  The  new 
registration certificates are issued since 1 October 2005. Old documents remain valid 
until a change occurs that makes it necessary to issue new documents.  

In principle in Germany a vehicle is accompanied throughout its life by a registration 
certificate  Part  II  (in  German  it  is  called  “Fahrzeugbrief”),  which  lists  the  holder’s 
and vehicle’s details. The registration certificate Part II provides proof of the holder’s 
right to have the vehicle. The holder keeps the document at home or in a safe-deposit 
box. In contrast to the former vehicle letter the new registration certificate Part II that 
is issued according to Council Directive 1999/37/EC since 1 October 2005 does not 
contain  all  but  only  the  main  technical  vehicle  details  and  at  maximum  two  holder 
entries.  If  no  registration  certificate  Part  II  is  available,  the  holder  must  obtain 
documentary  evidence  of  the  right  to  have  the  vehicle  in  some  way  or  another,  for 
instance by submitting a copy of a purchase contract. 

Registration  certificates  Part  II  are  items  of  value.  Quite  a  number  of  security 
features is incorporated in the registration certificate Part II. They are printed by the 
Bundesdruckerei GmbH in Berlin on security paper and issued with a number, on the 
basis  of  which  the  KBA  monitors  distribution.  The  documents  are  distributed  from 
KBA among manufacturers, importers and licensing offices. 

In most cases the manufacturer or importer allocates a registration certificate Part II 
to a vehicle and prints the vehicle details (including the vehicle identification number 

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(VIN))  on  the  document.  They  report  the  number  of  the  document  as  well  as  the 
vehicle  identification  number  (VIN)  to  the  KBA.  In  this  way  the  vehicle  and  the 
registration certificate Part II are linked to each other at an early stage and stored in 
the ZFZR central vehicle register. 

The  holder  must  present  the  registration  certificate  Part  II  at  the  licensing  office 
when  the  vehicle  is  licensed  and  when  any  details  are  changed.  It  is  impossible  in 
Germany  to  prove  rightful  ownership  of  the  vehicle  without  the  accompanying 
registration  certificate  Part  II.  For  that  reason  this  document  serves  as  a  kind  of 
ownership protection, although it is not an ownership title as such. 

The  holder  can  use  the  registration  certificate  Part  II  as  collateral  for  loans.  In  that 
case the lender will retain the Part II document until the final loan repayment. During 
this time the holder cannot sell the vehicle. 

The registration certificate Part I (in German it is called “Fahrzeugschein”) provides 
proof of correct licensing. This document is issued by the licensing office. It contains 
the  following  in  particular,  the  name  of  the  vehicle  holder,  the  technical  details, 
which (in part) are also listed on the registration certificate Part II and the location of 
the vehicle, in case this differs from the holder’s residence. 

In contrast with the Part II document, the registration certificate Part I must be kept 
in the vehicle when it is being used, so that drivers can present it to the authorities on 
request (at roadside checks, for instance). In case of a change, such as a transfer, the 
licensing office prepares a new registration certificate Part I. 

The  information  on  the  Part  II  document  and  Part  I  document  must  be  kept  up-to-
date. The owner or holder is obliged to report any changes to the licensing office. If 
he or she fails to do so, the licence office has the power to prohibit further use of the 
vehicle until the duty to report has been fulfilled. In the event of changes, the owner 
or  holder  must  always  present  the  registration  certificate  Part  II.  Failure  to  present 
the Part I document is usually not an insurmountable problem. Changes that must be 
reported  to  the  licensing  offices  include  changes  to  holder  details  (e.g.  name  and 
address),  vehicle  category  (e.g.  through  conversion),  engine  power,  loads  and 
weights,  emission  values  and  change  of  location  (in  case  of  a  move  to  another 
district,  a  vehicle  normally  receives  a  new  licence  number).  When  the  vehicle  is 
transferred to another district, it receives a new licence number. 

The licensing office records changes on the registration certificate Part II. If there is 
no place free for new entries a new Part II document is issued. The licensing office 
also  retains  the  old  registration  certificate  Part  I  and  prepares  a  new  one.  And  it 
informs the KBA and, if applicable, the tax office and the insurance company. 

8.3.6.  Estonia 

Maanteeamet  (the Estonian Road Administration) is responsible  for the registration 
of  motor  vehicles,  issuing  vehicle  registration  documents,  number  plates  and 
managing  the  national  road  vehicle  register. It  also  provides  data  on  road  vehicles, 
their legal status and owners as well as other related information. 

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The  licence  system  is  vehicle-based  but  there  are  possibilities  in  certain  cases  to 
retain the number plates and use them on another vehicle. 

Passenger  cars,  motorcycles,  commercial  vehicles, 
tractors,  mobile 
machinery and all terrain vehicles are registered. Registering a moped is compulsory 
since 2011. 

trailers, 

Before  the  registration  process  can  start,  the  vehicle  must  pass  the  pre-registration 
inspection. The vehicle documentation as well as the vehicle’s compliance with the 
national  technical  requirements  are  verified.  After  the  inspection,  the  owner  of  the 
vehicle or holder presents an application and a document certifying the acquisition of 
the vehicle, in the absence of this any other document certifying the ownership of the 
vehicle,  the  registration  certificate  (in  case  of  an  used  vehicle),  the  certificate  of 
conformity (in case of a new vehicle) and other documents when needed. 

After  registration,  the  registration  certificate  and  number  plate(s)  are  issued 
immediately  to  the  applicant.  The  owner  must  insure  the  vehicle  for  use  on  public 
roads and a technical inspection must be passed. 

Owners of vehicles must apply for the change of registration data in case of transfer 
of ownership, change of recorded data of an owner (name, address), data of a vehicle 
(colour, engine, etc) or in case of loss or theft of the registration certificates. 

8.3.7. 

Ireland 

Registration system 

The Revenue Commissioners are the registration authority in Ireland. They register 
vehicles,  collect  Vehicle  Registration  Tax  (VRT)  and  assign  registration  numbers. 
The  Department  of  Transport  issues  registration  certificates  for  vehicles  and  are 
responsible for the collection of Circulation Tax on behalf of the Department of the 
Environment,  Heritage  and  Local  Government  through  online  services  and  local 
authorities. 

The licensing system in Ireland is vehicle-based. 

Procedures 

Authorized distributors deliver new vehicles to dealers. The dealer is provided with a 
partially  completed  registration  declaration  document  on  which  relevant  vehicle 
details (partly taken from the type approval details) are already entered. 

When  the  vehicle  is  sold,  the  dealer  amends  the  document  with  the  new  holder’s 
details.  The  dealer  then  electronically  (in  about  95%  of  registrations)  declares  the 
transaction  to  Revenue  and  arranges  payment  of  the  VRT  due,  usually  via  their 
current account. The dealer will be informed of the registration number allocated to 
the  vehicle  and  will  supply  the  vehicle  to  the  customer  with  the  registration  plate 
attached. 

Private  importations  or  registrations  of  used  vehicles  must  be  completed  at  a 
National Car Testing Centre. The new keeper (registered owner) of the vehicle must 
pay the first Circulation Tax either directly online or at a local authority Motor Tax 

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Office.  Transport  department  will  post  the  registration  document  to  them  after 
payment. 

Transfers of ownership and other changes to the holder details are indicated on the 
Registration Certificate. The old and the new holder sign the document, which is sent 
to the responsible department where the changes are registered. A new Registration 
Certificate  is  then  produced  and  sent  to  the  new  holder.  Details  of  motor  dealers 
involved in holder changes are also recorded in the central register and motor dealers 
become  the  registered  owners  of  the  vehicles  while  in  their  possession,  however  a 
new Registration Certificate is not issued in these circumstances. 

An internet based facility which allows approved motor dealers to notify changes in 
ownership for vehicles purchased and sold by them was introduced in May 2008 and 
provides an additional channel to notify changes. Where dealers use this service they 
are required to retain the signed documents for a period of three years. Modifications 
to the vehicle, particularly those that may impact on the registration tax or the annual 
motor tax must be notified to the relevant authorities, whether Revenue or Transport. 
In some cases, where the change is significant and may compromise the vehicle type 
approval,  it  is  planned  that  a  certification  process,  whether  individual  vehicle 
approval  or  a  more  simple  certification  process  be  put  in  place  to  ensure  that  the 
vehicle modification has not compromised the safety of the vehicle. 

Documents 

The  main  document  in  the  system  is  the  Registration  Certificate,  which  contains 
details  of  the  vehicle  and  the  registered  owner.  It  is  issued  by  Transport  after 
registration  of  the  vehicle  by  Revenue  and  payment  of  the  first  annual  Circulation 
Tax.  This  document  was  introduced  in  2004  to  replace  two  documents  previously 
issued  for  each  vehicle,  the  Vehicle  Registration  Certificate  and  the  Vehicle 
Licensing Certificate. 

The new document was introduced to improve customer service and to comply with 
Council Directives 1999/37/EC and 2003/127/EC. The document does not need to be 
present in the vehicle when it is on the road.  

In the case of individual importation of vehicles, all original documents are returned 
to the country of origin via the appropriate embassy or vehicle licensing authority. 

8.3.8.  Greece 

EU  citizens  may  circulate  in  Greece  in  their  EU  state  registered  car  during  six 
months. After six months the car must leave the country or be registered in Greece. 
The  car  registration  document  is  always  required.  Travellers  should  at  all  times  be 
able to prove to the authorities when the car was brought into Greece. 

To  qualify  for  a  second  period  of  tax  free  circulation:  either  both  the  car  and  the 
owner should be out of Greece for at least 185 days or while the owner is away, the 
vehicle can remain at a special Customs compound in Greece for the period stated. 
Greek  circulation  tax  is  payable  for  all  additional  periods  of  circulation.  The 
entitlement  to  circulate  on  foreign  plates  is  strictly  personal,  consequently  only  the 
wife/husband or children may use the car in addition to the owner. After the expiry 

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of  the  period  granted  by  the  customs  authorities,  the  person  concerned  will  be 
required to re-export the car, or to seal it with the customs for a period of at least 6 
months (but no more than 12 months) after which time, provided the owner can show 
that he/she has been out of Greece for at least 6 months during this time, another 6 
month circulation period will be granted, or clear it through customs. 

In  general,  the  car  dealer  who  sells  a  new  car  will  register  it  temporarily  for  the 
buyer.  If  not,  the  dealer  will  supply  the  buyer  with  the  appropriate  documents 
required for registration.  

New  cars  are  registered  at  the  local  Citizen  Service  Centre  (Κεντρο  Εξυπηρετησης 
Πολιτων  -  KEP).  The  buyer  submits  the  necessary  documents  to  the  KEP  and  the 
application  is  forwarded  to  the  competent  institution.  A  receipt,  the  Βεβαιωση 
υποβολης  αιτηματος,  is  issued.  The  buyer  is  notified  when  the  final  document  is 
ready to be collected. 

The  following  documents  are  required  to  register  a  private  passenger  vehicle: 
certified copy of proof of identity, the residence permit for foreign residents (Aδεια 
παραμονης), a document from the manufacturer, the application for registration of a 
new passenger car, a copy of certificate in accordance with the JMD 31949/2725/99 
(V330) issued by the Department of Transport and the EU certificate of conformity. 

For motor vehicles that are already registered, the following documents are required 
for the transfer of ownership and registration: a certified copy of proof of identity of 
both the buyer and seller, a receipt of payment by the seller (an invoice marked paid), 
a  request  for  transfer  and  registration  of  the  car  ownership  (document  Aitisi),  the 
previous vehicle registration document, certified by the local tax office proving that 
the annual vehicle tax was paid, a power of attorney, if registration is carried out by a 
third  party  and  the  residence  permit  for  foreign  citizens  (Aδεια  παραμονης).  The 
documents  have  to  be  submitted  to  the  local  Citizen  Service  Centre  (Κεντρο 
Εξυπηρετησης Πολιτων - KEP). The buyer will be notified once the documents are 
ready  for  collection.  Car  insurance  should  be  taken  out  before  registration  of  the 
vehicle.  Vehicles  entering  Greece  are  also  required  to  undergo  a  test  at  a  Vehicle 
Technical Control Centre (KTEO). 

8.3.9. 

Spain 

Registration system 

The  registration  of  motor  vehicles  is  managed  by  the  DGT  (Dirección  General  de 
Tráfico). 

Spain  has  a  vehicle-based  licensing  system.  Cars,  buses,  motorcycles,  trailers 
weighing  more  than  750  kg,  lorries  and  mopeds  are  all  registered  and  bear  licence 
plates. Agricultural tractors are registered as special vehicles. 

Procedures  

The regular importation of new vehicles is carried out in an automated way through 
certified importers and manufacturers. 

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Vehicles  imported  by  individuals  and  homemade  vehicles  must  be  registered  at  a 
provincial  office  after  the  vehicle  has  been  taken  to  an  ITV  station  for  at  least  an 
identity check. Requisite documents include the certificate of conformity, certificates 
to prove that the municipal tax and the registration tax have been paid, and proof of 
identity. A proof of insurance is not required. The application form can be filled in 
on location or on the internet. The vehicle document can be picked up the next day, 
after which the licence plates can be purchased. 

The procedure for transfers of ownership is the same as for individual importation, 
with the understanding that instead of the COP the valid vehicle document must be 
produced. In principle, both the buyer and the vendor must register the transfer, but 
given the elaborate administrative procedure people often call in a service company 
and authorise it to register the transfer. 

Documents 

The  European  harmonised  vehicle  document  was  introduced  in  2005  as  a  one-part 
document. No new additions are made to the document – that is, a new document is 
issued if any changes have to be made. Drivers need to have the document on them 
when they are on the road. A smartcard registration document is being prepared. 

8.3.10.  France 

Registration system 

France  adopted  a  new,  nationwide  vehicle  registration  system  in  2009.  This  is  the 
‘Système  d'Immatriculation  des  Véhicules’  (SIV).  The  registration  is  done  at  the 
Préfecture or Sous-Préfecture.  

France  has  a  vehicle-based  licensing  system  (‘un  numéro  à  vie’).  The  vehicle  is 
issued with a registration number at the first point of registration. This remains with 
the  car  until  it  is  destroyed  or  exported,  regardless  of  its  location  of  registration  in 
France. An owner need not change the registration of a vehicle bought in a different 
‘département’.  An  owner  need  not  change 
they  move 
‘département’,  although  they  are  required  to  report  a  change  of  address.  A  sticker 
will be sent by post which must be placed in the registration document (there is no 
charge)  

the  registration 

if 

It is not obligatory to register a foreign vehicle in France unless the owner is resident 
in  France.  A  resident  is  someone  who  is  domiciled  in  France  for  more  than  six 
months (183 days) per year, or who is employed in France. 

A private vehicle must be re-registered in France if it is owned and used by a resident 
of France. 

Procedures 

For the registration of motor vehicles previously registered in another Member State, 
the vehicle's original registration documents and receipt of sale should be transmitted 
to  the  Centre  des  Impots  where  a  fiscal  certificate  (Quitus  Fiscal)  or  tax  clearance 
form will be issued.  

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The motor registration department at the Préfecture or Sous-Préfecture will start the 
registration process on the basis of a ‘Demande de certificat d'immatriculation d'un 
véhicule’.  The  applicant  will  have  to  provide  the  registration  department  with  the 
following documents: 

– 

– 

– 

– 

– 

– 

Proof of identity;  

Proof  of  residence/address  (property  title  deeds,  rental  contract,  utility  bill, 
insurance certificate); 

A copy of the foreign registration certificate; 

Copy of the Certificat de Conformité Europeen (issued by the manufacturer or 
their agent) or an Attestation RTI (Reception à Titre Isolé). There are two ways 
to identify that the car is of a recognised type in France or in the EU. Either by 
the identification number given by the manufacturer for cars produced in series 
(Certificate de Conformité Europeen) or with a ‘Attestation RTI’ (Reception à 
Titre  Isolé)  from  DREAL  (Directions  Régionales  de  l’Environnement,  de 
l’Aménagement et du Logement); 

A copy of the certificate of purchase and customs clearance certificate (issued 
by the Centre des Impots);  

Côntrole technique certificate if required: if the car is more than four years old 
it will need to pass a ‘côntrole technique’, the French roadworthiness test; this 
must have occurred less than six months before (two months if a contre-visite 
or  re-test  is  required).  Roadworthiness  certificates  from  other  countries  are 
usually  not  accepted  as  an  alternative  -  the  car  must  pass  a  French  ‘côntrole 
technique’. 

The  Préfecture  or  Sous-Préfecture  will  detail  where  the  documents  should  be  sent. 
The  DREAL  (Directions  Régionales  de  l’Environnement,  de  l’Aménagement  et  du 
Logement) might ask for additional documents. 

The  car  owner  is  notified  when  they  should  return  to  the  Préfecture  or  Sous-
Préfecture, where the registration document, and new registration number are issued. 
Next,  new  number  plates  (plaques  d'immatriculation)  must  be  ordered,  made  and 
fitted. 

8.3.11.  Italy 

Registration system 

In Italy, the licensing activities are performed by two organisations, the Ministry of 
Transport  and  Infrastructure  (‘DG  V&T’)  and  the  Automobile  Club  Italy  (‘ACI’). 
These  organisations  are  statutorily  appointed  to  carry  out  the  various  tasks.  The 
ACI’s  tasks  focus  primarily  on  the  ownership  aspects  of  licensing  and  providing 
related legal information. The DG V&T carries out, inter alia, the licensing of data 
relating to vehicles and supplies information for tracing and enforcement. 

DG  V&T  and  ACI  regularly  exchange  their  respective  files  in  an  attempt  to  avoid 
discrepancies in the database. The Italian system is based on continuous registration. 

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Vehicles are included, without interruption, in the registers of the DG V&T and ACI 
from  first  registration  until  they  are  scrapped.  At  the  end  of  the  vehicle’s  life  (i.e. 
when  it  is  scrapped)  or  on  export,  the  history  is  checked.  Any  gaps  must  then  be 
accounted for. 

The registration number is specific to the vehicle. 

Documents 

There are two official vehicle documents. The registration document is issued by DG 
V&T.  This  must  be  present  in  the  vehicle  whenever  it  is  used.  The  ownership 
document is issued after ratification of ownership and may be kept at home. In both 
cases,  modifications  to  the  document  are  made  using  stickers  that  must  be  pasted 
over the details that have changed. 

From  2002  both  the  documents  (the  registration  document  and  the  ownership 
certificate, the so-called “certificate di proprietà”) are issued in real time by ACI or 
DG V&T. 

Upon initial registration, the registration document is issued by the provincial offices 
of the DG V&T. The document primarily contains data relating to the vehicle. When 
the registration document is issued, the personal details of the person claiming to be 
the owner are included in addition to the technical data. No check is made by the DG 
V&T  as  to  whether  this  person  is  the  actual  owner  (a  photocopy  of  a  registration 
document is sufficient). The registration form has recently been modified in line with 
the EU requirements that came into effect from 2004.  

Upon  receipt  of  the  number  plates,  the  applicant  must  inform  the  ACI  about  his 
ownership with a declaration ratified by a notary or by an official. The ACI processes 
this in the PRA (Public Register Automotive) and checks who the actual owner is.  

Vehicles  that  do  not  have  a  certificate  of  conformity  or  which  enter  via  parallel 
import  (about  5%)  have  to  be  submitted  to  one  of  the  90  provincial  inspection 
centres. 

Procedures 

Transfer of ownership can be processed via agencies or directly by ACI or DG V&T. 
Changes  in  vehicle  ownership  have  to  be  accomplished  by  means  of  a  contract 
legalised by a notary or an official.  

Changes  of  address  are  notified  by  the  municipal  authorities  to  the  DG  V&T.  The 
DG V&T send the information to ACI. 

Vehicle  owners  notify  any  technical  changes,  insofar  as  these  affect  items  on  the 
registration document, at one of the provincial offices of the DG V&T. Depending on 
the  nature  of  the  modification,  the  vehicle  may  then  be  inspected  at  one  of  the 
inspection  centres.  The  owner  subsequently  receives  a  special  sticker  showing  the 
updated details. This is pasted over the old details. 

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8.3.12.  Cyprus 

Right  hand  drive,  used  vehicles,  with  first  registration  or  purchase  in  a  European 
Union Member State 

The applicant must submit the following documents to the registration authorities: 

– 

– 

Registration certificate (indicating that the vehicle’s first registration was in an 
EU Member State) 

Invoice or sales contract, if the vehicle is not registered to the person importing 
and  registering  the  vehicle  (from  now  on  referred  to  as  the  “owner”  of  the 
vehicle) 

If  the  above  documents  are  in  a  language  other  than  Greek  or  English,  the  owner 
must  produce  verified  translated  documents  issued  by  the  Press  and  Information 
Office. The documents must be properly stamped at the Stamp Duty Section of the 
Ministry of Finance. 

The  owner  must  submit  all  above  documents  to  the  District  Vehicle  Examination 
Centre  of  the  Road  Transport  Department  (R.T.D.) to have a certificate confirming 
the  vehicle’s  CO2  emissions,  issued.  The  owner  should  then  acquire  the  vehicle 
according to the procedure of the Department of Customs. 

The owner must then apply for a roadworthiness certificate by presenting the vehicle 
to  an  authorized  Private  Vehicle  Examination  Centre  (accompanied  with  Customs 
documents and other required documents as described in paragraphs A1-A2 above) 
for  inspection.  Provided  that  all  paperwork  is  correct  and  the  vehicle  is  in  proper 
working condition, a roadworthiness certificate will be issued. The owner must then 
present the vehicle to a District Vehicle Examination Centre of R.T.D. (accompanied 
with all above documentation) for inspection for registration. 

Upon  successful  completion  of these  procedures,  the  owner  will  have  to  submit  all 
the  above  documents  to  one  of  the  Motor  Car  Registry  offices  of  R.T.D.  for 
registration of the vehicle. 

Left hand drive vehicles 

Left hand drive, saloon type vehicles, can be registered in Cyprus, provided that: 

– 

– 

– 

The procedure above is followed, 

the  vehicle  is  submitted  to  a  test  for  single  vehicle  left  hand  drive  vehicles, 
undergoes any necessary modifications and certificate TOM 139(β) is issued; 

the  vehicle  is  accompanied  by  any  of  the  following  documents:  an  approved 
SVA certificate, a registration certificate from an EU member state indicating 
proof  of  EU  type  approval,  or  the  Certificate  of  Conformity  from  an  EU 
Member State. 

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8.3.13.  Latvia 

Registration system 

The registration is done by the CSDD (Road Traffic Safety Directorate). 

Latvia has a vehicle-based licensing system. All vehicles must be presented annually 
for technical inspection. In this way, registrations are kept up to date and obligations 
with regard to inspection, insurance and taxation are enforced.  

Cars, lorries, buses, motorcycles and all trailers are registered and bear licence plates. 

Transfers  of  ownership  are  dealt  with  at  the  CSDD  offices.  CSDD  registers  about 
750 transfers of ownership per day. There are two ways transfer of ownership can be 
performed: 

• 

• 

Based on an ownership document (purchase agreement, grant agreement etc.) 
In this case, the presence of the vendor is not necessary; 

Based on an ownership’s transfer application, which is executed at the CSDD 
office and signed both by buyer and vendor. 

All  vehicles  are  inspected  individually.  Documents  and  licence  plates  are  issued 
immediately after the inspection. 

Documents 

The  registration  document  is  a  tamper-proof  certificate.  This  is  generated  based  on 
the  vehicle  register.  People  are  required  to  have  this  document  with  them  when 
driving a vehicle.  

8.3.14.  Lithuania 

Registration system 

Motor vehicles are registered by the public enterprise REGITRA. It was established 
by the Ministry of the Interior and within the framework of the Law of the Republic 
of  Lithuania  "On  State  and  Municipal  Enterprises"  is  subordinate  to  the  Ministry. 
REGITRA registers passenger cars, buses, coaches, lorries, their trailers (irrespective 
of  their  weight),  motorcycles  and  mopeds.  Administrations  of  municipalities  carry 
out  registration  of  tractors,  self-propelled  and  agricultural  machinery  and  their 
trailers, they issue registration certificates and number plates.  

Lithuania  has  a  separate  Register  of  Tractors,  Self-Propelled  and  Agricultural 
Machinery and their Trailers (‘Register of Tractors’). It is different from the Register 
of Road Vehicles which falls under the responsibility of the Ministry of Agriculture. 
The  state  enterprise  Agricultural  Information  and  Rural  Business  Centre  is  the 
institution  responsible  for  the  administration  of  the  information  system  of  the 
Register of Tractors. 

Procedures 

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There  are  four  main  types  of  vehicle  registration  procedures  in  Lithuania:  the  first 
registration, temporary registration, change of registration data and deregistration. 

The  vehicle  identification  inspection  is  a  compulsory  initial  stage  of  procedures  of 
the first registration and change of vehicle data. Personal ID and vehicle documents 
are  checked  in  the  course  of  all  types  of  registration  procedures.  Registration 
documents and licence plates in all cases are issued on the spot at the final stage of 
the registration procedures. 

The following documents must be submitted for the first registration: an application, 
a personal identification document of an applicant, a document certifying the right to 
represent  an  owner  (power  of  attorney,  proxy,  etc.)  where  an  applicant  is  not  the 
owner, an acquisition document (invoice, purchase agreement, etc), a foreign vehicle 
registration  certificate  (where  appropriate),  a  contract  of  compulsory  insurance 
against civil liability in respect of the use of motor vehicles (Motor Insurance) and a 
certificate of conformity (where appropriate). 

There is a possibility for dealers to register new vehicles for their customers. In this 
case a representative of the retailer should also submit the purchase agreement where 
an authorization to register the vehicle on behalf of the owner is indicated. 

Owners  of  vehicles  must  apply  for  the  change  of  registration  data  in  the  following 
cases:  upon  transfer  of  ownership,  change  of  recorded  data  of  an  owner  (name, 
address), data of a vehicle (colour, engine, etc) and the validity period of temporary 
registration,  when  there  is  a  need  to  change  number  plates  and/or  the  registration 
certificate (badly damaged, stolen or lost). The application has to be submitted within 
30 days or immediately if a certificate or number plates are stolen or lost. 

Documents 

Currently there are 5 models of valid Lithuanian registration certificates in use: 

– 

– 

– 

– 

– 

The 1992 model, issued 01/10/1992 – 31/01/2001. It is currently quite rare in 
traffic.  The  issued  certificates  were  folded  in  the  middle,  sealed  in  protective 
film and they have a shape of a plastic card; 

The 2001 model (green), issued 01/02/2001 - 27/04/2004 ;  

The 2004 model (green), issued 27/04/2004 - 24/07/2006;  

The 2006 model (green), issued from 17/07/2006; 

The 2010 model (green), issued from 06/01/2010. 

The above documents are intended, inter alia, for the re-registration of vehicles. 

There  are  also  2  models  of  another  type  of  documents  -  vehicle  user  certificates 
(blue). Those documents were intended for the vehicle users other than owners, were 
not  compulsory,  issued  alongside  registration  certificates  upon  request  of  an  owner 
and valid for 5 years. It should be noted that the user certificates do not confirm the 
holder’s  proprietary  right  to  the  vehicle  and  therefore  are  not  intended  for  the  re-
registration.  The  user  certificates  are  no  longer  issued  since  07/2006  as  the  data  of 

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vehicle  users  can  be  (on  application  of  an  owner  or  his  legitimate  representative) 
indicated on the reverse side of the newest Registration Certificate. The data of the 
vehicle  user/holder  of  the  certificate  are  provided  in  conformity  with  Directive 
1999/37/EC  under  the  codes  (C.1.1)  surname  or  business  name;  (C.1.2)  other 
name(s) or initial(s); (C.1.3) address in the Member State of registration on the date 
of  issue  of  the  document  and  (C.4.b)  is  not  the  vehicle  owner.  All  the  documents 
consist of one part only. 

8.3.15.  Luxembourg 

Registration system 

The  SNCH,  the  ‘Société  Nationale  de  Certification  et  d’Homologation’  is  the 
managing the car registration in Luxembourg. 

Luxembourg has a vehicle-based licensing system. Cars, motorcycles, lorries, trailers 
(regardless of weight) and mopeds are registered and bear licence plates.  

Procedures 

Registration takes place at one of the three SNCT stations and is preceded by either a 
technical  inspection  or  a  conformity  inspection  involving  the  physical  check  of  the 
identity of the vehicle (stamped VIN Number). For vehicles coming from countries 
that are EUCARIS participants, every vehicle is checked via EUCARIS. As soon as 
the  inspection  has  been  successfully  completed,  and  payment  has  been  made,  the 
new documents are issued. 

In addition to the completed registration form, one must submit a proof of purchase, 
proof of insurance and proof of identity. The previous owner/keeper has to hand in 
both parts of the old registration document.  

The  procedure  to  be  followed  for  the  change  of  ownership  of  a  vehicle  is  quite 
similar  to  that  described  for  a  new  vehicle.  On  1  August  2004,  the  technical 
inspection  of  a  vehicle  in  case  of  change  of  ownership  was  made  voluntary,  if  the 
previous inspection certificate remains valid for at least 6 weeks. 

In case of technical modifications on a vehicle, the relating administrative procedure 
is  also  done  in  the  premises  of  our  three  SNCT  inspection  centres,  where  the 
identification  of  the  vehicles  can  be  done  as  well  as  the  eventual  check  of  the 
technical modifications (colour, fuel...). 

Documents 

Since  December  2006,  Luxembourg  has  a  two-part  registration  document,  of  grey 
and  yellow  colour  (before  only  one  part  document  in  grey  colour),  containing 
information both on the vehicle as well as on the owner and the keeper (holder). The 
document  does  not  constitute  a  historical  record.  If  any  changes  occur,  a  new 
document is made out. The registration document has to be in the car when it is being 
driven. 

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8.3.16.  Hungary 

Registration system 

The  COAEPS  (Central  Office  for  Administrative  and  Electronic  Public  Services  – 
Vehicle  and  Driving  Licence  Administration  and  Registration  Department)  is 
responsible  for  the  central  registration  and  therefore  has  a  role  in  the  licensing  and 
during tracing and enforcement. 

The licensing system and the tax system are not integrated. The local tax authorities 
get a monthly update database on the basis of the changed data registered by the local 
authorities.  The  licensing  system  is  linked  with  the  central  personal  database,  with 
the vehicle originality inspection system and with the Customs. 

Procedures 

The licensing system is vehicle-based, though it is possible in some cases to keep the 
number  plates  and  use  them  on  another  vehicle.  The  Hungarian  vehicle  register 
includes data both on the holder and on the owner. 

Passenger cars, buses, coaches, lorries, trailers, motorcycles and agricultural vehicles 
have to be registered. The vehicles appear in the Vehicle Registration from the first 
registration until 10 years after the de-registration. 

The  registration  takes  place  in  the  document  service  centres.  There  are  over  300 
document service centres in Hungary which are part of the local government office. 
COAEPS  is  their  professional  supervisor,  gives  professional  support  and  regularly 
controls their work. 

There are some differences in the procedures and the required documents for the first 
registration of a vehicle, depending on the origin of the vehicle (EEA, third country, 
new). As the vehicle is registered, the data appears immediately in the central register 
system so all document service centres can check the new records at once. Some of 
the required documents must be attached to the application and these will be sent by 
the document service centre to the central file department of COAEPS. 

For the first registration of the vehicle the applicant must transmit the following: 

– 

– 

– 

– 

The Technical Data Sheet which is a certification of the technical eligibility of 
the vehicle by the transport authority; 

Payment  receipt  of  the  fee  for  the  registration  certificate  and  the  ownership 
booklet; 

Certification  of  ownership  by  an  original  document  or  by  a  copy  which  has 
been officially authenticated as identical with the original document, or if the 
original document has not been issued in the Hungarian language, an officially 
authenticated Hungarian translation is to be attached to the request as well; 

The payment receipt for the fee of the number plates and the payment receipt 
for the fee of the license plate validity sticker. 

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– 

– 

– 

– 

– 

– 

– 

In addition, the following documents must be presented: 

A  special  national  document  called  „járműkísérő  lap”  that  is  issued  for  the 
trader when the vehicle is sold; 

If there is no „járműkísérő lap”, the originality inspection should be completed 
within 60 days;  

Proof of the payment of the third-party liability insurance;  

Certification  of  the  payment  of  the  registration  tax  in  case  of  vehicles 
determined by law and the verification of the originality of this certification has 
been checked by the road traffic authority in the register; 

Certification of the payment of property acquisition tax if the acquisition and 
the possession took place in the territory of Hungary;  

The client’s identification has to be verified by a document. 

Any  changes  considering  data  in  the  Vehicle  Registration  and/or  the  documents  to 
both  the  vehicle’s  and  the  keeper’s  details  must  be  registered  by  the  document 
service centres. 

Documents 

The registration certificate of Hungary consists of only one part. Although Hungary 
has  used  the  harmonised  EU  vehicle  Registration  Certificate  since  1st  July  2004, 
there are still other valid types of Registration Certificates in Hungary: 

• 

• 

• 

Type “A” Registration Certificate was issued until 31/12/1998. The Document 
was  made  of  green  card,  it  was  filled  in  by  hand  and  was  split  into  two.  The 
number of these Registration Certificates are steadily decreasing as they must 
be  exchanged  to  the  type  “C”  Registration  Certificate  whenever  the  holder 
starts a procedure in the document service centre. 

issued  from  01/01/1999  until 
Type  “B”  Registration  Certificate  was 
30/06/2004.  This  document  looks  similar  to  the  type  “C”  Registration 
Certificate though it contains the data descriptions in Hungarian and not with 
EU  codes  and  the  print  is  different.  These  documents  will  have  to  be 
exchanged to the type “C” when data of the vehicle or the holder has changed.  

Type  “C”  Registration  Certificate  has  been  issued  since  1st  July  2004 
following Directive 1999/37/EC. This document is green and folded into three. 
On  the  front  side  there  are  the  data  of  the  vehicle  (with  codes)  and  name, 
address and legal status (holder, owner, lessee etc.) of the holder. On the back 
there are the stickers of the technical inspection, date, signature and stamp of 
the issuing authority and space for possible authorised remarks. 

The  Registration  Certificate  is  to  be  held  in  the  vehicle  while  using  it  on  public 
roads. 

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In  Hungary  it  is  not  necessary  that  the  holder  and  the  owner  should  be  the  same 
person. If the owner and the holder of the vehicle are different persons they are both 
registered  in  the  Vehicle  Registration.  As  proof  of  ownership,  a  green  plastic  card 
(size  of  a  credit  card)  is  issued  by  the  document  service  centre.  This  card,  called 
“ownership  booklet”  has  a  very  important  role  in  the  Hungarian  registration 
procedure but  is not  Part II of the Registration Certificate in the sense of Directive 
1999/37/EC. The ownership booklet is withdrawn and  re-issued  at every change of 
owner and in some other cases. 

The  vehicle  originality  inspection  is  a  compulsory  check  of  the  vehicle  documents 
and  the  vehicle  originality  data  thus  avoiding  forgery.  It  must  be  processed  before 
registering a new owner. 

8.3.17.  Malta 

Registration system 

The registration process is managed by the Malta Transport Authority. 

Procedures 

For  new  motor  vehicles,  the  dealer  must  login  to  the  Online  Registration  system 
www.vehicleregistration.gov.mt to register and license the vehicle accordingly. After 
registering the vehicle he will be requested to present the documents listed below, at 
the Land Transport Directorate in Hall C between 7.30 and 12.00, Monday to Friday, 
except Public Holidays. 

In the case of New Private (M1) Vehicles, Chauffer Driven and Taxis, the following 
documents must be presented: 

– 

– 

– 

– 

– 

– 

– 

– 

Deposit Form VEH 03; 

Duly  filled  Application  Forms,  VEH  01  and  VEH  02  for  one  time  importers 
and  VEH  25  for  authorized  motor  car  dealers,  downloaded  from  website 
WWW.TRANSPORT.GOV.MT;  

New vehicles must comply with Directive 2007/46/EC, i.e.: Only vehicles with 
an engine complying to emission level standards of EURO 5 or higher may be 
registered; 

The  original  Certificate  of  Conformity  (Item  46.1  on  the  Certificate  of 
Conformity  must  read  715/2007/EEC/692/2008.  Only  vehicles  having  such 
description may be registered); 

The invoice;  

The freight note and Marine Insurance (if applicable); 

A valid insurance policy;  

Copy of ID card of purchaser (front only);  

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– 

– 

Customs  Inspection  Form  VEH  04  for  vehicles  coming  from  Non-EU 
countries;  

Board resolution if the vehicle will be licensed on behalf of an Organisation 

In  the  case  of  new  Goods  Carrying  Vehicles  (N1,  N2,  and  N3),  besides  the  above 
documents, the agent/dealer must also present a declaration for: 

– 

– 

– 

– 

– 

N1  vehicles  (Class  1)  with  Reference  Mass  between  0  and  1,305kg  require  a 
declaration by the manufacturer confirming that the vehicle complies with the 
emission  level  standards  established  under  Regulation  (EC)  No  715/2007  as 
amended (Euro 5/V); 

N1 vehicles (Class 2) with Reference Mass between 1,306kg and 1,760kg and 
N1  (Class  3)  with  Reference  Mass  between  1,761  and  2,610kg  require  a 
declaration by the manufacturer confirming that the vehicle complies with the 
emission level standards established  under  Directive 70/220/EEC  (Euro  4/IV) 
or higher;  

N2  and  N3  vehicles  with  a  maximum  authorised  Mass  over  3,500kg  having 
heavy duty engines require a declaration by the manufacturer confirming that 
the  vehicle  complies  with  the  emission  level  standards  established  under 
Directive 2005/55/EC, (Euro 5/V); 

Engineer’s report (in the case of chassis cab); 

Certificate  from  the  Public  Health  Authority  (in  the  case  of  refrigerated 
vehicle). 

All  new  N1  vehicles  manufactured  after  29  October  2011,  are  required  to  have  a 
Certificate of Conformity and all N2 and N3 vehicles manufactured after 29 October 
2012  will  also  be  required  to  have  a  Certificate  of  Conformity.  In  the  case  of  new 
Motorcycles  and  M1  vehicles  the  same  documents  as  for  Private  vehicles  are 
required. 

Prior to registration, all M1 vehicles will be inspected by Technical Unit to confirm 
if the vehicle may be used on the road. 

The  invoice  must  be  issued  by  the  manufacturer  or  by  an  authorized  agent  of  the 
manufacturer showing the cost of the vehicle and in the case of a goods vehicle or an 
off  road  vehicle  the  engine  capacity  and  gross  vehicle  weight,  and  the  other 
documents  showing  the  CIF  (Cost,  Insurance  and  Freight)  value.  (Motor  Vehicles 
Registration and Licensing Act, Cap 36, Article (d)). 

Used  vehicles  transferred  from  other  EU  countries  must  be  inspected  and  verified. 
Persons  bringing  a  used  vehicle  from  an  EU  Member  State  have  to  make  an 
appointment for the Inspection and Verification of the vehicle. 

On the appointed day, the client has to take the vehicle to the Technical Unit of the 
Land  Transport  Directorate  in  Floriana.  The  following  is  the  list  of  documents 
required for Inspection and Verification of the vehicle: 

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– 

– 

– 

Foreign Registration Certificate (Logbook) of vehicle signed by foreign Seller 
and the new Buyer; 

A print out from the Transport Malta website with Vehicle Registration Value 
WWW.VEHICLEREGISTRATION.GOV.MT; 

For Goods vehicles and ATV’s the car dealer or individual must submit a duly 
filled Application Form VEH 01. 

On the appointed day, the Technical Unit will verify that the details on the logbook 
tally with the valuation printout and with the actual vehicle.  

The  valuation  printout  will  be  signed  and  stamped  by  the  Technical  Unit,  and 
returned to the customer to be used during registration. 

After that the vehicle is inspected and verified by the Technical Unit, the client may 
register  the  vehicle  at  Hall  B  at  the  Land  Transport  Directorate  between  7.30  and 
12.00. 

In  the  case  of  Used  Private  (M1)  Vehicles  the  following  documents  must  be 
presented: 

– 

– 

– 

– 

– 

– 

– 

– 

– 

Deposit form VEH 03; 

Duly filled Application Forms, VEH 01 and VEH 02 for individuals and VEH 
25 
website 
car 
WWW.TRANSPORT.GOV.MT;  

downloaded 

dealers, 

motor 

from 

for 

Valuation printout signed by Technical Unit;  

Original  Foreign  Registration  Certificate  (logbook)  signed  by  the  foreign 
owner and the new buyer;  

For  vehicles  brought  into  Malta  as  of  the  1  April  2011,  or  thereafter  an 
Odometer  Certificate  of  Authenticity  issued  by  a  body  approved  by  the 
Authority (JEVIC) showing the vehicle’s authentic odometer reading. Details: 
JEVIC  UK  LTD,  Building  46,  Dunsfold  Park,  Cranleigh,  Surrey,  GU6  8TB, 
United Kingdom;  

Foreign Plates;  

Valid  insurance  policy  certificate,  starting  from  date  of  registration  (however 
owner must have the vehicle insured whilst the vehicle is used in Malta);  

VRT passed certificate (should be done prior to inspection);  

Board resolution by company secretary if the vehicle will be licensed on behalf 
of a company 

In the case of Used Goods Carrying Vehicles (N1, N2 and N3), the above documents 
are required together with: 

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– 

– 

Engineer’s report (in the case of chassis cab);  

Certificate  from  the  Public  Health  Authority  (in  the  case  of  refrigerated 
vehicle). 

In  the  case  of  Used  Motorcycles  and  ATV’s  the  same  documents  as  for  Private 
vehicles are required, except for the VRT and JEVIC certificate which is not required 
for a Motorcycle. 

Clients whose vehicles have not been supplied for more than 6 months from date of 
first  entry  into  service  or  have  not  travelled  more  than  6,000  km  must  supply  an 
invoice  issued  by  the  manufacturer  or  by  an  authorized  agent  of  the  manufacturer 
showing  the  cost  of  the  vehicle  and  in  the  case  of  a  goods  vehicle  or  an  off  road 
vehicle  the  engine  capacity  and  gross  vehicle  weight,  and  the  other  documents 
showing the CIF (Cost Insurance and Freight) value (Motor Vehicle Registration and 
Licensing, Cap 368 Article 4 (d)). 

8.3.18.  Netherlands 

Registration system 

The registration is performed by the RDW. It is an independent administrative body 
under the Ministry of Transport, Public Works and Water Management. The minister 
of transport, public works and water management carries political responsibility for 
the  RDW’s  activities  and  sets  its  responsibilities.  The  RDW  is  a  non-profit 
organization dedicated to executing statutory tasks. In principle it is financed by its 
cost-covering charges. 

The Netherlands Postal Service is a major partner for the RDW in the execution of its 
tasks  in  the  vehicle  chain.  Through  600  post  offices,  it  arranges  transfers  and 
suspensions.  Furthermore,  around  23,000  car  dealers  and  garages  and  demolition 
firms  record  many  changes  on-line  in  the  spheres  of  change  of  ownership,  PTI, 
business stock and demolition. 

The  Netherlands  has  a  strictly  vehicle-based  licensing  system.  Its  underlying 
principle  is  continuous  registration,  that  is  to  say,  a  vehicle  must  appear  in  the 
registration  system  without  interruption  from  the  cradle  (admission)  to  the  grave 
(demolition  or  export).  Central  to  the  system  is  what  is  called  the  ‘holdership’ 
concept  in  the  Netherlands.  This  means  that  the  vehicle  obligations  in  terms  of 
taxation,  inspection  and  insurance  and  related  to  holding  the  vehicle,  not  its  use. 
Hence, registration provides the basis for the vehicle obligations in the Netherlands. 

Passenger  vehicles,  commercial  vehicles  and  lorries,  motorcycles,  mopeds  and 
trailers over 750 kg are licensed and registered. 

Procedures 

The RDW registers around 650,000 new vehicles every year. Every day authorized 
dealers/importers report around 2,700 new vehicles with a European or national type 
approval to the RDW. These vehicles are given a licence number on the same day, 
and the RDW sends the vehicle registration document part IA to the importer. 

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In  case  of  individual  imports  or  home  build  vehicles,  the  RDW  inspects  around 
12,500 motor vehicles every month at one of its inspection centres. The RDW then 
generates a licence number centrally, prepares the documents and sends them out. If 
an imported vehicle is not older then 3 years, comes from an EU Member State and 
has  the  required  documents,  an  identity  and  a  limited  technical  inspection  is 
mandatory. 

Around  6.5  million  changes  of  ownership  in  the  vehicle  register  are  entered  every 
year, including the transfers, which are processed at one of the 600 post offices or, 
since the April 2002, at one of the 4.500 dealers who are authorised for this purpose. 
These  dealers  are  connected  to  authorised  providers  who  have  connection  to  the 
vehicle register of the RDW. The new owner or a dealer acting on the new owner’s 
behalf presents the part IB document and the transfer document and provides proof 
of  identity  with  a  valid  driving  licence  or  passport.  The  transfer  process  is 
computerized, executed on-line and in real time with the RDW registers. The driving 
licence is checked on line, as are the presented vehicle documents. At the same time 
the  vehicle  register  is  checked  to  detect  any  irregularities,  whether  the  vehicle  is 
stolen,  for  instance.  If  everything  is  in  order,  the  vehicle  is  registered  in  the  new 
owner’s  name.  A  new  part  IB  document,  showing  the  details  of  the  new  owner,  is 
then printed at the post office or authorized dealer. 

Vehicles transferred to an authorized car dealer or accredited garage for inclusion in 
its stock can be reported as such to the RDW electronically. In this case the vehicle 
obligations are temporarily suspended. Potential buyers and staff may then only drive 
the  vehicle  when  it  carries  a  green  trade  number  plate.  RDW  inspectors  make 
periodical and random checks to ensure compliance with the rules. 

The owner reports any changes to the vehicle directly to the RDW. Depending on the 
changes,  the  RDW  inspects  the  vehicle  and  adjusts  the  vehicle  register.  The  owner 
then receives a new part IA document with the updated vehicle details. 

Documents 

Vehicle registration is based on three documents. The part IA document includes the 
technical  data;  this  is  issued  at  first  registration  and  when  the  specifications  are 
changed. The part IB document includes the holder details; this is issued each time 
the vehicle is reregistered. The part II document includes the transfer details; this is 
issued to the owner/holder only at the time of first registration; in case of transfers it 
serves as proof of holdership. 

Drivers must have parts IA and IB on them when driving the vehicle; part II is kept 
at  home.  None  of  the  documents  have  a  historical  character.  That  is  to  say,  every 
time a change is made, a new document is prepared. 

8.3.19.  Austria 

Registration system 

In Austria, insurance companies play an important role in the licensing authority. A 
cooperation of insurance companies maintains one of the two central registrations for 
vehicles.  Transfer  of  ownership,  tax  collection  and  of  course  insurance  related 

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services  are  also  provided  by  the  insurers.  The  licensing  system  is  specific  to 
individuals and regions. Insurance and tax obligations are highly integrated into the 
licensing system. 

Austria has two central vehicle registers: 

– 

– 

One  register  is  maintained  by  the  Verband  der  Versicherungsunternehmen 
Österreichs  (VVO).  Its  primary  purpose  is  to  assist  the  Zulassungsproces 
(admissions  process),  assist  with  recalls  and  assist  with  the  production  of 
statistical information and information for the government (e.g. the Ministry of 
Defence). In principle, no information is given to the public from this register. 
However, information concerning insurance is provided by licence number via 
the website. 

The  other  vehicle  register  is  maintained  at  the  Ministry  of  the  Interior.  Its 
purpose  is  to  assist  the  tracing  and  enforcement  agencies.  This  register  is 
periodically updated from the register of the VVO. Personal information in this 
register  is  updated  by  means  of  a  link  with  the  register  of  persons,  a 
notification  register  to  which  the  municipalities  are  affiliated.  Police  reports, 
including those relating to stolen vehicles, are also included in this register. 

Cars,  lorries,  motorcycles,  mopeds,  agricultural  tractors  and  motorized  equipment 
and trailers are registered and bear licence plates.  

Documents 

The ‘Zulassungsbescheinigung’ (admission certificate) has two parts, one of which is 
to be kept in the car and the other at home. In addition there is the ‘Typenschein’, a 
type  of  ‘Fahrzeugbrief’  (vehicle  logbook)  with  all  the  (historical)  technical 
information. In January 2011 the smartcard registration document was introduced in 
Austria on an optional basis.  

In  the  case  of  regular  imports,  the  importer  supplies  the  ‘Typenschein’  with  the 
vehicle. Otherwise – in the case of imports by individuals, for example – the vehicle 
has to be inspected. 

insurance 

companies.  To  do 

One  can  transfer  the  ownership  of  a  vehicle  at  any  of  the  870  offices  of  the  25 
affiliated 
the 
‘Zulassungsbescheinigung’, the ‘Typenschein’, proof of insurance, the number plates 
and proof of purchase. Central registration is performed online and in real time, and a 
new  ‘Zulassungsbescheinigung’  is  created  on  the  spot.  Number  plates  are  supplied 
from  stock  (unless  a  ‘Wunschkennzeichen’,  i.e.  a  personalized  number  plate  is 
involved),  together  with  one  inspection  sticker.  The  transfer  costs  amount  to  172 
euro. 

this,  one  must 

submit 

There is no distinction between the changes of the ownership and the changes of the 
vehicle. Both need a new registration. 

In  the  event  of  suspension,  one  must  hand  in  the  number  plates  and  Part  1  of  the 
‘Zulassungsbescheinigung’ at one of the insurance offices. The obligation to insure 
and tax the vehicle is then suspended. No fee is charged for suspension. 

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The  number  plates  and  the  Zulassungsbescheinigung  must  be  handed  in  during  de-
registration. Number plates are kept, the registration certificate part 1 and part 2 are 
marked as invalid and are given back to the former car holder. There is no charge for 
this. 

8.3.20.  Poland 

Registration system 

There are 400 local authorities responsible for motor vehicle registration. The rules 
of registration of vehicles and issuing of driving licenses are established in the Law 
on  road  Traffic  of  20  June  1997  (Journal  of  2005  No  108,  item  908  with  further 
modification). 

Motor vehicles, agricultural tractors, mopeds and trailers may be allowed for traffic 
if they meet the technical requirements and are registered. 

Procedures 

Following  the  application  for  the  registration  of  a  motor  vehicle  with  the  required 
documents, the responsible authority verifies the documents, checks the vehicle and 
holder  in  the  central  register  of  motor  vehicles,  following  which  the  registration 
authority  issues  the  registration  plates  and  the  temporary  certificate  of  registration 
(valid for 30+14 days, if required). 

During  that  period,  the  registration  authority  may  make  further  investigation  about 
the  vehicle  and  the  holder,  for  example  through  a  question  to  SI  Schengen,  a 
confirmation  by  another  EU  country  when  Part  II  of  the  registration  certificate  is 
missing, etc. Next, the registration authority orders the registration certificate that is 
issued centrally by one unit (the producer of registration certificates). Within 7 days 
of  registration,  the  certificate  is  produced  for  transmission  by  the  registration 
authority  (upon  receipt  from  the  producer)  to  the  holder.  The  registration  data  are 
then transmitted to the Central Register of Vehicles. 

The following documents are necessary for the registration of motor vehicles: 

– 

– 

– 

– 

– 

– 

– 

The title of ownership;  

The vehicle card, if it was issued;  

The certificate of conformity, if it is required;  

The certificate of technical inspection, if it is required;  

The certificate of registration, if the vehicle was previously registered; 

In  addition,  the  following  documents  must  be  transmitted  for  the  first 
registration of a vehicle in Poland:  

Proof  of  excise,  if  a  passenger  vehicle  or  category  L6  and  L7  was  exported 
from EU Member States and it is registered the first time in Poland;  

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– 

– 

Proof of tax on goods and services, if the imported vehicle from Member States 
is registered the first time; 

Proof of recycling payment, if the vehicle is registered the first time. 

8.3.21.  Portugal 

Registration system 

The  Institute  for  Mobility  and  Land  Transport  (Instituto  da  Mobilidade  e  dos 
Transportes Terrestres, IMTT) is responsible for vehicle registration.  

It is not obligatory to register a foreign vehicle for private use in Portugal for the first 
180  days  of  a  visit  in  any  one  calendar  year,  unless  the  owner  intends  to  live 
permanently in Portugal. 

However the following conditions must be met: 

– 

– 

The  vehicle  is  registered  in  the  name  of  a  person  who  is  not  a  resident  in 
Portugal; 

The vehicle is brought into Portugal and driven there by its registered owner or 
keeper; 

– 

The vehicle is for private use only. 

Procedure 

Before registering a vehicle in Portugal on a permanent basis the owner must apply 
for  a  Residency  Card  (Cartão  de  Residência)  from  the  Portuguese  immigration 
authorities, SEF (Serviços de Estrangeiros e Fronteiras). 

An imported car or bike must conform to the Portuguese road standards under what 
is  termed  "homologation"  (Homologacão)  before  it  can  be  registered.  The 
complexity of the process can vary according to age, make and origin of the vehicle. 

The  process  is  different  for  classic  and  collectable  vehicles.  It  is  also  different  and 
more  complicated  for  modified  vehicles  which  must  be  examined  at  an  authorised 
inspection  centre  to  ensure  the  work  was  carried  out  correctly  and  adheres  to  EU 
safety standards. 

Registration is recorded at both the local customs office and the IMTT. 

The following documents are usually needed: 

– 

– 

– 

A fiscal certificate or tax clearance form issued by customs. In some instances, 
there  are  customs  and  tax  charges  payable  (depending  on  the  model,  power, 
age and mileage of the vehicle); 

Original receipt of purchase showing taxes paid; 

A Certificate of Compliance (Form Model 9) issued by the IMTT confirming 
that the vehicle has undergone an inspection;  

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– 

– 

– 

– 

– 

A certificate of "homologation" (Homologacão) from the vehicle manufacturer 
or  certified  representative  in  Portugal  to  identify  that  the  vehicle  is  of  a 
recognised type in Portugal or the EU; 

Copy of the foreign vehicle registration certificate;  

Certificate of conformity, COC (Certificado de Conformidade CEE);  

A certificate of roadworthiness (IPO); 

The technical inspection (Inspecção Periódica Obrigatória, IPO) is made at an 
IMTT  approved  garage.  This  checks  vehicle  identification,  brakes,  tyres, 
emissions,  noise  levels,  lights,  steering,  windscreen  and  wipers,  and  chassis 
condition (inside and out).  

The following owner's documents are usually required: 

– 

– 

– 

– 

– 

Driver's licence (Cartão de Condução);  

Proof of identity (passport, identity card (Bilhete de Identidade)); 

Proof  of  residency  (Cartão  de  Residência),  evidence  of  application  for 
residency,  or  proof  of  residence  (property  title  deeds,  rental  contract,  utility 
bills, insurance certificate); 

Taxpayer's  identification  card  (Cartão  Fiscal  de  Impostos  or  Cartão  de 
Contribuinte) and number plus three year's tax returns or a declaration from the 
tax  office  stating  income  earned  (in  Portugal  or  elsewhere)  over  the  previous 
three years;  

A  certificate  of  cancellation  of  residence  issued  by  the  former  country  of 
residence or their Consulate in Portugal  

Original  documents  and  one  copy  must  be  supplied.  Once  the  application  has  been 
submitted,  customs  may  issue  a  limited-validity  authorisation  (Guia  de  Circulação) 
which means the vehicle may be used while the application is in process. 

The details of the vehicle's registration are recorded on the DUA (Documento Uníco 
Automóvel) or "All-in-One Card". This replaces the Vehicle Ownership Registration 
(Titulo  de  Registo  de  Propriedade),  Licence  Plate  (Matrícula)  and  Log  Book 
(Livrete) card. Vehicle registration documents must be carried in the car at all times. 

DUAs - and the registration of new or second hand vehicles can be done at a local 
civil registry office, the IRN (Instituto dos Registos e Notariado). 

8.3.22.  Romania 

Motor vehicles are registered by the Department for Driving Licenses and Vehicles 
Registration  (DRPCIV).  The  registration  is  carried  out  only  for  vehicles  that  are 
approved by the Romanian Automobile Register (Registrul Auto Roman (RAR)) and 
require the following documents: 

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– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

The  vehicle  registration  form  which  should  contain  the  necessary  data  and 
carry the stamp of the competent tax body of the local government authority;  

The vehicle identity document, original and copy;  

A  document  that  proves  the  applicant’s  ownership  of  the  motor  vehicle  or 
trailer, original and copy; 

The identity document of the applicant, original and copy; 

Evidence  that  the  technical  periodical  inspection  was  carried  out  and  is  still 
valid, except for new motor vehicles and trailers; 

A valid mandatory third party liability insurance document; 

Proof of registration tax payment; 

Proof of special tax for cars and motor vehicles payment; 

Proof of registration certificate issuance payment; 

Proof of registration plates issuance payment; 

Authenticity certificate of the vehicle, except for new vehicles, motor vehicles 
used at sport competitions, and historical vehicles; 

– 

Special power of attorney, if appropriate. 

Cars  belonging  to  foreign  citizens  working  in  Romania  should  be  temporarily 
registered  with  the  local  police  department.  In  order  to  qualify  for  temporary 
registration  in  Romania,  the  car  should  first  be  registered  abroad,  even  if  such 
registration  is  only  temporary.  To  obtain  temporary  registration  plates,  foreign 
nationals  need  to  provide  the  police  department  with  the  identity  card  of  the  car,  a 
notarised translation of the foreign registration certificate, the registration form from 
the  tax  authorities,  the  Romanian  insurance  policy  and  copies  of  their  passport  and 
residence permit/registration certificate (as applicable). 

The  Registrul  Auto  Roman  (Romanian  Automobile  Register)  issues  the  Vehicle 
Identity  Card  (VIC)  which  sets  out  the  technical  data  and  the  data  for  the 
identification of the vehicle which are used afterwards by the registration authority. 
The  Vehicle  Identity  Card  can  be  issued  only  for  the  vehicles  which  can  be 
identified,  respectively  the  ones  for  which  the  representatives  of  DIA  establish  a 
valid identification number. 

Vehicles which have been last registered in a Member State of the European Union 
and the configuration of which has not been modified can receive the identity card 
without being subject to individual approval. Nevertheless, since they are before their 
first  registration  in  Romania,  these  vehicles  are  checked,  especially  with  respect  to 
the authenticity of the elements of identification and the document proving the prior 
registration, as well as their technical condition.  

The road vehicle authenticity certification is performed by RAR: 

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– 

– 

– 

For  used  vehicles  which  have  not  been  previously  registered  in  Romania  and 
which are subject to approval; 

For  vehicles  which  were  previously  registered  in  a  Member  State  of  the 
European Union and which are imported or introduced in Romania; 

For the vehicles which are or have been previously registered in Romania, the 
owner of which changes. 

During the authenticity certification, the RAR checks whether: 

– 

– 

– 

The  main  identification  elements  of  the  vehicle  are  original  and/or  were  not 
subject to unauthorized changes; 

The standard form of the document confirming the previous registration of the 
vehicle,  issued  by  the  competent  authorities  in  the  country  of  origin,  is 
authentic. 

The vehicle does not appear on the wanted list at national or international level, 
according  to  the  databases  to  which  RAR  has  access  based  on  the  protocols 
concluded with the authorities managing these databases. 

8.3.23.  Slovenia 

Registration system 

The Slovenian Traffic Safety Agency (Javna agencija Republike Slovenije za varnost 
prometa) is managing the registration of motor vehicles. 

Slovenia’s  licensing  system  is  a  vehicle-related  system.  Cars,  buses,  lorries, 
motorcycles, mopeds, agricultural tractors and trailers of over 750 kg are registered 
and  bear  licence  plates.  Light  trailers  (under  750  kg)  are  not  registered,  but  should 
bear the “third” licence plate from the towing vehicle. 

Procedures 

When privately importing a vehicle one must report with the vehicle to one of the 61 
private  roadworthiness  test  organisations  (under  the  Slovenian  Traffic  Safety 
Agency).  Based  on  the  COC  and  an  identification  and  assessment  of  technical 
condition of the vehicle, a national COC is drawn up. This costs about 100 €. Once in 
possession  of  a  national  COC  one  can  apply  to  one  of  the  vehicle  licensing 
organisations  (regional  government  offices  or  roadworthiness  test  organisations  or 
car  sellers  with  authorisation  of  Slovenian  Traffic  Safety  Agency)  for  first 
registration in Slovenia. 

When applying for registration, one must also produce proofs  of vehicle  insurance, 
tax  payment,  ownership,  and  identity.  In  the  case  of  used  vehicles  the  relevant 
foreign documents must also be produced. 

Applications  to  register  vehicle  ownership  must  be  made  to  one  of  the  vehicle 
licensing organisations. A condition for registering vehicle ownership is residence in 

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Slovenia.  This  must  be  evident  from  the  proof  of  identity.  Proof  of  ownership,  the 
most recent vehicle document and the national COC must be submitted. 

When  applying  the  vehicle  must  be  taxed  and  insured  and  have  passed  inspection. 
The deed of sale must be signed by new and the previous owner. The signature of the 
previous  owner  must  be  legally  verified.  The  previous  owner  is  only  required  to 
present  himself  in  person  and  must  hand  over  the  previous  vehicle  document.  The 
new vehicle document and the number plates are issued on the spot. 

From  1  July  2011,  the  vehicle  ownership  change  requires  the  presence  of  the 
previous and the new owner (in the case of natural persons) at the vehicle licensing 
organisation, where the identities of both persons are verified.  

Documents 

Slovenia  has  introduced  a  one-part  vehicle  document  that  conforms  to  the 
harmonised European model. The document does not constitute a historical record. If 
any changes are necessary, a new document is issued. 

The vehicle document is produced in the Slovene language; in certain municipalities 
(border zones), it is bilingual - also in Italian or Hungarian. 

Drivers must have their vehicle documents with them when driving a vehicle.  

8.3.24.  Slovakia 

In  order  to  register  a  car  in  Slovakia,  applicants  must  provide  the  original  Vehicle 
Title  (which  must  contain  the  technical  specifications),  a  document  showing  the 
vehicle  was  de-registered  in  the  Member  State  of  origin,  documented  proof  of 
ownership,  an  ID  Card  or  Passport,  a  residence  permit,  a  certificate  of  conformity 
proving the vehicle complies with the specifications for the EU market and a new car 
insurance. 

The car registration form must be filed at the Motor Vehicle Register at the Transport 
Inspectorate.  The  applicant  will  then  report  to  the  district  office,  department  of 
transport in the place of residence, which shall submit an application for approval of 
individually  imported  vehicle  or  the  request  for  recognition  of  type  approval  of  an 
application for recognition or approval (so-called national approval) of individually 
imported  vehicle.  The  application  must  contain  particulars  of  the  applicant.  The 
application  must  be  accompanied  by  proof  of  ownership.  This  could  include  the 
purchase  contract,  invoice,  or  deed  of  gift.  The  registration  certificate  (technical 
passport)  or  proof  of  disposal  of  vehicle  registration  in  the  country  of  origin  is 
needed too.  

The  application  will  then  receive  a  fiscal  stamp  according  to  the  Transport 
Inspectorate’s current price list. With this administrative decision and the copy of an 
application form, the new owner must bring his motor vehicle to the technical control 
station (TCS).  

After  inspection,  the  applicant  must  hand  over  the  technical  inspection  report  and 
proof  of payment of the recycling fee to the Recycling Fund to the District Office. 

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The Traffic Office will issue a decision on approval of individually imported vehicle 
and issue the vehicle registration certificate. 

Subsequently,  the  vehicle  owner  chooses  the  insurance  company  to  insure  the  car. 
The insurance company will provide the owner with a certificate of insurance. 

Finally,  the  applicant  has  to  visit  the  Transport  Inspectorate  (DI),  where  he  should 
show the decision and submit the registration certificate from the District Transport 
Office, proof of acquisition, a certificate of insurance contract and its identification 
documents.  The  DI  will  register  the  vehicle  and  will  assign  a  registration  number 
(license plate number of the former).  

Documents  in  other  than  Slovak  or  Czech  language  must  be  translated  into 
Slovakian. Where the documents are bilingual, it is necessary that both languages are 
translated  to  Slovakian.  Translation  can  be  done  only  by  a  translator  who  is 
registered in the list of official interpreters.  

Since 1 January 2008, applicants importing a new or used vehicle registered have to 
submit the following documents: 

– 

– 

– 

– 

– 

– 

The  proof  of  ownership,  such  as  the  invoice,  the  purchase  agreement  or  the 
donation agreement;  

The certificate of registration;  

A document to remove the vehicle from the vehicle registration in a Member 
State; submitted only if the record of the disposal is not listed on the certificate 
of registration under the second point;  

The expertise to check the originality of the vehicle;  

The valid protocol on technical vehicle inspection or a valid implementation of 
roadworthiness 
in  a  Member  State,  such  as  a  certificate  of 
roadworthiness, referred to the documents shall be submitted only if a vehicle 
is subject to inspection;  

issued 

The  valid  protocol  on  emission  control  of  motor  vehicle  pursuant  to  §  67 
paragraph 2 point a) the results of the fit to road traffic or a valid execution of 
emission on vehicle issued in a Member State, for example, issue a certificate 
of inspection you need only if the record of emission control is not part of the 
document for technical inspections by the fifth point specifying the documents 
to be submitted only in case of a used vehicle when the vehicle is subject to a 
control;  

– 

The  proof  of  payment  of  contribution  to  the  Recycling  Fund  for  imported 
vehicles.  

8.3.25.  Finland 

Registration system 

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The Liikenteen turvallisuusvirasto Trafi (i.e. the ‘Transport Safety Agency Trafi’) is 
in  charge  of  all  the  tasks  formerly  handled  by  the  Finnish  Vehicle  Administration 
(AKE). Trafi is a central government office working under the Ministry of Transport 
and Communication.  

Trafi is in charge of vehicle registration and maintains the Vehicular and Driver Data 
Register. Trafi arranges vehicle registration by obtaining the services necessary from 
service providers, i.e., contractual registration authorities. Registrations are done by 
insurance  companies,  car  dealerships  and  financing 
inspection  companies, 
companies. Private customers can also perform some registration-related tasks in the 
online  registration  service  provided  by  Trafi.  Apart  from  registering  diplomatic 
vehicles, Trafi does not perform registrations. 

The  licensing  system  in  Finland  is  vehicle  based  and  licensing  is  integrated  to  the 
registration system and the prior notification system. A vehicle can receive a license 
plate  number  and  actual  plates  in  the  prior  notification  process  or  in  the  first 
registration process.  

Passenger  vehicles,  commercial  vehicles  and 
lorries,  motorcycles,  mopeds, 
agricultural tractors, motor-driven working machines, snow mobiles and trailers are 
all  registered.  Some  road  maintenance  and  harvesting  motor-driven  working 
machines and trailers do not have to be registered. 

Documents 

The registration document is the pivot in the system and includes all relevant details 
about  the  vehicle  and  the  owner/holder.  The  registration  document  is  issued  at  the 
time  of  the  first  registration,  and  continues  to  be  used  for  all  subsequent 
administrative changes. Every time there is a change of information, a new document 
is produced. 

Trafi introduced a new Vehicle Traffic Data System (ATJ) on 12 November 2007. At 
the same time, the look and part of the content of the previous registration certificate 
was also renewed. The current certificate is in two parts (as was the former one). The 
technical  part  (part  I)  contains  the  vehicle’s  technical  information  and  name  and 
address information of the owner(s) and holder(s). 

The  driver  must  always  carry  with  him/her  the  technical  part  when  operating  the 
vehicle. The notification part (part II) of the certificate contains related sections for 
making  notifications  of  changes.  Both  parts  are  printed  on  A4-size  security  paper. 
The security paper used is the same for both part of the document. The certificate’s 
parts can be identified by the name and number of the part, which are printed on the 
upper right hand corner of each part. 

The  new  certificate  contains  information  on  the  intervals  between  scheduled 
inspections and suggestions for repair issued at the annual inspection. Customers are 
given a new technical part (part I) at each inspection. On all registrations, both parts 
of the certificate are printed for the customer. The old registration certificate is valid 
until the customer receives a new certificate from the registration partner or by mail, 
but no more than 30 days from the time a registration notification was made. If a new 

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certificate  has  not  been  received  within  30  days,  the  customer  must  request  a  new 
one from the nearest inspection station.  

The registration for new vehicles is organised via vehicle importers and car dealers in 
a way that is very similar to the accelerated procedure in the Netherlands. In case of 
individual imports the registration document and the licence plates are issued on the 
spot at registration time at the inspection station. 

The following requirements apply to the first registration of a vehicle: 

– 

– 

– 

– 

– 

– 

The vehicle must pass a registration inspection, or a pre-registration certificate 
or single approval certificate valid for registration must have been granted for 
the vehicle; 

The vehicle must comply with all valid Finnish requirements; 

A certificate of destruction as specified in Section 18 I of the Waste Act may 
not be issued for the vehicle; 

Documentation  for  payment  of  all  taxes  and  other  fees  regarding  the  vehicle 
must be submitted; 

A report on the vehicle’s proprietary rights and holder must be submitted;  

The vehicle must be covered by a motor liability insurance policy. 

If a private person imports a vehicle from abroad to be used in traffic in Finland, the 
following documents are required for the first registration: 

– 

– 

– 

– 

A valid registration inspection certificate; 

Customs  registration  permit  (submitted  electronically  by  the  Vehicular  and 
Driver Data Register); 

Customs certificate, if a tax-free vehicle is imported from a non-EU country; 

An  ownership  report  starting  from  the  last  owner  outside  of  Finland  (if  the 
customer  submits  a  vehicle  taxation  decision,  an  ownership  report  beginning 
with the first person liable to pay taxes in Finland is required); 

–  Motor liability insurance policy. 

8.3.26.  Sweden 

Registration system 

The Traffic Registry (Trafikregistret or TR), a department of the Swedish Transport 
Agency,  STA  (Transportstyrelsen)  is  responsible  for  the  registration  of  motor 
vehicles. 

The  licensing  system  in  Sweden  is  vehicle-based.  Passenger  vehicles,  commercial 
vehicles and lorries, motorcycles, mopeds, agricultural tractors, trailers and scooters 
are all registered and numbered. 

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Procedures 

The initial registration of a vehicle requires: 

– 

– 

– 

– 

– 

Documents related to a vehicle’s origin; 

Normally  a  certificate  of  conformity,  but  for  privately  imported  vehicles  a 
general certification (by a Vehicle Inspection Company) 

Proof of insurance; 

Proof of tax payment, when put in traffic; 

Declaration of a number of technical details. 

The registration documents and the number plates are issued by the Traffic Registry. 
The plates are produced by a private company. The registration of most new vehicles 
is organized via accredited importers and manufacturers by means of file transfers. 

In case of changes of ownership, both the buyer and the seller must sign the vehicle 
registration  document.  After  registration  the  buyer  will  receive  a  new  registration 
document.  The  seller  receives  a  certificate  stating  that  he  or  she  is  no  longer  the 
owner  or  holder  the vehicle.  Transfer of ownership  can also  be  completed  at 3,000 
accredited car dealers and garages. 

When the verification of origin has been approved the vehicle needs to undertake a 
registration  inspection  and  technical  identity  verification  by  a  Vehicle  Inspection 
Company.  They  report  the  changed  data  to  TR  who  then  issues  a  new  vehicle 
registration document to the owner. 

If  a  vehicle  has  been  re-built  or  changed  in  other  ways  the  vehicle  might  need  to 
undertake an inspection by a Vehicle Inspection Company. They report the changed 
data to TR who then issues a new vehicle registration document to the owner. 

Documents 

The  pivot  in  the  system  is  the  vehicle  registration  document,  which  includes  all 
relevant  details  about  the  vehicle  and  the  owner/holder.  This  EU-harmonised 
document in two parts is issued at the time of the first registration, and continues to 
be used for all subsequent administrative changes. It is not a historical document, but 
is  issued  every  time  some  facts  are  changed,  except  for  changes  of  address  of  the 
owner.  Drivers  and  riders  do  not  need  to  bring  the  registration  document  when 
driving or riding their vehicle. 

The  owner  can,  beside  the  vehicle  registration  document,  use  the  Internet  –  or 
telephone-based services for reporting certain administrative changes of the vehicle 
using a smartcard. 

8.3.27.  United Kingdom 

Registration system 

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The  motor  vehicle  registration  system  is  managed  by  the  Driver  and  Vehicle 
Licensing Agency (DVLA) which is the largest of the four Agencies of the Safety, 
Service Delivery and Logistics Group (SSDL) within the Department for Transport 
(DfT). Each agency works under the authority of the Secretary of State for Transport 
who  is  assisted  by  three  Ministers.  DVLA  is  an  Executive  Agency  of  DfT.  It 
undertakes registration services for Drivers in Great Britain and Vehicles in the UK 
(Great Britain and Northern Ireland) and the necessary operational and development 
costs are funded through fees charged to the motoring public. 

The licensing system in the United Kingdom is vehicle-oriented.  

DVLA  register  vehicles  such  as  cars,  buses,  commercial  vehicles,  lorries, 
motorcycles,  mopeds,  agricultural  tractors  and  all  other  mechanically  propelled 
vehicles for use on the public road. 

Procedures 

At first registration an authorized dealer or DVLA local office requires presentation 
of a registration application form (V 55), the Certificate of Conformity (or alternative 
documentation)  and  proof  of  insurance.  Vehicles  not  covered  by  a  type  approval 
must undergo an inspection before being admitted on the public highway. 

Any changes and amendments to both the vehicle’s and the keeper’s details must be 
indicated on the registration certificate and sent to DVLA. The Agency then records 
the information, prepares a new certificate and sends this to the keeper. 

When a vehicle is imported for use in Great Britain (GB), it must be registered with 
the  Driver  and  Vehicle  Licensing  Agency  (DVLA).  This  must  be  done  as  soon  as 
possible as the vehicle cannot be used or kept on public roads. 

A  'brand  new'  vehicle  can  be  driven  to  GB  and  registered  as  'new'  provided  the 
vehicle: 

– 

– 

– 

– 

Is  registered  within  two  weeks  of  collection  -  this  may  be  extended  to  one 
calendar month at peak periods, e.g. before 1 March and 1 September; 

Only  has  reasonable  delivery  mileage  -  DVLA  considers  reasonable  delivery 
mileage to mean the vehicle being driven from the pick up point to home using 
a direct route; 

Has not been previously permanently registered; 

Has  been  stored  before  registration  and  is  a  current  model  or  is  a  model  that 
has ceased production within the last two years. 

The  DVLA  recommends  importers  to  transport  rather  than  drive  vehicles  from  the 
port to the first destination. 

New  vehicles must  have a  certificate  of conformity as  proof of type approval from 
the supplier or vehicle manufacturer. 

EN 

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   EN 

 
Left-hand-drive  vehicles  from  within  the  EU  will  need  a  certificate,  issued  by  the 
Vehicle  Certification  Agency  (VCA),  under  the  Mutual  Recognition  scheme.  This 
shows  that  changes  have  been  made  to  the  vehicle,  making  it  suitable  for  use  on 
British roads. 

Vehicles that have not been subject to European type approval will be subject to one 
of the following tests, they are: 

– 

The  Individual  Vehicle  Approval  (IVA):  The  IVA  inspection  checks  that  the 
vehicle is designed and constructed to meet safety and environmental standards 
for  use  on  UK  roads.  Examiners  from  the  Vehicle  and  Operator  Services 
Agency do inspections at approved sites in Great Britain. The Driver Vehicle 
Agency  does  inspections  in  Northern  Ireland.  If  the  vehicle  passes  an  IVA 
inspection, the examiner issues an Individual Approval Certificate. Applicants 
can then register your vehicle with the Driver and Vehicle Licensing Agency 
using the certificate. For passenger cars and light goods vehicles there are two 
levels  of  IVA  inspection,  basic  and  normal.  Vehicles  subject  to  the  basic 
requirements  are  left-hand  drive  vehicles,  personally  imported  vehicles, 
amateur  built  vehicles,  vehicles  manufactured  in  very  low  volume,  etc.  The 
basic IVA requirements can be assessed by a visual inspection of the vehicle to 
assess its design and construction against the technical standards. Vehicles that 
do  not  fall  into  any  of  the  above  classes,  including  heavy  vehicles,  larger 
passenger vehicles and trailers will require a normal IVA inspection. Passenger 
cars and light goods vehicles having a normal IVA inspection have to meet the 
basic IVA, as well as meeting additional EC Directive standards for up to 12 
safety,  environmental  and  security  features.  In  some  cases,  evidence  of 
compliance  to  standards  from  another  country  considered  comparable  to  the 
EC standards - e.g. Japan - will be acceptable. 

– 

Light  goods  vehicle  -  Single  Vehicle  Approval  (SVA)  test  if  it  is  a  (up  to 
3,000kg); 

–  Motorcycle or quadricycle - motorcycle SVA. 

Documents 

The  pivot  in  the  vehicle  registration  system  is  the  registration  certificate  (V5C) 
which belongs with each vehicle and contains all the relevant details of the vehicle 
and its keeper. This is not an historic document, because a new V5C is prepared by 
DVLA  each  time  the  relevant  details  change.  Drivers  do  not  need  to  have  this 
certificate on them when driving the vehicle. 

From  15  August  2010,  DVLA  introduced  a  new  style  V5C.  The  re-designed  V5C 
makes it clear that this certificate is not proof of ownership and also provides details 
of where keepers can obtain advice on how to avoid becoming the victim of vehicle 
crime. 

The  front  of  the  certificate  is  red  instead  of  blue  and  the  customer  information 
sections on the back have been made simpler. A new style certificate will be sent to 
keepers  when  they  purchase  a  new  vehicle  and  DVLA  is  notified;  when  a  keeper 

EN 

125 

   EN 

 
applies to change any vehicle or personal details or when the original V5C has been 
lost, stolen or destroyed and replacement application is made. 

The blue version of the certificate, however, is still valid. 

EN 

126 

   EN 

 
8.3.28.  Transferring motor vehicles to another Member States - Temporary and professional 

(or ‘commercial’) registration schemes in the EU 

When a second-hand motor vehicle is sold, it can obviously be put on a trailer or on a 
truck and brought to the other Member State. Yet many motor vehicles will be driven 
to the Member State of destination. A motor vehicle cannot be driven on public roads 
without displaying a registration number. 

There  are,  in  a  nutshell,  four  main  ways  to  drive  a  motor  vehicle  lawfully  to  the 
Member State of destination:  

8.3.28.1. The seller drives the motor vehicle with his own registration plates 

Both parties can agree that the seller drive the motor vehicle displaying its original 
registration  to  the  Member  State  of  the  buyer.  The  vehicle  should  also  carry  the 
registration certificate. 

8.3.28.2. The buyer seeks registration of the motor vehicle in his own Member State:  

When the buyer has fulfilled the registration formalities in his home Member State 
and obtained the registration certificate while the vehicle is still in the Member State 
of  origin,  he  is  entitled  to  use  that  registration  certificate  and  the  corresponding 
number  plate  to  drive  the  motor  vehicle  home,  pursuant  to  Article  4  of  Directive 
1999/37/EC.  

8.3.28.3. The buyer seeks temporary registration of the motor vehicle:  

Many Member States apply the principle that the motor vehicle should not be used or 
kept on their public roads until the registration and vehicle tax formalities have been 
completed.  Nevertheless,  many  Member  States  have  put  in  place  a  system  of 
temporary  registration  so  that  the  vehicle  can  be  driven  for  a  short  period  before  it 
obtains final registration. If the vehicle is temporarily registered in the Member State 
of the buyer or the seller, it is lawfully admitted to international traffic: 

– 

– 

The Member State may issue a temporary registration certificate that does not 
differ, or only slightly differs, from the model set out in Directive 1999/37/EC. 
In  that  case,  other  Member  States  are  obliged  to  recognize  the  temporary 
registration  certificate  issued  by  a  Member  State  for  the  identification  of  the 
vehicle  in  international  traffic,  provided  that  the  driver  carries  Part  I  of  the 
registration certificate pursuant to Article 5(1) of the Directive.  

Alternatively,  the  temporary  registration  certificate  may  substantially  differ 
from the model set out in Directive 1999/37/EC. The Member States of transit 
and the Member State of destination must, in principle, recognise the certificate 
and  admit  the  motor  vehicle  to  their  territory,  in  accordance  with  Articles  34 
and 36 TFEU. The free movement of the motor vehicle may only be impeded 
for reasons relating to road safety (such as the driving capacities of the driver, 
his  compliance  with  the  local  rules  of  the  road  or  the  roadworthiness  of  the 
motor  vehicle),  in  case  of  reasonable  suspicion  of  vehicle  theft  or  when  the 

EN 

127 

   EN 

 
 
controlling  authorities  have  reasonable  doubts  about  the  validity  of  the 
certificate. 

Temporary  registrations  are  an  important  instrument  for  the  second-hand  market, 
especially  for  the  physical  transfer  of  the  motor  vehicle  to  another  Member  State. 
Impediments  to  the  intra-EU  movement  of  motor  vehicles  displaying  a  temporary 
registration number issued in another Member State have to be primarily examined 
in the light of Articles 34 to 36 TFEU. According to settled case-law of the Court of 
Justice,  the  free  movement  of  goods  between  Member  States  “could  not  itself  be 
complete if it were possible for Member States to impede or interfere in any way with 
the movement of goods in transit. It is therefore necessary, as a consequence of the 
Customs Union and in the mutual interest of the Member States, to acknowledge the 
existence of a general principle of freedom of transit of goods within the [EU]70”. 

If  a  Member  State  impedes  the  transit  of  a  motor  vehicle  carrying  temporary 
registration plates lawfully issued in another Member State, it will infringe Article 34 
TFEU, unless the impediment is justified on the basis of Article 36 TFEU or one of 
the  mandatory  requirements  accepted  by  the  Court  of  Justice71.  For  example,  a 
Member State would be entitled on the basis of Article 36 TFEU or pursuant to one 
of the mandatory requirements accepted by the Court of Justice, to impede the transit 
of a vehicle carrying temporary registration plates legally issued in another Member 
State for reasons related to road traffic safety, if the vehicle or its driver constituted a 
risk to the health of other road users, or if the driver could not demonstrate that he 
was entitled to drive the motor vehicle. 

The  following  table  established  by  EReg72  gives  an  overview  of  the  temporary 
registration systems in some Member States: 

70 

71 

72 

Point 18 of the judgement of the Court of Justice of 23 October 2003, Administration des douanes et 
droits indirects v Rioglass SA and Transremar SL, Case C-115/02. 
See judgement of the Court of Justice of 2 October 2003, Criminal proceedings against Marco Grilli, 
Case C-12/02. 
Association  of  European  Vehicle  and  Driver  Registration  Authorities,  HTTPS://WWW.EREG-
ASSOCIATION.EU/.  

EN 

128 

   EN 

 
                                                 
TEMPORARY REGISTRATION SYSTEMS (Table 1) 

Country 

How many systems 
of temporary 
registrations? 

Availability only 
under certain 
conditions? 

Maximum duration 
of registration? 

Documents 
compliant with 
Directive 199/37/EC

Belgium 

2 systems: transit 
plates; international 
plates 

Cyprus 

One system only 

Denmark 

2 systems: border 
number plates and 
temporary stickers 

Transit: limited to 
non residents 
international: to 
members of 
international 
organisations. 

Only for non 
residents  

border plates: non 
residents; temporary 
stickers: same as 
commercial plates 
for private  

Transit 6 months; 
International 1 
year(renewable) 

Yes but only limited 
validity 

Maximum 1 year 

Similar documents as 
normal registrations 

border plates: two 
years; temporary 
stickers:7days 

border plates 
compliant no official 
document issued for 
stickers  

Estonia 

Transit plates system 
only 

No restrictions 

Maximum 30 days 

No formal 
registration 
document issued 

Finland 

One system only 

No restrictions 

Varies between 1 day 
to several months 

Different from 
"normal" registration 
document 

Germany  Two systems 

Only for legally 
defined purposes but 
available for 
residents and non 
residents 

Varies between 5 
days to one year 

Similar documents as 
normal registrations, 
but not compliant 
with Directive 
1999/37 

Hungary  One system only 

National restrictions 
(No detail) 

6 Months for 
"E"plates;12months 
for "P" plates 

Not compliant 

Iceland 

One system only 

Only available for 
persons with Iceland 
Id. Number 

No time limit 

No specific 
document 

Ireland 

One system only 

Only available to non 
residents 

Maximum 30 days 

No 

EN 

129 

   EN 

 
 
Same registration 
document as normal 
registration 
document 

Same registration 
document as normal 
document; special 
option for resale 

Same registration 
document as normal 
registration 
document 

Different layout to 
normal registration 
documents 

Latvia 

One system only 

Available for all 
persons 

Maximum 6 months 

Lithuania  One system only 

Available for all 
persons 

Maximum 90 days 

Luxem-
bourg 

Nether-
lands 

Poland 

One system only 

Two different 
systems depending 
on either former 
Dutch registration or 
not 

Two systems: 
temporary 
registration system+ 
system for multiple 
use  

Romania  One system only 

Available only for 
non residents and for 
export of vehicles 
only 

Only for transit and 
export for all persons 
residents or not 

Maximum 90days 

Maximum 14 days 

Temporary systems 
for all residents; 
multiple use for 
companies 

Temporary systems 
maximum 
44days;multiple use 
maximum 6 months 

Different documents 
but all compliant 
with Directive 
1999/37 

Only for import and 
export: export only 
for non residents 

Export maximum 
30days;import 
depending on 
customs clearance 

Similar documents as 
normal registrations 

Slovakia  One system only 

Only for non 
residents  

Maximum 30days 

Identical documents 

Sweden 

Different systems for 
holder with residence 
permanent, 
temporary or no 
residence 

UK 

No temporary 
registration system 

Available for all 
persons see before 

Maximum 12 
months, but different 
schemes with 
different durations 

Identical documents 
then normal 
registration, but with 
expiry date 

Not applicable 

Not applicable 

Not applicable 

EN 

130 

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TEMPORARY REGISTRATION SYSTEMS (Table 2) 

Country 

Conditions for obtaining 
temporary Registration?  

Formal agreement for 
recognition? 

Description of number 
plates used 

Belgium 

holder id.; insurance cover; 
valid roadworthiness test; 
possible tax exemption 

conformity with Vienna 
convention and Dir1999/37 

Cyprus 

holder id.; insurance cover; 
valid roadworthiness test; 
possible tax exemption, 
payment 

Yes 

Denmark 

border plates: holder id; 
insurance  

Temp. Stickers: holder id. 
and insurance cover 

Recognition with Germany 
in preparation 

Estonia 

 holder id.; insurance cover; 
valid roadworthiness test 

No 

Finland 

holder id.; insurance cover; 
tax paid 

Nordic countries agreement:: 
Sweden; Norway; Denmark 

Germany 

holder id.; proof of insurance 
cover; credibility; vehicle Id 
inserted by holder 

Agreement between 
Netherlands and Germany 

Three different models in 
use: white with green; red 
with white; blue with yellow; 
sticker with date of expiry 

Professional plates: White 
background red digits; 
Temporary registrations 
identified by V for visitor on 
plate 

border number plates: white 
with red and black numbers 
stickers no plate date of 
expiry indicated 

Professional: Letters 
PROOV followed by 4 No; 
Transit: white with red digits 
and frame 

Professional: yellow 
reflective black digits; 
temporary: sticker white 
reflective red digits  

Red Plates: white 
background with red 
numbers; Temporary white 
background black numbers 
+expiry date 

Hungary 

holder id. and check of 
activity; insurance cover 

No 

White background with 
black digits only numbers 

Iceland 

holder id.; insurance cover; 
valid roadworthiness test; tax 
payment 

No 

Ireland 

Not specified 

No 

Pre registration: red bas 
black frame and characters 

Identified by ZZ and unique 
number 

EN 

131 

   EN 

 
 
Latvia 

holder id.; vehicle id.; 
vehicle technical data ; 
insurance cover; tax payment

No 

Lithuania 

holder id.; insurance cover; 
proof of holdership 

No 

Luxem-
bourg 

holder id.; ownership 
document; technical data; 
valid technical inspection; 
insurance cover 

Not necessary as documents 
compliant 

Nether-
lands 

holder id.; insurance cover; 
valid roadworthiness test; 
possible tax exemption 

No 

Professional plates: 
reflective white with red 
numbers; Temporary plates 
identical to normal plates 

Professional plates 
:reflective white with red 
numbers year of validity 
indicated; 

Temporary plates waterproof 
cardboard colours as above  

Professional: red with white 
numbers only expiry on 
plate; 

Temporary normal plate with 
"EX" four numbers and 
expiry date  

Only available trough RDW 
authorised companies; light 
green with black numbers; 
temporary plate can also be 
homemade 

Poland 

holder id.; ownership 
document; available 
technical data; valid 
technical inspection 

Not necessary as documents 
compliant 

Different colour and 
structure than normal plates; 
sticker with date of expiry 

Romania 

holder id.; insurance cover; 
valid vehicle id.+ 
roadworthiness test; possible 
tax exemption, payment 

Not necessary as documents 
compliant 

Slovakia 

holder id.; insurance cover; 
available technical data 

Not necessary as documents 
compliant 

Sweden 

holder id.; insurance cover; 
available technical data; 
valid vehicle inspection 

Nordic countries agreement: 
Norway; Finland; Denmark 

UK 

Not applicable 

Not applicable 

For Probe "PROBE" on the 
plate; provisional: white with 
red letters one or two letters 
followed by four or five 
numbers  

Yellow background with 
black digits identified by 
character V 

Green with black digits 
expiry date shown on plate; 
letter B indicate limitations 
of use 

Professional plates: White 
acrylic with red digits 3 
letters 2 numbers displayed 
in triangular holder 

EN 

132 

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8.3.28.4. The professional seller drives the motor vehicle with his professional number plates:  

Professional  registration  schemes  exist  in  most  Member  States  in  order  to  allow 
retailers to drive motor vehicles on public roads for a very short period without being 
obliged to formally register them. Professional registration schemes are reserved for 
manufacturers,  assemblers,  distributors  and  dealers,  with  respect  to  motor  vehicles 
which they possess.  

Most  Member  States  do  not  issue  professional  registration  certificates  as  such, 
involving  identification  of  the  motor  vehicle.  They  usually  provide  another  type  of 
document,  establishing  the  link  between  the  registration  plates  and  their  holder, 
and/or require the holder to keep a logbook in which trips made with the registration 
plate are recorded.  

Article  35(1)(a)  of  the  Vienna  Convention  on  Road  Traffic73  specifies  that  the 
Contracting  Parties  may  not  prohibit  the  movement  of  motor  vehicles  that  are 
registered  by  another  Contracting  Party,  provided  the  driver  carries  a  registration 
certificate.  The  Contracting  Parties  must  also  recognise  registration  certificates 
issued  by  other  Contracting  Parties  in  accordance  with  the  Convention.  However, 
there  is  no  provision  of  the  Convention  which  requires  or  permits  the  Contracting 
Parties to prohibit the free movement of vehicles not complying with the Convention.  

The  intra-EU  movement  of  motor  vehicles  displaying  a  professional  registration 
number issued in another Member State is also governed by Articles 34 to 36 TFEU. 
The jurisprudence of the Court of Justice that applies to temporary registration also 
applies  here.  Therefore,  if  a  Member  State  would  impede  the  transit  of  a  motor 
vehicle  carrying  professional  registration  plates  lawfully  issued  in  another  Member 
State, it will infringe Article 34 TFEU, unless the impediment is justified on the basis 
of Article 36 TFEU or one of the mandatory requirements accepted by the Court of 
Justice74.  

The  following  table  established  by  EReg75  gives  an  overview  of  the  professional 
registration systems in some Member States: 

73 
74 

75 

United Nations - Economic Commission for Europe, 8 November 1968, as amended. 
See judgement of the Court of Justice of 2 October 2003, Criminal proceedings against Marco Grilli, 
Case C-12/02. 
Association  of  European  Vehicle  and  Driver  Registration  Authorities,  HTTPS://WWW.EREG-
ASSOCIATION.EU/.  

EN 

133 

   EN 

 
                                                 
PROFESSIONAL (OR ‘COMMERCIAL’) REGISTRATION SYSTEMS (Table 1) 

Country 

Which group of 
persons can receive 
these plates? 

How many systems 
of commercial/ 
professional plates?

Restrictions for the 
use of these plates? 

Different 
registration 
certificates? 

Belgium 

Professionals only 
for different purposes 

2 types :trade and 
test systems 

Restrictions 
concerning 
authorized drivers 
and utilisation 

Same document as 
used for all 
registrations 

Cyprus 

Professionals only 
for different purposes  1 Type only 

Maximum duration 
of 15days 

Different documents 

Denmark 

Estonia 

Professionals only 
for different purposes  1 Type only 

Professionals only 
for different purposes  1 Type only 

Finland 

Professionals only 
for different purposes  1 Type only 

Germany 

Hungary 

Professionals 

1 Type only 

Professionals only 
for different purposes  1 Type only 

Ireland 

Professionals only 
for different purposes  1 Type only 

Latvia 

Professionals only 
for different purposes  1 Type only 

Restrictions 
concerning 
authorized drivers 
and utilisation No 
transports allowed 

Same document as 
used for all 
registrations 

Restrictions 
concerning 
authorized utilisation 
limited to national 
territory 

Same document as 
used for all 
registrations 
additional logbook 
required 

Restrictions 
concerning 
authorized utilisation 

Same format of 
document as used for 
all registrations 

Restrictions 
concerning 
authorized utilisation 

Restrictions 
concerning 
authorized utilisation 
No transports 
allowed 

Different format of 
document additional 
‘Fahrzeugscheinheft’ 
sort of log book 

Different document; 
additional logbook 
required 

Restrictions of the 
times during which 
these plates can be 
used 

No documents 
emitted only 
registration plates 
issued 

Restrictions 
concerning 
authorized utilisation 

Different document 
than normal 
registration 
Certificate  

EN 

134 

   EN 

 
 
Lithuania 

Professionals only 
for different purposes  1 Type only 

Professionals only 
for different purposes  1 Type only 

Professionals only 
for different purposes  1 Type only 

Luxem-
bourg 

Nether-
lands 

Poland 

Restrictions 
concerning 
authorized utilisation 

Different document 
than normal 
registration 
Certificate emitted 
by retailers personnel

Restrictions 
concerning 
authorized utilisation 
and user; maximum 
validity two years  

Same document as 
used for all 
registrations, not 
compliant no vehicle 
id.  

Restrictions 
concerning 
authorized utilisation 
additional 
administration 

Same size document 
but not fully 
harmonised 

No system of 
professional plates 
available 

Not applicable 

Not applicable 

Not applicable 

Romania 

Professionals only 
for different purposes 

2 systems: Probe for 
constructors and big 
dealer; provisional 
for smaller dealers 

Slovakia 

Professionals only 
for different purposes  1 Type only 

Sweden 

Professionals only 
for different purposes  1 Type only 

UK 

Professionals only 
for different purposes  1 Type only 

Restrictions 
concerning 
authorized utilisation 
and territorial 
limitation 

Restrictions 
concerning 
authorized utilisation 
additional 
administration 

Different documents, 
document for Probe 
similar but without 
vehicle details 

Different document 
than normal 
registration 
Certificate  

Restrictions 
concerning 
authorized utilisation 

No special 
registration 
documents issued 

Restrictions 
concerning 
authorized utilisation 

No documents 
emitted only 
registration plates 
with licence issued 

EN 

135 

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PROFESSIONAL (OR ‘COMMERCIAL’) REGISTRATION SYSTEMS (Table 2) 

Country 

Identification of the 
vehicle? 

Bilateral 
agreements with 
other Member 
States? 

General insurance 
cover required? 

Valid technical 
Certificate 
required? 

Benelux agreement 
for the trade plates 

Yes 

Trade plates yes ;test 
plates no 

No 

Yes 

Yes 

No identification of 
the vehicle; engine 
size and maximum 
mass limited 

No identification of 
the vehicle on 
registration 
document but 
mandatory via 
logbook  

No identification of 
the vehicle; different 
plates for different 
types of vehicle 

No identification of 
the vehicle on 
reg.document but 
mandatory via 
logbook  

Belgium 

Cyprus 

Denmark 

Estonia 

Finland 

Agreement Norway 
Sweden Finland 

Yes 

No 

Yes 

No identification of 
the vehicle 

Agreement with 
Nordic countries: 
Sweden; Norway; 
Denmark 

Yes 

No, but plates can 
only be used on 
vehicles that are no 
hazard for road 
safety 

No, but plates can 
only be used on 
vehicles that are no 
hazard for road 
safety 

No, but plates can 
only be used on 
vehicles that are no 
hazard for road 
safety 

Germany  Not on document but 

via log book 

Agreement between 
Netherlands and 
Germany 

Yes 

No 

Hungary 

No identification of 
the vehicle 

No 

Yes 

No, but plates can 
only be used on 
vehicles that are no 
hazard for road 
safety (responsibility 
of the holder) 

Ireland 

No identification of 
the vehicle 

No use outside 
Ireland allowed 

Yes 

No 

EN 

136 

   EN 

 
 
Latvia 

No identification of 
the vehicle 

No 

Yes 

No 

Lithuania 

No identification on 
the document but 
identification of 
vehicle and driver via 
a separate logbook 

No 

Yes 

No 

No identification of 
the vehicle 

Benelux agreement 
for the trade plates 

Yes 

No identification of 
the vehicle 

Benelux agreement 
for the trade plates 
plus agreement with 
Germany for lorries  Yes 

Luxem-
bourg 

Nether-
lands 

Poland 

No but vehicle must 
be in roadworthy 
condition as 
specified in "Code de 
la route" 

Yes must comply 
with so called 
permanent 
requirements, while 
on Dutch roads 

Not applicable 

Not applicable 

Not applicable 

Not applicable 

Romania 

For Probe no 
identification of 
vehicle provisional 
vehicle details on 
document 

No 

Slovakia  No identification of 

the vehicle 

No 

Sweden 

No identification of 
the vehicle; Different 
plates required for 
different types of 
vehicles 

Nordic agreement 
with Finland, 
Denmark and 
Norway 

Yes 

Yes 

No 

No 

Yes 

Not always required 

UK 

No identification of 
the vehicle 

No, only destined for 
UK use 

Yes 

Yes 

EN 

137 

   EN 

 
 
8.4. 

Annex 4: figures and statistics 

8.4.1.  Affected groups 

• 

• 

Citizens  are  in  the  first  to  be  affected  by  re-registration  problems.  As  EU 
integration  proceeds,  more  people  may  wish  to  move  from  one  country  to 
another;  or  to  have  holiday  homes  in  other  Member  States,  leaving  their  cars 
there.  More  than  3  million  people  arrived  for  a  permanent  stay  in  Member 
States  in  2007,  with  more  than  2  million  arriving  in  Spain,  Germany  and  the 
United Kingdom combined. Among the 22 Member States for which data are 
available, some 40% were citizens of another EU Member State, and 12% were 
nationals  returning  to  their  Member  State  of  citizenship.  Returning  nationals 
accounted  for  the  highest  proportion  of  immigrants  in  Bulgaria,  Denmark, 
Estonia,  Lithuania  and  Poland  (permanent  stays  only)  in  2007.  In  Belgium, 
Germany,  Ireland,  Latvia,  Luxembourg,  Malta,  the  Netherlands,  Austria  and 
Slovakia,  the  highest  proportion  of  immigrants  were  citizens  from  other  EU 
Member States76.  

Cross-border  workers  -  and  in  particular  the  persons  using  an  employer's 
company car in another Member State - and employers are also affected by the 
problem. In total, about 780,000 people in the EU (including EEA/EFTA) were 
cross-border  commuters  in  the  year  2006/2007  (including  commuters  using 
other  means  of  transport).  Commuting  streams  are  clearly  condensed  in  the 
area  of  Central-Western  Europe.  For  EU-15/EEA/EFTA  the  total  number  of 
commuters  has  increased  by  26%  from  about  490,000  in  1999/2000  to  about 
660,000  in  2006/2007.  The  main  countries  of  destination  are  Switzerland 
the  Netherlands 
(206,000),  Luxembourg  (127,000),  Germany  (86,000), 
(58,000), Austria (48,000) and Belgium (39,000), together receiving about ¾ of 
all  EU-commuters.  The  main  countries  of  origin  are  France  (284,000), 
Germany  (117.000)  and  Belgium  (78,000),  providing  about  60%  of  all  out-
commuters  in  the  EU77.  For  passengers  car  (M1  motor  vehicles),  company 
registrations accounted for about 50.5% of the 11.6 million new passenger cars 
registered  across  the  18  EU  Member  States  in  200878.  Employers  are  usually 
able  to  purchase  a  company  car  at  lower  costs  than  the  employee.  The 
employer’s advantage comes from the firms greater bargaining power vis-à-vis 
car dealers which results in lower costs for purchasing new cars. Firms which 
operate  fleets  of  passenger  cars  (for  example  distribution  firms)  are  often 
granted  significant  discounts  by  car  dealers.  Next,  corporate  fleet  clients  are 
likely to obtain discounts off list prices for insurance and maintenance. Firms 
will also be able to finance purchases of company cars at a lower cost. Due to 
their scale, firms are more likely to have access to better terms of financing of 
capital  purchases  with  cash  than  individual  employees.  Furthermore  due  to 
larger scale, firms are also likely to obtain better terms for alternative financing 
options, such  as  operating or financial lease arrangements. In this context the 
leasing market is growing.  

76 
77 

78 

Eurostat Yearbook 2010. 
MKW Wirtschaftsforderung GmbH, ‘Scientific Report on the Mobility of Cross-Border Workers within 
the EU-27/EEA/EFTA Countries’, January 2009. 
European Commission, Taxation Papers – Company Car Taxation, 2010.  

EN 

138 

   EN 

 
                                                 
• 

Although  there  are  no  precise  statistics  on  the  intra-EU  trade  of  second-hand 
motor vehicles, the intra-EU flows of second-hand vehicles can be subdivided 
in six groups79: 

– 

– 

– 

– 

– 

– 

Group  1:  With  high  relevance  of  imports  (≥  60%  compared  with  the 
annual registration of new cars) and low relevance (< 15%) of exports are 
BG, CY, CZ, GR, LV, MT, PL, RO and SK. 

Group 2: Imports are of medium relevance (≥ 16%, ≤ 33%) and exports 
of small relevance (≤ 2%) for FI, HU, IE. 

Group 3: DK has both medium imports and medium exports. It is not a 
typical importer or exporter but apparently is simply well integrated. 

Group 4: In the case of BE, NL and SI, imports are of medium relevance 
(≥ 15%, < 30) and exports of high relevance (≥ 60%; ≥ 52% in the case 
of LU). 

Group 5: Imports are of low relevance (< 15%) in the case of AT, DE, 
ES,  FR,  IT,  PT,  SE  and  UK.  Germany,  with  its  high  share  of  exports 
(55%), is somewhat an exception in this group. 

Group  6:  LT  is  seemingly  an  exception  as  it  appears  to  be  a  shipment 
centre  with  high  imports  from  EU  27  and  high  exports  to  extra-EU 
countries; in terms of net imports (around 155%) it is in the range of LV 
and GR. 

A  study  made  by  Car-Pass80  provides  the  following  elements  regarding  the 
second-hand car market, principally in Belgium, Luxemburg, Germany, France 
and the Netherlands: 

– 

The  European  used  car  market  might  look  like  a  market  without  trade 
barriers  and  therefore  seem  potentially  perfect.  In  reality,  the  market  is 
very untransparent and in fact still relatively small. It is very difficult to 
trace  the  history  of  a  car  imported  from  another  member  state  and 
therefore  evaluate  precisely  the  real  value  of  that  car.  The  high  cost  of 
searching  for  information,  hinders  the  development  of  a  truly  pan-
European  used  car  market.  Not  only  do  consumers  face  this  lack  of 
information, but automotive professionals do as well. The European used 
car market is characterized by a high level of information asymmetry.  

– 

The used car market is increasingly European, but used car flows do not 
automatically go from low value countries to high value countries; there 
are  also  flows  of  cars  in  the  opposite  direction.  There  is  no  single 

79 

80 

EN 

e.v., 

European 

Öko-Institut 
(HTTP://WWW.OEKO.DE/OEKODOC/1114/2011-005-EN.PDF)  
Impact  study  of  mileage  fraud  with  used  cars  &  Adaptability  of  the  Car-Pass  model  in  other  EU-
countries  (Brussels,  October  2010),  HTTP://WWW.CAR-PASS.BE/DOCS/CAR-PASS-STUDY-FINAL-
REPORT.PDF.  

second-hand 

analysis, 

market 

car 

2011 

139 

   EN 

 
                                                 
– 

– 

European used car buyer profile, and market needs are different in every 
country. 

Another used car market dynamic is the difference in car density within 
the  different  EU  countries.  This  market  saturation  is  a  key  driver  for 
cross border used car transactions. If one takes a closer look at the market 
figures,  one  can  consider  the  newer  Member  States  as  being  “low 
density”  and  non-saturated  markets.  Car  density  is  an  important  factor 
that explains the way consumers purchase a (used) car. In countries with 
a  low  density,  many  consumers  need  to  fulfil  their  basic  need  for 
transportation.  Due  to  improving  economic  conditions  and  a  growing 
need  for  more  mobility,  these  customers  are  also  increasing  their  needs 
for comfortable, luxurious transportation. In the automotive industry, the 
newer Member States are considered growing markets for both the new 
and  used  cars.  Since  the  average  citizen  in  these  countries  has  a  lower 
available  income  than  those  in  western  countries,  used  car  demand  is 
considerably  higher  than  the  demand  for  a  new  car.  However,  these 
countries lack a natural supply of used cars. Their economic development 
started much later than in other EU countries. Consequently, the current 
car  pool  is  smaller  and  the  possibility  to  source  used  cars  from  the 
national  supply  is  low.  The  import  of  used  cars  is  a  logical  step  to 
balance supply and demand. Many people want to experience the western 
lifestyle, which includes owning a relatively new car. The ideal used car 
in upcoming markets has the same characteristics as those that consumers 
desire in Western European countries (low mileage, high specification). 

The second-hand market is sourced by private consumers, business users, 
leasing  companies  and  rental  companies.  Private  consumers  normally 
drive  lower  mileage.  Small  business  users  may  buy  the  more  luxurious 
cars, whereas leasing companies supply the more “bread and butter cars” 
to  the  used  car  market.  Rental  companies  supply  a  separate  segment  of 
used cars, the nearly new ones. In many cases, rental cars are returned to 
the  manufacturer  or  dealer  after  only  a  short  period  of  use  (average  9 
months), on so-called buy-back agreements. When looking closer at the 
rental  companies,  the  cars  they  put  into  operation  and  return  to 
manufacturers  are  frequently  seen  as  an  oversupply  of  relatively  new 
used  cars,  putting  used  car  prices  under  pressure.  Their  numbers  are 
relatively high and they warrant the manufacturers a high(er) production 
capacity utilisation. In the used car markets, these ex-rental cars directly 
compete  with  younger  used  cars  of  consumers  or  even  new  cars.  Their 
volumes  are  able  to  put  used  car  prices  under  more  pressure  in  already 
saturated used car markets.  

• 

Leasing  companies  were  founded  by  car  manufacturers  and  retailers  to 
stimulate the sales of new cars and after sales. The leasing sector is divided by 
the so-called “captive” lease company, a subsidiary from and owned by the car 
manufacturer, and the “non-captive” leasing company, which is in the hands of 
banks  and  private  ownership.  The  capital  intensity  has  led  to  a  high 
involvement  of  financial  institutions  in  this  segment.  Leasing  companies 
optimize the costs of depreciation, insurance, maintenance and repairs based on 
a  given  mileage  per  year;  in  most  cases,  they  are  also  the  riskbearer  of  these 

EN 

140 

   EN 

 
costs. Leasing companies have become big suppliers of the used car markets, 
both on a national and international level. 

In  theory,  leasing  companies  could  face  similar  problems  as  cross-border 
workers, at least if they are the holder of the registration certificate and when 
the vehicle is used by a person established in another Member State. Leasing 
firms retain the ownership of the leased motor vehicles throughout the life of 
the  contract  whereby  they  convey  to  the  lessee,  in  return  for  a  payment  or 
series of payments, the right to use the motor vehicle for an agreed period of 
time81. Leasing firms usually also offer long term automotive rental contracts. 
This  is  a  specific  kind  of  leasing,  whereby  businesses  outsource  their  vehicle 
fleet needs to a leasing company which provides the necessary passenger cars, 
vans or trucks to the client, along with any required related services, including 
maintenance, 
replacements. 
Automotive assets, i.e. passenger cars and commercial vehicles, accounted for 
about  55%  (€124.1  billion)  of  total  new  leasing  contracts  agreed  in  2010, 
remaining the largest individual asset segment of the European leasing market. 
It  is  estimated  that  European  leasing  companies  financed  some  5.8  million 
passenger  cars  in  2010.  New  leasing  volumes  for  commercial  vehicles  also 
increased,  albeit  at  a  somewhat  slower  rate  than  for  passenger  cars,  gaining 
2.8% in 2010 to reach new leasing volumes of €34.9 billion82. 

fuel  management  and/or 

insurance, 

tyre 

There are indications that employers increasingly rely on leasing arrangements 
rather  than  ownership  when  providing  cars  to  their  employees.  Essentially,  it 
changes  nothing  vis-à-vis  the  employee.  In  a  leasing  arrangement,  the  firm 
deducts the annual fee from its gross income while with a company owned car 
it directly deducts costs of financing, depreciation, insurance, motoring taxes, 
maintenance  and  period  repairs.  Provided  that  the  company  and  the  leasing 
company face the same costs, then it changes nothing vis-à-vis the employee. 
Obviously, the firms use leasing contracts rather than ownership because it is 
more  efficient:  a  leasing  company  can  exploit  market  power  and  knowledge 
better  than  particularly  smaller  firms  thus  reducing  costs  of  purchase  and 
maintenance. 

• 

Car-rental  companies  are  equally  affected  by  the  problem  but  in  a  very 
different  manner.  These  companies  rent  out  motor  vehicles  to  private  or 
professional clients for a relatively short period of time in order to meet their 
respective  transport  needs.  Besides  the  traditional  car-rental  services  (as  a 
means  of  transport  to  complete  a  train  or  plane  journey  or  as  a  replacement 
vehicle), truck rental is a growing sector. The EU fleet for short-term rental is 
estimated  at  1.4  million  vehicles,  split  into  about  1  million  cars  and  400,000 

81 

82 

According to IAS 17.4, a lease is classified as a finance lease if it transfers substantially all the risks and 
rewards incident to ownership. All other leases are classified as operating leases. Classification is made 
at  the  inception  of  the  lease.  Whether  a  lease  is  a finance  lease  or  an  operating  lease  depends  on  the 
substance of the transaction rather than the form. Situations that would normally lead to a lease being 
classified  as  a  finance  lease  are,  for  example,  when  the  lease  transfers  ownership  of  the  asset  to  the 
lessee by the end of the lease term, or when the lessee has the option to purchase the asset at a price 
which  is  expected  to  be  sufficiently  lower  than  fair  value  at  the  date  the  option  becomes  exercisable 
that, at the inception of the lease, it is reasonably certain that the option will be exercised [IAS 17.10].  
HTTP://WWW.LEASEUROPE.ORG/INDEX.PHP?PAGE=KEY-FACTS-FIGURES.  

EN 

141 

   EN 

 
                                                 
light commercial vehicles. Car-rental fleets are usually very new, in particular 
for large cross-border companies, as vehicles remain in the fleet for about 6-9 
months, and are subsequently bought back by manufacturers. 

The  total  number  of  car  leasing  firms  and  car  rental  companies  acting  in  the 
segment of passenger cars (M1) and light duty motor vehicles (N1) is estimated 
at  around  23,000.  Almost  the  totality  of  the  sector  is  composed  by  SMEs 
(99.8%).  Only  75  are  large  enterprises  (250  or  more  employees)83.  Total 
employment in this sector is around 160,000 workers. The biggest percentage 
of companies is located in France, United Kingdom, Germany, Spain, Italy and 
Czech Republic (66% of the total). The car-leasing fleet in 2010 was around 14 
million  vehicles,  representing  about  5%  of  the  total  number  of  vehicles 
registered in the EU. The leasing market is a highly concentrated market. The 
10  largest  enterprises  across  Europe  have  a  market  share  of  more  than  70%. 
The short term rental fleet is estimated at around 1.5 million in 2010 (0.5% of 
the total EU vehicle fleet). 75% correspond to passenger vehicles and the rest 
to commercial vehicles. Only 3 to 4 car-rental enterprises have a fleet of more 
than  100,000  vehicles,  whilst  95%  of  enterprises  manage  a  fleet  of  less  than 
1,000 vehicles. The car-rental sector is estimated to carry out around 90 million 
transactions per year84.  

8.4.2.  Background statistics 

8.4.2.1.  Methodological remarks  

Statistics on intra-EU trade of car are used as a proxy for figures of de-registration 
and  re-registration  of  vehicles  transferred  between  EU  Member  States.  They 
represent  the  most  accurate  source  on  this  issue.  These  figures  are  based  in  the 
Comext  database  from  EUROSTAT.  This  could  lead  to  underestimations  because 
there  are  reporting  thresholds  under  which,  the  economic  operators  don’t  have  to 
report. Additionally, there are cars that cross-EU borders without complying with the 
registration  formalities.  Therefore,  figures  about  numbers  of  vehicles  used  in  this 
report  should  be  considered  as  a  conservative  estimate,  as  more  transfers  and 
therefore de-registration and re-registrations may be occurring every year. 

Some figures in this annex are based on the answers to the questionnaire submitted 
by  the  National  Registration  Authorities,  and  a  study  of  the  2nd-hand  car  market 
carried out at the request of the Commission85.  

Total number of de- and re-registration is not the same for businesses and citizens. 
This  can  happen  when  a  motor  vehicle  is  de-registered  by  a  company  and  re-
registered by (or on  behalf of) a citizen. This is quite a common phenomenon, e.g. 
when  leasing  companies  sell  their  fleet  on  the  2nd  hand  market  after  the  leasing 
period has expired. The split among de- and re-registrations by citizens or businesses 
is  based  on  an  extrapolation  of  detailed  information  provided  by  7  national 
registration authorities. 

83 
84 
85 

Eurostat 
Source : LeaseEurope 
Öko-Institut  e.V.,  Transport  and  Mobility  Leuven,  COWI  (2011)  European  second-hand  car  market 
analysis Final Report 

EN 

142 

   EN 

 
                                                 
M1 refers to passenger cars and N1 to light motor vehicles. 

The baseline scenario reflects the current situation. It is based on the most recently 
available  data  (although  it  was  not  possible  to  have  a  single  data-year)  and 
combining both hard and soft data, i.e. statistical databases, direct enquiries with the 
stakeholders, the public consultation, and a survey of several Member States. 

EN 

143 

   EN 

 
8.4.2.2.  Car registrations in the EU  

Table 1 - Passenger cars (thousand) 

2005 

2006 

2007 

2008 

2009 

EU27 

BE 

BG 

CZ 

DK 

DE 

EE 

IE 

EL 

ES 

FR 

IT 

CY 

LV 

LT 

LU 

HU 

MT 

NL 

AT 

PL 

PT 

RO 

SI 

SK 

FI 

SE 

UK 

HR 

MK 

TR 

IS 

NO 

CH 

LI 

220.223 
4 919 
2 538 
3.959 
1.965 
40 660 
 494 
1.684 
4 303 
20 250 
30 497 
34 667 
 355 
 742 
1 455 
 307 
2 889 
 213 
7 092 
4 157 
12 339 
4 200 
3 364 
 960 
1 304 
2 430 
4.154 
28 326 
1 385 
253 
5 773 
 187 
2 029 
3 861 
 24 

224.455  
4 976 
1 768 
4.109 
2.020 
41 020 
 554 
1.802 
4 543 
20 909 
31 002 
35 297 
 373 
 822 
1 592 
 315 
2 954 
218 
7 230 
4 205 
13 384 
4 290 
3 603 
 980 
1 334 
2 506 
4.202 
28 447 
1 436 
242 
6 141 
 197 
2 084 
3 900 
 24 

229.536  
5.049 
2.082 
4.280 
2.068 
41.184 
524 
1.910 
4 799 
21 760 
31 443 
35 680 
411 
905 
1 588 
322 
3.012 
225 
7.392 
4.246 
14.589 
4.379 
3.541 
1.014 
1.434 
2.570 
4.258 
28.873 
1.491 
249 
6.472 
 208 
2 155 
3 956 
 24 

233.852 
5 131 
2 366 
4.423 
2.099 
41 321 
 552 
1.953 
5 024 
22 145 
31 109 
36 105 
 444 
 933 
1 671 
 329 
3 055 
229 
7 542 
4 285 
16 080 
4 408 
4 027 
1 045 
1 545 
2 700 
4 279 
29 050 
1 535 
263 
6 797 
 210 
2 197 
3 990 
 25 

236.147  
5 193 
2 502 
4.435 
2.120 
41 738 
 546 
1.931 
5 132 
21 983 
31 394 
36 477 
 461 
 904 
1 695 
 332 
3 014 
235 
7 622 
4 360 
16 495 
4 457 
4 245 
1 059 
1 589 
2 777 
4 301 
29 152 
1 533 
282 
7 094 
 205 
2 244 
4 010 
 26 

Source: national statistics, United Nations Economic Commission for Europe, Eurostat 

EN 

144 

   EN 

 
 
 
Table 2- Buses and coaches (thousand) 

2005 

2006 

2007 

2008 

2009 

790,3 
15,4 
37,8 
20,9 
14,4 
75,2 
5,2 
7,6 
26,8 
58,2 
90,1 
94,4 
3,2 
10,6 
15,3 
1,3 
17,5 
1,1 
11,0 
9,3 
79,6 
14,7 
39,3 
2,3 
9,1 
10,9 
13,5 
105,6 
4,9 
2,3 
501,9 
1,9 
28,8 
45,8 
0,1 

790,9 
15,3 
22,8 
21,1 
14,6 
75,1 
5,4 
8,0 
26,9 
59,1 
92,2 
96,1 
3,2 
10,6 
15,6 
1,4 
17,7 
1,1 
10,8 
9,3 
83,5 
15,0 
40,4 
2,3 
8,8 
11,2 
13,6 
109,7 
4,9 
2,2 
533,5 
1,9 
27,0 
46,4 
0,1 

797,6 
15,5 
23,9 
21,2 
14,5 
75,1 
4,3 
8,5 
27,1 
61,0 
94,4 
96,4 
3,3 
10,6 
14,5 
1,5 
17,9 
1,2 
11,1 
9,3 
87,6 
15,1 
34,2 
2,3 
10,5 
11,5 
13,3 
111,9 
5,0 
2,3 
561,7 
1,9 
25,2 
48,0 
0,1 

816,7 
16,0 
25,2 
21,1 
14,5 
75,3 
4,3 
8,9 
27,2 
62,2 
92,9 
97,6 
3,4 
10,5 
14,3 
1,5 
18,0 
1,2 
11,3 
9,4 
92,4 
15,4 
41,5 
2,4 
10,5 
12,3 
13,5 
114,0 
5,1 
2,3 
583,5 
2,0 
23,3 
48,5 
0,1 

823,9 
16,1 
25,1 
20,7 
14,5 
76,4 
4,1 
8,6 
27,3 
62,7 
95,8 
98,6 
3,4 
9,7 
13,8 
1,6 
17,7 
1,2 
11,7 
9,6 
95,4 
15,5 
41,2 
2,4 
9,4 
13,0 
13,4 
115,0 
5,1 
2,5 
585,1 
1,9 
21,5 
50,7 
0,1 

EU27 
BE 
BG 
CZ 
DK 
DE 
EE 
IE 
EL 
ES 
FR 
IT 
CY 
LV 
LT 
LU 
HU 
MT 
NL 
AT 
PL 
PT 
RO 
SI 
SK 
FI 
SE 
UK 
HR 
MK 
TR 
IS 
NO 
CH 
LI 

Source: national statistics, United Nations Economic Commission for Europe, Eurostat 

EN 

145 

   EN 

 
 
Table 3- Goods vehicles (thousand) 

2005 

2006 

2007 

2008 

2009 

31.177,1 
652,1 
333,9 
439,2 
469,5 
2.404,9 
86,2 
286,5 
1.186,5 
4.849,6 
5.346,7 
4179,7 
118,4 
113,1 
122,5 
29,6 
427,6 
44,4 
1.004,5 
358,0 
2.304,5 
1.308,0 
493,8 
66,4 
174,2 
363,6 
461,2 
3.552,4 
162,9 
18,0 
2.152,0 
25,5 
465,4 
307,2 
2,6 

32.030,1  
670,4 
226,1 
490,9 
508,8 
2.471,2 
92,9 
318,6 
1.219,9 
5.087,3 
5.344,8 
4331,7 
115,7 
121,1 
135,5 
30,7 
444,4 
45,5 
995,7 
364,3 
2.392,7 
1.320,0 
545,3 
70,1 
189,3 
376,1 
479,8 
3.641,1 
169,7 
17,0 
2.405,2 
28,1 
488,6 
314,0 
2,5 

33.138,3 
690,7 
261,3 
554,8 
536,6 
2.503,0 
80,3 
345,9 
1.255,9 
5.353,3 
5.476,0 
4437,6 
117,5 
129,6 
147,6 
32,5 
459,4 
46,9 
1.010,4 
372,6 
2.520,5 
1.333,0 
502,0 
77,6 
215,7 
394,7 
504,1 
3.778,7 
176,7 
16,6 
2.619,7 
31,1 
513,7 
324,2 
2,6 

33.675,3 
711,9 
299,2 
607,4 
531,4 
2.523,6 
83,4 
351,3 
1.289,5 
5.405,6 
5.212,0 
4534,7 
121,8 
129,8 
150,1 
34,4 
470,8 
48,2 
1.025,9 
381,3 
2.709,7 
1.335,0 
645,3 
83,9 
248,7 
424,5 
510,2 
3.805,8 
180,3 
17,3 
2.810,2 
31,8 
523,4 
326,2 
2,7 

33.840,4 
724,1 
317,8 
601,8 
507,9 
2.556,0 
81,1 
343,9 
1.302,4 
5.342,9 
5.238,6 
4589,1 
124,1 
120,6 
146,3 
34,7 
466,7 
47,8 
1.017,3 
388,0 
2.796,8 
1.337,0 
661,9 
83,6 
269,3 
443,9 
514,6 
3.782,1 
164,8 
18,4 
2.932,3 
30,9 
524,2 
327,8 
2,7 

EU27 
BE 
BG 
CZ 
DK 
DE 
EE 
IE 
EL 
ES 
FR 
IT 
CY 
LV 
LT 
LU 
HU 
MT 
NL 
AT 
PL 
PT 
RO 
SI 
SK 
FI 
SE 
UK 
HR 
MK 
TR 
IS 
NO 
CH 
LI 

Source: national statistics, United Nations Economic Commission for Europe, estimates 

EN 

146 

   EN 

 
 
Table 4- Two-wheelers (thousand) 

2005 

2006 

2007 

2008 

2009 

346,3 
146,5 
794,0 
171,9 
5.202,9 
10,2 
34,3 
1.124,2 
4.117,6 
2.475,3 
9.298,4 
40,4 
32,5 
24,0 
37,7 
122,7 
12,0 
1.112,9 
627,7 
1.091,2 
588,4 
197,4 
48,7 
56,4 
301,8 
453,1 
1.235,0 
128,4 
1,7 
1.441,1 
4,2 
257,5 
770,3 
3,1 

359,8 
76,3 
822,7 
184,0 
5.405,9 
12,6 
34,9 
1.205,8 
4.437,6 
2.543,6 
9.338,8 
40,4 
36,9 
25,5 
38,6 
130,2 
12,3 
1.279,7 
645,3 
1.190,1 
558,7 
194,0 
53,2 
58,1 
338,4 
497,7 
1.239,6 
143,5 
3,4 
1.822,8 
5,7 
268,5 
783,5 
3,2 

374,7 
90,3 
860,1 
197,2 
5.550,0 
14,8 
37,2 
1.298,7 
4.741,8 
3.740,0 
9.280,3 
41,2 
44,4 
35,3 
39,5 
135,9 
12,8 
1.371,6 
667,6 
1.350,8 
536,6 
56,5 
71,5 
63,9 
376,5 
528,1 
1.280,3 
162,7 
4,4 
2.003,5 
8,1 
282,5 
788,7 
3,3 

388,3 
106,9 
892,8 
204,8 
5.852,3 
17,6 
39,4 
1.388,6 
4.911,5 
3.857,0 
9.609,1 
43,2 
51,3 
45,6 
40,3 
141,5 
14,4 
1.479,5 
691,2 
1.607,3 
535,0 
71,8 
82,0 
70,3 
421,5 
553,9 
1.305,6 
183,8 
8,6 
2.181,4 
9,0 
296,4 
804,1 
3,4 

403,9 
117,6 
903,3 
205,2 
5.866,8 
18,6 
39,6 
1.448,9 
4.958,9 
3.532,0 
10.074,1 
42,7 
52,0 
51,4 
41,3 
142,0 
14,5 
1.579,1 
712,1 
1.808,7 
533,3 
80,0 
88,4 
55,4 
456,2 
571,9 
1.306,8 
184,5 
9,1 
2.303,3 
9,4 
306,8 
806,6 
3,6 

BE 
BG 
CZ 
DK 
DE 
EE 
IE 
EL 
ES 
FR 
IT 
CY 
LV 
LT 
LU 
HU 
MT 
NL 
AT 
PL 
PT 
RO 
SI 
SK 
FI 
SE 
UK 
HR 
MK 
TR 
IS 
NO 
CH 
LI 

Source: national statistics, Association des Constructeurs Européens de Motocycles (ACEM), 
Eurostat 

EN 

147 

   EN 

 
 
Table 5- Estimation of Number of new vehicle registrations (M1 and N1), 2010 

MS 

DE 
FR 
UK 
IT 
ES 
BE 
NL 
PL 
AT 
SE 
PT 
CZ 
DK 
EL 
FI 
RO 
IE 
SK 
SI 
HU 
LU 
BG 
EE 
LT 
LV 
EU 

2006 
3,772,394 
2,498,946 
2,734,360 
2,598,075 
1,953,134 
598,220 
568,683 
295,008 
347,387 
329,960 
265,174 
183,631 
226,350 
294,060 
166,630 
297,162 
225,723 
83,519 
67,836 
209,280 
55,512 
42,440 
30,754 
21,744 
30,443 
17,896,425 

New vehicle registrations 
2008 
3,425,039
2,573,713
2,485,258
2,423,606
1,362,586
617,223
604,057
401,232
336,000
301,459
275,119
215,451
191,611
292,865
161,243
324,091
185,620
102,378
81,631
174,837
58,405
55,236
29,000
28,885
24,085
16,730,630

2007 
3,482,279
2,584,035
2,799,619
2,776,018
1,939,298
606,459
602,810
372,278
339,691
358,722
276,606
207,038
226,219
306,875
147,462
366,818
236,353
89,094
78,398
193,581
56,647
51,739
37,480
31,090
39,690
18,206,299

2009 
4,049,353 
2,718,599 
2,222,542 
2,357,709 
1,074,222 
539,625 
451,348 
372,142 
350,429 
247,513 
203,760 
186,790 
131,786 
237,118 
100,795 
147,962 
68,031 
92,761 
63,286 
70,808 
51,462 
29,247 
11,489 
8,918 
6,244 
15,793,939 

2010 
3,198,416
2,708,883
2,293,576
2,161,087
1,114,119
611,340
544,733
387,050
362,449
333,747
272,775
184,548
172,380
153,842
121,564
119,284
99,988
73,829
66,871
55,221
53,993
20,553
12,203
10,369
7,534
15,140,354

Source: ACEA, 2011. Data for Malta and Cyprus not available

EN 

148 

   EN 

 
Table 6- Estimation of De-Registrations and Re-Registrations in intra-EU transfers of M1 
and N1 vehicles, 2010 

Re-registrations
31,558
170,824
153,868
9,054
207,240
181,221
42,790
15,085
404,019
82,296
25,022
99,572
29,065
56,910
65,280
256,537
16,933
41,396
901
93,495
1,123,583
10,925
225,936
24,390
20,269
102,835
8,996
3,500,000
Source: elaboration on data from study of the 2nd hand car market for DG Climate Action

De-registrations
68,804
213,727
306
94
3,548
1,697,641
56,309
2,363
465
269,133
1,380
271,858
1,642
1,023
423,857
9,648
31,044
1,076
122
309,103
7,385
2,792
48,211
17,968
2,650
1,115
56,736
3,500,000

MS  
AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
EU 

EN 

149 

   EN 

 
8.4.2.3.  Car-rental and leasing sector 

Table 8 - Number of employees in Renting and Leasing Cars companies (NACE code 77.11), 
2008 

Number of employees in renting and car leasing companies 
AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 
IE 

2,625
2,907
1,725
1,024
2,144
24,364
1,403
751
4,222
17,759
1,038
19,288
2,770
1,858

IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
EU 

10,292 
1,308 
312 
1,384 
1,024 
7,144 
4,090 
3,840 
2,256 
2,225 
213 
1,239 
43,634 
162,839 

Source: own elaboration on Eurostat data 

Table 9- Estimated fleet size in the car-leasing sector, 2009 

MS 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 
IE 

Estimate total 
number of 
passenger cars 
(M1) 

420,000
400,000
100,000
9,500
220,000
2,600,000
40,000
100,000
30,000
520,000
200,000
1,380,000
330,000
75,000

MS 

IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
EU 

Estimate total 
number of 
passenger cars 
(M1) 

700,000 
85,000 
30,000 
70,000 
3,500 
650,000 
305,000 
300,000 
280,000 
450,000 
90,000 
135,000 
4,400,000 
13,923,000 

Source: extrapolation of Leaseurope data 

Table 9- Estimated fleet size in the car-leasing sector, 2009 

EN 

150 

   EN 

 
MS 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
EU 

Estimate total number of passenger cars (M1) 

420,000
400,000
100,000
9,500
220,000
2,600,000
40,000
100,000
30,000
520,000
200,000
1,380,000
330,000
75,000
700,000
85,000
30,000
70,000
3,500
650,000
305,000
300,000
280,000
450,000
90,000
135,000
4,400,000
13,923,000

Source: extrapolation of Leaseurope data 

EN 

151 

   EN 

 
Table 10 – Estimated fleet size in the car-rental sector (M1 and N1 vehicles), 2009 

MS 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
EU 

M1 vehicles  

N1 vehicles 

Total fleet size (M1 + N1) 

8,700
14,851
4,000
1,531
6,900
153,000
19,978
417
12,600
168,452
9,500
170,000
10,400
34,700
115,000
1,117
2,349
466
3,000
29,790
10,100
52,600
4,000
21,100
1,500
1,500
200,146
1,057,697

2,921
949
1,343
514
2,317
41,000
7,059
140
4,230
56,557
3,190
45,000
3,492
11,650
6,100
375
789
156
1,007
11,572
3,391
17,660
1,343
7,084
504
504
124,270
355,117

Source: extrapolation of Leaseurope data 

11,621
15,800
5,343
2,045
9,217
194,000
27,037
558
16,830
225,009
12,690
215,000
13,892
46,350
121,100
1,492
3,138
622
4,007
41,362
13,491
70,260
5,343
28,184
2,004
2,004
324,416
1,412,813

EN 

152 

   EN 

 
Table 11- Short term rental companies per fleet size 

SIZE 
Large enterprises with 100,000 or more vehicles 
Enterprises with 50,000 to 100,000 vehicles 
Enterprises with 1,000 to 50,000 vehicles 
Enterprises with less than 1,000 vehicles 

ENTERPRISES 
3 to 4 enterprises 
5 to 10 enterprises 
about 4% 
At least 95% of all rental enterprises 

Source: extrapolation of Leaseurope data 

8.4.3.  Economic Impacts  

8.4.3.1.  Methodology and assumptions 

In  this  case,  the  usual  discrimination  among  administrative  costs,  business-as-usual 
costs,  and  administrative  burdens  is  not  fully  appropriate.  Indeed,  all  costs  are  not 
business-as-usual,  as  citizens  and  companies  re-register  their  car  not  to  respond  to 
any  need  of  their  own,  but  only  because  of  the  legal  provisions.  Therefore, 
throughout  the  analysis  the  term  “burdens”  is  used  to  represent  both  administrative 
costs and administrative burdens, and the business-as-usual factor is always assumed 
to be 0%.  

For the baseline scenario, the duration of every step of the procedure for each vehicle 
has  been  estimated  based  on  the  results  of  a  survey  carried  out.  An  estimated  time 
across different Member States has been calculated based on the data. For steps that 
are  not  carried  out  in  every  de-  and  re-registration  procedure  in  every  country,  the 
assessment  of  the  weight  of  each  step  in  the  procedure  is  considered.  Where 
appropriate, out-of-pocket costs (fees) paid during the procedure is also estimated. 

Time per occurrence is comparable between citizens and companies, as most of the 
procedures are exactly the same for both categories. Nevertheless, the survey shows 
a  lower  time  for  companies,  probably  due  to  the  fact  that  most  citizens  do  this 
procedure once in a lifetime, whilst companies enjoy some, albeit limited, economies 
of learning. 

In  the  calculation  of  the  time  of  the  procedure  for  registration  authorities,  for 
methodological reason, the time of a “normally efficient” registration authority was 
estimated.  It  means  that  possible  complications  and  waste  of  time  due  to  non-
efficient  application  of  the  legislative  framework  or  to  non-cooperation  could  not 
constitute  proper  administrative  burdens  on  national  authorities.  For  this  reason,  a 
methodologically  correct  assessment  of  administrative  burdens  for  national 
authorities does not constitute a full estimate of the time actually spent, which could 
possibly be higher. 

8.4.3.2.  Impact on administrative costs 

On the basis of the information about the various steps of the de-registration and re-
registration procedures in all Member States analysed in annex 3, as well as on the 
basis  of  questionnaires  and  interviews  with  stakeholders,  the  average  duration  of 
every  step  of  the  procedures  has  been  estimated  in  order  to  use  it  in  the  Standard 
Costs model. Cost per occurrence was calculated by applying the appropriate salary 
rate.  For  citizens,  the  average  hourly  labour  costs  in  the  business  economy  of  full-

EN 

153 

   EN 

 
time employees retrieved from Eurostat, has been used. For businesses and national 
registration  authorities,  the  average  salary rate  (including  overheads)  of  a  clerk  has 
been identified from the EU database on Administrative Burdens.  

The number of occurrences is the total number of de- and re- registrations carried out 
by both citizens and businesses in the different Member States.  

Table 12 – Costs per occurrence 

Average 
hourly 
salary 
rate 

(Eurostat) 

€ 27.57 
€ 37.12 
€ 2.89 
€ 13.38 
€ 9.15 
€ 29.15 
€ 36.29 
€ 7.55 
€ 17.79 
€ 20.12 
€ 29.53 
€ 32.37 
€ 7.35 
€ 28.19 
€ 24.53 
€ 5.72 
€ 31.72 
€ 6.05 
€ 8.31 
€ 29.38 
€ 6.75 
€ 11.90 
€ 4.02 
€ 33.47 
€ 13.74 
€ 8.19 
€ 19.21 

- 

Citizen 

Cost per 
occurrence 
– 
De-
Registration 
€ 243.05 
€ 301.59 
€ 91.93 
€ 156.13 
€ 130.22 
€ 252.71 
€ 296.48 
€ 120.43 
€ 183.15 
€ 197.44 
€ 255.05 
€ 272.47 
€ 119.20 
€ 246.87 
€ 224.46 
€ 109.23 
€ 268.47 
€ 111.26 
€ 125.11 
€ 254.13 
€ 115.57 
€ 147.08 
€ 98.82 
€ 279.18 
€ 158.35 
€ 124.37 
€ 191.83 
€ 248.80 

Cost per 
occurrence
–  
Re-
Registration
€ 338.05
€ 420.93
€ 124.10
€ 215.00
€ 178.31
€ 351.74
€ 413.70
€ 164.45
€ 253.26
€ 273.47
€ 355.05
€ 379.71
€ 162.71
€ 343.46
€ 311.73
€ 148.59
€ 374.05
€ 151.46
€ 171.07
€ 353.74
€ 157.56
€ 202.19
€ 133.86
€ 389.21
€ 218.13
€ 170.03
€ 265.54
€ 187.47

MS 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
EU 

Clerk 
Salary 
rate

(EU AB 
database)

€ 22
€ 23
€ 1
€ 10
€ 5
€ 25
€ 28
€ 4
€ 12
€ 13
€ 21
€ 21
€ 5
€ 25
€ 20
€ 3
€ 28
€ 4
€ 9
€ 22
€ 5
€ 10
€ 4
€ 23
€ 10
€ 3
€ 24

-

Business 

Cost per 
occurrence 
–  
De-
Registration
€ 192.63
€ 198.02
€ 79.58
€ 128.03
€ 101.12
€ 208.78
€ 224.93
€ 95.73
€ 138.80
€ 144.18
€ 187.25
€ 187.25
€ 101.12
€ 208.78
€ 181.87
€ 90.35
€ 224.93
€ 95.73
€ 122.65
€ 192.63
€ 101.12
€ 128.03
€ 95.73
€ 198.02
€ 128.03
€ 90.35
€ 228.20
€ 194.72

Cost per 
occurrence 
– 
Re-
Registration 
€ 266.38 
€ 273.99 
€ 106.61 
€ 175.08 
€ 137.04 
€ 289.21 
€ 312.03 
€ 129.43 
€ 190.30 
€ 197.91 
€ 258.78 
€ 258.78 
€ 137.04 
€ 289.21 
€ 251.17 
€ 121.83 
€ 312.03 
€ 129.43 
€ 167.48 
€ 266.38 
€ 137.04 
€ 175.08 
€ 129.43 
€ 273.99 
€ 175.08 
€ 121.83 
€ 281.60 
€ 200.46 

Registration Authorities 
Cost per 
Cost per 
occurrence
occurrence 
– 
– 
Re-
De-
Registration
Registration
€ 34.94
€ 13.31
€ 36.53
€ 13.92
€ 1.59
€ 0.61
€ 15.88
€ 6.05
€ 7.94
€ 3.03
€ 39.71
€ 15.13
€ 44.47
€ 16.94
€ 6.35
€ 2.42
€ 19.06
€ 7.26
€ 20.65
€ 7.87
€ 33.36
€ 12.71
€ 33.36
€ 12.71
€ 7.94
€ 3.03
€ 39.71
€ 15.13
€ 31.77
€ 12.10
€ 4.77
€ 1.82
€ 44.47
€ 16.94
€ 6.35
€ 2.42
€ 14.30
€ 5.45
€ 34.94
€ 13.31
€ 7.94
€ 3.03
€ 15.88
€ 6.05
€ 6.35
€ 2.42
€ 36.53
€ 13.92
€ 15.88
€ 6.05
€ 4.77
€ 1.82
€ 38.12
€ 14.52
€ 15.65
€ 13.48

Source: own calculations 

Having  estimated  all  the  data  necessary  to  run  the  standard  cost  model,  the  usual 
formula  ∑ × QP
, can be applied. P is Price (time X salary + out-of pocket costs), 
and Q is quantity, the number of vehicles. 

EN 

154 

   EN 

 
 
 
Table 13- Administrative Burdens under the no policy change scenario 

Citizens 

Total 

De-
Registration 
€ 3.010.076
€ 11.602.364
€ 6.368
€ 1.463
€ 337.298
€ 77.222.894
€ 3.005.018
€ 156.492
€ 8.523
€ 5.313.634
€ 323.737
€ 59.259.119
€ 142.904
€ 101.048
€ 9.513.846
€ 969.491
€ 1.500.181
€ 110.096
€ 14.659
€ 14.139.344

De-
Re-
Registration 
Registration 
€ 10.868.179
€ 6.210.525
€ 3.200.449
€ 34.703.588
€ 33.173.967
€ 21.571.603
€ 18.858
€ 17.191.735
€ 17.185.367
€ 10.800
€ 196.117
€ 194.654
€ 28.051.521
€ 96.875
€ 27.714.223
€ 96.345.463 € 290.640.045
€ 19.122.568
€ 10.385.979
€ 17.166.873
€ 14.161.855
€ 101.783
€ 875.914
€ 719.422
€ 10.240.540
€ 58.130
€ 10.232.017
€ 34.923.982
€ 7.564.223
€ 2.250.589
€ 20.667
€ 6.453.729
€ 6.129.992
€ 10.181.085
€ 63.039.989
€ 3.780.869
€ 44.837
€ 3.689.684
€ 3.546.780
€ 128.190
€ 15.737.953
€ 15.636.905
€ 69.376.930
€ 11.548.841
€ 2.034.995
€ 27.271.259
€ 69.735
€ 26.301.769
€ 5.725.857
€ 3.400.273
€ 1.900.092
€ 8.238
€ 4.436.410
€ 4.326.313
€ 162.699
€ 599
€ 148.040
€ 48.825.642
€ 24.061.238
€ 9.921.894
€ 201.635
€ 623.062 € 132.777.953 € 133.401.015
€ 261.948
€ 41.066
€ 321.726
€ 220.882
€ 3.571.400
€ 28.297.132
€ 27.219.439
€ 1.077.693
€ 355.804
€ 12.109.094
€ 7.594.282
€ 4.514.812
€ 91.620
€ 3.622.411
€ 3.316.046
€ 306.365
€ 13.739.404
€ 13.638.188
€ 101.216
€ 27.196
€ 2.589.452
€ 8.946.064
€ 238.880
€ 8.707.184
€ 523.348.833
€ 577.196.021
€ 375.086.067
€ 202.109.954

Business 
Re-
Registration 

€ 5.884.503 
€ 32.762.992 
€ 1.640.356 
€ 1.426.650 
€ 7.100.131 
€ 36.687.433 
€ 2.670.399 
€ 1.386.298 
€ 69.196.306 
€ 14.658.363 
€ 2.007.282 
€ 23.190.141 
€ 995.772 
€ 3.291.773 
€ 14.756.526 
€ 9.688.327 
€ 3.698.514 
€ 1.660.986 
€ 6.039 
€ 17.433.879 
€ 38.494.411 
€ 1.721.460 
€ 2.924.365 
€ 1.336.533 
€ 887.197 
€ 2.756.145 
€ 2.279.910 
€ 300.542.692 

Total 

€ 16.752.682
€ 67.466.580
€ 1.659.215
€ 1.437.449
€ 7.197.006
€ 327.327.478
€ 13.056.378
€ 1.488.081
€ 69.254.437
€ 49.582.345
€ 2.027.950
€ 33.371.225
€ 1.040.609
€ 3.419.963
€ 84.133.456
€ 9.758.062
€ 9.424.371
€ 1.669.224
€ 6.637
€ 66.259.522
€ 38.696.046
€ 2.043.186
€ 6.495.766
€ 1.692.337
€ 978.817
€ 2.783.342
€ 4.869.362
€ 823.891.525

MS 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
EU 

Source: own calculation 

EN 

155 

   EN 

 
MS 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
EU 

Registration Authorities 

De-Registration 

Re-Registration 

Total 

€ 915.777
€ 2.974.007
€ 185
€ 567
€ 10.734
€ 25.676.815
€ 953.879
€ 5.718
€ 3.378
€ 2.116.727
€ 17.529
€ 3.453.957
€ 4.968
€ 15.478
€ 5.128.671
€ 17.511
€ 525.879
€ 2.603
€ 665
€ 4.114.156
€ 22.341
€ 16.892
€ 116.671
€ 250.030
€ 16.035
€ 2.023
€ 823.813
€ 47.187.008

€ 1.102.730
€ 6.240.475
€ 244.393
€ 143.804
€ 1.645.832
€ 7.195.983
€ 1.903.026
€ 95.842
€ 7.700.599
€ 1.699.276
€ 834.613
€ 3.321.234
€ 230.823
€ 2.259.804
€ 2.073.725
€ 1.222.401
€ 753.057
€ 263.002
€ 12.886
€ 3.267.031
€ 8.923.119
€ 173.521
€ 1.435.447
€ 891.008
€ 321.941
€ 490.011
€ 342.922
€ 54.788.506

€ 2.018.506
€ 9.214.482
€ 244.578
€ 144.371
€ 1.656.565
€ 32.872.798
€ 2.856.905
€ 101.559
€ 7.703.977
€ 3.816.003
€ 852.142
€ 6.775.191
€ 235.791
€ 2.275.282
€ 7.202.396
€ 1.239.912
€ 1.278.937
€ 265.605
€ 13.550
€ 7.381.187
€ 8.945.460
€ 190.412
€ 1.552.118
€ 1.141.039
€ 337.976
€ 492.035
€ 1.166.735
€ 101.975.514

8.4.3.3.  Other economic impact: loss of profits 

Citizens and companies bear other additional costs due to the length of the de and re-
registration procedure. In particular, their ability to use their motor vehicle is reduced 
or impaired whilst waiting for the process to be completed. This affects citizens who 
have  to  resort  to  other  transport  solutions  or  to  reduce  their  mobility  and  affects 
vehicle-owning companies even more. 

It is considered that during the de- and re-registration process, the capital of a vehicle 
cannot  be  employed  in  the  production  process  of  a  vehicle-owning  business,  or 
cannot  be  sold  to  the  final  customer  by  a  2nd  hand  trader  or  a  leasing  company. 

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Capital,  and  its  value,  is  locked  in  for  a  certain  period.  Companies  lose  any  added 
value which the capital would produce.  

Estimating  the  loss  of  profits  depends  on  the  sector,  and  even  on  the  enterprise,  in 
which the vehicle is employed. Such a level of detail as exists for vehicle registration 
data is not available. Therefore, we will consider the opportunity cost of capital as a 
proxy for the lost profits. Rational actors would invest in capital input as long as it 
yields  a  higher  productivity  than  the  cost  of  capital.  Therefore,  the  cost  of  capital 
represents the lower level of the loss of productivity. To estimate the cost of capital 
in  case  of  vehicles,  the  leasing  rate  is  used.  This  is  mostly  representative  of  how 
firms manage their fleet, and is invariant to the different source of funding of firms 
(e.g. bank debt, corporate bonds, equity, own resources). The Bank of Italy reported 
that the lease rates for vehicles in the second term of 2011 were equal to 8.32% for 
an amount lower than €25,000, and to 6.96% for an amount higher than €25,00086. 
These data are calculated for national purposes and are not available at EU level, and 
similar  dataseries  are  not  produced  by  the  European  Central  Bank.  Since  Italy 
represents  the  third  national  market  for  leasing  in  the  EU,  and  the  second  in  the 
Eurozone, it is possible to consider these rates as representative of the cost of leasing 
in Europe. Therefore, depending on the average value of vehicles across the different 
segments, lost productivity is estimated using lease rates of 8.32% or 6.96% as cost 
of capital. We assume that the car is unavailable for use for around 1 month.  

Table 14 –Profit loss calculations 

Segment 

Average Value 

Leasing Rate 

Weight 

Large  

F 
E  Upper Medium 
D  Lower Medium 
C  Medium 
B 
Small 
A  Mini 

WEIGHTED AVERAGE 

€ 53,893
€ 31,592
€ 22,000
€ 16,277
€ 11,244
€ 9,702

€ 23.131

6.96% 
6.96% 
8.32% 
8.32% 
8.32% 
8.32% 

7.97% 

0.3 
1.2 
2.2 
1.5 
0.5 
0.05 

Number of re-
registrations by 
businesses 

n.a. 
n.a. 
n.a. 
n.a. 
n.a. 
n.a. 

- 

1,499,273 

86 

HTTP://WWW.BANCADITALIA.IT/MEDIA/COMSTA/2011/TEGM_240311.PDF.  

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Segment 

Large  
Upper Medium 
Lower Medium 
Medium 
Small 
Mini 

F 
E 
D 
C 
B 
A 
WEIGHTED AVERAGE 

Table 15 –profit loss calculations 

Loss of productivity 

€ 469
€ 275
€ 229
€ 169
€ 117
€ 101
€ 225

€ 336,691,336

Source: Copenhagen Economics, Bank of Italy, own analysis 

8.4.3.4.  Other economic impacts on the car-rental sector 

Under the current scenario, there are specific additional impacts for rental companies 
resulting  from  the  nature  of  their  business.  According  to  the  data  provided  by  the 
sector,  car-rental  undertakings  manage  a  fleet  of  1,412,813  vehicles  across  the  EU, 
and conclude about 93,000,000 short-term transactions per year 

As a result of current procedures car-rental companies face high cost barriers for 1-
way  cross-border  rentals,  and  are  unable  to  manage  their  fleet  to  meet  seasonal 
demand peaks. 

1-way  cross-border  rentals  cause  additional  costs  to  the  one  considered  in  the 
previous section: 

Currently,  the  car  can  only  be  rented  to  a  person  with  the  same  nationality  as  the 
number plate of vehicle. Therefore, the companies on most occasions incur the costs 
of  repatriation.  This  is  the  cost  of  transporting  the  vehicle  back  to  the  registration 
country,  or  in  having  the  firm’s  employee  return  the  vehicle  to  the  registration 
country. They depend upon the distance between the country of destination and the 
nearest major city in the country of registration. It is estimated that additional costs 
amount to about €500 per transaction, assuming an additional idle period of 8 days. 

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Table 15 – Examples of prices for cross-border and non-cross-border rental 
transactions 

1 day 

5 day 

Return to  Company 1 
€ 106
Frankfurt 
€ 960
Verona 
€ 854
Difference 
€ 248
Frankfurt 
€ 1,103
Verona 

Company 2 
€ 111
€ 666
€ 555
€ 239
€ 804

Difference 

€ 855

€ 565

Company 3 

Average 

€ 111 
€ 840 
€ 729 
€ 263 
€ 1,000 

€ 737 

€ 109
€ 822
€ 713
€ 250
€ 969

€ 719

These data show that current administrative barriers create costs which are eventually 
borne  by  customers.  Any  simplification  would  therefore  benefit  customers,  who 
currently  bear  the  costs,  and  then  secondly  would  benefit  car-rental  undertakings, 
because of an increase in demand. 

The conservative assumption, for the purpose of this impact assessment, is that only 
1% of short-term rental transactions are 1-way cross-border. Moreover, it is assumed 
that for 10% of these transactions it is possible to find a customer who is resident in 
the  Member  State  of  registration,  for  which  the  company  therefore  incurs  no 
additional costs. Consequently, it is assumed that 837,000 1-way cross-border rental 
transactions are concluded each year. 

They result in additional costs for businesses of €418.5 million, additional price paid 
by  customers  of  €599  million,  and  therefore  additional  profits  for  businesses  of 
€181.5mln.  Costs  for  society  are  equal  to  additional  costs  (or,  analogously,  to 
customers’ loss minus businesses’ profits), that are €418.5 million. 

Then,  the  effect  on  demand  should  be  assessed.  If  costs  are  reduced  and  therefore 
prices also reduced, this would be reflected in an increase in demand. The fact that 
the price for cross-border rentals more than reflects the additional costs is a sign that 
demand  is  inelastic.  In  practical  terms,  only  those  who  really  need  such  a  rental 
transaction currently  demand it.  For calculation purpose, elasticity equal to 0.5 and 
constant is assumed. Conservatively, prices of the 5-day transactions to calculate the 
increase  in  demand  are  increased,  as  the  additional  costs  on  the  1-day  transactions 
represent a too high share of total price. 

Elasticity  is  defined  as 

=ε

P
Δ
P
Q
Δ
Q

,  where  ε  is  elasticity,  P  is  price,  and  Q  quantity. 

Conversely,  the  increase  in  demand  is  defined  as 

Q
=Δ

PQ
Δ⋅
P
ε
⋅

.  According  to  our 

assessment, Q is 837,000 (number of 1 way transactions); P is €969 and  PΔ  is €719. 
QΔ  is therefore equal to 1,242,111 additional transactions.  

To  estimate  additional  benefits  for  society,  one  would  need  to  study  the  functional 
form  of  the  demand  curve  and  of  the  curve of  marginal  costs.  Little  information  is 
available on these aspects. The share of operating costs over operating income, is a 

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fairly  good  approximation  of  marginal  costs.  Since  the  share  is  equal  to  45.1%87, 
producers’  surplus  would  be  equal  to  €162  per  transaction.  Therefore  1,242,111 
additional  transactions  would  translate  into  additional  benefits  for  car-rental 
undertakings of about €202m.  

Management of seasonal peaks in demand 

It  is  estimated  that  in  the  current  situation  100,000  transactions  are  declined  every 
year because of supply constraint. Using the same assumptions described above, for 
each  transactions  €162  of  producer’s  surplus  are  lost.  Therefore,  impediments  to 
proper management of seasonal peaks cost society about €16.2mln. In theory, under 
current  rules  it  is  possible  to  transfer  cars  and  re-register  them  in  the  country  of 
destination, and then register them back in the country of origin. It is estimated that 
this process would cost about €1000 per car (both registrations). Assuming that the 
peak  period  lasts  three  months,  this  would  amount  to  a  cost  per  day  per  vehicle  of 
about €11. Considering that the average rental price per vehicle per day is €45-50, it 
would amount to an increase of 20%, which makes this strategy currently unfeasible 
from an economic point of view. 

If companies could freely manage their fleet and assuming that they are able to fully 
satisfy demand peaks, loss of producers’ surplus of €16.2mln would be eliminated.  

Companies would also incur the information costs. 

8.4.3.5.  Other economic impacts: the 2nd hand vehicle market 

The  reduction  of  administrative  barriers,  administrative  costs,  and  of  the  cost  of 
capital  due  to  the  current  procedures  for  the  registration  of  vehicles  previously 
registered  in  another  Member  State  would  be  reflected  in  a  reduction  of  the  final 
price  for  customers  of  2nd-hand  vehicles  originating  from  another  Member  State. 
Consequently,  the  relative  price  of  2nd-hand  vehicles  originating  from  another  EU 
country would be lowered compared to those originating from the same country. 

The effect would be straightforward if the market for 2nd-hand vehicles originating 
from another Member State were a separate relevant market. On the contrary, this is 
not the case, as at least both 2nd-hand cars originating from the same Member State 
and  new  cars  are  substitute  goods,  and  therefore  part  of  the  same  relevant  market. 
Therefore, it is not possible to say whether there would be a non-negligible effect on 
the  price  for  vehicles,  and,  consequently,  whether  this  would  translate  in  a  higher 
demand. 

Nevertheless, a more direct impact could be predicted. The fact that the relative price 
of  2nd-hand  vehicles  originating  from  another  Member  State  is  lowered  increases 
their  relative  attractiveness  compared  to  those  originating  from  the  same  Member 
State. It means that an increase of the cross-border flux of 2nd-hand vehicle is likely. 
As said above, it is not possible to say whether this would translate in an increase of 
the  overall  market  size,  or  only  in  a  higher  share  of  2nd-hand  vehicles  originating 

87 

Leaseurope Index for Q1 2011. Data refer to both car-leasing and car-rental sector. Source available at: 
HTTP://WWW.LEASEUROPE.ORG/UPLOADS/DOCUMENTS/STATS/LEASEUROPE%20INDEX/LEASEUROP
E%20INDEX_Q1%202011%20AND%202010.PDF.  

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from another Member State out of the total transactions. As a side-effect, the more 
intense trade flux would increase the arbitrage among national markets for vehicles, 
leading to more uniform prices across the Single Market. 

8.4.3.6.  Sensitivity analysis 

BASELINE VALUES 

Current 
costs 
Baseline 
scenario 
-€ 2.472
-€ 2.655 
-€ 2.930 
-€ 2.289 
-€ 2.015 
-€ 2.406 
-€ 2.538 

-€ 2.595 

-€ 2.347 

-€ 2.606 
-€ 2.414 

Current 
costs 
Baseline 
scenario 
-€ 2.472
-€ 2.655 
-€ 2.930 
-€ 2.289 
-€ 2.015 
-€ 2.406 
-€ 2.538 

-€ 2.595 

-€ 2.347 

-€ 2.606 
-€ 2.414 

cars=3,850,000 
cars=4,375,000 
cars=3,150,000 
cars=2,625,000 
Leasing Rate=5.57% - 6.58% 
Leasing Rate=8.35% - 9.98% 
1-way cross-border 
transactions=1,004,040 
1-way cross-border 
transactions=669,600 
elasticity=0.3 
elasticity=0.7 
Baseline assumptions 
cars =3,500 ,000 
leasing rate= 6,96%-8,32% 
1 way cross border transactions= 837,000 
elasticity of demand = 0.5% 

BASELINE VALUES 

cars=3,850,000 
cars=4,375,000 
cars=3,150,000 
cars=2,625,000 
Leasing Rate=5.57% - 6.58% 
Leasing Rate=8.35% - 9.98% 
1-way cross-border 
transactions=1,004,040 
1-way cross-border 
transactions=669,600 
elasticity=0.3 
elasticity=0.7 
Baseline assumptions 
cars =3,500 ,000 
leasing rate= 6,96%-8,32% 
1 way cross border transactions= 837,000 
elasticity of demand = 0.5% 

Savings 

2b 

2c 

€ 2.385 

€ 2.343

€ 2.561 
€ 2.825 
€ 2.209 
€ 1.945 
€ 2.451 
€ 2.319 

€ 2.540 

€ 2.258 

€ 2.509 
€ 2.315 

€ 2.517 
€ 2.778 
€ 2.169 
€ 1.908 
€ 2.409 
€ 2.277 

€ 2.468 

€ 2.216 

€ 2.452 
€ 2.295 

2a 

€ 2.472
€ 2.655
€ 2.930
€ 2.289
€ 2.015
€ 2.406
€ 2.538

€ 2.595

€ 2.347

€ 2.606
€ 2.414

Savings 

3 

4 

€ 1.171

€ 1.171 

5 

€ 274

€ 1.287 
€ 1.461 
€ 1.055 
€ 934 
€ 1.215 
€ 1.127 

€ 1.171 

€ 1.171 

€ 1.171 
€ 1.171 

€ 1.287 
€ 1.461 
€ 1.055 
€ 934 
€ 1.215 
€ 1.127 

€ 1.171 

€ 1.171 

€ 1.171 
€ 1.171 

€ 295 
€ 311 
€ 253 
€ 222 
€ 266 
€ 222 

€ 274 

€ 274 

€ 274 
€ 274 

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8.5. 

Annex  5:  European  Vehicle  and  Driving  Licence  Information  System 
(EUCARIS) 

8.5.1.  Treaty  concerning  a  European  Vehicle  and  Driving  Licence  Information  System 

(EUCARIS) 

The Treaty concerning a European Vehicle and Driving Licence Information System 
(EUCARIS)  was  signed  on  29  June  2000  in  Luxembourg  by  Belgium,  Germany, 
Luxembourg, the Netherlands and the United Kingdom. On 1 May 2009 the Treaty 
formally entered into force.  

Any  State  that  applies  the  data  protection  provisions  of  Directive  95/46/EC  of  the 
European Parliament and of the Council of 24 October 1995 may apply to accede to 
the  Treaty.  The  accession  requires  the  unanimous  approval  by  the  Parties  to  the 
Treaty.  On  1  July  2010  Latvia  was  the  first  country  to  accede  to  the  Treaty.  The 
Slovak Republic acceded on 1 December 2010. 

The Treaty obliges central registration authorities to set up and maintain a common 
system for the exchange of vehicle and driving licence data, namely the "European 
Vehicle  and  Driving  Licence  Information  System",  known  as  EUCARIS.  The 
purpose of this system is: 

– 

– 

– 

to ensure that the central vehicle and driving licence registers of the Parties to 
the Treaty are accurate and reliable; 

to assist in preventing, investigating and prosecuting offences against the laws 
of  individual  States  in  the  field  of  driving  licences,  vehicle  registration  and 
other vehicle-related fraud and criminality; and 

to  exchange  information  rapidly  in  order  to  increase  the  efficiency  of 
administrative measures taken by the relevant authorities according to the legal 
and administrative regulations of the Parties of the Treaty. 

The following countries currently exchange vehicle and driving licence information 
based on the EUCARIS Treaty: Belgium, Estonia, Germany, Hungary, Iceland, Italy, 
Ireland,  Latvia,  Lithuania,  Luxembourg,  Romania,  Slovakia,  Sweden,  The 
Netherlands and the United Kingdom (incl. Gibraltar, Isle of Man, Guernsey, Jersey 
and Northern Ireland).  

The following countries expressed their interest for participation in the (near) future: 
Norway, Finland, France, Slovenia, Poland, Bulgaria and Switzerland88. 

8.5.2.  Bilateral exchange of information 

Since  2005  Germany  and  the  Netherlands  already  exchanged  vehicle  owner/holder 
information  regarding  traffic  fines  via  floppy/CD.  In  2008  this  exchange  has  been 
automated  via  EUCARIS.  The  legal  basis  for  this  exchange  is  the  Enschede 
Agreement. In 2008 also France and Switzerland digitalized their exchange of traffic 
fines  information  via  EUCARIS.  This  exchange  is  based  on  a  bilateral  agreement 

88 

HTTPS://WWW.EUCARIS.NET/PARTICIPATION.  

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between  France  and  Switzerland.  Currently  also  Switzerland  and  Germany  and 
France and Germany exchange their traffic fines information by electronic means, in 
accordance with bilateral agreements.  

Cooperating Member States 

Eucaris Treaty 

Participants 

Prüm  
Council 
Decisions  

Bilateral 
agreements  
traffic fines 

Participants 

Participants 

Ratified 

Signed 

To accede 

Associated 

Germany 

Romania 

Estonia 

Gibraltar 

Luxembourg 

Hungary 

Isle of Man 

All EU Member 
States + Norway 
and Iceland  

The 
Netherlands  
United 
Kingdom 
Belgium 

Latvia 

Slovakia 

Italy 

Jersey 

Ireland 

Iceland  

Lithuania 

Sweden  

Germany – the 
Netherlands 
France – 
Switzerland 
Switzerland – 
Germany 
Germany – 
France 

8.5.3.  The exchange of vehicle registration data through EUCARIS in EU law  

The  electronic  exchange  of  information  among  national  motor  vehicle  registration 
authorities  is  developing  steadily  in  other  contexts,  for  example  in  the  so-called 
‘Prüm Decisions’89 which provide, inter alia, for the automated exchange of vehicle 
registration data, as well as for other forms of police cooperation between the 27 EU 
Member States. Car registration data (including number plates and chassis numbers) 
are  exchanged  through  national  platforms  that  are  linked  to  the  online  application 
‘EUCARIS’  (European  Vehicle  and  Driving  Licence  Information  System).  It  is  a 
communications  network  which  allows  participating  countries  to  exchange  data 
relating to motor vehicles and driving licences. The system gives the participants the 
possibility  to  consult  on-line  motor  vehicle  data  kept  in  the  national  registers  of 
countries affiliated to the system.  

‘EUCARIS’ will also be used in Directive 2011/82/EU facilitating the cross-border 
exchange of information of road safety related traffic offences. One of its provisions 
relates to the establishment of a system of information exchange between the State of 
offence and the State of registration on the most serious road safety infringements, in 
order to identify the vehicle holder who has committed an offence in a Member State 
other  than  the  one  where  his  vehicle  is  registered.  The  Member  State  of  offence 

89 

Council  Decision  2008/615/JHA  of  23  June  2008  on  the  stepping  up  of  cross  border  cooperation, 
particularly in combating terrorism and cross-border crime and Council Decision 2008/616/JHA of 23 
June 2008 on the implementation of Decision 2008/615/JHA. 

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would then be in a position to prosecute and sanction him. The Directive will specify 
the exchange procedures (data, responsible authorities and network). 

8.5.4.  The  functioning  of  the  electronic  exchange  of  vehicle  registration  data  through 

EUCARIS  

EUCARIS  uses  a  peer-to-peer  concept  for  the  data-exchange  by  means  of  a 
decentralised set-up in which all participating countries are connected to each other 
and are able – by means of an interface – to search in each other's register, without 
influencing  the  national  structure  of  their  registers.  There  is  no  centralised  system 
and  no  central  register  to  be  searched  by  the  registration  authorities.  EUCARIS  is 
currently  owned  by  the  Eucaris  Community  (Member  State  consortium).  The 
maintenance  and  the  support  are  ensured  by  RDW  (Dutch  registration  authority). 
According  to  a  study  about  the  European  Interoperability  Infrastructure  Services 
(EIIS)90, Eucaris II ‘can potentially be transformed into a more generic platform that 
can be used for the exchange of all sorts of data and not only for information related 
to  vehicles  and  driving  licences.  Recently  the  consortium  of  connected  Member 
States have declared that EUCARIS should be the general exchange mechanism for 
other transport related data (e.g. for tachograph cards, transport undertakings etc). 
The  potential  for  reuse  is  in  its  lightweight  and  pragmatic  architectural  approach. 
The development cost to add additional countries is low, and the operational cost is 
minimal.’  In  addition  the  system  offers  the  functionality  that  every  registration 
authority decides autonomously decides which exchanged data are to be provided to 
which other organisations on the territory of their Member States.  

The  following  vehicle  information  is  currently  exchanged  by  the  system:  licence 
number,  Vehicle  Identification  Number  (VIN),  document  ID,  registration  date, 
additional  identifying  attributes  like  colour,  make  and  commercial  type  of  the 
vehicle, all EU harmonized attributes that are indicated on the Vehicle Registration 
Document  foreseen  by  Directive  1999/37/EC,  PTI  information  and  destruction 
information. 

The inquiries between the Eucaris parties are carried out in a synchronous (ad-hoc) 
way. This implies that the client application waits for a response. As a consequence 
parties are expected to respond within a reasonable time.  

When a country is inquiring multiple other countries, the EUCARIS core will create 
a specific process thread for each country. This is done in a parallel way, so that all 
countries threads are started at the same time. On each thread the process will wait 
for  a  response.  Finally  responses  from  all  threads/countries  are  consolidated  and 
returned to the client.  

For  a  few  services  there  is  also  an  asynchronous  mechanism  in  EUCARIS.  These 
services are not time critical. Information transferred via these services is first stored 
in  a  queue  in  the  local  database  and  periodically  a  mechanism  tries  or  retries  to 
transfer  the  data  to  the  other  countries.  These  services  use  FileTransfer  as  generic 
transport mechanism. 

90 

HTTP://EC.EUROPA.EU/IDABC/SERVLETS/DOC8C04.PDF?ID=32600.  

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8.5.5.  Financial aspects 

EUCARIS  does  not  have  legal  personality.  The  budget  is  set  annually  by  the 
Participants’ Board in co-decision with third parties using EUCARIS, encompassing 
the initial (development) costs of the EUCARIS system and the annual joint costs of 
using the system. 

A (new) participating country will itself finance the connection of its own register to 
the EUCARIS system. While a country can opt for support arranged by EUCARIS, it 
will  then  be  billed  for  the  costs  involved.  Therefore  this  is  budget-neutral  for  the 
EUCARIS budget. 

Information  should  be  provided  to  foreign  enforcement  bodies  free  of  charge.  The 
operating  costs  of  the  register  systems  are  borne  by  the  countries  providing 
information and therefore have no impact on the EUCARIS budget. 

All countries connected to EUCARIS on 31 December of a financial year must pay 
the annual contribution for that year, including countries whose connection was not 
expected in the budget.  

The level of the standard fee is set (annually) irrespective of the difference in legal 
status of countries’ participation in EUCARIS. Operating and development costs for 
the  EUCARIS  system  are  differentiated  per  connection  and  per  legal  basis  and 
countries are only charged for the functionality they use or will use. 

Operating  and  development  costs  are  as  far  as  possible  be  divided  per  user  group. 
Each user group is defined by the legal basis for the services and functionalities used. 
In 2012 the user groups are: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

 EUCARIS Vehicle and Driving Licence exchange user group;  

 Prüm user group;  

 Vehicle Owner / Holder exchange user group; 

 Mileage exchange user group; 

 ERRU user group; 

 TACHO user group; 

 RESPER user group;  

 eCall user group; 

 CoC exchange user group 

A country wishing to join a specific user group can be asked to pay an entrance fee to 
contribute to certain investment costs already covered by the other users.  

The budget for 2012 amounts to € 636.845. 

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EUCARIS Budget 2011 and 2012 

Account 
2010 

Budget  
2011 

Expected 
outcome 
2011 

Budget 
2012 

1000 Contributions General 
1001 Contributions EUCARIS 
1002 Contributions Prüm 
1003 Contributions O/H File Transfer 
1004 Contributions Mileage 
1100 Interest  
1200 Donations General 
1201 Donations EUCARIS 
1300 Other income General 
1301 Other income EUCARIS 
1302 Other income Prüm 
1305 Other income ERRU 
1307 Other income RESPER 
1309 Other income CoC  
Total income 

281.400
51.506
73.493
28.800
6.084
0
0
4.000
0
0
3.223
-
-
-
448.506

2000 Meetings General 
2001 Meetings EUCARIS 
2002 Meetings Prüm 
2100 Procurement of hardware 
2200 Development of software General 
2201 Development of software EUCARIS 
2202 Development of software Prüm 
2203  Development  of  software  O/H  File 
Tran. 
2204 Development of software Mileage 
2205 Development of software ERRU 
2207 Development of software RESPER  
2209 Development of software CoC 
2300 Administration 
2400 Finances 
2500 Reporting 
2600 Operation 
2700 Maintenance of software 
3000 Publications 
3100 Symposia and such like 
3200 Representation General 
3201 Representation EUCARIS 
Total Costs 

4.967,65
7.237,92
899,36
0
77.426,57
42.888,96
72.140,05

17.248,38
6.297,36
-
-
-
71.776
4.966,27
0
106.365
52.964,52
5.401,41
0
0
1.179,64
471.758,09

248.284
3.000
33.393
0
0
0
0
4.000
0
217.427
96.283
-
-
-
602.387

7.500
5.000
1.500
0
12.757
217.427
128.185

0
0
-
-
-
73.211
6.000
0
108.491
50.000
2.600
P.M.
P.M.
2.000
614.671

248.284 
3.000 
33.393 
0 
0 
0 
0 
5.000 
0 
217.427 
70.683 
- 
- 
- 
577.787 

2.500 
8.000 
1.500 
0 
12.757 
217.427 
102.585 

0 
0 
- 
- 
- 
73.211 
6.000 
0 
108.491 
37.000 
2.600 
0 
0 
1.250 
573.321 

295.950
-2.198
33.291
-11.552
213
0
0
5.000
0
P.M.
74.352
 51.613
155.085
39.104
640.858

8.000
5.000
1.000
0
14.389
0
110.325
0

0
51.613
155.088
39.101
83.159
6.000
0
123.370
40.000
3.500
P.M.
P.M.
2.000
642.545

Sub Total 

Surplus 2008 
Surplus 2009 
Surplus 2010 
Total 

-23.252,99

-12.284

+4.466 

-1.687

+ 24.947

+12.275

+12.275 

+ 1.694,01

- 9

+16.741 

+1.694
+7

EN 

166 

   EN 

 
 
 
 
 
 
 
 
 
 
 
8.5.6.  Technical aspects91 

8.5.6.1.  Introduction 

The EUCARIS system was realised in the early nineties. The communication in the 
original EUCARIS I system was based on a transaction monitor, Tuxedo, and hosted 
on UNIX platforms. The message protocol was specific. 

In 2003 the EUCARIS Participants Board decided to start the development of a new 
generation of the application based on web service technology. This new generation 
was  called  EUCARIS  II  and  has  been  designed  to  send  and  receive  signed  XML 
messages and to run on a Windows platform.  

The  realisation  of  EUCARIS  II  was  completed  at  the  end  of  2006.  Deployment 
started  in  2007.  Since  October  2009  all  countries  are  connected  to  the  new 
EUCARIS  II  environment.  Therefore  only  the  architecture  of  EUCARIS  II  will  be 
elaborated in this document.  

The EUCARIS architecture consists of the following components that are described 
below and in the next chapters: 

• 

• 

• 

 National Registries 

 An EUCARIS application in each Member State 

 A closed and secured TCP/IP network 

8.5.6.2.  National Registries 

Each Member State is responsible for its own Registry of vehicle and driving licence 
information and its own registration procedures. Though European harmonisation is 
advancing, differences in these procedures are still substantial. For instance, in most 
States  a  vehicle  licence  identifies  a  vehicle  and  can  be  transferred  from  one 
owner/holder to the next. In other States this licence is issued to a person, and can be 
transferred from one vehicle to another.  

8.5.6.3.  An EUCARIS application in each Member State 

EUCARIS  is  basically  a  centrally  developed  application  that  is  deployed  in  each 
Member  State.  The  application  consists  of  two  parts.  These  parts  are  a  Web  client 
and  the  so-called  ‘Core’  application,  responsible  for  the  secure  handling  and 
communication of the messages, between the European Member States at one side, 
and the national Registry and the national users at the other side. 

The  main  philosophy  of  EUCARIS  is  a  direct ‘peer-to-peer’ communication, so all 
States  communicate  directly  to  one  another,  without  any  central  component.  Both 
synchronous (interactive) and asynchronous (batch) communication are supported.  

91 

Source : Eucaris Secretariat. 

EN 

167 

   EN 

 
                                                 
8.5.6.4.  Presentation 

At the front-end, the services framework or ‘Core’ receives requests from its national 
users, working with either the ‘standard’  EUCARIS  Web  client  application or with 
custom  Web  or  legacy  clients  that  may  be  integrated  in  systems  of  other 
organisations  like  the  national  police.  The  EUCARIS  system  has  been  setup  to 
support multiple clients.  

– 

EUCARIS  Web  client:  The  system  is  delivered  with  a  browser  based  Web 
client that supports: 

•  Multilanguage user interface enabling an administrator to translate screen 

items 

•  Multilanguage  message  interface  enabling  an  administrator  to  translate 

coded attributed 

•  Multiple languages per country/user  

• 

• 

• 

Group role access control per application function 

Configuration management 

Single Sign-on  

Using the default EUCARIS Web client, a new participating party can access 
the Registries in other countries within a few days (under the condition that the 
new participating party is granted access to do inquiries in the specific Member 
States).  

– 

Customized client: Besides the default client application a so called customized 
client  can  be  developed.  Such  a  customised  client  can  be  incorporated  in  a 
larger  application  (e.g.  a  police  system)  or  in  the  workflows  within  the 
organisation. A customized client application uses: 

• 

• 

The EUCARIS web services for accessing services in other countries, 

The  EUCARIS  internal  services  for  retrieval  of  meta  information  on 
authorisation  or  for  translation  of  the  various  message  elements  like 
vehicle colours, vehicle signals, etc. 

The EUCARIS Web client and one or several custom client applications may 
be combined in one Member State. 

8.5.6.5.  Applications 

The  EUCARIS  application  has  been  written  in  the  Microsoft  C#  development 
language.  The  application  consists  almost  entirely  of  so  called  managed  code. 
Managed  code  runs  on  top  of  the  Microsoft  Common  Language  Runtime 
environment  (CLR).  The  CLR  provides  a  secure  and  independent  platform  for 
running applications. 

EN 

168 

   EN 

 
– 

SOA: The EUCARIS application has been setup using SOA techniques. The so 
called  ‘core’  application  consists  of  several  Services  Frameworks  with 
interfaces for External and Internal Services and a series of ‘core’ libraries with 
generic  functionality  used  by  the  EUCARIS  Web  client  and  the  External  and 
Internal  Services.  Communication  between  services  is  based  on  SOAP  and 
XML messages. 

Architecture release 6.0

Users

VH
VH
VH

DL
DL
DL

PR
PR
PR

FT
FT
FT

?
?
?

Eucaris WebClient Framework
Eucaris WebClient Framework
Eucaris WebClient Framework

External Interface

Public Interface

Internal  Interface

VHI DLI VHP

?

?

CLS DBS CS

?

?

Eucaris Services Framework

Eucaris Internal Services

Eucaris common libraries

Eucaris
Configuration

Eucaris
Database

Other
Member 
States

Legacy Interface

To
Register

SI

AC

RR

QA

?

SIT

UM

LV

AA

Eucaris
Management
Framework

– 

– 

The  core  application  is  connected  to  the  legacy  of  a  Member  State  via  a 
dedicated  gateway  that  is  no  part  of  the  EUCARIS  application,  but  has  to  be 
developed by each individual Member State since it contains functionality very 
specific for that State.  

Generic  Functionalities:  The  EUCARIS  Services  Framework  contains  a 
number of generic functionalities used by the various services. The following 
functions are available: 

• 

• 

• 

• 

• 

Signing of a message 

Validation of a signed message 

Logging of messages 

Validation of message on conformity to the XSD 

Authorisation 

EN 

169 

   EN 

 
 
 
• 

Authentication 

•  Message distribution to other countries (synchronous) 

•  Message  distribution  to  multiple  countries  (Multi  Country  Inquiry) 

(synchronous) 

• 

Consolidation of incoming responses on a Multi Country Inquiry  

•  Message distribution to other countries (a-synchronous) 

• 

Queuing 

An important feature of the application is the so-called Multi Country Inquiry, 
a  broadcasting  mechanism  sending  a  request  to  all  connected  Member  States 
(provided that the inquiry is authorised). Response messages are consolidated 
and returned to the requesting user. 

At the back-end, the Services Framework is connected via an interface to the 
national  Registries  providing  the  vehicle  and  driving  licence  information  on 
request from other States. In this interface all coded information is translated to 
standardised  values  (e.g.  colour-code  or  the  indication  that  the  vehicle  is 
stolen). 

–  Web services: The Services Framework provides access to a series of services. 
The external interface, used for the information exchange with parties abroad, 
requires signed messages and validates the message-signature accordingly. The 
client  interface  requires  unsigned  messages.  Security  has  to  be  organised 
outside  the  application,  based  on  mechanisms  like  userid  -  password 
authentication and authorisation. The following services are available: 

Service 

Description 

CollectExtractService 

External  web  service  hosted  by 
the 
Secretary  State  which  receives  requested 
Extracted  Logging  and  stores  it  into  the 
Sectary State database. 

ExtractLoggingService 

External  web  service  which  provides 
access to Extracted Logging. See below 

FileTransferService 

Transfer 

Web service for submitting and retrieving 
File 
messages.The 
FileTransferService  is  used  as  generic 
transport  mechanism  for  asynchronous 
messaging. 

MessageOfTheDayService 

Web  service  for  submitting  message  of 
the day notifications. See below 

RegistrationNotificationServic
e 

Web  service  for  submitting  registration 
notifications. 

EN 

170 

   EN 

 
 
Service 

Description 

NotificationOfDestruction 

  Web services for notifications on scrapped 

vehicles 

SearchDriversLicenseService  Web service for directing Drivers License 

Inquiry requests. 

SearchVehicleOwnerService  Web  service  for  directing  Vehicle  Owner 
Holder  or  Vehicle  Insurance  Inquiry 
requests. 

SearchVehicleService 

Web service for directing Vehicle Inquiry 
requests. 

VHOwnerHolderExchangeSer
vice 

Web service for submitting and retrieving 
VHOwnerHolder Exchange messages. 

GenericService 

Single  point  of  entry  for  delivering 
(ad-hoc)  messages.  Will 
synchronous 
synchronous 
dedicated 
the 
replace 
“SearchVehicleService”, 
services 
and 
“SearchDriversLicense” 
in 
“SearchVehicleOwnerHolderService” 
the future. 

– 

Internal  Services:  The  internal  web  services  provide  access  to  the  following 
services  for  local  users  of  the  standard  EUCARIS  Web  client  or  customized 
client applications: 

Service 

ClientLogicService 

Description 

Web  service  containing  several  web 
methods 
client 
functionality to other local clients. 

exposing  Web 

ExtendedClientLogicService  Web  service  containing  several  web 
methods 
client 
functionality to other local clients. 

exposing  Web 

–  Windows  services:  Windows  services  are  configured  to  handle  asynchronous 
communications  between  EUCARIS  servers.  The  services  run  continuously 
and trigger the web services at regular intervals: 

Service 

Description 

ExtractLogging 

Windows  service  running  exclusively  on 
the  EUCARIS  server  of  the  Secretary 
State, starting the ExtractLogging process. 
On  activation  the  service  requests  logged 
messages from all Member States. 

FileTransferDelivery 

Windows  Service  which  delivers  the  File 
Transfer  functionality.  Extracts  locally 

EN 

171 

   EN 

 
 
 
 
 
Service 

Description 

NotificationDelivery 

VHOwnerHolderExchangeDel
ivery 

and 
stored 
processes them via a queuing mechanism. 

FileTransfer  messages 

the 
Windows  Service  which  delivers 
Notification functionality. Extracts locally 
stored  notifications  and  processes  them 
via a queuing mechanism. 

Windows  Service  which  delivers 
the 
VHOwnerHolderExchange  functionality. 
Extracts 
stored 
locally 
VHownerHolderExchange  messages  and 
processes them via a queuing mechanism. 

8.5.6.6.  Communication  

The inquiries between the Eucaris parties are carried out in a synchronous (ad-hoc) 
way. This implies that the client application waits for a response. As a consequence 
parties  are  expected  to  respond  within  a  reasonable  time.  Within  the  EUCARIS 
community the standard has been described in a Letter of Intent.  

When a country is inquiring multiple other countries, the EUCARIS core will create 
a  specific  process  thread  for  each  country.  This  is  done  in  a  parallel  way,  so  to  all 
countries threads are started at the same time. On each thread the process will wait 
for  a  response.  Finally  responses  from  all  threads/countries  are  consolidated  and 
returned to the client.  

Thanks to the parallel processing, a MCI lasts only slightly longer than the response 
time of the slowest country.  

For  a  few  services  there  is  also  an  asynchronous  mechanism  in  EUCARIS.  These 
services are not time critical. Information transferred via these services is first stored 
in  a  queue  in  the  local  database  and  periodically  a  mechanism  tries  or  retries  to 
transfer  the  data  to  the  other  countries.  These  services  use  FileTransfer  as  generic 
transport mechanism. 

8.5.6.7.  Technical infrastructure  

– 

 Platform  &  Operating  system:  The  EUCARIS  application  has  been  set-up 
using as few as possible additional software to provide a lean, mean and cost 
effective system. The EUCARIS environment requires: 

•  Microsoft  Windows  2003  +  2008  32  bit  architecture  with  ample  user 

licenses 

•  Microsoft  .NET  Framework  3.5  (no  additional  costs).  As  from  .Net 
framework  4.0  this  framework  is  an  integrated  part  of  the  operating 
system.  

•  Microsoft IIS (no additional costs) 

EN 

172 

   EN 

 
 
The system has been designed with scalability as one of the design principals 
and  therefore  it  can  scale-up  or  scale-out  to  meet  the  requirements  of  the 
business.  Performance  tests  have  proven  that  the  system  will  scale-up  to  at 
least 8 CPU. Expansion of the system can also be accommodated by network 
load balancing and multiple servers and database clustering. 

– 

 Storage:  All  data  regarding 
logging,  configuration  and  customization 
information is stored in the database. The EUCARIS system has been designed 
to support the following database configurations: 

•  Microsoft  SQL  2000/2005/2008  on  EUCARIS  server  using  the  free 

Express editions (out of the box) 

•  Microsoft SQL 2000/2005/2008 on EUCARIS server using full version 

•  Microsoft SQL 2000/2005/2008 on external server 

• 

• 

Oracle 9, 10 on EUCARIS server 

Oracle 9, 10 on external server 

Since EUCARIS uses a lean and mean database model, other versions of above 
database will probably work but are not yet tested. 

– 

 Network:  It  is  recommended  to  have  two  network  cards  available  in  the 
EUCARIS server. One network card should be assigned to the internal network 
and  the  other  card  to  the  EUCARIS  (INFONET/TESTA)  network.  The 
EUCARIS server however will also work with a single network card, but then 
separation of internal network and EUCARIS network should be controlled by 
a router. 

–  WAN  -  a  closed  and  secured  TCP/IP  network:  All  information  is  exchanged 
between  the  Member  States  via  a  secured  private  TCP/IP  network.  Each 
Member State is connected to TESTA, a network managed under the auspices 
of  the  European  Commission,  connecting  administrations  in  the  EU  Member 
States.  

– 

DNS:  Currently  there  is  no  DNS  server  configured.  The  EUCARIS 
environment  however  supports  full  DNS  by  its  operating  system.  The  host 
entries  for  all  countries  are  maintained  in  the  hosts  file  on  each  EUCARIS 
server.  Configuration  of 
the  secretary 
management tool to ease configuration. Future use of DNS is to be expected. 

is  controlled  via 

these  entries 

8.5.6.8.  Security 

– 

Security between the Member States: The security between the Member States 
is controlled by the EUCARIS server core. The messages are transferred over 
an  SSL  connection.  All  messages  exchanged  between  the  States  are  signed 
with the use of a certificate. The EUCARIS server will verify the signature of 
the incoming messages and then forward the verified message unsigned to the 

EN 

173 

   EN 

 
registration server or requesting client application. Details on security are given 
in. 

– 

Certificate  usage:  Certificate  information  is  only  present  on  the  server  that 
initiates  the  communication.  Validation  of  the  message  and  signature  is  done 
by  using  the  certificate  information  that  is  exchanged  with  each  request, 
provided that this certificate has been issued by a trusted CA. No complicated 
certificate  management  between  Member  States  is  required.  The  EUCARIS 
server supports multiple certificates from multiple PKI providers. Currently the 
EUCARIS  States  run  their  own  managed  PKI  that  makes  use  of  Verisign 
certificates. The application has facilities to assign a specific certificate to one 
or several services.  

–  Member  State  authorization:  Member  States  authorise  other  States  based  on 
their  bilateral  agreements  or  an  international  Treaty  etc.  The  common  name 
(CN) on the certificate contains an organisation-code that is used to validate the 
authorisation of the requesting State or organisation. Multiple common names 
are supported by EUCARIS. The EUCARIS application validates the message 
signing and permits/rejects a country to make inquiries based on its own access 
control  information.  Access  control  can  be  configured  for  each  service  and 
country  via  the  Web  client.  A  Member  States  doesn’t  have  to  validate  the 
requesting  users  in  other  Member  States  and  therefore  no  complicated  cross 
EUCARIS user management is required. 

– 

– 

CRL:  The  Certificate  Revocation  List  for  the  used  certificates  is  stored  on  a 
central  server  at  RDW.  Since  EUCARIS  runs  on  a  private  network,  the  CRL 
which  is  published  by  the  Certificate  Authority  (Verisign)  on  the  public 
internet  is  not  accessible  and  therefore  is  periodically  copied  to  a  server  at 
RDW.  To  address  this  CRL  an  entry  in  the  hosts  file  is  added  which  will 
redirect the CRL checking request to SVRSecure-crl.verisign.com to the server 
at RDW. 

User  Authentication/Authorisation  (Web  client):  EUCARIS  users  using  the 
standard  EUCARIS  Web  client  are  authenticated  using  the  default  Windows 
mechanisms. The users can be assigned to various Windows groups and each 
group can be authorised for particular functions of the application. The admin 
functions  are  separated  from  the  regular  users.  Requests  made  to  other 
countries are made on the credentials of a country, but user information is also 
transmitted in the request message to the requested country. 

– 

User  registration:  Registration  of  users  is  based  on  Windows.  There  are  two 
possibilities to register users: 

• 

• 

Local  registration:  users  can  be  registered  locally  on  the  EUCARIS 
server.  Whenever  a  user  connects  via  the  browser  to  the  EUCARIS 
server,  the  user  is  prompted  to  enter  username  and  password.  This 
method doesn’t support Single Sign On and password ageing. 

Domain authorization: this is the preferred method of adding users to the 
EUCARIS  server.  The  EUCARIS  server  must  be  a  Member  of  the 
Windows domain used within the Administration. Once the user connects 

EN 

174 

   EN 

 
to the EUCARIS server his credentials are used to connect to the server 
without an additional logon screen. Password management applies to the 
same rules as defined in the Administration’s Windows domain. 

– 

Customised client: It is the responsibility within the Member State to secure the 
inquiries  made  by  a  Customized  client.  This  is  outside  of  the  scope  of 
EUCARIS. 

8.5.6.9.  Operational system management 

– 

Software maintenance, delivery and deployment: 

• 

• 

• 

• 

Release  management:  A  major  change  in  one  of  the  messages,  or 
addition  of  a  new  service,  will  lead  to  a  new  release  of  a  plugin  or  the 
application.  New  releases  of  the  EUCARIS  application  are  always 
compatible with former releases, so e.g. a Member State with release 6.x 
is  able  to  communicate  with  a  State  using  release  7.x.  Changes  in  a 
request message and changes in the structure of response messages will 
always  lead  to  the  definition  of  a  new  service.  Addition  of  optional 
elements in the response messages results in a new version of the existing 
message. Eucaris uses a sophisticated method to degrade messages from 
a higher version to previous versions of this message if the requestor is 
not able to handle messages from a higher version.  

Phased implementation: The EUCARIS software is delivered on CD, as a 
standard Microsoft MSI package. For installation some pre-requisites are 
required  like  IIS  and  the  Microsoft  .NET  Framework.  Installation  and 
configuration are supported by specific tools that are distributed with the 
application.  Eucaris  PlugIns  and  tools  are  also  distributed  via  the 
www.eucaris.net  website.  For  the  local  administrators  only  Windows 
knowledge  is  required.  It  is  possible  to  implement  only  the  specific 
functionality  of  EUCARIS,  or  to  split  the  implementation  in  several 
phases,  e.g.  a  first  phase  for  client  functionality,  a  second  phase  to 
connect EUCARIS to the national vehicle registration and a third phase 
to connect the drivers licence registration.  

Acceptance  procedure:  A  new  Member  State,  or  an  organisation 
extending  its  service  with  a  new  message,  will  only  be  accepted  in  the 
production  environment  of  EUCARIS  after  a  formal  test  procedure. 
During  this  procedure  the  Secretary  State  checks  both  requests  from 
customised  client  applications  and  response  message.  It  is  advised  to 
have  a  separate  acceptance  and  production  environment  available  for 
EucarisII,  especially  when  you  plan  to  implement  specific  functionality 
in 
inbound  or  outbound 
implementation must be tested with an acceptance test coordinated by the 
secretary state prior to go live in production. 

fases.  Every  major  change 

in  your 

Consequences  of  the  addition  of  a  new  Member  State  for  other  States: 
Addition  of  a  new  organisation  in  the  EUCARIS  network  has  some 
consequences for the other parties. All parties have to authorise the new 
Member  and  to  define  their  own  rights  to  perform  inquiries  in  the  new 

EN 

175 

   EN 

 
country.  Moreover,  the  IP  address  and  URL’s  of  the  newcomer  have  to 
be registered in all connected organisations. To support this process the 
Secretary  State  generates  for  each  Member  State 
the  relevant 
configuration files by means of a specific tool and distributes these files 
to  all  parties.  The  secretary  state  releases  an  average  of  12  so  called 
‘Configuration  Updates’  per  year  for  the  production  environment. 
Installing  a  ‘Configuration  Update’  is  relatively  easy  and  is  normally 
performed  by  your  local  system  administrator  (this  procedure  is  well 
documented  in  the  technical  documentation  of  Eucaris).  This  recurring 
task  has  to  be  taken  into  account  when  defining  the  local  Operational 
Service Management.  

• 

Service  levels  and  Letter  of  Intent:  So  far  there  is  no  formal  Service 
Level  Agreement.  However  the  EUCARIS  Member  States  signed  a 
Letter  of  Intent  concerning 
the  opening  hours,  availability  and 
performance of the EUCARIS services, including their Registry systems. 
The Prüm Member States have drawn up such a Letter of Intent as well. 
The  actual  service  level  offered  by  each  State  is  reported  monthly  and 
discussed during the yearly EUCARIS Participants’ Board.  

–  Management and support 

• 

Error  handling:  At  the  European  level,  the  EUCARIS  environment 
consists  of  loosely  coupled  applications.  This  implies  that  there  is  no 
dependency  between  the  systems  in  each  Member  State.  In  case  of  a 
failure of one of the systems, requests and replies of all other systems are 
still  processed.  Error  handling  depends  on  the  nature  of  the  failure. 
Serious failures concerning e.g. network, hardware or authorisation, will 
result  in  an  immediate  error  message  that  is  returned  to  the  local  client 
application or the requesting Member State. When no response has been 
received within the configured time, the requesting country will generate 
a  so  called  time-out  error  and  inform  the  client.  The  EUCARIS  Web 
client  application  is  able  to  show  incomplete  results,  consisting  of 
responses from some Member States and error messages from others. 

• 

Event  logging:  The  EUCARIS  system  will  report  all  information 
messages, warnings and error messages into the Windows Event log. The 
Secretary  State  has  a  shortlist  with  causes  and  the  solutions  related  to 
most of the messages and the actions to perform.  

•  Message  logging:  All  messages  are  optionally  logged  into  the  database 
for  auditing,  statistics  or  error  handling.  Per  service  there  are  several 
messages types which can be logged. These message types are: 

– 

– 

– 

Request  entering  the  system  from  a  local  client  (Web  client, 
customized client)  

Request forwarded to another Member State 

Reply received from another Member State 

EN 

176 

   EN 

 
– 

– 

– 

– 

– 

Reply returned to the client 

Request entering the system from another Member State server 

Request forwarded to the legacy (Registry system) 

Reply received from the legacy  

Reply returned to the requesting Member State 

By using the Web client, an administrator can define for each individual 
service which message types are logged. So it is possible e.g. to log the 
Driving Licence Inquiries and not to log the Prüm Inquiries. 

• 

First, second and third line support: First line support has to be arranged 
by  the  participating  country.  For  second  line  support  the  participating 
country  can  contact  the  service  desk  of  the  Secretary  State  (currently 
RDW).  Support  is  available  during  office  hours.  When  required,  RDW 
will pass the problem to a subcontractor for further support. 

•  Monitoring  of  availability:  RDW,  in  the  role  of  Secretary  State,  will 
probe  all  EUCARIS  servers  in  the  network  by  means  of  a  specific 
monitoring tool. Currently polling has been set to occur each 10 minutes. 
The tool sends at regular times for each service a request message to all 
connected  organisations  and  reacts on  the  incoming  response  messages. 
Both availability and performance are registered. Whenever a system in 
one  of  the  Member  States  is  not  available,  this  will  be  reported  to  the 
service  desk  at  RDW  and  appropriate  actions  will  be  taken.  The 
organisation involved will be notified.  An incident report will be made. 
An availability report is published monthly.  

• 

Functional  support:  Functional  support  concerning  the  content  of 
individual  registrations  is  given  by  the  service  desk  of  each  individual 
organisation. A comprehensive help text is available for the end users as 
part of the Web client application. 

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8.6. 

Annex 6: Discarded option 

An amendment of the Vienna Convention on Road Traffic of 8 November 1968 was 
discarded at an early stage.  

Austria,  Belgium,  Bulgaria,  Czech  Republic,  Denmark,  Estonia,  Finland,  France, 
Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, the Netherlands, 
Poland,  Portugal  Romania,  Slovakia,  Slovenia,  Spain,  Sweden  and  the  United 
Kingdom  are  contracting  parties to the Convention which was concluded under the 
auspices  of  the  United  Nations  Economic  Commission  for  Europe.  Ireland,  Malta 
and Cyprus did not sign the Convention92. 

According to Article 1(b) of the Convention, a vehicle is said to be “in international 
traffic” in the territory of a State if: 

‘(i) It is owned by a natural or legal person normally resident outside that State; 

(ii) It is not registered in that State; and 

(iii) It is temporarily imported into that State; 

provided,  however,  that  a  Contracting  Party  may  refuse  to  regard  as  being  “in 
international traffic” a vehicle which has remained in its territory for more than one 
year  without  a  substantial  interruption,  the duration  of  which  may  be  fixed  by  that 
Contracting Party.’ 

Article 35(1)(a) of the Convention specifies inter alia that, in order to be entitled to 
the  benefits  of  the  Convention,  ‘every  motor  vehicle  in  international  traffic,  and 
every trailer, other than a light trailer, coupled to a motor vehicle shall be registered 
by a Contracting Party or a subdivision thereof, and the driver of the motor vehicle 
shall  carry  a  valid  certificate  of  such  registration  issued  either  by  a  competent 
authority  of  such  Contracting  Party  or  subdivision  thereof  or  on  behalf  and  by 
authorization  of  such  Contracting  Party  or  subdivision  thereof  by  an  association 
duly empowered thereto by that Contracting Party or subdivision thereof.’ 

According  to  the  Convention,  the  registration  certificate  must  at  least  bear  the 
following particulars: 

– 

– 

– 

– 

A  serial  number,  to  be  known  as  the  registration  number,  composed  in  the 
manner indicated in Annex 2 to the Convention; 

The date of first registration of the vehicle; 

The full name and home address of the holder of the certificate;  

The name or the trademark of the maker of the vehicle;  

92

EN 

http://treaties.un.org/pages/ViewDetailsIII.aspx?&src=TREATY&mtdsg_no=XI~B~19&chapt

er=11&Temp=mtdsg3&lang=en.  

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– 

– 

– 

– 

The serial number of the chassis (the maker’s production or serial number); 

In  the  case  of  a  vehicle  intended  for  the  carriage  of  goods,  the  permissible 
maximum mass; 

In the case of a vehicle intended for the carriage of goods, the unladen mass; 

The period of validity, if not unlimited. 

The Convention indicates that the particulars entered in the certificate must either be 
in  Latin  characters  or  so-called  English  cursive  script  only,  or  be  repeated  in  that 
form. The Convention allows Contracting Parties or their subdivisions to decide that 
the year of manufacture, instead of the date of first registration, may be entered on 
certificates  issued  in  their  territories.  In  the  case  of  motor  vehicles  of  categories  A 
and  B  as  defined  in  Annexes  6  and  7  to  the  Convention  and,  if  possible,  for  other 
motor  vehicles,  the  certificate  must  be  headed  with  the  distinguishing  sign  of  the 
State  of  registration  as  defined  in  Annex  3  to  the  Convention.  It  obliges  its 
Contracting Parties to place the letters A, B, C, D, E, F, G and H respectively before 
or after the eight items of information which are required under Article 35(1)(a) to be 
shown  on  all  registration  certificates.  The  Convention  specifies  also  that  the  words 
‘Certificat d’immatriculation’ in French may be placed either before or after the title 
of  the  certificate  in  the  national  language  (or  languages)  of  the  country  of 
registration. 

Pursuant  to  Article  35(1)(d)  of  the  Convention,  a  photocopy  of  the  registration 
certificate, certified as a true copy by the authority which issued the certificate, must 
be  considered  sufficient  for  trailers,  including  semi-trailers,  imported  temporarily 
into a country by a mode of transport other than road transport. Article 35(2) of the 
Convention  entitles  articulated  vehicles  which  are  not  disassembled  while  in 
international traffic to the benefits of the provisions of the Convention even if they 
have  only  a  single  registration  and  a  single  certificate  for  the  drawing  vehicle  and 
semi-trailer composing them. According to Article 35(3), nothing in the Convention 
can be construed as limiting the right of Contracting Parties or their subdivisions to 
require, in the case of a vehicle in international traffic which is not registered in the 
name of a person travelling in it, proof of the driver’s right to be in possession of the 
vehicle. Article 35(4) of the Convention recommends the Contracting Parties to set 
up, if they have not already done so, a service responsible for keeping, at the national 
or  regional  level,  a  record  of  motor  vehicles  brought  into  use  and  a  centralized 
record, for each vehicle, of the particulars entered in each certificate of registration. 

Consequently,  the  Convention  does  not  specify  in  which  State  the  motor  vehicle 
ought  to  be  registered,  nor  does  it  specify  the  administrative  requirements  of  the 
registration.  None  of  the  provisions  of  the  Convention  prevents  Member  States 
and/or the EU to facilitate the registration of motor vehicles previously registered in 
another Member State of the EU. Moreover, not all Member States are party to the 
Convention  while  many  other  countries  ratified  or  acceded  to  the  Convention. 
Moreover, any change of the Convention would need the agreement of all the parties 
to  the  Convention,  which  seems  completely  disproportionate  in  order  to  solve  a 
European  problem.  Finally,  an  amendment  of  the  Convention  does  not  prevent  the 
Contracting Parties from formulating a reservation. 

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8.7. 

Annex 7: SME Test 

(1) Consultation with 
SMEs representatives 

of 

categories 

During  the  public  consultation,  the  online  questionnaire, 
hosted  on  the  European  Union’s  website,  was  open  to 
stakeholders.  Tailor-made 
various 
questionnaires for different categories of stakeholders — 
citizens,  businesses  and  public  authorities  —  were 
available in all 22 EU official languages. Information on 
the public consultation was published on several websites 
and  promoted  through  business  networks,  e.g.  through 
the  Enterprise  Europe  Network.  The  Enterprise  Europe 
Network  brings  together  almost  600  business  support 
organisations  from  50  countries  in  order  to  help  small 
companies  in  the  EU  Single  Market.  Of  the  151  replies 
received  from  businesses  during  the  public  consultation 
(143 replies via the public questionnaire and 8 submitted 
as  separate  contributions),  many  were  submitted  by 
SMEs,  namely  businesses  selling  second-hand  vehicles 
(49.0%),  followed  by  leasing  companies  (2.1 %),  car 
rental companies (0.7 %).  

(2) Preliminary 
assessment of businesses 
likely to be affected 

(3) Measurement of the 
impact on SMEs 

the  second-hand 

Two  categories  of  SMEs  are  likely  to  be  affected.  The 
traders. 
first  category  consists  of 
Although  one  can  assume  that  they  will  not  register  the 
motor  vehicles  purchased  in  another  Member  State  and 
that  the  registration  will  be  done  by  the  customer,  a 
professional  second-hand  trader  will  be  in  a  position  to 
provide  its  (potential)  clients  with  all  the  paperwork, 
including  roadworthiness  certificates  and 
inspection 
results. The second category consists of car leasing firms 
and  car  rental  companies  acting  in  the  segment  of 
passenger cars (M1) and light duty motor vehicles (N1). 
They are estimated at around 23,000. Almost the totality 
of the sector is composed by SMEs (99.8%). Only 75 are 
large  enterprises  (250  or  more  employees).  Total 
employment  in  this  sector  is  around  160,000  workers. 
The  biggest  percentage  of  companies  is  located  in 
France,  United  Kingdom,  Germany,  Spain,  Italy  and 
Czech Republic (66% of the total).  

The  impacts  on  SMEs  are  measured  specifically  in  all 
options  separately.  For  leasing  firms  and  car-rental 
companies, a quantitative assessment of the impacts took 
place.  As  regards  the  second-hand  traders,  there  are  no 
precise  statistics  on  the  intra-EU  trade  of  second-hand 
motor  vehicles.  Therefore,  a  qualitative  assessment  with 
respect  to  the  second-hand  market  was  made  for  every 
option. 

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(4) Assess alternative 
options and mitigating 
measures 

At  the  end  of  the  impact  assessment,  there  was  no 
indication  that  the  selected  options  might  result  in  a 
disproportionate burden for SMEs. Consequently, there is 
no element showing the need for SME specific measures 
in  order  to  ensure  compliance  with  the  proportionality 
principle.  

EN 

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