REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Directive 2007/38/EC on the retrofitting of mirrors to heavy goods vehicles registered in the Community
Date: 2012-06-04
Institutions: European Commission
Subjects: Community certification, commercial vehicle, safety device, safety standard, technical standard

EUROPEAN COMMISSION 

Brussels, 4.6.2012  
COM(2012) 258 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the implementation of Directive 2007/38/EC on the retrofitting of mirrors to heavy 
goods vehicles registered in the Community 

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REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the implementation of Directive 2007/38/EC on the retrofitting of mirrors to heavy 
goods vehicles registered in the Community 

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TABLE OF CONTENTS 

1. 

2. 

3. 

3.1. 

3.2. 

4. 

5. 

6. 

6.1. 

6.2. 

6.3. 

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

Blind spots as a factor in road accidents ...................................................................... 5 

EU legislation on the field of vision ............................................................................ 5 

The 2003 directive on type-approval ........................................................................... 6 

The Retrofitting Directive ............................................................................................ 7 

Transposing the Retrofitting Directive......................................................................... 7 

Implementing the Retrofitting Directive...................................................................... 8 

The effects of retrofitting blind spot mirrors................................................................ 9 

Methodology for assessing the results achieved by blind spot mirrors ....................... 9 

Findings of the study.................................................................................................. 10 

How to improve the situation..................................................................................... 11 

6.3.1.  Action to improve vehicles ........................................................................................ 11 

6.3.2.  Action targeting road users ........................................................................................ 12 

6.3.3.  Action to improve infrastructure................................................................................ 12 

7. 

8. 

9. 

The way forward ........................................................................................................ 12 

Conclusions ................................................................................................................ 13 

Annex ......................................................................................................................... 15 

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1. 

INTRODUCTION 

A significant number of road accidents involve larger vehicles when their drivers are 
not aware of the presence of other road users very close to them. 

These accidents are often related to a change of direction at  crossings, junctions or 
roundabouts when the drivers fail to see other road users that are placed in a ‘blind 
spot’. Blind spots are areas around a vehicle that cannot be seen by the driver, either 
by  looking  directly  through  the  windows  or  indirectly  using  the  mirrors  or  other 
devices. 

Particularly  important  for  road  safety  are  blind  spots  in  heavy  goods  vehicles 
(HGVs), i.e. vehicles designed for transporting goods and having a maximum mass1 
of  more  than  3.5  tonnes.  Blind  spots  are  significant  factors  in  accidents  involving 
HGVs and vulnerable road users such as motorcyclists, cyclists and pedestrians. 

Improvements  in  technology  and  a  better  understanding  of  the  causes  of  accidents 
have  led  the  EU  to  adopt  legislation  aimed  at  reducing  by  means  of  appropriate 
devices the number and size of blind spots and consequently the number of accidents 
and fatalities. Directive 2003/97/EC2 requires all new vehicles put into circulation in 
the EU as of 27 January 2007 to be equipped with blind spot mirrors. 

In  the  light  of  a  study  carried  out  in  20043,  the  Commission  decided  that  it  would 
also be cost-effective to retrofit existing HGVs with mirrors of the kind required for 
new vehicles. 

The  Commission’s  proposal  was  adopted  by  the  European  Parliament  and  the 
Council  as  Directive  2007/38/EC4  on  the  retrofitting  of  mirrors  to  heavy  goods 
vehicles, which will be referred to in this report as the ‘Retrofitting Directive’. 

This  report  has  been  drawn  up  in  accordance  with  Article  5  of  the  Retrofitting 
Directive, which requires the Commission to: 

• 

• 

report on the implementation of the Directive; 

consider whether revision of the existing legislation is necessary. 

2. 

BLIND SPOTS AS A FACTOR IN ROAD ACCIDENTS 

Accident  research5  has  shown  that  blind  spots  increase  the  risk  of  accidents, 
particularly  those  involving  HGVs  and  small  road  users  such  as  motorcycle  and 

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Technically permissible maximum laden mass. 
Directive  2003/97/EC  of  the  European  Parliament  and  of  the  Council  of  10  November  2003  on  the 
approximation  of  the  laws  of  the  Member  States  relating  to  the  type-approval  of  devices  for  indirect 
vision  and  of  vehicles  equipped  with  these  devices,  amending  Directive  70/156/EEC  and  repealing 
Directive 71/127/EEC, OJ L 25, 29.1.2004, p. 1–45. 
Cost-benefit analysis of blind spot mirrors: 
http://ec.europa.eu/transport/road_safety/pdf/projects/mirrors.pdf. 
Directive 2007/38/EC of the European Parliament and of the Council of 11 July 2007 on the retrofitting 
of mirrors to heavy goods vehicles registered in the Community, OJ L 184, 14.7.2007, p. 25–28. 

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moped riders, cyclists or pedestrians, and that mirrors or other devices that enhance 
the field of vision and reduce or eliminate blind spots can be effective in preventing a 
significant proportion of these accidents. 

This  is  particularly  true  when  an  HGV  is  carrying  out  what  is  known  as  a  ‘critical 
manoeuvre’  —  for  example,  when  it  is  turning  right  (or  left  in  countries  where 
vehicles drive on the left) and a motorcycle, moped or bicycle is next to the HVG on 
its passenger side. This manoeuvre may also be dangerous for pedestrians, but to a 
lesser extent. 

Other  critical  manoeuvres  carried  out  by  an  HGV  involve  changing  lanes  when  a 
motorcycle, moped or bicycle is alongside it, and setting off when a vulnerable road 
user, especially a pedestrian, is in front of the HGV. 

Accidents  involving  HGVs  and  cyclists  are  more  common  in  urban  areas,  while 
those involving motorcycles happen mostly in non-urban areas. 

The great variety of traffic patterns across the EU makes it difficult to quantify the 
number  of  accidents  or  fatalities  that  can  be  attributed  to  blind  spots.  Moreover, 
accident databases generally do not include information that would make it possible 
to  establish  a  causal  link  between  an  accident  and  a  blind  spot.  Consequently,  the 
number of accidents where an HGV’s blind spot has played a decisive role can only 
be assessed through in-depth investigations. 

The  above-mentioned  cost-benefit  analysis  assumed  that,  in  56 %  of  the  accidents 
involving a cyclist or a motorcycle/moped rider, the HGV was turning right (or left 
in a country where vehicles drive on the left). It was also assumed that 40 % of those 
accidents could be prevented by fitting the HGV with mirrors with an enhanced field 
of vision. 

On  this  basis,  in  2007  the  Commission  estimated  that  approximately  400  fatalities 
per year could be attributed to blind spots6. 

3. 

EU LEGISLATION ON THE FIELD OF VISION 

EU  legislation  on  the  ‘type-approval  of  systems  for  indirect  vision’  dates  back  to 
1971.  The  first  piece  of  legislation  was  Directive  71/127/EEC7  on  the  rear-view 
mirrors  of  motor  vehicles.  This  directive  was  amended  by  a  number  of  subsequent 
directives that added more advanced mirrors and required them to be fitted to a wider 
range of vehicles. 

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Truck accident causation study (ETAC 2007): 
http://ec.europa.eu/transport/roadsafety_library/publications/etac_exec_summary.pdf. 
Commission  Staff  Working  Document  accompanying  the  Proposal  for  a  Directive  of  the  European 
Parliament  and  of  the  Council  on  the retrofitting  of  mirrors  to  heavy  goods  vehicles  registered  in  the 
Community. Full impact assessment. SEC(2006) 1238. 
Council Directive 71/127/EEC of 1 March 1971 on the approximation of the laws of the Member States 
relating to the rear-view mirrors of motor vehicles, OJ L 68, 22.3.1971, p. 1–17. 

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3.1. 

The 2003 directive on type-approval 

A  significant  change  in  the  legal  framework  was  made  by  Directive  2003/97/EC. 
This repealed Directive 71/127/EEC and laid down common mandatory requirements 
for mirrors, and for the first time allowed other systems for indirect vision. 

In the new Directive, the mirrors are classified into six categories, according to their 
field  of  vision.  Some  of  them  are  commonly  referred  to  as  ‘blind  spot  mirrors’ 
because they were designed to reduce or eliminate blind spots. They can be briefly 
described as follows. 

(a)  Wide-angle exterior mirrors, named ‘class IV’ mirrors. These cover an area on 
both sides of the vehicle which starts closer to the driver’s position and is much 
wider to the side than the area covered by the normal (‘class II’) rear mirror. 

(b)  Close-proximity exterior mirrors, named ‘class V’ mirrors. These cover an area 

immediately adjacent to the vehicle cab on the passenger’s side. 

(c)  Front  mirrors,  named  ‘class  VI’  mirrors.  These  cover  the  area  in  front  of  the 

vehicle which cannot be seen from the driving position. 

The  new  requirements  for  class  IV  (wide-angle)  and  class  V  (close-proximity) 
mirrors laid down in the 2003 Directive significantly increased the driver’s field of 
vision compared to the previous Directive. The ground area covered by the new class 
IV  mirrors increased by 43 % while the area covered by class V mirrors more than 
doubled. Class VI mirrors were included in EU law for the first time. 

Figure  2  in  the  Annex  to  this  report  sums  up  the  changes  to  the  field  of  vision 
provided  by  class  IV  (on  the  passenger’s  side)  and  V  mirrors,  as  required  by 
Directive 2003/97/EC. 

According to that Directive, all new HGVs with a maximum mass of more than 7.5 
tonnes had to be fitted with class IV, V and VI mirrors by 26 January 2007. HGVs 
with a maximum mass of less than 7.5 tonnes had to be fitted with class IV and V 
mirrors but were exempted from the obligation to install class VI mirrors. 

The General Safety Regulation8 repeals Directive 2003/97/EC as from 1 November 
2014  and  replaces  it  by  Regulation  No  46  adopted  under  the  United  Nations 
Economic  Commission  for  Europe  (UNECE).  This  does  not  bring  any  changes 
relative to the requirements of Directive 2003/97/EC concerning mirrors but results 
in  these  requirements  being  applied  to  vehicles  registered  in  countries  outside  the 
EU. 

3.2. 

The Retrofitting Directive 

The Commission considered that it would take a long time — at least 16 years — to 
bring all HGVs in Europe into line with the requirements of Directive 2003/97/EC, 
given the need to completely renew the HGV fleet. 

8 

Regulation  (EC)  No  661/2009  of  the  European  Parliament  and  of  the  Council  of  13  July  2009 
concerning  type-approval  requirements  for  the  general  safety  of  motor  vehicles,  their  trailers  and 
systems, components and separate technical units intended therefor, OJ L 200, 31.7.2009, p. 1–24. 

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The  Commission  also  estimated  that  approximately  400  fatalities  every  year  were 
caused by HGV blind spots. It therefore proposed to make it compulsory to retrofit 
blind spot mirrors to existing vehicles as a cost-effective measure to reduce accidents 
and fatalities. The Commission’s proposal was adopted as the Retrofitting Directive 
(Directive 2007/38/EC). 

The Retrofitting Directive applies to vehicles designed to carry goods and having a 
maximum  mass  of  between  3.5  and  12  tonnes  (category  N2)  and  those  having  a 
maximum mass of more than 12 tonnes (category N3), which were registered as from 
1 January 2000. In accordance with Article 3 of the Directive, these vehicles had to 
be fitted with class IV and V mirrors by 31 March 2009 at the latest. 

Article  2(2)  of  the  Retrofitting  Directive  exempted  HGVs  weighing  less  than  7.5 
tonnes on which it was not possible to fit class V mirrors. It also exempted HGVs to 
which  national  rules  already  applied  before  the  Directive  became  part  of  national 
law.  Special  allowance  was  also  made  for  vehicles  already  fitted  with  mirrors  that 
covered  a  field  of  vision  only  slightly  smaller  than  what  was  required  under  the 
Directive. 

In cases where it was impossible to fit mirrors complying with the new requirements, 
Article  3(3)  of  the  Directive  allowed  the  use  of  alternative  technical  solutions, 
including  supplementary  mirrors  or  other  devices  such  as  monitor  and  camera 
systems.  Member  States  where  such  alternatives  were  used  had  to  send  the 
Commission their list of acceptable technical solutions. 

4. 

TRANSPOSING THE RETROFITTING DIRECTIVE 

The  deadline  for  transposing  the  Directive  into  national  law  was  6  August  2008, 
allowing the vehicles concerned to be retrofitted with blind spot mirrors by 31 March 
2009.  The  Commission  took  legal  action  (‘infringement  procedures’)  against  some 
Member  States  for  failing  to  notify  it  accordingly.  Full  transposition  was  finally 
achieved by June 2009. The transposition dates are shown in Table 1 below. 

Generally,  the  transposition  of  this  Directive  into  national  legislation  was 
unproblematic  and  —  except  in  some  cases  —  was  done  on  time.  In  one  Member 
State  (Denmark),  transposition  took  place  well  ahead  of  the  deadline,  since 
corresponding national rules were already in place when the Directive was adopted. 

Table 1. Dates on which Member States transposed Directive 2007/38/EC 

Belgium 

Bulgaria 

21/02/2008 Luxemburg 

14/11/2008 Hungary 

Czech Republic 

27/10/2008 Malta 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

1/10/2004 Netherlands 

29/09/2007 Austria 

18/12/2007 Poland 

8/08/2008 Portugal 

25/08/2008 Romania 

28/05/2009 

14/08/2008 

14/12/2007 

28/08/2008 

11/10/2007 

12/06/2009 

17/11/2008 

15/08/2008 

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Spain 

France 

Italy 

Cyprus 

Latvia 

11/06/2008 Slovenia 

30/04/2008 Slovakia 

31/03/2008 Finland 

22/05/2009 Sweden 

29/10/2008 United Kingdom 

17/12/2007 

1/04/2008 

17/12/2007 

2/06/2008 

31/03/2009 

Lithuania 

26/07/2008

5. 

IMPLEMENTING THE RETROFITTING DIRECTIVE 

The  Commission  asked  Member  States  to  report  on  the  implementation  of  the 
Retrofitting  Directive  by  filling  in  a  questionnaire.  Only  thirteen  Member  States 
responded9 to this request. 

Before  the  transposition  date,  the  Netherlands  and  Denmark  had  already  adopted 
national  rules  requiring  vehicles  covered  by  the  Directive  to  be  fitted  with  mirrors 
that provided the enhanced field of vision. These rules applied to vehicles registered 
before 1 January 2000 or type N2 vehicles weighing less than 7.5 tonnes. 

Only  five  Member  States  said  that  they  permitted  alternative  technical  solutions  as 
provided  for  in  Article  3(3)  of  the  Directive.  In  accordance  with  Article  3(4),  the 
Netherlands  notified  the  Commission  of  an  alternative  technical  solution  it  had 
adopted.  The  Commission  then  published  this  information  on  the  road  safety 
website10, as required by the Directive. 

On  18  December  2007,  the  Technical  Adaptation  Committee  set  up  under  the 
Roadworthiness Directive11 discussed the implementation of the specific provisions 
of Article 4(2) of the Retrofitting Directive. 

They  came  to  the  conclusion  that  the  Roadworthiness  Directive  did  not  need  to  be 
amended,  since  it  already  required  annual  tests  for  the  vehicles  covered  by  the 
Retrofitting  Directive,  and  these  compulsory  tests  included  rear-view  mirrors  and 
their field of vision. Member States were free to adopt their own rules on the testing 
procedures.  The  Commission  made  some  recommendations  on  how  to  carry  out 
these tests. 

From the answers to the questionnaire there appear to have been no major problems 
in  implementing  the  Retrofitting  Directive.  However,  most  Member  States  had  no 
detailed information on how many vehicles failed their roadworthiness test because 
they failed to comply with the retrofitting requirements. Technical inspection records 
show  whether  a  vehicle  had  mirror  problems,  but  they  do  not  specify  whether  the 
mirrors failed to comply with the Retrofitting Directive or had other types of defect. 

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11 

Denmark, Germany, Ireland, Spain, France, Italy, Latvia, Luxembourg, Netherlands, Poland, Romania, 
Slovakia, Finland. 
http://ec.europa.eu/transport/road_safety/vehicles/blind_spot_mirrors_en.htm. 
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. 1–19. 

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6. 

THE EFFECTS OF RETROFITTING BLIND SPOT MIRRORS 

In 2011 the Commission carried out a study on blind spot accidents as required by 
Article  5  of  the  Retrofitting  Directive.  The  purpose  of  the  study  was  to  update  the 
2004 cost-benefit analysis and to compare the situation before and after the Directive 
was  implemented.  The  study  included  a  review  of  how  Member  States  had 
implemented the Directive (presented in sections 4 and 5 above) and an assessment 
of  the  effectiveness  of  retrofitting  blind  spot  mirrors  in  terms  of  the  number  of 
fatalities avoided. 

6.1.  Methodology for assessing the results achieved by blind spot mirrors 

The study used the same methodology as the 2004 cost-benefit analysis. In essence, 
this involved calculating the expected trend in fatalities if blind spot mirrors were or 
were not retrofitted. 

In the 2011 study these calculations were updated and the result was then compared 
with the actual number of fatalities according to the official statistics recorded in the 
CARE database. 

The methodology can be briefly described as follows. 

(1)  To calculate the number of fatalities if blind spot mirrors were not retrofitted, it 

was assumed that: 

(a) 

(b) 

the  overall  number  of  road  fatalities  would  continue  to  decline  at  the 
same yearly rate as observed in previous years; 

fatalities  resulting  from  accidents  involving  vulnerable  road  users  and 
HGVs would continue to represent the same proportion of total fatalities. 

(2)  To calculate the number of fatalities if blind spot mirrors were retrofitted: 

(a)  only  accidents  involving  motorcycles,  mopeds  and  bicycles  were 
considered, and only those where the HGV was turning right (or  left in 
countries where vehicles drive on the left); 

(b) 

(c) 

(d) 

in  accidents  involving  an  HGV  turning  right  (or  left  in  some  countries) 
and a bicycle, moped or motorcycle, the proportion of fatal accidents was 
taken to be 56 %; 

it was assumed that 40 % of such fatalities could be prevented by fitting 
the new blind spot mirrors; 

the number of fatalities that would be avoided by fitting the new blind-
spot mirrors was considered to be proportional to the number of HGVs to 
be retrofitted. 

These  calculations  were  updated  using  actual  accident  data  to  2005  and  the  results 
were compared with the actual figures. 

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6.2. 

Findings of the study 

It  was  estimated  that  in  2009  there  were  approximately  3.7  million  vehicles  to  be 
retrofitted as a result of the Directive. 

Updating the calculations performed when the Directive was adopted showed that the 
total number of fatal accidents involving an HGV and vulnerable road users would 
have been expected to decrease by 21.5 % between 2005 and 2009 as a result of the 
Retrofitting  Directive.  In  reality  the  actual  number  of  fatalities  in  this  type  of 
accident decreased by 27.5 % over this period. 

The  trend  in  the  actual  number  of  fatal  accidents  involving  HGVs  and  vulnerable 
road  users  is  shown  in  Annex  1.  The  comparison  suggests  that  the  retrofitting  has 
been effective. As shown in Figure 1 below, the total number of vulnerable road user 
fatalities  actually  recorded  is  lower  than  what  was  estimated  to  be  the  result  of  the 
Retrofitting Directive. 

However, the extent to which this positive trend can be attributed to the Retrofitting 
Directive remains uncertain. For one thing, the number of pedal cyclist fatalities had 
already fallen sharply in 2006, before the Retrofitting Directive was implemented. 

Figure 1 

Expected and observed trends in the number of vulnerable
road user fatalities from accidents involving HGVs

s
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2000

1800

1600

1400

1200

1000

800

600

400

200

0

Business as usual prediction (no new mirrors)

Expected trend with new mirrors (updated)

Actual observed number

2001

2002

2003

2004

2005

2006

2007

2008

2009

Year

It  should  also  be  noted  that  the  available  data  cover  a  very  short  period  after  the 
implementation  of  the  Retrofitting  Directive.  The  date  after  which  the  vehicles 
concerned would fail a roadworthiness test if they did not comply with the Directive 
was 31 March 2009. When the implementation study was carried out, however, the 
CARE database contained no data more recent than the end of 2009. So it is possible 
that the full effect of the Directive will not be seen until a longer time series of data 
is available. 

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The CARE database contains information on the circumstances of accidents but not 
on the contributing factors. It is thus impossible to precisely identify those accidents 
in which blind spots may have been a contributing factor. This was also a constraint 
on the original 2004 study on the cost-effectiveness of retrofitting blind spot mirrors 
to existing vehicles. To overcome this difficulty, the share of accidents attributable to 
blind spots and the effectiveness of the mirrors in preventing them were both taken 
from  in-depth  research  studies  carried  out  by  some  Member  States,  as  explained 
above. 

To  sum  up,  there  is  a  downward  trend  in  the  number  of  fatal  accidents  involving 
vulnerable road users and HGVs, but it is not clear how much of this progress can be 
attributed to the Retrofitting Directive, or if even better results could be achieved by 
imposing additional technical requirements. 

6.3. 

How to improve the situation 

Despite  the  reduction  in  the  number  of  fatal  accidents  involving  vulnerable  road 
users and HGVs, there is still room for improvement. However, there is no single or 
simple  solution  that  can  bring  about  a  substantial  reduction  in  the  number  of 
accidents and fatalities. Action should be taken to improve both the vehicles and the 
behaviour of road users. 

6.3.1.  Action to improve vehicles 

Where the vehicle is concerned, technical improvements could help to further reduce 
blind spot accidents. These improvements fall into two categories. 

(1)  Reducing or eliminating blind spots 

The  simplest  solutions  consist  in  fitting  additional  mirrors  or  Fresnel  lenses. 
The  latter  allow  the  HGV  driver  to  see  a  vulnerable  road  user  who  is 
immediately next to the vehicle on the driver’s side. 

Monitor and camera systems could either complement or replace some mirrors. 
They show one or more images of the vehicle’s sides displayed on a monitor 
inside the cab. 

The driver’s direct vision, i.e. without using technical aids, can be improved by 
better designing both the cab windows and the position of the driver. A balance 
has to be struck between the vision requirement and other constraints. 

(2)  Warning the driver of a potential danger 

HGVs  can  be  fitted  with  devices  that  warn  the  driver  about  the  presence  of 
vulnerable  road  users.  For  example,  ultrasound  sensors  that  detect  vulnerable 
road users when they are in close proximity to the vehicle and alert the driver 
by  means  of  audible  or  visual  signals.  These  systems  can  also  warn  the 
vulnerable road user of a potentially dangerous manoeuvre by the HGV. 

The  cost-effectiveness  of  these  technical  devices  has  not  yet  been  thoroughly 
assessed and the available studies are not conclusive. In particular, it is not clear that 
the  benefits  would  increase  in  proportion  to  the  number  of  technical  devices  fitted. 

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All  of  them  (with  the  exception  of  better  windows)  impose  on  the  driver  an 
additional workload which may adversely affect his ability to use them efficiently. It 
must also be borne in mind that warning systems do not exempt the driver from the 
responsibility  of  using  all  the  means  available,  including  mirrors,  to  check  for  the 
presence of vulnerable road users. 

6.3.2.  Action targeting road users 

There is room for improvement in the behaviour of both HGV drivers and vulnerable 
road users. Professional and licence training, particularly for HGV drivers, should do 
more to stress the dangers of blind spots and to teach the necessary skills for dealing 
with them. Vulnerable road users also need to be aware that, because of blind spots, 
the  driver  of  an  HGV  cannot  always  see  them.  This  is  particularly  important  for 
cyclists. Training schemes and targeted awareness-raising campaigns are an effective 
way to address vulnerable road users. 

6.3.3.  Action to improve infrastructure 

Roadside mirrors and other external devices can be installed at intersections to help 
drivers detect the presence of vulnerable road users. 

Traffic  management  measures,  such  as  traffic  segregation  or  speed  reduction,  may 
also  help  reduce  blind  spot  accidents,  particularly  those  involving  cyclists  and 
pedestrians in urban areas. 

7. 

THE WAY FORWARD 

The  Commission  departments  concerned  will  continue  to  monitor  accident  data  in 
order to see whether  the  number of accidents involving HGVs and vulnerable  road 
users continues to fall, as it did until 2009. Further in-depth accident investigation is 
needed  to  update  our  knowledge  of  the  extent  to  which  blind  spots  lead  to  fatal 
collisions between vulnerable road users and HGVs. 

Moreover,  the  contribution  of  blind  spots  to  road  injuries  still  needs  to  be  better 
assessed. Measures to ensure proper reporting of blind spot accidents will be a part of 
the EU’s strategy to counter road traffic injuries. 

Technology,  already  available  or  being  developed,  could  help  to  further  reduce 
accidents  involving  vulnerable  road  users  and  HGVs.  It  includes  camera  and 
monitoring  devices  and  detection  and  warning  systems.  The  Commission  believes 
that further research is needed to assess their potential and cost-effectiveness. They 
are still at an early stage of development, and we must beware of overloading HGV 
drivers with extra devices that may distract them. 

Discussions are under way at the UN-ECE on improvement of HGVs’ field of vision. 
In particular UN-ECE is developing technical requirements for the type-approval of 
monitor  and  camera  systems.  Once  these  requirements  are  established,  only  type-
approved systems will be allowed on HGVs registered in the EU12. The replacement 

12 

This obligation will apply as from 26 July 2013. Series of Amendments 03 to UNECE Regulation No 
46 (Add.45/Rev.4) in adoption process. 

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of  mirrors  by  monitor  and  camera  systems  is  amongst  the  possibilities  being 
discussed for future improvements in the field of vision. 

Revision of the current EU legislation will only be appropriate once further evidence 
becomes available that justifies fitting additional devices to vehicles on a mandatory 
basis. 

Meanwhile,  there  are  various  other  ways  of  potentially  preventing  blind-spot 
accidents — not by adding technical equipment to vehicles but rather by improving 
road infrastructure and the behaviour of road users. 

As part of the CARS 2113 process, the Commission will discuss with Member States 
and stakeholders what further action ought to be taken to deal with blind spots. 

The  Commission  has  launched  a  public  consultation  on  amending  the  Directive  on 
the  weights  and  dimensions  of  HGVs  with  the  aim  of  improving,  amongst  other 
aspects,  their  design  in  terms  of  road  safety.  The  revision  of  this  Directive  will 
provide  an  opportunity  for  looking  at  possible  improvements  to  the  driver’s  direct 
field of vision, as explained above. 

A  grant  from  the  Commission  helps  to  finance  the  BIKE  PAL14  project,  which 
includes  demonstrations  of  the  HGV  driver’s  field  of  vision  in  order  to  raise 
awareness  among  cyclists.  The  Commission  also  helps  to  finance  the  Safecycle15 
project,  which  will  identify  information  and  communication  technologies  that  can 
improve the safety of cyclists. 

8. 

CONCLUSIONS 

The  Directive  on  the  retrofitting  of  blind  spot  mirrors  has  been  successfully 
implemented  by  EU  Member  States.  No  major  technical  difficulties  were 
encountered, though some countries were late in transposing the Directive into their 
national legislation. 

The  number  of  vulnerable  road  users  killed  in  a  collision  with  an  HGV  fell 
substantially  from  2001  till  the  end  of  2009.  The  assessment  carried  out  by 
Commission  staff  suggests  that  blind  spot  mirrors  have  contributed  to  this  trend, 
especially where cyclists are concerned: research shows that cyclists are particularly 
vulnerable to accidents caused by blind spots. 

However,  on  the  basis  of  the  available  data  it  is  not  possible  to  establish  the 
proportion  of  HGV  accidents  in  which  blind  spots  were  a  contributing  factor.  This 
can only be estimated from in-depth studies which have a very limited coverage and 
are  based  on  data  collected  before  the  Retrofitting  Directive  was  implemented. 
Consequently, it is not possible to distinguish between the effect of retrofitting blind 
spot  mirrors  to  existing  vehicles  and  the  effect  of  fitting  such  mirrors  to  new 
vehicles. Moreover, it is not possible to separate the effect of blind spot mirrors from 
the general downward trend in the number of fatal road accidents. 

13 
14 
15 

‘Competitive Regulatory System for the 21st century’. 
http://www.etsc.eu/documents/ETSC_BIKE_PAL.pdf. 
http://www.safecycle.eu/. 

EN 

13 

   EN 

 
                                                 
Despite the very positive reduction in the number of vulnerable road users killed in 
road accidents, there are still more than 1 200 such deaths each year resulting from 
accidents involving an HGV. Efforts to prevent these accidents must be pursued and 
the Commission is committed to working on this issue as one of its priorities for the 
period 2011-202016. 

The  Commission  will  follow  closely  any  technological  developments  aimed  at 
preventing blind spot accidents which may be incorporated into new vehicles in the 
future, once they prove their cost-effectiveness. 

The  Commission  will  continue  to  promote  better  training  and  awareness,  both  for 
HGV  drivers  and  for  vulnerable  road  users,  along  with  actions  aimed  at  improving 
infrastructure  so  that  vulnerable  road  users  and  HGVs  can  safely  share  it.

16 

COM(2010) 389 final, Towards a European Road Safety Area: policy orientations on road safety 2011-
2020. 

EN 

14 

   EN 

 
                                                 
9. 

ANNEX 

Table 2. Trend in the number of fatalities in accidents involving HGVs 
and vulnerable road users in 19 Member States * 

Type of vulnerable road user 

Motorcycle 

Moped 

Bicycle 

Pedestrian 

Total 

318 

308 

315 

298 

298 

308 

289 

301 

249 

170

148

150

140

135

130

102

110

83

427

424

395

410

401

337

353

288

250

972 

961 

918 

913 

835 

773 

837 

738 

628 

1 887

1 841

1 778

1 761

1 669

1 548

1 581

1 437

1 210

Year 

2001 

2002 

2003 

2004 

2005 

2006 

2007 

2008 

2009 

* Data extracted from the CARE database for 19 Member States: EU 15 plus CZ, SI, PL and RO 

EN 

15 

   EN 

 
Figure 2 

EN 

16 

EN