COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the documents Proposal for a regulation of the European Parliament and of the Council amending Regulation (EC) No 443/2009 to define the modalities for reaching the 2020 target to reduce CO2 emissions from new passenger cars and Proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) No 510/2011 to define the modalities for reaching the 2020 target to reduce CO2 emissions from new light commercial vehicles
Date: 2012-07-11
Institutions: European Commission
Subjects: approval, commercial vehicle, greenhouse gas, harmonisation of standards, motor vehicle, reduction of gas emissions, road safety, roadworthiness tests

EUROPEAN COMMISSION 

Brussels, 11.7.2012  
SWD(2012) 214 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the documents 

Proposal for a regulation of the European Parliament and of the Council amending 
Regulation (EC) No 443/2009 to define the modalities for reaching the 2020 target to 
reduce CO2 emissions from new passenger cars  

and 

Proposal for a regulation of the European Parliament and of the Council amending 
Regulation (EU) No 510/2011 to define the modalities for reaching the 2020 target to 
reduce CO2 emissions from new light commercial vehicles 

{COM(2012) 393 final} 
{COM(2012) 394 final} 
{SWD(2012) 213 final} 

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COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the documents 

Proposal for a regulation of the European Parliament and of the Council amending 
Regulation (EC) No 443/2009 to define the modalities for reaching the 2020 target to 
reduce CO2 emissions from new passenger cars  

and 

Proposal for a regulation of the European Parliament and of the Council amending 
Regulation (EU) No 510/2011 to define the modalities for reaching the 2020 target to 
reduce CO2 emissions from new light commercial vehicles 

1. 

PROBLEM DEFINITION 

1.1. 

The nature of the problem 

Road transport is one of the few sectors with rapidly rising emissions and between 1990 and 
2008 emissions from the sector increased by 26%. This trend is not sustainable in view of the 
EU's climate policy. According to the Commission's  'Roadmap  for  moving  to  a  competitive 
low carbon economy in 2050'1 and Transport White Paper2, road transport has to significantly 
reduce its CO2 emissions by 2050. 

Light-duty  vehicles  (LDVs)  are  responsible  for  a  significant  part  of  overall  transport 
emissions  and  emit  around  13.5%  of  total  EU  CO2  emissions  and  about  15%  when  the 
emissions from supplying the fuel are included. In view of the expected increase in the LDV 
fleet,  a  continuation  of  the  effective  application  of  mandatory  CO2  targets  is  necessary  to 
ensure further reduction of road transport emissions of CO2. 

The two-step approach of the Regulations requires that the Commission proposes modalities 
of meeting the 2020 targets by end of 2012. Proposals to amend the Regulations should be "as 
neutral  as  possible  from  the  point  of  competition,  socially  equitable  and  sustainable".3  This 
necessitates  updating  the  formulae  in  Annex  I  to  the  Regulations  for  the  2020  targets.  In 
addition, the vans target for 2020 requires confirmation of feasibility. Modalities are taken to 
mean aspects of the implementation which impact on how the emission targets are achieved. 
The  level  of  stringency  of  the  Regulations  for  2020  is  determined  by  the  target  values 
established within them. The targets were established in the co-decision process and are not 
reconsidered in the review.  

1 
2 

3 

COM/2011/0112 final  
'Roadmap  to  a  Single  European  Transport  Area  –  Towards  a  competitive  and  resource  efficient 
transport system' , COM/2011/0144 final 
Article 13(5) of Regulation (EC) 443/2009 and Article 13(1) of Regulation (EU) 510/2011 

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The two Regulations leave uncertainty for the period beyond 2020. However, the automotive 
industry works to planning cycles that suggest the need to know approximately ten years in 
advance the broad framework within which LDVs need to be designed, and a shorter period 
of around five years for more precise decisions on variants that will actually be produced. It is 
thus  important  to  provide  indications  as  to  the  future  reductions  early  enough  to  allow  for 
appropriate planning certainty. 

1.2. 

How will the problem evolve without new EU action? 

Without action the 2020 car and van CO2 targets could not be implemented and no reduction 
beyond respectively 2015 and 2017 would be required. This is because neither 2020 target can 
take  effect  without  legislation  defining  and  implementing  the  modalities  for  2020.  This 
requires  the  amendment  of  the  Regulations  in  the  ordinary  legislative  procedure.  Without 
further EU action it is likely there would be little additional CO2 reduction from new LDVs. 
Further  progress  in  fuel  efficiency  could  not  be  assumed,  as  evidence  from  the  EU  and  US 
indicates that in the absence of regulatory requirements or large fuel price increases, LDV fuel 
consumption improves at only a modest rate.  

This  'do  nothing'  option  forms  the  baseline  scenario  of  the  Impact  Assessment  and  the 
modelling supporting it. In case of no new EU action the following impacts of implementation 
of the 2020 targets would not be realised: 

• 

• 

• 

An  approximately  25%  reduction  in  car  and  van  oil  consumption,  saving 
approximately  €25bn  in  consumption  a nnually.  Around  25mtoe  per  year  lower 
energy use in 2030, saving in total around 160 mtoe in the period 2020 to 2030. An 
estimated aggregate energy security benefit between 2020 and 2030 of €20bn. 

Avoided fuel use increases progressively from €27bn per year over the 2020 to 2025 
period to €36bn per year over the 2025 to  2030 period. Avoided expenditure on fuel 
imports  is  substituted  by  spending  on  capital  and  technology  which  increases 
domestic demand. Input-output analysis suggests that this can be expected annually 
to increase GDP by around €12bn and e xpenditure on labour by around €9bn.  

Estimated  fuel  savings  from  implementation  of  the  2020  targets  more  than 
compensate  the  expected  costs  of  compliance.  The  net  cost  to  society  ranges  from 
around  minus  €80  to  €230  per  tonne  of  CO 2  avoided  for  cars4  and  minus  €172  to 
€295  for  vans.  The  range  depends  on  the  oil  pr ice  which  for  the  analysis  is  varied 
between $90 and $140 per barrel. 

1.3. 

The stakeholders affected 

The  main  stakeholder  groups  affected  by  the  Regulations  include  the  general  population, 
vehicle  purchasers,  vehicle  manufacturers,  automotive  component  suppliers  and  fuel 
suppliers. The impact routes are primarily as follows: 

• 

• 

• 

4 

The EU population is increasingly affected by the impacts of climate change. 

Buyers  of  vehicles  are  affected  by  possible  vehicle  price  increases  and  reduced 
running  costs  due  to  lower  fuel  consumption.  Fuel  savings  outweigh  vehicle  cost 
increases. 

Vehicle manufacturers are affected by the obligation and need to introduce technical 
CO2 reduction measures. This may increase production costs and affect their product 

Under cost scenario 2 with a 60% slope 

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portfolios.  It  will  give  them  the  opportunity  to  gain  first  mover  advantage  and  the 
potential to sell advanced low CO2 vehicles in other markets.  

Component  suppliers  are  expected  to  benefit  from  higher  demand  for  advanced 
technologies and the possibility to export them to other markets. 

Fuel suppliers are likely to see lower demand for transport fuels. 

Other users of fuel and oil are expected to benefit from lower prices. 

There  will  be  reduced  pressure  on  GHG  emitting  sectors  other  than  transport  to 
further reduce emissions to compensate for increased transport emissions.  

• 

• 

• 

• 

2. 

ANALYSIS OF SUBSIDIARITY 

The EU has already acted in this area when it adopted Regulations (EC) 443/2009 and (EU) 
510/2011 based upon the environment chapter of the Treaty (cars on Article 175 of TEC5 and 
vans on Article 192(1) of TFEU6). The single market also provides grounds to act at EU level 
rather  than  at  Member  State  level  so  as  to  ensure  common  requirements  across  the  EU  and 
thus minimise costs for manufacturers. 

3. 

OBJECTIVES 

GENERAL 

Provide for a high level of environmental protection in the European Union and contribute to 
reaching the EU's climate change targets while reducing oil consumption, thus improving the 
security of energy supply in the EU, stimulating innovation and boosting competitiveness of 
the EU industry. 

SPECIFIC 

Ensure  the  continued  and  effective  application  of  the  car  and  van  CO2  regulations 
particularly in respect of the 2020 targets.  

OPERATIONAL 

•  Ensure that the 2020 van CO2 target is feasible. 

•  Ensure the environmental benefits of the 2020 light duty vehicle CO2 targets are achieved 

cost-effectively. 

•  Ensure  the  modalities  of  achieving  the  2020  targets  do  not  have  unacceptable  social 

impacts.  

•  Ensure 

the  modalities  of  achieving 

the  2020 

targets  do  not  have  undesired 

competitiveness impacts for the EU automotive sector. 

•  Create  sufficient  certainty  for  the  automotive  sector  with  regard  to  future  light  duty 

vehicle CO2 requirements. 

•  Minimise where possible the administrative burden and costs for SMEs of the Regulations. 

5 
6 

Treaty of the European Communities amended by TFEU (see footnote 6) 
Treaty on the Functioning of the European Union 

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4. 

POLICY OPTIONS 

4.1. 

Identification of policy options 

A broad approach has been taken to identifying policy options. These cover issues raised in 
the legislation, those arising with implementation and those assessed in the studies analysing 
possible  approaches  to  improve  the  legislation's  effectiveness.  The  following  aspects  are 
analysed:  

a) 'Do nothing' option; 

b) Confirmation of feasibility of the 2020 target for vans; 

c) Within each modality of meeting the car and van targets different options are analysed: 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

Different utility parameters, shapes and slopes forming the limit value curve 

Excess emissions premia (no change or adjustments) 

Derogations (no continuation, continuation or adjustments) 

Eco-innovations (phase-out or prolongation) 

Phase-in (no phase-in of the 2020 targets or inclusion of phase-in) 

Super-credits (no prolongation, prolongation or modification of the scheme) 

Banking and borrowing 

Combining car and van targets 

Mileage weighting 

Vehicle based limits  

d) Simplification and reduction of administrative burden 

e) Adaptation to the new test cycle 

f) Form and stringency of legislation beyond 2020 

4.2. 

Conclusions of the preliminary assessment of options 

A  preliminary  assessment  has  been  made  of  these  issues,  primarily  based  upon  external 
studies and input from the stakeholders.  

(a) 

'Do nothing' 

This option is equivalent to the baseline scenario and means the car and van 2020 targets are 
not  implemented  due  to  a  lack  of  definition  of  the  modalities  to  meet  them.  This  option  is 
discarded because it is counter to the general, specific and operational objectives.  

(b) 

Confirmation of feasibility of the 2020 target for vans 

The  2010  emissions  data  shows  the  reduction  to  be  achieved  to  meet  the  2020  target  has 
reduced  significantly  without  major  technological  change.  Average  CO2  emissions  in  2010 
reduced  for  all  van  segments  as  compared  to  2007  although  the  level  of  reduction  differed 
between  classes.  The  updated  cost  curves  show  greater  reduction  potential  and  lower  costs 

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compared to the 2009 analysis. The timeframe available for the reduction is consistent with 
development times. As a result, it is concluded that the 2020 van target is feasible. 

(c) 

Modalities of meeting the car and van targets 

The modalities assessed are not alternatives to each other with the exception of phase-in and 
banking  and  borrowing  which  preferably  should  not  be  combined.  Therefore,  for  each 
modality  a  set  of  alternative  policy  options  is  assessed  against  the  objectives  specified  in 
section 3.  

Certain options regarding the utility parameter, the slope of the limit value curve, changes to 
derogations and simplification are retained for further assessment. In addition, it is concluded 
that it may be desirable to continue with the eco-innovation scheme. With regard to the excess 
emissions  premia  these  are  currently  higher  than  the  van  marginal  costs  and  are,  overall, 
consistent with the average car marginal cost. In view of the lower stringency of the van target 
compared to cars and a potential overlap between some larger cars and vans, it is concluded 
that the premia should continue at the current level.  

Phase-in  and  super-credits  are  discarded  from  further  analysis.  The  former  is  not  seen  as 
necessary in view of the current trajectory of new car emissions and the expectation that the 
overall  target  will  be  met  in  2020.  Furthermore,  any  additional  intermediate  targets  would 
make  the  obligation  on  manufacturers  more  costly  due  to  reduced  flexibility.  A  phase-in 
ending later than 2020 would undermine the ambition of the Regulation and thus lead to lower 
CO2  savings.  In  addition,  it  would  undermine  the  regulatory  certainty  for  the  automotive 
industry keen to recoup earlier investments in CO2 reducing technology. These arguments are 
even more pertinent for vans in case of which the 2020 target is easier and less costly to meet. 
Super-credits  for  low  emitting  cars  are  discarded  for  cars  and  vans  based  on  their  potential 
perverse  impact  on  meeting  the  overall  target.  This  approach  undermines  the  effort  needed 
from  conventional  vehicles  by  allowing  them  to  emit  more  and  reduces  the  overall  cost-
effectiveness  of  the  policy.  In  addition,  it  runs  counter  to  the  objective  of  technology 
neutrality.  However,  these  undesirable  impacts  can  be  limited  with  a  low  multiplier  and 
capping the number of affected vehicles. 

Further  modalities  not  present  in  the  current  Regulations  such  as  banking  and  borrowing, 
combining car and van targets, mileage weighting and vehicle based limits are also discarded 
from further analysis as either overly complex, running counter to the objectives of planning 
certainty  and  ensuring  the  environmental  targets  are  achieved,  adding  to  the  administrative 
burden, imposing disproportionate compliance costs on some manufacturer or due to lack of 
sufficiently robust data on mileage of different car segments. 

(d) 

Simplification and reduction of administrative burden 

The potential simplification of the current Regulations and reduction of administrative burden 
are  assessed  for  the  following  provisions:  reduction  of  the  number  of  modalities, 
simplification  of  the  implementing  measures,  simplification  of  rules  for  SMEs  and  micro-
SMEs. Pre-screening of policy options results in a reduction of the number of modalities. In 
addition,  the  implementing  measures  can  mostly  be  simplified  due  to  the  review  provisions 
set out in therein. However, the simplification of rules for SMEs by inclusion of a de-minimis 
threshold and reduction of the administrative burden of the derogation procedure by making it 
more flexible is retained for further analysis. 

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(e) 

Adaptation to the new test cycle 

With  regard  to  adaptation  to  the  new  test  cycle,  the  Regulations  already  empower  the 
Commission to adapt them to a new test procedure. However, since the revised test procedure 
is  unlikely  to  be  adopted  prior  to  the  coming  into  force  of  the  amended  Regulations  this 
cannot be done at present. To minimise uncertainty, it would be possible to describe in outline 
the  principles  and  procedure  that  will  be  used  for  adaptation  of  the  legislation.  This  could 
potentially increase manufacturer certainty and thereby lower compliance costs.  

(f) 

Form and stringency of legislation beyond 2020 

With  regard  to  the  regulatory  regime  beyond  2020  it  is  considered  desirable  to  publish  a 
consultative  communication.  This  would  set  out  the  Commission's  analysis  of  alternative 
regulatory  approaches  and  an  illustration  of  the  likely  range  of  stringency  that  would  be 
required  for  future  CO2  limits.  Future  changes  to  the  regulatory  approach  and  making  the 
level of emission reduction mandatory would be carried out at a second legislative stage. 

4.3. 

Options retained for further analysis 

The following options are taken forward for detailed analysis. 

Car specific options: 

– 

– 

– 

– 

– 

Utility parameter – mass and footprint 

Utility function – linear  

Slope of the limit value curve – 60 to 100% 

Changes to derogations- 'de minimis' rule, amendment of the niche derogation 

Simplification and reduction of administrative burden connected to derogations 

Van specific options: 

– 

– 

– 

– 

– 

Utility parameter – mass and footprint 

Utility function – linear curve for mass and non-linear curve for footprint  

Slope of the limit value curve – 80 to100% 

Changes to derogations- 'de minimis' rule 

Simplification and reduction of administrative burden connected to derogations 

5. 

ASSESSMENT OF IMPACTS 

Policy options have been assessed on the basis of the objectives, ensuring they respond to the 
request that the amendments should be "as neutral as possible from the point of competition, 
socially equitable and sustainable". 

Impact of options with regard to utility parameter 

For cars, the analysis shows a small cost benefit of shifting from mass to footprint since light-
weighting  is  under-incentivised  with  mass  as  the  parameter.  Mass  gives  a  more  even 
distribution over vehicle segments but as a result the relative price increase for smaller cars is 
higher. If footprint is used as the utility parameter, perverse incentives to change the design of 
the  car  are  more  limited  provided  that  the  limit  function  is  not  too  steep.  Footprint  would 

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allow  greater  use  of  light-weighting  as  a  compliance  option,  especially  for  potential  future 
targets beyond 2020. A change of utility parameter would not meet the objective of planning 
certainty  since  it  is  highly  probable  that  manufacturers  have  planned  their  compliance 
pathways to 2020 on the basis of continuation of the current parameter.  

For  vans,  footprint  seems  a  less  desirable  parameter  than  mass  due  to  the  difficulties  for 
manufacturers implicit in a change within 3 years, the increased risks of perverse incentives, 
and  the  need  to  use  a  non-linear  limit  function.  In  addition,  manufacturer  costs  and  price 
increases  are  less  evenly  distributed.  Finally,  planning  certainty  is  also  compromised, 
especially in view of the short time gap between the two targets. 

With regard to innovation, there is unlikely to be an impact on most routes to meet the 2020 
targets  for  both  cars  and  vans,  with  the  exception  of  light-weighting.  In  this  respect  using 
mass as the utility parameter does not treat all options equally. The choice of car or van utility 
parameter  is  considered  to  be  neutral  as  regards  the  competitiveness  of  the  EU  industry. 
Furthermore, it is not expected to have any impact on trade or SMEs. 

For  environmental  impacts,  the  different  utility  parameters  assessed  have  no  direct  impact 
provided certain assumptions are met. There are no social impacts other than higher relative 
price increases for smaller cars with mass. However, this does not apply to vans. 

Impact of options with regard to slope 

For cars a slope above 100% is undesirable as it gives a perverse incentive to manufacturers 
and average costs increase with increasing slope for both parameters. For mass, a slope below 
100% based on 2009 data should avoid a serious risk of perverse incentives. The cost increase 
in  absolute  terms  is  fairly  evenly  distributed  over  the  different  vehicle  segments.  However, 
relative price increases are greater for small than large cars and a lower slope value reduces 
this effect. Lower slope also helps to compensate for the lack of mileage weighting.  

For  vans,  the  slope  of  the  limit  value  curve  preferable  for  a  mass-based  function  is  in  the 
range  80-100%  from  the  cost  and  distributional  perspective.  For  footprint,  the  lowest  cost 
occurs with 110% slope however such a steep slope is likely to give a perverse incentive to 
increase footprint, therefore, a slope around 100% seems preferable. 

The  car  and  van  slopes  are  not  expected  to  have  any  significant  effect  on  innovation, 
competitiveness,  trade  or  SMEs.  Since  there  was  no  previous  expectation  of  which  slope 
would apply for 2020, planning certainty is not affected. 

For environmental impacts, policy options affecting the slope were assessed as having a very 
minor  impact. There are potential secondary  and behavioural impacts  caused  by vehicle-km 
being  slightly  differently  distributed  across  the  fleet.  Therefore,  a  lower  slope  for  cars  is 
desirable  on  environmental  grounds.  This  effect  is  considered  not  relevant  for  vans.  As 
regards social impacts, the slope of the car curve has a distributional impact on relative new 
car prices. As a result a lower slope is desirable. No such impacts are expected for vans which 
are mostly used for business purposes and are purchased based on their utility. 

Derogations 

It  is  considered  to  be  desirable  to  update  the  reduction  effort  required  from  niche 
manufacturers to ensure further reductions beyond 2015. This is in line with the competitive 
neutrality objective since, due to the upper threshold of 300,000 registrations, manufacturers 

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covered by this derogation may hold up to 2.5% of the EU car market before being subject to 
the  normal  CO2  regulatory  regime.  The  niche  CO2  requirements  would  not  have  any  direct 
SME  impact.  The  environmental  impacts  will  be  positive  since  the  manufacturers  will  be 
required to reduce their emissions. 

Impacts of simplification and reduction of administrative burden 

The introduction of a de-minimis threshold for small-volume manufacturers, or the exclusion 
of SME manufacturers, could be considered. Economic benefits would come from a reduced 
administrative  burden  for  the  company  (estimated  at  around  €25,000  per  manufacturer)  and 
the Commission (around €10,000 per application) li nked to avoiding the need for a derogation 
procedure. There would be a marginal environmental impact of smaller emission reductions 
for both cars and vans. Social impacts are expected to be minor. 

Simplification  of  the  administrative  procedure  in  these  cases  would  permit  a  smoother 
assessment process. Simplification is not expected to have any significant environmental and 
social  effects.  Other  than  the  benefits  for  the  companies  directly  affected,  the  de  minimis 
threshold is not expected to have any impact on competitiveness, trade, SMEs or innovation. 

6. 

COMPARISON OF OPTIONS 

The 2020 target of 147g/km for vans is confirmed as feasible. 

Table  1  and  2  below  summarise  the  assessment  of  the  economic,  environmental  and  social 
impacts of the different modalities.  

Based on the analysis it is concluded that the following options should be preferred: 

• 

• 

• 

• 

• 

• 

Utility parameter should continue to be mass for both cars and vans. 

The limit value curve should continue to be linear. 

The slope of the curve should be around 60% for cars and 100% for vans. 

Derogation  schemes  may  be  adjusted  to  exclude  the  very  smallest  manufacturers. 
Furthermore the procedure should be simplified to reduce the administrative burden.  

The reduction effort for niche manufacturers should be updated to reflect the average 
effort required from the industry. 

Excess Emissions Premia should be maintained at €95/g/vehicle. 

7. 

MONITORING AND EVALUATION 

The  core  indicators  of  progress  are  linked  to  the  evolution  of  the  average  new  car  and  van 
fleets. They cover data relating to specific CO2 emissions and utility. The latter is recorded in 
case  a  shift  in  utility  requires  future  adaptation of  the  utility  curve.  Other  utility  parameters 
such as footprint or payload are monitored to assess their appropriateness.  

In  addition,  the  Commission  will  collect  information  regarding  the  number  of  derogation 
applications and the reduction targets proposed by the manufacturers, as well as information 
on the number of eco-innovation applications and granted eco-innovation credits. 

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Table 1 Comparison of impacts of different options for modalities – cars 

Modalities 

Options 

Advantages 

Disadvantages 

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i

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S

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e
D

Mass 

Regulatory certainty- no change from current Regulation. 
More even cost distribution between segments. 

Footprint 

Average additional manufacturer cost is about 2% cheaper than 
with mass. 
Provides greater incentive for light-weighting. 

Slope<100% 

e
v
r
u
c

Slope>100% 

Costs slightly lower overall.  
Avoides serious risk of perverse incentives. 
Compensates for lack of mileage weighting. 
Beneficial impact on overall CO2 and pollutant emissions. 
More  socially  equitable  (lower  relative  price  increase  for 
smaller cars). 
Actual cost increase per vehicle more even between segments. 

fully 

since 

technology  neutral 

Greater risk of perverse incentives than for footprint. 
Not 
disadvantaged. 
Average  additional  manufacturer  cost  is  about  2%  greater  than 
with use of footprint since light-weighting is not rewarded. 
No regulatory certainty- change from current Regulation. 
Less even cost distribution between segments. 
Adjustment costs linked to shift to another utility parameter. 

light-weighting 

is 

Actual cost increase per vehicle less even between segments. 

Costs slightly higher overall.  
Increased risk of perverse incentives. 
Less socially equitable (higher relative price increase for smaller 
cars). 

De  minimis 
threshold 

Reduced  administrative  burden  for  SMEs  and  for 
Commission. 

the 

Marginal reduction of emissions savings. 

More competitively neutral. 
Slightly higher CO2 savings. 

Update 
Niche 
Derogation 

Higher cost for manufacturers benefitting from niche derogation. 

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Table 2 Comparison of impacts of different modalities - vans 

Modalities 

Policy 
options 

Advantages 

Disadvantages 

Mass 

Regulatory certainty- no change from current Regulation. 
More even cost distribution between segments. 
Limited perverse incentives to increase mass. 

Footprint 

Average  additional  manufacturer  cost  slightly  lower  for 
footprint for slopes above 80%. 
Provides greater incentive for light-weighting. 

Slope<100% 

Minimises risk of perverse incentive for both functions. 
Slopes 80-100% lowest costs for mass-based function. 
Costs  lowest  and  most  evenly  distributed  around  100%  slope 
for mass-based function. 

is 

than 

fully 

light-weighting 

technology  neutral 

Average  additional  manufacturer  cost  slightly  higher 
footprint, especially for slopes above 100%. 
Not 
since 
disadvantaged. 
No  regulatory  certainty-  change  from  current  Regulation; 
adjustment  costs  can  be  expected  to  be  higher  due  to  3-year  gap 
between the targets. 
Requires a non-linear limit value function. 
Less even cost distribution between segments. 
The  cost  increase  of  changing  to  footprint  especially  high  for 
some manufacturers. 
Easier  to  manipulate  than  mass  but  it  can  be  limited  by  a  shape 
and slope of the limit value curve. 
Slopes 60-80% highest costs for footprint-based function. 
Slopes  below  80%  lead  to  uneven  distribution  of  costs  between 
segments. 

Slope>100% 

Lower costs for footprint-based function above 100%. 
More  even  distribution  for  footprint-based  function  between 
segments above 110% slope. 

Increased risk of perverse incentives for both parameters. 
Highest  costs  and  less  even  distribution  between  segments  for 
mass-based function above 110% slope. 

De minimis 
threshold 

Reduced  administrative  burden  for  SMEs  and  for 
Commission. 

the 

Marginal reduction of emissions savings. 

r
e
t
e
m
a
r
a
p
y
t
i
l
i
t

U

t
i

m

i
l

e
h
t

f
o

e
p
o
l

S

s
n
o
i
t
a
g
o
r
e
D

e
v
r
u
c

e
u

l
a
v

EN 

11 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
EN 

12 

EN