COMMISSION STAFF WORKING DOCUMENT Accompanying the document REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC and REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union and repealing Directive 2000/30/EC and DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Council Directive 1999/37/EC on the registration documents for vehicles Summary of IMPACT ASSESSMENT
Date: 2012-07-13
Institutions: European Commission
Subjects: approval, commercial vehicle, data recording, harmonisation of standards, motor vehicle, reduction of gas emissions, road safety, roadworthiness tests, vehicle documents, vehicle registration

EUROPEAN COMMISSION 

Brussels, 13.7.2012  
SWD(2012) 207 final 

ROADWORTHINESS PACKAGE 

COMMISSION STAFF WORKING DOCUMENT 
Accompanying the document 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on 
periodic roadworthiness tests for motor vehicles and their trailers and repealing 
Directive 2009/40/EC 
and 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on 
the technical roadside inspection of the roadworthiness of commercial vehicles 
circulating in the Union and repealing Directive 2000/30/EC 
and 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
amending Council Directive 1999/37/EC on the registration documents for vehicles 

Summary of IMPACT ASSESSMENT 

{COM(2012) 380 final}_{SWD(2012) 206 final} 

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COMMISSION STAFF WORKING DOCUMENT 
Accompanying the document 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on 
periodic roadworthiness tests for motor vehicles and their trailers and repealing 
Directive 2009/40/EC 
and 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on 
the technical roadside inspection of the roadworthiness of commercial vehicles 
circulating in the Union and repealing Directive 2000/30/EC 
and 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
amending Council Directive 1999/37/EC on the registration documents for vehicles 

Summary of IMPACT ASSESSMENT 

1. PROBLEM DEFINITION 

Directive 2009/40/EC fixes minimum standards for the periodic technical inspection (PTI) of 
motor  road  vehicles.  The  role  of  PTI  is  to  ensure  that  vehicles  in  operation  are  properly 
maintained  and  tested,  so  that  their  performance  remains  in  accordance  with  the  type-
approval1  throughout  their  lifetime.  Directive  2009/40/EC  is  complemented  by  Directive 
2000/30/EC,  which  provides  the  requirement  to  control  the  technical  state  of  commercial 
vehicles in between periodic inspections (roadside inspections – RSI). 

On 20 July 2010 the Commission adopted policy orientations on road in whichit announced 
the  harmonisation  and  progressive  strengthening  of  EU  legislation  on  roadworthiness  tests 
and  on  technical  roadside  inspections;  the  inclusion  of  powered-two  wheelers  in  vehicle 
inspections;  and  the  possible  setting-up  of  a  European  electronic  platform  with  a  view  to 
harmonise and to exchange vehicle data. 

The  stakeholder  consultation  and  the  analysis  by  the  Commission  allowed  identifying  one 
main  problem  with  the  current  PTI  system  in  Europe:  there  are  too  many  vehicles  with 
technical defects on the road. Indeed, studies from the UK and Germany indicate that up to 
10%  of  cars  at  any  point  in  time  have  a  defect  that  would  cause  them  to  fail  the  PTI  test. 
Moreover,  many  technical  defects  with  serious  implications  for  security  (mainly  related  to 
electronic  safety  components  such  as  ABS,  ESC)  are  not  even  checked  at  PTI  tests  as 
conducted under current rules. 

Technical defects contribute heavily to accidents: it is estimated that they are responsible for 
6%  of  all  accidents,  translating  into  2,000  fatalities  and  many  more  injuries  yearly.  Also, 
technical defects increase emissions (e.g. CO, HC, NO and CO2) by some 1.2% and 5.7% on 
average, and by up to 20 times for particular vehicles. 

Two root causes of the problem have been identified. 

First,  the  scope  of  EU  legislation  is  too  narrow  and  the  level  of  requirements  it  sets  is  too 
low. A comparative analysis of existing national PTI systems suggests that the requirements 

1 

The "type-approval" is defined in 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 

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of EU legislation are insufficient for the 7 pillars of EU roadworthiness test to reduce defect 
occurrence to sustainable levels: 

– 

– 

– 

– 

– 

– 

– 

not  enough  items  are  inspected  (particularly  electronic  safety  devices  are  not 
thoroughly inspected); 

the definitions of defects are out of date and the assessment not harmonised;  

the equipment used for PTI is not performant enough; 

the skills of inspectors are not precisely defined; 

many  vehicle  classes  are  not  inspected  at  all  (notably  motorcycles,  which  are 
involved in many accidents); 

vehicles  are  not  tested  frequently  enough  (in  particular  older  and  commercial 
vehicles, which have higher damage rates); 

testing stations are not sufficiently supervised in many Member States. 

Second,  information  and  data  vital  for  the  effectiveness  of  testing  and  enforcement  of  test 
results is not exchanged between concerned actors. In particular: 

– 

– 

– 

– 

Data for testing electronic safety components is often not available; 

Odometer readings are not collected in a centralised manner; 

PTI centrificates are not protected against fraud; 

Data  on  PTI  results  not  available  to  enforcement  authorities,  such  as  police  or 
registration authorities. 

Evolution of the problem (baseline scenario) 

The failures identified as drivers of the problem are regulatory in nature. The Netherlands and 
the United Kingdom have been looking at possibilities to reduce the frequency of PTI to save 
costs  for  vehicle  owners,  but  this  is  a  very  modest  indication  of  potential  future  changes 
across the EU Member States. On the EU side, the technical annexes to Directive 2009/40/EC 
will be updated regularly to take into account technological advances, as it has happened so 
far.2 However, since the Directive allows only the list of test items and testing methods to be 
updated  through  commitology,  no  change  to  the  scope  and  frequency  of  testing,  and  to  the 
framework for data exchange, can be achieved in the baselie scenario.  

Available projections concur to conclude that the vehicle fleet in Europe will increase in the 
future.  The  Commission  estimates  that,  in  a  no  policy  change  scenario,  the  number  of 
passenger  cars  will  increase  from  220.2  million  in  2005  to  307.1  million  in  2050.3  More 
vehicles in principle increase the risk of accident occurrence.  

At the same time, the ambitious policies announced in the Road Safety Policy Orientations for 
2010-2020  are  expected  to  increase  road  safety.  In  particular,  large  hopes  are  related  to  the 
development  and  deployment  of  Intelligent  Transport  Systems  (ITS)  and  related  pervasive 
technologies and tools. On the other hand, the latter will increase the complexity of on-board 

2 
3 

The last amendment was Directive 2010/48/EU. 
Primes-Tremove, reference scenario. 

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electronic equipment, which is difficult to test under the present conditions since the technical 
data from manufacturers are not currently available in functional form. Overall, it is expected 
that  the  downwards  trend  in  fatalities  is  maintained,4  but  it  is  probable  that  the  share  of 
accidents caused by technical defects will rise from the current 6%. 

On  the  environment  side,  pollutant  emissions  will  be  drastically  reduced  as  vehicles 
compliant with older Euro classes are gradually scrapped and new, zero-emission vehicles are 
marketed.  As  it  happens,  the  incidence  of  heavy  polluters  (due  to  technical  defects)  on  air 
quality will become proportionally higher. 

2. ANALYSIS OF SUBSIDIARITY 

The right to act for the EU in the field of transport is set out in the Treaty on the Functioning 
of  the  European  Union.  More  particularly,  Art.  91  of  the  Treaty  puts  on  the  legislators  the 
obligation to lay down measures to improve road safety. 

Road  transport  –  individual,  passenger  and  particularly  commercial  –  has  a  strong  cross 
border aspect. This is particularly important for enforcement, where effectiveness depends on 
the seemless flow of information about the technical state of vehicles, the compliance history 
and  fraud  detection  between  different  authorities  in  different  Member  States.  Similarly, 
vehicle manufacturing is global, and action addressing the provision of data for PTI purpose 
by the manufacturers clearly has to be taken at the highest possible level. 

Under  current  rules,  Member  States  have  a  lot  of  flexibility  in  the  application  of  the 
Directives,  allowing  them  notably  to  establish  higher  PTI  standards.  Experience  shows  that 
this opportunity has not been seized by all the MS, resulting in a diversity of testing qualities 
across the continent. This trend can be only reversed by concerted action at EU level. 

In order to avoid falling in the trap of looking at legislative solutions only, the Commission 
also analysed the impacts of an intervention based purely on soft-low, or on a mixed soft and 
legislative approach. 

The  Commission  believes  that  some  aspects  of  the  review  of  the  roadworthiness  system 
should be left to the MS, who can achieve the goals in a more effective way, notably in what 
concerns:  the  organisation  of  roadside  technical  inspections,  training  of  inspectors  and  the 
execution of supervision activities. 

3. OBJECTIVES OF EU INITIATIVE  

The general objectives of this initiative are: 

1. To contribute to the achievement of the goal of halving the overall number of road deaths 
in the European Union between 2010 and 2020 and moving to zero fatalities in road transport 
by 2050, through measures aiming at increasing the quality and better coordinating national 
PTI and roadside inspection systems, and 

2.  To  contribute  to  the  reduction  of  the  emissions  of  GHG  and  air  pollutants  from  road 
transport  through  measures  aiming  at  detecting  more  effectively  and  removing  from 
circulation vehicles which are over-polluting because of technical defects. 

These general objective can be translated into two specific objectives: 

4 

The  goal  set  for  the  next  ten  years  in  the  Policy  Orientations  on  Road  Safety  is  to  reduce  yearly 
fatalities by 50%. 

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– 

– 

increase  the  scope  and  the  level  of  requirements  for  roadworthiness  testing  and 
roadside controls across the European Union; 

create  the  appropriate  framework  for  seamless  flow  of  information  between  actors 
and Member States involved in the enforcement of PTI results. 

There are two operational objectives to be achieved three years after the entry into force of all 
elements of the new legislation (including the set-up of the data exchange system): 

– 

– 

To reduce the number of fatalities caused by technical defects by as close as possible 
to 1100 yearly, which has been estimated as the maximum potential; and 

To move towards eliminating the "gross emitting" vehicles from the fleet in use. 

4. POLICY OPTIONS 

A set of policy options have been considered: a no policy change option (Policy option 0); the 
discontinuation  of  EU  action;  a  soft  law  approach  (Policy  option  1);  a  legislative  approach 
(Policy  option  2);  a  combination  of  soft  law  and  legislative  approach  (Policy  Option  3). 
Discontinuation of EU action was discarded at an early stage because it would not contribute 
to the objectives and be inconsistent with existing EU strategies. 

Policy  option  1  encompasses  an  increased  use  of  peer  reviews  and  screening  by  the 
Commission and the exploration of optimal levels of investment in PTI and roadside testing 
exploring the scope for risk-based testing regimes together with Member States. The option 
would  also  include  looking  into  the  enforcement  of  legal  responsibilities  of  individuals  not 
presenting  their  vehicles  to  required  PTI.  Enforcement  measures  would  include  awareness 
campaigns  focusing  on  vehicle  owners,  enhancement  of  roadside  inspections  and  testing  as 
well  as  supervision  by  Member  States.  Finally,  PO1  would  include  recommendations  for 
voluntary action by vehicle manufacturers.  

Policy options 2 and 3 were further declined into three incremental sub-options from a to c, 
ranging  from  moderate  to  highest  increase  of  minimum  EU  standards  for  PTI  and  roadside 
inspections (RSI). All three sub-options have been analysed separately. 

PO  2a  increases  the  scope  of  RSI  beyond  checking  emissions  and  brakes;  sets  detailed 
requirements for the equipment to be used at PTI; puts in place the obligation for government 
departments to perform regular quality checks on PTI centres; includes motorcycles (L3,4,5,7) 
and light trailers (O2) among vehicles to be inspected at PTI; pushes forward the date of the 
first  mandatory  PTI  from  the  fourth  year  after  registration  to  the  third;  and  sets  regular 
training requirements for inspectors, both for PTI and RSI. 

Policy Option 2b, in addition to Policy Option 2a sets higher standards for testing equipment 
at PTI centres (including for testing electronic safety components) and for RSI (testing 15% 
of  vehicles  at  roadside  inspections  with  mobile  roadside  inspection  units);  increases  the 
specific training requirements for ispectors (PTI and RSI) to 4 days a year; includes mopeds 
(L1,2,6)  among  vehicles  tested  at  PTI  and  vans  (N1)  with  commercially  used  small  trailers 
(O1,2)  among  vehicles  tested  at  RSI;  increase  the  testing  frequency  for  older  small  vehicles 
(every year instead of every two years for M1N1O1,2L3,4,5,7); sets a minimum requirement of 
10%  of  commercially  used  vehicles  being  tested  at  RSI;  and  increases  the  quality  of 
supervision of PTI centres. 

Policy  Option  2c,  in  addition  to  Policy  Option  2b,  introduces  emission  testing  for  all 
categories of vehicles at RSI by the use of remote sensing technology with a target of 15% of 
vehicles  tested;  expands  RSI  to  all  categories  of  vehicles;  and  increase  the  frequency  of 

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testing of light vehicles (M1N1O1,2 L3,4,5,7) to yearly counting from the moment of registration 
and for heavier vehicles to every half a year instead of every year for M2,3N2,3O3,4. 

Initially,  also  three  technical  solutions  for  ensuring  the  exchange  of  data  from  and  for  PTI 
have been considered: centralised data store; centrally defined data store with full replication 
of all data to each Member State; and centrally defined but regionally administered data stores 
holding  local  information  only.  However,  preliminary  analysis  indicated  that  given  the 
particular requirements in the PTI context, the first two solutions would be too costly and also 
suboptimal  from  an  operational  point  of  view.  For  this  reason,  only  the  third  solution  was 
retained for further analysis and incorporated into Policy options 2a-c and 3a-c. 

Table 1: Summary table of Policy Options 

Minimum EU standards for PTI 
and roadside inspections 

Data exchange 

Policy Option 0 

Policy Option 1 (PO 1) 

Policy Option 2 

No policy change 

Soft law 

Legislative approach 

PO 2a  Moderate  increase  in  the  minimum 
standards  for  PTI  and  roadside 
testing 

PO 2b  Advanced increase in the minimum 
standards  for  PTI  and  roadside 
testing 

PO 2c  Highest  increase  in  the  minimum 
standards  for  PTI  and  roadside 
testing 

Data exchange platform 

Policy Option 3 

Soft law + Legislative approach 

PO 3a  PO 2a + PO 1 

PO 3b  PO 2b + PO 1 

PO 3c  PO 2c + PO 1 

PO 2 + PO1 

5. ASSESSMENT OF IMPACTS 

The  analysis  of  impacts  follows  the  logic  of  a  partial  cost-benefit  analysis.  The  main 
economic,  social  and  environmental  impacts  are  classified  according  to  whether  they 
constitute  costs  or  benefits.  Of  course,  what  is  a  cost  for  one  group  can  be  a  benefit  for 
another:  for  example  additional  PTI  generate  costs  for  vehicle  owners  and  benefits  for  the 
garages.  The  analysis  below  therefore  deals  with  what  can  be  perceived  as  social  costs  and 
benefits.  In  the  end  of  the  section,  impacts  concerning  particular  stakeholder  groups  are 
detailed, i.e. impacts on SMEs, citizens and public authorities. 

All  the  costs  are  presented  in  a  monetized  form.  On  the  benefit  side,  most  of  the  impacts 
related to road safety and environment were monetized, and gains in term of new jobs created 
are  also  quantified.  However,  some  important  benefits  could  not  be  quantified  and  are 
presented in qualitative terms. 

The costs are mostly related to: 

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– 

– 

– 

additional  equipment  and  staff  at  PTI  centres,  borne  by  garages  which  are  mostly 
SMEs; 

more frequent tests for a wider range of vehicles, borne by vehicle owners; 

supervision  of  garages  and  setting  up  the  data  exchange  system,  borne  by  public 
authorities. 

The benefits are mostly related to: 

– 

– 

– 

– 

increased road safety (nearly the totality of benefits  of  each policy option and sub-
option); 

reduced impact on the environment; 

additional employment; 

availability of better statistics for policy making and better functioning of the internal 
market. 

The table below provides a summary of the costs and benefits of each of the options. 

Table 2: Costs and benefits of the different options 

Cost (€ million) 

Polic
y 
optio
n 

Other benefits 

Monetize
d  benefit 
(€ 
million) 

Monetize
d 
benefit/c
ost ratio 

PO1 

0.28, of which: 

184 

656:1 

0.2:  Communication 
campaigns 

0.08: peer reviews 

(mostly 
related  to 
road 
safety) 

Increased  average  scope  and  level  of 
PTI and RSI resulting from additional 
peer reviews  and  screenings  and from 
the  exploration  of  optimal  levels  of 
investment 
roadside 
in  PTI  and 
testing. 

459.5, of which: 

1,622 

3.53:1 

- 1,450 additional jobs created; 

(mostly 
related  to 
road 
safety) 

125: 
testing frequency  

increased 

150:  more  vehicle 
categories tested 

95:  more 
needed 

staff 

-  increase  in  the  rate  of  detected  defects 
thanks  to  better  training  of  inspectors  and 
supervision of PTI centres; 

-  more  "heavy  offenders"  detected  at  RSI 
thanks to targeted roadside inspections; 

-  better  enforcement  of  PTI  results  by  the 
authorities thanks to data exchange; 

-  better  policy  making  and  more 
reliable 
car  market 
thanks to data exchange. 

second-hand 

3,347, of which: 

5,623 

1.68:1 

Benefits of PO 2a plus: 

PO2
a 

PO2
b 

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(mostly 
related  to 
road 
safety) 

1,681: 
testing frequency 

increased 

273:  more  vehicle 
categories tested 

263:  more 
needed 

staff 

- 12,000 additional jobs created 

-  increased  detection  of  defects  at  RSI  due  to 
increased scope (target numbers and 
all vehicle categories checked); 

- higher increase in the rate of detected 
defects  thanks  to  better  training  of 
inspectors. 

9,227, of which: 

7,027 

0.76:1 

Benefits of PO 2b plus: 

- 34,260 additional jobs created. 

(mostly 
related  to 
road 
safety) 

8,541: 
testing frequency 

increased 

281:  more  vehicle 
categories tested 

273:  more 
needed 

staff 

460, of which: 

1,806 

3.93:1 

Benefits  of  PO  1  plus  benefits  of  PO 
2a 

(mostly 
related  to 
road 
safety) 

125: 
testing frequency  

increased 

150:  more  vehicle 
categories tested 

95:  more 
needed 

staff 

3,347, of which: 

5,807 

1.73:1 

Benefits  of  PO  1  plus  benefits  of  PO 
2b 

(mostly 
related  to 
road 
safety) 

1,681: 
testing frequency 

increased 

273:  more  vehicle 
categories tested 

263:  more 
needed 

staff 

9,227, of which: 

7,211 

0.78:1 

Benefits  of  PO  1  plus  benefits  of  PO 
2c 

(mostly 
related  to 
road 
safety) 

8,541: 
testing frequency 

increased 

281:  more  vehicle 
categories tested 

273:  more 

staff 

PO2
c 

PO3
a 

PO3
b 

PO3
c 

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needed 

6. COMPARISON OF OPTIONS 

Policy  option  1  allows  reaching  the  "low  hanging  fruit",  i.e.  achieving  a  limited  increase  in 
road safety and environment protection at a very low price. It is however far from exploiting 
the full potential of the roadworthiness system in contributing to increasing road safety, which 
is estimated in different studies at 900-1100 avoided fatalities per year. The tools contained in 
policy option 2a are far more effective, since they allow avoiding 749 fatalities yearly. Policy 
option 2b – after taking into account the possible margin of error in the estimation of impacts 
–  probably  allows  unleashing  the  full  potential  of  roadworthiness  systems  in  avoiding 
accidents, injuries and fatalities. Policy option 2c goes beyond what can be considered as the 
"normal" potential with 1,441 avoided fatalities, which explains its prohibitive cost. 

In  the  light  of  the  above  considerations  and  of  the  EU's  overarching  goals  in  terms  of  road 
safety, the following conclusions can be made: 

• 

• 

• 

• 

• 

Policy option 1 is very cost-effective, but does not sufficiently contribute to the EU 
goals on road safety and environment; 

Policy option 2a is relatively cost effective and allows considerable increases in road 
safety  and  environment  protection,  but  below  what  is  commonly  estimated  as  the 
"conventional" potential; 

Policy  option  2b  allows  exploiting 
full  potential  of 
roadworthiness testing in increasing road safety and environment protection, and still 
has a positive cost-benefit ratio; 

the  "conventional" 

Policy option 2c allows achieving slightly better results  than  PO 2b, but at  a much 
higher cost (benefit to cost ratio below 1). 

PO  3  in all its versions combines the  advantage of the cost-efficiency of PO1 with 
the effectiveness of PO 2. 

PO  3b  is  therefore  seen  as  the  preferred  option.  The  calculations  which  are  behind  this 
choice are relatively robust in termas shown by the results of the sensitivity analysis. 

7. MONITORING AND EVALUATION 

Within five years after the entry into force of all elements of the new legislation (including the 
set-up  of  the  data  exchange  system),  the  Commission  will  report  to  the  Council  and  the 
Parliament on the effectiveness of the measures in reaching the objectives. In particular and in 
line  with  the  operational  objectives,  the  Commission  will  commission  a  scientific  study  to 
estimate if the number and proportion of accidents, injuries, fatalities and emissions attributed 
to technical defects has decreased and to what extent. 

The  Commission  will  use  the  results  extracted  form  the  national  risk  rating  system  of  road 
transport  companies  for  the  monitoring  of  the  compliance  of  commercial  vehicles  with  the 
roadworthiness requirements and its impact on the number and proportion of accidents related 
to this category of vehicles. 

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The  Commission  will  use  the  potential  synergies  stemming  from  the  revision  of  the 
legislation  on  type  approval  for  motorcycles.5  This  new  regulation  on  type-approval  for 
powered  two  and  three  wheelers  foresees  requirements  on  anti-tampering  measures.  The 
enforcement of these measures, as indicated in the accompanying IA report, will be subject to 
roadworthiness testing (both PTI as well as RSI) and create together with the elements related 
to market surveillance a further input for monitoring. 

Further synergies will be used for monitoring and evaluation in correlation with the recently 
started preparation for a legislative initiative on re-registration6. As one of the main problems 
at  re-registration,  the  availability  of  data  will  be  solved  via  the  Vehicle  Administrative 
Platform, which will provide a deep insight into the functionality of the intra EU information 
exchange and will allow real time monitoring of the system.. 

The  Commission  will  also  use  the  existing  reporting  system  for  roadside  technical 
inspections,  as  required  by  Article  6  of  Directive  2000/30/EC  on  roadside  technical 
inspections,  to  monitor  that  Member  States  perform  the  required  number  of  inspections  of 
commercial vehicles. These reports will also allow to monitor the changes in the frequency of 
occurrence of defects resulting from the enhanced PTI system.  

5 

Proposal for a Regulation of the European Parliament and of the Council on the approval and market 
surveillance of two- or three-wheel vehicles and quadricycles COM(2010)542 final. 
Registration of motor vehicles previously registered in another Member State 

6 
http://ec.europa.eu/enterprise/policies/single-market-goods/files/car_registration/roadmap_en.pdf.  

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