COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Impact Assessment Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the monitoring and reporting of CO2 emissions from and fuel consumption of new heavy-duty vehicles
Date: 2017-05-31
Institutions: Directorate-General for Climate Action, European Commission
Subjects: bus, commercial vehicle, consumption, disclosure of information, environmental monitoring, greenhouse gas, motor fuel, motor vehicle pollution, reduction of gas emissions

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 31.5.2017  SWD(2017) 188 final   COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Impact Assessment Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the monitoring and reporting of CO2 emissions from and fuel consumption of new heavy-duty vehicles  {COM(2017) 279 final} {SWD(2017) 189 final}  
 
 
TABLE OF CONTENTS 

ACRONYMS AND DEFINITIONS ................................................................................................................ 4 

1.  PROBLEM DEFINITION ..................................................................................................................... 5 

1.1 

CONTEXT ..................................................................................................................................... 5 

1.2  WHAT IS THE PROBLEM? ............................................................................................................. 7 

1.3  WHY IS IT A PROBLEM? WHAT ARE THE MAIN DRIVERS? ........................................................... 9 

1.3.1  WHERE ARE WE NOW IN ADDRESSING THE PROBLEM? .......................................................... 10 

1.4  WHO IS AFFECTED BY THE PROBLEM, IN WHAT WAYS, AND TO WHAT EXTENT? WHOSE 
BEHAVIOUR WOULD HAVE TO CHANGE TO IMPROVE THE SITUATION? ................................................. 13 

1.5  WHAT IS THE EU DIMENSION OF THE PROBLEM? ...................................................................... 14 

1.6 

HOW WOULD THE PROBLEM EVOLVE, ALL THINGS BEING EQUAL? ........................................... 14 

1.7 
HAS ANY FITNESS CHECK/RETROSPECTIVE EVALUATION BEEN CARRIED OUT OF THE EXISTING 
POLICY FRAMEWORK? ........................................................................................................................... 15 

2.  THE RIGHT OF THE EU TO ACT ...................................................................................................... 15 

2.1 

2.2 

2.3 

LEGAL BASIS ............................................................................................................................. 15 

ANALYSIS OF SUBSIDIARITY AND ADDED VALUE OF EU ACTION ............................................. 15 

PROPORTIONALITY CHECK ........................................................................................................ 17 

3.  OBJECTIVES ................................................................................................................................... 17 

4.  OPTIONS ........................................................................................................................................ 18 

4.1 

COMMON ELEMENTS OF THE OPTIONS CONSIDERED ................................................................. 18 

4.1.1 

SCOPE OF MONITORING AND REPORTING .............................................................................. 18 

4.1.2 

STATISTICAL ANALYSIS ........................................................................................................ 20 

4.1.3 

ROLE OF THE EUROPEAN ENVIRONMENT AGENCY (EEA) ................................................... 20 

4.1.4 

PUBLICATION OF MONITORING DATA................................................................................... 21 

4.2 

4.3 

BASELINE OPTION "NO ACTION AT EU LEVEL" ......................................................................... 21 

OPTIONS ASSESSED ON HOW TO MONITOR AND REPORT ........................................................... 21 

4.3.1 

OPTION 1: REPORTING BY NATIONAL AUTHORITIES ............................................................. 22 

4.3.2 

OPTION 2: REPORTING BY MANUFACTURERS ........................................................................ 23 

4.3.3 

OPTION 3: MIXED REPORTING BY NATIONAL AUTHORITIES AND MANUFACTURERS ............ 24 

4.4 

4.5 

DISCARDED OPTIONS ................................................................................................................. 25 

ARE SMALL AND MEDIUM SIZED ENTERPRISES TARGETED BY THE DIFFERENT OPTIONS? ...... 27 

5.  WHAT ARE THE IMPACTS OF THE DIFFERENT POLICY OPTIONS AND WHO WILL BE AFFECTED? ... 27 

5.1 

ECONOMIC IMPACTS .................................................................................................................. 27 

5.1.1 

GENERAL ECONOMIC IMPACTS .............................................................................................. 27 

2 

 
 
5.1.2 

COST OF OPTIONS (ADMINISTRATIVE BURDEN FOR MAIN STAKEHOLDERS CONCERNED) ..... 28 

5.2 

5.3 

SOCIAL IMPACTS ....................................................................................................................... 32 

ENVIRONMENTAL IMPACTS ....................................................................................................... 32 

5.3.1 

CO2 EMISSIONS ...................................................................................................................... 32 

5.3.2 

OTHER EMISSIONS ................................................................................................................. 33 

5.4 

5.5 

5.6 

IMPACT ON COMPETITIVENESS AND INNOVATION..................................................................... 33 

IMPACTS ON THIRD COUNTRIES AND ON EU INTERNATIONAL TRADE ...................................... 34 

IMPACT ON SMES ...................................................................................................................... 35 

6.  HOW DO THE OPTIONS COMPARE?................................................................................................. 36 

6.1 

6.2 

6.3 

6.4 

6.5 

6.6 

6.7 

EFFECTIVENESS ......................................................................................................................... 36 

EFFICIENCY ............................................................................................................................... 37 

PROPORTIONALITY .................................................................................................................... 37 

SUBSIDIARITY ........................................................................................................................... 38 

COHERENCE WITH OTHER MAINSTREAM EU POLICIES ............................................................. 38 

STAKEHOLDERS' VIEWS ............................................................................................................. 38 

CONCLUSIONS ........................................................................................................................... 38 

7.  HOW WOULD ACTUAL IMPACTS BE MONITORED AND EVALUATED? ............................................. 40 

ANNEX 1 - PROCEDURAL INFORMATION ............................................................................................... 41 

ANNEX 2 - STAKEHOLDER CONSULTATION ........................................................................................... 43 

ANNEX 3 - WHO IS AFFECTED BY THE INITIATIVE AND HOW ................................................................ 52 

ANNEX 4 - DEVELOPMENT OF A NEW SIMULATION TOOL, VECTO, FOR THE DETERMINATION OF CO2 
EMISSIONS FROM HEAVY-DUTY VEHICLES .......................................................................................... 53 

ANNEX 5 - DRAFT CERTIFICATION METHODOLOGY FOR THE DETERMINATION OF THE CO2 EMISSIONS 
FROM HEAVY-DUTY VEHICLES .............................................................................................................. 57 

ANNEX 7 - HDV SECTOR STATISTICS ................................................................................................... 63 

ANNEX 8 - MONITORING OF CO2 EMISSIONS FROM VANS ..................................................................... 72 

ANNEX 9 - INTERNATIONAL EXPERIENCES WITH HDV FUEL EFFICIENCY ............................................ 73 

ANNEX 10 - ASSESSMENT OF ADMINISTRATIVE COSTS OF MONITORING AND REPORTING ................... 78 

3 

 
 
 
 
CO2 
ETS 

Euro VI 

GHG 
HDV 

LDV 
NOx 
OEM 

PM 
Tailpipe emissions  
TTW emissions  

VECTO 
WTW emissions  

ACRONYMS AND DEFINITIONS 

Carbon dioxide 
Emissions  Trading  Scheme.  The  EU  emissions  trading  scheme  (carbon 
market  on  which  allowances  for  tons  of  CO2  are  being  traded  among 
participating  entities)  does  not  currently  include  road,  waterways  and 
maritime  transport  emissions  (aviation  emissions  have  been  included  as  of 
1.1.2012) 
The  latest  HDV  exhaust  gas  emission  standards  for  gaseous  pollutants  and 
particulate matter as set out in Regulation (EC) 595/2009.  
Greenhouse gases: gases that have a global warming effect 
Heavy-Duty  Vehicles,  i.e.  lorries,  buses  and  coaches  (vehicles  of  more  than 
3.5 tons) 
Light-Duty Vehicles, i.e. cars and vans 
Nitrogen oxides (nitric oxide (NO) and nitrogen dioxide (NO2)) 
Original  Equipment  Manufacturer:  the  main  truck  and  bus  manufacturers  of 
complete vehicles, tractors and chassis/cabin unfinished vehicles 
Particulate matter 
TTW emissions (see below) 
"Tank-to-wheel" –or tailpipe- emissions: emissions that occur throughtout the 
drive  cycle  of  vehicles.  This  only  includes  dowstream  emissions,  excluding 
upstream emissions (see below WTW emissions) 
Vehicle Energy Consumption calculation TOol 
"Well-to-wheel"  emissions  =  TTW  +  upstream  "well-to-tank"  emissions 
attached to the fuel production and transport 

4 

 
 
 
 
 
1.  PROBLEM DEFINITION 

1.1 CONTEXT 

This Commission's primary political objectives are to create jobs, growth and investment, and 
in this context to make the transition to clean energy for all Europeans. This is underpinned 
by an investment plan aimed at reindustrialising Europe based on new business models and 
cutting-edge technologies. The medium- to long-term aim is to achieve, a circular low carbon 
economy. 

In the context of transport, particularly with respect to lorries, buses and coaches, i.e. heavy-
duty  vehicles  (HDVs),  the  Commission’s  vision  is  to  ensure  that  European  citizens  and 
business have access to fair, sustainable and competitive mobility: 

  In  2014,  the  Commission  adopted  a  Communication  on  a  Strategy  for  Reducing  Heavy-
Duty  Vehicles'  fuel  consumption  and  CO2  emissions1  (referred  to  hereafter  as  "the  HDV 
Strategy"), announcing firstly an implementing measure setting out the procedure for the 
certification  of  carbon-dioxide  (CO2)  emissions  from  new  HDVs,  calculated  by  the 
VECTO simulation tool, and secondly upon its adoption to propose legislation to monitor 
and report them for all new vehicles placed on the EU market. 

  In  July  2016,  the  Commission's  European  Strategy  for  low-emission  mobility2  set  the 
ambition  for  the  transport  sector  to  reduce  greenhouse  gas  (GHG)  emissions  by  at  least 
60%  in  2050  compared  to  1990  levels  and  of  drastically  reducing  the  emission  of  air 
pollutants. The strategy3 includes an action plan to improve fuel efficiency and to reduce 
emissions from HDVs. So far, only pollutant emissions from these vehicles are regulated 
under  the  so-called  Euro  VI  Regulation4.  The  Strategy  confirmed  the  earlier  2014  work 
and also announced that the Commission will speed up analytical work on design options 
for HDV CO2 emission standards to prepare a legislative proposal during the mandate of 
this Commission. 

  In  October  2015,  the  EU  ratified  the  Paris  Agreement  which  then  entered  into  force  30 
days  thereafter.  The  EU  committed  to  an  at  least  40%  domestic  emission  reduction  by 
2030 compared to 1990. As part of the implementation, the Commission proposed in July 
2016  the  Effort  Sharing  Regulation  on  binding  annual  GHG  emission  reductions  by 
Member States for the period 2021 to 2030. Central policy scenarios used inter alia for the 
low-emission  mobility  strategy  and  for  the  impact  assessment  underpinning  the  Effort 
Sharing  Regulation  show  that  for  reaching  the  EU’s  ambitious  2030  target  emission 
reductions  for  transport would  have  to  be  around  18  to  19%  by  2030  compared  to  2005 
levels. 

  In  December  2016,  the  Commission  also  proposed  a  revision  of  the  Energy  Efficiency 
Directive  setting  a  binding  headline  target  at  EU  level  of  30%  for  improving  energy 
efficiency  in  2030  compared  to  business  as  usual.  Total  primary  energy  consumption 
should come down to 1 321 Mtoe by 2030. In 2015, total primary energy consumption was 
1529.6 Mtoe. 

1 COM (2014)285, available under: http://ec.europa.eu/clima/policies/transport/vehicles/heavy/documentation_en.htm 
2 https://ec.europa.eu/transparency/regdoc/rep/1/2016/EN/1-2016-501-EN-F1-1.PDF 
3 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=SWD:2016:244:FIN 
4 Regulation (EC) No 595/2009, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32009R0595 

5 

 
 
                                                            
This  impact  assessment  (IA)  accompanies  a  Commission  proposal  for  a  Regulation  on  the 
monitoring and reporting of CO2 emissions and fuel consumption from HDVs, which is part 
of the Clean, Connected and Competitive Mobility Package and constitutes an additional step 
to address HDV CO2 emissions, as announced in the abovementioned strategies.  

The  scope  of  this  IA  therefore  covers  specifically  the  monitoring  and  reporting  of  CO2 
emissions and fuel consumption of new vehicles. It also takes into account the first two steps 
which have already been decided and are therefore not subject to this IA:  

1) the VECTO simulation tool, developed to calculate new HDVs CO2 emissions and 
fuel consumption, and  

2) the certification procedure for calculating these emissions with VECTO through a 
draft Commission Regulation under the type approval legislation.  

This constitutes the first block of EU measures in relation to CO2 emissions from HDVs. 

This measure will close the knowledge gap on EU HDV CO2 emissions identified in the 2014 
HDV  Strategy.  At  the  same  time,  it  provides  the  key  enforcement  tool  for  the  future  CO2 
emission  standards  for  these  vehicles,  which  will  be  proposed  before  the  end  of  this 
Commission mandate and will be subject to another dedicated IA.  

This Regulation will also help with the establishment of a methodology for the differentiation 
of  infrastructure  use  charges  for  new  HDVs  according  to  CO2  emissions,  supporting  the 
implementation of the review of the "Eurovignette" Directive.  

6 

 
 
 
 
1.2 WHAT IS THE PROBLEM? 

1. Missed opportunities to design policies to reduce the fuel bill for transport operators 

Freight  transport  operators  can  experience  fuel  costs  greater  than  a  quarter  of  their 
operational  costs5  and  rank  fuel  efficiency  as  their  top  purchase  criterion.  While  the  fuel 
efficiency  of  heavy-duty  vehicles  has  improved  over  past  decades,  many  of  the  more  than 
half a million transport companies, which are to a large extent SMEs, do not have access yet 
to standardised information to evaluate fuel efficiency technologies, compare lorries in order 
to make the best informed purchasing decisions and reduce their fuel costs. This is also made 
more  difficult  by  the  absence  of  a  commonly  agreed  methodology  to  measure  fuel 
consumption. 
A study6 assessed market barriers to increased efficiency in the European freight sector and 
concluded  that  the  lack  of  information  and  comparability  between  vehicles'  CO2  emissions 
and  fuel  consumption  was  one  of  the  main  market  barriers  to  the  uptake  of  fuel  saving 
innovation. Despite being aware of a number of fuel saving technologies, transport operators 
were not able to make informed choices and purchase the most energy efficient vehicles as 
they could not compare the different brands and models at the stage of vehicle purchase.  

Over  time,  these  missed  fuel  savings  cumulatively  increase  the  EU's  dependency  on  fossil 
fuel imports and represent a missed opportunity to reduce fuel imports.  

2. Increasing competitiveness challenges for vehicle manufacturers 

In 2015, according to industry data, the exports of lorries generated a trade balance surplus of 
€ 5.1 billion. This sector is part of an automotive industry which generates 12.1 million direct 
and indirect jobs in Europe (5.6% of total EU employment)7.  

EU  HDV  manufacturers  face  increasing  global  competitive  pressures.  Significant  markets 
such  as  the  United  States,  Canada,  Japan  and  China  have  in  recent  years  implemented 
certification  and  fuel  efficiency  measures  in  the  form  of  fuel  consumption  and/or  emission 
standards in order to stimulate innovation and rapidly improve vehicle efficiency. A summary 
of the experiences for the other main HDV markets in the world is provided in Annex 9. The 
city  buses  market  sees  also  an  increasing  competition  in  the  field  of  electric  vehicles,  in 
particular from Chinese manufacturers. The EU HDV manufacturing sector will need to keep 
up  with  the  technological  improvements  in  these  markets  to  preserve  its  current  market 
position. 

The lack of market transparency translates into lesser pressure for EU HDV manufacturers to 
make  further  efforts  to  improve  vehicle  efficiency  and  invest  in  innovation  in  such 
competitive  global  market.  This  creates  risks  for  the  EU  manufacturing  sector  to  lose  its 
current  leading  role  in  vehicle  fuel  efficiency.  Transparency  on  the  fuel  and  CO2  emission 
performance of the vehicles would also stimulate competition inside the EU market, where in 
2016  the  Commission  revealed  a  cartel  among  a  number  of  manufacturers  of  lorries  that 
operated between 1997 and 20118. 

5 Fuel cost assessment studies illustrated in section 5.6 and Annex 7. 
6 Study by CE Delft on Market Barriers to Increased Efficiency in the European On-road Freight Sector carried out for the International 

Council on Clean Transportation (October 2012) available under the link: 
http://www.theicct.org/sites/default/files/publications/CE_Delft_4780_Market_Barriers_Increased_Efficiency_European_Onroad_Freight

_Sector_def-2.pdf 
7 http://www.acea.be/uploads/publications/ACEA_Pocket_Guide_2016_2017.pdf 
8 In particular regarding coordinating prices at "gross list" level for medium and heavy lorries in the European Economic Area  (EEA), the 
timing  for  the  introduction  of  emission  technologies  for  medium  and  heavy  lorries  to  comply  with  the  increasingly  strict  European 

7 

 
 
                                                            
 
3.  Barrier  for  setting  policies  to  address  the  GHG  emissions  challenges  for  the  heavy  duty 
vehicles sector  

The  HDV  sector  is  a  significant  source  of  GHG  emissions.  In  2014,  GHG  emissions  from 
HDVs  represented  5%  of  total  EU  emissions,  a  fifth  of  all  transport  emissions  and  about  a 
quarter of road transport emissions9. 

During the period 1990-2014, overall GHG transport emissions10 have increased by 20% and 
HDV emissions by 14%11 as illustrated in Figure 1. 

Figure 1. Road transport GHG emissions 1990-2014 

Note: 1.A.3. b.ii / Light duty trucks includes light-duty vehicles < 3.5 t  

Source: GHG Inventory data 201612 

As shown in Figure 2, without further action, HDV CO2 emissions are set to increase by up 
to 10% between 2010 and 203013. Given action already taken to curb emissions from cars and 
vans,  HDV  CO2  emissions  are  bound  –particularly  as  regards  emissions  from  lorries  –  to 
represent an increasing share of road transport emissions, from around 25% in 2015 to around 
30% in 2050. 

emissions  standards  (from  Euro  III  through  to  the  currently  applicable  Euro  VI)  and  the  passing  on  to  customers  of  the  costs  for  the 
emissions technologies, http://europa.eu/rapid/press-release_IP-16-2582_en.htm  

9 GHG Inventory data 2016, http://www.eea.europa.eu/data-and-maps/data/data-viewers/greenhouse-gases-viewer 
10 Including international aviation but excluding international shipping. 
11 GHG Inventory data 2016, http://www.eea.europa.eu/data-and-maps/data/data-viewers/greenhouse-gases-viewer 
12 http://www.eea.europa.eu/data-and-maps/data/data-viewers/greenhouse-gases-viewer 
13 EU Reference Scenario 2016: Energy, transport and GHG emissions - Trends to 2050 

8 

 
 
 
 
 
                                                                                                                                                                                         
Figure 2. HDV CO2 emissions projections 2030-2050 

Source: EU Reference scenario 2016, PRIMES-TREMOVE Transport Model (ICCS-E3MLab) 

At the same time, the EU has set ambitious targets for GHG reduction in 2030 to which the 
transport sector must contribute. The EU has an overall domestic emissions reduction target 
for 2030 of at least 40% below 1990 levels which has been divided in a cost-effective manner 
into reductions by 2030 compared to 2005 of 43% for the emissions from the EU ETS sectors 
and of 30% for the non-ETS sectors, to which transport belongs. 

Member States’ transport emissions range from 21% to 69% of total national emissions in the 
not-ETS  sectors  covered  by  the  Effort  Sharing  Regulation.  While  no  sector-specific  targets 
have been set for 2030, transport will need to contribute its share to the achievement of the 
non-ETS emission reduction target in the context of the Effort Sharing Regulation, together 
with buildings, agriculture, and waste. 

The  above  mentioned  lack  of  information  is,  however,  hampering  action  at  national  or  EU 
level to reduce HDV CO2 emissions. For instance, at national level the lack of availability of 
data  on  fuel  consumption  and  CO2  emissions  prevents  Member  States  to  provide  further 
incentives for the uptake of efficient HDVs, and design for example appropriate taxation or 
incentive  schemes  including  road  charging  and  public  procurement  to  promote  emission 
reductions.  At  EU  level,  the  absence  of  robust  and  comparable  data  prevents  the 
implementation and enforcement of future harmonised CO2 emission standards across the EU 
market.  

1.3 WHY IS IT A PROBLEM? WHAT ARE THE MAIN DRIVERS? 

The  main  driver  for  the  identified  knowledge  gap  is  a  market  failure,  i.e.  the  absence  of 
monitoring  and  reporting  of  objective,  standardised  and  comparable  CO2  emissions  from 
HDVs. 

Figure 3 illustrates the problem tree. 

9 

 
 
 
 
 
Figure 3. Problem tree 

Transport operators 
unable to chose the most 
fuel efficient vehicles and 
save fuel costs 

CO2 emissions and fuel 
consumption from HDVs 
placed on the EU market are 
neither certified, nor monitored 
nor reported 

Knowledge 
gap 

Lack of competitive 
pressure for increased 
innovation / deployment 
of energy efficient 
technologies/vehicles 

Lack of  appropriate data 
to set and enforce 
emission reduction 
measures for HDVs 

CO2 emissions from new heavy-duty vehicles placed on the EU market have so far not been 
monitored  and  reported  in  an  objective  and  comparable  manner,  implying  that  no  reliable 
data  are  available  regarding  their  magnitude  at  fleet  and  vehicle  level.  This  is  also  true  for 
fuel consumption of these vehicles, which is directly correlated to the CO2 emissions, as well 
as the real benefits of fuel efficiency technologies. 

The only EU HDV fleet data available at the moment with regards to CO2 emissions come 
from the greenhouse gas emission inventories, for which emissions of the whole HDV sector 
are  estimated  by  each  Member  States  based  on  fuel  sales.  Such  data  does  not  provide 
information on CO2 emissions of each specific vehicle, and therefore cannot be used to define 
policies aimed at increasing fuel efficiency and reducing CO2 emissions at vehicle level. 

At  vehicle  level,  and  until  certification  becomes  mandatory,  the  information  available  to 
buyers  of  new  HDVs  concerning  their  fuel  consumption  is  based  on  different  testing  and 
simulation  methodologies  depending  on  each  HDV  manufacturer,  and  are  therefore  not 
directly  comparable.  Buyers  have  also  no  broader  information  on  the  development  of 
competition with respect to fuel efficiency in the EU-wide market for transport services 

The EU HDV market is therefore lacking transparency as regards fuel consumption and CO2 
emissions  of  new  vehicles  preventing  well  informed  purchasing  and  policy  decisions 
promoting the most fuel efficient vehicles. 

1.3.1  WHERE ARE WE NOW IN ADDRESSING THE PROBLEM? 

Against this background and in application of the 2014 HDVs Strategy, the Commission has 
taken  action  to  address  this  knowledge  gap,  based  on  the  following  three-step  approach 
illustrated in Figure 4. 

10 

 
 
 
 
 
Figure 4. Identified three-step solution 

VECTO simulation 
tool to calculate 
fuel consumption 
and CO2 emissions 
from new HDVs 

Developed and ready 
to simulate CO2 
emissions and fuel 
consumption of 
lorries above 7.5 
tonnes 

Developed for 
lorries above 
7.5 tonnes 

Certification 
procedure to calculate 
CO2 emissions and 
fuel consumption with 
VECTO for new HDVs 
placed on the EU 
market  

Monitoring and 
reporting regulation: 
VECTO CO2 emissions 
and fuel consumption 
from every new HDV 
registered in the EU will 
have to be monitored and 
reported 

Subject of this 
impact 
assessment 

Step  1:  Development  of  a  simulation  software  -  the  Vehicle  Energy  Consumption 
calculation TOol (VECTO) - in order to calculate fuel consumption and CO2 emissions of 
new vehicles 

The first measure has been to develop an IT simulation tool, so-called VECTO, to calculate 
HDV CO2 emissions and fuel consumption in a comparable manner among different heavy-
duty  vehicles  across  all  manufacturers.  The  decision  to  develop  this  tool  was  made  after 
considering  other  options  for  test  procedures,  including  engine  test  beds,  chassis 
dynamometer and on-board tests in real traffic with Portable Emission Measurement Systems 
(PEMS). 

The key reasons to opt for simulation rather than any of the other testing procedures were: 

1)  Comparability: test results for different types of HDVs are directly comparable; 

2)  Cost efficiency because of high costs of testing facilities compared to simulation; 

3)  Capability  to  deal  with  high  variability:  HDV  series  of  production  are  very  small 

since vehicles are to a large extent customized to end-users' prescriptions; 

4)  Repeatability: simulation offers the highest scores for reproducibility of the tests; 

5)  Accuracy: small savings from single component optimisations can be detected; 

6)  Comprehensiveness:  simulation  can  be  used 

total  vehicle 
configuration  in  order  to  achieve  lower  fuel  consumption,  since  it  includes  all 
components (i.e. cabin, tyres, engine, transmission, etc.). 

to  optimise 

the 

This approach was confirmed in the 2014 HDV Strategy and its accompanying IA. 

Other major countries have also opted for using simulation tools. For instance, the US EPA 
has developed a similar simulation software, the Greenhouse Gas Emissions Model (GEM) to 
calculate CO2 emissions and fuel consumption from HDVs (see Annex 9). 

11 

 
 
 
 
The  Commission  in  close  cooperation  with  stakeholders  have  developed  VECTO.  The 
current version is ready to support CO2 certification for lorries above 7.5 tonnes. Simulation 
module  for  buses  and  coaches  is  still  under  development.  Simulation  results  have  been 
compared to real driving, and the VECTO simulations have shown a high level of accuracy of 
around +/- 3%. Further details on VECTO are provided in Annex 4. 

Step 2: New Commission Regulation on the determination of new heavy-duty vehicles' CO2 
emissions (so-called "certification" Regulation) 

The  development  of  VECTO  has  laid  the  ground  for  a  certification  methodology  for  CO2 
emissions and fuel consumption of new heavy-duty vehicles before being placed on the EU 
market. It will be possible to  calculate  VECTO  values  in  a comparable and certifiable way 
under the existing type approval legislation14. 

According to the upcoming Commission Regulation on certification each heavy-duty vehicle 
of the categories identified,  which is going  to  be placed  on the EU  market, will  need to  be 
simulated  in  terms  of  CO2  emissions  and  fuel  consumption  with  VECTO.  Vehicle 
manufacturers themselves will perform the simulation on the basis of certified input data of 
all  different  vehicle  components  and  of  a  certified  process  of  sourcing,  managing  and 
applying such input data. Further details on the draft certification methodology are provided 
in Annex 5. 

The  certification  methodology  has  been  developed  in  2015-2017  based  on  extensive 
stakeholder consultation and input. The Technical Committee on Motor Vehicles provided a 
positive  opinion  on  11  May  2017  on  the  draft  Commission  Regulation  on  certification 
proposed by the Commission. It covers the main categories of lorries above 7.5 tonnes, to be 
followed  by  amendments  to  cover  smaller  lorries  (above  3.5  tonnes)  as  well  as  buses  and 
coaches. The Regulation is not accompanied by a specific impact assessment beyond the IA 
on the 2014 HDV Strategy. Nonetheless studies on the costs of its implementation have been 
carried out. Relevant cost information is illustrated in Annex 5. 

Once  the  certification  regulation  enters  into  force  in  2019,  HDVs  manufactures  will  be 
required to calculate with VECTO fuel consumption and CO2 emissions of every single HDV 
produced and placed on the EU market.  

Certification,  however,  would  only  close  the  knowledge  gap  partially,  since  information 
on the performance of the vehicles will only be available to each individual purchaser and to 
the national authorities where the vehicle is registered. 

In  order  to  close  the  knowledge  gap  and  create  full  market  transparency,  this  information 
should be made available to all stakeholders, so that: 

  Transport operators can have an understanding of the performance of lorries from 
different  brands  with  similar  characteristics,  to  be  able  to  make  better  informed 
purchasing decisions. 

  Vehicle  manufacturers  can  compare  their  vehicles'  performances  with  those  of 

other brands, and have increased incentives for innovation.  

  Public  authorities  can  have  access  to  comprehensive  data  for  designing  and 
implementing policies to promote more fuel efficient lorries, for instance through 
taxation, road user charging, etc. This would not otherwise be possible as Member 

14 Directive 2007/46/EC, http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32007L0046 

12 

 
 
                                                            
States  have  access  only  to  VECTO  data  from  the  vehicles  registered  in  their 
territory. 

  Non-governmental organisations can make analysis of the data, e.g. assessing the 

penetration level of certain technologies, etc. 

Step 3: Monitoring and reporting certified CO2 emissions from new heavy-duty vehicles 

Through  this  third  step,  all  relevant  data  calculated  by  manufacturers  according  to  the 
certification  methodology  would  be  monitored,  reported  and  published  at  EU  level.  In  this 
way the data would be available to all stakeholders. 

Whether and how such monitoring and reporting system should be designed is the subject of 
this IA.  

Since  emission  data  will  become  available  from  the  first  year  of  the  entry  into  force  of 
certification  in  2019,  it  will  be  paramount  to  set  up  the  system  in  order  to  have  such  data 
reported and published the year after. 

This is a necessary step also in the process to prepare the implementation and enforcement of 
future CO2 emission standards for HDVs. A monitoring and reporting system is necessary in 
particular for assessing the compliance of such future standards, as it is the case for cars and 
vans.  

A  system  already  in  place  by  the  time  future  HDV  CO2  emission  standards  will  enter  into 
force will allow for the actors involved, especially vehicle manufacturers, to become familiar 
with the obligation to monitor and report, and for the system to be tested, and implementation 
guidance developed if need be. 

Stakeholders' view 

All stakeholders, who replied to the online public consultation, agreed that monitoring HDV 
fuel consumption and CO2 emissions in the EU is needed in order to gather the necessary data 
to close the identified knowledge gap. 

1.4 WHO IS AFFECTED BY THE PROBLEM, IN WHAT WAYS, AND TO WHAT EXTENT? 
WHOSE BEHAVIOUR WOULD HAVE TO CHANGE TO IMPROVE THE SITUATION? 

The lack of information on fuel efficiency directly affects freight transport operators as well 
as logistics companies, i.e. the buyers and users of HDVs. 

This  lack  of  information  and  possibility  to  compare  prevents  them  from  choosing  the  most 
efficient vehicles and to benefit from the corresponding potential fuel savings. These could be 
significant  considering  that  fuel  represents  a  large  share  of  vehicle  operating  costs15.  It  has 
therefore  impacts  on  intermediate  transport  costs  and  potentially  on  the  costs  of  goods  and 
services for consumers and companies. 

HDV manufacturers and automotive component suppliers in the absence of such transparency 
have  only  limited  incentives  from  the  market  to  invest  in  innovation  and  deployment  of 
energy efficient technologies to improve their vehicles and hence their competitiveness. 

Member States  are also  affected. At the  moment  few Member States have  set up voluntary 
schemes to promote HDV CO2 emissions reductions and fuel efficiency.  

15 See section 5.6 and Annex 8. 

13 

 
 
                                                            
16,  transport  companies  can  sign  a  charter  of 
In  France,  under  the  initiative  Objectif  CO2
commitments,  pledging  to  work  towards  an  overall  CO2  emission  reduction  goal  over  a 
period of three years. In Ireland, the Sustainable Energy Authority recognises best practice in 
energy  performance,  management  and  design  through  the  annual  Sustainable  Energy 
Awards17, for the individuals and groups who demonstrate a commitment to include energy 
management as part of their overall management structure, including transport companies. 

However, the lack of availability of data on fuel consumption and CO2 emissions from HDVs 
prevents  Member  States  to  regulate  effectively  on  that  basis,  and  design  for  example 
appropriate  taxation  schemes,  including  road  user  charging,  which  can  currently  only  be 
based  for  HDVs  on  the  EURO  air  pollutants  emission  classes.  It  would  also  provide 
information  to  design  incentives  schemes,  for  instance embedded  in  public  procurement,  to 
promote  fuel  efficient  and  low  emission  HDVs.  Moreover  it  would  make  existing  fuel 
taxation18 more effective.  

In  addition,  lower  fuel  consumption  would  reduce  the  necessity  for  imports  of  fossil  fuels 
into the EU and contribute to overall energy security and trade balance. 

1.5 WHAT IS THE EU DIMENSION OF THE PROBLEM? 

Markets  for  new  HDVs  and  transport  services  are  both  operating  EU-wide  and  are integral 
parts of the Single Market. The lack of transparency concerning fuel consumption and CO2 
emissions from new vehicles is not yet addressed in any of the Member States and concerns 
the EU as a whole. Moreover, HDV CO2 emissions are covered under the EU’s greenhouse 
gas emission reduction target. 

The development of the vehicle emissions simulation tool VECTO has been carried out cost 
efficiently  by  the  Commission  in  close  cooperation  with  experts  from  Member  States  and 
stakeholders. 

The  certification  of  HDV  fuel  consumption  and  CO2  emissions  is  set  out  in  a  Commission 
Regulation, under the EU type-approval framework which covers HDVs. 

For  cars  and  vans  a  mandatory  EU-wide  system  to  monitor  and  report  CO2  emissions  is 
already in place19. 

1.6 HOW WOULD THE PROBLEM EVOLVE, ALL THINGS BEING EQUAL? 

In the absence of an EU-wide monitoring and reporting legislation, national authorities may 
adopt different monitoring and reporting approaches leading to a fragmented and inconsistent 
collection  of  such  data  across  the  EU.  This  would  lead  to  high  administrative  burden  for 
HDV manufacturers who would have to keep different reporting systems. However, this risk 
is unlikely as illustrated by the public consultation indicating that national authorities would 
rather not act at all. 

In case HDV certification is put in place without monitoring and reporting CO2 emission and 
fuel  consumption  data  at  EU  level,  information  on  the  level  of  penetration  and  actual 
diffusion  of  advanced  fuel  efficient  technologies  will  not  become  fully  available  to 
manufacturers,  HDV  buyers  and  policy  makers.  One  would  not  be  able  to  compare  the 

16 http://www.ademe.fr/en/objectif-co2-an-emissions-reduction-program  
17 http://www.seai.ie/EnergyMAP/Transport/Intro/  
18 In particular on diesel fuel. 
19 Regulation (EC) No 443/2009 and Regulation (EU) No 510/2011. 

14 

 
 
                                                            
performance  of  vehicles  across  the  whole  fleet,  assess  the  wider  effective  demand  for  fuel 
efficient  vehicles  and  evaluate  national  policy  incentives  for  fuel  efficient  lorries.  With 
certification  alone,  only  the  direct  buyer  of  a  vehicle  would  receive  the  information  at  the 
moment of purchasing and Member States would have access to the information only for the 
vehicles registered in their territory. 

As a result, technological progress in terms of fuel efficiency and CO2 emissions would stay 
at business as usual. Freight operators would lose in terms of fuel costs, transport costs would 
be  higher  than  necessary,  EU  manufacturers  risk  falling  gradually  behind  their  competitors 
outside Europe, and the share of emissions  from heavy-duty  vehicles would increase in the 
coming decades. 

Furthermore,  it  would  not  enable  the  implementation  and  enforcement  of  future  CO2 
emission standards and would also hamper action at Member States level to reduce emissions 
from this sector. For example, road user charging schemes could not be effectively designed 
to address CO2 emissions as Member States do not have access to the full database on CO2 
emissions from HDVs that could operate on their territory. 

1.7 HAS ANY FITNESS CHECK/RETROSPECTIVE EVALUATION BEEN CARRIED OUT OF 

THE EXISTING POLICY FRAMEWORK?  

HDV  CO2  emissions  are  currently  not  subject  to  specific  EU  legislation.  Consequently,  no 
evaluation could be carried out. 

2.  THE RIGHT OF THE EU TO ACT  

2.1 LEGAL BASIS 

Climate  change  is  a  trans-boundary  problem  and  at  the  same  time  is  a  competence  shared 
between  the  EU  and  Member  States.  Coordination  of  climate  action  at  European  level  is 
therefore necessary and EU action is justified on grounds of subsidiarity. 

Articles  191  to  193  of  the  Treaty  on  the  Functioning  of  the  European  Union  confirm  and 
further  specify  EU  competencies  in  the  area  of  climate  change.  In  particular,  the  TFEU 
provides the legal basis for acting on HDV fuel consumption and CO2 emissions. 

The  EU  has  already  acted  in  the  area  of  vehicle  emissions,  adopting  Regulations  (EC) 
443/2009  and  (EU)  510/2011  which  set  limits  for  CO2  emissions  from  cars  and  vans,  and 
with  implementing  legislation  on  monitoring  and  reporting  of  data  on  registration  and  CO2 
emissions  of  new  light  commercial  vehicles  ((EU)  No  410/2014  and  2012/293).  These 
Regulations were based upon the Environment chapter of the Treaty and namely on Article 
192 TFEU. 

In addition, there is a need to maintain a functioning Single Market for HDV manufacturers 
and to preserve a level playing field for all transport operators in the EU. 

2.2 ANALYSIS OF SUBSIDIARITY AND ADDED VALUE OF EU ACTION 

EU action is justified in view of both the cross-border impact of climate change and the need 
to safeguard single markets in fuel, vehicles and transport services. 

15 

 
 
The EU-28 share of international transport20 in total road freight transport in 2015 was 40%, 
in some Member States reaching above 80%21, see figure 5 below. 

Moreover,  new  HDVs  registered  in  a  given  Member  States  are  often  produced  by  a 
manufacturer  in  another  Member  State.  Monitoring  at  national  level  instead  of  EU  level 
would  thus  require  extensive  cooperation  among  Member  States,  including  the  adoption  of 
various pieces of national legislation. 

Even if such monitoring at national level were to materialize, comparable and homogeneous 
monitoring  data  would  not  be  guaranteed  due  to  differences  between  Member  States' 
legislation  and  policy  practices,  for  instance  in  the  field  of  taxation  or  organization  of  the 
transport  network.  Comparability  and  completeness  of  data  would  be  difficult  to  achieve, 
triggering EU market fragmentation and loss of market transparency. 

Another difficulty related to the proliferation of monitoring schemes at national level would 
be  the  lack  of  a  common  database  containing  all  Member  States'  monitoring  data.  This 
would, in particular, hamper the utility and use of the data by the purchasers of vehicles and 
by policy makers at EU level. 

A common monitoring scheme at EU level appears to be the most straightforward and simple 
approach. This would reap the benefits of the adoption of the certification procedure on HDV 
fuel consumption and CO2 emissions. For similar reasons, this is the approach followed for 
cars and vans through EU level action. 

Figure  5.  Share  of  international  transport  in  total  road  freight  transport,  2011  and  2015  (%  in  tonne-
kilometres) 

Source: Eurostat, 2016 (road_go_ta_tott)22 

20 International road freight transport is defined as the transport by road between two places (a place of loading and a place of unloading) in 

two different countries irrespective of the country in which the vehicle is registered.  
transport 

international 

statistics 

Eurostat 

freight 

road 

on 

21 

explained/index.php/Road_freight_transport_by_journey_characteristics  

22 http://ec.europa.eu/eurostat/statistics-

(2016), 

http://ec.europa.eu/eurostat/statistics-

explained/index.php/File:Share_of_international_transport_in_total_road_freight_transport,_2011_and_2015_(%25_in_tonne-
kilometres)_F3.png  

16 

 
 
 
                                                            
2.3 PROPORTIONALITY CHECK 

HDV  emissions  are  significant  representing  about  5%  of  EU  CO2  emissions  and  20%  of 
transport  emissions.  In  view  of  their  scale  and  their  long-term  increasing  trend,  it  appears 
proportionate to collect and report HDV CO2 emissions and fuel consumption data for new 
vehicles, thereby improving market transparency. 

Conclusions  on  proportionality  (section  6)  will  further  take  into  consideration  how  the 
options meet effectiveness requirements, notably with regards to its costs and benefits. 

3.  OBJECTIVES  

General policy objectives: 

1)  Facilitate a reduction in fuel costs for transport operators, many of which are SMEs 

2)  Contribute to the improvement of the competitiveness of HDV manufacturers 

3)  Contribute to the achievement of the EU's climate and energy target and objectives 

Specific objectives: 

  Enable informed purchasing decisions and deployment of more fuel efficient vehicles  
  Foster innovation and development of fuel efficiency technologies  
  Promote  cost-effective  reductions  of  CO2  emissions  and  reduce  overall  fuel 

consumption from HDVs 

  Enable  the  development  of  rational  policies  promoting  the  uptake  of  advanced  fuel 

efficient and low emission HDVs 

Operational objective:  

Monitor and report in a cost efficient manner:  

  CO2 emissions and fuel saved over time per vehicle group, manufacturer and Member 

State 

  uptake  levels  of  more  fuel  efficient  vehicles  and  rate  of  annual  efficiency 

improvement in each vehicle group  
technology development and penetration levels in the fleet 

 

17 

 
 
 
 
4.  OPTIONS  

With the entry into force of the certification obligation, CO2 and fuel consumption of all new 
lorries  above  7.5  tonnes  placed  on  the  EU  market  and  falling  under  the  scope  of  the  new 
Commission Regulation will have to be simulated using VECTO. 

Options will be considered in this impact assessment on whether and how these data should 
be reported and  monitored at EU level to  close the knowledge  gap on CO2 emissions  from 
heavy-duty vehicles. 

4.1 COMMON ELEMENTS OF THE OPTIONS CONSIDERED 

4.1.1  SCOPE OF MONITORING AND REPORTING 

The options considered relate to the monitoring and reporting of CO2 emissions from all new 
HDVs placed on the EU market, which will be subject to the certification process under the 
type approval framework. 

The  monitoring  system  will  only  cover  CO2  emissions,  resulting  from  the  certification 
procedure. Emission pollutants, such as particulate matter (PM), nitrogen oxides (NOx), un-
burnt  hydrocarbons  (HC)  and  carbon  monoxide  (CO),  as  well  as  methane  (CH4)  emissions 
from  CNG  fuelled  engines,  are  already  covered  by  the  EURO  VI  engine  standards23. 
Fluorinated  greenhouse  gases  due  to  leakages  from  refrigeration  systems  in  the  case  of 
refrigerated  trucks  and  from  the  air  conditioning  systems  of  HDVs  are  covered  by  the  so-
called F-gas Regulation24.  

The monitoring system will only cover new vehicles, since vehicles in use cannot technically 
be subject to certification. The input data needed to run the VECTO simulation tool are not 
available  for  vehicles already  sold  and  in  operation.  Moreover,  fuel  efficiency  technologies 
can  generally not  be  (cost-effectively) retrofitted to  existing vehicles. Furthermore, the first 
purchasing decisions are crucial for the diffusion in the fleet of more fuel efficient vehicles. It 
is thus essential to provide the right set of information to influence them. 
Considering the average lifetime of a  lorry  of around ten years25, it can  be assumed that  in 
ten-year time the whole (or most) of the EU fleet will be covered by the monitoring scheme. 

Manufacturers will generate the digitised monitoring data at the time of production. This will 
contain a subset of around 80 parameters coming out of the certification process under type 
approval  (see  Figure  6  below  for  an  illustration  of  the  link  between  VECTO,  certification 
and monitoring and reporting). 

The  parameters in  the monitoring  data  file  have  been  chosen  from  the  VECTO  output  data 
file following a technical analysis, which took into account the relevance of these parameters 
for  the  objective  of  closing  the  knowledge  gap  on  HDV  CO2  emissions  and  future  policy 
action,  in  particular  having  in  mind  the  enforcement  needs  for  future  HDV  CO2  emission 
standards.  

The  key  parameters  are  fuel  consumption  and  CO2  emission  values  and  other  parameters 
relevant for the determination of such values coming from the certification process. Table 1 

23 Regulation (EC) No 595/2009, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32009R0595  
24  Regulation  (EU)  No  517/2014  of  the  European  Parliament  and  of  the  Council  of  16  April  2014  on  fluorinated  greenhouse  gases, 

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0517&from=EN  

25 Ricardo AEA (2015), Light weighting as a means of improving Heavy Duty Vehicles’ energy efficiency and overall CO2 emissions, Report 

for DG Climate Action, https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/heavy/docs/hdv_lightweighting_en.pdf  

18 

 
 
                                                            
below  provides  a  list  of  the  main  elements  of  the  monitoring  data  which  will  have  to  be 
reported. 

Table 1. Main elements of the data to be monitored and reported 

General 
(mission profile 
independent) 
vehicle 
information 

Component identification 

Vehicle classification 

Vehicle and chassis specification 

Main engine specifications 

Aerodynamics 

Main transmission specifications 

Main axle specifications 

Angle drive 

Main tyre specifications 

Main auxiliary specifications 

Technologies to reduce CO2 emissions, e.g. advanced driver assistance 
systems 

Vehicle mass 

Vehicle driving performance and information for simulation quality check  

Fuel and CO2 results 

Mission profile 
and loading 
dependent 
values 

VECTO version 

Manufacturers'  reported  monitoring  data  will  not  include  information  on  where  the  vehicle 
was  registered.  National  authorities  will  need  to  complement  manufacturer’s  information 
with  vehicle  registration  data  on  the  basis  of  the  Vehicle  Identification  Numbers  (VIN, 
described in Annex 6). This will allow calculating average values for CO2 and fuel efficiency 
across  the  fleet  of  new  heavy-duty  vehicles  registered  in  certain  Member  States  for  each 
calendar year. 

19 

 
 
 
 
Figure 6. Links between VECTO, certification and monitoring and reporting 

4.1.2  STATISTICAL ANALYSIS  

Taking  into account  future regulatory use  of the  monitoring data, it is  necessary to  provide 
effective  safeguards  ensuring  the  objectivity  and  precision  of  the  data.  It  is  therefore 
appropriate  to  foresee  an  empowerment  for  the  Commission  to  develop  a  methodology  for 
carrying out statistical data analysis for detecting and taking into account possible unjustified 
divergences  found  in  the  reported  data,  e.g.  lorries  of  the  same  model  reported  with  very 
different  CO2  emissions.  This  could  trigger  for  example  further  targeted  verification 
according  to  future  provisions  of  the  certification  Regulation,  thereafter  improving  market 
surveillance. 

4.1.3  ROLE OF THE EUROPEAN ENVIRONMENT AGENCY (EEA) 

The European Environment Agency (EEA) is the most appropriate body at European level to 
act on behalf of the Commission in order to collate data, build a new database, analyse and 
perform quality checks of the reported monitoring data from heavy-duty vehicles. This was 
also confirmed by comments received through the public consultation, which underlined the 
need of an independent agency to perform the monitoring at EU level. 

The  EEA  already  carries  out  these  tasks  for  different  monitoring  and  reporting  schemes, 
including  for  CO2  emissions  from  cars  and  vans26  (see  Annex  8  for  more  information). 
Impacts on EEA's resources are assessed in section 5. 

26 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R0410 

20 

 Certification process Monitoring and reporting  
 
 
                                                            
4.1.4  PUBLICATION OF MONITORING DATA 

The  annual  monitoring  process  would  be  completed  with  the  publication  by  the 
Commission/EEA  at  the  end  of  year  n  of  monitoring  data  for  year  n-1  per  vehicle, 
manufacturer and Member State. 

Stakeholders  expressed  different  views  concerning  the  publication  of  the  full  set  of 
monitoring  data  reported  per  vehicle.  On  the  one  hand,  civil  society  organisations  consider 
that all monitoring parameters should be published per individual vehicle in order to ensure 
full  transparency.  On  the  other  hand,  HDV  and  some  component  manufacturers  have 
expressed concerns about the commercial confidentiality of some of the parameters like the 
coefficients of the rolling resistance of the tyres and of the aerodynamic drag.  

In duly justified cases, such as where it is clearly demonstrated that a public disclosure of the 
data  would  seriously  undermine  commercial  interests,  the  transparency  objective  may 
nevertheless  be  achieved  by  e.g.  the  publication  of  ranges  of  values  instead  of  the  specific 
values or the parameter may not be made public if absolutely critical. In the latter case, the 
data would be kept only for Commission internal use. 

The  Commission  has  also  considered  the  risks  that  publication  of  data  for  each  new  HDV 
registered in the EU would entail in terms of market reactions. The risk of market collusion in 
a market with a very limited number of players, such as the EU HDV market, is considered to 
be limited as a result of the publication of the monitoring data. The availability of such data is 
expected rather to enhance competition in the market, given the information available on the 
performance of each player's vehicles. 

4.2 BASELINE OPTION "NO ACTION AT EU LEVEL" 

This option does not entail any action at EU level on setting up a monitoring and reporting 
system  for  the  CO2  emission  and  fuel  consumption  data  from  new  heavy-duty  vehicles 
resulting from the certification process. The certification legislation would be adopted under 
the type-approval framework, but no instrument would be proposed to gather such data at EU 
level in a common database. The other options below are assessed against this baseline. 

4.3 OPTIONS ASSESSED ON HOW TO MONITOR AND REPORT 

The options relate to  how to  monitor and report CO2 emissions and fuel consumption from 
new HDVs. Three main options are considered as illustrated in Figure 7. 

21 

 
 
 
 
Figure 7. Overview of option 1, 2 and 3 

Source: EC/CE Delft, 2016 

4.3.1  OPTION 1: REPORTING BY NATIONAL AUTHORITIES 

Under this option, national authorities report the monitoring data and the registration data of 
the vehicles concerned via the EEA to the Commission. 

As  is  the  case  for  monitoring  and  reporting  CO2  emissions  from  vans,  Member  States  will 
designate  a  competent  authority  for  the  collection  and  forwarding  of  the  monitoring 
information, which would be the registration authorities in most cases. They will gather the 
monitoring data as part of the vehicle registration process. 

The activities required for monitoring and reporting of HDV CO2 emissions under this option 
include the following: 

  adaptation of the national vehicle register, if needed; 
  gathering of the monitoring data from the national vehicle register; 
  submission of data to EC/EEA; 
  combining national data sets and processing of data by EEA; 
  eventually  fixing  of  mismatches  of  data  upon  comparison  of  national  data  and 

manufacturers' data. 

Under the assumption that  all  VECTO data  is  available due to  the vehicle certification,  the 
role  of  manufacturers  would  be  to  submit  monitoring  data  to  national  authorities  or 
intermediary  persons  (such  as  importers  or  dealers),  during  the  registration  procedure.  In 
addition, manufacturers would review the data set compiled by EEA. 

Implementation of this option will require extra investments, for example concerning training 
staff  in  all  Member  States.  The  amount  of  additional  costs  will  depend  on  the  existing 
expertise and technical system already available in the specific Member State. 

22 

           Monitoring data        Monitoring data  Monitoring data             Monitoring data +  Vehicle Identification Numbers                                                                                                                                                 Vehicle Identification Numbers   Manufacturers EC (via EEA) MS EC (via EEA) Manufacturers MS EC (via EEA) Manufacturers Checks Checks  
 
 
 
Full digitisation of monitoring and reporting may not be easily feasible under this option as 
the majority of national registration authorities still process paper files to register HDVs (see 
Table 2 in section 5.1.2), therefore adaptation to fully digitised flows of monitoring data may 
be challenging and costly, this will be further assessed in section 5.1.2. 

Figure 8. Actors and related role for option 1 

Option 1 

Original Equipment 
Manufacturers 

Member States 
Registration and/or Type 
Approval Authorities 

EC/European 
Environment Agency 

• Provide monitoring data to MS at registration 
• Cross-check monitoring data with EEA 

• Send registration and monitoring data for new 

vehicles registered in year n-1 

• Receive, process and publish checked 

monitoring data for new vehicles of year n-1 

Stakeholders' view 

Option  1  was  deemed  the  most  appropriate  option  for  monitoring  and  reporting  HDV  CO2 
emissions  and  fuel  consumption  by  31%  of  the  121  respondents  to  the  online  public 
consultation (see Annex 2). The stakeholders most in favour of this option belong mainly to 
professional  organisations,  e.g.  dealing  with  transport  and  logistics,  private  enterprises  like 
component  manufacturers,  business,  industry,  and  trade  associations,  some  civil  society 
organisations and some public authorities. 

4.3.2  OPTION 2: REPORTING BY MANUFACTURERS  

This option would alternatively put HDV manufacturers in charge of reporting the monitoring 
data for each new vehicle via the EEA to the Commission. In such a case the monitoring data 
would  be  annual  sales-based  data  in  the  possession  of  vehicle  manufacturers  and  no 
registration  data  would  be  reported  (i.e.  no  information  would  be  available  on  where  the 
vehicle was registered). 

Under  this  option  manufacturers  would  thus  annually  collect  and  report  the  required 
monitoring data  of their  produced  vehicles to  the  EC/EEA,  including  sales  numbers  on  EU 
territory.  The  country  of  registration  is  not  necessarily  the  country  where  vehicle  and 
documents  are  sent  to  from  the  manufacturer.  Dealers  may  register  it  elsewhere  and, 
consequently,  the  manufacturers  have  no  reliable  information  on  where  vehicles  are 
registered. 

Under  this  option,  only  manufacturers,  the  EEA  and  the  Commission  would  have  specific 
obligations  with  respect  to  monitoring  and  reporting  of  HDVs  CO2  emissions  and  fuel 
consumption, whereas Member States would play no role, as illustrated in Figure 9. 

23 

 
 
 
 
 
Figure 9. Actors and related role for option 2 

Option 2 

Original Equipment 
Manufacturers 

• Send monitoring data for new vehicles sold in 

year n-1 

• Cross-check monitoring data with EEA 

EC/European 
Environment Agency 

• Receive, process and publish monitoring data for 

new vehicles of year n-1 

Full  digitisation  of  monitoring  and  reporting  appears  feasible  under  this  option  since 
manufacturers  deal  with  digital  files  (e.g.  they  already  own  the  digital  VECTO  input  and 
output data) and could efficiently transfer them. 

Stakeholders' view 

Option 2 was considered the most appropriate option by 12% of the respondents to the online 
public consultation, mainly by professional organisations (e.g. representing shippers). 

4.3.3  OPTION 3: MIXED REPORTING BY NATIONAL AUTHORITIES AND 

MANUFACTURERS 

This third option is an intermediate option between 1 and 2. Designated national authorities –
most of which are expected to be the national registration authorities– would annually report 
via the EEA to the Commission registration data (VIN numbers) of new registered vehicles. 

Vehicle  manufacturers  would  submit  via  the  EEA  to  the  Commission  the  corresponding 
monitoring data. On the basis of the VIN numbers the two datasets are combined in order to 
obtain monitoring data at a Member State level. 

Figure 10. Actors and related role for option 3 

Option 3 

Original Equipment 
Manufacturers 

Member States 
Registration and/or Type 
Approval Authorities 

EC/European 
Environment Agency 

• Send monitoring data for new vehicles sold in year n-1 
• Cross-check monitoring data with EEA 

• Provide Vehicle Identification Numbers for new vehicles 

registered in year n-1 

• Receive, process and publish checked monitoring data 

for new vehicles of year n-1 

Under this option, full digitalisation of the flow of data is ensured, since manufacturers are in 
charge of reporting the monitoring data. 

24 

 
 
 
 
Stakeholders' view 

Option 3 was considered as the most appropriate option by the highest number of respondents 
(42%)  to  the  online  public  consultation,  belonging  to  civil  society  organisations,  the 
automotive industry, sector/trade/employers' associations, private and public companies, not 
for profit organisation, professional organisations (mainly linked to the automotive industry), 
private  enterprises  (e.g.  from  the  energy  sector),  public  authorities,  individuals  and 
international organisations. 

4.4 DISCARDED OPTIONS 

Voluntary cooperation 

Voluntary  cooperation  among  national  authorities  and/or  vehicle  manufacturers  could 
provide a monitoring of fuel consumption and CO2 emissions of new vehicles in the EU. 

However: 

   Harmonised checks and controls of these data would not be possible and the quality of the 

reporting may be affected. 

   Cooperation cannot be taken for granted. In the absence of full cooperation of all players 

EU-wide monitoring/reporting would not be possible. 

   The  absence  of  such  voluntary  monitoring  so  far  points  to  the  difficulty  of  such 

approaches. 

In view of the latter this option was discarded. It has not been supported by any stakeholder. 

Collection of real-world fuel consumption data 

Some  stakeholders  suggested  that  the  emission  data  reported  by  manufacturers  should  be 
supplemented with “on-road/actual operations” data. Real-world fuel consumption data could 
be collected directly from on-board units fitted on the vehicles or requesting the operators to 
retrieve  and  report  such  data  from  their  fleet  management  systems.  This  would  require  in 
particular on-board fuel flow meters to be made compulsory. 

This  option  goes  beyond  the  scope  of  this  Impact  Assessment  which  focuses  on  the 
monitoring data generated by VECTO through the certification process. It has therefore been 
discarded. 

It should, however, be noted that the relationship between the HDV CO2 emissions calculated 
ex-ante with VECTO and the real world emissions has been subject to thorough reflection in 
the  preparation  of  the  first  block  of  HDV  CO2  emission  legislation.  In  particular,  the 
Commission has considered the following elements: 

  Firstly,  the  high  accuracy  of  the  VECTO  simulation  tool.  The  simulation  tool  has  been 
designed and calibrated in such a way to ensure a high accuracy, in the order of +/-3 % 
according  to  tests  carried  out  by  DG  JRC.  This  measures  the  ability  of  VECTO  to 
accurately calculate the emissions and fuel consumption of a specific vehicle on a specific 
route.  

  Secondly,  it  will  be  important  to  set  up  periodic  verification  on  VECTO  and  its  use  by 
manufacturers  to  ensure  that  this  accuracy  remains  high  and  that  manufacturers  use  the 
VECTO  simulation  tool  in  a  correct  manner.  This  safeguard  will  consist  of  periodic 
verification  of  the  results  of  the  certification  procedure  and  of  the  accuracy  of  the 

25 

 
 
simulation tool. Discussions have started in view of the introduction of this requirement 
in the certification Regulation as soon as a robust verification testing procedure is agreed 
(see Annex 5). 

  Thirdly, from the side of the monitoring and reporting legislation, an additional safeguard 
will  be  foreseen  to  detect  possible  unjustified  divergences  found  in  the  reported  data 
through statistical analysis of the reported data (see above section 4.1.2).  

  Fourthly, the Commission aims to monitor the gap between the future VECTO data and 
real-world data. This gap should be as small as possible but cannot be entirely closed in 
view of the large variability in the use of the vehicles in real-world. A quantified analysis 
is not yet possible as VECTO is not in place and on-board fuel meters are not mandatory 
under the type approval. Further work will be needed in this respect and goes beyond the 
scope of this IA. 

VECTO as an open tool 
A non-governmental organisation and other stakeholders27 submitted a joint memorandum to 
the Commission28 requesting VECTO to be made available to third parties such as transport 
operators or suppliers. This should enable third parties to independently consult and compare 
vehicle combinations, their energy performance and CO2 emissions. 

The design of VECTO largely accommodates this request since it has been established as an 
open  source  software  under  EU  Public  License.  It  can  be  run  under  so-called  'declaration' 
mode  for  certification  purposes  and  under  'engineering'  mode  with  various  possible 
assumptions to assess vehicles' energy performance and emissions in a customized way (see 
Annex 4 for more details). However, the confidentiality of some of the input data, e.g. fuel 
and  engine  maps,  does  not  allow  the  access  of  VECTO  'declaration'  mode  to  third  parties. 
Furthermore, this concerns the regulation on certification. It was therefore discarded in this 
IA. 

Coverage of Well-to-Wheel emissions 

Some  stakeholders  proposed  that  the  monitoring  and  reporting  should  have  a  broader 
approach providing information not only of HDV tailpipe CO2 emissions but also of the GHG 
emissions from the whole fuel production process. 

This option has been discarded in the present IA for several reasons: 

  Certification only provides tank to wheel CO2 emission data. 
  Furthermore,  this  could  lead  to  double  regulation.  Today,  upstream  "well-to-tank" 
GHG  emissions  are  subject  to  other  EU  legislation  through  the  inclusion  of  the  oil 
industry and energy production sector into the EU Emission Trading System and by 
the Fuel Quality Directive29.  

  Creation of legal ambiguity as the responsibility for the fuel production process lies 

with the fuel producers, and the final choice of fuels is left to the truck operator. 

  A tank to wheel approach has also been taken in the case of cars and vans. 

27  The  International  Road  Union  (IRU),  The  European  association  for  forwarding,  transport,  logistics  and  customs  services  (CLECAT), 
Leaseurope,  the  European  Transport  Board,  the  European  Express  Association,  Green  Freight  Europe,  and  the  Nordic  Logistics 
association 

28https://www.transportenvironment.org/sites/te/files/publications/Memorandum%20on%20Heavy%20Duty%20Vehicle%20CO2_final.pdf 
29  Directive  2009/30/EC  (http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0030)  amending  Directive  98/70/EC 

(http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31998L0070) 

26 

 
 
                                                            
4.5 ARE SMALL AND MEDIUM SIZED ENTERPRISES TARGETED BY THE DIFFERENT 

OPTIONS?  

HDV  manufacturers  responsible  for  the  monitoring  and  reporting  are  all  very  large 
international companies, namely Daimler, Volvo Trucks (which is also the owner of Renault 
Trucks), MAN and  Scania which are part of the  VW group,  Iveco (CNH Industrial Group) 
and DAF (Paccar Group) (see Annex 7). 

Body and trailer manufacturers are to a large extent SMEs: the trailer and body-builder sector 
is highly diverse with thousands of enterprises most of which operate only in local markets. 
The  sector  is,  however,  not  impacted  as  body  and  trailer  manufacturers  are  not  involved  in 
the first stage of implementation of the certification regulation. VECTO simulations will use 
generic default values on body and trailer characteristics to calculate entire vehicle emissions. 

5.  WHAT ARE THE IMPACTS OF THE DIFFERENT POLICY OPTIONS AND WHO WILL BE 

AFFECTED?  

5.1 ECONOMIC IMPACTS 

5.1.1  GENERAL ECONOMIC IMPACTS 

Depending  on  consumer  choices,  rates  of  technological  progress  in  manufacturing  more 
efficient  vehicles,  and  the  actual  downstream  use  of  the  monitoring  and  reporting  data  by 
policy  makers,  the  potential  benefits  could  be  sizeable.  The  impact  assessment  that 
underpinned the 2014 HDV Strategy has shown that a more transparent HDV market would 
stimulate competition among HDV manufacturers and transport operators. This should foster 
innovation to produce more energy efficient vehicles in the EU market (see paragraph 5.6). 
For  instance  this  could  trigger  new  design  of  the  driving  cabin  to  improve  aerodynamic 
according to the directive on weights and dimensions30. Such redesign was quantified in the 
related impact assessment31 as yielding up to 8.9% of fuel savings. 

The effects of more energy efficient freight and passenger road transport are expected to, at 
least  partially,  pass-through  and  spread  to  most  sectors  of  the  EU  economy:  lower  fuel 
operating  costs  of  transport  will  under  the  current  competitive  environment  of  transport 
trigger  lower  transport  prices,  and  thereby  reduce  other  sectors'  costs  for  intermediate  and 
consumer  goods,  eventually  benefitting  EU  consumers.  However,  transport  costs  are 
generally a small share of overall product costs: the elasticity of output prices to increases in 
road  transport  prices  has  been  assessed  in  the  context  of  past  legislation  and  varies 
significantly32 across sectors. 

Options 1 and 3 are considered not to have different economic impacts. However, the second 
option  provides  much  less  detailed  information  for  policy  makers  and  therefore  benefits 
should be expected to be smaller. 

In the absence of knowledge on how exactly the gathered information will be used over time, 
it  is  difficult  to  assess  the  exact  vehicle  percentage  efficiency  gains  that  monitoring  and 

30 Directive (EU) 2015/719 of the European Parliament and of the Council of 29 April 2015 amending Council Directive 96/53/EC laying 
down for certain road vehicles circulating within the Community the maximum authorised dimensions in national and international traffic 
and the maximum authorised weights in international traffic, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015L0719 
31  Commission  Staff  Working  Document  Impact  Assessment  Accompanying  the  document  Proposal  for  a  Directive  of  the  European 
Parliament  and  of  the  Council  amending  Council  Directive  96/53/EC  laying  down  for  certain  road  vehicles  circulating  within  the 
Community  the  maximum  authorized  dimensions  in  national  and  international  traffic  and  the  maximum  authorized  weights  in 
international traffic (SWD/2013/0108 final), http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:52013SC0108 

32 See COM(96)339 final, Proposal of a Council Directive on the charging of heavy goods vehicles for the use of certain infrastructures, see 
in particular Annex 2 p. 34, available under http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:51996PC0331&from=EN 

27 

 
 
                                                            
reporting alone could trigger on top of business as usual, which is assumed by manufacturers 
at around 1.3% per year during the period 2005-202033. 

However, a simple marker of the potential economic benefits that could be reaped from such 
efficiency  gains  is  illustrated  in  Box  1.  It  shows,  under  the  assumptions  made,  that  an 
incremental  1%  improvement  of  the  energy  efficiency  of  the  fleet  could  lead  to  savings  of 
fuel costs for transport operators of about € 725 million per year. 

Box 1 Potential benefits of monitoring HDV fuel efficiency and CO2 emissions 

Potential benefits of monitoring HDV fuel efficiency and CO2 

The HDV fleet in the EU in 2014 consisted of around 5.6 million trucks and 0.6 million buses34, emitting some 
35.  Assuming  over  time  that  the  full  fleet  is  purchased  in  light  of  more  transparent  information 
214  MT  of  CO2
benefiting from such monitoring, each 1% efficiency gain on the HDV fleet would translate annually into 2.1 MT 
emission savings and fuel savings of 790 M litres, i.e. a gain of some € 725 M for transport operators at current 
automotive gas oil prices36 or 4.9 M barrels of oil. As this is mostly imported, i.e. a non-refined oil value of some € 
250  M  annually  based  on  an  oil  price  (brent)  of  USD  54.1537  i.e.  €  50.9  it  would  reduce  Member  States'  oil 
imports. 

Stakeholders' view 

The  majority  of  stakeholders  which replied  to  the  online  public  consultation  (see  Annex  2) 
share the opinion that the economic impacts of monitoring and reporting HDV CO2 emissions 
and fuel consumption are expected to be positive even though limited. 

5.1.2 

 COST OF OPTIONS (ADMINISTRATIVE BURDEN FOR MAIN STAKEHOLDERS 
CONCERNED) 

Monitoring costs have been estimated in an external study38 (see Annex 10) for each of the 
three  options  considered  and  of  the  actors  involved  (Member  States,  OEMs,  EEA/EC). 
Monitoring  costs  are  estimated  between  €  1  (Option  3)  and  €  5  (Option  1)  per  heavy-duty 
vehicle registered in the EU. 

These  costs  are  additional  to  the  costs  for  certification  (available  in  Table  1  and  2  in 
Annex 5). 

Two cost components have been assessed: 

   transition costs: implementation costs and database development/IT investments; 
   annual  costs:  technical  maintenance  and  IT  costs,  VECTO  data  transfer  costs, 

reporting costs, and costs for making checks and answering questions. 

These cost components have been described in more details and indicated for each option and 
respective actor in Table 2 below. 

Transition  costs  have  been  annualised  with  a  discount  rate  of  4%,  in  accordance  with  the 
Better  Regulation  Toolbox39,  and  a  10  year  depreciation  period.  Labour  costs  have  been 

33 ACEA, 2016, ACEA Position Paper Reducing CO2 Emissions from Heavy-Duty Vehicles, p. 14, 

https://www.acea.be/uploads/publications/ACEA_Position_Paper_Reducing_CO2_Emissions_from_Heavy-Duty_Vehicles.pdf  

34 ANFAC, 2016, European Motor Vehicle Parc 2014, http://www.acea.be/uploads/statistic_documents/ACEA_PARC_2014_v4.pdf, pp. 9-

10 

35 GHG Inventory data 2016,  
36 Based on automotive gas oil Price EU28 average week of 13 February 2017, https://ec.europa.eu/energy/en/data-analysis/weekly-oil-

bulletin, and http://www.eea.europa.eu/data-and-maps/indicators/fuel-prices-and-taxes/assessment-6  
37 Crude oil brent price for Europe on 13 February 2017, http://www.eia.gov/dnav/pet/pet_pri_spt_s1_d.htm 
38 CE Delft, 2016, Monitoring heavy-duty vehicles’ CO2 emissions and their costs - An assessment, available in Annex 11 
39 http://ec.europa.eu/smart-regulation/guidelines/docs/br_toolbox_en.pdf 

28 

 
 
                                                            
estimated based on an hourly rate of 30€/hour (60.000€ for one working year), and the figure 
includes also social charges and costs for pension (25%). 
Table 2. Cost components40 

Cost 
component 

Sub-component 
description 

Description 

Transition 
costs 

Annual 
costs 

Implementation 
costs 

Database 
development/ 
IT investments 

Technical 
maintenance &  
IT costs 

VECTO data 
transfer costs 

Reporting costs 

Costs for 
making checks, 
answering 
questions 

for  organising 

The  implementation  costs  are  defined  as 
non-technical  costs 
the 
process,  making  arrangements  between 
actors (between MS and OEM on registration 
procedure,  between  EEA  and  MS/OEM  on 
reporting  format).  These  costs  are  non-
recurring costs. 

The technical implementation costs refer to 
investments  in  the  development  of  needed 
databases  and  additional  IT  requirements. 
OEMs  database  costs  are  defined  as 
certification  costs  and  therefore  not  taken 
into  account.  These  costs  are  non-recurring 
costs. 

Data  management  costs  concern 
the 
technical  maintenance  costs  for  IT  systems 
and  databases.  These  only  apply  when  IT 
systems  are  in  use  for  the  sole  purpose  of 
HDV  monitoring.  OEMs  database  costs  are 
defined  as  certification  costs  and  therefore 
not 
account.  The  data 
management  costs  are  estimated  at  10%  of 
the technical investments. 

taken 

into 

VECTO  data  transfer  costs  apply  only  to 
monitoring  option  1.  In  this  option,  not  all 
Member  States  use  a  fully  digitalised 
registration  system,  and  additional  costs 
will  occur  when  registration  procedure  is 
extended  for  the  sole  purpose  of  HDV 
monitoring.  This 
for  all 
registrations  for  the  OEM  and  only  for  non-
digitalised registrations for Member States. 

is  the  case 

Reporting  costs  are  defined  as  costs  of 
transfer of data to EEA and management by 
EEA. These costs refer to the effort made by 
the responsible entity (MS in Option 1, OEM 
in Option 2 and both in Option 3) to perform 
the  annual  reporting.  In  case  of  EEA,  this 
cost  components  represents  the  processing 
of the received datasets. 

EEA  and  EC  will  perform  several  quality 
checks  in  order  to  evaluate  the  accuracy 
and the quality of the datasets. On the basis 
of  the  checks  and  the  feedbacks  from  the 
responsible 
preliminary 
database  is  published.  Depending  on  the 
quality  control  system  in  each  monitoring 
option,  various  actors  will  be  able  to  give 
feedback  on  the  datasets  and  notify  the 
Commission  of  any  errors  in  the  data.  The 

entity(ies) 

a 

Relevant for actor 
under option 1, 2 or 3 

MS 

OEM 

EEA 

1,3 

1,2,3 

1,2,3 

1 

1,2,3 

1,3 

1,2,3 

1 

1 

1,3 

1,2,3 

1,2,3 

1,3 

1,2,3 

1,2,3 

40 CE Delft, 2016, Monitoring heavy-duty vehicles’ CO2 emissions and their costs - An assessment, available in Annex 11 

29 

 
 
 
 
 
                                                            
feedback  is  assessed  and,  when  justified, 
taken into account for the final database. 

1)  Costs of Option 1 

Monitoring  costs  under  option  1  vary  greatly  among  Member  States  in  function  of  the 
number  of  registrations  and  the  degree  of  digitalisation  of  the  registration  systems  (for 
example a number of Member States still uses mainly paper work, see Table 3).  
Table 3. Rate of digitalised registrations and registration methods allowed in various countries41 

Country 

Austria 

Croatia 

Czech 
Republic 

Denmark 

Finland 

France 

Germany 

Greece 

Hungary 

Italy 

Lithuania 

Netherland
s 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

United 
Kingdom 

MS uses CoC42 
on paper for 
registration 
(WVTA43) 
Yes 

MS uses CoC 
XML file for 
registration 
(WVTA) 
Yes 

MS uses other 
(than) XML file 
for registration 

Yes, adapted 

Rate of total number of 
registrations on the basis of 
transferred digital files (from 
interviews) 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes + local 
declaration 
paper 

Yes 

Only for 
incomplete HDV 

Yes 

Yes 

Yes 

No 

No 

Only for 
complete 
vehicles, other 
vehicles via 
national IVA 

Yes 

Yes 

Yes 

No 

No 

Yes 

No 

No 

Yes 

No 

Yes 

No 

No 

Yes 

Yes 

Yes 

No 

No 

No 

Not decided yet, 
system DMR 

No 

Yes (OTC file) 

Yes adapted 

No 

No 

No 

No 

IVI standard 
designed by EReg 

No 

No 

No 

Yes 

No 

No 

Moderate 

Moderate 

Low 

High 

None 

None 

High 

High 

High 

Low 

Low 

Decisive cost categories are thus the development and operation of the needed IT systems by 
Member States in order to process large monitoring data files and the transfer of individual 
data files per vehicle. 

41 CE Delft, 2016, Monitoring heavy-duty vehicles’ CO2 emissions and their costs - An assessment, available in Annex 11 
42 CoC = Certificate of Conformity 
43 WVTA= Whole Vehicle Type-Approval  

30 

 
 
 
 
 
 
 
 
 
 
                                                            
Total one-off transition costs for all Member States are estimated to be around €2 million and 
the annual costs for all EU Member States around €500.000 per year. When transition costs 
are annualised, the total costs are estimated to about € 800.000 per year in average for each 
Member State. 

Transition costs for all manufacturers have been estimated in the range of €125.000-250.000 
and annual costs between €75.000-180.000 per year, plus €20.000 for data checking. 

2)  Costs of Option 2 

This option entails no additional costs for Member States. Transition costs per manufacturer 
are estimated to be around €16.500 and annual costs around €7.000 for reporting plus €6.750 
for checking data. 

3)  Costs of Option 3 

This option does not involve transition costs for Member States and in total annual costs are 
estimated in average at around €100.000 for all Member States (around €3.500 per Member 
State) per year. Costs for manufacturers are similar as for option 2. 

All  three  options  require  transition  costs  of  around  €250.000  for  the  EEA/EC  and  around 
€175.000 of annual costs. Total annualised costs for the EEA/EC are estimated to be around 
€205.000. 
Table 4. Comparison of total costs of monitoring options 

Entity 

Cost component 

Option 1 
national 
authorities 
reporting to 
EC/EEA 

Option 2  
manufacturers 
reporting to 
EC/EEA 

Option 3 
Mixed : national 
authorities/manufacturers 
reporting to EC/EEA 

HDV 

Manufacturers 

Transition costs 

k€  1.313 

Annual costs 

k€     901 

k€   116 

k€   96 

Total 
annualised(*) 

k€ 1.062 

k€   110 

Transition costs 

k€  2.242 

Member States 

Annual costs 

k€    534 

EC/EEA 

Total annualised 
(*) 

Transition costs 

Annual costs 

Total 
annualised(*) 

k€   811 

k€   250 

k€   175 

k€   206 

0 

0 

0 

k€   250 

k€   175 

k€   206 

k€   116 

k€     96 

k€   110 

0 

k€   98 

k€   98 

k€   250 

k€   175 

k€   206 

Total annualised 

Total annualised 
(*) 

k€  2.079 

k€   316 

k€   414 

(*) Transition costs were annualised using a discount rate of 4% and a period of 10 years 

   Source: CE Delft (2016) 

Stakeholders' view 

31 

 
 
 
These  results  of  the  cost  assessment  carried  out  by  CE  Delft  were  presented  at  the 
stakeholders' meeting on 17 October 201644 and have not been challenged. 

5.2 SOCIAL IMPACTS 

There is no expected appreciable impact on employment from either option in the short term. 

The  possible  short  term  impact  on  employment  could  be  the  few  jobs  related  to  the 
monitoring  and  reporting  function  in  national  authorities  (options  1  and  3),  vehicle 
manufacturers (option 2 and 3). In all three options, two45 additional full time employees will 
be required in the EEA and 0.5 in the EC. 

In the medium to long-term, positive social impacts are expected through the stimulation of 
competitiveness and innovation for manufacturers and transport operators. No quantification 
is however possible at this stage. 

Stakeholders' view 

The majority of stakeholders which replied to the online public consultation agree that social 
impacts will not be material for any of the options. 

5.3 ENVIRONMENTAL IMPACTS 

5.3.1  CO2 EMISSIONS 

As indicated in the impact assessment that underpinned the 2014 HDV Strategy, certification, 
monitoring and reporting of HDV CO2 emissions in curbing HDV fuel consumption and CO2 
emissions is expected to be effective.  

This  action  would  establish  a  reliable  track  record  of  whole  HDV  emissions,  independent 
from each manufacturer's measurement, providing reliability and transparency to the market 
as to real vehicle performances. This would be expected to increase awareness among fleet 
operators  on  the  most  cost  effective  vehicles  to  operate,  and  influence  decision  making  in 
purchasing new HDVs. 

A second dynamic impact related to increased transparency in the HDV market, is expected 
to  be  the  creation  of  an  incentive  for  HDV  manufacturers  to  innovate  and  to  the  uptake  of 
fuel efficiency technologies, which in the long term will contribute to an increasing share of 
more energy efficient heavy-duty vehicles in the fleet. 

A precise quantification of the impacts of monitoring and reporting over time on HDV CO2 
emissions in the EU could not be carried out due to the lack of reliable methodology for such 
an assessment. However, the simple marker illustrated in Box 1 above provides an indicative 
benchmark. Assuming over time that the full fleet is purchased in light of more transparent 
information benefitting from such monitoring, an incremental 1% efficiency improvement in 
the EU fleet would translate into around 2.1 Mt CO2 emission reductions. 

Impacts are therefore expected to be favourable. CO2 emissions reductions would be relevant 
for new vehicles and progressively for the whole HDV fleet. 

44  The  stakeholder  meeting  on  17  October  2016  took  place  in  Brussels  with  around  70  participants  representing  EU  Member  States,  the 
automotive  industry  (original  equipment  manufacturers  and  component  suppliers),  transport  operators,  the  logistics  sector,  non-
governmental 
services 
Environment 
organisations, 
(http://ec.europa.eu/clima/events/articles/0113_en). 

Commission 

European 

Agency 

other 

and 

the 

45 This assessment differs from the CE Delft study in Annex 10, since after the study was completed, it became clear that additional tasks 
would be necessary, with important implications for the resources required at the Agency. In particular, an additional post,  compared to 
1FTE estimated in the study, would be needed due to the additional statistical analysis to be performed by the Agency on behalf of the 
Commission for verification purposes (see section 4.1.2). 

32 

 
 
                                                            
The three options are not expected to have different impacts on CO2 emissions. 

Stakeholders' view 

The large majority of stakeholders, who replied to the online public consultation, agree that 
HDV  monitoring  and  reporting  will  increase  awareness  among  fleet  operators  on  the  most 
effective vehicles to operate and consequently influence their purchasing decisions. They also 
agree that its effect on reducing HDV fuel consumption and CO2 emissions will be real but 
limited. 

5.3.2 

 OTHER EMISSIONS 

Other  environmental  impacts  considered  relate  to  emissions  of  air  pollutants  (particulate 
matter,  nitrogen  oxides,  un-burnt  hydrocarbons  and  carbon  monoxide),  which  are  already 
regulated under the Euro VI Regulation. As underlined in the impact assessment attached to 
the 2014 HDV Strategy, favourable but only negligible impacts can be expected. Given that 
HDV engines are already subject to not-to-exceed limits according to the EURO VI standard 
for such pollutant emissions, favourable impacts on the overall pollutant emissions from the 
vehicle can only be expected from efficiency measures outside the engine, e.g. aerodynamic 
improvements of the cabin. Quantitative estimates cannot be provided at this stage.  

The three options are not expected to have any differentiated environmental impacts. 

Stakeholders' view 

The  majority  of  stakeholders,  who  replied  to  the  online  public  consultation,  shared  the 
opinion that the increased fuel efficiency of vehicles would lead to some reduction of other 
non-CO2 emissions. 

5.4 IMPACT ON COMPETITIVENESS AND INNOVATION 

Within  the  EU  market,  positive  impacts  on  competitiveness and  innovation  are  expected  in 
the medium / long-term, irrespective of the options. Such impacts would be differentiated by 
sector. 

1)  Automotive manufacturing industry. As anticipated in the 2014 HDV Strategy impact 
assessment,  no  material  impacts  are  expected,  even  though,  to  some  extent, 
comparability  between  manufacturers'  vehicles  energy  efficiency  may  foster 
innovation and the industry's competitiveness on the EU internal market. Innovation 
would be fostered both at the level of component and vehicle manufacturers. 

2)  Transport operators. The combined cost of vehicle purchase and operation would be 
expected to be reduced by improved comparability of the HDVs' energy performance, 
leading to improved performance of transport operators expected to be at least partly 
passed through to their customers through lower prices, as this is a very competitive 
industry. 

3)  Other sectors of the economy. Lower transport costs may (marginally) lead to lower 
prices  of  intermediate  goods,  and  thereby  to  increases  in  competitiveness  of  many 
other segments of the economy. In relative terms on the EU market this would only 
affect  the  competitiveness  of  companies  operating  in  the  same  market  if  they  have 
very different shares of transport costs in their product costs. 

Stakeholders' view 

The  large  majority  of  stakeholders  responding  to  the  online  public  consultation  agreed  that 
increased  transparency  in  the  HDV  sector  would  improve  competition  among  HDV 

33 

 
 
manufacturers  and  transport  operators.  Stakeholders  also  agreed  that  marginal  positive 
impacts can be expected in terms of improved competitiveness. 

5.5 IMPACTS ON THIRD COUNTRIES AND ON EU INTERNATIONAL TRADE 

There is not likely to be any direct impact on third countries. 

Switzerland  has  in  the  past  largely  replicated  EU  car  and  light  commercial  vehicle 
Regulations and might continue to do so in the future. It is possible that other countries might 
take inspiration from the EU approach in this field. However, most of the large countries such 
as the US, China and Japan, have already put in place a system of certification, monitoring 
and reporting of HDVs emissions. 

Impacts on EU international trade and investment are expected to be positive in the medium / 
long-term and differentiated among sectors of the economy: 

  Automotive  manufacturing  industry.  As  indicated  in  the  competitiveness  assessment 
(annex 10) of the 2013 impact assessment underpinning the 2014 HDV Strategy46, the EU 
HDV industry is highly competitive, has a positive trade surplus and specialisation index 
in  HDV  production  and  trade.  Expected  improvements  in  innovation  uptakes  and  the 
international 
industry's  competitiveness  would  benefit 
competitiveness  and  its  global  market  penetration  both  through  trade  or  Foreign  Direct 
Investment  (FDI)  and  overseas  production.  It  should  also  be  noted  that  the  other  major 
HDV  markets  in  the  world  (US,  China  and  Japan)  have  already  enacted  HDV  CO2 
emissions, setting emission standards, leading manufacturers from these other markets to 
enhance the efficiency of their fleet to comply with the standards. 

the  EU  HDV 

industry's 

  Transport operators. While benefitting from improved competitiveness in the EU market, 
the  industry  of  transport  services  would  not  be  expected  to  significantly  improve  its 
international  position  (outside  the  EU)  as  differences  in  labour  costs  would  not  be 
affected.  More  energy  efficient  vehicles  would  also  be  expected  to  be  available  to 
competitors in neighbouring countries. 

  Other sectors of the economy. The above mentioned competitiveness assessment took the 
view  that  the  implementation  of  legislative  measures  to  reduce  HDV  fuel  consumption 
and  CO2  emissions  may  change  the  costs  of  intermediate  products  and  hence  also  the 
costs  of  final  products  through  changes  in  transport  costs.  For  products  offered  on  a 
global market, the change in transport costs due to measures aimed at reducing HDV CO2 
emissions  may  also  affect  the  global  competitive  position  of  European  companies.  For 
both  situations,  however,  transport  costs  are  generally  a  small  share  of  overall  product 
costs.  Direct  or  indirect  impacts  on  EU  international  trade  through  changes  in  the  cost 
price of intermediate and final products will therefore most likely be negligible. 

Options are not expected to differ with respect to these impacts. 

Stakeholders' view 

Most  of  the  stakeholders,  respondents  to  the  online  public  consultation,  agree  that,  if  the 
international 
assumptions  above  mentioned  are  fulfilled, 
competitiveness and EU exports could marginally benefit. 

the  EU  HDV 

industry's 

46 http://ec.europa.eu/clima/policies/transport/vehicles/heavy/docs/swd_2014_160_en.pdf 

34 

 
 
                                                            
5.6 IMPACT ON SMES 

1)  Manufacturing industry  

In  the  case  of  HDV  manufacturers,  there  is  no  expected  impact  on  SMEs  as  the  main 
HDV  manufacturers  are  all  very  large  international  companies,  in  particular  6  large 
manufacturing companies dominate the EU HDV market (see Annex 7). 

Body and trailer manufacturers are mostly SMEs but no impacts are expected since they 
are not involved in the monitoring and reporting. In the first stage of certification, trailers 
and body will be included in the VECTO simulation using default values. 

2)  Transport operators  

Transport companies, most of which are SMEs (see Annex 7) operating only a few trucks 
or  buses,  would  benefit  from  the  monitoring  of  emissions  as  this  would  provide  more 
transparency  on  the  fuel  consumption  performance  of  HDVs.  The  transport  companies 
will  be  able  to  take  this  information  into  consideration  in  their  purchasing  decisions, 
thereby realising fuel savings and reducing their operating costs. 

The economic impact for transport operators is subject to the evolution of fuel prices. An 
assessment of mid-2015 (i.e. when oil prices were around 60 USD/barrel) estimated fuel 
to  represent  between  26%  and  36%  of  transport  operators  costs,  with  variations  to  the 
category of vehicle and cycle47. Another assessment by the French Fédération Nationale 
du Transport Routier suggests lower fuel relative costs in 2016 between 14.3 and 20.7% 
of  operating  costs  (see  Annex  8)  as  a  result  of  the  recent  fall  in  oil  prices.  The  Freight 
Transport Association (FTA) in the UK estimated in July 2016 that fuel costs represented 
a  percentage  ranging  between  17  and  32%  of  total  annual  vehicle  operating  costs48, 
depending  on  mileage  and  gross  vehicle  weight49.  The  Comité  National  Routier  (CNR) 
estimated  the  share  of  fuel  costs  of  total  operating  costs50  for  a  heavy-duty  vehicle  of 
40tonnes to be 21.1% for regional delivery and 23.1% for long haul in December 201651. 

While these operating costs follow fuel price developments, this points to fuel operating 
costs that represent a very significant share of transporters' overall costs. 

Depending  on  the  penetration  of  fuel  efficient  HDVs,  the  impact  may  be  significant  on 
transport prices as well, given the highly competitive situation in the transport industry. 
This  suggests  that  with  high  penetration  the  fuel  cost  saving  is  expected  to  be  passed 
through to transport end-users. 

Options are not expected to have differentiated impacts in this respect. 

Stakeholders' view 

The  vast  majority  of  stakeholders,  respondents  to  the  online  public  consultation,  agree  that 
transport  companies,  most  of  which  are  small  SMEs,  are  expected  to  benefit  from  the 
monitoring of fuel consumption and CO2 emissions from HDVs. 

47 "Transporte Profesional", Separata especial N°354, October 2015 
48 Vehicle standing costs, vehicle running costs and driver costs 
49 Source: FTA's Manager's Guide to Distribution Costs - July 2016 Update Report 

http://www.fta.co.uk/policy_and_compliance/fuel_prices_and_economy/fuel_prices/fuel_fractions.html 

50 Including cost of fuel (excluding VAT, taking into account the partial reimbursement of excise), maintenance costs, infrastructure charges, 

equipment , driver (remuneration + employers' contributions), travel expenses and charges. 

51 http://www.cnr.fr/Indices-Statistiques/Longue-distance-40T#haut, and http://www.cnr.fr/Indices-Statistiques/Regional-40T#haut  

35 

 
 
 
 
                                                            
6.  HOW DO THE OPTIONS COMPARE? 

6.1 EFFECTIVENESS 

Against the general policy objectives:  

1) Facilitate a reduction in fuel costs for transport operators 

All options would make available to transport operators data on fuel consumption and CO2 
emissions from new HDVs placed on the EU market, through the publication of a database 
where  vehicle  efficiency  could  be  compared.  Regardless  of  the  option  chosen,  transport 
operators will benefit from the information  available, which will influence  their purchasing 
decision  towards  the  vehicles  that  would  allow  the  highest  fuel  savings  for  their  specific 
operations. 

2) Contribute to the improvement of the competitiveness of HDV manufacturers 

Providing  information  on  fuel  consumption  and  CO2  emissions  will  create  an  additional 
incentive for HDV manufacturers to invest in innovation in order to put on the market more 
fuel efficient technologies and vehicles, improving their competitiveness worldwide. This is 
the case for all of the options. 

3) Contribute to the achievement of the EU's climate and energy targets and objectives 

All  options  would  make  available  data  on  fuel  consumption  and  CO2  emissions  to  policy 
makers, providing a baseline for policy action to reduce HDV emissions and also a tool for 
implementation and enforcement of future CO2 emission standards. 

Against the specific objectives: 

  Enable informed purchasing decisions and deployment of more fuel efficient vehicles  
  Foster innovation and development of fuel efficiency technologies  
  Promote  cost-effective  reductions  of  CO2  emissions  and  reduce  overall  fuel 

consumption from HDVs 

  Enable  the  development  of  rational  policies  promoting  the  uptake  of  advanced  fuel 

efficient and low emission HDVs 

All  options  would  provide  for  information  on  fuel  consumption  and  CO2  emissions  per 
vehicle  and  would  allow  comparing  the  performance  of  new  vehicles  placed  on  the  EU 
market from various manufacturers by market segment. 

However,  option  2  is  considered  to  meet  the  specific  objectives  only  partly,  as  it  will  not 
provide information at the level of each Member State. The HDV monitoring data reported 
by  manufacturers  would  be  based  on  the  vehicles  sold.  Registration  information  held  by 
national  authorities  would  not  be  provided  under  this  option.  As  a  result,  the  reported 
emissions data could not be allocated to a particular Member State. This would make it more 
difficult  for  Member  States  to  design  effective  national  policies  to  increase  the  uptake  of 
more efficient HDVs. 

Option  2 is in  this respect less effective than options 1 and 3, under which Member States' 
HDV emissions would be satisfactorily covered through the registration data provided to the 
EC/EEA by their national authorities.  

Options  1  and  3  are  equally  effective  in  meeting  all  specific  objectives,  since  they  would 
equally contribute to market transparency, overcoming the main market barrier identified i.e. 
the lack of information on the most efficient vehicles. 

36 

 
 
Option 1 is less effective than option 3 in meeting the last specific objective of enabling the 
development  of  rational  policies  promoting  the  uptake  of  advanced  fuel  efficient  and  low 
emission HDVs. This is due to the risks concerning the quality of the data. Under option 1, 
the digital flow of information may be interrupted if national registration authorities operate 
in a non- or partly digitalised mode. This may cause errors in reporting the monitoring data to 
the  EEA.  This  risk  does  not  materialise  under  option  3  as  the  data  flow  will  be  fully 
digitalised. 

Under  option  3,  the  possible  risks  of  errors  identified  relate  to  the  EEA  matching  each 
vehicle's registration data provided by Member States with the corresponding monitoring data 
reported  by  manufacturers.  These  risks  will  be  mitigated  through  the  implementation  of  a 
quality assurance and quality check (QA/QC) process by the EEA, for example performing 
checks on:  

the completeness of the data;  
the variability;  
the plausibility, in order to identify outliers (e.g. vehicles with similar characteristics 
and very different emissions). 

Similar  mitigation  measures  have  been  put  in  place  successfully  by  the  EEA  for  the 
monitoring and reporting of CO2 emissions from vans (see Annex 8). 

In light of the above, option 3 is considered the most effective option in meeting the specific 
objectives. 

6.2 EFFICIENCY 

The main efficiency criterion that is being considered is the administrative costs. 

This costing exercise exhibits a quite significant difference between option 1, which turns out 
to be the most costly, and the two others, that have modest cost implications. 

The  main  reason  for  this  lies  in  the  current  state  of  play,  in  which  registration  is  in  most 
countries not a digitalised process. The cost assessment has assumed that digitalisation would 
be  required.  Significant  costs  are  therefore  anticipated  for  establishing  the  necessary 
digitalised IT procedures and database systems, mainly for Member States, and more limited 
costs for manufacturers to adapt to possible shortcomings in the transmission chain of digital 
data. While overall relatively moderate in view of the size of the EU economy, option 1 costs 
are high for Member States considering the available resources of the relevant authorities. 

In the case of options 2 and 3, costs would be minimal for Member States. Authorities in the 
Member  States  are  not  involved  for  option  2,  and  only  have  to  submit  one  monitoring 
parameter,  i.e.  the  Vehicle  Identification  Number  (VIN)  for  option  3. Manufacturers  would 
not face high costs either, as they will have to set up the necessary databases to implement the 
certification  obligations.  The  main  costs  lie  with  the  EC/EEA,  which  is  in  charge  of 
processing the data, publishing them and reporting. 

6.3 PROPORTIONALITY 

In  view  of  its  necessity  and  potential  magnitude  of  the  economic  benefits,  EU  monitoring 
envisaged  in  the  three  options  would  meet  proportionality  requirements:  at  the  EU  scale, 
efforts  needed  are  rather  limited  and  costs  reported  above  almost  negligible  compared  with 
potential benefits.  

In addition, the costs estimated per vehicle for the options rank between €1 for option 3 and 
€5 for option 1, which compared to the cost of a vehicle (in the order of hundred thousand 

37 

 
 
  
  
  
euros) and  to  the  annual  fuel  cost (in  average  estimated  above  €20.000  per  vehicle)  can  be 
considered as negligible. Saving 1 litre of fuel from around 30.000 litres consumed in average 
per year by a vehicle would be enough to cover the total administrative costs related to the 
monitoring of this vehicle. 

6.4 SUBSIDIARITY  

In all cases, EU-level action is deemed superior to fragmented national initiatives to monitor 
HDV fuel consumption and CO2 emission. 

6.5 COHERENCE WITH OTHER MAINSTREAM EU POLICIES 

Options 1 and 3 are expected to rank equally in addressing the identified knowledge gap and 
in providing accurate and complete information on CO2 emissions from HDVs in the EU to 
serve as  baseline for future policy action.  Option 2 would instead  be expected to  provide a 
less complete baseline, lacking the geographical distribution of emissions.  

Option  2  would  therefore  risk  a  lower  level  of  coherence  with  the  main  EU  policies 
concerning GHG emissions from transport as it would not provide data at the Member States 
level.  This  could  lead  to  inconsistencies  and  inefficiencies  when  implementing  key  EU 
policies: the European Strategy for low-emission mobility52, the review of the "Eurovignette" 
Directive53  and  the  Effort  Sharing  Regulation  setting  2030  national  targets  for  GHG 
emissions in non-ETS sectors, including transport. 

6.6 STAKEHOLDERS' VIEWS 

The  majority  of  stakeholders  agree  that  manufacturers  of  heavy-duty  vehicles  and  public 
authorities should share the administrative burden of monitoring HDV fuel consumption and 
CO2 emissions. 

Most of the stakeholders, across all categories, expressed a preference for option 3, pointing 
out  that  the  administrative  burden  of  monitoring  and  reporting  is  shared  between 
manufacturers and Member States' authorities and that the digital flow of data is ensured. 

6.7 CONCLUSIONS 

Table  5  provides  an  illustration  on  how  the  options  compare  and  rank  based  on  the 
explanations given in the previous paragraphs. 

52 https://ec.europa.eu/transparency/regdoc/rep/1/2016/EN/1-2016-501-EN-F1-1-ANNEX-1.PDF 
53 Review of Directive 1999/62/EC ("Eurovignette") as amended, on the charging of heavy goods vehicles for the use of certain roads. 

38 

 
 
 
 
                                                            
 Table 5. Comparison of monitoring options 

Option 1 
national authorities 
reporting to EC/EEA 

Option 2  
manufacturers reporting 
to EC/EEA 

Option 3 
Mixed: national 
authorities/manufacturers 
reporting to EC/EEA 

Effectiveness  
in meeting 
objectives 

Efficiency 
(proportionality of 
effort, in particular 
costs, needed to 
reach objectives) 

Stakeholders views 

+ 

Objectives are expected to be 
met under this option, 
however there are risks for 
the integrity of the monitoring 
data due to the possible 
interruption of the digital flow 
of information during the 
reporting 

= 
This option is the most costly, 
but its overall cost remains 
moderate (to keep the 
continuous flow of digital 
monitoring data national 
authorities would need to 
make significant investments 
as a large number of them 
currently process data with 
paper) 

+ 

Option considered as 
possible by around 30% of 
the stakeholders. However 
not favored by many of them 
in view of its costs, the 
interruption of the digital flow 
of information and hence its 
low efficiency 

Subsidiarity 

++ 

EU scheme superior to 
aggregation of national ones 

- 

Objectives are expected to be 
partly met with an important 
caveat: manufacturer's 
monitoring data would be 
sales-based and would not 
include national registration 
data. This option would hence 
not provide full set of 
information at EU level nor at 
Member State level 

++ 

Objectives are expected to be 
met under this option 

++ 
This option has a zero cost for 
national authorities, and a 
moderate one for 
manufacturers as well as the 
EC/EEA 

++ 

This option has only a marginal 
cost for national authorities, 
and a moderate one for 
manufacturers as well as the 
EC/EEA 

- 

Option considered as possible 
but not favored by most 
stakeholders given its burden 
falling exclusively on HDV 
manufacturers and the lack of 
MS data coverage  

+ 

EU scheme superior to 
aggregation of national ones, 
however limited information 
hampers development of 
national policies 

++ 
Option favored by most of 
stakeholders (above 40%) in 
view of its good efficiency and 
effectiveness 

++ 

EU scheme superior to 
aggregation of national ones 

Coherence with 
other mainstream 
EU policies 

++ 

- 

++ 

Option expected to contribute 
to the broader EU objectives 
and mainstream policies  

Option expected to contribute 
in a less effective way to the 
broader EU objectives and 
mainstream policies  

Option expected to contribute 
to the broader EU objectives 
and mainstream policies 

Ranking 

2 

3 

1 

In view of this assessment, Option 3 is the preferred option for the following key reasons: 

1)  Its  administrative  cost  is  modest  compared  to  the  more  costly  option  (option  1)  and 

comparable to the cost of option 2. 

2)  It is more effective than options 1 and 2 as it ensures the digital flow of information 

and provides for the expected degree of reliability of national data. 

3)  This option meets subsidiarity requirements. 

Given the latter three criteria findings, it is the option that is the most proportionate in view of 
effort needed compared with effectiveness in meeting objectives. 

39 

 
 
 
 
In the stakeholders' consultation it appeared as the most favoured option by the majority of 
stakeholders, from all categories. 

On  other  criteria,  namely  the  economic  and  social  impacts,  environmental  impacts, 
addressing market barriers, and possible effects for SMEs this option appears as effective as 
options 1 and 2. The option 3 also meets all the general, specific and operational objectives. 

It  should  thus  be  concluded  from  the  present Impact  Assessment  that  this  option  should  be 
the one retained in the upcoming regulation on monitoring and reporting HDV CO2 emissions 
and fuel consumption. 

A  fully-fledged  new  legislative  basis,  under  the  ordinary  (co-decision)  legislative  approval 
procedure will be required to establish such monitoring and reporting. 

7.  HOW WOULD ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

In order to monitor and evaluate the progress made towards the operational objectives of this 
monitoring and reporting initiative, the following four indicators are proposed: 

1)  Average  annual  CO2  emissions  and  fuel  consumption  per  vehicle  group, 
manufacturer  and  Member  State  from  new  HDVs  registered  in  the  EU  within  the 
scope of the certification legislation. 

This indicator should be calculated each year by the European Environment Agency based on 
the reported data for the retained option. Over time, it will give an indication on the amount 
of fuels saved and the reduced costs for operators. 

2)  Comparison  of  average  annual  CO2  emissions  and  fuel  consumption  of  the  same 

group of vehicles across different years. 

This indicator should be calculated every year by the European Environment Agency based 
on the reported data for the retained option. Over the time it would help monitor and evaluate 
progress  towards  the  three  general  policy  objectives,  indicating  the  uptake  of  more  fuel 
efficient  vehicles,  and  in  particular  showing  each  year  the  rate  of  annual  efficiency 
improvement  in  each  vehicle  group,  i.e.  whether  new  vehicles  in  the  same  group  have  an 
increased  fuel  efficiency  and  lower  CO2  emissions.  It  would  also  demonstrate  the  level  of 
innovativeness of the manufacturing industry and the acceptance by transport operators. 

3)  Annual overview of fuel efficiency technologies fitted in the new vehicles and their 

penetration level. 

This indicator should be calculated each year by the European Environment Agency based on 
the  reported  data  for  the  retained  option.  The  results  of  this  monitoring  will  enable  better 
design  of  emission  reduction  measures,  and  especially  the  further  development  of  CO2 
emission  standards,  providing  knowledge  about  technology  development  and  penetration 
level in the fleet and therefore allowing a more accurate estimation of the level of ambition 
for such measures. It would also be an indicator of overall innovation in the manufacturing 
industry. 

4)  Exports and imports of HDVs 

This  indicator  would  give  an  indication  on  the  competitive  position  of  EU  HDV 
manufacturers, based on data being collected via EUROSTAT. 

40 

 
 
 
 
ANNEX 1 - PROCEDURAL INFORMATION 

1.  Organisation and Timing 

The  Directorate-General  (DG)  for  Climate  Action  was  leading  the  preparation  of  this 
initiative and the work on the impact assessment in the European Commission.  

An  inter-service  steering  group  (ISG),  chaired  by  DG  Climate  Action  and  the  Secretariat-
General,  was  established  in  December  2015  on  CO2  emissions  from  road  vehicles  and  was 
tasked of preparing this initiative. The ISG met four times in the period from December 2015 
to February 2017. The following Directorates-General (DGs) participated in the work of the 
group:  Secretariat-General  (SG),  Legal  Service  (SJ),  DG  GROW,  DG  MOVE,  DG  ECFIN, 
DG  ENER,  DG  ENV,  DG  JUST,  DG  RTD,  JRC,  DG  TAXUD,  DG  CNECT,  DG  COMP. 
The EEA was also consulted. 

An indicative roadmap was adopted in July 2016. 

An online public consultation took place from 20 July to 28 October 2016 (see Annex 2). A 
stakeholder consultation meeting took place on 17 October 201654.  

2.  Consultation of the Regulatory Scrutiny Board 

 The Regulatory Scrutiny Board received the draft version of the present impact assessment 
report  on  24  February  2017  and  following  the  Board  meeting  on  22  March  2017  issued  a 
positive  opinion  on  24  March  2017.  The  Board  made  recommendations.  Those  were 
addressed in the revised IA report as follows: 

RSB recommendations 

Modification of the IA report 

1) The introduction is not sufficiently clear on the 
context  and  scope  of  the  impact  assessment. 
Explanation  of 
interlinked  prior  and  future 
decisions  on  emission  reporting  and  certification 
regulation is inadequate. 

Explanations have been added in the first section 
to  clarify  what  decisions  had  already  been  taken 
in  the  past,  concerning  the  development  of  a 
simulation  tool  and  a  certification  procedure  for 
CO2  emissions  and  fuel  consumption  from  new 
HDVs, and how future decisions, in particular on 
CO2  emission  standards  for  HDVs,  are  linked 
with  this  initiative  on  monitoring  and  reporting 
HDV CO2 emissions. 

2)  Data  sensitivity  and  the  potential  market-
disruptive  risks  relating  to  the  monitoring  and 
data collecting system lack assessment. 

Section  4.1.4  has  been  expanded  to  provide 
considerations  on 
the 
publication  of  monitoring  data  for  the  EU  HDV 
market. 

the  risks  related 

to 

3) The differences in digitalisation costs between 
options lack specificity. 

Sections  4.3  and  5.1.2  have  been  further 
elaborated to provide more details about the costs 
of each option. 

3.  Evidence and external expertise used 

The cost assessment of the different monitoring and reporting options was carried out by CE 
Delft.  The CE  Delft  study  is  largely  based  on interviews to  national  registration  authorities 
and  HDV  manufacturers,  in  order  to  collect their  opinion about  various monitoring  options 
and receive targeted input with regard to the costs for their organisation, taking into account 
the current procedures and required adaptations. 

54 http://ec.europa.eu/clima/events/articles/0113_en 

41 

 
 
                                                            
Moreover,  the  IA  relies  on  the  previous  Impact  Assessment  from  2014  accompanying  the 
Strategy  for  Reducing  Heavy-Duty  Vehicles  Fuel  Consumption  and  CO2  Emissions,  in 
relation to the assessment of the other impacts.  

42 

 
 
 
 
ANNEX 2 - STAKEHOLDER CONSULTATION 

1.  Process and quantitative results of the public consultation  

The European Commission organised a public online consultation from 20 July to 28 October 
2016, i.e. 12 weeks, on the preparation of legislation on monitoring and reporting of Heavy-
Duty Vehicle fuel consumption and CO2 emissions55. The Part A of the consultation sought 
input  on  how  to  monitor  and  report  fuel  consumption  and  CO2  emissions  from  heavy-duty 
vehicles, with questions concerning the need of action, the objectives, the options and their 
anticipated impacts. Part B of the consultation focused on requesting general feedback on the 
need and design of CO2 emissions and fuel efficiency standards. The public consultation was 
carried  out  using  the  “General  principles  and  minimum  standards  for  consultation  of 
interested parties by the Commission”.  

The  consultation  received  responses  among  others  from  professional  organisations,  private 
enterprises,  civil  society  organisations,  public  authorities,  international  organisations, 
individuals/private persons and 'others'.  

This  analysis  will  only  focus  on  the  replies  to  Part  A  of  the  online  consultation  as  directly 
linked  to  the  initiative  on  monitoring  and  reporting  HDV  CO2  emissions  and  fuel 
consumption  that  this  impact  assessment  aims  to  underpin.  Replies  to  Part  B  of  the  online 
consultation  will  be  analysed  in  the  frame  of  the  future  impact  assessment  on  HDV  CO2 
emission standards. 

Part  A  of  the  public  consultation  consisted  of  a  questionnaire  in  English  with  twelve  main 
questions,  ten  multiple  choices  (in  some  cases  articulated)  and  two  spaces  limited  to  2  000 
characters for additional comments. This report follows the structure of the questions in the 
consultation questionnaire. The individual stakeholder submissions can be downloaded on the 
consultation  website  for  those  stakeholders  that  gave  their  consent  to  publication  (either 
under  the  given  name  or  anonymously),  whereas  6  submissions  are  not  available  either 
because missing publication consent or because received in a modified format.  

Main conclusions from the consultation replies can be summarised as follows: 

   general agreement with the need of action at EU level to monitor vehicle efficiency to 

close the identified knowledge gap; 

   broad  support  of  the  objectives  put  forward,  especially  reducing  HDV  fuel 
consumption and  CO2 emissions,  improving market transparency in the HDV sector 
and ensuring competitiveness of the European HDV manufacturing sector; 

   option  3,  i.e.  mixed  reporting  by  national  authorities  and  HDV  manufacturers,  is 
considered as the most appropriate option by most stakeholders, followed by option1, 
i.e. national authorities reporting; 

   broad agreement with the expectation of a positive although limited economic impact; 
increased transparency in  the HDV market is expected to contribute to an improved 
level  playing  field  among  HDV  manufacturers  and  the  available  comparability  is 
likely to foster innovation; 

   a  marginal  increased  competitiveness  of  the  transport  sector  is  expected  by  the 
majority of stakeholders, as a result of lower transport costs due to more fuel efficient 
vehicles placed in the market; 

55 The results of the public consultation are available at http://ec.europa.eu/clima/consultations/articles/0031_en 

43 

 
 
  
                                                            
   fleet operators, and in particular SMEs, are anticipated to benefit from the monitoring, 
since  they  will  be  able  to  take  more  informed  purchasing  decisions  concerning  the 
fuel efficiency of the vehicles; 
the administrative burden of monitoring and reporting HDV CO2 emissions and fuel 
consumption should be shared between national authorities and HDV manufacturers, 
according to the majority of respondents; 

   real but limited effects on reducing CO2 emissions are expected from the initiative, as 

well as limited reductions in non-CO2 emissions. 

2.  Stakeholders' participation in the public consultation  

The  Commission  received  121  formal  replies  from  a  broad  spectrum  of  stakeholders  as 
shown  in  Table  1,  three  of  which  were  received  by  email  and  not  through  the  EU  Voice 
website.  

Table 1. Classification of stakeholders responding to the questionnaire  

Stakeholder category 

Professional organisation 
Private enterprise 
Civil society organisation 
Other 
Public authority 
International organisation 
As an individual / private person 
Academic / Research institution 

32 
21 
20 
20 
12 
9 
6 
1 

Number of 
responses 

% of responses 

26% 
17% 
16.5% 
16.5% 
10% 
7% 
5% 
1% 

Grand Total 

121 

100% 

Notes:  Other  includes:  one  employers'  association,  2  trade  associations,  5  automotive/and 
body  builders  industries,  one  association  for  manufactures,  one  industry  association,  3 
business organisations, one sector association, one alliance of private companies operating 
in  the  logistics  industry,  one  public  company,  one  company,  2  non-governmental 
organisations and one non-profit organisation. 

A  number  of  coordinated  responses  were  received,  indicating  that  respondents  followed  a 
common answer, although with different degrees of variations. Since respondents were free 
to  adapt  the  answers  to  correspond  with  their  own  views  all  responses  have  been  analysed 
individually in the following sections. 

Responses  were  received  from  organisations  based  in,  or  respondents  residing  in,  19  EU 
Member  States  (Austria,  Belgium,  Czech  Republic,  Denmark,  Finland,  France,  Germany, 
Hungary,  Ireland,  Italy,  Latvia,  Netherlands,  Poland,  Portugal,  Romania,  Slovenia,  Spain, 
Sweden and the United Kingdom), while few responses were also received from other non-
EU locations such as Norway and the United States. The highest number of responses came 
from organisations residing in Belgium, followed by respondents from Germany, France and 
the United Kingdom, as shown in Table 2.  

44 

 
 
  
 
 
 
Table 2. Country of residence/establishment of stakeholders responding to the questionnaire 

Country of 
residence/establishment 

Number of 
responses 

Belgium 
Germany 
France 
United Kingdom 
Austria 
Netherlands 
Sweden 
Hungary 

29 
13 
10 
8 
7 
7 
7 
6 

3.  Responses to the individual questions 

Need of action 

All stakeholders, but one that gave no answer, agreed that monitoring vehicle efficiency (both 
in terms of fuel consumption and CO2 emissions) in the EU is important in order to gather the 
necessary  data  to  close  the  identified  knowledge  gap,  with  70%  of  the  respondents 
considering it as very important. 

The majority of respondents (56%) were of the opinion that if no action is taken at EU level, 
monitoring of HDV CO2 emissions would likely not take place. Only 25% of the respondents 
were  of  opposite  views,  with  18%  being  neutral.  44%  of  the  respondents  believed  that 
Member  States  would  separately  take  the  necessary  measures  to  monitor  and  report  HDV 
CO2  emissions  in  case  of  no  action  at  EU  level,  whereas  27%  saw  this  as  unlikely,  in 
particular most of the public authorities, and 26% were neutral. 

Objectives 

All  stakeholders,  but  one  that  gave  no  answer,  agreed  that  objective  1  'reducing  fuel 
consumption and HDV CO2 emissions' is important, with 86% of the respondents considering 
it as very important.  

Most of the stakeholders considered objective 2 'Improving market transparency in the HDV 
sector'  as  important,  however  with  a  lower  number  of  respondents  considering  it  as  very 
important (58%).  

Stakeholders'  opinions  are  more  mixed  regarding  objective  3  'Improving  road  transport 
competitiveness', with the vast majority recognising it as important, but 12% of stakeholders 
belonging to different categories indicated it as not important. 

Almost  all  stakeholders  agreed  that  objective  4  'Ensuring  competitiveness  of  the  European 
HDV manufacturing sector' is important, with 47% of the respondents considering it as very 
important. 

Options 

Option  1  is  deemed  the  most  appropriate  option  for  monitoring  and  reporting  HDV  CO2 
emissions and fuel consumption by 31% of the respondents, belonging mostly to professional 
organisations  (10  respondents,  among  which  organisations  dealing  with  transport  and 
logistics),  private  enterprises  (7  respondents,  including  component  manufacturers),  'other' 
(business/  industry/  trade  associations,  6  respondents),  civil  society  organisations  (6 
respondents) and public authorities (5 respondents).  

45 

 
 
 
Option  2  is  the  most  appropriate  option  according  to  12%  of  the  respondents,  mainly  from 
professional  organisations  (8  respondents,  mainly  representing  shippers),  2  private 
enterprises,  2  international  organisations,  2  'other'  (non-governmental  organisations)  and  1 
public authority. 

Option 3 is considered as the most appropriate by the highest number of respondents (42%): 
11  civil  society  organisations,  11  belonging  to  the  'other'  category  (automotive  industry, 
sector/trade/employers'  associations,  private  and  public  companies,  not 
for  profit 
organisation),  10  professional  organisations  (mainly  linked  to  the  automotive  industry),  8 
private  enterprises  (e.g.  from  the  energy  sector),  4  public  authorities,  4  individuals  and  3 
international organisations.  

Suggested other options and comments on proposed options 

Limiting the administrative burden and ensuring data reliability 

Several  stakeholders  from  private  enterprises,  automotive  industry  and  trade  association 
provided  similar  replies,  according  to  which  the  system  for  monitoring  should  be  based  on 
whole vehicle values provided by VECTO, should avoid double reporting and seek an easy 
handling  of  the  (digital)  data  submission,  minimizing  the  risk  of  errors.  Similarly,  one 
international organisation and a business organisation indicated as main requirements for the 
monitoring  and  reporting  system  that:  it  should  be  cost-effective  and  minimize  the 
administrative burden for manufacturers and Member States; and sufficient guarantees should 
be built into the system to ascertain the reliability of the data which is being communicated. 

Publication of data 

A number of civil society organisations provided similar replies advocating for option 3 and 
adding  that  VIN  numbers  should  be  made  public  in  the  EEA  database  to  allow  Member 
States to introduce other necessary measures, e.g. differentiated toll for trucks. A civil society 
organisation  expressed  a  similar  comment,  according  to  which  CO2  emissions  per  vehicles 
should be made public to make possible the introduction of complementary measures at local 
or national level. 

An  international  organisation  argued  that  regardless  of  the  reporting  option,  the  values 
published  by  the  Commission  should  be  more  detailed  than  average  values  per  vehicle 
type/manufacturer, since the limited potential of the monitoring and reporting system to curb 
CO2 emissions from HDVs depends on the granularity of the data made available to inform 
the  public  (i.e.  the  impact  on  CO2  emission  reduction  can  be  strengthened  by  making 
available the fuel consumption data from each vehicle sold).  

Real-world fuel consumption data 

One international organisation proposed a different monitoring and reporting system, where 
actual  fuel  consumption  information  should  be  measured,  recorded  and transmitted  through 
the electronic tachographs (on-board units of trucks) to data collection points from where the 
information is then conveyed to the European Commission for compilation into a report.  

A similar idea is expressed by a private enterprise, which is of the opinion that the operator 
should be responsible for monitoring and reporting emissions of the vehicle operated.  

Another  private  enterprise  provides  the  example  of  Ireland  where  HDV  operators  have 
incentives  to  report  actual  fuel  use  (and  therefore  emissions)  under  a  commercial 
performance scheme established to implement Article 7 of the Energy Efficiency Directive.  

Another international organisation stressed the need to supplement the emission data reported 
by manufacturers with “on-road/actual operations”. A public authority underlined the need to 

46 

 
 
implement  mechanisms  to  ensure  the  real-world  compliance  in  order  to  avoid  differences 
between VECTO and the real driving emissions.  

Benefits of VECTO 

Some private enterprises and professional organisations praised the VECTO simulation tool 
as  a  key  aid  in  the  decision-making  process  towards  a  carbon  efficient  fleet  strategy, 
especially  for  small  and  medium  sized  transport  companies.  In  order  to  fully  grasp  the 
benefits  of  it,  they  proposed  that  access  to  the  VECTO  simulation  should  be  opened  up  to 
transport buyers and operators and that it should be mandatory that they receive the VECTO 
results. A public authority also agreed that VECTO should be transparent and accessible for 
all stakeholders. 

Independence of the monitoring process 

A number of stakeholders from different categories underlined the need for independence and 
robustness of the monitoring process, with different proposals for who should be in charge of 
it: either national environment agencies or a central EU agency. 

Different approach compared to cars and vans 

Two professional organisations stressed the need of not copy pasting the monitoring system 
in  place  for  light  duty  vehicles,  as  heavy-duty  vehicles  have  different  characteristics  and 
require a system with a more complex (e.g. individual vehicle values and not  vehicle types 
monitored and reported). 

Coverage of pollutant and Well-to-Wheel emissions 

Three private enterprises are of the opinion that pollutant emissions such as NOx, SOx and 
particulate matters (PM) as well as noise should also be covered, and in addition two of them 
believe  that a  well-to  wheel  (WTW)  methodology  should  be  adopted  when  calculating  fuel 
consumption, to take into account of the whole production process. 

Likely economic impacts 

The majority of stakeholders fully agreed (33%) or tended to agree (39%) with the statement 
that  the  economic  impacts  of  monitoring  and  reporting  HDV  CO2  emissions  and  fuel 
consumption  are  expected  to  be  positive  even  though  limited,  with  21%  of  the  respondents 
having no strong view and only 5% of the respondents either fully disagreeing or tending to 
disagree. 

39% of stakeholders tended to agree with the statement that economic impacts of the various 
options  are  expected  to  be  broadly  similar,  36%  had  no  strong  view  and  18%  tended  to 
disagree  (7  professional  organisations,  6  'others'  including  automotive  industry,  business 
organisation,  trade  association  and  NGO,  3  international  organisations,  2  civil  society 
organisations, 2 private enterprises, 1 individual and 1 academic/research institute). 

Likely impacts on competitiveness and innovation  

Views were quite split concerning the statement that no sizeable competitiveness impacts are 
expected  in  the  Internal  market,  with  33%  of  stakeholders  tending  to  disagree  or  fully 
disagreeing (3%) versus 30% tending to agree or agreeing (2%), and 29% not having a strong 
view. 

The vast majority of the respondents agreed with the statement that a more transparent HDV 
market would contribute to an improved level playing field among HDV manufacturers and 
transport operators, with 45% in full agreement and 42% tending to agree. 

47 

 
 
Most of the stakeholders (52%) tended to agree with the statement that marginal impacts on 
competitiveness  are  expected:  comparability  between  manufacturers'  vehicles  energy 
efficiency may foster innovation, with 28% fully agreeing. 

The majority of the respondents were either in full agreement (31%) or tended to agree (42%) 
with  the  statement  that  fuel  savings  on  more  energy  efficient  vehicles  would  further  foster 
lower  transport  costs  in  the  EU,  leading  to  (marginal)  increased  competitiveness  of  the 
transport  sector,  while  17%  had  no  strong  view  and  8%  either  tended  to  disagree  or  fully 
disagreeing (3 professional organisations, 3 international organisations, 1 private enterprise, 2 
'others' from a business organisation and an NGO). 

Half of the stakeholders tended to agree (36%) or fully agreed (15%) with the statement that 
increased  competitiveness  of  the  transport  sector  would,  by  way  of  lower  prices  of 
intermediate  goods,  translate  into  increased  (marginal)  competitiveness  of  many  other 
segments of the EU economy, however a very high number of respondents had no strong view 
(31%)  and  14%  either  tended  to  disagree  (12%,  including  5  professional  organisations,  3 
international  organisations,  4  'other'  from  automotive  industry,  2  private  enterprises  and  1 
public authority) or fully disagreeing (2%). 

Likely impacts on third countries and EU international trade 

45%  of  the  stakeholders  had  no  strong  view  concerning  the  statement  that  there  is  no 
expected  material  direct  impact  on  third  countries,  the  rest  of  the  opinions  were  almost 
equally split between tending to agree (26%) and tending to disagree (22%). 

Stakeholders mostly tended to agree (52%) or fully agreed (24%) with the statement that if as 
assumed  above  improvements  in  innovation  uptakes  and  the  industry's  competitiveness  are 
possible, this will (marginally) benefit the EU HDV industry's international competitiveness, 
while 21% had no strong views. 

Stakeholders' opinions on the statement that pass-through of  lower  transport  costs  to  many 
sectors  of  the  EU  economy  would  (marginally)  benefit  EU  exports  and  international 
competitiveness were mainly tending to agree (37%) or fully agreeing (15%), however a high 
number of stakeholders had no strong opinion (36%) and 8% either tended to disagree (6%, 
mainly from professional organisations) or fully disagreed (2%). 

Likely impacts on SMEs 

Respondents were rather split with regards to the statement that there is no expected impact 
on SMEs from the manufacturing sector since HDV manufacturers on which the monitoring 
burden  shall  fall,  are  all  very  large  international  companies,  45%  either  tended  to  agree 
(28%)  or  fully  agreed  (17%)  while  38%  either  tended  to  disagree  (19%)  or  fully  disagreed 
(19%), and 16% had no strong view. 

The vast majority of the stakeholders fully agreed (57%) or tended to agree (21%) with the 
following statements: Transport companies, most of which are small SMEs, are expected to 
benefit  from  the  monitoring  of  fuel  consumption  and  CO2  emissions  as  this  would  provide 
more  transparency  on  the  most  energy  efficient  HDVs.  SMEs  could  take  this  into 
consideration  in  their  purchase  decisions,  thereby  realising  fuel  savings.  16%  of  the 
respondents had no strong view. 

Likely social impacts 

A high number of respondents (39%) had no strong view on the statement that  no material 
social impact is expected from either option, while half them either tended to agree (33%) or 
fully agreed (17%) with it and 9% either tending to disagree (6%) or fully disagreeing (3%). 

48 

 
 
42% of the stakeholders had no strong view with regards to the statement that social impacts 
of options would only slightly differ, while 35% tended to agree and 17% fully agreed with it. 

Likely administrative burden 

The  majority  of  the  respondents  either  tended  to  disagree  (39%)  or  fully  disagreed  (15%) 
with  the  statement  that  manufacturers  of  heavy-duty  vehicles  should  bear  the  essential 
administrative burden of monitoring HDV fuel consumption and CO2 emissions. Only 20% of 
the  respondents  either  fully  agreed  (12%)  or  tended  to  agree  (8%)  and  18%  had  no  strong 
view. 

Most of stakeholders tended to disagree (35%) or fully disagreed (3%) with the statement that 
public  authorities  should  bear  the  essential  administrative  burden  of  monitoring  HDV  fuel 
consumption and CO2 emissions, whereas 29% had no strong view and 31% of stakeholders, 
mainly from professional organisations or public authorities, either tended to agree (18%) or 
fully agreed (13%). 

The  majority  of  stakeholders  either  fully  agreed  (28%)  or  tended  to  agree  (26%)  with  the 
statement that manufacturers of heavy-duty vehicles and public authorities should share the 
administrative  burden  of  monitoring  HDV  fuel  consumption  and  CO2  emissions,  while  a 
rather high number of respondents had no strong view (32%) and 12%, mainly from private 
enterprises and professional organisations, either tended to disagree (10%) or fully disagreed 
(2%). 

Likely environmental impacts (on CO2 emissions) 

A large number of respondents either fully agreed (26%) or tended to agree (48%) with the 
statement that real but limited effect on reducing HDV fuel consumption and CO2 emission, 
whereas 15% of stakeholders, mainly from private enterprises and professional organisations, 
either tended to disagree (12%) or fully disagreed (3%). 

The vast majority of stakeholders either fully agreed (29%) or tended to agree (50%) with the 
establishment  of  a  reliable  and  transparent  track  record  of  whole  HDV  CO2  emissions, 
independent  from  each  manufacturer's  measurement,  while  8%  of  stakeholders,  mainly 
professional  organisations  and  private  enterprises,  either  tended  to  disagree  or  fully 
disagreed. 

88% of stakeholders tended to agree or fully agreed that monitoring and reporting HDV CO2 
emissions  and  fuel  consumption  would  increase  awareness  among  fleet  operators  on  the 
most effective vehicles to operate and influence decision making in purchasing more effective 
HDVs. 

Most of the respondents (43%) had no strong view concerning the statement that there would 
be no differentiated environmental impacts of the various options on CO2 emissions, however 
38% tended to agree or fully agreed and 16% tended to disagree or fully disagreed. 

The  vast  majority  of  stakeholders  (87%)  fully  disagreed  or  tended  to  disagree  with  the 
statement that HDV CO2 monitoring should be focussed only on the main petrol and diesel 
fuels. Correspondingly 83% of stakeholders were fully in agreement or tended to agree with 
the statement that the scope of the HDV CO2 monitoring should be broadened to incorporate 
alternative fuels such as biofuels, CNG or LPG, while 8% of stakeholders, mainly from civil 
society organisations, tended to disagree or fully disagreed. 

49%  of  stakeholders  fully  agreed  or  tended  to  agree  with  the  statement  that  HDV  CO2 
monitoring should focus on tailpipe (tank-to-wheel) emissions, but on the other hand 36% of 
respondents fully disagreed or tended to disagree. 

49 

 
 
Half of the respondents (51%) fully agreed or tended to agree with the statement that  HDV 
CO2 monitoring  should incorporate a comprehensive approach on well-to-wheel  emissions, 
to  better  reflect  the  lower  carbon  content  of  some  alternative  fuels,  while  24%  of 
stakeholders  had  no  strong  view  and  24%,  mainly  from  civil  society,  professional 
organisations and public authorities, fully disagreed (15%) or tended to disagree (9%). 

Likely environmental impacts (on non-CO2 emissions) 

More than half of the respondents (54%) tended to agree or fully agreed with the statement 
that  increased  fuel  efficiency  of  vehicles  would  lead  to  limited  reduction  of  other  non-CO2 
emissions, 28% had no strong view and 17% of stakeholders, mainly belonging to the 'other' 
category  and  in  particular  from  the  automotive  industry  and  private  enterprises,  tended  to 
disagree or fully disagreed. 

Almost half of the stakeholders (47%) had no strong view with regards to the statement that 
options  will  not  have  differentiated  environmental  impacts  on  non-CO2  emissions,  37% 
tended  to  disagree  or  fully  disagreed,  especially  respondents  from  civil  society  and 
professional organisations, and only 14% tended to agree or fully agreed. 

Other comments 

According to a number of different stakeholders (trade and employers' associations, a private 
enterprise, an international organisation, and a not-for-profit organisation), besides reporting 
to  customers  who  purchase  the  vehicles  and  providing  information  to  authorities,  the  most 
important  customer  benefit  of  establishing  common  procedures  (i.e.  standardised 
methodologies for generating inputs to a common simulation tool) is that, for the first time, 
potential  customers  can  compare 
the  expected  vehicle  performances  of  different 
specifications and from different manufacturers. This is the main “market driving” element of 
the  upcoming  regulation  which  has  not  in  the  view  of  these  stakeholders  been  properly 
addressed in the inception impact assessment. 

A  number  of  civil  society  organisations  consider  that  the  monitoring  and  reporting  system 
needs to be a transparent tool to empower truck-makers when they buy a truck but also and to 
provide the European Commission with more accurate data for future legislative initiatives. 
All the input parameters for VECTO should be monitored and published (especially the tyre 
rolling resistance and the aerodynamic drag). According to these stakeholders, OEMs should 
be obliged to provide interested buyers with the VECTO results so that transport companies 
can  easily  compare  different  vehicles  of  different  brands.  Moreover,  the  truck  fuel 
consumption  information  monitored  by  fleet  management  systems  should  also  be  reported 
every year in order to provide the EC with an extensive real world database. Such a database 
would enable to discern real world trends, including whether improvements in type approval 
CO2  performance  also  translates  in  lower  vehicle  fuel  consumption.  According  to  these 
stakeholders,  the  Commission  should  also  include  trailers  as  soon  as  possible  in  the  MRV 
system and develop a procedure how trailer performance can be tested. 

One  international  organisation  and  a  private  enterprise  stressed  the  key  importance  of 
monitoring and reporting data for different payloads. 

Some  stakeholders  (an  international  organisation,  two  professional  organisations,  a  private 
enterprise  and  a  business  organisation)  are  of  the  opinion  that  fuel  consumption  and  CO2 
emission  reductions  should  lead  not  only  to  environmental  benefits  but  also  provide  road 
freight and passenger transport operators with benefits in terms of reductions of operational 
costs and guarantees for a return on their investments in the latest and cleanest technologies, 
including vehicles, over an adequate period of time. They believe monitoring should in first 
instance  be  focused  on  tank-to-wheel  emissions;  however,  they  see  the  need  for  a  certain 

50 

 
 
degree of well-to-wheel information, as it would allow commercial road transport operators 
to  make  better-informed  decisions  on  switching  to  alternative  fuels.  They  also  stress  that 
commercial  road  transport  operators  should  be  further  encouraged  to  reduce  fuel 
consumption and increase efficiency of their existing fleets and operations, and that they will 
be  less  inclined  to  do  so  if  their  efforts  are  offset  by  additional  taxes,  charges  and  duties, 
higher  vehicle  and  technology  prices  and  reduced  transport  rates.  They  finally  think  that 
efforts should not only be limited to new vehicles.  

Two private enterprises underlined the need to ensure that all alternative fuels are measured 
using the same methodology, and a number of stakeholders highlighted the role of alternative 
fuels in reducing emissions. 

51 

 
 
 
 
 
ANNEX 3 - WHO IS AFFECTED BY THE INITIATIVE AND HOW 

Who is affected 

How are they affected? 

Member States 
public 
administrations 

Manufacturers of 
HDVs 

Under  option  1,  national  public  administrations  (in  most  countries  these 
would be Registration Authorities) would have to monitor and report HDV 
CO2  emission  data  to  the  EEA.  This  may  imply  an  additional  burden  in 
terms  of  IT  data  management  systems  and  staff  for  the  relevant  national 
administrations.  Option  3  would  significantly  reduce  this  burden  on 
national  administrations  as  they  would  only  need  to  report  registered 
vehicle  identification  numbers  ("VIN")  to  the  EEA.  Option  2  would  not 
trigger any additional burden on national administrations.  
Member States would have access to a public database, which under option 
1 and 3 would be Member State specific, with accurate information on CO2 
emissions  from  heavy-duty  vehicles  that  could  be  used  for  national 
emission reduction measures. 

No  simplification  of  administrative  burden  can  be  expected  as  HDV  CO2 
emissions  are  not  currently  monitored  or  reported.  An  administrative 
burden  is  possible  (on  top  of  the  administrative  burden  attached  to  the 
certification  of  HDV  CO2  emissions  under  type  approval  legislation)  for 
vehicle  manufacturers  in  the  second  option  on  "self-monitoring"  under 
which manufacturers would be expected to report to the EEA, and likewise, 
in  the  third  option  under  which  the  EEA  would  retrieve  monitoring  data 
from  manufacturers,  based  on  Vehicle  Identification  Numbers  (VINs)  of 
newly registered vehicles provided by national registration authorities. 

Transport 
Operators and 
logistics 
companies – many 
of which SMEs 

Under  all  three  options,  freight  transport  operators  as  well  as  logistics 
companies  (i.e.  the  buyers  and  users  of  HDVs)  would,  for  the  first  time, 
have the information and the possibility to compare the performance of the 
vehicles, and be able to choose the most efficient ones. This should allow 
them  to  realise  potential  fuel  savings,  which  could  be  significant 
considering  that  fuel  represents  a  large  share  of  their  vehicle  operating 
costs. 

Consumers 

EEA/EC 

Under  all  three  options,  transparency,  and  the  subsequent  uptake  of  more 
fuel efficient HDVs to transport goods and passengers, would be likely to 
reduce  costs  for  consumers  of  those  goods  and  services,  since  the 
intermediate  transport  cost  may  be  reduced  thanks  to  the  improved  fuel 
efficiency. 

Under all three options the EEA and the Commission would need to devote 
additional  resources  to  HDV  CO2  monitoring  and  reporting  (IT  systems, 
staff), on top of resources already devoted to monitoring and reporting cars 
and vans CO2 emissions.  

The  Commission  would  gather  for  the  first  time  accurate  information  on 
CO2 emissions of heavy-duty vehicles and would be able to implement and 
enforce appropriate emission reduction measures. 

52 

 
 
 
 
 
ANNEX 4 - DEVELOPMENT OF A NEW SIMULATION TOOL, VECTO56, FOR THE DETERMINATION 
OF CO2 EMISSIONS FROM HEAVY-DUTY VEHICLES 

1.  Current situation 

Unlike  for  cars  and  vans,  where  pursuant  to  the  existing  type-approval  regulation  the  fuel 
consumption  of  each  new  type  approved  vehicle  is  tested  on  a  chassis  dynamometer,  there  is  no 
official  and  comparable  determination  for  the  fuel  consumption  or  its  equivalent  for  the  CO2 
emissions  for  a  whole  new  Heavy-Duty  Vehicle  (HDV).  For  a  consistent  policy  on  reducing  CO2 
emissions and measuring the future achievement of fuel efficiency a robust, reliable and cost effective 
determination of fuel consumption has to be established. 

Several  approaches  for  the  determination  of  CO2  emissions  from  the  whole  vehicle  have  been 
investigated: 

  Chassis dynamometer 
  Portable Emission Measurement Systems (PEMS) and 
  Component testing and computer simulation 

Due to multiple combinations of axle type, number of driven axles, gear boxes, engines and cabins, 
the number of variations within one HDV model range can exceed 1000. Therefore measuring every 
possible  configuration  on  a  chassis  dynamometer  or  with  PEMS  would  be  a  very  burdensome 
approach. 

2.  Development of a simulation tool of whole HDV CO2 emissions 

The  Commission  has  since  2009  engaged  with  main  industry  stakeholders  in  the  development  of  a 
simulation tool for whole vehicles CO2 emissions and fuel consumption that should be applicable to 
all main categories of HDVs. 

In the project “Reduction and testing of Greenhouse Gas Emissions from Heavy duty vehicles” - (call 
for  tender  ENV.C.3/SER/2009/0038)  a  simulation  based  test  procedure  where  the  relevant 
components  of  the  HDV  were  tested  and  based  on  this  data  a  simulation  tool  calculating  the  fuel 
consumption and the CO2 emissions in vehicle class specific test cycles was chosen as the method that 
delivers robust results of  CO2 figures for HDVs  and appears  manageable for the  manufacturers and 
public administrations that have to deal with the test procedure.  

The  relevant  data  needs  for  the  simulation  of  HDV  CO2  data  that  have  been  identified  include  the 
engine  fuel  efficiency  map,  vehicle  weight,  tires  rolling  resistance  coefficients  (RRC),  aerodynamic 
drag coefficient multiplied by the frontal area (A) of the vehicle (CdxA), moments of inertia from the 
vehicle including standardised bodies or trailers, the specifications of the gear boxes and efficiency of 
the auxiliaries. 

Such a simulation based approach should allow cost efficient testing of multiple HDV variations by 
compiling  the  measured  component  data  in  the  simulator.  This  approach  also  makes  it  possible  to 
easily assess the CO2 emissions impact of improved trailer and body structure design. The proposed 
test procedure has been applied  experimentally on three HDV  categories so far and appears  to give 
reliable and accurate results.  

The simulation-based method consists of:  

  On-road measurement of driving resistances 

  Determination of drivetrain losses  

  Determination of power demand of engine auxiliaries and other consumers 

  Measurement of the engine fuel consumption map as extension to the engine's type approval 

tests  

56 VECTO = Vehicle Energy Consumption calculation TOol 

53 

 
 
                                                            
  Simulation of the fuel consumption and the resulting CO2-emisions from the vehicle using the 

aforementioned input data for predefined representative driving cycles. 

The single steps described in brief: 

The driving resistances of the vehicle will be measured during constant speed or coast down rides on a 
test  track.  Standardized  bodies  and  trailers  will  be  used  to  obtain  reliable  air  resistance  values.  For 
reproducible results, corrections for influences of road gradient, wind speed, ambient temperature and 
air pressure as well as for velocity unsteadiness, have to be applied to the measured driving resistance 
values.  

For  the  body  and  trailer  manufacturers  an  option  for  a  less  extensive  procedure  can  be  applied. 
Improved bodies or trailers (aerodynamics, curb weigh) can be tested in comparison to the standard 
components  via  constant  speed  tests  or  via  coast  down  tests  at  high  velocities.  The  relative  change 
against the standard body or trailer can then be introduced into the simulation tool to calculate the fuel 
consumption and the CO2 emissions of the alternative vehicle and body-configuration. 

Drivetrain friction losses and the power demand of engine auxiliaries like engine fan, air compressor 
or  heating  and  air  conditioning,  will  be  defined  as  default  functions.  If  OEMs  use  more  efficient 
components, the default values can be replaced by component specific efficiency maps. 

Since  several  technical  options  to  improve  the  fuel  efficiency  of  HDV  have  different  reduction 
potentials at varying driving conditions, the definition of representative driving cycles is important for 
a  realistic  ranking  of  the  specific  fuel  consumption.  Driving  cycles  (or  mission  profiles)  for  the 
different  categories  and  usage  of  HDVs  are  newly  developed  to  give  more  realistic  results  on  fuel 
consumption. 

It is desirable for the methodology to address all characteristics that are relevant to the efficiency of 
the entire vehicle. Realistic values for the fuel efficiency of various HDV in different mission profiles 
will  improve  customer  information  and  incentivise  manufacturers  to  develop  and  apply  fuel  saving 
technologies. In future a standardised test procedure could support other measures in the HDV sector 
including CO2 emissions monitoring, labelling or programmes for HDV customers to calculate HDV 
fuel efficiency. 

The main targets for the test procedure are: 

1.  Repeatable (within same laboratory) and reproducible (between different laboratories) 

2.  Incentive to apply efficient technologies and to optimise the entire vehicle set-up 

3.  High sensitivity for fuel saving measures 

4.  Reasonable costs and efforts to run and examine the procedure  

5.  Simple and robust 

Schematic overview of simulation model and computational programme 

Figure  1  below  gives  an  overview  of  the  test  procedure.  Rolling  resistance,  air  resistance,  power  to 
accelerate translational and rotatory moved masses, power resulting from road gradients, losses in the 
transmission system and power demand from auxiliaries are considered in the simulation.  

54 

 
 
 
 
Figure 1.  

Schematic picture of the test procedure 

All the measured data of the components / subsystems of a HDV will then be used as input data in a 
HDV energy/CO2 simulation. 

Figure 2. Structure of the simulation tool 

The structure of the simulation tool is shown below: 

The simulation tool will calculate the energy consumption of the whole HDV and give as a result the 
fuel consumption or CO2 emissions in g/km, g/t*km, g/m3*km or g/passenger*km (for buses). 

55 

 
 
 
 
 
3.  On-going and future development steps of the VECTO tool 

The  development  of  the  VECTO  tool  entered  in  October  2012  in  a  new  phase  with  tests  of  the 
methodology  with  an  active  participation  of  the  manufacturers  to  prove  the  reliability  of  the  test 
procedure and simulation.  

Until June 2017:  

This phase (on-going), based on currently contracted assignments, is expected to last until June 2017, 
and includes: 

the current development and test of the VECTO tool which covers three categories of HDV 
vehicles, i.e. long haul, regional/city delivery but also buses and coaches; 

   and the preparation of the required documentation of certification/registration process (to be 

finalised in May 2017). 

The model has been validated for the above mentioned trucks that represent more than 50% of new 
HDV registrations and further testing is planned for buses and coaches by the end of spring 2017. 

Mid-2017 until end 2018 (tentatively): 

The VECTO tool thereafter will have to be extended to other categories of HDVs (e.g. city and inter-
city buses, municipal utility trucks, service and urban delivery trucks, construction trucks). Moreover, 
the  IT  platform  of  VECTO  will  have  to  be  created.  The  next  and  last  phase  of  development  of  the 
VECTO tool is thus expected to include: 

the further development and finalisation of VECTO to cover other categories of HDVs; 
the  IT  development  of  a  user-friendly  software  platform  to  support  the  deployment  of  the 
VECTO tool; 

   and the adaptation of the required documentation of the certification/registration process for 

all relevant categories of vehicles. 

4.  Cost of developing the Vehicle Energy Consumption calculation TOol  

The development of the Vehicle Energy Consumption calculation TOol (VECTO) required 4 contracts 
and did altogether cost around 2.4 M€. Further costs are to be expected to maintain the tool and provide 
end-user support (a new contract is signed for this purpose), as well as to upgrade it to future needs. 

"Lot 2" contract 2009-2011: initial assessment 

"Lot 3" contract 2012-2014: core development of tool 

"Lot 4 contract" 2014-2017 (ongoing): refactoring and completing the tool 

Contract on bus auxiliaries 2015-2017 modelling into VECTO 

Budget (€) 

499.000 

659.523 

699.914 

248.508 

"VECTO helpdesk support, maintenance and further development" 2016-2019 

299.764 

Total 

2.406.709 

This  assessment  is  based  on  contractual  development  work  that  has  been  outsourced  to  external 
contractors. However, it does not include internal Commission costs, related to staff working on this 
programme,  nor  costs  incurred  by  manufacturers  –deemed  much  higher  than  this  –  to  provide  the 
vehicles  needed,  run  the  programme  and  test  VECTO  on  their  various  facilities:  such  costs  are 
difficult to be assessed. 

56 

 
 
  
  
 
  
 
 
ANNEX 5 - DRAFT CERTIFICATION METHODOLOGY FOR THE DETERMINATION OF THE CO2 
EMISSIONS FROM HEAVY-DUTY VEHICLES 

1.  Background 

DG  GROW,  as  responsible  for  the  type-approval  legislation  of  vehicles,  has  developed  the 
certification procedure whose outcome will be a set of vehicle specific fuel consumption and 
CO2 emission values calculated on the basis of the VECTO tool (see Annex 4). In order to 
support  the  Commission  services  in  the  development  of  the  certification  procedures  for 
heavy-duty vehicles, an Expert Group (‘HDV CO2 Editing board’) with the participation of 
the Member States, industry and NGOs was established. 

Taking  into  consideration  that  the  type-approval  framework  has  proved  its  robustness  and 
applicability in the context of the certification of vehicles, the new piece of legislation was 
developed  under  the  framework  Directive  2007/46/EC.  Moreover,  the  simulation  approach 
was already mentioned in the framework Directive giving a legal base for the application of 
the ‘VECTO’ software for the purpose of the certification procedure.  

There is, however, a main difference from the usual type-approval approach due to the large 
variety of vehicle types in heavy-duty vehicles, and vehicle manufacturers will be obliged to 
provide  CO2  values  for  each  vehicle  put  on  the  European  market.  Certification  under  the 
type-approval framework will also imply that the component and vehicle manufacturers will 
need to fulfil the obligations resulting from the conformity of production (CoP) requirements. 

2.  Structure of the new Regulation 

The new Regulation consists of the following parts: 

1)  certification of the input data (components) 
2)  CO2 calculation by means of VECTO  
3)  conformity of production provisions for the components and whole vehicles and on-

road verification 

4)  Output data including a CO2 information file for the consumer 

2.1. Certification of the input data (components) 

In order to perform the calculation of the CO2 emissions of a complete vehicle by means of 
the VECTO software, it is necessary to obtain reliable input data of the performance of the 
CO2 related components. During the work on the simulation model, it has been decided that 
the following components have a major impact on the CO2 emissions: 

-  engine 
- 
tyres 
- 
transmission 
-  axles 
-  air-drag (NB: air-drag is a VECTO input and, as such, assimilated to a "component") 
-  auxiliaries 

2.2. CO2 calculation by means of VECTO  

For  the  purpose  of  VECTO,  the  heavy-duty  vehicle  market  has  been  divided  into  18 
categories depending on the number of axles, structure and weight. For each vehicle category 
a specific standard body/trailer has been defined, as well as dedicated test cycles, over which 
a vehicle will be simulated, have been assigned.  

57 

 
 
 
 
Figure 1. Vehicle groups 

Identification of vehicle class 

Allocation of mission profile and vehicle configuration 

n
o
i
t
a
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u
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4x2 

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Rigid 

Rigid (or 
tractor)* 

Rigid (or 
tractor)* 

Rigid (or 
tractor)* 

Rigid 

Tractor 

Rigid 

Rigid 

Tractor 

Rigid 

Tractor 

Rigid 

Tractor 

Rigid 

Tractor 

8x2 

Rigid 

8x4 

8x6 
8x8 

Rigid 

Rigid 

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>3.5 – <7.5 

(0) 

7.5 - 10 

>10 - 12 

>12 - 16 

>16 

7.5 - 16 

>16 

>16 

all weights 

all weights 

all weights 

all weights 

all weights 

1 

2 

3 

4 

5 

(6) 

(7) 

(8) 

9 

10 

11 

12 

all weights 

(13) 

all weights 

(14) 

all weights 

(15) 

all weights 

16 

all weights 

(17) 

)
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T+ST 

T+ST+T2 

R+T2  R+D+ST 

R 

R+D+ST 

T+ST  T+ST+T2 

T+ST 

T+ST+T2 

R+T2  R+D+ST 

R 

R+D+ST 

T+ST  T+ST+T2 

T+ST 

T+ST+T2 

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B1 

B2 

B3 

B4 

B5 

B5 

(generic 
weight+CdxA) 

* in these vehicle groups tractors are treated as rigids but with specific curb weight of tractor 
R 
T1, T2 
ST 
D 

Rigid & standard body 
Standard trailers 
Standard semitrailer 
Standard dolly 

= 
= 
= 
= 

On  the  basis  of  the  certification  procedure  described  in  point  2.1,  the  input  values  for  the 
simulation will be defined. The calculation will be performed by VECTO for each test cycle 
assigned to the category to which a specific vehicle belongs. 

The CO2 impact of some vehicle categories was found to be rather small (below 1% of total 
HDV CO2 emissions), in particular for categories 6, 7, 8, 13, 14, 15 and 17. It was therefore 
decided not to include them for the purpose of certification. 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 2. Estimated share of total CO2 emissions from different HDV categories57 

Source: TU Graz et al, 2012 

2.3. Conformity of production provisions for the components and whole vehicles and 

On-road Verification 

In  order  to  ensure  that  the  fuel  and  CO2  values  declared  by  the  vehicle  manufacturer 
accurately reflect the actual values, CoP provisions were introduced on different levels of the 
certification procedure. They are based on the already existing provisions in the framework 
Directive supplemented by specific points designed for the purpose of this Regulation. 

In  the  first  place,  all  the  certified  components  fall  under  the  CoP  requirements.  Before 
granting  a  type-approval,  component  manufacturers  will  be  audited  by  the  Type-approval 
Authority to verify the processes related to the production of parts and management of data. 
After  receiving  a  type-approval,  manufacturers  will  be  subject  to  annual  audits  and  will  be 
requested to perform a specific number of tests. 

As the vehicle manufacturers are also the producers of components (ex. they will certify air 
drag  value),  the  procedures  described  above  will  also  apply  to  them.  In  addition,  vehicle 
manufacturers  will  be 
to  data 
management/handling and they will perform, together with the Type-approval Authorities, an 
on-road verification test. 

to  more  detailed  provisions 

subject 

related 

57TU Graz, TNO, TUV Nord, VVT, AVL, LAT and Heinz Steven (2012), Reduction and Testing of Greenhouse Gas Emissions from Heavy 
Duty  Vehicles  -  LOT  2:  Development  and  testing  of  a  certification  procedure  for  CO2  emissions  and  fuel  consumption  of  HDV, 
https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/heavy/docs/hdv_2011_01_09_en.pdf 

59 

 
 
 
                                                            
The purpose of the on-road verification test will be an identification of possible discrepancies 
between the simulated and actual CO2 values of a complete vehicle. The testing procedure is 
currently under development. The tests will be performed under the supervision of the Type-
approval  Authorities.  In  case  a  verification  test  identifies  significant  discrepancies  with  the 
initial VECTO calculated value, the vehicle  manufacturer will be asked to  identify the root 
cause of the problem –possibly in most cases wrong input values into VECTO– and introduce 
remedial measures. 

2.4. CO2 certificate for the consumer 

As  one  of  the  objectives  of  the  CO2  certification  is  an  increase  of  the  transparency  of  the 
heavy-duty market, the results of the simulations will be available to the customers. Due to 
the  fact  that  a  substantial  number  of  heavy-duty  vehicles  are  certified  under  the  individual 
type-approval  schemes,  inclusion  of  the  data  in  the  certificate  of  conformity  of  vehicles 
would  only  have  a  very  limited  value.  Instead,  it  was  decided  that  an  additional  certificate 
with  all  the  fuel  and  CO2  related  values  should  be  provided  to  the  purchasers  with  each 
vehicle registered. 

3.  Cost of certification 

The  above  assessment  of  costs  related  to  certification  is  drawn  from  a  2015  report  to  the 
Commission by a team of consultants led by TNO (including ICCT and TNM).58 

TNO  assessed  several  options  for  certification.  The  table  below  is  based  on  the  option 
eventually  retained  in  the  certification  regulation  as  the  preferred  one  by  not  only  the 
Commission,  but  also  vehicle  manufacturers,  technical  services  and  Member  States  Type 
Approval  authorities,  based  on  simulation  (using  the  VECTO  tool)  and  component  testing 
(option "D1" in the TNO report59). 

Table 1. Transition cost estimates 

Cost type 

Large manufacturers 

Medium manufacturers 

Total cost 

Cost per vehicle 

Total cost 

Cost per vehicle 

Direct variable 
costs 
Fixed costs 
Total / 
Manufacturer 

€ 2,5 M 

€ 1,1 M 

€ 3.6 M 

€ 65 

€ 28 

€ 93 

€ 1.4 M 

€ 0.4 M 

€ 1.8 M 

€ 81 

€ 21 

€ 102 

Source: TNO, TNM and ICCT (2015) 

58  TNO  et  al.  (2015),  Final  report:  Cost-benefit  analysis  of  options  for  certification,  validation,  monitoring  and  reporting  of  heavy-duty 

vehicle fuel consumption and CO2 emissions,  

https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/heavy/docs/tno_2015_final_report_en.pdf, pp 75-76 
59 See table 20 and 21 p.76. 

60 

 
 
 
 
 
                                                            
Table 2. Annual cost estimates 

Cost type 

Large manufacturers 

Medium manufacturers 

Total cost 

Cost per vehicle 

Total cost 

Cost per vehicle 

€ 0.2 M 

€ 1.1 M 

€ 1.3 M 

€ 5 

€ 28 

€ 34 

€ 0.1 M 

€ 0.4 M 

€ 0.5 M 

€ 7 

€ 21 

€ 28 

Source: TNO, TNM and ICCT (2015) 

Direct variable 
costs 
Fixed costs 
Total / 
Manufacturer 

Definitions 

Costs 

The costs were divided into direct (mostly related to physical testing required for compliance, 
especially relevant for the “D” options) and indirect costs (administrative and other types of 
overhead  costs.  As  for  the  time  horizon  of  measuring  costs,  both  the  transition  costs  and 
annual  costs  were  estimated:  the  transition  costs  here  refer  to  expenses  associated  with  the 
certification  of  CO2  emissions  for  all  vehicle  variants  currently  being  marketed  (i.e.,  it  is 
assumed that,  once  the regulation is in  place,  a substantial, one-off economic effort  will be 
made  ensure  that  the  current  product  portfolio  is  in  compliance).  Annual  costs  refer  to 
recurrent costs associated with certifying new vehicles and vehicle components as they enter 
the market, assuming that the rest of the product portfolio is already certified (in other words, 
these  are  the  “business  as  usual”  costs  to  be  expected  once  the  regulatory  scheme  is  fully 
phased in).  

Classification of large and medium manufacturers 

In  addition  to  the  time  dimension,  the  costs  were  also  estimated  for  two  representative 
categories of vehicle OEMs. To that avail, the European market for HDVs was divided into 
two tiers, namely three brands with more than 30,000 newly registered vehicles each in 2012 
(“large manufacturers”), and four vehicle brands with 10,000 to 30,000 registered vehicles in 
2012 (“medium manufacturers”). These two tiers cover around 95 percent of all registrations 
in  2012.  While  results  are  presented  for  large  and  medium  vehicle  manufacturers,  costs 
throughout the entire industrial value chain were considered. 

61 

 
 
 
 
 
 
ANNEX 6 - VEHICLE IDENTIFICATION NUMBER (VIN) 

'Vehicle identification number’ (VIN) means the alphanumeric code assigned to a vehicle by the manufacturer 
in order to ensure proper identification of every vehicle; The first three characters uniquely identify the 
manufacturer of the vehicle using the World Manufacturer Identifier or WMI code. Some manufacturers use 
the third character as a code for a vehicle category (e.g., bus or truck), a division within a manufacturer, or both. 

Part B of Regulation (EU)19/2011 (OJ, L 8/6 12/01/2011) states that:  

1. General provisions  

1.1. A VIN shall be marked on each vehicle.  

1.2. The VIN shall be unique and unequivocally attributed to a particular vehicle.  

1.3. The VIN shall be marked on the chassis or the vehicle when the vehicle leaves the production line.  

1.4. The manufacturer shall ensure the traceability of the vehicle by means of the VIN over a period of 30 years.  

1.5. The existence of measures taken by the manufacturer to ensure the traceability of the vehicle referred to in 
point 1.4 needs not be checked at the time of the type-approval.  

2. Composition of the VIN  

2.1. The VIN shall consist of three sections:  

(a) the world manufacturer identifier (WMI);  

(b) the vehicle descriptor section (VDS);  

(c) the vehicle indicator section (VIS).  

2.2. The WMI shall consist of a code assigned to the vehicle manufacturer to enable him to be identified.  

2.2.1. The code shall comprise three alphanumeric characters, capital roman letters or Arabic numerals, which 
shall be assigned by the competent authority in the country where the manufacturer has his principal place of 
business.  

2.2.2. The competent authority shall act in agreement with the international organisation referred to in Standard 
ISO 3780: 2009 on ‘Road vehicles — World manufacturer identifier (WMI) code’.  

2.2.3. Where the manufacturer’s global production is less than 500 vehicles per annum, the third character shall 
always be ‘9’. In order to identify such manufacturers, the competent authority referred to in point 2.2.1 shall 
assign the third, the fourth and the fifth character of the VIS.  

2.3. The VDS shall consist of six alphanumeric characters, capital roman letters or Arabic numerals, which shall 
serve to indicate the general characteristics of the vehicle. Where the manufacturer does not use one or more of 
the six characters, the unused spaces shall be filled in with alphanumeric characters at the manufacturer’s 
discretion in order that the total number of characters required shall be 6.  

2.4. The VIS shall consist of eight alphanumeric characters, capital Roman letters or Arabic numerals, of which 
the last four shall consist of digits only.  

It shall provide, in conjunction with the WMI and the VDS, clear identification of a particular vehicle. Any 
unused space shall be filled in with the digit ‘0’ in order that the total number of characters required shall be 8.  

2.5. The height of the characters of the VIN stamped on the chassis shall be no less than 7 mm.  

2.6. There shall be no space between the characters.  

2.7. The use of the letters ‘I’, ‘O’ or ‘Q’ shall not be permitted.  

2.8. The beginning and the end of the VIN shall be limited by one symbol at the choice of the manufacturer 
neither symbol should be a Roman capital letter nor an Arabic numeral.  

2.8.1. This provision may be waived when the VIN is marked on a single line.  

2.8.2. When the VIN is marked on two lines, this provision shall apply to each line. 

62 

 
 
 
 
ANNEX 7 - HDV SECTOR STATISTICS 

1.  Heavy-duty vehicles categories 

Heavy-duty vehicles include lorries, buses and coaches of various categories: 

N2 vehicles 

Lorries used for the carriage of goods and having a maximum mass exceeding 3.5 tonnes 
but not exceeding 12 tonnes 

N3 vehicles 

Lorries used for the carriage of goods and having a maximum mass exceeding 12 tonnes 

M2 vehicles 

M3 vehicles 

Small busses, i.e. passenger vehicles used for the carriage of passengers, comprising 
more than eight seats in addition to the driver's seat, and having a maximum mass not 
exceeding 5 tonnes 

Large busses and coaches, i.e. passenger vehicles used for the carriage of passengers, 
comprising more than eight seats in addition to the driver's seat, and having a maximum 
mass exceeding 5 tonnes 

2.  HDV Registrations 

The number of new HDVs registered in the EU per year is on the rise although still below pre-crisis 
numbers, with around 400,000 vehicles registered in 2016.  

According to the latest figures, in 2016, 365,051 new trucks (medium and heavy commercial vehicles 
over 3.5 tonnes) were registered in the EU, 11.0% more than in 2015. The highest increases have been 
observed in Italy, France and Spain. The EU market for buses and coaches registered only a +2.3% 
increase, with 40,370 new vehicles. Spain, Italy and Germany contributed the most to such increase, 
while France saw a demand decline60. 

In 2015, latest year for which consolidated registration figures are available, around 365,000 HDVs 
were registered in the EU61. New trucks (medium and heavy commercial vehicles over 3.5 tonnes) 
registered in the EU saw an increase of +16.2% compared to 2014, and the EU market increased also 
by +17.8% for new medium and heavy buses and coaches (over 3.5 tonnes)62. 

60 http://www.acea.be/press-releases/article/commercial-vehicle-registrations-11.6-in-2016-10.4-in-december 
61 http://www.acea.be/statistics/tag/category/by-country-registrations 
62 http://www.acea.be/press-releases/article/commercial-vehicle-registrations-12.4-in-2015-14.8-in-december 

63 

 
 
 
 
 
                                                            
Table 1. Total new registrations in the EU in 2015 by country and vehicle 

Country 

Austria 
Belgium 
Bulgaria 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Netherlands 
Poland1 
Portugal 
Romania2 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
European Union3 (EU) 
European Union3 (EU) 
Total (EU)3 

Total Medium 
Commercial 
Vehicles  
from 3.5t to 16t 
830 
2.374 
0 
228 
1.818 
390 
49 
548 
5.927 
27.766 
185 
471 
759 
3.376 
69 
106 
147 
1.604 
2.069 
577 
347 
218 
164 
3.178 
607 
11.607 
65.414 

Total Medium 
Buses and 
Coaches 
 from 3.5t To 16t 
106 
288 
0 
67 
189 
281 
129 
276 
1.478 
1.174 
19 
138 
61 
841 
118 
163 
17 
53 
1.403 
101 
2.251 
16 
75 
694 
334 
5.151 
15.423 

Total Heavy 
Commercial 
Vehicles 
 over 16t 

Total Heavy 
Buses and 
Coaches  
over 16t 

6.461 
6.992 
0 
749 
9.540 
4.363 
772 
2.122 
36.856 
61.956 
279 
5.231 
1.491 
11.991 
1.236 
3.609 
1.005 
12.490 
20.586 
3.464 
5.778 
2.390 
1.743 
19.390 
4.849 
36.239 
261.582 

790 
635 
0 
62 
1.159 
169 
79 
246 
5.867 
4.945 
32 
401 
303 
1.565 
83 
29 
234 
291 
0 
146 
181 
173 
88 
1.923 
996 
2.499 
22.896 

80.837 

284.478 

365.315 

Source: Association Auxiliaire de l'Automobile, http://www.acea.be/statistics/tag/category/by-country-registrations  

1Data for Poland taken from PZPM (Polish Automotive Industry Association) 
2Data for Romania refers to sales (APIA). For registrations, see ACAROM figures at www.acea.be 
3Data for Cyprus and Malta not available 

64 

 
 
 
 
3.  HDV manufacturers 

The  European  HDV  market  is  dominated  by  six  manufacturers:  Daimler  Trucks,  Volvo  Trucks 
together with Renault Trucks, MAN Truck and Bus, DAF (Paccar Group), Scania and Iveco. 

Figure 1. Share of truck registrations in the EU and EFTA countries by manufacturers in 2015 

Table 2. HDV manufacturers' revenues and European market share in 2015 as published in their annual 
reports 

DAF (Paccar Group) 63 

Daimler Trucks 64 

Iveco (CNH Industrial Group)65 

MAN (VW Group) 66 

Scania (VW Group) 67 

2015 revenues 

~€4.5 bn 

€ 37,6 bn 

European market share 
2015 (*) 
(>6<16t) 8.9% 
(>16t) 14.6% 
22.5% 
 (Western Europe) 

USD 26.4 bn (~€ 24.8 bn, data for 
the whole group) 

€ 13,7 bn 

94, 9 bn SEK (~€ 10.3 bn) 

11.3% 

16.3% 

16.5% 

Volvo Trucks (incl. Renault Trucks) 68 
 (*) Definitions of "Europe" in manufacturers' annual accounts vary and may not necessarily coincide 

312 bn SEK (~€ 34 bn) 

23.8% 

63 DAF annual report 2015, https://www.daf.com/~/media/files/about%20daf/annual-report-daf-in-2015-en-68220.pdf, p.5 and p.15; Paccar 

annual report 2015, http://www.paccar.com/media/2486/paccar-ar-2015.pdf 

64 Daimler annual report 2015, https://www.daimler.com/documents/investors/berichte/geschaeftsberichte/daimler/daimler-ir-annual-report-

2015.pdf, p.3 and 92 

65 CNH Industrial annual report 2015, http://www.cnhindustrial.com/en-

us/investor_relations/financial_information/annual_reports/CNH_2015_Annual_Report.pdf, p. 14 and p. 59 

66 

MAN 

2015 

annual 

report, 

https://www.volkswagenag.com/presence/investorrelation/publications/annual-

reports/2016/man/11_03_2016_man_gruppe_gb_2015.pdf, p. 11 and p. 69  

67 The Scania report 2015, https://www.scania.com/group/en/wp-

content/uploads/sites/2/2016/03/Scania_Annual_and_Sustainability_Report_2015.pdf, p.2 and p. 39 

68  The  VOLVO  Group 

report 
group/markets/global/en-en/investors/reports-and-presentations/annual-reports/Volvo-group-annual-report_2015_eng.pdf, p.1 and p. 88 

http://www.volvogroup.com/content/dam/volvo/volvo-

sustainability 

annual 

2015, 

and 

65 

 
 
 
 
 
                                                            
Table 3. Registrations in the EU and EFTA by manufacturer of total commercial vehicles (trucks) over 
3.5t in 2015 

GROUP 

BRAND 

2015 

DAF 

DAIMLER 

FIAT 

FORD 

G.M. 

IVECO 

JAGUAR LAND ROVER 

43.462 
72.778 
4 
72.782 
32 
4.761 
4.793 
669 
41 
281 
15 
337 
37.811 
1 
1 
2 
2.617 
534 
1.962 
5.113 
16 
50.273 
50 
213 
263 
25.349 
44 
25.393 
43.860 
118 
1.616 
43.073 
7.289 
336.870 
Source: Association Auxiliaire de l'Automobile, http://www.acea.be/statistics/article/consolidated-registrations-by-manufacturer 

D.A.F. 
MERCEDES 
Others 
Total 
DODGE 
FIAT 
Total 
FORD 
CHEVROLET 
OPEL 
Others 
Total 
IVECO 
LAND ROVER 
Others 
Total 
MITSUBISHI 
NISSAN 
Others 
Total 
HYUNDAI 
M.A.N. 
CITROEN 
PEUGEOT 
Total 
RENAULT 
Others 
Total 
SCANIA 
TOYOTA 
VOLKSWAGEN 
VOLVO 
Others 

RENAULT 

SCANIA 
TOYOTA 
VAG 
VOLVO TR. 
OTHERS 
TOTAL 

JAPAN 

KOREA 
MAN 

PSA 

66 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
Table 4. Registrations in the EU and EFTA by manufacturer of total buses & coaches over 3.5t in 2015 

GROUP 

BRAND 

2015 

CHINA 
DAF 
DAIMLER 

FIAT 
FORD 
G.M. 
IVECO 
JAPAN 
KOREA 
MAN 

PSA 

6 
809 
10.815 
2.054 
12.869 
222 
3.687 
1.280 
5.904 
54 
1 
3.113 
154 
3.267 
11 
6 
17 
283 
1.789 
1 
482 
483 
2.235 
7.078 
39.984 
Source: Association Auxiliaire de l'Automobile, http://www.acea.be/statistics/article/consolidated-registrations-by-manufacturer 

Others 
D.A.F. 
MERCEDES 
Others 
Total 
FIAT 
FORD 
OPEL 
IVECO 
Others 
HYUNDAI 
M.A.N. 
Others 
Total 
CITROEN 
PEUGEOT 
Total 
RENAULT 
SCANIA 
SKODA 
VOLKSWAGEN 
Total 
VOLVO 
Others 

RENAULT 
SCANIA 
VAG 

VOLVO TR. 
OTHERS 
TOTAL 

67 

 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
Table 5 – EU motor vehicle trade 

1 Passenger cars 
2 Commercial vehicles up to 5t 
3 Commercial vehicles over 5t, inlcuding buses and coaches 

Source: ACEA, The Automobile Industry Pocket Guide 2016-201769 

4.  HDV Production 

Table 7 - Motor vehicle production in the EU  

1 Passenger cars 
2 Light commercial vehicles up to 3.5t 
3 Medium commercial vehicles from 3.5t to 15t 
4 Heavy commercial vehicles over15t (incl. artic trucks) 
Source: ACEA, The Automobile Industry Pocket Guide 2016-201770 

69 http://www.acea.be/uploads/publications/ACEA_Pocket_Guide_2016_2017.pdf, p.50 
70 http://www.acea.be/uploads/publications/ACEA_Pocket_Guide_2016_2017.pdf, p. 22 

68 

 
 
 
 
 
                                                            
5.  Transport operators 

Table 8. 2014 Annual detailed enterprise statistics for freight transport by road in the EU28 
(Extracted from annual detailed enterprise statistics for services, NACE Rev. 2 H-N and S95) 

EU28 - 2014 

Number of 
enterprises 

Production 
value 

Number of 
employees 

Number of 
persons 
employed per 
enterprise 

Gross 
operating 
surplus/turno
ver (gross 
operating 
rate) (%) 

H4941 - 
Freight 
transport by 
road 

542.358 

287.160 

2.392.019 

5,2 

12,1 

 Source: Eurostat, [sbs_na_1a_se_r2] 

Table 9. Distribution of transport and storage companies according to their size 

Number of persons employed by enterprise size class, transportation and storage  
(NACE Section H), 201371 

71 Available at: http://ec.europa.eu/eurostat/statistics-

explained/images/c/c6/Table_6a_Number_of_persons_employed_by_enterprise_size_class%2C_Transportation_and_storage_%28NACE
_Section_H%29%2C_2013.png 

69 

 
 
 
 
                                                            
Figure 2. Share of fuel (diesel) costs in the costs of French transport operators 

Source: Fédération Nationale du Transport Routier 2016, data Comité National Routier 

Table 10. Share of fuel costs in operating costs72 for 40t long haul as estimated in the index "Longue distance 
40 tonnes" by the Comité National Routier (France)  

Source: http://www.cnr.fr/Indices-Statistiques/Longue-distance-40T#haut, retrieved February 2017 

Table 11. Share of fuel costs in operating costs for 40t regional delivery as estimated in the index "Régional 
40 tonnes" by the Comité National Routier (France)  

Source: http://www.cnr.fr/Indices-Statistiques/Regional-40T#haut, retrieved February 2017  

72 Including cost of fuel (excluding VAT, taking into account the partial reimbursement of excise), maintenance costs, infrastructure charges, 

equipment, driver (remuneration + employers' contributions), travel expenses and charges. 

70 

Dec-06Dec-07Dec-08Dec-09Dec-10Dec-11Dec-12Dec-13Dec-14Dec-15Dec-16Gazole professionnel25,227,622,42326,328,52827,222,420,723,1Dec-06Dec-07Dec-08Dec-09Dec-10Dec-11Dec-12Dec-13Dec-14Dec-15Dec-16Gazole professionnel23,926,521,322,225,328,227,726,121,519,821,1 
 
 
 
 
 
 
 
                                                            
Table 12. UK Freight Transport Association (FTA) 'fuel fractions' table 

The  table  below  shows  fuel  costs  as  a  proportion  of  total  annual  vehicle  operating  costs  (including  vehicle 
standing costs, vehicle running costs and driver costs) for a range of HDVs. (Fuel prices based on bulk prices 
and exclude VAT). 

Low 
mileage 
(miles 
p.a.) 

Fuel costs as 
a 
percentage 
of total cost 
of vehicle 
and driver 
17 
22 

Average 
mileage 
(miles 
p.a.) 

High 
mileage 
(miles 
p.a.) 

Fuel costs as 
a 
percentage 
of total cost 
of vehicle 
and driver 
17 
22 

19 

25 

19 

25 

35,000 

50,000 

40,000 

70,000 

60,000 

50,000 

26 
29 
30 

30,000 
42,500 

50,000 
60,000 

40,000 
50,000 

60,000 
55,000 
75,000 

50,000 
50,000 
60,000 

7.5t rigid 
10 - 12t 
rigid 
12 - 14t 
rigid 
16 - 18t 
rigid 
26t rigid 
32t rigid 
33t (2+2) 
artic 
38t (2+3) 
artic 
38t (3+2) 
artic 
32.5t 
drawbar 
40t (2+3) 
artic 
44t (3+3) 
artic 
Cost data as at 1 July 2016.  
Source: FTA's Manager's Guide to Distribution Costs - July 2016 Update Report. 
http://www.fta.co.uk/policy_and_compliance/fuel_prices_and_economy/fuel_prices/fuel_fractions.html 

70,000 
65,000 
85,000 

26 
26 
30 

100,000 

50,000 

85,000 

85,000 

85,000 

70,000 

80,000 

70,000 

75,000 

50,000 

45,000 

60,000 

70,000 

80,000 

65,000 

31 

32 

29 

24 

30 

28 

29 

27 

29 

26 

Fuel costs as 
a 
percentage 
of total cost 
of vehicle 
and driver 
18 
21 

19 

25 

25 
26 
29 

29 

30 

28 

28 

30 

71 

 
 
 
 
 
ANNEX 8 - MONITORING OF CO2 EMISSIONS FROM VANS 

The following details are required for each new van (category N1 vehicle) registered in the EU:  

- 

- 
- 
- 

- 
- 

VIN number of vehicle (reported both 
by Registration Authorities and OEMs); 
Manufacturer name; 
Type approval number; 
Type, variant, version, make, 
commercial name; 
Specific emissions of CO2; 
Mass of the vehicle, wheel base, and 
track width; 

- 
- 
- 
- 
- 

Fuel type and fuel mode; 
Engine power; 
Engine capacity; 
Electric energy consumption; 
Innovative technologies and emission 
reductions through innovation 
technologies. 

Regulation  (EC)  No  510/2011  requires  Member  States  to  record  information  for  each  new  van  registered  in  its 
territory.  Every  year,  each  Member  State  submits  to  the  Commission  all  the  information  related  to  their  new 
registrations. Since 2013 the EEA is collecting data on newly registered vans in all EU Member States.  

The structure for the monitoring is as follows: 

1.  Member States record information for each new passenger van registered in their territory and transmit this 
information  to  the  Commission  by  28  February  of  each  year.  Data  are  submitted  to  the  Central  Data 
Repository (CDR) managed by the EEA (http://cdr.eionet.europa.eu/). 

2.  The EEA performs several quality checks in order to evaluate the accuracy and the quality of the dataset. On 
the  basis  of  the  checks  and  the  feedbacks  from  Member  States  the  EEA  finalises  and  publishes  the 
preliminary database. At the same time, notification letters are sent to manufacturers informing them of their 
provisional CO2 performances. 

3.  For the purpose of the verification of the provisional data, manufacturers shall submit to the Commission, at 
the  latest  by  28  February  each  year,  the  vehicle  identification  numbers  of  any  light  commercial  vehicle 
(complete, completed or incomplete) they sold in the preceding calendar year in the EU. Manufacturers can, 
within three months of being notified of the provisional calculation, notify the Commission of any errors in 
the data via the BDR (repository for businesses, https://bdr.eionet.europa.eu/). 

4.  The Commission assesses the manufacturers’ corrections, and, where justified, amends the provisional data 
for the calculation of the manufacturer final average CO2 emissions and specific emission targets. The final 
data  and  targets  are  confirmed  by  the  Commission  by  31  October  each  year  through  a  Commission 
Implementing Decision. The final database is published on the EEA website. 

The type approval, registration and monitoring process is illustrated in Figure 1. 

Figure 1. Overview of N1 vehicle type approval, registration and monitoring 

Source: CE Delft 

Note:  this  figure  describes  the  most  common  situation  in  Member  States  (MS),  where  –in  most  cases-  registration  data  is  used  for 
monitoring purposes. However, in some Member States type approval data is (partly) used. The data check, if performed by Registration 
Authorities  (RA),  is  not  necessarily  performed  between  RA  and  the  Type  Approval  Authorities  (TAA)  of  the  same  MS,  as  TA  can  be 
granted in any MS. 

72 

 
 
 
 
ANNEX 9 - INTERNATIONAL EXPERIENCES WITH HDV FUEL EFFICIENCY 

Extract from: Ricardo Energy and Environment (2017), Analysis of fuel economy and GHG emission reduction measures 
from Heavy-duty Vehicles in other countries and of options for the EU73 

Main markets 

United States, California and Canada 

1. 

Introduction and broad market characteristics 

The  United  States  has  had  CO2  and  fuel  consumption  regulations  in  place  since  2014.  The 
regulations are developed and managed by the Environmental Protection Agency (EPA; for 
CO2)  and  the  National  Highway  Traffic  Safety  Administration  (NHTSA;  for  fuel 
consumption). The regulations cover all on-road vehicles with a gross vehicle weight rating 
over  8,500lbs  (3,850  kg),  which  are  broken  down  into  7  subcategories.  Almost  identical 
legislation is in place in Canada. 

2. 

Background to measures 

The  drivers  behind  these  measures  involved  a  combination  of  energy  security  and 
environmental  protection  concerns.  The  regulations  took  7  years  from  conception  to 
implementation,  beginning  in  2007  and  becoming  effective  for  the  2014  model  year  (MY). 
The  current  regulations  are  known  as  Phase  1  and  run  until  2017,  after  which  Phase  2 
regulations will be implemented and run until 2027. 

The regulations use a baseline derived from actual vehicle market data, taking representative 
vehicles for each subcategory for MY2010. From this baseline, improvements are expected 
through a range of technologies with varied adoption rates. Compliant MY2017 vehicles will 
be used as the baseline for Phase 2.  

A number of studies were carried out that informed the regulations, including assessment of 
the  environmental  and  economic  impacts  and  reviewing  which  technologies  would  best 
achieve the required results. Furthermore, extensive consultation was carried out with a wide 
range of stakeholders in the sector. 

3. 

Scope 

The  current  US  regulations  give  standards  for  fuel  consumption  and  CO2  emissions  for 
engines  and  whole  vehicles.  In  Phase  2,  further  regulations  will  also  be  introduced 
specifically for trailers. The standards for CO2 emissions and fuel consumption are given in 
gCO2e/ton-mile and gal/1,000 ton-miles, respectively. The standards also cover nitrous oxide 
and methane emissions, as well as air-conditioning leakage and hydrofluorocarbon release. 

Engines  are  certified  using  an  engine  dynamometer  running  two  different  drive  test  cycles. 
The  standards  for  whole  vehicle  emissions  and  fuel  consumption  use  the  GEM  simulation 
model,  which  has  three  different  drive  cycles  and  a  further  two  idle  cycles  for  vocational 
vehicles.  The  simulation  currently  uses  default  engine  maps,  but  in  Phase  2  manufacturers 
will  provide  engine  maps  to  better  simulate  transient  drive  cycles.  Pickups  and  vans  (Class 
2B/3) are tested on a chassis dynamometer instead, similar to the LDV programme. 

73 Ricardo Energy and Environment (2017), Analysis of fuel economy and GHG emission reduction measures from Heavy Duty Vehicles in 
other countries and of options for the EU, Interim Report contract 340201/2016/736088/SER/CLIMA.C.4, unpublished. Final report will 
be available at https://ec.europa.eu/clima/policies/transport/vehicles/heavy_en#tab-0-2  

73 

 
 
                                                            
Manufacturers  must  meet  certain  standards  within  each  manufacturing  year,  although  there 
are flexibility options to allow manufacturers sufficient lead-time to introduce technologies to 
their fleet. The flexibilities are provided through an averaging, banking and trading scheme 
that also gives credits for early adoption and advanced technologies. 

Through  adopting  separate  engine  and  vehicle  standards,  the  US  agencies  have  sought  to 
drive technology improvements in both engines and vehicles, while also leaving the market to 
decide the most cost effective technologies to meet the standards.  

Overall,  significant  savings  in  fuel  reduction  (530  million  gallons),  CO2  emissions  (270 
million  metric  tonnes  of  GHGs),  fuel  cost  savings  ($50  billion)  and  other  social  and 
environmental benefits ($49 billion) are expected in Phase 1 alone. Phase 2 would see further 
savings significantly greater than Phase 1 in all respects. 

4. 

Monitoring, reporting, verification and enforcement 

 Under the Clean Air Act, all vehicles must be certified at the point of sale. Testing is carried 
out by the manufacturer before sale, but also throughout the useful life of the vehicle (though 
no standards are in place for the latter). Testing data is sent to the EPA and the NHTSA prior 
to  manufacture,  and  this  data  is  used  to  calculate  model  year  emissions.  Violations  and 
penalties are issued on the basis of this information. There is a single reporting structure in 
which  manufacturers  report  their  sales  for  the  year  and  their  emissions  given  in  the 
Certificates of Conformity. Given the flexibilities in place and the feasibility of compliance to 
the Phase 1 regulation, no penalties have yet been necessary.  

California 

California holds a unique regulatory position in the US, as the only state with an air quality 
regulator  independent  from  the  Federal  Government.  Regarding  HDV  CO2  and  fuel 
consumption regulations, California has followed the federal US Phase 1 regulations in 2014. 
However,  it  is  possible  that  California  will  decide  to  adapt  slightly  more  stringent  Phase  2 
standards than the Federal level. A decision is expected in 2017 on this. 

In  addition,  California  has  adopted  two  separate  programmes  that  go  beyond  the  Federal 
HDV regulations. Firstly, California have a Hybrid Truck and Bus Voucher Incentive Project 
(HVIP), which provides vouchers for the purchase of new hybrid trucks and buses. Secondly, 
California  have  made  the  EPA’s  SmartWay  programme,  mandatory  for  certain  trucks  and 
trailers under the Tractor-Trailer regulation. This programme is voluntary on a national scale 
and provides SmartWay-certified technology to improve aerodynamics and tyres. However, 
many  of  the  measures  set  out  in  this  regulation  are  incorporated  into  Phase  2  of  the  US 
regulations (applying from 2018) and will therefore essentially become obsolete. 

Canada 

Canada has followed US standards and adopted Phase 1. Similarly, it is expected that Canada 
will adopt the Phase 2 standard along the same timeline as the US.  

Administration, monitoring and enforcement is handled by Environment Canada. Before the 
introduction  of  Phase  1,  Environment  Canada  undertook  a  separate  regulatory  impact 
assessment which estimated a reduction of approximately 19.1 Mt CO2e, 7.2 billion litres of 
fuel and economic benefits of $5.3 billion74.  

74 Canadian dollars (2011). 

74 

 
 
                                                            
The  Canadian  Phase  1  standards  contain  very  minor  changes  to  the  US  equivalent.  First, 
Canada allows for an optional certification for vehicles over 80,000 lbs which are not covered 
by the US regulations, due to the greater use of such vehicles in the Canadian fleet. Second, 
limit values in Canada are purely defined in terms of GHG emissions.  

China 

1. 

Introduction 

China have had regulations in place for heavy-duty fuel consumption since 2008. These first 
standards  are  the  responsibility  of  the  Ministry  of  Transport  (MOT)  and  regulate  fuel 
consumption  from  in-use  vehicles.  In  2012,  the  Ministry  of  Industry  and  Information 
Technology (MIIT) implemented a second standard which requires manufacturers to obtain a 
certificate of conformity for all new type approvals before production can take place. In 2014, 
this  became  a  requirement  for  all  vehicles  sold.  Later  in  2014,  the  second  stage  of  these 
regulations was introduced for all new type approvals (2016 for all vehicles sold). The third 
stage of the regulations, expected to be introduced for all new type approvals in 2019 (2021 
for all vehicles sold), has recently been announced and is currently open to public comment.  

2. 

Background to measures 

The  measures  were  pursued  following  environmental  and  economic  rationale.  China  has 
expressed its interest in controlling emissions from its rapidly growing HDV sector, whilst it 
is  also interested in  its energy security,  road safety, and improving technological capability 
within the sector. 

A  modified  version  of  the  World  Harmonised  Vehicle  Cycle  (WHVC)  test  procedure  was 
developed  by  China  Automotive  Technology  and  Research  Center  (CATARC)  in  order  to 
take  into  account  typical  accelerations,  decelerations,  and  weighting  between  urban,  rural, 
and motorway driving of the Chinese heavy-duty sector. Due to the lack of data concerning 
the fuel efficiency and composition of the fleet, efforts were focussed on accumulating fuel 
consumption data in order to inform the development of the standards. Vehicles were tested 
by  the  CATARC  and  the  results  used  to  inform  regulatory  subcategories  and  limit  values. 
Stage I was seen as a data collection exercise by MIIT. Further data collection through testing 
by CATARC and data submission required from manufacturers informed the development of 
Stage II and III, which as a result are much more difficult to satisfy. 

3. 

Scope 

Stage I regulations cover rigid trucks, articulated trucks and coaches, whilst for Stage II the 
scope expanded to include construction HDVs and urban buses. The proposed scope remains 
the same for Stage III. Function-specific HDVs, such as salt spreading vehicles, are exempt. 

4. 

Monitoring, reporting, verification, and enforcement 

China  regulates  new  type  approvals,  conducts  conformity  of  production  testing  and  runs 
inspection  and  maintenance  programmes  as  a  part  of  its  heavy-duty  emissions  regulation 
programme. The former two compliance mechanisms are the responsibility of the Ministry of 
Environmental  Protection  (MEP).  The  institution  implementing  the  programmes  is  the 
Vehicle Emission Control Center (VECC) under the MEP. 

China’s emissions regulatory programme primarily focuses on enforcing requirements at the 
pre-market stage, by requiring manufacturers to obtain emission type approvals and to satisfy 
conformity of production. The MOT standards are responsible for regulating in-use vehicle 
emissions. 

75 

 
 
Japan 

1. 

Introduction 

Japan  implemented  its  HDV  fuel  efficiency  measures  in  2006,  and  was  the  first  country  to 
have such regulations. The measures are the responsibility of the Ministry of the Environment 
(MOE),  the  Ministry  of  Land,  Infrastructure  and  Transport  (MLIT)  and  the  Ministry  of 
Economy, Trade and Industry (METI). Japan’s fleet is quite different from the US and EU, 
being composed largely of light trucks. Japan’s HDV fuel efficiency measures follow the Top 
Runner  Approach,  which  has  been  applied  to  a  wide  range  of  industries  to  achieve  energy 
efficiency improvements. 

2. 

Background to measures 

Japan began pursuing fuel efficiency measures following a series of oil crises in the 1970s. 
As such, energy security has always been an important aspect of the measures. More recently, 
meeting global climate targets has been a significant factor driving regulation.  

As  with  other  Top  Runner  Approaches,  the  baseline  was  derived  from  the  top  performing 
product in the market. The regulations used the most fuel efficient MY2002 vehicle in each 
category  to  set  targets  for  MY2015,  also  factoring  for  further  improvement  of  the  ‘Top 
Runner’ vehicle over that time.  

3. 

Scope 

Japan’s  fuel  efficiency  measures  cover  diesel  fuelled  vehicles  with  a  gross  vehicle  weight 
rating  (GVWR)  in  excess  of  3.5  tonnes,  broken  down  into  12  categories  for  buses  and  13 
categories for freight vehicles, including tractors. For each category, a target standard is given 
for  MY2015.  The  fuel  efficiency  standards  are  part  of  a  wider  suite  of  energy  saving 
measures,  including  subsidies  for  new  vehicles,  eco-driving,  improved  traffic  management, 
efficient logistics and mobility management. The fuel efficiency standards are given in km/L 
and amount to a 12.2% fuel efficiency improvement by 2015 over 2002 levels. 

Japan  have  a  similar  testing  process  to  that  of  the  US.  An  engine  dynamometer  is  used, 
running two drive cycles in a ratio based on the vehicle category.  

The  fuel  map  created  by  the  dynamometer  test  is  then  fed  into  a  simulation  model  that 
includes actual engine and transmission specifications, and standard values for aerodynamics, 
tyres and size. The Top Runner approach does not specifically incentivise any technologies. 
This allows manufacturers to reach the standards by any technology pathway. 

The deadline for compliance  was set  in 2006 giving  standards for MY2015. Unlike the US 
regulation, only a single MY standard is set for each vehicle category. 

4. 

Monitoring, reporting, verification and enforcement 

METI  and  MLIT  monitor  manufacturers  through  their  corporate  average  fuel  efficiency 
(CAFE). This average gives some flexibility across a manufacturer’s range of products. The 
penalties for non-compliance are relatively loose. The most notable enforcement mechanism 
is a public announcement by the Authorities, which is considered a severe enough incentive 
to ensure compliance. 

76 

 
 
 
 
Other markets 

India 

India  currently  does  not  have  measures  to  reduce  heavy-duty  vehicle  fuel  consumption  but 
has  been  considering  them  in  more  depth  since  2014.  It  is  expected  that  HDV  engine 
standards will be introduced in the next few years, whilst the likely end goal of full vehicle 
standards may take longer. 

Mexico 

Mexico is the world’s leading exporter of heavy-duty vehicles, but does not yet have any fuel 
consumption or  CO2 regulations. However, as  most of the  vehicles are exported to the US, 
Mexico’s manufacturers most likely comply with US regulations. Regulations are expected to 
be implemented in Mexico in the future as part of an aligned North American standard, and 
would be in line with Phase 2 US regulations. 

South Korea 

South  Korea  does  not  currently  have  any  HDV  fuel  consumption  or  CO2  regulations.  An 
HDV fuel efficiency programme is currently under consideration, although the timeline is not 
known. 

77 

 
 
ANNEX 10 - ASSESSMENT OF ADMINISTRATIVE COSTS OF MONITORING AND REPORTING

Monitoring heavy-duty 
vehicles’ CO2 emissions 
and their costs 

An assessment 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Monitoring heavy-duty 
vehicles’ CO2 emissions 
and their costs 

An assessment 

The information and views set out in this report are those of the author(s) and do not necessarily 
reflect the official opinion of the Commission.  

This report is prepared by: 

Eelco den Boer, Maarten ‘t Hoen (CE Delft) 

Stefan Hausberger (TU Graz) 

Delft, CE Delft, March 2016* 

Publication code: 16.4G09.30 

Heavy-duty Vehicles / Carbon dioxide / Emissions / Monitoring / Certification / Costs  

Client: European Commission, DG CLIMA. 

Further information on this study can be obtained from the contact person, Eelco den Boer. 

CE publications are available from www.cedelft.eu 

© copyright, CE Delft, Delft 

CE Delft 

Committed to the Environment 

Through its independent research and consultancy work CE Delft is helping build a sustainable 

world. In the fields of energy, transport and resources our expertise is leading-edge. With our 

wealth of know-how on technologies, policies and economic issues we support government 

agencies, NGOs and industries in pursuit of structural change. For 35 years now, the skills and 

enthusiasm of CE Delft’s staff have been devoted to achieving this mission. 

* Limited update in October 2016 to cover the presentation of the findings to a stakeholder meeting. 

1 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Glossary 

Glossary 

ECWVTA 

GVW 

eCoC 

IVA 

MSV 

EEA 

OEM 

MS  

European Community Whole Vehicle Type Approval 

Gross Vehicle Weight 

electronic Certificate of Conformity 

Individual Vehicle Approval 

Multi Stage Vehicle 

European Environment Agency 

Original Equipment Manufacturer 

Member State 

NSSTA 

National Small Series Type Approval 

RA 

TAA 

XML 

XSD 

IVI 

EReg 

HDV 

VECTO 

VIN 

Registration Authority 

Type Approval Authority 

Extensible Markup Language  

XML Scheme Definition 

Individual Vehicle Information 

Association of European Vehicle and Driver Registration Authorities 

Heady Duty Vehicle 

Vehicle Energy consumption Calculation TOol 

Vehicle Identification Number 

N1, N2, N3 

A vehicle category classifying a land vehicle for regulatory purposes.  

N1:  Vehicles used for the carriage of goods and having a maximum mass not 

exceeding 3.5 tonnes (Pick-up Truck).  

N2:  Vehicles used for the carriage of goods and having a maximum mass 

exceeding 3.5 tonnes but not exceeding 12 tonnes (Commercial Truck). 

N3:  Vehicles used for the carriage of goods and having a maximum mass 

exceeding 12 tonnes (Commercial Truck).  

EC  

TA  

European Commission 

Type Approval  

ECWVTA 

European Community Whole Vehicle Type Approval 

IAC 

Individual Approval Certificate 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
Abstract 

This study identifies three options for monitoring of HDV CO2 emissions and 
fuel consumption data ensuing from the future certification procedure under 
type-approval: 1) Member States reporting through the national vehicle 
registration process per individual vehicle to the EC (via the EEA), 2) OEMs 
once a year reporting directly to the EC (via the EEA) and 3) by cross reporting 
of VIN numbers by Member States and VECTO result data by OEMs to the EC 
(via the EEA). OEMs prefer cross reporting, mainly since this option limits their 
administrative costs. Member States have expressed different views: some 
supported the cost argument favouring option 3, others argued that  
option 1 provides more credibility to the monitoring data. Monitoring costs are 
between € 1 (Option 3) and € 5 (Option 1) per vehicle registered in the EU. 
Decisive cost categories are development and operation of the needed IT 
systems by Member States in order to process large VECTO result files  
(Option 1) and the definition and agreement of the modus operandi of OEMs 
with 28 Member States and transfer of individual data files per vehicle  
(Option 1). 

3 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
Summary 

Introduction 
On 21 May 2014 the European Commission adopted a Communication to the 
Council and the European Parliament on a Strategy for reducing HDV fuel 
consumption and CO2 emissions in Europe. This strategy focusses on short term 
actions to certify, monitor and report HDV fuel consumption and 
CO2 emissions.  

The upcoming HDV CO2 certification methodology is based on vehicle 
simulation performed via a dedicated VECTO simulation software tool.  
In addition to certification, a monitoring system needs to be set up in order to 
inform policy makers and other stakeholders on newly registered vehicles’ fuel 
and CO2 emission performance. To this end, DG CLIMA aims to inventory the 
available options for monitoring and reporting VECTO data and to assess the 
related costs, following on an indicative assessment of costs by TNO (2015)1.  

Objective and study methodology 
The objective of the study is twofold:  
 

to better understand the various options for monitoring HDV CO2 emissions; 
and  
to make a proper costs assessment of monitoring options.  

 

The main feature in designing monitoring options is defining the responsible 
body for monitoring VECTO data and identifying the respective pros and cons2. 
We conducted interviews with national registration authorities, OEMs and EEA 
in order to better understand the current monitoring procedures in 
EU countries, to hear their opinion about various identified monitoring options 
and to receive targeted input regarding the costs for their organisation, taking 
into account the current practice and required adaptations. The results of this 
study are used as input for the internal EC impact assessment on monitoring 
options. 

Monitoring options for HDVs 
Taking into account the current practice in EU Member States regarding  
N1 monitoring, three main monitoring options have been identified for HDVs. 
Among all options, VECTO data is transferred to the European Commission or 
the European Environment Agency (EEA) on behalf of the Commission.  
This data is submitted by either Member States (Option 1) or OEMs (Option 2 
and Option 3): 
1.  Monitoring responsibility for Member States only: 

a  Only digital file submittal. 
b 

In a number of MS digital & paper data flows (variant). 

2.  Monitoring responsibility for OEMs only: Based on sales data  

(‘self-reporting’). 

1   TNO 2015 R10150 Final report, Cost-benefit analysis of options for certification, validation, monitoring and reporting of heavy-duty vehicle 

fuel consumption and CO2 emissions. 

2   The exact definition of data to be monitored shall be discussed in parallel to this study as part of the stakeholder dialogues organised by the 

European Commission. 

4 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
                                                            
3.  Intermediate option (between 1 and 2): designated national authorities 

annually report vehicle identification numbers (‘VINs’) of new registered 
vehicles to the Commission, which is used for the extraction of monitoring 
data from OEMs’ files. 

Option 1 is expected to mirror the monitoring already carried out for  
light-duty vehicles’ CO2 emissions in which the monitoring responsibility lies 
with Member States. VECTO data is submitted by OEMs to Member States as 
part of the vehicle registration process. 

Transfer of monitoring data 
Registration procedures vary widely among EU Member States. In some 
Member States the HDVs are registered through vehicle certificate of 
conformity (CoC), others use type approval documents, or a combination of 
forms. HDV CO2 monitoring takes place via the transfer of VECTO data  
(up to 500 data points) from OEMs to the reporting authority. It can be done in 
different ways: 
  as part of an extended vehicle CoC or type approval document (PDF) used 

for registration (Option 1); 

  as part of a standardised XML file (extended Individual Vehicle Information 
(IVI) file) that can replace the current CoC and type approval documents 
(Option 1); 

  as an additional file (XML) that can either be added to the current 

registration documents (Option 1) or can be handed over directly by OEMs 
to European authorities (Option 2/3).  

Many countries are digitalising their processes of registration, but the degree 
of digitalisation varies and digitalisation processes are not harmonized. From a 
technical point of view it would be possible to use the IVI message file that is 
developed by EReg3, but current digitalisation efforts are hardly based on this 
file. It is therefore unrealistic to assume that the registration process will be 
based on an extended IVI message file. It is rather expected that HDV  
CO2 registration will occur: 
  By the use of one harmonized XML file with VECTO results (Option 1, 2 

or 3). 

  Or by amendment and expansion of the existing and upcoming digital 

national registration processes. This would imply that OEMs and national 
registration authorities have to agree on the file structure (Option 1 only). 
This option holds the risk of a non-aligned file structure. 

Member States and OEMs’ perspectives 
The use of paper documents (Option 1b) would be expensive and lacks support 
of Member States or OEMs. Therefore this method will not be analysed in this 
report. Both stakeholder groups stated that VECTO data should be processed in 
standardised electronic formats (XML) and need to be compatible with 
database systems. 

Option 3 is favoured by six out of twelve interviewed Member States,  
Option 1 is preferred by four Member States and two Member States expressed 
no preference. The most important argument in favour of Option 3 is that it 
will put less burden on Member States and requires no extra investments in  
IT systems (vehicle registration databases). The main argument supporting 
Member State monitoring is related to data credibility and reliability, and 

3  Association of European Vehicle and Driver Registration Authorities. 

5 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
                                                            
parallels with the light-duty vehicle monitoring that is currently performed by 
Member States. Since Option 1 imposes a high burden on OEMs, due to data 
transfers for every individual vehicle, they prefer Option 3. However, OEMs do 
not necessarily know in which country vehicles are registered, when the 
VECTO CO2 results are produced on the production line. Subsequently, OEMs 
and Member States are not in favour of Option 2.  

Based on the interviews, it seems unlikely that Member States will have 
introduced sufficiently harmonized electronic data handling and registration 
procedures before 2018. This implies that OEMs would need to send the files to 
each of the national registration authorities, with the risk of deviating data 
formats. This is currently the case with digital registration. 

Multi stage vehicles 
When VECTO data files are directly added by OEMs to a central EU database 
(Option 2/3), multi stage vehicles (MSV, representing approximately 40% of the 
market) can also be included in the monitoring system without special efforts 
by n-stage manufacturers. In case of Option 1, MSVs can only be included if 
n-stage manufacturers need to register MSVs along with the VECTO data.  
This may result in a significant additional administrative burden, since these 
companies are often small and medium sized companies.  

Costs of the different options 
We estimated the costs of the various monitoring options for Member States, 
OEMs and the EEA. Total cost figures are quantified for 28 Member States and 
7 OEMs and include one-off investment costs and annual costs. Non-technical 
implementation costs and database development costs have been quantified as 
non-recurring costs. Database maintenance, VECTO data reporting costs and 
quality and accuracy checks have been identified as annual costs. 
Figure 1 shows the total annualised costs, consisting of the one-off transition 
costs and the annually recurring costs. 

Figure 1 

Comprehensive total annualised costs of monitoring and reporting options 

6 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

€0€500.000€1.000.000€1.500.000€2.000.000€2.500.000Option 1: MSresponsibleOption 2: Selfreporting OEMOption 3: Crossreporting OEMand MSTotal costsTotal annualised costsEEA/ECMember StatesOEM 
 
 
 
 
 
The figures show that the costs of Option 1 are the highest, representing: 
 

the high annual costs for OEMs that is linked to the transfer of VECTO data 
to registration authorities; 
the high transition costs for Member States and the high annual costs as a 
result of the development or adaption of databases and IT systems. 

 

The costs of Options 2 and 3 are lower because Member States’ registration 
systems do not need adaptation and VECTO data is not transferred for every 
single vehicle registered. Instead, OEMs extract the relevant monitoring data 
from the database where VECTO certification data is stored, on an annual 
basis. In case of Option 3, Member States report the identity of vehicles 
registered in their countries. This is a relative simple operation that can be 
performed on the basis of existing registration practice. 

7 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
Contents 

Glossary 

Abstract 

Summary 

Introduction 
Background 
Project objective and scope 
Research structure 
Research methodology 
Report structure 

2 

3 

4 

9 
9 
10 
11 
12 
13 

Assessment of HDV monitoring options 
Introduction 
Vans (N1 vehicle) registration and monitoring 
Current practice of heavy-duty vehicle type approval and registration in  
EU Member States 
Monitoring options for HDVs 
Member States’ perspective 
OEMs’ perspective 
Conclusion 

14 
14 
14 

17 
20 
22 
27 
30 

Assessment of monitoring activities and costs 
Introduction 
Definition of cost methodology 
Costs per actor 
Overall costs for the various monitoring options 

Conclusions 
Options for monitoring actors 
Method of transfer of data 
Member States’ and OEMs’ perspectives 
Costs of the monitoring options 
Recommendations 

1 
1.1 
1.2 
1.3 
1.4 
1.5 

2 
2.1 
2.2 
2.3 

2.4 
2.5 
2.6 
2.7 

3 
3.1 
3.2 
3.3 
3.4 

4 
4.1 
4.2 
4.3 
4.4 
4.5 

33 
33 
33 
35 
43 

46 
46 
47 
47 
48 
48 

49 

52 

52 

Annex A 

Overview of cost estimations for MS of Monitoring Option 1 

Annex B 

Rate of digitalised registrations 

Annex C 

Comparison of this study with the TNO study 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
Introduction 

Background 

Heavy Duty Vehicle (HDV) emissions represent an estimated 5% of total EU 
GHG emissions and more than a quarter (about a 27%) of road transport 
emissions. Unlike car emissions, they are not covered by EU legislation and, 
without action, would probably remain at their current level, i.e. some 20% 
above their 1990 levels (EEA, 2015a/b)4. Such a result would be clearly 
incompatible with the objective to reduce greenhouse gas emissions from 
transport by around 60% in 2050 (compared to 1990 levels), as set out in the 
Commission’s 2011 Transport White Paper and Roadmap for moving to a 
competitive low carbon economy in 2050. 

On 21 May 2014 the European Commission adopted a Communication to the 
Council and the European Parliament on a Strategy for reducing HDV fuel 
consumption and CO2 emissions in Europe. This strategy focusses on short 
term actions to certify, monitor and report HDV fuel consumption and 
CO2 emissions. This will require legislation on certifying, monitoring and 
reporting these emissions. 

The upcoming HDV CO2 certification methodology is based on vehicle 
simulation performed via a dedicated VECTO (Vehicle Energy consumption 
Calculation TOol). This approach offers the possibility to accurately capture 
the highly diverse characteristics of HDVs and their influence on fuel 
consumption and CO2 emissions, without heavily increasing the complexity and 
the costs for vehicle certification. An ‘editing board’ has been established by 
DG GROW to facilitate stakeholder involvement and to define the exact 
certification methodology and legislation. 

Currently, the HDV certification methodology is being finalized and tested, 
and adaptations to the relevant regulatory framework (Regulation (EC) 
595/2009) are being proposed. Certification will basically use the VECTO 
simulation software tool, which requires input parameters from components 
testing. Since mid-2015, a draft certification procedure is available for testing 
in a ‘pilot phase’. This pilot phase ran until the end of 2015 and its outcomes 
are currently being assessed. The goal is to have the system operational in 
2018. 

Original equipment manufacturers (OEM) will be responsible for certification 
of the entire vehicle (partly based on default values, e.g. for bodies/trailers). 
The process covers both single stage manufactured vehicles and multistage 
vehicles (for all HDV, default values on the body or trailer will be used in the 
simulation). 

4   EEA, 2015a. Annual European Union greenhouse gas inventory 1990–2013 and inventory report 2015, Submission to the UNFCCC Secretariat, 

27 November 2015. 
EEA, 2015b. Evaluating 15 years of transport and environmental policy integration TERM 2015: Transport indicators tracking progress towards 
environmental targets in Europe. 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
                                                            
In addition to a certification scheme, a monitoring system needs to be set up 
in order to inform policy makers and other stakeholders on newly registered 
vehicles' fuel and CO2 performance. DG CLIMA aims to inventory the available 
options for monitoring and reporting of VECTO data and to assess the related 
costs, following on an indicative assessment of costs by (TNO, 2015)5.  

Project objective and scope 

The objective of the project is twofold:  
 

to better understand the various options for monitoring HDV CO2 emissions 
and fuel consumption; and  
to make a proper costs assessment to feed the internal EC impact 
assessment on monitoring options. 

 

Two main questions arise regarding the HDV monitoring options: 
  What VECTO data should be monitored? 
  Who should monitor and report? 
The first question is outside the scope of this study but will be discussed 
during the stakeholder dialogues. Quite a number of parameters can 
potentially be monitored. We can aggregate them into the following groups: 
1.  General vehicle information (mission profile independent): 

transmission specifications; 

  component identification; 
  vehicle classification; 
  engine specifications; 
 
  axle specifications; 
transfer case specifications; 
 
tyre specifications; 
 
  auxiliary specifications; 
  advanced driver assistance systems. 

2.  Mission profile and loading conditions: 

  mission profile and loading dependent values; 
  vehicle mass; 
  vehicle driving performance and information for simulation quality 

 

check; 
results for energy consumption (fuel) and CO2 emissions per CO2 test 
cycle and weight assumptions; 
  average energy consumption values; 
software and user information. 
 

We assume that OEMs will produce a VECTO result file with above mentioned 
values for any new vehicle. Vehicles that do not include generic standard 
bodies (used in the actual VECTO approach to define air drag and weight) will 
still be assigned CO2 values of the generic configuration. Subsequently, the 
CO2 values of produced HDVs give an indication of their efficiency, but they 
not necessarily reveal the absolute fuel consumption when alternative bodies 
and trailers are mounted later on. This may change in the future if a 
methodology that considers different body and trailer designs is implemented.  

5  TNO, 2015. R10150 Final report, Cost-benefit analysis of options for certification, validation, monitoring and reporting of heavy-duty vehicle 

fuel consumption and CO2 emissions. 

10 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
                                                            
The use of generic values irrespective of whether the vehicle is produced in 
multistage or by the OEM completely. It should, however, be guaranteed that 
fuel efficiency of base vehicles can be compared in order to meet the 
objective of improved consumer information. The share of MSVs is significant 
in some countries and typically around 40%. 

It should also be realised that the impact of future adding n-stage buildings to 
the CO2 monitoring can be significant. This would imply that n-stage builders 
(often SMEs) are responsible for transferring data to OEMs, registration 
authorities or the European Commissions (EEA). Since OEMs co-operate with up 
to several hundreds of n-stage builders, the costs data transfer might be 
significant. 

This study will focus on the monitoring process. It identifies monitoring 
entities, pros and cons of the various available options. Cost estimates of the 
identified options are also included. 

Research structure 

The structure of the research is illustrated in Figure 2. 
Two main tasks can be identified: 
  definition and assessment of monitoring options: 

  definition of options;  
  consultation of stakeholders; 
  assessment of pros, cons and stakeholder preferences. 

  cost assessment of monitoring options: 

  assessment of activities; 
  assessment of costs; 
  consolidation of findings with (TNO et. al., 2015)6; 
  presentation of findings to stakeholders. 

Figure 2 

Overview of project structure 

6   TNO, 2015. R10150 Final report, Cost-benefit analysis of options for certification, validation, monitoring and reporting of heavy-duty vehicle 

fuel consumption and CO2 emissions. 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

Task2: Assesscostsof monitoring optionsTask1: Re-assessmonitoring optionsTask1.1Definingmonitoring optionsTask1.2Interviews withstakeholdersTask1.3 Assessment of  monitoring optionsTask2.1Assessment of monitoring activitiesTask2.2CostassessmentTask2.4Stakeholder workshopTask2.3Consolidatingfindingsbottom-up analysis andTNO analysis 
 
 
 
 
 
 
                                                            
Definition of monitoring and reporting 
Type approval and certification is not part of this study, but is discussed in 
TNO et al. (2015). It is the certification process, including verification by type 
approval authorities, which needs to ensure that a representative CO2 emission 
figure is attached to each single vehicle that is certified. Monitoring only 
needs to ensure that the certified data is transferred to the relevant 
monitoring authorities, exactly as it was certified. 

For the purpose of this study, monitoring and reporting is defined as 
“gathering and forwarding data made available through type approval 
processes for newly registered vehicles for the purpose of information 
provision”. The process ranges from data storage by OEM and National 
Authorities to central database development and operation by the European 
Commission (or the EEA on behalf of the Commission). This implies that the 
following activities are not taken into account when measuring monitoring 
costs: component certification, running the VECTO simulation software, 
conformity testing, VECTO data storage, the type approval process and 
registration. With respect to national authorities, only costs that relate to the 
storage and submission of monitoring data to the Commission should be taken 
into consideration when defining costs in the context of the present impact 
assessment. 

Figure 3 shows which steps are required for bringing a vehicle to the market. 

Figure 3 

Three steps related to bringing a vehicle to the market 

Only the latter category of ‘M’ costs is considered in this study. These are 
additional activities needed for monitoring that cannot be allocated to type 
approval and registration. For example, the eventual expansion of Member 
States’ registration databases (in order to process VECTO data) is included in 
the analysis. 

Research methodology 

This study is largely based on interviews. They have been mainly applied for 
national registration authorities and OEMs in order to better understand the 
current monitoring procedures in EU countries, to hear their opinion about 
various monitoring options and to receive targeted input with regard to the 
costs for their organisation, taking into account the current procedures and 
required adaptations.  

It should be noted that some registration authorities and national governments 
have only been involved to a limited extent in the EU discussions on the 
development of heavy-duty vehicle CO2 certification and monitoring and have 
not started analysing the requirements for HDV CO2 monitoring within their 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

Production& type approvalRegistrationMonitoringTypeapprovalcostsTARegistrationcostsRMonitoring costsM 
 
 
 
 
 
 
 
 
organisations. Therefore it is difficult for them to understand and oversee the 
impact of monitoring and reporting. Furthermore, various details have not yet 
been defined (e.g. the number of data to be monitored). As a result, some 
interviewees could not answer all questions. 

Table 1 shows the countries and OEMs that have been approached for an 
interview, as well as their feedback, either written or oral. 

Table 1 

Overview of countries and OEMs approached 

Interviewed (17)  

Croatia, Denmark, France, Finland, 

ACEA, Scania, DAF, 

Member States 

OEMs 

Germany, Greece, Netherlands, Slovakia, 

Volvo, Daimler 

Sweden, UK, Spain, Italy 

No or negative 

response (8) 

Belgium, Cyprus, Estonia, Luxembourg, 

Iveco, MAN 

Lithuania, Poland, Romania, Ireland 

Not contacted (8) 

Austria, Bulgaria, Czech Republic, Hungary, 

Renault 

Latvia, Malta, Portugal, Slovenia 

Report structure 

In Chapter 0, the concept of vehicle CO2 monitoring is introduced with  
N1 vehicles (vans) as a reference. Subsequently, three monitoring options are 
identified and assessed. Chapter 0 covers a cost assessment of the various 
options. In Chapter 0, the main conclusions are drawn. 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
Assessment of HDV monitoring 

options 

Introduction 

In this chapter, the available options for future monitoring of HDV’s are 
inventoried and discussed. The current practice of registration and monitoring 
of N1 vehicles is an appropriate case of reference, since vans are already 
monitored on an individual bases using their vehicle identification number. 
Therefore, the chapter starts with an overview of N1 registration and 
monitoring. Subsequently, the monitoring options are inventoried and 
assessed. 

Vans (N1 vehicle) registration and monitoring 

New vehicle registration data is the main source of information for  
N1 monitoring in EU countries. Such registration and consequently  
N1 monitoring procedures are not uniform across Europe. They differ 
significantly. The two main variables are:  
  national registration procedures;  
sources of monitoring data.  
 

National registration procedures 

Most countries use centralised registration. In the Netherlands, for example, 
N1 vehicles are centrally registered by the Dutch RDW registration authority, 
which also performs the monitoring activities on behalf of the Dutch 
government. It forwards the data to the European Environment Agency (EEA). 

Germany and Greece are examples of countries that work with a system of 
local registration, while centralised authorities (e.g. German KBA) are 
responsible for the transfer of data to the EEA. These countries have more 
complex systems of N1 monitoring and reporting, which are more labour 
intensive. In Germany, for example, the type approval (TA) database is used 
for enriching the registration data, e.g. adding wheel base data to this 
database. 

Which national authority is responsible for N1 monitoring differs among 
countries. In most countries the registration authority solely performs the 
reporting of data to the EEA, but in several countries various organisations are 
involved. In Greece for instance, the TAA is responsible for aggregating the 
locally registered data. 

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N1 vehicle monitoring 

Since 2012, N1 vehicle CO2 data has been monitored. Information that must be 
provided for each new van that is registered in the EU includes:  
  VIN number of vehicle (since 2014 data only, reported both by Member 

type approval number; 
type, variant, version, make, commercial name; 
specific emissions of CO2; 

States and OEMs7); 
  manufacturer name; 
 
 
 
  mass of the vehicle, wheel base, track width; 
 
  engine power; 
  engine capacity; 
  electric energy consumption; 
 

fuel type and fuel mode; 

innovative technology(ies) and emissions reductions through innovation 
technology(ies). 

Regulation (EC) No 510/2011 requires Member States to record the above 
information of each new van registered within its territory. Member States 
yearly submit all information related to their new registrations to the 
Commission. Since 2014 OEMs must also submit the VINs for the vehicles sold 
and/or for which warranties were issued for the monitoring year (whichever is 
the closest in time to the date of registration) including the last three months 
of the previous year. In addition OEMs may submit detailed data. The structure 
of this monitoring system is as follows: 
1.  Member States record information for each new van registered in their 
territory and transmit this information to the Commission. Data are 
submitted to the Central Data Repository (CDR) managed by the EEA 
(http://cdr.eionet.europa.eu/). At the same time manufacturers submit a 
list of VINs and possibly detailed data (see above) to the EEA's Business 
Data Repository (BDR, https://bdr.eionet.europa.eu/). 

2.  The EEA performs several quality checks in order to evaluate the quality of 
the submitted data. VIN matching is used for gap filling and to identify 
base vehicle manufacturers in case of multi stage vehicles. Based on the 
checks and feedbacks received from Member States, the EEA finalises and 
publishes the provisional database. At the same time, the Commission 
notifies the manufacturers of their provisional CO2 performance. 

3.  Manufacturers can, within three months of being notified of the provisional 
calculation, notify the Commission of any errors in the data via the BDR. In 
order to facilitate their error notifications manufacturers are informed via 
the BDR about the data records for which matching VINs were submitted. 

4.  The Commission considers the manufacturers’ corrections and confirms or, 
where justified, amends the provisional data for the calculation of the 
manufacturers' final  average specific emissions and specific emissions 
target. The final CO2 performance data and targets are confirmed by the 
Commission through a Commission Implementing Decision which is notified 
to each manufacturer. The final database is published on the EEA website. 

The type approval, registration and monitoring process is illustrated in  
Figure 4. 

7   VINs for the vehicles sold and/or warranties (whichever is the closest in time to the  

date  of  registration)  issued  for  the  monitoring  year 

including the last three months of the previous year. 

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Figure 4 

Overview of N1 vehicle type approval, registration and monitoring  

Note:   This figure describes the most common situation in Member States (MS), where – in most 

cases - registration data is used for monitoring purposes. However, in some MS type 

approval data is (partly) used. The data check, if performed by RA, is not necessarily 

performed between RA and the TAA of the same MS, as TA can be granted in any MS. 

Source of monitoring data 

The documents used for vehicle monitoring also differ among Member States. 
Some countries use registration data for CO2 monitoring, other countries also 
extract data from the type approval (TA) database. Some countries can 
relatively easily combine these data as one organisation performs both type 
approval and monitoring. However, it should be noted that type approval and 
registration do not necessarily take place in the same country. OEMs may ask 
any appointed authority in the EU for type approval. 

In all countries, N1 registration data is stored digitally nowadays, based on 
both type approval data and/or the certificate of conformity (CoC). 
However, some countries still use a manual digitalisation step starting from 
e.g. paper documents or PDF documents. The Nortype process8 is an example 
of such a registration system where data is digitalised by the registration 
authority. Accordingly, data flows and the time required gathering and 
forward the monitoring data differs significantly per country. 

EReg9 digitalisation efforts 

In the context of Directive 2009/443 registration authorities have made 
significant efforts to implement CO2 monitoring in the period 2009-2010.  
At that time, countries did not have a complete registration of the required 
characteristics.  
An EReg (Association of European Vehicle and Driver Registration Authorities) 
topic group has agreed on a definition file (XSD/XML) for CoC data exchange. 
This file, called the initial vehicle information (IVI) file or message10, can be 

8   The  NorType  project  is  a  cooperation  between  Sweden,  Finland,  Norway  and  Iceland,  takes  place  in  Iceland.  The  purpose  of  the  NorType 
project, which started in the beginning of year 2000, is to have a common registration of European Whole Vehicle Type Approval Information, 
and to distribute it to participating countries, over the Internet, through a password protected website or via XML. 

9   Association of European Vehicle and Driver Registration Authorities. 
10  www.ereg-association.eu/documents/subjects.php# 

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RAMSCommission/ EEACDR1Check,preliminarydatabaseOEM2BDR3PublicationPublic database4# registrationsCO2/alltechnicaldata fromCoCRegistrationTAAType approvalData check 
 
 
 
                                                            
used for the purpose of CO2 monitoring. It describes the data exchange on 
individual vehicles. The IVI file can be used for all vehicle classes. See also the 
following textbox. 

CoC data harmonization 

A joint TAAM/EReg Topic Group XII on CoC data exchange and the XML Sub Working Group 

have developed electronic means of data exchange of the CoC information. The CoC 

message file is called IVI message (initial vehicle information) and can also be used for the 

Individual Vehicle Approval vehicles. Primary the message was developed to make it 

possible to exchange the information on the CoC in a harmonized electronic way all over 

Europe. For this purpose the topic group has agreed to the first version of a definition file 

(XSD) on data exchange of CoC data.  

The file describes the data that is exchanged when receiving data from manufacturers or 

manufacturer’s representative on individual vehicles. It consists of a range of attributes 

the importer/manufacturer needs to deliver in a specific order. 

The fields of the EC Individual Vehicle Approval Certificate (IAC) and of 1999/37/EC are 

also in the message to make it possible for the approval authorities to exchange the data 

of an individually approved vehicle. The message contains also optional fields for 

additional technical information.  

The new message was designed to use throughout the European Union. The IVI message 

fits the future European model, which involves all EU Member States using the XSD 

message. 

The predefined IVI file has not been broadly used. Although it facilitates a 
harmonized electronic exchange of information on the CoC all over Europe, 
national specificities in terms of data requirements, e.g. for tax purposes, 
impede broad use. The message also contains optional entry fields for 
additional technical information. The fields of the EC Individual Vehicle 
Approval Certificate (IAC) and of 1999/37/EC are also in the message to allow 
the approval authorities to exchange the data of an individually approved 
vehicle.  

Current practice of heavy-duty vehicle type approval and registration in 

EU Member States 

Registration procedures for heavy-duty vehicles vary significantly among 
EU Member States. This can be explained by differences in organisations and 
responsibilities, but also by the variety of type approval procedures used in 
various countries. Two important characteristics of the HDV type approval and 
registration practices in EU Member States are: 
 
 

type approval procedures; 
rate of digital registrations. 

Type approval procedures for HDV in EU Member States 

HDVs can be type approved by means of three methods: ECWVTA, NSSTA and 
IVA11. Generally, ECWVTA is used for single stage approved truck series 
produced in large numbers, e.g. 4x2 or 6x2 truck types. Multi stage vehicles 
(MSV) are developed for specific purposes. Generally, a base vehicle (normally 

11  ECWVTA, NSSTA and IVA respectively refer to European Community Type Approval, National Small Series Type Approval, and Individual 

Vehicle Approval. 

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a chassis or chassis/cab) is produced and another manufacturer (normally a 
body builder or converter) subsequently finishes the vehicle. 

Directive 2007/46 requires the issuing of a CoC for ECWVTA vehicles, but not 
for individually approved vehicles. The share of individual approvals (IVA) 
varies significantly per country. In Scandinavian countries, it is around  
80-100%, which can be explained by the high share of vehicles with a GVW of  
70-80 tonnes. In most other countries, gross vehicle weights (GVWs) are around 
40 tonnes. For that reason, many vehicles are built in multiple stages and/or 
small series. In Sweden, for example, HDV registrations are based on IVA for 
98.5% of all registrations. In Finland, the number of IVA registrations is around 
80%, corresponding with the high number of MSVs produced in that country.  
In other European countries, the number of individual vehicle approvals cited 
is much less, typically around 20-40%. It means that a larger share of vehicles 
is type approved on the basis of Directive 2007/46 and produced with a CoC. 

One respondent mentioned that the ECWVTA procedure is relatively new and 
that its use is still increasing, thereby reducing the number of IVA 
certifications. Table 2 provides information on the use of type approval 
methods and the share of multistage vehicles, based on interviews. 

Table 2 

Type approval details in various countries 

Member State 

Share IVA/NSS  

Share WVTA  

Share multi stage 

Germany 

Netherlands 

Finland 

Spain 

Sweden 

Croatia 

Denmark 

Italy 

UK 

(no CoC) 

80% 

55% 

1% 

98.5% 

40% 

85% 

20% 

81% 

(CoC) 

20% 

45% 

99% 

1.5% 

60% 

15% 

80% 

9% 

vehicle (no CoC) 

80% 

40% 

80% 

22% 

>80% 

30% 

90% 

40% 

Multi stage vehicles 
Registration of MSVs can be done by importer (our distributor), body builder, 
dealer or customer. This varies depending on the country and business case. 
In order to register, the vehicle needs to have the necessary approval (WVTA, 
NSSTA or IVA). The vehicle manufacturer (either body builder or OEM) is 
responsible for type approval of the vehicle. In a multi-stage approach each 
vehicle manufacturer (OEM or n-stage) is responsible for the ‘parts’ added by 
him. For bus and coach type approval the body builder is often responsible for 
the last stage of the type approval. OEMs usually provide necessary documents 
where appropriate. OEMs state that a high number of bus and truck body 
builders are cooperating with them (typically more than 100 up to 400 per 
OEM). 

Digitalised registrations of HDVs in EU Member States 

These days, registration practices vary significantly across Europe. Both TA 
documents and CoC data (ECWVTA) are used at the moment, depending on the 
approval procedure. The dealer, body builder, distributer or the customer can 
be responsible for providing data to the registration authority (RA).  

Data is delivered in paper or digitally, depending on the requirements of the 
national authority. The OEMs interviewed have all CoC data in digital form. 

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Paper is only used when necessary. Many countries are in a transition phase for 
trucks now. They are moving towards a more digitalised registration 
procedure, after the digitisation of registration and monitoring for light-duty 
vehicles has been finished in recent years. Typically, digital data is sent from 
OEM to importer and from the importer to national authorities. The dealer 
receives the paper version of the CoC from the importer. 

Of all countries interviewed, The Netherlands is the first country where digital 
registration on the basis of the IVI file has been required for complete 
vehicles since 01/2016. In Spain digital registration is in the final stage of 
implementation. However, it is not based on the standardised IVI message,  
but on a nationally developed method, using a combination of information 
documents and CoC. In Sweden, digital registration is possible, but not used. 
The Croatian representative also mentioned that importers/OEMs are reluctant 
to digital registration. Other counties that are running e-CoC pilots are 
Germany and Finland. Implementation years mentioned were 2017-2018.  
In Croatia, a PDF file of the CoC or a standardised Excel file has to be 
submitted to the registration authority. 

As mentioned before, not all vehicles are approved by means of the EC WVTA. 
One challenge of using the e-CoC for digital registration could be the HDVs 
that are type approved via NSS and IVA. Typically, these vehicles do not have a 
CoC. However, the IVI message (initial vehicle information) can also be used 
for Individual Vehicle Approval, which implies that the dataset can be stored 
and issued in the same way as the e-CoC dataset. The format for the IVI 
message was jointly developed by EU countries via EReg (see the textbox in 
Section 0).  

Finalising the standardisation and digitalisation of processes will most likely 
take some more years, since a trend towards standardisation is currently not 
yet visible. In several countries dealers face higher costs due to today’s 
different national demands for registration (e.g. additional documents to 
CoC). Therefore some stakeholders argue in favour of obligatory use of the 
IVI file for registration.  

Table 3 provides an overview of registration options in EU countries. It shows 
the variation in use of digital files, paper files (PDF) and file type. The table 
also illustrates the current situation in which countries are testing the use of 
digital registration, but still allow registration on paper. 

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Table 3 

Rate of digitalised registrations and registration methods allowed in various countries 

Country 

MS uses CoC on 

MS uses CoC 

MS uses other 

Rate of total 

paper for 

registration 

(WVTA) 

XML file for 

registration 

(WVTA) 

Austria 

Croatia 

Czech Republic 

Denmark 

Finland 

France 

Germany 

Greece 

Hungary 

Italy 

Lithuania 

Yes 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes + local 

declaration 

paper 

Yes 

Netherlands 

Only for 

incomplete HDV 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

Yes 

Yes 

Yes 

No 

No 

United Kingdom  Only for 

Yes 

Yes 

Yes 

Yes 

No 

No 

Yes 

No 

No 

Yes 

No 

Yes 

No 

No 

Yes 

Yes 

Yes 

No 

complete 

vehicles, other 

vehicles via 

national IVA 

(than) XML file 

number of 

for registration 

registrations on 

the basis of 

transferred 

digital files 

(from 

interviews) 

Moderate 

Yes, adapted 

No 

No 

Not decided yet, 

Moderate 

system DMR 

No 

Yes (OTC file) 

Yes adapted 

No 

No 

No 

No 

Low 

High 

None 

None 

High 

IVI standard 

High 

designed by EReg 

No 

No 

No 

Yes 

No 

No 

High 

Low 

Low 

Monitoring options for HDVs 

Taking into account the current practice in EU Member States regarding  
N1 monitoring, three main monitoring options have been identified for HDVs. 
Among all options, VECTO data is transferred to the European Environment 
Agency. This data is submitted by either Member States (option 1) or OEMs 
(Options 2 and 3): 
1.  Monitoring responsibility for Member States only: 

b  Only digital file submittal. 
c 

In a number of MS digital & paper data flows (variant). 

2.  Monitoring responsibility for OEMs only: Based on sales data  

(‘self-reporting’). 

3.  Intermediate option (between 1 and 2): designated national authorities 

annually report vehicle identification numbers (‘VINs’) of new registered 
vehicles to the Commission, which is used for the extraction of monitoring 
data from OEMs’ files. 

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For passenger cars and vans, Member States report the registrations and 
technical data to the EC/EEA. A similar monitoring process is defined as first 
option for HDV CO2 monitoring. However, alternatives for data collection exist 
when data as reported by different entities can be combined.  

It is assumed that a rather large number of data points12 will be monitored, 
which are direct inputs and outputs of the VECTO tool.  

Option 1: Member States responsible for reporting to the EC/EEA 

Member States gather HDV CO2 monitoring data from registration authorities 
and type approval authorities in some cases, or mandate these bodies to 
submit monitoring data to EEA. 

This option reflects provisions on vans (as formulated in Regulation (EC)  
NO. 510/2011), that require monitoring and reporting of a defined set of data  
(see Section 0). The data originate both from registration and type approval 
data, or a combination of both. 

For trucks – as for vans - Member States will designate a competent authority 
for the collection and forwarding of the monitoring information, which would 
be the registration authorities in most cases. They will gather the CO2 
monitoring data as part of the vehicle registration process. Only data reported 
in the certification procedures (up to several hundreds of data points) will be 
monitored. 

The activities required for monitoring/reporting of HDV CO2 include the 
following: 

  adaptation of the national vehicle register, if needed; 
  gathering of the monitoring data from the national vehicle register; 
 
  combining national data sets and processing of data by EEA; 
  eventually, fixing of mismatches of data upon comparison of national data and OEM data. 

submission of data to EC/EEA; 

Under the assumption that all VECTO data is available due to the vehicle 
certification, the role of OEMs would be to submit monitoring data to national 
authorities or intermediary persons (such as importers or dealers or body 
builders), during the registration procedure. On top of that, OEMs should 
review the data set compiled by EEA. 

Implementation of this monitoring option will require extra investments, for 
example concerning training staff in all MS. The amount of additional costs will 
depend on the existing expertise and technical system already available in the 
MS. 

The European Commission/EEA will publish a report and a public database 
containing the relevant monitoring data on an aggregate and individual vehicle 
level.  

This option assumes a fully digitalised transfer of data, which makes it easier 
to handle the data flow using predefined structure of input files. Although it 
might be an efficient option, it needs to be verified whether it is feasible in 
view of the heterogeneous situation in Member States with regard to 
digitalisation (see Section 0).  

12  This remains to be decided; the number of data points could be a few to several hundred data points. 

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Sub-option 1b: In a number of MS digital data flows will not be completely 
feasible. Therefore, MS will continue requiring paper or PDF files. 
Member States may have difficulties in processing and implementing changes 
in their registration systems that are needed to transfer digital files to 
EC/EEA. For that reason, this sub-option shows similarities with the current 
monitoring for N1 vehicles, but digitalisation is done by the MS. OEMs provide a 
PDF or alike file to Member States, which is also the data carrier in the HDV 
registration process in many countries. In this option the additional work of 
digitalisation for these MS is taken into account. 

Option 2: OEM responsible for reporting to the EC/EEA 

The responsibility for monitoring lies with the vehicle OEM. Vehicle OEMs 
annually collect and report the required monitoring data of their produced 
vehicles to the EC/EEA, including sales numbers on EU territory. The country 
of registration is not necessarily the country where vehicle and documents are 
sent to from the OEM. Dealers may register it elsewhere and, consequently, 
the OEMs have no reliable information on where vehicles are registered. 

Just as in Option 1, the OEMs make sure that CO2 certification data is available 
to TAAs, but the OEMs would also send the data to the EC/EEA, instead of the 
national authorities. 

Regarding the cost effects of this option, OEMs may be able to perform 
monitoring and reporting tasks more efficiently as they already own the VECTO 
digital input and output files.  

This option may result in an unbalanced record of national developments, 
since OEMs cannot report on the country of vehicle registration, which implies 
that developments on the country level cannot be monitored as sharply as with 
registration data.  

Option 3: Cross-reporting of MS and OEM to the EC/EEA 

This is an intermediate option between Options 1 and 2: designated national 
authorities (national registration authorities most likely) would annually report 
individual HDV vehicle identification numbers (‘VINs’) of new registered 
vehicles to the Commission (or an EU designated agency such as the EEA). 
Based on the latter, the Commission or EEA would extract relevant monitoring 
information from vehicle manufacturers’ data files. As in the two previous 
options the Commission would publish annual average values per vehicle 
type/manufacturer. 

Member States’ perspective 

This section reveals the opinions of Member States and OEMs on the three 
options. Based on the interviews, Member States’ preferences for one of the 
options, technical feasibility and perceived advantages and disadvantages are 
discussed. 

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Option 1: Member States responsible for reporting to the EC/EEA 

Feasibility of digital registration system 
Almost all interviewees reported that it would not be feasible to implement 
the monitoring system if the VECTO data would be submitted on paper or as 
pdf files (Option 1b). They indicate that monitoring can only be done digitally, 
given the large number of data. Registration through paperwork or pdf files 
would imply a too large administrative burden, and a risk of errors. 
This implies that Option 1b is unwanted and unnecessary. It will not be further 
assessed in this report. 

Some Member States proposed to adapt Directive 2007/46 for obligatory 
implementation of digital file transfer, instead of paper, in context of the 
need for harmonization of the digital CoC file (IVI). Some countries even 
stressed that they will only be able to collect and report the requested data if 
this is included in the vehicle e-CoC, since they have started a process to 
implement e-CoCs or have implemented this already. Only very limited 
technical information is currently included in the CoC. The Netherlands is 
frontrunner in the area of digital registration, but also Sweden, Finland and 
Germany currently run pilot projects aimed at using digital CoC files for HDV 
registration within a few years. Some of these countries already register 
vehicles having an e-CoC at small scale, which are mainly whole vehicle type 
approved vehicles. 

Some countries have not started digitalisation programmes. In the 
United Kingdom, dealers manually enter registration data into the national 
registration database. The UK representative indicated that monitoring of a 
limited amount of data (25 data points, as for vans) could be implemented in 
the current registration processes. Monitoring up to 500 data points would not 
be feasible within the current registration system, and would require a 
completely new system that allows the exchange of digital data files between 
OEMs and the UK registration authority.  

Slovakia does not use any form of digital registration for trucks. Although the 
monitoring of N1 vehicles is based on binding XML schemes, no digitalisation 
steps for HDVs are foreseen. Spain and Croatia specifically chose not to 
introduce a registration system based on e-CoC. A mandatory process would 
require a total redefinition of their registration processes. 

Two interviewed representatives are confident that their MS would be able to 
set up a digital registration system within a few years. Four MS also think it is 
feasible, provided that all registration data are included in the e-CoC.  
Two Member States are not planning to introduce a digital registration system 
yet. One of them argues that neither the TAA nor the RA actually has the 
capacity needed to implement the CoC document digitalization process. 
In addition to the technical feasibility of including VECTO data into the 
national registration processes, the following advantages and disadvantages 
for MS monitoring were mentioned by the interviewees (Table 4). 

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Table 4 

Advantages and disadvantages of MS monitoring, mentioned by respondents 

Advantages 

Disadvantages 

  Credibility and consistency of reported 

  Significant additional effort combined 

information. 

  MS are already familiar with the existing 
monitoring process. It harmonises HDV 

with limited resources. 

  The necessity of modifying all the 

processes. 

data sets in MS registers. Mismatches of 

 

Increased possibility of clerical  

data sets are corrected in MS registries 

(or informatical) errors. 

due to their natural relationship with TAA 

that allows checking the data. 

  Development of new data points in the 
registry will be needed – meaning costs 

  Quality check: random check of values. 
We trust the OEMs, but they also know 

and work time. Monitoring will add 

burden to authorities independent of the 

that the values are going to be checked. 

number of HDVs registered. 

  All TA and registration data is in one 

  Construction changes (completion) of 

hand (RDW, KBA), which matches with 

vehicles and installation of 

the current practice and allows use of 

superstructures after OEM production line 

the data for a broad range of purposes. 

(MSV) may cause problems to compare 

  Data are collected from one system,  
that is centralised in the country.  
  Better understanding of CO2 emission 

dispersion across different MS. 

Central EU database 

data sets of OEM and MS.  

Several interviewees indicated that a central EU database would be a helpful instrument of 
reporting and exchanging HDV CO2 monitoring data. Amongst others, all vehicle type 
approval data and registration data in the EU should be added to such a database, 
including the CO2 certification/monitoring data, but also information on traffic violations 
could be added. The type approval authorities would upload their data to this database, 

and the EU monitoring could be easily done on the basis of this database.  

The option of creating such a central database with all registration data/type approval data 

has been considered and is under discussion in the EU for a long time. This option is, at 

least in the short term not feasible, according to some of the interviewees. According to 
the Vehicle Chain report (2014)13 the implementation of a central e-CoC database for 
registration purposes and CO2 monitoring, is specifically mentioned in the context of CO2 
monitoring, and preferred by some registration authorities. 

At the moment, EUCARIS14 is being used as a method for international exchange of data. 
EURARIS allows the exchange of data between national authorities and a central database 

can be seen as an extension of EUCARIS. 

13  The Vehicle Chain in Europe 2014, a survey of vehicle and driving license procedures, EReg, 2014. 
14  EUCARIS  is  the  European  CAR  and  driving  license  Information  System.  EUCARIS  is  a  system  that  provides  opportunities  to  countries  to 
share  their  car  and  driving  licence  registration  information  and/or  other  transport  related  data.  EUCARIS  is  not  a  database  but  an  exchange 
mechanism that connects the Vehicle and Driving Licence Registration Authorities in Europe. www.eucaris.net/  

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Option 2: OEM ‘self-reporting’ to the EC /EEA 

From a technical point of view, OEM reporting was identified as the most 
straightforward option by Member States. There are no technical implications 
for Member States since they have no active role in this scenario. 
Consequently, there is no need for investments. However, in the opinion of the 
majority of the interviewees some control from the Member States is needed.  

During the interviews the following advantages and disadvantages were 
mentioned by the interviewees (Table 5). 

Table 5 

Advantages and disadvantages of OEM self-monitoring, mentioned by respondents  

Advantages 

Disadvantages 

  No need to adapt the national vehicle 

register database (IT). 

  No costs for MS. 
  Less trouble and work for MS. Data shall 
be much more accurate with less risk of 

error. 

  No information about developments on 
Member State level and no easy use of 

data by Member States. 

  Risk of credibility, transparency and 

consistency issues. 

  Validity of data needs to be checked by 
separate surveys regularly without MS 

database. 

  Risk of ‘adjusted’ results, especially in 

case legislation will be implemented. 

  CO2 values are stored only in the 

EC/EEA’s database and additional actions 

are needed if data is used for national 

purposes in some MS. 

There was broad consensus on the fact that this option lacks the opportunity 
to consistently monitor developments at the national level. Therefore Member 
States rather preferred Option 3 over Option 2. 

All but one respondent recognized the risk of credibility, transparency and 
consistency issues for the OEM monitoring option. These MS considered that MS 
should be definitely involved at some stage of the process for transparency 
reasons, by e.g. a mutual cross check of the monitoring data. 

One country, however, does not consider the risk of fraud to be a 
disadvantage, because the TAAs are responsible for a check of the process of 
running the VECTO tool. This would be enough for this purpose, and the 
technical option of using digital signatures by TAAs. If the data is made 
publicly available as much as possible, in such a way that recalculations can be 
made, any wrong numbers will be discovered. 

One MS explicitly argued that OEMs cannot be held responsible for the 
monitoring process: monitoring fundamentally is a task of registration 
authorities, since it concerns newly registered vehicles.  

Option 3: Cross-reporting of MS and OEMs to the EC/EEA 

The registration data (including VIN-number) collected by Member States is 
supplemented by OEM reported monitoring data. On the basis of the  
VIN-numbers the two datasets are combined in order to obtain monitoring data 
on a country level. 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
 
 
 
 
Member States replied that: 
 

this would be rather easy: all the vehicles that are registered are in the 
registration database and the RA would only have to make one extract for 
all registered heavy-duty vehicles; 
this is a much more efficient and precise way of monitoring because there 
are two independent parties involved; 
this is feasible to start without spending any new resources. 

 

 

One respondent indicated that, on the short term, monitoring data could be 
reported by OEMs, while in a later stage, when the use of data for policy 
purpose becomes relevant, Member States could take over the monitoring as 
the credibility of the data becomes more important then. 

The advantages and disadvantages of this option are largely comparable to 
those of OEM monitoring, since the effort for Member States is limited  
(see Table 6). However, in contrary to Option 2, it allows monitoring 
developments at a national level. It should furthermore be noted that this 
option does not take away the disadvantages linked to OEMs forwarding the 
data to EC/EEA directly.  

Table 6 

Advantages and disadvantages of OEM self-monitoring, mentioned by respondents  

Advantages 

Disadvantages 

  No need to adapt the national vehicle 

  Risk of credibility, transparency and 

register database (IT). 

consistency issues. 

  Limited costs for MS. 
  Less trouble and work for MS. Data shall 
be much more accurate with less risk of 

  Validity of data needs to be checked by 
separate surveys regularly without  

MS database. 

error. 

  Risk of ‘adjusted’ results, especially in 
case VECTO data will become a major 

buying criterion by vehicle purchasers.  

  CO2 values are stored only in the 

EC/EEA’s database and additional actions 

are needed if data is to be used for 

national purposes in some MS. 

CO2 data for policy needs 

None of the interviewed Member States indicated that they already have plans 
for the introduction of national policy instruments based on HDV CO2 data. 
Instead, it was indicated that the legislative process should be completed first 
and that the reliability and accuracy of the VECTO simulations should be clear. 
Few Member States representatives stated that OEM self-reporting might be a 
solution for monitoring but that would rule out utilisation of monitored  
CO2 values for policy needs. The monitoring data would not be included in the 
MS registration data on the same level. 

With Option 2, segregation on MS level is not available, and in Option 3 the  
MS segregation is made by matching VIN numbers (delivered by the MS) with 
the monitoring data. If the CO2 monitoring data would need to be used by MS 
for policy purposes, it could be retrieved from the EC/EEA database. 
More than half of the interviewees stated that it would be very likely that 
their Member States would use monitoring data for policy purposes in the 
future. Policy instruments mentioned were purchase subsidies, vehicle taxes 
and road tolls. 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
 
 
Some countries are, however, sceptical about using the VECTO data for policy 
purposes, as too many details are yet not clear enough for national policy 
makers, like the impact of the use of default values for MSVs. One country said 
that the quality of CO2 values will become an important concern, meaning that 
policy makers need to have access to methods and input data. Another country 
stressed that CO2 values simulated by OEM with some default factors behind 
the process may not be representative enough for application in national 
policy instruments. 

OEMs’ perspective 

The interaction with the OEMs was performed in three steps: 
1.  ACEA answered a written questionnaire to the extent that common 

practice and point of views exist at the ACEA members. 

2.  The OEMs were asked more detailed questions in written form. 
3.  The questions under 2) were discussed in detail in oral interviews with 

some OEMs. 

The involvement of ACEA and OEMs in the interview steps is listed in  
Table 7. 

Table 7  

OEMS participating in the interviews 

OEM 

ACEA 

Scania 

Daimler 

DAF 

Volvo 

Step 1 

x 

Step 2 

Step 3 

x 

x 

x 

x 

x 

x 

General aspects 

ACEAs position is that the following aspects should be considered when 
identifying the suitable option for CO2 monitoring and data collection: 
  Avoid double/multiple reporting for vehicle OEMs by: 
submitting data in one system/format only; 
submitting data to one receiver only. 

 
 

  Seek effective and reliable data handling by: 

  use digital data format when submitting data from vehicle OEMs; 
  minimize manual digitalization of data when transferring data at MS,  

to minimize risk of errors. 

OEMs indicate that if the registration including the VECTO data is on paper 
(PDF) this may introduce a lot of mistakes and will create the need to check 
the data reporting of EEA. This is inefficient and not a good option: 
  One OEM said: digitalisation by hand by registration authorities is not an 
option, as it would increase the risk of mistakes. A fully digital data 
transfer is a precondition.  

  Another OEM added: As long as the standardised CoC in digital form exists, 
a separate file for CO2 in XML format is preferred. Adding CO2 information 
in a paper CoC is not reasonable and adds a lot of work. 

  Again another OEM stated that adding CO2 information in a paper CoC is 
not reasonable and adds a lot of work. It would be better if this could be 
an attachment to the current digital CoC. 

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Concerning the use of VECTO results in the certification process, ACEAs 
position is that there is no need to transfer VECTO result files for the specific 
vehicles to TAA. TAA can store information on specific vehicles if multiple/ 
parallel databases to the EEA database are set up for individual vehicles, 
which is normally not the responsibility of type approval authority (other 
specific vehicle information, such as the CoC, is not transferred to TAA). 

According to ACEA Member States could have access to all certificates granted 
for checks at registration by request to the TAA. In the case of CO2, the 
process certificate would ensure that OEMs have procedures in place to 
properly declare CO2 for the vehicles. The VECTO files and specific CO2 data 
values per vehicle will not be included in the CO2 certificate(s), and are 
therefore not relevant for TAA storage. If wanted, the Member States could 
gain access to the specific CO2 values in the EEA database.  

ACEA notes that the responsibility of the vehicle OEM is limited to submitting 
monitoring data on the vehicles they produce, which can be complete or 
incomplete vehicles. A vehicle OEM cannot be made responsible for:  
  Detailed information on when and where the specific vehicles are 

registered. This has to be reported by the Member States.  

  Reporting obligation of other vehicle manufacturers, e.g. an n-stage 

vehicle manufacturer or a completed vehicle or bus. 

  Checking that the information collected at Member State level is correct. 
This responsibility lies with the European Commission or Member States 
itself. 

In all monitoring scenario’s, the Member States have to be responsible for 
collecting information on the number of vehicles registered in each 
Member State. 

Option 1: Member State responsible for reporting to the EC/EEA 
The Options 1 a/b assume fully digitalized transfers of data from OEM. 
However, only a few Member States are currently working with fully digital 
systems. Therefore, ACEA believes that a transfer of data from paper (PDF) 
into a digitalized format will be needed in many Member States. Manual 
digitalization by MS or processing large amounts of data in paper format is not 
desired because results might be less reliable and costs are high.  

Reporting by Member States, such as on the basis of CoC supplied from vehicle 
OEMs, is only suitable for monitoring a few parameters per vehicle and limited 
to vehicles which are registered by ECWVTA. ACEA considers such a scheme 
not to be optimal for HDV monitoring, taking into account the special 
conditions that apply to trucks and busses/coaches: 
  The CO2 results for HDV are expected to be more extensive than a few 
parameters, and more extensive than those of passenger cars and vans. 

  Part of the registrations takes place without ECWVTA/CoC (for some 

countries ECWVTA is basically non-existing). Therefore, another additional 
format to the CoC would be needed to cover these vehicles.  

  To a large extent the vehicle OEMs manufacture incomplete vehicles that 

are completed by a body builder (n-stage vehicle manufacturer). 
These decide what type of vehicle approval is used for registration 
(ECWVTA, small series and individual approval). 

OEMs assume that there is a need to check the data compiled by MS and EEA 
and to provide feedback. In this way any mistake due to the digitalization at 
MS registration can be corrected and changes due to measures at n-stage 
vehicle manufacturer (i.e. addition of axles changing the market segment, 
etc.) can be considered. 

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Table 8 

Advantages and disadvantages of MS reporting, mentioned by ACEA and OEMs 

Advantages 

Disadvantages 

  MS can provide correct information on 
the registered vehicles, such as:  

  The exact numbers of vehicles that 
are registered in the MS and EU per 

year. 

 

Require new or extended formats and 

procedures to be developed by OEMs for 

reporting to MS, both in digitalized and 

paper (PDF) format. Existing CoC 

procedure/format is not sufficient. 

  Which vehicle (VIN) was registered in 
the specific year (OEMs may not know 

 

Require procedures for submitting 

information to all EC Member States, 

in which MS registered the vehicle in 

instead of sending information to one 

many cases). 

receiver as in Option 2. 

 

Information in case it is a special 

 

Digitalisation of a large amount of data 

purpose vehicle that should be 

may be needed at MS, since not all MS 

exempted from monitoring. 

work with digital system today, involving 

the risk of introducing errors, etc. 

 

Additional controls/feed-back required 

by OEM which would need more effort 

when data is distributed over many MS. 

Possibly in addition feedback could be 

required on the data compiled by EEA 

for entire EU. 

 

OEMs may have to report to 28 individual 

Members States, with potentially 28 

specific data requests to accommodate 

National programs. 

Option 2: OEM self-reporting to the EC/EEA 

According to ACEA Option 2 needs no consideration, since a link to national 
registrations is deemed to be crucial. Vehicle OEMs cannot take responsibility 
for correctness of the sales data of complete and incomplete vehicles. 
Therefore OEMs prefer Option 3 above Option 2. 

Option 3: Cross-reporting of MS and OEMs to the EC/EEA 

ACEA notes that the vehicle OEMs’ responsibility is limited to submitting data 
to EEA for the vehicles that are produced for sale in the EU (complete and 
incomplete). This is similar to the comment made on Option 1. 

ACEA provided the following general notes on Option 3: 
  Option 3 is the preferred option for monitoring, provided that it does not 
involve parallel reporting of the monitoring data information to individual 
MS or TAA. 
If separate reporting to MS/TAA is required in parallel, the advantages of 
Option 3 are partly eliminated, since it would require most of the activities 
listed under Option 1. 

 

  ACEA suggests to consider consequences in case of a future inclusion of 
bodybuilder as vehicle OEM (e.g. for busses). A standardized and simple 
format is thus needed.  

Table 9 lists the advantages and disadvantages of Option 3 according to ACEA. 
MS shall annually provide information to EEA on when and where the specific 
vehicles are registered. Compiling the information from OEMs and MS shall be 
done in the database using the VIN number or by using the chassis number (last 

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digits of VIN) combined with the first manufacturer (in case the VIN is changed 
for MSV, which can be the case e.g. at bus builders). 

Table 9 

Advantages and disadvantages of OEM self-reporting according to Option 3, mentioned by  
ACEA and OEMs 

Advantages 

Disadvantages 

  Simple, consistent and efficient way for 
vehicle OEMs to provide monitoring data 

  MS may not have access to the CO2 results 
at the moment of registration, depending 

by submitting monitoring information to 

on the lead times for OEM reporting to 

one receiver (e.g. an ftp server). 

EEA, and/or the efficiency of EEA system 

  Providing digital information directly to 
EEA reduces the risk of error, compared 

(possibilities to instead set up on an 

interface to this retrieve from OEM could 

to manual transfer into a digital format 

be discussed). 

at MS. The additional data needed from 

the MS/RA (vehicle registered) should be 

simple to transfer to EEA. 

  Reporting could be done at certain 
intervals, not necessary and not 

manageable to send one report per 

vehicle to EEA already before 

registration.  

  MS could get access to relevant parts of 
the EEA database for their monitoring 

purposes, instead of developing own 

separate databases. 

  EEA would have the data necessary for an 
efficient control of MS data vs. OEM data. 

When VECTO data files are directly provided by OEMs to a central database  
(as in Option 3), default MSV CO2 values can also be included in the monitoring 
system without special efforts from n-stage manufacturers. Due to different 
bodies (box, tippers, tank, etc.), the CO2 data provided by VECTO for the 
generic norm bodies and trailers is not representing the absolute levels for all 
trucks correctly but may be a good indicator for the HDV efficiency.  

The fact that many HDVs will not be equipped with the standard bodies and 
trailers in real operation is an issue for all HDVs (truck-trailer e.g.), not just 
for MSVs. How to deal with other possible changes at MSVs (e.g. adding axles 
and thus changing the vehicle class allocation) is also an open issue that 
requires further discussions.  

Conclusion 

Monitoring options 
Taking into account the current practice in EU Member States regarding  
N1 monitoring, three main monitoring options have been identified for HDVs, 
with two variants for Option 1. Under all options, VECTO data is transferred to 
the European Environment Agency, but under Option 1 this data is submitted 
by Member States and under Options 2 and 3 the data is submitted by OEMs: 
1.  Monitoring responsibility for Member States only: 

a  Only digital file submittal. 
b 

In a number of MS digital & paper data flows (variant). 

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2.  Monitoring responsibility for OEMs only: based on sales data  

(‘self-reporting’). 

3.  Intermediate option between 1 and 2: designated national authorities 

annually report vehicle identification numbers (‘VINs’) of new registered 
vehicles to the Commission, which is used for the extraction of monitoring 
data from OEMs’ files. 

Method of data transfer 
HDV CO2 monitoring means that OEMs transfer VECTO data to the reporting 
authority. This can be done in various ways: 
  as part of an extended vehicle CoC or type approval document (PDF) used 

for registration (Option 1); 

  as part of a standardised XML file (IVI message file) that can replace the 

current CoC and type approval documents (Option 1); 

  as an additional file (XML) that can either be added to the current 

registration documents (Option 1) or can be handed over directly by OEMs 
to European authorities (Option 2/3).  

The use of paper documents would be expensive, as illustrated by TNO (2015), 
and it is not supported by Member States or OEMs. Therefore, this method is 
not analysed in this report. 

The digitization of registration processes is ongoing in many countries, but the 
degree of digitalisation varies and digitalisation processes are not harmonized. 
From a technical point of view it would be possible to use the IVI message file 
that is developed by EReg. However, current digitalisation efforts are hardly 
based on this file. It is therefore unrealistic to assume that the registration 
process will be based on an extended IVI message file. It is rather expected 
that HDV CO2 registration will occur: 
  By the use of one harmonized XML file. 
  Or by amendment and expansion of the existing and upcoming digital 

national registration processes. This would imply that OEMs and national 
registration authorities have to agree on the file structure. 

Member States and OEMs’ perspectives 
Interviewed representatives from Member States rejected the use of paper or 
pdf files for the transfer of VECTO results to registration authorities because it 
would require too much work to enter the data in a digital system.  

Of the twelve Member States, six countries favoured Option 3, four countries 
preferred Option 1 and two countries expressed no preference. The most 
important argument for Option 3 is that it will put less burden on MS and 
requires no additional investments in IT systems (vehicle registration).  
The main argument made in favour of MS monitoring was related to data 
credibility and reliability, and parallels with the light-duty vehicle monitoring 
that is currently performed by Member States. 

According to OEMs, information from VECTO on CO2 should be processed in 
standardised electronic formats (XML) directly. It needs to be compatible with 
database systems. It is, however, unlikely that Member States will have 
introduced sufficient harmonized electronic data handling and registration 
procedures before 2018. This implies that OEMs would need to send the files to 
each of the national registration authorities instead. There is a risk of creating 
deviating data formats, which is already the case with digital registration. 

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Since Option 1 creates a high burden on OEMs, they prefer Option 3. OEMs do 
not necessarily know in which country vehicles are registered when the VECTO 
CO2 results are produced on the production line.  
This means that a link of CO2 data to vehicle registration is crucial to ensure a 
good quality of data and to allow a MS related monitoring.  

Multi stage vehicles 
When VECTO data files are directly added by OEMs to a central EU database 
(Option 2/3), MSV CO2 values (representing approximately 40% of the market) 
can also be included in the monitoring system if default values are used.  
CO2 data provided by VECTO only covers generic norm bodies and trailers. 
It will not represent the absolute CO2 levels for all trucks correctly, due to 
different bodies (box, tippers, tank, etc.).  

In case of Option 1, inclusion of MSVs can only be done if n-stage 
manufacturers are required to register MSVs along with the VECTO data. 
This may result in a significant additional administrative burden, since these 
companies are often small and medium sized companies. 

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Assessment of monitoring 

activities and costs 

Introduction 

In this chapter the costs of monitoring HDV CO2 emissions are estimated in 
terms of required investments and amount of labour needed. Monitoring costs 
are defined as costs on top of certification. This means that costs until the 
stage of vehicle registration are excluded from the analysis. For example, 
costs of VECTO data storage are not regarded as a monitoring cost, since data 
storage is required for certification purposes. 

The costs for Member States, OEMs and EEA (assuming the EEA shall be the EU 
agency in charge of this) are quantified. In case second stage certification is 
needed, second stage builders might also face costs of transferring the VECTO 
data (forwarded to them by OEMs). These costs are not quantified as the use 
default data is decided as the solution for the first period. 

Since data transfer on paper is perceived as unrealistic by stakeholders, this 
option – while discussed previously - is not further assessed. Therefore, only 
the three main options will be considered. 

Firstly, the cost assessment methodology is explained. Then the costs of each 
monitoring option are estimated, per actor and in total.  

Definition of cost methodology 

The monitoring costs will be estimated for the major actors, being Member 
States, OEMs and EEA. Three monitoring options are taken into account: 
  Option 1: MS responsible for reporting to EC/EEA, various registration 

procedures in Europe; harmonised VECTO output in separate file or added 
to IVI file. 

  Option 2: OEM responsible, self-reporting to EC/EEA. 
  Option 3: Cross-reporting of OEM and MS to EC/EEA. 

Figure 5 shows the major activities of MS, OEMs and EEA. The costs of those 
activities will be estimated. 

Figure 5 

Overview of the main activities of the three options 

---- = data check. 

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OEMMS registrationEEA database OEMEEA database MS reportingOEM reportingOEMEEA databaseMSCross reporting 
 
 
 
 
 
 
Description of activities 

Option 1 
HDV CO2 monitoring data is forwarded as part of the registration data by or on 
behalf of OEMs to national registration authorities. Every year, Member States 
select the CO2 monitoring data from their registration data and forward the 
data to EEA, using an extension of the system that is already in use for the 
CO2 monitoring of van and passenger car. EEA processes the data and creates a 
publicly accessible database.  

The monitoring activities of Member States consist of three steps: 
1.  Data transfer from each OEM to 28 MS, through the registration of each 
vehicle. The VECTO results are transferred in a predefined file to 
registration authorities as part of vehicle registration data transfer, by 
OEM or a mandated party (importer/dealer), but the registration 
procedure may differ per Member State.  

2.  Member States extract the monitoring data for each individual vehicle 

from their registration databases and forward these data to EEA through 
EEAs data management system. The data is stored in the CDR. 
This procedure is similar to the current process for vans (N1).  

3.  EEA, EC and OEMs correspond on the quality and correctness of the data 

forwarded by EEA. 

It is assumed that if MS still require registration data on pdf/paper, a separate 
digital XML file with the necessary VECTO CO2 data is added to the registration 
files (which is sent, for example per e-mail). This approach would be 
consistent with the view of most Member States. They also indicate that 
attaching a separate file to the registration would be preferred. 

Option 2 
OEMs forward the type approved monitoring data to the EEA on an annual 
basis. EEA processes the data as under Option 1.  

Option 3 
Option 3 is a mix of Options 1 and 2: Member States forward an extract of the 
vehicles registration database to EEA (VIN number) and EEA request the 
relevant CO2 monitoring data from OEMs on the basis of these VIN numbers. 
OEMs forward the data to the EEA as described under Option 2. 

Cost components 

For all three options both one-off transition costs and recurring annual costs 
were assessed as listed in Table 10. All these cost components are quantified in 
the following sections. 

Table 10 

Cost components 

Sub-component description 

Description 

Cost 

component 

Relevant for actor 

under option 

MS 

OEM 

EEA 

Transition costs 

Implementation costs  

The implementation costs are defined as non-technical 

1,3 

1,2,3 

1,2,3 

costs for organising the process, making arrangements 

between actors (between MS and OEM on registration 

procedure, between EEA and MS/OEM on reporting 

format). These costs are non-recurring costs. 

Database development/ 

The technical implementation costs refer to investments 

1 

1,2,3 

IT investments 

in the development of needed databases and additional 

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Cost 

component 

Sub-component description 

Description 

Relevant for actor 

under option 

MS 

OEM 

EEA 

IT requirements. OEMs database costs are defined as 

certification costs and therefore not taken into account. 

These costs are non-recurring costs. 

Annual costs 

Technical maintenance &  

Data management costs concern the technical 

1,3 

1,2,3 

IT costs  

maintenance costs for IT systems and databases. These 

only apply when IT systems are in use for the sole 

purpose of HDV monitoring. OEMs database costs are 

defined as certification costs and therefore not taken 

into account. The data management costs are estimated 

at 10% of the technical investments. 

VECTO data transfer costs 

VECTO data transfer costs apply only to monitoring 

1 

1 

option 1. In this option, not all Member States use a 

fully digitalised registration system, and additional costs 

will occur when registration procedure is extended for 

the sole purpose of HDV monitoring. This is the case for 

all registrations for the OEM and only for non-digitalised 

registrations for Member States. 

Reporting costs 

Reporting costs are defined as costs of transfer of data 

1,3 

1,2,3 

1,2,3 

to EEA and management by EEA. These costs refer to 

the effort made by the responsible entity (MS in Option 

1, OEM in Option 2 and both in Option 3) to perform the 

annual reporting. In case of EEA, this cost components 

represents the processing of the received datasets.  

Costs for making checks, 

EEA and EC will perform several quality checks in order 

1,3 

1,2,3 

1,2,3 

answering questions 

to evaluate the accuracy and the quality of the 

datasets. On the basis of the checks and the feedbacks 

from the responsible entity(ies) a preliminary database 

is published. Depending on the quality control system in 

each monitoring option, various actors will be able to 

give feedback on the datasets and notify the 

Commission of any errors in the data. The feedback is 

assessed and, when justified, taken into account for the 

final database. 

Methodological notes 

The transition costs are annualised by using the annuity method, a discount 
rate of 4%, in accordance with the impact assessment guidelines (EC, 2009)15, 
and a 10 year depreciation period. The estimation of labour costs is based on 
an hourly rate of € 30/hour, which equals cost of € 60,000 for one working 
year. This value is deemed to be representative for experts representing the 
Member States, OEMs and EU institutions. The figure includes social charges 
and costs for pension (25%). 

Costs per actor 

Three major actors have been identified above, being Member States, OEMs 
and EEA. The EC is also involved in the last stage of quality checks. For each of 
these actors a detailed cost assessment is performed. 

15  European Commission, Impact Assessment guidelines, SEC(2009) 92, 15 January 2009. 

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Member States 

The costs for Member States differ strongly. Some Member States already have 
an advanced system of digitalised registration and are using or preparing the 
electronic CoC, while others (partly) use paperwork.  

Analysis has been made for two groups: interviewed Member States and  
non-interviewed Member States. Most data was obtained via the interviews.  

Option 1 – Interviewed Member States 
For 13 MS both the transition costs and the annual costs are estimated on the 
basis of interviews (twelve countries) and the report on CO2 data monitoring 
by EReg (2011)16 on the costs of the current monitoring system for M1+N1 
vehicles (Belgium). This group of Member States includes the four Member 
States with the highest number of registrations of HDV, and is displayed in red 
colour in Figure 6. 

Figure 6 

Method of cost estimation per Member State as function of number of registrations 

Source: (ACEA, 2011). 

16  EReg Topic Group IX on CO2 Data Monitoring, final report, 07 April 2011. 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
                                                            
The total annual costs for Member states can be divided into the following cost 
components: 
  Transition costs: 

  database investment and development costs, summarised in 0; 
 

implementation cost, € 16,500 per Member State for communication 
and aligning with OEMs on the needed registration format have been 
estimated; 
technical maintenance & IT costs, which are 10% of the technical 
implementation costs. 

 

  Annual costs: 

  VECTO data transfer costs; 
  annual costs for reporting and data checks, summarised in 0. 

Figure 7 presents the total annual costs for monitoring Option 1. Member States 
mentioned a broad range of costs, representing the variation in the current 
registration practice and the number of actors involved in the monitoring of 
M1 and N1 vehicles. Transition costs range from 0 to € 100,000 and annual 
costs range from € 1,500 to € 80,000. 

Figure 7 

Annualised total costs for interviewed Member States of Option 1 

Note:   Germany, France, UK, Spain, Netherlands, Sweden, Slovakia, Denmark, Belgium Finland, 

Croatia and Greece are on the low/left of the axis. See Figure 6. 

Non-interviewed Member States were grouped into two categories based on 
the degree of digitisation. 

Option 1 – Non-interviewed Member States 
Due to lack of data, for fifteen Member States a cost estimation must be made 
on the basis of thirteen Member States for which data is available from the 
interviews. The most important conclusions and assumptions are: 
  The database development costs seem to be dependent on the specific 
situation of the Member State, but will probably be in the range of  
€ 45,000-90,000. We have assumed an average € 67,500 per Member State. 

  The VECTO data transfer costs depend on the rate of digitalised 

registrations. If the rate is low, many registrations will be processed via 
PDF files (by e-mail). The VECTO monitoring data will be included as an 
attachment (XML file) and we estimate 5 minutes of extra work for these 

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GermanyFranceSpainUK€0€10,000€20,000€30,000€40,000€50,000€60,000€70,000€80,000€90,000020,00040,00060,00080,000100,000120,000Number of registrations in 2011 of CV (>3.5t) (ACEA 2011)Annualised total costs for MS of HDV monitoring option 1Cost estimations from interviews 
 
 
 
 
 
 
registrations. The rate of digitalised registrations was estimated from 
Table 3 and if unknown, a low rate of digitalisation was assumed.  
In 0 these assumptions are summarised. Calculations are based on 10% (low 
digitisation) and 90% (high digitisation) rates. 

  The annual reporting costs for each MS to EEA were estimated at € 3,500 
per year in accordance with the interview results. Additionally, the 
Member States activities also include answering questions from EEA after 
the OEMs have commented on the provisional data. We estimate that this 
will cost on average 1 working day per OEM for every Member State  
(€ 1,750).  

These assumptions are summarised in Table 11. 

Table 11 

Assumptions that were used for cost estimations of non-interviewed MS 

Cost 

component 

Sub-component description 

Low rate of 

digitalisation 

High rate of 

digitalisation 

Transition 

Implementation costs  

It was assumed that all MS will need € 16,500 

costs 

to implement the new monitoring system 

(non-technical investments).  

Database development/ 

This depends on the specific situation of the 

IT investments 

MS. 

According to interviews in the range of 

€ 50,000-90,000. 

Conclusion for all: € 67,500. 

Annual costs 

Technical maintenance &  

10% of technical implementation costs: 

IT costs 

€ 6,750. 

VECTO data transfer costs 

Depends on rate of 

5 min. per 

digitalisation and 

registration on paper 

number of 

registrations: 

5 min. per 

(via XML 

attachment), 

90% digital 

registration on paper 

registrations. 

(via XML 

attachment), 

10% digital 

registrations. 

Reporting costs: MS to EEA 

Fixed costs of € 3,500 per year 

Costs for making checks, 

1 day of work per OEM on average:  

answering questions: MS to 

€ 1,750 per year. 

EEA and EC 

Option 1 – Annual costs for all MS 
Based on the cost estimations provided in the interviews and the estimations 
for countries that were not interviewed, the total one-off transition costs for 
Member States for Option 1 are € 2.24 million and the annual costs for all 
EU Member States are € 534,000 per year. 

When the transition costs are annualised, the total costs of HDV monitoring 
Option 1 are € 811,000 per year for all Member States. Figure 8 shows this cost 
estimate in relation to the number of registrations. 

38 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
 
Figure 8 

Total annualised costs of monitoring Option 1 for all Member States 

Option 2 and 3 – Annual costs for all MS 
Option 2, in which OEMs will self-report the CO2 monitoring data, implies no 
additional costs for Member States. 

With respect to Option 3, all interviewed Member States indicated that 
extracting data from the registration database (on all registered HDVs in their 
country in one year) was relatively easy. Seven out of twelve countries stated 
that the annual costs are marginal or very small. Other provided cost 
estimates range from a few working days to a maximum of one month.  

Our assumption is that, for all 28 MS, efforts to derive a set of VIN numbers of 
HDVs registered from their database is small and will cost about € 3,500 per 
year. No costs incur for making checks. Also, no transition costs would be 
needed. 

In total, the annual costs of monitoring Option 3 are estimated at € 98,000 for 
all MS per year. 

OEMs 

In the first round of interviews, as illustrated in Table 7, little information on 
the costs of monitoring options was received. It is understandably difficult for 
OEMs to give an estimation, because monitoring actions are completely new to 
them. Therefore, we have sent a memo with a cost estimation for OEMs based 
on the Member State cost methodology to all the OEMs, and offered OEMs the 
opportunity to give feedback on our estimations. Two OEMs did so and their 
feedback was taken into account.  

39 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

GermanyFranceSpainUKPoland€0€10,000€20,000€30,000€40,000€50,000€60,000€70,000€80,000€90,000020,00040,00060,00080,000100,000120,000Number of registrations in 2011 of CV (>3.5t) (ACEA 2011)Annualised total costs for MS of HDV monitoring option 1Cost estimations from interviewsOwn cost estimations 
 
 
 
 
 
 
Option 1: Annual costs for all OEMs 

Transition costs 
A first important step is that each OEM will have to agree with all Member 
States how the registration procedure will be adapted due to the monitoring 
requirements. Setting up such a system would involve high transition costs, 
depending on the rate of standardisation of VECTO data exchange between 
OEMs and MS:  
 

if one standardised XML file can be agreed on, the transition costs would 
be limited and one central working group need to be installed; 
if each Member State requires different file structures from OEMs as part 
of the digital registration, the transition cost would be much higher and 
OEMs would need to negotiate with numerous Member States. 

 

One OEM worries that deviations from the standard XML file for the CO2 
reporting would increase the costs of Option 1. Such deviations could be 
caused by individual Member States if they want to introduce a specific 
requirements for CO2 for the registration in its country, e.g. for the purpose of 
following-up of national targets or taxation scheme, or if they for some 
reason decide they cannot handle the standardized XML format. Therefore 
coordination between Member States will be required. The cost for the initial 
implementation phase is estimated at € 250,000 for each OEM in the latter 
case and at € 125,000 in the first case. Since it is not known which of the two 
situations will occur, we decided to take an average of these two cost figures 
for calculation. 

No additional database development costs/IT investments are needed in this 
scenario, since it was assumed that database development costs are upstream 
certification costs before monitoring takes place. One OEM explained that they 
already have a database with digital versions of the CoC, which may also track 
the additional information required by the various Member States.  

Digital registration in the Netherlands 

An example of the high implementation costs for OEMs is the development of a fully 

digitalised registration system in the Netherlands. This leads to an IT project for each OEM 

and only concerns one country. Such digitalisation projects happen uncoordinated at the 
moment, while a standard e-CoC has been agreed within EReg. To limit costs of CO2 
monitoring, it is important to set up a coordinated development of an agreed VECTO result 

file standard. 

Annual costs 
The annual costs will be high. One OEM indicates that costs will be very high if 
there is no standardisation of CoC and they are required to deliver MS specific 
digital files. Due to different national demands for registration (additional 
documents to CoC) this adds a lot of work and costs. Another OEM mentioned 
that high effort is needed when they have to submit initial VECTO data to  
28 authorities. 

When some MS still require reporting on paper, no extra data transfer system 
is required. A separate digital file will be attached to the existing registration. 
In case the digital VECTO data is sent along with PDF files, this would only add 
an additional data file to be included in an existing data exchange between 
OEM/dealer and registration authority. When we assume an additional extra 
work of 5 min. per vehicle (to include the necessary XML file into the existing 

40 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
 
dataflow towards RA) the annual costs amount to € 75,000-180,000 per year, 
depending on the OEM (assumed is 5 min. per vehicle for € 30/h17). 

After the provisional dataset is constructed by EEA, the OEMs will have the 
opportunity to check the data with their own databases. We estimate that the 
data checking costs are approximately three days per Member State: € 20,000 
per year for each OEM. 

The costs are summarised in Table 12. 

Table 12 

Cost of monitoring Option 1 per OEM 

Cost component 

Sub-component description 

Option 1: Various registration 

procedures in Europe; harmonised 

VECTO output in separate file 

Transition costs 

Implementation costs  

€ 125,000-250,000 

Database development/ 

N/a 

IT investments 

Annual costs 

Data delivery costs: OEM to RA 

€ 75,000-180,000 

depending on the number of 

registrations 

Costs for making checks answering 

€ 20,000 

questions: OEM to EEA 

*   No additional database is needed, as there is already a database in place for certification 

purposes. 

Please note that the data delivery costs may occur at the distributer/dealer. 

Option 2 and 3 – Annual costs for all OEMs 
In these scenario’s, OEMs are responsible for transferring VETCO data to the 
EEA. Option 2 implies that the OEMs are self-reporting without any other data 
flows involved. Option 3 includes cross-reporting from Member States 
(registered vehicles). However, only the costs for MS will differ. For OEMs both 
monitoring options imply the same costs and therefore we do not distinct 
between Option 2 and 3. 

Self-reporting of OEMs requires, according to ACEA, that the production 
records of vehicles produced for the EU market need to be generated and 
periodically distributed. One OEM adds that data need to be submitted to the 
EEA and checked again before publication. This effort is quite limited 
compared to Option 1, in case only one single receiver is defined and VIN 
numbers are used. 

The implementation cost for Option 2 and 3 are based on a simple IT solution, 
were the CO2 data are automatically forwarded to the one entity (the EEA) 
without any additional handling/storage at the OEM. One OEM estimated that 
the implementing cost will be significantly lower than for Option 1.  

The implementation costs are assumed to be similar to those of a medium 
Member State and as estimated to be around € 16,500 if the system is 
comparable to the current N1 monitoring system. 

17  This equals approximately € 60,000 per year and includes social charges, pension and overhead. 

41 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
  
 
 
 
 
 
 
 
                                                            
No database development nor IT investments will be needed as all the 
databases will be present at OEMs. The monitoring options elaborate on the 
VECTO databases of OEMs (which will be developed for certification purposes). 
Therefore, no additional monitoring costs will occur (these should be 
attributed to certification procedures). 

The reporting costs arise when monitoring data for each individual vehicle 
needs to be extracted from their databases and is forwarded to EEA through 
EEAs data management system. This needs to be done once per year.  
OEMs indicated that they would face significantly higher annual reporting costs 
than Member States. This is reasonable as the database per OEM is much larger 
than per MS (on average). Therefore we estimate these costs to be twice as 
high as for Member States: € 7,000. 

The OEMs will receive some feedback from EEA based on the initial datasets,  
if there seem to be errors, or questions regarding the monitoring data. It is 
estimated that the OEMs will need about € 6,750 to process this, which 
corresponds to one day per Member State. 

The costs are summarised in Table 13. 

Table 13 

Cost of monitoring Option 2 and 3 per OEM 

Cost component 

Sub-component description 

2: Self-reporting 

3: Cross-reporting 

Transition costs 

Implementation costs  

Database development/ 

IT investments 

Annual costs 

Reporting costs: OEM to EEA 

Costs for making checks 

answering questions: OEM to 

EEA 

€ 16,500 

N/a 

€ 7,000 

€ 6,750 

€ 16,500 

N/a 

€ 7,000 

€6,750 

EEA and EC 

EEA database development and data processing costs have been estimated on 
the basis of expert insights from the EEA and experience with the current 
monitoring system for N1/M1 vehicles. 

The investment needed for setting up a new monitoring system for HDV will be 
around € 250,000 for EEA, depending on e.g. need to store complex data. 
When the monitoring requirements are clearer, the EEA will be able to make a 
better estimation. The number of data points (up to 500) is not a significant 
factor. One additional staff member (1 FTE) needs to be hired to manage the 
data(base) and correspond with stakeholders. The number of data flows (28 
flows from the MS, or less flows from OEMs) is neither important, according to 
EEA. More important are: the number of registrations and checks that need to 
be made. 

Additionally, the costs for the European Commission are estimated at 0,5 FTE. 

It is estimated that the number of checks and the process of guiding this is not 
so different for the various options, from the perspective of EEA. The costs are 
summarised in Table 14. 

Table 14 

Costs of monitoring options for EEA 

42 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
 
 
 
 
Cost component 

Sub-component description 

Transition costs 

Implementation costs  

Option 1 

€ 250,000 

Option 2 

€ 250,000 

Option 3 

€ 250,000 

Database development/ 

IT investments 

Annual costs 

Data management costs 

EC staff costs 

Reporting costs 

€ 25,000 

€ 30,000 

€ 25,000 

€ 30,000 

€ 25,000 

€ 30,000 

Costs for making checks, asking 

€ 60,000 

€ 60,000 

€ 60,000 

questions 

Total annual 

costs 

€ 145,000 

€ 145,000 

€ 145,000 

Overall costs for the various monitoring options 

The overall costs consist of the sum of costs identified for the various actors in 
the sections above, quantified for 28 Member States and 7 OEMs. Figure 9, Figure 
10 and Figure 11 provide an overview the one-off transition costs, annually 
recurring costs and the total annualised costs. 

Figure 9 

Comprehensive transition costs of monitoring and reporting options 

43 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

€0€500,000€1,000,000€1,500,000€2,000,000€2,500,000€3,000,000€3,500,000€4,000,000Option 1: MSresponsibleOption 2: Selfreporting OEMOption 3: Crossreporting OEMand MSTotal costsTransition costsEEA/ECMember StatesOEM 
 
 
 
 
 
 
 
 
 
 
 
Figure 10  Comprehensive annual costs of monitoring and reporting options 

Figure 11  Comprehensive total annualised costs of monitoring and reporting options 

The figures show that the costs of Option 1 are the highest, representing: 
 

the high transition costs for Member States and the high annual costs as a 
result of the development or adaption of databases and IT systems; 
the high annual costs for OEMs that are linked to the transfer of VECTO 
data to registration authorities. 

 

Monitoring costs are between 1 (option 3) and 5 Euro (option 1) per vehicle 
registered in the EU. 

In Scenario 1, Member States and OEMs bear the largest absolute costs while 
absolute costs are similar for EC/EEA in all options. Total costs are 8 times 
higher in Option 1 than in Option 2 and approx. 5.5 times higher than in 
Option 3. 

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€0€200.000€400.000€600.000€800.000€1.000.000€1.200.000€1.400.000€1.600.000€1.800.000Option 1: MSresponsibleOption 2: Selfreporting OEMOption 3: Crossreporting OEMand MSTotal costsAnnual costsEEA/ECMember StatesOEM€0€500.000€1.000.000€1.500.000€2.000.000€2.500.000Option 1: MSresponsibleOption 2: Selfreporting OEMOption 3: Crossreporting OEMand MSTotal costsTotal annualised costsEEA/ECMember StatesOEM 
 
 
 
 
 
 
 
 
Table 15 illustrates the costs for the various options per actor, used for creating 
the figures above. 

Table 15 

Resulting costs of different monitoring options 

Actor 

Cost component 

Option 1: 

Option 2: 

Option 3: 

MS responsible 

Self-reporting 

Cross-reporting 

OEM 

OEM and MS 

OEMs 

Transition costs 

Annual costs 

Total* 

MS 

Transition costs 

Annual costs 

Total* 

EC/EEA 

Transition costs 

Annual costs 

Total* 

Total* 

Overall 

€ 1,313,000 

€ 901,000 

€ 1,062,000 

€ 2,242,000 

€ 534,000 

€ 811,000 

€ 250,000 

€ 115,000 

€ 146,000 

€ 2,019,000 

€ 116,000 

€ 96,000 

€ 110,000 

€ 0 

€ 0 

€ 0 

€ 250,000 

€ 115,000 

€ 146,000 

€ 256,000 

€ 116,000 

€ 96,000 

€ 110,000 

€ 0 

€ 98,000 

€ 98,000 

€ 250,000 

€ 115,000 

€ 146,000 

€ 354,000 

*   Transition costs were annualised using a discount rate of 4% and a period of 10 years. 

This study builds on the work that was done by TNO et al. (2015)18, which also 
provided a cost estimation on the monitoring and reporting options. 
The monitoring options in the TNO study and this study are not strictly 
comparable. This study does not make a cost assessment for reporting of  
non-digitalised data, comparison can only be made limitedly. 
See 0 for more explanation. 

The conclusions of this study have been presented at a stakeholder meeting in 
Brussels on October 17, 2016, and no major comments were received on the 
cost estimations. 

18  TNO 2015 R10150 Final report, Cost-benefit analysis of options for certification, validation, monitoring and reporting of heavy-duty vehicle 

fuel consumption and CO2 emissions. 

45 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
 
 
                                                            
Conclusions 

Options for monitoring actors 

This report discusses the options for transferring HDV CO2 monitoring data 
produced by OEMs to the European Commission, or an EU designated agency 
(such as EEA). The European Commission will publish a database and annual 
average values per vehicle type/manufacturer. Three basic options have been 
identified: 
  Option 1 is expected to mirror the monitoring procedure that is already 

carried out for light-duty vehicles’ CO2 emissions. Manufacturers report to 
national authorities, most of which are expected to be the national 
registration authorities, and national authorities report to the Commission. 
This means that registration-based data needs to be monitored. 
Subsequently, national registration authorities are a priori designated as 
the main potential national authorities in charge of submitting national 
data to the EU.  

  Option 2 would alternatively put HDV manufacturers in charge of the 

monitoring, with reporting to the Commission. The data that needs to be 
monitored in this case would be annual sales-based data in the possession 
of vehicle manufacturers. 

  Option 3 is an intermediate option between 1 and 2: designated national 
authorities - would annually report to the Commission individual HDV 
vehicle identification numbers (‘VINs’) of new registered vehicles. Based 
on the latter, the Commission or EEA would extract relevant monitoring 
information from vehicle manufacturers' data files. As in the two previous 
options the Commission would publish annual average values per vehicle 
type/manufacturer. 

The options are graphically illustrated in Figure 12. 

Figure 12  Overview of the main activities of the three options 

---- = data check. 

46 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

OEMMS registrationEEA database OEMEEA database MS reportingOEM reportingOEMEEA databaseMSCross reporting 
 
 
 
 
Method of transfer of data 

HDV CO2 monitoring takes place via the transfer of VECTO data (up to 500 data 
points) from OEMs to the reporting authority. It can be done in different ways: 
  as part of the vehicle CoC or type approval document (PDF) used for 

registration (Option 1); 

  as part of the a standardised XML file (IVI message file) that can replace 

the current CoC and type approval documents (Option 1); 

  as an additional file (XML) that can either be added to the current 

registration documents (Option 1) or can be handed over directly by OEMs 
to European authorities (Option 2/3). 

The use of paper documents would be an expensive option as illustrated by 
TNO (2015). It is not supported by both Member States and OEMs and therefore 
not analysed in this report. 

Many countries are digitalising their processes of registration, but the degree 
of digitalisation varies and digitalisation processes are not harmonized. From a 
technical point of view it would be possible to use the IVI message file that is 
developed by EReg. However, current digitalisation efforts are hardly based on 
this file. It is therefore unrealistic to assume that the registration process will 
be based on an extended IVI message file. It is rather expected that HDV  
CO2 registration will occur: 
  By the use of one harmonized XML file. 
  Or by amendment and expansion of the existing and upcoming digital 

national registration processes. This would imply that OEMs and national 
registration authorities have to agree on the file structure. 

Member States’ and OEMs’ perspectives 

Option 3 was favoured by six out of twelve Member States, Option 1 was 
preferred by four Member States and two Member States have no preference. 
The most important argument for Option 3 is that it will put less burden on MS 
and requires no extra investments to IT systems (vehicle registration).  

The main argument made for MS monitoring was related to data credibility and 
parallels to the current light-duty vehicle monitoring, which is also performed 
by Member States. 

According to OEMs, standardised electronic formats (XML) need to be used to 
collect CO2 data from VECTO. They should be compatible with database 
systems. It is, however, unlikely that Member States will have introduced 
sufficiently harmonized electronic data handling and registration procedures 
before 2018. This implies that OEMs would need to send the files to each of 
the national registration authorities, with the risk of deviating data formats. 
This is currently the case with digital registration. 

Option 1 imposes a high burden on OEMs; Option 3 is their unanimously 
preferred solution. Option 2 is rejected since it does not allow monitoring 
national developments. The following arguments were mentioned favouring 
Option 3:  
 
 
 
 

this option allows monitoring of CO2 values on MS level; 
this option reduces the risk of errors; 
reporting could be done using yearly intervals; 
this option could be implemented at lower costs compared to Option 1. 

47 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
 
 
Costs of the monitoring options 

The overall cost estimate consists of the sum of costs identified for the various 
actors and is quantified for 28 Member States and 7 OEMs. Figure 13 provides 
an overview the one-off transition costs, annually recurring costs and the total 
annualised costs. 

Figure 13  Comprehensive total annualised costs of monitoring and reporting options 

Figure 13 shows that the costs of Option 1 are the highest, representing: 
 

the high transition costs for Member States and the high annual costs as a 
result of the development or adaption of databases and IT systems.  
the high annual costs for OEMs that are linked to the transfer of VECTO 
data to registration authorities. 

 

Monitoring costs are between 1 (option 3) and 5 Euro (option 1) per vehicle 
registered in the EU. 

Recommendations 

Since the use of a harmonized file by all national registration authorities would 
reduce the costs of reporting, it makes sense to install a working group were 
EReg members and OEMs agree on the data transfer procedures. This is 
especially relevant in the context of Option 1. 

For Option 2 and 3, we recommend that digital signing of monitoring data at 
the vehicle level is explored. In order to prevent any discussion about the 
credibility of the monitoring data, this data should be ‘secured’ by type 
approval authorities in such a way that EEA can see if the data has been 
changed after securisation by the TAA. Digital signing is already used by the 
Dutch registration authority (exchange of digital CoCs).  

48 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

€0€500.000€1.000.000€1.500.000€2.000.000€2.500.000Option 1: MSresponsibleOption 2: Selfreporting OEMOption 3: Crossreporting OEMand MSTotal costsTotal annualised costsEEA/ECMember StatesOEM 
 
 
 
 
 
 
 
 
Overview of cost estimations for 

MS of Monitoring Option 1 

49 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
Table 16 

Overview of cost estimations for MS of Monitoring Option 1 

MS 

Vehicle 

1: Various registration 

Description 

procedures in Europe; 

harmonised VECTO output in 

separate file or added to IVI 

Croatia 

Denmark 

HDV 

HDV 

file 

Transition 

costs 

€ 0 

Annual  

costs 

€ 4,800  Estimation of transition costs to be negligible based on the interview. Estimation of annual costs based on  

20 working days per year from interview. 

N/a 

€ 12,531  Estimation of transition costs could not be made, and was estimated at € 90,000 in accordance with the 

estimated transition costs of Sweden and Finland. 

Estimation of annual costs are derived from the interview, based on 5-10 working days per year and 80,000 DKR 

for consultants and system adaptions. 

Germany 

HDV 

€ 75,000-

250,000 

€ 60,000  Estimation of transition costs based on estimation from the interview, where € 250k refers to the initial 

implementation of M1 monitoring and € 75k refers to the elaboration of the monitoring system to M1+N1 

monitoring. Transition costs for HDV monitoring depend on the degree of extra activities and IT investments 

needed. 

Estimation of annual costs based on one extra full time employee per year from interview. 

Greece 

N1 

N/a 

€ 15,000  Estimation of transition costs could not be made, and therefore was estimated at € 50,000 in accordance with 

France 

Finland 

Italy 

Netherlands 

Slovakia 

the estimated transition costs in Italy. 

Estimation of annual costs based on 3 person months per year as was stated in the interview to be about  

3 person-months per year (including IT support) for vans. Annual costs for option 3 (cross-reporting) were 

estimated at 1 person-month. 

HDV 

HDV 

HDV 

HDV 

HDV 

€ 45,000 

€ 15,000  Estimation of transition costs based on 1,500 hours estimated in the interview. 

Estimation of annual costs based on 500 hours per year for M1+N1 vehicles from interview. 

€ 100,000 

€ 2,400  Estimation of transition costs of € 100,000 from the interview. 

€ 50,000 

€ 7,200  Transition costs were estimated (based on contact with the ICT provider) at € 50,000. 

Estimation of annual costs based on 10 working days per year from interview. 

Estimation of annual costs based on 30 working days per year from interview, which is an increase of  

1/3 compared to current annual costs for M1+N1 vehicles. 

€ 45,000 

€ 1,500  Estimation of implementation costs based on 1,500 hours from interview. 

Estimation of annual costs based on 50 hours per year from interview. 

N/a 

€ 2,160  Estimation of transition costs could not be made, and therefore was estimated at € 50,000 in accordance with 

the estimated transition costs in Italy. 

Estimation of annual costs based on 4 controls of 1 working day and 1 week reporting per year from interview. 

50 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
MS 

Vehicle 

1: Various registration 

Description 

procedures in Europe; 

harmonised VECTO output in 

separate file or added to IVI 

file 

Transition 

costs 

Annual  

costs 

Spain 

HDV 

€ 87,500 

€ 36,000  The transition costs were estimated at about 75-100 k based on the interview. The registration processes have 

Sweden 

UK 

HDV 

HDV 

to be modified in order to fulfil the information required. 

Estimation of annual costs based on 150 man days per year from interview (which means that 3 people will be 

working for three weeks a year). 

€ 60,000 

€ 6,000  Estimation of implementation costs based on 2,000 hours from interview. 

Estimation of annual costs based on 200 hours per year from interview. 

N/a 

€ 16,474  No estimation was provided on the implementation costs, however in the interview the transition costs for 

M1+N1 vehicles were estimated to be one of the highest in the EU. Therefore we have taken the highest 

transition costs from other interviews: € 100,000. 

Estimation of annual costs based on 1 month per year for statistics and reporting from interview, and a 10% 

increase of work for paper registrations. 

Unfortunately, the estimations could not me affirmed. 

Belgium 

N1 

N/a  

€ 9,000  Estimation of transition costs could not be made, and was estimated at 1,500 hours in accordance with the 

estimated transition costs in the Netherlands, France. 

Estimation of annual costs based on 300 hours per year which was reported in EReg (2011). 

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Rate of digitalised registrations 

The rate of digitalised registration was based on Table 17. 

Table 17 

Rate of digitalised registration (used for cost estimations of MS that were not interviewed) 

Member State 

HDV registrations (ACEA, 2011)  Rate of digitalised registration 

Croatia 

Denmark 

Finland 

France 

Germany 

Greece 

Italy 

Netherlands 

Slovakia 

Spain 

Sweden 

United Kingdom 

Belgium 

Austria 

Bulgaria 

Cyprus 

1,500  Cost estimation from interview 

3,658  Cost estimation from interview 

3,430  Cost estimation from interview 

49,366  Cost estimation from interview 

96,161  Cost estimation from interview 

547  Cost estimation from interview 

20,747  Cost estimation from interview 

12,854  Cost estimation from interview 

3,691  Cost estimation from interview 

16,300  Cost estimation from interview 

6,060  Cost estimation from interview 

41,125  Cost estimation from interview 

10,281  Cost estimation from literature 

7,345  High 

5,000  Unknown (low is assumed) 

200  Unknown (low is assumed) 

Czech Republic 

7,629  High 

Estonia 

Hungary 

Ireland 

Latvia 

Lithuania 

Luxembourg 

Malta 

Poland 

Portugal 

Romania 

Slovenia 

746  Unknown (low is assumed) 

4,301 

Low 

1,497  Unknown (low is assumed) 

1,390  Unknown (low is assumed) 

2,762 

Low 

1,337  Unknown (low is assumed) 

50  Unknown (low is assumed) 

17,105  Unknown (low is assumed) 

2,630  Unknown (low is assumed) 

2,081 

Low 

1,382  High 

Comparison of this study with the TNO 
study 

This study builds on the work that was done by TNO et al. (2015)93, which also 
provided a cost estimation on the monitoring and reporting options. 
The monitoring options in the TNO study were defined as sub-options from the 
baseline, and each sub-option had another focus: 

93  TNO, 2015. R10150 Final report, Cost-benefit analysis of options for certification, validation, monitoring and reporting of heavy-duty vehicle 

fuel consumption and CO2 emissions. 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

 
 
 
 
 
                                                            
1.  Baseline. 
2.  Sub options regarding quantity and subject of data. 
3.  Sub options regarding responsibilities for data collection and reporting. 
4.  Sub options regarding modernisation of the system. 

Since this study does not make a cost assessment for reporting on  
non-digitalised data, comparison can only be made limitedly. We compared 
options M4.1, M3.3 and M3.1 with Option 1, 2 and 3 in this report respectively. 

Table 18 

Comparison between monitoring options in TNO study and this study 

Option 

Comparable option TNO study 

Option 1:  MS responsible, digitalised 

M4.1: Fully digitalised system (paperless via 

reporting 

digital forms), MS responsible. 

Option 2:  OEM responsible 

M3.3: Vehicle OEM self-monitoring  

(non-digital data transfer) 

Option 3:  Ross reporting of MS and OEM 

M3.1: Hybrid monitoring (MS + Vehicle OEM) 

(non-digital data transfer) 

Figure 14  Total annualised costs of HDV monitoring options in both studies 

A fair comparison for Options 2 and 3 and the TNO options is not possible 
because of different assumptions on boundary conditions. The main 
differences are: 
  All options in the TNO study besides option M4.1 and M4.2 assume paper 

data transfer, while in this study we have concluded that paper 
registration of VECTO is not feasible. Therefore the annual costs for OEMs 
in M3.3 and M3.1 and the annual costs for Member States in option M3.1 
are very high in their assessment. 

  For option 1 the transition costs for both OEMs and Member States have 

been estimated higher in this study. The main reasons are the 
implementation costs that were estimated in this study for communication 
and aligning between OEMs and Member States on the registration 
procedures. 

  The annual costs for Member States are similar in both cost assessments. 

53 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs 

€0€1.000.000€2.000.000€3.000.000€4.000.000€5.000.000€6.000.000€7.000.000123M4.1M3.3M3.1This studyTNO studyTotal costsTotal annualised costsEEA/ECMember StatesOEM 
 
 
 
 
 
 
 
  The annual costs for OEMs in Option 1 were estimated to be higher in this 
study. The explanation is that in the TNO study it was assumed that the 
registration would be to a high level automatized, while we have assumed 
a 5 min./vehicle extra work due to VECTO data transfer. 

In conclusion, the monitoring options can hardly be compared with each other 
in a consistent way, mainly because of the different assumptions concerning 
paper registration. For Option 1 a comparison was possible and the costs were 
estimated higher in this study, due to additional work needed for the 
registration of vehicles in monitoring Option 1. 

54 

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4.G09 – Monitoring heavy-duty vehicles’ CO2 emissions and their costs