REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the effects of the Euro 5 Environmental Step for L-category vehicles
Date: 2018-03-19
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: European standard, approval, cost-effectiveness analysis, environmental impact, environmental standard, motor vehicle, motor vehicle pollution, technical standard, two-wheeled vehicle, vehicle parts

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.3.2018 COM(2018) 136 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the effects of the Euro 5 Environmental Step for L-category vehicles  
 
 
1.  INTRODUCTION 

Regulation (EU) No 168/20131 sets out Euro 4 and Euro 5 emission limits and the associated 
technical requirements and test procedures with respect to the Euro 5 step, to provide vehicle 
manufacturers  and  the  supplier  industry  with  long-term  planning  predictability2.  Together 
with its four delegated and implementing acts3 it forms a comprehensive package of measures 
for the safety, emissions control and placing on the market of such vehicles.  

Annex IV to  the Regulation  sets  the timetable for the introduction  of the different tests and 
other  technical  requirements  in  respect  of  type-approval.  Thus  the  Euro  4  emission  limits 
were introduced for new vehicles of certain subcategories on 1 January 2016 but it was only 
on 1 January 2017 that these limits became mandatory for all new types of vehicles.  

Regarding  the  Euro  5  emission  limits,  the  Regulation  provides  that  they  shall  become 
mandatory for all new types of vehicles of all sub-categories as of 1 January 2020. 

In  order  to  underpin  this  two-step  approach,  Article 23(4)  of  the  Regulation  requires  the 
Commission to conduct an environmental effect study through modelling, technical feasibility 
and cost-effectiveness analysis based on the latest available data. 

The objective of this study, as pointed out by the above-mentioned Article, is to evaluate and 
confirm the feasibility and cost-effectiveness of the Euro 5 emission limits. By gathering and 
analysing  the  latest  available  data  and  research  findings,  the  study  should  substantiate  the 
adoption  of  further  policy  measures  which  would  amend  and  complement  the  existing 
framework. Hence, Article 23(4) clearly defines the scope of the environmental effect study.  

1  Regulation  (EU)  No 168/2013  of  the  European  Parliament  and  of  the  Council  of  15  January  2013  on  the 
approval  and  market  surveillance  of  two-  or  three-wheel  vehicles  and  quadricycles  (OJ  L  60,  2.3.2013, 
p. 52). 

2  The  provisions  on  the  Euro  4  step  were  based  on,  and  justified  in  detail  by,  a  Commission  impact 

assessment (SEC(2010) 1152).  

3   Commission  Delegated  Regulation  (EU)  No  134/2014  of  16  December  2013  supplementing  Regulation 
(EU)  No  168/2013  of  the  European  Parliament  and  of  the  Council  with  regard  to  environmental  and 
propulsion unit performance requirements and amending Annex V thereof (OJ L 53, 21.2.2014, p. 1). 

 Commission  Delegated  Regulation  (EU)  No 44/2014  of  21  November  2013  supplementing  Regulation 
(EU) No 168/2013 of  the  European Parliament  and of  the Council  with  regard  to  the  vehicle  construction 
and  general  requirements  for  the  approval  of  two-  or  three-wheel  vehicles  and  quadricycles  (OJ  L  25, 
28.1.2014, p. 1).  

Commission Delegated Regulation (EU) No 3/2014 of 24 October 2013 supplementing Regulation (EU) No 
168/2013  of  the  European  Parliament  and  of  the  Council  with  regard  to  vehicle  functional  safety 
requirements for the approval of two- or three-wheel vehicles and quadricycles ( OJ L 7, 10.1.2014, p. 1–

12) 

Commission Implementing Regulation (EU) No 901/2014 of 18 July 2014 implementing Regulation (EU) 
No 168/2013 of the European Parliament and of the Council with regard to the administrative requirements 
for the approval and market surveillance of two- or three-wheel vehicles and quadricycles Text with EEA 
relevance (OJ L 249, 22.8.2014, p. 1–202) 

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The environmental effect  study was commissioned to  an external consultant  –  a consortium 
led by TNO4 after a call for tenders. The final report of the study was submitted on 18 May 
2017 and approved by the Commission on 20 July 2017. 

Based  on  the  findings  of  this  study  and  pursuant  to  its  obligation  under  Article  23(5),  the 
Commission  is  presenting  the  following  report  to  the  European  Parliament.  It  covers  the 
following aspects:  

  An  analysis  of  the  feasibility  and  cost-effectiveness  of  the  enforcement  dates  of  the 

Euro 5 level; 

  An analysis of the adequacy of the Euro 5 emission limits referred to in Annex VI and 
OBD  threshold  in  Annex  VI  of  the  Regulation  in  light  of  the  most  recent  available 
data; 

  A cost-benefit analysis of the foreseen introduction of OBD stage II at the Euro 5 level 

for (sub) categories L3e, L5e, L6e-A and L7e-A and; 

  A review of the durability mileage for the Euro 5 level referred to in Annex VII (A) 
and the deterioration factors for the Euro 5 limit referred to in Annex VII (B) of this 
Regulation. 

Annex  V  of  Regulation  (EU)  No 168/2013  enumerates  the  eight  test-types  to  which  L-
category vehicles are subjected during type-approval. In the framework of the study, five of 
those  tests  (types  I,  II,  III,  IV  and  VII)  were  carried  out  on  a  large  number  of  L-category 
vehicles  in  different  environments  to  collect  basic  information  on  the  emissions-related 
performance  of  the  vehicles  and  their  individual  components.  The  results  were  used  to 
examine  the  potential  effectiveness  of  different  policy  options,  provide  input  for  the 
modelling approaches adopted in the study and validate the main conclusions reached. 

The  information  thus  obtained  also  formed  the  basis  of  a  dedicated  cost-benefit  analysis 
model to assess the societal costs of policy options within the Euro 5 step and beyond, i.e. to 
help determine whether particular options result in a net benefit or loss to society, in monetary 
terms.  In  the  context  of  the  study,  an  option  generates  a  net  benefit  where  environmental 
savings, converted into monetary terms, exceed investment and implementation costs. 

Overall, the study concluded on a positive cost/benefit assessment of the Euro 5 provisions in 
EU  legislation  and  indicated  good  technical  feasibility  of  the  Euro  5  step.  The  detailed 
conclusions of the study have been published in the report "Effect study of the environmental 
step Euro 5 for L-category vehicles"5. 

On the basis of its findings, the study also outlined possible areas of improvement beyond the 
Euro 5 step, concerning in particular in-service conformity testing, off-cycle emission (OCE) 
requirements  and particle number emissions  limits for certain categories. However a  further 
in-depth study on the feasibility and cost-effectiveness of such measures should be carried out 
before considering translating them into policy instruments.  

4  

 www.tno.nl  

5   https://publications.europa.eu/en/publication-detail/-/publication/f3f268fc-943f-11e7-b92d-

01aa75ed71a1/language-en/format-PDF/source-37961262 

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2.  ASSESSMENT OF THE ENVIRONMENTAL EFFECTS OF EURO 5 

Emissions information was collected using seven test types that are part of the type-approval 
procedure  for  new  L-category  vehicles.  This  section  summarises  the  main  findings  and 
highlights areas in which EU legislation could be improved in the light of these findings. 

2.1. Assessment of the Euro 5 emission limits6 and test procedures  

For the purpose of type-approval the manufacturer needs to show that the vehicles, systems or 
component meet the requirements and test procedure laid down in the Regulations (EU) No 
168/2013 and its four delegated and implanting acts. Several test types have to be performed, 
each concerning a specific requirement (e.g. test type VII deals with CO2 emissions). During 
the  environmental  effect  study  for  the  Euro  5  step,  the  hereafter  mentioned  test  types  were 
evaluated. 

2. 1. 1 Assessment of Type I test- Tailpipe-Emissions after cold start and overall Euro 5 limits  

Test type I was used to assess the suitability of the World harmonised Motorcycle Test Cycle 
(WMTC) for all L-category vehicles, and of the Euro 5 limits as required under Article 23 of 
Regulation (EU) No 168/2013. The WTMC is a system of driving cycles used to measure fuel 
consumption and emissions in motorcycles. It has been developed under the United Nations 
World  Forum  for  Harmonization  of  Vehicle  Regulations  and  has  been  introduced  in 
Regulation (EU) No 168/2013 for the application to the larger motorcycles in a first step, with 
the objective of expanding the use of the WMTC to other L-category vehicles. The extension 
of  the  WMTC  to  other  L-category  vehicles  is  based  on  the  view  that  the  use  of  vehicles  in 
congested  urban  areas  is  better  reflected  in  the  WMTC  than  in  existing  driving  cycles 
therefore one of the objectives of the study was to provide confirmation that this drive cycle 
can indeed be extended to all L-cat vehicles. 

The  results  of  the  study  determined  that  the  WMTC  is  suitable  for  use  for  all  L-category 
vehicles.  It  provides  better  environmental  protection  in  the  course  of  real-world  operations 
than the driving cycles currently used. 

Concerning  the  Euro  5  limits  in  Regulation  (EU)  No 168/2013,  the  study  finds  that  overall 
both  limits  and  associated  dates  for  implementation  are  cost-beneficial  and  technically 
feasible  for  all  L-category  vehicles.  It  appears  that  compliance  with  emissions  limits  will 
depend  on  incremental  technical  improvements  rather  than  engineering  breakthroughs. 
Despite cost increases due to new technology, major environmental benefits stemming from 
the Euro 5 step will lead to a significant overall net monetary benefit, which may collectively 
exceed EUR 330 million between 2020 and 2040. 

In addition, Euro 5 mopeds and motorcycles would be among the cleanest conventional road 
vehicles in urban conditions. 

The study however also points out that due to their specific characteristics and usage there is a 
need for an extended lead time for the three following sub-categories: mini cars (L6e-B), three 
wheel  mopeds  for utility purposes  (L2e-U) and the enduro and trail motorcycles (L3e-AxE; 
L3e-AxT).  

6   Annex VI (A2) to Regulation (EU) No 168/2013. 

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For  mini  cars  and  three  wheel  mopeds  for  utility  purposes,  the  impact  assessment  of  4 
October  2010  carried  out  by  the  Commission  prior  to  the  adoption  of  Regulation  (EU)  No 
168/2013 already outlined their limited market share in proportion to the total L-category fleet 
as  well  as  their  low  average  annual  mileage7.  The  study  report  provided  data  for  2015 
confirming that the market share of mini cars (27 000 vehicles) in comparison to the total L-
category market (1.2 million vehicles) is small, only 2.25%8. In the light of this assessment, 
the  Commission  has  concluded  that  there  has  been  no  significant  evolution  of  the  market 
share  of  the  mini  cars  which  would  change  the  conclusions  of  the  impact  assessment 
conducted in 2010.  

Furthermore,  as  the  original  Impact  assessment  of  2010  had  already  pointed  out,  the 
manufacturers  of  mini  cars  are  SMEs  which  are  often  established  in  regions  lacking  a 
developed industrial network and which have limited resources for R&D. 

Mini cars are mostly equipped with very small, diesel powered compression ignition engines. 
Therefore, it is not certain that these engines can be sufficiently adapted to meet the Euro 5 
emission limits and even if such adaptation was to be proven feasible, the cost would exceed 
the environmental benefits leading to EUR 65 million total damages in monetary terms. 

In  order  to  avoid  such  negative  impact,  the  study  recommended  providing  for  a  transition 
period of four years which would allow the manufacturers of mini cars to channel their R&D 
efforts and investments into the development of alternative technologies covering the Euro 5 
limits. 

After further evaluation of the extension recommended by the study, and taking into account 
on the one hand the Commission's environmental objectives and promotion of clean transport 
and  on  the  other  hand  technical  feasibility  and  competiveness  of  the  industry,  in  particular 
SMEs active in the sector of mini cars, the Commission concluded that two years extra lead 
time  would  be  sufficient  for  the  industry  to  shoulder  obligations  stemming  from  new 
regulatory limits.  

The extra lead time of two years for such vehicles, i.e. to 2022 for new vehicles and 2023 for 
all  vehicles,  would  still  allow  the  manufacturers  of  the  concerned  vehicles  to  develop  new 
(e.g. electric or petrol-hybrid) powertrains and take advantage of the expected drop in the cost 
of  manufacturing  batteries  due  to  increased  global  production.  It  would  also  allow  cities  to 
provide  additional  charging  infrastructure.  The  cost-benefit  analysis  estimated  that  the 
potential net benefits, taking into account the delay in the introduction of the Euro 5 step for 
the above-mentioned categories, would be in the order of EUR 230 million.   

In  the  light  of  the  above  recommendations  by  the  study,  the  Commission  has  come  to  the 
conclusion that pushing back the introduction date of the Euro 5 step for the mini cars by two 
years  would  be  more  cost-beneficial  than  enforcing  it  in  2020  (Base  line).  The  negative 
environmental  impact  caused  by  the  extra  lead  time  granted  to  the  mini  cars  would  be 
counterbalanced  after  the  Euro  5  step  becomes  mandatory  in  2022  as  in  the  meantime  the 
manufacturers would have been able to develop cleaner vehicles.  

7   COM(2010) 542 final, page 73 

8   Effect study of the environmental step Euro 5 for L-category vehicles", section 2.5.2.2, p.54 

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Furthermore,  the  Commission  has  concluded  that  the  introduction  of  the  Euro  5  step  at  the 
foreseen date in 2020 could imply that mini cars may simply disappear from the market. This 
would  entail  negative  economic  and  social  consequences  as  these  vehicles  provide  for  the 
social needs of a group of people not being able to obtain a regular driver licence, e.g. elderly 
and disabled people as well as younger people as an alternative for the mopeds. 

Regarding enduro and trial motorcycles, the study report points out that these vehicles are not 
used  for  regular  commuting  but  mostly  for  leisure  activities  in  both  road  and  off-road 
conditions. They are also used, on average, for only a few hours per year (equivalent of 10-15 
days)  and  have  short  lifetimes  (4-5  years)9.  Hence  the  study  recommends  excluding  these 
vehicles from the requirements of OBD II stage.  

According to data provided by the industry, the market share for enduro and trial motorcycles 
in  2015  represents  around  2.25%  of  the  total  L-category  fleet  which  is  comparable  to  the 
share of mini cars and utility tricycles.  

Considering  both  the  low  mileage  during  the  useful  life  of  enduro  and  trial  motorcycles  as 
well as their limited market share, their contribution to the total pollutant emissions is to be 
seen as marginal. Furthermore, these vehicles have manufacturing processes which are similar 
to those of mini cars. Therefore, since the study recommended providing for an extended lead 
time for the mini cars, the Commission is considering also providing a similar extension for 
the enduro and trial motorcycles. Such a solution would allow for a consistent set of rules to 
be applied to sub-categories which present similar characteristics.  

In  view  of  the  above  and  in  line  with  the  conclusion  regarding  mini  cars,  the  marginal 
negative environmental impact caused by the extra lead time granted to the enduro and trial 
motorcycles would be entirely  counterbalanced after the Euro  5 step becomes  mandatory  in 
2022 as in the meantime the manufacturers would have been able to develop cleaner vehicles.  

As a subtask, the study assessed whether it was appropriate to measure separately the limits 
for  non-methane  hydrocarbons  (NMHCs)  and  total  hydrocarbons  (THCs),  as  currently 
required under Regulation (EU) No 168/2013. It concludes that separate measuring should be 
maintained, as it enables separate reporting on air pollutants and greenhouse gas emissions. 

2. 1. 2 Assessment of Type II test- Tailpipe emissions at (increased) idle and free acceleration 

Regulation  (EU)  No  134/2014  in  its  Annex  III  introduced  a  revised  procedure  to  check 
tailpipe  emissions  at  (increased)  idle  and  free  acceleration,  in  order  to  align  type-approval 
requirements  with  other  vehicle  types  and  be  coherent  with  the  requirements  set  out  in  the 
latest legislation on roadworthiness testing. The appropriateness and smooth implementation 
of the procedure had to be confirmed in this study.  

The  test  in  general  is  easy  to  perform.  However,  the  description  for  setting  the  different 
engine  rotation  speeds  during  the  test,  as  described  in  the  procedure  in  Annex  III  of 
Regulation (EU) No 134/2014 could lead to a misinterpretation by test engineers. The study 
makes specific technical recommendations for improving the description of the test.  

2. 1. 3 Assessment of Type III test- Emissions of crankcase gases  

9   Effect study of the environmental step Euro 5 for L-category vehicles", section 9.9, page 238 

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Test type III (on crankcase gases) of Annex IV of Regulation (EU) No134/2014 verifies that 
engines are constructed so as to prevent fuel, lubrication oil or crankcase gases from escaping 
directly into the atmosphere without being combusted. The study points out that some minor 
adjustments could be made to improve the test procedure currently set out in the Regulation, 
e.g.  adapting  the  sample  bag  used  in  the  procedure  to  the  engine  capacity  The  study 
recommends also to change the order of the currently set out test procedures. This will lead to 
an improvement in the quality of the evolution of the test preformed. The proposed changes 
will not have any effect on the overall cost-benefit. 

2. 1. 4 Assessment of Type IV test - Evaporative emissions test  

The legislation for the Euro 4 step introduced provisions on evaporative emissions and set out 
corresponding  test  procedures  for  certain  L-category  vehicles.  Subsequently,  in  the  Euro  5 
step these requirements are extended to all L-category vehicles. The study evaluated which of 
the  two  available  evaporative  emissions  test  procedures  set  out  in  Annex  V  of  Regulation 
(EU) No 134/2014 (permeation or sealed housing evaporative determination (SHED)) is more 
appropriate and cost-beneficial for the vehicle types that were not already covered in the Euro 
4  step.  It  concludes  that  for  certain  L-category  vehicles10,  the  permeation  test  is  the  better 
option, as it leads to environmental benefits that in this case by far exceed technology costs 
(net monetary benefit for all vehicles will be in the order of EUR 61 million). 

2.  1.  5  Assessment  of  Type  VII  test  -Energy  efficiency  test  (CO2  emissions  fuel  /energy 
consumption and electric range) 

The study reviewed whether the test type VII is appropriate for determining  CO2 emissions, 
fuel  consumption,  and  the  electric  range  for  hybrid  or  fully  electric  vehicles.  The  results 
indicate  that  the  procedures  are  adequate.  It  is  recommended  to  carry  out  a  future  study  on 
hybrid  electric  L-category  vehicles’  CO2  emissions  and  fuel  consumption  as  soon  as  these 
vehicles penetrate the market and more real data becomes available. 

2.2. Assessment of OBD stage II and durability at Euro 5 level 

The study assessed the application of OBD stage II at Euro 5 level for certain sub-categories 
of L-category vehicles (L3e, L5e, L6e-A, L7e-A.). 

The  aim  of  introducing OBD  requirements  for  L-category  vehicles  was  not  only  to  monitor 
the environmental performance and provide the appropriate signals in case of malfunctioning 
of  the  emission  system  to  the  vehicle  owner  via  activation  of  an  indicator  lamp  on  the 
dashboard, but also to support the successful repair of a vehicle by providing authorised and 
independent  repairers  with  access  to  essential  vehicle  information.  The  OBD  stage  I 
requirements involve monitoring electric circuits and electronic failure of the emission control 
system. The update of the requirements with the introduction of OBD stage II as of 2020, as 
foreseen in Article 21 of Regulation (EU) No 168/2013, would allow the detection of serious 
degradation in powertrain and environmental systems and its components. 

The  assessment  covered  several  aspects  of  the  OBD  stage  II  environmental  tests,  assessed 
their technical feasibility and cost-benefit and proposed changes in the monitoring procedure. 

10   L1e, L2e, L5e-B, L6e-B, L7e-B and L7e-C. 

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The Commission agrees with the findings of the study that identifies catalyst monitoring and 
misfire  detection  as  the  two  critical  components  enabling  implementation  of  OBD  stage  II. 
Catalyst monitoring involves monitoring the operation of the catalyst over the lifetime of the 
vehicle.  Misfire  detection  is  important  in  detecting  engine  ignition  malfunctioning.  Misfire 
can  lead  to  higher  emissions  from  the  engine,  which  will  shorten  the  life  of  the  catalyst, 
resulting in higher repair and maintenance costs and an increase in pollution from the vehicle. 

The  study  points  to  the  technical  limitations  of  catalyst  monitoring  for  certain  vehicles  and 
indicates that the technical development required for its implementation is not expected to be 
ready for the first round of Euro 5 implementation, but should be foreseen for 2024.  

For misfire detection, the technology is already available and can be derived from passenger 
car applications. However, it needs to be adjusted to allow efficient monitoring functionality 
for L-category vehicles while at the same time eliminating false misfire detection. The study 
recommends  narrowing  the  window  (bandwidth)  for  misfire  detection  and  making  it  more 
robust  in  order  to  eliminate  as  far  as  possible  the  impact  of  external  factors,  e.g. vibrations 
from the road surface, which could lead to false positives. Taking the recommendations into 
account misfire detection could therefore be implemented as envisaged by 2020. 

As  regards  successful  vehicle  repair,  the  study  confirms  that  OBD  stage  II  would  allow 
catalyst malfunction to be detected even outside periodic environmental technical inspections. 
For  misfire  detection,  trouble  codes  can  provide  useful  information  on  the  source  of  a 
potential technical malfunction, but the study warns that reliable misfire diagnosis is required 
to  avoid costly  troubleshooting by the repair and  maintenance  workshops.  By  following the 
recommendation  made  in  the  study  and  adjusting  the  window  in  which  misfire  should  be 
detected the risk of reporting a false and thus unnecessary trouble could be mitigated.  

The  study  also  assessed  in-use  performance  ratios  (IUPR).  The  aim  of  IUPR  is  to  set 
minimum  monitoring  requirements  in  order  to  ensure  that  the  OBD  system  is  functioning 
correctly.  For  example  an  IUPR  of  0,1  (10%)  means  that  during  at  least  10  %  of  the  total 
duration of every measurable real driving trip ,the important emission control components or 
systems  must  be  monitored.  The  study  finds  that  IUPR  should  be  implemented  gradually 
allowing  for  an  introductory  period  until  2024  to  enable  type-approval  authorities  and 
manufacturers  to  become  familiar  with  the  IUPR  functionality.  The  requirement  should  be 
implemented for new vehicles in 2020 and for all vehicles in 2021 using the current Euro 4, 
OBD  stage  I  emission  thresholds  (OTL  I)11,  combined  with  an  IUPR  ratio  defined  by  the 
manufacturer.  

The  OTL  defines  the  emissions  threshold  limit  which  needs  to  be  achieved  before  a 
malfunction is reported. As of 2024 for new vehicles and 2025 for all vehicles, the minimum 
IUPR ratio as currently foreseen in the Euro 5 step (10%), together with the Euro 5 emission 
threshold  (OTL  II)12  should  be  mandatory.  Consideration  could  be  given  to  applying  more 
stringent  IUPR  limits  in  the  future,  but  a  specific  cost-benefit  study  should  be  carried  out 
beforehand. 

Focusing  on  certain  sub-categories  of  L-category  vehicles,  such  as  enduro  and  trial 
motorcycles,  which  are  very  particular  and  have  a  short  lifetime,  the  study  finds  that  OBD 

11  Euro 4, OBD stage I OBD emission thresholds (Annex VI (B1) to Regulation (EU) No 168/2013). 
12  Euro 5, OBD stage II OBD emission thresholds (Annex VI (B2) to Regulation (EU) No 168/2013). 

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effectiveness  is  questionable.  Therefore,  the  study  recommends  extending  existing  partial 
exemption  from  OBD  II  for  heavy  all  terrain  quadricycles  to  enduro  and  trial  motorcycles, 
which  are  very  similar  to  them  in  nature  and  use.  Furthermore,  considering  that  the 
manufacturers of such  vehicles are mainly  SMEs with  limited means  for R&D expenditure, 
the  costs  that  they  would  have  to  bear  to  comply  with  OBD  II  provisions  would  not  be 
compensated by the environmental benefits as these vehicles have a marginal environmental 
impact as mentioned in paragraph 2.1.1.  

2.3. Durability mileages13 and deterioration factors14 for Euro 5  

The Commission asked for a comparison  between the two cycles used for durability testing 
under the current regulation, namely the Approved Mileage Accumulation (AMA) test cycle 
and  the  Standard  Road  Cycle  for  L-category  vehicles  (SRC-LeCV).  The  purpose  was  to 
determine  which  of  the  two  durability  cycles  is  most  suitable  for  L-category  vehicles  and 
better reflects the deterioration under real driving conditions. The conclusion of the study is 
that the SRC- LeCV is most suitable overall for all L-category vehicles and more in line with 
the world harmonised transient cycle (WMTC) which is used in the type I emission test. The 
SRC-LeCV reflects better the deterioration of the emission performance over the life time of 
the vehicle compared to real driving.  

However, the study also concluded that a complete phasing out of the AMA cycle after 2020 
is not necessary, as this is still useful for vehicles with a moderate and low speed profile, for 
which  it  provides  the  same  accuracy  as  the  SRC-LeCV  and  has  already  been  globally 
accepted  and  used  for many  years.  This  is  why  the  Commission  concludes  that keeping the 
AMA test cycle for these specific vehicles would contribute to maintain the testing costs and 
administrative burden as low as possible by avoiding the need to conduct double testing.  

The Commission acknowledges the conclusions of the study to phase out the AMA test cycle 
only for larger motorcycles and the necessity to introduce minor changes to the SRC-LeCV 
sub-classification  of  vehicles  to  better  define  to  which  subclass  a  vehicle  with  specific 
characteristics (engine size and speed) belongs; this would make the SRC-LeCV more robust.  

The  study  finds  that  the  mathematical  procedure  in  point  (c)  in  Article 23(3)  of  Regulation 
(EU) No 168/2013, whereby vehicles are only tested after 100 km of use, does not reflect the 
real  degradation  of  the  emissions  control  system  of  a  vehicle  during  its  lifetime.  It 
recommends phasing out this method in 2024 and suggests bench ageing15 as a more reliable 
and less costly method than full mileage accumulation. The bench ageing procedure is already 
well  established  and  accepted  as  a  robust  method  for  determining  the  degradation  of 
emissions  control  systems  in  other  motor  vehicles.  With  some  minor  adjustments,  this 
procedure could be implemented by 2020.  

The  study  finds  that  the  ‘useful  life  values’  in  Regulation  (EU)  No 168/2013  are  generally 
appropriate  for  most  vehicle  categories,  but  suggests  revising  the  lifetime  for  mopeds.  It 
considers  the  current  values  for  moped  lifetime  to  be  too  low  and  suggests  conducting  a 
specific data collection survey to gather robust information. It also suggests that it would be 
appropriate to make a proposal for adaptation to future change.  

13   Annex VII (A) to Regulation (EU) No 168/2013. 
14   Annex VII (B) to Regulation (EU) No 168/2013. 
15  The bench ageing procedure is already used for passenger cars; see UNECE Regulation 83. 

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3.  POSSIBLE AREAS FOR IMPROVEMENT BEYOND EURO 5 

On the basis of its findings, the study also outlined possible areas for improvements beyond 
the Euro 5 step. The following subjects are touched upon: Off-cycle emissions requirements; 
In-service conformity testing requirements and Particulate number emission limit for certain 
(sub-) categories. 

3.1.  Off-cycle emission (OCE) requirements 

The study assessed the possibility of implementing OCE testing for L-category vehicles. The 
test results and subsequent analysis led to the following conclusions:  

OCE requirements are expected to be an appropriate measure for ensuring low emissions from 
L-category  vehicles  in  everyday  operation  and  better  reflecting  real  driving  conditions.  The 
anticipated benefits are significant and outweigh the additional costs. The portable emissions 
measuring system (PEMS)16 appears to be the most suitable method for gauging OCEs. Due 
to the wide variety of L-category vehicles, specific requirements will have to be developed for 
different WMTC classes. 

The  study  recommends  compiling  definitive  evidence  of  the  viability  OCE  requirements  in 
order to prepare for their introduction in EU legislation after 2020. 

3.2. In-service conformity testing requirements 

The  study  reviewed  the  need  for  in-service  conformity  testing  requirements.  It  found  that  a 
number  of  vehicles  currently  on  the  market  have  excessively  high  emissions  levels.  The 
conformity factors are in the range  of 1.5 to 25 for CO emission and 0.4 to 1.2 for HC  and 
NOx.  However,  the  study  notes  that  the  majority  of  vehicles  on  the  market  are  approved 
according to Directive 2002/24/EC17 under which the anti-tampering requirements are not as 
stringent  as  under  Regulation  (EU)  No 168/2013,  the  discrepancies  found  exceed  even  the 
emission limits set out in Directive 2002/24/EC.  

The  study  concludes  that  the  introduction  of  in-service  conformity  testing  is  technically 
feasible and may be an effective and cost-beneficial measure to secure proper emissions levels 
from in-use vehicles during their useful life. However, the study recommends assessing in the 
first  place  effectiveness  of  the  measures  taken  in  the  Euro  5  step  before  coming  to  a  final 
conclusion on the need to introduce in-service conformity testing and developing the technical 
details of such procedure.  

3.3. Particulate number emission limit for certain (sub-) categories 

The Euro 5 step introduces the Particulate Matter (hereinafter PM) limits for direct injection 
(DI), positive ignition (PI) and compression ignition (CI), i.e. diesel vehicles, at a level of 4.5 
mg/km, similar to those for passenger cars. The study reviewed these limits and evaluated if 
particle number limit (PN) for L-category vehicles should be introduced. 

16   The existing PEMS equipment needs further development in order to be adapted for use on a larger scale.   

17  Directive  2002/24/EC  of  the  European  Parliament  and  of  the  Council  of  18  March  2002  relating  to  the 
type-approval of two or three-wheel motor vehicles and repealing Council Directive 92/61/EEC (OJ L 124, 
9.5.2002, p. 1). 

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The PM limits introduced by Regulation (EU) 168/2013 for PI, DI and diesel vehicles were 
found to be cost-beneficial. Concerning the possible introduction of a PN limit for L-category 
vehicles,  the  study  concludes  that  a  better  understanding  would  be  needed  of  the  emissions 
performance of such vehicles, when new emissions control technologies become available at 
the Euro 5 step.  

4.  CONCLUSIONS 

Based  on  its  assessment  of  the  study  and  targeted  stakeholders  consultations  it  conducted 
throughout the study's total duration, the Commission draws the following final conclusions:   

1.  The  assessment  generally  indicates  that  the  existing  Euro  5  emission  limits,  dates, 
requirements  and  test  procedures,  set  out  in  Regulation  (EU)  No  168/2013,  are  both 
feasible and cost-effective.  

2.  The introduction date for the Euro 5 step for mini cars (L6e-B), three wheel mopeds 
for  utility  purposes  (L2e-U)  and  the  enduro  and  trail  motorcycles  (L3e-AxE;  L3e-
AxT): the adjustments to the emission control system needed cannot be introduced by 
2020 in a cost-effective way for the engines currently fitted in those vehicles. An extra 
lead  time  of  two  years  should  allow  manufacturers  to  move  away  from  Euro  4 
powertrains  and  introduce  the  Euro  5  step  in  a  cost-beneficial  way  for  these  vehicle 
categories.  

3.  OBD II requirements: there is a need to change the window of misfire detection and to 
extend  the  lead  time  for  the  introduction  of  catalyst  monitoring  to  ensure  accurate 
monitoring of the emission control systems. 

4.  In  Use  Performance  Ratios  (IUPR)  introduced  at  the  Euro  5  step:  IUPR  should  be 
implemented  gradually,  allowing  for  an  introductory  period  to  enable  that  type-
approval authorities and manufacturers become familiar with the IUPR functionality.  

5.  The  mathematical  durability  procedure  for  environmental  performance  requirements 
as set out in Article 23(3)(c) of Regulation No 168/2013: there is a need to phase out 
this  procedure.  The  mathematical  durability  procedure  does  not  reflect  properly  the 
actual deterioration of the environmental performance of a vehicle during its lifetime. 
Under  the  mathematical  approach,  new  vehicles  are  only  driven  for  100  km  during 
which they are tested, which does not reflect the ageing of the emission control device 
over  the  lifetime  of  the  vehicle.  Therefore,  this  method  does  not  guarantee  the 
environmental performance during the entire life of a vehicle. 

6.  The drive cycles  used  for the durability requirements:  a complete phasing out  of the 
AMA  cycle  after  2020  is  not  necessary,  as  this  is  still  useful  for  vehicles  with  a 
moderate and low speed profile, for which it provides the same accuracy as the SRC-
LeCV. Phasing out is therefore only recommended for larger motorcycles. 

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7.  Mileage  accumulation  durability  procedure:  there  is  a  need  to  introduce  a  bench 
ageing procedure as an alternative to full and half mileage accumulation, as required 
in Article 23(3)(a) and 23(3)(b) of Regulation No 168/2013.  

In accordance with Article 23(5) and 23(6) of Regulation (EU) No 168/2013 and the outcome 
of  the  study,  the  Commission  will  consider  making  appropriate  proposals  for  future 
amendments to the type approval legislation. 

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