COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on type-approval requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such vehicles, as regards their general safety and the protection of vehicle occupants and vulnerable road users, amending Regulation (EU) 2018/… and repealing Regulations (EC) No 78/2009, (EC) No 79/2009 and (EC) No 661/2009
Date: 2018-05-17
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: European standard, approval, environmental standard, motor vehicle, pneumatic tyre, road safety, safety device, safety standard, technical standard, transport accident

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.5.2018  SWD(2018) 190 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on type-approval requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such vehicles, as regards their general safety and the protection of vehicle occupants and vulnerable road users, amending Regulation (EU) 2018/… and repealing Regulations (EC) No 78/2009, (EC) No 79/2009 and (EC) No 661/2009 {COM(2018) 286 final} - {SEC(2018) 270 final} - {SWD(2018) 191 final}  
 
 
Table of Contents 

List of abbreviations and glossary of terms ............................................................................... 5 

1. 

Introduction: Political and legal context ............................................................................. 7 

1.1. Political context ............................................................................................................ 7 

1.2. Legal context ................................................................................................................ 8 

1.2.1.  Vehicle safety legislation under the type-approval framework ............................ 9 

1.3. Adapting the legislation to vehicle safety developments ............................................. 9 

1.4. Contribution of vehicle safety legislation to road safety in general .......................... 10 

2.  What is the problem and why is it a problem? .................................................................. 12 

2.1. Traffic accidents in the EU and their effects .............................................................. 12 

2.2. Transformation of main safety problem into vehicle level problems ........................ 16 

2.3. Slow market uptake of new safety features in the vehicle fleet ................................. 18 

2.4. Competitiveness and innovation ................................................................................ 18 

2.5. Efficiency of measures introduced so far ................................................................... 18 

2.6. Market description ..................................................................................................... 19 

2.7. Outdated safety exemptions for SUVs, MPVs, vans and the like .............................. 20 

2.8. Contribution to the reduction of the regulatory burden on companies ...................... 21 

2.9. Main problem drivers and consequences ................................................................... 23 

3.  Why should the EU act? .................................................................................................... 23 

4.  What should be achieved? ................................................................................................. 24 

5.  What are the various options to achieve the objectives? ................................................... 25 

5.1. Measures to completely avoid accidents, to reduce the overall severity of accidents or 
to mitigate the outcome of injuries in accidents between vehicles or vehicles and 
obstacles ........................................................................................................................... 27 

5.1.1.  Frontal impact occurrences ................................................................................. 27 

5.1.2.  Side impact occurrences...................................................................................... 30 

5.1.3.  Rear impact occurrences ..................................................................................... 30 

5.2. Measures to completely avoid accidents, to reduce the overall severity of accidents or 
to mitigate the outcome of injuries that result from impacts between vehicles and 
pedestrians and cyclists .................................................................................................... 31 

5.2.1.  Pedestrian and cyclist protection when hit by front-of-vehicle .......................... 31 

5.2.2.  Pedestrian and cyclist protection when hit by side-of-vehicle ............................ 33 

5.2.3.  Pedestrian and cyclist protection when hit by rear-of-vehicle ............................ 33 

5.3. Policy option “Baseline” ............................................................................................ 34 

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5.4. Policy options “Regulatory approach” to prevent road accidents or to mitigate the 
outcome of accidents ........................................................................................................ 34 

5.4.1.  Design of options and timeframe for implementation ........................................ 35 

5.4.2.  Policy option 1: Generalisation of mature and widely available safety features 36 

5.4.3.  Policy option 2: Introducing widely available and less commonly available 
safety features as standard equipment .............................................................................. 37 

5.4.4.  Policy option 3: Introduction of a full set of safety features boosting innovation

38 

5.5. Options discarded at an early stage ............................................................................ 38 

5.5.1.  Policy option “Self-regulation” ........................................................................... 38 

6.  What are the impacts of the different policy options and who will be affected? .............. 39 

6.1. Social impact .............................................................................................................. 39 

6.2. Environmental impact ................................................................................................ 40 

6.3. Economic impact ........................................................................................................ 40 

6.3.1.  Costs 41 

6.3.2.  Benefits ............................................................................................................... 42 

6.3.3. 

Impact of additional safety measures on vehicle prices and sales prices ............ 43 

6.3.4.  Competitiveness and drivers of innovation ......................................................... 44 

7.  How do the options compare? ........................................................................................... 45 

7.1. Effectiveness .............................................................................................................. 45 

7.1.1.  Effectiveness in achieving the general objective ................................................ 45 

7.1.2.  Effectiveness in achieving the specific objectives .............................................. 46 

7.2. Efficiency and proportionality ................................................................................... 48 

7.3. Coherence ................................................................................................................... 49 

8.  The preferred option .......................................................................................................... 50 

9.  How would actual impacts be monitored and evaluated? ................................................. 53 

Annex 1 – Procedural information ........................................................................................... 55 

1.1. Lead DG, Decide Planning/CWP references ............................................................ 55 

1.2. Organisation and timing ............................................................................................ 55 

1.3. Consultation of the RSB ............................................................................................ 55 

1.4. Evidence, sources and quality ................................................................................... 57 

Annex 2 – Stakeholder consultation ......................................................................................... 59 

2.1. General stakeholder consultations ............................................................................. 59 

2.2. Public consultation .................................................................................................... 61 

Annex 3 – Who is affected by the initiative and how .............................................................. 70 

3.1. Practical implications of the initiative ....................................................................... 70 

2 

 
 
3.2. Summary of costs and benefits .......................................................................................... 72 

3.3. Detailed discussion on road safety problem drivers .................................................. 73 

3.3.1. Slow market uptake of new safety features in the vehicle fleet ............................. 73 

3.3.2. Outdated safety exemptions for SUVs, MPVs, vans and the like .......................... 74 

Annex 4 – Analytical models used in preparing the impact assessment. ................................. 76 

4.1. Description of analytical models used ...................................................................... 76 

4.1.1. PRIMES-TREMOVE transport model ................................................................... 76 

4.1.2. TRL model ............................................................................................................. 77 

4.1.3. COWI model .......................................................................................................... 81 

4.1.4. PRIMES-TREMOVE, TRL and COWI models role in the impact assessment .... 84 

4.2. Baseline scenario ....................................................................................................... 85 

4.2.1. Scenario design, consultation process and quality assurance ................................ 85 

4.2.2. Main assumptions of the Baseline scenario ........................................................... 86 

4.2.3. Summary of main results of the Baseline scenario ................................................ 90 

4.2.4. Baseline scenario – sensitivity analysis ................................................................. 93 

Annex 4.0
implementation of different sets of vehicle safety measures – Review of the General 
Safety and Pedestrian Safety Regulations ........................................................................ 97 

Cost-effectiveness analysis of Policy Options for the mandatory 

Annex 4.1

Annex 4.2

Annex 4.3

Annex 4.4

Annex 4.4.1 

Annex 4.4.2 

Annex 4.4.3 

Annex 4.4.4 

Annex 4.4.5 

Annex 4.4.6 

Annex 4.4.7 

Annex 4.4.8 

Annex 4.4.9 

Annex 4.4.10 

Annex 4.4.11 
numbers 

Annex 4.4.12 

Annex 4.4.13 

Executive summary .................................................................. 97 

Introduction and objectives .................................................... 104 

Policy options and baseline scenario ...................................... 105 

Methodology and input parameters ........................................ 110 

Overview: Calculation model structure .................................. 110 

Evaluation period ................................................................... 113 

Casualty baseline .................................................................... 113 

Vehicle fleet size .................................................................... 116 

Fleet dispersion of safety measures ........................................ 117 

Target population estimates ................................................... 120 

Safety measure effectiveness ................................................. 123 

Avoidance of double-counting of casualties prevented ......... 124 

Monetisation of casualties prevented ..................................... 125 

Safety measure costs .............................................................. 126 

Impact of additional safety measures on vehicle prices and sales 
128 

Discounting of costs and benefits ........................................... 131 

Inflation of monetary values .................................................. 131 

3 

 
 
 
 
 
 
Annex 4.4.14 

Annex 4.4.15 

Annex 4.4.16 

Annex 4.5

Annex 4.5.1 

Annex 4.5.2 

Annex 4.6

Annex 4.7

Annex 4.8

Annex 4.8.1 

Annex 4.8.2 

Annex 4.8.3 

Annex 4.8.4 

Annex 4.8.5 

Annex 4.8.6 

Annex 4.8.7 

Annex 4.9

Annex 4.9.1 

Annex 4.9.2 

Annex 4.9.3 

Annex 4.9.4 

Sensitivity analysis ................................................................. 132 

Data sources and stakeholder validation ................................ 133 

Limitations ............................................................................. 134 

Results .................................................................................... 136 

Cost-effectiveness of policy options ...................................... 136 

Casualties prevented by policy options .................................. 144 

Conclusions ............................................................................ 150 

Bibliography ........................................................................... 151 

Appendices of input values .................................................... 153 

General road casualty trend .................................................... 153 

Layers of proposed and existing safety measures .................. 154 

Vehicle fleet size .................................................................... 157 

Fleet dispersion of safety measures ........................................ 160 

Target population descriptions for accident data extracts ...... 164 

Effectiveness .......................................................................... 167 

Costs ....................................................................................... 175 

Appendices of results ............................................................. 179 

Casualty baseline .................................................................... 179 

Monetary benefits and costs ................................................... 180 

Casualties prevented ............................................................... 186 

Sensitivity analysis ................................................................. 195 

Annex 5 – Flow chart for vehicle groups with focus on the road accident victim’s perspective

203 

Annex 6 – In depth information on various aspects in the main document ........................... 211 

1. Vehicle safety legislation – General Safety Regulation ............................................. 211 

2. Vehicle safety legislation – Pedestrian Safety Regulation ......................................... 212 

3. Impact of additional safety measures on vehicle prices and sales prices ................... 213 

4. Impact of advanced safety measures on driver perception and behaviour ................. 216 

Annex 7 – European Parliament resolution on Commission Report ..................................... 217 

Annex 8 – Member States’ declaration on road safety .......................................................... 227 

Annex 9 – Car industry (ACEA) – extract of position paper and priority list ....................... 233 

Annex 10 – Market analysis ................................................................................................... 242 

Annex 11 – Cooperative, connected and automated mobility (CCAM) ................................ 245 

Annex 12 – List of terms and abbreviations used in the Annexes ......................................... 248 

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LIST OF ABBREVIATIONS AND GLOSSARY OF TERMS 

Term/abbreviation  Explanation 

ACEA 
AEB 
AEB-PCD 
AEB-VEH 

ALC 
BCR 
CARE database 
CARS 21 

C-ITS 
CLEPA 
C-ROADS 
Platform 

DDR-ADR 
DDR-DAD 
DG 
EDR 
ESC 
ESS 
EU 
Euro NCAP 

FFW-137 
FFW-THO 

GSR 
HDV 
HED-MGI 

ISA 
ISA-VOL 
ISO  
LDV 
LDW 
LKA-ELK 

European Automobile Manufacturers’ Association 
Autonomous Emergency Braking 
Autonomous emergency braking for pedestrians and cyclists 
Autonomous emergency braking for driving and still-standing vehicles 
ahead 
Alcohol interlock installation facilitation 
Benefit-to-Cost Ratio 
Community Road Accident Database 
The Competitive Automotive Regulatory System for the 21st century 
High Level Group on the competitiveness and sustainable growth of the 
automotive industry in the EU with representatives of the EU Member 
States, EU institutions, automotive industry, Trade Unions, NGO, users 
and the Commission. 
Cooperative Intelligent Transport Systems 
European Association of Automotive Suppliers 
The C-Roads Platform is a joint initiative of European Member States 
and road operators for testing and implementing C-ITS services in light 
of cross-border harmonisation and interoperability. 
Distraction recognition 
Drowsiness and attention detection 
Directorate-General 
Event (accident) Data Recorder 
Electronic Stability Control 
Emergency Stop Signal 
European Union 
European New Car Assessment Programme is a voluntary European car 
safety performance assessment program backed by the European 
Commission and several European governments, as well as by motoring 
and consumer organisations. Euro NCAP publishes safety reports on new 
cars, awarding ‘star ratings’ based on the performance of the vehicles in 
a variety of crash tests, including front, side and pole impacts, and 
impacts with pedestrians. The top rating is five stars. 
Full-width frontal occupant protection crash test 
Full-width frontal occupant protection crash test with advanced 
measuring dummy and lower appropriate injury criteria thresholds to 
encourage adaptive restraints 
General Safety Regulation 
Heavy Duty Vehicles 
Head impact zone enlargement for pedestrian and cyclist protection (to 
include the windscreen area) 
Intelligent Speed Assistance 
Intelligent Speed Assistance (through non-intrusive haptic feedback) 
International Organisation for Standardisation 
Light Duty Vehicles 
Lane Departure Warning 
Lane Keeping Assist (emergency lane keeping system that intervenes 
only in case of an imminent threat such as leaving the road, or leaving 

5 

 
MPV 
NGO 
PO 
PSI 
PSR 
REV 
R&D 
SAE 
SMEs 
SUV 
T&E 
TFEU 
TNO 
TPM / TPMS 
TRL 

UNECE 
VIS-DET 
VIS-DIV 

the lane with oncoming traffic) 
Multi Purpose Vehicle 
Non-Governmental Organisation 
Policy Option 
Pole Side Impact Occupant Protection 
Pedestrian Safety Regulation 
Reversing Camera or Detection System  
Research and Development 
Society of Automotive Engineers 
Small and Medium-Sized Enterprises 
Sport Utility Vehicle 
European Federation for Transport and Environment 
Treaty on the Functioning of the European Union 
Netherlands Organisation for Applied Scientific Research 
Tyre pressure monitoring (system) 
Formerly the UK Government's Transport Research Laboratory 
subsequently transformed into a private company in 1996 
United Nations Economic Commission for Europe 
Vulnerable road user detection and warning on front and side of vehicle 
Vulnerable road user improved direct vision from driver’s position 

6 

 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1. Political context 

Road safety is a pan-European issue that is addressed through an integrated approach on EU, 
national,  regional  and  local  level.  Policies  are  traditionally  structured  around  three  pillars: 
road users (drivers, pedestrians and cyclists), vehicles and infrastructure. The coordination of 
actions and measures adopted by the different authorities in the various domains (e.g. traffic 
rules  enforcement,  health  care,  education,  improvement  of  infrastructure,  vehicle  type-
approval  and  roadworthiness  inspections)  calls  for  strategic  planning.  Road  safety  policy  is 
best defined and implemented under an overarching strategy that addresses all these aspects. 
Moreover,  road  safety  stakeholders:  road  user  associations,  vehicle  manufacturers  and 
suppliers,  infrastructure  managers,  fleet  operators  and  other  organisations  should  play  an 
active role in ensuring road safety. 

The remarkable progress achieved in the past decades is the result of measures taken in these 
three areas. Today however, as the reduction of road casualties is stagnating, it is even more 
evident  that  further  progress  can  only  be  achieved  by  continued  improvement  across  the 
various  domains,  including  that  of  vehicle  safety.  For  that  reason,  the  present  initiative  to 
significantly  improve  vehicle  safety  performance  has  to  be  viewed  in  close  relation  with 
several other initiatives. Reflections on whether and how the relevant policy areas should be 
amended should be seen as part of the preparation of an EU road safety policy framework for 
the period 2020 – 2030 (to be proposed as part of the Third Mobility Package in May 2018). 
Progress  in  the  reduction  of  road  fatalities  and  serious  injuries  on  EU  roads  has  stalled  in 
recent years, and a revised framework better adapted to this challenge and to  the changes in 
mobility resulting from societal trends (e.g. more cyclists and pedestrians, an aging society) 
and  technological  developments  is  necessary.  The  complex  situation  calls  for  a  dynamic 
policy adjustment that addresses the major challenges in a consistent and effective way across 
the entire spectrum of road safety policies. 

The  framework  should  follow  the  Safe  System  approach.  This  approach  is  based  on  the 
principles that human beings can and will continue to make mistakes and that it is a shared 
responsibility for actors at all levels to ensure that road crashes do not lead to serious or fatal 
injuries.  In  a  safe  system  approach,  the  safety  of  all  parts  of  the  system  must  be  improved; 
roads and roadsides, speeds, vehicles and road use so that if one part of the system fails, other 
parts will still protect the people involved. 

In addition to enhancing vehicle safety features, the foreseen amendment of two directives on 
road infrastructure safety management1 and on minimum safety requirements for tunnels2 also 
aim at contributing to the reduction of the number of fatalities and injuries on EU roads. Thus, 
the named initiatives do not only share a common horizon (in form of the baseline), but they 
also  interlink  as  the  vehicle  technology  needs  to  rely  on  infrastructure  in  order  to  be 
operational (e.g.  visible  road  markings  to  support lane  keeping  assistance  technologies).  On 
the  other  hand,  the  overall  vehicle  and  infrastructure  safety  framework  needs  to  take  into 
account  developments  in  connected  and  automated  driving,  which  are  advancing  at  high 
speed.  Therefore,  the  present  exercise  is  closely  linked  to  Commission's  Strategy  on 

1   Directive 2004/54/EC of the European Parliament and of the Council of 29 April 2004 on minimum safety 

requirements for tunnels in the Trans-European Road Network, OJ L 167, 30.4.2004, p. 39–91 

2   Directive  2008/96/EC  of  the  European  Parliament  and  of  the  Council  of  19  November  2008  on  road 

infrastructure safety management, OJ L 319, 29.11.2008, p. 59–67 

7 

 
                                                 
Cooperative  Intelligent  Transport  Systems  (C-ITS)3  and  in  particular  to  the  upcoming 
proposal  for  a  strategy  for  Cooperative,  Connected  and  Automated  Mobility.  In  order  to 
become  future-proof,  vehicles  not  only  have  to  be  ready  for  the  new  technological 
developments in the infrastructure, but they will also have to take the lead and pave the way 
towards  fully  automated  driving.  For  this  reason,  mandating  advanced  safety  features  for 
vehicles is seen as the right step in this direction.  

Then  there  is  a  third  ongoing  initiative  to  update  legislation  on  qualification  and  periodic 
training  of  drivers4  by  raising  the  standards  for  new  professional  drivers  and  continuously 
updating  their  skills,  including  their  awareness  of  road  safety  risks  and  the  ways  to  reduce 
them. Proper training and education of drivers is particularly valid and important in the light 
of new vehicle safety features becoming available in motor-vehicles.   

Thus, the present initiative is fully in line with the Council conclusions based on the Valletta 
Declaration,  in  which  transport  ministers  reconfirmed  their  commitment  to  improving  road 
safety5 and notably called upon the Commission to enhance the protection of road users, and 
in  particular  vulnerable  road  users,  by  ensuring  the  deployment  of  new  safety  features  for 
vehicles. 

Lastly,  the  proposal  corresponds  to  the  call  made  by  the  EP  Committee  on  Transport  and 
Tourism  in  its  own  initiative  report6  for  resolute  and  determined  action  to  be  taken  by  the 
Commission  in  the  field  of  vehicle  safety.  It  is  observed  that  approximately  95%  of  all 
accidents are due to human error, nearly half of road fatalities involve vulnerable road users 
and  fatalities  among  this  group  are  decreasing  much  slower  than  those  of  other  road  users. 
Therefore,  EP  calls  on  the  Commission  to  mandate  cost-effective  driver  assistance  systems 
significantly  promoting  safety,  which  have  attained  market  maturity,  and  to  consider 
additional  passive  safety  measures  to  mitigate  severe  injurious  effects  of  accidents.  This 
standpoint  has  also  been  voiced  throughout  numerous  Parliamentary  questions7  during  the 
past years. 

1.2. Legal context 

Directive 2007/46/EC8 sets out harmonised safety and environmental requirements that motor 
vehicles have to comply with before being placed on the internal market, thus facilitating the 
free movement of vehicles  and ensuring equal health and safety standards across the EU. It 

3   Communication from the Commission “A European strategy on Cooperative Intelligent Transport Systems, 

a milestone towards cooperative, connected and automated mobility” (COM/2016/0766 final) 

4   Directive  2003/59/EC  of  the  European  Parliament  and  of  the  Council  of  15  July  2003  on  the  initial 
qualification  and  periodic  training  of  drivers  of  certain  road  vehicles  for  the  carriage  of  goods  or 
passengers,  amending  Council  Regulation  (EEC)  No  3820/85  and  Council  Directive  91/439/EEC  and 
repealing Council Directive 76/914/EEC (OJ L 226, 10.9.2003, p. 4) 
http://ec.europa.eu/transport/road_safety/sites/roadsafety/files/valletta_declaration_on_improving_ 
road_safety.pdf 

5 

6   Report on Saving Lives: Boosting Car Safety in the EU – Rapporteur Dieter-Lebrecht Koch 

7  

(2017/2085(INI)) 
E-009286/2015, E-014211/2015, E-014761/2015, E-015519/2015, E-015953/2015, E-000388/2016, E-
001145/2016, E-005715/2016, P-006385/2016, E-007920/2016, E-009592/2016, E-001462/2017, E-
003189/2017, E-004478/2017, E-005145/2017. 

8   Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007 establishing a 
framework for the approval of motor vehicles and their trailers, and of systems, components and separate 
technical units intended for such vehicles (Framework Directive) (Text with EEA relevance), OJ L 263, 
9.10.2007, p. 1 

8 

 
                                                 
provides  a  framework  under  which  a  multitude  of  separate  regulatory  acts  with  specific 
technical requirements for the different types of vehicles are operating.  

The  type-approval  framework  is  in  the  process  of  being  revised.  In  December  2017,  the 
European Parliament and the Council reached an agreement on the proposal for a Regulation 
on  the  approval  and  market  surveillance  of  motor  vehicles  adopted  by  the  Commission  in 
January 20169. 

1.1.1.  Vehicle safety legislation under the type-approval framework 

In  the  context  of  the  type-approval  framework,  the  vehicle  safety  legislation  consists  of  the 
two following regulations: 

The General Safety Regulation (GSR): 

General  vehicle  safety  is  regulated  through  a  single  act,  namely  Regulation  (EC)  No 
661/200910 as adopted by the co-legislator, covering a large number of safety measures. The 
main objectives of the GSR were adding new technologies and safety features to vehicles as 
standard equipment and simplification. 

The Pedestrian Safety Regulation (PSR): 

Regulation  (EC)  No  78/200911  aims  to  protect  pedestrians  and  other  vulnerable  road  users 
involved  in  a  collision  with  a  vehicle.  It  requires  cars,  vans  and  other  light  commercial 
vehicles  to  be  fitted  with  energy  absorbing  bonnets  and  front  bumpers,  to  cushion  the  head 
and  legs  of  a  pedestrian.  It  further  requires  manufacturers  to  fit  so-called  ‘brake  assist 
systems’ into their vehicles, for more efficient panic stops, shaving-off valuable fractions of 
the speed of impact as well as centimetres of stopping distance. 

1.3. Adapting the legislation to vehicle safety developments 

Both12 under the GSR and PSR the Commission has to report to the European Parliament and 
Council on the monitoring of technical developments in the field of enhanced passive safety 
requirements, and the consideration and possible inclusion within the Regulations, of new and 
enhanced  safety  features  as  well  as  enhanced  active  safety  technologies.  To  fulfil  the 
obligations, the Commission Report “Saving Lives: Boosting Car Safety in the EU”13,  14 was 
adopted on 12 December 2016, outlining the possible ways forward to improve vehicle safety 
in the EU. These are captured in this initiative. 

9   COM (2016) 31 final. 
10   Regulation (EC) No 661/2009 of the European Parliament and of the Council of 13 July 2009 concerning 

type-approval requirements for the general safety of motor vehicles, their trailers and systems, components 
and separate technical units intended therefor (Text with EEA relevance), OJ L 200, 31.7.2009, p. 1 
11   Regulation (EC) No 78/2009 of the European Parliament and of the Council of 14 January 2009 on the 
type-approval of motor vehicles with regard to the protection of pedestrians and other vulnerable road 
users, amending Directive 2007/46/EC and repealing Directives 2003/102/EC and 2005/66/EC (Text with 
EEA relevance), OJ L 35, 4.2.2009, p. 1 
12   Article 17 of the GSR and Article 12 of the PSR 
13   Reporting on the monitoring and assessment of advanced vehicle safety features, their cost effectiveness 
and feasibility for the review of the regulations on general vehicle safety and on the protection of 
pedestrians and other vulnerable road users (COM(2016) 787 final) 
14   http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=SWD:2016:431:FIN 

9 

 
                                                 
1.4. Contribution of vehicle safety legislation to road safety in general 

Road safety in the EU has improved significantly over the past decades, thanks to strong and 
effective  action  taken  at  the  EU,  national  and  local  levels  to  address  vehicle  safety,  user 
behaviour, and infrastructure, as part of the EU policy on road safety15. 

In 2003, the Commission adopted its third European action programme for road safety, which 
aimed to halve the number of road deaths by saving 25 000 lives until 2010. While the initial 
target  was  not  quite  met  by  the  end  of  2010,  it  was  decided  to  continue  with  a  target  of 
halving the overall number of road deaths in the EU by 2020, starting from a new baseline in 
201016 from approximately 31 000 to 15 000 in 2020. 

Measures  have  been  taken  as  part  of  an  integrated  approach.  The  measures  taken  in  the 
framework  of  passive  vehicle  safety  overall,  e.g.  introduction  of  frontal  and  side  crash 
legislation,  presented  a  medium  advancement,  considering  that  their  implementation 
depended  on  the  vehicles  renewal  rate  where  the  total  fleet  was  expected  to  be  completely 
renewed  after  about  a  14-year-cycle17.  The  ex  post  analysis  further  concluded  that  between 
2001  and  2007,  vehicle  occupants’  safety  had  been  increasing  remarkably.  In  general,  both 
the effectiveness and the efficiency of passive vehicle safety improvements had proven to be 
positive,  where  generally  the  technologies  themselves  were  not  considered  as  hugely 
expensive,  but  were  observed  to  be  having  a  great  impact  on  injury  and  fatality  reduction. 
Clear examples of such effective safety regulations are the provisions for passenger car frontal 
and side crash safety that were phased in between 1998 and 200318 which, in the meantime, 
were integrated within the GSR for simplification and legislative harmonisation purposes. 

Also,  for  protecting  pedestrians  and  other  vulnerable  road  users  such  as  cyclists,  a  set  of 
comprehensive  vehicle  safety  requirements  had  been  introduced  and  phased  in  for  normal 
passenger cars from 2005 to 201319, eventually as part of the current PSR. When comparing 
the  EU  situation  in  2014  to  that  of  2005  as  regards  the  total  number  of  fatalities,  analysis 
shows a 33% reduction of pedestrian and 30% reduction of cyclist fatalities respectively over 
the entire period20.  

Road collisions are often multifactorial, with various driver, infrastructure and vehicle factors 
contributing to their causation. Addressing any of the causation factors of a specific collision 
bears a certain chance to prevent it or mitigate the resulting consequences. It should therefore 
be  acknowledged  that  the  effects  of  additional  in-vehicle  safety  systems  and  infrastructure 
improvements will, to a certain extent, affect the same population of road traffic collisions. In 
how far the cases where the two sets of measures are effective overlap, i.e. being successful at 

15   Ex post evaluation of the European Road Safety Action Programme (2001-2010) – 

http://ec.europa.eu/transport/facts-fundings/evaluations/doc/2010_road_safety.pdf, Interim evaluation of 
the Policy orientations on road safety 2011-2020 – http://ec.europa.eu/transport/facts-
fundings/evaluations/doc/interim-road-safety-evaluation-report-final8june15.pdf 

16   Towards a European road safety area: policy orientations on road safety 2011-2020 (COM(2010) 389 final) 
17   https://ec.europa.eu/transport/facts-fundings/evaluations/doc/2010_road_safety.pdf 
18   Directive 96/27/EC of the European Parliament and of the Council of 20 May 1996 on the protection of 

occupants of motor vehicles in the event of a side impact and amending Directive 70/156/EEC (OJ L 169, 
8.7.1996, p. 1.) and Directive 96/79/EC of the European Parliament and of the Council of 16 December 
1996 on the protection of occupants of motor vehicles in the event of a frontal impact and amending 
Directive 70/156/EEC (OJ L 18, 21.1.1997, p. 7.) 

19   Directive 2003/102/EC of the European Parliament and of the Council of 17 November 2003 relating to the 
protection of pedestrians and other vulnerable road users before and in the event of a collision with a motor 
vehicle (OJ L 321, 6.12.2003, p. 15.) 

20   CARE historical percentage change in number of fatalities by mode of transport 2016 – 

https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2016.pdf 

10 

 
                                                 
preventing  a  targeted  collision,  is  very  complex  to  quantify  in  detail.  Namely,  scope  and 
effectiveness  vehicle  safety  measures  are  relatively  closely  defined,  designed  to  avoid 
collisions  by  compensating  for  mistakes  or  non-compliant  behaviours  of  human  drivers. 
However,  the  resulting  collision  types  are  likely  involve  interaction  with  the  road 
infrastructure,  for  instance  run-off  road  or  head-on  collisions  following  unintentional  lane 
departures due to inattention or excessive speed. A proportion of these accidents could also be 
addressed by rumble strips or roadside barriers if they were laid down and placed on the full 
road network. There are however also collisions with an assumed low level of infrastructure 
interaction,  such  as  rear  collisions  or  vehicle  to  pedestrian  or  cyclist  collision  due  to  a 
distracted driver. The effectiveness values for in-vehicle safety measures are typically in the 
order  of  20%  to  40%  of  the  targeted  collisions.  The  effectiveness  for  the  passive  safety 
measures will be lower and predominantly act through mitigation of consequences rather than 
collision prevention.  

The scope of the road infrastructure and tunnel safety  initiative is  defined at a higher level, 
focusing  on  audits  (of  new  roads),  inspections,  black  spot  identification  (of  existing  roads) 
and  minimum  safety  standards  for  tunnels,  which  leaves  the  decision  on  suitable  technical 
countermeasures  open  for  the  specific  roads  covered.  While  radical  changes  of  the  road 
infrastructure design could have the potential to ‘undermine’ vehicle safety cost-effectiveness 
evaluation, the measures expected from the road infrastructure and tunnel safety initiative are 
not  believed  to  fall  in  this  category,  because,  for  instance,  separation  of  carriageways  using 
central  barriers  could  physically  prevent  front-to-front  collisions  resulting  from  lane 
departures,  but  is  unlikely  to  be  viable  for  most  of  the  single  lane  road  network.  The 
initiatives  are  aimed  rather  to  lift  a  greater  part  of  the  road  infrastructure  to  an  appropriate 
safety level that is achieved on better performing roads already. Therefore, the vehicle safety 
effectiveness studies as conducted remain valid. 

Furthermore,  certain  in-vehicle  systems  rely  on  a  well-maintained  road-infrastructure:  Lane 
keeping systems require well-maintained lane markings, and speed assistance systems rely on 
speed limit signs in  a  good state  of repair for camera detection. The road infrastructure and 
vehicle safety initiatives will therefore also complement each other in certain areas and enable 
in-vehicle systems to realise their full safety potential. 

Figure 1: Pace of traffic accidents, injuries and fatalities in the EU 

Figure  1  demonstrates  the  respective  number  of  fatalities,  injuries,  serious  injuries  and 
accidents, over time. It is easy to note that the reduction rate of accidents is running in parallel 
with the reduction rate for slight and severe injuries, but that that the one for road fatalities is 

11 

 
 
 
more  pronounced  and  performing  better.  This  may  be  linked  to  current  vehicle  safety 
evolution,  but  given  the  nature  of  the  combined  road  safety  actions  and  the  insufficient 
availability  of  EU  wide  in  depth  accident  data21,  it  has  so  far  been  proven  impossible  to 
attribute a clear quantified reduction rate to mandatory vehicle safety legislation. 

In context of the above, it should also be noted that apart from demanding EU vehicle safety 
legislation, vehicle manufacturers have been further encouraged to make vehicles even more 
safe  and  to  fit  state-of-the-art  advanced  safety  technologies  through  consumer  new  car 
assessment  and  rating  programmes,  notably  that  carried  out  by  the  European  New  Car 
Assessment  Programme  (Euro  NCAP)  that  launched  its  activities  in  December  1996.  The 
resulting positive effects are also taken into account as part of the baseline scenario based on 
the  EU  Reference  scenario  2016  covering  the  entire  transport  system,  within  this  Impact 
Assessment. 

With increasing levels of vehicle automation being a priority for car manufacturers, accurate, 
robust, durable and affordable sensor technologies are becoming widely available. These are 
necessary  to  detect  the  environment  around  the  vehicle  fully  and  also  to  facilitate  the 
determination  of  a  safe  passage  through  traffic  scenarios.  Fitting  such  sensors  and  data 
processing  technology  to  vehicles  will  continue  contributing  to  safety  improvements, 
especially  regarding  vulnerable  road  users,  and  even  to  the  reduction  of  congestion  and  the 
ensuing  pollution,  given  that  15%  of  all  congestion  in  Europe  is  due  to  accidents22.  The 
beneficial  effect  of  connectivity  is  achieved  by  various  ways  like  messages  transmitted  via 
smart  phones,  navigator  devices  as  well  as  Internet  of  Things  applications.  The  concept  of 
Vehicle-to-vehicle (V2V) and vehicle-to-infrastructure (V2X) communication is however not 
yet  mature  enough  for  widespread  incorporation  in  vehicles.  Despite  this,  it  may  be 
considered to ask the co-legislator for a mandate to ensure standardisation, as requested by the 
industry23, to better facilitate e.g. multi-brand platooning. 

The  ex  post  evaluation  of  the  road  safety  action  programme,  published  in  December  2009, 
already  concluded  that  the  development  of  measures  related  to  the  active  safety  of  vehicles 
(primarily those having accident avoidance capability) presented a good state of advancement, 
but that they would play a considerable role for safety in the medium or long term rather than 
the short term. Accident avoidance measures can help in further reducing the number of road 
accidents by assisting the driver and providing a remedy for human errors, which is by far the 
main cause of road traffic accidents24. 

2.  WHAT IS THE PROBLEM AND WHY IS IT A PROBLEM? 

1.5. Traffic accidents in the EU and their effects 

Until 2009, transport accidents were the leading cause of death in the EU, but this is no longer 
the case25. The number of road fatalities has come down considerably during the last 15 years, 
namely with an approximate 54% reduction from 54 900 in 2001 to 25 300 in 2017 according 
to  the  statistical  EU  accident  data26.  However,  traffic  accidents  still  affect  hundreds  of 
thousands of families and lead to huge economic costs each year, not only due to the loss of 

21   http://www.dacota-project.eu/Deliverables/DaCoTA_D2.5_finalreportv2.pdf 
22   http://ec.europa.eu/transport/themes/its/road/application_areas/vehicle_safety_systems_en.htm 
23   http://www.acea.be/uploads/publications/Platooning_roadmap.pdf 
24  
25   http://ec.europa.eu/eurostat/statistics-explained/index.php/Causes_of_death_statistics 
26  Data are extracted from CARE (Community Road Accident Database) – 
https://ec.europa.eu/transport/road_safety/specialist/statistics_en 

eSafety Final Report of the Working Group on Road Safety, DG INFSO, November 2002 

12 

 
                                                 
lives, but also due to persons sustaining serious injuries in road accidents. The social cost due 
to  road  casualties  (i.e.  rehabilitation,  healthcare,  death,  material  damages,  among  others)  is 
estimated to be at least in the order of € 100 billion per year27and as such, the problem of road 
safety remains an urgent one. 

Figure 2: Road traffic fatalities and serious injuries in the EU (CARE database) 

Strong annual reductions  of road  fatalities  were observed, for example considering the total 
reduction in each of the Member States from 2005 to 2014, with the highest rate reduction per 
million inhabitants occurring in Spain (65%) and Lithuania (65%) followed by Czech (61%) 
and  lowest  rate  reduction  in  Romania  (26%),  followed  by  Bulgaria  (29%)  and  Germany 
(35%). However, the overall reduction appears to have stagnated since 2013. This is clearly 
visible in the plateau that has developed from 2013 to 2017 (last available annual data). 

The main problem to tackle at this instance is the persistent high number of accidents that in 
turn leads to a high number of fatalities and a high number of severe injuries. The solutions to 
address the main problem should either avoid and lower the number of accidents or lower 
the severity of un-avoided accidents to lower the number of fatalities and severe injuries. 

Whereas some Member States are still making considerable progress every year, some others 
are even recording increases in fatalities. The causes are diverse, including structural factors 
(e.g. urbanisation, a growing number of cyclists and pedestrians, an ageing population, fewer 
resources for enforcement, road maintenance and vehicles following the economic crisis) and 
behavioural  factors  (e.g.  distraction  by  electronic  devices,  speeding;  alcohol).  The  lack  of 
detailed  data  makes  a  precise  analysis  difficult.  It  is  however  clear  that  much  of  the  low 
hanging  fruits  for  policy  making  at  national  and  EU  level  have  been  picked  and  that  it  is 
unlikely that the EU objective of a 50% reduction in road fatalities between 2010 and 2020 
will  be  reached.  A  paradigm  shift  is  needed  towards  a  framework  based  on  results  that 
addresses the major challenges in an effective and flexible way across the entire spectrum of 
road safety policies. Such a framework will be proposed for the period 2020 – 2030 as part of 
the third Mobility Package and will follow the Safe System approach. 

New  and  safe  vehicles,  meeting  the  latest  EU  requirements  adopted  by  the  Council  and  the 
European Parliament in 2009 and becoming mandatory for almost all vehicles since 2014, are 
sold  on  the  EU  market  today  and  dispersing  into  the  fleet,  replacing  older  and  unsafer 

27 

Press release statement – http://europa.eu/rapid/press-release_IP-16-863_en.htm 

13 

 
 
                                                 
vehicles.  However,  we  also  know  that  increasing  traffic  volumes  will  lead  to  a  mounting 
number of road incidents potentially leading to more collisions and casualties. We now also 
become  aware  that an  increasing  safety  level  in  the  vehicle fleet,  resulting  from  the  vehicle 
safety measures introduced in the previous years, is required simply to achieve the status quo. 
Without the previous measures, the fatality and severe injury rates could even be expected to 
rise. Those effective vehicle safety measures however as introduced in the past and that are 
still dispersing into the fleet, e.g. stability control, are integrated into the baseline scenario for 
future  years  and  indeed  seen  to  avoid  casualties,  but  not  to  the  extent  necessary  to 
considerably  overcompensate  the  increase  in  traffic  volumes.  Hence,  further  action  is  now 
needed. 

According to the Safe System approach28, death and serious injury in road collisions are not 
an inevitable price to be paid for mobility. While collisions will continue to occur, death and 
serious injury are largely preventable. The Safe System seeks to better accommodate human 
errors, which are often simple errors of perception or judgment by otherwise compliant users, 
whilst also dealing with misbehaviour. It is a shared responsibility of actors at all levels and 
from  all  relevant  sectors  to  ensure  that  road  crashes  do  not  lead  to  serious  or  fatal  injuries. 
Better vehicle construction, improved road infrastructure, lower speeds for example all have 
the  capacity  to  reduce  the  impact  of  accidents,  and  addressing  one  factor  alone  will  not  be 
enough. The aim is to create several layers of protection so that when one element fails, others 
will  compensate  for  it.  For  example,  if  a  drowsy  driver  veers  from  his  lane,  vehicle 
technology  can  alert  him  or  gently  correct  the  vehicle's  trajectory.  Rumble  strips  provide 
another  warning.  Should  the  vehicle  nevertheless  leave  the  road,  a  "forgiving  roadside" 
without  dangerous  obstacles  or  with  energy  absorbing  roadside  barriers  can  prevent  serious 
consequences.  Finally,  crash  absorbing  vehicle  design,  along  with  seatbelts  and  airbags, 
protect  vehicle  occupants.  The  Safe  System  approach  is  being  adopted  increasingly  in  EU 
Member  States,  regions  and  cities.  It  is  recommended  globally  by  the  World  Health 
Organisation29. 

Working  towards  the  EU’s  strategic  objectives  to  halve  the  number  of  road  deaths  by  2020 
compared  to  2010  and  to  move  close  to  zero  deaths  by  2050  ("Vision  Zero"  approach) 
requires  a  wide  range  of  measures.  Experts  agree30  that  contributions  towards  these  targets 
will  have  to  come  from  all  areas  of  road  safety  policy.  Measures  addressing  speed,  drink-
driving  and  vehicle  safety,  and  –  to  a  slightly  lesser  extent  –  measures  addressing  road 
infrastructure,  protective  equipment  (seatbelts,  child  restraints)  and  post-crash  care,  are 
generally  regarded  as  having  the  highest  potential  impact.  Vehicle  and  infrastructure  safety 
are being addressed in the present proposals. Further complementary actions will be assessed 
in the future, subject to separate impact assessments. 

According to the main statistical findings provided and analysed by Eurostat31, the number of 
road  traffic  fatalities  in  the  various  countries  and  regions  depends  on  both  structural 
differences (size of the country/region; composition, density and quality of the road network, 
characteristics  of  the  population)  and  socio-economic  differences  (characteristics  of  the 
vehicle stock, transit and tourist traffic, behavioural aspects, etc.).  

28   OECD/International Transport Forum (2016): "Zero Road Deaths and Serious Injuries: Leading a paradigm 

shift to a Safe System", OECD Publishing, Paris; and http://www.visionzeroinitiative.com 

29   http://www.who.int/roadsafety/decade_of_action/plan/plan_en.pdf 
30   The SafetyCube (Safety CaUsation, Benefits and Efficiency) review project, financed under Horizon2020, 

synthesises relevant research: https://www.safetycube-project.eu 

31   http://ec.europa.eu/eurostat/statistics-explained/index.php/Road_safety_statistics_at_regional_level 

14 

 
                                                 
The trends in fatality rates vary significantly throughout the entire EU. For the period 2014-
2015, 16 Member States reported rising casualty figures32 (e.g. Belgium (4%), France (2%), 
Germany  (3%),  Czech  Republic  (7%),  Austria  (10%)  and  Cyprus  (27%).  A  decrease  was 
observed  in  10  Member  States  (e.g.  Poland  (-8%),  Ireland  (-15%),  Estonia  (-15%)  and 
Luxembourg (-9%).  

Causes and sources of traffic accidents have been subject to extensive investigation during 
many  years.  There  are  several  in-depth  international  studies  on  traffic  crashes  that  have 
identified significant causes and severity factors. Infrastructure, e.g. road layout such as hills, 
bends  or  narrow  lanes  and  road  environment  such  as  slippery  roads  due  to  the  weather 
conditions,  contribute  to  the  causes  factors.  On  the  other  hand,  road  user  factors,  such  as 
inadequate  restraint  systems  or  improper  use  play  a  dominant  role  in  severity  factors.  In 
contrast, vehicle factors (e.g. due to malfunction, worn parts, non-compliance) contribute only 
a relatively small portion to accident severity factors (road user factors 63%, road factors 33% 
and vehicle factors 4%)33.  

The traditional vehicle safety performance, not to be confused with vehicle factors, has been 
consistently addressed through previous measures introduced in EU legislation. Of these, the 
passive  safety  measures  consist  of  improving  car  designs  and  construction  to  protect  the 
occupants  in  a  crash.  This  is  done by  physically  strengthening  the  vehicle chassis,  structure 
and  bodywork  as  well  as  the  designs  of  e.g.  seats,  steering  column  and  energy  absorbing 
elements. More recently, the active safety measures that have been introduced are those that 
deploy once an accident is already occurring, e.g. airbags and safety belt tensioners. An area 
however that so far has not really been fully addressed is that of accident avoidance measures 
(with  the  noted  exception  of  new  stability  control  systems  that  are  mandatory  for  all  new 
vehicles since November 2014 and is identified as a major influence on the baseline scenario). 
Avoidance  systems  have  the  capability  of  indeed  preventing  an  accident  from  happening 
altogether  and  the  initiative  covered  by  this  Impact  Assessment  has  a  particular  focus  on 
deploying such measures alongside other conventional passive and active safety measures. 

Some of the  sources  of accidents  with great impact  on accident severity factors are thus 
ideal  candidates  to  address  by  means  of  new  and  advanced  safety  measures.  For  this 
purpose  this  was  assessed  in  the  context  of  the  Commission’s  reporting  to  European 
Parliament  and  the  Council  as  referred  to  in  section  1.3  above.  One  has  to  think  along  the 
lines of forward looking detection systems that can spot safety issues before the human driver 
can see them, in a way addressing infrastructure shortcomings. It should be noted that these 
sources differ across EU countries, thus avoidance measures enhance the overall safety effect 
throughout the EU.  

Another  area  that  can  be  addressed  concerns  population  diversity  throughout  a  regional 
population.  This  is  done  by  improving  (e.g.  softening  and  optimising)  in-vehicle  restraint 
systems  for  better  protecting  physically  sensitive  elderly  drivers  with  reduced  bone  density 
and frailty due to their age, as well as protecting small female occupants, as the smaller the 
person,  the fewer  crash  forces  the  body  can  tolerate.  This  addresses  the  road  user  factors 
and in particular the inadequate restraint systems mentioned above. 

It has further been suggested by stakeholders that the increasing number of older persons lead 
to an increase of reversing accidents in which an older pedestrian is hit, as the elderly have 

32   Country by country road deaths per million inhabitants – http://europa.eu/rapid/press-release_IP-16-

863_en.htm 

33   Final  report  –  Support  study  for  an  impact  assessment  of  the  revision  of  Directive  2008/96/EC  on  road 
infrastructure  safety  management  and  Directive  2004/54/EC  on  minimum  safety  requirements  for  road 
tunnels in the trans-European network (to be published) 

15 

 
                                                 
less agility to get out of the way of impending danger. It could also be argued that drivers of 
age  may  have  longer  reaction  times  and  that  they  would  benefit  from  autonomous  safety 
systems. However concerning the latter there is insufficient data available that would help to 
precisely quantify both problem and benefit. 

Another possible problem driver that is often mentioned34 by stakeholders and Member States, 
but for which only limited EU wide evidence exists35, is that of driver inattention because of 
distraction through the  use of smartphones while driving. Distraction can be addressed by 
new technologies in motor-vehicles. In a recent publication on a targeted questionnaire in the 
Netherlands36, up to 39% of car drivers indicated using a mobile phone behind the wheel for a 
task other than hand-held or hands-free calling. The overall average mobile phone use while 
driving was admitted by 42% of respondents, where the age group 25 to 34 topped the range 
at  79%.  Of  the  respondents,  37%  conceded  doing  this  on  a  frequent  basis.  Along  the  same 
lines  on  driver  inattention,  driver  fatigue  and  drowsiness  should  be  mentioned,  as  it  is 
estimated that this is a major factor in a large proportion of road crashes, in the 10% to 20% 
range37.  

Therefore,  in  order  to  reach  the  current  EU  strategic  target  of  halving  the  number  of  road 
deaths  from  approximately  31  000  in  2010  to  15  000  in  2020,  as  stated  in  the  Policy 
Orientations  on  Road  Safety  2011  –  202038,  or  rather  the  updated  targets  that  are  to  be  set 
beyond this date, additional efforts are needed. Despite the big improvement made in the past, 
road  fatalities  are  still  persistent  in  European  countries.  As  explained  above,  a  large  part  of 
those  are  driven  by  human  error  factors.  Therefore,  in  order  to  complement  our  past 
initiatives  and  contribute  to  a  further  reduction  of  fatalities,  our  focus  should  be  on 
introducing  new  safety  measures,  especially  those  ones  tackling  human  error  factors, 
something that has not been the centre of attention before, to help boost road safety. 

1.6. Transformation of main safety problem into vehicle level problems 

In this section the description of specific road safety problem is ultimately provided from the 
perspective  of  persons  that  are  injured  or  killed  in  traffic  accidents  involving  vehicles. 
However, with reference to Annex 5, no less than 96 accident scenarios have been reviewed 
and  subsequently  rated in  terms  of  feasibility and  occurrence  rate  while  taking  into  account 
EU accident data analysis. Account was taken of vehicle to vehicle accident as well as vehicle 
to person accident scenarios. A further rating was then applied based on assessment of risk, 
specifically  concerning  the  persons  in  and  around  the  vehicle  involved  in  the  accident,  in 
order to identify the target priorities. 

Given  the  scope  of  the  legislative  framework  that  has  been  considered,  the  vehicle  classes 
could be crudely grouped into two main distinctions: Light Duty Vehicles (LDV) and Heavy 
Duty Vehicles (HDV) as illustrated in Figure 3. 

34   http://etsc.eu/several-countries-looking-to-crack-down-on-mobile-phone-use-at-the-wheel/ 
35   https://www.who.int/violence_injury_prevention/publications/road_traffic/distracted_driving_en.pdf 
36   https://www.swov.nl/publicatie/interpolis-barometer-2017 
37   https://ec.europa.eu/transport/road_safety/specialist/knowledge/fatique/fatigue_and_road_crashes/ 

conclusions_en 
38  COM(2010) 389 final 

16 

 
                                                 
Figure 3: Vehicle categories and grouping for problem description 

Light Duty Vehicles 

Heavy Duty Vehicles 

A  further  distinction  was  made  in  relation  to  the  category  of  vulnerable  road  users,  namely 
pedestrians and cyclists.  

Although moped and motorcycle riders are also often referred to as vulnerable road users, and 
e.g.  the  users  of  self-balancing  machines,  they  are  not  explicitly  included  as  such  for  the 
purpose of this Impact Assessment, although improved protection will to a certain extent also 
benefit them. This is however not quantified, because there is a considerable variation in the 
Member  States  in  the  distribution  of  e.g.  moped  and  motorcycle  fatalities  by  area  and  road 
type,  diverging  practises  of  helmet  use,  and  the  most  frequently  recorded  specific  critical 
event for riders is surplus speed that is described as speed that is too high for the conditions or 
manoeuvre  being  carried  out,  very  much  in  contrast  to  pedestrians  and  cyclists39.  Also, 
motorcycle riders tend to be disconnected from the vehicle in case of an accident. Although 
this  group  should  clearly  be  taken  into  account  wherever  practicable,  specific  measures  to 
address  their  safety40  were  deemed  more  appropriate  outside  of  the  regulatory  framework 
impacted  by  this  specific  initiative.  Other  possible  improvements  could  for  instance  be 
achieved  through  road  infrastructure  risk  management,  by  encouraging  the  application  of 
roadside barriers that are especially designed to better protect riders sliding over the ground 
and impacting them. 

The  EU  accident  data,  as  well  as  by  the  additional  preparatory  analysis41  carried  out 
specifically in support of this Impact Assessment, finally supported that the accident scenarios 
as  mentioned  below,  most  commonly  involving  LDV  and  HDV  with  the  identified  primary 
and secondary risks to be addressed by the initiative: 

39   https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/bfs2016_ 

motomoped.pdf 

40   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) and 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) 
41   Based on CARE 2015 data and TRL, Seidl et al., May 2017 including the additional Technical Annex to the 
report,  concerning  “Cost-effectiveness  analysis  of  Policy  Options  for  the  mandatory  implementation  of 
different sets of vehicle safety measures – Review of the General Safety and Pedestrian Safety Regulations”, 
not yet published  

17 

 
 
 
                                                 
  Frontal impacts and the protection of occupants resulting in about 63% (8650/yr) of 
all  occupant  fatalities  in  LDV  and  HDV,  as  well  as  a  need  for  fire  and  electric  shock 
prevention after a crash occurrence; 

  Side  impacts  and  protection  of  occupants  resulting  in  about  17%  (2325/yr)  of  all 
occupant  fatalities  in  LDV  and  HDV,  as  well  as  a  need  for  fire  and  electric  shock 
prevention after a crash occurrence; 

  Rear  impacts  and  protection  of  occupants  resulting  in  about  5%  (725/yr)  of  all 
occupant  fatalities  in  LDV  and  HDV,  as  well  as  a  need  for  fire  and  electric  shock 
prevention after a crash occurrence. 

and 

  Pedestrian  and  cyclist  protection  hit  by  the  front-side  of  a  vehicle,  resulting  in  about 

78% (5250/yr) of all pedestrian and cyclist fatalities hit by LDV and HDV; 

  Pedestrian  and  cyclist  protection  hit  by  the  side  of  a  vehicle,  resulting  in  about  8% 

(575/yr) of all pedestrian and cyclist fatalities hit by LDV and HDV; 

  Pedestrian  and  cyclist  protection  hit  by  the  rear-side  of  a  vehicle,  resulting  in  about 

11% (750/yr) of all pedestrian and cyclist fatalities hit by LDV and HDV. 

As the protection of persons is central to the reduction of road casualties, this aspect should be 
the  focus  of  attention  in  the  context  of  actions  that  are  analysed  within  this  Impact 
Assessment. 

1.7. Slow market uptake of new safety features in the vehicle fleet 

The rapid development of accident avoidance technologies in the past years has resulted in the 
availability  of  a  panoply  of  driver  assistance  features  (e.g.  autonomous  emergency  braking, 
lane keeping assist, reversing camera) that have a great potential to improve road safety, by 
either  avoiding  collisions  altogether  or  reducing  impact  speed  and  thus  the  victims’  injury 
levels. In  parallel,  improved active safety  features (e.g. window airbags, deployable bonnet, 
safety  belt  pre-tensioners  and  load  limiters)  as  well  as    passive  safety  features  (e.g.  energy 
absorbing  windscreens,  larger  windows  on  trucks)  also  play  an  important  role  to  further 
reducing the number of fatalities or injuries in collisions that will inevitably still occur. The 
voluntary market uptake of new vehicle safety features however has shown to be rather slow, 
as  typically,  mainly  larger  luxury  cars  did  benefit  from  these  new  features.  Passive  safety 
measures beyond those that are imposed and that are not primarily directed at protecting the 
occupants  (i.e.  pedestrian  safety)  are  rarely  incorporated  in  motor-vehicles  on  a  voluntary 
basis.  

1.8. Competitiveness and innovation 

It is envisioned that the current road safety problems can help to stimulate innovation for safer 
cars and technologies. As mentioned above, innovation on safety features has been limited to 
certain market segments so benefits are not optimal across the board. However, any 
introduction of new legislative measures shall not harm competiveness of car manufacturers 
and suppliers nor penalise their capacity to innovate.. 

1.9. Efficiency of measures introduced so far 

Given the very recent timeframe in which the latest safety measures have become mandatory, 
or in some cases still have to, the dispersion of fully compliant vehicles within the EU fleet is 
not yet achieved and will take up to 2025. This issue is the direct consequence of the choice of 
the co-legislators in 2009 to have long transitional arrangements for the implementation of the 

18 

 
 
measures. Given, these very long transitional arrangements, a comprehensive evaluation of all 
the measures adopted so far could not be completed. 

1.10.  Market description 

The  evolution  of  fatalities  depends  on  a  large  number  of  factors,  such  as  economic 
development (GDP/capita), mobility level (number of vehicle kilometres driven) or exposure, 
vehicle safety technologies, driver trainings or behaviour or road infrastructure. 

At the same time, the impact of safety measures will depend on the improvements of vehicle 
technology  and  gradual  penetration  of  the  safety  measures  into  stock  of  all  vehicles.  Even 
though  we  do  not  have  granular  data  to  approximate  the  current  state  of  safety  measures 
penetration in the car fleet, we can approximate it by the fleet renewal rates and the age of the 
car. 

When  observing  an  historical  evolution  of  road  accidents,  we  note  that  most  European 
countries present similar accident trends which differ on the timing, depending mostly on the 
economic  situation  of  countries42  (figure  A10.1  Annex  10).  After  a  peak  there  is  a  high 
decrease  on  the  number  of  accidents,  followed  by  a  stabilisation  of  the  trend,  with  a  lower 
decline  rate  of  accidents.  Western  European  countries  experienced  a  high  reduction  of  road 
accidents during the 60’s and 70’s, while Southern European countries did not experience a 
sharp decrease until some years later. Eastern countries experienced a big decline much more 
recently, around 2007, with some countries still being in this transition phase.43  

During the past decades, the number of vehicles per inhabitant has increased, but we observe 
different  regional  tendencies.  The  number  of  passenger  cars  per  thousand  inhabitants  has 
gradually increased in all Europe since 1990 (figure A10.2 Annex 10).  The steep growth in 
Eastern European countries contrasts with a moderate increase in Western Europe and Central 
Europe.  By  2015,  the  number  cars/thousand  inhabitants  in  South  European  countries  was 
similar to Central European Member States, while Eastern countries are quickly catching-up 
and approximating to similar figures to those in Western countries.  

On the other side, we observe big differences in vehicle fleet composition between Member 
States. Even though most of the measures proposed in this Impact Assessment have already 
attained  a  certain  level  of  maturity  in  the  market44,  its  integration  in  different  EU  countries 
might  remain  heterogeneous.  From  2007,  we  observe  renewal  rates  of  passenger  cars  to 
decrease in all Europe, with especially remarkable falls in South and Western Europe (Figure 
A10.3 Annex 10). Central European Member States were less affected than other regions, and 
kept a quite stable renewal rate from 2004 to 2015. From 2013 onwards, most Member States 
changed  the  tendency  and  started  experiencing  a  faster  renewal  rate  on  passenger  cars. 
Nowadays,  Central  Europe  and  Western  Europe  are  the  regions  with  faster  renewal  rates, 
while South Europe and Eastern Europe are slowly recovering.  

These differences are confirmed when observing the age of the current car fleet in different 
countries (Figure A10.4 Annex 10).  Member States such as UK, Germany and France have 
more  than  half  of  their  fleet  composed  of  relatively  new  vehicles:  19%  of  their  fleet  is  not 
older than 5 years, with less than 15% of cars being older than 10 years. On the other hand, 
other Member States, such as Poland, Hungary or Spain still present relatively old car fleets, 

42     Kopits and Cropper 2003 
43     COWI report 
44   TRL, Seidl et al., May 2017 – https://publications.europa.eu/en/publication-detail/-/publication/77990533-

9144-11e7-b92d-01aa75ed71a1 

19 

 
                                                 
with more than half of the fleet older than 10 years, and in some cases, even a notorious share 
of cars older than 20 years (Poland 32 %, and Latvia 22%).  

1.11.  Outdated safety exemptions for SUVs, MPVs, vans and the like 

Currently,  heavy  passenger  cars  (e.g.  family  van,  SUV,  MPV45)  and  all  light  commercial 
vehicles (e.g. cargo delivery van, pick-up) are fully exempted from the frontal crash testing as 
introduced in 1996. At that time the exemptions were introduced based on either a very low 
market  availability  of  such  vehicles  or  the  notion  that  utility  vehicles  would  have  severe 
difficulties  to  comply  due  to  their  size  and  mass.  It  was  further  suggested  that  compliance 
with the legislation would make larger and heavy cars stiffer at the front, and that this would 
create  a  specific  problem  for  small  non-compliant  older  cars  in  collisions  with  newer 
compliant  heavy  cars  (i.e.  compatibility  mismatch).  However,  this  issue  has  become 
increasingly obsolete over time, given that a high percentage of small cars in the fleet46  now 
meet the frontal impact off-set crash requirements. 

The  absence  of  frontal  crash  testing  requirements  for  light  commercial vehicles  as  a  whole, 
based on the notion of size and mass as with SUVs, presents the situation that workers that are 
required  to  drive  light  commercial  vehicles  to  carry  out  their  duties  cannot  rely  on  a 
harmonised minimum level of frontal crash protection. The actual safety level depends fully 
on the vehicle purchase choice made by their employers and even that safety performance is 
not subject to a guaranteed level. 

In practise, the actual safety level may vary significantly between two vehicles that appear to 
be completely identical in terms of looks, but that differ on a technical level. Some equipment 
may be fitted, but their performance can be erratic, given that there is no control mechanism 
due to the nature of the exemptions in the current legislation. 

Vehicles that do not have a seating position under just 70 cm above ground level are in turn 
fully  exempted  from  the  side  impact  crash  test.  Also  in  this  case  it  notably  includes  those 
passenger  cars  that  can  be  characterised  as  SUVs  as  well  as  delivery  type  vans.  The 
exemption was based on a lower risk of bodily injury of occupants, due to the ‘high’ seating 
position.  In  principle  this  reasoning  is  still  valid,  but  the  regulations  contain  other  safety 
criteria covering spontaneous door opening in a crash or all doors being jammed shut after a 
crash, which are then also neglected, putting occupants of these vehicles at a risk.  

Rear impact crash testing has been exempted altogether for all vehicle categories although the 
relevant test specifications and requirements have existed on UNECE level that apply in the 
EU  since  its  accession  in  199747.  Its  current  application  in  the  EU  is  mandatory,  but  with  a 
specific exemption concerning the rear crash test.  

When  motor-vehicles are exempted  from these  type of crash tests, the post-crash protection 
against electric shock and fire risks can also not be guaranteed. 

45   Family  van  is  generally  defined  as  a  passenger  car  version  of  e.g.  a  cargo  delivery  van  with  windows  all 
around and up to 9 seating positions – SUV means Sport Utility Vehicle generally defined as a large station 
wagon shaped vehicle with high riding position that is designed to be used on rough off-road surfaces, but 
that  is  rather  often  used  on  urban  roads  and  motorways  –  MPV  means  Multi-Purpose  Vehicle  generally 
defined as a family van,  but not derived from a cargo delivery van, with high riding position and up to 9 
seating positions 

46   Eurostat, Road transport equipment – Stock of vehicles 
47   OJ L 346, 17.12.1997, p. 78 

20 

 
                                                 
In  the  light  of  the  success  of  SUVs  in  the  marketplace,  up  from  only  3%  in  1996  to  14% 
market penetration in 201648 and the increasing sales figures49 for light commercial vehicles 
with the market addressing urban mobility solutions the justification for these exemptions has 
to  be  reconsidered.  In  addition,  the  accelerated  shift  towards  zero-emission  mobility  with 
electric vehicles and their heavy and high capacity batteries also plead for re-examination of 
these  exemptions  as  battery  powered  vehicles  need  to  offer  adequate  protection  against 
electric shock and vehicle fire after a crash. It should be recognised that e.g. consumer testing 
points to certain manufacturers that may very well design and construct vehicles based on due 
diligence. However, given this very unclear situation, it has also proven to be impossible to 
quantify this specific problem. Hence  the safest way forward would be to  scrutinise the old 
justifications  with  a  view  to  lift  these  exemptions,  to  ascertain  that  they  cannot  have  an 
unintended negative effect on the already precarious status quo. 

1.12.  Contribution to the reduction of the regulatory burden on companies 

The initiative has a REFIT dimension, but is not expected to have a significant impact on the 
regulatory  burden  for  manufacturers  or  national  governments.  Vehicle  type-approval  is 
already  covered  by  the  existing  vehicle  legislative  framework  (Framework  Directive 
2007/46/EC)  and  the  inclusion  of  any  new  safety  measures  is  to  be  integrated  within  that 
framework. 

Although the relevant vehicle testing and certification procedures can be performed within the 
existing  type-approval  infrastructure  available  in  the  Member  States,  additional  testing  and 
certification cost will be applicable. These costs are however insignificant50 in relation to the 
overall  cost  of  the  development  of  a  new  vehicle  model  (typically  ranging  from  several 
hundred millions to several billions euros). 

The  original  GSR  introduced  a  range  of  vehicle  safety  measures,  but  also  aimed  to  achieve 
simplification  based  on  the  CARS21  High  Level  Group  recommendations51  by  replacing  38 
EC  Directives  with  equivalent  and  world-wide  harmonised  UNECE  regulations.  The 
proposed  new  vehicle  safety  measures  covered  by  this  initiative  should  also  adhere  to  this 
principle and where detailed technical testing provisions do not yet exist, they should clearly 
be  developed  on  UNECE  level.  In  the  same  vein,  several  EU  Regulations  that  currently 
implement the GSR will be repealed and replaced by equivalent UNECE regulations that have 
in the meantime been introduced.  

Because  of  the  transparent  stakeholder  engagement  and  frequent  reporting  in  EU  Working 
Groups and UNECE Working Parties, there has been significant interest by other Contracting 
Parties to engage on UNECE level. For instance, work to develop safety standards has already 
started  on  Lane  Keeping  provisions,  Autonomous  Emergency  Breaking  for  cars  and  for 
pedestrians and cyclist detection on the front and to the side of trucks cabs, as well as for a 
direct  vision  standard  for  heavy  duty  vehicles  by  countries  including  Japan,  Russia  and 
Canada.  

48   http://www.acea.be/statistics/tag/category/4x4-penetration 
49   http://www.acea.be/statistics/tag/category/by-country-registrations  
50   Fitness  Check  of 

the  Legal  Framework 

for 

the  Type-Approval  of  Motor  Vehicles 

- 

http://ec.europa.eu/smart-regulation/evaluation/search/download.do?documentId=9407681 

51   COM(2007) 22 final – CARS 21 High Level Group was mandated to make recommendations for the short, 
medium  and  the  long  term  public  policy  and  regulatory  framework  for  the  European  automotive  industry 
that  enhances  global  competitiveness  and  employment  while  sustaining  further  progress  in  safety  and 
environmental performance at a price affordable to the consumer  
http://ec.europa.eu/DocsRoom/documents/1891/attachments/1/translations/en/renditions/pdf 

21 

 
                                                 
 
The  proposed  initiative  will  consolidate  in  one  legal  act  and  repeal  the  three  currently 
applicable  co-decision  regulations,  namely  the  General  Safety  Regulation,  the  Pedestrian 
Safety  Regulation  and  the  Hydrogen  Safety  Regulation52,  as  they  share  specific  similarities 
that  will  result  in  simplification  of  this  EU  legislation.  In  particular,  a  further  15  individual 
implementing measures of the three main acts will be repealed and replaced, on the one hand 
with UNECE Regulations that have been adopted in the meantime, and on the other hand with 
one delegated act and one implementing act. 

The  proposed  action  is  future  proof.  The  envisioned  measures  are  to  be  put  in  place  on  a 
‘technology neutral’ basis. The overall vehicle safety measures covered by this initiative will 
further  adhere  to  the  established  and  industry welcomed  principle  of  preferred  development 
on  UNECE  level  for  reasons  of  world-wide  harmonisation.  It  is  also  highly  preferential  in 
terms  of  its  potential  for  efficient  adaptation  of vehicle  safety  rules to  technical  progress.  It 
means that on the one side manufacturers can innovate to meet their own safety performance 
objectives, without dictating the technical approach, but also that the Commission as regulator 
can  efficiently  address  technical  progress  and  urgent  safety  needs  through  more  simple 
integration within the EU legislative framework.  

Finally, thanks to the technology neutral approach, manufacturers will be enabled to exceed 
the  minimum  requirements  with  deployment  of  new  innovations.  This  is  in  particular 
important  given  the  transition  to  more  autonomous  functions  in  vehicles,  vehicle  to  vehicle 
and  vehicle  to  infrastructure  communication.  The  room  that  is  going  to  be  provided  for 
innovation allows for various options that can  benefit the further development of connected 
and automated transport, e.g. use of advanced sensors and/or cameras for road sensing.    

52   Regulation (EC) No 79/2009 of the European Parliament and of the Council of 14 January 2009 on the type-
approval  of  hydrogen-powered  motor  vehicles  and  amending  Directive  2007/46/EC  (Text  with  EEA 
relevance), OJ L 35, 4.2.2009, p. 32 

22 

 
                                                 
1.13.  Main problem drivers and consequences 

Figure 4: Problem tree 

Out of scope: 

  Road infrastructure (e.g. signs, lane markings, motor-ways, tunnels) 
  Driver training 
  Level of enforcement 
  Mobility mix options (e.g. car-pooling) 
  Mobility restrictions (e.g. low emissions zones) 
  Cooperative, connected and automated mobility (CCAM) 

3.  WHY SHOULD THE EU ACT? 

The Legislative Framework for type-approval of vehicles in general is based on Article 114 of 
the  TFEU  and  contributes  to  the  implementation  of  the  internal  market  for  goods.  Vehicle 
safety  requirements  are  already  harmonised  at  the  EU  level,  which  not  only  prevents 
fragmentation of the internal market, but also ensures equal health and safety standards across 
the  EU  as well  as  offering  advantages  of  economies  of  scale:  products  can  be  made  for  the 
whole  European  market,  instead  of  being  customised  to  obtain  national  approval  for  every 
single Member State. 

If actions to address road safety problems were to be taken individually by Member States at 
national  level  by  imposing  additional  specific  performance  requirements,  there  would  be  a 
particular  risk  of  creating  obstacles  to  the  free  movement  of  motor  vehicles.  This  risk  has 

23 

 
   
clearly  been  demonstrated  in  the  discussions  about  the  more  strict  requirements  concerning 
the positioning or repositioning of the steering-wheel of new or previously registered vehicles 
designed for left-side traffic in order to be used on public roads of Member States with right-
side traffic53. 

Another  example,  demonstrating  this  risk  is  linked  to  local  or  regional  level  prohibition  of 
vehicle  circulation,  for  instance  inside  of  certain  cities  or  city  sections  that  would  require 
more stringent safety equipment on vehicles than required by EU  legislation. In some cases 
this  is  limited  to  public  procurement  methods,  for  instance  by  the  city  of  Copenhagen  with 
guidelines  for  procurement  of  garbage  collecting  services,  requiring  that  the  garbage  trucks 
used  should  be  designed  to  maximise  the  safety  of  surrounding  vulnerable  road  users,  e.g. 
with glass doors for increasing the driver's field of vision54. It is however also known that the 
city of London is working on actually banning EU compliant vehicles from city areas if they 
do  not  fulfil  specific  additional  safety  criteria55.  For  this  purpose,  the  mayor  of  London  is 
currently  already  finalising  a  set  of  comprehensive  rules  on  a  direct  vision  standard  for 
trucks56, hence there is clear added value to take action at EU level. 

Furthermore,  given  the  lack  of  rapid  uptake  of  new  vehicle  safety  features,  as  outlined  in 
section 2.2 above, and the fact that the typical fitment rates are still well below what could be 
considered  an  effective  and  appropriate  proportion  of  new  vehicles,  these  matters  should 
rather be considered for EU legislative action. 

In addition, making available, on a large scale, motor-vehicles with raised sophistication will 
also  have  consequences  concerning  several  aspects  related  to  vehicle  drivers  as  well  as  the 
infrastructure.  Notably  these  could  include  incorporating  knowledge  and  awareness  of  new 
technologies in driver training programs as well as optimisation of road markings and traffic 
signs  for  the  increasing  automation  functions  depending  on  that  type  or  road  infrastructure 
input. As such, it is again underlined how important the integrated approach remains. 

4.  WHAT SHOULD BE ACHIEVED? 

The general objective of the proposed initiative is to contribute to a further reduction of 
the number of traffic accident fatalities and severe injuries. 

The problem definition has pointed to two specific objectives to address the general objective 
in terms of physical protection of persons:  

  Occupants of vehicles involved in collisions need to be protected. 
  Pedestrians and cyclists struck by a vehicle need to be protected. 

A  range  of  underlying  problems  have  also  been  identified.  The  slow  market  uptake  of  new 
features  and  abolishing  of  outdated  vehicle  safety  exemptions  can  be  addressed  when 
measures indeed focus on upgrading EU vehicle safety with concrete vehicle safety measures 
and new features. Competitiveness and innovation are general issues that need to be taken on 
board regardless of the proposed solution. The lack of data on the efficiency of measures that 
have been adopted in the past cannot be addressed for those measures per se, but to promote a 
workable solution for new measures that are presently under consideration.  

As previously outlined, the legislative framework addressing vehicle safety consists of on the 
one hand the GSR and on the other the PSR that are thus subject of this Impact Assessment. 

53   Judgement of the Court (Fifth Chamber) in Case C61/12 
54   COM(2013) 913 final -  
55   https://tfl.gov.uk/cdn/static/cms/documents/safer-lorries-scheme-traffic-regulation-order-2015.pdf 
56   http://www.tfl.gov.uk/direct-vision-standard 

24 

 
                                                 
Reduction of traffic casualties can be achieved through the introduction of new vehicle safety 
measure  implementing  legislation,  adopting  existing  implementing  legislation  available  e.g. 
on UNECE level57 to which the EU is a Contracting Party, or by adapting existing mandatory 
legislation in the context of the specific objective. 

Figure 5: Objective tree 

5.  WHAT ARE THE VARIOUS OPTIONS TO ACHIEVE THE OBJECTIVES? 

The main problem to tackle has been identified as the persistent high number of accidents that 
in turn leads to a high number of fatalities and a high number of severe injuries.  

57   Council  Decision  of  27  November  1997  with  a  view  to  accession  by  the  European  Community  to  the 
Agreement  of  the  United  Nations  Economic  Commission  for  Europe  concerning  the  adoption  of  uniform 
technical prescriptions for wheeled vehicles, equipment and parts which can be fitted to and/or be used on 
wheeled  vehicles  and  the  conditions  for  reciprocal  recognition  of  approvals  granted  on  the  basis  of  these 
prescriptions  (‘Revised  1958  Agreement’)  (OJ  L  346,  17.12.1997,  p.  78)  as  last  updated  by  Council 
Decision  (EU)  2016/1790  of  12  February  2016  on  the  conclusion  of  Revision  3  of  the  Agreement  of  the 
United  Nations  Economic  Commission  for  Europe  concerning  the  adoption  of  uniform  technical 
prescriptions for wheeled vehicles, equipment and parts which can be fitted and/or used on wheeled vehicles 
and  the  conditions  for  the  reciprocal  recognition  of  approvals  granted  on  the  basis  of  these  prescriptions 
(‘Revised 1958 Agreement’) (OJ L 274, 11.10.2016, p. 2) 

25 

 
 
 
                                                 
The solutions mentioned below try to address the main problem by either completely avoiding 
and  lower  the  number  of  accidents  or  by  lowering  the  severity  of  un-avoided  accidents  to 
lower the number of fatalities and severe injuries.  

The  different  measures  listed  below  have  been  selected  on  the  basis  of  the  Commission's 
study  ''Benefit  and  Feasibility  of  a  Range  of  New  Technologies  and  Unregulated 
Measures  in  the  fields  of  Vehicle  Occupant  Safety  and  Protection  of  Vulnerable  Road 
Users"58,  that  initially  analysed  over 50  possible vehicle  safety  measures.  The  initial list  of 
potential  measures  was  brought  forward  by  the  Commission,  but  the  stakeholders  added 
possible measures for analysis in the course of the frequent consultations that took place. For 
reasons  of  transparency  this  process  and  the  suggestions  contributed  by  the  various 
stakeholders were fully documented in the respective study. 

All suggested measures were in a first step assessed on the basis of feasibility and expected 
cost-effectiveness.  In  a  second  step a  reduced  list  of  around  20  measures  was  based  on  the 
results  of  the  initial  assessment  and  it  was  looked  at  whether  the  potential  measures  were 
available  through  existing,  robust  or  otherwise  feasible  technologies  and  whether  such 
technologies would be affordable.  

For  all  measures  that  were  assessed  positively,  the  individual  costs  and  benefits  were 
assessed. This was also done for the effectiveness of measures. These assessments were based 
on literature studies or input provided by stakeholders in the course of the consultations.  

Subsequently, in the context of a targeted stakeholder workshop event, all data was explicitly 
shared  with  all  stakeholders  on  ‘fact  sheets’  for  each  individual  measure.  Stakeholders 
were then asked to agree with this data or to provide updated figures and data sources if they 
did  not  agree.  By  this  the  stakeholders  eventually  endorsed  all  input  data  that  was  to  be 
used  for  the  purpose  of  this  Impact  Assessment,  i.e.  the  vehicle  manufacturers,  supplier 
industry, safety advocacy and environmental groups, as regards the costs and effectiveness of 
the range of safety measures. 

In the final stage the stakeholders however insisted that the assessment of the benefits and 
costs for multiple grouped measures would be assessed in a combined fashion, and not on 
individual  basis,  for  each  vehicle  category.  Indeed,  some  of  the  proposed  measures  were 
targeting the same accident type and thus had a mutual influence/interaction on the level of 
their effectiveness. E.g. autonomous braking avoiding a collision vis-à-vis improved restraint 
systems  in  case  of  crashing  –  if  the  collision  is  avoided,  the  improved  restraint  system  is 
effectively  of  no  use,  however,  no  measure  is  100%  effective,  so  there  is  still  a  significant 
merit to improve the restrain systems although its specific effectiveness figure needed  to be 
adjusted  downward.  Some  features  also  use  a  common  technology  (e.g.  forward  looking 
camera  for  autonomous  braking,  lane  keeping  and  intelligent  speed  assistance)  and  their 
grouping would save cost. 

On this basis, the cost and benefit analysis of the measures was adapted accordingly. It should 
be mentioned as a concrete example, that the safety measure of “small overlap crash test” that 
was  one  of  the  20  short-listed  measures  was  potentially  cost-effective  as  a  standalone 
measure,  but  with  the  simultaneous  introduction  of  “lane  keeping”  technology  and  through 
independent accidentology data provided on behalf of the vehicle industry, the occurrence of 

58   http://bookshop.europa.eu/en/benefit-and-feasibility-of-a-range-of-new-technologies-and-unregulated-

measures-in-the-field-of-vehicle-occupant-safety-and-protection-of-vulnerable-road-users-
pbNB0714108/;pgid=Iq1Ekni0.1lSR0OOK4MycO9B0000BAJ9tQVy;sid=OT_-Ap3uO3P-
V8j2wGFgpf_Lm_yCUpo9P-w= 

26 

 
                                                 
such  small  overlap accidents would be starkly reduced and the residual effectiveness would 
no longer weigh up to the cost for structural improvements to the vehicles. 

1.14.  Measures to completely avoid accidents, to reduce the overall severity of 
accidents  or  to  mitigate  the  outcome  of  injuries  in  accidents  between 
vehicles or vehicles and obstacles  

1.1.2.  Frontal impact occurrences 

New advanced safety features: 
Several  of  the  possible  measures  addressing  frontal  impacts  revolve  around  an  active 
intervention by vehicle systems or a general aim to either avoid the frontal impact altogether 
or to mitigate accident outcome in terms of occupant injury levels. Other measures have the 
potential  to  reduce  the  overall  risk  of  a  frontal  impact  collision  or  to  aid  in  terms  of 
measurement of the effectiveness of vehicle safety systems. 

Autonomous  emergency  braking  for  driving  and  still-standing  vehicles  ahead  is  a  new 
vehicle safety measure for LDV, but is already mandatory for HDV. It combines sensing of 
the  environment  ahead  of  the  vehicle  with  the  automatic  activation  of  the  brakes  (without 
driver input) in order to completely stop the vehicle before the collision occurs or to reduce 
the impact speed, the latter also still having great beneficial effect on injury risk59. 

  Action  to  be  considered:  mandatory  application  of  autonomous  emergency 

braking for driving and still-standing vehicles ahead 

Alcohol interlock installation facilitation is a new vehicle safety measure that is expected 
to  lead  to  more  vehicles  being  equipped  with  an  alcohol  interlock  device,  either  on  a 
voluntary basis, due to a national policy for categories of (professional) drivers or as a result 
of  a  national  (recidivist)  fitting  program,  and  that  thus  reduces  the  risk  of  collision 
occurrence. 

  Action to  be considered: mandatory application of  alcohol  interlock installation 

facilitation 

Drowsiness  and  attention  detection  is  a  new  vehicle  safety  measure  that  detects  driver 
inattention  through  system  analysis  over  a  given  timeframe  of  erratic  driving  and  steering 
input,  either  due  to  fatigue  or  due  to  some  activity  that  competes  for  a  driver’s  visual 
attention. Upon detection of driver inattention, the driver receives a warning to resume normal 
attentive driving, or to take a rest, leading to a reduction of the risk of a collision. 

  Action  to  be  considered:  mandatory  application  of  drowsiness  and  attention 

detection 

Distraction  recognition  is  a  further  new  vehicle  safety  measure  that  also  detects  driver 
inattention, but that goes a step further by recognising the situation for which the key shared 
feature is the actual absence of visual attention on the driving task, again either due to fatigue 
or due to some activity that competes for a driver’s visual attention. Upon more or less instant 
detection  of  driver  inattention,  the  driver  receives  a  warning  to  resume  normal  attentive 
driving, leading to a reduction of the risk of frontal collision. 

  Action to be considered: mandatory application of drowsiness recognition 

59   https://ec.europa.eu/transport/road_safety/specialist/knowledge/speed/speed_is_a_central_issue_in_ 

road_safety/speed_and_injury_severity_en 

27 

 
                                                 
Emergency stop signal is a new vehicle safety measure that consists of a rapid flashing of 
the brake lamp when full brakes are applied. This system is designed to address front-to-rear 
accidents.    Drivers  following  a  hard-braking  vehicle  are  instantly  aware  that  the  vehicle  in 
front  is  braking  with  a  high  retardation  so  that  they  can  take  appropriate  action.  It  helps 
drivers to avoid late recognition of the hard-braking situation that might prevent a collision 
or reduce the resulting impact speed. 

  Action to be considered: mandatory application of emergency stop signal 

Intelligent speed assistance  is a new vehicle safety measure that works with the driver to 
provide non-intrusive haptic feedback, preferably through the accelerator pedal that could be 
overridden by the driver, to promote the adoption of a (slightly) reduced speed in accordance 
with  the  maximum  permissible  speed  limit.  Speed  limit  information  would  be  provided 
through a combination of optical recognition of maximum speed signs as well as up-to-date 
detailed map data or real-time over-the-air type data. The link between speed in  excess  and 
increased  severity  and  frequency  of  accidents  has  long  been  established.  This  measure  is 
expected to reduce the risk of collision occurrence, but also the resulting impact speed in 
those collisions that will not be prevented. 

  Action to be considered: mandatory application of intelligent speed assistance 

Lane  keeping  assist  is  a  new  vehicle  safety  measure  that  either  keeps  the  vehicle  in  its 
driving lane by correcting driver steering input where appropriate. In a first step the measure 
recognises that the vehicle is about to leave or no longer follow the appropriate lane, but then 
only actively intervenes to keep within the lane in the particular case where also an imminent 
threat such as leaving the road, or leaving the lane when a collision with other traffic or road 
obstacles is about to occur. This vehicle safety measure therefore reduces the risk of frontal 
collision occurrence through its avoidance potential. 

  Action  to  be  considered:  mandatory  application  of  (emergency)  lane  keeping 

assist 

Tyre pressure monitoring system is a new vehicle safety measure for all vehicle categories 
except  passenger  cars  for  which  it  is  already  mandatory.  The  system  reports  situations  of  a 
critically  underinflated  tyre  to  the  driver.  Underinflated  tyres  can  lead  to  poor  vehicle 
handling  and  increased  stopping  distances,  and  can  result  in  catastrophic  tyre  failure,  and 
subsequent loss of control of the vehicle, due to increased stress and heat build-up in the tyre. 
This vehicle safety measure therefore reduces the risk of collisions through its avoidance 
potential. 

  Action  to  be  considered:  mandatory  application  of  tyre  pressure  monitoring 

system 

Event (accident) data recorder is a new vehicle safety measure for LDV that stores a range 
of vehicle status data over a specific timeframe (short duration in conventional vehicles, long 
duration in vehicles with highly automated functions) before, during and after a crash, usually 
triggered by airbag deployment. It  should facilitate a standardised form of interrogation and 
should store critical crash-related information such as vehicle speed, state of restraint systems, 
detection  and  monitoring  systems,  light  signalling  devices  and  driver  direct  control  input 
parameters (e.g. steering wheel angle, accelerator pedal, brake force), as well as the level of 
activation  and  influence  of  accident  avoidance  systems,  and  further  relevant  vehicle  data  at 
the  time  of  the  collision,  without  linking  it  to  any  data  facilitating  the  identification  of  a 

28 

 
vehicle other than its make, type, variant and version and specific fitted optional equipment. 
Although studies show a range of reductions in accidents when fitted60, the addition of this 
device would actually make the effectiveness of most of the above vehicle safety systems 
measurable, i.e. a key element of setting objectives. The relevant data for the purpose of in 
depth accident analysis should be made available in a considerably more accurate, consistent 
and barrier-free way. 

  Action to be considered: mandatory application of event (accident) data recorder 

Extension of existing measures:  
Occupants  protection  in  frontal  crashes  is  currently  regulated  in  the  EU  through  a  frontal 
impact  off-set  crash  test  that  was  introduced  within  the  EU  in  199661,  subsequently 
harmonised on UNECE level62 and amended several times to account for technical progress. 
The relevant vehicle safety measure is UNECE regulation No 9463. 

As described in section 2.4, heavy passenger cars and all light commercial vehicles are fully 
exempted  from  the  frontal  crash  testing  (as  introduced  in  1996),  based  on  low  market 
availability, difficulties to comply and potential compatibility mismatch that may have been 
applicable  at  the  time.  Presently,  the  exemption  of  these  vehicles  is  no  longer  justified  or 
desirable.  

  Action  to  be  considered:  add  heavy  passenger  vehicles  (e.g.  SUVs)  and  all  light 
commercial vehicles to the scope of the mandatory frontal off-set crash tests 

Further benefits are foreseen in the field of occupant protection in frontal crashes when a new 
type of crash test is added to the above that focuses starkly on improving restraint systems 
(i.e. airbag and safety-belt combinations) to encourage adaptive restraints protecting a broader 
demography of occupants (e.g. small females and elderly) than the current test achieves. The 
test protocol already exists on UNECE level, but the specific objective would further benefit 
from  a  specific  revision  to  enhance  that  protocol.  The  relevant  vehicle  safety  measure  is 
UNECE regulation No 13764 

  Action to be considered: mandatory application of full overlap frontal crash that 
focusses on restraint system (i.e. safety belt and airbag system) performance. 

Finally, a note for information. Safety belt reminder system for the front seats in all motor-
vehicles  and  also  on  the  rear  seats  in  passenger  cars  and  vans  have  in  an  early  stage  of  the 
preparatory  work  also  been  identified  as  a  cost-effective  safety  measure.  This  was  also  the 
case for  improved rear underrun protection device on trucks, removal of exemptions for 
lateral protection devices on Special Purpose trucks, as well as fire prevention measures on 

60   https://ec.europa.eu/transport/sites/transport/files/docs/study_edr_2014.pdf 
61   Directive 96/79/EC 
62   Council  Decision  of  27  November  1997  with  a  view  to  accession  by  the  European  Community  to  the 
Agreement  of  the  United  Nations  Economic  Commission  for  Europe  concerning  the  adoption  of  uniform 
technical prescriptions for wheeled vehicles, equipment and parts which can be fitted to and/or be used on 
wheeled  vehicles  and  the  conditions  for  reciprocal  recognition  of  approvals  granted  on  the  basis  of  these 
prescriptions  (‘Revised  1958  Agreement’)  (OJ  L  346,  17.12.1997,  p.  78)  as  last  updated  by  Council 
Decision  (EU)  2016/1790  of  12  February  2016  on  the  conclusion  of  Revision  3  of  the  Agreement  of  the 
United  Nations  Economic  Commission  for  Europe  concerning  the  adoption  of  uniform  technical 
prescriptions for wheeled vehicles, equipment and parts which can be fitted and/or used on wheeled vehicles 
and  the  conditions  for  the  reciprocal  recognition  of  approvals  granted  on  the  basis  of  these  prescriptions 
(‘Revised 1958 Agreement’) (OJ L 274, 11.10.2016, p. 2) 

63   OJ L 254, 20.9.2012, p. 77 
64   Not yet published 

29 

 
                                                 
buses.  These  matters  have  in  the  meantime  all  been  adequately  addressed  in  the  context  of 
technological progress in the respective UNECE regulations and will thus become obligatory 
in accordance with the transitional provisions in those regulations. 

1.1.3.  Side impact occurrences 

This is currently regulated in the EU through a side impact crash test that was introduced in 
199665  on  EU  level,  that  was  subsequently  harmonised  on  UNECE  level,  and  that  has  been 
amended several times to account for technical progress. The relevant vehicle safety measure 
is UNECE regulation No 9566. 

As  described  in  section  2.3,  certain  vehicles  with  ‘high’  seating  positions  are  currently 
exempted from the side crash testing as introduced in 1996, that causes other safety criteria 
that are normally also checked in this test to be omitted as well. In line with the clarification 
provided for frontal impact off-set crash, the exemption of these vehicles is no longer justified 
or desirable. 

  Action to be considered: add vehicles with a high seating position (e.g. SUVs and 

vans) to the scope of the mandatory side impact crash tests 

Additional  benefits  are  foreseen  in  the  field  of  occupant  protection  in  side  impact  crashes 
when a new type of side impact crash test is added to the above that focuses on a vehicle 
side collision with a rigid narrow pole (i.e. pole side impact when skidding off the road) to 
demand a much better protection in the head strike area of the occupants with interior parts of 
the  vehicle  (e.g.  side  curtain  airbag  protection).  The  vehicle  safety  measure  already  exists, 
namely in the form of UNECE regulation No 13567 

  Action to be considered: mandatory application of pole side impact crash test  

Review  of  further  new  vehicle  safety  measures  and  opportunities  having  a  significant 
potential to address side impacts: 

  Autonomous emergency braking for driving and still-standing vehicles ahead 
  Alcohol interlock installation facilitation 
  Drowsiness and attention detection 
  Distraction recognition 
  Intelligent speed assistance 
  Tyre pressure monitoring system 
  Event (accident) data recorder 

1.1.4.  Rear impact occurrences 

There are no measures currently at our disposal that should be amended to reach this specific 
sub-objective,  nor  are  there  proposed  new  vehicle  safety  measures  that  are  specifically  and 
exclusively  geared  towards  it.  The  only  existing  legislation  that  regulates  rear  impacts 
revolves  around  head  restraint  performance  in  UNECE  regulation  No  1768  to  mitigate  the 
effects  on  occupants  in  terms  of  whiplash  protection.  However,  this  regulation  is  subject  to 
adaptations  to  technical  progress  in  the  context  of  ongoing  regulatory  work  under  UNECE 

65   Directive 96/27/EC 
66   OJ L 183, 10.7.2015, p. 91 
67   Not yet published 
68   OJ L 230, 31.8.2010, p. 81 

30 

 
                                                 
and  the  beneficial  effects  thereof  are  therefore  incorporated  into  the  baseline  scenario  in 
which no specific additional EU regulatory actions are taken. 

On  the  other  hand,  UNECE  regulation  No  3469  on  fire  risks,  fuel  tanks  and  rear  impact 
protection, applies on an obligatory basis in the EU. Again, this legislation suffers from the 
fact that specific exemptions apply which has the detrimental effect that those vehicles are not 
tested  in  terms  of  post-crash  protection  against  fire  risks.  It  is  also  explicitly  necessary  to 
accelerate  the  work  on  including  protection  against  electric  shock  in  the  regulation,  as  has 
been done for all other vehicle crash legislation on UNECE level, as that is currently not yet 
the case for this regulation. This is particularly important given that (hybrid) electric vehicle 
propulsion  battery  packs  are  often  located  in  the  rear  luggage  compartment  section  of 
conventional vehicles.  

  Action to be considered: add the  mandatory application for rear impact testing 

and also address post-crash electric safety 

Review  of  further  new  vehicle  safety  measures  and  opportunities  having  a  significant 
potential to address rear impacts: 

  Autonomous emergency braking for driving and still-standing vehicles ahead 
  Alcohol interlock installation facilitation 
  Drowsiness and attention detection 
  Distraction recognition 
  Emergency stop signal 
  Intelligent speed assistance 
  Tyre pressure monitoring system 
  Event (accident) data recorder 

1.15.  Measures to completely avoid accidents, to reduce the overall severity of 
accidents  or  to  mitigate  the  outcome  of  injuries  that  result  from  impacts 
between vehicles and pedestrians and cyclists 

1.1.5.  Pedestrian and cyclist protection when hit by front-of-vehicle  

This specific aspect is currently regulated for LDV through Regulation (EC) No 78/2009 of 
the  European  Parliament  and  of  the  Council  on  the  type-approval  of  motor  vehicles  with 
regard  to  the  protection  of  pedestrians  and  other  vulnerable  road  users,  along  with  its 
implementing measures. More recently these requirements have been harmonised on UNECE 
level, with some adaptation to technical progress, under UNECE regulation No 12770. 

The  EU  legislation,  and  rather  preferably  also  the  UNECE  legislation  in  order  to  facilitate 
future  simplification,  should  be  revised  to  enlarge  the  current  head  impact  zone  as 
supported  by  EU  accident  data,  to  achieve  that  the  risk  of  severe  head  injuries  of 
pedestrians  and  cyclists  is  reduced  by  means  of  improved  energy  absorbing  measures 
integrated in a bigger overall head contact zone, notably including the front windscreen area 
between the A-pillars.  

  Action to be considered: adding head impact area covering the windscreen area 

of motor-vehicles 

69   OJ L 231, 26.8.2016, p. 41 
70   Not yet published 

31 

 
                                                 
This Impact Assessment also reviews possible new vehicle safety measures addressing front-
of-vehicle collisions with vulnerable road users. Several of these measures revolve around an 
active  intervention  by  vehicle  systems  or  a  general  aim  to  either  avoid  collisions  with 
vulnerable road users altogether or to mitigate accident outcome in terms of vulnerable road 
user injury levels. Other measures have the potential to reduce the overall risk of a collision. 

Autonomous  emergency  braking  for  pedestrians  and  cyclists  is  a  new  vehicle  safety 
measure  that  combines  sensing  of  vulnerable  road  users  ahead  of  the  vehicle  with  the 
automatic  activation  of  the  brakes  (without  driver  input)  in  order  to  completely  stop  the 
vehicle before the collision occurs or to reduce the impact speed. 

  Action  to  be  considered:  mandatory  application  of  autonomous  emergency 

braking for pedestrians and cyclists 

It  is  noted  that  while  autonomous  emergency  braking  (for  vehicles  ahead)  is  already 
compulsory on buses and trucks, the relevant implementing legislation should be adapted to 
technical progress by adding pedestrian and cyclist detection capability as well. 

Vulnerable  road  user  detection  and  warning  on  front  (and  side)  of  vehicle  is  a  new 
vehicle  safety  measure  that  uses  sensing  detection  or  camera  monitor  solutions  to 
specifically draw the attention of the driver if necessary and to clearly indicate the presence 
and  the  location  of  a  vulnerable  road  user  in  or  about  to  be  in  the  vehicle  path  where  a 
collision is likely to occur if the driver does not take any countermeasures. According to EU 
accident  data,  the  system  should  in  particular  indicate  the  presence  of  a  pedestrian,  and  to 
some extent cyclists, either visible or invisible to the driver when crossing the motor-vehicle 
relatively  close  to  its  front  edge  when  the  vehicle  is  about  to  take-off,  for  instance  for  a 
truck stopped at a zebra crossing. This measure is aimed to avoid collisions with persons, 
but without active intervention by the system itself.  

  Action to be considered: mandatory application of vulnerable road user detection 

and warning on front (and side) of vehicle 

Vulnerable  road  user  improved  direct  vision  from  driver’s  position  is  a  new  vehicle 
safety measure geared towards enlarging the field of vision of drivers in bus and truck cabs. 
Assuming that the driver is aware of the presence of a vulnerable road user in front of the 
vehicle,  or  his  or  her  attention  has  been  drawn  to  that  fact,  the  effectiveness  relies  on  the 
direct  visual  confirmation  by  the  driver  that  can  take  the  appropriate  counter  measures  to 
avoid a collision with the person. 

  Action  to  be  considered:  mandatory  application  of  vulnerable  road  user 

improved direct vision from driver’s position 

In  line  with  section  5.1.1.  the  following  are  further  new  vehicle  safety  measures  for  review 
that  also  has  a  significant  potential  to  completely  avoid  front-of-vehicle  collisions  with  a 
pedestrian  or  cyclist  or  to  mitigate  injury  outcome.  Other  measures  have  the  potential  to 
reduce  the  overall  risk  of  a  front-of-vehicle  collision  with  a  vulnerable  road  user  or  to  help 
measure advanced safety system effectiveness: 

  Alcohol interlock installation facilitation 
  Drowsiness and attention detection 
  Distraction recognition 
  Intelligent speed assistance 
  Lane keeping assist 
  Event (accident) data recorder 

32 

 
1.1.6.  Pedestrian and cyclist protection when hit by side-of-vehicle 

There are no measures currently at our disposal that should be amended to reach this specific 
sub-objective. 

Review  of  possible  new  vehicle  safety  measures  addressing  side-of-vehicle  collisions  with 
vulnerable road users: 

Vulnerable  road  user  detection  and  warning  on  (front  and)  side  of  vehicle  is  a  new 
vehicle safety measure, as described in chapter 5.2. EU accident data in this case supports 
that  cyclists,  and  to  some  extent  pedestrians,  should  be  detected  at  the  side  of  the  vehicle 
when  it  is  making  a  turn  towards  the  driver’s  far-side  and a  collision  is  about  to  occur,  for 
instance a cyclist riding along the side of a truck in the blind spot. This measure is aimed 
to avoid collisions with persons, but without active intervention by the system itself.  

  Action to be considered: mandatory application of vulnerable road user detection 

and warning on (front and) side of vehicle 

Vulnerable  road  user  improved  direct  vision  from  driver’s  position  is  a  new  vehicle 
safety measure, as described in chapter 5.2. for the presence of a vulnerable road user on 
the side of the vehicle, or his or her attention has been drawn to that fact, the effectiveness 
relies  on  the  direct  visual  confirmation  by  the  driver  that  can  take  the  appropriate  counter 
measures to avoid a collision with the person. 

  Action  to  be  considered:  mandatory  application  of  vulnerable  road  user 

improved direct vision from driver’s position 

Review  of  further  new  vehicle  safety  measures  and  opportunities  having  a  significant 
potential to address side-of-vehicle collisions with vulnerable road users: 

  Alcohol interlock installation facilitation 
  Drowsiness and attention detection 
  Distraction recognition 
  Intelligent speed assistance 

1.1.7.  Pedestrian and cyclist protection when hit by rear-of-vehicle 

There are no measures currently at our disposal that should be amended to reach this specific 
sub-objective. 

Review  of  possible  new  vehicle  safety  measures  addressing  rear-of-vehicle  collisions  with 
vulnerable road users: 

Reversing  camera  or  detection  system  is  a  new  vehicle  safety  measure  that  uses  camera 
monitor or sensing systems that should increase the view of drivers or otherwise warn them of 
persons behind reversing vehicles. Particularly vulnerable in this context are short, crouching 
or  slow  moving  people,  such  as  the  elderly  and  children.  The  system  should  in  particular 
indicate  presence  of  a  vulnerable  road  user,  either  (indirectly)  visible  or  invisible  to  the 
driver when reversing, but without active intervention by the system itself. 

Review  of  further  new  vehicle  safety  measures  and  opportunities  having  a  significant 
potential to address rear-of-vehicle collisions with vulnerable road users: 

  Alcohol interlock installation facilitation 
  Event (accident) data recorder 

33 

 
1.16.  Policy option “Baseline” 

This is the option whereby the EU would not undertake any new action.  

In line with the standards of the Commission, it is assumed that no actions other than those 
already initiated would take place, including the adaptation to technical progress of measures 
currently in force, as is common practise today. The baseline scenario also takes into account 
the dispersed voluntary uptake of available safety technologies by vehicle manufacturers, for 
instance  with  the  aim  to  obtain  favourable  reviews  and  ratings  in  new  car  assessment 
programs such as Euro NCAP. 

It is understood that the baseline scenario provides for a wide range between pessimistic and 
optimistic outlooks. In  this  initiative however,  we have  adopted a conservative approach  by 
selecting  the  medium  effectiveness  in  assuming  that  the  other  sectors, for  different  political 
reasons, will take initiatives to improve road safety at local, national and Union level where 
this could be applicable.  

1.17.  Policy  options  “Regulatory  approach”  to  prevent  road  accidents  or  to 

mitigate the outcome of accidents 

Based on the preparatory work carried out to support the Report on “Saving lives: Boosting 
Car  Safety  in  the  EU”,  and  in  particular  the  consideration  of  the  initial  and  subsequent  in 
depth  cost-benefit  indicators,  a  comprehensive  list  of  proposed  vehicle  safety  measures  is 
considered for implementation (Table 1). The elimination of exemptions that currently exist 
for  front,  side  and  rear  impact  should  be  considered  as  well.  Note  that  trailers  and  semi-
trailers  of  categories  O3  and  O4  are  to  be  considered  as  part  of  the  overall  motor-vehicle 
combination according to EU accident data and that no further distinction is made. 

Table 1: List of all new safety measures considered for mandatory implementation that 
can be integrated into the indicated vehicle categories 

Measure 

Description 

Applicable vehicle categories 

Passenger 
cars 

Light 
commercial 
vehicles 

Buses 

Trucks and 
trailers 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

VIS-DET 

VIS-DIV 

Autonomous  emergency  braking  for  driving  and  still-
standing vehicles ahead 
Autonomous emergency braking for pedestrians and cyclists 

Alcohol interlock installation facilitation 

Drowsiness and attention detection 

Distraction recognition 

Event (accident) data recorder 

Emergency stop signal 

Full-width frontal occupant protection crash test 
Full-width  frontal  occupant  protection  crash  test  with 
advanced  measuring  dummy  and  lower  appropriate  injury 
criteria thresholds to encourage adaptive restraints 
Head  impact  zone  enlargement  for  pedestrian  and  cyclist 
protection (to include the windscreen area) 
Intelligent  speed  assistance  (through  non-intrusive  haptic 
feedback) 
Lane  keeping  assist  (emergency  lane  keeping  system  that 
intervenes  only  in  case  of  an  imminent  threat  such  as 
leaving the road, or leaving the lane with oncoming traffic) 
Pole side impact occupant protection 

Reversing camera or detection system  

Tyre pressure monitoring system 
Vulnerable  road  user  detection  and  warning  on  front  and 
side of vehicle 
Vulnerable  road  user  improved  direct  vision  from  driver’s 
position 

34 

M1 

M1 
M1 
M1 
M1 
M1 
M1 
M1 

M1 

M1 

M1 

M1 

M1 
M1 

N1 

N1 
N1 
N1 
N1 
N1 
N1 
N1 

N1 

N1 

N1 

N1 

N1 
N1 
N1 

M2 & M3  
M2 & M3  
M2 & M3  

N2 & N3  
N2 & N3  
N2 & N3  

M2 & M3  

N2 & N3  

M2 & M3  

N2 & N3  

M2 & M3  
M2 & M3  

N2 & N3  
N2 & N3  

M2 & M3  

N2 & N3  

M2 & M3  

N2 & N3  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  cost-effectiveness  analysis  also  specifically  takes  into  account  existing  mandatory 
measures and, in particular those that are still dispersing into the fleet. These will continue to 
contribute to casualty reductions in the real world in the future and, thus, effectively reduce 
the target populations for some of the proposed measures (see Table 2). 

Table 2: List of existing mandatory safety measures still dispersing into the fleet 

Measure 

Description 

Applicable vehicle categories 

AEB-VEH 

Autonomous emergency braking for vehicles 

ESC 

LDW 

TPM 

Electronic stability control 

Lane departure warning 

Tyre pressure monitoring system 

Passenger 
cars 

Light 
commercial 
vehicles 

N1 

M1 

M1 

Buses 

M2 & M3  
M2 & M3  
M2 & M3  

Trucks 
and 
trailers 
N2 & N3  
N2 & N3  
N2 & N3  

Three  policy  options  to  be  taken  into  consideration  for  the  cost-benefit  analysis  have  been 
defined.  These  policy  options  reflect  a  specific  selection  of  new  safety  measures  to  be 
implemented  for  a  given  vehicle  category  on  a  mandatory  basis,  as  established  for  all 
vehicle categories. The options are distinguished primarily by the level of ambition. They are 
separated on the following basis: 

−  First, by containing a set of state-of-the art measures that that can already be found on 
5%  to  90%  of  all  new  cars  sold  today  depending  on  the  technology  and  the  vehicle 
category; 

−  Second, by, in addition, containing safety measures that are somewhat less frequently 
fitted to current vehicle models and that may require a longer development lead-time 
for the other vehicle models to be also enabled; and 

−  Third, by considering the above plus maximising the overall casualty savings spread 
over all vehicle categories, while also promoting innovation in terms of vehicle safety 
solutions  designed  to  address  driver  behaviour  in  terms  of  modern-day  distraction 
sources  and  lack  of  effort  or  inability  to  continuously  check  vehicle  state  or  the 
surroundings. 

1.1.8.  Design of options and timeframe for implementation 

The  options  distinguish  in  terms  of  ambition  as  well  as  efforts  needed  and  technological 
readiness  of  safety  features.  The  first  option  can  be  quickly  and  easily  implemented  by 
manufacturers. The second option requires more R&D effort and engineering solutions for a 
robust integration. The third option needs considerably more R&D effort and innovation. 

In  order  to  calculate  the  cost-benefits,  the  envisioned  mandatory  introduction  date  of  each 
separate measure has been taken into account. These dates have a significant influence on the 
short  and  long  term  effectiveness.  They  have  however  been  selected  purely  taking  into 
account  in  particular  the  readiness  of  potential  technical  solutions  in  the  marketplace, 
according to broad stakeholder input. Further such input was provided specifically linked to 
the anticipated relative burden to the vehicle industry and in particular the effort that is needed 
to  further  optimise  the  technical  solutions  as  indicated  by  manufacturers  and  suppliers.  For 
example, some technologies that have been chosen by manufacturers and suppliers to address 
a given safety issue, as recognised in the stakeholder dialogue, can benefit from a more robust 
performance for which more field-data and real-world experience is necessary. A longer lead-
time will provide manufacturers appropriate additional time to achieve that. This also allows 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
them to investigate potential alternative solutions if that would be more appropriate. The dates 
that  have  finally  been  selected  are  fully  in  line  with  the  agreed  CARS21  principles71  as 
endorsed and promoted by the Commission. This has in particular also been a clear and firm 
request by the vehicle manufacturers in the context of the consultations and in their various 
position papers.  Finally, in the context of the UNECE ‘Revised 1958 Agreement’, the dates 
are  set  to  the  1st  of  September  of  a  given  year  aligning  with  general  implementation  dates 
following  the  agreed  principle  for  UNECE  regulations72.  This  avoids  the  situation  for 
manufacturers to introduce so-called ‘running changes’ in the production process but rather to 
anticipate  on  several  vehicle  changes  in  one  single  model  year  update,  as  is  the  industry 
practise. 

The mandatory introduction dates are grouped into three main timeframes,  where new 
vehicle  types  (i.e.  entirely  new  vehicle  models  introduced  on  the  EU  market)  will  have  to 
comply  with  the  new  requirements  at  a  first  stage,  followed  by  all  vehicles  sold  on  the  EU 
market, in particular those that were introduced on the market before the ‘new vehicle type’ 
date, at a second stage:  

•  From 1 September 2021 to 1 September 2023: This timeframe is applicable to the bulk 
of  possible  new  vehicle  safety  features  (in  total  13  features),  which  represent  ‘add-on’ 
solutions  that  are  already  available  on  vehicles  in  the  marketplace  and  will  become 
standard equipment for all vehicles.  

•  From 1 September 2023 to 1 September 2025: This timeframe concerns 3 features, for 
which  still  a  significant  effort  of  further  development  and  evaluation  is  needed  beyond 
the start date of the first timeframe in order to ensure that technical solutions can deliver 
the expected effectiveness.  

•  From 1 September 2025: This longer timeframe is provided only for 1 feature, namely 
the improved direct vision from driver's position for HDVs, which will require significant 
investment, re-design and changes of the cabins. The mandatory compliance date for new 
vehicle  types  remains  open  to  avoid  disproportionate  and  not  cost-effective  phase-out 
complications for vehicle manufacturers. 

1.1.9.  Policy option 1: Generalisation of mature and widely available safety 

features 

State-of-the-art  and  widely  available  package  of  safety  measure  solutions  that  are  not  yet 
mandatory in the EU and their fitment varies from around 5 to 90% on newly sold vehicles at 
present (see Table 3) as well as the elimination of the exemptions linked to SUVs and vans. 

Table 3: List of mandatory safety measures in PO1 

Measure 

Description 

Applicable vehicle categories 

Passenger 
cars 

M1 

Light 
commercial 
vehicles 
N1 

Buses 

M2 & M3 

Trucks 
and 
trailers 
N2 & N3 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

Autonomous emergency braking for driving and still-
standing vehicles ahead 
Autonomous emergency braking for pedestrians and cyclists 

9/2021 

9/2021 

- 

- 

Alcohol interlock installation facilitation 

9/2021 

9/2021 

9/2021 

9/2021 

Drowsiness and attention detection 

Distraction recognition 

Event (accident) data recorder 

- 

- 

- 

- 

- 

- 

- 

- 

9/2021 

9/2021 

71   http://ec.europa.eu/DocsRoom/documents/1891/attachments/1/translations/en/renditions/pdf 
72   https://www.unece.org/fileadmin/DAM/trans/doc/2016/wp29/WP29-169-11.pdf - Transitional Provisions  

36 

 
 
 
 
 
 
 
 
 
 
 
                                                 
9/2021 

9/2021 

9/2021 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

VIS-DET 

VIS-DIV 

Emergency stop signal 

Full-width frontal occupant protection crash test 
Full-width frontal occupant protection crash test with 
advanced measuring dummy and lower appropriate injury 
criteria thresholds to encourage adaptive restraints 
Head impact zone enlargement for pedestrian and cyclist 
protection (to include the windscreen area) 
Intelligent speed assistance (through non-intrusive haptic 
feedback) 
Lane keeping assist (emergency lane keeping system that 
intervenes only in case of an imminent threat such as 
leaving the road, or leaving the lane with oncoming traffic) 
Pole side impact occupant protection 

Reversing camera or detection system  

Tyre pressure monitoring system 
Vulnerable road user detection and warning on front and 
side of vehicle 
Vulnerable road user improved direct vision from driver’s 
position 

9/2021 

9/2021 

- 

- 

- 

- 

- 

- 

- 

9/2021 

9/2021 

9/2021 

- 

- 

- 

- 

Benefit-to-cost ratio 

Total cost per vehicle 

Fatalities prevented 

Severe injuries prevented 

2.95 

€ 201 

13 785 

63 493 

1.78 

€ 131 

852 

4 074 

Slight injuries prevented 

276 815 

11 208 

- 

- 

- 

- 

- 

4.64 

€ 6 

2 

33 

113 

- 

- 

- 

- 

- 

0.56 

€ 6 

0 

47 

157 

1.1.10.  Policy  option  2:  Introducing  widely  available  and  less  commonly 

available safety features as standard equipment 

In addition to PO1, this option includes features that are currently also available and fitted to 
the  vehicle  fleet,  but  which  are  less  common  and  need  more  time  to  fully  mature  for  all 
vehicle categories and market segments. It also contains measures ensuring driver attention to 
the driving task and with an overall view on cost effectiveness (see Table 4). 

Table 4: List of mandatory safety measures in PO2 

Measure 

Description 

Applicable vehicle categories 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

VIS-DET 

Autonomous emergency braking for driving and still-
standing vehicles ahead 
Autonomous emergency braking for pedestrians and cyclists 

Alcohol interlock installation facilitation 

Drowsiness and attention detection 

Distraction recognition 

Event (accident) data recorder 

Emergency stop signal 

Full-width frontal occupant protection crash test 
Full-width frontal occupant protection crash test with 
advanced measuring dummy and lower appropriate injury 
criteria thresholds to encourage adaptive restraints 
Head impact zone enlargement for pedestrian and cyclist 
protection (to include the windscreen area) 
Intelligent speed assistance (through non-intrusive haptic 
feedback) 
Lane keeping assist (emergency lane keeping system that 
intervenes only in case of an imminent threat such as 
leaving the road, or leaving the lane with oncoming traffic) 
Pole side impact occupant protection 

Reversing camera or detection system  

Tyre pressure monitoring system 
Vulnerable road user detection and warning on front and 
side of vehicle 

37 

Passenger 
cars 

M1 

Light 
commercial 
vehicles 
N1 

Buses 

M2 & M3 

Trucks 
and 
trailers 
N2 & N3 

9/2021 

9/2021 

9/2021 

9/2021 

- 

9/2021 

9/2021 

- 

9/2021 

9/2021 

9/2023 

9/2021 

9/2021 

- 

9/2021 

9/2021 

9/2021 

9/2021 

9/2023 

9/2021 

9/2021 

- 

9/2021 

9/2021 

- 

- 

9/2023 

9/2023 

9/2021 

- 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

- 

- 

- 

- 

- 

- 

- 

- 

9/2021 

9/2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
VIS-DIV 

Vulnerable road user improved direct vision from driver’s 
position 

9/2025 

9/2025 

Benefit-to-cost ratio 

Total cost per vehicle 

2.14 

€ 360 

Fatalities prevented 

20 081 

Severe injuries prevented 

Slight injuries prevented 

107 913 

389 756 

1.35 

€ 206 

1 005 

5 068 

15 536 

3.11 

€ 607 

207 

2 064 

6 421 

1.52 

€ 607 

1 658 

3 888 

9 849 

1.1.11.  Policy option 3: Introduction of a full set of safety features boosting 

innovation 

As PO2, plus additional safety solutions that are feasible and already exist in the marketplace, 
but  that  have  a  low  fitment  rate  and  market  uptake.  However,  they    would  maximise  the 
overall casualty savings in the EU and have the potential to boost safety solution innovation 
in the key automotive sector (see Table 5). 

Table 5: List of mandatory safety measures in PO3 

Measure 

Description 

Applicable vehicle categories 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

VIS-DET 

VIS-DIV 

Autonomous emergency braking for driving and still-
standing vehicles ahead 
Autonomous emergency braking for pedestrians and cyclists 

Alcohol interlock installation facilitation 

Drowsiness and attention detection 

Distraction recognition 

Event (accident) data recorder 

Emergency stop signal 

Full-width frontal occupant protection crash test 
Full-width frontal occupant protection crash test with 
advanced measuring dummy and lower appropriate injury 
criteria thresholds to encourage adaptive restraints 
Head impact zone enlargement for pedestrian and cyclist 
protection (to include the windscreen area) 
Intelligent speed assistance (through non-intrusive haptic 
feedback) 
Lane keeping assist (emergency lane keeping system that 
intervenes only in case of an imminent threat such as 
leaving the road, or leaving the lane with oncoming traffic) 
Pole side impact occupant protection 

Reversing camera or detection system  

Tyre pressure monitoring system 
Vulnerable road user detection and warning on front and 
side of vehicle 
Vulnerable road user improved direct vision from driver’s 
position 

Passenger 
cars 

M1 

Light 
commercial 
vehicles 
N1 

Buses 

M2 & M3 

Trucks 
and 
trailers 
N2 & N3 

9/2021 

9/2021 

9/2023 

9/2021 

9/2021 

9/2023 

9/2021 

9/2021 

9/2021 

9/2023 

9/2021 

9/2021 

9/2023 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2023 

9/2023 

9/2021 

9/2021 

9/2023 

9/2021 

9/2021 

9/2023 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

0.53 

€ 521 

1 283 

6 917 

23 486 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2021 

9/2025 

9/2025 

2.11 

€ 970 

227 

2 410 

8 174 

1.03 

€ 1,013 

1 947 

5 023 

13 274 

Benefit-to-cost ratio 

Total cost per vehicle 

1.39 

€ 516 

Fatalities prevented 

21 337 

Severe injuries prevented 

Slight injuries prevented 

126 390 

470 747 

38 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.18.  Options discarded at an early stage 

1.1.12.  Policy option “Self-regulation”   

This  would  concern  the  possibility  of  using  an  industry  self-commitment  to  increase  the 
vehicle safety in terms of occupant protection as well as protection of pedestrians and cyclists 
in the event of an accident, and potential other vehicle safety areas. 

Self-regulation and commitment by the vehicle industry, agreed by a specific number of 
manufacturers  covering  a  certain  percentage  of  the  EU  vehicle  market,  to  increase  vehicle 
safety  in  terms  of  occupant  protection  in  front,  side  and  rear  impacts.  In  this  case,  industry 
would commit to meeting certain to-be-agreed performance requirements that could be taken 
from various sources such as SAE73, ISO74 or new car assessment programmes, e.g. in the EU 
or U.S.75  

This  option  has  been  discarded  for  the  following  reasons.  First  this  would  require,  for 
achieving tangible results, to involve a large number of European and foreign manufacturers 
with no guarantee to cover all categories of vehicles. Second, there is no political support for 
this  approach  from  the  European  Parliament  and  Member  States  and  it  is  also  clearly  not 
supported  by  the  majority  of  respondents  and  stakeholders  in  the  public  consultation  that 
requested an opinion on this matter specifically. Third, a previous attempt to self-regulate the 
inclusion of safety features (energy absorbing bonnets and bumpers) failed in 200176. 

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

AFFECTED? 

Given  the  various  three  options  under  consideration  pursue  the  same  logic,  i.e.  addition  of 
advanced  safety  features,  and  only  differ  by  their  intensity  (number  of  features  added),  the 
analysis of impacts does not necessarily discriminate between the three options. 

1.19.  Social impact  

In  terms  of  the  various  policy  options,  traffic  accidents  still  affect  hundred  thousands  of 
citizens  and  their  families.  The  social  cost  of,  for  instance,  rehabilitation,  healthcare,  death, 
material damages, etc., due to road casualties is estimated to be at least in the order of EUR 
100 billion per year as also quantified in section 2. The expected reduction in the number of 
road  fatalities,  severe  injuries  and  slight  injuries  will  therefore  have  a  positive  impact  on 
social costs. 

So far, advanced safety features have mainly been incorporated in the high-end car segment. 
Thus, mainly  people with  high incomes  could benefit from  such  measures. The compulsory 
addition  of  advanced  safety  features  on  cars  will  contribute  to  distribute  more  evenly  the 
benefits from these features among EU citizens, regardless of income considerations.   

In this context, there have been repeated requests from the European Parliament for resolute 
and  determined  action  by  the  Commission,  as  well  as  Member  States  calling  for  the 
Commission to act, adhering to a strict regulatory approach.  

73   http://topics.sae.org/safety/standards/automotive/ 
74   https://www.iso.org/search/x/query/vehicle%2520safety 
75   http://www.iihs.org/ 
76 Commission Communication (COM(2001)389final) concerning the voluntary agreement on safer cars fronts 

with the European car Industry (ACEA° 

39 

 
                                                 
Some  concerns  have  however  been  expressed  regarding  the  impact  of  the  introduction  of 
Event  Data  Recorders  on  privacy  of  data.  One  of  the  stakeholders  (FIA)  even  suggested 
carrying out an impact study before taking further steps. The intention is that data contained 
in  the  Event  Data  Recorders  should  not  be  linked  to  the  vehicle  identification  number  or 
chassis number and thus should allow for anonymised treatment of the information. 

Some  literature  suggests  that  policy  intervention  such  as  introduction  of  compulsory  new 
safety  measures  could  encourage  reckless  driving  behaviour  due  to  additional  sense  of 
security,  although  the  views  are  generally  not  substantiated.  Respondents  to  the  public 
consultation however have not raised this as a potential issue for this initiative or the specific 
vehicle safety measures as foreseen. 

1.20.  Environmental impact 

The current initiative is also expected to have positive environmental impacts. Throughout the 
stakeholder consultations no evidence was brought forward that alluded to any vehicle mass 
increase  because of the addition of  proposed vehicle safety  measures that  would be of such 
significance that it would have a negative environmental impact. Rather on the contrary, some 
of  the  proposed  technologies  can  help  contribute  to  the  reduction  of  CO2  emissions  and 
therefore to comply with the EU targets on climate action and to the objectives of the Energy 
Union. For instance, tyre pressure monitoring affects the wear rate of the tyre as well as the 
stability and braking performance of the vehicle increasing its safety on the road. However, 
proper  tyre  pressure  also  reduces  rolling  resistance  and  thus  saves  fuel  and  reduces  CO2 
emissions,  with  a  relative  effect  estimated  from  -0.12%  to  -0.43%  depending  on  vehicle 
category77.  The  impact  on  CO2  was  emphasized  also  during  public  consultation:  “CLEPA 
supports  further 
technical 
requirements  which  enable  also  efficient  contribution  to  the  reduction  of  fuel  consumption 
and CO2 emissions.” 

tyre  pressure  monitoring  system 

implementation  of 

the 

In addition, fuel savings and CO2 emissions reduction in the range of 1% to 9% depending on 
road type resulting from even a slight reduction of average vehicle speed, may be attributable 
to intelligent speed assistance (ISA) systems78. Further benefits were identified in the form of 
potential  reduction  of  overall  journey  time  or  idling  time,  due  to  motorway  speed 
management potential and traffic incident reductions. 

Finally  each  accident  prevented  reduces  waste  due  to  scrapping  damaged  cars/parts  and 
replacing with new ones (e.g. in the NL car damage cost was estimated at between EUR 2,000 
and EUR 4,000)79.  

1.21.  Economic impact 

Generally, there will be additional cost associated with mandating new vehicle safety features. 
This is due to the fact that new content, materials and equipment is likely to be added to each 
vehicle and should be taken into account. Furthermore, engineering, development, validation 
and type-approval certification costs of the vehicle safety features are also applicable and add 
to the overall cost as well. In principle this will entail an increasing cost of vehicles for the 
public.  

77   https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/heavy/docs/tno_2013_final_report_en.pdf 
78   https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/ldv_speed_control_devices_en.pdf 
79   The cost of road crashes in the Netherlands. 2016. Page 80. 

 https://www.government.nl/documents/reports/2016/11/16/the-cost-of-road-crashes-in-the-netherlands 

40 

 
                                                 
It is worth mentioning however that in the public consultation most of the respondents do not 
expect  the  introduction  of  the  new  safety  features  to  lead  to  a  price  increase.  Instead  it  is 
expected that safety features will become cheaper anyway and that car insurance will decrease 
as well. This view is largely supported by price change analysis that has been carried out in 
relation to other new vehicle requirements (see section 6.3.3). 

As far as SMEs are concerned, no major impacts are to be expected, also with reference to the 
analysis in terms of purchase price. 

At the level of car manufacturers, most companies are large companies. The number of SMEs 
is  extremely  limited.  They  either  produce  small-series  or  are  considered  ultra-small  volume 
manufacturers.  In  the  course  of  the  stakeholder  consultation  events  and  in  the  public 
consultation phase, they have  clearly expressed their concerns indicating that new measures 
could  bring  significant  cost  due  to  engineering  complexity  or  lack  of  access  to  on-the-shelf 
technology  as  is  the  case  for  large  manufacturers.  The  cost  of  in-house  development  is  not 
likely to be off-set because of limited vehicle production numbers, while the impact on safety 
of  these  vehicles  is  negligible  in  the  overall  vehicle  fleet.  These  issues  can  already  be 
addressed  through  the  existing  legislative  framework  that  indeed  already  contains  specific 
provisions for small series manufacturers80.  

At the level of suppliers, over 3000 SMEs are in one way or another involved in the supply 
chain and likely to benefit from additional demand81. This is also expected to be the case for 
SMEs involved in e.g. knowledge based engineering services, testing and validation. 

In  terms  of  concrete  costs  associated  to  specific  mandatory  vehicle  safety  features,  whether 
the end-consumer will indeed see a vehicle price increase or not, the policy options are each 
studied  for  their  cost-effectiveness  compared  to  a  baseline  scenario,  where  none  of  the 
measures  are  implemented  on  a  mandatory  basis,  but  voluntary  uptake  would  continue  (i.e. 
Policy  option  “Baseline”).  The  reported  cost-effectiveness  results  reflect  a  comparison 
between  each  policy  option  with  the  baseline,  i.e.  capture  only  the  costs  and  benefits  that 
exceed those estimated for the voluntary fitment scenario. 

In terms of the remaining options, the evaluation period was chosen to extend to 2037 in order 
to  capture  the  effects  of  dispersion  of  the  new  safety  measures  into  the  vehicle  fleet  via 
fitment  to  new  vehicles.  Results  are  calculated  for  individual  years,  converted  to  present 
values and summed for the study period extending from 2021 to 2037. 

1.1.13.  Costs 

For  each  proposed  new  vehicle  safety  measure,  a  ‘per  vehicle’  cost  was  established  as 
provided  in  detail  in  section  5.4.  This  accounts  for  single  one-off  costs  and  ongoing 
production costs, all of which were estimated to be incurred by the vehicle manufacturer from 
the time of mandatory introduction. The following costs have been included: 

  Substantive compliance costs incurred by the vehicle manufacturers, including fixed and 
variable  costs  of  manufacturing  and  assembly,  and  overheads  for  research  and 
development; and  

  Regulatory  charges  and  administrative  costs,  when  distributed  over  all  new  vehicles 

produced in a year, represent only a small proportion of the ‘per vehicle’ cost. 

80   Articles 22 and 23 of Framework Directive 2007/46/EC 
81   https://clepa.eu/wp-content/uploads/2017/09/CLEPA-Members_catalogue.pdf 

41 

 
                                                 
The  total  costs  for  the  manufacturer  per  individual  vehicle  at  mandatory  introduction  of 
proposed  measures  are  assumed  to  go  down  due  to  e.g.  economies  of  scale  and  improved 
productivity. The breakdown of costs per  measure is available in Tables 76 to 79 of Annex 
4.8.7. 

Non-quantified costs, notably enforcement costs, are incurred by public authorities linked to 
the  implementation  of  legislation  and  particularly  in  the  development  of  type-approval 
requirements.  These  activities  are  supported  by  the  automotive  industry  and  so  the  cost 
burden is shared, to some extent. However, the part attributable to the public authorities and 
the costs incurred by the vehicle manufacturers developing the regulations are considered to 
be negligible compared to the overall cost of complying with the policy options.   

Further  non-quantified  indirect  costs,  through  potential  vehicle  retail  price  increases,  have 
been considered. However, substantial increases due to the additional proposed new vehicle 
safety measures in the medium and long term are not expected. Vehicle manufacturers in the 
past  have  found  strategies  and  practices  to  balance  production  costs  and  regulatory 
compliance for investments of a similar magnitude which did not translate to an increase in 
vehicle retail prices, for instance CO2 emissions legislation (see section 6.3.3). 

1.1.14.  Benefits 

The  Direct  regulatory  benefits  as  modelled  in  the  cost-benefit  analysis  consist  of  casualties 
avoided due to the intervention. Societal unit cost values for fatalities (€1 870 000), serious 
injuries  (€243  100)  and  slight  injuries  (€18  700)  were  assigned  per  casualty  prevented  or 
mitigated.  

The casualty simulation model that has been used to determine the benefits summarised the 
safety  measures  in three main groups that allowed to  take into account their interactions, in 
order  to  avoid  double-counting  of  casualties  prevented  (see also  Figure 33  in  Annex  4.4.8). 
These groups are: 

−  Assisting the driver with the driving task (permanent/ongoing collision mitigation) 
−  Active Safety (mitigation immediately pre-collision) 
−  Passive Safety (protection during collision) 

The groups were modelled as three ‘layers’ acting one after the other on the overall casualty 
population,  which  allows  a  breakdown  of  the  benefits  per  ‘layer’  based  on  the  reduction  of 
casualty numbers between them. 

−  The first layer determines mainly the proportion of casualties that are prevented by 

e.g. reducing speed, avoiding distraction 

−  The  second  layer  subsequently  determines  the  proportion  of  casualties  that  are 

prevented by in e.g. rear end collisions, pedestrian impact  

−  The third layer mitigates accident outcome with a given effectiveness in those that 

still will happen 

Indirect  benefits  of  the  interventions  which  are  not  modelled,  due  to  the  complexity  of 
quantifying, include the increased productivity due to reductions in congestion, improvements 
in air quality due to reduced vehicle emissions, reductions in emergency service requirements, 
possible reductions in car insurance premiums and the potential for harmonisation of technical 
requirements  across  world  regions  and  between  vehicle  manufacturers.  Their  benefits  have 
been  considered  but  they  are  not  quantified  for  this  impact  assessment.  The  effect  of 
considering  them  would  increase  the  benefit-to-cost  ratios  in  favour  of  implementing  the 
relevant policy options. 

42 

 
Also some of the measures included within the policy options are expected to provide for cost 
savings  for  police  enforcement  and  other  public  road  safety  authorities,  such  as  intelligent 
speed  assistance,  which  will  increase  speed  limit  compliance  without  the  need  for  stricter 
enforcement. 

1.1.15.  Impact  of  additional  safety  measures  on  vehicle  prices  and  sales 

prices 

This section makes predictions of future new vehicle sales numbers and fleet growth based on 
extrapolation of historic trends. It is important, in this context, to analyse whether the cost of 
the  additional  safety  measures  to  the  vehicle  manufacturers  would  be  likely  to  result  in  a 
substantial increase in end-user vehicle prices and thereby negatively affect new vehicle sales 
price.  If  this  was  the  case,  slower  dispersion  of  the  safety  measures  into  the  fleet  might 
partially  diminish  the  safety  returns,  which  should  then  be  reflected  in  the  cost-benefit 
calculation model. 

The  costs  calculated  in  this  study  for  fitment  of  the  proposed  safety  measures  are  to  be 
understood  to  reflect  the  costs  to  the  vehicle  manufacturers.  The  full  set  of  proposed  safety 
measures, as reflected in all relevant PO3s, is estimated to create additional costs in the region 
of € 516 per passenger  car (M1), € 521 per light commercial vehicle (N1), € 970 per bus (M2 
and M3), and in the region of € 1 013 per truck (N2 and N3), respectively. These costs incurred 
by the vehicle manufacturers are not expected to be entirely translated into a change in vehicle 
retail  prices,  because  the  markets  for  consumer,  as  well  as  commercial,  vehicles  are  highly 
competitive which is prohibitive of allowing costs to be passed on directly, as can be observed 
in historic pricing data. 

Up  until  2011,  Directorate-General  for  Competition  published  annually  the  ‘Report  on  car 
prices  within  the  European  Union’82.  These  reports  provide  the  most  comprehensive  and 
detailed guide to the historic development of car prices in Europe  year-on-year  by collating 
list  prices  for  cars  (i.e.  before  any  dealership  discounts)  and  determining  the  car  price 
development  in  real  terms,  i.e.  adjusted  for  inflation.  Table  6  shows  the  price  development 
during the last decade of available data (2002 to 2011).  

Table 6: Year-on-year change in real car prices for the last decade of available data  

2004 

2002 

2003 

2005 

-0.2% 

Year 
Year-on-year 
price change 
Note: 2012 and beyond - EU car price reports discontinued; no published data 
The source of the data is the “Report on car prices within the European Union – Technical annex, Years: 2002 
to 2011”. The car price reports were discontinued after 2011 because the Commission did not find any 
significant competition shortcomings in the new cars sector. 

-3.2% 

-1.5% 

-0.6% 

-0.7% 

-3.1% 

-1.6% 

-1.9% 

-1.0% 

2010 

2006 

2007 

2008 

2009 

2011 

-2.5% 

It can be seen that cars have become cheaper in real terms in every year of the last reported 
decade,  despite  this  being  a  period  in  which  technical  development  to  meet  new  and  more 
demanding emissions and safety standards increased, for example those listed in Annex 6.  

The net effect of decrease in vehicle sales volumes will depend on two factors. The utility of 
safety  to  consumers  and  how  consumers  would  react  to  any  potential  price  increase.  These 
effects  are  not  homogenous  across  consumers.  What  the  literature  says  is  that  demand 
increases  more  when  safety  increases  in  vehicles  which  are  equipped  with  low  safety 
standards (and vice-versa). At the same time, sensitivity to price increases (price elasticity) is 

82   http://ec.europa.eu/competition/sectors/motor_vehicles/prices/report.html 

43 

 
 
                                                 
higher  for  popular  vehicle  brands.  Therefore,  introduction  of  new  safety  measures  could 
increase demand, especially of consumers planning to buy vehicles with lower initial standard 
safety  measures,  to  the  extent  that  this  effect  is  not  offset  by  a  price  increase.  If  the 
introduction  of  new  measures  pushes  prices  up,  consumers  of  popular  vehicle  models  with 
relatively low safety standards might instead buy on secondary market or continue using their 
old vehicles. 

1.1.16.  Competitiveness and drivers of innovation 

The  automotive  industry,  consisting  of  vehicle  manufacturers  (ACEA83)  as  well  as  vehicle 
equipment  suppliers  (CLEPA84),  fully  support  a  regulatory  approach  by  the  Commission. 
However it is also important to mention one of the stakeholders (MOBIVIA) has during the 
public  consultation  raised  in  detail  the  issue  of  competitiveness  and  called  upon  a  quickly-
adopted  EU  regulatory  provision  eventually  requiring  the  introduction  of  an  on-board 
application  platform  with  an  open  access  for  all  actors.  Standardising  the  way  that  data  is 
made available would help a fairer application of competition law.  

The  vehicle  manufacturing  industry  has  been  categorised  as  a  sector  requiring  global 
innovation,  but  retaining  strong  elements  of  regional  production.  Many  EU  based  vehicle 
manufacturers  are  producing  more  of  their  products  overseas  for  overseas  markets,  up  to 
about  67%  of  total  company  sales85.  Still,  a  significant  proportion  of  EU  based  car 
manufacturing, in the order of 30% to 40%, often in the luxury car segment, continues to be 
for export, and the EU has a large trade surplus in the sector. Hence the relative international 
competitiveness of EU based production remains a critical factor for the sector going forward. 
This can in particular be aided by the first mover advantage of EU automotive suppliers in the 
vehicle safety equipment market, the ability to set world standards by means of introduction 
of  new  EU  vehicle  safety  legislation  and  its  global  harmonisation  potential  (e.g.  through 
UNECE  cooperation  with  non-EU  Contracting  Parties86),  the  knock-on  effect  of  increased 
safety  reputation  of  EU  vehicle  brands  and  by  allowing  for  economics  of  scale  of  vehicle 
safety  equipment  producers  leading  to  lower  unit  cost  and  higher  profit  margins  in  markets 
where the safety technologies are fitted as for-purchase option.  

For  vehicle  manufacturing  the  following  main  market  dynamics  megatrends  have  been 
identified.  The  shift  in  demand  towards  fast-growing  emerging  markets,  tightening  of 
environmental  and  energy  efficiency  standards,  a  greater  urge  for  the  integration  of  digital 
services,  as  well  as  changes  in  demographics  and  urban  mobility,  all  likely  to  affect  the 
automotive  industry  of  the  future.  In  this  context,  the  EU  has  been  a  leader  of  automotive 
intellectual  property  and  technology,  however,  this  advantage  is  likely  to  decrease  as 
emerging markets begin to develop increasingly sophisticated auto industries themselves. The 
EU should therefore aim to retain and increase its important competitive advantages relating 
to  intangible  factors,  in  particular  the  high  innovation  capacity  of  the  EU  vehicle  industry, 
their  supplier  base  and  notably  SMEs  offering  various  relevant  and  crucial  knowledge  and 
skills  based  services  in  the  sector.  In  particular,  policy  option  “Regulatory  approach”  3,  to 
optimally achieve all sub-objectives, creates opportunities for the EU automotive industry in 
this context. 

83   http://www.acea.be/publications/article/position-paper-general-safety-regulation-revision 
84   https://clepa.eu/mediaroom/clepa-position-paper-tyre-pressure-monitoring-systems-tpms-review-general-

safety-regulation 

85   https://ec.europa.eu/futurium/en/system/files/ged/13-_i24c-_report-understandingeusectorcompetitivenes_ 

innewglobal_economy.pdf. 

86   http://www.unece.org/fileadmin/DAM/trans/doc/2017/wp29grsg/GRSG-113-14e.pdf, 
http://www.unece.org/fileadmin/DAM/trans/doc/2017/wp29grrf/GRRF-84-03e.pdf 

44 

 
                                                 
In the context of new vehicle safety measures that are considered for this initiative, it should 
be  highlighted  that  many  features  offer  a  ‘basic’  safety  capability,  in  other  words,  it  works 
effectively when it has to. On the other hand the safety features make use of equipment such 
as  sensors  that  may  be  used  for  a  variety  of  other  tasks  that  are  geared  towards  driver 
assistance  and  comfort.  This  means  that  vehicle  manufacturers  have  the  opportunity  to  ‘up-
sell’  highly  desirable  optional  features  such  as  adaptive  cruise  control  and  lane  keeping 
assistance,  indeed  nearly  autonomous  driving  functions.  For  these  features  the  essential 
hardware  will  already  be  incorporated  within  the  vehicle  for  the  safety  functions.  The 
manufacturer can enable the more sophisticated use of automated driving features by simply 
reprogramming  the  control  modules  and  the  possible addition  of  a  few  buttons  on a  ‘multi-
function steering wheel’ that is in turn also sold for an additional premium, thus without the 
basic initial costs and thus for a higher profit. 

7.  HOW DO THE OPTIONS COMPARE? 

1.22.  Effectiveness 

Table 7: List of separated policy options per vehicle category cluster and benefit to cost 
ratios 

Benefit-Cost 
ratio 

BCRs of policy options PO1, PO2, PO3 

Vehicle categories  PO1  PO2  PO3 

Passenger cars 
(M1) 

2.95  2.14  1.39 

Vans (N1) 

1.78  1.35  0.53 

Buses and coaches 
(M2 & M3) 

4.64  3.11  2.11 

6,0

5,0

4,0

3,0

2,0

1,0

PO1

PO2

PO3

Trucks (N2 & N3) 
and trailers 
Based on present values over entire evaluation period 2021–2037 relative to the baseline scenario (best estimate with indication of 
uncertainty ranges from scenario analysis) with indication of uncertainty margin 

0.56  1.52  1.03 

M2&M3

N2&N3

M1

N1

0,0

1.1.17.  Effectiveness in achieving the general objective  

Table 8 to Table 11 provide a summary of the effectiveness of the policy options in achieving 
the general objective for each vehicle category cluster. The tables compare  the total sum of 
casualties  prevented  by  the  vehicle  safety  measures  across  all  vehicle  categories  over  the 
evaluation period 2021 – 2037 across EU-28 compared to the baseline option.  

It  can  be  observed  for  all  vehicle  categories  that  the  number  of  casualties  prevented  by 
implementation  of  PO2  or  PO3  exceeds  the  number  prevented  by  PO1  by  a  considerable 
margin. Between all four vehicle category clusters, implementation of PO2 has the potential 
to prevent an additional 8 312 fatalities and 51 286 serious casualties compared to PO1 across 
EU-28  over  the  period  2021  –  2037.  PO3  exceeds  the  potential  of  PO2  by  further  1 843 
fatalities and 21 807 serious casualties. 

45 

 
 
 
 
 
Table 8: Comparison of the effectiveness of the policy options for passenger cars (M1) in 
achieving the general objective relative to the baseline option  

Passenger cars (M1) 
Fatal casualties prevented 
Serious casualties prevented 
Impact compared to baseline 
Initial cost per vehicle 

PO0 
0 
0 
n/a 
0 

PO1 
13 785 
63 493 
+ 
€ 201 

PO2 
20 081 
107 913 
++ 
€ 360 

PO3 
21 337 
126 390 
++ 
€ 516 

Table  9:  Comparison  of  the  effectiveness  of  the  policy  options  for  light  commercial 
vehicles (N1) in achieving the general objective relative to the baseline option  

Light commercial vehicles (N1) 
Fatal casualties prevented 
Serious casualties prevented 
Impact compared to baseline 
Initial cost per vehicle 

PO0 
0 
0 
n/a 
0 

PO1 
852 
4 074 
+ 
€ 131 

PO2 
1 005 
5 068 
++ 
€ 206 

PO3 
1 283 
6 917 
++ 
€ 521 

Table  10:  Comparison  of  the  effectiveness  of  the  policy  options  for  medium  and  large 
buses (M2 & M3) in achieving the general objective relative to the baseline option  

Medium and large buses (M2 & M3) 
Fatal casualties prevented 
Serious casualties prevented 
Impact compared to baseline 
Initial cost per vehicle 

PO0 
0 
0 
n/a 
0 

PO1 
2 
33 
≈ 
€ 6 

PO2 
207 
2 064 
+ 
€ 607 

PO3 
227 
2 410 
++ 
€ 970 

Table  11: Comparison of the  effectiveness of  the policy options for medium and heavy 
trucks (N2 & N3) in achieving the general objective relative to the baseline option  

Medium and heavy trucks (N2 & N3) 
Fatal casualties prevented 
Serious casualties prevented 
Impact compared to baseline 
Initial cost per vehicle 

PO0 
0 
0 
n/a 
0 

PO1 
0 
47 
≈ 
€ 6 

PO2 
1 658 
3 888 
+ 
€ 607 

PO3 
1 947 
5 023 
++ 
€ 1 013 

1.1.18.  Effectiveness in achieving the specific objectives 

Table  12  to  Table  15  summarize  the  effectiveness  of  the  policy  options  in  achieving  the 
specific objectives for each vehicle category cluster. With regard to specific objective 1, it can 
be  observed  in  general  that  PO1  is  not  effective  for  buses  and  trucks,  and  only  moderately 
effective  for  passenger  cars  and  light  commercial  vehicles.  PO2  and  in  particular  PO3  are 
considerably more effective. With regard to specific objective 2, PO2 and in particular PO3 
are highly effective, whereas PO1 is not effective.  

Table 12: Comparison of the effectiveness of the policy options for passenger cars (M1) 
in achieving the specific objectives relative to the baseline option 

Passenger 
cars (M1) 

PO0 

PO1 

PO2 

Occupant 
protection 
in vehicles 
= 

Pedestrians 
and cyclists 
protection 
= 

+ 

++ 

≈ 

++ 

Assessment 

This is the baseline option. 
PO1 comprises seven measures primarily designed to protect vehicle 
occupants. The impact on pedestrians and cyclists is minimal. 
PO2 contains additional active measures designed to address driver 

46 

 
 
 
 
PO3 

++ 

++ 

drowsiness and inattention and speeding, passive measures to protect 
vehicle occupants, and active  (autonomous emergency braking) and 
passive measures (head impact protection) to protect pedestrians and 
cyclists. The additional pedestrian and cyclist casualties saved (fatal 
and serious) in relation to PO1 are considerable. 
PO3 contains additional advanced measures against driver distraction 
and reversing accidents with pedestrians and cyclists. It prevents 
additional casualties in both groups, at the serious casualty level. 

Table  13:  Comparison  of  the  effectiveness  of  the  policy  options  for  light  commercial 
vehicles (N1) in achieving the specific objectives relative to the baseline option 

Light 
commercial 
vehicles 
(N1) 
PO0 

PO1 

Occupant 
protection 
in vehicles 

Pedestrians 
and cyclists 
protection 

Assessment 

= 

+ 

= 

≈ 

PO2 

++ 

++ 

PO3 

++ 

++ 

This is the baseline option. 
PO1 comprises five measures primarily designed to protect vehicle 
occupants. The impact on pedestrians and cyclists is minimal. 
PO2 contains additional active measures designed to address driver 
drowsiness and inattention, and active  (autonomous emergency 
braking) and passive measures (head impact protection) to protect 
pedestrians and cyclists. The additional pedestrian and cyclist 
casualties saved (fatal and serious) added to PO1 are considerable. 
PO3 contains additional advanced active measures against driver 
distraction and speeding, passive measures to protect vehicle 
occupants, and measures to prevent reversing accidents with 
pedestrians & cyclists. It prevents additional casualties, in particular 
vehicle occupants at fatal and serious level. 

Table  14:  Comparison  of  the  effectiveness  of  the  policy  options  for  medium  and  large 
buses (M2 & M3) in achieving the specific objectives relative to the baseline option 

Occupant 
protection 
in vehicles 

Pedestrians 
and cyclists 
protection 

Assessment 

Medium 
and large 
buses (M2 
& M3) 
PO0 

PO1 

PO2 

= 

≈ 

+ 

= 

≈ 

++ 

PO3 

++ 

++ 

This is the baseline option. 
PO1 consists of only two measures. The impact on casualty 
numbers amongst both vehicle occupants and pedestrians and 
cyclists is minimal. This option is not expected to prevent fatalities. 
PO2 contains additional measures designed to address driver 
drowsiness and inattention and speeding and also detection and 
visibility measures to protect pedestrians and cyclists. The 
additional casualties prevented added to PO1 are considerable. 
PO3 contains additional measures for both casualty groups 
(occupants and pedestrians and cyclists) that are technologically 
more advanced and prevents further casualties, in particular 
seriously injured casualties. 

Table  15: Comparison of the  effectiveness of  the policy options for medium and heavy 
trucks (N2 & N3) in achieving the specific objectives relative to the baseline option 

Medium 
and heavy 
trucks (N2 
& N3) 
PO0 

PO1 

PO2 

Occupant 
protection 
in vehicles 

Pedestrians 
and cyclists 
protection 

Assessment 

= 

≈ 

+ 

= 

≈ 

++ 

This is the baseline option. 
PO1 consists of only two measures. The impact on casualty 
numbers amongst both vehicle occupants and pedestrians and 
cyclists is minimal. This option is not expected to prevent fatalities. 
PO2 contains additional measures designed to address driver 
drowsiness and inattention and speeding and also detection and 
visibility measures to protect pedestrians and cyclists. The 

47 

 
PO3 

++ 

++ 

additional casualties prevented added to PO1 are considerable. 
PO3 contains additional measures for both casualty groups 
(occupants and pedestrians and cyclists) that are technologically 
more advanced and prevents further casualties, in particular 
seriously injured casualties. 

1.23.  Efficiency and proportionality 

Table 16 to Table 19 present an overview comparing the efficiency and proportionality of the 
policy options based on the benefit-to-cost ratios (BCR) relative to the baseline option, over 
the evaluation period 2021 – 2037 for each vehicle category cluster. It can be observed that 
PO1  and  PO2  generally  offer  favourable  cost-effectiveness  ratios,  except  for  trucks  where 
PO1 is not cost-effective. The total monetary benefit realised by PO2 is considerably higher 
compared  to  PO1  for  all  vehicle  category  clusters.  Favourable  cost-effectiveness  ratios  for 
PO3 were found for passenger cars and buses; a marginal value was found for PO3 for trucks. 
For light commercial vehicles, the costs for PO3 exceed the benefits by a large margin.  

Table  16:  Comparison  of  the  monetary  benefits  and  costs  of  the  policy  options  for 
passenger cars (M1) relative to the baseline option  

Passenger 
cars (M1) 
Present value 
benefit 
Present value 
cost 
BCR (best 
estimate) 
BCR 
(uncertainty 
range 
lower/upper) 
Efficiency 
compared to 
baseline 

PO0 

PO1 

PO2 

PO3 

€ 0 

€ 37.5 bn 

€ 57.4 bn 

€ 64.1 bn 

€ 0 

€ 12.7 bn 

€ 26.9 bn 

€ 46.0 bn 

n/a 

2.95 

2.14 

1.39 

n/a 

2.28  3.31  1.58  2.69  1.01  1.85 

n/a 

++ 

++ 

+ 

Table 17: Comparison of the monetary benefits and costs of the policy options for light 
commercial vehicles (N1) relative to the baseline option  

Light 
commercial 
vehicles (N1) 
Present 
value 
benefit 
Present 
value cost 
BCR (best 
estimate) 
BCR 
(uncertainty 
range 
lower/upper) 
Efficiency 
compared to 
baseline 

PO0 

PO1 

PO2 

PO3 

€ 0 

€ 2.3 bn 

€ 2.8 bn 

€ 3.7 bn 

€ 0 

€ 1.3 bn 

€ 2.0 bn 

€ 6.9 bn 

n/a 

1.78 

1.35 

0.53 

n/a 

1.39  1.83  0.98  1.51  0.39 

0.65 

n/a 

++ 

+ 

– – 

48 

 
 
 
 
Table  18:  Comparison  of  the  monetary  benefits  and  costs  of  the  policy  options  for 
medium and large buses (M2 & M3) relative to the baseline option  

Medium and 
large buses 
(M2 & M3) 
Present 
value 
benefit 
Present 
value cost 
BCR (best 
estimate) 
BCR 
(uncertainty 
range 
lower/upper) 

Efficiency 
compared to 
baseline 

PO0 

PO1 

PO2 

PO3 

€ 0 

€ 11.2 mn 

€ 813.7 mn  € 937.0 mn 

€ 0 

€ 2.4 mn 

€ 262.0 mn  € 444.5 mn 

n/a 

4.64 

3.11 

2.11 

n/a 

3.17  14.32  1.91  4.42  1.46  2.56 

n/a 

++ 

++ 

+ 

Table  19:  Comparison  of  the  monetary  benefits  and  costs  of  the  policy  options  for 
medium and heavy trucks (N2 & N3) relative to the baseline option  

Medium and 
heavy trucks 
(N2 & N3) 
Present 
value 
benefit 
Present 
value cost 
BCR (best 
estimate) 
BCR 
(uncertainty 
range 
lower/upper) 
Efficiency 
compared to 
baseline 

PO0 

PO1 

PO2 

PO3 

€ 0 

€ 0.01 bn 

€3.4 bn 

€4.1 bn 

€ 0 

€ 0.02 bn 

€2.2 bn 

€4.0 bn 

n/a 

0.56 

1.52 

1.03 

n/a 

0.39 

2.93 

0.89  2.28  0.59  1.29 

n/a 

– – 

+ 

≈ 

1.24.  Coherence 

Road  traffic  safety  is  an  EU  priority87.  The  proposed  new  vehicle  safety  measures  serve  to 
protect  EU  citizens  from  the  loss  of  life  and  health  caused  by  road  traffic  accidents.  They 
should indeed be able to expect systematic and continuous road safety improvement, and in 
this particular case in vehicle safety improvement as well. 

In  principle everyone  has  the right  to  use  roads and  streets without  threats  to  life  or  health. 
This includes access for everyone to equal, safe and sustainable mobility, with due attention 
for vulnerable road users, including the elderly and children. 

As regards coherence in future forecast and baseline determination between different remits 
within the EU, e.g. road safety and vehicle safety, the best estimate provided for the general 

87   COM(2010) 389 final 

49 

 
 
 
 
 
 
                                                 
future  casualty  trend  depends  on  many  unknown  factors  and  potentially  diverging views  on 
the  matter.  The  approach  that  has  been  opted  for  in  terms  of  forecast  is  represented  in  a 
constant casualty number at all severity levels from 2016 onward, showing that the continued 
effects in all non-vehicle sectors are expected to offset the increase in traffic volume but not 
be strong enough to result in a net casualty reduction. The calculations to arrive at the casualty 
baseline were performed based on this general casualty trend and using detailed input values 
and calculation methods as described in Annex 4. The resulting casualty baseline reflects the 
effects  of  continued  dispersion  of  existing  mandatory  vehicle  safety  measures  with  new 
vehicles  into  the  legacy  fleet  and  continued  voluntary  uptake  of  the  safety  measures  under 
consideration, as well as the generally agreed contribution by improved infrastructure and e.g. 
tunnel safety. 

Generally, road infrastructure and vehicle safety measures can be regarded as complementary 
(e.g.  for  measures  like  alcohol  interlock  installation  facilitation,  autonomous  emergency 
braking  for  pedestrians  and  cyclists,  distraction  recognition,  better  follow-up  of  road  safety 
management  procedures  etc.)  although  there  are  also  some  measures  which  are  mutually 
reinforcing (e.g. visible road markings to support lane keeping assistance technologies). The 
baseline  scenario  assumes  the  application  of  the  existing  RISM  Directive  in  line  with  the 
current legislation, as required by the Better Regulation principles. No further policy action is 
considered  at  the  EU  level  in  the  baseline.  Including  additional  road  infrastructure  safety 
measures  in  the  baseline  would  result  in  lower  numbers  of  fatalities  and  serious  injuries. 
Consequently, the impact of vehicle safety policy options in terms of lives saved and serious 
injuries avoided may be slighly reduced when compared to such an alternative baseline. This 
is due to the overlapping effects between the impacts of the policies, in the same way as there 
is nearly always more than one factor in accident causation. The individual influence of each 
factor  is  virtually  impossible  to  determine.  In  other  words  the  combined  effect  of  road 
infrastructure and vehicles safety measures deployed together, is going to be somewhat lower 
than the sum of their individual effects. 

8.  THE PREFERRED OPTION 

The analysis of the policy options has been carried out for each of the four vehicle category 
clusters. This was done in order to transparently present the results of the impact assessment 
in terms of cost-effectiveness of the foreseen vehicle safety measures. Table 20 provides an 
overview that summarises the preferred option for each vehicle category. 

Table 20: List of policy options and key performance indicators 

Policy options and key performance indicators 

Applicable vehicle categories 

PO1 

PO2 

Passenger 
cars 

Light 
commercial 
vehicles 

Buses 

Trucks 
and 
trailers 

M1 

Benefit-to-cost ratio 

2.95 

N1 

1.78 

M2 & M3 

N2 & N3 

4.64 

0.56 

Total cost per vehicle 

€ 201 

€ 131 

Fatalities prevented 

13 785 

852 

Severe injuries prevented 

63 493 

4 074 

Benefit-to-cost ratio 

2.14 

Total cost per vehicle 

€ 360 

Fatalities prevented 

20 081 

1.35 

€ 206 

1 005 

€ 6 

2 

33 

3.11 

€ 607 

207 

Severe injuries prevented 

107 913 

5 068 

2 064 

€ 6 

0 

47 

1.52 

€ 607 

1 658 

3 888 

50 

 
 
PO3 

Benefit-to-cost ratio 

1.39 

Total cost per vehicle 

€ 516 

Fatalities prevented 

21 337 

0.53 

€ 521 

1 283 

2.11 

1.03 

€ 970 

€ 1,013 

227 

1 947 

5 023 

Severe injuries prevented 

126 390 

6 917 

2 410 

Fatalities prevented per policy option  
(sum of all vehicle categories) 

30 000

20 000

10 000

 0

[VALUE] 

[VALUE] 

[VALUE] 

PO1

PO2

PO3

Figure  6:  Fatal  casualties  prevented  by  PO1,  PO2  and  PO3  relative  to  the  baseline 
option  across  all  vehicle  categories  with  indication  of  uncertainty  margin  over  the 
evaluation period 2021 – 2037 

Figure 7: Severe injuries prevented by PO1, PO2 and PO3 relative to the baseline option 
across  all  vehicle  categories  with  indication  of  uncertainty  margin  over  the  evaluation 
period 2021 – 2037 

For passenger cars (category M1), medium and large buses (categories M2 and M3), medium 
and  heavy  trucks  (categories  N2  and  N3)  the  preferred  policy  option  is  PO3  for  reasons  of 
effectiveness, efficiency and policy coherence, while cost-effective. 

It  is  noted  that  for  the  above  vehicle  category  clusters  the  additional  lives  saved  in  PO3 
compared to PO2 is not proportional to the cost increase. However, the reduction in serious 
injuries  is  significant  for  all  vehicles  categories  and  varies  between  17%  and  36%. 
Furthermore,  the  indicated  cost  per  vehicle  for  vehicle  manufacturers  in  each  policy  option 
should be strongly considered in relation to the much higher sales price of the motor-vehicle 
in  question  and  not  in  isolation.  Finally,  the  initial  safety  measures’  cost  for  manufacturers 
will  drop  due  to  e.g.  economies  of  scale  and  vehicle  manufacturers  will  continue  to  find 
additional ways to compensate so that vehicles will not get significantly more expensive for 
the buyer. 

51 

 
 
 
For  light  commercial  vehicles  (category  N1)  the  preferred  policy  option  on  the  basis  of  the 
benefit to cost considerations should in principle be PO2 (PO3 benefit to cost ratio is 0.53). 
However, additional considerations must be taken into account. 

For  light  commercial  vehicles,  most  EU  manufacturers  already  provide  for  safer  than 
currently  required  vehicles  since  light  commercial  vehicles  often  share  platform  and  other 
hardware with passenger cars. This is reflected in the relatively low overall calculated benefit 
for this option. On top of that, the cost estimate can be considered as conservative since the 
industry  has  already  implemented  certain  features  (frontal  crash  test,  airbags)  and  will  face 
lower costs due to economies of scale with the passenger cars category. 

Several stakeholders, notably the European Traffic Safety Council ETSC88 and Transport and 
Environment  T&E,  have  explicitly  called  for  the  Commission  to  apply  consistent  measures 
between  the  different  vehicle  categories.  In  addition,  Transport  and  Environment  provided 
evidence  that  there  is  an  increasing  share  of  light  commercial  vehicles,  also  resulting  from 
their increased used to transport goods in the Union in an effort to circumvent driving times 
and rest legislation that applies to heavy goods vehicles. Light commercial vehicles are also 
more commonly used to comply with Urban Mobility initiatives that require adapted logistical 
arrangements in an increasing number of cities. 

If PO3 is not pursued for light commercial vehicles, persons in these vehicles may be faced 
with an increased risk of an accident (because of less accident avoidance measures), a higher 
crash  severity  (less  accident  mitigation  measures)  and  lower  protection  levels  (lack  of 
advanced crash testing), in comparison to regular passenger cars. Distribution effects would 
be concentrated on one single category of people, i.e. workers using this category of vehicles. 
Exposing workers to higher risks is not consistent with the Commission’s approach to reduce 
accidents at the workplace89. 

PO3 for N1 vehicles also allows ensuring a level playing field since all producers would be 
subject to same standards. 

As regards N2/N3 heavy goods vehicles cost effectiveness and the broad uncertainty range it 
should be explained that all measures, except driver direct vision for cabs, has been evaluated 
by  the  two  ‘opposing’  stakeholders,  vehicle  industry  vs.  supplier  industry  which  has  led  to 
validated costs  that are generally considered  as  more  realistic.  In  all  these  cases  the  vehicle 
manufacturers  are  relying  on  suppliers  for  certain  components  or  systems.  In  case  of  cab 
design this is different. In particular truck manufacturers are completely alone responsible for 
cab  design  without  supplier  input.  This  means  that  the  indicated  costs  that  the  stakeholders 
have provided in the context of the consultations could not be truly validated by third parties. 
This  is  reflected  in  the  broad  cost  range  that  has  been  taken  on  board.  For  transparency 
reasons this is then clearly and conservatively reflected in the uncertainty range. In any event, 
the cost of PO3 (i.e. EUR 1 013) should be viewed in context with the usual price of a truck 
(i.e. starting from around EUR 80-100 000).   

88   European Transport and Safety Council: http://etsc.eu/wp-content/uploads/2017-03-ETSC-position-paper-

general-safety-regulation.pdf, Transport & Environment: 
https://www.transportenvironment.org/sites/te/files/publications/2017%2009%2018%20Eurovignette 
%20Position%20Paper.pdf 

89   COM(2017)12 final. "Safer and Healthier Work for All - Modernisation of the EU Occupational Safety and 

Health Legislation and Policy". 

52 

 
                                                 
As far as costs are concerned, the vast majority of manufacturers90 producing N1 vehicles are 
also  producing  M1  and  other  categories  of  vehicles  for  which  PO3  is  recommended.  In 
addition,  N1  vehicles  usually  share  platforms  with  M1  vehicles.  They  will  thus  be  able  to 
benefit from economies of scale for all their production.  

A proposal to amend the General Safety Regulation (EC) No 661/2009 and Pedestrian Safety 
Regulation (EC) No 78/2009 should therefore reflect PO3 for all vehicle category clusters as 
the preferred policy option. Over the evaluation period (2021 – 2037) it will address the target 
population (see section 2.1) as follows: 

Fatalities prevented:  
24 794 

occupant protection in frontal, side and rear impact:  
reduction by 16.0% of the vehicle occupant fatalities 
pedestrian and cyclist protection in frontal, side and rear 
impact: reduction by 14.4% of the vulnerable road user fatalities 

Severe injuries prevented: 140 740 

The analysis and comparison shows that road infrastructure measures could save over 3 200 
lives  and  avoid  more  than  20  700  serious  injuries  during  2020  –  2030  relative  to  the 
baseline.91  Vehicle  safety  measures  would  have  higher  impact,  reducing  the  number  of 
fatalities by 4 380 to 7 300 and of serious injuries by 19 850 to 38 900 during 2020 – 2030. 
For 2030 alone road infrastructure measures would result in 562 lives saved and 3 675 serious 
injuries avoided, while vehicle safety measures would result in 1 030 to 1 769 fewer fatalities 
and  4  721  to  9  824  serious  injuries  avoided.  Thus,  additional  measures  going  beyond  road 
infrastructure and vehicle safety will be needed to achieve the EU's strategic objectives. 

9.  HOW WOULD ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The European Commission  will continue to  monitor technical  progress developments  in  the 
automotive sector and, wherever appropriate, will propose to amend the relevant legislation in 
order to include new safety features. It will also continue to actively participate and lead the 
vehicle standard harmonisation process at international level (UNECE). 

In  order  to  make  the  new  Regulation  future  proof,  it  has  been  deemed  more  appropriate  to 
address any review of these vehicle safety rules in a more dynamic fashion, namely linked to 
the  overall  technical  progress  and  occurrences  of  new  safety  needs.  In  this  context,  the 
international  regulatory  developments  through  UNECE  as  well  as  the  frequent  need  for  the 
adaptation of those rules tend to prompt this reviewing process automatically. 

EU  wide  in  depth  accident  data  that  currently  does  not  exist  on  a  wide  enough  scale  is 
indispensable for a comprehensive monitoring of vehicle safety measures.  

The introduction of event (accident) data recorders (following the preferred option), storing a 
range  of  crucial  vehicle  data  over  a  short  timeframe  before,  during  and  after  a  triggering 
event, most commonly airbag deployment, should however be seen as a valuable step in the 
right direction to obtain much more and more accurate in depth accident data that is in turn 
used  for  road  safety  analysis  and  by  extension  to  assess  effectiveness  of  specific  measures. 
For  this  reason  Member  States  should  be  strongly  encouraged  to  perform  (much)  more  in 
depth  accident  analysis  on  EU  roads  and  make  available  comprehensive  reporting  on  a 

90   Renault,  Citroën,  Fiat,  VW,  Mercedes,  Peugeot,  Ford  Opel,  Nissan,  Toyota  had  a  combined  EU  market 

share of almost 90% in 2015 (source ICCT). 

91   Add reference to the IA on road infrastructure safety 

53 

 
 
 
 
                                                 
national  basis.  In  this  context  Member  States  should  also  be  further  stimulated  in  their 
activities  to  analyse  and  improve  road  safety  on  national  level  through  different  knowledge 
sharing platforms at their disposal92. 

92   https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/national-road-safety-strategies_en.pdf 

54 

 
                                                 
ANNEX 1 – PROCEDURAL INFORMATION 

1.1. Lead DG, Decide Planning/CWP references 

Lead Directorate-General  

This initiative is led by Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(DG GROW).  

Agenda planning and Work Programme References  

The Agenda Planning Reference is PLAN/2016/497. The revision of legislation on the General Safety 
of Vehicles and Pedestrian Safety is part of Commission’s 2018 Work Programme93 

1.2. Organisation and timing  

The  inter-service  steering  group  for  this  initiative  was  chaired  by  the  DG  GROW.  The  following 
Directorates-General  (DG)  participated:  SJ,  SG;  DG  MOVE;  DG  TRADE;  DG  CNECT;  DG  RTD; 
JRC; DG CLIMA; DG JUST. 

The following meetings took place 

  28 April 2017 – on the inception impact assessment; consultation strategy 
  8 June 2017 – email consultation of ISG on questionnaire for public consultation 
  27 October 2017 – on draft Impact Assessment 
  6 December 2017  - on draft final Impact Assessment and synopsis report of public consultation 

1.3. Consultation of the RSB 

The Regulatory Scrutiny Board (RSB) of the European Commission assessed a draft version of the 
present impact assessment 17 January 2018 and issued its opinion on XX January 2018. The Board 
made several recommendations. Those were addressed in the revised IA report as follows: 

93 Commission Work Programme 2016 - https://ec.europa.eu/info/sites/info/files/cwp_2018_en.pdf  

55 

 
 
 
                                                 
Area  RSB recommendations 

The report does not sufficiently 
delimit the expected contribution 
of this initiative within the 
comprehensive approach to road 
safety of the Safe System.  

Modifications of the Impact Assessment report 
The report now clarifies in chapter 1.4. the overlap and 
contribution of this initiative to the overall road safety 
objectives in terms of the relation, prioritisation and 
complementarity with the parallel initiative on road 
infrastructure and tunnel safety. 

s
e
v
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t
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e
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o

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n
a

e
p
o
c
S

s
n
o
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n
a
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o
i
t
i
n
i
f
e
d
m
e
l
b
o
r
P

It does not well explain the 
relationship and complementarity 
with the parallel road 
infrastructure and tunnel safety 
initiative 

A description and clarification of the Safe System 
approach has been added to chapter 2.1. explaining the 
respective contributions to the common objectives of the 
initiatives on vehicle safety and road infrastructure safety 
and the interactions. 

There is no coherence between 
the problem (stagnation in the 
reduction of road fatalities), its 
drivers, the objectives of the 
initiative and the design of 
options. 

There is a need for a more 
coherent intervention logic, 
linking problems, objectives and 
options in a consistent way. The 
report should revise the design or 
naming of the objectives and 
options. 

In chapter 2.1. both initiatives are also put into the context 
of the common baseline approach (detailed in Annex 4), 
notably the methodologies of the studies for the two 
proposals that have been developed to avoid double 
counting within and between proposals. 

A new chapter 2.2. has been developed binding the main 
road safety problems to those linked to vehicles and 
vehicle safety performance. This in turn allows for a better 
comprehension of the structure of the problem definition 
and drivers that are arguably of a less holistic nature, but 
much more to the point on vehicle system level, while 
being still fully relevant. 

More possible reasons for the stagnation in the reduction 
of road fatalities and severe injuries since 2013 have been 
provided in chapter 2.1. whereas they are now also put into 
context of sources of accidents, population diversity, road 
user factors and general driving behaviour concerns, for 
which it has been expressively clarified when they are 
based more on assumptions than facts. 

The intervention logic in chapters 5.1. to 5.4. has been 
more consistently linked to main problems, objectives and 
options. The naming of the objectives and options were 
clarified to ensure that it is clear that this initiative is not 
focussing on the protection of specific groups of traffic 
participants, while neglecting the others (i.e. occupants of 
vehicles versus pedestrians and cyclists) as the clusters of 
vehicle safety measures indeed work on in the different 
areas simultaneously. The objectives were further clarified 
with the notion of protection in case of an accident 
together with potential to completely prevent and avoid 
accidents from happening altogether. 

56 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
The report does not clarify how 
the individual measures were 
selected and what their estimated 
costs and benefits are. It does not 
sufficiently explain the role and 
opinions of stakeholders in this 
process. 

Chapter 5. now explains in clear steps the interaction and 
role of the stakeholders in this process, how the individual 
measures were selected, how their benefits and 
effectiveness were determined (in multiple steps), assessed 
and eventually validated prior to use in the Impact 
Assessment study and how the final costs and benefits 
assessment of individual measures vis-à-vis clustered 
measures was developed through stakeholder input and 
insistence. 

Given that the stakeholders insisted on an approach that 
would evaluate clusters of safety measures instead of 
individual measures, the benefit to cost ratios have not 
been provided on the level of individual measures, as they 
may be misinterpreted in the context of the Impact 
Assessment. The individual costs and benefits of each 
measure has however been provided in Annexes 4.4.2. to 
4.4.5. to the Final Report “In depth cost-effectiveness 
analysis of the identified measures and features regarding 
the way forward for EU vehicle safety” of May 2017 (see 
also point 1.4. on Evidence, Sources and Quality of this 
Annex as well as point 2.1. on General Stakeholder 
Consultations of Annex 2). 

  The analysis should include a 
n
o
discussion of the REFIT 
i
t
a
dimension of the initiative.  
c
i
f
i
l
p
m
i
S

Chapter 2.8. has been modified to better explain the 
expected simplification of the legislative framework, the 
way forward in terms of possible outdated regulatory 
dispositions, and giving indications on future updates of 
vehicle safety rules. 

The report should explain further 
the preference for option 3 for 
light commercial vehicles. 

The justification and clarification of the choice to include 
PO3 for light commercial vehicles has been added to 
chapter 8 and explain the issues of most EU manufacturers 
already providing for safer than currently required 
vehicles, level playing field for manufacturers, vehicle 
design synergies, cost sharing, stakeholder opinions, and 
finally the increased risk of harm to a limited category of 
of people, namely workers using light commercial vehicles 
in their workplace.  

n
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y
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1.4. Evidence, sources and quality 

In  preparation  of  this  initiative,  and  specifically  to  develop  the  Commission  Report  on  “Saving 
lives:  boosting  car  safety  in  the  EU”,  a  specific  study  was  carried  out  covering  more  than  50 
potential safety measures for consideration. This work included several stakeholder engagements, 
such as through the 124th meeting of the Working Group on Motor Vehicles (i.e. the Commission’s 
expert group involving public and private stakeholders), which was followed by a targeted (face-

57 

 
 
 
 
 
 
 
 
 
 
 
to-face)  stakeholder  consultation  in  October  201494.  The  study  on  “Benefit  and  Feasibility  of  a 
Range of New Technologies and Unregulated Measures in the fields of Vehicle Occupant Safety 
and Protection of Vulnerable Road Users”95 was finalised in March 2015. 

Generally,  the  safety  features  that  have  been  selected  to  be  assessed  as  part  of  this  work  were 
chosen to operate in parallel with and in addition to the safety features that are presently mandated 
in the GSR and PSR. The safety features that have been assessed were chosen not to be interfering 
with or amending specific existing safety requirements that are still dispersing into the EU vehicle 
fleet, as the real-world effectiveness of those measures should then first be known.  

As  a  follow-up  to  this  first  study,  a  second  commissioned  study  covered  a  thorough  review  of 
measures  that  were  concluded  by  the  first  study  as  likely  to  be  cost-effective  as  well  as  feasible 
from a technical perspective. This second study was made available to the public in August 2017. 
In order to assess the “in depth cost effectiveness analysis of the identified measures and features 
regarding  the  way  forward  for  vehicle  safety  in  the  EU”96,  a  significant  quantity  of  updated 
information on costs and benefits as well as other relevant amendments and additions in relation to 
the  initial  study  were  taken  on  board.  Again,  targeted  stakeholder  consultations  were  held  at  the 
end of 2016, this time to specifically support all previous and new analysis, providing reassurance 
that  the  relevant  benefit  and  cost  information  sources,  as  well  as  those  for  the  target  population, 
uptake  estimates  and  effectiveness  were  appropriately  captured  and  reported.  The  relevant  input 
values were thus agreed and validated by an expert group of over 70 members that took part in the 
extensive stakeholder consultation strategy as set up for this purpose, in a highly transparent and 
open peer-evaluation exercise. 

Given the trigger of the road safety problem that  is explained in  section 2 above, it was decided 
that  the  information  would  be  transformed  in  a  final  step  to  feed  directly  into  the  calculation  of 
cost/benefit  ratios  for  the  implementation  of  the  specific  Policy  Option  packages  of  this  Impact 
Assessment. 

94   http://ec.europa.eu/growth/tools-databases/newsroom/cf/itemdetail.cfm?item_type=250&lang=en&item_id=7803 
95   TRL, Hynd et al., March 2015 – https://publications.europa.eu/en/publication-detail/-/publication/47beb77e-b33e-

44c8-b5ed-505acd6e76c0 

96   TRL, Seidl et al., May 2017 – https://publications.europa.eu/en/publication-detail/-/publication/77990533-9144-11e7-

b92d-01aa75ed71a1 

58 

 
 
                                                 
ANNEX 2 – STAKEHOLDER CONSULTATION 

2.1. General stakeholder consultations 

Two stakeholder consultations were carried out during the preparation of the studies: 

  “Benefit  and  Feasibility  of  a  Range  of  New  Technologies  and  Unregulated  Measures  in  the 

fields of Vehicle Occupant Safety and Protection of Vulnerable Road Users”97 

  “In depth cost effectiveness analysis of the identified measures and features regarding the way 

forward for vehicle safety in the EU”98 

The first stakeholder consultation exercise was undertaken on 27 and 28 October 2015, in Brussels. 
Prior  to  the  meeting,  stakeholders  were  provided  with  an  overview  of  the  study’s  scope  and 
objectives, a brief overview of the interim benefits and costs for all measures in the subject area, and 
drafts  of  the  evidence  reviews  for  each  potential  measure.  Minutes  of  the  stakeholder  consultation 
meeting  may  be  found  in  the  project  report  (as  referenced  above).  Following  the  consultation 
meeting,  stakeholders  were  given  three  weeks  to  provide  any  additional  evidence  relating  to  the 
potential  measures  under  review.  The  feedback  from  the  consultation  meeting  and  the  evidence 
submitted subsequently were then incorporated into updates of the evidence reviews as presented in 
this report. 

The second stakeholder consultation was held to discuss the preliminary findings of the subsequent 
study and to agree preliminary recommended input values for a cost-benefit assessment. Stakeholders 
had the opportunity to provide written feedback on preliminary findings and/or participate in a two-
day stakeholder consultation meeting on 28 and 29 November 2016, in London. Invitations were sent 
to  the  General  Safety  Stakeholders  Contact  List.  72  people  from  54  organisations  attended  the 
meeting. A breakdown of the type of organisation of the attendees is given in Figure 8. The meeting 
minutes  documenting  the  discussion  in  the  stakeholder  meeting  for  each  of  the  measures  may  be 
found in the GSR2 report. 

Type of organisations represented at the GSR2 
consultation meeting 

22 

7 

9 

5 

11 

OEM

Road Safety and
Enviromental NGO,
Consumer Organisations
Tier 1 Supplier

Government Body

Figure 8: Type of organisations represented during the GSR2 stakeholder consultation meeting 
in November 2015 

97   GSR1 – TRL, Hynd et al., March 2015 – https://publications.europa.eu/en/publication-detail/-/publication/47beb77e-

b33e-44c8-b5ed-505acd6e76c0 

98   GSR2 – TRL, Seidl et al., May 2017 – https://publications.europa.eu/en/publication-detail/-/publication/77990533-

9144-11e7-b92d-01aa75ed71a1 

59 

 
 
                                                 
A list of organisations that provided written feedback is given in Table 21.  

All  stakeholder  inputs,  provided  in  writing  or  during  the  two-day  face-to-face  meeting,  were 
documented and used to update and refine the results of the study where appropriate.  

Table 21: List of organisations that provided input during the GSR2 stakeholder consultation 

Organisation name 

ACEA 
Adam Opel AG 

AGU Zürich 
AUDI AG 
Autoliv 
BASt - Federal Highway Research Institute 
Bridgestone Europe 
CLEPA 
DAF Trucks N.V. 
DfT 
ETRMA  

ETSC 

European Cyclists Federation 
Fédération Inter-Environnement Wallonie 
FIA Region I 
Fujitsu Ten (Europe) GmbH 

Synopsis re 

German Insurers Accident Research at GDV 
JASIC - Japan Automobile Standards 
Internationalisation Centre 
MAN Truck & Bus AG 
NIRA Dynamics 
PSA Peugeot Citroen 
RDW (Dutch National Authority) 
RoadPeace 
SBD Automotive 
Schrader / Sensata Technologies 
Seeing Machines 
Society of Motor Manufacturers and Traders Limited 
(SMMT) 
Toyota Motor Europe NV/SA (as part of ACEA 
comments) 
Transport & Environment (T&E) 
Transport for London (TfL) 
University of Leeds, Institute for Transport Studies 
VTI - Swedish National Road and Transport 
Research Institute 

60 

 
 
 
 
 
 
 
2.2. Public consultation 

Consultation activities 

1. INTRODUCTION 

This synopsis documents all the consultation activities accompanying the preparation of the proposal 
for revision of General Safety Regulation and the Pedestrian Safety Regulation. 

The  formal  Commission’s  public  consultation  on  the  proposal  took  place  between  31  July  and  22 
October 2017. However, there were significant additional targeted consultations namely: in the context 
of  our  initial  study,  finalised  early  2015,  there  was  a  general  stakeholder  engagement  in  July  2014 
through the 124th meeting of the Working Group on Motor Vehicles (the Commission's expert group 
involving  public  and  private  stakeholders),  which  was  then  followed  by  a  targeted  (face-to-face) 
stakeholder  two-day  consultation  event  in  October  2014.  The  findings,  opinions  and  detailed 
discussions  on  the  extensive  list  of  over  50  new  and  unregulated  vehicles  safety  measures  were 
accurately captured in the report as published by the Commission, forming the basis for a ‘shortlist’ for 
further consideration. Discussions with Member States' authorities and international partners also took 
place prior to the completion of the study. 

On 16 February 2016, the Commission presented to the Member States and stakeholders (at the 131st 
meeting of the Working Group on Motor Vehicle) a set of 19 potential ‘shortlist’ measures that could 
be  considered  for  the  revision  of  the  Regulations  under  the  present  initiative.  In  the  context  of  the 
follow  up  review  study,  in  November  2016  a  further  intensive  two-day  stakeholder  consultation 
seminar took place with 72 attendees representing 32 scholars/research organisations, safety advocacy 
groups, vehicle manufacturers, vehicle supplier industry, local/national governments and other relevant 
experts. 

The key objectives of these in depth consultations were on the one hand to inform stakeholders of the 
Commission’s  views  on  the  way  forward  for  vehicle  safety,  and  on  the  other  hand  to  present  to  all 
stakeholders  in  the  most  transparent  way  possible,  all  data, parameters,  expert  views  and  its  sources 
that would form the backbone of the impact assessment in terms of data sets of in particular the vehicle 
safety  system  voluntary  uptake  rates,  technology  cost,  technology  effectiveness  and  traffic  victim 
target population, as well as in particular the stakeholder’s judgement and validation of this key data 
being sufficiently and appropriately robust, relevant and up-to-date. In other words, an elaborate and 
very extensive form of peer-reviewing the data and impact assessment approach. 

The  results  of  these  consultations  were  subsequently  used  for  the  preparation  of  the  proposal  and 
accompanying impact assessment.  

2. RESULTS OF THE PUBLIC CONSULTATION 

The  on-line  public  consultation  consisted  of  three  dedicated  questionnaires  for  public  authorities, 
companies/organisations and road users and was available in six languages: German, English, French, 
Polish,  Italian  and  Spanish.  31  position  papers  or  further  explanations  of  the  replies  in  the 
questionnaires were received by email or as attachment to the questionnaire. 

61 

 
27  organisations/companies  and  two  public  authorities  were  registered  in  the  EU  Transparency 
Register99.  

Responses  to  the  public  consultation  are  voluntary  and  represent  only  views  of  the  respondents. 
Consequently they cannot be interpreted as representative in a statistical sense to the whole EU.  

2.1. Description of respondents 

Distribution of 
respondents by category 

13% 

41% 

46% 

Road users

Companies/orgn
aisations

Public authorities

48 

replies 

(13%), 

Responses  are  classified  based  on  self-
identification by the respondent. By the end of 
the  consultation  period 
the  Commission 
received  118  replies:  15  replies  from  public 
authorities100 
from 
companies  and  organisations  (41%),  and  55 
replies  from  road  users  (46%).  The  replies 
came  from  18  EU  Member  States,101  an  EEA 
country 
country 
(Switzerland)  and  one  non-European  country 
(Israel).  21  Organisations/companies,  6  public 
authorities and 4 road users submitted position 
papers.102 

an  EFTA 

(Norway), 

Distribution of replies across Member States 

road users

public authority

company/organisation

25

20

15

10

5

0

Below, we offer detailed information on the profile of each respondent group 

99 http://ec.europa.eu/transparencyregister/public/homePage.do  
100 For some Member States different authorities replied. 
101 Under category "other" we have listed EU countries represented in a smaller proportion of replies such as: Ireland (2 replies) and Czech Republic, 

Estonia, Finland, Hungary, Latvia, Poland, Romania and Slovakia (one reply each).  

102 Numerical analysis of responses is based only on those that came via EU Survey. Position papers not following the questionnaire of the EU Survey are 

used only for describing arguments presented by stakeholders and for description of respondents. 

62 

 
 
 
 
 
 
                                                 
2.2 Breakdown of Public authorities  

Public Authorities 

27% 

13% 

60% 

Road safety

Traffic
enforcement

Other

Most  public  authorities  participating 
the  public 
consultation  represent  road  safety  organisations  (9), 
followed by traffic enformencent (2 ).   

in 

More than half of these institutions are big organisations, 
employing 250 or more employees.  

2.3 Breakdown of private companies and organisations  

Private industry 

Automotive equipment

15% 

Maintenance services

44% 

15% 

10% 

4% 

4% 

8% 

Car safety

Organisations representating vehicle
producers
Vehicle producers

Organisations representating
automotive equipment producers
Others

The spectrum of sectors representing private companies has been quite broad and balanced, with 15% 
of  the  sample  representing  automotive  equipment  producers,  15%  of  companies  working  on 
maintenance  services,  10%  dealing  with  car  safety  and  8%  being  organisations  representing  vehicle 
producers.  

Private  industry  remained  silent  on  the  types  of  vehicles  they  produce.  This  could  be  in  part  be 
explained by the fact that vehicle producers have already provided extensive detailed input throughout 
the preliminary stakeholder engagements that we have organised in preparation of the initiative and did 
not deem it necessary to provide it again at a later stage. 

Around  2/3  of  the  companies  and  organisations  did  not  provide  information  on  the  number  of 
employees. From those that did provide an answer, eight are big firms, with 250 or more employees 
and nine are SMEs.  

The majority of organisation/companies also did not want to reveal their annual turnover in 2015, only 
about  35%  (17)  provided  information,  out  of  which  six  had  above  €  50  million;  four  had  €  10-50 
million; three had less than € 2 million.  

63 

 
 
 
 
 
 
 
The  majority  of  organisations/companies  did  not  provide  information  on  their  turnover  and 
employment figures most probably as they didn't find it relevant or they didn't want to reveal their size. 
Therefore data on the size of all companies/organisations that participated in the public consultation is 
not complete.   

The  list  of  private  companies  and  organisations  which  participated  in  the  public  consultation  and 
voluntarily accepted to be publicly identified is provided in the Annex. 

2.4 Breakdown of Road Users  

Road users 

4% 

16% 

Individuals

Company or
organisations

Public Authorities  -
road safety

80% 

the 

road 
and 

The  majority  of  road  users  indicated  to  drive  mostly 
for  private  reasons  (around  45%),  while  only  few 
(15%) stated to drive mostly for work purposes.   

consultation 

Most  road  users  participating  in 
public 
identified 
themselves  as  individuals  (80%), 
while only 16% were identified as 
companies  or  organisations  (two 
passenger  transport  companies  or 
organisations;  one  vehicle  traffic 
or 
consulting 
organisation; one vehicle safety or 
safety  company  or  organisation 
five  other  type  of  companies  or 
organisations)    and  only  4%  as 
public authorities.  

company 

Motivation for driving  

45% 

50,00%
40,00%
30,00%
20,00%
10,00%
0,00%

20% 

20% 

15% 

Private
reasons

Work
purposes

Other

N/A

Results of consultation activities 

The  individual  contributions  received  in  response  to  the  public  stakeholder  consultation  will  be 
publicly available. 

The  following  sections  summarise  the  replies  received  from  the  respondents.  Since  some  of  the 
questions allow for more than one answer, for those questions the number of total replies received is 
indicated, instead of percentage value. 

64 

 
 
 
 
 
 
 
 
 
3.1 Need for new legislation 

A broad majority of the respondents (87%) support mandatory introduction of the new vehicle safety 
features and requirements in the EU legislation, while a minority (6 respondents) consider this should 
be  done  as  a  voluntary  agreement  within  industry.  The  share  of  supporters  for  the  mandatory 
introduction  of  the  suggested  safety  measures  among  the  public  authorities  who  replied  in  the 
consultation is high, namely 80% (12 respondents out of 15 in total), with no public authority stating 
preference for voluntary implementation by manufacturers. However, a notorious share of road users 
and  organisations  did  not  answer  this  question  (38%  and  33%  respectively).  Among  those  that 
answered,  a  large  majority  (more  than  80%  in  both  stakeholders'  category)  preferred  a  mandatory 
implementation. Only two road users and four organisations believe this should be done on the basis of 
the automotive industry's self-commitment or voluntary agreements.  

3.2 Scope of the new legislation 

As  regards  the  scope  of  vehicles  to  be  covered  by  the  new  safety  measures,  the  preferences  of  the 
respondents are summarised in the chart below: 

Priorities in relation to vehicle categories* 

Trailers 
3% 

HDV Buses 
13% 

Other 
16% 

HDV Trucks 
21% 

LDV Passenger cars 
(incl. SUVs) 
26% 

LDV light 
commercial and 
vans 
21% 

* Respondents could indicate multiple vehicle categories. 

Concerning  the  scope  of  accidents  to  be  covered  by  the  new  legislation  the  vast  majority  of  the 
responses  indicated  that  either  all  types  of  accidents  or  at  least  the  most  severe  ones  should  be 
addressed  (these  measures  received  a  35.5%  and  43.22%  of  support  respectively),  while  a  relatively 
small  proportion  gave  priority  to  the  most  frequent  accidents  instead  (19  replies).  As  most  frequent 
accident types the respondents point to: (i) rear collision of motor vehicle into tail-end of another or 
multiple vehicles in a row (50% of stakeholders); (ii) collision of motor vehicle with pedestrians (44% 
of  stakeholders);  (iii)  collision  of  motor  vehicle  with  cyclists  (39.8%)  and  (iv)  frontal  collision 
between two motor vehicles (33.9%).  

A  similar  trend  is  reflected  in  the  answers  to  the  question  on  the  top  accidents  types  that  should  be 
addressed  by  further  action  at  EU  level.  Stakeholders  agree  that  priority  action  should  be  given  to 
address  accidents  of  motor  vehicles  with  pedestrians  (24.7%).  Cyclists  are  also  perceived  as  a 
vulnerable  group.  More  than  21%  of  stakeholders  consider  that  collision  of  motor  vehicles  with 

65 

 
 
cyclists  should  be  further  addressed  by  the  EU.  Finally,  frontal  and  rear  collisions  between  motor 
vehicles are also perceived as major concerns to be tackled further (18 and 13 replies respectively).  

The  most  preferred  method  to  address  road  accidents  at  EU  level  is  the  introduction  of  new  vehicle 
safety features (29.4% of stakeholders). There was also a large consensus on the need to address road 
infrastructure, marking, signs and signalling in order to reduce road accidents.  26.7% of stakeholders 
identified this measure as the 2nd most important.  Other measures, such as improving driver training 
and raising driver awareness and improving general training were also identified as important ones but 
to a lower extent (26.7% of stakeholders). 

The charter below provides a global overview on the number of replies received that rank each of the 
suggested 19 safety requirements as top three priority measures for the new legislation: 

Autonomous emergency breaking
Intelligent speed assistance
Lane-keeping assistance
Driver drowsiness/distraction monitoring
Emergency breaking display
Safety belt reminders
Frontal crash testing update
Side crash testing update
Rear crash testing update
Alcohol interlock device installation
Crash event data recorder
Tyre pressure monitoring

Front-end design & direct vision (trucks &…
Rear underrun protection (trucks&trailers)
Truck lateral protection
Fire safety for buses
Pedestrian & cyclist forward detection
Head impact & front windscreen protection
Reversing camera

Priority 1

Priority 2

Priority 3

0

10

20

30

40

Stakeholders agree on considering Autonomous emergency breaking (20.6%) and Intelligent speed 
assistance (16.8%) as the preferred safety requirements with more potential to reduce fatalities. 
Pedestrian and cyclist forwards detection (19.6%) has also been considered a safety measures with 
high potential, with a large share of stakeholders considering it its second priority.  Lane keeping 
assistance had a large consensus among stakeholders (18.6%) as their 3rd priority measure to be 
introduced in legislation.  

3.2.1 Position papers 

21  organisations/companies  sent  position  papers.  The  larger  European  associations  representing  the 
interests  of  automotive  industry  such  as  ACEA,  CLEPA  and  ETRMA  expressed  their  support  for 
introduction of new measures. Position papers were sent, on commercial vehicles and passenger cars. 
For  passenger  cars,  the  importance  of  a  cost/benefit  analysis  of  all  the  measures  was  emphasized. 
Synergies between different measures and avoidance of double counting of benefits were mentioned. 
This  aspect  has  indeed  been  taken  fully  on  board  in  the  cost/benefit  calculation  model.  For  trucks  a 
concern about forced modification of direct visibility for trucks was raised and taken into account by 
means of a later introduction date. The other two associations highlighted their support for the measure 

66 

 
 
on  Tyre  Pressure  Monitoring  System  (TPMS),  the  importance  of  its  better  implementation,  and  its 
positive  impact  on  optimisation  of  fuel  efficiency  and  reduction  of  CO2.  Two  organisations 
representing  the  interests  of  small  and  ultra-small  volume  car  manufacturers  argued  that  different 
implementation period for new safety measures should apply for small volume manufacturers. In some 
cases they suggest complete exemption from new requirements due to significant cost of development 
and implementation of new requirements for such manufacturers, due to complexity or lack of access 
to  technology.  These  issues  are  important,  relevant  and  should  thus  be  considered,  especially  in  the 
context of SME activities. Matters related to small-series exemptions are however dealt with in the EU 
vehicle  type-approval  ‘Framework  Directive’103  and  the  relevant  suggestions  should  be  incorporated 
there  in  the  same  spirit  of  adapted  implementing  dates  of  the  requirements  for  electronic  stability 
control  systems  as  done  in  the  original  GSR,  recommending  a  similar  mechanism  for  this  initiative. 
Several organisations concerned about safety of cyclists and pedestrians expressed their strong support 
for the measure on direct vision for heavy duty vehicles and called upon earlier implementation dates 
than  suggested  in  the  previous  studies.  This  was  also  the  case  for  two  organisations  representing 
insurances  with  regard  to  Autonomous  Emergency  Braking  for  Pedestrians  and  Cyclists  and  Adult 
Head to Windscreen Area Protection. These opinions have indeed largely been taken on board  in the 
cost/benefit model.  Finally,  just  one  organisation  noted  they  are  not  in  favour  of  a  proposed  vehicle 
safety  measure,  namely  the  one  on  mandatory  installation  of  Event  Data  Recorder,  pointing  out 
concerns about privacy, reliability and robustness of data and liability and warranty. It was therefore 
noted in the impact assessment that it will not be possible to identify the specific unique vehicle (and 
thus potentially its owner) with data made available through the EDR.  

Six  supporting  position  papers  were  received  from  public  authorities.  Certain  authorities  sent  letters 
accompanying  their  questionnaires  to  provide  further  context  and  support  to  their  responses  in  the 
questionnaire  and  explain  in  more  detail  their  position.  One  of  them  highlighted  several  detailed 
approaches for certain measures, in particular those tackling truck fatalities. One called for an earlier 
implementation  date  for  minimum  direct  vision  requirements.  One  emphasized  the  importance  of 
appropriate timeline for fitment of measures that do not exist yet, i.e. not already fitted voluntary by 
manufacturers.   

Four position papers were submitted also by road users. Most of them expressed overall their support 
for new measures, one sent background information on road accidents. 

3.3 Expected outcome from the new legislation 

It  is  worth  mentioning  that  the  above  measures  are  largely  supported  by  all  three  groups  of 
respondents,  which  see  significant  positive  outcome  thereof.  Around  2/3  of  the  respondents  believe 
that  as  a  result  of  mandating  the  new  vehicle  safety  features  at  EU  level:  (i)the  number  of  traffic 
accidents will decrease (78.8% of stakeholders agree on this); ii) safety features will become cheaper 
(on  average  77.11%  of  stakeholders  confirmed  this);  (iii)  the  number  of  road  traffic  deaths  will  go 
down  significantly  (average  of  76%  of  stakeholders);  and  (iv)  the  number  of  severe  injuries  in  road 
traffic  accidents  will  also  decrease  considerably  (average  of  74.55%  of  stakeholders).  Although  the 
opinions are more diversified, a large share of stakeholders (44.9%) also believes that car insurances 

103 Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007 establishing a framework for the approval of motor vehicles 

and their trailers, and of systems, components and separate technical units intended for such vehicles (OJ L 263, 9.10.2007, p. 1) 

67 

 
                                                 
will  decrease  while  at  the  same  time  the  introduction  of  self-driving  vehicles  in  Europe  will  be 
speeded-up (45.7%). 

Regarding the final impact on vehicle’s price, opinions are divers. Almost 30% of stakeholders think 
that new legislation might impact final vehicle prices, although 24.7 % slightly disagree.  

3.4 Time-line for implementation of the new legislation 

On  the  time  needed  for  the  manufacturers  to  implement  the  new  vehicle  safety  features,  the 
information provided is not complete as only one of the respondents from the companies/organisation 
group  replied  to  this  set  of  questions.  The  reply  shows  that depending  on  the  features  different time 
line will be necessary. The stakeholder rightfully noted that some of the measures, as for example the 
safety belt reminder and the truck and trailer rear underrun protection (rear bumper) covered UNECE 
harmonised legislation as updated due to technical progress after the start of the preparations for this 
initiative in 2014, can be omitted from the initiative altogether. Other measures, such as tyre pressure 
monitoring, crash event data recorder, alcohol interlock device, emergency braking display and reverse 
monitoring, seems to be easily implemented in short-term, while for the rest e.g. driver's drowsiness 
and distraction monitoring, autonomous emergency braking, lane keeping assistance, intelligent speed 
assistance, etc. a longer lead time is needed. 

4. RESULTS OF TARGETED CONSULTATIONS 

The Commission discussed  the possible revision of the two Regulations on several occasions with  a 
broad range of stakeholder.  

A  targeted  (face-to-face)  stakeholder  consultation  took  place  in  October  2014.  All  relevant 
stakeholders were represented, namely vehicle producers, automotive suppliers, road safety advocacy, 
Member States, scholars and several other NGOs. Several MEPs had also expressed interest to be kept 
informed. The discussion was focused on technological feasibility of a very broad range of measures 
proposed,  more  than  50,  their  feasibility  from  a  technical  standpoint  and  their  potential  cost-
effectiveness based on available data. The measures were presented in the following ranking: Likely to 
be feasible and cost-effective (‘green’ measures), less-likely to be feasible or cost-effective (‘orange’ 
measures) and finally not likely to be feasible or cost-effective (‘red’ measures). There were no strong 
opposing  views.  Moreover  where  there  was  doubt,  the  relevant  stakeholders  offered  to  provide 
additional  (objective)  data  either  to  support  the  cost/benefit  calculations  or  to  clarify  that  a  measure 
was not feasible or cost-effective. 

In  the  context  of  the  2016  review  study,  in  November  2016  an  intensive  stakeholder  consultation 
seminar  took  place  (72  attendees  representing  associations,  industry,  NGOs  and  others).  A  further 
discussion was organised, this time on the shortlisted measures. New and updated data used for cost-
effectiveness  of  measures  was  presented  to  the  stakeholders.  This  specifically  concerned  voluntary 
uptake rates, technology cost, technology effectiveness and traffic victim target population. This data 
was presented in  24 separate fact sheets, each covering a specific topic, that were made  available in 
advance  of  the  stakeholder  event  to  all  registered  participants.  At  the  session,  the  fact  sheets  were 
discussed  in  depth  in  two  dedicated  groups,  in  a  set  order,  divided  according  to  specialism.  This 
allowed  participants  to  jump  from  one  to  another  topic  between  the  different  groups  if  preferred.  In 
principle, the main goal of applying this consultation strategy in the preparatory stage of this initiative 
was to ensure the acceptance by all the relevant stakeholders of the presented data to be used for the 
impact assessment and for them to explicitly validate it between experts as the best-available, robust, 

68 

 
relevant  and  up-to-date  data.  Thus  as  a  result,  the  relevant  data  used  for  the  impact  assessment  has 
been reviewed by ‘opposing’ stakeholders and is thus objective to a very large degree. 

Several stakeholders raised the matter of interaction between the different measures if implemented on 
vehicles  at  the  same  time  and  the  possible  overlap  or  double  counting  of  benefits.  Technological 
synergies  were  also  pointed  out  meaning  that  one  type  of  hardware  could  be  used  for  different 
measures, leading to reduced overall cost. Both these important observations were taken fully on board 
in the impact assessment’s cost/benefit calculation model.  

In order to assure the transparency of the process, the Commission has further presented and discussed 
the measures at the Working Group on Motor Vehicles (124th meeting104 and 131th meeting105), where 
associations representing industry and other stakeholders were present as well as member states. There 
have been numerous other instances where the Commission presented the ongoing work, notably for 
members  of  the  European  Parliament,  Member  States  and  international  expert  fora,  in  order  to  raise 
awareness. 

Use of consultation results 

The  suggestions  by  stakeholders  are  taken  on  board  to  a  very  large  degree  in  the  preparation  of  the 
impact assessment, and align mostly with the Commission’s intentions. 

With 118 responses received and 31 position papers submitted, the public stakeholder consultation had 
a very satisfactory and sufficiently representative reply rate. This holds also for the distribution of the 
respondent’s  affiliation  which  can  be  qualified  as  balanced  with  most  significant  participation  from 
road users and organisations/companies; but also public authorities were well represented. 

Overall, the consultation process went smoothly. As regards the written contributions/position papers 
received on the public consultation, the initiative appears very broadly accepted and well supported by 
all  stakeholders.  Objections  were  received  from  only  one  of  the  organisations,  in  particular  on  the 
safety  measure  related  to  mandatory  installation  of  event  (accident)  data  recorder,  linked  to  privacy 
issues that can actually be adequately addressed when implemented. 

Mandatory introduction of the new safety measures by the manufacturers appears generally to be the 
preferred  way  forward  for  most.  Introduction  of  new  vehicle  safety  features  was  selected  as  the 
preferred  method  to  address  the  road  accidents  at  EU  level  by  most.  The  expected  outcome  by 
respondents,  of  the  actions  covered  by  the  consultation,  corresponds  mostly  to  the  objectives  of  the 
proposed initiative, namely that the number of traffic accidents will fall, the number of road deaths will 
go down and the number of severe injuries and road traffic accidents will also decrease considerably. 

Much information submitted in position papers was already shared with the Commission at earlier 
stages, in particular during targeted consultations with relevant stakeholders. The whole process of 
involving different parties concerned has been throughout very transparent. 

104 https://circabc.europa.eu/w/browse/23e5db20-3cd0-4e34-820f-1ba1d802a738 
105 https://circabc.europa.eu/w/browse/6e903b1e-4bf7-46b1-bccf-117cfaf0733b 

69 

 
 
                                                 
ANNEX 3 – WHO IS AFFECTED BY THE INITIATIVE AND HOW 

3.1. Practical implications of the initiative 

Comparison of the impact of policy options on stakeholders  

Stake-
holder 

Policy 
option  

PO0 

PO1 

PO2 

PO3 

Aspects 
consider
ed: 

Vehicle users  Pedestrians 
and cyclist 

Vehicle 
manufacturers 

Equipment 
manufactures 

Member 
States 

0 

≈ 

+ 

++ 

0 

≈ 

++ 

++ 

0 

≈ 

 

0 

+ 

+ 

0 

≈ 

+ 

  

++ 

++ 

no 

Increased 
occupant 
safety; 
substantial 
increases 
in 
vehicle prices 
the 
to 
due 
additional 
safety 
measures 
in 
the  medium 
and long term 
expected; 
potential 
reduced 
insurance 
premiums; 
potential 
increase 
in 
vehicle  repair 
costs; 
Reduced 
vehicle 
efficiency 
due 

fuel 

for 

to 

Increased 
vulnerable 
road 
safety; 

user 

Increased 
safety  system 
and 
component 
sales; 
encouraging 
innovative 
technologies/
R&D 

Increased 
costs; 
OEM 
potential 
for 
harmonisation 
of 
technical 
requirements 
across  regions 
and 
between 
OEMs; 
encouraging 
innovative 
technologies/ 
R&D 

Reduction  in 
emergency 
service 
requirements; 
in 
reduction 
road 
closures/cong
estion leading 
to  increase  in 
productivity; 
in 
reduction 
fatalities/seri
ous 
casualties; 
increase 
equitable 
treatment  of 
VRUs 
in 
vehicle safety 
legislation; 
increased 
VRU 
could 
encourage 
more 
cycling/walki

safety 

70 

 
increased 
vehicle  mass; 
increased 
driving 
comfort;  AID 
to  maintain 
the  mobility 
of 
rehabilitating 
drink-driving 
offenders, 
while 
minimising 
recidivism 
rates 

to 

ng;  potential 
for  increased 
CO2 
emissions 
due 
increased 
vehicle  mass 
and  potential 
for 
reduced 
emission  due 
to  TPM;  cost 
of 
defining 
test 
regulatory 
requirements 

Magnitude of impact as compared with the baseline scenario (the baseline is indicated as 
0): ++ strongly positive; + positive; – – strongly negative; – negative; ≈ marginal/neutral; ? 
uncertain; n.a. not applicable  

Casualties: 

All vehicle categories 

Fatal casualties prevented 

Serious casualties prevented 

Monetary indicators: 

All vehicle categories 

Present value benefit 

Present value cost 

BCR (best estimate) 

PO3 

24 794 

140 740 

PO3 

€ 72.8 bn 

€ 57.4 bn 

1.27 

BCR (uncertainty range lower/upper106) 

0.91 

1.68 

106   € 70.5 bn / € 77.8 bn lower, € 92.9 bn / € 55.2 bn upper 

71 

 
 
 
 
                                                 
3.2. SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred Option 

Description 

Amount 

Comments 

Casualties prevented (fatal, 
serious and slight) by safety 
measures 

Direct benefits 

€ 72.8 bn 

Reduced road congestion due to 
avoided collisions 

not quantified 

Value of safety per se (citizens), and 
avoidance of direct and indirect 
economic costs (businesses and 
administrations) 

Reduced loss of time (citizens), 
increased productivity (businesses), and 
better use of existing road infrastructure 
(administrations) 

Reduced vehicle emissions 
(speed assistance system, tyre 
pressure monitoring) 

Potential for reduced motor 
insurance premiums due to 
avoided collisions 

Potential for harmonisation of 
technical requirements for 
safety measures 

not quantified 

Improved air quality (citizens) 

Indirect benefits 

not quantified 

Reduced cost of mobility (citizens) 

not quantified 

Reduced costs for variants due to 
standardisation between vehicle 
manufacturers or across world regions 
(businesses) 

Potential for reduced 
enforcement costs (speed 
assistance system) 

not quantified 

Reduced police cost for surveillance and 
enforcement of speed limit compliance 
(administrations) 

72 

 
 
 
 
 
II. Overview of costs – Preferred option 

Citizens/Consumers  

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct costs 

No substantial vehicle retail 
price increases due to 
proposed safety measures in 
the medium and long term 
expected. 

€ 57.4 bn  
(one-off costs and ongoing 
production costs incurred by 
vehicle manufacturers) 

Not quantified 
(implementation of 
legislation) 

Indirect costs  Higher repair costs  

(only in case of defect or 
damage) 

Included in estimate above 
(regulatory charges and 
administrative costs to 
vehicle manufacturers) 

Not quantified 
(contribution to the 
development of type-
approval requirements) 

3.3. Detailed discussion on road safety problem drivers 

3.3.1. Slow market uptake of new safety features in the vehicle fleet 

Features such as autonomous emergency braking, lane keeping assist and reversing camera, have a 
great  potential  to  improve  road  safety,  either  by  avoiding  collisions  altogether  or  reducing  impact 
speed and mitigating the level of victims’ injury levels. Improved active and passive safety features 
also play an important role to further reducing the number of fatalities or injuries in collisions that 
will inevitably still occur. 

The voluntary market uptake of new vehicle safety features has shown to be rather unfavourable. 

For instance, stability control systems reached an 80% voluntary fitment plateau in the period before 
it was made mandatory on all new vehicles.  

Detailed  analysis  as  carried  out  to  establish  the  baseline  scenario  illustrates  the  situation  for 
autonomous  emergency  braking  systems  on  passenger  cars with  fleet  fitment  rates in  2015  of  only 
32% of new cars that were registered in the Netherlands, 30% in Belgium, 16% in Spain and 21% in 
the  United  Kingdom,  whereas  the  technology  became  prominently  available  already  since  2009.  A 
negligible proportion of these cars are currently equipped with systems that can detect an impending 
collision with a pedestrian or cyclist. 

As concerns intelligent speed assistance systems on passenger cars, analysis revealed that only 1% to 
10% of the passenger car fleet was equipped in 2015 with some form of built-in speed alert system, 
hence  the  proportion  of  an  advanced  intelligent  system  is  estimated  to  be  much  lower.  Finally, 
approximately 1%  of the  car fleet was equipped with  lane keeping support systems in  2015 with a 
new vehicle fitment rate around just 5% according to available 2012 and 2013 data. 

73 

 
 
 
 
3.3.2. Outdated safety exemptions for SUVs, MPVs, vans and the like 

Currently,  heavy  passenger  cars  (e.g.  family  van,  SUV,  MPV107)  and  all  light  commercial  vehicles 
(e.g. cargo delivery van, pick-up) are fully exempted from the frontal crash testing as introduced in 
1996. At that time the exemptions were introduced based on either a very low market availability of 
such vehicles or the notion that utility vehicles would have severe difficulties to comply due to their 
size and mass. It was further suggested that compliance with the legislation would make larger and 
heavy cars stiffer at the front, and that this would create a specific problem for small non-compliant 
older cars in collisions with newer compliant heavy cars (i.e. compatibility mismatch). However, this 
issue has become increasingly obsolete over time, given that a high percentage of small cars in the 
fleet108  now meet the frontal impact off-set crash requirements. 

The absence of frontal crash testing requirements for light commercial vehicles as a whole, based on 
the  notion  of  size  and  mass  as  with  SUVs,  presents  the  situation  that  workers  that  are  required  to 
drive light commercial vehicles to carry out their duties cannot rely on a harmonised minimum level 
of frontal crash protection. The actual safety level depends fully on the vehicle purchase choice made 
by their employers. 

Vehicles  that  do  not  have  a  seating  position  under  just  70  cm  above  ground  level  are  in  turn  fully 
exempted from the side impact crash test. Also in this case it notably includes those passenger cars 
that can be characterised as SUVs as well as delivery type vans. The exemption was based on a lower 
risk of bodily injury of occupants, due to the ‘high’ seating position. In principle this reasoning is still 
valid, but the regulations contain other safety criteria covering spontaneous door opening in a crash 
or  all  doors  being  jammed  shut  after  a  crash,  which  are  then  also  neglected,  putting  occupants  of 
these vehicles at a risk.  

Rear  impact  crash  testing  has  been  exempted  altogether  for  all  vehicle  categories  although  the 
relevant test specifications and requirements have existed on UNECE level that apply in the EU since 
its accession in 1997109. Its current application in the EU is mandatory, but with a specific exemption 
concerning the rear crash test.  

When motor-vehicles are exempted from these types of crash tests, the post-crash protection against 
electric shock and fire risks can also not be guaranteed. 

These  perilous  loopholes  should  be  avoided  especially  in  the  light  of  proliferation  of  SUVs  in  the 
marketplace, up from only 3% in 1996 to 14% market penetration in 2016110 and the increasing sales 
figures111 for light commercial vehicles with the market addressing urban mobility solutions. It should 
also be avoided in light of the accelerated shift towards zero-emission mobility, with electric vehicles 
and  their  heavy  and  high  capacity  batteries,  viewed  by  the  Commission  as  key  enabling 
technology112. For reference, in the first two quarters of 2017, there was significant growth in demand 
for both chargeable electric vehicles (+38%) and hybrid electric vehicles (+61%)113 compared to the 
same period the previous year. Clearly, these battery powered vehicles always need to offer adequate 

107   Family van is generally defined as a passenger car version of e.g. a cargo delivery van with windows all around and up 
to 9 seating positions – SUV means Sport Utility Vehicle generally defined as a large station wagon shaped vehicle 
with high riding position that is designed to be used on rough off-road surfaces, but that is rather often used on urban 
roads and motorways – MPV means Multi-Purpose Vehicle generally defined as a family van, but not derived from a 
cargo delivery van, with high riding position and up to 9 seating positions 

108   Eurostat, Road transport equipment – Stock of vehicles 
109   OJ L 346, 17.12.1997, p. 78 
110   http://www.acea.be/statistics/tag/category/4x4-penetration 
111   http://www.acea.be/statistics/tag/category/by-country-registrations  
112   COM(2017) 283 final 
113   http://www.acea.be/statistics/tag/category/electric-and-alternative-vehicle-registrations 

74 

 
                                                 
protection  against  electric  shock  and  vehicle  fire  after  a  crash  has  happened  and  thus  the  current 
exemptions must be revisited. 

Available data that has been analysed to assess this issue provides a high confidence that current EU 
built large heavy vehicles will have no problems to pass the regulatory requirements, as is clear from 
various  relevant  Euro  NCAP  safety  tests114  that  show  sufficiently  adequate  levels  of  protection  are 
attained  by  such  vehicles  subjected  to  the  evaluation  tests,  as  represented  in  today’s  vehicle  fleet. 
Hence, there is no justification to maintain these old exemptions. 

It  may  be  feared  that  these  exemptions  will  be  further  exploited115  by  vehicle  manufacturers 
producing less sophisticated cars outside of the EU with the aim to provide cheaper alternatives or 
gain bigger profits than their competition that do take safety seriously. When they do not ensure an 
adequate level of safety protection of such vehicles, this is all unknown to the drivers, end-consumers 
or  rescue  workers.  EU  citizens  should  however  be  able  to  trust  that  all  these  vehicles  also  comply 
with minimum safety standards as set for passenger cars in general. 

114   Business  &  Family  Vans  –  https://www.euroncap.com/en/ratings-rewards/business-family-vans,  SUVs  – 
and 

https://www.euroncap.com/en/ratings-rewards/latest-safety-ratings/?selectedClasses=1197 
https://www.euroncap.com/en/ratings-rewards/latest-safety-ratings/?selectedClasses=1198 

115   H-1033/05 

75 

 
 
 
                                                 
ANNEX 4 – ANALYTICAL MODELS USED IN PREPARING THE IMPACT ASSESSMENT. 

4.1. Description of analytical models used 

A model suite has been used for the analytical work: PRIMES-TREMOVE transport model, a specific 
model developed by TRL in the programming language Python116 with inputs and outputs produced in 
Microsoft  Excel  spreadsheets  and  an  Excel-based  tool  developed  by  COWI.  While  PRIMES-
TREMOVE is a transport model covering the entire transport system, used for the development of the 
EU Reference scenario 2016, TRL and COWI models specifically focus on evaluating the impacts of 
vehicle  technologies  and  infrastructure  measures  on  road  safety,  respectively.  A  brief  description  of 
each model is provided below, followed by an explanation of each model’s role in the context of this 
impact assessment. 

4.1.1. PRIMES-TREMOVE transport model 

The PRIMES-TREMOVE transport model projects the evolution of demand for passengers and freight 
transport  by  transport  mode  and  transport  mean.  It  is  essentially  a  dynamic  system  of  multi-agent 
choices  under  several  constraints,  which  are  not  necessarily  binding  simultaneously.  The  model 
consists of two main modules, the transport demand allocation module and the technology choice and 
equipment operation module. The two modules interact with each other and are solved simultaneously.   

The  projections  include  details  for  a  large  number  of  transport  means,  technologies  and  fuels, 
including  conventional  and  alternative  types,  and  their  penetration  in  various  transport  market 
segments for each EU Member State. They also include details about greenhouse gas and air pollution 
emissions  (e.g.  NOx,  PM,  SOx,  CO),  as  well  as  impacts  on  external  costs  of  congestion,  noise  and 
accidents. 

In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g. eco-driving, 
deployment of Intelligent Transport Systems, labelling), economic measures (e.g. subsidies and taxes 
on fuels, vehicles, emissions; ETS for transport when linked with PRIMES; pricing of congestion and 
other  externalities  such  as  air  pollution,  accidents  and  noise;  measures  supporting  R&D),  regulatory 
measures (e.g. CO2 emission performance standards for new passenger cars and new light commercial 
vehicles;  EURO  standards  on  road  transport  vehicles;  technology  standards  for  non-road  transport 
technologies),  infrastructure  policies  for  alternative  fuels  (e.g.  deployment  of  refuelling/recharging 
infrastructure for electricity, hydrogen, LNG, CNG). Used as a module which contributes to a broader 
PRIMES scenario, it can show how policies and trends in the field of transport contribute to economy 
wide  trends  in  energy  use  and  emissions.  Using  data  disaggregated  per  Member  State,  it  can  show 
differentiated trends across Member States.  

PRIMES-TREMOVE  has  been  used  for  the  2011  White  Paper  on  Transport,  Low  Carbon  Economy 
and Energy 2050 Roadmaps, the 2030 policy framework for climate and energy and more recently for 
the  Effort  Sharing  Regulation,  the  review  of  the  Energy  Efficiency  Directive,  the  recast  of  the 
Renewables  Energy  Directive,  the  European  strategy  on  low-emission  mobility,  the  revision  of  the 
Eurovignette Directive and the recast of the Regulations on CO2 standards for light duty vehicles. 

116  https://www.python.org/ 

76 

 
                                                 
The  PRIMES-TREMOVE  is  a  private  model  that  has  been  developed  and  is  maintained  by 
E3MLab/ICCS of National Technical University of Athens117, based on, but extending features of the 
open  source  TREMOVE  model  developed  by  the  TREMOVE118  modelling  community.  Part  of  the 
model (e.g. the utility nested tree) was built following the TREMOVE model119. Other parts, like the 
component on fuel consumption and emissions, follow the COPERT model.  

As module of the PRIMES energy system model, PRIMES-TREMOVE120 has been successfully peer 
reviewed121, most recently in 2011122. 

4.1.2. TRL model 

A  simulation  model  was  developed  by  TRL  to  estimate  the  benefits  (monetary  values  of  casualties 
prevented by safety measures) and costs (cost to vehicle manufacturers of fitment of safety measures 
to new vehicles) associated with policy measures assessed in the context of the revision of the General 
Safety Regulation and Pedestrian Safety Regulation. The model was implemented in the programming 
language  Python123  with  inputs  and  outputs  produced  in  Microsoft  Excel  spreadsheets.  Figure  0-1 
presents a simplified visualisation of the structure and calculation steps of the model. The scope of the 
cost-effectiveness evaluation was: 

  Geographic scope: EU28 
  Vehicle categories covered: M1, M2&M3, N1, N2&N3 
  Evaluation period: 2021–2037 
  Baseline  scenario:  No  further  policy  intervention  in  the  transport  sector,  but  voluntary 
improvements  and  effects  of  already  implemented  policies  continue.  Continued  dispersion  of 
mandatory vehicle safety measures into the legacy fleet and continued voluntary uptake of the 
safety measures under consideration. 

  Evaluated  scenarios:  Three  sets  of  safety  measures  (PO1,  PO2  and  PO3)  implemented  on  a 

mandatory basis 

  Benefits considered: Monetary values of casualties prevented by safety measures 
  Costs considered: Cost to vehicle manufacturers of fitment of safety measures to new vehicles 
  Treatment of uncertainty: Interval analysis and scenario analysis 
  Results:  Benefit-to-cost  ratios  (BCRs),  based  on  present  monetary  values  and  casualties 

prevented, compared to the baseline scenario over the entire evaluation period 

117  Source: http://www.e3mlab.ntua.gr/e3mlab/ 
118  Source: http://www.tmleuven.be/methode/tremove/home.htm 
119  Several model enhancements were made compared to the standard TREMOVE model, as for example: for the number 
of  vintages  (allowing  representation  of  the  choice  of  second-hand  cars);  for  the  technology  categories  which  include 
vehicle types using electricity from the grid and fuel cells. The model also incorporates additional fuel types, such as 
biofuels  (when  they  differ  from  standard  fossil  fuel  technologies),  LPG  and  LNG.  In  addition,  representation  of 
infrastructure for refuelling and recharging are among the model refinements, influencing fuel choices. A major model 
enhancement concerns the inclusion of heterogeneity in the distance of stylised trips; the model considers that the trip 
distances  follow  a  distribution  function  with  different  distances  and  frequencies.  The  inclusion  of  heterogeneity  was 
found to be of significant influence in the choice of vehicle-fuels especially for vehicles-fuels with range limitations. 
120  The model can be run either as a stand-alone tool (e.g. for the 2011 White Paper on Transport and for the 2016 Strategy 
on low-emission mobility) or fully integrated in the rest of the PRIMES energy systems model (e.g. for the Low Carbon 
Economy and Energy 2050 Roadmaps, for the 2030 policy framework for climate and energy, for the Effort Sharing 
Regulation, for the review of the Energy Efficiency Directive and for the recast of the Renewables Energy Directive). 
When coupled with PRIMES, interaction with the energy sector is taken into account in an iterative way. 
121  Source: http://ec.europa.eu/clima/policies/strategies/analysis/models/docs/primes_model_2013-2014_en.pdf 
122  https://ec.europa.eu/energy/sites/ener/files/documents/sec_2011_1569_2.pdf 
123  https://www.python.org/ 

77 

 
                                                 
The vehicle fleet calculation model determines how the vehicle safety measures disperse into the fleet. 
The model determines the effect of mandating a measure for all new types, and two years later for all 
new registered vehicles, on the overall proportion of the fleet equipped. Benefits conferred by a safety 
measure, that is, casualties prevented, will only be realised by equipped vehicles. However, the legacy 
fleet  will  also  be  affected  by  active  safety  measures;  for  example,  if  a  rear-end  shunt  is  avoided  by 
autonomous emergency braking for driving and still-standing vehicles ahead (AEB-VEH), the vehicle 
in front, will benefit from the measure even if it is a legacy vehicle. This is taken into account in the 
benefit calculations. 

Figure 0-1: Flowchart of the TRL simulation model to calculate benefit-to-cost ratios  

To simulate the casualties prevented by each measure, an accident data analysis was performed based 
on Great Britain national road accident data (Stats19) to determine the casualty target population for 
each  proposed  measure,  i.e.  the  number  of  fatal,  serious  and  slight  injuries  that  could  potentially  be 
affected by a safety measure based on relevant characteristics of the collision (e.g., collision geometry 
or  contributory  factors).  The  target  populations  were  scaled  to  EU28  level  using  weighting  factors, 
based on severity and vehicle categories involved, derived from analysis of the pan-European CARE 

78 

 
 
 
database.  The  target  populations  found  are  multiplied  with  effectiveness  values  for  each  safety 
measure, i.e. a percentage value indicating what proportion of the relevant accidents will be avoided or 
mitigated  by  the  measure.  Mitigated  casualties  (fatal  turned  to  serious  casualty,  or  serious  to  slight 
casualty) are added to the target population of the next lower injury severity level for other measures. 
The casualties prevented are multiplied with monetary values for casualty prevention to calculate the 
monetary benefit. 

Evaluation period  

To  model  the  costs  and  benefits  of  the  safety  measures,  it  was  necessary  to  set  an  evaluation  window 
which  allowed  technology  sufficient  time  to  propagate  through  the  vehicle  fleet  and  into  the  collision 
population. This was set by considering the earliest time at which a measure could affect all new vehicles 
(year 2023, 2 years after introduction for new approved types); then an allowance was added for the age of 
the  traffic  population  (mileage  contribution  to  total  miles  driven  is  not  constant  over  the  vehicle  age). 
Previous evidence, established for the car fleet in London, has demonstrated that about 88% of the traffic 
is 0 to 11 years old and 97% of the traffic is 0 to 14 years old. Vehicles which are 15 years old account for 
about only 1% of the traffic and about 2% of the collision involved cars. Therefore, 14 years was added to 
new vehicle implementation date to allow the full cycle of fleet benefits to be captured. This period also 
matches the length of time allocated for the majority of voluntary uptake measures to reach close-to-full 
adoption levels. As such, the evaluation period was set to extend from 2021 to 2037. 

The model also addresses the interaction of different safety measures on overlapping casualty groups. 
To give an example, there are collisions where a driver was exceeding the speed limit, left the lane and 
suffered a frontal impact. These collisions will be in the target populations for multiple measures, but 
they can only be prevented once by either one of these systems. This is addressed in the model by 
removing casualties prevented by one measure from the subsequent target population of the other 
measures. The impact of highly effective existing safety measures, which have been mandatory for a 
few years, but are still dispersing into the vehicle fleet is also modelled to reduce the remaining target 
populations for the proposed measures. 

Fleet dispersion of vehicle technology safety measures  
There are two aspects to the fleet fitment estimates which are vital to the process of establishing the cost-effectiveness for 
the measures related to vehicle technologies. 

−  The voluntary uptake which defines a ‘do nothing’ scenario. In this case, the propagation of technology is led by the 
willingness of manufacturers to fit the necessary components to vehicles and the willingness of consumers to pay for 
them. 

−  The mandatory uptake brought about by a policy intervention. In this case, all new vehicles or all vehicle types will be 
required to meet the regulatory requirements by an implementation date. The effects of this will be superimposed at 
that moment in time. 

To model the uptake of technology alongside each of the measures, it was necessary to define the uptake by new vehicles 
and also the penetration into the fleet due to fleet expansion and ‘churn’ (the rolling addition of new vehicles and scrappage 
of old). This textbox provides an illustration on the way in which the model accounts for technology propagation on a 
voluntary or mandatory basis. The model accounts for the fact that some of the vehicles being scrapped in the churn 
process would also have the technology fitted. Otherwise, an overly optimistic estimate of technology penetration would be 
generated. 
Voluntary fleet fitment estimates were based on evidence identified previously (Seidl et al., 2017), comments provided by 
stakeholders and, in the absence of other information, opinions of an expert panel within TRL based on observations of 
similar technologies and expectations of pressures on the industry (for instance, whether a measure is likely to be 
incentivised by Euro NCAP). 
The launch date for a technology was used to define the x-axis (time) start point for s-shaped curves of fitment. This relates 
to the first time a system was released with the characteristics likely to be required in order to meet the regulatory 
requirements. As a general rule, the launch date was intended to be independent of vehicle category; assuming general 
transfer of technologies was possible, with some exceptions. The year that full voluntary implementation is achieved 

79 

 
 
dictates the gradient or slope of the s-shaped curve and represents the time necessary for the measure to reach maturity in 
terms of full voluntary adoption into new vehicle registrations.  
The voluntary take up of technology and the implementation within the fleet was selected to be one of three possible 
options: 

  None = No voluntary uptake, regulatory action required to drive adoption 

  Medium = 40% voluntary propagation within the fleet without additional stimuli 

  High = 80% voluntary propagation leaving the 20% of vehicles which wouldn’t be equipped without regulatory 

action 

These values represent point estimates for the resulting final take up in the fleet. The s-shaped curve for percentage of 
newly registered cars equipped is modelled to form a plateau at this value. 
Examples of model outputs for measure uptake and fleet dispersion of pedestrian-capable autonomous emergency braking 
(AEB-PCD) in cars are shown in Figure 21, Figure 22 (voluntary uptake scenario) and Figure 23, Figure 24 (mandatory 
uptake scenario). In the voluntary uptake scenario it can be seen that this high-uptake measure levels off at approximately 
80% fleet fitment by the end of the evaluation period (Figure 22). The mandatory uptake scenario follows the voluntary 
uptake curve up until 2023 and elevates the new vehicle fitment rates from then onward gradually over two years to 100% 
(Figure 23). Even with full fitment in new vehicles, it still takes time for those vehicles to replace existing vehicles on the 
road, but the effect of regulation can be seen in the resulting higher fleet fitment of more than 90% by the end of the study 
period (Figure 24). The difference between these curves is responsible for the casualties prevented of a policy option 
compared to the baseline option.  

Figure  10:  Percentage  of  newly  registered  cars  equipped 
with pedestrian-capable AEB in voluntary uptake scenario 

Figure  11:  Percentage  of  all  cars  within  the  vehicle  fleet 
equipped with pedestrian-capable AEB in voluntary uptake 
scenario 

Figure  12:  Percentage  of  newly  registered  cars  equipped 
with 
mandatory 
implementation scenario (new approved types from 2023, 
all new cars from 2025) 

pedestrian-capable 

AEB 

in 

Figure  13:  Percentage  of  all  cars  within  the  vehicle  fleet 
equipped  with  pedestrian-capable  AEB  in  mandatory 
implementation  scenario  (new  approved  types  from  2023, 
all new cars from 2025) 

80 

 
 
 
 
 
 
The  cost  of a  policy  option  is  calculated  by  multiplying  per-vehicle  cost  estimates  for  each  measure 
with  the  number  of  new  vehicles  of  each  vehicle  category  across  EU28  that  are  equipped  with  the 
measure in the given year of the analysis according to the output of the fleet calculation model. In the 
economic calculation model, the monetary values of costs and benefits are subjected to inflation and 
discounting  to  determine  their  present  value.  The  present  values  of  benefits  and  costs  exceeding  the 
baseline, calculated for individual years and summed over the study period, are compared in order to 
arrive at cost-effectiveness estimates. 

A more detailed description of the TRL analytical model is provided in the impact assessment support 
study outlined in the sub-Annexes below. 

4.1.3. COWI model 

An  Excel-based  tool  was  developed  by  COWI  to  assess  the  impacts  of  measures  related  to 
infrastructure  on  road  safety.  The  tool  covers  each  EU  Member  State  individually  and  distinguishes 
between  the  TEN-T  and  non-TEN-T  network,  drawing  on  the  CARE  database124  and  the  TENtec 
information system125.  

The approach to quantify impacts on fatalities and injuries includes a number of calculation steps: 

−  Estimation of the effect of each measure expressed as a percentage reduction of the baseline number 

of fatalities and serious injuries; 

−  Estimation of the share of fatalities and serious injuries that the measure apply to; 

−  Calculation  of  the  expected  reduction  in  the  number  of  fatalities  and  serious  injuries  by  Member 

State for the proportion of the fatalities and injuries that are covered by the measure; 

−  Application of social unit costs of fatalities and serious injuries to the above-calculated reduction to 

derive the estimated benefits.  

The sources for the estimation of the impacts on the number of fatalities and serious injuries are based 
on  two  main  studies:  the  Safety  Cube  project  and  the  Handbook  of  Road  Safety  Measures.  These 
studies include almost all evidence available on the impacts of infrastructure on road safety. 

SafetyCube review project126 
The  SafetyCube  project  is  a  Horizon2020  research  project,  which  aims  at  ”…developing  an  innovative 
road safety Decision Support System (DSS) that will enable policy-makers and stakeholders to select and 
implement the most appropriate strategies, measures and cost-effective approaches to reduce casualties of 
all road user types and all severities”. 
The project involves a review of some 50 infrastructure related road safety risk factors and 48 associated 
improvement measures. In total, some 800 papers/studies were coded. Many of the studies reviewed as 
part of the SafetyCube project are specific Case studies, where certain risk factors are analysed in certain 
geographical locations, including examples of measures applied to address these factors. 
The Handbook of Road Safety Measures127 
Contains  summaries  regarding  the  effects  of  128  road  safety  measures.  It  covers  various  areas  of  road 
safety  including:  traffic  control;  vehicle  inspection;  driver  training;  publicity  campaigns;  police 

124  Source: https://ec.europa.eu/transport/road_safety/specialist/statistics_en 
125  Source : https://ec.europa.eu/transport/themes/infrastructure-ten-t-connecting-europe/tentec-information-system_en 
126  See e.g. Filtness A. & Papadimitriou E. (Eds) (2016), Identification of Infrastructure Related Risk Factors, Deliverable 

5.1 of the H2020 project SafetyCube. 

127  Elvik,  R.,  T.  Vaa,  A.  Hove  and  M.  Sorensen  eds.  (2012)  The  Handbook  of  Road  Safety  Measures:  Forth  Edition  in 

Norwegian Second ed. In English, 2009. 

81 

 
                                                 
enforcement; and, general policy instruments. It also covers topics such as post-accident care, and speed 
cameras. 
The main sections and topics of the handbook are: 
−  Literature Survey and Meta-Analysis 
−  Factors Contributing to Road Accidents 
−  Basic Concepts of Road Safety Research 
−  Assessing the Quality of Evaluation Studies  
−  Road Design and Road Equipment 
−  Road Maintenance 
−  Traffic Control 
−  Vehicle design and protective devices 
−  Vehicle and Garage Inspection 
−  Driver Training and Regulation of Professional Drivers 
−  Public Education and Information 
−  Police Enforcement and Sanctions 
−  Post-Accident Care 
−  General-Purpose Policy Instruments 
The handbook builds upon a large number of case studies, research papers and reports and studies 
undertaken in many different projects. It is recognised among road safety experts as a central reference 
point. 

The compliance costs128 are closely related to the share of fatalities and injuries that are influenced by 
each  measure.  For  the  calculation  of  the  compliance  costs  (costs  of  applying  the  road  infrastructure 
safety  management  procedures  and  subsequent  investments  in  changes  to  the  infrastructure),  the 
calculation steps include: 

−  Estimation of the relevant unit costs per kilometre of road of each measure; 

−  Estimation of the share of roads (typically in km) where the measure would be applied; 

−  Calculation of the total compliance costs of the measure. 

In  the  compliance  costs  estimation,  it  is  assumed  that  the  same  share  (length)  of  roads  is  subject  to 
each measure as the one used for the estimation of the reduced number of fatalities and injuries. There 
are, however, deviations from this general assumption. For example, the assumption is changed when 
considering motorcycle friendly guard rails. Such rails are installed where the risk of a crash is high (in 
turns where there are road side objects etc.). This will typically not be along the entire stretch of road. 
Therefore, we assume a smaller number of kilometres where the rails are installed, but retain the full 
impact of the measure on all VRU fatalities and injuries. 

Another important assumption is that investments are made firstly where the impacts are highest. This 
is  also  the  approach  outlined  in  the  14  case  studies  of  the  EuroRAP  SENSOR  project129  looking  at 
Southern  and  Eastern  European  countries.  The  textbox  below  outlines  how  the  case  study  has  been 
used to estimate investment costs needed to correct the safety defects in Member States where there is 
no specific information about costs of making upgrades.  

128  In the quantification of economic impacts, ’compliance costs’ are costs both to undertake the different procedures and 

the costs of investing in the safety changes recommended as part of the procedures. 

129  These case studies are documented in a set of national reports and in a joint summary report: EuroRAP (2016)  

82 

 
                                                 
SENSOR case studies and the use to estimate costs 

The outcome of the SENSOR study is an application of the iRAP EuroRAP method to assess roads using 
automated detection vehicles. The results are shown in section 4 of the impact assessment support study 
for the investigated EU Member States130. 

Part of the work also included a bottom up approach to calculate investments costs in order to remedy the 
detected safety issues. For the broad categories of issues (e.g. obstacles placed close to the road, missing 
centre  and  edge  lines,  barriers,  road  surface,  additional  lanes  etc.),  measures  to  correct  the  defects  were 
proposed and cost-benefit analysis was carried out. For measures with an overall positive evaluation, these 
were added up in so-called Safer Roads Investment Plans (SRIP). 

The costs per km of road is the factor that has been used to calculate the total costs. The costs are adjusted 
by  using  Price  level  index  and  the  Purchase  Power  Parity  (PPP)  to  undertake  value  transfer  to  other 
countries.  

When calculating costs, it has been assumed that the costs in the SRIP correspond to lifting all roads in the 
observed countries to 3 star roads.131 This means that 1 star roads must be “lifted by two stars”, whereas 2 
star roads must be “lifted only one star”. This implies that on average, there are twice as many defects to 
be adjusted on 1 star roads compared to 2 star roads.132 For each country, we therefore assume that one km 
of 1 star roads is twice as costly to adjust compared to one km of 2 star road. The distribution between 1 
and 2 star roads in the observed SENSOR countries is used to calculate the weighted average of lifting a 
road by one star. Or in mathematical terms: 

𝐶𝑜𝑠𝑡 𝑝𝑒𝑟 𝑠𝑡𝑎𝑟 𝑙𝑖𝑓𝑡𝑒𝑑 𝑝𝑒𝑟 𝑘𝑚

= 2 ∗

#𝑘𝑚1 𝑠𝑡𝑎𝑟
#𝑘𝑚1 𝑠𝑡𝑎𝑟 + #𝑘𝑚2 𝑠𝑡𝑎𝑟

+

#𝑘𝑚2 𝑠𝑡𝑎𝑟
#𝑘𝑚1 𝑠𝑡𝑎𝑟 + #𝑘𝑚2 𝑠𝑡𝑎𝑟

𝑆𝑅𝐼𝑃 𝑐𝑜𝑠𝑡𝑠 𝑝𝑒𝑟 𝑘𝑚

 𝑆𝑅𝐼𝑃 𝑐𝑜𝑠𝑡𝑠 𝑝𝑒𝑟 𝑘𝑚 

The resulting weighted average costs per km to lift a road by one star is then applied to other countries 
where specific costs are not provided (after adjusting to the price level in this country). 

The resulting average unit costs per km using the approach outlined in the text box are shown in Table 
0-1. The resulting compliance costs per km of road that is improved by one star are shown for each 
country in annex G of the impact assessment support study. 

130  Final report – Support study for an impact assessment of the revision of Directive 2008/96/EC on road infrastructure 
safety management and Directive 2004/54/EC on minimum safety requirements for road tunnels in the trans-European 
network (to be published)  

131  IRAP and EuroRAP use 3 star roads as the reference point for safe roads. Hence, on average the identified defects in the 

SENSOR study is aiming at lifting roads to 3 stars. 

132  In reality there may be more individual things to change in lifting a 1 star road to 2 star than a road lifted from 2 star to 
3 stars. On the other hand, the possibly fewer things to improve on 2-star roads will be on average more expensive. Due 
to variations between the specific roads, the assumption is that the total costs per km ”per star” that is lifted is the same. 

83 

 
                                                 
Table 0-1 Estimated costs per km of carriageway133 to address the identified safety defects using the 
EuroRAP methodology  

Country 

Bulgaria 

Croatia 

Greece 

Hungary 

Romania 

Slovakia 

Slovenia 

Average 

Country code 

Price adjusted million  euro/carriageway km 

BG 

HR 

EL 

HU 

RO 

SK 

SI 

0.3369 

0.1102 

0.1556 

0.0852 

0.2201 

0.1052 

0.0624 

0.1537 

Source: SENSOR case study. Note: Prices are adjusted according to price level indexes.  

The assessment of administrative costs is based on the EU Standard Cost Model, covering the costs of 
reporting obligations.  

To  calculate  the  present  values  of  the  benefits  (and  the  costs),  the  following  set  of  assumptions  has 
been applied. 

Table 0-2 Cost benefit analysis - assumptions 

Parameter 
Time horizon 

First year of effect from 
measures 

Unit  
years 

year 

Implementation period 

years 

Social discount rate (SDR)  % 

Assumption 
2020-2050 

2020 

10 

4% 

Inflation 

% per year 

Price Level Index  

Index 

Harmonized Index of 
Consumer Prices 
(HICP) 
Calculated for all 
countries 

Comment 
A sensitivity analysis is carried out, where only 
a ten year period is analysed (2020-2030) 
It is assumed that the measures will have an 
effect on the number of fatalities and injuries 
from 2020 onwards 
It is assumed that all measures are implemented 
gradually over ten years and the effects follow 
the implementation.  
The Better Regulation Guidelines suggest the 
use of 4% as the social discount rate for impact 
assessments. It is mentioned that when 
considering road infrastructure with long life 
times, a lower or a declining rate could be used.  
All costs and benefits have been expressed in 
2016 prices based on the HICP from Eurostat. 

The price level index, drawing on Eurostat and 
European Central Bank, is used to account for 
the different price levels in each country. 

4.1.4.  PRIMES-TREMOVE,  TRL  and  COWI  models  role  in  the  impact 
assessment 

The  PRIMES-TREMOVE  transport  model  is  a  building  block  of  the  modelling  framework  used  for 
developing the EU Reference scenario 2016, and has a successful record of use in the Commission's 
transport, climate and energy policy analytical work – it is the same model as used for the 2011 White 
Paper on Transport and the 2016 European strategy on low-emission mobility.    

133  Carriageways corresponds to main roads and motorways, but not to smaller roads, nor to general urban roads. The costs 

are estimated in the SENSOR study. They are not the result of actual investments made. 

84 

 
  
 
                                                 
The TRL model is a simulation tool assessing the impact of vehicle technologies on road safety in the 
context of the revision of the General Safety Regulation and Pedestrian Safety Regulation.  

In  this  impact  assessment,  building  on  an  update  of  the  EU  Reference scenario  2016  (including  few 
policy  measures  that  have  been  adopted  after  its  cut-off  date  i.e.  end  of  2014),  the  PRIMES-
TREMOVE  model  together  with  the  TRL  model  have  been  used  to  define  the  common  Baseline 
scenario used for the purpose of the present impact assessment report and for the impact assessment 
accompanying the revision of the General Safety Regulation and Pedestrian Safety Regulation. In the 
first step, the TRL model has been calibrated on the projected evolution of the vehicle stock from the 
update of the EU Reference scenario 2016. In the second step, the impact of mandatory and voluntary 
vehicle technology measures on the number of fatalities, serious and slight injuries has been assessed 
at EU28 and Member State levels with the TRL and PRIMES-TREMOVE models drawing on input 
from TRL.   

The COWI tool has been calibrated on the Baseline scenario developed with the PRIMES-TREMOVE 
and TRL model and has been subsequently used for assessing the impacts of infastructure measures on 
road  safety  and  performing  cost-benefit  analysis  in  the  context  of  this  impact  assessment.  The  TRL 
model has been used for assessing the impacts of vehicle tehchnologies on road safety and performing 
cost-benefit analysis in the context of the impact assessment accompaying the revision of the General 
Safety Regulation and Pedestrian Safety Regulation. 

4.2. Baseline scenario  

4.2.1. Scenario design, consultation process and quality assurance 

The Baseline scenario used in this impact assessment builds on the EU Reference scenario 2016 but 
additionally  includes  few  policy  measures  adopted  after  its  cut-off  date  (end  of  2014)  and  some 
updates in the technology costs assumptions. 

Building an the EU Reference scenario is a regular exercise by the Commission. It is coordinated by 
DGs ENER, CLIMA and MOVE in association with the JRC, and the involvement of other services 
via a specific inter-service group.  

For  the  EU  Reference  scenario  2016,  Member  States  were  consulted  throughout  the  development 
process  through  a  specific  Reference  scenario  expert  group  which  met  three  times  during  its 
development.  Member  States  provided  information  about  adopted  national  policies  via  a  specific 
questionnaire, key assumptions have been discussed and in each modelling step, draft Member State 
specific results were sent for consultation. Comments of Member States were addressed to the extent 
possible, keeping in mind the need for overall comparability and consistency of the results. 

Quality of modelling results was assured by using state of the art modelling tools, detailed checks of 
assumptions  and  results  by  the  coordinating  Commission  services  as  well  as  by  the  country  specific 
comments by Member States. 

The  EU  Reference  scenario  2016  projects  EU  and  Member  States  energy,  transport  and  GHG 
emission-related developments up to 2050, given current global and EU market trends and adopted EU 
and Member States' energy, transport, climate and related relevant policies. "Adopted policies" refer to 

85 

 
those  that  have  been  cast  in  legislation  in  the  EU  or  in  MS  (with  a  cut-off  date  end  of  2014134). 
Therefore,  the  binding  2020  targets  are  assumed  to  be  reached  in  the  projection.  This  concerns 
greenhouse gas emission reduction targets as well as renewables targets, including renewables energy 
in  transport.  The  EU  Reference  scenario  2016  provides  projections,  not  forecasts.  Unlike  forecasts, 
projections  do  not  make  predictions  about  what  the  future  will  be.  They  rather  indicate  what  would 
happen if the assumptions which underpin the projection actually occur. Still, the scenario allows for a 
consistent  approach  in  the  assessment  of  energy  and  climate  trends  across  the  EU  and  its  Member 
States.   

The report "EU Reference Scenario 2016: Energy, transport and GHG emissions - Trends to 2050"135 
describes the inputs and results in detail. In addition, its main messages are summarised in the impact 
assessments accompanying the Effort Sharing Regulation136 and the revision of the Energy Efficiency 
Directive137, and the analytical work accompanying the European strategy on low-emission mobility138.   

PRIMES-TREMOVE is one of the core models of the modelling framework used for developing the 
EU  Reference  scenario  2016  and  has  also  been  used  for  developing  the  Baseline  scenario  of  this 
impact  assessment  in  connection  with  the  TRL  model.  The  model  was  calibrated  on  transport  and 
energy data up to year 2013 from Eurostat and other sources. 

4.2.2. Main assumptions of the Baseline scenario 

The  projections  are  based  on  a  set  of  assumptions,  including  on  population  growth,  macroeconomic 
and oil price developments, technology improvements, and policies.  

Macroeconomic assumptions 

The Baseline scenario uses the same macroeconomic assumptions as the EU Reference scenario 2016. 
The  population  projections  draw  on  the  European  Population  Projections  (EUROPOP  2013)  by 
Eurostat.  The  key  drivers  for  demographic  change  are:  higher  life  expectancy,  convergence  in  the 
fertility rates across Member States in the long term, and inward migration. The EU28 population is 
expected to grow by 0.2% per year during 2010-2030 (0.1% for 2010-2050), to 516 million in 2030 
(522 million by 2050). Elderly people, aged 65 or more, would account for 24% of the total population 
by 2030 (28% by 2050) as opposed to 18% today.  

GDP projections mirror the joint work of DG ECFIN and the Economic Policy Committee, presented 
in the 2015 Ageing Report139. The average EU GDP growth rate is projected to remain relatively low at 
1.2%  per  year  for  2010-2020,  down  from  1.9%  per  year  during  1995-2010.  In  the  medium  to  long 
term, higher expected growth rates (1.4% per year for 2020-2030 and 1.5% per year for 2030-2050) 
are  taking  account  of  the  catching  up  potential  of  countries  with  relatively  low  GDP  per  capita, 
assuming convergence to a total factor productivity growth rate of 1% in the long run.  

134  In addition, amendments to two Directives only adopted in the beginning of 2015 were also considered. This concerns 
notably  the  ILUC  amendment  to  the  Renewables  Directive  and  the  Market  Stability  Reserve  Decision  amending  the 
ETS Directive. 

135  ICCS-E3MLab et al. (2016), EU Reference Scenario 2016: Energy, transport and GHG emissions - Trends to 2050 
136  SWD(2016) 247 
137  SWD(2016) 405 
138  SWD(2016) 244 
139  European  Commission/DG  ECFIN  (2014),  The  2015  Ageing  Report:  Underlying  Assumptions  and  Projection 

Methodologies, European Economy 8/2014. 

86 

 
                                                 
Fossil fuel price assumptions 

Oil prices used in the Baseline scenario are the same with those of the EU Reference scenario 2016. 
Following a gradual adjustment process with reduced investments in upstream productive capacities by 
non-OPEC140 countries, the quota discipline is assumed to gradually improve among OPEC members 
and thus the oil price is projected to reach 87 $/barrel in 2020 (in year 2013-prices). Beyond 2020, as a 
result  of  persistent  demand  growth  in  non-OECD  countries  driven  by  economic  growth  and  the 
increasing number of passenger cars, oil price would rise to 113 $/barrel by 2030 and 130 $/barrel by 
2050.  

Techno-economic assumptions 

For  all  transport  means,  except  for  light  duty  vehicles  (i.e.  passenger  cars  and  light  commercial 
vehicles),  the  Baseline  scenario  uses  the  same  technology  costs  assumptions  as  the  EU  Reference 
scenario 2016.  

For light duty vehicles, the data for technology costs and emissions savings has been updated based on 
a recent study commissioned by DG CLIMA141. Battery costs for electric vehicles are assumed to go 
down  to  205  euro/kWh  by  2030  and  160  euro/kWh  by  2050;  further  reductions  in  the  cost  of  both 
spark  ignition  gasoline  and  compression  ignition  diesel  are  assumed  to  take  place.  Technology  cost 
assumptions  are  based  on  extensive  literature  review,  modelling  and  simulation,  consultation  with 
relevant  stakeholders,  and  further  assessment  by  the  Joint  Research  Centre  (JRC)  of  the  European 
Commission. 

Specific policy assumptions 

The key policies included in the Baseline scenario, similarly to the EU Reference scenario 2016, are142:   

  CO2  standards  for  cars  and  vans  regulations  (Regulation  (EC)  No  443/2009,  amended  by 
Regulation (EU) No 333/2014 and Regulation (EU) No 510/2011, amended by Regulation (EU) No 
253/2014);  CO2  standards  for  cars  are  assumed  to  be  95gCO2/km  as  of  2021  and  for  vans 
147gCO2/km as of 2020, based on the NEDC test cycle, in line with current legislation. No policy 
action to strengthen the stringency of the target is assumed after 2020/2021. 

  The  Renewable  Energy  Directive  (Directive  2009/28/EC)  and  Fuel  Quality  Directive  (Directive 
2009/30/EC)  including  ILUC  amendment  (Directive  2015/1513/EU):  achievement  of  the  legally 
binding  RES  target  for  2020  (10%  RES  in  transport  target)  for  each  Member  State,  taking  into 
account the use of flexibility mechanisms when relevant as well as of the cap on the amount of food 
or feed based biofuels (7%). Member States' specific renewable energy policies for the heating and 
cooling sector are also reflected where relevant. 

  Directive on the deployment of alternative fuels infrastructure (Directive 2014/94/EU). 

  Directive on the charging of heavy goods vehicles for the use of certain infrastructures (Directive 

2011/76/EU amending Directive 1999/62/EC).  

140  OPEC stands for Organization of Petroleum Exporting Countries. 
141  Source: https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/technology_results_web.xlsx  
142  For a comprehensive discussion see the Reference scenario report: “EU Reference Scenario 2016: Energy, transport and 

GHG emissions - Trends to 2050”  

87 

 
                                                 
  Relevant national policies, for instance on the promotion of renewable energy, on fuel and vehicle 

taxation, are taken into account.  

In addition, a few policy measures adopted after the cut-off date of the EU Reference scenario 2016 at 
both EU and Member State level, have been included in the Baseline scenario: 

  Directive on weights & dimensions (Directive 2015/719/EU); 

  Directive as regards the opening of the market for domestic passenger transport services by rail and 

the governance of the railway infrastructure (Directive 2016/2370/EU); 

  Directive on technical requirements for inland waterway vessels (Directive 2016/1629/EU), part of 

the Naiades II package; 

  Regulation establishing a framework on market access to port services and financial transparency of 

ports143; 

  The  replacement  of  the  New  European  Driving  Cycle  (NEDC)  test  cycle  by  the  new  Worldwide 
harmonized Light-vehicles Test Procedure (WLTP) has been implemented in the Baseline scenario, 
drawing  on  work  by  JRC.  Estimates  by  JRC  show  a  WLTP  to  NEDC  CO2  emissions  ratio  of 
approximately 1.21 when comparing the sales-weighted fleet-wide average CO2 emissions. WLTP 
to NEDC conversion factors are considered by individual vehicle segments, representing different 
vehicle and technology categories144.  

  Changes in road charges in Germany, Austria, Belgium and Latvia.  

Safety measures assumptions 

Reflecting  the  plateauing  in  the  number  of  fatalities  and  injuries  in  the  recent  years,  in  the  Baseline 
scenario  it  has  been  assumed  that  post-2016  vehicle  technologies  would  be  the  main  source  of 
reduction in fatalities, serious and slight injuries while measures addressing infrastructure safety (such 
as  the  existing  RISM  and  Tunnel  Directives),  and  driver  behaviour  (such  as  legislation  improving 
enforcement  across  borders,  namely  Directive  2015/413/EU  facilitating  cross-border  exchange  of 
information on road safety related traffic offences) would compensate for the increase in traffic over 
time. The following vehicle technologies safety measures are covered by the Baseline scenario: 

  The  impact  of  highly  effective  existing  vehicle  technologies  safety  measures,  which  have  been 
mandatory for a few years, but are still dispersing into the vehicle fleet (standard electronic stability 
control  systems  for  all  vehicle  categories,  and  advanced  emergency  braking  systems  and  lane 
departure warning systems for all new heavy goods vehicles and buses), are modelled to reduce the 
remaining target populations for the proposed measures.145 

  Voluntary uptake of vehicle technology safety measures. The list of these measures is provided in 

Table 1. 

143  Awaiting signature of act (Source : 

http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?reference=2013/0157(COD)&l=en)  

144  Simulation at individual vehicle level is combined with fleet composition data, retrieved from the official European CO2 
emissions  monitoring  database,  and  publicly  available  data  regarding  individual  vehicle  characteristics,  in  order  to 
calculate  vehicle  CO2  emissions  and  fuel  consumption  over  different  conditions.  Vehicle  CO2  emissions  are  initially 
simulated  over  the  present  test  protocol  (NEDC)  for  the  2015  passenger  car  fleet;  the  accuracy  of  the  method  is 
validated against officially monitored CO2 values and experimental data. 

145  Standard  electronic  stability  control  systems  are  mandatory  for  all  new  vehicles  and  vehicle  categories  since  1 
November 2014 and from 1 November 2015, all new trucks and buses must also be equipped with advanced emergency 
braking systems as well as lane departure warning systems. 

88 

 
                                                 
Table 0-3: List of vehicle technology safety measures considered for voluntary uptake 

Measure 

Description 

Applicable vehicle categories 

AEB-VEH 

Autonomous emergency braking for vehicles (moving and stationary 
targets) 

AEB-PCD 

Autonomous emergency braking for pedestrians and cyclists 

ALC 

Alcohol interlock installation document 

DDR-DAD 

Drowsiness and attention detection 

DDR-ADR 

Advanced distraction recognition 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

Event data recorder 

Emergency stop signal 

Full-width frontal occupant protection (current R137 configuration 
with Hybrid III ATDs) 

Full-width frontal occupant protection (introduction of THOR-M 
ATDs and lower appropriate injury criteria thresholds to encourage 
adaptive restraints) 

Adult head-to-windscreen impact (mandatory HIC limit in 
headform-to-glass impact tests; no mandatory A-pillar impact) 

Intelligent speed assistance (voluntary type system; can be 
overridden by driver and switched off for the rest of journey) 

Lane keeping assist (emergency lane keeping system that intervenes 
only in case of an imminent threat such as leaving the road, or 
leaving the lane with oncoming traffic) 

Pole side impact occupant protection 

Reversing camera system  

Tyre pressure monitoring system 

VIS-DET 

Front and side vulnerable road user detection and warning (no auto 
braking) 

VIS-DIV 

Minimum direct vision requirement (best-in-class approach) 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M2&M3 

M2&M3 

M2&M3 

M2&M3 

M2&M3 

M2&M3 

M2&M3 

M2&M3 

M2&M3 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

The year that full voluntary implementation is achieved represents the time necessary for the measure 
to  reach  maturity  in  terms  of  full  voluntary  adoption  into  new  vehicle  registrations.  All  but  three 
measures were assumed to have a long voluntary implementation phase, with 14 years between launch 
of  the  technology  and  full  voluntary  implementation.  Car  fitment  Event  Data  Recorders  (EDR)  and 
Full-width  frontal  protection  based  on  current  UN  Regulation  No.  137  with  the  Hybrid  III  dummy 
(FFW-137)  were  given  a  shorter  voluntary  uptake  period  of  6 years.  This  was  justified  based  on  the 
percentage of vehicles in the fleet already expected to meet the regulatory requirements for the system, 
which  matches  the  predicted  final  voluntary  uptake  levels.  A  medium  and  a  long  length  adoption 
period were used for vans and heavier vehicle uptake of EDRs, respectively.  

The voluntary take up of technology and the implementation within the fleet was selected to be one of 
three possible options: 

89 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.  None = No voluntary uptake, regulatory action required to drive adoption 
2.  Medium = 40% voluntary propagation within the fleet without additional stimuli 
3.  High = 80%  voluntary propagation leaving the 20%  of vehicles  which wouldn’t be equipped 

without regulatory action 

These  values  represent  point  estimates  for  the  resulting  final  uptake  in  the  fleet.  The  full  voluntary 
uptake levels for each measure are provided in Table 0-4.  

Table 0-4: Maximum voluntary uptake of vehicle technologies for new registrations 

AEB-VEH 

AEB-PCD (pedestrian) 

AEB-PCD (cyclist) 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESC 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LDW 

LKA-ELK 

PSI 

REV 

TPM 

VIS-DET 

VIS-DIV 

M1 

High 

High 

High 

None 

Medium 

None 

Medium 

High 

High 

High 

High 

None 

None 

n/a 

Medium 

High 

Medium 

n/a 

n/a 

n/a 

M2&M3 

High 

n/a 

n/a 

None 

Medium 

None 

n/a 

High 

High 

n/a 

n/a 

n/a 

None 

High 

n/a 

n/a 

None 

None 

None 

Medium 

N1 

High 

Medium 

Medium 

None 

Medium 

None 

Medium 

High 

High 

Medium 

Medium 

None 

None 

n/a 

Medium 

None 

Medium 

None 

n/a 

n/a 

N2&N3 

High 

n/a 

n/a 

None 

Medium 

None 

n/a 

High 

High 

n/a 

n/a 

n/a 

None 

High 

n/a 

n/a 

None 

None 

None 

Medium 

4.2.3. Summary of main results of the Baseline scenario 

EU  transport  activity  is  expected  to  continue  growing  under  current  trends  and  adopted  policies 
beyond  2015,  albeit  at  a  slower  pace  than  in  the  past.  Freight  transport  activity  for  inland  modes  is 
projected to increase by 36% between 2010 and 2030 (1.5% per year) and 60% for 2010-2050 (1.2% 
per year). Passenger traffic growth would be slightly lower than for freight at 23% by 2030 (1% per 
year)  and  42%  by  2050  (0.9%  per  year  for  2010-2050).  The  annual  growth  rates  by  mode,  for 
passenger and freight transport, are provided in Figure 0-14146. 

146  Projections for international maritime and international extra-EU aviation are presented separately and not included in 

the total passenger and freight transport activity to preserve comparability with statistics for the historical period. 

90 

 
 
 
                                                 
Road transport would maintain its dominant role within the EU. The share of road transport in inland 
freight is expected to slightly decrease at 70% by 2030 and 69% by 2050. The activity of heavy goods 
vehicles expressed in tonnes kilometres is projected to grow by 35% between 2010 and 2030 (56% for 
2010-2050) in the Baseline scenario, while light goods vehicles activity would go up by 27% during 
2010-2030 (50% for 2010-2050). For passenger transport, road modal share is projected to decrease by 
4 percentage points by 2030 and by additional 3 percentage points by 2050. Passenger cars and vans 
would still contribute 70% of passenger traffic by 2030 and about two thirds by 2050, despite growing 
at  lower  pace  (17%  for  2010-2030  and  31%  during  2010-2050)  relative  to  other  modes,  due  to 
slowdown in car ownership increase which is close to saturation levels in many EU15 Member States 
and shifts towards rail. 

Figure 0-14: EU passenger and freight transport projections (average growth rate per year) 

Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab) 
Note: For aviation, domestic and international intra-EU activity is reported, to maintain the comparability with reported 
statistics. 

High  congestion  levels  are  expected  to  seriously  affect  road  transport  in  several  Member  States  by 
2030 in the absence of effective countervailing measures such as road pricing. While urban congestion 
will  mainly  depend  on  car  ownership  levels,  urban  sprawl  and  the  availability  of  public  transport 
alternatives,  congestion  on  the  inter-urban  network  would  be  the  result  of  growing  freight  transport 
activity along specific corridors, in particular where these corridors cross urban areas with heavy local 
traffic.  The  largest  part  of  congestion  will  be  concentrated  near  densely  populated  zones  with  high 
economic  activity  such  as  Belgium  and  the  Netherlands  –  to  a  certain  extent  as  a  result  of  port  and 
transhipment operations – and in large parts of Germany, the United Kingdom and northern Italy. 

The  PRIMES-TREMOVE  model  considers  the  stock  of  transport  means  inherited  from  previous 
periods, calculates scrapping due to technical lifetime, evaluates the economics of possible premature 
scrapping and determines the best choice of new transport means, which are needed to meet demand. 
The choices are based on cost minimisation, which include anticipation factors.147 

147  There are several factors influencing the choice of a new transport means, covering payable and non-payable elements. 
True payable costs include all cost elements over the lifetime of the candidate transport means: purchasing cost; annual 
fixed  costs  for  maintenance,  insurance  and  ownership/circulation  taxation;  variable  costs  for  fuel  consumption 
depending on trip type and operation conditions; other variable costs including congestion charges, parking fees, etc. 
Other  factors,  like  perceived  cost  factors,  which  do  not  necessarily  imply  true  payments  by  the  user  but  may  imply 

91 

-1.0%-0.5%0.0%0.5%1.0%1.5%2.0%2.5%3.0%RoadRailAviationInlandnavigationPassenger transport '95-'10'10-'30'30-'50-1.0%-0.5%0.0%0.5%1.0%1.5%2.0%2.5%3.0%RoadRailInland navigationFreight transport'95-'10'10-'30'30-'50 
 
 
                                                 
 
The road transport vehicle fleet is projected to continue growing over time, driven by developments in 
transport activity. The heavy goods vehicle fleet is projected to grow by 27% between 2015 and 2030 
(1.6% per year) and 52% for 2015-2050 (0.9% per year). Growth in the light commercial vehicle stock 
is  projected to  be somewhat  lower at 15% between  2015 and 2030 (0.9% per year) and 33% during 
2015-2050 (0.8% per year).  

The passenger cars fleet would grow at a lower pace compared to heavy goods and light commercial 
vehicles: 9% by 2030 (0.6% per year) and 24% by 2050 (0.6% per year), driven by slowdown in car 
ownership  increase  which  as  explained  above  is  close  to  saturation  levels  in  many  EU15  Member 
States.  The  buses  and  coaches  fleet  is  also  projected  to  go  up,  at  rates  similar  to  those  of  light 
commericial vehicles:  15%  increase between 2015 and 2030 (0.9% per year)  and 28%  during 2015-
2050 (0.5% per year). 

Figure 0-15: Road transport vehicle stock projections by type of vehicle (average growth rate per year) 
at EU level 

Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab) 

Under  current  trends  and  adopted  policies,  measures  addressing  infrastructure  safety  and  driver 
behaviour  would  compensate for the increase in traffic over  time while the uptake of the mandatory 
and voluntary vehicle technology safety measures described above would result in further decreases in 
the number of fatalities, serious and slight injuries over time. The number of fatalities is projected  to 
go down by 11% between 2015 and 2030 (9% for 2016-2030)  and 16% during 2015-2050 (14% for 
2016-2050), while the reduction in the serious injuries is expected to be lower at 7% by 2030 (6% for 
2016-2030) and 10% by 2050 (10% for 2016-2050). Slight injuries are also projected to drop by 2050, 
however, at much lower pace than fatalities and serious injuries (5% for 2015-2030 and 7% for 2015-
2050). 

indirect  costs  are  influencing  decisions  about  choice  of  new  vehicles.  They  reflect  technical  risk  of  yet  immature 
technologies,  acceptance  factors  representing  market  penetration,  density  of  refuelling/recharging  infrastructure 
applicable to technologies using alternative fuels and those that have range limitations. 

92 

 
 
                                                                                                                                                                       
Figure  0-16:  Evolution  of  fatalities,  serious  and  slight  injuries  over  the  2015-2050  time  horizon 
(average growth rate per year) 

Source: Baseline scenario, TRL model and PRIMES-TREMOVE transport model (ICCS-E3MLab)  

In the Baseline scenario, the evolution of fatalities, serious and slight injuries by EU region continues 
recent trends observed in the historical data, with the Eastern and Southern EU countries showing the 
highest decrease in the number of casualties.    

Figure 0-17: Evolution of fatalities, serious and slight injuries by EU region between 2015 and 2030 
(cumulative growth rates) 

Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab) and TRL model 

4.2.4. Baseline scenario – sensitivity analysis 

Considering  the  high  uncertainty  surrounding  the  evolution  of  fatalities  and  injuries,  sensitivity 
analysis  has  been  performed  on  the  Baseline  scenario.  An  alternative  optimistic  and  a  pessimistic 
baseline scenario have been considered: 

 

In the optimistic baseline scenario, it is assumed that the slight reduction of fatalities and serious 
injuries  observed  during  2014-2016  (0.7%  per  year)  would  come  from  infrastructure,  driver 

93 

 
  
 
 
behaviour and other factors (mandatory vehicles technologies) and the trend of a continuous 0.7% 
reduction  relative  to  the  previous  year  would  be  continued  in  time.  In  addition,  the  voluntary 
uptake  of  vehicle  technologies  measures  is  assumed  to  be  the  same  as  in  the  main  Baseline 
scenario.  

 

In the pessimistic baseline scenario, it is assumed that post-2016 vehicle technologies would be the 
main  source  of  reductions  in  fatalities,  serious  and  slight  injuries,  while  measures  addressing 
infrastructure safety and driver behaviour and other factors would compensate  for the increase in 
traffic  over  time.  However,  a  lower  estimate  of  technology  take  up  was  modelled  to  represent  a 
scenario  where  voluntary  fitment  of  the  voluntary  measures  reaches  only  half  the  maximum 
percentages quoted in Section 0. 

The  projected  evolution  of  fatalities,  serious  and  slight  injuries  over  the  2015-2050  horizon  in  the 
optimistic and pessimistic baseline scenarios is presented in figures 0-18 to 0-20. It is compared with 
the central baseline scenario described in the previous section. In cumulative terms, between 2016 and 
2030 the number of fatalities is projected to go down by 18% in the optimistic baseline scenario and 
6%  in  the  pessimistic  scenario  relative  to  9%  in  the  central  baseline  scenario.  Similarly,  serious 
injuries would decrease by 15% in the optimistic baseline and 4% in the pessimistic baseline compared 
to 6% in the central baseline scenario while slight injuries would go down by 15% in the optimistic 
baseline and 4% in the pessimistic baseline relative to 7% in the central baseline scenario. 

Figure 0-18: Evolution of fatalities over the 2015-2050 time horizon (average growth rate per year) in 
the optimistic and pessimistic baseline scenarios 

Source: Baseline scenario, TRL model and PRIMES-TREMOVE transport model (ICCS-E3MLab)  

94 

-1.6%-1.4%-1.2%-1.0%-0.8%-0.6%-0.4%-0.2%0.0%Baseline - centralBaseline - optimisticBaseline - pessimisticFatalities (annual growth rates)'15-'30'30-'50 
 
 
Figure 0-19: Evolution of serious injuries over the 2015-2050 time horizon (average growth rate per 
year) in the optimistic and pessimistic baseline scenarios 

Source: Baseline scenario, TRL model and PRIMES-TREMOVE transport model (ICCS-E3MLab)  

Figure  0-20:  Evolution  of  slight  injuries  over  the  2015-2050  time  horizon  (average  growth  rate  per 
year) in the optimistic and pessimistic baseline scenarios 

Source: Baseline scenario, TRL model and PRIMES-TREMOVE transport model (ICCS-E3MLab)  

Similarly to the central baseline scenario, the evolution of fatalities, serious and slight injuries by EU 
region  in  the  optimistic  and  pessimistic  baseline  scenarios  continues  recent  trends  observed  in  the 
historical data, with the Eastern and Southern EU countries showing higher decreases in the number of 
casualties relative to the Northern and Central EU countries.    

95 

-1.4%-1.2%-1.0%-0.8%-0.6%-0.4%-0.2%0.0%Baseline - centralBaseline - optimisticBaseline - pessimisticSerious injuries (annual growth rates)'15-'30'30-'50-1.2%-1.0%-0.8%-0.6%-0.4%-0.2%0.0%Baseline - centralBaseline - optimisticBaseline - pessimisticSlight injuries (annual growth rates)'15-'30'30-'50 
 
 
Figure 0-21: Evolution of fatalities, serious and slight injuries by EU reagion between 2015 and 2030 
(cumulative growth rates) in the optimistic baseline scenario 

Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab) and TRL model 

Figure 0-22: Evolution of fatalities, serious and slight injuries by EU reagion between 2015 and 2030 
(cumulative growth rates) in the pessimistic baseline scenario 

Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab) and TRL model 

96 

 
 
 
 
 
 
Annex 4.0

Cost-effectiveness  analysis  of  Policy  Options  for  the 
mandatory  implementation  of  different  sets  of  vehicle 
safety  measures  –  Review  of  the  General  Safety  and 
Pedestrian Safety Regulations 

Annex 4.1

Executive summary 

Objective: 

The objective of this in-depth cost-benefit study was to calculate concrete cost-effectiveness 
indicators and numbers of future casualties that could be prevented at a European level for 
three sets of safety measures proposed by the European Commission and considered for 
mandatory implementation in new vehicles starting from 2021.  

Methodology and scope: 

The European Commission has defined three policy options, i.e. sets of safety measures to 
be implemented on a mandatory basis, for this cost-effectiveness study to assess: 

  PO1: State-of-the-art and widely available package of safety solutions that are not yet 

mandatory in EU; their fitment varies from around 5–90% 

  PO2:  As  PO1  with  added  safety  solutions  that  focus  on  vulnerable  road  user 

protection and on ensuring driver attention to the driving task  

  PO3:  As  PO2  with  safety  solutions  that  are  either  feasible  or  already  exist  in  the 
marketplace,  but  that  have  a  low  fitment  rate  and  market  uptake,  that  maximises 
overall casualty savings and can boost safety solutions' innovation 

The policy options are each studied for their cost-effectiveness compared to a baseline 
scenario (PO0), where none of the measures are implemented on a mandatory basis, but 
voluntary uptake would continue. 

Table 5 presents a full list of the safety measures considered for vehicle categories M1 
(passenger cars), M2&M3 (buses and coaches), N1 (vans), and N2&N3 (trucks). Table 6 to 
Table 9 presents an overview of the sets of measures to be implemented in each policy option 
and the proposed introduction dates. Table 10 presents the cost estimates per vehicle category 
for each of the policy options assessed. 

A simulation and calculation model was developed to estimate the benefits and costs 
associated with each policy option. The scope of the cost-effectiveness evaluation was: 

  Geographic scope: EU-28 
  Vehicle categories covered: M1, M2&M3, N1, N2&N3 
  Evaluation period: 2021–2037 
  Baseline scenario: No further policy intervention in the transport sector, but voluntary 
improvements  and  effects  of  already  implemented  policies  continue.  Continued 
dispersion  of  mandatory  vehicle  safety  measures  into  the  legacy  fleet  and  continued 
voluntary uptake of the safety measures under consideration. 

  Evaluated scenarios: Three sets of safety measures (PO1, PO2 and PO3) implemented 

on a mandatory basis 

  Benefits considered: Monetary values of casualties prevented by safety measures 

97 

 
 
 
  Costs considered: Cost to vehicle manufacturers of fitment of safety measures to new 

vehicles 

  Treatment of uncertainty: Interval analysis and scenario analysis 
  Results:  Benefit-to-cost  ratios  (BCRs),  based  on  present  monetary  values  and 
casualties  prevented,  compared  to  the  baseline  scenario  over  the  entire  evaluation 
period 

Note that the model takes into account: 

 

 

the interactions of all measures when implemented together (to avoid double-counting 
of casualties prevented by different measures), and 
the effects of already existing mandatory measures (AEB-VEH and LDW for M2&M3 
and  N2&N3,  ESC  for  all  categories)  that  are  still  dispersing  into  the  fleet  on  the 
European casualty target populations. 

Table 5: List of safety measures considered for mandatory implementation 

Measure 

Description 

Applicable vehicle categories 

AEB-VEH 

Autonomous emergency braking for vehicles (moving and stationary 
targets) 

AEB-PCD 

Autonomous emergency braking for pedestrians and cyclists 

M1 

M1 

N1 

N1 

ALC 

Alcohol interlock installation document 

M1 

M2&M3 

N1 

N2&N3 

DDR-DAD 

Drowsiness and attention detection 

M1 

M2&M3 

N1 

N2&N3 

DDR-ADR 

Advanced distraction recognition 

M1 

M2&M3 

N1 

N2&N3 

EDR 

Event data recorder 

M1 

N1 

ESS 

Emergency stop signal 

M1 

M2&M3 

N1 

N2&N3 

FFW-137 

Full-width frontal occupant protection (current R137 configuration with 
Hybrid III ATDs) 

FFW-THO 

Full-width frontal occupant protection (introduction of THOR-M ATDs 
and lower appropriate injury criteria thresholds to encourage adaptive 
restraints) 

HED-MGI 

Adult head-to-windscreen impact (mandatory HIC limit in headform-to-
glass impact tests; no mandatory A-pillar impact) 

M1 

M1 

M1 

N1 

N1 

N1 

ISA-VOL 

Intelligent speed assistance (voluntary type system; can be overridden by 
driver and switched off for the rest of journey) 

LKA-ELK 

Lane keeping assist (emergency lane keeping system that intervenes only 
in case of an imminent threat such as leaving the road, or leaving the lane 
with oncoming traffic) 

PSI 

Pole side impact occupant protection 

M1 

M2&M3 

N1 

N2&N3 

M1 

M1 

N1 

N1 

REV 

Reversing camera system  

M1 

M2&M3 

N1 

N2&N3 

TPM 

Tyre pressure monitoring system 

M2&M3 

N1 

N2&N3 

VIS-DET 

Front and side vulnerable road user detection and warning (no auto 
braking) 

M2&M3 

N2&N3 

VIS-DIV 

Minimum direct vision requirement (best-in-class approach) 

M2&M3 

N2&N3 

98 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 6: Policy options for passenger cars (M1); letters indicate mandatory introduction 
dates148, dash indicates measure is not included in the policy option 

Measure 

Baseline 

PO1 (M1) 

PO2 (M1) 

PO3 (M1) 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

A 

– 

A 

– 

– 

A 

A 

A 

– 

– 

– 

A 

A 

– 

A 

B 

A 

A 

– 

A 

A 

A 

A 

B 

A 

A 

A 

– 

A 

B 

A 

A 

B 

A 

A 

A 

A 

B 

A 

A 

A 

A 

Table  28:  Policy  options  for  buses  and  coaches  (M2&M3);  letters  indicate  mandatory 
introduction dates, dash indicates measure is not included in the policy option  

Measure 

Baseline 

PO1 (M2&M3) 

PO2 (M2&M3) 

PO3 (M2&M3) 

ALC 

DDR-DAD 

DDR-ADR 

ESS 

ISA-VOL 

REV 

TPM 

VIS-DET 

VIS-DIV 

– 

– 

– 

– 

– 

– 

– 

– 

– 

A 

– 

– 

A 

– 

– 

– 

– 

– 

A 

A 

– 

A 

A 

– 

– 

A 

C 

A 

A 

B 

A 

A 

A 

A 

A 

C 

148 The introduction dates for mandatory fitment are coded in the tables as follows: 

  A: 1st September 2021 (new approved types), 1st September 2023 (new vehicles) 
  B: 1st September 2023 (new approved types), 1st September 2025 (new vehicles) 
  C: 1st September 2025 (new approved types), no mandatory introduction for new vehicles 

99 

 
 
 
 
                                                 
Table 29: Policy options for vans (N1); letters indicate mandatory introduction dates149, 
dash indicates measure is not included in the policy option 

Measure 

Baseline 

PO1 (N1) 

PO2 (N1) 

PO3 (N1) 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

A 

– 

A 

– 

– 

A 

A 

– 

– 

– 

– 

A 

– 

– 

– 

A 

B 

A 

A 

– 

A 

A 

– 

– 

B 

– 

A 

– 

– 

– 

A 

B 

A 

A 

B 

A 

A 

A 

A 

B 

A 

A 

A 

A 

A 

Table  9:  Policy  options  for  trucks  (N2&N3);  letters  indicate  mandatory  introduction 
dates, dash indicates measure is not included in the policy option 

Measure 

Baseline 

PO1 (N2&N3) 

PO2 (N2&N3) 

PO3 (N2&N3) 

ALC 

DDR-DAD 

DDR-ADR 

ESS 

ISA-VOL 

REV 

TPM 

VIS-DET 

VIS-DIV 

– 

– 

– 

– 

– 

– 

– 

– 

– 

A 

– 

– 

A 

– 

– 

– 

– 

– 

A 

A 

– 

A 

A 

– 

– 

A 

C 

A 

A 

B 

A 

A 

A 

A 

A 

C 

149 The introduction dates for mandatory fitment are coded in the tables as follows: 

  A: 1st September 2021 (new approved types), 1st September 2023 (new vehicles) 
  B: 1st September 2023 (new approved types), 1st September 2025 (new vehicles) 
  C: 1st September 2025 (new approved types), no mandatory introduction for new vehicles 

100 

 
 
 
 
                                                 
Table  10:  Initial  cost  at  mandatory  introduction  of  policy  options  per  vehicle  (best 
estimate) inflated to year-2021 Euros 

Initial cost per vehicle 

Passenger cars (M1) 

Buses and coaches (M2&M3) 

Vans (N1) 

Trucks (N2&N3) 

PO1 

€201 

€6 

€131 

€6 

PO2 

€360 

€607 

€206 

€607 

PO3 

€516 

€970 

€521 

€1,013 

Key results: 
The benefit-to-cost ratios (BCRs) reported in Table 32 and Figure 23 allow a comparison of 
the different policy options based on the extent to which the benefits exceed (or fall short of) 
the costs created by a policy option over the entire evaluation period 2021–2037 compared to 
the baseline scenario (voluntary uptake). Values greater than 1 indicate that the benefits are 
greater than the costs incurred. 

For passenger cars (M1) and for buses and coaches (M2&M3), the results indicate that 
implementation of any of the policy options considered would be cost-effective. For vans 
(N1), implementation of PO1 or PO2 was found to be cost-effective. For trucks (N2&N3), 
PO2 and PO3 exceeded the threshold to cost-effectiveness. 

Table  32:  Results:  Benefit-to-cost  ratios  (BCRs)  of  policy  options  PO1,  PO2  and  PO3 
based  on  present  values  over  entire  evaluation  period  2021–2037  compared  to  the 
baseline scenario (best estimate) 

Benefit-to-cost ratios 

Passenger cars (M1) 

Buses and coaches (M2&M3) 

Vans (N1) 

Trucks (N2&N3) 

PO1 

2.95 

4.64 

1.78 

0.56 

PO2 

2.14 

3.11 

1.35 

1.52 

PO3 

1.39 

2.11 

0.53 

1.03 

101 

 
 
 
 
 
 
 
BCRs of policy options PO1, PO2, PO3 

PO1

PO2

PO3

6,0

5,0

4,0

3,0

2,0

1,0

0,0

M1

M2&M3

N1

N2&N3

Figure  23:  Results:  Benefit-to-cost  ratios  (BCRs)  of  policy  options  PO1,  PO2  and  PO3 
based  on  present  values  over  entire  evaluation  period  2021–2037  compared  to  the 
baseline  scenario  (best  estimate  with  indication  of  uncertainty  ranges  from  scenario 
analysis) 

The casualty prevention results reported in Table 33 and Figure 24 allow conclusions about 
which policy option prevents the highest number of fatalities across EU-28 when compared 
with the baseline scenario. To estimate the casualty prevention totals, the best estimate 
numbers for each year of the evaluation period 2021–2037 were summed. 

It can be observed for all vehicle categories that the number of casualties prevented by 
implementation of PO2 or PO3 exceeds the number prevented by PO1 by a considerable 
margin. Between all four vehicle categories, implementation of PO2 has the potential to 
prevent an additional 8,312 fatalities and 51,286 serious casualties compared to PO1 across 
EU-28 over the period 2021–2037. PO3 exceeds the potential of PO2 by further 1,843 
fatalities and 21,807 serious casualties. 

Table 33: Results: Total number of fatal casualties prevented by safety measures of the 
respective  vehicle  category  over  the  evaluation  period  2021–2037  compared  to  the 
baseline scenario (best estimate) 

Fatalities prevented 

Passenger cars (M1) 

Buses and coaches (M2&M3) 

Vans (N1) 

Trucks (N2&N3) 

PO2 

20,081 

207 

1,005 

1,658 

PO3 

21,337 

227 

1,283 

1,947 

PO1 

13,785 

2 

852 

0 

102 

 
 
 
 
Fatalities prevented per policy option  
(sum of all vehicle categories) 

24 974 

22 951 

14 639 

30 000

25 000

20 000

15 000

10 000

5 000

 0

PO1

PO2

PO3

Figure 24: Results: Total sum of fatal casualties prevented by safety measures across all 
vehicle categories over the evaluation period 2021–2037 across EU-28 compared to the 
baseline  scenario  (best  estimate  with  indication  of  uncertainty  ranges  from  scenario 
analysis) 

Implementation of the policy options would address the fatal casualty populations of vehicle 
occupants and vulnerable road users as detailed in  

Table 34. 

Table 34: Results: Overall percentage of all fatal vehicle occupant and vulnerable road 
user casualties prevented by the policy options over the evaluation period 2021–2037  

Reduction of fatal casualties  

Vehicle occupants 

Pedestrians & cyclists 

PO1 

PO2 

PO3 

Conclusions: 

12.7% 

15.4% 

16.0% 

11.6% 

14.0% 

14.4% 

From the results found in this cost-effectiveness study, it can be concluded overall that PO1 
offers favourable cost-effectiveness ratios in most vehicle categories; however, these are 
achieved with only a small impact on both the costs and the benefits compared to the baseline 
scenario of continued voluntary uptake. The impacts of PO2 and PO3 are larger, with 
numbers of fatalities prevented exceeding those of PO1 by a considerable margin; however 
this is accompanied by a greater cost. Where PO2 or PO3 exceed the threshold to cost-
effectiveness (BCR>1), the considerably greater number of casualties prevented compared to 
PO1 could be a reason to favour implementation of PO2 or PO3. 

103 

 
 
 
 
Introduction and objectives 

Annex 4.2
In 2015, the European Commission published the report conducted by TRL on the Benefit and 
Feasibility of a Range of new Technologies and Unregulated Measures in the Fields of 
Occupant Safety and Protection of Vulnerable Road Users  (‘GSR1’) (Hynd et al., 2015). 
This Report provided initial feasibility and cost vs. benefit reviews for over 50 new safety 
measures that could be implemented as part of the amendment to the General Safety and 
Pedestrian Safety Regulations. 

The follow-up report, In Depth Cost-Effectiveness Analysis of the Identified Measures and 
Features regarding the Way Forward for Vehicle Safety in the EU (‘GSR2’) (Seidl et al., 
2017), has been published in September 2017, and contains a thorough review and collation 
of the available evidence regarding effectiveness, cost, fleet penetration and target population, 
alongside the results of a large-scale stakeholder consultation for a shortlist of 24 safety 
measures. Preliminary cost-effectiveness indicators for the individual measures and additional 
technical considerations were reported to enable the European Commission to select the final 
list of proposed safety measures considered to be taken forward for mandatory 
implementation.  

The objective of this in-depth cost-benefit study is to build upon the outcomes of the GSR1 
and GSR2 projects and calculate concrete cost-effectiveness indicators and numbers of 
casualties prevented at a European level for three proposed sets of safety measures (policy 
options), taking into account: 

 

 
 

the interactions of all measures when implemented together (to avoid double-counting 
of casualties prevented by different measures), 
the baseline effects of voluntary uptake into the fleet, and 
the effects of already existing mandatory measures still dispersing into the fleet on the 
European casualty target populations. 

104 

 
 
 
 
Policy options and baseline scenario 

Annex 4.3
The European Commission defined, based on consideration of the initial cost-benefit 
indicators reported in GSR2 and additional information regarding technical feasibility 
received in the GSR2 stakeholder consultation, the list of proposed safety measures 
considered for implementation (Table 1). More detail about the measures is available in the 
GSR2 report (Seidl et al., 2017). Note that some measures have been split into two compared 
to the GSR2 report to allow more detailed modelling (DDR, FFW and VIS) and the 
description of some measures has evolved (HED-MGI: head-to-glass impact test; LKA-ELK: 
emergency lane keeping systems; REV: reversing camera).  

Table 35: List of safety measures considered for mandatory implementation 

Measure 

Description 

Applicable vehicle categories 

AEB-VEH 

Autonomous emergency braking for vehicles (moving and 
stationary targets) 

AEB-PCD 

Autonomous emergency braking for pedestrians and cyclists 

ALC 

Alcohol interlock installation document 

DDR-DAD 

Drowsiness and attention detection 

DDR-ADR 

Advanced distraction recognition 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

Event data recorder 

Emergency stop signal 

Full-width frontal occupant protection (current R137 
configuration with Hybrid III ATDs) 

Full-width frontal occupant protection (introduction of THOR-
M ATDs and lower appropriate injury criteria thresholds to 
encourage adaptive restraints) 

Adult head-to-windscreen impact (mandatory HIC limit in 
headform-to-glass impact tests; no mandatory A-pillar impact) 

Intelligent speed assistance (voluntary type system; can be 
overridden by driver and switched off for the rest of journey) 

Lane keeping assist (emergency lane keeping system that 
intervenes only in case of an imminent threat such as leaving 
the road, or leaving the lane with oncoming traffic) 

Pole side impact occupant protection 

Reversing camera system  

Tyre pressure monitoring system 

VIS-DET 

Front and side vulnerable road user detection and warning (no 
auto braking) 

VIS-DIV 

Minimum direct vision requirement (best-in-class approach) 

M2&M3 

M2&M3 

M2&M3 

M2&M3 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M2&M3 

M1 

M1 

M1 

M2&M3 

M2&M3 

M2&M3 

M2&M3 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

N2&N3 

This cost-effectiveness study also takes into account existing mandatory measures that are 
still dispersing into the fleet and thereby continue to contribute to casualty reductions; these 
will reduce the target populations for some of the proposed measures (see Table 2). 

105 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 36: List of existing mandatory safety measures which are modelled in this study 

Measure 

Description 

Applicable vehicle categories 

AEB-VEH 

Autonomous emergency braking for vehicles 

M2&M3 

M2&M3 

ESC 

Electronic stability control 

M1 

M2&M3 

N1 

M2&M3 

LDW 

Lane departure warning 

M2&M3 

M2&M3 

The European Commission has defined three policy options (POs), i.e. sets of safety 
measures from the above list to be implemented on a mandatory basis, for this cost-
effectiveness study to assess: 

  PO1: State-of-the-art and widely available package of safety solutions that are not yet 

mandatory in EU and their fitment varies from around 5–90% 

  PO2:  As  PO1  with  added  safety  solutions  that  focus  on  vulnerable  road  user 

protection and on ensuring driver attention to the driving task  

  PO3:  As  PO2  with  safety  solutions  that  are  either  feasible  or  already  exist  in  the 
marketplace,  but  that  have  a  low  fitment  rate  and  market  uptake,  that  maximises 
overall casualty savings and can boost safety solutions' innovation  

The sets of measures to be implemented in each policy option and the proposed introduction 
dates are shown in Table 37, Table 38, Table 39, and Table 40 for vehicle categories M1, 
M2&M3, N1, and N2&N3, respectively. 

The introduction dates for mandatory fitment are coded in the tables as follows: 

  A: 1st September 2021 (new approved types), 1st September 2023 (new vehicles) 
  B: 1st September 2023 (new approved types), 1st September 2025 (new vehicles) 
  C:  1st  September  2025  (new  approved  types),  no  mandatory  introduction  for  new 

vehicles  

The policy options are each studied for their cost-effectiveness compared to a baseline 
scenario (PO0), where none of the measures are implemented on a mandatory basis, but 
voluntary uptake would continue. The reported cost-effectiveness results reflect a comparison 
between each policy option with the baseline, i.e. capture only the costs and benefits that 
exceed those estimated for the voluntary fitment scenario.  

The evaluation period was chosen to extend to 2037 in order to capture the effects of 
dispersion of the measures into the vehicle fleet via fitment to new vehicles. Results are 
calculated for individual years, converted to present values and summed for the evaluation 
period extending from 2021 to 2037. 

The following tables provide information on which of the safety measures are introduced 
under each policy option by vehicle type.  

106 

 
 
 
 
 
 
 
Table 37: Policy options 1, 2 and 3 for passenger cars (M1); letters indicate mandatory 
introduction dates (see key above), dash indicates measure is not included in the policy 
option 

Measure 

Baseline 

PO1 (M1) 

PO2 (M1) 

PO3 (M1) 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

A 

– 

A 

– 

– 

A 

A 

A 

– 

– 

– 

A 

A 

– 

A 

B 

A 

A 

– 

A 

A 

A 

A 

B 

A 

A 

A 

– 

A 

B 

A 

A 

B 

A 

A 

A 

A 

B 

A 

A 

A 

A 

Table  38:  Policy  options  1,  2  and  3  for  buses  and  coaches  (M2&M3);  letters  indicate 
mandatory introduction dates (see key above), dash indicates measure is not included in 
the policy option 

Measure 

Baseline 

PO1 (M2&M3) 

PO2 (M2&M3) 

PO3 (M2&M3) 

ALC 

DDR-DAD 

DDR-ADR 

ESS 

ISA-VOL 

REV 

TPM 

VIS-DET 

VIS-DIV 

– 

– 

– 

– 

– 

– 

– 

– 

– 

A 

A 

– 

A 

A 

– 

– 

A 

C 

A 

A 

B 

A 

A 

A 

A 

A 

C 

A 

– 

– 

A 

– 

– 

– 

– 

– 

107 

 
 
 
 
Table  39:  Policy  options  1,  2  and  3  for  vans  (N1);  letters  indicate  mandatory 
introduction dates (see key above), dash indicates measure is not included in the policy 
option 

Measure 

Baseline 

PO1 (N1) 

PO2 (N1) 

PO3 (N1) 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

A 

– 

A 

– 

– 

A 

A 

– 

– 

– 

– 

A 

– 

– 

– 

A 

B 

A 

A 

– 

A 

A 

– 

– 

B 

– 

A 

– 

– 

– 

A 

B 

A 

A 

B 

A 

A 

A 

A 

B 

A 

A 

A 

A 

A 

Table  40:  Policy  options  1,  2  and  3  for  trucks  (N2&N3);  letters  indicate  mandatory 
introduction dates (see key above), dash indicates measure is not included in the policy 
option 

Measure 

Baseline 

PO1 (N2&N3) 

PO2 (N2&N3) 

PO3 (N2&N3) 

ALC 

DDR-DAD 

DDR-ADR 

ESS 

ISA-VOL 

REV 

TPM 

VIS-DET 

VIS-DIV 

– 

– 

– 

– 

– 

– 

– 

– 

– 

A 

A 

– 

A 

A 

– 

– 

A 

C 

A 

A 

B 

A 

A 

A 

A 

A 

C 

A 

– 

– 

A 

– 

– 

– 

– 

– 

108 

 
 
 
 
Some measures considered in GSR2 (Seidl et al., 2017) will not be taken forward for 
mandatory implementation, following negative initial cost-benefit results or based on 
concerns regarding technical feasibility: 

  FSO for M1: Small overlap frontal occupant protection, based on likely unfavourable 

cost-effectiveness after introduction of relevant active safety measures. 

  SFS for M1 and N1: Side impact collision protection for far-side occupants, based on 
technical  concerns  raised  by  stakeholders  indicating  that  no  design  solutions  were 
proven to be effective and no suitable ATD existed for far-side impact tests. 

Note that the European Commission considers removing exemptions of certain vehicle 
categories or weights related to the following measures: 

  F94  for  M1  and  N1:  UN  Regulation  No.  94  Frontal    Offset  Occupant  Protection  – 

Removal of Exemptions 

  S95  for  M1  and  N1:  UN  Regulation  No.  95  Side  Impact  Occupant  Protection  – 

Removal of Exemptions 

These removals of exemptions are not covered in this cost-benefit study.  

109 

 
 
 
Annex 4.4

Methodology and input parameters 

Annex 4.4.1 
Overview: Calculation model structure 
A simulation and calculation model was developed to estimate the benefits (monetary values 
of casualties prevented by safety measures) and costs (cost to vehicle manufacturers of 
fitment of safety measures to new vehicles) associated with the policy options PO1, PO2 and 
PO3 compared to the baseline scenario. The model was implemented in the programming 
language Python150 with inputs and outputs produced in Microsoft Excel spreadsheets. Figure 
25 presents a simplified visualisation of the structure and calculation steps of the model. A 
brief description of the steps is given in the following paragraphs and a detailed description in 
Annex 4.4.2 to Annex 4.4.14. 

150 https://www.python.org/ 

110 

 
 
 
                                                 
Figure 25: Flowchart of the simulation model to calculate benefit-to-cost ratios (BCRs) 
for policy options PO1, PO2 and PO3, respectively, compared to the baseline scenario 

The vehicle fleet calculation model determines how the safety measures disperse into the 
fleet. The model determines the effect of mandating a measure for all new types, and two 
years later for all new registered vehicles, on the overall proportion of the fleet equipped. 
Benefits conferred by a safety measure, that is, casualties prevented, will only be realised by 
equipped vehicles. However, the legacy fleet will also be affected by active safety measures; 
for example, if a rear-end shunt is avoided by AEB-VEH, the vehicle in front, will benefit 
from the measure even if it is a legacy vehicle. This is taken into account in the benefit 
calculations. 

To simulate the casualties prevented by each measure, an accident data analysis was 
performed based on GB national road accident data (Stats19) to determine the casualty target 
population for each proposed measure, i.e. the number of fatal, serious and slight casualties 

111 

 
 
that could potentially be affected by a safety measure based on relevant characteristics of the 
collision (e.g., collision geometry or contributory factors). The target populations were scaled 
to EU-28 level using weighting factors, based on severity and vehicle categories involved, 
derived from analysis of the pan-European CARE database. The target populations found are 
multiplied with effectiveness values for each safety measure, i.e., a percentage value 
indicating what proportion of the relevant accidents will be avoided or mitigated by the 
measure. Mitigated casualties (fatal turned to serious casualty, or serious to slight casualty) 
are added to the target population of the next lower injury severity level for other measures. 
The casualties prevented are multiplied with monetary values for casualty prevention to 
calculate the monetary benefit. 

An added complication that had to be addressed is the interaction of different safety measures, 
which address overlapping casualty groups. To give an example, there are collisions where a 
driver was exceeding the speed limit, left the lane and suffered a frontal impact. These 
collisions will be in the target populations for multiple measures: ISA, LKA-ELK and FFW-
137/FFW-THO, but in reality can only be prevented once by either one of these systems. This 
is addressed in the model by removing casualties prevented by one measure from the 
subsequent target population of the other measures. The impact of highly effective existing 
safety measures, which have been mandatory for a few years, but are still dispersing into the 
vehicle fleet (ESC for all vehicle categories, and AEB-VEH and LDW for M2&M3 and 
N2&N3), is also modelled to reduce the remaining target populations for the proposed 
measures. 

The cost of a policy option is calculated by multiplying per-vehicle cost estimates for each 
measure with the number of new vehicles of each vehicle category across EU-28 that are 
equipped with the measure in the given year of the analysis according to the output of the fleet 
calculation model. All calculations are run separately for PO1, PO2, PO3, and for the baseline 
scenario, which assumes that none of the proposed measures will be mandated, so all the 
benefits and costs in the baseline scenario result from voluntary uptake of the safety measures. 
The results for the baseline scenario are subtracted from the results of each policy option, in 
order to only capture the benefits and costs of the legislative intervention which exceed the 
voluntary uptake.  

In the economic calculation model, the monetary values of costs and benefits are subjected to 
inflation and discounting to determine their present value. The present values of benefits and 
costs, calculated for individual years and summed over the evaluation period, are compared in 
order to arrive at cost-effectiveness estimates (benefit-to-cost ratio, BCR). Individual BCRs 
are calculated per policy option (PO1, PO2, PO3) and per vehicle category (M1, M2&M3, 
N1, N2&N3). A total of 12 different best estimate BCRs is reported. In addition to the 
calculations using the best estimate values for all input parameters, an interval and a scenario 
analysis is carried out to quantify the range of uncertainty around the best estimate BCR 
values.  

The following sub-sections describe in more detail the individual aspects of the model and the 
input data used. 

112 

 
Evaluation period  

Annex 4.4.2 
To model the costs and benefits of the safety measures fully, it was necessary to set an 
evaluation window which allowed technology sufficient time to propagate through the vehicle 
fleet and into the collision population. This was set by considering the earliest time at which a 
measure could affect all new vehicles (year 2023, 2 years after introduction for new approved 
types); then an allowance was added for the age of the traffic population (mileage 
contribution to total miles driven is not constant over the vehicle age). Previous evidence, 
established for the car fleet in London, has demonstrated that about 88% of the traffic is 0 to 
11 years old and 97% of the traffic is 0 to 14 years old. Vehicles which are 15 years old 
account for about only 1% of the traffic and about 2% of the collision involved cars. 
Therefore, 14 years was added to new vehicle implementation date to allow the full cycle of 
fleet benefits to be captured. This period also matches the length of time allocated for the 
majority of voluntary uptake measures to reach close-to-full adoption levels. As such, the 
evaluation period was set to extend from 2021 to 2037. 

Casualty baseline 

Annex 4.4.3 
The EU-28 casualty baseline is an important factor for the model because it determines the 
size of the overall casualty target population for all safety measures over the time period 
assessed. The casualty baseline (policy option PO0) is also the basis against which the costs 
and benefits of the other policy options (PO1, PO2 and PO3) are compared. 

Historically, road casualty numbers of all severity levels (fatal, serious and slight) in Europe 
have declined continuously over the past decades up until 2013. In the years following 2013, 
a slight increase or plateauing of the numbers can be observed (Figure 26). 

113 

 
 
 
 
60.000

50.000

40.000

30.000

20.000

10.000

8
2
-
U
E
s
e
i
t
l
a
u
s
a
c

l

a
t
a
F

0
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Figure  26:  Historic  road  fatality  trend  EU-28151,  highlighted  period  2013–2016  with 
plateauing trend  

The reasons for the long-term decline can be attributed to advancements in vehicle safety 
technology (driven by regulation, consumer information programmes such as Euro NCAP, 
vehicle manufacturers’ research and development efforts, and independent vehicle safety 
research), as well as certain other major factors, including improvements to the road and 
cycling infrastructure, improvements in post-collision medical care, and behavioural changes 
of drivers due to awareness campaigns and cultural shifts (e.g. seat belt wearing rates, drink-
driving behaviour, and speeding behaviour).  

It was not possible within the scope of this study to attribute fractions of the overall trend to 
these aspects and there is no conclusive study that shows why the casualty reductions have 
slowed over the past five years. The European Commission, therefore, provided estimates of 
the continued effects in all non-vehicle-related sectors (general road casualty trend), and the 
vehicle-related baseline effects were calculated using the model developed for this study to 
arrive at the casualty baseline. The basic assumption to define the general road casualty trend 
and the casualty baseline was that no further policy intervention would take place in the 
transport sector, but voluntary improvements and effects of already implemented policies 
would continue.  

The European Commission’s best estimate provided for the general casualty trend was a 
constant casualty number at all severity levels from 2016 onward. This shows that the 
continued effects in all non-vehicle sectors are expected to offset the increase in traffic 
volume but not be strong enough to result in a net casualty reduction. The calculations to 
arrive at the casualty baseline were performed based on this general casualty trend and using 

151 https://ec.europa.eu/transport/road_safety/specialist/statistics_en  

114 

 
 
 
                                                 
 
 
 
input values and calculation methods as described in the subsequent sections of this report. 
The resulting casualty baseline reflects the effects of continued dispersion of existing 
mandatory vehicle safety measures with new vehicles into the legacy fleet and continued 
voluntary uptake of the safety measures under consideration (see Figure 27 for fatal 
casualties, and Annex 4.9.1 for other severity levels).  

Historic numbers

Policy target

Fatal casualty baseline

8
2
-
U
E
s
e
i
t
l
a
u
s
a
c

l

a
t
a
F

60.000

50.000

40.000

30.000

20.000

10.000

0

1
0
0
2

3
0
0
2

5
0
0
2

7
0
0
2

9
0
0
2

1
1
0
2

3
1
0
2

5
1
0
2

7
1
0
2

9
1
0
2

1
2
0
2

3
2
0
2

5
2
0
2

7
2
0
2

9
2
0
2

1
3
0
2

3
3
0
2

5
3
0
2

7
3
0
2

Figure  27:  EU-28  fatal  casualty  baseline  (2017–2037),  historic  fatality  numbers  (2001–
2016), and indication of a potential continuation of the EU policy target (2011–2037) 

Note that European member states have recently agreed on a new common definition of 
‘serious traffic injury’ casualty, based on MAIS injury severity (MAIS3+ injuries). This is a 
more stringent definition than that applied in CARE (most member states report serious 
casualties as those where the casualty was treated as an in-patient in hospital). According to 
the new definition there are about 5.3 serious casualties per fatality, whereas the CARE 
definition captures 8.9 serious casualties per fatality. No historic numbers are available for 
MAIS3+ casualties across Europe and the published monetary values assigned for prevention 
of a serious casualty are more closely related to the CARE definition. Therefore, all 
calculations in this study are based on serious casualties as defined and captured in the CARE 
database. 

In order to treat the inherent uncertainty in the forward projection of the general road casualty 
trend, the input numbers for fatal, serious and slight casualties were varied, along with other 
inputs, as part of the sensitivity analysis (see Annex 4.4.14). The European Commission’s 
lower estimate provided was a situation where the general casualty trend (at all severity 
levels) would continue at the rate of fatality reduction observed within the last three years 
(2014–2016). This is a continuous 0.7% reduction relative to the previous year.  

115 

 
 
 
 
 
 
 
Refer to Annex 4.8.1 for the general casualty trend estimates and Annex 4.9.1 for the resulting 
casualty baseline. 

Annex 4.4.4 
Two series of data regarding the vehicle fleet were required to provide a dynamic estimate of 
the total benefits and costs: 

Vehicle fleet size 

1.  The total fleet size each year for the period of interest; with values separated to show 

the different vehicle categories. 

2.  The number of new vehicles registered each year in Europe, again broken down to the 

level of vehicle categories. 

The European Commission provided input numbers for both series of data, created using the 
PRIMES-TREMOVE transport model152 (Table 41 and Table 42). 

Table  41:  EU-28  total  vehicle  fleet  size  (in  thousand  vehicles);  Source:  PRIMES-
TREMOVE transport model (updated EU Reference scenario 2016) 

2010 

2015 

2020 

2025 

2030 

2035 

2040 

Passenger cars (M1) 

240,841.6 

263,530.3 

276,929.5 

283,672.9 

288,125.2 

300,708.2 

311,068.5 

Buses and coaches 
(M2&M3) 

818.9 

905.8 

980.8 

1,018.3 

1,039.0 

1,070.8 

1,107.7 

Vans (N1) 

27,979.6 

29,645.6 

30,945.4 

32,230.3 

33,944.6 

35,871.5 

37,395.6 

Trucks (N2&N3) 

5,876.1 

7,006.8 

7,842.9 

8,451.2 

8,888.6 

9,448.6 

9,965.7 

Table 42: EU-28 new vehicle registrations (in thousand vehicles, aggregated over 5 years 
leading  up  to  the  year  referenced);  Source:  PRIMES-TREMOVE  transport  model 
(updated EU Reference scenario 2016) 

2010 

2015 

2020 

2025 

2030 

2035 

2040 

Passenger cars (M1) 

110,716.6 

75,137.2 

90,611.3 

99,106.8 

104,355.5 

107,329.5 

109,279.0 

Buses and coaches 
(M2&M3) 

381.5 

309.1 

319.0 

343.2 

364.7 

357.7 

369.6 

Vans (N1) 

10,924.9 

9,810.9 

10,781.0 

11,931.7 

12,325.1 

12,638.4 

13,171.2 

Trucks (N2&N3) 

2,482.9 

2,559.3 

2,471.6 

2,755.6 

2,943.3 

3,155.9 

3,161.5 

152 

http://www.e3mlab.ntua.gr/e3mlab/PRIMES%2520Manual/The%2520PRIMES-

TREMOVE%2520MODEL%25202013-2014.pdf  

116 

 
 
 
 
 
 
 
                                                 
The new registration data was aggregated in 5-year blocks and had to be split into individual 
years for this study. The middle year of each block was assigned the mean value and a slanted 
line was created through that value connecting each 5 year block to the next, thus avoiding to 
show implausible step changes every five years while obtaining the same total number. 

An example of this is shown in Figure 28. In this case, the total fleet values are plotted with 
respect to the left axis and the new registration values with respect to the right. Refer to 
Annex 4.8.3 for data on other vehicle categories. 

Figure 28: Passenger car (M1) fleet and new registrations 2011 to 2037  

Note that the size of the fleet for the subset of M2/M3 vehicles with an extra-urban use mode 
(i.e. not city transport) was not available directly from the PRIMES-TREMOVE data. It was 
estimated using a single ratio of the M2/M3 values, which was derived from the number of 
vehicles in use in Europe, according to ‘Eurostat’ data (European Commission, 2017) and was 
set to be 37 % (for extra-urban type M2/M3 vehicles) for all years. 

Annex 4.4.5 
There are two aspects to the fleet fitment estimates which are vital to the process of 
establishing the cost-effectiveness for the measures within these policy options. 

Fleet dispersion of safety measures 

1.  The  voluntary  uptake  which  defines  a  ‘do  nothing’  scenario.  In  this  case,  the 
propagation  of  technology  is  led  by  the  willingness  of  manufacturers  to  fit  the 
necessary components to vehicles and the willingness of consumers to pay for them. 
2.  The mandatory uptake brought about by a policy intervention. In this case, all vehicles 
or  all  vehicle  types  will  be  required  to  meet  the  regulatory  requirements  by  an 

117 

 
 
 
 
 
implementation date. The effects of this will be superimposed on the baseline fitment 
rates at that moment in time. 

To model the uptake of technology alongside each of the measures, it was necessary to define 
the uptake by new vehicles and also the penetration into the fleet due to fleet expansion and 
‘churn’ (the rolling addition of new vehicles and scrappage of old). The numbers of vehicles 
being registered newly each year and the numbers in the fleet were already determined, as per 
the previous section. This section describes the way in which the model accounted for 
technology propagation on a voluntary or mandatory basis. The model accounts for the fact 
that some of the vehicles being scrapped in the churn process would also have the technology 
fitted. Otherwise, an overly optimistic estimate of technology penetration would be generated. 

Voluntary fleet fitment estimates were based on evidence identified previously (Seidl et al., 
2017), comments provided by stakeholders and, in the absence of other information, opinions 
of an expert panel within TRL based on observations of similar technologies and expectations 
of pressures on the industry (for instance, whether a measure is likely to be incentivised by 
Euro NCAP). 

The launch date for a technology was used to define the x-axis (time) start point for s-shaped 
curves of fitment. This relates to the first time a system was released with the characteristics 
likely to be required in order to meet the regulatory requirements. As a general rule, the 
launch date was intended to be independent of vehicle category; assuming general transfer of 
technologies was possible, with some exceptions. The assumed launch dates and notes about 
supporting observations are provided in Table 63. 

The year that full voluntary implementation is achieved dictates the gradient or slope of the s-
shaped curve and represents the time necessary for the measure to reach maturity in terms of 
full voluntary adoption into new vehicle registrations. All but three measures were predicted 
to have a long voluntary implementation phase, with 14 years between launch of the 
technology and full voluntary implementation. However, ESC was given a shorter adoption 
window of only 10 years to match a medium length period. For car fitment Event Data 
Recorders (EDR) and Full-width frontal protection for UN Regulation No. 137 with the 
Hybrid III dummy (FFW-137) were given an even shorter voluntary uptake period of 6  years. 
This was justified based on the percentage of vehicles in the fleet already expected to meet the 
regulatory requirements for the system, which matches the predicted final voluntary uptake 
levels. A medium and a long length adoption period were used for van and heavier vehicle 
uptake of EDRs, respectively. The full voluntary implementation years for the various 
measures are provided in Table 64.  

The voluntary take up of technology and the implementation within the fleet was selected to 
be one of three possible options: 

118 

 
1.  None = No voluntary uptake, regulatory action required to drive adoption 
2.  Medium = 40% voluntary propagation within the fleet without additional stimuli 
3.  High  =  80%  voluntary  propagation  leaving  the  20%  of  vehicles  which  wouldn’t  be 

equipped without regulatory action 

These values represent point estimates for the resulting final take up in the fleet. The s-shaped 
curve for percentage of newly registered cars equipped is modelled to form a plateau at this 
value. The assignments of these uptake levels to the different measures and vehicle categories 
are shown in Table 65 in Annex 4.8.4. 

Examples of model outputs for measure uptake and fleet dispersion of AEB-PCD in cars are 
shown in Figure 21, Figure 22 (voluntary uptake scenario, PO0) and Figure 23, Figure 24 
(mandatory uptake scenario, PO3). In the voluntary uptake scenario it can be seen that this 
high-uptake measure levels off at approximately 80% fleet fitment by the end of the 
evaluation period (Figure 22). The mandatory uptake scenario follows the voluntary uptake 
curve up until 2023 and elevates the new vehicle fitment rates from then onward gradually 
over two years to 100% (Figure 23). Even with full fitment in new vehicles, it still takes time 
for those vehicles to replace existing vehicles on the road, but the effect of regulation can be 
seen in the resulting higher fleet fitment of more than 90% by the end of the study period 
(Figure 24). The difference between these curves is responsible for the casualties prevented of 
a policy option compared to the baseline option.  

Figure  21:  Percentage  of  newly  registered 
cars  equipped  with  pedestrian-capable 
AEB in voluntary uptake scenario 

Figure 22: Percentage of all cars within the 
vehicle  fleet  equipped  with  pedestrian-
capable AEB in voluntary uptake scenario 

119 

 
 
 
 
Figure  23:  Percentage  of  newly  registered 
cars  equipped  with  pedestrian-capable 
AEB 
implementation 
scenario  (new  approved  types  from  2023, 
all new cars from 2025) 

in  mandatory 

Figure 24: Percentage of all cars within the 
vehicle  fleet  equipped  with  pedestrian-
capable 
mandatory 
implementation  scenario  (new  approved 
types from 2023, all new cars from 2025) 

AEB 

in 

In order to treat the inherent uncertainty in these voluntary uptake predictions, the input 
numbers were varied, along with other inputs, as part of the sensitivity analysis (see Annex 
4.4.14). A lower estimate of the voluntary uptake was modelled to represent a scenario where 
voluntary uptake of the voluntary measures reaches only half the percentages quoted above.  

Target population estimates 

Annex 4.4.6 
An accident data analysis was performed to estimate the size of the casualty target population, 
i.e. the number of fatal, serious and slight casualties that could potentially be affected by a 
safety measure based on suitable characteristics of the collision, for each of the proposed and 
existing safety measures.  

Accident data was extracted from the Stats19 database153 for the years 2011–2015 (last 
available year at the time of the study) and average numbers of this period were used to arrive 
at per annum estimates. Rollover collisions and collisions with more than two vehicles 
involved were excluded from the analysis because the police-reported data does not allow 
determination of which was the most severe event (injury causation) and therefore it is not 
clear which safety measures would apply to these collisions. Note that the calculation model 
corrects for the fact that the vehicle fleet was part-fitted with some of the measures under 
consideration at the time the accident data sample was drawn (e.g. ESC). The calculations 
approximate the accident data fleet fitment to be the average fleet dispersion calculated for the 

153 Stats19 is Great Britain’s database that records police reported traffic accidents that result in injury to at least 
one person. The database primarily records information on where the accident took place, when the accident 
occurred, the conditions at the time and location of the accident, details of the vehicles involved, the first 
point of impact, contributory factors to the accident, and information about the casualties. Approximately 50 
pieces of information are collected for each accident. 

120 

 
 
 
 
 
                                                 
years 2011–2015 using the model described in Annex 4.4.5. The casualty saving effects are 
calculated as a reduction resulting from the relative increase in fleet fitment starting from the 
2011–2015 level rather than absolute fleet fitment rate. 

The data extract queries for each measure were phrased to match descriptions from the 
effectiveness studies used (see Annex 4.4.7). Correction factors (multipliers) were applied to 
the target population estimates: 

  Where the Stats19 data did not offer the necessary level of detail to arrive at a suitable 
target  population.  For  example,  for  FFW-137,  the  police-reported  data  allowed  to 
determine  the  number  of  casualties  in  all  frontal  impacts  and  a  correction  factor 
smaller than one from in-depth studies was applied to represent only the fraction that 
was in a large overlap (full-width) frontal collision. This reduced the target population 
for some measures. 

  Where it was known that any relevant collision circumstances or contributory factors 
are  systematically  underreported  in  the  police-reported  statistics  (e.g.  ‘exceeding  the 
speed limit’). This increased the target population for some measures. 

  Where  data  from  additional  European  countries  regarding  target  populations  for  the 
specific measures considered was available, in order to represent the average situation 
in  the  countries  available.  This  was,  for  example  the  case  for  measures  HED-MGI, 
ISA-VOL,  REV,  VIS-DET  and  VIS-DIV.  This  increased  or  decreased  the  target 
populations for the relevant measures. 

Refer to Annex 4.8.5 for an overview of target population descriptions and correction factors 
applied for each measure. 

The target populations found were disaggregated by vehicle categories involved for (vehicle 1 
and vehicle 2 or vulnerable road user), and first point of impact (e.g. N2N3 front to M1 off-
side) to allow detailed modelling of the overlaps in target populations between measures (see 
Annex 4.4.8) and scaling to the European casualty population in the relevant vehicle 
combinations. This resulted in approximately 400 collision configurations and the target 
populations were converted into percentages of the total casualties in each of these 
configurations. 

These target population percentages were scaled up to EU-28 to greatest level of detail 
possible from the data fields available within the pan-European CARE database154. The 
scaling was based on the average European casualty distribution for fatal, serious and slight 
casualties in the years 2011 to 2015 in collisions where the relevant vehicle categories 
collided (see Table 43). This means, the scaling was carried out so that it is representative of 
the European proportions of casualties in M1-to-M1, M1-to-N1, N1-to-M2M3, etc. collisions. 
Information regarding the first point of impact (front, off-side, near-side, rear) is not available 

154 CARE is the community database on road accidents resulting in death or injury in the 28 European member 

states. https://ec.europa.eu/transport/road_safety/specialist/statistics_en#  

121 

 
                                                 
at a pan-European level155. Therefore, the UK was chosen to apportion the geometric 
configurations within the vehicle category combinations (based on Stats19 data). 

The target populations for each year were scaled proportionally to match the total casualty 
population for fatal, serious and slight casualties in the given year according to the general 
road casualty trend (see Annex 4.4.3). 

Table  43:  Total  casualty  population  and  collision  numbers  across  EU-28  per  annum 
(average of period 2011 to 2015) in the relevant vehicle category combinations. Source: 
CARE database 

Vehicle category 

Collisions 

Casualties (Vehicle 1) 

Casualties (Vehicle 2) 

Vehicle 1 

Vehicle 2 

Fatal 

Serious 

Slight 

Fatal 

Serious 

Slight 

M1 

M2M3 

N1 

N2N3 

PTW 

Cyclist 

Other 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M2M3 

M2M3 

M2M3 

M2M3 

M2M3 

M2M3 

M2M3 

N1 

N1 

N1 

N1 

N1 

none 

none 

none 

none 

none 

none 

none 

M1 

M2M3 

N1 

N2N3 

PTW 

Pedestrian 

Cyclist 

Other 

M2M3 

N1 

N2N3 

PTW 

Pedestrian 

Cyclist 

Other 

N1 

N2N3 

PTW 

Pedestrian 

Cyclist 

127,635 

5,405 

33,198 

129,912 

5,313 

7,475 

4,456 

52,552 

25,686 

4,301 

50 

338 

222 

818 

1,687 

1,209 

6,625 

7,305 

3,578 

1,667 

16,652 

38,205 

335 

317 

7,662 

1,560 

17,848 

3,239 

252,173 

2,900 

37,283 

367,874 

8,986 

32,931 

23,967 

130,523 

109,876 

103,824 

194 

552 

1,456 

35 

17 

7 

808 

3,720 

4,583 

731 

206 

123 

13,203 

331 

1,469 

117 

755 

488 

1,410 

4,260 

1,654 

472 

2,313 

2,112 

10,374 

7,685 

7,051 

2 

6 

27 

1 

0 

0 

4 

57 

139 

1 

2 

1 

605 

75 

121 

11 

48 

26 

56 

413 

492 

33 

9 

6 

5,254 

30,590 

22,809 

8,797 

1,980 

1,581 

9,247 

9,317 

1,005 

1,077 

191 

637 

332 

500 

2,997 

1,684 

346 

100 

82 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

13 

111 

35 

1,939 

3,600 

1,005 

114 

n/a 

12 

3 

52 

184 

49 

7 

n/a 

13 

271 

463 

164 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

580 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

8,823 

1,320 

13,459 

483 

3,522 

30,768 

106,274 

27,549 

83,758 

16,833 

86,001 

1,246 

5,628 

n/a 

55 

27 

323 

972 

288 

43 

n/a 

75 

2,435 

1,832 

1,321 

n/a 

325 

101 

1,060 

2,975 

1,173 

150 

n/a 

430 

8,230 

6,102 

5,572 

155 First point of impact in CARE is only reported by two member states (UK and Denmark) on a regular basis, 

as well as sporadically by Luxembourg (2013–2015) and France (2015 only). 

122 

 
 
                                                 
Vehicle category 

Collisions 

Casualties (Vehicle 1) 

Casualties (Vehicle 2) 

Vehicle 1 

Vehicle 2 

Fatal 

Serious 

Slight 

Fatal 

Serious 

Slight 

N1 

N2N3 

N2N3 

N2N3 

N2N3 

N2N3 

PTW 

PTW 

PTW 

PTW 

Other 

N2N3 

PTW 

Pedestrian 

Cyclist 

Other 

PTW 

Pedestrian 

Cyclist 

Other 

Pedestrian 

Cyclist 

Pedestrian 

Other 

Cyclist 

Cyclist 

Cyclist 

Other 

1,190 

1,688 

3,422 

3,188 

3,790 

716 

9,683 

8,953 

4,550 

3,477 

7,628 

5,846 

6,799 

2,685 

30 

138 

1 

2 

1 

15 

175 

25 

14 

136 

24 

291 

71 

78 

115 

629 

12 

7 

4 

71 

2,386 

452 

425 

893 

966 

1,377 

1,896 

547 

586 

2,019 

90 

73 

60 

277 

8,738 

3,211 

2,125 

2,214 

4,772 

4,193 

7,776 

1,974 

Multi vehicle (any) 

109,959 

3,865 

26,459 

159,204 

25 

n/a 

188 

438 

218 

32 

n/a 

202 

52 

2 

8 

5 

n/a 

1 

n/a 

180 

n/a 

901 

812 

808 

121 

n/a 

1,559 

777 

128 

577 

50 

n/a 

39 

n/a 

655 

n/a 

1,923 

1,486 

2,246 

512 

n/a 

5,769 

2,919 

489 

3,018 

245 

n/a 

170 

n/a 

Safety measure effectiveness 

Annex 4.4.7 
The casualty target populations are multiplied with effectiveness values for each safety 
measure, i.e. a percentage value indicating what proportion of the relevant collisions will be 
avoided or mitigated by the measure.  

‘Avoidance’ describes a situation where casualties would remain entirely uninjured after 
application of the effective safety measure, for example, because the collision is prevented by 
an active safety system. ‘Mitigation’ describes a situation where casualties would sustain 
injuries of a lower severity level (fatal turned to serious casualty, or serious to slight casualty), 
for example, because an effective passive safety measure prevents the most severe injuries, or 
an active safety measure reduces the impact speed. Measures have been assigned separate 
values for effectiveness of avoidance and mitigation at all injury severity levels. It should be 
noted that effectiveness values for avoidance and mitigation are additive in this model. 
‘Mitigated’ casualties are subsequently added to the target population of the next lower injury 
severity level for other measures. 

Note that casualties prevented are attributed to the vehicle category equipped with the 
effective safety measure, which is not always identical with the vehicle category occupied by 
the casualty. To give an example, if a head-on collision involving a van (N1) and a car (M1) 
where the van drifted out of the lane and the drivers of both vehicles were fatally injured was 
prevented by LKA-ELK fitted to the van, then both fatalities prevented would be counted as 
benefit of LKA-ELK in the N1 category. 

The effectiveness best estimates were based on the values determined by (Seidl et al., 2017) 
in preparation of this study (extracted from research studies and stakeholder input). Where no 

123 

 
 
 
values could be identified during the course of this review and where no stakeholder input 
was provided, a road safety expert panel at TRL determined best estimates from the available 
evidence.     

Refer to Annex 4.8.6 for the relevant effectiveness values, sources and rationale for expert 
panel estimates. Note that effectiveness values should always be interpreted in conjunction 
with the target population definition applied. Effectiveness can appear high when the target 
population definition is already very narrow and vice versa. For example, HED-MGI shows a 
high effectiveness percentage, however this applies only to the already narrow target 
population of ‘pedestrian and cyclist casualties in impacts with the vehicle front who suffered 
serious head injuries from impact with the glazed area of the windscreen more than 10 
centimetres away from the scuttle, A-pillars, and header rail’. 

For the interval and scenario analysis (see Annex 4.4.14), effectiveness values were assigned 
a confidence level (high or low depending on the quality of the source) and the best estimates 
were varied as follows in order to determine the upper and lower estimates: 

  Plus/minus 10% for high confidence estimates (for example, a value of 40% would be 

varied ±4 percentage points, i.e. 36% to 44%) 
  Plus/minus 20% for low confidence estimates. 

Avoidance of double-counting of casualties prevented 

Annex 4.4.8 
When considering all proposed safety measures separately, the number of prevented 
casualties would be overestimated, because the target populations for different measures are 
partially overlapping, but each casualty can only be prevented once. To give an example, 
there will be collisions where a driver was exceeding the speed limit, left the lane and suffered 
a frontal impact. This collision will be in the target population for ISA, LKA-ELK and FFW-
137/FFW-THO, but in reality can only be prevented once by either one of these systems. This 
is addressed in the model by removing casualties prevented by one measure from the 
subsequent target population of the other measures. 

To achieve this, the proposed and existing safety measures were organised in groups that 
allow to take into account their interactions, to the level of detail which can realistically be 
expected, when all or a subset of measures are implemented. The measures are organised in 
‘clusters’, which are based on the vehicle categories on which the measures are implemented 
(i.e. where the development effort and costs are accrued; and for most measures also where 
the benefit arises). Within each cluster, the measures are further organised in three ‘layers’, 
based on the phase in which they protect: 

  Driver Assistance (permanent/ongoing collision mitigation) 
  Active Safety (mitigation immediately pre-collision) 
  Passive Safety (protection during collision) 

The general structure for modelling the interactions between measures in this study is 
visualised in Figure 33. The initial target population for the calculations includes all EU-28 
road casualties. Each ‘layer’ will prevent some of the casualties and thus reduce the target 
population for the next layer. The interactions/overlaps within each layer are expected to be 
limited because the safety systems address distinct collision causes or configurations. The 

124 

 
reductions in target populations for subsequent layers are carried through for each of the over 
400 collision configurations to realise a high level of accuracy. Note that ‘mitigated’ 
casualties (fatal turned to serious casualty, or serious to slight casualty) are added to the target 
population of the next lower injury severity level for other measures. 

Figure  33:  Modelling  interactions  of  safety  measures  based  on  layers  of  protection 
(driver assistance, active safety, passive safety) 

Refer to Annex 4.8.2 for the organisation of the proposed and existing safety measures in 
layers for M1, N1, M2&M3 and N2&N3 as applied in this study. 

Monetisation of casualties prevented 

Annex 4.4.9 
The monetary values assigned for prevention of a fatal, serious and slight casualty, 
respectively, were based on the unit cost values suggested in the 2014 Update of the 
Handbook of External Costs of Transport, prepared on behalf of the European Commission, 
DG MOVE (Korzhenevych et al., 2014), see Table 43156. The values relate to market prices in 
the year 2010 and were adjusted for inflation to the relevant study year, using the inflation 
factors described in Annex 4.4.13.  

156 Note: ‘Mitigated’ casualties are monetised as full prevented casualties at the higher level, but subsequently 
added to the remaining population of the lower level and thereby reduce the monetary benefit in the lower 
severity  group.  The  benefit  of  a  fatality  turned  to  a  serious  casualty,  for  instance,  equates  to  €1,626,900 
based on the above values. 

125 

 
 
 
  
 
                                                 
Table  44:  Monetary  values applied for prevented casualties, at  market prices (PPP) in 
year 2010 euros 

Casualty severity 

Social unit cost 

Fatal 

Serious 

Slight 

€1,870,000 

€243,100 

€18,700 

Note that the value of €243,100 is assigned to ‘severe’ injuries in the study by (Korzhenevych 
et al., 2014), which appears to implicate a definition based on injury level of MAIS4+ rather 
than police-defined ‘serious’ injuries. However: 

 

(Korzhenevych  et  al.,  2014)  use  the  terms  ‘serious’  and  ‘severe’  interchangeably 
throughout the report. 

  All values in the report are updates of the values determined during the course of the 
HEATCO  project  (Bickel  et  al.,  2006a),  which,  in  turn,  based  the  serious  casualty 
valuation on a proportion of the fatality value that was derived for the ECMT 1998 or 
2001  Round  Table.  This  Round  Table  saw  scientific  contributions  from  Germany, 
Netherlands,  UK  and  Sweden  and  the  definition  of  a  ‘Serious’  casualty  was  closely 
related to the national police record definition, rather than a MAIS-based definition.  

Therefore, the value cited above for serious casualties is most appropriately applied to the 
conventional reported number of serious casualties in the CARE database, rather than the new 
MIAS-based definition of MAIS3+ injuries. 

Annex 4.4.10  Safety measure costs 
Costs for the proposed safety measures were estimated on a per vehicle basis for this study. 
The cost values are subjected to inflation using the inflation factors described in in Annex 
4.4.13 and multiplied with the number of new vehicle registrations per vehicle category in the 
relevant study year.  

The initial cost estimates presented are to be understood to reflect the costs to the vehicle 
manufacturers at time of mandatory introduction, that is, 

 

 

the  price  a vehicle  manufacturer  would  pay  a Tier  1  supplier  for  fully  manufactured 
components  (‘Tier  1  supplier  costs’)  with  an  additional  mark-up  to  reflect  costs  for 
acquisition, storage and installation of the components; or  
the  total  cost  to  the  vehicle  manufacturer,  including  fixed  and  variable  cost  of 
manufacturing  and  assembly,  and  overheads  for  research  and  development,  broken 
down per vehicle. 

Table 45 presents the initial cost estimates per vehicle for each of the policy options assessed. 
Refer to Annex 4.8.7 for the relevant individual cost estimates, sources and rationale for 
expert panel estimates. 

126 

 
 
 
 
Table  45:  Initial  cost  at  mandatory  introduction  of  policy  options  per  vehicle  (best 
estimate) inflated to year-2021 Euros 

Initial cost per vehicle 

Passenger cars (M1) 

Buses and coaches (M2&M3) 

Vans (N1) 

Trucks (N2&N3) 

PO1 

€201 

€6 

€131 

€6 

PO2 

€360 

€607 

€206 

€607 

PO3 

€516 

€970 

€521 

€1,013 

The cost estimates in the study reflect the assumption of high-volume manufacturing of the 
required components due to mandatory introduction. Based on the practice applied by 
agencies such as NHTSA157 and EPA158 in past regulatory cost-effectiveness evaluations159, 
cost reductions through learning by doing (accumulated production volume and small 
redesigns that reduce costs) are applied to the initial cost estimates after first mandatory 
introduction of the measures (Committee on the Assessment of Technologies for Improving 
Light-Duty Vehicle Fuel Economy; National Research Council, 2011). A two-step reduction 
of 20% and 10%, respectively, is applied to the initial cost-estimates in the first and second 
year, respectively, after introduction.  

Where technology sharing of sensors between different measures was deemed possible, the 
relevant cost was distributed between the measures of interest. This was done for the 
measures AEB-VEH, AEB-PCD, ISA-VOL, and LKA-ELK, considering that these could 
likely be realised in a camera-based version (although radar might be necessary for more 
advanced systems, basic functionality could be realised using visual sensors). 

The best estimates for costs were based on the values determined by (Seidl et al., 2017) in 
preparation of this study (extracted from published tear-down studies and stakeholder input). 
Additional industry estimates from vehicle manufacturers were received and considered, 
where deemed appropriate, to justify upward or downward adjustments of the initial best 
estimates and to define the breadth of variation for the upper and lower estimate for the 
interval and scenario analysis. Where no values could be identified during the course of this 
review and where no stakeholder input was provided, a road safety expert panel at TRL 
determined best estimates from the available evidence. Note that most cost-estimates for N1 
vehicles were derived from M1 costs, and most M2&M3 estimates from N2&N3 costs. This 

157 https://www.nhtsa.gov/  

158 https://www.epa.gov/  

159 https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/deis_appx_c.pdf   

127 

 
 
 
                                                 
was necessary because the level of evidence for vans and buses and coaches was not as high 
as for the other vehicle categories. 

Annex 4.4.11 

Impact  of  additional  safety  measures  on  vehicle  prices 
and sales numbers 

This study makes predictions of future new vehicle sales numbers and fleet growth based on 
extrapolation of historic trends. It is important, in this context, to analyse whether the cost of 
the additional safety measures to the vehicle manufacturers would be likely to result in a 
substantial increase in end-user vehicle prices and thereby negatively affect new vehicle sales 
numbers. If this was the case, slower dispersion of the safety measures into the fleet might 
partially diminish the safety returns, which should be reflected in the model. 

The costs calculated in this study for fitment of the proposed safety measures are to be 
understood to reflect the costs to the vehicle manufacturers. The full set of proposed safety 
measures (PO3) is estimated to create additional costs in the region of €520 per M1 and N1 
vehicle, and in the region of €1,000 per M2&M3 and N2&N3 vehicle (refer to Annex 4.8.7 
for details). These costs incurred by the vehicle manufacturers cannot directly be translated 
into a change in vehicle retail prices, because the markets for consumer, as well as 
commercial, vehicles are highly competitive which might not allow costs to be passed on 
directly; this  can be observed in historic pricing data.  

Up until 2011, the European Commission has published annually the ‘Report on car prices 
within the European Union’160. These reports provide the most comprehensive and detailed 
guide to the historic development of car prices in Europe year-on-year by collating list prices 
for cars (i.e. before any dealership discounts) and determining the car price development in 
real terms, i.e. adjusted for inflation (European Commission, 2011). Table 6 shows the price 
development during the last decade of available data (2002 to 2011).  

160  Available  at:  http://ec.europa.eu/competition/sectors/motor_vehicles/prices/report.html  The  car  price  reports 
were  discontinued  after  2011  because  the  Commission  did  not  find  any  significant  competition 
shortcomings in the new cars sector. 

128 

 
      
  
                                                 
Table  46:  Year-on-year  change  in  real  car  prices  for  the  last  decade  of  available  data. 
Source: Report on car prices within the European Union – Technical annex, Years: 2002 
to 2011 

Year 

2002 

2003 

2004 

2005 

2006 

2007 

2008 

2009 

2010 

2011 

Year-on-year price change 

-0.2% 

-0.7% 

-1.9% 

-1.5% 

-1.6% 

-1.0% 

-3.2% 

-3.1% 

-0.6% 

-2.5% 

2012 and beyond 

EU car price reports discontinued; no published 
data 

It can be seen that cars have become cheaper in real terms in every year of the last reported 
decade, despite this being a period in which technical development to meet new and more 
demanding environmental and safety standards increased, for example:  

  Directive 98/69/EC and Regulation (EC) No 715/2007: Euro 4 and Euro 5 emissions 

standards applicable from 2005 and 2009, respectively. 

  Mandatory  average  fleet  CO2  emissions  limits:  EU  Regulation  No  443/2009  was 
adopted in 2009 with mandatory compliance limits applying from 2012. The average 
CO2 emissions of the new vehicle fleet sold by a manufacturer could not be reduced in 
a step change from one year to the next. Hence, manufacturers started around 2007, in 
preparation for the announced legislation, to introduce technologies that significantly 
reduced CO2 emissions, in order to be able to meet the compliance limits in 2012. This 
can  be  concluded  from  the  average  rate  of  progress  in  CO2  reduction,  which 
accelerated  considerably  after  2007,  compared  to  the  long  term  trend  before 
(Transport  &  Environment,  2011).  Considerable  investments  in  this  regard  therefore 
fall within the period of retail price decreases cited above. 

  Directives 96/79/EC and 96/27/EC: Compliance with frontal and lateral crash tests for 

all new cars sold from October 2003. 

  Regulation  (EC)  No  661/2009  (General  Safety  Regulation):  Electronic  stability 
control (ESC) applicable from 2011, mandatory gear shift indicators applicable from 
2012. 

  Regulation (EC) No 78/2009 (Pedestrian Safety Regulation): Emergency brake assist 

(EBA) applicable from 2011. 

A 2011 study commissioned by the European Commission, DG Climate Action, analysed the 
effect of emissions and safety regulations and standards on vehicle prices (Varma et al., 
2011). The study concluded that historical vehicle price data and fitment status of certain 
features did not provide any definitive relationship between emissions standards and car 
prices. Overall, cars had become 12% to 22% cheaper (after inflation) in the study period of 

129 

 
 
2002 to 2010. The study found that, while there was certainly a cost associated for the vehicle 
manufacturers to comply with the environmental and safety legislation during that period, 
these costs were largely offset by cost reductions from economies of scale and improved 
productivity, because the competition in the market made it difficult to pass on cost increases 
to consumers. Stakeholders interviewed for the study argued that without the additional 
legislation, car prices would have fallen even further in that period. Nevertheless, it is evident 
that regulatory requirements have not stopped the trend of car retail prices decreasing, 
because compliance costs for emissions and safety standards are only one of the many 
complex factors influencing vehicle retail prices. 

A report published by the European Federation for Transport and Environment (T&E) in 2011 
also looked into the aspect of potential vehicle price increases specifically due to CO2 
emissions regulations and, looking back, compared the predicted influence on retail price with 
actual figures (Transport & Environment, 2011). The authors came to a similar conclusion as 
(Varma et al., 2011): That car retail prices were influenced by a complex set of factors, with 
compliance costs being only one of them, and that concerns over cars becoming unaffordable 
due to CO2 emissions regulations had been unfounded. 

The past experience with CO2 emissions legislation also allows comparing predicted 
additional costs with predicted and actual retail price increases: In a 2006 study prepared for 
the European Commission, the researchers from TNO had estimated the future costs to 
manufacturers of reaching the required average CO2 targets to be an additional €832 per car in 
2008, compared to a year-2002 baseline (Smokers et al., 2006). This was expected by the 
authors to translate to an additional retail price of €1,200 per car in 2008, again compared to 
2002. In reality however, cars have become approximately 10% cheaper (after inflation) 
between 2002 and 2008 (see Table 6), which equates to a price reduction of €2,000 for a 
€20,000 model. These figures show that, bearing in mind the scale of investment required to 
meet emissions requirements, coupled with the costs of the other aspects cited above, the 
costs to vehicle manufactures related to the fitment of new safety measures in the present 
study are not considered to be orders of magnitude different in scale than past predictions 
which did not translate to retail price increases.  

Interpreting the general price trend and the conclusions from the cited studies on compliance 
costs, it can be concluded that vehicle manufacturers in the past have found strategies and 
practices to balance production costs and regulatory compliance. This has been, for example, 
via increases in production efficiency, or accepted temporarily reduced profit margins to at 
least partially offset any cost increase, because the competitive nature of the vehicle market 
did not allow substantial retail price increases. Past evidence therefore suggests that requiring 
additional equipment for CO2 emission standards, which was estimated at a cost higher than 
the present estimates for the full set of proposed safety measures, did not cause an increase in 
retail prices. Substantial increases in vehicle prices due to the additional safety measures in 
the medium and long term are therefore not expected and consequently no extraordinary 
impact on vehicle sales numbers was modelled for the cost-benefit analysis. 

130 

 
 
Annex 4.4.12  Discounting of costs and benefits 
A discounting rate is applied in the economic analysis for this study to relate the benefits and 
costs occurring in future years to the present. A ‘social discount rate’ r is applied to reflect the 
fact that benefits and costs further ahead in the future are valued lower than present benefits 
and costs. 

The present value PV of costs C in the years t=0 to the end of the appraisal period t=T is 
calculated as (Bickel et al., 2006a): 

𝑇
𝑃𝑉 = ∑ 𝐶𝑡 ×
𝑡=0

1
(1 + 𝑟)𝑡

The present value of benefits is calculated in the same way. 

Recommended social discount rates for EU transport projects in relevant guidelines range 
between 3% (recommended in the HEATCO project as lower bound for sensitivity analysis, 
(Bickel et al., 2006b)) and up to 5.5% (recommended by DG Regional Policy for investments 
in Cohesion countries, (European Commission, DG Regional Policy, 2008)).  

For the current CBA an average rate between these recommendations, i.e.  

𝑟 = 4.25%, 

was chosen for the central estimate calculations. The interval analysis range was set as 
𝑟𝑙𝑜𝑤 = 3.0% to 𝑟ℎ𝑖𝑔ℎ = 5.5%. A constant rate r was applied over time for the entire analysis 
period, which is in line with the HEATCO recommendations, which only call for a declining 
discount system if intergenerational impacts are concerned in very long appraisal periods 
(Bickel et al., 2006b). 

Inflation of monetary values 

Annex 4.4.13 
An inflation rate is applied to all monetary values in this study to adjust cost and benefit 
estimates from the past to current values and to factor in future devaluation. The inflation rate 
used is the year-on-year percentage change of the Harmonised Index of Consumer Prices 
published by Eurostat. For the past, historic data from Eurostat was used; for the future 
forecasts by the European Central Bank (Table 47).   

Table 47: Year-on-year inflation rates applied in the study 

Year 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

Inflation rate 

3.7% 

1.0% 

2.1% 

3.1% 

2.6% 

1.5% 

0.5% 

Type 

actual 

actual 

actual 

actual 

actual 

actual 

actual 

131 

Source 

(Eurostat, 2017) 

(Eurostat, 2017) 

(Eurostat, 2017) 

(Eurostat, 2017) 

(Eurostat, 2017) 

(Eurostat, 2017) 

(Eurostat, 2017) 

 
 
Year 

Inflation rate 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

2023 and 
beyond 

0.0% 

0.3% 

1.5% 

1.4% 

1.6% 

1.8% 

1.8% 

1.8% 

2.0% 

Type 

actual 

actual 

forecast 

forecast 

forecast 

forecast 

forecast 

forecast 

forecast 

Source 

(Eurostat, 2017) 

(Eurostat, 2017) 

(European Central Bank, 2017a) 

(European Central Bank, 2017a) 

(European Central Bank, 2017a) 

(European Central Bank, 2017a) 

(European Central Bank, 2017a) 

(European Central Bank, 2017a) 

(European Central Bank, 2017b) 

Annex 4.4.14  Sensitivity analysis  
To quantify the range uncertainty around the best estimate BCR values, two sensitivity 
analysis techniques common in cost-benefit evaluations were applied (Bickel et al., 2006a): 

Interval analysis, and 

 
  Scenario analysis. 

Input parameters which have a strong influence on results and a relatively high associated 
uncertainty were identified as: 

  Measure effectiveness (directly influencing the number of casualties saved),  
  Measure cost (directly influencing the fitment cost), 
  Discounting rate (influencing the weight of short-term and long-term effects), 
  General road casualty trend (influencing the size of the target population for the safety 

measures), and 

  Voluntary measure uptake (influencing the baseline to which the other policy options 

are compared). 

The best estimate and upper/lower estimate values for these parameters were chosen as 
described in the previous sub-sections or in the appendices. Refer to Table 48 for an overview 
of the combination of input parameters used for each analysis. The other input parameters 
remained unchanged. 

132 

 
 
 
Table 48: Varied input parameter values for interval and scenario analysis 

Interval analysis 
(absolute lower 
BCR)  

Scenario analysis 
(expected lower 
BCR) 

Best estimate 
analysis 

Scenario analysis 
(expected upper 
BCR) 

Interval analysis 
(absolute upper 
BCR) 

Lower estimate 

Upper estimate 

Best estimate 

Lower estimate 

Upper estimate 

Upper estimate 

Upper estimate 

Best estimate 

Lower estimate 

Lower estimate 

Measure 
effectiveness 

Measure cost 

Discounting rate 

Upper estimate 

Best estimate 

Best estimate 

Best estimate 

Lower estimate 

General road 
casualty trend 
Voluntary measure 
uptake 

Lower estimate 

Lower estimate 

Best estimate 

Best estimate 

Best estimate 

Best estimate 

Best estimate 

Best estimate 

Lower estimate 

Lower estimate 

The interval analysis was carried out to determine the absolute upper and lower bound of the 
BCR. The parameters mentioned above were varied in a direction that represents an absolute 
optimistic assumption (absolute upper BCR) and an absolute pessimistic assumption (absolute 
lower BCR). These are the outer bounds of variation that could be conceivable according to 
the model employed under extreme circumstances; however, these bounds would only be met 
in the improbable case that future reality diverges from the estimated input values in the same 
direction for each of the safety measures.   

The scenario analysis was carried out to reflect the bounds of variation that could be expected 
in a scenario where the input value estimates applied had a tendency to systematically 
underestimate both effectiveness and costs (expected upper BCR), or to systematically 
overestimate both (expected lower BCR), and where the voluntary measure uptake (expected 
upper BCR) or the general road casualty trend (expected lower BCR) would be lower than 
expected.  

The resulting absolute and expected upper/lower BCR results are reported alongside each best 
estimate BCR. 

Annex 4.4.15  Data sources and stakeholder validation 
In preparation of this cost-effectiveness study, the European Commission tasked TRL to 
collate the most up-to-date, high quality data available on effectiveness, cost, fleet penetration 
and target population of the safety measures. TRL selected the best sources for these 
parameters from the body of published evidence based on quality of research, quality of data, 
timeliness and relevance and extract suggested input values.  

This was followed by a wide stakeholder consultation where stakeholders were asked to 
provide values for parameters (if no published evidence was available), to validate or contest 
TRL’s preliminary suggested values with additional evidence, and to comment on the 
proposed method for avoidance of double-counting of casualties prevented (three layers of 
protection). 72 representatives from 54 organisations (including vehicle manufacturers, Tier 1 
suppliers, government organisations, non-government organisations in the area of road safety 
and environment, consumer organisations, academic and vehicle safety research and 

133 

 
 
 
 
development organisations and consultancies) attended the two-day stakeholder meeting. In 
addition, 32 organisations provided written feedback.  

All inputs, provided in writing or during the two-day face-to-face meeting, were documented 
and, where appropriate, used to update and refine the input values proposed for this cost-
effectiveness study. The input values found in this process were collated in the report In 
Depth Cost-Effectiveness Analysis of the Identified Measures and Features regarding the Way 
Forward for Vehicle Safety in the EU (‘GSR2’) (Seidl et al., 2017) and are referenced 
throughout Annex 4.8.1 to Annex 4.8.7 of this report. Where additional sources or expert 
panel assessments were required, this is explained in Annex 4.4.1 to Annex 4.4.15 and 
referenced alongside the numbers. 

Limitations 

Annex 4.4.16 
In general, the model has used various input values (e.g. inflation rate, number of new 
registrations, measure effectiveness, etc.) to predict the effects of different policy options. 
Predictions of the future are by definition inherently subject to a degree of uncertainty. This 
study has used input values based on historical trends; the interval and scenario analysis 
provides assessment of the effect that deviations from the expected trend may have on the 
outcome, but cannot completely account for very extreme changes in circumstances. The 
following important limitations of the simulation model employed and the input value 
estimates should be taken into account when interpreting the results.  

The accident data analysis to determine the target populations for the safety measures was 
based on GB national data rather than pan-European data. The EU-wide accident data 
available from CARE did not offer the level of detail necessary to perform this analysis 
because it does not contain contributory factors of collisions or data on the first point of 
impact on vehicles. Where data from additional European countries regarding target 
populations for the specific measures considered was available, this was incorporated by 
applying target population correction factors to represent the average situation in the countries 
available. This was the case for measures HED-MGI, ISA-VOL, REV, VIS-DET and VIS-
DIV. To arrive at estimates valid for the European Union, the target population percentages 
found were scaled up to EU-28 to greatest level of detail possible from the data fields 
available within the CARE. The scaling was based on the average European casualty 
distribution for fatal, serious and slight casualties in collisions where the relevant vehicle 
categories collided. This means, the scaling was carried out so that it is representative of the 
European proportions of casualties in M1-to-M1, M1-to-N1, N1-to-M2M3, etc. collisions. 

The effectiveness and cost estimates used are subject to a degree of uncertainty. The level of 
uncertainty varies between safety measures, with the level of evidence available for each 
measure from research. The level of evidence was good for some well-established measures 
(e.g. AEB and AEB-PCD) and less robust for some other measures (e.g. DDR-DAD and 
DDR-ADR). Both, effectiveness and cost estimates were established using a thorough review 
process during the GSR2 project which involved large-scale stakeholder consultations and are 
therefore considered to represent the highest level of evidence that could be acquired. To treat 

134 

 
 
the remaining uncertainty in these values, upper and lower estimates were employed for the 
interval and the scenario analysis. 

The casualty simulations and cost calculations are based on a continuation of existing trends 
into the future (with expected variability in these trends captured in the scenario analysis). 
This approach cannot capture any potential disruptions that might occur in the mobility 
market in the future, such as autonomous driving radically changing the collision landscape, 
mobility as a service reducing private car ownership and potentially increasing overall miles 
driven, or a severe economic crisis reducing new vehicle uptake. Disruptions are highly 
uncertain and impossible to predict as to when, if, and to what extent they will happen and 
their impact could not be captured in the models other than in a highly speculative way, which 
would undermine the evidence-base for the analysis.  

The results of the cost-benefit analysis should be interpreted with this context in mind and 
understood as an evidence-based, detailed prediction of the cost-effectiveness of the policy 
options if historic trends continue within a range of expected uncertainty. 

135 

 
 
 
Annex 4.5

Results 

Cost-effectiveness of policy options  

Annex 4.5.1 
The main results of the cost-effectiveness evaluation are presented in the following tables and 
figures, separated by vehicle category cluster (M1, M2&M3, N1 and N2&N3, respectively). 
Further results for indvidual years of the evaluation period and ranges of uncertainty are given 
in Annex 4.9.2 and Annex 4.9.3, respectively.  

The benefit-to-cost ratios (BCRs) reported allow a comparison of the different policy options 
based on the extent to which the benefits exceed (or fall short of) the costs created by a policy 
option over the entire evaluation period 2021–2037, compared to the baseline scenario 
(voluntary uptake). Values greater than 1 indicate that the benefits are greater than the costs 
incurred. 

For passenger cars (M1), the results indicate that implementation of any of the policy options 
would be cost-effective, according to the best-estimate calculations and also within the 
expected lower and upper estimate band found in the scenario analysis. PO1 resulted in the 
highest BCR for passenger cars.  

For buses and coaches (M2&M3), all policy options were found to be cost-effective according 
to best estimate calculations and also within the expected lower and upper estimate band. PO1 
has the highest BCR; however note that this ratio is achieved, by this policy option consisting 
of only two measures, which has minimal impact on both costs and benefits as can be seen 
from the casualty prevention results (Annex 4.5.2). 

For vans (N1), implementation of PO1 and PO2 were found to be cost-effective according to 
the best-estimate calculations. The band of expected uncertainty for PO2 just spans the 
threshold of cost-effectiveness. PO3 was found to be less cost-beneficial and did not exceed 
the threshold of cost-effectiveness. 

For trucks (N2&N3), PO2 and PO3 exceeded the threshold of cost-effectiveness, according to 
best estimate calculations. PO2 presented the most favourable BCR with the expected lower 
BCR value falling short of cost-effectiveness by a small margin. For PO3, the expected lower 
and upper estimate band straddled the threshold of cost-effectiveness.  

When interpreting the results it should also be considered that only safety benefits of the 
assessed measures have been considered in this study. Non-quantified benefits, such as, 
productivity gains due to the reduction in traffic congestion associated with road traffic 
collisions or reduced CO2 emissions caused by TPM, will contribute to a greater benefit of the 
policy options. 

136 

 
 
 
 
Passenger cars (M1): 

Table 49: Passenger cars (M1): Benefit-to-cost ratios (BCRs) of policy options PO1, PO2 
and PO3 based on present values over entire evaluation period 2021–2037 compared to 
the baseline scenario; uncertainty ranges from scenario and interval analysis 

Passenger cars (M1) 

BCR (best estimate) 

PO1 

2.95 

PO2 

2.14 

PO3 

1.39 

BCR (expected lower/upper) 

2.28 

3.31 

1.58 

2.69 

1.01 

1.85 

BCR (absolute lower/upper) 

1.83 

4.14 

1.31 

3.30 

0.84 

2.27 

BCRs of policy options for passenger cars (M1) 

3,5

3,0

2,5

2,0

1,5

1,0

0,5

0,0

PO1

PO2

PO3

Figure  34:  Passenger  cars  (M1):  Comparison  of  best  estimate  benefit-to-cost  ratios 
(BCRs) of policy options PO1, PO2 and PO3, with indication of uncertainty ranges from 
scenario analysis 

Table  50:  Passenger  cars  (M1):  Present  monetary  value  of  benefits  and  costs  of  policy 
options  PO1,  PO2  and  PO3  over  entire  evaluation  period  2021–2037  compared  to  the 
baseline scenario (best estimate) 

Passenger cars (M1) 

PO1 

PO2 

PO3 

Present value benefit 

Present value cost 

€37.5 bn 

€12.7 bn 

€57.4 bn 

€26.9 bn 

€64.1 bn 

€46.0 bn 

137 

 
 
 
 
 
 
 
 
 
Buses and coaches (M2&M3): 

Table 51: Buses and coaches (M2&M3): Benefit-to-cost ratios (BCRs) of policy options 
PO1,  PO2  and  PO3  based  on  present  values  over  entire  evaluation  period  2021–2037 
compared  to  the  baseline  scenario;  uncertainty  ranges  from  scenario  and  interval 
analysis 

Buses and coaches (M2&M3) 

BCR (best estimate) 

PO1 

4.64 

PO2 

3.11 

PO3 

2.11 

BCR (expected lower/upper) 

3.17 

14.32 

1.91 

4.42 

1.46 

2.56 

BCR (absolute lower/upper) 

2.11 

21.72 

1.37 

6.26 

1.03 

3.65 

BCRs of policy options for buses and coaches 
(M2&M3) 

7,0

6,0

5,0

4,0

3,0

2,0

1,0

0,0

PO1

PO2

PO3

Figure  35:  Buses  and  coaches  (M2&M3):  Comparison  of  best  estimate  benefit-to-cost 
ratios  (BCRs)  of  policy  options  PO1,  PO2  and  PO3,  with  indication  of  uncertainty 
ranges from scenario analysis 

138 

 
 
 
 
 
 
 
Table 52: Buses and coaches (M2&M3): Present monetary value of benefits and costs of 
policy options PO1, PO2 and PO3 over entire evaluation period 2021–2037 compared to 
the baseline scenario (best estimate) 

Buses and coaches (M2&M3) 

PO1 

PO2 

PO3 

Present value benefit 

€11.2 mn 

€813.7 mn 

€937.0 mn 

Present value cost 

€2.4 mn 

€262.0 mn 

€444.5 mn 

139 

 
 
 
Vans (N1): 

Table 53: Vans (N1): Benefit-to-cost ratios (BCRs) of policy options PO1, PO2 and PO3 
based  on  present  values  over  entire  evaluation  period  2021–2037  compared  to  the 
baseline scenario; uncertainty ranges from scenario and interval analysis 

Vans (N1) 

BCR (best estimate) 

PO1 

1.78 

PO2 

1.35 

PO3 

0.53 

BCR (expected lower/upper) 

1.39 

1.83 

0.98 

1.51 

0.39 

0.65 

BCR (absolute lower/upper) 

1.09 

2.33 

0.79 

1.88 

0.31 

0.81 

BCRs of policy options for vans (N1) 

2,0

1,5

1,0

0,5

0,0

PO1

PO2

PO3

Figure  36:  Vans  (N1):  Comparison  of  best  estimate  benefit-to-cost  ratios  (BCRs)  of 
policy options PO1, PO2 and PO3, with indication of uncertainty ranges from scenario 
analysis 

140 

 
 
 
 
 
 
 
Table 54: Vans (N1): Present monetary value of benefits and costs of policy options PO1, 
PO2  and  PO3  over  entire  evaluation  period  2021–2037  compared  to  the  baseline 
scenario (best estimate) 

Vans (N1) 

Present value benefit 

Present value cost 

PO1 

€2.3 bn 

€1.3 bn 

PO2 

€2.8 bn 

€2.0 bn 

PO3 

€3.7 bn 

€6.9 bn 

141 

 
 
 
Trucks (N2&N3): 

Table  55:  Trucks  (N2&N3):  Benefit-to-cost  ratios  (BCRs)  of  policy  options  PO1,  PO2 
and PO3 based on present values over entire evaluation period 2021–2037 compared to 
the baseline scenario; uncertainty ranges from scenario and interval analysis 

Trucks (N2&N3) 

BCR (best estimate) 

PO1 

0.56 

PO2 

1.52 

PO3 

1.03 

BCR (expected lower/upper) 

0.39 

2.93 

0.89 

2.28 

0.59 

1.29 

BCR (absolute lower/upper) 

0.25 

4.49 

0.73 

2.81 

0.47 

1.63 

BCRs of policy options for trucks (N2&N3) 

2,5

2,0

1,5

1,0

0,5

0,0

PO1

PO2

PO3

Figure 37: Trucks (N2&N3): Comparison of best estimate benefit-to-cost ratios (BCRs) 
of  policy  options  PO1,  PO2  and  PO3,  with  indication  of  uncertainty  ranges  from 
scenario analysis 

142 

 
 
 
 
 
 
 
Table  56:  Trucks  (N2&N3):  Present  monetary  value  of  benefits  and  costs  of  policy 
options  PO1,  PO2  and  PO3  over  entire  evaluation  period  2021–2037  compared  to  the 
baseline scenario (best estimate) 

Trucks (N2&N3) 

Present value benefit 

Present value cost 

PO1 

€ 0.01 bn 

€ 0.02 bn 

PO2 

€3.4 bn 

€2.2 bn 

PO3 

€4.1 bn 

€4.0 bn 

143 

 
 
 
Casualties prevented by policy options 
Annex 4.5.2 
The main results of the casualty prevention simulations are presented in the following tables 
and figures separated by vehicle category cluster (M1, M2&M3, N1 and N2&N3, 
respectively). Further results for indvidual years of the evaluation period are given in Annex 
4.9.3. 

Comparison of the results allows conclusions about which policy option prevents the highest 
number of casualties161,162 across EU-28 when compared with the baseline scenario. To 
estimate the casualty prevention totals, the best estimate numbers of all years of the evaluation 
period 2021–2037 are summed. 

It can be observed for all vehicle categories that the number of casualties prevented by 
implementation of PO2 or PO3 exceeds the number prevented by PO1 by a considerable 
margin. Between all four vehicle categories, implementation of PO2 has the potential to 
prevent an additional 8,312 fatalities and 51,286 serious casualties compared to PO1 across 
EU-28 over the period 2021–2037. PO3 exceeds the potential of PO2 by further 1,843 
fatalities and 21,807 serious casualties. 

161 When interpreting the results, it should be noted that casualties prevented were 
attributed to the vehicle category equipped with the effective safety measure, which is not 
always identical with the vehicle category occupied by the casualty. To give an example, if a 
head-on collision involving a van (N1) and a car (M1) where the van drifted out of the lane 
and the drivers of both vehicles were fatally injured was prevented by LKA-ELK fitted to the 
van, then both fatalities prevented would be counted as benefit of LKA-ELK in the N1 
category. 

162 It should further be noted that ‘mitigated’ casualties were added to the remaining casualties at the next lower 

injury severity level. 

144 

 
 
                                                 
All vehicle categories (total sum): 

Table  57:  Total  sum  of  casualties  prevented  by  safety  measures  across  all  vehicle 
categories over the evaluation period 2021–2037 across EU-28 compared to the baseline 
scenario (best estimate) 

All categories 

Fatalities prevented 

Serious casualties prevented 

Slight casualties prevented 

PO1 

14,639 

67,647 

288,293 

PO2 

22,951 

118,933 

421,562 

PO3 

24,794 

140,740 

515,681 

Fatalities prevented per policy option  
(sum of all vehicle categories) 

24 794 

22 951 

14 639 

30 000

25 000

20 000

15 000

10 000

5 000

 0

PO1

PO2

PO3

Figure 38: Total sum of fatal casualties prevented by safety measures across all vehicle 
categories over the evaluation period 2021–2037 across EU-28 compared to the baseline 
scenario (best estimate with indication of uncertainty ranges from scenario analysis) 

145 

 
 
 
 
 
 
 
 
Passenger cars (M1): 

Table  58:  Passenger  cars  (M1):  Total  number  of  casualties  prevented  by  M1  safety 
measures over the evaluation period 2021–2037 across EU-28 compared to the baseline 
scenario (best estimate) 

Passenger cars (M1) 

Fatalities prevented 

Serious casualties prevented 

Slight casualties prevented 

PO1 

13,785 

63,493 

276,815 

PO2 

20,081 

107,913 

389,756 

PO3 

21,337 

126,390 

470,747 

Fatalities prevented per policy option for 
passenger cars (M1) 

20.081 

21.337 

25.000

20.000

15.000

13.785 

10.000

5.000

0

PO1

PO2

PO3

Figure 39: Passenger cars (M1): Total number of fatal casualties prevented by M1 safety 
measures over the evaluation period 2021–2037 across EU-28 compared to the baseline 
scenario (best estimate) 

146 

 
 
 
 
 
 
 
 
Buses and coaches (M2&M3): 

Table  59:  Buses  and  coaches  (M2&M3):  Total  number  of  casualties  prevented  by 
M2&M3 safety measures over the evaluation period 2021–2037 across EU-28 compared 
to the baseline scenario (best estimate) 

Buses and coaches (M2&M3) 

Fatalities prevented 

Serious casualties prevented 

Slight casualties prevented 

PO1 

2 

33 

113 

PO2 

207 

2,064 

6,421 

PO3 

227 

2,410 

8,174 

Fatalities prevented per policy option for buses 
and coaches (M2&M3) 

207 

227 

2 

PO1

PO2

PO3

250

200

150

100

50

0

Figure 40: Buses and coaches (M2&M3): Total number of fatal casualties prevented by 
M2&M3 safety measures over the evaluation period 2021–2037 across EU-28 compared 
to the baseline scenario (best estimate) 

147 

 
 
 
 
 
 
 
 
Vans (N1): 

Table 60: Vans (N1): Total number of casualties prevented by N1 safety measures over 
the  evaluation period 2021–2037 across EU-28 compared to  the  baseline  scenario (best 
estimate) 

Vans (N1) 

Fatalities prevented 

Serious casualties prevented 

Slight casualties prevented 

PO1 

852 

4,074 

11,208 

PO2 

1,005 

5,068 

15,536 

PO3 

1,283 

6,917 

23,486 

Fatalities prevented per policy option for vans 
(N1) 

1.283 

1.005 

852 

1.400

1.200

1.000

800

600

400

200

0

PO1

PO2

PO3

Figure 41: Vans (N1): Total number of fatal casualties prevented by N1 safety measures 
over  the  evaluation  period  2021–2037  across  EU-28  compared  to  the  baseline  scenario 
(best estimate) 

148 

 
 
 
 
 
 
 
 
Trucks (N2&N3): 

Table  61:  Trucks  (N2&N3):  Total  number  of  casualties  prevented  by  N2&N3  safety 
measures over the evaluation period 2021–2037 across EU-28 compared to the baseline 
scenario (best estimate) 

Trucks (N2&N3) 

Fatalities prevented 

Serious casualties prevented 

Slight casualties prevented 

PO1 

0 

47 

157 

PO2 

1,658 

3,888 

9,849 

PO3 

1,947 

5,023 

13,274 

Fatalities prevented per policy option for trucks 
(N2&N3) 

1.947 

1.658 

0 

PO1

PO2

PO3

2.500

2.000

1.500

1.000

500

0

Figure  42:  Trucks  (N2&N3):  Total  number  of  fatal  casualties  prevented  by  N2&N3 
safety  measures  over  the  evaluation  period  2021–2037  across  EU-28  compared  to  the 
baseline scenario (best estimate) 

149 

 
 
 
 
 
 
 
 
Conclusions 

Annex 4.6
From the results found for passenger cars (M1) in this cost-effectiveness study, it can be 
concluded that PO1 offers the most favourable cost-benefit value, but falls short of the overall 
casualty savings that are expected for implementation of PO2 or PO3 by a considerable 
margin. PO2 has the potential to prevent approximately 6,296 fatalities more over the 
evaluation period (2021–2037) compared to PO1 and is cost-effective, with the benefits 
exceeding the costs by a factor of almost three. PO3 is expected to prevent an additional 1,249 
fatalities compared to PO2. 

The results for buses and coaches (M2&M3) lead to the following conclusions: PO1 is most 
cost-beneficial; however, with this policy option consisting of only two measures, the impact 
of implementation on both costs and benefits would be minimal. PO1 is  expected to prevent 
almost no fatalities. PO2 has a favourable BCR of over 3 and has the potential to prevent 207 
fatalities, which could be a reason to favour this policy option over PO1. PO3 would prevent 
an additional 20 fatalities and is still expected to be cost-beneficial compared to the baseline 
scenario at a factor of more than two. 

For vans (N1), again PO1 is most cost-beneficial, but implementation of PO2, which is 
exceeding the threshold to cost-effectiveness, offers the potential to prevent an additional 153 
fatalities and 994 serious casualties over the period 2021–2037, many of which are 
pedestrians and cyclists addressed by the measures AEB-PCD and HED-MGI. PO3 falls short 
of crossing the threshold to cost-effectiveness, with the costs exceeding the benefits with a 
factor of almost two, but would be expected to prevent another 278 fatalities and 1,849 
serious casualties compared to PO2.  

The conclusions for trucks (N2&N3) differ from those for buses and coaches, in that PO1 was 
found not to be cost-effective. However, it should be considered that PO1 has minimal costs 
associated with it (two measures) and therefore small differences in the target populations and 
resulting benefits cause large fluctuations in the ratio. PO2 is the most favourable option for 
trucks based on BCR and would prevent 1,658 fatalities. PO3 offers the potential to prevent 
an additional 289 fatalities, with the benefits exceeding the costs by only a small margin.  

Overall it can be concluded that PO1 offers mostly favourable cost-effectiveness ratios; 
however, these are achieved with only a small impact on both the costs and the benefits 
compared to the baseline scenario of continued voluntary uptake. The impacts of PO2 and 
PO3 are larger, with numbers of fatalities prevented exceeding those of PO1 by a considerable 
margin; however this is accompanied by a greater cost. Where PO2 or PO3 exceed the 
threshold to cost-effectiveness (BCR>1), the considerably greater number of casualties 
prevented compared to PO1 could be a reason to favour implementation of PO2 or PO3. 

150 

 
 
 
Annex 4.7

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Korzhenevych A, Dehnen N, Bröcker J, Holtkamp M, Meier H, Gibson G, Varma A and Cox V (2014). 
Update of the Handbook on External Costs of Transport. Ricardo-AEA. 

Lenkeit J and Smith T (2016). Preliminary Study of the Response of Forward Collision Warning Systems to 
Motorcycles. Dynamic Research Inc.. 

151 

 
 
 
Martin P, Knight I, Hunt R, O'Connell S, Cuerden R and McCarthy M (2017). Study on enhanced truck 
front  end  designs  (TFEDs)  -  Safety  Benefits  for  Vulnerable  Road  Users  (VRUs)  (unpublished).  Transport 
Research Laboratory, Crowthorne. 

NHTSA  (2010).  Notice  of  proposed  rulemaking  (NPRM)  -  Federal  Motor  Vehicle  Safety  Standard,  Rearview 
Mirrors;  Federal  Motor  Vehicle  Safety  Standard,  Low-Speed  Vehicles  Phase-in  Reporting  Requirements 
(Docket No. NHTSA-2010-0162, RIN 2127-AK43). 

NHTSA  (2015).  Federal  Motor  Vehicle  Safety  Standards;  Electronic  Stability  Control  Systems  for  Heavy 
Vehicles - Final Rule. 

Organisation Internationale des  Constructeurs  d’Automobiles  (OICA) 2017,  Vehicles  in  use., Paris, viewed 22 
September 2017, <http://www.oica.net/category/vehicles-in-use/>. 

Robinson B, Hulshof W, Robinson T and Knight I (2010). AEBS and LDWS exemptions study: final report. 
Transport Research Laboratory: Crowthorne. 

Seidl M, Hynd D, McCarthy M, Martin P, Hunt R, Mohan S, Krishnamurthy V and O'Connell S (2017). 
In depth cost-effectiveness analysis of the identified measures and features regarding the way forward for EU 
vehicle safety. Transport Research Laboratory, European Commission: Crowthorne. 

Smokers  R,  Vermeulen  R,  van  Mieghem  R  and  Gense  R  (2006).  Review  and  analysis  of  the  reduction 
potential and costs of technological and other measures to reduce CO2-emissions from passenger cars. TNO, 
Delft. 

Sternlund  S,  Strandroth  J,  Rizzi  M,  Lie  A  and  Tingvall  C  (2017).  The  eﬀectiveness  of  lane  departure 
warning systems—A reduction in real-world passenger car injury crashes. Traffic Injury Prevention, 18(2), 225-
229. 

Transport & Environment (2011). How clean are Europe's cars?. 

van Zyl S, van Goethem S, Kanarachos S, Rexeis M, Hausberger S and Smokers R (2013). Study on Tyre 
Pressure  Monitoring  Systems  (TPMS)  as  a  means  to  reduce  Light-Commercial  and  Heavy-Duty  Vehicles 
fuelconsumption and CO2 emissions - TNO 2013 R10986. TNO, Delft. 

Varma A, Newman D, Kay D, Gibson G, Beevor J, Skinner I and Wells P (2011). Effect of regulations and 
standards on vehicle prices. AEA. 

152 

 
 
 
Annex 4.8

Appendices of input values 

Annex 4.8.1 

General road casualty trend 

Table  62:  General  road  casualty  trend,  EU-28  casualties  per  annum;  historic  numbers  for  2011–2016,  future  projections  provided  by 
European Commission for 2017–2037  

Year 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

Best estimate 

Lower estimate 

Fatal casualties 

Serious casualties 

Slight casualties 

Fatal casualties 

Serious casualties 

Slight casualties 

30,685 

28,243 

25,956 

25,977 

26,130 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

264,929 

247,661 

240,039 

250,051 

247,905 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

1,235,015 

1,193,873 

1,156,475 

1,173,515 

1,180,068 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

153 

30,685 

28,243 

25,956 

25,977 

26,130 

25,619 

25,440 

25,262 

25,085 

24,909 

24,735 

24,562 

24,390 

24,219 

24,049 

23,881 

23,714 

23,548 

23,383 

23,219 

264,929 

247,661 

240,039 

250,051 

247,905 

246,127 

244,404 

242,693 

240,994 

239,307 

237,632 

235,969 

234,317 

232,677 

231,048 

229,431 

227,825 

226,230 

224,646 

223,074 

1,235,015 

1,193,873 

1,156,475 

1,173,515 

1,180,068 

1,207,268 

1,198,817 

1,190,426 

1,182,093 

1,173,818 

1,165,601 

1,157,442 

1,149,340 

1,141,295 

1,133,306 

1,125,373 

1,117,495 

1,109,672 

1,101,905 

1,094,191 

 
 
 
Year 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

Best estimate 

Lower estimate 

Fatal casualties 

Serious casualties 

Slight casualties 

Fatal casualties 

Serious casualties 

Slight casualties 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

25,619 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

246,127 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

1,207,268 

23,057 

22,896 

22,735 

22,576 

22,418 

22,261 

22,105 

221,512 

219,962 

218,422 

216,893 

215,375 

213,867 

212,370 

1,086,532 

1,078,926 

1,071,374 

1,063,874 

1,056,427 

1,049,032 

1,041,689 

Annex 4.8.2 

Layers of proposed and existing safety measures 

Figure 43: Measure layers for cluster cars (M1) 

154 

 
 
 
 
 
Figure 44: Measure layers for cluster buses and coaches (M2&M3) 

Figure 45: Measure layers for cluster vans (N1) 

155 

 
 
 
 
 
Figure 46: Measure layers for cluster trucks (N2&N3) 

156 

 
 
 
Annex 4.8.3 

Vehicle fleet size 

Figure 47: Bus and coach (M2 and M3) fleet and new registrations 2011 to 2037 

157 

 
 
 
 
 
 
Figure 48: Extra-urban bus and coach fleet and new registrations 2011 to 2037 

158 

 
 
 
Figure 49: Van (N1) fleet and new registrations 2011 to 2037 

159 

 
 
 
 
Figure 50: Truck (N2 and N3) fleet and new registrations 2011 to 2037 

Annex 4.8.4 

Fleet dispersion of safety measures 

Table 63: Technology launch date 

M1 

M2&M3 

N1 

N2&N3 

Source / justification 

160 

 
 
 
 
M1 

M2&M3 

AEB-VEH 

AEB-PCD 
(pedestrian) 
AEB-PCD 
(cyclist) 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESC 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LDW 

LKA-ELK 

PSI 

REV 

TPM 

VIS-DET 

VIS-DIV 

2009 

2012 

2015 

2019 

2011 

2018 

2006 

1996 

2010 

2008 

2012 

2009 

2015 

n/a 

2018 

2001 

2010 

n/a 

n/a 

n/a 

2009 

n/a 

n/a 

2019 

2011 

2018 

n/a 

1996 

2010 

n/a 

n/a 

n/a 

2015 

2011 

n/a 

n/a 

2010 

2005 

2016 

2017 

N1 

2009 

2012 

2015 

2019 

2011 

2018 

2006 

1996 

2010 

2008 

2012 

2009 

2015 

n/a 

2018 

2001 

2010 

2005 

n/a 

n/a 

N2&N3 

Source / justification 

2009 

n/a 

n/a 

2019 

2011 

2018 

n/a 

1996 

2010 

n/a 

n/a 

n/a 

2015 

2011 

n/a 

n/a 

2010 

2005 

2016 

2017 

Introduced before 2011 (Seidl et al., 2017), 2009 provides the closest link to third-party observations on fleet fitment rates in 
2015 (i.e. 32% of newly registered cars in the Netherlands, 30% in Belgium, 16% in Spain and 21% in the United Kingdom). 

Launch date in first motor cars (e.g. Volvo). 

Launch date in first motor cars (e.g. Volvo). 

Time needed to develop the installation document and to see alcohol interlocks developed to match the specifications. 

Systems recognised by Euro NCAP (e.g. Ford Driver Alert). 

Close to market, but no evidence of launch, yet (Seidl et al., 2017). 

Initial cost/benefit study date. 

1996 is probably too early for trucks and buses but is intended to reflect the launch date of the first example, and predominantly 
relating to the car fleet uptake. 

System evaluation cited by (Seidl et al., 2017). 

Monitoring phase for headform-to-windscreen tests in Pedestrian Safety Regulation (EC) No 78/2009. 

This matches the release date for vehicles such as the Ford S-Max with its voluntary ISA system. 

NHTSA and TRL studies suggest launch dates about 2011. 

Suggested launch date according to GSR2 stakeholder input (Seidl et al., 2017). 

(NHTSA, 2010) 

(Seidl et al., 2017) 

Mercedes-Benz Active Brake Assist 4 was introduced in December 2016 and it offers functionality including (and exceeding) 
that required for this measure (Seidl et al., 2017).  
The topic of heavy vehicle direct vision starting to gain momentum  amongst operators and vehicle manufacturers (e.g. 
announcement of direct vision standard for London). 

Table 64: Full voluntary implementation year for new registrations 

AEB-VEH 

AEB-PCD (pedestrian) 

M1 

2023 

2026 

M2&M3 

2023 

n/a 

N1 

2023 

2026 

N2&N3 

2023 

n/a 

161 

 
 
 
 
 
 
AEB-PCD (cyclist) 

ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESC 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LDW 

LKA-ELK 

PSI 

REV 

TPM 

VIS-DET 

VIS-DIV 

M1 

2029 

2033 

2025 

2032 

2012 

2006 

2024 

2014 

2026 

2023 

2029 

n/a 

2032 

2015 

2024 

n/a 

n/a 

n/a 

Table 65: Voluntary implementation uptake for new registrations 

AEB-VEH 

AEB-PCD (pedestrian) 

AEB-PCD (cyclist) 

M1 

High 

High 

High 

N1 

2029 

2033 

2025 

2032 

2016 

2006 

2024 

2014 

2026 

2023 

2029 

n/a 

2032 

2015 

2024 

2019 

n/a 

n/a 

N2&N3 

n/a 

2033 

2025 

2032 

n/a 

2006 

2024 

n/a 

n/a 

n/a 

2029 

2025 

n/a 

n/a 

2024 

2019 

2030 

2031 

N1 

High 

Medium 

Medium 

N2&N3 

High 

n/a 

n/a 

M2&M3 

n/a 

2033 

2025 

2032 

n/a 

2006 

2024 

n/a 

n/a 

n/a 

2029 

2025 

n/a 

n/a 

2024 

2019 

2030 

2031 

M2&M3 

High 

n/a 

n/a 

162 

 
 
 
 
ALC 

DDR-DAD 

DDR-ADR 

EDR 

ESC 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LDW 

LKA-ELK 

PSI 

REV 

TPM 

VIS-DET 

VIS-DIV 

M1 

None 

M2&M3 

None 

N1 

None 

Medium 

Medium 

Medium 

N2&N3 

None 

Medium 

None 

Medium 

High 

High 

Medium 

Medium 

None 

None 

n/a 

Medium 

None 

Medium 

None 

n/a 

n/a 

None 

n/a 

High 

High 

n/a 

n/a 

n/a 

None 

High 

n/a 

n/a 

None 

None 

None 

Medium 

None 

Medium 

High 

High 

High 

High 

None 

None 

n/a 

Medium 

High 

Medium 

n/a 

n/a 

n/a 

None 

n/a 

High 

High 

n/a 

n/a 

n/a 

None 

High 

n/a 

n/a 

None 

None 

None 

Medium 

163 

 
 
 
Annex 4.8.5 

Target population descriptions for accident data extracts 

Table 66: Target population descriptions for proposed measures for all vehicle categories 

Measure 

Target population description for extract from police 
reported data 

Correction factors subsequently applied in order to … 

Correction factor 
fatal 

Correction factor 
serious 

Correction factor 
slight 

AEB-VEH 

Casualties in two-motor-vehicle (excluding powered two-
wheelers) front-to-rear collisions. 

None. 

AEB-PCD 

Pedestrian and cyclist casualties in impacts with vehicle front. 

None. 

ALC 

Casualties where the driver being impaired by alcohol 
contributed to the collision. 

… narrow the target population down to only those alcohol-
related collisions which were caused by hard-core drink drivers 
(repeat offenders) (Seidl et al., 2017). 

DDR-DAD 

Casualties in collisions, where drowsiness or long lasting 
inattention/distraction contributed to the collision. 

… account for underreporting of relevant contributory factors 
(TRL expert panel estimate). 

DDR-ADR 

Casualties in collisions, where drowsiness or long lasting or 
short-term inattention/distraction contributed to the collision. 

… account for underreporting of relevant contributory factors 
(TRL expert panel estimate). 

EDR 

Car and van occupant casualties in all motor vehicle collisions. 

None. 

ESS 

Casualties in two-motor-vehicle (excluding powered two-
wheelers) front-to-rear collisions on roads with a speed limit 
exceeding 30 mph, where sudden braking of the vehicle in front 
contributed to the collision. 

FFW-137 

Front seat casualties in frontal impacts. 

FFW-THO 

Front seat casualties in frontal impacts. 

HED-MGI 

Pedestrian and cyclist casualties in impacts with vehicle front. 

ISA-VOL 

LKA-ELK 

Casualties in collisions where the driver exceeding the speed 
limit contributed to the collision and there were no other 
contributory factors that indicated poor compliance of the driver 
with the law (e.g. impaired by alcohol/drugs, uncorrected 
eyesight, using mobile phone, stolen vehicle, etc.). 
Casualties in head-on and single-vehicle crashes on roads with 
speed limits between 70 km/h and 120 km/h (40 mph and 70 
mph) and dry or wet road surfaces (i.e. not covered by ice or 
snow). 

PSI 

Front seat casualties in lateral impacts against narrow objects 
(e.g. trees, lampposts, traffic signals, etc.). 

… account for underreporting of relevant contributory factors 
(TRL expert panel estimate). 

… narrow the target population down to only full-width impacts 
with thorax injuries (Seidl et al., 2017).  

… narrow the target population down to only full-width impacts 
with thorax injuries (Seidl et al., 2017). 

… narrow target population down to those casualties who 
suffered serious head injuries from impact with the glazed area 
of the windscreen more than 10 centimetres away from the 
scuttle, A-pillars, and header rail; TRL calculations based on 
GIDAS data (ACEA TF-ACC, 2017e). 

… (account for underreporting of contributory factor ‘exceeding 
the speed limit’ in Stats19) x (adjust to average population in 
Germany and UK (ACEA TF-ACC, 2017a), (ACEA TF-ACC, 
2017b)). 

None. 

None. 

164 

1 

1 

0.75 

2.00 

2.00 

1 

4.50 

1 

1 

0.75 

4.00 

4.00 

1 

4.50 

1 

1 

0.75 

4.00 

4.00 

1 

4.50 

0.0825 

0.0825 

0.0825 

0.0825 

0.0825 

0.0825 

0.025875 

0.020493 

0 

M1/N1: 
4.50x0.99 

M1/N1: 
4.50x1.18 

M1/N1: 
4.50x1.12 

M2&M3/N2&N3: 
4.50x1.64 

M2&M3/N2&N3: 
4.50x5.50 

M2&M3/N2&N3: 
4.50x4.50 

1 

1 

1 

1 

1 

1 

 
 
 
 
Measure 

Target population description for extract from police 
reported data 

Correction factors subsequently applied in order to … 

Correction factor 
fatal 

Correction factor 
serious 

Correction factor 
slight 

REV 

TPM 

VIS-DET 

VIS-DIV 

Pedestrian and cyclist casualties caused by a reversing motor 
vehicle. 

Casualties where illegal, defective or under-inflated tyres 
contributed to the collision.  

For N2&N3: Pedestrian and cyclist casualties in impacts with 
vehicle front or side. 

For M2&M3: Pedestrian and cyclist casualties in impacts with 
vehicle front or side where a vehicle blind spot contributed to 
the collision. 
Note: The narrower target population definition for buses and 
coaches is necessary to make meaningful effectiveness 
estimates, because the current direct vision of these vehicles is 
considerably better than that of trucks. 
For N2&N3: Pedestrian and cyclist casualties in impacts with 
vehicle front or side. 

For M2&M3: Pedestrian and cyclist casualties in impacts with 
vehicle front or side where a vehicle blind spot contributed to 
the collision. 
Note: The narrower target population definition for buses and 
coaches is necessary to make meaningful effectiveness 
estimates, because the current direct vision of these vehicles is 
considerably better than that of trucks. 

… (account for collisions that happen away from public roads 
and are therefore not included in official road casualty statistics 
(Seidl et al., 2017)) x (adjust to average population in France, 
Germany and UK (ACEA TF-ACC, 2017c)). 

… narrow the target population down to only those collisions 
where under-inflated tyres contributed (TRL expert panel 
estimate). 

M1/N1: 
2.00 

M1/N1: 
2.00 

M1/N1: 
2.00 

M2&M3/N2&N3: 
2.00x1.25 

M2&M3/N2&N3: 
2.00x1.08 

M2&M3/N2&N3: 
2.00x1.00 

0.25 

0.25 

0.25 

… adjust to average population in France, Germany and UK 
(ACEA TF-ACC, 2017d). 

0.80 

1.21 

1.33 

… adjust to average population in France, Germany and UK 
(ACEA TF-ACC, 2017d). 

0.80 

1.21 

1.33 

165 

 
 
 
 
 
 
 
Table 67: Target population descriptions for existing measures for all vehicle categories 

Measure 

Target population description for extract from police 
reported data 

Correction factors subsequently applied in order to … 

Correction factor 
fatal 

Correction factor 
serious 

Correction factor 
slight 

AEB-VEH 

Casualties in two-motor-vehicle (excluding powered two-
wheelers) front-to-rear collisions. 
Note: This is an existing measure for M2&M3 and N2&N3 
only. 

ESC 

Loss of control crashes. 

LDW 

Casualties in collisions on a dual-carriageway or motorway 
where the vehicle left the carriageway, or rear-impacted a 
vehicle on the hard shoulder, or side-swiped vehicle. 
Note: This is an existing measure for M2&M3 and N2&N3 
only. 

None. 

None. 

None. 

1 

1 

1 

1 

1 

1 

1 

1 

1 

166 

 
 
Annex 4.8.6 

Effectiveness 

Table 68: Effectiveness of proposed measures for M1 vehicles equipped 

Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

AEB-VEH 

19.0% 

19.0% 

19.0% 

19.0% 

42.0% 

High 

AEB-PCD 

24.4% 

24.4% 

21.0% 

21.0% 

42.1% 

High 

AEB-PCD 

27.5% 

27.5% 

16.4% 

16.4% 

32.8% 

High 

ALC 

4.2% 

0.0% 

4.2% 

0.0% 

4.2% 

Low 

(Seidl et al., 2017). Note: Powered-two wheelers were excluded from the target population, 
i.e. car/van-to-motorcycle collisions were considered not affected. Recent preliminary 
research showed that in reality a positive effect is to be expected (Lenkeit and Smith, 2016). 
The benefit estimates applied are therefore conservative. 

Effectiveness for pedestrians. (Seidl et al., 2017) for fatal and serious, expert panel estimate 
for slight. 

Effectiveness for cyclists. (Seidl et al., 2017) for fatal and serious, expert panel estimate for 
slight. 

TRL expert panel estimate. Assumption that this measure allows the continuation of alcohol 
interlock installation programmes for hard core drink drivers. 32.0% percent of the EU-28 
population live in countries where such programmes exist; (Elder et al., 2011) report that 
around 13% of relevant individuals take part in programmes, with programmes being highly 
effective while interlocks are installed. 

DDR-DAD 

16.7% 

0.0% 

16.7% 

0.0% 

16.7% 

Low 

(Seidl et al., 2017) 

DDR-ADR 

16.7% 

0.0% 

16.7% 

0.0% 

16.7% 

EDR 

ESS 

1.0% 

1.0% 

1.0% 

1.0% 

1.0% 

5.0% 

20.0% 

10.0% 

20.0% 

20.0% 

Low 

Low 

Low 

FFW-137 

0.0% 

5.0% 

0.0% 

5.0% 

0.0% 

High 

FFW-THO 

0.0% 

6.0% 

0.0% 

6.0% 

0.0% 

High 

HED-MGI 

0.0% 

77.0% 

0.0% 

48.0% 

0.0% 

High 

(Seidl et al., 2017). Same effectiveness assumed as for basic DDR-DAD systems, but 
applied to the extended target population for advanced distraction recognition.  

TRL expert panel estimate. Nominal number to reflect that there will be anon-zero positive 
effect for road safety from the possibility to learn from detailed collision records. 

TRL expert panel estimate. Based on the brake reaction time reductions, referenced in (Seidl 
et al., 2017), and resulting reductions in stopping distance and impact speed.  

(Seidl et al., 2017). Effectiveness of making vehicles that would comply with UN 
Regulation No. 94 (but not with UN Regulation No. 137) compliant with FFW-137. Note: 
Applied only to a small proportion of the vehicle fleet, which would not meet this 
requirement yet. 

(Seidl et al., 2017). Additional effectiveness of making vehicles that would comply with 
FFW-137 compliant with FFW-THO. 

Based on data collected during the course of the monitoring phase for headform-to-
windscreen tests in Pedestrian Safety Regulation (EC) No 78/2009. The value represents a 
head-to-glass impact test with a mandatory limit of HIC=1,000, which would reduce the 
mean result from HIC=727 (current monitoring data) to HIC=550 and result in a relative 
reduction in injury risk as indicated by the effectiveness values given.  Note: Applied only to 
the narrow corrected target population representing casualties who suffered serious head 
injuries from impact with the glazed area of the windscreen more than 10 centimetres away 
from the scuttle, A-pillars, and header rail. 

ISA-VOL 

19.0% 

6.7% 

19.0% 

8.4% 

19.0% 

High 

TRL calculations based on (Barrow et al., 2017) and (ACEA TF-ACC, 2017a). 

167 

 
Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

LKA-ELK 

53.0% 

0.0% 

38.5% 

0.0% 

38.5% 

High 

(Sternlund et al., 2017) and (Cicchino, 2017). For serious and slight casualties, an average 
value between the effectiveness values found by the two studies was used. For fatal 
casualties, the Sternlund value was used as a conservative estimate because the value found 
by Cicchino for fatalities (86%) was based on a very small sample of vehicles and therefore 
considered unreliable. Assumption that emergency-type LKA systems could not or would 
not be deactivated frequently by drivers. 

(Seidl et al., 2017) and (Billot et al., 2013) Note: Applied only to a small proportion of the 
vehicle fleet, which would not meet this requirement yet. 

0.0% 

54.0% 

0.0% 

54.0% 

0.0% 

High 

PSI 

REV 

41.0% 

0.0% 

41.0% 

0.0% 

41.0% 

High 

(Seidl et al., 2017). Effectiveness for camera-based system. 

Table 69: Effectiveness of existing measures for M1 vehicles equipped 

Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

ESC 

38.0% 

0.0% 

21.0% 

0.0% 

21.0% 

High 

(Høye, 2011) 

168 

 
 
 
 
Table 70: Effectiveness of proposed measures for M2&M3 vehicles equipped 

Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

ALC 

4.2% 

0.0% 

4.2% 

0.0% 

4.2% 

Low 

TRL expert panel estimate. Assumption that this measure allows the continuation of alcohol 
interlock installation programmes for hard core drink drivers. 32.0% percent of the EU-28 
population live in countries where such programmes exist; (Elder et al., 2011) report that 
around 13% of relevant individuals take part in programmes, with programmes being highly 
effective while interlocks are installed. 

DDR-DAD 

16.7% 

0.0% 

16.7% 

0.0% 

16.7% 

Low 

(Seidl et al., 2017) 

DDR-ADR 

16.7% 

0.0% 

16.7% 

0.0% 

16.7% 

ESS 

5.0% 

20.0% 

10.0% 

20.0% 

20.0% 

Low 

Low 

(Seidl et al., 2017). Same effectiveness assumed as for basic DDR-DAD systems, but 
applied to the extended target population for advanced distraction recognition.  

TRL expert panel estimate. Based on the brake reaction time reductions, referenced in (Seidl 
et al., 2017), and resulting reductions in stopping distance and impact speed.  

ISA-VOL 

8.9% 

9.1% 

1.3% 

16.8% 

19.9% 

High 

TRL calculations based on (Barrow et al., 2017) and (ACEA TF-ACC, 2017b) 

REV 

TPM 

33.3% 

0.0% 

33.3% 

0.0% 

33.3% 

Low 

TRL calculations based on (ACEA TF-ACC, 2017c). Effectiveness for camera-based 
system. 

33.3% 

0.0% 

33.3% 

0.0% 

33.3% 

Low 

TRL expert panel estimate. Note: Applied to narrow target population. 

VIS-DET 

39.7% 

0.0% 

40.0% 

0.0% 

40.0% 

Low 

VIS-DIV 

24.0% 

0.0% 

24.0% 

0.0% 

24.0% 

Low 

TRL calculations based on (Barrow et al., 2017) and (ACEA TF-ACC, 2017d). 
Effectiveness for front and side vulnerable road user detection and warning (no auto 
braking). Note: Applied to a considerably more narrowly defined target population than that 
for N2/N3. 
TRL calculations based on (Barrow et al., 2017) and (ACEA TF-ACC, 2017d). 
Effectiveness for best-in-class direct vision approach. Note: Applied to a considerably more 
narrowly defined target population than that for N2/N3. Note 2: The estimated balance 
between the effects of detection-warning systems and improved direct vision might shift in 
reality between the two measures. Human factors research indicates that drivers need visual 
confirmation of the reason for a warning to respond fully effectively to it (see US research 
for reversing camera rulemaking, (NHTSA, 2010)). Improvements in direct vision are 
therefore needed to realise the full benefits modelled for detection-warning systems. 

169 

 
 
Table 71: Effectiveness of existing measures for M2&M3 vehicles equipped 

Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

AEB-VEH 

0.0% 

25.0% 

0.0% 

25.0% 

5.0% 

Low 

(Robinson et al., 2010) 

ESC 

LDW 

28.5% 

0.0% 

28.5% 

0.0% 

28.5% 

High 

(NHTSA, 2015) 

20.0% 

0.0% 

20% 

0.0% 

20.0% 

Low 

(Robinson et al., 2010). Lower end of the prospective effectiveness estimates used to reflect 
the fact that LDW systems, as defined in UN Regulation No. 130, can be deactivated by 
drivers. 

170 

 
 
 
Table 72: Effectiveness of proposed measures for N1 vehicles equipped 

Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

AEB-VEH 

19.0% 

19.0% 

19.0% 

19.0% 

42.0% 

High 

(Seidl et al., 2017) 

AEB-PCD 

24.4% 

24.4% 

21.0% 

21.0% 

42.1% 

High 

AEB-PCD 

27.5% 

27.5% 

16.4% 

16.4% 

32.8% 

High 

ALC 

4.2% 

0.0% 

4.2% 

0.0% 

4.2% 

Low 

Effectiveness for pedestrians. (Seidl et al., 2017) for fatal and serious, expert panel estimate 
for slight. 

Effectiveness for cyclists. (Seidl et al., 2017) for fatal and serious, expert panel estimate for 
slight. 

TRL expert panel estimate. Assumption that this measure allows the continuation of alcohol 
interlock installation programmes for hard core drink drivers. 32.0% percent of the EU-28 
population live in countries where such programmes exist; (Elder et al., 2011) report that 
around 13% of relevant individuals take part in programmes, with programmes being highly 
effective while interlocks are installed. 

DDR-DAD 

16.7% 

0.0% 

16.7% 

0.0% 

16.7% 

Low 

(Seidl et al., 2017) 

DDR-ADR 

16.7% 

0.0% 

16.7% 

0.0% 

16.7% 

EDR 

ESS 

1.0% 

1.0% 

1.0% 

1.0% 

1.0% 

5.0% 

20.0% 

10.0% 

20.0% 

20.0% 

Low 

Low 

Low 

FFW-137 

0.0% 

5.0% 

0.0% 

5.0% 

0.0% 

High 

FFW-THO 

0.0% 

6.0% 

0.0% 

6.0% 

0.0% 

High 

HED-MGI 

0.0% 

77.0% 

0.0% 

48.0% 

0.0% 

Low 

(Seidl et al., 2017). Same effectiveness assumed as for basic DDR-DAD systems, but 
applied to the extended target population for advanced distraction recognition.  

TRL expert panel estimate. Nominal number to reflect that there will be anon-zero positive 
effect for road safety from the possibility to learn from detailed collision records. 

TRL expert panel estimate. Based on the brake reaction time reductions, referenced in (Seidl 
et al., 2017), and resulting reductions in stopping distance and impact speed.  

(Seidl et al., 2017). Effectiveness of making vehicles that would comply with UN 
Regulation No. 94 (but not with UN Regulation No. 137) compliant with FFW-137. Note: 
Applied only to a small proportion of the vehicle fleet, which would not meet this 
requirement yet. 

(Seidl et al., 2017). Additional effectiveness of making vehicles that would comply with 
FFW-137 compliant with FFW-THO. 

Based on data collected during the course of the monitoring phase for headform-to-
windscreen tests on cars in Pedestrian Safety Regulation (EC) No 78/2009 (therefore 
reduced confidence for vans). The value represents a head-to-glass impact test with a 
mandatory limit of HIC=1,000, which would reduce the mean result from HIC=727 (current 
monitoring data) to HIC=550 and result in a relative reduction in injury risk as indicated by 
the effectiveness values given.  Note: Applied only to the narrow corrected target population 
representing casualties who suffered serious head injuries from impact with the glazed area 
of the windscreen more than 10 centimetres away from the scuttle, A-pillars, and header rail. 

ISA-VOL 

19.0% 

6.7% 

19.0% 

8.4% 

19.0% 

High 

TRL calculations based on (Barrow et al., 2017) and (ACEA TF-ACC, 2017a). 

171 

 
Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

LKA-ELK 

53.0% 

0.0% 

38.5% 

0.0% 

38.5% 

High 

(Sternlund et al., 2017) and (Cicchino, 2017) (studies for M1 vehicles, best available 
evidence). For serious and slight casualties, an average value between the effectiveness 
values found by the two studies was used. For fatal casualties, the Sternlund value was used 
as a conservative estimate because the value found by Cicchino for fatalities (86%) was 
based on a very small sample of vehicles and therefore considered unreliable. Assumption 
that emergency-type LKA systems could not or would not be deactivated frequently by 
drivers. 

(Seidl et al., 2017) and (Billot et al., 2013) Note: Applied only to a small proportion of the 
vehicle fleet, which would not meet this requirement yet. 

PSI 

REV 

TPM 

0.0% 

54.0% 

0.0% 

54.0% 

0.0% 

High 

41.0% 

0.0% 

41.0% 

0.0% 

41.0% 

High 

(Seidl et al., 2017). Effectiveness for camera-based system. 

33.3% 

0.0% 

33.3% 

0.0% 

33.3% 

Low 

TRL expert panel estimate. Note: Applied to narrow target population. 

Table 73: Effectiveness of existing measures for N1 vehicles equipped 

Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

ESC 

38.0% 

0.0% 

21.0% 

0.0% 

21.0% 

High 

(Høye, 2011) 

172 

 
 
 
 
Table 74: Effectiveness of proposed measures for N2&N3 vehicles equipped 

Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

ALC 

4.2% 

0.0% 

4.2% 

0.0% 

4.2% 

Low 

TRL expert panel estimate. Assumption that this measure allows the continuation of alcohol 
interlock installation programmes for hard core drink drivers. 32.0% percent of the EU-28 
population live in countries where such programmes exist; (Elder et al., 2011) report that 
around 13% of relevant individuals take part in programmes, with programmes being highly 
effective while interlocks are installed. 

DDR-DAD 

16.7% 

0.0% 

16.7% 

0.0% 

16.7% 

Low 

(Seidl et al., 2017) 

DDR-ADR 

16.7% 

0.0% 

16.7% 

0.0% 

16.7% 

ESS 

5.0% 

20.0% 

10.0% 

20.0% 

20.0% 

Low 

Low 

(Seidl et al., 2017). Same effectiveness assumed as for basic DDR-DAD systems, but 
applied to the extended target population for advanced distraction recognition.  

TRL expert panel estimate. Based on the brake reaction time reductions, referenced in (Seidl 
et al., 2017), and resulting reductions in stopping distance and impact speed.  

ISA-VOL 

8.9% 

9.1% 

1.3% 

16.8% 

19.9% 

High 

TRL calculations based on (Barrow et al., 2017) and (ACEA TF-ACC, 2017b) 

REV 

TPM 

33.3% 

0.0% 

33.3% 

0.0% 

33.3% 

Low 

TRL calculations based on (ACEA TF-ACC, 2017c). Effectiveness for camera-based 
system. 

33.3% 

0.0% 

33.3% 

0.0% 

33.3% 

Low 

TRL expert panel estimate. Note: Applied to narrow target population. 

VIS-DET 

39.7% 

0.0% 

40.0% 

0.0% 

40.0% 

High 

VIS-DIV 

2.9% 

0.0% 

2.9% 

0.0% 

3.0% 

High 

(Barrow et al., 2017) and (ACEA TF-ACC, 2017d). Effectiveness for front and side 
vulnerable road user detection and warning (no auto braking). 

(Barrow et al., 2017) and (ACEA TF-ACC, 2017d). Effectiveness for best-in-class direct 
vision approach. Note: The estimated balance between the effects of detection-warning 
systems and improved direct vision might shift in reality between the two measures. Human 
factors research indicates that drivers need visual confirmation of the reason for a warning to 
respond fully effectively to it (see US research for reversing camera rulemaking, (NHTSA, 
2010)). Improvements in direct vision are therefore needed to realise the full benefits 
modelled for detection-warning systems. 

173 

 
 
Table 75: Effectiveness of existing measures for N2&N3 vehicles equipped 

Measure 

Fatal (avoid) 

Fatal 
(mitigate) 

Serious 
(avoid) 

Serious 
(mitigate) 

Slight (avoid) 

Confidence 

Source / justification 

AEB-VEH 

0.0% 

25.0% 

0.0% 

25.0% 

5.0% 

Low 

(Robinson et al., 2010) 

ESC 

LDW 

28.5% 

0.0% 

28.5% 

0.0% 

28.5% 

High 

(NHTSA, 2015) 

20.0% 

0.0% 

20% 

0.0% 

20.0% 

Low 

(Robinson et al., 2010). Lower end of the prospective effectiveness estimates used to reflect 
the fact that LDW systems, as defined in UN Regulation No. 130, can be deactivated by 
drivers. 

174 

 
 
Annex 4.8.7 

Costs 

Table 76: Initial cost at mandatory introduction of proposed measures for M1 vehicles. Cost estimate in € per vehicle equipped for the given 
year (subject to inflation). Estimated development and fixed production costs are included and spread equally across vehicles. 

Measure 

Cost (best 
estimate) 

Cost (lower 
estimate) 

Cost (upper 
estimate) 

in year 

Source / justification 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

€44 

€54 

€2 

€9 

DDR-ADR 

€110 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

€2 

€1 

€32 

€16 

€5 

€59 

€70 

€30 

€35 

€43 

€1 

€8 

€98 

€1 

€0 

€26 

€13 

€2 

€47 

€56 

€20 

€53 

€65 

€5 

€10 

€150 

€5 

€2 

€38 

€19 

€20 

€71 

€84 

€40 

2012 

2012 

2020 

(Seidl et al., 2017) under consideration of industry input. The cost reflects the apportioned share of the total cost for a 
system that shares sensor technology to deliver four measures: AEB-VEH, AEB-PCD, ISA-VOL and LKA-ELK.  

(Seidl et al., 2017) under consideration of industry input. The cost reflects the apportioned share of the total cost for a 
system that shares sensor technology to deliver four measures: AEB-VEH, AEB-PCD, ISA-VOL and LKA-ELK. 

(Seidl et al., 2017) under consideration of industry input. Cost of an alcohol interlock installation sheet. The cost for 
equipping any vehicles with alcohol interlocks, made possible by this measure would be carried by the drivers affected. 

2020 

(Seidl et al., 2017). Cost of a system based on existing sensors, such as steering wheel input. 

2020 

2020 

(Seidl et al., 2017) under consideration of industry input. Cost of a system based on driver-facing sensor hardware, such 
as camera. 

(Seidl et al., 2017) under consideration of industry input. Cost for a Part-563-type EDR. Equivalent hardware already 
available on most vehicles, but recordings are not readable. 

2020 

(Seidl et al., 2017). Nominal cost for software-based system (validation and testing). 

2008 

(Seidl et al., 2017). Cost for vehicles that comply with UN Regulation No. 94 but not with UN Regulation No. 137. 

2008 

2020 

2012 

2012 

2020 

(Seidl et al., 2017). Additional cost for vehicles that comply with UN Regulation No. 137 with Hybrid III ATDs but not 
with THOR-M ATDs. 

TRL expert panel estimate for cost of adapting the glazed area of windscreens to comply with a mandatory HIC limit in 
head-to-glass impact tests. Assumption that this cost is mostly made up of research and development efforts by glass 
suppliers, with only a small increase in ongoing production costs. 
(Seidl et al., 2017) under consideration of industry input. The cost reflects the apportioned share of the total cost for a 
system that shares sensor technology to deliver four measures: AEB-VEH, AEB-PCD, ISA-VOL and LKA-ELK. 
Additional cost added for actuators required. 
(Seidl et al., 2017) under consideration of industry input. The cost reflects the apportioned share of the total cost for a 
system that shares sensor technology to deliver four measures: AEB-VEH, AEB-PCD, ISA-VOL and LKA-ELK. 
Additional cost added for actuators required. 

TRL expert panel estimate under consideration of industry input for cost of making vehicle compliant with UN 
Regulation No. 135, which do not meet the requirements yet. 

175 

 
 
Measure 

Cost (best 
estimate) 

Cost (lower 
estimate) 

Cost (upper 
estimate) 

in year 

Source / justification 

REV 

€40 

€25 

€55 

2012 

(Seidl et al., 2017) under consideration of industry input. Cost of a camera-based system using an existing display.   

Table 77: Initial cost at mandatory introduction of proposed measures for M2&M3 vehicles. Cost estimate in € per vehicle equipped for the 
given year (subject to inflation). Estimated development and fixed production costs are included and spread equally across vehicles. 

Measure 

Cost (best 
estimate) 

Cost (lower 
estimate) 

Cost (upper 
estimate) 

in year 

Source / justification 

ALC 

DDR-DAD 

€4 

€20 

€2 

€10 

DDR-ADR 

€165 

€147 

ESS 

ISA-VOL 

REV 

TPM 

VIS-DET 

€2 

€110 

€125 

€52 

€300 

VIS-DIV 

€150 

€0 

€92 

€106 

€44 

€150 

€100 

€6 

€50 

€225 

€4 

€124 

€144 

€60 

€500 

2020 

2020 

2020 

(Seidl et al., 2017) under consideration of industry input provided for other heavy vehicles (N2&N3). Cost of an 
alcohol interlock installation sheet. The cost for equipping any vehicles with alcohol interlocks, made possible by this 
measure would be carried by the drivers affected. 

(Seidl et al., 2017) under consideration of industry input provided for other heavy vehicles (N2&N3). Cost of a system 
based on existing sensors, such as steering wheel input. 

(Seidl et al., 2017) under consideration of industry input provided for other heavy vehicles (N2&N3). Cost of a system 
based on driver-facing sensor hardware, such as camera. 

2020 

(Seidl et al., 2017). Nominal cost for software-based system (validation and testing). 

2012 

(Seidl et al., 2017) under consideration of industry input provided for other heavy vehicles (N2&N3). 

2012 

(Seidl et al., 2017). Cost of full system including camera and display.   

2013 

(van Zyl et al., 2013) and (Seidl et al., 2017). Cost of a direct TPM solution. 

2020 

TRL expert panel estimate under consideration of industry input provided for other heavy vehicles (N2&N3) and 
(Martin et al., 2017). Cost of front and side vulnerable road user detection and warning (no auto braking) 

€450 

2020 

TRL expert panel estimate under consideration of industry input provided for other heavy vehicles (N2&N3). Cost for 
best-in-class approach, i.e. adjustments of existing cabs. Requirement only applies to new types of vehicles, i.e. any 
cost incurred will partially be absorbed in cab re-design for new vehicle generation (no redesign cost for existing 
models). This is reflected in a cost estimate reflecting the lower end of estimates from industry input.    

176 

 
 
 
Table 78: Initial cost at mandatory introduction of proposed measures for N1 vehicles. Cost estimate in € per vehicle equipped for the given 
year (subject to inflation). Estimated development and fixed production costs are included and spread equally across vehicles. 

Measure 

Cost (best 
estimate) 

Cost (lower 
estimate) 

Cost (upper 
estimate) 

in year 

Source / justification 

AEB-VEH 

AEB-PCD 

ALC 

DDR-DAD 

€44 

€54 

€2 

€9 

DDR-ADR 

€110 

EDR 

ESS 

FFW-137 

FFW-THO 

HED-MGI 

ISA-VOL 

LKA-ELK 

PSI 

REV 

TPM 

€2 

€1 

€32 

€16 

€5 

€59 

€70 

€30 

€40 

€5 

€35 

€43 

€1 

€8 

€98 

€1 

€0 

€26 

€13 

€2 

€47 

€56 

€20 

€25 

€4 

€53 

€65 

€5 

€10 

€150 

€5 

€2 

38 

€19 

€20 

€71 

€84 

€40 

€55 

€10 

2012 

2012 

2020 

(Seidl et al., 2017) under consideration of industry input provided for other light vehicles (M1). The cost reflects the 
apportioned share of the total cost for a system that shares sensor technology to deliver four measures: AEB-VEH, 
AEB-PCD, ISA-VOL and LKA-ELK.  
(Seidl et al., 2017) under consideration of industry input provided for other light vehicles (M1). The cost reflects the 
apportioned share of the total cost for a system that shares sensor technology to deliver four measures: AEB-VEH, 
AEB-PCD, ISA-VOL and LKA-ELK. 
(Seidl et al., 2017) under consideration of industry input provided for other light vehicles (M1). Cost of an alcohol 
interlock installation sheet. The cost for equipping any vehicles with alcohol interlocks, made possible by this measure 
would be carried by the drivers affected. 

2020 

(Seidl et al., 2017). Cost of a system based on existing sensors, such as steering wheel input. 

2020 

2020 

(Seidl et al., 2017) under consideration of industry input provided for other light vehicles (M1). Cost of a system based 
on driver-facing sensor hardware, such as camera. 

(Seidl et al., 2017) under consideration of industry input provided for other light vehicles (M1). Cost for a Part-563-
type EDR. Equivalent hardware already available on most vehicles, but recordings are not readable. 

2020 

(Seidl et al., 2017). Nominal cost for software-based system (validation and testing). 

2008 

(Seidl et al., 2017). Cost for vehicles that comply with UN Regulation No. 94 but not with UN Regulation No. 137. 

2008 

2020 

2012 

2012 

2020 

2012 

2013 

(Seidl et al., 2017). Cost for vehicles that comply with UN Regulation No. 137 with Hybrid III ATDs but not with 
THOR-M ATDs. 

TRL expert panel estimate for cost of adapting the glazed area of windscreens to comply with a mandatory HIC limit in 
head-to-glass impact tests. Assumption that this cost is mostly made up of research and development efforts by glass 
suppliers, with only a small increase in ongoing production costs. 
(Seidl et al., 2017) under consideration of industry input provided for other light vehicles (M1). The cost reflects the 
apportioned share of the total cost for a system that shares sensor technology to deliver four measures: AEB-VEH, 
AEB-PCD, ISA-VOL and LKA-ELK. Additional cost added for actuators required. 
(Seidl et al., 2017) under consideration of industry input provided for other light vehicles (M1). The cost reflects the 
apportioned share of the total cost for a system that shares sensor technology to deliver four measures: AEB-VEH, 
AEB-PCD, ISA-VOL and LKA-ELK. Additional cost added for actuators required. 

TRL expert panel estimate under consideration of industry input, provided for other light vehicles (M1), for cost of 
making vehicle compliant with UN Regulation No. 135, which do not meet the requirements yet. 

(Seidl et al., 2017) under consideration of industry input provided for other light vehicles (M1). Cost of a camera-based 
system using an existing display.   

(van Zyl et al., 2013) and (Seidl et al., 2017). Cost of an indirect TPM solution fitted to vehicles with four wheels (no 
twin-wheels). 

177 

 
Table 79: Initial cost at mandatory introduction of proposed measures for N2&N3 vehicles. Cost estimate in € per vehicle equipped for the 
given year (subject to inflation). Estimated development and fixed production costs are included and spread equally across vehicles. 

Measure 

Cost (best 
estimate) 

Cost (lower 
estimate) 

Cost (upper 
estimate) 

in year 

Source / justification 

ALC 

DDR-DAD 

€4 

€20 

€2 

€10 

DDR-ADR 

€165 

€147 

ESS 

ISA-VOL 

REV 

TPM 

VIS-DET 

€2 

€110 

€150 

€66 

€300 

VIS-DIV 

€150 

€0 

€92 

€130 

€56 

€150 

€100 

€6 

€50 

€225 

€4 

€124 

€250 

€200 

€500 

2013 

2020 

€450 

2020 

2020 

2020 

2020 

(Seidl et al., 2017) under consideration of industry input. Cost of an alcohol interlock installation sheet. The cost for 
equipping any vehicles with alcohol interlocks, made possible by this measure would be carried by the drivers affected. 

(Seidl et al., 2017) under consideration of industry input. Cost of a system based on existing sensors, such as steering 
wheel input. 

(Seidl et al., 2017) under consideration of industry input. Cost of a system based on driver-facing sensor hardware, such 
as camera. 

2020 

(Seidl et al., 2017). Nominal cost for software-based system (validation and testing). 

2012 

(Seidl et al., 2017) under consideration of industry input. 

2012 

(Seidl et al., 2017) under consideration of industry input. Cost of full system including camera and display. 

(van Zyl et al., 2013) and (Seidl et al., 2017) under consideration of industry input. Cost of a direct TPM solution fitted 
to the towing vehicle only (no trailers). 

TRL expert panel estimate under consideration of industry input and (Martin et al., 2017). Cost of front and side 
vulnerable road user detection and warning (no auto braking) 

TRL expert panel estimate under consideration of industry input. Cost for best-in-class approach, i.e. adjustments of 
existing cabs. Requirement only applies to new types of vehicles, i.e. any cost incurred will partially be absorbed in cab 
re-design for new vehicle generation (no redesign cost for existing models). This is reflected in a cost estimate 
reflecting the lower end of estimates from industry input.    

178 

 
 
 
 
 
Annex 4.9

Appendices of results 

Annex 4.9.1 

Casualty baseline 

Table  80:  Casualty  baseline  (PO0,  reflecting  continued  dispersion  of  existing  mandatory  safety  measures  and  voluntary  uptake  of  safety 
measures), EU-28 casualties per annum  

Year 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

Best estimate 

Fatal casualties 

Serious casualties 

Slight casualties 

1,200,609 

1,197,141 

1,192,776 

1,187,341 

1,181,155 

1,174,802 

1,168,456 

1,162,231 

1,156,208 

1,150,094 

1,143,662 

1,137,101 

1,130,854 

1,125,625 

1,121,229 

1,117,078 

1,113,449 

1,110,322 

1,107,619 

1,105,474 

1,103,725 

25,245 

25,123 

25,012 

24,895 

24,759 

24,613 

24,459 

24,301 

24,141 

23,971 

23,788 

23,598 

23,408 

23,222 

23,044 

22,876 

22,721 

22,579 

22,451 

22,340 

22,243 

244,674 

244,081 

243,387 

242,524 

241,495 

240,377 

239,198 

237,992 

236,787 

235,549 

234,239 

232,874 

231,496 

230,197 

229,002 

227,873 

226,850 

225,930 

225,114 

224,434 

223,865 

179 

 
 
 
Annex 4.9.2 

Monetary benefits and costs 

Table  81:  Benefits  of  policy  option  PO1  compared  to  the  baseline  scenario  per  vehicle  category  per  year  (future  monetary  value,  best 
estimate) 

Benefits PO1 

M1 

M2&M3 

N1 

N2&N3 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

€ 0 

€ 3,652,196 

€ 0 

€ 854 

€ 0 

€ 210,718 

€ 0 

€ 966 

€ 151,296,385 

€ 35,500 

€ 9,203,539 

€ 37,192 

€ 545,168,688 

€ 133,426 

€ 34,170,855 

€ 145,379 

€ 1,000,898,311 

€ 255,849 

€ 64,560,479 

€ 285,993 

€ 1,400,107,873 

€ 371,047 

€ 91,097,341 

€ 415,470 

€ 1,771,664,008 

€ 483,150 

€ 114,072,703 

€ 533,452 

€ 2,118,023,710 

€ 592,081 

€ 134,088,757 

€ 641,286 

€ 2,445,305,073 

€ 697,999 

€ 151,755,745 

€ 740,125 

€ 2,757,870,573 

€ 801,080 

€ 167,505,333 

€ 830,859 

€ 3,037,253,906 

€ 897,348 

€ 181,520,552 

€ 914,852 

€ 3,273,637,576 

€ 983,998 

€ 194,450,377 

€ 994,352 

€ 3,480,530,155 

€ 1,062,392 

€ 206,230,741 

€ 1,070,533 

€ 3,661,231,359 

€ 1,132,949 

€ 216,896,377 

€ 1,143,570 

€ 3,818,311,956 

€ 1,196,280 

€ 226,553,732 

€ 1,213,646 

€ 3,964,331,864 

€ 1,254,962 

€ 235,592,427 

€ 1,279,173 

€ 4,104,957,655 

€ 1,311,279 

€ 239,408,474 

€ 1,338,221 

180 

 
 
 
Table 82: Costs of policy option PO1 compared to the baseline scenario per vehicle category per year (future monetary value, best estimate) 

Costs 
PO1 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

M2&M3 

N1 

N2&N3 

€ 0 

€ 0 

€ 0 

€ 0 

€ 20,851,089 

€ 3,029 

€ 2,052,932 

€ 22,887 

€ 666,628,005 

€ 103,749 

€ 69,015,529 

€ 832,924 

€ 1,096,450,305 

€ 181,071 

€ 120,557,163 

€ 1,541,724 

€ 962,402,461 

€ 174,006 

€ 112,143,632 

€ 1,568,627 

€ 950,204,101 

€ 175,225 

€ 104,096,560 

€ 1,521,154 

€ 932,402,875 

€ 176,448 

€ 96,273,637 

€ 1,476,343 

€ 918,897,205 

€ 177,609 

€ 89,786,569 

€ 1,433,454 

€ 914,885,110 

€ 178,677 

€ 85,032,330 

€ 1,392,087 

€ 920,097,355 

€ 179,638 

€ 81,758,624 

€ 1,352,020 

€ 866,858,578 

€ 171,522 

€ 78,805,841 

€ 1,361,456 

€ 821,028,128 

€ 163,679 

€ 76,508,761 

€ 1,369,900 

€ 779,785,286 

€ 156,099 

€ 74,590,851 

€ 1,377,368 

€ 741,519,077 

€ 148,771 

€ 72,890,548 

€ 1,383,888 

€ 705,351,992 

€ 141,687 

€ 71,318,764 

€ 1,389,492 

€ 706,705,939 

€ 142,780 

€ 70,636,578 

€ 1,337,121 

€ 707,857,856 

€ 143,761 

€ 69,974,289 

€ 1,286,365 

181 

 
 
Table  83:  Benefits  of  policy  option  PO2  compared  to  the  baseline  scenario  per  vehicle  category  per  year  (future  monetary  value,  best 
estimate) 

Benefits PO2 

M1 

M2&M3 

N1 

N2&N3 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

€ 0 

€ 0 

€ 0 

€ 0 

€ 5,043,429 

€ 58,327 

€ 236,837 

€ 241,474 

€ 210,270,736 

€ 2,634,930 

€ 10,319,870 

€ 11,365,243 

€ 754,955,557 

€ 9,825,649 

€ 38,416,358 

€ 43,208,350 

€ 1,406,209,021 

€ 18,777,585 

€ 74,799,102 

€ 84,051,066 

€ 2,033,698,335 

€ 27,228,953 

€ 109,948,213 

€ 122,090,314 

€ 2,648,095,042 

€ 35,336,633 

€ 140,958,380 

€ 156,508,065 

€ 3,219,130,259 

€ 43,067,457 

€ 166,751,229 

€ 187,606,327 

€ 3,753,286,844 

€ 50,597,095 

€ 188,508,110 

€ 215,851,332 

€ 4,259,317,555 

€ 58,111,280 

€ 207,158,331 

€ 243,081,828 

€ 4,706,545,364 

€ 65,333,713 

€ 223,294,324 

€ 268,235,450 

€ 5,078,380,771 

€ 71,876,058 

€ 238,184,903 

€ 292,288,513 

€ 5,396,376,447 

€ 77,630,018 

€ 251,521,779 

€ 315,504,968 

€ 5,667,224,301 

€ 82,575,411 

€ 263,388,500 

€ 337,632,315 

€ 5,896,416,783 

€ 86,758,175 

€ 274,092,181 

€ 358,724,627 

€ 6,103,661,312 

€ 90,376,170 

€ 284,143,468 

€ 378,248,366 

€ 6,297,613,219 

€ 93,562,470 

€ 288,550,553 

€ 395,547,577 

182 

 
 
Table 84: Costs of policy option PO2 compared to the baseline scenario per vehicle category per year (future monetary value, best estimate) 

Costs 
PO2 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

M2&M3 

N1 

N2&N3 

€ 0 

€ 0 

€ 0 

€ 0 

€ 36,608,027 

€ 294,132 

€ 2,187,630 

€ 2,222,375 

€ 1,173,837,465 

€ 10,287,194 

€ 73,476,170 

€ 82,588,682 

€ 1,946,885,861 

€ 17,869,262 

€ 129,257,128 

€ 152,147,319 

€ 1,831,696,972 

€ 17,226,074 

€ 149,251,181 

€ 155,289,935 

€ 1,968,686,605 

€ 17,424,317 

€ 170,685,530 

€ 151,263,075 

€ 1,970,382,148 

€ 17,351,814 

€ 161,024,412 

€ 145,183,480 

€ 1,981,486,293 

€ 17,535,211 

€ 153,190,295 

€ 141,524,065 

€ 2,004,601,027 

€ 18,181,667 

€ 147,380,027 

€ 141,654,506 

€ 2,037,673,215 

€ 19,354,195 

€ 143,213,366 

€ 145,666,632 

€ 1,932,164,962 

€ 19,538,819 

€ 138,927,979 

€ 155,089,405 

€ 1,836,698,195 

€ 19,240,903 

€ 135,370,212 

€ 161,035,027 

€ 1,747,920,951 

€ 18,583,567 

€ 132,240,431 

€ 163,975,882 

€ 1,663,929,128 

€ 17,829,579 

€ 129,364,756 

€ 165,853,663 

€ 1,583,675,055 

€ 16,977,921 

€ 126,647,479 

€ 166,498,652 

€ 1,587,193,701 

€ 17,107,512 

€ 125,473,959 

€ 160,209,742 

€ 1,590,033,775 

€ 17,224,227 

€ 124,317,325 

€ 154,121,562 

183 

 
 
Table  85:  Benefits  of  policy  option  PO3  compared  to  the  baseline  scenario  per  vehicle  category  per  year  (future  monetary  value,  best 
estimate) 

Benefits PO3 

M1 

M2&M3 

N1 

N2&N3 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

€ 0 

€ 0 

€ 0 

€ 0 

€ 5,296,049 

€ 64,080 

€ 267,361 

€ 262,633 

€ 220,849,893 

€ 2,896,213 

€ 11,704,789 

€ 12,375,282 

€ 794,090,313 

€ 10,806,181 

€ 43,611,477 

€ 47,111,746 

€ 1,496,571,707 

€ 20,826,921 

€ 87,490,526 

€ 93,633,844 

€ 2,204,354,042 

€ 30,619,015 

€ 134,640,508 

€ 140,563,460 

€ 2,910,930,151 

€ 40,181,364 

€ 178,777,729 

€ 184,717,893 

€ 3,568,592,789 

€ 49,310,690 

€ 216,127,851 

€ 224,526,483 

€ 4,183,755,428 

€ 58,182,496 

€ 248,035,142 

€ 260,548,408 

€ 4,765,255,593 

€ 66,984,433 

€ 275,546,462 

€ 294,681,257 

€ 5,277,941,509 

€ 75,393,916 

€ 299,305,818 

€ 326,140,295 

€ 5,703,014,983 

€ 82,991,402 

€ 320,661,884 

€ 355,962,675 

€ 6,064,831,386 

€ 89,687,075 

€ 339,457,416 

€ 384,478,601 

€ 6,371,420,680 

€ 95,468,181 

€ 355,889,709 

€ 411,581,971 

€ 6,629,391,751 

€ 100,391,933 

€ 370,396,600 

€ 437,312,718 

€ 6,861,170,981 

€ 104,689,595 

€ 383,714,462 

€ 461,074,546 

€ 7,076,868,299 

€ 108,522,074 

€ 390,972,196 

€ 482,050,865 

184 

 
 
Table 86: Costs of policy option PO3 compared to the baseline scenario per vehicle category per year (future monetary value, best estimate) 

Costs 
PO3 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

M2&M3 

N1 

N2&N3 

€ 0 

€ 0 

€ 0 

€ 0 

€ 42,192,710 

€ 423,552 

€ 5,964,756 

€ 3,415,339 

€ 1,353,540,595 

€ 14,823,967 

€ 205,725,210 

€ 127,023,221 

€ 2,261,052,623 

€ 25,820,055 

€ 364,708,363 

€ 234,596,848 

€ 2,672,896,381 

€ 28,071,684 

€ 454,925,311 

€ 268,124,075 

€ 3,435,357,794 

€ 31,645,012 

€ 549,369,467 

€ 289,349,543 

€ 3,492,303,600 

€ 31,685,993 

€ 535,330,457 

€ 279,335,838 

€ 3,555,792,162 

€ 31,971,352 

€ 523,206,307 

€ 271,847,808 

€ 3,628,433,359 

€ 32,708,691 

€ 513,156,649 

€ 268,252,408 

€ 3,708,222,578 

€ 33,961,455 

€ 504,782,127 

€ 268,638,814 

€ 3,527,235,174 

€ 33,487,203 

€ 493,196,216 

€ 278,929,380 

€ 3,358,790,944 

€ 32,552,048 

€ 482,490,434 

€ 285,648,055 

€ 3,199,454,280 

€ 31,278,482 

€ 472,359,156 

€ 289,270,906 

€ 3,047,245,254 

€ 29,928,662 

€ 462,624,055 

€ 291,743,199 

€ 2,901,045,223 

€ 28,500,980 

€ 453,185,807 

€ 292,898,673 

€ 2,907,900,432 

€ 28,719,539 

€ 449,132,708 

€ 281,846,047 

€ 2,913,320,014 

€ 28,916,012 

€ 445,068,893 

€ 271,140,899 

185 

 
 
 
 
Annex 4.9.3 

Casualties prevented 

Table  87:  Fatal  casualties  prevented  across  EU-28  by  safety  measures  of  policy  option  PO1  compared  to  the  baseline  scenario  per  vehicle 
category per year (best estimate) 

Fatal casualties 
PO1 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

1 

47 

172 

321 

457 

589 

717 

843 

969 

1,087 

1,195 

1,295 

1,390 

1,479 

1,567 

1,656 

M2&M3 

N1 

N2&N3 

0 

0 

3 

11 

21 

30 

38 

47 

53 

61 

67 

73 

79 

84 

90 

96 

99 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

1 

0 

0 

1 

0 

186 

 
 
Table 88: Serious casualties prevented across EU-28 by safety measures of policy option PO1 compared to the baseline scenario per vehicle 
category per year (best estimate) 

Serious casualties 
PO1 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

5 

205 

757 

1,423 

2,041 

2,648 

3,245 

3,837 

4,431 

4,995 

5,509 

5,995 

6,454 

6,886 

7,314 

7,748 

N1 

0 

0 

13 

51 

98 

141 

180 

217 

251 

285 

315 

348 

379 

408 

437 

466 

485 

N2&N3 

0 

0 

0 

1 

1 

2 

2 

2 

3 

3 

4 

4 

4 

4 

5 

6 

6 

M2&M3 

0 

0 

1 

0 

0 

1 

2 

2 

1 

2 

3 

3 

3 

3 

4 

4 

4 

187 

 
 
Table 89: Slight casualties prevented across EU-28 by safety measures of policy option PO1 compared to the baseline scenario per vehicle 
category per year (best estimate) 

Slight casualties 
PO1 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

20 

836 

3,107 

5,883 

8,491 

11,103 

13,718 

16,359 

19,051 

21,650 

24,051 

26,323 

28,482 

30,533 

32,569 

34,639 

N1 

0 

1 

36 

138 

267 

386 

498 

601 

697 

790 

878 

961 

1,042 

1,120 

1,196 

1,273 

1,324 

N2&N3 

0 

0 

0 

2 

4 

5 

7 

8 

9 

10 

12 

13 

15 

16 

18 

18 

20 

M2&M3 

0 

0 

0 

1 

2 

4 

4 

5 

7 

8 

8 

10 

11 

12 

13 

14 

14 

188 

 
 
Table  90:  Fatal  casualties  prevented  across  EU-28  by  safety  measures  of  policy  option  PO2  compared  to  the  baseline  scenario  per  vehicle 
category per year (best estimate) 

Fatal casualties 
PO2 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

1 

65 

237 

446 

651 

855 

1,054 

1,245 

1,434 

1,608 

1,762 

1,903 

2,032 

2,150 

2,263 

2,375 

M2&M3 

N1 

N2&N3 

0 

0 

4 

12 

24 

35 

46 

56 

64 

72 

80 

86 

94 

99 

105 

112 

116 

0 

0 

5 

17 

34 

51 

67 

82 

98 

112 

127 

141 

155 

171 

185 

199 

214 

0 

0 

0 

2 

4 

5 

8 

10 

11 

14 

16 

18 

20 

22 

24 

26 

27 

189 

 
 
Table 91: Serious casualties prevented across EU-28 by safety measures of policy option PO2 compared to the baseline scenario per vehicle 
category per year (best estimate) 

Serious casualties 
PO2 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

7 

294 

1,084 

2,089 

3,149 

4,260 

5,355 

6,441 

7,530 

8,562 

9,497 

10,371 

11,186 

11,948 

12,695 

13,445 

N1 

0 

0 

14 

57 

115 

175 

231 

280 

323 

362 

397 

435 

471 

505 

538 

571 

594 

N2&N3 

0 

0 

11 

45 

87 

128 

165 

197 

229 

264 

298 

330 

362 

395 

428 

460 

489 

M2&M3 

0 

1 

6 

21 

41 

61 

81 

101 

120 

141 

162 

181 

199 

215 

231 

245 

258 

190 

 
 
Table 92: Slight casualties prevented across EU-28 by safety measures of policy option PO2 compared to the baseline scenario per vehicle 
category per year (best estimate) 

Slight casualties 
PO2 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

25 

1,064 

3,946 

7,580 

11,275 

15,125 

18,971 

22,849 

26,801 

30,610 

34,120 

37,430 

40,561 

43,525 

46,454 

49,420 

N1 

0 

1 

43 

165 

332 

509 

682 

837 

979 

1,111 

1,235 

1,350 

1,459 

1,563 

1,664 

1,766 

1,840 

N2&N3 

0 

0 

26 

101 

202 

301 

398 

490 

580 

667 

753 

839 

927 

1,013 

1,100 

1,185 

1,267 

M2&M3 

0 

0 

18 

67 

131 

195 

257 

319 

382 

446 

509 

568 

620 

668 

710 

748 

783 

191 

 
 
Table  93:  Fatal  casualties  prevented  across  EU-28  by  safety  measures  of  policy  option  PO3  compared  to  the  baseline  scenario  per  vehicle 
category per year (best estimate) 

Fatal casualties 
PO3 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

1 

66 

242 

460 

680 

902 

1,118 

1,325 

1,529 

1,716 

1,880 

2,030 

2,166 

2,290 

2,408 

2,524 

M2&M3 

N1 

N2&N3 

0 

0 

4 

13 

27 

42 

56 

70 

81 

93 

103 

112 

121 

129 

137 

145 

150 

0 

0 

5 

18 

37 

58 

78 

96 

115 

132 

149 

166 

184 

202 

219 

236 

252 

0 

0 

0 

2 

4 

6 

9 

11 

13 

15 

17 

20 

22 

24 

26 

28 

30 

192 

 
 
Table 94: Serious casualties prevented across EU-28 by safety measures of policy option PO3 compared to the baseline scenario per vehicle 
category per year (best estimate) 

Serious casualties 
PO3 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

8 

320 

1,180 

2,306 

3,553 

4,887 

6,204 

7,513 

8,822 

10,061 

11,182 

12,225 

13,195 

14,097 

14,978 

15,859 

N1 

0 

1 

17 

67 

138 

221 

301 

373 

436 

495 

548 

602 

653 

701 

746 

792 

826 

N2&N3 

0 

0 

13 

50 

100 

153 

205 

250 

295 

342 

387 

431 

474 

517 

561 

603 

642 

M2&M3 

0 

1 

7 

23 

46 

70 

93 

117 

140 

165 

189 

212 

233 

252 

270 

288 

304 

193 

 
 
Table 95: Slight casualties prevented across EU-28 by safety measures of policy option PO3 compared to the baseline scenario per vehicle 
category per year (best estimate) 

Slight casualties 
PO3 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

2036 

2037 

M1 

0 

28 

1,173 

4,360 

8,514 

13,002 

17,798 

22,597 

27,435 

32,359 

37,099 

41,454 

45,548 

49,410 

53,053 

56,645 

60,272 

N1 

0 

2 

52 

201 

420 

682 

953 

1,203 

1,436 

1,657 

1,866 

2,061 

2,248 

2,426 

2,599 

2,771 

2,909 

N2&N3 

0 

1 

28 

111 

231 

367 

507 

641 

771 

897 

1,020 

1,143 

1,267 

1,390 

1,514 

1,635 

1,751 

M2&M3 

0 

0 

19 

73 

146 

227 

310 

393 

478 

563 

647 

726 

798 

863 

923 

978 

1,030 

194 

 
 
 
 
Annex 4.9.4 

Sensitivity analysis 

Figure  51:  Passenger  cars  (M1):  Present  monetary  value  of  benefits  of  M1  safety  measures  over  entire  evaluation  period  2021–2037 
compared to the baseline scenario (range of results found in interval and scenario analysis) 

195 

 
 
 
 
Figure  52:  Passenger  cars  (M1):  Present  value  of  costs  of  M1  safety  measures  over  entire  evaluation  period  2021–2037  compared  to  the 
baseline scenario (range of results found in interval and scenario analysis) 

196 

 
 
Figure 53: Buses and coaches (M2&M3): Present monetary value of benefits of M2&M3 safety measures over entire evaluation period 2021–
2037 compared to the baseline scenario (range of results found in interval and scenario analysis) 

197 

 
 
 
Figure  54:  Buses  and  coaches  (M2&M3):  Present  value  of  costs  of  M2&M3  safety  measures  over  entire  evaluation  period  2021–2037 
compared to the baseline scenario (range of results found in interval and scenario analysis) 

198 

 
 
 
Figure 55: Vans (N1): Present monetary value of benefits of N1 safety measures over entire evaluation period 2021–2037 compared to the 
baseline scenario (range of results found in interval and scenario analysis) 

199 

 
 
 
Figure  56:  Vans  (N1):  Present  value  of  costs  of  N1  safety  measures  over  entire  evaluation  period  2021–2037  compared  to  the  baseline 
scenario (range of results found in interval and scenario analysis) 

200 

 
 
 
Figure  57:  Trucks  (N2&N3):  Present  monetary  value  of  benefits  of  N2&N3  safety  measures  over  entire  evaluation  period  2021–2037 
compared to the baseline scenario (range of results found in interval and scenario analysis) 

201 

 
 
 
Figure  58:  Trucks  (N2&N3):  Present  value  of  costs  of  N2&N3  safety  measures  over  entire  evaluation  period  2021–2037  compared  to  the 
baseline scenario (range of results found in interval and scenario analysis) 

202 

 
 
 
ANNEX 5 – FLOW CHART FOR VEHICLE GROUPS WITH FOCUS ON THE ROAD ACCIDENT VICTIM’S PERSPECTIVE 

203 

LDV = Light Duty VehicleHDV = Heavy Duty VehicleAccident scenario = in which the occupants of or persons around the respecive LDVs and HDVs are involved Occurance = accidents occuring in the real-worldAccident type = FI Frontal Impact, RI Rear Impact, SI Side Impact, F-LVRU Front impact LDV with VRU,R-LVRU Rear Impact LDV with VRU, F-HVRU Front impact HDV with VRU, S-HVRU Side impact HDV with VRU, R-HVRU Rear Impact HDV with VRUHighest risk = for persons in and around the accident vehicle or N/S if Not SignificantAdditional risk = of fire and/or electrocution of occupants, bystanders and rescue workersLDVAccident scenarioOccuranceAccident typeHighest riskAdditional riskRemaining focus areasWhile driving forward: Collision front-side with approaching vehiclecommon ----------------------------------FILDVYesFI-LDVincludingPost crash fire and electric safetyCollision front-side with vehicle moving awaycommon ----------------------------------FILDVYesCollision front-side with still-standing vehicle or obstaclecommon ----------------------------------FILDVYesCollision front-side with vulnerable road usercommon --------------------------------------F-LVRUVRUF-LVRUCollision rear-side with approaching vehiclecommon --------------------------------------RILDVYesRI-LDVincludingPost crash fire and electric safetyCollision rear-side with vehicle moving awayimpossibleCollision rear-side with still-standing vehicle or obstacleimpossibleCollision rear-side with vulnerable road user impossibleCollision side-of-vehicle with approaching vehiclecommon --------------------------------------SILDVYesSI-LDVincludingPost crash fire and electric safetyCollision side-of-vehicle with vehicle moving away impossibleCollision side-of-vehicle with still-standing vehicle or obstacle common --------------------------------------SILDVYesCollision side-of-vehicle with vulnerable road usernot commonWhile driving rearward: Collision front-side with approaching vehiclenot commonCollision front-side with vehicle moving awayimpossibleCollision front-side with still-standing vehicle or obstacleimpossibleCollision front-side with vulnerable road userimpossibleCollision rear-side with approaching vehiclenot commonCollision rear-side with vehicle moving awayimpossibleCollision rear-side with still-standing vehicle or obstaclecommon --------------------------------------RILDVYesCollision rear-side with vulnerable road usercommon --------------------------------------R-LVRUVRUR-LVRUCollision side-of-vehicle with approaching vehiclecommon --------------------------------------RILDVYesCollision side-of-vehicle with vehicle moving awayimpossibleCollision side-of-vehicle with still-standing vehicle or obstacle not commonCollision side-of-vehicle with vulnerable road user not commonfront-siderear-sideside-of-vehicle 
 
204 

While turning: Collision front-side with approaching vehiclecommon ----------------------------------FILDVYesCollision front-side with vehicle moving awaynot commonCollision front-side with still-standing vehicle or obstaclecommon ----------------------------------FILDVYesCollision front-side with vulnerable road usercommon --------------------------------------F-LVRUVRUCollision rear-side with approaching vehiclecommon --------------------------------------RILDVYesCollision rear-side with vehicle moving awayimpossibleCollision rear-side with still-standing vehicle or obstacleimpossibleCollision rear-side with vulnerable road user impossibleCollision side-of-vehicle with approaching vehicle common --------------------------------------SILDVYesCollision side-of-vehicle with vehicle moving awayimpossibleCollision side-of-vehicle with still-standing vehicle or obstaclenot commonCollision side-of-vehicle with vulnerable road usernot commonWhile at a standstill: Collision front-side with approaching vehiclecommon ----------------------------------FILDVYesCollision front-side with vehicle moving awayimpossibleCollision front-side with still-standing vehicle or obstacleimpossibleCollision front-side with vulnerable road userimpossibleCollision rear-side with approaching vehiclecommon --------------------------------------RILDVYesCollision rear-side with vehicle moving awayimpossibleCollision rear-side with still-standing vehicle or obstacleimpossibleCollision rear-side with vulnerable road user not commonCollision side-of-vehicle with approaching vehicle common --------------------------------------SILDVYesCollision side-of-vehicle with vehicle moving away impossibleCollision side-of-vehicle with still-standing vehicle or obstacleimpossibleCollision side-of-vehicle with vulnerable road usernot commonHDV While driving forward: Collision front-side with approaching vehiclecommon ----------------------------------FIHDVYesFI-HDVincludingPost crash fire and electric safetyCollision front-side with vehicle moving awaycommon ----------------------------------FIHDVYesCollision front-side with still-standing vehicle or obstaclecommon ----------------------------------FIHDVYesCollision front-side with vulnerable road usercommon --------------------------------------F-HVRUVRUF-HVRUCollision rear-side with approaching vehiclecommon --------------------------------------RIHDVYesRI-HDVincludingPost crash fire and electric safetyCollision rear-side with vehicle moving awayimpossibleCollision rear-side with still-standing vehicle or obstacleimpossibleCollision rear-side with vulnerable road user impossibleCollision side-of-vehicle with approaching vehiclecommon --------------------------------------SIN/SCollision side-of-vehicle with vehicle moving away impossibleCollision side-of-vehicle with still-standing vehicle or obstacle not commonCollision side-of-vehicle with vulnerable road usernot common 
 
205 

While driving rearward: Collision front-side with approaching vehiclenot commonCollision front-side with vehicle moving awayimpossibleCollision front-side with still-standing vehicle or obstacleimpossibleCollision front-side with vulnerable road userimpossibleCollision rear-side with approaching vehiclenot commonCollision rear-side with vehicle moving awayimpossibleCollision rear-side with still-standing vehicle or obstaclecommon --------------------------------------RIN/SCollision rear-side with vulnerable road usercommon --------------------------------------R-HVRUVRUR-HVRUCollision side-of-vehicle with approaching vehiclecommon --------------------------------------SIN/SCollision side-of-vehicle with vehicle moving awayimpossibleCollision side-of-vehicle with still-standing vehicle or obstacle not commonCollision side-of-vehicle with vulnerable road user not commonWhile turning: Collision front-side with approaching vehiclecommon ----------------------------------FIHDVYesCollision front-side with vehicle moving awaynot commonCollision front-side with still-standing vehicle or obstaclecommon ----------------------------------FIN/SCollision front-side with vulnerable road usercommon --------------------------------------F-HVRUVRUCollision rear-side with approaching vehiclecommon --------------------------------------RIHDVYesCollision rear-side with vehicle moving awayimpossibleCollision rear-side with still-standing vehicle or obstacleimpossibleCollision rear-side with vulnerable road user impossibleCollision side-of-vehicle with approaching vehicle common --------------------------------------SIN/SCollision side-of-vehicle with vehicle moving awayimpossibleCollision side-of-vehicle with still-standing vehicle or obstaclenot commonCollision side-of-vehicle with vulnerable road usercommon --------------------------------------S-HVRUVRUS-HVRUWhile at a standstill: Collision front-side with approaching vehiclecommon ----------------------------------FIN/SCollision front-side with vehicle moving awayimpossibleCollision front-side with still-standing vehicle or obstacleimpossibleCollision front-side with vulnerable road userimpossibleCollision rear-side with approaching vehiclecommon --------------------------------------RIHDVYesCollision rear-side with vehicle moving awayimpossibleCollision rear-side with still-standing vehicle or obstacleimpossibleCollision rear-side with vulnerable road user not commonCollision side-of-vehicle with approaching vehicle common --------------------------------------SIN/SCollision side-of-vehicle with vehicle moving away impossibleCollision side-of-vehicle with still-standing vehicle or obstacleimpossibleCollision side-of-vehicle with vulnerable road usernot common 
 
 
The following main accident types are derived from the flow chart above: 

  FI-LDV – Frontal Impact Light Duty Vehicle 

o  This  means either passenger cars, SUVs, pick-ups,  vans  or  other  light commercial 
vehicles that are involved in a crash where the front-side of the vehicle is crushed. 
Although there are numerous crash configurations possible, the persons at risk here 
are in principle the vehicle’s occupants that are generally subjected to very similar 
dynamics among the different crash configurations, where high deceleration forces 
and  high  external  forces  are  exerted  on  the  occupants,  leading  to  internal  and 
external trauma. 

  Victims are the occupants of the light duty motor-vehicle. 
  Scope for improvement of mitigation though crash testing representing real-
world crash scenarios with injury measuring dummies. [Remove exemptions, 
introduce full-width crash test] 

  Scope  for  introduction  of  frontal  crash  avoidance  technologies.  [AEBS  and 

LKA] 

  Scope  for  introduction  of  further  crash  injury  mitigation  technologies. 

[Catch all] 

o  As a result of a crash, the vehicle in question could catch fire due to ruptured fuel 
system or compromised propulsion battery integrity in case of an electric or hybrid-
electric  vehicle.  Additionally,  such  accidented  vehicles  can  further  have  exposed 
high-voltage components that may electrocute persons coming into direct or indirect 
contact with them. 

  Victims  are  the  occupants  of  the  light  duty  motor-vehicle,  bystanders  and 

rescue workers. 

  Scope for improvement of mitigation through crash testing representing real-
world  crash  scenarios  with  post-crash  fire  risk  and/or  electrical  risk 
checking. [Remove exemptions, introduce full-width crash test] 

  SI-LDV – Side Impact Light Duty Vehicle 

o  This means light duty motor-vehicles as above, involved in a crash where the side of 
the  vehicle  is  crushed.  There  are  a  few  crash  configurations  possible  and  in  each 
case  the  principle  persons  at  risk  are  the  occupants  that  are  generally  subjected  to 
high  deceleration  forces  and  high  external  forces,  leading  to  internal  and  external 
trauma. 

  Victims are the occupants of the light duty motor-vehicle. 
  Scope for improvement of mitigation though crash testing representing real-
world crash scenarios with injury measuring dummies. [Remove exemptions, 
introduce pole side-impact test] 

  No  scope  for  improvement  of  side  crash  avoidance  technologies.  [ESC, 

already rolled out] 

o  As a result of a crash, the vehicle in question could catch fire due to ruptured fuel 
system or compromised propulsion battery integrity in case of an electric or hybrid-
electric  vehicle.  Additionally,  such  accidented  vehicles  can  further  have  exposed 
high-voltage components that may electrocute persons coming into direct or indirect 
contact with them. 

  Victims  are  the  occupants  of  the  light  duty  motor-vehicle,  bystanders  and 

rescue workers. 

  Scope for improvement of mitigation through crash testing representing real-
world  crash  scenarios  with  post-crash  fire  risk  and/or  electrical  risk 
checking. [Remove exemptions, introduce pole side-impact test] 

206 

 
 
 
  RI-LDV – Rear Impact Light Duty Vehicle 

o  This means light duty motor-vehicles as above, involved in a crash where the rear-
side of the vehicle is crushed. There are a few crash configurations possible and in 
each  case  the  principle  persons  at  risk  are  the  occupants.  However,  the  issue  is 
rarely  a  matter  of  high deceleration  forces  or  high  external  forces,  but  notably  the 
risk of whiplash in low-speed accidents and the risk of fire due to the traditional and 
conventional placement of the fuel tank at the rear of the vehicle. 
  Victims are the occupants of the light duty motor-vehicle. 
  No  scope  for  improvement  of  mitigation  though  crash  testing  representing 
real-world  crash  scenarios  with  injury  measuring  dummies.  [This  will  fall 
under  the  Baseline  Scenario  option,  as  the  relevant  UNECE  regulation  17 
on seat and head restraint testing in process of being updated] 

  No  scope  for  introduction  of  rear  crash  avoidance  technologies.  [Does  not 

make sense / does not exist] 

o  As a result of a crash, the vehicle in question could catch fire due to ruptured fuel 
system or compromised propulsion battery integrity in case of an electric or hybrid-
electric  vehicle.  Additionally,  such  accidented  vehicles  can  further  have  exposed 
high-voltage components that may electrocute persons coming into direct or indirect 
contact with them. 

  Victims  are  the  occupants  of  the  light  duty  motor-vehicle,  bystanders  and 

rescue workers. 

  Scope for improvement of mitigation through crash testing representing real-
world  crash  scenarios  with  post-crash  fire  risk  and/or  electrical  risk 
checking. [Introduce rear impact crash test] 

  F-LVRU – Front-side of Light duty vehicle impacting Vulnerable Road User 

o  This  means  light  duty  motor-vehicles  as  above,  involved  in  a  collision  with  a 
pedestrian or cyclists onto the front of the vehicle. In the initial phase the pedestrian 
or  cyclist  is  struck  by  the  front  of  the  vehicle,  generally  leading  to  leg  and  hip 
injuries,  and  subsequently  the  head  of  the  person  strikes  the  bonnet,  wiper  scuttle 
panel, windscreen or windscreen frame, by which head trauma is sustained. 

  Victims are pedestrians and cyclists outside the light duty motor-vehicle. 
  Scope for improvement of mitigation though crash testing representing real-
world  crash  scenarios  with  injury  measuring  devices  for  the  two  distinct 
injury  modes.  [Extension  of  the  front-of-vehicle  testing  zone  for  head 
impacts] 

  Scope  for  introduction  of  pedestrian  and  cyclist  frontal  crash  avoidance 

technologies. [AEBS] 

  Scope  for  introduction  of  further  crash  injury  mitigation  technologies. 

[Catch all] 

  R-LVRU – Rear-side of Light duty vehicle impacting Vulnerable Road User  

o  This means light duty motor-vehicles as above, involved in a collision with a person 
onto the rear of the vehicle, most commonly when the motor-vehicle in question is 
reversing out of the parked position. The person is struck by the rear of the vehicle 
that generally leads to the person to fall, either being partly or fully run-over by the 
motor-vehicle  or  sustaining  injuries  through  impact  with  head  or  other  body  parts 
onto the ground. 

  Victims are pedestrians and cyclists outside the light duty motor-vehicle. 

207 

 
 
 
  No  scope  for  introduction  of  mitigation  though  crash  testing  representing 
real-world crash scenarios with injury measuring dummies or devices. [Does 
not make sense / does not exist] 

  Scope  for  introduction  of  pedestrian  and  cyclist  rearward  crash  avoidance 

technologies. [Introduce rear view camera or detection] 

  FI-HDV – Front Impact Heavy Duty Vehicle 

o  This means either trucks, with or without their trailers, or buses that are involved in 
a crash where the front-side of the vehicle is crushed. Although there are numerous 
crash  configurations  possible,  the  occupants  are  subjected  to  similar  dynamics 
among the different crash configurations, subject to deceleration forces and external 
forces  being  exerted  on  the  occupants.  If  the  collision  occurs  with  a  light  duty 
vehicle, an occurrence that is generally more common than with another heavy duty 
vehicle,  the  occupants  in  the  light  duty  vehicle  will  have  a  much  higher  risk  of 
injuries than those in the heavy duty vehicle. These instances are however covered 
by the relevant main accident type FI-LDV above. 

  Victims are the occupants of the heavy duty motor-vehicle. 
  No  scope  for  improvement  of  mitigation  though  crash  testing  representing 
real-world  crash  scenarios  with  injury  measuring  dummies.  [This  will  fall 
under  the  Baseline  Scenario  option,  as  the  relevant  UNECE  regulation  29 
on cab strength has recently been introduced in GSR]. 

  Scope  for  improvement  of  mitigating  effects  intended  for  the  common 
collision partner, light duty vehicles. [This will fall under the Self-Regulation 
option,  as  Directive  2015/719/EU  promotes  fuel  efficient  elongated  cabs 
voluntary  uptake  that  needs  modified  and  improved  Front  Underrun 
Protection device] 

  No  scope  for  improvement  of  frontal  crash  avoidance  technologies.  [AEBS 

and LDWS have recently been introduced in GSR] 

  Scope  for  introduction  of  further  crash  injury  mitigation  technologies. 

[Catch all] 

o  As a result of a crash, generally speaking when it concerns a bus rather than a truck 
as according to available accident statistics there is a much lower risk for the latter, 
the vehicle could catch fire due to ruptured fuel system or compromised propulsion 
battery integrity in case of an electric or hybrid-electric vehicle. Additionally, such 
accidented  vehicles  can  further  have  exposed  high-voltage  components  that  may 
electrocute persons coming into direct or indirect contact with them. 

  Victims  are the occupants  of the heavy duty  motor-vehicle, bystanders and 

rescue workers. 

  Scope for improvement of mitigation through fire risks measures. [This will 
fall under the Baseline Scenario option, as the relevant UNECE regulations 
107 and 118 are improved or in process of being updated] 

  No  scope  for  improvement  of  mitigation  through  electrical  risk  checking. 
[This  will  fall  under  the  Baseline  Scenario  option,  as  the  relevant  UNECE 
regulation 100 is in process of being updated] 

  RI-HDV – Rear Impact Heavy Duty Vehicle 

o  This means heavy duty motor-vehicles as above, involved in a crash where the rear-
side of the vehicle is crushed. There are a few crash configurations possible, but it is 
not likely there is a major injury risk for the occupants of the heavy duty vehicle. In 
principle, occupants of a light duty motor-vehicle being the other party involved in 

208 

 
 
 
the accident, as already covered by the relevant main accident type FI-LDV above, 
would bear nearly the full risk of sustaining injuries when they occur. 

  No victims in the heavy duty motor-vehicle. 
  Scope  for  improvement  of  mitigating  effects  intended  for  the  common 
collision  partner,  light  duty  vehicles.  [This  will  fall  under  the  Baseline 
Scenario  option,  as  the  relevant  UNECE  regulation  58  is  improved  or  in 
process of being updated] 

  No scope for improvement of rear crash avoidance technologies. [Does not 

make sense / does not exist] 

o  As a result of a crash, generally speaking a bus in question could catch fire due to 
ruptured  fuel  system  or  compromised  propulsion  battery  integrity  in  case  of  an 
electric or hybrid-electric vehicle, as such systems are in principle not found on the 
rear of truck or trailers. Where applicable, such accidented vehicles can further have 
exposed  high-voltage  components  that  may  electrocute  persons  coming  into  direct 
or indirect contact with them. 

  Victims  are the occupants  of the heavy duty  motor-vehicle, bystanders and 

rescue workers. 

  Scope for improvement of mitigation through fire risks measures. [This will 
fall under the Baseline Scenario option, as the relevant UNECE regulations 
107 and 118 are improved or in process of being updated] 

  No  scope  for  improvement  of  mitigation  through  electrical  risk  checking. 
[This  will  fall  under  the  Baseline  Scenario  option,  as  the  relevant  UNECE 
regulation 100 is in process of being updated] 

  F-HVRU – Front-side of Heavy duty vehicle impacting Vulnerable Road User  

o  This  means  heavy  duty  motor-vehicles  as  above,  involved  in  a  collision  with  a 
pedestrian or cyclists with the front of the vehicle. In the initial phase the pedestrian 
or  cyclist is struck by the front of the vehicle  that can lead to  overall injuries, but 
subsequently there is a risk of the person of being run over. 

  Victims are pedestrians and cyclists outside the heavy duty motor-vehicle or 

vehicle combination. 

  No  scope  for  introduction  of  mitigation  though  crash  testing  representing 
real-world  crash  scenarios  with  injury  measuring  devices.  [Does  not  make 
sense / does not exist] 

  Scope  for  introduction  of  pedestrian  and  cyclist  frontal  crash  avoidance 
technologies.  [Introduction  of  detection  systems  and  introduction  of  direct 
visibility requirements. No scope for updating AEBS for trucks/buses as this 
measure has just been introduced by GSR] 

  S-HVRU – Side-of-vehicle of Heavy duty vehicle impacting Vulnerable Road User 

o  This  means  heavy  duty  motor-vehicles  as  above,  involved  in  a  collision  with  a 
pedestrian  or  cyclists  with  the  side  of  the  vehicle,  notably  when  the  vehicle  or 
vehicle combination is turning. In the initial phase the pedestrian or cyclist is struck 
by  the  front  or  side  corner  of  the  vehicle,  that  can  lead  to  overall  injuries,  but 
subsequently there is a risk of the person of being run over, even to the extent of the 
rear wheels of the vehicle, given the relatively high ground clearance in relation to a 
person that is knocked down onto the road. 

  Victims are pedestrians and cyclists outside the heavy duty motor-vehicle or 

vehicle combination. 

209 

 
 
 
  No  scope  for  introduction  of  mitigation  though  crash  testing  representing 
real-world  crash  scenarios  with  injury  measuring  devices.  [Does  not  make 
sense / does not exist] 

  Scope for introduction of pedestrian and cyclist side or frontal-towards-side 
crash  avoidance  technologies.  [Introduction  of  detection  systems  and 
introduction  of  direct  visibility  requirements.  No  scope  for  updating  AEBS 
for trucks/buses as this measure has just been introduced by GSR] 

  R-HVRU – Rear-side of Heavy duty vehicle impacting Vulnerable Road User 

o  This  means  heavy  duty  motor-vehicles  as  above,  involved  in  a  collision  with  a 
person  onto  the  rear  of  the  vehicle,  most  commonly  when  the  motor-vehicle  in 
question is reversing out of the parked position. The person is struck by the rear of 
the vehicle that generally leads to the person to fall, either being partly or fully run-
over  by  the  vehicle  or  vehicle  combination  or  sustaining  injuries  through  impact 
with head or other body parts onto the ground. 

  Victims are pedestrians and cyclists outside the heavy duty motor-vehicle. 
  No  scope  for  introduction  of  mitigation  though  crash  testing  representing 
real-world crash scenarios with injury measuring dummies or devices. [Does 
not make sense / does not exist] 

  Scope  for  introduction  of  pedestrian  and  cyclist  rearward  crash  avoidance 

technologies. [Introduce rear view camera or detection] 

210 

 
 
 
 
 
ANNEX 6 – IN DEPTH INFORMATION ON VARIOUS ASPECTS IN THE MAIN DOCUMENT 

1. Vehicle safety legislation – General Safety Regulation 

As  part  of  the  vehicle  type-approval  framework,  general  vehicle  safety  in  the  EU  is  in  turn 
covered  by  a  de  facto  sub-framework  within  the  main  framework.  General  vehicle  safety  is 
regulated through a single act, namely Regulation (EC) No 661/2009163 as adopted by the co-
legislator, covering a large number of safety measures. The main objectives of the GSR were 
adding new technologies and safety features to vehicles as standard equipment, simplification 
by repealing old Directives and to primarily replace them by UNECE164 regulations. For other 
political reasons at the time, the GSR also achieved environmental benefits in that vehicle tyres 
became  more  energy  efficient  and  quieter  and  it  also  introduced  gear-shift  indicators  to  help 
drivers  save  fuel  and  cut  vehicle  emissions  by  optimising  the  engine  speed  under  specific 
driving  conditions.  Apart  from  the  last  mentioned  (minor)  items,  the  GSR  covers  all  vehicle 
safety  aspects  such  as  stability  control  systems,  braking  performance,  crashworthiness,  safety 
belts,  child  seat  safety,  electric  powertrain  protection,  lighting  installation,  electro-magnetic 
resistance, fuel system fire safety, head restraints, tyre safety and numerous additional items. 

Upon the introduction  of the GSR new vehicle types,  that  were granted a new whole  vehicle 
type-approval, have been required to be fitted with stability control systems since 1 November 
2011. Mandatory compliance followed for nearly the full package of measures covered by the 
GSR and for all new vehicle types, as per 1 November 2012. The suite of requirements had to 
be applied for all vehicles sold in the EU to the general public (not just new ‘types’ of vehicle) 
from  1  November  2014,  save  for  the  mandatory  fitment  of  advanced  emergency  braking  and 
lane departure warning systems on all trucks and buses which came into force one year later. 
Also,  the  protection  of  occupants  in  truck  cabs  in  case  of  a  crash  was  introduced  on  a 
mandatory basis for new types of trucks from 30 January 2017 and will be required for all new 
trucks sold in the EU as from 30 January 2021. Finally, several specific requirements covering 
tyre safety, noise and rolling resistance are still being phased-in until 1 May 2023. 

This  can  be  best  explained  by  for  instance  the  introduction  of  stability  control  systems,  as 
regulated in the original GSR, for which our estimates of technology adoption in the past time 
have been based on data and other information provided by the vehicle industry and supplier 
industry,  as  validated  through  several  wide  and  transparent  stakeholder  consultation  sessions 
from  2014  onwards.  In  this  case,  manufactures  had  to  make  this  safety  feature  available  by 
November 2011 on all new vehicle types introduced on the market with all new vehicles sold 
having  to  comply  before  2014.  This  had  the  effect  of  first  boosting  the  up-to-then  voluntary 
fitment from a plateau at around 80% in 2008 and 2009 up to 100% by 2014. However, even 
with  full  fitment  in  new  vehicles,  it  still  takes  time  for  those  vehicles  to  replace  existing 
vehicles  on  the  road.  This  explains  the  lag  in  the  vehicle  fleet  dispersion  where  an  effective 
near 100% fitment will be reached at a much later stage. 

Even  though  the  current  time-lapse  does  not  allow  carrying  out  a  full  ex  post  evaluation,  the 
effectiveness  and  fleet  penetration  of  the  previous  measures  is  taken  into  account  for  the  in 
depth  analysis  the  effectiveness  of  the  new  vehicle  safety  measures  proposed  in  this  Impact 

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

164   United Nations Economic Commission for Europe – World Forum for the harmonization of vehicle regulations 

(WP.29)  

211 

 
                                                 
Assessment. This is based on the initial information on effectiveness165 with further data taken 
from  other  available  and  referenced  sources  (e.g.  international  studies)  as  part  of  the 
preparatory  work  for  this  Impact  Assessment  in  which  this  approach  was  requested  and 
validated  by  the  stakeholders.  In  reality  a  casualty  can  only  be  prevented  once  and  therefore 
this was addressed in the analysis model by removing casualties prevented by a given existing 
measure, such as stability control, from the subsequent target population of the other measures. 
This  approach  was  also  fully  endorsed  through  extensive  stakeholder  consultations  on  this 
matter. 

2. Vehicle safety legislation – Pedestrian Safety Regulation 

Regulation  (EC)  No  78/2009166  aims  to  protect  pedestrians  and  other  vulnerable  road  users 
involved in a collision with a vehicle. It requires cars, vans and other light commercial vehicles 
to be fitted with energy absorbing bonnets and front bumpers, to cushion the head and legs of a 
pedestrian.  These  features  are  also  expected  to  protect  cyclists  when  an  accident  occurs 
between a motor-vehicle and such vulnerable road user. It further requires manufacturers to fit 
so-called  ‘brake  assist  systems’  into  their  vehicles.  These  systems  anticipate  in  a  matter  of 
milliseconds whether a driver is going to perform an emergency stop instead of normal gradual 
braking, and in those emergency circumstances apply the brakes beyond the level called for by 
the driver. This intervention can shave-off valuable fractions of the final impact speed as well 
as centimetres of the stopping distance, all helping to reduce the severity of the vulnerable road 
user’s injuries167. 

Although moped and motorcycle riders are also often referred to as vulnerable road users, they 
are  not  included  as  such  for  the  purpose  of  this  Impact  Assessment.  There  is  a  considerable 
variation in the Member States in the distribution of moped and  motorcycle fatalities by area 
and  road  type  and  the  most  frequently  recorded  specific  critical  event  for  riders  is  surplus 
speed,  described  as  speed  that  is  too  high  for  the  conditions  or  manoeuvre  being  carried  out, 
very much in contrast to pedestrians and cyclists168. Although this group should be taken into 
account  wherever  practicable,  specific  measures  to  address  their  safety169  are  deemed  more 
appropriate outside of the regulatory framework impacted by this initiative. 

The  energy  absorbing  capability  of  bonnets  and  front  bumpers  already  existed  in  European 
vehicles  since  mandatory  vulnerable  road  user  protection  requirements  were  introduced  in 
Directive  2003/102/EC170  .  This  legislation  followed  a  failed  attempt  to  self-regulate  through 
the  negotiated  voluntary  agreement  in  2001  between  the  European  Commission  and  the 

165   COM(2008) 316 
166   Regulation (EC) No 78/2009 of the European Parliament and of the Council of 14 January 2009 on the type-
approval of motor vehicles with regard to the protection of pedestrians and other vulnerable road users, 
amending Directive 2007/46/EC and repealing Directives 2003/102/EC and 2005/66/EC (Text with EEA 
relevance), OJ L 35, 4.2.2009, p. 1 

167   COM(2007)560 final 
168   https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/bfs2016_ 

motomoped.pdf 

169   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) 
and 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) 

170   Directive 2003/102/EC of the European Parliament and of the Council of 17 November 2003 relating to the 
protection of pedestrians and other vulnerable road users before and in the event of a collision with a motor 
vehicle and amending Council Directive 70/156/EEC, OJ L 321, 6.12.2003, p. 15 

212 

 
 
                                                 
European  Automobile  Manufacturers’  Association  (ACEA)171.  Over  the  course  of  many 
following  years,  the  relevant  mandatory  safety  provisions  have  been  implemented  on  most 
passenger  cars,  vans  and  light  commercial  vehicles,  and  will  be  fully  implemented  on  24 
August 2019, when the full set of requirements become mandatory on all new cars sold in the 
EU, notably by finally including heavy passenger cars such as SUVs that were exempted from 
pedestrian protection structural design requirements before this time. 

In this case, there is also the matter of time it will still take before vehicles compliant with this 
safety aspect are completely dispersed within the EU fleet, meaning no  ex post  effectiveness 
analysis could yet be carried out.  

3. Impact of additional safety measures on vehicle prices and sales prices 

Analysis  has  shown  that  cars  have  become  cheaper  in  real  terms  in  every  year  of  the  last 
reported  decade,  see  Table  6  in  section  6.3.3,  despite  this  being  a  period  in  which  technical 
development to meet new and more demanding environmental and safety standards increased, 
for example: 

  Directive 98/69/EC and Regulation (EC) No 715/2007 

Euro 4 and Euro 5 emissions standards applicable from 2005 and 2009, respectively. 

  Regulation (EC) No 443/2009 

Mandatory  average  fleet  CO2  emissions  limits  with  mandatory  compliance  limits 
applying  from  2012.  The  average  CO2  emissions  of  the  new  vehicle  fleet  sold  by  a 
manufacturer  could  not  be  reduced  in  a  step  change  from  one  year  to  the  next.  Hence, 
manufacturers confirmed to have started around 2007, in preparation for the announced 
legislation, to introduce technologies that significantly reduced CO2 emissions, in  order 
to be able to meet the compliance limits in 2012. This can be concluded from the average 
rate of progress in CO2 reduction, which accelerated considerably after 2007, compared 
to  the  long  term  trend  before172.  Considerable  investments  in  this  regard  therefore  fall 
within the period of retail price decreases cited above. 

  Directives 96/79/EC and 96/27/EC 

Compliance  with  frontal  impact  and  side  impact  crash  tests  for  all  new  cars  sold  from 
October 2003. 

  Regulation (EC) No 661/2009 (General Safety Regulation) 

Mandatory  electronic  stability  control  (ESC)  applicable  from  November  2011,  tyre 
pressure  monitoring  systems  (TPMS),  safety  belt  reminder  (SBR),  ISOFIX  child  seat 
connectors, gear shift indicators,  et cetera, applicable from November 2012 for all new 
passenger car EU market introductions. 

  Directive 2003/102/EC  

Compliance with pedestrian protection provisions, energy absorbing bumper and bonnet 
from October 2005 for new passenger car EU market introductions. 

  Regulation (EC) No 78/2009 (Pedestrian Safety Regulation)  

Anti-lock braking system (ABS) with brake assist system (BAS) applicable from October 
2009 for all new passenger car EU market introductions. 

171   Commission Communication (COM(2001) 389 final) regarding the voluntary agreement on safer car fronts 

with the European car industry (ACEA)  

172   https://www.transportenvironment.org/sites/te/files/media/2011_09_car_company_co2_report_final.pdf  

213 

 
 
                                                 
A 2011 study commissioned by Directorate-General for Climate Action, analysed the effect of 
emissions  and  safety  regulations  and  standards on  vehicle  prices173.  The  study  concluded  that 
historical vehicle price data and fitment status of certain features did not provide any definitive 
relationship between emissions standards and car prices. Overall, cars had become 12% to 22% 
cheaper (after inflation) in the study period of 2002 to 2010. The study found that, while there 
was certainly costs associated for the vehicle manufacturers to comply with the environmental 
and safety legislation during that period, these costs were largely offset by cost reductions from 
economies of scale and improved productivity, because the competition in the market made it 
difficult to pass on cost increases to consumers. Stakeholders interviewed for the study argued 
that without the additional legislation, car prices would have fallen even further in that period. 
Nevertheless, it is evident that regulatory requirements have not stopped the trend of car retail 
prices decreasing, because compliance costs for emissions and safety standards are only one of 
the many complex factors influencing vehicle retail prices. 

A report published by the European Federation for Transport and Environment (T&E) in 2011 
also  looked  into  the  aspect  of  potential  vehicle  price  increases  specifically  due  to  CO2 
emissions regulations and, looking back, compared the predicted influence on retail price with 
actual figures174. The authors came to a similar conclusion as the DG CLIMA study:  that car 
retail prices were influenced by a complex set of factors, with compliance costs being only one 
of them, and that concerns over cars becoming unaffordable due to CO2 emissions regulations 
had been unfounded. 

The past experience with CO2 emissions legislation also allows comparing predicted additional 
costs with predicted and actual retail price increases: In a 2006 study prepared for the European 
Commission,  the  researchers  from  TNO  had  estimated  the  future  costs  to  manufacturers  of 
reaching the required average CO2 targets to be an additional € 832 per car in 2008, compared 
to  a  year-2002  baseline.  This  was  expected  by  the  authors  to  translate  to  an  additional  retail 
price of € 1 200 per car in 2008, again compared to 2002. In reality however, cars have become 
approximately 10% cheaper (after inflation) between 2002 and 2008, which equates to a price 
reduction of € 2 000 for a € 20 000 model.  

These  figures  show  that,  bearing  in  mind  the  scale  of  investment  required  to  meet  emissions 
requirements,  coupled  with  the  costs  of  the  other  aspects  cited  above,  the  costs  to  vehicle 
manufacturers related to the fitment of new safety measures in the present Impact Assessment 
are not considered to be orders of magnitude different in scale than past predictions which did 
not translate to retail price increases.  

Interpreting the general price  trend and the conclusions  from the cited studies  on compliance 
costs,  it  may  be  concluded  that  vehicle  manufacturers  in  the  past  have  found  strategies  and 
practices  to  balance  production  costs  and  regulatory  compliance.  This  has  been  for  example, 
via  increases  in  production  efficiency,  or  accepted  temporarily  reduced  profit  margins  to  at 
least partially offset any cost increase, because the competitive nature of the vehicle market did 
not allow substantial retail price increases. 

Past evidence suggests that requiring additional equipment for CO2 emission standards, which 
was  estimated  at  a  cost  higher  than  the  present  estimates  for  the  full  set  of  proposed  vehicle 
safety  measures,  did  not  cause  an  increase  in  retail  prices.  Substantial  increases  in  vehicle 
prices  due  to  the  proposed  new  vehicle  safety  measures  in  the  medium  and  long  term  are 

173   https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/cars/docs/report_effect_2011_en.pdf 
174   https://www.transportenvironment.org/sites/te/files/media/2011_09_car_company_co2_report_final.pdf 

214 

 
                                                 
therefore not expected and consequently no extraordinary impact on vehicle sales numbers was 
modelled for the cost-benefit analysis. 

In  order  to  understand  how  new  safety  measures  could  affect  demand  for  vehicles  it  is 
important to observe on one side, how consumers perceive safety measures in vehicles, and on 
the other side, to which extend the additional cost of safety measures affects the final price of 
vehicles.  

Academic literature has developed a large literature based on hedonic techniques: differentiated 
goods are valued by consumers for their utility-bearing attributes.  

Berry  et.  al  (1995)  pioneered  in  this  field,  assuming  demand  in  the  automobile  sector  is  not 
homogenous and differs according to the product characteristics.175 The authors find different 
demand  elasticities  (how  demand  changes  facing  a  variation  in  another  variable  i.e.:  price, 
safety level) for different measure and different vehicle models. In other words, all consumers 
do  not  value  vehicle  (safety)  measures  equally.  This  depends,  on  one  side,  on  consumer’s 
characteristics (such as income or family size) and on the other side on vehicle characteristics 
(Berry et al.2004).   
The results of the research help to characterise demand elasticity. Literature shows that increase 
in safety measures reduces considerably elasticity. In other words, for a given vehicle price, it 
is  likely  that  consumers  can  tolerate  better  larger  price  changes  if  car’s  safety  equipment  is 
higher176  (alternatively,  for  a  given  price,  consumers'  demand  would  react  further  to  a  price 
variation when safety equipment is lower).  

Other  stylised  facts  from  research  show  that  demand  differs  depending  on  vehicle  models. 
Research conducted by Berry et al. seems to indicate that, increasing safety measures by 10% 
while  keeping  the  same  price  in  case  of  low  safety  level  vehicles  models177  increases  the 
demand by 13%, the corresponding increase in vehicles models with already high safety level 
produces only 1.7% increase in demand. 

What these results seem to indicate is that probably, consumers value safety differently, valuing 
it more (larger marginal utility) when vehicles have lower safety standards.  
On  the  other  hand,  price  elasticity  seem  to  be  higher  for  consumers  of  popular  vehicle 
segments, while consumers of less crowded vehicle segments seem to cope better with a price 
increase. 
The final drop in vehicle sales volumes will depend on the net effect. Lower decreases in sales 
volumes  could  result  from  increased  perceived  value  of  safety  features  by  consumers  which 
offsets  any  price  increases.  What  literature  seems  to  point  is  that,  depending  on  the  safety 
standards of the vehicle and the vehicle segment, these effects will be different. 

References 

Andersson, H. “The value of safety as revealed in the Swedish car market: an application of the hedonic pricing 
approach”, The journal of Risk Uncertainty, 2005, 211-239. 

175   The empirical analysis is done using data for the American automobile market.  
176   Interestingly enough, the paper also analyses elasticity of other vehicle’s characteristics.  For instance, we 

observe that sport cars have lower elasticities than other vehicles. This means that for a given vehicle price, 
consumers wanting to buy sport cars will tend to react to a lower extend to a price change , due in large part to 
the “sport” characteristic of the vehicle.  

177   Authors considered Vehicle size as a proxy for safety. 

215 

 
 
 
 
 
 
                                                 
Berry,  S.,  and  Levinsohn,  J.,  and  Pakes,  A.  “Automobile  Prices  in  Market  Equilibrium”,  Econometrica,  Vol.63, 
No.4 (Jul., 1995), 841-890 

Berry, S., and Levinsohn, J., and Pakes, A. Differenciated Products Demand Systems from a combination of Micro 
and Macri Data: The New Car Market”, Journal of Political Economy, 2004, 112, no.1 

Ehrlich,  I.,  and  Becker,  G.S.  “Market  Insurance,  Self-Insurance,  and  Self-Protection“,  Journal  of  Political 
Economy, 1972, 80, 623-648 

Peltzman, S. “The effects of automobile safety regulation”, Journal of Political Economy, 1975, 83(4), 677-725. 

4. Impact of advanced safety measures on driver perception and behaviour 

Research has studied how governmental intervention influences valuation of safety features on 
the  car  market.  Ehriclk  and  Becker  (1972)  discuss  in  their  theoretical  paper  the  influence  of 
different  safety  measures  such  as:  market  accident  insurance,  “self-insurance”  (i.e.  wearing 
seat-belt), and “self-protection” (e.g.: reduction by the driver of the probability of an accident 
through  cautious,  slower  driving).  Interaction  of  these  measures  seems  to  be  different.  While 
market insurance and self-insurance act as substitutes, self-insurance seems to discourage self-
protection  (i.e.  drivers  wearing  seat  belts  are  likely  to  drive  faster  and  careless).  Therefore, 
policies  aiming  to  increase  traffic  safety  through  self-insurance  (i.e.:  new  safety  measures) 
could discourage self-protection (i.e.: driver behaviour). 

Peltzman  (1975)  also  analysed  the  response  to  safety  regulation  in  the  American  automobile 
market.  His  hypothesis  complements  those  of  Ehriclk  and  Becker.  If  government  introduces 
higher safety  levels  than  the  ones  perceived  optimal  by  consumers,  drivers  might  respond  by 
reducing their self-protection, i.e.: driving faster. 

While  optimality  is  a  subjective  perception  (as  discussed  above  in  section  3  of  this  Annex  – 
utility  of  safety  measures  depends  on  consumer’s  characteristics  and  vehicle  characteristics), 
one could discuss to which extent optimality is partly influenced by a “crowd effect” and how 
familiar the driver is with the safety measures. Safety measures which are not yet mature in the 
market could be perceived as not optimal by consumers, who could then not use them if they do 
not perceive them as optimal. 

References 

Ehrlich,  I.,  and  Becker,  G.S.  “Market  Insurance,  Self-Insurance,  and  Self-Protection“,  Journal  of  Political 
Economy, 1972, 80, 623-648 

Peltzman, S. “The effects of automobile safety regulation”, Journal of Political Economy, 1975, 83(4), 677-725. 

216 

 
 
 
 
 
 
ANNEX 7 – EUROPEAN PARLIAMENT RESOLUTION ON COMMISSION REPORT  

European Parliament 
2014-2019 

TEXTS ADOPTED 
Provisional edition 

P8_TA-PROV(2017)0423  

Saving lives: Boosting car safety in the EU  

European Parliament resolution of 14 November 2017 on saving lives: boosting car safety in 
the EU (2017/2085(INI))  

The European Parliament, 

– 

– 

– 

– 

– 

having regard to the Commission report entitled ‘Saving Lives: Boosting Car Safety in the 
EU – Reporting on the monitoring and assessment of advanced vehicle safety features, 
their cost effectiveness and feasibility for the review of the regulations on general vehicle 
safety and on the protection of pedestrians and other vulnerable road users’ 
(COM(2016)0787) and to the accompanying Commission staff working document 
(SWD(2016)0431), 

having regard to Regulation (EC) No 661/2009 of the European Parliament and of the 
Council of 13 July 2009 concerning type-approval requirements for the general safety of 
motor vehicles, their trailers and systems, components and separate technical units 
intended therefor178, 

having regard to Regulation (EC) No 78/2009 of the European Parliament and of the 
Council of 14 January 2009 on the type-approval of motor vehicles with regard to the 
protection of pedestrians and other vulnerable road users, amending Directive 2007/46/EC 
and repealing Directives 2003/102/EC and 2005/66/EC179, 

having regard to Directive 2014/47/EU of the European Parliament and of the Council of 
3 April 2014 on the technical roadside inspection of the roadworthiness of commercial 
vehicles circulating in the Union and repealing Directive 2000/30/EC180, 

having regard to Directive (EU) 2015/413 of the European Parliament and of the Council 
of 11 March 2015 facilitating cross-border exchange of information on road-safety-related 

178 OJ L 200, 31.7.2009, p. 1. 
179 OJ L 35, 4.2.2009, p. 1. 
180 OJ L 127, 29.4.2014, p. 134. 

217 

 
 
 
 
                                                 
– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

traffic offences181, 

having regard to 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 traffic182, 

having regard to Regulation (EU) 2015/758 of the European Parliament and of the Council 
of 29 April 2015 concerning type-approval requirements for the deployment of the eCall 
in-vehicle system based on the 112 service and amending Directive 2007/46/EC, 

having regard to its resolution of 9 September 2015 on ‘The implementation of the 2011 
White Paper on Transport: taking stock and the way forward towards sustainable 
mobility’183, 

having regard to its resolution of 18 May 2017 on road transport in the European Union184, 

having regard to its resolution of 3 July 2013 on ‘Road safety 2011-2020 – First milestones 
towards an injury strategy’185, 

having regard to its resolution of 27 September 2011 on European road safety 2011-
2020186, 

having regard to its resolution of 15 December 2011 on ‘The Roadmap to a Single 
European Transport Area – Towards a competitive and resource efficient transport 
system’187, 

having regard to the Commission communication entitled ‘A European strategy on 
Cooperative Intelligent Transport Systems, a milestone towards cooperative, connected 
and automated mobility’ (COM(2016)0766), 

having regard to the Commission communication entitled ‘Towards a European road safety 
area: policy orientations on road safety 2011-2020’ (COM(2010)0389), 

having regard to the Commission communication entitled ‘CARS 2020: Action Plan for a 
competitive and sustainable automotive industry in Europe’ (COM(2012)0636), 

having regard to the Commission White Paper entitled ‘Roadmap to a Single European 
Transport Area – Towards a competitive and resource efficient transport system’ 
(COM(2011)0144), 

having regard to the Commission report entitled ‘Benefit and feasibility of a range of new 
technologies and unregulated measures in the field of vehicle occupant safety and 
protection of vulnerable road users’, drawn up by the Transport Research Laboratory and 
published on 31 March 2015, 

181 OJ L 68, 13.3.2015, p. 9. 
182 OJ L 115, 6.5.2015, p. 1. 
183 Texts adopted, P8_TA(2015)0310. 
184 Texts adopted, P8_TA(2017)0228. 
185 OJ C 75, 26.2.2016, p. 49. 
186 OJ C 56E, 26.2.2013, p. 54. 
187 OJ C 168E, 14.6.2013, p. 72. 

218 

 
                                                 
– 

– 

– 

– 

– 

– 

having regard to the Commission staff working document entitled ‘On the implementation 
of objective 6 of the European Commission’s policy orientations on road safety 2011-2020 
– First milestone towards an injury strategy’ (SWD(2013)0094), 

having regard to the Council conclusions of 8 June 2017 on road safety in support of the 
Valletta Declaration of March 2017, 

having regard to the package ‘Europe on the Move’, released by the Commission on 31 
May 2017, which includes a set of eight legislative initiatives with a special focus on road 
transport, 

having regard to the United Nations General Assembly resolution 70/260 of 15 April 2016 
entitled ‘Improving Global Road Safety’, 

having regard to Rule 52 of its Rules of Procedure, 

having regard to the report of the Committee on Transport and Tourism and the opinion of 
the Committee on the Internal Market and Consumer Protection (A8-0330/2017), 

A.  whereas every year on Europe’s roads around 25 500 people die and some 135 000 are 

seriously injured, so that more – and more effective – measures need to be taken, in 
consultation with Member States, if the vision zero goal of ‘no fatalities’ is to be achieved; 

B.  whereas road safety depends on three factors: vehicle, infrastructure and drivers’ 

behaviour, and, therefore, measures in all three areas are necessary in order to enhance 
road safety and effective measures should be taken in the area of active and passive vehicle 
safety; 

C.  whereas the average age of passenger cars, light-duty vehicles and heavy-duty vehicles in 
the EU is constantly increasing and is now over 10 years; whereas the age of a vehicle has 
a direct bearing on the consequences of and the injuries sustained in a road accident; 

D.  whereas driver assistance systems make the vehicles safer and also enable the safe and 

active participation of persons with reduced mobility and the elderly in road traffic; 

E.  whereas intelligent driving systems reduce congestion, warn drivers of hazards on their 

route, and consequently help to lower the risk of causing an accident; 

F.  whereas the move towards driver-free vehicles is progressing rapidly and road safety 

generally is an urgent issue, so that a review of the General Safety Regulation must be 
submitted by the Commission no later than first quarter of 2018; whereas in any event any 
further delay would be unacceptable; 

G.  whereas since 38 % of all fatalities occur in urban areas, often involving vulnerable road 
users, Member States should take vulnerable road users into consideration in urban traffic 
planning, improving their treatment in relation to modes of transport such as cars and 
buses; whereas the Commission should present its review of the pedestrian protection 
regulation; 

H.  whereas there is a clear link between road safety and the working conditions of 

professional road users; 

General requests  

219 

 
1. 

Stresses that Member States should conduct efficient and regular road checks on drivers, as 
the main causes of accidents, at present as in the past, are speed levels that are 
inappropriate and excessive speed for the driving conditions concerned, distraction, driving 
under the influence of alcohol or drugs, and excessive fatigue, and therefore:  

(a) 

(b) 

(c) 

calls on the Commission to set a percentage for the numbers of vehicles in classes 
M1 and N1 to be checked; 

calls on the Commission to introduce stricter controls for the proper enforcement of 
compulsory working-time limits and rest periods for drivers who are professional 
road users; 

calls on the Member States to step up exchanges of best practices, particularly 
regarding smart enforcement strategies, and to introduce penalties which will act as a 
deterrent to offenders; 

2.  Notes that around 25 % of all annual traffic fatalities in the EU are caused by alcohol 
consumption; invites the Commission, therefore, to assess the possible added value of 
harmonising the EU blood alcohol concentration limit at 0.0% for new drivers in their first 
two years and for professional drivers, and welcomes some Member States’ zero tolerance 
policy for drunk driving; 

3.  Urges the Commission, bearing in mind the Valletta Declaration on improving road safety 
issued by the Maltese presidency on 29 March 2017, to include new targets for halving the 
number of serious injuries on the roads in the EU in its new road safety strategy for the 
decade 2020-2030; 

4. 

5. 

Calls on the Member States to significantly improve the state of their road infrastructure by 
means of regular and effective maintenance, including of traffic signs and signalling 
systems, and appropriate upgrades to cope with traffic volumes, and to introduce 
innovative measures providing full functionality and enhancing the interoperability of 
driver assistance systems, resulting in so-called intelligent infrastructure; calls on the 
Commission to set up a mechanism to ensure that the European road infrastructure remains 
in an adequate condition;  

Points out that infrastructural alterations (for example certain types of crash barrier or 
traffic-calming devices) can sometimes cause accidents or make them worse, especially 
when motorised two-wheelers are involved; calls on the Commission, therefore, to propose 
any standardisation measure likely to remedy the drawbacks; 

6.  Observes that many drivers are not aware of the necessity of or how to form a corridor for 
emergency vehicle access on motorways, and therefore calls on the Commission to set 
common standards for the creation of such corridors and to launch a European awareness 
campaign; 

7.  Observes that for pedestrians and cyclists nearly half of all fatalities resulting from traffic 
accidents are of persons aged over 65, and that road accidents are the biggest cause of 
death among young people; calls on the Member States, therefore, to make it possible for 
older people and young drivers to use the roads safely by developing well-publicised 
programmes to avert age-specific accident risks; 

8.  Observes that in 51 % of cases the victims of fatal road accidents in urban areas are 

pedestrians and cyclists, and therefore encourages cities to include targets in their mobility 

220 

 
plans for reducing the number of road and traffic accidents; also calls on the Member 
States to take greater account of more vulnerable road users, by addressing critical accident 
hotspots and by building and maintaining more safe pedestrian and cycling infrastructure 
or expanding and modernising existing infrastructure while also ensuring better 
indications; calls on the Commission also to take further action at EU level over and above 
the availability of existing funding schemes, in order to facilitate widespread 
improvements to cycling infrastructure and to mandate new active and passive vehicle 
safety technologies that protect in particular vulnerable road users; 

9.  Notes that because some cyclists are ignorant of traffic regulations and/or fail to observe 

them, situations sometimes arise in which their own safety and that of other road users can 
be endangered; calls on the Commission to consider what kind of proposal it might make 
to promote safer cycling, thereby enabling bicycles to be dovetailed smoothly with the 
other modes of urban mobility; 

10.  Encourages intelligent transport system (ITS) and public transport operators to further 

develop technologies for vehicles that encourage drivers to switch to safer modes of 
transport when entering urban areas; 

11.  Observes that new means of transport, such as e-bikes and other electric mobility devices, 

are becoming increasingly popular; calls on the Commission, therefore, to examine the 
safety requirements for such vehicles without delay, and to make proposals for their safe 
integration into road transport, while taking due account of subsidiarity; 

12.  Notes that the development and implementation of safety systems ought to make for road 
safety, and that this process will accordingly require some kind of adaptation period; calls 
on the Commission, therefore, to allow for the time necessary to develop such systems 
before specific technical legislation is put into effect; 

13.  Recalls that odometer fraud remains an untackled problem, especially in the second- hand 

car market, as noted by the Commission in its study on the functioning of the market for 
second-hand cars from a consumer perspective; urges the Commission and the Member 
States to address the issue of manipulation of or tampering with odometers through 
effective measures and legislation; 

14.  Notes that the more vehicles there are on the road, the more likely it is accidents might 
occur; calls, therefore, on the Member States and the Commission to promote collective 
and shared mobility, especially in urban areas, in order to reduce the circulating fleet, as 
well as measures to increase the proportion of bicycles and of professionally driven 
vehicles; 

15.  Points out that the equipment that must compulsorily be carried in a vehicle differs from 
one Member State to another, and calls on the Commission, therefore, to draw up an EU-
wide binding list of objects that should fall under the carrying requirement; 

16.  Maintains that the EU and its research centres should play a leading role in the 

development of autonomous vehicles, since these will revolutionise the automobile sector, 
especially in terms of road safety, in which respect they are expected to save thousands of 
lives every year, as well as contributing to the digitalisation of the internal market; 

Driver assistance systems to increase road safety 

17.  Stresses that approximately 92 % of all accidents are due to human error or interaction of 

221 

 
human error with vehicles and/or infrastructure, and that it should therefore be compulsory 
to incorporate only those driver assistance systems which improve road safety significantly 
as demonstrated by scientific evidence, have a favourable cost-benefit ratio, and have 
attained market maturity; considers that additionally, the resulting purchase price increases 
should not be so inordinate that the intended customers for such vehicles cannot afford to 
buy them, and that driver assistance systems, which are of relevance for road safety, should 
be checked regularly; 

18.  Calls on the Commission to test the above-mentioned safety devices when performing 

vehicle market surveillance; 

19.  Considers that the benefits of improved safety standards and equipment can be realised 

only if existing and future provisions are implemented and enforced effectively; calls, in 
this regard, for increased European-level oversight of type-approval authorities and 
technical services in the Union; calls, in addition, for greater and more independent post-
market surveillance of vehicles on roads across the Union to ensure that they continue to 
conform to safety criteria; 

20.  Stresses that, when non-conformities are identified, European consumers should be able to 

count on rapid, appropriate and coordinated corrective measures, including Union-wide 
vehicle recall where necessary; considers that economic operators should be liable for any 
damage caused to owners of affected vehicles as a result of non-compliance or following a 
recall;  

21.  Calls on the Commission and the Member States to improve the safety level of existing 

vehicles in use and to support developments and innovations which will increase the safety 
of cars already in use by incentivising and promoting the retrofitting of vehicles with cost-
effective road safety systems that help drivers react better in a dangerous situation; 

22.  Calls on manufacturers and operators: 

(a) 

to make it clear to drivers what the activation status of each driver assistance system 
is; 

(b)  where systems can be switched off, to introduce two-stage deactivation systems, such 
that the driver can initially merely switch off the warning signal and can only 
deactivate the system itself by means of a second procedure; 

(c) 

(d) 

to ensure that each time a vehicle is started afresh the driver assistance system is 
restored to active status; and 

to introduce a pricing policy which will encourage consumers to choose vehicles 
equipped with safety and driver assistance systems; 

23.  Stresses that evident warnings should be sufficiently differentiated to ensure that it is 

intuitively clear to which system the assistance pertains, and that warnings should also be 
easy to perceive for elderly persons, persons with a disability, such as hearing and/or sight 
impairment, and persons with reduced mobility; calls, therefore, on the parties concerned 
to adopt appropriate uniform standards allowing the possibility of operator-specific 
solutions; 

24.  Welcomes the fact that almost all cars tested under the European New Car Assessment 

Programme for consumers (Euro NCAP) are awarded five stars and that the majority of car 

222 

 
manufacturers have successfully responded to the challenge of meeting the new Euro 
NCAP requirements; notes, however, that not all car models sold in Europe are tested by 
Euro NCAP, and not all of the same type are sold with the same specification, which may 
create lack of clarity for consumers and thus offer a false level of confidence in the vehicle 
in relation to the actual performance of the model purchased; recalls the importance, 
therefore, of a strong underlying standard of mandatory safety requirements which ensure 
that all necessary safety equipment is present across the fleet used and sold in the EU; 

25. 

Is of the opinion that the Euro NCAP should always reflect the actual car safety of a 
specific model, and encourages it to be more ambitious in assessing the safety of new 
vehicles than the statutory minimum requirements compel it to, and to take into 
consideration the updated statutory minimum requirements, in order to further promote the 
development of vehicles that ensure high road safety standards and so that Europe remains 
ambitious and acts as a global leader in car safety; 

26.  Calls on the Commission to coordinate the adoption of standards with the United Nations 

Economic Commission for Europe (UNECE) so as to achieve international consistency 
and at the same time limit to a minimum exemptions from the requirement to install driver 
assistance systems, in order to improve road safety across the board; stresses, in addition, 
that manufacturers should create clear information materials to help drivers better 
understand the various driver assistance systems and their functionalities; 

27.  Calls for a harmonised European approach which takes into account all 

existing international and national legislation and ensures its complementarity; 

28.  Calls on the Commission to investigate the involvement of special-purpose vehicles in 

urban accidents and, if necessary, to abolish the existing exemptions from the requirement 
to install driver assistance systems; 

29.  Stresses that drivers' instruction should include periodical and additional training in using 
obligatory driver assistance mechanisms, paying special attention to the elderly and 
persons with reduced mobility; urges driving schools, on the one hand, to incorporate 
issues relating to the operation of these systems into their learner training, and, on the other 
hand, to couple acquiring a driving licence with having received professional, on-road 
practical training; 

30.  Notes that financial incentives, for example tax-based or insurance-based, for measures 

such as the installation of additional safety-relevant driver assistance systems in new and 
used cars or their inclusion in driver training, can facilitate the market uptake of vehicles 
with advanced safety features; invites Member States to consider introducing such 
mechanisms; 

31.  Calls on the Commission to require market operators to arrange for the use of open 

standards and interfaces which will further improve interoperability, so that independent 
tests can be carried out by accessing the relevant vehicle and system data, including their 
updates, and can be performed by any qualified professional, while respecting proprietary 
data and intellectual property; 

32.  Stresses that a high level of data protection and retention as required by Regulation (EU) 
2016/679 (the General Data Protection Regulation) and by the right to protection of 
privacy and personal data should be ensured, as should high IT security, so that the 
possibility of new accident risks due to remote manipulation of on-board systems or 
conflicts of compatibility is excluded; recommends that the principle of ownership of data 

223 

 
be explored; 

33.  Stresses the importance of making use of reliable position and time information from 
satellite-based positioning systems and of applying the EGNOS/GNSS system to road-
active safety; calls for more efforts to be made in order to achieve an EGNOS/GNSS road-
active safety accuracy of less than one metre, with a view to a shift from the system's 
ability to reduce vehicle speed to its ability to automatically intervene and deviate the 
vehicle trajectory; calls for the promotion of enhanced road safety by integrating 
EGNOS/GNSS data with on-board control systems; 

Safety measures for accident prevention  

34.  Welcomes the fact that emergency braking is already mandatory, since November 2015, 

for all new trucks and buses in the EU, but calls on the Commission to make it compulsory 
to install automatic emergency braking assistants with detection of pedestrians, cyclists, 
light powered two-wheelers and motorcyclists in cars, light commercial vehicles, buses, 
coaches and, especially, heavy goods vehicles, as these have a strong potential to prevent 
road accidents by means of autonomous powerful braking and a resulting shorter stopping 
distance; 

35.  Calls for safer front-end design of heavy goods vehicles related to better vision of 

pedestrians and cyclists, as well as for barriers to avoid collisions and mitigate 
consequences of collisions; 

36.  Calls for the compulsory installation of overridable intelligent speed assistant systems that 
indicate speed limits, stop signs and traffic lights and intervene to assist drivers to remain 
within speed limits; calls on Member States to ensure that road signs are kept in excellent 
condition and that road markings are clearly legible; emphasises that for the proper 
working of intelligent assistant systems it is necessary to have updated online road maps 
with current speed limit indications; 

37.  Stresses that, in order to improve road safety, the deceleration of vehicles should be 

rendered easier for other road users to perceive by means of clear signal lights on vehicles, 
and expects the compulsory use of an emergency braking indicator in the form of a 
flashing brake light or flashing hazard lights; 

38.  Stresses that in view of its relevance to road safety, an overridable lane-keeping assistance 
that not only warns but also appropriately intervenes, albeit without preventing drivers 
from acting directly, should be made compulsory; notes that for using this warning system 
it is necessary that road markings are kept in a condition ensuring that they are clearly 
recognisable; 

39.  Emphasises that increasing the direct vision of the driver in heavy goods vehicles, buses 

and coaches and reducing or eliminating blind spots are vital for improving the road safety 
of such vehicles; calls on the Commission, therefore, to mandate ambitious differentiated 
direct vision standards and to make it compulsory to install front, side and rear cameras, 
sensors and turning assistant systems, while observing that such measures should accord 
with Directive (EU) 2015/719 and should not result in any extension of the time limits for 
implementation laid down therein; 

40.  Stresses the need to provide preconditions for installing alcohol interlock devices and 

systems to detect driver distraction and drowsiness, and urges the use of alcohol interlocks 
for professional drivers and for drivers who have caused a traffic accident under the 

224 

 
influence of alcohol and have therefore been convicted of a drunk driving offence, as a 
rehabilitation measure; 

41.  Observes that trucks are involved in 15 % of road fatalities, and that vulnerable road users 

account for approximately 1 000 truck-related fatalities every year; calls on the 
Commission, therefore, to accelerate the mandatory introduction for trucks of ambitious 
differentiated direct vision standards, intelligent speed assistance, and automatic 
emergency braking systems with cyclist and pedestrian detection; 

Safety measures to mitigate the effects of accidents 

42.  Observes that tyre pressure has significant implications for road safety and fuel 

consumption as well as for emissions; calls on the Commission, therefore, to make it 
compulsory to install direct tyre pressure monitoring systems; also calls on the 
Commission to transpose into EU law the tyre pressure measurement systems amendments 
aimed at delivering in real world conditions agreed at UNECE; 

43.  Considers it necessary to make it compulsory to install intelligent seatbelt reminder 
systems for all front seats for all vehicles and for rear seats for M1 and N1 vehicles; 

44.  Considers it important to make it compulsory to install automated seatbelt adjustment 

systems in order to avoid neck damage; 

45.  Calls on the Commission, from 2019, to extend the eCall installation requirement to 

motorcycles, heavy goods vehicles and buses and coaches, and also to make the system 
available for retrofitting so as to ensure that it can cover the highest possible numbers of 
vehicles on the road; 

46.  Calls for accurate and reliable EU-wide accident statistics, including statistics on the 

causes of accidents, exposure data and listing of injuries and accident victims, and 
observes that an event data recorder could be very helpful in this connection, in which 
context the data must be kept anonymous and used only for purposes of accident research; 

47.  Calls for data to be collected throughout the EU on vehicle occupants killed or injured due 
to causes other than collisions; notes that there are no data available on vehicle heat-stroke 
casualties; 

48.  Calls for better fire safety rules for buses and coaches with different types of power, 
including CNG-powered buses, to maximise the protection of passenger safety; 

49.  Observes that redesigned front underrun protection of trucks could reduce fatalities in 

head-on collisions between cars and trucks by 20 %; calls on the Commission to mandate 
improved energy-absorbing front underrun protection for all new trucks; 

50.  Calls for compulsory frontal, side and rear-end crash tests for: 

(a) 

all-terrain vehicles (SUVs) with raised seats and a maximum weight of more than 
2 500 kg; and 

(b) 

electrically propelled vehicles and vehicles with other new propulsion technologies; 

51.  Calls on the Commission to also update the testing requirements for motor vehicle passive 
safety systems so as to include protection of all vulnerable road users in front and rear 

225 

 
impacts, including not only pedestrians but also cyclists; 

52.  Calls on the Commission to ensure that the market will have sufficient and realistic time to 

adapt to these measures; 

53.  Stresses that Directive (EU) 2015/719 on weights and dimensions of heavy goods vehicles 
has great potential to improve truck safety; calls on the Commission to accelerate work on 
this directive and come forward with its assessment without delay; 

o 
o   o 

54. 

Instructs its President to forward this resolution to the Council, the Commission and the 
governments and parliaments of the Member States.  

226 

 
 
 
ANNEX 8 – MEMBER STATES’ DECLARATION ON ROAD SAFETY  

Valletta Declaration on Road Safety 

29 March 2017 
Valletta 

227 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ministerial declaration on road safety 

1. 

Transport ministers of the Member States of the European Union, meeting in Valletta on 29 March 

2017 under the Maltese Presidency of the Council of the European Union, reconfirm their 

commitment to improving road safety. The persistently high number of traffic fatalities (26 100 

deaths in the EU in 2015) and serious road traffic injuries is a major societal problem causing 

human suffering and unacceptable economic costs, estimated to be in the order of EUR 50 billion 
per year for fatal accidents alone1, and more than EUR 100 billion when serious accidents are 
included.2 

2. 

There has been a steady and promising trend towards meeting the common target of halving the 

number of road deaths between 2010 and 2020, endorsed by the Council of the European Union in 
2010,3 but fatality reduction rates have plateaued in recent years. Of particular concern is the 

number of fatalities and serious injuries among pedestrians and cyclists. The target has therefore 

become extremely challenging and, unless further efforts are made, it may not be met. 

3. 

The work on improving road safety should not be measured only by counting road deaths; the 

number of serious injuries is no less worrying as it is five times higher than the number of road 
deaths.2 We should aim towards an ambitious overall target, in the spirit of the UN General 
Assembly resolution on improving global road safety4, to drive the appropriate reduction measures. 

Such a target needs monitoring through comparable and reliable data, reported using a common 

definition. Those data have to be thoroughly analysed in collaborative work between Member States 

and the European Commission so that, based on their robustness, appropriate additional measures 

can be taken to reduce the number of such injuries in the next decade. 

4. 

The situation with regard to road safety varies widely across the Member States. A special effort 

should be made in those cases where road safety is below the European Union average, supported 

by close cooperation and knowledge-exchange among Member States. 

1 

2 

3 

4 

European  Commission,  Road  safety  study  for  the  interim  evaluation  of  Policy 
Orientations on Road Safety 2011-2020, 2015, p. 19. 
European Commission, press release, 31 March 2016, IP/16/863. 
Council conclusions on road safety, 2 December 2010, paragraph 21, ST 16951/10. 
Resolution A/70/260 of April 2016. 

 
 
 
 
 
 
 
5. 

Speeding, driving under the influence of alcohol or drugs, and being distracted or tired while 

driving continue to be among the major causes of road traffic collisions. Failure to use protective 

equipment aggravates the severity of injuries. Particular attention should thus be paid to improving 

road users' behaviour. 

6. 

There is already a wide range of instruments relating to, in particular, better enforcement of traffic 

rules in the Member States and across borders, better education of, and awareness-raising among, 

road users, as well as improvement of infrastructure and vehicle safety, taking into account age and 

roadworthiness. These instruments should be readily applied. 

7. 

Building on the principle of subsidiarity, road safety is a shared responsibility, which requires 

concrete and joint action by the institutions of the European Union, the Member States, regional and 

local authorities, industry and civil society. 

8. 

The transport ministers will undertake to: 

a) 

continue and reinforce measures necessary to halve the number of road deaths in the EU by 

2020 from the 2010 baseline; 

b) 

enhance cooperation between Member States, including relevant authorities, and with civil 

society, research institutes and the private sector, in particular with regard to road safety plans 

and strategies following a risk-based or an integrated approach (such as the ‘Safe System’ 

approach); 

c) 

take cycling5 and walking into account in mobility plans, safety policies and measures and, 

where feasible, consider the inclusion of dedicated infrastructure; 

d) 

improve the safety of road users by developing safer road infrastructure, bearing in mind the 

possibility of extending the application of infrastructure safety management principles beyond 

the Trans-European Transport Network (TEN-T) roads; 

e) 

engage with relevant stakeholders, as part of urban mobility planning, on the possibility of 

expanding and integrating reduced speed limits, such as 30 km/h, into high-risk areas, in 

particular areas where people work, cycle and play; 

5 

The policy on cycling is specifically addressed in the Declaration of Luxembourg on cycling 
as a climate friendly transport mode, October 2015. 

 
 
 
 
 
 
 
f) 

ensure the effective deployment of the e-Call system and reduce rescue times; 

g) 

promote the undertaking of in-depth investigations using relevant samples of severe traffic 

collisions/accidents and analysing the data to identify priority areas for intervention; 

h) 

continue, in parallel with our efforts towards reaching the 2020 fatality reduction target, with 

the work towards: (i) reducing the number of serious injuries in road traffic collisions, and (ii) 
reporting reliable and comparable data using a common definition based on the MAIS63+ 

trauma scale by 2018; 

i) 

set a target of halving the number of serious injuries in the EU by 2030 from the 2020 

baseline using this common definition and in the framework of an overall road safety strategy 

for this period; 

j) 

continue developing measures to ensure post-collision care, early rehabilitation and social 

reintegration of road traffic accident victims, in cooperation with the relevant public policy 

stakeholders, in particular with those representing road traffic victims; 

k) 

effectively enforce road safety rules and provide support to road enforcement bodies, 

including through cooperation and exchange of best practices, in particular with regard to 

speeding, driving under the influence of alcohol or drugs, failing to comply with traffic light 

and traffic sign rules, being distracted while driving, e.g. by using mobile devices, and failing 

to use protective equipment. Particular attention should be given to preventive tools such as 

alcohol interlocks, and to other technical support systems; 

l) 

continue to work in international road safety bodies7 to help accelerate improvements in road 

safety through technical and non-technical means in Europe and further afield; 

m) 

ensure adequate levels of funding for future road safety policies, programmes and research in 

accordance with: (i) the objectives set out in national strategies and (ii) the available financial 

resources of the Member States; 

6 

7 

Maximum Abbreviated Injury Scale, an index ranging from 1 to 6. 

Such  as  working  groups  of  the  UN  Economic  Commission  for  Europe  (Working  Party  on 
Road  Traffic  Safety  (WP.1),  World  Forum  for  Harmonization  of  Vehicle  Regulations 
(WP.29), Working Party on the Transport of Dangerous Goods (WP.15)). 

 
 
 
 
 
 
 
 
n) 

promote, together with the European Commission, a Europe-wide road safety culture based 

on shared values and improve road users' behaviour through continued and effective 

education and training targeting different groups, taking into account the specific needs of 
vulnerable road users8 as well as professional drivers; 

o) 

support the deployment of compatible and interoperable connected and automated vehicles 
with proven safety benefits, as mentioned in the Declaration of Amsterdam9 and the 
Commission's strategy on Cooperative Intelligent Transport Systems.10 

9. 

The transport ministers call upon the Commission to: 

a) 

enhance the protection of road users, and in particular vulnerable road users, by ensuring the 

deployment of new safety features for vehicles, for instance through accelerating the review 

of type-approval rules in the General Safety Regulation as outlined in the Commission's 

report to the European Parliament and the Council entitled 'Saving Lives: Boosting Car Safety 
in the EU';11 

b) 

prepare a new road safety policy framework for the decade after 2020, including an 

assessment of road safety performance taking into account the targets and objectives set out in 

this declaration; 

c) 

explore the strengthening of the Union's road safety legal framework with a particular focus 

on Member States' cooperation on the mutual recognition of the driving disqualifications of 

non-resident drivers, without prejudice to the appropriate legal base(s) for such proposals; 

d)  work with all stakeholders to establish projects and initiatives to protect vulnerable road users 

and facilitate the exchange of knowledge and best practices among Member States concerning 

road accident investigation, as well as road safety strategies and campaigns; 

8 

9 

10 

11 

'Vulnerable  road  users'  includes  non-motorised  road  users,  such  as  pedestrians  and 
cyclists,  as  well  as  motor-cyclists  and  persons  with  disabilities  or  reduced  mobility  and 
orientation. 
Declaration of Amsterdam on cooperation in the field of connected and automated driving, 
April 2016. 
Document COM (2016) 766 final of November 2016. 
Document COM (2016) 787 final of December 2016. 

 
 
 
 
 
 
 
 
e) 

explore the potential of connected and automated driving technologies, and 

of the use of the data that is already available in vehicles and infrastructure, 

to enhance road safety while ensuring data security; 

f) 

ensure that necessary resources are allocated to research, programmes and 

projects promoting road safety in Europe; 

g) 

cooperate with Member States and other key stakeholders on developing a 

Europe-wide road safety culture. 

10.  The transport ministers invite industry, in cooperation with civil society in the sector, 

to: 

a) 

develop cooperative intelligent transport systems, ensuring that new services 

and systems are compatible, secure and interoperable at European level; 

b) 

develop and promote new technologies, especially those automated 

driving functions and driver assistance systems that reduce the effects of 

human error and distraction, such as advanced Intelligent Speed 

Assistance or Autonomous Emergency Braking, protecting in particular 

vulnerable road users; 

c) 

promote the road safety potential of cooperative, connected and automated 
vehicles. 

11.  The  transport  ministers  highlight  the  importance  of  continuous  work  and 

cooperation  on  road  safety,  and  take  note  of  the  contributions  and 

commitments  made  by  stakeholders  prior  to  and  during  the  Valletta 

conference. 

232 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 9 – CAR INDUSTRY (ACEA) – EXTRACT OF POSITION PAPER AND PRIORITY LIST 

ACEA Position Paper 

General Safety 
Regulation Revision 

March 2018 

233 

 
 
 
 
 
 
 
 
 
KEY MESSAGES 

a.  The  European  Automobile  Manufacturers’  Association  (ACEA)  is  a  strong  supporter  of  the 
EU  objective  of  reducing  road  casualties  and  thus  welcomes  the  initiative  to  revise  safety 
regulations. 

b.  An  integrated  approach  is  needed,  examining  the  benefits  that  can  be  achieved  by 

combining new technology with improving road infrastructure and driver behaviour. 

c.  Active safety measures can reduce the number and consequences of accidents. 
d.  Passive safety measures will have fewer benefits than active safety measures and may have 

negative impacts, such as increasing CO2 emissions. 

e.  Safety will also be further improved by the introduction of autonomous driving features, but 
the successful roll-out of this technology will require a coherent approach across all services 
within the European Commission, as well as the member states. 

KEY RECOMMENDATIONS 

      Based on the proposed measures of the EU General Safety Regulation (GSR): 

a.  The focus should be on active safety measures. 
b.  Detailed  cost-benefit  analysis  and  impact  assessment  are  needed  for  all  measures 

considered, separated into different vehicle categories. 

c.  When considering measures with an effect on the same type of accidents (eg collisions with 
pedestrians), synergies have to be factored in to avoid solving the same problem twice. 
d.  The measures need to take into account the different usage and characteristics of vehicles 

(passenger cars, light commercial vehicles, heavy trucks, etc). 

e.  ACEA  considers  the  following  measures  most  effective:  autonomous  emergency  braking 
(AEB)  systems  (M1,  N1,  stepwise  introduction);  emergency  braking  display  (EBD)  (M,  N); 
lane keeping assistance (LKA)/lane departure warning (LDW) (M1, N1); safety belt reminders 
(SBR)  (M,  N;  all  front  seats;  only  buckling  monitor  on  rear  seats  on  M1  vehicles;  further 
exemptions to be considered such as removable seats, etc); alcohol interlock interface (AI) 
(M,  N,  instruction  sheet);  crash  event  data  recorder  (EDR)  (M1,  N1);  reverse  detection  (M, 
N1,  N2);  tyre  pressure  monitoring  system  (TPMS)  (M1,  N1);  front-end  blind  spot  cameras 
and  detection  (M2,  M3,  N2,  N3);  frontal  crash  full  width  protection  (M1,  N1  derived  from 
M1); pole side impact protection (M1, N1 derived from M1); lateral protection (N2, N3, O3, 
O4); fire safety of CNG buses (M2, M3); fire suppression for buses (M2, M3); and rear crash 
test (M1, N1). 

f.  All  measures  need  to  be  harmonised  with  the  provisions  of  the  United  Nations  Economic 
Commission for Europe (UNECE) regulations; specific EU regulations have to be avoided. 
g.  Transition  time  must  be  aligned  with  product  development  time,  allowing  at  least  three 
years for new vehicle types from the date the regulation has entered into force and the final 
requirements are available. 

234 

 
 
 
 
 
 
CONCLUSIONS AND RECOMMENDATIONS 

ACEA  members  welcome  the  Commission  initiative  to  further  improve  road  safety  through  the 
revision of the General Safety and Pedestrian Safety regulations. 

As  previously  indicated,  ACEA  members  are  open  to  considering  a  large  number  of  the  proposed 
measures, while expressing concerns on only a few. The measures considered are (*N1 two years 
later): 

  AEB  (M1,  N1*):  step-wise  introduction  –  step 1,  moving  obstacles;  step 2,  stationary 

obstacles; step 3, pedestrians; step 4, cyclists 

  EBD (M, N) 
  LKA/LDW (M1, N1*) 
  SBR (M, N): all front seats; only buckling monitor on rear seats on M1 vehicles; exemptions 

to be considered for removable seats and seats in a row with a suspension seat 

  AI (M, N): instruction sheet 
  EDR (M1, N1) 
  Reverse detection (M, N1, N2) 
  TPMS (M1, N1): technology neutral requirement 
  Front end blind spot cameras and detection (M2, M3, N2, N3) 
  Frontal crash full width (M1, N1 derived from M1) 
  Pole side impact (M1, N1 derived from M1) 
  Lateral protection (elimination of exemptions; N2, N3, O3, O4) 
  Fire safety of CNG buses (M2, M3) 
  Fire suppression for buses (M2, M3) 
  Rear crash test (M1, N1) 

ACEA recommends that all measures should consider: 

  The possibility of solving the problem with other initiatives, by looking at driver behaviour 

and following an integrated approach. 

  A  horizontal  approach,  looking  at  the  benefits  of  other  considered  measures,  avoiding 

addressing issues that will be completely or partially solved through other measures; 

  A  detailed  cost–benefit  analysis  and  impact  assessment  for  all  considered  measures, 

separated into different vehicle categories. 

  That  the  impact  assessment  has  to  take  into  account  the  impact  on  other  European 
priorities,  for  example  the  impact  of  passive  safety  measures  on  vehicle  weight  and 
consequently CO2 emissions. 

  That heavy M1/N1 vehicles and M2/N2 vehicles should be evaluated separately from more 

lightweight vehicles, since they have a different design-principles. 

  That  the  measures  need  to  take  into  account  the  different  usage  and  characteristics  of 

vehicles (passenger cars, light commercial vehicles, heavy trucks, etc). 

235 

 
 
 
 
 
 
  That all measures need to be harmonised with the provisions of the UNECE regulations and 

specific EU regulations have to be avoided. 

  That  transition  time  must  be  aligned  with  product  development  time,  allowing  at  least 
three years for new vehicle types from the date the regulation has entered into force and 
the final requirements are available 

BIBLIOGRAPHY 

TRL, CEESAR and ACEA: accident analysis, November 2017 

LIST OF ABBREVIATIONS 

AEB: autonomous emergency braking 

AI: alcohol interlock interface 

BAC: blood alcohol concentration 

CARE: Community Road Accident Database 

EBD: emergency braking display 

EDR: crash event data recorder 

ESC: electronic stability control 

ESOP: European Statement of Principles 

GSR: General Safety Regulation 

ISA: intelligent speed adaptation 

LDW: lane departure warning 

LKA: lane keeping assistance 

OEM: original equipment manufacturer 

PPA: pedestrian protection airbag 

SBR: safety belt reminders 

SLI: speed limit information 

TPMS: tyre pressure monitoring 

VRU: vulnerable road user 

236 

 
 
 
 
 
 
 
 
237 

 
 
 
 
238 

 
 
 
 
239 

 
 
 
 
240 

 
 
 
 
241 

 
 
 
ANNEX 10 – MARKET ANALYSIS 

This annex provides supplementary figures to description of the market presented in section 
2.6. 

Analysis is done by following regions: 
Central Europe: Austria, Belgium, France, Germany, Luxembourg, Netherlands 
Eastern Europe: Bulgaria, Croatia, Czech Republic, Estonia, Hungary, Latvia, Lithuania, 
Poland, Romania, Slovakia, Republic, Slovenia  
North-Western Europe: Denmark, Finland, Ireland, Sweden and UK 
Southern Europe: Greece, Italy, Cyprus, Malta, Portugal, Spain 

Figure A10.1 Development of road accidents for EU regions between 19770 and 2014 

 Source: OECD , Eurostat, Provisional data (2014 injury stat) for 2015 is used for Denmark , Estonia, Ireland, 
France, Italy and Romania. Note: Cyprus is not included due to lack of data on road casualties  

242 

 - 20 40 60 80 100 120 140 160 180 20019701972197419761978198019821984198619881990199219941996199820002002200420062008201020122014Index (Number of road casualties per capita 1970)Eastern EuropeNorthWestern EuropeCentral EuropeSouthern EuropeEurope total 
 
 
 
 
 
 
 
 
 
Figure A10.2: Number of passenger cars per thousand inhabitants (A) and its evolution from 
common base year (B) for EU regions between 1990 and 2015 

Source: DG Mobility and Transport – Statistical Pocketbook 2017 Chapter 2.6 Means of Transport 
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en  

Figure A10.3: Renewal rate of passenger cars  

Note: Share of new registrations of passenger cars in a given year to the total fleet per EU region 
between 2004 and 2015. 

Source: DG Mobility and Transport – Statistical Pocketbook 2017 Chapter 2.6 Means of Transport, 
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en 

243 

0100200300400500600cars/thousand inhabitantsA Eastern EuropeWestern EuropeSouth EuropeCentral Europe100120140160180200220240260280% increase in number of carsB Eastern EuropeWestern EuropeSouth EuropeCentral Europe0%2%4%6%8%10%12%14%200420052006200720082009201020112012201320142015newly annually registered cars  as % of total car fleet Eastern EuropeWestern EuropeSouth EuropeCentral Europe 
 
 
 
 
Figure A10.4: Average age of passenger cars per EU Member State in 2015 

Source: Eurostat, [road_eqs_carage] 

244 

0%10%20%30%40%50%60%70%80%90%100%LTROLVCYPLHUHREEMTSIESCZFIFRDEUKSEAUIEBELU< 2 years 2 to 5 years 5 to 10 years> 10 years 
 
 
 
 
 
 
ANNEX 11 – COOPERATIVE, CONNECTED AND AUTOMATED MOBILITY (CCAM) 

The  European  Commission  European  Strategy  on  Cooperative  Intelligent  Transport 
Systems (C-ITS)188 is a milestone initiative towards cooperative, connected and automated 
mobility. The objective of the C-ITS Strategy is to facilitate the convergence of investments 
and legal frameworks across the EU, in order to see deployment of mature C-ITS services in 
2019 and beyond. As announced in the Communication and confirmed by public statements 
of the automotive industry189 and sizeable investments from Member States, united in the C-
ROADS Platform190, the 2019 target for large-scale C-ITS deployment is now becoming a 
reality. 

In many respects today’s vehicles are already connected devices. However, in the very near 
future  they  will  also  interact  directly  with  each  other  and  with  the  road  infrastructure  (C-
ITS),  which  will  allow  road  users  and  traffic  managers  to  share  information  and  use  it  to 
coordinate  their  actions  so  as  to  facilitate  mobility.  This  cooperative  element,  enabled  by 
digital  connectivity  between  vehicles  and  between  vehicles  and  transport  infrastructure,  is 
expected to significantly improve road safety, traffic efficiency and comfort of driving, by 
helping the driver to take the right decisions and adapt to the traffic situation.  

The beneficial effect of connectivity, experienced by increasing driver's/users awareness, is 
achieved by various ways like messages transmitted via smart phones, navigator devices as 
well  as  Internet  of  Things  applications.  The  concept  of  Vehicle-to-vehicle  (V2V)  and 
vehicle-to-infrastructure  (V2X)  communication  is  however  not  yet  mature  enough  for 
widespread incorporation in vehicles. This may be viewed as a problem, as communication 
between  vehicles,  infrastructure  and  other  road  users  is  crucial  to  increase  the  safety  of 
future  connected  and  automated  vehicles  and  for  their  full  integration  in  the  overall 
transport system. Cooperation, connectivity, and automation are technologies that reinforce 
each other when it comes to offer increased mobility safety services to the end-user.  

In  this  context,  with  the  progressing  digitisation  of  infrastructure  and  vehicles  the  EU 
Network  Information  Security  (NIS)  Directive  comes  into  play,  covering  operators  of 
essential  services  (including  transport  and  digital  infrastructure)  as  well  as  digital  service 
providers.  In  addition,  cybersecurity  aspects  should  not  be  neglected.  The  "cyber  security 
package" adopted in September, supports a voluntary certification scheme for cybersecurity 
in the mobility sector, ultimately resulting in an "EU cyber secure" label. 

The  European  Commission  adopted  a  European  Strategy  on  Cooperative  Intelligent 
Transport  Systems  (C-ITS)191,  a  milestone  initiative  towards  cooperative,  connected  and 
automated mobility. The objective of the C-ITS Strategy is to facilitate the convergence of 
investments and legal frameworks across the EU, in order to see deployment of  mature C-
ITS services in 2019 and beyond. 

188   COM (2016) 766 
189   https://www.car-2-car.org/index.php?eID=tx_nawsecuredl&u=0&g=0&t=1507893218&hash=13650cd84c 

30c1624e2860180968b35a2c532ad0&file=fileadmin/downloads/PDFs/C2C-CC_Press_Information_on_ 
EC_Masterplan_final.pdf 

190   www.c-roads.eu 
191   COM (2016) 766 

245 

 
 
 
                                                 
As announced in the Communication and confirmed by public statements of the automotive 
industry192  and  sizeable  investments  from  Member  States,  united  in  the  C-ROADS 
Platform193, the 2019 target for large-scale C-ITS deployment is now becoming a reality. To 
progress  towards  this  shared  goal  important  work  on  security,  data  protection  and 
compliance  assessment  is  required  and  key  advances  in  these  areas  were  achieved  during 
the second phase of the C-ITS platform. 

In  addition,  the  European  Commission  adopted  a  strategy  for  deployment  of  5G  GSM 
technologies194 and to foster the collaboration between telecom and automotive industries by 
organising  Roundtable  sessions195  which  resulted  in  the  establishment  of  the  European 
Automotive Telecom Alliance (EATA)196 and the 5G Automotive Alliance (5GAA)197. 

The  Amsterdam  Declaration  on  cooperation  in  the  field  of  connected  and  automated 
driving198 was signed by the transport ministers of all EU Member States on 14 April 2016. 
It  lays  down  agreements  on  the  steps  necessary  for  the  development  of  self-driving 
technology in the EU. It notably invites the automotive industry, that welcomed199 it as an 
important  milestone  promoting  much-needed 
automobile 
manufacturers,  national  governments  and  the  EU  institutions,  to  acknowledge  that 
standardisation will be a key factor in driving scale, both at the European and international 
level,  and  to  support  the  development  of  standards  in  the  relevant  domains  through 
developing  V2V  and  V2X  communication  systems  and  continue  standardisation  work  to 
ensure that new services and systems are interoperable at EU level.  

cooperation  between 

In  March  2017,  in  the  margin  of  the  60th  anniversary  of  the  signature  of  the  Treaties  of 
Rome, during the Digital Day in  Rome, 27  Member States, plus  Norway and Switzerland 
acknowledged  the  importance  of  cross-border  cooperation  on  Connected  and  Automated 
Driving  (CAD)  by  signing  the  Letter  of  Intent  (LoI)200  on  the  testing  and  large  scale 
demonstrations. 

The follow-up of Member States initiatives is further discussed in the High Level Structural 
Dialogue. The 2nd meeting took place in September 2017 and resulted in the ''Action plan 
for    connected  and  automated  driving  (CAD)''  addressing  key  issues  like  cross-border 

192   https://www.car-2-car.org/index.php?eID=tx_nawsecuredl&u=0&g=0&t=1507893218&hash=13650cd84c 
30c1624e2860180968b35a2c532ad0&file=fileadmin/downloads/PDFs/C2C-CC_Press_Information_on_ 
EC_Masterplan_final.pdf 

193   www.c-roads.eu 
194  Communication  from  the  European  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic  and  Social  Committee  and  the  Committee  of  the  Regions:  "5G  for  Europe:  An  Action  Plan"  - 
COM(2016)588 and Staff Working Document - SWD(2016)306 

195   https://ec.europa.eu/digital-single-market/en/cooperative-connected-and-automated-mobility-europe. 
196 

http://www.acea.be/press-releases/article/37-leading-companies-join-forces-in-european-automotive-

telecom-alliance 
197    http://5gaa.org/ 
198   https://www.rijksoverheid.nl/binaries/rijksoverheid/documenten/rapporten/2016/04/29/declaration-of-
amsterdam-cooperation-in-the-field-of-connected-and-automated-driving/declaration-of-amsterdam-
cooperation-in-the-field-of-connected-and-automated-driving.pdf 

199   http://www.acea.be/press-releases/article/ministers-eu-policymakers-and-auto-industry-push-for-connected-

and-automate 

200  https://ec.europa.eu/digital-single-market/en/news/eu-and-eea-member-states-sign-cross-border-experiments-

cooperative-connected-and-automated. 

246 

 
 
 
                                                 
 
cooperation on testing, public awareness, social impact and ethical issues, data access and 
use as well as international standardization. 

Justification for discarding this option 

As  part  of  another  area  not  covered  by  the  scope  of  the  regulatory  framework  and  this 
impact assessment, the ITS Directive 2010/40/EU201 with its Delegated Acts on road safety, 
real-time-traffic  and  multimodal  travel  information,  providing  the  necessary  legal  and 
technical framework to steer and ensure the interoperability of deployed ITS services, is  a 
suitable example. Specifications and standards for aspects related to the exchange of data or 
information between vehicles or between vehicles and infrastructure are also highlighted as 
important,  but  concrete  prescriptions  do  not  yet  exist.  The  automotive  industry  could 
therefore  take  the  initiative  and  to  consider  a  self-regulatory  approach  to  lead  the 
development  of  V2V  and  V2X  standards  on  European  and  international  level.  It  would 
cover  a  forward-looking  approach  on  issues  such  as  how  to  deal  with  data  security,  data 
protection, communication protocols, interoperability and compliance assessment processes. 

In this context it may also be appropriate to consider whether or not the EU should impose a 
specific technology and communication protocol. However, given that there is no clarity yet 
on  the  best  way  forward,  as  indicated  above,  it  must  be  noted  that  it  is  premature  at  this 
stage to already elaborate or commit to a decision concerning these far reaching regulatory 
aspects and that this should be part of a future assessment of impacts in due course. 

The  self-regulation  approach  to  address  the  need  for  implementation  of  V2V  and  V2X 
communications  is  in  principle  also feasible,  but  given  that  a  sensible  and  comprehensive 
analysis  of  the  cost-benefits  was  deemed  very  premature  at  this  stage,  it  should  be  taken 
forward  to  be  part  of  a  separate  track  in  the  overall  context  of  C-ITS  developments. 
Therefore the self-regulatory approach had to be discarded from further analysis. There are 
however anticipated benefits202 in terms of road casualty reduction in the EU through future 
(voluntary) implementation of V2V and V2X communications, but this information is of a 
considerable high-level nature with many uncertainties and subsequent assumptions. 

201   Directive 2010/40/EU of the European Parliament and of the Council of 7 July 2010 on the framework for 
the deployment of Intelligent Transport Systems in the field of road transport and for interfaces with other 
modes of transport (OJ L 207, 6.8.2010, p. 1) 

202   https://ec.europa.eu/transport/sites/transport/files/2016-c-its-deployment-study-final-report.pdf 

247 

 
 
 
 
 
 
                                                 
ANNEX 12 – LIST OF TERMS AND ABBREVIATIONS USED IN THE ANNEXES 

Term/abbreviation  Explanation 

5GAA 
ABS 
ACEA 
AEB 
AEB-PCD 
AEB-VEH 

ALC 
BAS 
BCR 
CAD 
CARE database 
CARS 21 

CCAM 
C-ITS 
CLEPA 
C-ROADS 
Platform 

DDR-ADR 
DDR-DAD 
DG 
EATA 
ECMT 
EDR 
EFTA 
EGNOS 
EPA 
ESC 
ESS 
ETRMA 
EU 
Euro NCAP 

FFW-137 

5G Automotive Alliance 
Anti-Lock Braking System 
European Automobile Manufacturers’ Association 
Autonomous Emergency Braking 
Autonomous emergency braking for pedestrians and cyclists 
Autonomous emergency braking for driving and still-standing vehicles 
ahead 
Alcohol interlock installation facilitation 
Brake Assist System 
Benefit-to-Cost Ratio 
Connected and Automated Driving 
Community Road Accident Database 
The Competitive Automotive Regulatory System for the 21st century 
High Level Group on the competitiveness and sustainable growth of the 
automotive industry in the EU with representatives of the EU Member 
States, EU institutions, automotive industry, Trade Unions, NGO, users 
and the Commission. 
Cooperative, Connected and Automated Mobility 
Cooperative Intelligent Transport Systems 
European Association of Automotive Suppliers 
The C-Roads Platform is a joint initiative of European Member States 
and road operators for testing and implementing C-ITS services in light 
of cross-border harmonisation and interoperability. 
Distraction recognition 
Drowsiness and attention detection 
Directorate-General 
European Automotive Telecom Alliance 
European Conference of Ministers of Transport 
Event (accident) Data Recorder 
European Free Trade Association 
European Geostationary Navigation Overlay Service 
United States Environmental Protection Agency 
Electronic Stability Control 
Emergency Stop Signal 
European Tyre and Rubber Manufacturers' Association 
European Union 
European New Car Assessment Programme is a voluntary European car 
safety performance assessment program backed by the European 
Commission and several European governments, as well as by motoring 
and consumer organisations. Euro NCAP publishes safety reports on 
new cars, awarding ‘star ratings’ based on the performance of the 
vehicles in a variety of crash tests, including front, side and pole 
impacts, and impacts with pedestrians. The top rating is five stars. 
Full-width frontal occupant protection crash test 

248 

 
 
 
HED-MGI 

FFW-THO 

LDV 
LDW 
LKA-ELK 

IA 
ISA 
ISA-VOL 
ISO  
ISOFIX 
ITS Directive 

Full-width frontal occupant protection crash test with advanced 
measuring dummy and lower appropriate injury criteria thresholds to 
encourage adaptive restraints 
Global Navigation Satellite System 
General Safety Regulation 
Heavy Duty Vehicles 

GNSS 
GSR 
HDV 
HEATCO project   Developing Harmonised European Approaches for 
Transport Costing and Project Assessment project 
Head impact zone enlargement for pedestrian and cyclist protection (to 
include the windscreen area) 
Impact Assessment  
Intelligent Speed Assistance 
Intelligent Speed Assistance (through non-intrusive haptic feedback) 
International Organisation for Standardisation 
The international standard for child seat connectors 
Intelligent Transport Systems Directive - Directive 2010/40/EU of the 
European Parliament and of the Council of 7 July 2010 on the 
framework for the deployment of Intelligent Transport Systems in the 
field of road transport and for interfaces with other modes of transport 
Light Duty Vehicles 
Lane Departure Warning 
Lane Keeping Assist (emergency lane keeping system that intervenes 
only in case of an imminent threat such as leaving the road, or leaving 
the lane with oncoming traffic) 
Letter of Intent 
Maximum Abbreviated Injury Scale 
Member of the European Parliament 
Multi Purpose Vehicle 
Non-Governmental Organisation 
United States National Highway Traffic Safety Administration 
Network Information Security Directive - Directive (EU) 2016/1148 of 
the European Parliament and of the Council of 6 July 2016 concerning 
measures for a high common level of security of network and 
information systems across the Union 
Original Equipment Manufacturer / vehicle manufacturer 
Policy Option 
Price-Induced Market Equilibrium System - Transport Energy Demand 
Transport Model 
Pole Side Impact Occupant Protection 
Pedestrian Safety Regulation 
Reversing Camera or Detection System  
Research and Development 
Regulatory Scrutiny Board 
Society of Automotive Engineers 
Safety Belt Reminder 
Small and Medium-Sized Enterprises 
Sport Utility Vehicle 
European Federation for Transport and Environment 

OEM 
PO 
PRIMES-
TREMOVE 
PSI 
PSR 
REV 
R&D 
RSB 
SAE 
SBR 
SMEs 
SUV 
T&E 

LoI 
MAIS 
MEP 
MPV 
NGO 
NHTSA 
NIS Directive  

249 

 
 
 
TFEU 
TNO 
TPM / TPMS 
TRL 

UNECE 
V2V 
V2X 
VIS-DET 
VIS-DIV 

Treaty on the Functioning of the European Union 
Netherlands Organisation for Applied Scientific Research 
Tyre pressure monitoring (system) 
Formerly the UK Government's Transport Research Laboratory 
subsequently transformed into a private company in 1996 
United Nations Economic Commission for Europe 
Vehicle-to-Vehicle 
Vehicle-to-Infrastructure 
Vulnerable road user detection and warning on front and side of vehicle 
Vulnerable road user improved direct vision from driver’s position 

250