REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers repealing Directive 2009/40/EC
Date: 2020-11-11
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: EU Member State, application of EU law, motor vehicle, road safety, roadworthiness tests, technical regulations

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 11.11.2020  COM(2020) 699 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers repealing Directive 2009/40/EC                   
 
 
Table of Contents 

1. 

2. 

3. 

Introduction ................................................................................................................ 2 

The Directive ................................................................................................................ 3 

National transposition measures notified by the Member States and the 
preliminary findings of their assessment ...................................................................... 3 

4.   

  Feasibility study on the electronic vehicle information platform………………11 

5.   

  Summary – conclusions………………………………………………………13 

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1. 

INTRODUCTION 

1.1.Background  

Vehicle inspections are fundamental to road safety and to ensure environmental performance 
of vehicles. The EU rules setting minimum standards for vehicle checks dated back to 1977, 
with only minor updates. However, vehicles, driver behaviour and technology have developed 
a lot since then. The first substantial change in the roadworthiness inspection framework was 
introduced with the adoption of the Roadworthiness Package1 in 2014. It had three parts, the 
periodic roadworthiness tests, the technical roadside inspections of commercial vehicles, and 
the vehicle registration documents.  

The  proposal  of  the  Roadworthiness  Package  in  2012  was  prompted  by  the  Commission’s 
2010 policy orientations on road safety2. Under “objective no 4: Safer vehicles” of the policy 
orientations the Commission defined the action to “make proposals in view of the progressive 
harmonisation  and  strengthening  of  roadworthiness 
technical  roadside 
inspections”. 
Directive 2014/45/EU3  on the periodic  roadworthiness tests  (hereinafter ‘the Directive’) has 
applied  from  20  May  2018  and  it  introduced  substantial  novelties  compared  to  Directive 
2009/40/EC4.   

tests  and 

The novelties include: 

 

Improving  the  quality  of  vehicle  tests  by  setting  common  minimum  standards  for 
equipment, training of inspectors and assessment of deficiencies. 

  Making  electronic  safety  components  (such  as  ABS,  ESC  and  air-bag)  subject  to 

mandatory testing. 

  First European measures to combat odometer fraud. 

  Compulsory  EU  wide  testing  for  heavy  motorbikes  unless  a  Member  State  achieves 

equivalent road safety enhancement by other measures.  

  Compulsory EU wide testing of high-speed tractors used for commercial road haulage 

purposes.  

  Mutual  recognition  of  the  roadworthiness  certificate  during  the  re-registration 
procedure, where the frequency of testing is  the same in  the Member State of origin 
and in the Member State of destination. 

1.2. The purpose and scope of this report 

Pursuant  to  Article  20(1)  of  the  Directive  the  Commission  should  draw  up  a  report  by  30 
April  2020  and  pursuant  to  Article  20(2)  a  report  by  30  April  2019.  The  Commission  fully 
acknowledges and deeply regrets the late submission of these reports.   

1 https://ec.europa.eu/transport/road_safety/events-archive/2014_04_30_rwp_en  
2 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social  Committee  and  the  Committee  of  the  Regions,  Towards  a  European  road  safety  area:  policy 
orientations on road safety 2011-2020, COM(2010) 389 final. 

3  Directive  2014/45/EU  of  the  European  Parliament  and  of  the  Council  of  3 April  2014  on  periodic 
roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC, OJ L 127, 
29.4.2014, p. 51–128 

4 Directive 2009/40/EC of the European Parliament and of the Council of 6 May 2009 on roadworthiness tests 

for motor vehicles and their trailers, OJ L 141, 6.6.2009, p. 12–28 

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The report according to Article 20(1) should  

  provide information  on the implementation  and effects  of the Directive, in particular 
as  regards  the  level  of  harmonisation  of  periodic  roadworthiness  tests,  the 
effectiveness  of the provisions on its scope, the frequency of testing, and the mutual 
recognition  of  roadworthiness  certificates  in  cases  of  re-registration  of  vehicles 
originating from another Member State;  

  cover  the  results  of  the  examination  concerning  the  feasibility  of  introducing  an 

electronic vehicle information platform5; 

  analyse  whether  there  is  a  need  to  update  the  Annexes,  particularly  in  the  light  of 

technical progress and practices.  

The report should be consulted by the respective committee and it should be accompanied by 
legislative proposals if appropriate.    

The report according to Article 20(2) should  

  provide information on the effectiveness of the inclusion of light trailers and two- or 
three- wheel vehicles in the scope of the Directive, based on independent studies; 
  assess the evolution of the road safety situation in the Union and, for each subcategory 
of  the  two-  or  three-  wheel  vehicles  compare  the  results  of  national  road  safety 
measures, taking into account the average distance travelled by those vehicels;   

  assess the standards and costs of periodic roadworthiness testing of each category of 

vehicle is proportionate to the road safety objectives set;   

  be  accompanied  a  detailed  impact  assessment  analysing  the  costs  and  benefits 

throughout the Union, including the specificities of the Member States.  

 As mentioned above, the Directive has applied from 20 May 2018. In order to generate data 
to  draw  meaningful  conclusions,  on  average  an  uninterrupted  period  of  application  of  three 
years  is  required.  Therefore  the  data  collection  that  will  enable  drawing  conclusions 
concerning the effects of the Directive may start in the second half of 2021 the earliest.  

In this respect, this report aims at providing an overview of the implementation actions of the 
Member States based on the preliminary findings of the transposition control as well as of the 
results of the feasibility study on the electronic vehicle information platform6.  

However as regards the inclusion of two- or three- wheel vehicles, it should be noted that their 
periodic  roadworthiness  testing  will  only  start  from  1  January  2022,  which  may  allow  for 
meaningful  conclusions  in  2025  the  earliest.  As  far  as  the  effectiveness  of  the  inclusion  of 
light trailers is concerned, it should be noted that light trailers have not yet been included in 
the scope of the Directive, thus the effects of their inclusion cannot be analysed.  

Finally, it should be noted that contrary to  what was initially proposed  by the Commission, 
light  trailers  were  ultimately  not  included  in  the  scope  of  the  Directive.  Nevertheless,  the 
majority of the Member States have introduced this additional vehicle category to the periodic 
roadworthiness  testing  regime.  However,  as  mentioned  above,  in  order  to  be  able  to  draw 
meaningful  conclusions,  on  average  an  uninterrupted  period  of  application  of  three  years  is 
required.      

5 as referred to in Article 16 
6 https://op.europa.eu/en/publication-detail/-/publication/9d809050-2e78-40a4-be65-16ce40a8e8b8/language-en  

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2. 

THE DIRECTIVE  

2.1 The scope of the Directive and responsibilities 

The Directive kept the principle of Directive 2009/40/EC that the roadworthiness tests have to 
be carried out by the Member State of registration of the vehicle.  

The Directive also kept the mandatory testing for both safety and environmental performance 
for all vehicles which have already been tested regularly according to Directive 2009/40/EC, 
i.e.  for  passenger  cars,  light  and  heavy  duty  vehicles  carrying  persons  or  goods  as  well  as 
heavy trailers.  

However there are two new groups of vehicles: 

 

 

the  testing  of  tractors  with  a  maximum  design  speed  exceeding  40  km/h 
(speed-tractors), if they  are mainly used on public roads for commercial road 
haulage purposes, and  
the testing of some two- or three-wheel vehicles with an engine displacement 
of more than 125 cm3 as of 1 January 2022.   

In  some  cases  the  Directive  provides  Member  States  the  option  to  exclude  certain  vehicles, 
registered  in  their  territory,  from  the  testing  regime,  such  as  vehicles  of  historical  interest, 
vehicles  covered  by  diplomatic  immunity  or  vehicles  used  exclusively  on  small  islands  or 
sparsely populated areas.  

In  the  case  of  the  newly  added  two-  or  three-wheel  vehicles,  the  Directive  allows  Member 
States to exclude them from the roadworthiness testing, if they have put in place alternative 
road safety measures, taking into account in particular relevant road safety statistics covering 
at least five years. 

Member States have to notify the exemptions to the Commission.    

2.2 The frequency of testing; Contents and methods for testing 

There  was  no  change  in  how  often  vehicles,  already  tested  according  to  Directive 
2009/40/EC, need to undergo testing. The Directive also kept the testing frequency flexible, 
allowing Member States to apply shorter periods between two inspections.   

A new element is related to the vehicle categories newly added to the testing regime. Speed-
tractors  have  to  be  tested  the  first  time  four  years  after  their  first  registration  and  thereafter 
every two years.  

The testing frequency for the two- or three-wheel vehicles is not defined by the Directive but 
is  left  to the Member States, the same as the areas to  test and the contents and methods for 
testing.    

For  all  other  vehicle  categories  harmonised  minimum  requirements  are  set  out  in  detail  by 
Annex  I  to  the  Directive.  It  defines  the  items  to  be  tested,  the  content,  the  methods,  the 
reasons for failure and their classification.  

The  Directive  introduced  a  solution  if  the  vehicle  would  need  an  inspection  before  the  due 
date of the next periodic test. Member States may require the vehicle to undergo an inspection 
for example after an accident, if some systems of the vehicle have been altered or they may 
check the vehicle more frequently when the vehicle has reached 160 000 km.  

2.3 Assessment of deficiencies  

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In  2010  the  Commission  adopted  a  recommendation7  in  order  to  provide  guidance  to 
inspectors and to ensure harmonised assessment of the defects listed in Annex II to Directive 
2009/40/EC.  The  recommendation  introduced  three  defect  categories  (minor,  major  and 
dangerous) and defined the category for each defect as guidance.  

Based  on  the  recommendation  the  Directive  introduced  the  assessment  of  deficiencies  as  a 
harmonised measure. Depending on their severity defects can be minor, major or dangerous 
and  refer  to  the  safety  or  the  environmental  performance  of  the  vehicle.  Where  several 
defects,  falling  in  different  severity  categories,  are  found  during  a  roadworthiness  test,  the 
vehicle has to be classified according to the more serious deficiency. Additionally, if a vehicle 
shows  several  defects  of  the  same  inspection  area  (such  as  braking  or  steering)  the  vehicle 
may  be  classified  in  the  next  most  serious  deficiency  group  if  the  combined  effects  of  the 
defects result in a higher risk to road safety.            

2.4 The follow-up of deficiencies  

One of the most important novelties of the Directive was the harmonisation of the follow-up 
measures  depending  on  the  severity  of  the  defect(s)  identified  during  a  periodic 
roadworthiness test.  

In case the vehicle has only minor defects, they have to be rectified but the vehicle passes the 
roadworthiness test and will not be retested after the repair.  

If  major  or  dangerous  defect(s)  has  been  found,  the  roadworthiness  test  is  failed  and  the 
vehicle has to be submitted to a new test once the defect(s) has been rectified. In case of major 
deficiencies, the vehicle has to be retested not later than two months after the initial test and 
the  vehicle  may  be  used  during  this  period.  However  in  case  of  dangerous  deficiencies,  the 
authorities  may  suspend  the  registration  of  the  vehicle  by  that  forbidding  the  use  of  the 
vehicle in road traffic until the defects are rectified and a roadworthiness certificate is issued.       

2.5 The  roadworthiness  certificate  and  the  proof  of  test;  Administrative  cooperation 

between Member States 

The  roadworthiness  certificate  with  a  harmonised  minimum  content  was  introduced  by 
Commission Directive 2010/48/EU8 as of 31 December 2013. 

One of the novelties added by the Directive is,  that all mandatory elements  have to  be now 
preceded by a harmonised Union code, which facilitates the identification and understanding 
of the most relevant information displayed on the otherwise not harmonised document.  

Building  on  the  harmonised  elements  of  the  roadworthiness  certificate,  one  of  the  most 
important novelty of the Directive is the mutual recognition of roadworthiness certificates for 
the  purpose  of  re-registration.  By  this,  the  Directive  set  halt  to  the  systematic  testing  of 
vehicles before re-registration regardless if they have a valid roadworthiness certificate. The 
only  limit  to  the  mutual  recognition  is,  that  at  the  time  of  the  re-registration,  the 

7  Commission recommendation on the assessment of defects during roadworthiness testing in accordance with 
Directive 2009/40/EC of the European Parliament and of the Council on roadworthiness tests for motor vehicles 
and their trailers (2010/378/EU) 

8Commission Directive 2010/48/EU of 5 July 2010 adapting to technical progress Directive 2009/40/EC of the 
European Parliament and of the Council on roadworthiness tests for motor vehicles and their trailers; OJ L 173; 
8.7.2010; p. 47 

5 

 
 
  
                                                           
 
 
roadworthiness  certificate has  to  be valid in  terms  of the frequency intervals  established for 
periodic  roadworthiness  tests  by  the  re-registering  Member  State.  This  can  be  the  case  for 
example if a passenger car has been imported from a Member State with a testing frequency 
of 4-2-2 and is being re-registered in a Member State with a testing frequency of 3-1-1.       

Another important measure of the Directive is, that where the re-registering Member State has 
doubts  about  the  validity  of  the  roadworthiness  certificate,  it  may  verify  its  validity  before 
recognising it. For this purpose Member States’ authorities can use the national contact points 
appointed  and  notified  to  the  Commission.  The  Commission  has  drawn  up  a  list  of  the 
notified national contact points, has updated it based on the subsequent notifications and has 
regularly distributed to the Member States.    

Member  States  were  obliged  to  communicate  to  the  Commission  a  description  of  the 
roadworthiness certificate before 20 May 2018.           

The  Directive  introduced  significant  measures  concerning  the  communication  between  the 
testing  centres  and  the  competent  authorities.  Testing  centres  have  to  communicate  the 
information  mentioned  in  the  roadworthiness  certificate  electronically  and  in  a  reasonable 
time after they issued the roadworthiness certificate. However in order to have enough time to 
carry out the necessary developments, Member States have time until 20 May 2021 to ensure 
that  the  electronic  communication  is  up  and  running.  Finally,  to  connect  the  periodic 
roadworthiness  testing  with  the  electronic  vehicle  register  introduced  by  Directive 
2014/46/EU9,  Member  States  have  to  notify  the  results  of  the  roadworthiness  test  to  the 
registration authority.  

2.6 Odometer fraud  

The Directive is  the first  European legislation that introduced harmonised measures  to  fight 
odometer  fraud.  It  addresses  odometer  fraud  from  the  perspective  of  the  periodic 
roadworthiness testing by obliging Member States to ensure that the odometer data recorded 
at  the  previous  roadworthiness  test  is  made  available  to  the  inspector  carrying  out  the  next 
inspection. The information needs to be made available electronically as soon as possible.    

Additionally, Member States have to  introduce effective, proportionate, dissuasive and non-
discriminatory penalties for the case where an odometer is found to have been manipulated. 

2.7 Testing  centres,  testing  facilities  and  equipment,  supervision  of  the  testing  centres, 

inspectors 

The Directive introduced a number of harmonised requirements for the testing centres.  

  Testing centres have to be authorised by a Member State or by its competent authority. 
  Annex  III  lays  down  minimum  technical  requirements  for  testing  facilities  and 

equipment and Member States are obliged to ensure the compliance.  

  Member States have time until 20 May 2023 to ensure that all testing centres comply 

with the minimum technical requirements.  

To  ensure  that  testing  centres  continuously  comply  with  the  requirements,  Member  States 
have  to  ensure  that  they  are  supervised.  By  1  January  2023  the  supervising  bodies  have  to 
fulfil the requirements and carry out the tasks set out in Annex V to the Directive, such as  

 

requirements concerning the supervising body; 

9  Directive  2014/46/EU  of  the  European  Parliament  and  of  the  Council  of  3 April  2014  amending  Council 
Directive 1999/37/EC on the registration documents for vehicles, OJ L 127, 29.4.2014, p. 129- 133 

6 

 
 
 
                                                           
  contents of the rules and procedures; 
  verifying training and examination of inspectors; 
  checking  whether  the  minimum  requirements  for  premises  and  test  equipment  are 

met; 

  validation of measurement results of roadworthiness tests; 
  proposing the withdrawal or suspension of authorisation of testing centres and/or of 

inspectors; 

An important, newly introduced requirement is, that the results of a roadworthiness test may 
only be modified if the findings are manifestly incorrect. The modification has to be in line 
with the procedure set up by the competent authority or carried out by the supervising body.   

In order to ensure that the inspectors performing roadworthiness tests have a certain level of 
knowledge and skills and that they receive regular training, the Directive introduced a number 
of measures. In its Annex IV, the Directive sets  out harmonised minimum competences and 
experience, which are the prerequisite to be authorised as an inspector. Additionally, Annex 
IV also sets out the minimum content of the initial and refresher training inspectors have to 
follow.  Only  inspectors  employed  or  authorised  by  competent  authorities  of  the  Member 
States  or  by  a  testing  centre  at  20  May  2018  are  exempted  from  the  newly  defined 
requirements.  

Inspectors  who  fulfil  the  minimum  competence  and  training  requirements  have  to  receive  a 
certificate from the competent authorities or approved training centres. Annex IV also defines 
the minimum content of the certificate that has to be issued. 

2.8 The electronic vehicle information platform  

The  Directive  set  out  for  the  Commission  to  carry  out  a  feasibility  study  of  establishing  an 
electronic  vehicle  information  platform.  The  requirements  to  be  taken  into  account  during 
carrying out the study were,  

  To consider existing and already implemented international data exchange solutions;  
 
to consider the most appropriate way to link the existing national systems in order to 
facilitate  the  data  exchange  on  roadworthiness  testing  and  odometer  readings 
between  the  competent  authorities  of  Member  States  responsible  for  testing, 
registration and vehicle  approval,  testing centres, test equipment  manufacturers and 
vehicle manufacturers; 

Additionally the Directive required the Commission to carry out a feasibility study on  

  how available information concerning the main safety-related components of vehicles 

which have been involved in serious accidents could be stored and collected,  

  how information on accident history and odometer readings could be made available 
in an anonymised form to inspectors, holders of registration certificates and accident 
researchers.  

3. 

NATIONAL TRANSPOSITION MEASURES NOTIFIED BY THE MEMBER STATES AND THE 
PRELIMINARY FINDINGS OF THEIR ASSESSMENT  

3.1 National transposition measures notified by the Member States  

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Member States had to  adopt  and publish the national measures  required  to  comply with  the 
Directive  by 20 May 2017 and subsequently notify them  to  the Commission.  The measures 
have applied from 20 May 2018.  

By  20  May  2017  only  6  of  the  28  Member  States  informed  the  Commission  that  the 
transposition  of  the  Directive  had  been  completed.  In  line  with  the  procedural  rules,  the 
Commission  launched  infringement  procedures  urging  the  other  22  Member  States  to  adopt 
the required national transposition measures. The launch of the infringement procedures was 
the basis of intensive exchanges with the Member States and in the majority of the cases it led 
to  the  notification  of  the  missing  national  transposition  measures.  There  are  two  Member 
States, the Netherlands and Poland, which have declared that the transposition of the Directive 
is  only  partial.  The  necessary  actions,  to  force  these  Member  States  to  comply  with  their 
obligation to ensure the transposition of the Directive, are under way.           

3.2 Preliminary findings  

In  order  to  gain  a  preliminary  assessment  of  the  national  transposition  measures  on  their 
compliance  with  the  Directive’s  requirements,  the  Commission  has  contracted  an  external 
contractor. The findings of the contractor are being further analysed by the Commission, the 
work is expected to be finalised in the coming months.   

3.2.1  The scope of the Directive and responsibilities  

According to the preliminary analysis of the national transposition measures, the inclusion of 
speed-tractors  and  the  two-  and  three  wheel  vehicles  was  challenging  for  some  Member 
States, while only minor issues could be detected in relation to the vehicle categories having 
already been part of the testing regime.  
It  seems  that  agricultural  vehicles  are  in  general  not  registered  in  some  Member  States10, 
which made the introduction of periodic testing for these vehicles challenging.  

Only  two  Member  States,  Ireland  and  the  Netherlands,  have  notified  alternative  road  safety 
measures and consequently excluded the testing of two- and three wheelers. Considering that 
the  periodic  testing  of  these  vehicles  will  be  only  due  from  1  January  2022,  many  Member 
States  were  late  with  the  adoption  and  notification  of  the  transposing  national  measures, 
noting  that  the  actual  application  date  would  allow  for  some  additional  time  for  the 
transposition.   

Other exclusion categories of the Directive which the majority of Member States (18) made 
use of concern 

  vehicles  never  or  hardly  ever  used  on  public  roads,  such  as  vehicles  of  historical 

interest or competition vehicles; 

  vehicles used by armed forces, fire services, civil protection service and emergency or 

rescue services. 

Additionally,  some  Member  States  benefited  from  the  opportunity  to  exclude  vehicles  used 
for  agricultural,  horticultural,  forestry,  farming  or  fishery  purposes  and  vehicles  used 
exclusively in small islands or sparsely populated areas.     

10  Note:  In  the  absence  of  European  legislation,  it  is  a  national  competence  to  decide,  which  vehicles  are 

registered and consequently issued a vehicle registration document and licence plate(s).   

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The majority of the Member States (18) have introduced additional vehicle categories to the 
periodic  roadworthiness  testing  regime,  mainly  smaller  trailer  categories  (O1,  O2),  further 
two- and three wheeler categories and agricultural vehicles.     

3.2.2  The frequency of testing; Contents and methods for testing 

It seems that most Member States kept the frequency of testing they already have established 
in  line  with  Directive  2009/40/EC,  which  means  that  in  some  cases  Member  States  have 
shorter frequencies, than those set out by the Directive as minimum requirements, mainly for 
passenger cars, such as Austria (3-2-1), Croatia (1-1-1) or Germany (3-2-2).   

The  preliminary  analysis  indicated  that  Member  States  did  not  have  problems  with 
introducing the testing frequency for the new category of speed-tractors (4-2-2).   

As  mentioned  above,  the  Directive  required  Member  States  to  define  the  testing  frequency, 
thee items to be tested, the methods and the reasons for failures as regards the two- or three-
wheel vehicles, thus providing a lot of flexibility to the Member States. Some examples are 
Germany introduced a test frequency of 2-2-2, Spain 4-2-2, Croatia 2-1-1.    

Based  on  the  preliminary  assessment  it  seems  that  some  Member  States  chose  the  literal 
transposition of Annex  I to  the Directive concerning the items  to  be tested, the  content, the 
methods,  the  reasons  for  failure  and  their  classification.  Some  Member  States  however 
transposed the measures of Annex I in several different national acts making the identification 
and  assessment  of  the  national  transposition  measures  of  this  highly  technical  Annex  more 
challenging. 

The  optional  measures  allowing  Member  States  to  require  the  vehicle  to  undergo  an 
inspection  before  the  due  date  of  the  next  periodic  test  (see  point  2.2  above),  were  not 
introduced  in  their  entirety.  It  seems  that  the  two  cases  introduced  by  most  Member  States 
are:  

  where  the  vehicle  was  subject  to  an  accident  and  it  affected  its  main  safety-related 
components, such as wheels, suspension, deformation zones, airbag systems, steering 
or brakes (about 19 Member States), and  

  where the safety and environmental systems and components of the vehicle have been 

altered or modified (about 12 Member States).  

It seem that about 10 Member States introduced testing for all other cases where road safety is 
seriously  affected.  However,  it  seems  that  only  three  Member  States  intend  to  require  the 
vehicle to pass a periodic test where the holder of the registration certificate of a vehicle has 
changed  and  only  one  would  like  to  submit  vehicles  with  higher  mileage  (160 000   km)  to 
more frequent testing.   

3.2.3  Assessment of deficiencies 

Possibly  owing  to  the  recommendation  of  2010,  the  preliminary  assessment  of  the  national 
transposition  measures  has  not  identified  potential  substantial  non-compliance  issues 
concerning the now mandatory defect categories (minor, major and dangerous).  

Possible  issues  that  might  require  clarifications  in  upcoming  exchanges  with  the  Member 
States  concern  the  case,  where  several  defects,  falling  in  different  severity  categories,  are 
found during a roadworthiness test, and the vehicle has to be classified according to the more 
serious deficiency. 

3.2.4  The follow-up of deficiencies  

9 

 
 
The preliminary assessment of the national measures did not raise any particular concerns in 
relation to the follow-up measures of defects found during the inspection. 

3.2.5  The  roadworthiness  certificate  and  the  proof  of  test;  Administrative 

cooperation between Member States  

A number of problems emerged in relation to the requirements of the Directive:  

  Several  Member States  did  not  communicate the description of the roadworthiness 
certificate on time despite several reminders and requests sent by the Commission.  
In  many  cases  Member  States  did  not  notice  that  the  Directive  introduced  the 
mandatory  use  of  the  harmonised  Union  codes,  which  required  changes  of  the 
national legislation, causing further delays.      

 

  The  use  of  harmonised  Union  codes  proved  to  be  misleading  for  many  Member 
States and instead of using the codes of Annex II to the Directive, they introduced 
other  codes.  In  exchanges  between  the  Commission  and  the  Member  States 
concerned,  these  mistakes  were  clarfied.  The  rectification  of  these  errors  required 
amendment of the national legislation, causing further delays.  

In 2016, conscious of the obligation related to the roadworthiness certificates due in 2018, the 
Commission  asked  the  opinion  of  the  Committee  about  a  possible  future  Commission  tool 
that would display the roadworthiness certificates, proof of tests and the vehicle registration 
documents. Based on the support of the Committee, the Commission launched the procedure 
and created the new tool where the specimen of the vehicle registration11 and roadworthiness 
documents12 can be checked.   

Member States notified their national  contact  points  by 20 May  2015 and have sent  regular 
updates since then, as set out by the Directive.              

Concerning the measures related to the mutual recognition of roadworthiness certificates, the 
preliminary  analysis  found  that  in  the  majority  of  the  Member  States  the  transposition  has 
been  satisfactory  and  further  clarification  will  be  required  in  only  a  handful  cases.  Most 
Member States made use of the optional measure to verify, in cases of doubt, the validity of 
the roadworthiness certificate.                

According to the preliminary analysis, it seems that most Member States have the necessary 
electronic communication between the testing centres and the competent authorities in place. 
the 
However,  clarifying 
roadworthiness  and  the  registration  authorities,  will  require  further  assessment  and  possible 
exchanges with the Member States.    

the  electronic  communication 

is  also  ensured  between 

if 

3.2.6  Odometer fraud13 

It appears from the preliminary analysis that the measures requiring Member States to ensure 
that the odometer data recorded at the previous roadworthiness test is made available during 
the  next  inspection,  as  soon  as  possible  electronically,  have  been  transposed  without  major 
problems.  

11 https://ec.europa.eu/transport/road_safety/topics/vehicles/vehicle-registration-certificate_en  
12 https://ec.europa.eu/transport/road_safety/topics/vehicles/roadworthiness-certificate_en  
13 With the use of the generous support of the European Parliament, the Commission has been working on a pilot 
project concerning the exchange of odometer data with volunteering Member States. The pilot project runs until 
the end of 2020. 

10 

 
 
                                                           
However as regards the obligation to introduce effective, proportionate, dissuasive and non-
discriminatory penalties for the case where an odometer is found to have been manipulated, it 
seems that the national  measures are in many cases rather generic, not specifically aimed at 
odometer fraud. The deeper analysis of the national measures and future exchanges with the 
Member States concerned will be aimed at clarifying these points.  

3.2.7  Testing centres, testing facilities and equipment, supervision of the testing 

centres, inspectors 

According  to  the  preliminary  assessment,  it  seems  that  there  are  no  transposition  gaps  in 
relation to the authorisation requirement of testing centres and in the general requirement to 
ensure the supervision of testing centres. Also, the general measures, requiring Member States 
to ensure that inspectors fulfil minimum competence and training requirements, seem to have 
been transposed without substantial problems. 

However, it seems, that the Commission will have to launch exchanges with several Member 
States  to  clarify  the  national  measures  aiming  to  transpose  Annex  III  on  the  minimum 
requirements concerning the roadworthiness facilities, Annex IV concerning the competence, 
training  and  certification  of  inspectors  and  Annex  V  concerning  the  detailed  tasks  of  the 
supervising body.  

2.  FEASIBILITY STUDY ON THE ELECTRONIC VEHICLE INFORMATION PLATFORM

14   

In line with the requirements of the Directive, the Commission contracted Unisys to carry out 
the feasibility study in the course of 2014. The final report was published in April 2015.  

The study identified three business cases or technical data flows:  

1.  Member  States  ->  Commission:  for  Member  States  to  submit  their  biannual 

national roadside inspection statistics   

2.  Testing  centres/Member  States, 

test  equipment  manufacturers  <->  vehicle 
manufacturers:  for  providing  specific  vehicle  technical  information  necessary  to 
carry out the periodic roadworthiness tests   

3.  Member  State  ->  Member  State:  for  the  notification  procedure  after  a  technical 
roadside inspection, for registration procedure and for periodic technical inspection  

The study concluded that in order to maximise the re-use of existing systems and taking into 
account cost-effectiveness, it would be more beneficial if for each purpose a separate system 
would  be  used  instead  of  developing  one  over-arching  system.  Also,  independently  of  the 
vehicle information data flow, a common data format and structure is a pre-requisite for the 
implementation of the Vehicle Information Platform (VIP). This will benefit all stakeholders 
by facilitating data exchanges and increasing data quality at all levels of the vehicle life cycle.  

Therefore if certain  conditions  for data protection, administrative cooperation, legal  barriers 
and  governance  conditions  can  be  ensured,  the  implementation  of  a  Vehicle  Information 
Platform may be feasible by extending existing systems. If these conditions cannot be met, the 
study  found  that  implementing  a  new  system  would  be  possible  but  at  additional  costs  and 
time. 

5.  SUMMARY – CONCLUSSIONS  

14 https://op.europa.eu/en/publication-detail/-/publication/9d809050-2e78-40a4-be65-16ce40a8e8b8/language-
en/format-PDF/source-120996274 

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The Roadworthiness Package adopted in 2014 introduced a number of novelties in the field of 
periodic roadworthiness testing, the technical roadside inspection of commercial vehicles and 
the vehicle registration documents, while at the same time it kept the majority of existing and 
functioning requirements in place.  

With the exception of two, Member States  have successfully  completed  the transposition of 
the  Directive’s  measures  into  their  national  legislation.  As  regards  the  compliance  of  the 
national  measures  with  those  of  the  Directive,  the  preliminary  assessment  indicates  that  the 
transposition appears to be overall satisfactory in the majority of Member States, however in 
some  cases  the  Commission  may  consider  launching  exchanges  with  the  Member  States 
concerned in order to clarify potential non-compliance issues.  

Concerning  the  effects  of  the  Directive  on  the  various  aspects  of  periodic  roadworthiness 
testing,  meaningful  conclusions  could  be  drawn  only  based  on  data  generated  after  three 
years’ uninterrupted period of application. Nevertheless the Commission will closely monitor 
the situation and follow up with an ex-post evaluation when the time comes.   

12